5780
                           DRAFT
           ENVIRONMENTAL IMPACT STATEMENT
                    PROPOSED REGULATION

                CRITERIA FOR CLASSIFICATION OF
                SOLID WASTE DISPOSAL FACILITIES
                       (40 CFR PART 257)
                         PREPARED BY
                    OFFICE OF SOLID WASTE
            U.S. ENVIRONMENTAL PROTECTION AGENCY
                   WASHINGTON, D.C. 20460
                       tf/EFFEN W. PLEHN
               DEPUTY ASSISTANT ADMINISTRATOR
                      FOR SOLID WASTE
                         APR IL 1978     y s Envlfonmentai protection Aftncy
                                         .Region 5, library (PL-12J)
                                         77 West Jackson Boulevard, 12th Flow
                                         Clปicaซo. fL 60604-3590

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    i
    |   UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
    ?                  WASHINGTON. D.C. 20460
                       June 12, 1978
                                                  OFr'.CE OF WATER AND
                                                 HAZARDOUS MATERIALS
DRAFT ENVIRONMENTAL  IMPACT  STATEMENT  ON  PROPOSED "CRITERIA FOR
CLASSIFICATION OF SOLID WASTE  DISPOSAL FACILITIES"


     Public Notica of the Availability of  this  EIS  was published

in the Federal Register on  April  21,  1978.   The EIS consists of

two volumes.  All persons sent Volume I  are  also being sent the

Appendices  (Volume II).

     The public comment period on the EIS  has been  extended and

will end at 4:30 p.m. on June  30, 1978.  The public comment

period on the proposed "Criteria" extended from February 6 to

June 12, 1978.

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                           ERRATA

         ซ

DRAFT ENVIRONMENTAL IMPACT STATEMENT: PROPOSED REGULATION: CRITERIA
SOLID WASTE DISPOSAL FACILITIES. Office of Solid Waste, USEPA,
April 1978.


Volume I
p. 1-19, para. 4:    "31X" not "37%"; "69%" not "63%"

p. 1-20, para. 2:    "$1.34 per ton" not "$0.66 per ton"; "$2.95  -
                     per ton" not "$1.19 per ton"

p. IV-15, Table 30:  Shows combined costs; total total is
                     $1,661,169,512" not "$1,676,723,500"

p. IV-46, para. 2:   "require avoidance remedial action and..." not
                     "require preventive action for ground-water
                     protection and..."

p. IV-58, Table 46:  Shows combined costs
Appendices

p. V-3, Table 22:    An "X" indicates equivalency of state regulations
                     to the proposed criterion

p. V-6, last line:   "A2 = (0 + M)" not "A2 = (0 + M)  (6.144)"

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                             SUMMARY
              DRAFT ENVIRONMENTAL IMPACT STATEMENT
                    FOR PROPOSED CRITERIA FOR
                  CLASSIFICATION OF  SOLID WASTE
                       DISPOSAL FACILITIES
                 Environmental  Protection Agency
                      Office of Sol id Waste

1.    Type of Action
     Administrative Action (Regulatory)

2.    Brief Description of Action

     On February  6,  1978, EPA published  in the  Federal  Regi ster
proposed  "Criteria  for  Classification  of  Solid Waste  Disposal
Facilities" (43 Fed.  Reg. 4942).  The  proposed action prescribes
a  new  set   of   regulations  which   set  minimum  criteria  for
classifying solid  waste  disposal  facilities  according  to  their
probability  of  causing  adverse  impacts  on  health  and  the
environment.  The regulations have been issued under authority of
the  Solid  Waste   Disposal  Act  as  amended  by  the  Resource
Conservation  and  Recovery Act of 1976  (Pub.  L.  94-580),  and  the
Federal Water  Pollution Control Act  as  amended by the Clean  Water
Act of 1977 (Pub. L. 95-217).

3.    Summary of Beneficial and  Adverse  Environmental  Impacts

     a.   In  general,  implementation  of  the  proposed  Criteria
          will  result in  significant   improvements  in  environ-
          mental  quality, with  beneficial impacts on such factors
          as:      environmentally   sensitive   areas   (wetlands,
          floodplains, critical habitats  for  endangered  species,
          permafrost  areas,  and sole  source  aquifers),  surface
          water,  ground water, air quality, soil  quality (amount
          of  cadmium  and  other contaminants  entering  the  food
          chain), disease vectors, and  public  health and  safety.

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b.   The  general  effects of  the  proposed Criteria  will  be
     threefold:

          Many existing facilities (such as landfills, land-
          spreading  operations,   and  surface  impoundments)
          will close  or  be forced to close,  because of the
          cost or physical  impossibility of compliance;
          Many other  existing  facilities  will  upgrade their
          operations  in conformance with  a State compliance
          schedule  and will  reduce to  acceptable  levels or
          eliminate  the   adverse   environmental  effects  of
          their operations;
          New  and  expanded  solid  waste  disposal  sites,
          resulting   from  previous  c.l'bs'ufesT/consol "" dati onc>
          .and  new demands, will  be located,  designed,  and
          operated  in such  a  way  as to  ensure a reasonable
          probability  of   protecting   health,  safety  and
          environmental quality.

c.   In  some  cases where existing  facilities  are  closed or
     upgraded, the  environmental  effects  of  past operations
     (for  example, caused  by  location   in  wetlands/f 1 ood-
     plains/critical  habitats; leachate  and  gas generation,
     and migration; and heavy  metal application to land) may
     still continue for some time into the future.
d.   Bringing  all   solid-waste   disposal   facilities  into
     compliance with  the proposed Criteria will increase the
     cost   of   landfill ing,   landspreading,   and   surface
     impoundment   operations.      An   annualized   cost   of
     approximately  $1650 million  per year will be neided to
     bring  all  sites  into compliance.   Of this cost, $1150
     million  per  year will  be necessary to bring sites into
     compliance   with  existing  State  regulations  'State-
     standard-induced  costs).    The  remaining  $500 million
     per year will  result directly from the Criteria where
                           ii

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          the  Criteria  are  more  stringent  than existing  State

          regulations (Criteria-induced costs).


4.   Alternatives Considered


     a.   Proposed Action

     b.   Less Restrictive Regulations
     c.   More Restrictive Regulations


5.   Federal, State, and Local Agencies from Which Written

     Comments Have Been Requested


     The proposed regulation has been distributed to thousands "f
individuals  and   organizations  representing all  sectors of  our

society.   The draft EIS  is  also  being distributed  to  a diverse
group of individuals and organizations including, but not limited

to, the following examples:


Other Federal Agencies

Department of Interior (U.S.G.S., Fish and Wildlife, Bureau
     of Mines, MESA, Office of Surface Mining)
Department of Health, Education, and Welfare (Food and  Drug)
Department of Agriculture
Department of Commerce
Department of Energy
Department of Defense
Office of Management and Budget
U.S. General  Accounting Office

State Government

All 50 State  solid waste management offices
National Governors'  Association
National Conference of State Legislators
National Association of State Attorneys General
Conference of State Sanitary Engineer;,
                               111

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Local Government

National  Association of Regional  Councils
National  Association of Counties
National  League of Cities/U.S. Conference of Mayors
International  City Management Association

Solid Waste Management Professional  Groups

National  Solid Waste Management Association
Governmental Refuse Collection and Disposal Association
American  Public Works Association
Association of Metropolitan Sewerage Authorities

Professional Associations

American  Society of Civil Engineers
American  Consulting Engineers' Council
Water Pollution Control Federation

Environmental, Health, and Citizens Groups

Sierra Club
Environmental  Action, Inc.
Environmental  Action Foundation
Environmental  Defense Fund
Natural Resources Defense Council
National  Wildlife Federation
National  Environmental Health Association
Izaac Walton League
League of Women Voters

Trade Associations

American Mining Congress
American Petroleum  Institute
Manufacturing Chemists Association
National  Food Processors Association
American Water Works Association
National  Water Well Association
American Farm Bureau Federation
                                fv

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6.   Date Available to the Public

     The Draft  Environmental  Impact Statement  has  been provided
to  the  Office  of  Federal Activities,  EPA,  for  the  purpose  of
publishing  an  official   public  notice  of  availability  in  the
Federal  Register.   This  notice  is  anticipated by April 21,  1978.
The 45-day  public  comment period  for  the  Draft  EIS  begins with
the issuance  of this  notice.   Copies of  the  Draft  EIS may  be
obtained by  writing:   DRAFT  EIS,  Office of  Solid  Waste,  WH564,
U.S.  EPA,  Washington, D.C. 20460,  Attention:   Kenneth Shuster.
Comments should be  sent to the same address.

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                        ACKNOWLEDGEMENTS
     This  EIS was  prepared under EPA contract  number  68-01-4677
to  Emcon   Associates,   Inc.     The  major   contract   personnel

contributing to  the EIS were:


Emcon Associates,  Inc.

     Don Andres
     Fred Cope
     Ed Griffith
     Donna Herndon
     Audrey Johns
     Gail  Karpinski
     John Pacey
     Susan Rex
     Jerry Yudelson


Dec i s i o n Systems,  Inc.

     Jack Berry
     Robert Colonna
     Virginia Farris
     Janice Mahady
     Al Vitberg
     The  EPA project  officer  was Kenneth A. Shuster,  Office  of
Solid  Waste.   Other  EPA contributors  were:   Les Otte,  Bruce
Meddle,  and  John  Skinner,  also  of  the  Office  of  Solid  Waste;
Richard  Lawrence,  Office of  Federal  Activities;   and  Victoria
Potter and Ed Brandt, Office of Planning and Management.

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                        TABLE  OF  CONTENTS


                                                                 Page


I.    EXECUTIVE  SUMMARY                                            1-1

     A.    Description of Action                                  1-2

     B.    Results of Impact Analyses                             1-10

II.   INTRODUCTION                                               II-l

     A.    Legal  Basis for Action                                 II-l

     B.    PurposeofRegulation                                 11 - 8

     C.    Relevant Federal  Laws                                 11-10

     D.    Coverage                                              11-12

     E.    Regulatory Approach                                    11-14

     F.    Purpose of EIS                                        11-22

     G.    EIS Approach                                           11-23

III. MAJOR CRITERIA ALTERNATIVES  AND ENVIRONMENTAL             III-l
     CONSEQUENCES FOR EACH ADVERSE EFFECT

     A.    Environmentally Sensitive Areas                       III-3
          1.   Definition; Identification of Areas Considered   III-3
          2.   Wetlands                                          III-4
          3.   Floodplai ns                                      111 -11
          4.   Permafrost Areas                                 111-14
          5.   Critical  Habitats                                III-lfi
          6.   Recharge  Zones of Sole-Source Aquifers           III-'P
          7.   Summary Technology, Economic, and                111-..;)
              Environmental Impact Analysis

     B.    Surface Water                                         III- ;'8
          1.   Importance; Adverse Effects  from Improper        III-?8
              Di sposal
          2.   Regulatory Alternatives and  Environmental        111-30
              Consequences
          3.   Summary Technology, Economic, and                111-33
              Environmental Impact Analysis

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C.   Ground Water                                         111-39
     1.   Importance; Adverse Effects from Improper        111-39
         Di sposal
     2.   Major Regulatory Issues                          111-41
     3.   Regulatory Alternatives and Environmental         111-42
         Consequences
     4.   Summary Technology, Economic,  and                 111-45
         Environmental  Impact Analysis

D.   Air                                                  111-52
     1.   Importance; Adverse Effects from Improper        111-52
         Di sposal
     2.   Regulatory Alternatives and Environmental         111-53
         Consequences
     3.   Summary Technology, Economic,  and                 111-55
         Environmental  Impact Analysis

E.   Application to Land Used for the Production          111-60
     of  Food Chain Crops
     1.   Importance; Adverse Effects from Improper        111-60
         Di sposal
     2.   Regulatory Alternatives and Environmental         111-68
         Consequences
     3.   Summary Technology, Economic,  and                 111-74
         Environmental  Impact Analysis

F.   Disease Vectors                                      111-82
     1.   Importance; Adverse Effects from Improper        111-82
         Disposal
     2.   Regulatory Alternatives and Environmental         111-83
         Consequences
     3.   Summary Technology, Economic,  and                 111-84
         Environmental  Impact Analysis

G.   Safety                                               111-86
     1.   Explosive and  Asphyxiating Gases                 111-86
     2.   Fires                                            111-88
     3.   Bird Hazards to Aircraft                         111-89
     4.   Access                                           111-91
     5.   Summary Technology, Economic,  and                 131-92
         Environmental  Impact Analysis

H.   Aesthetic and Other Environmental  Effects            111-99
     1.   Importance; Adverse Effects from Improper        111-99
         Di sposal
     2.   Regulatory Alternatives and Environmental         111 -10 0
         Consequences
     3.   Summary Technology, Economic,  and                 III-101
         Environmental  Impact Analysis

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IV.   IMPACT EVALUATION OF PROPOSED ACTION                       IV-1

     A.   Approach and Methodology                              IV-1

     B.   Environmental Effects and Cost Impacts; Summary       IV-7
          of Proposed Alternative (By Criterion)

     C.   Environmental Effects and Cost Impacts Summary        IV-18
          of Proposed Alternative (By Disposal Method)

     D.   General Benefit Discussion                            IV-46

     E.   Social/Equity Impacts Summary                         IV-48

     F.   Irreversible and Irretrievable; Short and Long        IV-66
          Term Impacts

     G.   Energy and Material Use                               IV-69

V.   REFERENCES                                                  V-l


APPENDICES (Separate Volume)

I.   TEXT OF CRITERIA
II.  RELEVANT FEDERAL LAWS
III. TYPES OF DISPOSAL FACILITIES
     A.   Landfills
     B.   Landspreading
     C.   Surface Impoundments
IV.  ADVERSE EFFECTS AND CONTROL TECHNOLOGIES
     A.   Environmental Sensitive Areas
     B.   Surface Water
     C.   Ground Water
     D.   Air
     E.   Application to Land Used for the Production
          of Food Chain Crops
     F.   Disease Vectors
     G.   Safety
     H.   Aesthetic and Other Environmental  Effects
V.   ECONOMIC IMPACT ANALYSES
     A.   Methodology and Major Assumptions
     B.   Analysis of State Peculations vs.  Federal Criteria
VI.  WASTE AGE SURVEY OF LANDFILLS
VII. EPA MEMO ON LANDSPREADING
VIII.REFERENCES
IX.  BIBLIOGRAPHY

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                   LIST OF TABLES AND FIGURES


Table                                                         Page

 1   National  Environmental  Improvement  as a Result            1-12
     of Criteria

 2   Typical  Control  Technologies Used to Estimate             1-14
     Costs for Proposed Alternatives

 3   Combined Cost by Criterion, Disposal Method,  and          1-16
     Regulatory Consideration

 4   Annualized Cost Impacts of Proposed Criteria               1-18

 5   National Annualized Cost Summary                          1-20

 6   Annualized Cost Impacts of the Proposed, More             1-22
     Restrictive, and Less Restrictive Alternatives

 7   Proposed Criteria:  Comparative Percentage Costs for      1-24
     Each Disposal Method

 8   Equity Impacts of Criteria                                1-26

 9   State Breakdown of Criteria-Induced Costs for             1-32
     Landfills, Surface Impoundments, and Landspreading

10   Relevant Federal Laws                                    11-10

11   Sources of Waste to be Regulated by Proposed Criteria    11-13

12   Type of Standard Used to Assess Compliance               11-19
     with Criteria

13   Total Area of Wetlands in United States in 1956         III-6

14   Environmentally Sensitive Areas:  Comparison of         111-26
     Annualized Incremental Costs Based Upon Disposal
     Method and Regulatory Alternative

15   Environmentally Sensitive Areas: Economic and           111-27
     Environmental Comparison of Alternatives

16   Surface Water:  Comparison of Annualized Incremental    111-37
     Costs Based Upon Disposal Method and Regulatory
     Alternati ve

17   Surface Water:  Economic and Environmental              111-38
     Comparison of Alternatives

18   Ground Water:  Comparison of Annualized Incremental      111-50
     Costs Based Upon Disposal Method and Regulatory
     Alternative

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19   Ground Water:   Economic and Environmental                111-51
     Comparison of Alternatives

20   Air:  Comparison of Annualized Incremental  Costs        111-58
     Based Upon Disposal Method and Regulatory
     Alternative

21   Air:  Economic and Environmental  Comparison of          111-59
     Alternati ves

22   Land Application to Food Chain Crops:   Comparison       111-80
     of Annualized Incremental Costs Based Upon Disposal
     Method and Regulatory Alternative

23   Land Application to Food Chain Crops:   Economic         111-81
     and Environmental Comparison of Alternatives

24   Safety:  Comparison of Annualized Incremental Costs      111-97
     Based Upon Disposal Method and Regulatory Alternative

25   Safety:  Economic and Environmental  Comparison of       111-98
     Alternatives

26   Aesthetics:  Comparison  of Annualized Incremental       III-104
     Costs Based Upon Disposal Method and Regulatory
     Alternative

27   Aesthetics:  Economic and Environmental Comparison      III-105
     of  Alternatives

28   Summary  of Major Environmental Benefits                  IV-9
     (By Criterion)

29   State-Standard-Induced vs. Criteria-Induced              IV-13
     Annualized Costs for Landspreading,  Landfills,
     and Surface Impoundments

30   Disposal Method Cost Summation:  Upgrade and Closure     IV-15

31   Landfill Data Base                                       IV-20

32   Landfill Costs  by Site Size                              IV-24

33   State-Standard-Induced vs. Criteria-Induced              IV-28
     Annualized Landfill Costs

34   Combined Economic  Impact of Proposed Regulations         IV-29
     by  State and Criterion:  Landfills

35   Data  Base and Cost Summation:  Surface Impoundments       IV-32

36   Surface  Impoundment Technology Costs per Site            IV-34
     by  Criterion

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37   Annualized Cost for Surface Impoundments by              IV-35
     Selected Criteria (Federal  and State)
38   Total Costs for Surface Impoundments:                     IV-36
     Environmentally Sensitive Areas
39   Total Annualized Costs for Surface Impoundments:          IV-37
     Ground Water
40   Total Annualized Costs for Surface                       IV-38
     Impoundments:  Safety
41   Landspreading Data Base                                  IV-41
42   Landspreading Cost Summation                             IV-43
43   Well Contamination Case Studies                          IV-47
44   Incremental Per Capita Upgrading and Closure             IV-51
     Costs for Landfi11s
45   States with Highest Percentage of Wetlands               IV-53
46   Criteria Impact by State:  Landfills,  Surface            IV-58
     Impoundments, Landspreading
47   Incremental Criteria-Induced and Combined Upgrading      IV-60
     Cost/Ton:  Landfills
48   Impact of  Industrial Surface Impoundments on             IV-62
     State-Standard-Induced and Criteria-Induced
     Annualized Costs
49   National Summation Cost Distribution:   Industrial        IV-64
     Surface  Impoundments
50   Environmental Impact Evaluation                          IV-67
51   Energy Potentially Recoverable from Residential          IV-72
     and  Comercial Solid Waste
52   Post-Consumer Waste and Maximum Material Recycle         IV-75
     Potentials Relative to U.S. Consumption and
     Production for Selected Materials, 1971
F1gure                                                        Page
1    Major Wetlands                                          III-5

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                      I.   EXECUTIVE  SUMMARY
     This  Environmental  Impact  Statement  (EIS)  identifies  the
adverse effects from improper solid waste disposal  and summarizes
the major  regulatory  alternatives considered  in  the  development
of a  proposed  regulation  to minimize these adverse effects.   It
also  summarizes the environmental, economic, and other impacts of
the major regulatory alternatives.

     The  EIS   was   prepared  to  explain  the   background  of  the
proposed regulation and the rationale that was used  in developing
it.   In  developing  the regulation,  EPA  considered a  number  of
alternative  approaches  and  rejected    those  whose   potential
environmental,   technological,   physical,  economic,  social,   or
legal  consequences were unacceptable.

     This  executive  summary attempts  to familiarize  the  reader
with   (1) the   contents  of   this  environmental  impact  statement,
(2) the purpose, coverage,  and  content of the  proposed regulation
for solid  waste disposal   facilities, and (3) the  major environ-
mental,  economic,   equity,  and   other  impacts  of  the  proposed
regulation, and of major regulatory alternatives to the proposed.
Also  discussed are the regulatory development  process, regulatory
alternatives considered, and the  data  base,  data  gaps,  and  key
assumpti ons.

     The  executive  summary  includes  references to where  in  the
report each topic is discussed  in more detail.
                               1-1

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 A.  DESCRIPTION OF ACTION

     In   the   February   6,   1978   Federal   Regi ster   (43 Fed.
Reg. 4942), EPA  proposed  "Criteria  for Classification  of  Solid
Waste Disposal  Facilities" (40 CFR Part 257).*

1.    Legal Basis

     The Criteria  are  proposed  under  the  authorities of Sections
1008(a)(3) and 4004(a) of the Solid Waste  Disposal  Act as amended
by  the Resource  Conservation  and  Recovery   Act  (RCRA)  of  1976
(Pub.  L.  94-580)  and Section 405(d) of the  Federal  Water Pollu-
tion Control Act  (FWPCA)  as  amended by the Clean Water Act (CWA)
of  1977 (Pub.  L. 95-217).

     According  to  RCRA,  the  proposed  regulations  are to contain
minimum  criteria  for  determining  which  solid  waste  disposal
facilities  shall  be  classified  as  posing no  reasonable probab-
ility  of  adverse  effects  on  health or the  environment.   Facil-
ities  not  meeting  the Criteria  are classified as open dumps, are
prohibited, and must be closed,  or upgraded according to a State-
established   compliance    schedule   containing  an   enforceable
sequence of actions leading to compliance.  According to the CWA,
EPA  is to develop guidelines for the  disposal  or  utilization of
sludge.  The Criteria are proposed as partial fulfillment of this
requirement.   All  public  wastewater  treatment works  owners and
operators  who  dispose  of  or  utilize  sludge  on  the  land  must
comply with the Criteria.
* T h e s e proposed regulations are hereinafter referred to as "the
Criteria."  The full text of the Criteria appear in Appendix I,
Volume II.  The preamble which also appeared in the Federal Register
contains a lengthy  background discussion and e x p 1 a n a I i o n ,  5"ut is not
reproduced in the EIS.

                                1-2

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     The  RCRA  solid  waste  disposal   Criteria  reouirements  and
implementation  provisions,  and leqislative  history  and  intent,
and the  CWA  are discussed  further  fp the first  few  sections  of
Chapter II.

2.   Purpose  of Regulation

     The purpose of  the Criteria  is  to  provide minimum  national
standards for  the  protection of health  and  the environment  from
solid waste  disposal  facilities.

3.   Co v e r a g e

     The Criteria  apply  to all fac'lities for the  "disposal"  of
"solid  waste"   as  these  terms  are  defined   in  RCRA,  incltdinn
landfills,   dumps,   surface   impoundments   (ponds,   pits,   and
lagoons), and 1andspreading sites.  . Certain agricultural,  mining,
radioactive,   and  other  wastes  and   facilities   are  excluded,
however, as  discussed in Chapter II, Section  D.

4.   Adverse  Environmental Impacts  (Droblem Identification)

     The first  step  in  developing  the proposed  regulation was to
identify all  the adverse effects of improper  solid waste  disposal
and their relative impacts  on  health and the environment.   The
adverse  effects  of improper  solid  waste disposal  are  numerous.
These   include  adverse   effects   on  wetlands,   floodplains,
permafrost areas,  habitats  of  endangered species,  and  recharge
zones  of  sole  source  aquifers;  pollution  of surface-water  and
ground-water   resources;   air  pollution;   contamination  of  food-
chain  crops;  harboring  disease vectors;   creating  noise,  litter,
odor,   and  other aesthetic  nuisances;  and explosive  or  asphyxi-
ating  gases,   auto  traffic  and  air  hazards, fires,  and  other
health and safety  hazards.   These  adverse effects and the impor-
tance   of  the  affected   resource  arc   summarized   in  Chapter II,
Section A, and  discussed  in  Chapter III  together  with regulatory
                               1-3

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alternatives  designed  to   prevent  or  minimize  them.    A  more
detailed discussion  of  the adverse effects,  regulatory  alterna-
tives, and technological options is included in Appendix  IV.

     Solid waste management is  vital  to the protection  of public
health  and  the  environment   (e.g.,  Ref.  72)  and  solid  waste
disposal  facilities   are  a necessary   component  of solid  waste
management.   Even with  increased  resource  and energy  recovery
systems  there  will   be  a  need  for solid  waste disposal  sites.
Yet,  for  political  and  other  reasons,  suitable new solid  waste
disposal  sites  are  often  very  difficult  to  obtain.    For  the
protection of public  health and  the environment,  it is  important
to  ensure  that  disposal  facilities  are  available,  that  new sites
can  be  obtained,  and   that  the  available  sites  are  located,
designed,  constructed,  operated,  and  maintained so  as  to protect
the  environment.   To help  in  the  aquisition  and  development of
new  disposal  sites,  the Criteria must  be  written  to  ensure that
sites  which  comply  with  the  Criteria  do  not adversely affect
public health or the  environment.

5.   Regulatory Approach/Regul atory Alternati ves

     Once  the  adverse   environmental   effects  of  each   type  of
disposal facility were  identified,  the  next task  was to  identify
all  the regulatory control options.  Next, the  regulatory options
were  evaluated  in terms of feasibility,  environmental  benefit,
and  economic, equity, and other impacts.

     EPA   recognizes   there  are   many   factors  which  must  be
considered in determining if there nay  be an adverse impact, what
the  magnitude  of  the impact may  be,  and what  regulatory options
^xist  to   effectively  control  the  impact.   Many  of  the factors
vary  from  site to  site, including climate,  hydrology,   geology,
the  amount and  types of  wastes,  :^nd  ground-water  and   surface-
water  proximity  and   usage.   Since the  Criteria  are  basically  a
State-enforced  standard,  one  aim  in  developing the Criteria was
                                1-4

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to be as specific as possible without reducing the flexibility of
State  solid  waste  management,  and  enforcement  agencies   and
disposal  site  engineers  and operators  to  take into  account  the
site-by-site variations,  and select technologies and make assess-
ments based on local conditions.

     The regulatory approach is discussed in greater detail  below
and in Chapter II, Section E.

     a .    Li sti ng of Envi ronmental Performance and
          Operational  Standards

          Two  types of  regulatory  options  were   identified  and
evaluated:    environmental  performance  standards  and  operational
standards.    EPA  decided  to establish  environmental  performance
standards  for  each potential  adverse  environmental  effect  of
improper disposal,  and  to  use operational  standards  in  addition
where they were necessary to clarify how the performance  standard
is  to be  achieved.   In  all  cases where a  specific  operational
technology  or  standard was  specified,  it was worded so as not to
inhibit the advancement of technology development nor to  preclude
the use of other equally effective,  site-specific, technologies.

      A   lengthy   listing   and   discussion    of   the   regulatory
alternatives considered  is  in  Appendix  IV.   The proposed, a  more
restrictive, and  a  less  restrictive alternative for each adverse
effect are analyzed in depth in Chapter III.

      b.    Relevant Federal Laws

          In  order to  avoid  duplication,   inconsistencies,   and
confusion,   the  Criteria  utilize  other Federal   regulations  or
approaches  where   appropriate.    For example,  the wetlands  and
surface    water   criteria   utilize   the   NPDES   permit   system
established  for  point  source  discharge   of  pollutants  under
Section  402 of the Federal Water  Pollution  Control Act Amendments
                               1-5

-------
of 1972 (Pub. L. 92-500);  the  sole-source  aquifer recharge  zones
designated under the Safe Drinking Water Act  (Pub.L.  93-523)  were
utilized in the  environmentally sensitive area  criterion;  and the
ground-water criterion  utilizes  the approach of  the  Underground
Injection  Control Program  proposed  under  the  Safe Drinking  Water
Act.

     A  listing  of   relevant  Federal laws  and  regulations  is  in
Chapter II,  Section C,   and  a   discussion   of   each   is   in
Appendi x II.

     c.   Technical  Feasibility

          Even  when operational  standards  were  not  specified,  it
was necessary to identify the design  and  operational  technology
that is available to be used  to achieve the environmental  perfor-
mance  standard  or   goal.   The technology  feasibility  evaluation
included an assessment of current usage, reliability,  unit costs,
and  effectiveness.     The  major  technologies   identified  are
discussed in Chapters III and IV, and in Appendix IV.

     d.   Environmental Benefits  vs. Economic  and Equity  Impacts

          Once the  technological  feasibility was  determined, the
environmental benefits  were  compared  to  the economic  (both cost
and  benefit)  and   equity  impacts  for  each   major  regulatory
alternative  to  make a final  selection  of  the  proposed  approach.
These  trade-off  evaluations  are   summarized in  Section B  of this
summary  and discussed  at length  in  Chapters  III  and  IV,  and
Appendix V.
                               1-6

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6.    The Criteria

     The proposed  regulation contains criteria  which  address  the
following adverse  effects:

     (1)  environmentally sensitive  areas  (wetlands,  floodplains,
          permafrost  areas,  critical  habitat   for   endangered
          species,  and recharge  zones  of sole-source  aquifers)
     (2)  surface  water
     (3)  ground water
     (4)  air
     (5)  application  to  land  used  for the  production  of  food
          chain crops
     (6)  disease  vectors
     (7)  safety (explosive  and  asphyxiating gases,   fires,  bird
          hazard to aircraft, and access).

     The proposed  Criteria  are  given in  Appendix I (Volume  II)  as
they appeared in the Federal Regi ster  on February 6,  1978.

7.    Basic Data

     In  order  to   make  rational  decisions  concerning regulatory
approaches and  to  evaluate  their impacts,  the  following  data  is
needed  for   each  type  of   disposal  facility  (landfill,  surface
impoundment,  and 1andspreading):

     (1)  Number and size of existing  sites
     (2)  Locations and  conditions  of sites,  from which  a  deter-
          mination  can  be  made   as  to  the   number of  sites  to  be
          upgraded  and the  number to be  closed and replaced
     (3)  Control  technologies and  unit costs  needed to  upgrade
          sites or  for new  sites  to  comply  with the Criteria.
                               1-7

-------
     The data base used in developing this  EIS  is  discussed  below
and  described  further  in  Chapter  IV  and  in  the  Appendices,
Volume II.

8.   Data Base and Gaps

     Unfortunately  for   the  EIS,   the  inventory   of   disposal
facilities   to be  developed  under  RCRA is  to  occur after  the
regulation  is finalized.   However,  good  information  exists  on  the
number and  sizes  of municipal  landfills,  on the potential  adverse
environmental effects  of  landfilling,  surface  impoundments,  and
landspreading, and  on the  basic  technologies  needed to  achieve
specific levels  of  environmental  protection (with  the  exception
perhaps of ground-water protection).  Unfortunately,  a  number of
assumptions   had  to  be made because  the  following  information is
sketchy or  not well  known:

     (1)  number  and size of on-site industrial landfills
     (2)  number  and  size of  surface impoundments  (an estimate--
          considered   to    be   incomplete   or   conservative--is
          available  on  the  number of  surface  impoundments
          Reference 107)
     (3)  number   and   size  of  1andspreading  operations on  food
          chain  cropland — specifically,  industrial   sludges  and
          sludges   from   the    smaller   municipal   waste   water
          treatment works
     (4)  the specific locations and conditions of all categories
          of solid waste  disposal  facilities.

     The data base includes  18,500 landfills  by size,  and 110,000
surface impoundment facilities (averaging 2 to  3 impoundments  per
facility),  by SIC code.
                                1-8

-------
9.   Key Assumptions

     To fill  the  data gaps,  the  following key  assumptions  were
made:
     (1)  For surface  impoundments,  two  sizes  were assumed:  2.5
          acres  and  50  acres..    Fifty  percent  of  the  surface
          impoundment   facilities   in   specific   mining,   paper
          products, and utility service industrial groups contain
          an  average  of  one   50-acre   surface   impoundment  per
          facility.    All  other  surface  impoundment  facilities
          contain  an  average  of three  2.5-acre  impoundments  per
          facility.
     (2)  For surface impoundments, site lining wris assumed to be
          needed at 50% of all  sites to meet the proposed ground-
          water alternative; at  75%  to  meet the more restrictive
          alternative;  and  at  25%  to  meet the  less  restrictive
          alternati ve.
     (3)  All landfill sites were grouped in one of the following
          three  categories:    (1)  permitted,  (2)  authorized,  and
          (3) illegal.    The  following  assumptions  were  made
          regarding these categories:
               Permi tted sites were  assumed  to  comply with State
               regulations and their  condition  was  assumed to be
               a  function  of  the  extent  to  which  the  State's
               solid waste  regulations  comply with  the  proposed
               Criteria.   Thus,  the  costs   for  these sites  to
               comply   with   the   Criteria   is   the   amount   of
               upgrading needed on a criterion-by-criterion basis
               for  the  difference  between   the  current  State
               regulations and the proposed Criteria.
               Authori zed sites are assumed to meet current State
               regulations except those for existing ground-water
               and  surface-water  standards.    The costs  for  thf
               authorized sites  to  comply  with  the  Criteria  are
               the  same  as  for  the  permitted sites (based on  any
               differences  between   the  State  standard   and  thp
               Criteria), plus any  additional  costs  necessary to
               comply  with   the   ground-water  and  surface-water
               cri teri a.
                               1-9

-------
          c.    111eoal  sites  are assumed to be open dumps;  these
               require  closing  under  RCRA within  5 years.

     (4)   The   number   of   facilities  in   an  environmentally
          sensitive  area is related  to  the  amount of  land within
          a   State   that  can  be  classified  as  environmentally
          sen si ti ve.
     (5)   The  landspreading criterion impacts  only landspreading
          operati ons.
     (6)   No   landspreading  occurs  in environmentally  sensitive
          areas.
     (7)   Upgraded  and  new  facilities have an average  site  life
          of  10 years.

     The   data  base,  assumptions,  and methodology  are  discussed
further in Chapters  III and IV,  and in the  Appendices.

B.    RESULTS  OF IMPACT  ANALYSES

     The   disposal  of   solid  wastes  has been  grouped  into  three
general  disposal  methods  for   purposes of identifying  environ-
mental, cost,  and other impacts.  These  categories are landfills,
landspreading,  and  surface   impoundments  (pits,    ponds,   and
1agoons).

1.    Environmental  Benefits

     The  benefits to be obtained by the  proposed  Criteria include
the  prevention  or  minimization  of  adverse  impacts  at  new
facilities and their gradual elimination  or reduction at present
disposal  sites.  Some  of the  specific benefits include:

          protection of  wetlands, critical habitats,  permafrost
          areas,  and sole source aquifers;
                               1-10

-------
          reduction  of the  potential  for causing an increase  in
          flooding   and   pollution   problems   from   landfills   in
          f1oodpiai ns ;
          reduction  in surface  water  pollution from solid waste
          disposal ;
          reduction  in  ground-water  resource  damage  from  leachate
          pollution;
          improvements  in air  quality  near  landfills;
          restrictions  on the  application  of  harmful  substances
          to lands  producing food-chain  crops;
          improvements  in   public  and  occupational  health   and
          safety  in  and near landfills;
          control  of explosive and  asphyxiating gases;
          reduction  in  bird  hazards  to  aircraft  and fire  and
          smoke  hazards;  and
          controlled access  to solid waste  disposal  sites.

     Table 1 summarizes  the  magnitude  of the  anticipated  national
environmental   benefits   or   improvements  as  a  result   of   the
proposed  Criteria   and   as   contrasted   to  the  more   and   less
restrictive alternatives  presented  in Chapter  III.   In  general,
the more  restrictive  are bans  on  disposal   in  specific  areas  or
zero degradation and  the less  restrictive  are status quo or  do
not address the adverse  impact.   In several  areas no alternative
to  the  proposed  was considered  practical.   Although  subjective,
these assessments  take   into  consideration  (1) the  condition  of
existing sites,  (2)  the  anticipated average improvement per  site,
and (3)  the number  of  sites.

     The  major  national  environmental  benefits of  the  proposed
Criteria  are:   wetlands  and  ground-water  protection  from  land-
fills and  surface   impoundments,  and  gas  control   at  landfills.
The proposed  Criteria  achieve essentially the  same  magnitude  of
national   environmental   benefit   as   the   more   restrictive
alternati ve.
                               1-11

-------
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-------
     At  this   point,   it  is  important  to  point   out  that  new
disposal  sites being  permitted  by  the  States comply with  most if
not all  of  the Criteria,  so  the  impact  of  the Criteria  on  new
disposal  sites  being  developed  according  to the  relatively  new
State regulations and  procedures  is  expected to be minimal.   The
table  of environmental  benefits  refers  to  existing  conditions
which States  and  disposal  site owners  and operators  are  already
gradually upgrading or eliminating.   As discussed  earlier, solid
waste disposal  sites  are a necessity.   Unless  alternative sites
can  be   located  and  developed,  old  ones cannot  be shut  down.
Therefore,   achieving   some  environmental  improvements  can be  a
very  slow  process.    In  addition  to  being  a   slow  process,  the
reason these  improvement's have  not already been achieved  is  that
attention to  solid-waste disposal  and  ground-water  protection,
including   land   use/ground-water   use   planning,   are   recent
developments in the environmental  arena.

2.   Economic Impacts

     The  economic  impacts  were  determined  for  the  proposed
criterion,   a  more  restrictive  regulatory alternative, and a  less
restrictive alternative.   The  economic impact  of each regulatory
alternative  was   determined  for  each   disposal  method and  each
group  of adverse  effects or criteria,  as  follows:   (1) environ-
mentally sensitive  areas,   (2)  surface water,   (3)  ground  water,
(4) air, (5) application to land  used  for the  production of  food
chain  crops,  (6)  disease vectors, (7)  safety,  and (8)  aesthetic
and other environmental effects.

     In  order  to  develop  the   economic  impacts, a  "typical"  or
"average" condition was assumed for various sizes of each  type of
disposal   facility.     Then  the  technologies  required,  and  the
associated  unit costs, to comply with the Criteria  were developed
for each site-size category  for  each  disposal  type.  This  was
done  for the  proposed criterion,  a more  restrictive,  and  a  less
restrictive  regulatory alternative.
                               1-13

-------
     Table  2  summarizes  typical  control   technologies  used  to
estimate costs  for  the proposed  regulatory  alternative  for  each
criterion;  these  technologies  are  discussed  briefly   in   the
summary  economic  and  environmental  impact analysis  sections  in
Chapter III and in greater detail in Appendix IV.
                             TABLE 2
       TYPICAL CONTROL TECHNOLOGIES USED TO ESTIMATE COSTS
                    FOR PROPOSED ALTERNATIVES
Criterion
             Technology
Envi ronmentally
Sensitive Areas
  - wetlands, floodplains
  - permafrost, sole-
    source aquifers
  - critical habitats
Surface Water
Ground Water
Air
- contaminant levee
- study of alternatives
- N/A
- major channel  along one side,
  ditches on three sides, berms
- vegetation
- clay lining
- leachate collection facilities
- leachate monitoring,  removal,
  and treatment
- monitoring wel1s
- additional land required for
  unburned wastes
                               1-14

-------
                             TABLE 2
       TYPICAL CONTROL TECHNOLOGIES USED TO ESTIMATE  COSTS
              FOR PROPOSED ALTERNATIVES  (continued)

Criterion                              Technology

Land Application              - dewater;  analyze  solid  waste  or
                                crop
                              - landfill
Disease Vectors               - placement of soil  cover
Safety
  - gas control               - gas extraction  venting  system
  - fires                     - fire/water truck  and stockpile  of
                                soi1 cover
  - access                    - low cost  perimeter fence and  gate
  - bird hazard               - study
     The results  of  the economic  analyses  are shown  in  Table 3
and discussed below.   These  are annualized costs  using 1977 unit
costs  and  based  on   the   assumption   that  upgraded  and  new
facilities  have  a site life  of 10 years.
                              1-15

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                                      TABLE 3
                ANNUALIZED COflBINED COST BY CRITERION DISPOSAL
                       METHOD, AND REGULATORY CONSIDERATION
                              (Millions of Dollars)
Adverse
Effect
Environmentally
Sensitive Areas
Surface Water
Sround Water
Air
Land/Food Chain
Disease Vectors
Safety
Aesthetics
Closure
Total by
Disposal Method
Total
More Restrictive
LF
20.6
35.4
215.1
3.2
0
0
110.2
2.5
398.0
785.0
SI
125.1
0
1252.6
0
0
0
26.1
0
Oc
1403.8
LS
0
0
0
0
20.9
70. 4b
0
0
0
0
20.9
70.4
2201.9 - 2247.8
Proposed
LF
5.6
28.8
139.5
2.9
0
0
94.5
0
398.0
669.3
SI
125.1
0
835.2
0
0
0
17.4
0
Oc
977.7
LS
0
0
0
0
14.1
0
0
0
0
14.1
1661.1
Less Restrictive
LF
0
0
113.7
0
0
0
91.1
0
398.0
602.8
SI
0
0
417.6
0
0
0
8.7
0
oc
426.3
LS
0
0
0
0
0
0
0
0
0
0
1029.1
Key:   LF = Landfill.       SI  =  Surface Impoundment.      LS = Landspread.


Notes:    Refers  only to landfill closure; closure costs are discussed on Page 1-19.

          Most  restrictive alternative for land application.
         ฃ
          It was  assumed that only surface impoundments  in environmentally sensitive
          areas (ESA)  would be  closed;  therefore,  these  costs  are  included in the
          ESA  category.   All other surface impoundments  were assumed to bo upgraded.
                                         1-16

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     a.    State-Standard-Induced Costs vs Criteria-Induced Costs

          As mentioned  previously  in  the  environmental  benefits
section,  disposal site owners and operators are already upgrading
facilities  and  opening   new   sites  which  comply  with  State
regulations  which  are   often   as   stringent  as  the  proposed
Criteria.   It  is  unknown  if  or how  much the  Federal  Criteria
(which are  State-enforced, but  mandatory  for Federal  facilities
and subject  disposal  sites  to  the  potential   for  citizen suits)
will  speed  up   or  strengthen  the   State   regulation  compliance
process.    Because  of  this, the  total  additional  cost  to bring
sites  into  compliance  was  divided  into  two  components:   State-
standard-induced costs and Criteria-induced costs.

     To   do  this, existing State regulations were compared to the
proposed  Criteria  and  the more and  less  restrictive  regulatory
options.     Existing  State  regulations  were  also  compared  to
current   disposal  site   conditions.    The  cost  of meeting  the
Criteria  were  then calculated  as  follows:   (1)  the  additional
costs  necessary  for  sites   to   comply   with  existing  State
regulations  (State-standard-induced  costs),   (2)  the  additional
cost  to   meet  the  proposed Criteria  in  those cases  where  the
Federal    regulations  are  more  stringent  than  existing  State
regulations (Criteria-induced costs), and (3)  the combined costs.
In other words, t_h_e_ costs  aj> s i g n e d tx) t h e C r i t e r i a are those costs
beyond   t n e   costs   necessary   to   bring   existing  sites  into
com pi i a nee  w i t h  existing  State  regulati ons ,  a_n_d_  combi ned costs
a_re  the   total   incremental  c o s t s  to^  bring existing  si tes  Into
compiia nee wi th both State regulations and  Federal Criteria.

     Table 4  shows  the annualized  cost  impacts of  the  proposed
Criteria  for each of the  three cost categories--Criteria-induced,
State-standard-induced,  and total or combined costs.
                               1-17

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                                             TABLE  4


                       ANNUALIZED  COST  IMPACTS  OF  PROPOSED  CRITERIA
                                       (Millions  of  Dollars)
Criteria
ESA
Surface
Water
Ground
Water
Air
Disease
Vectors
Safety
Aesthetics
Closure
Land
Application
Total
*
Cost
Categories
Criteria
State
Comblntd
Criteria
State
Combined
Criteria
State
Combined
Criteria
State
Combined
Criteria
State
Combined
Criteria
State
Combined
Criteria
State
Combined
Criteria
State
Combined
Criteria
State
Combined
Criteria
State
Combined
Disposal Method
Landfill
5.6
0
5.6
2.3
26.5
28.8
50.2
89.3
139.5
2.9
0
2.9
0
94.5
0
94.5
0
148.5
249.5
398.0

0

304.0
365.3
669.3
Surface
Impoundments
99.2
25.9
125.1
0
96.9
738.3
335.2
0
0
2.9
14.5
17.4
0
Closure
costs
reflected
in the ESA
criterion
0
199.0
778.7
977.7
Land
Application
0
0
0
0
0
0
0
0
10 6
3 5
14 1
10.6
3 5
14 1
Cost
Categories
Total
104.8
25.9
130.7
2.3
26.5
28.8
147.1
827.6
974.7
2.9
0
2.9
0
97.4
14 5
111.9
0
148.5
249.5
398.0
10 6
3 9
14 1
513 6
1147.6
1661 1
Total
Cost
130.7
28.8
974.7
2.9
0
111.9
0
398.0
14. 1
1661 1
*  See explanation of  coit  categories on  page
t  Cloture coiti  or*  discussed on  page   I -19.
1-17
                                                  1-18

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     In the "Cost Categories" column of Table 4 "Criteria" refers
to  Criteria-induced   costs;   "State"   refers  to  State-standard-
induced costs.

     As  indicated   earlier,   Criteria-induced  costs   are   the
additional  annualized costs required for disposal  sites to comply
with the Criteria above  the  costs needed to comply with existing
State standards.  State-standard-induced costs are  the additional
annualized  costs required for sites to comply with  existing State
standards.     Combined costs  represent  the  sum   of   the  State-
standard-induced and  Criteria-induced costs.

     "Closure"  costs,  as  shown  in  Table 4,  reflect  the  cost  of
applying certain  minimum  requirements  to  close existing illegal
landfill sites,  as   well  as  costs  to develop new  facilities  of
equal  capacity  (that  comply  with  the  Criteria)   to  replace  the
illegal sites.   In regard  to surface impoundments, closure costs
were included in the  environmentally sensitive area category.   No
closure costs were calculated for 1andspreadinq operations.

     In  sum,  the  annualized  economic  impact  for  all  three
disposal methods  is   $1,661.1 million,  of  which   $513.6 million
(37%)  is  attributable  to  the   Federal  Criteria  and  $1,147.5
million (63%) is due   to State standards.

     b.   Impactson  Disposal Types

          Table 5 summarizes  the  economic  impact  of the proposed
Criteria by disposal  method.
                               T _ 1 0

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                             TABLE  5
      NATIONAL  ANNUALIZED COST  SUMMARY  OF  PROPOSED  CRITERIA
                      (millions  of  dollars)
          ===== =
Disposal
Method
Landfil 1
Surface Impoundments
Landspreading
State-Standard-
Induced-Costs
365.3
778.7
3.5
Criteria-Induced
Costs
304.0
199.0
10.6
Combi ned
Costs
669.3
977.7
14.1
Total                       1147.5          513.6            1661.1
     Fifty-nine  percent  ($977.7  million)  of   the   annualized
combined costs  for  upgrading or closure is for  surface  impound-
ments, 40% is for landfills  ($669.3 million),  and 1%  is  for  land-
spreading  ($14.1 million).  For  Criteria-induced  costs,   these
percentages are  59%  landfills,  39% surface impoundments, and  2%
landspreading.

