TD788
.W37
1988
United States
Environmental Protection
Agency
November 1988
Washington DC
                      Solid Waste and Emergency Response
                      The Waste System
    OOOK88001

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U.S. Environmental Protection Agency
      Office of Solid Waste and
        Emergency Response
    U S  Environmental Protection Agency
    Region 5, Library (PL-12J)
    77 West Jackson Boutevar.d, 12th Floor
    Chicago, IL  60604-3590

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                     FOREWORD
In June 1987, The Hazardous Waste System report was issued by
the Office of Solid Waste and Emergency Response. The primary
focus of the report was on hazardous waste as defined in the
Resource Conservation and Recovery Act (RCRA) and the Super-
fund program.

This report serves as an update to the original report. In addition
to providing new information on  the current hazardous waste
system, the report includes a discussion of solid waste issues as
well as several upcoming regulations and policies not previously
discussed.

We hope that this report will serve as a starting point for consid-
eration of hazardous and solid waste management issues as well
as focusing on areas that may arise in the reauthorization of the
Hazardous and Solid Waste Amendments.
                                        J. Winston Porter
                                   Assistant Administrator

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               TABLE OF CONTENTS
EXECUTIVE SUMMARY
ES-1
SECTION 1  HAZARDOUS WASTE MANAGEMENT  1-1

            Definitions of Hazardous Waste           1-1
            Generators of Hazardous Waste           1-5
            Geographic Profile of Hazardous Waste
             Managed                             1-7
            Treatment and Disposal Practices         1-12
            - Treatment Technologies               1-13
            - Incineration Technologies              1-16
            - Land Disposal Technologies            1-18

SECTION 2  SOLID WASTE MANAGEMENT         2-1

            Definition of Solid Waste                2-1
            Generators of Solid Waste                2-3
            Geographic Profile of Solid Waste
             Management Facilities                  2-4
            Treatment and Disposal Practices          2-6
            - Landfills                             2-6
            - Incinerators                           2-7
            - Recycling                             2-8
            - Source Reduction                      2-9

SECTION 3  REGULATORY AND POLICY
            IMPLICATIONS                        3-1

            Land Disposal Restrictions               3-1
            - Restrictions                           3-1
            - Technology Standards and Implications    3-3
            - Location Standards                    3-4
            Pollution Prevention Policy               3-5
            Deep-Well Injection Regulation           3-7
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            Domestic Sewage Sludge Regulation        3-8
            Ocean Incineration Regulation            3-10
            Ocean Dumping/Disposal Regulation      3-10
            Medical Wastes                        3-12
            Subtitle D Regulation                    3-14
            Corrective Action Regulations            3-17
            Superfund Off-Site Policy and Clean-Up
             Standards                             3-18
            Emergency Planning and Community
             Right-to-Know (Title III)                3-19
            Redefinition of RCRA Hazardous Waste   3-20
            Superfund State Capacity Assurance Plans  3-20
            Potential Regulatory Impact              3-21

SECTION 4  OUTLOOK FOR THE FUTURE           4-1

            Integrated Waste Management Planning
             is Needed                              4-1
            Successful Siting and Permitting is Needed  4-2
            Recycling, Source Reduction, and Reuse
             Efforts Must be Improved                4-4
            Innovative and Alternative Technologies
             Need to be Developed                   4-5
            More Enforcement is Needed             4-5
APPENDICES
            A. Operating Commercial Incinerator Facilities
            B. Operating Commercial Land Disposal
                Facilities
            C. Commercial Deep-Well Injection Systems
BIBLIOGRAPHY
                          m

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                       EXHIBITS

Exhibit 1    Simplified Waste System Chart	ES-3
Exhibit 2    Sections of Waste System Report	ES-4
Exhibit 3    Volumes of RCRA Hazardous Waste
            Treated and Disposed	ES-5
Exhibit 4    Hazardous Waste Managed by Industry	1-6
Exhibit 5    Hazardous Waste TSDRs and Waste
            Volumes by Geographic Sector	1-8
Exhibit 6    RCRA Hazardous Waste Managed in the U.S.. 1 -9
Exhibit 7    State-By-State Profile of RCRA Hazardous
            Waste Managed, Imported and Exported	1-10
Exhibit 8    Number of Active Facilities by Type of
            Technology	1-12
Exhibit 9    Estimate of Physical Characteristics of RCRA
            Hazardous Wastes	 1-14
Exhibit 10   Treatment Technologies	1-15
Exhibit 11   Incinerator Types and Incinerable Waste
            Descriptions	1-17
Exhibit 12   Number of Land Disposal Facilities by
            Type of Process	1-19
Exhibit 13   Gross Discards of Materials in Municipal
            Solid Waste	2-2
Exhibit 14   Current Municipal Solid Waste Management
            Practices, 1986	2-3
Exhibit 15   Number of Subtitle D Solid Waste Disposal
            Units	2-5
Exhibit 16   Effective Dates of Land Disposal Restriction
            Regulations	3-2
Exhibit 17   HSWA Minimum Technology Requirements.. 3-4
Exhibit 18   Distribution of Municipal Sludge by
            Management Practice	3-9
Exhibit 19   Regulations and Policies and Their Potential
            Effects on Capacity	3-22
Exhibit 20   Potential Capacity Problem Areas	4-3
                           IV

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                EXECUTIVE SUMMARY
This report provides an overview of the country's waste system.
Included are descriptions of the sources and quantities of hazard-
ous and solid wastes and the system for management, treatment,
storage, and disposal (TSD) of these wastes. In addition, a discus-
sion of upcoming regulatory efforts and other potential impacts on
the waste system is provided in this report. It is hoped that this
information will increase public and regulatory awareness of the
cross-media implications of waste management practices.

Several functions are served by this report.

First, the report provides an overview of the hazardous and solid
waste system.  It serves as a beginning reference document for a
more detailed study of the report topics at a later date. Informa-
tion contained in this report can be supplemented by referring to
the documents listed in the Bibliography.

Second, the report  serves as a starting point for the 20 year state
hazardous waste capacity assurance efforts currently being under-
taken by states in accordance with the requirements of the Super-
fund Amendments and Reauthorization Act of 1986 (SARA).

Third, the report offers an integrated approach to waste manage-
ment that  addresses the treatment, storage, and disposal of both
hazardous and solid waste.

Fourth, the report  provides an initial vehicle for discussion of
possible impacts of various EPA regulatory efforts currently
underway with respect to hazardous and solid waste.

Finally, the question of whether there is, in fact,  a "capacity
problem" is addressed in a very preliminary way.
                           ES-1

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Rather than looking at waste issues from a single medium perspec-
tive, this report  examines these issues through an integrated
framework for addressing environmental problems.

The primary focus of this report is hazardous and non-hazardous
solid waste as defined in the Resource Conservation and Recov-
ery Act (RCRA) and by the Superfund program. However, the
waste system does not exist in isolation. It is important to note that
regulation of non-hazardous solid waste differs from regulation of
hazardous solid waste.  Non-hazardous solid waste is managed in
accordance with Subtitle D of RCRA, while hazardous solid waste
is managed  in accordance with  Subtitle C of RCRA.  Further,
Superfund regulates releases of "hazardous substances," which
can encompass both hazardous and non-hazardous solid waste.
These distinctions are explained in more detail in the body of the
report. For purposes of this report, solid wastes that are defined
as hazardous wastes under Subtitle C of RCRA are referred to as
"hazardous waste," and non-hazardous wastes  under Subtitle D
of RCRA are referred to as "solid waste."

An overview of the waste system is provided  in Exhibit 1, the
Waste System Chart.   RCRA and Superfund  wastes are high-
lighted by bold lines. The chart illustrates the relationships among
such items as hazardous wastes, municipal and industrial waste-
waters,  and non-hazardous solid wastes.  This chart  focuses
attention on "where things go" in the waste management process.
By implication,  this chart also demonstrates the various waste
system processes that can be affected by regulatory changes.

It is important to note that Exhibit 1 serves as an overview of the
waste management system and is not intended to deal with every
source or possible exposure route of wastes or  toxic substances.
For example, hazardous air emissions, pesticide applications, and
many "non-point" sources of  pollution are  not included in
Exhibit 1. These sources and others such as wastes discharged to
surface waters through a National Pollutant Discharge Elimina-
tion System (NPDES) permit are not discussed in detail in this
report. However, these wastes could be added to updated versions
of this report.
                           ES-2

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         Exhibit 1.  Simplified Waste System Chart
NM.
BoWlinn r»tof ID RCfw Sublt* C
    d huardouf VMM fytwrn
    soHdw
    RCHASuMUD.
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   ] »CIW3uOltl1gC
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Each section of the report is shown below in Exhibit 2, and is
briefly summarized in the following paragraphs. More detail is
provided in subsequent report sections.

        Exhibit 2. Sections of Waste System Report
       Hazardous Waste
         Management
                      Waste System Report
                       Executive Summary
Regulatory and Policy
    Implications
                   Solid Waste
                   Management
             Outlook for the
                Future
HAZARDOUS WASTE MANAGEMENT

The amount of hazardous waste managed under RCRA totaled
about 275 million metric tons (MMT) in 1985. The overwhelm-
ing majority of this waste, well over 99 percent, was managed by
"large quantity generators" who produced  1,000  kilograms or
more of this waste per month.

Referring again to the bold print portion of Exhibit 1, about 96
percent of all RCRA hazardous waste is managed  at the facility
where the waste was generated (e.g., on-site). The remaining 4
percent goes to off-site commercial treatment and disposal facili-
ties.  An approximate breakdown of the hazardous waste treat-
ment and disposal system follows in Exhibit 3.
                          ES-4

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      Exhibit 3. Volumes of RCRA Hazardous Waste
                   Treated and Disposed
•. % ' V* ' .. ••
y ^
'' ''••' •/ •.
Incineration
Other Treatment
Solvent 6 Other Recovery
Furnaces and Boilers
Land Disposal
Deep-Wall Infection
Total
^
17
2040
•
•
8.0
•

"^Jg-"*1
04
1 6
•
•
50
•

DWfi)
21
2056
57.0
09
130
-250
3036"
 SOURCE: Material Screering Survey, U.S. EPA. Office of Solid Waste (1»M).
 •Breakdown of on-«n» versus ofl-slte waste volumes Is not curranty available
 "Total exceeds 275 MMT as deep-well mjecton. which Is covered under the Sato Drinking Water Act, Is included
 MUT-mlHon metric wet ions per year.
Exhibit 3 relates to about 3,000 facilities which treat, store or dis-
pose of RCRA hazardous waste. There are currently over 175 on-
site incinerators and 16 commercial incinerators.  A list of com-
mercial incinerators is contained in Appendix A of this report. In
addition to incineration, there are many other treatment practices
including biological wastewater treatment, solidification, steam
stripping, and treatment impoundments. Most current treatment
systems consist of on-site  impoundments handling relatively
dilute wastewaters. There are about 320 operating land disposal
facilities,  approximately 49 of which are commercial facilities
which accept a wide range of wastes.  Appendix B of this report
contains a list of commercial operating land disposal facilities.
Finally, while  the majority of deep-well injection systems are
located on-site, a few commercial facilities also use deep-well
injection systems. These facilities are identified in Appendix C of
this report.

SOLID WASTE MANAGEMENT

Non-hazardous solid waste, as defined under RCRA, consists of
many diverse types of wastes including  municipal solid waste,
municipal sewage sludge, industrial and commercial "non-haz-
ardous" waste, as well as some semisolid and liquid wastes.
                            ES-5

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Presently, there are approximately 227,000 Subtitle D solid waste
disposal units which receive solid waste not regulated as hazard-
ous waste under Subtitle C for treatment, storage,  disposal, or
recycling.   These  facilities include surface impoundments,
municipal sewage sludge land application units, and landfills.
Treatment and disposal practices for solid wastes include incin-
eration, recycling, source reduction, and landfilling. Currently,
approximately 6,000 landfills are in operation. However, many of
these landfills are in the process of closing or are nearing capacity.

REGULATORY AND POLICY IMPLICATIONS

Waste management practices are constantly changing due to the
effect of new and proposed statutory and regulatory requirements.
Some of the more significant regulations and policies affecting
waste management are briefly outlined below.  Innovative and
alternative  technologies  are increasingly  being considered to
manage hazardous and solid wastes.

Land Disposal Restrictions

The Hazardous and Solid Waste Amendments of 1984 (HSWA)
require EPA to ban the land disposal of over 400 hazardous
chemicals and waste streams unless the wastes are treated, or it can
be demonstrated that there will be no migration from the disposal
unit as long as the wastes remain hazardous.  EPA  has recently
published land disposal restrictions for some of these wastes. By
1990, EPA will have published  regulations implementing  land
disposal restrictions for all RCRA wastes.  At this time,  it is
difficult to estimate the effect these rules may have on the demand
for additional treatment capacity.

HSWA further established minimum technology standards that
require changes in the way new and existing landfills and surface
impoundments are constructed and operated.

Pollution Prevention Policy

EPA strongly favors preventing the generation of  waste rather
than controlling it after it is generated. EPA's pollution preven-
                          ES-6

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tion program focuses on two main goals: to foster the use of waste
minimization through technology and information exchange, and
to report to Congress  in 1990 on the need for regulations on
pollution prevention.

A significant reduction  in waste volume should be possible
through process changes, product substitution, recycling and
"good housekeeping"  practices. Concerns over economic and
liability issues are already driving firms to reduce the volume and
toxicity of the wastes  they produce.  A number of states have
aggressive waste minimization programs. EPA intends to con-
tinue encouraging such programs.

Deep-Well Injection Regulation

A large amount of dilute hazardous waste (about 20-35 MMTper
year) is disposed of via deep-well injection.   Most deep-well
systems are located on-site and wastes are disposed of at the site
where they are generated.

EPA regulations became effective in August 1988 which restrict
specific hazardous wastes from deep-well injection. These wastes
include certain solvents, dioxins,  "California List" wastes and
first third wastes. However, two year variances were granted for
the underground injection of some of these wastes due to insuffi-
cient incineration capacity to handle these wastes. More wastes
will be restricted in 1989 and 1990 as remaining land disposal
restrictions come into effect.

Domestic Sewage Sludge Regulation

Under the Clean Water Act, municipalities are  required to treat
wastewater before discharging it to surface waters. This treatment
process generates sludge which must be used or disposed. Very
large amounts of non-hazardous sludge are produced each year.
The overwhelming majority of this sludge is landfilled or applied
to the land. RCRA contains an exclusion for mixtures of hazard-
ous wastes and domestic sewage passing through a sewer to a
publicly owned treatment works (POTW) for treatment. The EPA
is scheduled to propose regulations on domestic sewage sludge by
April 1989.
                          ES-7

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Ocean Incineration Regulation

In the early 1980s, EPA proposed regulations that would have
allowed bulk liquid organic hazardous waste to be burned at sea.
However, EPA suspended this program in February 1988.  The
extent to which ocean incineration is used in the future will depend
upon need, cost and environmental considerations.

Ocean Dumping/Disposal Regulation

In November 1988, Congress passed legislation that establishes a
framework  for ending ocean  disposal of sewage sludge and
industrial waste by December 31, 1991. The Agency is currently
in the process of developing proposed regulations, which are
scheduled for publication in the Federal Register in late 1989.

Medical Wastes

Very recently, public attention has been dramatically focused on
problems posed by unregulated medical wastes. Congress has
responded by amending MPRS A and the CWA and by passing the
Medical Waste Tracking Act of 1988 (MWTA).  The amendments
to MPRS A and the CWA pertain to ending the disposal of medical
wastes into territorial seas and internal waters of the U.S. The
MWTS A requires EPA, by May 1,1989, to list medical wastes to
be covered by a program to track listed medical wastes from point
of generation to point of disposal.

