Solid Waste
Management
Strategy
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste Management Programs
October 31, 1974
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
3 ; 1974
OFFICE OF THE
ADMINISTRATOR
TO: Waste Management and Resource Recovery Officials
The Environmental Protection Agency has been actively engaged
in developing and implementing programs directed toward a goal of
effective solid waste management and resource conservation under
the Solid Waste Disposal Act as amended. We view our activities
and the progress which has been made under this authority to date
as providing the basis for an environmentally sound national solid
waste management program. We believe that a continuation of the
programs begun under the Act is essential to the development and
maintenance of an effective State-Federal partnership in addressing
the solid waste problems we face today and those projected in the
next several years.
We view many of the environmental problems associated with
solid waste disposal as stemming in large measure from practices
of inefficient and wasteful consumption and careless disposal,
symbolized by our "throw-away" style of life. These practices
must be replaced by a more enlightened conservation which includes
reduction in both consumption and waste generation, as well as
increased recycling of wastes.
From our experience with solid waste management, we have become
increasingly aware of the need for national standards and special care
in the management of hazardous wastes. As we learn more about the
components of hazardous wastes and their effects upon man and the
environment, we realize that we can no longer rely on the simple,
customary means of waste treatment and disposal. Based on our
findings in this area, we recognize that comprehensive Federal,
State or local regulations controlling hazardous wastes are required
to bring about a national program for environmentally acceptable
and safe treatment and disposal of hazardous wastes. Our proposed
"Hazardous Waste Management Act," forwarded to the Congress in
February of last year, provided for a strong Federal role in the
identification and issuance of standards for the storage, treatment,
and disposal of hazardous materials.
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This strategy document is part of a management system designed
to serve as a general guide for EPA Headquarters, EPA regional
offices and the States in implementing a coordinated Federal-State
program of Solid Waste Management. It is intended for their use
in setting annual objectives and allocating resources in support of
these objectives. It is meant to ensure that activities undertaken
will conform to this strategy and will be consistent with each other.
As a public statement of EPA's intentions it is intended to serve
as a means of promoting public comment and public participation.
This strategy should be viewed as a dynamic document intended to be
responsive to situations that develop as the Act is implemented.
A further element which we believe is integral to a viable waste
management and resource conservation program is a strong and
effective State and local program. In general, it has been our belief
that State and local programs should be self-financed to ensure that
they are responsive to local needs and to ensure that resources are
allocated in a most efficient manner. However, we have found that
the broad application of new technologies is a new and demanding
responsibility for the States, and that their own resource constraints
have hampered them in initiating and carrying out comprehensive and
effective programs of solid waste disposal and resource recovery.
Greater attention by EPA will be required to assist States and local
governments in meeting these new program demands.
This strategy envisions that the first and most significant role
of State government is the control of all land disposal sites where
any type of wastes are disposed. Further, this strategy relies
heavily on State implementation and envisions a broad State program
which would implement the Federal hazardous waste regulations
and enforcement. The general approach to management of solid
waste is to direct the most severe types of wastes to a few strictly
controlled process/disposal sites, leaving the overwhelming
number of other sites to process/dispose of "other" wastes.
While the program is currently constrained by existing legislation,
the strategy envisions direct Federal regulation and enforcement of
very hazardous wastes, Federal standard setting; and State
implementation of control of "other" hazardous wastes, and State
responsibility for "other" wastes with guidance provided by
Federal guidelines. Finally, this strategy sees the States as a
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catalyst and facilitating agent to bring about increased resource
recovery at the local and regional level. State government, because
of its ability to cross jurisdictional lines, can create the institutional
relationships that will provide a logical balance between recovery and
disposal.
Within the limits of our resources, the Environmental Protection
Agency will assist States in developing their programs to carry out
effective waste management ajid resource recovery programs.
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PREFACE
This first edition of the Solid Waste Strategy has been prepared to assist Federal,
State and local government Officials in understanding EPA's solid waste program and for
the information of the public. This strategy encompasses the activities of all EPA
organizations involved in solid waste related activities, and most activities described will
involve the participation of several offices within EPA. The strategy is designed to provide
a framework for developing and implementing a coordinated Federal-State solid waste
management program which addresses all types of wastes and residuals disposed of on
land. It is recognized that lead activity related to some residuals falls under the aegis of
air or water programs or their respective research counterparts and that these wastes are
covered by other agency strategies in more detail.
On the use of the Strategy, it is emphasized that the Strategy, while based on the
law, is not the law, nor is it a regulation mandated by the law. It is guidance prepared
for use by Government agencies in implementing the Act. It is part of a management
system whose purpose is to insure that program activities, by conforming to a single
strategy, are consistent with each other.
The Strategy Paper is written under the aegis of the Office of Solid Waste
Management Programs in EPA Headquarters. While much of its development has been
within this office, it more fully reflects the work of individuals within all EPA
Headquarters program areas, and the participation of EPA's Regional Offices.
Comments on the Strategy are welcomed. They should be addressed to:
Deputy Assistant Administrator for Solid Waste
Management Programs (AW-5 62)
U.S. Environmental Protection Agency
401 M St., S.W.
Washington, D.C. 20460
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TABLE OF CONTENTS
Page
I. Purpose and Summary 1
II. The Problem 4
III. Major Causes of the Problem 6
IV. Strategic Goals 7
V. Constraints to Strategic Formulation .... 8
Formulation
VI. Tools 9
VII. Discussion of Basic Strategic Approach... 10
VIII. Summary of Programmatic
Implementation 14
Summary of Program Thrust 14
Appendix A. Detailed Discussions on Program
Thrust 16
Appendix B. Environmental, Health, and Safety
Impacts of Improper Waste
Management 26
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SOLID WASTE MANAGEMENT STRATEGY
I. Purpose and Summary
The purpose of this document is to present an EPA solid waste program strategy for FY
1975. This document lays the ground work for guidance to EPA headquarters, EPA
Regions, and to the States. It is meant to ensure that activities undertaken will conform
to this strategy and are consistent with each other. As a statement of EPA's intentions,
this paper is also meant to serve as a means of promoting public awareness, encouraging
public participation and guiding the public on EPA solid waste management policies. The
strategy should be viewed as a dynamic document, intended to be responsive to situations
that develop. It will undergo revision to accommodate new needs, problems, and legislative
thrusts, but the basic philosophy and framework will be continued.
This strategy is designed to encompass the activities of all agency elements involved in
solid waste related activities, and most activities described will involve or require the
participation of several offices within EPA. The strategy is designed to serve as a general
guide for all types of wastes and residuals disposed of on land, but it is recognized that
lead activity related to some residuals falls under the aegis of water or air programs or
their respective research counterparts and that these wastes are covered by other agency
strategies in more detail.
In summary, the major issue being addressed is one of improper waste management,
resulting in problems ranging from extreme health and environmental damages to resource
wastage.
The problem is caused by the fact that improper disposal is cheap compared to
environmentally acceptable practices. Problems tend to result from improper actions over
long periods of time, and result from practices not easily understood or visualized.
Aesthetic damages are easily visualized, and represent varying impacts on human health
or animal life. On the other hand, for example, groundwater contamination which is not
visible can result without a proper understanding and application of the necessary
environmental control procedures.
We know that leachate is formed in land disposal sites and that this liquid enters
groundwater aquifers. As rain water percolates through soil, it is more or less purified
depending on the constituents of the leachate and the type of soil through which it flows.
In areas of high water tables and high precipitation, there is a significant potential for
groundwater contamination. The extent and seriousness of this problem is now being
investigated, but a current presumption of damage exists.
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A number of causes for inadequate waste management have been cited (e.g., municipalities
have no money, technology is inadequate, trained manpower is lacking). However, EPA
believes that these problems could be overcome if a major national commitment were made
to control the adverse effects of waste management. Such a commitment would result in
adequate standards and their vigorous enforcement. In turn, fiscal and other barriers would
fall or be minimized.
EPA has formulated two strategic goals: to achieve acceptable and safe waste
management, and to conserve natural resources. EPA is constrained in effectively
formulating and implementing this strategy primarily by a lack of direct regulatory power
to assure proper land disposal or groundwater quality protection. Authority to set
standards on hazardous wastes has been sought from Congress.
