II I III
SW9PA
  : t
                .ri'i	T'

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                       PROCEEDINGS

        1975 Public Meetings  on  Hazardous Waste Management

                              Volume I
               This publication (SW-9p) was compiled
               under the direction of Alan S. Carson,
by Patricia A.  Savage, Cynthia A.  Baggatts, and  Tawanna Holloway.
       It  constitutes the official record of the meetings
     announced September 17,  1975, in the Federal Register
   and held by the Office of Solid Waste Management Programs,
     December 2 (Newark, N.J.),  December 4 (Rosemont,  III.),
     December 9 (Houston), and December 11 (San  Francisco).
               U.S. ENVIRONMENTAL PROTECTION AGENCY

                                1976
            For sale by the Superintendent of Documents, U S Government Printing Office,
                   Vol I and VoL II Washington, D C 20402 - Pnce $14 00
                Er.vj.•-..'•  .-. •    - -,  .'•  .-..   ... --:i  /i.r.eucy

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                        FOREWORD
     Last December the Office of Solid Waste Management
Programs held a series of public meetings on hazardous waste
issues.  The purpose was to gain a better national perspective
on whatever guidance might be needed from EPA for the proper
management of these particularly dangerous discards of our
highly industrialized society.  Hazardous wastes are the toxic
chemical, biological, radioactive, flammable and explosive
byproducts generated primarily in extracting and processing
the raw materials used by our Nation.  Hazardous wastes
constitute an overwhelming disposal burden and threaten the
public health and the quality of our environment.

     The meetings were announced in the Federal Register,
September 17, 1975. and were well attended by members
of the public, representatives of the industrial firms that
generate hazardous wastes as well as those that dispose of
them, by representatives of other Federal agencies, and by
environmentalists.  Rather than making only a single record
of the meetings available for public inspection in our Washington
headquarters  (as stated in the Federal Register), the following
proceedings, which include the transcripts of the four meetings
together with copies of all documents presented and all written
submissions, are being printed in limited quantity for sale
by the Superintendent of Documents, and for inspection at the
EPA regional libraries and State solid waste management agencies.
We hope the official record of these important meetings is thus
being made widely available across the Nation.
                              Sheldon Meyers
                      Deputy Assistant Administrator
                    for Solid Waste Management Programs
                           iii

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        WEDNESDAY, SEPTEMBER 17, 1975


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                                                       NOTICES
                                                                                                                 42993
  ENVIRONMENTAL PROTECTION
               AGENCY
              [FBL 432-6]

   HAZARDOUS WASTE MANAGEMENT
            Public Meetings
  Hazardous wastes are the particularly
dangerous discards of any highly indus-
trialized, technology-based society. These
wastes are the toxic chemical, biological,
radioactive, flammable and explosive by-
products generated primarily by the Na-
tion's extractive, conversion, and other
process Industries as  well  as Federal
facilities.  Growing industry  production,
bans  and cancellations of  toxic sub-
stances, and the effectiveness of air and
water  pollution  controls (along  with
ocean dumping restrictions) are increas-
ing the pressure for hazardous waste dis-
posal to the land. The  generation  rate
for nonradioactive hazardous  wastes fs
estimated at  well over  10 million  tons
yearly and  increasing. At present, Fed-
eral, State,  and local regulations dealing
with the treatment and  disposal of non-
radioactive  hazardous wastes  are gen-
erally spotty or nonexistent. Considera-
tion is currently being given  in Congress
to new legislation providing more posi-
tive control over hazardous wastes.
  In order to gain a better National per-
spective on needed  guidance for the
proper management of hazardous wastes,
and pursuant to Section 204  of the Solid
Waste Disposal Act, as amended, wherein
the Administrator may  gather and dis-
seminate  information and  recommen-
dations on waste management issues,
notice  Is hereby  given of  four  public
meetings  to solicit information as to the
scope and nature of the  hazardous waste
management problem and related topics.
The meetings will  begin  at 8:30 a.m.,
December 2,1975, at the Gateway Motel,
Newark, N.J.; December 4, 1975, at the
O'Hare-Kennedy  Expressway  Holiday
Inn,  Rosemont,  Illinois;  December  9,
1975, at the Holiday Inn-Medical Center,
Houston,  Texas; and December 11, 1975,
at tile Sheraton-Fisherman's Wharf, San
Francisco, California. A second day may
be scheduled at each location should the
response warrant.
  The purpose of each meeting is to so-
lid* public, Industry, labor, and other
Federal agency comment in order to as-
sist the Agency In determining the types
and character of any advice and guid-
ance whtoh should be developed for the
environmentally   safe management  of
hazardous wastes. Members of the inter-
ested public, representatives of industrial
firms tbat generate as well as those that
treat and dispose of these wastes, labor
unions  representing  Individuals   who
work with such  wastes,  and Federal
agencies are urged to attend and respond
to any  or all of the Discussion Topics
listed below as well as any other issues
of concern.
  The meetings are open  to the public
and will be conducted  by  a panel from
the  Environmental Protection Agency.
The following procedural rules will apply.
The Chairman of the panel is empowered
to conduct the meeting in a manner that
in his judgment will facilitate the orderly
conduct of business, to schedule presen-
tations  by partkapatnts, and to exclude
material which is irrelevant, extraneous,
or repetitious. The time  allotment for
oral statements shall be at the discretion
of the Chairman, but shall  not ordinarily
exceed  15 minutes. With the permission
of any person offering a statement, ques-
tions may be asked by members of the
panel. At the discretion of the Chairman,
a procedure may be made available for
presentation of pertinent Questions from
other persons to participants. Individuals
with prepared statements are requsted to
bring 20 copies. Persons unable to attend,
but  wishing to comment on the Discus-
sion Topics, are invited to send  written
comments to the address below by Janu-
ary 31,  1976.
  A transcript of  the  meetings  will be
made and a copy of the transcript, to-
gether with copies of all documents pre-
sented  at the hearings and all  written
submissions, will constitute the record of
the meetings. A copy of the record of the
meetings will  be available  for public in-
spection by March 30,  1976, at the 0.S.
Environmental Protection  Agency, Pub-
lic Information Reference  Unit,  Rm.
2404, 401 M Street, S.W., Washington,
D.C. 20460.
  Anyone  desiring  additional Informa-
tion on the meeting or wishing  to be
placed on the program to present a state-
ment Is requested  to contact: Mr. John
P. Lehman, Director, Hazardous Waste
Management  Division, Office of  Solid
Waste  Management   Programs   (AW-
565), Environmental Protection Agency,
Washington, D.C. 20460, telephone (202)
254-6837  or, after September 22,  1975,
(202) 755-9185.
            DISCUSSION TOPICS
  1. What  IB  a hazardous  waste?  What
criteria  should be used to Identify hazardous
vs. non-hazardous wastes? What are proper
methods for collection of waste samples for
analysis? What analytic/laboratory methods
have been  useful or efficient  111 analyzing
wastes  for characteristics relevant to  this
decision process?
  3. what  responsibilities   and  liabilities
should rest with the generator, the  treater,
and/or the disposer of hazardous waste for ite
ultimate  environmentally  acceptable dis-
posal? Who should bear the costs of assuring
environmentally safe disposal?
  3. For which  wastes,  If any, should  (a)
recovery and  reuse, (b)  Incineration,  (c)
chemical treatment, (d) physical treatment.
(e) biological treatment, or (f) land emplace-
ment be required? For which wastes, If any,
should (a), (b), (c), (d), (e),  or (f) above
be prohibited?
  4. Which practices, for certain specified
wastes, are particularly effective In detoxify-
ing, neutralizing or otherwise tendering such
wastes harmless?
  5. To what  extent are cost data available
for the variety of processes and techniques
useful In treating and disposing of hazardous
wastes?
  6. What are the minimal safety and secur-
ity precautions  for hazardous  waste treat-
ment, storage, and disposal sites (Including
packaging  and contalnerlzatlon, fire safety,
site security, employee training, Incident re-
porting, etc.)  which are necessary for envir-
onmentally sound management?
  7. What provisions for site  monitoring,
recordkeeplng. and reporting are  necessary
and prudent to  Insure the Integrity  of haz-
ardous waste storage,  treatment, and dis-
posal sites?
  8. What has been the availability and price
of insurance and other mechanisms to reduce
the risks of operation to operators of private
hazardous waste management facilities?
  9 What are necessary and  sufficient re-
quirements to assure the long-term Integrity
and care of operating as well as closed haz-
ardous waste storage/disposal sites?
  10. What are feasible  methodologies. If
any, to set limits  on the amounts of speci-
fied hazardous wastes permitted to  be em-
placed In the land at specific sites?
  11. To what extent are existing transpor-
tation safety regulations and definitions use-
ful  and sufficient to govern the  transport
(both Interstate and Intrastate) of hazardous
wastes, as distinguished  from substances?
  12 To  what degree  should  labeling  and
placarding of waste shipments be required?
What  are  the most effective and accepted
systems for such  labeling and placarding?
  13. To  what extent  are the damages or
costs of improper hazardous waste manage-
ment evident? To what extent have they been
Investigated?
  14. What mechanisms and experiences are
effective for soliciting citizen acceptance of
hazardous waste management facilities?
  15. What Federal facilities typically gener-
ate what  types and amount  of hazardous
wastes?
  i6. To what extent and by  what  mecha-
nisms should the  private sector be Involved
in the treatment and disposal  of hazardous
wastes, especially  those from Federal facu-
lties?

  Dated:  September 11,1975.

                  EDWARD Ttrrax,
           Assistant Administrator,
       for Air and Waste Management.
  [FB DOC.75-2477S Piled 9-16-75;8:4S am]
                             FEDERAL KGISTEI, VOL 40, NO. 181—WEDNESDAY,  SEPTEMBER 17. 1*71
                                                          VI

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                        CONTENTS

                                                      PAGE

Newark Public Meeting	  1

     John P. Lehman, Director
          Hazardous Waste Management Division	  3

     Conrad Simon, Director
          Environmental Programs Division, Region II..  7

     Rollins Environmental Service
          William B. Philipbar	 13

     Chemifix, Inc.
          Jesse R. Conner	 25

     Trane Thermal Co.
          J.J. Santoleri	 34
               Supplementary Information*	 47
               Supplementary Information	 62

     DuPont Co.
          Philip A. Palmer	 66
               Supplementary Information	 78

     American Iron and Steel Institute
          David A. Boltz	 97

     Scientific, Inc.
          Al Gathman	112

     Environmental Action
          A. Blakeman Early	125
               Supplementary Information	136

     SBB Ltd. - Germany
          J. Gallay	149

     New Jersey Manufacturers Assn.
          David Nalven	166

     National Barrel and Drum Association
          Clarence Moore	174
               Supplementary Information	184

* - This indicates that additional information,  either submitted
at the meetings or raised at the meeting, has been included at
an appropriate location in the record.

                            vii

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                                                     PAGE
     Sierra Club
          Diane T.  Graves	227

     American Electroplaters Society
          Clarence  Roy	237

     New York City  Fire Department
          Capt. Hugh McCabe	244

     Pollution Abatement Services
          Jack Miller	250

     Chemtrol
          Ed Shuster	259
               Supplementary Information	264

     Atlantic Terminal Corp.
          Warren Kinsman	306

     Robert Canace	315

     U.S. Soil Conservation Service
          John E. Witty	320
               Supplementary Information	325

     Kawecki Berylco Industries
          Anthony Falla	357
               Supplementary Information	364

Chicago Public Meeting	375

     John P. Lehman, Director, Hazardous Waste Management
      Division, Office of Solid Waste Management	377

     Valdus Adamkus, Deputy Regional Administrator for
      Region V, EPA	377

     Illinois Power Company
          W.S. Brenneman	386
               Supplementary Information	392

     Monsanto Company
          Donald Eby	405
               Supplementary Information	428

     Lake Michigan Federation
          Thomas J. Murphy	431

     Hyon Waste Management Services
          R.B. Bruns	438

                            viii

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                                             PAGE

Illinois EPA
     Thomas Clark	455

Wisconsin Department of Natural Resources
     Daniel Kolberg	471

Geraghty & Miller,  Inc.
     William H. Walker	483
          Supplementary Information	505

Missouri Dept. of Health
     Patrick Phillips	507

Bernard Reese	520

Illinois EPA
     Dennis Johnson	533

Manufacturing Chemists Association
     Dennis Bridge	559
          Supplementary Information	568

Minnesota Pollution Control Agency
     Patrick Born	599

Oconomowoc Electroplating Co.
     William Kitazaki	615

Columbus Steel Drum Co.
     Sidney Blatt	625

Industrial Steel Container Co.
     Donald Rutman	629

Mobay Chemical Corp.
     Lee Frisbie	637

Pollution and Environmental Problems
     Frank Richards	645

Ohio EPA
     Donald Brown	661

Illinois Dept. of Public Health
     Gary Wright	669

IMC Chemical Group
     David Russell	681
          Supplementary Information	686

Dames and Moore
     Dean Gregg	700

Commonwealth Edison Co.
     Edward Jerusak	704
                         IX

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                                                       PAGE

Houston Public Meeting	709

     John P. Lehman, Director
          Hazardous Waste Management Division	711

     Raymond Lozano, Director of Air and Hazardous
          Materials Division, Region VI, EPA	711

     Shell Oil Company
          L.P. Haxby	717
               Supplementary Information	724

     Houston Chamber of Commerce
          Jack Westney	736
          Dr. Nugent Myrick	741

     League of Women Voters
          Brenda Gehan	743

     Citizens Against National Nuclear Overkill Technology
          C. Leon Pickett	756
          Teresa Pickett	756

     Holland and Knight
          Roger Sims	761

     Taxpayers' Rights Association
          Jack T. Woods	768

     SBB Limited
          J. Gallay	776

     Agro-City Incorporated
          Geoffrey Standford	791

     Texas Water Quality Board
          George Maxon	807
               Supplementary Information	811

     Bio-Ecology
          William Brown	838
               Supplementary Information	856

     U.S. Soil Conservation Service
          James Dement	878

     University of Oklahoma
          James M. Robertson	887

     Malone Company
          John R. Montgomery	905

     Texas Chemical Council
          John F. Erdmann	919

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                                                       PAGE

     Exxon Coporation
          H.H.  Merdith,  Jr	938
               Supplementary Information	950

     Dow Chemical
          Glen Wessels (Submitted but not presented
            orally)	956

San Francisco Public Meeting	961

     Russ Freeman, Deputy Regional Administrator of
          Region IX, EPA	963

     John P. Lehman, Director,  Hazardous Waste Management
          Division,  EPA	971

     State of California
          Harvey Collins	975
               Supplementary Information	1001

     Envirotech Corporation
          F. Sidney Howard	1005
               Supplementary Information	1013

     Zero Waste Systems,  Incorporated
          Paul Palmer	1132

     American Institute of Chemical Engineers
          G.F.  Kroneberger	1152
               Supplementary Information	1160

     Lockheed Missies and Space Company
          Don Degruch	1177
               Supplementary Information	1189

     Sierra Club
          Tom Torlakson	1191

     Contra Costa Conservation  League
          Jean B. Siri	1200

     Western Federal Regional Council Task Force for
      Hazardous Waste Management
          Wyatt McGhee	1207
               Supplementary Information	1213

     Advanced Chemical Technology
          Alvin Simon	1316

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                                                       PAGE

     Sierra Club
          Nancy Buder	1324

     California State Solid Waste Management Board
          David Baker	1336
               Supplementary Information	1347

     Bay Area Sewage Services Agency
          Mary Lee	1391

     Chevron Research Company
          Harold D.  Knowlton	1402
               Supplementary Information	1411
               Supplementary Information	1461

     Naval Ammunition Depot Management Assn.
          Joann Ferguson	1491

     S.  Rose Cooperage Company
          Sanford Jay Fleisher	1499

     W & H Industries
          Jos E. Hooper	1504

     BKK Company
          Leonard Tinnan	1511
               Supplementary Information	1532

     Citizens Against Pollution of Berkeley
          Glen Barlow	1534

Written Comments on Hazardous Waste Management	1547

     Aluminum Company of America
          Roy H. Carwile	1549

     American Cyanamid Company
          C.P. Priesing	1551

     Beaver Buildings, Inc.
          Don C. Davis	1556

     Central and West Basin Water Replenishment District
          John G. Joham, Jr	1557

     Chatauqua County Dept. of Public Works
          Kenneth Fladie	1558

     Conservation Chemical Company
          Norman B. Hjersted	1562

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                                             PAGE

Council for Agricultural Science and Technology
     Charles A. Black	1565

City of Dallas
     John A. Teipel	1566

Friends of the Earth, San Francisco Branch...1567

Robert Gartner	1568

General Motors Corporation
     O.K. Van  Zile	1570

Godax Laboratories, Inc.
     George Goda	,	1584

Christina M. Groth	1586

Guam Environmental Protection Agency
     Jerry L. Wager	1589

Houston Geologic Society
     Martin Sheets	1595

League of Women Voters of New Jersey
     Margaret Hoffman	1598

Los Angeles City Flood Control District
     A.E. Bruington	1600

Marathon Oil Company
     F.C. Aldrich	1602

The Metropolitan Sanitary District of Greater
 Chicago
     Bart T. Lynam	1604

State of Michigan-Dept. of Natural Resources
     David M. Dennis	1637

The Mid-Ohio Health Planning Federaltion
     Charles A. Turner, III	1639

State of Minnesota - Dept. of Agriculture
     Rollin M. Dennistoun	1643

National Solid Waste Management Assn.
     Warren T. Gregory	1646

State of Nevada - Dept. of Human Resources
     James P. Hawke	1652

                          xiii

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                                                  PAGE

New York State Dept. of Environemntal Conservation
     Eugene F. Seebald	1653

Pennsylvania Separator Corporation
     John A. McNeil	1681

Project Survival
     James E. Burch	1682

Solvents Recovery Service of New Jersey
     John P. O'Connell	1684

Southern Methodist University
     Joe G. Gallagher	1686

System Technology Corporation (SYSTECH)
     Thomas J. Wittman	1687

University of Texas at Dallas
     G. Fred Lee	1691

Sidney B. Tuwiner	1696

U.S. Dept. of the Interior - Bureau of Land Management
     George L. Turcott	1699

U.S. Dept. of the Interior - Geological Survey
     Henry W. Couller	1701

U.S. Dept. of Transportation
     Alan Roberts	1707

Ventura Regional County Sanitation District
     John A. Lambie	1710

Commonwealth of Virginia
     Eugene T. Jensen	1712

Waste Management Inc.
     David L. Smillie	1725

Weyerhaeuser Company
     Vivien Lee	1731

Wichita-Sedgwick County Dept. of Community Health
     James F. Aiken, Jr	1732

Ruth Zaat	1735
                         xiv

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                     PUBLIC MEETING

                       held at the

              GATEWAY DOWNTOWNER MOTOR INN

                   NEWARK, NEW JERSEY
                         Tuesday
                    December 2, 1975
                        8:30 A.M.
                      PANEL MEMBERS
John P. Lehman, Director
Hazardous Waste Management Division (HWMD)
Office of Solid Waste Management Programs, EPA

Walter W. Kovalick, Jr., Chief
Guidelines Branch, HWMD
Office of Solid Waste Management Programs, EPA

Alfred W. Lindsey, Program Manager
Technology Assessment, Technology Branch, HWMD
Office of Solid Waste Management Programs, EPA

Murray Newton, Program Manager
State Programs, Implementation Branch, HWMD
Office of Solid Waste Management Programs, EPA

William Sanjour, Chief
Technology Branch, HWMD
Office of Solid Waste Management Programs, EPA

Michael F. DeBonis, Chief
Solid Waste Management Branch
EPA Region II

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               MR. JOHN P. LEHMAN:  I call this public
meeting to order.  Good morning, ladies and gentlemen, my
name is John P. Lehman, I'm the Director of the Hazardous
Waste Management Division, Office of Solid Waste Management
Programs, U.S. Environmental Protection Agency, Washington,
D.C.
               I would like to welcome you on behalf of
the Agency, I think it is noteworthy that this particular
meeting is taking place exactly on the 5th birthday of
EPA.  We are starting our 5th year today.
               The purpose of this public meeting as
announced in the Federal Register of September 17, 1975,
is to gather information and data for the Agency as to the
scope and nature of the hazardous waste management problem
in this country and the need for and extent of guidance
that should be developed by the Agency to help cope with
this problem.
               For the purpose of this meeting, hazardous
wastes are the non-radioactive discards of our technology
based society.  They include the toxic, chemical, biologi-
cal, flammable and explosive byproducts of the nation's
extractive, conversion and process industries.
               This is not a rule making or regulatory
hearing.  The Agency does not have a proposal or a state-
ment to issue for comment.   ^Rather, this is a meeting
                                 3

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on the record to solicit input from industry, labor, Federal



state and local government and other members of the public



as to the extent of mismanagement of hazardous wastes and



the available or anticipated systems and technologies to



abate this problem.



               In order to provide a framework for discus-



sion today, the Federal Register Notice announcing this



meeting suggested 16 discussion topics that reflect issues



of concern to the Agency.   Commentary on these and any



other related topics are what we are most interested in



hearing today.  Copies of this Federal Register are avail-



able on the table at the back of the room marked "Publica-



tion. "  I also am submitting a copy of the Federal Register



notice for the record.



               The panel here with me is composed of staff



of the Hazardous Waste Management Division in Washington



and EPA's Regional office, Region 2, in New York City.



Now these gentlemen specialize in certain suoject areas



related to this issue.  They are from your left Mr.



Michael DeBonis, Chief, Solid Waste Management Branch in



EPA Region II.   Mr. William Sanjour, Chief of the



Technology Branch in the Hazardous Waste Management Divi-



sion.   And, on my left, Mr. Walter Kovalick, Chief of the



Guidelines Branch, Hazardous Waste Management Division.




Mr. Alfred Lindsey, Program Manager for Technology

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Assessment In the Division.  And, lastly, Mr. Murray Newton

who is Program Manager for State Programs, also with the

Hazardous Waste Management Division.

               In addition to this meeting in Newark today,

three other identical sessions are being held in Chicago,

Houston and San Francisco during these first two leeks of

December.  Persons not wishing to deliver a statement here,
may send a statement, a written statement to the address

noted in the Federal Register before January 31, 1976.

               As our time here is limited, I would now

like to describe the procedural rules for this meeting

which I feel will maximize the opportunity for persons in-

terested in speaking to be heard and yet make the best use

of all of our time.

               Persons wishing to make an oral statement

who have not made an advanced request by telephone or in

writing, should indicate their interest on the registration

card.  If you have not indicated your intention to give a

statement and you decide to do so, please return to the

registration table, fill out another card and give it to

one of the staff.

               As we call upon an individual to make a

statement, he should come up to the lectern and after iden-

tifying himself for the court reporter, deliver his state-

ment and at the beginning of the statement I will inquire
                            s

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as to whether the speaker is willing to entertain questions


from the panel and from the audience for that matter.   He


is under no obligation to do so although within the spirit


of this information sharing meeting, it would be of great


assistance to the Agency if questions were permitted.


               It is expected that statements will not ex-


ceed fifteen minutes in length.  For extraordinarily long


written statements, I would suggest a brief oral summary


and submission 01 the full text for the record.  The chair-


man reserves the right to close off statements which are


excessively long, irrelevant, extraneous or repetitive.

                                          o
               Assuming that the speaker Js permitting ques-


tions, members of the audience will not be permitted to


directly question the speaker.   Members of the audience


may obtain a 3 x 5 card from a member of the staff upon


which questions may be written.   These cards will be col-


lected by the staff and returned to the panel for consider-


ation during the question period.  If a written question


from the audience is not presented to the speaker because


we run short of time, I will ask the speaker to respond to


those questions in writing for the record.


               Now, a transcript of the meeting is being


taken.   A copy of the transcript, together with copies of


all documents presented at the hearing and all written sub-


missions, will constitute the record of the meeting.  A copy



                                6

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of the record will be available for public inspection by



March 30, 1976, at the U.S. Environmental Protectioi Agency




Public Information Reference Unit, Room 2404, 401 M Street




S.W., Washington, D.C. 20460.




               Finally I would like to describe the days




activities as we currently see them.   We will recess for




a fifteen minute break at 10:30 A.M., a one hour luncheon




break at 12:15 P.M. and reconvene at 1:15 P.M.   Another




fifteen minute break will be held at 3:30 P.M.  Depending




on our progress, I will announce plans for a dinner break




after lunch.  At this time we plan to conclude this meeting




today.  We may have to run  past  dinnertime to do this,




however, because we have a large number of people who wish




to give statements.




               In order to facilitate the comfort of all,



I suggest that smokers sit on the left side of the room



facing front and non-smokers towards the right.




               This concludes my opening remarks.   I




would like to at this time introduce Mr. Conrad Simon,




Director of the Environmental Programs Divis ion for Region




II of the U.S. Environmental Protection Agency.  Mr. Simon




please.




               MR. CONRAD SIMON:  Good morning, ladies and




gentlemen, on behalf of the Regional Office of EPA, I




would like to welcome you here to this meeting and to





                             7

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welcome our colleagues from headquarters here to Newark.



               Over the past few years, the intensive Feder-



al and states' efforts to control and clean up air and water



pollution has steadily led to an increasing demand for dis-



posal of waste on land. Many of these wastes have been



labeled "hazardous" by a  definition currently in use.



This condition has led to a new strong thrust by the Federal)



govermtEnt and EPA to bring hazardous wastes undercontrol



whether under our current authorities or under proposed new



legislation and in order to do this we believe that Federal



invlvement is necessary.



               Hazardous wastes by our definition include



toxic chemicals, pesticides, acids, caustics, flammables,



explosives, biological and radiological residuals.  Many



of these, of course, are carcinogenic or cancer forming.



Their primary source is the industrial sector but many



institutions, particularly hospitals and laboratories gener-j



ate significant amouncs of hazardous wastes.



               In our Report to Congress in 1973> we esti-



mated the total amount of non-radioactive hazardous wastes



generated in the United States to be approximately 10



million tons per year or roughly 10$ of all industrial



wastes.  Recent information indicates that this number may



be on the low side.   We estimate that about 40$ of these



wastes by weight in organic material and about 60$ is or-




                               B

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ganic, that about 90$ occurs In liquid or semi-liquid form



and over 7056 or the hazardous waste  generated is generated



in the somewhat highly industrialized areas of the Mid-



Atlantic states, Great Lakes, Gulf Coast areas.



               During the past two or three years the pub-



lic health and environmental consequences of a proper waste



disposal to the land have become an area of growing concern



with the recognition of the high potential for growing



water contamination, by leachate from landfills, surface




water contamination by run off from landfills,  air pollu-



tion by open burning and evaporation and, of course, person-



al injury by way of direct contact and explosions which




may result from the mixing of wastes in landfill ooerations.



               We see an increasing opportunity for adverse



impacts from hazardous waste disposal from three primary



sources; the first is the expansion 01 industrial produc-



tion which is tied directly to hazardous waste generation.



Next is the transfer of hazardous materials from other media



to the land as a result of air-water pollution controls,



third is the increase in hazardous waste materials destined



to the land as a result of controls on ocean dumping and



cancellation of the use of certain materials such as DDT.



               Taking these factors into consideration, we



estimate that the growth of hazardous waste generation in




the United States in the next few years will be in the order




                               9

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of 5 to 10$ per year.



               We believe that technology is adequate for



the treatment of most hazardous wastes by physical, chemi-



cal, thermal or biological means.   Especially designed



landfills  which isolate hazardous wasbes from the environ-



ment by way of natural or artificial membranes with gas



andleachate collection where necessary, can be and have



been built.



               There are secure storage facilities avail-



able for those few wastes to which current treatment and



disposal technology does not apply.   The main problem



appears to be that the use of tnis technology is expensive



and far exceeds the cost of current practices.



               For example,  the cost  of incineration of hazardous



wastes can run as high



        as $50 per ton whereas the current inappropriate



practices of open dumping may cost only $3 or $4 a ton.



Because of this wide disparity between the cost of proper



disposal practices and the harmful practices currently



allowed in many places, there is generally no obvious or



direct economic incentives for using environmentally ac-



ceptable practices.



               Unfortunately, the land disposal of hazar-



dous wastes is essentially unregulated at the Federal




level and in most states.   There are only two areas in



                           10

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which Federal authority exists to deal with parts of the




hazardous wastes management problem.   These are the




Federal Insecticide, Fungicide and Rodenticide Act, that's




the pesticide act, which provides for EPA regulation of the




storage and disposal of wastes, pesticides and containers




and the Atomic Energy Act of 195^ as anended which provides



for Federal regulation of radioactive wastes produced in




fision reactions.



               Although most pesticide and radioactive




wastes can be Jabeled hazardous, in aggregate they represent




only a small fraction of the total hazardous waste problem.




               It is our current position that environmen-




tal insult and the hazard of improper waste management will




continue in the absence of strong, uniform regulation of




land disposal on a national basis and vigorous enforcement




of regulations on a state and local basis.




               As long as the economic pressures tilt the




balance toward improper disposal, as long as no consistent




and uniform rules exist for public and private operation,




as long as offending sites cannot be closed because no al-




ternatives exist, the necessary transition from poor en-




vironmental management to optimum management will not take




place.




               With this in mind, we have scheduled these




series of meetings, as Mr. Lehman has mentioned, in order





                              11

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to elicit your ideas, the ideas, comments, opinions, recom-



mendations, etc. of representatives of government, indus-



try, labor and the public at large, in order to assist the



Agency in developing guidelines for hazardous waste manage-



ment.



               We thought Newark would be  a suitable site



for such a meeting and for this first meeting because the



Northeast and New Jersey in particular is one of the most



highly industrialized areas in the country and is therefore




faced with a particularly serious hazardous waste management



problem.  In addition, a number of other states in the area



are generating hazardous wastes and can take advantage of



the accessibilit^or Newark by transportation means to get



here.



             I'm glad  to see that we have a rather large



turn out and I'm very happy that you could come here today



and I hope that you will take this opportunity to give us



your opinions whether they are pro EPA, EPA ideas or other-



wise.



               Thanks a lot for coming.



               MR. LEHMAN:  Thank you, Mr. Simon,  Let me



add my welcome to all of you, to that of Mr. Simon.  I



now call upon Mr. William Philipbar of Rollins Environmenta:



Services to deliver the first statement.  Mr. Philipbar,




will you take questions?

-------
               MR. WILLIAM B. PHILIPBAR:  Sure.



               We want to thank. Jack Lehman and the Federal




EPA for allowing us to make these statements.



               The management of hazardous wastes in



regional treatment plants has passed from the sound con-



 cept stage to proven, practical, available technology.



Rollins Environmental Services, Inc. has pioneered the bus-



iness of treatment, disposal, and recovery of hazardous



wastes.  Having started this industry in 1969, Rollins



Environmental Services is a Wholly owned subsidiary of



RLC Corp. which is a $180,000,000 company whose stock is



traded on the American Stock Exchange.



               To date, Rollins has invested some $6,000,000



in the development of technology and $18,000,000 for con-



struction of three regional hazardous waste treatment plants



Rollins is the acknowledged leader in this pioneer industry.



The $18,000,000 in construction costs have provided sound



base facilities for the treatment of hazardous waste pollu-



tants while the development expenditures have provided



extensive in-house technology and know-how for the economi-



cal treatment of hazardous wastes.



               The Rollins Plants located in Logan



Township, New Jersey, Baton Rouge, Louisiana, and Houston,



Texas, offer indemnified hazardous waste disposal service



to the Mid-Atlantic and the South Central region which,





                              13

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 according to the EPA June, 1973, "Report to Congress on




Disposal of Hazardous Wastes" represents over 47 percent of




the hazardous waste generated in the United States.  These




plants also receive wastes from New England, South Atlantic,




North Central and Southwest regions.  The existing plants




have a total capacity to incinerate, biodegrade, and




chemically treat about 360,000 tons of waste per year and




are now operating at less than 40 percent of this capacity.



These plants, in operation for almost seven years represent




accumulative operating knowledge of over 20 years.  These




plants utilize treatment processes to perform volume reduc-




tion, component separation and detoxification.  Usually,




several processes are required to handle a given waste



stream.




               These treatment processes, or unit opera-




tions, are basically thermal biological oxidation and




Chemical treatment.  Material recovery is also carried out




but at a much lower level because of the lack of further




development funds.




               We are a private company whose whole func-




tion is the management of hazardous wastes.  We have not




had the benefit of any public financing and, therefore, the




cost of management is being borne by those who generate




the wastes.




               The critical problems that we faced are:






                                 1't

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               1.  That the volume of business offered to




the three regional plants is not sufficient to make the




Rollins Environmental Services a profitable company.



               2.  The lack of return on the Rollins in-




vestment reduces the ability of Rollins to improve perfor-




mance of present plans and to expand to other areas which




require this type of coverage.




               These problems stem from the fact that land




dumping and deep well disposal practices are prevalent and



are continuing.  Because wastes, generally, have little or




no intrinsic value, getting rid of tnem in the cheapest




way is a route that will prevail even though it is environ-



mentally unsound until there is adequate legislation and



enforcement to prevent these practices.




               The cost of treatment at a regional plant




varies from fifteen to more than one  hundred dollars per  ton



depending on the treatment methods required.  These costs,




although higher than dumping or deep welling are not,  we




feel, prohibitive.   As incremental costs in the orocessinq




and manufacturing industries, they are but a tiny fraction




of the total operating costs which are dominated by large




fixed costs, raw materials, labor and distribution expenses.




              AS was  stated at the start of this presen-




tation, regional treatment of hazardous wastes has passed





from a sound concept stage to proven, practical, available




                                 "' ^
                                 j. J

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technology, but without sound legislation and enforcement,



private capital will not be allotted to this need.  It is



felt thai. Federal legislation is required to set the over-



all guidelines for the management of hazardous wastes with



the states having the ultimate responsibility, similar to



the present Clean Air and Water Acts.



               Control or the hazardous wastes from the



generator to the ultimate disposer is a must.



               A manifest system is recommended where,



for each load of waste, the generator initiates a manifest



describing the waste, the hauler and the dispoer.  The



hauler fills in the portion of the manifest outlining that



he has completed his job and the disposer completes this



document outlining treatment and disposal procedures and



dates.   These are all funneled back to the state for con-



trol purposes.



               Let's now go to the discussion topics as



outlined in the Federal Register that announced this meeting



Unfortunately, time does not permit a thorough discussion



of each question and we would be happy to discuss these



questions in detail with those interested.



               1.  On the definition of hazardous wastes.



It is felt thai the definition of hazardous wastes given in



the EPA "Report to Congress.."  is a good one, and I won't




repeat it here, but I think, is one that most of the people





                                  16

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 in the industry subscribe to.




                The sampling of hazardous wastes is another




 question tint is asked and this is a difficult problem.




 Sampling, as any chemist or chemical engineer knows,even a




 virgin material,is difficult.    We would not take into




 our plants a waste stream until samples are collected,




analyzed and a treatment procedure outlined.   Every truck




 load of material coming into the plant is again analyzed.




                Samples from tanks, the customer's tanks




 and the tank trucks are thiefed so that the bottom, middle




 and upper portions are sampled.




                Waste in the lagoon is a tough problem as




 far as sampling.  We try to take samples from a number of




 different spots and depths in an attempt to obtain repre-




 sentative samples.




                Analytical-laboratory methods used are im-



 portant as the waste profile must be pretty well outlined.




 Basic wet chemistry analytical methods are used along with




 atomic absorption techniques for metals, calorimeter for



 BTU measurements as well as mass spectrograph and infrared




 for more definitive analysis.




                Setting criteria for the identification of




 hazardous waste versus non-hazardous waste, which is




 anotit r question that was asked in the Federal Register, is




 a difficult problem.   In order to have effective legislation





                           I"

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and enforcement, criteria have to be set and. identifica-



tion should be relatively simple and yet it is not a simple



problem.



               A suggested approach is as follows where



all materials falling in the following categories would



have to be detoxified before ultimate disposal:  And, here



again is a list.



               A)  Halogenated hydrocarbons except those



compounds and concentrations that are generally accepted



as non-toxic to man or animal.



               B)  Toxic metal salts or other compounds



which have appreciable solubility in ground waters at



 normal pH ranges that are greater than the potable water



Standards including arsenic, barium, beryllium, cadmium,



copper, chromium, lead, selenium, silver, zinc and mercury.



               C)  Cyanides and sulfides including, but



not limited to  sodium  and potassium  cyanide,  the metal



cyanide from plating operations such as copper.



               D)  Water soluble phenolic compounds that



have been shown to exert toxic effects including phenols,



cresols, cresylic acids and their derivatives which are



water soluble to levels higher than acceptable potable



water standards.



               E)  Explosives.



               P)  Water soluole dyes and byproducts of the


                          Ln
                          o
IP

-------
manufacture of water soluble dyes including dye stuff which




might be solubilized by variations in ground water acidity.




               G.  Pesticides and herbicides as well as




containers contaminated with these products.



               H.  Acid wastes and aqueous acidic solutions




that would adversely alter ground water and surface water




properties to ai extent that would make them unsuitable for




public use.




               I.  Flammable materials falling into the



NFPA category four.




               The next question asked was the recovery




and reuse of hazardous material.  We feel that this is al-




most totally an economic consideration.  If a waste stream




can be more cheaply recovered and reused than disposed of




in other ways., it  generally finds its way into a recovery




situation.  Most solvents are recovered this way.  A large




amount of metals,  both ferrous and non-ferrous also go the




recovery and reuse route.




               However, the vast majority of materials that




find their way into a plant such as ours are not recovery




candidates.  It is felt that all hazardous organic materials



that cannot be economically recovered should be incinerated.




This includes aqueous organics with BOD's at a level that




cannot be readily  blodegraded as well as highly concentrated




cyanide compounds.   When you get to inorganic materials

-------
you have chemical and physical treatment that are intended



reduce volume, detoxify, change the physical form, separate



and isolate the hazardous portion of the waste  streams.



Low order of aqueous organics can be economically treated



through bioloqical degradation.  The land placement of



hazardous wastes should only be done after they have been



detoxified or stabilized so that they no longer pose a



hazardous problem.



               The next portion or the question had to do



with cost data.  And, having been in the business as long



as we have, we have extensive cost data on a number of



different unit operations and these can be made available



for interested people.  Costs per pound are obviously a



function of the number of pounds processed, type of materia.



treatment methods, etc.  Overall, as I said before, the



costs of handling hazardous wastes can range from fifteen



to well over one hundred dollars per ton.



               Safety precautions.  The safety precautions



that are required in the handling of hazardous wastes are



similar or the same as those in any chemical plant that is



handling the virgin materials.   These precautions are well



defined and have been a practice for a number of years.



Control or material is a key word in safe handling.  Know-



ledge or what the composition of material is and then




assigning proper control methods is essential.



                         20

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               For the overall government control of the



management of hazardous wastes, we feel the manifest system,



as previously discussed, is a must with the haulers and the



disposal sites licensed and inspected by the state with



stringent requirements for all who are involved in hazar-



dous waste management.



               Insurance.  Insurance has not been a problem,



as far as we are concerned.  We accept complete responsibil-



ity for the waste when it leaves the generator's plant if



it is in one of our trucks and if the waste has been pro-



perly identified.  Our umbrella policy for this type of



indemnification is over $20 million.



               Strict control over what is to be landfilled



and what pretreatments are needed to detoxify materials



to be landfilled have to be set and enforced.  The basis



for these criteria were previously outlined.   Again, the



manifest system is the surveillance tool needed to give you



the enforcement power.



               Another question was on the transportation



labeling of hazardous waste.  The Department of Transporta-



tion has jurisdiction  over the hauling of both intra and



interstate hazardous wastes hauls.  The D.O.T.  regulations



covering the hauling of these materials are presently ade-



quate in our opinion and if properly enforced,  should in-




sure safe transportation.  The same regulations cover




                          21

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labeling and placarding of wastes for shipment.




               It is strongly felt that the private sector




should be the mechanism for the management of hazardous




wastes, being responsible for the transportation, treatment




and ultimate disposal.  Most of the technology and know-how




is available and the private sector will meet this demand




when proper legislation and enforcement creates it.




               MR. LEHMAN:  Thank you, Mr. Philpbar.



I would like to point out that Mr.  Alan  Corson of  our  staff




in the dark suit in the back, he has the 3x5 cards and



will pass them out or collect them if you have any ques-




tions.    Why don't you raise your hand if you want to fill




out a card to ask questions.




               Meanwhile, does any of the panel have a ques-




tion of Mr. Philipbar?  Yes, Mr. Sanjour.




               MR. SANJOUR:  Mr. Philipbar, you were comment




ing about the, if I could focus in on the information that




you need to treat waste and trying to match that up with




what we know about the Department of Transportation label-




ing and placarding  is it your opinion that the information




on the label and in this case the label is sufficient for




you to operate on?




               MR. PHILIPBAR:   On the placard or on the




bill of lading?




               MR. SANJOUR:  Well, on the label hopefully, i

-------
it is properly labeled.

              , MR. PHILIPBAR:  On a drum or sometning  like

that.

               MR. SAJMJOUR:   Right.  Is that usually  suf-

ficient for you to treat?

               MR. PHILIPBAR:  No, we get a full run down

of the analysis or we try to from the generator, and then

we analyze it ourself.   We certainly wouldn't go with

what is on the label itself.   We feel as far as transpor-

tation and any problem on route, that usually the labeling

is sufficient to find what's going on.

               MR. SANJOUR:  Tnank you.

               MR. LEHMAN:  If you wouldn't mind just

standing there, Mr. Phil£bar, while we collect the written

questions.   I just want to alert the next two speakers

in order so that they will be prepared to come up.   We

intend to have Mr. Conner and Mr. Santoleri, in that order,

following Mr. Philipbar.  We have some questions now.  Mr.

Kovalick, do youwant to read the questions?

               MR. KOVALICK:  Mr. Philipbar, how does  your

legal responsibility change if the delivery to your ptot

is made in the generators or the originators vehicles

versus your own?

               MR. PHILIPBAR:  Well, we, qgain, take title

of the waste if it is our own vehicle when the truck

leaves the generators plant.   If it is sent in their
                        23

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vehicle, we will take title when it comes on our property.




Now, tnis is still a moot point on whether or not you can




or can't take title.   We take responsibility, full title.




               MR. LEHMAN:  Mr. Lindsey?




               MR. LINDSEY:  Mr. Philipbar, can sulfuric



containing wastes be handled by incineration and if so are




SOX emissions a problem?




               MR. PHILIrBAR:  We handle organic sulfur



from          wastes in several of our plants, and our




serubbing equipment has been sufficient to handle SOX.




We are careful on how much we burn at any given time.




               MR. LEHMAN:   Are there any other questions?




If not, thank you very much, Mr. Philipbar.   I would ask




that each speaker who has a prepared statement, that is a



written type version of his recitation, that he make that




availaole to the panel and also the press table before he




gives his speech.



               I might point out here, in amongst the ques-




tions that were brought up, there was one addressed to me,




and I want to reiterate that we are here to listen, not to




orate, so please address your questions to the people who




have made their own presentations and not to EPA, if you




will please.



               Our next speaker is Mr. Jesse Conner of




Chemfix, Inc.  Mr. Conner, please.

-------
               Will you accept questions, Mr. Conner?
               MR. CONNER:  Yes.
               Thank you.  It is a pleasure to be here this
morning.
               As a representative of an industrial firm
engaged in the treatment and disposal 01 hazardous waste
residues, I would like to address my comments toward
Discussion Topics 3, k, 5 and 16 as listed in the notice of
this meeting published in the Federal Register, September
17, 1975.
               These topics deal with:   What types of trea
ment can be applied to various wastes?  Which processes or
practices are most effective?  What should be the extent
and mechanism of involvement by the private sector in the
treatment and disposal of hazardous wastes?
               In spite of wishful thinking on the parts
of the public, regulatory agencies, and much of industry,
it is obvious that the large bulk of waste residues, hazar-
dous and non-hazardous, will eventually go to the land.
Much of the recovery or reuse which is presently economic-
ally feasible is already being done before these materials
become residues.
               Future process improvements will have some
effect on reducing the amount of waste generated per unit
 of product.   Some wastes can be thermally or chemically

                    25

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transformed into only water and carbon dioxide.  Volume




reduction can be practiced to some extent, certainly more



so than presently being done.  However, even with these




various possibilities, the phasing out of ocean dumping,




deep well injection, and permanent lagooning as disposal




methods, will, in the balance, put greater pressures on




the land.  Therefore, it is essential that we find ways




to place these materials on or in the land in such fashion




that they are either non-hazardous and environmentally




acceptable when such disposition is made, or if this is




not possible the wastes must be secured under perpetual




care so that the probability of release into the environ-




ment is eliminated.




               One of the newest and potentially most use-



ful unit processes in the hazardous waste disposal field



is "chemical fixation and solidification".  In this ap-



proach, hazardous components of the waste are chemically



altered, encapsulated, or otherwise Immobilized so that




they are not available to the environment under planned




disposal conditions.  In addition, this results in a ma-




terial which is sufficiently solid so that when disposed




on land, it does noi. destroy the useful physical proper-




ties of the land.  Solidification of liquid, hazardous




materials also assures that the waste can be located and




recovered for some future positive economic use, or for





                       26

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further treatment.




               This latter consideration - being able to




locate and recover waste material at a later date - has




never been more pertinent than at this point in time, when




we are discovering that many substances previously believed




to be harmless are potentially hazardous.




               There is no possible way that we can know




the full effects of all the tremendous spectrum of modern




synthetic chemicals and other materials on human beings,




plant, animals and aquatic life.  Therefore, if through




lack of available information or technical  capabilities




we are unable at this time to proceed further in the treat-




ment of a waste, it is essential that we be able in the




future to rectify such mistakes with minimal environmental




damage.  This cannot be done if a potentially hazardous




material is dispersed in a nonrecoveratle fashion, such




as in ocean dumping, deep well disposal, or land spreading.



               Specifically, chemical fixation and solidi-




fication techniques are capable of dealing with most in-




organic, water based, solutions, slurries or sludges.




The Chemfix Process can tie up toxic heavy metals in chem-




ically insoluble forms that remain inert under acid and




alkaline ground water conditions and under the influence




of other environmental factors such as ultra-violet light,





biological action, and weathering.




                            27

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               By proper application of tnese techniques,



the wastes can be rendered harmless for a specific intended



disposal program.  For example, treated wastes can be



placed in sanitary landfills (often replacing dirt as



cover material) or used for structural landfill in certain



applications.



               In the case of sewage sludge, chemical fix-



ation provides a safe means for utilizing the fertilizing



and soil conditioning capabilities of this material while



njnimizing its detrimental attributes which have prevented



widespread use for this purpose in the United States.



               Chemical fixation and solidification tech-



niques also apply to certain organic wastes.  Water based



sludges containing large quantities of organics, e.g.,



sewage, sludges, refinery sludges, etc., can be success-



fully treated to produce an environmentally safe fill ma-



terial.  More difficult organics such as pesticides can be



completely encapsulated in much more expensive, but still



useful organic polymeric systems.



               The Chemfix Process is a proven commercial



process which has been used to treat more than 110,000,000



gallons of industrial and municipal IJquid wastes.  It is



available as a mobile service for on-site treatment, as



a unit process at central treatment sites, and as a cus-



tomer operated, in-plant, treatment facility.  The




                         20

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mobile service and in-plant facility are available any-
where in the United States (also in Prance, Japan and the
United Kingdom).  Central site treatment is available in
several locations now, and is being expanded under license.
               Chemical fixation and solidification can
be, and frequently is, the least expensive environmentally
acceptable method for the disposal of waste residues, es-
pecially those occurring in very large volumes.
               Typical costs for large scale treatment
presently range from 40 to 10^ per gallon.  Treatment costs
for materials not capable of being handled in this fashion
generally range upward from 10^ to $1.00 per gallon or
more.
               Accurate and meaningful cost data are avail-
able from private companies doing this type of work.  In
almost all cases, costs for proper disposal are higher
than those previously encountered for indiscriminate dump-
ing, just as it is much cheaper to discharge dirty water
or contaminated air than to apply the appropriate water
or air pollution control measures.
               As long as cheap, "non-control" disposal
techniques are available to industry, we can expect that
they will be used regardless of the effect on the environ-
ment.  As with any other segment of the environmental con-
trol picture, Federal, State and Local legislation,
                           23

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regulation and enforcement are essential before any real



control of hazardous wastes is accomplished.




               In almost all cases the private sector is




capable of handling the treatment and disposal of hazardous



wastes from any source, including radioactive materials.




Private companies have already paid the price (both in




development  costs and in poor profitability)  during the




last five years to form the nucleus of an emergent indus-




try treating hazardous waste residues.




               In spite of the economic difficulties and




risks with which it has had to contend, the private sector




has at this time more than sufficient capacity to handle




the existing level of business in the hazardous waste




area, and in my opinion, it stands ready to expand as




soon as it has reason to do so.




               However, such procrastination as is pre-



sently taking place in the passage of the proposed Federal



hazardous waste legislation will eventually weaken the




Industry's ability and willingness to provide the neces-




sary capital to prepare for the needs of the future.  This




procrastination is not primarily the fault of the regula-




tory agencies.  Without enabling legislation, funds and




other resources necessary to do their job, they cannot be




expected to assure proper disposal of hazardous materials




in the future.




                             30

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               Thank you.




               MR. LEHMAN:  Thank you, Mr.  Conner.   Will




those who wish to submit a question please  raise their




hand.   Meanwhile, Mr. Lindsey?




               MR. LINDSEY:  Mr. Conner, you discussed




certain structural properties, I believe, of ChemfLx ma-




terials.  Can you comment somewhat on the normal load




bearing capacity of normally Chemfix wastes?




               MR. CONNER:  Yes, they vary  quite a. bit,




depending upon the material being treated and also the aim




being used because this process  as other solidification




processes can be varied to meet these requirements.  In




general, we end up with load bearing capabilities that




range from as low as half a ton per square  foot to five




tons a square foot or more,,   I'm not a soil mechanics




man but I understand 5 tons per square foot is reasonable



soil load bearing capacity.




               However, these materials are not soils,




they have different properties and so the testing proce-




dures are somewhat open to question.




               MR. LINDSEY:  I have a written question




here.  How long after chemical fixation in landfill is




the landfill available for use, capable of bearing struc-




tures, how long after?




               MR. CONNER:  Generally within a week and

-------
more often within several days it has achieved perhaps 90$




of its final bearing strength and general physical proper-




ties.




               MR. LEHMAN:  Mr. Sanjour.




               MR. SANJOUR:  I've got a question here for




you, Mr. Conner.   Cost of 4^ to 10^ a gallon, does that




include hauling costs?




               MR. CONNER:  It does not include hauling



costs,no.




               MR. LINDSEY:   One more here.  Are there




any materials that you process is either unable to handle




or less readily able to handle than others?




               MR, CONNER:  In general the process is only




capable of handling water based residues.   Solvent based




residues are not handable with this process.  And, also,



there are a number of water soluble organic hazarouds ma-




terials which we do not handle.  The solidification can




be accomplished, but the material remains hazardous due to




leaching of these kind of materials, so it is not suitable




for these.




               MR. LEHMAN:  Mr. Conner, I have another




written question.  It  says, you cite lack of dollars as




the reason for lack of EPA regulations, isn't it really




a lack of closer coordination by EPA officials?




               MR. CONNER:  Well, I don't think I said

-------
that the lack of dollars was the reason for the lack of




EPA regulations, necessarily.  I think what I was trying



to say is that first you need enabling legislation and



then you need the funds to allow whatever regulatory



agenfcy that is involved to in fact do the regulations, to



hire the people and spend the money to do regulation, this



is what I was trying to say.



               MR. LEHMAN:  Are there any other written



questions?   We have one more coming here.



               Mr. Conner, you have indicated that you may




do business in a variety of states around the country,



what has your experience been as far as effects on your



ability to do business in states that ha\e regulations



versus those who do not, they are in substantial difference



would you like to comment on that?



               MR. CONNER:  Well, in general there is rela-



tively little impetus for anybody to engage in a more ex-



pensive process such as Chemifix as opposed to just land



dumping of material in a state that has no regulations or



in which the regulations aren't being enforced, so we find



that where the regulations are there, where they are being



enforced we are able to do business, where they aren't, it



is only possible to do business where the individual com-



pany essentially has adopted the good neighbor policy on




its own, and this is rather difficult for an individual





                          33

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company, especially an individual plant to do because it




makes tnem uncompetitivewLth other people who aren't doing



this.




               MR. LEHMAN:  Mr. Lindsey.




               MR. LINDSEY:  I have a question here, who




do you feel should make the decision on what specific pro-




ducts should be or should not be chemically fixed, who do




you feel should do that?




               MR. CONNER:   I think the general guidelines




as to what materials are hazardous, what materials are




suitable for this kind of treatment in a general way should




be done by EPA.   I think when you get down to specifics,




it will have to be and will be done by the individual




states, but I think they need the guidelines, they do not



and probably will not from my experience have the technical



capability to really make these kind of judgments.




               MR. LEHMAN:  Are there any other questions?




Thank you very much, Mr. Conner.   At this time I would




like to call Mr. J. J. Santoleri from Trane Thermal Co.,




and just to alert the next speaker, Mr. Palmer from the




DuPont Company.   Mr. Santoleri, will you accept questions?




               MR. SANTOLERI:  Yes.




               MR. LEHMAN:   Mr. Santoleri, will you please




identify your company and its location.




               MR. SANTOLERI:  I am with the Trane Thermal

-------
Company, formerly Thermal Research & Engineering Corporatioji




out of Conshohocfcen, Pa.




               I want to thank the U.S. Environmental Pro-



tection Agency for allowing us to give this discussion



this morning.



               Technological advances over the past thirty



years have created many new industrial processes which



have enabled all of us to live much more comfortably, but



at the same time have created wastes which, in most caes,



can be considered hazardous to human health and the en-



vironment .



               We are talking about hazardous wastes this



morning, I will attempt to give our experiences in the



thermal processing of these hazardous wastes.



               The first installation we put in was approxi-



mately twenty-five years ago and since then we have put in



well over 400 installations for processes which we con-



sider as hazardous wastes.



               The companies we dealt with were companies



who were concerned about    the protection of their own



personnel, the handling of the materials within their



plant properties, as well as the local community.   These



responsible people were concerned about how to dispose of



these wastes and we were called in in many cases to de-




termine whether this could be done by thermal processing.




                             35

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               I will list some of the processes that we



have looked at, some of the solutions we have accomplished



and give you some idea of the different areas that you can



find hazardous wastes.



               In Chemical processes we looked at



the Acrylonitrile process.  This contains fumes with



acetyl chloride and hydrogen cyanide.



               Caprolactam process contains wastes with



aqueous liquids containing adipic acid, also tars and



sodium compounds.



               In the agricultural industry we find in the



past couple of years there has been a great growth in any



process involved in the agricultural industry, primarily



with the production of herbicides, pesticides and insecticides.



Here we find wastes containing chlorinated hydrocarbon



liquids and gases, also aqueous wastes containing organic



and inorganic materials, some of these containing sodium



and phosphorous compounds.



               In the Preon process we have handled



fluorinated hydrocarbon liquids and gases.



               Phthalic Anhydride process.   Here we find



fumes containing phthalic and maleic anhydride, carbon monox|-



ide and air.  Also waste liquids containing phthalic and




maleic anhydride.




               In the plastics industry, phendic tars and





                              3C

-------
fumes; polyvinyl chloride, chlorinated hydrocarbon  liquids




and gases.




               In the Vinyl,chloride process,  chlorinated



hydrocarbon  liquids, ethylene dichloride  liquids  and  fumes.




               In the Amunition Plants we have handled




trinitor toluene; which is a waste from their process;




nitrogenated compounds, both gases and liquids.




               Asphalt Plants, Gases containing hydrocar-




bons, steam and air, as well as liquids.




               Coal Gasification Plants and Coal  Liquefac-




tion Plants.   Most of these are in the pilot stage now




but these also generate wastes which are toxic and hazardou




               Pood Plants.   People consider the odors




from coffee roasters as toxic or at least injurious to the




neighborhood, we find many people in the  area  like  the odor,




they know the plant is running when they smell it,  but




they still have to take care of it.




               Fiberglass Plants.  Phenolic fumes are usua




ly generated in the operation of the fiberglass plants.




               Paint Plants.  Aqueous wastes and  caustic



and latex.




               Pharmaceutical Plants.   Both fumes and




liquids from drug drying processes, solvents containing




toluene, diethyl ether and acetone; aqueous wastes con-




taining caustic, also phosphorous and sodium compounds.

-------
               Rubber Plants.   Fumes containing hydro-



carbons, polystyrene tars.



               In the Space Industry, liquid wastes con-



taining unsymmetrical dimethyl hydrazine and nitrogen



tetraoxide.



               Sulfuric Acid  Plants.   Gases containing



hydrogen sulfi& and sulfur dioxide.



               Tobacco Plants.   Fumes containing nicotine



ammonia with steam.



               Wire Enamelling Processes.   Both fumes and



liquids containing phenol.



               And, in the automotive industry, primarily



aqueous wastes containing oils and tars from the machine



operations.



               These are only a few of the problem areas



which we have been exposed to over the years.  In order



to handle the problem from a thermal processing standpoint,



we first must know whether it is solid ,liquid or gaseous.



In all cases, these wastes, if they are organics can be



considered as combustMe and can be thermally processed.



               Second, we will want to know whether the



waste is all organic or a percentage is organic, and whe-



ther the inorganic portion is water, inorganic compounds



or a combination.





               Third, we need to know why the waste is




                          30

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hazardous and to what degree.  This is necessary for the




material handling step prior to incineration, as well as




determining the conditions for incineration.




               Depending upon the nature of the material,




temperature and residence time must be determined to insure




complete destruction of the hazardous components.




               Finally, in order to optimize the process




design of the thermal processing system, we must know the




precise chemical formula and the concentrations of the




materials involved. This is necessary to simplify the




prediction of the results of the processing operation.




               What I would like to spend a little time




on this morning is Chlorinated Hydrocarbons.   We have had




quite a bit of experience in handling chlorinated hydro-




carbons and we find that this presents problems in many




plants.



               In recent months a great deal of discussion




has been directed toward the processing which takes place




in the vinyl chloride monomer plants,  in this area we




have installed quite a number of thermal units.   This is




in the disposal of waste fumes from venting of various




parts of the process and liquid wastes from various parts




of the operation.




               In approaching a problem we know the compos-




ition of the waste, the quantify of the waste and what

-------
variations you will have in the disposal of these wastes.
When it is a liquid waste normally this can be tanked and
stored so that you can have a continuous level of opera-
tion of your waste disposal system.   However, if this is
a venting operation, it is very difficult to try to vent
and store gases, so your system must be able to take
swings and be able to handle the vent gases as they are
generated and properly destroy them.
               The composition of the waste is critical
in determining what will occur in the incineration step.
Physical data determines the reaction, the temperature and
the products of combustion.  Normally this can be deter-
mined prior to the design of the system.   However, in
cases where this physical data is not available, we recom-
mend that tests be run on the materials, especially in the
case of the liquid wastes.
               If the composition is such that it will
sustain combustion, auciliary fuel will not be required.
However, if the waste is essentially all water with some
chlorinated materials, auxiliary fuel is necessary and it
is also important to determine the quantity of chlorine
that is available in the waste and also the hydrogen avail-
able for hydrolizing the chlorine to HC1.  This is impor-
tant so that chlorine will not go right on through the sys-
tem and be discharged through the atmosphere.
                         1*0

-------
               In combining chlorine with hydrogen to




form hydrogen chloride, this becomes a combustion product



at high temperatures and can be readily quenched and ab-



sorbed in downstream equipment, scrubbers and absorption



systems.



               The conversion  of the chloride portion to



HC1 depends upon the operating temperature, the availabili-



ty of hydrogen in the waste material or hydrogen in the



form of fuel or water that can be added to the system.



               In our experience we have found that it is



critical to design the system to minimize this chlorine



release and at the same time minimize the amount of fuel



necessary to dispose of the waste, especially in these



days of energy shortages.



               Therefore, this is one of the main reasons



why we have to know the composition of the waste material



which will enable the incinerator designer to set the



operating temperature and the auxiliary fuel requirements.



               Since this is a hazardous waste, it is



also important to the plant operator, as well as the de-



signer, to know the composition of the waste material so



that the handling equipment, the piping, the valves,



pumps are designed properly, with the proper materials



to prevent corrosion and leakage of the material into



the environment prior to its Injection into the inceneratoi

-------
               The incinerator also must be designed proper




ly to withstand the temperatures of operation, the swings




because of flows or temperatures and the corrosion result-




ing from the exposure of the lining to the variations in




temperature from start-up to shut-down.




               In burning a chlorinated hydrocarbon the




products of combustion will normally contain carbon dioxide,




water vapor, oxygen, nitrogen and CC>2 as well as HC1.




Improper combustion will result in the formation of




chlorine and hydrocarbons in the stack gases discharged to




the abTiosphere.




               Therefore, proper design of the incinerator




as well as proper instrumentation and control is a definite




requirement to insure complete oxidation of the hazardous




materials and the discharge of a pollution free gas to




the atmosphere.



               In cases where we have incinerated chlori-




nated hydrocarbons,systems have been designed in which the



hot gases are reduced in temperature to permit scrubbing




of HC1 from the gases.  This hydrogen chloride can be ab-




sorbed in water very easily and this water solution neu-




tralized with caustic so we will end up with a salt water




stream.




               Additional equipment can be provided to




permit concentration of the HC1 gases to acid, to any

-------
concentration up to anhydrous HC1.   This will permit dis-




charge from the system to contain only stack gases with




COgj water vapor and nitrogen with some oxygen and the




liquid discharge to essentially the HC1 acid at some con-




centration level.




               In more recent installations, heat recovery




equipment has also been added to utilize the heat available




from the combustion of the chlorinated hydrocarbons.  This,




of course, involves proper selection of materials in your




waste heat recovery equipment.




               We must realize that the main problem in




all cases is the disposal of this hazardous toxic waste.




The addition of equipment to recover heat, or to recover




valuable chemicals, is secondary and must be considered




only if it is economically feasible and does not become




the primary reason for the system.   The system must always




be designed to operate so that the hazardous waste is dis-




posed of properly.




               In many applications where the process is




only on the drawing board, the waste disposal problem is




handled by testing a synthetic material which approximates




the final waste product.   We have done this in many cases




where the plant hasn't even been built but this is a typi-




cal composition of waie product, how do you take care of




it.

-------
                If we haven1t done it before, we suggest a



 test be run to determine what the handling problems are,



 what the injection problems are for the atomizer and also



what the temperature and residence time in the incinerator.



               However, when the plant does get into opera-



 tion, we often find that the synthetic material that was



 used is nowhere  near what the final waste product actual-



 ly is.  So, it is necessary to determine how flexible a



 system has to be before it is put into operation, determine




 what additional equipment should be Installed to take care



 of the difference between the synthetic and the actual



 waste.  This should be an agreement between the user and



 the.designer.



                It is also necessary to determine in the



 test the amount of fuel required.  This becomes a big part



 of the operating cost of the system.  If it is a self-



 sustaining fuel, how much auxiliary fuel will be needed in



 the event the fuel does change in composition.   These



 are all questions that must be answered prior to the final



 design of the system.



                Tests are also necessary to determine the



 products of combustion by gas analysis and also the parti-



 culate analysis in the stack discharge, especially when



 handling inorganic materials along with the organics.



                 Many times the synthetic waste  I mentioned

-------
does not approach the final process waste from the  system,



and we must be flexible enough to permit variations  in com



position.



               In any hazardous waste problem, it is best



to review the process as much as possible todetermine



if there is any way to reduce the waste that is being



discharged.  We found in many cases that the waste was be-



ing discharged but there is no care given to how it was



being generated, we have a waste problem, how can you take




care of it.



               Many times we have found upon investigation



that there were other uses for the waste, minimized the



waste problem and also efficiencies were made in the



operating process to minimize the total waste that was



generated.  When this is done, we found a lot of times




that where somebody has a thousand pounds an hour waste,



he can reduce this to maybe half by going back into his



process, adding equipment which can reduce his waste prob-



lem.



               We feel it is very important when you do



have a situation like this to determine  "  whether you



can handle this at a neighboring facility or whether you



should go into your own total facility.   In going into



your own total facility you have total control, at the




same time you must be jsure that you have qualified people

-------
designing and installing the system.



               With this hazardous waste problem growing



as it has in the past few years, many people are getting



involved, many problems have resulted and many catastro-



phies have also resulted.  Therefore, it is best to work



with a qualified organization, someone who has had the



experience, someone who has been exposed to the problems



of corrosion, operation, maintenance, high temperatures,



incineration.



               Since I am running out of time, I would



like to again thank you for the opportunity to present



our experiences in thermal processing.

-------
THERMAL PROCESSING OF ORGANIC HAZARDOUS  WASTES



                J.  J. Santoleri

             Trane Thermal  Company

            Conshohocken,  Pa. 19428
                                 United States  Environmental
                                   Protection Agency
                                 Hazardous  Waste Management Meeting
                                 December 2,  1975
                                 Newark,  N.  J.

-------
                THERMAL PROCESSING OF ORGANIC HAZARDOUS HASTES

        Technological  advances over the past thirty years have created many new
   Industrial  processes which have enabled all of us to live more comfortably,
   but  at  the  same  time have created wastes which, in most cases, can be considered
   hazardous to  human  health and the environment.  The discussions which are being
   held this morning will enable us to have a better understanding of the term
   "hazardous  wastes".  I will attempt to give you our experiences in the thermal
   processing  of these hazardous wastes.
        Trane  Thermal  Company, formerly Thermal Research and Engineering Corp.,
   receives inquiries  almost daily from companies presently involved in a waste
   disposal problem, or planning a process which will require process waste control.
   Over the past 25 years we have been exposed to many industrial processes which
   generate wastes  1n  all forms - solid, liquid and gaseous.  The easiest way to
   solve the problem is to minimize the amount of wastes that are formed in the
   process by  increasing the overall efficiency of the process.  In the past few
   years many  companies have approached the problem in this manner.  However,
   since it is impossible to get a process to operate at 100% efficiency, there
   will always be wastes generated in the manufacture of any commodity.  In the
   areas in which we have been involved, most of the applications can be considered
   as the  disposal  of  hazardous wastes.
        I  will list below the various processes that we have looked at and  the
   types of waste  that are generated in these processes.
   Process            Waste
1.  menu ca I
   Acrylonitrile      Fumes containing acety] chloride and hyrfroqen c«anirfe.
   Caprolactam        Aqueous liquids containing adipic acid; aqueous liquids con-
                                      taining tars and salts.         t
   Herbicides  &        Chlorinated hydrocarbon liquids and gases; aqueous wastes  con-
     Insecticides                      taining orgsnics and inorganic materials  such
                                      as sodium and phosphorous.
   Freon              Fluorinated hydrocarbon liquids and gases.

-------
    Process
                        Waste
 9.
10.

11.

12.
13.
14.
    Phthalic Anhydride- Fumes  containing  phthalic  and  maleic  anhydride,  carbon  monoxide
                                       and  air; liquids  containing  phthalic  and  maleic
                                       anhydride.
                        Phenolic tars  and fumes; polyvinyl  chloride;  chlorinated  hydro-
                                       carbon  liquids and  gases.
                        Solvents,  fumes,  chlorinated hydrocarbons, eldrin.
                        Chlorinated hydrocarbon  liquids;  ethylene dichloride  liquids
                                       and  fumes.
                        Liquids  -  trinitro toluene; nitrogenated gaseous compounds.
    Asphalt Plants      Gases  containing  hydrocarbons, steam  and air.
    Coal  Gasification   Fumes  containing  coal dust, water vapor and  air.
      Plants
    Coal  Liquefaction   Waste  tars containing hydrocarbons.
Plastics

Pesticides
Vinyl chloride

Ammunition Plants
      Plants
    Food Plants
    Fiberglass
    Paints
    Pharmaceutical
Rubber
Space

Sulfuric Acid
  Plants
Tobacco
Wire Enamelling
Automoti ve
Fumes from coffee roasters and other food drying systems.
Phenolic fumes.
Aqueous wastes with caustic and latex.
Fumes from drug drying processes; solvents containing toluene,
                diethyl  ether and acetone; aqueous caustic
                wastes containing phosphorous and sodium
                compounds.
Fumes containing hydrocarbons; polystyrene tars.
Liquid wastes containing unsymmetrical  dimethyl  hydrazine
                and nitrogen tetraoxide.
Gases containing hydrogen sulfide and sulfur dioxide.

Fumes containing nicotine, ammonia and  steam.
Fumes and liquids containing phenol.
Aqueous wastes containing tars from machine operations.
    These are only a few of the  problem areas  which we  have  been  exposed  to over the

    years.  In order to handle the  problem  from  a  thermal  processing  standpoint, we

    must know first whether the  waste  is  liquid, solid  or  gaseous,  since  organics in

    all  three states can be thermally  processed.   Second,  we will want to know whether

    the  waste is all organic, or the percentage, and whether the  inorganic portion

    Is water, inorganic compounds,  or  a combination.  Third, we need  to know why the

    waste is hazardous and to what  degree.   This is necessary  for the material

    handling step prior to incineration,  as  well as determining the conditions for

    incineration.  Depending upon the  nature of  the material,  temperature and

    residence time must be determined  to  insure  complete destruction  of the hazardous

    components.   Finally, in order  to  optimize the process design of  the  thermal

    processing system, we must know the precise  chemical formula  and  the  concentrations

-------
of the materials involved.   This  1s  necessary  to  simplify the  prediction  of the
results of the processing operation.
Chlorinated Hydrocarbons
     In recent months a great deal of discussion  has  been directed  toward the
processing which takes place in the  vinyl  chloride  monomer plants.   This  is one
area where we have had a great deal  of experience.  That is,  in  the disposal of
waste fumes and liquids from this type of operation.   In approaching the  problem
we must know the composition of the  waste, the quantity of the waste, and what
variations in process waste flow  can be expected  during operation.   When  the
system has only a liquid waste disposal problem,  the  variations  can be satis-
factorily handled by storage of the  liquid in  tanks,  and the  incineration system
designed to operate at a constant rate of disposal.  However,  in a  gaseous system
it is very difficult to consider  storage of gases that are being vented and the
system must be able to handle the wide swings  that  may occur  in  the process.
     The composition of the waste is critical  in  determining  what will occur in
the incineration step.  In many cases the waste has sufficient heating value and
auxiliary fuel is not required.   However, when the  composition is such that the
waste will not sustain combustion, auxiliary fuel will be required.  The amount
will depend upon the composition  of the waste  material.  It is important in dis-
posing of a chlorinated hydrocarbon  material to insure complete  conversion of
the chlorine to hydrogen chloride.  This prevents the discharge  of  chlorine into
the atmosphere.  Hydrogen chloride can be readily absorbed in downstream absorption
and scrubbing equipment.  The conversion of the chloride portion of the chlorinated
hydrocarbon to HC1 depends upon  the operating  temperature and the availability of
hydrogen in the waste material or by the addition of  hydrogen in either the fuel
or water which may be necessary.   In our experience we have found that it is
critical to design the system to  minimize this chlorine release  and at the same
time minimize the amount of fuel  necessary to dispose of the waste, especially

                                    50

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in these days when energy requirements must be reduced.   Therefore it is very
important to know the composition of the waste material,  whi.ch will  enable the
incinerator designer to set the operating temperature and the auxiliary fuel
requirements.  Since this is a hazardous waste, it is also important to the
operator and the designer to know the composition of the  waste material so
that the piping, pumps and valves handling this material  will not cause
corrosion or leakage of the material into the environment prior to its
injection into the incinerator.  The incinerator also must be designed
properly to  withstand the temperatures and the corrosion  resulting from the
exposure of the lining to the materials being incinerated and the products
of combustion resulting from the incineration step.   In burning a chlorinated
hydrocarbon the products of combustion will normally contain nitrogen, C02,
water vapor and HC1.  Improper combustion will result in  the formation of
chlorine and hydrocarbons which, when discharged to the  atmosphere,  will create
a pollution problem.  Therefore, proper design of the incineration equipment,
as well as proper instrumentation and control, is a definite requirement to
insure complete oxidation of the hazardous materials and  the discharge of a
pollution-free gas to the atmosphere.
     In cases where we have incinerated chlorinated hydrocarbons, systems have
been designed in which the hot gases are reduced in temperature to permit the
scrubbing of MCI from the gases.  The MCI can be absorbed in water very easily
and this water solution neutralized with caustic so we will end up with a salt
water stream.  Additional equipment can be provided to permit the concentration
of the HC1 acid to a point where anhydrous HC1 gas can be generated.  This will
permit the discharge from the system to contain only stack gases with C02, water
vapor and nitrogen with some oxygen, and the liquid discharge to contain HC1  at
some concentrated level.  In some installations more recent, heat recovery equip-
ment has also been added to utilize the heat available from the combustion of

                                    51

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these chlorinated hydrocarbons.   We  must realize that the main  problem in  all
cases is the disposal  of this  hazardous, toxic waste.   The  addition  of equip-
ment to recover heat,  or to recover  valuable  chemicals, is  secondary and must
be considered only if  it is economically feasible and does  not  become the
primary reason for the system.   The  system must  always be designed  to operate
so that the hazardous  waste is  disposed of properly.
     In many applications where the  process is only on the  drawing  board,  the
waste disposal problem is handled by testing  a synthetic material which approxi-
mates the final waste  product.   We find it extremely important  for  a test  program
to be run on the actual  waste  material  to determine its handling problems,
corrosion problems, and the conditions  which  are optimum for efficient disposal
of the material.  This includes operation of  the incinerator at varying temper-
ature levels and residence times. This is necessary to minimize the amount of
fuel required if the material  is not a  self-sustaining waste fuel.   At the same
time tests are necessary to determine the products of combustion by gas analysis
and particulate analysis in the stack discharge.  This is necessary to permit
the designer of the system to  select proper equipment for air pollution control.
Many times the synthetic waste does  not approach the final  process  waste from
the system and the equipment must be flexible enough to permit variations  in
composition.  However, this must be  determined prior to the final  design of
the equipment.  We have found  from many years of experience with the various
process industries and the process waste streams that are being generated, what
to expect in plant operations.   But  there are still those unexpected surprises
which occur even though both the plant operator  and the system designer use
their best efforts in  finalizing a proper disposal system.
     In any hazardous  waste problem  it is best to review the process as much as
possible to determine  if there are any means  by  which the waste discharge can  be
reduced, and this is of prime  importance.  The more efficient the process, the

                                     52

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less waste will be generated and the problems  of disposal  will  be  minimized.
Next, a good understanding of the waste material  is  necessary by the  plant
operator.  What are the rates and composition  of the material?   If the rates
are minimal, is it possible that this can  be handled through a  neighboring
facility having the capabilities of disposing  of this waste, or is there a
local, central disposal facility having the experience to  handle  this waste?
It is critical that the operator review the capabilities of the ultimate dis-
posal site.  Even though you may release this  material to  a disposer, since you
have generated the waste, you will still be responsible for the method of its
ultimate disposal.  If you decide on an in-plant disposal  system,  be  sure that
you fully understand the qualifications of the system designer.  Since the
hazardous waste disposal business has been expanding at a  rapid rate  over the
past few years, many companies have become involved  and many failures have
occurred.  It is extremely important that an experienced company be contacted
and a review of their installations be made.   Find out if  the present users
of the equipment are satisfied and determine what problems can  be  expected
from a maintenance standpoint.  No equipment used in hazardous, toxic waste
disposal is maintenance-free.  This material is toxic and  will  cause  problems
in the material handling area from a corrosion standpoint, as well as in the
refractory and construction of the incinerator due to the  high  temperatures at
which this equipment will operate.  If a plant operator is looking for the
cheapest method of disposal, he is making his  first  mistake.  Most times the
waste disposal equipment is necessary for the  plant  to continue operation.  If
the waste disposal system is inoperative,  the  plant  may be forced  to  shut down,
with the subsequent loss of revenue.  From past experience the  system designer
who has been exposed to these problems will know where quality  is  necessary
and from our own experience, we insist on  proper materials to insure  long, safe
operation of the equipment.  A system designer should also have available a test

-------
facility where the materials  to be disposed of can be tested and proper evaluation
made of the disposal techniques prior to the final design and construction of the
system.
     I hope that I have passed along some of our experiences in the field of
hazardous waste material.   There are solutions to many of these problems and
I feel that with increased support from industry and the government, in many
critical areas the problem of hazardous waste disposal can be minimized.  It
is a capital investment that  will  be required of many industries and many of
these investments can be justified economically if recovery of the heat being
generated or the material  being disposed of can be made.  We find this to be
true in more than half the cases with which we deal.

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               MR. LEHMAN:  Thank you,  Mr.  Santoleri.




Mr. Lindsey?




               MR. LINDSEY:   I have  a two part  question




here.  Number 1, in the thermal processing  of TVC,  what




pollution control equipment for the gas  do you recommend?




And, Number 2, what materials of construction are  used in




this pollution control equipment to  resist  HC1  corrosion?




               MR. SANTOLERI:  In the incineration  of




any chlorinated hydrocarbon    say from  a FVC plant, number 1,




the incinerator is designed with refractories which will




operate at temperatures as high as 3000 .   We  find the



higher the temperature, the less chance you have of chlorine




discharge.   The equilibrium reaction between chlorine,

-------
HC1, 02, etc., will tend to give you less chlorine the high




the temperature.   The refractory, therefore, is normally




designed with a very high aluminum shock resistant for




swings in temperature, also very dense to permit, prevent




the pentration of HC1 to the refractory. The linirg of the




incinerator is usually held to a temperature high enough




so that condensation of HC1 will not affect the steel




liner during start up or shut down.   And most tin.es we




recommend that the unit be purged with a clean stream,




such as water or air, prior to the injection of the waste




at the same time during shutdown, so that any HCL that is




in the system can be purged out.




               As far as the clean-up equipment, normally




this is a quench system which will quench the gases and



scrub the gases out.   These are usually acid brick lined



tanks and towers with a rubber lining on a shell so that




the cooling which will take place and generate HC1 acid,




when it does get back to the shell because of the low tem-




peratures, will not cause corrosion of the steel liner.




               The quench system is usually either a




submerged exhaust system where the gases are quenched down




to saturation temperature of about 190 and then it goes




through a stack tower which contains saddles which are




resistant to the HC1.




               MR. LEHMAN:  Mr. Newton?

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               MR. NEWTON:  Mr. Santoleri, your prepared




statement contains the statement that a/en though you may




release this material to a disposer, since you have gener-




ated the waste, you will still be responsible for the




method of its ultimate disposal.  Could you elaborate upon




that?




               MR. SANTOLERI:  Yes, I can give you an ex-




ample, you take and hire a contractor to haul your waste




and he tells you he is going to haul it off to a disposal




site.    You pay him and you figure you are clean, he's




taking care of your problem.   You should know exactly




where that waste is going, how it is going to be treated




and be sure that the final disposer is going to clean it up




so that it goes into the atmosphere clean or if it is in




a land disposal site it doesn't leach out into the ground.




               This responsibility, I feel, is the respon-



sibility of the waste generator, whoever is generating the




waste.   There was a case where a plant had a contractor




haul his waste, he was paid, he took it to a farm down in




South Jersey, left it there, it was never disposed of.




A few years later this leaked out into the ground, and the




drums were still marked with the plant owner.   And, who-




ever found these drums went right back to him.  The con-




tractor who hauled it away was gone.




               So, whoever is generating the waste should





                            -  57

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know where it is going and how it is being taken care of.




               MR- DeBONlS:   I have a two part question



here, it basically addresses itself  to energy considera-



tions, it says, don't you consider your thermal disposal



methods too energy intensive since they use natural gas



and shouldn't you restrict the, your processing to things



which will support combustion by themselves.   I think



you did address that but perhaps you  could reiterate.




               MR. SANTOLERI:  Yes, in most cases the or-



ganics which are disposed of are combustible, require



natural gas or fuel only for warm up to get the system in



operation.   However, there are a lot of waste, aqueous



wastes containing organics where the concentration of the



aqueous is so high that it will take a lot of fuel.   There



it is best to look at a concentration step utilizing the



heat that is available from the incinerator.   In other



words, you have a waste that might be 90$ water, 10$ or-



ganics, the organics are toxic and hazardous.   You have



to get rid of this by incineration, getting it up to a



high enough temperature.



               But, to take say a thousand pounds of water



up to 1800 degrees, is going to require 5 million BTU's



of heat, not taking into consideration the heat available



from the organics.   That's 5,000 CPH of gas.   If you




can concentrate that 90$ down to a point where you only





                           5G

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have a 50$ concentration, you save a tremendous  amount  of




gas.  This requires additional capital equipment but  there




is equipment available for this.




               So, in many cases people,  say five years




ago, were not concerned because gas was running  30  or 60^




a million BTU's.   Now when it is a dollar  to  two and a




half a million, they can spend the additional  capital




money for the evaporation equipment.




               MR. LEHMAN:  Mr. Sanjour,  you have a ques-




tion?




               MR. SANJOUK:  A question from the audience




here.  What is the ultimate disposal of the scrubber  solu-




tion or salts?




               MR. SANTOLERI:  Many times this is usea




back in the plant process itself, we have wastes that are




generated from          Caprolactam processes where the




waste or the solution that is leaving the process is  a




aodium carbonate solution.   This is often used  in  neutral-




ization of other acid streams.




               MR. LEHMAN:  Mr. Lindsey?



               MR. LINDSEY:  I have a number of  questions,




written questions here, I don't think we are going  to




have tirre to ask them all.   What I would like to do  is




ask you, I have one that I am going to ask you,  and then




the rest of them I would like to give you and  ask you to




                             SB

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answer them in writing if possible.   The one question I




want to ask is, you discussed a number of waste types and




industries from which wastes are generated and you men-




tioned in design you must know the characteristics and the




composition of the waste.   In your experience then, has




it been possible to design one incinerator capable of hand-




ling a wide variety of wastes or must we have a different




model or design for each waste.




               MR. SANTOLERI:  We find that every case is




a special case.   People always wonder why you can't have a




standard incinerator to handle 15 different types of



wastes.  Each problem is a different problem in itself.




               There may be possibilities that a standard




shell size may fit different conditions, in other words,



if you have a certain heat release, this ends up with a




certain size incinerator, but you have to worry about the




construction of the piping, the refractories, the nozzle.




In one case you might be able to get away with a 3/16




stainless steel nozzle and in another case you would have




to use hastoloid.




               The refractories,  you may be able to use




60$ aluminum in one unit because of the type of materials




you are handling, in other cases you have to go to 95$




aluminum.   So, you can't say that you can design a




standard incinerator to handle many different wastes




               MR. LEHMAN:  Okay^ we have one last ques-

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tion, Mr. Santoleri.  Mr. Kovalick?




               MR. KOVALICK:  This is from the audience.




Has or does your company feel that hazardous waste legis-




lation is necessary to remain profitable?




               MR. SANTOLERI:  Yes, I think it — for us




to remain profitable?




               MR. KOVALICK:  Yes.




               MR. SANTOLERI:  Not necessarily because




this is not the only business we are in, this is part of




our total operation.   But, hazardous waste legislation,




I feel, will help the public, the environment, especially




in those places where people are just hiding behind the




fact that there is no legislation, they are continuing to




create a problem.




               We have found that most of the companies we




have dealt with are responsible companies, they are con-



cerned not only with the local community but also their




own plant people.  This is most critical.

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                        TRANE THERMAL COMPANY
                               BROOK ROAD
                       CONSHOHOCKEN, PENNSYLVANIA 19428
                               (215) 828-54OO



                           December 22, 1975
Mr. John P. Lehman, Director
Hazardous Wastes Management Division
Office of Solid Waste Management Programs (AW-565)
Environmental Protection Agency
Washington, DC  20460

Dear Mr. Lehman:

I want to again thank you and the U.S. EPA for giving Trane Thermal
the opportunity to present our experience in the thermal processing
of hazardous wastes.  The attendance at the meeting shows the interest
from all areas in this particular problem, and I'm sure that after
having heard the discussions, and after subsequent meetings at the
other locations, those in your organization directly associated with
hazardous wastes will realize the impact that hazardous waste disposal
1s making on the nation.

I have responses to the questions which were asked on the cards distri-
buted at the meeting, and I am enclosing them for your review.  The
questions are as follows.

1.  When burning sulphate bearing waste, don't you end up with S02 in
    your stack?  What provisions do you have for controlling S02 emission
    to some stringent state requirements?

    Yes, we do have S02 resulting from burning wastes with sulfur bearing
    compounds.  If the incinerator is operating with a sodium compound
    initially, and the amount of S02 generated 1s minor, additional caustic
    may be injected into the incinerator to cause the formation of sodium
    sulfate.  This, of course, will mix with the other sodium compounds
    leaving the incinerator as ash and be collected normally in a wet
    solution.  If the quantity 1s great and the incinerator is not oper-
    ating with sodium bearing compounds, and not designed for the addition
    of caustic, a scrubber will usually be added to the system to scrub out
    the S02 before leaving the stack.  This, of course, will result in a
    sodium sulfate solution which will then have to be concentrated and
    disposed of.  In some areas the stack height requirements are sometimes
    sufficient to cause dispersion so that the ground level concentration
    is well within the requirements of the particular locality.  Each case
    has to be reviewed on its own merits and with the total quantities of
    S02 that are being generated.  This aids In determining whether the
    solution is a simple stack extension or requires the addition of scrubbers.

2.  You mentioned the incineration of sodium compounds.  Have you solved the
    problem of preventing reaction between sodium and refractory?

                                      62

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    We are licensed at the present time by the Nittetu Chemical  Engineering
    Company for their process of disposing of aqueous  wastes  containing
    organic and inorganic compounds.   The inorganic compounds normally
    contain ash, and we also become involved in organics  which are caustic
    organics and salt bearing organics.  These incinerators  are  downfired
    and the temperature of the incinerator is such that the  reaction with
    refractory is minimal.  There will always be a reaction  between the
    sodium and the C02 generated in the incinerator which will form a
    sodium carbonate.  Sodium carbonate and sodium oxide  will react with
    refractories, especially the silicon refractory, to form sodium silicate,
    which is a glass and melts at temperatures in the  range  of 1800-1900°F.
    Using a downfired system, any molten salt that comes  in  contact with  the
    walls will run down the surface of the walls into  a quench tank which is
    located directly beneath the incinerator.  There will be  some attack  on  the
    refractory, but the refractory used in this system is designed to operate
    satisfactorily for at least one year in the worst  instances  - where sodium
    carbonate is a product of combustion - and as long as two to three years
    where other sodium compounds are in the products.   Papers have been pre-
    sented as follows:

    "Incineration of Waste Liquids Containing Organic  Compounds  and Inorganic
    Salts" by J. J. Santoleri, presented at the Second National  Conference on
    Complete WateReuse in Chicago, May 4-8, 1975.  "Industrial Liquid Waste
    Disposal and Valuable Recovery Systems" by Yen-Hsiung Kiang, presented at
    the AIChE 68th Annual Meeting in Los Angeles, November 16-20, 1975.

3.   What residues remain for landfilling after incineration?   Must they be
    treated  before landfill?

    In most cases the residues from the quench system  where we are burning
    an aqueous containing organics and inorganics, the solution  leaving the
    quench tank is usually a salt solution containing  sodium  carbonate and/
    or sodium sulfate and sodium chloride at a concentration  of  15-20% in
    water.  This is a neutral solution and can be concentrated further if
    necessary, or discharged to the sea if location of the plant is along
    the shores.  If concentration can be accomplished  economically, this
    will allow collecting of the final residue (which  is  inert)  to a land-
    fill.  When chlorinated hydrocarbons are burned and the  effluent is a
    weak solution of HC1, this can be treated with a caustic  or  lime solution
    to generate a salt solution and water.  This can be treated  as described
    above.

 4.  Do you use condensation techniques to liquefy suitable gaseous wastes
    and thus simplify disposal.  For example, heat exchangers using ambient
    air as the condensing medium and recovering useable heat.

    We do use a condensing type heat exchanger after gases are quenched in
    a water solution.  The gases leaving the quench tank  are  saturated at
    temperatures in the range of 185-200°F.  At this temperature level the
    gases leaving the system are approximately 50% inert, containing C02,
    nitrogen and oxygen, and the other 50% water vapor.  The  heat generated
    in the incinerator system is carried in the water  vapor  leaving the quench

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    tank.  Therefore there is a considerable amount of heat that can be gained
    by condensing this water vapor.  We do this by using a shell and tube heat
    exchanger with the process waste on the one side and a gaseous effluent on
    the other.  The process waste can then be concentrated and heat recovered
    by this method.  Another method of recovering heat is to take these sat-
    urated gases and preheat another liquid stream.  By condensing the water
    out of these gases, the requirements of the scrubber system downstream
    to provide a clean effluent to the atmosphere are reduced.  Without the
    condenser we find that sub-micron particulates will require 60-80" W.C.
    pressure drop across the venturi scrubber.

    By using a condenser ahead of the scrubber the total pressure drop re-
    quirement of the scrubber drops to 30-40" W.C., thereby reducing the
    total horsepower of the system.  We have not considered the air cooled
    heat exchanger, only because of the high surface requirements with the
    gas-to-gas heat transfer.

5.  At 3000°F it is not possible to avoid the formation of chlorine and
    nitrogen oxides?  This is another form of pollution.  How can you there-
    fore recommend such operating conditions?

    The 3000°F was mentioned as the maximum temperature at which we operate
    the chlorinated hydrocarbon incinerator.  We limit the operation to 3000°
    primarily from a refractory maintenance standpoint.  We have been able
    to incinerate chlorinated hydrocarbons as low as 2000°F; however we find
    that with our type of burner and the ability to reach high temperatures
    has permitted us to get very close to the equilibrium conditions for the
    incineration of these chlorinated hydrocarbons.  Lower temperatures re-
    quire much more residence time and normally this occurs with less mixing
    and turbulence.  The ability to reach equilibrium conditions is directly
    related to the turbulence and temperature of a system.  The paper en-
    titled "Chlorinated Hydrocarbon Waste Recovery and Pollution Abatement"
    goes into the details of the equilibrium conditions of chlorine, water
    vapor, oxygen and C02,  and relates the equilibrium of this reaction to
    temperature.  You will note that at the higher temperature, higher equi-
    librium will take place.  This essentially will reduce chlorine to its
    minimum condition at that particular temperature.  Again we have found
    that with the Vortex burner we have been able to approach very close to
    equilibrium conditions because of the reaction taking place at very high
    temperatures and excellent mixing.

    With respect to nitrogen generating NOX, this is true.  The higher the
    temperature the more NOX will be generated.  However, with the combustion
    air alone containing nitrogen, we  .ave not found the incineration of
    chlorinated hydrocarbons to present any problems regarding NOX emissions.
    However, we have handled chlorinated hydrocarbons which had nitrogen bound
    in the waste.  In this case v/e had to be very careful regarding the oper-
    ating temperature of the unit and we had to reduce this.  This was able
    to be done by the injection of water into the liquid waste, which permitted
    two reactions to take place; one, the lowering of the combustion temperature
    which aided in the  reduction of NOX formed, and at the same time, a re-
    duction of chlorine due  to the additional hydrogen that was generated  to

-------
    complete the reaction to HC1.   By  doing  this  no additional air had to be
    Injected to maintain lower temperatures  and we were able to operate as
    close to sto1ch1ometric as practical, which minimized the NOX formation
    from the combustion air, as well as  the  nitrogen from the waste.

6.  The scrubbed material is neutral or  should be so.  How could you use it
    for further chemical neutralization  reactions?

    When I was describing the scrubber effluent used for neutralization of
    acids, this was from a system where  the  quench water contained salts
    from the incineration of an organic-inorganic material.  The products
    from the Incinerator are quenched  in a water  bath and the inorganic
    materials which are normally salts such  as sodium chloride, sodium car-
    bonate and sodium sulfate are carried out in  a 15-202 solution.  This
    solution is normally basic and  has been  used  in neutralization of acid
    streams within a plant.  However,  if the Ph of the quench water 1s
    neutral, this would not be possible. Each system has to be reviewed
    on its own.

7.  In referring to your ammunition plant installation - (1) is it in
    operation; (2) where is the location; (3) the capacity and Ibs. per
    hour; (4) the capital investment required; (5) the operating cost.

    An installation was supplied to the  Badger Army Ammunition Plant in
    Baraboo, Wisconsin, in mid 1966.   At the present time, due to the cut-
    back in operation of munitions  plants, this system is no longer in
    operation.  However, the unit was  designed to bum a stream consisting
    of 65% dinitrotoluene, 25% dibutyl ph thai ate, and 10% diphenylamine.
    This system operated with the waste  material  being Injected directly
    into a Vortex burner having a capacity of 10  MM Btu/hr.  The gases
    from the reaction were scrubbed by use of a submerged exhaust system
    so that the gases were cooled and  scrubbed before entering the exhaust
    stack.

    The total capacity of the system was for 1 6PM of the waste material.
    As far as operating cost, the only costs were involved with the 30 HP
    blower which was used to supply combustion air to the system.  No fuel
    was needed other than for the initial light-off with a natural gas pilot.
    The waste was a self-sustaining material so that no auxiliary fuel was
    required.  The only other operating  expense would be the water required
    for cooling the gases and this  would be  dependent upon whether a hot water
    stream is generated or the gases are allowed  to go out saturated with water
    vapor.  In one case where the system will take and heat water approximately
    100°F, approximately 200 6PM will  be required.  However, if the heat will
    be used to evaporate water, only 20  GPM  will  be required.  The total cost
    for this system as supplied by  Trane Thermal  Company in 1966 was approxi-
    mately $22,000. and the total installed  cost  approximated $40,000.  These
    numbers would probably double based  on today's prices.

This covers all the questions that  were  presented at the end of my discussion.
If any other information is required,  please contact me.

           yours ,
                                      BROCHURE  DETACHED AND  RETAINED
                              '       IN SOLID  WASTE MANAGEMENT  FILES
                              "    35
               .
.  Santoleri,  Vice  Pres.

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               MR. LEHMAN:  Thank you very much, Mr.



Santoleri.   Next may I call upon Mr. Philip A. Palmer



of the DuPont Company.  And just to alert the next speaker,



Mr. David W. Miller of Geraghty & Miller.  In that case,



the next speaker following Mr. Palmer would be David A.



Boltz, AISI.  Mr. Palmer.




               MR. PHILIP A. PALMER:  Mr. Chairman,




                          r-r:

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members of the panel, my name is Philip A. Palmer.  I am



a Solid Waste Management Consultant for the Engineering



Service Division of the DuPont  Company.    Thank you for



the opportunity to present our views on this important



topic.  We share your concern that all wastes, including



hazardous wastes, should be disposed of in a safe and



orderly manner without damage to the environment and that



the recovery of energy or materials should be encouraged



where technically and economically feasible.



               The problem of hazardous waste management



is of direct concern to us for, as a major chemical manu-



facturer, we produce wastes which would be classified as



hazardous.  We all recognize that the complex problem of



hazardous waste management is not an easy one to deal with



               Although the DuPont Company does not have



expertise in all areas of hazardous waste management



most of the current waste disposal techniques are used in



some manner within the Company.   Therefore, we would



like to focus our attention on a number of the issues to



which these hearings are addressed and share with you



some of our observations.




               There appear to be differing views on how



a hazardous waste should be defined.   Much of this can



be attributed to the lack of defining the waste charac-




teristics relevant to the problem and then matching the




                       G7

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required control to that specific characteristic.




               As we see it, effective hazardous waste




management should insure that the waste is:  collected




and handled in a safe manner; transported safely; disposed




of without hazard to the disposer or the community; and




disposed of in a manner that protects the quality of us-




able ground waters, surface water and air.




               Some states are proposing hazardous wasbe




criteria similar to those shown in Table 1 of Appendix I,




attached to this testimony.




               Typically, once a waste has been designated



hazardous by any one of these several criteria, the con-




trol requirement is that it be placed in a landfill which




has an impermeable liner with leachate collection and



treatment facilities.




               For example, a waste containing nitrocellulose




may be classified hazardous according to the flammability




category, and indeed, must be transported in a safe manner,




however, these landfill requirements are not at all neces-




sary for this compound.




               Consideration must be given to the objec-




tive of the hazardous waste classification and the kind




and degree of control needed to meet that objective.




               Table 1 contains a great many criteria




which would require extensive testing and classification.





                          60

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We believe that rather than defining a waste by this ex-




pensive and time-consuming approach, that technical cri-




teria be adopted which are concise and focus on the highest




priority problems.




               For example, our proposal for criteria im-




portant to transportation would be flammability and acute




toxicity.  Criteria important to safe disposal site opera-




tion would be flammability, acute toxicity and reactivity




while criteria important to ultimate disposal requirements




would be based on the acute toxicity of components in the




leachate.




               We believe that recently proposed hazardous




waste criteria are not appropriate, because they are




overly restrictive and broad.




               A more detailed discussion of these cri-




teria is included in Appendix I.



               A major consideration in determining the




hazard of any waste should be its potential for polluting



potable ground or surface waters.  We believe all leach-



able wastes may be a hazard to ground water supply and




that industrial wastes should not be discriminated against




with respect to ultimate disposal requirements.  The same




degree of control should be required of all wastes which




have potential for contaminating potable ground water




supplies, or surface water.

-------
               If the quality of a waste's leachate is


used to determine the potential for ground water pollu-


tion, as we believe it should be, industrial and  municipal


wastes are potentially equally hazardous.  This was hign-


 lighted by a. recent proposal in one state for defining


the relative hazard of a waste based upon the concentra-


tion and toxicity of materials in the


This method is described in Table 2 of Appendix II where


this method is described, depending upon the assumptions


made for the organic content of municipal waste's leach-


ate, it ranked in the most hazardous classifications.


               I believe most waste generators and regula-


tory agencies agree that the most pressing problem is


adequate ultimate disposal of all wastes.


               It must be recognized that the actual


hazard that a waste may pose is a function of the site


characteristics as well as the waste characteristics.


Sophisticated  land disposal systems with linings or


double linings, leachate collection and treatment may be


necessary where the potential for contaminating potable or


otherwise usable ground water supplies or surface water is


great.  Less stringent requirements are in order where


the site is more secure.  In these cases, we find use of


such sophisticated systems may not offer a reasonable


increase in protection and are unnecessarily costly.

                         ~» r~\
                         .'U

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               It is nearly impossible to make generaliza-




tions on proper methods of processing or disposal of in-




dustrial or so-called hazardous wastes because of the uniq




properties of each waste produced within the chemical In-




dustry.  These unique properties require engineered solu-




tions, which must be economically as well as technically




sound.



               A number of basic treatment and disposal




techniques exist, all of which are used singularly or




in combination in some manner within the DuPont Company.




General cost information is available in the literature




and through many of the EPA contractor reports on hazar-




dous waste management to which DuPont has contributed




treatment, disposal and cost information.




               Caution should be used, however, in using




such data on specific wastes which may require specialized



handling or unusual designs.  Methods used to treat wastes




include:




               1.  Incineration or thermal processing of



combustible wastes or those which decompose with heat.




This may be accomplished with heat recovery or materials




recovery.  For example, heat is recovered by burning




waste liquids and tars in power house boilers, HC1 is




recovered when burning chlorinated hydrocarbons.



               2.  Chemical fixation to physically

-------
.stabilize  wastes and decrease leaching characteristics.



                 3.  Neutralization, precipitation and




  filtration to physically stabilize wastes and retard leach-



  ing of metals.




                 4.  Assimilation on or in the ground.




                 Major disposal methods within DuPont in-




  clude:




                 1.  Sanitary landfill or burial in low




  permeability soil strata.




                 2.  Landfills or storage piles with im-




  permeable liners and leachate collection.




                 Considering the complexity of the waste




  produced by our industry and the evaluation that must be




  given to the proper method of treatment and/or disposal foi




  each waste, we feel it would be virtually impossible for



  an agency such as the EPA to establish pretreatment or pro-




  cessing requirements or standards for solid waste which



  could be uniformly applied and have the desired effect of




  minimizing environmental impact.  We believe that the gre-




  atest emphasis should be placed on establishing standards




  which assure that the ultimate disposal method is satis-




  factory.




                 Within the industry, numerous processes




  or process modifications are made to allow recycle or re-




  use of waste materials.  Many of these processes are re-




  garded as trade secrets.  In addition, we are always

-------
actively seeking secondary markets for waste materials and



have been reasonably successful to date.  We believe the



economic incentive alone should determine the degree of



waste recycle and recovery.  For this reason, we are op-



posed to regulations specifying the kind and amount of



processing and recycle of wastes.



               In the instances where adequate waste treat-



ment and disposal facilities are not available on the site



for a particular waste, the materials are processed by



waste treatment and disposal firms.



               There has been a desire on the part of



State regulatory agencies In recent years to fix the re-



sponsibility for transport and ultimate disposal of a



 waste on the waste generator.  We agree that the generate:



has some responsibility in the area, however, the waste



hauler and disposer have responsibility to asaure, res-



pectively, that the wastes are delivered for disposal at



the proper location and properly disposed.



               Irresponsible action is invited if the



person holding the waste has no responsibility for it.



A major portion of the industrial waste disposal con-



tracts written in our Company pass ownership of the waste



to the waste disposer when it is acquired by him for dis-



posal.  If irresponsible handling does occur and there



are damages, legal remedies are available which may





                             73

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ultimately hold the disposer, hauler, or waste generator




liable.  We feel that this system is adequate and proper




and that responsibility for the waste cannot rest solely




on the generator.




               The major responsibilities in waste dis-




posal as we see them are these:




               1.  The generator should adequately label




and describe the wastes so that the transporter and dis-




poser are aware of properties which may be important to




safe transportation and proper disposal.  He should iden-




tify the disposer and make some determination that the




disposer is competent and has the proper permits for dis-




posal.  Regulatory requirements that the wastes be ade-




quately labeled and that records of disposition of the




wastes be kept are reasonable.  The generator should not




be required to obtain a permit for waste generation.



               2.  The transporter should be required to




transport the wastes which are properly labeled and des-




cribed in  a safe manner.  We believe that the authority




of DOT is adequate in this area.  DOT methods for classify-




ing materials are suitable for classifying wastes for




transportation.  We believe that additional regulations by




the Federal Government or states would be duplicative and




confusing.  We are in favor of a reasonable transoortation




reporting system which allows a state to monitor waste

-------
movement and disposition.




               3.  The waste disposer should be required




to dispose of the wastes in an environmentally sound




manner.  This can best be handled through a waste disposal




permit system.  Record keeping on the part of the disposer




to define the quantity and types of waste disposed seem




reasonable.  Some form of bonding may be necessary to re-




quire that the land disposal site is retired in a satis-




factory manner.   We believe that such regulations should




best be written by the states under guidelines provided



by the  Federal  government.




               We fail to see any significant national




need for additional regulations or standards for fire-




safety, employee training, or incident reporting.




               Until the waste is at the transport and




disposal stage, it is indistinguishable from any other



material (raw material, intermediate, product) being pro-




cessed, and, therefore, it is subject to the same OSHA




regulations for fire-safety and worker protection, and to



spill prevention control requirements.




               Additional employee safety standards,




labeling requirements, etc.,  would conflict with the exist-




ing OSHA regulations.  These  OSHA regulations also apply




to workers handling the material in transport or at the



disposal site.



                           v c                        -i
                            i J

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               Treatment, recycle and recovery should be




at the discretion of the waste generator and he should




be free to choose the most economical environmentally




sound disposal method.  Great caution must be exercised




to prevent conflict of requirements under DOT, OSHA, the




./Sr, Water and Drinking Water Act as well as toxic sub-




stances legislation.




               In summary, we believe that only a disposal




permit system is needed.  Disposal requirements should




be applied to all wastes, industrial or municipal and




should vary depending upon the degree of hazard repre-




sented by the waste.  A system for reporting the transpor-




tation of the hazardous wastes would be beneficial.  We




believe this is all that is necessary to assure that



wastes are disposed in an orderly, safe and environmental-



ly sound manner.




               Looking ahead, we see some problems if



some states implement more stringent solid and hazardous




waste disposal regulations than called for in Federal




guidelines.  As individual states become more restrictive,




wastes will be forced to less strict neighboring states foi




disposal.  These states in turn may respond by developing




yet more stringent regulations.

-------
               We believe that the Federal government
has a role to play in bringing a degree of uniformity in
state disposal requirements and insuring that no state
can prevent importation of wastes for disposal.  We believe
that private enterprise must be allowed to develop dispos-
al capacity to the greatest degree possible.
               Additionally, we foresee problems where
large central disposal facilities will be needed but
will be denied permission to build on a highly desirable
site for waste disposal because of local and state opposi-
tion.
               It may be necessary for the Federal govern-
ment to obtain central waste disposal lands and lease them
to private waste disposers.  With retirement of the dis-
posal facility, the Federal government would retain the
site and be responsible for environmental monitoring.
               We have touched upon only a few of the
issues involved in hazardous waste management.   Certainly,
more detailed and thorough consideration must be given
to many of these areas.  We hope that these hearings will
be just the beginning of dialogue among all parties inter-
ested in solid waste management.  We would be pleased to
participate in future forums on this subject.
               I will be pleased to answer questions, and
thank you for the opportunity to present our views.

                              1 1

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                           APPKNDIX I



            HAZARDOUS WASTES - DEFINITION AND CRITERIA





          There are a number of considerations in defining a waste



as hazardous.  As discussed in the body of the statement,  there must



be a concise definition of the hazard to be guarded against and then



appropriate controls must be placed on transportation, disposal site



operations, and ultimate disposal.






          We believe the waste can be classified primarily by the



physical and chemical properties of the total waste material and the



chemical composition of the waste's leachate.  The quality of the



leachate produced is an important consideration in determining the



potential environmental hazard.  This is recognized in the Report to



Congress on Hazardous Waste Disposal (U.S. EPA, June 30,  1973, page 13)



which states:



          "The form of a hazardous waste is also very critical



          because it determines if a toxic substance is releasable



          to the ambient environment.  As an example, an insoluble



          salt of a toxic metal bound up within a sludge mass that is



          to be disposed of at a landfill does not present the same



          degree of immediate threat to public health and the environ-



          ment as a soluble salt of the same metal that is unbound



          going to the same landfill."





          There has been a tendency on the part of some states to adopt



lists of hazardous materials without recognizing that wastes are seldom



a pure compound, or that the presence of a "hazardous material" in the



waste does not necessarily make the waste hazardous.  We believe there
                                 78

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is a lower limit of concentration of these materials in a waste at
which the probability of release into the environment in harmful
concentrations would be diminishingly small,  consequently, there
must be some practical upper concentration limit set which puts the
waste in the hazardous category if a listing system is used.

          The list of criteria in Table 1 is an attempt to cover all
possible routes of exposure and types of hazard under every conceiva-
ble circumstance.  This list was abstracted by a state from Figure Cl,
"Graphic Representation of Hazardous Waste Screening Model" of the
June 30,' 1973 Report to congress on Hazardous Waste Disposal.  Some of
the criteria are important only to specific aspects of hazardous waste
management.  Other criteria, we believe, are unnecessary or of rela-
tively minor importance.

          Our thoughts on these criteria are discussed below.

Flash Point Less than 175"F
          This criterion is most important with respect to shipping
of waste and waste handling at the disposal site.  It is difficult to
understand why such a high flash point is used.  The DOT criteria for
flammable liquids is a flash point of 80°F or below.
Infectious Waste
          The handling, transport and disposal of infectious waste is
a recognized problem.  We believe that the precautions which should
be taken with this waste are different than those for other wastes
and the disposal of such wastes is often regulated by the states under
their present regulatory systems.
                                79

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Lethal Chemical
          This term is vague and unnecessary considering other criteria
on the list which referred to LD__'s or inhalation toxicities.  Many
materials are lethal if administered in large enough dosages.   Conse-
quently, this term/ unless better defined, has no meaning and  should
be dropped.  If lethal chemical refers to chemical or biological warfare
agents, this distinction should be made.

Material Which Becomes Hazardous When Wet
          We agree this is an important criterion for waste disposal.
However, the type of hazards should be more clearly defined, such as
explosive, etc.  This is a property which we feel must be disclosed by
the generator of the waste when it is given to a shipper or disposer.

pH Less Than 4 or More than 9
          We question whether this criterion is germane with respect
to shipping and suggest that the DOT criteria for acids and corrosive
liquids is more appropriate.  While this information may be necessary
for a disposer to determine if neutralization is required or the type
of land disposal facility which should be used, we question whether the
pH range shown defines a hazardous material.  For example, the rain
•water falling on the east coast may have a pH of 4 or less.  Simple
antacids for gastric upset produce a pH in water approaching 9.

Radioactive Waste
          This term as used by some states is so vague as to be meaning-
less.  This definition gives no quantity or degree of radioactivity
which is hazardous.  A discarded luminous dial from a wrist watch would
be considered a hazardous radioactive waste under the present definition.
The -use of Maximum Permissible Concentrations Levels may be useful.

                                80

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Waste Subject to Bioconcentration
          This term has been broadly and incorrectly used in virtuall.
every proposed law or regulation in hazardous waste management.  We wish
to emphasize that the simple bioconcentration of a material is not a
criterion for the hazardous nature of the material.  Every living
organism bioconcentrates certain materials.  For example, iron in blood
or calcium in bone - such bioconcentration is necessary for the well
being of the organism.  Any criteria on bioconcentration must be
because of toxic effects which are linked to such bioconcentration.
If this criterion  is used, it should be applied primarily to the
ultimate disposal requirements.  It is of minor importance with respect
to transportation and waste handling.

Waste Flammability in NFPA Category 4
          The NFPA category referred to is that given in NFPA Standar"
No. 704M.  The intent of this standard is to broadly characterize
materials so that they may be labeled to give an indication of the
hazards to which public and private fire-fighting personnel may be
exposed during fire emergencies.  The criteria are not numerical in
nature and, consequently, unsuitable for a regulatory definition.  We
believe these categories are useful in labeling of fixed storage con-
tainers, but the labeling required under DOT should be the overriding
transportation labeling requirement.
Waste Reactivity in NFPA Category 4
          The same comments apply as to the flammability category
discussed above.

Waste Having an Oral LD™ of Less than 50 mg/kg
          This is the criteria used by DOT in defining Class B poisonous
materials.  We believe it is a useful and proper criterion for defining
                                61

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a hazardous waste with respect to shipment and handling requirements.

It may be an acceptable criterion for determining hazardous waste ulti-

mate disposal requirements, however, we believe that the characteristics

of the leachate are more important than the lethal does of the waste

itself.


Waste Having an Inhalation Toxicity  <^200 ppm as a Gas or Mist or
     <. Than 2 mg/1 as Dust
          The LCcQ criterion is also the same as that for Class B

poisons.  We believe it is also useful with respect to regulation of

transportation and handling and operation at a disposal site.  The

inhalation toxicity requirement is vague.  We assume this also refers

to LCgQ which would then be similar to the 2 mg/1 limit.  If this is so

it would be reasonable to use the 2 mg/1 limit for both gases and dust.

We fail to see, however, how these criteria relate to ultimate disposal

requirements as the contamination of ground or surface waters.


Waste Having Dermal Penetration Toxicity LD50 of Less Than 200 mgAq

          Our comments are similar to those for the oral toxicity

criteria.


Waste Having Dermal Irritation Reaction Less than Grade 8

          We believe this criterion is of minor significance compared

to others and should not be included.  While we realize that it may be

important with respect to exposure of people handling and disposing of

these wastes, this is not a reason for classifying a waste as hazardous.

Dermal penetration toxicity would be a more meaningful measure of hazard

in handling.
                                82

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Waste Having Aquatic 96-Hour TLM of Less than 1000 mcf/1
          We question the importance of this criteria with respect to
transportation and general handling.  It also has little bearing on the
ultimate land disposal of a waste, unless the waste is dumped directly
in surface waters.  Since most state regulations prohibit direct dumping,
we believe aquatic toxicity is of minor significance.  In general, we
feel the emphasis should be placed on protecting human health and pota-
ble ground water supplies.  If such a criterion is used, it should apply
to the leachate produced by a waste rather than the waste itself.

Waste Phvtotoxicity ILF^ Less Than 1000 mq/1
	if         >•	OU                 ^'	
          We believe that inclusion of this criterion is an unnecessary
complication which would add unnecessarily to the cost of defining the
waste characteristics without significantly clarifying the definition of
a hazardous waste.

Waste Known to or Suspected to be a Carcinogen
          This is an extraordinarily broad definition which does not
define the criteria to be used.  Does this mean a human carcinogen, ex-
perimental carcinogen, or suspect carcinogen?  What is the test method?
We question whether such   criteria should require all wastes be
tested  for carcinogicity and if such a criterion is used, we would
recommend that a restricted list of recognized substances as those
cancer suspect agents regulated under OSHA (Federal Register Vol. 39,
No. 20 - Tuesday, January 29, 1974) be used.  In addition, it should
be pointed out that even under the OSHA rules and regulations, the
material is not recognized as a cancer suspect agent unless the concen-
tration of these compounds is above a specified level in the material
We feel strongly that such   criteria cannot be used unless concentration
limits in the waste or leachate are clearly defined.
                          '    83

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Waste Known or Suspected to Cause Genetic Changes



          Our comments are basically the same as those for suspected



carcinogens.  We question whether this is a high priority criterion



with respect to hazardous waste management and would recommend that it



not be adopted.

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                                    TABLE 1
                       LIST OF HAZARDOl'S WASTE INDICATORS


Flash point less than 17^°?

Infectious Waste

I.^thal Chemical

Material which becomes hazardous when wet

pH less than 4 or more than 9

Radioactive Waste

Waste subject to bioconcentration

Waste flammability in NFPA Category 4

Waste reactivity in NFPA Category 4

Waqte having an oral LD_0  < 50 mg/kg

Waste having inhalation toxicity 200 ppm as gas or mist, or
                                 LCjn <  2 mg/liter as dust

Waste having dermal penetration toxicity LDcg < 200 mg/kg

Waste having dermal irritation reaction < Grade 8

Waste having aquatic 96-hr. TLM<  1,000 mg/liter

Waste Phytotoxicity IL50 < 1,000 mg/liter

Waste known to or suspected to be a carcinogen

Waste known to or suspected to cause genetic changes

MOTE:  See next page for definitions.

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ABSTRACTED FROM:   Report to Congress, Disposal of Hazardous Waste
                   U.S. Environmental Protection Agency 1974

                   Appendix C - Decision Model for Screening and Selecting
                   Hazardous Compounds and Ranking Hazardous Wastes


Definitions of Abbreviations Used in the Screening Model


Bioconcentration (bioaccumulation, biomagnification) :   The process by which living
organisms concentrate an element or compound to levels in excess of those in the
surrounding environment.

National Fire Protection Association (NFPA)  category 4 flammable materials:
Materials including very flammable gases, very volatile flammable liquids, and
materials that in the form of dusts or mists readily form explosive mixtures when
dispersed in air.

NFPA category 4 reactive materials:  Materials which in themselves are readily
capable of detonation or of explosive decomposition or reaction at normal
temperatures and pressures.
Lethal dose fifty (LDsg) :   A calculated dose of a chemical substance which is
expected to kill 50 percent of a population of experimental animals exposed through
a route other than respiration.  Dose concentration is expressed in milligrams per
kilogram of body weight.

Lethal concentration fifty (LC50) :   A calculated concentration which when
administered by the respiratory route is expected to kill 50 percent of a population
of experimental animals during an exposure of 4 hours.  Ambient concentration is
expressed in milligrams per liter.

Grade 8 dermal irritation:  An indication of necrosis resulting from skin irritation
caused by application of a 1-percent chemical solution.

Median threshold limit (96-hour TLm) :  That concentration of a material at which
it is lethal to 50 percent of a test population over a 96-hour exposure period.
Ambient concentration is expressed in milligrams per liter.

Phytotoxicity:  Ability to cause poisonous or toxic reactions in plants.

Median inhibitory limit (ILm) :  That concentration at which a 50 percent reduction
in the biomass, cell count, or photosynthetic activity of the test culture occurs
compared to a control culture over a 14-day period.  Ambient concentration is
expressed in milligrams per liter.

Genetic changes:  Molecular alterations of the deoxyribonucleic or ribonucleic
acids of mitotic or meiotic cells resulting from chemicals or electromagnetic or
particulate radiation.
                                            66

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                         APPEflDIX II
  The following classification system is from a proposed Texas
  hazardous waste regulation.  The calculation method was modified
  so that leacliatt analysis as ppm of various cations and anions
  could be used, rather than concentrations of a specific compound.
  This was done by choosing a compound with the toxicologically
  active ion and multiplying the compound's LDso by the weight
  fraction (f) of the ion in the compound.   The active ion in each
  chosen compound is underlined in Table 2.
           3.  Class A refers to waste materials which are of a

               high strength, toxic or hazardous nature and which

               require the imposition of stringent standards to

               insure the proper collection, handling, storage and

               disposal of these wastes.  By definition, Class A

               wastes include waste materials not susceptible to

               classification in classes B and c.  Class A non-

               commercial (4f)  industrial solid wastes are sub-

               classified in terms of the hazardous index (HI)«

               of the waste materials as follows:
a.
                      Class A-l exists where HI is less than or

                      equal to 1.

                      Class A-2 exists where HI is greater than 1

                      but less than 100.

                      Class A-3 exists where HI is greater than 100

                      but the waste material contains one or more of
*  The HI or hazardous index is a measurement designated by the Texas

   Water Quality Board to indicate a waste material's combined degree

   of solubility and toxicity.   As the HI for a particular waste

   material increases, the lesser the potential for its escape into

   the environment and the lesser the demand for stringent environ-

   mental safeguards.   HI measurement techniques are described below.
               87

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                     the following hazardous or heavy metals:

                     arsenic, barium, baron, cadmium, copper,

                     chromium, lead, manganese, mercury, nickel

                     selenium, silver and zinc.

               d.    Class A-4 exists where HI  is greater  than

                     100 and  the waste  material contains none of

                     the above-referenced hazardous  or  heavy

                     metals.

     B.    For determining a noncommercial (4f)  industrial  solid

          waste material's hazardous  index  or  HI,  the following

          formula and laboratory  procedure  should  be  used:
           HI
                    50
               ^ Toxicity
                1

           Where CC1 is the concentration of component (1)  in mg/1
               Toxicity. is  either the Oral LD50,  the Oral LDLo,  or
               the Oral TDLo,  in mg/kg.
           Where  Toxicity is:
               Oral LDjg is a  calculated dose of  chemical substance
                            which is  expected to  kill 50 percent of
                            a  population of experimental animal
                            exposed through an oral route.

               Oral LDLo is Oral Lethal  Dose Low  — the lowest dose
                            of a substance introduced by an oral
                            route over any given  period of time  and
                            reported  to  have'caused death in man,
                            or the lowest single  dose introduced in
                            one or more  divided portions and reported
                            to have caused death  in animals.

               Oral TDLo is Oral Toxic Dose Low — the lowest dose
                            of a substance introduced by an oral
                            route over any given  period of time
                            and reported^to produce any toxic effect
                            in man or to^produce  carcinogenic, tetra-
                            togenic,  mutagenic or neoplastigenic toxic
                            effect in animals or  humans.

           NOTE:   If more than one of the toxicity values is available
                  the preferred order of use in the hazardous index
                  calculation  is Oral LDcn before Oral LDLo before
                  Oral TDLo.
         is
The hazardous index calculated using  the above formula is equal  to
the number of liters of the liquid waste or leachate solution obtained
from a solid material that  would deliver a lethal amount of material
to an average adult human being.
                    68

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-------
               MR. LEHMAN:  Thank you, Mr. Palmer.   I



have one question that actually came in at the end of the



last speaker, but I think you have touched upon this issue



as well and so I will ask it of you.  The question is, has,



I guess it is to your knowledge, have there been any recent



legal decisions concerning responsibility for hazardous




waste disposal?



               MR. PALMER:  I am not a lawyer and to my



knowledge I am not aware of any.



               MR. LEHMAN:  Do we have any questions?



               MR. KOVALICK:  Mr. Palmer, if I may ask a



question, in your statement, back several pages, you made



a comment about the kinds of guidelines that you thought



were appropriate, if I may read these two sentences.



               MR. PALMER:  What page?



               MR. KOVALICK:  Page 5.  You said, "We



feel it would be virtually impossible for an agency such



as the EPA to establish pretreatment or processing require-



ments or standards for solid wastes which could be uniform-



ly applied and have the desired effect of minimizing en-



vironmental impact.   We believe that the greatest empha-



sis should be placed on establishing standards which as-



sure that the ultimate disposal method is satisfactory."



I'm really interested in having you expand on that.  That




last sentence.




                        SO

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                MR. PALMER:  I think we are all ultimately



 interested in performance standards and that is that the



 waste disposal method be one which does not contaminate,



 for example, ground water supplies.   And this performance



 can be obtained in a number of ways and one way can cer-



 tainly be by providing a very secure landfill site.



 Another method may be by performing a certain degree of



 treatment and providing a less secure landfill site, yet



 nonetheless adequate.



                And, I think this decision is one that



 has to be made for almost each waste, particularly for



 disposal Of wastes on a plant's own   property.   You have



 to realize that, for example, there are many ways that a



waste could be treated.   If we were to take an organic



 tarring waste which had, for example, a heavy metal in it



 the waste could be solid or virtually solid, not leach-



 able, particularly of the heavy metals and could probably



 be landfilled properly in a relatively, I shouldn't say



 insecure but less than totally secure landfill site with-



 out contamination of the environment.



                If the restriction came or the regulation



 came that all wastes of this variety had to be incinerated,



 for example, we could wind up with a less desirable situ-



 ation, in which we had to burn the waste, the heavy metals




 would then be released as an ash, which in turn would




                             31

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become a water pollution problem, which in turn would have
to be removed from the water as a sludge which in turn
might have to be further treated and which in turn may
have to be further treated and which in turn may still
not be going into a very secure landfill.
               So when you look at the variety of wastes
that we are faced with, this is why I made the statement
that standards for treatment may not be fully applicable
or could apply across the broad spectrum.
               MR. LEHMAN:  Mr. DeBonis?
               MR. QfiBOWlS:     Mr. Palmer, you referred
to the Federal Government insuring that states  — pre-
vention of waste across state borders and I think in light
of the recent State Supreme Court decision, I was wonder-
ing if you would share your views with us on what effect
that would have potentially if it is allowed to stand and
stay as ultimately resolved.
               MR. PALMER: You are talking about New
Jersey?
               MR. DeBONIS:   Right.
               MR. PALMER:  We are still trying to assess
the effect in New Jersey.  As we understand it, this
decision only relates to really a municipal type waste
and wastes which are disposed of in a facility, a treat-
ment facility in New Jersey, are exempted.  Consequently,
                          S2

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I believe our industrial wastes probably will not be
affected by this.   But it would be a very serious prob-
lem if the movement of industrial waste were restricted
to cross batteries, because there certainly is some de-
gree of scaling economics available in a central waste
disposal facility and particularly for snail comoanies who
just have a few barrels of something to get rid of, it
is very helpful for them to have a centralized waste dis-
posal facility to send those two or three drums or tank
cars a month.   And I think it can only be supported on a
regional basis really.
               MR. DeBONIS:     I^>preciate your view but
I think that you are not correct in terms of the industri-
al waste being excluded from that ban, I think it is ex-
cluded, as well as the municipal wastes.  The intent of
the ban is to ban land disposal and not reprocessing or
reuse.
               MR. PALMER:  Well, as I said, we are still
assessing the problem, but I believe most of the waste
which we send into New Jersey are processed prior to dis-
posal.
               MR. LEHMAN:  Mr. Sanjour?
               MR. SANJOUR:   A question from the audience.
You stressed tha^ acute toxicity is a criterion that  you
use to define hazards.  Are  you suggesting that chronic
                       S3

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 toxicity should not  be  used  as  a  criterion?




               MR. PALMER:   For certain  limited  and  speci-




 fied  components,  this may be the  case.   However,  looking




 at  the  broad  spectrum of wastes we  have  that  by  and  large



 the acute  toxicity data which is  available is available  in




 quantity,  it  is relatively determined for a specific waste




 and by  and large  I believe would  cover a very  large  major-




ity  of waste.




               MR. LEHMAN:   Mr. Kovalick, do you  have a




 question?




               MR. KOVALICK:  Yes.  I could perhaps, you




 heard my question to Mr. Philipbar  earlier on  the suffi-




 ciency  of  labeling for  understanding how to treat hazar-




 dous  wastes and on page 7 of your statement you  suggested,




 for transportation purposes  DOT classifications are  suffi-



 cient,  are suitable, and we  believe this is your  quote,



 that  additional regulations  by  the  Federal crovernment or




 the States would  be  duplicative and confusing.    Would



 you care to comment  on  Mr. Philipbar1s point of  view as  a




 receiver of wastes,  that labeling information  is  insuffi-



 cient vis  a vis your comment?




               MR. PALMER:   I was talking specifically




 about transportation in this sense  and would share the




 view  of Mr. Philipbar.   As  far as  the safe transportatior



 of  the  wastes from one  point  to another, the specifica-

-------
tions and the criteria of DOT  I think are perfectly  ade-
quate in determining the waste be properly classified  for
transportation, be packaged adequately, be labeled ade-
quately, so that it can be transported in a safe manner.
               Now, certainly the waste disposer must  know
somewhat more than that for certain wastes and it is the
responsibility, I believe, of the generator to define  the
wastes in adequate detail, so that the person that he
writes a contract with to dispose of the waste is absolute-
ly sure of what he is getting and how he must handle it.
I think that's his decision on handling, however, but  he
must know the characteristics of the waste, important  to
disposal.
               But, what I am trying to bring out is that
if you classify a broad range of wastes hazardous and  then
require some specialized transportation requirements,
which are overlapping with DOT, you get into a real night-
mare.
               MR. KOVALICK:;  But you are distinguishing
between transportation requirements and treatment of dis-
posal requirements.
               MR. PALMER:   Yes,  indeed.
               MR. LEHMAN:   Mr. Newton?
               MR. NEWTON:   Mr, Palmer, a question from
the audience,  please.   Does DuPont send a representative

-------
along with each waste load from generation to the disposal
or recycling site and at what point in time does DuPont
feel it loses responsibility for the waste?
               MR. PALMER:  We do not send a representa-
tive along.  We are cautious in our selection of contrac-
tors to determine if they are doing a proper job in dis-
posal and if they have the required permit.  And we speci-
fy where the waste is going to go, to which disposer.
               If you have an adequate permitting system
forveste disposal, which the state enforces, then the fact
that we send it to this type of facility should be ade-
quate .
               MR. LEHMAN:  Are there any other questions?
Yes, Mr. Sanjour?
               MR. SANJOUR:   The previous three speakers
are all in the business of treating wastes and you are
the first generator of wastes that we have had up here,
and several of them have commented on the fact that busi-
ness is bad and industries in general don't take adequate
precautions with their wastes because they are not required
to do so and to do so would out them at a disadvantaqe.
Could you comment on that general train of thinking?
               MR. PALMER:  I would think that a major
proportion of their business comes from the DuPont Com-
pany, so we are not responsible for their problems.
                           So

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          Again, I think if we get into transportation




reporting and if there is some regulatory ability to make




sure that a waste goes to a licensed and properly permitte>




disposal and treatment facility, this will solve some of




the problems involved in waste being inadequately disposed




               MR. LEHMAN:  Thank you, Mr. Palmer.  I




don't believe we have any further questions at this time.




In view of the fact that Mr. Miller was unable to be here




from the firm of Geraghty & Miller and will submit a state-




ment for the record, I think it would be an appropriate




time for us to take a break now rather than to wait ten




minutes as we originally planned.   I would like to now




adjourn the meeting for a fifteen minute break.   Please




be prompt.  We will be starting up again at approximately




10:35.  Thank you.




          (Whereupon a short recess was taken.)




               MR. LEHMAN:  All right, ladies and gentle-



men, I think we are about ready to start.  I would like to




call at this tii-.e Mr. David A. Boltz, representing the



American Iron & Steel Institute.   Mr. Boltz,  will you



accept questions, sir?




               WR. BOLTZ:  Yes.




               Mr. Lehman and members of the EPA panel,




my name is David G. Boltz, Solid Waste Control Engineer




in the Environmental Quality Control Division of the





                          S7

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Industrial Relations Department, Bethlehem Steel Corpora-




tion.   I also represent the Technical Committee on




Environmental Quality Control of the American Iron and




Steel Institute, a non-profit trade association composed




of 66 member companies in the  ^United States.  These




companies account for approximately 95 percent of domes-




tic steel production and employ some  700,000 persons  in




the United States.




               During 197^ the steel industry produced




145,700,000 tons of raw steel.  For every ton of raw




steel that is produced, approximately 1200-1500 pounds




of by-product solid, semi-solid, and liquid material




(excluding iron and steel scrap) is generated.   Much of



this by-product material is recycled, reused or sold, but




a significant quantity snds up as waste which must be dis-




posed of either on site or at municipal or private dis-




posal facilities.  Thus, any legislation affecting waste



disposal is of major significance ,to our industry.




               There is no question about the desirabili-




ty of disposing of hazardous wastes in a manner that mini-




mizes the threat to human health.  We know that EPA has




been studying the hazardous wastes problem for several




years and that the Hazardous Waste Management Division of




EPA has developed a conceptual plan for identifying hazar-




dous wastes and determining  if  a  particular waste  requires




                              S8

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special disposal technology.  We understand that this




plan is based on the provisions of S.2150, Sen. Randolph's




proposed Solid Waste Utiliziation Act of 1975, on the




assumption that future legislative action to regulate




hazardous wastes will contain some form of these provisions




               In the absence of specific proposed regula-




tions, the following comments will reflect our reaction




to EPA's conceptual plan as it was explained to industry




representatives at a workshop held in Washington, D.C.




on October 9, 1975.



               Regulation of hazardous wastes requires a




procedure for evaluating all wastes and selecting those




which, according to EPA's definition, "pose a substantial




danger, immediately or over time,  to human, plant, or




animal life and which, therefore,  must be handled or




disposed of with special precautions."




               As we understand the conceptual plan, the




initial waste evaluation phase would be a series of




standard generic tests for flammability, explosivity,



corrosivlty,  etc.,  to identify those wastes which possess




obvious hazard characteristics.   The wastes would then be



subjected to a solvent-acid leaching tei to determine if




toxic substances can be leached.   If the resulting leachatc




shows the presence  of more than a trace amount of any




toxic substance, the waste would be classified as "hazardous






                             S3

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and therefore subject, at a minimum, to a "management
control system" whereby records would be required for
every movement of the waste.
               Finally, those wastes which become clas-
sified as "hazardous" as a result of the leaching test
would be evaluated further by use of a Standard Attenu-
ation Procedure, a site-specific test to approximate the
net effect of a given waste at a specific disposal site.
               There appears to be a need for standard
generic tests to identify those wastes which oossess flam-
mable or explosive characteristics.  Furthermore, we
appreciate the fact that for administrative purposes, EPA
must develop criteria to identify those wastes which could
if improperly disposed of, pose a substantial danger to
human health or living organisms.
               We do not agree, however, with the plan to
classify as "hazardous" every waste which fails the
standard  leaching  test screening procedure as conceived by
EPA.  The presence of toxic substances in what amounts to
a "worst case" leachate does not necessarily prove that
the waste is actually hazardous.
               Rather than the rigorous dual solvent-
acid screening procedure, a test more representative of
natural conditions should be used.  We suggest that EPA
study test methods already in use by regulatory agencies

-------
such as the Pennsylvania Department of Environmental Re-
sources.  This test involves the mixing of a 500 gram
sample with 2000 ml distilled, deionized water and agitat-
ing for 48 hours.  After 24 hours settling, the superna-
tant is decanted, analyzed, and reported as mg/1 by
weight.
               We therefore recommend that wastes be clas-
sified as "potentially hazardous" and included in a manage
ment control system only if:  (1)  the leaching test Tor
the waste material in question reveals the presence of
toxic substances in the leachate in concentrations suffi-
cient to cause harm, and (2) disposal in a local sanitary
or industrial landfill would contaminate ground or sur-
face water to the point of creating substantial danger to
human health.
               Such criteria would allow EPA (or the
state, if certified) to concentrate on monitoring those
wastes which possess significant hazard potential, while
eliminating those wastes whose hazard potential is negli-
gible.  Under EPA's very stringent test criteria, we fear
that most industrial wastes would eventually be classi-
fied as "hazardous," thereby creating an administrative
nightmare for both the regulatory agency and the company
involved without significant benefit to the environment.
               We also recommend that EPA exempt from

                       .  101

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regulation storage areas within plants which are not
final disposal areas.  In many cases materials must be
temporarily accumulated or stored prior to their use,
recycle, or transport to final disposal areas and should
not be subject to regulation during their interim stock-
piling.
               We recognize that our recommendation for
determining which wastes should be classified as
"hazardous" does not address the problem of deciding the
levels of pollutants in the leachate which would be
hazardous or how much toxic material a given aquifer can
accept before a substantial danger to human health is
created.   But from the discussion at the October 9 work-
shop, it would appear that EPA is not close to an answer
to these problems either.  Since these are obviously key
technical issues in determining the hazard potential of a
given waste, it would be appropriate for EPA to engage
two or three contractors to make independent studies of
the problems and present recommendations.
               We take this opportunity to offer EPA our
cooperation with regard to the future work that will be
required to develop reasonable hazardous waste regulations
In using the term "reasonable hazardous waste regulations,
we refer to regulations where the costs to achieve the
requirements (1) are not prohibitive, (2) are rationally

                      102

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related to the expected environmental gain, and  (3) give




recognition to the wise use of already scarce fuel and




energy reserves.




               We believe that our historical experience




in managing waste materials is a logical and necessary




complement to EPA's technical expertise.  Our recent




work with Calspan Corporation to assess waste disposal




practices in the steel industry shows our interest in




cooperating with EPA and its contractors.  In this parti-




cular study, we recommended that the proposed "grab"




sampling program be replaced by a program of daily sampl-




ing for four weeks at each of the plants, with the daily




samples consolidated each week to provide four represen-




tative samples for subsequent analysis.  The manpower




for tne four-week sampling program was contributed by




each of the steel plants involved in the survey.



               We look forward to working with you and



your associates on this matter in the near future.



               Thank you.



               MR. LEHMAN:  Thank you, Mr. Boltz.




Mr. Sanjour?



               MR. SANJOUR:  First of all, let me thank




your Institute for their cooperation on that Calspan




study, we really appreciate that.




               On the issues you raise on page 3, about

-------
the classification of a waste as hazardous, as you point




out., this was drawn up under the umbrella of 3.2150,




which, for the benefit of the audience, this is Senator'




Randolph*s proposed solid waste bill in the Senate now.




Now, under that provision, if a waste is not defined as




hazardous, then EPA has no regulatory authority over that




waste.   Therefore, you point out a management control




system only if      disposal in a local sanitary or




industrial landfill would contaminate ground or surface




water to the point of creating subsantial danger to human




health.   Well, if we do not first, under that law, if




we do not first classify a waste as a hazardous waste,




then we have nothing to say about its disposal.




               So, then, my question to you then is, are




you advocating the bill that would give EPA regulatory



authority over all wastes and not just hazardous wastes?




               MR. BOLTZ,   I think in my opening state-




ment, we recognize that all waste materials that are



generated by industry need to be examined and evaluated




to determine their hazard potential.    I understand what




you are saying, as far as 2150 only allowing you to regu-




late hazardous wastes, but our feeling on that is that




S.2150 is not currently the law and certainly before any




kind of hazardous waste law is passed, we would expect




EPA to thoroughly express their vievrs and perhaps reserva-

-------
tions about such a limitation.   I don't know if this




adequately addresses your question or not,




               MR. LEtiMAN:  Mr. Kovalick?




               MR. KOVALICK:  Mr. Boltz, on page 4 you




comment on the subject of storage areas, which is aio a



problem that we have thought about and you suggest that




storage areas, should there be some kind of regulatory




program at a state or Federal level, should not be subject




to regulation because of the fact that they are interim




stockpiling?   Has your institute given any thought to




distinguishing between what is interim stockpiling and




what is in fact disposal, that is a condition that either




affects the ground, the surface or the air?



                           Some criteria to distinguish?




We are certainly interested if you have given it some




thought and if you care to respond in writing later, we




would be most interested in that.



               MR. BOLTZ:  I think at this point we have



not studied the problem sufficiently to comment on that.




The whole subject of solid waste disposal and the regula-



tion of waste disposal is really new and as we would dis-



tinguish between disposal and stockpiling, our thoughts,




our collective thoughts are not sufficient to compile to




be able to answer that.




               I think the comment rose out of a concern





                          115

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for undue regulation of storage piles.  If you have ever

been to a steel plant, you can't help but be impressed

with the huge piles of raw materials that we of necessity

have to accumulate and store prior to their use.

And, we have visions of extreme regulation over those

stockpiles, I guess I'm taking a pretty cautious viewpoint

at this juncture.

               We recognize there is the need for perhaps

surface water control and that kind of thing.  But, we

have had a lot of experience with the Air & Water Pollu-

tion Control laws and maybe you will understand our reluc-

tance at this point.

               MR. KOVALICK:  How would you suggest deal-

ing with wastes which might not now be considered hazar-

dous but may be found later to be hazardous once they are

in the water supply?  I suppose that means if they were

exposed to the water suoply.

               MR. BOLTZ:  I guess that means if a waste

that had been just landfilled in past years and are there

as a potential for ground water contamination.  I don't

know, I don't have a lot of experience in retrofitting a

sanitary landfill or even an ordinary landfill such as we

operate in the steel plants.   It would be a gigantic job.

Solid waste really departs from air and water pollution

right here because you can stop air and water pollution
                     i>
                         1GG

-------
by putting proper controls on the stack gases and treat-
ing the water, but past practices that have put hazardous
wastes or wastes that might in the future be classified as
hazardous into the ground, and this includes the millions
and millions of tons of municipal wastes as well, which
have been perhaps landfilled imorooerlv, is a collective
problem that we, I guess human beings all over the world,
have been guilty of.   And, I can't imagine the kind of
system whereby you could go back and unearth all of these
potentially hazardous wastes and try to rectify those
problems.   It's a mind boggling kind of thing and I'm
afraid that I could probably talk for five minutes and
still not answer the question really, what they are gett-
ing at there, I don't know how to do it.
               MR. LEHMAN:  I had a point to make and
also a question.   You mentioned at long length that EPVs
conceptual plan, as it was explained to industry represen-
tatives at a workshop held in Washington, D.C. on October
9, 1975* I just wanted to point out to the audience that
this was one of a series of workshops that was held,
first with all of the state government representatives,
next with the industrial representatives and also in
November with the, well the trade associations were all
included in the October meeting, and then in November with
the puolic interest groups, labor and representatives of

                     107

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academia.  Nowj you comment that one of our concepts that
we provided at that meeting was the possibility of a
standard test using a solvent and an acid as a screening

mechanism and that you would recommend a test more repre-
sentative of natural conditions should be used and yet

the example that you gave, in the State of Pennsylvania,
which uses distilled water, and I would just ask you if
you feel distilled water represents natural conditions
that wastes are likely to see?
               MR. BOLTZ:  No, the test that we recommend
is first of all a screening test.   We don't argue with
the concept or a standard leachate test.   Our problem
comes in that if you choose your acids and your solvents
and the strengths of each, we feel that there is no indus-
try represented by people in this room that is going to
be, going to escape havina 95% or olus of their waste cate-
gorized as hazardous.
               We feel that the solvent acid leachate test,
as we understand it, is too rigorous.  What we are trying

to do is have you consider other approaches to this leach-
ate test.   We are not recommending the distilled water
test ?er se.  I think maybe you might consider going to
the opposite extreme, somewhere  in between is probably  ap-
propriate.
               We recognize too that a leachate test in

                             iUB

-------
and of itself is not sufficient to deal with quantities




of wastes that is generated.  I triink this was brought out




pretty clearly at the October 9 workshop.   If you have a




couple of tons of waste generated per year, that's a lot




different from the problem that we have, where we have




thousands of tons of wastes.