Subtitle D Regulations

RCRA Subtitle D establishes  a framework for managing non-
hazardous solid waste. This framework includes voluntary im-
plementation  of solid waste management plans combined with
minimum technical standards established by EPA for new and
existing solid waste management  facilities. EPA strongly sup-
ports  state planning activities for the reduction of solid waste
volume.

EPA proposed new criteria for municipal solid waste landfills in
August, 1988. This criteria established engineering controls and

                          ES-8

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monitoring requirements for improved landfill operation. Cur-
rently, EPA is examining the status of municipal waste combus-
tion ash as well as high volume, low toxicity special wastes such
as mining waste.

Corrective Action Regulations

Corrective action involves taking corrective measures to address
RCRA facilities which have been contaminated from solid waste
management units. Leaking underground storage tanks are an-
other potentially large universe for corrective action.

The volume of contaminated soils and sludges generated from
corrective action cleanups could be large. While most of the waste
will likely be  treated and disposed of on-site, some concentrated
wastes may require off-site handling. These wastes will compete
for existing commercial incineration and land disposal capacity.

The EPA is currently preparing proposed corrective action regu-
lations.  In addition, the Agency is looking into state capability to
implement corrective action requirements.

Superfund Off-Site Policy and Clean-up Standards

The Superfund Amendments and Reauthorization Act of 1986
(SARA) establishes standards for Superfund clean-up actions and
identifies the  conditions for disposing of Superfund wastes off-
site. The impact of these provisions could change the proportions
of hazardous wastes managed on-site and off-site. For example,
new clean-up standards could increase the use of mobile treatment
units and stabilization techniques to manage wastes on-site. Some
of the more  concentrated wastes  will likely  shift off-site for
treatment and disposal.

Furthermore,  the off-site disposal provisions  of  SARA restrict
where Superfund wastes can be taken.  Only those off-site facili-
ties which are in  compliance with  RCRA and the Toxic Sub-
stances Control Act (TSCA) or other applicable Federal require-

                          ES-9

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ments and applicable state requirements are eligible to accept
wastes from Superfund sites.  In addition, the unit receiving
Superfund wastes must not be releasing any hazardous wastes or
hazardous constituents.  In addition, releases from other units at
the facility must be controlled by a corrective action program.
Several Superfund sites have experienced difficulties locating a
commercial facility eligible to  accept their wastes.  However,
these situations have been resolved in relatively short periods of
time as other facilities come into compliance with the off-site
requirements.

Emergency Planning and Community Right-To-Know
 (Title HI)

The Emergency Planning and Community Right-to-Know Act,
created under Title HI of SARA, focuses on improving public
awareness of the presence and release of hazardous and toxic
chemicals in the community. Title in applies to all chemicals
present at a facility in amounts greater than the threshold quantity
established for each chemical under Title in. Four  sections of
Title HI are scheduled to be implemented in accordance with a
phased schedule containing emergency planning provisions, emer-
gency notification requirements, right-to-know reporting require-
ments, and toxic chemical release reporting requirements. The in-
formation obtained from the Tide III reporting requirements will
be used to improve the emergency response planning efforts of
state and local governments.

Redefinition of RCRA Hazardous Waste

Currently, a waste is defined as  hazardous  under RCRA  if it
possesses certain characteristics or is listed in Subpart D, Part 261
of the Code of Federal Regulations (40 CFR).  About half of
RCRA hazardous waste possesses one of the four characteristic
attributes: reactive, ignitable, corrosive, or EP toxic. The other
half of the wastes are "listed" hazardous wastes.

In early  1987, EPA  began examining alternative methods for
defining RCRA hazardous waste.  EPA is considering the use of

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such criteria as waste concentration and management practices to
define such wastes.  Although no  significant change  in the
definition of RCRA hazardous waste is foreseen in the immediate
future, EPA is continuing its investigation of these alternative
methods.

Superfund State Capacity Assurance Plans

SARA provides that EPA shall not provide remedial actions
within any state unless that state assures that it has adequate haz-
ardous waste treatment and disposal capacity for hazardous wastes
generated in the state for the next twenty years. EPA is currently
developing a guidance document  to assist states in preparing
capacity assurance plans.

OUTLOOK FOR THE FUTURE

It is highly likely that the hazardous and solid waste system of
tomorrow will be different than the one of today. Regulatory
impacts, costs of waste disposal, liability considerations, regional
capacity constraints, and waste minimization efforts are already
affecting waste management practices.

A number of factors could affect the volumes of wastes generated
in the future. Factors such as economic and population growth
will influence the  amount  of waste produced annually.  As
industrial production increases, the volume of industrial wastes
produced could also increase.  However, efforts to recycle and
reuse wastes, as well as programs to minimize the amount of waste
generated, are likely to temper increases in waste volumes.

As a result of the regulatory and other factors discussed above, a
number of general  observations about the waste management
system become apparent.

    •   First, there  will be increasing restrictions on land
       disposal without some type of treatment.

    •   Second, hazardous waste treatment and disposal will
       steadily increase in cost.

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   •   Third, it will be important that the impacts of new
       regulations are carefully examined to ensure that
       additional problems are not created.

Having made these observations, let's briefly look at the initial
implications that can be drawn from information provided in this
report. These implications serve as a starting point in identifying
national priorities  as well as focusing on issues of concern to
regions and states. The initial implications of the report are
summarized below.

   •   First, more facilities are needed to incinerate certain
       hazardous wastes.  This need is likely to increase as
       SARA's  remedial action provisions and  RCRA's
       corrective action and land disposal restriction pro-
       grams are implemented.

   •   Second, a better understanding of on-site hazardous
       waste management activities is required.  With 96
       percent of all RCRA  hazardous wastes managed on-
       site, it is important to understand and deal with likely
       industry responses to the various regulatory and other
       impacts.

   •   Third, waste management capacity is largely a re-
       gional and waste-specific issue.  Some states and
       regions have inadequate capacity and must ship their
       wastes to other areas of the country.  Since wastes can
       move freely in interstate commerce, it will be difficult
       to "tie down" specific capacity shortfalls.

   •   Fourth, EPA fully supports the concept of pollution
       prevention through waste minimization, recycling and
       reuse programs. It is far better to reduce the generation
       of hazardous and solid waste than manage waste after
       it is created.

   •   Fifth, there is a recognized need to site and permit new


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       hazardous and solid waste management facilities and
       to expand existing units. This is an important part of
       planning for the future.  The 20 year state capacity
       assurance requirement in SARA is a major step in
       encouraging states to develop new capacity.

   •   Sixth, innovative and alternative technologies need to
       be developed to improve current waste management
       practices. Waste management techniques must con-
       tinually respond to implement these new practices.

   •   Finally, integrated waste management planning is
       vital to ensure that hazardous and solid wastes are
       managed effectively.

This report provides a "big picture" look at emerging hazardous
and solid waste issues. It offers a framework for strategic planning
at the national, regional, and state levels. Furthermore, Exhibit 1
provides a conceptual tool for qualitatively evaluating the interre-
lationships  among various parts of the waste system. However,
for assessing the needs for regional or waste specific capacity,
more detailed information is required  than is presented in this
report.

The information contained in this report is based on existing EPA
surveys and studies as well as in-person interviews with several
major hazardous waste generators and treatment  and disposal
facility operators. Some data are better than others, and not all data
are comparable.  At the conclusion of several on-going EPA and
other studies, more detailed information on hazardous and solid
waste generation, treatment, and disposal will be available.
                          ES-13

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                      SECTION 1

        HAZARDOUS WASTE MANAGEMENT

In 1985, about 275 million metric tons (MMT) of hazardous
waste, as the term is currently defined, were managed in units
regulated under Subtitle C of the Resource Conservation and Re-
covery Act (RCRA).  In this section, the important issue of
hazardous waste definition is  addressed. Also included in this
section is a breakdown of the sources, locations, and quantities of
hazardous waste managed in the RCRA-regulated system. The
types of treatment and disposal technologies  typically used are
also discussed.

DEFINITIONS OF HAZARDOUS WASTE

Defining what constitutes a "hazardous waste" requires consid-
eration of both legal and scientific factors. The basic definitions
used in this report are derived from: The Resource Conservation
and Recovery Act  (RCRA) of 1976, as amended  in 1978,
1980,1986, and by the Hazardous and Solid Waste Amendments
(HSWA) of 1984, and the Comprehensive Environmental Re-
sponse, Compensation and Liability Act (CERCLA) of 1980 as
amended by the  Superfund Amendments and Reauthorization
Act (SARA) of 1986. Within these statutory authorities a distinc-
tion exists between a hazardous waste and a hazardous substance.
The former is regulated under RCRA while the latter is regulated
under the Superfund program.

   Hazardous Waste refers to "...a solid waste, or combina-
   tion of solid wastes, which because of its quantity, concen-
   tration, or physical, chemical, or infectious characteristics
   may..." pose a "substantial present or potential hazard to
   human    health    or   the  environment    when
   improperly...managed..." [RCRA, Section 1004(5)].

Under RCRA regulations, a waste is considered hazardous if it is
reactive, ignitable, corrosive or toxic or if the  waste is listed as a
hazardous waste  in Parts 261.31-33 of the Code  of Federal
Regulations (40 CFR).  Currently, there are about 450 listed
wastes.
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In addition to hazardous wastes defined under RCRA, there are
"hazardous substances" defined by Superfund. Superfund' s defi-
nition of a hazardous substance is broad and grows out of the lists
of hazardous wastes or substances  regulated under the Clean
Water Act (CWA), the Clean Air Act (CAA), the Toxic Sub-
stances Control Act (TSCA), and RCRA. Essentially, Superfund
considers a hazardous substance to be any hazardous substance or
toxic pollutant identified under the CWA and applicable regula-
tions, any hazardous air pollutant listed under the CAA and
applicable regulations, any imminently hazardous chemical for
which a civil action has been brought under TSCA, and any
hazardous waste identified or listed under RCRA and applicable
regulations.

   Hazardous Substance means any substance designated
   in Section 311(b)(2)(A) of the Federal Water Pollution
   Control Act, any hazardous waste having characteristics
   identified or listed in Section 3001 of the Solid Waste Dis-
   posal Act, "any toxic pollutant listed under Section 307(a)
   of the Federal Water Pollution Control Act,... any hazard-
   ous air pollutant listed under Section 112 of the Clear Air
   Act, and... any imminently hazardous chemical substance
   or mixture" with respect to action taken under Section 7 of
   the Toxic Substances Control Act  [CERCLA,  Section
   101(14)].

Accordingly, Superfund encompasses the following numerous
substances:

   •   297 hazardous substances designated under CWA
       Section 3 ll(b)(4)

   •    126 priority pollutants designated under CWA Sec-
       tion 307(a)

   •   8 hazardous substances designated under CAA Sec-
       tion 112

   •    341 hazardous wastes and 110 wastestreams desig-
       nated under  RCRA Section 3001.

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This report focuses primarily on RCRA regulated processes for
treating and disposing of solid and hazardous waste (e.g., incin-
eration, impoundments, chemical and biological treatment tech-
nologies, and land disposal technologies).  The implications of
these processes on the waste system chart are also discussed.
There are, however, other hazardous wastes or toxic substances
which the report does not specifically address.  Examples are:

   •   Wastes from non-point sources (e.g., storm or irriga-
       tion run-off)

   •   Wastes that are exempt from RCRA  management,
       such  as wastewaters treated in enclosed tanks and
       discharged subject to  National Pollutant Discharge
       Elimination System (NPDES) permits

   •   Industrial and domestic wastewaters discharged to
       surface waters under NPDES permits or into under-
       ground injection systems

   •   Agricultural application of pesticides

   •   Polychlorinated biphenyls  (PCBs) that are not mixed
       with hazardous wastes.

Although these wastes are not regulated under RCRA or Super-
fund, these wastes are covered under statutory authorities such as
the Clean Air Act, the Clean Water Act, the Safe Drinking Water
Act, the Toxic Substances Control Act, the Federal Insecticide,
Fungicide and Rodenticide Act, and the Marine Protection, Re-
search, and Sanctuaries Act. The various ways in which these acts
interact with RCRA and Superfund are discussed briefly below.
                           1-3

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The Clean Air Act (C AA), under Section 112, author-
izes EPA to  list various hazardous air pollutants.
Currently included  arc asbestos, beryllium, vinyl
chloride, benzene, arsenic, radionuclides, mercury,
and coke oven emissions. The CAA also sets certain
emission standards for many types of air emission
sources, including RCRA-regulated incinerators and
industrial boilers or furnaces.

The Clean Water Act (CWA) lists substances to be
regulated by effluent limitations over 21 primary in-
dustries. The CWA  substances are incorporated into
both RCRA and CERCLA.  In addition, the CWA
regulates discharges from publicly owned treatment
works (POTWs) to surface waters, and indirect dis-
charges to municipal wastewater treatment systems
(through the pretreatment program). Some hazardous
wastewaters which  would  generally be considered
RCRA regulated wastes are covered under the CWA
because of the use of treatment tanks and a NPDES
permit to dispose of the wastewaters. Sludges from
these tanks, however, are subject to RCRA regulations
when they are removed from these tanks.

The Safe Drinking Water Act (SDWA) regulates
underground  injection systems, including deep-well
injection systems. Prior to underground injection, a
permit must be obtained which will impose conditions
which must be met  to prevent the endangerment  of
underground  sources of drinking water.

The Federal  Insecticide, Fungicide and Rodenti-
cide Act of 1972 (FIFRA) contains registration and
labeling requirements for pesticide products.  The
Agency  must approve any use of a pesticide, and
manufacturers must clearly state the conditions of that
use on the pesticide label.  Some pesticides are listed
hazardous wastes and are subject to RCRA rules when
discarded.
                    1-4

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   •  The Toxic Substances Control Act (TSCA) regu-
      lates the production and distribution of new chemicals
      and governs the manufacture, processing, distribu-
      tion, and use  of existing chemicals.  Among the
      chemicals controlled by TSCA regulations are: PCBs,
      chloroflurocarbons, and asbestos.  In specific cases,
      there is an interface with RCRA regulations.  For
      example, PCB disposal is generally regulated by TSCA.
      However, hazardous wastes mixed with PCBs are
      regulated under RCRA.

   •  The Marine Protection, Research, and Sanctuaries
      Act of 1972 has regulated the transportation of any
      material for ocean disposal and prevents the disposal
      of  any  material in oceans which could affect the
      marine environment.  Recent 1988 amendments will
      end ocean disposal of sewage sludge, industrial waste
      and medical wastes.

In addition, this report does not cover various exposure routes of
hazardous waste, such as air emissions and discharges to surface
waters and POTWs. In addition, this report does not address the
industrial wastes which are exempt from RCRA regulation but
covered under the Clean Water Act. These wastes are typically
treated and then discharged to surface waters under an NPDES
permit.  These are important  considerations which may be ad-
dressed in subsequent updates of this report.

GENERATORS OF HAZARDOUS WASTE

Once a RCRA hazardous waste is generated, it must be managed
(i.e., stored, treated or disposed) in accordance with RCRA
requirements. Currently, there are about 3,000 facilities manag-
ing 275  MMT of RCRA hazardous waste. Generators also pro-
duce over 300 MMT of waste which is exempt under RCRA but
which is regulated by the CWA.

The overwhelming majority of the 275 MMT of RCRA hazardous
waste is produced by large quantity generators.  Large quantity
generators are defined as those firms which produce 1,000 kilo-
                           1-5

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grams or more of hazardous waste per month. These generators
account for 99 percent of the hazardous waste produced and
managed under RCRA.

