PROCEEDINGS
1975 Public Meetings on Hazardous Waste Management
Volume II
This publication (SW~9p) was compiled
under the direction of Alan S. Corson,
by Patricia A. Savage, Cynthia A. Baggatts, and Tawanna Holloway.
It constitutes the official record of the meetings
announced Sept&riber 17, 1975, in the Federal Register
and held by the Office of Solid Waste Management Programs,
December 2 (Newark, N.J.), December 4 (Rosemont, III.),
December 9 (Houston), and December 11 (San Francisco).
U.S. ENVIRONMENTAL PROTECTION AGENCY
1976
For sale by the Superintendent of Documents, TJ.S. Government Printing Office,
Vol. I and Vol. II Washington, D.C. 30402 - Price $14.00
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PUBLIC MEETINGS
held at the
SHERATON MOTOR INN
FISHERMAN'S WHARF
SAN FRANCISCO, CALIFORNIA
Thursday, December 11, 1975
8:30 A.M.
PANEL MEMBERS
.n P. Lehman, Director
;ardous Waste Management Division (HWMD)
'ice of Solid Waste Management Programs, EPA
.ter W. Kovalick, Jr. , Chief
.delines Branch, HWMD
fice of Solid Waste Management Programs, EPA
.aid B. Mausshardt, Chief
ilementation Branch, HWMD
:ice of Solid Waste Management Programs, EPA
iry Lazar, Program Manager
rironmental Damage Assessment, Technology Branch, HWMD
ice of Solid Waste Management Programs, EPA
:red W. Lindsey, Program Manager
ihnology Assessment, Technology Branch, HWMD
:ice of Solid Waste Management Programs, EPA
.rles Bourns, Chief
.id Waste Management Program
i Region IX
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oOo
THE CHAIRMAN: I call this public meeting to order.
Good morning, ladies and gentlemen. My name is John
P. Lehman of the Hazardous Waste Management Division, Office of
Solid Waste Management Programs of the United States
Environmental Protection Agency in Washington, D.C.
I would like to introduce Mr. Russ Freeman, Deputy
Regional Administrator of Region 9 of the United States
Environmental Protection Agency.
Mr. Freeman, please.
MR. FREEMAN: Thank you.
I have been asked or assigned the responsibility for
welcoming you to the meeting and making a few introductory
remarks to set the stage for this meeting this morning.
So I welcome you all to San Francisco. It is a great
city. It is a beautiful city. I hope you enjoy your stay here.
I don't know if the city is best known for its Golden
Gate Bridge or its cable cars or whether it is because it has
the tallest pyramid on the North American continent or because
it dumps raw sewage in the San Francisco Bay, but for whatever
reason it might be famous, it is a beautiful city, and I hope
you enjoy your stay.
I also wanted to take the opportunity, however, to
give you a little introduction to the Environmental Protection
Agency, because it is an agency that reaches far beyond the
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scope of the hearings in the hope that that will give you some
context for the type of hearings that we are having here today
and the purpose of such a meeting.
Our agency is perhaps best known to some of you becaus<
of its air pollution efforts.
They seem to be highly publicized, our efforts to
control the automobile in Detroit or the way it is used on the
street. Some of you .may know us for our efforts in water
pollution control, because we are indeed required to license
every discharge of water in navigable waters, and, indeed, we
are getting into the area of regulating discharge to ground waters
We run the largest capital construction programs, and
some of you may know us because of the amount of dollars we
spread around.
Here in California, for example, we spend $400 million
a year in sewage treatment plant construction.
Some of you may know us best for our pesticide
regulations, because we get a great deal of publicity when we
ban DDT or when we tell people they cannot use certain things
for certain things, again, without a registration or license.
And some of you may know us well because of our drink-
ing water regulations. As you know, we have had a new
bill passed that puts us in the business of insuring that every-
one who gets drinking water from a public system gets drinking
water that meets certain federally established standards.
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In addition to some of these very popular programs, how-
ever, we also have programs in noise abatement, and you may
have run into us there.
We have programs in radiation control, and you may
have heard of us because of that. And we have an emerging and
long-standing program in solid waste management that may well
be emerging under new legislation to join these other programs
in terms of publicity, stature, and so on.
Perhaps, however, some of you best know us as the
agency that can't seem to do anything right. And that is a
little bit what I would like to talk about this morning.
Part of the problem is that we are a regulatory agency
by design. That means we are charged with trying to find some
middle ground between the environmentalists who would like to
have nature in its pristine and pure state and the industrialist
who would like to have absolutely no control over his use of
hazardous substances, chemicals and so on in the environment.
And it seems that a person who is caught in the middle, even if
he comes to a conclusion with the wisdom of Solomon and chooses
exactly the right balance between these two interests, finds
himself in the following position:
That is, that the industrialist who wants to sell his
chemicals will indeed probably fall into line behind the center
position, because it does indeed let him keep his business,
and he is not banned altogether from the world.
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On the other hand, the environmentalist who would
like to keep the world pure and clean really does not tend to
fall in line, but tends to stick with that position of advocacy
for a pure and clean environment.
And so you find us oftentimes, once the decision has
been reached, seemingly in the camp of the enemy.
And there are textbooks written and a great deal said
about the fact that regulatory agencies are captured and get
into bed with those they try to regulate.
I would merely like to point out that that is the
nature of the regulatory process, that you essentially-, after a
debate is made in good faith and a decision is reached and the
position is taken, the regulatory agency tends to find itself
in the same railroad and on the same train with the group
regulated.
I think we should not be surprised by that. We should
just accept it as a part of the facts of life.
Another part, of the problem, however, has been our
approach in trying to do things. This is something that has
recently emerged in EPA as something which requires very serious
attention.
This is really complicated by two things that are in all
of our enabling legislation. One of those things is state
primacy — that is, the Federal regulatory laws work to have
the Federal government set standards and then direct the state
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government to see that those standards are carried out.
Now, many state governments, especially here in the
Western part of the United States, think that approach to a
problem is in fact unconstitutional, that if the Feds are going
to do something they may well be able to see that they are
carried out, but they have no mandate to direct and order the
states to see that they are carried out.
Well, indeed, the constitutionality of that approach
has been tested, and the courts have upheld it, but suffice it
to say that it does create a couple of problems for the
administrator of such a program. First you require a great deal
of diplomacy to walk in as a Fed to a state office and tell thos<
people what they can and cannot or should or should not do,
because there is nothing out of priority that makes a state
person very interested in taking orders from some Federal person
who does not pay his salary and does not fill out his performance
criteria at the end of the month.
The second part of that problem, however, is that when
there is a real tough question, one that in fact seems to have
no answer, the state oftentimes will indeed s>y so: His problem
has no answer.
Very interestingly, however, under environmental law,
EPA does not have the same discretion or latitude. The laws
very generally mandate that we carry things out. And in Los
Angeles we have to achieve air quality standards by the year
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1977 under the law, whether it is reasonable or not. The law
directs us to do it.
Indeed, there are citizens'rights under the law. If
we fail to do it, we can be taken to court by any citizen,
including any person sitting in this audience. And the courts
indeed — as history has shown us — will direct us to implement
enforceable regulations to achieve the mandate of law, because,
they tell us quite pointedly, that the business of changing
unworkable laws is the business of Congress, of the legislature;
and the business of interpreting interpretable law is the
business of the courts. And the agency is indeed charged with
carrying out the law.
Well, what that really means under state primacy is
that whenever you see EPA out in front on an issue, it is
generally a very controversial issue. It is an issue that
seemingly has no answers, because if there were answers, the
states probably would have taken the responsibility on and the
problem would have been solved.
So that is, again, just part of the facts of life
when you are talking about EPA.
The second and very real part of the problem, however,
has been our approach to rule making. In the past when we have
had an idea, whether it was our own idea or an idea mandated on
us by the courts through the process of civil citizen suits,
we essentially have said this is our idea. This is what we are
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going to do. We publish it in the Federal Register. We give yo
a few days to think about it and comment on it. We listen to
your comments. And then we promolgate it in the Federal
Register, and that becomes the rule of the day.
If we have learned anything from the process of trying
to implement laws with citizens' rights in difficult require-
ments, it is that this is really not a sufficient way to go
about dealing with the hard environmental problems. And so the
agency in the past year has tried very hard to turn this process
around and begin to have the dialogue before the citizens are
so incensed that they believe they have to take us to court
in order to get some action on an issue, and to begin to bring
the responsible parties into the dialogue before anything gets
in the Federal Register so that you have had a chance to think
about it before it is laid on you with 30 days for a deadline
to comment on it. And so that we have had a chance to hear
what you have said before we ever put pen to paper or to write
what goes into the Register in the first place.
That is the type of meeting we have here today. Under
the Solid Waste Disposal Act, EPA is authorized to gather and
disseminate information, to designate sites for hazardous
waste disposals, should that become necessary, and to develop
guidelines regarding hazardous waste disposal.
This is one of four meetings to gain a perspective on
the need for guidance for the proper management of hazardous
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waste.
We are interested in information that you may have on
a number of issues: what things ought to be classified as
hazardous waste; what responsibilities should rest with the
person who generates, the person who uses, and the person who
disposes of that; any information on the technical processes
for recycling or disposal of the waste; cost data; safety
precautions; monitoring and record keeping; insurance; methods
for insuring the long-term integrity of disposal sites; and
any of a number of other things which you may believe to be
important to this issue of regulating hazardous waste disposal.
A list of 16 specific areas of inquiry were included
in this notice of the meeting, as published in the Federal
Register of Wednesday, September 17th, 1975.
A transcript of the meeting today will be made, and
written comments may be submitted for the record up until January
31st, 1976. The transcript will be made available for public
review.
It is my pleasure at this time to introduce the chairman
of today's panel, who will set the ground rules for presentation
and who will introduce other members of the hearing panel.
Our chairman this morning is Director of the Hazardous
Waste Management Division of the Office of Solid Waste Management
Programs for the Environmental Protection Agency.
He graduated cum laude in engineering physics from
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our own university here in Berkeley, the University of
California. He has over 12 years' experience in industry in
the areas of toxic and hazardous waste management, and he has
over five years' experience with the Environmental Protection
Agency in the programs that he has managed.
Mr. John P. Lehman, panel chairman, Director of
Hazardous Waste Management.
John.
THE CHAIRMAN: Thank you, Mr. Freeman. Let me add my
welcome to that of Mr. Freeman.
The purpose of this public meeting, as announced in
the Federal Register, is to gather information and data for the
agency as to the scope and nature of the hazardous waste
management problem in this country and the need for and extent
of guidance that should be developed by the agency to help cope
with this problem.
For the purpose of this meeting hazardous wastes are
defined as the non-radioactive discards of our technology based
society.
They include the toxic, chemical, biological,
flammable and explosive by-products of the nation's extractive
and conversion and process industries. Discussion of radio-
active wastes is outside the scope of this meeting.
This is not a rule-making or regulatory hearing.
The agency does not have a proposal or a statement to .issue for
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comment.
This is a fact-finding meeting on the record to solicit
input from industry, labor, Federal, state and local government,
and other members of the public as to the extent of the mismanage
ment of hazardous waste and the available or anticipated systems
and technologies to abate the problem.
In order to provide a framework for the discussion today
the Federal Register notice, announcing this meeting, suggested
16 discussion topics that reflect issues of concern to the
agency. Commentary on these and other related topics are what
we are interested in today.
Copies of this Federal Register notice are available
at the table marked "Publications" at the entrance to this
room.
I am also submitting a copy of the Federal Register
notice for the record.
The panel here with me is composed of staff of the
Hazardous Waste Management Division in Washington and EPA's
Region IX Office here in San Francisco who specialize in certain
subject areas related to these issues.
They are from your left, Mr. Charles Bourns, Chief of
the Solid Waste Management Program of EPA's Region IX
Mr. Donald Mausshardt, Chief of the Implementation
Branch of the Hazardous Waste Management Division.
Mr. Walter Kovalick, Chief of the Guidelines Branch of
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the division.
Mr. Fred Lindsey, Program Manager for Technology
Assessment in the Division.
And Mr. Emery Lazar, Program Manager for the
Environmental Damage Assessment for the Division.
Also with us today, although not in the room at this
moment, are Mr. Alan Corson and Mr. Cam Metcalf of our staff
in Washington.
In addition to this meeting in San Francisco today,
three other identical sessions were held in Newark, Chicago
and Houston during the first two weeks of December.
Persons not wishing to deliver a statement here may
send a written statement to the address noted in the Federal
Register before January 31st, 1976.
As our time here is limited, I would now like to
describe the procedural rules for this meeting which I feel will
maximize the opportunity for persons interested in speaking
to be heard and yet make the best possible use of all of our
time.
Persons wishing to make an oral statement who have not
made an advance request either by telephone or in writing
should indicate their interest on the registration card. If
you have not indicated your intention to give a statement and
you decide to do so, please return to the registration table,
fill out another card and give it to one of the staff.
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As we call upon an individual to make a statement, he
should come up to the lectern and, after identifying himself for
the court reporter, deliver his statement.
At the beginning of the statement, I will inquire as
to whether the speaker will be willing to entertain questions
from the panel. He is under no obligation to do so, although
within the spirit of this information sharing meeting it would
be of great assistance to the agency if questions are permitted.
It is expected that statements will not exceed 15
minutes in length. For extraordinarily long written statements,
I would suggest a brief oral summary and submission of the full
text for the record.
The chairman reserves the right to close off statements
which are excessively long, irrelevant, extraneous or repetitive.
Assuming that the speaker is permitting questions,
members of the audience will not be permitted to directly
question the speaker. By raising their hands, members of the
audience may obtain a three-by-five card from a member of the
staff upon which questions may be written. These cards will be
collected by the staff and returned to the panel for consideratiojn
during the question period.
If a written question from the audience is not presented
to the speaker because we run short of time, I will ask the
speaker to respond to those questions in writing for the record.
As Mr. Freeman indicated, a transcript of this meeting
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is being taken, and a copy of the transcript together with
copies of all documents presented at the hearing and all written
submissions will constitute the record of the meeting.
A copy of the record will be made available for
public inspection by March 30th, 1976 at the United States
Environmental Protection Agency> Public Information Reference
Unit, Room 2404, 401M street, Southwest, in Washington, D.C.
Finally, I would like to describe the day's activities
as we currently see them.
We will recess for a 15-minute break at about 10:15
a.m., and a one and one-half hour lunch break at 12:00 noon,
and then reconvene at 1:30. Another 15-minute break will be
held at 3:30 p.m.
Depending on our progress, I will announce plans for
a dinner break after lunch.
At this time, based on the number of people who have
indicated an interest in speaking, we plan to conclude this
meeting today.
This concludes my opening remarks. And I would now call
upon Dr. Harvey Collins of the State of California to deliver
the first statement.
Dr. Collins, please.
DR. HARVEY COLLINS: Mr. Chairman, members of the
panel, ladies and gentlemen, my name is Harvey F. Collins.
And in answer to your question, Mr. Chairman, I will
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be willing to answer questions if I can.
I am in charge of the Waste Management Unit, California
Department of Health in Sacramento.
The Department is mandated by law to develop and
enforce regulations governing hazardous waste to protect against
hazards to the public health, domestic livestock, and wildlife.
In developing and administering this program, the
Department has been very involved over the past few years in
addressing the many complex problems and issues concerned with
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hazardous waste management.
Most of the concerns expressed by EPA in the list of
Discussion Topics for this meeting have also been of interest
to us. Today I would like to briefly sumroarzie the policies and
opinions of our staff on some of these topics.
What is a hazardous waste? In the written document
which I will submit I have quoted California law defining a
hazardous waste and an extremely hazardous waste. And I will not
go into the details of those definitions.
The California Hazardous Substances Act is tied in
with Federal Regulations as published in the Code of Federal
Regulations, Title 16, Chapter 11 for hazardous substances,
which detail criteria and testing methods for toxic, corrosive,
flammable and irritating substances.
The criteria, unfortunately, are aimed primarily at
pure substances. Wastes are seldom pure substances, but rather
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they are usually mixtures of many chemicals and are often made
up of several physical phases. A mixture of hazardous
substances may be more or less hazardous than the pure
substances because of synergistic and antagonistic effects
which are not well understood. There are presently insufficient
data available to set concentration limits for most hazardous
substances. In view of these data gaps, the waste mixtures
themselves must be tested if their hazardous properties are to
be fully elucidated.
In most cases hazardous waste producers are hesitant to
conduct detailed tests on their waste mixtures in order to
determine their hazardous properties because of the large
expense involved. There are approximately 500 to 1,000 loads
of potentially hazardous wastes being delivered to disposal
sites in California each day. Few of these loads are identical;
yet, it would be very expensive to test each individual load.
Our approach to determine which wastes may be
hazardous has been to establish two lists. The first is a
list of hazardous chemicals and the second a list of extremely
hazardous chemicals.
I will not go into the criteria to show how those
lists were established, but I have summarized them in the
written statement which will be presented. It goes into the
LDSO's, acute inhalation, acute skin contact, et cetera, et
cetera.
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Our position, therefore, in the absence of other data
has been that any waste mixture that contains a hazardous or
extremely hazardous component will be considered hazardous by
the State of California.
Now, in order to aid persons in the field who have to
safely and legally handle and dispose of hazardous wastes, we
have also prepared lists of wastes according to their generic
names with probable chemical components. This enables these
persons to spot loads of wastes which are potentially hazardous.
This approach admittedly is not the most technically
satisfactory one. It does not take into account dilution of
the components nor synergistic or antagonistic effects.
We believe,however, that in the absence of substantial
data on the hazardous properties of mixtures, this is one of
the few approaches that can be reasonably taken. Our regulation;
contain a section which provides an alternative for those waste
generators who may believe that their particular waste should
not be considered as hazardous even though it may contain
hazardous substances. In these cases the generator may test
his mixture directly and present the data on the waste to the
Department for review and possible reclassification as non-
hazardous.
In regards to sampling and analysis of hazardous
wastes, ideally, samples of every waste material would be
analyzed to determine if it contains hazardous substances. We
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feel that this can best be done by the generator or the producer
of the waste. However, regulatory agencies like ourselves are
also concerned. We are very active in developing approaches
to characterizing waste streams for purposes of enforcement
and surveillance. Under the auspices of the federal EPA, we
are conducting an intensive sampling and analysis effort of
potentially hazardous wastes which are produced in California.
We have designed and tested a sampling apparatus
which allows us to sample wastes in a truck. We are also
developing prescreening techniques for wastes and are preparing
a decision tree approach to aid in the sequence of steps
necessary in the analysis of various waste mixtures. Procedures
that are being developed include the, quote, "gunk to standard
analysis," quote, methods — those approaches needed to convert
what may often be a hard-to-handle sludge, tar, or emulsion into
a form that is compatible with standard chemical analyses.
Many of the wastes that we recover or sample at
hazardous waste disposal sites have very little documentation
data accompanying them, such as source and probable components.
In these cases the analyses must start from scratch.
We are presently investigating rapid screening, general analyses
using such instrumental approaches as gas chromatography coupled
with mass spectroscopy, emmission spectroscopy, and X-ray
flourescence in order to rapidly obtain information on the
general sorts of organic and inorganic constituents in the
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wastes.
With regard to legal responsibilities, our position
is that the producer of a waste also has the legal responsibili
to provide reliable data on the composition of his waste and
on any potential hazards that may be associated with it.
This is required of hazardous waste generators by
California law. The information must be provided on a state-
established hazardous waste manifest, and the manifest must
accompany the waste load to the disposal site so as to aid and
alert handlers and disposers of its proper handling and
disposal.
Current guidelines, soon to be adopted as regulations,
require that all generators or producers of hazardous wastes
notify our agency in writing with this hazardous waste manifest
in regards to each load of hazardous wastes which has been
picked up at his facility.
In addition, the waste disposal site operator is also
required to send us these manifests at the end of the month.
In regard to treatment or reuse of hazardous wastes,
we feel that prior to the application of many hazards wastes
to land, we feel that this would be desirable. However, it is
an extremely complicated area in which economic, environmental
and social tradeoffs are often necessary. Variables that
must be considered are: economics; hazard or environmental
pollution potential of the waste.; the geology, the geography,
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the climate and the local regulations and restrictions, to name
a few.
It is the general belief of our staff that most
hazardous wastes,however, can and should be recovered and reused
or they should be treated to less hazardous forms prior to final
application to the land. Most large volume, untreated liquid
wastes should not be dumped directly onto the land because of
the severe hazard they can present to public health and the
environment.
Hazardous components of such wastes should be recovered
destroyed, or neutralized prior to ultimate disposal. In
certain areas the most economical and safest method of disposing
of highly treated, large volume aqueous wastes is solar
evaporation. In some cases large volumes of untreated organic
and oily wastes may be deposited directly onto the land, where-
upon soil microorganisms will consume organic constituents.
Persons practicing this method, however, should make certain
that the wastes contain no persistent components such as heavy
metals that may present long-term environmental pollution
problems.
Many tons of relatively pure chemicals are buried in
California landfills each year. Although these materials often
have considerable value, burial by landfill has been the
traditional fate for many off-specification or old chemical
stockpiles accumulated by industries, laboratories, and
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universities.
In many cases these materials present the most severe
threats to personnel involved in handling them and to the
environment because of their concentrated forms and often
deteriorating containers. It is our position, therefore, that
whenever possible these materials should be diverted back into
the market.
With regard to safety and security in handling of
hazardous wastes, we feel that the most important precaution
that can be instituted to protect personnel, the public, and
the environment is proper characterization and identification
of hazardous wastes. All safety precautions at any hazardous
waste facility including containerization, fire prevention,
site security, employee training, et cetera, hinge on a
complete knowledge of what kinds of wastes are being handled,
as methods and precautions will vary with different kinds of
wastes.
At any hazardous waste facility, therefore, effective
screening and inspection of all wastes coming into the site is
the first stage in an effective safety program.
Other considersations in a safey program are: training,
proper fire fighting equipment, et cetera.
In regards to enforcement, in view of the vast
geographical size of California and the diversity of its industries,
control of hazardous wastes on a statewide basis requires a
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major surveillance and enforcement program. The limited number
of approved hazardous waste disposal sites in California and
the fees charged for disposal of hazardous wastes have
encouraged illegal disposal.
Recent evidence, verified in part by the Department
and other state agencies, indicates that appreciable quantities
of hazardous wastes have been deposited in unapproved areas.
Therefore, one of the primary goals of the Department is to
immediately expand its surveillance and enforcement program
to ensure proper management of hazardous wastes.
Fortunately, we recently obtained approval to employ
six additional persons using state funds. We also recently
received an EPA grant for $200,000 to increase our enforcement
activity. This will allow the Department to hire
enforcement teams in both the Los Angeles and Berkeley offices.
Hopefully, this expanded effort, as well as the
enforcement efforts of other state and local agencies, will
help minimize illegal activities.
In summary, I have attempted in the short time period
allowed to express some of our approaches in dealing with
hazardous wastes in California and to express some of our
opinions on the topics which we have found to be the most
perplexing.
EPA is to be commended for its active leadership in
the field of hazardous waste management. Results of these
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meetings should allow EPA to provide even further guidance to
state programs. Strong Federal leadership, hopefully to be
strengthened with pending Federal hazardous waste management
legislation, combined with strong state programs, is absolutely
mandatory if we are to truly manage hazardous wastes.
THE CHAIRMAN: Thank you. Dr. Collins.
I would like to remind the audience that if you wish
to address questions to Dr. Collins or any of the speakers,
merely raise your hand and members of our staff; will give you
three-by-five cards upon which you may write questions.
Do we have questions?
Yes, Mr. Lindsey.
MR. LINDSEY: Dr. Collins, could you comment for us
a little bit further on the effectiveness of your three-part
ticket or manifest in eliminating the disposal problems that
you have.
DR. COLLINS: We have high hopes, Mr. Lindsey, that
the manifest system will do more for us than any 50 inspectors
in the field.
Now, I was telling some fellows yesterday that the day
of grace is about over. By that I mean that thus far we have
only been able to analyze those manifests manually, and we
have merely roughly screened them. However, we do have a
computer program that has been written. It has been debugged,
and we are in the process of recruiting a chemist that will take
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the data from those manifests, get them into keypunch form,
and we are contracting with the University of California at
Berkeley to provide us with a keypunch operator and the computer
time.
We hope to have that program on-line by February 1.
We will then hopefully keep up and then work back in our stock-
pile of manifests. I am sure there will be many problems in
getting industry representatives to fill those manifests out
correctly. But if correctly filled out, it will work.
THE CHAIRMAN: Mr. Lindsey, do you have a question?
MR. LINDSEY: This comes from the audience.
Are waste manifests required on the same site where
they are generated?
On-site disposal, is a manifest required there?
DR. COLLINS: No. If they are not hauled on the road-
ways they are not required. However, there will be reporting
systems required later. But at this time, no manifests are
inquired unless they are transported on the highways, railroads,
et cetera.
THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: Dr. Collins, it is a pleasure to ask
questions of someone who has to face the reality of the program.
We have had testimony in three other locations pointing
to the California program, so I would like to ask you several
questions relating to your experience which should be very
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valuable for us.
One of the comments we received most recently in
Houston was that the way in which one ought to define our
hazardous waste is to not only know what hazards, that is,
acute hazards it has, but also know how it would be disposed of.
If you know both those things, many,many things would not be
hazardous, because you would be sure of the way in which it was
disposed. And there was encouragement from several speakers
that that was the way it should be done, to take into account
its immediate, acute hazards, and if you have knowledge of its
disposal, then you call it a hazardous waste.
I gather from your testimony that that is not the
system you have chosen, that things are labeled potentially
hazardous wastes first, and then that leads them into a
management system where you then see how they are ultimately
disposed.
Would you comment on the desirability of the approach
you have chosen versus one where you have to know both the
hazards and its destination in order to call it a hazardous
waste.
Am I asking a feasible question?
DR. COLLINS: I think so, Mr. Kovalick.
In California the law specified what would be
considered a hazardous waste. So we, therefore, were required
to define hazardous wastes in terms of their constituents.
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It is true that you need to know the ultimate disposal
method. And when we issue permits for the disposal of
extremely hazardous wastes, then certainly we evaluate that
waste from the time it is picked up, how it will be picked up,
how it is hauled, and its ultimate fate.
And so ideally, I think they have a point, legally
and practically, we could not do this.
MR, KOVALICK: Could I ask a couple more questions,
Mr. Chairman?
THE CHAIRMAN: Yes.
MR. KOVALICK: I was very interested also in other
testimony we have had that speculated about the effect of good
regulations in one state and their effect on neighboring states led
Have your relationships with neighboring states led
you to any conclusions about the net inflow or outflow of
waste to those states because you have a certainly well-defined
and apparently more effective system than they might havel
DR. COLLINS: Yes, we are very concerned with that,
Mr. Kovalick.
In fact, I have chatted with agencies from other
states and told them when they got a program going we would be
more than glad to share information and even trade manifests,
if you will.
And this is one of the main reasons we would like to
see Federal input here, so that the states would have a. fairly
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uniform system. Otherwise, as California develops it program,
it merely will allow more exportation or lead to more exportation
of those wastes to other states.
So we would like to see this program fairly uniform
nationwide.
And I think also reputable businesses would endorse
such a philosophy.
THE CHAIRMAN: Mr. Bourns, you had a question?
MR. BOURNS: In fact, I have two questions. One has
several parts, if you don't mind.
The first, Dr. Collins, relates to a remark you made
about the limited number of sites in California and their
capacity.
Would you care to comment as to the need for more of
new sites first, and second, the environmental acceptability of
the present sites and whether or not they should be privately
owned and publicly regulated or publicly owned.
DR. COLLINS: Let me take your last questions first,
Mr. Bourns.
My personal philosophy is that all site operators
should be treated equitably regardless of whether they are
privately or publicly owned. And I think that industry in this
state has played a vital role in the waste management state-
wide. So in fact, we are very pleased with some of our private
operators. So I would say that government and private industry
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both have a. role, and any regulatory agency must deal with both
private and public entities on an equitable basis and treat
them both alike.
In regards to the other part of your question, as to
whether or not there are enough sites. Chairman Dave Baker is
here. He chaired a liquid waste committee for the State Solid
Waste Management Board. I served on that committee as did a
representative from the State Water Resources Control Board,
and I believe he will address that this afternoon.
The results of that committee's findings were that,
no, there are not enough sites. And he will speak to that
i further.
In regards to whether or not the current capacities of
those sites — is that correct — what was the other question?
MR. BOURNS: The environmental acceptability of
present sites and their capacity.
DR. COLLINS: Well, Mr. Baker will speak to the
capacity issue. As far as the environmental acceptability of
those sites, I would hate to say off the cuff yes or no, they
are not environmentally acceptable.
I think that the concept of a Class One site in
California, as you know, is that theoretically they are a
contained site. If indeed that is true, then the sites are
the most economical solution to deposit these hazardous residues
And before we say that they are all bad, I would hope that ther«
389
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would be a real technical study made of each site including
drillings, et cetera, and if indeed this data shows that those
sites are not environmentally safe, then they should be closed
down.
But I do not think the decision should be made without
a thorough engineering study of each site.
MR. BOURNS: You think the sites should be reevaluated?
DR. COLLINS: Oh, I think we are all in the process
of evolution. I think we need to constantly monitor and
evaluate these sites. And in fact, some sites have been closed
in California in recent months because they were found that they
did not meet the criteria. And certainly as we get more
information we may tighten up on others.
MR. BOURNS: One other question.
A question was asked concerning waste imported to
California. And you spoke to the area of cooperation with
other states. But is the volume of hazardous wastes now importec
to California a sizable amount?
DR. COLLINS: Without having our computer on-line, I
cannot answer that. We know by the grapevine that some wastes
are imported from clear across the nation.
My personal philosophy, and I think — well, in fact,
the staff of the Department, our contention is that we should
not restrict the flow of waste across county boundaries or
even state boundaries, because if we are going to truly manage
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it, we have got to look at the nation as a whole. And so,
therefore, we do not object to importation of waste as long as
they are managed according to state regulations.
THE CHAIRMAN: Mr. Mausshardt, do you have a question?
MR. MAUSSHARDT: I have a question from the floor, Dr.
Collins.
The question is stated: "How does California distinguish
between hazardous materials and hazardous substances?"
DR. COLLINS: Mr. Mausshardt, the California law listed
by tying it into this Hazardous Substance Act, we were to define
hazardous waste in such a way that technically we almost had
to tie it into hazardous substances.
We realize that even though that may meet the legal
requirements, it leaves much to be desired technically and from
a practical viewpoint.
Therefore, we were forced in essence to develop our
guidelines in which we listed those wastes in accordance with
generic terms so that the common man handling those wastes would
know what we were talking about.
So I agree, it leaves much to be desired, but legally
we had to go this route.
THE CHAIRMAN: Mr. Lazar.
MR. LAZAR: Dr. Collins, a question from the audience.
How does a rendering company maintain traceability when
wastes from more than one source are hauled in the same truck?
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How complicated does it get when a truck picks up waste
from several sources, and how do you handle that?
OR. COLLINS: As long as those wastes are compatible,
this is common.
We have had problems in which incompatible wastes were
mixed in the same truck which, of course, must be avoided.
Our guidelines document, which I will provide to the
gentleman if he will see me, speaks to that, —
if they will take the information and attach those to the common
liquid waste hauler's record and that is filled out, how to
handle the trucks that are picking up the various loads from
different lots. And different generators.
THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: Yes. I have one from the audience.
This is in several parts. To what extent will the
state carry out enforcement with its personnel? In other words,
will the surveillance be directed primarily at the disposal
site, the producers, or the haulers? And is local authority
to carry out additional enforcement being delegated?
DR. COLLINS: Mr. Lindsey, yes. The enforcement at the
state level will address not only the disposer, but it will
address the trucking industry. It will also address the
generator. In our manifest system every industry will be
catalogued statewide. And if we are not getting manifests from
those industries, then we will ask why, what are you doing with
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your waste, are you recycling it, et cetera.
In regards to the enforcement, at the state level we hop
in the Department that — well, let me back up. Legally the
director can delegate the enforcement of the state regulations
to the local health department or other local entities.
Now, we had thought that perhaps the enforcement
agency that is delegated in the county solid waste management
plans, that that would be the logical agency to enforce the
hazardous waste regulations.
There are problems with that approach, however, if
that local enforcement agency is not countywide.
Also, it will depend on the philosophy of that local
agency, the expertise that that local agency has, et cetera.
And we have taken the position in the Department that
any local agency wanting to enforce the hazardous waste
regulations should submit said proposal to the Department. We
in turn would take it to our Hazardous Waste Technical Advisory
Committee and handle it on a case-by-case basis.
THE CHAIRMAN: I think Mr. Mausshardt has a related
question.
MR. MAUSSHARDT: I have another question from the floor
Dr. Collins.
In the case of an improperly operated or illegal Class
One site, how long is required to enforce compliance? How could
the enforcement process be improved? That is a two-part questioi
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DR. COLLINS: Well, I am sure that the audience realizes
as well as I, Mr. Mausshardt, the problems you get into when
you get into litigation.
The Hazardous Waste Act merely states that if there is
a violator you shall gather the facts and certify said facts to
the District Attorney in the county. If the District Attorney
does not act, then we are required to certify the facts to the
Attorney General.
How long this takes would no doubt vary from case to
case.
In regards to the fact that if a site is not meeting
criteria or — I believe it was worded as an "illegal site" —
here again, usually there are several agencies involved. Most
of these sites, many of the sites, also have solid wastes
deposited at those sites. So here you have got the Solid Waste
Management Board. Also in California the Regional Water Quality
Control Board sets discharge requirements on each site.
So it is usually a time—consuming process. The various
agencies get together to see whether or not their regulations
are being violated; what should be done to improve the site.
In our philosophy in the Department, and I am sure in the State
Solid Waste Management Board, our philosophy has been we will
work with industry to try — or government — to try to get the
needed improvement.
Then if we cannot, the last step would be legal action.
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THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: Dr. Collins, we have heard across the
country of the extreme difficulties in obtaining public
acceptance of hazardous waste sites, whether they be treatment
sites or disposal sites or both.
Can you comment on your experience in this regard and
how you see getting around this problem in California in future.
DR. COLLINS: Mr. Lindsey, yes. It is a very, very
controversial subject. It has been a joke, in fact, in the
technical field for years that the best place for a site is
over the hill. And now people live over the hill.
And in California there were two occasions in the last
year in which proposed sites went down to defeat as a result
of local political opposition. And here again, the Liquid
Chemical Waste Committee that I referred to earlier which
Mr. Baker chaired, we asked that same question in hearings we
held last summer statewide. And we asked the question in view
of the local opposition, might not the state be required or
should not the state have the authority of eminent domain.
We realize this sort of conflict with local control
but on the other hand, many local officials testified that they
would welcome the state to have authority to come in and take
that pressure off them.
Now, right now, there is an assembly concurrent
resolution that has been passed, No. 79 in the state, that directjs
-------
the State Solid Waste Management Board, the Health Department,
the Department of Food and Agriculture, the State Water
Resources Control Board to do a statewide study on the need for
additional Class One sites, on the problems involved, and the
role that the state must play.
So the results of that committee could well plot a
path that California will go in the future. Whether it will
involve eminent domain or the recommendation for legislation for
that, I do not know. But certainly something has to be done.
Otherwise good sites that are perfectly acceptable from every
technical viewpoint will never be accepted due to political
opposition.
THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: Dr. Collins, with regard to the manifest
system again, are Federal agencies or Federal facilities them-
selves or government-owned, contractor-operated facilities
currently users of the manifest system?
And, if so, what percentage of your business, if you
will, do they represent? Do you have any idea?
DR. COLLINS: In regard to the latter portion, Mr.
Kovalick, I do not know the percentage of the business. It is
my understanding, some of them are using it. I have had a few
rumbles that perhaps not all of them, and in fact, I have had
the comment tossed out that maybe they are exempt.
I think that Mr. Bourns sort of convinced a certain
-------
individual last week at Reno that maybe they weren't exempt,
that maybe EPA could help influence them to cooperate.
Certainly, we feel that in the state that all Federal
entities should cooperate in the spirit of cooperation to insure
that the wastes are really managed. And unless they do, they will
not be managed. So we would hope that this will be prevalent
throughout, whether private or state or Federal.
MR. KOVALICK: I have one other unrelated question.
We had a comment at a couple of the other meetings
about the training needed for a person working both a treatment
facility as well as a person working in a disposal, straight
disposal facility. And there were those who pointed out that
there -.»ere sufficient training materials available from the
chemical industry, for example, to provide for the training
of those persons and that there did not seem to be much additionajl
need for — not necessarily not need for training — but need
for training materials or some kind of assurance that some train-
ing has been given.
What is your current approach to that issue, since you
mentioned it in your remarks?
DR. COLLINS: I personally feel that the training
material available is probably of too technical a nature. It
is written mainly for the chemists, et cetera, and I feel it is
of too technical a nature for the operator of those sites to
understand; so I feel that there is need of a statewide training
-------
program, hopefully with leadership from EPA, in which the
available information will be gathered from every source,
condensed, and simplified, if possible, so that you can go out
and explain to the truck drivers and to the operators of the
equipment in language that they can relate to and they can go
away feeling that, yes, I learned something other than they
tried to snow us.
So I disagree with that philosophy that, yes, there is
enough information available. It has got to be assembled and
simplified. And we do hope to get into this area, but it is a
matter of priorities, and thus far we have not been able to
put out enough fires to get to it.
THE CHAIRMAN: Mr. Bourns.
MR. BOURNS: Dr. Collins, I have a question from the
floor, and the person who wrote this question emphasizes certain
words, and I will try to do likewise.
He says we all are for private enterprise, but —
capitalized — how is the private waste site operator receiving
waste from many sources protected from local citizens' harrassment
resulting in politcal discussion to shut down. Witness River-
side County Class One site.
In short, is there really a future for private site
operators?
DR. COLLINS: Yes. I think so. And I think that in
our complex world, there are too many of us. And I feel that
-------
regardless of whether you are a government operator of a site
or a private operator of a site, you are going to be subjected
to the same type of criticism. And therefore it behooves each
operator to put his shop or his site in order and try to
minimize said criticism.
And here again, I think it is a matter of educating
the public. You cannot overnight in my opinion shut down that
site. Industry will find a way. Technology, in my opinion, is
not here yet to completely reclaim or detoxify, perhaps, many
of these wastes. So I think it is a matter of educating the
public, doing our best to minimize the problem so that we
minimize that criticism.
But this should not apply to just private sites. This
same opposition is directed at governmental entities operating
the sites. For example, LA County Sanitation District, Ventura
and others have come under the same public criticism as have
private operators.
THE CHAIRMAN: All right, Dr. Collins. I have one last
question from the audience, and I think it should be a short
answer.
Is a producer of waste material required to fill out
a waste manifest if the waste is not hazardous?
DR. COLLINS: If it is a liquid waste, the answer is
yes.
if it is a hazardous waste, the answer is no.
-------
And I will clarify it briefly, then I will sit down.
The Porter-Colon Act administered by the State Water
Resources Control Board requires that a California liquid waste
hauler's record be filled out by every liquid waste hauler.
Now, in order to cut down paperwork, we adopted that
liquid waste hauler's record, and we specified that all haulers
of hazardous waste would have that manifest in his possession.
So, consequently, you have to fill it out in order to
satisfy the State Water Resources Control Board whether or not
it is hazardous.
If it is not hazardous, though, do not send it to us.
If it is hazardous, send us a copy, and then we will get the
copy from the disposer.
So it was not quite a 'yes* or "ho" question.
THE CHAIRMAN: Dr. Collins, thank you very much.
I think we are running a little short of time. I
appreciate very much your remarks, and obviously they have
stimulated a lot of questions. And I think it was time well
spent, because I would just say the State of California does
have, I think, the most advanced program in hazardous waste
management in the country, so obviously we have a lot to learn
from you.
Thank you very much.
DR. COLLINS: Thank you very much, Mr. Chairman.
1000
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STATE OF CALIFORNIA—HEALTH AND WELFARE AGENCY
EDMUND Q BROWN JR.. Gonrnor
APARTMENT OF HEALTH
4 P STREET
SACRAMENTO, CALIFORNIA 9M14
(916) 322-2337
January 28, 1976
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs
U.S. Environmental Protection Agency
1835 K Street, N.W.
Washington, D.C. 20460
Dear Mr. Lehman:
At the December 11, 1975 meeting in San Francisco regarding
hazardous waste, Mr. Alfred Lindsey of your staff asked that we:
(1) identify the concerns of the California State Department of
Health regarding the long-term disposal of large amounts of un-
treated liquid wastes to land in spite of favorable hydrogeologic
conditions; and (2) what safeguards are practiced at hazardous
waste disposal sites in California to protect personnel from
accidents resulting from mixing incompatible wastes? We developed
the following statements about these two subjects in collaboration
with Mr. Lawrence A. Burch, Deputy Executive Officer, California
State Solid Waste Management Board.
1. Department Concerns
The Department is concerned with disposal methods which in-
volve the deposition of large volumes of untreated liquid
wastes to the land. The reasons for this concern are discussed
below:
a. Evaporation/infiltration Ponds
The deposition of certain untreated liquid wastes directly
into evaporation/infiltration ponds is undesirable from
a safety, public health, and environmental standpoint.
Many untreated liquid wastes contain materials that are
odoriferous and that are potential air pollutants, such
as acids, sulfides, and volatile organic solvents. The
mixing of untreated wastes together in ponds in a random,
uncontrolled manner can result in undesirable interactions
which can cause fires, violent chemical reactions, and
discharge of toxic substances. Generally, volatile,
odoriferous, and potentially reactive components of liquid
wastes should be destroyed, removed, or neutralized before
the wastes are placed in evaporation ponds.
1001
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Mr. John P. Lehman January 28, 1976
b. Land Spreading
For most of the reasons that ponding of certain untreated
liquid wastes is undesirable, so is landspreading. In the
landspreading operation, liquid waste is allowed to flow
over a prepared area of land, whereupon the volatile com-
ponents evaporate and the remainder of the waste soaks
into the soil. Certain materials in wastes, e.g., oils
and sodium, can lower the absorptive capacity or the
permeability of the soil and, as a result, highly limit
the applicability of the method to large volumes of wastes.
c. Landfill and Trench Burial
' These methods involve the preparation each day of a basin
in a solid waste landfill or a trench in the soil. Un-
treated liquid waste is unloaded directly from trucks into
the basin or trench. The waste is then mixed with solid
waste or soil and covered. These methods probably offer
the greatest potential for untreated incompatible wastes
to interact unless the site operator is very careful in
screening incoming wastes. In addition, the vapors and
mists produced during the unloading, mixing, and burial
of untreated hazardous wastes pose an acute and chronic
threat to the health and safety of workers involved in
these operations and to the health of the public in the
vicinity of the site.
d. Security at Filled Disposal Sites
Filled disposal sites that received untreated liquid wastes
might contain persistent hazardous contaminants at the
surface or in the shallow subsurface layers of the soil.
When such sites are closed, it might be necessary to seal
off the contaminated soil for long periods of time to
prevent humans or animals from encountering the contaminants
and to prevent erosion of those contaminants. Which
individuals or government agencies will be held responsible
for maintaining disposal sites after closure and for
monitoring them for possible problems has not been settled
yet in California, but corrective legislation will be
introduced soon.
e. Unknown Hazards
The site classification system used in California may
impart a false sense of security to the site operator, the
waste producer and the regulatory agencies. That is, they
1002
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Mr. John P. Lehman January 28, 1976
may assume that the site would automatically handle the
liquid wastes and that Mother Nature would be forgiving.
It must be acknowledged that geophysical examination of
a parcel of land proposed for disposal of dangerous
chemicals faces limitations of financial resources and
there are practical limitations on testing procedures and
evaluations. In other words, we really do not have com-
plete knowledge of what exists underground and what future
situations are yet to be encountered.
f. Site Operation
The operation of a disposal site must follow a reasonable
plan. Designers, operators and regulators of these sites
have to acknowledge that the disposal site has finite
limits regarding the storage capacity either in the land-
fill sponge or in the underlying deposits and formations.
If the storage or field capacity is exceeded then an over-
flow or surface discharge will occur following the laws of
science.
On the other hand, a properly managed landfill that is
indeed "secure" is the most cost-effective method of
hazardous waste disposal. Recently, core samples were
obtained from a Class II-l site in California from depths
up to 88 feet. Surprisingly the refuse at the greater
depths was dry even though the site had been accepting
large volumes of liquid wastes for years. Evidently,
the field capacity of the buried material had not been
exceeded.
g. Loss of Resources
After untreated liquid wastes have been deposited on land,
any valuable constituents they contain are usually lost.
Strenuous efforts directed toward resource recovery could
substantially reduce the impact of the Department's con-
cerns discussed above.
Safety Precautions
The operations at hazardous waste disposal facilities in
California vary considerably from site to site. At some sites
there is little or no control of what kind of wastes are
accepted and how they are mixed. Minimal effort is expended
to properly identify the wastes and to prevent the mixing of
incompatible wastes. As a result, numerous accidents have
occurred from the mixing of incompatible wastes. Haphazard
-------
Mr. John P. Lehman January 28, 1976
mixing of chemicals may occur due to either unknowledgeable
personnel operating the site and/or poor knowledge of the
content or characteristics of incoming wastes and their
interaction with wastes already present in the site.
At several sites, on the other hand, the operators maintain
staffs of chemists and engineers who thoroughly review each
waste load that arrives at their sites with regard to its
composition, properties, and compatibilities. At three sites
in California, on-site screening laboratories are maintained
to check the chemical and gross properties of waste loads
before they arrive at the gate or prior to deposition in the
site.
Based on these evaluations waste loads are assigned to
specific ponds, trenches, wells, or receiving tanks to prevent
their being mixed with incompatible wastes.
There are presently very little data available to operators on
the compatibility of hazardous wastes. Much of the compatibility
information available to operators is that which they have
learned by trial and error (often spectacularly) or by use
of common chemical sense (e.g., don't mix acids and cyanides;
acids and sulfides; oxidizers and solvents; water-reactives
and water; etc.).
The single most important deterrent to more effective control
of incompatible wastes is the lack of compatibility lists
compiled specifically for hazardous wastes which also list
potential interactions under normal disposal conditions.
Hopefully, the above lengthy discussion has answered the two
questions. Please let us know if we can be of further help.
Sincerely,
VECTOR CONTROL SECTION
Jollins, Ph.D.
Supervising Engineer
Waste Management Unit
HFC:b
cc: Richard F. Peters, Chief VCS
Charles T. Bourns
Earl Margitan
David L. Storm, Ph.D.
Lawrence A. Burch
1GO<»
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THE CHAIRMAN: Next I would like to call Mr. Sidney
Howaru of the EIMCO BSP Division of Envirotech Corporation.
Will you take questions?
MR. F. SIDNEY HOWARD: Yes, we will.
Mr. Chairman, panel, ladies and gentlemen, we
appreciate the opportunity to speak before this group. And our
concern is that of an industry manufacturing equipment used
in solid waste disposal.
We hope to bring before the group a little background
information.
My name is F. Sidney Howard, and I am Marketing Manager
of the EIMCO BSP Division of Envirotech. We are one of the
leading manufacturers in sludge processing and disposal equip-
ment including multiple hearth furnaces and other thermal
devices.
We have in the last 13 years built over 100 units for
municipal sludge disposal for sewage treament plants.
In regard to the control and detoxification of wastes,
we believe our developments in multiple hearth furnace technology
are of considerable importance. Although this hearing is
primarily concerned with hazardous waste management, I would like
to take a few minutes to update the often misunderstood aspects
of sludge incerineration/reclamation furnaces to show that
slude incineration/reclamation is an environmentally viable
and energy efficient means of hazardous waste disposal.