     In  regard  to   landfills,  the  Criteria-induced  costs  for
closure and upgrading will  increase the  national  cost  of  disposal
by  an  average  of  $0.66 per ton;  the  combined  increase  (State-
standard-induced plus  Criteria-induced)  is $1.19 per ton.   On  a
per capita basis, the  national  incremental  Criteria-induced cost
for landfill  closure and upgrading  is  $1.50 per year.
                               1-20

-------
      c.    Proposed  vs  More  Restrictive  vs  Less
           Restrictive  Alternatives

           The   definitions   of   the   more   and   less   restrictive
 alternatives  for  each  criterion  are  presented  in Chapter  III;
 control  techniques  and  unit  costs  for each  regulatory  alternative
 are  presented   in Chapters  III  and  IV and  discussed in detail in
 the  Appendix.

      Table  6  shows  a  summary  of the less   restrictive, proposed,
 and   more  restrictive   combined    annualized   costs   for  each
 criterion.   Note  that  the  proposed Criteria  are  about  halfway
 between  the less and more restrictive costs, whereas the environ-
 mental  benefits  of  the proposed are  similar to the more restric-
 tive  benefits.

      The  costs  of  each regulatory  alternative are compared below
 for  each  disposal method:

          Landfills.   The  combined  annualized  cost of  the  less
          restrictive  alternatives  would be S602.8  million  (10%
          less)  while  the  combined  annualized  cost of  the  more
          restrictive  alternatives  would be $785.0  million  (17%
          more).
          Surface Impoundments.  The  combined  annualized  cost of
          the  more   restrictive  alternatives would  be  $1,403.8
          million  (44%  greater)  while   the combined  annualized
          cost  of  the  less  restrictive   alternative  would  be
          $426.3 (56% less).
          Landspreading.*   The  combined  annualized cost of  the
          more   restrictive  alternatives would  range  from  $20.9
          million to $70.4 million  (48%-399% greater).
 For 1andspreading,  the  less  restrictive  alternatives  resulted
in no change  in  costs.
                               1-21

-------
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-------
     In total, the combined  annualized  cost  of the  less  restric-
tive  alternative  would  be   $1,029.1  million  (38%  less);   the
combined  annualized  cost  of  the  more  restrictive  alternatives
would  range   from  $2,201.9-$2,247.8 million  (33%-35%  greater).
These changes in  cost can be  compared with the  respective changes
in environmental  benefit described above  in Section  Bl.

     d.   Cost-Centers  of the Proposed  Criteria

          As   previously  discussed,   surface  impoundments,  mostly
because of the large number  of facilities, will  incur 59- of  the
combined  costs.     Also,  as   previously   discussed,  the  State-
standard- induced  costs  are 69% of  the  combined  costs while  the
Criteria-induced  are  only 31% of the combined costs.

     The major cost centers (Table 4) are  ground-water criterion,
surface  impoundments  at  50%  ($835.2   million)   of  the  total
combined  costs;   closure,  landfills at   24%  ($398.0  million);
ground  water,  landfills  at 8%  ($139.5  million);  environmentally
sensitive areas,  surface impoundments at 8% ($125.1  million);  and
safety, landfills (mostly gas controls)  at 6% ($94.5 million).

     The  relative  impacts  of  the proposed Criteria  on  each  dis-
posal  method  are  shown  in  Table 7 by criterion.  The  major  cost
centers for  landfills are  closure  (59.5%), ground  water  (20.8%),
and  safety--mostly  gas   controls  (14.1%).   For  surface  impound-
ments,  the  major  cost  centers  are  ground  water   (85.4%)  and
environmentally  sensitive  areas  (12.8%).    For  landspreadinq,
almost  all  of the cost  impact will be  the  land application  to
food chain crop lands criterion.
                              1-23

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-------
     e.    Economic Benefits

          All sting of potential  economic benefits  is  provided  in
Chapter  IV,   Section  D.     The  only  economic  benefit  which was
quantified  was   protection of  ground-water  resources  used  for
drinking water  supplies.  Based on a number of we!1-contamination
case studies, and  a  number of  very conservative assumptions,  the
total  national  benefit  for damage,  avoidance,  and  administrative
cost ranges  from  $134 million  to  $668  million and  for corrective
costs,   $3.6 billion.    The definitions  of  these  terms  and  the
associated  assumptions  are also   given  in  Chapter  IV,  Section  D.
Note that  these  are  total costs,  not annualized  costs.   These
benefits  are  conservatively estimated  since,  as the  demand  for
clean water increases and  as the  supply of clean water diminishes
(by nonpoint source  contamination, reduction  in  recharge  areas,
and overpumping, etc.),  the value of clean water will  increase.

4.   Eq.u.1 ty Impacts

     The  equity   impacts   of   the  Criteria  are  discussed  in
Chapter IVE.    Table 8 shows  the equity  impacts  (both  negative
and positive) of each criterion.   This table is subjective, based
on  whether  or  not there  is a specific  segment of  society which
will bear  a greater  cost or  gain  a   greater  benefit  than  other
areas of  the country  or society.   The impacts of the Criteria  on
rural  areas, specific  geographic  areas  (regions),   States,  and
industry, are summarized below.

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-------
     a.    Urban/Rural  Community Impacts

          An  important  equity  consideration   in  developing  the
Criteria was whether the economic impact of the Criteria  on  rural
communities (users of  disposal  facilities)  would be  unreasonable.
Of major  concern  in assessing  this  impact were landfills  which
receive municipal  wastes.   The  Criteria as proposed do  not  apply
to agricultural  wastes   returned  to  the  soil  as fertilizers  or
soil   conditioners.    On-site  industrial   landfills  and  surface
impoundments  impact consumers  of products  and services  rather
than   rural  vs.  urban  communities per se.   The  major  conclusions
were:

          In  general,   rural  landfills  are smaller  than  urban
          landfills  in  terms  of tons  per day.    However,  some
          landfills    serving   urban   communities   are   rurally
          located, and some regional  rural  landfills are large.

          Large  sites   are  able  to  obtain  economies of  scale,
          which decrease  the cost  impacts  per  capita and per ton
          of solid waste disposed.

          On  the  other  hand,  large  urban  sites generally  need
          more expensive  environmental  controls  than  smaller and
          more remote sites.   Smaller,  remote  sites generally do
          not  have  the leachate  and  gas production  and  control
          problems  that  larger  sites   have.    The  concern  at
          smaller,  remote  sites  is generally  limited  to  control
          of  disease   vectors  and  exposure to  wastes — both  of
          which  can  be  controlled  by   periodic  application  of
          cover material.  Remote sites  are frequently cheaper to
          obtain  and  engineer  than sites  of equivalent  sizes in
          urban areas.    Thus,  there are  some  diseconomies  for
          large and/or urban sites.
                               1-27

-------
In rural  areas,  economies of scale can  be  achieved  by
(1) development  of   larger   regional   landfills,   and
(2) rotational use  of  equipment  from one  landfill  to
the next.  Both  approaches  achieve  better use of land-
fill  equipment, but  result  in  increased  transportation
costs.   In the first case, longer solid waste haul  dis-
tances   result.   However, many  rural  areas  have  effec-
tively   demonstrated  the use  of  "green  box"  systems
(bulk bins or transfer  stations along  rural  roads)  to
minimize  individual  haul  distances  and  costs.  In  many
cases,   urban  areas  have  remote landfills,  with 20  to
50-mile haul   distances  or with  congested urban streets
to  lengthen   haul  time,  and  must  likewise  resort  to
transfer  operations  to  reduce haul  costs.    In  the
second   case,   a transportation  cost  is incurred to  move
the  disposal  equipment from one landfill  to the next;
but  again,  several   rural communities  have  effectively
demonstrated   the    economic   viability   of   such   an
approach.

The  proposed  open  burning ban   is not expected to cause
an  economic   hardship  in  rural areas,  since evidence
shows that burning  putrescible  wastes does not elimin-
ate  or  reduce  the  need  to  cover  the   residue  where
disease  vectors  are  a  problem.  The  only advantage of
open  burning  is  volume  reduction.    But   with  cover
material  needed  anyway (and  therefore the equipment to
apply it), and with space and  cover material generally
more  readily  available  in  rural  areas,  the economic
impact  of a burning  ban  is minimal.

In  those  States  (either  rural or  urban)  which  have
adopted   stringent   regulations,   the  impact  of   the
Criteria  is  minimal, and therefore  the greatest impact
generally  occurs  where  current  regulations  are  less
stringent  than  the  Criteria.    This factor probably
                     1-28

-------
          impacts  costs  more  than  does  the  rural/urban  factor.
          Also, hydrogeologic setting impacts costs more than the
          rural/urban factor.

          Given  the   relatively  low  income   base  in  many  rural
          areas, expenditures for acceptable landfills may impose
          more of a financial burden in some rural  communities as
          compared with urban communities.

     In conclusion,  the  impact of  the  Criteria  on  rural  commun-
ities  is  not considered  to be unreasonably  burdensome.   In  very
remote areas disposal equipment may not be available and would be
economically  impractical,  but then  these  areas  are  generally so
remote  and  the  population  so small  and  sparse that  the  little
waste  generated  poses  minimal   or  no  environmental  problems
anyway.

     b.   Regions Impacted by Specific Criterion

          The  wetlands   criterion  affects  mainly  the  low-lying
coastal  regions,  particularly  the  southeast,  from  Louisiana to
Florida  to   South  Carolina.   The  permafrost  criterion  affects
arctic Alaska.

     The  criterion  for  protecting  ground  water  has  greater
economic  impacts  on  landfills  in  the  far  northwest,  and  those
east of the Mississippi  River, particularly in the  northern Great
Lakes  and  south-central   and eastern  regions, and   on  surface
impoundments in the eastern coal  and steel regions  and the south-
central oil   and  gas  region.   This is because in wet,  humid areas
surface impoundments cannot  depend  on  net evapotranspiration for
waste  volume  reduction,  and  landfills need  leachate  generation
and/or migration controls.
                               1-29

-------
     Throughout much of the Atlantic and Gulf Coast Plain,  a high
ground-water   table   is   encountered   within  permeable   sandy
deposits.    A  difficult and  costly  technical  problem  to  contend
with  in  these  regions  is the  isolation  of  refuse  from  shallow
ground water.

     c.   States

          From  the  above  discussion,  it  can  be seen  that  waste
disposal  operators  in  certain  States may  be impacted  more than
others from the proposed Criteria:

          States  located  in  the  low,  coastal   areas  of  the
          southeastern  part  of  the country  (Florida,  Louisiana,
          South  Carolina,  and   Georgia)  will  be  significantly
          impacted   by   the   environmentally   sensitive   area
          cri terion.
          States  located  in  the  eastern  and,  especially  the
          southeastern  part   of  the  country  receive  relatively
          high  levels  of  rainfall,  and  experience  relatively low
          rates  of  evaport'•anspi rati on.   As  a result,  both the
          ground-water  and  ".urface-wa ter  criteria  will  have  a
          substantial  impac   n these  States.
          Those  States  who   disposal  practices  and solid-waste
          legislation  r e f 1 <  ^ t  more  concern  for  environmental
          protection have already made upgrading expenditures and
          therefore are  expected  to  have  a  smaller incremental
          cost  to comply with the Criteria.
          Highly  industrialized  States  in  the   northern   Great
          Lakes  region  (Ohio,   Illinois,  Michigan)  and  in the
          Appalachians  (West  Virginia   and  Kentucky)  will  be
          impacted  considerably  by  the  ground-water and surface-
          water  criteria.    These  States  generate  substantial
          quantities of industrial wastes (som*? hazardous).
                               1-30

-------
          Some Appalachian  States  (Kentucky, West  Virginia)  may
          incur  additional  c*osts  for the  ground-water  criterion
          due to unfavorable hydrogeologic conditions.

     The  total  cost  impact  for each  State,  due to these  over-
lapping impacts, is presented in Table 9 and discussed  further in
Chapter IV.

     d.   Industry

          The main effects  on  industry  derive from the  impact on
surface   impoundments   of   the   criteria   for   environmentally
sensitive areas (which forces closure),  ground water,  and safety.
The  total  annualized  cost of  upgrading  and  closure for  surface
impoundments  is  $977.7  million,   of  which  the  oil   and  gas
industry, with  68% of all impoundments,  pays  $404  million  (41%)
and  the  mining   industry  (especially  coal),  with 21%  of  all
impoundments, pays $439 million  (45%).   Thus, 86% of  this impact
falls on the oil/gas and mining industries.

     The  large  impact  on  industrial  impoundments  is  due to  the
ground-water criterion.   Eighty-five  percent  ($835.2 million)  of
the  combined surface  impoundment costs  can be attributed to this
criterion.  The environmentally sensitive area criterion accounts
for  13%  ($125.1  million)  of  the  combined costs,  while  the safety
criterion accounts  for  2% ($17.4 million).   Thus,  the  criterion
with major  national impact  on  the  combi ned costs of the Criteria
is  clearly  the  ground-water criterion  as  it applies to  surface
impundments.    However,   if  one compares  only  Criteria-Induced
costs,   the  ESA  criterion  is  actually  slightly more  expensive
($99.2  million) than the ground-water criterion ($96.9 million).
                               1-31

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                                                                          1-32

-------
5.   Other Impacts

     In  addition  to  the  above  impacts,  the  EIS  looked  at
irreversible  and  irretrievable  impacts  and  short and  long  term
effects (Chapter IV, Section F)  and  materials  and energy impacts
(Chapter IV, Section G).   The major conclusions are:

     (1)  improper  solid  waste  disposal  practices  addressed  by
          the  Criteria  which  may   result  in  long  term,  often
          irreversible,  adverse   impacts   are:    destruction  of
          productive   wetlands;   reduction   in  temporary   flood
          retaining capacities of  floodplains  or  restricting the
          flow of flood waters;  destruction  of permafrost  areas;
          destruction of  critical habitat and endangered species;
          contamination   of   food   chain   crop   lands;    and
          contamination of  ground water,  including  sole  source
          aqui fers.

     (2)  by  requiring gas  controls,  the  Criteria will encourage
          methane recovery from  the larger landfills.

     (3)  by  increasing  the cost  of  land  disposal  to  achieve  a
          specific  level  of environmental  quality,  the Criteria
          will encourage  energy  and  material  recovery  systems by
          making them more ecnomically competitive.

     Although there will  be some  material  and energy  requirements
and  long-term  maintenance  requirements  as  a  result  of  the
Criteria,   the  net  effect  is  positive,  with  long-term  environ-
mental  improvements, and  increased energy and materials recovery.
                               1-33

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                        II.   INTRODUCTION
A.   LEGAL BASIS FOR ACTION

     The  "Criteria  for  Classification  of  Solid Waste  Disposal
Facilities"  (40  CFR  Part 257)   are   being  proposed  under  the
authorities of Sections 1008(a)(3) and 4004(a)  of the Solid Waste
Disposal Act as amended by the Resource Conservation and Recovery
Act  Of  1976  (P.Law 94-580,  90  Stat.  2803 and  2815,   42  U.S.C.
6907(a)(3)  and  6944(a))  and Section 405(d) of  the  Federal  Water
Pollution  Control Act  as  amended by the Clean  Water Act  of 1977
(P.Law 95-217).

1.   Legislative Intent

     The Resource Conservation and Recovery Act (RCRA)  was signed
into law  on October 21,  1976, amending  the original  Solid Waste
Disposal Act of 1965.   Of particular concern to Congress were:

     (1)  protection of  public  health  and the  environment  from
          solid waste  disposal  (both   hazardous  and  nonhazardous
          wastes);
     (2)  plugging   the loophole  left  by  other  environmentally
          oriented   Federal  laws  and   regulations  (now land  and
          ground-water  protection  in   addition  to  surface  water
          and air protect!on);
     (3)  proper disposal  of  the  increasing  amounts of pollution
          control residuals destined  for  land  disposal  (e.g.,  as
          a result  of  the  Clean  Air Act and Federal Water Pollu-
          tion Control  Act); and
     (4)  resource  conservation and recovery.
                               II-l

-------
     In fact,  the  House of Representatives' Committee  on  Inter-
state and Foreign Commerce  in  Report 94-1491 wrote:

     The committee believes that  the  approach  taken  by  this
     legislation eliminates the  last remaining loophole  in
     environmental  laws, that  of unregulated  land  disposal
     of discarded materials and  hazardous  wastes.   Further,
     the Committee believes that  this  legislation  is neces-
     sary if  other  environmental  laws  are  to  be both  cost
     and environmentally effective.   At present,  the  Federal
     government  is  spending billions  of dollars to  remove
     pollutants  from  the  air  and water, only  to  dispose  of
     such pollutants  in an environmentally  unsound  manner.
     The existing  methods  of  land  disposal  often  result  in
     air pollution, subsurface leachate, and surface  runoff,
     which affect  air  and  water  quality.   This  legislation
     will  eliminate  this  problem  and  permit  the  environ-
     mental  laws to  function  in  a coordinated  and effective
     way" (Ref. 79, p.  44).

     In keeping with the Congressional  intent,  resource  conserva-
tion  and recovery  are among  the  highest  priorities  with  EPA;
therefore, practices such  as the landspreading  of  waste  materials
in  environmentally  safe   ways   are  strongly  encouraged.    The
Criteria  encourage  the  implementation  of  controlled  practices
while  prohibiting  practices  that   pose  a  substantial  risk  to
public health or the environment,

     a.   Adverse Impacts  of Past Pi sppsa!_ Practices

          Solid wastes, sometimes referred  to as  discarded mater-
ials or  residual  wastes, include  residential,  commercial, indus-
trial, waste-water sludges, agricultural, and mining  discards and
may  be solid,  semi-liquid, liquid,  or  contained  gaseous  wastes.
They are  commonly  disposed of  on the  land  in dumps, landfills.
ponds, pits or lagoons, or  by  landspreading.

     The  ultimate  disposal of  solid  wastes  on  the  land in  an
environmentally  sound   manner  is a  rapidly increasing  problem.
The  environmental   and  economic  impacts  of improperly  located,
designed, operated,  monitored,  and  controlled  disposal  sites are
                               II-2

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sure to increase  on  a  national  level,  and to be  quite  severe  on
local   and  regional   levels.    In  developing  the  RCRA and  Clean
Water   Act  (CWA)  legislation,  Congress  identified  a number  of
adverse effects from improper solid-waste disposal or utilization
on  the  land,  and  a  number of factors which  are  exacerbating  the
problems.

     This  increase  in  the importance and  severity of the  solid
waste   disposal  problem  is a  result  of   several   factors.   First,
more  wastes   are  being  disposed  of  on  the land.    Population
increases,   economic  growth,  and  affluence  are   accompanied  by
increased   annual   production  of  residual  wastes and  pollution
control  residues.     In  addition,  legislative  mandates  are
producing  more  solid wastes  by requiring reductions  or  elimin-
ations  of  traditional   air   and   water  disposal  "sinks"  and
requiring  higher levels of treatment.

     Second,  many  new,  frequently exotic, and  often  toxic  solid
wastes  are  being  produced as  a result   of chemical  research  and
new materials productions.

     Third,  these  wastes  tend  to be concentrated  in  larger dis-
posal  facilities producing larger concentrations of leachate.

     Fourth,  there  is  a  general  lack  of control  of  solid  waste
facilities  in  the United States, including  hazardous  waste dis-
posal,  especially  for  ground-water  protection.   There   is  very
little  monitoring  of solid waste  disposal  sites, indiscriminant
dumping frequently   occurs,  and  there   is  no   effective  Federal
legislation  for  the  protection of ground water  from  solid  waste
disposal sites.

     Fifth,   because  of  the   amount  of   time  before  sites  reach
field  capacity and  produce leachate,  the long-term production  of
leachate and  the  slow movement  of  ground water,  the  impacts  of
land disposal  sites may not be realized  until years after
                               II-3

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deposition and are long-term in duration.   This means that closed
sites and new sites have a cumulative effect on water resources.

     The specific adverse effects of environmentally unsound dis-
posal facilities can be grouped into eight categories of impacts:
environmentally sensitive areas, surface water, ground water,  air
quality, land used for food chain crops, disease vectors,  safety,
and aesthetics.  In essence, the proposed Criteria delineate both
performance  and  operational  requirements to  eliminate  a  reason-
able  chance  of  adverse  effects  on  health and  environment from
disposal of discarded material  at a solid waste disposal site.

          Environmentally sensitive areas (wetlands, floodplains,
permafrost areas,  critical  habitats,  and  recharge zones of sole-
source  aquifers)  in  the  past have been prime locations for land-
fills  generally because  of  less social  resistance,  their lower
cost,  and  the practice  of  selling the site  as "reclaimed" land
after   the  facility's  life was   over.    However,   there  is  an
increasing  public awareness that  these areas  are  vital  natural
resources of  great hydrological and ecological  Importance.

          Surface  water  can  also be adversely affected by certain
disposal  practices.   Without  proper  controls of runoff,  surface
leachate,  leachate treatment effluent, and  unchanneled leachate
seeps,  these flows have  entered  surface  waters  and  caused con-
tamination of water supplies and significant  environmental damage
(for  example, see  Ref. 79, p. 38).

          Ground water  is  perhaps the  resource in  greatest need
of  protection  by  the   Criteria,  since  about  one-half   of  the
population  depends upon  it as  a  source  of  drinking  water,  and
since  existing  regulations  or  practices for  ground-water protec-
tion  are inadequate.    A  recent  report  to  Congress  found that
waste   disposal   practices   have  affected   the  safety  and  avail-
ability of ground  water  on a local basis, but  that its overall
                               II-4

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usefulness  had  not  yet  been  diminished  on  a  national  basis
(Ref. 7).

          Landspreading of solid waste  on  food-chain  crop  land
can  have  adverse  effects   on  public  health  and  agricultural
productivity.  Some wastes or sludges have high concentrations of
heavy metals.    Excessive amounts  of heavy  metals,  particularly
cadmium,  added  to the soil   may  have serious  effects  because of
their uptake by  food-chain  crops  or possibly even the contamina-
tion  of ground  water  by percolation  through  the  soil.   Leafy
vegetables,  tobacco,  and  root crops  have been found  to take up
cadmium  readily, while  certain grains,  such  as  corn,   tend  to
exclude i t.

     Natural food  chains  serve as  biological  amplifiers for all
kinds of  trace chemicals spread  out in  our  environment.   Land-
spreading of solid waste  on agricultural  land is  one of  the ways
toxic substances, including  some  potentially carcinogenic mater-
ials, have been introduced into the food chain.

          Emissions of pol1utants into the air  from  open burning
are  high,  compared  to  controlled  burning.   In  addition  to the
potential health and property damages from air pollution, signif-
icant  safety and  damage  threats  caused  by  smoke  and  fire are
associated with open burning.

     Improper   solid-waste   disposal   can   also   create  safety
hazards, including hazards from explosive, toxic,  or asphyxiating
gases,  fires,  bird  hazards   to  aircraft,  and access.  The House
Report on RCRA (Ref.  79,, p.  37) describes a number of examples of
these safety  hazards  and cites  them as  a basis  for  part of the
1egi siati on.

     Products of  solid waste  decomposition,  oxidation, volatili-
zation,   sublimation,  or   evaporation  may  include  gases   such  as
methane, hydrogen, carbon monoxide, carbon dioxide, and chlorine.
                               II-5

-------
Presence of any of  these  or similar gases at a disposal  site,  in
sufficient concentration,  can pose a serious threat to the health
and welfare of  site  employees  and users,  and occupants of nearby
structures.   Explosions  and property  damages  resulting  in  death
and injury have resulted from disposal  site gases.

     The  threat  of  property damage  and  injury or  death  to site
employees,  users,  and  nearby   residents  from  fires  is   all  too
evident.   Furthermore,  funds spent  to  extinguish  such conditions
are often quite high.

     Birds may  be attracted  to  disposal  facilities which receive
putrescible wastes,   creating hazards when  such sites are located
near airports.

     Solid-waste  disposal   facilities  can  also  cause injury  or
death  to  persons  on  the  site  (whether in  a  work  capacity  or  by
trespassing)  due to  accidental  or intentional  fires, excavations
and  earth-moving  activities,  operation  of heavy   equipment  and
haul  vehicles,  and   hazards  associated with  the   types  of  waste
deposited there.

     Aesthetic  factors  include  noise,  litter, dust,  and  odor
which can be a nuisance or cause annoyance or inconvenience.

     Finally,  there   is also  a  potential  of a disposal  site  to
breed  rats,  fleas,   flies,  mosquitos,   and other   vermin  and  the
consequent  need to   minimize  the  propagation  of  these  ai sease
vectors.

     b.   Prohibition of Such Practices

          After  identifying  the  adverse  effects  of   improper
solid-waste  disposal,  Congress  developed  a program  to  correct
these  problems.  The  RCRA-established  program to eliminate open
                               11-6

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dumping specifies:

     (1)  EPA  is  to  develop  criteria  which  define  acceptable
          solid-waste disposal  practices (Sections 1008(a)(3)  and
          4004(a)).
     (2)  All  facilities  which  do  not  meet  EPA's criteria  are
          classified  as   open   dumps   (Sections  4004(a)   and
          4005(a)).
     (3)  EPA is to publish an  inventory of all  open dumps in  the
          U.S. (Section 4005(b) ).
     (4)  Open   dumping   is  prohibited   (Sections  4003(2)   and
          4005U)).
     (5)  States receiving EPA  solid-waste grants are to prohibit
          the establishment of  new open dumps and are to close or
          enforce  upgrading  of   existing   open   dumps  within  a
          reasonable time, not  to exceed five years from the date
          of  publication  of the   inventory  (Sections  4003(2)  and
          (3), 4004(b) , and 4005(c)).
     (6)  Citizen suit and imminent hazard suit provisions enable
          other  enforcement  mechanisms in  addition  to  the State
          programs (Sections 7002 and 7003).

     The CWA-established program  specifies:

     (1)  EPA  is  to   develop  guidelines  for  the disposal  and
          utilization of sludge.
     (2)  All  public  treatment  works  owners and  operators  must
          comply with such guidelines when applicable.

2.   Statutory Requirements of  RCRA and CWA

     Section  1008(a)(3)  of RCRA  calls  for  EPA  to develop guide-
lines which "provide minimum criteria to be used by the  States to
define  those  solid waste  management  practices  which constitute
the   open    dumping   of   solid   waste   or  hazardous   waste."
Section 4004(a)  calls  for  EPA  to  "promulgate  regulations  con-
                               II-7

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taining criteria for determining which facilities shall be class-
ified as. . .posing...no reasonable  probability  of adverse effects
on  health  or  the  environment  from  disposal  of solid  waste,  at
such facilities."

     Sections  405(d)  of  CWA calls for EPA  to  develop guidelines
for  the  disposal or  utilization  of  sludge.    The  Criteria  are
proposed  as  partial   fulfillment  of  this  requirement.    Under
Section  405(e),  all  public  treatment  works  owners and operators
must comply with any applicable guidelines developed by EPA under
Section  405(d).   Thus,  all  public works owners and operators who
dispose  or  utilize  sludge  o_n_  the la n d  must  comply  with  these
Criteria.

B.   PURPOSE OF  REGULATION

1.   Minimum National Standards

     The  purpose of the Criteria  is  to  provide minimum  national
standards  for  the protection  of  health  and the environment from
solid  waste disposal  facilities.   The  Criteria provide minimum
standards  for  the  classification  of disposal  facilities,  to be
used  in  developing  the  inventory  of   open  dumps  (unacceptable
disposal  facilities).

  2.  Implementation  of the  Criteria

     Implementation  mechanisms  for the prohibition on  open dumps
include  the regulatory power  established to implement  the State
plan    (Section 4003),    the   "citizen   suit"   provision   of
Section  7002,    and    the    "imminent   hazard"   provision   of
Section  7003.   There are  no statutory requirements  for  States to
implement or  enforce  the open-dumping  prohibition, but  States are
not eligible  for Federal  financial  assistance  under  the act if
the State  plan  fails  to  provide  for  such  implementation  and
enforcement.   A State  does  not  need  an EPA-apprcved  State plan to
                               II-8

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a-j\)\. 
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C.   RELEVANT FEDERAL LAWS


     There are  a  number of  Federal  laws,  regulations, and  Exe-

cutive Orders related to  the  proposed  Criteria.   To  avoid  dupli-

cation, inconsistencies  or  conflicts,  the proposed  Criteria  use

existing  laws  and regulations  or  approaches wherever  feasible.

Table 10 lists the major  relevant  Federal  laws,  regulations,  and

Executive  Orders.   Brief summaries  of each  of these  are contained

in Appendix II (Volume II).
                            TABLE ]0

              RELEVANT FEDERAL  LAWS  AND  REGULATIONS
Criterion                    Law/Regulation/Executive  Order


Environmentally
Sensitive Areas

  Wetlands            P.L.  92-500,  Federal  Water  Pollution  Con-
                      trol  Act (Section  402,404)

                      33 CFR Part 323,  Permits  for  Discharges  of
                      Dredged or Fill  Material  Into Waters  of
                      the U.S.

                      Executive Order  11900,  Protection  of  Wet-
                      1 ands

  Floodplains          Executive Order  11988,  Floodplain  Manage-
                      ment

  Critical Habitat    P.L.  93-205,  Endangered Species  Act  (Sec-
                      tion  4,7)

                      50 CFR Part 17,  Subpart F,  Critical  Habitat

  Sole-Source          P.L.  93-523,  Ssfe  Drinking  Water Act
  Aquifers            (Section 1424(e))
                      Proposed Procedures  for Sole-Source  Aquifer
                      Designations  (42 Federal  Regulation  51620)
                              11-10

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                      TABLE  10  (Continued)

              RELEVANT  FEDERAL  LAWS AND REGULATIONS
Criterion
       Law/Regulation/Executive Order
  Historical  Pre-
  servation and
  Archaeological
  Areas
Surface Water
Ground Water
Air

Land Apjjl ^cation



Safety

  Bird Hazards


Aesthetics

  Noise


General
  Landfil1s
P.L. 93-291, Archaeological  and Historic
Preservati on Act,
National Historic Preservation Act of 1966

Executive Order 11593

P.L. 92-500, Federal Water Pollution Control
Act as amended (Section 402)

P.L. 93-523, Safe Drinking Water Act
Proposed Underground Injection Control  Program
(41 Fed. Reg. 36726)
P.L. 95-217, Clean Water Act (Section 304)

P.L. 93-319, Clean Air Act,  as amended

Federal Insecticide, Fungicide, and Rodenticide
Act as amended.
Federal Food, Drug,  and Cosmetic Act
P.L. 95-217, Clean Water Act (Section 405(d))
FAA Order No. 5200.5, FAA Guidance Concern-
ing Sanitary Landfills On or Near Airports
40 CFR Part 205, Noise Emission Standards
for New Transportation Equipment
40 CFR Part 241,  Guidelines for the Land
Disposal  of Solid Wastes
                              11-11

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D.    COVERAGE

     The  Criteria   apply   to  all  "solid  waste"  and  "disposal"
facilities as  these  terms are  defined  in Section 1004  of  RCRA.
The  definition  of  "solid  waste"  includes  liquid,   contained
gaseous and semi-sol id wastes, and sludges.

     Based on the definition  of solid waste,  the land application
of  domestic  sewage  and  liquid  effluent  from  the   treatment  of
domestic sewage is  excluded from the Criteria coverage.  However,
the Criteria  do apply  to  the land  disposal  of sludge resulting
from the treatment  of domestic sewage.

     In addition,  the Criteria  do not  apply to irrigation return
flows  or  discharges  which are  point sources  subject  to Section
402 permits  under  FWPCA.   The Criteria  also do  not  apply  to the
location and operation of septic tanks.   However, the disposal  of
septic tank pumpings is subject to these Criteria.

     Based  on   Congressional   intent as   described  in   the  House
Report  on  RCRA,   the   following  wastes  are  excluded  from  the
Criteria:  "agricultural wastes  (e.g., manures  and crop residues)
which  are  returned  to  the  soil  as fertilizers  or  soil  condi-
tioners"  and "overburden  (mining  and  milling  wastes)  resulting
from mining  operations  and intended for return to the  mine site"
(Ref. 79).

     The  Criteria  also  do not apply to  source, special nuclear,
or  byproduct material  as  defined  by  the Atomic  Energy  Act  of
1954, as amended.

     When regulations for hazardous waste disposal facilities are
promulgated  under  RCRA,  facilities for  the disposal  of hazardous
waste  must  comply  with  those  regulations   instead   of  tnese
Criteria.   Similarly,  when regulations  for the State Underground
Injection Control  Program  (UICP)  are promulgated under authority
                              11-12

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of the Safe Drinking Water Act of 1974 (P.Law 93-523),  they  apply
to  underground  well   injection   in   lieu   of  these   Criteria.
However, the  Criteria  may be revised  to  incorporate  sections  of
the UICP  to  reach  problems  in  those States  which  do  not  have
primary enforcement responsibility for the UICP.

     Table  11  lists  sources  of  wastes  to   be  regulated by  the
proposed Criteria.   The  types of disposal  methods covered  by the
Criteria include:  landfills, dumps,  surface impoundments (ponds,
pits,   and  lagoons),   landspreading   of  wastes,   and  resource
recovery practices  involving  land application of  solid  waste  as
soil conditioners or fertilizers.
                            TABLE  11
      SOURCES  OF  WASTES  TO  BE  REGULATED BY PROPOSED CRITERIA
1  -  Municipal:   residential, commercial,  institutional  (e.g.,
      schools, litter containers), street sweepings
2  -  Sewage sludge/septic pump ings
3  -  Industrial  wastes:   manufacturing residues,  air  and water
      pollution sludges
4  -  Construction/demolition wastes
5  -  Agricultural  wastes not returned to the soil  as  fertilizer
      or soil  conditioner:  feedlot manures,  process wastes,  etc.
6  -  Mining and  milling  wastes not intended  to be  returned to the
      mine:  coal  mining, other minerals

NOTE:   Hazardous  wastes in  the  above categories  are  subject  to
regulation under Subtitle C of RCRA,  and  not these  Criteria.
                              11-13

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E.    REGULATORY APPROACH

     The  need  and mandate  for EPA  to  develop a  regulation  for
solid waste disposal  was established by  Congress and contained in
RCRA and  CWA.   EPA  must,  therefore, develop  such  a  regulation.
The  following  discussion  summarizes the  approach  and  considera-
tions used by EPA to develop the proposed Criteria  in  response to
this mandate.

1.    Adverse Impacts

     The  regulatory  approach  begins  with a  statement  of the need
for  regulation.    This  need  stems  from  the  adverse   impacts  of
current   disposal  practices  and  the  lack  of  adequate  State
regulation.  A number of studies, both published and unnublished,
have identified  a number of  adverse  effects  from  improper  solid
waste  disposal.   The need for regulation by  EPA is contained in
RCRA,  passed by  the  Congress  in 1976.  RCRA and the accompanying
committee  reports   summarized  the  major  areas   of  impact  as:
ground-water  quality;   surface  water quality;  air quality;  ,jnd
human  health and  safety (from disease transfer, pollution of food
sources,  fires  and  explosions,  personal  injury, bird  hazards to
aircraft, poisoning, etc.).

     These environmental  impact  concerns provide  the  basic  goils
and  objectives for the regulatory approach.

2.    Criteria Alternatives

     Several basic issues and alternatives were considered in  he
development  and   adoption  of  the  Criteria.    In determining  -he
coverage  of  the  regulations,  the scope   of RCRA was considered to
include  almost  all  wastes  being  disposed of  to land  (regarulsss
of  physical  state).   Addressing  this   broad  spectrum  and  Targe
quantity   of   wastes,   each  with  its    resulting   or  potential
environmental  effects   in   the   varied  physical   and  climatic
                              11-14

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conditions  throughout  the  United  States,   presented  a  mammoth
challenge.    Environmental   effects  of  national   environmental
concern  and  the  methods  of  handling  these  concerns  were  key
issues addressed in  EPA's  approach  to implementing  the  charge of
RCRA.

     EPA's consideration of alternative  approaches  to  developing
the required Criteria  was  evidenced  by  both  its  solicitation of
comments  on  a  May 12,  1977  draft  of the  Criteria  and  its
"Advanced   Notice    of   Proposed   Rulemaking",   July 5,   1977,
(Ref.  58).  In  the latter document,  EPA solicited  public  comments
on major  questions  pertinent to the  development  of  the  Criteria
from the basic  mandate of RCRA.

     The  next   steps   in   the  regulatory   approach   included:
identification  and evaluation of the major alternatives,  based on
available  technology  and  management practices;   assessment  of
uncertainties  and   risks  associated  with   physical   processes
(hydrogeology)  which  disperse  pollutants; analysis  of  available
implementation    methods   and   their   feasibility,   along   with
performance  expected   from   each   level  of  regulation;   and
preliminary evaluation of costs  to  individuals, firms,  industrial
groups,  geographic  regions,   social   groups   and   governmental
agencies for each level  and type of  regulation.

     The  factors considered  in selecting  the various  Criteria
options to evaluate were:

     (1)  Effectiveness and  degree  of certainty  of  criterion in
          achieving goal.
     (2)  Technological  feasibility, availability,  reliability.
     (3)  Economic  impact and  feasibility.
     (4)  Feasibility of compliance  monitoring, inventorying,  and
          correcting disposal  facilities.
                              11-15

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     (5)   Utilization  of existing  Federal  and State  regulations
          or   approaches,   to  avoid  conflicts   or   unnecessary
          duplicati on.

     a.    Operational  And  Performance Standards

          One of  the  basic  questions addressed  by  EPA was  the
relative    merits   of   operational    standards   or   performance
standards.

     (1 )   Operational  Standards

          With  operational   standards-  and particular  standards,
particular practices  (technology,  designs or operating  methods)
are specified to  provide  for reasonable  protection of health and
environment.    Considerable  detail  is required  to  identify  the
best operational techniques for the great variety of  solid  wastes
which  exist  and  for   the   varied   physical  and  climatologica1
conditions which  exist  throughout the nation.   The  advantage in
using  this  approach  is   that  the  best  practical  technology
available  could  be  implemented and  utilized  for  the disposal of
wastes,   leading  to a  reasonable  uniformity  of results.   Also, it
is  relatively  easy   to  determine   compliance  with  a  specific
operational criterion.

     One   of   the  major disadvantages  to this  approach is  that
compliance  is  measured by  assessing conformance  to operational
criteria   rather  than  by  assessing or  monitoring  the  actual
effects   on the  environment.   Also,  it is likely  that most  people
would  follow  an established  operational  practice  rather  than
applying   creative  thinking,  i.e., finding the best  method  for a
given  situation.   Also,   operational  standards  often  have  the
disadvantage of requiring  revisions in State laws and regulations
as  changes  occur in  waste  types,  coverage  of  disposal  methods,
disposal  technology and knowledge of environmental effects.
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     In  summary,  the  basic  reason  for  not  relying  solely  on
operational   standards  in  the  Criteria  is  to  avoid  having  to
specify all  the particulars  of:   waste type and methods  of waste
pretreatment;   site   location,   including  hydrogeology,   precipi-
tation  and  climate,  and   ground   water   regime;  site  design
practices;  environmental   control   equipment  and   practices;
construction   methods;    operating   procedures;    maintenance
procedures,  and monitoring equipment and  testing procedures.

     (2)   Environmental Performance Standards

          Under environmental  performance  criteria,  reducing the
actual impacts on  the environment would be  the controlling factor
in  technology  selection.   Technology  and  methods  are  organized
around the  goal  of  providing  given  levels  of  protection to all
environmental  media  at given  site,  to meet  the goal of RCRA to
prevent  a  "reasonable probability  of  adverse  effects on health
and  the   environment."    This  approach  allows  broader  local
interpretation  and   technical  creativity  in  providing  adequate
disposal.    It  also  provides  for  emerging  technology  to  be
implemented rapidly  without creating  the  necessity  for  changing
regulations which  specify current techniques,  which  may be  more
costly  and/or  less   effective   in   the  future.     Determining
compliance with the performance criteria  is generally not as  easy
as with operational  criteria, and monitoring  the effectiveness of
the environmental  control measures  is  generally more complex and
costly.   Inspectors  need  a  far  greater grasp  of  the  potential
effects of waste  disposal  on  the environment and a broader grasp
of  technical  skills to  identify and evaluate conditions of  com-
pliance and noncompliance.

     Given  the  complexity  and  variability  of  both  solid wastes
and  site-specific   situations,  EPA  considered  it  preferable  to
allow  for some  local  discretion  in  meeting  the Criteria  and
making site-specific evaluations based  on local conditions.
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     Therefore,  performance  criteria  were considered  generally
preferable for addressing the variety of conditions which will  be
governed by these regulations as well as the varied environmental
settings  in  which  the  waste disposal  could  take place.   There
was,  however,  a need  for  the performance  criteria  to  be  as
specific as possible  in  order  to provide unequivocal  and uniform
criteria,  while  maintaining the  State  prerogative  of  setting
specific  limits  where known environmental  problems  dictate  this
approach.   The  type  of  standard  embodied in each  criterion  is
shown  in  Table 12.    In  all   cases,   there  are  environmental
performance standards, and  in  almost half the cases, operational
requirements are also specified.

     b.   Other Federal  Regulations

          Whenever   possible,   the   Criteria   utilize   existing
Federal,  State,  and local regulations  or  approaches  in order  to
avoid  duplication,  inconsistencies,  and  unnecessary  new regula-
tions.    For  example,  the  wetlands  and  surface-water criteria
utilized  the   NPDES  permit  system  established  for  point-source
discharge  of  pollutants  under  Section  402 of the  Federal  Water
Pollution  Control  Act Amendments of  1972  (P.Law  92-500).   Also,
the  ground-water criterion  utilizes  the approach of  the  Under-
ground Injection Control  Program proposed under the Safe Drinking
Water Act  (P.Law 93-523).

     c.   Resource Recovery

          The Criteria are designed to encourage the recovery and
utilization of  solid waste in environmentally safe ways.  This is
in  keeping  with RCRA  and EPA policy to urge the conservation and
recovery of material and energy resources.
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                             TABLE  12

                 TYPES  OF  STANDARD  USED  TO  ASSESS
                     COMPLIANCE  WITH CRITERIA
Cri ten' on
Performance
Operational
1






2.


3.


4.
5.




6.
7.





Environmental ly
Sensitive Areas
a. Wet! ands
b. Floodplains
c. Permafrost
d. Critical Habitats
e. Sole Source Aquifers
Surface Water
a. Point Sources
b. Non-Point Sources
Ground Water
a. Case I
b. Case II
Ai r
Land Application
a. Cadmium
b. Pathogens
c. Pesticides
d. Direct Ingest ion
Disease Vectors
Safety
a. Explosive Gases
b. Toxic Gases
c . Fires
d. Bird Hazards
e. Access


X
X
X
X
X

X
X

X
X
X

X
X
X
X
X

X
X
X
X
X


X

X



X


X

X

X



X




X
X
                              11-19

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 d.        Imp!ementati on

          EPA recognizes  there  are  many  factors  which must  be
considered in determining  if  there  will  be an adverse impact and
what the  magnitude  of   the  impact  will  be.   Many  of  the  factors
vary from  site  to site,  including  climatological,  hydrological,
geological, the  amount  and type of wastes, and ground  and  surface
water proximity  and usage.

     One  aim  in  developing these Criteria was  to  be  as specific
as  possible  to   facilitate  the distinction or  classification  of
disposal  facilities,  without  reducing  the flexibility  of  State
solid  waste  management  and  enforcement  agencies  to  take  into
account the site-by-site variations and make assessments based on
local conditions.   These  Criteria  are not intended to prevent or
restrict  the authority  or  discretion  of  States  to  develop  or
utilize  more  stringent  State  or  site-specific  (situational)
standards  or criteria.   States may choose to require more strin-
gent location, design,  construction,  operation, maintenance, and
performance standards where local conditions indicate.

     Due   to  the  difficulties  of   determining compliance  with
certain  criteria (particularly  the  ground-water  criterion,  EPA
plans  to   allow  States  to  phase the  conduct  of  the inventory.
Priorities for the inventory will be based on degree  of potential
environmental harm and ease of determining compliance.  The five-
year maximum  compliance schedule will  start  when  a  facility  is
listed  as  an open  dump.   One  alternative considered was not to
apply  certain  criteria  (the  more  difficult  criteria  to evaluate
and  correct, such  as  ground-water  quality  goals)  to  ex i sting
sites.   Another  alternative was  to  phase the application of the
Criteria  to certain disposal types (essentially exempting classes
of   disposal  facilities   initially).      These  approaches  we-re
rejected  by EPA  as inconsistent  with the  stated goals of RCRA.
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     Compliance  schedules   for   each  disposal   facility   will
consider severity of environmental  consequences, availability and
costs  of  control  equipment,  availability of  alternative  sites,
time  required  to   monitor  and  determine  compliance,  and  the
availability   of   Federal/State   resources   to   implement   the
Criteria.

     Application of the  Criteria to  all  types of disposal  facil-
ities immediately has  several benefits:

     (a)  in  the  beginning,  it defines  the   minimum  acceptable
          levels of disposal for all  types of  disposal  facilities
          which  will  help  disposal  site  owners  and  operators  in
          their planning and compliance  programs;
     (b)  it  aids  planning  for  State and  regional  solid  waste
          management agencies;
     (c)  it  minimizes  loopholes  in  EPA's regulatory  scheme  to
          control all  land disposal;  and
     (d)  it  allows  the inventory  process  to  be  started  immed-
          iately for all types  of  disposal  facilities  which will
          aid the State and EPA planning  programs and improve the
          inventory efficiency.

3.   Decision Making

     The Criteria  alternatives  were  examined  for various aspects
of  feasibility  and  were   then subjected  to   a  comparison  of
environmental benefit  and Criteria-induced cost (and, in the case
of  ground  water,  economic  benefit from   controlling damages)  of
compliance and  implementation.   The  basic process was  iterative,
in which a  balance  was  struck between the environmental improve-
ment mandates of RCRA,  risk, and the costs of  compliance.

     In choosing alternatives for  final   examination,  EPA  looked
for  those  which satisfied  certain  needs,  compared  to  the  pre-
ferred  set   of  Criteria.     Less-restrictive  criteria  (i.e.,
                              11-21

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requiring  less  costly  approaches)  were   examined   for   their
relative  increase  in   overall   adverse   environmental   impact,
compared  to  the costs  avoided.    For more  restrictive  criteria
(i.e., those with  greater  environmental  benefits),  EPA evaluated
the relative cost increases against their potential  environmental
benefi ts.