Furthermore, it is possible to look at the industries that produce
most of the hazardous waste generated each year. The chemical,
petroleum, metals,  and transportation  industries stand out  as
major producers of hazardous waste. Exhibit 4 provides informa-
tion on the number of facilities, the volume of hazardous waste
managed, and the nature of waste handled by major industrial
categories.

    Exhibit 4. Hazardous Waste Managed by Industry
INDUSTRY
Chemical
Fabricated
Metals
Electrical
Equtynent
Petroleum
Refinery
Primary
Metals
Transportation
Equipment
National Security
Other
Total
NUMBER
•OF
FACimES
700
200
240
100
150
150
100
1360
3000
AMOUNT
WASTE
MANA0ED
(MMT)
218
4
1
20
4
3
1
24
275
GENERAL WASTE
DESCRIPTION
Contaminated wastewaters, spent solvent residuals, still bottoms, spent
catalysts, treatment sludges, and filter cakes
Electroplating wastes, sludges contaminated with metals and cyanides,
degreasing solvents
Degreaslng solvents
Leaded tank bottoms, slop oH, emulsion solids, API separator sludge, DAF
float
Pickle liquor, sludge with metal contaminates
Degreasing solvents, metals, sludges
All types of wastes
All types of wastes

 Source- Nalonal Screwing Survey of Hazardous Watt* Treatment, Storage, Disposal and Recycling FacHi«e>, U S EPA. Office
    of Solid WasM. Offlce of Polcy, Plannng and Intomuton. 1986

 A much smaller amount of waste, about one MMT per year, is
 generated by small quantity generators.  These  firms generate
 more than 100 kilograms but less than 1,000 kilograms of hazard-
 ous waste per month. The majority of the 100,000 small quantity
 generators are automotive repair firms, construction firms, laun-
 dromats and dry cleaners, photographic processors, equipment
 repair shops, laboratories, electroplaters and schools.
                            1-6

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Prior to their being regulated in 1984, small quantity generators
could legally dispose of hazardous waste outside of RCRA Sub-
title C regulated facilities. Today, small quantity generators must
treat, store, or dispose of their waste at RCRA Subtitle C facilities.
Most small quantity generators do not manage their own waste but
rely on the services of a commercial facility.

The wastes produced by small quantity generators span the full
spectrum of RCRA hazardous  wastes.  According to EPA's
"National Small Quantity Hazardous Waste Generator Survey,"
over 60 percent of small quantity generator waste is derived from
used lead acid batteries. The remainder includes acids, solvents,
photographic wastes, and dry cleaning residues.

Small quantity generator industries are widely dispersed across
the country. While small quantity generators individually produce
only a small volume of waste, their waste is hazardous and must
be appropriately handled to protect human health and the environ-
ment. Frequently, geographic pockets of small quantity genera-
tors representing a collection of industries are concentrated in a
few city blocks.  While each firm individually generates only a
small volume of waste, collectively these firms may constitute
"hot spots" of hazardous  waste generation.   If  small  firms
discharge their wastes to sewers, the combined industrial dis-
charges from small firms can potentially upset the chemical or
biological treatment processes at POTWs.

GEOGRAPHIC PROFILE OF HAZARDOUS WASTE
MANAGED

Next, let's look at where hazardous wastes are managed. While
most hazardous waste is treated and disposed of at the site where
it is produced, some hazardous waste is transported hundreds of
miles to an incinerator or secure landfill. Because waste is shipped
interstate, it is important to understand where waste is produced in
relation to where it is treated and disposed.  For example, some
states are net importers of hazardous waste (e.g., Alabama and
Louisiana) while other states (e.g., Connecticut, Massachusetts,
and Virginia) are net exporters of hazardous waste.
                           1-7

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As might be expected, the large majority of hazardous waste is
managed in the more highly industrialized areas of the country,
particularly those areas with active chemical and petroleum indus-
tries.  An approximate geographic breakdown by region of the
number of Treatment, Storage, Disposal, and Recycling (TSDR)
facilities, and  the volumes of waste managed, is provided in
Exhibit 5.

  Exhibit 5.  Hazardous Waste TSDRs and Waste Volumes
                  by Geographic Sector
GEOGRAPHIC
SECTOR
Northeast
Southeast
Southwest
Mid-West
Rocky Mountains
Far West
Total
NUMBER OF
TSDR FACILITIES
830
440
390
910
90
340
3,000
QUANTITY OF RCRA
WASTE MANAGED (MMT)
63
84
58
64
1
5
275
 Source: National Screening Survey, U.S. EPA, Office of Solid Waste, 1986.
The exhibits on the following pages illustrate the approximate
geographic breakdown of hazardous waste managed by state.
Exhibit 6 contains estimates of total waste management for each
state, while Exhibit 7 contains information on  the quantity of
RCRA waste generated and managed within each state as well as
the volume of waste exported and imported into each state.
                            1-8

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                  ll  j!
                Hi  1
1-9

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Exhibit 7. State-By-State Profile of RCRA Hazardous
      Waste Managed, Imported and Exported
              (Figures are In thousands of tons)
State
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of
Columbia
Florida
Foreign
Georgia
Guam
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
Quantity of RCRA
Waste Generated
7,403
3
66
57
3,385
295
190

2

834
.
37,325
>1
7
2
2,141
2,518
121
1,325
7,600
12,182
7
698
114
4,077
61
2,507
64
25
543

Shipped Out-ol-State
(Exported)
66
1
16
53
4
22
76
70
2

104

76
.
>1
2
118
695

11
55
103
7
103
157

30
83
44
>1
14
1
Received
{Imported)
146

3
29
33
1
37
9
-

12
-
53
.
-
8
676
162
5
13
55
368

90
17
267

25
10
-
1
3
Quantity of RCRA
Waste Managed
7,556
1
37
716
3,453
153
174

-

666
-
37,319
>1
6
4
2,356
1,873
95
1,325
8,246
12,196
2
602
140
5,537
95
2,449
33
25
5
97
                                              (Continued)
                        1-10

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      Exhibit 7 (cont.).  State-By-State Profile of RCRA
     Hazardous Waste Managed, Imported and Exported
                       (Figures ara In thousand* of tons)
State
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
Total
Quantity of RCRA
Waste Generated
20
8,653
9
444
1,285
3
2,986
1,591
31
31,307
149

5,033
1
33,199
38,006
1,135
10
24,996
338
12,077
85
16
245,128
Shipped Out-of-State
(Exported)
12
311
2
138

3
263

9
261

9
18
>1
53
197

11
108

62
40
>1
3,732
Received
(Imported)
14
152
3
187
25
2
340
56
64
383
.
32
120
>1
24
99
9
>1
19
9
18
20
1
3,627
Quantity of RCRA
Waste Managed
1
8,071
7
10,085
1,416
72
3,852
2,172
28
31,179
130

5,159
.
916
35,011
1,147
1
24,971
460
12,045
105

222,055
Notes: Data were provided by generators and owners and operators of TSD facilities. They
represent the best information currently available on a state-by-state basis. However, these are
subject to change as new data becomes available.

The figures presented in this exhibit are taken from the 1985 Biennial Report which uses a mass
balance approach. Thus, the quantity of hazardous waste managed in TSD facilities in each
state should equal the quantity of hazardous waste generated in each state plus imports minus
exports. However, numbers may differ because of state-by-state variations in the definitions of
wastes generated and wastes managed.

Source: Draft 1985 National Biennial Report of Hazardous Waste Generators and Treatment,
Storage and Disposal Facilities Regulated under RCRA (January, 1988).
                                    1-11

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TREATMENT AND DISPOSAL PRACTICES

The Hazardous Waste System includes about 3,000 facilities that
treat, store, or dispose of RCRA hazardous waste (see Exhibit 8).
Because of economic factors and liability concerns, many firms
prefer to store, treat, and dispose of hazardous waste on-site at the
facility where the waste is generated.  About 96 percent of all
RCRA hazardous waste is managed on-site. The remaining waste
is taken off-site to commercial facilities, which are in the business
of managing other firms' waste. The Hazardous and Solid Waste
Amendments of 1984 (HSW A) favor treatment technologies over
disposal of certain wastes.
     Exhibits.  Number of Active Facilities by Type of
                        Technology
 3,000
                                      Total Number of
                                   Facilities In 1985 = 2959
                                       All Facilities
                                       Commercial Facilities
          Treatment    Storage
 Land
Disposal
Recycling
 Note: Some facilities have more than one process.
 Source: National Screening Survey, U.S. EPA, Office of Solid Waste, 1986.
                           1-12

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Treatment Technologies

Treatment refers to any process, including neutralization, de-
signed to change the character of hazardous waste in order to
render it less hazardous or reduce its volume.  Although most
treatment processes reduce the volume or toxicity of waste,
residuals often result which must be further treated or disposed. A
waste stream may go through several treatment processes to
reduce its toxicity or volume. Typical treatment methods include
incineration, biological and chemical wastewater treatment, steam
stripping, and solidification.  The most widely used treatment
technologies are briefly described below.

    •   Incineration - Used to burn primarily liquid organic
       hazardous waste. In addition, some incinerators  are
       designed to burn solids and sludges as well as liquid
       wastes.  Increasingly, regulatory decisions favor such
       practices as incineration over land disposal of certain
       wastes.

    •   Biological and Chemical Wastewater Treatment - The
       most widely used method of treating aqueous hazard-
       ous waste. Wastewaters are rendered less hazardous
       by biological decomposition, chemical neutralization,
       or precipitation.  Treatment occurs in large settling
       ponds or tanks.  Retention time in the treatment units
       varies from a few hours to several days depending on
       temperatures  and the  types of waste streams.  A
       residual sludge is produced in the treatment process
       which is generally incinerated, treated or land dis-
       posed.

    •   Stream  Stripping Technologies - Used in  treating
       aqueous, hazardous wastewaters.   Hazardous con-
       stituents in the water are converted into gas by means
       of heating.  A non-hazardous gas is then emitted into
       the  air and the hazardous constituents are captured
       through air pollution control equipment.
                           1-13

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   •   Solidification - Involves mixing hazardous waste with
       a stabilizing agent to create a solid or impermeable
       material. The process requires a large area to combine
       the stabilizing agent (e.g., Portland cement) with the
       hazardous waste.  Solidification is most effectively
       used on inorganic sludges.

 Exhibit 9. Estimate of Physical Characteristics of RCRA
                    Hazardous Wastes

 Organic Sludges (2 MMT)	,   ;	 Organic Liquids (4 MMT)
                                    Inorganic Solids (2 MMT)
                                      Inorganic Sludges (15 MMT)
  Source: National Screening Survey. U.S. EPA. 1986.
Understanding the physical  characteristics  of  waste is an
important  element in knowing what treatment and disposal
practices can be use to manage waste.  For each type of waste,
there are appropriate treatment and disposal technologies.  The
physical characteristics of the 275 MMT of RCRA hazardous
wastes managed in 1985 vary from dilute wastewater to metal
bearing sludge to contaminated soil. Over 90 percent (by weight)
of RCRA hazardous waste is in the form of wastewater.

The remaining wastes are organic and inorganic sludges  and
organic and inorganic solids.  Exhibit  9 categorizes hazardous
wastes by their physical characteristics.
                           1-14

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As illustrated in Exhibit 10, for each type of waste there may be
more than one appropriate treatment or disposal technology. The
vast majority of hazardous waste is inorganic liquid waste which
is generally treated in wastewater treatment plants or treatment
impoundments. The waste is  then discharged to surface waters
subject to effluent limitations in NPDES permits.  A residual
sludge is also produced in this process which is generally treated
or stabilized, and then land disposed.

            Exhibit 10. Treatment Technologies
: — . tTlToixiftl. ::•••••••
CHARACTEfllStK^
Organic Liquids (4 MMT)
Inorganic Liquids (252 MMT]
Organic Sludges (2 MMT)
Inorganic Sludges (15 MMT)
Inorganic Solids (2 MMT)

•
o
o
o
o
M.$:
o
•
o
0


o
•
o
o

/-:4';'

o
o
•
o
/•••':':- **

o



  •  Widely Used     Q Sometimes Used
  Source: U.S. EPA, Office of Solid Waste
The volume of incinerated hazardous waste is small and com-
posed mainly of organic liquids and sludges.  However, upcom-
ing regulatory and policy actions may require incineration for
other types of wastes. These additional wastes could include more
sludges and solids, especially contaminated soils. Because of the
strong interest in the incineration of additional wastes and the
restriction on land disposal of certain chemicals, these two tech-
nologies are discussed in more detail in the remainder of this
section.
                           1-15

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Incineration Technologies

This section focuses on the growing importance of incineration in
treating wastes and the types of incinerators operating today. The
vast majority of the 275 MMT of hazardous waste managed
annually is treated in impoundments and wastewater treatment
plants.  A very small amount of  the waste, about 2 MMT, is
presently incinerated.  This incinerated waste is generally low
volume, although highly concentrated or toxic.  However, the
volume of incinerated waste  may increase significantly in  re-
sponse to the land disposal restrictions required under HSWA.

Incinerable wastes range from highly concentrated, organic liq-
uids to sludges and  low concentration,  but hazardous, solids.
Wastes with low levels of metals and high organic content burn
most efficiently. Incineration is used for a specific waste if it is
the most efficient and economically feasible treatment technol-
ogy, or if the waste is restricted from land disposal under the land
disposal restriction regulations.

Incinerable wastes include the following:

    • Organic Sludges                       2 MMT

    • Organic Liquids                       4 MMT

    • Inorganic Sludges, Liquids, and Solids  Unknown
The above wastes are burned in incinerators specifically designed
and permitted to destroy a limited range of wastes. Organic liquid
waste, for example, can be burned in liquid injection incinerators,
rotary kilns, cement kilns, or used as fuel for industrial boilers and
furnaces. Exhibit 11 shows the four major types of incinerators,
the number of incinerators in each category, and the kinds of
waste capable of being incinerated by a specific incinerator design
category.
                           1-16

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   Exhibit 11. Incinerator Types and Incinerable Waste
                       Descriptions
INCINERATOR
DESIGN
Rotary Kiln
Liquid Injection
Fume
Open Hearth
Total
ESTIMATED
NUMBER
OF UNITS
40
95
25
30
190
WASTE DESCRIPTIONS
Liquid sludges, solids, drummed
wastes
Pumpable hazardous wastes,
solids
Liquids
no

Liquids, sludges, and some solids


 Source: U.S. EPA, Office of Solid Waste
Most of the RCRA hazardous waste incinerators operating today
are located on-site.  There are over 175 on-site incinerators that
burn 1.7 MMT of hazardous waste. In contrast, the commercial
sector has 16 incinerators which burn 0.4 MMT of hazardous
waste each year. These units are required to meet air emission and
other performance standards. An incinerator permit restricts the
type of wastes that can be burned in a specific unit. See Appendix
A for a list of commercial incinerators.

While adequate capacity exists for some wastes, it appears that
more commercial incinerators are needed to incinerate other
hazardous wastes. In response to the potential increase in demand
to burn  solids, sludges and other wastes from Superfund clean-
ups, RCRA corrective action measures, and wastes barred from
land disposal  under the land  disposal restriction  regulations,
industry is  looking  into the siting  of new incinerators and the
expansion of existing incinerator capacity.
                           1-17

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Land Disposal Technologies

Having discussed the major hazardous waste treatment technolo-
gies, let's now turn to land disposal technologies.  Historically,
many hazardous wastes were land disposed because landfilling
was an economical and available means to dispose of wastes. As
the land disposal restrictions imposed by HSWA become effec-
tive, the land disposal of certain wastes will be prohibited. Only
wastes that meet specific standards or are treated to meet these
standards will be allowed to be disposed on the land.