EPA can (1) stimulate regulation by others, (2) provide limited planning support to States,
(3) carry out research, development, and demonstration, and (4) provide technical
assistance.
A. Environmental Protection
The strategy to achieve environmentally acceptable, safe solid waste management relies
primarily on the eventual establishment of a regulatory approach. It is the most direct
attack on environmental, health, and associated problems. The approach is to direct the
most dangerous types of wastes to a limited number of strictly controlled
processing/disposal sites, leaving a larger number of sites to process and dispose of less
hazardous wastes.
This strategy relies heavily on the States. From the State perspective, the problem is one
of land disposal. States generally have the power to issue regulations for all wastes and
all sites and to relate the degree of control to the potential degree of hazard. Typically,
however, States have issued site regulations that prohibit acceptance of hazardous wastes.
The exclusion of certain wastes from disposal sites has virtually resulted in no controls
for these excluded wastes. State enforcement of these regulations is severely hampered by
low resources. A principal objective of the strategy is to strengthen the State role,
particularly with regards to establishing authority over the disposal of all wastes. Adequate
disposal site control also implies control of the movement of at least hazardous waste from
generator to disposal sites lest indiscriminate dumping take place.
The major headquarters thrust will include: developing a data base on hazardous wastes;
demonstration programs to advance certain treatment and disposal methods; developing
a hazardous waste regulatory strategy; augmenting knowledge on the inter-media effects
of land disposal; consolidating technical/economic data on all aspects of solid waste
management; and technical assistance support to improve local practices.
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B. Conservation
The approach to natural resource conservation by waste recovery and source reduction
relies primarily on technical assistance. The primary barriers to waste recovery
implementation are institutional constraints.
The plan is to concentrate on the evaluation and dissemination of information about
existing systems to reduce perceived risk, and on working with communities seriously
considering recovery options, helping them make sound decisions.
Headquarters will conduct a program of studies related to the concept of conservation
through source reduction, primarily addressing benefit/cost trade-offs of economic
product regulation.
Some States have emerged as strong supporters of recovery system implementation,
primarily through the provision of financial assistance. Connecticut has a unique program
in that it addresses institutional problems through a Waste Management Authority. The
Authority puts together a package (site, system, financing backed by State bonding,
contracts with firms to operate the system) for a competitive disposal fee, which covers
the full cost of the system. This concept is attractive for disposal sites, as well as for resource
recovery. The approach is to utilize Federal demonstration funds in one or more States
to stimulate establishment of similar institutions.
C. Regional Activities
The Agency approach anticipates a strengthening of the role of EPA Regional Offices
primarily to (1) provide better and more intensive relationships with States to help achieve
national objectives; (2) to support enforcement efforts by States and to utilize existing
enforcement powers where appropriate, and (3) to become the cutting edge of technical
assistance efforts for waste management and resource recovery.
The headquarters role in support of the regions is to (1) provide policy guidance, (2) assess
specific approaches taken by the Regions; (3) develop the knowledge on the state-of-the-
art of all types of waste management practices; and (4) provide the specialized expertise
for technical assistance.
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D. Basic Strategy Assumptions
The Federal solid waste management program was originally established to improve solid
waste management nationally through research, development, demonstration, training,
and planning activities. The major focus of the program in the 1965-1970 period was on
municipal waste collection, processing, and ultimate disposal activities; and on State, local,
and regional planning. In the 1970-1973 period, the focus was broadened to resource
recovery, support of regulatory activities by States, and investigation of hazardous waste
management problems.
It is assumed that the program will continue to evolve in a generally regulatory direction
related to waste treatment and disposal activities, while in the resource recovery activities
the Federal role will consist of implementation stimulation through technical assistance,
information dissemination, planning activities, and demonstrations.
In FY 1975, the program is expected to operate under an extension of the Solid Waste
Disposal Act, as amended. However, passage of legislation incorporating the provisions
of the proposed Hazardous Waste Management Act is expected ultimately.
II. The Problem
Waste management presents a spectrum of problems, from extreme health and
environmental hazard to municipal management inefficiency. The extremely diverse nature
of the wastes (dead animals, mercury-rich industrial sludges, dredge spoils, abandoned
cars, septic tank pumpings, residential solid waste, infectious hospital wastes, demolition
debris, feedlot wastes, etc.) and their manner of occurrence (in or near concentrations of
population, in rural areas, etc.), means that the dimensions of waste management are very
diverse. Any abstraction of the problem into categories is a dangerous oversimplification.
The problem cannot be disaggregated neatly into "hazardous" and "non-hazardous"
components. Solid waste is not merely residential trash and food wastes. Such an over-
simplification obscures the real situation. The early stress on municipal solid waste (by
the program and by others) was because this waste is most apparent to concerned
environmentalists and is easier to understand than the management of many closely related
industrial, institutional, and agricultural residuals.
The basic problem is improper land disposal of wastes—all wastes—with adverse
environmental consequences. Appendix B provides a more detailed discussion of this
subject. A categorization, recognizing the fact that it oversimplifies the issue, follows:
• Health and Environmental Effects Occur Under Five Headings
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• Health and Environmental Effects Occur Under Five Headings
Water. Ground and surface waters can be polluted by land deposition of wastes. The
problem ranges from contamination of waters by heavy metals and other toxic chemicals
to introduction of organics and soluble gases (CO2).
Air. Air pollution can result from incineration, open burning, or sublimation of chemicals
at land sites; odors are also associated with processing and disposal facilities, especially
with organic waste dumps and lagoons.
Health. Disease vectors arise from improper waste management and waste movement and
disposal. The problem is associated especially with improper storage and collection of
residential wastes in the inner city.
Land Use. Waste disposal alters soil biota and soil chemistry and thus affects future
potential land use. For example, land contaminated by heavy metals cannot be used for
food or feed crop production.
Human Safety is endangered in accidents during waste collection and at land disposal sites
where hazardous wastes are handled. Migration of methane or carbon monoxide from land
sites to confined areas can cause explosion or suffocation respectively.
• Aesthetic and Other Problems also accompany waste management, especially the
following:
Litter, ugly accumulations, and uncontrolled dumping;
Adverse economic impact of disposal sites on land values—due to historically poor practice
in management of disposal sites;
Inequitable population effects—disposal sites typically impact on a small portion of the
population but serve the total population; and
Inefficient management of wastes—which causes higher than required expenditures on this
function by the people.
• Resource Wastage. Waste management is accompanied by little or no materials
or energy recovery because recovery is most often more expensive than simple
dumping. This activity is wasteful so long as simple dumping is an unacceptable
practice for other reasons.
The resource aspect of waste management, however, goes beyond the fact that waste
materials are not usually recovered. Waste generation is itself a symptom of national
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practices that impact on the ability of the economy to supply materials and energy at
requisite levels.
III. Major Causes of the Problem
The chief environmental problems exist for a number of interrelated reasons:
• Regulatory and Enforcement Gaps. Some States do not regulate disposal
effectively and most do not enforce regulations vigorously because of low
manpower resource commitments.
• Resource Allocation. Municipalities do not devote required resources to
environmentally sound disposal and efficient management where such poor
practice is tolerated by an apathetic population or where the impacted population
has no political power.
• Aesthetic vs. Environmental Control. Since litter and ugliness are typically the
most obvious target of popular displeasure, municipalities may manage disposal
"cosmetically" but not environmentally — no blowing paper, no odor, but leachate
into the groundwater — unless environmental regulations are enforced.
• Barriers to Recovery. Poor disposal practice is cheaper than resource recovery,
and the cheap option retards the consideration of recovery or other more
environmentally sound practices. In this connection, however, it should be noted
that recovery today is primarily a residential/commercial waste management
option and not a solution for all types of wastes.
Especially acute is the effect of an absence of regulation in the industrial, and above
all the hazardous waste areas, where the cost differential between dumping and
proper treatment may be twenty-fold or greater. This results in under-utilization
of the private sector industrial waste detoxification, treatment, and disposal
services (the existing, small industrial waste management industry operates at 25
percent capacity).
Typically a number of other "causes" for the problem are cited — e.g.,
municipalities have no money, disposal technology is inadequate, manpower
resources are lacking or poorly trained, consultants are poorly qualified, etc. All
of these are true to some extent somewhere. However, where a community makes
a commitment to control the adverse effects of waste management, such problems
can be overcome.