               So, you have to have a test criteria de-




veloped where you would do a laboratory type analysis of




the waste and then go out to the field and look at the




sites that this waste is going to be disposed at, and




what the acidity of the rain water is, what other kinds of




waste are in the landfill, and develop this standard




procedure test to reflect site specific characteristics.



We are not advocating a distilled water test per se.




               MR. LEHMAN:  Mr. Boltz, I just want to




make a general comment here that we have had a number of




questions from the floor that deal with the basic issue



of how do you define a hazardous waste and you have attemp-




ted to throw some light on that in your remarks and I



just want to point out that we're here to get the




public's help on how to answer that question, and arrive




at a definition which is a proper one from all points of




view.   Another subset  of that was a question that in




the context of today's hearing, what is the definition




of a toxic substance and here again, I think the distinct!

-------
we are attempting to make at these meetings is between a
pure chemical toxic substance and a waste material which
often is not always consistent, a mixture of perhaps un-
known quantities of a large number of different types of
chemicals all mixed together.   And, this causes us a
great deal of problem in attempting to arrive at an appro-
priate definition.  So, we are not talking about toxic
substances that is pure chemicals in their original form,
but we are talking about waste materials, often a conglome
ation of a lot of things.
               Mr. Sanjour?
               MR. SANJOUR:   I have a question from the
audience, which I don't completely understand,  and that
is, can you give an example of a not hazardous  waste?
Let me rephrase the question in a way that has  a little
bit more meaning to me, and that is, can you give an exam-
ple of non-hazardous waste in a sense that you would con-
sider it non-hazardous, but you would fear some rggula-
tory act would consider it a hazard.   Could you get down
to the specifics of those kinds of materials?
               MR. BOLTZ:   We generate a lot of dust
from air pollution control equipment and sometimes this
dust cannot be recycled within the steel plant  for a
number of reasons.  Sometimes it contains a lot of zinc.
Now, if you put zinc bearing materials into a steel making

-------
furnace, or more specifically would go back  into a blast




furnace, the zinc is going to cause you all  kinds of



problems, and, so, for technical reasons we  are not always




able to recycle.  And, storing it in a segregated storage




area, for, hopefully future reclaim, there is a bit of



economics involved in here.




               As a single plant you may not generate




enough to install a process to upgrade that  dust or sep-




arate out the zinc, but perhaps a regional treatment fac-




ility could.




               But, anyway, that is a kind of waste materi-




al that would be put in a segregated storage area.  It




could lead to a little bit.   If exposed to  rain water,




we have done leachate analyses on it, there  is zinc pre-




sent in the leachate, but any kind of leachate test that




you perform, such as the one that I described, that the




Pennsylvania Department of Environmental Resources uses, what you




get is a filtrate and you analyze it for miligrams per



liter   of whatever constituent you are looking for and you



get an answer and then what do you do with that number?




I don't know what you do with the rmmhor-.   I don't think



the DER has given sufficient guidelines on how to inter-




pret those kinds of numbers.




               But,  there are wastes, dust being an example




that we consider at this point to be non-hazardous,  but on





                        ill

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vigorous kind of evaluation, they do contain some hazardous




constituents.




               MR. LEHMAN:  Thank you, Mr. Boltz.  I




don't believe we have any other questions.  Thank you




very much.  We have next on our program, actually we are




moving into what we had originally planned to cover this




afternoon and I hope that some of the individuals are pre-




sent.  I would like to call upon Diane T. Graves from the




Sierra Club.   Is Miss Graves here?   Perhaps she is go-




ing to come this afternoon.   Well, we'll come back and




cover these later.  Is Mr. Cushman here from the Plymouth



State College?  Is j^ Early here?  N0j presumably they




are coming in a little later.  Is Mr. Mahen here?




               MR. MAHEN:  Mr. Gathman is going to speak




for us today.



               MR. LEHMAN:  All right, then, we have a




representative from Scientific, Inc.   Would you please




identify yourself and your location?




               MR. GATHMAN:  Just let me get organized,




I gxpscted 1:30 this afternoon.




               MR. LEHMAN:   Yes, I understand we are




jumping ahead here a little bit.   Just to alert the next




speaker, while the gentleman from Scientific is getting




organized,, Mr. Nalvin would be next, if he is here.



               MR. GATHMAN:  My name is Al Gathman, I hope





                              112

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everybody can hear me because maybe I won't be making the

statements that are real profound but I'll try to give you

some opinions of an old timer.

               The company that I am working with,

Scientific, is an oldtimer in this business of recovery

and use of rawnateria.ls that are considered aB va<-tes bv

a lot of people.   We are sort of pioneers, we feel in

this business.   And, as a company, we have been devoted

to all phases of resource recover;/ and our initial ef-

forts were to utilize off -- I shouldn't say off tests —

but by-products screened out of chemical companies and we

sold products that their own salesman refused to put their

hands on and made money out of it.  So, we feel that we

started way back 30 years ago in recycling materials that

would have been dumped into gasoline or into the streams

and the rivers.

               This operation kind of grew like Topsy for

many reasons, one economics, there were just so many  of

these nice little side streams that we could lay our hands

on to make money out of so we got into the solid and liqui
by-products as waste products that had to be disposed of.

And, under the present definitions of hazardous and non-

hazardous wastes, we could amuse you by relating some of

our experiences, but I will just mention one.   We were

paid by a company to remove a product from

-------
sold it to Plant B for a profit.   As an example or what



goes on in big companies, where the left hand doesn't




know what the right hand is doing.  Macy's doesn't tell




Gimbel's what's going on sale tomorrow.




               I would like now to get into the meat of



what I feel is pretty important in this waste business




and we firmly believe, as you would expect from our oper-




ation, that a chemical landfill is an acceptable disposal




metnod, providing it meets two  requirements.  These




sound easy to do but they are expensive to do and they




are not being done by all of our competitors.   First,




it must be well engineered and second, it must be under




the supervision of technically trained personnel.   This




means  that not all sanitary landfills are suitable for



chemical landfills.




               The manager of a typical sanitary landfill,




and we've got a couple of those too in our working force,



is a hard working individual whose main worries are:



fires, the weather, traffic jams on the llrt, cover materi-



al, dust and fumes that annoy the neighbors, and we have




many neighbors who take delight in getting us into trouule.




I know one who had complained about obnoxious fumes and




she called the Board of Health and the local Board of




Health called our plant manager and he gets over there,




and, 2 o'clock in the morning and they can't smell any-

-------
thing, so they decide they will go to this neighbor's




house and find out what is going on.   When they got over




there all the lights were out and nobody answered the




doorbell.   So they all went home.  But, these are the




kinds of things that we are faced with in a landfill, a




typical landfill too.




               If you taKe this hard working and worrying




individual and add on the acceptance of hazardous waste,




you have a situation that may be completely out of control




And, we know, from the grapevine, that this is happening




in locations in the state that will be apprehended.




               Now, working on the notices here, we didn't




try to cover all sixteen items here, but I did write down




my thoughts on the definition of a hazardous waste.   I




think they are wastes of sufficient quantity that poses a




substantial danger, immediately or over time,  to human,



plant or animal life and which, therefore, must be handled




or disposed of with special precautions.




               Now, this we think we do in our landfill




because of the A&B restrictions that I said a chemical




landfill should have.   As in the correction of any defi-




ciency, the over-compensation of our sins of pollution has



led us down a road that has everyone frightened of the




 dire consequences of our past mistakes.




               We had questions here before I got up,





                        iiS

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 what's going to happen if something shows up in the water




 twenty years from now.  I don't think most of us will be




 worrying about that.   But, these are the things that I




 think are over-compensating for our mistakes.




                We hope with proper education of the public




 the chemical landfill will be acceptable, and this de-




 pends on the operators, performance of the operators.




                One of the alternatives that has been men-




 tioned here today to  landfilling is incineration, which




 should be held to a riinimum because of air pollution or




 the possibility of concentrating toxic metals in the ash




 in bigger quantities  that then could pose a problem.




 The landfill itself acts as an incinerator, in that it




 slowly oxidizes the sarie components that the incinerator




 does rapidly, and if  metals are present they will be di-




 luted in a large volume of the landfill.




                At this point we would like to offer an




 idea that to aid in disposal efforts, exception to some




 of these new stringent laws should be available to us.




 For example, a combustible aronatic tar which cannot,




 because of compatibility, be blended into a low sulfur




 petroleum fuel and burned, we feel may be an exception




 to sometning like this, where it could be granted, to



allow tne burned and electrical generator somewheres, may-




 be in Atlantic City where prevailing winds Is offshore and






                    liC

-------
the sox~ generated wouJd go out to sea aid nobody would know




anything about it.    But there should be some exceptions.



I know I have heard that there was a lot of coke down in




Delaware that was high in sultur  and because of the prob-




lems involved in trying to get permission to burn it in




this country, a good deal of it went to our friends in




Red China who burned it too,,    So, I think we ought to




think of these kind of laws.




               Now, to come back to the chemical waste




disposal area, which we believe should be monitored or




supervised by competent professional chemical men, be he




an engineer or a chemist.  The hazardous waste landfill




is a complete challenge in itself.   The toxic, the flam-




mable, the obnoxious odors or the perfumes are all sooner




or later offered up for disposal.  The chemical supervisor




will quickly recognize whether or not a waste is hazardous



               All wastes should be classified by the pro-



ducer or the generator, the word is being used, and we



think, especially the ones that are not usual, can be




classified as hazardous in the future, the generator shoult




be really alerted to the fact that it is his responsibili-




ty to tell us, who are disposing of it, the proper techni-




ques.  Maybe we should spend a little research on finding




out how to get rid of some of these products.



               When we do get the bill of lading,  which





                        117

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is one of the requirements that we demand., the bill of lad




ing, many times couched in technical language to the point




where it takes a good technical man, not just a beginner




out of school maybe, who hasn't had the wide experience of




the older oeople, to make sure that it is right.




               We get products in sometimes that are not




labeled properly and we have to check; them.  But the infor




mation must be available in advance of any delivery, as on




of our requirements.   This is to allow Tor site prepara-




tion and any precautionary plans to insure the proper




handling when the shipment arrives.   One of the primary




objectives of this planning is to be certain that the land-




fill operators, these are the men on the bulldozers and




compactors, are instructed on the disposal technique to



be used with the arrival of the shipment.  These instruc-




tions must be implemented to safeguard the operators.




And, this in our operation is our primary objective, to




be sure that these products coming in are not being helter




skelter dropped in any direction and having people really




getting hurt.



               Our accident experience on the landfill




is about equal to the averages,,listed in the recently




issued bulletin by the EPA titled "Injury Reporting and




Information Systems for Solid Waste Management.''  We had



a fatality and I think one of the earlier speakers, maybe






                       118

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 Mr.  Simon made  tne  comment  that made  it  look  like  a  land-




 fill or a chemical  landfill was something  different  than




 any  other manufacturing operation, and it  isn't  really.




 We are doing  things that  the manufacturing people  do too,,




 I know Mr. Palmer from DuPont spoke about  their  expedience




 But,  I would  say I  have seen eight or ten  people here  in




 the  group t^at  are  actually working at making hazardous




 wastes and also disposing of them, on their own property.




 So,  I think we  ought to look at a landfill as a manufac-




 turing ooeration or an industrial operation  rather  than




 an eyesore in somebody's  backyard,that everybody would  like




 to see stopped and  therefore anything that happens,  they




point a finger at it and  say, he wouldn't  have been  killed




 if it wasn't on a landfill.  People will get careless  no




matter where they are.




               I would just like to leave  tnat idea  with




 you.   We right now are stressing safety with our peoole




 to try to bring our averages down below the average.   We




are  not satisfied with the data that we have, nor with




what  the EPA has published as being satisfactory.  We




think that improvements can be made, and we can see  that




even between our own landfill, some of them are a little




bit more careful and they do a little better job and are




preventing accidents than the other, and we are in the




midst of an educational program to stress  this with  our

-------
landfill operators, we are spending money and  time and  ef-



fort to do it.




               One of the big problems, as I said before,




is education of the public.   On clean-up days,  the  citi-




zen who is cleaning up his cellar comes across a can, he




says, I think it might be turpentine or it might be  laci-




cin or it might be something, oh the heck with it, I'll




throw it in the garbage and this winds up in a compactor




and the compactor doesn't break it and a bulldozer runs




over it and breaks it and flashes on the man or  it might




even set a fire going.   So, we think the public should




be educated that their responsibilities are here too.




               And then we come up with the fellows  who




are in the garbage disposal business, they go around from



house to house picking up municipal trash and every



now and then someone talKs tnem into hiding a  drum or two



of what might be obnoxious, but usually isn't.   I know




we picked up two drums of concentrated hydrochloric  acid



about two weeks ago and they were in one of our  landfills




down at the South end of the State, they didn't remertber




who brought it in, all they knew is here all of  a sudden




is two drums laying out in front of one of the tractors




and ir they had broken it, who knows who could have  been




seriously injured.   These are the kind of things that  we




stress with the landfill operators, to be on the alert at

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all times.




               MR. LEHMAN:  Excuse me, Mr. Gathman, we




are running short on time.




               MR. GATHMAN:  I thought I was going to be




short, I'm sorry.




               The second and equally important aspect




to be certain that the environment will be protected.




I would like to point out that there are no cut and dried




instructions to give the people, you have to take each




hazard as it comes in and handle it as it is.  And, I




know I have seen a copy of the proposed list of materials



that cannot be landfilled without permission.   Now, some




of those products can be converted to less nazardous ma-




terials.   For instance, cyanides can be converted to




the ferri-cyanides that are blue pigments that we paint




our houses with, things like this that can be done.




               In conclusion, let us say we are dedicated



to our objectives of minimum pollution under the system




of free enterprise as the EPA is under the Federal auth-




ority, wnich is to dispose of industrial waste in an ac-




ceptable environmental manner at a reasonable cost.  We




think chemically designed landfills under technical super-




vision does this.



               MR. LEHMAN:  Thank you, Mr. Gathman.  Do



we have some questions?  Yes, Mr. Lindsey?





                        121

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               MR. LINDSEY:  Mr. Gathman, you mentioned




that a suitable chemical landfill must be properly engi-




neered, I believe on the first page.




               MR. QATHMAN:  Right.




               MR. LINDSEY:  Can you give us some thoughts




on what characteristics such a landfill design should have




and what engineering precaution should be taken in your




opinion?




               MR. GATHAMN:  Well,, we hired engineers to




do this, we have engineers, in fact, who have designed a




combination of dikes.   We are on a clay bed that is im-




pervious.   They measured the clay to be sure that it was




impervious.   We've got a leachate collection system in a




corner of that piece of land that we are going to use for




this purpose.  Does this answer your question?




               MR. LINDSEY:  Yes.  I have one more.  In




your opinion, should hazardous and toxic materials be




disposed of together with municipal trash and refuse in




the same facility?




               MR. GATHMAN:  Yes.  We have found over the




years that a good engineer, as they say a heat sink, if




you want to, a good place to dispose of hazardous, if you




want to classify 20% sulfuric acid water,  aqueous water




waste as hazardous in trash, because there is enough zinc




oxide, for instance, in white  paper to do a pretty good

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job on neutralizing  it.




               MR. LEHMAN:  M*.  Newton?




               MR. NEWTON:  Mr. Gathman,  first  a  state-




ment, if I may, may  I  confirm  for  the record's  sake  that




yourreference  to the state DEP proposing  a  list means  the




New Jersey Department  of Environmental  Protection?




               MR. GATHMAN:  Right.




               MR. NEWTON: You lay great  stress in your




statement that on training the  operators  adequately, may




we have your views please on how one might  assure that




landfill operators do  receive  adequate  training and  instrui




tion?




               MR. GATHMAN:  Well, I guess  being  exposed




for forty years to training adequately, you might say,




with a small company called EXXON, I guess  it kind of




rubs into me,  or is  born1  or bred  into  the  skin.   So, I




think it is the responsibility  of the management or the




operator, of the landfill, to  institute safe practices and




to stress them.   I know I have talked  to a couple of  the




landfill  supervisors and have even  thought of employing an




EXXON svfoterfuge,  if y°u want to call it that, of  awarding




gifts for safe working days.    Big companies will have




contests, for  instance, everybody whose name begins  with




an A and ends with down to E,  Lf they don't have  any off




the job accidents  (lost time)  they are  awarded  somthing.  I talked

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about this with our operators too, as a method of impress-




Ing them, that we are serious.




               And, another thing, probably more important




to them, is that our safety meetings are all on overtime,



so they know we are serious when we  are willing to pay them




time and a half to sit and listen to us.   And, I think




this in itself guarantees the safety.




               MR. LEHMAN:  All right, do we have any



other questions from the audience?  Mr. Sanjour?




               MR. SANJOUR:  Could you comment on whether



you feel there is any need for Federal  legislation  in the




hazardous waste area and if so, how would that affect




your business?




               MR. GATHMAN:  Well, I have mixed feelings,



being an ordinary citizen, that whenver anything gets in-




to the Federal nands, it kind or gets bigger and bigger,




it never gets smaller and smaller, and the money gets




spent and many times in my particular level of civiliza-




tion, if youwant to use the word, doesn't even see  where




his money is going.  So, I think our people in New  Jersey




are doing a good job on this.   And, I think they probably




would be capable of continuing to do it.




               Now, I am not mentioning the fact that some




of them have decided that we can't take out of state




trash, I don't believe that is a good piece of legislation.

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 if you want to  call it that.  I think that  should be
 changed.
                MR. LEHMAN:  All right, thank you.   I think

 we have one last question and we should move on.  Mr.
 DeBonis?
                MR. DeBONIS:  Just a brief question.  You
 referred to recovering hazardous wastes in  the beginning
 of your presentation.  I was just wondering if you  could
 give us some sort of an estimate of the tyoes  or auanti-
 ties of wastes  that you actually look to recover as op-
 posed to, let's say, placing into the chemical landfill?
                MR. GATHMAN:  Well, it is all economics.
 If there is an  alcohol water mixture that comes into a
 landfill, to be disposed of.   If it is below a certain
 concentration and it costs more to regenerate that alco-
 hol than it is  to buy new products, it is pretty obvious
what's going to happen.
                MR. LEHMAN:  All ri^ht, thank you very much
Mr. Gathman.  One the of the speakers we had originally
 scheduled for tnis morning has now arrived, so I would
like to call upon, if I nay, Mr. Blakeman Early from the
Environmental Action in Washington, D.C.  Mr.  Early please
And following him will be Mr.  Nalven.
               MR. EARLY:  Good morning.  My name is
Blakeman Early,  I'm with Environmental Action,  a non-

                          125

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profit national citizen's environmental loobyinp; organiza-




tion located in Washington, B.C.




               I air. pleased to be 'iere to present




Environmental Action's views on the management of hazard-




ous wastes, a topic which has received relatively little




public attention in the oast.   However, if the subject re-




ceives no more than discussion, more public attention will




be necessarily drawn to the increasing number of damages




and injuries which occurs as a result of both past and pro-




sent improper hazardous waste-management practices.




               Although my testimony today will focus nri-




marily on the more obvious damages associated with the



improper hazardous waste disposal, such things as loss of




drinking water supplies, destruction of underground water



aquifers, animal and human poisoning.




               Environmental Action is committed to improv-



ing hazardous waste management from a broader long range




perspective.  We are all becoming more aware of the grow-




ing threat being posed by cancer in this counury due to




publicity surrounding such reports as the National Cancer




Institute estimate that between ?0 and 90$ of all cancer




is environmentally induced and the National Center  for



Health Statistics finding that the rate of cancer deaths




rose .'to.. 5.2$ in 1975, a level 4.2$ higher than the



annual growth experienced during the past 3O years.





                       Itu

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               It is readily apparent that if we could




prevent numan contact  with carcinogens  in the environment




we can have a vast effect on the rate of cancer growth in




this country.




               Environmental Action believes that improved




management of hazardous wastes will not only have the




short term benefits of preventing the more apparent




damares mentioned later in my testimony but will also clos




one avenue, indeed many avenues by which carcinogens- are




released into the environment.




               There is no data available linking impro-




per waste management practices to cancer.  This is due in




part to the long latency period during which cancer de-




velops.   Experts consider a minimum of 15 years to be




necessary for most cancers to develop and some take up to




40 years.




               Similarly, little data exists linking




chronic poisoning to improper hazardous waste disposal.




This lack of data is also due to the relative lack of




attention to hazardous waste management drawn in the past.




               It is obvious, however,  that the same type




of practices which result in leaching, spilling and emitt-




ing or substances to the air, to which humans have immedi-




ate toxic reactions, also provide a pathway by which




humans come into contact with carcinogenic  substances  as

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well as low level toxics which can cause chronic poison-




ing.



               Clearly, the upgrading of hazardous wa^ te




management practices is a more intelligent, effective and




in the long run economic approach to protecting the pub-




lic from cancer and chronic poisoninq. In the treatment



of our drinking water, restriction of our fishing areas,




and other measures which only deal with hazardous pollu-




tants after they have paraded into the environment.




               I would like to turn now to a discussion of




the damages which often result from the improper manage-




ment of hazardous waste.  In most cases I am referring to




damages resulting from improper storage or disposal of




hazardous waste rather than improper transport, though



enough dajnage has been caused by the latter activity to




raise significant concern.




               The EPA's Hazardous Waste ManagementDiviston




of the Office of Solid Waste Management is to be compli-



mented for its current damage assessment studies, which is




the first concerted effort to assess the magnitude of




damages resulting from the improper hazardous waste manage-




ment.




               The EPA has identified six major routes of




environmental transport through which the improper land




disposal of hazardous wastes can result in damage.  1)






                         128

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ground contamination via leachate,  2)  surface water cont.ami,-




nation via  run  off,  3)  air  DolluH.nn  via  ooen burning,



evaporation, sublimation and wind erosion, 4) poisoninq



via direct contact, 5) poisoning via  the food  chain and




6) injury due to fire and explosion.




               Rather than  repeat the incidents of each




type of damage which EPA has previously cited  and which I




hope will be introduced for the record, I would like to




supplement these examples with other  incidents.




               First, in the area of  ground and surface




water contamination, water  damages are by far  the more




frequent type of reported damage, because lagooning is



the most prevalent method of disposing of hazardous in-



dustrial waste.   And reported water  damage often becomes




manifest via fish kills and obnoxious drinking water.




               In most cases humans can protect themselves



from drinking water that is so contaminated as to cause




immediate pqisoning through the use of sight and smell.




Therefore, few documented incidents of injury are direct-




ly traceable to drinking water polluted by hazardous




wastes.  These same faculties we have are not useful




in protecting against chronic poisoningand the consump-




tion of carcinogens.




               The following are typical examples of the




problems caused by inadequate lagooning of hazardous

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 wastes.   The State of Pennsylvania was faced with a




 $400,000 clean up cost when the River Chemical Company




 ordered to upgrade its industrial waste storage lagoons,




 containing 3i million gallons or toxic wastes, abandoned




 its facilities near Doylestown, Pa.




                The American International Refining




 Corporation left Pennsylvania with another extensive




 clean-up job when it went banKrupt and abandoned an indus-




 trial waste storage tank ana lagoons which were in need




 of repair.   Previously a lagoon rupture had killed an



 estimated 4.5 million fish in the Allegheny River.




                In New Jersey, the town of Newfield had




 to abandon its municipal drinking water well when it was



contaminated    by chromium leachate emanating  from a near-




 by waste lagoon.




                In Long Island, Hew York, a liquid waste




 disposal base and used for the containment of plating




 wastes by the Liberty Aircraft Company, corroded nearby




 private wells and has tainted a large portion of the




 underlying aquifer which is a supply source for New York




 City.




                A recent report tu  the Maryland General




 Assembly, by the Maryland State Department of Natural




 Resources, Maryland is no stranger to the hazards of



 improper waste lagooning.   In Hollywood, Maryland, a






                            13G

-------
leaching lagoon containing phenolic wastes from a wood


treating company, have contaminated both ground and  sur-


face waters in areas up to two miles from the plant.


               In Hewlick, Maryland, sewerage oxidation


ponds containing a large proportion of industrial pickling


brines have rendered six private wells unfit for drinking


purposes.


               Water damages have been sustained in  near-


ly every state from illegal and indiscriminate dumping.


Here in New Jersey approximately 150 wells were con-


demned and rendered useless for decades, when over 4.100


drums of petrochemical wastes were dumped at an abandoned


chicken farm in Dover Township.  The cost of extending


public water supply alone will be approximately $250,000


and other costs, such as providing interim drinking water,


loss of water rights, and health damage will escalate


that total cost.


               Most of the above incidents are preventable


when industries are required to maintain lagoons adequate-


ly and treat or incarcerate wastes which may threaten the


integrity of the lagoon liner.


               Currently, however, many states do not


have the authority to inspect and monitor lagoon facili-


ties located at a plant which is not in the business of


waste disposal.   The examples above,  which are duplicated



                      O *">• -"i
                      JLOJL

-------
many times over throughout the country, demonstrate a need
for such authority.
               In the area of air pollution, Maryland's
Department of Natural Resources  is a source of
a report of an air pollution damage incident.   In this
incident six persons were injured when 2,000 gallons of
liquid sodium were dumped in the Norris Farm  landfill
emitting obnoxious gases.
               Another example. Environmental Action  has
learned    that a preliminary study conducted for EPA's Office
of Research and Monitoring, which is yet to be released,
found samples of air in the community near the Kin-Buc
Landfill to contain vinyl chloride, a carcinogen, in amounts
alarmingly close to the Occupational Safety & Health Ad-
ministration's occupational limits.  The Kin-Buc   landfills
accepts polyvinyl chloride processing sludges for dispos-
al from which it is believed  the vinyl chloride  gases  es-
caped.
                Poisoning via direct contact.  One of the
classic cases or how not to dispose of hazardous wastes
was widely reported last Spring.     This case involved the
 poisoning of more than SO horses and 6  humans as a result
of their contact with TCDD, which was a contaminant in sor>
waste industrial oil used as a dust retardant in three
stables in Central And Eastern Missouri.    It took nearly

                       102

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three years to trace the cause of the damage.  This case
clearly indicates the necessity for keeping track of
hazardous  wastes from the point of generation to the
point of final disnosal.
               Finally, fire and explosion.  This type of
incident is less common and more often affects only dis-
posal site operators as illustrated by an incident already
reported in EPA's Hazardous Waste Disposal Damage report
dated June 1975.

               In August of 197^5 a landfill in Everett ,
Washington was the scene of a particularly fierce blaze
and attendant explosions when aluminum and magnesium
wastes were disposed in combination with concentrated
ohosohorns.    Fortunately, no workers were injured.
               As observed in the Maryland Department of
Natural Resources Report, these incidents represented
only the tip of the iceberg.   They were obtained from
newspapers, magazines and other public sources.
Furthermore, the magnitude of the problem will increase
as air pollution, water pollution and ocean dumping re-
quirements come into full effect over the next decade,
and the volume of pollution control residuals increases
an estimated 100$ between 19?1 and 1993 according to EPA
               Those residuals which are not hazardous

-------
will nevertheless be competing for the land disposal space
which will be competing with hazardous residuals for land
disposal space.
               Only a handful of states have adequate
hazardous waste mangement authorities today.   Unless all
states have effective controls, we shall continue to see
articles such as that which appeared in the November 23
issue of the Newark Star Ledger.   This article described
New Jersey as the recipient of hazardous industrial wastes
from as far away as Ohio and Virginia, because of the low
cost and limited enforcement of state regulations.
               Much of the latter problem is believed to
be attributable to the lack of money and manpower provided
to the state public utilities commission and the Depart-
ment of Environmental Protection.
               Without uniformity and control over hazar-
dous wasoe management nationwide, the states with the
weakest authorities and/or enforcement, will be the recipi-
ents of a disproportionately high amount of the nation's
hazardous wastes.
               Environmental Action submits that the im-
proper management of hazardous wastes is a problem which
is greater in scope than the states are willing and equip-
ped to handle.  We endorse the basic provisions in Senate
Bill 2150, which provide Federal  standards for hazardous

-------
 waste management.   However, we feel tne bill should also
 provide Federal standards for the transport of hazardous
 wastes.
                Environmental Action also supports the
 concept of Federal fiscal support to all states that ade-
 quately implement such Federal standards.
                I'm gratified by the supuort of this legis-
 lation, which has been demonstrated here today.
                We call upon the Congress to act on this
 legislation and other comprehensive solid waste management
 legislation as quickly as possible.   It is unfortunate
 that the administration has not found itself able to en-

 dorse this legislation.
                Thank you.
                MR. LEHMAN:  Thank you, Mr.  Early.  Mr.
Early requested tnat a certain doc'jjnent be introduced into
 the record and I would lilte to do that at this time.  Xt
 is this particular document, Volume I of the Hazardous
 Waste Disposal Management Report dated June, 1975.   So
 I will introduce that into the record.

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      This publication (SW-151),  the first in a series of reports
  to document incidents of improper land disposal  of hazardous wastes,
    was prepared by the Office of Solid Waste Management Programs


               HAZARDOUS WASTE DISPOSAL DAMAGE REPORTS
     On June 30, 1973, the U.S.  Environmental  Protection Agency (EPA)
submitted a report to the U.S. Congress on the subject of hazardous
waste disposal as .had been required by the Solid Waste Disposal Act
Amendment of 1970.    That report concluded that the prevailing methods
of land disposal of hazardous wastes are largely inadequate and cited
numerous case studies pertaining to improper hazardous waste management.
Since the 1973 Report to Congress, EPA has continued to study hazardous
waste disposal.  A portion of these studies has consisted of more detailed
investigations of improper land disposal practices to determine their
impact on public health and on the environment.  Case studies have been
compiled within the framework of these investigations.

     The problems associated with improper land disposal of hazardous
wastes—unlike the problems of air and water pollution—have not been
widely recognized by the public, although the damages may be as severe
and difficult to remedy.  In addition, the hazardous waste disposal
problem continues to become even more significant, as the progressive
implementation of air and water pollution control programs, ocean
dumping bans, and cancellation of pesticide registrations results
in increased tonnage of land-disposed wastes, with adverse impact on
public health and the environment.  The problem is manifested in ground-
water contamination via leachate, surface water contamination via runoff,
air pollution via open burning, evaporation, sublimation and wind
erosion, poisonings via direct contact and through the food chain, and
fires and explosions at land disposal sites.

     The objective of publishing these damage reports is to bring about
national awareness of the problem, which is essential to its solution.
These reports will be published from time to time as resources permit.
No systematic effort has been made to concentrate on any one parameter
of interest, be it geographical, industrial, type of disposal site, or
type of damage.  Similarly, it is not the purpose of this series of
reports to single out any particular person, firm, or industry.  Cases
are investigated as information becomes available.  The only criteria
used in the selection of incidents for these reports are:

      oseverity of damage
      oavailability of supporting information
      oavailability of EPA personnel for investigation

     The data base for these damage reports varies widely.  In some
instances, official public records will be available for documentation;
however, in most  cases the reports will have to be based on inspection

-------
by EPA personnel, Interviews with parties Involved or having first-
hand knowledge of specific incidents, technical  Investigations by
consulting firms, newspaper accounts, etc.

     The authority for the publication of such reports derives from
Sec. 204 (a)(l) and (b)(l) of the Solid Waste Disposal Act of 1965
(P.L. 89-272)—as amended by P.L. 91-512, P.L. 93-14, and P.L. 93-611.
                             CONTENTS

     Report

     1.   Arsenic  Poisoning  in Minnesota  	

     2.   Industrial  Waste Disposal on  Farmland  in  Illinois  .  .  .

     3.   Fatality at a  New  Jersey  Industrial  Landfill  	  .
                               -LO?

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                        HAZARDOUS WASTE DISPOSAL
                              DAMAGE REPORT

                              March 7,  1975

                     Arsenic Poisoning  in Minnesota


 1.   Personal  Damage - Eleven persons developed arsenic poisoning.
          Two  required hospitalization  and treatment.

 2.   Environmental  Damage - Contamination of the soil  and groundwater

 3.   Economic  Damage - Discontinued usage of contaminated well.
          Installation of public water  supply cost approximately
          $3,000.   Removal and safe disposal of contaminated soil
          is estimated at $25,000.

 4.   Cause of Problem - Subsurface migration of arsenic compound.

 5.   Type and  Quantity of Hazardous Waste Involved - Grasshopper bait,
          consisting of arsenic trioxide, bran, sawdust, and molasses.
          Total  quantity disposed estimated at less than 50 pounds.

 6.   Source of Waste - Local fanners

 7.   Date of Incident - Burial of grasshopper bait estimated between
          1934 and 1936.  First case of illness reported in May 1972,
          with other cases following during the next 10 weeks.

 8.   Location  - EPA Region V, Minnesota, Perham

 9.   Status -  Problem of how to deal with contaminated soil still
          requires resolution.  Samples from 12 nearby wells are being
          analyzed at six-month intervals by the State Health Department.

1.0.   Remedial  Action Taken - The well has been capped.  Cost considera-
          tions have prevented permanent correction of the situation at
          this time.

11.   Legal Action Taken - None

12.   Remarks - In May 1972, a local building contractor occupied a new
          office and warehouse structure at the outskirts of Perharo, a
          town of 1900 residents in western Minnesota.  At that time, a
          well was drilled to supply drinking water for about 13 people
          who worked on the premises.
                                        138

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     Early in May, five employees became ill  with gastrointestinal
symptoms.  Following this, and continuing throughout the next 10
weeks, other employees also became ill.   Arsenic poisoning was
determined to be the cause, which affected a  total  of 11 out of 13
persons exposed to the water.   Two required hospitalization and
treatment.  One of the victims lost the  use of his  legs for about
six months due to severe neuropathy.  The medical asnects of this
groundwater contamination incident have  been  well documented by
Dr. E. J. Feinglass.2

     Chemical analysis of samples taken  from the affected well
established arsenic concentrations of up to 21,000  ppb.  (The U.S.
Public Health Service drinking water standard for arsenic is 50 ppb.)
As Dr. Feinglass pointed out in his article,  the particularly
serious consequences of chronic arsenic  poisoning were probably
avoided in this instance because of the  extremely high concentration
of arsenic in the drinking water.  The acute course of the illness
allowed early recognition of the problem.

     The source of the well water contamination has been traced back
to the mid-1930's, at which time grasshoppers had constituted a
serious problem to farmers in the area.   Some old-timers recall that
excess grasshopper bait had been buried  at the former County Fair-
grounds, in a corner which was used as the village dump in those days.
That area is now directly adjacent to the new facilities of the
building contractor whose well became contaminated.

     The exact area of disposal was located approximately 20 feet from
the well.  The well is 31 feet deep and the arsenic trioxide was buried
at a depth of about 7 feet.  Analysis of soil samples established a
maximum arsenic concentration of 40% at the spot where a white
crystalline material was found.  The Minnesota Department of Agriculture
has estimated that less than 50 pounds of grasshopper bait was disposed
in the trench about 40 years ago.

     Several options have been proposed for solving the problem.  These
include the following:  (a) removal of approximately 2,000 cubic yards
of contaminated soil to sealed vaults; (b) chemical fixation of the soil;
and (c) covering the area with asphalt to retard further leaching of
arsenic into the groundwater.  The estimated costs of these solutions
range from $25,000 to $2,5CO.  Due to budgetary considerations, the
problem has not yet been resolved.  There are current plans to install
a monitoring well in the immediate vicinity in the direction of the
estimated groundwater flow.

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                      HAZARDOUS  WASTE  DISPOSAL
                           DAMAGE  REPORT

                           March 7,  1975

          Industrial  Waste  Disposal  on Farmland  in  Illinois


 1.   Personal  Damage  - None

 2.   Environmental  Damage - Contamination  of the soil,  surface-  and
          ground-waters  with toxic materials; destruction  of wildlife,
          stream-dwelling organisms, and  local vegetation

 3.   Economic  Damage  - In excess of  $250,000 has been spent  to date by
          one  property owner for clean-up  and monitoring operations; at
          least three cattle were  killed  by cyanide poisoning.

 4.   Cause of  Problem -  Dumping  and  burying of hazardous industrial
          wastes on land

 5.   Type and  Quantity of Hazardous  Waste  - At least 1,511 containers
          (mostly 55-gal. and 30-gal.  drums) of  industrial wastes
          containing  cyanides, heavy metals, and miscellaneous other
          materials

 6.   Sources of Waste -  Mostly metal finishing operations

 7.   Date of  Incident -  Three dead cattle  discovered on May  20,  1974;
          however,  the dumping had been going on for an unknown  number
          of years  until about 1972

 8.   Location  - EPA Region  V, Illinois, near Byron, on  the Johnson
          Property  and the  former  Dirks Farm, which was purchased  by
          the  Commonwealth  Edison  Company  in 1973

 9.   Status -  The dumping and burying  ceased around 1972,  but the  disposal
          site has  sustained long-range environmental damage, which
          is particularly evident  during  periods of heavy  rainfall.  An
          unknown quantity  of deteriorating drums of chemical wastes are
          estimated to be still  buried at  the Johnson Property.

10.   Remedial  Action  Taken  - Commonwealth  Edison's  contractor, the
          Conservation Chemical  Company,  removed a  total of  1,511  con-
          tainers from the  former  Dirks Farm for controlled  disposal.
          Of  this quantity, 576  fifty-five gal.  drums and  425 thirty-
          gal, drums  contained spent cyanides, which were  incinerated.
          Earthen dams and  trenches  were  constructed to confine  the
          toxic runoff, which was  treated with  calcium  hypochlorite
          to  destroy  the cyanide.  A surface- and ground-water monitoring

-------
           program was initiated.   No known remedial  action has been
           taken at the adjacent Johnson Property.

11.   Legal  Action Taken - In December 1974, the State Attorney General
           Office, at the request of the Illinois EPA, filed a complaint
           against Byron Salvage Company and its listed owners, Mr.  and
           Mrs.  W.E. Johnson.  The complaint alleges  that the company
           allowed contaminants to be placed on land  so as to create a
           water pollution hazard; polluted Woodland  Creek with dis-
           charges of cyanide, cadmium,  copper, iron, lead, manganese,
           nickel, silver and zinc; conducted a refuse disposal oper-
           ation without a permit; contaminated underground water with
           phenol, cyanide and cadmium;  and did not have a state wastewater
           discharge permit.

12.   Remarks - In May 1974, three dead cattle were discovered on
           Commonwealth Edison Company's recently acquired property
           (formerly known as the Dirks  Farm), and pathological exam-
           ination established that the  cattle had died of cyanide
           poisoning.  Further investigation revealed that the approxi-
           mately 5-acre area, which is  part of a large property set
           aside for a nuclear power plant, had been  for several years
           a repository of large quantities of toxic  industrial wastes.
                According to information furnished by the Illinois EPA,
           Mr. Johnson, owner of the Byron Salvage Company, initially
           hauled industrial wastes to his own property for dumping
           and burial.  Later, Mr. Johnson allegedly  negotiated with
           Mr. Dirks, owner of the neighboring farm property, for
           permission to dump more industrial wastes  there.  In 1974,
           when Commonwealth Edison Company learned of the potential
           problems associated with its  acquired property, it hired
           the consulting firm of Dames  and Moore to  study the nature
           and magnitude of the environmental damage  and to recommend
           a proper clean-up procedure.   Dames and Moore prepared a
           comprehensive study which documents the substantial damage to
           wildlife (birds, downstream aquatic community, stream
           bottom-dwelling organisms, frogs, etc.) and local vegetation
           (trees, shrubs, etc.).   Also, the study points out the
           severity of the contamination of nearby soils, vegetation,
           and surface- and ground-waters by toxic materials.  The
           following tabulation will serve to illustrate the contamination
           of the surface-water runoff which ultimately enters the
           Rock River, situated 1  1/2 miles east of the site:

                                                U.S.  Public Health
                        Maximum Concentration    Service Drinking
    Contaminant           Detected in Runoff     Water Standards
                          (parts per billion    (parts per billion)

     Arsenic                     60                   50
     Cadmium                    340                   10
     Chromium                17,200                   50 (W.H.O. standard)
     Cyanide                365,000                  200
     Phenols                      8                    1 (recommended)

-------
     Ongoing surface- and ground-water monitoring efforts by
Commonwealth Edison testify to the long-range nature of the problem
posed by toxic pollutants that had drained into the soil.  Also,
it is too early to predict what time period will be required
before farm crops can be safely harvested on the affected
property.  As far as the Johnson Property is concerned, an unknown
quantity of chemical wastes is estimated to be buried there,
awaiting the outcome of current legal proceedings.

     There are two recent significant developments surrounding
this case study:

     1.  In February 1975, Mr. Johnson brought to the attention of
         local public health officials several additional sites
         within one mile of his property where other parties
         allegedly dumped liquid industrial wastes on land. These
         sites are currently being investigated.

     2.  As of March 1975, owners of at least forty-six private
         wells within a three-mile radius of the Johnson Property
         have been warned by the Illinois Department of Public
         Health that their drinking water is unsafe due to
         unacceptable levels of lead and mercury.  One of the
         wells was found to have an unsafe concentration of
         cadmium and many contained cyanide; however, the cyanide
         concentrations were within U.S. Public Health Service
         drinking water standards.  Investigations by State
         authorities are in progress to determine the source(s)
         of these contaminants.

-------
                      HAZARDOUS WASTE DISPOSAL
                            DAMAGE REPORT

                           March 7, 1975

              Fatality at a New Jersey Industrial  Landfill


 1.   Personal  Damage - Bulldozer operator killed in explosion at landfill

 2.   Environmental Damage - None which resulted from incident

 3.   Economic  Damage - Bulldozer destroyed; approx. $91,000 damage

 4.   Cause of  Problem - Explosion while burying and compacting drums of
          unidentified industrial waste chemicals

 5.   Type and  Quantity of Hazardous Waste Involved - From one to five
          55-gallon drums of unidentified chemicals

 6.   Source of Waste - Unknown industrial origin

 7.   Date of Incident - October 11, 1974

 8.   Location  - EPA Region II, New Jersey, Edison Township, Kin-Buc
          Landfill

 9.   Status -  Landfill remains active.  The case was investigated by the
         Occupational Safety and Health Administration (OSHA) and New
         Jersey State authorities.

10.   Remedial  Action Taken - Management has agreed to make every effort to
         keep  out unknown chemical wastes.

11.   Legal Action Taken - The OSHA issued six citations (covering thirty-
         six items) for violation of the Occupational Safety and Health
         Act of 1970.  A formal settlement of contested items was reached
         between OSHA and the management on March 4, 1975.

12.   Remarks - The Kin-Buc Landfill, located on 30 acres adjacent to
         thT Raritan River, has received both municipal and industrial
         wastes for about twelve years.  It is owned by Kin-Buc, Inc.,
         a subsidiary of Scientific, Inc., of Scotch Plains, N.J.

-------
According to Mr.  James Stroln, Vice President of Scientific,
the landfill receives approximately 200 truckloads of waste
per day, 25% of which is industrial waste.  This includes wastes
from such industrial categories as organic and inorganic
chemicals, Pharmaceuticals, paints, plastics, and others.

     The wastes are delivered to the site in tank trucks and in
containers.  Bulk liquids are poured out of the tank trucks on
top of the previously deposited waste, while those in containers
are buried and then compacted with bulldozers.  Mr. Stroin
explained that two tests are conducted as a means of identifying
the wastes.  The first, a test for flammability, is conducted by
igniting a sample in a glass beaker.  The second is pH testing
by indicator paper.

     The acceptance of unidentified chemical wastes at landfills
has been deemed an unsafe practice by the State of New Jersey and
is specifically prohibited in recently promulgated solid waste
disposal regulations.  However, these regulations had been sus-
pended by court order at the date of the explosion; they have
since been reinstated.

     According to the OSHA investigation, eleven 55-gallon drums
of unknown chemicals had been stored at the site for about six
weeks prior to the explosion.  On October 11, 1974, one of the
managers of the Chemical Waste Division of Scientific, Inc.,
told an employee to remove these drums for burial.  Mr. Donald
Amatel, one of the two bulldozer operators working there at
the time, had covered five drums of the unidentified industrial
waste chemicals and had begun the compacting operation when an
explosion occurred.  According to the OSHA investigation, a large
flame enveloped the bulldozer.  Mr. Amatel jumped out of his
cab and another explosion followed, which caused burns covering
approximately 85% of his body and destroyed the bulldozer beyond
recovery.  Mr. Amatel died the following day.  He had been active
in his line of work for about fifteen years.

     When interviewed by an EPA official, Mr. Stroin attributed
the fatal outcome of the accident to the faulty judgment of the
bulldozer operator.  He indicated that Mr. Amatel should have
stayed in the cab and backed out with the equipment to avoid
injury. Witnesses, however, stated that this would not have been
possible.   In response to questions about possible environmental'
problems with the landfill, Mr. Stroin concerted that there
were occasional problems with contaminants being- drained from
the landfill after periods of heavy rainfall.
                             '  Ikk

-------
     For the first ten months of 1974, six other obviously chemical
waste disposal-related occupational  injuries were recorded in the
Kin-Buc logs, the maintaining of which is required under the Williams-
Stelger Occupational Safety and Health Act of 1970 (excluded from
this requirement are minor Injuries  requiring only first aid treatment).
The recorded Injuries affected two bulldozer operators, a laborer,
and two drivers.  These Injuries, as obtained from the OSHA files,
are as follows:

     1.  Eye irritation sustained while bulldozer operator was
         pushing drum which split, squirting liquid into eyes.

     2.  Smoke inhalation which caused respiratory and stomach
         conditions while operator was fighting a fire on a
         bulldozer.

     3.  Conjunctivitis of eyes caused by fumes from waste
         products.  Safety glasses were being worn at the
         time of injury.

     4.  Burned foot when driver stepped out of truck into a
         hole containing 250°F acid  waste.

     5.  Chemical burns to hands and other parts of body as a
         result of pushing a drum with bulldozer.  The drum
         split open and liquid squirted out.

     6.  Sustained burn of the cornea when dumping acid from a
         tank truck.
                          REFERENCES
  1.  U.S. Environmental Protection Agency, Office of Solid Waste
        Management Programs.  Disposal of hazardous wastes; report
        to Congress.  Environmental Protection Publication Sw-115
        Washington, U.S. Government Printing Office, 1974.  110 p.

  2.  Feinglass, E.J. Arsenic Intoxication from well water in the
        United States.  The New England Journal of Medicine, Vol.
        288, No. 16, pp. 828-830 (April 19, 1973).

                                                      uol!83aR

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               As before, if any of the audience has ques-




tions for Mr. Early would you please raise your hand and




write out your question.   Do we have any questions from




the panel?  Mr. SanJour?




               MR. SANJOUR:  Could you comment, Mr. Early,

-------
on how you feel about the adequacy of state regulation of
hazardous waste, particularly in New Jersey, in light of
the previous  speaker's comments?
               MR. EARLY:  I didn't hear all of the pre-
vious speaker's comments.   By and large, to my knowledge,
only three states have comprehensive solid waste manage-
ment legislation per se, although others utilize more
basic legislation, such as water pollution and air pollu-
tion and solid waste management laws.
               Clearly, each state has to have a very
comprehensive type of authority, one that is clearly
spelled out in the legislation.   New Jersey has some regu
lations which I understand are pending, which might pro-
vide adequate authority, but the article in the Newark

Star Ledger made it very clear that even in a situation
where New Jersoy wants to act, they have a limited number
of inspectors and it is very difficult for them to carry
out the kind of enforcement they would like to.
               I find those states with which I am famili-
ar have by and large inadequate legislation.

               MR. LEHMAN:  Do we have other questions ?
We have a question here.  Mr. DeBonis?
               MR.  DeBONlS:    Yes, there is a question
relating to a statement you made that 70$ of all cancer
is environmentally caused and the question is  whether or

-------
riot this includes smoking as a cause, and what percentage
due to smoking?
               MR. EARLY:  I believe that those figures
do include smoking, but I'm not certain, these figures
come from the National Cancer Institute, and I'm not posi-
tive, I wouldn't know the percentage.
               MR. LEHMAN:  Mr. Kovalick?
               MR. KOVALICK:   You indicated a support or
an endorsement for Senate Bill 2150, does that bill includ
that bill as I understand it talks about Federal guide-
lines and Federal standards,but state implementation, is
that also part of your endorsement?  That the states
carry out provisions of that bill, if they are capable
and willing?
               MR. EARLY:  I would endorse a scheme that
would be analogous with the water act, in that the Federal
government would have the authority to initiate a perman-
ent program for the management of hazardous wastes, and
they could authorize that the states implement that pro-
gram, if they found the state program to have sufficient
authorities.
               MR. LEHMAN:  Any other questions?  Thank
you, Mr. Early.   I would like at this time, please to
call on Mr. Malvin from the New Jersey Manufacturers
Association.  Is he here?  Not here.  Mr. Gallay then, are

-------
you here?   Yes.   Mr. Gallay from the




Germany, Mr. Gallay.




               MR. GALLA.Y: Rood morninq and thank vou




very much to give to my company the opportunity to inform




the American industry about, our environmental protection




activity in Europe.




               As the gentleman  said, I represent the




company, SBB, which is a Dutch/German company and is a




company who invented and developed and practiced for the




first time trie incineration at sea of chemical wastes.




And, our operations cover firstly and almost exclusively




the incineration or chlorinated hydrocarbon wastes.




               I'd better state right from the start the




philosophy of the company.   We think that the only right




thing to do with the wastes is to transform it chemically




into a useful product.   We think., however, that we will




oe in business for about 30-40 years because we do not be-




lieve that a significant or  at least major part of the




chemical waste, the hydrocarbon waste, will be transformed




chemically in an acceotable technical way, and an acceotabl




econorric way.




               Therefore, we believe, as I said, that —




to put it another way, we do not celieve that before thirty




forty years the industry will have available the catalyst




to make the chemical transformation in a satisfactory and

-------
acceptable way.


               Now, the whole operation started when


SBB, which was originally a German company, constructing,


engineering, designing equipment for chemical and petro-


leum industries and especially combustion furnaces, they


were building one of the largest chemical companies in


Europe, in Germany actually, building a furnace and in


the discussion with this company we found out that the


disposal of the majority of their wastes was made in a


.more or less satisfactorv wav.  But. they had one_ problem


that they could not master, and this was the disposal of


chlorinated hydrocarbon, they had tried everything.


               For years they have operated land inciner-


ators, waste recovery of HCO with carbon, of material


with natural carbon hydroxide and they just couldn't make


it.


               By that time the German or the European


restrictions on damping the discarded material from HCL


neutralization was such that they were at a loss, they


didn't know what to do.   And then, the man who started


the company, the German engineer, suggested that as the


problem is to avoid the toxicity of chlorinated hydro-


carbons or organic compounds, on the life in the sea,


thev should burn this product at sea and to transform


this organic compound into inorganic products wnicn are
                        *

                            150

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non-toxic.  Therefore, through the complete combustion,




C02, water and HC1.  Everybody knows what happens with




H20 and C02, the hydrochloric acid condenses in the water



and integrates by this association in the sea water.




               Now, the first ship that has been built was




the ship called Mathias  I a small ship with a loading




capacity of 530 tons and was such a success that in fact




it unveiled a fantastic problem.    The problem was




worsened by the fact that the environmental authorities




in Europe, whenever an industry came to say, well look,




we believe now that we have an alternative, we have this




amount of waste,  the authorities said, well, you never




said that before.  And they started putting penalties,




               I think we were instrumental to convince




these European authorities to stop such a procedure be-




cause this was making sure that what we call black prac-



tices of disposing the waste will be continued.



               Tne second ship i*as built in 1972, and




most of you have heard of  vulcanus,  our competitor,  that



was built and put into operation after our second ship.



The Vulcanus  has  something like  4,000 tons,  therefore




larger than our first two ships.   Now, because it was so




large we realized that we have to go now in quite another




dimension about the whole business.  And, for that we




decided that before doing so we  had to answer some question




                       J.51

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and the first question was, how much chlorinated hydro-




carbon waste is in the whole world, and from the whole




possible information that we obtained, to is amounts be-




tween 500,000 tons and one million tons a year.




               Now, the next question was, how complete




is the incineration in the furnace or our ship.  The




next one was, what exactly  is  the  chemical effect of  the



combustion gases coming from the ship furnace on the sea




And, the last one was, what is the biological effect of




these gases.




               Now, I have no time to give the details.




I am prepared to answer all the questions in the inter-




val after the meeting, but the first question was answered




after tests had been carried out in the presence of high-




ly specialized people, in the presence of the Dutch govern-



ment and the result was that the incineration combustion




efficiency is higher than 99.9$,v*iich to our knowledge




and to the knowledge of all the sources, official or pri-




vate, is comparably higher than what is achieved on the




land incineration.




               The other question was, what wag the chemical




effect on the sea.   A Professor Gratsoff, from the




University of Kilamarine Institute has determined and




found in fact that it is insignificant.   A very interest-



ing point is that we were burning in the  North  Sea, we  still





                         152

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do in the North Sea, the pH of the North  Sea is 8.2 which




Is too high, close to the pollution, industrial pollution.




Therefore, practically any amount of HC1  poured in the




North Sea has a favorable effect.   But that was startling




but true.  The only thing is that the amount of HC1 that




comes out of incineration, carried on our ship, is insig-




nificant to have any practical effect on the huge amount




of water.



               The next one is, how toxic are the chlori-




nated organic compounds to marine life, and for that and




the last question we have assigned the Institute  sorbonne




which is a most suitable biological institute for marine




biology in France,  sorbonne  took samples from the sea




and contaminated this sample with chlorinated hydrocarbon,




the ones which you usually receive from industry.  And




they determined by dilutions of 1,000 to 10,000, all the




category of fish, all category of animals, died, all of



them within less than ten hours.  And, I trust and I hope




that everybody here will shudder thinking what this means



when 500,000 tons to 1 million tons of chlorinated hydro-




carbon,  which are disposed every year, all over the world,




in an iirroroper way.




               The next question was, what is the biologi-




cal effect of the gases of our combustion on the sea.




And,  what they have done, they took a sample about 60 li






                        153

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 and they took the gases directly from the furnaces and let




 bubble up the gases in the sample, 34 hours, and then they




 put the same animals that they used in the first experiment




 in this mter, and I have the report, official report,




 which is available to everybody in the world that is con-




 cerned with the environment, that there was after 70 days




 exposure no mortality or any physical disturbance was




 shown.  And this was the basis that we took for expansion




 of our business.




                What we did, we have a new ship, remember




 I said the first ship was 530 tons, the second ship was




1300 tons, the third has 4,000 tons, the new ship is going




 to be ready by January-February 1976 and it is 20,000




 tons.



                Now, you may ask why?   Somebody said that



 business is not going very well.   Unfortunately for the



 world, our business does fantastically well.   We have two




 ships and we have not been able to keep u-}  with the demand




 in 1975-    We have had companies, I won't say the country,




 that for two years they have told us they have nothing




 and then in February they called us and begged us to come




 because the police have clamped down on their operations.




 We had to remove 14,000 tons at once.




                We have one competitor -- oh, we have many




 competitors in the system, but what happened is that many

-------
industries have tried to cling to their old system, this




and this and that, and many of them with incineration on



land.



               I never heard about incineration on land



that functions properly,,  I heard about; plants that were



said to function properly.   And this is, maybe I haven't



seen anything, but in two years I have been in the United



States I haven't seen yet a plant that operates properly.



And this comes now on us with a terrific demand to come



to the rescue.   We are going to come if we clear all the



procedures with EPA by March, April, May for loading the




first chlorinated  hydrocarbon   liquids.  And here I come



to the point.



               The three existing incineration ships are



able to incinerate only liquid chlorinated hydrocarbons.



Our new ship is going to have the capability to incinerate



also solid or semi-solid.   We can also, on the two ships



that we have, we can incinerate chlorinated hydrocarbons



containing water.    And, I heard here, many of the wastes



can be treated to reduce water and so on.   I wish it was




so.



               We have among five companies, three in



the States and two in Europe, over 60O,000 tons of watery



waste that contains 95 to 96$ water.   We can burn it but



who is going to pay it.   600,000 tons that cannot be





                           155

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reduced to something like 20 to 30$ water.




               We have burned about 250,000 tons of chlori-



nated hydrocarbon liquid in six years of operation.  Now,




don't believe that this has so much in Europe, I do not




know exactly, although I think I stopped understanding




what happend in the states, but it will be interesting




for you to know that the Rhine has analyzed in 197S wi t-h



the Dutch Government with 200,000 samples and has been




found in April of this year to have more severe pollution




in Holland than in 19Y4 and the chlorinated hydrocarbons




contained is double in 1975 than in 1974.   I hope you




are in better shape.




               We think that we have opened a gate for




new directions.   I would like to make a small suggestion.




particularly because I saw an article today in the paper



talking about EPA switching to prevention and I worked 17




hard years for an American company and I learned that it




is one quality in the American approach, to go step by



step.   I would suggest this time go half step by half




step.   For the prevention you can all of you come in




from the industry, I have been a long time, 20 years in




the chemical industry, what you have to do first toward




the new company's sake and the national economy's sake,




start prevention by segregating your different wastes.




We are approached by  many,  manv  companies  who say,  can





                      156

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you help  us?  Yes, we can help everybody, but it would be




much cheaper if you would segregate right from the start




the wastes that can be disposed in a cheap way or a rela-




tively cheaper way than to mix it, as I sav,  with 600,000




tons of water.




               I have no more time but if you have any




questions, I'll be glad to answer them.




               MR. LEHMAN:  Thank you, Mr. Gallay.  It




looks like we have a number of questions here.  I would




like to ask. just one at the beginning.   Mr.  Gallay,




could you comment on the cost of incineration at sea?




               MR. GALLAY:  Yes, sir.  The cost, of




course is imoortant.°ur basic line was to be competitive



first of all with incineration on land.   For my informa-



tion, we are cheaper than incineration on land in the




States, the same level in Europe.   For the liquid chlori-




nated hydrocarbons our prices go down from $60 to $40 de-



pending on the volume.   For the solid waste or semi-solid




we have not yet burned semi-solid or solid.  We are going




to do it after we finish all our investigation of condi-




tions               of the liquid in our new ship.  That




means by June, July we start with the solid and we are




going to start with drums.   You know everywhere the prob-



lems with drums with waste and the price for this is going




to be probably between $60 and $100, but we said to all





                       157

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our potential customers, we want to first of all have a




certain volume, a. significant volume of this material




sold before we crystalize our records.




               Now, for the cost point, there is one im-




portant thing.  In order to keep the cost as low as pos-




sible, we are going to sail from Europe with European




wastes to the Americas, North and South and to sail from



American continents with the wastes from this Part of



the world to Europe, in order to kill as much as possible




the dead time for such an expensive vessel.  And to re-



flect in our prices, the lower cost.




               MR. LEHMAN:  Thank you, we have many other




questions.  Mr. Lindsey?




               MR. LINDSEY:  Yes, I have a number of ques-



tions here from the floor that are very similar.   May I




ask it in this way.  You mentioned that you know of no




land incineration facility that operates satisfactorily.




May I ask the question, why should a shipboard facility




operate in a more satisfactory manner than a land facili-




ty?



               MR, GALLAY:  All right, gentlemen, the




land incineration has to do something with the HC1.  Now,




it can either recover HC1 or it can scrub it.   The problen




is that you have to bring the gases that are going to be



at something like 1300 C   which is 2500 P. back to the





                       158

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 temperature where  the water is  still liquid, which is be-



 low 100  C.   And, I haven't heard yet of a plant that




 hasn't got corrosion problems to the point — well, any-




 way I haven't heard of any.   So, therefore, this is the



 problem of the land incineration.




               Our ships, I'm sorry, I have some slides



 but I couldn't snow them, the new ship has a furnace




 which is built in  such a way in order to insure complete




 combustion that has an opening that can be inserted in




 this room up to the first column.   It has 48 feet dia-




 meter.   Now, you can imagine what a technical problem




 would be to cover this circle in order to bring the gases




 somewhere where you could either scrub the gases or to




 recover the HC1.




               Therefore, the difference in difficulty is,




 the difference in the technique is that the land incinera-




 tion cannot let the HC1 go in the air because of the




 damage it makes to the environment and therefore has to




 recover the HCI  prescribed, whereas we let the HC1 gases




 out in the sea where it can integrate in an inorganic way.



               MR. LINDSEY:  Along the same lines, I would




like to extend that a little bit, can you elaborate any




further on how far HCI emissions from the ship are likely




to travel?   In other words, might they travel to where




the land is?





                    159

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               MR. GALLAY:  The largest distance that we



have seen is when everything Is calm on the sea, and this



was about 500 meters, 550 yards.   When you have wind or




when it_i_s a very humid atmosohere the HC1 condenses verv



quickly, in snail droplets and goes down in the sea.



               MR. LIKDSEYi  One more part of this also



from the audience.   How long can the sea continue to



absorb the off gases before there is an adverse effect?



               MR. GALLAY:  The sea?



               MR. LINDSEY:  Yes.



               MR. GALLAY:   Well, you have here, as I



said, if the combustion is complete, you have water, C02



and HC1.  Water makes C02, you will agree there is no prob



lem.  HC1, when you consider the amount of HC1 th* can



come out Of a combustion, and which is .spread on the sur-



face of the sea, you will see it as insignificant.  Maybe



I can give you something that you feel, what I want to



say.  When we started, there were these two ships, the



Dutch government had to give us an area in the North Sea



because the ships were too small to keep the high sea.



And the area that they gave us is the area with the least




traffic. we may  have heard of the problems about the



traffic in the channel In the North Sea.



               Now, we have operated six years in this




area which is the area of the fisherman — which is the




                         160

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fishermen area from the Coast of Holland next to the Hague
Six years.  And, I can tell you also that the fishermen
come with their boats at night to fish because their
catches are better, not because of the HC1, but because
of the light which attracts fishes.   But it is one proof
that in six years we did not have any unfavorable effect.
               MR. LEHMAN:  Mr. DeBonis?
               .MR. DeBONIS:  There is a question from
the audience here, it says, what is the possibility of
using HC1 for vessel fuel?
               MR. GALLAY:   I "think we shnnlfl take it
from the record.
               MR. LEHMAN:  Another question?
               MR. KOVALICK:  Prom the floor.   What pro-
visions have been made for accidental spillage of these
highly toxic wastes into marine waters during transfer
and handling operations especially considering the large
amounts handled?
               MR. GALLAY:    Yes, sir.  I do not know
to what extent you are familiar with IMCO.  IMCO is the
International Maritime Coordination Orcranizatinn,  nf
which all the European governments are members and the
United States is an observer, and as I understand they
have plans in two or three years from Coast Guard to join.
IMCO gives regulations for all chemical transport, or
                      161

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transport of all .chemical material on all waters.   You
can prepare yourself gentlemen, but two or five years from
now to have to have only vessels with double bottom and
double walls to transport these chemical materials.
               Our ships are all satisfying the import
specifications which are made just in order to avoid
spillage in case of an accident.
               Now, the past three,.though its dimension
should have a douole wall, distance one from the other one.
1 meter 40.   By chance when we bought the tanker that we
transformed into an incineration ship, had along the two
sides tanks with 5 meter distance from one wall to another
one, and it came out for us to be cheaper to leave these
walls than to put a double wall.  Therefore, we are about
three times better :than what the specification requires.
               The second thing is that the ship accord-
ing to the German specifications, which are observed now
by IMCO as well, is constructed in such a way that if it
is cut in two by another ship, both halves have to stay
floating. I couldn't tell you what happens if it is cut
in three.
               MR. LEHMAN:  We have another question, Mr.
Newton?
               MR. NEWTON:  A question from the floor.
How do your operations affect international law of the

                       162

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 sea treaties?



               MR. GALLAY:  There are no international



 law of  the  sea treaties.   That's a question.  We have



 been hammering to everyone from the states to Europe



 that the environmental authorities should start thinking



 about thJs situation.   There are no international laws



 for the high sea.



               I must say for you, gentlemen, I wish in



 Europe we had such a good year as we found in the States.



 What happens is in Oslo-  in 1972, was a conference trying



 to legislate what happens at high sea and they realized



 that that's impossible unless they are going to quarrel



 about 24 years and then if there is one small African



 Republic to say no, it will be worthless.   And for once



 they managed in 24 hours to find a brilliant solution.



 They bypassed the problem and said, all right, we cannot



 legislate the Ugh seas, but what we can say is that the



 ships who do not do what we require are not going to



 enter our ports.   And, if you are  a ship owner and you



want to make business, but you cannot go in Finland,



 Sweden, in Norway, in Germany and Holland and Belgium



and France and Britain and Ireland, in Spain, In Italy,



then you'd better close shop.



               The United States,  I said, is not a member




yet of this organization, but is a member of the Ocean





                      163

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 Dumping Convention.   We work together with the other
 thing, which in fact, although, 1 repeat, there is no
 International legislation to regulate the sea operations,
 but it is very effective for controlling what the ships
 are going  to do.
                M£( &EHMAN:  Thank you, Mr. Gallay.  Evi-
 dently we have a few late questions which we may ask you
 in writing to respond to.  There was one question that
 was really addressed  to'EPA, and I want to comment on
 that.  The question reads, there was a demonstration burn
 of chlorinated hydrocarbon on a ship in the Gulf of
 Mexico a couple of years ago, was it successful?  And,
 does the EPA approve of this method of disposal?
                This is a very complex que-fclon in the
 sense that you've got to recognize that the Hazardous
 Waste Management Division of the EPA is not the group
that issues the ocean dumping permits.   This is done
 through the Marine Protection Branch in tne Office of Wate^r Pro-
 grams        of EPA.   And also there is an Ocean Dis-
 posal Branch or at least a section in each of EPA's region-
 al offices.
                So, whoever asked this question, I would
 suggest that they get in touch with the EPA regional
 office or the headquarters office and get their view on
 the success or non-success of that type of operation.

-------
It is my understanding that the EPA1s position is that



it depends.  In other words, it is a waste by waste judg-



ment. In other words there is no carte blanche for the



whole situation.



               Ladies and gentlemen, in view of the fact



that we had a large number of questions of our last speakei



and we are very close if noi; .past   the time we announced



for our lunch, I'm going to adjourn the meeting now for



a lunch break.   We will reconvene one hour from now,



which is roughly 1:17 or 1:20, and we still have a large



number of people to speak, so we want to start again on




time.



               (Whereupon a luncheon recess was taken.)
                      165

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                AFTERNOON    SESSION








               MR. LEHMAN:   May we please come to order.



We have, I believe, Mr. Nalvin from the New Jersey



Manufacturers Association, is with us now.   I would like



to call him as our first speaker this afternoon and follow



ing him, Diane Graves of the Sierra Club, just to give you



a little advance  warning.  Mr. Nalven, please.




               MR. NALVEN:  Representatives of the



Hazardous Waste Management Division, Environmental Pro-



tection Agency, my name is David Nalven.  I appear today



as chairman of the Solid Waste Subcommittee, New Jersey



Manufacturers Association.



               The safe disposal of hazardous solid



wastes presents a problem of major concern to both the



people of the state of New Jersey and its corporate citi-



zens as well.   We face this situationJargely because the



state contains a high concentration of industries which



generate significant amounts of hazardous wastes.



               Our small geographical size and advanced



environmental control situation have served to limit our



disposal options.   While we recognize the necessity



for stringent controls on the disposal of hazardous



wastes, we have already seen how public support for en-



vironmental controls can be wakened when there is a high





                         16$

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 unemployment rate.
                The  onlycsatlsfactory  answer may be  to
 seek solutions  on a nationwide  basis.
                New  Jersey Manufacturers Association has
 been able  to work closely with  the New Jersey Department
 of Environmental  Protection and the members of  its  staff
 responsible  for developing a sound solid waste  management
 program.   We are  pleased  that together we have  made some
 measurable progress in  the development of the state's
 program.   We can  see, however,  that a complete  solution car
 not be  structured within  the state's  borders  alone.
                We,  therefore welcome this opportunity to
 address this panel  for  the purpose of recommending  the
 development  of  uniform  national  standards and the further
 involvement  of  the  Federal government in the  development
 of a national program to  "dispose of  the undlsposable."
                Our  experience in attempting to  wrestle
 with the problems of hazardous waste management and dis-
 posal has  revealed  some siqnificant issues that deserve
 your careful consideration.
                To date, no definition of the  term
 "hazardous waste" has been found to be completely accep-
table to all concerned  parties.  Perhaps the  most perplex-
 ing part of  the problem is thendwscessity  of basing  the
 definition,  or Including  therein, some reference to
                      167

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  levels of concentrations.   Since a so-called hazardous
wastei  can generally represent  a hazard to the environment
  at even low levels of concentration,  it  becomes  desirable
  to provide specific limits  -  or at the very least,  guide-
  lines - to be used.  In addition,  certain hazardous wastes
  can be put into a condition which makes  them unavailable
  to the environment.  The definition,  therefore,  should
  be based on the likelihood  of a release  of significant
  concentrations of hazardous components to the environment,
  whether in leachate,  incinerator off-gas,  or other  dis-
  charge modes.
                 Our Committee  feels that  clear delineation
  of responsibilities between generators,  haulers-collec-
  tors  and disposer should be established.   There has  been
  an unfortunate tendency to  multiply liability at each
  step  of the procedure.   In New Jersey,  for example,  the
  generator continues to be liable for  actions taken  by
  either or both of the licensed hauler-collector  and the
  ultimate disposer.  This creates the  potential for  un-
  warranted prosecution.
                 We propose the following:
                 1)  The generator should  be responsible
  for contracting with a licensed hauler and treater/dis-
  poser, properly characterizing the waste,  and maintaining
  disposal records.
                          100

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               2)  The transporter should be responsible
for obtaining a hauling license and maintaining records
of origin, destination, and characteristics of materials
hauled.
               3)  The treater/dispoeer should be respon-
sible for maintaining records of wastes received includ-
ing the identities, the transporter and generator, and
obtaining a license for operation.
               Operational standards for hazardous waste
disposal sites should not be based on the philosophy of
controlling both the internal procedures and what is re-
leased or made available to the environment.  We favor,
instead, control based on the latter, with stringent con-
trols on record keeping so that abandonment of a disposal
site does not leave problems for successors to deal with.
               Our general view is that where "possible,
private Industry should be permitted to treat and dis-
pose of "hazardous" wastes.  Industry should operate its
facilities and equipment within the constraints of regu-
lations promulgated to protect the environment.  Regula-
tions should be developed, however, designating a reason-
able timetable for the phase-out of environmentally unac-
ceptable waste disposal practices.  Industry would then
have the opportunity to provide the alternate disposal ser
vices or process modifications to comply.
                         189

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               The Association's solid waste subcommittee



has already recommended to the New Jersey Department of



Environmental Protection that regional sites should be



encouraged for certain extra-hazardous wastes.  This con-



cept should also apply at thejiederal level for certain



other wastes; namely, those that might be difficult or



impossible to dispose of within state boundaries due to



small quantitites yet high hazard potential which render



them uneconomic for localized disposal.  Some examples



are radio-active materials, certain explosives, most etio-




logical agents, war gases, some heavy metals, and other ma



terials of an especially toxic and hazardous nature such



as dioxin or PCB's.



               It may be that past and present methods



of disposing of, for example, war gases, should be re-



viewed before a determination is made as to whether pri-



vate industry or the Federal government should handle



these exotic wastes.



               We would like to repeat our point, that



hazardous waste disposal is of special concern in our



small state.   Solutions that do not recognize the na-



tional nature of the problem will inevitably end up as



 discriminatory to New Jersey industry.   Solving the



problem must be accomplished without putting an additional




burden on New Jersey residents and their Industries.




                          170

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               We thank you for this opportunity to express



our views.



               MR. LEHMAN:  Thank you, Mr. Nalven.  will



you accept questions, Mr.  Nalven?



               MR. NALVEN:  Yes, certainly.



               MR. LEHMAN:  Mr. Kovalick, do you have a



question?



               MR. KOVALICK: Yes, I have a couple while



we are waiting for some from the audience.  First of all,




for clarification   does your Association represent the



category of industry we would call generators or also



treaters and disposers of waste or both?



               MR.  NALVEN:  We are not restrictive.  The



committee on which I'm a member, the Environmental



Quality Committee aid the Subcommittee on Solid Waste, is



a subcomittee thereof, we have only generators.



               MR. KOVALICK:  I see.  The second ques-



tion.



               MR. NALVEN:  I would like to add that some



of our generators have on-site disposal facilities of



their own.



               MR KOVALICK:    You mentioned,  if I could



find my place, the statement,  well I recall a statement



that Mr. Palmer from DuPont  made this morning and he



uses the words performance standards referring to the





                      171

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kinds of standards and guidelines that he believes to be
most desirable.   That is, standards or guidelines govern-
ing what comes out of the site.   Do I Interpret your
endorsement to be the same here?
               MR. NALVEN: (We do favor what Is released
into the environment.
               MR. KOVALICK:   As opposed to regulations?
               MR. NALVEN: , To what goes Into a facility.
               MR. KOVALIffiK:   Or a process?
               MR. NALVEN:  Yes.  What may come out of
it or what Indeed comes out of it.
               MR. NEWTON:  Mr. Nalven, I note the state-
ment in your testimony that in New Jersey the generator
continues to be liable for actions taken by either or
both of the licensed hauler/collector and the ultimate
disposer.  We would be interested In the statute> regula-
tion or case law under which you base that statement?
               MR. NALVEN:  We w°uld be very happy to
supply that to you.  I don't have it right here with me,
but if somebody here could give me the address to get it
to, I would be more than happy to send it to you.
               MR. NEWTON: Pine, I would appreciate that.
The address, of course, is in our Federal Register notice.
              MR. NALVEN:   jn the Federal Register notice)?
               ME. NEWTON:  Yes, do you have that?
                          172

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               MR.  NALVEN:  Ves.
                MR. LEHMAN:  Any further questions?
                MR. KOVALIffiK:  On page 4 you noted the
 Association has recommended that regional sites should
 be encouraged by the State of New Jersey for certain
 extra-hazardous wistes,  and this concept should also apply
 at the Federal level.   Could you elaborate on what you
 meant by encouraged?
           MR. NALVEN:       We  feel  that the State or the
Federal  government,  as  the case may be, should assume the
 leadership in this area of how such a regional site should
 be set up.  We have  discussed this at great length with
 the state, our discussions are  continuing.   It isn't an
 easy problem for the state, we  certainly don't feel it is
 an easy problem for you,  as a Federal government, but we
 do feel that there are  certain  wastes which must be
 handled, which an individual company and some very large
 companies cannot handle by themselves, which even a pri-
 vate waste disposer  may not be  able to handle,  and perhaps
 a larger geographical  area, a  larger population area or
 a  larger industrial  population  area must be included.
                MR. LEHMAN:  I have a question,  Mr.  Nalven,,
 when you say regional facility,  do you refer to a region
 within a state or a larger  region that might contain more
 than one state?
                      173

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               MR.  NALVEN:   of neaessity, first of all,




 we're talking, when I talk about our discussions with the



State of New Jersey, we are certainly talking about with-




in New Jersey, because that's the only area that they have



to operate.   But we also feel that it is very likely



that when we say regional, now to you, we may mean several



states or maybe a large portion of the country.  We do



not even see that it would rule out the possibility of



one site for the whole 48 states.




               MR. LEHMAN:  I see.  Do we have any other



questions?  I guess not. Thank you very much, Mr. Nalven.



Our next scheduled speaker is Diana Graves of the Sierra



Club, is she here?  Momentarily.  Our next qaeaker on our agenda



is Mr. Clarence Moore of the National Barrel & Drum



Association.   Is Mr. Moore here.  Mr. Moore please.



               MR. MOORE:  Thank you, Mr. Lehman.  If



the thickness of the copies distress any of you, most



of it is attachments.



               My name is Clarence Moore.   I am the



Environmental & Legislative Consultant for the National



Association of Barrels and Drums.  And, this statement is



submitted on behalf of the National Barrel and Drum



Association, a trade association with headqaurters in



Washington, D.C., representing some 175 steel drum recon-




ditioning companies throughout the United States,




                            Ilk

-------
responsible for reconditioning and returning to commercial



reuse approximately 73 million drums annually.   That



represents about 85% by volume of the steel drum recondi-




tioning done in this country.



               The purpose of this statement is to propose



recovery from the Nation's solid waste disposal problem



of an estimated one million tons of steel annually.  Addi-



tionally, our proposal would result in the  elimination of



an imminent environmental and public health hazard, asso-



ciated with the current pesticide container disposal prac-



tice, as well as other highly toxic substances.



               A further objective of this proposal is



the removal of the prohibitions and restrictions on the



use and reuse of toxic  containers subject to certain limi-




tations which result in the loss of valuable natural re-



sources and the wasteful use of energy, as well as contri-



buting to the problems of hazardous waste disposal.



               This proposed solid waste management via



resource recovery concept is predicated upon the utiliza-



tion of existing technology within a viable industrial



group, which has its roots firmly implanted in resource



recovery, through the repetitive reuse of packaging mater-



ials.



               In recent years pesticides have become a





very important and vital part of agricultural technology.





                           175

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 The use of these substances has resulted. In greatly in-



creased productivity per  acre  of both food and fiber.



               The Council on Environmental Quality



in its annual report stated that domestic use of pesti-



cides, et al, is in excess of 8oo million pounds annual-



ly and the amount used continues to grow each year.   An



example of this growth pattern in pesticide  usage can be



seen in the increase between 1966 and 1971.  In 1966 the



estimated  usage was 68l million pounds, by 1971 up to



833 million pounds, an increase of 22$.



               This continued increase in pesticide use



has produced public concern regarding the toxic aspect



and the persistence of these chemicals in the environment



and this public concern has resulted in both Federal and



state regulations governing the use of the substances.



               But one major aspect of pesticide  usacje



that remains to be dealt with,  i.e., the impact of pesti-



cide container disposal on the solid waste management



problem.  For as pesticide usage    las increased, so have



the number of containers whlchnust be disposed of.



               Now, one of the critical problems associated



with empty containers is that they are not completely emp-



tied  and small quantities of active ingredients, remain



in the containers.   Various rinse and drain plans have





been instituted to minimize  hazards associated with



                            176

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exposure and contact with empty containers, but these



plans have had only very limited success.  The majority




of empty containers are still disposed of in an improper



and hazardous manner.  This represents a significant



nationwide disposal problem for emptiers of pesticide




containers.



               It is not uncommon for farmers and appli-



cators to discard the containers in the most available



area, where, in addition to causing the pollution by



leakage, rust, etc., they become readily available for



misuse and handling by persons not aware of the dangers



associated with the residues.



               To date there is little or no incentive



to return these containers to the supplier or for sal-



vage, and only limited areas of the country have pro-



vided facilities for the disposal or storage of empty



pesticide containers, although studies to date have indi-



cated that farmers recognize the problem of empty pesti-



cide container disposal and would be willing to cooper-



ate in a solution aimed at solving these disposal prob-



lems.



               An example of the magnitude of the problems



associated with empty pesticide container disposal is



the 417 page workshop report of the Federal Working Group




on Pest Management.




                         177

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               Incident reports involving the environment




human health and animal losses as a result of improper




management of empty pesticide containers can be found in




various reports, the most recent of which is the Toxi-




cology of Pesticides.




               Now, one suggested solution to the pesti-



cide container disposal problem is by disposal in land-




fill areas.  Yet this catchall solution ignores the




issues concerning the safety of employees and equipment;




additionally it contributes to the depletion of a valu-




able natural resource, steel.   And, it also increases




associated energy costs, according to CEQ reports, which




estimated that each 1 million tons of steel lost to land-




fills cost the equivalent of 1.5 million barrels of oil.




               The pesticide container disposal problem is



only the tip of an iceberq  just forming, as daily more



and more substances are declared to represent threats to




human life and the environment and potentially millions



of additional containers will compound the solid waste



management problem.  And as with pesticide containers




the majority of these containers still contain residues



of the original materials.  In a few selected areas of




the country these containers are being collected and




placed in public or privately operated landfills, which




is clearly neither an adequate nor totally safe resolution





                          178

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of the problem.



               The use of landfills to dispose of pesti-



cide as well as other toxic substance containers raises



many serious questions, which might best be summarized by



the comments of Dirk R. Brunner, of ..the EPA Solid Waste



Research Laboratory, at the 1972 conference on pesticide



containers (the report is one of the appendices), and the



last paragraph reads as follows:    This is Mr. Brunner.




               "So we've got these problems with pesti-



cide containers, and how to get rid of them in a land-



fill.  If it is truly a sanitary landfill, the ground



water and surface water contamination problems are mini-



mal.  But there aren't too many sanitary landfills around.



The problem then revolves around what happens to the



employees who are disposing of these containers as well



as other hazardous wastes at the landfill site."



               In writing the Solid Waste Disposal Act,



the findings of the Congress as stated in     section 202



of the Act, were in part that inefficient and improper



methods of disposal of solid wastes result in scenic



blights, creates serious hazards to public health, have



an adverse effect on land values,  create public nuisances



and further,  that the failure or inability to salvage



and reuse such materials economically results in the



unnecessary waste and depletion of our natural resources.





                         173

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               One stated objective of the act was to con-



duct investigations to determine means to recover materials



and energy from solid waste.   It is our aim to deal with



that aspect of solid waste disposal associated with pesti-



cide containers.



               The numerous problems associated in this



field have been thoroughly documented in the literature.



The problems which have received the greater attention



have been centered around those incidents involving in-



juries and the occasional loss of human life, fish kills,



and ground water contamination.



               Now, our proposal is predicated upon the



utilization of the existing steel drum reconditioning



plants within the Continental United States for the re-



conditioning of pesticide and other highly toxic contain-



ers, which previously held more than 15 gallons.  The



members of this industrial community who would be able to



participate in this plan are geographically well distribu-



ted, with economically viable facilities, including proper



burning facilities, and a list o'f the members of the



National Barrel &  Drum Association who have proper burn-



ing facilities, more than 50, is available upon request.



               An important element in the proper disposal



of these empty toxic containers is decontamination by the



emptier.    This has been recognized by the manufacturers





                             IbO

-------
of these pesticides.  The National Agricultural Chemicals



Association of Washington, D.C. has recently published



an updated booklet entitled "Disposing of Pesticide Con-



tainers", which recommends a rinse and drain procedure,



prior to shipment to a drum reconditioner.   The con-



tainers would then be burned out in a drum incineration



furnace and reconditioned via standard reconditioning



methodologies by companies with adequate facilities.



Those containers found to be unacceptable for recondition-



ing after burning could then be shipped to a scrap dealer



for recovery of the steel.



               Now, a mini-model of this plan was sub-



mitted by Dr. Joseph Hooper, President of W & H Industries



Inc., to the California Department of Agriculture and has



been operational in the State of California for approxi-



mately one year.    A copy of that Code is attached as




Appendix B.



               On February 14, 197^, a comparative study



of the energy requirements of steel drum manufacturing



and reconditioning was prepared by Trussing and Prussing



of Urbana, Illinois, and this is attached to my statement



as Appendix C.   Data utilized in developing the pesti-



cide container recovery plan In Tables 1 through 5 are



modified with the same computer program, attached as



Appendix D to my statement.






                         181

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               To highlight the energy savings of the pro-
posed system of reuse of toxic containers, we quote from
the Abstract on the second page of the Prussing report,
which says:
               "Single use drums require twice as much
energy per fill as heavier drums •  which can be recondi-
tioned.  This is because the greatest energy requirement in
the steel drum system is for the manufacture of steel. It
takes roughly ten times as much energy to manufacture a
drum as to recondition a drum.
               A shift from the current mix of reusable
and single-use drums to an all 18 gauge drum system, with
an average of eight reconditionings per drum (9 fills)
would create energy savings of 17,043 billion HTU per year
which is   23$ of the total energy requirements of the

present system and enough energy to provide electric power
for one month to a city the size of San Francisco."


               Currently, the agricultural chemicals in-
dustry annually utilizes an estimated six million steel
containers with a caoacitv greater than 15 gallons.
This accounts for an annual depletion of steel in excess
of 1 million tons and up to this time, very little empha-
sis has been placed on the reuse of these containers or
the recovery of the scrap steel.  Authoritative estimates

                                162

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place 3$, only "$%, as the figure representing the combined
reuse and recovery portion.  If the total number of con-
tainers recovered for reuse or resource value were to be
increased to 40$, the energy savings would be 2,826 trillic
BTU's annually.
               Ancillary to the energy and resource re-
covery aspects, but not less important is the.oublic
health and environmental aspect for which no economic
value can be clearly defined but which must be clearly
shown as a portion of the solid waste disposal problems
associated with these containers.
               Gentlemen, I thank you for the chance to
present this statement.
                       163

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                                                  APPENDIX A
             Excerpts From Comments Of Mr. Dirk R.Brunner
       U.S.  Environmental Protection Agency,  Cinncinnati, Ohio
             At The 197Z Conference on Pesticide Containers
      "Presently there are two basic methods for disposing of solid waste,
and I am including pesticide  containers as solid waste:  incineration and
sanitary landiflling.  I'll limit my subsequent comments to sanitary land-
filling because I am not competent to critically evaluate incineration of
pesticides and their containers.

      Sanitary landfilling is a bit more than the  dump that probably serves
your hometown.  In fact,  the 1968 national survey indicated 6 percent of
the nation's solid waste disposed on the land was by sanitary landfilling.
This figure was based on very rough criteria, even excluding an investigation
of ground water impairment. The number of acceptable disposal sites would
be lower if more stringent criteria were used.  This severe shortage of  suit-
able solid waste disposal sites indicates there are few acceptable sites for
disposal of pesticides and pesticide containers.

      California, a leader in landfill technology, can be used as an example of
the shortage of acceptable sites.  There are presently only 11 Class 1 disposal'
sites that accept all.types of pesticides and  containers.  For the less hazar-
dous pesticides, the more prevalent Class 2 disposal sites can be used.  EPA's
position stated in a brief paragraph in Sanitary Landfill Design and Operation
published this year, allows the disposal of empty pesticide containers at all
sanitary landfills.  If we  look at the California guidelines for pesticide con-
tainer disposal, empty containers can only be disposed if they are rinsed.
More work is definitely needed in this area  before the establishment of  sound
guidelines.

      What are some of the problems that the landfill operator  has?  Basically,
they revolve around the health and safety of the  employees.  What type of em-
ployees do we  ha.ve ?  We have poorly educated people who are working on the
collection route and at the disposal site itself.  The specific jobs performed
by disposal site employees are equipment operators and spotters. The equi-
pment operator,  located several feet above  the  solid waste,  spreads and com-
pacts the solid waste (including pesticide containers and other hazardous wastes)
8 hours a day. In other words, these people endure long-term exposure to a
variety of hazardous materials.

      The Spotter is responsible for directing collection vehicles to the ap-
propriate areas for waste deposition and subsequent spreading and compacting.
Typically, the spotter stands in or adjacent to the waste through most of the
day.  He consequently is exposed to the dusts, aerosols, splashings, and oc-
casional explosions associated with the waste deposition.

      These two employees at the landfill site are the ones who are exposed
the most to pesticides in the solid waste disposal field.  They are the

-------
                                                           Appendix A cont'd
potential victims of the pesticide problem and the hazards associated with it:
the irritants,  the breathing of toxic chemicals, and so forth.

      How can we approach these people and solve their problem? We can
provide a public education program, directed through their trade organi-
zations.   We can do it at the federal level in programs.  We have, in the
past, directed training programs at the public administrator, the engineer,
and the public.  We are now directing our training efforts to all the operating
people, the ones who are intimately involved.  Basically, we've  got the
same problem the trucking industry has, or any one of  the transportation
industries that are only partly affected by the pesticide program.  That is,
many of the employees are not aware of the problems and they do not know
how to handle  the pesticides. They don't really know how dangerous they
can be or whether or not all of them are dangerous.

      This is  the type of information that I feel should be labeled on the
container when it's brought to the landfill.  We must  remember that people
are at the disposal site.  We have to consider the durability of that container
all the way through the system, and specifically the  label.  Without notifying
these people about how to dispose of a pesticide and the problems associated
with it, we are exposing them to potential accidents and explosions. There
have been explosions due to  the carrier liquid in  the pesticide; when this
occurs at a sanitary landfill, both life and equipment are endangered.  The
bulldozer is a minimum of $50,000  investment for the landfill operator; you
can't put a dollar value on the operator's life or health.

      We  can  also have inhalation of dusts.  There was  one example following
a warehouse fire.   Several thousand pounds of damaged packages containing
pesticide  dust were to be disposed of.  The-containers were brought to a land-
fill site;  a dozer was run around to  cover them over with soil.   The whole
time the  dozer operator was working, he was breathing in the pesticide dust.
How did this affect him? We don't know.  There  was no investigation of this
particular incident in terms of health and welfare of the  dozer operator.

      So  we've got these problems .with  pesticide  containers, and how to get
rid of them in a landfill.  If it is truly a sanitary landfill, the ground water and
surface water contamination problems are minimal.  But there aren't too
many sanitary landfills around.  The problem then revolves* around what
happens to the employees who are disposing of these  containers as well as
other hazardous wastes at the landfill site.
      Dirk R.Brunner is Project Manager of the Land Disposal Project, Solid
Waste Research Laboratory, U. S. Environmental Protection Agency, Cincinnati,
Ohio. He graduated from Clarkson College, Potsdam, New York, with a major
in civil engineering, and did graduate work at the University of Maine in sanitary
engineering.  He joined the U.S.Public Health Service, Solid Waste Program
in 1968, and this work became part of EPA's responsibility in 1970.
                                                   165

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 November 19,1974                                  APPENDIX  B





               r.Eco>3!r:«>KD  ruomiuw: AJJD rpj.cricns TOR THE
     I'uroiiant  to Aitlcle  10,  Section 3143, of the California Ada.lniEtra-




tlvt Code, the folloujuf;  nrc  t lie criteria for tlic reconditioning of  ur.cd




pcnticide containers with a capacity of 28 gallons  or rare.




     Tlicce reconditioning procedures apply to nil r.utli ppi;tlcide con-




tninerG except tlioi;e v/liirli have contnlned organic n-2rcuiy, lead, cadclum,




or  nrscnic.




     Those procedures  are otriicturcd to minimize potential adverse public




health, vorkcr health  and/or  environmental ir:pact wiiich could arise  as  a




result of the  folio 'Ing:




     Tr^ir.port.Ttion of Enptied ContninerB.




     Storage of Emptied Containers.




     Reconditioning of Emptied Containers.




     Etcployoe  Exposure to refit lei den.




     TenLlcide r.e.ildue Wr.ponnl.




     Container Hcuce.









TRAHSFORTATI ON OF EKPTjr.D CONTATt;fcRS_




     A Bj'cclflc 'ti'hck  chnll be  itcr>t(oocd of not  ler.s than 10*




sodium hyciroyide r.nd 2-1/72 codlini  gluconilc  followed  by a voter rince.




     AM [jcitlclrfe co/   -i*  i'_-/-o rolJected L-ijnt  huve Lvnf,!;  in piece wlien








                              1GS

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                                                      Appendix B cont'd


 loaded  nud  transported,  nnd  bh.ill be  m'.oquately  secur.-d to prevent  Ion:,

 fron tlic  vehicle vhilo  In  transit.



 STORAGj: _0_F_LKPTIE!) _CONTA1_ME_RS_

      A  upcclflc ctoragc  area exclusively  for pesticide containers shall

 be  provided with n cHu'i-proof  fenrc  nnd  locked  gate.s.  In addition,

 thin area dull be located GO aa  to ntnlnizc exposure of any cnployoe

 vho lo  not  Involved  In handling u'jed  pesticide contQine.rs.

      The  area  dull  bo ported wl th w.TrnJng ai^ns on cr.ch side aud on

 t;hc C'1t:e  In English  rnd  any  othor Inncuacc nr-eonsary, nubotautlally as

 follows:
                                  DANOKR
                            POISON ST(Jli/,CE  ARM

                     All Un.iMthori/t'd  l'err,oiT3  Kcnp  Out
                     Keep  Door Locked  \.1ien  !lot_In J!EC_ _

      This sign  Diuct  be of auch  size that it Jr, readable at a distance

 of  25 feet.

      The otorage  area ehnll be  pioLected froia flooding by off-Kite

 waters.  In addition, the grading shall lur. (o a central collection

 suup  for collection  of vehicle  decontaulnation proreas waters, other

 wastes accumulated in the Btornge area, and on-r,itc  droincce.

      All containers  etored  in this r.rca ohall  h.'ivc bungs in place.

      Adequate soap,  clean touoln,  and not  Iccn  than  20 gallons of water

 shall be maintained  in the  ctorrge area for emergency washing in the

 event of skin contact uith  a pesticide renldual.



RECONDITIONJHC OF EMPTIED CONTAINFRS

     In nil c<>j-,c.s, the flnsheic,  f.nd/or etrippern  r.hall be ur.ed exclusively
                                      1ST

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                                                Appendix  B conttl




for pesticide containers.  The  cor.jntngllng of Ihc pc-iticidc contalnmi




with other containers  in the  san-o  cleaning process  shall  be prohibited.




     Reconditioned pesticide  containers shall not bo  irlxcd with other




containers and shall not he reused as food, feed, beverage, drug, or




co'iraotic containers.




     Containers  to be  reconditioned cliall have only the head of said




container removed.  Jn_iio__r.ji'>e _f-.hn]_l_ thc_ rntj_ bcp.rlnjj_ t he DOT ccibossrjcnj^




be tcroved.  The  container and  its reriovcd cover khall be placed in 3




drun burn out furnnce  operating at a njnfirura of 1/iQO"  F with a dwell time




o£ five (5) ipfond-i.   In addition, the ftitv."i__fron_l.li_f  fjjrr^a5_e_r,uM:_l^'J£




tlirou^li an after  burner operating  at a ulninun'of 1650° F.  From here the




container shall be reconditioned by sr.-inilird accepted  reconditioning




processes.










tMPJ. 0YKE__EXF 0!; U RE




     For each cir^loyce being  nssigund to i.-ork v;ith  used pesticide




containers, Che employer f.h.ill  ariange \;Lth a pliysiflan to have a base




line cholinesterase determination.  Furtlrrr r.onltoring of e.-.ch er.ployee




shall be detcrnined by the physician.




     No employee  .shall be permitted to vork with contni.'injted con-




tnlrcrs unless he is utilizing  all applicable protective  clothing and




equipnjcnt.




     No employee  under 18 years  of age sh.i)! be pemittcJ to work with




or handle pesticide containers before reconditioning.




     The employer shall provide  adequate  Inr, truct f on ,'nd  training of




Gup< rvicors and en.ployees oo  they  uniiemt.'ind  tt;o safety procedures




required for the handling of  their  con f. 'iv:ra.
                                     168

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                                                          Appendix B cont'd





      No employee  :,hcmld work alor.e h.mdllng rcutninero  except v'non s,u,ief-




 vision is  provld.-d  at  Intervals not rxcndlnj;  2 hours.   Ertvecn the




 liours o£ 6:00  p.m.  and 6:00 a.m., at  len-jt two crpJoyecs arc required




 to work together  uhuii handling such containers.




      Ilo Enoking or  eating  khall be permitted in any  area, where such




 containers arc processed or stored, nor shall  food or tobacco be




 permitted  to be r.tored in  thcue areas.




      Krijployecs ehall be iiiot meted to rer.^ve their protective clothing




 and cquipnont  at  the end of ench day.  No cr.iloyoe t,hall be ^emitted




 to tnke hone protective clothing or cqulpK>nt i;orn whije working with




 euch containere.  Clean outer clothing cuch ae coveralls chr.ll be worn




 daily.




      Mien  illncsc is apparent, or uhen expocurc h.is  occurred that nay




 be expected to lead to an  illness, the enployce bhall be taken itr;>jdiately




 to nn appropriate uedicnl  facility for tieatrnnt.









 RESIDUE DISPOSAL




      All caustic  v/osh solutions and contininef product residuals shall be




 disposed of by  off-site disposal in a land fill authorized  to accept




 hazardous  and/or  cxtreirely hmacdovs wastes in accord with  the regula-




 tions  of the State. Popartmfnt of Health in Title 22,  Division 4,




 California Administrative Code.









 CONTAINER REUSE




     Reconditioned pesticide containers  shall not  be  cold for,  or  be  used




a3, food, feed, br-verngn, drug,  or  cosmetic  containers.
                                       163

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         THE ENERGY REQUIREMENTS OF STEEL DRUM




           MANUFACTURING AND RECONDITIONING
                          by



                 Laurel Lunt Prussing



                         and



                   John E.  Prussing
Urbana, Illinois                        February  14,1974
                       130

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                       ABSTRACT
     This study estimates and compares the energy require-
ments of reusable and single-use steel drums.  Single-use
drums require twice as much energy per fill as heavier drums
which can be reconditioned.  This is because the greatest
energy requirement in the steel drum system is for the manu-
facture of steel.  It takes roughly ten times as much energy
to manufacture a drum as to recondition a drum.
     A shift from the current mix of reusable and single-
use drums to an all 18 gage drum system with an average of
eight reconditionings per drum (9 fills) would create energy
savings of 17,043 billion BTU per year, which is 23% of the
total energy requirement of the present system and enough
energy to provide electric power for one month to a city
the size of San Francisco.
     Further energy savings could be realized if the number
of reconditionings of reusable drums could be increased.
                              iSl

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                   TABLE OF CONTENTS
List of Charts and Tables	ii




About the Authors	 iii




Introduction.	1




Estimates of the Energy Requirements for Steel Drums...1




Conclusion	................10




References	 12




Technical Appendix	A-l

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              LIST OF CHARTS AND TABLES
Flowchart, Steel Drum Reconditioning System.
Table I Estimated Energy Requirements for the
    Manufacture, Transport and Reconditioning of
    Steel Drums	4
Table II Energy Requirements*  Manufacture and
    Delivery of New Drum to Filler;  Reconditioning
    and Delivery of Used Drum  to Filler	.....8
Table III Comparison of the Cumulative Energy
    Required for 100 million fills of Reusable
    and Single-use Steel Drums	
                              133

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                 ABOUT THE AUTHORS

LAUREL LUNT PRUSSING
     Mrs. Prussing is an economist with research and
practical experience in the economics and politics of
recycling.  Her academic background includes A.B.,Wellesley
College* A.M.(Boston University, and graduate study at the
University of California, San Oiego.  She is presently a
Ph.D. candidate in the Department of Economics at the
University of Illinois at Urbana-Champaign.   As an elected
official of Champaign County, Illinois, she is charged with
the responsibility of finding solutions to county solid
waste problems.  She was formerly an Urban and Regional
Economist with Arthur D. Little, Inc., Cambridge, Massa-
chusetts and an Economist at the Center for Advanced
Computation, University of Illinois.

JOHN E. PRUSSING
     Dr. Prussing is an Associate Professor of Aeronautical
and Astronautical Engineering at the University of Illinois
at Urbana-Champaign.  His academic degrees -are S.B., S.M.,
and Sc.D. from the Massachusetts Institute of Technology.
His research and teaching interests are in optimal control
of dynamic systems, a field in which he has published
numerous articles in professional journals.   Prior to
joining the faculty at the University of Illinois, Dr.
Prussing was Assistant Research Engineer and Lecturer at
the University of Californiat,San Diego and at M.I.T.
                           Jio'4

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INTRODUCTION
     This study was commissioned by the National Barrel
and Drum Association to determine the energy requirements
of reconditioning steel drums versus discarding or recycling
drums by scrapping and remelting.  The steel drum recondition-
ing industry has long promoted its product as a more economical
alternative to single-use or limited reuse drums.  However,
as in other types of packaging, there has been a trend toward
throw-away steel drums.
     In 1973 fuel shortages caused Americans to realize that
nature's riches are not infinite.  The United States may be
returning to an earlier ethic of resource conservation.  It
is appropriate to examine the role of the steel drum recon-
ditioner in such conservation.
     The method used in this report is based on Bruce Hannon's
classic study of the energy requirements of reusable versus
recyclable beverage containers.  Professor Harmon has been
of invaluable help in this analysis of the steel drum industry.
ESTIMATES OF THE ENERGY REQUIREMENTS FOR STEEL DRUMS
     Energy use can be studied at many levels, for most industries
are interrelated.  This report is based on a model which abstracts
1 Bruce Hannon, "System Energy and Recyclingi  A Study of the
  Beverage Industry", Document No. 23, Center for Advanced
  Computation, University of Illinois at Urbana-Champaign,
  January 5, 1972, revised March 17, 1973.
                              135

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from that maze of interrelationships and selects the most
significant energy requirements of the steel drum system.
     This study traces the energy needs of steel drums from
raw materials procurement through steel making, drum manu-
facturing and reconditioning and all transportation links
between these activities.  The flow chart on page 3 shows
the steel drum system and the processes for which energy use
was estimated.  Activities enclosed by broken lines on the
chart were not included in the energy estimates.  The energy
requirements of fillers and industrial users, for example,
dwarf the portion that might properly be allocated to the
use of steel drums within the industry.
     Although there are other industries besides steel from
which drum manufacturers purchase inputs (e.g., paints) sheet
steel comprises 95% by weight of all such inputs.  Similarly
an insignificant fraction is omitted by not including chemical
and paint purchases by reconditioners.
     Table I on page 4 gives the energy required at each
stage of the flow chart for three types of steel drums,
the durable 18 gage drum, the lighter weight 20/18 gage
drum and the single-use 22 gage drum.  Although the 18 gage
drum is heavier and requires more steel and more transport
energy at each stage, its ability to withstand many recondi-
tionings eventually reduces its total energy requirements
considerably below the 20/18 gage reusable drum and the 22
gage single-use drum.
*Notet the finished weights of these drums are 46 Ib.,  38 Ib.
and 28 Ib., respectively. Each requires an additional 25% of
steel from the steel mill to allow for fabrication scrap.

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                       FLOWCHART

            STEEL DRUM RECONDITIONING SYSTEM
u
tn
        RAW
     MATERIALS
         I
Scrap
       STEEL
       INDUSTRY
        DRUM
        MAKER
      UJT
        FILLER
    I  INDUSTRIAL »
    I    USER  -  I
              _J

1 .
^
DISCARD |
-I




RECONDITIONER,









SCRAP
^ UKALER

                            1S7

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                      TABLE I
 ESTIMATED ENERGY REQUIREMENTS FOR THE MANUFACTURE,
    TRANSPORT, AND RECONDITIONING OF STEEL DRUMS
         Process
Energy Requirement
 (1,000 BTU/drum)

Mining of ores
Transport of ore
Manufacture of steel
Transport of steel to
drum manufacturer4
Manufacture of drums
Transport of scrap from
drum manufacturer to
steel industry
Transport to filler
Transport of filled drums
to industry
g
Transport of used drums »
a) to reconditioner
b) to scrap dealer
c) for discard
Reconditioning of drums
Transport of reconditioned
drums to filler11
12
Scrap yard
Transport of scrap to
steel industry
18 gage drum
(46 Ib.)
100.1
27.0
1,322.5
10.9
113.0
2.7
7.2
108.7
2.0
1.4
1.4
147.6
2.5
0.9
5.9
20/18 qaae drum
(38 Ib. )
82.7
22.3
1,092.5
9.0
113.0
2.3
6.0
107.0
1.7
1.2
1.2
147.6
2.1
0.9
4.9
22 aaqe
(28 Ib.)
60.9
16.5
805.0
6.7
113.0
1.7
4.4
104.8
0.9
0.9
	
	
0.6
3.6
Notes on following page
                               en

-------
Notes for Table I (complete list of references on

1. Hannon, Table 3: 1,740 BTU/lb. of finished steel

2. Ibid., 470 BTU/lb. of finished steel

3. Ibid.. 23,000 BTU/lb. of finished steel

4. Ibid., 190 BTU/lb. of finished steel to transport steel
   to drum manufacturers an average of 392 miles.  Includes
   weighted average of rail and truck transport at 640 BTU
   per ton-mile and 2,400 BTU per ton-mile respectively
   (Hannon, p. 12)

5. Census of Manufactures, MC67(S)-4, Table 4, "purchased
   electricity" converted to thermal energy at 1 kwh= 11,620 BTU;
   "kilowatt hour eqivalents of purchased fuel" converted to
   thermal energy at 1 kwh=3,412 BTU (Hannon, p. 12).  Alloca-
   tion of fuel requirements for steel drums in SIC 3491,
   "Metal Barrels, Drums and Pails" computed from the value
   of steel drums as a percent of the value of the industry's
   total output in 1967 (reference 3).  This share—65%—is
   virtually identical to the physical measure of drum output
   versus total output in terms of the surface area of the
   steel processed.

6. 25% of the transport energy used from steel industry to
   drum industry

7. Average distances and mode of transport from reference 4

8. Share of drum output to each filler from reference 5,
   distance and transport mode from reference 4

9. Reconditioner receiptsi 85% local by truck 10 miles; 14%
   by truck 100 miles; 1% by rail 250 miles.  Energy of local
   truck shipments! 4 miles per gallon diesel fuel; 138,000 BTU
   per gallon.  Energy to scrap dealer and discardi 10 miles
   by truck; 4 miles per gallon diesel fuel; 240 drums per
   truck.  Energy reduced for lighter drums by weight.

10. Reconditioning energy: natural gas (1 therm= 10  BTU),
   purchased electricity as in note 5 above

11. Reconditioned drums shipped an estimated 25% further
   than reconditioner drum receipts

12. Gasoline consumption of scrap dealer less energy for
   10 mile haul from local sources (note 9 above)

13. Based on average shipping distance of a midwest scrap
   dealeri 400 miles by rail
                               iS3

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     The manufacture of a steel drum begins with the mining
and transport of ores to the steel industry.  Sheet steel
from the mill is then shipped to the drum manufacturer.
The steel required to make a drum includes an extra 25%
allowance for each pound of finished  drum to account for
scrap incurred in the drum manufacturing process.  This
scrap is returned as an input to the steel industry.
     Steel requirements and transportation energy are estimated
in proportion to the weight of each of the three types of
drums.  Drum manufacturing energy, however, was estimated as
equal for all three, since surface area rather than weight
seemed a more reasonable measure of the energy used in the
fabricating of drums from sheet steel.
     The transport  energy required to ship drums to fillers
was estimated from a weighted average of the proportion of
drums shipped by rail and by truck.  Slightly more than half
of new drums are shipped by truck and the rest are shipped by
rail.  Rail shipment takes about one fourth as much energy
per ton-mile as truck shipment (640 BTU per ton-mile, versus
2,400  BTU per ton-mile according to Hannon's estimates).
     The energy required to ship filled drums to industrial
users was computed as a weighted average based on the type of
filler (chemicals, SIC 281; paints, SIC 2851; and petroleum
products, SIC 291), the average distance to customers from
each filler by rail and by truck, and the proportion of each
filler's output shipped by rail and by truck.

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     Once drums are emptied by industrial users they can
be reconditioned, scrapped, or discarded. (In this model
we have included in "discard"  drums which may find a useful
purpose such as highway markers or even stoves and shower
stalls in Alaska; in short, drums which are no longer used
to ship the output of fillers.) The energy required to ship
used drums to any of these alternatives is relatively small.
     Information on the energy used to recondition drums was
supplied by a reconditioner who prefers to remain anonymous.
Reconditioning energy was assumed to be the same for both
types of reusable drums since the energy is needed to clean
and repair drum surfaces.
     The energy requirements to ship reconditioned drums to
fillers and to compress drums for scrap and to ship the scrap
to steel mills are negligible compared with other requirements
of the drum system.
     Table II on page 8 sums the appropriate energies from
Table I and indicates the savings made possible by recondi-
tioning a drum rather than manufacturing a new one.   For the
18 gage drum reconditioning energy is one tenth as much as
manufacturing energy.
     Table III on page 9 indicates the total amount of energy
which would be required for each type of drum to provide 100
million fills, the estimated annual number of fills of steel
drums in the United States.  The energy ratios at the bottom
of the table show that an all single-use drum system would
                            201

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                       TABLE II




                 ENERGY REQUIREMENTSt

    MANUFACTURE AND DELIVERY OF NEW DRUM TO FILLER;

  RECONDITIONING AND DELIVERY OF USED DRUM TO FILLER

                   (1,000 BTU/drum)
                      18 gage    20/18 gage    22 gage
New drum1             1583        1328          1008
Reconditioned drum2    152         151
1 Table I down to and including transport to filler

2 Table I, transport to reconditioner, reconditioning
  energy, and transport to filler

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                      TABLE III



       COMPARISON OF THE CUMULATIVE ENERGY REQUIRED

               FOR 100 MILLION FILLS OF

          REUSABLE AND SINGLE-USE STEEL DRUMS
             Reusable
   18 gage
  20/18 gage
 Single-use
   22 gage
56,489 bil. BTU    77,735 bil.  BTU
                    111,400 bil. BTU
(9 fills per
drumi 8 recon-
ditionings)
(4 fills per
drum; 3 recon-
ditionings)
(new drum for
 each fill)
ENERGY RATIO
          20/18 gage drum
            18 gage drum  =  *
22 gage drum
18 gage drum
                                 _ ? n
                              2U3

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require twice as much energy as an all 18 gage system.
A complete 20/18 gage system would require 40% more energy
than an all 18 gage system.
     Table III is based on a systems analysis in which all
flows of material on the flow chart have been estimated.
The equation and an explanation of the variables upon which
Table III is based are given in the Technical Appendix.
     Table III is based on the reconditioning industry's
conservative estimates of eight reconditionings per 18 gage
drum (9 fills) and three reconditionings per 20/18 gage
drum (4 fills).  Lighter weight drums which can be recondi-
tioned have an initial advantage over heavier drums until
the number of reconditionings of the heavier drum exceeds
that for the lighter drum. (Single-use drums are at a dis-
advantage after the first reconditioning of an 18 gage drum.)
Lighter weight drums are less durable and generally cannot
be reconditioned more than three times.  The 18 gage drums,
however, could be reconditioned up to 16 times with little
problem.  Any increase in the number of reconditionings will
lower the energy requirements of the steel drum system.
CONCLUSION
     The estimated energy requirements of the current mix of
reusable and single-use steel drums in the United States  is
73,532 billion BTU per year.  If the system were converted
to all 18 gage drums with an average of eight reconditionings
(9 fills per drum) an estimated 17,043 billion BTU per year

-------
could be saved.  This is enough to provide the equivalent

in electrical energy for a city the size of San Francisco

for one month.

     If the return rate of 18 gage drums vere increased so

that the average number of reconditionings was raised to

15 ( 16 fills per drum) then the United States could save

an estimated 29,707 billion BTU per year, the equivalent

of 238 million gallons of gasoline, by converting to an

all 18 gage drum system.  This would raise the ratio of

energy requirements of the 22 gage single-use drum to

energy required for the 18 gage (16 use) drum to 2.5.

     Clearly efforts to increase the use of 18 gage drums

and the rate of return of such drums(by such means as

deposits) would conserve energy.  Conversely, a trend to

use more light weight drums or to reduce the return rate

of drums would further burden American energy resources.
2 See Hannon,  op.  cit..  p.  23.

3 If no losses occurred  in the 18 gage system (no discards
  and no drum failures)  the ratio would reach a maximum of
  4.2.  This is because  as the number of reconditionings
  increases, the average energy approaches the reconditioning
  energy, since the energy required to manufacture the drum
  becomes a smaller and  smaller fraction af the cumulative
  energy used.  Mathematically, in equation A-4 of the Techn-
  ical Appendix the average energy for the 18 gage drum
  approaches a lower limit of 265.5 x 10  BTU per fill as
  the number of fills becomes infinite.  The average energy
  for the 22 gage drum is 1113.5 x 103 BTU per fill.
                               2u5

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                            References


1. Hannon, Bruce, "System Energy and Recycling! 4 Study of the Beverage
   Industry"^ Center for Advanced Computation)  university of Illinois,
   CAC1 Document No. 23, revised March 17, 1973.

2. U.Si Bureau of the Census, Census of Manufactures, 1967,  Special Series i
   Fuel and Electric Energy Consumed, MC67(S)-4.,  U.S. Government Printing
   Office, Washington, D.C., 1971.

3.. U.S. Department of Commerce, "U.S. Industrial  Outlook,  1974.,  Metal
   Shipping Drums and Pails".

4.. U.S. Bureau of the Census, Census of Transportation,  1967,  Vol.  Ill,
   Commodity Transportation Survey, Part 3, Commodity Groups,  U.S.  Govern-
   ment Printing Office, Washington, D.C., 1970.

5. U.S. Department of Commerce, "Current Industrial ReportsiSteel Shipping
   Drums and Pails, Summary for 1967", M34K(67)-13.

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                  APPENDIX  A






                Technical  Appendix










     The  system analysis  of the  steel  drum reconditioning



 system is based on the flowchart of  the system.   On the



 next page the  flowchart is   shown   with the energy



 variables of the system labelled.  These variables denote



 the amount of  energy required by a process,  such as EnD
                                                      LiX\


(the amount of  energy required to make  a drum)  or the



 amount of energy required for transportation,  such as



 EC™ r,n (  the energy required to  transport the  steel for a
  S 1 ,LJK


 drum from the  steel industry to  the  drum maker).   On the page



 following the  flowchart a symbol list  is given which defines



 each of the symbols appearing on the flowchart.





     The  total energy required to mine raw materials,



 make a new drum, fill it  and deliver it to the industrial

                 *

 user is called E  , and is  equal toi
       *


      E  =  EM  +  EM,ST  +  EST  *  EST,DR  +  EDR,ST  +  EDR




           E      -t-  E
           LDR,F +  LF,I
      Next,  an  equation is  derived',  based  on the  flowchart,



 which describes  the  total  energy  requirement for the



 complete  reconditioning system.   The  total  energy

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                        FLOWCHART
            STEEL DRUM RECONDITIONING SYSTEM
                                                           A-2
       RAW
    MATERIALS
         V.ST
      STEEL
     INDUSTRY
'DR.ST
       "ST
'ST.DR
       DRUM
      MAKER
       "DR
            S.F
      FILLER   |
  . -- ---
  |  INDUSTRIAL I
  ,     USE      |
 "I,SC
          'I.DI
                       RECOKT1ITIONER
         •   DISCARD
                                                          "SC.ST
                                                       •R,F
                                             JR,SC
                                                      "SC
                                          SCRAP
                                         DEALER
                                 klC-0

-------
     LIST OF SYMBOLS FOR FLOWCHART








          Energy Requirements






E.. = Mining of ores




EM ST = Transport of ore



EST = Manufacture of steel




Eom no = Transport of steel to drum manufacturer
 o 1 t UK


ED  = Manufacture of drums




En_ g_ = Transport of scrap from drum

   '     manufacturer to steel industry




EDR F = TransP°rt to filler



E_ _ = Transport of filled drums to industry
 r > 1


E_ _ = Transport of used drums to reconditioner
 i ,K


E.J. __ = Transport of used drums to discard




E_ „£ = Transport of used drums to scrap dealer



Eg = Reconditioning of drums



Eg p = Transport of reconditioned drums to filler



Eg gj, = Transport of reconditioned drums to

  '     scrap dealer (equal to ET cn)
                                JL i OU


ES  = Scrap yard




ESC ST = Transport of scrap to steel industry

-------
requirement, E, is expressed in terms of N, the number



of reconditionings of a drum.  By changing the value of



N in the equation, one can calculate the energy requirement



for any number of reconditionings.



     The general equation for the energy requirement for



N reconditionings  (N + 1 fills) ist
E = E* + N   f^E^sc + Esc + ESC>ST) + f,, EI§DI +






    f   E    + E  + f  (E    + E> + f  (E
           3  EI.R + ER + f4  ER,F + EF.1  + f5  ER,SC *    (A-2)
    ESC + ESC
                   >STj]   +  (1 - f3 f4) A
where
     f^ = fraction of drums from industrial user to scrap




     f2 =      • .....     "      "       "    " discard




     f3 =      ......     "      "       "    " reconditionci





 ( Note that these fractions must sum to onei f. + f- + f, = 1)




      f. = fraction of drums from reconditioner to filler




      f  _     ..    .,    ..     ..         ..      ..  scrap
Numerical values for these fractions are given on the following




page.  The values  for the energy variables  are given in Table I




 of the report.

-------
Numerical values for the fractions f. i
             1 fl GAGE _         20/1 B GAGE
             1.03 N/(N+1)         1.05
   f4        0.97                 0.95
   f5        0.03                 0.05

 Note:  f3 is determined from £3^4. which is the return
        rate for the reconditioning loop, equal to
        1 - 1/(N+1) = N/(N+1).
     While expressions for the fractions f. and f_
( the fractions of the drums from the industrial user
which go to scrap and discard)  can  be determined, the
terms in Eqn. (A-2) in which they appear have very small
coefficients.  These negligibly small terms are ignored
in obtaining the simplified equations which appear later
in the appendix.
     Assuming f  and f  are equal, expressions for them
arei  f. = f^ =   j I N "i \     for *"ne ^ 9a9e drum, and
fj = f2 =  127N°'^5N   for the 20/18 gage drum.

-------
Once the total energy requirement E for a given number

of reconditionings N is calculated for a given weight

drum, the average energy requirement per fill can be

calculated by dividing E by the number of fills, N+l.

This average energy per fill, Eav , is the number which

decreases as the number of reconditionings of a drum

increases.  The total energy used, E, increases each

 reconditioning,  but less than for new drums.
av
                   / (N+l)    =  average  energy  per  drum
                               per  fill.
      The magnitudes of the energy variables in the energy

 equation are given in Table I as followsi  (in 1000 BTU's
                 18 gage
*
E
IT j. T?
E1,SC + ES



1692.1
4
f 8.2
\
                                            per drum)
                       20/18 gage
                                   1434.8
                                      7.0
EI,DI
EI,R
ER,F
U O j"^
£\ f
-------
SIMPLIFIED  EQUATIONS  for  the  cumulative energy per drum



 (E)  for an  arbitrary  number of reconditioning^. (N)t





Equation   (A-2)  , after substitution of the values of



the  energy  variables, can be  simplified.  Some of the  terms



in the equation  are negligibly small and can be  ignored.




The  simplified equations  are  as followsi
 18 GAGE DRUM





         E
= 11692.1 (2N+1) + 265.5 N2J/ (N+l)       (A-4)
20/18 GAGE DRUM   (maximum of 3 reconditionings)






      for N^3  :    E =  [l434.8  (2N+1) + 266.0 N2J/  (N+l)     (A-5)





       3
-------
                           COMPUTER PROGRAM

              A small computer program was written to  calculate

         the cumulative and average energy requirements  per  drum

         for the reconditioning system. A listing of the program

         appears below.
       DIMENSION E(50)
      NR-0
      NO4
CC     NC IS THE MAX. NO*  OF FILLS FOR 20/18 DRUM.
      KMOD-0
      DO 100 K-1,16
      NF-NR+1
      NZ-NF+NR
      NSQ»NR»NR
      E18»(1692.1*NZ*265.5«NSQ>/NF
      E22-1113.5*NF
      AV18-E18/NF
      IF  GO TO 10
      E2018»<1434.8»NZ+266.»NSQ>/NF
      AV20-E201S/NF
      E(NF)-E2018
      GO TO 99
  10  IF  KMOD-KMOD+1
      E2018-E(KMOD*NC)+E(NF-KMOD»NC)
      E»E2018
      AV20-E2018/NF
  99  VRITE(6«98i NF>NR«E22*E20I8*E18*AV20*AV18
  98  FORMAT(1X,2I5«5F11.1>
  100 NR-NR+1
  97  STOP
      END
         On the following page a list of symbols and their

         explanation is given.  The equations programmed are the

         simplified equations from the preceding page.

-------
             COMPUTER PROGRAM SYMBOLS







MR x number of reconditionings



NC = maximum number of fills for the 20/18 gage drum.



NF = number of fills



El8 = Cumulative energy requirement in 1000 BTU's per



      drum for 18 gage drum



E2018 = Cumulative energy requirement for 20/18 gage drum



E22 = Cumulative energy requirement for 22 gage drum



AVI8 = average energy per drum per fill for 18 gage drum



AV20 = average energy per drum per fill for 20/18 gage drum

-------
                    TABLE A-l

              OUTPUT OF COMPUTER PROGRAM
CO
H
§
H
-H
*w

*W
O

^
01


z
1
2
3
4
5
6
7
8
9
10
11
12
13
14
01
H1
•H
fl
0

0 *J

i-i *O
Q) C
£ O
§ a!
Z U

0
1
2
3
4
5
6
7
8
9
10
11
12
13
i-i g
SB
01 tJ

01 0>
> 01
•H 10
4J Oi
10
•-I (N
3 oo
                  •H iH
                  10 O
                  >-t (N
                  3
                 1434.8
                 2285.2
                 2746.0
                 3109.4
                 4544.2
                 5394.6
                 5855.4
                 6218.8
                 7653.6
                 8504.0
                 8964.8
                 9328.2
                10763.0
                11613.4
 Q) TI

 01 01
   W
 0) 10
 > Oi
 •H
 jj 00
 10 <-<
                             O
1692.1
2670.9
3174.2
3558.5
3895.4
4208.4
4507.9
4798.9
5084.2
5365*5
5644.0
5920.3
6195.0
6468.3
   m
   Oi
   00
   r-l
 H\
 01 O
 P. CM

 6! H
 M H
 01 -H
 C «u
 0)
   M
 01 01
 & a
 (0
             > ^
             < TI
1434.8
1142.6
 915.3
 777.3
 908.8
 899.1
 836.5
 777.3
 850.4
 850.4
 815.0
 777.3
 827.9
 829.5
                                                      01
                                                      01
                                                      &
                                                    U
                                                    01 CO
                                                    Q..H
 01 -H
 C >M
 01
  U
 0) 01
 01 a
 10
 >-i i
 0) 3
 > M
1692.1
1335.4
1058. 1
 889.6
 779. 1
 701.4
 644.0
 599.9
 564.9
 536.6
 513. 1
 493.4
 476.5
 462.0
Notei The average  energy per drum per  fill for the 22 gage
      drum  is  1113.5 regardless~Bf~ttte value of N.
      ALL NUMBERS  SHOWN ARE IN UNITS  OF  1000 BTU's per drum.

-------
                                                                            D
Modification of Trussing Energy Study
VHfS, SIC Group 5085  inRet  Pesticide containers over 15 gallon capacity
Modified flowcharts for direct flow without loss offset


Reconditioning Flow
El-r  to  EH  to  ER-f  to  EF-i  and repeat


CODEi                                              BTU/drums
El-r    Transport of used drums to reconditloner        1»850
ER-f    Transport of reconditioned drums to filler      2,300
ER      Reconditioning of drums                       1^7,600
EF-1    Transport of filled drums to industry         106,830
HJ-r    Cumulative Enerrv in reconditioning flow      254-.830
Formulai

El-r + ER + ER-f + EF-i = E3-r
STOP
End

-------
New Drum Manufacturing Flow

E-e to E-mST to E-st to EST-dr to E-dr to EDR-f to EF-i

CCDEt                                                  BTU/drum

E-e      Mining of ores                                82,700
E-mST    Transport of ores                             22,300
E-st     Manufacture of Steel -                       1,092,500
EST-dr   Transport of steel to drum manufacturer          9,000
E-dr     Manufacture of drums                          113,000
EDR-f- •  Transport to filler                             6,000
EF-i     Transport of filled drums  to Industry          106,000

BCDR Cumulative Energy in New Drum  Manufacturing      1.^32,330
Formula i
E-m + E-mST + E-st + EST-dr + E-dr  + EDR-f  + EF-i =  EODR
STOP
End
                                         218

-------
 Ore mining flow

 E-ffl to K-ttST
 CODE t
 E-m
 E-mST
-BC-o

 Formulai
Mining of ore
Transport of ores
Cumulative energy to mine and transport
  BTU/drum
  82,700
  22,300
105,000
 E-m + E-mST •= EC-o

 STOP
 End
                                             219

-------
Proposed resource recovery flow






ECDR to E-hs to El-r to EH-d to EB-so to ECS-st






CODEi                                                            BTU/drum






ECDR      New drum manufacturing to filler to industry           1,^32,330






E-hs      Transport to holding site                                  1,700






El-r      Transport to recondltioner                                 1,850






ER-d      Reconditioner decontamination                             80,000






ER-DC     Transport from reconditioner to scrap dealer               1,000






ESC-st    Transport to steel industry                                5,000






B3-o      Cumulative mining / transport energy                    105,000






IK-rr     Cumulative energy for resource recovery                1,416,880





Formula






ECDR + E-hs + El-r -t ER-d + ER-sc + ESC-st + EC-o = EC-rr





STOP






End
                                           220

-------
               MR. LEHMAN:  Thank you, Mr. Moore.  Will



you entertain some questions?




               MR. MOORE:  I shall be glad to.



               MR. LEHMAN:  Mr. Kovalick?



               MR. KOVALICK:   I take it it is largely



economic and not technical reasons that there isn't more



drum reconditioning going on in the country as a whole,



versus California specifically?




               MR. MOORE:  If you mean in the toxic and



pesticides, with reference to toxic and pesticides con-



tainers I would say so.   There was a study we had that



showed that of over 2,000 farmers who were interviewed by

-------
the Department of Agriculture In 1972, over 50# of them



said that they would be willing to cooperate with a



regional recovery spot, but it is a query how far a farmer



would take his drum, I mean these are feasibility study



programs that we are not capable of answering.   But, I



would say that In answer to your question specifically,



yes, the average drum reconditioner Is not capable of go-



Ing to the expense of talcing these containers in with a



detriment, with the residue they have and meeting the



economic needs, the economic price of the market for the



normal reconditioned drum.



               MR. KOVALICK:  What would be the alterna-



tive then, if he can't, do you have a recommendation or



is that Dr. Hoofer's?



               MR. MOORE:   No, I think Dr.  Hooper addres-



ses himself more to this technically, I address myself to



it as a layman.    It seems to me that the industry is



there, the industry is made up of a group of responsible



businessmen, they do have the facilities, they do have



the incinerators but they get In thousands and thousands



of drums each day from normal use and they have no way to



deal with these special pesticide drums.   They can't in



the economic picture handle the pesticide drum, though it



would seem to me there would have to be some thought given



by the government and by you gentlemen to a proper way to

-------
  invigorate  and  to  use  an existing  industry which stands



  waiting  your  call  to do  anything and the two together, with




  imagination devise a system whereby an  industry  that  is



  capable  of  handling it but  finds a;very special  problem




  which  it can't  economically handle, find somethina  to solv



  that situation,  also to  save  the steel  and keep  these



  drums  in use.



                 MR.  LEHMAN:  Before we go on with the



  questions,  Mr.  Moore referred to a brochure with photo-



  graphs of steel drumscand I think it only  fair that we



  put that in the record to show what he  referred  to, so



  we will  do  that.   We do  have  other questions.  Mr.  Sanjour



                 MR.  SANJOUR:   You seem  to  be advocating



  some sort of  Federal initiative. Could  you be more  speci-



  fic as to if  that  is the case.



                 MR.  MOORE:   Well, there  do  exist  these



approximately 6 million drums that are filled with pesti-



  cides  each  year and out  of  tnis 6 million,  only  3$  are



  treated  in  any way  so  that  they can enter  into our  nor-



  mal commerce  again  as  do other drums by the normal  pro-



  cess of  reconditioning.   Yet  the facilities do exist  in



  the reconditioning  plants to  handle these  drums  under



  certain  regulations as to the  safety, the way in  which they



  could  be  tiandled, the  facilities that the  company would



  have to have, so that  these drums instead  of being  taken

-------
  to  a  landfill which probably isn't adequate  or left  on




  the countryside,  could become part of  the normal recondi-




  tioning industry.   I think it  does require,  I don't say




 Fe_deral legislation, I think it requires Federal  initia-




  tive  to help devise a system by which  the  industry can




  use its facility  to the  fullest extent to  reach  this goalo




                 I  don't think the industry, we do have, we




  are an industry that has an environmental  committee  and




  works hard  on its  own environmental problems.   I don't




think  it is  an issue that the industry  by itself  can  solve,,




                 MR. LEHMAN:  We  have another  question, Mr.



  Lindsey?




                 MR. LINDSEY:   Yes, a question from the




  floor<>  Do  drum reconditloners  have facilities to scrub




  noxious gases from heat  treating of drums?   More general-



  ly, has your organization put together any guidance  on




  incineration of drums and how it should be carried out?




                 MR. MOORE:  We have just begun to. We



  have  had one meeting, we will have another meeting in




  January.    Yes, I  must put a comment on it that  I'm  essen-




  tially an attorney and not a technician and  Mr.  Hooper




  will  address himself to  this later, but yes,  the industry




  does  have the capacity through  rinse and drain procedures



  to  clean these  drums so  that they can  be used in the nor-




  mal application.

-------
               MR. LINDSEY:  I think maybe you misunder-




stood the question.  They were asking, I tnink, specifical-




ly, are there pollution control facilities on the inciner-




ator itself?




               MR. MOORE:  Yes,  afterburners and pollu-



tion control facilities.




               MR. LEHMAN:  Mr. DeBonis?




               MR. DeBONIS:   Yes, reference was made to




your mention of 100 million tons of steel being lost to




landfills, according to the CEQ report, the question is




how much of that total represents steel and barrel drum




containers?   As opposed to, I suppose beer cans and other




types of things that will come up as steel and solid waste




               MR. MOORE:  It is my understanding from




the information given to me that that speaks only to the




steel drum,, the amount that is lost to the landfill




through the steel drum containers that contain more than



15 gallons, that's all I was speaking of.   That figure



relates to those drums that contain more than 15 gallons.




               MR. DeBONlS:   I think to clarify this, I



think the context, now that I read it more clearly, is




not that 100 million tons of steel a year go to a land-




fill but that for every 100 million tons, 1.5 million




barrels or oil is saved, so ib is just an energy equiva-




lent.

-------
               MR. LEHMAN:  Mr. Lindsey?




               MR. LINDSEY:  Another question from the




floor.  What is done with rinse solutions from the empty




containers?




               MR. MOORE:  I'm not sure about this.  I




know that they,are all disposed of according to legal




procedures within the areas in which that company oper-




ates.   And we have, our industry has always had an enor-




mous solid waste problem because even in a non-toxic or




non-pesticide area the1  first user frequently leaves as




much as a gallon of .   some substance in the drum and




the average drum reconditioner has been faced year in and




year out with a solid waste disposal program that he's




had to meet successfully to meet his local standards.




And, the question of the toxic materials is simply an



added version that he has to handle locally.




               MR. LINDSEY:  It would be helpful to us,




I think, if you could perhaps later on enlighten us on




how that is accomplished.




               MR. MOORE:  I'm sure the Association would




like to do it.




               MR. LINDSEY:  We would appreciate it.




               MR. MOORE:  They would be very happy to




play a real role in developing any rules or regulations




that we can work up.




                         22G

-------
               MR. NEWTON:  There is one more question




from the floor as to whether or not you consider a pesti-




cide container different from any other type of drum that




contains chemicals?




               MR. MOORE:   Yes, I think there are, I'm




sure there are Federal regulations that presently pesti-




cide containers cannot be reused except under very limited




circumstances and have to be discarded, so they are



special treatment.  The industry accords them special




treatment. Ninety seven% of them don't even rsach t.hf* rf»oor\rHtion-



ing industry, so it is only 3$ of them out of the 6




million, only 180,000 that ever really tangentially reach




my industry, which really could handle 100$ of it.




               MR. LEHMAN:  Thank you very much, Mr.




Moore.  Our next speaker, I believe she is here now, is




Diane Graves, Sierra Club, Princeton, New Jersey.  Miss




Graves, please.



               MISS GRAVES:  Thank you for the opportuni-




ty to comment on the scope and nature of the hazardous



and toxic management problem.  My name is Diane Graves



and I'm Conservation Chairman for the New Jersey Chapter



of the Sierra Club.   Today I'm speaking for the national




Sierra Club as well as the Chapter.




               The policy of the Sierra Club is that the





release of any environmentally hazardous substance into




                         227

-------
the environment should be prohibited unless the immedi-



ate environmental and safety benefits clearly outweigh



the      long-term environmental damages.



               It is urgent that EPA focus  on problems



caused by hazardous and toxic substances at the earliest



possible stage.  Chemicals must be tested for health



effects prior to marketing.  Once a chemical is marketed,



the investment"in money, time and jobs is  enormous.




Thus it becomes far more difficult to prohibit or even



to regulate the chemical's use.



               There needs to be stringent regulations




during the development, production and the use of these



substances.   There need  to be regulations for storage



and transport.  Disposal of the product and its wastes



must be regulated with the greatest care.    Though some



manufacturers act responsibly and see that their wastes



are disposed of properly, most do not.  We know that li-



quid chemical wastes are dumped in fields  and woodlands in



New Jersey.  One chemical company's waste was dumped at



a farm, the waste found its way into 180 household wells



that had to be sealed and city water brought in at home-



owners expense.



               In February, 1975, the National Cancer



Institute estimated that from 6o# to 90$ of all human




cancers are caused by environmental factors.  In July,





                         228

-------
1975* the NCI released maps showing New Jersey has re-




corded one of the highest rates of cancer-related deaths




in the nation.  In early November, 1975, the National




Center for Health Statistics reported that the cancer




death rate for Americans so far this year increased 5.2$




over the same period of last year.




               Canaries used to.,be taken into mines.




When the canaries sickened  and died, miners were alert to




danger and left the mine.  We've been given warnings for




a long time and we have done little more than give the




problem our attention.  The cancer statistics indicate




that we are the canaries.  We must not delay any longer.




               An example of how ignoring the need to




clean up continuous serious hazards is the PCB experience.




Polychlorinated biphenyls (PCB's) provide a typical and




continuing tale of environmental misfortune and irrespon-




sibility.  The industrial history of PCB's has been well



documented.  PCB's were first manufactured in 1929.  By




1933,, 23 of the 24 men working in the first U.S. PCB



manufacturing plant suffered from chloracne.  Further,




PCB's were carried home on workers clothing causing fre-




quent chloracne among wives and children.




               PCB's seriously affect liver function, as




well.




               By the mid-1940's it was well established

-------
from workers'experiences that PCB's were toxic and needed




to be controlled.  The warning was ignored for 20 years




until it was recognized as an environmental hazard.  The




general public first learned about the problem in 1970.




Had industry heeded the 19^3 warning to avoid human ex-




posure to PCB's, we could have avoided the 1972 estimated




1,500 to 2,000 tons of PCB's per year "lost" to the air,



4,000 to 5>000 tons per year to fresh and coastal waters,




and 18,000 tons per year to dumps and landfills.  The




continuing PCS experience gives us an urgent warning and




it should prompt strong action at last.




               "Environmental Determinants of Human




Cancer," a paper in the Oct. 197^ Cancer Research publi-




cation states, "The economic impact of cancer is massive.



The direct costs of hospitalization and medical care for



cancer in 1969 exceeded $500 million.  The direct and




indirect costs of cancer, including loss of earnings




during illness and during the balance of normal life ex-



pectancy, were estimated at a total of $15 billion for




1971....On purely economic grounds, it is clear that con-




trol or further limitation in the overall burden of en-




vironmental and occupational chemical carcinogens, with




anticipated major reductions in the incidence of human




cancer, is likely to achieve very significant reductions




in total national costs from cancer.

-------
                These considerations are not appropriately
 reflected in allocation of Federal priorities and re-
 sources for prevention, in contrast with the diagnosis
 and treatment, of human cancer...Since World War II,
 there has been an exponential and largely unregulated
 increase in the numbers and quantities of synthetic or-
 ganic chemicals manufactured and  used in industrial coun-
 tries.  The claimed needs to use  increasing numbers of
 new s5Tithetic chemicals make it essential to recognize and
 critically evaluate carcinogenic  and other human and
 environmental hazards with regard to the real or alleged
 matching benefits that they confer.
                Such costing must  be weighted by factors
 including the persistence and environmental mobility of
 the chemical, the size of the population exposed,  and
 the reversibility of the adverse  effect....there are
 clear economic, besides other,  incentives to reduce the
 environmental and occupational  burden of chemical  carcino-
 gens. . •.Inherent in the toxioological and regulatory
philosophy and practice is lip service to the concept  of
 balancing benefit against risk; this implies benefit  to
 the public and not to industry, and risk to public health
 or  environmental integrity and  not economic risk to in-
 dustry.   If the chemical in question does not serve a
 broad  socially and economically useful  purpose  for the
                            231

-------
general population, why introduce it and force the public-




at-large to accept potential hazards without general




matching benefits?




               There are approximately 6,000 new compounds




used in industry processes and commercial products made




each year.  There is little or no testing, and no legisla-




tion to control inclusion of these in non-food and non-




pesticide products before they are widely distributed




and used.  About 100 of the 6,000 substances are hazardous




toxic.



               In considering the costs of pre-market




testing and regulation to the chemical industry, the




balancing factor must be the cost to society of not do-




ing so.




               Now  that we know that most human cancer



is caused by environmental factors, we should be able




to prevent a great deal of human cancer by finding and




removing chemical carcinogens from the environment.  We




should be more careful of exposing the human population




to chemical carcinogens than we are to radiation, as




chemical carcinogens are probably a greater hazard.




               There is clear need for effective hazar-




dous and toxic substances control legislation.  The




Sierra Club generally supports So776 and we urge that EPA




move  swiftly to promulgate rules and regulations upon
or

-------
its passage.



               Both legal and financial responsibility



for hazardous and toxic waste treatment and disposal rests



squarely on the producer of the product.  The manufactur-



ers must be accountable to the public through EPA.  The



agency should issue operating permits subject to periodi-



cal review.  Piling of lists of hazardous and toxic wastes



generated and the procedures for treating and disposing of



must be mandatory.  There must be built in enforcement.



               Whether disposal is on-site or contracted,



out, the safest method must be required.  EPA must have



tough standards, and enforcement authorization and capa-




bility.



               If hazardous waste is contracted for dis-



posal, the manufacturer must report what was collected,



the amount, how and where transported and what treat-



ment process is required.  The entire disposal process



must be monitored.  Waste processors must be financially



responsible for the waste collected and have sufficient



money to complete proper processing in case of going out



of business.



               Again,  from the Cancer Research paper,




"Responsibility for these constraints must be shared with



regulatory agencies,  by the legislature, by _the scienti-



fic community,  and by consumers and citizens,  who have





                        233
it

-------
not yet developed adequate mechanisms for protecting
their own vital rights and interests...Decisions on the
use of carcinogenic chemicals in consumer products and in
the workplace must be made in the open political arena on the
basis of economically unconstrained and expert advice."
               Thank you.
               MR. LEHMAN:  Thank you, Miss Graves.
Will you accept questions?
               MISS GRAVES:  Yes.
               MR. LEHMAN:  Do we have any questions from
the panel?   We have one or two here from the floor.
Mr. Kovalick.
               MR. KOVALIGK:  Prom the floor.  You have
stated that most manufacturers do not properly treat
their wastes, what is the basis for this?   Have you any
statistics, etc.?
               PESS GRAVES:  I don't have any statistics
but I think it has been generally recognized, certainly
in New Jersey, that it is a severe problem.  There aren't
facilities to deal with these wastes.  I know for a
fact that tank trucks have pulled into a field and dumped
it, it's been found out and so forth, the wastes were un-
treated.  This Is not an uncommon experience.   We are
very concerned in New Jersey about the Pine Baron's
Region which is in South Jersey and there is a huge aquifelr

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under the Pine Baron's.  Here again, it is known that




tank trucks go down there and dump it, it is a sandy soil



and noDody knows what happens to it.  Whether people have



been caught doing this, people are reluctant to report



such things, we found, for a variety of reasons.   I



imagine there are some statistics on it, but I don't have




them.