Land disposal is the depositing or injecting of solid  or hazardous
wastes on or into the land. A small percentage of the 275 MMT
of hazardous waste generated each  year  is land disposed in
landfills, land farms, or disposal surface impoundments.  Cur-
rently, there are about 320 operating land disposal facilities. The
various kinds of land disposal facilities are briefly described
below:

   •   Landfills - Generally rectangular pits located below
       ground. A permitted hazardous waste landfill must be
       lined with layers of impermeable materials (e.g., syn-
       thetic or  clay liners for new, replacement  or lateral
       expansion units) and have a leachate collection system
       to detect ground-water contamination.  Most residuals
       generated in treatment processes, such as incinerator
       ash or impoundment sludge, are ultimately landfilled.
       Landfills range in size from a few acres to hundreds of
       acres. Currently there are about 70 hazardous waste
       landfills in the country, 33 of which are commercial
       landfills.

   •   Land Treatment - Involves spreading hazardous waste
       on the land. Land treatment, particularly the form of
       treatment referred to as land farming, is most often
       used to dispose organic solids and sludges, such as the
       waste by-products of the petroleum industry.

   •   Deep-Well Injection Systems  - Used to dispose of
       aqueous waste. Approximately 35-50 MMT of dilute,
                           1-18

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       hazardous waste is disposed annually into deep-well
       injection systems.

   •   Surface Impoundments - Used to  treat,  store, and
       dispose of large quantities of aqueous wastes. Surface
       impoundments  vary in size from a  few hundred
       square feet to hundreds of acres.  As  much as 100
       MMT of RCRA hazardous waste may be treated and
       disposed of in these impoundments.  This practice
       handles a large amount of the wastes currently man-
       aged under RCRA. However, many surface impound-
       ments are likely to close by the end of 1988 rather than
       bear the cost of re-design to meet HSWA's minimum
       technology requirements (e.g., a double liner system,
       monitoring wells, leachate collection system and, for
       surface impoundments treating banned wastes, annual
       dredging).

As shown in Exhibit 12, most land disposal facilities are impound-
ments located on-site at the plant.   In  comparison, about 49
commercial facilities have land disposal units and manage 5 MMT

 Exhibit 12.  Number of Land Disposal Facilities by Type of
                          Process
         Deep-Wot  Disposal   LandM
          Injection Impoundment
 Land
Treatment
Wade
 Pile
 Storage   Treatment
Impoundment Impoundment
     Note Some facilities have more than one process
     Source- National Screening Survey, U S EPA, Office of Solid Wane, 1966
     U.S. EPA Office of Solid Waste, 1968, for commercial facfliitoa.
                            1-19

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of hazardous waste.  These units include: landfills, impound-
ments, land treatment, and waste piles. A list of of the commercial
land disposal units is provided in Appendix B.

The nature of the wastes managed at commercial facilities may be
vastly different from that of on-site wastes. Representatives from
the commercial waste management industry indicate that they are
now receiving more concentrated wastes than in the past. This is
because firms are reusing waste, pretreating waste, and sending
less aqueous waste off-site. This trend is likely to continue in the
future as firms minimize the volume of waste they generate and
comply with land disposal restriction regulations.

Since 1984, the number of operating land disposal facilities  has
decreased from 1500 to less than 325 today. UnderHWSA, firms
are required to meet  certain  financial tests and comply with
ground-water monitoring and minimum  technology standards.
Many facilities chose to close rather than meet these standards.

It is believed that many of these facilities were at or near capacity
and many others were small units. While the closing of these
facilities has not significantly  affected current land disposal ca-
pacity, the impact of land disposal restrictions on future land
disposal capacity is uncertain.  In 1988, EPA  estimated that
commercial  landfills had approximately  12 years of useful  life
remaining.
                           1-20

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                      SECTION 2

            SOLID WASTE MANAGEMENT

Management of solid waste differs  from the management of
hazardous waste. In this section, the definition of solid waste is
addressed.  Also included is a breakdown of the sources, loca-
tions, and quantities of solid waste managed  throughout the
United States. Solid waste disposal practices are also discussed.

DEFINITION OF SOLID WASTE*

Defining what constitutes a "solid waste" requires consideration
of technical and regulatory factors.  The basic definition used in
this report is derived from the Resource Conservation and Recov-
ery Act (RCRA) as amended by the Hazardous and Solid Waste
Amendments (HSWA).

   Solid Waste means "any garbage, refuse, sludge from a
   waste treatment plant, water supply treatment plant, or air
   pollution control facility and other discarded material,
   including solid, liquid, semisolid, or contained gaseous
   material resulting from industrial, commercial, mining,
   and agricultural operations, and from community activi-
   ties, but does not include solid or dissolved material in
   domestic sewage...." [RCRA, Section 1004(27)]

Solid waste consists of such diverse items as municipal solid
waste, municipal sewage sludge, industrial and commercial "non-
hazardous" waste, and waste tires. Solid waste also consists of
some semisolid, liquid and contained gaseous wastes that are also
regulated under RCRA Subtitle D.  On January 8, 1988, EPA
published a proposed rule that would exclude from solid waste
regulation certain materials that will be reused or recycled in an
ongoing manufacturing process. However, these materials would
be considered "solid waste" when they are discarded or cease to be
reused in an ongoing manufacturing process.  Solid waste also

Throughout this document, solid waste refers to non-hazardous materials.

                           2-1

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consists of such special wastes as infectious waste, construction
waste, household hazardous waste, oil and gas waste, and large
volume wastes such as mining waste.

The composition and volume of solid waste is affected by such
factors as population increases, economics, and technological and
social factors. EPA studies have revealed that more than 11 billion
tons of solid waste are generated each year. A large portion of
solid waste consists of municipal solid waste, with approximately
158 million tons of municipal solid waste generated in 1986. The
annual production of such waste is expected to increase to 193
million tons by the year 2000.

A breakdown of the  changing  composition of municipal solid
waste is provided in Exhibit 13.  Since 1970, the amount of
plastics, many of which are currently non-recyclable, in munici-
pal solid waste has increased from approximately 3% in  1970 to
approximately 7% in 1986. Also, paper products and yard wastes
made up about 56% of municipal solid waste in 1986.

                       Exhibit 13.
   Gross Discards of Materials in Municipal Solid Waste
                    (in Millions of Tons)
Materials                        1970  1986   2000
Paper and paperboard              36.5   50.1    66.0
Glass                             12.5   11.8    12.0
Metals                            13.5   12.6    14.4
Plastics                            3.0   10.3    15.6
Rubber, leather, textiles, wood       9.0   12.5    13.2
Food wastes                       12.8   12.5    12.3
Other nonfood product waste         0.1    0.1     0.1
Yard wastes                       23.2   28.3    32.0
Misc. inorganics                    1.9    2.6     3.2

Totals                           112.5  140.8   168.8
 Source: Characterization of Municipal Solid Waste in the United
 States, 1960 - 2000, U.S. EPA, Office of Solid Waste, 1986 and
 updated Draft Report, 1988.
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The primary treatment and disposal methods for municipal solid
waste include use of landfills and incinerators as well as recycling
efforts. Exhibit 14 contains an analysis of the use of these meth-
ods in 1986.

                       Exhibit 14.
  Current Municipal Solid Waste Management Practices,
                          1986

                                  Million
                                  ton/Yr        %
Landfilling, other                     126         80
Incineration with energy recovery       10          6
Incineration without energy recovery     5          3
Materials recycling                   17         11

Total                               158        100

Source: Characterization of Municipal Solid Waste in the
United States, 1960 - 2000, U.S. EPA, Office of Solid Waste,
1986 and updated Draft Report, 1988.

The Agency has determined that a comprehensive solid waste
management system includes the use of source reduction, recy-
cling and incineration, as well as the safe use of landfills. The
Agency has established the goal of 25% source reduction and
recycling by 1992. Increased source reduction and recycling will
reduce the volume of the waste which requires incineration or
disposal in landfills. Other methods to achieve this goal include
improved waste treatment and disposal methods and proper waste
management.

GENERATORS  OF SOLID WASTE

Generators of solid waste vary. Municipal solid waste is gener-
ated by businesses and residents within the community as well as
by the municipality itself in running the operations of the commu-
nity.  Other generators  of solid waste include commercial and
industrial facilities.

Municipal solid waste can contain small quantities of hazardous
materials.  Most of these materials are derived from household
wastes or produced by commercial generators that dispose of less
than 100 kilograms per month of hazardous waste.
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Household hazardous waste consists of such items as some
cleaning  agents, lawn products, batteries, electronic devices,
automotive products, and home maintenance items. Small quan-
tity generator waste consists of such items as paint wastes, acids,
photographic wastes, pesticides and dry cleaning residues.

Many states and communities are implementing household haz-
ardous waste collection programs to collect and properly dispose
of such waste. This is done in an effort to keep such waste out of
the municipal solid waste stream.

GEOGRAPHIC PROFILE OF SOLID WASTE
MANAGEMENT FACILITIES

Presently, there are approximately 227,000 Subtitle D solid waste
disposal  units located throughout the United States.  Of these
units, 84% are surface impoundments, 8% are primarily munici-
pal sewage sludge land application units, 6% are landfills and 2%
are waste piles. An approximate geographic breakdown of the
number of Subtitle D solid waste disposal units located within
each state is contained in Exhibit 15.

With regard to municipal solid waste landfills, every State has
minimum technology  standards  for the operation and mainte-
nance of such facilities.  Additional state requirements are as
follows:

   •   44 States and territories have implemented landfill
       location standards

   •   51 States and territories have closure and 42 have post
       closure care requirements

   •   42 States and territories require ground-water moni-
       toring

   •   23 States and territories require leachate monitoring

   •   10 States require surface water monitoring

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                                2-5

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Solid waste disposal capacity is declining in many areas of the
country, particularly in the Northeast and other areas with high
population densities. States such as Connecticut, Massachusetts
and Florida are rapidly running out of landfill space. The siting of
new  Subtitle D disposal facilities is necessary to provide future
disposal capacity.

TREATMENT AND DISPOSAL PRACTICES

The solid waste universe includes approximately 227,000 facili-
ties that receive solid waste for treatment, disposal or recycling.
In this section, solid waste capacity as well as the various types of
solid waste treatment and disposal practices are briefly discussed.

Landfills

Landfills have historically been the least expensive way to dispose
of solid waste. Approximately 83% of the municipal solid waste
that is produced is deposited in landfills.

A study of municipal solid waste landfills demonstrated that such
landfills receive household waste (72%), commercial waste (19%),
construction/demolition waste (6%), and other wastes such as
sewage sludge and industrial wastes (3%). Safe landfill manage-
ment techniques include the use of liners; application of cover ma-
terials; leachate collection, removal and treatment; ground-water
monitoring; and control over the materials placed in the landfill.

Landfill capacity throughout the United States is rapidly declin-
ing. Currently, approximately 6,000 operating municipal landfills
exist throughout the United States. Many of these landfills are in
the process of closing.  This decline has occurred despite the con-
tinued increase in the amount of solid waste produced annually.
The Agency anticipates that as many as 27 States may run out of
landfill capacity for municipal solid waste within the next five
years, with 70% of all municipal landfills expected to close within
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15 years. Currently, approximately  184 landfills are either pro-
posed or final sites on the National Priorities List (NPL) for
Superfund cleanup.

With declining landfill disposal capacity, many communities and
solid waste haulers must transport municipal waste great distances
to dispose of the waste. This has resulted in increased disposal
costs for many communities.  The siting of new facilities to
dispose of municipal waste will be a key factor in easing the
municipal solid waste disposal crisis.

Of major concern to the Agency is the leachate that results from
the mixing of materials in the landfill with rain water and other
liquids within the landfill. The Agency is also concerned with the
production of methane gas, which is generated naturally in most
landfills. Landfill operators must ensure proper ventilation and
control to prevent underground fires or explosions which can
result from methane gas accumulation. Many operators collect
and sell the methane gas.

Incinerators

Municipal waste combustors  are used to burn municipal solid
waste.  Most solid  waste incinerators are resource recovery or
waste-to-energy facilities that convert the heat generated from the
burning waste into either electricity or steam. Approximately 140
incinerators either exist in or are planned for 38 States at present.
Of these facilities, 91 result in energy recovery from the burning
waste. The volume of municipal solid waste that is incinerated is
expected to increase from 10% in 1986 to approximately 20% by
the year 1992.  In many situations,  incineration reduces the
volume of solid waste by up to 90%.

In July, 1987, the Agency issued a Report to Congress on resource
recovery facility  emissions.  The Agency  concluded that the
following mix of controls would ensure the safe operation of such
facilities:  scrubbers, paniculate matter collection, and proper
combustion.
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Approximately 30 million tons of the municipal solid waste
generated annually can not be incinerated. Such materials include
construction waste, stones, concrete, old appliances, and bricks.

The siting of solid waste incinerators has been affected by air
pollution concerns.  Air emissions from such facilities are cur-
rently regulated under the Clean Air Act.  Incinerator siting has
also been affected by concerns over the characteristics of the ash
that remains after incineration of materials.

Recycling

Recycling involves separating reusable materials such as glass,
metals, and paper from solid waste. The recyclable materials are
then processed and returned to the economy as parts of other
products.

Recycling and source separation techniques are used to reduce the
volume of solid waste requiring either landfill disposal or incin-
eration. In addition, recycling reduces the need for raw materials
and thereby conserves natural resources. In 1986, approximately
10% of the municipal solid waste stream was recycled. Approxi-
mately 80% of the material recycled in 1986 constituted newspa-
pers, corrugated cardboard and office paper. Glass bottles and
aluminum cans also play a role in municipal sou'd waste recycling.
Also, the recycling of plastics is increasing.

Many States and communities are implementing mandatory as
well as voluntary recycling programs.  Such programs often
include the curb-side pick up of recyclable materials. The success
of these programs has varied.  However, programs in New Jersey
and Oregon have resulted in the recycling of approximately 20%
of the waste stream. In addition, programs in such cities as Seattle,
San Jose and San Francisco have resulted in the recycling of over
20% of the waste stream. Ten States  have so-called "bottle bill"
laws that require refunds to be issued for the return of beverage
containers. These laws promote the recycling and reuse of such
containers.
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The issue faced by many in the recycling industry is the changing
demand for materials recovered through recycling. This results in
price fluctuations for such materials. Another issue is the diffi-
culty of recycling several materials, such as some plastics and
mixed materials.

Source Reduction

Source reduction involves the management of materials before
end disposal to reduce the volume and toxicity of such materials.
Source reduction can  effectively increase the useful  life  of
landfills as well as reduce the toxicity of waste streams destined
for incineration or disposal.

Many manufacturers substitute alternative materials as a source
reduction measure either to reduce the amount of waste produced
during the manufacturing process or to create a product that can be
easily disposed of after consumer use. Source separation and the
redesign of product packaging are also being used to reduce the
amount of wastes that require disposal.

Economic factors such as increasing waste disposal costs have
significantly increased  source reduction  efforts.  The need for
increased waste disposal capacity has also influenced  source
reduction measures.
                           2-9

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                      SECTION 3

    REGULATORY AND POLICY IMPLICATIONS

There are a number of upcoming regulatory and policy initiatives
which will change the way hazardous waste is currently managed.
Many of these changes were mandated in the Hazardous and Solid
Waste Amendments (HSWA) and the Superfund Amendments
and Reauthorization Act (SARA).