Thanks to both EPA and industry sponsored research and
1005
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
SAN FRANCISCO, CALIFORNIA 94102
TEL (415) 673 7747
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development efforts in the analysis of exhaust gases, the here-
tofore unknown environmental benefits of sludge incineration
have been discovered.
Now, I might comment here that I have 20 copies of
the support information and graphs which we will give to you
at the break. I believe that will be more expeditious.
Aside from the decomposing of hazardous wastes, which
I will be discussing later, five points worthy of mention are:
One. These units will meet the new air quality
standards under the Clean Air Act.
Two. In connection with an NOX restricted area, their
exhaust gases have been ruled by one of the most stringent air
pollution control agencies in the United States, the San
Francisco Bay Area Air Pollution Control District, to have an
insignificant impact on air quality.
To illustrate how incinerators perform in terms of
air pollution standards, I quote from the June, 1975 EPA
Technology Transfer Publication, "Air Pollution Aspects of
Sludge Incineration," which states:
"... The newly promulgated Federal NSPS are
based on demonstrated performance of an operating
facility, indicates that use of proper emission
controls and proper operation of the inceration
system will enable a facility to meet all existing
particulate matter regulations."
1008
SCHILLeR& COMBS, INC
COURT AND DEPOSITION REPORTERS
401 POLK, SUITE 103
SAN FRANCISCO, CALIFORNIA 94102
TEL (415) 673 7747
-------
Multiple hearth furnace operations have also been
demonstrated to comply well within existing emission standards.
Figure One illustrates the margin between the actual
emissions standards and the much lower emissions characteristic
of operating multiple hearth furnaces.
Three. MHF controls heavy metals contained in sludge.
Mercury, in the EPA proposed toxic substances list, was found,
contrary to conventional thinking, to be controlled. I should
point out here that in the Technology Transfer publication
mentioned above, there is a statement citing mercury as dis-
proportionately appearing in the stack gases.
However, this statement was based on information prior
to the Proposed Amendments to Standards for Asbestos and Mercury
These new data show that 68 percent to 96 percent of the mercury
in the exhaust gases are actually removed in the scrubber system
Our installations have shown removals from 83 percent
to 96 percent of trace amounts of mercury.
I have included an annotated supplment to the Technology
Transfer publication, which contains this new information on
mercury, plus updated supplements to other parts of the document
where new data have become available.
These studies were sponsored by the EPA air quality
group at Research Triangle Park. According to the above-
mentioned Technology Transfer publication, lead, which is also
a potential emission problem, has been found to be more than
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
SAN FRANCISCO, CALIFORNIA 94102
TEL (415) 673 7747
-------
99 percent controlled in the multiple hearth furnace, with only
.84 percent entering the atmosphere.
This report also states that most potentially hazardous
and hazardous metals will not be significantly found in the
stack gases, but instead will be converted to oxides in the
incineration process and consequently removed either as
particulates by the scrubbers or in the ash.
Four. In this conservation-minded society, where
reclamation is all important, multiple hearth furnace systems
offer an advantage in recovering lime and recycling carbon
dioxide during the normal operating procedures in advanced
physical chemical treatment plants.
Five. The multiple hearth furnace creates a product,
an ash, that is potentially useful as a quasi-fertilizer as it
normally contains 6 to 15 percent phosphate. Over 50,000 tons
of sludge ash have been used experimentally in Japan as a quasi-
fertilizer and deserve more R & D consideration, at least
consideration equal to that given to land use disposal of wet
sludge, which has been found to contain toxic materials that
would otherwise be destroyed in the incineration process.
Ash has more concentrated nutrients compared to sludge.
Ash from a primary and secondary treatment system has a potential
value of $48 per ton — four times that of sludge, whereas ash
from a tertiary treatment plant may be worth $80 per ton.
In regard to the handling of toxic substances such as
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
5AN FRANCISCO, CAL IFORNIA 94102
TEL (415) 673 7747
-------
pesticides, the furnace performs efficiently at normal operating
temperatures to remove and control toxic pesticides from sludge.
Pesticide removal and decomposition rates during co-
incineration with sludge were tested by Curtis and Tomkins.
The data was gathered from ash, sludge, exhaust fumes and scrubbe|r
water samples at the Monterey Sewage Treatment Plant in
California.
Although some slight problems were involved with some
of the data, the results are generally indicative of multiple
hearth furnace performance in the controlling and decomposing of
toxic substances during incineration.
The removal efficiencies for eight pesticides listed
exceeded 99 percent.
And I would comment here just on the side that in
testing any of these furnaces for the decomposition or removal
of such products, the first problem we experienced was there was
not enough in the sludge itself, and therefore, we had to
increase or dose the sludge in order to obtain a measurable
fraction.
We believe this near complete removal of toxic
substances from waste streams by multiple hearth furnace has
particular significance in conjunction with the industrial
cost recovery under Public Law 92-500 due to the relatively
insignificant incremental cost in removing these substances
while co-incinerated with municipal sludge.
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
601 POLK. SUITE 103
SAN FRANCISCO, CALIFORNIA 94102
TEL (415) 673 7747
-------
Besides controlling toxic substances, the multiple
hearth furnace removes many toxic materials from the environment
by the decomposition process occurring simultaneously in the
standard incineration procedure.
And again, we list eight pesticides and the percentages
of decomposition, many of which are over 99 percent.
With the exception of the PCB decomposition, the
preceding data was derived from Exhibit 5 and was performed
using a furnace exhaust gas temperature of 900 degrees
Fahrenheit. This is a normal operating range. In the case of
PCB's, the temperature was elevated to 920 degrees Fahrenheit.
While it is known that PCB's and the majority of
pesticides mentioned are more than 99 percent decomposed during
incineration, the fate of such toxic materials with land
disposal of sludge is still unknown.
Certainly more research is required to determine the
density of these hazardous materials once they are applied to
land in the form of sludge. The fate of potential carcinogenic
viruses, which are destroyed during incineration, also pose a
serious environmental and health hazard for sludge disposal.
PCB's are appearing in the natural environment in
increasing quantities. However, the problems associated with
PCB's can be reduced through sound technological practices.
And in our presentation we review the work done in that.
Yet the problems of PCB's requires careful review. Fo
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
SAN FRANCISCO, CALIFORNIA 94102
TEL (415) 673 7747
-------
example, a recent statement attributed to Thomas Kopp in the
November 24th issue of "Air Water Pollution Report," arrives
at the conclusion that PCB's are not removed by any known
sewage treatment process and are assumed to remain in the
if fluent.
However, other data shows that PCB's from a primary
secondary treatment process are more than 70 percent removed
:rom waste waters .
Since the sampled Cedarburg, Wisconsin sludges contained
.,000 times .larger PCB concentrations than those found in the
mtgoing waters, the treatment process must have removed most
if the PCB's from the incoming wastes.
Accordingly, we see that PCB's tend to remain in the
iludge rather than the effluent. Therefore, because PCB's under-
o near total destruction via incineration, the conditions are
tore favorable for PCB destruction through incineration.
In conclusion, incineration as demonstrated by the
tultiple hearth furnace has proven to be of negligible
snvironmental impact and offers substantial benefits in the
landling, disposal and elimination of hazardous wastes. The
idvantages of using incineration in the disposal of hazardous
naterials are:
The process meets new air quality standards under the
:iean Air Act;
The San Francisco Bay Area Air Pollution Control
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
SAN FRANCISCO, CALIFORNIA 94102
TEL (415) 673 7747
-------
District has ruled the multiple hearth furnace to have an
insignificant impact on air quality within a NO restricted
area;
Controls heavy metals;
It recovers resources;
It creates a useful product;
Decomposes pesticides which are listed as toxic
substances to be controlled under the proposed EPA water quality
criteria during the normal incineration procedure at no extra
cost;
Near total destruction of PCB's at no additional
expense at the normal operating exhaust gas temperature ranges
with conventional equipment currently in use.
We feel that the problem of hazardous wastes is going
to require the concern and efforts of all those people in
industry and the manufacturers as well.
We do feel that we must review all of the processes
available to arrive at the best solutions for a given waste.
We do not propose that we have the answer for all wastes. But
we just wanted to present what we have learned working with
specific wastes.
Thank you very much.
1012
-------
STATEMENT
BEFORE THE ENVIRONMENTAL PROTECTION AGENCY
PUBLIC MEETING ON HAZARDOUS WASTE MANAGEMENT
BY
F, SIDNEY HOWARD
MARKETING MANAGER
EIMCO BSP DIVISION
ENVIROTECH CORPORATION
DECEMBER 11, 1975
1013
-------
STATEMENT: HAZARDOUS WASTE MANAGEMENT
MY NAME is F. SIDNEY HOWARD, MARKETING MANAGER OF THE EIMCO BSP
DIVISION, ENVIROTECH CORPORATION, WE ARE ONE OF THE LEADING
MANUFACTURERS IN SLUDGE PROCESSING AND DISPOSAL EQUIPMENT IN-
CLUDING MULTIPLE HEARTH FURNACES FOR SLUDGE PROCESSING AND
DISPOSAL IN CONNECTION WITH OUR INSTALLATION OF OVER 100
UNITS FROM MUNICIPAL SEWAGE TREATMENT PLANTS OVER THE LAST
13 YEARS,
IN REGARD TO CONTROL AND DETOXIFICATION OF WASTES, WE BELIEVE
OUR DEVELOPMENTS IN MULTIPLE HEARTH FURNACE TECHNOLOGY ARE OF
CONSIDERABLE IMPORTANCE. ALTHOUGH THIS HEARING IS PRIMARILY
CONCERNED WITH HAZARDOUS WASTE MANAGEMENT, I WOULD LIKE TO
TAKE A FEW MINUTES TO UPDATE THE OFTEN MISUNDERSTOOD ASPECTS
OF SLUDGE INCINERATION/RECLAMATION FURNACES TO SHOW THAT SLUDGE
INCINERATION/RECLAMATION IS AN ENVIRONMENTALLY VIABLE AND
ENERGY EFFICIENT MEANS OF HAZARDOUS WASTE DISPOSAL.
THANKS TO BOTH EPA AND INDUSTRY SPONSORED RESEARCH AND DEVELOP-
MENT EFFORTS IN THE ANALYSIS OF EXHAUST GASES, THE HERETOFORE
UNKNOWN ENVIRONMENTAL BENEFITS OF SLUDGE INCINERATION HAVE BEEN
DISCOVERED (EXHIBIT 1). ASIDE FROM THE DECOMPOSI.NG OF HAZARDOUS
WASTES, WHICH I WILL BE DISCUSSING LATER, FIVE POINTS WORTHY
OF MENTION ARE:
1. THESE UNITS WILL MEET THE NEW AIR QUALITY STANDARDS
UNDER THE CLEAN AlR ACT,
2, IN CONNECTION WITH AN NOX RESTRICTED AREA, THEIR
EXHAUST GASES HAVE BEEN RULED BY ONE OF THE MOST
STRINGENT AIR POLLUTION CONTROL AGENCIES IN THE
UNITED STATES, THE SAN FRANCISCO BAY AREA AIR
POLLUTION CONTROL DISTRICT, TO HAVE AN INSIGNIFICANT
IMPACT ON AIR QUALITY,
1011*
-------
To ILLUSTRATE HOW INCINERATORS PERFORM IN TERMS OF
AIR POLLUTION STANDARDS, I QUOTE FROM THE JUNE 1975
EPA TECHNOLOGY TRANSFER PUBLICATION (EXHIBIT 2),
"AiR POLLUTION ASPECTS OF SLUDGE INCINERATION/'
WHICH STATES:
",,,THE NEWLY PROMULGATED FEDERAL NSPS (NEW SOURCE
PERFORMANCE STANDARDS) ARE BASED ON DEMONSTRATED PER-
FORMANCE OF AN OPERATING FACILITY, INDICATES THAT USE
OF PROPER EMISSION CONTROLS AND PROPER OPERATION OF
THE INCINERATION SYSTEM WILL ENABLE A FACILITY TO
MEET ALL EXISTING PARTICULATE MATTER REGULATIONS."
MULTIPLE HEARTH FURNACE OPERATIONS HAVE ALSO BEEN
DEMONSTRATED TO COMPLY WELL WITHIN EXISTING EMISSION
STANDARDS. FIGURE 1 ILLUSTRATES THE MARGIN BETWEEN
THE ACTUAL EMISSIONS STANDARDS AND THE MUCH LOWER
EMISSIONS CHARACTERISTIC OF OPERATING MULTIPLE HEARTH
FURNACES (HEREAFTER REFERRED TO AS MHF).
3, MHF CONTROL HEAVY METALS CONTAINED IN SLUDGE. MERCURY,
IN THE EPA PROPOSED TOXIC SUBSTANCES LIST, WAS FOUND,
CONTRARY TO CONVENTIONAL THINKING, TO BE CONTROLLED.
I SHOULD POINT OUT HERE THAT IN THE TECHNOLOGY TRANSFER
PUBLICATION, "AiR ASPECTS OF SLUDGE INCINERATION,"
(EXHIBIT 2), MENTIONED ABOVE is A STATEMENT CITING
MERCURY AS DISPROPORTIONATELY APPEARING IN THE STACK
GASES. HOWEVER, THIS STATEMENT WAS BASED ON INFOR-
MATION PRIOR TO THE (BACKGROUND INFORMATION FOR NEW
•SOURCE PERFORMANCE STANDARDS) PROPOSED AMENDMENTS
TO STANDARDS FOR ASBESTOS AND MERCURY, EPA 450/2-74-
009A, OCTOBER 1974. THESE NEW DATA, WHICH ARE RE-
PORTED IN THE DOCUMENT REFERENCED ABOVE, SHOW THAT
68% - 96% OF THE MERCURY IN THE EXHAUST GASES ARE
ACTUALLY REMOVED IN THE SCRUBBERS, WHILE ENVIROTECH
1015
-------
INSTALLATIONS WERE SHOWN TO REMOVE FROM 83% TO 96%
OF TRACE AMOUNTS OF MERCURY, I HAVE INCLUDED AN
ANNOTATED SUPPLEMENT (EXHIBIT 3) TO THE TECHNOLOGY
TRANSFER PUBLICATION, WHICH CONTAINS THIS NEW IN-
FORMATION ON MERCURY PLUS UPDATED SUPPLEMENTS TO
OTHER PARTS OF THE DOCUMENT WHERE NEW DATA HAS
BECOME AVAILABLE.
THESE STUDIES WERE SPONSORED BY THE EPA AIR QUALITY
GROUP AT RESEARCH TRIANGLE PARK. ACCORDING TO THE
ABOVE MENTIONED TECHNOLOGY TRANSFER PUBLICATION
(EXHIBIT 2), LEAD, WHICH is ALSO A POTENTIAL EMISSION
PROBLEM, HAS BEEN FOUND TO BE MORE THAN 99% CONTROLLED
IN THE MULTIPLE HEARTH FURNACE, WITH ONLY.34% ENTER-
ING THE ATMOSPHERE,
THIS REPORT ALSO STATES THAT MOST POTENTIALLY HAZARDOUS
AND HAZARDOUS METALS WILL NOT BE SIGNIFICANTLY FOUND
IN THE STACK GASES, BUT INSTEAD WILL BE CONVERTED TO
OXIDES IN THE INCINERATION PROCESS AND CONSEQUENTLY
REMOVED EITHER AS PARTICULATES BY THE SCRUBBERS OR
IN THE ASH.
4, IN A CONSERVATION MINDED SOCIETY WHERE RECLAMATION
IS ALL IMPORTANT, MULTIPLE HEARTH FURNACE SYSTEMS
OFFER THE ADVANTAGE OF RECOVERING LIME AND RECYCLING
CARBON DIOXIDE DURING THE NORMAL OPERATING PROCEDURES
IN ADVANCED PHYSICAL CHEMICAL TREATMENT PLANTS
(EXHIBIT 4),
5, MHF CREATE A PRODUCT - ASH - THAT IS POTENTIALLY
USEFUL AS A QUASI-FERTILIZER AS IT NORMALLY CONTAINS
6% TO 15% PHOSPHATE (FlGURE 2). OVER 50,000 TONS
OF SLUDGE ASH HAVE BEEN USED EXPERIMENTALLY IN JAPAN
1016
-------
AS A QUASI-FERTILIZER AND DESERVE MORE R&E CONSIDERATION
- AT LEAST CONSIDERATION EQUAL TO THAT BEING GIVEN TO
LAND USE OF WET SLUDGE, WHICH HAS BEEN FOUND TO CON-
TAIN TOXIC MATERIALS THAT WOULD OTHERWISE BE DESTROYED
IN THE INCINERATION PROCESS. ASH HAS MORE CONCENTRATED
NUTRIENTS COMPARED TO SLUDGE. ASH FROM A PRIMARY AND
SECONDARY TREATMENT SYSTEM HAS A POTENTIAL VALUE OF
$48.00 PER TON - FOUR TIMES THAT OF SLUDGE (FIGURE 3),
WHILE ASH FROM A TERTIARY TREATMENT PLANT IS WORTH $80.50
PER TON,
N REGARD TO THE HANDLING OF TOXIC SUBSTANCES SUCH AS PESTICIDES,
'HE MHF PERFORMS EFFICIENTLY AT NORMAL OPERATING TEMPERATURES
'0 REMOVE AND CONTROL TOXIC PESTICIDES FROM SLUDGE. PESTICIDE
EMOVAL AND DECOMPOSITION RATES DURING CO-INCINERATION WITH
LUDGE WERE TESTED BY CURTIS AND ToMKINS, LTD. OF SAN FRANCISCO
EXHIBIT 5). DATA WAS GATHERED FROM ASH, SLUDGE, EXHAUST
UMES AND SCRUBBER WATER SAMPLES TAKEN IN APRIL 1972 AT THE
ONTEREY, CALIFORNIA SEWAGE TREATMENT PLANT. ALTHOUGH SOME
LIGHT PROBLEMS WERE INVOLVED WITH SOME OF THE DATA, THE
:ESULTS ARE GENERALLY INDICATIVE OF MHF PERFORMANCE IN THE
:ONTROLLING AND DECOMPOSING OF TOXIC SUBSTANCES DURING IN-
INERATION. THE REMOVAL EFFICIENCIES FOR EIGHT PESTICIDES,
OST OF WHICH EXCEED 99%, ARE AS FOLLOWS (FIGURE .4):
% REMOVAL
ALDRIN 99.64
DIELDRIN >99.99
DDD 98.59
DDE >99.99
DDT >99.99
ENDRIN >99.99
HEPTACHLOR 98.99
2A5-T 99.99
1017
-------
MOST OF THE PESTICIDES ABOVE, WHICH ARE ALL MORE THAN 98%
REMOVED FROM THE ENVIRONMENT, ARE ALSO LISTED AS TOXIC SUBSTANCES
REQUIRING CONTROLS UNDER THE PROPOSED EPA WATER CRITERIA.
WE BELIEVE THIS NEAR COMPLETE REMOVAL OF TOXIC SUBSTANCES
FROM WASTE STREAMS BY I'1HF HAS PARTICULAR SIGNIFICANCE IN CON-
JUNCTION WITH THE INDUSTRIAL COST RECOVERY UNDER PUBLIC
LAW 92-500 DUE TO THE RELATIVELY INSIGNIFICANT INCREMENTAL
COST IN REMOVING THESE SUBSTANCES WHILE CO-INCINERATED WITH
MUNICIPAL SLUDGE.
BESIDES CONTROLLING TOXIC SUBSTANCES, THE FIHF REMOVES MANY
TOXIC MATERIALS FROM THE ENVIRONMENT BY THE DECOMPOSITION
PROCESS OCCURRING SIMULTANEOUSLY IN THE STANDARD INCINERATION
PROCEDURE. THE FOLLOWING TOXIC SUBSTANCES, WHICH ARE ALSO
LISTED ON THE LIST OF TOXIC SUBSTANCES PROPOSED IN THE EPA
WATER CRITERIA MENTIONED ABOVE, WERE DECOMPOSED IN A f1HF
AS FOLLOWS:
% DECOMPOSED
ALDRIN 62.6
DIEALDRIN >99.99
DDT 99.19
ODD 75,2
DDE >99.99
ENDRIN >99.99
HEPTACHLOR 82.9
PCB 99.91
WITH THE EXCEPTION OF THE PCB DECOMPOSITION, THE PRECEDING
DATA WAS DERIVED FROM EXHIBIT 5 AND WAS PERFORMED USING A
FURNACE EXHAUST GAS TEMPERATURE OF 900°F WITH A 0.1 SECOND
RETENTION TIME, THE PCB TEST DATA WAS TAKEN FROM EXHIBIT 6,
WHICH TESTED THE DECOMPOSITION OF PCBs USING A 0,1 SECOND
RETENTION PERIOD WITH A 920°F EXHAUST GAS TEMPERATURE,
1018
-------
WHILE IT is KNOWN THAT PCBs AND THE MAJORITY OF PESTICIDES
MENTIONED ARE MORE THAN 99% DECOMPOSED DURING INCINERATION,,
THE FATE OF SUCH TOXIC MATERIALS WITH LAND DISPOSAL OF SLUDGE
IS STILL UNKNOWN. CERTAINLY MORE RESEARCH IS REQUIRED TO
DETERMINE THE DESTINY OF THESE HAZARDOUS MATERIALS ONCE THEY
ARE APPLIED TO LAND IN SLUDGE. THE FATE OF POTENTIAL CARCINOGENIC
VIRUSES, WHICH ARE DESTROYED DURING INCINERATION, ALSO POSE A
SERIOUS ENVIRONMENTAL AND HEALTH HAZARD FOR SLUDGE DISPOSAL.
PCBs ARE APPEARING IN THE NATURAL ENVIRONMENT IN INCREASING
QUANTITIES. HOWEVER, THE PROBLEMS ASSOCIATED WITH PCBs CAN
BE REDUCED THROUGH SOUND TECHNOLOGICAL PRACTICES. ONE OF THE
BEST ECONOMICAL METHODS FOR DISPOSING OF PCBs IS THROUGH THE
NORMAL INCINERATION PROCEDURE IN MULTIPLE HEARTH FURNACES.
TESTS SHOW THAT 99.9% OF PCBs ARE DECOMPOSED IN THE MULTIPLE
HEARTH FURNACE AT 593°C (1100°F) USING A 0.1 SECOND EXHAUST
GAS DETENTION TIME (EXHIBIT 6). ACCORDING TO A UNITED STATES
GEOLOGICAL SERVICE SURVEY, THERE APPEARS TO BE NO OTHER WAY IN
WHICH THESE HIGHLY PERSISTENT MATERIALS ARE BEING REMOVED FROM
THE NATURAL ENVIRONMENT. ONE OF THE RECENTLY DETERMINED BENEFITS
OF THE TOTAL OXIDATION OF SLUDGE IN THE MULTIPLE HEARTH FURNACE
IS THAT 95% OF THE PCBs ARE DESTROYED IN THE NORMAL OPERATION
TEMPERATURE OF THE SLUDGE FURNACE - WHICH IS ONLY 371°C
(700°F) USING A 0.1 SECOND EXHAUST GAS RETENTION TIME. As
PREVIOUSLY MENTIONED, THIS LOWERED TEMPERATURE REPRESENTS A
SUBSTANTIAL FUEL SAVINGS COMPARED TO ALTERNATE METHODS, AND
WHILE DESTROYING 95% OF PCB POLLUTANTS AT NO ADDITIONAL EX-
PENSE IT ALSO COMPLIES WITH EPA RECOMMENDED STANDARDS FOR
SLUDGES FOUND TO CONTAIN PCBs.
YET, THE PROBLEMS OF PCBs REQUIRES CAREFUL REVIEW. FOR
EXAMPLE A RECENT STATEMENT ATTRIBUTED TO THOMAS E. KOPP IN THE
NOVEMBER 24, 1975 ISSUE OF AIR/WATER POLLUTION REPORT, ARRIVES
AT THE CONCLUSION THAT PCBs ARE NOT REMOVED BY ANY KNOWN
1013
-------
SEWAGE TREATMENT PROCESS AND ARE ASSUMED TO REMAIN IN THE
EFFLUENT. HOWEVER, OTHER DATA (EXHIBIT 7) SHOWS THAT PCBs
FROM A PRIMARY SECONDARY TREATMENT PROCESS ARE MORE THAN 70%
REMOVED FROM WASTE WATERS. SlNCE THE SAMPLED CEDARBURG,
WISCONSIN SLUDGES CONTAINED LOGO TIMES LARGER PCS CONCENTRATION
THAN THOSE FOUND IN THE OUTGOING WATERS, THE TREATMENT PROCESS
MUST HAVE REMOVED MOST OF THE PCBs FROM THE INCOMING WASTES.
ACCORDINGLY, WE SEE THAT PCBs TEND TO REMAIN IN THE SLUDGE
RATHER THAN THE EFFLUENT. THEREFORE, BECAUSE PCBs UNDERGO
NEAR TOTAL DESTRUCTION VIA INCINERATION, THE CONDITIONS ARE
MOST FAVORABLE FOR PCB DESTRUCTION THROUGH INCINERATION.
IN CONCLUSION, INCINERATION AS DEMONSTRATED BY THE MHF HAS
PROVEN TO BE OF NEGLIGIBLE ENVIRONMENTAL IMPACT AND OFFERS
SUBSTANTIAL BENEFITS IN THE HANDLING, DISPOSAL AND ELIMINATION
OF HAZARDOUS WASTES. THE ADVANTAGES OF USING INCINERATION IN
THE DISPOSAL OF HAZARDOUS MATERIALS ARE:
1) PROCESS MEETS NEW AIR QUALITY STANDARDS UNDER THE
CLEAN AIR ACT.
2) THE SAN FRANCISCO BAY AREA AIR POLLUTION CONTROL
DISTRICT HAS RULED THE MHF TO HAVE AN INSIGNIFICANT
IMPACT ON AIR QUALITY WITHIN A NO RESTRICTED AREA.
A
3) CONTROLS HEAVY METALS
4) RECOVERS RESOURCES - CG^, LIME
5) CREATES A USEFUL PRODUCT - ASH
6) DECOMPOSES PESTICIDES, WHICH ARE LISTED AS TOXIC
SUBSTANCES TO BE CONTROLLED UNDER THE PROPOSED EPA
WATER QUALITY CRITERIA, DURING THE NORMAL INCINERATIOI*
PROCEDURE AT NO EXTRA COST,
7) NEAR TOTAL DESTRUCTION OF PCBs AT NO ADDITIONAL
EXPENSE AT THE NORMAL OPERATING EXHAUST GAS TEMPERATUF
OF 700°F WITH A 0.1 SECOND RETENTION TIME.
-------
Figure 1
PALO ALTO EMISSIONS
300 PPM
25 PPM
o
m
tc
<
o
o
oc
Q
&
IS
g
x
o
cc
YLS
AR
O.15
GR./SDCF STANDARDS
mwv""-'
n
^
UJ
UJ
0
ACTUAL
1021
-------
Figure 2
TYPICAL ANALYSIS OF ASH FROM
SEWAGE TREATMENT. SYSTEMS
Content
Silica (SiO2)
Alumina (A12O3)
Iron oxide (Fe2O3)
Magnesium oxide (MgO)
Total calcium oxide (CaO)
Available (free) calcium oxide (CaO)
Sodium (Na)
Potassium (K)
Boron (B)
Phosphorus pentoxide (P7O^)
Sulfate ion (SO4)
Loss on ignition
Silica (SiO2)
Alumina (A12O3)
Iron oxide (Fe2O3)
Magnesium oxide (MgO)
Total calcium oxide (CaO)
Available (free) calcium oxide (CaO)
Sodium (Na)
Potassium (K)
Boron (B)
Phosphorus pentoxide (P?OS)
Sulfate ion (SO4)
Loss on ignition
Prrroil of Tula!
Smnpfe 1
lake Tahoe
II/IH/6'J
23.85
16.34
3.44
2.12
29.76
1.16
0.73
0.14
0.02
6.87
2.79
2.59
Afinn.-S< ran!
9/30/69
24.87
13.48
10.81
2.61
33.35
1.06
0.26
0.12
0.006
9.88
2.71
1.62
Snmji/r 2
Lake Taliat
II '25/69
23.72
22.10
2.65
2.17
24.47
1.37
0.35
0.11
0.02
15.35
2.84
2.24
Clrt elaml
3/2/70
28.85
10.20
14.37
2.13
27.37
0.29
0.18
0.25
0.01
9.22
5.
-------
(0
- LLJ
!/) 1C
u.*
=>o:
uj u
o
LLJ
I-
o
iy
(0 c
CO
o
i
-------
Exhibit 1
FISCAL YEAR 1976 EPA R. & D.
AUTHORIZATION
HEARINGS
BEFORE THE
SUBCOMMITTEE ON THE
ENVIRONMENT AND THE ATMOSPHERE
OP THE
COMMITTEE ON
SCIENCE AND TECHNOLOGY
TJ.S. HOUSE OF REPRESENTATIVES
NINETY-FOURTH CONGRESS
FIRST SESSION
MABCH 4, 5, 6, 1»75
[No. 7]
Printed for the use of the
Committee on Science and Technology
U.S. GOVERNMENT PRINTING OFFICE
80-278 0 WASHINGTON : 1976
102**
-------
Conference on Human Environment in Stockholm where Mr. Sebastian was also
nn observer. He was a member of tne first Executive Level trade mission to Mos-
cow in November 1973 and is a member of the Working Group for Pollution
Prevention from Municipal and Industrial Sources under the U.S./U.S.S.R.
Environmental Agreement.
Mr. Sebastian has been a member of the District Export Council and predeces-
sor organization of the U.S. Department of Commerce since 1970 and has served
as a consultant to the EPA National Air Pollution Control Techniques Advisory
Committee. He also served as a panelist on the National Forum on "Growth
with Environmental Quality ?" held in Tulsa, Oklahoma September 23rd to 26th,
1973.
Mr. Sebastian holds degrees from the Stanford Graduate School of Business
(MBA) and the University of Texas (BSME). He lives in Atherton, California.
He is a director and vice president/treasurer of the California Council for Inter-
national Trade; vice chairman of the board of directors of the Educational De-
velopment Corporation; was recently a director of the Stanford Business School
Association; is a director and 2nd vice president of the Water and Wastewater
Equipment Manufacturers Association. He is a member of the Water Pollution
Control Federation, the American Institute of Chemical Engineering and the
American Water Resources Association. He is the author of several chapters
of engineering books and of more than 50 presentations and publications, one of
the latest of which appeared in the Journal of the Water Pollution Control
Federation in February of 1974, having been presented originally at Subcom-
mittee Hearings on Development and Environment before the Secretary of
State's Advisory Committee on the 1972 United Nation's Conference on the
Human Environment, March 6, 1972.
STATEMENT OF PRANK P. SEBASTIAN, JR., SENIOR VICE PRESI-
DENT, ENVIROTECH CORP.
Mr. SEBASTIAN. I appreciate the opportunity to discuss with you the
research and development programs relative to the Clean Water Act
of 1972 amendments, and particularly to present information about a
frequently overlooked reservoir of technology, the wastewater equip-
ment industry, which in fact is perhaps the broadest area of environ-
mental technology that isjihead of Federal standards and require-
lents for water pollution alnd control.
I have with me the GAO report, and perhaps it would help set the
stage to note that there was no reference to this segment of technology
that I will speak about this morning.
Mr. BROWN. Is there any chance we can get you to merge with
General Motors or anything of that sort? I would like to see them
ahead of Federal regulations also.
Mr. SEBASTIAN. Well, this is a very proud part of our industry, that
we keep pace or a little ahead wherever possible.
Before I begin, perhaps it would be helpful to give the subcommittee
some background on my company and myself.
Envirotech Corp. is a publicly owned company that was formed by
combining two existing companies, Eimco Corp. and BSP Corp., in
1969. It now employs 8,000 people and does $300 million worth of
business annually, principally in water quality control equipment, air
quality control equipment, and mining machinery. In the water quality
area we offer one of the broadest lines of equipment available. We are
frequently listed as the company doing the largest sales volume in
waste water treatment equipment. In tne interest of time perhaps I
could skip over portions of my statement.
Mr. BROWN. Without objection your complete statement will be in-
cluded in the record, Mr. Sebastian, and you may proceed summarizing
and skipping any portion of it that you feel appropriate.
[The complete prepared statement of Mr. Sebastian follows:]
1025
-------
Mr. SEBASTIAN. Prior to becoming senior vice-president of Enviro-
tech, I was president of BSP Corp., one of the founding divi-
sions of Envirotech, and managed the BSP operation from 1961 to
1970. During this period, BSP provided the solids handling and
reclamation systems for the most advanced wastewater treatment plant
in the United States at South Lake Tahoe, Calif.
I am an officer and director of the Water and Wastewater Equip-
ment Manufacturing Association, WWEMA, and also serve as chair-
man of its Legislative Oversight Committee on Public Law 92-500 and
liaison with EPA for WWEMA and for Envirotech. I have organized
and led four U.S. trade missions to Europe and Asia and have partici-
pated in several other trade missions abroad.
I was also co-leader of the San Francisco delegation to the People's
Republic of China in May 1972 where I made presentations to the
PRC corporations on the status of water and air quality control
technology in the United States. Currently I am a member of the
EPA's Working Party on the Prevention of Pollution from Municipal
and Industrial Sources under the Environmental Agreement between
the United States and the Soviets.
In the brief time available this morning I believe I can best con-
tribute to the subcommittee's purpose by imparting the viewpoint of
an equipment manufacturer and supplement the record with informa-
tion that I feel is often overlooked when considering R. & D. needs—
that of the technology developed by the equipment manufacturers and
which underlays the EPA R. & D. programs. My comments relate
principally to (1) proven existing technology in municipal water pol-
lution control, (2) new developments in sludge processing technology,
(3) treatment costs, (4) need for more EPA R. & D. in (a) health
effects and other damages caused by pollution, (b) health effects and
damages eliminated by cleanup and (c) utilization of sludge as a quasi -
fertilizer.
Before getting into the R. & D. technology, however, I would reques.
the subcommittee's permission to comment on a few aspects from the
equipment manufacturer's point of view on the largest single item in
the EPA budget for 1975 onward, that of Construction Grants
funding.
The largest sums of money in the history of water pollution control
in America have been released in the past few days, to be added to
already record-breaking levels of funding backlogs for treatment plant
construction. None of the R. & D., State or regional plans, or sewage
collection plans removes any pollution from wastewater until the actual
equipment is installed and operating.
There is a recent but severe impediment to getting greater quantities
of equipment bid and installed—lack of capital and high interest costs.
I. am happy to report, however, that on November 7 Mr. Train an-
nounced as a part of EPA's speed-up program that both a reduction
of retainage held from contracts and equipment manufacturers' pay-
ments and progress payments on work performed were being actively
considered.
Only 2 weeks later, on November 24, the first of these two pro-
grams, reduction of retainage, was issued in the form of a program
guidance memorandum. The even more vital progress payments
guideline is now, I understand, in the final stages of review. At this
1C28
-------
point, even with the new impetus from the recently released funds,
the full capacity of equipment manufacturing industry to bid on or
produce equipment cannot be brought to bear on this enormous pro-
gram—until progress payments are fully extended to major equip-
ment manufacturers. The present and the proposed payments sched-
ules are shown on exhibit No. 1 and exhibit No. 2.
If I may, I will move to the view graph to project these on the
wall [exhibit 1].
The present payment schedule for a typical million-dollar contract
under the EPA construction program shows a cost curve of a cumu-
lative cost along these lines; but the manufacturers have not nor-
mally been eligible for getting progress payments until they deliv-
ered their equipment on the site, and this meant a time delay and
followed this bottom line [indicating] (exhibit 2).
PRESENT
CONTRACT
PRICE
PAYMENT
EXHIBIT 1
SCHEDULE
MATERIALS 8 CONSTRUCTION
73: .
START
UP
2Z
ENGRG. PROCUREMENT 8
MOBILIZATION 2W
»l,000,i)UO- — — •
800,Ul)U-
600,000-
400,000-
200,000-
35
* INCLUDES DIRECT COST, INDIRECT COST, Ł PROFIT
1027
-------
CONTRACT
PRICE
$1,000,000.
800,000,
60U,OOU
4UU,UuU
200,000
PROPOSED PAYMENT SCHEDULE
EXHIBIT 2
ENGRG. PROCUREMENT S
NOBILIZATION 21Z
5Z MONTHLY PAYMENTS, UP To
60T OF CONTRACT PRICE
CONTRACT
AWARD
5 llos. 10 15 20 25 JO
* INCLUDES DIRECT COST, INDIRECT COST, « PROFIT
35
CASH FLOW FOR TYPICAL PROJECT
EXHIBIT 3
S200.000
-1200,000
-WOO, 000 -
-J600.00U •
1G28
-------
The proposed plan that we have under consideration with the EPA
would be to matcli the payment schedule so that receipts would be
put into industries' hands to closely follow the cost curve (exhibit
3). This would eliminate a tremendous burden on the financial mar-
ket to provide funds at a time when there is virtually no additional
capital available by having the money flow through currently.
Mr. BROWN. Mr. Sebastian, I think this is a very important point,
and I would like to ask that you keep the committee informed, in the
event that we are not properly informed from the EPA, as to the
progress that is made in regard to your discussions with them on this
point.
It seems to me that this would be a tremendous cost saving to the
taxpayer, as well as a way of expediting the putting in place of the
pollution control equipment that our national policy requires and
which the Congress very strongly supports.
It seems to me that an expedited payment schedule in the fashion
that you have indicated here is a much better procedure than per-
haps trying to underwrite or develop low-cost loan programs or
some other things of that sort which might be alternative ways of
going about it.
Mr. BROWN. I think the committee would be interested in what
happens as a result of your presentations.
Mr. SKBASTIAN. Thank you very much, Mr. Chairman. I will do so.
The EPA's leadership through its immediate response to these prob-
lems is greatly appreciated by the equipment manufacturers, and
as we have asked of the staffs of both the Senate Public Works
Subcommittee on Environmental Pollution and the House Public
Works Subcommittee, we seek the support of this subcommittee in
not only endorsement of the EPA's action but to add the additional
strength necessary to rapidly effect change in traditions built up over
many years of practice at farjower levels of activity.
In the past the financial demands of providing 60 percent of the
ace amount of the contract, plus normal time lags between billing
and receipt of funds, could be accommodated because the level of
activity was relatively low, particularly in comparison to other busi-
nesses in which many of the companies were also involved.
Under today's financial market conditions and the size of the con-
struction program, this is no longer possible.
Now to the technology area, which is the principal reason for my
being here today. I would like to comment on the advanced state of
industry-developed technology which, as I said earlier, is all too
frequently overlooked when assessing the construction grants pro-
gram and the R. & D. activities needed.
Last year there were reports to Congress analyzing the EPA's
R. & D. programs that did not include any mention or recognize the
existence of any equipment industry technology. The sense of the
GAO report on R. & D. to Congress last year seemed to be that "His-
torically, all municipal (wastewater treatment) technology has been
developed by the government. There is no large (significant) indus-
trial research and development activity." Fortunately for the success
of the Clean Water Act program to date and for whatever success
may be achieved in the immediate future, this is not the case.
1029
-------
As chairman of the WWEMA committee relative to oversight
legislation on Public Law 92-500, I polled our 280 member compa-
nies on their R. & D. efforts and obtained the following results:
Seventy-four firms responded and indicated an annual industry
expenditure of $570,000. This results in an annual industry expendi-
ture of at least $42.75 million.
As a percent of total sales, this amounts to an average of 5.44 per-
cent—the sales generated by all of the responding firms totaled $350
million.
And 93 percent responded that equipment manufacturers and in-
dustrial equipment users funded the largest share of current munic-
ipal wastewater treatment technology.
I would like to give some specific examples of the state of the tech-
nology; that is, the technology that the equipment manufacturers
are bidding, and indeed guaranteeing, today without waiting for
any additional K. & D. output from their own companies or other
research development organizations, including the EPA.
I referred earlier to the South Lake Tahoe Water Reclamation Plant
as one of the mos: advanced plants in the United States. This 7.5
MGD plant, as you undoubtedly know, has been operating since
1967 and has been converting municipal sewage to a water that will
meet laboratory tests for drinking water; it has not failed to meet its
standard for the full period of its operation.
Further, this plant is a key stop for many foreign water quality
and environmental visitors. For example, it has been included in
virtually every visit of the Soviet scientists involved in water quality
since the Environmental Agreement was signed, and in July 1973
it was my pleasure to host Dr. Yury Izrael, Mr. Train's Soviet counter-
part, on a visit to the plant where he and his delegation drank what
we call "Tahoe champagne" from the effluent pipes at the plant.
[Exhibit 4.]
1030
-------
EXHIBIT 4
Team fours SJPUD
Russians lift glasses, gulp
reclaimed Tahoe wastewater
Hv JKF » COHKN.
Tribune Maffttntpr
Lake T^hoe i> a parudi^e for
«rifnti>K as we!) a> toun-Js so
it c.imc as no surprise \1«>nda>
when n wj^ announced that a
group <>f husswn scientists will
Coim- here in (he fall to stud)
Tihi*'s emironnu-nt
The n«-w- canic during a one-
dj> VIMI to s..uthTjh.^b> three
Ku-vwait stivrm»t- who took time
in a (»» week i»ur »f ihe Lmtrd
Stale* l» see the pioneering
a*l\.mre the South
Tahi* Public 1 tilil > Ihstnct and
l« drink it- puntiett water
The >ltkd\ >tecl»»n said
Tah»e is similar tn Baikal in
water qualitv and in (he special
protective laws adopted to
thwart pollution
Izrael. Dr Vury Knsakov. Ihe
permanenl secretary of the
enMrnnmenul committee, and
Lcimliv Mmdtimtv. a committee
nieniber. went U» Ihe Smith
Tah*>e rrclamatu* plant, which
ha* been tiailed as the first in the
w nr Id in treat sewage to
drinking water standards
The) look long draughts of the
water th^t pours from an
oversized champagne bolt It-
conMructed b> plant wtirkers
Dr Izravl learnedoOhe Tahoe
plant recent 1) and changed Ihe
group'* ihnerarv Thev had been
to several national parks and are
Rmng to a pulp and paper
irralmenl plant in Utsnmnin
Izrael commented on Ihe
export of treated water out *»f thr
TaNte B*«i.tn ID a reservoir 2*>
miles awa>, sa>ing ' some
means tnighl to be wtirker)
•ml to permit the return of the
water" fur use lie said this is
being Horlted »«i in ihe Smift
L'n»itn
Izrael said there are similar
treatment plant* at Lake Baikal
hui thev are treating industrial
rather ih.ii municipal wastes
The Baikal treated water can
IM' drunk I/raet vud. ruiling that
Kus^ell Tram chairman of (he
IS Council .>n Environmental
ljualitv had partaken of some
i>n j recenl trip to Russia
A dinner for (he Russians.
California *ta
Oislrul wa* held on the crut&e
ship M N Dixie winch enabled
ihe visiNir* In see the Tahoe
scenerv Aboard were state
K«'MHjrces Secretary Norman
Li\ rrnuire and Win Adams.
chairman of the Water Quah(>
Cnntml Board
I brought samples. I can't put them on the record, Mr. Chairman,
but I have certified samples of the water from the plant.
Please note that I am not saying that this water can be connected
directly to the water tap supply, but it will meet laboratory tests for
drinking water, and, as Ave all know now from recent reports, much of
the surface water in our tap supplies today does contain elements of
sewage effluent that has not been anywhere near as highly treated as
the Tahoe wastewater.
A key aspect of this most advanced plant is the sludge processing
and handling, for as you increase the level of pollutants removed you
increase the amount of sludge generated. The Tahoe plant received a
generous amount of Federal funding for the liquid stage, but it was not
until the Clean Water Restoration Act of 1966 was passed in December
1031
-------
of that year, providing R. & D. funds, that sufficient money was
available to install the solids handling and processing system.
Tahoe received one of the very first R. & D. grants under the 1966
act for over $1 million to demonstrate an incineration/reclamation
process that would reclaim the treatment chemicals—lime, in this
case—for on-site reuse and convert all other waste residuals to a sterile,
innocuous ash.
It is pertinent to my point that although this sludge project was
fully funded by the Federal Government as research and development,
it was my company as the successful equipment bidder that nad to
guarantee the performance of this equipment, thus in effect guaran-
teeing the results of an R. & D. program.
I am happy to say that we did achieve the result specified. Thus, for
the first time there was demonstrated to the United States and the
world a complete wastewater treatment plant making a drinkable
quality water from sewage, reclaiming chemicals onsite and convert-
ing all residue to a sterile ash that, as I will mention later, has some
other resource reclamation potentials.
You may be wondering. "What about the impact of the incineration/
thermal reclamation process on the pristine air quality in the Lake
Tahoe area?"
In fact, I have received calls from the head of a State water re-
sources board in this area in the past saying that at a meeting the
night before someone said the plant was causing the trees in the area to
die. We checked it out, and fortunately that is not the case.
Those myths seem to travel fast when they are on the negative side.
Mr. BROWX. They are confusing Tahoe with southern California, T
think.
Mr. SEBASTIAX. The environmental impact on the air quality was n^,
because there is no visible plume and the highly cleansed exhaust gases
are recirculated through partially treated waters at one stage of the
process to reclaim the carbon dioxide for reuse in the process.
To obtain further verification outside of laboratory tests on the
suitability of such reclaimed water for direct use in tap water, one
must go outside the United States to Windhoek Namibia, southwest
Africa, where there is a 1-million-gallon-per-day treatment plant that
is patterned along lines similar to tbe Tahoe plant.
The most significant thing about the Windhoek plant is that it has
been supplying reclaimed water directly for the tap supply in Wind-
hoek since it became operational in 1967. Researchers have conducted
complete viral and epidemiological tests at the plant, and there have
been no health problems associated with its use. Of equal significance,
there has not been any citizen resistance.
I visited there in 1969. We brought some water samples home. I was
to give testimony before one of the subcommittees dealing with pol-
lution, estuary pollution, and my Congressman asked my daughter who
was carrying the 1 gallon of the reclaimed water what she thought
about it/I think that she focused on the issue—she was 8 years old—
that, "the water tastes better before you see the plant."
I have the reports on virus, which is frequently a concern expressed
in reviews of this use of this resource. If the committee would like it
tor the record, I would be happy to submit it. 1032
-------
Both U.S. technology and manufacturers were involved in equip-
ment and processes used in this facility. Another advanced treatment
plant at Colorado Springs, Colo., has been operating since 1971 where
a tertiary treatment plant was added to an existing secondary treat-
ment plant to produce an effluent of quality almost equal to that of
Tahoe, with a plan to supply this highly treated effluent to an electric
utility located adjacent to the treatment plant for use as cooling water
makeup.
It is worthwhile noting that the reclaimed water is priced at about 26
cents to 28 cents per thousand gallons, as compared to the local whole-
sale value of tap water of 38 cents per thousand gallons.
All of these facilities mentioned involve biological conventional
treatment with a tertiary physical-chemical treatment facility added.
Since these plants were built, there have also been other industry and
Government developments in physical-chemical treatment, commonly
called PCT processes, which are of great significance. In July 1971 the
EPA announced its lime/activated carbon physical-chemical process.
including on-site lime and carbon reclamation through high tempera-
ture thermal processes.
Envirotech also has developed somewhat similar PCT processes that
produce a product water comparable to Tahoe quality water, but which
are sufficiently different from or prior to EPA developments to be the
basis for issued U.S. patents, both in the liquid treatment sector and
in the sludge processing and reclamation area. The latter we call the
Plural Purpose Furnace, which is a further step of development
beyond that achieved at Tahoe and combines the two steps of lime re-
covery and incineration into one step utilizing the fuel value of the
sludge as a partial source of fuel to reclaim the lime for on-site reuse.
Several plants utilizing these PCT processes are currently under
construction by my company in widespread areas of the United States
today involving many milljjons of dollars of EPA construction grant
support.