               MR. LEHMAN:  Mr. Lindsey?



               MR. LINDSEY:  Yes, question from the floor.



The statement says, cancer from environmental factors



have increased from 70$ this morning to 90$ this afternoon.



Apparently they are referring to some statistics that were



quoted this morning.   In any case, in either event, what



fraction of this is due to industrial waste disposal?



               MISS GRAVED:  That's probably impossible to



figure out.  As far as the 60 to 90$ figure, that has been



in a nuraoer of publications recently, including the one



that I referred to in my paper.   There are so many small



and big and intermediate insults all the time,  it is prac-



tically impossible to sort it out.   We know that land-



fill operators, it is obviously a hazardous occupation



and in South Jersey there is the example of what happened



last year when a bulldozer evidently crushed or whatever



some kind of drum and it exploded and engulfed the bull-



dozer in flames and the man was killed.   As far as




                         235

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figuring out just what the percentage is from landfill



versus being dumped indiscriminately, I don't have the



statistics on it.



               MR. LEHMAN:  Another question?



               MR. KQJDSEY:   Prom the floor.  What would



you suggest that Federal EPA do or the state of New Jersey



do to implement control of disposal?



               MISS GRAVES:  I think it has to come from



the Federal government initially.  New Jersey does have



some proposed rules for hazardous and toxic wastes and



regulations, they are proposed.  In the meantime, there




are no regulations for these substances.



               MR. LEHMAN: I have a question.  Your state-




ment indicated that the waste processors "iu
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properly taking care of it.



               MR. LEHMAN:  Do we have any other questions'



No.  Thank you very much, Miss Graves.



               Our next speaker is scheduled to be Mr.



Cushman from Plymouth State College, is he here?  No.



All right, we'll move on then.  Mr. Clarence H. Roy



representing the American Electroplaters Society.  Is Mr.




Roy here?



               MR. ROY:  Ladies and gentlemen, I do not



have a prepared statement.   I would simply like to make



a few comments that are relative to the problems of hazar-



dous wastes as they pertain to the metal finishing industry.



               Many of the earlier speakers this morning



were advocating self-serving and stringent  legislation.



I feel that the legislation should be objective and rela-



tive to improving or protecting the environmental quali-



ty rather than reacting or over-reacting in an emotional



atmosphere.



               Specifically with respect to the electro-



platers, we are concerned with the toxic materials that



are contained in the sludge which is produced as a conse-



quence of treating the environmental problems involving



water pollution and air pollution.



               Presently landfilling is essential to the



Industrial water pollution control program and cannot be




                       237

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abruptly discontinued.




               In Qonnecticut we endured an experience



about two years ago wherein these residues were banned



from all municipal landfill sites, sanitary landfill sites



At the end of the year the problem was monumental.  Some



of the larger industries, quite literally, had warehouses



of sludge.  The larger industries were using lime to neu-



tralize their acidic residue and as a consequence had a



very voluminous and bulky residue.



               At the end of the year, the authorities



were changed around and eventually landfilling was begun



In Connecticut.   However, it was done under the super-



vision of the Water Compliance Unit of the Department of



Environmental Protection and certain landfills, those



which had a detrimental impact either due to leachate or



poor site selection, were not Included in the metallurgi-



cal waste dumping that was allowed in the state.



               I'm on the Governor's committee in Connec-



ticut and we dealt with a problem that was brought up this



morning, which I call hindsight technology, with respect



to toxicity.   I think everyone is afraid of another



Thalidomyde episode and perhaps rightly so, and the



matter of retrieval of solid waste from a sanitary land-



fill is a very difficult problem and it should be studied



and addressed in greater detail.  We came up with a couple

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of observations  on how  these kinds of ^things may be accom-




plished.  One was to  fill the landfill  in a  vector  or  a




vein  in order that if in hindsight we find that these  ma-




terials that have been  buried are detrimental to the en-




vironment that they can be retrieved by a backhoe or




clam  shell technique,  rather than have them disperse




helter skelter through  the landfill.




               The other alternative that was considered,




it*6.s not particularly  acceptable, was  the so-called pea-




nut butter technique, wherein these wastes would be spread




upon the top of  the landfill and overfilled  with a  single




layer of fill or soil,  so that if at a  later date they




were found to be toxic, they could be removed with  a bull-




dozer.   Of course, you would also have to have legisla-




tion that would  prohibit, overfilling this last top  layer.




So this would prohibit  using that landfill site perpetual-




ly thereafter once it had been covered  with  a top fill




of toxic material.



               Some of  the speakers this morning were  ad-



dressing themselves to  the potentialities of recycling.




This is increasing in many areas, including  the reuse  of



so-called metallurgical sludges, those  that  contain metals




of some value, are obviously targets for reclaiming or re-




cycling.    But,  needless to say, economics will determine




this outcome,  and some of the metals will probably never

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economically justify recovery, within, like the gentleman




this morning was saying, 40 years before this technology




and the economics will catch up with the problem.




               We have done some small amount of work




with determining leachate burden, but I feel that it would




be beneficial to know how significant the leachate burden,




particularly with respect to metals and more importantly




heavy metals, how relevant and how serious are these lea-




chates from dumps that are in existence today, particular-




ly those that are well run.




               So that in the formulation of your laws




you will have some criteria that are based on say well




operated landfill sites.




               I would suggest further that the matter of



filling landlills or operational formats based upon the



data and experience that we gathered from studying proper



landfilling techniques with respect to metal bearing ma-




terials, would undoubtedly produce better landfills than




we have today.



               We have in the Electroplaters Society a




number of small electroplaters who will almost forever




have this mfetal sludge burden on a scale such that it




will always present an exorbitant cost relative to the




size of the corporation and it will be difficult for




these people to follow an elegant sludge disposition

-------
program such as the one outlined this morning that Chemfix




or some such technique as that.   And this may well recom-




mend itself to other people's comments concerning region-




al disposition sites for specific toxic materials, in




this case particularly metallurgical sludges and wastes,




and I think at this point that would constitute the com-




pletion of my comments.




               MR. LEHMAN:  All right, thank you, Mr. Roy.




will you accept questions?




               MR. ROY:  Yes.



               MR. LEHMAN:   Mr. Sanjour?




               MR. SANJOUR:  Does the technology exist




to treat electroplating waste waters without generating




large amounts of sludge that have to be land disposed?




               MR. ROY:  The answer to that would be yes




and no.   Specifically I think you are thinking or things




like reverse osmosis,  Hon  exchanqe,  tnose techniques



wherein the metals can be reclaimed rather than discharged




to a waste stream, wherein they would then be subject to




precipitative technology which would produce the sludge.




Here again you include the Gordian knot type of situation




where if the economics justify the reclamation, then re-




clamation is the way to proceed.   Unfortunately, with




the smaller conpanies the consumption figures are not




sufficient to justify the investment in the reclamation

-------
technology, but rather to go through the, what might be




termed today the best practical control technology, which



would be precipitative technology, which would be the



sludge generating mechanism.




               MR. LEHMAN:  Mr. Kovalick?



               MR. KOVALICK:  Mr. Roy, if I heard your




comments correctly, you indicated that because it is an




economic burden for a small electroplater to dispose of




his sludges in an elegant way, I think you used the term,




therefore you thought that regional facilities were a




good idea, if I can paraphrase.    And, I guess I don't




understand why that is a lower cost option unless that




service is free, which has some implications.  I would




like you to talk about that.   Either he is going to pay




to do it himself, which you say is a burden, or he is



going to pay someone else to do it, unless you are imply-



ing that someone like a government is going to operate




that facility.  I didn't connect all that logic together.



               MR. ROY:  I understand, these were  just  sort




of a group or comments, they might not have been quite as




well organized as if I had this talk prepared.  But, I




wanted to touch on the point that the technology is avail-




able and perhaps in a communal sense, say the person has




a very small amount of copper bearing sludge, which we
know is toxic to some fish, if in turn it became solubiliz
sd

-------
which  is  one  of  the questions  that I was trying  to pose




in the landfill  problem,  is that, does the metal leach out




does the  hydroxide redissolve  and does it dissolve very




rapidly.




               Now, let's  suppose the small plater has




this residue  copper in this case.  This is a valuable me-




tal, but  the  volume he is  generating, it is hardly worth




the effort, do you understand?  So, I was thinking if



these  small contributors  could in some way get their ma-




terial consolidated, so that the recipient could, in this




case reclaim  the metal at  a profit, we might have the



Jack Spratt Affair, as it  were, where one man's  meat would




be another man's poison and vice versa.   In this case,




the copper is certainly easier to get out of the  sludge




than it is to get out of the ground.   And his problem



is mainly in  the dimensions, if he has, say, one  drum of




this material, he certainly is not going to go into the




reclamation business, whereas if he could have his drum




contributed along with others, there might be sufficient




volume to justify this.




               And, there are some companies springing up




around the country that are working this way, to reclaim




some metals.  Unfortunately, the economics have to be




there.   It has to be a metal that is worthwhile eclaiming




and worthwhile transporting some reasonable distance to a

-------
central reclamation center.




               MR. LEHMAN:  Do we have any other ques-




tions?  No questions.  All right, thank you very much,




Mr. Roy.



               At this time I would like to move into




what was to be our next group of speakers, I hope some of




them are here.   I would like to call on Capt. Hugh




McCabe from the New York City Fire Department or his alter




nate.  Mr. McCabe.




               MR. McCABE: My name is Hugh M. McCabe,




I'm Captain, Division of Pire Prevention, New York City




Fire Department.  I thank the committee for this oppor-




tunity to present our comments in relation to solid waste



disposal.




               If we can discard waste paper, cardboard,




wood shavings and the like, in New York City, there is




little fire or emergency experience with hazardous waste



generated from industrial processes.   There is, however,




a need for information and direction and regulation rela-




tive to hazardousmste disposal management.




               The generation of hazardous waste, either




flammable, explosive toxics, corrosive or radioactive



introduces many problems.    Human life and property can




be endangered and fire and explosions may occur if dis-



posal operations are not  properly planned and executed.

-------
               Disposal should be conducted in a controlled
manner that prevents hazards to the public's safety.

Safe disposal depends on knowledge of the waste material
characteristics and the various metnods of safe packaging,
transportation and disposal.
               The New York Pire Department, and I am
sure many other fire department? throughout the country
experience a few problems involving hazardous wastes.
Our experience generally lies within the area of chemicals
These experiences involve laboratories seeking assistance
with disposal of old or unused chemicals.   We have vaca-
ted premises wherein chemicals have been abandoned and
left; amateurs, hobbyists, etc., also seek our assistance
in the disposal of hazardous material.

               In most cases, the quantities are small.
If the generator is in possession of the material, the
services of a chemical waste disposal company is recommen-
ded.  However, there are a limited number of such companies
in the City of New York.
               If the material is not in the possession
of the generator, it becomes our problem for disposal.
Problems arise relative to such things as bombs, other
explosives and various chemicals.  In relation to bombs
and/or explosives,  the New York City Police Department
Bomb Squad and the  Blasting Inspecting Unit of the New York

-------
Fire Department arrange for the safeguarding of the materi
al of removal, transportation and final destruction in a
safe location.
               We are involved sometimes with soil contami
nated with volatile _infl.ainmable liquids resulting from
leaks from tanks which also present disposal problems.
There are oil spills on land and water.  All these prob-
lems are field problems and our emergency force must cope
with each depending upon the waste material and the sur-
rounding life.and/or property involved.
               Personal training, experience, expertise
and reliance on information contained in chemical diction-
aries, hazardous materials dictionaries, and standards and
texts of such  agencies  as  the  National  Fire  Protection
Association, Compressed Gas Association and some Federal
and private publications, provide the hope for safe re-
solvement of each problem presented.
               We have been fortunate in that the incident
have been infrequent and quantities of the material have
been small, characteristics have been known and safe dis-
posal has been accomplished.
               As indicated in the notice announcing this
hearing, Federal, state and local regulations dealing
with the treatment and disposal of hazardous waste are
spottjr  or  non-existent.     We  are pleased  that  the  problen

-------
has been recognized at  the national level and will look for-



ward to a hopefully realistically, reasonable and economical



ly feasible legislation or regulations, and to this end,



offer within our capabilities, any information and assis-



tance that may prove of value to the committee.



               This concludes our presentation and again



we thank you for the opportunity to be heard at this meet-



ing.



               MR. LEHMAN:  Thank you. Captain McCabe.



Do you have any questions?  Will you accept questions?



               CAPT. McCABE:    Certainly.



               MR. LEHMAN:  Are there any questions?  Mr.



Kovalick?



               MR. KOVALICK:  I think just for the record



it would be interesting if you could tell us a couple of



the contaminated soils or other problems that you have had?



               CAPT. McCABE:   In relation to soils, we



have gasoline tanks, other type tanks buried below ground -



gasoline stations, paint manufacturing plants and the



like.    Prom time to time these are tested, but in the



interim period because of corrosion or whatever, they de-



velop leaks.   The next thing we hear, there is a complaint



and an emergency call for gasoline fumes in the subway,



gasoline fumes in the cellars or thehouses or whatever.  It



is our reaction then to take necessary action to safeguard




                        21*7

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lives and property.   In this respect we would evacuate




if necessary.  We would evacuate the properties and so




forth.




               Now, we then run tests on these particular




installations.  If they withstand the pressure test, we




know that an installation is okay, we go beyond, we




start trying to find out where the leak originates.  When




we do locate the culprit, so to speak, we order all pro-



duct.-s removed, tanks purged of its flammable vapors and




that no commodity be put back into that system and used




again.




               Now, what is happened now to this soil,




the gasoline or product that has gotten into the soil,




we are stuck now with a problem of a soil problem, con-



taminated with explosive vapors perhaps.   So what we do



in many cases,  we will have an excavation of that soil,



the excavation is made, the soil will be removed from




the surrounding tank and excavated and this will be taken



care of by an Environmental Protection Agency, they will




come in and excavate' it and they will take that soil.




               Now, we have the soil on our hands satur-




ated with a combustible, flammable liquid, it must be




disposed of.  It is generally taken out to a landflat




and allowed to evaporate.   This is a way to do it, it



is done at times, but it is a problem.  It may be better

-------
for us to have an agency like a waste disposal company




come in, take that particular material away, mix it with




a fuel oil and put it into a high temperature incinerator




to dispose of it.  And these are the type of situations




we run into.




               We run into a laboratory, a laboratory will




move out, we'll have a new occupant take over those premi-




ses and hell run in and he'll wind up finding six or eight




boxes of ether or sodium or whatever.   That becomes our




burden now, and we make arrangements with distributors,




we know who they are, we'll have them delivered back to




the distributor or have them picked up.  And, that's




generally the way we handle it.   We handle it as a situ-




ation develops.




               MR. KOVALICK:  And all of those are done




at the taxpayers expense then, not by the —




               CAPT. HcCABE:    In the interest of public




safety, at the taxpayers expense, unless the generator is




known and has possession, then it is his responsibility




to take a waste disposal company and remove it and dispose



of it.




               MR. LEHMAN:  Any other questions?  I guess




not. Thank you  very much, Capt. McCabe.   Our next speakei




is Mr.  Robert Canace  of Maplewood, New Jersey.  Is Mr.




Canace here?   No.  He was scheduled a little later on in

-------
the afternoon, perhaps he will come later.  Our next
speaker scheduled then is Mr. Ed Shuster of the Chemtrol
Corporation, is Mr. Shuster here?  Here again, these
gentlemen are scheduled for a later time period.  All
right, next, Mr. Jack Miller, Pollution Abatement Ser-
vices.
               MR. MILLER:  My name is Jack Miller and
I am Vice President and General Manager of Pollution Abate
ment Services of Oswego, Inc., located in Oswego, New
York.   Since 1971 we have been in the business of des-
troying liquid industrial wastes primarily by high tem-
perature incineration.   our general market area is the
Northeast,  including New England, New Jersey and
Pennsylvania.
               Our business is quite specialized in that
the material we receive cannot be recycled or reused and
as such, is at the very end of the environmental* clean-up
ladder.  In terms of total impact on the environment,
the waste we process have taken a back seat to such
problems as waste water treatment plants, internal com-
bustion engine exhausts, etc.  It is gratifying to see
the attention the EPA is giving to this problem now and
we are pleased to have an opportunity to make comments.
               We would first like to comment on the in-
cineration process.  As everyone knows, matter can neither
                      250

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be created nor destroyed; only its form can be changed.  Consequently,
    we believe that high temperature incineration is one of
    the best methods possible for the proper treatment of
    many hazardous wastes.   Under proper conditions, burning
    breaks down hydrocarbons into harmless gases which can be
    omitted to the atmosphere and contained metals are oxi-
    dized at high temperatures to their most stable, inert
    state.   There are very few processes that are as univer-
    sal and positive as incineration.  We destroy literally
    hundreds of different materials with one process.
                   It is no secret t>at the great majority of
    hazardous wastes have been either landfilled or dumped
    in the waterways.  It is furthermore no secret that this
    practice continues, even in cases where the laws are ex-
    plicit and enforceable.  The reason these procedures con-
    tinue is two-fold, 1) that it is considerably less expen-
    sive to dispose of these wastes in such a manner and 2)
    in many cases the proven technology for proper disposal
    is lacking.
                   In response to the question, "What can
    governmental agencies do for us?" we would like to make
    three basic recommendations:
                   1.   Enforce existing landfill and dumping
    regulations.
                   2.   Make governmental loans or outright
                              251

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grants available to the industry to implement current




technology.




               3-  Become deeply involved in the advance-




ment of new technologies and the development of those




already on the drawing board.




               Our industry, that Is the industry of dis-




posing of hazardous wastes in a manner compatible to




the environment, is new and as such, faces unique prob-




lems.  We believe there is a real need for such services




because quite obviously, individual generators of wastes




are not, in a position to make significant investments in




equipment, manpower or technology.




               A centralized collection agency and dis-



posal service can consolidate technical help, equipment



and expertise in an economical fashion.  However, as a




private company in the hazardous waste disposal business,




we are faced with the three problems mentioned above that




must be solved if the industry is to survive.  The exist-




ing laws with regard to disposal must be enforced.




               Since our inception, we have had to compete




with waste disposal operations that do no more than pick




up and dump wastes indiscriminately.  As long as this




oractice continues, pricing will make the advancement of




our industry almost impossible.  Make no mistake, the



cost of disposal is what governs how and where wastes will




                          252

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be handled.
               This has a direct bearing on the second
point, and that is the difficulty of obtaining investment
capital at a reasonable cost.  As long as the industry
must compete with illegal dispoal methods, a reasonable
return on investment capital will be an impossibility.
               We have not, as an industry, been able to
realize a fair return on our investment, let alone make
expansions or do additional research on various types of
treatments.  It would seem with the millions of dollars
being spent on environmental programs, that S0me monies
could be allotted for lowinterest loans to overcome this
problem.
               Although certain vehicles for borrowing
or grants do exist, we find no money is available because
we are a privately owned, profit oriented venture.  There

are numerous opportunities for joint ventures where capi-
tal is available,  but until such time as a reasonable
return on investment can be shown, #3, because of lack

of capital, there  is no opportunity to make necessary
investigations to improve on the technology.
               In this respect, the EPA has acted as a
dissemination source of current technology, but we feel
they should go further and actually do the necessary re-

search and development on a laboratory and pilot scale
                            253

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to develop this technology.  The industry needs an informa




tion source which can offer advice and facts regarding




specific materials and processes and proper disposal




methods.  Small businesses, such as this industry, simply




cannot afford such sophisticated research, whereas the




common good may very well justify governmental expendi-




tures.




               We would also like to comment briefly on




some of the discussion topics listed in the meeting notice




First, we believe the classification of hazardous material




must be done by a central agency since a generator of a




waste may, in fact, be unable to determine the extent of




the hazards involved in his wastes.




               As to sampling, the generator of the waste



should be responsible for the contents of the waste.




There is simply no way in the limits of economic feasi-



bility for a waste disposal operation, such as ours,  to




accurately qualitatively analyze every waste we receive.




A single 55 gallon drum of wa±e may have several layers




of different materials in it.  To try to qualitatively




analyze with any degree of surety what we are dealing




with, in many cases would be next to impossible.  There-




fore, we, as a disposal site, must rely heavily on our




customers knowledge of the contents of the waste materi-




al.  Once this is known, the disposal operation can set

-------
up checks to maintain control.
               We also believe that the waste originator
should be held responsible for ascertaining whether or
not he is dealing with a legitimate and legal waste dis-
posal operation.  He should also be held responsible for
the accurate description.of the wastes given to the waste
disposal firm.  When these two things have been establishe
we believe the responsibility should pass to the waste
disposal operation.
               With respect to the several questions
on how specific wastes  should be treated, WB believe the
agency should establish proper disposal and destruction
methods for various groups of materials.  The solutions
must be practical, i.e., the magnitude of the problem
must be taken into consideration with respect to the real
hazards involved and weighted against the economic prac-
ticability of different methods of treatment.
                With respect to the control of disposal
sites, we believe they .should be carefully controlled and
monitored by qualified agency personnel.  However, we
feel that the agency should provide assistance and advice
if requested, as opposed to simply enforcement.   We have
too often heard the statement that the enforcement body
has no idea of what we can do with the material,  that it
cannot be buried or burned.  This is ro t a practical
                            255

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approach, since in fact, material ends up being burled



somewhere when the enforcement agency Is not looking.



               We cannot comment on the questions regard-



ing the use of landfills since we do not have a landfill.



It is our general opinion, however, that many hazardous chejmicala



that are landfilled will result in problems in years to



come.  Recent information published by the EPA illustrates



cases where materials have been burled for 20 or 30 vears



and are now contaminating water supplies.



               In summary, we firmly believe that opera-



tions such as ours will, in large part, be the solution



to the hazardous waste problem, but we must first become



profitable to attract capital for the necessary growth



and investment in technology.  Without adequate enforce-



ment, availability of money and technology, the growth



of our industry will be a slow process.



               Thank you.



               MR. LEHMAN:  Thank you, Mr. Miller.  Do



we have any questions?  Will you answer questions?



               MR. MILLER:  Yes.



               MR. LEHMAN:  Ar. Llndsey?



               MR. LINDSEY:  You have indicated that your



facility, your specific facility is primarily in inciner-



ation, incineration oriented, is that right?




               MR. MILLER:  That's true.






                         2b6

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               MB. LEHMAN: Could you comment for us on the

types 01 waste that you handle, specifically are there

types of wastes which you will not handle in such a facili-

ty?   And, secondly, what do you do with the ash and so

forth from this facility?

               MR. MILLEK:   Our system operates, actual-

ly an enclosed system, we handle virtually any type of

organic material.  You have to be careful when you answer

these questions. Arsenic we do not handle, lead, mercury,

those metals which the oxides are high temperature oxides,

are toxic.

               As far as organic material, virtually any

organic will break down at high temperatures, can be

handled, handle acids and bases.   The particulate matter

taken off the burning process is actually recirculated

back to a main gallon lime lagoon in which right now it

is being collected and which may be a problem in later

years, as a matter of fact.   There is no discharge.

               MR. LEHMAN:  Mr. DeBonis?

               MR. DeBONiS:    j haveiso, what is done

with the incinerator ash.

               MR. LEHMAN:  Same question.   Mr. Kovalick?

               MR. KOVALICK:   On page 3 of your statement,

you indicate that it would be very helnful to you to have

the generator identify specifically what's in the wastes

being sent to you, that he should ''be held responsible for
                              kbT

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the accurate description of the waste."   Do I interpret



that as an endorsement that he may be required to do that?



I mean, how do you hold someone responsible?  That is, if



you were in this business and you had another company in



this business, and he did not require that and someone



who wanted to use his firm, and the only way that he could



be required to do that , I presume by some state or other



regulation, is that what you intend or am I misreading it?



               MR. MILLED:  Well, perhaps I am stating



it incorrectly.   The problem goes back to the adequate



sampling and the liability placed on the disposal operation.



Let's say that we have normally taken a truck load of



barrels a week from a customer.  We know what they deal




with, we know after the initial samples and initial truck-



loads just what it is.



               But, let's say that some clown slips a



barrel of arsenic or something that could get away from



us or be harmful, then we feel that we must be relieved



of this responsibility.



               As I stated in here, to sample every barrel



for every element is an impossibility, it just can't be



done.   So, somehow we believe that the responsibility



for this must rest upon the generator of the waste.



               MR. LEHMAN:  Do we have any other questions!



Evidently, not, thank you very much, Mr. Miller.  To move





                        258

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backwards to one of the scheduled speakers who has now




entered the room, I would like to call next, Mr. Ed




Shuster from the Chem-Trol corporation.  Mr. Shuster?




               MR. SHUSTER:  Gentlemen, it is a  privilege



for me to be present today to briefly summarize certain




inputs on the suoject of Professional Management of




Hazardous Wastes.   There is absolutely no way I can dis-




cuss this subject in fifteen minutes.  For example, in




the supporting information  are copies of addresses made




by Mr. Wagner and myself which we painfully edited to




45 minutes.  Discussion of nearly any unit process, or




our synergistic Closed-loop System, which combines these




processes into a highly sophisticated Central Processing




Facility complex would require more time than is alloca-




ted for the entire meeting.




               Therefore, I am submitting in writing a



substantial amount of material for the record.  I'll




limit my comments here and will entertain questions.




               We will between now and January, as stipu-



lated in your notice, respond point by point to the dis-



cussion topics.




               Our company has participated actively in




the business of the Chemical Waste Committee of NSWMA,




who will be submitting a comprehensive document.  I am



pleased to say that much of our philosophy and recommended

-------
practices have been adopted by NSWMA and are included in ti
document.  I will avoid that redundancy at this time.
eir
               I would like to comment briefly that we
strongly endorse the type of manifest system which they
advocate, wherein the producer, the transporter, the pro-
cessor and the disposer would all be held accountable for
the management of the material.
               We also advocate the type of waste advisory
committee advocated by~NSWMA, which would tie together tha
forces of the generators of wastes, the processes and
disposers of wastes,the regulatory people and the public
at large, in a form of a task force committee to try and
draw something rational out of this whole difficult sub-
ject.
               Hazardous wastes are a diverse lot.
Characterization must be on the basis of properties of
the waste, as well as the chemical composition of the
waste and the attributes of individual components.
Waste streams from the same source frequently exhioit
marked compositional and property changes with relation
to time.   The definition of hazardous waste, therefore,
should reflect that there is not a sharp delineation

                            260

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between hazardous and non-hazardous, but in fact it is a



very broad grey area that exists.



               We have demonstrated that most chemical



wastes can be processed within reasonable economic con-



straints.  In our processing, many are converted to useful



marketable products, to environmentally conroatible species



such as C02  and water vapor or substantially converted



to stable, detoxified forms with the degree of hazardous/



toxic properties reduced to a level of enivonrmental



acceptability commensurate with the final place of depos-



it of these ultimate residues.  Even so, using this exten-



sive initial processing and the type of Controlled Scien-




tific Landfilling pioneered by Chem-Trol, provision must



be made for collection and processing of any leachate



formed.  Today's ultimate residues in the SLP are ex-



pected to be resources of tomorrow.



               Since the combined or sequential use of



typically ^ to 6 processes, and sometimes as many as 10,



are required to properly treat each fraction of a hazar-



dous waste, flexibility in processing must be readily



permitted.  What should be regulated are the discharges



to the air, water, and land, wherein the material would



escape the control of man.



               The generator of the waste and hence the



consumer of the generator's products  will bear the




                          261

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ultimate financial burden.  Private enterprise is best




equipped to conduct the business of hazardous waste manage=




ment.  Government should consider not only the needed




regulatory program to eliminate the illicit, unethical,




or shady practices that have thwarted the growth of the




Professional Hazardous Waste Processing Industry;




 government-Should also consider incentive programs to en-




coUrage voluntary compliance, and eminent domain actions




where needed to assure appropriate siting of processing




centers and disposal sites based on technological factors.




Incentive freight rates are also needed.   Which is out




of EPA, that's over in the Department of Transportation.



               Our submitted documentation identifies the




means or reducing or rrfnimizing disposal costs through



source segregation and management, rigorous analytical



and quality control processes, proper identification sys-




tems, and our ability to utilize the waste resource.




This approach frequently results in reduction in quantity




of waste produced and permits conservation of significant




quantities of natural resources and energy.  Where a




large enough recoverable value is present, our policy is




to share this with the waste generator, further lowering




his costs or resulting in his selling us the waste for




Its raw material value.  We buy many wastes.





               We feel our approach is sound, it is





                          262

-------
viable today and it is geared toward the future.




of Pertune's 500 companies use our services for this rea-



son in addition to their need to meet today's codes.  We



process wastes from nearly every corner of America in



spite of the distant transportation factor, and from lo-



cations abroad.  We have substantial capacity to serve the



needs of the waste generators and modular expansion capa-



bilities at our present plant.   We are also prepared to



move forward with additional plants once a requisite,



firm business is there to warrant the economic investment.



               I believe my time is about expired, and I




will again say that we will respond to the discussion



topics point by point and I would be glad to either field



a question or two now or later in writing, if you please.



               Thank you.
                       263

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                                 NSWMA/EPA
                                San Francisco
                               Nov. 12-16, 1974
                "MANAGEMENT OF  CHEMICAL AND HAZARDOUS  WASTE"
GENTLEMEN,
     IT CERTAINLY IS A PLEASURE TO PARTICIPATE  IN THE NATIONAL  SOLID
WASTE MANAGEMENT ASSOCIATION'S THIRD NATIONAL CONGRESS ON WASTE
MANAGEMENT  TECHNOLOGY AND RESOURCE RECOVERY.  TODAY,  I AM GOING TO
GENERALLY DISCUSS THE PROPER  IMPLEMENTATION  TO  INSURE CORRECT MANAGE-
MENT OF CHEMICAL AND HAZARDOUS WASTES.  MY PRIMARY PURPOSES ARE:
     1.  TO REALLY LET YOU KNOW THE FACTS OF THE  REAL WORLD IN
         PROPER TREATMENT OF  WASTES.  WHEN THE  CONSULTANTS, THE
         DESIGN ENGINEERS, THE PROMOTION EXPERTS  HAVE LEFT, AND
         MATERIAL STARTS FLOWING INTO YOUR PLANT, OPERATIONS
         ESSENTIALLY HAVE BEGUN AND THAT'S WHEN YOUR PROBLEMS
         START.  THERE ARE NO PROBLEMS UNTIL OPERATIONS START.
         IN THE VARIABLE FEED WORLD OF DISPOSING OF HAZARDOUS
         AND CHEMICAL WASTES,  PROBLEMS ARE IMMENSE,  DIFFICULT
         AND SOMETIMES IMPOSSIBLE TO HANDLE  ON  A REASONABLE,
         ECONOMIC BASIS.
     2.  I  WOULD LIKE TO MAKE YOU AWARE OF HOW  DIFFICULT THE
         TREATMENT OF CHEMICALS AND HAZARDOUS WASTES REALLY IS.
     3.  TO MAKE YOU AWARE, UNLESS YOU KNOW  THE NATURE OF THE
         WASTES (EXACT ANALYSIS) YOU ARE ASKED  TO HANDLE A WASTE
         DISPOSAL PROBLEM WITHOUT BEING FULLY INFORMED AS TO THE
         NATURE OF THE WASTE,  YOU ARE BEING EXPLOITED.
     HISTORICALLY, IN 1969, IT BECAME VERY APPARENT TO OUR ENTIRE
SOCIETY THAT WE HAD SUPERSATURATED OUR WATERWAYS  WITH VARIOUS TYPE
OF WASTE PRODUCTS.  THIS LED  TO A NATIONAL OUTCRY FOR ACTIONS TO
IMPROVE OUR ENVIRONMENTAL CONDITION.  IN TURN,  THIS LED TO A DRASTIC
CHANGE IN THE METHODS THAT WERE USED TO DISPOSE OF CHEMICAL AND
HAZARDOUS WASTES.  AT THAT TIME CHEMICAL AND HAZARDOUS WASTES WERE
BEING DISPOSED OF PRIMARILY BY DILUTION WITH WATER AND THEN DUMPING
INTO A WATERCOURSE, STREAM.   LAKE, OCEAN, ETC.   OTHER METHODS WERE
ILLEGAL DUMPS, DUMPING IN FARMER'S FIELDS, DUMPING DIRECTLY INTO
SEWER SYSTEMS, AND MANY, MANY OTHER NEFARIOUS WAYS.   THE PUBLIC
OUTCRY AND  THE SUBSEQUENT FORMATION OF THE EPA, A SPECIFIC AGENCY
TO DEAL WITH THE PROBLEM, CAUSED THE WASTE DISPOSAL TREATMENT TREND
TO TURN GENERALLY FROM DILUTION TO LAND DISPOSAL.

-------
TODAY THE  PROBLEM IS BECOMING VERY ACUTE.  DEMAND  FOR LAND DISPOSAL IS
SO GREAT THAT ALL TYPES OF  HAZARDOUS WASTE MATERIALS ARE DUMPED IN
LANDFILLS  THAT ARE NOT PREPARED TO HANDLE SUCH  WASTES.  THE ENVIRON-
MENTAL PROTECTION AGENCY, THE LOCAL AND STATE ENVIRONMENTAL AGENCIES,
ARE CRACKING DOWN ON BLATANT ENVIRONMENTAL VIOLATIONS AND TEMPORARILY
CAUSING MORE AND MORE WASTES TO GO TO LAND DISPOSAL.  MANY CHEMICAL
WASTES ARE BEING HANDLED, BY SEWER DISPOSAL WHERE  THE SEWER SYSTEM
HAS ONLY PRIMARY TREATMENT.   AS SOON AS SEWER DISTRICTS GO TO
SECONDARY  AND TERTIARY TREATMENT,  THIS WILL SHUT OFF AN AVENUE FOR
CERTAIN TYPE OF CHEMICAL AND HAZARDOUS WASTE, AND  AGAIN CAUSE A GREATER
DEMAND FOR LAND DISPOSAL.   PUBLIC  OUTCRY AND THE FACT THAT LAND DISPOSAL
WAS NOT AN ACCEPTABLE LONG-TERM SOLUTION FOR HAZARDOUS WASTES CAUSED
THE FORMATION OF PROFESSIONAL TREATMENT COMPANIES.  THE FIRST TWO IN
THE UNITED STATES WERE INITIATED IN 1969.  TODAY,  THEY HAVE GROWN
SUBSTANTIALLY AND ARE HANDLING APPRECIABLE QUANTITIES OF HAZARDOUS
AND CHEMICAL WASTES, BUT FRANKLY,  THE MAJORITY  OF  WASTES ARE STILL
DEPOSITED  ON THE LAND, MANY IN UNACCEPTABLE MANNERS.
     THE KEY TO PROPER IMPLEMENTATION OF A PROGRAM IS CONTROL.  THE
BUSINESS OF PROPER TREATMENT IS ESSENTIALLY A CHEMICAL BUSINESS.  WE
ARE PROCESSING WASTE CHEMICALS THAT THE CHEMICAL INDUSTRY HAS BEEN
UNABLE OR  UNWILLING TO PROCESS.  CONTROL MEANS  COMPLETE KNOWLEDGE OF
THE WASTE.  CONTROL MEANS FULL ANALYSIS.  THEREFORE, TO DETERMINE
WHETHER YOU CAN HANDLE A PRODUCT AND DETERMINE  AN  ACCEPTABLE METHOD
FOR' DISPOSAL, YOU MUST HAVE A COMPLETE CHEMICAL ANALYSIS, AND LACKING
THAT, YOU  SHOULD HAVE ACCESS TO A LABORATORY THAT  CAN GIVE YOU THAT
COMPLETE INFORMATION.  LANDFILLS HANDLING MATERIALS THAT ARE NOT
IDENTIFIED ARE SUBJECTING THEIR EMPLOYEES AND THEIR BUSINESS TO GREAT
LIABILITIES.  OVER THE YEARS MANY COMPACTOR AND BULLDOZER OPERATORS
HAVE BEEN  KILLED OR SERIOUSLY HURT; IN COMPRESSING A DRUM IT EXPLODES
OR CATCHES ON FIRE AND COMPLETELY ENGULFS THE OPERATOR BEFORE HE CAN
JUMP OFF.   OUR LATEST TRAGIC EVENT OCCURRED OCTOBER 1974.  UNFORTUNATELY
THESE INCIDENTS WILL CONTINUE UNLESS THE PROPER ANALYSIS PROCEDURE  IS
PRACTICED.  WE CAN NO LONGER TOLERATE BEING EXPLOITED BY GENERATORS
OF WASTE.   NOW, WHAT MUST BE DONE  IS THAT ONCE  THE ANALYSIS IS
RECEIVED?   YOU MUST BE ABLE TO DETERMINE THE BEST  METHOD FOR DISPOSING
OF THAT WASTE TO MEET ALL CODES AND SAFETY REQUIREMENTS, OR PERHAPS,
EXTRACTING SOME VALUE FROM  IT.   IF IT IS THOUGHT TO HAVE VALUE, IT
SHOULD GO  TO A COMPANY THAT HAS RESOURCE RECOVERY  EQUIPMENT SUCH AS
DISTILLATION EQUIPMENT, OIL RECOVERY SYSTEM, METAL AND SALTS RECOVERY.
                                      265

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IF IT DOESN'T HAVE ANY VALUE,  IT SHOULD BE DESTROYED  BY THERMAL OXI-
DATION, BY NEUTRALIZATION,  CHEMICAL STABILIZATION, AND WATER TREATMENT,
OR PROPERLY CONTROLLED LANDFILL; SPECIFICALLY, A  SCIENTIFIC LANDFILL
WHICH HAS LEACHATE CONTROL AND THE EQUIPMENT ON SITE  TO PROPERLY
DISPOSE OF THE LEACHATE.   SCA/CHEM-TROL HAS DEVELOPED A "CLOSED-LOOP"
(ATTACHED), (A SYSTEMATIC PROCEDURE TO DETERMINE  WHETHER YOU CAN
SAFELY AND PROFITABLY HANDLE A GIVEN WASTE) PROCESS THAT SHOWS THAT
IN THE TREATMENT  OF  WASTE,  VARIOUS FACILITIES ARE REQUIRED TO DO THE
COMPLETE JOB.  IN MY OPINION,  RESOURCE RECOVERY IS A  METHOD TO SHOW
POTENTIAL SAVINGS TO THE  ORIGINATOR OF WASTES AND THEREBY ENCOURAGE
HIM TO PARTICIPATE IN A TOTAL PROPER WASTE DISPOSAL PROGRAM.  THE
CLOSED-LOOP PROCESS  GIVES YOU A FLOW DIAGRAM AS TO THE PROPER IMPLE-
MENTATION AND HANDLING OF CHEMICAL AND HAZARDOUS  WASTE.  GOING THROUGH
IT QUICKLY WE RECEIVE A DESCRIPTIVE SAMPLE FROM THE CUSTOMER, WE
ANALYZE IT, WE DETERMINE  IF WE HAVE THE PERMITS,  THE  EQUIPMENT,
STORAGE CAPABILITIES TO HANDLE THAT PRODUCT.  IF  WE DO, WE SUBMIT A
CONTRACT PROPOSAL.   THEN  WE SCHEDULE A TRIAL PICKUP AND, PERHAPS THE
TRIAL WILL INVOLVE TWO OR THREE TANKWAGONS OF MATERIAL FROM THE
CUSTOMER.  IF WE  FIND THE ORIGINATOR IS SHIPPING  US WHAT HE'SAYS HE
IS, WE ENTER INTO A  LONGER CONTRACT.  IF WE DON'T, WE EITHER INITIATE
A RESEARCH AND DEVELOPMENT PROGRAM TO HANDLE IT IN THE FUTURE, OR WE
REFUSE THE ORDER. A PROFESSIONAL TREATMENT PLANT IS  NOT THE ANSWER
TO ALL THE WASTE  PROBLEMS.   IT CERTAINLY HAS LIMITATIONS AND TO
RECOGNIZE THOSE LIMITATIONS, YOU HAVE TO HAVE THE PROPER ANALYSIS,
PROPER PROFESSIONAL  TEAM.  NOW BACK IN THE LAB EVALUATION PORTION, WE
MADE OUR DETERMINATION THEN BEFORE WE MADE THE CONTRACT PROPOSAL,
WHETHER THE MATERIAL AHD ANY VALUE, AND COULD GO  TO RESOURCE RECOVERY
OR HAD TO BE DISPOSED OF.  IF IT HAS RECOVERABLE  VALUE, IT IS PROCESSED
THROUGH FRACTIONAL OR FLASH DISTILLATION, FUELS RECOVERY, METALS SUCH
AS COPPER, ZINC RECOVERY, AND PRODUCTS THAT CAN BE SOLD "AS IS".  IN
OTHER WORDS, WE ACT  AS A CLEARING HOUSE FOR CERTAIN TYPE OF WASTE
PRODUCTS.  IF THERE  IS NO VALUE, THE PRODUCT MUST EITHER BE PUT THROUGH
THE THERMAL OXIDIZER AND DESTROYED BY HIGH TEMPERATURES, NEUTRALIZED,
STABILIZED AND PUT INTO A LANDFILL, OR IT IS RUN  THROUGH THE WATER
TREATMENT SYSTEM. THIS IS THE TYPE OF CONTROL, THE TYPE OF BACKUP,
THAT IS REQUIRED  TO  OPERATE A CENTRAL DISPOSAL FACILITY IN ACCORDANCE
WITH ALL LAWS.  A SMALLER CLOSED-LOOP COULD BE DEVELOPED, IN OTHER
WORDS, A LOOP CONTAINING LESS FACILITIES, IF YOU  CAREFULLY DEFINE
YOUR LIMITATIONS  SO  YOU DON'T TAKE PRODUCTS IN THAT WILL CAUSE
PROBLEMS.

-------
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                      267

-------
      I WOULD  JUST LIKE TO DISCUSS BRIEFLY THE MATERIAL HANDLING
ASPECT OF PROPER IMPLEMENTATION.  AGAIN, IDENTITY OF THE PRODUCT IS
ESSENTIAL SO YOU CAN DETERMINE THE CORROSION NATURE  OF THE PRODUCT
AND UTILIZE PROPER EQUIPMENT SO YOU DO NOT ENDANGER  YOUR DRIVER OR
OTHER PEOPLE ON  THE HIGHWAYS.  ALSO, IDENTIFICATION  IS REQUIRED SO
YOU DON'T MIX  ON MILKRUNS.  PRODUCTS THAT ARE NOT COMPATIBLE, SUCH
AS CYANIDE AND ACIDS,  THAT WOULD RELEASE A POISONOUS GAS, AND MANY
OTHER COMBINATIONS THAT WOULD CAUSE EXPLOSIONS.   MANY HAPPEN EACH
YEAR WITH HAULING CONTRACTORS THAT ARE NOT INFORMED  AS TO THE NATURE
OF THE WASTE PRODUCT THEY ARE HANDLING.  FOR YEARS THE ORIGINATORS
OF THE WASTE HAVE GENERALLY TRIED TO MAINTAIN SECRECY AS FAR AS THE
NATURE OF THE  WASTES ARE CONCERNED, AND FOR YEARS, THEY HAVE EXPLOITED
THE LANDFILL OPERATORS, AND THE POOR LITTLE HAULER,  IN THE SENSE THEY
HAVE SUBJECTED HIM TO TREMENDOUS DANGER POTENTIAL, BECAUSE IN MOST
CASES, THEY DID  NOT SUBMIT INFORMATION REGARDING THE NATURE OF THE
WASTE.  EVEN RECENTLY A CERTAIN GROUP OF PROFESSIONALS INSISTED THAT
THEIR BUSINESSES WOULD BE IN DANGER IF THEY HAD TO REVEAL THE NATURE
OF THE WASTE.  OUR POSITION AS PROFESSIONALS  IN THIS FIELD TODAY MUST
BE COMPLETE IDENTIFICATION.  WE ARE ESSENTIALLY TAKING THEIR ENVIRON-
MENTAL PROBLEM AWAY AND WE BETTER BE ABLE  TO  HANDLE  IT IN THE PROPER
FASHION OR WE  CREATE MANY PROBLEMS WITH THE REGULATORY AGENCIES FOR
OURSELVES.
      IT IS QUITE OBVIOUS TO ALL OF US THAT THE COSTS OF PROPERLY
TREATING WASTES  ARE GOING TO BE APPRECIABLY HIGHER THAN PREVIOUS
METHODS.  PROPER IDENTIFICATION IS COSTLY.  FOR EXAMPLE, A GOOD
LABORATORY WILL  CHARGE $35 AN HOUR FOR ANALYSIS, AND I CAN ASSURE
YOU THAT ALMOST  EVERY SAMPLE WILL COST A MINIMUM  $35, AND MOST OFTEN
ON THE AVERAGE OF $70.  THE CAPITAL EQUIPMENT REQUIRED TO DO A PROPER
JOB IS EXTREMELY EXPENSIVE.  TO DUPLICATE  WHAT WE HAVE AT MODEL CITY
WILL COST OVER $10 MILLION.  HIRING CHEMICAL  ENGINEERS, THE CHEMISTS,
THE PROFESSIONAL PEOPLE THAT WE MUST EMPLOY TO DO A PROPER JOB IS
EXPENSIVE.  THIS ALL ADDS UP TO MUCH HIGHER COST FOR PROPER TREATMENT.
WE AS A SOCIETY, WE AS AN INDUSTRY, HAVE NO ALTERNATIVE BUT TO
PROPERLY TREAT THESE WASTES AND CHARGE THE PRICES THAT ARE REQUIRED.
WE MUST, HOWEVER, MAKE EVERY EFFORT TOWARD RESOURCE RECOVERY.  THE
WASTE RESOURCE,  THAT IS PRODUCTS OF VALUE  CONTAINED IN WASTE, HAS
REALLY NEVER  BEEN PROMOTED, AND BELIEVE ME,  THERE ARE HUNDREDS OF
THOUSANDS OF  DOLLARS OF VALUABLE PRODUCTS  BEING THROWN AWAY EACH DAY.
IF WE CAN FIND ONE OR TWO PRODUCTS OF VALUE IN A CUSTOMER'S WASTE
STREAM, AND THEN PUT IT IN A FORM THAT MAKES  IT MARKETABLE, WE WILL
APPRECIABLY REDUCE THE ORIGINATOR'S COST AND  ALSO HELP OUR SHRINKING
NATURAL RESOURCE PROBLEM.                       268

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IT IS ESSENTIAL,  IT IS PROFITABLE, AND  IT IS A WAY TO APPRECIABLY
DEVELOP OUR  INDUSTRY.   IF WE CAN SHOW A CUSTOMER THAT THERE  IS
POTENTIAL FOR LOWER COSTS, AS COMPARED  TO THEIR DOING IT, WE HAVE
A LONG-TERM  CUSTOMER BECAUSE HE IS NOT  INTERESTED IN INSTALLING HIGH
COST CAPITAL EQUIPMENT AND THE ENVIRONMENTAL ENFORCEMENT PROGRAM
AND TECHNOLOGIES  ARE MOVING AHEAD AND CHANGING SO OFTEN.  (SEE  ATTACHED
COST-TIME GRAPH).
      OUR  INDUSTRY MUST IMPROVE IN THE SENSE OF HAVING TECHNICALLY
CAPABLE PEOPLE TO RUN THE BUSINESSES FOR US.  THE FACTS OF LIFE ARE:
TO PROPERLY CONDUCT THE CHEMICAL AND HAZARDOUS WASTE BUSINESS,  WE
HAVE  TO HAVE COMPETENTLY TRAINED CHEMISTS AND ENGINEERS.  THERE IS NO
OTHER WAY.   THE SOLID WASTE INDUSTRY RECOGNIZES THIS AND IS  GEARING
UP TO MEET  THE CHALLENGE.  THE SOLID WASTE BUSINESS INDUSTRY HAS THE
HAULING CAPABILITIES AND THE MATERIAL HANDLING CAPABILITY.   NOW WITH
THE ADDITION OF THE PROPER FACILITIES AND TECHNICALLY COMPETENT PEOPLE,
THE SOLID WASTE INDUSTRY HAS ALL THE NECESSARY TOOLS TO DO AN EXCELLENT
JOB AT A LOWER COST THAN INDUSTRY OR GOVERNMENT.
      IN SUMMARY,  PROPER IMPLEMENTATION  TAKES PROPER IDENDIFICATION,
COMPLETE FACILITIES, WELL-ENGINEERED HAULING CAPABILITIES, TRAINED
TECHNICAL PERSONNEL, AND ENFORCEMENT BY THE REGULATORY AGENCIES.  IF
A CONTRACTOR NOW HAULING WASTES WANTS TO DO IT ON A LONG-TERM BASIS,
HE MUST NOW  RECOGNIZE HIS LIMITATIONS AND MUST CONSIDER THESE POINTS:
     1.  DO  I HAVE THE PRODUCT COMPLETELY ANALYZED?
     2.  CAN I HANDLE THAT TYPE OF PRODUCT FOR DISPOSAL OR
         RECLAMATION.
     3.  WHO CAN  HANDLE THE PRODUCT FOR DISPOSAL OR RECLAMATION?
     4.  DO  I KNOW WHERE TO TAKE THESE  WASTE PRODUCTS SO THAT I
         DO  NOT CAUSE A PROBLEM FOR THE ORIGINATOR NOR FOR MY
         COMPANY?
     5.  DO  I HAVE THE PROPER CONTROL TO MAINTAIN THE ECOLOGICAL
         AND SAFETY CODES THAT ARE REQUIRED?
     GENTLEMEN, UNLESS YOU CAN ANSWER THESE QUESTIONS AND BE PROPERLY
ORGANIZED TO HANDLE THE WASTE PRODUCTS  WITHOUT CAUSING ENVIRONMENTAL
OR SAFETY PROBLEMS, YOU ARE IN A SHORT-TERM BUSINESS.  IF YOU WISH
TO BE LONG-TERM,  YOU MUST TAKE IMMEDIATE STEPS TO GEAR-UP TO PROPERLY
MANAGE THE DISPOSAL OF CHEMICAL AND HAZARDOUS WASTES.

                                    LOUIS E. WAGNER, PRESIDENT
                                    CHEM-TROL (LIQUID WASTE DIVISION)
                                    SCA  SERVICES, INC.
                                                  269

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               SEMINAR ON MANAGING HAZARDOUS MATERIALS AND WASTES
                              Nashville, Tennessee
                                  April k, 1975

Address by:  Edward R. Shuster, Division Manager, Technical Services 6 Market Develop-
             ment - CHEM-TROL POLLUTION SERVICES, INC.


It certainly is a pleasure for me to be here today at this Hazardous Waste Seminar.

Rounding out discussions of handling, transporting and disposing of these materials,

is an exciting alternative to disposal, "The Value That Can Be Derived From Waste

Products".  As we all have seen, the prices of chemicals, metals, fuels and just about

everything else, have sky-rocketed over the past year and; even though there is hope

that our current administration is going to take the necessary corrective steps, prices

will continue to rise.  As a result, it seems the goal of cleaning our environment, re-

using raw materials as many times as possible, and treating waste as a valuable raw

material, must now be considered necessity.  Pollution control has become an accepted

requisite, not simply a whim, of an affluent society.  Cleaner air and water are not

so much luxuries as conditions necessary to insure health, safety, and the quality of

life.  Cleaning up and recycling are not only the answer to disposal and pollution

control problems, they are also part of conserving our diminishing natural resources.

This Is a broad base, scientific, public and political concern.  But those of us en-

meshed In the positive side of pollution control, its opportunities for new technology

and enterprise, find  It too easy to forget that the main thrust of the environmental

movement upon Industry heretofore has been a rather negative one.  In fact, most of

the problems and frustrations of the environmental  management business can be traced

to Its basic negative Impact.  Heretofore, environmental management was a source of

a cost, not of a profit, to most industries.   Today,  cleaning up can be considered

not only a challenge, but an opportunity to reduce costs appreciably and, perhaps even

establish a value for waste products.  Environmental  management's responsibility has

become much broader.   Those responsiblI ties now include returning, dollars (profit) to

the corporation, because now there are  substantial  opportunities in the environmental

management sector to do exactly that.  Environmental  management today presents  several
                                         271

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cost saving opportunities.   Do you as private enterprise really have a choice but to




look for value in your waste product?  Do you have an option?  Not really.  You have




these choices.  Simply pay waste disposal costs, or set up a realistic program to




define, analyze your waste products in a very professional manner and determine the




best game plan toward cost savings.  What is the magnitude of industrial wastes




generated in the United States today?  The wastes that I speak of include paper,




metals, rubber, chemicals, Industrial liquids, waste oils, hazardous wastes, etc.




Waste metals have been recognized as a major growing industry in the United States.




Millions of tons of these wastes are now being  recycled.  A feW very short years




ago, scrap steel and Iron were selling for anywhere between $18 and $22 a ton.  This




past year, scrap steel shot up to as high as $200 a ton giving new  impetus to this




type of enterprise.  You have a parallel situation in the paper and cardboard industry.




The lubricating oil reclaiming plants that have dwindled  in number  from 1M in  1965




to about 31* operating plants in 137**, have now found a new life in much higher prices




for their reclaimed products.  In the area of industrial  liquid chemical wastes and




hazardous wastes, the E.P.A. has indicated that there are at least  10 million tons




generated in the U.S. per year.  In many circles, it is felt that this figure is more




like 100 million tons per year.  The magnitude  Is great.  We are wasting and have




wasted valuable raw materials that could be utilized in many segments of our  industrial




community.  The magnitude of industrial and municipal wastes has been huge and  it will




continue to grow In our affluent society at a level of 5% to 10% annually.   It  seems




very clear that by discarding these waste products, we are also not recognizing




millions and perhaps even billions of dollars of revenue each year.  Many plant




managers often say, "Well, there is no way that waste disposal  in this plant  is going




to be anything but an operating cost".  That attitude  Is  totally obsolete.  That situa-




tion is best exemplified by this case study.




A major Western New York company had the entire waste disposal needs of their plant




handled on a disposal cost basis.  Each year, they put out a contract to dispose of

-------
their wastes for one year, and each year, for at least five years,  the same refuse



hauler was awarded the job.  During that five year period, he quoted fixed rates on



containers, pick-ups, etc., but it mounted at an increasing rate from a minimum of




$100,000. up to approximately $180,000. the last year.  The company suffered several




business setbacks, called  in efficiency experts to evaluate every conceivable way to



save money.  After months of study on the waste, the efficiency expert recommended



that because there are so many products of value being thrown away each year, it



would be interesting to request a quote this year for the highest bid for these



waste products rather than a disposal cost.  You can imagine what happened.  The



same refuse hauler that hauled away this waste at a high disposal cost previously,



now submitted the highest bid to purchase these products of value.   He knew that



even paying the company $30,000 a year for their waste products and hauling them away,



he still would make appreciable profits.  There are many other examples.  One company



was disposing of a liquid waste amine product for 10 years at the annual cost of



$10,000 a year.  A central disposal facility working with the product found a home for



It, found a direct sale, because oftentimes one company's waste is another company's



raw material, and subsequently started paying for the waste product.  Savings to the



originator of the waste - over $10,000. per year.  There are many other examples.



Waste chlorinated solvents such as trichlor, perchloroethylene, methyl chloroform



and methylene chloride are frequently recoverable products with established values



to reclaimers of $.03 to $.05 per pound, based on recoverable yield, and fluorinated,



chlorinated solvents are even worth more.  Oxygenated solvents such as waste acetone,



methyl isobutyl ketone, methyl ethyl  ketone, and others, now are sold based on recover-



able yield.  Two years ago, it would cost you a minimum of $.15 to $20 per gallon for



an Incineration disposal charge.   There constantly are new uses developed as the



virgin raw material  market shrinks.  New markets are being found for recycled pro-



ducts each day.  Recycled products are now being looked to in many areas as primary



supplies, and certainly are now described as very valuable commodities, and in short




                                       273

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supply, because the waste resource has not really been fully promoted or exploited




by the people that have created it.  We speak of the waste resource, we mean those




products of value that are now considered waste that can have a value as a raw




material or as an energy source, and have been discarded rather than suggested and




reclaimed.  I  would urge all of you to start considering the waste resources in your




respective companies.  I am just going to list a few suggestions regarding the steps




that you should take now toward recognizing the value in waste products, as summarized




in Table 1.




     A.  Know your processes.




     B.  Know your raw material and supply intake.




     C.  Know your output.




     D.  Know your waste products.  Chemical wastes should be throughly analyzed.




     E.  Set up a company-wide program to segregate your waste products.  A major




         problem  in  industry, and  in general, has been co-mingling of many waste




         products that separately have high value, but mixed together makes it econo-




         mically  impossible to recognize the value because of the high cost and




         difficulty of separation.  Therefore, it Is extremely important to classify




         your waste  streams and segregate to recognize value.  Only mix when you




         are absolutely positive that there can be no value associated with that




         waste stream.




     F.   Initiate a collection program, and for large volume wastes, start designing




         for containerizatlon.  Many companies, especially with various types of liquid




         wastes,  have fallen  into the habit of putting their wastes in 55 gallon steel




         drums, and smaller.  The result is you are not only throwing away your waste




         now, but you are throwing away a valuable steel drum.  Study today's economics




         and you will find you may be pleasantly surprised that containerization would




         save you appreciable dollars today, and will also make more feasible the possi-




         bility of collecting dollars for your waste products.  Establish a firm

-------
    program of waste handling rules,  to which your employees  must  adhere.



    Clear identification of waste products is extremely important  in  each



    program and It can only be accomplished by your employees.   These people



    must be fully trained and made to understand that  identification  of  waste



    products and consistent quality waste products are extremely important  In



    a program to develop value In your wastes.



G.   Initiate a program to Identify waste disposal  costs as  a  cost  of  doing



    business.  Heretofore, waste disposal was just so  simple  and so easy,  It




    was not considered expensive, it was never considered a significant  cost



    of doing business.  Today you must include it  as a cost of  doing  business



    as a separate cost control center, so you can  determine your effectiveness



    In this area.  If you do not start a program to recognize the  value, I  can



    assure you that your cost for positive disposal wilt continue  to  increase



    at a very high rate.  Proper disposal techniques cost appreciably more  than



    simple landfill or uncontrolled techniques.  The regulatory agencies are




    going to require legal compliance through the  proper disposal  of  waste



    products, although costly.



H.   Emphasize to all  employees the control required to produce  consistent quality



    waste products.  This is not in conflict with  efficiency  or quality  control,



    and in accordance with good management and production techniques.   If you  are



    producing a quality product, you should be producing a  consistent quality



    waste product.



I.   Initiate a waste inventory and make it the responsibility of competent



    supervisors to keep that inventory sheet up-to-date.  Waste has always  been



    a measure of efficiency.  Supervisors in-many  cases reported lower quantities



    to show their efficiency.  They were not disputed  because the  costs  were so



    low, no one paid  attention to it.   It was like an  exaggeration in reverse.



    Quantity reported from middle management to a  higher level  was reduced  some-




    what and reduced  each step up the line until  top management received the word



                                 275

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         that there was no waste.




     J.   Know your wastes thoroughly and completely.   Have a  competent  waste  manage-




         ment firm assist your own efforts.




In today's tight money situation many say that there  is  no way we can  spend  the  capital




dollars to start deriving values from wastes.




If that is the case with your company, you have alternatives.  There are professional




central  disposal and recovery facilities in the Northeast section of the U.S. today.




One such company is CHEM-TROL POLLUTION SERVICES,  INC.,  located In Model City,  New




York, near Niagara Falls.  CHEH-TROL can assist you in setting up a program  to  recog-




nize the waste resource.  This first involves  in-plant analysis of your waste stream,




determination of the quantities and then looking for  values.   CHEM-TROL not  only estab-




lishes values, performs removal services on a  professional and timely  basis,  but it




also eliminates many of your environmental problems.   CHEM-TROL can haul your wastes




away and eliminate your need for capital expenditures at this time.  Figure  1 Illus-




trates the economic trends relating costs with time.   Not only can CHEM-TROL provide




economic incentives, but changing environmental codes make major capital investment




today a serious gamble.




Chem-Trol can provide a complete service.  Exactly what CHEM-TROL offers and how they




can do it is best exemplified  in the Closed-Loop Process Diagram, Figure 2.




How and why are values established?  There are several reasons and they include:




     A.  A shortage of virgin  raw materials.




     B.  Many companies are now starting to formulate utilizing recycled products.




     C.  Many companies have now recognized that they do not always need virgin pro-




         ducts.  Purchasing agents who experienced the shortages of last winter are




         doing many things, including utilization of  recycled materials as a second




         source of supply to make sure they are never caught short again.
                                   2VG

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D.   The oil crisis has made us recognize that we must take advantage of BTU's




    no matter what shape or form that they take.  When it is impossible to




    recognize a chemical value from a waste, it may be possible then to recognize




    a BTU or energy value.  Many waste solvents and waste oils, are now being




    processed to put them in a form where they can be burned In incineration




    systems, boilers, kilns, and be used as a primary source of energy.  Billions




    of gallons are available through the waste resource.   Technology is perhaps




    the major reason.  Technology was pretty much dormant in this whole waste




    field for over 30 years.  Now the wheels are really starting to spin.  Segre-




    gation and separation techniques are improving.  Uses for waste products are




    expanding.  Who would have thought a few years ago that we would develop




    equipment to burn garbage and utilize it as a fuel.  Who would have thought




    that we would develop technology to economically extract  methane gas to be




    used as a supplement for natural gas to heat your home, from landfills.




    Another very Important factor is that, as I mentioned before, one company's




    waste product is another company's raw material.  A reputable central disposal




    facility also establishes value in this manner - acting as a clearing house




    for waste products.  How long does it normally take to establish a value for




    waste products?  If you set up your own program and have a definif method




    for the reclamation of products of value frort. your waste and a utilization




    for these products, starting today, it probably would take 2 to 3 years.  If




    you dealt with a professional central disposal facility, because of their




    experience and contacts, and if your product    fit into one of the broad




    categories that now has value,  it could be as little  as 3 to 6 months.  On




    the average, it takes anywhere from 6 months to a year and a half, if a




    value is to be established.  It also depends on the research priorities  that




    are set, and these are pretty much set based on volume of the waste products.




    In other words,  high volume products are given more research priorities.  Now

-------
there are several   advantages and disadvantages to setting up your own




program rather than doing business with a professional  central reclamation




and disposal facility.   But, at this time, the advantages of experience,




marketing, and processing of waste products,  and the fact that minimal




capital expenditure is  required,it is strongly recommended that you consider




a program with a reputable service company.  A company you can rely on will




allow you to do what you know best, while meeting your waste service require-




ment and setting up a realistic program to establish values from your waste




streams.  Also, in establishing such an alliance, you may find the central




service facility as a source for needed raw materials and products, and fuels




that you need to conduct your business.  We must not think of environmental




management as nothing but a source of cost, but now as a potential source of




a profit, as a challenging opportunity.  Our raw material resources are




finite.  We may exhaust some supplies within the twentieth century, and many




more before the twenty-second century.  The U.S. Is the most developed country




in  the world and utilizes the majority of  the  raw materials generated today.




Underdeveloped nations are catching up.  They are using our lifestyle as




their personal goals for their respective countries.  To do that, they them-




selves will use substantial quantities of  raw materials.  We need to set up




a responsible program of re-utilization to extend our supplies and expedite




our technology to find new energy sources.  Promoting the waste resourse Is




a must for your business, It is a must for your society, and  it's good for




your business.
                                218

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-------
                             WASTE  PRODUCT SURVEY
                 PLEASE PROVIDE ALL INFORMATION REQUESTED BELOW,THEN RETURN THIS FORM TO

                              CHEM-TROL POLLUTION SERVICES, INC.
               P.O. BOX 200, MODEL CITY, NEW YORK 14107 TELEPHONE 716 - 754 - 8231
                                                                                      DIVISION
                                                                          PLANT LOCATION
MAILING ADDRESS
DESCRIPTION OF WASTE PRODUCT
                                 CIRCLE  APPROPRIATE BLOCKS
PHYSICAL STATE * 70^
                                  |    SEMISOLID
                                                  ISCOSITY ®70T
                                                                   	MEDIUM
                                    MULT1LAYERED
                                                 % LAYERING BY VOLUME AT INFINITE SETTLING

                                                    	*TOP. 	i 	,  .
SUSPENDED SOLI PS

  <5%   | [   5-20%
                                                 DISSOLVED SOLIDS BY WEIGHT
                                 PLEASE IDENTIFY AND QUANTIFY ALL KNOWN COMPONENTS


NON VOLATILE ORGANICS
ACIDS OR ALKALIS
SALTS
METALL1CS
CYANIDES - PESTICIDES -
HAZARDOUS/ TOXICS
%
%
%
%
%
%
%
%
%
X
%
X
%
X
*
X
%
%
%
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%
%
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%
%
%
%
%
%

SERVICE DESIRED:
                                                       DISPOSAL ONLY
IF RECOVERY WHAT COMPONENT(S) IS (ARE) TO BE CONSIDERED FOR RECOVERY
PL    ATTACH RECLAIMED PRODUCTS SPECIFICATIONS AND ANY ADDITIONAL HAZARD AND HANDLING INFORMATION TO THIS SHEET

TO THE BEST OF MY KNOWLEDGE AND ABILITY TO DETERMINE, THIS IS A COMPLETE AND ACCURATE DESCRIPTION OF THIS WASTE MATERIAL
PHONE NUMBER (INCLUDE AREA CODE)

-------
                         POLLUTION SERVICES, INC.

      PO BOX 200, MODEL CITY, NEW YORK 14107  •  TELEPHONE 716-754-8231

      GUIDE TO PACKAGING AND  IDENTIFICATION OF WASTE PRODUCTS


Proper packaging and identification  of waste products is essential
to assure their intact arrival at  Chem-Trol,  to assure safety for
all personnel handling the material  and to assure compliance with
governmental rules and regulations regarding material shipments.
By following these guidelines you  will be  able to avoid or minimize
delays, rejections and additional  laboratory,  handling and trans-
portation charges.
A.  DRUMS

Drums must comply with ICC/DOT container and marking specifications
including the following:
    1.  Drums must have bungs in place and tightly secured.  Vented
        bungs or bungs with pressure relief should be used to avoid
        build-up of pressure.  Leave at least three inches of empty
        head space in the drum to  minimize pressurization.
    2.  Open top drums must be properly gasketed and have rings
        tightened securely.
    3.  Closed head drums with heads cut out cannot and will not be
        accepted by our drivers or plant.

    4.  Leaking or damaged containers will not be accepted by
        Chem-Trol drivers or  plant.

    5.  Chem-Trol code number and product name must be clearly marked
        on each container.  Gross, tare, and net weights are desired
        whenever possible.

    6.  Markings may be on labels, tags or stencilled onto the drum.
        Markings should be on the  side of  the drum but near the top.

    7.  Caution labels and placards  and/or precautionary statements
        (poison, explosives,  corrosive, etc.)  must be applied as de-
        fined and required by the  ICC/DOT.

    8.  Additional handling charges  apply  to small containers (e.g.
        5, 15, 30 gal. )

    9.  Drums are not normally returnable  to the customer.
B.  PALLETS. CARTONS. CASES

    1.  Pallets when used, are to  be 48" x 40", must meet Material
        Handling Association  specifications,  and will not be re-
        turned by Chem-Trol.
             A Regional Facility Specialising in trie Trtdiment of Industrial Chemical Wastes

-------
B.  PALLETS. CARTONS. CASES


    2.  Bags, cartons, cases, etc., should be covered with an over-
        pack of cardboard or plastic, and banded or strapped as
        necessary.
    3.  When two or more products are on the same pallet,  a separator
        must be used.

    4.  Palletized loads require the same markings and identification
        as to drums as noted above.

    5.  One label should be fastened to each side of each pallet.

    6.  Drums are not normally shipped on pallets.

C.  SCHEDULING A PICKUP
To schedule a pickup, simply call Chem-Trol's order desk far enough
in advance of the desired pickup date to permit timely scheduling.
Two working days is generally adequate within a 300 mile radius.

    1.  When placing an order,  in addition to standard information
        required, you should also provide us with product name and
        code, quantity of each product,  type of containers,  and
        tentative scheduling requested.    •

    2.  At that time, Chem-Trol will provide you with a Work Order
        number applicable to that shipment.

    3.  In addition to the Bill of Lading, please include with the
        shipment a packing slip containing the following information:

              Drum or container count per each product
              Product name
              Chem-Trol code number
              Chem-Trol Work Order number
        This is required by ICC/DOT regulations.

    4.  When our truck arrives at your site, our driver will be
        prepared to assist in loading, once you have placed  the
        drums on our tiuck.

        Please do not delay our driver or equipment any more than
        necessary.  He has a tight schedule to follow, and we wish
        to give our other customers the same high level of service
        desired by yourself.

    5.  Shipments may be made by customer truck or by common
        carrier if desired.  In that event, please follow
        Steps 1-3 and notify Chem-Trol of anticipated carrier
        and  scheduled arrival ahead of time.

    6.  If we can be of further assistance regarding packaging or
        identification of waste products, please contact our
        Marketing Department.
Rev. 8/12/73

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                               POLLUTION SERVICES, INC.

        PO BOX 200, MODEL CITY, NEW YORK 14107  •  TELEPHONE 716-754-8231


                            STANDARD PRODUCT DESCRIPTION

                   DISPOSAL OF PACKAGED LABORATORY CHEMICAL WASTES


 General Description:  Waste laboratory chemicals individually packaged  In labeled
                       containers made of glass, metal, fiber or plastic.  These
                       chemicals must be combined into specific code groups and
                       packaged into properly sealed and labeled DOT approved  ship-
                       ping containers, with adequate padding to assure  intact
                       arrival.

                       Each shipping container may contain chemicals from only one
                       of the following code groups A through F.

Chemical Code Groups:  Packaged Laboratory Wastes

    Group A
    (1)  Inorganic acids, (eg:  hydrochloric or sulfuric acids)
    (2)  Elements and inorganic salts that do not liberate gaseous  products when  acidified
         (eg:  Sodium chloride, barium sulfate)

    Group B
    (1)  Inorganic alkaline chemicals  (eg:  Sodium hydroxide, ammonium hydroxide)
    (2)  Organic bases (eg:  Triethanolamine, pyridlne)
    (3)  Elements and inorganic salts that liberate gaseous products when acidified
         (eg:  Potassium cyanide, Sodium Sulflde)

    Group C
    (1)  Sol  id organic compounds  (excluding organic acids and bases)  (eg: pentachloro-
         phenol, glucose)

    Group D
    (1)  Organic liquids including organic acids but excluding organic bases  (eg:
         acetone, xylene)

    Group E
    (1)  Inorganic oxidizing agents,  (eg: potassium nitrate,  sodium peroxide)
         Note: Use non-oxidizing  packing material such as vermicullte

    Group F
    (I)  Solid pesticides,  insecticides, fungicides, etc.


                                       266


                A Regional Facility Specializing in the Treatment of Industrial Chemical Wastes

-------
POLLUTION SERVICES, INC.   PO BOX 200, MODEL CITY, NEW YORK 14107  • TELEPHONE 716-754-8231

                                  STANDARD PRODUCT DESCRIPTION

                          DISPOSAL OF PACKAGED LABORATORY CHEMICAL  WASTE
    Exceptions:
    Packaging & Shipping:
The following exceptions will not  be  allowed  under this
product description:

(I)  Shock sensitive materials  (eg:   Mercury  fulminate)
(2)  Organic oxidizing agents (eg:  Benzoyl peroxide)
(3)  Pressurized gas containing cylinders  (eg:   Hydrogen
     sulfide)
CO  Materials that react violently with water  producing
     heat and flame,   (eg:  Sodium metal)
(5)  Radioactive materials of any  type.
(6)  Carcinogenic compounds of any type.

Packaged in 55 gallon non-returnable  open-head  steel  drums
with gaskets, covers, and rings to tightly seal.  A packing
slip specifically listing the contents of  each  drum is
required.  See Chem-Trol's Guide to Packaging and Identifi-
cation of Waste Products.
    Process Charges:          $80.00 per 55 gallon drum plus  freight.
                              Minimum price  $200.00 per order plus freight.

    Terms:                     Net 30 days.  Prices are  subject to change without notice.
                              Subject to Chem-Trol's  Standard Terms  and Conditions.
    Effective Date:
                              May 1,  1975
    Shipping Address:         Chem-Trol Pollution  Services,  Inc.,  1550 Balmer Road,
                              Model City, New  York  14107.   Obtain authorization to ship
                              from our  Order  Department before shipping.
   5/1/75/mlc
                   A Regional Facility Specializing in the Treatment of Industrial Chemical Wastes

-------
POLLUTION SERVICES, INC.   PO  BOX 200, MODEL CITY. NEW YORK 14107  •  TELEPHONE 716-754-8231
                 GUIDE  TO  PACKAGING  AND IDENTIFICATION OF WASTE CARCINOGENS


      All  provisions of the  general  Guide to Packaging and Identification of Waste
      Products apply to these  wastes.

      Additionally, under the  provisions  of Chem-Trol's approved disposal permit, the
      following  provisions must  be  strictly followed:

                  1.  Materials shall  be  shipped in sturdy, physically sound steel drums
      or pails with covers firmly affixed and sealed.  Containers must meet D.O.T.  re-
      qui rements.

                  2.  Any  liquid  components shall  be soaked up in a suitable absorbent
       (such as "Speedi-Dri")•   Small  bottles of liquid may be packed in absorbent inside
      an outer container.

                  3.  Waste material  inside the drum shall be enclosed in a poly bag
      liner, closed and sealed securely.

                  A.  Drums shall  be identified as per A.5., plus numbered sequentially
      on a portion of  the drum capable of being checked by the receiver.

                  5-  Three copies of the attached affadavit must be completed, signed,
      and  attached to  the bill of  lading  accompanying the shipment.

      Any  deviation from  strict  accordance with these provisions requires advance formal
      approval by Chem-Trol  based on full written disclosure of such proposed variance
      by the customer, the  reason why the variance is necessary to the customer, and
      may  require additional  affadavit and/or handling charges.

       If we can  be of  further  assistance, please contact our Marketing Department.
       10/29/71!
       ERS/fcb

       Attachment
                                             268
                                                                                     i
                                                                                       SCA ^
                                                                                     SERVICES
                   A Regional Facility Specializing in the Treatment of Industrial Chemical Wastes              SUBSIDIARY

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                                               PCS PRICE LIST

                         CHEMICAL DISPOSAL  OF POLYCHLORI NATED  BIPHENYLS   (PCB"S)

                         (Some Trade  Names  Used Are Pyranol, Inerteen,  Askarel,  Arochlor  1242,
                                                                               1254,  1260)

POLLUTION SERVICES, INC.  PO BOX 200, MODEL CITY, NEW YORK 14107  • TELEPHONE 716-754-8231
 GENERAL DESCRIPTION
 OF WASTE PRODUCT
 FOR DISPOSAL:
 PACKAGING AND
 SHIPPING:
 DISPOSAL:
                        L I QU I PS:   -  POLYCHLORINATED BIPHENYLS (PCB'S)  AS IS  OR MIXED
                                     WITH  OTHER WASTE OILS AND SOLVENTS.

                        SOL IDS:    -  CLEAN-UP ABSORBENTS AND RAGS SATURATED WITH PCB'S:
                                     EARTH OR GRAVEL FROM SPILL CLEAN-UP: CAPACITORS
                                     AND MISCELLANEOUS DEBRIS INCLUDING VARIOUS ELECTRICAL
                                     EQUIPMENT.
                        LI Q_U I PS :   -  IN  TANK TRUCK QUANTITIES AND 55 GALLON OR LESS
                                     NON-RETURNABLE STEEL DRUMS.

                        SOL I PS :    -  IN  55  GALLON NON-RETURNABLE OPEN-HEAD STEEL DRUM
                                     WITH TIGHT  FITTING COVERS.

                        SEE - GUIDE TO  PACKAGING AND  IDENTIFICATION OF WASTE PRODUCTS
                              FOR  UNUSUAL PACKAGING REQUIREMENTS.

                        IN  ACCORDANCE  WITH  STATE  AND  FEDERAL POLLUTION
                        CONTROL  REGULATIONS.
PRICING:
     Con_ta i ner

     Bulk, T/T

     Drums,  55 gal Ion  *

     Drums,  less  than  55  gal.-
                               LIQUID PCB PRICE SCHEDULE

                                  Contract Price

                                  $0.07 per pound

                                  $52.00 per drum

                                  $35.00 per drum
Non-Contract Price

$0.075 per pound

$54.00 per drum

$37.00 per drum
     * - Minimum 15  drums;   14 drums or less add $25.00 handling,   Minimum order $200.00.

                               SOLID PCB PRICE SCHEDULE

     Bulk ''"•
     Drums,  55 gal Ion  *
                                  $5.00 per cubic foot
                                  $28.00 per drum
      Cu Ft.  $6.50/Cu.  Ft.
 >50 Cu Ft.  $5.00/Cu.  Ft.

$30.00 per  drum
     * - Minimum 15  drums;   14 drums or less add $25.00 handling,  Minimum order $200.00
     ** - Pricing  based on outer measurement of overwrap or  array.
TERMS:
                     NET  30 DAYS - F.O.B. MODEL CITY,  NEW  YORK,  PRICES ARE SUBJECT TO CHANGE

                       CHEM-TROL POLLUTION SERVICES,  INC.,  1550 BALMER ROAD, MODEL CITY, NY

EFFECTIVE  DATE:         NOVEMBER 15, 1975
  IIPPING ADDRESS:

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                                              ORDERING PROCEDURE
POLLUTION SERVICES, INC.   PO BOX 200. MODEL CITY, NEW YORK 14107 « TELEPHONE 716-754-8231


      Customers are asked to  follow this procedure in order to be assured of timely,
      coordinated service:

         1)   To order a pickup by Chem-Trol's vehicle, or to schedule a delivery by
             customer's own vehicle or carrier, please telephone Chem-Trol during
             normal  business  hours.

         2)   Ask the Chem-Trol operator to connect you with the Sales Order Department.
             She will connect you with Mr. Clyde MolIon or Mr. Jim Hattler who will
             take your order.  In their absence, you will be connected with Mrs. Balcom.

         3)   Be prepared to provide the following information:

                   Customer Name and Address
                   Your name  and phone number
                   Purchase Order Mo. or other authorization
                   Name of  Waste Product (s) and Chem-Trol Code (s).
                   Quantities of each Product, Container Type, Date,
                   Time, and  Specific location of pickup (or Delivery).

             On receipt of  this information, you will  be assigned a Chem-Trol Work
             Order Number.   Please make note of it and refer to it in all subsequent
             communications regarding the transaction.

         A)   If it is not possible to meet your desired schedule, Chem-Trol will
             promptly call  you back to discuss best alternatives.

         5)   See also Chem-Trol's Guide To Packaging & Identification of Waste Products.


      Outside of Normal Work  Hours

         1)   The main plant phone number (716-75^-8231) is in service 2k hours a day.
             For emergency  service or service requiring communication during off hours,
             telephone this number only.

         2)   Tell whoever answers that you wish to place an order for pickup.  Determine
             to whom you are  speaking.  Provide all information as requested above.   If
             you do not receive Immediate confirmation, or confirmation within a
             reasonable time, follow up with another phone call.

         3)   Home phone numbers for Emergency Use if unable to reach the plant are:

                   7l6-7'»5-37'l7    Terry Hailey, Transportation Manager
                   7l6-63
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CHEM-TROL POLLUTION SERVICES, INC.
Subsidiary of SCA Services, Inc.

P. 0. Box 200, 1550 Balmer Road
Model City, New York  14107
(716) 754-8231
      BACKGROUND

       A)  Services provided
            •  Collection/Hauling
            •  Recycling/Reclamation
            •  Processing/Treatment
            •  Disposal
            •  Oil/Chemical  Spill Clean-up - Tank Cleaning
       B)  Service Area - U.S.  and Canada
            •  Chiefly 30 Eastern States,  Ontario, Quebec.
       C)  Date established - 1969
       D)  Licensed by - New York State
            •  Supplemental  collection/hauling permits throughout areas served.
       E)  Organizational structure - wholly owned Subsidiary of SCA Services,
           Inc. of Boston (as of October  1973).   Originally located at Blasdell,
           N.Y.  Relocated  to Model City, N.Y.  in 1972 to accommodate rapid
           growth.  SCA/Chem-Trol Sales Offices  throughout U.S.  and Ontario.

       WASTE STREAMS
       A)  Accept - Most types of chemical-related wastes including solvents/
           cleaners, halogenated hydrocarbons, paint f, coatings  sludges,  oils
           and oily waste, toxic acids,  alkalis,  plating/etching wastes,  cyanides,
           heavy metal  solutions £ residues,  pestlcides/PCB's, carcinogens,
           sludges & solids, arsenic and mercury  wastes.
       B)  Exclude - Radioactive wastes, shock-sensitive  wastes  & explosives
       C)  Volume - Capacity in excess of 100 million gallons annually at
           Model City facility.

III.    WASTE HANDLING

       A)  Collection/hauling - 12 tractors,  25 assorted  bulk tankers, 16 closed  van
           trailers, 4  vacuum trucks available.  All  in compliance with D.O.T.
           Regulations.
       B)  Receiving storage - 24 hour operation
            •  Receive by truck, common carrier, and rail  in  bulk or drum  form
            •  2.0 million gallon tank storage
            •  6.7 million gallon lined lagoon storage.
            •  25,000 drum storage area.
       C)  Laboratory analysis
            •  Modern well-equipped facility,  advanced instrumentation.
            •  7 B.S.-M.S. Chemists,  1  PhD,  Biologist, 4 Technicians
            .  5 B.S.-M.S. Engineers  (Chemical, Environmental)
            •  Perform R  & D, Quality Control, Process Control, Waste Product
              evaluation
            •  Over 18,000 waste materials analyzed/evaluated to  date.
            •  Pi lot plant faci1ity.
            •  Close to  $100,000 in Laboratory Equipment and  Instrumentation  with
              additional purchases anticipated.


                                      (D        2Si

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       D)   Treatment  -  Depending  on  composition,  volume  and  economics,  wastes
           are processed for resource  recovery with disposal  of unrecoverables.
           l)   Chemical  detoxification
                 •  Firm employs a patented  neutralization  process  for acids  £  alkalies.
                 •  Company has developed  and  used proprietary physical/chemical
                   detoxification technology.
           2)   Chemical  Fixation  - Stabilization  and fixation process using  pro-
               preitary chemicals with wastes  in  a reactor vessel.
           3)   Recovery processes employ  distillation, centrifuging,  settling,
               decanting and/or blending  techniques to recover saleable materials
               (e.g., solvents, fuels, oil  and inorganics).
           4)   Incineration  -  Only approved PCB incinerator in New York State.
                 •  Liquid injection  thermal  oxidizer (@2700°F or greater)
                 •  Alkaline gas scrubber  removes  air contaminants  and cools  effluent
                   gas  to 180°F.
                 •  Operates 2k hrs./day for 60-120 days  then  shut  down  for maintenance.
       E)   Controlled Landfill
              Reinforced membrane-lined clay  cells that  receive solids, sludges,
              and chemically fixed wastes.
              Internal  sump within each cell  collects liquids for treatment.
              3 - dimensional  inventories of  buried wastes are maintained for
              possible  recovery at later  date.
       F)   Wastewater Treatment - Complex physical-chemical  wastewater  treatment
           facility followed by biological  treatment.
       G)   Technical  Services  - Assistance  offered in preparation,  identification,
           and packaging of wastes for safe shipment, storage, and  processing.

IV.     ECONOMICS

       A)   User costs vary greatly in  accordance  with recovery values and
           processing requirements.
            •  Transportation charges stated separately.
            •  Company purchases many recoverable  wastes.
            •  Many bulk liquids disposed  in 5"20< gallon range.
            •  Scientific Landfill of chemical  residues with  leachate collection
              and processing.   $10.00  - $15.00 per drum  base price.
            •  Packaged  laboratory wastes  accepted.  Pricing  depends  on
              composition and packaging.
            •  Accommodation made  for small  and large volumes.
            •  Hazardous/toxic wastes more expensive.

       B)   Costs - Custom facilities were constructed by modifying available equip-
           ment.  Company estimates $15-20  million capital costs to duplicate  in  1975-

       C)   Resource recovery constitutes  over hO% of current business.   Percentage
           of reclamation expected to be  70% within 5 years.

       D)   Percent capacity - currently below 50% of available capacity, growing
           rapidly.

       E)   Expansion potential  -  Actively considering sites  and markets  in several
           industrialized states.

V.     COMMENTS - Firm operates  total  waste handling, disposal, and resource
                  recovery facility for chemical  wastes.

                                                  *"* <*") ^
                                                  s.3^
11/15/75
mlc

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Chemical Wastes
                   Stressing Safety
                  Makes Extensive
                   Recovery Viable
                       Reprinted From
              June 1975 Issue Solid Wastes Management Magazine
                       2S3

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Louis E. Wagner Is founder and presi-
dent of  Chem-Trol  Pollution Services,
        Inc., Model City, N.Y.
      Any  company attracted to the
      challenge of handling chemical
      discards should be prepared to
cope with the demands of an irresistible
force, safety. There is no casual way to
deal with potentially hazardous mate-
rials —  around  every  comer, behind
each problem, waits a safety consider-
ation, ready to draw the wastes man-
ager deeper into  this  highly special-
ized 6eld.
  One firm, Chem-Trol Pollution Ser-
vices, Inc.,  located in the  Buffalo sub-
urb  of  Model City, NY, began to
tackle this  challenge  six years ago.
Simply by attempting to eliminate the
dangers  in  handling a wide spectrum
of chemical wastes, the company grew
in vanous directions. In the process, it
not only relieved the industries con-
centrated in the Niagara Falls area of
many of their troublesome discards, it
also gave a dramatic demonstration of
the economic viability of resource re-
covery in  the liquid wastes  field.
  Chem-Trol's  president, Louis  E
Wagner, founded  the  company  in
1969, starting out on a modest site of
approximately 20 acres in the Blasdell
area, just south of  Buffalo. Acquired
by  SCA Services,  Inc. in 1973, the
firm is now a wholly owned subsidiary
of the national  corporation.
  During the  first  two  years  at the
Blasdell site, the  operation  concen-
trated on the disposal aspects  of the
business. When poorly packaged ma-
terials began to arrive with improper
labels, the firm saw that it was essen-
tial  to  have its  own  transportation
component.
  Recognizing the enormous  chemical
and energy values  contained  in the
wastes,  Chem-Trol shifted its orienta-
tion to  reclamation activities, follow-
ing its move to the Model City site in
1971 A large stainless steel distillation
tower, installed at the new  location,
formed the  nucleus of a refinery opera-
tion, so  that the company could func-
                                      Chemical  Wastes

                                              Stressing  Safety   Makes
                                           Extensive   Recovery   Viable
tion as a chemical processing facility.
  Currently, the firm accepts materi-
als originating from Maine to the Gulf
of Mexico, and receives quite a bit of
business  from  Canadian  industries,
too.   It  collects  chemical  wastes,
processes them  into marketable sub-
stances and usable energy, maintains
careful inventories,  manufactures  its
own  products  and  scientifically  dis-
poses  of all  residues.  The  tech-
nological capabilities of this complex
operation allow it to harness the liquid
wastes stream  in a manner that ap-
pears more advanced than anything
practiced in the solid wastes  field.
  The hauling of chemical discards is
a specialized service that the common
carrier simply  is  not  equipped  to
handle. There are obvious problems in
transporting wastes products in trailers
that  may be  subsequently used to
carry such items as food.  Trucking
firms  are reluctant to  handle these
consignments for many reasons, the in-
experience of drivers, the mandatory
paperwork, the  very real  possibility
that certain chemicals could leak  and
damage even the metal parts of the
vehicle, and other related problems
  Early on, it became apparent that if
Chem-Trol  expected to receive large
quantities of chemical discards, it had
to provide many  wastes  generators
with a safe and assured means of get-
ting  such material  to the  site.
  Today, deliveries are made by a va-
riety of means  Some customers ship
by rail or send their own trucks; sub-
stances in drums or packaged in an
approved  fashion  are  collected  by
Chem-Trol trucks and personnel; bulk
liquid  materials  are hauled in tank
trailers, owned by the company. In all
cases, the nature of the  loads requires
constant maintenance and repair of all
vehicles.
  During transport, proper packaging
is always important. The very fact that
these matenals are being sent to a cen-
tral processing facility for appropriate
disposal or recycling, indicates a con-
cern  that they don't escape back into
the environment, All shipments, even
solids such as pesticides and agricul-
tural chemicals,  must be properly cov-
ered in containers, sealed or packaged
according  to  U.S   Department  of
Transportation standards.
  Large quantities of pumpable mate-
nals are generally carried in the bulk
tankers — oily wastes from refineries
or acids from metal working facilities
fall into this category. Sludges that are
too thick to pump would  usually  be
placed in  55-gallon  drums, the stan-
dard for the chemical wastes industry.
Products in a solidified form would be
packaged,  according to accepted prac-
tice, and taken to the site by  vans
Care is taken so that even if the true
were to tip  over in an accident, the
chemicals  would not mix  or escape
  The company nevei agrees to trans-
port a wastes product, or even accept
a shipment, unless it knows the char-
acteristics  of the material  in advance
All  potential  customers are asked to
complete  a  wastes  products  survey
form, providing all information, on a
"best effort" basis, relating to the com-
position and quantity of the matenal
under  consideration.   They  are
required to state any known hazards
associated with the component sub-
stances, and report all safety precau-
tions practiced  at their own facility
Safety is the most important consider-
ation, and Chem-Trol  wants to  make
sure that it can handle the wastes at
least as  safely as the personnel  at the
customer's plant.
  Based  on  the survey  data, the
Model City  operation  makes a  deter-
mination as to whether it can process
the  wastes.  At  this  point, either a
sample or a  trial shipment is solicited
and the actual material is analyzed by
the firm's  laboratory staff. The  imme-
diate acceptance of a trial shipment is
a practice limited to cases in  whic'
the firm is familiar with the product,
process  and generating industry.
  The laboratory not only checks the
accuracy of the submitted data, but
tests to  see whether the substance is

-------
 hazardous  in  ways  not   reported,
 checking for characteristics that could
 cause  processing  difficulties,  safety
 risks or possible damage to equipment.
   After  these steps are  completed, a
 description  of the wastes product  is
 submitted to the customer along with
 a  proposal  to  process  the  material
 under contract. From that point on, all
 shipments are sampled to make sure
 they conform to the description con-
 tained in the contract.
   When pickup is made by one of the
 Chem-Trol  vehicles, the drivers are
 prepared in  advance,  so that  they
 know  what's in  the load,   how  to
 handle it, and whether to accept the
 shipment Most of the drivers have the
 capability of sorting the wastes and
 determining such  character!sties  as
 whether the material is acid  or alkali.
 Where   appropriate,  they   are  in-
 structed  to use such safety equipment
 as face shields, and rubber gloves and
 coats
   The trucks are marked with plac-
 ards,   as   required,  and   carry   a
 manifest descnbing the load, following
 the same DOT rules applied to the
 transport of primary commodities.
   If the driver  encounters   matenal
 that  is  not  properly  packaged  or
 marked,  he  is not permitted to accept
 the shipment; when other firms trans-
 port such non-conforming matenal di-
 rectly to the plant, it normally will not
 be off-loaded. In cases where a check
 by production people or analysis by
 the laboratory indicates that  the in-
 coming  chemicals  were  incorrectly
 identified, the expense of finding out
 what actually is in the drums must be
 borne by the customer.
   It is company policy not to accept
 any radioactive material 01 loads that
 may  explode  due  to  sensitivity  to
 pressure  or shock.  Excluding these
 two categones, the operation  is able to
 process 99% of the products offered to
 the company  for disposal.
   Those matenals that are accepted at
 the plant are identified  by code and
 enter the firm's exact process invento-
 ry. From this  point on,  the  precise
 location   of each  product   can  be
 quickly  determined  by company per-
 sonnel. Storage facilities for  bulk de-
 liveries  consist of approximately  1.5
million   gallons  of  closed  tankage,
 ranging from 3,000 to 35,000 gallons
per tank
  The storage tanks are constructed of
 a  variety  of  materials,   including
carbon and  stainless steels,  glass and
 rubber linings, and  resin coatings  —
 different   products  are  assigned  to
 tanks  based  on their chemical charac-
teristics.
  Separate storage facilities are main-
tained for incoming wastes, feedstocks
for various  recovery processes,  and
tanks for the finished products that the
This 40-tray stainless steel distillation tower represents one of the processes by
which  Chem-Trol recovers  the  chemical  and energy values of incoming wastes.
company  manufactures and  markets
   Chemical   discards  from   many
sources are held in the inventory until
they can be utilized by the process in
a  smooth and  practical way
   From   the   customer's  viewpoint,
sending the wastes  to  a  central pro-
cessing site eliminates secondary ef-
fluent problems, and the  need to test
and monitor the bothersome  discards.
Shipping  the  wastes  out effectively
transfers a problem, allowing the man-
ufacturer  to  concentrate on  more
primary and productive concerns
   Chem-Trol,   however,  sees   the
wastes  products  in an entirely dif-
ferent  light.  The ability  to  collect,
store and  refine large  volumes of dis-
cards transforms the wastes into useful
raw  materials.  Large  quantities  of
waste acids, for instance,  can be used
to neutralize discarded alkalis, should
a manufacturing company attempt the
same process, raw matenals would
have to be purchased and the problem
of secondary  effluents would  have to
be  faced
  Separate  consideration is  given to
each  of the more  than 2000 wastes
products that are regularly accepted at
the  facility.  Some  require  pretreat-
ment, some do not.  Where necessary,
matenals are  converted either chemi-
cally or physically into forms that can
be co-mingled with othei materials for
joint treatment.
  At the Model City site, the empha-
sis is .ilways on recovery  This  thrust is
indicated by the fact that when a par-
ticular lot  is  ready  to be  processed,
"manufacturing   instructions"   are
                                                             2S5

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Chemical Wastes
      Reuse  Strongly  Emphasized;
      Disposal  Considered  Last  Resort
placed on the waste substances.  Dis-
posal  is  considered only as  a  last
resort. Even when material is  routed
to the landfill, a thiee dimensional in-
ventory is  maintained,  showing  ex-
actly  wheie everything  is buried, so
that at a future date the material can
be retrieved  and further worked by
new  technologies.
  One resource lecovery process used
at the facility is fractionating  taking a
nmtuie of waste matenals and  sep-
aiatmg  the   component  parts   ac-
cording to physical piopeities in a
boiling situation. This takes place in a
stainless  steel   distillation   towei,
equipped with 40 trays The process is
based on the theory that eveiy mateii-
al has a specific boiling point and will
come off on  one of the trays.
  Heat is applied at the bottom and as
material nses through the tower it gets
cooler, allowing substances to be sepa-
iated  on the  basis  of then  different
boiling  temperatures.  Material  that
boils  .it the lowest  temperatures  will
rise highest, condensing only when it
i caches the trays on the top  of the
tower, wheie the temperatuies  are the
coolest   Heaviei   materials,  that
lequire high temperatures to come to
a boil,  will  condense closei  to  the
sou ice of heat in the bottom  of the
tower
  Materials  lecovered  through   the
piocess are circulated for blending, to
make  sure  that they  are  unifoi m
thioughout. A sample is  taken to labo-
 latoiy foi analysis to ascertain that the
product meets specifications, iind then
it is  muiketed back to  industry.
  Some of the leelaimed matenals can
be sold to industry on the basis  of then
chemical values, others  ate lecoveied
foi then eneigy value and marketed as
specialized industrial fuels, part of the
film's Tiol-Fuel family  of products
  These liquid mels aie composed of
 mixtures of solvents, oil-type matenals
 and  othei  chemical  wastes.  A   few
 yeais ago,  such waste pioducts  were
 fed into the facility's thermal oxidizei
 and  burned
  Tiol-Fuels aie not chemically iden-
tical to fuel oil and lequne some modi-
fications  in  the  t ustomei 's stoi age,
handling,  pumping  and  burning
 systems Once the conversion is made,
 the buyei can utilize both Tiol-Fuels
 and  regulai fuel oil The savings are
 such, the company claims, that the in-
vestment is paid back within a yeai.
  Marketing  efforts  are aimed pri-
marily at the industries which supply
the waste materials in the first place
Edward R  Shustei, manager of tech-
nical  services and  market  develop-
ment, explains a manufacturing com-
pany is offered a total wastes progiam
in which its discards are piocessed and
a specialized industrial fuel is leturned
m place of the wastes As such,  about
seven million gallons  of Tiol-Fuels are
now being sold in bulk quantity
   Generators of wastes
       provide market
     for  recovered fuels
  Wastes that have no leuse value aie
fed into the facility's thermal oxidizei,
where combustion takes place at tem-
peratures in the range of 2200-2700
degrees Fahrenheit.  This process is
fueled exclusively by othei wastes ma-
terials  and reduces  all substances to
caibon dioxide  and water which  aie
released into the atmosphere, 01 mate-
nals of an oxide 01 acid form which
are scrubbed  out, creating a  small
amount of sludge.
  In  the  thermal  oxidation process,
there is an area of intense heat, where
the burning takes place, and a second-
ary  zone,  where  waste  water  is
sprayed to cool the gases,  in order to
render  them   scrubbable   In  this'
manner,  large  quantities  of  waste
water are constantly  being processed
as hot gases burn out all organic com-
ponents  and convert  the  water  to
steam.
  Othei  material  is piepared for dis-
posal by the neutralization of its acid
or alkali natuie
  Only  innocuous  solid   matenals,
primarily inorganics, are placed in the
landfill  Some contraction takes place
as the pioportionally small  amounts of
oiganic materials,  buned  in the fill,
convert to caibon  dioxide  and  watei
  The landfill,  itself, lests on 55 feet
of solid clay  and  reinforced hypolon
liners are installed  in each  excavation.
Thus,  the thiee-dimensional cells  —
much  like swimming  pools —  aie
sealed to pievent leaching.  During fill-
ing,  any rainwater that gets into the
cells is withdiawn thiough a vertical
standpipe and tiansferred to the com-
pany's aqueous  wastes treatment facil-
ities.  Once the chambers  have been
filled and capped  with  clay, the rain-
water can no longei penetrate the dry
cells' but runs off into ponds  These
ponds serve as  a lesource, since they
provide watei in case of fiie — so far,
they haven't been needed. This water
is tested on a regular  basis.
  The  company's  advanced  watei
treatment process is so complete that
the discharge is leferred to as lecycled
watei  rather than treated industrial
wastes  The chief chemist  is so con-
fident of its punty that he dnnks some
on  occasion.                      •
The limited number of discards that have no reuse value are generally fed into the
           thermal oxidizer and burned at 2200-2700 degrees Fahrenheit
                                                       2SB

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               MR. LEHMAN:  Thank you, Mr. Shuster.   Do




we have some questions?  Mr0 Sanjour?




               MR. SANJOUR:   Mr. Shuster, both you and



everyone else in the waste disposal business who has been




up here today, has referred to the prime difficulty in




your business as competition with shady   waste disposers^




And, since there is no one here from the shady waste



disposal industry, I wonder if you could elaborate, for




your entire industry, if you would like, to just what




specifically do you mean by this kind of competition?



                          2S7

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               MR. SHUSTER:  Okay, I would like to quote
from Bill Burns, from the Department of Transportation,
who is looking into that aspect of hazardous wastes and
did visit our site and spent several days with our people,
learning about hazardous wastes.   He subsequently made
a comment at a public meeting, I believe it was in
Washington or else in Atlanta, to the effect that, there
are approximately 80 businesses in the Buffalo area that
do plating, generate plating wastes, and very few of these
people are using our services.   Now, everything has got
to be someplace, you tell me where it is going.  We know
where it is not going, it is not coming to us.
               I can't site authoritatively.  There are
cases where the generators themselves don't know where it
is going.   We have always put it into this strain and
we still are.   There are cases where material is being
landfilled, that in our feeling should be treated, should
be processed prior to landfilling.   This is a substantial
part of it, there is more of/-it that is going into sewers,
in areas which are not served by modern secondary ,  tertiary
treatment plants, where these things may be getting some
kind of a crude pre-treatment, or possibly   'st discharged
raw.   And these things will come to a screeching halt once
the generators are forced to pre-treat effectively at
their own plant and put this through a Plant where they
                          2S8

-------
are going to be charged based on the parameters under the
water regulations.
               MR. LEHMAN:  Mr. Lindsey?
               MR. LINDSEY:  On page 2 of your statement
you say government should also consider incentive programs
to encourage voluntary compliance.   Would you elaborate
a little bit on what you see happening there?
               MR. SHUSTER:  There are a number of these
type things, to some degree some of these are being prac-
ticed now.   We looked at tax incentives, in the form of
rapid depreciation allowances, tax relief on processing
equipment.   You'd look at such things as the environmental
bond programs where you would get a government guarantee
behind your money.  You would pay it back over a period
of time.  These are just some ways.   The transportation
aspect of it would be a substantial benefit to encourage
people to ship wastes long distance to a processing cen-
ter.
               MR. LEHMAN:  Mr.  Kovallck?
               MR. KOVALICK:  I guess that sentence is
full of interesting thoughts.   I'll finish it and ask you
about it.   You say:and eminent domain actions where
needed to assure appropriate siting of processing centers
and disposal sites based on technological factors.  That's
one of the first comments,we have had today,  which I re-
                            239

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     late to one of our discussion questions,  14 on mechanisms



     and experiences for soliciting acceptance of hazardous



     waste facilities.   Could you comment on that, since you



     have apparently suggested a fairly extreme solution.




                    MR. SHUS'iER:  I think this is going to be




     covered to a great degree by NSWMA.   Birt as we a11 know,



     not only in the hazardous waste business but simply in



     the matter of landfills and solid waste resource recovery



     plants, the difficulty that we have encountered with



     local governments, regional and county governments, in



     getting the necessary local approvals to put in a facili-



     ty of this type, and this is probably true in spades in



     the hazardous waste treatment business.



                    Now, our plant happens to be built on the



     site of an old  TNT plant, and there is a rocket engine



     test center next to it and the Atomic Energy Commission has a



5lace just to the south of us.   But, had we not moved into an



     area that had the ideal geology and geography, market



     location and previous use and appropriate zoning for this



     kind of thing, I think it was once in a million lucky



     fluke that we found this kind of site that we are in.



     I know other people that are in this type of business,



     other people that have probably spoken today, have had



    troubles with their existing plants, with the feeling that



     they are a bad neighbor in the community.   There is out-





                               300

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 right  pressure on  them either to go  somewhere  else  or  to




 disaopear. But, as long as we want the marvelous  consumer




 goods, that the marvel of the present day technology,




 chemical manufacturing gives us, we  are going  to  have  to




 address the subject of the wastes that come along with




 them,  and place these plants where they need to be.    They




 need to be placed where the geology, where the land use,




 where  the population, a whole block  of parameters are




 appropriate.  And, you go through all this and then a




 local  township or a county or some local unit of municipal




 government says, well we don't want  that here.




               We need to resolve that and one alternative




 solution is eminent domain, by the state, placing this on




 federal lands, which I think has been suggested on occa-




 sion in the past.




               Does that answer your question?




               MR. KOVALICK:  Yes, thank you.




               MR. LEHMAN:  Mr. Lindsey?




               MR. LIKDSEY:  One more if I may.  You have




 advocated the use of private enterprise to, as a mechanism




 for treating and disposing of these types of wastes.




 You have also indicated that landfills are, at least at




 the present time, a part of this whole scheme as you see




 it.  Given both of those things, could you comment on how




we could insure perpetual care of these facilities,

-------
permanent monitoring for the long haul, things of that



nature?



               MR. SHUSTER:  I don't have all the answers.



One way in which we can do a simple record keeping Job



on where these sites are for future generations, who will



probably go on long after all of us, is through recording



this kind of information in the deeds on the property,



where the recorder of deeds or the county treasurer,



whatever office it is in your area that keeps track of



the land, to record the fact that areas where residues



from hazardous waste material processing have been buried,



what is in there, at least in generic terms, and the loca-



tion and so on.  The kind of provisions that are made.



               The best situation, if we had our brothers,



would be to put these in places where they would take



care of themselves after  awhile.   And in order to do



this you have to do a substantial amount of treatment, to



put them into a form, as I have mentioned, which would



be compatible with the aivironment you are going to put



it into.    If you are going to solidify and fix heavy




metals, which can be done, and you are going to put them



in the ground, you want to put them in the ground where



they are not going to be reacidified and dissolved and



subjected to that kind of forces.    Now, we can't really




predict natural forces.    We have some pretty good predictc





                       3U2
rs

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but we still have uncertainty factors on them.  This would
be an example.
               MR. LEHMAN:  Another question?  Mr. Newton?
               MR. NEWTON:  A question from the floor, Mr.
Shuster.   Is there any noticeable difference between the
quantities of wastes you are receiving  from states with
regulations or strong regulatory programs than those you
receive from states without such programs?
               MR. SHUSTER:  A leading question.  Certain-
 ly this is a factor.  Distance is a factor to some degree

I think that by and large once you get outside of your
backyard market, that your business relates largely to
the corporate citizenship attitude of the companies you
are doing business with.    They are willing to make this
kind of additional voluntary investment in doing the job
right.   And, in working with us, certainly we haven't
done all there is to do, and we are continuing our re-
search and development programs and the dollars that these
companies pump into our company, helping to support this.
And, so, for this reason, I think that overwhelms the cur-
rent regulatory aspect of it, to some degree.
               MR. LEHMAN:  Did you have another question,
Mr. Newton?
               MR, NEWTON:  Also from the floor.  Are you
in favor of Federal hazardous waste legislation versus

-------
state legislation with reference to the NSV7MA guidelines?




               MR. SHUSTER:  Okay, the NSWMA, we are now




going into blindly, an(j  j wasn't in on HIP  inception of



this, but I know that the people in the Office of Solid




Waste Management programs have been, at least informally,




over the back fence, involved in these things and they




have put some personal comments in and things of this




sort.   So, I don't think that the NSWMA guidelines are




contrary to Federal "druthers".




               The desirable aspect of having Federal IRQ-



islation here would be that the hazardous waste political




community would be then taken out of the realm of state




borders, where we feel that there has got to be a smooth




inner flow ofrastes from one state to another.




               There are cases now where the whole trans-




action takes three or four states to complete, and so




Federal legislation could aid on that basis.  I think




NSWMA, and I can't speak for them, but from my own inter-




pretation is advocating these guidelines to states, be-




cause many states are moving ahead prior to Federal legis-




lation being on the books and it would be nice if the




states do move ahead, if most states had systems where




the forms were at least a little bit alike  lnd the pro-




grams were similar in their functional aspects, so that,




for example, the manifest documents, that are generated in

-------
one state and went to a processor in another state, that




it would be the same kind of a form that he would get




from the other states he is doing bulness in.   We are do-




ing business in over 30 states now.  And, the paperwork




could get very hairy.




               MR. LEHMAN:  Mr. Shuster, I have a ques-




tion.  One or the discussion topics that we wanted to




talk about today and hasn't been raised so far, I'll raise




it with you and see if you have any comment.   It concerns




the Federal government itself as being a generator of




waste, and the question would be, has your company ever




been approached by an agency of the Federal government to



have its wastes processed by you, and if so, under what




conditions was that carried out?




               MR. SHUSTER:  We regularly and routinely




do receive and process a number of industrial wastes from



various Federal  agencies, including Air Force, Army, EPA




themselves, there is a long list Of them and we could pro-



vide you that list.  There is more of a need for this.




For example, the U.S. Government operates the largest plat-




ing shop  in the world at the San Diego Naval Base in




California, and so there is a great need for that there




as well.



               I have spoken to a few people from EPA





laboratories about  what do you do with vour laboratory



                         3G5

-------
wastes and there is not without some shuffling or the feet
before we get the straight answer, and the answer is, we
are glad to know about you fellows.
               So, as it goes, everybody has wastes,
there are household wa&es which once you take them out of
the aerosol can, the housewife throws in her garbage can,
are hazardous chemicals by definition.
               MR. LEHMAN:  Okay, are there any other
questions?   I guess not.  Well, thank you very much, Mr.
Shuster.   Next I would like to call Mr. Warren Kinsman
of the Atlantic Terminal Corporation.   Is Mr. Kinsman
here?  Yes.
               MR. KINSMAN:  Gentlemen, I'm going to di-
rect my talk to primarily one phase of waste and this is
lube oils.
               My name is Warren Kinsman, Atlantic Termi-
nal Corporation, we are a wholly owned subsidiary of the
A. Johnson & Co., Inc.  It is also an affiliate company
of C. H. Sprague Co., well known marketers,, of heating
fuels in New England.  We are a diversified company with
interests in many fields.  However, petroleum and petro-
leum related activities are our primary business in this
area.
               Reclamation of waste oils has rapidly be-
come one of our major objectives, especially with the

-------
current concerns towards environment and conservation.




               Our oil reclamation unit has been 5 years




in developing, having done extensive research and develop-




ment work in Ventura, California.  Upon perfecting it,




our first commercial size unit was constructed in Newingtor




New Hampshire in 1974.  It is still being used consider-




ably for extensive R&D work, as well as commercially




treating waste lubes and oils.




               The unit itself, in very basic terms, is a




thermal distillation process for reclaiming waste oils.




It has several unique features that make it the most ef-




ficient and effective way or recycling used lube and




waste oil in the country today.  It is a completely en-




closed system, and every precaution has been taken to




make it the cleanest and most environmentally safe unit




in the industry.  We have welcomed many visits from both



state and Federal E.P.A. people, and have received nothing




but praise regarding our entire operation.



               Contrary to the outdated acid-clay method




of treating waste lubricants, we have much greaser flexi-




bility with our unit.  It has tremendous emulsion break-




ing capacity and allows us to handle a wide variety of




feedstocks.  To date we have effectively handled waste




crankcase oils, tank bottoms, a variety of industrial




slop oils, ship bilges or bottoms and oil from various

-------
 spills.  We do not produce quantities of contaminated
 acid-clay that present a disposal problem.  Our system
 is also designed to produce more than one type of
 finished product, allowing us great versatility in meet-
 ing market conditions.  Our intent, in the near future,
 is to batch process oil from industry and return them in
 their original state, at a great cost saving, with con-
 servation of a valuable natural resource a major aim.
               While we are able to handle most forms
 of hydrocarbons, it should be noted that there are sever-
 al items we cannot, or will not accept.  They are as
 follows:  chlorinated hydrocarbons, volatile solvents,
 some cracked hydrocarbons, synthetic oils, coal tar and
 their derivatives and water soluble oils.
               Naturally, on any questionable products,
 we have the ability to do a complete lab analysis prior
 to acceptance or denial.  Our lab is equipped to handle
 the entire range of hydrocarbon products, from light hydro
 carbons, such as methane, ethane, etc., to heavy residuals
 such as Bunker-C or asphalt.  We have some of the most
 modern equipment available for many tests, and are uni-
 que in New England for our depth of analytical coverage
 for hydrocarbon analyses.
               In addition to routine analyses our staff
(two chemists and several technicians) conduct research

                        3u8

-------
amd development work on new methods for converting wastes




into assets.  Our R&D equipment includes:   Atomic Absorp-



tion Spectrophotometry, Gas Chromatography, X-ray



Flourescence, Spectrophotometry and Column Chromatography,




to name a few.



               Lastly, we have a complete effluent analy-



sis lab, which includes a state-of-the-art, two minute



automatic analysis for Chemical Oxygen Demand, as well as



the usual Biological Oxygen Demand, Oil & Grease, Total




Suspended Solids, PH, etc.



               Reqardirujthe actual operation of the Oil



Reclamation Unit, our gross energy balance is a very



favorable 6% or 6 gallons of fuel necessary to process



every 100 gallons of waste oil.  Our average recovery



rate of usable products is 90%, after deducting bituminous



solids and water from the feedstock.  Naturally, these



figures can vary some depending on type of feed and de-



sired end product.   Our existing process capacity is



43,000 gal/day, however, the unit can be expanded if



volume of feedstock demanded same.  We currently operate



in a tank farm area containing over 1,000,000 bbls of stooge.



Of this, we currently have 42,000 bbls allocated to waste



oil.  This allows us to handle large volumes at any one



time.  The bulk of our product comes in by truck, but we




do have the capability to bring in barges at our deep





                         309

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water facility.




               Our company is totally committed to waste




oil recovery.  Our opinion is that hydrocarbons are too



valuable a resource to be used as road oil, or indiscrimi-




nately burned.  It should be put to its best possible



use if we are to conserve our own resources and become




less dependent on foreign supplies, as well as protect




the environment in which we live.




               Already, many areas of the country are




passing laws prohibiting road oil use, and the indiscri-




minate burning of crankcase oils.  It is only a matter of




time when these same laws will be passed in New England.




There is much proven evidence that road oil and burning




of untreated oils put thousands of tons of toxic materi-




als into our air and water streams every year, and do noth




ing to conserve petroleum.  Rigid controls are necessary




regarding hauling, disposal, and end use if we are to




obtain these goals.



               Only a coordinated effort by industry,




State and Federal government  and the public at large



will help us attain these goals.  Generators of these




waste oils and lubes must be made responsible for the




way in which they are disposed, going only to government




approved disposal facilities, keeping in mind that again,




they should be reclaimed whenever possible.  These







                             310

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generators  should bear full responsibility cf any  costs
or fines accrued for  indiscriminate dumping whicn would
 affect the  environment or create a loss of a natural re-
source.  Upon receipt of the product , the re-refiner must
bear these  responsibilities.
               Accurate records must be kept beginning wit
the source  of the product, the hauler and the re-refiner
or disposal agent.  It must be determined Quantities of
waste  generated by each plant, factor, etc., and these
figures followed through to disposal or reclamation.
               Until such a time as these laws and regu-
lations are enacted, we will continue to diminish our re-
sources and pollute our environment.
               And, I would like to add to this that we
look to the EPA to protect our environment, but we also
hope that you people would be a leader in conserving our
natural resources through reclamation whenever possible.
               Thank you.
               MR. LEHMAN:  Thank you, Mr. Kinsman.  Will
you answer questions?
               MR. KINSMAN: :  Yes.
               MR. KOVALICK:  The first one from the floor
What happens to the lead in used motor oil and also the
sulfur in the oil?
               MR. KINSMAN:  To date, I should say first

-------
of all the lead in our process, lead solids are oxidized,
we do have some lead solids that drop out in our tank
bottoms.   This is, as I said, a thermal installation pro-
cess.   We are recovering 90# or better of the oils in
the bottom of our tank, we are getting certain amounts of
sludge.  I should say we have been operating for better
than a year now and we have not had to clean our tank bot-
toms yet.    We are getting a build up of residue in there;
this is where the lead is at tftis time.
               Now, we have done extensive research and
development work on this, and one favorable aspect of
this has been that to date we have found, and this is
strictly on lab test scales, that these bottoms will be-
come intrained and become a very favorable additive to
asphalt if added in the proper quantity.   In fact, it
can be an asphalt additive that will increase the ductility
of the asphalt, and reduce the overall cost of the pro-
duct.
               Hopefully, we will be able to develop a
commercial market out of this, which will be one way of
diposing of it.   As I said, we really haven't generated
large quantities to date.    I would say right now, if
we were to dispose of this product right now, today, it
would have to go to an improved incineration site, but
this has not been the case.

-------
               MR. LEHMAN:  Mr. Lindsey?



               MR. LINDSEY:   I have a two part question



here from the floor.   I guess actually you have answered



the second part, so I'll ask only the first.   What do



you do with filter cakes containing 10 to 15$ oil?   Do



you handle things  like that?




               MR. KINSMAN:  I don't understand the ques-



tion.  Are you talking water primarily?  We don't use the



clay treatment.



               MR. LINDSEY:  I think the question should



be, do you handle only liquid wastes or do you handle



solids that have liquid waste  oil embedded in them?



               MR. KINSMAN:  No, we do not handle solids.



It has to flow.   As I said, initially, we handle crank-



case oil, which is a small percent of our feed and is one



reason lead hasn't been a really big problem yet.   The



bulk of our product has been coming from tank bottoms



from tank firms, primarily No. 4 oil, No. 6 oil.  We have



been getting a lot of oil spilled material.   Again, this



is heavily contaminated with water.



               We have taken some contaminated product



off of ships, again working with the Coast Guard, we have



taken contaminated products from the government, the



Air Force particularly.




               MR. LINDSEY:  Another question from the






                          313

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floor.  Other speakers have referred to the transporter




or hauler being controlled or regulated as you do, can




you elaborate on how you visualize that?




               MR. KINSMAN:  Yes, I think that the hauler




certainly has an obligation.   I also feel the producer




of the waste has an obligation to see that it goes to an




approved hauler to an approved disposal site.   Now, we




work two ways ourselves.   We take full responsibility




of the product if we haul it in our own vehicles.  How-




ever, I would say that 30 to ^0$ of our product comes




from outside haulers, they are responsible for the pro-




duct until it is disposed at our plant.



               MR. LEHMAN:  Do we have any other questions



I guess not.  Thank you very much, Mr. Kinsman.



               Ladies and gentlemen, we don't have enough




time really, to have another speaker before we have our




scheduled break, so I think we'll have it now.   Before




we do that I just want' to say that I believe we have made




excellent progress today, and it appears that we will be




able to finish the scheduled speakers in the allotted




time period, finished by 5:30 this afternoon, and we will




not have to go into an evening session.   So those of




you who have perhaps travel plans are probably glad to




hear that.




               So, at this time we win take the break

-------
a little early.




                (Whereupon a break was taken.)




               MR. LEHMAN:  I would like to open the




meeting again now after our break,  i  would like to call



as the first speaker in this part of the session, Mr.




Robert Canace of Maplewood, New Jersey.  Mr. Canace.




               MR. CANACE:  Good day.  My name is Robert




Canace; I am a graduate student in geology at Rutgers




University, here in Newark.  I have orepareda statement




and I would like to read it to you.




               By concentrating on hazardous waste sources



we can., by extension, ameliorate management problems at




the disposal end.  A prevention-oriented approach would




reduce problems associated with non-radioactive hazar-




dous wastes and those that are radioactive.



               With respect to non-radioactive wastes, I




offer the following recommendations:




               a)  Require pre-market screening of poten-




tially dangerous substances.  For dangerous substances,




reuire a statement or available substitutes and alterna-




tives.



               b)  Private interests should divulge re-




search findings on health aspects of the toxic substances




they produce and use.  Testing should be done by EPA-pre-




scribed methods and conclusions as to a substance's  carcinq






                            315

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geniclty, mutagenicity, etc., should be reported to the



EPA.  Regular consideration should be given to disallow-



ing the continued use of substances found to be highly



detrimental to the biosphere.



               c)  Consider on-site storage of wastes in



a prescribed manner to allow for management solutions to



arise and a management industry to develop.



               d)  Detoxification of existing hazardous



waste stockpiles is an urgent need.  Existing stocks of



chlorinated still bottom residues can be subject to




chlorinolysis to convert thosetoxic wastes to carbon



tetrachloride and hydrochloric acid.  Large volumes of



the latter should present a less severe problem than



stockpiles of Vietnam-era defoliants, banned insecticides,



polychlorinated biphenyls, etc.



               e)  Recent alarm concerning the health as-



pects of PCS should be taken with utmost seriousness.  A



moratorium is needed on discharging PCB's into risers



like the Hudson, until the epldemiological consequences of



PCB in the physical environment can be more firmly estab-



lished.



               f)  There is a need to regulate interstate



traffic of toxic wastes.  Some statep New Jersey for in-



stance, have accommodated themselves to those seeking out-




lets for hazardous wastes and as such carry a dispropor-




                             316

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tionate burden of the clanger.

                g)  In-state there is a need for toxicity-

 oriented land disposal.  California has a landfill designa-

 tion  system that should be examined for possible nation-

 wide  application.  Land disposal sites should be classi-

 fied  on the basis of their geology, hydrography and their

 relationship to population.  Wastes of various toxic

 levels can then be relegated to disposal sites fit to

 accept them.

                h)  Existing land disposal sites should

 be monitored regularly for a broad range of leachates.

 University based labs could be established to regularly

 analyze and report on water quality in proximity to dis-

 posal sites.

                j)  The many cases of accidental contami-

 nation point to the need for obvious and ubiquitous label-

 ing of dangerous substances.  Container manufacturers couli

 be the ones to which the responsibility of labeling is

 given.  As trite as it may sound, the  Jolly  Rodger  (skull

 and crossbones) is universally understood to represent

 poisonous qualities; it should be blatantly and indelibly

 embossed on all toxic waste containers, for the sake of

 the public.

                In the absence of large-scale  plutonium

 recycle and breeder reactor "burn-up", radioactive waste

 management must be commensurate with the magnitude of
                               317

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demands imposed by trans-uranium contaminated wastes —



high-level radioactive wastes with long half-lives.  This



calls for solutions which will stand the trials of millenid.



               Promise for geologic disposal of radioactive



wastes faded with the AEC failure of actively-pursued



salt-deposit emplacement at Lyons, Kansas and Carlsbad,



New Mexico.  ERDA continues to balk at engineered



Retrievable Surface Storage.  And the track record and



reprocessing facilities (West Valley, New York) and the



Federal waste repositories (Hanford, Wash., Valley, New



York) and of the Federal waste repositories (Hanford,



Wash., Savannah River, S.C. and Idaho Falls, Idaho)



is badly stained.  A lack of disposal options causes



"^rubbernecking" throughout the entire nuclear fuel cycle—



witness the stockpiling of wastes at West Valley, New York,



for the improvement and expansion of that facility.



               Therefore, with respect to radioactive



wastes, diminishing the quantity is the only foreseeable



way in the near term to mitigate potentially extreme



adverse impact.  In light of existing technological op-



tions, radioactive waste reduction can only be accomplishes



through a moratorium on commercial nuclear power genera-



tion and weapons production.



               Existing radioactive waste stocks should be




converted to a dry calcine product to reduce the potential



                               310

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for contamination via leakage of "hot" liquid wastes.

               In conclusion, hazardous wastes are both

perplexing and frightening.  Toxic wastes denote morbidity,

which demands high priority research and development ini-

tiative.  The Environmental Protection Agency should con-

tinue to solicit advice from the public, the private sec-

tor and academia, in formulating hazardous waste manage-

ment policy.

               Thank you.

               MR. LEHMAN:  Thank you, Mr. Canace«  Do we

have any questions.  Are you willing to answer questions?

               MR. CANACE:  Yes, I would.

               MR. LEHMAN:  Do we have any questions from

the audience or from the panel?  Mr. Kovalick:

               MR. KOVALICK:  Your Point G, where you

noted in state, referring to New Jersey, I imagine, there

is a need for toxicity oriented land disposal.   Could

you elaborate a little bit on that?  Prom your geological

background or are you referring solely to the California

system there?

               MR. CANACE:   Well,  the California system

is based on, I guess, inertness of environments, if you

have a geographically  inert environment you can in

that environment emplace wastes that are more toxic than

in a leachate pond fill, for Instance.   This is what I

mean, the more toxic the fill, the more inert the environ-
                      319

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ment  should be  in which  it  is  in place,  if land  disposal
is to be used.
                MR. LEHMAN:  In any of your studies, have
you attempted to look at the geology of  your home  state,
for example, New Jersey, to see whether  there are  areas
within the state that would fall into the various  cate-
gories you are  talking about?
                MR. CANACE:  Not formally, no, but  in
general, this being a very  moist state,  I'd have to say
no.
                MR. LEHMAN:  Are there any other  questions
of Mr. Canace?   I guess not.  Thank you very much, Mr.
Canace.
                Next I would like to call on Mr,  John E.
Witty  of the U.S. Soil  Conservation Service.
              MR. WITTY:    Thank you.   My name  is John
  .      I'm a soil scientist working for the Soil  Conser-
vation Service  with headquarters at the  Northeast  Techni-
cal Service Center in Broomall        ,  Pa.  And I have a very
brief position  statement to read, presented by the Soil
Conservation Service.
                For disposal of many kinds of hazardous
wastes, the safest method is land disposal.   The  capacity
of the soil to  safely absorb and hold such materials is
influenced by its chemical  and physical  properties,
                         320

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including:  Cation exchange capacity, percent base

saturation, pH, organic matter content, permeability and

depth.

               These  properties are identified by soil sur-

veys prppared by the U.S. Soil Conservation Service.

Such soil surveys are completed for nearly 60 percent of

the land in the United States.

               For disposal of specific hazardous wastes,

soil chemists and physicists of the SCS, using data from

soil surveys, can determine the limiting soil properties

and make useful evaluation  of the potential of soils at

specific sites to safely dispose the wastes.

               Thank you.
               MR. LEHMAN:  Thank youa Mr.  Witty.  You

have a question, Mr. Sanjour?

               MR. SAWJOUR:  I wonder what kind of data
you have to support the statement in the case that dispos-

al of many kinds of hazardous wastes, that the safest
method is lime disposal.   I ask the question because our

research in the EPA in recent years, the more we learn I

think the less confidence we have in that kind of state-

ment.  Specifically, our recent research has shown cat-

ion exchange capacity doesn't really have much effect,

that the organic matter is capable only up to a point of

attenuating and when loading, more typical of what is

actually practiced,  in fact the attenuation practice
                               321

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 breaks down.   I was Just wondering whether you have done




research or have data, on what basis these conclusions are




founded.




               MR. WITTY:   Well, things like cation ex-




change capacity, the soil has, the higher the capacity it




is for absorbing certain kinds of heavy metal for example,




and in sand which may have very low exchange capacity.




               MR. SANJOUR:  Is this based on theoretical




considerations or have you actually studied disposal sites




or done laboratory experiments of wastes, or something of




that nature?




               jjjfj^ WITTY:   Most are theoretical consider-




ations, yes.




               MR. LEHMAN:  Another question?




               MR. KOVALICK:  A question from the floor.




Of what value are soil conservation surveys below 4 feet




from the surface?   I guess another way of asking it, is




your data base, what portion of the soil did your data




base complete?




               MR. WITTY:   It is based essentially on the




upper five feet, below that we have to go more to the geo-




logical kind of information.




               MR. LEHMAN:  Mr, ^jittv,  your statement




leaves one to believe that SCS' is perhaps available for




consultation to various people who are interested in these




                       --,'; 9

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aspects.
               MR.  rvlTTY.   Tnat is
               MR. LEHMAN:  That is true, that if someone
wanted to talk to you about these aspects that they
could contact  SCS and get some help, some technical
assistance?
               MR.  WITTY:   Yes'
               MR. LINDSEY:  I guess related to that,
more specifically, can or does your agency, Soil Conser-
vation Service, recommend a specific site for specific
wastes?
               j/0^ WITTY:   We have prepared guidelines
for evaluating the soils for some kinds of waste, not all
kinds and these guidelines would be available for evaluat-
ing soils-for a specific site, a long list, you need the
soil survey, the maps and so forth.
               MR. LINDSEY:  Are those sufficiently for-
mulated that you could submit them for the record to the
address in the Federal Register?
               MR.  WITTY:  Pardon?
               MR. LINDSEY:  Could you submit them for
the record or are they voluminous?
               MR. WITTY:   I brought along a draft of a
set of guidelines that I'm working on now and I could
send that to you later.

                   323

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                   MR. LINDSEY:   If  you  would  please.




                   MR. LEHMAN:   I have another question,  Mr.



 Witty.      you  indicated  that  soil surveys are  completed




   for 60$ of the  land  in  the U.S.   Could you characterize




   in general what the  geographical areas are that  are com-




   pleted, or another way,  those that are not yet completed,




   or is  it  sort of a patchwork quilt all over the  U.S.?




                 MR. WITTY:      I* is patchwork type of. com-



.tpleibion;  in the  more  populated areas  we have a higher




   density of the  surveys  completed.     In the Par  West, for




   example,  in the range country, they  are not completed to



   the extent that they are here.




                   Now,  I believe that 60$, it is the  60$




   that we have  mapping completed,  I suspect  that there  is



   somewhat  less than that 60$  that is  actually  published.




   It's probably around 50$ that is published, but  I'm not



   sure on that.




                   MR. LEHMAN:   Mr.  DeBonis?




                   MR. DeBONlS:   Would  it be  safe to  say that




   a state like  New Jersey is 100$  all  completed?




                   MR. WITTY:  No, it is  not

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UNITED STATES DEPARTMENT OF AGRICULTURE
SOIL CONSERVATION SERVICE - Northeast Technical  Service Center	
 1974 Sproul Road, Broomall, Pennsylvania  19008


 Hazardous Waste Management - Public Meeting,        DATE  December 3,  1975
 12/2/75, Newark, New Jersey

 John P. Lehman, Director
 Hazardous Waste Management Division
 Office of Solid Waste Management Programs (AW-565)
 Environmental Protection Agency
 Washington, D. C.  20460
 At  the public meeting in Newark, New Jersey, on the above subject,  Mr.
 Walter W. Kolvalick, Jr. requested me to send you some of the  guidelines,
 developed by the Soil Conservation Service, for selecting sites  or  rating
 soils concerning their limitations for use in land treatment systems  of
 wastes.  Mr. Kolvalick requested that this information be entered as  part
 of  the records.

 I am sending two items:

     1 .  A draft of a paper titled "Site Selection as Related  to Land
         and Soil Properties" by John E. Witty and Klaus W.  Flach,  and

     2.  Guide for Interpreting Engineering Uses of Soils, USDA, Soil
         Conservation Service.

 Limitations for using these kinds of guides are discussed in both the
 paper by Witty and Flach and on page 2 of the "Guide for Interpreting
 Engineering Uses of Soils."

 I believe the two enclosures pretty well describes how soil  surveys
 can be used for aiding in the selection of sites for land based  treat-
 ment systems of wastes.
  I  >'    
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                                 DRAFT
Paper presented at the SSSA Symposium on "Soils for Management and Utilization of
Organic Wastes and Waste Waters."  Muscle Shoals, Alabama, March 11-13, 1975.
              SITE SELECTION  AS  RELATED  TO  LAND AND  SOIL  PROPERTIES
                                      by
                        John  E.  Witty and Klaus  W. Flachl/
            The  purpose of  this  paper  is  to discuss site  selection criteria
       for management and utilization  of  organic wastes and waste waters with
       emphasis  on  land and soil properties.  Criteria or properties considered
       are   those that will  lead to  the utilization or disposal of wastes without
       causing environmental  problems  outside the  site perimeter and any buffer
       zones.  The  basic objective,  therefore,  is  to utilize or dispose of the
       wastes in such a way that they  are either rendered harmless or prevented
       from  moving  onto adjacent land, into surface waters, into the ground water,
       or into air.
            In discussing site selection  criteria, one can give only general
       principles that apply to wastes from many sources  and to waste management
       systems that are in  common  use.  Soil chemical, physical, and biological
       properties related to waste interactions with soils are discussed in
       earlier chapters.  The list of  soil properties, their limits, and intra-
       actions is almost infinite.   However, some  properties may be crucial for
       a specific waste disposal problem  at a given location but may be unimportant
       elsewhere.   Also one set  of properties of a given  soil may maximize its
       ability to renovate  wastes, another set may minimize its ability to accept
       significant  amounts  of wastes,  and a third  set ray even influence manage-
       ment  of the  disposal  site.  Final  decision  as to whether a site should or

       1/USDA, Soil Conservation Service, Broomall, Pennsylvania and Washington, D.C.

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should not be used for a specific system almost always represents a
compromise.  The properties of many soils are known and can be used to
make initial selection of disposal sites.  Additional studies may be
needed, however, to determine soil properties that may be critical for a
specific use.
     Three general sets of criteria can be considered:  First, those
criteria that are important if the soil is to act primarily as a container
for highly concentrated wastes and where the wastes do not interact with
the soil to a significant degree, such as in sanitary landfills or in
feedlots; second, those criteria that are important if the soil is to react
with important components of the wastes so as to immobilize or destroy them
and where utilization is not or cannot be a primary consideration.  Examples
are sewage effluent disposal sites or sludge disposal sites; and third, those
criteria that are important if waste utilization is the primary consideration.
     Each of these three sets of criteria is discussed with emphasis on
soil properties, followed by a discussion on the use of soil surveys as an
aid for locating potential  sites and some hydrological and geological
considerations in selecting potential  sites.  Regional limitations such as
soil temperature, length of growing season, or amount and distribution of
precipitation are not discussed.  The above items are important considerations
for regional planning, however, because they do affect decisions on the
feasibility of soil-based systems or on costs if winter storage facilities
are necessary.
     The following presentation is centered around guidelines (Tables 1-5)
that have been developed and are now being used by the Soil  Conservation
                               o27

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Service.  However, these guidelines are under continual review and
subject to change from time to time.
     In these guides, individual critical  soil properties are rated as
to how severely they limit the usefulness  of soils as treatment media
for certain wastes.  No attempt is made to evaluate the ease with which
limitations can be overcome through appropriate design of the system or
through modification of the soil.
     The approach is simple and can serve  as an initial guide in rating
kinds of soils on the basis of criteria that have been published (Soil
Conservation Service, 1971) or are available in computer storage for the
11,000 or so soil series of the United States.
I.  SITE SELECTION CRITERIA FOR WASTES DISPOSED ON LAND AT HIGH RATES
     Examples where wastes are concentrated or applied at high rates include
sanitary landfills, sewage lagoons, feedlots, and areas of stockpiled
organic material.  The wastes, when disposed on land, are generally highly
concentrated in small areas and have a high potential for causing
environmental problems.  Of prime importance is the design of facilities
and proper management of the wastes because the soil will not normally have
the capacity to dissipate them adequately.  The basic function of the soil
is to act as a container.  Proper site selection can greatly reduce the
problems of design and management.
                       A.  Sanitary Landfills
     The process of sanitary landfilling is to bury wastes in soil.
Loughry (1974) described four functions that soil has in relation to
landfills, as follows:

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     1.  Soil serves as container and support.
     2.  Soil serves as the most commonly used cover material.
     3.  Soil retains intermediate products, providing time and a
         favorable medium for change and recycling of some of the wastes.
     4.  Soil, if used as the final cover material, supports vegetation
         and can be used for farming, forestry, or recreation.
     The Soil Conservation Service (1971) has published guides for
assessing the suitability of different kinds of soil for sanitary landfills.
Two guides are provided, one for the trench-type sanitary landfill and the
other for the area-type sanitary landfill.
1.  Trench-type Sanitary Landfill
         The trench-type sanitary landfill  consists of trenches in which
refuse is covered at least daily with a layer of soil material at least
15 cm thick.  Soil  excavated in digging the trench is used as the covering
material.  When the trench is full, the landfill is covered with a layer
of soil material  at least 60 cm thick.
     Table 1 lists  the soil  limitation ratings for the trench-type sanitary
landfill.  Soil properties considered are:   depth to seasonal high water
table, soil drainage class,  flooding, permeability, slope, soil texture,
depth to bedrock, stoniness  class,  and rockiness class.   The degree and
duration of soil  wetness as  related to seasonal water table, soil  drainage
class, and flooding are considered  because  they affect earth moving
operations and the  likelihood of contaminating the ground water.   As degree
of soil wetness increases, the site becomes increasingly less suitable as
a sanitary landfill site.
                                  oi.3

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     Soil permeability is important because it affects vertical  or



lateral movement of leachate.  Soils with low permeability are most



desirable because seepage is minimized.



     Soil slope is an important consideration since it may affect runoff



and ease of constructing trenches and roads.  On moderately steep and



steep soils, leachate may concentrate in downslope trenches (Apgar et al,



1971) thus increasing the potential for ground water pollution.



     Soil texture affects the workability and trafficability of the



soil, both wet and dry.   Soils with textures that are workable over a



wide range of moisture content are most desirable.  Many coarse-textured



soils have a low degree of workability and trafficability when dry, while



many fine-textured soils have low workability qualities when either wet



or dry.  The final cover should be soil material that is favorable for



plant growth.



     Bedrock, stoniness, and rockiness affect the ease of excavating



trenches to suitable depths.  Fractured bedrock immediately underlying



the trench also creates a potential for the pollution of ground water.



2.  Area-type Sanitary Landfill



     In this type of landfill, waste is placed on the soil surface and



covered with soil.  The waste is covered daily with at least 15 cm of



soil and is covered with soil at least 60 cm thick when the landfill is



completed.



     Table 2 lists soil  limitation ratings for the area-typ'e sanitary



landfill.  Soil properties considered are:  depth to seasonal water table,



soil drainage class, flooding, permeability, and slope.  The importance

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of these properties for workability or potential  pollution of ground
water is the same as discussed above for the trench-type sanitary
landfill.  Stom'ness, rockiness, or bedrock are not important con-
siderations because no excavating is done in the area-type sanitary
landfill.
     The dally cover material and final cover material  for the area-type
sanitary landfill generally must be imported from other soil  areas.  A
table giving the "suitability ratings of soils as sources of cover
material for area-type sanitary landfills" has been prepared by the Soil
Conservation Service (1971).  This table is not included in this paper;
soil properties listed for the cover material are moist consistence,
texture, thickness of material, coarse fragments, stoniness,  slope, and
drainage class.  Soils with very friable or friable consistence are good
sources of cover material, those with loose or firm consistence are fair
sources, and those with very firm or extremely firm consistence are poor
sources.  Soils with good textures for cover material  include sandy loam,
loam, silt loam, and sandy clay loam; those with fair  textures are silty
clay loam, clay loam, sandy clay and loamy sand;  and those with poor
textures are silty clay, clay, muck, peat, and sand.  Thick,  well drained
soils with gentle slopes and without coarse fragments  are better sources
of cover material than shallow, gravelly or stony soils or soils in wet
areas.
                       B.  Sewage Lagoons
     A sewage lagoon or stabilization pond is a flat-bottomed pond used
to hold sewage for the time required for its bacterial  decomposition

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(Soil Conservation Service, 1971; Clark et al, 1971).  In sewage
lagoons the soil serves two functions:  (1) a container for the
impounded sewage, and (2) material for the enclosing embankment.  The
lagoon must be capable of holding water with minimum seepage.   Material
for the enclosing embankment does not have to come from the sewage
lagoon site.
     Table 3 gives soil limitation ratings for sewage lagoons.   Criteria
considered are:  depth to water table, permeability, depth to bedrock,
slope, coarse fragments less than 25 cm in diameter, percentage of
surface area covered by coarse fragments more than 25 cm in diameter,
organic matter, and Unified soil classification groups.
     Depth to water table is important in that water should never rise
high enough to enter the lagoon.  If, however, the floor of the lagoon
consists of at least 60 cm of essentially impermeable material, depth to
water table can be disregarded.  If the floor of the lagoon consists of
slowly permeable material, at least 120 cm of material is needed between
the bottom of the lagoon and the seasonal water table or any cracked
and creviced bedrock.
     Limitation classes for slope are determined by the requirement that,
for the lagoon to function properly, the liquid depth should range from
60 to 150 cm.  The slope must be sufficiently gentle and the soil material
sufficiently thick over the bedrock to make land smoothing practical so as
to obtain a uniform depth in the lagoon.
     A high percentage of coarse fragments interferes with the manipulation
and compaction needed to prepare the lagoon properly; hence, limitation

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classes for coarse fragments should be considered.
     Soils subject to flooding are normally unsuited as sites for sewage
lagoons because of the potential of floodwaters to mix with and carry
away polluting sewage before sufficient decomposition has occurred.
If, however, floodwaters do not damage the lagoon embankment or do not
overflow the lagoon, this limitation does not apply.
     Soil materials placed in the Unified soil classification groups (U.S.
Army Corps of Engineers, 1968) of GC, SC, CL and CH (defined below) can
be compacted to a satisfactory low permeability for a lagoon bottom.  The
coarse groups with few fines and soil materials high in organic matter
have severe limitations and are poorly suited.  Soil materials in the
Unified soil classification groups GM, ML, SM and MH are suitable if
properly compacted or used in combination with soils classified as GC,
SC, CL, and CH.
     The Soil  Conservation Service (1971) has published a guide showing
the general relationships between the Unified soil classification groups
and USDA texture classes.  The relationship is not perfect but it can be
used for predicting the likely group or groups for each textural  class.
The following shows a simplified relationship between the Unified soil
classification groups listed above and the USDA texture classes.
     GC - very gravelly silty clay loam, gravelly silty clay loam, and
          very gravelly silty clay.
     SC - heavy sandy loam, sandy clay loam, and sandy clay.
     CL - heavy silt loam, clay loam, and silty clay loam.
     CH - heavy clay loam, heavy silty clay loam, silty clay, and clay.