These regulatory and policy initiatives are in various stages of
development and their potential effects can only be estimated.
This section outlines the issues and the potential implications of
twelve proposed statutory and regulatory initiatives. The majority
of the regulations and policies discussed in this section were
mandated under RCR A. In addition, this section includes a discus-
sion of several regulations and policies mandated under Super-
fund.

For more detailed information on a specific area discussed in this
section, refer to the "Bibliography" listed in the Appendix of this
report.

LAND DISPOSAL RESTRICTIONS

Restrictions

The Hazardous and Solid Waste Amendments use a phased
approach to prohibit the land disposal of all  untreated hazardous
wastes.  By 1990, any waste listed as hazardous on the date of
enactment of HSWA will be prohibited from land disposal unless:
(1) EPA has published treatment standards for the waste or (2) a
petition has been approved that demonstrates that there will be no
migration of hazardous constituents from the disposal unit for as
long as the waste remains hazardous. EPA must set treatment
standards for wastes listed after the date of enactment of HSWA
within six months of listing; however, ao automatic prohibitions
apply to these wastes. Exhibit 16 contains the effective dates of the
land disposal restriction regulations by waste category.

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  Exhibit 16. Effective Dates of Land Disposal Restriction
                       Regulations
. 
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All other listed hazardous wastes (approximately 450) were
divided into thirds based on volume and toxicity. Treatment
standards for certain of the "First Third" wastes were promulgated
on August 8,1988. Wastes in the First Third schedule for which
the Agency did not set treatment standards may continue to be land
disposed, under certain circumstances, until EPA sets treatment
standards or until May 8,1990, whichever is earlier. However, the
treatment standards specified in this rule do not apply to First
Third wastes disposed by deep-well injection. It currently appears
that insufficient capacity may exist to treat some of these wastes.
The Agency therefore granted a two-year variance for some of the
high volume wastes without adequate disposal capacity.

The full impact of land disposal restrictions on treatment capacity
is uncertain at present.  It is anticipated that use of incineration
techniques will increase as a result of the treatment requirements
of the land disposal restriction regulations. Stabilization of metal
containing wastes will also increase.

Technology Standards and Implications

HSWA's minimum technology standards require improving the
ways existing and new landfills and surface impoundments are
constructed and operated. These standards include: installing two
or more liners, a leachate collection system, and a ground-water
monitoring system. Also, EPA regulations require firms to meet
certain financial tests for liability coverage. Wastes that have been
granted capacity variances under the land disposal restriction
regulations can only be disposed in facilities that meet the mini-
mum technology requirements.  Exhibit 17 illustrates the specific
minimum technology requirements for surface  impoundments
and landfills.
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 Exhibit 17.  HSVVA Minimum Technology Requirements
TYPE OF UNIT
SURFACE
IMPOUNDMENTS
LANDFILLS
STATUS Of UNIT
NEW UNITS
• 2 or more liners
• Leachate collection system
between liners
• Ground water monitoring system
• 2 liners
• Leachate collection system
above too liner and between
liners
• Ground water monitoring system
EXISTING UNITS

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that will impact the types of treatment technologies that can be
utilized at each site. New location standards could also require
corrective action measures to be implemented at existing land dis-
posal facilities.

POLLUTION PREVENTION POLICY

EPA strongly favors preventing the generation of waste rather
than controlling waste after it is generated. It is a national policy
that the generation of hazardous waste be reduced or eliminated as
expeditiously as possible. EPA's  pollution prevention program
has two main objectives. First, to foster source reduction through
technology and information dissemination, and second, to report
to Congress by 1990 on the need for regulations on waste minimi-
zation.

The 275  MMTs  of hazardous waste managed annually in the
United States is expected to increase unless firms adopt  serious
waste reduction and recycling programs.  At present, the 1984
Hazardous and Solid Waste Amendments to RCRA outline three
statutory requirements relating to  pollution prevention. The re-
quirements are summarized below:

   •   Generators must certify on their manifests that they
       have a  program in place to reduce the volume and
       toxicity of wastes [Section 3002(b)].

   •   Any treatment, storage or disposal permit issued after
       September 1,1985 must include a waste minimization
       certification statement [Section 3005(h)].

   •   As part of the generator's biennial report, generators
       must describe the efforts undertaken during the year to
       reduce  the volume and toxicity of waste  generated
       [Section 3002(a)(6)] and document actual reduction
       achieved.
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Within the private sector, strong incentives already exist to
promote a pollution prevention program. These incentives in-
clude:

   •   High costs of corrective action at current facilities

   •   Large increases in the price of treating and disposing
       of hazardous wastes

   •   Difficulties in siting and permitting new facilities

   •   Concern  with  liability associated with managing
       hazardous waste

   •   Public pressure on industry to reduce waste generation

A few states currently either require or promote a policy that
encourages pollution prevention. Many firms are already work-
ing towards reducing the amount of  hazardous waste produced
through a variety of waste minimization techniques, including:

   •   Process modification

   •   Input material substitutes

   •   Recycling

   •   Technology modification

   •   Product substitution

EPA's pollution prevention program focuses on addressing multi-
media opportunities to minimize wastes through research  and
technology transfer, an information clearinghouse, a national data
base and support for state programs.  The Agency has recently
established the Office of Pollution Prevention to coordinate such
efforts among EPA programs.
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In conclusion, economic and liability issues are driving a reduc-
tion in the volume and toxicity of hazardous wastes generated. As
a pollution prevention technique, source reduction can alleviate
the capacity problem by reducing the volume of waste requiring
costly treatment and disposal.

DEEP-WELL INJECTION REGULATION

Over 1,000 MMT of dilute, aqueous wastes are deep-well injected
each year. About 35-50 MMT of this  waste may be RCRA
hazardous wastes.

The majority of deep-wells are located on-site so  that wastes are
disposed of at the plant where they are generated. A small number
of commercial firms operate deep-well systems (refer to Appen-
dix C for a list of deep-well injection systems). Most deep-well
systems are  concentrated along  the Gulf Coast of Texas and
Louisiana.

The Hazardous and Solid Waste Amendments (HSWA) required
EPA to determine by August 8,1988 whether to further restrict the
deep-well injection of hazardous wastes.  On August 27, 1987,
EPA outlined plans for prohibiting the underground injection of
certain solvents, dioxins, and California List wastes under the
Land Disposal Restriction regulations. On July 26,1988, EPA
promulgated the framework for implementing land disposal re-
strictions for the underground injection of these wastes. A final
rule establishing effective dates for land disposal restrictions on
the underground injection of California List wastes and certain
first third wastes became effective August 8,1988. Specifically,
this rule prohibits the underground injection of PCBs and concen-
trated HOC wastes. However, this rule grants a two year extension
for the underground injection of certain cyanides, metals, corro-
sives, dilute  HOCs, and chromium wastes due  to insufficient
alternative capacity to treat the wastes. Additional wastes will be
restricted in 1989 and 1990.

If deep-well injection  were prohibited, most of these wastes
would probably shift to wastewater treatment plants.  Firms could
                           3-7

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obtain  or modify NPDES permits in order to discharge treated
wastes from a wastewater treatment plant to surface waters. Some
of these wastes may also be discharged to sewers, treated at
POTWs and then discharged to surface waters. It is likely that
most firms would continue to treat their waste on-site rather than
transport large volumes of dilute, aqueous waste to a commercial
facility.

In summary, large volumes of RCRA hazardous and non-hazard-
ous wastewaters are currently deep-well injected. Making deep-
well injection regulations more stringent may affect wastewater
treatment capacity.  There is  likely to be minimal impact on
incineration capacity because it is usually not economically fea-
sible to incinerate dilute, aqueous wastes.

DOMESTIC SEWAGE SLUDGE REGULATION

The Clean Water Act requires municipalities to treat wastewater
to meet discharge standards, before discharging it to surface wa-
ters. Each year, approximately 37 billion metric tons of municipal
(domestic)  and industrial wastewaters are treated in  POTWs.

In treating these wastes to meet discharge standards, vast quanti-
ties of sludges are generated which can contain varying amounts
of toxic pollutants. The quantity of municipal wastewater treat-
ment sludges produced annually has almost doubled over the past
15 years. Municipalities now generate about 7.7 million metric
tons of sewage sludge a year, the majority of which is landfilled
or applied  to the land.   Exhibit 18 shows the proportions of
municipal sludge managed by type of management practice.
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                       Exhibit 18.
Distribution of Municipal Sludge by Management Practice
          Landfllllng
                                             Ocean
                                             Disposal
       Distribution l^S\.  /     16%    \     /    Incineration
       Marketing
                   \	\v
                                Land Applications
       Source: U.S. EPA. Office of Water, 1988

By the year 2000, municipal sludge production is expected to
increase to 12 million dry metric tons a year.  This  increase is
attributed to (1) a growing population, and (2) more advanced
wastewater treatment systems which remove more pollutants and,
therefore, generate more sludges. During this same period, more
municipal landfills are expected to close. This may place greater
demand on other sludge disposal practices.

In a February, 1986, "Report to Congress on the Discharge of Haz-
ardous Wastes to Publicly Owned Treatment Works," the Agency
recommended that the RCRA exemption for regulating hazardous
wastes which mix with domestic sewage sludge discharged to
POTWs be continued.  The report also indicated that improve-
ments were needed to ensure pretreatment of industrial hazard-
ous wastes. EPA expects  to publish regulations to carry out this
recommendation.

There is increasing concern that some hazardous wastes, which
are prohibited from land disposal under HS WA, may be redirected
to POTWs. Such wastes are exempt from regulation under RCRA
if they are subject to control by a discharge permit issued under
the Clean Water Act. This may cause some municipal sludges to
become contaminated with high concentrations of toxic constitu-
                           3-9

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ents. If municipal sludges fail the Extraction Procedure Toxicity
Test, the sludges would be subject to RCRA Subtitle C manage-
ment requirements. Regulation of sludges as hazardous waste
could further strain existing disposal capacity.

In 1987, Congress further amended the Clean Water Act to direct
that the disposal of sewage sludge be regulated.  Regulations to
carry out this program are expected to be proposed by EPA in
April, 1989.  EPA is also developing technical standards for the
land application, distribution and marketing, landfilling, incinera-
tion, and land surface disposal of domestic sewage sludge. These
standards are also expected to be proposed in April, 1989, with
final regulations expected to be issued in October, 1991.

The sewage sludge technical standards could affect hazardous in-
dustrial wastes disposed of in municipal  treatment systems.
Annually, approximately  160,000  industrial and commercial
facilities discharge in excess of 100,000 metric tons of hazardous
waste constituents to POTWs.

OCEAN INCINERATION REGULATION

In the early 1980s, EPA proposed regulations that would allow
bulk liquid organic hazardous waste to be burned at sea under an
ocean incineration program. Solid wastes were excluded from the
ocean incineration regulations. In early February, 1988, the ocean
incineration program was suspended.

OCEAN DUMPING/DISPOSAL REGULATION

Prior to 1972, ocean disposal of sludges and industrial wastes was
unregulated. In 1972, the Marine Protection, Research,  and
Sanctuaries Act (MPRSA) was created to regulate the transporta-
tion of any material for ocean disposal and to prevent the disposal
of any material in oceans which could affect the marine environ-
ment. In November 1988, MPRSA was amended to establish a
framework for ending ocean disposal of sewage sludge  and
industrial waste by December 31,1991.

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Since the enactment of MPRSA in 1972, the amount of industrial
waste deposited in the ocean declined from approximately 6
million tons to approximately 0.3 million tons per year in 1986.
However, the MPRSA regulations have been the focus of several
legal challenges.  Additionally,  the amount of sewage sludge
disposed of in the ocean has increased from approximately 4.9
million tons in 1973 to 7.9 million tons in 1986. The increase in
volume  is  mainly a  result of upgrading existing wastewater
treatment facilities to comply with the Clean Water Act require-
ments.

The  Agency is currently in the process of developing proposed
regulations which will update the current regulations to respond to
the new statutory amendments and address remaining legal issues.
The proposed regulations are scheduled for publication in the
Federal Register in late 1989.

The new legislation has several key elements. It prohibits new
entrants, that is, any person who was not ocean dumping sewage
sludge and industrial waste as of September 1,1988, from beginning
to dump. Existing dumpers must cease dumping sewage sludge
and industrial wastes as of August 15,1989, unless the dumper has
received a permit and has entered into a compliance or enforcement
agreement  with EPA which, among other things,  includes a
schedule for development and implementation of an alternative
system for the management of sewage sludge and industrial waste.
In any event, it is unlawful to dispose of sewage  sludge and
industrial waste in the ocean after December 31,  1991. EPA is
required to report to Congress on the progress in implementing the
Act and the results of a monitoring program also required by the
Act.

Additionally, the newly amended MPRSA now imposes fees for
ocean dumping prior to the 1991  deadline and civil penalties for
dumpers who continue ocean dumping after the 1991 deadline.
A portion of each individual dumper's fees and/or penalties must
be deposited in a trust account which the dumper must establish.
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The trust accounts can be used by dumpers to implement land
based alternatives. After the dumper ceases dumping, remaining
trust account funds will be returned to the dumper to comply with
the CWA, to reduce debt incurred for compliance with MPRS A
and the CWA and for matching Federal grants. Other portions of
the fees are allocated to EPA, and such programs as the State Clean
Oceans Fund and the Clean Water Act Title VI Revolving Fund.

The States of New York and New Jersey are required to contribute
funds during fiscal years 1990 and 1991 to assist dumpers to
develop alternatives to ocean dumping. The funds are to constitute
10% of Federal and state contributions to CWA Title VI Revolving
Fund Grants.

Garbage barges are also addressed in the new legislation. The law
contains provisions to regulate garbage barge operations. The
disposal of medical wastes is addressed as well. A discussion of
medical wastes follows.

MEDICAL WASTES

Very recently, public attention has been dramatically focused on
problems posed by unregulated medical wastes. Fear of the spread
of highly infectious, life threatening  diseases by contaminated
medical wastes has been one  factor that has influenced the
movement for regulation of these wastes. The now all too familiar
beach scene strewn with medical debris and the beach closings
have played their part in the call for regulations to manage medical
wastes. Congress has responded by: (1) amending MPRS A and
the CWA and (2) passing the Medical Waste Tracking Act of
1988, which was signed into law on November 1,1988, to address
medical wastes.

The amendments to MPRSA and the CWA: (1) amend the
MPRSA  to prohibit transportation for the purpose of dumping
medical waste into ocean waters, effective the date of enactment;
(2) amend the Clean Water Act to prohibit the disposal of medical
waste into the territorial sea and internal waters, also effective on
the date of enactment; and (3) prohibit the disposal of potentially
                          3-12

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infectious medical waste in ocean waters by public vessels with
certain narrow exceptions, effective six months after the date of
enactment   Substantial penalties, including jail sentences and
property forfeiture are included in the new Act for violations of the
new provisions.

The Medical Waste Tracking Act of 1988 (MWTA) has several
key provisions. The MWTA requires EPA to list medical wastes
to be covered by the program by May 1,1989. The MWTA also
requires EPA's Administrator to establish a demonstration pro-
gram by May 1,1989 to track listed medical wastes from point of
generation to point of disposal; the demonstration program is to
last two years. The program is to be applicable to medical wastes
that EPA will list. Wastes are to be segregated by type of waste and
placed in labeled containers that protect waste handlers and the
public from exposure. The program will require the tracking of the
waste from  the generator to the disposal facility; waste that is
incinerated, however, need not be tracked after incineration. For
those incinerated wastes disposed of at the site of generation, the
Act imposes certain recordkeeping and reporting requirements.
The MWTA contains inspection and enforcement authority. EPA
may establish an exemption for generators of less  than 50 pounds
per month.

