II I III
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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
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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
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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
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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
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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
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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
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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?
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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,
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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
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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
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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
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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
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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
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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.
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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
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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
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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
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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
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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.
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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
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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
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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
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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
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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.
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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
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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
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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.
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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.
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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.
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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
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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,
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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?
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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
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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.
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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.
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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
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.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
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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
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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
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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.
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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
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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.
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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.
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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
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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.
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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.
-------
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.
-------
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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63
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
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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
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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
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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!
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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
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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
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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
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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
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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-
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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
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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
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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
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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?
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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-
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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
-------
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)
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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
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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
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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
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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
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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)
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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.
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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.
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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
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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
-------
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
-------
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
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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
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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
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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
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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
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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
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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?
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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
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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
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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
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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
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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.)
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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
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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.
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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.
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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.
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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
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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?
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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?
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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
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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.
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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
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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.
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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
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
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
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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
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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
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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
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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
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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.
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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
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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
-------
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
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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
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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
-------
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
%
%
%
%
%
%
%
%
%
%
%
%
%
%
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
-------
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:
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
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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
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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
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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
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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
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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
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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
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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.
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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.
-------
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
-------
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
-------
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
-------
(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
-------
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.
-------
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).
-------
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
-------
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
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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.
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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.
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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
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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.
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
-------
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
-------
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
-------
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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,
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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
-------
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.
-------
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.
-------
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
-------
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
-------
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.
-------
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
-------
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
-------
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.
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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.
-------
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
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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.
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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
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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.
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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
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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
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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
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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
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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.
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
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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
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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
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
-------
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.
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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
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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
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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
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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
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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
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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
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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
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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.
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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.
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(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
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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.
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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.
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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
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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
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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
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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
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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.
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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
-------
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
-------
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
-------
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
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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.
-------
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.
-------
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
-------
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.
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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
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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
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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.
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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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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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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.
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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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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
-------
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
-------
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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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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T*chnicol
Guid«
SW-3
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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Technical
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SW-3
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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TKhnicol
Gu«t<
SW-3
Manufacturing Chemists Association
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.
-------
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
Guid.
SW-3
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
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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
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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
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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.
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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.
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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
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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
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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
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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
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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
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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
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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.
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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.
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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"
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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
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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
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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
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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
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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
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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
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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.
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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.
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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
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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
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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.
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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
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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
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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,
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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
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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
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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
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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
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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
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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.
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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?
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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?
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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
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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.
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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
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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
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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
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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
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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?
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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.
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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.
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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
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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
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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
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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
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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
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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.
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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
-------
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
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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
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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.
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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
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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
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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?
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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
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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
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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
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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
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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
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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
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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.
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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.
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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
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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
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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,
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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
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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
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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.
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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.
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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
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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}
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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.
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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.
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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
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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
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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
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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?
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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
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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
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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
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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
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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
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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
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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
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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,
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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
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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,
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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
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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.
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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
-------
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
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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
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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
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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
-------
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
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
(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
-------
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
-------
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
-------
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.
-------
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 .
-------
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
-------
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,
-------
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
-------
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
-------
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
-------
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
-------
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
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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
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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.
-------
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
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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
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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
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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).
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(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.
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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
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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
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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
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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
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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
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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
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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|
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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
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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
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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.
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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
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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.)
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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.
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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
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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
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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.
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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
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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
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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
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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
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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
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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
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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
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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
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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.
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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
-------
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.
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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.
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