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     GM - very gravelly sandy loam, very gravelly loam, very gravelly
          silt loam, and gravelly silt loam.
     ML - fine sandy loam, very fine sandy loam, loam,  silt loam,  and
          silt.
     SM - fine sand, very fine sand, loamy sand, sandy loam, and fine
          sandy loam.
     MH - silty clay loam and clay loam.
     The Soil Conservation Service (1971) has rated separately soils
that are suitable for lagoon embankments and  those that are suitable for
lagoon floors.  Properties considered in rating soil materials for their
suitability as lagoon embankments are:  sheer strength, compressibility,
permeability of compacted soil, susceptibility to piping,  and compaction
characteristics.   They are evaluated for each Unified soil  classification
group.  Basically, soils in the Unified soil  classification groups listed
as having slight  limitations for the floor of a sewage lagoon are  also
suitable for the  embankment.
                          C.  Feedlots
     Under this subheading, major emphasis is placed on site selection
for animal pen areas.   Criteria for selecting sites for lagoons or
catch basins associated with pen areas are virtually the same as those
discussed in the  previous section on sewage lagoons.  If the manure is
stored outside the pen areas, then criteria discussed under the subheading
"Areas for Stockpiled Organic Materials" apply.
     General guidelines for evaluating soils  for feedlots  have been
published by the  Environmental Protection Agency (Kreis et al, 1972).

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The guidelines specify that soils with slopes of 2 to 6% are suitable



and that highly permeable loose soils, shallow soils over fractured



bedrock, and soils with a shallow water table should be avoided.   Sloppy



pen conditions may develop if the slope is less than 2%, and uncontrol-



lable runoff may occur if the slope is greater than 6%.  Loose, shallow,



or wet soils may lead to contamination of ground water.



     If a feedlot is managed properly and continuously stocked, and a



manure mulch left after cleaning, an impermeable layer forms at the



manuare-soil interface that effectively seals the floor of the feedlot



against downward movement of pollutants (Elliott et al, 1973; Mielke et al,



1974).  This seal apparently forms in any soil regardless of texture or



permeability.  Therefore, texture and permeability are not considered in



rating except for very rapidly permeable soils (>50 cm/hr.).  These may



have moderate limitations because of the potential instability and time



lag before a seal forms.



     Soil drainage is important because of its effect on trafficability.



Well drained, somewhat excessively drained, and excessively drained soils



as well  as sloping, moderately well  drained soils have slight limitations;



poorly and very poorly drained soils have severe limitations.  If slopes



are less than 2 or 3%, however, moderately well drained soils have



moderate limitations and  somewhat poorly drained soils have severe



limitations.



     Soil slope is important;  erosion is a hazard on steep slopes but



sloppy pen conditions may result if the soil  are level or nearly  level.



Gilbertson et al  (1970) reported no significant  difference  in  runoff

-------
volume or solids removal  from feedlots near Mead,  Nebraska,  having
slopes of 3, 6, and 9%.   Swanson et al (1971),  however,  found that  in
eastern Nebraska a feedlot with 13% slope lost  more solids  than  one
with an 8.5% slope.  This indicates that possibly  slopes as  high as 10%
have slight limitations  while steeper slopes might have  moderate or
severe limitations.  The slopes in these studies,  however,  were  relatively
short, about 30 meters and less, and may not represent solids removal  for
longer slopes under similar precipitation characteristics.   E. J. Monke
(Department of Agricultural Engineering, Purdue University,  personal
communication) and N. P.  Swanson (Agricultural  Research  Service, University
of Nebraska, personal communication) suggests general  slope limitation
classes of 2 to 6% as slight, 0 to 2 and 6 to 10%  as moderate, and  greater
than 10% as severe.  N.  P. Swanson also suggests that if snowmelt or
rainfall is not a problem, soils with slopes of 15 to 20% should be use-
ful for feedlots.  Slopes steeper than about 20% present a  safety hazard
for machinery operations.  Hence the general slope guidelines, as given
above, should be adjusted according to snowmelt or precipitation
characteristics.
     Depth to bedrock should be considered because it affects feedlot
construction if terracing or, on level soils, mounding is required. The
soil must be deep enough so that the feedlot can be cleaned properly and
revegetated when it is abandoned.  This is important to  remove nitrogen
compounds that might otherwise pollute the ground  water  (McCalla, 1972).
Depth to bedrock should  probably be more than one  meter.
     Stones affect feedlot construction and cleaning. Stoniness  classes
                                 336

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of 0 and 1 present slight limitations, 2 and 3 present moderate limitations
limitations, and 4 and 5 present severe limitations (Soil Survey Staff,
1951).
           D.  Areas for Stockpiled Organic Materials
     The stockpiled materials considered here are organic materials
handled as solids rather than as liquids.  Materials are stockpiled in
open piles and are not covered with soil material as in sanitary landfills.
The materials may be stockpiled for either a short or long time but the
site is used continuously.  Of primary concern here are animal wastes but
included are organic materials such as logs in the lumbering or pulp
industry, sewage sludge, leaves, or other kinds of organic materials
that are composted in large quantities.  It is assumed that the stockpiled
materials are managed to minimize odor and vector problems.  The primary
function of the soil is that it serves as container and support.
     Specific guidelines have not been published.  The same soil
properties and limitation ratings used for making soil  limitation ratings
for the area-type sanitary landfill  (Table 2), however, can be considered.
II.  SITE SELECTION CRITERIA FOR WASTES DISPOSED ON LAND AT LOW RATES
     Under this heading are discussed criteria for selecting sites on
which wastes can be applied at a rate that is in equilibrium with rate
of decomposition.  Hence the site should be usable on a continuous basis.
Side benefits may be realized, such as harvestable crops or recharge of
ground water, but the primary objective is to dispose of wastes.
     Kinds of wastes disposed of on land at low rates may be sewage
sludge, sewage effluent, animal  wastes, and cannery wastes.  The major
                            oST

-------
function of the soil is to dissipate the wastes, to recycle them through
crops, or to purify them through filtering and adsorption.
     The Soil Conservation Service has prepared an interim guide that is
being tested (Tables 4 and 5).   Soil properties used to rate kinds of soils
by this guide are:  permeability, soil drainage class, runoff, flooding,
and available water capacity.
     Soil permeability influences length of time liquid wastes remain in
the soil and potential loading rates.  If permeability is very high,
liquid wastes or soluble components of solid wastes may pass through a soil
so fast that any potential pollutants are not adequately dissipated,
especially during periods of high rainfall.  On the other hand, if
permeability is too low permissible application rates would be too low to
be practical, or anaerobic conditions would be induced.  Moderate and
severe limitations do not apply for moderately slow, slow, or very slow
permeabilities if layers having these permeabilities are below the rooting
depth and evapotranspiration exceeds water added by rainfall and waste,
or if solid waste is not plowed or injected into these layers.
     In humid areas (udic moisture regimes), excess water in a soil can
be predicted according to its soil drainage class.  Soil drainage
classes are a measure of the length of time the soil is naturally at or
near saturation during the growing season.  They reflect both the ability
of the soil to remain aerobic and to support traffic.  Well drained and
moderately well drained soils are considered to have slight limitations,
while excessively drained or poorly and very poorly drained soils have
severe limitations.

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          It is important that the applied waste stay on the site, therefore
     soils are also rated for surface runoff and flooding.  Runoff is closely
     related to infiltration rate, soil slope, and cover.   It has been argued
     that the infiltration rate should be considered in rating soils for
     receiving liquid wastes.  However, the actual infiltration rate depends
     so much on management practices that it is omitted from Table 4.  If soil
     is managed to maximize infiltration, e.g., by maintaining plant cover,
 1    by keeping traffic to a minimum, or by interjecting drying cycles, then
 i    the effective infiltration rate is primarily dependent on soil  permeability.
     The degree of soil limitation for runoff is given in terms of runoff classes
 !    as defined in the Soil  Survey Manual (Soil Survey Staff, 1951).   In general,
 i    soils that flood are considered to have severe limitations for  disposal
 1    of wastes.  If the soils flood only during the nongrowing season, however,
 3    they are considered as having only moderate limitations at some localities.
 3         The available water capacity is primarily a measure of the capacity
 7    of a soil  to supply moisture to plants.  It is used here as a measure
 3    of the minimum soil volume needed to dissipate the wastes through plant
 9    nutrient uptake, microbial  decomposition, and soil adsorption.   The depth
0    considered is from the soil  surface to 150 cm, or to  a limiting layer
 1    less than  150 cm deep.   Soils with more than 15 cm available water have
2    slight limitations, those with 8 to 15 cm have moderate limitations,  and
3    those with less than 8 cm have severe limitations.  The moderate limitation,
4    however, does not apply for  liquid wastes in an arid  climate.
5
6

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III.  SITE SELECTION CRITERIA FOR WASTES UTILIZED FOR CROP PRODUCTION
     Considered here are the organic wastes and waste waters that 'can
be used as fertilizer, soil amendment, or irrigation water to supplement
precipitation.  For example, wastes may be used on golf courses, on parks,
or for crops.  Yield of vegetation or crop* rather than disposal of waste,
is the primary objective.  Although the site selection criteria concerning
soil properties are practically the same as for waste treatment on land
at low rates, they are discussed separately because of possible differences
in the extent and distribution of suitable soils.  Furthermore, arrange-
ments for use of the wastes are usually made with individual landowners
or governing bodies, such as an irrigation district.  The parcels of
land may be widely scattered and economic factors may influence the
feasibility of the system.
     The success of a project in which the primary objective is to
utilize the waste ultimately depends on the value of the wastes compared
with costs of alternative methods of satisfying the landowner's needs.
Liquid wastes have much greater value in the arid western part of the
United States than in the humid eastern part.  As a rule, if arrange-
ments for utilization of the wastes have to be made with many landowners,
the total extent of soils with suitable properties must be much greater
than if the municipality or industry purchases or leases land for its
waste disposal.  Under these circumstances the amount of land needed is
likely to be inversely proportional to the value of the waste in a given
farming system.

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                     IV.  SELECTING A SITE
     Soil surveys are probably the most useful single source of
information for making initial judgments on the suitability of potential
sites for disposal or management of wastes on land (Flach et al, 1974).
Soil surveys are available for more than 40% of the country (Flach, 1974)
and are generally available where soils are used most intensively.  They
consist of detailed soil maps usually at a scale of 1:31,680 to 1:15,840
on photographic background, a general soil map, description of the soils
by series and mapping unit, data on engineering and agronomic properties
of soils (usually with some characterization data on major soil series),
and interpretive tables.  Soil surveys are prepared by the Soil Conservation
Service in cooperation with agricultural experiment stations and units of
local government.
     A report prepared by Sopper and Kardos (1972) regarding the
suitability of soils in the Tocks Island Region of the Delaware River
Basin for potential use of treated municipal sewage effluent is an excel-
lent example of the use of soil surveys for making an inventory of potential
disposal sites.
     Sopper and Kardos reviewed published soil surveys and supplementary
information for the area to establish criteria for the selection of
desirable kinds of soil.   After development of the criteria, the soils
were evaluated and those that did not measure up to the standards were
rejected.  Next, suitable soils were located on soil  maps, color coded,
and acreages of the various soil parcels measured.  This provided
information on the extent and distribution of soils in the area which

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were potentially suitable for sorav irrigation.
     The guidelines discussed in our paper are useful  as a first ap-
proximation for making a general survey of soil resources suitable
for waste treatment systems.
     The guidelines do not consider interaction among  soil properties,
between treatment systems, or combinations of soil  properties.   The
guidelines consider soils in a pedologic sense.  Also, they do  not take
into account underlying unconsolidated regolith that may be an  important
part of treatment systems, and they do not allow one to pinpoint soils
with the best potential for a particular treatment system if all soils
in the area available as treatment sites have the same degree of
limitations.
     More sophisticated and complex guides could be developed,  but
because of the large number of waste materials, treatment systems, and
soils, the utility of such an effort is questionable.
     Hence, after an initial screening using these guides, further
evaluation is still necessary in which all information on the properties
of soils of a given area and the requirements and alternatives  of the
treatment system are used.
     Information on the properties of individual soils can be obtained
from soil descriptions and tables of soil properties in published soil
surveys (Table 6).  A computerized inventory of properties of the 11,000
or so soil series in the United States is being prepared by the Soil
Conservation Service.  An example of the kind of data  in the inventory
is shown in Table 7.  In addition, a great many site data, representative
                                A 2

-------
of many kinds of soils, are contained in the Soil Conservation Service,



USDA, Soil Survey Investigations Reports and in other technical publi-



cations.  In fact, for a first approximation, many soil properties



important for waste treatment systems can be deduced from the placement



•of soils in Soil Taxonomy, the system of soil classification adopted



by the National Cooperative Soil Survey.  Hence, a competent soil classifier



working closely with other specialists in soil science and with engineers,



geologists, and hydrologists can identify potential sites that meet as



many requirements as is possible for a given area.



     In any case, practical experience with a specific kind of soil



should be an overriding consideration in judging the suitability of



a particular kind of soil.  If a system works  well in one area with a



specific soil, it can be expected to do equally well with the same or a



similar soil elsewhere.



     Soil  surveys, however, are concerned primarily with the top 2 meters



of the regolith.  For many disposal systems, particularly trench-type



sanitary landfills and lagoons, the nature of the underlying unconsolidated



material and the depth of the regolith to inert bedrock also must be



determined.   This is particularly important if the regolith is permeable and



chemically active and if the rock is jointed, fractured, or contains other



open channels such as tubes in basalt or solution channels in limestone.



In addition, the hydrology of the site as it might be affected by the



construction and the operation of the disposal  site must be evaluated.



For example, the site may have limited capacity to accept added waste

-------
water and the addition of waste water may cause the ground-water level
to rise (Keeley, 1972); Parizek, 1973).
     Some information on the geology and the hydrology of the site can
be obtained from geologic maps and the geologic literature of the area
but careful onsite studies are usually necessary.  Onsite studies are
also necessary for a detailed evaluation of the soil resource.  Soil mapping
units of the published soil survey may include small areas of contrasting
soils that could not be shown at the scale of a published survey but that
may influence the design of the system or render a site unsuitable.  Small
areas of shallow soil where deep soils were delineated, for example, may
create difficulties for trench-type sanitary landfills or pollution hazards
for liquid waste disposal systems.
     In the design of treatment sites for liquid wastes, other points to
consider are the probable loading from rain and snow and the periods when
the soil is warm enough to be microbiologically active.  In considering
climate, the probability and magnitude of extremes, particularly in
precipitation, must be carefully evaluated.
                          V.  CONCLUSIONS
Site selection requires the following steps:
     1.  Determine kind of waste and method of disposal or utilization.
     2.  Assess the soil properties and select criteria to determine
the suitability of the soil for receiving the waste in question.  Various
guides are avilable for rating suitability of soils for receiving many
kinds of wastes.
     3.  Using soil surveys, determine which soils in the area are

-------
suited for receiving wastes.
     4.  Locate the suitable soils on the soil map to determine extent of
potential sites.
     5.  Provide onsite investigations by a soil scientist, hydrologist,
and geologist to determine the actual suitability of the potential site
for receiving wastes.

-------
Apgar, M. A., and D.  Langmuir.   1971.   Ground-water pollution
     potential of a landfill  above the water table.  Ground  Water.
     9:76-96.
Clark, 0. W., W. Viessman, and  M.  J.  Hammer.  1971.  Water supply and
     pollution control.   International Textbook Co., Scranton,  Pa.
Elliott, L. F., T. M. McCalla,  N.  P.  Swanson, L.  N. Mielke,  T.  A.
     Travis.  1973.  Soil  water nitrate beneath a broad-basin
     terraced feedlot.  Soc.  of Agric. Eng., Trans. 16:285-293.
Flach, K. W.  1973,  Land  resources.   P.113-119.   In Proceedings of
     the joint conference  on  recycling municipal  sludges and effluent
     on land.  Nat. Assoc. of State Univ.  and Land Grant Col.,
     Washington, D.C.
Flach, K. W., and F.  J.  Carlisle.   1974.   Soils and site selection.
     p.1-17.  I_n_ Factors involved  in land application of agricultural
     and municipal wastes.  ARS, USDA.  National  Program Staff, Soil,
     Water and Air Sciences,  Beltsville,  Maryland.
Gilbertson, C. B., T. M. McCalla,  J.  R. Ellis, 0. E. Cross, and
     W. R. Woods.  1970.  The effect of animal density and surface
     slope on characteristics of runoff,  solid wastes and nitrate
     movement on unpaved beef feedlots.  Univ. of Nebraska, Col. of
     Agric. and Home Econ.  SB 508.
Keeley, J. W., Session Chairman.  1972.  Bull session 3 - solid waste
     its ground water pollution potential.  Ground Water.  10:27-41.

-------
Kreis, R. Douglas, and Lynn R. Shuyler.  1972.   Beef cattle feedlot
     site selection for environmental protection.   National Envir.
     Res. Center, Office of Res. and Monit., U.S.  Envir.  Prot.  Agency,
     Corvallis, Oregon.  EPA-R2-72-129.
Loughry, F. G.  1974.   The use of soil science in  sanitary landfill
     selection and management.  P. 131-139.  ln_ Non-agricultural
     applications of soil survey, edited by R.  W.  Simonson.  Elsevier
     Scientific Publ.  Co., New York.
McCalla, T. M.  1972.   Beef cattle feedlot waste management research
     in the Great Plains.  P. 49-69.  ^n_ Seminar on control of agricul-
     ture-related pollution in the Great Plains.  Univ.  of Nebraska,
     Col. of Agric., Lincoln, Nebraska.  Great Plains Agric.  Council
     Publ.  No. 60.
Mielke, L. N., N. P. Swanson, and T. M. McCalla.  1974.   Soil profile
     conditions of cattle feedlots.   J. Envir.  Qual.  3:14-17.
Parizek, R. R.  1973.   Site selection criteria  for wastewater disposal--
     soils and hydrogeologic considerations.  P.95-147.   In Proceedings
     on recycling treated municipal  wastewater and sludge through forest
     and cropland.  Univ. Press, The Penn. State Univ.
Soil Conservation Service.  1971.  Guide for interpreting engineering
     uses of soils.  US Government Printing Office, Washington.
     Stock No. 0107-0332.
Soil Survey Staff.  1951.  Soil  survey manual.   USDA Handbook No.  18.
                                 347

-------
Soil Survey Staff (in press).  Soil taxonomy - a basic system of soil
     classification for making and interpreting soil  surveys.
     USOA Handbook No. 436.
Sopper, W. E., and L. T. Kardos.  1972.  Potential  use of spray
     irrigation in the Tocks Island Regions.  Prepared for Delaware
     River Basin Commission.
Swanson, N. P., L. N. Mlelke, J. C. Lon'mor, T. M.  McCalla, and
     0. R. Ellis.  1971.  Transportation of Pollutants from sloping
     cattle feedlots as affected by rainfall intensity, duration, and
     recurrence.  P. 51-55.  lt± Proceedings of the international
     symposium on livestock wastes,  Amer. Soc. of Agric. Eng., St.
     Joseph, Michigan.
U.S. Army Corps of Engineers.  1968.  The Unified soil classification
     system.  Military Standard  619B.

-------
      Table 1.—Soil Limitation Ratings For Trench-Type Sanitary Landfills!/ —'
Item affecting use
Depth to seasonal
high water table
Soil drainage class
Flooding
Permeability*/
Slope
Soil texture!/
(dominant to a
depth of 150 cm)
lepth to Hard.
bedrock Rippable
Stoniness class?/
Rockiness classZ/
Degree of soil limitation
Slight 1 Moderate
Mot class determining
if more than 180 cm
Excessively drained ,
somewhat excessively
drained, well drained,
and somejL/ moderately
well drained
None
Less than 5 cm/hr
0-5%
Sandy loam, loam,
silt loam, sandy
clay loam
More than 180 cm
More than 150 cm
0 and 1
0
Somewhat poorly
drained and
someV moderately
well drained
Rare
Less than 5 cm/hr
15-25*
Silty clay loam*/
clay loam,
sandy clay/
loamy sand
More than 180 cm
Less than ISO cm
2
0
Severe
Less than 180 cm
Poorly drained and
very poorly
drained
Occasional or
frequent
More than 5 cm/hr
More than 25%
Silty clay, clay,
muck, peat,
gravel, sand
Less than 180 cm
Less than 150 cm
3, 4, and 5
1, 2, 3, 4, and 5
I/ From "Guide for Interpreting Engineering Uses of Soils"  (Soil Conservation Service,  1971).

2/ Based on soil depth  (IS-2 m) commonly investigated in making soil surveys.

3/ Soil drainage classes do not correlate exactly with depth to seasonal water  table.   The
   overlap of moderately well drained soils into two limitation classes allows  some of
   the wetter moderately well drained soils (mostly in the Northeast) to be given a
   limitation rating of moderate.

4/ Reflects ability of soil to retard movement of leachate from the landfills:  may not
   reflect a limitation in arid and semiarid areas.

5/ Reflects ease of digging and moving  (workability) and trafficability in the
   immediate area of the trench where there may not be surfaced roads.

6_/ Soils high in expansive clays may need to be given a limitation rating of severe *

7/ For class definitions see Soil Survey Manual, pp. 216-223 (Soil Survey Staff, 1951).

-------
 Table  2.—Soil  Limitation  Ratings For Area-Type Sanitary Landfills—'
                                                                  I/
Item affecting use
Depth to seasonal^/
water table
Soil drainage^/
class
Flooding
Permeability!/
Slope
Degree of soil limitation
Slight
More than 150 cm
Excessively
drained, somewhat
excessively
drained, well
drained , and
moderately well
drained
None
Moderate
100-150 cm
Somewhat poorly
drained
Rare
Not class determining if less
than 5 cm/hr
0-8%
8-15%
Severe
Less than 100 cm
Poorly drained
and very
poorly drained
Occasional or
frequent
More than
5 cro/hr
More than 15%
I/ From "Guide for Interpreting Engineering Uses of Soils" (Soil Conservation
~  Service, 1971).

2/ Reflects influence of wetness on operation of equipment.

V Reflects ability of the soil to retard movement of leachate from landfills;
   may not reflect a limitation in arid and semiarid areas.
                                        350

-------
   Table 3.—Soil Limitation Ratings For Sewage Lagoons—
                                                       .17
Item affecting use
Depth to water table
(seasonal or year-round)
Permeability
Depth to bedrock
Slope
Coarse fragments, less
than 25 cm in
diameter: percent,
by volume
Percent of surface area
covered by coarse frag-
ments more than 25 cm
Flooding!/
Soil groups (Unified)i/
(rated for use mainly as
floor of sewage laqoon)
Degree of soil limitation
Slight
More than
150 cm
Less than
1.5 cm/hr
More than
150 cm
Less than
2%
Less than
20%
Less than
3%
None
GC, SC, CL,
and CH
Moderate
100-150 cm!''
1.5-5 cm/hr
100-150 cm
?-7*
20-50%
3-15%
None
GM, ML, SM,
and MH
Severe
Less than!/
100 cm
More than
5 cm/hr
Less than
100 cm
More than
7*
More than
50%
More than
15%
Soils subject
to flooding
GP, GW, SW,
SP, OL, OH,
and PT
I/ From "Guide for Interpreting Engineering Uses of Soils"  (Soil
   Conservation Service, 1971).

2/ If the floor of the lagoon is nearly impermeable material at le«st
   60 cm thick, disregard depth to water table.

V Disregard flooding if it is not likely to enter or damage the lagoon.
   (low velocity and the depth less than about 1.5 m)
   Disregard if permeability is less than 1.5 cm/hr and it does not
   increase as a result of building the lagoon.

-------
 Table  4.—Soil Limitations For Accepting Nontoxic Biodegradable Liquid-Waste
Item affecting use
Permeability of the
most restricting
layer above 150 cm
Soil drainage class!/
Runoff!/
Flooding
Available
water Humid—'
capacity
150 cm or
a limiting Arid—'
layer
Degree of soil limitation
Slight
Moderately rapid
and moderate
1.5-15 cm/hr
Well drained and
moderately well
drained
None, very slow,
and slow
None
> 15 cm
> 8 cm
Moderate
Rapid and
moderately slow!/
15-50 and 0.5-1.5
cm/hr
Somewhat exces-
sively drained
and somewhat
poorly drained
Medium
Soils flooded
only during non-
growing season
8-15 cm

Severe
Very rapid, slow
and very slow^/
> 50 and < 0.5
cm/hr
Excessively
drained, poorly
drained, and very
poorly drained
Rapid and very
rapid
Soils flooded
during growing
season
< 8 cm
< 8 cm
I/ Modified from an interim guide for use in the Soil Conservation Service.

2/ Moderate and severe limitations do not apply for moderately slow, slow, and
~~  very slow permeability if layers having these permeabilities are below the
   rooting depth and if evapotranspiration exceeds water added by rainfall and
   waste.

V For class definition see Soil Survey Manual, pp. 169-17  (Soil Survey Staff,  1951).

4/ For class definition see Soil Survey Manual, pp. 166-167  (amended to use  "None"
~  for "Ponded")  (Soil Survey Staff, 1951).

5_/ Humid, as used here, includes soils that have aquic, udic,  or ustic moisture
~  regimes if utilized throughout the year.  For definitions,  see "Soil Taxonomy".

6/ Arid, as used here, includes soils that have aridic or torric moisture regimes
~  and xeric moisture regime if utilized only during  the dry season.   For
   definitions, see "Soil Taxonomy"  (Soil Survey Staff - in  press).

-------
  Table 5.—Soil Limitations For Accepting Nontoxic Biodegradable Solids
Item affecting use
Permeability of the
most restricting
layer above 150 cm
Soil drainage
classV
Runoffi/
Flooding
Available water
capacity from
0 to 150 cm
or to a limiting
layer
Degree of soil limitations
Slight
Moderately rapid
and moderate
1.5-15 cm/hr
Well drained and
moderately well
drained
None, very slow,
and slow
Moderate
Rapid and moderately
slowl/
15-50 and 0.5-1.5
cm/hr
Somewhat excessively
drained and somewhat
poorly drained
Medium
None
> 15 cm
8-15 cm
Severe
Very rapid, slow,
and very slow^/
>50 and <0.5
cm/hr
Excessively drained,
poorly drained, and
very poorly drained
Rapid and very
rapid
Soils flooded
< 15 cm
I/ Modified from an interim guide for use in the Soil Conservation Service.

2/ Moderate and severe limitations do not apply for moderately slow, slow, and
~~  very slow permeability unless the waste is plowed or injected into the layers
   having these permeabilities or if evapotranspiration is less than water added
   by rainfall or irrigation.

3/ For class definition see Soil Survey Manual, pp. 169-172 (Soil Survey Staff, 1951),

£/ For class definition see Soil Survey Manual, pp. 166-167 (amended to use
   "None" for "Ponded") (Soil Survey Staff, 1951).
                                        353

-------
                Table  6.—Information  Available  From Published  Soil  Surveys
                              TABLE «.—PHYSICAL AID CHEMICAL PROPERTIES OF SOILS

    [Daahea Indicate data ware not available.  TIM ayabol < aean» leas than, > neans gr«at«r than   The erosion
        tolerance factor {T> la for th*  «ntlr« proflla.  Abacnoe of  an entry Means data wera not estlnated]
Soil naoe and
nap ayabol
Addicka:
Ad 	 	 	
IAK.
Addlcks part 	
! ' -
Depth 1 Pernea-
1
0-11 t 0.6-2.0
11-49 ! 0.6-2.0
09-78 1 0.6-2.0
i
0-11 ! 0.6-2.0
11-49 J 0.6-2.0
•9-78 ! 0.6-2.0
Available
watar


0.15-0.24
0.15-0.24
0.15-0.21
0.15-0. 2»
0.15-0.24
! Shrink- ! flisfc of corroalon
Soil ! avail \ Uncoated
I j
III ( !


6. 1-8.4 !Low 	 iHlgh 	 	
6.6-6.* (Lou 	 I High 	

Concrete






Ero
fag
0 32
0 37
0.37
0 12
0.37
0.37
Ion
rfaU
5
5
                            TABLE B.—UCIHEEDINO PROPERTIES AND CLASSIFICATIONS
Soil name and
nap symbol
Addicks.
'Ak
P

Depth
ia
1 1-«9
119-78
1 1-119

USDA texture

Loam, silt loan
Loan, silt lo»m,
ailty ally
loam.
Loan , silt loan
silty clay
loam
Cl.»«l
Unified

CL, CL-NL
CL
CL, CL-HL

icatlon
AASHTO

A-4, A-6
A-6, A-7
A-4, A-6

-T—

95-100
95-100
95-100

10 ! 40

90-1001 75-95
90-100190-100
90-100175-95

200
51-75
60-75
60-80
60-75

Unit
£ii
20-!*0
25-"5
20-«0

Plaa-
index
5-l<*
5-iO
11-27
uj-2u

                                   TABLE  C.--SOIL AMD  KATER FEATURES

[Aoaenoe of an entry Indicates the feature  Is not a concern.  See text for deacrlptions of symools
     terms .13 "rare," "brief," and "perohed."  The aynbol  < means leaa than, > meana  greater than]

Soil name and
map symbol
Addlcks
'AH:


Hydro-
logic
group




Frequency




Flooding 	
Duration




Months




Depth
El
1.0-2. 5
1 .0-2.5


Kind . *ontr.-j
Apparent Jan-f-tD
Apparent , Jin-t-eb

              I/This mapping unit  is made  up  of two  kinds of  soil.

-------
Table  7.—Data  Included  in Computer Records  for Soil  Survey  Interpretations!/
            130.  I4«,  I4»
NLNAISII
•CC. »-T
TWIC OrSTROCMMPTS. CO**K-LOAMV«  MIX
F*OM ftfcNDSTOM AM) CONOLOMCHATC, TYPI
SUM01L FNCIi • TC !• 1NCMU It *HM«
SAMOV LOAM. MOHOCK 11 AT 10 INCHES.
.T TMCS* SOIL* NAVK * BMMN BRAVILLV LOAM SURFACE U
>T LOAM. TMB MBtTHATUH FROM It TO M 1MCHCS IS STB<
        PftO* * TO It PtftCCtT.
IIN.»| USOA TKXTUHC 1 UNlPICO
1 '
•-• |L. »-. PBL IML. m
B-B ISH-L. SH-SL. CH-PBL, It*** ML
IB- JO )«*-•.. BB^LS IB*. ••
» |UH« 1
I" "» mHmm 'fte-
AASHTO |>3
1. jiff


1*-* 1 o-t i»s-ist *•-!•• «s*«t as-T» I
A-* | e-lt|B*.«« »•>•• »•«• U-» |
A-** A-4* A-t | •-lt|TS»*S ••*•• J«-«» lt-40 | <2S NP-ft
A»t. A-l |l«*4«|4S»tt 4«-M 3B-4O IB-IS | <2B *M*-1
1 1 1
*.14 [•••~**B I - LO» f L3* 1
t-S | 2*B-B.O | S.1B-B*14 |4.B-*.t | - LOB | LOU
•-IS) *.B-B.« | C*IB-B>I4 |4.S-**B | - COB | LO«
IB-JO) !.*-«.• 1 B-M-i-OS |4.*>«.* | - LOU 1 L3«
M) 1 1 II 1
fill f
1 (W.TH
kJMlTAkV »AfU.ft|f;4 ,1ft
0-IMt «««-OfFW TG WKK
SCPTIC TAMC lt**l SC«>Mt-*LOK*OIPTM TO MCX
AMOFPT1ON
P1CLCS
0-T«r K««E*OCPTM TO *OCK
ftEMACE T*t! SCV0ll-SLOPViDFPTH TO «3CK
LACOCN
AREAS
t-2f»! seve«*-OCPTH TO MOCK.SCCPAOI
SAMTADV 25*«: SEVeP-?-6LO»r . OEPTH TO MCK .•
LAM7FILL
(TAtNCHt
0-1911 sevtRE-jeepAce
LAMOF ILL
 J lltfl,. flM IliMl ' ' ACTION
iwr*"" "Mini* ***
B-XBW POOH TMlN LAVC*
*

UNSUlfcO^KXCUS FINCS
- „.,., .... , , , ..,.,, ........
C-t«»t POOR-SHALL STONES
I**«i POCR-BLOM .SMALL STONfcS

OCPTH TO 10
-------
                MR. LEHMAN:   Okay,  are there any other ques.




 tions?  If not, thank you very much,  Mr. Witty.   I would



 like to call next Mr. Anthony  L. Falla of  the  Kawecki



Berylco   Industries,  Inc.   Is  Mr.  Falla  here?

-------
               MR. PALLA:  My name is Anthony Falla, I'm



an environmental engineer and I work for Kawecki Berylco




in Reading Pennsylvania.  And, this is not a prepared



statement, I have nothing written.  It's extraneous in



nature.   I drafted it as I listened to the speakers, and



bear with me if I sound nervous, I am nervous because



talking about pollution is like talking about sex.



Nobody really talks freely about it but everybody does it.



               So, I appreciate this opportunity to pre-



sent my personal views regarding legislation on hazardous



wastes.   And, the word hazardous to me means dangerous,



and I think if you use that word sometimes that may help



you put things into perspective.



               Many years ago I was told that you solved



your pollution problem when you got rid of the waste off



of your property.   If you didn't get rid of the waste



you didn't solve your problem.  And,  the challenge that



we face today is that we have to do this in a way that's



natural to the environment and it doesn't interfere with



the health or welfare of your neighbor.



               So,  again, when yo u think of hazardous



waste, I think the word dangerous would help define it a



little more.    You are talking about  impact and how does



it relate to the community,  which sometimes could be not



only a city,  it could be along a whole seaboard.




                            357

-------
               I think that any regulation regarding dis-




posal of hazardous waste should include some of the




following items, I certainly don't cover them all.



               1,  You should establish regulatory respon-




 sibility.  I think this should be spelled out clearly.




For example, I think the ultimate responsibility of haza-




dous, defining hazardous waste should not lie in the




jurisdiction of local governments or municipalities.  I




think it should be a state and/or Federal responsibility.




A guideline, for example, I think is the Water Pollution




Control Act, the Public Law 92-500 .which set uo some  relation-



Ship between state and Federal regulations.




               Another item, I think, is you should estab-




lish guidelines for disposal, and the key word here is




disposal, not treatment, although sometimes the two are



hard to distinguish.   For example, if you take organic




wastes, I think you should establish guidelines that are



related to say incineration, thermal decomposition or




say chemical breakdown of the substance or something like



that, you take inorganic aids or  alkalis,  jf the proce-




dure chosen say is neutralization and removal of heavy




metals, then I think there should be guidelines on what




to do with the solids, what to do with the filtrate.




For example, putting into a landfill for solids aid fil-




trate, clear filtrate say disposed via ocean barging.

-------
something like that.   Take solids, and I don't know  if




the technology exists here, but you take encapsulation,




solidification.   Another principle I think has been  men-




tioned is segregation in a landfill, where you can geo-




graphically segregate wastes and you know where they  are




at.




               Another thing maybe you should cover in




that establishment of guidelines would be, for example,




to establish control tests, like leachinq tests and this




has been mentioned for years.   Our company has been  us-




ing, with our consultant, a leaching test where we use




100 grams of material and one liter-, of leachate from  a




landfill.   And you do successive vleachings on the same




solid, maybe four, five, six leachings, using landfill  leach




ate and this gives you, say, initial solubility, and  then




eventually should give you an equilibrium solubility.




And, this, I think, simulates to some degree, what goes



on in a landfill, because eventually  j.n a landfill you




must hit an equilibrium condition, although it is con-




stantly changing probably to a certain degree.




               The third thing I want to mention, I think




legislation should include or should establish a certifi-




cation procedure for waste treatment firms and for firms




who supply a treatment procedure for hazardous waste.




It seems to me that in today's economy and with the




                         •;«.' o
                          '

-------
available technology today, private waste treatment firms
are desirable and I think some kind of certification pro-
cedure would help a person choose an acceptable outlet.
It is my opinion that most people want to get rid of their
wastes in an acceptable manner and this would certainly
be a big help.
               The last one I have here, and I don't know
how to exactly describe it, is the legislation shouldn't
close all doors.   This has been mentioned previously by
Mr. Roy.  He talked about the best practical treatment,
the best available treatment.  Here again, Public Law 92-500',
I think, may serve as a guide where you have certain
available technology today, best practical technology to-
day.   You could set up the law such that it could be
something that could change in time and work with what
you've got today and then as time goes on make it better.
               Thank you very much for allowing me this
opportunity.
               MR. LEHMAN:  Thank you, Mr. Falla.  Will
you answer questions?
               MR. FALLA:  Yes.
               MR. LEHMAN:  Mr. Lindsey?
               MR. LINDSEY:  Mr. Falla, you mentioned the
landfill leachate test, could you elaborate on how that
works?   In other words, I guess one question I would
like to have you elaborate on is, how is the concentration
                               360

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issue handled in this test?   What concentrations of the
hazardous material, must be reached before you become
concerned, and secondly, could you send us information on
this test?
               MR. PALIA:  The second one, yes.  We could
send you an outline of procedure that we use.   It is
something that is not formal but I have no reference for
it.   But, the way we have been using it and did use it
on one occasion with the Pennsylvania Department of En-
vironmental Resources, and they accepted it, in fact they
were the ones that made us do it.  We did it with dis-
tilled water, and I think this point was brought up be-
fore, they are the ones that said you've got to go out
and do it with landfill leachate because landfill leach-
ate is a lot different from distilled water.
               And, we set up successive leachings.   We
would take 100 grams of air dried material, usually if
you put some of this stuff in an oven, you may decompose
it, so we set up the criteria, air dry it, so it is reason
ably dry, and not very wet.   So you take 100 grams and
then you take a liter  of leachate.  In other words, the
philosophy here is to take a large volume of water and a
small amount of sample, so that you will hopefully reach
an equilibrium.  Your first leachinq  generally will  have your
highest concentrations because with some of these solids
                         361

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you might have mother liquors attached with it cr something




like that, so you leach out the most soluble oortions  in



the very first leaching and that gives you some idea 'of what




the initial leachate will look like, and then the succes-




sive leachates will slowly decrease untj.1 you reach an




equilibrium, or some constant value.   You should repeat




these tests until you reach that constant..value..and vou'll



end up with a curve that starts out high and comes down




to some steady number.   And, I interpret that number as




being the solubility or equilibrium value of the iron that




we are looking for and usually analyze for heavy metals or




whatever else you are interested in, in that particular




environment.




               MR. LEHMAN:  Do you have another question?



               MR. LINDSEY:  You mentioned the possible




certification of people who are in the treatment and I



guess disposal business, what did you have in mind?   Or,




what is involved in certification, is that a permit sys-




tem, that's what I think of, but maybe you have --




               MR. PALLA:   Well, I didn't want to go as




far as permit, but first I think it should be state or




Federal.  I don't think certification should be on a lo-




cal level, not when you are dealing with hazardous wastes,




and I want to emphasize the fact that we are specifying




hazardous wastes.   You define a waste as hazardous, that

-------
should put it into a category which is beyond the local




and municipal government's capability.




               So, certification, what I am trying to do




here is, I think these waste treatment firms should be




evaluated and it is pretty hard for an individual to evalu-




ate because we can't always get the facts sometimes and




I think the governmental agencies are in a better position




to evaluate a waste treatment firm and certification to




me would just say that they are complying with rules and




regulations that are applicable to that area.




               Now, it doesn't necessarily mean you have




to have a permit, although I would think that they would




have to have permits to get rid of say the liquid efflu-




ent and the solid waste.




               MR. LEHMAN:  Are there any other questions?




No.  Thank you, Mr. Falla.
                             ob3

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KAWECKI BERYLCO INDUSTRIES, INC.
                                    P. O. Box 1462, Reading, Pa. 19603
                                        Telephone: 215/929-0781
15 December 1975
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs AW-565
U.S. Environmental Protection Agency
Washington, D.C.  20460

Dear Sir:

     At the public meeting on hazardous waste held in
Newark, N.J. on December 2, I presented a statement in
which reference was made to a solids leaching test procedure.
A request was made by a member of the panel for details
on the leach test procedure.  The leach test procedure is
given below with comments for inclusion as part of the
record of that public meeting.

     LEACH TEST ON SOLIDS FOR DISPOSAL IN LANDFILL:

     A.  OBJECTIVE

         The objective of the leach test is to determine
which ions leach from the waste solids; determine whether
the leaching is a continuing process; and determine equil-
ibrium solubility levels.

     B.  TEST PROCEDURE

         One hundred grams of dry solids  (usually air
dried if solids are sensitive to heat) are mixed with 1000 cc
of filtered landfill leachate (if available) and agitated
continuously for 24 hours.  The slurry is then filtered and
the solids portion subjected to another 24 hour leach with
1000 cc of fresh landfill leachate.  The above procedure is
repeated for four to six consecutive leaches.

     Notes:

     (1)  On occasions, it may be desirable to run simultaneous
                   METALS . ALLOYS • CHEMICALS

-------
                   KAWECKI BERYLCO INDUSTRIE* INC
                          Reading. Pa 19603
leach test using distilled water as the leaching media to
determine if the leachability differs from landfill leachate
which usually may contain acidity and organics.

     (2)  On occasions, if there is evidence of a chemical
reaction, e.g. oxidation of Chromium 3 to Chromium 6, then the
24 hour leaching period should be increased to 72-96 hours
to determine equilibrium conditions of the reaction.

     (3)  Other than air drying and utilizing proper sampling
techniques, no attempt is made to regulate the characteristics
of the solids to be tested.  One factor which would influence
the results of this test is particle size.

     (4)  This test is suitable for industrial waste precipitates
and for solids that are not too bulky.

     C.  REPORTING OF RESULTS AND INTERPRETATION OF DATA

     Results are generally tabulated or plotted to show changes
in concentration of the leachate with each succeeding leach.

     Ion concentrations which continually decrease and reach a
constant value lower than that originally present in the landfill
leachate indicate that the solids being evaluated have a
beneficial effect on the landfill.  This result could occur for
example on parameters such as iron, BOD, COD, and some heavy
metals when the alkalinity or pH of the leachate is increased.

     Ion concentrations which increase very rapidly and then reach
a constant value imply either a chemical reaction or solubility
limit.

     Ion concentrations which increase slowly and then reach a
constant value imply solubility limit.

     Ion concentrations which increase initially and then decrease
to a constant value imply presence of a very soluble constituent
which eventually is depleted or reaches an equilibrium value,
e.g., adhered mother liquor if from a filtering operation.

     Ion concentrations which show no change imply no adverse
effect by solids being evaluated.

     Ion concentrations which continually increase imply degradation
of material resulting in increased solubility.
                                  3G5

-------
                    KAWECKI BEKYLCO INDU8TRIE& INC
                           RtxJing. P.. 19603
     Ion concentration which vary  and  show no  definite trend
imply analytical error or solubility effect from particle size
variation.

     Note:  Our experience has generally  been  that ion concen-
trations usually reach a constant  value either on the upward
side or on the downward side.

     Thank you very much for the opportunity to present the
above information.
                              Very  truly yours,

                              KAWECKI  BERYLCO INDUSTRIES,  INC.




                              Anthony, L. Fala
                              Environmental Engineer
ALF:pad
                                 366

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               MR. LEHMAN:   Our next speaker, Mr. Lawrence]



Cushman from Plymouth State College.  Is Mr. Cusnman here?



He was down on our list of people desiring time to speak



and yet this must be about the fourth time we have called.



I gather he is just not able to come.



               Well, ladies and gentlemen, that completes



the roster of people who have requested time for prepared



statement, or not a prepared statement.   Let me just




issue one last call.  Is there anyone in the audience who




                            367

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would like to make a statement at this time?  Mr. Sanjour?
               MR. SAwJOUR:  I just want to say, it has
been suggested to me that these proceedings, Mr. Chairman,
be published, and I thought I would throw that idea up to
you, perhaps in TIS, or some other mechanism like that
rather than merely have them available to someone to come
in and read.
               MR. LEHMAN:  All right.  It has been sug-
gested by several members of the audience that the.proceed-
ings of this hearing, or this public meeting, excuse me,
and the others that are pending, in the other three cities
be published rather than being merely  made available for
public inspection, which is our current plan.
               And, let me just comment on that, that our
original thinking on this was that the record might be a
very voluminous document.   When you get as much informa-
tion as has been developed here today, and multiply that
by four, it might be an excessively large document to re-
produce and to distribute.
               However, what I think we should do and will
do is hold that decision in abeyance until we see what the
response is from the other meetings around the country.
And, if it turns out not to be an  onerous task,  then per-
haps we can do that.   I'm just trying to point out why
we were not planning to publish this in the first place.

                         368

-------

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               Now, if the demand is there, then perhaps



that would influence our decision too.   So, if you feel



a necessity for this, that might influence it, you might



let us know.



               We are about ready to close the meeting



now.   Is there anyone who has a statement for the record



that they did not wish to present orally?  All right.



As we pointed out earlier, this is not the last chance,



you can also submit any statement to the record, to the



address given in the Federal Register by January 31,



1976 and it will be considered as part of the record.



               I would like very much to thank you all.



Excuse me, we have one point here.



               SPEAKER:  Do you have a feel for when the



proposed law might be written, when it might be promul-



gated?



               MR. LEHMAN:  Well, the appropriate person



to address that question to would be the gentlemen in the



U.S. Congress and not to me.   All I can do is just com-



ment in general terms, we have made reference to Senate



Bill 2150 today, which is under active consideration in



the Senate Public Works Committee, called the Solid Waste



Utilization Act, 1975, and it is our understanding that



a companion bill is in the draft stage in the House of




Representatives.  But, really to go beyond that and make




                           369

-------
some opinion about how fast the Congress is going to move,




I think would be hazardous.   Let's say that we are hope-




ful that they will move quickly on it, but have no indi-




cation as to when they intend to move on it.




               All right, with that, I want to again




thank you all very much for coming and participating in




this public meeting.   Speaking for EPA, I can say that




we have learned an awful lot and I hope you in the audi-




ence have too, and we will look forward to the next series




of meetings in the other cities, and hopefully they will




be as productive as this one was.   With that, I'll ad-




journ the meeting and call it a day.   Thank you.




               (Whereupon the meeting was adjourned.)
                         370

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                         INDEX

                                                 PAGE

 1)  William B. Philipbar
        Rollins Environmental Service             13

 2)  Jesse R. Conner
         Chemifix, Inc.                           25

 3)  J. J. Santoleri
         Trane Thermal Co.                        34

 4)  Philip A. Palmer
         DuPont Co.                               52

 5)  David A. Boltz
         American Iron & Steel Institute          71

 6)  Al Gathman
         Scientific, Inc.                         86

 7)  A. Blakeman Early
         Environmental Action                     99

 8)  J. Gallay
         SBB Ltd. - Germany                      112

 9)  David Nalvln
         NJMPRS Assn. - Moore                     129
                                                 137
10)  Diane T. Graves
         Sierra Club                             152

11)  Clarence Roy
         American Electroplaters Society         162

12)  Capt. Hugh McCabe
         New York City Fire Department           169

13)  Jack Miller
         Pollution Abatement Services             175

14)  Ed Shuster
         Chemtrol

15)  Warren Kinsman
         Atlantic Terminal Corp.                 197
                          371

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                                                 PAGE


16)  Robertcanace
         Maplewood,  N.J.                           206


17)  John E. Whitey
         U.S. Soil Conservation Service           211


18)  Anthony Falla                                2l6
                            372

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                     PUBLIC MEETINGS

                       held at the

                0'HARE-KENNEDY EXPRESSWAY
                       HOLIDAY INN

                   ROSEMONT, ILLINOIS
                        Thursday,
                    December 4, 1975

                        8:30 A.M.
                      PANEL MEMBERS
John P. Lehman, Director
Hazardous Waste Management Division (HWMD)
Office of Solid Waste Management Programs, EPA

Walter W. Kovalick, Jr., Chief
Guidelines Branch, HWMD
Office of Solid Waste Management Programs, EPA

Emery Lazar, Program Manager
Environmental Damage Assessment, Technology Branch, HWMD
Office of Solid Waste Management Programs, EPA

Alfred W. Lindsey, Program Manager
Technology Assessment, Technology Branch, HWMD
Office of Solid Waste Management Programs, EPA

Murray Newton, Program Manager
State Programs, Implementation Branch, HWMD
Office of Solid Waste Management Programs, EPA

Karl J. Klepitsch, Jr., Chief
Solid Waste Branch
EPA Region V

-------

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          MR. LEHMAN:  Ladies and Gentlemen, may

I ask you to take your seats and we'll get started.

               I call this public meeting to order.

Good morning ladies and gentlemen, my name is John P

Lehman, and I'm Director of the Hazardous Waste

Management Division, office of  Solid TVaste Management
Programs,-                            United States

Environmental Protection Agency, Washington, D.C.

               I would like to  introduce Mr. Valdis

Adamkus, Deputy Regional Administrator for Region V

of the U.S. Environmental Protection Agency, who

has some opening remarks.

               Mr. Adamkus.

          MR. ADAMKUS:  Thank you Mr. Chairman,

good morning ladies and gentlemen.  I hope you can

hear me over there.

               I would like to welcome all of you

who have come to Region V to attend this public

meeting.  This meeting is designed to gather in-

formation from industry, government and public

interest groups concerning the area of hazardous

waste management.

               Samples of hazardous wastes include

toxic chemicals, pesticides, acids, caustics,
                         -" -•
                         ! 7

-------
flammables and explosives, biological and radiological



residuals.



               It is estimated that the total volume



of non-radioactive hazardous wastes is generated



annually in this country -- it's approximately 10



million tons per year, or roughly 10 per cent of



all industrial wastf.



               The primary source of this waste is



the industrial sector where contributions are being



made by hospitals, laboratories, and Federal  govern-



ment itself.



               Of the national total of hazardous



wastes generated, this region is estimated to generate



about 25 per cent.  Only in the last year or two  has



the public heard and felt effects of improper hazardous



waste management been under serious study.



               This problem has manifested itself in



groundwater contamination by wastes leaching through



the soil and surface water contamination  via run-off am?




air pollution  via  open burning, and food contamina-



tion via improper storage, and personal injury via



direct contact and explosions which may result from



the improper mixing of wastes.



               The problems of improper handling





                          378

-------
of this waste can have both short term acute effects
and long term  chronic effects.
               We are now faced with increasing
possibilities for adverse impacts from hazardous
waste   management from at least three sources.  The
first is the expansion of industrial production,
which is tied directly to hazardous waste generation.
Second, is the transfer of hazardous materials from
other media as a result of air and water pollution
controls.  Third, is the increased hazardous waste
materials generated as a result of ocean dumping
controls, and bans on certain materials such as
cancellation of pesticides.
               When all of these factors are con-
sidered it is estimated that the growth of hazardous
waste generation in this country will be between
5 and 10 per cent per year.
               In order to minimize those impacts
to the public health, due to existing and future
production of hazardous wastes, we are beginning
to look at the future role of the Federal government
in the management of these wastes.
               Fulfillment of this development of
the Federal role will require a major cooperative
                       379

-------
effort on the part of many different organizations



to make this all happen.  Waste generators, waste



treatment and disposal contractors, local, regional



and state governments, academia and the Federal




government  must all communicate and work together



as we are doing here today.



               Your participation in today's public



meeting will aid us in finding the answers to



problems we find in managing this waste and perhaps



more important the future direction of the Federal



program.



               To offer further comments and to



expand upon the reasons for today's meeting, I would



like at this time to formally introduce Mr. John



Lehman, Director of the Hazardous Waste Management



Division, Office  of Solid Waste Management Programs



of the United States        Environmental Protection



Agency.



               Thank you and welcome all of you.




          MR. LEHMAN:  Thank you Mr. Adamkus.



               Let me add my welcome to that of Mr.



Adamkus.  The purpose of this public meeting as



announced in the Federal Register of September 17th,



1975, is to gather information and data for the







                        SCO

-------
agency as to the scope and nature of the hazardous




waste management problem in this country, and the




need for and extent of guidance that should be




developed by the agency to help cope with this problem.




               For the purpose of this meeting, hazardous




wastes are non-radioactive discards of our technologically




based society.  They include toxic, chemicals, biological,




flammable and explosive by-products of the nation's



extractive, conversion and process industries.




               This is not a rule making or regulatory




hearing.  The agency does not have a proposal or a




statement to issue for comment.  This is a fact finding




meeting, on the record, to solicit input from industry,




labor,  Federal  state and local governments, and other




members of the public as to the extent of the manage-



ment of hazardous wastes and the available or anti-




cipated systems and the technology to abate this



problem.




               In order to provide a framework for




discussion today,  the Federal Register notice announc-




ing this meeting suggested 16 discussion topics that




reflect issues of concern to the agency.  Commentary




on this and any other related topics are what we




are mostly interested in hearing today.

-------
               Copies of this Federal  Register  are




available on the table in the back  of  the  room,




along with our publications.




               I am also submitting a  copy of the




Federal Register notice for the  record.




               The panel here with  me  is composed




of staff of the Hazardous Waste  Management Division




in Washington, D.C. and EPA' s Region V office in




Chicago, who specialize in certain  subjects and




areas related to this issue.




               They are from your left Mr. Karl




J. Klepitsch, Chief of the Solid Waste Branch,



EPA Region V, Mr. Emery  Lazar, Program_Manager




for7 Environmental Damage Assessment of the Hazardous



Waste; Management  Division, Mr. Walter KovaJ-icJc,




Chief Guidelines Branch in the Hazardous Waste




Management Division, Mr. Alfred Lindsev.- Program ._



Manager for Technology Assessment in the Division,




and Mr. Murray Newton, program Manager for State




programs also from the Hazardous Waste Management




Division.



               Also assisting us are Mr. Alan Corson




and Mr. Donald Farb who I also understand  are there




at the back of the room and will be assisting us
                          362

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with questions, and also Mr. Metcalf who stepped




out for a moment.




               In addition to this meeting in Chicago




today, three other identical sessions are being held




in Houston, San Francisco and two days ago we had one




in Newark.  During these first two weeks of December,




persons not wishing to deliver a statement here or




at the other meetings, may send a written statement




to the address noted in the Federal Register before




January 31st, 1976.




               As our time here is limited, I would




now like to describe the procedural rules for this




meeting, which I feel will maximize the opportunity




for persons interested in speaking to be heard and




yet make the best use of all of our time.




               persons wishing to make an oral state-




ment who have not made an advance request by tele-




phone or in writing, should indicate their interest




on the registration card.  If you have not indicated




your intention to give a statement, and if you decide




to do so, please return to the registration table




and fill out another card and give it to one of the




staff.




               As we call upon an individual to make

-------
a statement, he should come up to the lectern and




after identifying himself for the court reporter,




deliver his statement.  At the beginning of the




statement I will inquire as to whether the statement




-- the speaker is willing to entertain questions




from the panel.  He is under no obligation to do




so, although within the spirit of this information




it would be of great assistance to the agency if




questions were permitted.




               It is expected that statements will




not exceed 15 minutes in length, for extraordinarily




long written statements I would suggest a brief oral




summary, and submission of the full text for the



record.




               The Chairman reserves the right to




close off statements which are excessively long,




irrelevant and extraneous, or repetitive.



               Assuming that the speaker is permitted




questions members of the audience will not be per-




mitted to  direct question to the speaker, but rather




members of the audience may obtain a 3 by 5 card




from a member of the staff upon which questions may




be written.



               You can obtain such a card by merely

-------
raising your hand.  These cards will be collected



by the staff and returned to the panel for con-



sideration during the questioning period.



               If a written question from the audience



is not presented to the speaker because we run short



of time, I will then ask the speaker to respond to



those questions in writing for the record.



               A transcript of this meeting is being



taken, a copy of the transcript together with copies



of all documents presented at the hearings, and all



written petitions will constitute the record of the



meeting.



               A copy of the record will be available



for public inspection by March 30th, 1976, at the



U.S. Environmental protection Agency, Public Infor-



mation reference unit, Room 2404, 401 M Street



s.w.,      Washington, D.C. 20460.



               Finally I would like to describe



today's activities as we currently see them.  We



will recess for 15 minutes at 10:30 A.M., a one



hour luncheon break at 12:15 P.M. and reconvene



at 1:15.  And then hold another 15 minute break




at 3:30 P.M.  Depending on our progress, I will



announce plans for a dinner break after lunch.

-------
               At this time we plan to conclude




this meeting today.  In order to facilitate the




comfort of all I suggest that smokers sit on the




left side of the room facing front, and non-




smokers toward the right.  This concludes my opening




remarks.




               I now call upon Mr. W. S. Brenneman




of the Illinois Power Company to deliver the first




statement.




               Mr. Brenneman indicates he will




entertain questions.




          MR. BRENNEMAN:  First I want to preface




these remarks with a few ad lib ones.




               Last night after gorging on a gourmet



dinner, I thought this may not be a hazard to your




health but it certainly is to your pocketbook.




Similarly 20 copies of this dissertation may not




be a hazardous waste but I pray  if it is, it's not a




waste of a renewable resource, and that is wood




fiber.




               Today I have two main thrusts, one




is please don't over-control.  This is a real hazard




to our health, and remember today's waste may be




tomorrow's resources.

-------
               Now this is an oral statement for




this public meeting.  My name is William S. Brenneman




and I'm employed by Illinois Power Company of Decatur,




Illinois.  I received a degree in Forestry at Michigan




State University in 1948, and my present title is




Land Use and Conservation Supervisor in the Company's




Department of Environmental Affairs.




               Like most of the public, I'm not




certain what wastes are hazardous, or if they are




really wastes.  Today's time constraints, plus my




limited knowledge, will, you'll be glad to hear, limit




this statement to three substances which are usually




wasted now.




               So-called waste number one, fly ash.




prior to World War II, the nation's power was




generated in a multitude of small plants.  Some of




the ash   generated in burning coal was discharged




into the air via short stacks and fell nearby as




soot.




               Heavier ash  or cinders, were used




on roads during snows, spread on the roads to




prevent skidding.  Today's efficient plants, which




generate possibly 100 times more electricity than




the old teakettles, electrostatically precinitate

-------
perhaps 99 per cent of the fly ash.  This ash, plus




bottom  ash or cinders, is stored in a large pit




adjacent to the plant.




               In metropolitan areas, varying quantities




of  ash are sold or given away for manufacturing



cinder block, fill and cindering roads.




               In rural areas, at mine mouth plants,




uses for ash  are limited and most must be stockpiled,




or if you will, wasted.




               But future technology and economics




may allow this waste to become a resource.  Effluent




from ash pits may contain trace amounts of heavy




metals, may be alkaline, and may contain  suspended




solids.  But  these constituents should not cause




coal ash to be classified as a  hazard or toxicant.



                     It may become a valuable future




resource.




               William T. Flass, Northeastern Forest




Experiment Station, U.S. Forest Service, and John




Capp Morgantown Energy Research Center, U.S. Bureau




of Mines, have suggested using fly ash for reclaiming




extremely acid surface mine sites.




               Presently they have only suggested




this use for  fly ash.  In the future, it may prove

-------
to be a most economical solution to strip mine




reclamation.  However, if inappropriately classified



as hazardous, fly ash could not be used for reclamation.



               So called waste number two, wood chips,



tree clearance for overhead lines annually generate



millions of tons of organic waste.



               I extrapolated that from the wet chips



 that our company generates and what I figured other



companies did, and it may be a little high but probably



not too much.



               In Illinois, the State EPA stipulates



such chips must be most expensively disposed of in a



registered landfill, where they are covered with six



inches of earth each day.  Previously, the chips



could be disposed of by dumping in a farm gully,



dumping in a leased or owned ravine, or burning.



               The leachate from a pile of decaying



chips should not be considered toxic, at least in



my opinion, any more than should the runoff from



forest litter or duff.



               So-called waste number three, sludge



disposal.  Chicagoland's Metropolitan Sanitary District,



USD, is said to have a 20 year supply of sludge at




Stickney.
                            "* Cn
                            w ^ ---'

-------
               Since 1970 MSD has been pioneering



in strip mine reclamation with sludge in Fulton



County.  The semi-liquid sludge is incorporated



directly into the soil by discing.  Erstwhile



barren land now yields crops of wheat, corn and



soybeans.



               The leachates are monitored in sur-



face and subsurface waters.  The harvested grain



is analyzed for heavy metals.   Todav   I understand,



toxic leachates have been insignificant.




               The trace amounts of heavy metals



in the harvested grain are not considered harmful.



The MSD received the American Society of Civil



Engineers' Outstanding Civil Engineering Achievement



award for 1974.  It would be a shame to eliminate



this valuable resource as hazardous.



               In summary, the three previous



illustrations demonstrate the need for reasonable-



ness and thorough evaluation by regulators when




promulgating future hazardous waste regulations.



               Certainly let's dispose of the



cyanides and arsenics with great care.  But,  really



now, what's so hazardous about a pile of wood chips.




Or a nearly immeasurable amount of heavy metals, in

-------
grain harvested from sludge  treated  lands,  is it




a real threat to our health?




               Thank you.
                         331

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Physical  and  chemical
characteristics  of
surface  mine  spoil
treated  with fly  ash
WILLIAM T. PLASS and JOHN  P. CAPP
ABSTRACT—Use of power plant fly ash for surface mine reclamation offers
an attractive outlet for large tonnages of this waste material. Research by the
U. S. Bureau of Mines beginning in 1963 showed that fly ash could be used to
neutralize extremely acid surface mine spoil.  The agency's treatments favored
establishment of grass and legume cover by modifying chemical and physical
characteristics of the spoil.  Described here arc changes tiiat occurred in a spoil
following the application of 150 tons of fly ash per acre.  The treatment neu-
tralized acidity, added plant-available  phosphorus, lowered spoil density, and
increased subsurface moisture.
pRONOUNCED physical, chemical,
•  and biological changes take place
on the earth's surface when it is dis-
turbed to expose minerals. In the 12-
state Appalachian region where coal is
recovered by surface mining, erosion,
massive earth slides,  acid formation,
and stream pollution may result.
  Proper reclamation and the estab-
lishment  of perm an en t vegetative
cover may minimize this environmen-
tal damage. However, vegetation may
be difficult to establish on some sur-
face mine spoils because  of nutrient
deficiencies, unfavorable  moisture
regimes, acidity, and  excessive  salts
or toxic substances.
  Many of these conditions can be
modified or corrected by treating the
spoil  with  some  ameliorating mate-
rial.   Power plant fly ash offers an
attractive opportunity.   Millions  of
tons of fly ash are produced annually
in coal-fueled generating plants.  The
alkaline fly ashes, which  are rich in
some plant nutrients, can be used to
revegetate  acid  mine spoils.  Recom-
mendations regarding sources of suit-
able fly ash and rates of application
-are  being  developed  by the U.  S.

  William T, Plasx u princii>al pltmt ccolo-
gist at the U, S Forctt Service's Northeatt-
ern forest Ex)terintent Station t'orcvt  Prod-
ucts  Marketing Laboratory  in  Princeton,
We*t Virginia 2J7J0. John P. C«MM u diem-
teal research engineer at the Morgantown
Energy Research Center of the V. S llureait
of Minn, Morgantotvn, West Virginia 26505.

MAY-JUNE  1974
                                    Bureau of Mines' Morgantown, West
                                    Virginia,  Energy Research Center.
                                      This report  describes the  changes
                                    in chemical and  physical  properties
                                    of an extremely acid spoil after treat-
                                    ment with 150 tons of alkaline fly ash
                                    per acre.
                                                Background
                                      In early studies of fly ash use, sur-
                                    face mine reclamation was recognized
                                    as a promising outlet for  large ton-
                                    nages. Greenhouse studies initiated
                                    in 1963 by the U.S. Bureau of Mines
                                    at Morgantown showed several spe-
                                    cies  of grass commonly used for sur-
                                    face mine revegetation would grow in
                                    soil treated with fly ash.  Field trials
                                    in 1965 showed  that good stands  of
                                    tall  fescue  (Festuca   arundinacea),
                                    orchardgrass (Dactylis glomerata},
                                    and  birdsfoot trefoil  (Lotus  cornicu-
                                    latis) could be established on an ex-
                                    tremely acid surface mine  spoil after
                                    treatment with fly ash. Further field
                                    tests in 1966 and 1968  compared ap-
                                    plication  rates and fly ash sources.
                                      In 1970 a demonstration  was estab-
                                    lished on a 65-acTC rocky spoil area
          that had been surface-mined 25 years
          before and later partially leveled. Fly
          ash  \\as used to neutrah/r  llir ex-
          tremely acid spoil, then acid-tolerant
          grasses and  legumes were seeded.
            Before treatment, spoils at all these
          sites were extremely  acid l>ecatise of
          pyntic minerals in the coal and over-
          burden.  p!I ranged from 2.5 to 3.5
            The surface spoil on all sites ap-
          peared to dry out rapidly. This could
          have been due to low infiltration rates,
          poor percolation, or low water-holding
          capacity. Soil textural classification of
          the soil-size fraction  (2 mm or less)
          indicated the soils were loams, sandy
          loams,  or clay loams. In  all cases,
          rock fragments larger than 2 mm com-
          prised a high percentage of the spoil
          volume
            This research showed that applica-
          tions of large quantities of alkaline
          fl\  ash could  produce the following
          chemical and physical changes: lower
          bulk  density,  increased  pore  space,
          increased available water, an increase
          in several plant nutrients,  and neu-
          tralization  of some  acidity.  These
          changes improved  the  chances for
          successfully  establishing a vegetative
          cover. Speculation followed that de-
          creased  bulk  density and  increased
          pore space may have resulted in great-
          er rates  of infiltration and significant
          increases in  moisture below the  fly
          ash-treated surface layer.
            The effect of fly ash  applications
          on  subsurface moisture  was investi-
          gated jointly by the Morgantown En-
          ergy  Research Center and  the U.  S.
          Forest  Service's  Northeastern  Forest
          Experiment  Station.  This study was
          established  on a 3-year-old, leveled
          surface  mine bench.  The  fly  ash
          came from the Fort Martin generating
          plant  near  Maidesville,  West Vir-
          ginia

                       Procedure
            Three contiguous  60  X  120-foot
          plots  were  established on  the site
          One of the  following treatments was
          assigned to each  plot   (a)  control
           (no fly ash and unscarified), (b) scar-
                                    Table 1. pit and available phosphorus, by treatments.
                                                                                             e f (,,,iin)
                                    Chcx-k
                                    S<,.mfit.ati
-------
 ified (no fly ash but surface scarifica-
 tion), (c) fly ash (150 tons of fly ash
 per acre  and  surface  scarification).
 The rate of application, 150 Ions per
 acre,  was  equal to  15 percent  by
 weight for the plow layer.  Scarifica-
 tion was  accomplished with a two-
 chisel  subsoiler  to  a  depth  of  12
 inches.  The fly ash  and scarification
 plots were plowed and disked to pre-
 pare a seed bed.  Both plots were fer-
 tilized and seeded to grasses and le-
 gumes.
   So that measurements of soil mois-
 ture and density could be made with
 a nuclear meter,  10  access tubes, 20
 feet apart, were installed on each plot.
 Plastic tubing  (1.5-inch inside diame-
 ter) was inserted in  each of the  4.5-
 foot-deep  access  holes.  A seamless
 aluminum collar was attached to the
 top of each tube to accommodate the
 meter.
   A recording raingage  on the  study
 area documented  precipitation during
 the study period.
   Moisture was  determined with  a
 neutron-activated density  and  mois-
 ture probe following the method de-
 scribed  in USDA Agricultural  Re-
 search  Bulletin  No.  41-24,  August
 1958.  A necessary modification of the
 method substituted plastic for alumi-
 num tubing, since the latter could be
 quickly  destroyed by acids in  the
 spoil.  Although absolute values were
 not determined with the plastic tub-
 ing, the error  was the  same for all
 tests; so the relative  values could be
 used to  determine changes  in  mois-
 ture.
   Moisture measurements at depth in-
 tervals of 1 foot were made initially
 on June 11,  1970, and continued  at
 weekly intervals  until  October  29,
 1970.
   Once during this period density was
 measured  at  1-,  2-,  3-,  and  -4-foot
 depths with a nuclear density probe.
   The field  data  on soil moisture
 were reduced and analyzed by a com-
 puter program  written in Fortran IV
 (4). Density data were reduced with
 a  similar program. Each access hole
 was considered  a  sampling  point.
 Therefore,  10 subplots or access  holes
 described the  moisture  and  density
 following each of the three treatments.
   Sampling to  determine surface soil
 moisture gravimetrically  began  early
in May and continued at weekly  in-
tervals until  early August.  On  each
sampling  date,  a  composite  of five
             0-6 in depth

           12-18 in depth
          Scarified  Scarified  Control
           with      only
          fly ash
 Figure 1. Particle-size distribution of spoil
 after treatment.
 Figure 2.  Mean spoil density at various
 depths by treatment
 samples from the surface 3 inches was
 was collected on each plot. Standard
 procedures  were used  to  compute
 total moisture  for  each  composite
 sample.
  At three locations on  each plot, a
 sample  weighing approximately  10
 pounds was  collected from  the sur-
 face 6 inches of spoil,  and another of
 similar  size was collected  at a depth
 of  12 to  18 inches.   These samples
 were used  to  compare  particle-size
 distribution between treatments.  Each
 sample  was  air-dried and screened
 through  sieves  with  the  following
 mesh sizes:  0.75 inch, 0.50 inch, 025
 inch, and  2 mm.  The percentage dis-
 tribution by weight was computed for
 each  sample.
  pH  and  percentage of available
 phosphorus  for  the surface 6 inches
 were determined for 19 samples from
 each  plot.  Laboratory determinations
 of pi I were  made with a  glass elec-
trode pH  meter from solutions using
 two parts distilled water and one part
spoil. Available phosphorus was de-
 termined from solutions extracted us-
 ing the Bray No. 1 procedure.

       Fly Ash Effects on Spoil

 Chemical  Characteristics
   Soil pH is among the more impor-
 tant chemical  properties  governing
 the availability  of nutrients to plants.
 For  example, molybdenum  sorption
 by plants  increases as pH increases.
 In contrast, zinc sorption increases as
 pH decreases.
   The median  pH of the spoil fol-
 lowing the fly  ash treatment at this
 test site was 6.4.  For the untreated
 check and scarified plots, pH was 3.6
 and 3.3, respectively (Table 1),
   Similar  increases in  pH were ob-
 served after  fly ash treatment of spoil
 and refuse banks at  other  Bureau of
 Mines experimental sites (1).
   Martens noted the same effect in
 studies to  determine the availability
 of plant nutrients in fly ash (2), He
 found that many fly ashes were  alka-
 line and neutralized only 0.04 to 3.37
 meq. H30  +/g,  compared with about
 20 meq.  HsO-f-/g for calcium carbon-
 ate.  From these data  he  concluded
 that fly ashes differ in their ability to
 neutralize  soil and that considerably
 more fly ash  than  calcium  carbonate
 is required to bring the pH of the
 spoil to a specified level. Nonetheless,
 the availability of nutrients in soils is
 affected  by changes  in pH resulting
 from fly  ash  application.
   Investigators  have found  that  fly
 ashes range  widely in plant  nutrient
 content.  Except for nitrogen, the per-
 centages of many macro- and micro-
 nutrients in fly  ash are the same or
 somewhat higher than in natural  soils.
 When fly ash is  applied at a rate of
 150 tons  per acre, many essential nu-
 trients are  added (Table 2). Martens
 showed that selected fly ashes at con-
 trolled rates  of  application  increased
 boron uptake in  alfalfa, increased al-
 falfa  yield by  additions of soluble
 molybdenum, and  corrected zinc de-
 ficiencies m corn (3),
   Fly ash  may also add phosphorus.
At the 150-ton   application rate,  as
 much as 400 pounds  of  phosphorus
 per acre  could be added to the soil.
   In  thii study  there was an  oppor-
 tunity to compare the phosphorus on
 the scarified plot treated with a com-
mercial inorganic  fertilizer  and  the
spoil  treated with  the same  amount
of fertih/er and 150 tons of Fort Mar-
                                                       333
                                                                    JOURNAL OF SOIL AND WATER CONSERVATION

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tin fly  ash.  The fertilizer increased
the phosphorus significantly above the
control  plot  (Table 1).  On  the  plot
treated  with fly  ash, the phosphorus
was nearly three times  higher than
on the  scarified plot.  Presumably
some of the phosphorus was available
to plants.

Physical Characteristics
   There was no significant difference
among  treatments in the percentage
of material passing sieves with a  0.25
inch or 2 mm mesh (Figure 1). Thus,
the large quantity of fly ash applied
to the  surface was not  reflected in
the particle-size analysis.  A consistent
difference  occurred  on  all plots  be-
tween the surface spoil and the spoil
over a foot below the surface.  The
higher percentage of fine particles at
the surface probably reflects  physical
breakdown  of  large  particles  by
weathering or scarification.
   Spoil  densities at  the 1-,  2-,  and
3-foot depths were significantly lower
on the fly ash plot, but there was no
significant difference  at  the  4-foot
depth (Figure 2.).  Densities of the
control  and scarified plots were simi-
lar throughout the soil  profile.  There
were  significant differences in density
between depths  on  the  plot treated
with  fly ash. Density at the  2-foot
depth was significantly higher than at
the 1-foot depth. This  may  identify
a  zone  of compaction that  resulted
from the weight of equipment moving
over the spoil surface when the spoil
was regraded.
   The lower density near the surface
on the fly ash plot could mean greater
porosity  and higher infiltration rates.
However, the addition of 150 tons of
silt-size   fly  ash  should  have filled
voids between particles  and  reduce
infiltration The paradox might be ex-
plained  by the pozzolanic  nature of
the fly ash.  The fly ash  under these
conditions may cause soil aggregates
to form. If this were true, the failure
to recognize the fly ash in the particle
analysis, the  greater porosity, and the
increased  infiltration  could  be  ex-
plained.  On the other hand, the lower
densities  on the fly  ash  plot may
merely reflect plot differences.

Soil Moisture
   There were no  significant  differ-
ences in soil moisture in the surface
6  inches of spoil  during the measure-
ment period (Table  3).   Moisture

MAY-JUNE 1974
Table 2.  Elements commonly found in  fly
ash.
                          Approximate
                         Amount at ISO
            Concentration  Ton* wr Acre
C.llcinm
M.iKwsiiim
Poto-ssium
Phmpliorm
Cobalt
Molylxleum
Boron
Manganese
Iron
Aluminum
i on
..36
174
13
01
.01
.01
02
994
14.01
3.000
1.000
5,250
400
15
20
25
63
30,000
42,500
Table 3.  Moisture  content  in  the top 6
inches of spoil.

                         Moisture (%)
                       Range*    Mean
Control
Scarified
Fly ash, scarified
104-197    13.4
 80-13.8    11.0
 8.7-177    12.1
"Range for 11 composite samples taken be-
tween May 19 and August 6, 1970
measurements  at  1  foot  or  more
showed no significant  difference be-
tween the control and  scarified plots.
  Accumulated soil moisture  at  a
depth of 1 foot on  the  control plot
was significantly higher  than on the
fly  ash plot throughout the study pe-
riod  (Figure 3).  The high  surface
moisture on the control plot  suggests
slower infiltration rates.  Retention of
water in the top 12 inches would re-
Figure 3  Total accumulated soil moisture
by depth  for control plot scarified with fly
ash.
duco the amount of water that could
percolate deeper into the profile. This
mav also cause grcatrr Mirtacc runoff
during intense rainfall.
  At depths  of  2 foot  or more,  ac-
cumulated soil moisture on the ily ash
plot was consistently  higher than on
the control. These differences Ix-came
significant at  the 3-foot depth. The
high soil densities at the 2- and 3-foot
depth on the control  covild have  re-
stricted  percolation and limited the
amount of water reaching a depth of
3 to 4 feet   The lower densities  on
the fly ash plot at 2 and 3 feet allowed
more water to reach the 3- and 4-foot
depths.

            Conclusions

  Fly ash treatment significantly  in-
creased pH and soil phosphorus. The
chemical composition  of fly ash indi-
cated that other  essential plant nutri-
ents were added also.
  Spoil density on the fly ash plot was
lower than on  the other two plots.
This probably  was due  in part to
treatment effects and  in part  to plot
differences. This lower density sug-
gests higher percolation rates through-
out the  soil profile.
  Moisture  determinations  showed
high surface moisture on the  control
plot.  At lower depths,  fly  ash plots
consistently recorded  more accumu-
lated soil moisture. Fly  ash treatment
thus increased  infiltration rates,  in-
creased  soil  porosity, and  increased
percolation to a depth  of 4 feet  Mois-
ture at  this   depth  could  provide a
reserve for deep-rooted  plants during
times of moisture stress
  The results of this  study and past
research  by the U.S. Bureau of Mines
suggest  that  fly  ash   applications
should be considered in recta iming
extremely acid surface mine sites. Fly
ash could possibly be used to supply
nutrients and  improve the structure of
agricultural soils also
         REFERENCES CITED
1 Adam-s, L. M , J. P  Capp. jnd D. W
  Gillmorc  1972   Coal mine v>oil and
  rcftiw bank reclamation with power plant
  fly ai/j. Proc , Third Mineral Waste Utili-
  zation Symp , Chicago, III pp 105-111
2. Martc-iis, D.wid C  1971   Avatltthtlttij of
  plant ntttnent* in ftij a\h  Compost  Set.
  12(6). 15-18
3. Martens. D  C , M. C.  SchnnppinRur, Jr,
  J. W. Down, and F.  U.  Mulford. 1970.
  Fly ash as a  fertilizer  Second Ash Utih-
  •/ation Symp . Pittsburgh. I'.i,
4. Sh.»nholU, Vc-riiun O  1908. Computer
  SusU-m for tin- reduction and totalities of
  soil moisture data Hul.  16  V,i Water
  Resources Outer, Blu.lc»biirK         d

-------
 Conifer  seedling   nursery

 in  a  greenhouse

 RICHARD W. TINUS

 ABSTRACT—A new greenhouse system for grousing containerized tree seed-
 lings avoids many problems of outdoor nurseneb.  In otic year, wedhngs equal
 m size 3- to 4-ycar-old nursery stock grown outdoors on the Great Plains,
    TREES have many  important con-
     servation uses on the Great
 Plains.   Wind  reduction,  farmstead
 beautification,  feedlot  protection,
 snow distribution for moisture conser-
 vation,  wildlife habitat,  erosion con-
 trol, and noise reduction are perhaps
 the most obvious of these uses.
   Conifers are  particularly desirable
 for these purposes because they are
 long-lived, maintain their density and
 color in winter, and tend  to be freer of
 disease and  insect pests than many
 hardwoods.  Compared  with  hard-
 woods, however, conifers grow slowly,
 especially in the first years after plant-
 ing, and establishment is less certain
   Conifers also are expensive to pro-
 duce. It takes 3 to 5 years in an out-
 door  nursery to produce the  size of
 stock needed  for  planting  on  the
 Plains.  If adverse growing conditions
 reduce  a nursery's seedling stock at
 an early age, there is no way to catch
 up. Likewise, too much seedling stock
 can result  in  costly surpluses  Even
 if a  nurseryman experiences  ideal
 growing conditions and produces ex-
 actly  as much  stock as  he wants, it
 is still difficult for him to predict the
 demands for trees 3 to  5  years into
 the future.
   Some nurseries are poorly situated
 Soil may be unfavorable  or the  water
 supply  inadequate.  Climatic  uncer-
 tainties  include  torrential rain,  wind,
 extremes of heat or cold, and unsea-
 sonable frosts. Insect and disease con-
 trol is a constant battle
   Nurseries  also depend heavily on
 seasonal labor, the quality and quan-
 tity of which  is often  unreliable  A

  Richard \V,  Tunis i? a jirmnpitl jtltmt
physmlttKt-tt tit the Rocky Mountain  Forest
and Ranfic Etiicrtmcnt Statton, Forest Scr-
 oict', V, S  DciMirtnient of Axriutllnn; main-
 tai'tcd  in  coupe rat ion  tutli  North  Dakota
State Uniocrutti-lititttncuu Hrunch. Boltmeau,
North Dakota 53318
 production  system  that  could  offer
 more year-round employment and re-
 duce  the  need  for seasonal  labor
 would solve a  major personnel prob-
 lem (11, 12).

       Answer-. Move Indoors

   At the Forest  Service Shelterbelt
 Laboratory  in  Bottineau, North  Da-
 kota, our solution to these  problems
 was to move the nursery into a green-
 house  and grow trees in containers.
 The greenhouse provides a controlled
 environment in which most  environ-
 mental factors are optimized for maxi-
 mum  growth   We  can  grow  the
 equivalent of a 3- to 4-year-old  tree
 in 9 months.  The container and intact
 root ball protect the  root system,
 provide a ration of moisture and nu-
 trients to help the  tree get estab-
 lished, and greatly increase  the tree's
 resistance to mishandling and  poor
 storage.

          Container Shape

  The  container we helped develop is
 made of thermoformed sheet plastic
 folded  and welded with solvent into
 self-supporting  units  of  52  cavities,
 2X2X8 inches each (Figure 1).
 The cavity shape  is  designed to de-
 velop a root configuration that will
 not strangle itself in future years, but
will help the tree establish a balanced
 root system and escape from the orig-
 inal root ball after cmtplanting  Pines
especially need  to have their root con-
 figuration  controlled
  Experiment!, to determine the effect
of container shape on the root system
have not been completed, but a  year
of observing seedling growth  in these
containers  indicates that  vertical
grooves and lack of  sharp horizontal
corners direct the lateral roots down-
ward and  prevent spiralhig, which
they are prone  to do m a  circular
container.- A large opening at the lx>t-
 toin allows root tips to grow out into
 tlu- air beneath, where trn-y desiccate
 ami die (6, 7).  This is ni'ct'ssary to
 prevent roots from balling up at the
 bottom.  New laterals  are initiated
 higher up.
          Cultural Methods

   Containers are filled with  a  1:1
 mixture of peat and venmcuhte. This
 mixture is light, bus high water hold-
 ing capacity, and yet is well aerated.
 It  also is sterilized so  it contains no
 viable  weed seeds or pathogens. In
 fact, it must be inoculated with my-
 corrhizal fungi, symbionts  living on
 the tree's root system that aid in min-
 eral absorption and  protect it from
 pathogens (5, 8,  10).
   In  forested  areas  there may  be
 enough spores in the  air for natural
 inoculation,  but  we  cannot rely on
 this in  the Plains. Inoculation  makes
 a tremendous difference in the growth
 of  the  tree over  a year's time  (Fig-
 ure 1).
   A fungus may form mycorrhizae
 with a variety of species.  Duff from
 under  a ponderosa pine stand success-
 fully inoculated blue spruce and nine
 other conifer species.
   Seed must be  the  best possible,
 since the quality of tree produced can
 be no better than its genetic potential.
 Present information on superior seed
 sources is meager. Studies in progress
 show  as much as  a 3.1  difference in
 height growth between the fastest and
 slowest sources of ponderosa pine 4
 years  after outplantmg
  If tests indicate that  90 percent or
 more of the seed  will germinate, only
 one seed per pot is needed   If the
 germination rate is lower, then several
 seeds  per  pot are needed, and the
 pots must be hand-thinned.
  The  seed is covered with S to 3* inch
 of perhte to insure uniform germina-
 tion and  establishment. This  fairly
 deep,  droughty surface prevents moss
 from growing on  the pot surface.

         Greenhouse Design
  The  greenhouse itself is  an alumi-
num-frame quonsct covered with two
 layers  of 6-mil ultraviolet-stabilized
 polyethylene A small blower inflates
 the space between the two layers, giv-
 ing the plastie excellent windfirmness
 and insulating qualities.
  Although  fairly conventional in de-
sign, the greenhouse has two unique
features (J3),  First, it  is completely
                                                       ?95
                                                                   JOURNAL  OF SOIL AND WATER CONSERVATION

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       RECENT  SANITARY  DISTRICT HISTORY  IN
 LAND RECLAMATION AND  SLUDGE UTILIZATION
     JAMES L. HALDERSON,  BART T. LYNAM, AND RAYMOND R. RIMKUS
                The Metropolitan Sanitary District of Greater Chicago
                                     Chicago, Illinois
INTRODUCTION

Area Served
  The Metropolitan Sanitary District of Greater
Chicago,  an organization chartered under the
statutes of the State of ll.'mois, serves an 860 square
mile area with a population of appioximately 5  Vi
million persons  The non-domestic waste load, in-
cluding  industrial,  commercial, infiltration and
storm-water, adds the equivalent of an additional 5
'/i million persons. Ail of the area served is located
within Cook County Illinois and is composed of the
city of Chicago as well as approximately 120 other
cities and suburbs.
forms of Sludge
  Three major treatment plants handle the daily
flow  of  1 4 billion gallons. The major treatment
process  of  heated  anaerobic  digestion,  Imhoff
digestion followed by sand bed drying, and heat
drying of vacuum filtered waste activated sludge,
produce approximately 625 dry tons  of solids per
day.
  Heat dried sludge is disposed of thru a contractor
who transports the total output of this process  to
the southern states  and Canada for agricultural
use. The Imhoff sludge from the sand drying beds is
removed to a storage area for additional dewatering
and decomposition  Final disposal has been by oc-
casional contract and  pickup  from  the  general
public. In recent months all of the output of the
anaerobic digesters  of  the  major plant, West-
SouLhnest  has  been sent  to  Fulton County for
storage prior to land application. On a volume basis
Ihis amounts to approximately 7000 wet tons per
day.
  Of the three sludge forms being processed the air
dried sludge has the most desirable properties for
land  utilization. Essential plant  nutrient analvsis
averages  4-6-0 1 for nitrogen  (N),  phosphorus
(PzOs) and potassium (KiO) while dry matter con-
tent varies from 30 to 70 percent. However, the air
dried sludge is much more valuable, on a dry matter
basis than are  the other sludges, because of the
much greater stabilization which it has undergone.
One  appears to  be  justified  in  considering the
organic content of the air dried sludge to be essen-
tially humic matter  As such, its importance for
rebuilding topsoil would be well appreciated by the
agricultural community.
  Heat dried sludge has an  N-PzOs—KzO analysis
of approximately 6-5-0 5 with about a five percent
moisture content. However,  the valuable com-
ponents of alkalinity, and hunnt content are essen-
tially missing because of relatively little biological
stabilization  prior  to  the  drying  operation.
Anaerobically digested sludge, on the other hand,
has considerable alkalinity, 3-4000 mg/1  but the
solids content  only averages  four percent as  it
comes out of the digesters. Analysis shows the di-
gested sludge to average 6-5-0.5 for  N-PzOs and
KzO.  Lagooning  concentrates solids to  eight
percent.

Projects to Date in Land  Reclamation

Northwestern University Campus
  in April of 1968 the Sanitary District, at the re-
quest of Northwestern University officials, began a
program of applying digested sludge to University
owned land. A  five acre peninsula had been con-
structed from dredged sand by the University. On

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       MUNICIPAL SLUDGE MANAGEMENT
top of the sand an 18 inch clay layer was placed to
hold the sand  in place and to provide sufficient
water holding capabilities for vegetation. A rate of
100 dfy tons per acre of digested sludge was applied
to the soil by the ridge and furrow method of irriga-
tion. Test wells for water monitoring indicated no
detrimental effects due to infiltration. Soil struc-
ture and pH were  improved to the extent that
shrubs  and an excellent grass cover could be es-
tablished and maintained.
 Ottawa, Illinois
   At a 37 acre site near Ottawa, Illinois, the Libby-
 Owens-Ford Company disposed  of waste  silica
 sand  from  a  glass  manufacturing  operation.
 Because of the nature of the sand, the site was bare
 of vegetative cover so that moderate winds caused
 severe dust problems  Digested sludge was applied
 to the site by gated pipe irrigation methods The ini-
 tial soil pH of approximately eleven was reduced to
 near neutral and sufficient organic matter  was
 added to the soil so that a good vegetative cover of
 grass could be established and maintained.
 Hanover Park
   The village of Hanover Park, Illinois, located in
 northwestern Cook County, has a 6 mgd treatment
 plant serving the residential area In 1968 an eight
 acre site was developed for investigating the effects
 of sludge fertilization on agricultural crops. The
 site was prepared so that surface and  subsurface
 water could be collected for analysis  Six plots were
 established and  have been planted to field corn
 during  each of the subsequent years  Heavy metal
 analysis of corn  plant tissue and of the grain has
 been the major research interest. To date, results
 indicate that corn grown under such conditions
 does  not   differ   from  corn  grown under
conventional  practices except  for  an increased
protein content of the grain
Calumet farm
   At the Calumet Sewage Treatment Plant a rub-
bish disposal site of approximately 60 has  been
reclaimed for agricultural cropping purposes  Sur-
 face debris has been removed and sludge applied so
that a productive soil has been formed. At the end
of the 1973 growing season an accumulated total of
237 dry tons per acre had been accomplished over
 the five years of sludge application. Application has
been done entirely by flood irrigation practices as
 the fields are essentially level Field corn and wheat
have been the crops grown to date at this site.

PflUo Protect
   The Shawnee National Forest located near Car-
bondale, Illinois  has considerable acreage of strip
mined land within its confines. Generally, the sur-
face water leaving the mined areas has pH values in
the  3.0  range.  This prevents most  forms  of
biological growth  in and  along  the receiving
streams. In addition  to  the  pH problem,  a  rock
problem exists  such  that use of  the lands for
cultivated purposes is economically not feasible
  In 1970 The National Forest Service  in coopera-
tion with  The Sanitary District  conducted an
application rate study on four test plots. Dry sludge
solids were  applied at rates of up to 100 tons per
acre where  the applied material  was digested
sludge. Various grasses were planted on the plots
following sludge application.  Companion plots
received applications of agricultural limestone and
commercial  fertilizer.
  Only on the plot with the highest application rate
of sludge did a  substantial grass growth occur.
Testing of soil pH indicated that change in  the pH
was primarily responsible for vegetative growth.
The plots receiving limestone tended to have acid
leaching through the soil at a later  date.  This
resulted in  a reversion  of  soil  pH's and  loss of
vegetative vigor.
  As a result of the pilot plot trials The National
Forest  Service  has  prepared a 190  acre site for
sludge application. At the present time a contractor
is removing sludge  from a lagoon at the Calumet
Plant site and is transporting it to the  application
site and will apply it over a period of several years.
The Sanitary District has also cooperated with the
Forest Service on this larger scale project.  Exten-
sive water monitoring is  being done on the site to
determine the effects of the sludge application and
subsequent  vegetative establishment.
Arcola Project
  For the past several years a private firm has
applied  lagooned digested sludge to  a  900  acre
agricultural site  at Arcola,  Illinois. On occasion,
loading rates of 150 dry tons per acre per year have
been accomplished under the supervision of the Il-
linois Environmental  Protection Agency. The firm
has the responsibility for all phases of the opera-
tion, starting with sludge removal from the lagoon
A unit train is used for transportation of sludge to
the site  with application  being done by traveling
sprinklers or by moldboard plow incorporation.
Elwood Agronomy Research Center
  In conjunction with the University of Illinois, a
research center  for agronomic  studies has  been
operated at Elwood, Illinois since 1968 A total of 44
plots, each of 10 feet by 50 feet, have been  used to
study several soil types under sludge  application
Plot  borders  are  isolated  from  surrounding
groundwater by plastic  sheets  with  total water
drainage being collected  for  analysis. The facility

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                                                RECENT SANITARY DISTRICT HISTORY
was designed to provide a means of determining the
accumulative  concentration   changes  of  plant
nutrients, non-essentiai heavy metals, and organic
carbon, along with the change in biological status of
soils and water from cropped  land irrigated with
various rates of digested sludge.
  To date, one of the significant research results
has been the indication  that application of freshly
digested  sludge can  inhibit or prohibit seed ger-
mination. However, if  the sludge is applied ap-
proximately one week prior to planting  or if the
sludge has been lagooned for  some time  prior to
application,  germination will  proceed normally.
Offensive  odors  from  well  digested  sludge
applications have not been a problem.

The Fulton County  Land Reclamation
and Utilization Site
 Lfind Acquisition
  In the fall of 1970 the Sanitary District made an
 initial purchase of land in Fulton County, Illinois,
 approximately two hundred miles away from the
 sludge treatment facilities. The land was a com-
 bination of place land and strip mined land. Of the
 strip mined land,  some  areas -had been partially
 leveled so that grazing operations could be under-
 taken.
  Fulton County, Illinois is one of three counties in
 Illinois which traditionally lead the state in coal
 production. Over the past several years, an average
 of 1650  acres per  year has been  stripped in the
 county. Since approximately 40,000 acres of such
 strip mined land already exist in the county, it was
 obvious  to concerned  county   officials   that
 something must be done to counteract this erosion
 of the economic base of  the county  As a result,
 Fulton County officials and  District officials got
 together.

 Steering Committee
   At an  early  date  a steering Committee  was
 formed which had  the responsibility of  a multidis-
 ciplined   advisory   group   to   the  District
 Represented on  the committee  are  University
 research personnel, State Water Survey personnel,
 University  Extension Service, Federal and State
 Soil  Conservation  personnel,  elected  county
 officials,  representatives of  various  local  com-
 munities,  citizen  organizations  and  District
 personnel Their task was to  review the various
 proposals offered  by  the District and  to suggest
 modifications  for  maximizing benefits of the
 proposals to all parties.
 Transportation System
   A transportation system was developed for mov-
 ing digested sludge directly from the digesters and
' hauling it by barge down the Illinois River. At the
 downstream end a dock was constructed for han-
 dling the barges and associated pumps. The sludge
 is removed  from the barges with portable pumps
 which  discharge into the suction  line of booster
 pumps  From this point the material is pumped
 through an undeiground 20 inch pipeline a distance
 of 10 8 miles to holding basins.

  Holding Basins
   The  holding basins  were constructed near the
  center of the planned utilization facility. Four in-
  dividual cells comprise the total storage capacity of
  approximately 8.1 million  cubic yards. Each basin
  was lined with a two foot thick compacted clay liner
  to  prevent  seepage and one basin is ringed with a
  number of  wells for purposes of collecting ground
  water to detect seepage from the basins.
   The basins receive sludge every day of the year
  barring exceptionally heavy ice or flood conditions
  on the river,  and  mechanical breakdowns. Two
  functions are served by the basins, to accumulate
  sludge without the need of immediate application,
  and to separate liquid  from solids Separation per-
  mits application of a sludge with a solids concentra-
  tion which  can  be different from the sludge being
  input  to the basins.

  Distribution  System
     A conventional dredge is used to remove sludge
  from  the holding basins. It has a cutter head which
  can reach depths in excess of 30 feet and is moved in
  an oscillatory  manner when  removing settled
  solids  The dredge discharges into a floating pon-
  toon line which conveys the sludge to several large
  holding tanks.
     From the holding tanks the  sludge is fed to two
  pumps in series which have a collective capability of
  delivering  1200 gpm at 80 psi The output of the
  distribution pumps is conveyed through a surface
  layed, ten  inch, steel line out  to  the fields  for
  application  Each of the  presently installed eight
  distribution lines services an area of approximately
  250 acres.
     Within the field, portable, eight inch, aluminum
  irrigation piping conveys the sludge to the various
  areas. Traveling" sprinklers do the major amount of
  sludge application  and they are connected to the
  aluminum  line with a five inch diameter 660 foot
  long  hose. In  some instances  a  tandem disk
  equipped with a distribution manifold is connected
  to the five inch hose for incorporating sludge as it is

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       MUNICIPAL SLUDGE MANAGEMENT
applied. Either application method can cover a max-
imum area of approximately ten acres with a single
settling of the aluminum pipe. Sludge  is applied
during the growing months of May through Oc-
tober with the distribution pipeline being flushed
with water and then drained for winter periods.

Stle Preparation
  Prior to sludge application each field is leveled by
construction equipment to maximum slopes of ap-
proximately six percent. Berms are placed around
the field so that all surface water runoff  is directed
to adjacent retention basins for temporary storage
and analysis prior to  release to the water course.
Retention basin capacity is designed to receive the
100 year  frequency storm, which for the Fulton
County area amounts to  a bit over five inches of
water. Rocks and other debris are removed from
the field during site preparation. Those  areas that
were scarified and which  will not become part of
the productive field are seeded to permanent grass
for erosion control.

Environmental Protection  System
  The system is designed to operate in a fail safe
manner  Complete surface water collection  is ac-
complished by directing application field runoff to
retention basins. The water is then analyzed prior
to release to show that it meets State water quality
standards. In addition, several  small streams that
run through the property are monitored at points
where they enter and leave District Property. The
State Water Survey, IEPA and the County Health
Department also monitor  some of these streams as
well as several other locations within the property
  Numerous  shallow wells  have been located
throughout the property tor purposes of supplying
ground water  for monitoring  purposes Shallow
wells for ground water monitoring purposes sur-
round the holding basin that was put into operation
first. Extensive use of grassed waterways reduces
the  sediment load that  leaves the  fields during
heavy rains. The waterways also provide for ad-
ditional utilization of nutrients prior to entry of the
runoff into retention  basins.

Cropping Program
  The basic aim of the Sanitary District is to be able
to apply as much sludge to a particular location as
the environmental limitations will permit In this
regard, the agricultural cropping program is a vital
component. Information indicates that somewhat
less than half of the applied nitrogen in this system
ends up in the soil and is thus available for plants.
The remaining portion evolves to the atmosphere
as gaseous nitrogen. To the present date, nitrogen
                                              39*
has been the primary parameter by whii h loading
rates  were  determined.  Of  all  conventional
agricultural crops, field corn has been the crop that
used  the  greatest  amount  of  nitrogen  and
presented the fewest management difficulties dur-
ing its production.
  The Sanitary District procures the services of
local farming organizations  through competitive
bidding on crop production contracts. The contrac-
tor is essentially responsible for  all phases of the
crop from  "bag to bin". During the growth of the
crop the District supplies the required fertility to
the  crop by  sludge application.  Marketing of the
crop has been done by contract through local com-
mercial grain dealers.
  Production records indicate that when sludge is
applied to strip mined land, corn yield has been in-
creased by approximately a  factor of four when
compared to those strip mined fields which received
no  sludge  Because  strip mined  soils  have  no
organic matter to speak of, they have relatively lit-
tle  ability  to contain adequate  amounts of  soil
moisture  Therefore, it appears  important  that
sludge  be  applied  in the liquid  form until  soil
organic matter is built up to a sufficient level.
  Many good agricultural soils range from three to
five  percent  in organic  matter. An application of
100  dry tons per acre of  the District's air dried
sludge would change the soil organic  matter con-
tent by approximately one percent. At this rate the
entire daily solids output of the District, 625 dry
tons, could only improve six acres per day by an
organic matter change of one percent. On an an-
nual basis  this  approximately equals  the  acreage
which is strip mined  in  one  county of one state,
Fulton County, Illinois. Conservation of a valuable
commodity must receive greater attention.

Research Studies
  The  District's  Research   and  Development
Department is  studying  quite a number of factors
connected with the long range changes that might
result from sludge application in an  agricultural
setting   In addition  to the above  mentioned
parameters that are being tested, lakes on the site
are  periodically sampled for  biological specimens
ranging from microorganisms to  fish. Grain and
plant tissue analysis is conducted on the crops being
grown.
  In cooperation with the University of Illinois
School of Veterinary Medicine a  grazing study is
underway which involves approximately 100 head
of beef brood cows. The cattle consume  forages
produced  entirely from sludge  fertilized lands.
During (he summer the cows directly graze an

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                                                RECENT SANITARY DISTRICT HISTORY
irrigated crop while during the winter they graze
stubble fields or are in dry lot. The cows and their
calves  are being examined for parasitic changes,
heavy  metal  concentration changes and changes
due to disease producing organisms.
  A number of small plots have been established on
strip mined soil  near the holding basins. Studies on
these plots involve crop response to sludge fer-
tilization, soil response to sludge fertilization, and
the effects, on soil water, of sludge migration down
through the  soil profile. Because of variable en-
vironmental conditions  it is sometimes unreliable
to extrapolate  data collected from plots  in  a
different locale.

Multiple Use Facilities
  Throughout  the early development and im-
plementation of the reclamation site, considerable
emphasis has been placed on multiple utilization.
Various integral  parts  of  the  site have  been
developed for public uses such as boating, camping,
fishing and hiking while other parts have been
devoted to  improving  the habitat for wildlife.
Several hundred acres of land, within which are
sludge recycle fields, has been leased to the county
government.  They in  turn  are  responsible for
managing the area for public utilization.  The State
of  Illinois  Department  of Conservation  is
cooperating in  the wildlife  habitat improvement
and stocking of the strip mined lakes for fishing. Ef-
forts continue on the project for reestabhshment of
a native population of giant Canada geese.

Future Developments

Application Rates
  At present, the Illinois Environmental Protection
Agency  has  approved  application rates  on the
Fulton County  site of 75 dry tons per acre per year
for strip mined land and 25 dry tons per acre per
year for place land. These rates pertain to liquid ap-
plication wherein the solids content might reach a
maximum of eight percent. Over a period of five
years the application rates are reduced to a steady-
state rate of  20 dry tons.
   Infiltration rates for the clay soils of the area
 restrict the amount of water that can  be applied
 over and above a normal annual  rainfall of ap-
 proximately  35 inches. It appears that an average
 year would result in approximately four acre inches
 of sludge being applied to the soils. This  factor
 would limit maximum dry matter application to ap-
 proximately  36 dry tons per acre per year if eight
 percent solids  are in  the irrigant. Therefore, it
 appears that in the near future, the District will be
strongly considering application of a sludge which
can be  handled  as a dry material.  Several major
benefits of  such a move would be that annual
application limits  could  be achieved in a single
application, organic matter could be built up in the
soils at a mucti more desirable rate, and that sludge
could be incorporated shortly after application to
result in much less nutrient and participate loss
from the field due to erosion.
  The concentration of heavy metals in the soil is a
factor that can be controlled to any desired degree.
One can monitor the soil for metal concentration
and the crop for toxicity indications. If, and when,
crop toxicity is  encountered one  can relieve the
metal concentration in the soil by tilling more deep-
ly. The  normal plow layer is considered to be eight
inches.  It is presently possible to till to a depth of ap-
proximately  36  inches  with existing equipment.
More than a four-fold reduction in concentration
would result from such action. Fears that there are
no  practical responses to too high of a metal con-
centration in the soil appear to be unfounded.

Reclamation and Strip Mining
  Some of the land that the District is now leveling
and reclaiming has been laying in an unproductive
condition for a great number of years. The  land has
become overgrown with low quality trees and vast
amounts of  soil has been conveyed to nearby
streams over the years. In considering the total cost
to society for such practices, it does not appear
reasonable  that  such  a  time  span need exist
between strip mining and reclamation.
  Recent  State  of  Illinois laws  have  required
current strip mined spoils to be leveled to slopes of
no greater than  15 percent. However, this practice
can  only be viewed as a partial solution to  the
problem. Long slopes of only several percent on
bare soil cause serious erosion problems. This con-
dition is coupled with the fact that soils devoid of
organic matter take an exceedingly long time to es-
tablish  adequate vegetative cover. Before vegeta-
tion protects the soil from erosion, ditches  are
formed which concentrate water flow and cause
still more serious  erosion. The process  is a never
ending  cycle as soil must be moved to correct the
ditch problem and the process is repeated.
  The missing key to the reclamation of these soils
is organic matter. The incorporation of sludge into
freshly  leveled mine spoil immediately after strip-
ping appears to present the most desirable  benefits
for  sludge   utilization  and   land  reclamation.
Nowhere in agriculture  are  such quantities  of
organic matter available at a cost which would be
comparable  to that of sludge.

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          MR. LEHMAN:  Thank you Mr. Brenneman.




Any members of the audience then if you wish to




pass questions to the speaker, merely raise your




hand, and a 3 by 5 card will be handed to you,




and then you will -- we will rapidly collect




the questions.




               Are there any questions on the panel?




          MR. KOVALICK:  Mr. Br*nneman, you made




an interesting statement about those things you




t-hink should not be called hazardous.  Have you had




a chance to give some thought as to the criteria




that ought to be used, distinguishing between arsenic




and cyanide, and the waste you are talking about?



          MR. BRENNEMAN:  I think it should be




established that it definitely is a hazard to our




health, and that's what we're really aiming at.




               And I would not be able to just




off the cuff give a criteria for that.  But certainly




leaching from wood chips per se, there may be other




reasons — I'm just asserting  myself that these




should not^just be dumped,  but it's hard to conceive,

-------
that this is a hazard to anyone's  health,  or  to




wildlife.




          MR. KOVALICK:  Would  it  be  your  view




that the hazard then is  a funtction of how that




waste is disposed of.  That  is, those  wastes that




are disposed of carefully are  net hazardous ,  and




those that are  not, are hazardous?




          MR. BRENNEMAN:  I  think  there  should  be




surveillance to see that there's a hazardous amount




of whatever there is.  This  is  being  done  like  at




our plants and at the MSB, they're constantly




monitoring it.




               As far as I know, or understand,




the MSD has been doing this  --  but I  can tell you



only what I'm reading.




          MR. KOVALICK:  Thank  you very much.




          MR. LEHMAN:  I think  we  have some  other



questions Mr. Brenneman.




               Would you please stay  at the  podium.




Mr. Lazar,




          MR. LAZAR:  Yes, I have  two questions,



Mr. Brenneman.




               The  first one you mentioned in the




case of fly ash which contains  trace  amounts  of

-------
heavy metals, that if this were classified  as




hazardous they would not be used  for reclamation.




               Could you explain  why -- to  me




it seems we don't have two mutually exclusive  things




here.  The way I understand it, it could  be



classified as hazardous and still^if carefully handles




be used for reclamation.




          MR. BRENNEMAN:  It relates to the quantities




of heavy metals.  If they are in  such trace amounts




they would be considered negligible.




               And therefore I hope they could be




used for fill on perhaps inter states and something




like that.




               We would like to use something



rather than waste something, and  that's my main




thrust.  Not waste it, if it can  be used and it's




not hazardous.




          MR. LAZAR:  May I ask another question,




please.




               You say first sewerage sludge in




Chicago, and you stated in trace  amounts in heavy




metals in the harvested grain are not considered




harmful, will you cite an authority for this




statement.

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          MR. BRENNEMAN:  The authority is Dr. Robert



Dowdy, Agricultural Research Service, United States



Department of Agriculture, St. Paul, Minnesota.



               He made a study, they have been using



sludge up there from different suburbs of the St. Paul



Minneapolis area, and they know what the heavy metals



are, they throw them where they can't escape, and



they collect everything and the grain, one statement



was that a man who ate 2 heads of lettuce a day for



20 years would not be in any danger.  But I'm not



certain which metals they are.



               He has researched it and he spoke



to a soil conservation society meeting, in pekin



last year.



          MR. LEHMAN:  Mr. Brenneman, could you



supply that name to us later for the record,



please.



          MR. BRENNEMAN:  I'll try.  I'll get it



or send it to you.




          MR. LEHMAN:  Are there any other questions?



From the panel or from the audience?



               Evidently not, thank you very much



Mr. Brenneman.



               Next I would like to call upon Mr.

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Donald Eby from Monsanto Company.




          MR. DONALD EBY:  Mr. Chairman, and members



of the panel, ladies and gentlemen, the Monsanto



Company appreciates the opportunity to respond to



the published questionnaire on solid waste management.



               My name is Donald Eby.  I am employed



by Monsanto as Process Environment Director in its



Department of medicine and Environmental Health.



               Monsanto produces a broad range of



chemicals, plastics and synthetic fibers in 62



domestic plants employing 44,000 people.



               We have suggested answers to several



of the 16 questions posed, in areas where our



experience in manufacturing and the associated wastes



management functions is appropriate.



               May I ask can you hear me at the rear



of the room?



               Thank you.:



               We would like to offer some preliminary




comments,  some parts of which are not specifically



addressed  by the questionnaire.



               These comments pertain to the chemical




processing industry.  It is recognized that other




types of hazardous wastes,  such as radioactive and

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pathogenic may require a different approach.  Also,




these suggestions may not be totally appropriate




for differing basic processes such as metals, and




extractive industrial operations.




               First, we accept the responsibility




for environmentally acceptable disposal of our




wastes and expect to continue to bear the associated




costs.




               At present, we are disposing of hazardous




wastes both at the site of generation and by using




services of treaters and processors.  We are employing




the safeguards and hazard controls that have been




found necessary in production and in use of these




chemicals.




               It may be desirable to establish




uniform guidelines for regulation, possibly including



an operational permit system for separate facilities




handling heterogenous wastes from multiple generating




sources.  Since local conditions of soil, water and




terrain and stage of land use will vary widely, it




is recommended that specific regulations be estab-




lished and implemented by states or municipalities




under general national guidelines.




               It is suggested, however, that waste

-------
processing and disposal by the generator, on his




property, of wastes for which specific knowledge




and control procedures exist would require a lesser




degree of regulation.  In this case, no need for a




permit system or handling or processing regulations




is needed since the total facility operates under




established environmental and Occupational Safety




and Health Administration controls.




               Second general point is that the




desirability of recovery, recycling and secondary




uses of waste materials in preference to discard is



acknowledged.




               It is however, suggested that regulation




of waste disposal be concentrated on environmental protec-




tion.




               The imposition of fees, penalties or




restrictions to force re-use will add a cost burden



to society without a concomitant environmental



benefit.




               Thirdly, it is evident that the desig-




nation of suitable land areas for hazardous waste




disposal is becoming increasingly difficult.




               The ultimate discharge to air,  surface




and sub-surface water after the  wastes are converted

-------
to environmentally acceptable form must be predicated



on natural conditions rather than political boundaries.


               Furthermore, the costs of transporting



hazardous wastes, as well as the potential environ-
                         /

mental risks in transit, are related to the distances


involved, and are ultimately borne by the consuming



public.


               We therefore, support the concept which


has appeared in several tentative legislative drafts


which provides for designation of appropriate public


land for hazardous waste disposal sites; and also


the prohibition of local statutes which would prevent


acceptance of wastes generated in a different


jurisdiction.


               We oppose the mandatory use of such


designated sites to the exclusion of alternative


sites.


               Now getting to the questionnaire,


the first question relates to definition of hazardous


wastes and sampling and analytical features.


               Hazardous wastes could be defined



as materials destined for ultimate disposal which



could create, or have the potential to create,



significant adverse effects on human health, or on



other beneficial living species.

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               The criteria for identifying hazardous




wastes could then be based on established carcinogenic




and toxicological properties of ingredients in the



wastes.



               For example, a given waste quantity



could be classed hazardous for disposal regulation



if it contained significant quantities of any



substance in one or more of these categories.



               Established human carcinogens, highly



toxic to humans and mammalian species, highly toxic



to beneficial acquatic organisms.



               Since the individual substances making



up the total lot of waste are generally known, although



the exact proportion of each substance can vary widely,



the classification by established toxicity of the known



ingredients, based on existing data for pure substances



could be readily used for most industrial wastes,



without special sampling or analytical procedures.



               If this hazardous classification of




wastes by significant ingredients is feasible for



disposal management,  it should be noted that the



toxic, or poisonous,  classification of the composite



waste entity should continue to be the criteria for




container labeling and transportation requirements.

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               Additional criteria of importance




to the ultimate acceptable processing or disposal



of wastes would be  their biodegradability and



the bio-accumulative toxic effects in acquatic



organisms.



               It is suggested that these latter



be considered in selecting acceptable methods for



treatment and/or disposal, and not as a criterion



for classifying the waste per se.



               There are also hazardous features of



materials which must be properly considered in the



handling, containerization and transporting of



such wastes, whether or not destined for ultimate



disposal.



               However, the safeguards related to



the pure materials such as in the Hazardous Materials



•transportation Act and OSHA  regulations could be



applied to the hazards of explosives, flammables



and combustibles, oxidizing and corrosive materials



without duplicating these in hazardous waste criteria.



               The second question relates to suggested




responsibilities for the generator, transporter,



processor.



               We feel the generator should be

-------
responsible  for establishing an environmentally




acceptable program for the disposal of his hazardous




wastes.




               Either A, by self-disposal on his




property, via processes  and methods which meet the




established  guidelines for air emissions, effluents




to waterways and all other requirements for environ-




mentally safe, nuisance-?ree operations.  Total




responsibility and liability rests with the generator




in this case.




               Alternative B, by initiating an




environmentally acceptable disposal method using




services of  licensed or permitted treaters or




disposers.  Each transporter, treater  and disposer




should be responsible for his individual activities




while the waste is in his possession.




               With alternative B, the responsibilities



should be as follows:




               The generator should characterize




the waste sufficiently for proper handling and disposal.




Insure that containerization and transport of the




waste is properly designated.   And confirm the




competence and reliability of transporters,  treaters




and processors to whom the waste may be transferred.

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               The transporter should, as with any



hazardous material in normal commerce, require



adequate information on characteristics of the



waste, comply with established Department of



Transportation and state and local regulations,



ensure proper equipment is employed, and be



responsible for safe handling and spill prevention



and mitigating action.



               The treater, or processor should be



responsible for ultimate disposal of wastes to the



environment in acceptable form, for accounting to



regulatory authority for proper disposal of these



wastes, and for accounting for any stockpiled waste



inventories and maintaining capability for their



future processing or acceptable disposal.



               Each party to the waste management



cycle should have financial liability for wastes



for which jurisdiction is accepted.  Contested



liability arising from disputes related to respon-




sibilities listed above will probably be issues



for court determination.



               The generator should bear the costs of




environmentally safe disposal either directly or




through fees paid to transporters, treaters and/or

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disposers.  However, the generator should not bear




the costs of improper handling or treatment due



to non-performance or negligence of transporters



or processors.



               Question three relates to specifics



for treatment or prohibition and since we have no



substantive comments, I would like to skip that



and in the interest of time proceed to question six,



which asks the minimal safety and security pre-



cautions for hazardous waste handling and treatment.



               The necessary safety and security



operational controls, as well as personnel exposure



protection, and training requirements for hazardous



wastes are analagous to those currently employed and



regulated for products of comparable hazard in



normal commerce.



               Thus, no super imposition of another



tier of regulations is needed.



               The guidelines and restraints of



the following nature should be  sufficient.   Spill



controls and reporting under Public Law 92-500



Air Quality Control Region notification for excess




emissions.  OSHA workplace standards.  Local




government and insurer's   requirements for fire and

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explosion.  Local zoning and land use requirements.




Department of Transportation container and shipping




regulations.




               Question seven asks for provisions




for site monitoring record keeping.




               For quantitative material accountability




records of shipments by generator, receipt and delivery




by transporter, and receipt, storage and processing




by disposer should be maintained in a consistent




manner.  Each party to the waste management cycle




will need such records to confirm the discharge of




his respective responsibilities and to substantiate




the payment or receipt of payment for the functions




performed.




               Periodic summaries or totalizing




reports could be provided to regulatory authorities




if required.



               It is questionable if a massive




compilation of such individual data would be effective




in monitoring the site, per se.  Site control, under




permitted stipulations, should consist of monitoring




discharges to the environment; liquid effluent by




NPDES permit, leachate by test data, air monitoring,




appropriate to the AQCR, etc.

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               In addition, inventory or stockpile



records should be required to control the potential



concentration of hazard and inherent future environ-




mental loading.



               It is not considered feasible to



expect one reporting, recordkeeping system to



satisfy both the objective of closed loop control



for each waste increment and also the overall monitoring



of the disposal site.



               In the case of on-site treatment and



disposal by the generator, it is suggested that



records of amounts treated and disposed of, and



amounts stockpiled for ultimate disposal would



suffice, presuming the operating location is in



overall compliance with air and water regulations.



               Question nine addresses itself to



the requirements for assuring long term security



for disposal sites.



               It is presumed that the assimilative



capacity and capability of the site based on its



features will be determined by initial survey and/or



by monitoring during continuing operation.   The



permitted operations will be circumscribed by these




conditions.






                        *   1*15'

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               The long term integrity safeguards



then have these aspects.  First stockpile controls



to limit quantity of wastes on-site to avoid



exceeding assimilative capacity after processing



or disposal.



               Second, financial surety to provide



adequate operating funds to process all on-site



wastes.  Perhaps by performance bond.



               And third, a permit requirement for



acceptable shutdown or abandonment plans and physical



safeguards.  This could be updated periodically.



               Question ten deals with feasible



methodologies to set limits on the amounts of



hazardous wastes permitted to be emplaced in the



land.



               Methodology exists for determining



the solubility and bio-degradability of waste



substances.  Also soil percolation and barrier



characteristics can be determined.  The limits of



the amount of wastes to be stored can only be



estimated by evaluation of these factors for the



specific conditions of the particular site.



               The safety factor allowed should be




further influenced by the location and existing






                            "  U.S

-------
conditions of the ultimate receiving ground or




surface waters.




               Proof of the assimilative capacity




of land emplaced wastes can be developed by monitoring




infiltration and leachate.  provisions should be




included for adjusting quantity limitations as




monitoring data is obtained.  The capacity of properly




operated sites may be found to be quite elastic.




               It is also suggested that sufficient




flexibility be included to adjust the effluent,




leachate and emission limits from a hazardous




waste disposal site to a realistic relationship




to the measured effluents and emissions from the




much larger number of properly operated sanitary




landfill disposal sites for domestic garbage and




refuse.




               Also, it is suggested that disposal




of industrial hazardous wastes be allowed in




existing processing facilities or landfills where




the ultimate environmental effect will not be




detrimental.




               In the interest of time, our answer




to the combined questions 11 and 12 regarding




transportation safety and labeling   was somewhat

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answered in question 6 in that the Department of




Transportation has and is proposing additional




rules which we feel will cover both intra and inter-




state transportation, including all  labeling  and




containerization.




               Therefore we see no need for special




regulations as a part of environmental control.




               Question 14 asks what mechanism and




experiences are effective to obtain citizen cooperation




and acceptance.




               Public acceptance of the need for land




areas to be designated for waste disposal and public




understanding of the apparent inconveniences necessary




for creating a generally safe environment must be




obtained through the programs of governmental statutory




and zoning actions.




               As a technologically oriented company




we will certainly do what we can to support the




objectives of government information programs and




to explain the problems of waste management in our




communications work on the subject.




               The final question asked of relations




between the Federal  and private sector, as covered




in our preliminary comments, private sector opportunities
                          1*18

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 should be  available  within a consistent  and




 practicable  regulatory  framework.   Waste generators,




 whether private  or public,  should  be  responsible




 for environmentally  acceptable  disposal.




               The selection of a  secondary disposer,




 whether public or private,  or the  determination of the




 generator  to directly assume disposal/operational




 responsibilities  should be  a free  choice.




               Thank you very much, and  I'd be




 glad to answer any questions.




           MR. LEHMAN:  Fine, Mr. Eby  has indicated




 he will answer questions,  and again I wish  to




 remind any newcomers to the  audience  if  you wish




 to ask a question merely raise  your hand and a  card




will be provided for you.




               Yes,  Mr. Lindsey.




          MR. LINDSEY:  Mr.  Eby in  the earlier  part




 of your statement you indicated that  a permit system



 is needed  for  commerical treaters  and disposers but




that such permit controls are not needed for treatment




or disposal by the generator.




               Now,  could you please  elaborate  on




why the distinction  should be made?




          MR. EBY:  We believe  the  distinction  is

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based principally on the fact that the generator




is dealing with his specific problems with specific




knowledge of their characteristics.




               All of the features of his manufacturing,




sale and use of these things is regulated based on the




hazard involved, and therefore it is top priority




and control.  Whereas the treater and disposer is




accepting heterogenous waste from many generators




and therefore needs uniform guidelines and controls




to make sure there is consistency  to handle the various




variables in what he is doing.




          MR. LEHMAN:  Mr. Newton.




          MR. NEWTON:  Mr. Eby you made the statement




that on site disposal currectly operates under established



environmental controls.  I would appreciate if you could




specify the state and/or Federal  environmental controls




to which you are referring.




               And if you also could specify those



which specifically cover ground water.




          MR. EBY:  Perhaps I should have said




existing and near future controls.  It is true that




the present control for water falls short of control.




And falls with the operator.




               The on-site waste treatment facilities -<-

-------
I'm not speaking for the whole  industry.  Testing




the leachate and the run-off -- that's  the  thing




as you are well aware would be  needed control  for




on-site generation.




               This may come before  or  after regula-




tion of run-off and the general water act.




          MR. NEWTON:  Again, in terms  of protecting




the ground water, versus the surface water, whether




from a point or non-point source, does  your company




operate under state or Federal   departments?




          MR. EBY:  No, sir, we do not  at the  present




time.




          MR. KOVALICK:  I have several questions




Mr. Eby.




               First of all, on a related question




in findings of hazardous wastes, you suggested  in




one of your questions or one of your statements on



page 2, that the classification, by establishing



toxicity  °f the substances in the waste, could be




readily used in most industrial wastes.  Have you.



had a chance,  or do you have any thoughts on whether




that's regardless of concentration?




          MR.  EBY:  Yes.  Our premise here  is re-




gardless of concentration.  With the point that the

-------
concentration and of course the ultimate characteristic




of the waste and the leachate into the environment




it's -- and we know and the chemical  industry knows




what is waste and what their toxicity is.  And that




data is readily available.




               If the waste has -- I  think I said a




significant amount, and of course that's subject to




further technical study, if the waste  contains this




product whether it's 10 per cent or 85 per cent,




we would be willing to classify the entire waste as




hazardous, for determination of its treatment site




and treatment manner.




               Obviously a waste with only 10 per cent




of that ingredient would be far less  hazardous than




if it were exposed to the environment at that time,




and that of 95 per cent.



               Our premise in  classification is to




quickly identify these things, so they can be properly



designated for treatment or disposal ,  and not to



identify how they 'would be to the environment right now




if they were wastes.




          MR. KOVALICK:  So the presence of any




amount of a toxic substance would cause that to be




labeled hazardous just for the purpose of making

-------
sure that it's properly managed later, at the disposal




site.  Is that correct?




          MR. EBY:  This is concentration with a




significant amount.




          MR. KOVALICK:  All right, significant.




Can I ask one more Mr. Chairman?




               In -- related to the subject of labeling




of hazardous wastes versus hazardous substances,




referring then to the Hazardous Materials Transportation




^ct and you pointed out that they do have a separate




label, such as caustic acid and so forth, but you




also in your statement which you did read says that




the adaptation of shipping names, labeling, packaging




and transport under DOT regulations addressed specifically




to waste would be advisable.




               So, if I understand your statement




correctly, you feel that the Department of Transpor-




tation regulations are sufficient for the transport




of waste, but may not be sufficient -- that is DOT




labeling and other requirements may not be sufficient



at the waste treatment/disposal site, is that correct?




          MR.  EBY:  That is a correct statement,




but that's not what I intended by that particular




c omme nt.

-------
               DOT is now beginning to promulgate




some special labeling for wastes, different from




those others I mentioned, and we should modify these




to suit their classification of waste products.




          MR. KOVALICK:  But there is a need to




recognize wastes as different subjects and different




substances.




          MR. LEHMAN:  We have a few questions from




the floor Mr. Eby.




               Mr. Klepitsch.




          MR. KLEPITSCH:  The question asks how




could future owners be protected from on-site




disposal of hazardous wastes in wells or landfills




unless a record is filed as part of Title II pro-




perty.



          MR. EBY:  That's a question I do not think




I am expert enough to answer.  But I think it's a




very logical question, and if as we propose records




were kept in total quantities of hazardous waste




disposal of properties, I think this has to be done




by the generator on his own property or an independent




processor.




               If those records are kept and then




I think it becomes a matter of local statute to

-------
require those to be on the property, that's what




should be done.




          MR. LINDSEY:  I have a question from



the floor.



               The question says does Monsanto



use a deep well injection and if so, for what



substances?  And I would like to amend that if



I could to also ask the question if you do use it



what criteria and safeguards do you use to decide



how and what should be well disposed.  That is



especially by deep well.



          MR. EBY:  Yes, we do use deep well injection



at several locations.  All of these situations are



fully permitted to the extent of geological surveys in



advance, and I could not cite specific quantities or



products at this time.



               The second part of the question was



how do we determine?



          MR. LINDSEY:  Yes.  What should be disposed



of by the well, and so forth.



          MR. EBY:  Well, this is permitted very



rigidly.  We only dispose of those things for




which we have official permits and in the quantities



that are stipulated by the guidelines, and these

-------
are mostly state permitted operations.




          MR. LINDSEY:  Thank you sir.



          MR. NEWTON:  Mr. Eby, your statement



notes that your support for the precept use in



several tentative legislative drafts, we'd



appreciate the reference to the legislative drafts.



          MR. EBY:  I'll send notice to you.



          MR. LEHMAN:  One last question.  Mr. Kovalick.



          MR. KOVALICK:  I wanted to make reference



to questions 2 and 7 where you refer to the waste



management cycle.  If I understand your suggestions



correctly, the generator, the transporter and the



disposer will maintain records and be responsible



certainly on his facility or on his vehicles for



integrity.



               But I don't understand how the loop



is closed by -- if I could use that expression, from



preventing wastes from reaching other than sites



for which they are destined.



               And if it's true, if both the trans-



porter and the well run disposal site what is to



prevent waste from leaving that loop and reaching




what we would call a non disposal site.




          MR. EBY:  That's a difficult problem.

-------
               I think the prevention would be proper




licensing, permit requirements for both the transporter




and the user, and that would monitor activity.




               My point was not that these records




should not be used as a check on activities, but




my point was that the sheer mass of the statistical




problem of trying to use these individual transit




tickets along with disposal records at the site




to get an overall material balance is going to be




a gargantuan task.    And 1 think if you look at two




separate systems one is controling the loop shipment




transit delivery, and the other controls the actual




activities at the disposal site.



               And I'm not trying to combine the




two into a computer system, but that could be more




effective.

-------
                           ionsanto
                           Monsanto Company
                           600 N Lindbergh Boulevard
                           St Louis. Missouri 63. 66
                           Phone (314) 694-1000
                            December 17, 1975
Mr. Murray Newton
United States Environmental Protection Agency
Hazardous Waste Management Division
Office of Solid Waste Management Programs AW-565
Washington, D. C. 20460

Dear Mr. Newton:

During the Public Hearing on Solid Waste Management at Rosemont, Illinois
on December 4, you requested references supporting Monsanto Company's
statement (page 2) that -

       We therefore support the concept which has appeared in several
       tentative legislative drafts which provides for designation of
       appropriate ?"'•>-.ic land for hazardous vast? disposal sites;
       and also the prohibition of local statutes which would prevent
       acceptance of wastes generated in a different jurisdiction.

Among the several allusions to these concepts which have appeared in various
legislative drafts and staff working papers, the following appear to be the
most explicit.

       Pertaining to land designation. Senate Committee in Public Works,
       Staff Working Paper dated October 15, 1974 which designates
       the Administrator — "to conduct studies together with recommendations
       for administrative or legislative action (to remove) the legal
       constraints and institutional barriers to the acquisition of land
       needed for solid waste management etc."

       Pertaining to acceptance of wastes from a different lurisdiction.
       S-1086, Senator Baker. March 6, 1973.
       "Section 9 - The Administrator shall encourage cooperative
       ... interstate, interlocal and regional planning for ... and
       conduct of ... hazardous waste disposal programs."

       and "Section 14(b) No State or municipality shall impose, on wastes
       originating in other States or municipalities, requirements re-
       specting the transport of such wastes into or disposal within its
       jurisdiction which are more stringent than those requirements
       applicable to wastes originating within such receiving States and
       municipalities."

-------
Mr. Murray Newton                                     December 17, 1975



Monsanto appreciates the opportunity to present its views to your panel.


                             Very truly yours,
                             Donald L. Eby
                             Process Environment Director
                             Department of Medicine and
                               Environmental Health
mo


cc:*>lr.
cc: Mr. John P. Lehman, Director
    United States Environmental Protection Agency
    Hazardous Waste Management Division
    Office of Solid Waste Management Programs AW-565
    Washington, D. C.  20460
                                             *t23

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          MR. LEHMAN:  Thank you very much Mr. Eby.



               Again, I have a point from the audience



that I'll just raise.  It's really not a question.



I'll only merely state what it says here.  It says



if industry is relieved of responsibility waste



would be given to anyone who has the lowest charge.



               So, that's verbatim, it is not posed,




in the form of a question.  So I'll just put that into

-------
the record.




               Next I would like to call upon Mr.




John Baker, Indiana Board of Health, or I understand




there may be an alternate.  Mr. David Fenton, are




either of those gentlemen in the audience?




               They must not be here.  We will have




to come back to them.




               I'd  like to next then call upon




Mr. Thomas J. Murphy of the Lake Michigan Federation,




is Mr. Murphy here?




               While he's coming to the microphone,




let me ask the next couple of speakers so we can get




a little preparation here.  Mr. Bruns from Hyon




Waste Management  and Mr. Thomas Clark, Illinois




EPA.




               I  now have Mr. Thomas Murphy of the




Lake Michigan Federation.




          MR. THOMAS J. MU&PHY:  Yes, I am Thomas




J. Murphy and I represent the Lake Michigan Federa-




tion and I make the following statement.




               There have been numerous incidents




in recent years of adverse health and environmental




effects due to the improper disposal of hazardous




and toxic wastes.   These include the following.

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               The mercury discharges from the




chlor-alkali plants into the rivers and lakes of




the nation.




               The continuing discharge of thousands




of tons of asbestos in mine tailings into Lake




Superior.




               Several incidents where hazardous




materials  disposed of in deep wells have contaminated




aquifers or have been released at the surface upon




failure of the well equipment.




               The problems with inadequate disposal




procedures were highlighted two weeks ago in Chicago




at the National Conference on  Polychlorinated biphenyls.




               These materials are toxic in themselves




and contain small amounts of very toxic dibenzo-




furans and by-products.  Many of the polychlorinated biphenyl




are not degraded by sewage microorganisms, high con-




centrations of F.C.B.'s are present in the sewage




received at treatment plants; though P.C.B.'s are




so stable  that they are not oxidized in most in-




cinerators, thousands of pounds end up each year




in refuse  burned at municipal incinerators .




               Thus this only serves to evaporate




these materials into the atmosphere where they are

-------
deposited throughout the world in rain and dry fallout.




               Though they are not decomposed by ground




water or soil microorganisms, millions of pounds are




disposed of in landfills each year resulting in a




vast accumulation which can only come back to haunt




us in the future.




               These incidents and many more underscore




the need for much more comprehensive and stringent




regulations to deal with the disposal of hazardous




materials.




               These regulations should, we feel,




include the following provisions:




               One that the responsibility for the




safe disposal and the ultimate fate of hazardous




materials reside with the producer of the materials,




even though the actual disposal is contracted to




others.




               That chronic testing be part of the




testing protocol and that all significant metabolites




or degradation products of the hazardous material




be tested for their acute and chronic toxicity.




               That wastes be chemically detoxified




before land or water disposal or incinerated in  such




a manner that oxidation to non-toxic  materials results.

-------
               That land, landfill or discharge to a




waste water treatment plant not be considered ade-




quate treatment except where it is shown that




such treatment will detoxify the material before




possible harm can result.




               That deep well disposal of hazardous




materials not be considered an acceptable disposal




method,




               That the charges and penalties for




improper disposal of hazardous materials, whether




or not harm has resulted, be made high enough that




the proper disposal of all potentially hazardous




materials be economically the cheapest method.




               Thank you.




          MR. LEHMAN:  Will you answer questions,



sir?  Are there any questions from the floor or the




panel?




               Mr. Kovalick has a question.




          MR. KOVALICK:  Mr. Murphy, we are of




course interested in many kinds of wastes, not




just those containing P.C.B.'s.




               Do you have any thoughts on state-




ments that you can point towards regulating of




wastes disposal via the substance contained in it?

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               Is that the position you have?




I noticed you focused on P.C.B.'s but have you




had a chance to think about that?




          MR. MURPHY:  I was using P.C.B.'s  as



a recent example.




               Yes, I think every waste has  to be




treated in its own right.  Oxidizing materials are




different from flammable materials, and there are




many different materials that are different  from




each other, that have specific toxic values.




          MR. KOVALICK:  You stated  Federal  guide-




lines ought to address wastes by their characteristics




or address the operation of the disposal and treatment




facilities or both?  Do you have a feeling on that?




               Do you have a distinction on  that?




          MR. MURPHY:  Okay I think the waste has




to be treated on its own properties.




          MR. KOVALICK:  I guess I was just  trying



to make a distinction between addressing wastes as




a class, instead of addressing sites.




          MR. MURPHY:  I think wastes have to be




treated individually.  As some things are different




from polychlorinated bioJienyl s,  .  and they have to be




-- there has to be a suitable distinction and disposal

-------
method for each of those on their chemical and




physical properties.




          MR. LINDSEY:  Mr. Murphy, I am interested




in your P.C.B. statement for the use of that example.




               Now, you indicated that millions of




pounds of it a year are liberated from municipal




incinerators --




          MR. MURPHY:  No, I'm sorry -- that they




were included in the waste which are discharged at




municipal incinerators.




               That waste containing   po.rychlorinai-Pd




biphenyls that end up in landfills.




          MR. LINDSEY:  Oh, all right, but along




the same lines it's my understanding that in recent




years the sole United States manufacturer has limited




that to electronic and electrical equipment and



electronic equipment, am I wrong in that?




          MR. MURPHY:  Well, that's right I believe




there's about 40 million pounds presently being




produced and these are being used in what is called




closed systems, and these are principally large




electrical transformers which contain a large




amount of polychlorinated binhenyls   which are
         /



handled differently.

-------
               The major amount of  polychlorinated




biphenyls goes into paper insullated capacitors.




And these capacitors are used in air conditioners,




for fluorscent lights -- and all electrical  applica-




tions where these capacitors are used.




               When these materials -- when  the




ballast in the fluorscent lights go bad  it is




through out.  There's no indication what  is  con-




tained in the capacitor.  And most of these  materials




go to the incinerator and go to landfills and go




where refuse normally goes.




               With the P.C.B.'s contained within




them.




          MR. LEHMAN:  We have a question Mr. Klepitsch




will read it.




          MR. KLEPITSCH:  Yes.  Question  from the




floor, it asks what would you propose to be  done




with those wastes which are so complex that  analysis




is impossible.




          MR. MURPHY:  I would not generate  such




wastes in the beginning.  I think that this  is part




of the manufacturing process.  If this is a  product




of the process it must be considered, so  I think




that planning for the disposal of waste has to

-------
begin where those wastes are generated.



          MR. LEHMAN:  All right.  Are there any



other questions?



               Evidently not, thank you very much



Mr. Murphy.



               Next I'd like to call upon Mr. R. B.



Bruns of the Hyon Waste Management Services-  is



Mr. Bruns here?



               I see that he is.



          MR. R. B. BRUNS:  My name is Bruns, I am



President of an engineering firm in Jersey, also



of a hazardous waste treatment facility known as



Hyon Waste Management Services here in Chicago.



               My remarks are addressed particularly



to discussing topics 3, 4 and 5 which refer or ask



something about the state of the art.



               The technology, the ability to treat



these materials.  And to some extent the economics



of such treatment.



               The size and scope of the hazardous



waste problem today is reasonably well identified



I think in the Federal EPA publications, which



are in the rear of the room, and the reported 10




million tons a year is indeed a formidable number.






                           ''  i*33

-------
               Except for a few small, private




operations mainly incinerator plants, and some recovery




operations, prior to 1970 most of the interest




in this business and most of the interest in the




disposal of concentrated wastes was shown by the




generators themselves.




               These people as the gentleman from




Monsanto indicated before, certainly are aware




of the nature of the wastes they produce.




               Then, however, as now most of these




materials were rather promiscuously discharged into




the land or into the sea.




               Since 1970 new efforts to treat and




manage have appeared, sufficient experience has




been accumulated to permit some comment on progress




to date and on the current state of the art.



               This work has been done largely by




a few private companies with private investment.




The risks have been high, the support by the major




generators is generally good, and the support by




local state level agencies and local agencies I




think has left something to be desired.




               In the course of five years then since




1970 substantial operating experience with several

-------
comprehensive treatment works, each currently




receiving and treating a'lout 100,000




tons per year, from these operations it is clear




that most wastes discharged by most generators




contain very little economic value.




               This is to be expected, of course.




The larger generators are highly sophisticated




technologists and they can best extract whatever




values there may be   They are doing this.




               Therefore the reuse or the recycle




values of these materials are mainly those which




occur at the treatment works where some degree of




intertreatability is found.




               This is a significant factor I might




say to the treatment works operator although it's



not a major cost factor.




               Treatment techniques have improved




with practice and with innovation.  The chemistry



of combustion is much better known and better




controlled.  The rigorous conditions to which




furnaces are exposed and the gas treatment systems




also exposed to these rigorous conditions




            have led to somewhat better designs.




               Also and most interesting I think

-------
biological treatment techniques, techniques




which have often been tried and often abandoned




have indeed been developed and successfully applied.




               This is a most significant accom-




plishment.  Particularly in the face of day to day




or even hour to hour biologically toxic variations




in these waste materials.




               Certainly biological and chemical




treatment procedures are preferred most operators




will tell you, they are preferred to incineration.




Incineration should be reserved for those highly




active and toxic wastes which can only be decomposed




at very high temperatures.




               As a matter of interest I would like




to report we have found facilities costs are pre-




dictable.  In fact they are rather well established




for plant sizes in the 100,000 to 300,000 ton per




year range.




               For example incinerator systems




cost to the  order of $15,000 per ton per day




capacity.  In contrast bio systems can be built




for about $3500 per ton per day.   And chemical




treatment systems which are highly variable may




cost on the  order of $4500 per ton per day.

-------
               Corrections needed here unfortunately




because incinerator systems by experience  have an




average availability of about 60 per cent because




of the high maintenance and repair outage.




               Therefore the productive cost




basis should be corrected from $15/)00per ton per




day to about $25,000 per ton per day.




               Operating costs have varied in




similar proportions and result in customer charges




in these more familiar terms of cents per gallon,




for bio treatments from 4 to 6 cents, for chemical




treatments from 4 to about 15 cents, and for burning




for incineration from 15 to as much as 80 cents




and more in some cases.




               In contract the maximum level of




landfill dumping charges today run about 3 cents.




You can see the problem.




               The operation of these waste plants




really is the proper business of chemical and




sanitary engineers and the technicians trained and




superviseed by them.




               It is a high technology business,




not because its end products, which are always




neutral salts, are sophisticated, but because

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the requirements of treatment, which must be done




within the economics of the market, are highly




variable and frequently dangerous.  It is not a




business for the uninformed.




               All available information indicates




that the major practitioners of hazardous waste




disposal have suffered substantial and continuing




operating losses.




               I have taken some figures from the




public financial statements of those public companies




in this business.  It is startling, for example,




four major installations representing a capital




investment of about $25 million, having a treatment




capacity of 1.5 million tons per year, operating at




about 30 per cent of that capacity, for a period of



almost 5 years, have sustained aggregate losses




of $9 million.  And somebody should ask why.  I do.




               The reasons I think are apparent.




We can talk about them a little bit.




               The several technologies involved




here, incineration, bio treatment, and chemical




treatment have been in a developmental stage




during these years.  Development is expensive.

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It costs a lot of money.