Not all states are covered by the demonstration program, although
any state can participate if it petitions EPA to be included and EPA
includes the state in the program. However, the MWTA does
specify that the medical waste generated in the states of New York,
New Jersey, Connecticut and states contiguous to the Great Lakes
is covered  by the demonstration program with the following
exception. If New York, New Jersey or Connecticut choose not to
participate in the program, the state (or states) must demonstrate
that it has implemented a medical waste tracking program that is
no less stringent than EPA's demonstration program. Other states
"opt oufsimply  by notifying EPA. Federal facilities located in a
state participating in the demonstration program  are required to
meet program requirements and local and state  medical  waste
requirements.

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The MWTA requires two reports to Congress on the impact of
medical wastes. First, the Administrator of the Agency for Toxic
Substances and Disease Registry must report on the quantitative
health effects' impacts of medical wastes by November 1,1990.
Second, EPA is required to submit a report within three months
after the end of the demonstration program on the effectiveness of
the program. The EPA report will contain other information, such
as: (1) types, number and sizes of medical waste generators; (2) the
present or potential threat to human health and the environment
posed by medical waste; (3) the present or potential costs to local
economies, persons and the environment that are associated with
the improper handling, storage, transportation, treatment or disposal
of medical waste; and (4) the present or potential costs to generators,
transporters and treatment, storage and disposal facilities that are
associated with regulatory requirements  dealing with medical
wastes.

SUBTITLE D REGULATION

Regulation of non-hazardous solid waste differs from regulation
of hazardous waste. Solid waste is managed in accordance with
Subtitle D of RCRA, while  hazardous  waste  is managed in
accordance with Subtitle C of RCRA.

Under Subtitle D of RCRA, a framework has been established for
Federal, State, and local governments to manage solid waste. This
framework includes  voluntary implementation of solid waste
management plans combined with minimum technical standards
established by the Agency for new and existing solid waste man-
agement facilities.  All "open dumps" were to be either closed or
upgraded  to meet the technical standards established under Sub-
title D.

The universe of solid waste regulated under RCRA Subtitle D
includes municipal solid waste as well as industrial and commer-
cial non-hazardous waste. In addition, Subtitle D includes non-
hazardous sludges from water supply and wastewater treatment
plants and "special" wastes such as some mining wastes, oil and
gas waste, and infectious waste.
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In 1986, approximately 158 million tons of municipal solid waste
was generated. The amount is expected to increase to 190 million
tons by the year 2000. Approximately 95% of the solid waste that
is produced consists of non-hazardous industrial waste, municipal
solid waste, oil and gas waste, and mining waste. Not only is the
gross volume of solid waste increasing, but the relative volumes
of the different types of waste are changing.

Approximately 85% of municipal solid waste is disposed of in
landfills.  There are about 6,000 currently  operating municipal
solid waste landfills, with approximately 184 of these landfills
either proposed or final sites on the National Priorities List (NPL).
An estimated one-third of all existing landfills will be full by 1994,
thereby decreasing available solid  waste disposal capacity.

Currently, some hazardous wastes are being disposed of in mu-
nicipal landfills along with non-hazardous, solid wastes. These
hazardous wastes include toxic constituents in household waste
and very small quantity  generator hazardous wastes (e.g., paint
wastes, dry cleaning residues, corrosive wastes, and pesticides).
Also, used lead acid batteries are a large source of hazardous waste
in municipal landfills.  EPA is currently examining the use of
authorities under TSCA  to control the manufacture and disposal
of products containing certain hazardous constituents.

On August  30, 1988, EPA published a proposed  rule which
addresses new criteria for solid waste disposal facilities. The pro-
posed rule contains revisions to the minimum criteria for munici-
pal solid waste landfills, including containing provisions which
would establish facility design and operating criteria, ground-
water monitoring requirements, location criteria, corrective ac-
tion provisions, methane gas controls, financial assurance, and
closure and post-closure care requirements for municipal landfills.
The proposed rule also contains provisions which would establish
notification and exposure information requirements for industrial
solid waste disposal facilities and construction/demolition waste
landfills.
                           3-15

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In addition, the Agency is examining the status of municipal waste
combustion ash.  Guidance is being developed for sampling and
analysis of incinerator ash under the EP-Toxicity test and techni-
cal guidance is being prepared for handling ash residues. More
stringent standards may be proposed for fly ash since fly ash has
been shown to contain higher concentrations of toxic metals than
bottom ash.

Another source of solid waste is large volume, low toxicity special
wastes, such as mining waste. In the 1985 Report to Congress on
Mining Waste (waste from extraction and beneficiation of ores
and minerals), it was noted that less than 1% of all mining waste
appeared to be hazardous.   Alternatives for regulating these
mining wastes under Subtitle D of RCRA are being examined.
Standards for mining waste will address stability, ground water,
surface water and direct human contact.  In accordance with the
July 3, 1986 mining waste regulatory determination,  EPA is
examining the components of current federal and  state mining
waste programs. EPA is currently considering whether regulation
under Subtitle C is warranted for mining wastes from the process-
ing of ores and minerals.

In February, 1988, the Agency established the Municipal Solid
Waste Task Force.  This Task Force is  currently developing a
national strategy for the management of municipal solid waste.
The final  report of  the Task Force is expected to be  issued in
January 1989.

On October 18,1988, the Subtitle D Report to Congress was sent
to Congress.  This report evaluates the adequacy of the current
Federal solid waste regulatory program. In preparing the report,
the Agency collected data on Subtitle D waste and facility charac-
teristics as well as State Subtitle D program components. Among
other things, the report addresses the perceived capacity shortage
among municipal solid waste landfills.
Currently, state and tocal governments have  the basic responsi-
bility for management of Subtitle D wastes. Continuing focus will
be placed on encouraging State planning activities, including en-

                           3-16

-------
couraging the promotion of increased use of product separation,
source reduction, and recycling to reduce the volume of solid
waste requiring disposal in Subtitle D facilities.

CORRECTIVE ACTION REGULATIONS

Corrective action involves cleaning up soils, surface water and
ground water contaminated with hazardous wastes at hundreds of
RCRA facilities. Specific corrective action requirements are
determined by the Agency based on the types of waste involved,
the risk of human exposure, the hazard to the environment, and the
likely future uses of the facility.

Corrective actions may be required for hazardous waste releases
to any media, including air. Corrective action requirements apply
to Regulated Units (RUs) at hazardous waste management facili-
ties, treatment, storage and disposal facilities (TSDs),  and solid
waste management units (SWMUs). Leaking underground stor-
age tanks under Subtitle I represent another potentially large uni-
verse for corrective action projects. In addition, publicly owned
treatment works (POTWs) that accept hazardous waste by truck or
rail may be subject  to corrective action requirements.

The focus of corrective action is to identify and address sites that
present significant environmental problems. Currently, the Agency
is preparing proposed corrective action regulations. In addition,
the Agency is looking into state capability to implement corrective
action requirements.

The volume of waste that will be generated from corrective action
projects could be large. Although most waste probably will be
treated on-site, some concentrated wastes may require off-site
treatment. These wastes will likely compete for existing commer-
cial treatment and  land disposal capacity.  Capacity  problems
could occur in those regions of the country with limited disposal
space.
                          3-17

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SUPERFUND   OFF-SITE  POLICY  AND   CLEAN-UP
STANDARDS

SARA establishes standards for Superfund clean-up actions and
also stipulates the conditions for disposing of Superfund wastes
off- site. These provisions could change the proportions of hazard-
ous waste managed on-site and off-site.

The clean-up standards provided for in SARA require Superfund
remedies to be protective of human health and the environment as
well as cost-effective. The remedies must also utilize permanent
solutions, alternate treatment technologies, and resource recovery
to the maximum extent practicable.  The on-site remedies must
also meet applicable or relevant and appropriate requirements
(ARARs) of other federal statutes including:  RCRA, TSCA,
SDWA, CAA, and CWA.  Also, where state standards are more
stringent than federal standards, state standards must be met. (The
Federal and state ARARs may be waived in certain circum-
stances.) For hazardous wastes that remain on-site and exceed
protective health-based levels, the remedial actions are reviewed
no less than  every 5 years. The new clean-up standards are ex-
pected to increase the use of mobile treatment units and stabiliza-
tion techniques  for on-site waste management.

SARA restricts off-site disposal of Superfund wastes to those
facilities in compliance with applicable Federal and State require-
ments. In addition, the unit receiving Superfund wastes must not
be releasing any hazardous wastes or hazardous constituents.
Furthermore, releases from other units at RCRA land disposal
facilities must be controlled by a corrective action program. The
purpose of these requirements is to ensure  that hazardous wastes
from Superfund sites are not moved to other facilities that could
potentially become Superfund sites in the  future. A revised off-
site policy will be proposed in the near future.

Several Superfund sites have experienced  difficulties in locating
a commercial facility acceptable to handle their waste. However,
these situations have been resolved in relatively short periods of
time as additional facilities achieve compliance with require-
ments.
                          3-18

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EMERGENCY PLANNING AND COMMUNITY RIGHT-
TO-KNOW (TITLE III)

In October 1986, Congress enacted Title HI of SARA which
focused on emergency planning and the community's right-to-
know about chemicals stored, processed, used, and released in its
boundaries. The intent of Title HI is to improve public awareness
of the presence of hazardous and toxic chemicals within commu-
nities, and of the releases into the environment of such chemicals.
This information will be used to improve the emergency response
planning efforts of state and local governments. Title HI accom-
plishes this intent by establishing requirements for emergency
planning,  emergency release notification, community right-to-
know reporting, and toxic chemical release reporting.

Title III applies to certain listed chemicals present at a facility in
amounts greater than the threshold quantity established for each
chemical under each section of Title III. This applies to chemicals
regardless of their designation as raw material, inventory, work-
in-process, product, chemical mixtures, chemicals stored on-site
to be recycled, or waste.

The provisions of Title  III require  a  phased approach  to
implementation. Under the emergency planning provisions of
Sections 301-303, an  emergency response commission is to be
established within each state. The state commissions are respon-
sible for creating local committees within areas designated by the
state as emergency planning districts. Currently,  35 states have
established districts according to existing  local government sub-
divisions; 10 states have designated existing regional response or
planning districts as the emergency planning district; and 15 states
have designated the individual state to be the entire district.

It is anticipated that Title HI will assist  in waste management
efforts through toxic release inventory reporting and community
right-to-know requirements. The availability of Title III informa-
tion might result in reductions in the amount of chemicals present
within communities as well as assist in source reduction efforts.
However, the effect on waste disposal capacity  is uncertain at
present.
                           3-19

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REDEFINITION OF RCRA HAZARDOUS WASTE

In early 1987, EPA started to examine alternative methods for
defining waste as a RCRA hazardous waste. Presently, a waste is
defined as hazardous under RCRA if it possesses certain charac-
teristics or is listed in Part 261 of the Code of Federal Regulations
(40 CFR). About half of RCRA hazardous waste possesses one of
four hazardous characteristic attributes:  reactivity, ignitability,
corrosivity, or EP toxicity.  There are now over  450 listed
hazardous wastes. New substances are added to the list of wastes
as they are tested.

Approximately 275 MMT of RCRA hazardous waste are gener-
ated by about 40,000 large quantity generators and about 100,000
small quantity generators.  Changing the criteria for defining a
hazardous waste could significantly affect the volume of waste
currently regulated by RCRA as well as the number of regulated
facilities.

SUPERFUND STATE CAPACITY ASSURANCE PLANS

SARA provides that EPA shall not provide  remedial actions
within any state unless that state assures EPA by October 17,1989
that it has adequate hazardous waste treatment and disposal ca-
pacity for wastes generated in the state for the next twenty years.
This assurance must also provide that the available capacity will
be in compliance with RCRA. These requirements seek to ensure
that Superfund money is only utilized in states that are actively
engaged in efforts to avoid the creation of future hazardous waste
disposal sites.

 Currently, EPA is preparing a guidance document to  assist states
in preparing their capacity assurance plans (CAPs).  States will
utilize the information obtained during the assurance process to
plan for their  future hazardous  waste  treatment and disposal
needs. Such planning will require accurate assessments of the
amount, type and disposition of the hazardous wastes that will be
generated within the state, exported to other states, and imported
into the state.
                          3-20

-------
The effect of waste minimization efforts upon the volume of waste
requiring treatment and disposal will play a role in determining
the amount of disposal capacity needed by a state. Also, siting and
RCRA compliance issues will be important factors in determining
state treatment and disposal needs.

POTENTIAL REGULATORY IMPACT

Each of the above regulatory and policy decisions has the potential
to shift waste from one medium to another or from one location to
another.  The various impacts of the regulations discussed in this
section are summarized in Exhibit 19.
                         3-21

-------
                     Exhibit 19.
Regulations and Policies and Their Potential Effects on
                      Capacity

v"::OiRP!pi»e» •;•'.';.
Land Disposal
RMMdkmt
PoMon
Pwwitton
Poky
D«ep-Wel Injecton
Regulation
Domestic Sewage
Sludge Regulation
Ocean Dumping/
Disposal Regulation
Subfile D
Regulation
•: - " " . ' WAflfW'THAMflFBIt : ' • •'
.>. ;:" PC8CBIPTK*t ••;••' .. ..?
• ShKt organic »qUd» and skidgee to
Indrwalhxv
• ScMty inorganic *jdg«t prior to
landdspoul.
• Redirect wwtawaMre torn surfic*
Impoundmtnlc to wa%twit tanks
and Hrfan mtan. Treat and dipos*
of residual dudge undw RCRA.
• UkelytoreauMlnconcanVatlonol
hazardout waatu prior to treatrant
anddltpoaal
• PolantlallyrMMctdlapoaalotnCRA
hazardoua. aquMua waatoa (ram
C)MP-VW«»; «hm waaM to POTWa
and Indurtlal wattmvaw IrMnwn
plant..
• Ur^vduniMolnon-hazardoua,
municipal aludga arc pfoduod annualy.
BCWi conWnt an uduttan tor
hazardous VMMM mh»d »Hh dotnxlc
Mwaga.
• Oc*andipoulolMW>g<«hjdg«.
rndkal vmlxandindurtial wu» wil
Ix bamwd alter D«cwitw> 31 . 1 «01 .
» f ocua en raeyd* and rauM may r*due*
aomeaoHwasla. HouMvarlaro*
volumaa wal conlnu* to b» land
d«po««d or inoiMratod

"• '...., iw*9TE.. ;;:;':"!
Modarato
Modarata
Unknown but
potentially larga
Raduc* volume
ZS-35%
Moderalato
Large
Unknown but
maybe
potenbaty
HonWcant
Modvak
Unknown tut
poHTHMy
l«r»e

:.-..-"*xin.QOic"" ••••••.
Contained
Available tor a
short-term
Maybe
constrained In
short term
Increase tie
longevity of
land Disposal unfta.
May Increase
demand tar
freatnent capacity.
ConsMned
Skidoa currently
landMed.used
tor land
appBotonor
indrwrattd.
NotappNcaMe
Deadly fcr
landHa
Icno-lemi
                                              (conanued)
                         3-22

-------
                 Exhibit 19 (cont.).
Regulations and Policies and Their Potential Effects on
                      Capacity
.^ :RECtUCWK)t( 4:;S::
:iVx5P.f~*5r '"•$&' :
Corrective Action
Reputations












SuperfundOff-SHs
PoHcy
and Clean- Up
Standards


Enwgoncy Planning
and Community Right'
To-Know (Tltis III)
RwMrrton
ofRCRA
Hazardous Waste




Superfund State
Capadty
Assurance nans


;\'x::?;ip5«tB*j««F» 	
•• ••::•;•¥:':;:'•.¥ «EBCflU!m)H
• UST and SARA may reauM In some
wastes Vanefsfred off-site to RCRA
commercial faculties

• Increase the volume of soNds and
sludges requiring Ireatnent and
disposal.







ajtotr
Disposal ofSuoertund watts. W*
minimize to volume of untreated waste
fransfafTM to u^vuvuh^ul latilM.