A further industry development which I believe is also indicated
as a similar project in the 1975 EPA R. & D. budget is that of energy
reclamation from sewage plants. Although I have already mentioned
reclamation of the fuel value of sewage sludge to reclaim chemicals on
site, this has been taken a step further in three EPA funded municipal
plants currently under construction by our company, here again fund-
ed under the Construction Grants program, involving use of our third
generation multiple hearth furnace systems which we call Closed Loop
Energy Systems.
1033
-------
EXHIBIT 5
Closed energy loop, sludge handling systems Incorporates
heat treatment, Incineration, and heat recovery
Reactor
ARCO Scrubber
EIMCO decant tank
Vacuum filter (existing)
BSPMltiple hearth (trace
I won't take the time to describe it (exhibit 5). It is available in the
material that I have already presented to the committee.
In these Closed Loop Energy Systems a sludge heat treatment step
is installed to break loose the water bound in the biological cells to
enable normal dewatering equipment [vacuum filters or centrifuges]
to be used to obtain a 250-percent increase in the normal solids con-
tents of the sludge which brings the sludge to a fuel value approxi-
mately equal that of soft coal.
The heat-treated sludge is then processed through a similar but dif-
ferently designed furnace to convert itself to a sterile but, again,
potentially useful ash without the need for auxiliary operating fuels
and with sufficient excess heat reclaimed to provide process heat and
steam at the treatment plant. Further details of this new process are
shown in the May 1974 issue of Environmental Science & Technology.
[Copies available.]
Considering the general view of need for more sludge processing
technology, I am sure you must be wondering about the impact upon
air quality of these incineration/reclamation units. Thanks to both
EPA and industry-sponsored research and development activities in
detailed analyses of the exhaust gases, the heretofore unknown en- ^
vironmental benefits of these processes have been discovered. 1.0 O "4
-------
There was about $50 million worth of this processing equipment
purchased under EPA grant funds in 1973.
EXHIBIT 6 t
• MEETS EPA AIR STANDARDS—- PARTICIPATES
• RULED INSiGNSFICANT SOURCE OF EMISSIONS
"DECOMPOSES PESTICIDES— DDT,2,4,5-T
• DECOMPOSES PCBS
• CONTROLS 5-iEAVY METALS
• RECOVERS RESOURCES — CO2 , LIME
• PRODUCES ASH PRO.OUCT —QUASI - FERTILIZER
Seven points arc worth noting: (exhibit 6).
(1) These units will meet the new air quality standards under the.
Clean Air Act.
• (2) Their exhaust gases have been ruled by one of the most strin-
gent air pollution control agencies in the United States, the San Fran*
Isco Bay Area Air Pollution Control District, to have an insignificant
.mpact on air quality.
(3) Incineration decomposes worrisome pesticides such as DDT, 2.
4,5-T, that may be contained in the sludge, at normal operating^tem-
peratures at no extra cost and such materials are not contained in the
exhaust air nor in the ash product.
(4) They destroy polychlorinated biphenyls or PCB's which have
been determined by the EPA to be the most persistent of the chlori-
nated hydrocarbon group found in sludge.
In fact, based on a search of the literature, it would appear that
the only way the PCB's are being removed from our environment once
they are introduced is when modern sludge incineration equipment is
employed at wastewater treatment plants.
Although EPA research efforts of 1971 and 1972 were uncertain as
to the fate of PCB's when incinerated, independent laboratory tests
sponsored by Envirotech showed that PCB's and most of the" other
substances on EPA's proposed toxic chemicals list, were all destroyed
under normal operating temperatures. EPA-sponsorecl tests in 1974
confirmed Envirotech's 1972 data showing the complete decomposi-
tion of DDT and 2,4,5-T.
(5) These systems control heavy metals contained in sludge. For
example, both lead and mercury, can now be removed from any air
quality list of concern. EPA-sponsored tests show that over 99 per-
1035
-------
cent of the lead contained in sludge is processed in the multiple hear''
furnace to the ash and not exhausted to the atmosphere.
Mercury, another item in the EPA proposed toxic substances list,
was found, contrary to conventional thinking, to also be controlled.
Over 90 percent of the trace amounts of mercury normally found in
sludge is removed through the process. Separate studies by the EPA
air quality group at Research Triangle Park corroborate these figures.
(6) These systems employ recovery processes to reclaim both lime
and carbon dioxide in advanced PCT plants.
(7) They create a product—ash—that is potentially useful as a
quasi-fertilizer because it normally contains 6 to 15 percent phosphate
(exhibit 7). Over 50,000 tons of sludge ash has been used experi-
mentally in Japan as a quasi-fertilizer and deserves more R. & D.
consideration—at least consideration equal to that being given to land
use of wet sludge under EPA R. & D. programs.
EXHIBIT 7
TYPICAL ANALYSIS OF ASH FROM TERTIARY QUALITY
ADVANCED WASTE TREATMENT SYSTEM
Percent of Tufa?
Content
Silica (SiO2)
Alumina (A12O3)
lion oxide (Fe2O3)
Magnesium o.xide (MgO)
Total calcium oxide (CaO)
Available (free) calcium oxide (CaO)
Sodium (Na)
Potassium (K)
Boron (B)
Phosphorus pentoxide (P,O<)
Sulfate ion (SO4)
Loss on ignition
Silica (SiO,)
Alumina (A12O3)
Iron oxide (Fe,O3)
Magnesium oxide (MgO)
Total calcium oxide (CaO)
Available (free! calcium oxide (CaO)
Sodium (Na)
Potassium (K)
Boron (B)
Phosphorus pentoxide (P?OO
Sulfate ion (SO.,)
Loss on ignition
Sample 1
l*ak* Tuho*
JJ/W69
23.85
16.34
3.44
2.12
29.76
1.16
0.73
0.14
0.02
6.87
2.79
2.59
Minn -Si Paul
9/30/69
24.87
13.48
10.81
2.61
33.35
1.06
0.26
0.12
0.006
9.88
2.71
1.62
Sami>lt,
LAr TuW
1//SS/S9
23.72
22.10
2.65
2.17
24.*"
1
0.3o
0.11
0.02
15.35
2.84
2.24
C/nrW
3/2/70
28.85
10.20
14.37
2.13
27.37
0.29
0.18
0.25
0.01
9.22
5.04
1.9-1
-------
Sludge ash is purified of PCB and pesticides and, because the
nutrients are more concentrated, has a potential value of $48 per ton—
'our times that of wet sludge (exhibit 8).
EXHIBIT 8
VALUE OF STP RESIDUAL SOLID
MATTER WHEN USED AS FERTILIZER
$80.5O
804
60
o
N
20
0)
$12.22
0.40'fc'phosphate
2-Q5%nilrogenl
$48.50
1 0% phosphate
0.1% nitrogens
0.1% potashj
bphosphate
O.1% nitrogen
0.Tfc potash "
product:
process:
location:
sludge
land disposal
Denver, Colorado
ash
incineration
Palo Alto, Calif.
ash
incineration
Lake Tahoe,Calif.
sources: Water & Waste Engr. Magazine, Wall Street Journal,
Envirotech Corp.
This chart shows in three columns the value of residual: (left) the sludge
value going into land disposal projects in Denver, Colorado, based on the values
for nitrogen (N) and phosphate (K) ; (center) ash from a conventional treat-
ment plant in Palo Alto, California, using the same values of X and K; and
'right) ash from Lake Tahoe's jrflvanced treatment plant.
You get $12.22 a ton value for the wet sludge at a land disposal
operation, whereas using the same values with the higher phosphate
content, you get $48.50 per ton potential value, and in an advanced
•waste treatment plant, again because of the higher levels of phos-
phate, you get an even higher value $80.50 per ton.
So far this is an area of reclamation that the Japanese have sought
and found as a potential area of value, and it should get more consid-
eration here in the United States.
To bring the air quality impact of advanced sludge incineration
into perspective, I think it would be helpful to compare the automobile
pollution emissions with exhaust emissions from sludge thermal
equipment.
When comparing one average automobile, which reportedly travels
12 miles per day, against the air quality impact of the incineration of
sludge on a per capita basis, we find that sludge incineration is about
equivalent to burning 1 ounce of gasoline in an automobile. With
sludge incineration, however, we are removing harmful chemicals
from the environment and reclaiming increasingly precious resources,
water, lime, carbon, et cetera. A detailed comparison of these emissions
is shown in exhibit 9.
1037
-------
EXHIBIT 9
ENVIROTECH
SLUDGE FURNACE vs. AUTOMOBILE
HYDROCARBON EMISSIONS
KM KASON KM DAV
MITOMOMU IIHMMT !•>•
1
L_^^^^^^ ___
•^•4 •• ":*:*
,HBIH
Ti^;?^zsi"
: tsriv^r
SLUDGE FURNACE vs. AUTOMOBILE
CARBON MONOXIDE EMISSIONS
Kfl KMOtt KA DAY
MHO
| ~ 1
MOMl IIMMKT IM«
"Sra-~. resgass:|
. ^.^r^ ,~~-
SLUDGE FURNACE v*. AUTOMOBILE
NrTBOGEN OXIDE EMISSIONS
KM KJOOM W« OAT
Mno
1
MOMU IUMMT UM
•MM
""""TiSS1
,...._^™« — - — '
SLUDGE FURNACE n. AUTOMOBHf
HYDROCARBON EMISSIONS
wro coMnuumvt Mtno
MOOT
mn cn*r**m*i mm
tMrt
SLUDGE FURNACE « AUTOMOBILE
CARBON MONOXKie EMISSIONS
•70 COMXUUTW1 MOTO
"
mowP«H>iy<«no
700.1
SLUDGE FURNACE «•. AinOMOMLE
NITROGEN OXIDE EMISSIONS
«7O OOMNMAITM HATO
mn
-I ••;
m OOMWMIM wno
4'
I might just quickly point out that the clean hydrocarbon emis-
sions based on the 1975 standard are about one two hundred-fiftieths of
the air impact from the sludge furnace per person, per capita; and
carbon monoxide is about one seven-hundredths; and nitrogen oxide
emission, which is the closest comparison, is about one-sixteenth.
I should interject here that in the Livermore Valley, just east of
San Francisco, a sewage treatment plant could not be permitted to
proceed 2 years ago. Because of the impact of the NOX emission in
the valley they couldn't get a construction permit.
* 1038
-------
Our company worked on the construction project at the invitation
of the municipal consulting engineer and reported the air quality data
to the Bay Area Air Pollution Control Board. They got the permit
:o proceed because there was an insignificant impact on air quality
and that is what enabled the construction to proceed.
What about the costs of this treatment technology? In the GAO
report to Congress on EPA R. & D. last year it was stated that "The
high cost of sludge handling and disposal is well recognized." Well,
let's take a look at those costs. The just published Environmental
Engineers' Plandbook chapter on incinerator economics shows a cost
of f 1.05 per capita per year for multiple hearth sludge incineration
for cities of 50,000 population.
For cities of 100,000 population it is 64 cents per capita per year
and down to only 14 cents per capita per year for cities of 1 million
population.
At the Tahoe plant sludge incineration costs amount to one-sixth of
the total plant operating and amortization costs, or about $1.74 per
capita per year.
Fuel costs and labor and material costs have gone up sharply since
these data were developed, but, as mentioned earlier, the new Closed
Loop Energy Systems furnaces eliminate the need for auxiliary oper-
ating fuel. For cities of 1 million population Closed Loop Energy
Systems cost about 38 cents per capita per year. Recent studies for
the Boston metropolitan area show that incinceration reclamation is
the lowest cost and lowest energy use alternative including land
disposal.
Systems have been operating in Europe for some years that also
use shredded waste paper as an auxiliary support source of fuel.
However, when the price of waste paper recently went up, the source
of this material dried up and created problems for those units that
were depending upon this scrap waste paper as a fuel resource. A
^lore reliable source of fueMs obviously that of the sludge itself since
ne is literally converting a "sow's ear into a silk purse'' on site; i.e.,
using the integral fuel value in the sludge to purify itself.
In the industrial sector, I would like to draw on a pulp and paper
industry example to illustrate the advanced technology available. In
the already mentioned GAO report to Congress last year it was esti-
mated that only 5 percent to 20 percent of the technology needed for
zero discharge was available as of June 1973. As an indication of
either technology overlooked or the progress made since that time.
I would like to use an example from the bleached pulp industry to
show what can be done on zero discharge.
Our firm, through its joint venture, with a Canadian firm, has suc-
cessfully conducted pilot demonstration of a process for bleached
kraft mills which produces no contaminated liquid effluent from the
plant. We are working with a Canadian paper company toward the
installation of this system on a possible new 700 ton per day bleached
kraft mill planned in Ontario Province bv 1976.
This brings me to treatment costs and benefits. According to a sur-
vey of 81 municipalities conducted for the R. & D. report by the
1039
-------
GAO, all but one cited the lack of funds or high cost of treatmei.
technology as an impediment to solving its water pollution problems.
Certainly the actions toward the freeing of funds that have taken
place during the first 2 months of this year have removed the bottle-
necks on funds for a half decade or more. With regard to the second
aspect of the answer as to whether technology is available but too
expensive, the survey showed that most municipalities responding
believe that the technology is available but too expensive.
Obviously, I would heartily concur that the technology is available
but what about the expense ? For example, 75 percent of responding
municipalities indicated technology available out too expensive for
physical-chemical treatment processes. I have already commented on
sludge handling and sludge disposal which were included by 64 per-
cent and 58 percent respectively of the respondents as being too expen-
sive, and I am certain that the hidden benefits that I have presented
here, PCB removal and using the fuel value in the sludge, were likely
unknown to these respondents.
I would like to select one physical-chemical treatment process to give
an indication of a posssible, even likely, misassessment by the respond-
ents of the costs versus the benefits of this technology. It has long been
my feeling that it is the benefit side of the cleanup that all too often
misses the view of the person commenting on the cost. One of the hidden
benefits of the water pollution control program has been accelerating
the construction of systems toward that of producing a product water
with a near term industrial reuse and a long-term water supply use
potential.
ExmB.no COST OF CONVENTIONAL AND ADVANCED
TREATMENT OF WASTEWATER
TREATMENT
COST
«/10OO GAL
401_
30
20
10
0
INCREMENTAL COST OF
REUSABLE WATER
SECONDARY &
TERTIARY
SECONDARY
I
I
20 40 60 80
PLANT SIZE
(MIL. GAL. PER DAY)
100
JANUARY <»• -OSTS
(•%. IS YD.)
AMORTIZATION INCLUDED
1C«*0
-------
EXHIBIT 11 POTENTIAL BENEFIT OF WATER REUSE
«/1000
GAL.
40
30
20
10
POSITIVE
POTENTIAL BENEFIT
INCREMENTAL COST OF
REUSABLE WATER
I
I
20
40
60
80
100
PLANT SIZE
(MIL. GAL. PER DAY)
Exhibits 10 and 11 show that the incremental cost of tertiary treat-
ment over secondary treatment could be recovered when the cost of
vew water supply exceeded 13 cents per thousand gallons for cities of 1
aillion population or more and exceeded 22 cents per thousand gallons
for cities of only 15,000 population.
In the San Francisco area the average cost of tap water ranges from
18 cents to 38 cents per thousand gallons. Additional water supply
sources would cost much more than the current charge. Water reuse
offers not only an opportunity to eliminate pollution but to use a finite
resource economically.
Two of our major cities in the West, by the way, have plans underway
for extensive water reuse. Denver is the most advanced and the city of
Los Angles is also undertaking extensive studies in this direction.
In addition to creating a usable product, there are other indirect
benefits from water reuse: First, the elimination of damage. The 1972
damages from water pollution throughout the United States were pro-
jected at $12.8 billion; the savings from clean-up were estimated at
$11.5 billion. The costs to achieve the savings were estimated to be $6.3
billion, providing a net savings of $5.2 billion or about $87 per family
in the United States.
Similar savings were estimated from the elimination of air pollution
damages. Certainly, increased EPA R. & D. in health effects is essential,
and determination of savings from elimination of damage should also
be increased. Elimination of damages, then, must be considered in
1CM
-------
evaluating cost to clean up, particularly when the Federal Government
is to pay a 75-percent share.
And, I believe that the record shows that the costs themselves are
really not that high. To support that contention, I would like to look
quickly at some overall waste treatment costs for individual systems
and community systems, or both biological and physical-chemical
treatment systems (exhibit 12).
EXHIBIT 12 WASTEWATER TREATMENT COSTS
TOTAL '
INDIVIDUAL SYSTEM ($*APITA.»R.)
SEPTIC
TANK
COMMUNITY SYSTEM
SEWEH'CONVENTIONAL WASTE
J 35.30
. SEWER STSTEM PRIM-SEC TERTIARY
TREATMENT TECHNOLOGY I TREATMENT TREATMENT
28.70
SEWER + PHYSICAL CHEMICAL
(P-C)TREATMENT TECHNOLOGY
SEWER SYSTEM | PRIM-SEC
-""pit"" 23.80
BASIS- CAPITAL COSTS ADJUSTED TO JUNE, 1968; 6% AMORTIZATION:
SEWERS-50 YRS , SEPTIC TANKS-35 YRS., SEWAGE TREATMENT
PLANTS-25YRS.
I see my time is running short, Mr. Chairman.
Mr. BROWX. Go ahead, Mr. Sebastian. If we have to run this after-
noon, why, we will do that.
Mr. SEBASTIAN. Thank you, Mr. Chairman.
First, an individual system similar to a septic tank. One very rarely
hears of any opposition to the request on the part of a community to
require septic tanks. However, according to EPA, the costs of a septic
tank amount to $35.30 per capita per year. This includes the amortiza-
tion of the septic tank over 35 years and biannual servicing, but with-
out any consideration of the cost of ultimately treating the material
that must be removed from the septic tank when it is emptied every
2 years or so.
Well, then, what about community systems? Frequently, when talk-
ing about costs, people overlook the first step of community systems,
again, over which there is frequently little controversy in urban areas,
and that is the cost of the sewage collection system.
According to EPA figures, communities with sewers pay about $16
per capita per year for the sewage collection system. When one adds
primary, secondary treatment at the end of the sewage collection sys-
tem in order to remove, say, 80 percent of oxygen-demanding pollu-
tion we get an additional cost of $4.90 for a total of $20.90 for second-
ary treatment.
The treatment costs,-then, are less than one-third the cost of the
sewer system. When tertiary treatment such as that practiced at Lake
-------
Tahoe, with complete treatment of solids and a fully environmentally
compatible system, is added, a cost of $7.80 per capita per year is also
dded, a little more than doubling the cost of primary and secondary
treatment, bringing the total to about $28.70 per year. But notice that
this is still less than the cost of the typical average septic tank, which
is hardly a complete system and is known to contaminate the water
supply in some areas.
Now, in applying cost effective analyses to the responses about al-
leged excessive cost of physical-chemical treatment, one should start
again with the sewer system, $16 per capita per year, but with today's
technology physical-chemical treatment can in many cases be used
instead of biological or conventional waste treatment, and can be con-
trolled in such a way as to achieve a quality of treatment comparable
to biological secondary treatment with a number of added benefits,
such as integral phosphorous removal, resistance to variations in in-
fluent characteristics from industrial effluent. It costs about 5 percent
more than conventional treatment.
However, the greatest benefits from physical-chemical treatment
undoubtedly rest in the long range benefits derived under our national
plan that is looking toward zero pollution discharge as a goal in 1985.
The incremental cost to bring tertiary, or drinkable, quality to a
typical municipal effluent is only $1.70 when added to an existing PCT
plant, bringing the total cost to $23.80 or 17 percent less than the cost
of conventional treatment plus tertiary.
While time available has not permitted me to update these costs
-ince they were published, the relative values are still considered quite
comparable. The most recent figures from EPA, just published by
NERC, Cincinnati last month, show that the capital costs for sewage
facilities in communities from 10,000 to 1,000,000 persons are divided
approximately five-sixths for collection and one-sixth for treatment,
when activated sludge treatment is provided; and if more complete or
gh-quality water is used the capital cost is divided approximately
-nree-quarters for collection and one-quarter for treatment.
Total costs for sewage services in communities of 10,000 to 100,000
persons are divided approximately two-thirds for collection and one-
third for treatment when activated sludge is provided; if complete
treatment is used the cost is divided about equally between collection
and treatment.
Thus, it seems to me to talk about excessive costs one must start from
the collection system to make comparisons, rather than with the treat-
ment plant because no improvement in quality occurs in the normal
collection step.
Before closing, I would like to add one comment about air quality.
Last year, the Industrial Gas Cleaning Institute recommended that
EPA consider providing at least a 50-percent Government share for
demonstration plants on SO, removal at power stations for at least one
throwaway system and two to three recovery-type systems. I under-
stand that one such SO2 program for a double alkali throwaway system
is imminent on a 100-megawatt-sized unit and perhaps a second one of
less than 100 megawatt size.
I would like to add my support to EPA for its R. & D. efforts and
ilirofHon«. and suggest that consideration be given to even further em-
-------
phasis to the health effects, particularly research in the area of watf
reuse, and of benefits from damages eliminated through clean-up.
I hope I have shown that far more technology exists in the equip-
ment industry community than is generally recognized, aud that there
is indeed far more reasonable cost technology available to move us to-
Avard 1985 goals than is being required at the present time in the
municipal sector.
Equipment industry-conducted R. & D. largely complements EPA
R. & D. and supports the overall objectives and goals of the Clean
Water Act and the EPA.
Thank you, Mr. Chairman.
Mr. BROWN. Thank you, Mr. Sebastian. I think that the record which
you have helped to make is going to create a great deal of interest not
only to the members of this committee but to the entire Congress. I
think that the goal which yon have indicated, of a complete clean-up
in our environmental system, is one which the Congress is moving
fairly rapidly toward.
I am going to defer questioning, if I may, Mr. Sebastian.
Mr. SEBASTIAN. Yes, sir.
Mr. BROWN. I still hope that we can get through by 11 when another
committee has to take over here. I will ask if I may submit questions
to you in writing and if you will respond to them.
Mr. SEBASTIAX. I will be happy to do so.
Mr. BROWN. I am extremely grateful to you for your testimony.
Now, I am going to invite Dr. James Pitts to take the witness stand.
Dr. Pitts is also from California and happens to come from my own
home district where he is head of the environmental laboratory at the
University of California, Riverside. That laboratory is a major re-
source in the fight against atmospheric pollution not only for the State
of California but for the entire United States.
We are very pleased to have you with us, Dr. Pitts, and are lool
forward to your testimony; we apologize for the time pressure wh.^i
has been forced upon us here.
Dr. PITTS. Thank you very much, Mr. Chairman. I might start by
officially wishing the chairman of this committee a happy birthday,
and indeed as a token of my esteem it seems appropriate, since we are
dealing with air pollution, that I brought for you a cigar.
Mr. BROWN. We were going to celebrate with a little of that Tahoe
champagne.
Dr. PITTS. We can go both ways there. I am sure you will not be a
stationary source. I have never seen you stationary. Mobile is indeed
the word.
I will in fact compress my remarks. I think it is only fair play to do
that. Professors have inflicted extended remarks upon students for
years, and compression cannot hurt at all.
For the record I would like to indicate that on page 7 there is a
point that is fairly useful. We left out a line. Under Atmospheric Mon-
itoring it should read,
"For the measurement of ambient NO and XO2 and used to calibrate field
instruments for the measurement of ambient NO and NO3 are themselves cali-
brated against the known stream of ozone. If this ozone is in error, then tho
"standard" calibration gases, and hence the instrument measuring ambient NO
and NO. in the field will also be in error."
-------
That is an interesting point. A large number, hundreds of instru-
ments that are put out to calibrate NO and NCK for your intimates in
;he field are in turn back-calibrated against oxidants, so that if the
oxidant calibration is wrong you now have errors in NO and NO2.
This indicates I think one of the reasons I am fully supportive of an
increased effort on the part of the EPA, cooperative effort with State
agencies, local agencies, and other Federal agencies to develop and to
coordinate this very important area of environmental monitoring.
Surely if we can't measure what the impact upon man and his en-
vironment is, then how can we indeed legislate appropriate laws for
control of our environment and then implement those laws through
our agencies ?
Mr. BROWN. Without objection your entire statement will be in-
cluded in the record with the one correction that you have indicated,
and you may proceed with your oral presentation in any fashion you
wish.
Dr. PITTS. I will go back now, but let me just indicate the following:
I am fully supportive of the remarks of Dr. MacDonald. In fact, we
fully agree. I had perhaps followed along focusing upon processes and
effects and perhaps fine-tuning some of his comments in the sense of
giving specific examples of where research is needed, desperately
needed, for the decisionmakers, so that we have a much better data
base to make the decisions that are costing us billions of dollars.
I might also say parenthetically the decision yesterday of Mr. Train
to defer the implementation of stricter emission standards on cars and
the basis on which that decision was made was based upon sulf ate emis-
sions—a prime example of where if some research had been done in
advance we could have avoided this problem. And the problem has been
embarrassing to the Government and embarrassing financially to a
number of automobile manufacturers who have gone the catalytic
route. It is a prime example of the type of situation where I would
'ke to say more defensive research should be done by agencies, a num-
.er of agencies.
The question of what problem are we going to face could have been
examined in advance.
I predict you will be here in a couple of years to discuss the problems
of diesel exhaust. The diesel engine represents a very interesting way of
combining high-fuel economy and low emissions. There is a foreign car
today which meets the Federal standards several years hence in all
aspects, at least in many aspects. It certainly will meet the new pro-
posed Train's 82 standards. Yet it is a diesel.
Now, the question is what are the particular chemical and physical
characteristics, toxics, potential carcinogens, what happens to the par-
ticulate matter in the exhaust when released to the atmosphere ? These
are all subjects amenable to rational scientific investigation. And I
would say that several years ago we should have looked at a problem
such as this, because this is an alternative system to the conventional
engine.
Another alternative system which is in fact currently driving about
and I understand selling well in California is the stratified charge
automobiles. The emissions—and I have the 1975 official emissions—
read something like the following: six-tenths of a gram per mile, hy-
-------
drocarbon; 4,9 grams per mole, CO; and 1.38 grains per mile. NC
This is a car being driven in California today, a car sold commercially.
That could be contrasted with the proposed standards yesterday of 1.5
grams per mile, hydrocarbons; 15 grams per mile, CO; and 2 grams
per mile, NO*.
It is perfectly clear that technologically this is a smaller car, but
with a smaller car it gets substantial savings, as you know, in fuel
economy.
I Avill admit it is a foreign car. I would prefer to buy an American
car—we all do. TVe want jobs here. It is a shame to see this happen.
I might even add that a reproduction model of this particular car,
equipped with the 1977 emission control system, has been tested and
emissions were .23 grams per mile hydrocarbons, almost half of the
original Muskie standards for 1977. This is the National Academy of
Science report of November, 1974. This is not hearsay, it is in the
National Academy report.
I would, if you are interested—I had prepared these comments
before Mi'. Train's statement yesterday at the request of the attorney
general of California's task force. If you would like them for the
record, the numbers are there.
Mr. BROWX. Yes, without objection that additional statement will be
included in the record.
-------
Exhibit 2
Air Pollution
Aspects of
Sludge Incineration
Technology Transfer Seminar Publication
-------
EPA-625/4-75-009
AIR POLLUTION ASPECTS
OF SLUDGE INCINERATION
ENVIRONMENTAL PROTECTION AGENCY* Technology Transfer
June 1975
10
-------
ACKNOWLEDGMENTS
This seminar publication contains materials prepared for the
U.S. Environmental Protection Agency Technology Transfer Program
and has been presented at Technology Transfer design seminars
throughout the United States.
A portion of this publication appeared originally in the
Technology Transfer Process Design Manual for Sludge Treatment
and Disposal. Additional information included was prepared by
Gordon Gulp, representing Gulp, Wesner, Gulp—Clean Water
Consultants, Eldorado Hills, Calif.
NOTICE
The mention of trade names or commercial products in this publication is
for illustration purposes, and does not constitute endorsement or
recd"mmendation for use by the U.S. Environmental Protection Agencv.
-------
CONTENTS
Page
Introduction
Particulate Matter
Metals {
Gaseous Pollutants J
Organics 1C
Conclusions 1
Case Histories 1
Livermore, Calif 1
Palo Alto, Calif 1!
References ...... \'t
1050
-------
INTRODUCTION
Incineration offers the opportunity to reduce sludge to a sterile landfill and remove offensive
>dors, but it also has the potential to be a significant contributor to the air pollution problem in an
irban community. The quantity and size of particulate emissions leaving the furnace of an
ncinerator vary widely, depending on such factors as the sludge being fired, operating procedures,
md completeness of combustion. Incomplete combustion can form objectionable intermediate
>roducts, such as hydrocarbons and carbon monoxide. There is also the potential for discharge of
ir pollutants such as sulfur dioxide, nitrous oxides, and metals such as mercury.
PARTICULATE MATTER
New Source Performance Standards (NSPS) regulating discharges from municipal sludge mcin-
rators have been promulgated by the Environmental Protection Agency (EPA). These standards
mit the discharge of particulate matter from both new and modified sewage sludge incinerators.
'he process weight and opacity restrictions placed on this atmospheric pollution source are:'
• No more than 0.65 g/kg dry sludge input (1.30 Ib/ton dry sludge input).
• Less than 20 percent opacity. Visible emissions caused solely by the presence of uncom-
bined water are not subject to the opacity standard.
Available data indicate that, on the average, uncontrolled multiple-hearth incinerator gases con-
ain about 0.6 grain of particulate per standard cubic foot of dry gas.2 Uncontrolled fluid-bed reac-
or gases contain about 1.0 grain of particulate per standard cubic foot.3 For average municipal
rastewater sludge, these uncontrolled pollutant concentrations correspond to about 33 pounds of
(articulates per ton of sludge burned in a multiple hearth, and about 45 pounds of particulates per
on of sludge burned in a fluid-bed incinerator. Particulate collection efficiencies of 96 to 97 per-
ent are required to meet the NSPS,4 based on the above uncontrolled emission rate.
Sludge incinerators differ from most other types of incinerators in that the sludge does not nor-
lally supply enough heat to sustain combustion. Furthermore, there is less emphasis on retaining
sh in the incinerator and much of it is discharged in stack gases. Particulate emissions to the atmos-
ihere are almost entirely a function of the scrubber efficiency and are only minimally affected by
icinerator conditions. Sludge incinerators in the United States are equipped with scrubbers of vary-
ig efficiency. These scrubbers range from simple spray-tower-type units to venturi-type scrubbers
fith pressure drops up to 40 inches of water.
Existing State or local regulations in the United States tend to regulate sludge incinerator emis-
lons through incinerator codes or process weightJjMpJations.5 Many State and local standards are
-------
Table 1 .-Sludge incinerator facility A,: Summary of results
Item
Pate
Stack effluent:
COj volume % dry
CO volume % dry
Visible emissions % opacity
Paniculate emissions:
Probe and filter catch
Ib/h . . .
Ib/ton of feed . . ,..,.,.,.,,...
Total catch.
Ib/h
Ib/ton of feed
Run number
1
1-11-72
108
0.550
2,880
314,000
59
1.93
12.8
4.8
0
<0.3
4.2
<3.8
<10
0.024
0.023
0.583
1.06
0.032
0.031
0.779
1.42
2
1-12-72
108
0.560
2,550
273,000
59
1.92
12.6
4.7
0
<0.3
5.7
<2.9
<10
0.005
0.005
0.116
0.207
0.007
0.007
0.160
0.286
3
1-12-72
108
0.560
2,660
285,000
59
2.23
11.5
6.4
0
<0.3
6.4
<4.1
<10
0.004
0.004
0.099
0.177
0.010
0.010
0.227
0.405
Average
108
0.557
2,700
291,000
59
2.03
12.3
5.3
0
<0.3
5.4
<3.6
<10
0.011
0.011
0.266
0.481
0.0163
0.016
0.389
0.704
feet.
Note.—dscfm indicates dry standard cubic feet per minute; dscf indicates dry standard cubic feet, acf indicates actual cubic
Source- Background Information for Proposed New Source Performance Standards, EPA Report APTD-13526, June 1973,
vol. 2, appendix.
corrected to a reference base of 12 percent carbon dioxide or 6 percent oxygen. Corrections to
CO2 or O2 baselines are not directly related to the sludge incineration rate, because of the high per-
centage of auxiliary fuel required. In some regulations, the CO2 from fuel burning is subtracted froir
the total when determining compliance.
-------
Table 2.—Sludge incinerator facility At • Summary of results
Item
Date
Stack effluent:
Particulate emissions, total catch:
gr/dscf (correspond? to 1 2% CO2 )
tb/h
Ib/ton of feed
1
5-3-71
60
0.325
3,480
642,500
80
3.4
4.0
<1
0.020
0.019
0.596
1.84
-tun number
2
5-4-71
60
0.325
3,600
664,600
80
3.4
5.1
<1
0.031
0.029
0.956
2.94
3
5-4-71
60
0.325
3,320
612,900
78
3.4
4.0
<1
0.048
0.047
1.365
4.20
60
0.325
3,470
640,600
79
3.4
4.4
<1
0.033
0.032
0.972
299
'No SO2 detected.
Opacity was not recorded.
Note.—Tested by local agency using code method 1. Probe and filter catch not analyzed separately, dscfm indicates dry
standard cubic feet per minute, dscf indicates dry standard cubic feet, acf indicates actual cubic feet.
Source: Background Information for Proposed New Source Performance Standards, EPA Report APTD-13526, June 1973,
vol. 2, appendix.
In developing the foregoing NSPS, tests were conducted on the gaseous discharges from several
sludge incinerators. Stack tests were conducted by EPA at five locations, including three multiple-
hearth incinerators and two fluid-bed reactors, as follows:6
A. Fluidized-bed reactor, 1,100 Ib/h dry solids design capacity, operated at 100 percent
capacity during test, equipped with a 20-inch-water-pressure-drop venturi scrubber
operated at 18 inches water pressure drop. Tested by EPA and by a State agency, the lat-
ter using code method 8 (see tables 1 and 2).
B. Multiple-hearth (six hearths) incinerator, 750 Ib/h dry solids design capacity, operated at
64 percent capacity during test, equipped with a 6-inch-water-pressure-drop single-
crossflow perforated-plate impinjet scrubber (see table 3).
C. Multiple-hearth (six hearths) incinerator, 900 Ib/h dry solids design capacity, operated at
35 percent capacity during test, equipped with a 6-inch-water-pressure-drop single-
crossflow perforated-plate impinjet scrubber (see table 4).
1G53
-------
Table 3.—Sludge incinerator facility B. Summary of results
Item
Stack effluent:
CO2 volume % dry
Oj volume % dry
CO volume % dry . ...
SO2 emissions ppm
IMOX emissions ppm
HCI emissions ppm
^*
Particulate emissions'
Probe and filter catch:
gr/dscf
gr/acf
Ib/h
Ib/ton of feed
Total catch:
gr/dscf ... .
gr/acf
Ib/h
Ib/ton of feed
F
1
10-13-71
120
0.237
3,300
835,000
198
3.64
3.8
17.3
0
2.29 to 2.57
<10
0.0245
0.0187
0 690
291
00374
00289
1 06
447
lun numbe
2
10-14-71
120
0.236
2,950
750,000
196
4.02
4.7
1.40
0
2.75
<10
00196
0.0155
0 495
2 10
00374
0 0287
0945
4 00
r
3
10-14-71
120
0.249
2,120
511,000
199
3.65
2.7
15.8
0
44.2 to 24.3
14.3
0.624 to 1 .33
0.621
<10
00173
0.0132
0 315
1 26
0 0457
00348
0832
3 34
120
0.241
2,790
699,000
198
3.77
3.7
15.7
0
2.53
27.6
0.858
<10
0 0205
00158
0 500
2 09
0 0402
00308
0 946
3 94
Note,—dscfm indicates dry standard cubic feet per minute, dscf indicates dry standard cubic feet, acf indicates actual cubic
feet.
Source- Background Information for Proposed New Source Performance Standards, EPA Report APTD-13526. June 1973,
vol. 2, appendix.
D. Fluidized-bed reactor, 500 Ib/h dry solids design capacity, operated at 95 percent capac-
ity during test, equipped with a 4-inch-water-pressure-drop single-crossflow perforated-
plate impinjet scrubber (see table 5).
E. Multiple-hearth incinerator, 2,500 Ib/h dry solids design capacity, operated at about 50
percent capacity during tests, equipped with a 2.5-inch-water-pressure-drop cyclonic iner-
tial jet scrubber (see table 6).
'
-------
Table 4.-~Sludge incinerator facility C: Summary of results
Item
ite
ack effluent:
COa volume % dry .
CO volume % dry
.*-
sible emissions, % opacity
rticulate emissions:
Probe and filter catch:
gr/dscf
gr/acf
Ib/h
Ib/ton of feed
Total catch*
gr/dscf
gr/acf . .
Ib/h
Ib/ton of feed
1
7-15-71
80
0.111
1,230
665,000
80
3.23
10.0
7.7
0
1 5.9 to 1 1 .9
402 to 140
3 50 to 2 62
<10
0.0127
0 00985
0 127
1 14
0.0195
00150
0206
1 86
Run number
2
7-15-71
80
0.149
1,490
600,000
80
3.00
10.1
7.3
0
14.5 to 14.6
908 to 74.3
2 33 to 2 62
<10
00620
0 0477
0620
4 16
00696
00535
0 889
597
3
7-16-71
80
0.146
1,400
575,000
77
2.95
10.2
7.4
0
14.6 to 13.3
14.5 to 142
50.6 to 61 .8
2 52 to 2 62
<10
00196
0 0152
0 196
1 34
00260
0 0201
0312
2 14
80
0.135
1,373
613,000
79
3.06
10.1
7.5
0
14.2
163
2 72
<10
00314
00242
0 314
2 21
00384
0 0295
0 469
3 23
Note.—dscfm indicates dry standard cubic feet per minute, dscf indicates dry standard cubic feet, acf indicates actual cubic
5t.
Source Background Information for Proposed New Source Performance Standards, EPA Report.APTD-13526, June 1973,
I. 2, appendix.
The results of these tests are shown in tables 1 to 6. Figure 1 summarizes the results of the
articulate measurements. The results from the unit using a venturi scrubber operating at 18-inch
rater pressure drop were used as the basis for the standard. The other systems using other types of
crubbers operating at lower pressure drops failed to meet the promulgated NSPS of 1.3 Ib/ton dry
udge input. The study of these facilities indicated no relationship between the mass emission rates
nd the percent of rated capacity at which the incinerator was operating, but a strong relationship
letween pressure drop across the scrubber and mass emission rates was found.4 All of the systems
asily met the opacity standard. Observations at 15 other facilities indicated they all met a 10-percent
1055
-------
Table ^.-Sludge incinerator facility D: Summary of results
Item
Stack effluent:
CO2 volume % dry
HCI emissions ppm
.-*
Visible emission % opacity
Particulate emissions:
Probe and filter catch:
gr/dscf
gr/acf
Ib/h
Ib/ton of feed
Total catch
gr/dscf
gr/acf
Ib/h
Ib/ton of feed
1
7-21-71
120
0.255
1,190
280,000
99
3.92
8.8
6.3
0
8 29 to 1 1 2
1 54 to 1 68
0.780 to 260
<10
0.0551
00468
0562
220
0.0665
00565
0678
266
Run number
2
7-21-71
96
0.237
1,170
296,000
99
4.90
9.9
7.4
0
14 8 to 148
41 2 to 42 9
4.16 to 1 56
<10
00766
00650
0 768
324
00859
00729
0861
363
3
7-22-71
96
0.202
1,240
368,000
95
3.48
9.1
8.2
0
142to154
17.8
187 to 170
161
2 35 to 2 09
<10
00545
0 0467
0 579
2 87
00653
00559
0 694
343
10<
0.23
1,20
315,00
&
3.8.
9.:
7.:
i
131
13
22
<1
0062
0052
0 636
2 77
00721
0061
0 744
3 24
Note.-dscfm indicates dry standard cubic feet per minute; dscf indicates dry standard cubic feet: acf indicates actual cubi
feet.
Source: Background Information for Proposed New Source Performance Standards, EPA Report APTD-13526, June 1973
vol. 2, appendix.
opacity. The estimated costs of the scrubbing systems used as standard practice in the United Stat«
are typically about 4 percent of the total incineration facility for a plant serving 100,000 people.
The scrubber required to achieve the proposed particulate standards would increase the cost an esti-
mated 0.4 percent. Annual operating costs were estimated to be increased by 0.9 percent.5
105S
-------
Table G.—Sludge incinerator facility E: Summary of results
Item
Stack effluent:
CO2 volume % dry
O-2 volume % dry
CO volume % dry
SO2 emissions ppm
NOX emissions 'ppm
HCI emissions ppm
Particulate emissions:
Probe and filter catch-
gr/dsf
gr/acf
Ib/h
Ib/ton of feed . .
Total catch.
gr/dscf
gr/acf
Ib/h
Ib/ton of feed
1
8-5-71
96
0.689
9,840
135
16.3
4.2
14.9
0
2.01
62.8 to 46.0
11.9
<10
0,0260'
QiOT96-
2 19
3 18
0.0335
00252
2.83
4 11
Run number
2
8-5-71
96
0.855
8,510
145
18.6
4.3
14.9
0
2.07
-------
PARTICULATE EMISSIONS (Ib/ton dry sludge)
O :-• fO U ^
t
Maximum
I Average
Minimum
1
Test method No. 2 =
2
AP = Pressure drop
•— 2
•)
^
\
A,
»
I
1-
1
AP
2
EPAm
1 *
= 4-in. H2O
AP = 6-in. H20
AP = 6-m. H20
1
AP= 18-in. H2O
1 1
B C
I
D
AP
1
sthod 5
2
i
= 2.5-in. H2O —
1
E
PLANT, CONTROL EQUIPMENT
s*
Figure 1. Particulate emissions from sludge incinerators at wastewater treatment plants.
(See reference 4.)
METALS
Wastewater sludges contain metals that could be hazardous if discharged into the atmosphere.
Unfortunately, there are very few data on the metals being discharged to the atmosphere from
municipal sludge incineration. The forms in which metals are found in sludge will influence their
behavior on incineration.5 For example, if cadmium is present in the sludge in solution as cadmium
chloride, it could volatilize upon incineration. If it is present as a precipitated hydroxide, it would
probably decompose to the oxide, but would not volatilize at the temperatures of incineration. It is
believed, however, that most of the hazardous or potentially hazardous metals, with the exception of
mercury, will not disproportionately appear in stack gases because of volatilization, but will be con-
verted to oxides and appear in the particulates removed by scrubbers or electrostatic precipitators
and in the ash.
1050
-------
Some data are available on the discharge of manganese and nickel, which indicate the following
emission rates from incinerator facilities with emission controls:
Metal
Mn
|\|i
Emission factor range,
millipounds per ton (dry solids)
0.5 to 1 .6
.2 to 8.2
In both cases, the higher limit is represented by a single measurement.
Mercury is an example of a substance that presents special problems during incineration. High
temperatures during incineration decompose mercury compounds to volatile mercuric oxide or
metallic mercury.
Tests for mercury have been conducted by EPA? on 42 sewage treatment plant sludges. The
mercury content ranged from 0.6 ppm to 43 ppm (in terms of dry solids) with an average value of
4.2 ppm. Tests on five incinerators equipped with scrubbers showed an average emission factor of
1.65 grams of mercury emitted to the atmosphere per metric ton of dry sludge incinerated.
Mercury-removal efficiencies of water scrubbers varied from 68 to 96 percent. A study of the fate
of mercury in municipal incineration plants has reported8 that 9.7 percent of the mercury entering
a multiple-hearth furnace at Palo Alto, Calif., escaped the wet scrubber and entered the atmosphere,
59 percent appeared in the furnace ash, and the remainder appeared in the scrubber underflow. In
th» same incinerator, only 0.84 percent of the lead in the sludge feed entered the atmosphere, with
88 percent in the ash and the rest in the scrubber underflow. The wet scrubber removed 93 percent
of the lead and 76 percent of the mercury from the exhaust gases.
In accordance with Section 112 of the Clean Air Act Amendments of 1970, a national emission
standard for mercury as a hazardous atmospheric pollutant resulting from sludge incineration was
proposed on October 25, 1974. This proposed hazardous pollutant standard limits the atmospheric
discharge of mercury from the incineration and drying of wastewater-treatment-plant sludges to a
maximum of 3,200 g/d.9 This limit is based on maintaining an average ambient mercury concentra-
tion of 1 Aig/m3 over a 30-day period. At an average emission rate (using wet scrubbers) of 1.65
grams of mercury per metric ton of dry solids incinerated, incineration facilities of 1,939 metric
tons per day of dry solids (2,138 tons per day of dry solids) will approach this limit. There are,
however, no known existing wastewater plants or new plants anticipated for use in the foreseeable
future that will approach this size.
GASEOUS POLLUTANTS
Gaseous pollutants that could be released by sludge incineration are hydrogen chloride, sulfur
dioxide, oxides of nitrogen, and carbon monoxide. Data are presented in tables 1-6 on the quanti-
ties of these materials found in stack gases. Carbon monoxide is no threat if the incinerator is prop-
erly designed and operated. Hydrogen chloride, which would be generated by decomposition of
certain plastics, is not a significant problem at concentrations currently observed. Consideration of
1059
-------
the possibility of SO2 and NOX pollution is aided by examination of the sulfur and nitrogen content
of sludges. Sulfur content is relatively low in most sludges. In addition, much of this sulfur is in
the form of sulfate, which originated in the wastewater. Sulfur dioxide is not expected to be a seri-
ous problem. At San Mateo, Calif., the SO2 discharge concentrations were found to be 10.2 ppm as
compared to a 300-ppm standard.' °
Sludge typically has a high nitrogen content from proteinaceous compounds and ammonium
ion. Limited data are available for predicting whether a high proportion of these materials will be
converted to oxides of nitrogen on combustion. From the data available, the concentration of
oxides of nitrogen from sludge incineration should be less than 100 ppm from a properly operated
incinerator, and were observed to be less than 10 ppm from facility A (table 1). Considering this
low concentration, the production of oxides of nitrogen will probably not limit the use of incinera-
tion for disposing of sludge in most cases.
ORGANICS
In addition to the major air pollutants resulting from the burning of sludge, toxic substances
can arise because of the content of pesticides or other organic compounds in the sludge. Unfor-
tunately, very limited data are available on the concentrations of these materials in municipal
sludges or their fate in an incinerator. Data reported by EPA,5 in a random selection of sludges,
showed the following levels of materials present in the raw sludges:
Compound
Aldrin
ODD
DOT
PCB's ....
Range (ppm)
16 (in one sludge only)
0.08 to 2.0
3.0 to 32
Not detected to 0.5
Not detected to 1 .1
Not detected to 1 05
Pesticide and polychlorinated-biphenyl (PCB) determinations were made on sludges collected
during the incinerator tests at three of the five plants listed in tables 1-6.5 PCB's were found in all
of these sludges, but concentrations were low (1.2 to 2.5 ppm). Pesticides and PCB's were found
only in the sludge. They were not found in the ash from either type incinerator, nor in the inlet or
outlet scrubber water. Ash can be analyzed for these materials to the same degree of sensitivity as
the sludge. A level of 0.1 /ig/g (ppm) could easily have been detected. It is quite certain that these
materials are not being carried out in the ash.
The mass flow rate of water to the scrubber is about 400 times the dry solids flow rate to the
incinerator. Consequently, the concentration at which these materials can be detected in water must
be sufficiently low to be sure that they are not escaping in the scrubber water. Fortunately, analyti-
cal techniques are such that these materials can be detected in water down to 0.1 ng/g (ppb). Thus,
it is reasonable to believe that they are not in the scrubber water.