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Absence of regulatory control (environmental standards, strictly enforced) is due
to some of the following factors:
Ignorance of the Problem. The problem has been identified recently. This is the
case with highly hazardous wastes and with the potential of groundwater
contamination by leachate. General recognition of the special nature of these
wastes or effluents and their adverse effect on life and the environment is a recent
phenomenon.
Absence of Alternatives. Courts or regulatory agencies do not move against
disposal site operators if there is no alternative available. Shut-down of an
operation is impossible politically unless wastes can be placed somewhere else. Site
operators can "blackmail" the public by threatening shut-down rather than
expending resources for upgrading. This problem is closely linked with the next
one, and is probably the chief obstacle to environmentally acceptable waste
management where standards exist but are not enforced.
Public Resistance to Disposal Type Land Use. Public resistance to the siting of
a new disposal site is usually intense and flows from public knowledge of poor
disposal practices in the past and reduction of land values (real or presumed). This
makes creation of alternatives very difficult, prevents institution of the most
economical logistical systems, and thwarts enforcement of regulations where they
are in force.
Imbalance in Power Between States and Large Metropolitan Areas. This
phenomenon sometimes results in enforcement of regulations in small, rural places
by the State but a "hands off' policy vis-a-vis large cities that have political and
fiscal strength.
Absence of Proven/Tested Technology. This phenomenon is applicable especially
for hazardous waste disposal sites. It is difficult to mandate, for instance, the
disposal of pesticides in landfills without hydrological connections unless such
sites exist. It is difficult to establish such sites without the necessary engineering
and testing programs to identify appropriate designs and to ascertain their
viability. To a lesser extent, this issue also retards recovery of some types of
resources — e.g., nonferrous metals and glass.
IV. Strategic Goals
From the problem statement the following goals are formulated for solid waste
management:
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• Achieve acceptable and safe waste management to protect public health and
welfare and the environment.
• Conserve natural resources through institution of resource recovery or by other
means where economically feasible.
Acceptable and safe waste management (for environmental, health, and safety reasons)
necessarily results in the elimination of most site-related land and groundwater pollution,
litter and blight, should improve the land values around disposal sites, will minimize
adverse inter-population effects, and (by imposing higher costs on disposal operators) will
create incentives for fiscal efficiency and other environmentally acceptable options. Road-
side litter, accumulations of abandoned automobiles or other bulky wastes, and similar
littering without a health or environmental impact would not be addressed by this goal.
Resource conservation would be indirectly aided by the achievement of this goal in that
it would raise the costs of disposal and thus make higher cost recovery a better option.
Conservation through recovery and other means, while indirectly supported by
environmental, health, and safety related upgrading of waste management, is singled out
as a national goal because resource recovery is a new activity at this time, not yet a self-
evident waste management option. Institution of recovery systems (or other measures)
will require more than regulatory pressure to achieve. Achievement of the highest feasible
recovery is seen as a worthwhile national goal for national efficiency, strategic, and general
public welfare reasons — to forestall shortages and disruptions attendant on shortages.
Both national goals are appropriate Federal or EPA goals. Environmental and health
protection is the chief mission of EPA. Resource conservation is the mission of the FEA
(for energy) and of Interior (for minerals). Conservation of materials and energy from
waste can and should properly be an EPA mission in that the achievement of such recovery
is inextricably intertwined with considerations of waste management and ultimate disposal
and achievement of environmental and conservation objectives are mutually supportive.
V. Constraints to Strategy Formulation
A. Regulatory Power.
There is no Federal regulatory power directly applicable to all land disposal sites and land
disposal practices. The Federal Water Pollution Control Act does address the issue of land
application systems for the treatment of municipal wastewater. The Clean Air Act is fairly
effective in addressing problems from open burning. But no effectively clear control over
groundwater exists for the many other kinds of wastes and disposal practices. Control over
surface water pollution from disposal sites is weak. Section 209 of the existing Solid Waste
Disposal Act provides the authority to issue guidelines which are mandatory for Federal
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agencies but no one else. Until regulatory power is provided to the Agency, work will be
carried out under the authority and mandates of Section 209.
B. Knowledge.
The extent of systematic knowledge (suitable for broad trade-off analysis and regulatory
program justification) is relatively poor. This is especially true with regard to (1) industrial
hazardous (and not-so-hazardous) waste quantities and compositions as they actually
occur; current data are in the form of chemicals, not chemicals in actual waste streams;
(2) land, air, water inter-media consequences of various types of disposal, (3) the effect
of hazardous and toxic materials on plant and animal life, (4) hazardous waste treatment
and disposal technology, and (5) the qualities, nature, occurrence, and handling methods
related to numerous special wastes not heretofore given priority (crop wastes, animal
wastes, hospital wastes, demolition debris, dredgings, and a variety of nonhazardous or
"situationally" hazardous sludges, (6) treatment and processes of the consequences of the
use of the land as a disposal media, and (7) the costs and benefits of product regulation
for recovery or source reduction.
C. Diversity.
State and municipal government structures, philosophies, and procedures vary greatly
from region to region and within regions. Differences in geography, geology, population
density, and many other factors exist. A uniform strategy for all States or all wastes or
all regions is unrealistic and probably counterproductive.
VI. Tools
Basic tools that could be used to achieve the strategic goals are listed below. Not all of
these are available under existing authorities.
• Regulatory action at various levels (Federal, State, local) including combinations
such as Federal standards, state enforcement, local implementation, etc. This
includes the semi-regulatory use of guidelines and recommended procedures. Land
condemnation procedures would fall into this category.
• Fiscal support such as grants, loans, subsidies, tax credits (to various levels of
government and various types of organizations for a diversity of purposes)
designed primarily to support capital acquisition and/or operations. This category
could include provision of land as a fiscal support mechanism.
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• Research, development, and demonstration, in-house or through contracts and
grants, aimed at systems development and testing and environmental, health, and
safety assessment.
• Technical assistance, consultation, and other forms of communications to transfer
knowledge, to facilitate project or program implementation, to persuade others,
etc.
VII. Discussion of Basic Strategic Approach
A general strategic approach to achieve the two goals formulated above is presented and
discussed here. A program array for the period of this strategy assessment is presented
in the next section.
A. Strategy to Achieve Environmentally Acceptable and Safe Waste Management,
and Protect Public Health
The basic elements to achieve this strategy include:
(1) Regulatory control of waste storage, treatment and disposal.
(2) Mixed Federal and State implementation based on degree of harm associated with
types of wastes.
(3) Program thrust supported by fiscal support to States, R&D, demonstrations and
technical assistance.
(4) Direct regulation and enforcement relative to Federal facilities.
Discussion. A regulatory approach is the single strategy likely to achieve a number of ends
as discussed earlier. If consistently followed over a period of time, it moves toward the
most equitable distribution of the costs of control, provides for maximum participation
by the private sector, provides incentives for efficiency and thus for cost reductions, and
represents the most direct attack on environmental, health, and associated safety problems.
Significant differences in environmental and health damage are associated with types of
waste, from innocuous (glass bottle) to severe (arsenic-containing pesticide). The level of
attention that should be paid by the Federal government to waste management can be
related to the degree of harm involved, the inter-state or national extent of damages
resulting from poor management, etc. Given the ever-present resource constraints it is
logical to some extent to concentrate Federal action in those areas where waste
management problems have the most direct adverse impact.
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General Approach. The approach is to direct the most severe types of wastes to a few,
strictly controlled processing/disposal sites, leaving the overwhelming number of other
sites to process/dispose of other wastes. Thus the above strategy envisions a "cascading"
regulatory strategy with direct Federal regulation and enforcement of very hazardous
wastes, Federal standard-setting and state implementation of other hazardous wastes, and
State responsibility for "other" wastes guided by Federal guidelines.
It is stressed that a clean demarcation between "hazardous" and "non-hazardous" wastes
does not exist except at the extremes of the spectrum. As more experience is gained the
basic strategy is expected to change as well and reflect the gaining of clearer views of the
demarcation.
Federal Facilities. The chief exception to this general strategy is waste management on
Federal facilities which is controlled under Sections 209 and 211 of the Act and Executive
Order 11752. Relative to these sites, the strategy is development and direct enforcement
of Section 209 guidelines (mandatory for Federal agencies) together with the necessary
supporting technical assistance and administrative efforts.