               Secondly, there has been a rather




inexorable pressure on the charges that these




facilities could make to their customers, since




there has generally been available landfill dumping




as an alternative, at much lower costs.




               Even though some landfill controls




have appeared and it seems that more will, the




enforcement is somewhat limited.  This is an




attractive business at the moment to the landfill




operators.




               And so as the chemical waste treatment




facilities developed they had tended to set a higher




level of charges under which landfill or ocean dumping



charges have indeed risen.  I don't know whether the




costs of landfill management or the costs of ocean




dumping have also risen.




               Nevertheless it can be stated that --




and it should be stated very plainly that treatment




plants cannot compete competetively with landfill




or ocean dumping.




               Traditionally if we looked only at




these figures and we considered only that for five




years this industry has not been profitable, if

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we considered  that  there is a lower competetive cost




available  for  disposal, onn would take this as a traditional








signal, a rather  loud  and clear signal/that this is




not an  economic  business,  that this is  not a business




and a desire by  the user.




               I really don't think that's the case.



However, it does pose  a dilemma as you can see to




potential  investors.   They are not going to rush




to invest  money  into  operations of this kind which



have  as  a history  a significant  loss.




               The  state of the industry then can be




iudqed.  I think significant private investment has




been made,  substantial support is available from




generators, adequate  transportation and handling




facilities  and skills  are  available.




               New  and effective  technology has




been developed,  and only two  conditions I think




remain  to  be resolved,  the local  agencies must




inform  themselves of  the nature of this problem,




and they must  deal  with it realistically.




               No special  dispensations are required,




and I might say,  further these agencies and the




Federal  agencies must  determine rather  quickly

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         the environmentally acceptable fate of




this 10 million tons a year.




               Obviously much of this material can




and it should be disposed into landfills, that's




not the question.




               It's equally obvious that a great deal




of it should not.  That is the question to those of




us who are in this business, and who have invested




in this industry.




               For  the economic benefit of the generator




this difference really should be clarified, so that




each of these methods of disposal will then function




competitively  in its own market place.




               The losses of the treatment plant



operators some of us feel shouldn't really become




the gains of the landfill operators, that accomplishes




nothing.




               The future of the chemical waste




industry, the preservation of the technology so far




developed and the fate of that 10 million tons per




year rests not therefore with the investors or with




the operators or with the technologists.  I think




rather it rests with the state and the Federal




agencies.

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                If there were  no  agencies  and  if




there were no regulations  at  all, there would  be




a small  industry based upon the  economic  relationship




between  the major generators, who chose to dispose of




their materials properly,  and certain regional plant




operators, and  of course landfill and ocean dumpers,




whose place would also be  identified.




                If the existing regulations at  all




levels properly recognized the hazardous waste




problem, there would develop we  think a large




sophisticated treatment industry, and the landfills




and the  sea would receive  only those dumpings  which



were proper.




                In the present twilight regulatory




circumstances,  however, some of  the regulations



which would be  drawn, the  purpose is becoming  in




fact an  impediment   to operators of facilities



of this  kind.




               For example, and  I believe this was




mentioned by the gentleman from Monsanto, these




operations are going to be regionally based, they




are not  going to be based  on the state lines or




the county lines or city lines.  This has got  to




be accepted.

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               Moreover, I would like to add finally




that the serveral levels of regulations, it seems




to me can be streamlined.  I do not know nor does




anyone else who works with regulatory agencies




why it is necessary that one operation must deal




in parallel with three or four separate agencies




all of whom have the same requirements,




               I do ask you therefore,  that the agencies




give some thought to this.  Thank you very much.




          MR. LEHMAN:  Thank you Mr. Bruns, will




you answer questions sir?




          MR. BRUNS:  Yes, indeed, if I can.




          MR. LEHMAN:  All right, Mr. Lindsey has




a question, and we also of course solicit questions



from the audience.




          MR. LINDSEY:  Mr. Bruns, I think the



information that you have given us here and the




data particularly will be quite helpful to us.




You have apparently thought this through quite a




bit.  Could you elaborate a little bit on how




in your opinion we should decide on which types




of things should go into landfills and which




type of things should not, and if you would give




some examples of the types of things that will

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also be helpful.




          MR. BRUNS:  I think there  are those who




probably know more about this than I do, those who




have concerned themselves with the characteristics




of landfills as they age.  And it seems to me that




this would inherently be the source  of guidelines.




And certainly we find in our own facilities as the




operator we find we are receiving materials which




really don't need to come to our plant.




               Simple materials, such as oily waste




waters, simple acids, low concentration phosphates,




with nothing else involved.




               These materials don't at all need to




go to an expensive treatment works.  They need to




go into landfills with the extent that the moisture




can be part of the landfill to the extent -- and




moreover to the extent where necessary that the




landfill itself will get into a treatment procedure.




And many landfills can do this.




               They can do it rather easily, and




I think it would be possible      for landfills to




receive even more materials than they may now be




receiving in some cases, and dispose of them very





very rapidly.

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               The other end  of  the  spectrum,  of




course, are those materials  which do not degrade bio-




logically and do not readily  simply  neutralize.




These are of course, principally the chlorinated




and  fluorinated  materials.




               The gentleman  previously  spoke




of P.C.B.s and certainly this  is one of  the  most




fearful materials which is produced  today,  and




it's something of course that  was in the newspapers.




               Any landfill operator who knowingly




permits such materials to be  disposed is I  think




very short sighted.  So for the  most part I  would




say 90 per cent of the materials available  in  the




marketplace today can be characterized  and  some  of




them can be related very directly to landfills  and




some of them under no circumstances  should  go  to




landfills, and there will be  some in the middle




that we don't quite know about,  but  they are there




too.




          MR. LINDSEY:  I have another  question,




which is from the floor.




               How does Hyon  dispose of  large




quantities of potentially toxic  amounts  of  chemicals




which are not in bulk quantity?

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          MR. BRUNS:  That's a very good question




because it's a very nasty problem.  We do receive




open drums actually filled with small vials, bottles




and containers and there may be hundreds of these




vials or containers and we do not always know what's




in each of them.  It is possible that a very small




vial will contain a very violently reacting material.




               We dispose of them -- we can't sort




them or label all of these things and you can't charge




enough to permit that to be done.  The producer doesn't




do this either although he is supposed to characterize




these things to some extent.




               We just burn them.  We subject them




to relatively high temperatures, the containers will




rupture and the materials will burn to the extent




that they will burn, and sometimes they'll damage




our equipment to the extent that they are acids.




We add that to the cost of our business.




               There's not too much of this, but




there's enough of it, to be a very great  nuisance.




It's so much of a nuisance that you can't even




envision the man's name -- they are emptying these




things all day long.




          MR. LEHMAN:  I believe we have  another

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question, Mr. Newton, please.




          MR. NEWTON:  Sir, you characterize the




peculiar posture of some state agencies manifested




in the geographic distribution of generators




using your services.




          MR. BRUNS:  I don't fully understand, you




mean what states?




          MR. NEWTON:  Is there a variance in the




use and relationship?




          MR. BRUNS:  Yes, we found a variation in




the relationship, a very wide variation.  I think




that peculiar posture of the words I chose refer




principally to the fact that we have not noticed




the state agencies directing themselves to this




problem specifically.



               Rather, we have noticed, that these



facilities are incorporated along with -- these are




Just additional waste treatment plants.  Not quite



that simple.




          MR. LEHMAN:  There's another question,




Mr. Kovalick.




          MR. KOVALICK:  From the floor.  The question




is who do you feel should establish the residue




standards of plants such as yours?

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               And what  if  state  standards  regulated




that sludge proposal?




          MR. BRUNS:   I  think that  the  existing




standards are directly applicable to  the  residues




for the existing facilities.




               Actually  these facilities  are  only




staging areas.  Their  final products  are  going to




be neutrals, salts and some are going to  be ash.




To the extent that such  salts can be  disposed




locally, they will be.  To the extent they can't,




they will end up in the  ocean one way or  the  other.




Even if we have to barge them all the way down the




river.




               Salts have been going  to the sea




for rather long periods  of time and that's where




they go.




               But I think chemically and insofar



as toxicity is concerned as far as  environmental




damage is concerned, the emissions  from these




facilities should comply with the established




standards.




               And that's the function  of this




service.




          MR. KOVALICK:  I guess another question

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relates to your remarks on financial condition




of your industry.  From the floor -- are regulations




controling the disposal of hazardous substances




enough or would the industry also need legislation




such as Ohio has which authorizes state agencies




to issue industrial revenue bonds to help finance




facilities?




          MR. BRUNS:  I don't think that really




makes any difference in today's money market, to




tell you the truth.




               I don't really think you will raise




money very much by revenue bonds or whatever.




The requirements here are not that large, the




investment is not that large.  I think the important



aspect of the matter is and I could have said this,




times have changed and I refer to some five years



experience.  As of this time the financial cir-




cumstances of the several facilities which I




looked at have changed.  Happily.




          MR. LEHMAN:  All right.  I don't believe




there are any further questions of Mr. Bruns.




               Thank you very much Mr. Bruns, and




I'd like to now make an announcement before we




go on.

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                               (Whereupon a discussion




                               was had off the record.)




          MR. LEHMAN:  On the  record.  Now, I'd




like to next call upon Mr. Thomas P. Clark of the




Illinois EPA, is Mr. Clark here?



               Yes, and while  he is coining up,




let me just alert the next speaker, Mr. Dan Kolberg




of the Wisconsin Department of Natural Resources.




          MR. THOMAS P. CLARK:  I hope you can all




hear me in the back of the room.




               My name is Thomas Clark.  I'm employed




with the Division of Land Pollution Control of




Illinois Environmental Protection Agency, which




is a state regulatory group.




               Passage of the  1970 Resource Recovery




Act brought national attention to the growing problem



of hazardous waste management.  Since that time, Federal




and state initiatives toward control of hazardous




wastes have mushroomed to the  point where many states




have established hazardous waste management divisions




within their solid waste programs with legislative




authority to inventory and control the generation,




transportation and disposal of such wastes.




               Illinois is no exception to this

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continuing trend.  Within the past year and  a half,




major emphasis has been placed on refining a supple-




mental permit system for the safe emplacement of




liquid and certain hazardous wastes into environ-




mentally sound disposal sites, developing guidelines




for management of special and hazardous waste, now




in final draft form; preparation for promulgation of




liquid and hazardous waste hauling regulations




before the Illinois Pollution Control Board; and




cooperation to provide means to minimize the volume




of hazardous wastes relegated to the land by imple-




mentation of the waste-exchange concept.




               Rather than discuss these initiatives




in any great detail, I will briefly address  several




key problems and areas in consideration of any



hazardous waste management program which will hope-




fully have some impact on development of a national




perspective on guidance for proper management of




these wastes.




               First, in defining hazardous wastes,




it is important that they be distinguished from




hazardous materials, or hazardous substances.




               Hazardous materials are generally




considered pure substances and not wastes.  Mixtures

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of hazardous materials comprise  a  much  larger  group




of hazardous wastes.  Regulations  developed  by the




U.S. Department of Transportation  pursuant to  the




Hazardous Materials Transportation Act of 1974




interpret hazardous wastes to be hazardous materials




and therefore subject to the definition  of hazardous




materials as included in that act.




               From the point of view of  a regulatory




agency in control of the transportation  and  disposal




of hazardous wastes, it is important to  remember that




such wastes are complex mixtures of pure  substances




and that no two are exactly alike.




               With this in mind,  it becomes increas-




ingly difficult to develop specific regulatory defi-




nitions for what is hazardous and what  is not.




               Second, general legislative definitions




of hazardous waste must be supplemented by a more




specific and rigorous regulatory definition  if a




state control program is to have meaning.




               In Illinois, we favor defining




hazardous wastes by specific criteria such as  are




discussed in our guidelines, supplemented by a




suggested list of hazardous materials which would




be updated periodically.

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               This would comprise hazardous wastes




within a five-fold waste classification system we




have developed.  We propose defining hazardous




wastes by specific criteria with the understanding




that such criteria must be applied carefully if




they are to be effective.




               Particular care must be taken to




consider the whole waste rather than to focus on




individual constituents within a particular waste.




If there is any question regarding designation



of a waste as hazardous or if a waste is comprised




of a hazardous material not identified in the list




appended to each classification, that specific waste




can be tested and an unequivocal decision made based




on the specific criteria.




               Third, and finally, the most important,




the guiding philosophy of any regulatory agency




hazardous waste management program should be we



believe to minimize hazardous waste disposal on land,




that is, to concentrate such wastes at the source




rather than to dilute them throughout the environment.




               One increasingly significant means




of accomplishing this task is through the waste




exchange concept which is just beginning to be

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developed here In the United States, after gaining




considerable importance in Europe.




               The Illinois Environmental Protection




Agency, in cooperation with the Missouri Department




of Natural Resources, the U.S. EPA and the St. Louis




Regional Commerce and Growth Association, has recently




implemented such an exchange in the St, Louis, Mo.,




E. St. Louis, Illinois, area.




               The overall concept is aimed at con-




verting certain wastes from expensive disposal




problems to saleable assets, while conserving natural




resources and reducing the environmental impact from



indiscriminately   dumped hazardous wastes.




               At the heart of the exchange system




is a volunteer task force comprised of local citizen



and industry interests, consulting firms, and




members of the Illinois EPA, Missouri DNR, U.S.




EPA, St. Louis Regional Commerce and Growth




Association and the East-West Gateway Coordinating




Council.




               The exchange is concerned primarily




with industrial wastes for which no developed




commercial market has been demonstrated.  Thus,




certain chemical process wastes and metal sludges

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are included whereas scrap metal, for example, is




not.




               An initial press release to trade




journals and the news media has been provided to




include instructions to potential users.  For a




$5 fee to recover administrative costs, the RCGA




arranges for publication of details regarding




wastes for sale or being sought in the market.




               Information about the waste, it's




manufacturer, and geographic origin are kept




confidential by RCGA, which then matches prospective




buyers with interested sellers.




               A listing company decides whether




it wishes to do business with the inquirer at which



point RCGA and the Waste Exchange relinquish involve-




ment.  A survey form will then be sent to involved




parties concerning results of the negotiation in




order to keep waste exchange files up to date and




assess program effectiveness.




               It is hoped that programs such as




this involving both private and public sectors




will at least serve as a start to reduce significantly




the volume of hazardous wastes to be disposed on




land.
                          f ."">

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               In summary, the State of Illinois




through its Environmental protection Agency and




its research arm, the Illinois Institute for




Environmental Quality, feels that the business of




establishing a comprehensive hazardous waste manage-




ment program must be carefully defined both in




terms of legislative and regulatory criteria for




determination of what is and is not hazardous.




               Major emphasis should be given to




reducing the volume of hazardous waste to be disposed




at the source and thus reducing the necessary disposal




loci for such waste.




               Finally, the regulatory effort must




involve control from cradle to grave to be effective.




This includes not only source reduction through such




mechanisms as the waste exchange, but control of those




who haul liquid and hazardous wastes and strict guide-



lines for those whose job it is to see that they




reach a safe final resting place,




          MR. LEHMAN:  Mr. Clark will you answer



questions?




          MR. CLARK;  Yes,




          MR. LEHMAN:  Thank you Mr. Clark.  Any




questions from the audience.  Mr. Kovalick.

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          MR. KOVALICK:  Mr. Clark,  previously




the preceding speaker commented  that  regulations,




state or Federal,  should be applied to such facilities




as his and should be recognizing the  interstate




market they serve.  Could  you comment  on Illinois'




services?




          MR. CLARK:  I could comment  on that,  there's




a great deal of movement across  state  lines.  We




realize this and we had a  meeting  of  the Region  V




U.S. EPA yesterday, which  includes  Minnesota,




Wisconsin, Illinois, Indiana and Ohio,  and  I  think




there is an increasing awareness on the part  of




the states that the regulatory effort  is going  to




have to be a cooperative one, and  our  regulations




are going to have to fit together,  and  definitely




take into account both inter-and-intra  state  move-




ments of these wastes.




          MR. KOVALICK:  One other  request.   In




fact if any of these documents that  you mentioned




in your  statement,  that is the guidelines  for i-h«=



management of special and  hazardous  wastes  or




the liquid and hazardous waste hauling  regulation




for the ITCB are  available, would  you  mind  sending

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them to us for the  record.
          MR. CLARK:   Okay,  I  believe  we  have done
that already, but we'll  certainly  provide you with
copies.
          MR. KOVALICK:   It might  not be the right
draft and so forth,  and  so  on,  but we'd  appreciate
it.
          MR. CLARK:  Well  certainly  do  that.
          MR. NEWTON:  Mr.  Clark,  I have a question
from the floor, please.
               rfhen  final disnoqal n-F toxic materials is
controlled by state agencies, should they  also determine
the number,  type and  location  of facilities,  and  if
so describe a practical  method  of  overcoming the
economic incentives  in the  problems,  thereunder.
          MR. CLARK:  Okay.   With  regard to the
first part of that  question,  I  don't  believe it's
really the position  or the  responsibility of the
state to control necessarily  the number  of these
locations.
               In other  words,  keep -- have  to
limit them specifically.  In Illinois  we  feel that
the hazardous wastes  disposal sites are  going to
have to be exceedingly good geologically from an

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 engineering point  of view,  and because of our




 environmental conditions in this state, with




 regard  to geology  we think  this is going to be




 necessarily a self-limiting factor.




                Would you go through the second part




 of  that question again.




           MR. NEWTON:   Describe a practical method




 of  overcoming the  economic  consensus  and/or what




 we  might call the  public acceptance or local accept-




 ance  problems.




           MR. CLARK:  I'm not sure I can do that,




 right now in Illinois due to a recent State Supreme




 Court decision.  The Environmental Protection Agency




 in  its  review process has been mandated to overrule




 local zoning should  local zoning not allow for a




 particular facility  at a certain location.



                In  other  words, we have the authority




to  overrule local zoning, but how long we are going




 to  have this authority is somewhat in question.




                Believe me we are looking at this




 very  carefully and we consider this an extremely




 important responsibility and we also recognize




 that  we are going  to have to look not only at




 engineering geologic criteria, but also land use

-------
criteria, due  to  the  hazardous waste  situation.




          MR.  LEHMAN:  Mr. Klepitsch,  do  you  have




a question?




          MR.  KLEPITSCH:  Yes, I have  a question




from the floor.




               Does Illinois  allow  disposal of




hazardous wastes  in sanitary  landfills which  are




primarily used for municipal  purposes?




          MR.  CLARK:  Yes.  Until we  get  our  guide-




lines and our  liquid wastes regulations we are




allowing certain  amounts of gaseous wastes from




a case by case basis to be disposed of in sanitary




landfills, except municipal refuse.




               I  might add if you look at these




on a case by case basis, it is handled through




our supplemental  permit system, and there are




generally very strict requirements  as  far as




acceptance in the community and this  is related




to cubic yards of municipal refuse.




               And currently  in Illinois  we also




have one site at  this time which is accepting




solely containerized hazardous wastes, at this




point that site is unique.  But I think in the




future we'll probably see more of these sites.

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          MR. LINDSEY:  Yes, Mr. Clark, I have a




question from the floor,




               A lot of interest apparently in




the St. Louis Regional Exchange, could you tell




us how successful this has been and what volumes




have been handled and also could you comment on




whether wastes       from outside the St, Louis




area would be accepted?




          MR. CLARK:  This is the waste exchange




concept in the East St. Louis area, it's very




recent, and it's only been formalized as of the



1st of November.




               At this time we really don't have




too much of a feeling for how successful it's



going to be.




               It's patterned pretty closely after




several of the waste exchange concepts in Europe.




It is my understanding that waste will be accepted




from outside the metropolitan St. Louis area.




          MR. LEHMAN:  Mr. Kovalick.




          MR. KOVALICK:  I have two questions




from the floor, and these first two are related.




               You spoke of the source of waste




in your remarks and both these questions relate

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to what is the definition  of  a  source  of  waste and


you suggested concentration of  waste  at  its  source.


               Are you  suggesting  that  the generator


treatment ''and disposal, as  contrasted to off-site


management — should be done  by outside companies?


          MR. CLARK:   I'm  not necessarily suggesting


that.  I think it should be done either place.  Or


overall we should reduce insofar as possible  the


amount of waste, in the best  possible way.


          MR. KOVALICK:  And  the second question is


why are so many disposal operators  in  Illinois being


cited for operation without a permit?


          MR. CLARK:   I think we have to  distinguish


the type of permit that's  involved  here.  What I


was referring to in my  remarks  here were  supplemental


permits to sites which  already  have EPA permits


to operate a landfill.


               What the questioner  there  may  have


been referring to was  our  recent initiative to


close operating municipal  revenue  sites,  which


have not come through the  initial  process.


               Supplemental permits  to take  liquid


or more hazardous waste are the only sites which have


Illinois EPA authorization.
                     ft
                     «   i f* ~*
                        kbi

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          MR. LINDSEY:  I have  one  more  question




from the floor.




               What would you propose  for  a




disposal of explosive wastes and  related products?




          MR.CLARK:  That's an  extremely difficult




question and the answer we have talked about  it




quite a bit.  If at all possible  I  would say  that




explosives should be  detonated  and in  a  safe area.




               Now you'll go on and ask  me what a




safe area is, and I'm not sure  I  can answer that




question.




               Fortunately in Illinois so  far the




explosives problem has been a minor one.  But we




agree that it is a very serious and significant one.




          MR. LEHMAN:  We have  another question




by Mr. Lazar.




          MR. LAZAR:  This is also  from  the floor.




Are cadmium and chromium metals amonq the  most hazardous?




          MR. CLARK:  They have been.




          MR. LEHMAN:  Mr. Kovalickwill read another




question.




          MR. KOVALICK:  You indicate  that at the




present time Illinois EPA is opposing  -- I mean




approving the disposal of hazardous wastes on a

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case by case basis with municipal waste.  Will




this practice be allowed to continue?




               Or are you about to curtail  it?




          MR. CLARK:  I'm not  sure I totally under-




stood that question.




          MR. KOVALICK:  I think the reference  is




                        defining • hazadous wastes at each site




-- is your policy as stated for that?




          MR. CLARK:  I think we're looking at  this




as a short term policy, and eventually what we  want




to try to do is establish hazardous waste sites  or




by the California definition, class one sites through-




out the state and as I mentioned earlier, we have one




B site, and I believe as I also mentioned earlier,




I think that geology, groundwater situations, and




so on are going to limit the number of these sites




severely.




               I think we're probably talking now




about a half a dozen sites.




          MR. LEHMAN:  Are there any other questions?




I believe not.  Thank you very much Mr. Clark.




               Ladies and gentlemen, I think in




view of the timing here, we are not going to have




enough time to have another speaker before our

-------
scheduled break, so I'd like to do it now.




               please be advised that we have a




large number of speakers including a number who




have signed up just this morning.




               So,  I would like to make sure that




when we do break that we reconvene and start on




time.




               At this time, I would like to adjourn




the meeting for fifteen minutes, and reconvene at




10:35.



               Thank you very much.




                              (At which time a brief




                               recess was held for




                               a coffee break.)

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          MR.  KOVALICK:   Ladies  and  gentlemen,




would you begin  to  take  your  seats,  please.




          MR.  LEHMAN:  Ladies  and  gentlemen,  please




take your seats  now.   I  now call the  meeting  to




order .




               I would like to call  upon Mr.  Dan




Kolberg, Wisconsin  Department  of Natural Resources




and while he's coming  to  the microphone, I want




to say that the  next speaker will  be  Mr, Bernard




Reese, and following Mr.  Dennis Johnson.




               Mr.  Kolberg.




          MR.  KOLBERG:  My name is Dan Kolberg, I




am with the Wisconsin  Department of  Natural Re-




sources, and I work in the solid waste management




section, and also as part of the hazardous waste




management committee,  that's part  of  the present



work of that section.




               What I would like to  do this




mvQxning very briefly is try to discuss a few  of




the needs that the  State  of Wisconsin sees with




respect to continued development of the hazardous




waste management program, and  1 would like to make




some recommendations as far as the things that




it sees important for  Federal   government and

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Federal EPA to consider with  respect  to  development




of a hazardous waste management  program  and  any




proposed legislation on a national  level.




               The first thing that we see as  being




exceptionally important at the present time  is the




somewhat limited funding of the  solid waste  programs




with respect to state program planning grants  in




the area of hazardous waste management program




development.




               At the present time  the solid waste




programs are funded at a somewhat substantially




lower level than either the air  or  water  programs,




and one of the problems with  this is  that the  solid




waste program in some respects bears  the  brunt of




handling many of the residues generated by control




programs in either the air or water areas.




               While primary  emphasis of  some  of




the air and water programs is aimed at the separation



and removal of residues from  either the  air  or water




streams.  The solid waste section along with the




hazardous waste management work  is  aimed  primarily




at the total management of those residuals once




they are removed.




               Now, in order  to  do  this  on a wide






                       V'2

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scale basLs  state-wide,  with all  the various




industrial applications  from the  air and water




programs, we find that  it  is going to require and




is requiring at the  present  time  a great deal of




sound state planning and program  development work




which is going to need  additional support.




               We are going  to  conduct these planning




and implementation   functions properly.  Another area




that I would like to touch on along      the lines




of the importance of increased  funding for  planning




and implementation  of some of these things  and pro-




grams is the idea that  a much greater emphasis,




particularly with respect  to the  management of




hazardous waste materials  is going to have  to be




placed on the training  and technical assistance




portions of those prog-rams.




               Now,  this would  include several basic




things.   It would include  training funds to support




development I guess  you  could say,  of qualified




people who would be  able to  both  man and implement




the various hazardous waste  systems.




               It would  include expanded program




s-upport  directly to  the  universities, for training




purposes, and would  also include  the type of funding

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that solid waste section independently would use




to conduct some of its training efforts with




respect to training and getting information across




to various groups like the industrial waste haulers,




to some of the site operators of the management --




hazardous waste management facilities working




directly with site operators.




               This type of training and technical




assistance and support.




               The second major thing that I would




like to discuss is being critical from the way the




State of Wisconsin sees the development of the program




at both the State and national levels, is that re-




cognition really has to be made as to the vital role




the state does play with respect to all the various



concerned agencies in the development of these pro-




grams .




               Now, this is from the standpoint that




the state directly deals with many of the industries




and the waste problems that they have.  We routinely




are requested to provide technical assistance and




answers to some very difficult questions, as to




what the best alternatives are for managing the certain




types of hazardous wastes.

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               We  are  involved in attempting to




define what the problems  are  in trying to assess




what the best  alternatives  for handling wastes are,




and collecting data  and analyzing that to arrive




at sound decisions,  and planning for  all the various



aspects  of a total  hazardous waste management nrograra,




and then for the  actual   implementation Of various




planning efforts  that  are undertaken.




               Now,  as far  as  some of  the planning




and  implementation functions  and the  administrative




tools associated with  those things, on a state




level, you can see that there  are a good number



of things that are included in  the development ot




a total hazardous waste management program.




               These things include actual  regulation




of hazardous waste management,  standard setting,



enforcement, plan review, license and  permit issuance



surveillance, very  detailed  education programs for




the various groups that I mentioned before,  technical




assistance on a case by case basis, to particular




industries with waste management  problems,  and




providing financial  incentives  for the development




of new facilities where they are  needed.




               Ongoing planning  work and upgrading

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work to improve the program  as you  go  along.




Research in critical areas,  where the  answers




are not available right now, but for industry




who is interested in trying  some unique  approaches,




to manage a particular problem waste.




               Operating certification programs,




and some of the questions  of both interim  and  long




term monitoring programs for hazardous waste manage-




ment facilities.




               The third main point  that 1  would  like




to make is that even though  I am attempting to define




that the state does have a key role  in the  entire




hazardous waste management program,  development on




both the state and national  level we recognize full




well that we could not do  this entirely  by  ourselves,




and that we do need a great  deal of  assistance and




support from the Federal government   in the  development



of these programs.




               It's a little bit more  difficult to




try to define for myself at  least some of  the  key




responsibilities or the limits of authority that




the Federal  government mignt: have in providing




this support but some of the areas  that  we  consider




very important for them to address  would be helping

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to define for the states this question  of  generator




responsibility as well as responsibility of  any




particular point in the entire waste management




chain, meaning the transportation  or the disposal




operators, processors or whatever.




               The actual transportation and  labeling




requirements and the interstate concerns for  the




shipment of hazardous materials under discussion and




some type of uniformity with this  manifest system




whereby reporting would be conducted to all  involved




concerned agencies on the flow of  hazardous  materials,




and also some support and technical  assistance in




resolving some of the questions associated with




long term care, maintenance and monitoring of the




hazardous waste facilities.




               Now, we would anticipate that  beyond




simply proposed legislation on a Federal level, that




the type of assistance that we are talking about in




these various areas would also include  technical




assistance, meetings with the states to discuss




plans and approaches that various  other agencies




throughout the country are taking  On for some of these




problems.




               Serving as a coordinator and  able

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to disseminate information on the status of programs




in other areas to the state so that some fairly




uniform approaches to keep us from operating on




at least a regional basis.




               Final -- the final point that I would




really like to try to make this morning, is the




state's view of the critical need for what is referred




to as the cradle to grave approach for management of




hazardous wastes.




               We feel in the State of Wisconsin




that as part of its total cradle to grave approach




for managing wastes, there is definitely a greater




emphasis placed on the development and utilization




of other alternatives for managing and disposing




of hazardous wastes than the simple land disposal




function.




               And, we have had  several very important




experiences dealing with specific experiences in




our state that seem to indicate to us at this point




in time that the industry also  perceives the need for




some cradle to grave approach if you're dealing with




the hazardous waste problem.




               Now, this has resulted from the fact




that in some cases specific problems were being

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encountered by the industry with finding a disposal

alternative for a particular type of waste and

they contacted the state agency     in an attempt

to find out what other type of alternatives might

be available to them for handling the waste materials,

and they found that the alternatives were fairly

limited but there were some areas where they might

be able to channel some of their efforts in dealing

with their waste problems.

               In simply looking for a disposal al-

ternative they also recognized that other important

factors entered in, that they could make various

changes directly within their industrial manufacturing

processes.

               Change the characteristics of the waste,

reduce the amounts that they had to get rid of, and

they found that not necessarily all of the waste

had to be handled or processed or disposed of in

the same means at the same facility but they found

that different facilities were available for different

portions of their wastes.

               And so they also recognized the fact

and several corporate policy statements were madp

to the effect that the greater amount of pressure
                      t

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was being placed directly  on the  industry to utilize




licensed   facilities  and facilities that have all




the appropriate permits of the  state agency.




               And  so they did  come to us ant! request




on the part of our hazardous  waste manage-




ment  program that we  look  at this entire approach




as it relates to all  of the phases of hazardous




waste management, including generator's  resoonsibilities,



transpiration   and  labeling processing, and then final




disposal of the waste materials.




               That's all  I have  to say, and I'd be




happy to try to answer any questions at this time.




          MR, LEHMAN:  Thank you  Mr. Kolberg.




          MR. KOVALICK:  Mr. Kolberg, did I understand



that  one of the recommendations you had for the



Federal government   was I heard  some kind of a




manifest system ought to be inaugurated and in-




vestigated and I did  not get to the thrust  of that




point, do you feel  it's preferable that there be




some  kind of a transportation tracking that's




often referred to as  a manifest system at the




Federal level versus  the state  level?




          MR. KOLBERG: Not necessarily at the




Federal level.  That's the point  that I have a

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 little trouble with personally, trving to define




 just  how  far  EPA should go in becoming  involved




with  those  things.




                But  my point was, at a minimum we




 feel  that the EPA does have information  available




 and it would  be very important to,  interact by way




 of technical  assistance and  coordination exchange with




the various states  on development  of plans  for




 a manifest  system possibly exchanging information




on the approaches being taken by some of the  other




 states.
          MR.  KOVALICK:   One more question.   You




spent  some  time  in your  remarks talking about




training  as  an important element.  I presume  you




are referring  to the training of site and  facility




workers and  operators as well as treatment plant




oper at or s,




                Is  it also your view that the




training materials that  are available to the




chemical  industry   which are very coimarable  to the




kind of plants that Mr,  Bruns discussed this





morning are  insufficient for your needs at the

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moment ?




          MR. KOLBERG:  That's a little hard to




answer because I am not all that sure that I




understand or am aware of the materials that




you are referring to right now.




               But the type of training programs




that I am talking about would tie right into the




developing of the state programs and making the




various interested parties in the hazardous waste




management system aware of the approaches that the




state is taking, and some of the technical concerns




that we are aware of in respect to the operation,




development and all of the aspects of the facilities




that we have to deal with as well as -- well I guess




I mentioned this but make people aware of the pro-




gression of the program, the things to look forward



to, as it develops further.




          MR. KOVALICK:  Perhaps as much a public




education and training in a technical sense.




          MR. KOLBERG:  Yes, within the various;




groups, like you mentioned industrial waste --




well, the operators themselves, and that type of




thing.




          MR. KOVALICK:  Thank you, I see.

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          MR. LEHMAN:  Any  other  questions?   Yes,




he's bringing a question up  from  the  floor,  would




you please remain there Mr.  Kolberg.




          MR. LEHMAN:  Oh,  I  see  this  question




was for a previous speaker,  evidently.   Well,




anyway, Mr, Kolberg,  I want  to thank  you very




much.




               Excuse me, - ••  all  right,  thank you




very much Mr. Kolberg.




               I would like  at this time to  call




on Mr. Bernard Reese.  Is Mr, Reese here?




               Well, we'll  have to come  back to




him later.  Let me call then  Mr.  Bill  Walker,




from Geraghty and Miller,




          MR. WILLIAM H. WALKER:  Mr.  Chairman,  I




have cut some of my prepared  statement  for the  sake




of time.  But may I suggest  that  all  of  my written




testimony be included in the  record.




               My name is William H. Walker,  and




I've worked with  the ground water area of  this whole




thing for about 27 years, now.




               First with the Federal  government




then with the state of Illinois for about  17




years, and now with ground water, so my  approach

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to this will be basically  on  ground water protection




standpoints, but  also  from an overall environmental




protection  standpoint  slant.




               Before  I  start I  would like to say




that I would also hope to  direct  my statements to




you the EPA people of  the  country because everybody




everywhere  is looking  for  guidance and we feel that




you people must set at least  a policy on these




areas.




              My work  has carripr!  me to Eurooe f*>



investigate their hazardous waste disposal approach




to things,  and my trip has taken me to Canada in




the past, and I see that Canada  also is looking




to you, and I know that we in the states and the




private industries  and consulting firms would likp




to know what you think  and how we can adapt our-




selves to your thinking  and still stay in business.




               So with these  thoughts in mind,  I




would like to direct my  testimony and if I do run




over slightly, pleast  stop me.




               At the  present time,  practically




all of the hazardous wastes generated in the




heavily industrialized parts  of  the world are




eventually dumped somewhere,  on  or beneath the

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 land surface, or into some nearby stream or ocean.




                Water dilution, land attenuation, and




 storage generally are the most common methods of




 treatment employed.  Ocean burial and deep mine




 or  well injection are secondary throw away methods




 used where alternative dumping methods are too




 costly, or where thw wastes involved are too




 hazardous for land disposal.




                Incineration, chemical treatment, and




 recovery recycling of most types of hazardous waste




 material are usually uneconomical under prevailing




 legal constraints, cost considerations, and technological




 limitations.




                Depending upon the nature of  the hazardous




 waste to be treated, land disposal costs now range




 from about 4 to 50 times less than other available




 processing or treatment methods.  For as long as this




 wide economic discrepancy prevails,  there appears to




 be  little hope or expectation anywhere that anything




 better  or cheaper will be accepted.




                As an ever-increasing tonnage of




 hazardous waste is generated, it just doesn't




disappear,  it has to go somewhere, we know that the




 ground  then will be receiving and called upon to

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receive more  and more.   We  are not against this,




we think that  the  ground in its proper use can




receive a  lot  of it.  We'd  also like to point out




though that these  other  dissipation means are there,




surface water,  the soil  and the vegetation should be




called upon to receive  its  fair share of the load




as well.   Not  iust all  underground water.




                Groundwater  and soils contaminated




with toxic chemical waste may be potentially much




more hazardous than these  other dissipation means,




you can't  see  the  groundwater pollution, it's out




of sight,  out  of mind,  they are not checking for




many of the hazardous chemicals that possibly are




there.




                In  the air  on the other hand you can




see the trees  start to  die, and the birds start to




get sick,  much before people start to get adverse



affects, as is -usually tne case,  and in streams 
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hazardous contaminants  such  as  viruses,  chlorinated




hydrocarbons, cyanides  or  organophosphates  and heavy




metals.




               It's too costly.   Some  of them cost




two or three hundred dollars  if you can qet  somebodv to




analyze them in the right  way.   And they keep changing




their  analysis procedures  and all  this,  so  it's




awfully difficult in that  regard  on some of  them.




They haven't standardized  the laboratory procedures




quite  yet in most areas, and you  don't  have  dependable




fail-safe analytical equipment  that's  everywhere  avail-




able and they are still in the  development  stages  with




some of that.  So it makes it difficult  to even  identify




some of these air contaminants,  you have --  you  don't




have trained persons available  really  throughout  the




country that can give you  results.




               The laboratories  aren't  registered,




s0> fraia one laboratory  to  another  you  might  get




results of entirely different degress.




               So, with this kind  of thing being,




as it  is, much effort needs to be  exerted1 I  think




from somewhere in this type of  thing.




               We don't know the  subclinical  effects




of some of these various hazardous  chemicals,  and

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once we dump them  somewhere  there might be an




infinite number  of  combinations of these things




and we'd have to try  at  least  to get some sub-




clinical  effects of those  types of things too,




as we go along.




               As  1 have  said  earlier nany of the




problems we have had  with  this groundwater pollution




area have been because the  laws were passed first




for surface water  protection and for air protection.




So the only place  left was the ground to dump it.




               We  think  that industry is trying their




darndest to do something  about this, and it's faced




with a real dilemma.   They  are  getting more concentrated




waste  because they now  have to get it out of the air




or surface water,  and then these concentrated wastes




have to be dumped  on  the  ground somewhere and knowing




where to dump them  within  economical hauling distance




gets to be a terrific problem, especially when it




may be  two or three hundred miles away to tne tirst sate




place to dump it,




               Rules and  definitions of this whole




thing keep changing too.   The  most economical and




practical degree of treatment  continues to be




changed on us,

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               And  then  they seemingly are adding




a whole stream of pertinent  legal  and economic




technical changes into this  to change the regulations




because we came  into  this  thing with such a cold




water plunge that now we don't have  time to do




anything, but exist  with  laws that  had to be passed




but that need badly to be  changed.




               Air  and surface water pollution protec-




tion laws which  force an ever-increasing quantity of




hazardous waste  to the land for ultimate disposal must




be changed drastically,  it seems,  and quite soon, if




the optimum environmental  protection is to be realized.




               All  new laws  developed and finally




adopted must be  a part of  an overall environmental




protection act which  permits and forces all mafor




pollution dissipation regimes, and that is air,




surface water, groundwater,  soil and vegetation,




to share to their full capability  their proportionate




part of the burden  of total  pollutant transport,




containment and  dissipation.




               No longer can we continue to solve




pollution problems  in one  dissipation regime in




such a fashion that an even  more serious and




hazardous problem may be created in  some other

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equally important ecosystem.  If laws are to insure




protection of the air and surface water, so must




they also equally protect the groundwater, soils




and plant regimes.



               At the present time, these are




everywhere being placed in serious ieopardy by




existing laws that do -- should be changed.




               Hazardous chemical waste materials




such as chlorinated hydrocarbons can be best burned




in high (incineration type) temperatures.  Along this




line it's being employed a little bit more in this




country, and we think someone should help to develop




the incineration equipment to make it easier to do




and then have incinerators located where we can




do it.




               We have to have a lot more wide




acceptance of it, and it's going to be more costly




and this too has to be considered, in the long



run, but this is a better way in which someone




should start to think along those lines.




               Then by the same token, trace con-




centrations of many of the toxic metals, and such




pollutants as nitrate, chloride, and sulfates,




can best be reduced to harmless levels by dilution

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in very large volumes of surface water  flow.




               Chemical reconstitution  of  some




of the pollutants to an inert, relatively  insoluble




form, encapsulation in an impermeable container  or




polymer for later recovery, and chemical  separation  or




recycling are equally viable alternative disposal




methods which must be covered by the law if optimum




pollution abatement and control at minimum costs




are to be assured.




               All new pollution protection laws




should reflect the legal philosophy




     that poisonous chemicals and other wastes known




to be harmful to public health     must be considered




guilty until proved innocent, instead of innocent




until proved guilty as is now widely accepted.




               Only in this way can the burden of



proof of a pollutant's guilt or innocence be




rightfully placed upon the polluter, not upon




affected society as is now the case under existing



laws.




               This new approach in law should




encourage hazardous pollutant volume reduction and




subsequent pollution abatement from such sources.




In unique cases where it fails to do so, volume

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reduction of the more hazardous pollutants may




have to be dictated by imposing true cost disposal




assessments on the manufacturer-user and/or placing




legal constraints upon the total quantities manu-




factured .




               Also, hazardous chemical wastes  from




industries, biological, virological, contaminated




sewage from hospitals, and chemically contaminated




runoff from streets, parking lots, and factory




grounds are now commonly dumped into sanitary or




interconnected storm sewers.




               Such wastes significantly reduce the




quality of municipal plant effluents, sometimes to




levels not permissible for disposal in streams  or




on the land.  For this reason, any laws passed  also




must reflect consideration of these adverse factors




by encouraging, or even forcing where necessary,




separation of industrial and storm runoff streams




from existing sewage treatment facilities which




are primarily designed for the processing of domestic-




type wastes.




               In the United States there are no




all-inclusive regulations governing hazardous




chemical transport, and spill cleanup.  Also these

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regulations in effect are very  fragmentated  and




distributed among so many different Federal,   state




and local governmental regulatory bodies  that  it  is




very difficult to even get  in contact with the




proper authority controlling any given  part  of the




problem.




               The United States Department  of




Transportation regulates, on the Federal  level,




rail and highway interstate transport,  but is  not




responsible for intrastate movement  of  hazardous




chemicals.  The U.S. Coast Guard deals  with  barge




transport, and some other Federal department  is




charged with air carriers.




               All of these departments    are  primarily




charged with the responsibility of preventing  hazardous




material spills.  If a spill actually does happen,



the U.S. Environmental Protection Agency  or  some




state environmental protection  agency must be




contacted for assistance in cleanup     pollution




control.



               Without exception, all of  these




agencies are understaffed and underfunded to  perform




their respective assigned tasks.




               For example,  one employee  of the U.S.

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Department of Transportation, Highway Branch, has




stated that in their branch there are only 6 specialists




in hazardous chemicals assigned to the entire United




States.  And that these 6 do not have ready access to




any emergency spill safety equipment or fast trans-




portation means of getting to a particular spill




occurrence.




               Nor  are they able to routinely inspect




the many thousand transport vehicles, or to see that




proper training is given the more than 5 million




active truck drivers in the country.  They don't --




can't see how they can get around to training 5 million




truck drivers who -- in the country, that may at one




time or another be called upon to drive a vehicle



containing hazardous materials.




               Most firemen and policemen are not




trained to handle spill accidents.  State and local




laws on the subject are generally nonexistent, and




even fewer qualified personnel and less money is




available at these lower governmental levels than




prevail at the Federal plateau.




               No laws are in effect requiring




previous notice by the shipper or transporter of




most hazardous chemical movements.

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               No highways or railroad  lines  are




exempted from their transport except for very highly




explosive types of loads.  Each transport vehicle




carrying toxic materials  supposedly must contain




a manifest description of the materials being moved,




and display an obvious placard describing what  to  do




in case of an emergency.




               But no routine inspection nor  emphasis




is placed on this matter, and as a result practically




no effort in this area is attempted.  Even more im-




portant from a groundwater pollution prevention stand-




point, groundwater protection is not specifically  men-




tioned or covered in any  laws governing hazardous




chemical transport anywhere in the United States.




               The economics part of it, at the




present time a true definition of the actual  costs




of pollution does not appear to have ever been made.




This is particularly needed, especially an exact




appraisal of the costs of adverse effects to  public




health created by current hazardous waste disposal



practices, and the true treatment costs of water



so contaminated to other downstream users.




               These answers are needed now so that




the initial sales price of every pollutant can be

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made to include the total costs  of  all  required.




control measures.




               Only in this way  can  the  people  who




make, distribute, and use a pollutant be properly




assessed for the beneficial values  they  receive




from Its use.




               In the technical  areas a  new  approach




seems to be especially needed.   For  example,  a  large




number of recent and current research projects  costing




millions of dollars and many man years  of effort  are




involved with such minor pollutants  as  hydrocarbons,




nitrates and chlorides.  It is recognized that  these




can and do cause objectionable pollution of  areally




limited portions of shallow aquifers in  the  vicinity




of surficial point source of accumulation.



               However, with the possible exception




of high nitrate water an,d its proven harmful  effects




to pregnant women and newborn infants,  these  types




of materials- generally are not extremely hazardous




to public health because in concentrations high




enough to be toxic s-ach ingredients  make the  water




nonpatable from, a smell or taste standpoint.




               To illustrate this point,  much of




the research associated with farm related pollutants

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 is  devoted  to  nitrate  pollution from septic tank




 and  animal  waste  sources.   Only slight  attention




 is  now being given  to  the  really harmful  wastes




 generated on the  farm  from highly toxic  metals,




 chlorinated hydrocarbon  or organic  pesticides,




 herbicides  and  fungicides.




                Available manpower and  resource




 funds never prove to be  enough  to do everything that




 everyone from  every field  of  specialty wants or




 needs done.




                For  this  reason,  it  seem  imperative to




 utilize the limited facilities  available  for hazardous




waste management  on a  priority  basis.  From a harm




 to public health  standpoint,  it  follows  that major




 emphasis should first  be placed  on  the abatement




 and control of  the  more  hazardous wastes  instead




 of devoting most  of the  available resources to




work on those  less  harmful pollutants  such  as




 nitrate find hydrocarbons.




                In this regard,  a  true  appraisal  of




 adverse effects to  the soil and  groundwater resources




resulting from past, present  and  possible future




land disposal of hazardous waste  has not been made




anywhere.

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               Sufficient data required to make a




meaningful evaluation of these effects are not




available, and are not being gathered at the present




time.  A few isolated occurrences of serious soil




and groundwater contamination have been recorded.




A few small number more are under study at the




present time.




               Yet, many hundreds of thousands of




land disposal sites known to have received all types




of hazardous waste in the past remain unmonitored




with little if any plans being  considered for their




investigation in the future.




          MR. LEHMAN:  Excuse me Mr. Walker, we're




running a little short on time, so could you shorten




it.




          MR. WALKER:  Monitoring procedures need




to be changed, vie are thinking, definitely that this



has to have a different perspective on it.  With




all of these dissipation regimes monitored we think




that we should control the  number of monitored




facilities and the depths of them, because this




seems to be an expenditure  of additional fund's,




not needed to solve the problem, and since the




proper motive is oriented here, we need to have

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much more attention given to these  low  level




pollutants that there is not much profit  in, but




that will eventually live to haunt  us,  and  most




of all we think that we need some regional  types




of waste treatment centers that  are established




on the basis of commercial need  instead  of  pollutant




boundaries.




               However, before such a  scheme can




be made viable, effective laws will have  to be




passed and implemented to accomplish two  prerequisite




goals.




               First, the law must  insure that only




one center will be permitted to  operate  in  any of




the established regions, and that this  center must




be set up to handle all wastes,  not just  the commercially




valuable ones.




               Second of all, the law must  insist




that all waste producers use the center.  Only in




this way can optimized process activities be assured.




               Also, if every waste producer uses




the facility and pays a true price  for  disposal




of all the waste he generates, this in  turn will




cause him to cut down the volume of his wastes,




which is a primary part of the dynamics of  the system.

-------
               We know that  you will  have  this

stuff now, and we want you to  consider  the fact that

groundwater should bear  its  full  share  of  the load,

but don't make it bear it all.

               Thank you.

          MR. LEHMAN:  Thank you  very much Mr. Walker

Are there any questions?  Mr.  Kovalick,  you have a

question?

          MR. KOVAUCK:  Mr. Walker,  one detail,

specific on the comment  you  just  made,  you suggested

that future laws might cause the  treatment center

to be set up in certain  regions and that there be

only one in that region.  This seems  to imply some

kind of a -- what I would call a  franchise system

or some kind of setting  aside  of  certain areas, is

that what you are advocating?

               Are you advocating that  for the

public or private sector or  both?

          MR. WALKER:  I'm advocating this be

privately run but controlled  as government: agencies

control other types of operations  in  this  business.

               But nevertheless,  it should be

protected enough so that the person running it

at least could make a living out  of it,  and not

                         t
                            r •  r

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have a whole bunch of little ones, just taking the




cream of the crop and making money off it, and




leaving these low levels which waste could be




far more harmful.




          MR. KOVAL1CK:  And my second question




has to do with your initial comments about the




guidance.  The need for communication there.  We




like to think that we are sometimes -- perhaps you




could suggest some vehicles that we are not using




to communicate some of the technology assessment




work that you do,




          MR. WALKER:  Sometimes I think the governor




should be taken off the vehicle that you have.  Because




some of these areas we are working on we don't have




the background data that you could take and run with




to get the answers.




               But you are going this way, as rapidly




as time and money will permit.  I wish there was




some vehicle wherein you could do more to get the




prerequisites or the data that you need to write




your regulations sooner.  If this could be done,




and write guidelines for us to follow so that




below this level we couldn't consider and above




this level would be foolish to consider, and give

-------
everybody a definition or broad  guideline  within




which to work.




               This I think would be better  to




correct pollution quickly, than  anything else.



          MR. K.OVALICK:  Thank you.




          MR. LEHMAN:  Do you have  any  other  ques-




tions of Mr, Walker?




          MR. LINOSEY:  You have discussed the




needs for regulations and do you have  some thoughts




on how this might be accomplished either by  the




state or EPA, and could you comment how you  see




such regulations taking  effect for  instance  should




we specify such things how our landfill should be




constructed, or should we impose limits for  dis-



charge of chemicals to groundwater, or  how would




this take place as you see it?




          MR. WALKER:  It keeps  going back to the




research needs and everything.   And one of the




things is that the liners we are now trying  to



pu t into  landfills for example, they keep  saying"




put the liner in that's impermeable, if we find




some of these impermeable "liners"  are  not good




any more, we find under certain  adverse conditions




they break down which is even more  hazardous  and







                          5*2

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we find that some of the people making  supposedly




impermeable plastic or rubber  liners will  only




make it for one chemical that  it can be  designed




for .




               But if you fill and throw  all  kinds




of chemicals into that they cannot assure  you that




it will hold up on a long term basis, so  yes, we




may be -- maybe we want to mention that  kind  of




hearing in your approach to it and doing  research




on that,




               So the people that actually design




these things will know which materials  are good to




use and which ones aren't.   Which system  is  good




to think about and which one is not.




               But I don't think that you  could




lay out an ABC guideline at your level.   I don't




believe in my mind that this would be right to do.




Because the states have their own hydrologic  fuel




and chemical needs, and everything else that  might




vary from place to place.




          MR.  LEHMAN:  There's another question.




          MR.  KOVALICK:  Question from the floor




Mr. Walker.




               Could you comment on the  f

-------
department of transportation becoming  involved




in regulating intra, that's within the  state




as well as interstate traffic of hazardous




wastes?




          MR. WALKER:  Here again I don't envision




their coming in with laws but at least  they have




to have guidelines out for the states  to follow




that will  be  consistent with their Federal guide-




lines.




               It seems to me, and in  this area,




I think this is   very important, from  our standpoint,




because some of these hazardous spills  once they




get into groundwater take years to clear up.




               One I know about 25,000  gallons of




cyanide took about 3 years to clean up  and it cost



a million and a half dollars before they could




finally get 25,000 gallons of cyanide  isolated




from the environment.  And that was due to a




train wreck.  And this kind of thing is a problem




everywhere.  So people hauling need guidance in




this area.




               Or some regulations, at  least, to




follow.

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Geraghty & Miller, Inc.
1101 EAST UNIVERSITY AVENUE
URBANA, ILLINOIS 61801

  Telephone
    Office 217384-0385
    Home 217367-7290
CONSULTING GROUND-WATER HYDROLOGISTS AND GEOLOGISTS
                                                        Port Washington, New York —Tampa, Florida


                                                     December 9,  1975
  Mr. John P. Lehman, Director
  Hazardous Waste Management Division
  Solid Waste Management Programs (AW-565)
  Environmental Protection Agency
  Washington, DC   20460

  Dear Jack:

            We appreciated the opportunity to testify at the Chicago  Public
  hearing meeting and trust that our remarks were in order and  received  in
  the constructive way we intended them.

            One question was submitted from the floor too late  after  my  ad-
  dress for answer during the allotted time.  For this reason,  the  question
  and the response I would have made are 'given below for inclusion  in the
  official transcript of the meeting.

            QUESTION:  Please expand on the regional waste treatment  centers.
  Will they involve incineration, well injections, landfilling, etc.?

            ANSWER:  It is imperative that all of the centers be equipped to
  handle a_ll_ wastes, in any form, and in any concentration level of receipt,
  whether it be liquid, sludge or solid.  All combustionable wastes received
  would be disposed of in the centers' properly designed and operated inciner-
  ators; particulate and gasious substance emmissions from the  incinerator
  stacks would be appropriately scrubbed to minimize air pollution  and the ash
  residues finally treated for disposal in some other environmentally safe
  treatment-disposal component of the center.  These would include  facilities
  for hazardous-waste chemical reconstitution, impermeable polymer  encapsula-
  tion, separation-recycling, and land disposal.  It is envisioned  that  all
  of the liquid waste streams entering the centers would be finally treated
  to a harmless state totally acceptable for reuse or discharge to  adjacent
  lands or water courses, and that solid waste disposal sites would be sealed
  from the environment with appropriate impermeable liners.

            Deep mine storage of mineral rich solid or containerized  liquid
  hazardous waste material for later profitable recovery could  be a viable
  waste-processing component of those centers located adjacent  to such under-
  ground facilities.  Also, where geohydrologic conditions permit,  properly
  sealed conduit wells tapping deeply buried brine aquifers naturally isolated
  from all regional fresh-water zones could be used for storage-retrieval of
  liquid wastes rich in valuable dissolved minerals.  In this regard, disposal
                                        5-5

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Geraghty & Miller, Inc.
       Mr. John P. Lehman, Director
       December 9, 1975
       into deeply buried mines and brine aquifers should be permitted as an ac-
       ceptable "treatment" method only until actual effective treatment technol-
       ogy and equipment has been developed.  Under no conditions should deep
       burial disposal .ever be considered as an optimum permanent treatment method.

                 I trust that this long-winded answer will contain enough informa-
       tion of what I should have said that your people can condense it to some
       intelligent short statement.

                 If we can be of further assistance in this matter, please do not
       hesitate to call on us.

                                                    Sincerely,

                                                    GERAGHTY & MILLER, INC.
                                                    William H. Walker

       WHW:tt
                                       5GS

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          MR. LEHMAN:  Thank you Mr. Walker.  Are

there any other questions?


               Okay, that's apparently it, thank


you very much sir.


               Next I'd like to call upon Mr.


Bernard Reese.  Is Mr. Reese here?


               Well, let's go back and see if


an earlier speaker has arrived, Mr. John Baker


or Mr. David Fenton from the Indiana Board of


Health.


               Mr. Baker or Mr. Fenton.  Then


let's move on then please, I'd like to call on


Mr. Dennis Johnson of the Illinois EPA, Mr. Dennis


Johnson.


               Perhaps he has not arrived.


               I'd like then to call upon --


correction, Dr.  Patrick Phillips, of the Missouri


Department of Health.  Dr. Phillips.


          DR. PATRICK PHILLIPS:  Yes.


          MR. LEHMAN:  Dr. Phillips, would you


please tell us whether you'll accept questions?


          DR. PHILLIPS:  Yes.


               First of all let me preface what I


hope to convey to you with my remarks today.


               I am not an expert at least not in
                          5I---T
                          U I

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hazardous waste.



          MR. LEHMAN:  Dr. Phillips, could you please



get a little closer to the mike.



          DR. PHILLIPS:  Surely.  I am not a chemist



and I am not an engineer.  I am a public health



veternarian.  And I like to think that my expertise



is in epidemiology.  I'd like to relate my personal



experience.



               We had in Missouri an experience that



dealt with the very toxic chemical by the name of



dioxin.  In May and June of 1971 the material was



applied to the soil and almost immediately animal



life became sick and started dying.



               Within two months humans were affected



and at least in one instance severely -- almost



fatally.



               Now we investigated this with the



help of the Center for Disease Control, a  Federal



agency, we tracked back to where the waste originated,




and found that the company that was responsible for



the generation of the waste had since gone out of



business and there remained approximately 4600 gallons



of this chemical waste that had a concentration of




dioxin between 300 and 350 parts per million.





                         sue

-------
               Mow in itself that does not sound




like much.  But taken in the light that this chemical



is extremely concentrated, it is a lot.



               For example, dioxin is lethal, in



concentrations of 10 to 50 parts per billion.  We



estimate that we have enough waste that if we can



divide it equally we should theoretically be able



to kill over 500,000 people.



               Now, once we have identified the



waste and the storage and the quantity we start



looking for ways to dispose of it.  It is a very



frustrating thing because there were no guidelines,



no regulations, no statutes, ordinances, laws, or



anything of this nature that we could use.  Now,



I am not talking about using the law or the statute



to beat over a company's head.



               The company that now has the waste



is as interested afi we are in disposing of it.  We



don't know how.  There are three main ways of



degrading dioxin.  And one is incineration, the



second is a process called  chloronalysis,   and



the third is a process by which the dioxin is



exposed to ultraviolet radiation, and of the three




avenues of disposal there is only one in this
                          $09

-------
country and that is available to us, and that is



incineration.



               We have approached five separate



companies in the United States and one of them was



in western Europe, the first five that we contacted



we were turned down.



               The sixth that we are trying to work



with now is asking in the neighborhood of a quarter



of a million dollars for the disposal of this waste.



               The suggestions that I have that I



hope will be taken in the correct light is not that



this is the way it should be done.  I feel that



there are two areas of concern, at least two areas



of concern, that if we are going to set up guidelines



and regulations, that we must include in the process



and one is human health, and the second is environ-



mental health.



               Now what I would suggest is that



the ultimate responsiblity of the safe disposal



of hazardous wastes rests with the originator.



               I envision this in this manner



because I feel the person who is concerned who



generates waste has the best chance of knowing




-- knowing what it is, and what quantity and
                    $10

-------
also the best way to get rid of it.




               I feel that the concern of the people




as shown by public meetings such as  these have to




be taken into account to see where priorities are




set.




               What is most important.  The originating




company concerned or the person I feel should draw up




requirements for disposal, find a service outlet,




that will do what he asks, enter into contracts,  and




have the job done.




               Before this would actually be carried




out, I propose that the plan of disposing be reviewed



by some type of regulatory agency, or commission




that would involve at least three members.




               One being public health,  the second



being public safety, and transportation, and the




third being environmental health.




               Those are only suggestions.  Those




are the best we have been able to come up with at




the moment, and in the meanwhile we  still have 4600




gallons of waste.




          MR. LEHMAN:  Thank you Dr.  Phillips.




               Any questions?




          MR. LINDSEY:  You run up against the
                      fill

-------
problem which we've heard about from other people,



in that the problem of not being able to dispose of



something because you can't find the facility that



will handle it, and in the case of dioxin I guess



it's because of the extremely toxic nature of it.



That nobody wants to be responsible.



               Given that then, how should we or



I am speaking now of generalities as a government



agency, state, Federal  or whoever, how should we or



can we insure that the facilities for disposal are



available?



               How should we promote this, this



sort of thing?  We generally have a lack of facilities



I gather from the speakers that we have heard before



you.  But what can we do to help them insure chat



adequate facilities are -- can become available?



          DR. PHILLIPS:  Well, the first thing that



frustrated me was not the fact that facilities were



not available, they are available.  One of them being



in western Europe.  But none in the United States.



               It took a long time or at least I



felt it was a long time to identify these facilities,



if for nothing else but as a clearing house for




consultants.








                  '   612

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               I would like to see the Federal



government act on this for the whole nation.



It can be a repository of consultants, expert



consultants, that would help with concerns of the



state government, will decide what is the best way



to dispose of certain hazardous wastes, and not



only that but it would have the information of



where it would go to find the facilities.



          MR. NEWTON:  A questioner on the floor



asks in which pesticide was dioxin found?



          DR. PHILLIPS:  Well, dioxin is a by-product



of the production of trichlorophenol.  Trichlorophenol



is a versatile compound-  From it can be produced tri-



cholorophenoxide acid, probably better known as



2,4,5THR, Also produced from trichlorophenol is hexa-



chlorophene, the tritetrapentachlorophenol groups



which are used a lot in wood preservatives-  The



company that was responsible for the generation of



this concentrated substance was making hexachlorophene,



 not  2,4,5THR .




          MR. LINDSEY:  I have another question.



               Question from the floor as a matter



of fact,  two questions here, I'll ask them one at




a t ime.

-------
               Has the incinerator ship Vulcanus




been considered?




          DR. PHILLIPS:   Yes, I spoke to their




agent in the United States and he said that they




would be interested in at least exploring the




possibility of being of service to us.  They




asked for a sample to determine the chlorine




content of the waste, so they would know how much




diesel would have to be burned to keep it at a




required temperature for destruction, and we sent




a sample to the Amsterdam laboratory personnel




and they came to pick it up and they saw dioxin




written on the outside and refused it.




               The official reply was that it was



and I quote "too toxic".




          MR. LINDSEY:  One more.  In your opinion




should Federal funds become available to assist




states in disposal of extremely toxic wastes?




               Should Federal funds be made available




to assist states in handling these wastes?




          DR. PHILLIPS:  You're asking me something




I'm not sure  would solve the problem.   It would




definitely help if we had more money, if we had




a quarter of a million dollars.

-------
                              (Laughter.)




               I am not sure that more money is




going to take care of the problem.  As others




before me have mentioned, we need to know more




about what we are dealing with.   We would be happy




if there were more facilities qualified to deal




with these wastes.




               I don't know.  I don't know if we




can solve the problem or not.




               I think we can help.




          MR. LAZAR:  I have a question from the




floor Dr. Phillips.




               Weren't P.C.B.'s also found in this




incident?




          DR. PHILLIPS:  Yes.  On analysis of the



soil from the first arena which was the only arena




we knew about for three years, until we found out we




were dealing with dioxin, that we started to at



least have a lead on where the investigation should




be.




               After this we found two other arenas




and the farm that had also been  exposed.   P.C.B.'s




were also found in rather high levels.   We think




they were present because of the nature of the
                      615

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waste oil distributing company.  This man had been




in business for 20 years and is still in business,




and his father had the business before him for




I don't know how long, and their main service was




going around to the gasoline service stations in




town and picking up wastes of crank case and motor




oil that they would sell most of it to a chemical




refining plant -- well, not a chemical refining




plant but an oil refining plant for re-refining.




               This sludge had settled out of this




oil while it was being held  and was what  was used to




oil the arenas.




               This man also picks up chemical wastes



and sells most to a chemical refinery  for refining



processing and purifying for reuse, and the sludge




from this is mixed with the sludge from the oil




and applied it to the arenas.




          MR. KOVALICK:  From the floor,  is dioxin




still produced as a by-product by any other




chemical and if so how are they disposing of the




wastes to your knowledge?  If you know.




          DR. PHILLIPS:  To my knowledge I don't




know.  Trichlorophenol is very common in the




industry as I understand it, and depending on the
                       61S

-------
process that is used to form and used to produce




trichlorophenol dtoxin will also be formed.




Probably one 'that is the most hazardous as far




as dioxin production is concerned involves alkaline




conditions at moderately high temperatures at




high pressures.




               And if there are other companies




having a problem with dioxin I wish them luck.  I




also wish people in the environment in the surrounding




area I wish them luck also, because they are probably




having as much trouble as we are getting rid of the




mess.




               It just does not go away.  It does




not degrade on its own.  It has a half life of at



least 18 months in the soil, it is a very heavy




tarry substance, it does not leach or move into




the soil very readily, it just stays there.




               If it is protected from the sunlight




it does not break down very readily, it is relatively




inert as far as treatment by acids or bases -- it




is extremely lethal in strong  dosaq^.




               I don't know of any other companies




but I would not be surprised to find that there




were some.

-------
          MR. NEWTON:  I have a question from the


floor Dr. Phillips.



               What would you suggest then  for the


company which does not have the financial resources



for disposal of this material given the high cost



of such disposal?


          DR. PHILLIPS:  Whoever asked that question


is very perceptive.  They have caught me right where



I hurt.
                             I

               Because the company


     that I am dealing with  is not that big a company.


And a quarter of a million dollars would probably


sink them.


               Even before the economic conditions


of today.  I don't know what to tell you.  I have


absolutely no opinion.  I have no idea.  Maybe it's


good that we don't have laws that say you've got


to get rid of the stuff, because it would certainly



drive people out of business.



               ^ou've got me on the horns of a


dilemma,  i want to get rid of it and I want to get



rid of it safely, but do I have the right to force



a company into bankruptcy?  This is what I am



talking about setting priorities.
                        &1S

-------
               What  is  more  important?  I just




can't answer your  question wherever  you are.




          MR. LEHMAN:   We  have  one last question




Mr. Lazar?




          MR. LAZAR:  Yes, somebody  asked from




the floor, if the  most  --  'did   the  most severely




affected child survive  the incident?




          DR. PHILLIPS:  Yes.   The child survived




the incident as  far  as  we  could tell  there was no




permanent damage.  It was  bad that the child  had a




hemorrhagic cystitis.  Alone;  with  the other signs_of_




migraine headache, she came down with cramps,  she




was placed on an artificial  kidney machine for




something like 2 weeks,  and  her condition was




severe enough where  they had her  in  intensive  care




for something like 6 weeks.




               Her exposure  was that  she played




in the arena and at  this tine she  was six years




old.  It was like  a  sand box.   Her mother was




a stable manager and a  very  fastidious woman  and




extremely intelligent also.




               And the  child probably bathed




every night if not twice a day,  so the stuff,




the material the agent was removed fairly rapidly







                        $13

-------
but it still almost did the child in.




          MR. LEHMAN:  Thank you very much Dr.




Phillips.




               I'd like to call on Bernard Reese,




at this time.  And just to alert the next speaker,




I'd like to call on Dennis Johnson.




               Mr. Reese, will you accept questions




after your statement?




          MR. REESE:  If I cannot answer the ones




I choose not to.




          MR. LEHMAN:  Surely.




          MR. BERNARD REESE:  I appreciate an opportunity




of being here, and my purpose for being here gentlemen




is simply to document a situation that has developed



in our community, of a family that had been the re-




cipients of some contamination, so that the idea of




environmental protection and that sort of thing isn't




just a word, but a necessary part of our society




today.




          MR. LEHMAN:  Mr. Reese.  Could you please




identify your affiliation.




          MR. REESE:  Yes, my name is Bernard Reese




and I am an attorney admitted to practice law in




the State of Illinois.
                           520

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               When I  first became  involved with




this the word environmental protection was simply




a word.  And I read about it  in the newspapers.




               But I had a farm client come into




the office                about October of 1972




and they had an apparent water problem, and she




said there was a  strong odor  of metal or some




odor coming from  a well that  they were using, and




the land owner adjoining their property was using




the land as -- a  portion of the land as a limestone




pit and then a strip of land  adjoining it as a




dumping area for  chemical barrels.




               That over this period of 1972, 1973




there were several hundred barrels of chemicals




that were dumped  on the land.  And the dumping




procedure had apparently taken place for a number



of years prior to that, but the odor in the water




   became apparent in the summer or late fall of "72.




               Preliminary investigation disclosed




that the barrel contained a chemical waste material




from a local paint manufacturer who we believe was




disposing of them in this manner.




               Further investigation substantiated




this fact,  and  litigation was commenced in the

-------
County of Winnebago. The dumping after the litigation




started primarily stopped and over a period of  '73




the majority of barrels that were on the adjoining




property were removed.




               Although up until let's say 60 or 90




days ago there were still barrels on the adjoining




land.




               These barrels, many of them were




split and the contents were leaking out and you




could smell -- as you walked in the area you could




smell the chemical odor.




               The client discontinued his use of




the well for drinking purposes and cooking purposes,




when the odor began to become too strong, and  then



we began to get involved in it.   To somebody who's




unsophisticated in the area of technological in-




formation, in terms of water, usually you drink it




but you know maybe you ought towatch out for bacteria.




               But when you begin to try to discover




what the problem with the water is, I discovered




that it was not a simple task.




               Testing of the water was quite difficult,




To find appropriate facilities where you could get the




kind of testing you needed.
                       522

-------
               And testing on the water  still




continues, but it appears pretty conclusive that




the water is chemically contaminated and contains




phenols, mercury, lead, zinc and other hazardous




and harmful chemicals.




               A new well was sunk to a  depth of




320 feet in an effort to avoid the contamination




and it was taken down below St. Peter's  limestone.




We thought and on the information we had at that




time, it was felt that would avoid the continued




contamination of the water supply.




               This conclusion based upon testing




of the new well now appears to be erroneous.




               It appears that we were wrong in




thinking we could get away from the leaking.




               The substrata is limestone and



apparently is a ready conductor and channel for




what we believe is the course of the chemicals




being dumped or having been dumped on the adjoining




property.




               The individuals, the client has




since — since the fall of "72 been forced to




transport in water for drinking purposes and




for cooking, and because of the inability to

-------
locate a satisfactory place to dig a well, has




had to dispose of the place and prepare to move.




               The medical condition of the family




is such that each member of the family has experienced




some sort of traumatic episode, of one kind or another.




               To some members of the family it has




been more acute than to others.  When you begin to




you know, somebody has a headache or swelling in




the throat or something, that's not apparent readily,




well the layman doesn't say this would be associated




with the water you are using.




               And if it had not been for the odor




that the water began to develop the contamination




of the well probably would never have been determined.




               It is believed or we believe there's




a causal connection between the chemicals that




were dumped on the adjoining property, the contami-




nation of the well and the physical condition that




many of the members of the family now demonstrate.




               I have a couple of suggestions --




as 1 have looked at the problem it has been my




observation that most industry is really trying to




make a legitimate effort to solve the problem of




waste disposal.

-------
               I think -- there are a couple of




things I had in mind.  If anybody who is disposing




of contaminant waste either a generator or whatever,




was required to register with the -- let's say the




county clerk's office, advise the county clerk at




the county in which he is operating, where he is




disposing of his waste and how, and after that




registration that either the state or the Federal




EPA would send him information on where that waste




would be disposed of, and the economics of so disposing




of it, the hazards of that particular waste, if it




was disposed of improperly, methods that  he shouldn't




abuse and perhaps the civil and legal consequences




can be handled or brought into play due to the im-




proper disposal of that waste.




               I also wish to say that I represent




the Rockford police Department and it's been my




discovery that law enforcement agencies of every




kind are underpaid.




               I don't think we pay our policemen




hardly enough money.   They are always fighting




for more money.  In terms of this particular situa-




tion the average guy who -- let's say he's on a




farm or has to do with the use of water or whatever,
                       5*5

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in this particular situation if it wasn't for the




division of land pollution control and the ability




to utilize some of the information that they are




capable of developing through their researching




and testing and enforcement field, the little fellow




who does not have the funds to develop the kind of




sophisticated testing that's necessary and to make




the kind of proof that's necessary in a court of




law, in a law enforcement situation, if it weren't




for the information that the police oftentimes




furnish a citizen's rights would not be protected.




               If it weren't for the information



and the type of assistance that the division of



land pollution control could furnish a citizen,




   the rights of an individual simply would not be




protected.




               And it is not just a question of




spending money but it's a question of having an




agency which really is a law enforcement agency




to protect the individual from attack in a much




more subtle way but just as dangerous and just




as detrimental as an assault on the street.




          MR. LEHMAN:  Thank you Mr. Reese.




               We have some questions.  Yes, Mr. Lazar,
                       526

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          MR. LAZAR:  Mr. Reese,  I  have  two  questions.




Could you tell us  something,  how  far  is  the  well  from




the disposal area  approximately and  also has any




other well in that general  area been  affected.




               That's my first question.




          MR. REESE:  There  are two  areas that  were




being used for dumping on the adjoining  property,




one which was a land strip  and which  is  about 3/4




of a mile from the well, and  the  other was in a lime-




stone pit, across  the -- in  sort  of  a northwesterly




direction, probably another  half  mile from the  strip




dumping area.




               The evidence  that  has been developed




and I think maybe  Mr. Johnson follows me,  and he




may have better information  on that,  if  he wants




to .disclose   it,  it appears  to me that  there was




another well in the south or  easterly direction that




was affected and there may be others  in  the  area




that have not as yet been documented, but  the lime-




stone -- the geological information  indicates that




the limestone falls in a southeasterly direction




from the dumping area down across the area where




the well was located and in  a --  running  in  a




southeasterly direction.

-------
               So that there is at least one  other




well that was contaminated, but to what extent  I




don't really know at the moment.




          MR. LAZAR:  My second question sir, is




can you be more specific about the physical condition




of the most severely affected member of the family?




               What are the symptoms or were  the




symptoms and generally what sort of hardships did




the family encounter as a result of this?




          MR. REESE:  I've got detailed notes in my




file, but I can say this.  That the one youngster




age 14 experienced significant amounts of time  away



from school.  Missed a lot of school.  As a matter




of fact he had headaches, and apparently water  behind



the ears, an electroencephalograph test indicated




abnormalities, and some unsteadiness, in walk.




               Difficulty on occasion in speech, and




the other members -- the mother had swelling  of the




neck, and swelling of the lips.  Each member  of the




family had, you know, different demonstrations  of




something physical.  Of one sort or another.  The




oldest daughter, she seemed to be the least affected




at all.  She was not substantially affected other




than perhaps headaches.
                     &4G

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               And  it wasn't until we began  to




look at information out of Japan that -- you  know




you -- we began to realize that maybe some of the




problems that they were having were  associated




with water .




               And the other thing that you  discover




is that for example, a case down in  Texas where there




was mercury poisoning in which the mercury was con-




centrated in hogs that were fed -- oftentimes the




level of chemical in the water is not always  in-




dicative of the effect that it can have on someone




who might be using it.  Particularly on a farm,




where they might have cattle that are drinking that




water, and the chemical will get down and get con-




centrated in the animal and be produced in the




milk which the family uses, and could have a




detrimental effect in that fashion.




          MR. LEHMAN:  I have another question.




Mr. Kovalick please.




          MR. KOVALICK:  I think these are four




clarifying questions from the floor.




               Was the case referred to the Illinois




EPA?




          MR. REESE:  I know the Illinois EPA

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apparently did some investigation and I have --




this is another point.  I'm kind of a country




lawyer here, and I just don't oftentimes just know




where to start.  If you begin looking at -- and




the client doesn't know where to start, you begin




talking and you find that nobody knows really where




to start.




               Finally in April of  '73 in an effort




to -- well, the University of Wisconsin is trying




to get an evaluation.  We called the local EPA office




in Chicago and talked to a gentleman there, and at




that time they didn't have a procedure for helping




or at least this gentleman told me they didn't for



helping diagnose water for heavy metals.




               And that again is a reason for having



that division, like the division of land pollution



control.  That at least offers some control and gets




some helpful information there.




               So it was hard to discover and I am




informed and believe that the EPA did have this




particular property under surveilance and for a




period of time and over the past number of years,




apparently there had been a complaint and there




had been efforts to stop the dumping.
                           530

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          MR.  KOVALICK:   I  think for  clarity the




division  of  land  pollution  control  is a division




of  the  Illinois EPA.




          MR.  REESE:   I  believe  it  is.




          MR.  KOVALICK:   So I  believe it  was several




offices that were involved  there.




               Now,  I  have  three other  questions.




Was the water  sample  sent to the Illinois Department




of Public Health? For testing?   Or the EPA or  either?




          MR.  REESE:  The water  was sent  to the




Department of  Health  and  I  always thought,  you  know,




you could take water  down to your local chemist and




find out what water was  and  I  discovered  it was not




quite that simple.




               The report we got back from  the  Depart-



ment of Health was based  on  bacteria,  nitrates, iron




that sort of thing.  But they  really  didn't  disclose




   any relevant information  as far as heavy metals.




You have to follow a totally different  approach




procedure for that.




               And you discover  further that  unless




the lab is sophisticated enough  to have let's say




computerized controls in developing that  chemical




content, when you get down below certain  levels you

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don't get the proper information.




          MR. KOVALICK:  Yes, thank you, and lastly




was the dumping site an EPA permitted facility and




would you care to najne the dumping site?




          MR. REESE:  Well, the dumping site




so far as I know was not an EPA authorized facility,




and the dumping site was land adjoining the client's



property owned by Mr. Tipton.




          MR. LINDSEY:  Mr. Reese, I have one more




from the floor here.  You have made the assumption




that the waste drums caused the water contamination.




Have you been able to prove the connection by




testing whether the same chemicals exist in the




waste as you found in the water?



          MR. REESE:  That presents an interesting



evidentiary question.




               We think we've been able to reach



that conclusion.




          MR. LEHMAN:  Well, I want to thank you




Mr. Reese.  I believe that's all the questions.




               I would next like to call on Mr.




Dennis Johnson of the Illinois EPA.  And while




he is coming up to the microphone, Mr. Wasneck




has a message here at the front table.
                        533

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               We have had  one  question  addressed




to the EPA panel, and I just wanted  to clarify




that the purpose of these meetings is not  for us




to expound on EPA policy, but it is your opinions which we want




to elicit.




               So, if you will  please address your




questions to the speakers,  'rather than to the oanel directly



and if you do have questions that come to  you as a




result of these meetings, we'd  be happy  to answer




them.




               And now Mr.  Johnson please.




          MR. DENNIS JOHNSON:   I'll  introduce myself,




I am Dennis Johnson, Regional Supervisor for the




Illinois EPA Division of Land Pollution  Control.




               My responsibility and also  my purpose




and intent for being at this meeting, is to clarify a




new approach to hazardous waste control  that I think




should be clarified prior to some adoptions of




proposed regulations for hazardous wastes  generated




and those hopeful to adopt  regulations that are




pending adoption by the pollution control  board.




               Let me get back  to some of  these




functions to the pollution  land control  as  far as




the state is concerned.
                    * §s:

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               My responsibility and my eight




staff members under me, we all respond to  the




environmental protection act under the legal




auspices of that act, and develop and build




around pollution -- as far as ,land pollution




control is concerned.




               We build it around solid waste




disposal.  Now this means solid waste disposal




usually on the landscape basis, and that's what




my division is all about.  So when you talk about




landscape, you talk about some very severe  limitations




from the standpoint of engineering technicalities,




geological considerations, and I'm not going to




get too much into this, unless I have questions




from the floor.



               John Clark, I saw him there  in the



audience, did make reference to some of the




functions of the divisional aspect of pollution




control, as far as landfills and  surveillance and




enforcement of the permits required for sanitary




landfill.




               But just to kind of give you an




overview very quickly, the solid waste permit




descriptions that govern every landfill become

-------
that landfill operations bible, it is also the




bible by which  surveillance and enforcement from my




office is governed too.




               The best sanitary landfill as far




as the landscape position is concerned would be




one that rests primarily and hopefully in a strong




clay geology.  It would be a landfill that would be




protective to the environment because it does not




sit on top of limestone or sandstone geological




formations.




               The worst landfill of course, I think,




is easily recognized that if you were to have surface




or subsurface within minimal numbers of feet, 20 or




less, dolomite limestone formations and if you were




to deposit any type of refuse on that surface the




percolation of rainfall through it would tend to




leach out whatever chemical compound that refuse




would have.




               That means that the lateral or




horizontal substratum movement of potential




chemically hazardous ions could move in that land-




-- that limestone and geology formation.




               And the possibility of groundwater




or the water table being affected by chemical ion
                        535

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contaminants would be a realistic problem.  And



again that's what the Division of Land Pollution



Control is all about.



               To prevent substrata, groundwater



contamination of any type,              whether it



be biological or hazardous.  So to prevent illegal



landfills from operating or to prevent existing



landfills that are created by the Illinois EPA



from taking hazardous materials when their permit



descriptions and geological engineering descriptions



don't warrant that they take it, we on an  enforcement



surveillance control basis prevent them from taking



any materials that could potentially get in the



groundwater  aquifers.



               The permit section of the division



of land pollution control does a real bang up job



to say the least of course, I'm prejudiced.



               But they do a fantastic job on



permitting and enforcement and pre-permit engineering



review of potential landfill sites.



               There are some very good sanitary



landfills in northern Illinois, central Illinois and



southern Illinois.  So I'm not talking about my 22



county region at all.  I'm talking about the State








                    '*  536

-------
of  Illinois  as a division of land pollution.



               These excellent landfills are many




of  them permitted by our permitting offices down



in  Springfield.  They are capable of taking some of



the most hazardous materials regardless of where it



was generated.  Even low threshhold radioactive



waste in some certain specific landfill areas.



               Industry has particular problems, and



I recognize  this, because I see it and industry in



my  region represents a fantastic gross manufacturing



million dollar figure.



               It exceeds just Cook County, statistically



in  the encyclopedia reference if you care to get out



your kid's books, statistically exceeds the gross



billion dollar manufacturing estimate, just Cook County



of  16 states of the union combined.



               Now that's staggering.  And Cook County



alone exceeds the conbined efforts of about 32 or 33



states in the union, in its gross manufacturing total.



Now this is heavy industry.  This is tool and die,



metal fabrication,  metal plating and chemical.  The Chicago




Heights area exceeds Pittsburgh in steel production.



               So what statistics that I'm giving




you are realistic from the standpoint of potential







                     "  537

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environmental impact.  And that again is what the




divisional aspect of pollution control is all about.




               The landfill descriptions that I




was talking about, as far as accepting hazardous




wastes, would be the clay geology hydrostatically




sealed landfills.




               If you want to think of a clay open




pit as a gigantic bathtub capable of receiving and




holding deposition of every type of refuse material




hazardous included, imaginable as being deposited




in that type of open hole that is I'U say a sanitary




landfill.




               Provided the clay geology is measured




peripherally and on the bottom in feet and not in




inches.



               Enough of that, I'll have some



questions from the floor, and if you have any specific



questions   on landfill, but we do have a strong




responsibility from the standpoint of environmental




impact on surveillance of existing legally permitted




landfills and that they do take the right materials.




               If the landfill sits on top of sand




or gravel or is an old quarry, if they get a permit




at all then that permit is limited to general refuse






                          530

-------
and certainly nothing hazardous.




               There are some things that I'd like




to mention especially with regard to industry at




this public meeting, the Division of Land Pollution




Control is rather dynamic and again I'm prejudiced.




We are not a reactionary body especially in hazardous




control.  We are thinking in terms of preventative




medicine for environmental impact.



               We have in the past followed complaints,




hazardous type complaints on a one on one follow-up




basis-For example, if we get cyanide, plating waste,




heavy metal waste, on a complaint basis where it's




been generated by who knows who, but it's being hauled




and it's being placed in such a manner that the barrels




are leaking or the barrels will be dumped in a non-




permitted landfill area, we will lump with both feet




on that of course, and try to direct the hazardous




materials, whatever its generated source, to a safe



technically permitted landfill.




               I heard a comment as I walked in,




just a little bit ago, that where are these safe




permitted sites?  Is there an abundance of them




or is there a shortage of them?




               I would take little ground on that

-------
question.  I feel that the Cook County geology




which is the impetus of some fantastic generated




materials, the Cook County geology is truly _a God




send.




               There is an abundance of clay land-




fills that the Illinois EPA permits to the tune of




-- when I say abundance I mean approximately one




dozen, and to me that's an abundance, because that




is very favorable for one county.




               But the clay is here, and the clay




is of safe engineering researched -- previously




researched geological application to just about




every conceivable hazardous waste generated and to




be safely deposited.




               And that is truly fortunate for the




industrial giant Cook County, and we monitor these



landfills.




               And the operational assistance that




I'd  like to project to the industry, and I think




you'll get a greater feeling for the projection in




a minute when I tell you about some of the proposals




that are coming before the pollution control board.




               The operation assistance is open




door policy.  We across the state in all three regions

-------
have a compliance conference table  that we welcome




and solicit industrial or private or corporate




profiteering type management landfill facilities




-- 1 don't use  profiteering in the wrong way  --




to come across the compliance table with questions




and answers, and to work with us in a  one on one




approach, to solve a problem.




               Obviously the problem has to  be  legal




deposition.




               This operators assistance is  certainly




forthcoming and I hope any member of industry now




or in the future would ring my phone up or Springfield




up and start pushing along these lines.




               My point of making reference  to where




are the landfills, they are there.  I  think  it's one




of the hazardous things in industry and one  of the




big responsibilities and I feel that there is a good




integrity in industry already.  It's been proven to



me  that industry is having a problem  and it  should




contact the Illinois Division of Land Pollution Control



for  legally permitted and safe hazardous deposition sites.




               Now I'm not saying we won't ask you to




drive 50 miles, or 75 miles,  or 100 miles, we are




not God.  We cannot put clay landfills and call them

-------
100 per cent hazardous fills anywhere we want  to.




We're at the mercy of the geology, the  geology  of




northern Illinois, My region  is not truly  as




lucrative as -- speaking of 22 counties now  --  is




not truly as lucrative from the standpoint  of  safe




short distance traveling to a safe deposit  site.




               Cook County is fortunate but  the




rest of the counties are not.  For example,  the




Winnebago County area, which is the  area from which




Mr. Reese is in, and where his client is located,




and is having problems, that Winnebago  County  area




and the surrounding periphery, 7 or  8 counties,  is




a sand and gravel, glacial apex geological  point




from the standpoint of high amounts  and subsurface



or near or at surface deposits of dolomite  limestone.




               Well, that creates problems.  Because



limestone or sand, if you wait to go play  in your




kid's sandbox, you know what happens when  you  put




any kind of a liquid in sand, it goes right  to  the




bottom, if on the bottom of that limestone  or  sand




or gravel or whatever the porous geology is, happens




to be a natural or horizontal  aquifer,  you  can  put




two and two together I'm sure.




               The contaminants will travel  horizontally

-------
in the natural  aquifer.   And this  is  a concern




that we have as a responsibility  from  my  pollution




control standpoint.




               So again, industry may  not  like to




-- appreciate this standpoint of  economics  and




overhead, because I once myself was a  representative




of industry as a chemical engineer, I  can  see that




you have to consider the fact that  you have  hauling




expenses or you have to pay a hauler,per  capita  or




per dollar figure higher than  someone  else  in another




area, with closer landfill sites.




               However it's still called  one of  the




hazards of the business and environmental  protection,




and I know you realize that.




               Let me make a few  comments  on what




we're doing and if I have any questions on  the




past performance of the EPA or division of  land




pollution control, or the past illegal activities




which are there, I'll be glad to  answer the questions.




But as far as future and near future reference,  my




exposure and my staff exposure and the other regions'




exposure to industry, I think it will  be along these




guidelines.




               September 1975, House Bill  2101 was

-------
passed by the Illinois State Legislature, and




this brought           hazardous waste directly




to the responsibility and totally the respon-




sibility of the Division of Land Pollution Control.




               Now that amendment to the Environmental




protection Act defines hazardous wastes as any refuse,




with inherent properties which make such refuse




difficult or dangerous to manage, by normal means,




included but not llmitted to chemicals, explosives,




pathological wastes or wastes likely to cause fires.



               This addendum called House Bill  2101




to the Environmental protection Act has really




two responsible mandates, and I'll give you my




interpretations and the agency's interpretations




of those mandates.




               Legal responsibility is such now



with the passage of that bill that private industry




can no longer store or deposit generated hazardous




materials on private property.  Specifically that




private and/or industrial landfills from the past




now have to meet engineering and permit descriptions




of the Illinois EPA Division of Land Pollution




Control.




               There is an alternative to this,

-------
rather than go through the expense of considering




putting in your own backyard safe hazardous




landfill site, which you wouldn't be able to do




if you had clay anyway.




               All right, the alternative is that




said hazardous generated materials must be hauled




to a legal technical landfill site permitted for




safe hazardous deposition.  And these la ndfills




are available, and again, if there is a question




of driving and a hauling basis, or paying a hauler




to drive to one of these safe permitted landfills,




that certainly is a risk of the business, and a




consideration that industry is going to have to




make, for environmental protection.




          MR. LEHMAN:  Excuse me Mr. Johnson, we




are running a little short of time, if you could --



if you could finish up please.




          MR. JOHNSON:  Yes.   Co-responsibility




for safe hazardous deposition also falls  upon




the independent and corporate hauling companies.




And I think this is the proposed legislation




that will be needed.




               Final draft preparations for liquid




and hazardous waste hauling regulations have been

-------
finalized and will be presented to the Illinois




Pollution Control Board for recommended adoption




in early ' 76,




               These upcoming regulations prescribe




procedures to be followed in connection with the




issuance of permits to liquid and hazardous waste




haulers.  And provides for inspection and numbering




of vehicles and tanks.




               The adoption of these regulations




will constitute a three way responsibility.  That




three way responsibility is -- will exist between




the generator, hauler and the landfill operator.




               It will be based on bill of ladings




and record receipts and onhazardous materials trans-



fering from generator to hauler to landfill.




               The violations of these regulations



will constitute pollution control board actions,




and also revocation of said permit.




               That to me is a direct response to




House Bill 2101, it's also a direct response to




the agency the Division of Land pollution Control




specifically, to past hazardous complaints and the




severity of those complaints.




               Okay, I have talked enough, I'll

-------
let someone ask me some questions  if that's the case.




          MR. LEHMAN:  Thank you Mr. Johnson.  We




have some questions.




               Mr. Kovalick.




          MR. KOVALICK:  Mr. Johnson, Mr. Kolberg




this morning from the State of Wisconsin commented




on that state's philosophy and minimizing the




amount of waste that is headed to  the land by




quoting it correctly, for treatment and other con-




cepts.  And I was wondering if you would like to




comment -- if I understand what you are saying,




is that different from Illinois' philosophy?




          MR. JOHNSON:  I certainly as a representative




of an Illinois agency can't contend or contest any-




thing from the division of Illinois resources or




any other philosophy.




               I can base my comments on research




records from other states and clay geology landfill




definitions which have been determined inherently




and geologically, that clay landfills and -- they




are very specific are environmentally safe.




               For example, regardless of what type




of landfill technically permitted, clay or a more




general refuse landfill that sits more of earthen

-------
type materials, regardless of the landfill, there




are engineering descriptions that require a landfill




operator to sink monitoring wells and to monitor




any horizontal traveling of leaching contaminants.




               If that would ever exist




                      from the standpoint of analytic




evaluation of those monitoring wells, then that




particular landfill would have consideration of




closure.




          MR. KOVALICK:  I have a question from the




audience.  What happens when you run out of landfills?




          MR. JOHNSON:  Well, hopefully resource




recovery engineering -- and I am a chemical engineer,




and I see many many gains in this area.  Now some




of the larger landfills in Cook County have projected




volumetric   life that goes past the year -- into the



future.




               The independent management staff is




doing a very good job and following up with regula-



tions, and after the year 2000 or It may be shortly




thereafter, it's hard to say.  If you start running




out of some of these clay deposit landfill areas,




what next.




               I would think from what I see already

-------
both from the standpoint of private enterprise




and  Federal funding efforts, that resource recovery




engineering is going to take the bulk of the problem




or the developing problem and deal with it and the




minimal materials that are hazardous will be dry




weight sludges, and --




          MR. LEHMAN:  We have another question.




          MR. NEWTON:  Mr. Johnson, a question from




the floor.




               Does the Illinois EPA require positive




identification of hazardous materials for their




properties before disposal?




          MR. JOHNSON:  Certainly.  The type of




chemical clarification for landfills are required




on the basis of a supplemental permit.  And many




supplemental permits have been turned down for



landfills because they find evidence of what




chemical composition is,  it's evaluative of the




permit section that materials in that particular




landfill represents an acquifer  hazard.




               And it's redirected maybe 100 miles




to a different area.  There are  fortunately areas




that can take some very hazardous materials.




          MR.  LEHMAN:   I  have another question, Mr.

-------
Lazar.




          MR. LAZAR:  Yes.  From the audience.




               Mr. Johnson, there's a series of




questions on the monitoring of sites that you




mentioned.  Does this include monitoring of all




sites or just hazardous waste sites?




          MR. JOHNSON:  Yes, okay.  First of all




the Division of Land Pollution Control files




or agency files are public now.  Anyone can check




and verify that all operating sites have under the




permit descriptions that have been  legally enforced




since when those permit descriptions became valid




with the Pollution Control Board. 'Some of these




permits,    older permits/ were initiated prior to




pollution control board adoption of the regulations.



               But those sites are being phased out.




And I can get into that specifically but I don't




want to disappoint the questioner.




               What I am saying is that all operating




sites since adoption of the rules raised for monitoring




the wells, all operating sites and new sites  do have




monitoring wells, and they are being surveyed.




               The surveillance is of two types, the




landfill manager or management, whoever it may be
                        i»50

-------
it requires getting well analysis and these  are




more or less and not disputing industry or management




but they are more or less cross checked with our




own laboratory analysis annually, and if we  get




into a problem there are considerations for  closure.




               And there have been some considerations




in the past few years to the pollution control board




for action.




          MR. LAZAR:  After a site is closed Mr.




Johnson, how is the -- who is paying for the analysis



after that?




          MR. JOHNSON:  When anyone goes to  a closure




on a sanitary landfill, that particular ownership,




even if a deed is to be transferred, it has  to be




stipulated in the deed that for 36 months thereafter




the monitoring program is to be carried on at the



expense of the previous owner, or if that responsibility



is transfered by deed to the new owner.




               And this is according to our rules




and regulations.




          MR. LAZAR:  And who is paying for that




chemical analysis, is it the state or is it --




          MR. JOHNSON:  Our own monitoring   surveillance




that is a state funded effort.

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          MR. KLEPITSCH:  I have another question.




               This is in the form of  a clarification,




that asks are you saying most of your  comments  are




landfill oriented, that landfill effluent  dumping




will be approved by your agency and the chemical




waste will not be approved.




          MR. JOHNSON:  Not at all.  I'm saying  at




the present time resource recovery engineering  is




not sophisticated or even economically attractive




enough to industry to get it off the ground  and




I know industry and so would I would like  to have




seen it-   But at the present time, until economic




recovery becomes more attractive in its efficiency




of recovery, then we will continue to  very  severely




monitor landfill approaches to all refuse  and



 hazardous wastes.




               I might add one final comment.  The




Illinois EPA in the southern region of land  pollution




control has had success in establishing a  waste




exchange conference, or waste exchange commission




in the St. Louis area, where many of you are aware




of what the indications are there.  Industry can




go on record in the confidential placement  of materials




they have, and in others they may recycle  it and
                      $52

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 together  that  may be projected release.




           MR.  KLEPITSCH:   This question  clarification




 I  don't  think  was directed towards resource recovery




 as much as for treatment of the  chemical and resource facilities.



           MR.  JOHNSON:   All right, there are available




 to industry other methods of ultimate disposal.   You




 might  say it's a shifting of responsibility on a fee




 basis,  and for example,  there  are independent companies




 some  in  Kansas City that  carry waste out of northern




'Illinois  areas certainly  in the near Indiana area,




 there  are chemical companies on a private and inde-




 pendent  basis  that incinerate  sludges in  bulk --  they




 handle  sludges in bulk.




                And ultimate disposal of  the final




 product  which  is the concentrated  sludge, is  then




 shifted  and responsibility to  an independent




 company,  and I think it's recognizable that if a




 company  is based in another state, the Division of



 Land Pollution Control  for Illinois will lose its




 enforcement responsibilities.




                However, we are combining efforts




 with EPA  and division of  natural resources and




 in other  states  to make them aware of considerations




 across the state lines.

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          MR. LEHMAN:  All right.  We have some




more questions.




               Mr. Kovalick.




          MR. KOVALICK:  This is from the floor.




Is it possible to dispose of P.C.B.'s in any Illinois




landfills and what if the P.C.B.'s are from another




state?




          MR. JOHNSON:  There is one particular




landfill south of Sheffield and I believe it's




approximately 100 miles directly south of Rockford,




and this is called the nuclear engineering landfill




and I believe if my knowledge is accurate and I'm




sure it is, if I remember right the file is not in




front of me, but I do know they are extracting



hazardous -- accepting hazardous wastes because



the clay geology of that particular area is such




that it is certainly a conceivable place to put




it.




               They have a separate area which has




been permitted by the Illinois EPA land pollution




control section for low threshhold radioactive




wastes also.



               So you can rest assured that the




geology in clay and -- it is utilized for those

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types of depositions.




               Now  specifically  to  the  answer,




if P.C.B.'s are being  deposited  in  that  field,




I am not going to go on record and  say  yes,  but




I'll say that without  the  file in front  of me,  I




am reasonably sure  that there are P.C.B.'s coming




from Minnesota that are deposited in  that area.




          MR. LINDSEY:  You mentioned your recommended




clay landfills as being bathtubs capable  of  handling




all wastes.




          MR. JOHNSON:  I'm not  saying  that  all




clay sites have this.




          MR. LINDSEY:  Well, some  of them.




               But  in  a wet environment  rainfall




in excess of evaporation bathtubs will  fill  up,




and do you require  leachate treatment and what



happens to leachate when this builds  up?




          MR. JOHNSON:  I  use the word  crudely,



bathtub for layman  exposure.  The engineering




concepts if you have or anyone in the audience




has a real feel for landfill procedures,  at  the




end of every day's  operation, there is  the fill



face  is not left open but it  has to  be  closed with six




inches of cover.  This does give a runotr gradient to any

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percolation of precipitation' going through.




               And that's why the consideration



is there, and it's part of the permit.



               If a particular landfill or the



operators of that fill do not put six inches of



daily covering material on their open fill face,



they'll have a real problem with our agency.



               And we rectify that problem immediately.



It's a legal description in their permit to do so.



And I know I'm saying more about that than I should,



but the question that you raise as far as a bathtub



I don't want to give you the impression that we



are having a standing cesspool of water and leaching



conditions, whatever leachate is generated out of



the bottom of the fill and there are exceptions



to this, engineering exceptions, and permit excep-



tions, but whatever leachate is generated many



times it's pumped right back into the fill and



there's a very good chemical reason for that.



               The exchange reaction conditions




are such that by placing potentially initially



hazardous materials in organic refuse they will




tend to neutralize one another in solution.



               If you have an alkaline base in





                     $56

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one and an organic acid base in the other they




will reach a blending effect  of neutralization,




and that's great.




               That's part of the  intention.




Now, whatever material goes (directly to the




bottom and collects on the hydrostatically sealed




body because it's running through  impervious




clay, there are many engineering considerations




depending upon the type of material that's been




allowed to go in there and we require engineering




considerations of that specific area of fill to




recirculate the  leachate back into the fill facing




continually neutralizing and percolating through




the fill face.




          MR. LEHMAN:  I thank you Mr. Johnson.




Your statement has precipitated a  large number of




questions, and unfortunately we are already running




15 minutes behind time, and in the interests of




the people who are scheduled to speak after the




lunch break, I think we should stop the questions.




Stop the question period now and we will submit




these additional questions that remain to you and




hope that you will respond in writing for the




record if you will please do so.

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          MR. JOHNSON:  That will be fine.




          MR. LEHMAN:  At this time I would like




to give the audience some idea of the way we think




we are going this afternoon.




               We have had a large number of people




who have indicated the desire to speak this after-




noon, and yet I think we will be able to finish




the meeting today, without question.  And probably




without going into an evening session.




               So those of you that have travel




plans if you want to worry about them -- I think




we'll probably be able to finish before the dinner




hour today.



               At this time I'd like to adjourn the



meeting for one hour and reconvene at 1:35.  Thank




you.



                              (At which time




                               a lunch break was




                               called.)

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          MR. LEHMAN:  All right, now would you




please take your seats ladies and gentlemen, so




we could get started.




               I'd like to reopen the meeting and




to call the first person, Mr. Dennis Bridge of




Standard Oil of Indiana.  Mr. Bridge would you




please take the podium.




          MR. DENNIS BRIDGE:  Mr. Chairman, members




of the panel, ladies and gentlemen, my riame is




Dennis Bridge.  I appear today in behalf of the




Manufacturing Chemists Association,       as




Chairman of the Solid Waste Management Committee.




               MCA is a non-profit trade association




having 186 United States company members representing




more than 90 per cent of the production capacity of




basic industrial chemicals within this country.




               I am a chemical engineer with eight



years of experience related to the safe disposal




of hazardous waste materials.




               MCA shares EPA concern that there is




a need for guidance to insure proper management of




hazardous wastes.  This concern is evidenced by the




fact that MCA has developed three guides on subjects




related to landfill disposal of solid wastes.







                           £53

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               Many of the topics discussed herein




are expanded upon in these guides.  Copies are included




with this statement for your consideration.




               We have chosen to reply in narrative




form to the many questions which the Environmental




protection Agency has proposed, rather than on a




question by question basis, to minimize repetitive




commentary.




               There is a great difference of opinion




as to how a hazardous waste should be defined.  The




difference exists because the terms hazardous




substances and hazardous materials can easily be




and frequently are used in an inaccurate manner.




This point can be illustrated by the following




example.



               A small, sealed and properly identified




bottle of potassium cyanide in a chemical laboratory




poses a minimal hazard to man or his environment.




However, if the contents of the bottle were to be




emplted into a drinking water well, they immediately




become extremely hazardous.




               Hazard is a function of not only a




substance's inherent toxicity but also the quantity




and mode of encounter as well.

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               The adjective hazardous cannot be




used with any degree of accuracy or precision relative




to a material, substance or waste unless some mean-




ingful indication is given of the circumstances under




which it applies.




               MCA recommends the following definition




for hazardous waste which addresses the disposal




aspect of hazardous waste management.




               "The term hazardous waste means any




waste or combination of wastes which,  when disposed




of in sufficient quantities in or on the land, pose




a substantial present or predictable potential




hazard to human health or to beneficial living




organisms."




               This definition of hazardous waste




is broad, and more specific criteria are required




for regulatory purposes.  There are hazardous




features of materials which must be properly con-



sidered in the handling, containerization and




transporting of such materials, whether or not




destined as a waste.




               The general criteria for evaluating




the possible adverse impact of waste materials




include:
                           SSI,

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               The quantity disposed of to the




site, the concentration as disposed, the concentration




anticipated in the surrounding environment, the




toxicity of the material, site characteristics.




               Among the latter are proximity of




ground and surface waters, soild percolation,




barrier characteristics, and leachate attentuation.




               Because of the complex interactions




of these factors, we do not feel that predetermination




of disposal techniques is practical or reasonable.




Final determination of a technically feasible




and economically sound disposal technique must be




made on a case by case basis.




               In fact, predetermination could be



counterproductive in that it would restrict




development of new technology and eliminate use




of viable alternatives appropriate to specific




geographic areas or to available equipment.




               There are of course hazardous




features materials which must be properly con-




sidered in the handling, containerization and




transporting of such materials, whether or not




destined as a waste.




               We recommend that authority over
                          &C2

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the packaging, transportation  and  storage  of




hazardous waste continue to be vested  in the  United




States Department of Transportation.




               And that the definition  of  hazardous



substances used by this agency should  apply as




equally to waste materials as  it does  to the  finished




products.




               Therefore, no additional regulations




or criteria are needed in these  areas.




               With respect to analytical  techniques




and sampling, a wide variety of  standard methods  is




available to identify the physical, chemical  and




biological characteristics of  a waste.




               Because these wastes can be in the  form




of solids, liquids, sludges, tars, and what have  you,




sampling techniques will vary  depending on the




physical state of the waste in order to assure  a



representative sample of the waste is  obtained.



               The responsibilities for safe  and




environmentally acceptable hazardous waste manage-




ment are shared by the generator,  transporter,




disposer of the waste, as well as  the  public  sector




as represented by  Federal, state and local agencies.




Among the several responsibilities of the generator







                             5G3

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of hazardous wastes are:




               First, the generator should adequately




describe the waste so that the transporter and




treater/disposer are aware of those properties




which are important for safe transportation and




disposal.




               Second, the generator must package




and label the waste in a safe and legal manner and




provide recommendations for safe handling and




spill control.




               Third, the generator must insure that




both transporter and treater/disposer have valid




legal sanctions to handle the waste.




               Finally, the generator, as well as



the transporter and treater/disposer, should maintain



records of all waste disposed of, including type and




amount.




               The transporter must comply with all




Federal , state and local regulations for handling




and transporting hazardous materials safely to the




designated treater/disposer.




               The treater/disposer is responsible




for the safe and legal disposition of wastes




accepted for disposal, taking into account the

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pertinent characteristics  of  the waste.




               Records of  the types  and  amounts  of




wastes in inventory  and the results  of control  and




monitoring tests must be maintained.  Monitoring and




record keeping should be concerned only  with  preserving




air and water quality and  public safety.




               MCA recommends that the responsibility




for the waste should be associated with  physical




possession of the waste, so that the generator  should




not be held liable for negligence by the transporter




and/or disposer of the waste.




               We emphasize that the generator  should




be free to decide whether  to treat or dispose of




wastes himself, or to utilize a privately or  a




publicly operated system,  providing  of course that




all operations are environmentally adequate and




satisfy governmental regulations.




               Published cost data on the various




processes and techniques for treating and disposing




of hazardous materials are limited.  This is  un-




fortunate because such data would be valuable in




establishing ultimate disposal regulations for




hazardous materials.




               Such data would also be of assistance

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to the waste generator in determining an optimal




waste handling system.




               In view of this inadequacy, it is




imperative that sufficient flexibility be incorporated




into any legislation or regulatory proposal to permit




evaluation of alternative and environmentally




acceptable disposal methods.




               Environmentally sound management of




hazardous waste treatment, storage and disposal




activities is comparable and equivalent in its




requirements to those for any well managed industrial




facility producing similar materials.




               Existing regulations already applicable




to packaging, containerization, fire protection,



employee training, transportation, incident reporting,




and what have you are in  existence and would also



apply to disposal operations.




               Labeling and placarding of waste




shipments should be to the degree required by




the Code of Federal Regulations, Titles 46 and 49.




This is an effective and accepted system for




transporting of hazardous wastes.




               It is the generator's responsibility




to furnish necessary information pertaining to the
                     5G6

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particular waste so that the disposer may handle




the hazardous waste in an acceptable manner.




               We thank you for the opportunity




to present this statement, and we assure you  of our




readiness to answer any questions or furnish  any




further information that the Environmental Protection




Agency may desire.
                        07

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TECHNICAL GUIDE
      SW-1
                A Guide for
                Landfill Disposal
                of Solid Waste
     MANUFACTURING CHEMISTS ASSOCIATION
     1825 CONNECTICUT AVENUE. N W
                      WASHINGTON. D C. 20009
             '5&B

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The information  and recommendations contained in this publication have  been compiled  from
sources believed to be  reliable and to represent the best opinion  on the subject as  of  1974.
However, no warranty, guarantee, or representation is mode by the Manufacturing Chemists Asso-
ciation as to the correctness or sufficiency of any information and representation contained herein,
and the Association assumes no responsibility in connection therewith; nor can it be assumed that
all necessary warnings and precautionary measures are contained in this publication, or that other
additional information or  measures may not be required or desirable because of particular or
exceptional conditions  or  circumstances, or  because of applicable  federal, state or  local law.
                     © 1974 by Manufacturing Chemists' Association, Inc.
                                         5BS

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                 TECHNICAL    GUIDE   SW-1


   A  GUIDE  FOR  LANDFILL  DISPOSAL  OF  SOLID   WASTE

Landfill usually is one of the  more viable alternatives for the ultimate disposal of unusable residual wastes
incident to chemical manufacturing. The responsibilities  of industry to assure compliance with  regulations to
protect and enhance the quality of the environment are becoming more definitive and performance requirements
more restrictive. In the disposal of waste materials resulting from chemical manufacturing operations by the
landfill method, whether carried out by the waste generator or by his contractor, it is essential  that the basic
obligations of safe handling and proper ultimate disposal  are met in a satisfactory manner.  It is intended that
this guide, prepared as an activity of the Solid Wastes Management Committee of the  Manufacturing Chemists
Association, will assist in fulfilling these responsibilities.
                                   INTRODUCTION
  A landfill, when properly designed  and  operated,
is a  well-controlled method  for disposing of solid
wastes.  It involves deposition of the wastes in a
controlled manner into a prepared portion of a care-
fully selected site followed by spreading and covering,
or blending, with soil.

  This guide has been prepared to provide a  refer-
ence for identifying  matters that  should  be  taken
into  account when considering landfilling chemical
wastes.  It is intended  to be used in conjunction with
existing federal, state  and local regulations to pro-
vide counsel for proper landfilling of chemical wastes
whether they be  disposed of separately, or m con-
junction with municipal-type refuse. In effecting ade-
quate and safe disposal of a chemical waste in either
case, basic considerations are the various character-
istics of the waste and the landfill location, design
and operation.

  The use of landfill  for liquid, semi-solid or solid
chemical waste either alone or in conjunction with
municipal and  industrial  refuse is a method of ulti-
mate disposal which  can be practiced safely.  The
landfill  disposal of chemical  waste from industry,
particularly when practiced in a joint or cooperative
facility for community solid waste, often offers  the
most economical disposal method as well  as  the
method of least environmental stress   Certain pre-
cautions in waste acceptance practices and in land-
fill location and operation must be taken to minimize
adverse effects upon the environment.  Some  chemi-
cal  wastes  constitute a  potential  water  pollution
problem because these wastes may leach through the
landfill into groundwater with subsequent detrimental
effects on groundwater quality.

  In addition to the possibility  of water  pollution,
there are other safety hazards associated with land-
fills of some chemical wastes. Internal gas genera-
tion  and highly  reactive and flammable  materials
charged to landfills can result in fires and explosions,
especially when  exposed to sources of ignition such
as bulldozing equipment  A  landfill  fire  also con-
stitutes an  air pollution  problem.  Odor  problems
can arise when  chemical wastes are not pretreated
and handled properly.

  Before deciding to landfill a particular waste, con-
sideration should be given to all  alternative methods
of disposal.  Both economics and hazard to the en-
vironment must be considered. In some cases a more
costly method may be justified in view of the poten-
tial hazard of one less costly.
                          WASTE  CHARACTERISTICS
  Several criteria should be employed in evaluating
the feasibility  of landfilling a  particular chemical
waste.  These include degradability, leaching char-
acteristics, toxicity, radioactivity, odor potential, flam-
mability, and reactivity.

A.  Degradability—Landfill is  particularly suitable
    for disposal of inert materials or  for substances
    which  can be  converted  into  harmless com-
    pounds within  the  fill by buffering,  filtration,
    precipitation,  microbial  action, adsorption  or
    ion-exchange.  Some polymers are  inert.  Those
    which  have degradation products which may be
    toxic to microbes  present in the fill  require
    special  care.
                                                    570

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 Udnticol
 Grid.
 SW-1
Manufacturing Chemists Association
    1.  Many aliphatic hydrocarbons decompose in
       the soil.  Examples  are  gasoline,  tars and
       some  rubber  compounds.   Unsaturated
       branched-chain compounds  of high  mole-
       cular weight are generally less  susceptible to
       degradation than their saturated, unbranched,
       low molecular weight analogs.

    2.  Aromatic  materials are generally more re-
       sistant  to  microbial  and  chemical  degrada-
       tion  in  the soil. Carbon in  aromatic  forms
       constitutes a substantial portion of the  stable
       organic  fractions in soils, however, it is known
       that  the aromatic  ring can  be cleaved by
       some soil  organisms.  Once  cleaved, result-
       ing straight chain hydrocarbons  are  more
       readily  degraded   and  oxidized to carbon
       dioxide  and water

    3.  Biocides may be degraded in a landfill if no
       toxic molecular fragments or metallic com-
       pounds  are produced  which would curtail
       the biologic activity of a standard waste water
       treatment system.

    4.  The  stability  of pesticides and halogenated
       or phosphorylated  compounds  is  usually  a
       function of soil texture, humus content, tem-
       perature, moisture, and pH  If a leachate is
       produced  from the  fill, these compounds
       should  not be placed in landfill until,  using
       systems  closely comparable to the fill  itself,
       studies  indicate that  they can  be safely de-
       graded   to provide  a leachate  which is not
       toxic or which can be treated by a standard
       waste treatment technique.

B.  Leaching Characteristics—-A collection system
    may be required for landfills where leaching is  a
    threat. The components of the leachate may not
    have been completely degraded and might  prove
    detrimental  to  groundwater supplies in the area
                     beneath and adjacent to the landfill. A collection
                     system might be provided when the leachate has
                     high COD, BOD, solids, and other characteristics
                     which respond to treatment before discharge into
                     the receiving water.

                  C. Toxicity—Chemical wastes, when placed in a
                     landfill, should not  result in  conditions  toxic to
                     the microbes involved in the breakdown of the
                     various materials in the landfill.  Heavy metals
                     in soluble form known to be toxic to animal and
                     microbial organisms may require conversion to
                     an  insoluble  form  before landfill  disposal,  or
                     isolation such  as  provided by impervious bar-
                     riers.   Some chemical wastes can  be toxic  to
                     operating personnel, and compounds such as cya-
                     nides must not be placed where acidic conditions
                     are possible.

                  D. Radioactivity—It   is  not  advisable to  place
                     radioactive waste in a  landfill, especially  gamma
                     and beta emitters with long half-lives.   Appro-
                     priate  AEC and state regulations must  be fol-
                     lowed in disposing of radioactive materials.

                  E  Odor Potential—Materials relatively nonbiode-
                     gradable and malodorous, such as some acrylates
                     and mercaptans, should  be placed  in  landfill
                     with care.  Odor can be minimized with proper
                     pretreatment,  handling and  blending of many
                     odorous  wastes.

                  F.  Flammability—Pyrophoric  materials may  be
                     dumped in an isolated portion of the land  fill
                     only after  careful  technical  preparations  have
                     been taken to  prohibit contact with  air at the
                     site.

                  G  Reactivity—Materials which tend to react vio-
                     lently  under certain conditions can be placed in
                     a landfill if care is taken to prevent those con-
                     ditions.  Examples  are monomers or  peroxides.
LANDFILL  DESIGN AND  OPERATION—GENERAL  CRITERIA
A.  INTRODUCTION

    1.  Assuming that  the waste  is acceptable  for
       landfill,  the design of the  fill should assure
       that no significant adverse environmental cir-
       cumstance will arise. Major factors to be con-
       sidered are infiltration  and percolation, gas
       production and emission, leaching, ground-
       water travel,  runoff,  emissions  from trans-
       portation and waste insertion activities, and
       —when   required—leachate  collection  and
       handling  systems.
                     2.  Basic mechanisms which result in contamina-
                        tion  of groundwater  are direct  horizontal
                        leaching  of  waste  by groundwater, vertical
                        leaching  by percolating  water, transfer by
                        diffusion  and convection of  gases produced
                        during decomposition.  These  mechanisms
                        may combine at random  and work together,
                        and each may separately have an effect upon
                        water quality.   The retention  or  spread  of
                        any resultant contaminant is determined by
                        the particular weather, geologic, and hydro-
                        logic conditions at the landfill site.
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                                   Manufacturing Chemists Association
                                                                                                T.dinicnl
                                                                                                Guid.
                                                                                                5W-1
   3.  Active chemical  wastes  can  be  rendered
       harmless in a landfill through buffering, filtra-
       tion, microbial action, adsorption,  and ion-
       exchange   To  facilitate  these  mechanisms,
       adequate  retention and contact  time between
       chemical  waste,  soil,  and any other solid
       wastes is necessary.  Grain size and unsatu-
       rated depth of the fill help determine retention
       time.  Adsorptive capacity of the solid waste
       and soil influences  the contaminant contact
       time and also represents a treatment mech-
       anism  in itself.   Greater  unsaturated  depth
       serves  to increase the adsorptive capacity of
       the fill system by bringing infiltrative water
       into  contact with a greater  mass  of  waste
       and soil,  also  affecting biological treatment.
       The  potential for  reaeration  of the  active
       biological  zone at the fill  surface,  once in-
       filtration has ceased, also is influenced by the
       unsaturated depth.  Adequate draining of the
       unsaturated zone  and of  the biologically
       active  zone at the surface is  necessary to
       ensure an  optimal retention  time  for bio-
       logical treatment and to  avoid  restricting
       reaeration of the active zone.

          Draining of the  unsaturated  zone  and of
       the surface bioactive  zone can be obtained
       on a dynamic basis in leaky landfills  Further
       enhancement of  the biological  reaction  can
       be obtained by leachate recycle in  the same
       systems when  leachate collection is required.
       Biological  activity  may  diminish  in  cold
       weather.  Its adverse effects can be overcome
       by achieving biological maturity in the system
       prior  to the onset of the cold season.

B. DESIGN  REQUIREMENTS

    1.  Topographical Maps of Proposed Fill and
       Adjacent Area

       (a) Topographic information should include
       at least the following:
          (1) Borrow pit areas.
          (2) Typical  cross-sections  of  lifts,  di-
              mensions  and elevations of the base
              lifts.
          (3) Grades required for proper drainage
              of lifts.
          (4) Location  of public and private water
              supplies, wells, springs,  streams,
              swamps  or other  bodies  of  water
              within one mile of the proposed land-
              fill property lines.
          (5) Location  of  all  homes,  industrial
              buildings, roads and other applicable
          details within three-fourths (%) mile
          of the disposal site.

      (6) Wind patterns  and velocities
      (7) Scale  should  not  be  greater  than
          1  inch equals  200 feet  and contour
          intervals should not be  greater than
          5  feet.
   (b)  Certain factors may serve to limit normal
   landfill operations,  and information pertain-
   ing to these factors should  be included as
   follows:

      (1) Location  of underground  and  sur-
          face mines within approximately one-
          fourth  (1A)  mile  of the  proposed
          landfill site  property  lines and maps
          showing  the  extent  of  deep  mine
          workings, elevation of the mine pool
          and location of mine  peel discharges.
      (2) Location  of gas and oil wells.
      (3) Location  of  high-tension power line
          rights-of-way.
      (4) Location  of fuel  transmission pipe-
          line rights-of-way

2  Soil Geological Characteristics

   (a)  A  report on  the soils,  geologic  and
   groundwater characteristics of the proposed
   site  should be based on a sound geological
   investigation

   (b)  A sufficient number of borings or wells
   should  be drilled  to determine the  soil
   geology and groundwater conditions.  These
   may  be  supplemented by past boring data
   as well as excavations where appropnate.
      (1) Borings  or wells  should  be  drilled
          five  (5)  feet  into the  groundwater
          or bedrock or twenty (20) feet  be-
          low the base of the proposed landfill,
          whichever is shallower.  One (1) bor-
          ing or well should be drilled neat the
          point of highest elevation.
      (2) A minimum of one (1) groundwater
          quality monitoring  well  should  be
          drilled in each dominant direction of
          groundwater movement in order to
          check the  effect  of  operations  on
          original  groundwater quality

3. Characteristics  of  Cover Material

   (a)  Cover material should  be suitable  soil
   or other  material which shall  have medium
   to moderately coarse  texture and should be
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Uchnial
Guide
SW-1
Manufacturing Chemists Association
       of such character that it compacts well, does
       not crack excessively when dry and is rela-
       tively  free of  decomposable  materials  and
       large  objects.

       (b) Where cover material is limited in quan-
       tity or  is not  available on the site, design
       and  operational  plans  must  include  a de-
       scription of source of cover  material,  indi-
       cating such  things as soil types, volumes to
       be  used,  transport  methods  and contract
       arrangements

   4   Prevention of Groumlwater Pollution

       (a) To minimize risk of groundwater  pollu-
       tion  from  landfill leachate,  several  factors
       including waste quantity and  characteristics,
       local  hydrology and geology, and local en-
       vironmental assimilative capacity  should be
       considered

          (1} General good practice in the preven-
              tion of groundwater pollution involves

               (i) Diversion of surface runoff from
                   fill;

               (n) Sloping fill surface and planting
                   durable ground cover to drain
                   away runoff without erosion;

              (iii) Using the most impervious con-
                   venient cover

       (b) If studies  indicate that landfill leachate
       may still be a problem, the following should
       be considered;

          (1) Elimination of production of leachate.
              In sufficiently dry  areas, waste  can
              be buried above the saturated zone.

          (2) Migration of leachate  under accept-
              able conditions is usually practiced in
              humid areas. The hydrogeologic en-
              vironment  for  acceptable  migration
              of leachates  ranges from relatively
              impermeable strata, such as clays and
              some  glacial tills, to more permeable
              strata, such as gravels and rocks  The
              quality  of  the receiving water body
              and  the nature of the  strata  will
              determine the travel time  and length
              of path  required for acceptability.

          (3) Migration and Recovery of Leachate

              (i)  This depends  on a groundwater
              flow  system to  funnel leachate  to  a
              point where it can be collected in  a
              reservoir on  or below the  surface
              when attenuation during travel is not
                                sufficient to render the leachate harm-
                                less

                                (ii) If flow lines  do  not converge
                                naturally, they can be made to do so
                                by creating an artificial discharge
                                zone  using  ditches,  tile  drains, or
                                pumping wells.

                                (iii)  Collected  leachate  should  be
                                treated prior to discharge.

                            (4) Retention and  Recovery of Leachate

                                (i) This design should be used when
                                there is indication  that leachate will
                                not be rendered harmless by the fill
                                and when  no  other  means  exist to
                                handle leachate.

                                (n) A tile drainage system should be
                                installed to collect the leachate.

                                (iii)  The fill should have the equiva-
                                lent of a clay seal.

                                (iv)  Leachate  should be treated prior
                                to discharge

                      5  Prevention  of Surface Water  Pollution

                         (a) To  avoid risk of  surface  water con-
                         tamination from the fill, the  site should be
                         designed  and operated to manage  surface
                         water  runoff and  erosion.   Surface  runoff
                         should  be  periodically monitored,  and  if
                         found to be contaminated,  the following  pro-
                         cedures should be  followed:

                            (1)  Rainwater  runoff from the fill mass
                                should pass into a contaminated catch
                                water basin

                            (2)  The catch basin should be constructed
                                to  prevent  leaching   of  materials.
                                Compacted clay construction may be
                                used or a lining may be required.

                            (3)  Runoff should subsequently be treated
                                before discharge.

                      6.  Gas Venting

                         (a) Gas can  accumulate at  high points in
                         cell-type  landfills   where  large  pockets of
                         orgamcs  lodge.  Vents  should be located at
                         such points in each cell to prevent significant
                         accumulation.

                         (b)  When soil or  solid waste are blended in
                         approximately equal volumes with chemical
                         waste, vents may not be required if there are
                         no cells and  gas is  emitted uniformly and in
                         low concentration over the  entire fill face.
                                                       573

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                                    Manufacturing Chemists Association
                                       Udinical
                                       Guidi
                                       SW-1
    7.  Access Roads

       (a) Access roads to the entrance of the land-
       fill should be surfaced with such materials as
       asphalt,  gravel  or cinders and  should  be
       provided with a base capable of withstanding
       anticipated load limits. Prevention of dusting
       is often required.

       (b) An all-weather access road negotiable by
       loaded collection  vehicles should be provided
       from the entrance gate  of  the landfill to the
       unloading area.

       (c) Signs indicating traffic  flow and hours of
       operation should be  provided.


C.  FILL  OPERATION

    1.  Waste Pretreatment

       (a) If the physical, chemical or lexicological
       features of a waste are such that hazards are
       imposed on transportation  personnel,  the
       surrounding  community, or  the landfill op-
       erators,  pretreatment  should  be  given  to
       eliminate this hazard.  If  such treatment  is
       not  possible,  alternate  disposal   methods
       should be sought. For example:

          (1) Catalysts  should  be added to organic
              monomer  semi-solids at production
              unit or fill site to  minimize leaching
              potential  and  maximize blendability.

          (2) Acid or  caustic sludges neutralized
              and slurried to maximize blendability
              and  minimize reactivity.

          (3) Malodorous  materials neutralized
              where they occur.

    2.  Unloading Chemical  Wastes

       (a) Chemical  waste loads  should not  be
       allowed  to enter the  fill area until  reviewed
       at the waste source and pretreated, if nec-
       essary.  It is recommended that the operation
       be systematized by requiring that a "landfill
       ticket"  accompany  each  load of  chemical
       waste which describes the material, applicable
       landfill  procedure, personnel protection  re-
       quirements, special instructions, waste source,
       quantity and date.

       (b)  Unloading areas should be specified and
       restricted  to within  a  reasonable distance
       from the working face  so as to permit col-
       lection  vehicles to unload  promptly.

       (c)  An  attendant should  direct vehicles  to
       the unloading  area or  clearly marked signs
   should be located prominently along the land-
   fill road up to the unloading area.

   (d)  Supervision should be continuously avail-
   able to coordinate the unloading  activities.

3.  Waste Blending

   (a)  Chemical wastes should be blended with
   appropriate volumes of soil or  refuse,  and
   compacted to produce stable earth.

   (b)  All large foreign  objects which will not
   provide much contact surface area and which
   may result in the introduction of an air pocket
   to the fill should be removed prior to blending.

   (c)  Six  inches  of cover  should be  added
   daily for safety and environmental protection.

   (d)  Stockpiling both soil and refuse for cold
   weather use  is advisable.

4.  Size of Working Area

   The size of the active fill area should be con-
   fined  to  insure that blended waste  can be
   spread, compacted and  covered  daily.

5  Equipment

   Equipment should be sufficient  for  the on-
   site  pretreatment,  size  reduction, blending,
   spreading,  compacting,  and  covering  op-
   erations.

6. Fire and Safety protection

   (a)  Fire  protection and fire-fighting facilities
   adequate to insure  the  safety of employees
   and provisions to deal with accidental bum-
   ing  of blended wastes within  the landfill
   should be provided.

   (b)  Emergency first-aid equipment for  ade-
   quate  treatment of injuries should  be  pro-
   vided.

   (c)  Fences should be provided to enclose the
   landfill to discourage non-authorized people
   from  entering the fill.

    (d)  Signs indicating  nature  of  the  landfill
    and  specific  hazardous  areas  should  be
    provided

    (e) A telephone or equivalent type of com-
    munication should be available at the fill site.

    (f)  24-hour surveillance over the fill should
    be maintained with appropriate security.

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hdiniul
Gviid.
SW-I
                                      Manufacturing Chemists Association
    7.  Operational Records

        These should consist of a  written  log main-
        tained by  the landfill operator including the
        following  information:

        (a) Types and quantities of chemical waste
        received;
                                                                   (b)  The portion or area of the landfill  used;

                                                                   (c) Special  provisions made for  hazardous
                                                                   waste disposal;

                                                                   (d)  Any deviation from the operating  plans
                                                                   and specifications.
  The following references offer additional material
which  may  be  helpful  in  landfill  planning  and
management:

 1.  Cummins, R  L,  Effects  of Land Disposal  of Solid
    Wastes on Water  Quality  Environmental Control Ad-
    ministration,  Bureau  of  Solid Waste  Management,
    Cincinnati,  1968

 2  Steiner, R L and  R. Kantz, Sanitary Landfill; A Bibli-
    ography,  Public Health Service Publication No  1819,
    Washington, U S  Government Printing  Office,  1968,
    37 p

 3.  Disposal  of  Solid  Toxic Wastes, Technical  Committee
    on the Disposal of Solid Toxic Wastes, Her Majesty's
    Stationery Office,  London, 1970,  106 p

 4.  Mead, B E, and W  G  Wilkie, Leachate Prevention
    and Control  from Sanitary  Landfills, Proceeds.  AIChE,
    68th Annual meeting, Houston, Texas, February  28-
    March4, 1971

 5.  Stone, R  , Sanitary Landfill Disposal of Chemical and
    Petroleum Waste Symposium on Solid Industrial Wastes-
                                                               Part II, AIChE, 68th Annual meeting, Houston, Texas,
                                                               February 28-March 4, 1971

                                                            6  Hydrogeology of Solid Waste  Deposit Sites  in  NE
                                                               Illinois, US. Environmental Protection Agency, 1971.

                                                            7. Witt, P. A.,  Jr, Disposal of Solid  Wastes,  Chemical
                                                               Engineering, October 4, 1971, pp  62-78,

                                                            8  Brunner, D.  R, and  D. J. Keller, Sanitary Landfill
                                                               Design  and  Operation, U.S  Environmental Protection
                                                               Agency, Solid Waste  Management  Series  Publication
                                                               SW-65ts, U.S. Government  Printing Office, Stock  No.
                                                               5502-0085, 1972, 59 p

                                                            9. Ballentme, R K, S R  Reznek, and C  W  Hall, Sub-
                                                               surface Pollution  Problems  in the United  States, US.
                                                               Environmental Protection Agency, Office of Water Pro-
                                                               grams,  Technical Studies Report-  TS-00-72-02, May,
                                                               1972, 24 p.

                                                           10  Manufacturing Chemists Association Pilot, Case No. 49,
                                                               Solid Approach to Waste Disposal,  April,  1971.

                                                           11  Curry,  Nolan A , Guidelines for Landfill of Toxic In-
                                                               dustrial Sludges, Proceedings Twenty-Eighth Industrial
                                                               Waste Conference, Purdue University,  1973.
                                                   575

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TECHNICAL GUIDE
      SW-2
                A Guide for
                Contract Disposal
                of Solid Waste
              Adopted 1974
     MANUFACTURING CHEMISTS ASSOCIATION
      1825 CONNECTICUT AVENUE. N W.
                       WASHINGTON. D. C 20009
              576

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The information  and recommendations contained in this publication have  been complied  from
sources believed to be  reliable and to represent the best opinion on the subject as  of 1974
However, no warranty, guarantee, or representation is made by the Manufacturing Chemists Asso-
ciation as to the correctness or sufficiency of any information and representation contained herein,
and the Association assumes no responsibility in connection therewith, nor can it be assumed that
all necessary warnings and precautionary measures are contained in this publication, or that  other
additional information or  measures may not be required or desirable because of particular or
exceptional  conditions  or  circumstances, or because of applicable federal, state or  local  law.
                     © 1974 by Manufacturing Chemists' Association, Inc.
                                     b'll

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SOLID WASTES  MANAGEMENT  GUIDE  SW-2


                      RECOMMENDED  PROCEDURES

         CONTRACT  DISPOSAL  OF  WASTE  MATERIALS
The Industry's responsibility to comply with regulations to protect and enhance the quality of the environment
progressively achieves clearer definition while performance requirements are becoming more exacting. Where
disposal of waste materials from chemical manufacturing operations is to be carried out by a contractor, it is
essential that the responsibility be assigned to a dependable, competent, and experienced operator to assure that
basic obligations of safe handling and proper ultimate disposal are performed in a mutually satisfactory manner.
This guide, prepared as an activity of the Solid Wastes Management Committee of the Manufacturing Chemists
Association, is intended to assist in fulfilling these responsibilities.
    Because of the many legal considerations involved, however, matters concerning contract disposal of waste
materials should be discussed with one's own legal counsel.
                                 INTRODUCTION
  Contract disposal of waste materials assigns re-
sponsibility for ultimate disposal to a second party, a
contractor assuming performance  obligations for  a
fee. The contractor must be competent, responsible,
and dependable. Both contractor and generator must
understand fully the obligations of each and the
potential liabilities involved.

  This guide contains suggestions to assist managers
of chemical manufacturing plants regarding contract
disposal practices which will:
  • Effect safe and economic ultimate  disposal of
    unusable waste residuals,
  • Fulfill social as well as regulator obligations,
                      and
  • Minimize adverse  community attitudes  and
    potential  legal  liability.
                       WASTE  CHARACTERIZATION
  First consideration in the disposal of waste mate-
rials  should be  given to the careful and complete
definition of the waste and technical assessment of
the alternative methods of disposal which may be
employed.  Although  the contractor may be  well
qualified in materials handling and disposal method-
ology, the  generator of the waste  material  will be
more familiar with the specific characteristics of the
materials and applicable handling and disposal prac-
tices   Full  disclosure by the generator and complete
understanding by the contractor are vital elements in
mutually satisfactory contract disposal.

  Before assessing applicable and acceptable disposal
methods, the basic physical, chemical, thermal,  bio-
chemical, and reactivity properties of the waste must
be established. In most cases the generator will con-
duct the necessary characterization studies and advise
the contractor, but sometimes the contractor may be
qualified to conduct such studies.

  Applicable materials handling methods  can  be
determined from knowledge of  physical state and
unique handling characteristics  A list of terms and
their meanings may be helpful to mutual understand-
ing of waste characteristics'
   Physical State
  Solids  _____  ___
                  Dry material in powder, gran-
                  ular, pelletized, or bulk form.
                                             £78

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 T
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                                  Manufacturing Chemists Association
                                         T.duikcil
                                         Gui*
                                         SW-2
generator and contractor. Arrangements to observe
periodically his materials handling equipment and
methods, and the ultimate disposal facilities should
be established  at the time the contractual arrange-
ment is  developed.  Follow-up on the status of au-
thority to transport and permits to operate should be
routine.  It is important that the contractor's activities
remain in compliance with all applicable law, regula-
tions and permit conditions; and that the generator be
fully aware of changing requirements and the con-
tractor's ability to continue to operate in compliance

  Monitoring is  particularly important when more
restrictive regulations are being promulgated; when
contract termination is  approaching; in cases where
permit authority  is transferred  to another party, or
when title  to materials  does  not pass from  the
generator.
                                         APPENDIX
WASTE CHARACTERIZATION CHECK LIST
   I.  Basic Physical State (Check one)
      1) Solid
         (a)  Granular
         (b)  Particle size
      2) Liquid & Slurry,
      3) Gas;
      4) Sludge;
      5) Tar,
      6) Containerized;
  II.  Physical and Chemical Characteristics
                               __°F to	
2 ) Density or specific
gravity
3 ) Moisfnre
4) Freezing point
5) Boiling point - 	
6) Thixotropic -
7) Stability
a) Decomposes
anerobically
b) Dries readily
(dewatered)
c) Sets up or hardens,
irreversibly
8) Heat Value 	 ...
III. Flow Properties
1) Viscosity .... 	 	

(Suitable units)
% hy weight

°F
Yes 	 No 	


.. Yes 	 No 	

Yes 	 No 	

Yes 	 No 	
	 B.t.u /lb.

(Suitable units)
                                                          2) Settles       ..    .     . Yes	No_
                                                          3) Pumpable               Yes	No_
                                                          4) Separates into phases _.   Yes	No_
                                                          5) Compressibility   -    .. Yes	No_
                                                     IV.  Storage Practices
                                                          1) Heated
                                                          2) Agitated
                                                          3) Gas-blanketed
                                                          4) Water-blanketed
                                 Yes	No-
                                 Yes	No_
                                 Yes	No_^
                                 Yes	No_
                                                      V.  Flammability
                                                          1) Flash point ...	
                                                          2) Auto-ignition	  	Yes	No_
                                                          3) Self-supporting        ..  Yes	No_
                                                          4) Reactive  ....  .    	   Yes	No_

                                                     VI.  General Chemical Form
                                                          1) Organic  -
                                                          2) Inorganic
                                                          3) Halogenated
                                                          4) Alkaline
                                                          5) Acidic -
                                                          6) Radioactive
                                                          7) Noncombustibles and
                                                                Metallic Compounds .. Yes	No	
                                                          8) Ash          	% by weight
                                                                           	fusion temperature
	 Yes 	
.. Yes 	
1 . Yes 	
. Yes 	
Yes
	 Yes 	
No 	
No 	
No 	
No 	
No 	
No 	
                                                    520

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SW-2
                                  Manufacturing Chemists Association
 VII.  Chemical Elements
      1) Carbon    	  	
      2) Hydrogen ....   	
      3) Nitrogen   _. .   	
      4) Oxygen ....  	 .
      5) Sulfur   	
      6) Halogens	    	
      7) Significant amounts of
            heavy metals 	
VIII.  Toxicity
      1) Skin irritant
      2) Eye irritant  	
      3) Sensitizer     	
      4) Inhalation hazard..
      5) Ingestion hazard	 ~
      6) Skin adsorption   	
 Yes	No_
 Yes	No_
 Yes	No_
. Yes	No-
. Yes	No-
. Yes	No-
  IX.  Environmental Pollution Potential
      1) Air
         a) Odor 	   	  Yes	No_
         b) Paniculate matter... .Yes	No_
         c) Photochemical
               reactivity 	    .. Yes	No_
         d) Vaporizes -.. ._   .— Yes	No_
      2) Water
         a) Biodegradable 	Yes	No_
                             b)  Ground water
                                   leaching ..    	Yes	No	
                             c)  Surface water runoff - Yes	No	
                             d)  Soluble . ..  	Yes	No	
                          3) Heavy metals present   . Yes	No	

                      X.  Explosiveness
                          1) Explosive limits
                             a)  Vapor
             From .
        b) Dust  	
    2)  Strong oxidant	
    3)  Shock-sensitive
    4)  Exothermic reaction ....

XI. Miicellaneous
    1)  Volume for disposal
    2)  Frequency of disposal
    3)  Containerized
        a) Size of container
    4)  Special handling
        a) Label	
        b) Transporting 	
        c) Solidifies while
             transported 	
        d) Disposal site 	
                                            -%LEL to .
                                                          _%UEL
                                                          _ox/f t3
.. Yes	No-
 Yes	No-
 Yes	No-
                                                      551

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TECHNICAL GUIDE
      SW-3
                A Guide for
                Incineration of
                Chemical Plant
                Wastes
    MANUFACTURING CHEMISTS ASSOCIATION
    1825 CONNECTICUT AVENUE. N W.
                     WASHINGTON, O. C. 20009

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The information  and recommendations contained in this publication have been compiled from
sources believed to be  reliable and to represent the best opinion  on the subject as  of  1974.
However, no warranty, guarantee, or representation is made by the Manufacturing Chemists Asso-
ciation as to the correctness or sufficiency of any information and representation contained herein,
and the Association assumes no responsibility in connection therewith; nor can it be assumed that
all necessary warnings and precautionary measures are contained in this publication, or that other
additional information or measures may not be required  or desirable  because of particular or
exceptional conditions or  circumstances, or because of applicable  federal, state or  local law.
                      )  1974 by Manufacturing Chemists' Association, Inc.
                                                5G3

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                 TECHNICAL  GUIDE   SW-3
A GUIDE  FOR INCINERATION OF CHEMICAL PLANT WASTES


The increasing restrictiveness of both national and local regulations governing solid waste disposal has made it
essential for producers of chemical products to:

     1.  Select equipment and processes for the incineration of certain chemical wastes that will assure compli-
        ance with all government regulations.

    2.   Provide guides for safe handling and proper disposal of their products.

Prepared by the MCA Solid Wastes Management Committee this paper is intended as a general guide in the
selection, design and operation of incinerating and needed auxiliary equipment to aid manufacturers in fulfilling
environmental responsibilities. The guide cannot obviate any real need for professional assistance.
                                   INTRODUCTION
  Incineration is one controlled combustion process
used in  the ultimate disposal of unusable organic
wastes resulting from chemical  manufacture.  Resi-
dues of these wastes, which become less toxic, less
hazardous and greatly reduced in volume as a result
of incineration, must usually be disposed of in a land-
fill.  When handled in this way, the residues have
a minimum impact on the environment.  Pyrolysis,
which is  thermal decomposition  in  an essentially
oxygen-free environment, breaks down organic wastes
into by-products having  further use or value; con-
sequently pyrolysis is not an ultimate disposal proc-
ess and is not considered in this discussion.

  It  is essential to  select carefully  equipment and
processes for the incineration of chemical wastes to
ensure that the basic obligations of safe handling
and proper ultimate disposal are met in a satisfactory
manner   In addition to  fulfilling social obligations,
an effective system should satisfy regulatory needs
with minimum adverse community reaction.