     In  some  cases,  the Criteria  alternative  was  selected  inde-
pendent  of   expected  economic  impact  because  of  the  critical
nature of the expected environmental impact and the difficulty of
assigning  a  price  to  the  benefit  created  by  reducing  the
environmental  impact;  this  was  the  case  with  the  Criteria
covering some environmentally sensitive areas.

F.   PURPOSE OF THE EIS

     This  EIS  was  prepared  in   response   to  EPA's  procedures
governing  voluntary  Environmental  Impact   Statements  (39  Fed.
Reg. 37419).   The  EIS  process and preparation of this EIS report
assisted EPA in five important areas:

     (a)  summarizing the major alternatives considered and their
          environmental, economic, social and equity impactsj
     (b)  comparing   trade-offs   among   alternative  courses   of
          action;
     (c)  promoting public understanding of the EPA decision;
     (d)  facilitating  public  participation  in  the  decision-
          making process; and
     (e)  identifying areas where  additional information and data
          are needed.

     This  EIS   is,   therefore,   a  policy-making  tool  whereby
comprehensive  alternative  courses  of action  were  developed  and
examined  at  an  early  date and the rationale for the action taken
by  EPA  was   analyzed  and  evaluated, both  for  internal decision-
making  and   explaining  EPA  actions  to  the public  for  external
                              11-22

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inputs to the development of the final Criteria.

G.   EIS APPROACH

1.   Identification of Impacts

     The first  task  in the Criteria  development  and  in  the  pre-
paration of  the  EIS  was  to  identify all the  potential  adverse
effects  of  improper  solid  waste  disposal,  and  to  identify  the
importance  of the resource being affected.  Only then could rela-
tive evaluations  be  made as to  the  importance  of each criterion
and  the degree  of   control  desired.    Next,  technologies  and
methods  are  identified which may  be utilized,  and  their  effec-
tiveness   in   reducing    the    adverse   effects   is   assessed
(Chapter III).

2.   Evaluation of Alternatives

     The next  step  in the  development  of the  proposed  Criteria
and preparation of the EIS  was  to identify  and  evaluate  criteria
alternatives   based   on   technology  and  methods,   performance
(including  risk  and  certainty), and  economics  (including  equity
considerations) .

     The social  and environmental impacts of  solid waste  disposal
practices include a wide  range of concerns such  as public health,
occupational   health   and   safety,   environmental   damage,   and
maintenance of  ecological  systems.   These concerns have  led  to a
variety of methods for measuring impacts and costs.   Three broad
categories  of criteria can be used to characterize the imoacts of
solid  waste disposal  technology:   criteria  that are  quantifiable
and amenable  to comparison among different technologies,  criteria
that are  quantifiable,  but  difficult or  impossible  to  compare
among  alternative  technologies;  and  criteria that are difficult
or impossible to quantify even  for a single  technology (Ref.  9?).
                              11-23

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     The severity of  future  environmental  impacts  depends on the
effectiveness  of  government  regulations  and  the  technological
developments  necessary  to   implement  regulations.    Our  under-
standing of  the  health and  ecological  effects of  present  solid
waste disposal  systems is only  sufficient  for  setting  standards
for a few  of  the  pollutants  associated with such  disposal,  e.g.,
cadmium, pathogens,  and some  compounds such as nitrates.  Reason-
ably  detailed  ambient  and  emissions  data  exist  for only  a  few
pollutants; even  for  these  pollutants,  actual  health  and ecolo-
gical effects are still being determined.

     As more is learned about the impacts of solid waste disposal
systems on the quality of our air, land, and water,  new standards
in  the  protection of  public  health  and welfare  can  be expected
and  the  proposed Criteria may  be adjusted.   Even  so,  if  gross
waste generation continues to increase, maintaining  a given level
of  environmental  quality  may become  increasingly  difficult, from
both  a  technological  and  economic  standpoint (Ref. 92, pp. 196-
197).

     The Criteria and alternatives  were derived in  an attempt to
reduce  the environmental  impacts,  including  a  consideration  of
risk  of  solid waste  disposal  to "reasonable"  levels,  determined
by  Congressional mandates and economic and technical feasibility.
The  EIS  then serves  to present  the  evaluation  of their relative
merits.

3.   Environmental Benefits  of Criteria Alternatives

     The  degree  to  which  the proposed Criteria  reduce  to accep-
table  levels  or eliminate  the  significant  cumulative  adverse
environmental  impacts of  the  solid  waste  disposal  practices  of
landfill ing,  landspreading,  and  impoundments  depends  on s e *•ฃ••* a 1
factors:
                               11-24

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          which potential or  actual  impacts  are addressed by the
          Criteria and which are not;
          nature and importance of the impacts not addressed;
          for the impacts addressed:
               how well  do the Criteria address the problem?
               how  many  sites  will  continue  to  operate  because
               there  are  no  feasible  alternatives,   and  what
               impacts will  they cause?
               how  well  will   the    available   technology  for
               environmental control  work?
               how well  will the regulations be enforced?
               when will  the Criteria finally be implemented?
               how  well   will   the   system   of   environmental
               monitoring work?
               how well  will the sites be operated?

     Although  considered  in  the  development of  the  proposed
Criteria,  it  is  not  the purpose of  this report  to  present the
evaluation of  the  efficiency  and practicality of the systems for
enforcing the regulations (including  monitoring to determine com-
pliance)  and  the  probability  of efficient  (predictable)  site
operation.     Rather,   the   report    evaluates   the   beneficial
environmental  effects which reasonably  can  be expected  to occur
when the  Criteria are fully  implemented  and contrasts  them with
the probable economic  and social costs of the regulations.

     The costs  of  achieving  these  effects will be borne directly
by  the  general  public,   disposal  site  operators,  public  agencies
at  local,  State and Federal  levels,  industries,  and  other waste
generators.   Some of these  economic and  social  costs  will fall
equally on people, while others may be distributed inequitably tc
segments of the population.

     Finally,  it  should  be  mentioned that there will  continue to
be  potential   impacts   from   solid   waste  disposal   which  are
primarily  local  in nature,   are  generally best regulated  at the
                              11-25

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local  or State  level,  and  which  are not covered by the Criteria.
These   potential  impacts  include effects  on archaeological  and
historical   sites,   local   traffic   and  related  noise  problems,
conflicts  with  established  uses  of on-site  or nearby  affected
lands  for  recreational, scientific  and  educational  purposes,  and
the problems  of locating   solid  waste  disposal  sites  on  or  near
karst  terrain, fault zones, and areas of high water table.

4.   Costs/Benefits of Major Criteria Alternatives

     a.   General Approach

          One aspect of the EIS is to identify costs and benefits
of the  Criteria.   Since  the environmental  benefits generally  are
not  quantifiable  in  a  coherent  overall  economic  framework,
economic  benefits   were   generally   not  determined.    The  major
exception  is in the analysis of the ground-water criterion, where
it  is  possible  to  assess  the  economic   value   of  preventing
pollution  of   drinking   water,   since   the  costs  of  securing
alternate  supplies  can  be  estimated.    This  has  been  done  in
Section IV, using six case  study examples.

     Thus, the  analysis  of  alternatives  generally  compares  cost
of Criteria to environmental benefit.

     b.    Cost Accounting

          The  basic  analytical  framework  of  the EIS divides  the
costs  of  meeting  the Criteria into  two  parts:   (1) the costs  of
meeting  existing  State solid waste  disposal  regulations  (State-
standard-induced costs) and (2) addi ti onal  costs  of meeting  the
Criteria   beyond   the  level   specified   by  State  regulations
(Criteria-induced  costs).   The  true cost  impact of the Criteria
is  found  in  (2),  but  the  total  (combi nod)  cojt to industry  and
consumer is the sum of the  costs in  (1)  and (2).
                              11-26

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     In order  to  compare the  impacts  of each  regulatory  alter-
native, specific costs were  attributed to meeting each criterion.
To  avoid   double-counting,   specific  technologies  which  would
achieve compliance  with  a combination  of  criteria  were  assigned
for cost  accounting  to  the  criterion  of greatest  importance  or
      the  technology had the greatest impact.

     In calculating  the  additional  cost of compliance  with  the
(riteria,   the   cost   impact  assessment  takes   as  given  Federal
regulatory control  of  certain  aspects  of  solid waste  disposal
(e.g.,   NPDES   permits,  Army  Corps   of  Engineers'  permits),  and
local/State regulations governing water pollution,  air pollution,
noise,  nuisance, litter, and similar effects.  It is  assumed that
there  is  considerable  variation  throughout  the  country in imple-
mentation   of  State regulatory  controls  on  solid  waste  disposal
practices.  The net effect of the proposed regulations is related
to the  existing standards:  the new Criteria lead to  effects only
if they upgrade an  existing  situation (as determined by  standing
Federal  and   State  laws  and  regulations)  or   introduce   a  neปv
standard.    This  assessment  of  the  net  effect  of  the  proposed
Criteria   thus  limits  the  economic   costs   as  well   as  the
environmental   and  social  b e n e f i t s.    Environmental  benefits will
also be  limited by (1)  how  each criterion  is  implemented  since
some criteria   give  a  degree  of State  discretion,   and  (2)  the
technological    effectiveness   of   the   acceptable   environmental
measures.   The  additional cost  impact of meeting the regulations
may  also  be  limited  if  the  most stringent criterion  affecting
each type  of  disposal  method forces  the site to  close.

     c.   Method of Analysis

          The  methodology for economic and environmental  analysis
was u.veloped  with  the  aid  of  fairly complete  data on the number
of landfills  and  on State solid  waste  disposal  regulations,  but
with very  limited  data  on the  number of 1andspreading operations
and  surface   impoundments  and  overall   conditions   or   current
                              11-27

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impacts of all  three types of land disposal  facilities.  Although
some  industrial  landfills   and   surface   impoundments  may  be
regulated by  the  hazardous  waste regulations of  RCRA  and  not by
these Criteria,  no  attempt was  made  to estimate  how  many sites
may  be  so  affected;   therefore,  Criteria  costs  may  include
estimates for some facilities that are regulated by the hazardous
waste regulations of RCRA.  The availability of data is discussed
in Appendices III and V (Volume II).

     The  basic  method  used on  a state-by-state  basis  was four-
fold:

     (a)  Estimate  the number  of  disposal   sites  (by  size  and
          1ocati on);
     (2)  Estimate   the   condition   (environmental   impact)   of
          existing sites (by size and location);
     (3)  Identify  control  technologies  (by  adverse  effect  arid
          regulatory alternative) and  estimate  unit costs  (based
          on site size) to meet each criterion;  and
     (4)  Derive  total  control  cost  of  closure or upgrading for
          the major  regulatory  alternatives  by  summing costs of
          each  criterion  for  the three types of disposal for the
          total  number of affected sites.
                              11-28

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 III.  MAJOR CRITERIA ALTERNATIVES AND ENVIRONMENTAL CONSEQUENCES
                     FOR EACH ADVERSE EFFECT

     As  summarized  in  the last chapter and  discussed  further  in
this chapter  and  in  Appendix  IV  (Volume  II),  research  efforts
have identified  a  number of  potential adverse  effects  on  health
dno. che  environment from improper  solid  waste disposal  practices.
Th'-e  are:     surface   and   ground  water   contamination;   air
pollution;  contamination  of  food   chain  crops;  explosive  and
asphyxiating  gases;  fires;   bird   hazard  to  aircraft;  disease
vectors;   exposure  to  wastes,  heavy equipment,  and  other  safety
hazards;   and   miscellaneous   other   environmental  and  aesthetic
effects  (noise,  odor,  litter,  dust,  and  dirt).   In  addition,  a
number of  environmentally sensitive  areas  that  may  be adversely
affected   by  improper  solid  waste disposal  have  been  identified,
Regulatory  alternatives  for  all  of these  adverse  effects  are
analyzed   in this  Chapter  in terms  of  costs  and  environmental
benefits   and  discussed further in  Chapter  IV and  in  Appendix IV
(Volume  II).
     This chapter summarizes information on each of these adverse
effect in terms  of:  (1)  the magnitude of each adverse effect and
the  importance  of control,  (2)  the major  regulatory  approaches
including  brief   discussions   of  technologies,   and   (3)   the
environmental    consequences  and   economic   impact   for   each
regulatory approach.   For  simplification,  only  three regulatory
approaches for each adverse effect are discussed in this  chapter:
(1) the  proposed  approach,  (2)  one more restrictive,  and (3) one
less  restrictive.     More   complete   lists  of  the   regulatory
approaches considered are in Appendix IV (Volume II).
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     The economic  impact analysis  shows  costs  for  each of  the
three  regulatory  approaches,   identifying   these   as   Criteria-
induced costs and combined (State-standard-induced  plus  Criteria-
induced)  costs  for  each  type  of   disposal  facility:      (1)
landfills,  (2) surface  impoundments   (ponds,  pits,  and  lagoons),
and (3) landspreading.
     To  determine  the  economic   impact  of  the  Criteria,  the
following  information  was  developed  for  each  type  of  disposal
facility (landfill,  surface impoundment,  and landspreading)  for
each site size category considered:


     (1)  technologies needed for  compliance
     (2)  unit costs for each technology and total  costs  for each
          site size
     (3)  number of facilities in  each site  size category needing
          modification.
     The  number  of  sites  needing  modification was  divided  into
two  categories:     sites  needing   upgrading   and  sites  needing
closure  and  replacement (new  facility  of  equal  capacity).   The
unit and  total costs for each site size were determined for both
of these categories.


     The  cost  figures  developed   represent   the  increments  or
additional  cost  above  current  disposal  costs to  bring  existing
facilities  into  compliance with the Criteria.   By  comparing the
Criteria  to  existing State standards,  it was  possible  to  divide
these  incremental   costs  into  two  categories:   State-standard-
induced  cost  (cost to  come  into  compliance with  existing  St;;e
standards) and Criteria-induced cost (cost  beyond those  needed to
achieve  compliance  with  State  standards).    This   breakdown  was
necessary because  a number of  disposal  sites do  not yet  comply
with   existing  State   standards   (corrective   or   compliance

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technologies and methods often take years to implement).   Without
the Federal  Criteria,  sites  can  be  expected to  eventually  come
into  compliance  with  State  standards.    The  combined  costs
demonstrate the total  additional  expenditures  necessary  to bring
existing  sites  into  compliance  with  State  standards  and  the
t r } L e r i a .
     Chapter  IV  and Appendix  IV  (Volume II)  contain  additional
information  on  the   economic   impact   analysis:     data  base,
methodology, assumptions, technologies,  unit costs,  costs by site
size,  numbers  of   sites  needing  modification,   and  impacts  on
various sectors of the country.

A.   ENVIRONMENTALLY SENSITIVE AREAS

1.   Definition; Identification of Areas Considered


     a.   Definition
          Environmentally  sensitive  areas  are  natural   assets
which  are  especially ecologically  productive or  important,  are
particularly vulnerable  or sensitive to solid waste disposal,  and
may not be adequately protected by the other Criteria.   These  are
areas  where  current  Federal   policy  has  already established  a
national   interest  in  protecting  the  resource.   (Ref. 40,  41,
115).  In general, these  areas should be avoided for  solid waste
disposal;  if  no feasible  alternative exists,  however,  disposal
facilities in  these  areas require  special  design,  construction,
operation  and maintenance considerations.
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b.        Areas Considered


          The environmentally sensitive  areas  criterion  has  been
limited  to  wetlands,   floodplains,  permafrost  areas,  critical
habitat  for  endangered  species and sole  source  aquifers.   Other
areas  considered  were   Karst   terrain,  active  fault  zones  and
historical  preservation  and archeological  areas.    The  latter
areas  were  not included because  EPA felt  that the surface-water
and ground-water criteria and other Federal and State regulations
provide  sufficient  protection  for  the  important  health  and
environmental features.

2.   Wetlands


     a.   Importance; Adverse Effects from Improper Disposal


          The  nation's   coastal  and  inland  wetlands  are  vital
natural  resources  of great  hydrological,  ecological,  and social
importance.   Wetlands  provide  natural   flood  and  storm  control,
sediment  and  erosion control recharge  of aquifers, natural puri-
fication of waters,  and  flow stabilization of  streams and rivers.
Wetlands  produce  large  quantities  of  nutrients   which  support
complex  ecosystems  extending   into  estuaries  and  streams,  well
beyond  the marshes  and wetland areas.  Wetland  habitats support
fish,  shellfish, mammals, waterfowl, and other wildlife fauna and
flora.   Moreover,  wetlands are  used  in the  production  of  many
agricultural  products (food  and fiber)  and timber,  as well as for
recreational,  scientific, and cultural  pursuits.
     The  major  wetlands  of  the nation  are  shown  in  Figure 1.
Wetlands   occur locally in other parts  of the  country, particu-
larly  along  the ocean coastlines,  bayfronts,  and riparian corri-
dors.    The   distribution  of  wetlands  by  State   is  given  in
Table  13.

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\ \\-ti

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                     TABLE  13

TOTAL AREA OF WETLANDS IN THE UNITED STATES IN 1956
              (SHAW AND FREDINE 1956)
          (Adapted from Ref. 4, p. VI-84)
State*
Al abama
Arizona
Arkansas
C a 1 i f o r n i a
Col orado
Connecticut
Del aware
Fl or ida
Georgia
Idaho
Illinois
Indiana
I owa
Kansas
Kentucky
Louisiana
Ma ine
Maryl and
Massachusetts
Michigan
Mi nnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carol ina
North Dakota
Ohio
Okl ahoma
Oregon
Acres (Total )
33,029,760
72,901,760
33,896,560
101,563,420
66,718,080
3,205,760
1,316,480
37,478,400
37,680,640
53,476,480
36,096,000
23,226,240
36,025,600
52,648,960
25,852,800
30,881,920
21,257,600
6,769,280
5,284,480
37,258,240
53,803,520
30,538,240
44,599,040
94,168,320
49,425,280
70,745,600
5,954,560
5,015,040
77,866,240
31,728,640
33,655,040
45,225,600
26,382,080
44,748, 160
62,067,840
Acres ( Wetl ands )
1,598,400
28,400
3,785,400
559,300
404,400
23,400
131,300
17,185,300
5,919,500
108,900
427,300
283,400
138,100
204,200
273,100
9,647,300
381,300
290,000
231,700
3,217,100
5,044,900
2,589,400
376,900
187,400
649,800
192,500
13,500
269,900
48,500
212,800
4,054,600
1,523,300
97,900
279,700
472,600
% Wetlands
4.84
0.04
11.14
0.55
0.61
0. 73
9.97
45.85
15.71
0.20
1.18
1.22
0.38
0.39
1.06
31.24
1.79
4.28
4.38
8.63
9.38
3.48
0.85
0.20
1.39
0.27
0 . 2 J
5.38
0.06
0.67
12,05
3 , .- •
U. 37
0.63
0. 76
                        I 11-6

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                      TABLE  13  (Continued)
       TOTAL AREA OF WETLANDS IN THE UNITED STATES IN 1956

   Te             Acres (Total )    Acres (Wetl ands)     % Wet! ands'
Pennsyl vani a
Rhode Island
South Carol i na
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wi sconsi n
Wyomi ng
29,013,120
776,960
19,875,200
49,310,080
27,036,160
171,096,960
54,346,240
6,149,760
26,122,880
43,642,880
15,475,840
35,938,560
62,664,960
52,900
25,400
3,377,000
752,000
828,000
3,741,000
1,174,400
38,100
541,100
223,200
3,800
2,790,600
30,300
0. 18
3.27
15.99
1.53
3.06
2.19
2.16
0.62
2.07
0.53
0.02
7.76
0.05
Total  United States 2,934,204,360    74,439,300**         2.53
*This table does not include the States of Alaska and Hawaii or the
 District of Columbia.
**Total  United States (square miles wetland):  116,311
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     Wetlands have been used extensively  for  solid  waste  disposal
because the land was cheap,  the resistance to disposal  site  loca-
tion  was   small,  the  location  was  close to  major  coastal  and
riverine  cities,and  filled-in wetlands  could  be used for  other
more direct  economic  activities.  The  effect  of this  practice has
been  to  eliminate wetlands  and reduce the value or  productivity
of  adjacent  wetlands. Disposal  sites  in wetlands often  degrade
adjacent  surface-water  quality.   The  alteration and  destruction
of  wetlands  through  draining,  dredging, landfill ing, and  other
means  has   had   an   adverse   cumulative  impact  on   hydrologic
stability and the ecosystems involved.   Recent estimates  indicate
that  about 40  percent of the  120 million acres of  this country's
wetlands   that   existed   200  years   ago have  been   destroyed
(Ref. 109).
     b.   Definition of Wetlands


          Wetlands are defined as "those areas that are inundated
 or  saturated  by  surface  or ground water at a frequency and dura-
 tion  sufficient  to support,  and  that  under  normal  circumstances
 do  support, a prevalence of vegetation typically adapted for life
 in  saturated  soil  conditions.  Wetlands generally include swamps,
 marshes,  bogs,  and  similar  areas."   This  is  the  current  Army
 Corps  of Engineers  definition  contained  in  33 CFR  323 "Permits
 for  Discharges  of  Dredged or  Fill  Material  into Waters  of  the
 United  States"  (Ref.  116).   This  definition  is  very  similar  to
 that  contained   in Executive  Order 11990  (42  FR 26961,  May 24,
 1977).   The major difference is  that  the  Executive  Order refers
 to  a  prevalence of "aquatic  life"  as  well  as "vegetative life",
 and  adds the following  examples:   wet meadows,  river overflow,
 mud flats,  and natural ponds.
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     c.    Regulatory Alternatives and Environmental  Consequences


          (1)   Proposed Crlter i on
               To  prevent  the   destruction   of   wetlands,   the
proposed criterion  states  that disposal sites may  not  be  placed
in  wetlands  unless  an  NPDES  permit  has   been  obtained  (under
Section 402 of  the  FWPCA).   Further,  if a  levee,  dike,  or  other
type  of  containment structure  is to  be placed  in the  water  as
part of  the disposal  activity,  an Army  Corps of  Engineers  permit
also must be obtained (under Section 404 of FWPCA).
     There  is  a  strong  presumption  against  the issuance  of  an
NPDES permit for the discharge of solid waste into wetland areas.
It  is  EPA  policy  that  only  upon  showing  of  extraordinary
circumstances  will  an  NPDES  application  be  considered and  an
NPDES permit  issued.   Such a  showing  must  include  an  assessment
of  alternative  disposal   methods,  the  environmenal  impact  and
technical  and  economic  feasibility  of  each  alternative,  and  a
justification  for wetlands  disposal  in view of the  environmental
impact and feasibility.


      In  general,  new disposal  sites will  be  permitted  in wet-
lands and  existing  sites  may  be  expanded into  wetlands  only  if
(1) there  are  no other  feasible  alternatives,  (2)  there  will  be
no  significant  adverse   impact   on  the  ecosystem,  and  (3)  the
facility utilizes the  best available technologies and  methods  to
minimize any adverse effects.
     The environmental  consequence  of the  proposed  criterion  is
the  protection  of   almost   all   productive  wetlands  and  the
strengthening of the 402/404 permit sections of the FWPCA.   Given
the  hydrological   and  ecological  importance  of  wetlands,  this

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criterion will  safeguard a vital  natural  resource.


          (2)   More Restrictive Alternative


               A more  restrictive approach,  the  banning  of  all
waste  disposal  sites in  wetland  areas,  would  obviously  protect
al1   wetlands.    The  environmental  consequence  of  the  proposed
approach is similar  to  a  ban  since it poses a severe  restriction
on  wetlands  disposal.   However,   the  proposed approach  enables
site-specific   flexibility  since  wetlands  disposal   is  allowed in
certain  extraordinary  circumstances.   Such a  ban would  severely
affect States  with a high percentage  of wetlands,  such as Florida
and  Louisiana,  and  not  all  wetlands  are  ecologically  productive.
Hence,  this restrictive alternative  was  rejected  in   favor  of  a
more  flexible  criterion  of  protecting  most of the  wetlands,  from
disposal sites.


          (3)   Less Restrictive Alternative
               To  abandon  the  criterion  governing  wetlands,  is
the  least  restrictive  alternative.   However,  protection  would
continue under the 402/404 permit authority established under the
FWPCA.    The main  problem  with this  approach  is  that  permit
standards and procedures under the 402/404 permit provisions have
not  yet been  established  for  solid  waste  disposal  facilities,
hence uniform protection is lacking at this time.
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3.    Floodplai ns
     a.    Importa nee ;  A dverse Effects from Improper Disposal
          There is currently underway a Federal  program of flood-
plain  management  designed  to avoid,  as much  as possible,  the
long-term  and  short-term   adverse  impacts   associated  with  the
occupancy and  modification  of floodplains.   One  element  of this
plan involves  discouraging  direct  or indirect  Federal  support of
floodplain  development  wherever  there  is  a practicable  alter-
native.   The  adverse  impacts of  floodplain occupancy and con-
tinued development in floodplains include the risk of flood loss;
effects  detrimental  to  human health,  safety, and  welfare (e.g.,
loss of  life  and  property);  and  erosion of valuable  land (soil
and vegetation) by flooding.


     Disposal   of  solid  wastes  in floodplains  (especially along
rivers) may have several  significant adverse impacts:  (1) if not
adequately protected from flooding, wastes in a  disposal  site may
be  inundated  by  water  and  flow  from  the  site,  impacting water
quality  and  aquatic  life in  downstream  waters,  and  also  causing
erosion,  siltation,  and  flooding; (2) filling  in  the  floodplain
may restrict  the  flow of  flood  waters and/or reduce  the  size and
effectiveness  of   the  floodplain  in  assimilating   flood  waters
which may result in higher  flood  levels and  greater flood  damages
downstream or  upstream;  and  (3)  since  floodplains  generally have
a  hydraulic  connection   to  wetlands,  surface  water,  and  ground
water,  locating  disposal   sites   in  floodplains  may  result  in
leachate contamination.
                              III-ll

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     b.    Defi ni ti on


          Floodplains are defined as  "the  lowland  and  relatively
flat areas adjoining  inland  and  coastal  waters (including flood-
prone  areas   of  offshore  islands)   including  .  .   .  that  area
subject to a  1% or  greater chance of flooding in  any given year."
(Ref. 41).*  The proposed  criterion  uses  the 100-year  floodplain
rather  than  the 50-year  or  other  level   to  be consistent,  with
other Federal  programs  (flood  insurance,  OHUD,  etc.) and to give
the added  safety factor  necessary  because  of changes in  the 100-
year levels caused  by human activities.  The U.S. Water Resources
Council   has  developed procedures  for determining   the extent  of
floodplains,   "A Uniform  Technique  for  Determining Flood  Flow
Frequencies"   (Ref.  128),  as well as  a  "Uniform  National  Program
for  Floodplain  Management"  (Ref. 87).   The 100-year floodplains
for many  areas  of  the country have been mapped  by  the  U.S. Geo-
logical  Survey,  U.S.  Army  Corps  of  Engineers,   and   the  U.S.
Department  of  Housing  and  Urban   Development.      For  unmapped
areas,  the Water  Resources Council   is to  developing  procedures
for  determining  flood levels,  according to Executive Order 11988
(Ref. 40).
*The flood with a 1% frequency of annual occurrence is called the
100-year flood, because it will occur, on the average, onct, t • ery
hundred years.  The 100-year  floodplain is not fixed; it is subject to
changes caused by future  urban development and flood  control
improvements,  including physical  structures and land  conservation
practices, i.e., it may expand or contract in the  future.

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     c.    Regulatory Alternatives and Environmental  Consequences


          (1)   Proposed Criterion
               The  floodplains  criterion  requires  that  a  solid
waste disposal  facility not be located in a floodplain unless (1)
it  will  not restrict  the  flow  or  reduce  the  temporary  water-
storage capacity  of the  100-year  floodplain  such  that increased
flooding   may   occur,   and   (2)   the   facility   is   designed,
constructed, operated,  and maintained  so  as  to  protect  against
inundation by the 100-year flood.  Landspreading of wastes in the
floodplain as fertilizers  or  soil  conditions for agricultural  or
vegetative purposes  serves  two  beneficial  purposes (disposal and
utilization), and should not pose a significant adverse impact on
flood  levels  or  water  quality  if  the  other  criteria are  met;
therefore, this  activity is exempt from the floodplain criterion.
     The proposed criterion will protect ground and surface water
from contamination  due to  flooding  of disposal  sites,  and  will
inhibit the  location  of  disposal  sites in floodplains where they
may impact on downstream or upstream flooding.


          (2)  More Restrictive Alternative
               A  total  ban  on  disposal  of wastes  in  floodplain
areas would ensure  the  protection  of such environmentally sensi-
tive regions.   However,  such a proposal  would impact severely on
cir-r;-it disposal  practices,  and  the  amount of potential  disposal
site lands.    When  properly  designed,  sites in  floodplains  can
protect  against  inundation,  and  impact  on  flooding  or  water
quality may  be  negligible.    In  fact, selection  of  alternative
sites in more  sensitive  areas (i.e., recharge zones of currently

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used  aquifers)  may result  in  potentially more  serious  environ-
mental impacts.
          (3)  Less Restrictive Alternative
               A less restrictive alternative would be to exclude
floodplains  from  consideration  as  an environmentally  sensitive
area.    While   it  is  true  that the  surface  and  ground  water
criteria  apply  to floodplains,  they  fail  to  emphasize  against
inundation by  floods and  protection  from  impacting  upstream  and
downstream flood levels.

4.   Permafrost Areas
     a.    Importance; Adverse Effects from Improper Disposal


          Permafrost areas, characteristic of  arctic  Alaska,  are
very  fragile  ecosystems  with  significant potential  erosion  and
ground-water contamination problems.    Permafrost  is  permanently
frozen  ground,  occurring  where  the  freezing  depth  each  winter
exceeds the summer  thaw  depth.   In portions  of arctic Alaska  the
depth of thaw or active zone  is less than 18  inches.


     b.    Regulatory Alternatives and_Env1ronmental Consequences


          (1)   Proposed Criterion
               Disposal sites should not be located in permafrost
areas  if  alternative  areas  or  disposal  methods  are  avc  idble.
Alternative disposal  methods include (1)  recycling  or  salvaging
of  materials,   (2)  incineration  and energy  recovery of  combus-
tibles, (3) deep-well  injection  of  incinerator  residue  and other

                              111-14

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wastes where  drilling  equipment  is  available,  and (4) transport
of the wastes back to more temperate regions.
     Should none of these alternatives be feasible, the following
practices should be  implemented  when  locating a site in Alaska's
arctic:
     1.   site the  facility  on  relatively  dry and workable soils
          where minimal or no vegetative cover exists;
     2.   design,  construct,  and  operate  the facility so  as  to
          minimize  erosion   and  total  quantity  of  surface  area
          consumed; and
     3.   develop  regional   disposal  facilities  to  the  maximum
          extent feasible.
     The  proposed   criterion   will   improve   current   disposal
practices in the permafrost regions of Alaska.


          (2)   More Restrictive Alternative


               A ban  on disposal  of  wastes in  permafrost  areas
would ensure the environmental  integrity of such regions but at a
considerable expense.   Such a  ban would  not  eliminate  the need
for  solid waste  storage facilities  in arctic   regions  and  would
further require the transport of al 1 wastes to  other locations.


          (3)   Less Restrictive Alternative
               A  less  restrictive  option  is  not  to  address
pernafrost areas in the criteria.  This would mean there would be
no i-tderal standards for disposal in these areas, and most of the
land is Federally owned.
                              111-15

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 5.   Critical  Habitats


     a.    Importance;  Adverse Effects from Improper  Disposal


     Many  species  of  animals  and   plants  have become  rare  or
endangered in  the  past through  the  cumulative effects  of  human
activity   in   habitat  destruction,   excessive  killing,   and,
recently, release of toxic substances into the environment.


     The Department of Interior has  currently  designated critical
habitats  of  the  snail   darter,  the  American  crocodile,   the
California  condor,  the   Indiana  bat,  and the Florida  manatee
(50 CRF, Part 17, Subpart F).


     b.    Regulatory Alternatives and Environmental  Consequences


           (1)  Proposed Criterion
               In  accordance  with  Section 7  of the  Endangered
Species Act of 1973 (16 U.S.C. 1536), all Federal departments and
agencies, in consultation with the Department of Interior, are to
use their authority to further the purpose of this act, including
the protection from destruction or modification of habitat deter-
mined  by  the  Secretary  of  Interior  to  be   critical  to  the
continued  existence  of  endangered  species.   Any  specific  geo-
graphical  area  identified  by  the  Department  of Interior  in  50
CFR,  Part  17,  Subpart F,  to be critical  habitat  may  not  be used
for  the  disposal  of  solid  waste  unless  it  is  demonstrated that
the  facility design,  construction,  operation,   and  maintenance
will  not jeopardize  the  continued  existence  of the  endangered
species, and  unless  approval  or  concurrence is obtained from the
Office of  Endangered  Species,  Fish  and Wildlife Service,  Depart-

                              111-16

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merit  of  Interior.   This  approach  enables location  of  disposal
facilities  in  critical  habitat  areas  based  on  professional
judgement that the endangered species are not further threatened.
This approach is more reasonable than an outright ban on  disposal
in such areas.  However, where other feasible alternatives exist,
such  critical  habitat  areas  should  not be used  for solid waste
di sposal .


          ( 2)  More Restrictive Alternative


               A ban on  locating  solid  waste  disposal facilities
in such identified critical habitats for endangered species would
guarantee  that disposal  facilities would  not  further  threaten
such  species.   However,  some  of  these habitats  encompass  very
large areas such that a ban could be very costly, and most of the
endangered species and  habitat  areas identified to date  are  such
that  a  disposal  facility  could  be  located  at  certain  places
within the area without further endangering the species.


          (3)  Less Restrictive Alternative
               To fail  to  address  the  problem of siting disposal
facilities  in  or  near  critical  habitats  of  endangered  species
could add to the process of extinction.  In addition, overlooking
this concern would  disregard  the  Congressional objectives of the
Endangered Species Act of 1973.
                              111-17

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6.    Recharge Zones of Sole-Source Aquifers
          Importance;  Adverse Effects from Improper  Disposal
          Aquifers  are  water-bearing,  geologic  formations  which
often yield significant quantities  of  water  to wells or springs;
a large percentage  of  the  population  in  this country obtains its
drinking water  supply  from these sources.   Aquifers  are  replen-
ished through recharge  zones  which  are permeable to rainfall and
surface runoff  and  through which  the  aquifer  is  susceptible  to
contamination.  Removal of  areas from  recharge zones reduces the
recharge zones reduces the recharge and hence the amount of water
available for use.
     As  a  contaminant  travels  through  the  soil   and   into  the
ground-water  system,  it can  be modified by  various  attenuation
processes  such  as  precipitation,  adsorption,  or  ion  exchange.
However,  these   processes   are  very  complex,   are  finite  in
capacity, are  reversible, and are dependent on such factors as pH
and soil  type.   Once in an aquifer, certain substances are highly
mobile.    Since  ground water  frequently  is very  slow-moving,
contaminants  within the ground-water system  do not  mix readily
with nature  water (i.e.,  they usually do not become very diluted
or   dispersed,   but   rather,   move   as   slugs   or   plumes   of
contamination).   Because  of  these factors,  contaminated aquifers
may take  decades  to purge themselves  and become usable again.


     Section  1424(e)   of  the  Safe  Drinking  Water  Act  of  1974
(Pub.  L.  93-523)  makes it  possible  for  EPA  to  designate  areas
which  are solely or principally  dependent on  an  aquifer f,  its
drinking  water  supply.  It is imperative that special precautions
be   taken  to   protect  the   recharge   zones  and  prevent  the
comlamination  of  such  designated  sole-source aquifers.
                              111-18

-------
     b.    Regulatory Alternatives and Environmental  Consequences
          (1)   Proposed Criterion
               The proposed criterion  states  that  disposal  sites
should  not  be   located  in  the  recharge  zones  of  sole-source
aquifers  when   feasible   alternatives   exist  (including   tech-
nological   and  economic  considerations);  however,    when  waste
disposal facilities are located in the recharge zones of aquifers
serving  these  designated  areas,   they must  be 1 ocated  (taking
advantage  of  topography,  depth   to  ground  water,  and  natural
soils),  desi gned,  constructed (generally  including  artificial
liners),  operated,  mai ntai ned, and  monitored  so  as to  prevent
endangerment of the water source.
     The proposed criterion will offer substantial  protection for
sole-source  aquifers  in  addition  to  that  already provided  for
under the  SDWA  (which  protects  only  to the  extent  that  Federal
funds are  involved)  or the ground-water section of  the  Criteria
(which  provides  for  no endangerment  beyond  the  property,  not  in
the  aquifer  itself,  and which  does  not  discourage  the  placement
of a disposal site in a recharge zone).


          (2)  More Restrictive Alternative
               A more  restrictive  alternative than  the  proposed
criterion  would  be  the  outright  ban  of all  disposal   sites  in
recharge zones of  sole-source  aquifers.   Although such  an option
would  guarantee   the  protection   of  such  vital  drinking  water
sour  s, it may be unnecessarily strict and  require  the  transpor-
tation of  wastes  to  another  location  with the attendant environ-
mental  and financial  impacts.    When  feasible,  disposal  sites
should  not be located  in sole-source  recharge  zones,   but  when
                              111-19

-------
such  zones  are very  large,  it may  be  more practical  to  locate
there.     By   implementing   the   best  available   technology,
technology,   collecting  and   treating   leachate,  and  monitoring
sites in these regions, sole-source aquifers should be adequately
protected.
          (3)  Less Restrictive Alternative
               Failure to address sole-source aquifers as special
areas  is  to  invite  additional  potential  environmental   risk  to
these  important  drinking water  sources  by  not  fully evaluating
alternative  disposal  options  with  less  risk,  by  not  utilizing
best available technologies,  and by  not discouraging the removal
of  parts  of the  recharge zone.   The  ground-water  section of the
Criteria  would  still  provide  some   protection  of  sole-source
aquifers,  but  applying the  endangerment  concept  at the   property
boundary  rather  than  on-site  doesn't   force  the  use   of  best
available technologies at all  sites.

7.   Summary Technology, Economic, and Environmental  Impact
     Analysis


     a.   Technol og^y


          The  technology  needed  to  control  adverse environmental
impacts  to  wetlands,  floodplains,   permafrost  areas,   critical
habitat  for  endangered  species  and  sole-source  aquifers  are
discussed  below;  these are  based upon what  EPA  considers to be
proven and  tested methods.   Although  regional solutions may vary,
these  technologies  represent  the best available  approach  for  a
nationwide  assessment of costs.
                              111-20

-------
     (1)   Wetlands
          The best means  to protect productive  wetlands  is  not  to
locate the  disposal  site  in such areas.   Although  there  appears
to be no  satisfactory  way  to  site a facility in  wetlands  without
adverse  impact,  there  are  methods  for  minimizing  the  impact  on
this sensitive environment.  The  primary  adverse impact in these
areas is  the destruction  of a  portion of an ecosystem;  hence,  the
aereal extent of the site  should be limited and every  effort made
to contain  the wastes  and  any  seepage.   As a minimum,  the  entire
site  should  be   confined  within  a dike.   Thus,  for  existing
disposal   sites  located in  wetlands  to  comply  with the  proposed
criterion,  it was  assumed  that  a containment structure  or  levee,
averaging  10 feet  in  height,  would  need  to be  constructed,  and
continued  expansion into  the wetland would cease.  It  was  assumed
that only  in rare,  extreme  circumstances  would new facilities  be
located  in wetlands, and  existing sites  be allowed  to  expand into
wet! ands.
     (2)   F1oodplai ns
          In  addition   to   the  standard   counter-measures   of
controlling  leachate   and  preventing  seepage  required  for  all
disposal   sites  to  achieve   surface  and  groundwater  protection,
perimeter protection  is  needed to preclude  innundation  by  flood
waters.
     The  isolation  of  disposal   sites  from  flooding  by use  of
perimeter levees may reduce the temporary storage capacity of the
flood  basin,  or  cause  a  partial  damming  of flood  waters  which
could  cause  flooding  of  new lands.  The impact  of  the  perineter
protection  can  be  precluded  or  minimized  by  siting  the  solid
waste  facility  where  it  will  not  irrpact on  the  water  flow  lasin
Storage capacity or the "backwater curve".

                              111-21

-------
     Drainage ways,  channel  improvement,  deflector  systems,  and
berms are  all  techniques available  to  assist in  the  control  of
the flood water  flow velocity and backwater  consequences.
     The  technology  assumed  for  meeting the  proposed  criterion
was an average 10 foot perimeter levee systom design for the 100-
year f1ood.
     ( 3 )  Permafrost Areas ,  Cr i tical  Habi tat, and Recharge
          Zones of Sole Source Aquifers
          Before locating a disposal  site in these areas, it must
be demonstrated  that  alternative  locations  and practices are not
practical;  it  has  been  assumed   for  purposes  of  meeting  this
restriction  that  additional  study and  evaluation  costs  would be
incurred for new sites in selecting such a location.
     The basic technology for operating sitos in permafrost areas
and  recharge  zones is  discussed  under surface  and  ground water
protection  technologies (Section III.B.  an
-------
     (4)   Technology to Meet More Restrictive Alternatives


          The  more  restrictive  alternative  for  all   environ-
mentally  sensitive  areas  is  a  ban  on location of the facility in
these areas.  Therefore, wastes presently being disposed in  these
areas would  have  to be hauled  to another location.   No  new  sites
could be  located in these areas


     (5)   Technology to Meet Less Restrictive Alternatives


     The   less   restrictive  alternative  for   all  environmentally
sensitive  areas was  not  to include  a  criterion;  therefore,  no
technology is required.


     b.   Assumptions
          The  major  economic  impacts  of  this criterion  result
from the need to provide levees for landfills located in wetlands
and  floodplains and  to  close surface  impoundments  located  in
these areas.   Only  two  regulatory alternatives result in costs--
the  proposed  and   one  which  is  more  restrictive.     The  less
restrictive  alternative  of  not   including  the  environmentally
sensitive   criteria   does   not   result  in   additional   costs.
Furthermore, the economic  impact  of  1andspreading  operations  in
these areas was assumed to be negligible.


     For  surface  impoundments, an  assumption  was made  that  all
sites  located   in  any  type  of  environmentally  sensitive  areas
would have  to  close,  but  would be replaced  on  a  1:1  basis.   The
technology  to   facilitate  this  for  both the  proposed  and  more
restrictive alternative included  fencing  around the  old site,  in
addition  to land  purchase,  excavation  and lining  for the
new
                              111-23

-------
si te.
     Landspreading of  waste  as soil  conditioners  or  fertilizers
is  exempt  from the  floodplains  criterion.    Since  1andspreading
generally is not practiced in the  other environmentally sensitive
areas,  it  is  assumed  that  the proposed  criterion would  have  a
minimal  or negligible impact on this disposal  method.


     c.    Costs
          Cost  estimates  for the  effect  of this  criterion  were
developed based upon the above technologies and on unit costs for
each technology, as  a  function  of site size.   Unit costs and the
data base  are presented in  greater  detail in  Section  II  and in
Appendix V (Volume II).


     No  State-standard-induced   costs  have   been  ascribed  to
landfills because (1) currently very few States have ESA legisla-
tion,  and  (2)  in those States with  ESA legislation,  it has  been
deemed adequate.  However,  there are State-standard-induced costs
for  surface   impoundments  because  calculations  were  based  upon
closure costs rather than upon a legislative analysis.


     In  summary,  the proposed  regulation  would affect landfills
in   18 States,   resulting   in  costs   ranging   from  $7,600  to
$1.9 million  per State.    Similarly,   for  the  more  restrictive
alternative,  these  18 States  would  incur  costs  ranging  from
$7,600 to $16.9 million per State.  For surface impoundments, the
proposed alternative will  affect  44  States at  costs ranging from
$15,700   to    $65 million   per   State;   the   more   restrictive
alternative imposes  the same costs.
                              111-24

-------
     Table 14  compares  annual!zed  costs  based  upon  disposal
method and regulatory alternative.
     d.   Economic and Environmental Comparisons Among
          Alternatives
          Table 15   shows   the   economic   and   environmental
comparisons among alternatives for this criterion.  Comparing the
more  restrictive alternative  with  the   proposed  shows  that  an
additional combined  cost  of $15.0 million per year  for the more
restrictive  does  provide  a   return  in  terms   of  environmental
benefits.   However,  at landfill  sites  and surface impoundments,
the  more  restrictive  alternative  for   sole   source  aquifers,
critical  habitats, and  permafrost areas  would impact severely on
current  disposal  practices,  resulting  in  a significant, reduction
of  potential  disposal  site  areas.  In addition  to being unneces-
sarily strict, the more restrictive alternative  would require the
transportation  of  wastes  to  another  location with  attendant
environmental and economic impacts.
                              111-25

-------
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                                                    111-27

-------
B.    SURFACE WATER

1.    Importance;  Adverse  Effects  from  Improper  Disposal


     The  nation's   rivers,  streams,  and  lakes  (and  associated
plant  communities)  are  a   vital  aesthetic,   ecological,   and
economic  resource,  serving  as recreational  places  for  people,
sources of  water  for  drinking and  industrial  purposes,  and  the
dwelling  place  for  a  wide  variety  of fish  and  oth-er  aquatic
organisms   that  depend  on an  oxygen-sufficient,  uncontaminated
living environment.  In  this  century we  have witnessed  the severe
pollution   of  this  valuable   resource,  including the  widespread
contamination of several  of  the  Great  Lakes and large  stretches
of lakes and rivers due  to a  variety of  human activities.
     Solid  waste  disposal   has  often led  to surface water  con-
tamination  from runoff  of  leachate,  accidental  spills,  and drift
of spray occurring at dumps, landfills,  surface  impoundments,  and
landspreading operations.
     One  study  cited  162  cases  of  surface water  contamination
from  industrial  waste  disposal,  of which  42  (26%)  occurred  at
surface  impoundments,   49  (30%)  at  landfills  or  dumps,  and  71
(44%)  at  landspreading operations or  from  haphazard  disposal  on
farmland.  (Ref.  79.)
     The  principal   source  of  surface  water contamination  from
landfills  is  leachate, caused  by  water percolating  through  the
refuse.  Leachate, a highly mineralized fluid,  typically contains
such  constituents  as  chloride,  iron,  lead,   copper,  sodium,
nitrate, and a variety of organic chemicals.  Where manufacturing
wastes  are  included,  hazardous  constituents are often present in
the  leachate  (e.g.,  cyanide,  cadmium,  chromium,  chlorinated

                              111-28

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hydrocarbons, and PCB).  The particular makeup of the leachate is
dependent upon  the  city and/or  industries  using  the  landfill  or
dump.   The  types and  concentrations  of  contaminants  in  leachate
are  of  great importance in determining  its  potential  effects  on
the quality  of surface water.