State Role. This strategy relies heavily on State implementation of a Federal hazardous
waste regulatory program and on a vigorous State regulation and enforcement of "other"
waste management. This strategy envisions strengthening the State role through fiscal
support on a flexible basis for both enforcement and for other preparation for a greater
hazardous implementation role. Thus, EPA is attempting to "strengthen the State role"
in all aspects of waste management.
From the State perspective, the problem is one of land disposal. States generally have
authority to promulgate regulations for disposal sites and to relate the degree of regulation
to the potential degree of hazard. Many States have issued regulations only for sites that
receive non-hazardous wastes; a few have regulations promulgated for both. First, States
that do not have the power to issue disposal regulations should acquire that capability.
Second, States that have general authority should issue regulations. Third, States that have
issued regulations should implement them, emphasizing the establishment of hazardous
disposal sites separate from sites for other wastes where needed, available in proximity to
the major waste generators. Thus, to "strengthen the State role" implies more aggressive
use of existing State permit, site approval, and enforcement powers—particularly with
regards to using existing legislation to develop stricter criteria for hazardous waste disposal
sites, distinct from "other" sites. Finally, States must take a more aggressive role in
regulating all sites.
States can get ready for the control of hazardous waste. Current EPA concepts rely on
a waste stream-by-stream approach to direct the worst wastes to selected sites and requires
generators to show the disposition of their wastes. Few States have the authority to place
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similar requirements on generators, and none have implemented authority (although the
NPDES does provide some leverage). States that do not have this power should obtain
authority; those with authority should implement it. As a first step, this approach implies
that States should obtain knowledge of generators of wastes, and present management
practices.
States can act to provide a facilitating role (apart from the incentives which result from
appropriate enforcement) for desirable practices if the State desires—for resource recovery,
hazardous waste disposal, or municipal waste disposal. Actions may include State
involvement in local siting actions, use of State eminent domain powers, implementation
of low cost, self-financing concept. The Connecticut Authority appears to be an attractive
approach to address institutional and financial constraints in disposal, as well as in resource
recovery.
To achieve the strategy, EPA will use its existing authorities to support planning and
demonstration activities at the State level that (a) achieve progress toward hazardous waste
control, (b) increase the pace of standard-setting and enforcement relative to "other"
wastes, and (c) lead to the establishment of facilitating institutions for implementation of
resource recovery and hazardous waste treatment facilities.
It is recognized that the States will require some incentive for stepped-up action. Current
authorities limit the range of Federal influence over State action. However, it is assumed
that a Federal standard-setting role will emerge from the current legislative cycle, which
would require state implementation. Failing that, EPA will depend on persuasion and fiscal
support for carrying out the strategy.
Hazardous Waste Technology and Effects. Because the level of knowledge is very low
about control technology and effects of hazardous wastes, and because the Federal
government will require hard data for standard-setting, a R&D and a demonstration
element is absolutely necessary as a means of developing and justifying standards.
"Other" Wastes. In the "other" waste areas, the level of knowledge about the
environmental and health effects associated with the many waste streams (animal, crop,
and mining wastes; industrial slags; septic wastes; dredge spoils; various sludges and
residues; and urban waste mixed or disposed of in combination with special wastes) is
inadequate—particularly inter-media effects, effects on ground and surface waters,
relationships between types of soils and leachate generation, etc. This strategy envisions
investigations to obtain such understanding to guide better the assessment of Federal
strategies in the future.
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B. Strategy to Conserve Natural Resources by Waste Recovery and Source
Reduction
The basic elements to achieve this strategy include:
(1) Technical assistance to promote implementation of energy and materials recovery
systems.
(2) One-time state recovery program support.
(3) Limited demonstration of technology to enlarge the technical options.
(4) Investigation of cost/benefit aspects of product regulation and other source
reduction methods.
Discussion. The fundamental barriers to implementation of waste recovery are (1)
institutional constraints arising from the need to form novel institutional arrangements
to practice recovery and (2) the high risk associated with full scale demonstration of new
technology, which prevents demonstration of such technology with private or State/local
funds.
EPA analyses indicate that resource recovery is already economically feasible in many
areas, will become more so as regulatory thrusts are initiated, and is not impeded by fiscal
constraints (State, private, and municipal funds are available).
The ability of the consulting community to provide technical aid and consultation is
severely limited — largely by the fact that new systems are proprietary and the basic
information is Federally held (in demonstrations). Thus this strategy envisions a two-fold
thrust — to provide technical assistance to communities and States and to improve the
ability of the consulting community to provide services.
Some States have emerged as strong supporters of recovery system implementation:
Connecticut, for instance, with Federal support, established a state-wide plan, an
independent authority with funding powers ($250 million in bonding authority), and a
strong state regulatory program (to foreclose cheap options). The state-wide scale provided
by such programs, the State financing potentially available after an initial
planning/implementation effort, and the ability to establish large and intelligently located
facilities (that provide needed specialized as well as general purpose facilities) indicates
that the State role in recovery can be strengthened by intelligent use of Federal resources.
Measures to reduce the generation of waste in essence represent changes in products and
distribution systems undertaken either voluntarily or by legislative fiat. Such interventions,
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unless minor, tend to be associated with costs to the economy in terms of disruption (jobs
lost, equipment obsoleted, locational shifts, etc.) and must be carefully weighed against
benefits. The benefits are reduced pollution, conservation of raw materials, and avoidance
or minimization of the disposal function. Because the benefits of reduced consumption
(achieved through less materials-intensive or longer-lived products or through substitution
of reusable for one-time-use products) are very significant, assessment of such conservation
options is a key part of the EPA strategy. However, because of the great variety of products
that must be examined, the approach will be selective, targeted to products or product
categories that promise the most success of achievement at lowest cost.
VIII. Summary of Programmatic Implementation
Through FY 1975, the following program thrusts are envisioned to carry out the strategies
broadly described above. The programs are arranged in order of priority within each major
goal area and are presented in categories that group related activities as closely as possible.
SUMMARY OF PROGRAM THRUST
A. Environmental Protection
1. Prepare for a hazardous waste regulatory role
a. Develop the data base—health/environmental
effects, quantification/qualification of
waste streams, treatment/disposal technology
b. Develop a regulatory strategy—type of standard,
State role, fiscal and land-use issues
c. Strengthen States to implement a hazardous
waste role
d. Implement Section 19, FIFRA
2. Support Federal/State/local efforts
a. Develop technical expertise in special wastes
b. Consolidate/augment technical knowledge or
inter-media effects of land disposal
c. Consolidate/disseminate technical/economic
data on processing and disposal methods
d. Support State regulatory/enforcement programs
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e. Implement Section 209 guidelines at Federal
Facilities
f. Other (complete demonstrations and provide
technical assistance)
B. Resource Conservation
1. Promote implementation of energy recovery from
mixed urban wastes
a. Technical assistance to States, localities,
and the private sector
b. Operation and evaluation of projects—EPA
demonstrations and others—to support TA thrust
c. Support of selected State implementation
programs
d. Identification and demonstration of new
technological concepts
2. Promote materials recovery through technical
assistance and information exchange in the establish-
ment of separate collection/recycling programs
3. Conduct a program of studies related to the concept
of conservation through source reduction
a. Benefit/cost trade-offs of economic product
regulation
b. Development and dissemination of information
to foster voluntary source reduction practices
4. Promote the consumption of secondary materials
through Federal procurement and other actions
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Appendix A
Detailed Discussions of Program Thrust
A. Environmental Protection
Two major activities are envisioned to carry out the strategy: (1) preparation for a
hazardous waste regulatory role and (2) support of Federal, State and local efforts in the
control of other wastes. The major program elements under each activity are listed and
then the activity is discussed.
1. Prepare for a hazardous waste regulatory role.
a. Develop the data base.
b. Develop a regulatory strategy
c. Stregthen States to implement a hazardous waste
regulatory role.
d. Implement Section 19, FIFRA.
Discussion. This is the highest priority activity of the program. The activity array is a
reflection of the current state of knowledge and is designed to prepare EPA to assert
leadership in the hazardous waste management area in an orderly manner as soon as
possible.