Since the PCB's do not appear in ash or scrubber water, they are either destroyed by incinera-
tion or remain as vapors in the water-scrubbed (and cooled) gas stream. All of these materials have
some solubility in water, and it is likely that no trace would be present in the scrubber water. Conse-
IC&3
-------
quently, their escape as vapors from the incinerators seems unlikely. However, one should also exam-
ine the available data on the decomposition of PCB's and pesticides in other situations.
Rapid thermal degradation of most pesticides has been shown to begin at approximately 500°
C with near total destruction at 900° C (1,652° F).1' -1 2 If these materials volatilize before burning,
the use of afterburners on incinerators would be needed to provide complete destruction. One man-
ufacturer of pesticides achieves near total destruction of pesticides in its multiple-hearth carbon re-
generator by providing an afterburner using a 0.23-0.80-second retention time at 1,600° to 1,800° P.
The PCB's are even more thermally stable than most pesticides, as one would suspect. An in-
cinerator at St. Louis, Mo., achieves total destruction of concentrated PCB's at 2,400° F with a re-
tention time of 2.5 seconds. Experiments have shown, however, that 99 percent destruction is possi-
ble at 1,600° to 1,800° F in 2.0 seconds on pure PCB's.
Tests on municipal sludges' ° showed that total destruction of PCB was possible when oxidized
in combination with sewage sludge and with an exhaust gas temperature of 1100° F versus 1600° F
required when PCB's are handled separately. Ninety-five percent destruction of PCB's was achieved
in a multiple-hearth furnace with no afterburning at the normal exhaust temperature of 700° F.
CONCLUSIONS
The EPA Sewage Sludge Incineration Task Force5 concluded that it has been adequately dem-
onstrated that existing well-designed and -operated municipal wastewater sludge incinerators are
capable of meeting the most stringent particulate emission control regulation existing in any State
or local control agency. This observation, coupled with the fact that the newly promulgated Federal
NSPS are based on demonstrated performance of an operating facility, indicates that use of proper
emission controls and proper operation of the incineration system will enable a facility to meet all
existing particulate matter regulations. Although only the venturi scrubber (tables 1-6) met the pro-
mulgated standard in the EPA tests, EPA4 has stated that—
Impingement scrubbers tested by EPA did not meet the standard but, in our best judgment, would do so if
used in conjunction with an oxygen meter that automatically regulates fuel burning rate. In our best judgment,
electrostatic precipitators could also provide more than adequate control. There are no EPA test data on
either of these control systems because during the test program there were no existing plants using them.
CASE HISTORIES
LIVERMORE, CALIF.
A recent evaluation10 of the environmental impact of sludge incineration at Livermore, Calif.,
provides an interesting case history. Livermore proposed to install multiple-hearth furnaces for
1061
-------
sludge incineration and lime recalcining. Much of the offgas from the recalcining furnace will be re-
cycled to the plant for recarbonation of the lime-treated wastewater. The Bay Area Air Pollution
Control District (BAAPCD) adopted standards for discharge as shown in table 7. Also shown in
table 7 are the results of analyses made at a nearby (San Mateo) multiple-hearth sludge incinerator.
These test data and those presented in tables 2-6 indicate that little difficulty should be encountered
in meeting particulate, hydrocarbon, and carbonyl standards with a properly designed and operated
system. Of major interest in Livermore was the potential impact of NO^., although there were no
standards established. The relative contributions of NO^ in the Livermore valley from several sources
were evaluated with the following results;
Source
Automobiles
Sludge hauling ....
Sludge oxidation . . .
Lime recalcining . . .
Pounds NOX per day
28000
10
50
12
The sludge-hauling value is only for the hauling of sludges to the border of the valley where it and
the pesticides and PCB's it contains still must be dealt with in an environmentally acceptable fashion.
In this example, the NO^ contribution from multiple-hearth incineration was slightly higher than the
NOj,. contribution from hauling only, but still was an insignificant fraction (0.2 percent) of the
total NO.J discharge in the study area. The average per capita discharges of pollutants from automo-
biles and sludge incinerators were also calculated, and the results are shown in figures 2-4.
Table 7.—Emission limits at Livermore, Calif.
Test
Hydrocarbons C2 -C$ ppm (dry basis) at 6 percent O2
Total carbonyls ppm (dry basis) at 6 percent O2 . . ... ... ....
Grain loading gr/dscf2 at 1 2 percent CO2
Test results
0.4 - 2.2
34-7.6
0.017-0.021
Emission limits'
25
25
0.15
'According to the California BAAPCD regulation 2 for units under 100 tons per day capacity with emissions adjusted to 6
percent O2.
dscf indicates dry standard cubic feet.
Source' F. P. Sebastian et at., "Sludge Incineration—Air Emission Standards vs. Technology—A Case Study," presented at
Water and Wastewater Equipment Manufacturers Association Industrial Water and Pollution Conference and Exposition, Detroit,
Mich., Apr. 1974.
PALO ALTO, CALIF.
Figure 5 illustrates the results obtained at Palo Alto, Calif., with a multiple-hearth furnace
equipped with multiple-tray impingement scrubbers. Nitrous oxide emission at Palo Alto was only
0.037 g/day' ° as compared to 0.29 shown in figure 4 as a typical value. If this level of NOX were
achieved in the Livermore example discussed earlier, the NO^ discharge from incineration and
recalcination would be even less than that from hauling alone.
REFERENCES
1 "National Source Performance Standards, Municipal Incineration," Fed. Reg., 36, No. 247,
24876, Dec. 23, 1971. 1GG2
-------
1972 automobile
40.8
1975 automobile
Oxidation
4.8
0.019
10
20 30
GRAMS PER DAY
40
50
Figure 2. Relative per capita contributions of hydrocarbons from automobiles and sludge incineration.
(See reference 10.)
1972 auto mobile
1975 automobile
Oxidation
468.0
450
460
30 40
GRAMS PER DAY
Figure 3. Relative per capita contributions of carbon monoxide from automobiles and sludge incineration.
(See reference 10.)
470
1972 automobile
1975 automobile
Oxidation
36.0
20 30
GRAMS PER DAY
40
50
Figure 4. Relative per capita contributions of nitrogen oxides from automobiles and sludge incineration.
(See reference 10.)
1063
-------
Hydro- Carbonyls, Sulfur
carbons, ppm oxides
ppm (S02),
ppm
E5J Standards
Particulate
emissions,
gr/dscf
Actual
Figure 5. Standards and emissions from the Palo Alto multiple-hearth incinerator.
(See reference 10.)
2 S. Balakrishman, D. E. Williamson, and R. W. Okey, State of the Art Review on Sludge Incin-
eration Practice. Federal Water Quality Administration Report 17070 olV 04/70,1970.
3R. S. Burd, A Study of Sludge Handling and Disposal. Federal Water Pollution Control Ad-
ministration Publication WP-20-4, May 1968.
"Background Information foi New Source Performance Standards, EPA Report 450/2-74-003,
APTD-1352C, Feb. 1974, vol. 3.
5 Final report, "Sewage Sludge Incineration Task Force," EPA, Feb. 1970.
6Background Information for Proposed New Source Performance Standards, EPA Report
APTD-13526, June 1973, vol. 2, appendix.
''Background Information on National Emission Standards for Hazardous Air Pollutants—
Proposed Amendments to Standards for Asbestos and Mercury, EPA 450/2-74-009a, Oct. 1974.
8 "A Study of Pesticide disposal in a Sewage Sludge Incinerator," Versar, Inc., Monthly prog-
ress report, EPA Contract No. 68-01-1587, Sept. 9,1974.
-------
'"Asbestos and Mercury—Proposed Amendments to National Emission Standards," Fed. Reg.,
39, No. 208, pt. 2, 38064, Oct. 25,1974.
1 °F. P. Sebastian et al., "Sludge Incineration—Air Emission Standards vs. Technology—A Case
Study," presented at Water and Wastewater Equipment Manufacturers Association Industrial Water
and Pollution Conference and Exposition, Detroit, Mich., Apr. 1974.
1' Basic Research on Equipment and Methods for Decontamination and Disposal of Pesticides
and Pesticide Containers, annual report, USDA Grant No. 12-14-100-9182(34), Mississippi State
University, June 1968 to June 1969.
12 Organic Pesticides and Pesticide Containers—A Study of Their Decontamination and Com-
bustion, Foster D. Snell, Inc., final report, Bureau of Solid Waste Management Contract No. CPA-
69-140,1970.
1065
-------
METRIC CONVERSION TABLES
Recommended Units
ueicription
Length
Area
Volume
Mass
Time
Force
Moment or
torque
itreu
Unit
metre
kilometre
millimetre
micrometre
square metre
square kilometre
square millimetre
hectare
cubic metre
litre
kilogram
gram
milligram
tonne or
megagram
second
day
year
newton
newton metre
pascal
kilopascal
Symbol
m
km
mm
urn
m2
km*
mm2
ha
m3
1
kg
g
mg
t
Mg
s
d.
year
N
N-m
Pa
kPa
Comments
Basic SI unit
The hectare (10 000
m2) is a recognized
multiple unit and
will remain in inter-
national usa.
The litre is now
recognized as the
special name for
the cubic decimetre.
Baste SI unit
1 tonne = 1 000 kg
1 Mg = 1 OOQ kg
Basic SI unit
Neither the day nor
the year is an SI unit
but both are impor-
tant.
JtttB newton is that
force that produces
tn acceleration of
1 m/i2 in a mass
of 1 kg.
The metre is
measured perpendicu-
lar to the line of
action of the force
N. Not a joule
Customary
Equivalents
3937in.=328ft=
1.09yd
0.62 mi
0.03937 in
3937X103=103A
10 764 sq ft
= 1.196 sq yd
6.384 sq mi =
247 acres
0.001 55 sq in
2.471 acres
35.314 cuff
1.3079cuyd
1. 057 qt = 0.264 gal
= 0.81X10* acre-
ft
2.205 Ib
0035oi= 15.43 gr
0.01 543 gr
0.984 ton (long) =
1.1023 ton (short)
02248 lib (weight)
= 7.233 poundals
0.7375 ft-Ibf
0.02089 Ibf/sq ft
0.14465 Ibf/sqm
Description
Velocity
linear
angular
Flow (volumetric)
Viscosity
Pressure
Temperature
Work, energy.
quantity of heat
Power
Application of Units
Jescription
•recipitation.
un-oR,
vaporetion
liver flow
low in pipes.
onduits, chan-
eli, over wain.
umping
lischarges or
tK traction i,
itlds
of water
lensity
Unit
millimetre
cubic metre
per second
cubic metre per
second
litre per second
cubic metre
per day
cubic metre
per year
litre per person
per day
kilogram per
cubic metre
Symbol
mm
m3/i
m'A
l/s
m3/d
m3/year
I/person
day
kg/m3
Comments
For nwteorologiia!
purposes it may be
convenient to meas-
ure precipitation in
terms of mass/unit
area (kg/m3).
1 mm of rain =
1 kg/m2
Commonly called
the cumec
1 l/s = 86.4 m3/d
The density of
water under stand-
ard conditions is
1 000 kg/m3 or
1 000 gfl or
Ig/ml.
Customary
Equivalents
35.314 cfs
15.85 gpm
1.83X103gpm
0764 gcpd
0.0624 Ib/cu ft
Description
Concentration
BOD loading
Hydraulic load
per unit area;
e.g filtration
rates
Hydraulic load
per unit volume.
e.g., biological
filters, lagoons
Air supply
Pipes
diameter
length
Optical units
1 nrc
lubo
Recommended Units
Unit
metre per
second
millimetre
per second
kilometres
per second
radians per
second
cubic metre
per second
litre per second
pascal second
newton per
square metre
or pascal
kilometre per
square metre
or kilopascal
bar
Kelvin
degree Celsius
joule
kilo joule
wan
kilowatt
joule per second
Symbol
m/s
mm/s
km/s
rad/s
m3/s
l/s
Pa-s
N/m2
Pa
kN/m2
kPa
bar
K
C
J
kJ
W
kW
J/s
Comments
Commonly called
the cumec
Basic Sf unit
The Kelvin and
Celsius degrees
ere identical.
The use of the
Celsius scale is
recommended as
It is the former
centigrade scale.
1 joule -INm
where metres ere
measured along
the line of
action of
force N.
1 watt = 1 J/s
Custoir
Equivali
328fps
0.00328 f|
2.230 mpt
1 5,850 gp
- 2.120 cf
15.85 gpir
0.00672
poundals/'
0.000145
0.145 Ib/s
14.5 b/sq
5F
"-"- — 17
9
2.778 X 1
kwhr-
3.725 X 1
hpJir-O.
ft-lb = 9.4
10-* Btu
2.778 kwJ
Application of Units
Unit
milligram per
litre
kilogram per
cubic metre
per day
cubic metre
per square metre
per day
cubic metre
per cubic metre
per day
cubic metre or
litre of free air
per second
milltmeUe
metre
lumen per
square metre
Symbol
mg/t
kg/m3d
m3/m*d
m3/m3d
m'h
IA
mm
m
lumen/mz
Comments
If this is con-
verted to I
velocity, K
should be ex-
pressed in mm/s
(1 mm/s = 86.4
m'/ro'dey).
Custon
Cquival
Ippm
0.0624 Ib/
day
3.28 cu ft/
0.03937 in.
39.37 in. "
3.28 ft
0.092ft
candle/so. A
-------
1'xhibit
ANNOTATED SUPPLEMENT
as of
September 1975
by
Frank P. Sebastian
Envirotech Corporation
1067
-------
EPA-625/4-75-009
AIR POLLUTION ASPECTS
OF SLUDGE INCINERATION
ENVIRONMENTAL PROTECTION AGENCY* Technology Transfer
June 1975
1068
-------
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Exhibit 4
SLUDGE INCINERATION SYSTEMS FOR
PURIFICATION AND RESOURCE RECOVERY
by
Frank P. Sebastian
Member, Working Party
Senior Vice President
Envirotech Corporation
Menlo Park, California
Working Party for the Prevention of Pollution from
Municipal and Industrial Sources
SLUDGE SYMPOSIUM
Moscow
May 12-27, 1975
under
USSR/USA ENVIRONMENTAL AGREEMENT
107i»
-------
SLUDGE INCINERATION SYSTEMS FOR
PURIFICATION AND RESOURCE RECOVERY
by
Frank P. Sebastian
Introduction
In the treatment of wastes at a sewage treatment plant, following the
various dewatering processes waste solids and water still remain for
disposal. More stringent laws and codes have reduced freedom of choice
in disposing of such waste solids or sludge.
In a study for a midwestern U.S. town, Weller and Condon reported rela-
tive costs for various systems as follows:
Original Annual
System Cost Cost
Dewatering and Incineration of Raw Solids 1.0 1.0
Digestion, Mechanical Dewatering and Land
filling 1.05 1.41
Digestion, Mechanical Dewatering and
Incineration 1.43 1.38
Wet Combustion and Effluent Treatment 1.97 1.54
This paper will review sludge incineration and heat treatment for conven-
tional primary secondary systems, and incineration and reclamation for
advanced physical chemical systems, particularly as regards their environ-
mental impact.
Uses
The multiple hearth furnace is versatile, although originally developed
1075
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in 1889 as a furnace to roast pyrites for the manufacture of sulfuric
acid. The modern multiple hearth system has been adapted to over 120
proven uses, including:
1. Burning (or drying) raw sludge, digested sludge, and sewage
greases;
2. Recalcining lime sludge and waste pond lime;
3. Reclaiming fruit, nut and lumber waste (peach pits, walnut
shells, almond shells, sawdust and bark) for charcoal bri-
quettes, and reclaiming cryolite and aluminum smelting
operations;
4. Regeneration of spent activated granular carbon and diato-
maceous earth;
5. Other uses: mercury, molybdenum sulfide, carbon, magnesium
oxide, uranium, yellow cake, nickel.
The multiple hearth furnace itself is a simple piece of equipment, con-
sisting primarily of a steel shell lined with refractory on the inside.
The refractory can be either castable or in brick form, depending upon
the size of the furnace. The interior is divided by horizontal brick
arches into separate compartments called hearths. Alternate hearths have
holes at the periphery to allow the feed solids to drop onto the hearth
below. The center shaft, driven by a variable speed motor, rotates the
rabble arms situated on each hearth. The rabble teeth on these arms are
placed at an angle such that the material is moved inwards and then out-
wards on alternate hearths. The shaft and rabble arms are cooled by air
introduced at the bottom. This air may be recycled as required by the
thermal process (Exhibit 1).
The sludge is fed through an inlet in the furnace roof by a screw feeder,
or belt and flapgate. The rotating rabble arms and rabble teeth push the
1076
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sludge across the hearth to drop holes where it falls to the next hearth
and continues to the next hearth and the next, until the ash is discharged
at the bottom.
The multiple hearth system has three distinct operating zones: the top
hearths where the feed is dried to approximately 48% moisture; the incin-
eration/deodorization zone where temperatures of 760°-982°C (1400°-1800°F)
are maintained/ and the cooling zone where the hot ash gives up heat to
the incoming combustion air. The warmed air rises to the combustion zone
in counterflow style and the hot combustion gases sweep over the cold
incoming sludge, evaporating the sludge moisture to about 48%, at which
point a phenomenon called "thermal jump" can occur in the beginning of the
combustion zone. This beneficial exchange of energy allows odorfree
exhaust gas and temperatures of 260°-593°C (500°-1100°F). The typical tem-
perature profile across the sludge furnace is as follows:
Approx. Half Nominal Design
Hearth No. Capacity - °C fF_ Capacity - °C fF
1 354 670 426 800
2 748 1380 648 1200
3 848 1560 898 1650
4 787 1450 787 145O
5 648 1200 648 1200
6 163 325 148 300
Thermal oxidation is reaching new high levels of technology and performance
not generally realized even in technical circles. New data recently devel-
oped answer favorably for the first time many questions that have surrounded
the impact on air quality from such thermal processing systems. In addition,
favorable benefits such as energy reclamation and ash utilization from the
1077
-------
burning of sludge have become a reality in these sludge processing units.
Sludge Incineration/Reclamation Benefits
* Meets EPA air standards - particulates
*. Ruled insignificant source of emissions
* Decomposes PCB's (polychlorinated biphenyls)
* Decomposes pesticides - DDT, 2,4,5-T
* Produces ash product - quasi-fertilizer
* Recovers resources - CO-^, lime
* Controls heavy metals
* Energy reclamation - Closed Loop Energy System
The most comprehensive study that has been done to date on sludge incin-
eration was by the EPA Sludge Task Force, the report on which was pub-
lished in August 1972. It included a survey of ten furnaces throughout
the United States, including, for example, installations at Monterey and
South Lake Tahoe, California. The Task Force study also included a
report of the sludge, ash and air emission, and of air pollutants and
toxics.
The Monterey sludge incineration building was converted from an existing
digester to house the incineration unit. It is located on the edge of Monterey
Bay where raw sludge used to be dumped.
The South Lake Tahoe Water Reclamation Plant is one of the most advanced
wastewater treatment plants in the world. The solids handling building
contains a sludge incineration furnace and a lime recalcination furnace.
1078
-------
The EPA Task Force conclusions were :
* Incineration is an acceptable alternative for sludge disposal.
* Air emissions acceptable:
Odors
Particulates
Apparent destruction of pesticides/PCB's
The information presented here is principally an update of several key
points that were included in the EPA Task Force report.
EPA Task Force Abstract
A Task Force was established within the Environmental Protec-
tion Agency to evaluate sludge incineration as an acceptable
alternative to sea disposal. Multiple-hearth and fluidized
bed furnaces, containing scrubbing devices for particulate
removal, were selected for performance evaluation. The siudge,
particulate, stack gas, scrubbing liquid, and ash were sampled,
and analyzed for heavy metals, pesticides and oxides of nitro-
gen and sulfur. The results indicated that incinerators are
capable of achieving low emission concentrations for the com-
mon pollutants. Particulate samples showed a measurable con-
centration of lead. The ash samples normally showed a higher
concentration of the heavy metals when compared with the
sludge samples; however, mercury was one of the exceptions and
was not detectable in the ash sample and assumed as lost to
the stack gases. The pesticides and PCB, present in the
sludge, were not detectable in either the ash or the scrubbing
water, and indicated complete destruction. The study demon-
strated that well designed and operated municipal sewage sludge
incinerators can meet the most stringent existing particulate
emission control regulation.
Since the Task Force published the report on its findings, there have been
new test results pertaining to PCB's, pesticides, lead and mercury. The
new data show that the air quality impact can be even further reduced over
the Task Force data. In addition, the fate of PCB's became the pivotal
1079
-------
issue of the report insofar as fuel conservation was concerned. These
concerns have now been relaxed.
The Task Force report recommended that, to be certain of complete decom-
position of PCB's found in a sludge furnace, exhaust gases should be
raised to 871°C (1600°F) for two seconds.
The Task Force further reported that PCB's were found to range from "not
detected" in mountainous areas to 105 PPM in industrial areas where PCB's
were used in manufacturing processes. The 871°C (1600°F) temperature
requirement, if imposed, would have meant as much as a four-fold increase
in the fuel cost of a typical sludge incinerator at that time.
As soon as a copy of the preliminary Task Force report was received, in
February 1972, Envirotech immediately undertook an independent study and
found virtually complete destruction of PCB's at 593 C (1100 F) in only
one-tenth of a second, and 95% decomposition under normal operations.
This information was presented to the EPA and in November 1974 the draft
EPA Technical Bulletin on Sludge Disposal revised the guidelines as
follows: (1) check to determine if the PCB content in sludge exceeds 25
milligrams per kilogram, and (2) if it does, use a process that assures
95% decomposition. Since the new data showed that this can be achieved
at the normal operating parameters of a multiple hearth furnace, no
extra fuel is required to eliminate the PCB's even when the sludge con-
tains more than 25 milligrams per kilogram.
1080
-------
The tests that led to this new guideline were conducted by injecting PCB's
into the sewage sludge at the San Mateo, California furnace.
* 4500 PPM of Therminal FR-1 was injected into the sludge feed;
* The furnace was operated at normal temperatures with internal
temperatures of
815°C (1500°F) to 926°C (1700°F)
* Four different afterburner temperatures were used to develop
sample decomposition data:
337°C (640°F)
365°C (690°F)
493°C (920°F)
632°C(1170°F)
* The analysis was done by certified independent laboratories.
The results showed what 95% of the PCB's were destroyed at 371°C (700°F)
using 0.1 second exhaust gas detention time. At 593°C (1100°F), 99.9% of
all PCB's were destroyed, also at an exhaust gas detention time of 0.1
second.
What is the significance of PCB in sludge? Perhaps it would be helpful
to review briefly some background information on PCB. PCB's have some
unique properties that have made them very useful in industrial applica-
tions for the last forty years. PCB's were first produced commercially
in the U.S. in 1929. Since then they have been produced by one U.S. manu-
facturer and several manufacturers outside the U.S.
The main properties that distinguish PCB's are: they are inert chemicals;
they are insoluble in water; they are adhesive; they are extremely heat
resistant; and they are toxic to many organisms. Chemically, they are
1D81
-------
very similar to the well known chlorinated hydrocarbons or pesticides.
Due to their remarkable stability, PCB's have found many uses, particularly
in industry.
The major user of PCB's has been the electrical equipment industry,
followed by heat transfer systems, use as hydraulic fluid, and, finally,
use as plasticizers which originally, but no longer, included carbonless
carbon paper, and in paints and glues. In 1966, PCB's were first identi-
fied as being present in some food products and, since, have been found
throughout the environment.
Based on these findings, the sole producer of PCB's in the United States
voluntarily limited production of these chemicals in 1971. The latter
three of these uses have been severely limited and suitable substitutes
have been found for the PCB's. At this time, the U.S. government is recom-
mending the use of PCB's only in electrical equipment, such as transformers
and capacitors, which presently have no suitable substitute for PCB's.
A U.S. government interdepartmental task force on PCB's identified where
PCB's exist in the environment. It was estimated that in North America
the air environment contains 20,000 tons of PCB's; land environment, 250,000
tons; and the water environment, 30,000 tons. These totals represent a
great majority of the PCB's that have been produced in the last forty years.
Worldwide totals for these three sectors of the environment would run much
higher. Significant to this report is that the government pinpointed the
principal means of cycling through the environment for PCB's as being in
wastewater systems.
1082
-------
The cycle consists of waste streams, receiving waters, fish, animals and,
finally, man. PCB's, like their close pesticide relatives, the DDT, DDD,
dieldrin-chlorinated hydrocarbons, tend to concentrate in the higher
levels of the food chain and in the fatty tissues of animals. The cycle
begins with waste streams from industrial manufacturing or accidental
spills into sewers or streams. From there the PCB's enter receiving
waters where aquatic organisms ingest them, and as mentioned above they
concentrate in the top of the food chain. Also, wildlife, which increas-
ingly serve man as an early warning system, take in PCB's and concentrate
them in their bodies when they consume water laced with PCB.
Finally, the chemicals find their way into man. The U.S. government does
not believe that PCB's represent an immediate threat to human health.
However, this tendency to concentrate in the food chain, plus the long
lived characteristics of PCB's make them a long range threat. The U.S.
government has recognized them as such and some New York reports show a
direct correlation in fish with age.
In September 1972 a United States Geological Survey report made headlines
in the newspapers across the U.S. A survey of streams and lakes in 39
states detected PCB's in 17 of the 39 states. In many places where PCB's
would not be expected to exist, such as remote lakes and rivers, scientists
were surprised to find PCB's present.
This omnipresence, coupled with the non-biodegradability, is obviously
the reason the U.S. EPA is concerned about the fate of PCB in sludges.
Fortunately, the current sludge incineration technology has been shown to
1083
-------
offer a safe alternative to eliminate any concern over PCB contamination
in the air or on land from that process.
Air Quality Impact
For comparison with stringent air quality regulations, further tests
were conducted at the same San Mateo installation. The air quality
tests there were also very favorable. Three tests for hydrocarbons
showed 0.7, 2.2 and 0.4 PPM, and three tests for carbonyls showed 3.4,
7.6 and 3.4 PPM - all very low fractions of the 25 PPM allowable for the
Bay Area Air Pollution Control District (BAAPCD). Similar low values
were obtained for particulates - .019, .021 and .017 PPM compared to the
.125 allowable of 0.15 in terms of grains per standard dry cubic foot.
To offer some perspective as to how significant incineration impact is on
air quality, a comparison can be made on a per capita or person versus
per automobile impact on air quality, using a typical U.S. automobile
traveling 12 miles per day. Taking the actual U.S. standards on hydrocar-
bons, hydrocarbon emissions for 1970 U.S. cars were 55.2 grams, in 1975
18.0 grams, and 1977 standards were 4.89 grams - a substantial reduction
(Exhibit 2). On a per capita basis, the air impact from incineration
is .019 grams per day per person. The carbon monoxide comparison is simi-
lar, at 564, 180 and 40.8 grams per day emissions for an automobile, and
only .057 grams per person per day from incineration.
Nitrogen oxide carries a similar story: improvements from 49.2 in 1970 to
37.2 grams in 1975, and 24.0 grams in 1977. The impact per person is 0.29
grains.
1081*
-------
The Tahoe plant, mentioned earlier, was one of the plants studied by the
Task Force. This plant was a conventional activated sludge plant that
has been upgraded by adding lime and carbon tertiary treatment to pro-
duce an ultra high quality effluent water. The effluent water will meet
U.S. "laboratory tests" for drinking water standards. The sparkling pro-
duct is pumped to a new 3.785 million cubic meter, one billion gallon
reservoir, Indian Creek, where it is used for trout fishing, recreation
and crop irrigation.
This advanced facility is frequently visited by both U.S. and foreign
environmental groups and has been inspected by several Soviet delegations
under the USSR/USA Environmental Agreement. It was our honor to host
Dr. Yury Izrael's delegation there in July 1973 and the Working Party for
Prevention of Pollution in October 1974. During these visits we sipped
together "Tahoe champagne" as the reclaimed water is called by the local
plant operators.
Further, environmental impact improvements have been achieved since Tahoe
was built, as the EPA Task Force report mentioned. Two 5.71 meter, 18.75 ft.
6-hearth furnaces were under construction when the BAAPCD reduced its
allowables in 1970. Tests were conducted on the improved Palo Alto fur-
nace design following completion in 1973. The actual emissions were a
small fraction of the reduced allowables for hydrocarbon emission, car-
bonyls, SO {a new requirement) and particulates (Exhibit 3).
About the time that the Palo Alto tests were completed, Livermore, Cali-
fornia, a small community east of San Francisco, was denied a permit to
1065
-------
build its wastewater treatment plant as required under the Clean Water Act.
This was due to the fact that this valley, which is famous in the U.S.
for its white wine, was already exceeding the secondary air quality stand-
ards. Therefore, no more construction could be started, not even to clean
up the wastewater. At the invitation of the municipality and its
consulting engineer, the impact on air quality from the new Palo Alto fur-
nace was presented to the Bay Area Air Pollution Control District Board (Exhibit 4).
A study showed that in the Livermore valley automobiles were the source of
28,000 pounds per day of NOX emissions. If sludge were hauled from a treat-
ment plant by truck, emissions from the truck would be ten pounds per day
into the valley, traveling just to the edge of the valley, and the truck
would still have to be driven some additional distance where it could be
unloaded. Within the valley itself there would be a ten pound NOX impact.
Earlier data indicated that 62 pounds per day of NOX would be emitted from
the sludge incinerator if lime reclamation were included with it, compared
to 50 pounds per day for sludge only. However, based on the Palo Alto
plant performance, it was determined that the NOX impact on the valley
would be about the same whether incinerated or hauled away by truck. Here
again, this does not include the truck emissions outside' the rim of the
valley. Based on these results, the Bay Area Pollution Control District
ruled that sludge incineration was an insignificant source of emission
and no permit was required to proceed to build the waste treatment plant.
A further comparison of air emissions on a per capita basis with the auto-
mobile on a per day -basis shows the NOX emissions, based on the Palo Alto
1086
-------
tests, were .037 grains per day per person, and a 1976 automobile traveling
12 miles per day is estimated to emit .4 grams per mile of NO . Sludge
incineration emissions per capita are about equal to driving a U.S. car
one-tenth of a mile.
The test results from San Mateo and Palo Alto were studied by EPA person-
nel concerned with solid waste and the disposition of residuals.
EPA concerns involved excess DDT which has been banned in the U.S. and
also disposition of the pesticide 2,4,5-T. The Solid Waste Division of
EPA was interested in the possibility of injecting DDT into sludge as a
means of processing DDT through the furnace to remove it from the environ-
ment. The EPA contracted for tests to be performed by Versar, Inc., an
independent laboratory. Following pilot scale tests, full scale tests
were run at the Palo Alto installation. DDT was injected into the sludge
fcxhibit 5) at the rate of 908 grams per hour. The ash at the bottom of the
furnace contained 0.000027 grams/hour. In the airstream with no after-
burner operating there was O.J3044 grams per hour and 3 grams per hour were
contained in the scrubber water which is returned to the headworks. The
overall removal or decomposition efficiency was determined to be 99.669%.
With the afterburner operating there was 0.0036 grams/hour in the ash, 0.0146
grams/hour in the airstream and 0.00039 grams/hour in the scrubber water.
The overall removal efficiency was 99.99%. It was concluded that any DDT that
is normally contained in the sludge is destroyed in the furnace, and that
additional DDT up to 5% that might be added to the sludge would also be
similarly decomposed. Similar tests were conducted for 2,4,5-T with similar
results - 99.989% decomposition (Exhibit 6) •
There has been some expressed concern about the fate of heavy metals that
might be contained in sludge.
1D87
-------
In connection with the fate of mercury in municipal incinerators, the EPA
has recently published results of tests on several sludge incinerators
including Envirotech installations at South Lake Tahoe and Monterey, Cali-
fornia. The results show, contrary to conventional thinking up to now,
that the mercury in the sludge exhaust gases is substantially removed in
the scrubber (Exhibit 7).
At the Lake Tahoe furnace the sludge feed was 28.0 grams/day and 26.805
grams/day or 96% of the mercury was removed from the exhaust gases. At
Monterey, California 62.5 grams/day of mercury was contained in the sludge
feed and 51.68 grams/day or 83% was removed by the scrubber.
The proposed EPA standard for mercury emissions is 3200 grams/day based on
the typical range of 5-15 PPM of mercury found in sludge. No constraint
of sludge incineration is foreseen due to mercury in the sludge (Exhibit 8).
Prior to these tests it was generally assumed that all mercury in the
sludge was vaporized and passed out of the furnace with the gas. Now it
is known through these tests that the mercury vapors will be substantially
removed in the form of gases and contained in the scrubber water which is
returned to the headworks of the plant for further treatment.
A further example of mercury removal is shown by the EPA - Georgia's Company
funded project to recover mercury from chlorine plant wastes at Burlingame,
Washington. Over 99% recovery of mercury is achieved through the incineration
of MHF to process sludge wastes from the chlorine plant.
1088
-------
Lime Reclamation
In these energy and material conscious days, reclamation is all important.
Reclamation in the multiple hearth furnace is a normal operating proced-
ure. For instance, the Lake Tahoe Water Reclamation Plant uses a separate
multiple hearth furnace to recalcine or reclaim lime that is used in the
treatment process. Since this is a manufacturing process - that is, tak-
ing the lime-rich sludge and reclaiming the valuable lime treatment chemi-
cal - it does not fall under the sludge furnace air quality regulations.
A further benefit of reclaiming lime is that there is a unique opportunity
to lower emissions to the atmosphere in the process. When lime is added
to facilitate settling of the solid matter, the alkalinity pH of the
wastewater is raised substantially. In order to reduce the pH, the
exhaust gases from the furnace are highly cleansed in the methods already
described - they are not released to the atmosphere but are reused. To
capture the CO2 that is required by the process, the gases are compressed
and bubbled into the bottom of a recarbonation basin where the COj and
trace components in the gases are transferred to the wastewater. Thus,
the gases are further scrubbed clean. This system has been in operation
at the South Lake Tahoe Water Reclamation Plant since 1968.
Energy Reclamation
A further industry development is that of energy reclamation from sewage
plants. In addition to the reclamation of the fuel value of sewage sludge
to reclaim chemicals on site for reuse, a further step has been taken in
three municipal plants currently under construction involving the use of
1089
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third generation multiple hearth furnace systems which we call Closed loop
(Exhibits ).
Energy Systems/ In these systems a sludge heat treatment step is installed
to break loose the water bound in the biological cells to enable normal
dewatering equipment (vacuum filters or centrifuges) to be used to obtain
up to a 250% increase in the normal solids content of the sludge. This
brings the sludge to a fuel value approximately equal to that of soft
coal. The heat treated sludge is then processed through a similar but
differently designed furnace to convert itself to a sterile but poten-
tially useful ash without the need for auxiliary operating fuels and with
sufficient heat left over to provide process heat and steam at the-treat-
ment plant.
Three sludge handling and disposal systems, designed with a "closed circuit
energy loop" to conserve fuel, are currently under construction in the U.S.
for Granite City, Illinois; Chesapeake-Elizabeth, Virginia; and the Western
Branch Plant at Prince Georges, Maryland.
Granite City, Illinois
At Granite City the existing wastewater facility is currently being upgraded
with activated sludge treatment to handle the 23 MGD flow and to treat
sludge in a "recuperative" BSP system. The influent consists primarily of
domestic waste with a small industrial component.
This system includes:
* Two 6000 GPH BSP Heat Treatment units to thermally condition
hydrous sludges using waste heat recovered from the furnace.
* One 18'9" fi x 7 hearth furnace designed to reduce 11,000 Ib/hr
of cake to 1000 Ib/hr inert ash without use of support fuel.
* One heat recovery boiler to convert the furnace's 16.9 million
BTU/hr of waste' heat to 8,255 Ib/hr steam for thermal condi-
tioning of the raw sludge.
1030
-------
* (The Eimco/BSP system also includes an 18 GPM BSP scum Concentrator
to segregate grease and fibrous trash and to put it into the fur-
nace as fuel at a controlled rate, and an Arco Impingement scrubber
to control emissions.)
The $10 million expansion at Granite City will also include two Eimco 80"
0 x 18' primary clarifiers, two Eimco 70' # gravity sludge thickeners;
and an Environmental Operating Services contract for a startup and train-
ing assistance program.
Chesapeake-Elizabeth, Virginia
The Chesapeake-Elizabeth waste treatment facility in Virginia, one of many
being executed for the Hampton Roads Sanitation District, includes:
* Two 70' 0 x 10' Eimco Sludge Thickeners.
* One 9300 GPH BSP Heat Treatment unit.
* Two 18'9" & x 7 hearth BSP furnace systems and an Environmental
Operating Services startup and training assistance program.
* Two heat recovery boilers to convert 3,319,000 BTU/hr. of waste
heat into 6200 Ib/hr of steam for the BSP Heat Treatment Process.
Western Branch, Maryland
The Western Branch facility at Prince Georges County, Maryland is the lat-
est of the three new "Closed Energy Loop" projects. It consists of upgrad-
ing an existing 15 MGD plant to reduce the sludge volume containing 51,700
pounds of dry solids per day over 99% in a virtually "fuel-less" system.
The plant primarily processes municipal waste with a small industrial com-
ponent. It includes two 6000 GPH BSP Heat Treatment systems and two 14'3"
0 x 7 hearth BSP furnaces. The 5500 Ib/hr waste heat recovered from the
autogenous combustion is 25% more than the 4666 Ib/hr necessary to power
the heat treatment system.
1031
-------
The economics of the CLES are based on the fact that the combustion in
the flowsheet containing the closed loop concept is self-sustaining. The
excess heat from the combustion is sufficient to run the heat treatment
system's heat treatment requirements. Therefore, the fuel required in
CLES is essentially zero (Exhibit 9).
Regarding the actual cost comparison between the Closed Loop Energy System
and the conventional system (Exhibit 10):
1. Costs include both operating and amortized capital costs of
installed heat treatment and multiple hearth furnace systems.
2. All costs have been reduced to "dollars per ton" of dry solids,
and include all the actual solids generated by a complete pri-
mary secondary treatment flowsheet.
3. Annual costs are computed by multiplying the sludge generated
(tons/year) by the cost (S/ton).
The following conclusions are apparent:
1. Despite the fact that a slightly greater quantity of sludge is
generated using the Closed Loop Energy System, savings are con-
sistently realized regardless of plant flow;
2. Annual cost savings vary depending on the economies of scale
realized. (A particular piece of equipment may be employed at a
higher rate of utilization which would affect the savings.) For
example, this phenomenon has occurred at the 75 MGD plant flow.
Conventional system costs at 75 MGD appear to be somewhat out of
line, probably due to lower equipment utilization rates.
fish as Potential Fertilizer
Other reclamation potential for sludge incineration - in addition to energy
and CO2 recovery - exists in the potential fertilizer value of the ash.
In Japan, more than 50,000 tons of ash from multiple hearth furnaces have
been sold on an experimental basis by cities to fertilizer companies for
1032
-------
sale in 20 kilo bags. The fertilizer value is
0.1% nitrogen
6.0% phosphate
1.0% potash
To indicate the high potential fertilizer value in ash, a comparison can
be made with typical values of nutrient found in wet sludges and used in
typical sludge to land projects such as at Denver, Colorado.
Using the value of $0.48 per kilogram ($440 per ton) for nitrogen, $0.88
per kilogram ($800 per ton) for phosphate, and $0.07 per kilogram ($6.00
per ton) for potash, the wet sludge at Denver has been valued at $0.013
per kilogram and $12.22 per ton. By comparison, using the same values,
and due to the fact that the ash is more concentrated, the ash from the
sludge furnace at Palo Alto - a typical secondary sludge - would have a
Value of $0.053 per kilogram and $48.50 per ton, four times as much as
wet sludge.
The ash from an advanced waste treatment facility such as Tahoe, of course,
removes a higher percentage of phosphate. Principally, due to the higher
phosphate content of the ash, it has a potential value of '$0.088/kilogram
and $80.50 per ton.
Costs
Before closing, a comment about costs based on U.S. experience might be
useful.
At the Tahoe Water Reclamation Plant, published figures show an operating
cost of $0.154 per kilogram ($13.98 per ton) of dry solids dewatered.
1033
-------
Total operating and capital cost is SO.053 per kilogram ($47.92 per ton)
for the sludge incineration process. This amounts to less than 5% of
the total cost for complete treatment, which is about $0.105 per cubic
meter (40C/1000 gallons) for the 28,400 cubic meter (7.5 MGD) capacity.
Large plant flows would reflect economics of scale and lower costs by as
much as one-half.
The Environmental Engineers' Handbook, published in 1974, reports multiple
hearth incineration cost for cities of one million population of 14
-------
In summary, the new sludge oxidation technology offers the following
advantages:
* Meets EPA air standards - particulates
* Ruled insignificant source of emissions
* Decomposes PCB's (polychlorinated biphenyls)
* Decomposes pesticides - DDT, 2,4,5-T
* Produces ash product - quasi-fertilizer
* Recovers resources - CC>2, lime
* Controls heavy metals
* Energy reclamation - Closed Loop Energy System
As the USSR and the US move to higher quality levels in both the air and
water sectors, the overall environmental impact of technology must be
considered. In the allocation of environmental resources in urban com-
munities, advanced thermal processing technology deserves to be fully
considered for its resource recovery and purification benefits, as well
as for its "disposal" aspects.
1035
-------
REFERENCES
"Advanced Waste Water Treatment as Practiced at South Tahoe," EPA, August
1971, No. 17010ELQ08/71
"Advances in Incineration and Thermal Processes," Frank P. Sebastian,
Short Course: The Theory and Design of Advanced Waste Treatment
Processes, University of California, Berkeley, September 30-October
1, 1971
"Accepted Methods for the Utilization or Disposal of Sludges," EPA No.
430/9-75-XXX, Technical Bulletin, November 1974
The Environmental Engineers' Handbook, Chilton Book Company, Philadelphia,
Pa., 1974
"PCB's Spotted in Nation's Water Resources", U.S. Geological Survey,
September 1972
"Problems in the Design of Sludge Incinerating Systems," Proceedings, 16th
Annual Conference of Sanitary Engineering, University of Kansas, Bulletin
of'Engineering and Architecture, No. 56, January 1966
"A Study of Pesticide Disposal in a Sewage Sludge Incinerator,", Frank C.
Whitmore and Robert L. Durfee, Versar Incorporated, Contract No. 63-01-
1587, prepared for EPA, Tenth Report and Final Report, 1974
"Sewage Sludge Incineration,", EPA Task Force, No. EPA-R2-72-040, August
1972, NTIS No. PB-211 323
1036
-------
Exhibit 1
BSP
ENVIROTECH
SLUDGE
OXIDATION SYSTEM
EXHAUST
STACK
I.D. FAN
SCRUBBER
1037
-------
Exhibit 2
TOTAL OXIDATION vs. AUTO
50
1975
HI .*'. IJA
—J4.
9
0 10
1038
-------
Exhibit 3
PALO ALTO EMISSIONS
300 PPM
25 PPM
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Exhibit 6
Volume 5
INDUSTRIAL
PROCESS DESIGN
FOR
POLLUTION CONTROL
Proceedings of the Workshop
organized and held under the
auspices of the
AIChE Environmental Division
Midland, Michigan
November 1-3, 1972
an lllBflf workshop published by
AMERICAN INSTITUTE OF CHEMICAL ENGINEERS
345 East 47 Street New York, N. Y. 1OO17
Copyright in U.S.A. 1974
1108
-------
INCINERATORS AND INCINERATION
SYSTEMS DESIGNED FOR USE IN
INDUSTRIAL PROCESS PLANT:
..atest Developments on Polychlorinated
Biphenyls Decomposition in BSP
Multiple Hearth Furnaces
F.P. Sebastian, G.F. Kroneberger,
L.A. Lombana, and J.M. Napoleon
BSP Division
Envirotech Systems Inc.
San Francisco, California
The first part of this article deals with the
characterization of polychlorinated biphenyls in
order to realize the concern about PCBs and their
impact on the environment. The second part of the
article discusses the decomposition by incineration of
FCB, the impact of incineration of PCBs and the
latest developments in PCB processing.
The following data and informatioti was developed in
late 1972 as part of an on-going R & D program at Enviro-
tech Systems Inc. as well as in response to an EPA study
request. In this study, we have evaluated the action of
Polychlorinated biphenyls, both in the furnace itself and
in afterburning chambers.
PCB Properties:
Heat .resistant
Toxic
Stable
Inert
Insoluble
Adhesive
Polychlorinated biphenyls have been used in industrial
processes because of their unique properties. Figures 1 to 3.
Unfortunately, some of these same properties promulgate
the toxic property which has caused the present concerns
on environmental impact. The toxicity effects are similar to
other chlorinated hydrocarbons such as used in pesticides.
The more highly chlorinated PCBs are more persistent and
the less chlorinated ones are more toxic. In some cases,
small traces of PCB have increased the toxicity of DDT by
100%.
PCBuses:
Electrical systems Heat transfer systems
Hydraulic fluid Plasticizers
PCBs were first produced commercially in the United
States, in 1929. In 1966, PCBs were identified in some food
products, and since that time have been found throughout
the environment. Because of the findings, the sole U.S.
producer has voluntarily limited production, and PCBs are
no longer used in carbonless (NCR) paper, paints, and glues.
PCB use has been drastically reduced in all applications
except electrical equipment, this is the only use currently
recommended by the government and no suitable substitute
has been found.
PCB in environment:
Air 20,000 tons
Land 250,000 tons
Water 30,000 tons
The PCB distribution shown above was determined by a
recent interagency task force. The totals represent a great
majority of the PCBs that have been produced in the U.S.
in the last 40 years. Worldwide totals would run much
higher. These figures underline the resistance, stability, and
inertness of this configuration. These totals also indicate
that even with an uneconomical discontinuation of all use,
Composition
Maximum Bulk
Tempeiature
HatinE CF )
Recommended the
BanieCF)
Pour Point (-F }
Pounds/Cation
(75-F)
Flash Point (*F.)
Fire Pant (-F.)
»IT<*F>
total kini.(T)
MUecular Weiihl
ElpansMD
Coemciccilct/cc/f.
Tnermlnel FR-I
Polrchlorinatcd
600'F.
45-575'F.
2
I1-5S
350
None to Boilinf
1206-F
620-00
m
000031
Thertmiwl K
Modified Teiphenyl
«0f.
45-U5-F.
—15
135
355
374-392
705
(44-745
i«
U0039
Thermmot M
Alkylated Aromatic
(00-F.
20-S75T.
-40
M
355
410
(70
(35-734
340
OJ0047
Figure 1. Typical physical, chemical end thermal properties.
1109
-------
Tcmpentun
•f
so
100
ISO
200
2SO
300
350
400
450
SCO
550
600
(SO
1111
•c
10
33
66
93
121
119
177
204
232
260
288
316
343
311
Dtnilty
lb/,,1
1163
11 46
1122
1099
1076
10 S3
1030
1007
9.13
960
937
914
891
to
Kg/in1
13996
13727
13437
13167
12891
12613
1233 5
12051
117! 0
11502
11275
1094.7
10669
SpeeUe Hell
BTU/H
•F
0272
0282
0291
03047
031S1
0.3255
03359
03464
0356!