  Beginning  with the essentials for  characterizing
waste  for preliminary determinations on the feasi-
bility and manner of its incineration, this guide sug-
gests available choices of laboratory needs and equip-
ment for establishing feasibility on a pilot scale and
for controlling subsequent operation.  Choice of the
appropriate incinerating equipment must be made
from a broad range of equipment commercially avail-
able but often  built to specification.  The  descrip-
tions herein indicate their variety and some of their
capabilities.  Featured also is a selection of highly
specialized air  pollution  control  equipment often
required as auxiliary to incineration.  No attempt is
made  in this guide to cope with residues left over
after incineration, most of which should be appro-
priate  for landfill disposal.
                      I. WASTE  CHARACTERIZATION
A. WASTE DESIGNATION

     Waste designation is a preliminary grouping of
   similar waste materials according to their physi-
   cal  and chemical  properties to facilitate  their
   transportation,  handling,  blending, storage and
   disposal.

     Waste designation has application to both de-
   sign  and operation of an incineration facility.
   Designation may occur in rather broad  generic
   terms,  such  as  spent  caustic, water-treatment
   sludge, or scrap PVC. Since it is imperative that
   all parties concerned with generation and disposal
   of wastes thoroughly understand, each designa-
   tion must be made simple and fully descriptive.
     Each chemical plant should  develop a list of
   clearly defined wastes for designation. This list
   can be updated from time to time as needed, but

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Uthnieol
Guid.
SW-3
Manufacturing Chemists Association
   alterations should be made formally and with the
   knowledge of all concerned.  Once  the list has
   been established it becomes the responsibility of
   the  supplier  of the  waste material  to  see  that
   each container of  waste  material  is  properly
   identified before incineration. No material should
   be accepted for incineration which has not been
   designated or which has a designation that does
   not appear on the approved listing

      Generally, the designation and the definitions
   on  the designation  list  should suffice, but on
   occasion  the  operator   may  need  additional
   information.
B. PHYSICAL PROPERTIES

   1.  State—

         To further define  the handling character-
       istics  of  the  material one  must know with
       precision in what state it will be received as,
       for example.
       a.  Solids


       b.  Liquids or
             slurries


       c.  Gases



       d  Semi-solids
                  Dry material m powder,
                  granular, pelletized, or
                  bulk form.

                  Materials suitable for
                  pumping.

                  Materials in  a gaseous
                  state  at ambient  condi-
                  tions

                  Wet sohds capable of be-
                  ing handled as solids.

e.  Containerized . Materials which must be
                  handled in  a container,
                  such  as  a  steel  drum,
                  cardboard box, etc
   2.  Density  and/or Specific  Gravity—as re-
       ceived.
   3.  Viscosity—At an agreed upon  tempera-
       ture and by a specific method.


   4.  Solids,  °/Q by volume and weight.


   5.  Particle Size.


   6.  Flash point,     °F.


   7.  Moisture,   % by weight.

         Indicate if present as a second phase and
       to what extent.
                      8.  Melting  point  or melting point  range,
                            °
                  C. CHEMICAL PROPERTIES

                        The listing of all chemical  properties pertinent
                     to  an incineration  process potentially could be
                     extensive Since laboratory analyses can be costly
                     and  time  consuming, careful selection of  the
                     wastes and parameters for analysis is essential.
                     Full utilization should be made of available in-
                     formation in determining those analyses that are
                     needed to describe fully  the  chemical properties
                     of  the materials in question.   Some of the  more
                     common parameters are  listed below.

                      1   Gross  Heat of Combustion, B.t.u./Ib. on
                         an "as  received" basis.

                     2   Ash, ... % by weight

                           Ash  characteristics such  as fusion  point
                         and composition should be determined  if the
                         quantity of waste is significant.

                     3.  Ultimate analysis

                           This  analysis  may be  calculated in whole
                         or in part  through knowledge of the chem-
                         ical composition  of  the waste
                         a  Carbon

                         b  Hydrogen

                         c  Nitrogen

                         d.  Oxygen

                         e.  Sulfur

                         f.  Halogens
Needed for flue gas compo-
sition calculation
Needed  to  determine  air
pollutants.  May determine
the  need  for secondary
equipment  such as  scrub-
bers,  in  addition  to deter-
mining corrosivity
                      4.  Acidity or alkalinity

                      5.  Noncombustibles and metallic compounds

                           A complete scan of metals present is de-
                         sirable due to the variety  of responses that
                         can be  obtained  in an  incineration process,
                         such as:

                         a.  Particulates of submicron diameter  from
                             volatile  salts and oxides (Sodmm, Phos-
                             phorus, etc )

                         b.  Low ash  fusion  temperature (Sodium,
                             Iron, etc.)
                                                   5G5

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                                  Manufacturing Chemists Association
                                                                                           Twhnkgl
                                                                                           Guid.
                                                                                           SW.3
       c  Refractory  attack  (Sodium,  Lead, Va-
          nadium, etc.)
       d  Toxic  products  in  effluents (Mercury,
          Arsenic, etc.)

    6.  Exposure hazards
       a.  Vapor exposure
       b.  Liquid contact
       c.  Suspended dust

    7.  Chemical reactivity—Particularly perti-
       nent where wastes may be blended
       a.  With water
   b.  With other organics

   c.  Polymerization potential

8. Special characteristics or hazards

   a.  Fuming

   b.  Odor

   c.  Thermal stability

   d.  Pyrophoric properties

   e.  Shock sensitivity

   f.  Chemical stability
       II.  LABORATORY  AND BENCH  SCALE  EQUIPMENT
A. LABORATORY  REQUIREMENTS FOR
   ANALYSES  OF  CHEMICAL WASTES

      Analytical  data should tje made available for
   all wastes to  be incinerated.  The physical and
   chemical properties and  the combustion charac-
   teristics of each chemical waste or general classi-
   fication of wastes, should be determined before
   incineration.  Only after such analysis can suc-
   cessful waste  disposal be carried out safely and
   without violation of air or water pollution regu-
   lations as set  forth by state and federal agencies.

      A minimum  but complete laboratory facility
   would  require a working area, including  office
   facilities, of about 2,400 sq. ft  Provision must
   be made for air, water, gas, and electricity, pref-
   erably  both AC and  DC  The laboratory furni-
   ture must include  benches,  sinks,  fume hood,
   shelving, glassware racks  and a refrigerator. Good
   lighting and air-conditioning are also important.

B. LABORATORY EQUIPMENT  FOR
   CHEMICAL  WASTES  ANALYSES
   NEEDED FOR CHARACTERIZATION

   Identification  of laboratory equipment needed for
   analyses of  chemical wastes  follows.  Specific
   requirements depend on the types of wastes to be
   processed and  the type  of incinerator.  If  the
   equipment for  sophisticated analytical methods
   is not  available in house, the  analyses can be
   performed economically by commercial analytical
   laboratories.

   1.  Typical  laboratory  equipment  to  deter-
       mine physical properties.

       a.  Specific  gravity balance—specific gravity
          of liquids.
   b.  Brookfield viscosimeter—viscosity meas-
       urement of liquids and sludges.

   c.  Imhoff cones and centrifuge with gradu-
       ated tubes—measurement of percent sol-
       ids by volume.

   d.  Sieving machine for  screen analysis (to
       100 micron) and HIAC particle counter
       (100-5 micron)—particle  size measure-
       ment.

   e.  Cleveland open cup  flash point tester—
       flash and fire point determinations.

   f.  Oven and balances—percent solids and
       moisture by weight.

   g   Gas chromatograph—mass  spectrometry
       and infrared apparatus to identify organic
       substances which may be toxic.

   h.  Differential thermal analyzer—explosion
       characteristics and fusion temperature.

   i.   Juno meter or equivalent—sensitive to
       alpha,  beta and gamma rays for  radio-
       activity.

2.  Laboratory  equipment  to  determine
   chemical properties.

   a.  Muffle furnace, oven, balances—for per-
       cent ash by weight.

   b.  Orsat, x-ray techniques for flue gas analy-
       ses to  provide data for excess air calcu-
       lations.

   c.  pH meter and automatic titrator—acidity
       and alkalinity measurement.

   d. Emission spectrograph for  concentration
       and presence of metals.

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Aionufacfuring Chemist Association
       e.  Atomic absorption spectrograph for con-
          centration of metals.

       f.  Optical microscope for paniculate char-
          acterization down to the sub-micron size.
          Electron microscope may be required for
          some sub-micron determinations.

    3.  Laboratory equipment to determine com-
       bustion properties.

       a.  Calorimeter for heating value and com-
          bustibility.

       b.  Orsat  (previously  listed) for CO,, CO,
          O2, H2 and N2 analysis.

       c. Flue gas  analyzer  (previously listed)  for
          analysis at various excess air rates.

       d.  Mass spectrometer (previously listed)  for
          hazardous products of combustion
                  C.  BENCH  SCALE  EQUIPMENT
                       Reliable bench  scale  chemical incineration
                     equipment is generally unavailable. The present
                     practice appears to follow the line of waste char-
                     acterization, physical, chemical and  combusti-
                     bility  analysis  followed by a test  burn in  pilot
                     or plant scale equipment.

                  D.  CHEMICAL WASTES  "TEST BURN"
                       Following the  physical/chemical/combustion
                     analysis,  it is extremely  important that a  "test
                     burn" be run on a particular waste or type of
                     waste  to review  the combustion products,  flue
                     gas  analysis, emission paniculate size, excess air
                     requirements, and flammabihty rate. These  "test
                     burns" are most  valid when conducted in plant
                     scale  equipment  of the  type proposed for the
                     incineration of the  particular chemical waste or
                     wastes in question.
                       III.  INCINERATION  EQUIPMENT
A. Incineration is often the most desirable method
   of treating the waste or by-products of a chemical
   process as  this method has  a minimum impact
   upon the environment.  The incinerators avail-
   able for this  service are generally more special-
   ized than those used in  municipal  or general
   refuse  service. Different types of chemical plant
   refuse, such  as combustible  types of packaging
   materials, plastic film and foam, polymers,  and
   fibers may  be handled in a municipal type in-
   cineration operation under certain circumstances
   Various parameters,  such  as environmental im-
   pact, degree  of halogenation,  gross weight  and
   physical form must be discussed  in detail with
   the municipal authorities  before any  material is
   sent for disposal.  Many chemical plant wastes,
   however, fall into  the category  of  hazardous
   materials and require handling, incineration,  and
   gas cleaning equipment specifically suited  to the
   materials to be handled.
      The following is a list of incinerator types  and
   and factors which are important in their selection
   and performance.  The outline is general as each
   specific application  should be considered indi-
   vidually taking into account unique design  and
   engineering problems.  Incinerators can be  classi-
   fied into certain categories:

   AA. INCINERATOR TYPES
         1.  Fixed bed incinerators
            a.  Open pit burning or incineration
                (unacceptable under many air pol-
                lution codes).
                              b.  Closed chamber burning.

                                  i. Single chamber.

                                 ii. Multiple chambers.

                              c.  Tray furnace incinerators.

                          2.  Moving bed incinerators

                              a.  Rotary tube or kiln.

                              b.  Fluid bed.

                              c.  Moving grate.

                              d.  Rotary hearth.

                              e.  Rotating rabble arms.

                     AB.  CAPACITY OF  CHEMICAL
                          INCINERATORS

                             The capacity and ability of the chemical
                          incinerators to handle  specific  chemical
                          wastes  will depend  upon the  following
                          factors:

                          1.  Size of  unit  selected,  B.t.u./br.
                              input

                              a.  Turndown ratio (maximum to min-
                                 imum operating range).

                              b.  Operating temperatures.

                              c.  Retention time.

                              d.  Physical size of charge.

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                                    Manufacturing Chemists Association
                                       Technical
                                       Guide
                                       SW-3
         2.  Physical form of feed

             a.  Liquid

                 i. viscosity.

                li. temperature.

             b.  Solids

                 i. powdered or granular.

                ii. bulk.

             c.  Semi-solids.

             d.  Gases.

         3.  Method  of feeding  to combustion
             zone

             a.  Batch

                 i. open charging.

                11. air lock feeders

             b.  Continuous.

         4   Combustion properties of materials
             being incinerated

             a.  Heat value, B.t.u./lb. as processed

             b.  Rate of combustion.

             c.  Combustion air requirements.

             d.  Supplemental fuel requirement.

             e.  Chemical  stability  and/or shock
                sensitivity.

B. Several types of  incinerators which appear to
   have the greatest application in industrial wastes
   are described in the following section. The listing
   is not intended to be  comprehensive; it  is merely
   representative of the  major types available.

   1.  Solid  Stationary  Hearth   (Solids Incin-
       eration )

       a.  Uses and Advantages

            i. Low capital.

           ii. Potential of tight air  control with an
              airlock feeder.

           iii. Can be designed to  include liquid
              incineration.

       b.  Limitations and Disadvantages

            i. No turbulence, mixing or aeration.

           ii. Slow burning rates.
       iii. Batch operation.

       iv. Manual ash removal.

        v. Does not lend itself to good air pol-
          lution control.

      Since  refuse, charged  onto a solid hearth,
   tends to accumulate m a pile and burn only
   on the surface, complete  combustion is dim-
   cult to achieve.  To assure complete  com-
   bustion,  industrial solid  wastes normally re-
   quire constant agitation  to allow oxygen  to
   reach  all areas.  Manual  agitation  is likely
   to be tedious and may be unsafe.

      Ash  removal  from  the  solid stationary
   hearth is usually a hand batch operation This
   is  often  unsafe  and  disrupts  any attempt
   toward smooth operation of either the com-
   bustion operation or pollution control

      The combustion chamber must be properly
   sized to allow flame space for complete com-
   bustion,  refractory  protection,  and adequate
   temperature  control  over the  desired  feed
   range  Proper design of the air pollution con-
   trol system,  fuel controls,  and  air controls
   can improve the operating  turndown  ratio

2.  Solid Hearth (Rotary Hearth or Rotating
   Rabble Arms )

      Principles  and applications  of  both  the
   solid rotary  hearth with fixed rabble arms
   and the fixed circular hearth with rotating
   rabble arms are very similar.

   a.  Uses and A dvantages

        i. Continuous ash discharge.

        ii. Capable of incinerating waste solids
          independently  or liquids and solids,
          in combination.

       iii. Widest practical  turn  down  ratio.
          (Maximum   to  minimum  operating
          range )

       iv. Incinerating  materials  will  not  fall
          through  hearth.

        v. Adaptable for use with a gas scrub-
          bing system.

   b.  Limitations and Disadvantages

        i  Rabble arms or plows are susceptible
          to damage.

        ii. Limited turbulence and air contact.

       in. Partly combusted materials may flow
          out ash discharge.

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Manufacturing Chemists Association
          iv. Solid wastes fed at intervals. An air
              lock system should be used to im-
              prove combustion  characteristics and
              control.

           v. Arched,  self-supported  multiple
              hearths of refractories are vulnerable
              to abrupt temperature variations with
              resultant downtime and cost increases

         While incinerating solids, the rotary hearth
       can incinerate  essentially  any  liquid  waste
       capable of being fed to a stationary liquid tar
       burner.   The combustion  chamber  must be
       properly sized to permit  complete  combus-
       tion,  minimize flame  impingement on  re-
       fractories, and provide adequate temperature
       control  over the desired feed range. Liquid
       burners are normally positioned to aid com-
       bustion  of solid wastes. An adequate supply
       of solids on the hearth is  needed  for  flame
       impingement  protection.  Protection of the
       rabble arms must also  be considered

         No air for combustion or turbulence passes
       up through the bottom hearth.  All  air must
       be supplied from above or through the rabble
       arm plows  Even with the use of rabble  arms,
       turbulence and air  contact is limited  The
       burning rate may range from 8 to 15 pounds
       per square foot per hour depending on the
       solids being incinerated.

         Rabble arms are normally  air cooled to
       protect  them from  heat  damage  and help
       supply some of the combustion air require-
       ments Rabble arms require continuous main-
       tenance and need periodic repair or replace-
       ment.   The solid  refuse must, therefore,  be
       free of large heavy items such as metal drums
       or metal  rings,  which would  damage the
       rabble arms

         Rotary hearths are  commonly used to in-
       cinerate sludges and granular material These
       materials will not fall  through the hearth as
       they would through  a  grating  If the heated
       solids  melt some material  may  flow through
       the center discharge before it  is completely
       incinerated.

         The stationary hearth with rotating rabble
       arms may be built with multiple hearths to
       provide  more capacity, residence time, and
       complete combustion   An  advantage of the
       rotating hearth with a ram feed is  that this
       device will allow solids to  move away  from
       the feed area  and partly  burn before con-
       tacting the rabble arms.  Stationary rabble
       arms can be of simpler, stronger design, thus,
                         the cost, time, and frequency of maintenance
                         are reduced.

                           In  some specialized applications,  such as
                         tire destruction,  the  rotary  hearth  is  used
                         without rabble arms.

                      3.  Crate Hearth

                         a.   Uses and Advantages

                              i. Provides under fire  air to aid com-
                                bustion.

                             11. Allows ash  removal  through grating

                             iii. Can be  designed  to forward  solids
                                through the incineration system.

                             iv  Does not  require   extensive  waste
                                preparation, i.e. shredding.

                         b.   Limitations and Disadvantages

                             i. Limited turbulence for air contact.

                             li. Solids may fall through grating before
                                complete burn out.

                             iii  Plastics or melt phase materials may
                                damage grates.

                           Traveling or reciprocating grates work well
                         with raw municipal refuse.  However,  many
                         industrial wastes tend to  fall through  the
                         open  gratings.  Plastics  and other industrial
                         wastes which form a melt phase tend to flow
                         through  and around  the grating.  This  can
                         jam the grate drive  mechanism or cause high
                         temperature damage as  the  wastes burn di-
                         rectly on the grates

                           In  this equipment, solid wastes are  not
                         tumbled  violently and may burn only on the
                         surface   With many  industrial solids, com-
                         plete combustion may not be achieved

                           The high temperatures and abrasive action
                         on  the  moving  grate increase maintenance
                         costs.  Drive mechanisms and grates require
                         periodic  repair or replacement.

                      4.  Rotary Kiln

                         a.   Uses and Advantages

                               i.  Will incinerate  a  wide  variety  of
                                 liquid and solid wastes.

                              ii  Capable  of  receiving liquids  and
                                 solids  independently  or  in  com-
                                 bination.

                             iii.  Not hampered by materials passing
                                 through a melt phase
                                                    063

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                             Manufacturing Chemists Association
                                   T«hnkol
                                   GiiM.
                                   SW-3
     iv. Feed capability for drums and bulk
        containers.

     v. Wide  flexibility  in  feed mechanism
        design.

     vi. Provides high turbulence and air ex-
        posure of solid wastes.

    vii. Long  inventory time for slow burn-
        ing refuse.

   viii. Continuous ash discharge.

     ix. No moving parts within the kiln.

     x. Adaptable for  use  with a wet gas
        scrubbing system.

b. Limitations and Disadvantages

      i. High capital cost installation for low
        feed rates.

     ii. Cannot utilize  suspended  brick  in
        kiln.

     iii. Operating care  necessary to prevent
        refractory damage.

     iv. Airborne particles  may be carried
        out of  kiln  before complete com-
        bustion.

     v. Spherical or  cylindrical items may
        roll through  kiln before  complete
        combustion.

     vi. Kiln incinerators frequently require
        excess air intake to operate  due to
        air leakage into the kiln via the kiln
        end  seals  and  feed  chute,   which
        lowers fuel efficiency.

    vii. Drying or ignition grates,  if  used
        prior  to the  rotary kiln, can cause
        problems  with  plastics melt plug-
        ging grates and  grate mechanisms.

  The rotary  kiln provides  the design flexi-
bility for  incineration of a wide variety of
liquid and solid industrial wastes. Any burn-
able  liquid  capable   of  being  atomized  by
steam or air through  a burner nozzle  can be
incinerated concurrently with a wide range
of industrial solids. Heavy  tars may  be fed
as solid waste  in packs or metal drums. The
kiln  can be  designed to receive  55-gallon
drums, or a feed mechanism can be designed
to empty the drum and retain  it.  It  is also
capable of handling  pallets,  plastics,  filter
cakes, and other solid  chemicals  passing
through a liquid phase before combustion.
  The  rotary  kiln  provides  a  maximum
amount of turbulence,  agitation, and surface
air  contact to  achieve  complete  burnout.
Complete combustion of slow burning refuse
is aided by a relatively long inventory time
in  the combustion chamber.  Ash discharge
is continuous.  Roll  through of spherical or
cylindrical items would  normally be  pre-
vented  by the  other solid  refuse being in-
cinerated.  Normal kiln operation would not
be expected to incinerate such items as metal
drums.

  However, a metal drum may be melted or
deformed, depending primarily upon its con-
tents  and the ash conveyor system must be
designed to remove  such items.

  Since the drive mechanism is outside the
kiln, maintenance is low. There are no in-
ternal  moving  parts such  as  rabble  arms,
grates, or plows.

  Care must be exercised in determining kiln
size to provide for adequate accommodation
of solid wastes  and maximize refractory life.
As the  kiln size decreases, the unit becomes
increasingly sensitive to excessive heat release
and temperature control  becomes more diffi-
cult.

  The rotary kiln is a high capital  installa-
tion  and  would not be considered practical
for very low feed rates.  Practical sizes are
limited.  At a  minimum, sufficient capacity
must  be provided to accommodate the feed
packages such as drums or packs and prevent
flame impingement  on the  refractory when
liquid wastes are incinerated.  The maximum
size  is  determined  by turndown  problems,
operating  costs,  maintenance  of a  proper
combustion temperature, and construction-
fabrication  costs. Turndown, the ratio of
maximum to minimum  thermal  capability,
represents a problem  due  to leakage  of air
through the system.

  Since the  rotary motion  of the  kiln pre-
cludes the use of suspended brick, the re-
fractory is more susceptible  to thermal shock
damage.  For this reason, continuous opera-
tion  should be maintained as much as pos-
sible.  Rebricking of the hottest part of the
kiln can be anticipated on roughly an annual
basis.   Therefore, it  is  often advisable to
maintain an inventory of kiln refractory and
refractory for  multiple  hearth furnaces in
protected storage.
                                                 500

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         Airborne  particles may be carried out of
       the kiln before complete combustion. A high-
       temperature  secondary combustion  chamber
       with intimate flame contact is  normally re-
       quired for complete burn-out.  The fuel for
       the secondary combustion chamber should
       be dependable high quality waste liquid or
       commercial fuel.


   5.  Fluid Bed

       a.  Vses and Advantages

            i. Capable  of incinerating a moderate
              range of liquid and solid wastes.

           ii. Rapid heat transfer from gas to solid.

          iii. High combustion rate.  High  turbu-
              lence and air exposure.

          iv. Low  excess air requirement.

           v. Large heat sink to smooth out fluctu-
              ations in feed rate or fuel value.

       b.  Limitations and Disadvantages

            i. Requires  fluid  bed preparation and
              maintenance.

           ii. Feed selection must avoid bed damage.

          iii. May  require  special operating  pro-
              cedures to avoid bed damage.

          iv. Incineration temperatures limited to a
              maximum of about 1500°F.

         Fluid bed incinerators may be designed to
       expose wastes to a hot fluid bed several feet
       deep with high turbulence and good air con-
       tact  for rapid complete combustion   Burn
       out may be accomplished with  as low as
       20 percent  excess air, which  will provide
       operating  economy because of low  power
       requirements, less air  to heat  and  flue gas
       to clean.

         Fluid bed incineration  appears most ad-
       vantageous when the bed can  be formed as
       a natural  product of  the  refuse being in-
       cinerated,  especially if  the refuse has a high
       ash content;  otherwise  the  bed  must be fre-
       quently replaced.  Low ash, highly volatile
       compounds such  as wet coffee grounds appear
       to have good incineration application.

         Fluid bed particles  may be temperature
       and composition  sensitive. Eutectic mixtures
                         may be formed which will destroy the bed
                         fluidization.  Some beds may be  very sus-
                         ceptible to caking during shutdown.


                      6.  Stationary Liquid Waste Burner

                         a.  Uses and Advantages

                              i.   Capable of incinerating a wide range
                                of liquid wastes.

                             ii. May use suspended brick.

                             iii. No continuous ash removal  system
                                required other than air pollution con-
                                trols.


                         b.  Limitations and Disadvantages

                              i. Must be  able to  atomize tars  or
                                liquids through a burner nozzle except
                                for certain limited  applications

                             ii. Heat content of liquids must maintain
                                adequate  temperatures or  a  supple-
                                mental fuel must be provided.

                             iii  Must provide  for  complete combus-
                                tion and prevent  flame impingement
                                on refractory.

                           A wide range  of industrial liquid  wastes
                         may be incinerated provided the heating value
                         is sufficient to maintain temperature for com-
                         plete  combustion.  When  a low-heat-value
                         liquid is incinerated, it musf be blended with
                         a liquid of higher heat value or auxiliary fuel
                         will be required.  The tar must be atomized
                         through a burner nozzle by air, steam,  or me-
                         chanical means.  However, mechanical atomi-
                         zation  is  normally avoided because  of  the
                         high pressure requirement and the wide range
                         of liquid viscosities.

                           Since there are no moving sections, sus-
                         pended, air-tempered  brick may be utilized.
                         This may contribute to longer life and lower
                         maintenance.

                           The ash is essentially all gas-borne parti-
                         cles.  Ash will  normally  be removed by  an
                         appropriate air  pollution  control  system.
                         Because a certain amount of particulate will
                         drop out  within  the  incinerator,  occasional
                         shutdown and cleanout is necessary. Depend-
                         ing on the tar burned,  cleanout  may  be
                         required  at about  six-month intervals.

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                                  Manufacturing Chemists Association
                                T.thnitol
                                Guid.
                                SW-3
             IV.  AIR  POLLUTION  CONTROL  EQUIPMENT
A. The pollution control  equipment used in con-
   junction with the various basic types of chemical
   incinerators,  or  one of their many  variations,
   can be classified by type.  Again, specific selec-
   tion is dependent upon individual requirements
   and represents a unique design  and engineering
   problem.

      The four  major  factors in the selection of
   control  equipment are paniculate loading  and
   size distribution, volume and temperature of gas
   to be handled, solubility of flue gas contaminants
   in water or scrubbing fluid, and  emission speci-
   fications  established by the regulatory agencies.

      Much of the air  pollution  control equipment
   available  is  effective  for  removing  only large
   paniculate matter; that is, particles greater than
   several  microns  m  diameter.  Emissions from
   chemical  waste  incineration  are  almost  exclu-
   sively in the submicron size range, many smaller
   than 0.1 microns

      Control of such emissions,  to  meet air pollu-
   tion codes, requires  the  use  of  high efficiency
   collection devices. The various  types of avail-
   able pollution control  equipment are listed by
   criteria of particle size capture ability.

   AA.  AIR POLLUTION CONTROL
         EQUIPMENT

         1.  Afterburners

             a.  Flue gas combustibles

                i.  Carbon particulates.

                ii.  Organic particulates.

             b.  Flue gas deodorizing

                i.  Mercaptans.

                ii  Odors  from low temperature
                   exit gases  following a low en-
                   ergy water scrubber.

         2.   Low  efficiency  collection,  greater
             than 10-20  microns size  range.

             a.  Mechanical cyclones, inertial  sep-
                arators.

             b.  Low pressure drop wet scrubbers.

                 i. Impingement baffles.
                ii. Spray chambers.

                hi. Packed bed.

                iv. Sieve  tray.
3. High efficiency  collection from  5
   microns to  less than  0.1 microns
   size range.

   a.  Electrostatic precipitators

        i. Dry type.

          aa.  No capability for removing
              acid gas from halogenated
              wastes in single stage form.

       ii. Wet types.

          aa.  Use in  moderately corro-
              sive service  with alkaline
              flushing water

          ab.  Requires corrosion resistant
              material of construction.

          ac.  Requires pollution control
              of scrubber  blowdown or
              discharge

   b.  High energy ventun scrubbers

        i. Removes  water   soluble   acid
          gases.

       ii. Can be fabricated of corrosion
          resistant materials.

       iii  Paniculate removal efficiency,
          particle size can be varied to
          suit from 0 1 to  5 microns de-
          pending inversely upon energy
          input (pressure drops of 60"—
          1CI" water gauge.)

       iv. Most commonly  used high effi-
          ciency air pollution control sys-
          tem on incinerators.

       v. Requires  pollution  control of
          scrubber  blowdown  or  dis-
          charge.

   c.  Fabric filters

        i. High paniculate  collection effi-
          ciency.

       ii. Low  temperatures  required,
          300-400°F maximum.

       iii. Ineffective on gaseous  pollu-
          tants.

       iv. Requires dry inlet gas to  filter.

       v. Sensitive to corrosive environ-
          ments.
                                                      5S2

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Technical
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Manufacturing Chemists Association
                                         V.  REFERENCES
 I.  "Air Pollution Engineering Manual " US. Department
    of  Health, Education, and Welfare,  Public  Health
    Service, Bureau of Disease  Prevention, Environmental
    Control,  National  Center  for  Air  Pollution Control,
    Cincinnati, Ohio  1967.

 2.  "Hazardous Chemicals Handling and Disposal " Noyes
    Data Corporation,  Noyes Building, Park  Ridge, New
    Jersey  07656   1970.  A collection of papers presented
    at the  1970 Symposium of the Institute  of  Advanced
    Sanitation Research International. Noyes Data  Corpo-
    ration, ($15.00).

 3.  "Proceedings of 1970 National Incinerator Conference,"
    Cincinnati, Ohio  The American Society of Mechanical
    Engineers, United  Engineering  Center, 345  East 47th
    Street,  New York, N Y  10017  May  17-20,  1970.
    Proceedings available for other conference years.

 4.  Novak, Rudy G , The Dow Chemical Company, Mid-
    land, Michigan. "Elimination or Disposal of Industrial
    Solid Waste." October 5, 1970  Chemical  Engineering

 5  Englund, H. M and Beery,  W  T "Proceedings of  the
    Second International  Clean  Air Congress "  Academic
    Press, New York and London  19717.

 6.  Sawinski, Richard  J  and Wilson, J  David,  The Dow
    Chemical  Company,  Midland,  Mich   "Evaluation of
    Combustion Gases  From Industrial Incineration." May
    16-19,  1971  Paper presented to the American Institute
    of Chemical Engineers, Cincinnati, Ohio

 7.  "Background  Information  for  Proposed  Nero-Source
    Standards   Steam  Generators,  Incinerators,  Portland
    Cement Plants,  Nitric  Acid  Plants,  Sulfunc Acid
    Plants." U S  Environmental Protection Agency, Office
                        of Air Programs, Research Triangle Park, North Caro-
                        lina  August, 1971.

                     8, "Standards of Performance for New Stationary Sources."
                        U S  Environmental Protection Agency,  Federal  Reg-
                        ister, Washington, D.C Thursday, December 23, 1971.
                        Volume 36, No. 247.

                     9  Cheremismoff, Paul M   and  Rao, K  R.,  Engelhard
                        Industries, Division of  Engelhard Minerals & Chemicals
                        Corp,  205  Grant Avenue,  E.  Newark,  New Jersey
                        07029  "Fluid Bed Incineration "  March, 1972.

                    10. Heimburg, R  W,  Colella,  R. A., Jones, D, Rausch,
                        J H,, Macrina, M.  Hon., P.  K , Fisher, H  E., Joyce, R
                        "Incineration of Plastics Found in Municipal Wastes "
                        Prepared for the Office of Solid Wastes, Environmental
                        Protection Agency. Research Grant No EC00304  Life
                        Sciences Division,  Syracuse University Research Corps ,
                        Merrill Lane, University Heights, Syracuse, New York
                        13200. June 25, 1972.

                    11  "Air  Pollution  Engineering  Manual." U S  Environ-
                        mental Protection  Agency,  Office of  Air and Water
                        Programs, Office of Air  Quality  Planning and Stand-
                        ards, Research Triangle  Park, Norlh Carolina 27711.
                        May, 1973. Second Edition.

                    12  "Nationwide Air Pollutant Emission Trends 1940-1970.
                        U S  Environmental Protection Agency,  Office of  Air
                        and Water Programs,  Office of  Air Quality Planning
                        and Standards, Research Triangle  Park, North Carolina
                        27711. January, 1973.

                    13  Lmdsley, John M, Eastman Kodak  Company, Ro-
                        chester, New York  Personal files  December, 1973.

                    14. Novak, Rudy G, The Dow Chemical Company, Mid-
                        land, Michigan  Personal  files December, 1973
                                                                                                PRINTED IN U S A
                                                              £53

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          MR. LEHMAN:  Thank you Mr. Bridge.  Are




there any questions?




               Perhaps for the benefit of the




audience those of you who were not here this morning,




we accept questions from the audience, all you have




to do is raise your hand and one of our staff will




provide you with a 3 by 5 card upon which you can




raise your question.




               But before we go into questions I have




an urgent message for Dean Gray.  That will be up



at the front of the desk.




               Now, Mr. Kovalick.




          MR. KOVALICK:  Mr. Bridge, could I refer




to the closing part of your statement where you




mentioned the placarding or labeling of waste




shipments which I recall are Title 46 and 49 and




part of the Department of Transportation regulations,

-------
so you're  saying  that  labeling  and  placarding of




containers  and  that  all  are  sufficient  within the




context of  DOT.




                I  am wondering how you compare that




statement with  your  other  one,  that  generators




should adequately  describe the  waste so that  the




treater/disposers  are  aware  of  the  properties.




At least our understanding of DOT regs, and we had




some comments in  Newark, that it's  not  sufficient




information on  the label,  that  is a  label  that just




says corrosive  or  a label  that  just  says flammable—




"it's not enough  to meet  the needs  of the treater or the



disposer of the waste.




                And you are talking  about the  person




who has to  transport it.




          MR. BRIDGE:  Yes,  there's  a difference




there, and  I'll refer  you to our MCA guide on



waste disposal, which  covers the subject very ade-




quately.  Because we are really concerned  about



the medium  in which you are trying to relay that




information.




          MR. KOVALICK:  Would  you submit  that to




us please?




          MR. BRIDGE:  Yes,  I have already  submitted  it.

-------
           MR. KOVALICK:   Oh,  it's  one  of  these




 three things, all right.




                Thank you.




                Now the other  question  I have  had




 to do with referring to Mr, Eby' s  comments  this




 morning, and you seem to  be advocating the  same




 type of system.  That is  the  generator is very




 responsible at the beginning  of  the  cycle,  and




 that the transporter is responsible  and is  well




 licensed, in his work, and the treater is also




 licensed or at least controlled  in their  work.




     I still don't understand  how waste is permitted




from  not going to one of the proper places and going




 to an improper place, as  you  seem  to be saying with




 the current regulatory approaches  as sufficient-



 What    is to prevent waste from a responsible



 manufacturer, to make it different  from perhaps




 less than a responsible transporter,  and  ending up




 at less than a responsible disposal  site?




           MR. BRIDGE:  I  think there is a bit of




 misunderstanding of my remarks.  We  are saying as




 fat as the generation or transportation  and handling of




 these types of wastes are conserved, we  were wnrripri ahnnt the



 actual physical type of transportation, and we feel

-------
there are sufficient regulations.




               Now as far  as the ultimate  disposal




of the material, MCA does  share some concern   but




there are some areas here  that do  need  attention.




How this can be accomplished -- there are  probably




several ways with the permit system.




               The permit  system is one way  that




has been mentioned to accomplish this thing,  but



in the past the MCA position on this  was we wanted an




actual disposal site permit.




          MR. KOVALICK:  Perhaps I'm not making my




point well enough.  What is to prevent  the waste




from not reaching a licensed permit disposal  site,




or reaching the kind of farmer's land you heard




about this morning?




               An unregulated site like that.




If you have some suggestions to prevent that,



that's what I'm interested in.




          MR. BRIDGE:  I don't know that I can answer




that question.




               As you well know, waste can be




transferred to a very reputable individual but for




one reason or another it might not reach the  desired




destination.





                        &S7

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          MR. LEHMAN:  Are there any other questions?




Mr. Lazar.




          MR. LAZAR:  Mr. Bridge, your MCA's recommended




definition of hazardous waste I see is restricted to




land disposal.  Wouldn't you say though that incinera-




tion of a toxic waste like dioxin as we heard before




could also cause a problem and therefore should also




be called hazardous as a waste which could be disposed




of by other means.




          MR. BRIDGE:  Sir, I think that your comment




takes us back to the MCA position as far as hazardous




waste is concerned.  Not only in the characteristics



and material of the waste itself, but we are concerned




primarily with the ultimate disposal.




               We would be concerned with the residues




of the operation, and their disposal to the land.




          MR. LAZAR:  But you would not call a waste




hazardous, I mean before it becomes a residue, if it




is a waste which is destined for an incinerator,




that you would not define as hazardous waste?




          MR. BRIDGE:  I would not define it --




this gets us back into  semantics.   And this goes




across a wide band of the environment.  I would




 term that waste as hazardous  as any type of waste

-------
you might consider  for  incineration,  landfill or




what have you.




               That waste  remains  potentially




hazardous and hopefully going  into the  incineration




process it will  lose the characteristics  that make




it potentially hazardous.   And  you have essentially




an inert residue to fill.




          MR. LEHMAN:   Do  you  have any  other  questions?




Evidently not.  Thank you  very  much Mr. Bridge.




               Next I would like to call  Mr.  pat




Born, Minnesota  Pollution  Control Agency.   Mr.  Born.




          MR. PAT BORN:  Thank  you Mr.  Lehman.




               My name  is  Patrick  Born, I'm with




the solid waste  division of the Minnesota Pollution




Control Agency.




               We like  the Illinois Environmental




Protection Agency are the  principal state environmental




advocate.




               Over the  course  of the  past several




years, the Minnesota Pollution  Control Agency in




coordination with the County units of government




has been developing a program to manage the state's




hazardous wastes.




               The question  with which we  ars cnnfr-onted  is

-------
not whether a hazardous waste problem exists  but




rather how best to manage the problem that we




know exists.




               As technology and government regulatory




programs are implemented the removal of pollution




from the air and water discharges will increase at




an  accelerated   rate.  One result is that the




pollutants  will become concentrated in solid  or




semi-solid form.




               Disposal of these residues is  adding




a new dimension to the management of industrial




hazardous wastes.




               Perhaps the most important question




which is being asked of us today is how best  can



we manage this nation's hazardous wastes.  We  in



Minnesota have enabling legislation to manage  the




identification, labeling, classification, storage,




transportation, treatment and disposal of hazardous




wastes.




               Federal legislation and control is




needed also.  The best combination being the




establishment of Federal  standards with the states




acting as the implementing body.




               We in Minnesota feel Federal  standards
                           €00

-------
should be prepared to  address  the  following




concerns.




               Number  one,  development  of  national




identification and classification  standards  to




uniformly determine what constitutes  a  hazardous




waste.




               Number  two,  governmental incentives




to encourage private industry  to expand, improve




and construct new hazardous waste  processing




facilities.




               Number  three, the government  --




development of a national standard  for  the transporta-




tion  of hazardous wastes.




               And number four, development  of  national-




directives for state implementation of  hazardous



waste control programs which will  monitor  hazardous




waste from a point of  generation to the point of




final processing and disposal.




               Staff of the Minnesota Pollution




Control Agency offer the following recommendations




on these concerns.




               Number  one, development  of  national




identification and classification  standards  to




uniformly determine what constitutes  a  hazardous

-------
waste .



               The United States Environmental Protection




Agency should develop a national  identification




standard for hazardous waste materials.  This




standard should be in the form of a decision model




as opposed to a list of hazardous waste materials.



               The advantages or a decision model




standard are the following.  (A)  administrative




procedures are less burdensome, ®  a decision  model




allows flexibility to address new wastes, (0  a




decision model is more defensible on a rational




basis, and (D) recognizes that no wastes are alike.




               A Federal standardized decision




model would confront the problem of establishing




defensible threshhold limits and reviewing wastes




as complex mixtures of chemicals.  Any standard




should allow individual states to develop more




restrictive standards to address the unique con-




ditions in their respective states.




               There may also be  a need for the




U.S. Environmental protection Agency to address




performance standards which must be met by various




chemical treatment or disposal methods.




               Number two, governmental incentives








                           6U2

-------
to encourage private industry to expand, improve




and construct new hazardous waste processing




facilities.




               A variety of methods to dispose




of hazardous wastes are available.  Recovery or




reclamation of valuable components of the waste




should be the disposal method first assessed.




               Not all hazardous wastes are • compatible




with recycling methods however.  A secondary method




of disposal is incineration, and  is one for which




there is considerable need for further study.




               The final method of disposal to be




considered is that of land disposal.  Land disposal




of hazardous wastes should be conceptualized as




long term storage with zero discharge to the surrounding




environment.




               And hazardous wastes which are land



disposed may prove to be valuable future resources.




               There are not enough existing facilities




to treat or dispose of hazardous wastes.  For those




existing facilities relatively few are in full com-




pliance with all pollution control standards.




               It is essential that the  Federal




government in its review of hazardous waste management
                         6U3

-------
programs identify methods of helping the existing




hazardous waste industry to expand and improve its




facilities.




               The following problems for private




industry in the area of hazardous waste seem to be




most  prevalent.




               Number one, high capital costs with




relatively low rates of return being realized.




               O  difficulty in obtaining financing.




               (Q  high interest rates.




               !Di  inequitable treatment of secondary




materials industry.




              (B  lack of proven technology in field




operations.



              (R  lack of effective control programs




to direct hazardous wastes to suitable processing




disposal facilities, which results in a high risk




to the private disposal firms.




               Number three, development of a national




standard for the transportation of hazardous waste.




A concern which is rapidly becoming serious is the




interstate transport of hazardous wastes.




               The Minnesota program requires a




Minnesota generator to provide documentation to
                         $'0*4

-------
our agency that the state in which the waste is




to be disposed has approved the acceptance of the




waste by a state licensing facility.




               The fact that interstate shipment of




a waste is continuing to occur points out the need




for interstate coordination and  Federal involvement.




               Number four, development of national




directives for state implementation of hazardous




wastes control programs which monitor hazardous




waste from a point of generation to the point of




final processing.




               The program must monitor the flow




of wastes from the generator to proper disposal.




The existence of hazardous waste disposal facilities




does not insure proper hazardous waste management.




               Without an effective control program




economics clearly favor the midnight dumper.




               A strong regulatory program is needed




to insure the use of proper treatment and disposal




facilities.  The monitoring program in Minnesota




will require reporting of wastes transactions




between the generators, the transporters and the




facilities handling the waste.




               The monitoring program will require

-------
a large amount of data processing, and subsequently



financial support will be provided by licensing



fees.




               Existing Minnesota legislation



places responsibility on the generator to provide



for proper hazardous waste management.  At the



same time this legislation provides regulatory



control of the storage, transportation, and



treatment or disposal to insure that these processes



are done in an environmentally acceptable manner.



               The economic responsibility for



environmental repair and clean up must be accepted



by the generator, the transporter, the facility,



or any combination of these individuals.



               In obtaining a license from the



county, the generator will be required to present



documentation which indicates that its management



practices are environmentally acceptable.



               There is a need for a national



uniformity of labeling and shipping papers for



hazardous wastes.  The existing  Federal Department



of Transportation Regulations present a workable




labeling system.  We would expect the labels to



be modified to reflect the information needed by





                         6U6

-------
all parties involved with the handling of the waste.




               In the area of labeling, one ad-




vantage is that the shipping departments of most




industrial firms are already well versed with DOT




regulations.




               In conclusion, state and  Federal




agencies cannot look at the task of drafting




control regulations without recognizing that other




programs and elements must be implemented concurrently.




               Among those elements most important




are development of consistent nationwide standards




of hazardous waste identification and classification.




Establishment of incentives to encourage the expansion,




improvement and construction of new hazardous waste




processes, and disposal facilities.




               Incentives could take the form of



risk sharing by government, technical assistance



and tax incentives/ establishment of standards for inter-








state transportation of hazardous waste, and directives




for establishment and implementation of state control




programs,  the purpose of which is to insure that




the wastes are directed in a safe manner to acceptable




disposal facilities.
                           607

-------
               Hazardous waste management is a




national problem which must be addressed on &




national basis.  It needs a great deal of research




and development to provide the best available




technology for treatment and disposal.




               It needs a strong regulatory program




to make it work properly on both a national and




state basis.




               I appreciate the opportunity to be




able to speak with you, and I will now entertain




any questions that you may have.




          MR. LEHMAN:  Thank you Mr. Born.  Are there




any questions?




               Mr. Kovalick.




          MR. KOVALICK:  I want to go back in your



statement if I remember correctly, you made reference




to the suggestion that there be national identifica-




tion systems as suggested by the  Federal government,




and then the states would elaborate upon that system.




               You made the point that I'm interested




in, is that it would be possible for states to adopt




more restrictive -- let's use those words -- than




Federal  standards and I would -- wonder if you would




care to comment.  I would seek that particular

-------
approach if Minnesota would to find and define




hazardous waste as more loosely or more stringently




than Wisconsin.  Would you care to comment on that




Mr. Born?




               Would it be either more restrictive




or less restrictive?  As opposed to making it only




that standard?




          MR. BORN:  Certainly the disparity that




exists between states conceivably could,contribute




to a net waste flow between either state.  My




remarks were directed towards the need for establishing




flexibility.  And a definition or a classification




and we realize that disparity undoubtedly will exist,




due to the potential for enforcement at varying degrees.




               And I think enforcement at varying degrees




will probably be a greater factor than a difference




of a technical leverage.




          MR. KOVALICK:  I have one other question.




With regard to the system as I understand it con-




templates managing the waste and knowing of its




whereabouts from generation to storage and disposal,




and Mr. Eby this morning from Monsanto commented




on the huge paperwork burden that he could  foresee




under such a system.
                       6US

-------
               I think of the charts that would

have to be turned in to develop a system such as

this and can you comment on the mounds of paper

that you would receive or not be receiving?

          MR. BORN:  It certainly would be a burden.

And to control the paperwork problem we are now in-

vestigating the possibility for electronic data

processing of that material, in a centralized

location to be the -- to be the centralized data

collection point, utilizing a central piece of

hardware or pieces of hardware.  We do recognize

that it will be great and we do recognize that

to do it the way we requested it and require  to

do it, it's going to require computer processing

and maybe that is the only way I can answer that

question sir.

          MR. LINDSEY:  I have a question here from

the floor.  Why do you believe a decision model

would be more effective than waste designation

that defines variables.

          MR. BORN:  I believe my discussion of

the decision model as opposed to a list that would

be created, the experience of the State of California

in this area, people with whom we have talked to in
                            6f
                            *

-------
California have  indicated  to  us  that  a  list  --  I
think this is the difference  here  --  that  the  list
approach requires that you  develop  some  kind of a
decision model anyway, and  that  any time you want
to revise that list  I think you  will  have  to go
through a very long  and  involved hearing --  clearing
process probably.  And it will be  very  administratively
time consuming and expensive  to  the state,  and  very
burden some.
               The decision model  approach  to  us
is a more flexible means of accomplishing  a  definition
than any other means that we  have  come  up with , provided
one can construct that   ,
decision model in a  defensible rational basis,   New
information is always being put  out on  the  toxicity
and the  hazardousness of various materials, and scientific
evidence changes either  for or against  certain  materials
that we come in  contact with.
               If a  material  is  put on  a list  or
not put on a list and you have to  at  some time  in
the future have  to either include  or  exclude it
you are going to have to go through a very more
involved process and we believe  that  the decision
model will streamline the definition  process involved

                             ' eu

-------
in determining what is and what  is  not  a  hazardous




waste.




          MR. NEWTON:  Mr. Born, earlier  speakers




have stated their belief that existing  DOT  controls




were adequate, then in apparently contrast  with




this you have called for national standards for




the transportation of hazardous  wastes.




               Could you be more precise  in what




you had in mind?




               Or tell us about  the  inadequacies




as you see them of DOT controls?




          MR. BORN:  I think what is  meant  by  the




inadequacies of the existing transportation system,




is that the information that is  required  on the




DOT labeling system is probably  not  sufficient  for




(determining what's in the container.



               And not sufficient from  a  point  of




the transporter himself in case  he  encounters  a




leakage or a spill problem, and  probably  not




sufficient to determine for the  disposer  or the




processer how to deal with that  waste when  it




gets to this facility.




               Perhaps the problem  is not in




regulating the  labeling system.
                        G12

-------
          MR. LINDSEY:  Yes,  I have  a question




from the floor.  You  stated that  landfill  should




be considered long term storage.   Should they




be considered a sink  instead?  Why storage rather




than disposal?  That's what the question is really.




          MR. BORN:   In Minnesota we don't have




the geological conditions that exist elsewhere in




the United States, which are  nice to have  for a




natural barrier to -- for movement of hazardous




chemicals in the land.




               As the potential exists for ground-




water contamination is pointed out by Mr.  Walker




this morning.  Our definition of disposal  is really




not leaving it there  for perpetuity but storing




it there for a long period of time if necessary,




until the technology or the economics exist which



is favorable for recovery.




               I guess I'm not sure what is meant




by a sink.   Just leaving it there -- without any




concern for future reclamation.




               I think we believe that should be




a part of any land disposal facility for hazardous




wastes.




          MR. NEWTON:   Question from the floor.

-------
               Could you clarify the meaning of




government providing incentives and how this




fits with charging fees to support state monitoring




costs?




          MR. BORN:  The incentives that I was




speaking about were for the processing and disposal




facilities.




               The fees were with regard to generators.




In Minnesota our mandated program charges county




units of government with licensing generators of




hazardous wastes.




               And, to offset the administrative




costs of carrying out and administering this




licensing program of generators, it has been




decided by the elected officials that they can




charge fees to recoup their costs.



               Perhaps there was a misunderstanding.  if




whoever asked that question would like to talk to




me about it further, I'd be glad to clarify it,




it seems to me there was a misunderstanding between




the governmental incentives and the requirement of




licensing fees.




          MR. LEHMAN:  We have  no other questions.




Thank you very much Mr. Born.

-------
          MR. BORN:  Thank  you.




          MR. LEHMAN:  Mr.  William  Kttazaki of




the Oconomowoc Electroplating  Company.




               Will you  accept questions  sir?




          MR. KITAZAKI:  Yes.




               My name is William Kitazaki  and I




represent Oconomowoc Electroplating Company of



Madison,  Wisconsin.




               Part of my purpose here, the general




, consensus with our company,  that is,  our group .in  the




company,  is the amount of toxic and  hazardous waste




material is far greater  than what we suspected.




               On February  13, 1963 a public hearing




was held in the City Hall of Watertown, Wisconsin,




from which an order was  issued on January 31,  1964




by the committee of water pollution and state  board




of health.




               The order was as  follows:




               "That the Oconomowoc Electroplating




Company of Ashippun, complete  construction  of  adequate




industrial waste treatment  facilities in  accordance




with approved plans not  later  than  December 31,  1965,"




               Since then we have been actively




attempting to treat our  effluents through implementation

-------
of various systems.  To date our total investment




in pollution control equipment amounts to $470,300.




               We were one of thirty-three companies




and towns that were issued orders to provide adequate




waste treatment facilities.




               We know of one town for certain that




has not stopped one ounce of pollution from going




into its streams.  I don't know what the other thirty-




two have done, or thirty-one have done, and we'll




research that in order to find out.




               We recognize that our pollution




control system is not 100 per cent effective but




when we started to set up our system the available




technology was rather slim, and in our opinion,




remains rather meager today.




               This fact did not and has not stopped




us from trying to accomplish a goal of stopping




pollution.




               When we started our duty of stopping




pollution we assumed that all electroplaters




and other polluters were being served notification




of the same restrictions and compliance dates.




               We find to our surprise that other




platers have different standards and different

-------
compliance dates.  We find this rather  odd  in  as




much as pollution is a problem of  accumulative




effect on the environment and it makes  no difference




whether it be in a stream, lake or  ocean.




               And I think Jacque  Costeau would bear




that one out.




               If P.O.T.W.'s are the cure all  for




our pollution problems then surely  they must  all




be in compliance one hundred per cent of  the time




with far tighter standards than we  have  due  to  the




dilution factor.




               Strangely enough if  a P.O.T.W.  can




be of some assistance in reducing  pollution we have




been specifically excluded from going through  a




proposed sewage system in our town.




               This study was made  by Robinson and




Association of Brookfield, Wisconsin.   It is difficult



for us to imagine a P.O.T.W. operating  100  per cent




of the time in compliance with tighter  effluent




standards unless the sewage system  is totally  un-




affected by rainfall or other water run off.




               We feel that it is the duty  of  each




individual industry to pretreat their waste waters




under the same guidelines as we are under.

-------
               We have been placed in a very non-




competitive position due to our investments in




pollution control when other platers have been




able to use their moneys on new or more efficient




production equipment.  It appears that many of the




squawkers against effluent standards have yet to



lift a finger or invest a penny in a pollution




control system.




               Of course, if we were going into the




Milwaukee sewage system we probably wouldn't say a




word for fear that someone would notice we were




dumping virtually raw effluent into the sewage system.




               We do have definite ideas on effluent




standards and well we should for we have at least




attempted to meet the current standards.  How does



one argue with guidelines when they have had no




experience in trying to meet them?




               To give an idea of what some of the




consequences are should we be forced to close our




operations because of the costly investment of




pollution control equipment, it would cost a total




of about $1,100,000 in unemployment, loss of




income, and we provide -- we're in a small community,




and we provide gainful employment to these people.
                        6i8

-------
               At our current rate of sludge




generation we estimate a total, although it's small,




of 329,000 pounds a year.  The latest costs for




hauling sludge to a licensed site is ten to eleven




and one half cents per gallon or a cost to us of




approximately $3,800 a year.




               This is a very minimum figure.  There




is only one licensed site in the State of Wisconsin




of which we are aware and that is Waste Management




of Wisconsin, Inc. in Menomonee Falls.




               It becomes very obvious to us that the




end solution for plating sludge is not to bury it but




to find useful applications.  Our educational insti-




tutions could certainly play a large part in getting




closer to solutions if grants were available.




               The reason why we feel that we are




only looking at a part of the problem is that 10



million tons per year figure came from what is




being generated currently.  I would have to guess




that there is a lot of soft solids that are going




into lakes and streams, going through municipal




systems where they have no regulations on solids,




much less whether they're hazardous or not, certainly




if what we see from a table in a publication of
                         613

-------
Industrial Finisher's Magazine, which notes the



only pretreatment required of people dumping into



the sewer system in Milwaukee are one of pH and



temperature.



               Any time there is a rainfall I have



to believe that raw sewage goes out into the lake.




It's not as easy to see out there but nonetheless



it's there.



               And I believe the goal of the EPA



is to stop a problem of pollution and protect our



environment.



               There are articles on trace elements



where they have not found that they were particularly



bad if they are spread over the land.  And I refer to



an article by M. B. Kirkham who is a plant physiologist at



Advanced Waste Treatment Research Laboratory, EPA



Cincinnati, which you have.



               This kind of research I think is



what we need in order to get us out of some of



our dilemmas.   I recognize that our particular wastes



are different than anyone else's wastes.



               But I think as we come up with some



more of these answers the greater chance we have




of not worrying about the landfill sites or the






                           620

-------
problems of polluting underground waters or getting




some realistically way of using these things or




maybe they have to be stored for a period of time,




until we do come up with the research necessary.




               It comes to mind that If Wisconsin 	




if we're correct in the research we have done




in finding who is a licensed        toxic and hazardous




material dump-ing site, it seems very strange that with




only one site there hasn't been more and more of a




clamor for where do we dump this stuff.




               If the sewer system of Milwaukee Is




just taking their stuff to a sanitary landfill they're




accepting all pollutants from the electroplaters in




the area, and they're dumping that same material Into




a sanitary landfill where as our material has to go




to a toxic and hazardous material licensed site.



               Something seems a little wrong and




certainly if we are controling our toxic and hazardous




materials and hauling them to licensed sites, I would




think that we'd have a whole lot more than what we




have in the State of Wisconsin.




               Thank you for your attention, are there




any questions?




          MR. LEHMAN:  Thank you Mr. Kitazakl.






                        621

-------
               We have a question.  Mr. Llndsey.



          MR. LINDSEY:  You mentioned that you seek



the end   solution for plating sludges^ as not_being



variable, but finding some useful results.



               1 would like to find out as best I



could what is the reason you'd advocate to find this



out, is it expecting         there is going to be



some damage from the waste, or secondly do you feel



that the prospects for finding some useful application



for these things in a cost effective manner are



imminent?



               Could you comment on that?



          MR. KITAZAKI:  I guess I didn't get the



first part of your question.



          MR. LINDSEY:  Let me rephrase it a little



bit.



               You say in your statement it becomes



very obvious to us that the end  solution for plating




sludge is not to bury it but to find useful applica-



tions.  I would like to know  on what you base this



conclusion or why you say that.



               Is it because of costs, is it because



of potential damage?  You say as a result of the



sludge being buried.





                       622

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          MR. KITAZAKI:  I would say that was a




gross inability of the use of the English language




on my part.  The only reason I said that is I don't




feel there is necessarily a solution.  I would think




that that was the one that we had tested first re-




gardless of the cost, so that we eliminate the problem




and that it be put to use in saving other resources.




               But whether or not the researchers




are at hand, and the only thing I have to refer to




is just one article where they have attempted it --




incidentally the only thing where they saw trace particle




elements coming up into the plant was in the  leaf as_




opposed to the fruit itself, whether it be corn or




apples, which is interesting because I'm sure it's




a problem if that amount of a trace metal is in there,




that would reduce it for silage or something if



that was for animals, which I don't know, and I




don't know if there is an answer to that.




               And the second part of your question?




          MR. LINDSEY:  You answered that.



          MR. KITAZAKI:  Thank you.




          MR. LEHMAN:  Are there any other questions?




          MR. KOVALICK:  I have one more thought if




I could.

-------
               If I understood the point you were




making correctly, I think that I heard you  say that




a number of your competitors and others are being




permitted to use waste water plants to take industrial




wastes which are then treated and then there will be




sludge just as the kind of sludge that you would have,




in your treatment, are you saying that there are ways




in which that sludge is handled or the lack of re-




strictions, that the way that sludge is handled differs




significantly from the requirements placed  on you?




               Is that what you said?




          MR. KITAZAKI:  That's what I said, essentially.




I have to assume I don't know  too much about    the




sewer system, whether they do or do not treat it.  I




mean if they don't treat it somebody will have to worry



about it in Lake Michigan, eventually.




               But if they do treat it as they are




supposed to treat it, assuming that they have,




assuming that they have  chlorination, sulfonation,




and so forth, and this takes care of cyanides and




 chromiums and if they  are taking the sludge that they




gain from that into a sanitary landfill, I  can't




see how that landfill isn't going to be a problem




if it's true, that that sludge that we generate

-------
which is the same they would arrive at is  in fact




toxic and hazardous.




               And I think there needs to  be some




help in there, whether or not in fact it is.  I




know it's not an answer you'll get tomorrow, but




it certainly will assist in learning what  we do




put in in helping dispose of a toxic landfill.




          MR. LEHMAN:  Are there any other questions?




Thank you Mr. Kitazaki.




               I'd like next to call on Mr. Sidney




Blatt, representing the Columbus Steel Drum Company




of Columbus, Ohio.




          MR. SIDNEY BLATT:  I am Sidney Blatt of




the Columbus Steel Drum Company, Columbus, Ohio,




and also I have with me Donald Rutman, of  Industrial




Steel Container Company of St. Paul, Minnesota, and



we are together submitting this statement  as Central




Region members of the National Barrel and  Drum




Association.




               If there are any questions  that




will be asked at the end of this statement, why




Mr. Rutman will be up here with me and he will




help me and answer questions.




               As members of the Central Region

-------
of the National Barrel and Drum Association,  we



are adding additional information to buttress the



statements submitted by our Association at your



hearing in Newark,  New Jersey,  on December 2, of



this week.



               As member companies we feel that the



thrust of these hearings regarding our industry



should be as follows:



               Number one, eliminate the problem of



toxic and pesticide waste material left in steel



drums.



               Two, establish the best methods of



environmentally safe disposal of the drums and their



contents.




               In our Newark report the emphasis was



on agricultural pesticides and  how these empty



containers could be handled.  There are regulations



in the State of California, and you can note  that



in your Appendix B, of the Newark Statement,  which



detail the handling of these empty containers.



               In the industrial areas of our



country, our industry would have the ability  to



handle drums which have contained toxic materials




and would be willing to meet certain criteria for






                        62"

-------
the segregating and reconditioning of these



drums in a manner similar to that being done in



California with pesticide drums.



               As an industry, we are today recon-



ditioning many drums that could possibly be con-



sidered toxic and are handling them in a safe



manner.



               The emphasis should be on what happens



to the drums and their residue material after they



are discarded by the emptier.  There could be con-



siderable savings in materials if the user or



emptying facility would agree to completely empty



and flush, if possible, all materials in the drums



not utilized in the manufacturing process.



               Our experience has shown that the



amount of material left in drums, and not used, is a



waste factor in our economy that runs into tens of



millions of pounds of material per year.



               Instead of being part of a finished



product, this excess material is taken away to



landfills or disposed of in any manner that is



available.  If this problem of completely emptying



drums before they are received by the reconditioner




could be enforced, then the problem of waste disposal





                         6*7

-------
would be considerably less in regard to toxic



materials.



               As mentioned in the Newark statement,



we have companies geographically situated throughout



the United States with the technical know-how,  the



experienced manpower, and the reconditioning facilities



to put back into service those drums which contained



toxic materials, thus eliminating one of the problems



in solid waste disposal.



               Drums with toxic substances, after being



completely emptied and flushed by the user company,



could be put in segregated areas at the user facility



and picked up by reconditioners' trucks in a prescribec



manner and reconditioned according to certain basic



criteria that could be set forth by the Hazardous



Waste Management Division.



               As an industry we are deeply concerned



about toxic materials left in drums and would be



willing to help develop workable solutions to over-



coming this problem.



          MR. LEHMAN:  Thank you Mr. Blatt, are



there any questions?



          MR. LINDSEY:  Mr. Blatt, apparently this



material that's left in the drums causes your

-------
companies quite a bit of problem.  How do you




handle that problem?  What happens -- if it comes




in with a couple of pints of materials, how do you




handle that problem?




          MR. RUTMAN:  My name is Donald Rutman.




Industrial Steel Container Company, St. Paul,




Minnesota.




               Presently we are handling the drums




through sophisticated reconditioning processes.




We completely remove the previous content of the




drum and flush the drum chemically through a  caustic




solution, remove any dents in the drum and completely




clean the drum so it is acceptable for reuse once




again.



               We are once again working  very




close to finishing and engineering a completely




closed loop system, water clarification as well




as chemical clarification, for our industry.




               A number of our private companies




are working on this as well as our association.




So this problem of what to do with the small




amount of residues that remain in the drum will




shortly be solved.




          MR. LINDSEY:  Would it be possible once

-------
you have formulated this for us to obtain a copy




of it in some way?




          MR. RUTMAN:  Yes, but I think the main




area of concern here is not after the reconditioning,



but actually the  reconditioner is not  a reclaiming




or a waste disposal company.  They are reconditioners




of steel drums.  The important thing is to educate




the generator to completely empty out the container,




so that we could probably clean them and have him




reuse the drum again.




          MR. KOVALICK:  Perhaps you can comment




to this audience and for our benefit also on whether




you feel that it's an education program that will




sufficiently meet your need.



               In other words, do you feel that there




are sufficient numbers of people informed about why




they ought to rinse these drums because they'll be




met with a residue and disposal problem and will that




be sufficient for them to do it or are you recommend-




ing something else?




          MR. RUTMAN:  I think the educational




process is certainly one step in eliminating the




solid waste problem that we have.  If we then




show the generator that oftentimes the residues






                          630

-------
that he sends us Is virgin material, and we  are




not only having a waste problem, he cannot only




use the material on his own end product, but he'll




save himself money.  But 1 want to emphasize that




I think that steel drum reconditioners are very




logical gathering points or concentration points




for the use of steel drums.




               In other words, the dirty steel




drums, because as Mr. Blatt indicated, our companies




are situated throughout the United States in all




of the industrial and heavily populated areas.




               So, we are at this moment set up to




handle the cleaning of the used or dirty steel drums.




          MR. LEHMAN:  I have another question.  We




have some more questions here.




          MR. LINDSEY:  I have a question here from



the floor.




               Are reconditioned drums restricted




to the same service as they were originally used




for?




          MR. RUTMAN:  No.  The steel drum now is




a universal container.  The differences come in the




gauge of the drum and as you gentlemen know, there




are certain hazardous products that must be contained

-------
in a particular type of gauge of drum, but it is




not restricted to the same type of product in the




same drum.




               Because after the drum has gone




through a sophisticated reconditioning process,




it is clean on the inside so that there is no




material remaining in the drum.




          MR. LEHMAN:  I have a question, but I'll




add to it another question from the floor, which is




related.




               Could you indicate for the record




approximately the range, I assume you buy these




huge drums or perhaps you don't, but would you



indicate whether you buy the drums from generators



or not?




               And if -- the second part, if a




drum contains a toxic residue or a residue which




is difficult for you to handle, do your member




companies charge a penalty or surcharge to the




seller of that drum?




          MR. RUTMAN:  The first part of the ques-




tion is do we buy the drum.  It depends on the




market area and the particular condition it's in.




               Some of its customers have used that






                        632

-------
drum maybe  8  or  10  times,  because of the recondi-




tioning process,. It becomes  a service issue where




the customer  owns the  drum.




               In other  areas,  depending upon product




it will be  on a  buy and  sell type of basis so again




my answer  is it  depends on  the market,area.




          MR.  LEHMAN:  How about the second part




of the question?




               What if it  has  any difficult material




in it, does  it -- is there any  surcharge?




          MR.  RUTMAN:   I don't  believe it depends




on the difficulty of the type  of material to be




removed.  It  depends  on how  much material is in the




drum, because  again we are reconditioning some steel




drums .  We are not disposers of hazardous wastes; we are re-



conditioners  of  steel  drums.




               Some companies  do charge for disposal



of the product because they  are charged for disposal




of the product,  and other  companies return the product




back to the  generator.




          MR.  LINDSEY:   There's another question here




from the floor.




               I think I understand it.  Until the




problem of what  is  in  the  waste to be treated is

-------
defined how is it possible for a drum reconditioning




company to expect to obtain a guarantee from a




company that is furnishing them with waste treatment




equipment?




               Maybe I can paraphrase this question




a little bit.




               If you don't know or you have no way




of knowing what -- the way wastes are to be treated,




how can you obtain a guarantee from the company




providing waste treatment equipment?




          MR. BLATT:  I don't think we're really




trying to guarantee -- I don't think we're  really




trying to get a guarantee on someone -- on waste




treatment equipment.




               I think the thing that we are really




trying to say here is this.  We have two methods



of reconditioning.  One Don mentioned about flushing




and cleaning out the drums, as a tight head drum.




We also have facilities which was asked many times




earlier about burning and incineration, we can




burn out any type of drums -- we can burn out any




type of material that's in the drums and they'll




just leave a residue ash.




               I think what we're really saying is

-------
this, that certain materials are toxic.  We don't




always know what is in the drums that we are




receiving.




               So unless our experience teaches us




that there are certain products in a drum that we




better not handle, we will refuse to take those




drums.




               If drums have excess material re-




gardless of what is in them, we again in many cases




refuse those drums because we are dealing with the




safety of our employees, and asking them not to




handle any drum and for example, from a different




weight standpoint, that he really couldn't handle.




               We do have the facilities but 1 think




what we are saying in our statement here today, is




this, that if there could be some way that those



materials which we think somewhere down the pike




you or some other agency will be saying is toxic,




that the generator company or -- shall have a certain




method of emptying the drum, flushing it and then




stacking it off to the side so we'll know what




it is.   And we will be able to handle it.




          MR. LAZAR:   Yes, fibre drums and steel




drums are often used for hazardous materials, but
                     635

-------
when empty they often contain non-hazardous materials •




I mean hazardous materials, how can this be corrected?




          MR. BLATT:  What we're saying is this.




That it's been proved to date, particularly with




pesticides in drums, rather than other toxic materials




that we are eliminating through the burning process




any material that is left in the drum.




               Now if someone wanted to get in there




microscopically, it's hard to say what they might




do, because I haven't been involved in that testing




process.




               But in most cases or in every case




we know in every case what goes in those drums, that




it is chemically clean, and this is what we are




saying.




               That if pesticide drums which I think




are the ones that are at this point being regulated,




particularly by the State of California, are handled



in a certain .prescribed method, then that is in




the information you have.   There have been other




materials that have been designated toxic, and we




understand there will be more later on as evaluations




are made of those products.




               Does this answer your question in
                     636

-------
terms of what you just asked?




          MR. LAZAR:  Yes.




          MR. LEHMAN:  Any more questions -- thank




you very much gentlemen.




          MR. BLATT:  Thank you.




          MR. LEHMAN:  Next I'd like to call upon




Mr. Phillip Lindall of the City of Des Plaines.




               In that case I'd like to call upon




Mr. Frisbie of Chemagro Mobay Chemical.




          MR. LEE FRISBIE:  I will accept questions.




And my statement is intended as a preliminary




statement, and therefore will be brief and general,




and I wanted to attend the meeting and get some




better ideas as to how to make specific comments




to some of these questions.



               My name is Lee Frisbie, I am the




manager of Environmental Protection for Chemagro




Mobay Chemical Corporation, located in Kansas City,



Missouri.




               Chemagro produces pesticides,




along with other agricultural products, and gen-




erates some waste materials that require special




precautions for disposal.




               Since the subject of hazardous

-------
materials has been a popular one recently, Chemagro




wants to participate in meetings like this to help




maintain a scientific perspective and avoid emo-




tional overreaction.  Hazardous wastes can be




handled safely and properly with current disposal




techniques.




               The first consideration should be to




minimize the amount of hazardous wastes generated.




In chemical processing, this means extraction and




other techniques to recover and recycle material.




               Chemagro has been practicing these




recovery techniques for many years.  In some cases,




the waste materials can be broken down to harmless



substances by additional processing.  The main




source of hazardous wastes at Chemagro is a stiuation




where mixing of several components has occurred and



separation is not feasible.




               In addressing the subject of hazardous




wastes, definition is extremely important.  To be




classified as hazardous, a waste should be either




toxic, explosive, or highly corrosive.  I will




comment primarily on toxic wastes.




                    For     toxicity the most




useful test is determination of the mammalian

-------
toxicity, LD50 values.  These values can be obtained




orally using rats, and dermally using rabbits.




Material with an oral LD50 less than 50  milligrams




per kilogram body weight, or a dermal LD50 less than




200 miligrams per kilogram should be considered toxic.




               As concerns responsibility and liability,




the generator of a hazardous waste should be respon-




sible for it until he has delivered it to a disposal




concern.




               This could take place at the generator's




location or the disposal concern's location.  We much




prefer to use disposal firms with their own trucks.




In this way, title passes when they leave Chemagro




premises, and they are responsible from that point




on.



               They have experienced personnel who




can take care of any problems with the load during




transit.  After the generator has checked to be sure




the disposal firm has the proper state disposal




permit and liability insurance for the transportation,




the generator should be free of responsibility.




               The only exception would be in a




case where the generator includes in the shipment




material not covered by the agreement, and if this

-------
material caused damage during transit or disposal.




               Analytical work, the analysis of




waste materials can be difficult and expensive,




particularly if individual component values are




desired.




               Then I would say that for many wastes




the characteristics of toxicity and pH are relatively




easy to determine and, combined with the chemical




family knowledge, should allow good characterization




of many wastes.  In case of reasonable doubt, the




higher hazard classification should be used.




               As I mentioned Chemagro will submit some




more detailed comments in writing, appropriate to



things learned during this meeting.




               And in dosing Chemagro has a policy




of careful selection of disposal firms.  This means



visiting the proposed disposal site, and checking for




proper environmental concern within the disposal




firm, permits, ground water protection, restricted




public access, a do it right attitude, and technical




competence.




               This policy has served us well over




the years.




               Thank you.

-------
          MR. LEHMAN:  Thank you Mr. Frisbie.




You have some question Mr. Lazar?




          MR. LAZAR:  Mr. Frisbie, in your remarks




you stated that a useful test for determining




toxicity is the LD50 toxicity test.  Of course,




this was -- this is for acute toxicity.  That's




.relatively  large doses within a short period of




time.




               What sort of tests would you suggest




to determine whether a substance or base is toxic




over a long period of time using very small dosages?



          MR. FRISBIE:  I don't believe I'd be able




to comment on that at this time, and that's not




really within my area, and I'd prefer not to deal




with that.  I am not a toxicologist.




          MR. LAZAR:  However, do you see a problem




with this rather than acute toxicity when it comes




through -- to disposal of the waste?




          MR. FRISBIE:  Well, I would say that if




we take the position I suggested, we're not positive




of what the situation is, we should take a more




conservative approach, and we should use a more




conservative side to make sure we take the best




care.

-------
          MR.  LAZAR;   Now, toxicity of course  is




what we're worried  about,  but we're worried  about




 carcinogenicitY  .  and this matters quite a bit




also.  Wouldn't  that  complicate -- testing for




c ar
-------
is can .Chem Agro add a policy of accepting empty con-




tainers for reuse as opposed to requiring disposal?




               In other words, do you use new con-




tainers all the time or do you use others?




          MR. FRISBIE:  We use new containers,




and again I'm not familiar with DOT specs, but I




believe they are single trip situations.




               So we do not accept containers back




from other sources unless we have shipped the




material there in our drums and it was our material,




then we take the drums back.




          MR. LEHMAN:  Another question Mr.  Frisbie.




You indicate that Chemagro has a policy of careful




selection of disposal firms, and there are a number




of parameters that you go through and the implication




of this policy would seem to be that you are pre-




pared to pay a higher price for the service  than



might otherwise be required.




               And first of all, I'd like for you to




comment on that point.




          MR. FRISBIE:  Yes, we would pay a  higher




price if someone has a site that we consider is




not appropriate or that's closer or whatever, we




don't feel that's a proper situation, we will pay

-------
a higher price and send it farther to the person




that we feel is -- we feel and believe is proper




to handle it.




          MR. LEHMAN:  And the second is, in reviewing




the policy the actual cost to your corporation or




what have you, have you seen any problem of your




company being involved with being competitive with




other companies that might not use this policy?




          MR. FRISBIE:  No, I have not seen this




in any of our situations.  We are a fairly specialized




chemical situation and we are not producing the same




materials that other companies produce.




               Our materials are patented materials,



so we have a little bit of a different situation.




          MR. LEHMAN:  I see, thank you.  Are there




any other questions?




               Evidently not, thank you very much




Mr. Frisbie.




               I'd next like to call upon Mr. David




Dennis of the Michigan Department of Natural Resources




if he's here.  Mr. Dennis.




               Is Mr. Dennis in the audience?  Well,




he may have stepped out.  We'll have to come back




to him.

-------
               All right.  Next I'd like to call




upon Dr. Frank Richards, pollution and Environmental




problems.




          DR. FRANK RICHARDS:  I will take questions.




I am representing pollution Environmental Problems




or PEP, an environmental action organization about




10 or 15 miles from here.




          MR. LEHMAN: Excuse me Mr. Richards, could




you get a little closer to the mike.




          DR. RICHARDS:  I am Frank Richards, and I'll




repeat myself.  I am representing pEp an environmental




organization based about 10 or 15 miles northwest of




here.




               We are pleased to be able to give our




views representing hazardous wastes.




               May I first compliment EPA on its




environmental information factsheet which accompanied




the announcement of this meeting.  I really pray that




the aims and priorities expressed therein will in fact




be carried out.




               In particular, I liked the emphasis




on reducing the  generation of wastes, on recycling




of the wastes generated, and I'm looking forward




to a recycling type of economy and culture, with

-------
man in harmony with his environment rather than




making it continually worse.




               1 believe that the majority of




people in the United States are becoming at least




somewhat concerned about these hazardous wastes




with which they are familiar, such as pollution




wastes in the air and so on, aerosols, and so on.




And at least vaguely uneasy about the possible




consequences of mankind's other interventions in




the environment.




               But people still need to be told about




the infinitely greater costs in environmental and




health damage which will arise if dangerous materials




continue to be discarded irresponsibly.



               So I think that the EPA's leadership




in these matters is very timely.  It's refreshing




to see a government agency actually ahead of the




public without being forced to get into things like




recycling of materials.




               Please keep Up this good work.  I




for one will gladly help in any way I can.




               I want to first make two specific




suggestions which arise out of my own experience




as a Ph.D. student and -postdoctorate in university physics






                         646

-------
laboratories, and then discuss two other topics  for




about one minute each.




               First suggestion, both at the




University of Chicago and at Purdue University,




there were no designated waste disposal experts  in




my department, or I assume in the whole university.




Purdue did have an expert on mercury disposal  and/or




recycling, because large dollar amounts of mercury




were being used.




               My suggestion then is for each




laboratory to designate an expert on waste disposal,




to whom any laboratory worker could go for advice




and help, encouraging responsible disposal by




making it easy, or as easy as possible.




               Naturally, the resident expert  should



be provided with an EpA issued handbook appropriate



to that laboratory.  I could give a few obvious  or




common sense guidelines to be included in such a




handbook for toxic metals, which is my main area




of experience.




               I worked with about 15 or 20 pounds



of this substance during my time at Purdue.




               As an example, this would be relevant




to discussion time, topic 3 which is in my statement,

-------
because toxic pure metals are -- or all pure



metals are limited and we will run out of metals,



eventually -- and by the same token they are



expensive now already, they obviously should be



recycled and reused.



               And this appropriate guideline might



state that preferably they be recycled by returning



them to the original supplier together with a written



history and estimated impurity content, depending



on how they were used, so that the supplier could



quickly and cheaply decide which bin to throw them



into.



               In general the handbook should answer



the question what alternatives are available for



disposing of that material.



               The second question, similarly, I'd



suggest that each city with a sewage or garbage



disposal center designate one of these as a hazardous



waste information center where any citizen could --



whether he owns a manufacturing plant or whatever,



-- could read an appropriate EPA issued handbook and



hopefully learn what he wanted to know.



               Someone who worked there might even



learn enough after a few years to give helpful advice.







                           BkQ

-------
               I believe such a service would be




"effective for soliciting citizen acceptance of




hazardous waste management facilities."  And this




is discussion topic 14.




               The city taxes needed for this




service would be well spent, that is in the extra




time that city employees I believe, just for




improved public relations and the gradual buildup




of a better informed citizenry.




               The topic of who should bear the




costs of environmentally safe disposal of wastes




is very dear to my heart.  I strongly encourage




Congress to make the user of it to pay not only the




initial disposal costs, but also the ultimate costs



for storage and monitoring, in advance.




               That is some sort of an endowment if




necessary.  In line with the Toxic Substance Bill,




S.766, the burden of proof should be on the marketer,




before he markets the product, to show that it's




non-toxic or to put the cost into the product.




               All products should be priced at their




full social cost, to help limit the demand for




particularly dangerous products.




               That has to be very close if you're

-------
going to allow effective i choices between products,



and therefore really cutting down on the use  of




dangerous materials.




               In answer to an earlier question,




I would say no, no  Federal  fund s should be provided




to help stage -- states with especially toxic wastes.




I want the full cost put into the product.




               I would like pricing of social costs




so high as to make recycling or recovery attractive




right now  and I can't emphasize that too strongly.




You could say we are 20 years ahead of our time in




worrying about recycling materials and probably




we won't get really going on it for another 20 years



until we actually have to.




               The  same as with energy and the cost




of fuels right now, where we are actually forced




to, to get going on it.




               But  I would like to put those  costs




right now in there, and I'll go further and say




that the raw materials should be treated as public




capital, such as the metal in the ground and  so on.




Instead of as free  or worthless.  Right now when




you pay for metal you pay for getting it out  of the




ground, and you pay nothing at all for the metal




                         650

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itself when it's sitting in the ground.




               This capital cost should be included




in the full social cost.  That payment should go




to the citizens, as a common inheritance.




               I recommend Chapter 1 of the book,




Small  is Beautiful, by E. F. Schumacher, for its




rational discussion of this whole topic, and pages




18-19 concerning toxic wastes generally.




               The final topic I want to discuss is




the topic of radioactive wastes.  No one neither




scientist nor politician can guarantee that radio-




active wastes can be successfully isolated from




man's environment for a half million years.




               This fact is implicit when nuclear




physicists say -- and I'm a physicist myself --




when they say that the long term problem is "the



biggest difficulty because it is the one that I




cannot evaluate.  I do know that it is possible




to store something for 300 years so that it




doesn't come back to haunt you."




               In fact no one can guarantee the




above for 300 years either, by the same token.




Although the risks can be kept down considerably




by trying to assure that man himself does not





                          651

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intrude into the waste storage areas.  At the



minimum, this requires some kind of continual



surveillance and monitoring and sufficient defenses



against malicious intruders.



               As a hopefully logical and careful



scientist I feel that we must openly, carefully,



and unemotionally consider all conceivable possi-



bilities.  In particular, I would like enough further



research such as well designed experiments on



radioactivity in our food chains or as they come



up to us through our food chains, to absolutely




rule /out any possibility that our  radioactive waste



might wipe out mankind at some time in the future.



               The crucial question is, can we be



absolutely certain that even the maximum amount of



fission products, somehow put in contact with man's



environment and concentrated by his food chains,



absolutely cannot wipe him out at some time in the




future.



               On the assumption that the American



people would not accept any risk of causing a



wipeout in the future, it seems only logical to



me to definitely answer the above question before




committing future generations to continual surveillance





                        652

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of large amounts of nuclear wastes, and the burden




It will create for them.  If the public would




accept some  slight risk of a wipeout, then the




above question is not as important  as I take it to




be.




               Would EPA like to poll the public




concerning the risk of wipeout which they would




accept?




               I make that suggestion.  Even if my




assumption about public opinion is wrong, the nuclear




industry should still be required to pay, and pass




on to their  customers, the full social costs of their




product.




               This includes the costs of much much




further research on waste storage and an endowment




sufficient to provide for all future waste storage




monitoring and security measures.




               Under discussion topic 2 , if I'm




right about  public opinion that they will not accept




any risk of wiping out mankind in the future, then




I recommend  obviously no -- or practically no




nuclear waste degenerated until the crucial question




can be answered,  whether or not we can be sure that




mankind will not  be wiped out.
                          653

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               I would clarify though that I'm




not against nuclear energy if it can pay its own




way without possible wipeout of mankind.




               I would make an additional obvious




suggestion, that's not in my written statement,




that the EPA's recycling and reuse efforts on




hazardous wastes should be tied in with materials




recycling in general, and other agencies.  And I




would like to see identification of products, let's




say anything that has a sufficiently toxic material




in it.  That you could take it, or a particular




character that could be written on there, with some




chemical in it that can be easily identified, if



a particular character were good for ten, or if




you had ten particular characters, you put three




characters on there and identify them, and I think




this might be feasible sometime in the future.




               It's an idea that I think is good.




          MR.  LEHMAN:  Thank you Dr. Richards.




Mr. Kovalick.




          MR.  KOVALICK:  You mentioned laboratory




waste disposal problems.  Could you comment what




has happened to it now?




               Where are they going?

-------
          DR. RICHARDS:  Typically  they  get  thrown




 in the wastebasket,  and to the best  of my  knowledge




 -- I was very interested to hear Mr.  Bruns  statement




 to the waste management assistance  this  morning.




 What he does is burn  it.  He  answered my question




 as to where they go.  They burn them.




          MR. LINDSEY:  You indicate  here  in your




 statement --




          DR. RICHARDS:  I want to  add more  on  that.




 I have thought about  those 15 pounds  of  material




 which I was not done  with, and I left them with the




 suggestion that they  be sent  to the  original supplier.




 With information how  they were to be  used.   But I




 don't think --




          MR. LINDSEY:  You state in  your  statement



 here that all products should be priced  at their




 full social cost.  And I think you  indicated that




 you thought it should be done right  now.




               Are we able to in your opinion determine




what the full social  costs are in all. such




 things as what might  happen in the  long  term future




 and things of that nature?




               In other words, can we determine




that  cost now?

-------
          DR. RICHARDS:  I think anyone  not  fully




aware of that question would say no.  But  for




instance in pricing oil which is a natural resource




that is in the ground now, oil, coal and gas,  all




of those should be priced high enough so that  a




> usable  source then — whicn is solar energy will



become competitive immediately.




               And particularly the fully  reusable




ones like solar energy should become competitive




immediately, and the price should be so high that




solar energy will be a most attractive thing to




heat your house with right now in the City of



Chicago.




          You need  insulation which keeos .down



the heat loss, at about one-third, and solar heat




could fully heat your house right now here in




Chicago.




          MR. LEHMAN:  Do we have any other  questions?




Excuse me.  Al, there's a gentleman here --  pick up




his question.  In the meantime, --




          MR. LINDSEY:  Could our economy manage




those additional losses right at the moment?




          DR. RICHARDS:  I take it that  you  mean




management costs without cutting down on our standard





                     656

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of living.




          MR. LINDSEY:   Significantly  I  mean.




          DR. RICHARDS:  Well,  probably  naturally



you just don't do  it  overnight,  and  I  think we




could cut down our consumption  b y about  a  factor




of two and cut down our  energy  consumption  by a




factor of one-half without hurting our quality




products.  This is ddne   in Europe now  of  course,




and your gross national  product would  not drop




very much apparently, it requires a  different kind




of culture though to  sort of kick the  habit  we've




been living with,




          MR. NEWTON:  Yes, I have a question here




from the floor.  Do you  feel that energy  conservation




or raw material conservation and waste recovery are




all part of the same  social problem  and  should be



considered by EPA in  their setting of  regulations?




          DR. RICHARDS:  Well,  yes,  clearly  they




are all part of the environmental problem,  and in




a sense should be at  least considered.




          MR. LEHMAN:  Yes, Mr. Lazar.




          MR. LAZAR:  Dr. Richards,  could you please




elaborate a little bit more on what  you  are  proposing




namely this hazardous waste information center.
                        657

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               What  sort  of  information would you




like to see the EPA  handle,  and what  would  this




accomplish?




               Would the  individual  citizens through-




out the country throw  less hazardous  wastes into




their garbage cans?  So most  hazardous  wastes would




be reduced by that?  I don't  quite understand what




you mean, what types of information  --  whether it




be toxicoloqical information or -just general warninas --



what types of general waste  should not  be discarded




lightly, what do you mean?




          DR. RICHARDS:   I was going  to have you




-- put yourself in the shoes  of the  average citizen.




He might wonder now  should 1  throw this --  we'll



I've got some paint  left  over here, what  should I




do with it?



               Is it going to hurt anybody  if I




just throw it into the garbage can.   Or should I




flush it down the toilet?  Or what?




               Now from my own experience if it's




handled by the laboratory  and the expert  comes in




and looks In the book  about  it, that  book should




say what is the level  -- what is the  level  of




allowable cadmium in the  air, and where does it






                        £50

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come  from?  Give me  some  idea  --  if  I  have  air




at that  level, how much harm will  it do  or  what,




because  my  own feeling that I  better stay below




that  because I don't know what that  effect  would




be or what  it would be good for,  and it  should




also  be  translated into everyday  language that I




could use.  Such as if I had a surface area, on




the other side of this room, it would  have  to be




extremely large, that would be on  the  order of




-- and you  have no turnover of air in  that  room,




that  cadmium would generate the level  that  is




allowed  in  the air.




          MR. LEHMAN:  There have  been a number




of questions submitted concerning  the  general




topic of energy, and to Dr. Richards I feel as




a Chairman  I will exercise my prerogative and say



that those questions are really not terribly




relevant to the discussion here, and I would ask




the people who have phrased those  questions to




contact Dr.  Richards directly.




          DR.  RICHARDS:  That will be fine.




          MR.  LEHMAN:  Also, I wish to point out




that also the aspect of radioactive waste wasn't




discussed here, and while it is a very important






                       653

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issue I would like to make it clear, both to the




speaker and to the audience that the Environmental



protection Agency's mandate in radioactive waste




disposal is somewhat limited and the primary




responsibility for that rests with ERDA.




               Now, ladies and gentlemen, we are




close to the time when you will take a break and




I don't think we have adequate time to have another




speaker before the break, so I will adjourn -- not




adjourn but recess.




               We'll take now a 15 minute break and




I'd like you to reconvene at 3:35.




               Thank you.



                              (At which time a 15




                               minute coffee break




                               was had.)
                        6GO

-------
          MR.  LEHMAN:   Ladies  and  gentlemen,  would




you please take  your  seats  so  we can  get  started




again.




               I would  like  to call the meeting




to order please.




               I would  like  to call now please,




Mr. Don Brown  of the  State  of  Ohio.




          MR.  DONALD  BROWN:  Good  afternoon,  my




name is Don Brown of  the  Ohio  EPA. I'm with  the




Hazardous Waste Division  in  the administration




part of it.




               My comments today will  be  extremely




brief, however I think  that  policy statements are




most important to Ohio.




               Ohio EPA strongly urges the Admin-




istrator of the U.S. E^A^he Administrator of the




Office of Management  and  Budget and our Ohio




Congressmen to oppose categorically any cut in




state programs.




               We are  informed of such  cuts in




the fiscal year  "77 and they could amount to  an




excess of 35  percent in state's_9rants-



               Many initial hazardous  wastes  and




energy recovery,  solid waste enforcement  and

-------
management programs would be In line for severe




paralleling cuts.




                  Service to our state's citizens




and industry     would be curtailed beyond our




current inadequate levels of funding.  Ohio however




wishes to commend the efforts of the fact finding




commission, this board is on today, and we recognize




both  Federal and state efforts must be intensified




during the next fiscal year.




               It is now apparent that many states




are developing hazardous waste regulations of




various descriptions.  Some are developing




         • decision models, others adopting pre-




existing hazardous material shipping or handling




statutes.




               Prompt U.S. EPA action is needed now




to develop continuity of the States law development,



paralleling the Federal program.  We do have a few




brief statements of support of the  Federal policy




as we understand it today.




               One, recognize that hazardous waste




treatment centers could pick up a great deal of




the volume of hazardous wastes that are going into




the land, and the nation today, but only if states

-------
themselves  adopt  a  policy  of  stringent  enforcement




within landfills  themselves.




               Two, we would  wish  to  see  development




grants similar to the Minnesota  grant,  only  on a




larger scale which would incorporate  energy  recoveryr




material recovery within them as well.




               We agree that  the movement  of waste




interstate will need to be maintained to  allow a




viable base for such hazardous  treatment centers.




The fact of the matter is the  marketing centers




are all often  100 to 150 miles,  and often  across




most state borders.




               We would tend  to  support several




statements mentioned today, criteria  for the design




modeling kind  of  legislation which would  allow




flexibility of both management and enforcement in




the state as well as some flexibility in the initial




enactment of the  industry's efforts in compliance.




               Along this line I will be announcing




we'll be having a public hearing in Ohio in  January



on our proposed solid waste and hazardous  waste




regulations.  We  anticipate an early March promulgation,




               Point Number Five,  is we feel that the




Federal government will be in  a good position to
                           uu J

-------
provide a clearing house function to allow industry




as well as the states to know what other companies




are in the business of handling various hazardous




wastes, in the various restraints they do under




permit today.




               We also support the concept that the




generators best will know their products and should




be able to develop toxicity data necessary and




further supply that information, and gain the con-




fidence of the states and governments responsible.




               With the states' meager staffs and




some states have three people, and others have




30 in a region, we feel that extensive training is




needed and further manpower grants are in order.




               We would like to caution U.S. EPA



development of these regulations, and caution them




as to the element of time, and to build into the




system some one or two years of compliance schedules




so that the industry can prepare financially so




that the alternatives can begin to develop.




               We find in Ohio for example we are




lacking many incinerators, many wet chemistry




recycling centers, and very few solvent and oil




recovery firms.  We feel the alternatives must be

-------
viable or in line with the time that our landfills



are cut off.



               We are in Ohio doing what we feel



is one of the largest surveys in the nation on



hazardous wastes.  We are surveying 50,200 industries



after extensive negotiation with the Ohio Manufacturing



Associations, as well as with the laboratory council,



and we feel at this time legwork is most important



in defining where, if, and in what amounts' there is



a problem.  And what the name of it is, and where



it is at.



               We also need to know the mobility



factors and as they ultimately are being handled



in our state, and my last point is we are most



happy to report that we will be able to supply



the U.S. EPA with 18 categorical studies in



March or April of this next year, in hopes that



it will be of some benefit in determining national



policy.



               I'll entertain questions at this




point.



          MR. LEHMAN:  Thank you Mr. Brown.  Any




questions for Mr. Brown?




               Mr. Kovalick.






                      685

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          MR. KOVALICK:  Perhaps for the benefit




of the record, and the audience and myself, you




can talk about the proposed regulations you are




considering and whether they parallel perhaps the




Minnesota experience which speaks of waste control




from generation to storage, treatment; disposal and




through the various forms and so forth, or I guess




it's the traditional approach of upgrading the




facilities in that circuit, and I guess trusting




that the waste will flow in the appropriate spots.




          MR. BROWN:  To that extent we'll be having




a public hearing in January. We have not yet had




one in OhioJ we have had consultation hearings,




but we do feel that there is a lot of merit in the




California system, particularly that of classifying



either class 1 sites of existing landfills as can




best be handled.




               There must be continued use of these




sites and parallel development of hazardous waste




treatment centers.




               We also -- there was another point




brought up earlier about the shipping requirements,




and we felt that the U.S. requirements should be




utilized to a great extent, and possibly with a

-------
slight amount of modification and could provide a




great deal of continuity because these powers




currently are required to comply with that.




               And, perhaps it is not necessary




for us to use that system and we find it to be of




great use in Ohio.




          MR. LEHMAN:  What is the date of the




hearing in Ohio, and the location?




          MR. BROWN:  We will be having a hearing




and this is just tentative, the announcements will




be in the major papers in Ohio shortly, I do think




the first two weeks in January, and that period




there.  And most likely in the state office tower,




which is in Columbus, Ohio.




          MR. LEHMAN:  Any other questions?  Yes




I see one.  Just a minute Mr.  Brown.  1 have another




question.




               It's a question from the audience.




You suggested building in a time element of one




or two years for compliance.  Would you liberalize




this to possibly two or three  years as equipment



delivery is sometimes six months or more.




          MR. BROWN:   Equipment delivery in what




aspect?

-------
          MR. LEHMAN:  Well, I assume the question



is addressed to the long lead time of delivery of



equipment for treatment or disposal facilities.



          MR. BROWN:  What we envision is that we



would like to see a hazardous waste treatment



regional center developed in a period of time



before making extensive capital outlays.  We



believe this is a division that the manufacturers



endorse because they are running short on space.



And also have the capital to do this.  And they



might at this point in time support regionalization



treatment.



          MR. LEHMAN:  Can the concept of regional-



ization -- in your statement, well, what is your



state's position with regard to handling waste from



out of state?  Within a regional system?



          MR. BROWN:  We feel that the state borders



should not be held as a wall or a barrier, in the



migration of hazardous waste to the extent that  the



state could handle the existing treatment centers,



or permitted centers because the fact of the matter



is the marketing centers are very often widely




spread across borders.



               We have currently that practice going
                        668

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on in Ohio and it seems to me to be viable for



existing centers.



          MR. KOVALICK:  Your statement reminds



me of Mr. Walker's comments this morning, in one



of his comments he was suggesting possibly a



franchise system in order to guarantee enough



business for regional centers.  Is that what's



contemplated in Ohio?



               Whether it's publically or privately



operated but some kind of an exclusive system?



          MR. BROWN:  No, I don't believe a franchise



or exclusive system is being contemplated;     we want to



allow the market to develop on its own merits.



          MR. LEHMAN:  Are there any other questions?



Thank you very much Mr. Brown.  Next I would like



to call Mr.  Gary Wright of the Illinois Department



of Public Health.



          MR. WRIGHT:  Mr. Chairman, members of



the panel and ladies and gentlemen,  my name is



Gary Wright.



          MR. LEHMAN:  Excuse me Mr. Wright,  please



get in closer to the microphone.



          MR. WRIGHT:  My name is Gary Wright, I



am here today representing the Illinois Department







                      663

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of Public Health to discuss the Department's




involvement in the transportation and disposal of




radioactive wastes in Illinois.




               Although as the Chairman indicated




radioactive wastes are not an issue at this meeting,




we feel there are parallels to be drawn in my




presentation here today.  Virtually all operations




that produce or utilize nuclear materials generate




radioactive waste,  protecting the public health




and safety requires that radioactive waste be




isolated from humans for the time they may pose




a health hazard.




               Radioactive wastes are generally




classified as high level wastes or low level




wastes.  High level wastes under existing regulations




are transferred to the custody of the U.S. Nuclear




Regulatory Commission, for storage or disposal




at U.S. repositories.




               Low level commercially generated




radioactive wastes are generally disposed of




according to the type of  radionuclides contained




in the waste, and the physical status of the waste.




               Liquid and gaseous wastes are




usually treated, diluted or held for radioactive

-------
decay and then released to the environment.  Solid




wastes, sludges, and solidified liquids are disposed




of by burial.



               There are currently six licensed



commercial low level radioactive waste burial



grounds in the United States ,  one  of which is




located near .Sheffield,  Illinois.



               Because of the necessity for perpetual



care, all commercial disposal sites are required to



be located on Federal or state owned land.  The



Sheffield   site is owned by the State of Illinois.



               In 1963 the General Assembly of the



State of Illinois enacted the radioactive waste act,



which provides for the acquisition by the state of



land for the purpose of disposing of radioactive



wastes in a manner consistent with the public health



and safety.



               The act also stipulates that the



operation of any and all sites required for the



concentration and storage of radioactive wastes



shall be under the direct supervision of the Department



of Public Health, and shall be in accordance with



regulations promulgated and enforced by the Department




to protect public health and safety.






                      671

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               In 1965 the Illinois Department of
Public Health with the assistance of the Illinois
Geological Survey, established criteria for radio-
active waste burial sites in Illinois.
               The criteria set forth state require-
ments for topographical, hydrological and geological
features of the site.  As well as population density
surrounding the site and the transportation facilities
to the site.
               In addition, various operating pro-
cedure requirements are set forth in the criteria.
In 1966 the State of Illinois acquired a 20 acre
disposal site                  near the town of
 Sheffield.
               Operation of the site began in August
of 1967 and to date some 1.8 million cubic feet of
waste have been accepted for burial at the site.
               Burial operations at the site are
carried out by contractors who are licensed both
by the United States Nuclear Regulatory Commission
and the Illinois Department of Public Health.
               Responsibility for perpetual care
of the site once operations cease rests with the
State of Illinois.

                        672

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               Over the years the Department




has maintained comprehensive programs  of  inspection




and surveillance at the   Sheffield site.




               Quarterly  health  and  safety  in-




spections are performed by the Department  in  order




to insure the health  and  safety  of operating  personnel.




And in order to insure -- inspect burial  procedures.




               The environmental  surveillance program




monitors air, water and soil to  insure  that no  radio-




active materials are  migrated from the  site.




               On November 26, 1975  the Department




adopted by reference  U.S. Department of Transportation




regulations, CFR Title 49, covering  the packaging




and transportation of radioactive materials including




waste materials.




               Department regulations  now  cover  both



interstate and intrastate transportation  of radio-




active wastes in transit  to the   Sheffield waste




disposal site, as well as other  radioactive material




transporters.



               Enforcement of these  regulations




will be carried out principally by the  Department




of Law Enforcement and the State Health Department.




The primary philosophy involved  in the  burial







                       673

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of hazardous wastes is the isolation and containment




of those wastes.




               In 1974 U.S.G.S. report prepared




at the request of the EPA listed several characteristics




for evaluating any radioactive wastes and disposal




sites and suitability for preventing migration of




wastes.




               Those characteristics specify that




the site should be generally devoid of surface




water, erosion and weathering should not be at a




rate which can significantly alter the land surface




over the next few hundred years, the hydrology must




be such that flow from the disposal site does not




lead to areas which provide potential pathways to




man, such as fractured bedrock, public waterways




and  aquifers used  for water supplies.




               The hydrogeologic conditions must



be simple enough for reliable residence time




predictions to be made.  The predicted residence




time of radionuclides must be on the order of




several hundred years, the natural water table




should be below the disposal site by at least




several meters, and large water table fluctuations




should be unlikely.

-------
               The characteristics of the  Sheffield




site are in general in good agreement with these




U.S. geological survey guidelines.




          MR. LEHMAN:  Thank you Mr. Wright, I




have a question or two, perhaps we could get to




some of these items.




               You indicated that there is a




quarterly surveillance and monitoring program




at the Scheffield site.




          MR. WRIGHT:  Correct.




          MR. LEHMAN:  Who does this monitoring,




who pays for it?




          MR. WRIGHT:  The State of Illinois does




monitoring also the contractor does monitoring




of the site.  The state's program, eventual care




for the site will be provided for through the



-- by a fund which at the present time is 5 cents




per cubic foot of waste at the site.




               And this money is given to the




state by a contractor who presently is in the




process of renegotiating.




               We never had that particular assessment




but at the present time the firm does take care of




the monitoring that's done by the state.
                        SV5

-------
          MR. LEHMAN:  Another question.  Do non-




radioactive wastes including perhaps non-radioactive




hazardous wastes go into the Sheffield  site or is




it exclusively for radioactive wastes'




          MR. WRIGHT:  The purpose of  it  is exclusively




for radioactive.  There is chemical waste adjacent




to the radioactive site.




          MR. LEHMAN:  So that they are co-located




but separate.




          MR. KOVALICK:  You were suggesting that




you might take some examples from the  radiation




field in terms of industrial waste, and cited the




fact that all of the sites to which low level



wastes are taken are on  publicly owned  land.




And is it your view being what you heard  here today,




or your experience in radioactive waste that that




should be the approach for all hazardous  industrial




wastes?




          MR. WRIGHT:  It seems that it could be




the  solution.  * a™ not  that familiar with all




of the ramifications, but for wastes which present




a hazard over a long term, I see that  this is




one way of insuring that perpetual care will be




maintained for that particular site.
                             BIB

-------
                Of course  it's  one  of  the  few  things




that hopefully  is perpetual.




          MR. LEHMAN:  Question  from  the  audience.




What percentage  of waste  dumped  in Sheffield  is




generated by public versus private sources?




          MR. WRIGHT:  That's  difficult to  answer.



Much of the waste that comes to  Sheffield is




generated by other publicly owned  institutions,




the number that  sticks in my mind  I think the




nuclear power field generates  some 60  per cent;



of the remaining 40  percent, how  much ot that is




actually there  I really couldn't say.




          MR. LEHMAN:  Is the  5  cents  per cubic




foot charge which you mentioned  for perpetual care




fee, is that a  separate charge exclusively for the




State of Illinois?




          MR. WRIGHT:  It is included  in  the  price




which is regulated by the State  of Illinois.




               It's the total  price of care.




          MR. LEHMAN:  What is the total  charge



then to the customer?




          MR. WRIGHT:  It was  recently revised but




I believe it is $1.35 per cubic  foot, but I would




have to check on that, it may  have been recently
                        677

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changed and I'm not sure.




          MR. NEWTON:  Mr. Wright, I have a question




from the floor and before that for the sake of the




record, could I ask you to distinguish please  between the




term low level radioactive which you used a couple




of times, from high level radioactivity?




          MR. WRIGHT:  Well, in our particular case




we have one -- at the present time we limit the




waste that goes into the  Sheffield  site to one




curie per cubic foot and anything below that is




acceptable at the site as long as it's acceptable




in solid form.




          MR. NEWTON:  Thank you.  The question from




the floor -- has the State Department of Public




Health found any violations on the regulations which




warrant an enforcement action by litigation?




          MR. WRIGHT:  With respect to what feature,




actual burial or burial procedures exceeding the




limits?




          MR. NEWTON:  I would take it at any --




any litigation?




          MR. WRIGHT:  To my knowledge, there has




been no litigation involved in the . Sheffield  site. .
                         678

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Although there have been  some modifications  and




some citations.




          MR. LINDSEY:  Question  from  the  floor.



If the  Sheffield  site becomes  filled, will  the




State take steps to acquire another  site and license




the same as was provided  for by the  1966 act?




          MR. WRIGHT:  The law  still exists  under




which the present site was acquired; it's  hard to




say under the present circumstances whether  or not




an additional site would  in fact  be  required.




          MR. LINDSEY:  Did you say  how long the




site that's presently there, how  long  you  expect




it to last?




          MR. WRIGHT:  There are  a couple  of things




taking place at the present time  that increase




the present capacity of the site.  One of  which




is an acquisition of additional land  surrounding




the present site, and another is  a method  by



which utilization of the  original 20 acres will




be improved.  If both of  these actions will  in




fact take place I believe the Sheffield  site



will -- the capacity this will provide will  allow




us to go approximately tothe year 1990.




          MR. LEHMAN:  All right, there's  a  question,

-------
Mr. Klepitsch.




          MR. KLEPITSCH:  This is actually  a  series




of three.




               I believe the solids were -- how  are




liquid toxics handled, I believe you  indicated




only solids are handled.




          MR. WRIGHT:  It's up to the generator of the waste




to solidify.




          MR. KLEPITSCH:  Or how are  they covered?




How are such wastes covered every d ay?




          MR. WRIGHT:  The waste when it is accepted




of course is packaged, it's not open.  And  for the




most part it's in 55 gallon drums.




               I don't believe there's a requirement




at the present time for daily burial  of all waste.




In fact, there's a provision for storage for  limited




t ime s.




          MR. KLEPITSCH:  It goes on  and asks are




they mixed with any other materials and lastly are




they classified or kept separate or are all materials




mixed together?




          MR. WRIGHT:  They are mixed.  Of course,




one of the processes for certification is of  course




-- please repeat part of that question.

-------
          MR. KLEPITSCH:  I think you just answered

it.

          MR. LEHMAN:  Are there any other questions?

Evidently not.

               Next I'd like to call Mr. David Russell

of the IMC Chemical Groups.

          MR. DAVID RUSSELL:  My name is David Russell

and I am a consultant and one of our plants happens
                                     i
to be a manufacturer of primary explosives.

               I would like to start out just very

briefly by defining according to a book that has

been submitted into evidence is a publication --

No. 3 of the Institute of Makes of Explosives, it's

the suggested code of regulations, and I'll read

from that for a moment, as far as what the definition

of an explosive is.

               Explosives -- any chemical compound

mixture or device, the common purpose of which is

to function by explosion.

               The term includes but is not limited

to dynamite and other high explosives, black powder,

pellet powder, initiating explosives, , detonators,

safety fuses, squibs, detinating cords, and igniters.

               It goes on -- the definition goes
                      681

-------
on extensively to define a few more things.




               The client manufactures  a  very  diverse




group of products including pentarachlor,  tetranitrate,



nitroglycerine, nitrostarch or treated flower dynamite,




and many forms of  ammonia and nitrates, nitrocarbo-.




nitrates, and forms of nitrocellulose.




               All of these have  fundamentally




several things in common.  One of which is  they




decompose in an extremely violent or explosive




manner.




               Generally I think  the other  common




characteristic  is that they have   what  is referred




to as a very high burn rate.  We  are talking about




products which decompose at a rate of between  10,000




-- I should say in excess of 10,000 and in  some  cases




several hundred thousand, three,  and four  and  five



hundred thousand feet per second.




               These compounds should not  in any



way be confined.  This gives us a very  interesting




problem as far as waste disposal  is concerned,




we butted up against several regulatory agencies




in this fashion.




               In some states we  have been  in  contact




with the DER or Environmental Protection  Agency  and
                            G82

-------
they advised us to burn this, in an incinerator.




Well, this violates every principle of safety that




we feel is fundamental to the explosive industry.




We do not want to confine this in any way, shape




or form.  If it's going to blow, it's going to blow




and we don't want any confinement or anything else




flying around other than the debris that happens to




be associated with the particular compound being




disposed of.




               Other states have an absolute pro-




hibition on burning.  They advise burying the wastes,




I'm sorry -- some states don't allow burying, they




allow burning.




               In one state recently we ran into




regulatory situations where one division in the air




pollution side was saying kindly dispose of your




wastes by burning -- I'm sorry, by burying.  The




other land pollution division was saying dispose




of your wastes by burning them.




               With a conflict like this we aren't




left with much choice.




               It's not an easy subject.   It's a




very complex subject and there are many many types




of explosives, incindiaries,  and other devices.







                             683

-------
               In general I think  the  position  that  we




would like to be put forward by members  of  the  IME,




or Institute of Makers of Explosives,  is  that they




feel that the best disposal for explosive and




explosive contaminated wastes  is open  burning,




unconfined burning.




               Generally these wastes  have  small




quantities and are at extremely remote locations,




primarily due to safety considerations,  but  there




are other•considerations as well.




               Much of the waste can be waste product




explosives, waste dynamite, and other  products, but




there is also  a" substantial quantity of contaminated



waste paper.




               This is not a quality -controlled




product.  This is a waste product.  There are




several problems associated with the disposal of




this.  Burial is not the final solution.  It




requires a dedicated land facility, and  there are




materials which you must put into  this facility




that are not amenable to volume production •  Fd£




example, I don't know of anyone in the explosives




industry who would even go so  far  as to  suggest




using the compactor.

-------
               The results could be most disturbing.




                               (Laughter.)




               And I think the final problem  is that




it poses one of an  even  greater liability/ a landfill




site although it's well run, and all that, where does




the liability really quit?  We try and cover  up in




our own plants all of the waste products daily.  But




who is to say that the hunter or the trespasser is




not going to come along -- across that stick  of




product which is going to be misused.




               And frankly it worries me.  As I




think we should be worried.  We feel that open




burning or burning in some type of approved device




as yet unspecified, and as we understand it there




may be devices like this which are under development,




but at this point these devices are not available.



               Open burning is by far at present




the best solution available for disposal of this




particular type of waste.




               I'll entertain questions now.
                             665

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           (Z)AUMERCIAJL SOLVENTS CORPORATION

                   TERRE HAUTE , INDIANA
                      January 12, 1976
U.S. Environmental Protection Agency
Office of Hazardous Wastes Management
(AN 465)
Washington, D.C.  20460

Attention:  Mr. John Lehman

Gentlemen:

        I would like to amend my remarks presented on
December 1, 1975 at the O'Hare-Kennedy Holiday Inn in
Chicago.

        I have recently became aware of a publication
#21 of the Institute of Makers of Explosives.  This
subject deals directly with the destruction of waste
explosives.  I would like to submit this publication
for consideration and would like to have it submitted
into evidence in lieu of publication #3 of the 1MB,
as it deals directly with the subject of destruction
of explosives wastes.

        If you have further questions on this subject,
please let us know.
                            David L. Russell, P.E.
                            Environmental Engineering
                            IMC CHEMICAL GROUP
DLR/pc

Encl-IME Pub #21
                                  68S

-------
 n&TITUTE OF?

   AfCEFKS OF

   XFM.O8IWE8
SAFETY LIBRARY •  PUBLICATION NO.
21
  HOW TO
    DESTROY
      EXPLOSIVES
        OO I      January, 197O

-------
       TITUTm. OF

       AKER8 OF
                         42O LEXINGTON AVENUE
                         NEW YORK, N.Y. 1OO17
             MEMBER COMPANIES

   APACHE  POWDER  COMPANY
   Benson, Arizona 85602

   ATLAS  CHEMICAL  INDUSTRIES, INC.
   Wilmington, Delaware 19899

   AUSTIN POWDER COMPANY
   Cleveland, Ohio 441 13

   THE DOW CHEMICAL COMPANY
   Midland, Michigan 48640

   E. I.  DU  PONT DE NEMOURS & CO., INC.
   Wilmington, Delaware 19898

   THE ENSIGN-BICKFORD COMPANY
   Simsbury, Connecticut 06070

   HERCULES  INCORPORATED
   Wilmington, Delaware 19899

   IRECO  CHEMICALS
   West Jordan, Utah 84084

   MONSANTO  COMPANY
   St. Louis, Missouri 63166

   TROJAN-U.S. POWDER
   Division of Commercial 5o/venfs Corporation
   Allentown, Pennsylvania 18105
NEPCO—371—10M
6SO

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                      HOW TO
          DESTROY EXPLOSIVES
  It is often necessary to destroy commercial explosives and blasting
agents. These explosives may be fresh material from containers which
have been broken during  transportation, usable material for  which
there is no further need on a job, or they may consist of material which
has deteriorated or which has become unfit for use  through some sort
of damage. Deteriorated or damaged explosives may be more hazardous
than those in good condition and, hence, require special care in han-
dling and disposal.

  Deterioration of explosives may occur after prolonged storage, par-
ticularly  under  conditions  of  high moisture  and  high temperature.
Explosive stocks should always be rotated  in the  magazine so that
older material is used first.

  EXPERT  ASSISTANCE IS POSITIVELY RECOMMENDED
IN DESTROYING EXPLOSIVES. THE INSTITUTE OF MAKERS
OF EXPLOSIVES HAVE AGREED TO  SUPPLY ASSISTANCE
IN DESTROYING COMMERCIAL EXPLOSIVES TO  FIRE DE-
PARTMENTS, LAW ENFORCEMENT  AGENCIES, INSPECTION
AND REGULATORY BODIES, AS WELL AS TO USERS OF
EXPLOSIVES. IF THE MANUFACTURER IS  KNOWN, SEEK
HIS ASSISTANCE. IF THE MANUFACTURER IS UNKNOWN, A
MEMBER COMPANY OF THE  INSTITUTE OF MAKERS OF
EXPLOSIVES  WILL  SUPPLY THE ASSISTANCE REQUIRED.
A LIST  OF MEMBER COMPANIES APPEARS OPPOSITE.

  Disposal of bombs or ordnance items should be  referred to appro-
priate military or police authorities.

WARNING — A preferred  method of destroying dynamite,  primers,
boosters,  slurry explosive, and detonating cord is by burning. It must be
assumed that there is always a possibility of an explosion when any of
these materials is being burned. Consequently, it is important that a
place be chosen for burning which is far enough away from any dwell-
ing, railroad, highway, or other place where people may assemble, to
eliminate the  possibility of  injury to persons, or damage to property,
should an explosion occur.

  Every precaution must be  taken when destroying explosives or blast-
ing supplies to make certain that only one type is destroyed at a time.
Dynamite,  primers, black powder,  detonating cord, and safety fuse
must be examined carefully to make certain that no detonators of any
kind are  included. Any attempt to burn these materials when caps of
any description are included will almost certainly result in an explosion.

-------
  The American Table  of Distances,  prepared by  the  Institute  of
Makers of Explosives, specifies the quantity of explosives  that may be
stored safely at  various distances from  inhabited buildings, passenger
railways, and public highways. The 2  to  100 pound portion of the
American Table of Distances  (as revised and approved June 5, 1964)
dealing with the  separation of unbarricaded explosives storage buildings
from inhabited buildings is given below:

    Explosives      Distances            Explosives       Distances
    (Pounds)         (Feet)              (Pounds)         (Feet)
      2-5           140               30- 40          280
      5-10           180               40- 50          300
     10-20           220               50- 75          340
     20 - 30           250               75 - 100          380

  Explosives should be burned at distances not less than those specified
in the table for  the quantity involved. These  minimum distances will
protect  persons  against everything  but the missile  hazard;  to  guard
against missiles,  they must stand behind and  under suitable cover in
case missiles develop.  The  minimum distances  will  also protect the
buildings against major structural damage. Obviously, if it is practicable
to do so, the burning should be carried out at distances so great that
there  is no chance of either missile injury or minor damage to  build-
ings. No burning should be done near magazines.

DYNAMITE — When properly stored  and cared for, dynamite  will
remain in good condition for long periods, in many instances for years,
but it will deteriorate rapidly if improperly treated. Dynamite which
shows obvious signs of deterioration, such as hardness, discoloration,
excessive softness, or leakiness, should  be  destroyed. If the leakiness
has proceeded to the  extent of saturating the sawdust in  the bottoms
of the shipping cartons, or of staining the cartons, the dynamite should
not be touched except by a representative of an explosives manufac-
turer, members of a U.S. Army Ordnance  Explosives Disposal Team,
or under the direct supervision of a representative of the  U.S. Bureau
of Mines or a state or local agency designated to handle such explosives.
In addition,  dynamite may become unfit for use through some damage,
such as wetting,  and should be destroyed.

  Small amounts of dynamite  can be destroyed by exploding them in a
safe place, but this is not usually practical  where larger quantities are
involved. The most satisfactory method of  destroying dynamite is by
burning, which can be done safely providing certain  precautions are
taken.  It is advisable  to limit  the amount of dynamite burned at any
one time to not more than 100 pounds, and local conditions may make
it necessary to reduce this quantity materially.

  When burning large quantities of explosives, it is often  necessary to
burn more than  one pile  at a time. This is safe provided that: (1) the
distance from any dwelling, railroad, highway, etc., is not less than that
specified in the above table, (2) any persons involved are also at the
minimum safe distance as specified in the table, and are under suitable
                             6 3D

-------
cover in case of missiles, before the  first pile starts to burn, and (3)
the piles are separated far enough so  that there is no chance of propa-
gation. Propagation can be avoided by spacing the piles at least 25 feet
apart. This distance covers all quantities up to 100 pounds.

   Situations occasionally arise in which the quantity of explosives to be
destroyed is so large that it would be impractical to limit  the amount
to be burned at one time to 100 pounds. In such cases, consult an ex-
plosives manufacturer  before proceeding.

   Dynamite should never be burned  in shipping cartons or deep  piles.
Wooden shipping cartons should be opened with wooden  mallets and
wedges, using special care in this operation  if there are any signs of
leakiness. The cartridges should be removed, slit, and  spread over the
ground, preferably with a mat of loose paper or excelsior underneath
them. In  no case should  the  layer of  dynamite exceed two or  three
inches in  thickness. Some dynamites  are difficult to ignite, hence it is
necessary to have combustible fuel beneath the cartridges. If the dyna-
mite is wet,  it is advisable to pour a substantial quantity of  kerosene or
diesel fuel oil over it.  The pile  should be ignited by a small  pilot fire
of paper, wood shavings, or other kindling material arranged so that the
fire will have to burn several feet before it reaches any explosive mate-
rial. This  will allow the operator ample time to reach a place of safety
before there is any possibility of an explosion. It is also recommended
that the kindling be arranged so that it can be ignited on the downwind
end. After lighting the pilot fire, all persons should retire immediately
to a safe  place  until the dynamite has completely burned. Minimum
distances are noted above.

   When repeated burning is required, a new space should be selected
for each lot, as  it is not safe to place dynamite on the hot ground of
the preceding burning. No one should approach the burning  site until
he is absolutely sure all burning action is completed. Remote examina-
tion with binoculars or other such means is recommended. As soon as
all  dynamite has been destroyed,  the ground  where the material was
burned should be plowed. The residue from burning  dynamite contains
salts which  may be eaten by livestock and other animals with serious
results.

   Should magazine floors  become  stained  with nitroglycerin,  they
should be scrubbed well with  a mop, using a solution made by dis-
solving  1  pound of sodium sulfide (60% commercial) in ll/2 quarts
of water and then adding 3Vi  quarts of denatured alcohol and 1 quart
acetone.  The solution  should be used  freely  to  decompose the  stain
thoroughly.  If the magazine floor  is covered with any  material imper-
vious to  liquid,  this portion of  the floor  should  be  thoroughly swept
with dry sawdust to absorb the nitroglycerin and the sweepings taken to
a safe distance from the magazine and destroyed in the  same manner as
dynamite. The solution of nitroglycerin remover should never be added
to standing  liquid or unabsorbed nitroglycerin because of  the heat of
reaction resulting when mixed with large quantities of nitroglycerin.
Following treatment,  a final  scrubbing  with  water and detergent  is
recommended.

-------
EXPLOSIVES BOXES AND PACKING MATERIALS — All empty
explosives boxes, box liners, sawdust, empty bags and cartridges should
be carefully collected and destroyed. This is in part because they con-
stitute  a potential hazard,  and in  part because  livestock  and other
animals may eat the paper products with possibly fatal results.

  Burning is also the most satisfactory means for destroying such boxes
and packing materials. An explosion may take place during the burning,
however, either because a little loose  explosive is  still present or be-
cause the materials have absorbed some of the liquid  explosive. Thus
the burning must be carried out in the open, and in a location such that
neither injury nor damage will result in the event of an explosion. All
persons involved should proceed to a safe place, at least 100 feet away,
immediately after the fire is started.

  Waste materials  accumulated in loading  a shot should preferably be
burned after the shot has been made. If they  are burned before the
shot, the burning should never be carried out either  (1)  in the shot
area, or (2) before the holes have been stemmed.

PRIMERS  AND BOOSTERS — Primers  and boosters may also be
destroyed by burning. The primers or boosters should be removed from
their cases or cartons, spread on kindling material in a single layer,  and
burned with the same procedure and precautions as dynamite. Primers
and boosters should be checked before burning is started to assure that
no detonators are present.

WATER SLURRIES — Slurry or  water-gel explosives and  blasting
agents may be destroyed by burning. Some of these materials are diffi-
cult to ignite and a generous supply of kindling or the use of fuel oil
or kerosene may be required. The technique and safety precautions indi-
cated for dynamite should be used.

DETONATING CORD — The preferred method of destroying deto-
nating cord  is  by burning. It should not be burned on the "spool," or
encased in or wrapped  with any material that  is not part and parcel of
the cord by virtue of its design and manufacture. It should be strung out
in parallel lines one-half inch or  more apart on top of paper or dry
straw.

BLACK POWDER — This is best  destroyed  by  pouring the powder
into a large  quantity of water. Pellet powder should be removed from
its wrapper  to insure  quick  destruction. Destruction results from the
dissolving of oxidizing  salts (sodium or potassium nitrate).

ANFO — Ammonium  nitrate/fuel oil  (ANFO) mixtures may  also be
destroyed by immersing in water or by burning. Water pollution from
both ammonium nitrate and oil must be considered. If burning  is  em-
ployed,  the  technique  and precautions  for  burning dynamite  apply.
Considerable fuel is required to provide sufficient heat  to effect decom-
position during burning.
                                     6S2

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DETONATORS — Blasting caps, electric  blasting caps, delay electric
blasting caps,  non-electric  delay blasting  caps  and delay connectors
which have so deteriorated from age or improper storage that they are
unfit for use should be destroyed. These  devices should also  be de-
stroyed  if they have ever been under water, as for example, during a
flood, regardless of whether they have been subsequently dried out. In
some cases the shells of caps which have been wet and  then dried will
show signs of corrosion. Such caps may be dangerous to handle,  and it
is recommended that they not be disturbed  until a representative  of the
manufacturer has had an opportunity to pass on them.

  The method most generally used for destroying detonators is  to ex-
plode them  with  dynamite or a primer under some confinement as
described  below. Detonators should not be thown into small lakes or
bodies  of water,  such  as  rivers, creeks, ponds, wells,  or  water-filled
abandoned quarries.

BLASTING CAPS — If possible it is advisable to explode ordinary
(fuse)  blasting caps in the original containers. Otherwise they should
be placed in a small box or bag. A hole should be dug in the ground,
preferably in dry sand,  at least a foot deep. The container is placed in
the bottom of the hole and primed  with  at least  one-half pound of
dynamite  and  a good electric blasting cap or ordinary cap and fuse.
The  caps  and  the primed  cartridge  should be  carefully covered with
paper and then dry  sand or fine dirt and fired from  a safe distance. It
is recommended that never more than 100 caps be fired at  one time
and that the ground around the shots be thoroughly examined after the
shot to  make certain that no unexploded caps remain. The same hole
should  not be  used for  successive shots unless the entire inside surface
of the hole feels cool to the touch.

ELECTRIC BLASTING CAPS OR DELAY ELECTRIC BLASTING
CAPS — To destroy electric blasting caps or delay electric  blasting
caps, it  is necessary first to cut  the wires off about one inch  from the
top of the cap, preferably  with a pair of tin snips. No  attempt should
be made to cut wires from  more than one cap at a time.  Not more than
100  caps should be placed  in a box or paper bag,  primed with  about
one-half pound of dynamite and a good electric blasting cap, buried
under paper and sand or dirt, and exploded as described above. It  is
desirable, especially in the case of delay electric blasting  caps, to bundle
them together  so that the business ends are close together and in close
contact  with the primer. Of course, the same precautions mentioned in
the preceding paragraph should be observed.

NON-ELECTRIC DELAY BLASTING CAPS — Non-electric  delay
blasting caps should be destroyed by cutting the miniaturized detonating
cord off from as close to the top of the delay-cap assembly as possible.
The  miniaturized detonating cord should be destroyed by burning in the
same manner as  recommended for detonating cord.  The delay-cap as-
semblies should then be destroyed in the same manner as described for
delay electric blasting caps.

-------
DELAY CONNECTORS — Delay connectors may be difficult to initi-
ate in quantity by the above methods. Disposal should be referred to
the manufacturer.

ELECTRIC SQUIBS AND DELAY ELECTRIC SQUIBS —These
devices  should be destroyed by the same procedure as that used for
electric  blasting caps.

SAFETY FUSE — This material may be disposed of very satisfactorily
by burning in a bonfire.

ALL OTHER MATERIALS — The destruction of explosives  and
blasting supplies not included above should be referred to the manu-
facturer.

ALTERNATE METHODS — Manufacturers are familiar with  and
frequently employ means of destroying explosives and blasting  supplies
other than by the methods above described, and such other methods
may be employed, but only under the direction of the manufacturer.
                             SO CHILDREN
                          CAN'T GET HURT

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          MR.  LEHMAN:   Thank you Mr.  Russell.   Any




questions?




          MR.  LAZAR:   Can you tell  us please  as
                        6S5

-------
far  as you  know  how  does  the military dispose of




these let's  say  excess   ammunition and explosives?




          MR.  RUSSELL:  To the best of my knowledge,



there are some facilities available for military




explosives.   I understand and I was talking with




one  your own representatives who tells me that the



military burns old   Polaris Missiles in open burning.




          MR.  LAZAR:  What sites, do you know the



locations?




          MR.  RUSSELL:   I understand these are out



in the southwest  somewhere.




               But I do not  pretend to be an expert




in knowing exactly what the  military does in the



burning of their  armaments.




          MR.  LINDSEY:  I have a question from the



floor.




               Do you move explosives from one



state to another  for  disposal?




          MR.  RUSSELL:  Yes, we do.  Or you said




for  disposal,  well,  no.   We  do not.




               We do not  move explosives.  Partially




because this is  a non-quality controlled product.




On-site  disposal  is  the best practical alternative




at this time.  You get  into transportation regulations

-------
that I wouldn't even want to touch with a ten foot




pole.




          MR. KOVALICK:  When you describe the




number of frustrations you have in trying to get




good advice on what to do, with these explosives,




I was not left with the conclusion of what you do




tell your clients -- are they burying them or are




they burning them or storing them?  I guess those




were the three options.




          MR. RUSSELL:  Yes, to all three.




                              (Laughter.)




          MR. LINDSEY:  Do you know of any work




which is being done anywhere to -- I guess the




word is to demilitarize these things by chemical




treatment techniques or something like that.




          MR. RUSSELL:  Well, offhand no I don't.




I would imagine that there is for example I know




there are procedures generally used throughout




the explosive industry to decontaminate explosive




plants when they are finally cleaned up so we




presume they can move out of them and be safe,




but we're talking about from this standpoint,




much of the problem is not so much of disposing




of the stick of dynamite or the half ton of nitro
                       6S7

-------
carbonitrates, the problem    from a safety stand-



point, is the disposal of the contaminated waste



papers.



               I'll put it to you somewhat in this



manner -- given an explosives plant would you want



to accept the responsibility of taking their waste



paper regardless of their assurances that there was



no explosives in it?  I wouldn't.



               I think it is fundamentally that



simple.  We've got a product here if you'll excuse




the  vernacular, that can go boom.  "And a  resultant liability



with potential loss of life and limb, and I don't



feel -- I think that the 1MB is right in saying



that the best disposal of this is open burning.



               I might cite a case that I am



not totally familiar with, but I have some general



knowledge of, and if someone would like to correct



me or has better knowledge of it, I would appreciate



it, and I would be happy to stand corrected on this.



               To the best of my knowledge, there



is an explosives plant in the State of Illinois



that has a waste incinerator.  Now this plant



manufactures a type of pyrotechnic or incindiary.




Now, we're talking about a piece of material which







                      esa

-------
Is primarily like a safety flare, it's a slower
burning product.  They I understand have incinerators
and I have not seen them.  But this incinerator I
also understand that this incinerator has blown
up on them a couple of times.
               And this is a pyrotechnic, it is
not a high explosive.  I think this again goes
to characterize the type of problem.
          MR. NEWTON:  This is a question from the
floor, please.
               What is being done to eliminate
secondary reaction to decontaminated wastes?
          MR. RUSSELL:  That's a good question.
I hate to duck it, but I really don't know.   I
would venture to say that it may be a problem
that needs further investigation but then again
I just don't know.
          MR. LINDSEY:  Yes, I have a question
again from the audience.
               Does the IME sponsor research in
the area of sound waste disposal of waste products?
          MR. RUSSELL:  Very definitely.
          MR. KOVALICK:  Perhaps you'd like  to
identify the name of the  individual address  of
the IME.
                         6S9

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          MR. RUSSELL:  Yes, the IME is the Institute




of Makers of Explosives, they are at 420 Lexington




Avenue, New York, New York, zip code 10017.




          MR. LEHMAN:  Any other questions?




               Evidently not, sir, thank you very




much, Mr. Russell.




               Next I'd like to call on Mr. Dean




Gregg of the firm of Gaines and Moore.




          MR. DEAN GREGG:  Thank you Mr. Chairman,




I am Dean Gregg,  Senior hydrologist for the firm




of Gaines and Moore.  I'm a groundwater hydrologist




and have been for about 15 years, and many of those




years have been spent with the U. S. Geological




Survey.




               About a year and a half ago we started



performing some work for a client of ours, Commonwealth




Edison, in Ogle County here in Illinois.  Commonwealth



had purchased a parcel of land, a farm, for a right




of way, and some months later sometime later, three




dead cattle were  discovered in a creek, (intermittant




creek) coming from this property.




               The cattle were analyzed, tissue




samples were analyzed I should say, and were found




that the cattle died from cyanide poisoning.
                       TOO

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               The cyanide apparently came from




a large collection of drums and canisters that




had been disposed of in this intermittent stream.




And then lightly covered with soil.  We made a




thorough investigation of the soil, groundwater,




surface water, and other things for us to determine




the extent of the contamination and find out exactly




the hazard to the groundwater supply for the users




of this supply.




               Later Commonwealth Edison removed




the -- some 1500 canisters and barrels of cyanide




waste, some of the barrels were empty, had been




punctured, some still contained some of this material.




There was not only cyanide but there was also large




concentrations of cadmium, chromium, lead and zinc.




               The zinc had been deposited in a




-- more or less in a dry form and has since been




excavated.




               We conducted a series of tests in




the laboratory to try and determine the best way




of taking care of these cyanides that had contaminated




the soil.  Because the cyanide  was then a source




of -- the soild was a source material for the




cyanide to leach into the ground water supply after
                     701

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heavy rains.




               It was found after running various




types of tests that there were several types of




cyanides.  We had a rather simple alkali   salt




of cyanide, which was easily oxidizable,  and we




had a complex metallic cyanide which required much




heavier concentrations of our oxidant.




               After various -- testing various




things we determined that the most feasible solution




to use was sodium hydrochloride   to try and oxidize




the cyanide in the soil.




               We ran various field tests to determine




the permeability of it and infiltration rates of the



soil.  A system was designed, conceptually designed




and implemented this fall.  And the system briefly




was that the area  contaminated by cyanide was




clarified several feet deep, all of the brush




and excess vegetation was removed, and then the




soil was irrigated with the potassium  hydrochloride



solution for     a designated length of time.




               The rate of application and the length




of time of application was based on the thickness




of the soil and these soil properties.  We are at




present evaluating the results of this treatment of
                        702

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the contaminated soil.



               We are pleased to report that the



indications are that the treatment was quite



successful.



               As I said the zinc area was excavated



    we are hopeful,along with the cyanide.



               I'll answer any questions.



          MR. LEHMAN:  Thank you Mr. Gregg.  I think



we have a question here from Mr. Lazar.



          MR. LAZAR:  How do you involve any well



contamination cases in the area which could possibly



come from this disposal or maybe some other similar



practices   in the same general area?



          MR. GREGG:  How do I evaluate this?



          MR. LAZAR:  No, are you aware of this?



          MR. GREGG:  We have picked up abnormal



concentrations of cyanide in well water in private



wells and also in some of the test wells, monitoring



wells which we installed, and  incidentally we are



still monitoring selected wells.



               This is being done in the treatment



area and outside the area.



          MR. LEHMAN:  What was the distance of




these affected wells from the disposal site?






                        7G3

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          MR. GREGG:  We found traces of cyanide




In well water at distances -- I am saying roughly




of a half mile or greater.




          MR. NEWTON:  This is a question from the




floor.




               What was done with the cyanide that




was dug up?




          MR. GREGG:  The 1500 odd drum canisters




that were dug up were excavated under the care  of and



by a licensed waste disposal firm.




               These drums were taken to that facility



and disposed of in the proper manner.




          MR. LEHMAN:  Mr. Gregg, can you estimate




the cost to your customers for correcting this




situation?



          MR. GREGG:  I would hate to -- I don't




know if Mr. Jerusak would like to address that.




          MR. LEHMAN:  Please identify yourself.




          MR. EDWARD JERUSAK:  I am Edward Jerusak,




staff  analyst for Commonwealth Edison Comapny,




and I'm in charge of this project for the company.




And the cost for the whole project to date is in




excess of $300,000.




          MR. LEHMAN:  Thank you very much Mr. Gregg

-------
and Mr. Jerusak,




               I would  like  to go back  now  and




call upon some individuals who indicated that




they would like to give a statement but were not




here when they were called earlier.




               I would  like  to now call Mr, Phillip




Lindahl of the City of  DesPlaines.




             If Mr. Lindahl in the audience?  Is




Mr. Lindahl here?




               All right then, I would  like to call




upon Mr. David Dennis,  State of Michigan, Department




of Natural Resources.   Mr. David Dennis please.




               Evidently he  is not able to  appear




at this time.




               Well, ladies  and gentlemen,  that is




the end of our scheduled speakers for this  day.




I would like to thank all of you very much  for




coming to this meeting, and  I hope that you got as




much out of it as I know that we did.




               Now these speakers'statements were




extremely well thought  out,  and I am sure will be




very helpful to the United States EPA in its




further development of  guidelines and it is a




very important area.
                        7G5

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               I would like also at this time




to express our appreciation to the staff of EPA's




Region V which has done a great deal of effort  to




arrange the facilities for these -- for this




meeting.




               Let me just ask one last time, is




there anyone in the audience who does wish to present




a statement at this time?




               Okay, there being none, I declare the




meeting adjourned, and I thank you all very much.




                              (Whereupon the meeting




                               was adjourned.)
                     706

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                     PUBLIC MEETING

                       held at the

               HOLIDAY INN MEDICAL CENTER
                     HOUSTON, TEXAS
                Tuesday, December 9, 1975
                        8:30 A.M.
                      PANEL MEMBERS
John P. Lehman, Director
Hazardous Waste Management Division (HWMD)
Office of Solid Waste Management Programs, EPA

Alfred W. Lindsey, Program Manager
Technology Assessment, Technology Branch, HWMD
Office of Solid Waste Management Programs, EPA

Walter W. Kovalick, Jr., Chief
Guidelines Branch, HWMD
Office of Solid Waste Management Programs, EPA

Emery Lazar, Program Manager
Environmental Damage Assessment, Technology Branch, HWMD
Office of Solid Waste Management Programs, EPA

Donald B. Mausshardt, Chief
Implementation Branch, HWMD
Office of Solid Waste Management Programs, EPA

Herbert Crowe
Solid Waste Management Representative
EPA Region VI

-------

-------
                    P_ROCE E D ^ N G S_




               MR. LEHMAN:  Ladies and Gentlemen, I call this




Public Meeting to order.




               Good Morning, Ladies and Gentlemen.  My name




is John P. Lehman and I am Director of the Hazardous Waste




Management Division, Office of Solid Waste Management




Programs, U.  S. Environmental Protection Agency, Washington,




D. C.




               I would like to introduce Mr. Raymond Lozano,




Director of the Air and Hazardous Materials Division for




Region VI of the U. S. Environmental Protection Agency.




               MR. LOZANO:  Thank you very much.  Good




Morning.  I would like to extend a welcome to each of you




at this Third National Hazardous Waste Management Public




Meeting on behalf of Mr. John White, Regional Administrator




of EPA Region VI.




               The purpose of this meeting is to gain a




better perspective on needed guidance for the propoer manage-




ment of hazardous wastes.  Management of hazardous wastes




on  a national scale is approaching a critical level.




Problems associated with this issue are increasing at an even




more rapid rate in the states of Region VI.




               Your presence here today indicates you are




all concerned with this important environmental issue.  We




trust that each of you will actively participate in the

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 meeting.   I am sure that this will be a most profitable
 meeting for all present here today.
                At this time I would like to extend an
 invitation to each and every one of you to attend an Environ-

 mental Town Meeting that is being held at Sewell Hall on the
 campus of Rice University at 7:30 this evening.   Our Deputy

 Administrator, Mr. John Quarles, as well as our  Regional

 Administrator, John White, will be there to discuss some of
 the environmental issues that affect the Houston area.
                Thank you very much.

                MR. LEHMAN:  Thank you, Mr. Lozano.  Let me
 add my welcome to that of Mr. Lozano.
                The purpose of this public meeting, as
 announced in the Federal Register of September 17, 1975, is
 to gather information and data for the Agency as to the scope
 and nature of the hazardous waste management problem in this
 country and the need for and extent of guidance that should
 be developed by the Agency to help cope with this problem.
                For the purpose of  this meeting,  hazardous
 wastes are the non-radioactive discards of our technology-
 based society. They include the toxic, chemical, biological,
 flammable, and expolosive by-products  of  the Nation's
 extractive, conversion, and process  idustries.
                This is not a rule-making  or regulatory

 hearing.   The Agency does not hav.e 3  proposal or  a  statement
	         712        	

-------
to issue for comment.  This is a fact-finding meeting on the

record to solicit input from industry,  labor.Federal, State,

and local government and from other members of the public as

to the extent of the mismanagement of hazardous wastes and

the available or anticipated systems and technologies to

abate this problem.

               In order to provide a framework for discussion

today, the Federal Register notice announcing this meeting

suggested sixteen discussion topics that reflect issues of

concern to the Atency.   A commentary on these and any other

related topics are what we are most interested in hearing

today.  Copies of this Federal Register are available on the

table at the right in back of the room marked "Publications",

and I am also submitting a copy of the Federal Register

notice for the record.
               MR. LEHMAN:  The panel here with me is

composed of staff of the Hazardous Waste Management Division

in Washington and EPA Region VI in Dallas, who specialize

in certain subject areas related to this issue.  They are

from your left, Mr. Herbert Crowe, Solid Waste Management

Representative, EPA Region VI.

               Mr. Donald Mausshardt, Chief Implementation

Branch of the Hazardous Waste Management Division.
                              713

-------
               Mr. Walter Kovalick, Jr., Chief of the




Guidelines Branch of the Hazardous Waste Management Division.




               Mr. Alfred Lindsey, Program Manager of




Technology Assessment of the Division.




               Mr. Emery Lazar, Program Manager for




Environmental Damage Assessment, also of the Hazardous




Waste Management Division.