Data Base. The level of understanding of the problems and solutions in their various
aspects (quantification, hazard levels, and treatment/disposal technology) is extremely
low. EPA's level of understanding has been over-stated in the past based on incomplete
data; now it has become clear that the program has barely begun to understand the
hazardous waste problem. Consequently, the data base development (which goes far
beyond surveys) is an essential first step toward implementation of a hazardous waste
regulatory program and support of EPA's legislative proposal. This work is essential
regardless of the ultimate Federal strategy adopted.
The data base program includes (1) the scientific work needed to assess hazard of chemicals
and waste streams as an evidentiary base for standard setting, (2) quantification, (3)
technology assessment, development, and demonstration, and (4) the necessary
benefit/cost trade-off analyses for standard setting justification.
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Regulatory Strategy. The proposed HWMA is extremely broad and flexible in the
authorities that it provides. The specifics of standard setting are not spelled out and many
issues are unresolved in the proposed legislation itself as well as in general. Thus, it is
imperative to focus resources on the orderly development of a regulatory strategy to
implement HWMA. This work depends to some extent on data base development (which
is ongoing) but much of it can be carried out in parallel. Major issues that require resolution
include orientation of the regulations (toward waste streams or chemicals or both; toward
processing or disposal or both), the precise nature of the State role, the issue of system
financing, land-use implications of regulations, the issue of "perpetual care," the extent
of Federal enforcement and the trade-offs between Federal financing of State programs
and Federal enforcement resource commitments—to name a few.
State Support. The proposed HWMA requires a major State role in implementation. States
must be prepared to assume responsibility for hazardous waste management. This suggests
the need for a major extension of the current State posture (which is focused toward land
disposal site control). The strategy calls for strengthening the State role. Determination
of precise State action is impossible until major policy issues are decided and the legislation
passes. Thus the intent is to assist States to get ready in the following ways: (1) by using
existing powers to segregate sites, having well controlled sites for hazardous wastes, distinct
from "other" disposal sites, but full control over all sites; (2) by conduct of surveys of
generators of hazardous wastes and establishment of reporting systems; (3) by acquisition
of skilled staff with requisite experience; (4) by identification of potential hazardous waste
disposal/processing sites; and (5) by general purpose procedural, logistical, and fiscal
planning.
To achieve this end, it is essential, first, to ensure a continuing State role in solid waste
management in general and, two, to provide some type of seed money to assist States to
extend their activities into hazardous waste management. EPA will use existing planning
grant and demonstration grant authorities to achieve this end, with the lead assigned to
Regional Offices (see below for a discussion of the RO role).
The need to maintain, as a minimum, a viable State solid waste role is stressed here. From
the State's perspective, hazardous waste management represents a very different and new
approach to the regulation of waste management. In most States, hazardous and other
wastes are disposed of in the same site, and from the State's viewpoint, there is only one
problem—that of disposal.
A State program must have reached a critical mass before the necessary differentiation
between hazardous and non-hazardous waste can be made at the state level. Thus in order
to ensure a viable State hazardous role, it will be necessary in some States to ensure first
a viable solid waste role across the board.
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Section 19, Pesticide Disposal. Under FIFRA as amended, EPA has regulatory authority
over excess pesticides. Regulations and recommended procedures have been published. The
pesticide disposal issue represents, in a microcosm, the hazardous waste disposal problem
and thus affords EPA with a test-bed for exploring the issues and problems of hazardous
waste regulation. Thus implementation of Section 19 supports the Agency's preparation
for a broader regulatory role. The strategy envisions provision of technical assistance to
Regional Offices, States, and disposers and the necessary investigatory, testing, and
demonstration work needed to improve upon the regulations/procedures already
published. It is expected that work under this program element will be widely applicable
for other hazardous waste standard-setting work later.
2. Support efforts in the control of other wastes.
a. Develop technical expertise in special wastes.
b. Consolidate/augment technical knowledge of
inter-media effects of land disposal.
c. Consolidate/disseminate technical/economic
data on processing and disposal methods.
d. Support State regulatory/enforcement programs.
e. Implement Section 209 guidelines at Federal
Facilities.
f. Other
Discussion. The basic strategy related to protection of the environment from the effects
of other wastes is to support efforts by other levels of government and the private sector
through information dissemination, technical assistance and guideline promulgation
drawing upon past and current research, studies, and demonstrations. Relative to Federal
facilities, the strategy also relies on a monitoring and enforcement activity.
The total area of waste management has not been uniformly explored by EPA. Most of
the stress has been on residential and commercial solid wastes. Very little knowledge about
special wastes exists. Therefore EPA also plans to concentrate on these wastes to identify
their degree of hazard, impact on the environment (at various levels of concentration and
in various combinations) in order that a better Federal posture may be developed in
succeeding strategy formulations.
Similarly, groundwater contamination from land disposal sites of all types has only recently
been recognized as a potentially serious problem (by the emergence of several cases of
severe groundwater pollution). Technology for the capture and treatment of leachate is
not proven. The EPA strategy therefore will involve the further quantification and
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assessment of the problem and development/demonstration of leachate collection and
treatment processes.
Special Wastes. As a consequence of Federal research, development, and demonstration,
the state-of-the-art and the state of knowledge in residential and commercial solid waste
collection, processing and disposal has been substantially advanced in the last eight years.
However, national understanding of a wide variety of special wastes is extremely low as
concerns quantities generated, geographical occurrence, damage and hazard, control
methods and costs. Many such wastes can be presumed to have adverse, and possibly
seriously adverse, effects on the environment. It is essential, as part of a national program,
to explore this area in some depth now that what has traditionally been considered the
chief problem in waste management—residential/commercial waste—is better understood.
Emphasis of this exploratory program element will be on the following special wastes:
• Sludges and semi-liquid residuals (e.g., paper plant sludges, waste chemicals,
industrial dyes, tannery wastes, septic tank pumpings, and the like)
• Pollution control residuals, especially new wastes (e.g., sulfur removal system
sludges)
• Dredge spoils
• Animal wastes, especially confined animal raising facility wastes
• Crop wastes, especially where currently open burning is the only "practical"
disposal method
The objective of the program element is to acquire the necessary management know-how
in order to advise States and localities and to determine the level of control (Federal or
other) that should be applied. Guideline promulgation under Section 209 of the current
Act may result from the investigations. The work under this element is also viewed as
supportive of EPA enforcement actions under the 1899 Refuse Act and the Federal Water
Pollution Control Act (PL 92-500).
Land Disposal. The objective of this element is to consolidate, disseminate, and augment
as necessary existing technical knowledge about land disposal—in part as support for EPA
hazardous regulatory work, in part as support of State and local control activities. Too
little is known today about the relationships between such factors as ground and surface
water quality, geology, soil types, precipitation, seasonal factors, population density, and
similar factors on the one hand and waste disposal on the other. A body of information
has been assembled as part of EPA's planning efforts in solid waste and as a result of
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other program activities. This information must be made useful to guide decision-making
at all levels of government, especially in terms of standard setting and cost/benefit
evaluation. Some areas of investigation, especially concerning leachate generation, must
be expanded to establish exact levels of national damage. Leachate collection and treatment
will be evaluated and demonstrated to show methods available for preventing groundwater
pollution at low cost. The results of this work will eventually be promulgated as Section
209 guidelines.
Technical/Economic Data on Processing/Disposal. A very important national support
function to States and localities is the provision of objective, unbiased technical and
economic information to allow appropriate local decision-making. The Federal
government has invested around $50 million in technology development through
demonstrations and studies. One objective of this element is to consolidate and to
disseminate the results of this work. Another is the development of such data about special
waste handling, with emphasis on special disposal methods that are poorly understood,
e.g., deep well disposal. Such study and dissemination activity is a proper national activity
in that at the Federal level significant economies can be achieved and a national perspective
developed. Good technical and cost information is a necessary adjunct of good regulatory
activity (at all levels) and thus directly supports environmental protection objectives.
Under this program element, additional Guidelines under Section 209 of the Act will be
issued.
State Support. As a consequence of Federal will be supported on a limited scale in close
coordination with the hazardous waste thrust as already discussed above.