     The amount of  infiltration  from  precipitation  that  falls on
a  disposal  site  is  the major  factor affecting the  quantity  of
leachate  that  can  be  generated.   Therefore,  the extent  of  the
potential problem  of  surface-water contamination resulting  from
leachate is  greatest  in  areas  where average annual  precipitation
exceeds  the  potential  water  losses by evaporation and transpira-
tion.    Such  areas  are  generally  found  east of  the  Mississippi
River and in  the  coastal  region of the Pacific  Northwest.   About
71 percent  of  the  municipal  refuse disposal sites  found  in  the
United States are located in these water surplus areas.
     Industrial  waste  water   impoundments  also  pose  a  serious
threat  to  surface  water because of  their  large  number  and  their
potential for leaking or overflowing as a result of precipitation
and  flooding.    Faulty  design,  accident,  or failure  of  surface
impoundments  containing industrial  effluent can  cause  surface
water  contamination  because   of  leakage  of waste  waters  into
streams, lakes, or rivers.   Potential contaminants cover the full
range  of  inorganic  chemicals  and  organic  chemicals  normally
contained in industrial  waste waters.  Those documented as having
degraded  surface  water quality  include  phenols,  acids,  heavy
metals, and cyanide.


     Although  the  effect  on  surface  water  of   1 andspreading  of
industrial   wastes  is not  well  documented,  indications  are that
some  contamination  is  occurring  in  the  heavily  industrialized
regions of the country.    (Ref.7).
                              111-29

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 2.   Regulatory  Alternatives  and  Environmental Consequences
     a.    Point  Source  Discharges
          (1)   Proposed  Criterion
               This  criterion  seeks  to  achieve the  objective  of
the  FWPCA:    restoring  and  maintaining   the  integrity  of  the
surface  waters   of  the   United   States.     Accordingly,   all
point source discharges of  pollutants, including  surface  runoff,
surface  leachate,  or  leachate treatment  effluent,  must  comply
with  an  NPDES  permit  issued  for  the  facility,  according  to
Section 402 of FWPCA.
     No lesser  or  more restrictive  alternatives  were  considered
because they would conflict with the requirements  of  the  FWPCA.
     The  environmental   impact  of  the  proposed   criterion   is
minimal; the  major  benefit is the  implementation  of  an  existing
control  mechanism,  section  402   of the  FWPCA,  to  ensure  that
surface waters will  be protected  from contamination due  to point-
source discharges.
                              111-30

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     b.    N o n p o in t-S o u r c e D i scharges


          (1)  Proposed Criterion


               The  proposed  criterion  calls  for  preventing  or
minimizing  non-point  source  discharges of  pollutants,  including
surface leachate,  leachate seepage, and  surface  runoff  into  any
off-site  surface  water.    According  to  this  criterion,  non-point
source  discharges   would  be   prevented   or  minimized   through
facility  design,  operation,  and  maintenance  (e.g.,  by artificial
or  natural  barriers  (e.g.,  liners,   levees,  and  dikes),  and
collection of such waters if  produced (e.g., by ditch or  trench).
If  such  waste  waters  are collected,  they  then  would   become  a
point source,  thereby  requiring  an  NPDES  permit if discharged to
off-site  surface  waters.   This  regulation also calls for  chan-
neling  the  runoff from adjacent  and  surrounding  lands  away from
the disposal site to avoid contamination.


     This  criterion  calls   for  the  implementation  of  practices
which  will  minimize  non-point  source  leaks and  discharges,  and
thereby potentially  creates  additional requirements  for on-site
treatment  or  NPDES permits.    The environmental benefit  of this
criterion  is the  reduction in  the chance  for bacterial  and  chem-
ical contamination of surface water by non-point discharges.


          (2)  More Restrictive Alternative
               A  more  restrictive  approach  to  the  problem  of
protecting  surface  water  would  be the  prohibition of  all  non-
point  source  discharges--i.e.,   zero  discharge.    An  outright
prohibition  would  mean  that  disposal  facilities  would have  to
install  dikes,  culverts,  and  storage   basins,   etc.   of  such
capacity to handle all likely precipitation incidents  and of such

                              111-31

-------
design   to   prevent   any  discharge   (regardless   of   volume,
concentration  reduction   or   quality).    Since  ground  water  is
generally  connected  to   surface  water,  this  could  mean  zero
discharge to ground water  would  be necessary regardless  of site-
specific situations.   Such a prohibition would  also  create  some
inconsistencies  in  logic,  since  point source   discharges   are
permitted under  regula ted conditions;   non-poi nt  sources  would
have  similar  environmental conseauences and  should not  be  more
severely regulated.


          (3)  Less Restrictive  Alternative
               Failure to address  the  issue  of  discharge of non-
point sources  to  surface  water  invites continued adverse effects
from  leakage  of  leachate  and runoff to  surface  waters.   Indeed,
since technology  for  control  and  management  of  non-point sources
is  available  and  is  usually  relatively inexpensive,  such  an
approach is unwarranted.
     Point  source   discharges  would  still  be  covered by  MPDES
permits,  but  very  few   landfills  or  1andspreadinq  operations
currently  have  such  permits.   One might  argue that  failure  to
address  the  non-point-source  issue   should  cause  no  serious
environmental impact,  since  Section 208/301  of  the FWPCA  provide
authority  for  controls for  leachate  seeps.   However,  the  "208"
control  standards   for disposal  sites  are  being  developed  on  a
local  level, are not well  established, are still being developed,
are  not  uniform,  and  will  be implemented on  varying  schedules.
Due  to  the  varied  nature  and   limited  availability  of  such
standards, they are not useful as national  criteria at this time.
                              111-32

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3.    Summary Technology, Economic,  and Environmental  Impact
     Analysis


     a.    Technology
          Surface waters are  protected  by  minimizing  or prevent-
ing  (1)  leachate generation  and  (2)  the   flow  of leachate  and
wastes to  off-site  surface waters.   These are  achieved  through
proper  site  selection,  design,  and  maintenance.   The  primary
factors  in  determining what  controls  are  necessary  to  protect
surface waters are  topography  of the  site  and surrounding lands,
proximity  of  surface  waters,   and   precipitation.    The  major
methods to protect surface waters are:
     (1)  divert off-site  surface  waters (including  streams  and
          surface  runoff  from  surrounding  lands)   around  the
          disposal   facility,   or   if  they  must  go   through  the
          facility,  use   a   conveyance   system   which   prevents
          contact with the wastes;
     (2)  encapsulate the wastes with top and/or bottom  liners or
          barriers  to prevent or minimize surface or  ground water
          infiltration and leachate generation;
     (3)  utilize  and  contour  cover  materials   and  vegetate  the
          site  surface   to   encourage   runoff   and   prevent   or
          minimize  erosion and consequent exposure of wastes;
     (4)  construct  dikes,  berms,   or   similar  barriers  and/or
          ditches,   culverts,   tiles,  basins,   sump  pumps,   or
          similar  drainage  and collection  systems  to  control
          leachate  seeps and discharges.


     These control   methods are also  applicable  to  protection of
ground water, as indicated in the next section  (IIIC.).
                              111-33

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     To estimate  costs  of the proposed  surface  water  criterion,
the use  of  a combination of  technologies was  assumed,  including
channeling of water courses,  intercepting and diverting  tributary
drainage,  controlling on-site runoff,  and contouring  and  revege-
tating disturbed soils.


     The  more  restrictive  regulatory  consideration  mandates  a
zero  non-point  source  discharge.    In  addition to  the  technical
measures  described  above, this  alternative requires  additional
ditches  and  sedimentation   control  facilities,  as  well  as  a
leachate collection and  treatment system.  These  technologies  are
based  upon  what  EPA considers  to  be  proven and  tested  methods.
Although  regional  solutions   may  vary,  they  represent  the  best
available approach for a nationwide assessment  of costs.
     b.   Assumptions


          The  major  economic  impact  of  this criterion  results
from  the  need  to  control  non-point  source  discharges  from
landfills  to  surface waters.   Only two  regulatory  alternatives
were considered  to have  economic  impacts—the proposed criterion
and  one  which  is  more  restrictive.    The  less  restrictive
alternative does not  mandate controls since it relies on existing
Federal  legislation  (i.e.,  Section 208  of   P.I. 92-500)  which,
therefore, would not  result in a Criteria cost.


     Since point source  discharges  are currently regulated under
P.L. 92-500,   NPDES  permit  costs  are  not  attributed  to  the
Criteria.   That is,  in  regard  to  point  source  discharges, this
criterion  refers to  the  implementation  of  an  existing  control
mechanism--Section  402  of P.L. 92-500.
                              111-34

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     It  is   also  assumed  that  surface  impoundments  and  land-
spreading   operations   will    be   minimally  affected   by   this
criterion,  and consequently,  they  were  not analyzed for  economic
impact.  Surface  impoundments with  surface  water  discharges  are
currently regulated  by  P.L.  9?-500  as  part  of  an  NPDES  program
and it was  assumed that both point source discharges and  nonpoint
source  discharges   are  controlled   under  this   program.     In
addition, discharges from  sur.face  impoundments  are frequently to
ground water  instead of to surface  waters  and  are considered in
another  section  of  this document.    Landspreading  operations  on
agricultural  land  were  considered   to  be  minimally affected  by
this criterion because of current erosion control  techniques such
as  contour  plowing, which  have  the effect of reducing  surface
runoff.
     c.    Costs
          Cost  estimates  for the  effect  of this  criterion  were
developed based upon the above technologies and on unit costs for
each technology, as a function of site size.  Since some of these
technologies are required for ground water controls,  a balance in
assigning  these  costs  between   the   surface  and  ground  water
criterion  was   used  to  avoid  double   accounting  of   costs.  Unit
costs  and  the  data  base  are   presented  in  greater detail  in
Section IV and in  Appendix IV, (Volume II).
     In summary, the proposed regulation would not cause costs  in
thirteen  States,  while in  the  other thirty-seven  States,  costs
will  be incurred  ranging  from  $41,000 to $4.3 million per State.
Similarly, for the more restrictive alternative,  no costs will  be
incurred  for  the  same thirteen  States,  while the  other  thirty-
seven   States   will   incur   costs   ranging   from   $51,000   to
$5.3  million per State.
                              ni-35

-------
     Table 16 compares annualized costs  based  on  disposal  method
and regulatory alternative.
     d.    Economic and Environmental  Comparisons  Among
          Alternati ves
          Table 17   shows    the   economic    and    environmental
comparisons among alternatives for the surface water criterion.


     Comparing the more restrictive alternative with the proposed
shows that  an  additional  combined cost of  $6.6 million  per  year
for the  more restrictive alternative  does  not provide a return in
terms of  environmental benefits.   Rather,  the more  restrictive
alternative would only have the effect of  increasing the need for
additional  storage  capacity  for  runoff.   In  comparing  the  less
restrictive alternative with  the proposed,  EPA has concluded  that
the  $28.8  million  per year increase  for  the  proposed regulation
is justified in terms of environmental benefits.
                              111-36

-------
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                                                     111-38

-------
C.    GROUND WATER

1.    Importance;  Adverse Effects From Improper Disposal

     Ground  water  is  often  a  high  quality,  low cost,  readily
available  source of  drinking  water.*    Almost  one-half  of  the
population of  the  United States depends  upon   ground water  as  a
source of  drinking water.    At almost  any  location  in  the U.S.,
ground water  may be  tapped  to  provide a  supply  sufficient  for
single family domestic use, and more than one-third of the nation
is  underlain  by  aquifers generally  capable  of  yielding  at least
100,000   gallons   per  day   (about   70   gallons/minute)   to   an
individual well.   In  many regions,  ground water is the only econ-
omic and  high  quality water source available.  In others, ground
water  can be  developed  at a  fraction  of  the  cost of  surface
water.   Ground water in aquifers  across  the  nation  is  generally
suitable  for  human   consumption  with   little  or  no  treatment
necessary.   Some large  cities  rely exclusively  on  ground water
for drinking water.

     Ground water  has been contaminated  by  solid waste  disposal
facilities on  a  local  basis in all  parts of  the  nation  and  on  a
regional   basis  in   some  heavily   populated  and  industrialized
areas, precluding its use as drinking water.  (See Refs.  4, 7,  8,
10,  12,  15,   16,  43,  45,  46,  51,  79).   Serious  local  economic
problems  have  occurred  because  of the   loss  of  ground-water
supplies.  The degree of reported contamination has ranged from  a
slight degradation of natural  quality  to the presence  of toxic
concentrations of  such  substances   as heavy  metals,  organic  com-
pounds,  and   radioactive  materials.    Many  known  instances  of
ground-water  contamination  have   been  discovered only   after  a
drinking water well  has been  affected.    Effective monitoring  of
* S e e Ref. 7, from which most of these findings are gleaned,  for a
further discussion of ground water resources and contamination source
and problems.

                              111-39

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potential   sources  of  ground-water  contamination is  almost  non-
existent.

     Leachate is contaminated water  which  is  produced when water
(from  precipitation,  ground water,  surface water  or  liquid  in
wastes) passes  through  wastes  in  a  land disposal site.   Leachate
production is common  in  the  United  States  because most sites are
subjected   to  substantial  precipitation,  and  although  many  have
surface   runoff  controls,   very  few   have  liners  to  prevent
percolation of  precipitation into the  wastes.   It is impractical
to  cover  the  working  face,  and uneven  settlement,  erosion,  etc.
result  in  ponding  and percolation.   Furthermore, wastes  at  many
sites have been placed directly in contact  with  surface or ground
waters  (e.g.,   in  streams,  marshes,  and  sand and  gravel  pits).
Once  produced,  leachate usually migrates  from  the  disposal  area
and enters surface or  ground waters.

     Ground  water   is  usually   very  slow  moving;  therefore,  it
often  takes  years  or  decades  for   contaminants  to  reach  water
users.    It  also  takes decades or  even centuries  for  a  ground-
water  resource  to  purge  itself  even  after  a contamination source
has  been   removed.    The  mechanisms  of soil  attenuation  (e.g.,
adsorption,  ion exchange,  precipitation,  or  dispersion)  have  a
limited  capacity,   are  not  always  avai 1 able,and are  reversible
since  attenuation  is a function of  soil and  leachate character-
istics,  thickness   of  unsaturated zone,  soil  homogeneity,  flow
rate,  concentration,  and pH.   Because  of  this,  soil  attenuation
alone  is  not  always   sufficient  to  assure prevention  of ground
water contamination from a waste disposal  source.

     The  characteristics  of  leachate are  primarily  a function of
the types  of wastes,  amount  of infiltrating water,  and pH.  High
concentrations  of  heavy metals, other  inorganics,  organics, and
biological contaminants,  generally  higher   than  waste water, are
common  in raw leachate.
                              111-40

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     Chemical contamination of  ground  water  may  occur from land-
spreading  of sewage  sludge.    Some constituents  in  sludge  are
soluble  and  are  likely to  be  leached  more  readily  than  others.
These  include  sodium,  potassium,  sulfate, chlorine,  and  nitrate
ions.   Other constituents  are  held more strongly  in  the  sludge
matrix  or  are  attenuated  more  strongly  in   soil.   These  include
calcium, magnesium, and the group  of heavy  metals.   Constituents
which are more strongly held  in sludoe or move relatively  slowly
into or  through  the  soil  profile  pose  less  of a  threat to  ground
water,  but  may  affect the  quality  of  crops  to  a  greater  extent
(see food chain crop criterion).

 2.  Major Regulatory Issues

     The major regulatory  issues for ground  water are:
           Definition of ground water to be protected
           PI ace of compli ance
           criterion alternatives
     Ground water  can  literally include  all  the  water  under the
earth's  surface.   Classification or  definition of  this  water  is
necessary  to   identify  under  what  conditions  this  water   is  a
valuable   resource  requiring   protection.      Generally,   the
occurrence  of  this water  may be divided  into  zone  of saturation
and  zone  of aeration.   The water  occurring  within  the  zone  of
saturation is commonly referred to as ground water and it is this
water   that  is   considered   for   coverage  by   the  Criteria.
Identifying ground water  for  protection  should  also consider the
fol1owi ng factors :
           Quantity (yield-transmissivity)
           Usage (existing or planned)
           Qua!i ty
                              111-41

-------
     Providing  protection  for  ground  water  must  also  address  the
plac2 of compliance such  as:

           all  usable ground  water
           specific distance  from waste  disposal
           property boundary
           nearest usable  wel1

    The last major issue  is  what impact,  if any,  is  allowable.
The criterion may specify  allowable impact, or  it may specify tech-
nology level which is based  on  probable  impact.   Examples  of  such
criteria alternatives are:

           zero di scharge
           zero degradation  beyond  background  quality
           zero degradation  beyond  a  specific  limit
           zero impact on  treatment required
           specific technology  - best management practice
 3.   Regulatory Alternatives and Environmental  Consequences

     Proper site location  and  ground  water/land  use planning,  as
well  as  design,  construction,  operation  and   maintenance   of
facilities, are the principal  techniques available for minimizing
ground-water  contamination  problems.    Where economics  or  other
factors dictate  that  sites be  located  in  areas  of  usable  ground
water  (such  as  existing  and  potential  drinking  water  sources),
such technologies  as  physical  containment  (liners),  collection,
and treatment of leachate may  be necessary.

     EPA feels that the ground-water criterion  should establish a
comprehensive  ground-water protection  standard  for  all   solid
waste  disposal  practices.   The goal  is  to protect  all  current
users of the  ground  water and  to protect other designated  ground
water  for  future  usage.    Of   primary  concern  is  protection  of
                              111-42

-------
current and future ground water used for drinking water supply.

     As  a  national   policy,  EPA  feels  that those  ground  waters
currently  used  or  potentially usable as  a  drinking  water  supply
should  be  protected for  that use.   States  should be  given  the
option to classify ground water for other uses.

     a.   Proposed Criterion

          Key definitions in  the  proposed ground water criterion
are  "ground  water",  "aquifers",   and   "endangerment".    Usable
quantities of water in the zone of saturation are covered in this
criterion.

     The  suggested   criterion  uses  the  "endangerment"  approach
proposed  for  the  Underground  Injection  Control  Program  (UICP)
standards  (41 R}  36726)  which  prohibits  any contamination  that
would require additional  treatment of current  or future drinking
water  supplies  or  otherwise  makes  the  water   unfit  for  human
consumption.  Drinking water supplies are defined as ground water
which  is  currently  used  or  designated  by the State  for such  use
ฃฃ waters  with  10,000 mg/1   or  less total dissolved  solids  that
have  not  been  designated   by  the  State for  other  use.    The
proposed criterion sets the  endangerment requirement for drinking
water supplies at  the disposal site property boundary.

     To  prevent  endanqerment  of  drinking water  supplies  beyond
the property boundary,  the disposal facility must (1)  collect  any
leachate  produced  by  using  an  artificial  liner  and,   where
appropriate, remove,  recirculate,  or treat  the  leachate,  or  ( 2 )
control   leachate   migration  by   using   natural   hydroneologic
conditions,  soil   attenuation  mechanisms,   and/or  recovery  and
treatment  of  contaminated  water.   Under  method  (2)  infiltration
of  water  into  the  solid  waste  is  to be minimized  or prevented
where appropriate.   Under both methods, ground-water monitoring,
prediction  of   leachate  migration,  and  a  contingency  plan  for
                              111-43

-------
corrective  action  is  mandated  so  long  as  leachate  may  enter
ground water in such  quantities and  concentrations that endanger-
ment at the property  boundary may occur.

     For  ground  water  designated by  a  State for  use  other than
human   consumption,   (e.g.,   as   waste    sinks,   oil    and   gas
production), water quality standards specified by the State shall
be maintained.   Conditions  in  which a State may designate a non-
drinking  water  use  are:   (1)  the  ground  water  is  already  so
contaminated, deep, or low yield as  to be impractical or adequate
alternative  drinking  water  supplies  are  available  for all users
in the  affected  area  into the  foreseeable future, and (2) waters
of  an  adjacent   State  or  country  will  not  be endangered  and
adequate hydrogeologic conditions exist to protect drinking water
supplies from endangerment.

     While  the  "endangerment"  criterion  is  to  be  applied at the
property  boundary  of  the disposal  site,  controlling leachate at
the  waste  boundary is essentially  the only  means to effectively
achieve this goal  at the  property boundary.  Likewise, monitoring
ground water at  the waste boundary is the most effective means to
measure effectiveness of  control technology.
     The  proposed  criterion  provides  significant  environmental
benefits to all ground-water users, present and future.

     b.   More Restrictive

          A more  restrictive  alternative  would  be  to   allow no
degradation of  all  usable (10,000 mg/1  IDS or less) ground water
(in  the  saturated  zone), on  or  off  the  site.    This criterion
would result  in  the need for liners and collection and treatment
of  all  leachate   at  most  landfills  and  impoundments   and  at
considerable  additional   expense.   The  additional  environmental

                              II1-44

-------
benefit  would  be  the  protection  of   ground  water  under  the
disposal   site  as  well  as  beyond  the   property  boundary  and  a
decrease  in the  chance of  off-site pollution migration caused by
designer  error or unknown subsurface conditions.

     c.   L e s s Restrictive

          A less  restrictive  alternative would be  to  require no
"endangerment" (impact  on treatment  required  or  otherwise render
the  water   unfit  for  human  consumption) at  the  nearest  usable
well,  and   allow the  unrestricted  designation  of  ground-water
"sinks".    The concept of no  "endangerment"  means  only  that no
further  treatment of  the water is required now or  in  the future
(although the  water  quality  may be degraded  somewhat).

     The  environmental  consequence  is that  this  would  allow off-
site  degradation  of  ground  water.   Also, this  alternative  might
not  adequately  protect supplies for future usage and  might lead
to haphazard designations of pollution  "sinks".

4.   Summary Technology, Economic, and  Environmental Impact
     Analysis

     a.   Techno!ogy

          Ground water  is  protected by  minimizing  or  preventing
(1)  leachate  generation and  (2) the flow of  leachate  and wastes
from  the site; these  are achieved through proper  site  selection,
design  and  maintenance.    Leachate  generation   and   flow  are
prevented or minimized by:

          covering the wastes  with an  impermeable material  to
          prevent or  minimize  precipitation  infiltration;
                              111-45

-------
          contouring  cover  materials  and  vegetating  the  site
          surface   to   encourage   surface   water   runoff   and
          transpiration,  and to prevent or  minimize  infiltration
          and erosion;
          contouring  and  vegetating  adjacent  lands  to  prevent
          surface water runon  from offsite  areas;
          constructing dikes,   berms,  or  similar barriers  and/or
          ditches,   culverts,   tiles,  basins,  sump   pumps,   or
          similar  drainage  and   collection  systems  to  control
          surface   and   ground   waters,    leachate   seeps   and
          discharges;
          providing enough depth  between the wastes  and expected
          high  ground  water  level  and/or  providing  a  barrier
          material  and/or  ground  water pumping  program  to prevent
          ground-water infiltration into  the wastes;
          collecting  (via   liners and/or  pumping  program)   and
          treating   leachate  prior  to  discharging  it  to   the
          surrounding  environment;
          taking advantage  of  the natural   assimilative  capacity
          of  soil   and  hydrogeologic  conditions   to   maximize
          attenuation   and   prevent  endangerment  of  the  ground
          water.

     b.   Assumptions

          The major economic   impacts of  this criterion  result
from the  need to control  leachate generation  and migration  from
landfills  and  surface  impoundments.    Since,  as   a  practical
matter,  1andspreading  on  food chain  crop  lands  is limited  to
amounts   and   concentrations    which  will   not   retard   plant
productivity, it  is assumed  that landspreading operations  will
have a  minimal   impact  on ground  water  and,  therefore,  will  be
only minimally  affected  by  the   ground-water  criterion.  It  is
further  assumed that,  although   some  landspreading on  non-food
chain  crop  lands  may  impact   ground  water, the national  impact
will be minimal  because,  as  a  practical matter, landspread wastes
                              111-46

-------
are generally applied  in  relatively  thin layers which allows for
natural  phenomena  to  attenuate or otherwise  minimize  the  impact
on ground water.   Thus,  the economic impacts of the ground-water
criterion  were  assumed   to   be   negligible  for  1andspreading
operations.

     To  estimate   the  cost for  landfills  to  meet the  proposed
ground  water  criterion,  a clay  liner  above  the  seasonal  high
ground water level  and a leachate  collection and treatment  system
were  used.    An  impermeable   bentonite  clay  liner  was used  to
estimate  costs  for  surface   impoundments   to  comply  with  the
proposed criterion.

     The following assumptions were made for the three regulatory
alternatives:

          for the  less restrictive,  all  authorized*  sites  would
          require ground-water controls;
          for  the  proposed,  ground-water   controls   would  be
          required  by   all   authorized*   sites;   in   addition,
          permitted*   sites   in   States    having   ground-water
          standards  less  stringent  than  the  proposed  criterion
          would also require controls;  and
          for the  more restrictive,  ground-water  controls  would
          be  required  for  all  authorized*  and  permitted*  sites
          located  in States having  standards less stringent than
          zero-discharge.

     For purposes  of differentiating between regulatory alterna-
tives  for   surface  impoundments,   it  was  assumed  that  for  the
proposed  alternative,  50%  of all  sites  would  require  lining;
while  for   the  more restrictive  alternative,  75%  of  all  sites
would require  lining.   The less  restrictive  alternative was not
considered to have any economic impact.
Mhese terms as used in this report are defined in Chapter IV,  on pa
IV-5.
                              111-47

-------
     It  was  also assumed  that  a modest  three-well  ground-water
monitoring system would  be  necessary  at all  of the sites needing
ground-water controls.

     c.   Costs

          Cost estimates  for the effect  of  this  criterion  were
developed based upon the above technologies and on unit costs for
each technology  as  a  function  of site size.    Unit  costs  and the
data base  are presented in greater detail in  Section  IV,  and  in
Appendi x V (Volume II).

     The  costs   of  the   technology   to   control  ground  water
contamination for landfills are the  following:

          the proposed regulation would not result in costs in  11
          States, while in the other 39 States  costs ranging fron
          $173,000 to $16.2 million  per State will be incurred;
          the  more  restrictive  alternative will  not cause costs
          in 7 States,  while in the  other  43  States costs ranging
          from  $526,000  to   18.9  million   per   State  will  be
          incurred;
          the  less   restrictive  alternative  will  not  result  in
          costs  in  11  States,  while in the other 39 States costs
          will range from $173,000 to $14.8 million per State.

     For  surface  impoundments,  all  the  States will  incur costs
for  control  technology for  ground  water;  costs  will  range  from
$199,000 to $283.7 million per State.

     Table 18  compares  annualized  cost on a nationwide basis  by
disposal method and  regulatory alternative.
                              111-48

-------
     d.    Economic and Environmental  Comparisons Among
          AT ternatives

          Table 19   shows   the   economic   and   environmental
comparisons among alternatives for the ground-water criterion.

     Comparing the more restrictive alternative with the proposed
shows that an additional  combined cost  of  $493  million  per  year
for the  more  restrictive alternative does not provide a return  in
terms of environmental benefits.  On the other hand, in comparing
the  less  restrictive  alternative  to  the  proposed,  EPA   has
concluded  that   the   environmental   benefits   of  the  proposed
regulation justifies the cost.
                              11 1--49

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D.    AIR

1.    Importance;  Adverse Effects from Improper Disposal

     Clean  air  is  recognized  as  an  essential  component  of  a
healthy environment  for all  living  things.   Indeed,  the  primary
air quality  standards  of the  Clean  Air Act  of  1970  were  estab-
lished  to  protect  human  health,  while  the.  secondary  standards
were  designed  to  protect  crops,  plants,  and property  from  the
adverse effects of air pollution.

     One of the major air quality effects of solid  waste disposal
has been particulate pollution (smoke and ash) from open burning,
which  is  uncontrolled  or  unconfined  burning.   Uncontrolled means
(1) the  air  or   oxygen-to-fuel   ratio  (which   determines  the
temperature  and  efficiency  of  combustion)   is  not  governed,
(?) the combustion  residence  time  and  mixing  is  not governed, or
(3) the  emissions  of   pollutants  into  the  air  are  unchecked.
Emissions  of  pollutants into the  air  from  open  burning are high
compared  to controlled burning  such  as  municipal  incinerators
with  air  pollution control   equipment  (Ref. 30).   Tests indicate
that  smoke  from  most  open burning can cause definite eye irrita-
tion up to 400 feet from the fire  (Ref. 79, p. 37).

     The  impact   of  open burning  is  particularly acute  in  the
major metropolitan areas and air basins.  Currently, open burning
of  wastes  is  generally prohibited  in critical air  quality basins
unless a variance is obtained from the State and  local air pollu-
tion  control  agency.   However, establishing  variances  based on
potential  impacts  is   very complex because  of the  dynamic  nature
of  the many  variables involved,  such  as  existing  air quality,
wind  speed,  humidity,  mixing  lid  and  vertical  dispersion, effi-
ciency  of the  burn,   terrain,  amount  and  type  of  wastes,  etc.
Because  of  this  complexity,   adequate  variance  procedures  are
often  difficult to administer and  enforce.

                              111-52

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     In  addition  to  the  potential  health  and  property  damages
from air  pollution,  significant safety and damage threats caused
by  smoke  and  fire are associated with  open  burning.   Smoke from
open burning  of  wastes  can  reduce  air  and  auto  traffic  visi-
bility,  and  has resulted in  incidents  of multiple car accidents
and deaths on  expressways.   Unconfined fires at dumps may spread
and result in damage to property (Ref. 30).

2.   Regulatory Alternatives and Environmental Consequences

     a.   Proposed Criterion

          In  order   to  minimize  the  adverse  impacts  from  open
burning,  the criterion  for  air quality contains a prohibition of
open  burning  for  residential, commercial,  institutional,  and
industrial  wastes.    Open  burning of  other  waste  types  is  also
prohibited,  except  that,  in  special  situations,  States may give
variances to such burning in accordance with established State or
local   procedures.   Such  variances  are  to  be  conditioned  upon
specific  cl imatol ogical/meteorological situations, assessments of
waste types and amounts, and confinement  to prevent the spread of
fires.    Such  variances are  not to  be  given  in  situations  where
smoke may interfere  with the  visibility  of air  or  road  traffic
(i.e.,  near airports or expressways).  An  example of a waste type
and situation when such a burning variance may be issued would be
field  and brush  burning  in  agricultural  areas,  under  specific
atmospheric conditions.

     The  air   quality  criterion also  calls  for  the  control  of
harmful   waste   emissions  through  evaporation,   sublimation,  and
oxidation, so as to protect public  health  and welfare.

     In most cases,  States already  prohibit open burning of urban
wastes,    and   have   restrictions   on  burning  in  urban   areas.
Therefore, the  environmental  benefits  that  would result from the
proposed  ban   on  open  burning  and  variance  for  certain  wastes
                              111-53

-------
would occur outside outside of urban areas.

     b.   More Restrictive A1 tern a t i v e

          Banning  all  open burning  would obviously  protect  air
quality from the adverse effects of this practice.   However,  such
a ban  would have  a  significant impact on  disposal  practices  in
agricultural  areas  of  the country where  field  and  brush  burning
would   be   permitted   under   specific   atmospheric   conditions
(provided that the State has issued a variance for  such burning).
To  ban  all  open  burning  is  to  force  all  agricultural  wastes
(especially slash piles and brush/debris from 1andclearing)  to be
composted,  plowed  under,  used  as  a mulch,  or  deposited  in
landfills.

     c.   Less R e s t r i c t i v e A1t e r n a t i v e

          A less restrictive approach to the open  burning problem
would  be  to allow  such  burning in  accordance  with National  Air
Pollution  Control  Act  provisions.   Under  this regulation,  open
burning  of  municipal  and other wastes  would  be allowed in  rural
areas,  under  the  same  variance  procedures  as for agricultural
wastes.  This would allow open burning at a large  number of small
landfills  and dumps  which  burn  for volume  reduction,  and  thus
would  be  expected  to  have some adverse effects on  air quality in
rural  areas  of  the country.   The  current National  Air Pollution
Control Act requirements are very limited in terms  of solid waste
disposal  sites:   there  are  no new  source  performance standards
for dispoal sites, and ambient air quality standards and emission
standards  apply  to  only a very limited number of pollutants from
disposal  sites.    Further,  variance  procedures  allowed  in  the
State  Implementation  Plans are  too simplistic  or  too cumbersome
to  apply  to  uncontrolled  open burning  to ensure  a reasonable
protection  of air quality.
                               111-54

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3.   Summary Technology, Economic, and Environmental  Impact
     Analysis

     a.   Techno!ogy

          The primary technology for landfills to comply with the
air criterion is  to  refrain  from the practice of open burning to
achieve  volume  reduction.   Although  there  is  no cost directly
associated with  this  technology,  indirect costs will  result from
the  additional  land  and  cover  soil  required  for the  increased
quantity  of  wastes.    Periodic  application  of  cover soil  is
required  by  all   States   to   control  disease  vecto'rs;   since
permitted and authorized  landfills  already  apply cover material,
no  costs for this  control  technology  are  ascribed  to the  air
criterion.    Consequently,  only  the  additional  land  costs  are
included for the proposed air criterion.

     Another  potential   source   of  air   contamination  is  the
evaporation  or  sublimation of  solid  waste  from surface impound-
ments.   However, these contaminants are impossible to estimate at
this   time,   but  are  assumed  to  be  minimal;  and  some  are
controlled by the Federal  Clean Air Act regulations.   Therefore,
they  were  not  considered  in  determining  the  cost  of  this
cri teri on.

     To  estimate  costs   of   the  proposed  air  criterion,  an
assessment was  made  of the additional  land  required  as a  result
of  the  regulation.   For the proposed  regulation,  an  estimate of
55%  additional   land  has  been  assumed,  while  for  the  more
restrictive  alternative,  additional  land  usage of 6Q%  has  been
assumed.  These  costs  have been estimated,  based upon an average
cost of  $2,000/acre  for  land  and the amount  of  land  needed  as  a
function  of  site size.    This  solution  is  based upon  what  EPA
considers  to be  the  best  available  approach  for a  nationwide
assessment of costs, even though regional  solutions may vary.
                              111-55

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     b.   Assumptions

          Since  it  is  assumed  that  the  impact  of  the   air
criterion  on  almost all  surface impoundments and  1andspreading
sites  is  either  negligible or  non-existent,  the  economic  impact
on these  disposal  methods  was  assumed to be  zero.   Unlike  land-
filling, neither of  these  disposal  methods  utilizes open burning
as  a  method   of   volume  reduction  of  waste.    Costs  will  be
incurred,  however,  under  the  proposed  and  more  restrictive
regulatory  considerations,  at  landfills  that   currently   burn
wastes.   For  the  less  restrictive  regulatory alternative,  costs
have  not  been  assigned  to  the  Criteria  because  they are  the
purview of the particulate emission standards and othr provisions
of the Federal Clean Air Act.

     c.   Costs

          Cost  estimates  for  the  effect of  this  criterion  were
developed  based  upon the  above technology and on unit costs as a
function  of  site   size.    Unit  costs  and  the   data   base  are
presented  in   greater   detail   in  Section IV  and  in  Appendix V
(Volume  II).

     In  summary,  the proposed  regulation  would  not impact  costs
in 42  States,  while  the other  8 States would incur costs ranging
from $72,000  to  $1.5 million  per State.   Similarly, for the more
restrictive alternative,  no  costs will  be  incurred for the same
42 States, while the other eight States  will incur costs ranging
from $78,000  to $1.6 million per State.

     Table 20  compares  annualized  costs  based  upon  disposal
method and regulatory alternative.
                              111-56

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     d.    Economic and Environmental Comparisons Among
          A1 t e r n a t i v e s

          Table 21   shows   the   economic   and   environmental
comparisons among alternatives for the air quality criterion.

     Comparing the more restrictive with the proposed alternative
shows that  an additional  combined cost of  $300,000  for  the more
restrictive  alternative  provides  only  a  slight  return  over  the
proposed in  terms of  environmental benefit.  Further, a  complete
prohibition  of  open burning would significantly affect  agricul-
tural areas   of  the  country  where  field  and  brush burning  is
permitted.    In  comparing  the  less restrictive alternative to  the
proposed,  EPA  has   concluded  that  the  $2.9 million  per year
increase for  the proposed  regulation  is  justified  in  terms  of
environmental benefits.
                              111-57

-------
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-------
E.    APPLICATION TO LAND USED FOR THE PRODUCTION  OF
     FOOD CHAIN CROPS*

1.    Importance; Adverse Effects from Improper Disposal

     a.    Importance of Landspreading

          In recent years  the combination of  higher   fertilizer
prices and  increasing quantities of municipal sewage  sludge  and
industrial waste-water residuals has led to a .growing  interest in
land  disposal   of  solid waste.   For  example,  the Metropolitan
Sanitary  District  of  Greater  Chicago  has  been  applying  sewage
sludge from the equivalent  of 2.5 million people  to  6070 hectares
(15,000  acres)  of land in west-central  Illinois.

     The  potential  benefits  to be  gained  from  1andspreading
sludge   are  both   environmental   and   economic.     Thus,   land
application  of  solid  wastes  in environmentally  safe ways  can
contribute significantly to  productivity  through the  addition of
organic   matter,  nitrogen,  phosphorous,  potassium,  and  certain
essential trace  elements  to the  soil.    It  is estimated  that 25
percent   of  municipal   waste-waste  treatment  sludge is  currently
being spread  on land;  of  this,  about  20  percent  is  spread on
agricultural land  used for food crops  for direct  human consump-
tion, and for  forage  and  food grain for animals  raised for human
consumption.   The  remaining  5  percent  is used on nonagricultural
land (Ref. 105).

     Several studies  in recent  years  have  shown that  dramatic
increases  in   crop  yield  may  result  from  properly  applied  and
suitably  digested  sludge.    In  West  Virginia,  for example,  the
application of  30  tons of  sludge per acre more  than  doubled  the
*Food chain crops are tobacco; crops grown for direct human consumption;
and pasture, forage, and feed grain for animals whose products are
consumed by humans.

                              111-60

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corn yield  compared  to the  control  plots (Ref. 100).   Prior  to
the application of the sludge, the soil  was low in  total  nitrogen
and phosphorous, but contained moderate to substantial concentra-
tions of  plant-available  potassium, magnesium,  and  calcium.   In
another  study   conducted  for  EPA by  the Metropolitan  Sanitary
District of Greater  Chicago,  researchers  found that the  applica-
tion of  digested  sludge by  ridge  and  furrow  irrigation  resulted
in crop yields  comparable  to or greater than those obtained with
inorganic  fertilizers  applied  at rates  considered  adequate  for
maximum yields  (Ref. 93).   (Additional  discussion  of these  and
similar studies is presented in Appendix IV.

     From an economic standpoint, spreading waste-water treatment
sludge on land  used  for food chain crops offers communities a  low
cost disposal  method.   Such  a  disposal  alternative is essential
since  (1)  ocean  dumping  is  costly  and  fuel  supplies  for  this
purpose  may  not  be  available  in the  future;  and  (3)  sanitary
landfilling  is  not  always   feasible.   Indeed,  1andspreading  of
municipal waste-water treatment sludge may be the most economical
disposal alternative for many communities.

     b.   Adverse Effects from  Improper Disposal

          When  improperly  managed,   land application  of  solid
waste  to  agricultural  land  can create  a  potential  threat  to  the
food chain through the entry of toxic elements and  compounds into
the  diet,   including heavy  metals  such  as  cadmium,  pathogens,
pesticides, and persistent organics.
                              111-61

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          (1)   Heavy Metals*

               Although cadmium is the metal  of  greatest concern
in sludge, there are  a  number  of  other potentially  toxic metals,
including the  following:
               Aluminum      Chromium       Mercury
               Arsenic       Lead           Molybdenum
               Boron         Manganese      Selenium
     At higher concentrations most  heavy  metals  can become toxic
to plants  or  to animals  consuming  the plants.  For  some  of  the
heavy  rnetals,  toxicity  to  plants  or  adverse health  effects  to
animals or  humans  can  occur at  very low  concentrations.   For
example, boron  can  be toxic  to  plants at soil  levels  as  low  at
1 ppm.   Other  metals  such  as  cadmium,  mercury,  and  lead  are
extremely  hazardous  to  higher  animals,   including  man, at  low-
intake 1evels.

     Maintaining a  near-neutral   pH  and   preventing  the pH  from
falling below 6.5 can  limit  the  translocation of metals to crops
as well as  the  movement  of those metals  to ground  water, because
of the  formation of  insoluble  compounds  and  other  effects.  This
effect  works  for all  heavy  metals  of concern  except  selenium,
molybdenum, and  arsenic.

          Cadmi urn.   One  heavy metal  of particular  health concern
is cadmium.   The uncontrolled disposal of municipal  waste-water
treatment  sludge on  agricultural  land has  been  identified as  a
potential   cause  of  increased cadmium  in  the  human  diet through
the contamination of  food  crops.   This same  potential would hold
*In the chemical literature, the term "heavy metals" generally
refers to those metals having densities greater than 5.0.
                              111-62

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true for  the  addition  to  agricultural  soils of any cadmium-
laden Industrial waste water or sludqe.

     Cadmium  Is  of great concern  In  the landspreadlng  of  solid
wastes  because  the  metal  (1) can be  readily  taken up  by  crops
unless appropriate controls are imposed,  (2)has the potential  for
bioaccumul ation  in  tissue,  and  (3)  is  toxic  to  humans  and
animals.

     Since  the  application  of  solid waste  to  land  used for  the
production  of  food  chain  crops   can,  under  certain  conditions
(e.g.,  solid  waste  with  high  levels  of cadmium applied on low-pH
soils),  result  in  significantly  increased   cadmium  levels   in
certain crops,  these  criteria  are  intended  to minimize the  move-
ment of cadmium into the  food chain from solid waste  applied  to
the  land.   EPA, the Food and  Drug Administration  (FDA),  and  the
U.S. Department of  Agriculture,  as well  as  many other  groups  are
concerned over  the conduct of  any practice which  could signif-
icantly increase  the cadmium  level in food  crops  beyond current
levels.   This concern arises  from an  FDA  assessment  of teenage
males  in  this  country  (those  individuals  who consume  the  most
food), which concluded that their average daily intake  of cadmium
from food and water approximates the  total  tolerable daily intake
level  recommended   by  the  World  Health  Organization.    FDA  ha:,
stated that  "While  there  is no evidence  that the present cadmium
level  in   the  U.S.  diet  poses  a  health   hazard  now,  prudence
dictates  that  new  developments  should  not  be established on  a
large scale that could cause a significant  and possible irrevers-
ible increase in cadmium in the food  supply" (Ref.  109).

     The U.S. FDA  has  estimated  in their total diet studies that
the daily intake of  cadmium from  food  for  a teenage male in  the
U.S. is 72 micrograms.   This exceeds  the  "total tolerable" intake
of  57-71  micrograms  per  day which a United  Nations  committee  of
experts has  recommended  and which the FDA  recognizes.   FDA  has
stated that present cadmium intake, which is at the maximum  limit

                               111-63

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of the  "tolerable"  level, does  not  pose a  hazard  to  the public
health.   Consequently,  FDA  does  not  support any  practice  that
could cause a  significant  increase of  cadmium in the diet and it
has  specifically  placed  the uncontrolled widespread  application
of waste-water treatment  sludge in this category.

     The  FDA  made  the  following  recommendations  on  cadmium  to
EPA's June 3,  1976  proposed  Technical  Bulletin  "Municipal Sludge
Management:   Environmental Factors" (Ref. 115):

     (1)  Solid waste should not contain nore than 20 ppm cadmium
          on a dry weight basis when applied to  agricultural  land
          or  food  chain   crops.    (For  a sludge  with  5  percent
          solids,  this  means  that  the  cadmium  concentration  in
          the wet  sludge  should be under 1  ppm).
     (2)  In support of  the  limits,  the maximum  total  of cadmium
          which should ever  be added to an  average  soil  (cation
          exchange capacity of 5-15) is in  kg/ha  (9 Ib/acre).
     (3)  Good  agricultural   practices   should   be  followed,   as
          recommended by  the USDA,  including a  soil  pH of 6.5 or
          greater.

     The FDA-recommended  limitations on  cadmium  are   more strin-
gent  than the  criterion  for  cadmium proposed by  EPA.  EPA  has  a
number of reasons  for not selecting the FDA  recommendations.

     In response to  FDA's first recommendation that not more  than
20 ppm  cadmium  in  solid  waste  be  applied  to agricultural  land,
EPA believes that:

          Solid waste qua!ity  is  not as accurate an indicator of
          potential  food  chain  impact  as cadmium appli ed.  Thus,
          a   sludge   containing  20  ppm of  cadmium  applied   at
          20 mt/ha adds approximately the same amount  of cadmium
          to soils as  a  sludge containing  40 ppm cadmium applied
          at  10 mt/ha.   Therefore,  EPA  has proposed  to  control
          annual additions rather than  sludge quality.
                              111-64

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          Crop  uptake  is  governed  by  many   other   variables
          including annual  and cumulative  loadings,  as  well  as  by
          pH.
          Such an  inflexible  limit would  cause  loss of potential
          resources  since  it  does not  permit   lower  appli'ction
          rates for solid  wastes having  a  higher cadmium content.

     In response  to  the second FDA recommendation  that 10  kg/ha
(9 Ib/acre)  is the maximum  total  of  cadmium which  should ever  be
added to an  average soil,  the Agency's position  is  that:

          This control  is  warranted;  however,  provisions  should
          be made for soils where the  cation exchange capacity  is
          lower or higher  than average (5-15).
          A    maximum   annual   cadmium   addition   of   2.0  kg/ha
          (1.8 Ib/acre)   with    phasing    down   to   0.5  kg/ha
          (0.45 Ib/acre)  by  1986  and   pH   controls  should  be
          coupled  with  the  total  permissible  cadmium  limits  to
          protect public health.

     EPA has included the  third FDA recommendation  on keeping the
soil and solid waste mixture at a pH  of  6.5  or greater.

     Research  studies  have  shown  that  different  plant species,
varieties,  and  plant  tissues  accumulate different  cadmium  con-
centrations  (through uptake) from similar rates  of  application  of
municipal  waste-water  treatment  sludge.    Further,  studies  have
shown that  the crops  most  likely  to  accumulate  potentially  harm-
ful  levels  of cadmium  are  leafy  vegetables,   tobacco,  and  root
crops,  while  certain grains,  such as corn, tend  to exclude it.
Therefore,  there  is  a  need to control growth of the most vulner-
able  crops  on sludge-amended  soils,  to  avoid   the  ingestion  of
excessive amounts of cadmium with foods.
                              I 11-65

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     In  recognition  of  the  many variables  affecting uptake  of
cadmium, a  second  approach using monitoring  is included.   This
approach  is  specifically  designed  for  facilities  which  are
closely  managed  and  monitored.   It allows for  the  comparison  of
crops  or meats  produced  from   solid  waste   amended  soils  'with
similar crops or meats produced  locally where solid  waste has not
been  applied.    This  approch   provides  flexibility  to  those
facilities which possess the necessary resources and expertise  to
intensively manage and monitor their operations.