               In addition to this meeting in Houston today,




three other identical sessions are being held in Newark,




Chicago and San Francisco during these  first two weeks in




December.  Persons not wishing to deliver a statement here




or at the other meetings may send a written statement to the




address noted in  the Federal Register before January 31st,




1976.




               As our time here is limited, I would now like




to describe the procedural rules  for  this meeting, which I




feel will maximize the opportunity for  persons  interested




in speaking to be heard  and yet make  the best use  of all of




our time.




               Persons wishing to make  an oral  statement




who have  not  made an advance  request  by telephone  or  in




writing should  indicate  their interest  on  a registration




card.   If you have  not  indicated  your intention to give  a




 statement and you decide to do so,  please  return to the




 registration  table,  fill out another  card,  and give it to

-------
one of the staff.



               As we call upon an individual to make a



statement, he should come up to the lectern and, after



identifying himself for the court reporter, deliver his



statement.



               At the beginning of the statement, I will



inquire as to whether the speaker is willing to entertain



questions from the panel.  He is under no obligation to do so



although within the spirit of this information-sharing



meeting, it would be of great assistance to the Agency if



questions  were permitted.  It is expected that statements



will not exceed fifteen minutes in length.  For extraordinar-



ily long written statements, I would suggest a brief oral



summary and submission of the full text for the record.



               The Chairman reserves the right to close



off statements which are excessively long, irrelevant,



extraneous or repetitive.



               Assuming that the speaker is permitting



q\.;-stions, members of the audience will not be permitted to



directly question the speaker.  By raising your hand,



members of the audience may obtain a 3 by  5 card from a



member of the staff upon which questions may be written.



These cards will be collected by the staff and returned to



the panel for consideration during the question period.  If



a written question from -the audience is not presented to the

                              7-c f
                              in

-------
speaker, because we run short of time,  I will ask the




speaker to respond to those questions in writing for the




record.





               A transcript of the meeting is being taken.




A copy of the transcript, together with copies of all




documents presented at the hearing and all written submissions




will constitute the record of the meeting.  A copy of the




record will be available for public inspection by March 30,




1976, at the U. S. Environmental Protection Agency, Public




Information Reference Unit,  Room 2404, 401 M Street, S. W.,




Washington, D. C. 20460.




               In addition, I understand the court reporter




in Houston can make the transcript available from the local




source here for this meeting only.




               A VOICE:  Would you repeat that first address,




please?




               MR. LEHMAN:  It is in the Federal Register




notice, sir, but I will repeat it one more time.  It is




the U. S. Environmental Protection Agency, Public Information




Reference Unit, Room 2404, 401 M Street, S. W., Washington,




D. C. 20460.




               Finally, I would like to describe the day's




activities as we currently see them.  We will recess for a




half-hour break at 10:30 a.m., a one-hour luncheon break




at approximately 12:15 p.m.., and reconvene at 1:15 p.m.

-------
Another half-hour break will be held at 3:30 p.m.  Depending




on our progress, I will announce plans for a dinner break




after lunch.  At this time, we plan to conclude this meeting




today, and I would say most likely before dinner.




               In order to facilitate the comfort of all,




I suggest that smokers sit on the left side of the room




facing the front and non-smokers toward the right.




               This concludes my opening remarks.  I now




call upon Mr. L. P. Haxby of the Shell Oil Company to




deliver the first statement.




               Mr. Haxby.




               MR. HAXBY:  Mr. Chairman and Members of the




Panel and this great audience of Ladies and Gentlemen:  My




name is L. P. Haxby.  I am Manager of Environmental Affairs




for Shell Oil Company.  Mr. Chairman and Panel, you have




copies of my statement.  The press table has copies of my




statement.  For the purposes of the rest of the public,




there are some additional copies I left over on the press




table, if you are interested in having them.




               MR. LEHMAN:  Mr. Haxby, will you accept




questions?




               MR. HAXBY:  Sir, in my statement I advise we




plan to respond further to the questions, more of the




questions in the Federal Register.  I may wish to reserve an




answer to questions.  I will be glad to give it a try.

-------
               MR. LEHMAN:  Thank you.




               MR. HAXBY:  I am pleased to have this




opportunity to provide information to you on behalf of the




Shell Oil Company and its subsidiaries on the very important




subject of hazardous waste management.




               As you may know, Shell Oil Company is an




integrated oil company, having facilities for producing,




transporting, manufacturing and marketing Shell products




in 44 of our 50 states.




               Our subsidiaries, Shell Chemical Company and




Shell Development Company, are involved with products that




range from agricultural chemicals to synthetic plastics.




These products require involvement with many hazardous




materials in the  research phases.  Because of this wide




involvement, not  only geographically, but also in the




varieties of activities  in which we are engaged, we feel  it




is important for  us to share with you some of our thoughts




and  experiences.




               We believe that responsible industries can




better  handle  their waste disposal problems  with a minimum




of restrictive regulations.  We  cite two  examples  in which




we have been  involved  where  innovative management  has




provided solutions  to  waste  disposal better  than those  which




could have  been  accomplished with restrictive  regulation.




Neither of  these examples has  necessarily been the least

-------
 costly alternative for disposal of waste materials.

               The first of these examples is that of oily

waste disposal.  At one of our refineries prior to 1970,

experimental work had been done in disposal of oily wastes

by soil cultivation.  This attracted the interest of the EPA

and a contract was undertaken at this refinery to further

evaluate this method of disposal in early 1970.

               After a year of intensive study, we concluded

that oily wastes could indeed be environmentally disposed

in the prevailing soil and climatic conditions found in the

Houston area.  The EPA agreed with our conclusion.  Costs of

this soil disposal method, which included fertilizers, were

about three dollars per barrel of sludge containing 33 per

cent oil.

               More importantly, however, it was demonstratec

that this was a viable disposal method that could be

practiced on one's own property.  This practice, when

properly controlled, can provide for monitoring of leachate.

It is an effective disposal means which  is now being

practiced not only by ourselves, but also by other companies

               In 1974, after cancellation of a valid

Federal Ocean Dumping Permit, we were obliged to seek

alternative disposal methods for some 37 million pounds of

organic chloride wastes from one of our manufacturing

facilities.  Being aware "-of the experiences with ocean
                            ?•• t5
                             I J.C

-------
incineration ships overseas, we contracted with Ocean

Combustion Services to incinerate these materials in Federal

waters.

               In due course, this attracted the attention

of the EPA and after public hearings, permits were issued

for four separate burns at a site in the Gulf of Mexico, 165

miles southwest of Galveston,  Comprehensive aerial, marine

and shipboard monitoring were conducted in co-operation with

the EPA.  The results were reviewed in considerable detail

in a series of public meetings.  From this activity, the EPA

concluded that a new method of environmental waste disposal

had been practiced in the United States and that, and we

quote,  "Ocean incineration of these wastes under appropriate

permit  conditions is an environmentally acceptable means of

ultimate disposal insofaras  any adverse  impact on  the marine

environment is concerned."

               You may be  interested to know that the cost

of this incineration aboard  the  ship Vulcanus  was

approximately $1.3 million.  This cost does not  include  the

substantial cost  of key government  and industry  people  in-

volved in  the testing  and  monitoring of  this operation.

               Again,  this serves as an  example  that

 innovative management,  knowing both the  characteristics

 of the waste  to  be  disposed of and  the  practices of their
                             s.
 own industry, can provide  proper environmental disposal,

-------
 often setting the example or leading to new metholds of

 disposal previously unknown as was done in these particular

 cases.

                Shell has been, and will continue to be a

 responsible corporate citizen.  Our corporation's written

 public  policies state that we will strive to attain

 environmentally acceptable disposal techniques for all of our

 wastes.   In order to achieve this goal, we must have sufficien

 latitude to determine the best alternative disposal

 technique currently available for our own particular waste.

 Without such latitude,  innovative or new techniques can

 become  suppressed.

                Turning  our attention to some of the

 discussion topics listed in the Federal Register notice of

 September 17,  we would  like to offer the following comments.

                A specific,  narrow definition of hazardous

 waste is not practical.   Under some given condition,

 literally everything is hazardous.   The distinction must be

 made relative to the potential hazards of a waste under the

 conditions and location of disposal and the likelihood of

 eventual human contact.

                We suggest a broad definition such as follows:

 A hazardous waste is one which requires specially considered,

 soundly engineered  disposal methods to prevent substantial

 harm, short term and long term,  to human, plant or animal
	721	

-------
life.
               We believe that the generator of a waste has
the ultimate responsibility to find the proper method and
location to dispose of his waste.   However, we believe that
as the ownership of the waste is transferred from the
generator to the transporter, and finally to the treater/
disposer of the waste, the responsibility to properly handle
the waste in the manner and place described on the Bill of
Lading, Receipt Ticket, or Invoice must also be transferred.
               To properly audit and monitor such a proposal,
we believe that a three-part trip ticket approach should be
taken.  The three-part trip ticket approach allows the
appropriate state agency to monitor not only where the waste
is generated, but also how it is transported and finally how
and where it is disposed.  Several states  have now adopted
this  system.  California and Texas are examples.
               We believe that  a properly  informed public  is
necessary.  To achieve this  goal,  an  educational program
must  be  instituted  which emphasizes the fact  that hazardous
waste sites when  properly managed  and maintained, do  not

present  a  substantial hazard to the public.
               We hope these suggestions  will be helpful  to

you.   We do plan to submit more comprehensive written

comments to the  requested discussion  items in the  Federal
Register before  the close of the public record on January
                            712

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31, 1976.




               I would draw your attention to the attachment




with this testimony.  We have enclosed for your information




excerpts from our internal Company "Guidelines for




Contracting Waste Disposal."  This report, which has provided




guidance to Shell facilities in waste disposal matters for




some time, clearly details our Corporate commitment to safe




disposal practices.  If you have any questions, now I would




be pleased to consider them.




               Thank you, gentlemen and audience, for your




attention.

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                  SHELL OIL COMPANY
                            ONE SHELL PLAZA
                             P.O. BOX 2463

                           HOUSTON, TEXAS 77001


                           January 28, 1976
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs  (AW-565)
Environmental Protection Agency
Washington, D. C. 20460

Dear Mr. Lehman:

          Our oral  presentation (attached)  at the public meeting on
Hazardous Waste Management in Houston,  Texas  on  December 9,  1975,  stated
additional comments would be filed by Shell  before  the  close of the
public comment period.   We are enclosing for  your information additional
comments and recommendations on a number of the  discussion  topics  which
appeared in the "Federal Register" notice  of  September  17,  1975.

          We hope that the enclosed information  will  provide some
guidance to you in  developing a national perspective  on this important
subject.  If you should have any questions, about our comments, please
advise.

                                   Very truly yours,
                                   L.  P.  Haxby,  Manag
REOrddj                            Environmental  Affairs

Enclosures
                                       12k

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  THIS DOCUMENT HAS BEEN PREPARED SOLELY FOR THE INTERNAL USE OF SHELL OIL
  COMPANY WHICH ASSUMES NO RESPONSIBILITY FOR ITS USE BY OTHER PARTIES.
               GUIDELINES FOR CONTRACTING WASTE DISPOSAL
          Shell has emphasized its corporate commitment to comply with all  laws
and regulations that protect and improve the quality of the environment,  although
to dispose of waste materials that result from refinery, chemical  plant,  and
research laboratory operations may become more difficult as rules become  more
restrictive.  Often the disposition of these wastes is accomplished through a
contract waste disposal company, but the use of an independent contractor for
such a purpose does not necessarily relieve Shell  of all responsibility in  the
matter.  Therefore, we must ensure that the waste  disposal  contractor  is  meeting
his obligations safely and responsibly, and is complying with all  pertinent laws
and regulations.

          Locations contemplating the execution of a contract for disposal  of a
waste stream should consult with the Environmental Conservation Department,
Manufacturing, Head Office, regarding legislation  and regulations  on solid  waste
management practices and land use regulations.  There continues to be  considerable
legislative activity on these subjects, and because the Environmental  Conservation
Department normally keeps up with developments, they may be able to provide
early input influencing the decision to contract waste disposal.

          The unfortunate consequences of an incident involving an inept
or unscrupulous waste disposal contractor can be prevented or minimized by
observing some general rules.

          a.  Know the properties of the waste and the regulations governing
              its disposal.

          b.  Know the contractor and the facilities he has available  for waste
              disposal.

          c.  Both contractor and the Shell facility must fully understand
              their contractual  responsibilities,  obligations, and liabilities.

          Some  guidelines for waste  characterization,  contractor  selection
and  contract  provisions  follow  in  the  remainder of  this  report.   Although
they will not cover all  waste disposal  situations,  the guidelines can  help
to stimulate  critical  evaluation during project development.

          A.  Waste Characterization

              When a facility classifies a material  as "waste" and starts to
              seek a contractor  for its disposal,  it has usually exhausted  all
              reasonable or economic alternatives  for sale, storage or internal
                                          725

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THIS DOCUMENT HAS BEEN PREPARED SOLELY FOR  THE INTERNAL USE OF SHELL OIL
COMPANY WHICH ASSUMES NO RESPONSIBILITY FOR ITS USE  BY OTHER PARTIES.
            (Shell) disposal.   By that time, the facility's  laboratory,
            environmental  group, and process engineers have  defined well  the
            quantity of waste  to be disposed of, its composition, what leg-
            islation or regulations limit or apply to its  disposal (Head Office
            Manufacturing Environmental Conservation Department will  assist),  and
            any other special  or unusual  properties of the waste.  We should
            then ensure that all pertinent information including a complete
            explanation of the hazardous  properties, if any, is  released  to
            the potential  contractor and  that he understands it fully.  The
            contractor may wish to analyze representative  samples in  his
            laboratory (if he  has that capability) and we  would  normally
            encourage him to do so.  Proprietary information can be protected
            through execution  of a secrecy agreement, but  this  should be
            necessary very infrequently,  e.g., when disposing of licensed
            or proprietary catalysts, developmental  chemicals,  etc.   The
            contractor may plan to reclaim or recycle the  waste, and  a know-
            ledge of its composition may  help in negotiating a  favorable
            disposal price.

            Waste disposal contracts  should  not attempt  to be too definitive
            with respect to  the composition  of the waste material, since even
            a  slight variance  from a  stated  composition  could conceivably
            justify the contractor in refusing to  comply with his obligations
            under the contract.   Also,  it  is doubtful  that the composition of
            the waste can  always be defined  accurately.  Wastes  are normally
            analyzed by methods developed  for nearly pure materials,  and the
            accuracy and repeatability  of  the analysis may suffer as  the
            number of interfering components increases and the purity decreases.
            The composition  of the waste can vary, since it  is not manufactured
            to meet any specification and  may result from production  during
            startup or upset conditions.   Consequently,  in the contract it is
            best to define the range  of compositions of  the  waste material;  to
            make the contractor fully aware  of the chemical, toxicologic,
            and other properties of the "usual" or "normal"  waste material,
            and how those  properties  vary  as the composition varies over  its
            extreme limits;  and, to establish for the contractor the  pro-
            perties of the "normal" waste  and how those  properties vary over
            the composition  range.

            A  waste characterization  check list and  some definitions  that
            might be used  to describe the  waste or its properties should
            be provided.  Many of the properties described may  not be useful
            or interesting to  the contractor and may therefore  be ignored.
            (A little common sense can help  to prevent a great  deal of
            unnecessary laboratory work.)   For example,  a  precise definition
            of the freezing  and boiling points of a  liquid waste over a wide
            composition range  is probably  unnecessary; the contractor wants
            to know whether  the waste will freeze solid  in his  unheated
            storage tanks  or boil off on  a hot day.   Similarly,  the heating
                                         726

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THIS DOCUMENT HAS BEEN PREPARED SOLELY FOR THE INTERNAL  USE  OF  SHELL OIL
COMPANY WHICH ASSUMES NO RESPONSIBILITY FOR ITS USE  BY OTHER PARTIES.
            value will  be of interest only  if the v/aste  is  to  be
            incinerated,  and thereby becomes  an  indicator of whether
            supplementary fuel  will  be required.
        B.   Contractor Selection

            Before we contract with  a  waste  disposal firm for removal
            of wastes, we should determine whether  the contractor can
            do the job properly.  We should  weigh the experience,
            stability and reputation of  the  contractor, and his
            knowledge of regulations governing  the  disposition of
            waste materials  in the selected  manner.  At the same time,
            we must keep the contractor  fully informed about the
            material  to be handled and what  we  expect from him --
            frequency of pickups,  monitoring of landfills, other
            services  to be rendered, etc.  A contractor who will take
            any material  without knowing its composition and properties
            is not apt to give us  reliable,  liability -- free, long
            term waste disposal  service.
           We must  also  determine  the contractor's ability to handle
           and  transport the waste materials safely.  When the con-
           tractor  transports  the material and a second contractor
           or subcontractor operates the disposal facility, we will
           need to  determine the capabilities of both contractors.
           Both should be financially responsible and should provide
           necessary  liability insurance coverage on their operations.
           The  contractor should have the necessary permits for
           transporting  the waste material as well as for the disposal
           operation.  State regulatory agencies in Calfiornia, New
           Jersey,  and many other states have set up procedures for
           proper transportation and disposal of hazardous wastes, and
           we should  verify that the contractor is abiding with state
           regulations as well  as federal.
                                              727

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THIS DOCUMENT HAS BEEN PREPARED SOLELY FOR THE  INTERNAL  USE  OF  SHELL OIL
COMPANY WHICH ASSUMES NO RESPONSIBILITY FOR ITS USE  BY OTHER PARTIES.
            Many regulatory agencies  require  that  the  disposal  site be monitored
            to insure that no adverse environmental  damage  results from waste
            disposal  activities.   We  should determine  whether contractors
            under consideration can exercise  the required control of the
            disposal  facilities over  the  life of the contract.  Matters of
            waste material  segregation, maintenance  of records  and respective
            obligations should be  resolved before  contracts are finalized.
            Any waste pretreatment, specifications for containers, etc., which
            Shell  is  obligated to  perform, should  be defined in the contract,
            as should contractor responsibilities  for  pickup, vehicle registra-
            tions, etc.

        C.   Contract  Provisions

            As noted  previously, the  contractor must understand exactly what
            he is  disposing of. In many  cases the nature of the waste materials
            will  not  vary significantly from  load  to load and only cursory
            inspection and  occasional  sampling and routine confirming analysis
            may be adequate for control.  If  a change  in characteristics is
            critical  to proper handling and disposal,  representative sampling
            and complete analysis  may be  necessary on  a load-by-load or day-
            by-day basis.   Mixed loads of waste materials may present special
            problems  for Shell  and the contractor.   Improperly  characterized
            waste  materials can result in serious  problems for  both parties.
            The contractor  is not.responsible for  the  nature of the wastes we
            generate  and Shell  does not have  direct  control of  the waste
            handling  and disposal  practices of the contractor - the integrity
            of both parties must be maintained or  the  result circumstances
            will  be difficult, expensive, or  perhaps disastrous.

            Monitoring the  waste disposal contractor performance is essential
            to safe handling and disposal.  Arrangements to periodically
            observe his materials  handling equipment and methods and the
            ultimate  disposal facilities  and  practices should be established
            at the time-the contract  is developed.   Follow-up on the status of
            authorities to  transport  and  permits to  operate should be routine.
            It is  important that the  contractor activities  remain in compliance
          .  with all  applicable laws  and  regulations and permit conditions;
            Shell  can help  to make the contractor  aware of  changing requirements
            and, by providing guidance, can assist the contractor in complying
            with new  regulations.  Monitoring is particularly important when
            more restrictive regulations  are  being promulgated; when contract
            termination is  approaching; or in cases  where permit authority  is
            transferred to  a second party.
                                           723

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                         SHELL OIL COMPANY'S RESPONSES
                      TO SELECTED DISCUSSION TOPICS IN
                        HAZARDOUS WASTE MANAGEMENT
                              JANUARY 28, 1976


la.  Definition -  As discussed in our oral statement, a specific, narrow
definition of "hazardous waste" is not practical.  The distinction must be
made relative to the potential hazards of a waste under the conditions and
location of disposal and the likelihood and extent of eventual human contact.
We suggest a broad definition such as the following:

          "A hazardous waste is one which, when disposed of in sufficient
     quantities in or on the land, requires soundly engineered disposal
     methods to prevent substantial and persistent harm to human, plant
     or animal life."

Ib.  Criteria - Lists of specific criteria such as radioactivity, flammability,
reactivity, explosibility, etc., are found in many decision models.  However,
from a practical standpoint, the testing requirements necessary to completely
classify a waste by all  of its constituent properties seems to be an unduly
burdensome and unworkable requirement.  Some testing js_ necessary and the
amount of testing required will vary according to the nature of the waste,
the disposal method and the disposal location.  It is suggested that the
requirements under this section be compatible with the Department of Trans-
portation's H I System with any additional requirements such as toxicity,
for example, imposed only to adequately assure the safe disposal  of hazardous
wastes and at the same time to realistically minimize the quantity of wastes
designated as hazardous which must be disposed.

          Under some circumstances it will be desirable to segregate certain
wastes at the source by their various characteristics (non-hazardous vs. various
degrees and types of hazard) prior to disposal by contractors.  In most cases
segregation by a responsible, knowledgeable individual should obviate the need
for laborious analytical procedures before disposal  of a waste may occur.

Ic.  Sampling - Although the nature of some wastes permits only a grab sample
for- •analysis, in most cases the major characteristics necessary for classi-
fication of the waste will  be present.  Individual sampling techniques should
be left to prudent judgment depending on the nature of the waste and the
method and location for disposal.

Id.  Analytical  Methods  - Complex mixtures of wastes are difficult to sample
properly and even more difficult to analyze.  Frequently the process or
operation generating a waste involves a single principal reaction with minor
side products.   Information on the composition of the waste is generally available
at the source.   Such information can be used advantageously to help describe
the nature of the waste  and guide any further analyses that may be required
to assure the safe disposal of the waste in question.  Many standardized
analytical  procedures are available for sample analysis.  Modifications to
these existing  procedures should be required only to the extent necessary to
properly identify the waste.
                                           723

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2a.  Responsibility and Liability - Each particicant in the ultimate disposal
of a hazardous waste should act responsibly.  The various responsibilities can
be identified as follows:

    The Generator is responsible for:
            proper description and identification of hazards
            proper segregation
            proper packaging
         4) proper records

    The Transporter is responsible for:

         1) proper handling and control during movement
         2) proper delivery of waste according to Bill of Lading,
              Shipping Ticket, Contract, etc.

    The Treater/Disposer is responsible for:

         1) proper treatment and disposal of wastes to avoid
              contamination of the environment and danger to
              the public
         2) proper records


          Assurances that the generator, transporter, treater and/or disposer
of wastes has carried out his duties responsibly could be audited via a
well designed and enforced three part trip ticket system.  While this does
require additonal work for all handlers of hazardous wastes, the end result
of a well conceived program will be that appropriate state agencies will know
what Quantities of hazardous wastes are generated, where they are located,
how they are transported and where they are disposed.  Several states have
now adopted this system - California and Texas are examples.

          Each participant must also be aware that failure to carry out fully
Liie rebpunsibilities cited above can lead to liabilities.  In the past, the
generator has often been held responsible for consequences related to his
particular waste stream.  It is suggested that liabilities should be incurred
by the party responsible for a particular circumstance arising from his failure
to adequately carry out his particular responsibilities.

2b. Costs -  With the increasing number of regulations which must be complied with,
concern regarding the costs and availability of environmentally acceptable
disposal sites has mounted.  These costs and the burden associated with finding
methods of disposal for hazardous waste will ultimately be borne by the general
public either as consumers, taxpayers or stockholders.

3.  Special Requirements - Depending on disposal methods available, wastes may
become unwanted, undesirable, and useless substances.  Every effort should be
made to reclaim useful values from such wastes before relegating them to a
useless category.  Consideration of all avenues of useful recovery will take
time.  Therefore specification of time .leadlines or disposal methods may not
enable gainful recovery of such values because of the various factors which
must be taken into consideration whe_n choosing a disposal method.  In some

                                          730

-------
cases, the most expedient method may not be the best or most economical  choice
over the long term.  There must be sufficient latitude to determine the  best
alternative disposal technology currently available under the prevailing
economic conditions.  Without such latitude, innovative or new techniques  to
recover residual values can be suppressed.

4.  Special Treatment - For a number of specific cases technology currently
exists by which certain hazardous wastes may be detoxified or neutralized, but
a generalized, all-purpose procedure, universally applicable, does not!  The
waste generator should have sufficient opportunity to investigate these  possi-
bilities before an expedient method is proscribed.  Methods appropriate  for
detoxification under one set of conditions  may not be applicable to other
wastes or other conditions.

5.  Costs - Waste disposal costs must be examined on a case by case basis
allowing for differences in waste composition, disposal  location and the
prevailing environmental climate and circumstances.  In many cases, contracts
may involve not only potentially hazardous  wastes but also non-hazardous
wastes.  In specific instances costs can be supplied.  In our oral presentation
it was indicated that 37 million pounds of  chlorinated hydrocarbon wastes
were incinerated aboard the ship Vulcanus at a cost of $1.3 million excluding
the time and cost of numerous key government and industry people.  These
costs are now higher as a result of increased fuel and labor costs and the
added control measures required.

6.  Safety and Security - Facilities should be protected from curious  intruders
who may enter an area.  Regulations by OSHA and DOT currently protect  employees
who work in these areas.  Regulations proposed by EPA should be consistent
with existing safety regulations.  EPA should require additional measures  only
when absolutely necessary for the protection of the general  public.

7.  Site Monitoring - It is suggested that  records of the quantity, type and
location of hazardous wastes be filed on a  monthly or quarterly basis  to a
state or local regulatory agency involved in Solid Waste Management.  In the
case of all hazardous disposal areas, recorded land deeds should specify the
location of existing, or prior hazardous waste sites.

8.  Insurance Availability - No comment.

9.  Long-term Integrity - There is a paucity of information regarding  the  rate
of disappearance of degradable wastes in hazardous waste sites.  Information
to address this question should be accumulated by the operator of the  site.
Even if later information on rates of degradation become available, the  site
should be checked to confirm that the wastes are indeed being degraded at  the
expected rate and to certify when the wastes have been degraded to a safe
level.

10.  No comment.

11.  Transportation Safety - Current regulations by the Department of  Trans-
portation address this issue and current interpretation does not distinguish
between wastes and substances.

                                   73i

-------
12.  Labeling and Placarding - Again,  existing regulations by the Department
of Transportation published in Titles  49,  46, and 14 adeauately establish
requirements in this area.  Any new requirements established under a solid
waste authority should be consistent with  the present regulations.

13.  Damage and Cost - In the past,damages and costs have been assessed on
the direct momtary losses incurred in correcting an improper disposal  of hazardous
wastes.  Investigation has been limited to finding the generator and assessing
clean-up costs, etc.  It is recommended that damage and cost liabilities be
borne by the party responsible (see 2a) and be assessed according to actual
environmental and physical damage caused as a result of the failure of the
generator, transporter, treater and/or disposer to comply with their stated
responsibilities.

14.  Citizen Acceptance - As stated in our oral presentation, we believe that
the public who receives balanced information will accept the fact that hazardous
waste sites when properly managed and  maintained do not present a substantial
threat to health or the environment.  As a first step in this approach, an
education program should be established in the area near disposal sites. This
will  provide a more efficient and more easily implemented means of reaching the
directly affected public.

15.  Not applicable to our operations.

16.  Private Sector Participation -  We believe it will be necessary for both
the public and private sector to participate in the treatment and disposal  of
hazardous wastes.  We can visualize  certain wastes from Federal facilities
(notably arsenals) which may pose peculiar problems.  We believe any regulations
developed must take cognizance of such problems but they should not attempt to
prescribe specific solutions as a part of  the general  problem.
                                        732

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                MR.  LEHMAN:   Do  we  have  any  questions?
                MR.  KOVALICK:  Yes.

                MR.  LEHMAN:   Mr.  Kovalick.

                MR.  KOVALICK:  Mr.  Haxby,  in your  statement

 you commented that  Shell  has set a high mark  I  guess for
 other industries  to follow  in the  management  of hazardous
 wastes,  but you point out the disposal  methods  you  have
 chosen have not necessarily been the  least  costly alternative:
 and I was wondering if you  had  some thought on  what would
 motivate those industries less  responsible  than yours  to
 choose the higher cost alternatives?

                MR.  HAXBY:  Sir,  I  have  not  intended to try

 to hold Shell up  as an example  against  anyone specifically.

 We are pleading primarily throughout  this for an  opportunity,
	          '"  733	

-------
 a flexibility,  if  you will,  that flexibility which will allow
 one to dispose  of  things in  an adequate environmentally sound
 waste fashion in the most expedient method that he might
 choose to do that, subject to proper approval.
                MR. LEHMAN:  Mr.  Lindsey.
                MR. LINDSEY:   Mr. Haxby, you talked about the
 need for a latitude for developing new techniques and you
 talk about a trip ticket approach as being something you
 think that is needed.  Could you comment a little more on
 what other regulatory approach you see is necessary, if any,
 and perhaps what type of Federal initiative is necessary, if
 any?
                MR. HAXBY:  Well, as we know and as we stated,
 hazardous materials, nearly any material can become hazardous
 It does seem reasonable to us that there is some record, some
 monitoring by states, if you will, as  to what  is being
 disposed of where.  We  like the concept that certain states
 have adopted of designated sites for different classes of
 wastes.  We suggest  the three-part trip ticket to  go with
 that in a sense.
                We  suggest on  our own part  that we  need the
 innovative ability of flexibility.  To practice our

  innovative ability,  we  suggest  it  is our  responsibility  to
 go with Federal Regulations  and State  Regulations  to know
 who  our waste  disposer  is,  to know how he is disposing of it
	I o^j.      	

-------
 and where  it is  being disposed  of  to  assure  ourselves  it  is




 being done properly,  as  well.   Further  regulatory  practices,




 I  would prefer not to comment on at the moment.




               MR. LEHMAN:   Do  we  have  any other questions?




               MR. KOVALICK:  Yes.




               MR. LEHMAN:   Mr. Kovalick.




               MR. KOVALICK:  A question from the  audience




  asks     You to repeat Shell's suggested definition for




 hazardous  waste.




               MR. HAXBY:  Repeat  it?




                MR. KOVALICK:  Yes.




                MR. HAXBY:  We have suggested that a hazardous




 waste —   I beg your pardon.




                 If someone has  it,  would you like to read it?




                MR. LAZAR:  "A  hazardous waste is one which




 requires  specially considered,  soundly engineered disposal




 methods to prevent substantial harm,  short term and long




 term,  to  human, plant or animal life."




                 MR. HAXBY:  Right.




                 MR. LEHMAN:  Before we  go to the next




 question,  I  would just  like to identify Mr. Alan Corson  and




 Cameron Metcalf,  who will be handling  questions from  the




 audience  here.  They  are the two  gentlemen  standing at the




 rear with their three-by-five  cards.




                 Mr. Lind^ey, do you have  a question?




	,___    735	

-------
               MR.  LINDSEY:   Yes.   We have heard in Newark
and Chicago that disposal of laboratory waste is a problem
and you mentioned that you have a  relatively large research
facility, and so on.  Do you find  this to be so and can you
enlighten us on how Shell handles  these materials?
               MR.  HAXBY:  Yes.  It is a problem in certain
instances and, no,  I do not choose at this time to advise
you how we handle those.
               MR.  LEHMAN:  Do we have any other questions?
                (No response.)
               MR. LEHMAN:  Evidently not.
               Thank you, Mr. Haxby.
               MR. HAXBY:  Thank you, sir.
               MR. LEHMAN:  I would like to call at this  time
Dr. W. A. Quebedeaux from the Harris County, Texas Pollution
Control  Department.  Is  Dr. Quebedeaux here?
               We will have to come back and get these at a
later  time.
                Next I would  like to call Dr. Nugent Myrick,
Houston  Chamber of  Commerce.
                MR.  WESTNEY:  Mr. Chairman  and  members  of  the
Panel,  I am Jack Westney,  staff representative,  Houston
Chamber  of  Commerce,  appearing for Dr.  Nugent  Myrick,  who
apparently  had some emergency  arise so he  could not be here.
He is the expert in this field on  our committee and,
   	 	  	     T.sfi	

-------
unfortunately, I am not, so I would not be able to answer




questions, but I am prepared to give his testimony.




               MR. LEHMAN:  Could you please spell your name




for us for the record.




               MR. WESTNEY:  W-e-s-t-n-e-y,  Westney.




               MR. LEHMAN:  Thank you, Mr. Westney.




               MR. WESTNEY:  Most all elements of our




industrial society generate wastes.  In recent years,




multi-level governmental atmospheric and aquatic waste




management programs have been formulated and are currently




being implemented at a substantial pace.  In the case of




wastewater treatment, concentrated wastes which may not be




treated in a  dilute wastewater control system are excluded.




These  materials along with the concentrated residuals, that




is sludges, which result  from the dilute wastewater




treatment and the treatment of air pollutant control systems




wastewaters pose a new  type of waste management concern.




                It is  the  unique physical, chemical  and




biological properties of  selected types of  these residuals




that bring us together  today to discuss the fate of  these




materials in  the environment.  It should be emphasized that




this group of waste materials is not  new, just becoming more




significant as  more air and water pollutant control  systems




are becoming  operational.




                Therefore,  we should approach the development

-------
of  environmentally acceptable solutions in handling these




materials in an orderly technical manner.  Similarly, we




must educate the public on the handling of these materials




in our communities just as we have done for other wastes.




               We are pleased to note that the Texas




Legislature addressed itself to passage of legislation, Solid




Waste-Disposal Act, for control of these wastes in  1969.  The




line responsibility of regulatory authority in control of




these materials of industrial origin was assigned to the




Texas Water Quality Board.




               It  should  be noted that  this agency  has




responded  in  establishing information on previous handling




methods  of these materials as well as developed  strong




regulations on handling  them  today and  in  the  future.   In




this  regard,  this  agency has  either  just recently adopted or




is formulating —  and I  believe it has  adopted — new




regulations which  are very rigorous  with respect to




 identifying past waste handling practices on land,  as well as




 new regulations  for their storage,  collection, transportation




 processing and ultimate land placement.  We strongly support




 these efforts and are of the opinion that they will provide




 the basis for a responsible program by each waste generator





 in the  state.  Our cities are working to effect these




 requirements  to the  inner city smaller industries.




                At this point we should be concerned about

-------
the economic impact of these new requirements on both the




consumer and industry.  Due to the lack of understanding of





 the  reliability  of process  technoloav  bv  the  oublic,  regional




processing centers for these wastes often cannot be built in




or near our urban areas.  Similarly, ultimate disposal




facilities have not been developed.  As a matter of fact,




only one site exists  in Texas for the handling of many of




these materials.  Excessive transportation costs and the




wastage of energy must be  eliminated.




               Again, this can only be achieved by rigorous




 education programs  for  the public.  We are pleased at the




 recent  efforts in  this  regard by  your  agency  in explaining




 to the  public the  application of  incineration of specific




 wastes  in very specialized  equipment   in  the  Gulf of Mexico.




 Even though  this technology was used  in Europe, substantial




 improvements were  made  prior  to processing these wastes  in




 the  United  States.



                To permit  further  developments in technology




 in handling and  processing of rather  specialized wastes




 where limited  volumes occur nationwide,  we request your




 agency to provide assistance in developing nationwide proces




 center siting  policies, including appropriate transportation





 considerations.




                In closing, the most urgent consideration in




 the management of concentrated wastes which may possess

-------
limited hazardous properties is public education on proven




technology to solve this growing urban waste management




requirement.  This effort could lead to the understanding of




the need and acceptance for urban facilities to process these




materials for recovery of resources or energy volume reduction




or ultimate land placement in an environmentally acceptable




manner.




               These materials are generated in rather small




volumes from numerous locations and for the most part must be




processed locally.  Therefore, we are of the opinion that




major  line  responsibility of planning, permitting  and




monitoring  of operations and enforcement of regulations  in




all  aspects of management of these materials should be a




state  and local  activity.




               We request  that your  agency enhance its




educational efforts in  a very  positive mode, that  is,  not




dwell  on  the  past, but  project reliable  and meaningful




current technology and  assist  in pacing  new technology.




                Thank you.




                MR. LEHMAN:   Thank you, Mr. Westney.




                I understand that Dr.  Myrick is with us and




 perhaps might be able to answer some questions.




                MR. WESTNEY:  Yes.  I am sure that he could.




                MR. LEHMAN:  Do we have any questions from





 the Panel?

-------
               Mr. Kovalick.




               MR. KOVALICK:  Dr. Myrick, I was wondering,




in the prepared statement you suggest that the Agency provide




assistance in developing "nationwide process center siting




policies, including appropriate transportation considerations




Would you care to elaborate on that?  Are you suggesting




that the Federal government be involved in the siting policy




decisions and could you comment on that?




               DR. MYRICK:  I think the Committee's main




interest in this regard is basically along the line  that theie is




a lot of specialized wastes that require very intensive




solutions to the problem of solving and handling these




appropriately.




               What we would like to propose is to make sure




we do not have transportation barriers placed on the trans-




port of these materials in a safe manner.




               MR. LEHMAN:  You will have to speak closer




to the mike.




               DR. MYRICK:  O.K.  To repeat, our basic




interest is in regard to the fact that many small volume




wastes are generated to require a very unique intensive




solution.  We can handle these waste materials in a very




effective manner, provided we get the economy  of SCale necessary




to provide the facilities to handle the problem.  We see




some no  importation" barriers and we have heard of

-------
transportation problems across certain states and we need to




make sure we can move these materials to get to the best




processing facility to handle it.




               Now whether the Federal government owns it or




not is academic.  I think the key question  is to make sure




we have  the facilities available and there are no




transportation barriers permitted, provided they meet the




proper DOT specifications to transport.




               MR. KOVALICK:  Perhaps  I  can get you  to




elaborate.  Does your knowledge  of DOT regulations regarding




the transport of hazardous materials lead you to believe




that  they are in  themselves sufficient for the transport




phase,  and the  second part  to  that  is, are  they  sufficient




at the  treatment and disposal  site  in  terms of,  for  example,




 labeling and  placarding  of  the  waste materials?




                DR.  MYRICK:   You are asking  for  a  lot of




 generalized information  here,  you know.   In some cases,




 yes,  they are adequate.   In some cases they are not.




                Now I  don't think you can go down the laundry




 list of many hundreds of these lists at this time.  I think




there are administrative procedures that can handle the




 problem once we understand the concern,  but these things are




 not real until you say,  I   .need to process so much poly-




 vinyl chloride waste in the Gulf of Mexico and we agree that




 incineration at sea is a- valid method of handling this, and

-------
we need to get those materials, say, to Houston, Texas, and



put them on a ship to ao out.  Then you can sit down and staH"



addressing yourself to ways to get the material here and you



can very effectively find out the reality of this in its



true meaningfulness.



               The key issue is to make sure that we have



good credible end solutions to the problem and we can get an



economic scale to achieve that goal.



               MR. LEHMAN:  Do we have any other questions?



               I will remind the audience if you wish to



address a question to the speaker, merely raise your hand



and our staff will provide you with a three-by-five card to



write your question down.



               Thank you, Mr. Myrick.



               DR. MYRICK:  Thank you for being on time.



Your agency called and said be here at 9:00 o'clock, and I



walked in the door.  You are always very efficient.



               MR. LEHMAN:  At this time I would  like to



call Ms. Brenda Gehan of the League of Women Voters.



               MS. GEHAN:  Thank you.



               MR. LEHMAN:  Ms. Gehan, will you accept



questions?
      •


               MS. GEHAN:  Yes.



               My name is Brenda Gehan.  I am  Water Quality



Chairman  for  the Leagu

-------
 statement I  am presenting today is  given on  behalf of the


 League of Women Voters  of the Bay Area,  as well  as the


 League of Women Voters  of Houston.


                Our organization is  not a technical group,  but


 has studied  the problems  of solid waste  management and land


 use on the local,  state and national  levels.   We have


 locally encouraged the  efforts of the Texas  Water Quality


 Board and the Texas Air Control Board to enforce anti-


 pollution laws.


                Compliance by industries  with the provisions


 of these laws, along with a continuing expansion of tech-


 nology, has  intensified the problem of the management of


 hazardous wastes.


                The threat to public health and to the


 environment  posed  by the  indiscriminate and  unsupervised dis-


 posal of hazardous wastes is a concern not only to us, but


 to many other citizens.


                Documented instances of contamination of


 groundwater  because of  improper disposal of  hazardous wastes


 are readily  available.  For example,  there is the Perham,


 Minnesota case where eleven persons developed arsenic


 poisoning after drinking  well water taken from soil where


 fifty pounds of arsenic had been buried over thirty years


 previously.   Estimates  of the cost  of correcting the problem


 are around $28,000.00,  an approximate cost of $560.00 per
	f V}	

-------
pound of waste.




               The death of a bulldozer operator at a land-




fill near the Raritan River in New Jersey caused by the




explosion of a drum of unidentified industrial waste chemi-




cals points out the dangers of accepting such wastes.




               Local examples include the French Ltd. dump




which operated near the San Jacinto River close to Houston




for several years.  Water wells and soil near the dump were




contaminated, and a continual wave of offensive odors in-




fested the air.  Pishing and recreational uses of the nearby




river had to be abandoned.  Frequent fires gave evidence of




the combustible and dangerous nature of the black, oily




material present in the area streams.  After an agonizingly




long struggle during the early 70's, the Water Quality Board




finally closed the dump in 1973 after a flood of the area.




The land, which now belongs to the State, has not been




properly covered and is not able to be used right now for




any purpose.




               The Sheridan industrial waste dump near




Hempstead threatened the Brazos River with pollution by




hazardous wastes after heavy rains in 1974.  Also in 1974,




approximately 5,000 barrels of industrial chemical wastes




from industries in Dallas, Austin and Houston were found




abandoned in unpermitted waste dump sites in Travis County.




The Texas Water Quality Board bjrpuijht suit against the dump

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manager, and finally in early 1975 the wastes were properly


disposed of at the expense of the industries concerned.


               The increasing amount of hazardous wastes


being produced by industry, agriculture, government, hospital


and laboratories requires that a program for managing these


wastes be developed.  We support the EPA's efforts to devise


regulations for management of hazardous wastes, including


transportation, storage, treatment and disposal.  The Solid


Waste Disposal Act gives EPA the authority to set forth


guidelines.  We commend the EPA for the efforts they are


making to accumulate a comprehensive data bank on which to


base their guidelines, and hope that the guidelines will be


promulgated speedily.


               The League's position on the environment


states that "the Federal government should establish policies


and programs to increase the demand for secondary materials


to encourage recycling of post-industrial and post-consumer


waste, and to reduce the generation of solid waste," and


that "the role of the Federal government should be expanded,


although the major responsibility for solid waste management


should remain with the State and local governments."


               In the management of hazardous wastes, we


identify the following concerns:


               1.  There must be strong, uniform regulation


of hazardous wastes through Federal, and state legislation.
                                  I K^

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   This  regulation should be  supported  by  economic  incentives,




   because  the private sector must play an important  role in




   hazardous  waste management,  and the  regulation should  cover




   all parties who participate in any phase of  hazardous  waste




   management.  Vigorous  enforcement procedures,  following upon




   inspection and monitoring  requirements  are essentials.   The




   use of criminal,  as well as civil penalties  against violators




   should be  considered.




                  Possible means  of implementing  such regulation




   include:   Use of state or  regional agencies, registration  of




   all generators of hazardous wastes,  issuance of  permits to




   qualified  hazardous waste  disposal facilities.   A  new  set  of




   regulations governing  hazardous waste management,  recently




adopted  by  the Texas Water Quality Board,  embodies  "any of these




   provisions, and will go into effect  in  1976  here in Texas




                  2.  Ml disposal sites should be  carefully




   recorded,  well-planned according to  the best technical




   knowledge  and corrective measures applied to existing  sites




   as needed.  The need for long-term care of disposal sites




   and the  potential problems associated with private sector




   ownership  of such sites argues for the  use of  public lands




   for hazardous waste disposal sites.   Publicly  owned disposal




   sites could be leased  to private firms, but  legal  title




   should remain with the governmental  body. Alternatively,




   once  a privately-owned landfill site were closed,  according

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to a set procedure, it could be deeded to the government.




               3.  We believe that any generator of hazardous




wastes should be held financially responsible for the proper




disposal of these wastes as part of his production costs.




He should be legally responsible for them until he has dis-




posed of them in accordance with regulations or delivered




them to a facility authorized to provide ultimate disposal.




Fines for violations should be significant.  The regulatory




agency should have access to all information regarding




transportation of wastes.




               4.  Processing facilities to provide recycling




reduction, detoxification, incineration, or safe packaging




if needed should be available either at the generator site




or at a designated hazardous waste disposal facility, which-




ever is more environmentally acceptable, and economically




preferable.  Exchange of wastes should be encouraged.




               5.  As to the choice of disposal methods:




Injection wells pose too great a hazard to groundwater




supplies to be acceptable; ocean dumping is dangerous to




aquatic life and to consumers of fish and seafood.  Incinera-




tion has replaced ocean dumping as a technique for disposing




of some industrial hazardous wastes and can also be




acceptable for the disposal of some explosives and military




wastes, providing that precautions are observed to avoid air




pollution.




                                 r',3

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               For the majority of hazardous wastes, a dis-




posal facility should consist of a secure chemical waste




landfill and the appropriate equipment and structures




necessary to carry out burial and surveillance.  Proper site




selection is crucial, as is the use of the proper liner




material for the expected wastes.




               Besides the social, economic and commercial




considerations involved in .closing  a landfill site, there




are geological criteria:  Low groundwater contamination




potential; location away from floodplains; natural depression




existing wells; low rainfall, high evaporation rates; soil




with high clay content; location of base sufficiently above




the high water table; location with no hydraulic continuity




with surface or subsurface waters.




               We urge the use of public hearings on the




siting of hazardous waste disposal facilities.




               There is so much controversy among scientists




concerning radioactive waste disposal that an informed




statement is almost impossible to make.  Some scientists feel




nuclear waste storage does not pose a technical problem and,




although lives will be lost in a nuclear economy, the




alternative paths will have an even higher cost in lives and




dollars.  Other equally renowned scientists say that enough




is simply not known about technical problems of nuclear




storage to make those predictions.

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               What is apparent is that nuclear wastes pose




a special threat to humans and their environment.  Since this




is the case, we recommend caution and restraint in all




aspects of nuclear waste disposal.  We must proceed with care




and make sure that we don't leave an unmanageable problem




for future generations.




               Without question, a comprehensive program to




deal with hazardous wastes will be expensive, and we know




that the consumer will have to bear the brunt of this expense




through higher prices and taxes.  However, the real question




is what happens in our expanding technological society if we




do not face this task of properly disposing of our hazardous




wastes.  We must remember that reckless disposal of hazardous




wastes from hospitals, laboratories, industries and munici-




palities will only result in incalculable costs to health,




life and property.




               On this subject, it is interesting to point




out some results of a nation-wide survey completed in




August of this year by the Opinion Research Corporation.




Ninety per cent of those persons surveyed agreed that if we




do not start cleaning up the environment now, it will cost




more money in the long run.  Moreover, sixty per cent said




it was more important to pay the costs involved in pro-




tecting the environment than to keep prices and taxes down,




and run the risk of more pollution.




                            7CO	_^_

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                We believe that,  although the management of




 hazardous wastes is a technical  subject and unfamiliar to




 the general public, it is so necessary for EPA to continue




 its fine work in educating citizens about this extremely




 vital program.   We urge that the public be involved through-




 out the regulation process, requiring public hearings on the




 siting of hazardous industrial and governmental installations




 and their waste disposal operations.   We further believe that




 citizens should have the right to sue to enforce public




 health and environmental requirements applicable to the




 future regulations.




                With this kind of public involvement, we




 believe that responsible citizens will be ready to support




 a program designed not only for  the safety of themselves,




 but the safety  of future generations.




                Thank you.




                MR. LEHMAN:  Thank you, Ms. Gehan.




                Do we have questions?




                Mr. Lindsey.




                MR. LINDSEY:  In  previous meetings, we have




 heard from a number of people that the siting of hazardous




 waste, chemical waste disposal sites  and other hazardous




 waste treatment facilities, and  so forth, is difficult at




 best and in many cases an impossible  task.




                Could you comment further on that as to



                             -; KI
	I ij .:.	

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whether you see that as a problem in this area and how this




particular problem might be overcome.  Do you have any




thoughts on that?




               MS. GEHAN:  It obviously is a serious problem,




but our feeling is that if people are made aware of the




necessity for them, of the enormity of the problem, and of




the consequences of not dealing with this properly that




people will be more ready to support whatever programs are




instituted by the use of public hearings where people can




be made aware of the problems and of the possible sites




being considered.  I think that by bringing them into the




decision they would be willing to accept the necessity for




it and go along with whatever choice is made.




               MR. LINDSEY:  Do you feel the State or




Federal government should have some sort of educational




program for the public at large?  Would that be helpful?




               MS. GEHAN:  I certainly do.  I think the




publication that you have put out already is a good publi-




cation.  I think the EPA does a very good job of putting out




publications for the general public.  I think this is an area




that really does need more ....




               MR. CROWE:  What do you feel is the actual




League's role in this specific issue?




               MS. GEHAN:  I'm sorry.  I didn't hear you.




               MR. CROWE:  What type of a role does the

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League  feel  that  it  can  serve best?




               MS. GEHAN:  Well,  the League  tries  to  promote




informed citizens.   I think the League would endeavor to




inform  its members of the seriousness of the problem  and of




the issues to be  considered and would attempt to lobby  for




effective legislation on a Federal and state level.




               MR. LEHMAN:  Mr. Kovalick.




               MR. KOVALICK:  I was interested in  your




comments regarding the possibility of deeding all  sites




ultimately to the government, State or Federal.




           Does the League have any further  thoughts  on that




subject?  We have given  it some thought and  it's obviously




fairly  controversial because then the government becomes




custodian, whatever level, of sites for perpetuity in much




the same as nuclear waste.




               Do you still feel, or perhaps you could




elaborate why you feel that is the wisest approach from




an acceptability point of view, or management's point of




view?  Could you comment further?




               MS. GEHAN:  I think what the  statement says




is that there is always a temptation when property is owned




by an individual to wish to sell it eventually and many of




these sites really need to be kept undeveloped and unused




for a good long period of time and it would  seem to me the




government is in a better position to keep the land unused

-------
than perhaps an individual, although it is agrued that in




a deed one could note that certain property had been used as




a disposal site.  It is a matter of let the buyer beware.




Maybe it is much for the buyer to be aware of something as




complicated as this.




               As an example, the land where arsenic poison-




ing was buried, 30 years later someone came along and put an




office building on that land and drilled a well and people




were poisoned.  Maybe if it had been in the deed, maybe a




person would have found it, but it would have to be pretty




clearly indicated, I think, before I would feel comfortable




about it.




               MR. LEHMAN:  Mr. Mausshardt.




               MR. MAUSSHARDT:  I have a question from the




floor here.




               In your statement, you urge that the generator




of hazardous wastes be held responsible for the disposal.




Why not have a certificate or licensing system for solid




waste disposal contractors?




               Do you have any comment on this?




               MS. GEHAN:  I think what I said was either




they would be able to do it themselves or transport it to a




facility that was licensed to do so and I think in many




cases the use of regional  facilities is more economical and




more environmentally acceptable, so I think we feel whichevei

-------
is more suitable to the particular instance would be all




right.




               MR. LEHMAN:  Are there any more questions?




               Mr. Lazar.




               MR. LAZAR:  Ms. Gehan, you indicated that it




would be desirable to have economic incentives for future




Federal and state hazardous waste regulations.  Would you




please elaborate on what you have in mind, what tyoes of




economic incentives perhaps, and by whom, by Federal or State




governments?




               MS. GEHAN:  Well, it's possible to consider




things like tax breaks.  We go into this initially, because




there aren't that many companies in the field at the present




time and to get companies ready to go and do this in a fairly




short period of time, tax incentives are certainly a possi-




bility.  This is something that was talked about in 1966 or




1967 for companies that would install pollution abatement




equipment without being coerced, giving them tax incentives.




Something like this might get a program like that started




quickly.  It seems to me it needs to be done.




               MR. LEHMAN:  Thank you, Ms. Gehan.




               Any other questions?




               (No response.)




               MR. LEHMAN:  Apparently not.   Thank you very




much.

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               Next, I would like to call Mr. C. Leon




Pickett, Citizens Against National Nuclear Overkill




Technology.




               REV. PICKETT:  Good Morning.  I am the




Reverend C. Leon Pickett and for your information, I am blind




as a bat and I broke my glasses this morning.  So I am asking




the one person who has done the most to make it possible for




me to be here, as well as everything else I do, my wife, Ms.




Teresa Pickett, to read this to you.  I ask you for your




attention and consideration.  I will return to the podium to




answer any questions that there may be.




               Thank you.




               MS. PICKETT:  Remnants of Progress, and I




quote:




               "I am Reverend C. Leon Pickett, Director of




CANNOT, and I am here today to pray for your most




earnest attention to what I have come to say for if it were




not the most important and the most pertinent statement that




you will hear at this or any other place, I would not be here




               "I want most sincerely to thank each and




every member of this assemblage for being here today, for by




our presence we demonstrate concurrence on the existence of




a problem together with our mutual desire to find and




implement  a solution to the problem, and I use the singular




inclusively.

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               "We are living in an age of miracles and




indeed, it would seem that our great and magnificent  nation




has not only matured on a diet of continuing miracles, but




has come to a point where it has developed, if not a need,




then certainly a desire for miracles of ever-increasing




magnitude for as we stand on the bicentennial plateau we can




look back upon fantastic growth and wondrous  rewards for the




implementation of our intellect and our integrity, and we may




take pride indeed in our accomplishments to date, but only




if we are prepared to accept the responsibility for what we




have done or what we have not done to handle the remnants of




progress which brings us to my reason for being here.




               "In our effort to produce some new miracle,




we have laid waste to some of the deadliest substances known




to man and we have poisoned our environment because of it,




but as usual what we have done in the past is trivial by




comparison to our gigantic success in the present.




               "However serious other waste management




problems may be, they are all secondary to the dread danger,




to the creeping genocide of the stockpiles of waste materials




spewed out by the n.uclear power plant that we had looked




forward to with such great hope, and have come to view with




such absolute horror.




               "Radioactive waste materials, which are the




remnants of progress in the nuclear power technological

-------
 field,  defy management,  threaten each and every form of


 animal  life and are  a source of contamination which must lead


 to the  insidious creeping death by cancer which is  their


 national function.


                "Radioactive  substances defy management


 primarily because there  are  very few storage methods which


 can retain the cancer-causing gamma rays which are  emitted,


 and because of the incredibly long life of radioactive


 particles, for instance,  plutonium has a 1/2-life of 24,000


 years which means simply that in 24,000 years the plutonium


 waste shall have reduced its volume by 1/2 and will require


 another 24,000 years to  half the remainder, and we  might


 consider radioactive iodine  which has a 1/2-life of 120,000


 years,  but why should we bother since it is readily apparent


 that there is only one way such substances can be properly


 managed and that is  to simply declare a moratorium  forthwith


 on the  development and use of all nuclear substances and the


 playing into extinction  of all ongoing systems until such


 time as our ingenuity can develop the technology with which


 to render nonradioactive (harmles^ those waste materials from


 the implementation of nuclear technology which are  presently


 being spilled, slopped,  dripped, dropped, oozed and otherwise


 exuded  into the environment where they will eventually move


 into the food chain and  induce a multiple increase  in the


 incidents of cancer among all the people of the world
                        *

	7L?	

-------
resulting in a gigantic worldwide act of genocide.




               "In closing, let me just make one thing very,




very clear, it is already too late to stop the manufacture




of the death-dealing plutonium, a substance that does not




even exist in nature, but it was created by man and its




further development could be halted on order, and it must be.




               "The Government has wasted approximately




three trillion dollars which it has stolen illegally in the




form of excessive income tax levied aqainst taxpayers and




handed over as a gift to the electric power industries of




this nation to play with in their quest for a thermonuclear




disaster, and because of this I would like to suggest that




you carry back to Washington a message that the twenty




million people who refuse to pay income tax to fund govern-




ment boondoggles this year will be encouraged to grow to




fifty million nonpaying previous taxpayers in 1976 for we




will refuse to fund such idiot programs on the simple basis




that there has been no legal money in circulation in these




United States since 1968, and that therefore no one has




received lawful funds against which income tax may be




legally assessed, which means in simple terms that no one is




legally obliged nor may be compelled to pay income tax on




Federal -Reserve Notes which are not legal tender nor consti-




tutional money and, further, that all employees may and




should demand that their employer cease forthwith any

-------
withholding from their pay checks, and by this act we should




revolt against the deadly disaster of creating a waste




material with which we C A N N 0 T live by refusing to




furnish the funding therefor.




               "May God bless you, and thank you."




               MR. LEHMAN:  Mr. and Mrs. Pickett, I would




like to just comment that the proceedings here today concern




nonradioactive waste, although we realize that radioactive




waste management is a problem, I would like to confine our




remarks if we can to the nonradioactive problem.




               REV. PICKETT:  John, I would like to talk to




that, if I may.  I heard you complimented for your efficiency




here just a few minutes ago.  Your efficiency extends to the




fact  that when I wrote to VJashinaton some week ago asking to




speak at this meeting, I was scheduled to speak in San




Francisco.  I thank you for that.




               I know you are well aware from previous con-




tact with  me how strongly and how intensely I and my organiza-




tion have worked to stop the flood of nuclear power plants.




I am aware from previous waste management meetings that




waste management is just not interested in discussing the




only waste that is worthy of discussion, because if we don't




stop the dumping of nuclear waste into the environment, and




that is what we are doing, we won't live long enough for the




other waste to matter a damn, so  I don't think you can just

-------
not include it because I think it is   the  one  and  only  vital




proper question before you.




               MR. LEHMAN:  Are you prepared to answer




questions?




               REV. PICKETT:  I certainly am.




               MR. LEHMAN:  Are there any questions from the




floor or panel?




               (No response.)




               MR. LEHMAN:  Apparently not.




               REV. PICKETT:  I recognize the conspiracy of




silence.  Thank you.




               MR. LEHMAN:  Next I would like to call upon




Roger Sims, from Lakeland, Florida.




               MR. SIMS:  Mr.  Lehman, Ladies and Gentlemen,




I don't have a prepared statement to give.  I called Mr.




Mausshardt last week and got a call back that I would have




an opportunity to speak this morning.  I have a few remarks




to make, but they will be just informal.




               I am an attorney from Lakeland, Florida with




the Law Firm of Holland and Knight and we represent numerous




companies which mine and process phosphate ore to make




fertilizers.




               I think before I say anything further, it is




important that everyone understand all the clients we work




with have a very high level of consciousness in terms of

-------
corporate responsibility and the need to be good corporate




citizens.  I think considering the multitude of regulatory




processes that must be complied with, that there are existing




now to a large degree sufficient safeguards pertaining to




the disposal of industrial waste.




               There is, for example, in our part of the




state, if you have an impoundment system and you need to




discharge water from it, you have to get three different




permits, a Regional Permit, a State Permit and a Federal




NPDES Permit.




               Gentlemen, I realize there may be some areas




that are not covered by local, state or Federal existing




regulatory procedures, but I would urge the Division, your




Department, to take notice of and make provision for existing




procedures where they do provide adequate regulations.




               In Florida there is a Code pertaining to the




development of regional impact.  If you meet certain criteria




you must file a comprehensive environmental impact statement




at the state level.  And as part of that, for example, to




dispose of tailings, sand and clay that are left after the




ore is separated from the matrix, you have to get approval




and it is comprehensive under this state environmental




impact statement.  You must also meet requirements imposed




under the State Severance Tax Law and do extensive reclama-




tion.  So in that situation, there is more than adequate

-------
 review and consideration.




                I don't think that is an instance of hazardous




 waste, but is an example of the type of regulation that is




 going on.  So I would say when you are drafting guidelines




 that you consider carefully making provisions for existing




 state and local processes and provide an exemption if the




 handling of the waste is already being permitted and




 regulated.




                I would also strongly urge, I think on behalf




 of industry in general, that input such as this meeting is




 critical and when you get to the drafting stage it would be




 helpful for all parties to be affected and involved in the




 process to have the opportunity to sit down over the




 conference table and talk about the best way to handle the




 problem,  after you have identified the problem areas,  and




 give various people with  different points  of view the  chance




 to get their input into the  process so that the best




 alternatives can  be selected.




                I  don't have  any further comments to speak of.




 If anybody has any questions,  I would  be happy to answer




 them,  but that is  the essence  of what  our  thoughts  are.




                MR.  LEHMAN:   Thank  you,  Mr.  Sims.




                Are  there  any questions?




                Mr.  Kovalick.




                MR.  KOVALICK:  Mr.  Sims,  do  you have  any



	{\j J	

-------
 suggestions  from  the  point  of  view of the  industry  that  you




 represent as to the need or lack  thereof for guidance  on the




 subject of either the waste specifically from your  industry




 or the  places to  which  your industry  takes its waste,




 presuming that some of  them might be  termed hazardous?




               MR.  SIMS: To tell you the  truth,  I  don't




 believe there is  a hazardous waste problem in the industry.




 I honestly don't.  Although when  I looked  at the  discussion




 topics, I saw it  was  completely wide  open, that this would




 be one  of the things  to talk about today.   I am really not




 sure that mining  by-products,  the sand and clay and so forth,




have anything to do with the realm of  what  we will be talking




 about today.




               However, at  this point, since you  are seeking




 general guidance  on what areas to hit, I thought  it would be




 helpful to point  out  that in Florida, for  example,  there are




 other comprehensive regulatory programming procedures  and




 they should  be carefully considered.




               MR. KOVALICK:  You made reference  to a




 disposal pond from which there might be water emissions, I




 presume surface  emissions.   Is the ground  water protected




 in the State of  Florida in  some fashion from waste disposal




 as opposed to surface water?




                MR. SIMS:  That's  a good point.  Under the




 state regulatory procedures, the  State Department of

-------
Environmental Regulation has specific jurisdiction to control




the ground waters of the state.  When you do a DRI — I



think it's a good example;  this would apply to not only mines




but industrial plants, chemical plants, what have you — you



have to do extensive work in geology to show the disposal sit




at the various levels, strata, any ceiling layers, and so




forth.  It is very involved and it is very, very




comprehensive.



               It just seems to me where you have a procedure




like that there is no point in going through another permitt-




ing procedure, one more set of guidelines to just lay another




overlapping permit on top of the heap.



               I did a tally of permits for one of the




developments I'm working on right now and there are fifteen




major permits.  It's a regulatory hassle.  It's just amazing.



               I'm not saying the agencies are not doing the



best they can and working as efficiently as possible, but




just the number and the   complexity, the details that have to



be complied with, is considerable.



               MR. MAUSSHARDT:  I have a question from the




floor.  The question is stated as such: are environmental



impact statements required related to EPA regulations, or ar<




they as a result of EPA regulations in Florida?




               MR. SIMS:  The statements I was referring to




are required under Chapter 380 of Florida Law.  Now in



                           YC:

-------
addition to the State Code, as many of you may know, if you




obtain a Federal Permit, a HPDES Permit, A Corps Dredqe and




Fill Permit, you may be required to file a Federal impact




assessment under NEPA, the National Environmental Policy Act




of 1969, and in turn the permitting agency would write an




impact statement on the basis of that subject.  So there are




two and we may have to do both statements for certain develop




ments.  So they are parallel.




               MR. LEHMAN:  Does anyone have another question




               Mr. Kovalick.




               MR. KOVALICK:  A question from the floor.




What happens to the uranium in the waste for phosphate




production?




               MR. SIMS:  Uranium?




               MR. KOVALICK:  Yes.




               MR. SIMS:  Are you talking about a mining




operation?  Is this mining or a chemical plant?




               A VOICE:  This is the extraction of phosphates




from your phosphate deposits.  It unavoidably releases the




uranium presently in the rock.  Now that's in your waste




water.  If you don't have any industrial waste problem, I




would like to know what you do with uranium.




               MR. SIMS:  There are natural background levels




in the matrix.




               A VOICE:  They are concentrated significantly



                            7GB

-------
in the extraction of phosphate values from the ore.  They




reside generally in waste water.  If you put this in the




stream -- I wouldn't put it in my stream if I had one.  I




wonder what in Florida is the ultimate state of uranium that




is concentrated in the extraction process?




               MR. LEHMAN:  Excuse me, please.  None of the




other audience can hear this dialogue, so I would like to




eliminate that, if possible.  The question really is what




happens to the uranium, which is a by-product of the




manufacturing processing in the phosphate industry?  Could




you address that question, please?




               MR. SIMS:  Let me say the background levels




of uranium that exist in the ore may be in the processed




water.  There is a circulating water system.  The ore is




taken to the beneficiation plant and separated, the result




being tailings and water which is recirculated.




               If there is any discharge of that water from




the site, it must meet, as I mentioned earlier, three per-




mitting requirements, regional, state and Federal discharge




requirements.  So the processed water itself is contained




on site completely.




               MR. LEHMAN:  Are there any other questions?




               (No response.)




               MR. LEHMAN:  Evidently not.




               Thank you very much, Mr.  Sims.
c-

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               I would like to call upon Dr. James Robertson,




of the University of Oklahoma.  Is Dr. Robertson here, please




               We will have to come back and check with him




later.




               The next, I would like to call Mr. Jack Woods,




the Taxpayers' Rights Association.  Is Mr. Woods in the




audience?




               Mr. Woods, will you answer questions?




               MR. WOODS:  Yes, of course.




               Ladies and Gentlemen, no one, especially no




one in our organization, Taypayers' Rights Association, wants




more government.  We don't want the EPA any more than you do,




but this is brought about when local and state officials do




not do the job which they are elected or appointed to do,




and that is protect the public.




               Now when it comes to lenient, stupid or




corrupt officials, our state will  take a back seat to no one,




so you are, therefore, welcomed by some of us.




               The brains, financial and political power




represented in this room is tremendous.  The group of people




represented here  control this state, they own the politicians




collectively  and  individually.  It is only a shame their




power is not  matched by their morals.




               Individually, every one in this room I am sure




is a very nice decent outstanding  and upstanding citizen.

-------
Collectively, there is a lack of moral consciousness that




is appalling.  Now those of you who defy the norm and are




trying to keep from poisoning the atmosphere and the streams




and all, are to be congratulated.  Remember, guilt is the




only thing that shrinks the more you spread it.




               Now, I have just found, too, in the past month




or so that there is a Communist plot to clean up the water




of the world.  Now let me hastily remind you this is said




only as a joke.  I mentioned it to someone recently and they




said. My God, don't say it.  They'll be saying you are




like other people that have been blaming EPA for a Communist




plot for a long time.  I know this is true because it was in




a recent edition of the Reader's Digest.   (Laughter)  So




we have to believe it.




               You know, we have always heard about cleanli-




ness beinq next to godliness, but they forgot about the




Reader's Digest.  It's right between the two.  So when they




put something in there, you know it has to be so.




               It turns out that in Russia, according to




Reader's Digest, people taking water from a stream have this




intake downstream from the discharge.  Now you think about




that just a minute and I believe you will find the water




will be somewhat cleaner if you are taking some of it back




in.  I would recommend to EPA that you consider such a thing




the intake pipe downstream from the discharge.

-------
               Now much of the blame in my mind for the




problems we have in the poisoninq of the stream, the




atmosphere, and all, it has to be laid on all of us because,




frankly, few people realized until recently, and again I




do want to congratulate those few who are stepping out and




doing what is right, but I blame a great deal of it on labor




and on the media.




               A recent example of that, a recent example we




have had here, for example, when labor put out what they call




a white paper on the ARMCO plant.  In the past few weeks we




have had something like this over in Louisiana on the closing




of a plant.  And I read through the report and the explanatio




by Mr. White as to all EPA has gone through in this plant




over in Louisiana, and I think they have been far too lenient




on the plant, myself, but I am sure they are catching all




kinds of unmitigated  hell from the labor unions over there.




               It is ny opinion, and I will discuss this




with Harry Hubbard, I think labor is being very negligent,




not only not protecting their own people, but protecting the




citizenry as a whole and not demanding that these plants do




what is right.




               Then media, we have great examples of that




around us at all times.  The media, most of it, is run by the




advertising department and too few members of the media are




able to report honestlyjon what is going on.

-------
               In the case of this plant over in Louisiana,




for example, the reports in the newspapers here were simply




a handout from the plant, evidently, that the EPA was




closing this plant.  I resent that.




               We have probably the best or the worst example




of the prosecution of the media right here in Houston and




that is KTRH Padio, a man called Dewey Compton.  You want to




poison the stream, sell poison to the people, buy some time




on KTRH with Dewey Compton.  The man is a functioning




illiterate and a 14-carat idiot.   (Laughter.)




               And I assure you KTRH, when their relicensing




time comes up, they are going to have an awful hard time




explaining the irresponsible garbage that idiot puts out.




               Now I will bring up something I am sure will




make all of you, I think at least the subject will make you




happy, and that is a plan to where we might get rid of the




EPA, eliminate it altogether.  Is there anybody in the room




that wouldn't go along with that, including these fellows




that take this guff all the time?  I arn sure those of you




who are responsible citizens, responsible companies who are




trying to keep  things straight would welcome such a plan,




and all of you say you are.




               To show you how this works, we all know the




River Thames  which runs down through London, for example, up' un•




just a few years ago was^ one of the nastiest bodies of water



                            i7^

-------
in the world.  It's suddenly  clean.  They are able to fish




in the downtown areas.  They are able to eat that fish, too,




by the way, not like some of that stuff out in the ship




channel.




               Now this was not brought about by some great




outpouring of moral consciousness.  It wasn't brought about




by some big tax refunds and all.  It was brought about by




something that has been given very, very little publicity,




but, by damn, it works.




               Some eight to ten years ago, England passed a




law on corporate responsibility and individual responsibility




This law stated that not only the plant manager who poisons




the stream or the air, but the board members, the board of




directors, and the stockholders are not only held financially




responsible, but criminally responsible.




               Now those of you that are all good citizens,




you don't poison, you don't pollute, you don't do these




things, I hope you will join with me at the next session of




the Texas Legislature.  I am having some bills drafted that




at least in the State of Texas would make it physically,




financially and criminally responsible for the stockholders,




the board members and everyone else who does this.  Now, if




you are good citizens, if you are not doing this, you should




welcome it, and we will thereby be able to abolish EPA and




I think you people would_ go along with that.  All we want is

-------
the stuff cleaned up.




               So the people, and among you, you know this.




Doggone it, you have to go in and you fight your battles.




You try to get your management to go along on things, and I




am sure there may be rulings that these people may have to




change.  No one is arguing about this at all.




               I will remind you what it says in the Bible.




It says, "Thou shalt not kill."  It doesn't say Thou shalt




not kill by hiding behind a corporate shield, by hiding




behind some corrupt or lenient or stupid political officials.




It says simply, "Thou shalt not kill."




               I will ask you to remember this, too.  Ask




for recognition of the right, more than that, the responsi-




bility to refuse to participate in actions which you consider




immoral.




               It is not a new idea.  It was the unmistaken-




able verdict of the Nuremberg trials.  Long before that it




was said more clearly and more eloquently, "Thou  shalt not




follow a multitude to do evil," that is from Exodus 23.




               Thank you.




               MR. LEHMAN:  Thank you, Mr. Woods.




               Are there questions?




               Mr. Kovalick has a question.




               MR. WOODS:  Excuse me.  This is the letter I




sent to John White on t^his one particular broadcast that

-------
Compton did and I want to enter it into the record.




               Excuse me.  Go ahead.




               MR. KOVALICK:  I think I understand the tenor




of your statement, but do you bring any specific recommenda-




tion to us today to take back with us, something to do as




opposed not to do?




               MR. WOODS:  That's right, simply change your




intake and discharge on your plants.




               (Laughter.)




               MR. KOVALICK:  Of course, we are mostly




interested in the non-water pollution aspects, because that




is another portion of EPA.




               MR. WOODS:  Then I would strongly recommend




that you talk to the Federal government or the people who




might be concerned about this, about getting Federal laws




making the board members, the major stockholders of these




companies, personally and criminally liable.  Six months in




jail for one of these big stockholders of one of these




corporations, they'd clean these streams up and this other




stuff we are talking about, too.




               MR. LEHMAN:  Do we have another question?




               Mr. Woods, we have one more question.




               Mr. Lindsey.




               MR. LINDSEY:  Mr. Woods, I have a question




here from the floor.  How do you define what needs cleaning

-------
up against what materials, how should that be defined?
               MR. WOODS:  I don't know what the technical
term would be for it, but anything that is injurious to the
health of the public or the food supply or anything else.
               rfe know about these streams.  We know about
poisons that are being sold and many of these things, of
course, have just come upon us, due to the research and all,
but certainly the hazardous materials that you are more con-
cerned with here are a more immediate problem than, say,
some long range pesticide may be, but it is all in the same
vein and, frankly, I think you people need help from the
public.
               I believe the lady with the League of Women
Voters was talking about it, an educational project for the
public, so that some of these people can go back to their
plants and say, "Look, by damn, I've got children and grand-
children the same as you do, who are going to be living
here.  Let's clean this mess up now."
               MR. LEHMAN:  Thank you.
               Any other questions?
               (No response.)
               MR. LEHMAN:  Apparently not.
               Thank you, Mr.  Woods.
               I would like to call now Mr. J. Gallay of
SBB Limited, The Hague,• Holland.
                           7', I'

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               Mr. Gallay.




               MR. GALLAY:  Good -Morning, Mr. Chairman,




Ladies and Gentlemen.




               My company is a Dutch German Company that




invented and developed the incineration at sea as the




responsible and environmentally protective disposal method




for chemical wastes.




               It was very interesting for me today to see




that the first and second paper given today was talking about




the incineration at sea.  Mr. Lozano here is the first man I




have seen three years ago, exactly three years and two days




ago when I came for the first time to the States to talk




about the incineration at sea, and from the contact I had




during these three years with American industries,




particularly with EPA, I can tell you that it is a long way




that you have come in the United States with this new idea.




               I have to say right from the start that my




company does not pretend to be a panacea for the terrible




problem of chemical pollution in the world.  I have the




feeling from Reverend Pickett that he does not, is not afraid




about a chemical pollution as something serious.  I am sorry,




sir.  I think we have demonstrated a splendid ability to kill




this world with chemical pollution, before we have the proof




that we will kill it with radioactive materials.




               To give you one small example, because

-------
 Mr.  Woods, I think Mr.  Woods,  the last speaker,  brought you




 very good news about the Thames.




                Well, I  bring you very bad news about the




 Rhine.




                (Laughter.)




                I  think, although I am convinced  he is right,




 there is a lot to do,  a lot of things we must do if we want




 to survive.   Because if you imagine,  and all of  you heard




 about the terrible pollution that the Rhine had, now with




 all  the efforts of all  the  authorities and all these




 countries, and as he says with the responsible people of all




 the  companies, the fact is  by having  200,000 samples during




 1974-75, the Rhine authorities determined that Rhine




 pollution was higher in 1975 than in  1974.  Particularly the




 chlorinated hydrocarbon contents in the Rhine was doubled in




 1975, over 1974.   Since 1969 we have  burned something like




 two  hundred fifty and  three hundred thousand tons of




 chlorinated hydrocarbons coming only  from Germany, Poland,




 Belgium, France and Spain,  but this is more the  quantity.




                Now I say we do not come and say  we have a




 panacea for all the chemical pollution, but we have found a




 way  that opened doors  to a  new sensible, rational, intelli-




 gent responsible  way of disposing of  chemical waste.  To




 put  it  very shortly, we do  not believe there is  anything




 else to dispose of a "articular kind  of chemical waste,



	TTt

-------
namely, the chlorinated hydrocarbon which is our field, but
two methods.
               One is the chemical transformation of the
waste material in another product that is useful.  However,
everybody knows this is not possible always because of
technical limitation and because of unfeasibility.
               The second one is the incineration at sea
which we maintain is the only one that any organization,
industry or authority should accept as a  disposal method,  and
this is because you do not do anything but to postpone the
problem, as we have seen in Europe, if you dump it somewhere
directly or indirectly, and I will explain in a minute what
I mean by indirectly.
               Let me say right from the start that fifteen
minutes is an impossible time to give you an idea of what
incineration at sea is.  This is my paper, which you see I
put it aside.  I would like to give you some documentation,
but this doesn't say in five pages anything that you would
understand what it is.
               For those who are interested, please contact
me.  I will take your name and address and will be happy to
send you — this is the only thing that would explain to you
what we want to do and what we do.
               Gentlemen, the chlorinated hydrocarbons have
been dumped for years it} £he sea, on the river, on land,
                         " 778

-------
whatever you like.  Because the time is short, let me tell

you quickly in Europe they have faced now the problem to

get the chlorinated hydrocarbon from out where they have put

it for years.  Whether it's in drums, whether it's in pits,

whether it's in salt mines, whether it's in the coal mines,

wherever they put it.

               Now you know how easy it is to get the fluid

from a thousand feet or a thousand meters.  That's one aspect

The other aspect is that chlorinated hydrocarbon is a materia

that is very resistant to biological degradation, whether

it's in the sea or on the land.  Land incineration has been

and is still used less and less in Europe because it comes

very close to forbidding land incineration, for several

reasons.

               Land incineration is not a very efficient

combustion operation.  It lives.  The combustion efficiency

of land incineration is 70 per cent to 90 per cent.  Dis-

carding all the technical problems that land incineration

has is not a complete combustion and after the land incinera-

tion, usually the HC1, the hydrochloric acid, is neutralized

and 10 or 20 or 30 per cent of unburned chlorinated hydro-

carbons are later dumped in the sea, in the river, or land.

               Since 1969, when we started incineration/

                   we could demonstrate and we have

records                                          the
                                779

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character of this incineration at sea, that our operation




does not have the problem.




               Now as I said, we have burned 250,000 to




300,000 tons this year.  We have used two small ships and we




build now a third ship which will have 20,000 DWT.  Our new




ship will be about four times larger and will be burning




liquid chlorinated hydrocarbons and solid chlorinated hydro-




carbons .




               We intend to come to the States as soon as




we have cleared all the procedures.  The American industry




is very interested in what we can do.




               Now in the little time I have, I want only to




tell you very quickly what we have done in order to insure




that our operation is indeed an environmental ly protective




one.




               We have determined with a very knowledgeable




and reputed organization in Europe what our combustion




efficiency is in the presence of the Dutch and German




Government.




               Our efficiency is higher than 99.9.  You




compare with 70 to 90.




               The second thing which we have done, we have




determined the toxicity of the chlorinated hydrocarbons.  We




were the first ones who did this in the whole world and for




that we used CERBOM Institute, a biological institute in



                               780

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 France, and CERBOM determined by taking seed and putting
 different concentrations in chlorinated hydrocarbons, the
 ones which we burn, that by interdilution of one to ten
 thousandths every animal from plankton to mussels and some
 small fish, crabs, whatever they liked, was killed within
 less than ten hours at one to ten thousand dilution.
                Now you may not know that in the whole world
 there's something like 500,000 tons to 1 million tons that
 is dumped directly or indirectly in sea, in rivers, land,
 anywhere.  I hope you shudder as we did when we put together
 the five hundred thousand tons to one million tons a year
 dumping in the whole world, and at one ten thousandth
 dilution it is killing everything within the sea within less
 than ten hours.
                That is why we believe that one should really
 consider very seriously as a citizen, as so many speakers
 said or will say probably today, consider short term and
 long term responsibilities.  This happens to be in Europe.
 Now that doesn't mean necessarily you will be taking our
 services.  There are other companies.
                Now the next one that was very important was
 what CERBOM did.  We asked them to investigate the biological
 effect on the marine life from the combustion gases that
 come from the sea which are water COj that goes into the air,
 and the HCL condenses and drops into the sea water, so we
	    761	

-------
want to know what is the effect of the combustion gases on
the marine life.
               They determined and I have here the papers on
all these environmental organizations made the world today
from Japan to even Moscow.  They have these documents
demonstrating that what they have done, they took the gases
from the furnace and they bottled up 60 samples for 34 hours,
accumulating in these samples of water all the combustion
products and they put in this water the same animals that
they did before, and after seven days' exposure there was
no effect, not even a disturbance on these animals.
               Now I said this the same in the public meeting
in Newark, when I got a question of:  Do you want to say that
you can make in seven days a proof that there is no genetic
impact on the animals?  No, certainly not.
               What we have done, we have proved that short
term.   What we do now is, if you want it like that, more
reasonable than it has been done up to now, because if you
think that there is still going  to have an effect on the
animals, what we do, the other method to dump the stuff,
whatever you like, in pits or in sea directly, we will have
at least ten thousand tons accordina to a recent survey.
               What we do, however, we have started
organizing a long-term project to determine the biological
effect of our combustions*  Let  me tell you this.  In six,
                           7S2

-------
almost seven years, we have been given by the Dutch Govern-




ment an area in the North Sea to incinerate the chemical




wastes from Europe, which has been chosen because of one




criteria, and this was the area with the less traffic.  Do




you know what it is?  It's a fishery area of the Dutch




fishermen.




               Since six or seven years we have burned there




and there has been a lot of study and a lot of investigation




going continuously to see what effect.  I cannot tell you




what the effect will be in seventy years, but I tell you what




it is in seven years.  Better than what we did before and




better than any alternative.




               We have, I just learned this morning, that it




has been already decided that CERBOM Institute is to start




immediately with a new ship that will have a long term




program of two years for starting the effect of the




combustion or gases from the third ship in the North Sea




and in north parts of the Atlantic.




               MR. LEHMAN:  Excuse me, Mr. Gallay.  We are




running a little late.




               MR. GALLAY:  Let me say the first paper given




by Shell, what they said about their high incineration at




sea, I think Shell should be commended for the courage and




money they spent toward investigating for the United States c




new disposal way.  With respect to the costs, I am sorry for



  	                    7B3

-------
 Shell that they had indeed too high a cost.   I don't believe




 the cost of the incineration at sea of normal operation are




 as high as Shell had to pay.




                On the contrary, because I know this will




 interest you,  we are cheaper than the London incineration anr




 many others.   This is not an operation comparable to sell




 melons or cucumbers.  This is a very sensitive operation that




 requires a lot of technology and a lot of discussion and a




 lot of co-ordination between the generator,  the environmental^




 authority concerned, and us.




                Thank you very much.




                (Applause.)




                MR. LEHMAN:   Thank you, Mr. Gallay.




                Do we have questions?




                MR. MAUSSHARDT:  Mr. Gallay,  in your statement




 you referred to several points which I thought were very




 interesting.   One was the efficiency of the system that you




 had on the ship, and, too,  on monitoring and technical papers




 that were developed.




                I would like to request any information you




 have on, one,  the monitoring of the ship itself and studies




 that have been done submitted for the record.




                MR. GALLAY:   Yes, sir.  I said, please, at




 the break time come to me,  give me your name.




                I have some documentation here and I will giv<



	l&k	

-------
a quick answer for the whole audience.




               The monitoring of this operation had to solve




one problem.  Namely, nobody is going to be on the ship the




whole time of operation from the controlling authority.




               SBB has developed a system whereby the control




is done at least as well — well, let's put it this way —




the authority controlling the operation who want to control




it can do it at least as well as if they would have an




inspector that would sleep 24 hours and awake 24 hours and




would be very alert.




               Basically, it is this.  A difficult problem,




as I said, 15 minutes.  Anyway, as I said, basically, if ther




is a panel where there is all the information, the relevant




and important information about everything what has to do




with the incineration process, from geographical location,




from date, hour and minute, with all the temperatures that




are in the furnace, where the waste comes from, anything




that has to be done in order to make a control is on the




panel, and is photographed automatically by a sealed camera




every half hour and, therefore, you get a film that has been




controlled by the authorities where the ship came to pick up




new loading.




               They did that for three or four months.  How-




ever, the film goes into an archives and stays in there for




three months, or for thirty years,  if you want.  It is too

-------
rough an explanation to give you the feeling how much lia-




bility the system has.




               Now, on the third ship we have a much more




sophisticated control system.  We have worked with EPA in




the States and with the German and European authorities in




each country so that we have indeed the approval for the




work.




               MR. LEHMAN:  Mr. Lindsey.




               MR. LINDSEY:  We have several questions here




from the floor which relate to this same topic.  Let me see




if I can put them together into one question.




               What is the specific reason that incineration




at sea is more effective, I guess, than the relationship of




the destruction efficiency than on land?  In other words,




why couldn't the Matthias incinerator be used on land as




efficiently?




               Isn't it a function of high enough temperature




or oxygen content, turbulence, and that sort of thing?




               MR. GALLAY:  I'm sorry.  I have too little




time to explain where the problem is.  The problem is, when




you burn chlorinated hydrocarbons totally, because if you




don't burn them totally, then you get unburned chlorinated




hydrocarbons which are poisonous, but if you burn them




totally, the combustion products are three — water, CC>2 and




HCL.  Now, the HCL, if it is left open, the spray in the

-------
atmosphere will land on the planet and will give destructive




effects.  That is why the land incineration today,  they




either try to recover the hydrochloric acid, which  is  -- well




that is a mess.




               Second, they neutralize the hydrochloric acid




with some alkaline solution.




               Now, what we do on the ship, we have a  very




large opening in our furnace and the HCL can go into the sea




where it disassociates and the chlorine ions join the  chlorin




 ions already present in the sea.




               Well, a ton of water, which is a cubic, 27




cubic feet -- 27 cubic feet contains 19  kilograms of




chlorine.  That is a natural sea water.




               Then tons, that's about 45 — okay,  28  foot




of sea water contains 40 pounds of chlorine.  What we  add,




the combustion are grams, per square yards, per square foot,




particularly, because the ship will move.




               In other words, it's insignificant what the




chlorine amount comes or the hydrochloric acid comes in the




sea.  Therefore, the difference between land incineration anc




the sea incineration is that the hydrochloric acid in  the




sea can be naturally integrate by the environment   , whereas



on the land it is going to provide corrosion.




               MR. CROWE:  I have a question from the  floor.




               Have you an estimated cost per ton of

-------
chlorinated hydrocarbons disposed of by incineration at sea?

               MR. GALLAY:  Yes, sir, I have, and the answer

is we have chlorinated hydrocarbons liquids.  There are the

only ones we have burned until now with the ships, Matthias

and Matthias II, but with the third ship, we are going to

burn liquids and solids.

               Now, for the liquid chlorinated hydrocarbon,

we are priced about the same here as in Europe.  This is the

highest price for the minimum quantity is $60 per ton, but

it can go lower with the amount of chlorinated hydrocarbon,

amount of waste, and with a contract for one or two years.

We can go as low as possibly something like $40 which we

know is cheaper than the land incineration first here and

even in Europe.

               Second, for the price for the solid, we

haven't burned yet solid.  We are going to do it, but we are

going to start it very slowly under control to determine

perfectly the technique we have to follow and on that

monitoring of the operation by EPA, by the French Government,

by the German Government, because we work together with

them, and the price for this, we do not know exactly what

it is.

               We will have to follow guidelines and we

think it will be somewhere around $100 and we realize this

is too much, but we say to every interested party, wait
                        "   768

-------
 until we have had the opportunity first of all to burn a




 larger quantity to determine our cost exactly.




                We have been 20 years or 25 years in industry,




 working in an oil company and then a chemical company.  I




 know what this means.  You have to pay money for something




 to destruct and not to get anything.




                MR. LEHMAN:  Mr. Lindsey.




                MR. LINDSEY:  Yes, as a result of your state-




 ment at Newark, a question came up later on which I would




 like to pose now.




                As you mentioned, the most responsible in-




 cineration facilities on land to incorporate scrubber




 facilities which would mitigate any problems in the event




 of a malfunction, such as a flame-out or something of that




 nature, what control does the Matthias have in the event of




 such a malfunction or a flame-out to prevent the emissions of




 unburned or partially burned materials, and do you see this




 as a potential problem with the incineration at sea?




                MR. GALLAY:  No, sir.  We have determined on




 our own program and our own time what are the conditions at




which chlorinated hydrocarbons have to be incinerated.  As




 you know, an organic molecule can burn at a temperature of




 800 degrees C.




                There is one temperature which is crucial.




 This is 1100 degrees C, Which is about 2000 degrees F,

-------
at which all organic compounds will crack, will be destroyed.
This was the basis of our operation and the incineration is
made at the temperature that goes between 1200 and 1400 C,
in order to give us that margin.
               Now the ships are built in such way that you
cannot — it is impossible — to build it in such a way,
you cannot inject waste in the furnace before the furnace
has been heated up at 1200 degrees C. with fuel.
               Only at that point you can mechanically open
the valve that leaves — we have a special burner that will
leave the waste coming in the furnace gradually when reducing
the fuel.  That is one.
               Second, if by any chance something happens in
the furnace that the temperature falls, automatically falls
below 1200 degrees C., automatically the supply of the waste
to the furnace is stopped.
               Point of interest, the same mechanism is
arranged is set also  at 1500 degrees C.   Actually at 1650 C.
you get the disassociation of the HCL, hydrochloric acid,
and chlorine and chlorine is a poison.  HCL is not a poison.
It is an irritant, but not a poison.  Chlorine is a poison.
At 650 degrees C., the HCL would disassociate in chlorine
and the nitrogen will fall with oxygen.  Nitrogen oxides
which are also poisonous.  Therefore, we keep automatically
the conditions between  1200  and 1400 degrees and
                             730

-------
automatically the operation is stopped if these conditions
are not there.
               MR. LEHMAN:  Thank you, Mr. Gallay.
               I believe that's all the questions we have.
               If there are any further questions, we will
submit them to you and ask you to respond in writing to them.
               MR. GALLAY:  Thank you very much.
               MR. LEHMAN:  Ladies and gentlemen, it is time
for our break.
               I would like to urge you to take no more than
a 30-minute break because we have a large number of people
yet to come.
               At this time I will recess the meeting until
11:00 a.m.
               (A short recess was taken.)
               MR. LEHMAN:  Ladies and gentlemen, I would
like to reconvene the meeting.
               I would like to call at this time Dr. Geoffrey
Stanford, ^gro-City, Incorporated.
               Dr. Stanford.
               DR. STANFORD:  Good Morning.  My name is
Geoffrey Stanford.  I am trained as a physician and surgeon,
with specialist training and qualification in radiotherapy.
               I practiced for many years before turning my
attention to long-range preventive medicine.  This I now
                         ""  TS1

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practice as a regional planner with special emphasis on
integrated urban-rural ecosystems.
               MR. LEHMAN:  Pardon me. Dr. Stanford.  Could
you please speak directly into the mike.
               DR. STANFORD:  I am General Manager of Agro-
City, Incorporated.  I am a Trustee of the Environic
Foundation International, and a Technical Consultant of the
International Center for the Solution of Environmental
Problems.  I am Project Director to a field research program
currently funded by the EPA to demonstrate some of the
possible benefits or disadvantages of applying municipal
wastes to agricultural land as a soil improver for increasinc
food production.
               I would like to offer some general remarks
which may give you some fresh insights into the importance
of the subject we are now addressing.  I will now go on to
some more detailed suggestions for your consideration.
               This Spaceship Earth is some five billion
years old.  Life as we know it is only some thirty million
years old.  Man emerged some three million years ago.  One
tenth of life's time.  Some of the simplest life forms
which first evolved ten and more million years ago are still
with us, almost unchanged in their design, today.  In en-
vironmental terms, they have proved adaptive and resistive
to environmental changes over all that time.  That is to say,
                                  752

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they are well designed.

               New life forms have developed largely through

changes in the make-up of their life programs, that is, by

mutation.  These random, unpredicatable, mutations occur

partly by accident as the organism develops and partly under

the influence of cosmic rays and other radiation damage.

These mutations are usually very slight in their effect.

They change the chemical programming in some  small way/  anc^

that change induces the production of another chemical which

is strange to that organism and which can affect it for good

or for bad.  That is, it can make it better adapted or less

well adapted to its environment.

               Most of these mutations lead to death of the

organism.  That is, they are lost to evolution as soon as

they are formed.  Now the chemical programs which form our

life processes proceed mainly by pathways which are assisted

by complex enzymes.

               By definition, enzymes are chemicals which

take part in a chemical reaction, but which are unchanged by

that reaction.  So any of these mutations which produce an

improved enzyme will produce an improved organism.

Conversely, any mutation xvhich produces a destructive enzyme

will lead to the death of that organism.  The same will

happen if a chemical is introduced by mutation which blocks

the action of an enzyme.
                             Yi>3

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               So we can imagine that mutations occur perhaps




every hundred generations.  That is, in every hundred




generations any one species or type of living organism has




the opportunity to improve itself with respect to its




brothers and sisters, and to lead on to an improved species;




that mutation will tend to be retained.  But the lethal




mutations, the harmful ones, are different.  They are, as I




have said, immediately lost again.




               Now, what I am getting at is this.  During the




thirty million years of life, and the three million years of




man, there has been ample opportunity for producing a vast




array of new chemicals by mutation.  There has been ample




opportunity to retain the good ones.  The bad ones all are




being lost, I comment again, along the line.  In other words,




all the chemicals we can find on earth now, which occur




naturally in life forms, can be assumed to be more or less




necessary for life processes.




               On the other hand, any chemical which we




cannot find occurring naturally, and which conceivably can




be made by an enzymic system, must be assumed to be harmful




to life unless that it is proved to the contrary over many




generations.




               Here is my first important point and I would




like to repeat it.  Any chemical which we are making today




in industry, and which^could conceivably be made by an

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enzymic program, and which does not already exist in


nature, must be presumed to be harmful to life unless proved


harmless over many generations.


               My second point is this.  If any such chemical


is harmful not at once, but insidiously, over perhaps ten


generations, shall we say, then we can observe that harmful


factor in a few hours with bacteria, and in a few years with


annual plants, but we shall not find out their effect on man


for two hundred years, on the ten-year analogy.


               So, in summary, I have explained to you any


chemical which is being made in industry today and which


does not already exist in nature may possibly, by delayed


mutation, kill off all mankind and even all life on earth


within decades or centuries if that chemical is not quickly


broken down by natural physical or chemical processes, or


natural pathways in living organisms -- that is, is not


biodegradable into harmless breakdowns or alternative


products.


               If you accept this thesis, and I think it is


very difficult not to accept this at least as a prudent


point of departure until it is disproved, then the EPA has


two immediate and grave responsibilities and duties.


               One is to recommend to our government that the


production of all chemicals which are not already occurring


in nature must be stwpped until they are proven harmless to
                    "*

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all life forms.
               The second is to secure that, until that
complete ban is in effect, the production, dissemination and
ultimate resting place of all such chemicals is carefully
controlled and executed in such a way that it does not
affect life forms today, and cannot affect life forms into
the infinite future.
               The EPA indeed has a grave responsibility
not only on behalf of the United States, but of the world,
and of the future generations of the world.  The U.S.A. is
indisputably the world leader in producing new chemicals,
and in distributing them around the world.  The U.S.A. has
the responsibility now to set an example in controlling that
practice.  The EPA has the responsibility of securing that
that example is set.
               It is nothing less than that that we are
considering today.
               Now in light of that analysis, I would like
to offer a few suggestions for managing ultimate disposal
facilities to meet those objectives.
               Our comments are concerned with treatment
and disposal of toxic and hazardous wastes, in general,
and the facilities for managing them.  They therefore apply
to any and all such sites wherever they may be world-wide,
unless we refer to obviously a local situation.
                            7S6       	   	

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               The proposals we are offering are not
exhaustive.  They are presented here as first thinking,
as a basis  for discussion of some aspects of control.
               Hopefully, legislators at Federal and at state
levels, and  administrators at city and county  levels,  will
assist the  promulgation of the principles I am about to
propose.  Hopefully, industries will recognize the intention
and produce their own regulations to provide the same levels
of safeguards, as they have already begun to do in the drug
industry, for example, for safe disposal of used containers
for agri-drugs.  Then we will have fulfilled, so far as we
can, the stewardship entrusted to us, that of preserving our
resources for the benefit of our grandchildren.
               In general principles, we suggest that no
industry or enterprise has any right to produce any material
that may be dangerous or offensive to any citizen or to the
environment.
               Secondly, all wastes should be recovered for
beneficial use.  The term, wastes, should soon be obsolete
and waste resources should be mandatory.
               Under certain circumstances, which include
compliance with safe, proper and prudent precautions, it may
be permissible for toxhaz materials to be produced, providing
that, at all times into the foreseeable future, the prime
emitter of that material retain full legal and financial
                        7S7

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responsibility for any damage caused by that material.
               Now that responsibility cannot be discharged
by subcontracting to some hauler or a processor.  But where
 a hauler or a processor is employed, then they also should
be responsible for any damage caused by their action or
inaction.
               Now the purpose of this is to secure that the
emitter shall take care to select a reliable subcontractor,
and not necessarily be tempted to employ the lowest bidder,
without regard to quality of care.  It should be noted that
it is already established for pharmaceutical drugs that the
manufacturer is responsible for any damage caused to patients
irrespective of the intermediacy of a doctor or hospital.
               Another purpose of this proposal is to secure
that an aggrieved party shall have recourse for damages in
law against a substantial defendant, the manufacturer, even
if a subcontracting haulsr or processor concerned has  ceasec
trading.
               The circumstances under which an industry may
reasonably produce a toxhaz material includes, for example,
clear labeling of contents, clear labeling of their dangerous
nature, clear labeling with explicit and detailed instruc-
tions on how to treat a person or to decontaminate a surface
or volume which has become contaminated, effective and safe
packaging, explicit and clear instructions for safe disposal
                           7S8

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of  contaminated empty containers,  and  so on.

               The responsibility  I have just mentioned  is

expressed there as related to any  emitted product.  As we

have phrased  it,  it may  seem to apply  to marketed  finished

products, and the "processor" will be  interpreted  as the

agricultural  spray contractor, or  the  painting shop, for

example.  But it  also includes, under  the term "emitter",

the producer of by-products, of conversion end-products, and

of  unwanted surpluses of any or all of those.

               In short, any and all who are involved in the

chain of production, handling, conversion, end use, and

disposal of any toxhaz material should individually and

collectively be responsible in law for any harm done at any

point in that chain.  Only by total acceptance in  this way of

responsibility by all concerned can we hope to secure

responsible management to toxhaz materials.

               Now, nothing I have said is intended to sugges

other than that it is the prime responsibility of  the

producer or emitter to manage his own wastes for himself.

If he cannot do so, he should not be allowed to continue in

business.

               If it is more convenient to him to acquire the

services of a specialist to manage this aspect of his busi-

ness for him,  that must not diminish his responsibility for

that management and he"must carry the  full burden of costs
                          YS.S

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of that subcontracting.




               It is of no benefit for the community through




its taxes to subsidize part of the real costs of a business




just because that business is contributing to the taxes.




Still less does it benefit that community to do so for a




business in another community.  Environmental damage is a




real cost, no matter how difficult it is to quantify in




short-term dollars.



               Once this principle is established, that the




producers, emitters and users should not, by subcontracting,




be able to divest themselves of their responsibilities in




law for safe management and ultimate disposal of their




products or of their wastes, we are now going to consider




some comments about ultimate disposal of those wastes, the




responsibility of the emitter.




               At the present time there are no Federal laws




I know of that specifically and directly govern or regulate




toxhaz management, or that ca n be related to this topic.




The EPA has prepared drafts, which we are probably consider-




ing in part now.  We have no direct management in Texas.




               It is debated whether any existing transport




regulations could be used to control or prohibit the




transport of toxhaz materials across the state or county




boundary.  This needs to be investigated.




               There j.s, a need for good, efficient, effectiv<



                        ' 800

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well-run toxhaz facilities, nationwide.  Distances involved
suggest that more than one should be in Texas.  In this
highly industrialized civilization, during the ten years,
1960 to 1970, we produced as many new chemicals as were
recorded in all the years before 1960.  This rate of increase
will continue as the techniques of tailored synthesis are
refined.  It is inevitable that a proportion, as I have
already explained, and perhaps a large proportion of these
will be toxhaz to a greater or lesser extent.
               The thalidomide tragedy and the Denver
radioactive mine tailings debacle are examples whose results
were recognized within a decade.  Many of the problems we
foresee may require several human generations to become
evident, and that will be too late, and we already have
warnings, for example, about DDT and its genetic effects
which are delayed.
               We propose that Texas should establish at
least three comprehensive and large regional sites, perhaps,
for example, at El Paso, Dallas-Fort Worth and Houston.
These should provide high standards of management for the
same routine wastes, that is, they replicate each other
and save distance of trucking or train loading.
               If there is a local concentration of in-
dustries which produces a class of exceptional wastes, then
the nearest one of those -three centers should, in addition,
                          SGI

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have specialized facilities for managing that class of
wastes for the entire state, in order to acquire common
scale management.
               This probability justifies establishing a
fourth central site.  Both the Austin and the Groesbeck
regions are, geographically, logical sites.  Further, the
clay deposits are near ideal for long-term safe storage, so
far as we know today.
               It is, therefore, unfortunate that in both
these areas attempts have been made to introduce a toxhaz
facility hurriedly, and without the careful program of
information and explanation to the surrounding communities of
the nature of such an operation that should precede
definitive planning.
               Now in order to manage a toxhaz facility
efficiently and safely, we suggest that an applicant for a
new license to operate a disposal facility should be required
to show that there is a need for it in that area.  This is
analogous to the "certificate of need" which is a require-
ment for opening, for example, a new hospital, a regulation
that is enacted in many states, and is now being considered
in Texas.
               It is not sufficient to show it will be
cheaper for the emitter to use a facility which is nearer.
It should also be shown it .would be cheaper for the state
                            8U2

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and the nation.  This is analogous to the "benefits-of-size"


thinking that underlies the present regional planning of,


for example, sewage works and of sanitary landfill sites.


               The applicant should be required to declare


what additional services he will provide at his facility


that are not available at other facilities in the state and


in all the bordering states and what services are available


at each of those that he will not provide, in order to show


that he has studied the specific need requirements.


               MR. LEHHAN:  Excuse me, Dr. Stanford.  We are


running a little short of time.


               DR. STANFORD:  How long would you like me to


proceed?


               MR. LEHMAN:  You are already over the fifteen


minutes.


               DR. STANFORD:  I see. Thank you.


               Okay, I will skip that and come on to the


next point, that which is facilities, which is crucial.


               Each site should include a fully equipped


and staffed analytical laboratory.  The certificates, which


was also suggested by Mr. Haxby, should be verified against


the contents as authorized by the material permit.


               These laboratories should be staffed and


funded by the University of Texas in its different centers


answerable to the University and their records should be

                             n i • r»
                             ouo

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open.  They can also be used as teaching facilities.




               Each laboratory should also be charged with




day-to-day supervision of the safety and good management




of the entire facility and should be answerable in this




regard both to the legislature and to the regulatory board.




               The funding for each laboratory should be




obtained by a tax on each barrel or on each unit volume or




weight of bulk material that enters the facility.  The




management of the laboratory should be completely independent




of the management of the facility that treats the materials.




               I think I will stop at that and hand in ray




full written declaration.




               Thank you very much.




               MR. LEHMAN:  Will you accept questions?




               DR. STANFORD:  Yes.




               MR. LEHMAN:  We have an urgent message here




for Mr. Henry Gregory of the City of Houston.




               Now, Mr. Lindsey, do you have a question?




               MR. LINDSEY:  Yes.  By way of clarification.




Doctor, as I understand , what you are  saying is,  you  are




recommending three or four sites for Texas.  Are you saying




that these should be state run, state franchised or complete!




private?




               We have also heard on one additional point




relative to that, we have alse heard in previous meetings

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and  in this one  that the problem of too few suitable  sites




is a real problem.




               Is there also a problem on the other end of




the  scale if we  have a multiplicity of sites?  In other




words, you are recommending three or four.




               DR. STANFORD:  I agree with those points.  I




think there are  too many small sites and not enough well




studied big sites which are able to cope with the requirement




of bulking and neutralizing one chemical against the other




so that you could hold both until you got regular amounts of




both.




               The logical thing to do is to establish a




tox'ic  facility  in a chain link common fence compound that




is completely enclosed for management facilities and to leave




space in that chain link for factories to move in which wish




to produce tox'ic materials, specifically and tie them in




with the disposal management plant, such that they can be




encouraged to take each other's wastes, so they are all, you




know, under complete surveillance.




               This could produce very high taxes to a




region.  For example, to Austin or to Groesbeck.




               I am suggesting that a facility for disposal



can  be managed by the state or by private enterprise,





providing the analytical laboratory emitting the materials




verifies what they art  "his provides for management  control



                            tiuS

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because it is indeoendentlv  funded.
               MR. KOVALICK:   Dr. Stanford, could I get you
to elaborate on the point that there is a demand in one
state, for example, Texas, and therefore it is deserving of
or should have three or four sites to meet that demand?
               That comment leads me to the point that only
those wastes that are generated in Texas should be handled
in Texas.   Those private industries that want to be in this
business,  are they only going to be limited to Texas wastes
because other states would follow this pattern?  Is that
what you are suggesting, that waste from a state are only
that state's responsibility?
               DR. STANFORD:   I think because I left out
some sections — I am suggesting, frankly, the opposite.  A
state should work very closely and that is why I have
suggested that any applicant for a permit should include
information about neighboring states' facilities to show
there is nothing within a reasonable distance, interstate
cooperation is desirable.
               Have I answered your question?
               MR. KOVALICK:  Yes.
               MR. LEHMAN:  Do we have any other questions?
                (No response.)
               MR. LEHMAN:  Evidently not.
               Thank you very much,D r. Stanford.

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               I would like to call George Maxon.




               MR. MAXON:  Mr. Chairman, I am George Maxon,




an employee of the Texas Water Quality Board.




               Out of deference to Mr. Woods' statement, I




am, as yet, an uncommitted employee.  If any of you rich




industrial people want to buy one, I'm available.




               (Laughter.)




               I have a statement that is rather lengthy.  I




will not read it.  I think it is available to you.  I would




like to make some few comments, however.




               We in the state or more specifically in the




Water Quality Board have been in the solid waste business




approximately five years.  We feel we have done a pretty




good job and we feel we can do better and intend to do better




               We are one of the few states in the nation




with a split responsibility for solid waste.  The municipal




waste is controlled and regulated by the Department of




Health Resources.  We have the regulatory responsibility




for industrial waste.  The Department of Health Resources




has the responsibility for mixed municipal and industrial




waste.




               Most of the hazardous waste which is of




interest to this group, as nearly as I can determine, is




industrial waste, and we feel a vested interest in this




particular group, and this is primarily why we are here.

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               We recognized several years ago the need for




improvement in our system.  As a consequence, about 18 months




ago we started a series of public hearings revising and




feeling the pulse of industry in an effort to develop a




more practical solid waste regulation.




               Strangely enough, one of the most difficult




tasks that we have tried to solve, and it is as yet un-




solved, is defining hazardous wastes.  We think we almost




have it and then some other individual gets up and brings




out something we hadn't thought of or a lawyer says, well,




this and that, so we have attempted to define solid waste




and we try to use the EPA definition in 92-500, and a lawyer




shot us down on that.  We tried others, but I think that




everyone in this assembly knows what hazardous waste is,




regardless of what the legal definition is.  And if I can




leave it at that, then I won't belabor the point any




further.




               We were successful in passing our new solid




waste regulation at the last Board Meeting on the 24th of




November.  I have given you a copy of that, Mr. Chairman.




I do not have enough to pass out to everyone.




               We feel that this will give us a pretty good




handle on solid waste disposal throughout the state.  From




an egotistical standpoint, if you want to call it that,




we feel that we as a state regulatory agency are capable of

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handling the solid waste within the state.  We need help

from individuals.  We need help from the Federal government,

and we need help from industry.

               One of the primary problems that we have

encountered over the years in solid waste disposal is public

acceptance of the fact that you have to dispose of solid

waste.  We have found sites throughout the state that are

geographically and geologically ideally suited for disposal.

They have been shot down the tubes by citizens who do not

want that type of stuff next to them or in their county.

               I think the EPA started out well in the public

awareness and their edification program, if you would like to

call it that, to the public, and unless and until the public

is willing to accept adequate well-regulated, well-controlled

disposal facilities for the waste products that are generated

through the manufacture of items that they demand as a public

we are going to be in deep serious trouble.

               We need desperately research data that can

educate the public as to what happens to waste.  Are we

burying time bombs?  Are we sure that burying a substances
within the
constrictions,  restrictions and constraints of the disposal

techniques that we employ, would be a harmless waste by the

time our controls have been eliminated?

               I am not smart enough to give those answers

and we have found from time to time that the people in good

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faith who are in opposition to us frequently will take




quotes out of context and through emotionalism stir up the




general pub]ic and make it extremely difficult for a




regulatory agency to do just that.




               We work for the state and it is our job to




please the state public.  We solicit your help.  We earnestly




request that you bear with us.  We will cooperate with the




EPA to any extent we can.  We feel we are capable of adequate




regulation and disposal of the solid waste within the state.




We would ask help for research data.  We will exchange in-




formation with anyone who wants to.  We are in the learning




process and we would like to learn as rapidly as possible




and pass whatever information we night obtain from anyone to




any other individual or company who is interested in it.




               Thank you.
                          810

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                    Statement for the Record
The regulatory responsibility for the disposal of solid wastes in
Texas is divided between the Department of Health Resources and
the Water Quality Board.  The Department of Health Resources is
responsible for municipal and mixed wastes disposal while the
Board is the regulatory authority for industrial waste disposal.
The subjects we are addressing today appear to fall primarily in
the industrial waste classification and as such are of vital
interest and concern to the Texas Water Quality Board.

For the past five years we have been working at State level to
establish a program which will provide adequate sites and the
safe and proper disposal of hazardous wastes.  We have encountered
several roadblocks.  Some of these are:   (1) Lack of public
acceptance.  People actively seek out new and better products.
The production of many of the items results in the generation of a
more sophisticated or hazardous waste materials that the same
people are unwilling to allow to be disposed of in their area.
(2) Technical limitations and lack of research data.  Our tech-
nological advances are more toward development of new products
than adequate disposal of the residue generated by such develop-
ments.  This is only natural.  We are grossly lacking in the
technology necessary to adequately dispose of the more sophisti-
cated wastes,  however.  Very limited research data is available.
Many waste products lack economically acceptable disposal tech-
niques.  A limited number of hazardous wastes must be returned
to the factory for disposal.  This void in the treatment or dis-
posal practices generates many "what if?" questions that have no
answers.  We need answers.   (3) Acceptable and economically feasi-
ble recovery techniques.  The abundance of some products and the
high cost of recovery of others encourages temporary storage of
some wastes until cheaper recovery techniques are developed or
until esculating market prices for that product make recovery
profitable.  "Temporary" in some cases is five or more years.
(4) People trying to beat the system.  This problem will exist as
long as people exist.   It should and can be reduced through tighter
controls and a better "police force" to ferret out violators.

The above problems were highlighted in a series of public hearings
recently concluded by this agency.  The hearings gathered infor-
mation and felt the pulse of both industry and the public.   With
inputs from the hearings, we developed a new industrial solid
waste regulation which was approved November 24, 1975 and will
become effective January 1,  1976.  We feel confident that this new
regulation will provide adequate controls over the generation,
and disposal of industrial hazardous wastes in Texas.  We will re-
quire an inventory/shipping control system for the disposal of
such wastes.


                                 611

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The public hearings confirmed that many ill-informed people feel
we are burying time bombs which could and probably would destroy
our drinking water, wildlife and people within five years or
perhaps a thousand years.  Lack of information provides the oppo-
sition with a fertile field to manipulate half truths into "what
if" questions and generate actions through emotionalism rather
than facts.  We need substantiated facts to counteract these
tactics.  This can be done to a degree through a public awareness
program.  The people need to be made aware that proper disposal
techniques are available and they must have confidence that these
techniques will be followed.  Basically the public must be informed
of the wastes generated by the products they demand from industry.
They should be encouraged to permit disposal of these wastes in an
authorized, regulated manner rather than the alternatives public
pressure is forcing on industry.  It's time the facts surfaced and
the public not only be made knowledgeable of the disposal problems
encountered but also encouraged to accept the civic responsibility
of entering into a sane solution to the disposal of hazardous
wastes.  A properly channeled, public awareness program can be of
immeasurable help.

I have studied Senator Randolph's proposed amendment (S2150) to
the Solid Waste Disposal Act with considerable concern.  I would
hope that the Environmental Protection Agency gained enough
knowledge through implementing the NPDES program to avoid the
similar pitfalls contained in Senator Randolph's proposal.  Any
amendment to the Solid Waste Disposal Act must avoid the admin-
istrative false starts and the many changes in forms, procedures
and definitions contained in the NPDES program.  Duplication must
be avoided.  States with adequate solid waste programs should be
allowed to continue until those with inadequate programs have been
"brought up to speed".  Let EPA learn, develop a program, and gain
experience in that manner rather than attempt to regulate the
entire nation without being properly equipped.  Bring about equality
and standardization by upgrading the less effective rather than
downgrading the effective programs.  Organization and preparation
are essential to a well run program.  Hopefully the EPA will be
given enough time for both before undertaking a nation wide solid
waste program as opposed to the compressed time frame and pressures
they were subjected to under the NPDES program.

Thank you for the opportunity to present my views.  I feel confident
that the lessons we have learned over the past five years are re-
flected in our new solid waste regulation.  It will produce the
desired results.  We feel the most effective assistance the EPA
can provide us is through selective research and other grants.
Our solid waste program will continue to improve.  We would prefer
                              812

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co "go it alone",  but will work with the  EPA  to  establish  an
effective Federal program within the State if it becomes necessary.
'eoxge E. Maxon,/Chief
Solid Waste Branch
Central Operations Division
Texas Water Quality Board
                                Date   December  8.  1975
                          613

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                    TEXAS WATER QUALITY BOARD
                P. 0. Box 13246, Capitol Station
                       Austin, Texas 78711
                       ORDER NO. 75-1125-1
AN ORDER of the Texas Water Quality Board approving and adopting
         the attached industrial solid waste management regula-
         tion; repealing Board Order No. 71-0820-18; repealing
         Section 310 of the Rules of the Texas Water Quality Board;
         and directing the staff to mail a copy of this order and
         the attached regulation to all persons known by the
         Executive Director to be interested in this matter.
                             PREAMBLE

As directed by the Board, public hearings have been held and an
Industrial Solid Waste Management Regulation has been developed
in order to more effectively safeguard the health, welfare and
physical property of the people of the State through controlling
the collection, handling, storage and disposal of industrial solid
wastes.  The proposed regulation is consistent with the Solid
Waste Disposal Act, Art. 4477-7, as amended, V.T.C.S.  Such regu-
lation, if approved by the Board, would probably be effective by
December 31, 1975.

Hearings concerning the regulation of industrial solid waste have
been conducted over the last eighteen (18) months.  First, hearings
were held around the state to feel the pulse on what was needed in
solid waste regulation.  Following those, five additional hearings
on various draft proposals were held.  Comments were received and
evaluated and a draft proposal considering these was circulated
to all interested parties prior to the November 10, 1975 hearing.
In order to give the most complete and up-to-date picture of the
staff's views concerning what should be in the regulation, a final
draft proposal, taking into account comments received, was pre-
pared for handout at the November 10, 1975 hearing.  So that any  •
confusion as to what changes were being made would be minimized,
George Maxon, of the staff, went through the draft pointing out
and commenting on the changes.

In light of the evidence and testimony included in the record of
the public hearing conducted on November 10, 1975, the Texas Water

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Quality Board finds that (1) the Industrial Solid Waste Management
Regulation should be approved and adopted, (2) Texas Water Quality
Board Order No. 71-0820-18 should be repealed, (3) Section 310 of
the Rules of the Texas Water Quality Board should be repealed, and
that (4) the proposed regulation is consistent with the Solid Waste
Disposal Act, Art. 4477-7,  as amended, V.T C.S.  Now, therefore,

BE IT ORDERED BY THE TEXAS WATER QUALITY BOARD THAT:

1.  The attached Industrial Solid Waste Management Regulation be
    approved and adopted.

2.  Board Order No. 71-0820-18 be repealed.

3.  Section 310 of the Rules of the Texas Water Quality Board be
    repealed.

4.  The staff be directed  to mail a copy of this Order and the
    attached regulation to all persons known by the Executive
    Director to be interested in this matter.

Issued this 25th day of November, 1975.
                         TEXAS WATER QUALITY BOARD
                            Douglass Tole,Chairman
                Jr», /fexecutive Director
                                815

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                    TEXAS WATER QUALITY BOARD

           INDUSTRIAL SOLID WASTE MANAGEMENT REGULATION


CHAPTER I   GENERAL

  Section 1.01 - Introduction and Purpose

        Industrial solid wastes as defined in the Solid Waste Act
        range from wastes that are solid,or nearly so, to wastes
        that are entirely liquid.  Wastes may be found in almost any
        form and may be in any type of containers,  in short, the
        term industrial solid waste may encompass essentially any-
        thing that does not flow from the regular waste discharge
        pipe or system of the industrial or commercial enterprises
        that created the waste.

        The regulations following are based upon the basic policy
        that the collection, handling, storage and disposal of in-
        dustrial solid waste must be a carefully designed, technically
        feasible, professionally carried-out operation.  Because of
        the variety of technical processes and arrangements which may
        be needed and due to the probability of future technical in-
        novations,  the Regulation does not attempt to define or state
        specific technical or operational requirements.

        The purpose of this Regulation is to safeguard the health,
        welfare, and physical property of the people by controlling
        the collection, handling, storage and disposal of industrial
        solid waste, pursuant to the Solid Waste Disposal Act, Art.
        4477-7,  as  amended, V.T.C.S.

  Section 1.02 - Definitions

        For the purpose of this Regulation, the definitions of terms
        used in the Regulation are those provided in Rule 100.0 of
        the Rules of the Texas Water Quality Board and Section 2 of
        the Solid Waste Disposal Act, and for the purposes of this
        Regulation, the Board ascribes the following meaning to the
        following terms:

        1.  "Act" - means Solid Waste Disposal Act, Art. 4477-7, as
            amended, V.T.C.S.
        2.  "Annual Disposal Summary" - report to the Texas Water
            Quality Board submitted by generators summarizing on-site
            waste disposal, and off-site shipments of Class II wastes

                                           Board Order No. 75-1125-1
                                           General
                             o •$ >*
                             010

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     for the prior one-year period.
 3.  "Board" - Texas Water Quality Board.
 4.  "Class I Waste" - All waste materials  not classified
     as Class II or III, normally including all industrial
     solid wastes in liquid form and all hazardous  wastes.
 5.  "Class II Waste" - Organic and inorganic industrial
     solid waste that is readily decomposable in nature and
     contains no hazardous waste materials.
 6.  "Class III Waste" - Essentially inert  and essentially
     insoluble industrial solid waste,  usually including
     materials such as rock, brick, glass,  dirt, certain
     plastics and rubber, etc., that are not readily decom-
     posable .
 7.  "Carrier" - Any person who conveys or  transports indus-
     trial solid waste off-site by truck,  ship, pipeline or
     other means.
 8.  "Commercial Disposal Operation" -  Those disposal opera-
     tions which store or dispose of waste  generated by others.
 9.  "Disposal Operation" - Refers to the activities of an
     operator in receiving, storing, retaining, processing,
     or disposing of industrial solid wastes.
10.  "Disposal Site" - Includes all land,  facilities, fix-
     tures, structures, and appurtenances  for receiving,
     handling, processing, storing, retaining, or disposing
     of industrial solid wastes.
11.  "Essentially Insoluble" - Means if when placed in either
     static or dynamic contact with deionized water at ambient
     temperature for seven days, it will not leach  any quan-
     tity of any constituent of the material into the water
     in excess of USPHS limits for drinking water.
12.  "Executive Director" - The Executive Director  of the
     Texas Water Quality Board or his designated representa-
     tives .
13.  "Generator" - Any person who produces  industrial solid
     waste.  The generator is also the  shipper in the case of
     off-site disposal.  The carrier will be considered to be
     the generator for those wastes received from out-of-state.
14.  "Industrial Hazardous Waste" - Means any waste or mix-
     ture of waste which, in the judgment of the Executive
     Director, is toxic, corrosive, flammable, a strong sen-
     sitizer or irritant, generates sudden  pressure by de-
     composition, heat or other means and would therefore be
     likely to cause substantial personal  injury, serious ill-
     ness, or harm to human and other living organisms.
15.  "Industrial Solid Waste" ("industrial  waste" or "waste")
     Solid waste resulting from or incidental to any process
     of industry or manufacturing or mining or agricultural
                        817
                                    Board Order No. 75-1125-1
                                    General

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     operation, including discarded or unwanted solid ma-
     terials suspended or transported in liquids,  and dis-
     carded or unwanted materials in liquid or semi-liquid
     form.
16.  "Mixed Waste" - Means combined municipal and industrial
     waste as described in Section 3(c) of The Solid Waste
     Disposal Act.
17.  "Off-Site Disposal" - A disposal operation in which a
     generator or shipper transports industrial waste to a
     receiver for disposal.
18.  "Off-Site Disposal Summary" - A monthly report to the
     Texas Water Quality Board submitted by shippers of
     Class I wastes summarizing shipments for the prior one-
     month period.
19.  "Operator" - Means a person who accepts industrial solid
     wastes from other persons for storage, retention or
     ultimate disposal on property owned or controlled by him.
20.  "On-Site Disposal" - A disposal operation in which a
     generator, under the provisions of Section 4(f) of The
     Solid Waste Disposal Act, Art. 4477-7, V.A.C.S., disposes
     of industrial solid waste within the boundaries of a tract
     of land which is owned and controlled by the generator
     and which tract of land is located within fifty (50)
     miles of the generator's facility from which the waste
     is produced.  A disposal operation shall not be con-
     sidered on-site disposal if the waste is collected,
     handled, stored or disposed of with waste from any other
     source or sources.  Other source or sources means generat-
     ing points under different ownership and does not pro-
     hibit one company from using one site for disposal of
     its waste from more than one generating point within
     fifty (50) miles of such generating points.
21.  "Permit" - Means a written permit issued by the Board
     which, by its conditions, may authorize the permittee
     to construct, install, modify, or operate a specified
     disposal site, conduct specified activities,  or dispose
     of industrial solid wastes in accordance with specified
     limitations.  Permits do not apply to activities regu-
     lated under Chapter II of this Regulation.
22.  "Person" - Means individual, corporation, organization,
     government or governmental subdivision or agency, busi-
     ness trust, partnership, association, or any other legal
     entity.
23.  "Receipt Summary" - A monthly report to the Texas Water
     Quality Board by receivers of waste shipments summarizing
     shipments of waste received during a one-month period.
24.  "Receiver" - Any person or organization who received
                    "    818
                                    Board Order No. 75-1125-1
                                    General

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           industrial solid waste generated by other persons for
           processing, storage, or disposal.
     25.   "Shipment" ("Transport") - Any action involving the
           conveyance of industrial solid waste off-site by any
           means.
     26.   "Shipper" - Any person who ships industrial solid waste
           for off-site disposal.  The shipper is usually the
           generator but may be a person collecting wastes at a
           central location prior to further shipments.
     27.   "Shipping Control Ticket" ("Shipping Ticket") - A Texas
          Water Quality Board form to accompany shipments of Class
           I industrial solid wastes.
     28.   "Storage" - Means interim containment or control of
          waste after generation and prior to ultimate disposal.
     29.   "Water" or "water in the state" - Means groundwater,
           percolating or otherwise, lakes, bays, ponds, impound-
           ing reservoirs, springs, rivers, streams, creeks, estu-
          aries, marshes, inlets, canals, the Gulf of Mexico in-
           side the territorial limits of the state, and all other
          bodies of surface water, natural or artificial, inland
           or coastal, fresh or salt, navigable or nonnavigable and
           including the beds and banks of all watercourses and
          bodies of surface water, that are wholly or partially
           inside or bordering the state or inside the jurisdiction
           of the state.

Section 1.03 - Responsibility of Industry Producing the Waste

      Any generator that allows its industrial solid waste to be
      disposed of at a disposal site which is not covered by
      valid authorization, Permit, Certificate of Registration,
      Waste Control Order, or Order of the Board permitting the
      solid waste disposal operation is in violation of the Solid
      Waste Disposal Act and this Regulation.  In the event of any
      unauthorized disposal of industrial solid waste, the Board
      will seek recourse against not only the owner and operator
      of the disposal facility but also against the generator
      which allowed or suffered its solid wastes to be disposed
      of in this manner at that location and may require the genera-
      tor to participate financially in whatever steps must be
      taken to place the site in an acceptable condition.

Section 1.04 - Prohibitions

      This Regulation prohibits the collection,  handling, storage
      and/or disposal of industrial solid wastes in such a manner
      so as to cause:         .    „. _
                                 0 X O
                                         Board Order No. 75-1125-1
                                         General

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      1.  The discharge or imminent threat of discharge of waste
          into or adjacent to the ground or surface waters of the
          state, except pursuant to a valid Texas Water Quality
          Board Permit issued under the Texas Water Quality Act;
      2.  The creation or maintenance of a nuisance;
      3.  The endangerment of the public health and welfare; and/or
      4.  The disposal of industrial solid waste in an unauthorized
          site by either the generator or carrier.

Section 1.05 - Deed Record Requirements

  A.  The owner or person controlling an industrial solid waste
      site is required to submit for recordation in the county
      deed records of the county or counties in which the site is
      located the following:

      1.  A metes and bounds description of the portion or por-
          tions of the tract utilized for the ultimate disposal of
          industrial solid waste;
      2.  The Texas Water Quality Board class or classes of the
          materials disposed or proposed for disposal; and
      3.  The name and permanent address of the person or company
          operating the site where more specific information on
          the materials can be secured.

  B.  Proof of recordation or denial of such request for recorda-
      tion shall be provided to the Texas Water Quality Board in
      writing.
  C.  Such recordation shall, in the case of sites opened after
      the effective date of this Regulation, be made prior to the
      acceptance of any waste for disposal.  All sites in opera-
      tion on or before the effective date of this Regulation
      shall record the information required in Section 1.05-A
      within one hundred eighty (180) days of the effective date.

Section 1.06 - Violations

      Under Section 8 of the Solid Waste Disposal Act, violations
      of the Act or any rule, regulation, permit, license, or
      other order passed under the Act are subject to injunctive
      relief or civil penalty, or both.

Section 1.07 - Guidelines

      In order to promote proper collection, handling, storage and
      disposal of industrial solid waste consistent with the intent
      of this Regulation, the Terfas Water Quality Board will make

                                         Board Order No. 75-1125-1
                                         General

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      available upon request copies of technical guidelines de-
      veloped by the Board's staff.  The guidelines will outline
      methods deemed adequate by the Executive Director to pre-
      vent the creation or existence of the conditions prohibited
      in Section 1.04 of this Regulation.

      Guidelines are suggestive only.  Other procedures determined
      by the Texas Water Quality Board to be equally as effective
      in preventing the creation or existence of the conditions
      prohibited in Section 1.04 of this Regulation may be em-
      ployed .

Section 1.08 - Exclusions

  A.  Disposal sites for soil, dirt, rock, sand and other natural
      and man-made inert solid materials used to fill land where
      the object of the fill is to make the land suitable for the
      construction of surface improvements are not considered in-
      dustrial solid waste disposal sites under the Solid Waste
      Disposal Act.
  B.  Disposal of waste materials which result from activities as-
      sociated with the exploration, development or production of
      oil or gas.  Such disposal activities are under the juris-
      diction of the Railroad Commission of Texas.
  C.  Under the Solid Waste Disposal Act, industrial solid waste
      does not include waste materials, the discharge of which is
      subject to the Texas Water Quality Act.  To discharge under
      the latter act, includes to deposit, conduct, drain, emit,
      throw, run, allow to seep, or otherwise release or dispose
      of, or to allow, permit, or suffer any of these acts or
      omissions.  Under the Board's water pollution abatement
      powers of the Water Quality Act, it may control or regulate
      situations where a threat to discharge exists.
  D.  This Regulation does not apply to radioactive wastes which
      are controlled by the Texas Department of Health Resources
      and the appropriate Federal agency.

Section 1.09 - Emergency Orders

      Whenever in the judgment of the Board or the Executive
      Director there is good reason to believe that a violation
      or threat of violation of an industrial solid waste permit,
      registration or the Solid Waste Disposal Act is creating or
      will create an immediate and serious threat to human life
      or health, or is causing or will cause extensive or severe
      property damage or economic loss to others, and that other
      procedures available to the Board or the Executive Director
                               521
                                         Board Order No.  75-1125-1
                                         General

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        to remedy the situation or prevent the situation from oc-
        curring will result in unreasonable delay, the Board or the
        Executive Director may issue an Emergency Order to the per-
        son or entity responsible for the violation or threat of
        violation, directing that corrective action or other appro-
        priate remedial or preventive measures be taken.  If the
        Board or the Executive Director issues an Emergency Order
        under this section without a hearing, the Order shall fix
        a time and place for a hearing to be held before the Board
        which shall be held as soon after the Emergency Order is
        issued as is practicable.

CHAPTER II   NONCOMMERCIAL OPERATIONS (ON-SITE)

  Section 2.01 - Regulated Activities

        This chapter applies to "on-site disposal", as defined in
        Chapter I, to include the collection, handling, storage and
        disposal of industrial solid waste which is disposed of
        within the property boundaries of a tract of land owned and
        controlled by the owners or operators of the particular in-
        dustrial plant, manufacturing plant, mining operation, or
        agricultural operation from which the waste results or is
        produced, and which tract of land is within fifty (50) miles
        from the plant or operation which is the source of the in-
        dustrial solid waste.  This chapter does not apply if the
        waste is collected, handled, stored, or disposed of with
        solid waste from any other source or sources.

  Section 2.02 - Notification

        Any person who stores or disposes or plans to store or dis-
        pose of industrial solid waste or who plans to modify
        existing facilities or procedures under the terms of this
        Regulation shall notify the Board in writing and is re-
        quired to submit to the Board such information as may be
        necessary to enable the Board or its Executive Director to
        determine whether in the judgment of the Board or its Execu-
        tive Director the waste disposal activity is:

        1.  One to which Subsection 4(f) of the Solid Waste Disposal
            Act applies; and
        2.  Capable of complying with the terms and not violating
            the prohibitions of this industrial solid waste manage-
            ment regulation.
  Section 2.03 - Othej Requirements
                                           Board Order No. 75-1125-1
                                           General and On-Site

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        Provisions of Chapters I,  IV and V also apply to those ac-
        tivities regulated under this Chapter.

CHAPTER III   COMMERCIAL OPERATIONS

  Section 3.01 - Permit Required

        A commercial industrial solid waste disposal site shall not
        be established, operated,  maintained or substantially altered
        or expanded and a substantial change shall not be made in the
        method or type of disposal at a disposal site until the person
        owning or controlling the  disposal site has first obtained a
        permit or an amendment of  an existing permit from the Board.

  Section 3.02 - Permit Application

        Permit applications to establish a new disposal site  or to
        substantially alter,  expand or improve  a disposal site or
        to make a change in the method or type  of disposal shall be
        filed and permits shall be issued, denied, modified or re-
        voked after notice and public hearing.   In order for  permit
        applications to be considered complete  and accepted for pro-
        cessing, they shall:

        1.  Be submitted in triplicate on forms provided by the Board
            and be accompanied by  a like number of copies of  all re-
            quired exhibits;
        2.  Include recommendations,  if any,  from the local and/or
            county governments within whose jurisdiction the  pro-
            posed site or facility is located;  and
        3.  Include such other information as the Board may deem
            necessary to determine whether the  proposed site  and
            industrial solid  waste disposal facilities and the opera-
            tion thereof will comply with applicable guidelines and
            requirements.

  Section 3.03 - Detailed Plans and Specifications Required

   A.   Before a new commercial disposal site is established,  con-
        structed,  maintained  or operated and before an existing dis-
        posal site is substantially altered,  expanded or modified,
        an applicant must submit to the Board final detailed  plans
        and specifications for construction,  operation and closing
        of the proposed disposal site and all related facilities.
        Permit issuance shall constitute approval of such plans and
        specifications  which  sjiall be incorporated by reference into
        the permit.               823

                                           Board  Order  No.  75-1125-1
                                           On-Site  and  Commercial

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  B.  Engineering plans and specifications submitted to the Board
      shall be prepared and sealed by a professional engineer,
      with current registration as specified in the Texas Engineer-
      ing Practice Act.
  C.  Engineering plans and specifications, operating procedures,
      and a staffing pattern including the qualifications of all
      key operating personnel shall be sufficiently detailed and
      complete to insure that the proposed disposal site and any
      related facilities will be constructed and operated as in-
      tended and in compliance with all pertinent state and local
      air, water and solid waste statutes and regulations.  Any
      changes to the foregoing shall be transmitted by letter to
      the Texas Water Quality Board within thirty (30) days.
  D.  A completed application for a commercial-industrial solid
      waste permit may be preliminarily reviewed by the Executive
      Director of the Board and interested state and local govern-
      ments prior to the preparation of final detailed plans and
      specifications, if requested by the Board.

Section 3.04 - Final Closing

      Until final closing of a disposal site in accordance with
      permit provisions and final cancellation of the permit by
      the Executive Director, the operator of the disposal site
      shall be responsible for the proper operation and maintenance
      of the site.

Section 3.05 - Public Hearing

      A public hearing shall be held on each permit application
      pursuant to the Rules of the Texas Water Quality Board.

Section 3.06 - Amendment

      Permits may be amended at the request of the permittee,
      Board  or Executive Director after proper notice and public
      hearing in accordance with the Rules of the Texas Water
      Quality Board.

Section 3.07 - Bond Requirement

      When a permit is issued, the Executive Director shall re-
      quire the permittee to execute a bond or give other finan-
      cial assurance conditioned on the satisfactory closing of
      the disposal site on final abandonment.  Such bond or other
      financial assurance shall bfe in full force and effect during
      the life of the permit and for so long thereafter as is
                            821*
                                         Board Order No. 75-1125-1
                                         Commercial

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        necessary for the proper closing of the site to the satis-
        faction of the Executive Director.  Any site which is
        closed in accordance with the terms of its permit shall be
        considered satisfactorily closed by the Executive Director.
        The permit shall have no force or effect until the Execu-
        tive Director has received satisfactory evidence of com-
        pliance with the requirements under this Section.

  Section 3.08 - Existing Permitted Disposal Operations

        All existing commerical-industrial solid waste disposal
        operations authorized by the Board may continue to operate
        their disposal sites under the terms and conditions of the
        registrations or permits previously issued by the Board.
        These operations shall comply with the terms and other re-
        quirements in this Regulation relating to shipping, receiv-
        ing and reporting.

  Section 3.09 - Other Requirements

        Provisions of Chapter I, IV and V also apply to those regu-
        lated under this Chapter.

CHAPTER IV   SHIPPING AND REPORTING

  Section 4.01 - Purpose

    A.   Purpose
        This chapter establishes an industrial solid waste shipping
        control and reporting system, prescribes the entities re-
        quired to participate in the system,  and sets forth shipping
        control and reporting procedures.  This chapter applies to
        noncommercial operations (on-site) and commercial operations.
    B.   General
        Three entities involved in the process of industrial solid
        waste off-site disposal are:   the shipper,  who is usually
        the waste generator but is sometimes  a central collector or
        broker of waste;  the carrier or hauler of waste materials;
        and the receiver of waste who may dispose of the waste di-
        rectly or after processing.

  Section 4.02 - Application of Regulations

    A.   Entities required to participate

        1.  On the basis  of information available to the Board,
            waste generators and shippers who employ one hundred (100;
                                 025
                                       •    Board Order No.  75-1125-1
                                           Commercial and Shipping

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        or more persons and generators and shippers who employ
        less than one hundred  (100) persons but who generate or
        ship Class I wastes.
    2.  Carriers of industrial solid waste.
    3.  Receivers of industrial solid waste.

B.  Exemptions

    1.  Industries employing one hundred (100) or more persons
        shall fall under the purview of this Regulation, unless
        they demonstrate to the satisfaction of the Texas Water
        Quality Board or Executive Director, when authorized by
        the Board, that they should be exempted and have received
        written confirmation of such exemption.
    2.  Industries employing one hundred (100) or more persons
        who generate only Class III waste and industries employ-
        ing less than one hundred  (100) persons who generate
        only Class II and/or Class III waste will be exempted.
        To obtain an exemption, the applicant bears the burden
        of substantiating the classification of his waste.
    3.  This Regulation does not apply to waste routinely col-
        lected by municipal refuse collection programs operated
        by or under the authority of governmental entities.

C.  Implementation

    1.  Effective sixty (60) days from the date of this Regula-
        tion, all receivers of industrial waste holding a valid
        Permit or Certificate of Registration issued by the
        Texas Water Quality Board for the disposal of Class I
        or Class II waste shall participate in accordance with
        this Regulation.
    2.  Effective thirty (30)  days from the date they are so
        notified by the Executive Director, generators shall
        participate in accordance with this Regulation.
    3.  Effective immediately, all carriers involved in the ship-
        ment of industrial waste which is accompanied by an In-
        dustrial Waste Shipping Control Ticket shall participate
        in accordance with this Regulation.

D.  Mixing of Wastes

    1.  Industrial waste generators and shippers shall be re-
        sponsible for assuring that wastes stored for shipment
        are segregated according to their classification and
        identified by labeling of containers, erecting signs, or
        other means necessary to clearly indicate the presence
                          826
                                       Board  Order No.  75-1125-1
                                       Shipping

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          and character of the waste materials.
      2.  When wastes of a given class are mixed with waste(s)
          of another class or classes during shipment, the re-
          sultant mixture shall be classified according to the
          waste with the lowest numeric classification present
          in the mixture (i.e. -A mixture of Class  II and
          Class I wastes would be considered Class I waste.).

Section 4.03 - Procedure

  All Class I industrial wastes must be transported  in accordance
  with the following shipping procedures.   All Class I and Class  II
  waste disposal must be reported according to the following re-
  porting procedures:

  A.  Shipping Procedures

      1.  All shipments of Class I industrial waste  off-site must
          be accompanied by a Texas Water  Quality Board Industrial
          Waste Shipping Control Ticket.
      2.  The generator or shipper will complete Part I of the
          shipping ticket and retain one copy for his records.
      3.  The carrier receiving industrial wastes for shipment
          will complete Part II of the shipping ticket and deliver
          the waste materials and the shipping ticket to the desig-
          nated destination.  Upon delivery of the waste to the
          receiver,  the carrier shall obtain the signature of the
          receiving site manager or other  representative authorized
          by the receiver to accept waste  shipments.
      4.  The receiver, upon delivery of the waste shipment and
          shipping ticket,  will complete Part III of the shipping
          ticket and retain one copy for his records, returning
          the original and one copy of the  shipping ticket to the
          carrier.
      5.  The carrier must return the original to the shipper and
          retain the final copy for his records.

  B.  Reporting Procedures

      1.  Off-site Disposal of Class I Waste

          a.   Shippers of Class I waste shall compile a monthly
              Off-site Disposal Summary from their copies of ship-
              ping tickets.  Receivers of  Class  I waste shall
              compile a monthly Receipt Summary  from their copies
              of shipping tickets.   These  reports are to be trans-
              mitted to the Texas Water Quality  Board by the 25th
              day of each month for all shipments originating
                      c,"-r              Board Order No.  75-1125-1
                                        Shipping

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             (shipped) during the prior month.  The quantity and
            classification of waste shall be itemized by ship-
            ping ticket number on reporting forms provided by
            the Board.
        b.  The Off-site Disposal Summary and Receipt Summary
            shall be submitted monthly regardless of the number
            of shipments made or received during the month.