• May result In firms reducing tin amount
of hazardous wasfc stored on-sHe

• Potentially change the amount of waste
dedned as hazardous, it Is unknown If
specific categories of wesle wouM
hK'rease more ttwn oVwre or tiw Intact
on particular waste management
practice*.

• Shouk) result In a belter undentandhig
of intrastate waste shipments and
on-srte capacity needs


JttWUMTQIi-:
WASTE
Modtrate to
slgnMcant












Moderate



Moderate


Unknown but
maybe
potentially
significant



Potentially
significant



CAPACITY
OuTtOOK
Incineration
capacity Is
limited in the
short-twin.
Could improve in
the long-term
given successful
siting programs
Land disposal
capacity may be
const- ained n
long-term unless
successful siting
occurs
Could be
Increased
through use
of innovative.
mobile treatment
technology
Unikely to affect
capacity

Capacity
constrained
already
for particular
wastes such as
some solvents
anddoxins
Capacity
requirements for
20 years will be
planned and
Implemented
                        3-23

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                      SECTION 4

            OUTLOOK FOR THE FUTURE
The regulatory actions discussed in the previous section will
significantly influence the ways waste is managed in the future. It
is difficult to predict the exact interaction among future regulatory
actions, generators' response to regulations, and the commercial
waste industry reaction.  It is also difficult to predict the specific
hazardous and solid waste system of tomorrow. However, several
preliminary conclusions emerge from information provided in
this report which apply to hazardous as well as solid  waste.

First, the report makes it apparent there is a need to develop more
integrated waste management planning at both the Federal and
state levels of government as the country approaches  the twenty-
first century.  Second, successful siting and permitting is need to
increase waste management capacity. Third,  pollution preven-
tion must become a primary goal for waste generators  through the
use of recycling, source reduction and reuse efforts. Fourth, more
innovative and alternative technologies need to be developed to
treat, store, recycle and dispose of waste. Lastly, a more focused
effort on enforcement of waste management statutes and regula-
tions is needed.

INTEGRATED WASTE MANAGEMENT PLANNING IS
NEEDED

Both  the Federal  government and states must  plan integrated
approaches to both hazardous and solid waste management and
disposal. Pollution prevention, recycling, reuse, resource recov-
ery and other techniques must be utilized to effectively reduce
waste production and to safely manage the waste that is produced.
Implementation of a single waste management method alone will
not resolve complex hazardous and solid waste management
issues.
                           4-1

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At the heart of waste mangement planning is the need to ensure
adequate waste management and disposal capacity while ensur-
ing the protection of human health and the environenment. In ad-
dition, planning is necessary to anticipate the impact of changing
regulations on future capacity needs.  It is important to note that
requirements contained in such regulations as the land disposal
restriction regulations and the corrective action regulations may
shift wastes normally treated in one type of facility to another type
of facility.  Furthermore,  changing  regulations may alter the
methods of treatment and disposal recommended for particular
wastes. In addition, our evolving environmental regulations could
also shift wastes that are currently regulated under RCRA to cov-
erage under another Act. Integrated waste management planning
efforts are needed to ensure that adequate capacity is available in
the future. Potential capacity problem areas are noted in Exhibit
20.

To accomplish this end, EPA strongly encourages the use of such
techniques as recycling, source reduction, and reuse. Incineration
is favored for certain types of waste, and landfilling must be used
sparingly to preserve the limited capacity that is currently avail-
able.

Everyone has a role in  integrated waste management planning,
including the Federal government, state and local governments,
manufacturers, consumers, and commercial waste management
firms. Most importantly, the public must accept that waste needs
to be managed locally to ensure that wastes produced at the local
level are managed efficiently.

SUCCESSFUL SITING AND PERMITTING IS NEEDED

There are a number of factors within the waste management
system, such as regulations, statutes and economics, which affect
the availability of capacity in the waste management system for
the future.  The regulatory and statutory initiatives have changed
the focus from landfilling and off-site treatment and disposal to
permanent treatment whenever feasible.
                           4-2

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          Exhibit 20.  Potential  Capacity Problem Areas
          PBOBLBW AHEA»
                                           UKELV CAPACITY
                                           PflOBLEM AREAS
                              UNLIKELY TO BE PROBLEM
                                ABEASFCttCAPAOTY
 Incineration

 •  Limited excess capacity  currently
    exists commercially for certain liquid
    organic wastes  On-sfts capacity is
    uncertain.

 •  Siting and permitting delays stow
    capacity expansion

 •  More sludges and solids could be
    brought Into hazardous waste
    system (e.g, RCRA and Superlund
    corrective action), some of which will
    be Incinerated.
    Capacity problem exists
Waitewiter Treatment In
Tanks or Double Lined
Surface Impoundments

 •  Large volumes of RCRA
   hazardous waste are
   currently treated and
   disposed of In surface
   Impoundments.

 •  Some shift from surface
   Impoundments to tanks
   could occur (exempt from
   RCRA, but regulated under
   the Clean Water Act)

 •  Potential Increase in
   demand for tank treatment
                                         Capacity problem will occur
                                         If conversion to tanks or
                                         retrofit does not take place
Solidification

 •   Many Inorganic soMts and
    sludges are potential
    candidates tor
    solidification.  Limiting factor Is
    availability of landfills.

 •   Set up time and costs are low
    to stabilize wastes.

 •   Technology Is not a limiting
    factor

 •   Some wastes may need to be
    stabilized m tanks

  | Capacity should be available [

    Recycling, Reuie, Fuel
    DkrtllMlon

    Most wastes currently going
    to land disposal would not
    require these technologies
    More likely the wastes would
    require Incineration m a
    hazardous waste incinerator

 •   Major permit modifications are
    not necessary (RCRA
    exempt processes).

    Use of these alternatives may
    be affected by regulations on
    waste minimization, fuel
    specifications, and air
    emissions
Note: The reader should note that this chart focuses on national, physical capacity  However, economic, transportation,
     regulatory and legal considerations may constrain the practical availability of capacity  Moreover, regional and state
     capacity problems may exist.
                                               4-3

-------
An important program in the next few years will be the state as-
surance of twenty years of adequate hazardous waste treatment
and disposal capacity which is required under SARA.  Failure of
a state to assure adequate capacity will result in the loss of Super-
fund remedial action funding for the state.

In addition, economic factors have combined with regulatory and
statutory  factors to produce a limited amount of disposal and
treatment capacity. What capacity is available is expensive due to
the significant increase in  landfill and other disposal costs  since
1984.

With the regulatory and statutory goals for decreasing the amount
of hazardous wastes requiring management and disposal, genera-
tors are generally managing their wastes on-site, and shipping off-
site the more concentrated and toxic wastes for treatment and dis-
posal.  The result has been a need for more on-site and off-site
treatment and disposal capacity to manage these wastes.

To address the need for more waste management capacity in the
future, the siting and subsequent permitting of waste management
facilities must be promoted.  First, communication and coopera-
tion must be created among the siting parties.  Second, creativity
and compromise must be used to develop thorough siting and per-
mitting options.  Third,  care should be taken to consider the
economic and environmental  needs of local communities and
states.  Finally, use of a  structured negotiation process which
ensures public participation is necessary to facilitate siting and
permitting.

RECYCLING,  SOURCE REDUCTION AND REUSE
EFFORTS MUST BE IMPROVED

The Agency's goal for the future is to ensure the implementation
of pollution prevention techniques by generators of waste in this
country.  Recycling, source reduction and reuse are the current
methods in use to achieve  this goal. Use of recycled waste saves
resources; source reduction refines production methods to reduce
                           4-4

-------
pollution at the source; and reuse again focuses on production to
find ways of reusing wastes to reduce the quantities of wastes
requiring disposal.

At present and in the future, recycling, source reduction and reuse
efforts could become more prevalent in the waste management
system.  Two market factors which may function as the impetus
of these efforts are the economics of waste management and
liability issues. The current economic factor that looms large for
waste management is rising costs of waste disposal (i.e., land
disposal, treatment, and incineration).   The liability concerns
center on the regulatory and statutory penalties associated with
wastes which are hazardous that are improperly disposed.

INNOVATIVE AND ALTERNATIVE TECHNOLOGIES
NEED TO BE DEVELOPED

The key to future waste management rests with the development
of innovative and alternative technologies. Innovative technolo-
gies are needed to continue the development of techniques for the
handling, transportation, treatment and disposal of waste.  The
Superfund Innovative Technology Evaluation (SITE) program is
one such program which has been developed by EPA to foster and
encourage the development of new and innovative hazardous
waste treatment technologies. It is possible that a parallel program
will be developed for solid waste in the near future.  Alternative
technologies, many available and proven effective, are needed to
promote more permanent solutions to waste problems over those
used in the past.

MORE ENFORCEMENT IS NEEDED

The enforcement of regulations and statutes is key to a viable
waste management system operating. Improvement in the en-
forcement area could translate into better waste management
practices throughout the country.
                          4-5

-------
More enforcement efforts should be focused on frequent and
comprehensive inspections to ensure TSD compliance with land
disposal restriction requirements, corrective action requirements,
and the requirements of other statutes and regulations.   In
addition, a stronger enforcement presence is needed to encourage
responsible parties to assume the costly clean-up responsibilities
mandated under RCRA and Superfund. Lastly, the Agency is
encouraging implementation  of increased  state enforcement
measures for the aforementioned areas.

In conclusion, waste management is everyone's responsibility.
Safe waste management can only be achieved through the active
cooperation of the public, private industry, and state and Federal
governments. Such cooperation is currently underway, and ef-
forts to reduce waste generation  as well as efforts to effectively
manage the wastes that are produced must continue.
                            4-6

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APPENDIX A

-------

-------
            Commercial Incinerator Facilities
::*V ':.'.""4ifeMJft ' .. •
Environmental
Systems Company
Chemical Wasto
Management Inc.
Chemical Services Inc.
OthCorp
LWD. Inc.
LWD. Inc.
RoWns Environmental
Services
Stauftor
Rollns Environmental
Services
Rollns Environmental
Services
StauNer Chemical Corp
Cakhvell Systems.
Inc
Ross Incineration
Stablex South
Cardlna Inc.
GSX Thermal
Oxidation Corp
BDT Inc
WSCATWH :
B Dorado
Arkansas
Sauget
Ntlnoie
Chicago
Illntxa
Brandenburg
Kentucky
Cahrertdty
Kentucky
day
Kentucky
Baton Rouge
LouWana
Baton Rouge
LouWana
Bridgeport
New Jersey
Deer Park
Texas
Houston
Texas
Lsndr
Norti Cardlna
Qrafton
Ohio
Rock Hill
South Cardlna
Roebuck
South Carolina
New York
TTPfOfUNff
Rotary KJIn
Liquid Injection and
Fixed Hearth
Liquid Injection and
Rotary KUn
Liquid Injection
Liquid Injection
Rotary Nil
Liquid Injection and
Rotary Klh
Not Available
Liquid Injection and
Rotary K*i
Uquld Incineration
and Rotary Kiln
Not Available
Uquld Injection and
Sdld Incineration
Uquld Injection and
Rotary Kiln
Fixed Hearth
Liquid Injection
Not Available
TYIfQF*ASt5»
PCB. Adds. Halogenated a Non-
Halogenated Solvents, Halogenatod
a Non-Halogented Organic*
Halogenated a Non-Halogenaled
Sdventa, Halogenatod a Non-Halo-
genated Organic.
PCB. Halogenatod a Non- Halo-
genatad Sdventa, Halogenatad
a Non-Halogenated Organic..
Non-Metallic Inorganics
Notavalableatlhieime
Add., Halogenatod a Non-Halo-
genated Solvents, Halogented a Non-
Halogenated Organic., Metalic Organic.
Add., Halogenatod a Non-Halo-
genated Solvents, Halogenated
a Non-Halogsnatad Organic..
Metallic Organic*
Adds, Halogenatad a Non-Halo-
genated Solvent., Halogenated
a Non-HalogenaHd Organics, Metalic
Organic*. Metallic a Non-Metalic
Inorganics
Notavaiableatthislme
Adds. Halogenatod a Non-Halogenated
Sdventa, Halogenatad a Non-Halogen-
abd Organic., Metalic Organics,
Metallic a Non-Metalic Inorganic*
PCB. Add*. Halogenated a Non-
Halogenated Sdventt, Halogen-
atod a Non-Halogenated Organic*.
Metallic Organic.. Metalic a
Non-Metallic Inorganic*
Not avalable at this Ime
Halogentod a Non-Halogented
Sdventa, Halogenatod a Non-
Halogenated Organics, Metalic
and Non-Metalic Organics
Add*, Halogenated and Non-
Halogenated Sdventa, Halogen-
atod and Non-Halogenated
Organic.
Halogenated a Non-Halogenated
Sdventa. Halogenatod a Non-Halo-
genated Organic*. Metalic
Organic.
Halogenated a Non-Halogenated
Sdventa, Halogenatod a Non-Halo-
genated Organic*
Metals
•  In addlton, there are lour TSCA commercial Incinerators permitted to burn PCB
Source. EPA Office ot Solid Waste and Office of Toxic Substances. 1966
                                   A-1

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APPENDIX B

-------

-------
      Operating Commercial Land Disposal Facilities
• ••:•.•:.••.•:,.••,;•. VHW**< '• ' :
Chamlcal Waato Managamant Inc.
IT Corp. Banada
IT Corp. Vina HM
IT Corp. bnparial
CaamaUa Raaoufeaa
ACME FK Corp.
™*""""»
Chamleal Waata Managamanr, Inc.
CECOS Intamaltonal Inc.
CllyolDantaury
Tomnglon LandM
Envlraaafa Sarvleaa ol Idaho
SCA Chamlcal Sarvlcaa Inc.
Paoria Dlapcaal Co.
CID-LandM
CECOS Wamaaonal toe^BFI
Four County UndM
Adarna Cantar LmdM he.
WCAIKlN •/ >:
Emala, Alabama
Banada, CrttomH
UarUnaz, CaHtemU
Waatnoraland.
Callomla
Ca«ma«a.Calllomla
MarHnaz.CaHfomia
Mar«r>at, CaWwrt.
Kattaman dty,
Brlald, Connadcut
Danbury, Connadtout
Comaelkut
Qrand Vlaw, kfaho
Chicago, Mnola
Paoria. Wnoto
CakjmatClty.
•nda
Zton.Mnda
Pochaalar. Indiana
Fort Wayna, Indiana
TyPWflfifACttmW
LandM, Sloraga Impoundmanta
LandM, Dtaooaal Impoundmanta,
Storaga Impoundmanta
Traa^lmcoundrrw*
Dlapoaal Impoundmanta,
LandM.Otapoaal Impoundmanla
Traatmant Impoundmanta
LandM
DlapoMl Impoundmanta,
Traatnant Impoundmanta
LandM, Traatnant
Impoundmanti
WaalaPMa
LandM
LandM
LandM, Waala PHaa
Storaga bnpoundmantk, Traavnant
bnpcundmanki
LandM
LandM
LandM
LandM
LandM
' j WWW
Matala, CyanMaa. Addte
Conoalvaa. PCBa,
Hatogana
Matala, CyanMai. Sobanta
Matito
U»W<. Sdvank
Addle CorroalvM. Matala.
Cyanktoa, Halogana
Otm
Matata, Addle Corroalvaa
Addle Corroalvai, Matala
Matala, CyanMaa
Matria
Mattfa
Addle Corroaivaa Matala
Hatogana
Otw
Matria
Addle Correahaa. Matala,
Hatogana
Matala. Sdvan*, Halogana
Malarlato
Addle Correabaa, MaMa.
Cyanldai.Solvanla,
Hatogana
Sourca: EPA OMea of Solid Waata and Offlca ol Toxic Subataneaa, 11M.
                                                        (eonhiuad)
                               B-1