          (2)  Pathogens

               Pathogenic  organisms   occurring  in  waste-water
sludge  cover  a  wide  variety  :of  bacteria, viruses,  and intestinal
parasites.   Their  individual  presence,  as well  as their numbers,
will vary considerably from community to community depending upon
rates  of  disease  in  the contributing  population.   The fact that
these  organisms are present in sludge and are capable of persist-
ing  in  various  environments  is  a  fundamental   concern  whenever
sludge  is applied to the land.  Routes of infection to humans and
animals  can  be  through direct contact with contaminated environ-
ments  or through the ingestion of contaminated  food and water.

     All  of  these  pathogens  can  be  controlled  through  various
stabilization processes.  However, stabilization processes do not
always   render   the    sludge  totally   free   of  all  pathogenic
organisms; indeed, those organisms that  survive the stabilization
process,  or  are present in raw  sludge,  are capable of persisting
in  the environment for periods  of  days,  months,  and even years.
The  viability  of  most  pathogenic organisms in  soil  is from  a few
hours  to a  few weeks.   A  more detailed  discussion  of stabili-
zation  processes is presented in Appendix IV  (Volume  II).
                              111-66

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     In summary,  since  crops grown  on  land treated  with  sludge
can  contain  viable   pathogenic  organisms,  they  pose  a  pirblic
health  hazard  to  consumers,  particularly when  the  contaminated
crops are eaten raw.

          (3)  Pesticides and Persistent Orgam'cs

               Our ability  to manufacture  and  use  raw  chemical
substances  has  far  outstripped   our   understanding  of  their
environmental  and  public  health  consequences.    The  principal
interest  in  this  area has centered  around  chlorinated  biphenyls
(PCB's),  and  insecticides  such   as  DDT,  Aldrin, Dieldrin,  and
Chlordane.   What  happens to  people  or  animals when  they  consume
such new chemical substances  and  what happens to  these substances
in  the environment  are  very  complex  and  primarily  unanswered
questions.

     These substances usually are not ingested directly  by people
but are distributed to plant  and  animals and reach us through the
food chain.   Natural food chains  serve  as  biological  amplifiers
for  trace  chemicals   spread  out  in  our environment.   PCB's  and
pesticides  have  been detected  in  sludge  in   small  quantities
(Ref 7, p.  256).   Landspreading  of  solid waste  on  agricultural
land is one  of  the  ways  toxic,  potentially carcinogenic chlorin-
ated hydrocarbons  such  as DDT and PCB's can  be introduced into
the food chain.

          (4)  Direct Ingest ion

               Solid  waste contains  various pollutants that  can
adversely   affect   both   humans  and  animals.    These  pollutants
include pathogenic organisms,  heavy metals, organics,  and  other
inorganic  and  organic  toxicants.   The  application of  sludges  to
cropland and  pasture land  can result in  the direct  ingestion  of
                              111-67

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these  pollutants  by  animals  raised  for  milk.    Livestock  and
domestic animals  are  exposed  to  these  contaminants  when  grazing
on pastures that  have  received waste  or when eating  contaminated
forage.   Grazing  animals  are known to  ingest  soil  (and  probably
wastes) in  amounts  ranging  from  2  to  14 percent  of  their -diet.
This direct ingestion  of waste contaminants,  which  are present at
higher levels than  in  crops,  could  result in increased uptake of
heavy metals.

     c.   Inadequate Protection by Air,  Ground-Water,  and
          Surface-Water Criteria

          Although  the  air,   ground-water,   and   surface-water
criteria adequately  protect the  air  and water  environment  from
improper disposal practices  stemming  from 1andspreading  on  non-
productive  land,  these three  criteria   do  not protect the  food
chain  adequately.    As  the  previous   section   indicated,   the
presence in  solid waste of  heavy metals, pathogens,  and  pesti-
cides  poses  a potentially  substantial  threat to  public  health;
therefore,   a   specific  criterion  governing   the  application  of
solid waste to land  use for the production of food  chain  crops is
included in the Criteria.

2.   Regulatory Alternatives and Environmental  Consequences

     The criterion  governing  the  application  of solid waste to
productive  land  (intended   for   food   chain   crops)  addresses
cadmium, pathogens, pesticides,  persistent organics,  and  direct
ingestion  of  waste.   For  these  problems, the following  section
describes alternative  regulatory approaches--a proposed,  two  more
restrictive alternatives,  and  one less  restrictive  option.   The
additional   more  restrictive  alternative was  included because it
was  extensively  considered  during  the  Agency's internal  review
process, as an option  to the proposed  alternative selected.

                              111-68

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     a.   Proposed Criterion

          (1)   Cadmium

               With  the  goal  of  minimizing  the  movement  of
cadmium  from  landspread  solid waste  into  the  food chain,  two
approaches  have  been developed for the  management  of  this  toxic
metal.    The   first   approach,   referred   to   as  "operational
controls,"   involves   the    following    four   site   management
requirements which will minimize the uptake of cadmium:   (1) con-
trolling  the  annual  application of  cadmium  from  solid  waste  to
the following  levels:

                                    EPA-Proposed Maximum
              Years                  Annual Cd Addition
                                          (kg/ha)
          Present-Dec. 31, 1981            2.0
          Jan.  1, 1982-Dec.  31, 1985       1.25
          Beginning Jan. 1,  1986           0.5


  (2)  restricting  the cumulative amount  of cadmium  applied  to  a
hectare  of  land  {based  on  soil  cation  exchange  capacity)  to
5 kilograms  on  soils  with  a  Cation  Exchange Capacity  (CEC)  of
less than 5, 10 kilograms on soils whose CEC is between 5 and 15,
and 20  kilograms  on  soils whose CEC exceeds  15;  (3) banning thr-
application  of   solid  waste  containing   more  than  25  mg/kg  dry
weight  at  si tes  where  tobacco,  1eafy  vegetables,  or  root  crops
are ฃฃ  wi 11 b_e_  grown for di rect human consumption; and (4)  main-
taining the  pH of soils and  solid waste containing cadmium at 6.5
or above.

     The  second  approach,  referred  to  as "crop  monitoring,"  is
specifically designed  for  facilities  which are  closely  managed
and monitored.   It  allows  for the comparison  of  crops or  meats
produced  from  solid  waste  amended  soils with similar  crops  or
meats  produced  locally where  solid  waste has not  been applied.
This  approach   provides  flexibility  to  those  facilities  which
possess  the  necessary  resources  and  expertise   to  intensively

                              111-69

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     The "operational  controls"  approach to controlling  cadmium
levels specifies reducing annual  and cumulative  cadmium  additions
in a  phased  manner,  thereby providing initial  protection  to  the
human  diet,   and  greater   protection   in   the  ensuing   years.
Beginning in  January  1986,  maximum annual  cadmium  addition  will
be limited  to 0.5 kg/ha,  a  restriction which may force  some sites
to discontinue 1andspreading and  require  other  sites to  implement
industrial  waste  pretreatment  programs  to  reduce  cadmium  levels
to  acceptable  limits.   A  phased  approach  to  reducing  cadmium
additions will  give  communities  and  industry   time  to  implement
such  programs  as source control  and  industrial  pretreatment  of
discharges.    (The  economic   impacts on communities  are  discussed
below) .

     Prohibiting the  application  of  solid  waste  containing  more
than 25  mg/kg cadmium at sites where tobacco, leafy vegetables or
root  crops will  be  grown,  further  limits  the  amount  of  cadmium
entering accumulator   crops,  thereby   protecting  public  health.
By  prohibiting   the   cultivation  of  these  crops,   a  high  risk
practice is  eliminated because  their  consumption  would  result in
the ingestion of rather high concentrations of  the metal.

     Maintaining the  pH  at  or  above  a  level of  6.5 through  the
application  of   lime  limits  the  uptake  of cadmium by  plants,
thereby   protecting food  chain crops  and  lessening  the  threat of
plant toxicity  from  most metals.    Since  cadmium  is less  soluble
in neutral  to alkaline soils, such a control method also  limits
the leachinn  of cadmium into the ground water.
                              111-70

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     The  second  approach  "crop  monitoring"  recognizes  the  fact
that  a  wide  variety  of site-specific conditions  and  management
variables can affect the level of cadmium entering crops.  Rather
than relying on operational criteria, this approach establishes a
minimum  level  of  performance based  on a  comparison  with cadmium
levels  of  the same crop species or  meats  produced locally where
solid wastes have not been applied.

          (2)  Pathogens

               This  criterion requires  solid wastes  of concern
due to  their  pathogen  content to be stabilized prior to applica-
tion  on the  surface  of  the  land.   In   addition,  the criterion
contains  a  specific  restriction  related  to  the  application  of
solid wastes  to  land  used  for human food crops that are normally
eaten raw.   This  restriction  states that solid waste (stabilized
and unstabilized),  having  a  potentially  harmful  pathogen content
is  not  to be  used  for  the production of  such food  crops  for at
least   one  year  following   application,  or  longer;   the  only
exception to this limitation  is a crop which does not contact the
solid waste during  its  growth.

     Pathogenic organisms  present  in sludge are  either killed or
greatly  reduced  in number when  exposed  to various stabilization
methods.   The specific  number  of  a  given  organism  creating the
potential for  disease   is  related  to various  factors.   There is
evidence  that  with many pathogens this  dose  may  be  rather high,
as  is   the  case  with  the  enteric  pathogens.   This  supports  the
premise  that  by  reducing  the number of   pathogenic  organisms  in
sludge,  the  public health hazards  associated  with  its use would
be  greatly  minimized.   The criterion establishing a year's delay
in  growing  food  crops  to be eaten raw   on  sludge-amended soils
would  lessen  the  risk  of  disease  transmission,  since  the  avail-
a b 'I j  data  indicate  that  there  is  only  a  remote  probability  of
encountering numerous viable  pathogenic organisms after one year.
                              111-71

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          (3)   Pesticides an^ Persistent Organics

               The  proposed  criterion  calls  for preventing  the
application  of  solid  waste containing  pesticides  and  persistent
organics on  land  that  is  currently  or will  in the future be used
for the  production of  food chain  crops which  would  result  in
pesticide or persistent organic residues in  or on crops in excess
of the  tolerances  set  pursuant to  section  408  of the  Federal
Food,   Drug  and  Cosmetic  Act,  or  persistent  organic  level  in
excess of those established by  FDA  (21CRR Part 109).

     The proposed  criterion would  protect  the  food  chain  from
unacceptable  levels  of   pesticides  and  persistent organics  by
controlling   residuals  in  or   on  food  products  with  existing
regulat ions.

          (4)   Direct  Ingestion

               The  proposed  direct  ingestion  criterion  requires
solid  waste of  concern  due to  its   pathogen,  toxic  organic  or
heavy metal  content not  to be  applied to a site  so that freshly
applied  solid  waste may  be  directly  ingested  by  animals raised
for milk or  by humans.

     The proposed  regulation  would  protect  humans,  as   well  as
animals  raised  for milk,  from  potentially  adverse  effects stem-
ming  from solid  waste which have unacceptable concentrations  of
pathogens,  toxic organics, or heavy  metals.

     b.   More Restrictive Alternative

     In  EPA's  judgment,  consideration  of  two  more  restrictive
alternatives to  the proposed criterion  is  warranted:   the first
calls  for   immediately  imposing  a  limit  of  0.5  kg/ha  nt ,imum
annual  cadmium  addition;  the second  is  a more stringent regula-
tory  approach — banning the  application  of  solid  waste  to land

                             111-72

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jsed for growing food chain crops, forage,  or tobacco.

          (1)   A1ternative 1

               Immediately restricting the  maximum annual  cadmium
addition  to   0.5 kg/ha   (0.45  Ib/acre)   is  not  expected   to
contribute  significant  additional  protection of  public  health
over that offered  by the  proposed  criterion.   This judgment  is
based on evidence  that  cadmium  is a long-term cumulative problem
in  the  human  diet,  as well  as  on  the  fact  that  the  phased
approach calls  for reducing permissible annual  cadmium  addition
to the  0.5  kg/ha  (0.45  Ib/acre)  level  by  1986.  Therefore,  it  is
assumed that  the  long  term public  health  impact  of  this  more
restrictive  alternative will not be  significantly  different from
the health impact of the proposed regulation.

     Furthermore,   a  negative   economics   impact  of   this   more
restrictive  alternative would be the elimination  of 1andspreading
as a disposal  option for communities with  large industrial  sludge
flows.    The  proposed  regulation,  on  the  other  hand,   reduces
cadmium additions   to  the  0.5  kg/ha  (0.45  Ib/acre)  level  in  a
short time period, yet it gives communities time  to improve  solid
waste quality by  implementing  such  technologies  as pretreatment.
A  more  detailed  assessment  of  the   impact of  the   0.5  kg/ha
(0.45 Ib/acre)  annual  cadmium  addition  on  current  1andspreadinq
practices  is presented in Appendix IV(E).

          (2)   Alternative 2

               Maximum protection for humans  and  livestock  would
be  achieved  by  banning  the application of  solid waste  to  land
used  for  growing   food  chain  crops,  forage,  or  tobacco.  The
expected result  would be reduced cadmium loading  in some  areas  of
the  country,  and  reduced  uptake of  pathogens,  pesticides,  and
persistent  organics.    However,  such  an alternative is  unneces-
sarily   restrictive,  and  in  some areas of  the country,   such  as
                             MI-73

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Illinois,  it would have  a  severe  impact on  current  land  disposal
practices.

     In certain parts of  the  country,  landspreading  is  the  least
expensive  mode  of  disposing of sludge;  incineration  is  prohibi-
tively expensive and  landfill  capacities are limited.

     c.   Less Restrictive Alternative

          A less restrictive alternative  to  the  proposed regula-
tions governing the  use  of  sludge  on productive  land  would  be  to
permit  unlimited  application   regardless  of the  toxic  chemicals
and  pathogens  contained  in   the  waste.    Such  an  alternative
obviously   is  undesirable since  it  fails  to protect food  chain
crops  from  contamination by  harmful  sludges  and hence  poses  a
threat to public health.

3.   Summary Technology, Economic,  and Environmental
     Impact Analysis

     a.   Technology

          Land  used  for  the  protection  of  food chain  crops  is
protected   from  the   adverse   effects  of   cadmium,   pathogens,
persistent organics and direct ingestion of  solid wastes by  dairy
animals and humans  by  the controls  outlined  in the  food  chain
crop criterion.  These  controls  are achieved through proper site
selection, design,  and operational  techniques.   The food chain is
protected from cadmium by:

          controlling the annual application of  cadmium to  land;
          restricting the cumulative amount  of  cadmium applied to
          land; banning the application of solid waste cor'--.ninq
          more  than  25  mg/kg  dry  weight  at  sites where tooacco,
          leafy  vegetables,  or rodt crops  are  or will  be  grown
          for  direct human  consumption; maintaining  the  pH  of

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          soil  and solid waste at 6.5 or above.
          comparing  crop  or  meats  produced from  solid  waste-
          amended  soils  with similar  crops or  meats  produced
          locally where  solid waste has  not been applied.   The
          marketed product must have cadmium concentrations which
          are comparable to similar crops raised locally.

     The  food  chain  is  protected  from  certain wastes posing  a
threat to public health due to their pathogen content  by:

          requiring  stabilization  if   such  wastes  are  applied
          directly to the land's  surface.
          crops normally eaten raw  may  not be grown  for at least
          one year following the  application of  such  wastes.

     The  food  chain  is  protected  from  solid  wastes  containing
pesticides and persistent organics by:

          requiring that any food and animal feeds grown on solid
          waste-amended  soils  meet  all  applicable  food  quality
          regulations.

     The  food  chain  and  humans  are protected  from  direct  in-
gestion of certain solid wastes by:

          requiring  these  wastes  be   managed  to  avoid  direct
          consumption of  freshly  applied  solid waste  by  animals
          raised for milk or by humans.

     b.   As sumptions

          Since there is insufficient data on exact  quantities of
soli^.  waste  that  is  spread  on  food  chain   croplands,  cost
estimates were  based  only on the application of  municipal  waste
treatment sludges.  However,  the  following industrial  groups  are
known to  currently  landspread  (though  not all  on  food chain  crop

                              111-75

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lands):    Pharmaceuticals,  food processors,  feedlots,  tanneries,
textile    mills,   petroleum   refineries,   and  pulp   and   paper
f a c i 1 i t i e s .

     Economic  consideration   of   impacts   resulting   from   the
pathogens, pesticides, persistent  organics,  and  direct ingest ion
subsections   of  this  criterion  were  n o t  addressed  because  their
impact  was considered  to  be  minimal.   Essentially,  each of these
concerns   will  require  that  municipal  waste  treatment   plant.
operators be aware of the chemical and biological  characteristics
of their  sludge.    If  the  potential   for  adverse  effects  exists,
operators must  prohibit  the  application  of  that sludge to  land
used  for food   chain crops.    Since  surface impoundments  and
landfill  operations will  not be affected by this criterion, their
economic  impact  was not analyzed.

     This assessment  is   based  on the  best   available  data  from
141 cities.    (Ref. 126)    Fifty-nine  of  these  cities  currently
landspread sludge; fifty-eight of these are anticipated to  select
the "operational controls" approach.   These cities spread 490 dry
metric tons  per day  of  waste treatment  sludge  on  land used for
the production of food chain crops.  The represents  approximately
20% of the  total  2,700 dry metric tons per day landspread  in the
U.S.

     The   City of  Chicago  is the  fifty-ninth city.   Chicago is
expected   to  select  the "crop monitoring"  alternative rather than
the four  site operational  controls.   The amount of  sludge  spread
by Chicago  represents 7% of  the  total  2,700 dry- metric tons .er
day landspread.

     The   costs  in  the EIS  were  based on  operational  costs  to
comply  with  controls and  costs  to  communities   where  f,    nt
practices would be terminated.  At sites where 1 andspreading will
be  terminated  because  of  the  maximum  annual  cadmium addition
control,   the sludge  was  assumed  to  be landfilled.   Land costs
                              111-76

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"operational   controls"  approach  since  they  generally  do  not
purchase  or  lease  agricultural  land.     While  there  may  be
additional land  costs  for those  communities  selecting  the  "crop
monitoring"  alternative,  land  costs  could  not  be  estimated
because  the   amount  of   land  necessary  is  dependent  on  site-
specific   variables   such   as   sludge  volume,   quality,   crop
selection, soil  type, etc.

     Three   regulatory   options  were   addressed — the   proposed
criterion  and  two more  restrictive  alternatives.    Although  the
environmental impact of a less restrictive alternative was evalu-
ated, there is no cost associated with this regulatory option and
therefore  this   option  is  not   discussed  in  the  cost  analysis
section.

     The  cadmium  criterion  differs  from  the others in respect to
its  time-phased  nature--a  1.25  kg/ha  (1.13 Ib/acre)  restriction
in the third year; a 0.5 kg/ha (0.45 Ib/acre) limit beginning the
eighth year  following  promulgation (1986).   Costs  were based on
data  documenting  concentrations of  cadmium  and  quantities  of
sludge landspread in 141 cities.  (Ref. 126).

     For  the  proposed  criterion,  sludge  quantities  which  could
not  be  landspread  (as  a  result of the regulation)  and consequent
costs were based upon the time-phased nature of the criterion and
on   an  assumption  that  upon  implementation  of  the  .5  kg/ha
restriction  in  1986,   half  of  the  municipalities  would  have
pretreatment programs reducing Cd levels to acceptable concentra-
tions.

     It  was  assumed  that  10 metric  tons  per  hectare per  year
(mt/ha/yr) would be near the lower end of the economically viable
range of  application rates.   Based on this, communities that had
tu reduce application rates below 10 mt/ha/yr to meet the maximur
annual  cadmium  addition  were  assumed to  require  termination of
1 andspreadi ng practices  on  food chain land.   Costs  for the more
                           111-77

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     restrictive  alternative  were  based upon  a  total  restriction  of
     sludge  applied  to  any  agricultural  land.   All  costs  were  based  on
     data   obtained   from  a  study  of  1andspreading   practices   in
     58  cities  (Ref. 126).    These  costs  were  then  extrapolated  to
     national  projections.

          Costs

          For  the proposed regulation,  the estimated national  cost  of
     the operational  controls alternative is  $12.3 million  per  year
     through 1981,  $16.3 million  per  year  from  1982   to  1985,  arid
     $14.1  million  per year from 1986.    The  one  city in  the data  base
     that   was   assumed  to  select   the  monitoring alternative  was
     Chicago.    At  the  present  time the  increased operating cost  to
     Chicago's  Fulton  County  site was assumed  to be negligible  due  to
     the extensive  monitoring  they already  conduct.    If  for  some
     reason   Chicago   could  not  meet  the  comparable   criteria,  the
     additional   cost  to landfill,  incinerate,   or  end   production  of
     food   chain   crops  would  be   significant.    The   national  cost
     projection   includes   only  the   operational  controls  alternative
     costs.   Due to the  interim  nature  of  the  cost figures throughout
     the various stages  of phasing, the national  cost  projection was
     based on  the annualized cost in 1986 of  $14.1  million.*

          For   the  first  more  restrictive   alternative   (implement
     0.5 kg/ha  now),  the   national  annual ized  cost is  $20.9  million.
     This  alternative   would  cost an average  of  $5.7 million  per  year
     more  than the  proposed  criterion  until   1986, when the  controls
     become  the  same.
 Total  tonnage applied to agricultural  land from  data  on  the  58  Cities
amounted to approximately 20% of the estimated sludge  spread  on
agricultural  land.   Therefore,  total costs were multiplied by a  factor
of 5 to derive a projected national  cost.
                                    II1-78

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     For  the  second  more  restrictive  alternative  (ban on  food
chain crops),  the national  annualized cost is $70.4 million.   The
additional  cost  of  this  alternative  is  $56.2 million  per  year
more than the  proposed criterion.

     Table 22 compares  annualized  costs based on disposal  method
and  regulatory  alternative.    The  cost for  the  most  restrictive
alternative was  assumed to be  all  Federally  induced  because  no
States are currently  expected  to ban all  solid waste  application
to  food  chain  land.   Unit costs, the  data  base,  and  methodology
for these analyses are presented in greater detail in  Appendix V.

     d.   Economic and Environmental Comparisons Among
          AJ ternatives

          Table   23   shows   the   economic    and   environmental
comparisons among alternatives for this criterion.

     Comparing   economic   considerations   with   environmental
benefits   indicates   that   even   though   a   more   restrictive
alternative is only $6.8 million per year more than the proposed,
the  overall   public  health  and   environmental  benefits are  not
significant enough   to  warrant  the  increased  costs.    The  most
restrictive   alternative   is   $56.3 million   greater   than   the
proposed  alternative.      Such  an  alternative  is  unnecessarily
restrictive based  on  current  data  and  would  tend  to  produce
severe economic impacts on many small communities.

     Finally,  the proposed  alternative  is  $14.1 million per  year
greater  than  the  less  restrictive  alternative.   However,  the
threat to  public  health which would result  from  the  adoption  of
the  less  restrictive alternative provides a  strong argument  and
justification  for adoption of the proposed regulation.
                              IN-79

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-------
 F.   DISEASE VECTORS

1.    Importance;  Adverse Effects from Improper Pisposal

     One of the major health problems of open dumps has  been that
they provide food and harborage (shelter and breeding) for common
disease vectors  such  as rats,  other rodents, flies, and birds.
In  addition,   surface  impoundments  can  often breed  mosquitoes,
with attendant disease problems.

     Rats  are responsible for the spread of a number of  diseases,
either  by   contaminating  food  directly,   rat  bites,  or  through
flies,  and mites.    The  more  common  diseases include  rat-bite
fever, '1 eptospi ros i s  (a mild  to  severe  infection);  trichinosis
(an  infection  of the intestine  and  muscles), and  murine typhus
fever.

     Flies  and birds  pose  less of a threat  to human  health than
do rats; nevertheless, they do act as mechanical  carriers of such
diseases  as  salmonel1osis   or   food  poisoning.     Mosquitos  may
transmit  such  diseases  as  encephalitis,  malaria,  and  yellow
fever.

     Since  sewage   sludge  may  contain  pathogenic  organisms,  its
improper  disposal   on  land  may  pose  a  threat to  public  health.
Industrial  sludges  may  also  carry a large  microbial  population
(generally  other  than human  pathogens)  capable of affecting the
environment.
                              111-82

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 2.   Regulatory Approach and Environmental  Consequences

     a.    Proposed Criterion

          This  criterion   requires  that  the  disposal  facility
protect  the  public  health  from  disease  vectors.    This may  be
achieved by minimizing the availability of  food and harborage for
disease  vectors  such as rats, flies,  mosquitoes,  and  birds.   At
landfills, an  effective means  to  control  vectors,  especially the
rodents  which  are of particular  concern,  is  the  application  of
cover material   at  the  end  of  each   day  of  operation.   Other
techniques  include  poisons,   repellants,  and  natural  controls
(e.g. , predators ) .

     "Periodic application  of  cover material"  is  defined as "the
application  of  soil  or  other suitable  material   over  disposed
solid waste at such frequencies and in such a manner as to impede
vectors   and   infiltration  of  precipitation;  reduce and  contain
odors,  fires,  and litter; and  to  enhance  the  facility's appear-
ance and  future  utilization"  (Ref.  30).   In  general, the results
can  be  achieved  by  covering  at the end of  each day the  site  is
open to receive  wastes.   In remote areas,  on days  when sites are
not  open,  storage bins may be  provided  for  temporary  storage  of
wastes.

     Landsprcading  of stabilized  and  composted wastes,  surface
impoundments,  and certain  relatively  inert  wastes  such  as  con-
struction, demolition,  and  land-clearing  debris generally do not
require  cover material because the wastes arc nonputrescible, are
relatively stable  and inert,  or  are  impractical to  cover.   Some
disposal  facilities,  because  of  their location or  because  they
use  other  moans  of  control,  will   not  need  periodic  cover.
Because   of those  exceptions,  the proposed  regulations  call  for
periodic application  of cover material "where appropriate."
                              I 11 - 8 3

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     The  proposed  criterion  is  expected  to  control   disease
vectors at  improperly  regulated landfills,  1andspreading  sites,
and impoundments.   The  choice  of a general criterion for disease
vectors rather  than  specific  operational  standards  permits local
choice  of  cost-effective  measures   for   landfills  and,  enables
impoundment   operators   to   make  the   necessary   site-specific
determinations.

     Current  practices   in   landfill inn  will  not  be  measurably
affected  by  the  criterion,  since   all   States  require  vector
control.   Increased  supervision  of application would probably be
required  at  many  1 andspreading  sites to comply with the proposed
regulation.   In  summary,  this  criterion  protects  public  health
from disease  vectors by use of best control technologies.

     No lesser  or more  restrictive  alternatives  were considered
practical  by  the EPA.

3.   Summary  Technology, Economic,and Environmental  Impact
     Analysi s

     a.   Technology

          Disease vectors include rats, flies, and mosquitos; the
most  effective  method   of   controlling  vectors  is   to  minimize
harborage  and  readily  available  foodstock,  thereby  creating an
inhospitable  h,abitat.

     Proper  and adequate  control  of  rodents and insects requires
a well  operated and maintained landfill.   Rat and fly control can
be  achieved  by  maximum  compaction  of the  refuse and placement of
an  adequately compacted soil cover  at  the end  of  each operating
day.
                               111-84

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     Mosquito control is best  obtained  by  preventing developnฐnt
of  stagnant  water  bodies  anywhere  on  the  site.    Certain  fish
thrive   on   mosquito  larvae   and  are   effective   in   aerobic
impoundments.

     Landspread wastes which  could  provide  surface  harborage  or
food stock should be ground or chipped and  then spread,  disced  or
otherwise  turned  into the  ground  as  part  of  the  routine  site
operation procedures.

     The use of  rodenticides,  insecticides,  and other pesticides
may  also  be  used   but  are  less  preferable  to  preventing  or
minimizing food  and  harborage  by  cover  soil  or other means.   The
technology used to calculate a cost for  the proposed  criterion  is
application of a daily soil cover where  appropriate to prevent  or
minimize food and harborage for disease  vectors.  This technology
is based upon what EPA considers to be proven and tested methods.
Although  regional  solutions  may vary,  cover  represents  the  oest
available approach for a  nationwide assessment of costs.

     b .    Assunption__s

          The  major  economic  impact of  this  criterion  results
from  the  need  to  prevent or  minimize food  and  harborage  for
vectors  such as rodents or insects.  Only one regulatory alterna-
tive was considered practical --the proposed criterion.

     Since economic impacts of this criterion on surface impound-
ments and Ian d spreading  operations  are   considered  neglioible,
only landfills were assessed.

     c.    Costs

          The  application  of  a  daily  cover  soil  is  the  best
available technology for  minimizing disease vectors.   An analysis
of  Stdto  solid  waste  rules   and  roqu1dti ons  reveals  that  all
                              I I I-8b

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States require periodic application of cover material  at landfill
sites.   Since permitted  and  authorized landfills  already  apply
cover  material,  these  costs   are  assigned  only  to those  sites
requiring closure arid are, therefore,  counted in closure costs to
avoid  double  counting  of  costs.    Table  6  in  Chapter I  shows
closure  costs  for  the  proposed,  more  restrictive   and   less
restrictive alternatives.

     While it is true  that  some  State-standard-induced costs for
cover  can  be  expected  to  be  incurred,  these are  expected  to be
negligible since  only small, remote facilities and roadside  dumps
will be affected.

 G.  SAFETY
1.    Explosive and Asphyxiating Gases

     a.    Importance; Adverse Effects From Improper Disposal

          Solid  waste  disposal   sites  may  contain  or  produce
explosive, toxic, or  asphyxiating, gases  which  may accumulate  on-
site or migrate off-site.   Products of solid waste decomposition,
oxidation,   volatilization,   sublimation,   or   evaporation   may
include  gases  such  as  methane  and  hydrogen  (explosive  and
asphyxiating), carbon monoxide and  carbon  dioxide (asphyxiating)
and chlorine  (toxic).   Presence  of any  of  these or similar gases
at   a   disposal  site,  in  sufficient  concentration,  can  pose  a
serious threat  to the  health  and welfare  of  site  employees  and
users,   and   occupants   of   nearby  structures.     Explosions,
asphyxiations, and  poisonings  resulting  in  injury and death have
resulted from disposal site gases.  In addition, property damage,
ground-water  contamination, and  vegetation  kills  (on-site and on
adjacent lands) have  been  attributed  to  gases  generated by solid
waste disposal.
                              111-86

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     In 1969, seepage of  gas  from a landfill  caused an explosion
in a National Guard  Armory  in Winston-Salem,  North  Carolina that
took the lives of three  men and seriously injured two others.   In
1975, buildings at two  separate  fills  in Michigan suffered frame
damage  due  to methane  explosions,  and  in Vancouver,  Canada,  a
newly-poured  foundation  slab  was  structurally  destroyed  by  an
explosion initiated  by  a cigarette  in  the air  space  underslab.
The  list  of  similar incidents continues  to  lengthen  annually,
dramatically  illustrating the  hazards   posed  by gas  migration.
(Ref. 117).

     Although methane gas generated in landfills can be explosive
in  fairly  low concentrations  when mixed with  oxygen,  potential
problems can be readily  averted by venting the gas.   In addition,
there  is  a   beneficial  side  to  methane  control  that  should  be
noted:  the  gas has commercial value as  an energy source if it is
cleaned.    Currently,   there   are   several  new  production-scale
projects underway to recover and sell the gas.

     b.   Regulatory Approach and Environmental Consequences

     (1)  Proposed Criterion

          Explosive Gases.  This   criterion   requires   that  the
concentrations   of   explosive   gases   in   facility   structures
(excluding gas control  or recovery system components) and in the
soil  at the  facility  property  boundary  rema i n  helow  the lower
explosive limits  for the  gases.  Implementation of this criterion
will protect  the  public  and  the environment from the potentially
hazardous effects  of explosive  gases.    The  development  of  gas
recovery facilities  should  not be  impeded  by the  explosive  gas
criterion.

     Toxic or Asphyxiating Gases.    To protect  the public  safety,
the criterion calls for  preventing the off-site migration  of gas,
and the accumulation of  gas in facility  structures (excluding gas

                              111-87

-------
control   or  recovery  components)  j_n_  concentrations  harmful  _to_
human ,  animal,  or plant  1 I fe.

     No   lesser  or  more   restrictive  alternatives   for  the  gas
criterion were  considered  practical by EPA.

2.         Fires
     a.   Importance; Adverse Effects From Improper Disposal

          Fires at solid waste  disposal  sites  pose a significant
hazard to public safety and environmental quality.   Death,  injury
and property damage have resulted from fires breaking out in open
dumps.

     Circumstances other than  intentional  burning  which may lead
to fires  at  a  disposal  site include:   vandalism,  carelessness,
spontaneous  combustion,   and   disposal   of  solid  waste  still
undergoing  combustion  (ashes).    Any  fire   at   a  solid  waste
disposal  site  poses  a  threat  of  property damage and  injury  or
death  to site  employees,  users,  and nearby  residents.   Under-
ground  fires   may  become  very  difficult  to  extinguish  if  not
attended  immediately.   A  fire  which began in  a  40-acre site  in
Wisconsin  late  in  1968   took   almost  6  months   to  extinguish.
Expenditures of hundreds of  thousands of dollars  were needed for
manpower and equipment used to fight the blaze.  (Ref. 79,  p.37).
     b.   Regulatory Approach and Environmental Consequences

          To  minimize  the   hazards  associated  with   fires,  the
criterion  calls  for  extinguishing  all fires  expeditiously,  and
implementing  proper  site  construction,   design  and  operation
practices.    Such  practices  include  monitoring  waste received,
applying  cover   material  or  other  suitable  means  to  limit  the
exposure  of  flammable  material,   and  providing  fire  fighting

                              111-88

-------
equipment to promptly extinguish such fires.

     The  fire-safety  criterion   supplements   the   air  quality
criterion  banning  open  burning  by  minimizing  the  chances  for
accidential fires,  thereby protecting public safety and property.

     No  lesser or  more  restrictive alternatives  for the  fire
criterion were considered practical.

     3.   Bird Hazards To Aircraft
     a.   Importance; Adverse Effects From Improper Disposal

          Solid waste disposal sites may attract large numbers of
birds  that  feed  on  the  fresh refuse and rest, preen and strut on
areas  of  open,  relatively  flat  land  frequently  found  near  the
sites.   The  gathering  of  flocks  not  only  creates  a  potential
nuisance  and  health  hazard,  but  may  pose  a  safety  hazard
(collision threat) to low-flying aircraft if the disposal site is
located in  the  proximity  of an airport (See Refs.  80-84).  Since
the  juxtaposition of airports  and disposal  sites  is relatively
common, particularly in coastal states, such a safety hazard must
be taken  seriously.   In  the San Francisco Bay area, for example,
over   thirty  solid  waste  disposal   sites   are  located  in  the
vicinity of seven major and thirteen smaller airports.  Two large
landfills are adjacent to the J.F. Kennedy Airport  in New York.

     In an effort to alleviate this problem, the Federal Aviation
Administration  (FAA)  issued  an  order in 1974 giving guidance for
evaluating  the  feasibility  of  locating   landfills  within  the
proximity of airports.  The FAA guidance suggested  that landfills
falling into  any  of  these various proximity categories should be
closed  "within a  reasonable time"  (Ref. 84).
                              111-89

-------
       b.  Regulatory Approach and Environmental  Consequences

     (1)  Proposed Criterion

          This criterion incorporates the restrictions on airport
location contained in the 1974 FAA order, by requiring that solid
waste  disposal  facilities  be  located  a specified  distance away
from airports  in  cases  where  bird hazard  to  aircraft  exists.
Disposal  facilities  receiving  putrescible  wastes  that  attract
birds  may  not be  located (1) within 3048  meters  (10,000  ft.)  of
any  runway  used or  planned  to  be  used  by  turbojet aircraft,  or
(2) within  1524 meters  (5,000 ft.)  of  any  runway used or planned
to be  used  only by piston-type  aircraft, unless i_t J[_s de termined
that  the   disposal   _f 3C i 1 i ty  does  n_o_t  pose  a_  bird  hazard  to_
aircraft.

     Disposal  facilities  outside of these  distances, but within
conical takeoff/Ianding  surfaces (specified  in  Federal  Aviation
Regulation  Part 77)  are to  be  reviewed on  a  case-by-case basis
for potential bird hazard.

     This  criterion  protects  aircraft  only  when  potential  bird
hazard   exists  within certain  prescribed distances  of an airport.
If a bird hazard exists, compliance may be  achieved by closing or
modifying either the disposal facility  or the airport.

     (2)  More  Restrictive Alternative

          A more  restrictive  alternative would  be  the banning of
al 1  disposal  facilities  within  the distances  specified  in  the
proposed  alternative  (including those  within  the  conical  air
spaces).   Although  such an  approach  might  reduce  the  risk  of
potential   bird  hazard  to aircraft,  it  may  eliminate  the use of a
site with minimal   or no  bird  problems and result, in the selection
of less desirable  alternative sites.
                              I 11-90

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     (3)  Less Restrictive Alternatlve

          A  less  restrictive  approach  would  be  to  have  no
criterion governing bird hazard to aircraft.  Such an unregulated
approach  would   undoubtedly  contribute  to  increased  numbers  of
incidents involving collision of birds with aircraft, with atten-
dant  threats  to  public  safety  and  property.    Such  a  lax
alternative was  therefore considered unacceptable by EPA.

4.   Access
     a.   Importance; Adverse Effects From Improper Disposal.

          Solid  waste  disposal   facilities   and  operations  can
cause  injury  or  death  to  persons  at  the  site; the  sources  of
hazards are often easy tq control and include:
               (a)  operation   of   heavy   equipment   and   haul
                    veh i cles;
               (b)  exposure  to   waste  including  sharp  objects,
                    pathogens, and toxic,  explosive, or flammable
                    materials;
               (c)  accidental or intentional fires;
               (d)  excavations and earth-moving activities.

       Control  of  access to disposal  sites or unsafe portions  of
sites  is  considered  vitally  important to  ensuring  the  public
safety.

     (1 )   Proposed C r i t_e_r i oji^

          The proposed  criterion calls for  controlling  entry  to
disposal  facilities, thereby minimizing exposure of the public  to
hazards of  heavy  equipment  operation,  construction,  and exposed
waste.    Professionals  in  waste  management   agree  that  the most
effective means of minimizing the risk of injury to the public  is
by prohibiting  access  to the  site  by  non-users  and by strictly
                              111-91

-------
controlling the activities of users on-site.   For persons wishinn
to  dispose  of  small   amounts   of  wastes,  storage  or  special
disposal  facilities are recommended.

     No  lesser  or more  restrictive  alternatives for  the  access
criterion were considered practical.

 5.  Summary Technology, Economic,  and Environmental  Analysis

a.   Tec hnology

          The  technology  needed to control  safety  hazards  is  a
function   of waste  characteristics,   disposal  site  environment,
safety hazard,  and  population  activity and  physical  proximity.
The safety  criterion addresses  explosive  and toxic  gases,  fires,
bird hazards to aircraft, and access.

     (1)   Explosive and Toxic Gases

          Gases generated  within landfills  will  migrate through
the  cover  soil,   base,  and  side  walls.    Many   above-ground
landfills and those below-ground landfills in an impermeable soil
or  rock  environment  will require  no  special  lateral  gas control
features.   On  the other hand, a gas  control  system  such as vents
or barriers must be provided where refuse extends below-ground in
landfills  with  permeable  side  walls   or  base.   Lateral  control
features   must  also be   provided  where utility or other man-made
features   of a  permeable  nature penetrate the  refuse  perimeter1.
Such  facilities  could  otherwise serve  as  gas  conveyors and thus
foster a  hazard condition.

     Certain climatic  effects may  reduce  the permeability of the
soil,   thus  restricting  the  passage   of  gas  through   the  cover
resulting in lateral  gas migration and potential  gas hazard.  For
example,   sufficient  rain or  frost will  render  any  type of soil
less permeable, encouraging the lateral migration of the n a s.  In
                              111-92

-------
addition  to  decreasing the  permeability  of surface  soils,  rain
water  or   snow  melt  may   infiltrate  the  refuse;  the  resulting
increase   in   moisture   may   stimulate    the   rate   of   waste
decomposition and  gas  production.   This combination of decreased
permeability of  the  cover  and increased 9as production may cause
a significant increase in lateral migration of the gas during the
rainy  season.   On the other  hand,  the  low temperature snow-melt
water may reduce gas generation by slowing microbial  metabolism.

     Methods of controlling landfill gas migration include one or
a combination of the following:

     1.   Placement  of impervious  liner  materials  to  block  the
          subsurface   flow  of  gas  to   adjacent   lands  or  into
          buildings.
     2,   Selective  placement  of  granular  materials  for  gas
          venting  and/or collection.
     3.   Atmospheric  or  pumped  wells  for evacuation and venting
          of gas from  the landfill itself.

     After  the  wastes  have   been  1 a n d f i 1 1 e d  it  is  difficult to
install  barriers  and,  therefore,  venting  or  evacuation  systems
must be  used.   A  combination  of  venting  trenches and extraction
wells  were  considered  in  developing   costs   for   the  proposed
criterion.   Although  regional  solutions  may  vary, these  techno-
logies  represent  the  best  available  approach  for  a  nationwide
assessment of costs.

     ( 2 )  Bird Hazard:, to Aircraft

          The  principal   method  controlling  birds  is  to  reduce
their food source  by covering  the wastes a  so 01 as possible after
disposal.   A  s i to- s ijec i fi c  study  to  determine  whether  a  bird
hazard  to  aircraft  exists   will  be   needed  for each  disposal
facility  which  received  putrcscible wastes  and  which  is  located
within  the  limits  pr r-^c r i bc>a  in the criterion.  The cost of this
                              I I I - 9 3

-------
study has been  used  to  assess  the initial  cost of the criterion.
If  a  bird   hazard   is  found  to  exist,   then  additional  cover
material  or  bird  repellants  to reduce the bird population,  or  a
change in aircraft pattern will be necessary,  and  at the extreme,
disposal   site   or  airport  closure  may  be   needed.    The  more
restrictive alternative calls for banning  waste disposal at sites
located  a  specific  distance  from airports;  this  would  require
hauling wastes  to  an  alternative  disposal  location and opening  a
new site  if one doesn't exist.

     (3 )   Fires

          Fires in landfills  can result from  the dumping of a hot
load, sparks from vehicles, spontaneous combustion, or deliberate
ignition.   The  latter  is  prohibited.   Hot loads can be minimized
by  proper   policing  of incoming  trucks;   these  loads  should  be
deposited away  from the working face and immediately extinguished
by  water  or  covered  with soil.   Adequate  daily  soil  cover  is
essential to  smother  any  potential  tire and  to provide a natural
barrier to a fire and prevent it from spreading.  The cost, impact
for  meeting this  criterion  v/as  based  on  the  cost  of providing
additional  water  storage  and  spraying equipment and wetting down
hot  loads.    These  control  methods are  considered by  EPA  to  be
proven and  tested; they represent the best available approach for
a   nationwide   assessment  of  costs.      As  indicated  in  the
discussion  of  the  disease  vectors  criterion,   permitted  and
authorized  landfills  already   apply  cover  material;   hence,  no
additional  costs  for  cover  soil  have been included in the safety
criterion.
                              111-94

-------
          Access

          Fencing  and  trespassing  signs  are  used to  control  or
limit  access  to  the  disposal   site;  permanent  and/or  portable
woven and chain  link fencing is commonly used for these purposes.
Public access to the working face and deposited wastes on-site is
controlled by supervisory  control,  and  directing public users of
the site to specific areas.

     Since   fencing   is   the   best  available   technology   for
controlling access, a nationwide assessment of costs was based on
this control  method.

     b.   Assumptions

          The major  economic  impact of  this  criterion  results
from the  need to  control  toxic,  explosive and asphyxiating gases
at landfills and  to  control  access at surface impoundments.   The
economic  impact  of tin's criterion  upon  landspreading operations
was considered to be minimal.

     For  both  landfills and  surface impoundments,  the  economic
impact of the proposed safety criterion  was determined.  More and
less restrictive  alternatives  were  considered practical  only for
bird  hazard  controls  for  landfills.   For  surface  impoundments,
fencing  was  considered to  be  the best  available  technology  for
access control.    It  was  assumed that to comply with the proposed
access  fencing  would  he  needed at  50!- of  all  impoundments.   The
more  restrictive  alternative   for  the   bird   hazard  alternative
calls  for  banning  waste   disposal  at  sites  located within  a
specified distance from the airports.
                              I I 1-95

-------
     c.    Costs

          Cost estimates  for the  effect  of this  criterion  were
developed based  on  the  above technologies and on  unit  costs  for
each technology,  as a function  of  site size.   Unit costs and  the
data base are  presented in  greater  detail  in Section  IV  and  in
Appendi x V (Volume  II).

     In   summary,  the  proposed  regulation  would  result  in  costs
for landfills ranging  from  $1200 to $15?.7  million per State in  45
States.    For  surface  impoundments, all states would  incur  costs
ranging  from  $6,000 to $4  million per  State.

     Table 24 compares  annualized  costs based  on disposal  method
and regulatory alternative.

     d.    Economic  and Environmental	Compari sons  Anon a
          A1terna ti ves

          Table 25    shows    the   economic   and   environmental
comparisons    among   alternatives  for   the   safety   criterion.
Comparing  the more   restrictive  alternative  with the  proposed
shows that an  additional combined  cost of $24.4  million per year
for  the  more  restrictive alternative  does  not  provide  a  return
over the  proposed  in  terms  of environmental  benefits.  Since the
only  additional   benefit   contributed  by  the  more  restrictive
alternative  is the ban  on  waste disposal   near airports,  the  EPA
concludes that  the  proposed  criterion   is  the  most  reasonable
option.
                              111-96

-------
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 G.   AESTHETIC AND OTHER EK'VTROK.IEN'TAL EFKF.CTS

1.   Importance; Adverse Effects From Improper Disposal

     Aesthetic  and  other  miscellaneous  environmental  effects
associated  with  solid  waste  disposal  sites  are  dust  and  dirt,
litter, noise,  and  odors.   All  of these factors are very dynamic
(constantly  changing)  and  frequently require  daily  operational
responses, most of which are readily  implemented.

     The  travel of  collection  trucks on untreated dirt roads and
operation of  site  equipment  for earth excavation are responsible
for  most  of  the  dust  and  dirt  problems  associated  wi th  land
disposal  operations.    Treating roads,  watering down  dust,  and
cleaning  vehicles  helps reduce  dust  and dirt.   Litter problems
are a  function  of  type of waste (e.g.,  paper and plastics), site
location  (e.g.,  topography),  operation  (e.q.,  use  of  cover
material, fence controls), and  weather conditions (e.g., winds).