03672
03776
03880
03985
Kcjl/Kg
•C
0272
0212
0291
03047
03151
03255
03359
03464
0.3568
03672
03776
03880
03985
Thcrmil
Conductivity
BTU/II
hr T
006098
0.06060
006021
0 05976
0 05927
005875
0 05819
005760
0.05697
005630
0055GO
005487
005409
10393 | 04089 | 04089 1 005329
Ktil/m
hr 'C
00907
00902
00896
00889
00882
00874
00866
00857
00848
00838
00827
00817
00805
00793
yiscuily
Cl
308
232
66
34
2.3
14
10
08
06
05
04
04
03
03
Cl
220
169
49
26
18
11
0.8
07
OS
04
04
03
04
03
V.P.T
Pressure
mmHi
Ibiolutl
_
—
—
_
_
10
27
65
143
291
550
USosia
31 9psn
Kg cm'
_
_
_
_
„
„
00136
00367
00884
0.194S
039S3
07480
11218
22429
ftftn 2. TlwrmiMl FR-1 variation of proptrtm with
there will hive to be some meini
persistence of this type of material
Cydt through tnvironm«nt
of decreasing the
Receiving Waters
Aquatic Organisms
Fiih
Animals
Although PCBi are not an immediate threat to human
health, the government is concerned about the long range
threat because of the tendencies forPCBs to concentrate in
die food chain Like then pesticide relatives, DDT, ODD,
dieldnan-chlonnated hydrocarbons tend to concentrate m
the fatty tissues at the various food chain levels In
addition, there have been cases reported were external
contamination has taken place
Water survey
Scientist! were surprised to find PCBi in many places
i.
Figure 3. Tnwminol FR-1 physical propMtitt.
where PCBi would not be expected to exist, such ai remote
lakes and nvers tn a survey of streams and lakes m 39
ttttes. PCBi were found in almost half of them
Recognizing the extent of this problem, the EPA
cxUbluhmed a task force to investigate the requirements
for FCB destruction The following pages summarize the
findings of that task force and also incorporate recent data
developed at Envtrotech Systems Inc 's Brisbane, California
facility.
There are about 210 possible PCB compounds About 50
of these are produced commercially and usually exist as
mixtures. Gas chromatography is used for total analysis,
and it B difficult to differentiate between the various
iiomers. Some generalizations are listed below, but the
effects are far from scientific at this point
The lower chlorinated compounds are more toxic
Dibenzo-furans are sometimes contained in PCBs and they
are suspected of being a major contributor to the toxic
effects
Concentrations in fish-
Common 001 to Ippm
Abo found in excess of the 5 ppm US. FDA Seizure
Limit.
In many areas, PCB residues tn fish have been found in
excess of DDT
e fish (several weeks exposure)
20 to SO ppb
8 ppb
Shrimp 1 ppb
Concentration* in Birds:
Concentrations of 300 to 1000 ppm have been found
in Cormorants and Ospreys
Concentration* In human*.
200 out of 600 samples of human adipose tissue con-
Lethal do«s for
Blue gills and c
Trout
1110
-------
tafoed at least 1 ppm 100 ppm has been found in the
fttty tissues in one cue
In the wane cue* which occurred to 1000 person! in
Japan to 1968, nee oil contaminated with PCB resulted in
Immediate external symptoms (darkened stans, eye
discharges, severe acne) on patients that consume 0 5 to 2g-
and more No treatments ate known and the conditions
edited thiee yean later in many cases (*Note There are
wN too many known clinical eases that have been related to
PCBt. The wont known incidence » suspected to have been
aggravated by impurities in materials of foreign
tnufacture.)
The intemil effects ue not known, but several infants
were bom with the symptoms from apparently unaffected
roothen
Tmtment of PCB In incinerator off-^t
Being imduble, much of the water borne PCS is
concentrated in sludge and sediment layers The February,
1972, EPA sludge incineration task force published a
preliminary report NT1S No PB-211-323 in August, 1972
Aa a part of the study, sludges from ten communities
around the US were analyzed in great detail, along with
Ac byproducts of incineration PCBs were found to be the
nott thermally resistant of the chlorinated hydrocarbons
The report presumed that PCBs were destroyed mice none
was reported in off-gases, ash, or scrubber water. However,
It observed that "direct experimental evidence .. .should
bt obtained." In the meantime, the report used
extrapolated data from liquid waste incinerator* ind rotary
kflm and determined that an off-gas treatment of 1600°F
for two sec was the best data at that time Subsequently,
the BSP tests have shown that a Multiple Hearth Furnace
can use considerably less retention time and temperature,
I100°F for 0.1 sec but the lem showed that there can also
be significant processing variations caused by the type of
•lenal in the admix
MHF Wtt procedure
The highest PCB concentration found to-date in
j sludge has been 100 ppm. In order to fully test
MOWtR «" *SM SUJfMT
Figure 6. BSP inctrwration system.
Figure 6. Effect of outlet temperature on fuel economy.
1000 TO 1100
KM TO 900
Figure 7 Ten results on porychlonnated biphanyU.
the referenced equipment and procea, the test sludge was
bolstered to 45 tunes this concentration with Themuno!
FR-1, type PCB
Sewage sludge * 4500 ppm FR-1
Normal 1SOO/1700°F + 4 afterburner tempera turn
Independent analysis
The test equipment, Figure 4, is one of the most
efficient types of sludge incinerators in existence and
became of this, sludges with a total heal content as low as
2800 Blu/wet Ib can be incinerated, m a self-sustaining
manner, with normal outlet temperatures Sludges with
more than 75% water or higher outlet temperatures can
1111
-------
10*
5 10*
120
110
-.100
SCRUBBER EXHNJST
- COCENTRATIONS
600 aoo 1000 1200
AFTERBURNER EXHAUST TEMPERATURE-'F
900 11OO 1300 1500
AFTERBURNER EXHAUST TEMPERATURE-'F
OESTRUCTION CF
PCS
600 800 1000 1200
AFTERBURNER EXHAUST TEHPERATURE-'F
Fffun &
1100 1300 1500
AFTERBURNER EXHAUST TEMPERATURE-'F
of ndiM« ^i pnHtactf.
1112
-------
require supplementary fuel It was found thai even with the
heavy dose of PCB the exhaust gases from the Multiple
Heuth Furnace Figure 5, tcquiredonly 1IOO°F and 0 I sec
Thto "combustion equivalent" for the BSP Mulliplc Hearth
Furnace is very conservative since any (races were 1/10 of
"ovemment suggested residuals
An item of further study will be the characterization of
the combined effects of PCBs and the entraining material
Advantages of low-temperature- MHF operationi
Figure 6 shows the effect of outlet temperature on fuel
economy With feed material characteristics that require
fuel at low temperatures, proportionately more fuel is
required for higher outlet temperatures Only multiple
chambered countcrflow units are able to obtain proper
combustion with low outlet temperatures Depending on
the type of application, a MHF can have outlet
temperatures less than 1000°F while maintaining
combustion zone temperatures over I600°F Advantages of
low-temperature operation include fuel savings,
economical sub process, complete destruction, and reduced
environmental impact
Normal multiple hearth operation has a weekly per
capita cost of 1V4 The daily emissions from this process
ire lest than that produced by operating a single
automobile for 5 mm , the furnace emissions being figured
on a per capita basis, the multiple zones greatly assist the
complete bum-out of trace quantities of PCBs because tests
hive shown that they can survive short periods of red hot
temperatures when deep within the interstices of inert
uncles
In the test results of Figure 7, no PCB was found in the
furnace ash The upper bar represents low temperature
afterburner operation and shows that the PCB is
satisfactorily destroyed, even at the lower retention times
and temperatures
Hie lower bar shows normal furnace operation without
aeparate afterburning In these runs, 94% of the PCB was
destroyed which indicate that the reduced afterburning
requirements of the furnace is due to the fact that most of
the PCB is destroyed within the hearth chambers due to ihe
multiple processing zones Subsequent tests. Figures 8 to 12,
found in scrubber influent water than in the exhaust gases
from the multiple hearth furnace If desired, activated
carbon systems can be used for removing PCB from water
ttreami The adsorbed PCBs can be destroyed during the
thermal reactivation of the carbon in multiple hearth
Increasingly, sludge incineration has been recognized as
the safest and most efficient method for ultimate sludge
disposal. In 197], the Council on Environmental Quality
recommended a policy of ending pollution dumping in the
United States. In the summer of 1972, California instituted
i plan which would outlaw ocean dumping by 1977 A
cent report prepared for the United Nations by
.v-presentaSves from Western Germany, identified sludge
Incineration as the disposal method with the brightest
future. In Japan, secondary benefits of incineration are
achieved by taking phosphate laden ash from the furnaces
Figure 10 Laboratory furnace test at 690°F
Figure 11. Laboratory fui
Ffgura 12. Laboratory funwce tt»t at 1170°F.
1113
-------
Ffeun 13. Simplified flowthMt of South Tihoc Public
Utility Dittrict Water Reclamation Plant This it • typrert
•dranced wait* treatment plant UHOJ phynMl/chemwal/
and selling it as a quasi-fertilizer containing up to 6%
phosphates The ash from BSP furnaces at the South Lake
Tahoe water reclamation plant, Figure 13, has been found
to contain twice that amount, 12%.
Data from the recently completed tests and experiment)
show that the ESI incineration system destroys PCB to the
decree desired by the EPA The tests also indicated that this
was accomplished at temperatures leu than 1100°F and
lew than 0 2 sec, so the suggested combustion equivalent
(•'Msec and I200°F is conservative
> ilh an afterburner temperature of 1200°F and a
retention tune of 0.5 sec , a smaller afterburner can be
used
1, With the lower temperature of 1200°F, a substantial
laving* in fuel can be realized
3. The lower temperature of 1200°F also reduces the NOX
concentration which accompanies rugh temperatures
The concern expressed by many agencies about PCB
entering the eco-syslem is a very real one Bui as far as
incineration of waste sludges are concerned. PCB removal
by proper incineration processes should not pose a
problem The PCB concentration levels now found in
municipal sludges are well below those used in the tests
Specific industrial sludges will have to be evaluated on 1
cue by cue buis
Bibliographv
1 Hammond, A1 , "EPA PCB Task Force Report."
Science, 175 (January 1972)
2. "PCB test report," Enwrotech Systems Inc (September,
1972)
3. "PCB Report, Enmolech Systems [nc (October, 1972)
4. Thermmol Conversion Bulletin SP/TC-1, Monsanto Co
5 Thermal Systems Bulletin 711, Envuotech Systems Inc
6. "Slack Gas Sampling and Analyses Report," Ultra Chem
Corp
-------
« Sot according to the test data of the EPA Background Information on National Emission
Standards for Hazardous Air Pollutants - Proposed Amendments to Standards for Asbestos
and Mercury dated October, 1974 EPa-4S-/2-74-009a. South Lake Tahoo and Monterey Water
Treatment plants have shown a scrubber efficiency of between 83% and 96* mercury rcmova]
See also the Federal Register, n|Gf*USfilON Octobcr 25- 19?4. Volume 29, 1*208,Pt
JUJCY- Nancy laboratories Would you discuss lead.
mercury, zinc and other vaporized metals in the gaseous
KRONEBERGER We do have, as part of the larger study,
many pages on the trace metal quantities both m the ash
and in the off-gases The presentation here, of course,
concentrated on the mam subject which is PCB's With
respect to metals and more particularly to heavy metals,
you do realize that the mam original use of the Multiple
Hearth Furnace was primarily for metallurgical processing
In these applications, ores and metal compounds are
converted for beneficial processing Because of the many
variations possible in temperature, atmosphere, and
retention time available in this type furnace, it has been
used for oxKluing compounds, reducing compounds and
volatilizing compounds and elemental constituents We can
t*V that through its use, we are able to control the form of
various compounds including metallic compounds to t
greater degree than in any other furnace In the case of
tract metal constituents in sludges, we would have to be
appraised of the most desirable forms of these constituents
to determine the best method of processing them for least
effect on the environment If any specific agent cannot be
detoxified by the Multiple Hearth Furnace, it would be best
to control that particular agent at the source
NANCY. There is no question that at these temperatures all
these metals are going m the atmosphere Now the question
b only that nobody is paying attention to the harmful after
-fftcts
1ONEBERGER Some of the metals are and some are
not As a matter of fact, most of the metals would be
discharged in the ash from the furnace not to the
atmosphere A few of the metals, like mercury for instance
would be volatilized, whether they would be captured in
the off gas system would depend on the specific design of
thai system Some plants processing mercury ores can be
nude to comply with the mercury emission codes with
stringent off gas equipment In the case of trace mercury
constituents in a sludge operation, I would say there is no
question but that we can emit a discharge that complies
COMMENT At the 1970 National Incinerator Conference
incinerator in Connecticut EPA went through an
exhaustive series of tests for metals coming out of the
sludge burning incinerators up there That data showed that
there are • lot of heavy metals as you indicate coming out
If anyone is interested m these results he can refer to the
1970 Proceedings of the National Incinerator Conference
the inorganic solids discharge as ash from the bottom of the
captured in the scrubber A typical mass balance would be
ax listed below We, of course, do not make any claims to
be able to make the inorganics disappear but we can
capture them in the most desirable fashion
Typical Balance: Basis 100 Ib of wet feed
VKajjf Combustible Ash
.aste sludge
(furnace feed) 75 20 50
So we have 100 Ib of wet putrescible sludge converted to 5
Ib of predominantly inert ash This ash typically is sand
and clays and can contain traces of various metals
As an example, taking one of the reports from NTIS
(National Technical Information Service) Pub PB211 323
out of 1 g of ash, there were 19 metals identified and
detected {other than silicon) These totaled 446 mg Of this
total, 400 mg are not only non toxic but are known
nutrients for human consumption I will let others
constituents, but I personally question "toxic lists' that
include trace quantities of copper, chrome and nickel for
instance
NANKEE-Dow Chemical In connection with this
particular PCB task force, the assumption or the
implication that we were not concerned with metals at the
time this was done is not accurate The ash metal content
was of considerable importance m that task force and 1
think those results were also published Likewise, the
overhead loss of the vaporized metals was once under great
concern in another part of EPA primarily m the air
programs Again, I don't have figures on this but I have seen
some material balances that were based on speculations that
there is in fact large postulated metal burning and I am sure
your conference data would support that We're also
concerned with the metals m the ash because it frequently
it used in landfill or put out on land as a soil aid or
whatever you want to call it, and metal in there is also of
extreme concern to us In fact, there's a couple proiects
turned down, just plain old sewaqe sludge not concentrated
by incineration, bul just the sludge itself was possessing too
much metal to be disposed of safely on the land from an
agricultural or business point of view Thus I think these are
of concern to EPA It would be a mistake to say that they
were not I think, however, the state of the art needs to be
clarified
KRONEBERGER Yes and for agricultural purposes
especially, there would be a great concern on the leachable
from a human toxicity point of view as it is a plant life
aspect
QUESTION Your PCBs contain chlorine Where did you
stack gases?
KRONEBERGER We found that there were two different
cases in the tests we made We found that if the PCB s were
from the sludge itself and highly concentrated (for
example, when we added the 4600 pom) that the trace
quantities that came to the scrubber did carry through
the quantity well below limits
It appeared, though, that when the PCB was in the
scrubber water (which we found out by accident) that a lot
of that material seemed lo adhere to the particles that
washed out and collected in the scrubber These are two
contrary types of effect and they would not necessarily
hold true in all cases You can see that in either case any
residuals were far below maximum limns Carbon
adsorption would be the best treatment foi trace PCBs in
water si
is HCI7
Bottom discharge
Fly ash
46
05
QUESTION. It this coming out as chlorine
KRONEBERGER In these cases, where we are saying we
had a 99 9% reduction m PCB's. (99% being acceptable) we
are saying we have 0 1% left The traces remaining were still
as chlorinated hydrocarbons The 99 9% that n destroyed
1115
-------
txnti as oxtdized constituent*
-------
Exhibit 7
PolychBorinated biphenyls in treatment
plant effluents
DOUGLAS J. DUDE, OILMAN D. VEITH, AND G. FRED LEE
As METHODS of detection for chlorinated
hydrocarbon pesticides have im-
proved, polychlorinated biphenyls (rcs's),
which are mixtures of chlorinated biphenyl
compounds that have various percentages
of chlorination, have been found in the
environment. Interest in PCB'S has in-
creased because some of the physiological
effects of the PCD isomers were thought
to be similar to those of the chlorinated
pesticides.
In Wisconsin, Veith * found PCB'S in
samples of the Milwaukee River near the
city of Milwaukee. The concentrations of
these PCB'S (identified as Aroclor 1260)
ranged from 0.02 to 0.25 ^g/1. The PCD'S
were also found in selected wastewater
treatment plant effluents along the Mil-
waukee River at concentrations of equiva-
lent Aroclor 1254 from 0.12 to 0.25 ^g/1.1
This study of wastewater treatment plant
efflents was conducted in order to deter-
mine the degree of contamination in other
wastewaters in southeastern Wisconsin.
STUDY AREA .
Samples were collected at municipal
treatment plants in 11 southeastern Wis-
consin cities (Figure ]). Factors used to
select these cities were population (1,500
to 100,000), volume of waste flow [140,000
gal/day to 13 mgd (530 to 49,205 cu m/
day)], type of treatment, number and
types of industries present, and type of re-
ceiving water. The characteristics of each
municipality investigated are presented in
Table I.
METHODS
Sampling. Glass containers were used
throughout the study to minimize the pos-
sibility of sample contamination.
906 Journal WPCF
The samples were collected by immers-
ing 2.5-1 bottles in the waste stream at its
entrance to the treatment plant, in the
primary settling tank, in the trickling filter
effluent, and in the final effluent of the
treatment plant. The samples were con-
veyed to the State Laboratory of Hygiene,
Madison, Wis., and extracted within 24 hr.
• Extraction. The samples were batch
extracted with redistilled hexane in separa-
tory funnels. The samples were not
filtered because they contained small
amounts of solids. Hexane (100 ml) and
the sample (800 ml) were placed in the
funnel. After vigorous agitation for 1
min, the sample was passed to another
funnel that also contained hexane (100
ml) and was again agitated for 1 min.
The water portion was then discarded.
This procedure was followed until 2,400
ml of the sample had been extracted.
The extracts were combined and con-
centrated to 10 ml for cleanup.
Cleanup. The sample cleanup was done
by means of liquid-solid chromatography
of fiorisil.2"' The florisil column used was
a 0.5-in. (1.27:cm) OD glass column with a
200-ml vessel on the top. The column was
fitted with a fritted glass and Teflon stop-
cock at the bottom. The column was
filled with 0,5 in. (1.27 cm) of anhydrous
sodium sulfate (Na2SO4) and 19 g of
florisil that had been activated at 105°C.
The column was then covered with another
0.5 in. (1.27 cm) of anhydrous Na2SO< to
prevent dcactivation from water in the
sample extract.* The columns were pre-
wetted with hexane, and the extracts
(10 ml) were placed on the column and
eluted with hexane ether mixture (200
mg, 94.6 percent) at 3 to 5 ml/min.' This
procedure was designed to remove fats,
waxes, oils, and pigments from the eluate.
1117
-------
roi REMOVAL
In order to separate tlie PCB'S from other
pesticides, the cluatc was concentrated to
2 ml and passed through a second florisil
column. This column consisted of florisil
in a 9-mm ID glass column with 65 ml of
hexane as the eluate.1 The extracts were
then concentrated to appropriate volumes
for analysis of the samples on the gas-
liquid chromatograph.
Instrumentation. Analyses of the cleaned
extracts to determine the presence of PCB'S
were made by means of gas-liquid chro-
matography (CLC) with an electron-cap-
ture detector. Gas chromatographic anal-
yses were conducted on a gas chromato-
graph * equipped with a concentric tube,
electron-capture detector ("°Sr). The
columns used were 6 ft by 0.25 in. (18.3 m
by 0.635 cm) glass coils packed with OV-
101/QM (2:2 percent) and OV-101/DC-
200 (2:3 percent) coated on Gas Chrom
Q (80/100 mesh). The carrier gas (puri-
fied nitrogen) was maintained at a flow
rate of 28 ml/min; and the injector,
column, and detector temperatures were
210°, 200°, and 270°C, respectively.
From the gas chromatograms, prelimi-
nary identification of the pen's was made
PORT WASHINGTON
PORTAGE-
BEAVER DAM-5
FORT ATKINSON^
BURLINGTON
LAKE GENEVA
WALWORTH
• Barber Coleman 5460
Coleman Co., Rockford, 111.
Pestalyzer, Barber-
FIGURE 1.—Location of sampling sites in
southeastern Wisconsin.
by comparing chromatograms of standard
Aroclors with the chromatograms of the
samples to determine which Aroclor the
sample most resembled. The determina-
tion of the concentration present was made
by measuring the height of the most promi-
nent peaks in each of the Aroclor standards
TABLE I.—Characteristics of Municipalities Investigated in this Study
Municipality
Beaver Darn
Beloit
Burlington
Cedarburg
Fort Atkinson
Grafton
Lake Geneva
Port Washington
Portage
Racine
Walworth
Population
15.000
35,000
6,000
5,000
8,000
4,000
5,000
8,500
8,000
100,000
1,500
Domins"* Tvoes of Industries
Paint, glass, foundry, metal fabricators
Printing, tool and die, chemical formulators, heavy
equipment
Cement, metal work, abrasives, paint, fiberglass,
electrical equipment
Casting, plastics, tool and die, printing, paint
Tool and die, printing, electrical equipment, paint
Steel products, welding and cutting, casting, print-
ing, plastics, electrical equipment
Plastics, electric fixtures, rubber products, tool and'
die
Foundries, chemicals, clothes manufacturing
Concrete products, plastics, hosiery, reproducing
paper
Die and molding, precision stamping, casting,
foundry, printing, electrical products, chemical
treatment and formulators
None
Flow
(mzd)
0.25
5
1.5
1
1.3
0.8
0.7
1
0.7
11
0.14
Type of
Treatment*
TF, C
AS, C
AS, C
TF, C
AS, C
AS, C
TF, C
Pr.C
TF, C
AS, C
TF
• TF = trickling filter; C = chlorination; D
Note: Mgd X 3,785 = cu m/djy.
: digestors; AS = activated sludge; Pr = primary.
-Vol. 46, No. 5, May 1974 9G7
1118
-------
DUBE ET AL.
TABLE II.—Reproducibility of PCB Analysis
Sample*
Raw wastewater
Sample 1
Sample 2
Sample 3
Final effluent
Sample 1
Sample 2
Sample 3
Volume
Extracted
(ml)
3,000
3,000
3,000
2.500
2,400
2,400
PCB Concen-
tration!
(ftm
1.5
1.4
1.4
0.9
1.1
1.0
* All samples were taken at the Ccdarburg, Wis.,
treatment plant on Oct. 6, 1971, at 11:30 hours.
t The chromatograms of all samples collected most
closely resembled the chromatogram of Aroclor 1254.
and comparing these to the height of the
most prominent peaks in the samples. In
this study, these peaks (PCB components
numbers 4 and 7) lay on either side of the
first doublet peak (isomer components
numbers 5 and 6 in Figure 2). The diffi-
culty of this method is apparent when a
sample contains a mixture of two or more
Aroclors and more detailed study is needed.
. Recoveries of the samples used to test
the precision of the Aroclor 1254 analyses
are summarized in Table H. The analyses
of the raw wastewater samples varied 7
percent from 1.4 /ig/1, while analyses of
the final effluent samples varied 10 percent
from 1.0 |ig/l.
Because of possible complications caused
by the presence of more than one Aroclor
and because of the possible interference of
DDE, identification of some of the samples
was confirmed using mass spectrometry.
Confirmation was made on nine of the
peaks from three of the samples.
The mass spectra were obtained at the
Environmental Protection Agency's South-
east Water Laboratory in Athens, Ga.
Analyses were made on a double focusing
instrument f interfaced to a gas chromato-
graph I with a separator.? A constant
accelerating voltage of 70 ev was used.
The mass spectra were manually reduced.
i Hatachi Perkin Elmer RMU-7, Perkin-Elmer
Corp., Norwalk, Conn.
t PE-900, Perkin-Ebner Corp., Norwalk, Conn.
§ Watson-Bieman.
968 Journal WPCF
RESULTS AND DISCUSSION
The analysis of the mass spectra of three
water extracts confirmed that the pen mix-
tures picscnt were the same as those
indicated by the gas chromatograph. Be-
cause the judgments made from chromato-
grams were confirmed by mass spectrom-
etry and because all samples were
analyzed on the gas chromatograph under
similar conditions, judgments made on
the remaining samples were assumed to
be qualitatively correct. However, the
occurrence of materials other than PCB'S
in the rest of the samples is not precluded.
The waste treatment plant at Beaver Dam
was the only site where possible inter-
ference was noted. On the gas chromato-
grams from this site, PCB'S could be de-
tected, but the peaks on the graphs were
obscured in such a way that the PCB con-
centrations present could not be deter-
mined.
The samples analyzed in this study in-
dicate that Aroclor 1254 is the most com-
mon PCB in the wastewater effluents.
Table III shows that PCB'S were detected
in all samples at concentrations that
ranged from < 0.05 ^g/1 at Beaver Dam
to 2.8 /ig/1 at Lake Geneva.ll The mass
transport (average pounds per day) of
equivalent Aroclor 1254 ranged from less
than 0.2 X 103- to 142 X 10'- Ib/day (0.9
X 10'- to 64.5 X 103~ kg/day) at Beaver
Dam and Racine, respectively.
Port Washington is not as highly in-
dustrialized as Grafton; however, the
effluents from both cities contained ap-
proximately the same concentrations of
PCB'S. The concentrations ranged from
0.12 to 0.23 pg/1 which, based on this
study, is typical for cities with little or no
industry.
Cedarburg is an industrialized munici-
pality whose effluents contained concentra-
tions of equivalent Aroclor 1254 of ap-
proximately 1.0 /ig/I. Because the concen-
trations of PCB'S for this city were high,
the fluctuations in concentration through-
out a 24-hr period were determined. The
II The determinable Jevel for PCB'S in water is
approximately 0.05 /*g/I with this method.
1119
-------
i-cu REMOVAL
TABLE III.—PCB Concentrations in Wisconsin Treatment Plant Effluents
City
Beaver Ddin
Port Washington
Grafton
Ccdarburg
Racine
Burlington
Lake Geneva
Walworth
Beloit
Fort Atkinson
Portage
Sampling
Date
(1V71)
1/20
2/19
3/22
10/6
1/20
2/19
3/22
10/6
1/9
2/19
3/22
10/6
1/20
2/19
3/22
10/6
10/6
10/6
1/20
2/19
3/22
10/6
1/20
2/19
3/22
10/6
1/20
2/19
3/22
10/6
1/19
2/20
3/22
10/6
1/19
2/20
3/22
10/6
1/19
2/20
3/22
10/6
5/20
9/20
10/6
1 ime
6:30
6:30
6:30
6:30
8:30
8:30
8:30
8:30
9:30
9:30
9:30
9:30
10:30
10:30
10:30
10:30
10:30
10:30
8:30
12:00
12:00
12:00
9:30
13:00
13:00
13:00
10:30
14:00
14:00
14:00
11:00
14:30
14:30
14:30
12:30
16:00
16:00
16:00
2:00
18:00
18:00
18:00
10:00
10.00
10:00
TCB Concen-
trations*
<0.05
<0.05
<0.05
<0.05
0.14
0.12
0.22
0.19
0.12
0.13
0.23
0.07
0.48
0.28
0.97
0.91
1.1
1.0
0.72
0.60
0.76
0.83
0.14
0.09
0.08
0.12
2.5
2.2
2.8
2.4
0.17
0.21
0.34
0.18
0.11
0.07
0.06
0.14
0.15
0.07
0.10
0.08
42
38
32
Flow
(mud)
1.59
4.33
3.50
2.34
0.70
1.27
1.46
1.80
0.84
1.00
0.78
0.84
1.05
1.17
2.57
1.95
1.95
1.95
16.45
25.06
23.01
20.51
1.74
2.61
2.50
1.35
0.56
0.66
0.78
0.54
—
—
—
—
3.89
11.75
7.56
4.42
1.24
2.48
1.85
1.30
0.79
1.00
0.78
Estimated M.1S3
Transport!
(lO'-Ibl'CB/ilay)
<0.2
—
—
—
_
—
2.7
—
0.8
1.1
1.5
—
4.2
2.7
—
15
18
16
— .
—
—
142
—
—
1.7
—
—
—
18
—
—
—
—
• —
—
—
3.8
5.2
—
—
1.5
—
—
—
~
* The chromatograms from all cities except for Portage most closely resembled the chromatogram of
Aroclor 1254; the chromatogram from the Portage samples most closely resembled the chromatogram of
Aroclor 1248.
t Mass transport estimates were made by dividing the number of pounds of PCB's discharged by the plant
per day by the average flow of wastes into the plant per day,
Note: Mgd X 3,785 = cu m/Uay; lb X 0.454 = kg.
Vol. 46, No. 5, May 1974 909
1120
-------
DuBE KT AL.
RELATIVE RESPONSE
100
04 8 12 16 20 24
RETENTION TIME (IN ^yllNUTES)
FIGURE 2.—Chromatogram of
Aroclor 1254.
concentration of POT'S in raw wastewater
began to increase at the beginning of the
working day (8:00) from 0.54 jig/1 to a
maximum of 3.1 ^g/1 at 16:00 hours (Fig-
ure 3).
The concentration of rcs's in the final
effluent seems to begin increasing from 0.33
/ig/1 at 0:00 (midnight) to a maximum of
0.77 /.g/1 at 14:00. The TCB concentration
in both raw and final wastewaters in-
creased and decreased simultaneously
throughout the day.
^The PCB concentration in the effluent is
approximately 30 percent of that in the
influent, and it is likely that the primary
.and secondary treatment plant was remov-
ing in excess of 70 percent of the PCB'S.
The analysis of PCB'S in the sludge pre-
sented in Table IV indicates that the
sludges contain 1,000 times higher con-
970 Journal WPCF
centrations than does the water effluent of
Cedarburg,
Racine is highly industrialized and has a
high flow [11 mgd (41,635 cu m/day)]
in its wastewater treatment plant. The
PCB concentrations varied from 0.60 ;ig/l
on February 19 to 0.83 Mg/l on October 6.
Because of the comparatively high flow,
the mass transpoit of pen's from the Racine
plant is greater than 0.1 Ib/day (0.05 kg/
day) compared with approximately 0.02
Ib/day (0.009 kg/day) from the Cedar-
burg treatment plant.
Plants in Burlington, Walworth, Beloit,
and Fort Atkinson had concentrations
CONCENTRATION
(IN /iQ./l)
15
— INFLUENT
— EFFLUENT
O 4 8 12 16 20 24
TIME (IN HOURS)
FIGURE 3.—Hourly concentrations, of
polychlorinated biphenyls in the influent
and effluent from the Cedarburg, Wis-
consin, treatment plant, April 15, 1971.
1121
-------
I'CD REMOVAL
above the dcterminable level but less than
0.40 jig/1. The mass transport of POT'S
from the treatment plants in these four
cities was less than 0.01 Ib/day (0.005 kg/
day).
Lake Geneva is a highly industrialized
city whose treatment plant effluents had
PCB concentrations between 2.2 and 2.8
/»g/l. These high PCB concentrations sug-
gested that the contamination is possibly
from industrial wastes. The daily dis-
charge of 0.02 Ib/day (0.009 kg/day) was
comparable to that for the Cedarburg
plant.
Although industries in the city of Portage
are few, they contributed between 32 and
42 /ig/1 of equivalent Aroclor 1248 to the
sanitary waste flow. A sample of the
digester sludge was analyzed at 10:00 and
found to contain 5.25 ing/1. It is of in-
terest to note that the city of Portage has
lepoited problems with the operation of
their trickling filter, which may partially
be the result of the presence of PCB'S and
other chemicals. With 32 to 42 /ig/1
equivalent Aroclor 1248 in ^the waste, it
could be toxic to some of the filter fauna.
Organic mercury compounds were also
found by mass spectrometry on the scum
of the trickling filter at concentrations up
to 90 mg/1.
Data presented in Figure 3 demonstrate
that the time of sampling waste effluents
is of major importance in mass transport
estimate. For example, if the Cedarburg
effluent was sampled at 14:00 on April 15,
1971, the estimated transport of PCB'S out
of the plant would be approximately twice
that estimated from a sample taken at 8:00.
It should be noted, however, that the PCB
concentration in the effluent from the plant
varied considerably less than that in the
raw wastes entering the plant. Conse-
quently, the mass transport may be con-
sidered as ordcr-of-magnitude estimates.
The sources of the PCB'S entering the
treatment plants have not been identified
in this study or in the literature. It is pos-
sible that pen's could be released through
the use of household products such as
cleaning compounds and waxes. For ex-
ample, Veith and Lee" -found PCB'S in
TABLE IV.—PCB Concentrations in the Cedarburg ,
Wisconsin, Treatment Plant*
Sample
Digester sludge
Primary settling sludge
PCB Concentration!
At 10.00
(ms/1)
24
69
At 16 00
(nig/I)
20
31
* Samples taken on April 15, 1971.
f The chromatograms of the samples most closely
resembled the chromatogram of Aroclor 1254.
several detergents designed for electric
dishwashers, aluminum foil, and packaging
material. In addition to these possible
household sources, PCB'S may be released
from leaking heat-exchanges, cutting oils,
and lubricants. The Monsanto Company,
formerly the sole producer of PCB'S in the
U. S., restricted the sales of PCB'S to ca-
pacitors, transfonners, and heat exchange
systems in August 1970, although until
April 1971 PCB'S were still sold for in-
dustrial uses for which suitable replace-
ment chemicals were not immediately
available.
Further studies are needed to determine
how effective these self-imposed restric-
tions by Monsanto will be in reducing the
quantities of PCB'S entering the environ-
ment.
SUMMARY AND CONCLUSIONS
The results of this study indicate that
6 of the 11 wastewater treatment plants
in the study had effluent concentrations in
the range of 0.1 to 0.5 p.g/1 of a compound
whose chromatogram appeared to match
the chromatogram of Aroclor 1254. Two
siles had effluent concentrations greater
than 1.0 /ig/1 of equivalent Aroclor 1254.
One city had -a maximum concentration
of 42 ^g/1 of equivalent Aroclor 1248 in
the effluent waters and 5.2 mg/1 of equiva-
lent Aroclor 1248 in the digester sludge.
Data from the Cedarburg treatment
plant show that the time of collection is
important because the concentration can
vary greatly. The data show that the
minimum concentrations of PCB'S in the
Cedarburg plant are probably 0.13 to 0.30
Vol. 40, No. 5, May 1974 971
1122
-------
DOBB ET AL.
of equivalent Aroclor 1254, while
maximum concentrations range from 1.5 to
3.1 ftg/1. Because of hourly fluctuations,
it is difficult to determine precisely the
total amount of pen's being discharged into
receiving waters without hourly sampling
of the effluent at a given site
Of the vaiious samples of waste effluents
collected, the estimated mass transport of
PCB'S varied from < 0.2 X 103' to 142 X
103- Ib/day (0.9 X 10'- to 64.5 X 103- kg/
day). At Racine, an equivalent of 41.1 Ib
FCB/yr (1S.7 kg/yr) flowed into the near
shore waters of Lake Michigan.
Based on the study at the Ccdarburg
plant, it seems that the treatment of do-
mestic waters removes 70 percent or more
of the PCB'S (Aroclor 1254) present in in-
coming wastes. The fact that most of the
PCB'S are removed by treatment is also
evident in the comparatively high concen-
tration of PCB'S found in the digester and
primary settling sludges.
ACKNOWLEDGMENTS
Credits. The authors wish to acknowl-
edge the aid of Jackie Zoch for her assist-
ance in the analyses, Joe Ball for his as-
sistance in sample collection, and Wayne
Garrison and his staff from the EPA South-
east Water Laboratory in Athens, Ga., for
their help on mass spectral analyses.
This investigation was funded by the
Wisconsin Department of Natural Re-
sources and by the Department of Civil
and Environmental Engineering, Uni-
versity of Wisconsin, Madison. Additional
support was provided by the University of
Texas, Dallas.
Authors. Douglas J. Dube is research
chemist, Department of Natural Resources,
Madison, Wis. Gilman D. Veith is scien-
tist, EPA National Water Quality Labora-
toiy, Duluth, Minn. G. Fred Lee is direc-
tor, Institute Environmental Science, Uni-
versity of Texas, Dallas.
REFERENCES
1. Veitli, C. D., "Environmental Chemistry of
the Chloro-Biphenyls in the Milwaukee
River." Pli.D. thesis, Univ. of Wisconsin,
Madison (1970).
2 Burchfield, H. P., and Johnson, D. E., "The
Analysis of Pesticide Residues." U. S.
Dcpt. of Health, Education, and Welfare,
Washington, D. C. (196S).
3. Hughes, R. A., "Studies on the Persistence of
Toxaphene in Treated Lakes." Ph.D. thesis,
Univ. of Wisconsin, Madison (1970).
4. Risebrough, R. S., et al., "Current Progiess in
the Determination of the Polychlorinated
Biphenyls." Bull. Environ. Contam. Toxicol.,
4, 192 (1969).
5. Stalling, D. L., and Huckins, J. N., "Gas-
Liquid Chromatography—Mass Spectrom-
etry Characterization of Polychlonnated
Biphenyls (Aroclors) and "Cl-Labeling of
Aroclors 1248 and 1254." Jour. Assn. Offic.
Anal. Chem., 54, 801 (1971).
6. Veith, G. D., "Role of Lake Sediments in the
Water Chemistry of Toxaphene." M.S.
thesis, Univ. of Wisconsin, Madison (1968).
7. "Pesticide Analytical Manual." Food and
Drug Admin., Dept. of Health, Education,
and Welfare, Washington, D. C. (1971).
8. Veith, G. D., and Lee, G. F., Unpublished
data. Water Chemistry Program, Univ. of
Wisconsin, Madison (1970).
972 Journal WPCF-
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THE CHAIRMAN: All right. Thank you, Mr. Howard.
Do we have questions?
Mr. Mausshardt.
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MR. MAUSSHARDT: Yes. Mr. Howard, would it be
possible — this is more of a request than a question — to
have you submit to the record for us cost data on the operation
of these incinerators and the cost of the incinerator itself?
MR. HOWARD: Yes.
MR. MAUSSHARDT: Thank you very much.
THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: Did I understand correctly that the
information which you are going to be giving to us will have
information on the data on the Monterey tests and some of
these other tests?
MR. HOWARD: Yes, yes. And if it is not all complete
here, we have the entire test.
MR. LINDSEY: And one other quick question, if I can.
You mentioned that the ash from this type of incinerator
brings somewhere in the neighborhood of $40 a ton to $80
a ton. I think those are the figures you used.
MR. HOWARD: Right.
MR. LINDSEY: Apparently this is a useful product.
Could you elaborate on what it is used for and who it
would be that might be interested in purchasing the materials.
MR. HOWARD: The value that was placed on this was
strictly for its phosphorus and nitrogen contents and would be
used as the cost of these chemicals increased.
The consideration of the utilization of ash as a soil
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conditioner and supporting material increases.
Historically in the past the cost of such fertilizer
with those products was so low because they could be manufactured
for less. But today with our shortages of natural gas and such
it is becoming worthy of consideration.
We have people inquiring from us today on samples of
ash from many installations so they can evaluate if they do
have a basis to set up a marketing program.
THE CHAIRMAN: All right. Mr. Lazar.
MR. LAZAR: Mr. Howard, the ash, as you said, will now
be used as a soil conditioner, but this is in spite of the high metal
content.
Now, do you have any information which would indicate
that this is safe to use to grow crops on?
MR. HOWARD: Well, I think, yes, we have, but you are
faced with two situations.
We are faced with ash coming from municipal treatment
plants which have very low quantities of heavy metals versus
ash that comes from a plant used to decompose or destroy
industrial waste.
So you could very well develop an ash from an industrial
furnace that would not be acceptable for the land. On the
other hand, the ash from the majority of the domestic sewage
treatment plants, the level of these heavy metals is so low
that they were not in there in the beginning — this is what we
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are saying. That the feeds in these furnaces were so low in
these materials that the ash is still safe.
MR. LAZAR: Could you submit something to the record
which would show the levels of the domestic original like
sludge versus industry origin sludge?
MR. HOWARD: We have in the pamphlet tests of all the
metals or a series of heavy metals run on sludges from a
domestic plant. We do not have here, and I do not know if we
have in our files from selected industrial wastes. So I can
only at the moment comply with the first part, the domestic.
MR. LAZAR: Thank you.
THE CHAIRMAN: Mr. Bourns.
MR. BOURNS: I have a question from the floor, and I
also have to ask one of my own which is similar. I will read the
question from the floor first.
Are there any sludge incinerators operating in the
Los Angeles area? If not, why not?
The question I had was: Has the LA Airport passed on
your mobile incinerator for all types of emissions?
MR. HOWARD: The answer to the first part is, to the
best of our knowledge, there are none operating in the LA Air
Pollution Control Area District.
MR. BOURNS: Why not?
MR. HOWARD: And as far as passing on it, the first
effect, you might say, was that if you put one in, it will not
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pass, regardless. No standards were given for any manufacturer
to• meet. It was just the basic statement that at that time —
this is like five years ago — that we sat down with the Board,
and it was not an open subject for consideration.
And since then we have been approached to build a pilot
test furnace. And it is our understanding now that because of
the severity of the problem in the basin, the questionable
continuation of ocean outfall, that they now wish to start
collecting data. And to this end we will be cooperating with
them as much as possible.
THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: I have two questions from the floor.
Has any work been done on pesticide manufacturer waste
sludges? If so, what was found?
MR. HOWARD: We have done none. The only history that
we have on handling some of these materials was that in the
case of PCB's, they attempted incineration of 100 percent PCB,
and in that case an elevated temperature for prolonged periods
accomplished destruction. And I think that that is about the
only information we have.
Our work has been conducted solely with these materials
as found in the domestic waste that we are processing.
MR. KOVALICK: The second question from the audience
was, what is the maximum concentration in NO issuing from the
X
multiple hearth furnace system?
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MR. HOWARD: The maximum concentration?
MR. KOVALICK: Right. If it is in the statement, maybe
we can —
MR. HOWARD: Yes, it is in the statement. But because
the furnace operates at a comparatively low temperature, compared
to other thermal devices such as automobiles, the NOX production
is very low.
It is only when you get into much higher temperatures
that you increase your production of NO...
A
THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: I have several here from the floor and
one of my own which I can combine altogether. They have to do
with emission control and discovery.
First of all, what type of emission control equipment
or scrubber equipment do you recommend for hazardous waste
incinerators of this type?
MR. HOWARD: Well, we have used in our domestic
installation, we used initially a three-stage impingement, and
then as the more stringent regulations came out and the increasec
volume of secondary biological sludges which produce a finer
particulate matter, we have now gone to a variable throat
venturl operating in the rage of 20 inches pressure drop on up
to 40, depending on the application.
MR. LINDSEY: Okay. The second part of these questions
if mercury and arsenic are removed in the scrubber, how are they
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removed from the scrubber water?
In other words, what do you do with the scrubber water
once you are done with it?
MR. HOWARD: This just brings the problem back to the
treatment plant, which brings it around again to the control of
dischargers to the treatment plant.
We have taken it out of the air and put it back into
the water. If it is in sufficent concentration, you have it
at a point where you can treat it, because you have less water
volume than the total discharge volume of the treatment plant.
But, on the other hand, in effect what you have done
is returned it to the water stream. And the first point of
control is really the discharger.
MR. LINDSEY: Then what you are saying is that since
the scrubber water is recycled into the sewage treatment plant
you would have a circulating effect, in essence.
MR. HOWARD: Circulating or going out in the effluent.
MR. LINDSEY: Or in the sludge or in the ash.
MR. HOWARD: If it comes back in the ash, then you
are going to have some recycing build-up in the ash. But you have
it in a much more concentrated form, and you have it at a
location where you can do something about it.
THE CHAIRMAN: Mr. Lazar.
MR. LAZAR: Mr. Howard, from the audience a question.
Have you studied the heavy metal air emissions as a
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function of heavy metal content of the waste?
I presume the question is concerned about those wastes
that have an exceptionally high amount of metal.
MR. HOWARD: Yes. We have. As I mentioned a little
earlier, in order to get a measurable amount of the heavy metals
we had to dose the wastes with heavy metals. So we immediately
had a material balance across the test program. We knew how
much we put in, and we knew where it all dropped out, so we had
to measure the sewages of the domestic wastes that may have
high heavy metals — we have found outside of those that you
can identify. We have found that in some areas you have
combined sewers, that they pick up zinc from guardrails and
such. Because they are flushing the whole city street system
at the same time they have an increase.
Philadelphia is a case in point.
THE CHAIRMAN: All right. Do you have one more ques-
tion, Mr. Lindsey?
MR. LINDSEY: Yes, I have one more question from the
audience.
What are the apparent difficulties with the San Jose
mobile hearth sewage plant installation?
Would you care to comment on that?
MR. HOWARD: Yes, I would be glad to.
The San Jose installation is designed to burn grease
or scum from the sewage process, and it is burning it in a
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hundred percent concentration. It is not mixed in with sewage
whatsoever. And, therefore, we had a tremendous load of this
material., And when the system was tested with a moderate energy
venturi scrubber, it was found that we could meet the hydro-
carbon emissions, we could meet the actual particulate loadings,
but because of a very fine sub-micron discharge of mostly
calcium identified particles, we could not meet the Wringleman
or the opacity. And therefore, the unit is being modified,
and we are making changes on it. ,
But basically it was a problem of calcium sub-micron
particles being outside of the efficiency range of the scrubber
system.
THE CHAIRMAN: Thank you very much, Mr. Howard.
Next I would like to call Mr. James Burch of Project
Survival.,
Mr. Burch, please. Is Mr. Burch in the audience?
I will call on the next speaker and perhaps we can come
back and check later on with Mr. Burch.
I would like to call Dr. Paul Palmer from Zero Waste
Systems, Incorporated.
Dr. Palmer, will you accept questions?
DR. PAUL PALMER: I rise today to speak as president
of Zero Waste Systems of Oakland, a broad spectrum industrial
chemical recycling company. We were the first of our kind in
the United States. After two and a half years we are probably
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still unique. I am glad to be speaking in this capacity since
all the discussions of industrial waste I have heard or read
lately, including those of the EPA, have been dominated by the
psychology of dumping with only a perfunctory nod toward the
value of resource recovery. I will try to bring that balance
back on center as I see it.
Anyone reading EPA publications recently would be
justified in assuming that the EPA is our staunchest ally.
Listen, for example, to Roger Strelow, Assistant
Administrator for Air and Waste Managmenet, writing in Seven
Conference Papers (EPA/530/SW-156 Feb. 1975)
"We at EPA are committed in making recycling
happy — for both energy and materials." Page 8.
In the same publication, on Page 25, John Lehman,
Director of the Hazardous Waste Management Division, says:
"We support the concept of an industrial and
hazardous waste clearinghouse, that is, to use the
waste as is, if possible. One man's waste is another
man's feed stock. A firm in Oakland, California was
recently formed to provide this service for the
western area."
It may be immediately understood that the reference
is to my company, Zero Waste Systems. What is not so
immediately understood by the layman is that this kind of
expression has become de rigeur in discussing hazardous wastes.
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Even the most vociferous opponent of recycling is required today
to endorse at least the concept of recycling "ultimately."
If I may be permitted a trite phrase, recycling has joined
motherhood and apple pie in the American pantheon. What
separates the supporters from the sideliners today is actions,
not words.
On the action Scoreboard EPA has shown anything but
support for chemical recycling. What I see instead is:
One. A pervading, arrogant blindness to the day-to-
day realities of industrial waste recycling;
Two. The Aerospace Syndrome. A dedication to
technology solutions and a rejection of common sense resolutions
Three. The We-Could-Have-Built-Rome-in-a-Day Syndrome.
An insistence on capital intensive approaches in a time of
capital shortage and a rejection of labor intensive techniques
in a period of unemployment.
Four. The Big-Bucks-Buy-Better Syndrome. A marriage
between EPA and giant institutions for expensive proposals.
There is no time for innovative approaches or small companies.