Federal Activities. Executive Order 11752 and Section 211 of the Solid Waste Disposal Act
make EPA solid waste guidelines mandatory for Federal agencies and all land disposal
activities carried out on Federal land. In essence, these mandates establish a regulatory
program for all types of land disposal at Federal facilities. This program is a high priority
effort by EPA to show leadership by the Federal government to clean up its own activities.
The effort involves (1) administrative and planning efforts to establish a Federal
compliance program, (2) monitoring progress, and (3) providing guidance and technical
assistance to other agencies in implementation.
Other. This activity includes completion and evaluation of currently funded
demonstrations related to land disposal, transportation, and processing. Technical
assistance (TA) will also be provided, but with a changed thrust and focus. Increasingly
TA will be provided from the regional rather than the national office; (recognizing the
limitation, at least through FY 75, of manpower in the Regions). Where TA is provided,
environmental as well as economic improvements will be considered-with the recognition
that the two may be inextricably intertwined or that achievement of an environmental
goal may require technical assistance that saves the recipient money.
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B. Resource Conservation
Four major activities are envisioned to carry out the over-all strategy: (1) promotion of
energy recovery; (2) promotion of materials recovery; (3) studies of conservation through
source reduction measures; and (4) promotion of secondary materials consumption
through Federal activities.
1. Promote implementation of energy recovery (and incidental, related materials
recovery) from mixed urban wastes
a. Technical assistance to states, localities,
and the private sector
b. Operation and evaluation of projects—EPA
demonstrations and others—to support TA
program
c. State implementation program support
d. Identification and demonstration of new
technological concepts
Discussion. The basic rationale for energy recovery from mixed urban wastes has already
been presented. Here it should be noted that this program activity directly supports State
and local regulatory efforts aimed at residential and commercial solid wastes by providing
a viable alternative to land disposal of most of such waste (but note that energy recovery
has not yet been proven as a solution to most industrial residues that are now going to
disposal).
Technical assistance is seen as the best method of implementing energy recovery (which
is typically accompanied by metal and glass separation and recovery). Barriers to energy
recovery are largely institutional—energy recovery requires new types of fiscal, marketing,
management, legal, and technical approaches. Increasingly the technical assistance
delivery function will be transferred to the Regional Offices, while investigatory,
evaluation, and other TA support functions will be maintained in headquarters. Such
support work flows from the operation of EPA demonstrations as well as the evaluation
of projects in which EPA has no financial interest. Results of evaluations will be issued
in the form of guidelines under Section 209 of the Act.
Based on the experience in the State of Connecticut (and in other states as well) the State
can play an important role in making energy recovery happen. The State role, ideally, is
that of the system planner, the source of financing (through bonding authorities), and the
coordinator of state-wide marketing. Strengthening the State role thus appears an
intelligent way to achieve energy recovery. The strategy selected is to provide initial, one-
time funding support to a selected number of States (three to five) to launch state-wide
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recovery programs. This strategy will be implemented as soon as resources allow. The
support would be constrained so that the best possible program—with such features as
an independent but non-regulatory authority; an independent, state-backed fiscal program;
a strong environmental control thrust; and a rational logistical/processing plan (based on
waste-shed or similar concepts)—results from the Federal involvement.
Current activities in energy recovery have been sparked largely by EPA demonstration
of new technology at full scale (begun some years ago~before the energy crisis). The private
sector has shown a willingness and ability to develop prototype technical solutions.
However, industry has been unwilling to invest in full-scale demonstrations while cities
have been equally reluctant to take risks on new technology. They want to see a plant in
operation before investing in the technology for themselves. Thus the EPA demonstration
program has been extremely successful in overcoming risk. A large number of cities are
now actively pursuing implementation of the St. Louis shredded-fuel concept, and two
cities have already committed to move forward with projects. Thus there is evidence that
Federal demonstrations will be implemented by other cities without Federal funding
support.
A Federal demonstration activity is thus seen as desirable to provide demonstration of
improved technology. In the time-frame of this strategy document, it is planned to take
a cautious but positive attitude toward demonstrations (especially in light of six on-going
projects, only two of which are operational at this time). Active identification and
evaluation of new technical concepts will be undertaken. Resources permitting, new
demonstrations may be launched late in FY 1975.
2. Promote materials recovery through technical assistance and information
exchange in the establishment of separate collection/recycling programs
Discussion. Technological processing of waste is only one approach and not suitable to
a number of important waste categories or components. Paper, abandoned automobiles,
rubber tires, and waste oil are best managed as separate streams—paper being source-
segregated as a preliminary to recycling, while the others usually occur in concentrated
form or in isolation from other types of wastes. Recycling of such wastes—especially in
the current shortage situation—is impeded by logistical difficulties rather than weak
markets. Abandoned automobile collection has logistical as well as legal ramifications
(titling laws).
The emphasis will be placed, in this program element, on aiding States, localities, and the
private sector to initiate effective collection programs. This will be accomplished by
evaluating successful programs and by transferring the information to those attempting
to set up new ventures. Priority will be given to paper, an area where the recycling
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technology is well developed and collection system start ups can materially increase
supplies in a shortage situation.
3. Conduct a program of studies related to the concept of conservation through
source reduction
a. Benefit/cost trade-offs of economic
regulation of products to achieve
conservation of materials and energy
b. Development and dissemination of
information to foster voluntary source
reduction practices
Discussion. Source reduction is a conceptually appealing and potentially very conservative
notion. Where it occurs naturally (as a result of shortages or as a consequence of voluntary
citizen buying choice), the result is beneficial from a resource point of vantage and (to a
less certain extent) from an environmental point of vantage as well. However, where source
reduction is achieved by public policy measures—while the same benefits will result—the
issue of costs/ benefits arises.
Source reduction is fundamentally economic regulation to achieve an economic benefit at
an economic cost. There is very little precedent for prohibitory type of economic regulation
of this type—although there are numerous instances of regulation for health and safety
reasons and the provision of positive incentives to promote economic well being (e.g., tax
laws favoring minerals exploration).
Source reduction, thus, represents a new national venture, analogous to current energy
conservation measures, with one notable difference: source reduction is a relatively indirect
approach to conservation in attempts to change product use (thus indirectly impacting
on materials and energy consumption to make the product).
Source reduction approaches can be regulatory, voluntary, or some combination of these
(e.g., voluntary product standards). By the very nature of the subject, different approaches
are applicable and desirable for different products or product categories. In some instances,
legislative solutions may be best; in others voluntary efforts can achieve the same results;
in yet others, a do-nothing approach may be necessary.
The study component of this activity will sort out the cost/benefit issues involved in source
reduction—and will also track the effect of shortages on product use patterns—so that
policy decisions can be made in the future on whether or not to pursue a legislative route
to achieve conservation by product regulation. The information dissemination element
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will be to inform the public about product consumption issues so that voluntary
conservation actions can be taken in light of the best information.
Source reduction efforts are said, by some, to conflict with resource recovery efforts in
that valuable commodities are removed from the waste stream, thereby adversely affecting
the economics of recovery. EPA analyses show that the critical parameter in recovery
system feasibility is the price received for the fuel component of waste (on the order of
$12 per ton in favorable cases); the revenue received for materials is quite low by
comparison (on the order of $2.50 per ton of input). For this reason—and because of much
higher overall resource/energy benefits associated with source reduction, the conflict is
more apparent than real.
4. Promote the consumption of secondary materials through Federal procurement
and other actions
Discussion. This is the continuation of an existing activity, which includes joint projects
with GSA, ICC, DOD, FMC, FTC, and other agencies to re-orient Federal actions that
tend to inhibit secondary materials consumption.
Studies are underway on the potential for secondary materials inclusion in construction
materials and lubricating oils; a joint study with DOT may result in uniform retreaded
tire standards (feasibility is not certain); a study is also underway to examine the potential
for energy recovery from waste at Federal facilities. In addition, various other inter-agency
contacts are being pursued to aid other agencies or to urge their action on such issues as
procurement, labelling, separate collection, packaging re-design, and the like.
It is planned to continue such activities as part of the general resource conservation
strategy.
C. Headquarters and Regional Office Roles
It is the intention of EPA to strengthen the Regional Office role in three areas: (1) imple-
mentation of State programs, (2) creative use of existing Federal regulatory powers, and
(3) delivery of technical assistance. At the same time, it is intended to improve the
headquarters services and technical/scientific/economic support and delivery to the
Regions.