     Noise occurs at landfill  sites due  to the passage  of collec-
tion trucks  and  the  operation  of landfill equipment (bulldozers,
scrapers, compactors).   The major  collection  truck  noise occurs
when vehicles  accelerate (e.g., after  crossing  scales) and when
they discharge  their   load on  the  working faco  of a  fill.   The
community  impact   of   noise  at   disposal  facilities  is directly
related  to  the surrounding  1 a n d-us e patterns;  as  exported,  the
impact    is    most   severe   whore   residential    and   s r n s i t. i v e
institutional areas adjoin the  facility.  Noise  at disposal  sites
is  generally   i n t r> riv i t L e n t   rather   than   continuous,  and  the
distance  fro;-1  the  work inn  faoj   (area  of   operation)  to  t;>o
property  lint  is  constantly c nan q inn.   Buffer  /tones  betveen the
operating a r e <"i  d n d surrounding  land  are effective i n  r; i n i m i 2. i n n
noise- and litter -ind may help i  n dust and odor controls.
                              111-09

-------
     Odors  caused  by the  decomposition  of putrer.cible  waste  at
disposal   sites  may  have a decidedly adverse  effect  on  the  imme-
diate  environment.    Cover  material  helps control  odors.    The
occurrence  of   odors  is  a  function  of  the  daily  and  seasonal
conditions at the site.

 2.   Regulatory Alternatives and Environmental Consequences

     a.   Proposed Criterion  •

          EPA  proposes   not   to  address  these  problems in  the
Criteria, since these environmental effects (1) are very dynamic,
(2)  are dependent on Adjacent land use and numerous site-specific
factors,   (3) are  generally temporary,  (4)  pose relatively  minor
degrees  of  cnv iron inert a 1  concern,  and  (5)  are  readily correc-
table.

     E P A's  position  is  that   State  and  local   governments  arc
better  qualified  to  make  site-by-site   determinations  of  the
impact of Iheso parameters and to recommend the necessary correc-
tive  actions.     Also,   as   discussed  in  Chapter II,   there  are
several  Federal  n o i s < •  standards  being  developed applicable  to
mobile solid waste collection and heavy disposal equipment.

     b.   More  Restrictive Alternatives

          The off-site  mi oration of dust, litter, noise and  odors
may  contribute'  to the drter i orati on of a local environment and/or
public inconvenience.

     A more restrictive-  alternative  would   be  to  specify  that
disposal   facilities  rust prevent  or  minimize  noise,  dust,  dirt,
odor, and litter miqration off-site so as to avoid causing damage
or  inconvenience.   Another more restrictive  alternative would be
to  specify operational  criteria for control of aesthetic impacts,
by  requirino  specific   en-site  controls  of dust,  litter,  noise,

                             III-100

-------
and odors.   Such an alternative,  while  preserving  the integrity
of  local  environments,  might  reduce  the  number  of  available,
otherwise  feasible   sites,   be   overly   restrictive   and  thus
unnecessarily  increase  operating  costs,   and  not  reflect  the
myriad  of local  conditions  and  individual  values.   Moreover,
alternative  sites  might   pose   more  serious  health  and  safety
problems.

3.   Summary Technology, Economic, and Environmental Impact
     Analysi s

     a.   Techno!ogy

          The control  methods  to minimize  the adverse impacts of
noise, dust, odor and  litter at  disposal  sites are site-specific.
Noise is controlled by reducing  noise from vehicles and equipment
and by using buffers.  Noise regulations  for nobile equipment are
being  developed  by  EPA.    Dust  and dirt  controlled  by  treating
access roads and providing a water truck  to periodically wet down
temporary  dirt   access   roads   to  the   site.    Odors  can  be
effectively  controlled  by  the  periodic  application  of  cover.
Litter  fences  placed  at  strategic locations  on-site control the
problem of off-site litter.

     These technologies  are based  upon  what  EPA  considers to be
proven and tested methods.  Although regional solutions may vary,
they  represent   the  best   available  approach  for   a  nationwise
assessment of costs.

     b.   Assumptions

          Only the  more restrictive alternative  would result in
an  economic  impact  since  it would  create  a need  to  prevent  or
minimize  noise,  dust,  odor,  and  litter from  off-site migration
that may cause damage  or inconvenience.  The proposed alternative
does  not  result  in  compliance  costs.    The  proposed alternative

                             III-101

-------
was  adopted  because  aesthetic   problems   are   dynamic,   often
temporary, and  readily  correctable;  moreover, aesthetic  effects
are  dependent  on  surrounding  land  use,  numerous  site-specific
factors,  and  minor  degrees  of  environmental concern.   A  less
restrictive alternative does not exist.

     Economic  impacts of  noise  and odor controls were considered
minimal  since  these  are  problems  only when  specific land  use
patterns  exist,  and  since cover material and  buffer  zones  exist
at most landfills.

     Surface  impoundments and  1andspreading  operations will  be
only   minimally  affected  by  this criterion  and,  therefore,  would
have minimal  economic impact.

     c.   Costs

          Cost  estimates  for the  effect  of  this  criterion  were
developed based upon the  above technologies  and on unit costs for
each technology,  as  a  function  of site size.  Unit costs  and the
data base are  presented  in  greater  detail   in  Section IV  and in
Appendix  V (Volume II).

     In  summary,  the  more restrictive  alternative will result in
costs  in  25 States ranging from $5,300 to $285,000 per State; the
remaining  25 States  will  not incur  costs.   Most State standards
were as  stringent as  the more restrictive alternative for litter
control,  while  about  half of the  States had regulations address-
ing dust  control.

     Table 26 compares annualized  costs  based on disposal  method
and regulatory alternative.
                            III-102

-------
     d.   Economic and Environmental Comparisons Among
          A1ternat1ves

          Table 27   shows   the   economic   and   environmental
comparisons  among  alternatives   for  the  aesthetics  criterion.
Comparing  the  more   restrictive  alternative  with  the  proposed
shows  that  an additional cost  of $2.4 million per year  for  the
more  restrictive   alternative  does  offer  some  return over  the
proposed  in  terms of environmental benefits.   However,  the  more
restrictive   alternative   could   be  difficult   and   costly   to
administer  and  enforce   since  aesthetic  problems  are  dynamic,
site-specific,  and  readily  correctable.    EPA  concludes  that
specifying  operational   standards  for  this  criterion would  be
overly  restrictive  and   not  cost  effective  for the  potential
environmental benefit.   State  and local  controls are more appro-
priate for aesthetic problems.
                             III-103

-------
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-------
            IV.   IMPACT EVALUATION OF PROPOSED ACTION
     Chapter  III  addressed each  adverse effect  associated .wi th
improper solid  waste  disposal, discussing  the  merits  of  various
regulatory    alternatives   to   control    each   adverse   effect.
Discussed  in  detail   for  each  adverse  effect were  the  environ-
mental  and  economic consequences  of  the proposed Criteria and of
selected more and less restrictive regulatory alternatives.

     This  chapter  evaluates  the  impact  of  the  proposed Criteria
as  a whole,  identifying  the  major  environmental   benefits  and
costs  on  a  national  basis   and  on  various  cross-sections  or
segments  of  our  society.    Section B  aggregates   the  national
environmental benefits and costs of the proposed Criteria, and of
the  major  regulatory  alternatives.   Section C  examines  each  of
the  three  major disposal  methods  in  terms  of  the  environmental
and  economic effects  of  the  proposed  regulations.   Section D
presents specific cases  of  the economic benefits of the Criteria
from damages that will be avoided.  Section E examines the social
and equity impacts of  the Criteria, i.e., how different groups in
the  population  are  affected  by  the  proposed regulation.   These
impact groups include rural  areas.  States,  regions, and specific
industrial   groups.    Section  F  presents  the  environmental  an
economic effects,  in  terms  of short-term  and  long-term  consid-
erations,  as well  as  irreversible   and  irretrievable  effects.
Finally, Section G discusses  the  impact of  the  proposed Criteria
on energy use and resource recovery.

A.   APPROACH AND METHODOLOGY

     The first task in the preparation of the EIS wซs to identify
all  the  potential   adverse  effects  of   improper   solid  waste
disposal  and to  assess   the   importance  of  the  resource  being
affected.  Only  then  could relative evaluations  ne mane as to
                               IV-1

-------
environmental benefits and importance of each proposed criterion.
Next,  technologies  and   methods  were  identified which  may  be
utilized to  comply with  the  proposed  Criteria, and  their  costs
and  effectiveness  in reducing the  adverse  effects  were  assessed
(Chapter III).

     The social  and environmental  impacts of solid waste  disposal
practices include a wide range of concerns such as public health,
occupational  health  and  safety,  environmental  damage,  and  main-
tenance of ecological systems..

     The degree  to which the proposed  Criteria  reduce  to accep-
table  levels  or  eliminate  the  significant  cumulative  adverse
environmental  impacts  of the  solid waste  disposal  practices  of
landfilling,  1andspreading,   and  impoundments  depends   on  the
effectiveness  of  government  regulations  and  the  technological
developments necessary to implement regulations.

     Although  considered  in  the   development  of  the  proposed
Criteria,  it is  not  the  purpose  of this  report to  evaluate the
efficiency  and   practicality  of  the  systems  for  enforcing  the
regulations  (including  monitoring  to   determine  compliance)  and
the  probability   of  efficient   (predictable)  site  operation.
Rather,  the EIS  evaluates  the beneficial  environmental  effects
which  reasonably  can be expected to occur  when the  Criteria are
fully  implemented  and  constrasts  them  with  the  probable economic
and  social costs of  the regulations.

     The costs of  achieving  these  effects will  be borne directly
by  the general  public,  disposal  site  operators, public  aqencies
at  local,  State  and Federal  levels,  industries, and other waste
generators.  Some  of these economic and  social costs fall equally
on   people,  while   others  may  be  distributed  inequitably  to
segments of  the population.
                                IV-2

-------
     The basic analytical  framework  of  the EIS diyiaes the costs
of meeting the Criteria into two parts:   (1) the costs of meeting
existing State solid waste  disposal  regulations (State-standard-
induced costs) and  (2) additional costs of  meeting  the  Criteria
beyond the level  specified by State regulations (Criteria-induced
costs).   The  true cost  impact  of the Criteria  is  found  in  (2),
but the total  (combi ned)  c_o_sjt to industry and consumer is the sum
of the costs in (1 )  and (2).

     In  order  to  identify  the   impacts,   specific  costs  were
attributed to meeting  each  criterion.   To  avoid double-counting,
specific  technologies  which  would   achieve  compliance  with  a
combination of criteria  were  assigned for  cost accounting to the
criterion of  greatest  importance  or  where  the technology had the
greatest impact.

     In  calculating  the  additional  cost of compliance  with the
Criteria,  the cost   impact  assessment  takes  as  given  Federal
regulatory  control  of certain  aspects   of  solid waste  disposal
(e.g.,  NPDES  permits,  Army  Corps  of  Engineers'  permits),  and
local/State regulations governing water  pollution,  air pollution,
noise, nuisance,  litter,  and similar effects.

     The methodology for  economic  and environmental  analysis w<  ,
developed with the  aid of fairly  complete  data  on  the number of
landfills and on  State solid waste disposal regulations,  but  with
very  limited  data on  the  number  of  1andspreadino  operations and
surface impoundments and overall conditions or current impacts of
all  three   types  of  land  disposal  facilities.   Although  some
industrial  landfills and surface impoundments may be regulated by
the  hazardous  waste  regulations  of  RCRA  and  not  by  these
Criteria, no  attempt  was  made to  estimate  how  many  sites  may be
so affected;  therefore,  Criteria  costs  may include estimates for
some  facilities   that  are  regulated  by   the  hazardous  waste
regulations of RCRA.   The  availability  of  data is  discussed in
Appendices III and V (Volume II).
                               IV-3

-------
     The basic method  used on  a  state-by-state basis was  four-
fold:

     (1)  Estimate  the  number  of  disposal  sites  (by size  and
          location);
     (2)  Estimate the  condition (environmental  impact) of exist-
          ing sites (by size and location);
     (3)  Identify  control  technologies  and estimatle  unit  costs
          (based  on site size) to meet each  criterion;  and
     (4)  Derive   total  control  cost  of  closure or  upgrading  by
          summing costs of  each  criterion  for  the  thr^ee  types  of
          disposal for  the total number of  affected sites.

     Unit costs  for landspreading  are expressed in  metric  units
($/metric  ton)   in  conformance  with  the   regulations  qoverninq
landspreading  that  are  currently  being   promulgated  by   EPA.
However,  unit  costs for  landfills and  surface  impoundments  are
expressed in  English  units  ($/ton),  reflecting the  predominance
of  the  English   system   in   the   solid  waste   management  field.
Calculations  for annualized  costs  have  taken   into  account  this
di spari ty.

     All  costs  in  this report  are in terms of annual i zed   19,
dollars.  The methodology  for the cost calculations  is disc us sou
in detail in Appendix V (Volume II).

1.   Landfil1s

     The  1977  Wa ste Age  survey  provided most  of  the  data  base
necessary  for  the  economic  impact  assessment  of  landfills.
Information  regarding  State   regulations   is   from  the  3NA's
Environmental Reporter, "State Solid Waste-Land Use."  Additional
information  and   clarification  resulted from   consultation  with
various State solid waste  offices.
                               T \l -A

-------
     Tne  Waste  Age  survey  identifies  the  total number  of  sites
within  each  State  and  presents  two  categories—permitted  and
authorized.   Since  these  two  categories  do not sum to thp total,
a third category--!' 11 egal  sites — is determined.

     This  latter  category  is  assumed  to be  open  dumps;  these
require  closing under  RCRA  within  5 years.    In  other  words,
illegal dumps meet  none  of  the Criteria, and consequently,  costs
for  these  sites  reflect  both  closure  costs  and  costs  for
obtaining and developing a new site.

     Permitted   sites   were   assumed   to   comply   with   State
regulations and  their  condition was  assumed to  be a function of
the  extent  to which the  State's solid  waste  regulations  comply
with  the  proposed Criteria.   Thus, the  costs  for  these  sites to
comply  with  the  Criteria  is the amount  of upgrading needed on a
criterion-by-criterion  basis  for  the  difference  between  the
current State regulations and the proposed Criteria.

     Authorized  sites,  according  to  the  Waste  Age  survey,  are
sites  which  are not quite  ready to  be  permitted.   In  order to
maintain  consistency,  it was  assumed that  both  authorized  and
permitted  sites  would  need  to  upgrade  to   meet  the  Federal
Criteria.   The  authorized  are assumed  to meet   current  State
regulations  except  those for  existing  ground   and  surface  water
criteria.   The  costs  for  the  authorized  sites,  to comply  is  the
same  as  for   the   permitted  sites,   plus  any  additional  costs
necessary to comply  with ground and surface water criteria.

2.   Surface Impoundments

     The  surface  impoundment  methodology  is  predicated  on data
from  USEPA  Contract  No. 68-10-4342;  Surface   Impoundments  and
Their  Effect  on Groundwater iji  the  United States—A P r e 1 i m i n a ry
Survey.   (Ref.  107).   In  addition  to the above, The Ground  Water
Report  to  Congress  (Ref. 7)  and  telephone interviews  provided
                               IV-5

-------
necessary information.

     Due to  the  limited  data on the location  size  and  condition
of  impoundments,  sites  were  grouped  into  only  two  categories
based  upon   the  nature of  the  industries  and the  size  of  the
impoundment  site.   Site  size  was the major distinguishing  factor
between the  two  groups.   Consequently,  some industries  (coal  and
other mining,  paper products, and utility  services)  having  both
small  and  large  impoundments  were  listed  in both  categories.
Group I and  Group II sites were defined as .follows:

     Group I  - Industries having one 20-hectare (50-acre)  surface
     impoundment  per  site;  includes  mining,  paper  product,  and
     utility  service industries.

     Group II  -  Industries   having  three   1-hectare  (2.5-acre)
     impoundments per  site,  totaling 3 hectares  (7.5 acres)  per
     site; includes oil   and  gas,  food  products,  textiles,  and
     chemical product industries.

     The proposed grou'nd-water criterion was identified as having
the  greatest potential  impact  on surface  impoundments  based on
observations  that most  impoundments  are  unlined and leak part of
their  contents  downward   into  the  soil.   (Ref. 107).   Therefore,
site  lining   was  assumed to  be  needed  to  meet   the  proposed
alternative  at  50% of all  sites within  a  given  State  when  that
State's  regulations  were  not  as  stringent  as  the  proposed
Criterion.   A more  detailed  discussion  of  the  cost methodology
and  assumations  is  presented  in  Appendix V  (Volume II).

3.   Landspreading

     The  data  sources  for calculating  the  economic impact of the
criteria upon landspreading practices were:
                               IV-6

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     (1)   Unpublished EPA report  on  sludge  disposal  practices of
          141 cities (Ref 126).
     (2)   Ground Water Report to Congress (Ref.  7).
     (3)   Consultation  with   major   cities  and  EPA   regional
          offices.
     (4)   Construction grant design and planning report.
     (5)   Other research reports and published articles.

     Initially,  information  regarding  industrial   groups  plus
municipal  waste treatment plants was examined.  Of all  industrial
groups surveyed,  seven  were thought  to  have wastes which could
feasibly   be   landspread:    pulp  and  paper,   Pharmaceuticals,
tanneries,  feedlots,  food  processing,  textiles,  and  petroleum
products.    However,  due to  a  lack of  data  regarding  their land-
spreading   practices,  they   were  not considered.    Thus,  only
sludges from municipal waste treatment plants were considered.

     All   criteria  were  analyzed  to  determine  their  economic
impact upon this  disposal   practice.    However, only  the  land
application  criterion  was  considered  to have  the  potential  to
significantly  impact 1 andspreading  practices.    See  Appendix V
(Volume II) for a more detailed explanation.

B.   ENVIRONMENTAL EFFECTS AND  COST IMPACTS; SUMMARY
     OF PROPOSED ALTERNATIVE

1.   Major Environmental Benefits

     The  general effects of  the Criteria  will be threefold:

     (a)   Many   ฃ   sting  facilities   (such   as  landfills,  land-
          spread:  j  operations,   and  surface impoundments)  will
          close or  be  forced  to  close,  because  of  the  cost or
          physical  impossibility of compliance;
                               IV-7

-------
     (b)   Many  other  existing  facilities   will   upgrade   their
          operations  in  conformance  with   a   State   compliance
          schedule  and  will   reduce  to  acceptable   levels   or
          eliminate  the  adverse environmental  effects of  their
          operations; and*,
     (c)   New and expanded solid waste  disposal  sites, resulting
          from previous closures/consolidations and new  demands,
          will  be   designed  and operated  in  such a  way  as  to
          ensure a  reasonable  probability  of  health,  safety  and
          environmental quality.

     In  some  cases  where existing  facilities  are  closed  or
upgraded,   the  environmental   effects   of  past  operations  (for
example,   caused  by  location   in  wet!ands/f1oodplains,  critical
habitats;   leachate  and gas generation  and  migration; and  heavy
metal  application  to  land) may still continue for some time into
the future.  This is because  of the prohibitively  high corrective
and retrofit costs and technological  infeasibility or  uncertainty
associated  with  closing  or upgrading  an existing  facility  such
that adverse  environmental  effects  are  eliminated.   Herein lies
the  major  economic  benefit  of  the  proposed  Criteria — damages
(including    corrective    and    retrofit    costs)     avoided.
Unfortunately, this economic  benefit is not readily quantifiable.
This is discussed further in  Section D.

     Specific environmental benefits  resulting  from  the  proposed
Criteria were discussed  in detail  in Chapter III  of this report;
these  are  summarized  by  criterion  for  landfills,  1andspreading
and surface impoundments in Table 28.
                               IV-8

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                                       TABLE 28

                       SUMMARY OF MAJOR ENVIRONMENTAL BENEFITS
                                    (By Criterion)
     CRITERION
                     DISPOSAL METHOD
1. Environmentally
   Sensitive Areas

     A. Wetlands
     B. Floodplains
     C. Permafrost
     D. Critical
        Habitats
     E. Recharge Zones
        of Sole-Source
        Aquifers
*Not Applicable
                                Landfills
Protects almost all
wetlands.  Will elimi-
nate many open dumps
now in wetlands; will
prevent expansion of
others and develop-
ment of new sites.
Protects these areas
from major water qua-
lity impacts during
flooding.

Protects against near-
by flooding caused by
backwater effects.
Will improve current
disposal practices in
Alaska's Artie and
minimize erosion and
water pollution prob-
lems
Prevents expansion in-
to such areas; pro-
tects such habitats
in the future.
Protects drinking
water supply.
                         Landspreading
       N/A"
Beneficial uses will
continue; protected
by other Criteria.
       N/A
No effect.
Protects drinking
water supply.
                      Surface Impoundment
Reduces impacts in
lowlying industrial
areas and ensures
that new sites will
be permitted only
if they do not en-
danger the environ-
ment.
Eliminates water
quality effects of
flooding, especially
in areas of high
net precipitation.
Will minimize ero-
sion and pollution
problems.
Reduces potential
harmful impacts on
critical habitats.
Protects drinking
water supply.
                                         IV-9

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                                   TABLE 28 (Cont'd)

                       SUMMARY OF MAJOR ENVIRONMENTAL BENEFITS
                                    (by Criterion)
     CRITERION
                     DISPOSAL METHOD
2. Surface Hater

     A. Point Sources


     B. Non-Point
        Sources
3. Ground Water
4. Air
5. Application to
   Land Used for
   Food Chain Crops
                                Landfills
Reinforces Section
402 of the FWPCA.

Prevents or minimizes
flow into surface
water.  May lead to
need for more point
source permits (NPDES)
Prevent or reduces
leachate flow into
ground water; improves
current and future
ground-water quality.
Reduces air pollution
from particulates and
gaseous emissions;
eliminates smoke haz-
ards.
          N/A
                         Landspreading
Reinforces Section
402 of the FWPCA.

Prevents or minimizes
flow of contaminents
into surface water.
Reduces potential
contamination of
ground water.
       N/A
Prevents additional
increase of cadi urn
into the diet; pro-
tects food chain
from unacceptable
levels of pesticides
and persistent or-
ganics; protects
animals raised for
milk from unaccep-
table concentrations
of pathogens, toxic
organics, or heavy
metals.
                      Surface' Impoundments
Reinforces Section
402 of the FWPCA.

Prevents or minimizes
flow of contaminents
into surface water.
Prevent or reduces
leachate flow into
ground water; improves
current and future
ground-water quality.
Reduces gaseous
emissions.
       N/A
                                         IV-10

-------
                                      TABLE 28 (Cont'd)

                       SUMMARY OF MAJOR ENVIRONMENTAL BENEFITS
                                    (by Criterion)
    CRITERION
                     DISPOSAL METHOD
6. Disease Vectors
                               Landfills
Reduces vectors in
existing landfills
and prevents vector
food and harborage
in new sites.
                          Reduces or eliminates
                          gas hazards.  Elimi-
                          nates or controls
                          fires; eliminates
                          smoke hazards.
                        Landspreading
Eliminates fly and
insect problems.
                       Controls animal and
                       numan access, there-
                       by reducing injuries
                      Surface Impoundments
Controls aquatic
related vectors.
                      Controls  toxic
                      gases;  reduces  in-
                      juries  due  to
                      improper  access.
                                         IV-11

-------
2.    State-Standard-Inducod and Criteria-Induced Costs

     To arrive at costs induced by State standards,  a  methodology
was developed  for  each type of disposal method.   For  landfills,
State-standard-induced  costs  were based  on two  considerations:
the number  of  "permitted"*  and  "authorized"*   sites within  each
State   (Ref. 76)  and  the  extent to which the State standards  meet
or exceed the new Federal Criteria.

     The  three   components  of  State-standard-induced  costs  for
landfills are:

     (1)  the cost  to  upgrade  "authorized"  sites to meet the new
          Federal ground and surface water criteria;
     (2)  the cost  to close illegal  sites  in  States  where State
          standards meet or exceed the new Federal Criteria;  and
     (3)  the cost of opening  new sites to replace those which do
          not meet State standards (the ratio of the cost to  meet
          State  standards  to  the  cost  to  meet Federal  standards
          was used to estimate this cost component).

     Only  the  third  cost  element was  used  to  estimate  State-
induced costs of 1andspreadi ng.

     For  surface  impoundments,   the  distribution  of  costs  was
based  upon  an   analysis  of  State regulations.    If  the  State
regulations met  the  Federal  Criteria,  then upgrading and closure
costs  were  attributed to  the  State regulations.   Conversely, if
the  State  regulation  did  not meet  the  Federal  Criteria,  then
upgrading and closure costs were considered Criteria-induced.
* D e f i n e d on page IV-5.
                               IV-12

-------
     In  summary,   the  combined  annualized  cost  for  all  three
disposal  methods is $1661.1 million of which $513.6 million  (31%)
are Criteria-induced costs and $1147.5 million  (69%)  are State-
standard-induced  costs.     Table  29   shows  Criteria  and  State-
standard-induced costs for  1 andspreading,  landfills,  and surface
impoundments.

                             TABLE  29
 STATE-STANDARD-INDUCED VS.  CRITERIA-INDUCED ANNUALIZED COSTS FOR
       LANDSPREADING, LANDFILLS,  AND  SURFACE  IMPOUNDMENTS
                       (Proposed Criteria)
                      (millions of dollars)

                                               Surface
Annualized Costs  Landspreading  Landfills  Impoundments   Total
Crite
State
Combi
=====
ri a-
-Sta
ned
= ===;
Indue
ndard

=====
ed
-In

=5=2 =
10.
duced 3.
14.
_________
6
5
1
_.
304
365
669
-*• 	 — ? 	 	 '_-•_• .^-^-*- 	
.0
.3
.3
====:====
199
788
977
=====
.0
.7
.7
==
513
1147
1661
________
.6
.5
.1
=:= = =
3.   Major Cost Factors

     The major costs of the Criteria derive from three individual
criteria  (ESA,  ground  water,  and  safety)  and closure.   To  meet
the  environmentally  sensitive   area   (ESA)  criterion,  a  total
annualized cost  of  $130.7 million will be  incurred;  these  costs
include closure costs for surface impoundments.   In order to  meet
the   ground-water   criterion,   a  total   annualized   cost   of
$974.7 million will  be  incurred;  most  of  this cost can be attri-
buted  to  lining  surface  impoundments.     Safety  considerations
involve  an  annualized   cost  of  $111.9  million,  a  significant
portion of which can  be attributed to  the  lack  of State legisla-
tion  for   control  of  toxic  and  asphyxiating  gases   at  landfill
sites.   Table 3  in  Chapter I summarizes the  annualized combined
costs for each criterion.
                               IV-13

-------
     Annualized  closure  costs  amounting  to  $398.0 million  are
based entirely upon the  number  of  illegal* landfill  sites,  which
must  be   closed  and  the  number  of  new  sites  which   will
consequently be developed and opened.

     For  surface  impoundments,  the  cost  of  closure  invo-lved
pumping   out   the   impoundment,   covering  it  with   dirt,   and
developing  and  lining a  new  impoundment.   Most of  the  costs  of
this  closure  process  are  associated  with  developing  and  lining
the  replacement  site.   Since  these  costs  are the  same  as  those
associated  with  upgrading  an   existing   site,   the  distinction
between  "closure"  and  "upgrading"  is  not significant for surface
impoundments.    For this  reason,  the  concept of closure  is  not  a
separate cost  element  as  it  is  in  landfills.  Therefore, closure
costs  do  not  appear  as  a  separate   cost  element  in  tables
presenting data for surface impoundments.

     Table 30 shows combined upgrading and  closure  costs  by  State
for  landfills, surface impoundments and 1andspreading.
*Sites which are neither permitted nor authorized (Ref. 76)
                              IV-14

-------
                                   TABLE   30
                           DISPOSAL METHOD COST SUMMATION
                                 UPGRADE AMD CLOSURE

                                 (Proposed Criteria)
Scat*
Alabama
Alaska
Arisona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
. Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Cakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Other
Total
Landfill
2,426,600
7,976,400
3, 348.000
13,003,700
0
9,2:4,400
4,216,300
855,500
12,740,100
44,358.600
1,737,000
7,009,100
65,128,200
6,814,800
11,637.500
7.112,700
7.402,100
17,527,300
9,714,300
9,272,400
15,214,000
63,252,300
3,514,300
28,810.500
3,701,500
3,711,700
10,779,500
2,498,900
2.840,200
10,321,500
14,075,100
42,296.700
2,311,700
6,623,300
10,432.:CO
69,926,300
1,469,500
18,565, 50O
16,500
7,248,300
1.179,900
4,933.500
21,723,900
28.262,700
1,337,700
6,933,5OO-
9,300..30O
6. 152, ;oo
ia,;88.4oc
2. 307.500
-
669,326,400
Surface
Impoundment
14,076,000
4,520,625
952,687
4,817,175
20,201,775
1,488,225
562,237
267,188
3,719,588
3,818,550
286,913
485,850
23,494,725
12,073,687
3,790,050
37,246,537
26,506,387
105,853,050
552,825
8,394,900
674,588
19,698.787
792,975
6,762.338
4,470,188
6,950.925
29,231,287
2,964,675
635", 550
1,965,000
4,199,250
6,954,000
4,714,350 '
16,671.262
106.253,387
20,941,688
2,446,612
313,761.105
252.525
1,006,950
346,650
5.650,338
59.665,500
Landspread










































1,752,263
1,847,212
233,000
3,409,087
76,602,300
1.902.9CO
4,849,275
-
977,703,112






14,140,000*
Total
16.S02.600
12,497,000
6.800,700
17,820,900
20.201,800
10.712,600
4,778.500
922,700
16,459,700
48,677,200
2,023,900
7,495,000
94,015,500
19,147,600
•15,427,600
44,359,200
33,908,500
123,680,400
10,267,100
17,667,300
15.888,600
82.951,100
9.307,800
35,572,800
ft. 347, Don
10,662.600
40,010,800
5.463,600
3,475.800
12.286.500
18,274.400
49,250.700
7,026,100
23,294.600
116,726,400
9O. 868, SCO
3,916,100
3VJ, 326, 60S
269, OOO
8.255,900
1.S26.60O
10.589,300
81,394,400
30,OIS,OCO
3,784,900
7.221,500
13.209.400
11. 554. 300
20.191,300
7.156,800
1.SSS.900
1.676.723.500
*This  total  results  from  multiplying by five the  "total
 (The  data represent  approximately  20% of  the sludge
 agricultural  land).

                                                IV-15
cost   figur*  for  the 58-eity survey.
currently being Mndtpread  on

-------
4.   Comparison of_ A1ternalives

     In Chapler III Ihe environmental  benefits and economic  costs
of the  proposed,  more restrictive and  less  restrictive  alterna-
tives were discussed for  each criterion.

     The  major  environmental  benefits  of the proposed  Criteria
were   summarized  in Table 28,  page IV-9.    Foremost among  these
benefits are protection of:

          almost all wetlands;

          floodplains   from   major  water  quality  impacts  during
          f1oodi ng ;

          ground  water  and   surface   water   by   minimizing  or
          preventing leachate damage;

          food  chain   crops  by  reducing  the  probability  of  an
          increased dietary  uptake of  cadmium; reduces  exposure
          to pathogens, persistent organics  and pesticides;  and

          public  and  environment  from  hazardous   effects  of
          explosive  gas  and  concentrations  of  toxic or  asphy-
          xiating gas

     These significant environmental  benefits would be sacrificed
if less restrictive  alternatives  were selected.   As a  result,
existing  adverse  effects  enumerated in Chapter III would  not  be
adequately  addressed.   Thus,  the less restrictive  alternatives
would   not  provide  comprehensive  protection  of  wetlands  and
floodplains;  in  addition, a  less  restrictive approach  does not
offer regulatory controls  to minimize  or prevent off-site decirad-
ation  of  ground  water and  contamination  of food chain  crops.
Consequently, even  though the implementation  of less  restriclive
alternatives  for  all  the  Criteria  would  result  in  an  annual
                              IV-16

-------
savings of $632 million over the proposed Criteria,  the resulting
adverse environmental impact would be so substantial  as to offset
any  saving.s.     As  discussed   in   Chapter  II,  the   House   of
Representatives' Committee  on  Interstate  and  Foreign  Commerce in
Report 94-1491   determined   that  legislation   regulating   land
disposal  of wastes is necessary if other environmental  laws  (such
as  those  governing  air  and  water)  are  to  be both cost  and
environmentally effective.

     As  indicated  in  the   summary   economic  and  environmental
impact analyses in Chapter  III, the environmental benefits of  the
more restrictive  alternatives  are quite  similar to  the benefits
offered  by   the  proposed Criteria;   the  difference  between  the
proposed and  the  more  restrictive alternative lies  in  the degree
of  risk,  not  in  the degree of  environmental  benefit.   For  the
environmentally  sensitive  area  criterion,  for  example,  bannina
solid waste disposal in these areas (the more restrictive altern-
ative)  would  result in less  risk of  damage  potential than that.
offered  by  the  proposed  criterion.   On  the  other   hand,  the
proposed  criterion  provides essentially  the  same  envi ronnPnta 1
benefit as the more restrictive, protecting almost all  productive
wetlands; protecting  ground and  surface water from  contamination
due  to  flooding;  reducing  the  potential  for flood hazard;  and
improving solid waste management in permafrost areas.   In effect,
the  proposed   regulations governing  disposal  of  solid  wastes  in
environmentally sensitive areas provide significant  environmental
protection without resorting to an outright ban.

     In  terms  of aggregate  costs, more restrictive  alternatives
would cost  $598 million more than the  proposed,  in  spite of  the
minimal   additional   environmental  benefit  offered  by the  more
restrictive  approach.   The  major  cost  differential  results from
the ground-water  criterion;   the  more  restrictive alternative  for
ground water  would  add  $493 million  (a 50% increase)  annually to
the cost of the proposed criterion.  The additional  environmental
benefit  of  the  more  restrictive  over  the  proposed  is  the
                              IV-17

-------
protection of ground water under disposal  sites,  resulting in the
protection of  all  usable ground  water  regardless of  present  or
future use.

     In  respect  to  the  criterion  for  land application  to  food
chain  crops,   implementing   the  most   restrictive   regulatory
alternative  would  add  $56.3 million annually,  a 399%  increase
over the  proposed.   Since the most  restrictive  alternative  is  a
ban on land  application  of  solid wastes to food  chain crops, the
environmental  benefit  of the most  restrictive alternative  would
offer  maximum  protection  for   humans  and  animals.    However,
current EPA data indicate that a ban on land application of  solid
waste is unnecessarily restrictive.   In addition, as  discussed in
Chapter III,   such  a  stringent  regulatory approach  would impact
severely on many small communities.

     In  summary,  the proposed Criteria developed  by  EPA address
the key  environmental  issues  of  concern in the disposal of  solid
wastes to  land,  providing  substantial  protection of  the environ-
ment; while  more restrictive regulatory  approaches  might lessen
the risk of adverse environmental impacts, they would not provide
any significant additional environmental protection.

C.   ENVIRONMENTAL EFFECTS AND COST IMPACTS SUMMARY OF
     PROPOSED ALTERNATIVE

1.   Landfill Disposa 1

     (a)  Data Base

          The   landfill   data  base  was   developed   using  the
Haste Age  survey.   (Ref. 76).  The  survey  provides,  on a state-
by-state  basis,  the numbers  of  permitted*  and  authorized*  sites
within  each   State  and  a  breakdown  of  these  sites  by  tonnage
^Defined on page IV-5.
                               IV-18

-------
received  per  day  (TPD).    Table 31  presents  assumptions  on
landfill status and size derived from the survey.
                              IV-19

-------
•  1    V -,
                 TABLE  31





             LANDF3U. JWWA BASE
Slate
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Cotmectxcut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansa^
Ker.tuck"
-ouisiana
Maine
Maryland
Massachusetts
Mi-'U.V'l'
Mi, aesoid
Mississippi
Missouri
Mom ana
Xetji aska
Nevada
New Hampshire
New Jersey
Sew Mexico
Sew York
North Carolina
North Dakota
Ohio
Oklahoma
Or Eฃon
Pennsylvania
Riot!.- Island
South Carolina
Siut Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wycrring
-tat
Permitted
127
84
78
• 74
430
67
55
30
238
123
21
40
288
125
94
103
144
60
13
48
101
295
134
78
117
124
62
31
62
210
50
420
170
23
242
165
167
111
35
217
23
109
293
9
60
209
50
51
289
10
6,160
Authorized
8
300
-
87
-
126
115
-
67
123
9
47
42
-
109
95
167
60
432
-
199
255
136
• 78
117
121
200
89
56
68
319
-
-
60
-
165
-
202
-
-
34
12
752
13
30
-
320
61
I. Oil
65
6,150
Illegal
3
16
f,6
239-
-
38
-
-
50
379
-
33
135
23
97
-
33
145
-
31
60
150
135
118
19
-
138
-
47
60
171
242
-
117
8
177
-
102
-
5
243
5
52
178
8
26
40
95
-
25
3.511
10 TPD
80
398
127
385
275
178
120
10
' . 247
511
17
50
218
91
255
150
322
255
441
43
300
316
371
206
219
239
397
118
157
278
537
363
69
196
26
227
157
328
30
113
298
31
1,008
100
97
139
339
192
1,220
98
12,342
100 TPD
51
1
11
14
80
47
48
14
71 .
75
9
60
112
41
40
43
15
-
4
19
43
245
34
32
24
6
1
1
7 ,
28
3
260
95
4
135
178
4
71
2
40
2
83
48
88
1
72
60
12
53
t
2,389
300 TPD
4
1
3
1
35
2
2 -
3
22
25
2
10
47
14
4
, 2
5
10
-
5
10
69
-
. 25
6
-
2
-
1
12
-
7
6
-
75
52
4
4
3
47
-
4
15
5
-
24
5
3
15
-
591
700 TPD
5
-
3
-
40
4
-
3
15
14
2
-
88
3
1
3
2
-
-
12
7
70
-
11
4
-
-
1
-
20
-
32
-
-
14
•50
2
12
-
22
-
8 .
26
7
-
-
6
-
12
-
499
Total
Tonnage /Day
10,600
4,380
4,770
5,550
49,250
8,280
6,600
4,500
-26,670 "
29,910
3,070
9,500
53,880
11,310
8,450
8,500
16,620
5,550
4,810
8,730
20,460
97 , 360
7,110
20,460
9,190
2,990
4,670
1.980
2,570
23,180
5,670
54,130
11 , 990
2,360
46,060
70,670
4,570
19,980
1.400
34,630
3,180-
27,410
37,580
16.200
1,070
15,790
15,090
4,020
30,400
1,180
856,280
Tons/Year
2,756,000
l.foa.SOO
1,240*200
1,443,000
12,805,000
2,152,800
1,716,000
1,170,000
6,934,200
7,776,600
798,200
2,470,000
14,008,800
2,940,600
2,197,000
2,210.000
4,321,200
1,443,000
1,250,600
2,269,800
5,319,600
25,313,600
1,848,600
5,319,600
2,389.400
777.400
1,214.200
514,800
668.200
6.026,800
1,474,200
14,073,800
3,117,400
613,600
11,975,600
18,374,200
1,188,200
5,194.800
364.000
9.003,300
826,800
7,126,600
9,770,800
4,212,000
273,200
4, 105, ..00
3,923,400
1,045.200
7.904,000
306,300
[27,313,800
                IV-20

-------
     Since  no   detailed  data  exist  to  establish  the  location  and
condition of these sites, several  assumptions were  made:

          Location  -   Information   Is  available  (Ref. 7)   to
          establish  the  percentage  of  land within  each .State
          classified   as   environmentally   sensitive.*       An
          assumption was  made that  the number  of  landfills  by
          size  and  type within  an  ESA   is  a   function  of  the
          percentage  of  land within  each  State  classified  as
          environmentally sensitive.    Thus,  if  10% of the  land
          within a State was classified as environmentally sensi-
          tive,  then   10%  of  the  10  TPD,  100  TPD,  300  TPD  and
          700 TPD sites  (permitted,  authorized and  illegal)  were
          considered to be located in an ESA.
          Condition - An assessment of the condition of the  sites
          was based upon the  type  of site and State regulations.
          Permitted site conditions were assumed  to  be  in  compli-
          ance with the  State regulations.  All  authorized  sites
          were  assumed  to need controls  for ground and  surface
          water.   Illegal  sites  were  assumed to be so  environ-
          mentally unsound that the most practicable solution was
          closure.

     Appendix  V  (Volume II)  presents  a detailed explanation  of
the methodology and assumptions concerning location  and condition
of landfills.
 To avoid double-counting wetlands and floodplains,  a figure for
the total number of square miles of wetlands and half of the total
number of square miles of floodolains was used in conjunction with
the total number of square miles of other ESA components.
                              IV-21

-------
     (b)   Major Environmental  Benefits


          For  landfills,  the  significant environmental  benefits

of the  Criteria include:
          Protection of  almost  all  wetlands by  eliminating  many
          open  dumps  located  in  these   areas   and   preventing
          expansion  of  existing  sites  and development  of  new
          ones.

          Protection  of   floodplains   from  major  water  quality
          impacts during  flooding.

          Improvement of  current disposal  practices  in  permafrost
          areas.

          Protection  of   habitats  of  endangered  species   from
          harmful impacts.

          Protection of drinking water in  recharge zones of  sole-
          source  aquifers.

          Improvement of  current and future ground-water quality.
          Protection  of  the  nation's  rivers,  streams and  lake
          from bacterial  and chemical  contamination.

          Reduction in air pollution caused by open burning.

          Reduction  in  safety  hazards  (explosive  gases,  fires,
          bird hazards to  aircraft and injuries due  to  improper
          access) .

          Protection of public health.
                              IV-22

-------
     (c)   Unit Prices For Each Criterion

          Costs for each criterion were based upon  a  hypothetical
scenario  of  an   "average  existing  condition"  and  an  "average
compliance  technology".    In other  words,   for  each site  size,
assumptions were  made  regarding:    (1) average  current  operation
and  maintenance;   (2) the  physical  dimensions,  properties,  and
other  characteristics  of   the   site;   and   (3)  the  technoloay
required  to  upgrade,  and  to develop  unit   costs.    Appendix  V
(Volume II) presents a  detailed description  of  these assumptions
of average conditions and average  technologies.

     Unit costs also assumed that  the life of an average landfill
was  10 years  and  that  implementation  would  occur  in  three  years.
The detailed economic methodology  can also be found in Appendix  V
(Volume II).

     Table 32 summarizes the landfill  cost for each criterion  and
site size.
                               IY-23

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-------
    (d)    State-Standard-Induced vs.  Criteria-Induced  vs.
          Combined Costs

          State costs were developed  according  to  the  methodolooy
briefly   described  earlier for  upgrading  and closure.   Table 33
summarizes State-standard-induced and Criteria-induced  costs  for
1 a n d f i 11 s .
                            TABLE 33
           STATE-STANDARD-INDUCED VS.  CRITERIA-INDUCED
                    ANNUALIZED LANDFILL COSTS
                      (mi 11 ions of dol1ars)
Annuali zed Costs
Upgrade
Cl ose
                                                         Total
State-Standard-Induced
Criteria-Induced
115.8
155.5
249.5
148.5
365.3
304.0
Combi ned
                                    271.3
            398.0
          669.3

     Table  34  presents  a  detailed  examination  of the  combined
economic  impact  on   landfills  of  the  proposed   regulations  by
criterion and by State.
                               IV-28

-------
                                            TABLE  3i                                         ;




COMBINED  ECONOMIC  IMPACT  CF  PROPOSED  REGULATIONS  BY  STATE  AND  CRITERION: LANDFILLS

-------
     (e)   Major  Cost  Factors

          Closure costs for illegal  sites  represent  the  greatest
overall  cost  factor  for  surface impoundments.   In regard  to  the
Criteria,   the  ground-water   criterion  represents   the   largest
single criterion cost;  most of this cost (88%)  is  State-standard-
induced  due   to:    (1)  the  assumption that  no  authorized  site
currently  meets  the  State  ground-water criterion,  and  (2)  the
large  number   of   authorized  sites.     The  safety   criterion
represents the  second  largest cost  factor since few  States  have
addressed  gas safety  considerations in their  regulations.

2.   Surface  Impoundmenf.s

     (a)   Data Base

          The surface  impoundment  data base was derived  from an
unpublished  EPA  report (Ref.  107)  which provided  an  estimate of
the  number  of  impoundments  in each  State.*  Due  to  the .limited
data on the  location,  size,  and condition  of impoundments, sites
were  grouped  into  only two  categories based upon  the  nature of
the  industries  and  the size  of the  impoundment site.   Site  size
was  the   major   distinguishing  factor  between the  two  groups.
Consequently,  some  industries  (coal   and  other  mining,  paper
products,   and  utility services)  having  both small  and  large
impoundments   were  listed  in  both  categories.     Group I   and
Group II  sites were defined as follows:

     Group I  - Industries  having one 20-hectare (50-acre)  surface
     impoundment  per  site;  includes mining,  paper  product,  and
     utility  service industries.
*Municipaxl waste treatment impoundments and agricultural  impound-
ments reported were not, considered in the data base for this EIS
                              IV-30

-------
     Group II   -   Industries  having  three  1-hectare   (2.5-acre)
     impoundments  per  site,  totaling  3 hectares (7.5 acres)  per
     site; includes  oil  and  gas,  food  products,  textiles,  and
     chemical  product industries.