TRW, Arthur D. Little, Battelle Corporation, Monsanto,
Occidental Petroleum — these are the grinning Cheshire cats
pocketing the grants.
Five. The Split-Century-Timing Syndrome. A willingness
to dawdle along the country roads of waste management so long
as some progress is made towards ultimate recycling. No tears
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are shed for the valuable resources being buried today that we
could already be recycling today were government policy not so
dilatory.
Six. The Witch Doctor Syndrome. A three-year romance
with an absurd bureaucratic solution to the waste problem — the
waste clearinghouse. By shaking the right rattle at the
diseased patient the illness will suddenly disappear. We have
tested this idea sufficiently to know that it does not work.
Recycling cannot be divorced from hard work, intelligence,
committed leadership and legislative support. The public is
hardly crying for another governmental department to meddle
in industrial affairs.
If unimpeachable proof of the lack of interest on
the part of the EPA in industrial recycling is required, we
could not do better than to turn to their own listing of EPA
reports through June, 1975. Looking under the following topics
we find:
Recycling — no entries;
Resource recovery — no entries;
Waste utilization — no entries;
Waste recycling (excluding solid wastes, municipal
wastes and automobile wastes) — six entries.
Two on waste plastics; one on recycling assessments
and prospects for success; one on a chemical microbial plant
for converting cellulosic wastes into protein; one on marketing
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sulfuric acid arising from sulfur dioxide abatement and one study
of Federal subsidies to stimulate resource recovery.
Looking under "waste disposal" on the other hand, we
find no fewer than 230 papers listed, many of which are long
bibliographies. Where in these reports can we discern the
EPA's commitment to recycling?
The EPA does further injury to the movement for recycl-
ing by accepting without question the traditional biases of the
dumping industry. Admittedly these biases can be subtle and
imperceptible ,so I will try to expose them to our scrutiny.
Remember that dumping is an absolutely unique concept of
chemical materials. The viewpoint of dumping is such as to
reduce all chemicals to two physical measures — gross weight
and gross volume. In no other industry are chemical substances
so insulted. Nevertheless, it is a fact of nature that all
substances possess mass and occupy space. Therefore, all
substances are more or less susceptible to the categories of the
dumping process.
Recycling,on the other hand, attaches no more signifi-
cance to gross weight and volume than any other industrial
process does. More important are chemical properties, reactivity
safety of handling, purity, availability, utility of resulting
products, pathways to commercial materials and closeness to
markets. The recycling industry is incapable of dealing with
wastes as either flammable or not, toxic or not, liquid or solid
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pondable or incinerable. We must slowly investigate an array
of questions, data and problems before we even begin to come
up with solutions. The biases referred to earlier come into
play when a potential recycler of a waste is thrown a problem
couched in all the terms of the dumping industry — "take care
of umpteen tons per day of anything we throw at you."
For a classic and disgraceful application of these
biases see the EPA Request for Proposal No. WA 75-R528 which is
out for a contract at this very moment.
Some simple corollaries flow from the above
observations:
One. Time. Recycling solutions will not be found
in response to crash study programs. They will require
nurturing and development. The early exploratory stages can-
not be dispensed with. They will take even more time than the
implementation stages. If the process of developing recycling
alternatives to dumping is delayed today, attainment of goals
will be delayed by an equal amount of time. The EPA wasted
two years fiddling with the national dumpsite concept. Now they
are throwing more years into the waste exchange concept. How
many years will it take before the EpA stops searching for
magical, convenience solutions to the hazardous waste problems
and begins to till the soil, sow the seed and prepare for the
hard work that has always preceded the best crops;
Two. Recycling must be allowed to treat individual
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problems. Any study, treatment plant or new invention which
purports to solve a host of waste management problems all at
once is construed to be a disposal technique. Recycling
solutions will not emerge this way. Any funded project whose
avowed goal is to treat enormous varieties of wastes will
succeed only in effective destruction of resource values, not
their conservation.
Three. Pushing back the generator interface. A
recycling approach cannot afford to waste time and expense to
unravel, decontaminate and unmix wastes which have been
unnecessarily degraded by the waste generator. The majority of
manufacturing processes are precision processes to manufacture
precision products. By and large,they are capable of producing
precision wastes. One of the main reasons we find so many gunky,
sludgey, intractable wastes today is what I call the "garbage
mentality." America has extended its Declaration of Independence
too far for 1975. "All garbage is created equalI" Old
furniture garbage, styrofoam cup garbage, sulfuric acid garbage,
DDT garbage — all have the same name and so can share the same
fate. In millions of plants the wastes are allowed to mix in
common drums, sumps and heaps. The dumper is unaffected. He
swallows it all. The recycler has to spend much of his energy
pushing back his interface with the generator into the
manufacturing process itself to eliminate unnecessary waste
degradation.
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The EPA has encouraged this process by its emphasis
on effluent cleanup with no regard for the sludges produced in
spite of the enormous quantity that are expected. If a former
air and water polluter spends millions on equipment to produce
garbage he has satisfied the EPA. How readily can you expect
him to spend once more to replace that equipment with other
equipment which produces a salable by-product instead of
garbage? We are watching today as the EPA orchestrates a vested
interest in producing garbage — a vested interest which will
resist recycling in years to come.
Putting the above three points together, we can con-
clude as follows: Any approach to waste management which makes
a genuine contribution to resource recovery, rather than merely
paying lip service to it, will need to separate waste treat-
ment into many small chunks rather than the monster batches it
is divided into now. It must begin immediately to explore the
chemical and marketing subtleties of recycling which will not
yield fruit this year or the next,but will eventually eclipse ai
other approaches. It must bring technology, common sense and
American know-how into this field through the involvement of
small innovative companies such as Zero Waste Systems.
Thank you.
THE CHAIRMAN: Do we have questions?
Mr. Lindsey.
MR. LINDSEY: Yes. Dr. Palmer, we have heard again and
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again that the major problem with recycling generally — talking
now of municipal refuse as well as industrial wastes — is one
of economics, that unless and until the raw material crisis
becomes high enough to make the process pay or unless and until
new technology is developed which enables the treatment of these
wastes to become cheap enough, why, recycling will not occur in
the private field.
Can you comment further on that particular part of
the problem as you see it.
DR. PALMER: Yes. I do not think that that is an
accurate assessment of where recycling finds itself today. I
think that is about six or seven years old.
Today, recycling is — most of the time — I do not
know what figure to put on that percentage-wise, but most of
the time it makes money for people, it is economical.
It is already — I think the shortages of 1972, '73,
the energy shortages have taken us beyond that point.
People talk about technology as though it is brand-
new technology that is waiting to be developed. It is not so
at all.
The technology for dumping, the dumping industry,
so far as I understand it, is not yet developed. People cannot
contain waste, they cannot incinerate them, they cannot do it
well. In all fairness, they bite off a bigger job than a
recycler who takes specific wastes and says, "I cannot handle
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everything in the world." And dumpers try to handle everything i;
the world. So in all fairness it is not the same.
Whereas in recycling the technology that is required
is 19th Century technology. It is well understood it is easy.
Now, it is a question of what you mean by recycling.
Our concept of recycling is that it is not a way of selecting
an industry taking its waste and returning it immediately to
the same industry. We try and move to a different industry.
We keep it in the materials pool for the benefits of recycling,
and we do it in a different way.
MR. LINDSEY: Well, then, are you telling me where it
is economically practical it is occurring?
For instance, I know of a number of companies that are
in the business of treating hazardous materials and reclaiming
large fractions of those materials. And they seem to be able
to do it at a profit where it is profitable. And it seems to
be being done.
Are you telling me that it is not in fact being done,
that there is something further that needs to be done that we
should do or undertake specifically?
DR. PALMER: As I understand it, most of the companies
— well, probably the companies you would be referring to have
taken a specific industry or specific waste where there was
some valuable components and then extract it attacks the
problem on a fairly limited basis one at a time.
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We take the broad range of chemical materials and
by moving them around different industries we essentially cover
— we treat recycling in itself as a separate discpline rather
than looking for one valuable component here or one component
there.
When you are dealing in valuable components you often
end up with a worse sludge than you started with. But it just
does not have that value in it any more, so you feel justified
in disposing of it, but it does not necessarily solve the
environmental problem.
THE CHAIRMAN: Mr. Lazar.
MR. LAZAR: Dr. Palmer, just the day before yesterday
when we had an identical public meeting in Houston a Dr. William
Brown from Bioecology Systems, Incorporated testified that to —
to give you an example how difficult it is to bring about
recycling, that he had a shipment of 10,000 gallons of essentiall
potable ethyl alcohol, and he tried for a long time — I
believe he said for weeks — and he just could not find a
customer for it. He just did not know what to do with it. I
presume he has to dispose of it.
What would you suggest as to how he could go about
recycling it if the market in that particular area seems to be
such that 10,000 gallons is probably not considered commercially
feasible, not profitable for recycling.
DR. PALMER: Well, I think that judging by the fact that
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he did testify that there is a real problem there.
Now, it sounds to me like the problem is one of
information, of knowing what to do, knowing your markets, and
knowing how to find markets than any technological problem or
economic problem.
I cannot see why there would be any purely commercial
obstacle encountered.
MR. LAZAR: How would you go about finding the market?
DR. PALMER: Well, rather than getting into the
specific question of ethyl alcohol, let me point out that this
is exactly what recycling is about. The heart of recycling
is not technology — well, it is the economics, but the heart
of it is in marketing, finding a way to reuse materials.
There are dozens, hundreds of potential products you
can make from a given waste or surplus or what have you with
all kinds of different markets.
What we specialize in is ways of finding those markets.
And so if that man had contacted us I do not think we would
have had any problem in placing that material, because that is
our daily business.
We have run into this before. In Stockton, the Army
disposed of an equivalent amount of ethyl alcohol at the time
of the worst shortage, in '72. They disposed of it while people
were shutting down their shops because they could not find it,
and yet they searched and were not able to find the people.
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MR. LAZAR: Well, Dr. Brown made the specific point
that if it had not been a one-time shipment he would have had
no problem probably — that is, if it was a continuous process
of producing 10,000 gallons of ethyl alcohol.
But would you be able to handle just the one shipment?
DR. PALMER: Yes. That would be normal for us to handle
one shipment. That is what I say, that the people you were
referring to before, they take a continuous waste stream and
look for one particular valuable component. A tremendous
proportion of the wastes are one shot or erratic. In fact,
it is the nature of waste and one of the problems in recycling
is that wastes are not being produced for you to use, they are
being produced accidentally against the will of the generator.
And if he can cut it down, he will. If he can do something
else with it, he will. And so, the sources are always erratic.
How do you handle erratic sources in this commercial
world that requires constant markets? Well, that is what we
are set up to handle, to know how to handle one-shot deals.
THE CHAIRMAN: All right. I just wanted to make a
comment before we go on with further questions.
One of the questions from the audience is addressed
to the EPA panel. And I just want to reiterate that the purpose
of this is to gather information and not have the EPA expound.
So if you have questions of EPA, this is not the appropriate
forum. Please address your questions to the speaker and his
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statement.
We would be glad to answer questions in another forum
or directly by you writing to us, but not here.
Mr. Mausshardt, do you have a question?
MR. MAUSSHARDT: Dr. Palmer, I have two questions. The
questions did come from the floor.
As a plant engineering manager concerned with the
realities and costs of waste disposal, I can state categorically
that any market for our wastes would be welcome. My question
is, are you claiming to be a clearing house for waste materials
sales or are you a processor?
DR. PALMER: All right. What we are claiming to be —
I have to shift it a little. It depends on our response to a
particular waste.
What we would like to do is not be a clearing house
for waste alone, but a clearing house for all of the processing,
all of the marketing, all of the contracting out for processing
that is required for our waste.
There was a statement in the question that he would be
glad of any market. Well, I have to return that and ask would
he be willing to consider his wastes as a resource in order
to find a market? This is where the problem is that is called
pushing back the generator or interface. And when I spoke about
the psychology of dumping, I mean there is a feeling today
that a plant manager can produce a waste, and he is used to
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having a dumper take it away. Well, with the same convenience,
he can go to a recycler and, hopefully, even have the recycler
buy it. But he does not want to make the changes that are
needed to make that waste recyclable rather than dumpable. And
there has to be an effort on the part of the generators of the
waste to make that a recyclable material.
This is where the EPA comes in, because the generators
do not have much of an incentive. I think dumping fees should
be ten times at least what they are today. I think it is
outrageous that you can take these noxious materials and throw
them into the ground, destroy the value of that ground, and
society just accepts the price. That ground is essentially
destroyed for anything but for surface use after that.
So I think EPA comes in in making it more desirable
for people to want to recycle their waste.
MR. MAUSSHARDT: The second question I have from the floor
is: Would you briefly comment on the recent report on an
experience in West Germany that sounds like your firm's function'.
I think the individual is specifically referring to
a"Business WeeK1 article a few months ago.
DR. PALMER: I have not read this specific article, so
it slipped my attention.
MR. MAUSSHARDT: I believe it is on waste exchange.
DR. PALMER: Yes. I know that there is a waste
exchange in West Germany. I am not familiar with the details
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of it. My research director is right now in England studying
a waste exchange. But I do not know that much about the German
one.
THE CHAIRMAN: Mr. Bourns.
MR. BOURNS: Dr. Palmer, I have a question. Does your
company take mixed waste for subsequent treatment to produce a
resalable product, and also, do you store chemical products
for later placement?
DR. PALMER: Yes, we do. Storage of chemical products
is sometimes the processing that is required.
If you have a lot of small manufacturing houses that
produce small quantities of waste — it may be perfectly usable
waste or it may be a processable waste or it may have a high
value component in it — whatever. Yet the mere fact that it
has been manufactured in the small units means
that nobody can afford to get into reclaiming it. And so each
person individually contacts a dumper, and it gets hauled away.
But merely storing it up until there is enough of a quantity to
make some kind of processing economically viable, you have
performed a recycling service without having to get into heavy
industrial techniques.
THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: I have a couple of questions from the
audience.
Have you encountered any waste materials that you could
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not use or could not recycle such as arsenic sludges, spent
catalyst materials? And do not most of these processes that
are used to treat these materials end up with a sludge that
creates a problem?
DR. PALMER: Well, it certainly is true that there are
many materials that we run into that for one reason or another
we cannot handle. But part of the reason we cannot handle
them is that we have no support from outside of our organization
We have had very little legislative support. To date
we have had no financial support whatsoever. We cannot take on
a problem which does not promise some kind of a return.
Now, that is not the position that the United States
as a nation dealing with this problem should be in. The United
States should be able to handle various problems if they are
recyclable, but if they lose a little bit of money or they are
not as profitable as you would want, we should be able to
tackle problems like that from the recycling point of view.
And as I pointed out in my paper, you cannot simply
take some sludge and immediately off the top of your head know
if this is recyclable or not. There is a lot of work that has
to be done to figure this out, to figure out markets, to figure
out what kind of processes are possible.
This work has not even been started. The studies
that I have seen, the EPA studies, the other governmental
studies, they skim along so high off the ground that they do
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not even catch the peaks.
We have made virtually no use of the EPA studies that
we have in our possession on chemicals, methods of detoxification
et cetera, et cetera, because they are too general. The
categories do not tell you anything about how to actually go
about treating a waste.
THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: A related question from the audience.
Do you believe it is necessary for the government to
support prices of recycled products in order to allow for
larger scale recycling?
DR. PALMER: I do not know whether it would take that
form or another form of subisidy, but I think right now dumping
is so cheap and plentiful and available and subsidized that
recycling will not get off the ground unless some kind of
support — either dumping is discouraged or recyclying is
encouraged in one way — and I do not knew what form the
encouragement should take.
THE CHAIRMAN: Mr. Kovalick, another question.
MR. KOVALICK: Now, following on that, you have
obviously had just a little bit more than a little frustration
with EPA, a variety of troubles with us, but given your aware-
ness of our current legislative authority — and I realize
that that may not be a fair background — but what several
things do you want us to take away with us as to what we should do
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or what you propose we should do to either redress things that
you feel are incorrect or correct the approach that we have
taken in the past?
DR. PALMER: Well, I would like to give you a neat,
snap list, but I think that would take a longer answer than i
have time for here.
To sum it up, what is required is consultation with
people who are actually working in this field.
Now, for years we have been labeled as a waste exchange.
And as I said we found that that is a primitive solution. It
does not work. And yet we have not been contacted on the ques-
tion of waste exchanges in general.
I pointed out that there is a request for proposal
today. I have read the whole thing. It says in there, it has
the traditional squib about resource recovery is to be given
priority, but there is no way in the world that any resource
recovery is coming out of that I can see,: Now, I may turn
out to be wrong on that, but I do not see how resource
recovery can come out of that because of the way it is
structured. It is structured so that someone can only come
out with an enormous list on how to generate and dump and dispos
of materials. I think you have to consult with the recycling
people.
MR. KOVALICK: Well, if you have any further thoughts
and you want to put them down in writing, we would be happy to
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put them in the record in terms of proposals after you have
given it some thought.
THE CHAIRMAN: One last question. Mr. Lazar.
MR. LAZAR: From the audience.
How much potentially hazardous waste do you recycle,
let us say tons per month, something like that?
DR. PALMER: I do not feel that that is a legitimate
question, because once again it partakes of the biases of the
dumping industry, which is gross weight, gross volume — how
many tons can you slap through some kind of a system and be
done with it.
It is a question I get all the time. There is no mentio
made in there of how toxic were the materials, how valuable
were the materials, how injurious were they to wildlife. These
are more to the point, and these are the questions that are
not asked of the dumping industry. It is just how many tons per
month.
I am not claiming that we are a very large outfit, but
the ideas that we have developed, the styles, the approaches we
have developed are capable of tremendous amounts of expansion
of scale-up. And I think that is the more important answer
to that question.
THE CHAIRMAN: All right. Thank you very much. Dr.
Palmer.
Ladies and gentlemen, we have gone a little beyond the time
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we set for a break, but I would like to take a break right now to:
15 minutes. We will reconvene at 10:43.
(Short recess.)
THE CHAIRMAN: I call the meeting back to order and
call upon Mr. G.F. Kroneberger representing the American
Institute of Chemical Engineers.
Mr. Kroneberger.
MR. G.F..KRONEBERGER: Thank you, Mr. Lehman. I would
like to thank the panel for the time to participate. I would
like to thank the audience for their interest in the matter.
I would like to correct the record on one small point.
I am actually speaking for the Environmental Division of the
American Institute of Chemical Engineers. It is a rather big
association, and you cannot clear everything you say through
everybody. And it has been delegated to our association.
I am chairman of the Solid Waste Section of that
division.
We would like to begin by saying that we do not intend
to answer all the questions completely that were posed in the
notice of this meeting.
We are supplying an attachment which I will abstract on the
important points.
I would like to say that the reason we are here is to:
One. To demonstrate a willingness to cooperate on
further development of this subject.
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Two. To establish trial bench marks so that areas
of agreement, or disagreement, can be established.
Three. To make suggestions, as to some of the next
steps that should be taken, in our opinion.
Four. To establish a broad outlook so that all items
can be placed in proper perspective.
One of the more important items, and one which did not
fit in the format of our submittal, pertains to point three
above.
The agency has accumulated a wealth of information and
documentation on the subject of hazardous wastes. There also
is a vast amount of data generated from other sources, perhaps
so much as to be approaching inaccessibility of much of the
important data.
What is needed at this time are master summaries and
categorical summaries that can be reviewed, commented upon, and
updated.
This in itself can be a great undertaking. One method
of simplification can be to establish a priority list of
hazardous substances so that the most serious items can be
considered before spending much time on those items in the
lesser categories. This does not say that all energies should
be directed to the most serious items; but rather, that they
should be given major consideration.
If we were to be asked what one of our first priorities
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would be, I am inclined to quote the words of one of my
colleagues which are: "It would be clearly in the best public
interest for the agency to submit a summary and a status paper
which distills the essence from the many millions of dollars
of investigation to date."
In preparation for this, presumably a categorical
bibliography would evolve. This should be made available to
interested contributors shortly after it is in existence.
We agree with the EPA concept which was contained in
a position paper generated in early 1973: that government
involvement in the identification, control, and disposal of
hazardous materials should be confined to data collection and
dissemination, and the regulatory process; and that private
enterprise and state and local governments should be used to
the maximum reasonable extent in handling, controlling,
and disposing of such materials.
We concur, that for the long-range outlook, the very
hazardous wastes should be converted, reduced or reused, and in
effect minimized at the source. This,of course, reaches to the
very root of process applications and admittedly is not an
overnight accomplishment.
That is the statement that is a computation of a handful
of interested people on the executive board of the Environmental
Division.
I will just go through the more important points that
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may have not been covered.
Harvey Collins covered the hazardous definition very
well. We would like to add to that that what should be included
on hazardous material are the triggers — in other words, a
material in most of its existence is not hazardous. Something
has to happen to it to make it hazardous, whether it is
ignition, pressure or force or somebody breathing it.
We have to start identifying these causative forces.
Also, the degree of the hazard has to be identified
as: very bad, bad potential,minor, et cetera. And also the
obviousness of the hazard. There are many hazards which are
very obvious, there are many hazards that are not.
One good case in point: I believe you all read about
the high school chem labs having materials that could be quite
hazardous, yet there is no way of knowing this unless you are
an expert on that particular material.
In some of these instead of reading a whole question,
what we have done is itemized the answers — very brief answers,
I might add — to the points specifically listed in the Federal
Register.
I will just refer to them by letter. Most of you have
a copy of that in case you wanted to see what the detailed
question is.
Regarding "2.A.," What Responsibilities/Liabilities
Rest With the Following for Ultimate Environmentally Acceptable
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Methods:
Generator: Should quantify the content, the
characteristics, and the hazards of the wastes he generates.
The treater should know the waste characteristics
he begins with, the effect of his treatment and the character!st-
tics of the wastes he ends with.
The disposer should know the composition characteristics
and hazards of the waste he emplaces.
I am just abstracting some of the points that have not
been covered.
On point "2.B," Who should bear the costs of assuring
envinronmentally safe disposal?
There is quite a bit of a disagreement on who should
bear those costs, and I am going to skip over the controversial
points, because I would like to present a, 'what-we-all-agree-
on" point of view.
One subletter under that paragraph is,"Each party should
assume the costs of what he has to do to perform his function
in a realistically environmentally sound fashion. This would
then be reflected in his costs and therefore the costs of his
services. If alternatives exist, which do not involve very
high costs for proper treatment, then the most environmentally
and economically usable method will evolve in the competitive
business world.
"Sut it should be borne in mind that changes and
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adaptations cannot be made with every "change of the wind1 and
realistic long-term evolution has to be programmed.
"The great turn-around has already been made. While
there is room for continued improvement, there is no need for
unrealistic panic."
On "3.A," for which wastes, if any, should the following
be required:
The subheadings are listed by the EPA.
a. Recovery/Reuse. We are saying whenever possible.
b. Incineration, which we are going to call combustion
because in some cases incineration has been given a connotation
that is not good because it used to be something that was waste-
ful.
We are saying, properly done, incineration can be an
energy resource recovery operation. We are saying let us call
this combustion now. For obnoxious toxic wastes can be
recovered — that was the answer to point "b."
c. Chemical Treatment — if needed.
d. Physical Treatment — when possible.
e. Bio. Treatment — if adequate and considering costs
and values.
One point under "3.B," for which wastes should the
above be prohibited, we are saying only those processes which can
produce dependable, acceptable results should be used.
The processes that qualify for point one should be
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applied in the sequence that gives the most favorable ratio of
benefit/cost. Special emphasis should be placed on
conservation processes, such as: recovery/reuse and combustion
with energy recovery.
As a supplement to point three we are preparing a detaile{3
listing which probably in no way will meet what is already
documented in some corner of some room, but we are going to
list the specific processes, specific equipment processes for
materials that have been known to be applied successfully.
This has not been completed yet.
What data are available for the above— for those that
we submit, data will be available on costs.
"6.A." was covered very well by Harvey Collins. That
was: What are minimal safety and security precautions for
treatment, storage and disposal sites?
And on "11," regarding transportation regulations,
we are suggesting that hazardous materials have an easily
identified marking on the box. This can be different colors or
different kinds — red for flammable, yellow for something else
— but something easily identified. And I believe it has to
be used sparingly. Because if you look at everything, every-
thing in the world can be called hazardous.
One colleague made the comment that love to excess can
be hazardous. The key there is "excess." Excess of anything
can be hazardous. What we have to do is focus on the very
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serious ones.
And that is about the extent of my remarks.
Thank you for your time.
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RESPONSE TO
ENVIRONMENTAL PROTECTION AGENCY
NOTICE OF PUBLIC MEETINGS ON
HAZARDOUS WASTE MANAGEMENT
Bv: r
ENVIRONMENTAL DIVISION
OF AIM
12/11/75
1160
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PREFACE
GFK/cs
11/75
This response is supplied by interested responsible
members of the Environmental Division of the American
Institute of Chemical Engineers. The task set-out by
the EPA is not a simple one, nor will we ever be able
to state "this is it". The subject is controversial
and parties can have honest differences of opinion from
their own particular points of view. The views expressed
herein are a melding of the points of view of professional
Engineers from the actual facets of generators, treaters,
disposers, intermediaries, the Government and of course
the citizenry. At this time they probably do not represent
the views of any particular individual, but should be looked
upon as a brief, composite starting point for continued well
guided evolution for the betterment of the whole without
undue over-emphasis on a particular facet.
Note: Copyrights are reserved and nothing is to be
abstracted or quoted out of context without
prior permission.
The following sections are presented as itemized in the
meeting announcement. The headings have been highly
abbreviated to aid identification without repetition.
Sub-headings have been added where multiple points were
listed in the original documentation. The portion posed
by the EPA has been underlined.
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HAZARDOUS WASTE (H.W.)
Answer Sheet
l.A. What IB a Hazardous Waste;
The definiation used in EPA (A-107 is a good start. In some
cases the effect that triggers the hazardous condition should
be included; such as:
Ignition, Force, Pressure, Temperature,Air exposure, etc.
We need criteria for categorizing the degree of hazard, such as:
Very bad, bad potential, minor
We need to establish (or include) the obviousness of the
hazard; such as:
Obvious, not normally obvious, latent, low potential.
I.E. Method of Collection of Waste Samples:
The waste source should list the types of hazardous materials
that might be present and the content of known constituents.
The best smapling methods should be known and established at
the source. The goal should be to reduce "unknown" wastes.
r.C. What Analysis/Lab Methods for This Decision Process:
Most of the analysis/lab methods are known. The main item
is to classify the material hazards.
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2.A. What Responsibilities/Liabilities Rest With the Following for
Ultimate Environmentally Acceptable;
Generator: Should quantify (reasonable ranges ok) the content,
and characteristics, and hazards, of the wastes
he generates.
Treater: Should know waste characteristics he begins with,
the effect of his treatment and the characteristics
of the wastes he ends with.
Disposer: Should know composition characteristics and hazards
of the waste he emplaces.
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Who should bear the coats of assuring Knvirnnmpnl-al1y Safp D-laptiHal^
(See notes which clarify or show objection to some of the following points
A. The cost of what each one does would be born by the doer.
B. What each one does "for the environment" rather than "for his
business" should not necessarily be taxed.
C. For known and established hazards known realistic requirements
should be established.
D. Persons that may have unknowlingly ( reasonably unknowingly rather
than irresponsibly unkowingly) malacted should be given consideration
in the event of damages.
E. Once restrictions and hazards have been established then irresponsi-
bility would be more serious. However, we have to consider that
this is not a completely hazard free world. And that every day
every one is exposed to hazards. No one on this earth has been
given eternal pain free life.
F. Each par by should assume the costs of what he has to do to perform
his function in a (realistically) environmentally sound fashion.
This would then be reflected in his costs and therefore the costs
of his services. If alternatives exist, which do not involve very
high costs for proper treatment then the most environmentally and
economically useacle method will evolve in the competitive business
world.
But it should be borne in mind that changes and adaptations cannot
be made with every "change of the wind" and realistic long term
evolution has to be programmed.
The great turn-around has already been made. While there is room
for continued improvement there is no need for unrealistic panic.
Notes:
* Point A. is subject to misinterpretation. One respondee disagreed
with A. But said "He who generates the waste must pay for its
ultimate safe disposal. Costs must be internalized". This is the
effect of "A"; if a generator subcontracts disposal, he will of
course have to pay the costs (and profit) of the subcontractor.
Though the costs are a carry through of the waste. The generator
still pays the total bill. (Or else someone along the line did
not know his costs, and will shortly go out of business if that
continues.)
** Point B. was objected to by some.
*** Point D. was objected to by some.
lid*
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3. A. For Which wastes/ if any, Should the Following be Required;
Some generalizations can be made but in most cases it would
be best to follow the procedures of 3B with guidance from 3C.
a. Recovery/Reuse
When ever possible.
b. Incineration (Combustion)
For obnoxious toxic wastes and especially when
energy can be recovered.
c. Chemical Treatment
If needed.
d. Physical Treatment
When possible.
e. Bio. Treatment
If adequate and considering costs and values.
3. B. For Which Wastes Should the Above be Prohibited:
In a brief response such as this we can only generalize and
leave the details to specific reports. The above treatment
processes should be applied in the following sequence.
1. Only thos processes which can produce dependable,
acceptable results.
2. The processes that qualify for point 1 should be
applied in the sequence that gives the most favorable
ratio of benefit/cost. Special emphasis should be
placed on conservation processes, such as: recovery/
reuse and combustion with energy recovery.
3. C. Process Types That can be Applied (* indicates, actually used)
We anticipate submitting specific processes for the specific
processes listed under 3.A. These will be forwarded at a
later date. • .. ., r.c
llbb
-------
4. WHICH PRACTICES HAVE BEEN ESPECIALLY SUCCESSFUL FOR WHICH
PARTICULAR WASTES:
(These are being tableized in the response for 3.C.)
5. WHAT COST DATA ARE AVAILABLE FOR ABOVE
Cost data is available and can be up-dated for practically
all of the above.
6. A. What are Minimal Safety and Security Precautions for Treatment,
Storage and Disposal Sites;
Treatment; Should comply with established regulations.* Specific
personnel safety has to be left to proper operating
procedures in each particular plant.
Storage: Sites should be properly controlled * so as not to
exceed the exposure conditions of the material,
assuming the exposure conditions have been listed
as recommended in other sections.
Disposal: Disposed materials should be properly treated
so that they do not present emminent hazards,
contemporarily or in the future. Materials that
cannot be realistically treated at present should
be **contained and stored in such a way as to be
safe for the long term and treated, or recycled
at some future time when the technology or capa-
bility is available.
* There appears to be a preference for state and local
control, except for radioisotopes which should be under
federal control.
** This statement is to be interpreted that consideration
should be given to possible future treatment. However,
the disposal system chosen should be adequate to cover
the assumption that the storage may be "forever".
6.B. Which Are Required for Environmentally Sound Management;
All.
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7. What Provisions for Site Monitoring, Record Keeping and Reporting
are Needed to Insure Integrity;
A. Site monitoring procedures have to be established lor
particular types of facilities and can include ambient
air measurements, sub-surface water monitoring, as well
as normal esthetic requirements.
B. Record keeping should cover any of the items established
above plus a log of quantities and form, (in and out) of
specific known hazardous substances.
C. Reports to regulatory * agencies should be mandatory when
quantities or concentrations approach within certain limits
of hazard violations.
* There was a preference for control by state &
local government.
8. What haa Been Availability and Price of Insurance and Other
Mechanisms to Reduce Risks of Operators at HW Management Facilites:
EPA should have data on this
9. What are Requirements for Long Term Integrity of Closed and
Operating HW Disposal Sites;
A survey and open record should be made * of all existing
(whether operating or closed) disposal sites. These should
be categoried as to content and possible hazard type. Future
land use should be governed by those findings and the findings
should be made easily available to those that are, or may
become, responsible for the land use in and around the disposal
site.
Present disposal sites should be classified as to type and
required treatment and operation.
Future sites should be carefully regulated with respect to
materials handled, treatment and method of disposal.
* Preferably by each state, with records open to all.
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10. What Methods are Available Regarding Setting Limits on Amounts
if H.W. to be Emplaced;
Proper operation of 9. above, would cover this adequately.
There ia a preference to contain the really bad wastes in
a few adequate sites rather than dispersing them to may sites.
11. Are Existing Transportation Regulations. Sufficient to Cover
H.W. as Distinguished From Substances;
(These are preliminary suggestions only)
Transportation regulations should require the external listing
on containers of hazardous materials. This along with proper
marking regarding exposure limitations would then give auto-
matic coverage for hazardous materials regardless of whether
they are called substances or wastes.
An item that is transported by non-agents of the shippers
(those that may not know of the hazard) and/or -to non-agents
of the shipper shall have noted on the container exterior the
"usual exposure" restrictions.
Usual can be considered to be 0 to 180°F.
The label should state whether restrictions are for hazard
prevention or product quality.
For items that would be hazardous at normally obtainable
conditions, say 110°F shipping container exterior should
be color coded:
Yellow for shock
Red for temperature
With each color approximately 20% visible on container surface.
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12. What Labeling Should be Used;
Labeling should list type of potential hazard and the exposure
conditions that may trigger a hazardous condition.
In some important cases such as strong chemicals, brief do's
and don'ts may also be desirable.
3. What Damages/ Investigations of Improper H.W.
We presume the EPA has these listings. Coverage of these instances
should be included in the state regulations.
.4. What is needed for Citizenry Acceptance of H.W. Management Facilities
A. Most will realize that some facilities are required.
B. Most will acknowledge that those that exist have to be regulated.
C. The main sensitive question will be which, and where.
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15. What Federal Facilities Generate What H.W.:
This is best answered by a survey of those facilities. Many will
be the normal types of waste from small facilities such as
munitions, gases, radioactive, etc., should be handled as listed
below.
16. How Should the Private Sector be Involved in Treatment and
Disposal of H.W. Including Federal Facilties;
A. The private sector is and should be involved in treatment
and disposal with proper controls.
B. The private sector is and should be used for treatment
equipment and services.
C. For specifically hazardous materials such as munitions,
gases, radioactive wastes? Government Storage and disposal
sites properly documented should be used.
D. As in other environmental matters, it is suggested that the
EPA establish guidelines (because of its vast data base) with
regulations to be submitted, and adopted fay the states.
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THE CHAIRMAN: Will you answer questions?
MR. KRONEBERGER: Sure.
THE CHAIRMAN: Any questions?
Mr. Lindsey.
MR. LINDSEY: Mr. Kroneberger, you indicated that lists
of wastes and processes and costs and so forth are being
prepared now.
Will it be possible to submit them as part of the
record — that is, before the end of January?
MR. KRONEBERGER: Some of them before January,
certainly.
MR. LINDSEY: That would be very helpful.
You indicated that one of the crying needs that you
saw that we — that is, EPA — might be able to help you out
with is to summarize the data and information which has already
been accumulated over the world, I guess, and to do that by
choosing a group of high priority hazardous substances and
pool this information together in that way.
Did I understand that correctly?
MR. KRONEBERGER: Almost. We are saying we have to
summarize what information we have, rather than make a
predetermination on what information we are going to try to
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summarize. In other words, you have a lot of information in
your category of solid waste, hazardous wastes right now. Let
us get summaries of categories so that we can find a solution for
a specific thing very fast.
Now, we as chemical engineers have a lot of these.
You have more than we have. I think that the categorical
summaries are what is needed, evaluating those. Then with
input from health hazards and what all, you can say which of
those can be then really pushed.
MR. LINDSEY: We have had some comment on that approach
in that waste materials are seldom substances — well, they are
compounds or conglomerations of a lot of materials. If we were
to put this together along the lines of, let's say, treating
arsenic or handling mercury or whatever, would this be useful
in the handling of wastes?
MR. KRONEBERGER: Certainly. We do have to categorize
the process system that will minimize if not eliminate the
hazard of a certain material. Then we have to categorize the
wastes we have and how we collect them.
One of the other points in my statement was that shortly
we should go through the chemical plants themselves, go back
in their process and minimize that right at the source, as was
mentioned by other speakers here.
So there are any many categories that have to be
approached.
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THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: Mr. Kroneberger, I was interested in
the comments that your panel or committee endorsed a number of
responsibilities for the generator, the treater and the intended
disposer of wastes, including characterizing them and so forth.
And I would imagine that a number of your members represent
industry as well as other sectors of our economy. So do I read
that as an endorsement of the costs involved to do that, that
when you compare that with Dr. Collins1 comments about expenses
MR. KRONEBERGER: We are saying that a person, one, should
know what he is doing. Two, the common American system right
now is, your coats is what you do, and you try to sell it for
what it is worth.
If you have to do something to do your job properly,
that cost is yours. Your reason for existence is that somebody
wants your service that you are performing.
MR. KOVALICK: If I can follow on that, there were
some comments in our other sessions that those who are less
responsible than the kind of people you are talking about are
not motivated to do things that cost more if they are not forced
to do it.
Do your committee members feel that would not put them
at a distinct disadvantage?
MR. KRONEBERGER: The Institute, and especially the
U~j •>
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Environmental Division, is made up of chemical engineers that solve
problems, both environmentally — that is,made up of people who
run process systems who perhaps might be considered as causing
the problems, citizens — chemical engineers that are in matters
not related to hazardous wastes. So it is a broad spectrum.
Of course, we did not poll every single member, but I
think the responsible position is that you do what needs to be done
and if you are not a responsible person, this is the reason for
regulations.
THE CHAIRMAN: I think we have some questions from the
audience that are coming.
Mr. Kovalick, do you want to take that?
MR. KOVALICK: From the audience.
Did we understand you to say that some generators feel
they should not absorb all costs?
MR. KRONEBERGER: No. Well, when you say "all costs,"
we assume all of their costs.
MR. KOVALICK: For proper environmental disposal?
MR. KRONEBERGER: Right. The point of disagreement
came more on interpreting different statements. We are saying
if you have a waste that needs to be disposed of, if you do give
it to a treater or a transporter or whatever, he is going to
charge you for that. So the charge to you is actually going to
represent his costs, which are the costs of this disposal.
Right.
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THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: I have a question here from the audience.
As a chemical engineer, in your opinion, what fraction
of large volume waste streams, directly from industrial
processes, are not irresponsibly mixed in sumps, et cetera,
by the producer?
MR. KRONEBERGER: I could not begin to give you a
number on that.
MR. LINDSEY: Okay. Thank you.
THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: Thank you. If I could clarify one
of the points you made, perhaps it bears reading also, about
labeling and transportation of hazaroud wastes. I did not quite
get the gist of your comment. What I thought I heard was that
there was a need for better labeling of waste materials. You
mentioned some color coding, or would you say you felt it was
sufficient?
And, of course, we are not particularly interested in
the transport base; we are primarily interested in labeling at
the treatment side.
MR. KRONEBERGER: Right. I read an abstract of a
statement which said in more detail that when a generator is
transporting material on his own trucks and the party that is
transporting it is to receive it all know what it is, that that
is their own in-house business.
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And what we did also was sav that it could be a
hazardous substance. In other words, we are not saying this
should only be for hazardous wastes, because why determine at
one point whether it is a material or a substance or a waste.
A hazardous material, if transported by means that are
a separate agency where the people handling it might not know
what that is, that it is hazardous, then if it is — it is
pertinent if they cannot store it at 150 degrees or if it is
exposed to 150 degrees, all of a sudden you are going to have
a problem — it should be obvious to the person having the
possession of that that there is some concern.
Now, granted, you cannot write a book on each shipment,
but you should have some simple alerting signs saying special
consideration is required.
THE CHAIRMAN: I believe that is all the questions.
Thank you very much, Mr. Kroneberger.
MR. KRONEBERGER: Yes. Thank you.
THE CHAIRMAN: Our next speaker on our list specifically
asked for a time of about 11:30 this morning. It is a little
early. But if he is here in the audience, we would take his
appearance now.
Mr. Tom Torlakson of the Sierra Club. If not, we will
return at the time he requested.
I would next call on Mr. Don Degruchy from Lockheed
Missiles and Space Company.
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MR.DON DEGFDCHY: Mr. Chairman, panel, ladies and gentle-
men. My name is Don deGruchy I am with the Lockheed Missies
and Space Company Waste Systems Group, and my comments today
are going to be quite brief and very simple. And I would like
to qualify the "simple."
I did not know, I still do not know in total who I am
addressing today, and I wanted my discussion of what can be a
fairly technical topic to be simplified to the point where any-
body, irrespective of their background, can take away with them
an understanding of the process's capabilities and perhaps the
problems that it purports to solve.
My purpose here today is to acquaint you with a
technology advance — not new technology — which has direct
bearing on the problems which concern you and ultimately all
people. My review of past meetings indicates attendance
largely by people, organizations and agencies who are concerned
with the safe disposition of toxic and hazardous waste. You are
voicing your concerns in this public forum. Lockheed is
concerned as well and has expended considerable amounts to
develop a technology which can do something about the problem.
It is my intent today to simply acquaint you with this process,
describe it in very general terms to enable you to understand
how it works and most importantly tell you what it does, which
distinguishes it from other treatment alternatives. In all
candor it is equally important that I tell you what it cannot do,
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and I intend to do just that.
The process is known as wet oxidation. It consists of
a flameless combustion or oxidation which takes place in the liqui 1
phase in a water waste stream. It occurs naturally in nature.
For example, the rusting of iron in water is oxidation. This wet
oxidation process hastens and enhances that natural reaction by
means of elevated temperature and increased availability of
oxygen.
Let me describe briefly the sequence of events so that
you can appreciate that the process is simple and safe. A waste
stream containing organic wastes and water is pumped to an
elevated pressure, pressurized air is added as the source of
oxygen, and the stream is heated to operating temperature to
accomplish the oxidation. Pressure is required to keep the
water from boiling at temperatures of 500 to 600 degrees
Fahrenheit. Oxidation takes place in a matter of minutes, and
the organic material is either burned, i.e., destroyed, or
rendered non-toxic — and that is an important factor — by
virtue of changes in the chemical composition of the toxic
compounds. Heat is then transferred to the incoming waste in
order to both heat up the influent material and cool down the
processed waste. This both conserves energy and prevents
thermal pollution.
Now that is basically the process. I would be glad to
discuss it in greater detail with those who are interested, but
nvo
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I think only that amount of detail which I have presented is
appropriate for the moment.
Of primary interest to you is "what can it do?" What
kinds of problems can it solve?
Let me first qualify my subsequent statements by saying
the process will treat all organics in all concentrations in
time, at varying rates. However, the situations which I will
identify are only those where it fits best, is practical and
has reasonable economics associated with it.
The process is useful only on organic materials —
that is, material composed of organic compounds. And it must
be used in association with an aqueous or water-based stream.
Ideally, these materials should be dissolved in water. For
economic reasons the process favors higher organic concentration
typically one to seven percent, lower flow rates, five to five
hundred gallons per minute.
I want to stress again that I am citing ideal operating
circumstances and not the limits of the process. Deviation from
the numbers I have given you can be accommodated by many simple
engineering techniques — surge tanks, dilution and so on.
All right. Now, you know how the process operates
and the regimes in which it operates best. Now what can it do?
Toxic materials have long been hidden or stored by
such means as deep well injection, landfill and dumping at sea.
These are not destructive processes, and toxic characteristics
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still exiist and no one can predict when they will reappear to
present a problem by means of infiltration of the deep well
material into the water cycle, leaching from the landfill or
accumulation in large water bodies. The wet oxidation process
would have destroyed these materials — changed them from toxic
or hazardous compounds into carbon dioxide.
The other elements in the compounds are released as
salts of nitrogen sulfur or phosphoric which are generally not
harmful,and in any case could be collected if so desired as
useful material. Chlorine in organic particles is converted to
chloride of which the sea is naturally full. Cyanide is
converted to carbon dioxide and nitrogen.
Another important economic feature of the process is
that without complete oxidation and in a much shorter time only
partial treatment of toxic organics results in a non-toxic
biodegradable effluent.
This last feature would enable a relatively small wet
oxidation plant to convert a toxic waste stream into a non-toxic
biodegradable stream which could be processed either in municipal
plants or even spray irrigated to degrade naturally on the
ground, not unlike organic fertilizers.
I did promise, and it is equally important for you to
understand that the process does not solve all problems. It,
like most other processes,is not a panacea. It does not
significantly affect inorganic materials. It has, except for
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a few instances, no effect on metals in the waste material. It
must know beforehand what it is treating so it can assure the
achievement of adequate treatment objectives.
Let me quickly list a partial summary of the types of
materials for which it is known to be very effective: cyanide,
phenols, herbicide, pesticide, toluine, vinyl chloride, xylene,
formaldehyde, dye waste, coke still water, explosive waste, PCB,
amines, alcohols.
And I could go on.
I think in closing I should clarify one question which
may have occurred to some of you. How is this different from
incineration, which is also an oxidation/combustion process?
It is different in several important respects.
First of all, you will recall that we are working with
an aqueous waste stream, not solids.
The process is controlled and oxidation can be
terminated when it is no longer required.
Two. It produces no air pollution. It is in effect
self-scrubbing.
Three. It is a lower temperature process, typically
5 to 600 degrees Fahrenheit as opposed to 1000 to 1500 degrees
Fahrenheit, therefore corrosion is more readily controllable.
Four. Because the water is not vaporized it is
conservative in the use of fuel, and therefore less costly to
operate.
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And in closing, finally, I do not mean to be commercial,
but for those of you who would like additional information, I
have some literature here in the form of a brochure which I
will leave in the lobby, or I, would be glad to talk to any of
you when it is appropriate.
And I am willing to answer questions if there are any.
THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: Mr. Degruchy, first of all, let me urge
you, if you can, to submit supportive data for this information
if you have it. It would be helpful to us — tests which have
been run, results and so forth.
If that could be given to us in writing, we would sure
appreciate it.
MR. DEGRUCHY: Fine. I think I can give you curves
which will show you what you might be interested in.
MR. LINDSEY: Fine. That would be good.
Could you give us some information on the economics of
the process compared to the other alternatives such as
incineration?
MR. DEGRUCHY: Let me not get into someone else's
domain too much. As to the other alternatives, I can give you
the economics of this process, and they will be general figures,
just as guides.
Typical processing costs — that includes, now, the
power for operating the pumps, compressors and heaters and so on
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and so forth, labor, insurance, depreciation and so forth —
typically run about one-tenth to one cent per gallon.
Capital costs are to a large degree a function of
hydraulic flow, but they vary very widely with the treatment
objectives and so on. But you are talking about systems that
are at least several hundred thousand dollars in scope.
MR. LINDSEY: Along the same lines, the processes used
— and I believe I am speaking correctly — vary widely for
treating sewage sludge materials. Is it possible also to destroy
a variety of hazardous materials along with sewage sludge in
this same facility?
MR. DEGRUCHY: I guess I would say — and I would
assume you are talking about organic hazardous materials —
MR. LINDSEY: Yes.
MR. DEGRUCHY: It depends largely on how the sludge
processor — and we do not — would elect to employ the system
— the operating parameters, residence time, et cetera. The
objective is quite different from our objectives in using this
process.
As I said, it is not new technology. We are working it
for a different objective. Sludge treatment has traditionally
\
been for hydrolysis, for de-watering and subsequent sterilizatior
— not complete oxidation, which we are after in some cases.
MR. LINDSEY: So it takes a different set of conditions
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MR. DEGRUCHY: Probably.
THE CHAIRMAN: Yes, Mr. Lazar.
MR. LAZAR: Mr. Degruchy, in our public meetings in
Chicago last week a gentleman who represented the explosives
manufacturing industry told us about the big problems incurred
in getting rid of explosive wastes. And he said that open
burning seems to be the only available alternative.
And I would like to ask you, could the wet oxidation
process be used to get rid of these explosive wastes, and to
what extent, and how safe is this?
MR. DEGRUCHY: Let me qualify the answer in several
ways.