State Programs. The Regional Offices already administer all EPA State programs,
including existing solid waste planning grants (but not State demonstration grants). The
unique ability of the Regional Administrator to coordinate, integrate, and to trade-off
various components of EPA's program support to States should be fully exploited; such
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a stance is also consistent with the recognition that the State programs are very diverse
and require flexible yet cross-EPA management.
The Regions should provide better guidance to State programs and manage EPA solid
waste grants to achieve the overall national policy. The States need to articulate a cogent
solid waste strategy, commit to attaining outputs relating to environmental performance
and commit to applying appropriate inputs (staff, expertise) to solid waste efforts.
Enforcement and/or Assistance in Enforcement. There is no Federal solid waste regulatory
power, but, to a degree, Regions can and should use other legislation—Air, Water, 1899
Refuse Act—to eliminate insults from offensive solid waste practices. Also, the Regions
should offer assistance to States in enforcement actions, particularly where States are
reluctant to act. Finally, Regions should assure that maximum leverage is obtained over
land disposal practices through other permit systems, primarily NPDES, as discussed in
the Water Strategy.
Technical Assistance. Regions now provide a bewildering variety of technical assistance
with commendable results. Ideally, TA services should be available as close to the requestor
as possible and be handled by staff maximally aware of local/regional conditions. To
achieve such a situation, EPA plans, over time, to increase Regional Office TA resources
and to develop appropriate headquarters services to regions to back-up TA delivery.
Specialized TA services would continue to be provided from headquarters, but the general
strategy will be to make the Regional Offices the cutting edge of TA delivery first in non-
hazardous wastes and eventually in hazardous wastes.
In some instances, State leaders and legislatures will need assistance, for instance, to gain
and implement authority for regulatory efforts over a variety of wastes or for establishing
new institutional arrangements to stimulate resource recovery. Other regional assistance
efforts should be directed toward areas where states or others have little expertise—
primarily in hazardous wastes or resource recovery.
D. OSWMP and ORD Roles
It is contemplated that the existing OSWMP/ORD roles would be continued, with ORD
responsible for a program of R&D responsive to OSWMP guidance. The current research
priorities are: (1) hazardous wastes health/environmental effects R&D, (2) hazardous
waste technology R&D, (3) resource recovery R&D, and (4) general land disposal
investigations.
Demonstration work and short-term policy studies will continue to be an OSWMP
responsibility. A detailed guidance document is transmitted to ORD annually.
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Appendix B
Environmental, Health, and Safety Impacts of Improper Waste Management
The purpose of this appendix is to (1) generally describe the problems of improper waste
management as well as possible, given the sparcity of adequate data at this time, and (2)
to describe the efforts being undertaken by EPA to better define the problems. Adverse
impacts have been usually portrayed by examining the potential for damage, by examining
the kinds and types of wastes disposed, and illustrating damages from case histories.
Although a pattern of adverse effects emerges, the magnitude of the impact and its
comparison to other environmental problems has not been well expressed. This appendix
attempts to draw some generalizations that are widely applicable.
A. Waste Volumes
Solid wastes are a disparate collection of unwanted materials—the residues of production
and consumption, solid by-products of removing pollutants from air and water, litter
discarded on the countryside, the "unusable" overburden of mining operations, the
unharvested or inedible remainder of agricultural and animal production activities. Waste
volumes are large, estimated at 4.5 billion tons per year. The management of these volumes
costs approximately $6 billion annually. The following is representative of the kinds and
amounts of wastes which are disposed of, totalling nearly 200 million tons annually.
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Thousand Tons per Year
Mixed municipal wastes 125,000
Pesticides and pesticide containers 150
Waste Oil 2,275
Industrial wastes currently dumped
in the ocean 4,400
Dredge spoils currently dumped in
the ocean 38,428
Explosives 120
Sewage sludges 4,400
Radioactive wastes (solids and liquids) 7
Selected suspended industry solids
currently discharged into the water 1,111
Utility stack sulfur sludges (current
dry weight with ash) 1,824
B. Pollution and Health Damages
Ground and Surface Water Pollution from Waste Disposal.
The most difficult damage to document is the impact on ground and surface waters. Waters
become polluted from leachate generated at a disposal site. The quality, quantity, and
effect of leachate is variable from site to site, and an extrapolation to a national level is
difficult. Some of the more critical variables in the quantity and quality of leachate and
its effects are:
• Composition of waste inputs: Composition affects the quality of leachate, but in
almost all cases the levels of contamination of leachate far exceeds that of ground
water. Certain wastes, namely sludges, are high in moisture content and rich in
heavy metals. The leachate generated from such wastes is obviously very
detrimental.
• Soils: The type of soil and soil depth between the bottom of wastes and the water
table determines the quality and quantity of leachate finally reaching groundwater.
Soil biota act on bacteria and soils absorb heavy metals. The degree of attenuation
is primarily related to the length of time the leachate remains in the soil and the
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exchange capacity of the soil. Leachate passes quickly through sandy soils and
slowly through more clay-like soils.
• Water input to the site: After the landfill has reached its moisture capacity, further
water input will result in an equivalent leachate flow. The amount of water input
to the site depends on a number of variables; the primary one is rainfall.
• Water table: The height of water tables affect the depth of soil available to
attenuate leachate. Water tables vary nationally, location to location, and
seasonally. The direction of flow would indicate where possible damages might
result. In some cases ground water would be discharged into a nearby stream or
swamp; in other cases it could be part of a regional aquifer used as a drinking
water supply. The degree of flow of groundwater near a site affects mixing,
dilution, and the time for it to be cleansed. Groundwater flow may be very slow;
damage may have long term effects.
EPA does not have broad regulatory control over the many wastes and disposal practices
that may affect groundwater. The Federal Water Pollution Control Act does address the
issue of land application systems for the treatment of municipal wastewater. The NPDES
permit system does provide some additional leverage over land disposal practices, but the
degree of control is limited.
The potential damage that may result from contamination of groundwater may be
significant but is not yet known. Half of the population is served by groundwater supplies
for its drinking water. Ninety-five percent of our rural population relies on groundwater
for its drinking supply. Municipal drinking water systems typically rely more on treatment
of surface water than groundwater.
The potential for groundwater contamination by leachate does not occur uniformly across
the nation. For example, most of the West is arid and has generally low water tables. Areas
with greatest potential problems are generally in the Pacific Northwest and all land east
of the Mississippi, with acute problems in coastal areas, and in some States in the Southeast
and Northeast. There are roughly 9000 disposal sites east of the Mississippi, out of a total
of over 15,000 sites nationally.
Based on a limited number of leachate samples examined by ORD, the quality of leachate
is significantly worse than raw sewage or drinking water standards (probably the applicable
comparison, since groundwater has limited dilution/cleansing capacity). For example,
BOD levels of leachate are typically 10,000 - 15,000 ppm, roughly 200 times that of raw
sewage and 15,000 times that for drinking water. Iron content is 1000-10,000 times that
of raw sewage and roughly 20,000 - 200,000 times that for drinking water. Note that these
figures are for leachate from non-hazardous wastes. Over 70 percent of all sites accept
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hazardous wastes; leachates from these sites may be significantly worse. Leachate flow can
be significant. An average site (roughly 20 acres) discharges roughly 20,000 gallons/day,
if the annual net infiltration rate is 12 inches. Sites range up to 300 acres.
Data obtained in 1968 indicate that roughly 20 percent of land disposal sites east of the
Mississippi are in direct contact with groundwater. Thus, discharge from land disposal
sites, even assuming soil attenuation at the majority of sites, is significant.
More than fifty cases of various kinds of damage resulting from waste disposal have been
recently documented by EPA. Several examples of damages are (1) contamination, from
a municipal disposal site, of a drinking water supply serving 40,000 people in Wilmington,
Delaware, (2) stream contamination with PCB's due to dumping directly into a spring in
Tennessee, and (3) cyanide poisoning of animals from wastes dumped in contact with
groundwater in Colorado.
Efforts are now underway to define better the problems resulting from the land disposal
of wastes. The most visible part of this work will consist of the acquisition of leachate
samples and other environmental data from 15 to 20 actual land disposal sites
representative of conditions across the nation. But associated with this work will be
continuation of several other projects carried out by EPA's Office of Solid Waste
Management Programs, and Office of Research and Development.