     Table 35  presents the  data  base  and  cost  summary  for  surface
impoundments.
                              IV-31

-------
                  TABLE   88




DATA BASE AND COST SUMMATION:  SURFACE  IMPOUNDMENTS


Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware ,
Number of Sites
Group 1
:>28
50
13
11
159
40
9
0
Florida 22
Georgia
Hawaii
38
2
Idaho 4
Illinois 125
Indiana ' 93
Croup II
309
59
37
475
1,680
173
23
Total
537
109
50
486
1.839
213
32
33 33
170 192
191
27
41
2,318
1,009
229
29
45
2,443
1.102
1 Iowa 63 U6 209
Kansas i 53
Kentucky [ 452
4,640 4,693
592
Louisiana 55 9,338
Maine 7
Maryland ! 132
Massachusetts 7
Michigan • 20
Minnesota | 7
Mississippi 30
Missouri i 71
, Montana i 11
Nebraska j 480
37
188
34
1,044 ,
9,393
44
320
41
2,273 ' 2,293
49
630
150
879
758
i Mevada 51 ' 77
; New Hampshire
Sew Jersey
< Mew Mexico
New York
North Carolina
North Dakota
! Ohio
8 J3
21
19
37
48
35
430
, Oklahoma 126
] Oregon 38
Pennsylvania 5,003
i Rhode Island 1
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Total
7
•>
86
158
4
21
3
40
704
24
34
9,082
101
56
660
221
890
1,238
128
41
122
456 475 .
464 ,' 301
223
1,955
11,480
1,213
83
7,871
32
72
34
228
6,762
208
103
26
201
5,755
79
438
64,153
271
1.990
11,910
1,339
121
12,374
33
79
36
314
6,920
212
124
29
241
6.459
103
472
73,235
Coats (Closure and Upgrading)
Group I
11,648,300
3,827,100
674,100
687,000
7,716,900
211,500 .
385,200
0
1,714,500
Croup II
2,427.700
693,500
278,600
4,130.200
12,484,900
1,276.700
177.000
267,100
2,005,000
2,157,300 1,661,200
Total $
14,076,000
4,520,600
952,700
4,817,200
. 20.201,800
11,488,200
562,200
267,100
3,719,500
3,818,500
96,300 ' 190,600 1 286,900
192,600 i 293,300
485,900
6,079,800 17,347,400 23,427,200
3,424,900 ' 5,827,000 9,055,900
2,702,900 1,087,200 I 3,790,100
2,606,600 34,640,000 ; 37,245.600
22,097,900 ' 4,408,500 26,506,400
3,904,100 101.899iOOO ' 105,853,100
288,900 ; 263,900 ! 552,800
5,904,100 1,490.800 1 8,394,900
391,700
1,072,200
282,900 i 674,600 |
18,626,600
391,700 665,600
1.656,500
3,370,500
5,105,800
1,099,700
481,500 i 6,469,400
23,555,300 5,676,000
2,407,500 557,200
385,200
1.797,300
864,800
3,693,000
2,834,300
1,739,900
20,929,400
6,073,400
1,829,700
250,674,300
0
391,700
96 , 300
4,644,100
7,935,300
192.600
1,065,800
96 , 300
1,926,000
34,116,000
1,264,800
1.637,100
455,285.600
250,300
822,700
19,698,800
1.057,300
6,762,300
4,470,200
6,950,900
29,231,300
2.964,700
635,500
2,620,000
3,334,400 ' 4,199,200
3,261.000
1,880,100
14,931,400
6,954,000
4,714,400
16,671,300
85,324.500 106.i53.900
14,868,300 20,941,700
616,900 2.446,600
60,086,700 310,761-,000
252,500
615,300
250,300
1,006,800
51,730,200
1,559.600
781,500
191,700
1,483,100
42,486,000
v 638,100
3,212,200
522,417.500
252,500
1,007,000
346,600
5,650,900
59,665,500
1,752,200
1,847,300
288,000
3. 409 , 100
76.602,000
1,902,900
4,849,300
977.703,100
                       IV-32

-------
     (b)   M a jor En v1r on menta 1  B e n e f i ts

          For  surface  impoundments, the significant  environmental
benefits  of the Criteria include:

          Reduction  of  impacts  in  low-lying  industrial  areas,
          ensuring  that  new   sites  will  be  permitted  in  .flood-
          plains only  if they  do  not endanger the environment
          Elimination    of  adverse  water   quality  effects   of
          flooding,  especially in  areas of  high net  precipitation

          Reduction   of   potential   harmful  impacts  on  critical
          habitats
          Protection of drinking  water
          Improvement of current  and future ground-water quality
          Reduction  in air pollution caused by gaseous  emissions
          Control of toxic gases
          Reduction  in injuries due to improper access

     (c)   Costs For Each Criterion

          Costs  for  surface  impoundments  were  based  upon  the
average site sizes described in the previous section.   Only three
criteria   were  judged  to  have  the  potential  for  the  greatest
economic   impact--ground water,  environmentally  sensitive  areas,
and  the  access  requirement  of safety.    Appendix  V  (Volume  II)
presents  a more detailed description of the cost methodology.

     Costs assumed that an average surface  impoundment  would last
10 years   and  that  implementation  would  occur  three years  hence,
Table 36  presents costs on a criterion-by-criterion, group  basis.
                              IV-33

-------
                            TABLE 36
   SURFACE IMPOUNDMENT TECHNOLOGY COSTS PER SITE BY  CRITERION*
                    (Annualized,  1977 Dollars)
Criterion              Group I                      Group II

ESA +                    $102,000                    $15,400
Ground Water             95,400    .                 14,300
Safety*                   1,100                        400
*Assuming implementation beginning in 3rd year.
"'"Includes closure costs (closing and opening a new site).
JCost for access.
     (d)   State-Standard-Induced vs.  Criteria-Induced
          ys.  Conbj ned Costs

          Costs categories were  developed  based  on  the status of
current  disposal  practices  and  on whether  the  proposed Criteria
are more  stringent than current  State  standards.    If the State
standards were at least as stringent as  the Federal  Criteria,  the
costs  to  upgrade  current practices were attributed  to the State
(State-standard-induced costs); if not,  the costs were attributed
to  the Federal  Criteria.   Table 37 shows that out  of a combined
cost  of   $997.7  million,   $778.7  mill ion,  or   79%,  are  State-
standard-induced costs, and  S199.0 million,  or  21%  are Criteria-
induced costs.
                              IV-34

-------
                            TABLE  37

  ANNUALIZED COST FOR SURFACE  IMPOUNDMENTS BY SELECTED CRITERIA
          (Criteria-Induced and State-Standard-Induced)
                    (millions  of  1977  dollars)


                                                            State-
                                                  Criteria  Standard-
Criterion            Group I    Group II   Total    Induced   Induced
ESA (closure)
Ground Water
Safety
36.6
413.6
5.2
88.5
421.7
21.2
125.1
835.2
17.4
99.2
96.9
2.9
25.9
738.3
14.5
Total                 455.3     522.4      977.7   199.0    778.7
     Tables  38,   39,   and  40  show  total   annualized  costs  for

surface  impoundments   resulting  from  the  proposed criteria  for

ESA,  ground water and safety,  respectively.
                              IV-35

-------
                                        TABLE   38






  TOTAL  ANNUALIZED COSTS  FOR  SURFACE IMPOUNDMENTS;  ENVIRONMENTALLY SENSITIVE  AREAS
Statt
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky

Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana

Nevada
New Hanfis'ntrt
Sew Jersey
New Mcxic-o
New v.ork
Nortn Coro 1 ma
I
1 , 1 3 5 , / SO
2,671, 500
0
203, ~ j,25-
"
267, 753
488, 250
0
1,223, =00
315,^)0
15,750
15, 7fO
47,050
1,433,250
488,250
0
0
6,31,5,.0
283,5 0
31,50,0
1,165,500
1 41,750

02,652, 500
0
217,5 ;o
6 3,000
3,685, :00
^8,7:0
#97,750
0
47,250
^3b , .-:>f-'
)
15,750
21.;,^---
15,7=0
36, 20 ,
472,5""
local
1,603,500
3,151,750
0
1,434,000
520,500
15,753
15,750
47,250
2,660,250
1,104,750
0
0
867,010
386,250
134,25,0
1 , 268, 250
861,303

65,016,750
0
1,245,000
165,750
3,391,000
131,500
i ,206, ;oo
0
47 250
l.ibi. !'••}
0
15, -50
513.000
15, 750
:,:=•!, "oo
1,131, "'--•
Federal
1,603,500
3.159,750
0
1,434,000
520,50,3
15,750


2,666, 250


-,
967.000
386.250

1,268. 250
361,000

65,016,753
0


3,891,000

1,206,000

47,250 j
1.161, JOO
0

513, OCO
' 15,753
2 ,091, 300
1,1 91, "50
State






15,750
47,250

1, 104, 750
J


1
13-1.250

{
i

1

1 ,.'45, ""0
165,755

131, 5:c j


1
1

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1
North r.ikcta
Ohio

Oici.inona
513,-:

- - t , ,,
:.173,5^

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2.f?7 =) • • --si ^3 j
! ,
320, 2:3 ' 323,: = "; 1
Oreg3n
?B.TS> Ivar.la
^t I.l^d
South Co ro'i lia
">
10,435,0:"


15,7='
4,457,2=:
n , ~~

15, "50 . 15,750
22,152,2-1 !
47,:-; ' 4-, 25:
-,-,-: o 3-7, •=:•-.




                                    IV-36

-------
                               TABLE   39





TOTAL  ANNUALIZED COSTS  FOR  SURFACE IMPOUNDMENTS:   GROUND WATER
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Total
I
10,200,003
1,143. ODD
666,750
476,250
7,429, 500
190,500
381,000
-
476,250
1,524,000
95,250
190,530
5,810,250
4,381,500
2,571,750
2,476,500
21,145,500
1,524,000
285,750
5,612,503
285, 750
857,250
285,750
1,333,500
3,333,750
476,250
?2, J83.7SO
2,381,253
381,000
825,000
855,000
1,620,000
1,905,000
1,619,250
20, 193, COO
5,905,500
1,809,750
225,647,750
-
285,750
95,250
3,905,25?
7,239,000
190,500
9S2,50'-i
95,250
1,905,000
33, 337, SOS
1,047,750
1,61-3,250
413,552, 300
II
2,100,000
199.500
270,750
2,620,000
11.E27.500
1.225,500
156,750
213,750
Srs.TSO
1,140,000
185,250
285,000
16,216, 500
7,053,750
1,026,000
32,532,750
4,146,750
38,19C,000
256,500
1,237,500
213,750
14.520,750
31 3 , 500
4,089,750
1,068,750
6. 241, 500
5,2P6,750
541,500
228,000
600,000
3,225,000
3,135,OOC
1,368,000
13,409,250
6C, 811, 750
14,135,750
584,250
54.064,500
199,500
399,000
220,000
640,750
46,341,000
1,439,250
e>9fc,250
171,000
J,4lr,750
<10_,755.000
513,000
3, 106,500
421,679,200
Total
12. 300, 000
1,342,500
937,500
3,296,250
19,257,000
1,416,000
537,750
213,750
1,032,000
2,664,003
2K . 500
475,500
22,026,750
11, 435, 250
3,597.750
35,009,250
25,292,250
39,714,000
542,250
7,05C,000
49e, 500
15,378,000
599,250
5,423,250
4,402,500
6,241,500
27,670,500
T, 922, 750
609,000
I, 425,000
4,080,000
4,755,030
•3, 273, 000
15,028,500
101,004,750
20,141,250
:,394,00i
283,712,250
199, 500
684,750
323,250
4,746,000
53,580,000
1,629, 750
i.f 50,750
266. 25R
3,315,750
74,:>=)2, SOO
1,560,750
4,725,750
635.231,500
Federal





1,416,000
537,750

-




11,425,250
3,597,750
35,009,25?


542,253

4 99, 5 X'


?,423,2ฃC'









1S,32ฃ,S--?

20,141,2-0







l.t>2ซ.~ =C
] ,650,? j?





96,911,2 10
State
12,400,300
1,342,500
937,500
3,296,250
19.257.00C


213,750
1,032,000
2,664,000
280, SOO
475,50.
22,026,750



25,292,250
39,714,OOC

7,050,000

15,37f,OOC
599,250

4,402,500
6.241.50C
27,670,500
2,922,750
609,000
1,425.000
4,080,000
4,755,000
3,273,000

101,004,750
_. .__ !
2,394,000
263,712,250
196,500
6B4. 75D
323,250
4,746,r-n
53,580,000


266.250
3,315.7fO
74,092,5-0
1,560,753
4,72S,T5C j
;36,320, 300
                                   IV-37

-------
                                     TABLE  40




              TOTAL  ANNUALIZED  COSTS  FOR  SURFACE IMPOUNDMENTS:  SAFETY
State
Alabama
Alaska
Arizona
Arkansas
Cal iforr.ia
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
1 ilinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Karoshire
New Jersey
Sew Mexico
New York
North Caro'lna
North Dakota
Ohio
O^lanoma
Oregon
Pennsvl var.ia
Rhode Island
Soutl. Carolina
Soutn Dakota
Tennessee
Texas
I'tal.
Vermont
Vlrfii.id
Washington
Wept Vi r^'inia
Wj sc.onฃin
WvoElr.R
Total
I
11 :,:ป->:
12, GOD
II
6', , 000
5,775
7,? 50 ?,838
;.25C ! 31,e~5
i
81,900 342,375
21,000 35,475
4 , 20 f
-
5,250
if, 300
1,050
: , i oo
64,050
4f,000
28,250
27, arc
233,100
16,800
3,150
64,050
3 , 1 50
9,450
3,150
14,700
36,750
5,250
?4e, 750
26,250
4 200
5,000
9,75',
18,000
210, OJC
17,850
222, ere
(i,i'j:
19. vs;.
r,53i,r,so
-
: , i so
1,053
4 ': . 500
79, MO
; , i . '•
4.53R .
6,186
16,068
33,000
5,363
6,2:."
4f9,42^
204,168
29,700
9ซ,73P
120, C38
1 ,105,500
7,425
35,650
6,1ฃS
420,336
9,0"':
118, 2E6
30,93fr
180,675
1 r-~ , IVt
15.C75
6,600
16.00C
93.75C
90,000
34, COO
TBt, J63
2,339,2Pt
4:r,csc.
i6,ฐ:3
1, 565,015
t, 775
11,550
6 , ', i 0
U, 33o
1,341,451
41 ,Df ?
10.500 | 2:, 21?
;.<-•:
21 , r C'
3 j7 , :. ^/.
11. ::;
1 7 , fe 30
5 , 1 54 , I'C'.-
4, ' "
4.,,P3t
Total
172, 500
lfc,375
15,188
86, ','25
424,275
56,475
8,738
6,1 BE
21,336
49, HOO
6,413
10,350
533.475
252,168
58,050
969,038
353.136
1,1 22,. '00
10,575
99,900
9,338
429,796
12,225
133,068
67,639
185,925
•Jo-, , -i-.R
41,925
10, ฃ03
27,:cr
103, so:
108,000
249, bOO
406,013
2,561, ฃ-88
477, l*c
3C,P.'3
4,PC/t , 575
5,77;
14,73'
~ ,<.- '•
454,fc3b
1,421.;50
43,761'
30,71?
e , no''
! Cl,63f<
l,17?,7f: j 1.54~,25C.
; 4 , f i •.
' ^, o::-.
i : , ii->. , ! f1
1
2f 40'1
107,77'
17,?. '.•,, itlfi
Federal
172.500

15,188







6,413






1,I22.3.?0









-

: 7 , o :• '













^3,". -



l, 54 ?.:•••


:. J:, -
State

.18,375

86,925
424,275
5ฃ,475
8.73B
6,151
21,33t
49,800

10, 350
533,475
252,168
58,050
969,035
353,133

10,575
99,000
9,336
429,788
12,225
133,088
ฃ7.686
185,925
3r:7,-cc
41,925
10,800

1C 3, 500
106,030
249,600
4C6.013
:, 561, ESS
477, 3 Pf
36, SP 3
4, 096, 575
5,7-5
14,700
7.C5C'
454.636
1.421.250
j
30,713
I
1
Cl ,t=3c

x. ,*<:•'.
ic"1 7 7 r.
14 ,4"0,fior
lactored by .75
                                          IV-38

-------
     (e)   Major Cost Factors

          The major cost  factors  for  surface impoundments are as
fol1ows:
           Group II costs are greater than  Group I  costs in total;
           however, considering numbers of sites, the average cost per
           site is greater for Group I than for Group II sites.
           The ground-water criterion will cause the greatest cost.
           Closure costs are mafnly attributable to the Criteria.
3.   Landspreading

     The  1 andspreading  data  base  was   derived  from  available
information  on  waste  categories   that  are  disposed of  by  land-
spreading.   At  the  present time,   several industries are known to
landspread   their   solid   wastes,   but  in   unknown  quantities.
Estimates  of the  total amount  of  wastes generated  is  known  for
all  categories;  however,  the composition of  that waste  and  the
amounts landspread are generally not known.

     Municipal waste-water  sludge  was  the only  category selected
for  impact  analysis because  it  is the  only one  for  which  there
are  national  estimates of  the  amounts  landspread.   Furthermore,
it  is  the only  category where  there  is  available  information on
waste  composition   and  quantities.    The  municipal  waste  water
sludge  data  base  was  derived  from an unpublished  EPA  report on
sludge disposal  practices  of 141 cities.  (Ref.  126).   This report
provided  data  on  (1)  the  amount  of  sludge currently  spread on
agricultural land,  and (2) the amount that in  the future will  not
be  permitted on   agricultural  land  (based on  the  recommended
reduction  in cadmium  levels  in   sludge  applied  to  food  chain
crops).   Because  the  sludge  represented in this  study  is  about
20% of  the  known  total  of sludge which is landspread,  a national
projection  for  total  tonnage  was   developed  hy  multiplying  the
                              IV-39

-------
study results by a factor of five, to derive the total  tonnage of
sludge which is landspread.

     Njo data  exist  on size or overall'  condition  of  these sites.
An assumption  was made that no  1andspreading  occurs  in  environ-
mentally sensitive areas.   Table 41  shows  the quantity of sludge
which  would  be  affected  by the  "operational controls"  and  the
amount  which  cannot  be landspread  at  10 and  20  metric  tons  per
hectare  per  year  (4.47  tons/acre   and  8.94 tons/acre,  respec-
tively)  for   the  various  maximum   annual   cadmium   additions
proposed.    The   rationale  for   selecting  these  two  application
rates   is   based  on  the   following   assumptions:     20 metric
tons/hectare/year of  a  typical  sludge  would  meet  the  nitrogen
needs  for  many  varieties  of corn and 10 metric tons/hectare/year
would  be near the lower  end of  the  economically  viable  range of
application  rates.    The  last two  columns  of Table 41  show  the
amount  of  sludge  which would be  1andspreadabl e and the amount of
sludge which cannot be landspread as a result of the proposed and
more   restrictive  regulatory  alternatives.     This  data  base
represents 58 cities  that landspread.
                               1V-40

-------
                                     TABLE 41
                             LANDSPREADING DATA BASE*
             (Quantity of Sludge Affected by "Operation Controls"
                           on Application of Cadmium)
Regulatory Alternative
(Based on Maximum Annual
Cadmium Addition)
Number of Sewage
Treatment Plants
That Can Meet The
    Criteria
 Quantity of
   Sludge
Landspreadable
Quantity
of Sludge
Eliminated
                                                            (drymetric tons/year)
Proposed
   2.0 Kg/ha cadmium limitation
-Applied at rate of 20 mt/ha
-Applied at rate of 10 mt/ha
1.25 Kg/ha limitation
-Applied at rate of 20 mt/ha
-Applied at rate of 10 mt/ha
0.5 Kg/ha limitation
-Applied at rate of 20 mt/ha
-Applied at rate of 10 mt/ha
More Restrictive+
-Applied at rate of 20 mt/ha
-Applied at rate of 10 mt/ha
Most Restricti ve+

50
54

47
50

41
45

41
45
None
159,140
172,645

151,110
159,140

125,378
153,851

90,155
144,905
None
19,170
6,205

27,740
19,710

44,348
16,973

88,695
33,945
All
*  For 58 cities, sources of information include consultation with major cities and
   EPA regional offices, construction grant design and planning reports, research
   reports and published articles.  Metric units in this table may be converted to
   English units, as follows:  1 Kg/ha = .89 Ib/acres, and 1 mt/ha = .45 ton/acre.

+  More restrictive would immediately restrict maximum annual cadmium addition to

   0.5 Kg/ha (rather than waiting until 1986 to implement); most restrictive is a ban
   on application to food chain crops.
                                        IV-41

-------
     (b)   Major Environmental  Benefits

          For  landspreading,  the     significant   environmental
benefits  of the Criteria include:
          Protection of  public health  by  preventing  additional
          increase  of  cadmium into  the  diet;  protects  the  food
          chain  from  unacceptable  levels  of   pesticides   and
          persistent organics.
          Protection of animals raised  for  milk from unacceptable
          concentrations  of  pathogens,  toxic  organics  or  heavy
          metals.
          Improvement in current and future ground-water quality.
          Reduction  of  bacterial   and  chemical contamination  of
          surface water.

     (c)  Unit Prices For Each Criterion

          Significant  environmental  impact  was  based  entirely
upon the  criterion governing  application  to  land used  for  food
chain crops.   Costs were based upon three factors:   tonnage,  an
assumption  regarding  the average   cost/metric  ton  for dewatering
and  landfill  disposal   ($78.00),  the time-phased  nature of  the
criterion and operational costs ($11.53/metric  ton).

     (d)  State- Stan da r d - In d u c e d ys,.  Criteria-Induced
          vs. Combined  Costs

          Based   on   the   costs   calculated   in   Appendix V
(Volume II),  25%  of  the  total  costs  were   attributed to  the
States.

     The combined  national  cost projection was $14.1 million,  of
which $3.5  million  was  the cost  induced  by  State  standards  and
$10.6 million  was  the   cost   induced  by   the  Federal  Criteria.
State,  Federal and combined regulatory  costs  for  each alternative
are given in Table 42.
                               IV-42

-------
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-------
   / (e)    Major Cost Factors

          Table  42  summarizes  the  increased 1andspreading  cost
for the  proposed and two more restrictive alternatives.   The  less
restrictive alternative  was  not included because  it  was  assumed
to have  no. increased cost.   This table shows the  increased  annual
operating  and  termination  costs   to  communities  at  a  sludge
application   rate   of   10  me trie   tons  per  hectare   per   year
(4.47  tons per  acre  per  year)  the  various  maximum annual  cadmium
additions  proposed.    The  increased  operating  and  termination
costs  were also  calculated  for  the  two more restrictive alterna-
tives.  These  costs  were then summed to  give the total  cost  (58-
city  data base).    The  total  cost for  the  58  cities  was  then
multiplied by 5 to nive a national  projection.   The national  cost
projection used  to  calculate the overall  Criteria-induced  costs
was  $14.1 million  (for  the  0.5  kg/ha   (0.45  Ib/acre)  maximum
annual  cadmium  addition at  a  10 mt/ha/yr  (4.47 tons/acre/year)
sludge application rate).

     Table 42 shows that approximately 60%  of the total  costs are
due to operational costs and the remaining  40% are due to termin-
ation  of  landspreading  practices.   The operational costs include
costs  for liming  the  soil,  analyzing  soils for  pH and  cation
exchange capacity, and monitoring cadmium content in the sludge.

     Major   costs   will   be   incurred   when   the   2.0 kg/ha
(1.8 Ib/acre) cadmium  limitation goes into effect.   Most  of the
landspreading  Criteria-induced   costs  can   be  attributed to  the
cadmium criterion since this will limit the amount of sludge  that
communities can apply and hence will increase operating  costs.

     Evidence  suggests  that  there  is not  a direct  correlation
between  the amount  of  sludge spread on agricultural land and the
incurrence  of  costs  to meet  the  agricultural   and  application
criterion.   Rather,  costs  are  solely  dependent  upon  the  cadmium
level  present in the sludge and upon the  application rate.
                              IY-44

-------
     As  pretreatment  regulations are  implemented  with the  effect  of
heavy metal  recovery,  lower cadmium  levels  will  result  and  the
economic  impact  of this  criterion  on 1 andspreading  will  corre-
spondingly decrease.

     In addition to the  above  costs,  there are other costs which
must be  borne  in  the  future  which cannot be  determined  at this
time.   These include  the impact of phasing out of ocean disposal
of municipal  sludge and the actions  taken by  States with regard
to   the   giveaway   or   sale  of  sludge  and  sludge-based  soil
conditioners/fertilizers.

     Based on  the  data obtained in the  141-city  survey,  615 dry
mt/day  (678  tons/day)   of  sludge  is   currently  disposed  in  the
oceans.    If  these cities  currently  ocean  dumping  wanted  to
landspread   one  half   of   their  sludge  on  food  chain  land,
51 dry/mt/day  or  17%  could  not economically  meet  the  cadmium
criterion.   If  each of the communities desired to landspread al1
of  its  sludge,  then 185 dry  mt/day  (204 tons/day)  or  30% could
not  economically meet the cadmium criterion.

     The  cost  impacts  on  bagged/giveaway/sale  programs are also
impossible to quantify.  This is due to the fact that there is no
practical way  to assure compliance with  the Criteria  by  the end
user.     Several   State   regulatory   approaches   are  possible,
including  restrictions  based  on  sludge  quality,  end user,  or
labeling  requirements.   The  impact  of each of these alternatives
varies  widely.   While  the  annual  cadmium application  will  have
little  direct  impact  on giveaway or  sale programs,  the severity
of  the  qadmium  restrictions  may  greatly affect  the   regulatory
approach  selected by the States.
                              IV-45

-------
D.   GENERAL BENEFIT DISCUSSION


     Data which  would enable  numerical  dollar benefits for  the

Criteria do not  exist, except  for  that presented  in  several 'case

studies of .ground-water contamination.   Table 43 presents  data on
well contamination  case  studies,  including  EPA documentation on

damage,* administrative*  and  avoidance* costs  incurred at  land-

fills  as  a  result of ground-water contamination.   (Ref.  10,  15,

16, 51,  134,  and 135).   In sum, these  costs range from $7,000 to

$2 million  per  site.   Estimates on corrective**  costs  exist  for

three  sites and  range  from $8 million  to  $25 million per  site

(Ref. 10 and 134).


     Total  national   benefits  for   ground  wtter   have   been

estimated, based on the following  assumptions:

          $8 million per site is required for corrective costs;

          $150,000  per  site is  required  for  damage,  avoidance,
          and administrative costs;  and

          From l%-5% of the total  number of landfills and  surface
          impoundments (890-4500 sites) require preventive action
          for ground-water  protection  and  0.5% of the total   (450
          sites) require corrective measures.
 *Damage Costs are costs of damaged products and equipment as a
result of corrision, staining or water pollution.  Admi ni strati ve
costs are investigative, monitoring, legal, and engineering design
costs.  Avoi dance c o s t s are the costs to provide both temporary
and permanent water supplies from an alternative source, including
bottled or tank water, and the cost to pipe in clean water or to
develop an upgradient (clean) water well.

**Corrective Costs are costs to render the contaminated water
usable, including retrofitting or removing the contamination
source (disposal site) and treating the contaminated water to
make  it potable.
                               IV-46

-------




























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     Using these conservative  assumptions,  the  following  ground-
water  benefits  derive  from  the  implementation  of  the  proposed
Criteria:
          The total  national  benefit for  damage,  avoidance,  and
          administrative   costs   ranges   from   $134 million   to
          $ 6 6 8 million.
          The  total   national  benefit  for  corrective  costs  is
          estimated at $3.6 billion.

     Other  obvious  economic   benefits  of  the  Criteria  besides
ground-water protection are difficult to quantify; these include:
          value  of shellfish, crabs,  and fish protected  by  the
          wetlands and surface water Criteria;
          value of property not impacted by flooding;
          value  of  reservoirs  and  recreational   surface  waters
          protected;
          value  of decreased  cleaning  and  property  repair  from
          fewer particulate and  corrosive gas emissions into the
          air;
          value  of  health  care  need   reduced   by   the  disease
          vectors,   fires,   gases,   bird   hazards,   and   access
          Cri teri a;
          value  of property  protected  from  damage by the gases,
          fires, and bird hazard Criteria; and
          value    of   crops    and   health   protected   by   the
          landspreading Criterion.

E.   SOCIAL/EQUITY IMPACTS SUMMARY

     Social  and  equity  impacts  were  analyzed  on the basis  of
available  data  on  municipal   landfills   and  State  solid  waste
disposal  regulations.   Unfortunately,  the lack  of comprehensive
data  on  the  exact  number of landspreading  sites  and  surface
impoundments  (See  Ref.  107  for the  most  complete  study to date.)
made   a  comprehensive  quantitative  analysis of   these  impacts
impossi ble.
                               IV-48

-------
    In  spite  of  these  limitations,   the  general  effects  of  the
Criteria on  several  special impact  groups  were  evaluated;  these
groups  include  rural   areas,   regions,   States,   and  specific
industrial  groups.

* •    Rural  Areas

     The  impact  on  rural  areas  was  evaluated  for  landfill
disposal only;  industrial  landfills and  surface impoundments do
not impact rural vs. urban areas per se.

     The Waste  Age  survey  reported  a  total  of  15,893  landfill
sites  nationwide.    The  survey  distributed  the sites  into  six
categories by  daily operating capacity,  with  11,165  (70%)  being
reported in the smallest (0-50 tons/day) category.  It is assumed
that these sites serve the smaller populations in the rural  areas
of  the  United   States  and  the   larger  sites  (greater  than  50
tons/day)  serve   more   urbanized   areas.     Some   rural   areas
undoubtedly  have initiated  regional  systems,  in which  case  the
solid  wastes  from  the  areas  would  be  disposed of in  a  larger
capacity site.

     Using the  average  daily  tonnages developed in  the costing
methodology   (Appendix V   (Volume  II)),   one   may   estimate  the
tonnage  of wastes  deposited in  small  sites  serving rural  areas.
Based  on  an   estimated  202  million  tons per/year  (total  wastes
disposed of in landfills), approximately 29 million tons/year are
placed  in  small, rural   sites.   This  means that only  14%  of  the
wastes are disposed of in 70% of the landfill  sites.

     While  most  of  the  costs  of  meeting  the  Criteria   are  a
function of  site size,   the  relationship  between upgrading  costs
and  site  size  is  not  directly  proportional.   For  example,
doubling the  site size will not result in a doubling of costs for
manpower and  equipment.   In effect,  larger sites--typically  found
in  urban  centers — are  able  to benefit  from  an  economy-of-scal e
                              IV-49

-------
approach to solid waste  disposal;  on  the other hand,  small  rural
sites  will  not  reap  the  benefits  of  economy-of-scal e.   As  a
consequence,   the  cost impact  per capita  or  per  unit of  waste
disposed will  be greater  for  small  landfill  sites  in  rural  areas
than for larger  landfills in  urban areas.

     Given the  relatively  low income  base  in many rural  areas,
expenditures  for additional  land,  major control features  (liners,
gas  control,  levees,  etc.),  and   equipment  may impose  a  severe
financial  burden  in  some communities.   Where  these costs  are
significant,   the communities  will  need to reassess their current
disposal  practices   and  the   alternatives  of  transporting  their
wastes and initiating larger  scale regional  solutions.

     Recognizing  the  potential   inequity,  Congress  provided  a
mitigating  factor   by   authorizing   special   funding  to  rural
communities in Section 4009  of RCRC,  which provides for up to  $25
million for the  purchase  of  landfill  capital  equipmment.

     Table  44,   which   identifies  the   total  and  per  capita
annualized  criteria-induced   costs,   shows  that the  more  rural
States  such as  Alaska, Maine,  and Utah, are  impacted  more than
most  "urbanized"   States.    However,  the   other   major  factor
affecting this cost increase  is the degree to which current State
regulations address land  disposal  practices.

     In  those States  which  have   adopted stringent regulations,
the impact of  the  Criteria is minimal, and therefore the greatest
iiii pact  generally   occurs  where  current  regulations  are  less
stringent than  the Criteria.   This factor probably impacts costs
more than does the rural/urban factor.
                              IV-50

-------
                          TABLE  44

INCREMENTAL  PER-CAPITA  UPGRADING AN!)  CLOSURE COSTS  FOR LANDFILLS
                (Criteria-Induced'Annuuliied  9agis  )
Scat*
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louie lana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri*
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakoca
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennesse
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Total
Criteria-Induced Costa
Upgrading
1.742,600
3, 561, 000
780,100
1,321,900
0
6,110,400
3,683,500
655,500
1,976,100
2,492,100
1.671,700
1,191,900
12,654,500
4.005,100
5,312,600
7,112,700
2,740,800
1,431,000
8,705,700
0
9,156,200
2f471,300
0
0
4,800
2,040,800
2.130,000
979,500
2,400
538,800
3,235.000
5,600,800
2,311.700
1.720,700
5,934,200
21,009,500
1,469,500
3,231.600
16,500
4,011.500
437,700
1.914,300
131,200
805,800
1,711,700
2,650,500
8,400
944,700
30,000
610,600
149,329,900
Closure
212,400
47,200
5,067,800
2,800,300
0
972,800
0
0
3,049,700
9,487,500
0
997,100
23,456,500
1,441,400
2,623.700
0
1.231.505
11,169.900
0
0
2,480,500
8.666,700
0
0
5,000
0
1,452,900
0
1,010,700
903,200
1,519,900
19,082,900
0
2,154,100
3,158,900
24,026,700
0
2.099,400
0
1,980,500
12,300
1,071,300
21,700
11,156,500
0
2,559,300
1.199.700
1,272.400
0
133,300
148,526.200
Total
1,955,000
3,608,200
5,847,900
4,122.200
0
7,083,200
3,683,500
655.500
5,025,800
11,979,600
1,671,700
2,189.000
36,111,000
5,446,500
7,936,300
7,112,700
. 3,972,305
. 12,600,900
8,705,700
0
11,636,700
18,138.000
0
0
9,800
2,041,800
3,582,900
979,500
1,013,100
1,442,000
4,754,900
24,683,700
2,311,700
3,874,800
9,093,100
45,036,200
1,469,500
5,331,000
16,500
5,992,000
470,000
2,985,600
152,900
11.962,300
1,711,700
5,209,800
1,208,100
2,217,100
30.000
744,400
297.356,100


3,444,164
300,382
1,770,900
1,923,295
19,953.134
2,207.259
3.031,709
548,104
6,789,443
'4.589,575
768,561
712,567
11,113,976
5,193,669
2,824,376
2,246,578
3,128,706
3,641,306
992,048
3,922,399
5,689,170
8,875,083
3,804,971
2,216,912
4,676,501
694,409
1,483,493
488,738
737,681
7,168,164
1,016,000
18,236,967
5,082.059
617,76,1
10,652,017
2,559,229
2,091,385
11,793,909
946,725
2,590,516
665,507
3,923,687
11,196.730
1,059.273
444,330
4,648,494
3,409,169
1,744,;37
4,417,731
332,416
202.4J5.416
Incremental Fer-Caplta Costs
Upgrading
0.51
11.85
0.44
0.69
0
2.77
1.21
1.20
0.29
0.54
2.18
1.67
1.14
0.77
1.88
3.17
0.88
0.39
8.78
0
1.61
1.06
0
0
0.001
2.94
1.44
2.00
0.003
0.08
3.18
0.31
0.45
2.79
0.56
8.21
0.70
0.27
0.02
1.55
0.69
0.49
0.01
0.76
3.85
0.57
0.002
0.54
0.01
1,84
0.76
Closure
0.06
0.16
2.86
1.46
0
0.44
0
0
0.45
2.07
0
1.40
2.11
0.28
0.93
0
0.39
3.07
0
0
0.44
0.98
0
0'
0.001
0
0.98
0
1.37
0.13
1.50
1.05
0
3.49
0.30
9.39
0
0.18
• • 0
0.76
0.02
0.27
0.002
10.53
0
0.55
0.35
0.72
0
0.40
0.73
Total
0.57
12.01
3.30
2.15
0
3.21
1.21
1.20
0.74
2.61
2.18
3.07
3.25
'1.05
2.81
3.17
1.27
3.46
8.78
0
2.05
2.04
0
0
0.002
2.94
2.42
2.00
1.373
0.21
4.68
1.36
0.45
6.28
0.86
17.60
0.70
0.45
0.02
2.31
0.71
0.76
0.012
11.29
3.85
1.12
0.352
1.26
0.01
2.24
1.47
                               IV- 51

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2.    Regions Impacted by Specific  Criteria

     Each of the Criteria  was  evaluated  to determine  if  it would
impact general  geographic  areas or segments of our society  more
than  others  (in   addition   to   the   obvious   rural   vs.   urban
dichotomy).    The  geographic  equity  impacts  were  found  to  be
related  to  the  environmentally   sensitive   areas   and  ground
water/surface water criteria.

     a,   Environmentally Sensitive Areas (ESA)

          Wetlands  are  most  prevalent in  the  low, coastal  areas
of  the  country.   Therefore,  the  environmentally  sensitive areas
criterion will  affect  Florida,  Louisiana,  South Carolina,  and
Georgia  more  than  other States  (Table 45).    In  much  of Florida
the wetlands criterion hampers conventional landfillinp at new or
expanded sites.
                               1V-52

-------
                            TABLE 45
           STATES WITH HIGHEST PERCENTAGE OF WETLANDS
        State                          Percent  Wetland
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
Florida
Loiii siana
South Carolina
Georgia
North Carolina
Arkansas
Del aware
Mi nnesota
Michigan
Mi ssi ssippi
Wisconsin
New Jersey
A1 abama
45.8
31.2
16.0
15.7
12.0
11.1
10.0
9.4
8.6
8.5
7.8
5.4
4.8
     Floodplains  are  most  prevalent  in the  States  east of  the
Mississippi,  and  in  Washington  and Oregon.   Although  no  exact
data are available,  it is possible that 25% of all  disposal  sites
in  these  States  lie  in  a  100-year  floodplain.  In  making  the
economic  impact  calculations,  it was  assumed that  25% of  all
sites in  States east of the Mississippi,  or  those bordering  the
Gulf  of Mexico,  Atlantic  Ocean,  and  Great   Lakes,  as  well  as
Washington and  Oregon,  lie  in  an  ESA;  and  5%  of  all  sites  in  the
remaining States (west of the Mississippi)  lie in  an  ESA.
                              IV-53

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     b.    Ground and Surface Water Criteria

          The ground-water and surface-water criteria will  result
in some  equity impacts due to climatic and hydrogeologic factors.

          (1)  Climate

               The  eastern,  and  particularly the  southeastern,
region of the  United  States  receives  a higher rainfall  and has a
lower  rate  of  potential   evapotranspiratipn  than  the  western
region.    As  discussed in Chapter  III,  the  potential  for ground-
water and surface-water  contamination  resulting  from leachate is
greatest in  areas where  average  annual  precipitation exceeds the
potential water  losses  by  evaporation  and  transpiration.   Such
areas are  generally found east  of the Mississippi  River  and in
the coastal  region of the Pacific Northwest.  About 71 percent of
the municipal  refuse  disposal sites  found  in the  United  States
are located in these water surplus areas.

     Although the production of leachate in  landfill  sites in the
southeastern  and Great  Lakes  regions  has  contributed  to  some
contamination  of  ground water   and  surface  water,  industrial
impoundments  in  these  regions   of   high   precipitation  are  of
particular concern.   Either through  faulty  design,  accident, or
failure, impoundments  containing  industrial effluents  have  been
responsible  for  contaminating ground  water  and  leaking  waste
waters into  streams,  lakes  or rivers.  Impacted  significantly by
the  proposed  ground-water  criterion   is  the  coal-producinq  and
steel-making region of this  country (Ohio, Pennsylvania, and West
Virginia);  the  combination   of high   precipitation  and  impounded
industrial  waste  poses a threat  to ground-water  quality in these
States.
                               IV-54

-------
          (2)  Hydrogeology

               There   are   many    factors    that    result   In
hydrogeologic  environments  unfavorable  for  land  disposal   of
wastes.   Such  factors  include  soil  porosity, thin  soil  cover,
shallow bedrock, fractured  and  jointed  bedrock of shallow depth,
and  a  high   water   table.    A   high  rate  of  precipitation  may
intensify already unfavorable site conditions.

     Although hydrogeologic environments vary widely from site to
site,  certain  regions of the United  States  are  characterized by
generally  unfavorable hydrogeologic  conditions.    These  regions
include areas  where  shallow bedrock  and  volcanic  terrain  pose a
threat   to   ground   water   and  consequently   complicate   the
construction  and  operation  of  landfills;  such  hydrogeologic
problems  are encountered  in  the  Pacific  Northwest  and  in  the
eastern Appalachian  regions.    In  these regions  additional costs
may  be incurred in  the  design  of  protective  features  to insure
protection  of  ground water  in areas  of  shallow  bedrock.   In
addition,  the  lack  of adequate cover  soil  in  such regions will
necessitate  the  importing of   cover,  thereby incurring  higher
costs  for landfill operation.

     Throughout much  of the Atlantic  and Gulf Coast Plain, a high
ground-water   table  is   encountered  within  permeable   sandy
deposits.   A difficult and  costly technical  problem  to  contend
with  in these  regions  is  the  isolation  of refuse  from  shallow
ground  water.

          (3)  Usage

               At  least  half   of  the  population  of  the  United
States  relies  on  ground  water  as  a  source of  drinking  water;
although  the equity  impacts  related  to  this  use  impinge  most
directly on  rural  areas, there  are  certain  regional  trends that
may be  noted.  The South, Midwest and West (with the exception of
                              IV-55

-------
Washington  and  California)   are  impacted  by  this  reliance  on
ground water  as  a  source of  drinking water.   Leading  the  States
that  rely  heavily  on  this  source  of  drinking  water  are  New
Mexico, Florida,  and  Mississippi ; .over 90%  of  the population  in
these  States   depend  on  ground  water  for  their  drinking  water
supply (Ref . 7 ).

     The  surface-water  criterion is  expected to have significant
economic  impact  on landfills and  impoundments  in  the  northern
Great  Lakes   region  (Ohio/Illinois/Michigan)  where  industrial
production generates  substantial quantities  of industrial  wastes
(some hazardous).  (Ref. 7).  Added costs may be incurred in this
region  to  implement   technology   required   to  protect  streams,
lakes,  and   rivers   from   the  adverse   environmental   impacts
associated with the disposal  of industrial wastes.

3.   States

     The  specific   social/equity  impacts  of  the  Criteria  in  a
given State depend on a variety of factors, including:

          the  climatic  and hydrogeological conditions;
          reliance  on   ground  water   for  drinking  water  and
          industrial  uses;
          the  current and past disposal practices;
          the  extent  of enacted State  legislation governing the
          disposal of solid waste;  and
          the   number,   size,   site   life,   and  environmental
          condition of  the existing disposal  sites.

     Climatic  and  hydrogeological  conditions have been discussed
above.  These factors significantly  affect the equity impacts in
specific  States, as summarized below and  illustrated in Table 46:
                               IV-56

-------
States  located  in  the  low,  coastal   areas  of  the
southeastern part  of  the country  (Florida,  Louisiana,
South  Carolina  and  Georgia)  will  be  significantly
impacted   by   the   environmentally    sensitive   area
criterion (Table 46).

States  located  in  the  eastern   and,  especially  the
southeastern  part   of  the  country receive  relatively
high levels  of  rainfall,  and  experience relatively low
rates  of  evapotranspiration.    As  a  result, both  the
ground-water  and  surface-water  criteria  will  have  a
substantial  impact  in these States.

States that  rely heavily on ground water as a source of
drinking  water   (New  Mexico,   Florida,  Mississippi,
Hawaii,  Idaho,  Nebraska and  Iowa)  will  be  impacted
significantly by the ground-water criterion (Table 46).

Highly  industrialized  States  in  the   northern  Great
Lakes  region  (Ohio,   Illinois,  Michigan)  and  in  the
Appalachians   (West  Virginia  and  Kentucky)  will  be
impacted considerably  by the  ground-water and surface-
water  criteria.    These States   generate  substantial
quantities   of  industrial   wastes  (some  hazardous).
Industrial  impoundments  and to some extent landfills in
these  States are expected to  require  upgrading  to meet
the  ground-water and  surface-water criteria.   Based on
the  data presented  in Table 46,  Ohio,  Pennsylvania, and
West Virginia  together  account  for 40%  of the economic
impact of the ground-water criterion.

Some Appalachian States (Kentucky, West  Virginia)  may
incur  additional  costs for the  ground-water criterion
due  to unfavorable  hydrogeologic conditions.
                    IV-57

-------
                             TABLE   4ซ
CRITERIA IMPACT BY STATE:  LANDFILLS, SURFACE IMPOUNDMENTS, LANDSPREADZNC
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
i Indiana
TOUR
Kansas
Kentucky
i Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Kebraska
Nevada
1 New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon

Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
\'e noon t
Virginia
Washington
Weปt Virginia
Wisconsin
Vyoalng
Total
ESA*
1,603.500
3,664,700
0
1,632,900
. 520,500
23,400
15,800
47.200
A, 642, 400
1,014,700
0
0
205,500
102,800
102,700
118,000
719,200
2,563,300
0
1,027,500
102,800
1,551,000
102.800
418,500
0
47,300
1,161,000
0
15,800
743,100
15,800
2,055,000
719,200
129,800
545,900
151,800
15.300
18,495,000
15,300
754,000
23,400
450,000
747,800
78,700
io:,soo
15.800
31 , 500
411,000
205, SOO
15,750
130.671,900
Surface
Water
41.250
748.S50
0
230,350
0
661,050
532.800
0
273.750
652,500
6S.250
375,600
631,500
0
454,050
924,750
563,400
0
1,008,600
0
969,000
3.011,250
414,600
1,087,200
519,150
312,450
508,950
362.800
156,450
435,900
780,300
0
0
151,350
0
1.931,100
0
1,070,700
0
0
81,600
133,950
4,299,900
75.300
72,000
0
1,431.600
197,400
3,433,100
170.700
28,781.050
Ground
Water
12,472,600
4,608,700
937,500
4,297,200
19,257,000
5,517,700
3,921,400
213,750
3,269,400
5,414,400
1,431,200
2,042.300
24,678,500
15,436,800
6,991,600
39,120,300
27,717,400
40,525,400
5,326,400
7,050,000
6.692,800
28,002,200
2,380,000
10,030,300
6,411,200
7,598.900
29.868,200
4,079,400
1,284,800
3,273.200
7,483,800
4,775,000
3,273,000
15,957,900
101,004,750
36,333,600
2.394,000
288,239,900
199.500
684 , 700
679,700
5,302,200
66,812.100
2,156,100
2,624,000
266.300
9 , 394 , 2OO
74,941,500
16,376,100
5,466.400
974,714,200
Air
0
0
0
0
0
0
296,250
152,550
0
0
108,742
0
0
0
0
0
0
132,990
368,903
0
0
0
0
0
0
0
0
0
0
0
302,017
0
0
72,502
1,508,587
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2,942,541
Disease
Vector
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
Safety
1,915.400
3,074,500
795,300
1,209,900
424 , 300
2,054,600
11,300
509,200
21,300
2,541,900
418,700
1,202,300
13,237,700
255,800
1,967,700
3,030,600
3,093,900
2,152,600
3,563.300
99,900
2,972,200
8,555,600
12,200
4,498,900
72,500
2,227,700
2,491.500
1,021,400
13,200
175,900
3,036.500
5,708,800 -
2,561.300
1.097.800
6,955,300
5,345,300
1.491,100
7,328,200
7,000
3.375.000
457,600
2,369.100
1,421,200
323,300
769,200
2,656.500
70,200
2,541,900
56,400
718,400
111, 516,200
Closure
470,175
400,200
5,067,825
10,450,050
0
2, 45:, 875
0
0
8,252,850
38,943.600
0
3,874,800
49,145,775
2,809,650
5,870,925
0
1,672,725
15,633,675
0
9,272,400
5,088,750
38,145,525
6,319,575
18,640,200
1,168,875
0
5,922,825
0
2,005,500
7,453,575
6,655,950
36,695,925
0
4,751,325
4,498,050
46.886,250
0
9,735,450
0
3,237,300
284,100
2.334,000
4,065.600
27,381,600
154,050
4,283,025
2.281,800
4,911.300
0
785,625
398,003,700
Food
Chain


















































I4,lซ0,000d
$ closure cent*  for surface Impoundment*.
 costs ซrซ for landfill* only.
                                        C0thซr
                                                    total for utlmw.1 projection.
                             IV-58

-------
    The  next  two  factors,  current and  past disposal  practices  and
enacted  State  legislation,  will   obviously  have a  considerable
impact  on  the   incremental  cost  to  the  State  of  meeting  the
Criteria.   Those  States  whose  disposal  practices and solid waste
legislation  reflect  more  concern  for  environmental  protection
have  already  made  upgrading  expenditures  and  therefore  are
expected  to  have a smaller  incremental  cost to  comply  with  the
Criteria.