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 Operating Commercial Land Disposal Facilities (cont.)
;. .:..:.;:;:.:::: $&8«nV'- ,/,.,, •'.'.
CECOS mtemaeonaf Inc.
CECOS International, he.
Chemical Waste Management, he.
Rolirw Envlrcnnwn(s>4 SwvfoM
Maryland Environmental Service
Wayne Disposal, me.
Environmental Waste Ccnfrot
B.H.S.. he.
Rogera Rental Lamm
US Ecology, he.
SCA Chemical Services
Frontier Waste Chemical Process
CECOS International Inc.
F.E.I Landfarmlng
Chemical Waste Management, he.
Fcndoesy Enterprleee, Inc
Erieway PcNuMon Gonfrol he.
CECOS International, he.
: UJCA1X** -
Weelake. Louisiana
LMnoston. Louisiana.
Canvas. Louisiana
Baton Rouge,
Louisiana
Baltimore. Maryland
Bsrlervtle. Uchigan
InkstBr McMo>n
Wright d*. Missouri
CenesrvUe,
Beady. Nevada
Modal City. New York
Nlajrs Fats, New York
Magra Fata. New York
Oregon. Onto
VIokery.ONo
Oreoon Ohio
Bedford Ohio
WHiemsbur J, Ohto
T*M»oarAn» •
Storage knpoundmanM
LandM
LandM
LandM, Storage
Impoundment*. Treafenent
Impoundment!
LandH
LandM
LandM
Land Treatment
LandM
LandM
Was* Pies
LandM
L«nd Treatment
LatfKMi

LandM
.... .;. mtqn-:: 	
Addle Corrosives. Metals.
SorvenU. Halogana
Addle Corrosrvss. Cyanides.
Sdvank. Helooens
Metals, Cyanides. Sorvsnts.
Halogana
Mstfllft, Solvwili. CyankJsM,
Addle Corrosrvas
Not avalaUe at Me tma
Addle Corrosives. Matala
Addle Corroalvaa Metala
Sorvenfc, Hajogana
Notavalableatthlalma
Metals, Cyanides, Solvents.
PCBa, Halogana
Not (rvelaUe SINS (me
Metala
Addle Corrosives. Mataai,
PCBa
Metals
Addle Corrosives. Metala
MaWa, Cyanldaa
Sorvank), Halogens
Halogana
Servants. PCSs. Halogana
Souroa- EPA Odtea of Solid Waste and Odoa ol Toidc Subatancas, 1 Ma

                              B-2

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Operating Commercial Land Disposal Facilities  (cont.)
^'MK-' aftta.-.. ::££.'.:•.'
Eagle Ploher Industiee. Inc.
USPCI
Chem-Seeurlly OyiUmt. Inc.
Mill Service Inc.
MM Senfce Inc.
OSX Service, of Soul) Caroftna
Gun Coast Warte Oaposat
Chemical WaMe Management.
me
RoHne Environmental Service.
Malone Service Company
Texaa Ecdogleto. me.
USPCI
•. .v,i3*££nw*'.v:''';;
Ouapaw, Oklahoma
Waynoka. Oklahoma
Arlington, Oregon
Yukon, Pennsylvania
Souti Carolina
VAiona. Tene
TexaiClty. Texas
PortArtw.Texae
DeerParii,Te>aa
Te>a>C«y. T«as
Robetown.Texae
Knowta.. Utah
• ^ TVPiabT' rACitmw
Dlaposal Impoundments
LandM. Disposal
hnpoundmentWaste Pne.,
Storage Impoundment..
Treatnent Impoundment.
LandM. Storage
Dlaposal Impoundment..
WaslsPle.
We.l»Ple.r
LandM, Tr.rtnenl
Impoundment
LjndM. LandTreasnent
UndM, Dhpoeal
Impoundment,
Storage Impoundments,
Treatownt Impoundment.
LandM. Storage
lmpoundmenls.Trea*nent
LandM. Storage
linpoundin*flli, TrMtnwnt
LandM
LandM. Land Treatnenl.
:'.•&.:••: Wiwiis
Metal., Solvents
Cyanide.
Addle Corrosive., Metal..
Solvents, PCBe, Halogen.
Metal.
Metal.
Addle Corrosive., MMate,
CyanMe.
Cyanides, Halogen.
Metal.. Cyanide.
Addle Corrosive., Metals,
Cyanides, Solvents, Dioxht.
Hatogene
Metal.. Cyanldee, Solvent.,
Halogen.
Metale. Cyanides, Addle,
Corrosives
Metale, Cyanide., Solvente,
Hatogene
Metal.. AdSc Corrode.,
Sdvenls, PCB.. Halogen.
 Source. EPAOt^ofSoHdWaeteandOfleeofToxleSubelanee.. 1M*
                           B-3

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APPENDIX C

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-------
       Commercial Deep-Well Injection Systems
•:•• ',.$.::'•• • ••:. 4*>mt I v 1 ' • • ;
CECOS Inlamalonal


Ftotln* Environmental Service*










Chemical Watte Management Inc.



Chemical Resource*, he.




Disposal Systems, Inc









BFI

'. "tteiMXM
L*k»Chariee
Louisiana

Baton Roug*
LouWana









Vk*»ry
Ohio


TulH
Oklahoma



Houston
T««








Houston
T«a*
:-v • ': ; **«« . • \ .
Add>, Caurtc.. CMring SoMom.
Organic and Inotgtnk WulMnlera,
LMdiato. Contomlnatod Sodt.
Add*. Chromic Ad*, Ploklng Adda.
Cwaloi, CyanldM. PUnk and Inkt.
Non-Hatog«na«K) Sdvank,
tUbpnalKl Sdvwk. WMM O».
Comimcdil Chemical ProduoH,
Noo-m.lJIlc horjartca. MMaWc
Inorganic*. Non-Hafogmlad and
H*Jog«ut*d Organlca. PMlddo.
PCB Uqulda <50 ppm. PCS Soldi
<50 ppm, ContombMM Soil. Lab
Packa.
Adda, Chromic Add*. Picking Adda.
Caualca. W««. OH. Noo-maUHc
Inorganics. M«W Inorganic*,
Non-Hatogenatod Organle*
Add*. Picking Add*. Cyanide*.
Paint and Mu. Non-HatogenaUd
Sotvann, Wuto OH. Metaate
InorgwilcB. M*Mk Organic*,
POTldda*.
Adda, Chromic Adda. Caurtca.
Cyanide*. P«lnl» and Mi*. Nan-
HatogenjUd Solvenk. Halogenawd
Sdvanl*. Waato OH. CommeroW
Chemical Produek, fton-Metalic
Inorganic*. Melallc Inorganic*,
MeU«c Organic*. Non-H*loojen*M
Organka. Hatogeneted Organfca,
PMddde*. Ccnkmioatod Sdl.
Te>a* Cla*a 1 Hazardou* Waatae
Not Available

                                                             (oofi«nued
Source- EPA OMce ot Sold Waste and Office of Tonic Substances. 1968.
                            C-l

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         Commercial Deep-Well Injection System (cont.)
                                          WCAflON
                                                                      WAST*
Chmkal Wute MnagRwnt. he.
                                       Corpu»Chil«l
                                       Tmm
Add.. Chromic Add*. Picking Ad*.
Caurfo, CftnOn, Pdnk »id lnk«
                                                         HdogwuM Sotvoon. Wa«W OK.
                                                         NorvnwMIe tiorgarto, MMalic
M«k»wS«rvlo»Co.
                                           .OH,
EMPAK. ha
                                        Da«P«rk
Gibr«IW Chemical [Kicmcai
Chemical W««. ManagMinnt
Ocjmlct. HalogwiM Orglnlo.

Add«. Chromic Addt, Picking Add*.
C«i»«c». CymMM, P*n« mi Ma,
Non-Halog«i«IMd Sdv*nli.
HalagKOM SorvMlk. WuK OH,
ComnMrdd Ch«nHc«l Product!,
Non-MitaMc harginlct. M««Bc
Inorguile*, M*Mlc Orgwkx,
Non-H«k>g«rwMd Orgmlo, PMfcUM.

Acttt, Chromic Addt, Ploklng Ada.,
CmuOtx. CyinldM. Prink «nd Mu,
Non-H«tog«MM Solvg«i>M Sdv«i».
rtatogvuHd Sdvwik, W««» CM.
                                        Pat Arthur
                                        Tmm
Ad, CyvMM. Prinb «id Mw.
Non-H«log«iuMd Sotnnto.
H«tog«MM ScKwik. W.W OH.
Comm«rdd Ch«i*^l ProduoO.
Non-MMritc Inergwlot, IMUKc
Orgvilc*, Non->tak>g«n«Hd and
C6COS Intematonal, Inc.
         , he.
                                        OdMM
                                        TOM
                                        Qoy
                                        TWM
Cont»HraiMSoll

Add* (pH >5). Chronic Add.. PKMng
Add^ CxMIc*. MMMc Organic..
Ftamm«bto Uquld.. Cyan!d> W.M.
                                                         Org«>tc. Brfcw, Add.
    Scurn 6PA OBo ol Solid W««.«nd Offlc* olToidcSuDttvicM.I MB
                                          C-2

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BIBLIOGRAPHY

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                      BIBLIOGRAPHY
Analysis of Capacity Short Falls of Schedules for Implementing the Land
Disposal Restriction Program.  U.S. EPA, Office of Solid Waste, ICF, Inc.,
March, 1985. (Report)

Assessment of the Commercial Hazardous Waste Incineration Market. U.S.
EPA, OPA, Booz-Allen & Hamilton, Inc., November 30,1984. (Report)

Capacity Short Falls and the Land Disposal Restriction Program: A Prelimi-
nary Assessment. U.S. EPA, Office of Solid Waste, ICF, Inc., July, 1985.
(Report)

Characterization of Municipal Solid Waste in the United States, 1960-2000.
U.S. EPA, Office of Solid Waste and Emergency Response, Franklin Associ-
ates, Ltd., July 1986. (Report)

Commercial Hazardous Waste Treatment Capacity: Data Sources, Evaluation
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Treatment Branch, Office of Solid Waste, Booz-Allen Hamilton, GCA, De-
cember, 1984. (Report)

Comprehensive Environmental Response, Compensation, and Liability Act of
1980.

Comprehensive Hazardous Waste ManagementStudy. Mississippi Hazardous
Waste Council, ERM, Inc., January, 1982. (State Report)

EPA Public Meetings on Municipal Solid Waste Press Handouts. Municipal
Solid Waste Task Force, Office of Solid Waste, 1988. (Handouts)

EPA to Issue New Toxic-Waste Rules; Big Rise in Disposal Costs Seen for
Firms.  Robert E. Taylor, Wall Street Journal, October 23,1986. (Article)

Estimate of Need. Minnesota Waste Management Board, September, 1985.
(State Report) Attachments: Commercial Hazardous Waste Landfill Capacity.
Memo, Marcia Williams, U.S. EPA, Office of Solid Waste, November 14,
1985. Recent Data on Out of State Landfill Capacity. Office Memo, Decem-
ber 1985.

Estimating Competition for Commercial Hazardous Waste Treatment Capac-
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Treatment Branch, Office of Solid Waste, Booz-Allen & Hamilton under
contract for GCA, Inc., December, 1984.  (Report)
                                1

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Final Report on Hazardous Waste in North Carolina: Analysis of the Collection
Systems, and of the Need for Waste Management Facilities. Battelle Colum-
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Gulf Coast Disposal of Hazardous Waste: Demand, Capacity, and Pricing -
1980-1990. Gulf Coast Waste Disposal Authority, The Pace Co., September,
1981.  (State Report)

Hazardous and Solid Waste Amendments of 1984.

Hazardous Waste Facility Needs Assessment.  New York State Dept. of
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Hazardous Waste Generation and Commercial Hazardous Waste Management
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Hazardous Waste Management Plan. Minnesota Waste Management Board,
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Hazardous Waste Management Report. Minnesota Waste Management Board,
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Hazardous Waste Management System: Land Disposal Restriction, California
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Hazardous Waste Management System: Land Disposal Restriction, Solvents
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Hazardous Waste Management Technology: Draft Report (Task 2). U.S. EPA,
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Hazardous Waste Treatment and Resource Recovery Facility Feasibility S tudy.
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Identification and Evaluation of Sources of Capacity-Related Data for Hazardous
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December, 1984.

Improved Hazardous  Wastes Management Needs.   Chemical  Engineering
Progress, September, 1986. (Article)

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Incineration Permitting and Capacity.  Office of Emergency and Remedial
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Incinerator and Cement Kiln Capacity for Hazardous Waste Treatment. G.A.
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Incinerator and Cement Kiln Capacity for Hazardous Waste Treatment. Vogel,
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Municipal Solid Waste: Agenda for Action, Municipal Solid Waste Task
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Marine Protection, Research, and Sanctuaries Act of 1972,  as amended.

Medical Waste Tracking Act of 1988.

National Screening Survey of Hazardous Waste Treatment, Storage, Disposal,
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1985 National Biennial Reportof Hazardous Waste Generators and Treatment,
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National Small Quantity Hazardous Waste Generator Survey.  U.S. EPA,
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National Survey of Hazardous Waste Generators and Treatment, Storage and
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1984 Needs S urvey Report to Congress Assessment of Needed Publicly Owned
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New Jersey Hazardous Waste Facilities Plan, NJ Hazardous Waste Facility
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Ocean Dumping Ban Act of 1988.

Permitting of Land Treatment Units; EPA Policy,  and Guidance Manual on
Land  Treatment Demonstration.  J. Winston Porter, September 17, 1986.
(Memorandum)

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Potential for Capacity Creation in the Hazardous Waste Management Service
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Profile of Existing Hazardous Waste Incineration Facilities and
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Question of Effect of UST Cleanups on the Capacity of Subtitle C Facilities.
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Re-Analysis of the National Survey of Hazardous Waste Generators and
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Serious Reduction of Hazardous Waste, Office of Technology Assessment,
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Solid Waste Management, J.E.  McCarthy, R.E. Pannebaker, Environmental
and Natural Resources Policy Division, Congressional Research Service.May,
1988.

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Statement of J. Winston Porter on Capacity and Waste Minimization before the
SubcommitteeonEnvironment, Energy and Natural Resources of theCommittee
on Government Operations. U.S. House of Representatives, September 24,
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Industry: 1985  Update.  U.S. EPA, Office of Policy Analysis, ICF, Inc.,
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Industry: 1986 and 1987 Update. U.S. EPA, Office of Policy Analysis, ICF,
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Survey of Waste as Fuel: Track II. U.S. EPA, Office of Solid Waste, Westat,
Inc., November, 1985. (Report)

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Hazardous Waste Treatment Facilities. Prepared for the Office of Solid Waste
by Jacobs Engineering Group, Inc., January 3,1986. (Final Report)
            a-U.S Government Printing Office   19S9 -619-248/00766

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U.S. Environmental Protection Agency
Region 5, Library (PL-12J)
77 West Jackson Boufevar.d, 12th Floor
Chicago, IL  60604-3590

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