Broadly, the answer is "yes."
For most explosives you are dealing with solid materials
In many instances they are relatively insoluble. If the material
is not soluble in the water stream, which I presume it must be
in, your oxidation is going to be inefficient.
If, on the other hand, you have explosive wastes such
as the TNT production red water wastes, it is a good candidate
for that. And as far as the safety goes, it is quite safe.
There is no means to detonate those kinds of things. You control
the concentration of things you are putting in such that even
in the case of open deflagration, you do nothing to your
temperature-pressure situation.
THE CHAIRMAN: Mr. Mausshardt.
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MR. MAUSSHARDT: I have a question from the floor, and
I would like to follow it with a broader question.
MR. DEGRUCHY: Fine.
MR. MAUSSHARDT: Must the waste product be soluble in
the water, first of all, or can it appear in some other medium,
such as in organic solvent or in some other semi-liquid state
possibly?
MR. DEGRUCHY: There are limitless answers to that
question.
Ideally, it should be dissolved, however, some solid
materials can be hydrolized by the process and subsequently
dissolved in the stream that came in as solids.
As far as solvents, they will be affected on the
assumption they are miscible with the water and the fact that
you will get oxygen transferred to the materials as opposed to
a bubble of this material.
THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: I have a question here from the audience.
Is the process termination immediate? That is, doesn't
it require a general lowering of oxidation by a general lowering
of the temperature?
MR. DEGRUCHY: The temperature is lowered gradually.
I did not dwell on it, but the heating of the influent material
and the cooling of the effluent material does take place in the
heat exchanger. Now, obviously, there is a passage of time
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during which the material flows through that.
We seek rather efficient heat exchange to the point
where Delta T of, oh, say, 30 degrees would be expected, and
the material would be cooled in that heat exchanger. But it
is gradual.
THE CHAIRMAN: All right. I believe we have one more
question that a gentleman is preparing now.
Mr. Kovalick.
MR. KOVALICK: Perhaps I could get you to comment
generally on the use of your process for the non-sewage variety
of treatment in this country.
Is it widespread?
MR. DEGRUCHY: Is it being used widely? If it were,
I'd be out selling it and not here today trying to tell you
about it.
(Laughter.)
No, it is not. As long as we are waiting, I will
digress a bit and tell you why a missle or an airplane company
as we are commonly known is in this game at all.
One of our product lines is space activities, and in
that vein we got into life support, and in the life support
area we developed a technology utilizing wood oxidation for
the reduction of human waste to potable water.
In being acquainted with that process over a period
of in excess of ten years now, only relatively recently did we
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feel that it has application to the chemical industry,
particularly the chemical industry.
We have worked for not quite two years on trying to
find adequate applications. We made many wrong ones. Now I
think we have gotten it down to the point where we know where
it does fit and we can eliminate the broad contenders. And we
are working closely with several chemical companies in the
proposal stage where we will have a system in, I hope, by the
next time you have a meeting.
THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: Yes. This is a question from the
audience.
Homogeneous catalysis of industrial liquid phased
material is a well-established technology. Has catalysis
been investigated for wet oxidation of waste — I guess in
conjunction with your type of ...
MR. deGruchy: Yes. We avoid it when possible. It is
an added expense. In some circumstances where the maximum
temperature and maximum reasonable residence times will not
give you adequate achievement of whatever your treatment
objective is, we will employe catalysts, both homogenous and
heterogeneous. We prefer the heterogeneous, because with homo-
geneous you start having to take metals back out of the waste
stream, which is an added step. But they are both effective.
THE CHAIRMAN: Mr. Bourns.
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MR. BOURNS: I have a question here from the floor.
What would a typical retention or flow through time
be for waste, say, cyanide?
MR. DEGRUCHY: Cyanide reacts quite quickly, and of
course that is dependent on concentration and your operating
parameters, but you are talking about something significantly
under ten minutes.
THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: One more from the floor.
Is your oxidation from atmospheric oxidation, can it
be super charged by another oxidant such as hydrogen peroxide?
MR. DEGRUCHY: You asked the one question I cannot
answer, because we have not tried it.
Let me say in general terms we have used chemical
oxygen additives, not hydrogen peroxide in this case.
It does in some certain circumstances enhance the
process.
Let me further answer a question that you did not ask,
and say that were we to use pure oxygen or oxygen enriched air,
does it help? It does not enhance the process. It does reduce
the pumping requirement to compress so much gas to put it into
the system, so there are economies there, depending on what
you have to pay for the oxygen.
THE CHAIRMAN: Mr. deGruchy , I believe that is all of
the questions.
Thank you very much, sir.
MR. DEGRUCHY: Thank you very much.
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MISSILES
& S P A C E IT December 1975
COMPANY.
INC.
United States Environmental Protection Agency
Office of Solid Waste Management Programs
Washington B.C. 20k60
Attention: Mr. John P. Lehman, Director
Hazardous Waste Management Division (AW-^65)
Gentlemen:
At your request, subsequent to the Lockheed wet oxidation presentation
at your hearing in San Francisco on December 11, 1975, I am submitting
additional data regarding the capability of wet oxidation to treat toxic
and/or hazardous wastes.
The material enclosed is in the public domain and not sensitive as proprietary
in any manner. Much additional information is on hand in our files and can
be used for personal discussion. However, since each stream and the data
pertaining thereto is in essence the property of a private client, we are
obligated to restrict the written dissemination of that data.
I recognize that the enclosed data is not wholly complete. Details as to
flow rates, residence time and cost are missing. I would like to suggest
the following in order to provide you with definitive information regarding
the performance of the process for any specific material or waste which may
be of concern. If you can obtain prior permission (in writing) from a respon-
sible party who is the source of a problem waste stream to share with you
detailed test results, we would provide on a specified distribution basis the
following information at no cost to the waste source or the government:
1. Test results showing COD, TOC, or BOD[- removal with time under
various operating conditions.
2. An analysis of the detoxification of the waste including a
bio-assay if appropriate.
3- A specification detailing component size and cost, for a
total capital cost estimate.
k. Estimated operating cost based on the test results.
BROCHURE DETACHED AND RETAINED
IN SOLID WASTE MANAGEMENT FILES
1189
A SUBSIDIARY OF LOCKHEED AIRCRAFT CORPORATION
1111 LOCKHEED WAY • SUNNYVALE. CALIFORNIA • 94088
-------
Lockheed Missiles & Space Company, Inc.
Page 2
In order to provide you with this test and economic data we would require
only a five gallon sample of the waste stream and information regarding
the character of the waste and treatment objectives.
Should you have an interest in pursuing this offer, you could call me at
lK)8-7^2-6202 and I would be glad to discuss the arrangement. I believe
that is the most effective way to provide you with meaningful technical
data which you have requested.
I want to thank you for the opportunity to speak at your December llth
meeting. I would very much like to receive a copy of the Proceedings.
Very truly yours,
LOCKHEED MISSILES & SPACE COMPANY, INC.
D. C. deGruo
Manager Waste Treatment System Marketing
DDd:jal
Enclosure
D. C. deGruchy
Lockheed Missiles & Space Company
Dept. 50-20 Bldg. 151
P.O. Box 5CA-
Sunnyvale, Ca.
1180
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THE CHAIRMAN: Next I would like to call upon Mr. Tom
Torlakson of the Sierra Club.
Mr. Torlakson, will you accept questions after your
statement?
MR. TOM TORLAKSON: Yes.
I am chairman of the Mount Diablo Regional Group of the
Sierra Club and speaking here today representing our regional
group.
I would like to illustrate some of the problems of
hazardous waste disposal and point out Sierra Club concerns
in this area by referring to an open pond evaporation dump for
liquid waste adjacent to the City of Antioch. It is the city I
live in, and I have had personal experience with the operation
of the dump and the problems with the administrative agencies
dealing with controlling and regulating the input of materials
into the dumps and the air pollution problems that result from
that.
For several years this industrial waste site has been
operated on a 60-acre site with about a half dozen ponds
receiving much of Contra Costa County's toxic wastes including
heavy acids, heavy metal solutions, referinery sludges, et
cetera.
As the City of Antioch expanded, the odors emanating
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from the ponds became an increasing nuisance to the new homes
and the residents in those new homes.
From the mere annoyance of the acrid smelly odors, the
problem took on dimensions, more serious dimensions as home
owners noticed evidence of corrosion to paints, aluminum and
metal fixtures on their homes.
Now, the prevailing wind in the area happened to blow
the fumes and odors evaporating off from the ponds into the
adjacent neighborhoods. Some of the neighborhoods were as close
as 300 yards. Some, which still suffer severe air pollution
problems, were within about a half-mile away.
At times the local residents had further apprehensions
and concerns concerning their actual health and safety. The
airborne chemicals were actually corroding metals and damage
might be done to one's lungs or to one's body by having been
exposed to these chemicals.
From the nuisance of not being able to enjoy one's
dining room or patio in this area in these neighborhoods from
having to keep one's windows closed at night on hot summer
nights when the fumes were evaporating off the ponds and driftinc
into area — there were further annoyances and problems with
actual eye irritation, throat irritation, congestion in the
throat — complaints of physical distress by residents in the
area.
Fairly often people could observe visible emissions,
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visible fumes, coming off from the ponds after a particular load
from a truck was dumped into one of the ponds.
Several small fires occurred at the site during the
early '70's. And in 1973 a larger fire and accompanying explosion
busted open some containers labeled "beryllium."
This was a scare to the local residents and fire
officials. It was never determined for sure if the beryllium
escaped into the atmosphere and was airborne into the neighbor-
hoods.. But, again, it illustrates the type of problem that can
occur in these types of sites.
The Sierra Club had an additional concern regarding
the danger to wildlife. The City of Antioch is located where
the Sacramento-San Joaquin combine. And this is a part of
the Pacific flyway. A lot of water fowl flying back and forth.
And we received reports that water fowl were landing in the
ponds and being gunked up by the chemicals and killed this way.
The problem which I think that would be most interesting
to this forum is the problems the citizens had in dealing with
what regulations were required of this operation, what could be
done about the problems they were suffering.
First, phone calls to local police didn't come up with
anything, because that was outside of their jurisdiction.
The City Council would not help, because it was out-
side of the city limits of Antioch. It was just adjacent to the
city" limits.
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The District Attorney couldn't help, even though we
could point out the certain regulations that did not seem to be
met.
Then there were the two regional agencies which could
have been helpful, and which had jurisdiction over the problem.
One was the Bay Area Pollution District. And here at this time
one of their major tools was that public nuisance — this was
a very hard type of problem to define, just how many people are
being annoyed. What is the extent of a nuisance; And how do you
take legal action to resolve such a problem.
The other district which had the primary interest and
regulation was the Central Valley Water Quality District.
The county originally let out permits for garbage for
the site -- just a simple garbage permit. Then the Regional Water
Quality District set up classification standards and began to
review different sites throughout California and give them
Class One, Class Two sites — designations.
Well, Central Valley Water District determined that
this particular site would not meet Class One or hazardous
waste standards, and only issued a Class Two permit for regular
garbage. However, they kept on extending the cease and desist
order for the operation of this dump, at which time the residents
continually trying to get their problems heard by different
agencies, trying to get it resolved, formed a group to take lega]
action against it, the dump owners.
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Once this legal action was taken and publicity
generated on the subject, a cease and desist order was finally
upheld as of January 1st, 1975. Bay Area Pollution had been
holding back from getting involved, because they said another
agency was in charge, the Central Valley Water District. Yet
at this point they also stepped in and did some pioneering work
defining what is a public nuisance and held some hearings to
try to get to the bottom of the problem and how to solve it.
Consequently, standards were worked out with the
operator throughout these hearings, which were quite lengthy.
The chemists and the engineers from the industrial waste
facility met with chemists and engineers from Bay Area Pollution
and the Central Valley Water District and together worked out a
plan for closing such a site down. And I think this is another
concern, area of concern, that the Environmental Protection
Agency should look into is what kind of standards you should
set up for closing down such facilities that contain potential
caustic and poisonous susbstances.
In this particular case each agency was running around
trying to find out what do you do, because there is no -- were
no standards at that time.
The procedure that was finally adopted was one of
skimming and draining one of the most toxic ponds and filling
the other with garbage.
Again, this is sort of a pioneering stage of the game.
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We are not. sure how this is going to eventually resolve the
problem. There are still odor problems — not anywhere near
as severe as they were before to the local residents.
We had a fire in July with flames 100 feet high or
so — this is after six months after the closure of the site --
where the garbage either was still smoldering and combusting
itself and was fed by methane gas from the decomposition of
the garbage plus chemicals that were in the pond.
So you can see that there are multiple problems
involved with such an open pond evaporation system. And it is
the opinion of our Sierra Club group that it is a rather
primitive method. It is a much better a method than letting
these toxic substances go up stacks or out into the water. But
there are alternative methods we feel should be looked into
and required, either closed types of systems or recycling to be
encouraged. And hopefully some standards and regulations will
be set up in this direction.
Unfortunately, when the local citizens were handling
the problem and trying to deal with it at that time, AB 598
was not in effect. This, however, we feel is a landmark piece
of legislation which does require some type of standards for
dumping so that you have compatibility of materials going into
the pond so you do not have explosive reactions; you have
plans and procedures developed for actually closing down these
particular types of industrial waste facilities.
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So we would hope that the Environmental Protection
Agency — Congress would develop some kind of regulations and
standards which would help other states in the United States
protect and handle this type of waste facility.
One problem that may have been brought up by the person
from Zero Waste Management is the fluctuating price of different
types of toxic chemicals and acids and so forth in fluctuating
markets. And perhaps government support of prices would be
helpful here, so that it will be cheaper to recycle materials
and sell them than to dump them in an open pond system or to
just dump them into a water system.
That is the conclusion of this background.
I think these various problems as you see the citizen
groups trying to find out who is in charge — well, now, under
AB 595 the Public Health Division is sort of coordinating —
California Health Division — is sort of coordinating the
development of standards. And the administration of these
standards hopefully, there will be some enforcement strength
added to their administrative ability.
THE CHAIRMAN: Thank you, Mr. Torlakson.
Do we have questions?
Mr. Bourns.
MR. BOURNS: Mr. Torlakson, you mentioned or passed
over a very important point that I think I would like to have
you speak to further, and that is concerning the particular site
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in question is one which is facing us across California — the
same kind of question.
Which was there first, the disposal site or the new
development? And should zoning have separated the two so that
you would not have the conflict between the citizens and the
disposal site?
MR. TORLAKSON: As I mentioned, the disposal site
was there first. I think this is going to be a problem. As
urban areas expand and move out to where these sites were
located, you are going to get this conflict.
And, yes, there should have been some regulation of
the zoning or some forethought on the part of the — maybe the
developer or the City Council involved.
THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: It was not entirely clear in your
statement — was the owner of the site the one who paid for all
of the corrections that you described — that is, the draining
and the — I presume that that was taken somewhere and disposed
of?
MR. TORLAKSON: Yes.
MR. KOVALICK: What was the amount of that?
MR. TORLAKSON: I do not hare the cost figures on that.
It was several hundred thousand dollars, I'm sure, to close the
site. It is not a cheap operation at all.
THE CHAIRMAN: Mr. Lazar.
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MR. LAZAR: Mr. Torlakson, could you tell us, has any-
one analyzed the air as to the toxic constituents, and what type
of pollutants have been identified in the lab report?
MR. TORLAKSON: Bay Area Pollution did set up some
monitoring sites at different times, but did not come up with
hard-core data. Part of the problem is that when you have some
of these caustic reactions or explosive reactions where fumes
were emitted, this would be in frequent points. In other words,
after you dump a load residents in the area would see the fumes
coming up, but the equipment was not there to monitor it.
I believe some samples were taken of metal in the
area and chlorides and nitrates which may have been a result
of acids that were airborne or something to this effect -- I'm
not a chemist. But the main opinion that the Bay Area
Pollution based their hearing and procedures on was the public
nuisance.
I understand since the closure and since the hearings,
tney have developed new tools and regulations regarding visible emissions
and organic emissions which give them more of a handle on being
able to go in and quantify what is going on and say, "Here's
a problem. You have to meet these standards."
MR. LAZAR: Have any organic substances also been dumpec
there?
MR. TORLAKSON: I believe materials from the paper
mills and this type of material, organic material, would have
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been used as fill material.
They are using municipal garbage from nearby cities,
and I believe they are also using solid waste garbage from
industries in the area.
THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: Question from the floor.
Was the dump owner willing to purchase the land adjoin
ing his dump? If not, is it not an example of public subsidy
of the dump site.
I am not sure I understand the last part of it.
MR. TORLAKSON: No. They had approximately a 60-acre
site, and the residential areas leap-frogged and moved closer.
There was quite a confrontation between the citizens and the
owners of the site, because they were looking at it from two
different sides. And the owners, of course, would say the
citizens shouldn't have moved into the area. The citizens said
somebody should have warned us before having moved into this
area where there was this potential problem.
But, no, the owner did not offer to buy the land.
THE CHAIRMAN: Well, I believe that is all the questioi
that we have.
Thank you very much, Mr. Torlakson.
Next I would like to call Jean B. Siri of the
West Contra Costa Conservation League.
MS. SIRI: It is a pleasure, gentlemen. I did not
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expect to be on until this afternoon late because I failed to
get ray name on the list.
We are very grateful to you in our part of California
for holding this hearing in our area, because we believe it is
one of pur most grievous problems.
You have heard Mr. Torlakson speak on the problem,
and it is a growing one for us with no real solution in sight.
We urge you to help us with this problem. We live in
Contra Costa County, surrounded by oil refineries and their
satellites. We have 80 percent of Northern California's
hazardous industrial waste in Contra Costa County. We are
about — supposedly — to get two new plastic plants and a new
large refinery or possibly two. We already have five
refineries in the county, one being tremendously large, Standard
Oil of California.
We in the Air Bollution Authority live in fear of
disastrous explosions and fires. We expect the barrel storage
to go. No one knows, especially the operators, what is dumped
and what is buried in the sites. We suspect that the high
tides flushing areas of hazardous waste is the reason for the
absence in the ten years of larva crab in San Pablo Bay as well as other
valuable resources in the San Francisco Bay.
The State Solid Waste Management Board, after hearings
around the State of California, has concluded that we need
more Class One dump sites. That means to us more solar
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evaporation ponds.
We read this marvelous little booklet that you put
out which sounded like Dr. Palmer's presentation about the
wonderful chemical solutions to all our problems. And then we
read that you had just let a pilot project in the Midwest for
more solar evaporating ponds. We cannot live with the solar
evaporation ponds that we have with the hydrocarbon emissions,
the fires, et cetera.
The Bay Area Water Quality staff thinks that Bay mud
is just the ticket for these ponds because the clay is
impervious, and therefore it is geologically great.
Though California has excellent new regulations, they
are only that, u nless the enforcement and the funding for
enforcement is as good as the regulations — and they are not.
In the Richmond area the enforcement seems to be non-
existent, at least to date.
We do not believe the usual Class One operator is
knowledgeable enough to cope with the chemical problems he
is faced with. And we do not believe that any of the people
in the state are capable of handling the bootlegged material
that is either going in the sewer or is being dumped on the
ground or being handled in a regular dump site.
There must be some kind of an incentive to industry.
Our organization finds itself inclined towards a club approach
rather than a carrot. Industry must be responsible for more
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recycling or for the sale of industrial waste, or they must be
responsible for the disposal of same. It must become too
expensive to just dump on the ground where it poses a long-
term human and natural resource hazard.
My organization has worried for years about the dangers
to the employees at the dump.
We have heard from the wives saying they are in fear
for their husbands' lives from explosions and so forth.
And there is nothing we can do. There seems to be
nothing that Cal OSHA is doing about that. Everybody knows
that the most hazardous job in the world is the operators at
the dump sites.
And we worry about the truckers who haul the waste.
We have had some explosions in which the truck and the trucker
have disappeared.
There must be a better way than burying mountains of
valuable steel barrels full of hazardous mixed waste. There
must be some way to keep it and recycle it so the hazard of
hauling it through city streets — which happens in my
community all the time — and through the freeway is diminished.
Another extremely crucial problem in Contra Costa
County is that which you have heard from Mr. Torlakson of
local government permitting housing developments next to
hazardous waste .ponds. We now have the dilemma of people livin<
in the subdivisions and suing the hazardous waste people who in
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turn are suing them and the developer of the home, when the real
villain, we believe, who should be sued is the local governmental
authorities who permitted this proximity.
We like to think that it would be better handled, better
financed and controlled in a more scientific manner and through
enforcement by the Federal government handling the entire
hazardous waste problem.
It is very much like saving San Francisco Bay was for
us. At the local level it was a disaster. The state controls
are still not strong enough. But when we got the Corps of
Engineers to move with strong public support, the Bay stopped
disappearing.
We urge you to speedily help us with this problem.
The combination of industry, garbagemen, hazardous waste men
and local government is very difficult for the citizens in this
part of California.
Thank you.
THE CHAIRMAN: All right. Thank you, Ms. Siri.
Will you accept questions?
MS. SIRI: Yes.
THE CHAIRMAN: Do we have questions?
Mr. Mausshardt.
MR. MAUSSHARDT: I would like to restate a request
that if you have any information on documentation on these
explosions or trucks disappearing we would very much like to
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receive them.
Thank you.
THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: For the record, when you were speaking
about Cal OSHA, you were referring to the Occupational Safety
and Health Administration?
MS. SIRI: Yes.
MR. KOVALICK: Could you elaborate a little bit on
what your frustation has been there. Is it a matter of
insufficient enforcement or the lack of understanding of the
kind of site involved?
MS. SIRI: I am not sure. Contra Costa County has
an extremely high industrial health problem which we have not
been able to get much money spent on studying or much help from
the Public Health Department. And it seems to me with this
kind of record that Cal OSHA has not done much as yet. We are
hopeful that they will be able to.
THE CHAIRMAN: We have one question coming.
Mr. Kovalick?
MR. KOVALICK: This is a two-part question.
Would you repeat your name and affiliation.
And how many fires and explosions have occurred in the
past ten years?
MS. SIRI: My name is Jean Siri. I am the president
of West Contra Costa Conservation League.
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I cannot document all the explosions, although you
could get this from the Regional Air Pollution Board who have
records on this. With luck we see an item in the paper, or if
we inquire of the Bay Area Pollution Board we can usually get
the record.
But I know there have been a couple in the last year.
I know there was one where the truck exploded. A barrel fell
off the back when the gate went down. There was one recently
in the area in which an extremely toxic insecticide, I believe,
had been sent. It started at Shell Chemical and was to go to
an industrial tanks area in the south. And they refused to
accept it there and recommended it to be sent to the Nevada
Hazardous Waste, Radioactive Waste Site, because it was so
hazardous. But instead they brought it to my town of Richmond
and dumped it on the ground, and there was a resulting explosion
That was in September.
THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: I have a question from the audience.
Having worked on a resources recovery subcomittee at
the state level, would you comment on the potential and
feasibility for resource recovery and recycling of hazardous
wastes?
MS. SIRI: Well, I made a presentation to the State
Board hoping that since we had a committee on resource recovery
at the advisory council level we would study hazardous wastes.
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At the moment, as I understand it, most of the
authority has gone to state and public health. And state and
public health, as far as I know, is not into resource recovery.
So I was trying to get the State Board to take a great deal
more interest in this, and I hope that they will.
THE CHAIRMAN: All right. Thank you very much, Ms.
Siri.
Next I would like to call Major Wyatt McGhee — is he
in the audience — representing the Western Federal Regional
Council Task Force for Hazardous Waste Management.
MAJOR WYATT McGHEE: I am Major Wyatt McGhee from
McClellan Air Force Base representing the Western Federal
Regional Council Task Force on Hazardous Materials Management.
I will be commenting briefly on items 15 and 16 in
the announcement of "What Federal facilities typically generate
what types and amount of hazardous wastes," and, "To what
extent and by what mechanisms should the private sector be
involved in the treatment and disposal of hazardous wastes,
especiall those from Federal facilities."
We in the task force will be submitting a report
which hopefully we will have in draft stage before the January
31st cutoff date for written comments. We will make a point to
get the draft report into the group here.
I would like to go over some of the background
involved with the formation of our task force and why it was
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established.
Back in August of 1973 a large number of shipments of
retrograde cargo were coming back from the Pacific area from
the phase down of the war effort. These were materials that
had been stored outdoors in containers. For one reason or
another they had corroded. In.some cases there were defoliates,
pesticides which would no longer go into solution properly —
just a large amount of waste products that were hazardous and
did have to be controlled.
Many of these were retrograded into Okinawa and other
areas where they have now become a political problem. And they
are, of course, trying to find a suitable disposal site for
these types of materials.
Back in that time frame of August, '73, there were
several requests made to Mr. Bourns and others in the
Environmental Protection Agency here in Region IX to try to find
out what is the best way of handling this type of a problem
and how great a magnitude is this problem.
So they sent out a few letters to some of the local
Federal agencies within Federal Region IX which consists of
California, Nevada, Arizona, Hawaii and the Pacific Trust
Territories to see what kind of response they would get in
holding a little session to try to talk this thing over.
Well, they were inundated by requests to attend the
meeting. Yes, we do have problems. I think every military
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facility in the region responded with wanting to bring a
representative and their boss along to discuss the magnitude
of the problem.
So it ended up we had several hundred people responding
to this little round-table session.
Without any official sponsorship by any one particular
group, it was decided that we should have some official sponsor
to try to pursue our efforts of how big a problem is it and
what'are we going to do about it. So we did talk to the Western
Federal Regional Council, and they agreed to adopt the effort.
We did come up with a steering committee of about 15
people representing the various Federal agencies in this region
to try to lay out some objectives.
And I have a listing of what we have attempted to
address in our task force.
One, to provide a mechanism for technology and
information transfer relating to the management of hazardous
materials and in an environmentally safe manner for personnel
within agencies who have assigned responsibilities in this
area.
I might point out that at least annually we call
together our full task force of about 115 people now representing
over 35 Federal agencies including the military services,
and we do have at least an annual meeting. And at each meeting
we do set aside a part of that meeting for technology transfer.
>
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So that is one of the ways these objectives are being
handled.
The second work element here is to develop and maintain
a directory of individuals within Federal agencies who are
designated for contact regarding management of hazardous
materials and environmental matters. That directory has been
completed. It was put out by the Navy. It is into the second
edition now. It does let us know who to talk to within our
own region to try to solve some of our mutual problems.
The third work element, to develop an inventory of
excess hazardous materials and wastes including related
information pertaining to these which are in the purview of
these Federal agencies.
The inventory has been completed by the civilian
Federal agencies. Thirty-five civilian agencies were inventoried
They came up with quantities in the realm of about eight
million pounds, 350 to 450,000 gallons, and about 10,000
contaminated containers which were generated on an annual basis
by these Federal agencies.
The military services are also being inventoried. This
is being done on a national basis. However, we will be getting
the information broken out on a statewide basis, which is
being developed through the defense supply agencies, so we will
have that information available also for military in this region
The fourth work element was to identify, develop, and
1210
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
SAN FRANCISCO. CALIFORNIA 94102
TEL- (Jill 673 7747
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disseminate recommended plans of action for environmentally
safe management, transportation, storage, resale, recycling,
reuse, modification, and ultimate disposal of these materials.
One of the things that we have attempted to do here is
to inventory our existing capabilities for hazardous waste
disposal within this region. And we are now circulating a
questionnaire to each one of the facilities within this region
to try to put together an overall listing of what can we do
at this time.
I know on my own base we can handle four things which
were identified at the last meeting. We have a capability to
redistill and reclaim mercury. We have a capability to dispose
of waste acid, waste cyanide, and waste chromes.
However, of course, this is limited at the present
time to disposal of materials that are generated there on the
base, but we hope to be able to work out some type of
cooperative arrangement with the other Federal agencies.
The fifth work element was to explore and develop and
recommend courses of action to the council to manage hazardous
materials safely where problems are identified.
This may involve either recommending action to the
individual agencies concerned or implementing a multi-agency
cooperative approach.
One of the things we have attempted to do as part of
this item is to come up with a set of criteria for identifying
1211
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
SAN FRANCISCO, CALIFORNIA 94102
TEL (4151 673 7747
-------
a proper waste disposal site, not limiting this to a Federal
facility type disposal site or a private sector site or public
or what have you, but just simply putting together information
on what is acceptable criteria for a Class One type of site.
Also, a second part of that is to put together a
separate set of criteria as to how should such a site be
operated and managed. Simply identifying all of the different
aspects of these two questions.
Work element six is to coordinate interagency action
relating to hazardous waste management when requested by the
agencies concerned.
And finally, work element seven, to coordinate final
disposition action with appropriate state agencies.
We will be putting together this final report. We hope
to have the draft, as I say, by 31 January.
A couple of the recommendations that we feel will be
made to the Western Federal Regionil Council is that, yes, we do
have a problem. We are identifying the problem of hazardous
waste within the Federal agencies. We are hoping that the
Western Federal Regional Council will make recommendations to
the governors of the four states to take action to set up
appropriate waste disposal sites or other means for recycling
or recovering these waste products. But this was the main
emphasis of our task force/ to try to get together appropriate
information on where and how these sites can be developed.
1212
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COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
SAN FRANCISCO, CALIFORNIA 941 OH
TEL (-115) 673 7747
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
„ JJECT: Conments and Supportive Materials for Hazardous DATE- JflM 9 Q iqyc
Waste Management Public Meeting, San Francisco CA, ' 3'°
December 11, 1975
FROM: Chairman, Federal Task Force for Hazardous Materials Management,
Western Federal Regional Council, Region IX
TO.- John P. Lehman, Director, Hazardous Waste Management Division, Office
of Solid Waste Management Programs, (AW-465)
In support of introductory testimony given by MAJ Wyatt L. McGhee,
USAF, at the subject meeting, representing the subject task force, he
promised that the Task Force would forward an executive summary of its
findings, data, and recommendations. At the direction of Mr. Webster
Otis, Chairman of the Western Federal Regional Council, I am forwarding
herewith an Executive Sumnary of the Task Force activities with
accompanying appendices which detail its actions, findings, data, and
recommendations, for your consideration.
If you have need of clarification or further information, please
contact me. My telephone number is (415) 556-4606.
cc:
T. Bourns
Mr. Webster Otis, Chairman WFRC
Task Force Executive Ccnmittee Members
Paul DeFaloo, Regional Administrator, IX
1213
EPA Form 13204 (fev. 6-72)
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FEDERAL TASK FORCE FOR HAZARDOUS MATERIALS MANAGEMENT
of
THE WESTERN FEDERAL REGIONAL COUNCIL
EXECUTIVE SUMMARY OF ACTIONS TO JANUARY 15, 1976
Background
The Federal Task Force for Hazardous Materials Management
came into being almost spontaneously as an "ad-hoc" working
group on August 2, 1973, as a result of a discussion of
related problems in the area of hazardous waste management
as experienced by a number of Federal agencies in standard
Region IX. This problem discussion session was announced by
the Environmental Protection Agency, Region IX, for the dates
of August 1 and 2, 1973, for any Federal agency representatives
in Region IX who were interested in participating. The response
of over one hundred persons, representing fifty-three agencies
indicated the wide-spread interest in this subject area.
Organization
The fruitful discussion at this meeting led to a consensus
decision to continue meeting on an "ad-hoc" basis and to work
through an Executive Steering Committee toward resolution
of identified problems in a number of areas relating to hazardous
waste management. An Executive Steering Committee was chosen,
composed primarily of representatives of those agencies with
the most severe problems or who indicated an interest in
serving on the committee. The membership of the Executive Steering
Committee of fifteen persons has varied but little from its
inception. The members of the Steering Committee and the
agencies they represent are shown in Appendix I of this summary.
The Executive Steering Committee was given broad powers
to further delineate and define the problems discussed at the
first task force meeting, to prepare workplans for arriving at
solutions, appoint sub-committees to work on specific problems
or designate individuals where a committee effort was not needed,
to act for the whole Task Force, to schedule further meetings
of the whole Task Force, and to attend to any other business
deemed necessary. The area of concern was restricted to standard
Region IX.
Problem Identification
The Committee identified several problem areas in Region IX
related to hazardous waste management for which there did not
appear to be environmentally acceptable or adequate solutions.
The foremost problem appeared to be that there either are not
treatment facilities or disposal sites located within reasonable
121k
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distances of origin of these materials such to be economically
Usable and that those few sites- which had been designated
by a State agency appeared to present a potential for either
present or future environmental insults. This problem seemed
to be composed of two parts: (1) the designation of existing
disposal sites and locations were not based on adequate con-
sideration of all necessary parameters for environmental,
social, or political protection and (2) the inadequate manner
in which the disposal or treatment sites appeared to be
operated and managed.
A second problem identified was that information was needed
for planning purposes as to the types of materials that were
being generated as hazardous wastes within the Federal
establishment. The quantities and time of generation were
also unknown. It was discovered in discussions that large
volumes of many types of materials, particularly pesticides,
were being returned from Pacific military operations and that
there were large residual stocks still on hand from World
War II at some locations.
A third major problem area was in the lack of a listing
of people and functions within the various Federal agencies
who were concerned with hazardous waste management. It waj
felt such information would be useful in coordination of
actions. Still another concern was that there was also a
lack of a catalog of facilities for treatment or disposal of
these materials which already existed or were being planned
and constructed by Federal agencies and which might have
potential for treating or receiving another's wastes.
In another problem area it was discovered that many
materials were merely "excess" to a particular agency's needs
and still had a "value" to others who were procuring the
same materials; some materials had value for uses other than
for that which they were originally bought for, or had value
but required reconditioning - a "recycling" strategy was
needed. It was found, also, that there was a great need
to share hazard waste management technology and to present
new technology to the participants.
Further, but not least in importance, it appeared that
a mechanism to motivate local and/or State or Federal govern-
ment agencies into establishing facilities and regulatory
programs is needed.
It was decided by the Committee that the best approach
to such an array of problems was to assign specific tasks to
subcommittees that would contribute to solutions and present
their recommendations to the Task Force for assigned subject
areas of concern.
Procedure
A second meeting of the whole Task Force was held in
February, 1974. At that meeting, an additional problem was
discussed, that of the need of "official recognition" of
this effort and of sponsorship - to justify the expenditure
of the resources being employed in this activity. It was
decided to seek the sponsorship of the Western Federal Regional
Council (WFRC). In view of the multi-agency nature of this
ilj.5
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coordinated action and of the need for joint Federal response
to the overall problem area, the Council, on April 24, 1974,
agreed to sponsor the Task Force, who specified a lead agency,
designated a chairman, and established a set of objectives.
The Environmental Protection Agency was designated as the
lead agency with Mr. Paul De Falco, Jr., EPA Regional
Administrator, responsible to the Council for accomplishment
of actions indicated above.
The WFRC concurred with the Task Force which had at its
February, 1974 meeting, elected Mr. Charles T. Bourns, Chief,
Solid & Hazardous Waste Management, Hazardous Materials Control
Division, Region IX, Environmental Protection Agency (Address:
100 California Street, Sa.n Francisco, California 94111;
Telephone: 415/556-4606).
The seven original objectives that were designated by the
Regional Council for the Task Force to pursue were as follows:
Objectives
1. Provide a mechanism for technology and information
transfer, for responsible agency personnel within the Region
relating to the management of hazardous materials in an
environmentally safe manner;
2. Develop and maintain a directory of individuals within
agencies who are designated for contact regarding management of
hazardous materials and environmental matters;
3. Develop an inventory of excess hazardous materials
and wastes (including related information pertaining to these)
which are in the purview of these Federal agencies;
4. Explore, develop, and recommend courses of action
to the Council to safely manage hazardous materials where
problems are identified. This may involve either recommending
action to the individual agencies concerned, or implementing
a multi-agency cooperative approach;
5. Identify, develop, and disseminate recommended plans
of action for environmentally safe management (transportation,
storage, resale, recycling, re-use, modification, and ultimate
disposal) of these materials; and
6. Coordinate inter-agency actions relating to hazardous
waste management when requested by the agencies concerned.
7. Coordinate final disposition actions with appropriate
State agencies.
Plan of Work
To accomplish the objectives set forth by the Western
Federal Regional Council, the Executive Steering Committee,
with later concurrence of the whole Task Force, developed a
plan of work with a timetable for accomplishment. The Task
Force primarily operated through several subcommittees or
individuals indicated for each work item identified in the plan
of work during FY-75 (See Appendix II). In FY-76, the plan
of work was revised as some goals had been achieved, and some
work plans were changed to reflect a more efficient attack
on the specific problem area (See Appendix III). The Executive
Steering Committee primarily serves to coordinate, receive,
1216
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review, and approve subcommittee actions.
Activities of the Task Force are now scheduled for
completion by June 30, 1976, but, as mentioned above, some
actions are now complete, and most others are now in final
review stages. All actions of the Task Force, however, are
subject to the final approval and acceptance of the Western
Federal Regional Council before becoming official actions of
a Federal inter-agency function.
The Director of the Western Federal Regional Council,
however, has authorized the transmittal of this Executive
Summary and the draft outputs of reports and summaries of
actions of the Task Force to date to the Environmental Pro-
tection Agency, for informational purposes, as an input to
that agency's Public Meetings on Hazardous Waste Management
in support of oral testimony presented by a representative of
the Task Force at the Public Meeting held December 11, 1975,
in San Francisco, California.
Summaries of present Task Force actions and final draft
copies of reports being prepared by the Federal Regional
Task Force for Hazardous Waste Management are included herewith,
as Appendices IV through IX, and itemized as follows:
* I, Executive Steering Committee as of January 15, 1976.
*II. Task Force Work Plan for FY 75.
*III. Task Force Work Plan for FY 76.
IV. Criteria for Selecting a Site.
V. Guidelines for Operation and Management of Sites.
* VI. Report: Sierra Army Depot Retrograde Chemicals, Herlong, CA.
VII. DOD - Region IX Pesticide Inventory and Disposal Actions.
VIII. Civilian Agency Hazardous Waste Inventory.
IX. A Databank System for Recycling, Recovery, and Disposal.
X. Inventory of Existing Federal Hazardous Waste Disposal and
Treatment Facilities.
* XI. Directory of Federal Hazardous Vfeste Management Personnel.
*XII. Coordination of Task Force Actions with State Agencies.
* XIII. Meeting Agenda Showing Technology Transfer Subjects.
There will be additional reports yet to be completed, relating
to efforts to get sites actually established and States to
establish regulatory programs. The latter will be transmitted
to EPA at appropriate times.
* DOCUMENT DETACHED AND RETAINED
IN HWMD FILES
1217
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CRITERIA FOR SELECTING A SITE TOR THE LAND DISPOSAL OP HAZARDOUS WAST
/App*?YN A, i
CONTENTS
Abstract
Acknowledgments
. 100 Introduction
.101 Scope
. 102 Purpose
.103 Assumptions
.200 The Site Selection Process
.201 Triggering Mechanism
.202 The Screening Process
.203 Site Selection
.204 Site Operation
.300 Description and Application of Site Screening Factors
.301 Hydrogeologic Element
.302 Biological (Ecological) Element
.303 Land Use/Status Element
.304 Socio-Economic Element
.400 Recommended Bibliography
Appendices
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CHAPTER
CRITERIA FOR SELECTING A SITE FOR THE LAND DISPOSAL OF HAZARDOUS WASTE
ABSTRACT
Large volumes of chemical residuals and process byproducts are found in the
Federal establishment that are irreducible and environmentally hazardous.
Presently, the only logical disposal is land burial. The sites nov available
for disposal in Region IX have evolved as hazardous waste sites over the
past 25 years because of their proximity to waste generators, and were not
selected for long-term environmental safety. A few sites must be selected
that will serve for ultimate disposal in perpetuity.
A Screening/Selection Process for disposal site selection has been developed
by the Site Selection Criteria Subcommittee based upon successive site
rejection through the proposal, screening, selection, and on-going site
evaluation phases. Four basic elements describe a potential site;
hydrogeologic, biological, land use and status, and socio-economic. A
selection procedure was developed for site evaluation. There are a number
of factors that must be analyzed under each element in each of three levels
of investigation; office review, field reconnaissance, and detailed site
study. The factors primarily describe the geographical setting of the desert
southwest and would have to be modified for use elsewhere. The selection
process on the other hand has universal applicability.
These criteria provide guidance for responsible Federal officials to help
select a site specifically for Federal waste, to evaluate a site proposed
by a commercial proponent to which Federal waste would be taken, or evaluate
the environmental safety of an existing site.
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ACKNOWLEDGMENTS
Chairman: Walter S. Weaver
Sanitary Engineer
USDA Forest Service
California Region
The "Criteria" is the product of the considerable experience of the
following specialists, who selflessly contributed their time and their
energy to write the "Criteria:"
W. L. Burnham Stuart Porter
Hydrologist Watershed Specialist
USDI Geological Survey USDI Bureau of Land Management
Menlo Park, Calif. California
L. E. (Ed) Horton Robert Scott
Ecologist Hydrologist
USDA Forest Service EPA Water Supply Program
California Region Region IX
G. Lewis Meyer
Geologist
EPA Radiation Programs
Washington, D. C.
The following persons who acted as a steering committee to define the scope
of the Subcommittee's work, develop the screening and selection process, and
provide helpful criticism during the writing of the "Criteria:"
Myron Allen (Ret.) Thomas George
Planning Coordinator Civil Engineer
USDI Bureau of Land USDA Forest Service
Management Intermountain Region
Arizona
Kenneth Boll Raymond Jorgensen
Civil Engineer Environmental Coordinator
USDA Forest Service USDI Bureau of Land Management
Southwestern Region Nevada
David Fishel G. Lewis Meyer
Industrial Hygienist Geologist
ERDA - Nevada Operations EPA Radiation Programs
Office Washington, D. C.
Stuart Porter
Watershed Specialist
USDI Bureau of Land Management
California
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The Task Force acknowledges the support given these members by their
respective Agencies and supervisors. The various Agencies have perservered
through what sometimes appeared to be an interminable task.
Special accolades are directed to: Mrs. Sadie Johnson, Clerk-Typist, USDA
Forest Service, California Region, for her skillful interpretation of bad
penmanship, and for putting up with the continual redrafting of the "Criteria,"
and Mrs. Charles Bourns who graciously accepted the task of copy editing
the final draft of the Criteria. Her only relationship to this Task Force
activity is an emotional one.
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CHAPTER
CRITERIA FOR SELECTING A SITE FOR THE LAND DISPOSAL OF HAZARDOUS WASTES
.100 Introduction
.101 Scope
.101-1 Authority
These criteria were developed as an assigned task of the Site Selection
Criteria Subcommittee, an entity of the Western Federal Regional Council's
Task Force for Hazardous Materials Management.
.101-2 Region IX
The mechanism and guidelines herein for the selection of sites for the
disposal of hazardous materials are for the use of all Federal agencies in
Standard Federal Region IX that use or generate hazardous materials. It is
not necessarily implied that sites selected will be for the sole use of the
Federal Government.
.101-3 Hazardous Waste
"Hazardous waste" means any waste material or mixture of wastes that is
toxic, pathogenic, corrosive, flammable, an irritant, a strong sensitizer,
or which generates pressure through decomposition, heat, or other means.
In addition, these wastes or mixtures of wastes can cause substantial personal
injury, serious illness or harm to man or wildlife, during or as a proximate
result of any disposal of such waste or mixture of wastes. The terms "toxic,"
"corrosive," "flammable," "irritant," and "strong sensitizers" shall be given
the same meaning as in the Code of Federal Regulations, Title 16, Chapter II.
However, these criteria do not apply to Class A explosives or radioactive
materials (except for low specific activity radioactive) as defined in the
Code of Federal Regulations, Title 49. (The definition from S.2150 may be
substituted).
.101-4 Disposal
There will certainly be some irreducible portion of many processes that are
considered a waste (1) by virtue of their environmental danger, (2) their
resistance to being effectively changed to an innocuous state, or (3) all
reuse or recycling potential has been exhausted. Therefore, disposal is the
only alternative remaining.
The management of the site, as a waste disposal site, will be in perpetuity
because of the extreme persistence of the materials handled. Once interred, the
wastes are considered to have been disposed of. Retrievability, although
possible, was not really considered herein, but is in the Guidelines for Site
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Operation.— It is believed, however, that any site qualifying as a disposal
site under these criteria would also quality as a site for the temporary storage
and processing of hazardous wastes.
.101-5 Federal Wastes
The site(s) selected shall be the preferred disposal site(s) for all excess
hazardous materials, residues developed through use of hazardous materials,
their containers, and all process wastes generated by direct action of the
various Federal agencies or their contractors.
.102 Purpose of the Selection Criteria
.102-1 Protect Environment
These guidelines are developed to facilitate the selection of a site whose
natural characteristics will reduce the possibility of the release of hazardous
substances disposed of therein in quantities harmful to man and the environment.
.102-2 Guidance to Responsible Officials
These Criteria are for the use of Federal agencies and may serve as guidance
to other agencies or persons. They should not be confused with the "Guidelines"
developed and promulgated under the authority of the Solid Waste Disposal Act
(42 U.S.C. 3251) by the Environmental Protection Agency.
Site Selection Guidelines are being developed by the Hazardous Waste
Management Division (EPA) and will probably be promulgated as "Guidelines",
either supplementing or superseding this Chapter.
.102-3 Supplements National Environmental Policy Act
The intensity of investigations required by these guidelines will provide
the background data for subsequent environmental analyses and Statements. The
disposal of Federal hazardous waste at existing sites will be a significant
Federal action with environmental impacts, which will be discussed through a
complete environmental analysis, and subsequent Environmental Statements for
new sites. Therefore, this screening and selection process is not intended to
be nearly as detailed regarding socio-economic impacts as is called for in NEPA
(42 U.S.C. 4321), Using these guidelines, existing sites may be screened before
use for "environmental safety."
.103 Assumptions
.103-1 The problem exists
All Federal agencies which generate or use hazardous materials are finding
that the locations available for disposal of surplus supplies, of by-products
or residues, and of containers are becoming less available because of limitations
— Guidelines for operation and management of hazardous waste disposal sites -
-------
and problems at existing authorized sites.
.103-2 Disposal site in public domain
Either Federal or State owned or acquired lands will be utilized to insure
control of ownership in perpetuity. "Private ownership" - even with so-called
"perpetuity insurance (funds)" does not provide an adequate guarantee for
future monitoring and action should the private owner move.
.103-3 Proposals for locating specific sites will be made by an advocate:
(a) Waste owner or landowner, Federal Government, State or County agency,
(b) Commercial operator or Federal agency operator.
.103-4 Users
The Criteria are intended to be used by many different technical specialists,
their number and their mix being dictated by the intensity of the screening
process applied to the site investigation. The screening agency should assure
itself of the competence of assigned specialists to perform the various complex
hydrologic, geologic, and biologic engineering and land management assessments.
.103-5 Factors and ratings are subject to modifications during use.
(a) The Criteria are designed specifically for use in the States of
Arizona, California and Nevada, Federal Region IX, and may have to be revised
for use elsewhere.
(b) The procedures for implementing an analysis will be prepared by the
agency (Lead Agency) having ultimate jurisdiction. This will probably require
an interagency team organization.
(c) The Criteria may have to be modified to fulfill the needs of the
team using it.
.200 The Site Selection Process
A flow chart of the Process Is shown in Figure 1.
Figure 1
1221*
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201 Triggering Mechanism
There is an urgent need for environmentally safe disposal sites for
iszardous waste. The impetus for specific site analysis could be generated
ly one of the following:
- Congressional mandate.
- EPA or WFRC commitment.
- Separate or joint agency need.
- Application for a site by a proponent other than a Federal agency.