     These  generalizations   are  illustrated  in  Table 47,  which
presents  landfill  cost  per  ton  on  a  state-by-state  basis,
differentiating  between  Criteria-induced and combined  cost-per-
ton  increases.   For all  the States,  the  average upgrading cost
per  ton  due  to  the Criteria is $0.66, slightly  less  than  50% of
the  combined cost-per  ton  average  of  $1.19.  Eight of the States
will incur no Criteria-induced cost-per-ton increases since these
States  already  have  regulations  equivalent  to  the   proposed
Criteria.   On  the other  hand,  in  nine  of  the  States,  Criteria-
induced  costs  constitute  over  90%  of  the   total   incremental
upgrading  costs  for   landfills.    The  lack  of  environmentally
oriented  solid  waste  legislation  in  these  States is responsible
for  the  greater economic impact  of the Criteria  on incremental
upgrading costs for landfills.

     In  the past,  the  lack  of  adequate financial  resources  in
some  States  has  hindered  the  development  and  implementation  of
progressive solid waste disposal legislation.   An important goal
of  RCRA  is  to  redress  this  inequity,  thereby  facilitating  the
upgrading  of  disposal  practices  in  these  States.    Under  RCRA,
special communities with  low populations and high levels of solid
waste  disposal   are  eligible  for  grants  to  be used  for  the
conversion,  improvement,  consolidation  or  construction  of  solid
waste disposal facilities (Ref. 6).   Such  grants are designed to
promote  environmentally  sound  disposal  practices  throughout  the
country.
                               IY-59

-------
                                TABLE  47




INCREMENTAL CRITERIA-INDUCED AND COMBINED  UPGRADING  COST /TON - LANDFILLS
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennesse
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Jyoralni?
Total
Total
Tons/tear
2,756,000
1,138,300
1,240,2CO
1,443,000
12,305,000
2,152,800
1, 71b,GOO
1,170,000
6,934,200
Criteria Induced
Upgrading
Costs
1,742,600
3, 561,000
780,100
1,321,900
0
. 6,110,400
3,033,500
655,500
1,976,100
7,776,600 | 2,492,100
798,200 1,671,700
2,470,000
14,008,800
2,940,600
2,197,000
2,210,000
4,321,200
1,443,000
1,250,600
2,269,800
5,319,600
25,313,600
1,848,600
1,191,900
12,654,500
4,005,100
5,312,600
7,112,700
2,740,800
1,431,000
8,705,700
0
9,156,200
9,471,300
0
5,319,600 0
2,389,400 4,800
777,400 2,041,800
1,214, 200 I 2,130,000
514,800 979,500
663,200 2,400
6,026,300
538,800
1,474,200 3,235,000
14,073,600
3,117,400
5,600,300
2,311,700
613, 600 i 1,720,700
11, 975, 600 | 5,934,200
18,374,200 21,009,500
1,188,200
5,194,300
364,000
9,003,800
826,800
7,126,600
9,770,300
4,212,000
278,200
4,105,400
3, 923, -00
1,045,200
7,904,000
W6,*00
227,312,300
1,469,500
3,231,600
16,500
4,011,500
457,700
1,914,300
131,200
305,300
1,711,700
2,650,500
8,400
394,700
30,000
610,600
,149,329.JOO
Cost/Ton
Increases
0.63
3.U
0.63
0.92
0
2.84
2.15
0.56
0.28
0.32
2.09
0.48
0.90
1.36
2.42
3.22
0.63
0.99
6.96
0
1.72
0.37
0
0
0
2.63
1.75
1.90
0
0.09
2.19
0.40
0.74
2.80
0.50
1.14
1.24
0.62
0.05
0.45
0.55
0.27
0.01
0.19
6.15
0.65
0
0.95
0
1.99
0.66
Combined
Upgrading
Costs
1,956,500
7,576,200
780,100
2,553,700
0
6,771,500
4,216,300
655,300
4, -'.87, 300
5,915,000
1,737,000
3,134,300
15,937,700
4,005,100
5,766,700
7,112,700
5,779,400
2,242,400
9.714,300
0
10,125,200
25,062,100
2,195,300
10,170,300
2,532,700
3,711,700
4,256,700
2,438,900
334,700
2,822,900
7,419,100
5,600,800
2,311,700
1,572,100
5,934,200
22,9iC,600
1,469,500
7,330,000
16,500
4,011,500
695,700
2,604,500
17,563,200
331,100
1,753,700
2.&50.500
7,513.500
2,107,600
18,238.400
1.521, "00
271,7.22.700
Cost/Ton '
Increases
0.71
6.65
0.63
1.76
0
3.14
2.45
0.56
0.54
0.76
2.17
1.26
1.13
1.36
2.62
3.22
1.32
1.55
7.77
0
1.90
0.99
1.13
1.91
1.05
4.77
3.99
• 4. S3
1.25
0.47
5.03
0.40
0.74
3.05
0.50
1.24
1.24
1.50
0.05
0.45
1.08
0.37
1.79
0.21
6.41
0.65
1.33
2.01
2.31
4.96
1.19
                               IV-60

-------
    It 1s  beyond  the scope  of  this report to  identify  the  specific
inequities that may  result  from  State  disposal  practices and the
inadequacies  of  environmentally   oriented  legislation.    Data  on
such  inequities  will be  available only  after  the  inventory  of
open dumps has been completed.

     To adequately assess the  last factors  identified as impact-
ing  on  States — the  number,  size,  site  life,   and  environmental
conditions—obviously would  require complete  and  specific  data
which is not available.

 4.  Industries

     As  noted in  the  discussion  of  regional  and  state  equity
impacts,  highly  industrialized   regions  of  the  country  (Great
Lakes,  Gulf  Coast,  and  Mid-Atlantic  regions)  are  expected  to
incur significant economic impacts as a result of the Criteria.

     The lack of a national  inventory of industrial  land disposal
sites precludes a comprehensive assessment of the economic impact
of the Criteria on industries.  Indeed, most industrial  sites are
located  on  private  property;  hence   their  location   or  even
existence, is  rarely  recorded  with public agencies (Ref. 7).  In
spite  of  the  lack  of  complete  data  on  industrial  sites,  some
general equity impacts may be noted.

     In analyzing the effects  of  the  Criteria  on industries, the
need  to  upgrade  existing  industrial   surface  impoundments  was
identified  as  contributing  the   major   portion  of  the  State-
standard-induced annualized  costs.   As shown in  Table  48,  costs
to upgrade surface impoundments comprise  68%  of the total State-
standard-induced costs,  and  59% of the combined costs (Criteria-
induced plus State-standard  induced).
                              IV-61

-------
                            TABLE 48

          IMPACT OF  INDUSTRIAL SURFACE IMPOUNDMENTS ON
  STATE-STANDARD-INDUCED AND CR I TER I A-INDUCED ANNUALIZED COSTS
                             Disposal  Method
                                           All          Percentage
                         Surface         Disposal         Surface
Costs                  Impoundments      Methods       Impoundments
                         (millions of dollars)
State
Combi
-S
ne
tandard-Induced
d
7
9
78
77
.7
.7
114
166
7.
1.
5
1
68%
59$
     A recent study of surface impoundments--Surface Impoundments
and  Thei>   E f f e c t  0ฃ  Ground   Hater   i_ฃ  the   United   States
(Ref. 107 )--provi ded ttie basis for an assessment of the impact of
the   Criteria   on   industries   that   dispose   of   wastes   in
impoundments.

     In developing  the  economic  impact  data, it was assumed that
all  impoundments  fell  into  two  groups  based upon  the nature of
the  industry and  the  size  of the impoundment site; site size was
the  major distinauishing factor  between  the two groups.  A total
of 73,235 surface  impoundments fell  into the following
categories:
                               IV-62

-------
Group I (20 hectares (50 acres)/site)*

     Coal  and Other Mining
     Paper Products              ^  9,082 sites
     Utility and Other Services

Group II (3 hectares (7.5 acres)/site)**

     Oil and Gas
     Food Products and Textiles  ^64,153 sites
     Chemicals and Refining
     Miscellaneous Mining
 *0ne 20-hectare (50 acre) impoundment per site.

**Three 1-hectare (2.5 acreh'mpoundments per site,
     The  annualized   (combined)  costs of  the proposed  Criteria
impact  Group I  and   Group  II   industrial   impoundments   almost
equally;  Group  I  industries will  receive  47% of  the  annualized
combined costs;  Group II, 53%.

     Table  49  gives   the  distribution  of  costs  to  particular
industries.   As noted,  the Criteria  affect the  larger  Group  I
sites only  slightly  less (47%  of  the combined  annualized  cost)
than the  smaller  Group II  sites (53% of the  combined  annualized
cost).
                               IV-63

-------
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     The  most   affected  industries  are  (in  order  of  combined
annualized cost):

     oil and gas         $404 million  (68% of  all  sites)
     coal  mining         $397 million  (19% of  all  sites)
     misc. mining         $  42 million  (1.9% of all  sites)
     utility service     $  35 million  (1.6% of all  sites)
     food products       $  11 million  (1.9% of all  sites)
     chemical  products   $   7 million  (0.2% of all  sites)
     The  causes  of  for  these  combined  (State-standard-induced
plus Criteria-induced)  costs are three criteria:

     ground water                      $835.2 million       85%
     environmentally sensitive areas   $125.1 million       13ซ
     safety                            $ 17.4 mill ion        2%

         Total                          $977.7 million      100%
     Thus,  the  criterion  with  major   national  impact  on  the
combined  costs  of  the  Criteria  is  clearly  the  ground-water
criterion as it applies to surface impoundments.   However,  if one
compares  only  Cri teri a-induced  c o s t s,   the  ESA  criterion  is
actually  more  expensive  ($99.2  million)  than the  ground-water
criterion ($96.9 million), as shown below:
                              IV-65

-------
Criterion
Cri teria-Induced
	Costs	
(millions of $)
 * of
Criteria-                   % of
Induced                   Combined
 Costs    Combined Costs   Costs
          (mil 1 ions -of $)
Ground Water        $ 96.9
Environmentally     $ 99.2
  Sensitive Areas
Safety              $  2.9
                       48.7$
                       49.8$

                        1.4%
              $835.2
              $125.1

              $ 17.4
             10.0%
             10.1%

              0.3%
   TOTAL
    $199.0
100%
$977.7
20.4%
     Consequently,  the  environmentally sensitive  area  criterion
is   a    significant   Federal   regulatory   change  for   surface
impoundments.

F.   IRREVERSIBLE AND IRRETRIEVABLE; SHORT AND
     LONG-TERM IMPACTS

1.   Nature of Impact

     Since  the  proposed  Criteria  aim at  environmental  improve-
ment, it  is  useful  to examine them in terms of the nature of the
impact  prevented  or reduced  in magnitude.   Table 50  shows  these
impact reductions.
                               IV-66

-------
                            TABLE 50
                 ENVIRONMENTAL IMPACT EVALUATION
                            Duration of
                            Env.  Benefit
                            Short-
                             Term
Long-
Term
   Nature
Irrever-
 sible
Envi ron.
Changes
Prevented
                                                       of  Impact
Irretri ev-
   able
 Commi tment
of Resources
  Required
Criterion

1. Environmentally
   Sensitive Areas
   a. Wetlands
   b. Floodplains
   c. Permafrost
   d. Critical Habitats
   e. Sole-Source Aquifers

2. Surface Water

3. Ground Water
   a. Drinking Water
   b. Other Water Supply

4. Air
   a. Municipal Wastes
   b. Rural Wastes

5. Land Application
   a. Heavy Metals
   b. Pathogens
   c. Pesticides

6. Disease Vectors

7. Safety
   a. Gases
   b. Fi res
   c. Bird Hazard
   d. Access
             YES
             YES
             YES
             YES
             YES
                YES
                YES
             YES
             YES
             NO
             NO
           YES(?)
             NO
             YES

             NO
             NO
             NO
             NO
             NO
                          YES
                YES
                YES
                YES
                YES
                YES
                YES

                YES
                              IV-67

-------
     a.    Irreversible Changes

          Solid waste disposal  facilities can  cause  irreversible
environmental  changes.  The Criteria  would  eliminate  such  impacts
on environmentally sensitive areas; wetlands,  floodplains,  perma-
frost areas, critical habitats and recharge  zones  of sole-source
aquifers; on  ground-water  supplies  for drinkino water  and  other
uses; and on  the  presence  of heavy metals  and pesticides  in soil
used for producing food chain crops.

     b.    Irretrievable Resource  Commitments

          To  be  implemented  fully,   certain  of   the   Criteria
require   irretrievable resource  commitments  of land, energy  and
materials.    These   Criteria  include  those   for  environmentally
sensitive  areas  (especially  for  alternate   sites   for  disposal
facilities in wetlands and floodplains), surface water (treatment
plants),  ground  water  (lining,  collection  and treatment),  air
(greater use of land  for disposal),  land application (greater use
of  land  or  pretreatment   for   heavy  metals  in  sludge),  gases
(collection  and  treatment), and bird  hazard  (less  advantageous
locations for disposal sites).

     The economic impacts of these irretrievable resource commit-
ments are given in Section IVB.

2.   Duration of  Impact

     The  proposed   Criteria   will   have   certain   environmental
benefits  which  are  permanent  and others  which are  only  short-
term.    Short-term  benefits  are the  result  of changes  in  waste
disposal  methods  to  eliminate  short-term or  reversible  adverse
impacts.    There  are  also short-term and   long-term  economic
impacts,  discussed   above  in  Section  IVB.     Long-term  impacts
result  from  preventing irreversible   environmental  changes.   All
of  these  impacts  are  shown in Table 50.
                              IV-68

-------
G.    ENERGY AND MATERIAL USE

     The  Criteria   may  initially  cause  displacement  in  direct
energy use  for solid waste management  by  increasing  tran.>porta-
tion energy requirements  for  some  persons,  groups,  agancies,  and
companies engaged in  solid  waste  transport,  while decreasing  the
energy requirements  for others.   The net result could  be  a  slight
increase  nationally,  but  this is impossible to  quantify.   There
also will be direct  increases  in energy use through  the increased
energy  requirements  for  site  preparation  and  operation  and
through  the  energy  inputs to create  the  materials  and equipment
used.    However,  it  is  also  impossible  at   this  time  to  give
quantitative estimates of this impact.

     On  the  other  hand,  energy production  may  increase  in  two
ways:

     (1)  with  the   likelihood  of  larger,  more  scientifically
          designed  landfills  and  as   a  result  of  the  Criteria
          requirement for control of  explosive gases,  there will
          be increased  direct  energy  (methane  gas)  recovery from
          landfilIs;
     (2)  the  increased costs  of  land disposal will increase  the
          economic  viability  and,  therefore,   the amount of off-
          site   resource  recovery,   for   both  materials   (with
          attendant  energy savings)  and direct energy  production.
     In  addition,  landspreading  may  have  a  positive  energy
effect, since  the nutrients in  the  sludge are  used  in  place  of
more energy-expensive  artificially  created fertilizers  and  soil
conditioners.
                               IV-69

-------
     Recycling  1s  typically  less  energy  Intensive than  virgin
material production,  when all the stages of material acquisition,
transportation,  and  processing  are  considered.   One  study,  for
example, estimates that  for  five metals evaluated (comprising 80
to  90 percent  of  energy  consumption  in  all   primary  metals
industries),  secondary  metal  recovery  required   only  1.5  to  31
percent of  the  energy  per ton of product  required  by  the virgin
counterpart  material.     Other  work  also  suggests  substantial
energy savings from paper and glass recycling.  Contract research
projects in progress will provide a considerably  firmer basis for
developing quantitative perspective in this area.  (Ref. 137).

     Currently,  the   disposal   of   solid  wastes   is   done  in
conformance  with  State   permit  requirements   which vary  widely
across  the  fifty  States.    In  States  which have  very  lenient
permit  requirements  or  in  which requirements are  not  enforced,
open  dumping and  open  burning  of  wastes  are practiced because
they are the cheapest disposal options.  The Criteria will  impose
nationwide  requirements   to  cover  and  under   certain  conditions
line  landfills,  and  treat the leachate  emanating from  the fill;
stop  burning;  insure  proper  grading  and runoff; control disease
vectors;  and  control  1andspreading  of wastes.    All   of  these
measures will  add  to  the cost  of  disposal,  which  will  have the
net   effect   of  making   resource   recovery   more  economically
attractive as an alternative.  It is  very difficult to assess all
of  the factors  which contribute   to  a community's  decision to
recover  materials  or  energy.    However,  local   governments  and
private  business  usually require  the   process  chosen  to  be at
least  as .cheap  as  the  prevailing disposal options, including all
economic and  financial  incentives  offered by  government.   If the
cost  of the  prevailing  disposal  options increases  significantly,
more  and  more decision-makers will  choose the resource recovery
option.  Therefore,  the  net effect of these Criteria on resource
recovery will  probably be to enhance its economic  feasibility in
the near future.
                               IV-70

-------
1.   Energy Recovery*

     a.    Theoretical Potential

          In  1973,  approximately  135  million tons  per year  of
residential and commercial  solid  waste  were  generated.   About 70
to 80 percent  of  this waste  was  combustible, having an  average
energy content of about 9 million British thermal  units  (Btu)  per
ton.    Theoretically,  if  all solid  waste in  the U.S.   has  been
converted into energy in 1973, about 1.2 quadrillion  Btu per  year
would have  been  generated.    This is equal  to more  than  564,000
barrels  per  day  of  oil   equivalent   (B/DOE)**  or  206 million
barrels  per  year  of  oil   equivalent  (B/YOE).**    Growth   in
population  and  per  capita   waste generation  would   cause  these
figures  to  increase  to 1,440 trillion  Btu  per year  by  1980,  or
about  680,000 B/DOE  or  248 million  B/YOE.    These  and  other
findings are summarized in Table 51.

     b.    Available Potential
          Not all waste is available for energy recovery.  Energy
recovery systems require  large  quantities  of waste (at least 200
to  250  tons  per day)  delivered  for  processing  at  one  site  in
order  to  achieve  economies  of  scale.   For this  reason,  energy
recovery appears feasible only  in  more  densely  populated areas,
such  as  most Standard  Metropolitan Statistical  Areas  (SMSA's).
If  energy  recovery  has  been  practical  in  all  SMSA's  in  1973,
almost 900 trillion Btu would have been recovered.  This is equal
  Source of this discussion is Ref. 138,
**Explained in Table 51.
                               IV-71

-------
                       TABLE 51 (Ref.  138)

  ENERGY POTENTIALLY RECOVERABLE FROM RESIDENTIAL AND COMMERCIAL

                         SOLID WASTE*


                      1973                           1980 '
               Btut     B/DOE*   B/YOEง    Btu        B/DOEB/YOE
           (trillion)(thousand)(million)  (trillion)(thousand)(m1111on)

Theoretical    1,194      564      206      1,440       680      248
Available1'      899      424      154      1,085       512      187
Projected
  recovery       --       —        --        85        40       15
*These  estimates   are   a  function  of  (1)  population;  (2)  the
average  amount   of   residential   and   commercial   solid   waste
Generated  per  person,   and  (3) the  energy  content of  the  waste
(4,500 Btu per pound).   The  heatling value of 4,500 Btu per pound
(9 million Btu per ton)  is  generally accepted for "as received,"
unprocessed  waste  as   delivered   by  a   collection  truck  to  a
processing or disposal  facility.

   t Btu:  British thermal  unit.

   * B/DOE:   Barrels  per day  of  oil  equivalent.   (Assuming  5.8
     million Btu per  barrel  of oil and 365 days per year.)

   S B/YOE:  Barrels  per year of oil  equivalent.

   II Based   on   all    Standard   Metropolitan  Statistical   Area
     (SMSA's).

NOTE:  Different waste  processing  methods have different recovery
efficiencies.  For example,  a  shreddinq/air classification waste
processing system  loses  some potential  energy by  removing heavy
combustibles  from  the  fuel  fraction,   while  high-temperature
incineration  with  no  prio   classification  would  lose far  less
potential  energy.   However,  no adjustment was made  to  allow  for
such  processing  losses  or   energy  conversion efficiencies  (of,
say, steam or electricity)  because  no  prejudgment can be  made as
to  which  energy  recovery  method would be  used  in  any  given
situation.
                               IV-72

-------
 to  more  than 424,000 B/OOE,*  or  154 million B/YOE.*   By  1980,
the energy potentially recoverable  from  the  SMSA waste  stream  is
projected to be about 1,085 trillion Btu  per  year, the equivalent
of more than 512,000 B/DOE, or 187 million B/YOE.

     c.   Impact on Energy Demand

          The quantity of energy potentially  available  from  the
waste  stream  of   more   densely   populated   areas  (SMSA's)   is
significant.   For  example,  the  424,00  barrels  per  day of  oil
equivalent that was available in SMSA's in 1973 is equal  to:

     4.6  percent  of  fuel   consumed  by  all  utilities  in  1973
     (9.2 million B/DOE)

     10  percent  of  all  the  coal  consumed  by utilities  in 1973
     (4.1 million B/DOE)

     28 percent  of  the  oil  projected to be delivered through  the
     Alaskan pipeline (1.5 million B/DOE)

     1  percent  of  all  energy  consumed  in  the  United  States  in
     1973 (35.6 million B/DOE)

     The energy  recoverable  from  SMSA's  can  light every home  and
office  building  in  the  country  and  is  equivalent to  twice  the
gasoline  savings   estimated  for   the   55-mi1es-per-hour   fuel
conservation program in 1973-74.

     Perhaps more  significant is the  impact on  energy  needs  of
individual   users.    For  example,   many  industrial  plants  can
generate at  least  half  the  process  steam  they use from  solid
waste fuel,  thus reducing dependence on fossil fuels.
^Explained in Table 51.
                               IV-73

-------
    d.     Projected Implementations of Energy  Recovery  Systems

     Based on energy  recovery  systems  existing  or planned  at the
present time,  it  is projected that by 1980 almost  30  cities and
counties around the country should be  operating  the equivalent  of
about   thirty-six   1,000-ton-per-day   plants,   recovering   an
estimated  85  trillion   Btu   per   year,   or   40,000  B/DOE,   or
15 mill ion B/YOE.

2.   Material Recovery*

     Detailed  analyses  of  the  practical  quantitative  potential
for  resource  recovery  to  save natural virgin  resources  have not
yet  been  developed.   However, some preliminary  evaluations with
respect  to  resource  recovery  potentials  have  been  made  that
suggest  the   order  of  magnitude  of  virgin  material   savings  at
i ssue.

     Table  52  summarizes  the recyling  potentials for  selected
materials in post-consumer municipal waste in relation to certain
measures  of  U.S.   material  consumption.   The  estimated  recovery
potentials   for   the   individual   materials   are  based  on  the
following assumptions:   (1)  95 percent  of the waste generated is
collected, either through mixed-waste collection  or  specialized
source-separated   collection   systems;   (2)  70  percent   of  the
collected  waste  is  processed  for recovery  of  specific  material
and  energy  values  (roughly eauivalent to the  waste  collected  in
U.S.  SMSA's   as   defined  by  the  U.S.  Department of  Commerce);
(3) with  respect  to paper, it is  assumed that only 40 percent of
SMSA  collected   weight  is  processed  for  fiber  recovery;  and
(4) with   respect  to   the  material  actually   processed  for
recycling,  final  material  recovery  efficiency  is assumed  to  be
80 percent.  Although crude, these assumptions are consistent
*Source of this discussion is Ref. 137
                              IV-74

-------





































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IV-75

-------
with current knowledge of the waste stream itself and current (or
soon-to-be-available) technology for material  recovery.

     The  final  national  recovery  ratios  themselves--53 percent
for minerals and  21  percent  for total  paper—represent practical
maxima  from  a  technical  standpoint.   They assume,  for example,
the existence  of  large-scale  recovery  plants  serving the entire
U.S. SMSA  population,  and they also assume implicitly a signifi-
cant   expansion   in   material-user-industry  capacity   in   most
instances.   They  are  thus  obviously  not  recovery  values  that
could  be   implemented  or achieved  in  the  near  future  under any
circumstances  and  should not  be  so  interpreted.   They  represent
what  could conceivably  be  achieved with current  or near-future
technology  under  a  very  vigorous implementation  program.   Note
that because they are based on current waste flow,  they represent
net additions to any recovery  already being achieved.

     Thus,  for  example,  if  the  incremental  recycle quantity has
been  achieved  in  1971   for  iron,  then  assuming  the  same   total
demand  for the  material, it  would have  been   possible  to  have
supplied  about  7  percent of  this demand from the  municipal  waste
stream  rather  than from  domestic  or imported virgin  sources.  For
the  six  materials  shown, the  percent of  U.S.  consumption that
could  have been  supplied from  post-consumer  wastes is  seen  to
range   from  a   low  of   3 percent  for  lead  up  to  as  much  as
18.9 percent for paper  and paperboard products.

     The  set  of ratios  in  the  next-to-last line  of Table  52 is
most  indicative  of  U.S. natural  resource  conservation benefits
because  it relates  to  U.S.  primary  production  based on domestic
ore {or forests, in  the  case of  paper).  The potential  reductions
in  primary production  from  virgin  domestic resources could have
amounted   to   10.3 percent   for   iron,  9.4 percent   for  copper,
6.8 percent   for   lead,   21.5  percent   for   paper,   and   over
100 percent  for  aluminum and  tin.   In  the  case  of  aluminum, for
which  90  percent  of  U.S. primary production is  based on imported
                               IV-76

-------
bauxite and alumina,  it  would  have been possible in principle to
have reduced the  aluminum  industry's  demand for domestic bauxite
to  zero  and  also  to  have  reduced imports.   In  the  case of tin,
where the U.S.  produces  negligible quantities of ore and refines
less  than  1   percent  of  our  virgin  consumption,  the  total
substitution  would  necessarily   have   to  come  entirely at  the
expense of imports.

     Two  principal  conclusions emerge  from these  fioure?.   The
first  is  that  recycling post-consumer  waste  materials  is  not  a
panacea  in  the  sense  that it cannot  be  expected  to  supply  the
majority  of  the  Nation's  raw material  demands.   On  the  other
hand,  the  substitution possibilities,  both with  reaard to  total
consumption  and   domestic  virgin   material   supply,   are  not
insignificant.

     In addition to these direct material  resource savings,  there
will also  accrue  further  net  indirect savings  in  the  form  of
reduced  capital  equipment  and other  material  input requirements
in  the  mining,  ore  reduction and  beneficiation,   and  smelt inn
sectors  of  the  virgin  mineral  industries,  as  well  as  similar
reductions  in  the  tree  harvesting,  wood  preparation,  and  wood
pulping  segments  of  the  pulp  and  paper industry.  No attempt has
yet  been  made  to  evaluate these  in  quantitative  terms.   There
will be,  of  course,  some  offsetting  new  capital  goods require-
ments  for  processing  the  waste  materials,  but  these  generally
appear  to be substantially less than those for virgin material.
                              I V - 7 7

-------
                           REFERENCES*
1.
2.
3.
4.
5.
6.
7.
8.
9.
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                               V-l

-------
10.   Shuster,   Kenneth   A.      Leachate   damaoe:     a   national
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13.   Feldsman,  Jim.   Ground  water pollution  standards  chapter.
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14.   Geswein,  Allen  J.    Liners  for  land disposal  sites;  an
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15.   Shuster,  Kenneth A.  Leachate  damage  assessment; Case study
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16.   Shuster,   Kenneth   A.    Environmental  impact  of  leachate.
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17.   Office   of   Solid   Waste  Management  Programs.    Decision
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18.   Proceedings;   Conference   on   Geotechnical   Practice   for
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19.   Proceedings;  Fourth  National Congress  on Waste Management
     Technology    and  Resource   &   Energy   Recovery.     Atlanta,
     Georgia,    November 12-14,   1975.       U.S.    Environmental
     Protection   Agency,  Washington,   U.S.   Government   Printing
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20.   Soil Conservation   Society  of America, Land  application  of
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21.   Land  Application   of   Residual   Material;   Proceedings
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     of Civil  Engineers.  18 3 p .
                               V-2

-------
22.   Smith, F.A.   Quantity and Composition of post-consumer solid
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23.   Boyd, G.B. and  M.B, Hawkins.   Methods of  predicting  solid
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24.   American  Chemical  Society.   Solid  wastes.   An Environmental
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25.   National   Environmental  Research  Center.    Municipal   solid
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26.   Environmental  Protection  Agency.   Water Proorams.   National
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27.   Sommers,   L.E.    Chemical  composition of sewage  sludges  and
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28.   Jelinck,  C.F. and  G.L.  Brande.   Management of sludge  use on
     land, F.D.A.  Considerations.  35-37.

29.   Municipal  Sludge:  what shall we do with it?  Current  Focus.
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30.   U.S.  Environmental  Protection  Agency.     Office  of  Solid
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31.   Jones,  R.L.,   T.D.  Hinesly, R.J.   Johnson.    Selenium  in
     agricultural   ecosystems;  a  bibliography of  the  literature.
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32.   Landspreading of  municipal   sludges   (Draft),  USEPA,  1977
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33.   The  Water  Pollution  Control  Act   of  1972:    Enforcement
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34.   Chian, E.S.K., 8,  F.B.  Dewalle.   Compilation  of methodology
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                               V-3

-------
35.   Office  of  Water  Supply.    U.S.  Environmental   Protection
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36.   Brunner, D.R.  and  D.J.  Keller.  Sanitary  landfill  design and
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37.   Subsurface  application  solves   community  sludge  disposal
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39.   Issue Paper:    Proposed  regulations  for  classification  of
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40.   Protection of Wetlands, Executive Order 11990,  May 24,  1977.

41.   Floodplain   Management,    Executive    Order  11988,   Federal
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42.   Background  document,  Land  criteria.   (Unpublished  Draft).
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43.   Environmental  Protection  Agency.   Environmental  impacts  of
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44.   Sanitary landfill criteria, Issue No. 3,  15p. EPA, 1977.

45.   Gray, Donald H.,  Environmental  concerns  related to disposal
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46.   Pohland,  F.G.  and R.S.   Engelbrecht,   Impact  of  Sanitary
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47.   RCRA  land  disposal  criteria:   coverage  of surface impound-
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48.   Personal   Communications.   Joseph  Nile,  Acting   Associate
     Commissioner for Compliance, Food and Drug Administration to
     Dr.  Andrew  W.   Breadenbach,  U.S.  Environmental  Protection
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49.   Anderson,  R.  Kent.  Case  studies of  the  cost of landspread-
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     plants  (unpublished document) U.S.E.P.A.
                               V-4

-------
50.   Emcon  Associates,   Evaluation   of  clay   liner   materials
     following in-field exposure  to  landfill  leachate.   Prepared
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51.   Shuster,  K.A.   Leachate damage  assessment:   Case  study  of
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52.   Stewart,  W.S.   State-of-the-art study  of  landfill  impound-
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53.   USEPA,   Industrial   waste  management:     seven  conference
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54.   American   Society  of  Civil   Engineers,  Sanitary  landfill
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55.   World  Health  Organization.    Evaluation   of  certain  food
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56.   The City  of  Scottsdale,  Arizona.   A handbook  for  initiatina
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57.   Berman,   E.B.   WRAP.    A  model  for regional  solid  waste
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58.   Environmental  Protection  Agency  -  Solid  waste  planning  and
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59.   Environmental Protection Agency.   Materials  recovery.   Solid
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60.   Environmental   Protection    Agency.      Resource   recovery
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61.   Environmental Protection Agency.   Polychlorinated  biphenyl  -
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     3p.
                               V-5

-------
62.   Environmental  Protection Agency.  Resource  Conservation  and
     Recovery Act  of 1976.   Federal  Register,  Vol. 42,  No.  23.
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63.   Environmental  Protection Agency.  Identification  of  regions
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     Guidelines.   Federal  Register,  Vol.  42,  No.  94.   Washington,
     U.S.  Government Printing Office,  May  16,  1977.   5p.

64.   Environmental    Protection   Agency.      Vinyl    chloride.
     Recommended  procedure for disposal  of aerosol  cans.   Federal
     .Register,  Vol.  41,   No.  112.    Washington,  U.S.  Government
     Printing Office, June 9, 1976.   2p.

65.   Terry, Jr.  R.C.  and  J.B.  Berkowitz, A.D. Little,  Inc.  C.H.
     Porter.    Waste  clearing  houses  and  exchanges.    Chenn' cal
     Engineering  Progress, 58-62.  December  1976.

66.   Ghassemi,  M.,  S.C.  Quinlivon and H.R.  Day.   Landfills  for
     pesticide   waste   disposal.     Envi ronmental   Science   and
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67.   Anderson,  K.  and  M.  Cowart.   Don't walk away  from  an  open
     dump.   The Ameri can Ci ty and County.   February 1976.   2p.

68.   Hatte,  S.J.  Anaerobic  digestion  of  solid  waste  and  sewage
     sludge  into  methane.   Compost  Science  _^  Journal  of  Wa s te
     Recycli ng,  17(1):   January - February 1976.   5p.

69.   Environmental   Protection Agency.   Winter  sewage  treatment
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70.   Emcon Associates  -  City and County  of  Honolulu.   Liners.
     July,  1977.   5p.

71.   Geswein, Allen J.   Liners for disposal  sites,  an assessment.
     Environmental    Protection   Agency    Publication   SW-137.
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72.   Wolcott, R.M.  and  B.W.  Vincent.  The  relationship  of  solid
     waste storage  practices in the  inner  city  to  the incidence
     of  rat   infestation  and  fires.   Environmental  Protection
     Agency  Publication  SW-150.    Washington,  U.S.  Government
     Printing Office, May  1975.  14p.

73.   Smith, F.A.      Comparative  estimates of  post-consumer  solid
     waste.  Environmental  Protection  Agency  Publication  SW-148.
     Washington,  U.S. Government Printing Office, May 1975.   Sp „

74.   Smith,  F.L.,   Jr.     A  solid  waste  estimation  procedure:
     material  flows  approach.   Environmental Protection  Agency
     Publication  SW-147.    Washington,  U.S.  Government  Printing
     Office,  May  1975.   55p.
                               V-6

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75.   Stanton,  W.S.  and  J.G.   Langerton.    Pesticide  container
     processing    in    commercial    reconditioning    facilities.
     Environmental   Protection    Agency    Publication    SW-88d.
     Washington,  U.S. Government  Printing  Office,  November 1976.
     20p.

76.   Exclusive  Waste Age  survey of the  nation's  disposal  sites.
     Waste Age.  21-28.   January 1977.

77.   Cost of  solid  waste  management  facilities.   Board  of County
     Commissioners.  Johnson County,  Kansas, March 1975.

78.   Inglehart, Cecil.   How  do  you measure the costs of  landfill
     design and operation?  (unpublished report).

79.   U.S. House  of Representatives.   Report of the  Committee  on
     Interstate  and Foreign  Commerce  on  H.R.   14496,   Resource
     Conservation  and Recovery  Act of 1976.  Report No.  94-1491,
     94th Congress, Second Session, September 9,  1976.  136pp.

80.   FAA  "Bird   Hazards   to   Aircraft"   Advisory   Circular  AC
     150/5200-3A,  1972.

81.   FAA  Advisory Circular.  Use   of  chemical  controls   to  repel
     flocks of birds at airports (AC 150/5200-8,  May 2,  1968).

82.   FAA  Advisory Circular,  Bird  reactions to scarinq  devices.
     (AC 150/5200-9, June  26,1968).

83.   FAA  Advisory Circular,  Announcing  the availability  of the
     international  civil  aviation organization airport  services
     manual, DOC-9137-AN/898,  Part 3,  Bird control and reduction.
     (AC 150/5200-22).

84.   FAA Order 5200.5 FAA  guidance concerning sanitary landfills.
     October 16, 1974.

85.   EPA  Noise  emissions  standards   for  (new)   transportation
     equipment:    medium   and  heavy   trucks.   (40  CFR  Part 205)
     Federal Register.  V.  41,  N72, April  13, 1976.  p.15538-58.

86.   EPA Noise regulations for new wheel  and crawler tractors and
     other heavy equipment.

87.   U.S. Water  Resources Council.   A Unified National  Program
     for Floodplain Management.   Washington, D.C., July  1976.

88.   James,  Stephen C.,  Metals in Municipal Landfill  Leachate and
     Their  Health  Effects.    Am.  J.  of Public Health 67,  5, May
     1977, 429-432.
                               V-7

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89.   Environmental   Protection  Aqency,  Bird/airport  hazards  at
     airports near  solid waste disposal  sites,  SW-116,  1974.

90.   Environmental    Protection    Agency    Technical    Bulletin:
     Municipal  sludge management technical  factors,  and  Notice of
     availability of proposed technical  bulletin.   1977.

91.   Geraghty &  Miller,  Inc.    Development  of a  data  base  for
     determining  the   prevalence   of  migration   of   hazardous
     chemical substances into the ground water  at.  industrial  land
     disposal  sites.     Project  Synopsis.    EPA    Contract  No.
     68-01-3707.  February 1977.

92.   Council  on  Environmental  Quality.   Environmental  Quality
     1976,   Seventh  Annual  Report,  Washington,  D.C.,  September
     1976.

93.   Cogswell,  Howard  L.   Proceedings  on  the  Co-nference  on  the
     Biological  Aspects  of  the  Bird/Aircraft  Collision  Program,
     Clemson University, South Carolina, February  1974.

94.   Hinesly, Thomas D.   Agricultural  benefits and  environmental
     changes resulting  from  the use of digested  sludge  on field
     crops.  Metropolitan Sanitary District of  Greater  Chicago,
     prepared for  Environmental  Protection Agency,  1974.   375p.
     (Distributed by NTIS, Springfield,  VA. as  PB-236 402).

95.   Recycling   sludge  and   sewage  effluent   by  land  disposal;
     Environmental   Science   a^nd   Tec hnol ogy   6(10):     871-873,
     October 1972."

96.   Walker, John,  Sewage sludges   -  management  aspects  for  land
     applicat ion, Compos t Sc i ence 12-21, March-April, 1975.

97.   Bjornson,   B.F.,  Pratt,   H.D.  and  Littig,  K.S.  Control  of
     domestic rats  and  mice.   Public  Health  Service Publication
     No.  563.  Washington, U.S. Government Printing  Office, 1970.
     Alp.

98.   Ham.  Robert   K.     Vectors.     Conference   of  Engineering
     Foundation  Research.  Deerfield, Massachusetts.  1970  14p.

99.   Manson, Robert  and Merritt,  Clifford.  Land  application of
     liquid  municipal  wastewater sludges.  Journal  of  t_he Wa_te_^
     Pollution  Control  Federation  (Vol. 47, ฅcT  IT" J a n u a ry 1 9 7" 5 .
     24-24.

100. Singh,  R.N.,  Keefer,  R.F., and  Hovath,  D.J.,   Can  soils be
     used  for  sewage  sludge  disposal?   Compost Science  22-25,
     March-April 1975.                     ~
                               V-8

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101.  U.S.   Senate   Report   No. 94-988,  94th   Congress,   Second
     Session, 1976.

102.  LA/OMA  Project,   Sludge  management activities  for  the  Los
     Angeles/Orange   County  metropolitan  area,  Whittier,   CA.,
     May 1977.

103.  The  Metropolitan  Sanitary  District   of  Greater  Chicaqo,
     Working  Draft — proposed   regulations  for  classification  of
     solid waste disposal facilities.  July 12, 1977.

104.  SCS  Engineers.    Municipal  sludge  agricultural  utilization
     practices — an environmental assessment.  Volume I.  Prepared
     for Office of Solid Waste, USฃPA.  1977.   151p.

105.  Impact  assessment  of  annual   cadmium   limitations  on  the
     agricultural  utilization of municipal  sludge. (Draft)

106.  Municipal  sludge   management:     EPa  construction  grants
     program.   An  overview  of the  sludge  management  situation.
     U.S.   Environmental   Protection   Agency,   Office   of  Water
     Program  Operations.   April  1976.   (Distributed by National
     Technical   Information   Service,   Springfield,    VA,   as
     PB-266-695).

107.  Geraghty  & Miller,  Inc.    Surface  impoundments   and  their
     effects  on  ground-water  quality  in   the United  States--A
     preliminary  survey.    Prepared  for   the Office  of  Water
     Supply,  U.S.  Environmental  Protection  Agency.   September,
     1977.   267p.

108.  U.S.   Environmental  Protection  Agency.    Office of Research
     and   Development.      Environmental   Protection  Technology
     Series.   Movement  of  selected metals, asbestos, and cyanide
     in  soil:   applications  to  waste  disposal  problems.    EPA
     600/2-77-020.  Cincinnati, Ohio.  April 1977.  242p.

109.  U.S.   Water  Resources  Council.    A  Uniform  Technioue  for
     Determining  Flood   Flow   Frequencies,    Bulletin   No. 15.
     Washington, D.C., December,  1976.

110.  The  carcinogen  assessment  group's  assessment of  cadmium.
     1977 26p.  (unpublished report)

111.  Dotson,  G.  Kenneth, et_._  a 1 .   An  appraisal  of the relative
     health  risks  associated with  land  application of municipal
     sludge.    50th  Annual   Conference  of  the  Water  Pollution
     Control  Federation,  Philadelphia,  PA,   October  2-6,  1977.
     22p.

112.  Bruade,  G.L. and  Jelinck,  C.F.  Management  of  sludge use on
     land,  FDA considerations.    Food and  Drug  Administration,
     Washington, D.C.
                               V-9

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113.  Troast,  Richard,  et.  al . ,  Cadmium.   (Position  Document  1).
     Office  of   Special  Pesticide  Reviews.  U.S.   Environmental
     Protection  Agency.

114.  Otte, A.D.  and  K.Z.  LaConde,  Environmental  assessment  of
     municipal  sludge  utilization at  nine  locations  in  the  U.S.,
     Ninth Annual   Food,   Fertilizer  and  Agricultural   Residues
     Conference.   Syracuse, New  York.   April  27,  1977.

115.  U.S.   Environmental   Protection   Agency.    Office  of  Water
     Program   Operations.     Municipal  Construction   Division.
     Municipal    sludge  management:     environmental   factors.
     EPA 430/9-77-004".  Washington D.C.   October   1977.   31p.

116.  Department   of  Defense,  Department  of  the  Army,  Engineer
     Corps.  Regulatory  program  of the  Corps  of  Engineers.   (42
     F_ed^ Reg.  37122-37164, July,  19,  1977).

117.  Emcon Associates.   Methane  gas  hazard.    In-house  report.
     1977  6p.

118.  Riggs,  James  L.   Economic  decision models for engineers  and
     managers.   New York:  McGraw Hill,  Inc.  1968.

119.  U.S.   Department  of  Commerce,  Bureau  of the  Census.   General
     Summary,  1972  Census  of  Manufacturers,  Washington:  U.S.
     Government  Printing Office, 1975.

120.  U.S.   Environmental  Protection Agency,  Office  of  Water  and
     Hazardous   Materials,  RCRA  solid  waste   disposal  criteria,
     (unpublished  memorandum from  Thomas  C.  Jorling  to Assistant
     Administrators).  December 1977.

121.  Federal   Insecticide,   Fungicide,  and  Rodenticide  Act   as
     amended.  Public  Law  94-140.

122.  The  Bureau  of National  Affairs,  Inc.  Environment Reporter:
     State Solid   Waste  -  Land Use  (Washington:   The  Bureau  of
     National Affairs, Inc. 1976).

123.  U.S.   Bureau of  the  Census.   1970  Census of the Population:
     Number  of  Inhabitants,  Vol.  I.   United  States  Summary,
     Table II,   Area,  1970, and population  per square  mile, 1920
     to 1970 (Washington:  Government Printing Office,  1972).

124.  Gordian  Associates,  Inc.  (draft)  An  economic analysis  of
     municipal    waste  water  sludge   treatment   and   disposal.
     Washington:   Gordian  Associates,  Inc., July 1977.

125.  Clean Water Act.  Public Law 95-217.
                               V-10

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126.  Federal  Food, Drug, and Cosmetic Act.  Public Law 95-217.

127.  Anderson, R. Kent. Case studies on the cost of landspreading
     and  hauling  sludge  from  municipal  wastewater  treatment
     plants (unpublished document) USEPA.

128.  Environmental   Protection   Agency.     Working   Paper   #1.
     Approach to  guideline  development  for disposal of municipal
     wastewater sludges and related residuals  (unpublished  report
     from Docket No."4004).  EPA WA77-B399, October, 1977.

129.  Endangered Species Act.  Public Law  93-205.

130.  Critical habitat.  50 CFR Part 17, Subpart F.

131.  Safe Drinking Water Act.  Public Law  93-523.

132.  Proposed  procedures   for  sole-source  aquifer designations.
     42 Fed.  Reg. 51620.

133.  Clean Air Act.  Public Law 93-319.

134.  Shuster,  Kenneth  A.    Leachate  damage  assessment:    an
     approach.  (Unpublished Draft).  December, 1975.

135.  Shuster, Kenneth  A.   Leachate damage assessment; case  study
     of  the  Islip  (Long  Island)  New   York  solid  waste  disposal
     site.    Environmental  Protection  Agency.   U.S.  Government
     Printing Office,  1976,

136.  Brunner,  D.R.,  S.J.   Hubbard  D.J.  Keller,  and  J.L.  Newton.
     Closing   open   dumps.     Environmental   Protection   Agency
     Publication  SW-61ts.   Washington,  U.S.  Government  Printing
     Office,  1971, 19p.

137.  Office of Solid Waste Management Programs.  Second Report to
     Congress;    resource    recovery    and    source   reduction.
     Environmental  Protection  Publication SW-122.   Washington,
     U.S. Government Printing Office, 1974.  112p.

138.  Office of  Solid  Waste  Management   Programs.   Third Report to
     Congress;    resource    recovery    and    waste   reduction.
     Environmental    Protection    Agency   Publication   SW-161.
     Washington, U.S.  Government Printing  Office,  1975.

139.  Thermal   processinq   and   land   disposal   of  solid   waste;
     guidelines.   40  CFR  Part 241.   39  Federal  Regi ster  29327-
     29338, August 14, 1974.
                                                            SW-692
                                          U.S. Environmental Protection Agency
                               V -11        Rซfton 5, Library (PL-12J)
                                          77 West Jacfcson Poufevard, 12th
                                                 ปL  60604-3590

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