    2.  On-site Disposal of Class I and Class II Waste;  Off-
        site Disposal of Class II Waste

        a.  Waste generators who dispose of Class I or Class II
            industrial waste on-site under the provisions of
            Section 4(f) of the Solid Waste Disposal Act, Art.
            4477-7, V.A.C.S., must maintain records of their on-
            site disposal activity.  These records shall include,
            as a minimum, information regarding the quantity,
            character and classification of the waste, and the
            method and location of disposal.
        b.  Shippers shall keep records of Class II waste
            shipped without shipping tickets.  These records
            must include, as a minimum, the carrier identity,
            date of shipment, and the waste description and
            quantity.
        c.  Generators who dispose of Class I or Class II waste
            on-site and shippers who dispose of Class II waste
            off-site may be required to compile an Annual Dis-
            posal Summary from their records of these activities
            to be submitted to the Texas Water Quality Board.
            The dates of reporting shall be determined by the
            Executive Director.
C.  Records
    1.  All copies of shipping tickets and records of Class II
        off-site disposal shall be retained for a minimum period
        of three (3) years from the date of shipment.
    2.  Records of Class I and Class II on-site disposal shall
        be retained for a minimum of three (3) years from the
        date of disposal or shipment.
    3.  All records and shipping tickets shall be kept readily
        available for review upon request at any reasonable hour
        (usually operating hours) by the Texas Water Quality
        Board staff.
D.  Completion of Forms'     __ .
                          1)28
                                       Board Order No. 75-1125-1
                                       Shipping

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        1.  General
            To comply with this Regulation, the shipper (generator),
            carrier and receiver of industrial wastes must enter
            complete information to their respective part of the
            Shipping Ticket and their respective Summary Report.
        2.  Classification of Waste
            For purposes of adequately identifying waste materials
            so that a waste classification code may be assigned, the
            Texas Water Quality Board may require a chemical analysis
            to be performed and a written description provided, or
            may take samples of the waste for analysis, or both.
        3.  Forms
            All forms for summary reports and shipping control
            tickets shall be those forms developed or approved by
            the Board or Executive Director.

  Section 4.04 - Specific Shipping and Reporting Prohibitions

    A.  Shipping or transporting of industrial waste by persons or
        organizations to which this Regulation applies without the
        utilization of a Shipping Ticket as prescribed herein, or
    B.  Failure to report as prescribed herein, or
    C.  Filing reports that are fraudulent, constitutes a violation
        of this Regulation.

CHAPTER V   SEVERABILITY

  Section 5.01 - Severabilitv

        If any provisions of this Regulation or the application
        thereof to any person or circumstance is held invalid, such
        invalidity shall not affect other provisions or applications
        of this -Regulation which can be given effect without the
        invalid provision or application, and to this end the pro-
        visions of this Regulation are declared severable.

  Section 5.02 - Effective Date

        This Regulation becomes effective on    December 31	, 1975.
                                           Board Order No. 75-1125-1
                                           Shipping and Severability

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               MR. LEHMAN:  Thank you.

               Do we have questions now from the floor?

               Mr. Crowe.

               MR. CROWE:  What kind of approach are you

anticipating taking to get these sites accepted in the

geographical areas and prove to the people' that these are

not time bombs?

               MR. MAXON:  We are bound by the state statute

which indicates one of the reasons for disproving a site is

the public opposition. ,Vmat I am saying in English is we do
                           0 ? r>
                           oou

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 not have the authority to jam something down an individual




 community's throat.  If they don't want it, we can't make




 them take it.




                I might say this, that we are not overly




 concerned with industry because industry by and large takes




 care of their own and we can regulate that.  It is the




 by-product that they create and disseminate throughout the




 state in bits and pieces and smatterings that someone calls




 up and says. What do I do with it?  We say, haul it to




 Galveston and put it on the incinerator ship, and they tell




 us what to do with that suggestion.




                (Laughter.)




                MR. LEHMAN:  All right.  Do we have other




 questions?




                Mr. Mausshardt.




                MR. MAUSSHARDT:  I have a question from the




 floor here.  The question is: Do sites which industry own,




which receive industrial waste, go through the same public




 hearing procedures as municipal and private sites?




                MR. MAXON:  They do not.




                MR. MAUSSHARDT:  Could you elaborate on why




 the difference?




                MR. MAXON:  Because the state law says so,




 that's the only difference I can give you.




                MR. LEHMAN:  Mr. Lindsey.



                         W v> j.

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                 MR.  LINDSEY:   Another question from the floor.




  Why do so many solutions  always  ultimately terminate in a




  so-called well-designed,  well-operated  drained and engineered




  landfill.




                 It's apparent  that almost all  substances are




 caustic and concentrated and yet  all  the answers point to




  concentrated  substances which are caustic even at  low levels.




                 Does your  office  advocate concentration?




                 MR.  MAXON:  I  don't fully understand the




  question.   By concentration,  if  we want it into one place,




  yes,  we do want it  concentrated  as opposed to sprayed over




  the land.




                 We are  endeavoring to approve  as many




  commercial sites as we find that are adequately prepared




  and people who are  responsible enough to run  them  as they




  say they will.  We  encourage  this throughout  the state.  We




  have  not been overly successful  in doing this.




                 Some companies have invested upwards of a




  quarter of a  million dollars  in  a site  and find that in a




  year or two they go in receivership  because they don't have




  the business  that they anticipate.




                 MR.  LEHMAN:  Mr.  Lazar.




                 MR.  LAZAR:  Mr. Maxon, here is a question




  from the audience.




                 What requirements are imposed  in Texas on



	   832             	.

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solid waste disposal contractors?
               MR. MAXON:  What requirements are imposed on
solid waste disposal contractors?
               The first requirement is they have a valid
permit.  They must have a permit or permission, if you would
like to call it that, from the Texas Water Quality Board to
operate.
               The site must be proven to protect the ground
waters and surface waters.  It must be, the types of waste
must be identified by classes, and for the most part
segregated.
               They are subjected to periodic inspections,
which we call compliance inspections.  They are required to
post a closing bond, in the event that they for any reason
close the gate and walk off.  Rather than have the taxpayers
pay for closing it, we would prefer they pay for closing it.
               I don't know whether I have answered the
question or not.
               MR. LAZAR:  Perhaps I could ask this, which
is related.  You mentioned there is provision for ground
water quality protection.  Is there any monitoring require-
ment and who does it, who pays for it?  Is it the state or is
it the contractor?
               MR. MAXON:  The monitoring that is required
to insure compliance ftfcj-th the provisions of the permit that
                         033

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we issue is done by the Texas Water Quality Board on a




periodic basis.  We do require from time to time some sites




to drill monitoring wells and to report the results of




their sampling, either on a monthly, quarterly or annual




basis.  But there are specific provisions and individual




permits which we feel are necessary to insure compliance




of the protective measures against ground water, surface




waters, flooding, and so forth.




               MR. LEHMAN:  I have a question.




               You mentioned one of the requirements of a




disposal contractor is to have a closing bond.  Could you




elaborate on that?  What is the nature of the bond and the




amount?



               MR. MAXON:  We have had problems with




determining the amount of a closing bond.  We have addressed




this problem more specifically in our new regulation.  The




old regulation was totally inadequate and as a rule of




thumb in order to provide uniform requirements throughout




the state, we more or less said two things.




               Normally we considered 25 acres as a minimum




size  for an industrial solid wast site.  We  then arbitrarily




placed  a thousand dollars per acre  for a closing bond.  While




it  is uniform within the regulation, it is completely  and




totally unfair to specific individuals and it  is totally




inadequate in  some cases.  ;, 04,

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               We are now endeavoring to evaluate the types




of waste that the individual will be handling and the




disposal or the closing cost will be predicated on what he




is handling and what if he gets mad and walks off right in




the middle of it, that is goinq to cost more than if he says




O.K., we are not going to receive any more waste and after




we treat what we treat, then we are going to walk off and




leave it or we are halfway through.  There are so many




variables here, it is going to have to be treated on an




individual basis and I don't think that you can say so much




per acre or so much per gallon because it depends on the




waste, the process it is in at the time, the process ir-




stopped and things like this.




               So we are going to endeavor at this point in




time to look at the worst possible situation for any given




site and establish a closing bond at that particular level.




               MR, LEHMAN:  Mr. Lindsey.




               MR. LINDSEY:  I have another question from the




audience.




               It starts off, why not dispose of solid or




liquid hazardous waste in desert regions where rainfall is




very small and therefore where leachate potential is very




small?




               Does Texas support such an approach, that is,




moving industrial hazardous waste to desert regions for




                            C35

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disposal?

               MR. MAXON:  Texas will support anything that

will adequately and properly dispose of our accumulating

industrial solid waste.  We cannot dictate, for example, that

someone in El Paso or Pecos set up an industrial solid waste

site and we cannot, therefore, dictate that someone from

Houston deliver that waste to El Paso.

               It is a competitive market.  The state has

no control over who does what except to regulate those who

are interested in going into this business.

               MR. LEHMAN:  Mr. Kovalick.

               MR. KOVALICK:  Could you give us a rough

number as to how many treatment and/or disposal sites there

are in Texas and do any or all of them accept waste from

out of state?

               MR. MAXON:  We have approximately 200 solid

waste sites registered in the state.  About 175 of these

are noncommercial sites, which means it is an industry

generating their own wastes, disposing of it on their own

property.  This mathematically and logically then equates

to about 25 commercial sites of various types which include

a very sophisticated site down to rubble that they are going

to use for something, buiJding later on.

               We have perhaps ten exclusive of injection

wells i perhaps ten sites throughout the state that will
                               C-36

-------
accept some form of hazardous waste on a commercial basis,
and two or three of those individuals are in the audience
today.
               MR. LEHMAN:  How about the aspect of acceptin
waste from out of state?
               MR. MAXON:  We have no objection to it.  It
is a business.  We do not feel we can regulate interstate
commerce any more than we can keep somebody from Oklahoma
qoinq to a Safeway Store and buying a package of bread.
They are in business and as long as they comply with the
rules, we are happy to have him.
               MR. LEHMAN:  Mr. "axon, will your new regula-
tions — we haven't had time to read your statement so I
will just ask you -- do your new requlations cover the
transport of wastes from the tire they are generated until
they reach a permanent site?
               MR. MAXON:  Mr. Chairman, our new regulation
alludes to this.  Unfortunately, I think, as you are probably
well aware, we have no control over licensing haulers.  That
is another agency.  We endeavor to control it to the extent
that we issue the generator, as we call it, a trip ticket.
It is divided into three parts, quite similar to the  Califorr
trip-ticketing system.
               The hauler, the trucker, or transporter, or
whatever you want to identify him by, receives two of these
                            637

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three, after having signed the first one.  When he delivers
that amount of waste to its disposal destination, he gets
his receipt signed by the receiver, who in turn signs it
and then all three ultimately end up back to the generator,
who in turn sends us a report.
            In this manner, we hope to be able to discourage
the individual who says, I will take it to Site X and finds
a blow hole somewhere and delivers it free and collects for
disposal.  We do not have enough police force throughout the
state to regulate from a practical standpoint things like
this.  The system can be beaten and it will be beaten and
we hope to reduce the number of violators by our trip ticket
control system.
               MR. LEHMAN:  Are there any other questions?
               (No response.)
               MR. LEHMAN:  Apparently not.
               Thank you very much, Mr. Maxon.
               Next I would like to call Dr. William Brown,
Bio-Ecology.
               DR. BROWN:  Mr. Chairman, Gentlemen of the
Panel, and the Assembled Multitude:
               This morning we have heard there is no
industrial waste problem.  We have heard that it is an
insurmountable problem.  We have heard it is an insignificant
problem because something else is going to get us first.
                              838

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               I might add I have got just as many prejudices




as the other guys do and you are going to hear another




story.  In particular, I am going to address my remarks to




the questions that were in the Federal Register and I'm




going to skip through them.  I'm not going to try and answer




all of them because I don't think I know all those answers,




but I do know some of the problems and I will talk about




those.




               First, in the definition, we have heard a




great deal on definitions of hazardous waste.  It is indeed




a difficult problem and I think some of the definitions that




have been proposed by EPA and the National Solid Waste




Management Association definition are workable definitions,




but what is a definition useful for if the people who are




trying to classify waste don't understand what they are




working with?




               We think it has got to be simplified and I




think perhaps the "decision tree" that was proposed in the




Battelle report (Program for the Management of Hazardous




Wastes, July, 1973 - Hazardous Waste - Decision Model




Figure 1)  which basically has a yes-no,  go-no-go, and you




use a series of qualifications for the waste and if it is a




nuclear waste that's a bad one.  That goes off to the side.




You can't handle that one in a hole in the ground.




               You go on down.   Does it have other deleterioi

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effects, and eventually if you get down to the bottom you




end up with something that's fairly innocuous.  Yes, you




can put that in a hole in the ground.




               That gets back to the company that I am with,




which is one of the so-called Class I waste handling sites.




We handle toxic and hazardous waste.  We operate under a




permit by the Water Board, from the Air Board, and by the




Grace of God, by industry sending us a few things once in




a while.  And I address some of those things in more detail.




               Our thesis basically is this.  You have to




take most of these wastes and treat them.  These are the




toxic and hazardous ones.  I think perhaps 90 per cent of




industrial wastes is very innocuous.  It's probably less




hazardous than domestic wastes.  It's boards, boxes,




materials which don't present a real problem, but that other




ten per cent, or maybe it's only five per cent is real whiz




bang stuff and it will eat your arm off if you are not




careful and we take that in every day in our plant.




               I don't think that some of the remarks that




were made here earlier are very realistic.  For example, the




requirement to analyze the samples.  Somebody runs into your




front door with a tank truck full of a waste product.  Now




this material is truly a waste and all of the good has been




squeezed out of it.  It's sludge, it's a gunk, it's a tar,




it has no commercial value.  In fact, it has a negative

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value.  It is something you've got to get rid of and it's




going to cost you to get rid of it.




               All right.  What do you do with it?  You sit




down and say, we should analyze this.  It will probably cost




you on the order of one hundred thousand dollars to get an




ultimate analysis on this one bucket of waste you've got




here.  It's ridiculous to even propose that these things be




analyzed because they defy analysis.




               What is not ridiculous is to have the




originator say where this mess came from, how did he produce




it, and you can work back from that and get a fair idea of




what it's got in it.  It may have a hundred thousand differ-




ent organic materials in it, but if it's not a chlorinated




hydrocarbon or halogenated then you know you've got a good




chance of burning it and that is what, indeed, we do with




most of the waste.  We do not accept halogenated materials




because we are not equipped to process them properly.  We




do accept other organics and we process them mainly by




incineration, although we do recover materials wherever we




can and try to resell them.




               Here is another point which I think is a




fallacy, the recovery, recycle business.  Right now I have




on hand the raw material for approximately 10,000 gallons




of ethanol CDA 19 grade, it's pretty good stuff.  In fact,




we got in trouble with the Treasury Agents because the

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first cycle that came out was potable.  They didn't think




much of that.  They were about to padlock the gate, as a




matter of fact.  All right.  I've got 10,000 gallons of




ethyl alcohol.  What do you bid?  I'll knock off the going




price by 30 per cent to start.  Any takers?  We don't have




any takers.




               What I am going to do is in January if we




haven't found a market for it, we are going to run it in the




incinerator and burn it.  Now what kind of recycling is that?




               I cannot tie up our tanks forever and it's




been in there for three months now with the material for




recycle.  I don't think there exists a recycle market for




small quantities of material and 10,000 gallons is not a




large enough quantity to be commercial.  What is a large




enough quantity to be commercial?




               Only a generator who can recycle the stuff




out of the back of the plant into the front of the plant has




got a large enough market to recycle, or if he's got a




next-door neighbor who can use it.  But I think to take a




disposal site and insist there be recycling is ludicrous.




It won't work.  We have tried it.  We have invested thousands




of dollars in just this batch.  It's a test case.




               I went through all the files and folders with




the Treasury Agents, and if anyone has ever tried to handle




ethyl alcohol you know «what I mean.  It's a tedious task

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and not go to jail to just have a bottle of it, and we almost




went that route.




                (Laughter.)




               It is interesting how the Federal government,




I called them up and asked them what are the procedures for




processing this and would you please give me some information




And they said,  "Yes, we will give you some information."  And




shortly thereafter three Federal Agents burst into my office




literally.  They didn't knock.  They came in.  They walked




right past the secretary and burst into my office, flashed




their badges and said who they were and where is the alcohol.




I told them, I don't have any.  It kind of deflated them a




bit, but we did work with them successfully and devised a




mechanism whereby we could make a CDA 19, which is a




completely denatured alcohol article, as you call it, and if




you drink it, it is kind of rough on you.  So we don't worry




about that one.




               But getting on with the question, we think




a decision tree can be made to where this group comes in and




you can yes-no  it and decide right on down the line how to




handle it.




               We indeed run our business that way.  We have




worked out waste streams with each company and they have




Waste Stream No. 127.  They so identified on the three-part




trip ticket which Mr. Maxon so described.  We have been usinc

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it three years.  The originator keeps a copy of the ticket




to come alonq with the truck.  When it's received at our




plant, we sign it and the signature on that, the signed copy,




is turned back to them.  It gives them a legal release for




liability for that waste.  We have accepted it as ours,




not his.




               Unfortunately, most of the waste doesn't go




that way and in the Dallas area right now my guess is 60 to




70 per cent of the industrial waste disappears.  It does not




go to a legitimate disposal site, either the originator's




own site or a permitted site by the State of Texas or any




other state.




               To give you a little bit of information on




that, we have our annual contracts with the various origina-




tors.  We had a phone  call the other day from out of state




from the National Headquarters of this international firm,




saying it's time to renew our contract.  We said, great,




let's renew the contract, but why?  And the person on the




other end was a little nonplussed by this.  Why do you ask




why?  We haven't seen  any waste from your company for




eighteen months.  Now  what do you want to renew your contract




for?  And they said, Oh! Where could it be going?  We said.




We certainly don't know.  Well, they admit they didn't have




a facility.  They didn't know where it went.




               The local manager, of course, he's got down

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to the bottom of the line.  It's his responsibility.  He




has to maximize his profit and one way to do it is not spend




money on waste and he sure didn't.  Now where it went, we




don't know, but I think he's got a red face trying to explain




where it went.  He may get a promotion, who knows.  Maybe




he's found a cost-saving method for the whole company.




               Most of this stuff does not go to a legitimate




disposal site and the reason it doesn't is because there is




a cheaper solution and the cheaper solution ranges all the




way from a hole in the ground to one place which I can show




you at the intersection of the Trinity River and Valley View




Lane where you drive your truck up to the side of the stream




and let her rip.  There are many such sites in the state.




These unfortunately take  the bulk of the business.




               As I said  earlier, I think it is perhaps 60




per cent in the Dallas area.  It's just going all over the




place.  How do you control this?  You have to control the




waste all the way from the originator to  the disposal site.




If you don't, the hauler  is going to make it disappear




because it is to his economic advantage to do it and  there




is no penalty right now on the originator of the waste,




at least none that I can  find, for giving it to "Cheap




John."  This  is our local jargon that we've developed in




some of our internal discussions.   "Cheap John" is  a  guy




that will make it go away for nothing.  He does it  very

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efficiently and as I said, if he can handle 70 per cent of




the waste in Dallas he is doing a better job than we can




because if all the waste in Dallas came to our plant, we'd




drown.  But we would like a little more than we've got




because we are drowning the other way at the moment because




we are getting less and less of what there is and I know that




the other gentlemen from the waste disposal industry in the




area, I know they are not getting it because we have checked




out to see where it's going.  I don't mean they are not




getting any.  There certainly is waste moving all over the




state legitimately.  I don't mean to say there is not.




               To get an idea how far can you move waste,




how far can you move this stuff without running an economic




penalty?  The R'eport to Congress and some earlier work, plus




the other report on alternatives to national disposal sites,




shows the economics is very favorable for a central disposal




facility which can detoxify waste up to 600 miles.
                               We found them to be very




accurate.




               Our waste comes in from as far west as New




Mexico, as far east as Arkansas and other parts of the




country.  We don't get a great deal at those distances




because there is not a lot of industry out there that knows

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about us or perhaps that needs waste disposal.  But when you




head west from Dallas, the next legitimate disposal site




is in California,  There aren't that many around.




               I don't want to dispute Mr. Maxon's comments,




but there are by our reckoning four toxic hazardoas waste




disposal sites in Texas that process waste, and I'm saying




that they have the capability of doing something other than




putting it in a hole in the ground.  Of those four sites,




two in Houston, one in the Corpus Christi area and one in




the Dallas area, which is our site, but they do not see




anywhere near the amount of material that is generated.




               What is happening, it is disappearing.  It




is going just everywhere.




               Okay.  Let me proceed here and stop preaching




at you.




               Question No. 3, which discusses the means for




handling the wastes, we feel that a specific method for waste




is not an answer.  We rather feel that you should establish




standards for the end products of processing.  It is a




little bit like, let's take the manufacturer of an automobile




If you decide to take some steel and pound it, stamp it,




twist it, beat it and paint it, you don't end up with an




automobile.  You might, but then you might not.




               On the other hand, if you say you want a




vehicle capable of doyig these things, then you get an

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automobile.  So we feel that the standards should be on the




end product.  In other words, having done something to this




waste you end up with this material which is nontoxic, non-




teratogenic, and so on down the line.  Then you've got a




handle on it.  There may be some waste where a specific




process is applicable and this doesn't mean you eliminate




that possibility.




               What I think you have to do is say, O.K.,




Plant A produces a product and we have learned, they have




learned, how to do this and very often the originators know




quite well what can be done with their wastes.  It is




amazing how well they know what can be done with their wastes




               We have labored in our laboratories to




develop methods and we say, Hey, did you know if you did




this, that and the other thing, it turns green and grows




from a tiger to a pussycat?  They say, Yes, we've done that




before.  As a matter of fact, the only way we have developed




any credibility with some of the major corporations is by




essentially duplicating the work that they have already done




in their laboratories on the treatment of their own wastes.




In other words, we have to kind of prove to them we know




what we are doing before they will even talk to us about




handling their wastes, which is a good point.  They don't




want to hand it out to somebody who doesn't know what he is




doing, but it is difficult, and of course, costly, for us to

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duplicate their efforts.  We wish we could get their




believability at an earlier stage.




               But specific waste may need specific pro-




cessing which has already been developed and for that I




have no argument with that concept.




               What practices are particularly effective




for wastes?  One of the things we believe is essential here




is to get the cost of waste treating down.  You've got to




get it down because the economic advantage to the "Cheap




John" is greater when the processing costs are high.




               One thing we think one can do is to use




one waste to detoxify another.  Here again a plant which




serves a large geographical area has an advantage because




we can pull in wastes from a number of different sources




which then can be used to react chemically with each other.




We have done preliminary work and found it successful in




getting a substantially mutual detoxification in heavy metal




and cyanide plating waste by the appropriate blending of




these wastes.




               For instance, you have the choices with




cyanide, for example, to purchase chlorine and try to




oxidize the cyanide with chlorine.  You can take it all the




way if you wanted to, C02 and nitrogen, if you have the




appropriate condition, but you are buying virgin chlorine




and you are creating pollution on the back end with the

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manufacture of chlorine at the alkali plant.  You are




creating further pollution by contributing chloridine to




your effluent.




               Now, if you have a waste, another waste which




you can combine with the cyanide and an oxidizing agent, what




we have done is use promic acid, waste plating acid, to




oxidize the cyanide.  This is a bit of a delicate job




because if you don't do it properly, you generate hydrogen




cyanide gas and then you don't have any problems any more.




               (Laughter.)




               It can be done.  We have done it in the




laboratory.  We have done it in 500 gallon batches, and we




have done it in 10,000 gallon batches.  It does work.  It




does require post treatment, because your reaction does not




go to completion.




               You have to take the effluent from this




process and process it further to get all the heavy metals




out, but it can be done and what we have done here, and the




message is that you can cut the cost down by eliminating the




purchase of new chlorine, new alkali, new sulfur  dioxide




and other materials that are normally used in the standard




process.




               You have to post-treat to clean it up because




the reaction only goes about 90 percent of the way, but still




you have cut 90 percent of the Jiew material out of it, and

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this reduces the volume of the waste and gives you a real




economic advantage.




               I am going to skip down now to one partial




answer to No. 9, "What are the necessary and sufficient




requirements to assure long-term integrity and care of




operating as well as closed hazardous waste storage sites?"




               We feel in this case that this is a very




difficult one because it can vastly increase the cost of




waste disposal and we think that — I've qot a whole list




of things here, I won't go through those as it is too time-




comsuming — but one point is that all the participants in




the field of hazardous waste management, the generator, the




recycler, the processor, the treater, the broker, the hauler




the disposer or any combination, should come under the




same regulatory system.




               We have a number of competitors that — well,




George, you probably know about them — but they are re-




cyclers, they aren't waste disposers.  They take in the




materials for recycling.  We have not been able to find




anything that they recycled, but they sure have disposed of




a lot of stuff.  But they aren't under the regulations at




the moment because they are not in the waste management




business, they are in the recycling business.  So, you can




play the game anyway you want to, but, nevertheless, they




are "Cheap Johns" of another color.



   	             '    851

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               We think if you are going to have an industry,




a viable industry, you have got to have equal application of




the regulations.  Everybody has got to get the same treatment




otherwise "Cheap Johns" flourish, and the legitimate com-




panies disappear.  We know one facility in Texas which was




a very nice facility, one of the better ones that we had,




that is no longer in operation because they could not get




a reasonable return on their investment.  That's the way




it goes.




               I'll go down to question No. 13, "To what




extent are the damages or costs of improper hazardous waste




management evident?"




               The damages and costs of this improper




management are well hidden.  Every taxpayer bears a part of




the cost of the hazardous materials that slip into the




sewer,which is where a lot of  the waste in the Dallas area




goes, but he has no knowledge  nor does  anyone take any pains




to point out what this cost is.  No one tries to calculate




it.  Certainly who knows how much it costs each citizen when




"Cheap John" dumps hazardous wastes in  the streams, roadside




ditches, and pastures?  Who publicizes  the cost of treating




the toxic leachate  from an all-purpose  landfill where the




losses occurred when it contaminated surface  or ground




water ?



                There exists a  great deal of  incentive to

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keep this information quiet.  There is no incentive to




publicize it unless you are trying to oust some incumbent




from office, or unless you are starting an environmentalist




campaign, or perhaps you are trying to determine the most




cost     effective way to handle waste.  Now there is really




no incentive to get the news out.




               Does anybody here know how much it costs the




city of Houston to handle the drinking water that comes




down the Trinity River to remove the toxic elements that




are added all the way up the stream — there is quite a bit




of things put in at Dallas and Forth Worth, and just




anywhere — this stuff comes down here.  Somebody has got




to clean it up.  There is no information on what it costs




to clean the water up once it is polluted.




               I know this, that if you have got a bucket




of clean water and you put a little bit of dirt in it, it




takes a heck of a lot of extra effort to get that little




bit of dirt out to make it clean water again.  The answer




to the problem is keep the dirt out in the first place,




and that is where I think the "treat before you dispose"




philosophy that we are preaching has an impact.




               We believe that you shouldn't dump hazardous




wastes at all, you shouldn't put them in clay, you should




not put them in glass tanks, you should not dispose of them




by storing them.  The proper way to handle hazardous wastes

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is to detoxify them.

               Now, everything on this earth was here with

the exception of the synthetic radioactive materials, but

all the materials have been here all along.  Now, chlorine

didn't come popping up out of a hole in the ground somewhere,

or someone didn't invent it.  It has been here all along.

               We have changed it.  We have increased the

energy level of all of these materials.  The toxic materials

we have now have been created from natural products.  Life

existed with all of these materials, the natural materials,

ever since it began.

               Now, the threat to life is from the unnatural

high energy forms of these materials.  I don't think anyone

will argue that it is possible to take these things, with

the exception of the radioactive materials, you can take

these chemical things and reconvert them back to the equiva-

lant of the natural form.  This can be done without the

tremendous cost, without the tremendous effort on anyone's

part.  It is something that we have to do because I feel

that if we don't, the grim fate that we've heard about is

going to be there awaiting us.  We are going to have all of

our water polluted, all of our air polluted and most of the

soil polluted.

               I guess, in closing, the thesis is treat the

wastes to detoxify them.  It can be done.  It is not
                          05*4

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exorbitantly expensive.  We feel that industry can do this




job better than government can because just like the "Cheap




John " in there trying to carve out his block, well,industry




can do this if we can find out how to get hold of "Cheap




John" and we are working on it.




               We need the help of the regulatory bodies.




We think if the EPA can do one thing, and that is to track




the materials from the originator to the disposal site in




some foolproof system, that a lot of this will be controlled




               The private industry is there.  It is ready.




It is willing.  We have excess capacity in almost all of the




industries that I know of who are working in this area.




They would like more business.  We are being defeated mainly




because of the ability of the waste to disappear which is




in part due to the -low level of enforcement that now exists




in the whole United States.
                            055

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n
          bio-ecology systems inc.
                               Comments
                           Addressed to the
                  Hazardous Waste Management Meeting
                    Environmental Protection Agency
                            Houston,  Texas
                           December 9,  1975
                  Discussion Topics Contained in the
                  Federal Register, Vol. 40, No. 181
                       Dated September  11, 1975
                              Prepared by

                            Dr. W.  E.  Brown
                                  and
                             J. T.  Lurcott
               4100 East Jefferson. Grand Prairie. Texas 75050 (214) 264-4281, 263-3077
                                  856

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                    RESPONSES TO DISCUSSION TOPICS
1.  What is a hazardous waste....?
    We believe the following definition to be properly structured for
effective use in regulation.

    "Hazardous Waste" - means any waste or combination of wastes which
because of its quantity, concentration, or chemical characteristics *
poses a substantial present or potential hazard to human health or the
environment because such wastes are bioconcentrative, flammable, reactive,
toxic, irrating, corrosive or infectious.

          * greater acceptance of this definition might be
            achieved by insertion after "characteristics"
            (at the *) of the phrase - "during handling,
            processing or disposal".

    We further believe thai the aLilisjation of a standard "decision
tree" type format such as that proposed in the Battelle report ("Program
for the Management of Hazardous Wastes, July, 1973 - Hazardous Waste
Decision Model Fig. 1. ) is the best approach to the "what criteria?"
problem.  Although substantial study might be productively employed in
selecting what specific level of test result is "hazardous", a reasonable
starting point would be achieved by pre-assigning a level as a "standard"
and making provisions for other consideration on a generator proven, case
basis.

    Since the waste processing/disposal industry seems to have settled
into from 9 to 23 working categories of hazardous and/or industrial waste,
it seems reasonable to propose a presumed hazard level for each category
of specific generic wastes such as those developed under the 16 industry
studies conducted for the EPA during 1974 and 1975.  A specific waste
(generated by A at location B from process line C) might gain exception
from its generic group classification by specific testing against the
decision tree.

    NOTE:  We propose use of the "generic classifications" of each
industries' wastes suggested by those studies - not the commentaries on
their "hazardousness", many of which we seriously question.
2.  What responsibilities and liabilities....?


    The generators of "hazardous wastes" (and through the pricing mechanism
their customers) should have responsibility for:


                                        857

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    a)  proper identification and classification of hazardous wastes

    b)  environmentally acceptable handling and ultimate disposal and/or
        recovery of all the component parts of the wastes, either by
        themselves or through approved commercial operators

    o)  the cost of assuring the above


3.  For which wastes....?
    Specific methods are not the answer!  Rather, establish "acceptable
standards" for final disposal to the air (emissions), the water (discharges)
and the land (land emplacement).   These standards and their interrelation-
ships will then determine which methods and/or combinations of methods
might be used.  This approach, recognizing, as it does, the chemical nature
of the components of a hazardous waste, offers the maximum opportunity for
the development of cost effective and environmentally adequate technology
by the many generators and commercial operators.

    Translated into the language of manufactured products, we prefer an
"end product" specification rather than a "process" specification.

    We do note, however, that there may be a small percent of the waste
types for which the specific assignment, of a mei/hod may be the best
approach - for the next 2-5 years at any rate.

    The "recovery" of many materials is technically achievable; the
"reuse" or "recycle" is an entirely different matter being dependent on
the relative economics (both capital and operating) of:

    a)  costs of virgin materials (including varying supply factors)

    b)  recovery processing costs

    c)  "adequate" disposal cost alternatives

    d)  the costs of disposal of the residue separated from the waste
        (the separation of which has made a portion of the original waste
        mass "reusable")

    e)  costs of getting the "recovered" waste to a "reuser"

    f)  the prospects of malperformance in use  i.e., might a $500
        savings in material costs or reduction in disposal cost result
        in the scraping of a $10,000 batch of "product"?  If the chance
        is 1 in 1000 - OK - if 1 in 100, it is a poor risk!
                                 858

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4.  What practices,	, are particularly effective....?


    High on the list of "effective practices" is this one - "Use one
waste to treat another".  Beyond the obvious savings on expenditures on
treatment chemicals the following advantages accrue:

    a)  elimination of non-productive use of natural resources

    b)  savings in transport and storage of materials

    c)  reduced volume for processing and final disposal of "processed
        end products" - the cost of a cubic yard of properly engineered,
        lined, leachate collectible, well-monitored, chemical land disposal
        facility is considerable

    In-plant implementation of this combined waste concept has been going
on for years.  It can be greatly expanded by professionally operated
regional waste management facilities, resulting in increased recovery + reuse,
lower total costs, improved resource utilization and increased environmentally
appropriate disposal practices.


5.  To what extent are cost data available....?


    There is considerable cost data in existence, however, it is widely
spread through the many generators and the relatively few commercial
operators.

    A review of the data collected in your July 75 edition of Information
About Hazardous Waste Management Facilities (EPA/530/SW-145) offers a
reasonable look at price structures.  Unfortunately, of the 64 facilities
covered, only about a dozen offer actual "treatment" services across a
fairly broad spectrum  i.e., oils, solvents,  acids - with and without heavy
metals.  Single source, comprehensive cost data is therefore scarce.  Other
factors leading to "cost scatter" are:

    a)  tremendous variance in capital equipment utilized

    b)  the effective regulatory situation, i.e., grandfather clause "blend
        it in" operations vs newly developed, capital and technology inten-
        sive firms whose facility and operating plans were reviewed by the
        regulatory agency for permit requirements before construction began.

    c)  local conditions such as rainfall/evaporation rates and available
        soil conditions

    d)  partial recovery and recycle prospects

    e)  available volumes in the market area
                             853

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    f)  prospects for effective cross blending of mixed wastes

    g)  access to unregulated disposal alternatives

    Although specific costs on specific wastes may vary, there is a definite
hierarchy of costs related to the entire disposal situation (see Fig.  I
attached).  Continually increasing costs are encountered as you move down
the list.  Therefore, volume considerations taken into effect, the first
alternative that is available and "acceptable" will be used.  There is little
motivation to move beyond the point of "accepted" method even though con-
siderable improvements in environmental method may be available there.

    The cost data for hazardous wastes generated by your contractors,
Battelle and Arthur D. Little, is good.  It runs somewhat above current
commercial practice.  This is primarily due to the need to compete
economically (on an adjusted basis) with grandfathered disposal operations
and/or alternative, unregulated disposal methods.  This forces a very
heavy cutback in what may in fact be appropriate and/or necessary costs
at both the capital and operating levels.  The net result of this, in all
likelihood, is disposal by less environmentally acceptable methods,
reduced cash flow, and low profit and growth prospects for the capital and
technology intensive sector of the industry; and high profit potentials
for grandfathered and unregulated disposal alternatives.


6.  What are the minimal safety and security precautions....?


    No statement at this time.


7.  What provisions for monitoring, record keeping and reporting are
    necessary?


    We strongly recommend the use of a standard manifest, or shipping
control document that carries the following information:

    a)  nature and description of the waste

    b)  quantity of the waste

    c)  generators (shippers) name and address with responsible individual

    d)  carriers name and address

    e)  designated processing/disposal site to which it is being shipped

    The document itself should follow the entire movement, receipt of the
waste at the disposal site must be noted on it and then a copy is returned
to .the generator to show arrival at the proper destination.  The generator,
carrier and processing/disposal site should all be responsible for main-
taining their copies.  We see this as the only practical mechanism likely
                                  860

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to offer assurance, if the system is monitored, that hazardous wastes get
to where they are supposed to go instead of disappearing.


8.  What has been the availability and price of insurance — to reduce the
    risks of operation....?

    There is a strong possibility that extreme requirements appearing in
some proposed legislation and regulations may drive the price of this type
protection out of the range of use.   Obviously, financial coverage and
responsibility need to be established but extremes should be avoided.
These hazardous materials have been with us for some time.  The potential
benefits of bringing them together for proper processing and controlled
disposal may be lost if emotionally generated, artifically high levels
of protection are required.
9.  What are necessary and sufficient requirements to assure the  long-term
    integrity and care of operating as well as closed hazardous waste
    storage disposal sites?


    We consider the following 6 points to be required:

    a)  interaction of site, facilities,  processes,  personnel and the
        hazardous and other material types to be handled should be
        subject to review and approved by regulatory authority

    b)  proof of adequate financial strength may be  required to assure
        appropriate construction and operating capital  to initiate
        operation of a proposed facility

    c)  adequacy of technical competence  in hazardous wastes management
        and business experience should be required to avoid  problems that
        could potentially revert to the public if inappropriately handled

    d)  adequate financial reserves and/or bonds may be required  to assure
        processing of all stored materials  i.e.,  those that have not been
        processed to be in compliance with final disposal standards, and
        provide for continuing care or re-development of final disposal
        landfill sites

    e)  licensing of both facility and the operators should  be required

    f)  all participants in the field of  Hazardous Waste Management, the
        waste generator, re-cycler, processor,  treater,  broker, hauler,
        disposer or any combination thereof,  should  come under the same
        regulatory system
                                    861

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10.  What are feasible methodologies, if any, to set limits....?


     Site location, size and characteristics as well as planned processing
and storage capacity are obviously factors here.

     Major attention should be given to the chemical^ condition of the matter
when it is emplaced in the land, not as it was wheh~~initially designated a
hazardous waste.  In most instances, treatment can be utilized that results
in a non-hazardous solid that is environmentally acceptable for land emplace-
ment.  The cost of this treatment is considerable; when properly handled,
the "processed end products" should not be unnecessarily penalized by being
subject to ultra-costly land emplacement requirements.

     We favor the establishment of "final disposal standards" of a chemical
nature that will serve as an objective in the processing and treatment of
hazardous wastes.  When the material has been de-toxified to these standards,
the solid end products may be land emplaced under conditions far less
restrictive than those appropriate for its original "hazardous state".


11.  To what extent are transportation....regulations....sufficient?


     The major lack in existing transport regulation is that they address
the material being transported as an asset — an iteui of value to the shipper
and the receiver.  Hazardous wastes in transit are a liability.  In many
cases, parties in the process would just as soon see the material simply
"disappear-go away".  When the hauler takes title to the waste, there is no
loss to him and probably again if it "disappears".  Regulations covering
the transport of hazardous wastes definitely require a fresh look.


12.  To what degree should labeling....?


     We have no statement at this time.
13.  To what extent are the damages or costs of improper hazardous waste
     management evident?
     The damages and costs of improper hazardous wastes management are
well hidden.  Every taxpayer bears a part of the cost of the hazardous
materials that "slip" into the sewer, but he does not know it nor does
anyone try to calculate the cost or tell him about it.  Similarly, who
knows how much it costs each citizen when "cheap John" dumps hazardous
wastes in streams, roadside ditches, pastures, etc.  Who publicizes the
cost of treating toxic leachate from an "all purpose" landfill, or the
losses incurred when it contaminates surface or ground water?  There
                                  862

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exists much  incentive to keep these costs and damages hidden, and no incentive
to publicize them  — unless you are trying to oust an incumbent from office,
start an  environmentalists crusade or perhaps determine the most cost effective
approach  to  achieving pollution abatement objectives.


14.  What mechanisms and experiences are effective for soliciting citizen
     acceptance of hazardous waste management facilities?


     Obviously, the name itself gets you off on the wrong foot.  We find,
however,  that it can be productive to introduce the concept of an environ-
mentally  acceptable processing/disposal facility to interested, environmentally
conscious citizens in the terminology of chemical processing and material
management as an alternative to past dumping, discharging and other inadequate
and/or illegal disposal practices.


15.  What Federal  facilities typically generate....?


     The  range is  great, from simple sand, oil and grease from traps for
sewer protection at many administrative and vehicle maintenance locations
to the mixtures of chemicals, fuels, cleaners, solvents and oils or the
corrosive metal finishing and cleaning wastes to be found at military
installations, arsenals, etc.

     We have found of late that some federal facilities are setting an
excellent example  in their hazardous waste management efforts.  This is
quite a turnaround from earlier practice when some facilities where consid-
ered major problems by local and state regulatory authorities.


16.  To what extent should the private sector be involved in the treatment
     and  disposal  of hazardous wastes....?


     To the full extent that they can effectively provide a needed service
to the market and  make a profit at it!  Given the developing standards for
environmentally acceptable disposal of hazardous wastes, it is now and will
become more  so, a  capital and technology intensive field.  The economies of
scale indicate that a few specialists in hazardous waste management can
efficiently serve  hundreds of small to large waste generators on a commercial
basis so  that they can more effectively utilize their resources within their
own industry.

     The  tremendous variety inherent in hazardous wastes calls for a flexi-
bility and creativity that has long been indentified with the private sector.
A very significant start has been made by the private sector as noted in
the report prepared for the EPA by Arthur D. Little, Inc., entitled
"Alternatives to the Management of Hazardous Wastes at National Disposal
Sites".   The past year or two has seen the industry take a more cautious
                                    863

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stance versus the expansion needed.  This was due to several factors:

     a)  regulatory programs falling behind legislative goals

     b)  continual regulatory adjustments, frequently having a heavy
         impact on this new and highly visible industry

     c)  a rash of "quick buck artists" who saw big profits to be obtained
         from offering 2Q% price reductions and then making the material
         "go away".  The methods ranged from digging a hole in good clay,
         putting a fence around it and calling it a Hazardous Waste Disposal
         Site; to "working it in with municipal refuse; to just plain dumping
         and "perenial" storage in obscure locations.

         Note that the generator of the waste may have no knowledge of and
         actually little interest in the fate of his hazardous wastes if
         he is relieved of any liability for it when it leaves his premises.
         This plays into the hands of the "cheap Johns" who make wastes
         "disappear".

     There is an important message here.  When an industry contracts to
have hazardous wastes handled it can have two interests:

     l)  to have the material removed — to make it go away,

     2)  to have the removed material subjected to environmentally
         adequate disposal procedures.

     When the generating industry follows through to assure that both steps
are taken the developing private waste processing industry can prosper and
develop to fully meet the need.  However, we have a serious problem when
only the first interest is pursued, and it often is since small savings can
look very big in competitive and difficult economic times, particularly
when viewed against some rather obscure long term, away from here potential
environmental danger.  This produces a very substantial drain on the revenue
of the capital and technology intensive waste processing industry and makes
it impossible to generate the profits that are essential to sustain the
growth necessary to serve the national market.  Please don't get us wrong —
many generators, large and small, are very diligent in assuring that their
wastes are properly handled.  This makes it all the more difficult when these
people have to receive price increases because others, often their competitors,
are utilizing sub-standard disposal operators.

     Here, again, the hazardous waste industry is different.  Every disposal
operation or process that is accepted openly, or indirectly, by the regulatory
authority is instantly a full fledged competitor to all existing hazardous
waste processing facilities.

     We hope regulatory people at all levels of government will realize this
and act accordingly.
                                  861*

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     In closing, we would like to return again to the aformentioned Arthur D.
Little study — "Alternatives to the Management of Hazardous Wastes".   The
following conclusions were presented:

     a)  "On economic grounds alone, off-site treatment facilities  i.e.,
commercial treatment industry or specialty designed and constructed public
facilities will be preferred by a majority of producers of industrial
hazardous wastes...."

     b)  "This conclusion will be true for all regions of the United States".

     c)  "Existing risk, legal or institutional considerations will not alter
         this basic conclusion".

     d)  On large volumes of dilute aqueous wastes, cost effectiveness may
         be found in on-site pre-treatment, with the pretreated (concentrated)
         but still hazardous waste then being shipped to an off-site processor.

     e)  Further economies of scale are obtainable when all specialty wastes
         (both hazardous and semi-hazardous) are treated at a central processin
         facility.

     We at Bio-Ecology Systems fully support these conclusions.

     The private sector will provide the facilities and services needed if
the governmental bodies sel Lheir iiiinds to creeling mid jual.iilaim.iig a
responsible climate within which the hazardous waste management industry
can work.
                                    8G5

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               MR. LEHMAN:  Thank you, Dr. Brown.

               Are there any questions?

               MR. LINDSEY:  Yes.  You indicated in order

to control the "Cheap Johns", as you are calling them, that

a trip-ticket system would help to do that.  In other

words, I understand Texas is instituting such a system.  Do

you feel that it will be effective in controlling this?

               DR. BROWN:  Only if there is enforcement.

You can have all the .tickets in the world and if nobody is
                     •    ace

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watching, nothing is going to happen.




               It is going to require a match up between the




originator's ticket and the disposal site's ticket to see




that the stuff went from one to the other.  If there is no




followup to make sure that that happens, then the thing will




be so much paper.




               MR. LOZANO:  Will the generator at least not




be able to match up the tickets?  In other words, if we have




a responsibile waste generator who wants to send it to the




proper addressee he at least — we will be able to compare




the tickets, no?




               DR. BROWN:  Yes, he will be able to, but




you remember the responsible generator who has a contract




with us, and we have many responsible generators, and I don't




mean to knock all industry.  What I am saying is there are




many industries who are breaking their back to do it right




and they are suffering an economic penalty because they are




spending more money to have their waste adequately treated




than some of their less civic-minded competitors.  The guy




who is dumping it now is going to dump it with a three-part




ticket if somebody isn't watching.  So, you don't change




the situation very much.




               MR. CROWD:  I have a question from the floor.




Several times you have made reference to a hoie in the




ground.  What is your definition of a "hole in the ground"?

-------
               DR. BROWN:  A "hole in the ground" — we


laugh about this.  A "hole in the ground" is simply a place


where someone has gone out -- it may be a natural depression,


it may be a scraped up thing, or it may just be the flood


plain of the Trinity River -- a hole in the ground is dumpinc


it on the surface of the ground.  Now, whether it is retainec


in that spot or not doesn't make any difference and I'll


tell you why.


               Let's say we have a completely impermeable


soil.  Nothing can ever go through it, never, nothing ever.


Agreed?  Nothing can get out of this.  All right, we are


qoing to dump waste in it.  We have never seen any v/aste,


including fairly clean material that doesn't have an oily


film on top of it.  Now, put this out here and you are going


to dump chromic acid, cyanide, and it has an oily film on


top of it.  The rate of rainfall in this area, where we are


at least, is a little over 30 inches a year.  If the


evaporation rate is anything less than 30 inches a year,


as it rains nothing is going out the bottom.  Remember, as


it rains it slowly comes up.  Let's give it a very


magnanimous 90 inches of free board.  Three years of normal


rainfall it is flowing over the top and down the Trinity


River and the people of Houston now have some additional


trace minerals in the ground.


               MR. LEHMAN *  -Mr. Kovalick.
                              ;•-. pn

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               MR. KOVALICK:  I noticed in your prepared
statement — although you didn't have time to comment about
it and since you do have a statement, I would like to
elaborate on it.
               You mentioned that Federal facilities are
indeed generators along with industry of industrial-type
waste.  Could you elaborate a little bit on the general
kinds of waste that you receive from Federal facilities and,
if possible, some volume kind of scope?
               DR. BROWN:  We receive very little waste
from ?ederal facilities.  We do receive it from subcontrac-
tors.  We have just finished a job of, oh, I guess 5,000
drums of miscellaneous waste.  A great deal of it was
solvents and oils.  Some of it was cleaning chemicals and
cleaning compounds which was from an air base which was
being phased out.  That is the type of waste we have gotten.
It ranges all the way from toxic and cyanide to plating
materials to as innocuous things as used lubricating oil.
               MR. LEHMAN:  Mr. Mausshardt.
               MR. MAUSSHARDT:  Dr. Brown, I have a question
from the floor.
               How do you suggest getting your originator to
state the content of his particular waste?
               Secondly, what regulations would be required?
Which agency should be involved — state, Federal, regional?
                             bCS

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               DR. BROWN:  We have no trouble getting the




originators to tell us what is in the waste even in cases




where the waste had proprietary materials.  We sign a




confidentiality agreement with them and we identify it as




"Waste Stream No. X."




               If someone wants to come in, as the Water




Board has the right to do, and examine our records and




see what waste we have received, they will see that here we




have got 5,000 gallons from Waste Stream No. X, from such




and such a company.  Now, if the Water Board says, "What is




X?"  We will say, "It is a proprietary material.  You go




to company X and they will tell you what it is, but we aren't




going to tell you."




               Now, we have to know what it is because we




can't handle it if we don't.  They give us very, very com-




plete information on what it is and it is surprising again,




and I want to re-emphasize this, that industry knows what is




in its waste.




               MR. LEHMAN:  Mr. Lindsey.




               MR. LINDSEY:  Your example of the ethylnol




situation you ran into was quite interesting.  Since the




price was apparently right and since the government




apparently blessed the quality of this stuff, at least they




didn't appropriate it in any way.




               DR. BROWN: . flo, we are clear.  It is legal.

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               MR. LINDSEY:  What then,as you see it, are the




impediments in selling the material?  Why did you have




problems selling it?




               DR. BROWN:  Well, I knocked on every door in




town, I guess maybe I have got BO or something, but —




               MR. LINDSEY:  You don't understand why?




               DR. BROWN:  The answer is: if we could promise




10,000 gallons per month from here until the end of the




world, we could attract some customers, but when you come up




with one batch of material and you want to sell 10,000




gallons of I don't care what it is in one batch, nobody




wants it.




               MR. LINDSEY:  So, it would have to be a con-




tinuing type of product that you would manufacture before




you know what the deal would be.




               DR. BROWN:  That appears to be my conclusion.




If you aren't a manufacturer of it, the market doesn't exist




in this area for small quantities.  Now, I checked with some




people up in the northeast, New Jersey area, and they said if




it were there, they could find a home for it at a reasonable




price, but in our area we don't have any consumers who use




that material.




               MR. KOVALICK:  Again, another question.




               Part of your statement related to the questior




of insurance and I was JHSrt interested in if you could share

-------
 with us some of your experiences as to your ability to get




 insurance and what kind is it?  Is it for property damage or




 other kinds of liability or other kinds of employee liability




 and if it has been available,  has it been extremely expensive




 or reasonably priced?




                DR. BROWN:  Insurance is available and,




 actually, I think in our situation we probably don't have




 any more risks than the manufacturer does and perhaps less




 risk in that we are getting the dregs.  Most of the stuff we




 get has been, the volatiles have largely been removed from a




 fire viewpoint, so our insurance costs, while they are high,




 are not abnormally high.  It is available for a price.  You




 can get the insurance.




                I don't think that we have been turned down




 on the insurance in any matter.  We do pay a higher premium,




 of course, than you do pay on your home because we have a




 greater exposure.  I think the insurance is available; the




 cost is high, but not unreasonable.




                MR. LEHMAN:  Mr. Lindsey.




                MR. LINDSEY:  I have one here from the




 audience.




                How can chlorinated and halogenated hydro-




 carbons be treated or detoxified economically?




                DR. BROWN:  I wish I knew.  I think the




 gentleman who earlier commented on this really had the




	   S72	

-------
answer and that is you have to decompose them.




               Here again, I might say while we do not proces




halogenated materials, we accept them and we only get small




quantities.  We accept them for trans-shipment to facilities




who can process them, but we get them from time to time and




I am sure that we have gotten small amounts of chlorinated




hydrocarbons along with the combustibles that we burn.  We




try to check, but it is impossible to find these materials so




I am sure that we are burning some, but the amount is so




small that we haven't been able to find it.




               MR. KOVALICK:  You made reference in your




statement to either drowning in waste or not drowning in




waste, and I was interested in perhaps a projection on your




part as to what the fate of the private hazardous waste




industry will be, perhaps not in Texas, but other parts of




the country if the "Cheap Johns" continue to be available.




               DR. BROWN:  Would you run through the question




again, I am not sure I understood it?




               MR. KOVALICK:  I was interested in just a




general comment about your industry, not necessarily in Texas




as to what you think the state of the hazardous waste treat-




ment industry will be in the future as long as the "Cheap




John" solution continues to be available.




               DR. BROWN:  I think there will not be a waste




treating industry if the "Cheap John" continues /naking inroad

-------
In our area, "Cheap John" is getting more and more of the

business rather than less and less.  The only way that the

industry can survive is to contract with larger and larger

companies that have such public visibility that they cannot

afford to use "Cheap John".

               What happens to the bulk of the waste that

comes in from the small companies and that is one of the

reasons that our company was set up in the Dallas area

because there are over 1,000 small industries that generate

toxic and hazardous waste.  They do not have in-house

technical capability to treat their own waste.  In the main,

they really don't understand what they have.

               Our facilities function then would be to

accept their residues, plating materials and such.  And with

the group that we have in technical confidence — we have a

chemical engineer, two chemists and a mechanical engineer on

our staff — we can process their waste.  Now, we often have

to go back to the supplier, to these companies, to find out

what is in their waste, but the suppliers will tell you.  If

you ask them, "What is in your proprietary ripening compound

used in Plating Vat No. 693?", they will tell you.  It is

not that big a problem.

               So we try to provide that service for the

little guys, but the little guys are the ones that have got

the real competition.  The noose is around his neck.  If the
                                 8 ik

-------
guy two doors down isn't paying to have his waste hauled

away, then this guy can't either.  So, he has to disappear

the same way.

               MR. LEHMAN:  Mr. Lindsey.

               MR. LINDSEY:  One last question.

               You indicated you don't knowingly receive

chlorinated hydrocarbons for treatment at your own facility.

Technically, why is it that you can't incinerate these types

of materials in your facility?

               DR. BROWN:  We do not have a scrubber on our

incinerator that would handle that.  You have to scrub it

and I think one of the points that came out this morning and

perhaps it might help to just say about two seconds worth on

that.

               When you run a scrubber, you generate a

high volume of fluid and then to treat that fluid you have

to add another high volume of materials to neutralize it, to

precipitate it, and then you end up with more tons of waste

than you started with.  Admittedly, the stuff you end up witf

is comparatively innocuous, but you have a temendous pile

of waste.

               We, in our operation, can't afford to run a

scrubber, so we exclude those wastes.  Now, there is here in

the Houston area an environmental service that has a scrubber
                                                            II
incinerator which can handle chlorinated hydrocarbons and

                             8T5

-------
they can go there and that is taken care of, hut we cannot




afford for the small volume of chlorinated material there is




in our area to even contemplate a scrubber.




               MR. LEHMAN:  Thank you, Dr. Brown.




               Are there any other questions?




               Apparently not.  Thank you, very much.




               Ladies and gentlemen, we are running a little




bit behind schedule.  I would like at this time to recess




for a lunchbreak and reconvene immediately at 1:25.




               Thank you, very much.




               (Whereupon, at 12:25 p.m., the hearing was




recessed until 1:25 p.m. of the same day.)
                                 3Y6

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                        AFTERNOON SESSION

                                                (1:25 p.m.)

               MR. LEHMAN:  Ladies and gentlemen,  I would

like to call the meeting to order, please.

               For your information, we have seven more

speakers scheduled for this afternoon.  So, since that is

a fairly large number, we will try to stick right on schedule.

               I would like at this time to call the repre

sentative of the National Barrel and Drum Association.  I

am sorry I do not have your name.  Is there a representative

of the National Barrel and Drum Association here?

               (No response.)

               MR. LEHMAN:  Perhaps he is not back yet.  We

will come back to that.
               I would like next to call Dr. James Robertson,
the University of Oklahoma.

               Dr. Robertson.
               A VOICE:  He is here but not in the room.

               MR. LEHMAN:  Not in the room.  Okay, we will

have to come back to him.

               I would like to call on Mr. John R. Montgomery,

 Malone     Company, Texas City, Texas.

               Mr. Montgomery of the Malone Company, is he

in the audience?

               (No response*.)-
                                bV7

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               MR.  LEHMAN:   We will come back to him.

               I would like to call on Mr.  James Dement of

the Soil Conservation Service, Forth Worth, Texas.

               MR.  JAMES DEMENT:   Mr. Chairman,  I notice the

crowd has diminshed some from this morning.  I think though

if you and the panel would have taken time to find some of

the good eating places here in Houston that you might have

delayed a bit yourself.  I suspect these people will show

up after they enjoy a good meal.

               I am James A. Dement, soil scientist with the

U.S. Soil Conservation Service at the South Technical Service

Center in Forth Worth, Texas.

               I have been asked by our Washington office to

make the following statement and, Mr. Chairman, if there are

questions, I will try to answer them or respond to them

later.

               This is a statement on hazardous waste

management.

               For disposal of many  kinds of hazardous wastes

the  safest method is  land  disposal.  The capacity of the soi:

to  safely absorb and  hold  such materials is  influenced by its

chemical and physical properties,  including  its  cation ex-

change  capacity, the  percent  base  saturation, the soil re-

action,  the organic matter content,  the  soil permeability,

and the soil  depth.    - *
                           8YO

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               These properties are identified by soil




surveys prepared by the U.F. Soil Conservation Service.  Such




soil surveys are completed for nearly 60 percent of the land




in the United States.




               For disposal of specific hazardous wastes,




soil chemists and soil physicists of the SCS, using data




from these soil surveys, can determine the limiting soil




properties and make useful evaluations of the potential of




soils at a specific site to safely dispose of the wastes.




               Thank you, Mr. Chairman.




               MR. LEHMAN:  Thank you, Mr. Dement.




               Do we have questions?




               Mr. Kovalick.




               MR. KOVALICK:  I have several clarifying




questions.




               First, to what depth are the soil surveys that




are complete in the United States?  Are they available?




               MR. DEMENT:  Yes.




               When you say depth, do you mean to what




extent do we examine?




               MR. KOVALICK:  Yes.




               MR. DEMENT:  Normally, two meters.  That is




about 80 inches.  We do have soil survey investigation people




who are geologists and geomorphologists who upon specific




requests at a particular site can examine to any depth



                              373

-------
necessary.
               I might add that the upper two meters of the
soil are the part in which many chemical and biological
reactions take place and we do not infer that we get into
the business of a geologist insofar as rock stratigraphy,
ground water supplies and things like that go.  We do consult
with these people but our examination primarily is in the
upper two meters of the soil.
               MR. KOVALICK:  For the 60 percent of the land
in the United States that has been surveyed, first of all:
is that data readily available to the average inquirer?
               Secondly, does that data cover largely urban
or rural areas, or both, to the same extent?
               MR. DEMENT:  All of these data are available
to the public in the form of published soil surveys and
these published soil surveys can be obtained locally from the
local Soil Conservation Service representatives.
               I'm sorry, what was the second part of your
question?
               MR. KOVALICK:  Just a clarification as to
whether the surveys that are complete cover largely urban
or largely rural areas, or both?
               MR. DEMENT:  Both.  The initial  input from
soil surveys was primarily  for agriculture purposes, but
within the last 10 to  15 years when we began  to see problems
                               o&c

-------
of the nature that we are discussing today, we began to con-
centrate more and more on urban areas.  Consequently, I
would say that perhaps equally well represented in rural and
urban areas.
               MR. LEHMAN:  Mr. Mausshardt.
               MR. MAUSSHARDT:  One question on the statement
you made here which does concern me.
               As you indicate, there are many kinds of
hazardous wastes that can be safely land disposed.  Would
you care to enumerate on what kind of hazardous wastes and
types of studies or information you have?
               MR. DEMENT:  I think that was kicked around a
little this morning and we saw that there are some questions
even as to the definition of "hazardous wastes".
               In broad terms, we are thinking of wastes
that are biodegradeable.  We are thinking of wastes that can
be absorbed by the soil itself through its exchange capacity
and retained there.  We are thinking of wastes that can be
retained in place in certain kinds of soils, without becominc
toxic in place.
               But I can't answer your question in its
entirety.
               MR. LEHMAN:  Mr. Lindsey.
               MR. LINDSEY:  Doctor, we know of some labora-
tory and field work being done to determine the cation
                            b61

-------
 exchange capacity  of various  soils  for various  wastes.   As




 a matter of fact,  the EPA labs  are  doing some of it.   Do you




 have some additional experimental data which relates  to catio




 exchange capacity  and these other things you have listed




 here on which you  base these?




                MR.  DEMENT:  Yes.  We have three basic sources




 of information in  determining the things I have listed.




                First, we have a national soil survey  labora-




 tory located in Lincoln, Nebraska.   These people are  equipped




 to do all of the kinds of things  I  have listed  here,  these




 determinations.




                Second, we work  very closely  with the  state




 universities and their research people and we are pretty




 much up on the data that they have  collected.




                Thirdly, we work closely with the Agriculture




 Research Service,which is a service dedicated to research,




 and they have specific sections for research in hazardous




 materials, or the  kinds of things we are discussing today.




                MR.  LINDSEY:  Has  this information been




 codified into some sort of a  document which  could be  made




 available which shows tenure  or capacity of  various soils




 for things of that nature.   If  it is, we would  certainly




 like to be able to obtain it.




                MR.  DEMENT:  With  your permission, I'd like  tc




 pursue this further.  If you  would  care for  a response, I



	    582	

-------
 can tell you off the cuff that I know of no specific place




 where all of it has been gathered into one bundle.   I tried




 to find that the other day.   I am on a waste disposal com-




 mittee with our service and  we do not have a complete




 bibliography on this subject that I am aware of.   I am still




 pursuing this.   Now, if I can find anything, I can let you




 know.




                MR.  LINDSEY:   We would appreciate that.




                MR.  LEHMAN:  Mr. Lazar




                MR.  Lazar :  Mr. Dement, would you agree




 though that the problem that arises when one land disposes




 potentially hazardous wastes is not just related to the soil




 but it is sort of a specific.  What is the underlying graphi




 formation under the soil?  So, even if we know in 60 percent




 of the country the soil is composed of certain types of




 constituents, we would still have to know at that specific




 site    what is the underlying rock formation.




                MR.  DEMENT:  We agree specifically on that,




 and when we are called upon  for a specific site study, if




 our local soils men can't determine this information, then




 they go either to our soil survey investigation people who




 are qualified to make these  studies, or they obtain local




 help through universities and the scientists that they




 have who are capable.




                I might a^ld - that our soil scientists are



	    863             	

-------
cautioned not to make statements that they can't back up.




We don't want to mislead the public.




               MR. LEHMAN:  Mr. Kovalick.




               MR. KOVALICK:  Mr. Dement, in listening to a




couple of other statements this morning there have been




several individuals who have said that in their view the




breakdown of hazardous wastes whether it is by thermal




breakdown or by chemical treatment to form basically non-




toxic or residuals was far preferable and I would presume by




that environmentally more sound than land disposal.




               Would you care to comment on that point of




view vis-a-vis your statement — is that




the safest method for disposable hazardous waste many times




is land disposal.




               M.R. DEMENT:  Yes, I listened to those discus-




sions and they are well taken.  The safer the material is




when it is initially deposited, of course, the less problems




that we are going to have in any sense.




               There are some wastes, however, that j.ust by




their sheer volume, as was discussed earlier this morning,




don't lend themselves to prior treatment.  And there are some




that never get into a system where they can receive prior




treatment.




               I'm thinking in this case perhaps in rural




and even some suburban areas of septic tank disposal.  Many

-------
states have very strong regulations on septic tank effluent

disposal and as far as I know there is no economical means
in these rural areas or in some cases suburban areas to
dispose of it other than by direct disposal in the soil.
               Here we, as I stated in the last paragraph:
make an evaluation to tell the builders and the local and
regional planners which soils lend themselves to this kind
of disposal better than others.
               MR. LEHMAN:  Thank you.
               Are there any other questions?
               Mr. Lazar:,
               MR. Lazar:  Mr . Dement, even though the soil
has a certain amount of attenuative capacity, we at the EPA
are aware of numerous incidents of damage that have been
caused by land disposal where actually the soil didn't
attenuate all of the toxic hazardous wastes.  Are you aware
of such incidents?
               MR. DEMENT:  Yes.  I think it is pretty
common knowledge that you can oversaturate a soil.  The only
area in which we might contribute in that case is to tell
you that this soil has the ability to accept more waste of
certain natures than another soil in the same local area, so
that planners might select one soil over the others.
               Now, if they are overloading it to the extent
that none of the soils can accept this, then they have got
                       Go 5

-------
to look for other programs as I see it.




               MR. Lazar:    One more question.




               Then we do have a disposal site.  To me, it




seems that the likelihood of overloading is quite appreciable




because that is a place where for years probably industrial




wastes will be deposited in large amounts.  So, wouldn't you




say that the question of overloading is quite acute in many




instances?




               MR. DEMENT:  Yes, I think when you concentrate




hazardous substances in this specific area that you have got




to realize that there comes a time when you have got to




abandon that site.









               MR. Lazar:•  But how can you determine when




to abandon a site?  By continuous monitoring?




               MR. DEMENT:  We aren't in the monitoring




business.  I understand that the Texas Water Quality Board




does some monitoring.  I think it might not be a bad idea




where a site receives hazardous material of this nature, if




they did have some monitoring.  I think that would be good.




               Specifically in answer to your question, no,




I don't think we  can tell how you can put so many tons on




this.




               MR. LEHMAN:  Are there any other questions?




               Apparently aat.

-------
               Thank you very much, Mr.  Dement.
               I would like to next call Dr.  James Robertson
of the University of Oklahoma.
               While Dr. Robertson is coming up, let me
remind any of you who are just arrivinq for the afternoon
session that if you wish to direct questions  to  the speakers,
merely hold up your hand and one of our staff will provide
you with a three-by-five card on which you can write your
question and it will  be delivered to the panel.
               Dr. Robertson, please.
               DR. JAMES M. ROBERTSON:  Well, I am a native
Texan, although I have been sort of misplaced, I guess you
might say.  But anyway, it is good to be back.
               I wanted to speak a little bit on the subject
of environmental monitoring requirements for hazardous
waste sites today.
               The present legislative climate is inducing
generators of hazardous wastes to dispose of them on land
with little or no environmental controls.  Without adequate
controls or enforcement of further controls or restrictions,
the deposition of certain hazardous wastes on land could
present potential threats to  operators or the pollution of
groundwater and the  surrounding land  areas.  Given the
apparent lack of  identification or selection criteria of
hazardous wastes  and yig permissive nature of the disposal
                          bC7

-------
 methods,  there is an obvious  lack of adequate control,




 management guidelines,  and information available to estimate




 the potential hazards generated by operation of a hazardous




 waste disposal site.




                A hazardous waste management program should




 result in the creation of a system with certain character-




 istics:  adequate treatment and disposal capacity statewide,




 lowest cost to society consistent with public health and




 environmental protection, equitable and efficient distributee




 of costs to those responsible for waste generation and con-




 servation of natural resources achieved by recovery and re-




 cycling of wastes.




                Some of the basic objectives and criteria




 include the following:




                The basic objectives of environmental anaylses




 are the protection of the environs from the buildup of




 significant quantities of hazardous materials and the col-




 lection of adequate data to substantiate just claims and to




 repudiate unjust claims should they arise concerning the




 sources of contamination.  In general, environmental analyses




 are performed to:  protect people in the environs from




 exposure to hazardous materials in excess of guidelines




 or fractions  thereof; to protect property from  contamination




 in excess of  guidelines or fractions thereof; to ensure




 adherence to  local,  state, andF aderal  regulations; to



	888	

-------
 foster good public relations  and to express  a responsible




 social attitude by informing  the public and  establishing




 effective control measures.



                Therefore,  the environmental  analyses can aid




 in:



                (a)   Establishing background  levels of




 chemicals and fluctuations due to man's activities.




                (b)   Confirming efficient operational controls




 for  containing hazardous materials.



                (c)   Determining the rate of  buildup before




 hazardous levels are reached.



                (d)   Determining the levels of contaminations




 following an accidental release.



                And finally,  (e)   Collecting  specific data




 that may be useful in litigation.



                When environmental analyses are to be per-



 formed for regulatory legal,  social, or technical reasons,



 criteria should be established to ensure effective analyses



 and  evaluation of data.  In general, criteria should be



 developed in the following areas:



                1.  Collection of samples.




                     (a) Type of samples (soil, vegetation,




 milk, water, air, et cetera).



                     (b) Method of collection (spot sample




 or continuous, representative or proportional samples).



	  889	

-------
                    (c)  Frequency of collection (daily,




weekly, monthly).




                    (d)  Collection specifications (location,




number, size, et cetera).




                    (e) Packaging   specification (identifi-




cation, labeling, type of container).




               2.  Method of analysis and detection.




               First of all, we would have the method of




analysis involved whether it be sophisticated or non-sophis-




ticated.




               Materials to be analyzed.  What types of




materials we are looking at.




                    Sensitivity and reproducibility.




                    Calibrations and controls.




                    Required correction  factors.




               3.  Evaluation of analytical results.




                    (a)  Comparison of results with




regulations that are existing.




                    (b)  Comparison of background levels.




                    (c)  Examination of  possible trends.




               Three types of environmental surveys of a




specific disposal site should be made:




                (1)  A  preoperational environmental survey,




                (2)  An operational environmental survey,  and




                (3)  A  post accident environmental survey.

-------
                Preoperational  surveys,  made  before  the




 facility is in operation,  determine the background  concen-




 tration quality of the  environs.   Operational  surveys




 determine any buildup of contaminants.   Post accident en-




 vironmental analyses, performed rapidly following an incident




 establish the location  and levels of contamination.




                Under preoperational surveys, the value  of




 preoperational surveys  and the extent to which they should bt




 conducted has been open to considerable discussion.   In




 general, however,  analysis of environmental  samples prior




 to operation of a  facility are a prudent investment.




                The extent to which a preoperational survey




 is conducted will  depend upon the nature and the magnitude




 of the operation.   This program should (1)  identify the




 probably critical  exposure pathways, (2)  the critical




 population groups, (3)  select the same media,  and sample




 site locations, (4) collect and analyze the  environmental




 samples, and  (5) interpret the data.




                Minimum sampling would include ground and




 surface water, air, soil and vegetation samples.  These




 samples can be used to substantiate or repudiate a  claim




 that hazardous waste disposal operations caused contaminatio




 in the environs.




                Under operational surveys, as with preopera-




 tional surveys, the magnitude or extent of the operational




	    BS1

-------
 survey activities depends on the type of operations and the
 character of the surrounding area.  The survey results
 should indicate the degree to which protection from con-
 tamination is achieved, and the extent to which additional
 control and sampling are needed.
                Under post accident surveys, post accident
 surveys should be made rapidly to reduce the consequences
 of an incident.  This could be involved with both disposal
 and transport of hazardous wastes.  Collection and analyses
 of air, water, vegetation, soil and aquatic life samples
 should be made as rapidly as possible.
                Classification of environmental samplings.
                Environmental sampling would involve
 essentially three areas: air, ground and water sampling.  The
 selection of sampling equipment, sampling sites and technique
 used for collecting and analyzing environmental samples are
 important considerations.  The choice of sampling equipment
 and method of analysis are dependent on the chemical com-
 position and quantity of material released in the environment
 In some cases, it is possible to run a fairly simple test. In
 other cases, it would require a more exotic testing.
                Air sampling.  Air sampling is a primary
 means of environmental sampling.  Particulate samples are
 normally collected on a filter medium with an air pump and
 flow-measuring device.  Gaseous  sampling will most often be
	-GS2	

-------
  very specific for a particular contaminant.   There  are,




  however,  various  detection systems  that can  indicate  total




  organic contaminants.



                 Under ground samplings,  ground sampling may  b




  considered in its broadest aspect to cover soil,  vegetation,



  and animals.   Soil is an excellent sampling medium retaining




 contaminants for long periods of time.  Soil analyses  are



  somewhat complicated because soil is a difficult matrix  from




  which to extract many materials.



                 Soil samples should be collected in areas




  where  (1) the vegetation cover is good, if applicable,



  (2) the land is level with a relatively small possibility of.




  water runoff from a higher level,  (3) the soil is highly



  populated by worms, which affect the vertical distribution




  of activity,  (4) the soil is not packed when dry, and (5)




  the soil sample is free of roots and flora.



                 For many purposes,  samples of soil collected




  to a depth of one-half to one  inch are satisfactory.



  Sampling programs have  shown that multiple borings to




  a depth  of six inches over areas one to two  feet square




  are representative.



                 Vegetation  samples  usually consist of  the




  leafy  or above-ground portions of  vegetation.  The leafy




  portions generally reflect the quantity of material  falling




  directly from the  atmosphere.   The quantity  of contaminant



	    8S3	

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reaching the leaves through the soil and the roots of the




plant is indicative of the long-term buildup of materials in




vegetation.  Of course, it could occur if a site were operatin




for an extended period of time.  The leafy portions of vege-




tation samples are analyzed to provide an index of the con-




tamination recently deposited in the environs.




               The selection of an adequate number of properly




located sampling sites is of great importance in obtaining




meaningful data.  Ideally regular sampling at carefully




selected locations should ensure that all phases of the




program are running smoothly before operations begin.




               In planning the survey, prepare a map of the




area in which the site is situated.  Geological survey maps,




when available show such physical features as bodies of water,




land contours, roads, and swellings that are especially




important in selecting off-site sampling stations.  The map




should contain such significant features as disposal site,




out-buildings, stacks, if an incineration facility is used,




neighboring plants, farmlands, and dwellings.  A detailed




map is necessary to show points immediately surrounding the




site.




               The usual mapping procedure is to place the




plant or other principal source of discharge or in this case,




the disposal site in the center of a series of concentric




circles spaced at varying distances.  These circles may be

-------
further subdivided by radii to form sectors that may be coded




for convenience.




               Under water-system sampling, which is probably




one of the more important components, water-system sampling




includes collecting water, fish, sediments, algae, plankton




and aquatic vegetation.  Of these samples, only water pro-




vides truly quantitative data.




               For simplification and classification, water




sampling may be divided into four general categories:  pre-




cipitation, surface, ground and plant-process and waste-




water.




               Precipitation samples.  Of all the types of




water samples, precipitation samples are the most flexible




with regard to location.  Such samples are usually taken in




close proximity to regular air-sampling stations, whose




locations have been determined by a study of predicted or




demonstrated emissions under various conditions of wind




speed and direction.  Data on the prevailing winds at




different seasons of the year should be studied, and samples




should be located to reflect the difference in concentration




of air currents approaching and leaving the plant.




               Again, speaking about the hazardous waste




disposal system.  If the prevailing wind is southwest, for




example, sampling stations should be located both to the




southwest and northeast.of the disposal site.  Other stations

-------
might be located in exactly complementary directions, that
is, northwest and southeast, or in slight variations, depend-
ing on the locations of other plants, dwellings, or livestock
grazing areas.
               Surface-water samples.  Sampling locations for
other types of water are not so flexible as precipitation
samples, and consideration of additional factors is necessary.
Flowing water should be sampled at least upstream and down-
stream of the site to indicate any differences in concentratic i
due to the possible release of materials from the site.  In
addition to samples taken from the surface of the water site,
silt or sediment should be dredged from the bottom, particu-
larly at locations where stream velocity is low to indicate
whether or not the increased concentration of contaminant is
due to deposition by coagulation or  settling.
               Ground water samples.  Ground water samples
are obtained  from monitoring wells,  existing springs or wells
and various seeps.  The monitoring wells should be situated
to reflect possible seepage from holding lagoons or ponds and
final disposal pits.  A hydrologic study should be performed
to determine  potential underground water flows as a guide to
monitoring well  location.   A minimum of  four monitoring wells
one in each quadrant, should be provided.
               For most types of samples,  accurately describe!
and numbered  stations-should be located  at varying distances
                        8S6

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 from  the plant.  The maximum distance will be determined by




 the amounts of materials handled or  likely to be  released,




 the meteorological  and hydrological  conditions  in the plant




 environs,  and the proximity of  population centers.  Periodic,




 random  samples at locations other than  regular  stations will




 add credibility  to  regular data.  Occasional samples can be




 taken at a great enough distance from the plant to serve as




 controls for the program.  In many cases, data  obtained from




 sampling programs conducted by  Federal,  state and local




 authorities may  be  substituted.




               Now, under frequency  of  samplings,  a recommend-




 ed minimum level environmental  monitoring program is included




 in this statement.  This table  is a  guide and it  should be




 recognized that  there is no substitute  for good professional




 judgment in the  development of  a specific monitoring at a




 given site.  Environmental conditions around a  site will




 vary  and may necessitate a modification to portions of this




 table according  to  the individual site  characteristics.




 Usually, the number of locations sampled and the  number of




 samples analyzed are considerably reduced after a number of




 years of successful operation if new and more complex




 operations are not  introduced.




               Under the format of an environmental sampling




 program, we have "Sample Type", "Frequency", "No.  of Sites",




 and "Location".  It,has been established that in  certain type|



	GST	

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of hazardous waste disposal sites, there is a danger to air




pollution and air particulates and gases should be sampled




monthly with the sampler to operate from five to seven days




each month in at least two stations.  The two locations are




  -edicted or measured highest off-site ground level concentra-




tions.  Precipitation should be monitored monthly in at least




two sites for the same — in the same sites on a hazardous




waste site as air particulates and gases.




               Surface water should be monitored monthly  if




applicable in at least two sites.  One upstream and one down-




stream after dilution, for example, one mile.




               Ground water should be monitored monthly in at




least four sites in monitoring wells.




               Soil should be monitored semi-annually in




approximately 12 sites, three from each quadrant at various




distances.




               Vegetation should be monitored seasonally in




12 sites, three from each quadrant at various distances.




               In general, from technical and administrative




viewpoints, the frequency of sampling depends on:  (1) the




significance that can be placed on a specific number of




samples,  (2) the magnitude of operations, of course, this




is very important.  It is realized that these numbers of




samples would vary with the size or magnitude of the operatior




being monitored, and ^(3) the possibility of  significant

-------
releases.  For example, as I mentioned earlier, if you do




have a type of holding facility and you do have this layer




of oil on top, it does build up to a significant level and




you get a flood like we occasionally get in Texas, then there




could be a significant release which would mean that you




would need to take some tests immediately of course.




               From an economic standpoint, the frequency nay




be affected by the total cost of sampling and analysis.  We




know that this cost can be considerable and that we do need




more simplified techniques that do not cost as much so that




the cost of sampling can be kept down.




               The final number of environmental samples col-




lected and analyzed will be based on the magnitude of the




potential hazard, particularly in relation to the public and




on the requirements set by various legislative authorities.




               MR. LEHMAN:  Thank you very much, Dr. Robertsoi




               Are there any questions?




               Yes, Mr. Lindsey.




               MR. LINDPEY:  Yes, could you give us some




general indication of what the cost would be for say the




format you have given us here in Table I for that magnitude




of a sampling effort?




               DR. ROBERTSON:  Well, I haven't put that to a




pencil: it would be considerable and as I said before, these




samples, the number of samples would vary.  This table was



                           833

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set up sort of as an ideal thing and, of course, we strive




for these things, but never do reach them, but I don't have a




figure for that right now.




               MR. LEHMAN:  Mr. Kovalick.




               MR. KOVALICK:  You have emphasized the




importance of air pollution sampling at hazardous waste




facilities.




               DR. ROBERTSON:  Right.




               MR. KOVALICK:  You also mentioned an operatione I




sampling would be one of the functions of comparing emissions




against existing regulatory requirements.  Has your experience




in doing this kind of work  led you to any conclusions about




the adequacy of existing ambient air standards to meet the




needs of your sampling requirements?  In other words, are




easy to sample against for the few that there are and are




sufficient to address the kinds of emissions you expect from




hazardous waste?



               DR.  ROBERTSON:  Yes,  there are standards set




for both particulates and organics in air, you know,  in




vapor form.   In  general,  I  think they probably  are.   It may




be that  as we learn more  about the nature of  some of  the




hazardous materials,  that additional criteria may have to be




added.   But,  as  far as  I  know, I think  that from a  general




standpoint  they  are fairly  adequate.




               MR.  LEHMAN:   Mr. Lindsey.




                        SCO

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               MR. LINDSEY:  Under your section dealing with




ground sampling, soil sampling and so forth, you indicate




that soil surveys one-half an inch to an inch, and perhaps as




much as six inches are usually satisfactory.  For preopera-




tional, particularly for preoperational surveys, don't you




see the subsurface environment as being important?




               DR. ROBERTSON:  Yes.  We mentioned the




monitoring wells and, of course, core samples should be taken




along with existing geological data.  This particular type




of soil sampling was to establish the movement of say




pollutants after the site was established, but, of course,




there should be a lot of presite work done which would




include fairly extensive corings.




               MR. LINDSEY:  If you have a recommendation at




a later time you could send to us, we would appreciate that.




               MR. LEHMAN:  Mr. Kovalick.




               MR. KOVALICK:  On your discussion of post-




accident surveys, I was wondering if from your experience




you have any specific incidents where you had experience and




you  have some idea what the costs were, if that is the kind




of sampling program you suggest, do you wish to give us the




flavor for that?




               DR. ROBERTSON:  We have not had that experienc




               MR. LEHMAN:  Mr. Lindsey.




               MR. LINDSEY:  Yes, I have a question here




                        Sbl

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from the audience which is a little confusing.   Let me see




if I can get the gist of it.




               If, after disposing some hazardous material on




a site for say ten years, and then a new site is opened, and




then perhaps at the first site some 10 or 20 years later the




ground water monitoring shows high level pollutants.  What




can be done about that?  Do you have any thoughts on that?




               DR. ROBERTSON:  That sounds like a loaded




question.  Would you mind running it by one more tine?




               MR. LINDKEY:  We have a site that we dispose




of hazardous materials for perhaps ten years and then we move




on.  We close the site.  At some point later, perhaps 20 years




or so later, we find that the ground water monitoring shows a




high level pollutant.  What can be done to ameliorate the




problem -- long-term care I guess it would be.




               DR. ROBERTSON:  That sounds about like closing




the barn door after the horse has gotten out to me.  I don't




know of anything exactly.  Of course, we had the examination




earlier today of the arsenic that had been buried.  This was




a fairly small quantity and you are talking about a reasonably




small figure to clean it up, but if this was a  fairly large




site and you had a fairly large volume and, of  course, you




know, there is a lot of variables.  You know, the distance




going down to the water table, you know, how much  actual




depth is involved, the type of soil and the type of pollutant

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It would be pretty well impossible to say.   Of course, in




some cases you might have metals migrating,  but it is not as




likely.  It most likely would be possibly either salts or




certain types of organics and once these have gotten down




there, other than just maybe trying to prevent further




spreading I don't know of any other solution.




               MR. LEHMAN:  Are there any other questions of




this speaker?




               MR, Lazar:   Just to go back to the previous




question, you said other than preventing further spreading,




what would you do to prevent further spreading?




               DR. ROBERTSON:  Again, this would depend upon




the depth of, you know, the depth between the bottom of the




pit and the water table and I guess in some cases it just




has to be mechanical removal of the material depending on how




far it had gone.  It sounds as if in this particular case




that not enough planning had been done before the site was




actually utilized the first time or otherwise these contami-




nants would not have gotten down to the water table.




               Again, hopefully in the future, we will not




have any problems of this nature.




               MR. LEHMAN:  Dr. Robertson,  one last question




from the audience.




               Is any study being done on treatment of




contaminated ground water in the ground, to your knowledge?

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               DR. ROBERTSON:  Not to my knowledge.  It sounds




like a reasonable idea.  I think this is one area that we do




need to do more work in.  There are a lot of different areas




that do need to be studied, but both treatment — say, after




it has gotten into the ground or either that or if we have




say large holding ponds that  have  been  there  for  a period of time




and the site is about to be closed down and you have got just




a real hodge-podge or very gross mixture of a lot of




different things, organics, acids, metals and so  forth, how




to treat this sort of thing.  I think these are some problems




that need to be addressed.




               MR. LEHMAN:  Okay.




               Thank you very much, Dr. Robertson.




               A VOICE:  May I address one last question?




               MR. LEHMAN:  I'm sorry, if you would like to




address something to the record or comment on what the speaker




said, that's fine.




               Thank you very much. Dr. Robertson.




               At this time, I would like to call Dr. W. A.




Quebedeaux of the Harris County, Texas Pollution  Control




Department.




               Is Dr. Quebedeaux  in the audience?




                (No response.)




               I would like to call at this  time  John R.




Montgomery of the Malone Company, Texas City, Texas.

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               Mr. Montgomery, please.




               MR. JOHN R. MONTGOMERY:  Panel members, ladies




and gentlemen, I didn't make a prepared statement or paper




here today because I didn't know what the nature of the




meeting was to be.  Now that I have seen a wide variety of




speakers and interested parties, et cetera, that have been




here, I think I was right in not doing so.




               I would like to make a couple of things clear




in advance.




               First of all, I will be happy to answer any




questions that I can for anyone, but you aren't talking to




a scientist of any kind.  You aren't talking to a chemist,




a biologist, a geologist or any other sort of scientific




person.  You will be listening basically to a rate man, a




traffic man, a regulatory person who deals with regulatory




agencies.  So, in that capacity I am representing the Malone




Company of Texas City, which is a firm dealing exclusively




in waste transportation, waste treatment and waste disposal




and I guess it is safe to say at the outset that everything




we handle is hazardous, by broad definition.




               Second of all, by word of clarification, my




name is John Montgomery, but if any of our customers are here




in the audience they can probably assure you that I am not




one of the "Cheap Johns" that Dr. Brown referred to.




               (Laughter.)

-------
               We provide a service to the public and we are

happy to do so and we hope to be able to continue to do so,

but it is not an inexpensive service.  We are regulated by

several agencies in the State of Texas and by other Federal

agencies, most notably the Department of Transportation.

               We wear two hats at the Malone Company:  we

have several divisions.  Malone Trucking Company I suppose is

the most profitable.  That is a Railroad Commission of Texas

regulated carrier.  We have one piece of authority and that

is to transport waste chemicals, that is liquid waste, from

all points in the State of Texas to licensed points of dis-

posal within Texas.  The material has to be of no commercial

value.

               Now, in that role we have quite a little bit

of supervision from the Railroad Commission.  All of our way-

bills, or bills of lading, are inspected regularly by the

Railroad Commission.  The commission also fixes the rates  at

which we can haul this material, all charges relating to the

transportation of the material and they also monitor the fina]

destination of the material.  This is good  in one way and

conversely it is bad.  If you are  a  regulated carrier in

Texas, which some people in the room may be, you have a

fairly reasonable return of profit that you can expect.  Now,

in return  for that, the Railroad Commission checks all  of

your papers, all of yottr transportation, all of your  trucks.
                           SOS

-------
               The bad part of that is that if you are not a




regulated carrier with authority, you aren't checked at all.




This goes back to something that I believe Dr. Brown spoke




about this morning, the "Cheap Johns".  We have to comply,




of course, we intend to comply anyway, but we have to comply




or we are out of business.




               There are some other people in our business whc




don't have to comply and don't comply.  This is a problem and




by way of recommendation to the Environmental Protection




Agency, I would recommend that continued or possibly expanded




enforcement of this triple ticket idea, the idea that the




generator of waste will record how much waste he has produced




and where it went and who took it there.  This would help us




and I think it would help the people of this state and any




state.




               Switching to the role of Halone Service Company




another subsidiary, which is our disposal plant, let me




describe the situation basically.  Ve take in waste chemicals




from several different sources, probably I guess 100 different




customers.  These people tend to be smaller plants.  Larger




plants with a large fund of money to deal with can become




involved in tax exempt, bonded, Federally supported waste




disposal programs such as the Gulf Coast Regional Waste




Disposal Authority.




               At Malpne Company we don't have any Federal

-------
 assistance whatsoever.   Any state assistance — we work  with
 the state, but we don't get any money from them.   Now, this
 precludes our going into such things  as  incineration, huge
 expansion of our plants, anything'that requires a lot of money
 Basically what we do is accept waste  of  all different types
 with a few exceptions.   If we can reclaim it,  we will.   If
 we can't, we neutralize the material  and dispose of it in an
 injection well system.
                Now, oils generally speaking can be reclaimed.
 We have oil from several sources.  As a  matter of fact,  we
 have a subsidiary company, Marine Pollution Control, which
 is basically an oil spill contractor, to use a.  euphemism
 there, in the oil recovery business.   They have contracts
 with the Port of Houston Association  which is  called the
 Clean Channel Association, the Texas  City, a similar associati
 in Texas City and the Port of Galveston.  I believe for
 about a year's period there in 1974 and  1975,  they cleaned
 up well over 100 oil spills.
                Now, if the oil is contaminated, or it has been
 on the water too long,  or if it has a lot of grass or sand  or
 other foreign matter in it, we accept that oil at our dis-
 posal plant and we don't dispose of it.   We treat it, we
 clean it, we filter it, in what even  I not being a scientist
 would say, is a fairly simple method.  And then we can  resell
 it or recycle it.  We can, use it as road oil.   Some of  it can
	     SGS	

-------
be reused as fuel.  Some of it can be fed into a process that




can be used as part bunkering fuel for ships, low quality




oil.




               The rest of the material is, generally speak-




ing, neutralized and injected.  Now, here again, you aren't




talking to a scientist so I can't tell you all that is involv




in it, but we make a blend of materials which is just




slightly on the acid side and put them into a well.  The well




is basically a dry hole.  Instead of having oil in it or wate




it has nothing, so we fill that with a neutral base chemical




that is a little bit on the acid                 to keep the




well running, to keep it from clogging up.




               Now, the disposal plant is permitted bY the Tr.




Water Quality Board and the Texas Air Control Board and they,




I can assure you, work with us on a regular basis to make




sure we comply.



               We have monitoring wells as was discussed




earlier to make sure that the material doesn't get out into




the water table and these are monitored by us and by the




Texas Water Quality Board.  So far, we have had no problems




since 1968.  And without giving any exact figures on the




amount of waste we are talking about, I can say that Malone




Trucking Company operates about 60 trucks around the clock,




around the year, hauling waste to this site.  So, we are




talking about a sizeable amount of material.




                           %3

-------
               Our main problem is not water,  but air




pollution.  Of course, we are permitted by the Texas Air




Control Board, but all chemicals have to be, at least on our




budget, stored in holding pit areas.   This is not a hole in




the ground, a permanent arrangement where you leave it out




there and hope it evaporates, but this is an area where they




are blended together before they are taken for final neutrali-




zation.




               Our main problem is being careful not to accept




any waste that has a high aromatic content because although




our plant is located in the Texas City area, there are people




who live there, believe it or not, and they are rather




particular if they have to leave their home over something




that was brought into our plant.  This has happened on a




couple of occasions and if anyone is here from that area, I




would like to apologize for that.




               We have some people with a scientific back-




ground on our staff.  We don't spend a whole lot of time as




Dr. Brown suggested analyzing every bit of waste that comes




in.  It is really prohibitively expensive and I don't think




it is necessary either.  The main thing that we check is what




its relative weight is so that we know where to put it,




whether it will float on top of what we already have or




whether it will go to the bottom: and what the aromatic




quality of it is.  If we can in fact release this material



                        910

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into the open air or not.




               Now switching back to the carrier operation.




Several people today have talked about whether or not the




regulatory bodies, Federal, state, or local, are adequate or




not.




               First of all, with regard to the disposal




operation, I feel that they are.  We certainly aren't left




alone by the State of Texas.  We are rather closely super-




vised and I feel that we are fairly supervised and the super-




vision is not of a defeatist nature.  It is of a health nature




We know what procedures to take when we want to expand, and




the Texas Air Control Board and the Water Quality Board will




really go out of their way to help us do that.  It is ray




opinion that they want us to continue as a private enterprise




and certainly we hope to.




               As a carrier the Railroad Commission, as I




have already said, is very particular about where we haul




to and what we have and the rates that we charge on the




state level.




               Now on the Federal level, the Department of




Transportation has become involved as you know in hazardous




material handling.  I just returned from a seminar in




Cincinnati that the Department of Transportation or rather




the American Trucking Association is putting on in behalf of




the DOT, concerning shipments of hazardous waste.  After

-------
spending about nine hours in learning what I could do to keep




out of jail, I can assure you that the Department of Trans-




portation is interested and they do have a pretty comprehensiv




program about transportation, shipping, and receiving and




record keeping on hazardous materials of all types.




               I believe that is all that I have in the way of




direct comments. I'll be happy to answer any questions.




               MR. LEHMAN:  Thank you, Mr. Montgomery.




               Are there any questions?




               Yes, Mr. Lindsey.




               MR. LINDSEY:  Mr. Montgomery, we have heard,




not here today, but prior to this, that in order to deep well




dispose satisfactorily one must be quite careful of the




geology of  the subsurface strata into which you are pumping




this material.  To be careful that you know what the capacity




and the extent of this strata is to receive and hold these




types of waste.  You are in  this business, and apparently




have been doing this for a while.  Can you tell us do you




have any procedures  for determining the capacity and extent




of the  strata to which you are  pumping to hold these kinds




of waste.   Could you tell us how you do that?




               MR. MONTGOMERY:  In a way  I can.  First  of  all




as I said before, that particular question is a little  bit




out of  my department, but  I  would like  to say that in  order




to get  permitted  to  do this  type of work  around  1968 we




                              912

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surveyed the well site, which incidentally we have been




operating one well, the same well, since 1968, and we surveyec




that as to capacity and as to possible contamination of




surrounding ground waters and that sort of thing.  We also




have a general idea of how much material has been put into




that since then.



               Now, I really apologize that I can't tell you




any more specific information than that as an answer to it,




but I know that this is done not just by our hands, but by




a survey of geologists which we contracted.




               MR. LEHMAN:  Mr. Mausshardt.




               MR. MAUSSHARDT:  I have a question from the




floor here.  The question really is a two part one.




               First of all, do you line your holding pits




that you place materials in and if so, what do you line them




with?  Do you also line or protect your injection wells as




far as sealing the top part of it so that materials can't com




to the surface?



               MR. MONTGOMERY:  Yes, sir.  Well, as far as




the holding areas  go,  I think the most general answer that  I




can give you is, no, they aren't  lined other  than by oils




and materials that we  had in the material that we have put




into it.



               Now that is true to form.  I know that there




is no plastic liner  in ^there.  Actually,  at this time I am



                         '313

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operating only one large pond for chemicals.




               Concerning the disposal well itself, it is




completely sealed up.  It is constructed in the oil well




fashion, cemented, fractured and completely protected.




               MR. LEHMAN:  Mr. Kovalick.




               MR. KOVALICK:  I was interested in some of your




comments about transporting waste.  Could you give us any




more information about the amount of interstate traffic these




60 trucks that operate around the clock carry, and the second




 question is  related  to the  transport.   You mentioned the  bill.of




lading or other shipping documents often contained quite a




bit of information.  Could you just describe for us the kind




of information that usually appears on a bill of lading for




mixed industrial wastes?




               MR. MONTGOMERY:  Yes.  First of all, with




regard to interstate transport, Malone Trucking Company is an




intrastate carrier.  We aren't engaged in interstate trans-




portation at all.  Related to that, I can't speak for Texas,




but I know of two neighboring states, Oklahoma and  Arkansas,




that don't care to take interstate waste shipments.  Oklahoma




for sure, I hope I am not speaking out of turn here, but we




were involved in a disposal site in southern California




which some state agency decided that they didn't need any wast




from Texas.  They had enough of their own.  The same thing I




think is true in Arkansas, though that might be by local

-------
 agreement rather than state.




                Now as far as  the Department of Transportation




 regulations concerning paper  movinq with the load'  i? nder the




 new public law for that sort  of thing there will be a shipper




 certification with the material.  The certification will stat




 that the material on board has been properly classified and




 it has the proper Department  of Transportation chemical name




 and the proper labeling and the proper classification,  and




 that will be signed by the shipper.  The carrier will keep




 this with him all the time he is transporting the load.  The




 truck that the stuff is moving in will be placarded either




 "flammable", "hazardous", "corrosive", "explosive" or what-




 ever it may be.  This certification and this record of class-




 ification and the placarding  will be kept in the carrier's




 records for inspection by the DOT.  This has not been done




 in the past.  This is relatively new.  The law became




 effective January 1st of '75, I believe, and it is just now




 finally being implemented.




                flR. KOVALICK:   If I could add just a little




 bit more to that.  As I understand those regulations the




 label that you would receive  at your disposal site might




 say "corrosive", or it might  say "organic", not otherwise




 specified, or something like  that.  Is that information




 sufficient for you to deal with that waste at the disposal




 site as opposed to_on board the truck?  Is there sufficient



	    SIS	    	

-------
 data there to deal  with mixing that with other wastes  by


 calling it a "corrosive",  "organic", or not otherwise


 specified?


                MR.  MONTGOMERY:  I  believe I understand your


 question,  but as  far as the Department of Transportation is


 concerned, as near  as I can determine they are interested


 only in transportation, shipping and transportation.   When


 it gets to the destination, to the consignee,  they are


 through.


                We know what the material is before we  get it


 because we just don't send a truck after it until we know


 just exactly what it is that we are getting and whether we


 can take it or not.  So we already have that information.  The


 reference  I made  to the DOT regs was so that the public would


 be protected in case of an accident or some sort of incident


 or spill of the material during transportation.


                MR.  LEHMAN:  Mr. Lazar.


                MR.  Lazar:   Mr. Montgomery, I have two


 questions.  Could you elaborate a  little bit more why  your


 company has to comply with the regulations of the Texas Air


 Control Commission  while many of your less responsible


 competitors don't have to do that.  I didn't quite understand


 that.


                MR.  MONTGOMERY:  Yes, sir, I will be glad to.


 That is my department.
                    » -

	        QIC	

-------
               All trucking intercity, anything that crosses


a public highway or leaves a town in Texas, is regulated by


the Railroad Commission.  Now in order to legally transport


any materials, I don't care whether it is cardboard boxes,


or chemicals, or gasoline, or diesel fuel, or household goods


you have to be granted authority by the Railroad Commission.


You have to go through a rather expensive process to do that


and any more you just about have to buy somebody else out to


get that type of authority.

               If you have it you are then subject to all the

rates, regulations, and all forms of compliance that the


Railroad Commission has.  One the other hand if you don't

have that authority the Railroad Commission flatly has washed


their hands of it.  They will not enforce any action against


anyone that is not a Railroad Commission regulated hauler.


So, if you are a dumping John Doe, or a "Cheap John Doe"

going down the road in your vacuum truck with no door signs

on it, as long as you don't have a Railroad Commission of

Texas plate they have nothing to say to you.  You can go on

about your business.

               Now, the Department of Public Safety, I believt


is supposed to take care of that sort of supervision.  That

is sort of important, but they are rather short-handed in


that department it has been our experience.

               MR. Lazaxi   MY other question concerns, or is
                           f* ,* M
                           Si7

-------
based on shipments you receive.  You mentioned at one point
you will make a decision as to what to do with it based on
whether to spread it on roads or whether to reject it and so
forth.  Obviously, it is quite complicated to do a thorough
chemical analysis of everything that comes in of this nature,
but do you check the sources of where these orders come from?
I have a good reason why I am askinq this question.  You
know, we know of one serious incident happening in Missouri
where oil was spread on the roads and it happened to have
dioxide in it which is an extremely toxic chemical substance,
or it may have poly-chlorinated minerals, so do you check
your sources before you decide what to do with it?
               MR. MONTGOMERY:  Yes, sir, we do.  The disposal
business in Texas is non-regulated.  Unlike the trucking
industry, it is not a public utility so you can charge what-
ever you want for disposal.  Obviously, if we were taking on
a hard-to-handle material that is of no commercial value or
a negative value, it will be disposed of finally and this is
going to cost us more and we have to pass this charge along
to the customer.  In the case of an oil, we can charge less
for that oil.  At that point in determining how much to
charge, we would try to make some determination of how clean
the oil was, how good it was, what the level of contamination
was, because we don't want to  — in other words, we may have
something that looks like oil, and if we know it is poisonous
                         SiG

-------
or hazardous or it is tremendously aromatic, we can't use it




for road oil.  So, in determining that the material we are




getting is good and clean, we can get a lesser rate so our




shippers, our customers, will be glad to work with us on that,




               MR. LEHMAN:  I'll just say for the benefit of




the audience that we have had a couple of other questions




brought up to the panel which are addressed to the panel, and




I just want to remind everyone that we are here not to speak,




but to listen, so if you do have questions please don't




address them to us, address them to the speaker.




             Are  there  any other questions of the speaker?




                (No response.)




               Evidently not.




               Thank you very much, Mr. Montgomery.




               MR. LEHMAN:  At this time, I would like to




call Mr. John F. Erdmann of the Texas Chemical Council in




Austin.



               MR. ERDMANN:  Members of the hearing panel and




assembled parties, before I begin I would like to mention




something about Mr. Montgomery's discussion.   I  am  from




Union Carbide in Texas  City and the Malone  facility is not




too  far  from one of our solid waste facilities.  The




question was asked about  the clay and the lining of pits




and  I would  like  to speak to that because I  feel that it  is




important to your understanding of the need  to be sure that

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local solid waste sites are evaluated on the basis of their




suitability, and that individual sites are very individual and




this is a very particular case.




          About four years ago , we contracted with the Gulf




Coast Waste Disposal Authority to build a liquid waste water




treatment plant and it was a plant which would involve the




use of large lagoons, and before we did the engineering work




we had to find out the suitability of the site.  Numerous core




samples were taken and permeability studies were made and it




so happens the clay in that area along the western shore of




dalveston Bay, right across from Pelican Island and so forth,




and in the Texas City area, is so impermeable to the passage




of water that we couldn't even get a test result.  It came out




less than one gallon per acre per year which was hardly




believable.  Then just recently we took some core samples frorr




some other pits that we  have had in operation for about 20




years containing a wide variety of organic materials and we




analyzed by the leaching process, the percolation with water




to determine how much material would go into the solution




from the clay.  We tested it for all sorts of metals and




organics and we found that it had no more material in it than




some materials which had been dredged out of the Bay and piled




over on another site at about the same tine that our pits




were dug 20 years ago, so we couldn't tell the difference.




I just wanted to bring that to your attention that certain

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sites do have peculiar characteristics and this is one that
we feel is very important that liners aren't necessary.
               Now back to what I came up here for in the
first place.
               I am substituting for Harry Whitworth of the
Texas Chemical Council.  He had to return to Austin and I
helped him at one of the subcommittees in preparing this
statement and some of the background for it.
               My name is John E. Erdmann.  I am the Environ-
mental Protection Coordinator for Union Carbide Corporation
at the Texas City plant, and a member of one of the Texas
Chemical Council subcommittees.
               The Texas Chemical Council is made up of 71
companies, all having one or more plants in Texas.  These
plants produce materials necessary for the health and well-
being of the people of the State of Texas, the nation and
the world.  Member companies employ 54,000 Texans and have
payrolls of over $500 million per year.  We appreciate this
opportunity to comment here at this hearing.
               The philosopher, Alfred North Whitehead, once
observed that before answering a question, you need to find
out what use was to be made of it.  He was concerned that
words and statements have different meanings in different
contexts.  We are similarly concerned today.
               From the Environmental Information Sheet and
                            921

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slick paper booklet "Hazardous Wastes" which was sent out to
the public by the EPA in preparation for this meeting, we
gather that the EPA has already concluded that  ederal regula-
tory legislation is needed.  We specifically disagree with
this conclusion.
               The State of Texas and the Environmental
Protection Agency in combination already have adequate control
of all discharges.  Therefore, before commenting on the sug-
gested discussion topics, we would like to make the context
of our remarks as clear as possible lest they be misinter-
preted.  Since these hearings are being held under Section
204 of the Solid Waste Disposal Act, we will confine our
remarks to those solids, semisolids, and liquids which are
disposed of by solid waste technology although hazardous
wastes can be in the form of either solids, liquids, or gases.
               First, the Texas Chemical Council supports the
safe and proper disposal of all solid wastes, both hazardous
and non-hazardous.
               Second, we believe this can be accomplished
best by local and state regulations.  Differences in disposal
site characteristics and the large variety of solid wastes

make the number of possible interactions so complex that
solid waste disposal can be handled best on a case-by-case
basis.  This means control and flexibility at the local

level.
                          b22

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               In Texas,  we already have the necessary




regulatory mechanisms to do this.   For those states that




don't yet have control programs we commend to them the




recently adopted solid waste regulations by the Texas Water




Quality Board.  These are specific enough to provide for




control while still allowing consideration of the best




methods on an individual basis.




               Further regulation would probably conflict




with existing legislation in at least some respects.




               The Section 208 areawide planning portion




of Public Law 92-500, which are the 1972 amendments to the




Federal Water Pollution Control Act, already mandates in




paragraph 208b2J and 208b2K processes for the control of




the disposition of all residual waste generated in such




an area which could affect water quality and the control




of disposal of pollutants on land or in subsurface




excavations within such an area to protect ground and




surface water quality.








               Under this plan, state and local bodies




are already working out waste management plans tailored to th




needs of specific areas. Let's give existing laws a chance

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to work before passing new ones.   Incidentally,  there was a
hearing this last Saturday in the Houston-Galveston area,
Council of Work Shops for that very purpose.
               Third, we believe solid waste should be
disposed of in a technically sound and feasible manner, and
that these technical aspects should be given precedance over
legal simplicity.  There is a strong tendency by rule makers
to write regulations that are easy to administer and to
enforce even though they may be costly and inefficient.
               Fourth, in regard to costs, we believe solid
waste regulations should be cost and energy effective.
Although we do not have the data in hand, we suspect that
solid waste disposal costs will follow a curve similar to
those for air and water.   That is to say, solid wastes can
be disposed of in a manner safe to humans and most organisms,
at reasonable cost and with reasonable expenditures of energy.
But super-safe disposal to protect all organisms against all
conceivable contingencies will require expenditures of both
money and energy that are disproportionate to the benefits
gained.   All costs must eventually be borne by the public
in the  form of increased prices, taxes,  defaults, or
inflation.  Thus no  law or rule that requires either
unnecessary or foolish expenditures is in the public
interest.
             Turning now- to the  suggested discussion  topics.
	BZk	

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The Texas Chemical Council in general endorses the statement




made by the Manufacturing Chemists Association at the




December 4, 1975 hearing in Chicago.  We also offer the




following comments:




               Under Topic 1:  The word "hazardous" in




ordinary usage means a combination of some thing and some




circumstance such as to produce a danger or risk.  All




materials are hazardous in some circumstances and thus, the




attempt to define a hazardous material without regard to




location or exposure has inherent difficulties.  Several




definitions have been proposed and we believe the one




proposed by the Manufacturing Chemists Association is as




good as any.  What is needed most is a common sense




interpretation of whatever definition is adopted.




               Sampling and analysis should follow standard




works on these subjects such as "Standard Methods"  used by




the ASTM.  We specifically request that the EPA not introduce




additional analytical methods without a truly compelling




need, and that, insofar as possible, existing analytical




methods be used.




               Topic No. 2:  In trying to assess




responsibility and liability, legislators and rule makers




can largely determine the mechanisms by which solid wastes




will be disposed of, even though these may not at all enhance




environmental protection. " For^example, holding the generator

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solely accountable for the ultimate disposal of his waste will




doom contract commercial waste disposal operations.  No




generator could afford the risk of having someone else do it




for him.  A number of rational divisions of responsibility




can be made and some of these are discussed in the MCA




statement.  We believe the divisions and procedures of the




Texas Water Quality Board regulations are reasonable ones.




               Topic 3:  As we indicated earlier these matters




are so complicated by specific waste and disposal site factors




that no general answer is possible.  Each case should be




handled individually and each should be a technically sound




compromise between the possible and the affordable.  Thus, we




believe it is futile to say that this or that waste should be




incinerated, biotreated, or whatever.




               Rather we recommend that reasonable, attainable




end-results should be defined and that the  decision be left




to  the  generator  as  to the best treatment and disposal means.




In  short, we do not  believe that  as a  blanket rule, any




specific  treatment  should be  either required or  prohibited,




only  that the material  be safely  disposed of.




               There is  a great need which  the  EPA could fill




for the collection,  organization,  and  dissemination of




information  on waste disposal treatment,  site  factors,  costs,




et  cetera.   Considering the  volume  of  solid waste generated




only a small fraction is receiving improper disposal  and

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probably much of this because of lack of information.




               Topic 4:   Where means of detoxification exist




these are generally known to the larger operators.   The EPA




could perform a service by publishing a description of




detoxification reactions along with realistic cost




requirements.  This information would be of value to smaller




operators and would set a rational framework for discussion




of the whole subject.  We suggest the EPA work through trade




and professional associations to prepare such a publication.




               Topic 5:   Very little cost data are available




in useable form and we suggest the EPA set about collecting




such information from published literature and from both




industries and municipalities by working through trade and




professional organizations.




               Topics 6, 7, 9 and 10:  We recommend that




the methods and procedures set forth in the recently




reviewed solid waste rsgulations of the Texas Water Quality




Board be used as a guideline for these.




               Topic 8:   We have no comment.




               Topics 11 and 12:  We believe that shipping




and labeling of wastes should follow the same requirements




as those required by other products having similar physical




and chemical characteristics.  Again, we recommend the Texas




solid waste regulations as a guide to recordkeeping




requirements.

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               Topics 13,  14,  15 and 16:   We would hope that

the EPA would provide the answers to these questions on

damages from improper solid waste disposal, of citizen

acceptance of hazardous waste disposal facilities, and of

waste generation and disposal by Federal facilities.

               In summary and in conclusion, we believe that

solid waste disposal is best regulated at the state and local

level and that sufficient legislation already exists for this

purpose.  We urge the Environmental Protection Agency to stay

its regulatory efforts and to redouble its other solid waste

functions as listed on the last page of their Hazardous Waste

booklet.  These include:

               1.  Supporting research on the health and

safety  effects of land disposal of those wastes that cannot

be recycled.
               2.  Working with State and  local governments

to improve  solid waste disposal practices;  and,

               3.  Providing technical assistance  and

information to State and  local  governments,  and to industry,

to speed  the application  of new technology and environmentall

sound waste disposal practices.

               Thank you  very much.

               MR. LEHMAN:   I have  one question.

               Certainly  your statement  indicated it  was

your belief that —  I  believe you used  the words  —  only
                              928

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 a small fraction of wastes is being disposed of improperly, c




 yet we heard earlier from Dr.  Brown that  it  was  his  estimate




 that at least in his locality  that  there  was a  significant




 percentage of,  I believe he  used the term something  like




 greater than 60 percent of the waste was  being  disposed of




 improperly.




                I was wondering if you had any comment on




 that,  some guide as to how you might resolve that  discrepancy




                MR.  ERDMANN:  First  of all, in our  area we




 have in the past had a little  bit of that.   I don't  know  of




 any now.   I know all of the  people  that we use  for truck




 hauling,  and Malone is one of  them  and there are several




 others, are reputable and in fact quite as concerned about




 the problem as we are.  We dispose  of all of our waste on




 site.   It is on our own property, and so  they don't  have  to




 worry about it.  They are not  concerned with anything but




 hauling it.




                However, in the Dallas area I am sure that the




 situation is different.  The industry up  there  is  quite




 different than it is in Texas  City  and the Houston ship




 channel,  and I feel that it  is quite diversified.   There  are




 a lot more smaller operators,  and the land situation is




 quite different.




                As to how to  prevent it, I would suggest  that




 a couple of State Troopers can stop that  practice  very



	                 S23

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quickly.  I am sure that it is against almost any ordinance




and with the proper show of diligence most people know where




these places are, where these dumps are occurring.  It is not




hard to find them and I should think that a little patroling




would certainly help the situation, and maybe you have to




string somebody up a little bit to get some attention, but I




think it would profit pretty quickly.




               MR. LEHMAN:  Any other questions?




               Mr. Lazar.




               MR. LAZAR:  Mr. Erdmann, you expressed the




hope in your comments that those states that do not have




regulations yet that they will innovate the Texas Water




Quality Board.  I would like to ask you how you envision




this would come about without Federal regulations.  How do




we encourage those states to effectively have regulations




which have not acted up to now?




               MR. ERDMANN:  I think that the Federal




government can set standards and in this way help promote




that, but there are other  ways which are I believe more




effective and that is that our agency people meet with agency




people  of other states.   In  fact,  the head of our Air Control




Board,  our Executive Director Charles Harden, is  the




chairman of a nationwide  group of  similar directors of Air




Control Boards in other  states, and  Mr. Yandis  is represented




on some, also, I  believe,  a-ndpwe do  have  representation  and

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we do discuss these things back and forth.




               What it boils down to, I think, is which




states are doing the job most effectively at the least cost,




and, really, then other people will be attracted to use those




methods.  Frankly, I think the recent regulation that was




written by the Water Quality Board took a step in that




direction, because it provides very definite, definitely the




use of the individual discretion in how things can be best




done in a technical manner.  And I think we all realize that




you cannot legislate technology.




               I hope that is helpful.  Did I answer what you




wanted?




               MR. LAZAR:  Yes.




               Another question, please.  You mentioned that




it would be very desirable to have flexible state and local




regulations on hazardous waste and, therefore, no Federal




legislation or regulations within those guidelines would be




desirable.  Why are the two mutually  exclusive?




               In other words, is it  not  conceivable to have




Federal legislation and guidelines or regulations and still




have local flexible control of a situation?




               MR. ERDMANN:  The problem  is when we are




dealing with the waste, none of which are pure materials  in




many cases, and what you would have as  in a still bottom




from a  location in Texas City would not correspond to one

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from a similar process in Oklahoma City, and would not
analyze the same and it might not be able to be handled the
same way.   You might be able to deep-well dispose of it there
but you might be able to do it here, and we feel in general
that if Federal regulations are imposed that they would have
to be so general that they might exclude the possibilities
of doing things which would be most practical in certain
locations.  This is what we are looking for, is the
flexibility to do the job technically and safely, and not
have to worry about the letter of some regulation which was
not proposed other than to be uniform but which may not fit
the need.
               MR. LEHMAN:  Mr. Kovalick.
               MR. KOVALICK:  If I could explore that last
point, I was wondering if you would also agree  that it is
possible for a state that is innovated like Texas to adopt
a set of regulations for the protection of its citizens, and
then for neighboring states to become concerned about, shall
we say, the waste flow for their area and, therefore, adopt
either more or less stringent regulations for the protection
of their citizens.  It would seem — at least that is
perplexing to us.  Do you have an observation on that

dilemma, that the waste end up being a waste flow because
of variances between and among the  states?
               MR. ERDMANN:  I don't think that we worry too
                           932

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much about whether the lettuce grown in California is sold in

Dallas, or Santa Fe, or Chicago.  It meets certain needs, and

I think that we can do the same thing with waste.  If we can

dispose of them properly, it doesn't make any difference

whether there is a state line there or not, as far as I am

concerned because the technology is determined and the site

location and the conditions under which it is being done, and

also the economics.  You are not going to transport things

from Dallas down to the Rio Grande, for example.  It costs

too much to move.  It seems more convenient to go across

state  lines to another area and if it can be done more

properly there, I see no reason why it can't be done that

way.   If somebody complains, "Well, you are bringing your

garbage over into my neighborhood," I don't think it makes

a whole lot of difference.  It  could have been coming from

another town in his own  state 30 miles away and he would

still  have the same complaint.

               MR. KOVALICK:  So you acknowledge there would

be  some confusion  if, for example, Oklahoma were to prohibit

land disposal of waste that would originate in Texas.

               MR.  ERDMANN:  That could possibly pose a

problem, but I think that it could be handled intelligently

if  people would  look at  the facts and not  at the political

consideration.

               MR.  LEHMAN:  Mr. Mausshardt.
                     '   933

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               MR. MAUSSHARDT:  I have a question from the




floor here.  The question is stated:  Hasn't the Federal Safe




Water Drinking Act provision had an effect upon state waste




disposal operations?  Do you care to comment?




               MR. ERDMANN:  Yes.  I believe they have, but




I haven't been working too closely with that drinking water




situation and, frankly, I don't feel comfortable in commenting




on that.




               You know that there are provisions in that




Act which will make deep-well disposal in some cases difficul




In our particular area in Texas City  it does not apply too w<




because the drinking water that they bring up is from  such




deep levels, and  the permeability aspects are such that no




surface water gets in  it.




               MR. LEHMAN:  Mr. Lindsey.




               MR. LINDSEY:   I have a question  from  the




audience.  Would  you comment  on the relative hazards of land




disposal versus properly  conducted  deep  ocean dumping?




               MR. ERDMANN:   Again, I think  it  depends to  a




great  extent  upon what you  are dumping.   Each case  should  be




taken  into proper perspective.   I  don't  believe you  should




dump chlorinated  hydrocarbons on either  land or in  the sea,




and  the burning of  it  on the  Vulcanus  as was described




earlier this  morning  is  a very  feasible  and  a  logical  way




 to handle  a  problem like that.   But you could  take  sewage
11,

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sludge from the City of Houston and dump it out at sea and it

probably wouldn't hurt a thing because it would just be a

drop in the bucket compared to what is coming down the

Mississippi River.

               MR. LEHMAN:  All right.  Are there any other

questions?

               Mr. Kovalick.

               MR. KOVALICK:  I wanted to clarify your

comment.   I don't know if I can find it in your statement

on a moment's notice.  As I recall, you made a distinction

between what I would call the process kind of standards that

have been typical of the water pollution permit discharge at

a certain level, or perhaps I should say best practical

treatment is what I call a process standard, and I thought

you were making a distinction between that and what I would

call a performance standard where there is some level of

performance that is up to the person providing that treatment

to meet that level whether it is certain parts per land, and

so forth.  If I heard that distinction correctly, did you

advocate the latter as opposed --

               MR. ERDMANN:  Well, it depends —

               MR. KOVALIcK:  With regard to waste treatment.

               MR. ERDMANN:  With regard to waste treatment

I think you ought to look at waste water treatment a little

bit differently than you'haveto look at solid waste
                           SOD

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treatment.  And if I get the gist of your question
correctly, and I am. not quite sure that I said that,  but I
will try to answer it anyway.
               The original work on water ocean control, we
were most concerned with the receiving water, and the
qualities of the receiving water, and I think in the ultimate
end of things that is really what we are concerned with, but
the practicalities of trying to determine whether the
receiving water is or is not meeting certain standards is
rather difficult.
               I think that Galveston Bay is a good example
of that.  I have followed a number of surveys on Galveston
Bay ever  since 1967, and from the data you certainly cannot
tell if it was polluted then nor is it any more polluted
along the way.  There is really no way you can analyze the
data to say this,  but we all know that there has been
tremendous changes in the Bay because of the work that has
been done around  here.
                So to use the criteria of the receiving water
is very difficult, because  it is  hard to assess  the  changes.
That water  is moving all the time.   If you get on a  land
spill  and you can see  the  effects,  and it doesn't get
around too  well,  and I  think that performance  there  is  a
 little easier to establish than perhaps  —
                MR. KOVALICK:  I found this  sentence.  Maybe
                              336

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this will help.   "We recommend that reasonable,  attainable

end-results should be defined and that the decision be left

to the generator as to the best treatment and disposal means.

I was trying to get an elaboration on what you mean by "end-
results" with regard to waste disposal.
               MR. ERDMANN:  In the case of solids we would
certainly hope that they would have no effect on the surface
waters or the sub-surface waters, and keep the odors down,
and disease, and flies, and all the rest of it in a sanitary
landfill  or its reasonable equivalent without any sub-
surface disturbances.
               MR. LEHMAN:  One last question, Mr. Lazar.
               MR. LAZAR:  Mr. Erdmann,  in your statement you
have referred to two specific paragraphs of the Water
Pollution Control Act of 1972, and I was wondering would you
elaborate on these two paragraphs.  You cited 208b2J and
208b2K.  Do they have any enforcement provisions, and if yes

what do they consist of?
               MR. ERDMANN:  I will have to decline on that,
because I, frankly, wouldn't be able to tell you.  I would
have to go back and look at some of the reasons.  As you know
the Act is quite lengthy and we worked on this some time ago

and it was a committee action.  I don't know why that was
put in in that manner, other than to be specific on the

statement about the fact that these things were already being
                                937

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regulated by this Act in terms of area planning.

               MR. LEHMAN:  All right.  Any other questions?

               (No response.}

               I don't believe so.  Thank you very much.

               Is Mr. Gartner in the audience now?

               (No response.)

               Next I would like to call upon Mr. H, H.

Meredith of the Exxon Corporation.  Mr. Meredith, please.

               MR. MEREDITH:  Mr. Lehman, members of the

panel, ladies and gentlemen.

               My name  is H. H. Meredith, Jr.  I am

Coordinator, Environmental  Conservation for Exxon Company,

U.S.A. on  whose  behalf  this statement is presented, as  well

as  the Exxon Chemical Company, U.S.A.
               We do appreciate  the opportunity  to  disucss

our response to  the  topic in  the Federal Register of

September  17,  1975.  My comments present Exxon's general

views on the subject of waste management.
                Exxon believes that protection of the  public

 health is  an essential  national  objective,  and should be the

 primary focus  of all environmental laws and regulations.

                A second, but appropriate national objective

 is conservation of the nation's resources to promote the

 public welfare to the extent of achieving a reasonable

 balance between the nation's economic and social needs and
                           938

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aspirations.
               These objectives,  obviously,  require  the

commitment and cooperative efforts of government,  industry,

and the public.  This meeting indicates commitment and

cooperation by EPA which is commendable.  Exxon stands ready

to assist in the development of waste management systems

which may be necessary to protect public health or promote

the public welfare.
               In responding to the subject of this meeting,

we must all keep in mind the numerous existing regulations

that control the discharge, the transport, the manufacture

and the handling of materials which may be significant

constituents of wastes.  These developed regulations are

basically adequate and, further, they are constantly being

modified to meet changing needs and circumstances.

               Regulatory guidelines and controls may also

be needed for  the disposal of wastes to our nation's land.

Municipal wastes and  industrial wastes may require

additional regulation  in  some locations.  As a matter of
fact,  the problems associated with each are inseparable.

               It  should  be noted at the outset that our

manufacturing  plants  use  land emplacement as the  primary

waste  management tool.  Therefore, most of our remarks  will

concentrate on this procedure.

               Any needed guidance for  waste management
                               033

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should provide a balanced program for land use and should be




site specific.  Potential leachate and/or surface runoff




should not contaminate potable waters nor render other waters




unsuitable for their intended use.  However, a land




emplacement site overlying nonpotable ground waters and




situated where leachate in surface water would go to a




nonpotable water body should have different requirements than




one where potable water is involved.




               Now while controls may be needed for the land




disposal of domestic and industrial wastes, this does not




mean that properly sited, engineered, and controlled landfill




operations should be regulated out of business.  Further,




resource recovery programs should be given every opportunity




to develop such that cost competitive, energy conservative,




alternate techniques will become  available.




               Any guidance for waste management should




allow a reasonable time period for the implementation of new




waste disposal practices.  With reasonable time private




competitive industry can respond  by modifying current waste




generating processes and/or by instituting new, environ-




mentally acceptable disposal  techniques.




                In general, any regulatory  approach  should




not  require specific techniques  to  be utilized  for  the




disposal of any waste.   The regulatory criteria should  be




strictly aimed  at contpoftling the environmental impact  of

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the disposal operation.  For most wastes there will be




several environmentally acceptable disposal techniques, and




the generator will naturally select the best combination of




efficient, acceptable procedures on the basis of local




physical and economic factors.   We recognize there may be a




limited number of wastes which are so specific and unusual




that only one method of disposal, such as encapsulation, is




environmentally acceptable.




               The proper definition of the term "hazardous




waste" is critical to the development of hazardous waste




management.  As inferred previously, the basic criterion




which should be considered is the impact of the waste on the




environment.  The fact that a waste material destined for lane




emplacement may require specific precautions in handling is




not, in our opinion, in itself a valid criterion to define as




a "hazardous waste" requiring specific disposal precautions.




               For instance, certain waste materials may




become environmentally inert upon land disposal.  Since




existing regulations provide the basis for controlling air




and point source water emissions from disposal operations,




the major concern of hazardous waste management should be the




control of ground water pollution from leachate and nonpoint




source runoff from landfills.




               Many leachate tests have been suggested to




help in determining what is. "hazardous" and what is not.

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However, no generalized criteria can be applied to the




leachate test results.  If the leachate could flow into a




potable water supply, it should be judged against a very




stringent standard.  However, application of this standard




to all leachate would be inappropriate and wasteful.  The




criteria should be the protection of the designated use of




the water resource, and should therefore be site specific.




               Any waste management guidance should call for




defining the responsibilities of the generator, the




transporter, and disposer of hazardous wastes.  In this




regard records must be maintained by each party so that the




generation, transportation, and disposal of the waste is




documented. In addition, the generator should be required to




accurately characterize the waste and to contract with an




approved hauler and disposer.




               Existing OSHA and Department of Transportation




regulations regarding  handling and  transport of materials we




believe are adequate  and should not be duplicated.




               In  the development of waste management




regulations, many  industrial wastes are being  considered




"hazardous."   it  should be pointed  out that many  petroleum




industry wastes readily respond  to  biological  oxidation




processes,  such as land farming.  Exxon's  position  is  that




these materials are not hazardous to  public  health  or  welfare




unless treated in an irresponsible  manner.   It is not

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necessary that these wastes be disposed of in completely




enclosed systems, as has been suggested by some.




               Finally, and I would like to comment on the




subject we should always keep in mind when generating guide-




lines, and that is who pays for a cleaner environment.  Each




dollar required to establish and achieve environmental goals




must be paid for either in additional taxes or in the higher




cost of products.  Both of these revenue sources must come




ultimately from the citizens.  The primary objective of both




industry and the government should be for each citizen to




receive the most benefit for his dollar.  Therefore it is




important that all controls be realistic and encourage low




cost,  efficient  solutions  to waste management problems.




               That concludes my presentation.




               MR. LEHMAN:  Thank you, Mr. Meredith.  Will




you accept questions?




               MR. MEREDITH:  Yes.




               MR. LEHMAN:  I have one.  You mentioned in




your  statement that if there were  to  be  any waste management




controls or regulations that a  reasonable  time  for




implementation be  allowed  for these.   Would you care  to




expand on  that and give us some feeling  of what you consider




to be a reasonable time for these  circumstances?




               MR. MEREDITH:  Only in general  terms,  if  you




will, Mr.  Lehman.

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               So often we encounter regulations which become




effective so quickly such that we have to come down on a




solution immediately and spend all of our energies and time




on the working out of the details of that one method instead




of spending some time trying to figure out what is the best




method.  So I am simply entering a plea here to consider the




fact that you may not have a solution worked out for a




regulation ahead of time, since you don't know what the




regulation is going to be.  So if there can be a period, you




know, we fool around with a problem for twenty or thirty year




and then we feel like we have to solve it in six months.  So




sometimes we just fall all over ourselves in shortening the




time period for implementation such that we, as the problem




solver on the other end, feel like we could have done a lot




better job if we had had a little bit more time.




               So, you know, we are just asking for




reasonableness as you people think about guidelines for




people to use in developing regulations you  ought  to think




about  this point, too.




               MR. LEHMAN:  Thank you.




               Mr. Kovalick.




               MR.  KOVALICK:   A sentence  out of your




statement--you said  in  general  any regulatory approach




 should not  require  specific  techniques to be utilized for




 the disposal of  any waste.   The regulatory criteria should

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be strictly a i.med at controlling the environmental impact of disposal




operations   ^s mV reading of that similar to my question of




the gentleman from the Association preceding you.




               MR. MEREDITH:  Yes.




               MR. KOVALICK:  I make a distinction at least




as in those two sentences between the concept of process




standards versus performance type standards, and I take  it you




are endorsing the latter.




               MR. MEREDITH:  Yes, but even more than Mr.




Erdmann did.  Considering the local conditions which exist;




I mean to repeat, if you have got a potable  water table




right below you there are very few things that you can  do




with the landfill operation, but to say that a specific




waste should always be incinerated or should always be




treated in some particular manner I think probably in some




cases cuts off maybe a better and certainly cuts off all




innovative solutions to the problem.  Yes, I think you  have




assessed it correctly, sir.




               MR. KOVALICK:  My second question, Mr.




Chairman, one of  your points — Why don't I come back to




that.




               MR. LEHMAN:  Mr. Crowe.




               MR. CROWE:   Have you had a chance yet  to look




into what you think the  increased cost  of your hazardous




waste approach will be in  view of the new Texas  Water  Quality

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rules and regs and  are they going to be that nuch more stringent




to where you feel this is going to increase yovr costs?




               MR. MEREDITH:  No,  sir.




               MR. LEHMAN:  Could  I clarify that, Mr. Mereditt




The "no" meaning no you haven't looked into it, or  "no"  it  is




not going to increase your costs?




               MR. MEREDITH:  The  procedures  which  are




required are being followed anyway, so it is  not going  to




increase our costs.




               MR. LEHMAN:  Mr. Mausshardt.




               MR. MAUSSHARDT:  The question  is do  you  feel




that the best system could be one  in which EPA would write




guidelines to the states  to establish  state  solid waste




regulations and have a compliance  schedule similar  to the air




pollution regulations?




               MR. MEREDITH:  You  lost me on  the  last part




of that question.




               MR. MAUSSHARDT:   Possibly I could  restate it.




The  question  was,  I  believe,  should  EPA  follow the  Clean Air




Act  type approach where  nationwide guidelines were  written




for  the states  to implement at  a state level, and this being




a regulatory  guideline approach is this  what you are




essentially  stating or making in your statement?




                MR.  MEREDITH:   Who am I  ;to say what the best




 solution is?   We have no particular  objection to EPA

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bringing uniformity to the state's handling of the wastes




management problem.  So there is no objection on our part to




an overall set of guidelines which would be followed by




regulatory agencies.




               Now this doesn't deal with the Clean Air Act.




I am frankly in the dark as to how it would relate to the




procedures of the Clean Air Act.




               MR. LEHMAN:  I think it is just the basic




philosphy and pattern used here.  That is the implication.




               MR. MEREDITH:  To which I can't resist saying,




Mr. Lehman, that may have been the original idea of the Clean




Air Act, but it has gone considerably further than that




today.   (Laughter and Applause.)




               MR. LEHMAN:  Do we have other questions?




               Mr. Lazar.




               MR. LAZAR:  Mr. Meredith, has your company




performed any research on the health safety of land farming?




You mentioned land  farming of certain petrochemical wastes




is harmless.  We would appreciate it if you could send any




documentation you might  have available.




               MR. MEREDITH:  Let me answer that  in two parts




We have  a  separate  research organization.  We have our own




medical  department.   There  is continual interplay between




our medical department and  the  research organization  to




determine  if  any  of  our  products  or  any of our  emissions  or

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any of our effluents contain elements which may be carcino-




genic which may cause trouble in any manner as far as  health




is concerned, and if such is ever found the product will  be




changed immediately.




               Now as regards to research on land farming,




we have conducted it for a considerable period of time.   All




of our tests indicate that in time the sludges which we have




land farmed have been oxidized and the lands have recovered




or as oxidized is insofar as we can tell equal to or better




than it was before the sludge was farmed into it.




               MR. LAZAR:  Do you have any information




specifically on potential update of metals by the crop?




               MR. MEREDITH:  No, I do not, but I will




certainly make a note of that and answer.




               MR. LEHMAN:  Do we have any other questions?




               Mr. Kovalick.




               MR. KOVALICK:  In your statement you recognize




the problem that has puzzled us as we think about  defining




hazardous waste,       There   is probably a body of things




one would not label hazardous if you had a certain degree of




certainty about the way in which it would be managed.




               MR. MEREDITH:  Yes.




               MR. KOVALICK:  You have in reality in some of




your statements this morning presented the difficulty in trying

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to think about definitions of hazardous waste at the same time




thinking about how it is managed, but  suggesting we separate it




into two questions.  In other words, thinking about a little




more catholic definition of what is hazardous and then if you




had confidence about the way that waste is managed that is




of course no longer hazardous.  Do you care to comment on




that?




               MR. MEREDITH:  I guess the sentence in the




statement is rather a frustration and a striking out against




all of us getting very strict and restrictive rules and




regulations because of irresponsibility which is exhibited




by a small percentage of industry, and we simply, well, you




know, if you don't break the speed limit you hate to see




real restrictive  limits set on things.  So I simply say this




is a philosophical approach in which it would seem to me




that the assumption should be made that responsible following




of the intent of  regulations will be the rule rather than




irresponsibly trying to get around it.




               MR. LEHMAN:  Do we have any other questions?




                (No response.)




               Evidently not.  Thank you very much, Mr.




Meredith.

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          COMPANY U.S.A.
 POST OFFICE BOX 2180 • HOUSTON, TEXAS 77001
 PUBLIC AFFAIRS DEPARTMENT
 ENVIRONMENTAL CONSERVATION
                                                   December  11,  1975
Mr.  Emery C.  Lazar,  Program Manager
Hazardous Waste Management Division
Office of Solid Waste Management Programs
Environmental Protection Agency
Washington,  D.C.  20460

Dear Mr.  Lazar:

      At the  conclusion of my presentation to the Environmental Protec-
tion Agency  Panel on Hazardous Waste Management on  December 9 here in
Houston,  you requested that I send you, for the record,  results of any
scientific studies on land farming of oily substances.   Attached is a
copy of a 1975 API paper, "Assimilation of Oil by Soil Bacteria" (Pre-
print No. 24-75) by R. L. Raymond, J. 0. Hudson, and V.  W.  Jamison.
The  land farming of six oils at three geographic locations  was investi-
gated to determine the magnitude of the stimulation of the  specific
hydrocarbon-utilizing flora.  In addition, residues, leachate water
and  runoff water were analyzed and the data are presented in this
report.

      The EPA report I mentioned to you after the meeting is titled
"Oily Waste  Disposal by Soil Cultivation Process" by Buford C.
Kincannon and has a report number EPA-R2-72-100  (1972) .   A  copy of
this report  should be available in Washington.

      I believe these two reports will give you very good background
.information  on land farming of oily waste materials.
                                     Yours very  truly,
 HHM-WLL:F
 Attachment
 c  wo/a:   John P.  Lehmann, Director, HWMD
                                REPORT DETACHED AND RETAINED
                                IN HWMD FILES
   A DIVISION Of BOON CORPORATION
                                      950

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               Ladies and gentlemen, we are very close to the
time we announced to take a break.  On the other hand, we
have remaining on our list of candidate speakers a number of
                           951

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people we have called in the past and who have not been



present.  I think it might be worthwhile, if you will bear




with us just for a bit, if we could perhaps one last time




call for these speakers and if they are not here then there




is really no reason to continue the meeting.




               I would like at this time to call a represen-




tative from the National Barrel and Drum Association. Is




there a representative of the National Barrel and Drum




Association in the audience?




                (No response.)




               Let the record show that such representative




was not in the audience.




               I might call at this time W. A. Quebedeaux,




Harris County Texas Pollution Control Department.  Is Dr.




Quebedeaux in the audience?




                (No response.)




               Let the record show that Dr. Quebedeaux was




not in  the audience when  called.




                I would  like  to call next Mr.  Robert  Gartner




of the  Sierra Club, Houston, Texas.  Mr. Gartner,  please.




                (No response.)




                Let the record  show Mr. Gartner was not  in




the audience  when  called.




                Ladies and gentlemen  that,  according to  my




 list,  ends the  people who have asked to  be allowed to speak



                            952

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at this meeting.   Let me say one last time is there anyone
in the audience who does desire to make a statement at this
time?
                (No response.)
               Let the record show there were no further
requests for time to make statements.
               I would like to remind you, as we said at the
beginning of the meeting, that we are accepting written
statements for the record up until January 31, 1976, so if
as a result of this meeting you have some thoughts that you
would like to leave with us I would urge you by all means to
please submit those in writing and submit them to us for the
record.
                I would like to express our thanks from our
headquarters office to EPA's Region  6 in Dallas which took
care of all of  the arrangements for  these meetings, and I
hope that you have gotten as much out of these discussions
and statements  as we have.   I know many of these statements
were very carefully thought  out and  presented and we
appreciate the  amount of effort that was put into them.
                Before closing I would like to remind you all
once again that there is an  EPA Town Meeting at which Mr.
John Quarles, the Deputy Administrator of  EPA, will appear
to be held this evening at  7:30 p.m., 301  Sewell Hall at
Rice University.  Perhaps some of vou would be  interested  in
                             353

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attending those sessions scheduled  from  7:30  to  10:00 o'clock




this evening.



               There being no  further  business I would like to




this opportunity to once again thank you for  coming,  and




I declare the meeting adjourned.  Thank  you.




                (Whereupon, at3:30 p.m.,  the proceedings in




     the above-entitled matter were closed.)'
-alee

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               STATEMENT
                OF THE
         DOW CHEMICAL COMPANY
           TEXAS DIVISION
             PRESENTED BY
             GLEN WESSELS

              BEFORE THE
    ENVIRONMENTAL PROTECTION AGENCY
  HAZARDOUS WASTE MANAGEMENT DIVISION
OFFICE OF SOLID WASTE MANAGEMENT PROGRAMS

      MEDICAL CENTER HOLIDAY INN
            HOUSTON, TEXAS

           DECEMBER 9, 1975
                    956

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                           PRESENTATION






     Good morning.  My name is Glen Wessels, I am Supt. of Waste




Control of the Dow Chemical U.S. Area Texas Division at Freeport,



Texas.  Our Company, as others, was invited to participate in




this open hearing concerning environmentally safe management of



Hazardous Waste.




     Since all our waste is handled, treated, and disposed of on




site, I will limit my remarks to topics that are of direct con-



cern with our operation.



     My presentation will be in narrative form to the discussion




topics rather than question by question.



     We subscribe to the classification of waste as established



by the Texas Water Quality Board.   We suggest that Hazardous



Waste as it relates to Waste Disposal Means "any waste or mixture



of waste which is toxic, corrosive, flammable, a strong sensitizer



or irritant, generates sudden pressure by decomposition, heat or



other means and would therefore be likely to cause substantial



personal injury, serious illness,  or harm to human and other living



organisms."  Hazardous substances  are already defined by other




Governmental Agencies including the Department of Transportation.




We suggest no additional regulations or procedures are needed.



     We endorse the proposal that  the generator of waste should




have the option to dispose of their waste on site or utilize a



private or public operated system, provided the system selected



satisfies governmental regulations and is environmentally safe.
                                   S5b

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We subscribe to the provisions that governing agencies establish




practical and environmentally acceptable regulations for handling



and disposal of waste.



     All of our waste is handled by us on site.  We are responsi-




ble for the cost and environmentally safe disposal of all waste



we generate.  This includes selection of disposal site, disposal



methods, transportation methods, packaging and labeling, main-




taining adequate records and adherence to an  acceptable perform-




ance in all phases of the operation.



     Every plant waste should first be considered a raw material




for recovery and reuse not only for in-plant use, but for others.




Beyond this, disposal methods will vary due to location, facili-



ties,  cost and environmental impact of disposal methods.  An



acceptable environmentally safe disposal method should be required—




with the method of disposal the responsibility of the generator.



     Safety and security precautions for handling and disposal of




Hazardous Waste are much the same as for the manufacturing facility



that created the waste.   Existing regulations already available



would apply to the disposal operation.



     The State of Texas  passed the Clean Air Act, Solid Waste Act,



and the Water Quality Act which created agencies to establish



guidelines and regulations concerning operations, waste handling,



and disposal.   Included  in these regulations are provisions for



site monitoring, record  keeping, reporting,  performance and



closing of storage and disposal sites.  We suggest no additional



regulations or procedures are needed.





                                   95:

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     Environmental Protection Agency, Department of Transportation,



State and Federal Health Departments, Texas Water Quality Board,




and Air Control Board, Occupational Safety and Health Adm.,  and



other federal,  state,  and local agencies now have regulations



which are already adequate within their area of responsibility.

-------