Air Pollution from Waste Processing or Disposal.
Air pollution results from incineration and from open burning of wastes. In 1968, the
estimate of contribution to air pollution was 8 percent; in 1971 the contribution was
roughly 4 percent, a marked decrease. The contribution from incineration of wastes is
small, less than 1 percent of the total.
Existing incinerators and burning at land disposal sites are subject to controls set forth
in state implementation plans. Incinerators are on a schedule to meet ambient air quality,
as set forth in the plan. Purposeful open burning is prohibited in most areas, although
exceptions may be granted for sparsely populated regions. In addition to compliance
schedules set by implementation plans new incinerators are subject to new source
performance standards under the Clean Air Act.
The most valid measure of the problem is the amount of pollution caused by variances
from implementation plans. These data are not readily available, although known
violations occur and damages do result. For example, air implementation plans can not
prevent "accidental or spontaneous" fires that may occur. One such fire occurred near the
New Jersey Turnpike, added to poor visibility and contributed to numerous collisions
resulting in nine deaths.
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As part of its overall hazardous waste, energy recovery work, and other programs, EPA
is examining the thermal degradation of a number of wastes, or components of wastes
where standards have not been set. Of primary concern is the level of emission of heavy
metal compounds from the incineration of municipal solid waste, water treatment sludges,
and industrial sludges. A special concern is the degradation of other compounds, e.g.,
pesticides, and those resulting from the burning of plastics.
Vectors at Land Disposal Sites.
Vectors (rats, flies, etc.) can find food and harborage from improperly operated landfills.
Under certain climatic and demographic conditions (e.g., desert, sparse population), health
hazards from vectors have not been documented. Under densely populated conditions, they
present a greater menace. Rats seldom travel more than 150 feet from an operating site,
although site closings may cause these rodents to move farther afield in search of new food
sources. There are known cases of rat bites resulting from dump operations (as opposed
to those from improper storage practices). Fly borne diseases are now rare in the United
States, and in an extensive study carried out on behalf of EPA, no such cases of diseases
were found.
Vectors from Improper Storage and/or Collection.
Vectors from improper storage and/or collection mostly affect the inner cores of cities.
The 30 million Americans residing within inner city areas of our cities share their
environment with upwards of 100 million rats. A nationwide study by DHEW indicates
that more than 45,000 people are bitten by rats each year. The majority of those bitten
are small children and the elderly. Rat bites are a traumatic experience and have resulted
in disfigurement, sickness, and death. The prompt and efficient removal of solid waste from
inner city areas is the key to reducing rat populations. An EPA study on inner city
problems showed that residents did not get adequate collection service in some cases, but
that underlying social-economic problems and citizens' personal habits were greater factors
in eliminating health hazards.
Safety at Land Disposal Sites.
Accident hazards exist at land disposal sites. National Safety Council figures show a
frequency of injury in solid waste disposal operations of nine times that of all industry,
and man-hours lost of eight times the average for all industry. The annual totals of deaths
at landfill sites is not known but is likely to be less than 20 deaths. Deaths primarily result
from equipment operator accidents involving exposure to hazardous wastes, especially
flammable chemicals.
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Safety of the Collection of Wastes.
National Safety Council figures show a frequency of injury 11 times and an intensity five
times that of all industry. A study of 30 solid waste organizations found that the direct
and indirect costs of injury may amount to as much as 20 to 25 percent of labor costs in
this labor intensive industy, or potentially $1 billion annually.
Fires resulting from Improper Storage and/or Collection.
The National Fire Prevention Association reports that the total number of fires in the
United States in cities of 25,000 or more for 1972 was 1,050,000. These fires took the lives
of 11,900 persons. No national figures exist for the fires caused by solid waste
accumulations: figures for Washington, D. C. show that 50 percent of fires are related
to solid waste; 50 percent of all fires in New York City are associated with solid waste;
Seattle statistics show that solid waste was the first material ignited in 17 percent of all
fires. From these estimates, a sizeable percentage, perhaps 40 percent of the deaths
resulting from fires, involved unacceptable waste accumulations.
Hazards at Land Disposal Sites.
Hazards caused by improper land disposal sites: 1) reduced visibility from smoke, 2) bird
collisions with aircraft, and 3) explosions or suffocation resulting from the migration of
decomposition gases (methane) or combustion gases (carbon monoxide) to confined areas.
The discussion of air pollution cited the 1973 example of reduced visibility from a burning
dump contributing to poor visibilty which resulted in 9 deaths; in addition, smoke has
contributed to poor visibility at airports (e.g., San Francisco), but has not been blamed
for accidents. Birds attracted by a continuing food supply at a near-by open dump collided
with a landing aircraft in Atlanta in 1973. The aircraft crashed, killing 15 people; similar
cases have occurred in Boston and in Maryland. In 1973, two members of a Pennsylvania
family were killed and others were paralyzed when carbon monoxide from an underground
fire in a dump migrated to their home. The sites east of the Mississippi generate 300 billion
cubic feet of methane annually, a significant explosion potential. (This also represents a
significant opportunity; this is enough energy to supply the natural gas needs for about
1,000,000 homes). Proper design and operating procedures at a land disposal site can
minimize these damages.
C. Aesthetic and Other Damages
Aesthetics.
Measurement of aesthetic degradation is difficult. The problem lies in quantifying how
much litter, for example, detracts from one's enjoyment of a particular landscape or lowers
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the value of the land. Such impacts might be quantified by ascertaining how much people
are willing to pay to avoid the aesthetic degradation of improper waste management. But
difficulties center around the fact that the person who objects to litter is not the one who
litters; or the person who would be willing to pay an equitable share to close an open dump
in his neighborhood is normally not the same as the one whose wastes go into that dump
and who may wish to pay nothing since the problem is not in his neighborhood or
jurisdiction. The best indicator of aesthetic degradation may be the significant level of
interest in measures to prevent such degradation, principally bills to ban one-way beverage
containers or to eliminate unsightly junkyards.
Adverse Economic Impact.
Improper solid waste disposal (principally open dumping) has been demonstrated to have
an adverse economic impact on land values. Although no national figures exist on such
impact, studies in California and Virginia have shown, for example, that the operation of
a sanitary landfill on a specific parcel of land can raise the land's value by as much as
100 percent, depending upon the end-use (e.g., recreation) for which the land is planned
once the fill is completed. Open dumps, on the other hand, were found in the same study
to reduce land values by as much as 90 percent. Land use and conservation of land
resources is clearly a problem connected with the improper management of urban wastes.
In addition to the impact on health, fires result from improper storage of wastes in inner-
city areas. The total damage of all fires in 1972 in cities over 25,000 was over $2 billion.
Solid waste contributed to 40 to 50 percent of these fires, or accounted for an estimated
cost of about $ 1 billion.
Rats also are a cause of property damage. The cost of destruction is in excess of $ 1 billion
each year. Most of this damage is from rats feeding or contaminating stored grain, but
some damage results from improper waste management in inner-city areas.
Inequitable, Inter-personal, and Inter-population Effects.
Like air and water pollution, improper solid waste management also creates inequitable,
inter-personal, and inter-population effects. The person who lives in an area in which
wastes are disposed of in an open dump suffers the costs of that dump. Persons whose
wastes go into that dump do not. This problem is real, and has been the subject of court
suits. A review of these suits clearly indicates that such effects cross local jurisdictional
and State lines. What is more, this impact is normally levelled on poor groups without
political power in their communities. A study for EPA of 83 land disposal sites found a
one-to-one correlation between income/race indices and the quality of disposal sites. Of
the 83 sites studied, 17 were proper sanitary landfills. All were in high income, white areas.
The remaining 66 were open dumps; all were in low income, black neighborhoods.
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Other inequitable effects are found in different levels of collection service between inner-
city poor areas and more well-to-do suburbs. Persons in the inner-city suffer the costs of
inadequate collection but are dependent upon the well-to-do suburbs to help defray the
costs of adequate collection. The well-to-do suburbs, however, receive none of the benefits
of adequate inner-city collection, and hence have demonstrated a remarkable resistance
to help shoulder part of the bill.
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