,202 The Screening Process
After potential areas or candidate sites are identified through proposals
>y an advocate, the process outlined in these guidelines provides a means for
.nvestigating, screening and rejecting unsuitable sites. At least three
.evels of investigation are visualized, namely (1) office review, (2) field
reconnaissance, and (3) detailed site study. These levels and their interactions
ire shown diagramatically in Figure 1. Each level is expected to reject the
ilearly unsuitable sites and pass suitable and satisfactory candidates on
:o the next investigative level.
Factors to be investigated and evaluated are the same for each level of
.nvestigation, but the intensity, detail, and cost become progressively greater
»ith each succeeding level. Screening leaves only the most promising sites,
which will then require detailed study. Some of the "surviving" sites may
well be more acceptable than others for factors other than those discussed
lerein; cost effectiveness, acceptability, etc.
It must be reemphasized that the screening process, if carried through
)etailed Site Study, is both costly and time consuming, but is necessary
to insure the long-term safety of a selected site. The need for safe disposal
sites is so urgent that the investigator minimize repeating the process to
further refine the analysis, i.e., making a situation estimate through tasks
such as map-literature survey, preliminary reconnaissance, intermediate
reconnaissance, then turning around and going through the same phases in a more
detailed manner, leading up to an even more "detailed site analysis."
.202-1 The Elements
Four elements describe a candidate site for waste disposal in sufficient
detail to allow the decision to commit resources for a detailed investigation
of the site. They are:
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- Hydrogeologic
- Biological (Ecological)
- Land Uses and Status
- Socio-e.-.onomic
The first two elements are physical descriptions of the environment that
will be affected by the commitment of a particular tract of land to the disposal
of hazardous waste. The last two elements are more transient in nature because
they can be changed through legislation, regulation, or changes in lifestyle.
Section .300 of this Chapter has a more complete description of the elements
and their major factors.
'.202-2 Factor Analysis
The four elements are subject to analysis through a number of factors in
each of the three levels of investigation (office review, field reconnaissance
and detailed site study. Since the detailed site study will determine a site's
suitability for selection, the intensity of investigation required is greater
than in the previous two levels.
The factors and their ratings, for other than those specifically noted under
Detailed Site Analysis (II.B.2.C), are shown on Plates 1, 2, and 3.
Plates 1, 2, and 3
(a) Office Review - Includes the review of historical records, agency
inventories, research of broad area indicators, land status and use factors,
socio-economic factors, and other literature.
(b) Field Reconnaissance - Should include a validity check on the office
review as well as an analysis of many of the physical (environmental) factors
of the Hydrogeologic, and Biological Elements. The product of this level of
investigation is the arraying of.indicators on the Rating Charts. See Plates
1, 2, and 3.
Two separate levels of field reconnaissance may be required for both
Hydrogeologic and Biological Elements, preliminary and intermediate reconnaissance
to lessen impact on expenditures and resources. The former requires the time of
competent investigators; the latter requires the extensive use of instrumenta-
tion and exploration equipment.
(c) Detailed Site Analysis - If confidence in a particular site's environvnenta
safety has not been confirmed through the previous phases, a more intense
investigation may be necessary, especially in the Hydrogeologic and Biological
elements. It might be more appropriate to consider this phase as one of the
aspects of site selection (See Section .203) rather than screening, because
this intensity of investigation would be carried out only on a few highly
qualified candidate sites.
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These analyses are complex in nature and are addressed at the prior two
levels by a professional investigator; at least, subjectively, On-site
investigations of specific items, if necessary, may entail large expenditures
of resources. Investigation may include, but not be limited to, the following
analyses:
(1) Hydrogeologic
- Streamflow Data: Streamflow data for perennial and ephremal
streams in sufficient detail to determine base flow, maximum
flows for evaluating the flooding potential of the site, and
for constructing a stream hydrograph.
- Soil Moisture Tension: In situ measurements of soil moisture
tension of the upper 15-30 feet of the proposed burial media.
Measurements are made with a tensiometer inserted into the soil
at a desired depth to measure soil-water tension. After a site
passes the initial screening phase and is selected for more
detailed analysis, these measurements should be conducted for a
period of two or more years.
- Soil Moisture Measurements: In situ measurements of soil moisture
content of the unsaturated zone down 30-45 feet should be made in
specially constructed holes using a neutron soil moisture gauge or
an equivalent method. The measurements should be made for a period
of two or more years after a site passes the initial screening phase
and is selected for more detailed analysis.
- Water Chemistry: Chemistry of the water in the aquifers and
aquitards beneath the proposed disposal facility to the base of
the shallowest confined aquifers. This includes the pH, Eh,
cations, anions, specific conductance, dissolved and suspended
solids, and other factors which are needed to establish original
baseline conditions in each formation, to differentiate between
waters from the different formations, and to estimate the potential
reactivity of the natural waters in the formations with leachates
and contaminated waters which might result from disposal operations.
- Stratigraphy: Composition, sequence, thickness, age, correlation
and other relationships of the stratified and non-stratified rocks
beneath and within the vicinity of a proposed site which might
affect the movement of water, stability of the rocks, site operations,
or long-term retention of wastes disposed of therein.
- Hydraulic Data on Sub-surface Formations: Permeability, porosity,
effective porosity, hydraulic conductivity, storage coefficient,
hydraulic head or potential, and other hydraulic parameters of the
subsurface water-bearing formations which are required to calculate
the direction and rate of movement of groundwater beneath the site.
Pumping, bailing, or slug tests of wells and physical property
measurements of samples from these wells are usually required to make
these determinations.
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- Natural Fluctuations of Water Table; The natural fluctuations of
the regional water table and of perched water tables beneath the
proposed site should be known, particularly the expected maximum
high water levels.
- Distribution of Hydraulic Head with Depth; Definition of the
hydraulic head or potential of each aquifer and aquiclude beneath
the site down to the base of the shallowest confined aquifer. The
hydraulic head(potential) of each individual aquifer is commonly
determined: (1) by testing each formation individually as it is
penetrated during the drilling of a test well; (2) by testing the
formations with inflatible packers after the drilling of the test
well is completed; or (3) by constructing a group of wells, each
of which is completed in a single waterbearing formation (commonly
called a. piezometer nest).
- Water .Table Contour Map: A map showing by contour lines the upper
surface of the water table, or zone of saturation, in the area
around the proposed site. On occasion, a similar map showing the
piezometric surface, pressure potential surface of the shallowest
or other significant confined aquifer may be required. Areas where
perched water tables occur should be shown where possible.
(2) Biological Communities
In addition to its physical characteristics, an ecosystem is composed
of plants and animals organized by dependency relationships into communities.
In order to assess the influence and importance of one element of the
ecosystem to another or to predict the effects of a new activity, it is
necessary to have inventory information concerning plant communities and
their animal associates.
- Plant communities.
- Animal associates.
(3) Ecological Relationships
The ecological integrity of an area is dependent upon an array of
processes and interactions which work to bind the various pares of the
ecosystem into a functioning whole. Predominant relationships vary from
ecosystem to ecosystem.
- Primary productivity.
- Plant successional trends.
- Stability (population and ecosystem).
- Predation (including parasite).
- Interspecific competition.
- Territoriality.
-------
.202-3 Screening Process Re-evaluation
The rating charts are for guidance only and It is not to be inferred that
a low ranking on any single factor, or a few factors automatically rejects a
site from further investigation. Two alternatives would be appropriate if a
.site appears to be rejected based on these Guidelines:
.(a) First, consider a larger number of sites and if then no viable
candidate is found, proceed to the next step, which is
(b) Reassess the most likely site from a total resource foregone basis.
The need for a "safe" disposal site may be greater than the loss of one or
more factors. See Section .304.
.203 Site Selection
Selecting a site for the disposal of wastes may be an irreversible land
use decision in that it commits a tract of land to this use to the exclusion
of other uses in perpetuity. Therefore, the same evaluation of values foregone
and other trade-off questions must be made as for any other land use decision.
Those sites not rejected by any of the three investigation levels (1) office
review, (2) field reconnaissance, and (3) detailed site study, are considered
to have physical and biological characteristics that are compatible with the
proposed use.
Sites that survive this progressive rejection system must still receive
public acceptance through the NEPA and political process. The data collected
through Factor Analysis should be easily convertible to Environmental Statement
format. Obviously the site(s) may ultimately be rejected in the political
arena, even if assessed as acceptable by the process outlined herein.
.204 Site Operation
Once waste is accepted for disposal, a site is committed in perpetuity.
Future generations will be responsible for monitoring. The data base
assembled during the Screening/Selection process, however, will become the
baseline for future monitoring procedures and requirements. The results of
the monitoring are necessary to give the site operator sufficient lead time
to take corrective action, and to mitigate unwanted effects resulting from
disposal of wastes at the site.
.300 Description and Application of Site Screening Factors
.301 Hydrogeologic Element
.301-1 Every effort is to be made to prevent or reduce contact between
water and wastes.
-------
.301-2 Factor scale ranges are based on the special conditions existing in
mainland Region IX, i.e.,
(a) Very large areas of unpopulated land with relatively low economic
value.
(b) Significant areas with arid or semi-arid climate.
.301-3 The screening factors are highly selective in that they force a site
into a "very low water" location (i.e., low precipitation, absence of surface
waters, and great depth of ground water).
.301-4 Although the factors are ultra conservative regarding potential
contacts of water and waste, they are somewhat liberal in other respects.
For example:
(a) Once buried, it is assumed that seismic activity will have little
effect on the wastes unless land surface rupture or displacement occurs within
the site.
(b) Fluctuation of the water table, monitorability, remediability, etc.,
are not as important in a "low water" situation as they would be in a humid
climate. In the latter, the relative impermeability of the underlying strata,
site engineering design, and construction methods become more important.
.301-5 The data collected must be sufficient to predict the waste retention
capability of a site, both in quantity and in time, as related to the type and
toxicity of the wastes.
.301-6 This screening process can be very useful for: (1) identifying sites
which have potential and are, worth investigating further; (2) flagging critical
factors which could limit or prohibit use of the site, and (3) indicating the
need for specific engineering and construction. However, it has a danger
which should be clearly recognized and guarded against. The comprehensive
results obtained from each individual measurement are tabulated into a combined
value. One or two critical factors, if negative, could negate the whole. The
evaluator would then be in the position of averaging 20 excellent measurements
with one or two unacceptable values and could obtain an excellent overall rating
for a potential site which would be an inherent threat to health and the
environment. Engineering modifications to the site to correct these unsatisfactory
factors may be acceptable in some cases. However, there are some factors which
are irremediable and require total rejection of the site (i.e., high precipitation,
closeness to fracture bedrock, or shallow water table).
1230
-------
301-7 The factors chosen deal with the availability, location, and movement
T water, the properties of the burial medium and underlying strata, and
rocesses which could disrupt the site, introduce water to the waste, expose
le wastes or otherwise return the wastes to contact with the environment
ad man. A brief description of each factor is found in Appendix 6.
301-8 Where possible, common units of measure and specific limits were
losen for the factors. However, there are not standard units for describing
srtain factors, so a "qualitative" description must be used; for example, the
aomorphic stability of a site cannot be easily quantified. For this type
; factor, a qualitative evaluation must come from professional judgement of
le site selection team. The unit of measure and range of value for each
ictor is shown on Plate 1 and given in Appendix B.
301-9 Each factor is ranked and given a weighting value based, in general,
i the estimated importance of the factor in causing the release of contaminants
com the waste, in reducing the retention capability of the site, or in hastening
jntact of the waste with man and the environment. The highest ranking is
.ven to water and its potential to contact the wastes. Physical isolation of
le wastes by distance from man and water is ranked second. Factors which could
.ter conditions at the burial site, add to the complexity of the site
rdrogeology, or affect the characteristics of the burial medium are ranked
lird. Included also and ranked last are those factors which definitely should
* known about a site but are considered less important because it is presumed
lat there will be very little precipitation or inflow of water at the site.
le relative importance and weight of hydrogeologic factors used in this
:reening system are displayed in Appendix B.
:u3l
-------
.301-10 This screening/selection system tries to develop a qualitative
numeric rating of the hydrogeologic factors at a potential burial site (or
area). A rating chart for screening the potential hazardous waste burial
sites is presented in Plate 1. The chart provides places to enter the raw
value for each factor graphically and numerically. After this is done, the
weighted value for each factor can be determined by 1) locating the raw
value on the graphic scale; 2) reading upward (or downward) to the relative
scale and determining its relative value; and 3) multiplying its relative
value by the weighing or ranking of the factor. A qualitative - numeric
rating of the site can be obtained at each investigative phase.
The range of weighted values corresponding to the relative values is as
follows:
Range of Numerical
Relative Value Weighted Values
Ideal 624-521
Excellent 520-417
Above average 416-313
Average 312-207
Below average 206-105.
Marginal 104-1
Unacceptable 0
The ideal result shown on the screening/selection display (See Plate 1)
would be a vertical line to the left of the chart.. A left leaning trend
is naturally desired.
.301-11 A hypothetical rating of the commercial radioactive waste burial
facility at Beatty, Nevada, by this screening/selection system is presented in
Example 1 as an example of how the system works. The Beatty site is located a
Example 1
the north end of the Amargosa Desert, Nevada; has low rainfall; and has
relatively good isolation from surface waters, ground waters, and use points.
Most of the factors used are real. However, some values are not known and
were estimated or put in for the purpose oŁ presenting this example.
-------
.301-12 Detailed hydrogeologic site analysis
See Section II.B.2.C.CD.
.302 Biological (ecological) Element
The factors identified represent those biotic elements needed by the
investigator to:
- Predict environmental changes occasioned by establishment and operation
of a disposal site in terms of biological (ecological) components.
- Assess potential effects (both adverse and beneficial) on each element
caused by the disposed materials in place or displaced by the disposal
activity, and by permanent protection from other uses within the site
enclosure on the site area, and on surrounding areas.
- Evaluate the relative significance of such changes and effects as an aid
in site selection.
.302-1 A factor analysis and rating scheme has been developed to display the
sensitivity of candidate sites regarding the primary biological factors. See
Plate 2. Appendix C contains descriptions of some of the Biological Screening
Factors.
The biological factor analysis and rating scheme can be applied to only a
portion of all the factors that must be investigated, but it provides a
minimum checklist for those factors that must be addressed during the Office
Review and Field Reconnaissance Phases.
The following constraints will be applied to the use of this rating scheme:
(a) Each factor will be inventoried for existence on site or nearby.
(b) Each factor will be evaluated for potential, compatibility, mitigation
or forfeiture, and relative significance of site to the whole.
(c) Tentative rejection criteria - reject sites with value of 2 or less
for any factors.
.302-2 Interrelationships
There are additional subtle processes and relationships that are recognizable
only by a skilled observer. These are not separable biological factors, but are
basic considerations that must be taken into account during all three levels of
investigation intensity (office review, field reconnaissance, and detailed site
study). They are present on all sites and are investigated to determine relative
significance, and to evaluate the effects of the disposal activity on them.
(a) Biological Communities
See Detailed Analysis .202-2(c)(2).
-------
(b) Ecological Relationships
See Detailed Site Analysis .202-2 (c)(3).
.302-3 Biological Factors Critical to Waste Disposal Sites
The following are factors that would tend to directly affect the selection
of a particular site for waste disposal (as opposed to the effect of a waste
disposal operation on the indigenous biological community):
(a) Rare or unique species or ecosystems. Includes organisms or places
that have local interest or have received public attention for other special
reasons (i.e., bristle-cone pine).
(b) Poisonous, noxious, ruderal, or other undesirable plant species. A
selected site containing such species could become a sanctuary or source area
for future spread of such undesirable species.
(c) Deep-rooted plant species who have the capability of translocating
waste materials into above ground tissue where they may enter food chains
or otherwise be transported off site.
(d) Burrowing animals (See (C) above).
(e) Wildlife incursion of the site for migration, browse, or water, as
it affects the spread of contaminants.
.303 Land Use/Status Element
.303-1 Use of the factors
Man's past and present use of land and his actions regarding the sites con-
sidered for waste disposal must be fully known before a site can be selected
to incure a site free from incumberances and modification that would jeopardize
the environment safety of the site.
-------
Fast, present, and future uses/actions on adjacent and surrounding lands
must be tested for compatability with the disposal of hazardous wastes.
Careful review and reconnaissance is necessary to ascertain the relative
compatability of a land use or status by displaying the existence of a
conflict with waste disposal. Plate 3 is a chart to highlight potential
land use conflicts. A leftward array of checks is most desirable.
.303-2 Land Use/Status Descriptors
(a) Transportation System
Roads, trails, highways, railroads, communication system lines (above and
below grade), and air strips for both public and private use.
(b) Water Resource Management
(1) Federal Power Commission licenses.
Hydroelectric dams, reservoirs, and associated transmission lines.
(2) Watershed - domestic and other beneficial.
(3) Water source - domestic and other beneficial.
(4) Geothermal Energy Source.
(5) Power generation facilities.
(6) Water treatment facilities.
(7) Flood protection facilities.
(8) Other adverse actions by man to affect water resources.
(c) Mining Claims and Operations
(1) Location and purchase - metallic or other substance in quantity
sufficient to render the lands valuable on account of it, considering its
location: Lode - "Rock in Place"; Placer; and necessary associated millsites.
(2) Leasable minerals - coal, oil, gas, sodium phosphate, potash, sulphur, etc.
(3) Common varities - Sand, stone, gravel, pumice, cinders, and clay.
(4) In situ leaching.
(5) Heap leaching.
(d) Encuraberances
1235
-------
(1) Permits
Permitted occupancy and use of public lands under specific regulations
of the agency with stewardship over the subject lands, including free and
fee, covering a multitude of uses, with variable terms.
(2) Easements (R.O.W.'s)
Oil, gas (pipelines), railroads, irrigation, drainage, dams, and reservoirs,
road, bridges, trails, water transmission, power transmission, telephone/
telegraph, radio/electronics, etc.
(3) Withdrawals
Certain public lands withdrawn from appropriation and entry and reserved
for governmental purposes under provisions of several acts of the Congress
and EO 10355, i.e., power, reclamation, military, and mineral.
(e) Outdoor Recreation
Any activity on public lands that contributes to inspiration, relaxation,
and enjoyment of the outdoor.
(f) Designated Areas and those of Special Interest
(1) Parks; National, State and local.
(2) Game refuges (See Biological; Wildlife).
(3) Significant archeological, historical, ecological, geological, or
scenic area.
(A) Wilderness - An area designated by Congress as undeveloped Federal land
retaining its primevil character and influence without permanent improvements
or human habitation, which is protected and managed so as to preserve its
natural conditions.
(5) Primitive and Roadless Areas - Lands suitable for inclusion In the
National Wilderness Preservation System.
(g) Agricultural
Grazing (range allotments), timber production, cultivated lands, etc.
.304 Socio-Economlc Element
These factors must be quantified or otherwise described or discussed. They
are typical of all sites to be investigated and the list is not at all exhaustive
1236
-------
.304-1 Proximity to waste source(s).
.304-2 Adequacy of transportation system for the delivery of hazardous
materials.
.304-3 Resources foregone by the commitment of land to waste disposal in
>erpetuity (energy, mineral, water, etc.).
.304-4 Institutional constraints (politics at all levels).
.304-5 Population and density.
.304-6 Ownership and use pattern.
.304-7 Employment and community impact.
1237
-------
.400 Recommended Bibliography
GENERAL
1. Brunner, D. R. and Keller, D. J., Sanitary Landfill Design and
Operation, Washington, U. S. Government Printing Office, 1972, 59 p.
2. Digest of Public Land Laws, Public Land Law Review Committee,
Washington, D. C., June 1968.
3. Fields, Timothy, Jr. and Lindsey, Alfred W., Landfill Disposal of
Hazardous Wastes: A Review of Literature and Known Approaches,
Cincinnati, U. S. Environmental Protection Agency, June 1975.
4. Guidelines for the Land Disposal of Solid Wastes, Federal Register
39(158):29333, Environmental Protection Agency, August 14, 1974.
5. Guidelines for the Preparation of Environmental Impact Statements,
40 CFR 1500 et seq., Council on Environmental Quality, August 1973.
6. Waste Discharge Requirements for Waste Disposal to Land, Disposal Site
Design and Operation Information, California State Water Resources
Control Board, November 1975.
HYDROGEOLOG1C
1. Cherry, J. A., Grisak, G. E. and Jackson, R. E. 1973. "Hydro-
geologic Factors in Shallow Subsurface Radioactive Waste Management
in Canada," Proceedings, International Conference on Land for
Waste Management, Ottawa, Canada.
2. LeGrand, H. E. 1964. "System for Evaluation of Contamination
Potential for Some Waste Disposal Sites," American Water Works
Association Journal. Vol. 46, Denver, Colo.
3. Papadopulos, S. S. and'Winograd, I. J. 1974. "Storage of Low-Level
Radioactive Wastes in the Ground: Hydrogeologic and Hydrochemical
Factors." U. S. Environmental Protection Agency Technical Report,
EPA-520/3-74-009, U. S. Environmental Protection Agency, Washington,
D. C. 20460.
4. Swift, W.H. 1973. Feasibility Study for Development of a System
of Hazardous Waste National Disposal Sites, Battelle Northwest,
Richland, Washington.
5. Williams, Roy E. and Wallace, Alfred. 1970. Hydrogeological Aspects
of the Selection of Refuse Disposal Sites in Idaho. Pamphlet 145,
Idaho Bureau of Mines and Geology, Moscow, Idaho.
1238
-------
BIOLOGICAL (ECOLOGICAL)
1. Allee, W. C., et. al., Principles of Animal Ecology, W. B. Saunders
Company, Philadelphia. 1949.
2. Daubenmlre, Rexford, Plant Communities: A Textbook of Plant
Synecology. Harper and Row, New York. 1968.
3. Greig-Smith, P. Quantitative Plant Ecology. Academic Press Inc.,
New York. 1957.
4. Kormondy, Edward J. Concepts of Ecology, Prentice-Hall Inc.,
Englewood Cliffs, N. J. 1969.
5. Odum, Eugene P. Fundamentals of Ecology, Second Edition, W. B.
Saunders Company, Philadelphia. 1959.
1239
-------
7RI6GERM&
MECHANISM
DEVELOP OK
SELECTION
PROCESS
AREAS OF
CONSIDERATION
FLOW OF
SELECTION PROCESS
121*0
-------
PLATE I
RATING CHART FOR SCREENING OF HAZARDOUS WASTE DISPOSAL SITES
RELATIVE VALUE
GREENING/SELECTION CRITERIA
CE REVIEW
:iPtTATION (INCHES / YEAR)
REST SURFACE WATER OR STREAM (MILES!
*ŁST USE (DISCHARGE POINTHMILES)
MIC ACTIVITY (MILES)
.IMINARY FIELD RECONNAISSANCE
"E(PERCENT)
MORPHIC STABILITY (QUALITATIVE)
DOING POTENTIAL (QUALITATIVE)
> EROSION POTENTIAL (QUALITATIVE)
TH 1
TH (DISTANCE) TO FRACTURED BEDROCK(FEET)
E OF BURIAL MEDIA (QUALITATIVE)
SIDENCE (FEET)
IMUM WIND DIRECTION (QUALITATIVE)
RMEDIATE FIELD RECONNAISSANCE
TANCE TO KNOWN FAULT (FEET)
UAL MEDIA AND UNDERLYING STRATA
SORPTION CAPACITY (ME/100 GM)
THICKNESS (FEET)
ENGINEERING PRCPERTIES(QUAUTATIVE)
PERMEABILITY (GAL/DAY/FT*)
EFFECTIVE POROSITY (PERCENT)
STRUCTURE (QUALITATIVE]
IATIO OF PAN EVAPORATION TO
ICIPITATION MINUS RUNOFF
>ROGEOLOGIC COMPLEXITY (QUALITATIVE)
ITABIUTY FOR CONTROL OF WATER TABLE
JAUTATIVE)
MITORABILITY (QUALITATIVE)
MEDIABILITY (QUALITATIVE)
OHAULIC GRADIENT (FEET/MILE)
AVENA«C AVCRACE
0 . •?••'? * . i.
no a 4 j j <(
L6 1.2 10 * • 7 4
TOO SCO 400 900 2OO WO «0 TO «0 _,
900400 300 200 100
vemfme/? • • ' • • GRAVEL
SH.TI
4000 SOOO KCO
>50.4P*°«) "9 ? .*•*
4?4* 'P ?s«5 .^,in
oilf • «c •> » . >
-------
PLATE 2
Biological (Ecological) Factor Rating Chart for Office Review and Field
Reconnaissance
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-------
PLATE 3
Land use status factors for
proposed sites or adjacent
lands
1. Transportation System
2. Water Resource Management
3. Mining Claims and Operations
4. Permits, easements (R.O.W. 's)
and withdrawals
5. Outdoor recreation
6. Especially designated areas
and those of special interest
7 . Agricultural
8. State and local
Government's Land Use Plans
and Zoning
Does not
exist
Low
potential
land use
Existing
Compatible
with waste
disposal
Does not
exist
High
potential
for land
use
Existing
Not
compatible
with waste
disposal
(Check where appropriate)
-------
EXAMPLE 1
RATING CHART FOR SCREENING OF HAZARDOUS WASTE DISPOSAL SITES
RELATIVE VALUE
SCREENING/SELECTION CRITERIA
OFFICE REVIEW
PRECIPITATION I INCHES / YEAR )
NEAREST SURFACE WATER OR STREAM (MILES)
NEAREST USE [OlSCMARGi: POINTHMILES)
SEISMIC ACTIVITY (MILES)
PRELIMINARY FIELD RECONNAISSANCE
GEOMORPHIC STABILITY (QUALITATIVE)
FLOODING POTENTIAL (QUALITATIVE)
WIND EROSION POTENTIAL (QUALITATIVE)
DEPTH TO WATER TABLE (FEET)
DEPTH (DISTANCE) TO FRACTURED BEOROCK(FEET)
SUBSIDENCE (FEET)
OTIMIJM WIND DIRECTION (QUALITATIVE)
INTERMEDIATE FIELD RECONNAISSANCE
DISTANCE TO KNOWN FAULT (FEET)
SORPTON CAPACITY (ME/IOO GM)
THICKNESS (FEET)
ENGINEERING PROPER TIES ( QUALITATIVE )
STRUCTURE (QUALITATIVE)
A RATIO CF PAN EVAPORATION TO
PRECIPITATION MINUS RUNOFF
HYDROGEOLOGIC COMPLEXITY (QUALITATIVE)
SUITABILITY FOR CONTROL OF WATER TABLE
( QUALITATIVE 1
MONITORABIUTY (QUAUTA1IVE)
REMEDIAB'LITY (QUALITATIVE)
HYDRAULIC GRADIENT (FEET/MILE)
IDEAL EXCELLENT ABOVE AVEflAGC BELOW MARGINAL UNACCEPTABLE
AVERACE AVERAGE
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-------
APPENDICES
Appendix A Comparision of Hydrogeologlc Screening Factors suggested
by several sources.
Appendix B Description of Hydrogeologic Screening Factors.
Appendix C Description of Biological Screening Factors.
12
-------
APPENDIX A
A COMPARISON OF SCREENING.AND SELECTION FACTORS FOR HAZARDOUS WASTE LAND
DISPOSAL SITES SUGGESTED BY SEVERAL SOURCES
FACTORS
OFFICE REVIEW
- Precipitation
- Nearest Surface Water
- Nearest Use or Discharge Point
- Seismic Activity
—
FIELD RECONNAISSANCE
- Slope
- Geomorphic Stability
- Flooding Potential
- Wind Erosion Potential
- Depth to Water Table
- Depth to Fractured Bedrock
- Type of Burial Media
- Subsidence
- Optimum Wind Direction
INTERMEDIATE RECONNAISSANCE
- Distance to Known Fault
- Burial Media
- Sorption Capacity
Thickness
Engineering Properties
Permeability
Effective Porosity
- Structure
- Ratio of Pan Evaporation to Precipitation
Minus Runoff
- Hydrologic Complexity
- Suitability for Control of Water
- Adequate Water Supply
-Monitorability
- Remediability
- Hydraulic Gradient 12^6
1 Level of
Expenditure
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I/
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X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
I/
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
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X
X
X
X
X
X
X
X
X
X
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X
X
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X
X
X
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X
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51
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X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
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3
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X
X
X
X
X
X
X
X
X
X
X
X
y
X
X
X
X
X
X
X
X
X
X
X
1
-------
APPENDIX A
cont.
A COMPARISON OF SCREENING AND SELECTION FACTORS FOR HAZARDOUS WASTE LAND
DISPOSAL SITES SUGGESTED BY SEVERAL SOURCES
ACTORS
ETAILED SITE ANALYSIS
Three Dimensional Head Distribution
Burial Media and Underlying Units
Including Nearest Confined Aquifer
- Water Chemistry
- Stratigraphy
- Ion Exchange Capacity
- Moisture Content of Unsaturated Zone
- Soil Moisture Tension
2. Transmissivity
• Natural Fluctuation of Water Table
• Flow Data for Nearest Streams (Underflow)
• Water Table Contour Map
INIMUM BASIC REQUIREMENTS
• Degree of Contact of Water with Waste
- Distance (s) Along Critical Flow Lines
- Direction and Rate of Movement of
Critical Elements
- Residence time in the Site for
Critical Elements
Level of
Expenditure
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- Criteria identified during studies by the Task Force Sub-committee on Site Selection.
?/
-Criteria identified or implied by Winograd and Papadopulis, 1974.
-Criteria identified or implied by Grizak, Cherry, et. al., 1973.
-^Criteria identified or implied by Legrand, 1974.
-^Criteria identified or implied by Battelle Northwest, 1973. 12A7
-^Criteria dientified or implied by Williams and Wallace, 1970.
—'Criteria adopted from other technical literature because of its apparent need
-------
APPENDIX B
DESCRIPTION OF HYDROGEOLOGIC SCREENING FACTORS
RANGE OF VALUES
UNIT OF WEIGHT OF
FACTOR MEASURE IDEAL UNACCEPTABLE FACTOR
PRECIPITATION Inches per year 5 18 10
Total precipitation per year, Including rainfall and snowfall; the less
precipitation, the better.
NEAREST SURFACE Miles 20 15
WATER OR STREAM
Distance of surface and subsurface travel path(s) along which contaminants from
site must migrate to reach nearest surface water or stream; the longer the travel
the better. A site conceivable could be located physically within several miles o
a stream without penalty, if it were clearly separated from the stream by topograp
and hydrologic divides.
NEAREST USE OR Miles 20 15
DISCHARGE POINT
Distance of surface and subsurface travel paths along which contaminants from site
must migrate to reach the nearest use of discharge point, the longer the travel
path, the better. Similar exceptions as for preceding factor.
SEISMIC ACTIVITY Miles 15 2 2
Distance in miles of site from a seismlcally active zone or area; the greater the
distance, the better. It is assumed that the wastes, once buried, will be little
affected by regional seismic activity such as earthquakes. The intent is to keep
the site away from areas of high acceleration, known tectonic stress, suspected
potential locii of earthquakes, active faults, and other seismic phenomena which
could rupture or damage the disposal facilities.
SLOPE Per cent 1 .-...*» 1.5 15 (max) 4
J-"u 0.5 (mln)
General slope of land surface measured in per cent. Land surface which are too
steep, too flat, or too irregular present problems in construction, operation, and
long-term maintenance. In example, steeper land surfaces increase the potential
for cap maintenance, erosion, and denudation of the buried wastes; whereas, water
(precipitation) will not run off fast enough, will tend to pond, and can infiltrati
into the trenches and soak the wastes, if the land surface is too flat. Therefore,
two unacceptable values for slope, one too high and one too low, and only one idea
-------
GEOMORPHIC Qualitative Stable Unstable 4
STABILITY
The land should be geomorphlcally stable for thousands of years; that is, the rate
of weathering and erosion should not be sufficient to affect the position and
surface of the land surface for thousands of years. Because there is no generally
, accept unit of measure for geomorphic stability, relative terms were used.
FLOODING Qualitative Low and High 4
POTENTIAL Infrequent
The potential for flooding of a site should be low. A site should not be located in
the flood plain at a stream where rising flood waters can flood it. Nor should a
site be located in a drainageway where descending runoff from a flash flood
could fill an otherwise dry channel and flood it. Relative rating terms are used
for the preliminary stages of investigation. In later detailed investigations, it
might be necessary for certain sites to calculate the size of a flood event
which would flood a site.
WIND EROSION Qualitative Low High 2
POTENTIAL
Wind could possibly cause construction and maintenance problems, serious erosion
of the trench caps, and denudation of the wastes; the lower the potential, the
better.
DEPTH OF WATER Feet 1000 50 5
TABLE
Depth below land surface to regional water table; the deeper the water table,
the better. The depth to any perched aquifers; known or suspected in the area
and the shallowest confined aquifer should also be known.
DEPTH OR DISTANCE Feet 1000 50 4
TO FRACTURED BED-
ROCK
Separation between burial zone and fractured bedrock; the greater the separation,
the better. The values presented herein are for fractured bedrock which underlies
the burial zone. If fractured bedrock lies downgradient along a travel path from
site, a different set of values should be used.
-------
TYPE OF BURIAL Qualitative Very fine Clean sands 4
MEDIA ' sands and and gravel
silts clay
It is assumed that a granular medium such as clastic sedimentary rocks, strongly
weathered bedrock, soils, glacial deposits, and certain pyroclastic rocks would
be used as the burial medium strictly on the basis of its favorable engineering
and workability properties. A brief description of the granular character of the
deposit is desired. Strata of intermediate permeability, such as silt, siltstone,
and silty sandstone, are preferred for burial media. Trenches in strata of low
permeability may act as bathtubs which collect water during unusual precipitation
events and overflow or soak the wastes. Contrawise, strata of high premeability
allow water to pass too freely and in general, have poorer ion exchange
characteristics.
SUBSIDENCE ' Feet 0 53
Subsidence is the net lowering of the land surface caused by man's activities
in four unrelated processes which are caused by (1) the intensive pumping of
ground water, (2) the collapse of moisture-deficient deposits when water is
first applied (hydro-compaction), (3) the oxidation of organic soils, and (4) the
local extraction of fluids from producing zones in oil fields.
OPTIMUM WIND Qualitative Good Bad 2
DIRECTION
Wind can play an important role in the transport, resuspension, and diffusion of
particulare and gaseous contaminants in arid and semi-arid regions. This factor
is not well-defined but should be considered in locating a disposal site.
DISTANCE TO Feet 5000 1500 3
KNOWN FAULT
Distance in feet of the site from a known fault; the farther from a fault, the
better. This factor is intended to include any "inactive" fault (a fault where
no recent movement is suspected) which was not included under "Seismic activity."
BURIAL MEDIA AND Mllliequivalent per 50 24
UNDERLYING STRATA 100 grams
SORPTION CAPACITY
The sorption capacity of the burial medium as evaluated in the laboratory by
the distribution coefficient, or K , method. The K, is the ratio of activity
concentration, or mass of a sorbed nuclide per unit of mass of solids to the
activity or concentration of dissolved nuclide per unit volume of water
(Thompkins and Mayer, 1947, Kaufman, 1963). The K is usually expressed in
1150
-------
mllliequlvalents per 1000 grams; the larger the ratio, the better. The K is
determined in the laboratory and is a function of a number of variables. At best,
It can only approximate the potential sorption and ion exchange capacity of
a burial media under limited laboratory conditions. Detailed studies in the
field, or which duplicate field conditions, will be required if the site is
selected for further evaluation. So far as practicable, the sorption capacity
of underlying strata down to the base of the shallowest confined aquifer should
also be determined.
JRIAL MEDIA
THICKNESS Feet 500 50 4
Thickness o.f burial medium as a relatively uniform, homogeneous, non-fractured
stratum; the thicker and more homogeneous the burial medium, the better. Fractures,
sub-strata of lower permeability, and other heterogenlties which reduce the
ability to predict how and where contaminants may migrate should be subtracted
from the overall thickness of the burial medium when they are encountered. The
thickness and stratigraphy of underlying strata down to the base of the shallowest
confined aquifer should also be determined.
ENGINEERING Qualitative Good Bad 4
PROPERTIES
The ease and facility with which burial medium can be worked in landfllling and
burial operational the easier the medium can be worked, the better. This factor
relates to the economics and engineering factors of disposal. A site and burial
medium might otherwise be ideal; however, if the burial medium Is too cemented
or too indurated to rip or to work, the site cannot be used. A silty sand strata
which can be easily excavated by dragline or bulldozers, and which would form
trench walls that stand vertical seems to approach the ideal (See AASHO
Classification of Soils).
PERMEABILITY Gallons/day/foot2 0.1 10 (max) 4
.001 (min)
Permeability of burial medium in gallons/day/ft2; burial media with permeabilities
in the range of 0.1 g/d/ft2 are more desirable; permeabilities significantly
higher or lower are generally less desirable. The permeability of underlying strata
down to the base of the shallowest confined aquifer should also be determined.
EFFECTIVE Per cent Intermediate Too high
(Ma:
low
POROSITY 1 9R1 0*° scale vet) (Max) Too
Effective porosity of burial medium in per cent; burial media with intermediate
effective porosltes are more desirable, effective porosites which are too high or
low are undesirable. No range of acceptable values or "ideal" intermediate value
have been arrived at yet. The effective porosity of the underlying strata down
-------
to the base of the shallowest confined aquifer should also be determined.
STRUCTURE Qualitative Simple Complex 4
The internal structure of the burial medium, the burial medium's relationship
to the strata underlying it, and structures within these underlying strata
should be determined. They all affect the ability to predict the movement of
contaminants after they leave the trench; the more simple the structure, the
better.
RATIO OF PAN Ratio 84 40
EVAPORATION
TO PRECIPITATION
MINUS RUNOFF
The ratio of pan evaporation to precipitation running off; the higher the
ratio, the better. (U. S. Weather Bureau Tech. Paper No. 37-1959).
HYDROGEOLOGIC Qualitative Simple Complex 5
,OMPLEXITY
The hydrogeologic complexity of the site in relation to local and near-Regional
hydrogeologic, the simpler and more predictable, the better.
SUITABILITY FOR Qualitative Easy Difficult 2
CONTROL OF THE
WATER TABLE
The degree to which the water table beneath the burial zone can be controlled by
dewatering or other engineering techniques; the easier It can be controlled, the
better. This factor is possible of marginal interest in Region IX because of
the potential for finding sites with deep water tables.
MONITORABILITY Qualitative Easy Difficult 3
The degree to which contaminants migrating from the site can effectively be
monitored; the easier they can be monitored, the better.
REMEDIABILITY Qualitative ^6J Difficult
The degree to which hydrologic and civil engineering manipulative actions can
effectively correct the failure of, or milit the threat to, the contaminant
affected by the site; the easier the corrective manipulation actions, the better.
Examples of remedial actions might include installing additional berms to divert
unexpectedly large snow-melt runoff or Installing a series of dewatering wells to
lower a water table that was threatening to rise into the burial zone during an
-------
HSDRADLIC GRADIENT Feet/mile 10 100 A
The gradient of the water table from the site down gradient along the travel
path(s) which contaminants from the site would migrate.
1253
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APPENDIX C
DESCRIPTION OF BIOLOGICAL SCREENING FACTORS
1. Endangered Species
PL 93-205 requires all Federal departments and agencies to insure that
actions authorized, funded or carried out by them do not significantly
jeopardize the continued existence of endangered and threatened species.
Fish and their habitat including species of fresh or salt water
fishes, crustaceans, and mollusks.
Wildlife and their critical habitats including nondomesticated
mammals, reptiles, amphibians, birds, and certain groups of
insects living in their natural environment. Cautionary note:
critical habitat for most species have not yet been determined so all
habitat may be judged critical until more precise determinations
have been made.
Plants and their habitat including grasses and vascular plants
living in their natural environment. Natural units of classification
of dominant species associations and communities are identifiable
with the various climatic zones in the Western States.
2. Designated Areas of Biological Interest
An active program exists for the preservation by formal classification of
areas of unique biological interest, scientific values or educational
opportunity and for other purposes. These areas may or may not be included
in the National Registry of Natural Landmarks. This factor is concerned
not only with those areas in which values have been identified and
designated, but with the potential for future designation as well.
a. Research Natural Areas (many agencies, universities, etc., have
similar programs currently coordinated in California through the
California Natural Areas Coordinating Council).
b. Botanical Areas (Including areas of ecological interest).
c. Zoological Areas.
d. Wildlife Refuge.
3. Wild free-roaming Horses and Burros
PL 92-195 establishes wild free-roaming horses and burros as an integral
part of the natural system of the public lands and directs that all
management activities shall be conducted so as to achieve and maintain a
thriving natural ecological balance on these lands regarding wild horses or
burros territory and their vital habitat.
-------
Vital Habitat for Fish and Wildlife
For a wildlife species to survive and thrive, habitat needs for all stages
of its life cycle must be met. Some stages often have extremely critical
requirements, while others are much less sensitive to habitat conditions.
The welfare of the species can, in part, be accommodated by focusing
management attention on those stages most critical and assuring that required
habitat conditions are met. Since both critical life cycle stages and the
characteristics of required habitat vary from species to species, an all-
inclusive checklist of critical requirements cannot be made. Vital habitat
elements for some of the many species are presented but the list is intended
to be suggestive only.
a. Migration routes.
b. Wintering areas.
c. Water sources in areas of limited supply.
d. Spawning areas.
e. Nesting and fledging habitat.
f. Calving, fawning, kidding, etc., areas.
g. Breeding areas.
h. Competition pressures.
1255
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Afp
ch
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(e) The proposed hazardous-waste disposal site should represent the
ultimate in environmental safety. Large volumes of
untreated liquid wastes shall not be deposited directly onto or into
the earth. Burial, infiltration, and soil mixing of untreated wastes
shortens the operational life of the site, and increases the potential
for eventual leachate or water pollution. In addition, materials of
potential value are rendered more difficult, if not impossible, to
recover at a future time. Bulk liquid waste should be treated prior to
disposal. This may include physical, chemical, and biological treatment.
Sludges, solids, concentrates, and other residues resulting from such
treatment shall be disposed of by engineered burial. Records should be
maintained in the event that future recovery and reclamation may be
justified. Large volumes of treated aqueous waste are best disposed of
by solar evaporation if the climate allows. Other types of wastes, such
as low-volume materials or extremely hazardous wastes, may be more difficult
to process prior to disposal and should be buried in containers in engineered
trenches. The area accepting untreated hazardous wastes should
remain separated from that accepting residues treated to inertness.
(f) Disposal sites will be required to maintain operations for
temporary storage, processing for disposal, disposal, and engineered long-term
storage. Intermediate-term storage for purposes of eventual reclamation
of wastes will not be required, but will be allowed as an operator's
option, as long as the additional storage capability does not interfere
with efficient operation of the disposal facility.
.101 Definitions.
As used in these guidelines:
(a) "Cell" means compacted solid or hazardous wastes that are enclosed
by natural soil or cover material in a disposal site.
(b) "Cover material" means soil or other suitable material that is
used to cover solid or hazardous wastes in a disposal site.
(c) "Disposal" means to abandon, deposit, or otherwise discard waste
as a final action after its use has been achieved or a use is no longer
intended.
(d) "Engineered burial" means the systematic burial and daily cover
of wastes in trenches, pits, or vaults designed by qualified engineering
personnel. The trenches, pits, or vaults may include but are not limited to
impermeable liners, access ramps, proper sloping, leachate collection facilities,
and final cover with properly sloped, impermeable soil.
(e) "Groundwater" means water present in a saturated zone beneath
the land surface.
(f) "Hazardous waste" means any waste material or mixture of wastes
that is toxic, pathogenic, corrosive, flammable, an irritant, a strong sensitizer,
or which generates pressure through decomposition, heat, or other means.
In addition, these wastes or mixtures of wastes can cause substantial personal
injury, serious illness or harm to man or wildlife, during or as a proximate
result of any disposal of such waste or mixture of wastes. The terms
"toxic," "corrosive," "flammable," "irritant," and "strong sensitizer" shall
be given the same meaning as in the Code of Federal Regulations, Title 16
NOTICE
TOs document Is In pr*MMrr 4nfl It tat Ml
been formally released MMand should not« M*
stage by construed to represent Agency policy. It
is being circulated for comment on its tecttnfeil
accuracy and polity Implications.
125?
-------
(g) "Holding" means short-term storage of hazardous wastes.
(h) "Incompatible wastes" means any two or more wastes that, when
combined or mixed in an uncontrolled manner, can cause or create the potential
to cause explosions, violent chemical reactions, fires, extreme heat,
toxic substance formation, hazardous waste discharge, or any other event
that may endanger the public health or environment.
(i) "Intermediate cover" means cover material that must resist erosion
for an indeterminate period of time, pending terminal use and final disposition
of the site.
(j) "Intermediate-term storage" means storage of wastes in physically
retrievable form for future recovery.
(k) "Leachate" means liquid that has percolated through or from solid or
hazardous waste and has extracted dissolved or suspended materials from it.
(1) "Licensing/regulatory agencies" means the organization elements that
have the legal duty to ensure that operators or users of disposal
sites comply with these guidelines.
(m) "Long-term storage" means storage and control of wastes that are
too hazardous to release to the environment via known disposal technology,
e.g., wastes that might return to the biosphere before a degradation process
is completed. Such long-term storage should be prepared in an engineered physicall
retrievable form for future treatment for recovery or burial.
(n) "Municipal solid wastes" means normal residential and commercial
solid waste generated within a community. This solid waste is composed of
garbage, refuse, sludges, and other discarded solid materials resulting from
industrial and commercial operations and from community activities.
(o) "Processing" means to treat, detoxify, neutralize, incinerate,
bio-degrade, or otherwise process a hazardous waste to remove its harmful
properties or characteristics for disposal.
(p) "Residue" means all materials that remain after completion of
any pretreatment.
(q) "Runoff" means the portion of precipitation and/or applied water
that drains from an area as surface flow.
(r) "Sanitary landfill" means a disposal site employing an
engineered method of disposing of solid wastes in a manner that
minimizes environmental hazards by spreading the solid wastes in thin
layers, compacting the solid wastes to the smallest practical volume, and
applying and compacting cover material at the end of each operating day.
(s) "Short-term storage" means the temporary storage of wastes only
until disposal or processing operations can be applied.
(t) "Sludge" means the accumulated semiliquid suspension of settled
solids deposited from wastewaters or other fluids in tanks or basins.
It does not include solids or dissolved material in domestic sewage or
other significant pollutants in water resources, such as silt, dissolved
or suspended solids in industrial wastewater effluents, dissolved
materials in irrigation return flows or other common water pollutants.
(u) "Vector" means a carrier that is capable of transmitting a waste
from one organism to another, or away from the disposal site.
(v) "Water table" means the upper surface of a body of groundwater.
NOTICE
TM* dMMMt h to pnlinrirary draft It •• Mt
been formally released kpM and should Ml «t (Ml
stage by construed to r«pre*»irt AfMCT l
is being clrcuhM fir ••Pint «i tt»
accu.acy and policy
125.8
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Part B-Requirements and Recommended Procedures
.200 Hazardous waste accepted.
.200-1 Requirement.
The site shall be designed and equipped to identify, accept, process, detoxify,
store, and dispose of most hazardous materials. It shall be capable of
accepting waste materials, which if handled at an inferior facility could
result in severe hazard to human health and the environment. The site
shall be capable of long-term engineered storage so that it can accept
materials which cannot be safely disposed of to the earth and for which
no satisfactory treatment exists.
.200—2 Recommended procedures:
Design.
Equipment and facilities at the disposal site should be designed to
ensure safe and convenient acceptance and inspection of hazardous wastes
at the site.
.200-3 Recommended procedures:
Operations.
(a) Special techniques of certifying the character of waste, segregating
it into classes for handling, and moving it to processing, storage, or
disposal sites should be used.
(b) Procedures for handling especially bulky wastes, or wastes in
unusual volume or state should be made a part of standard operating plans.
(c) There should be stringent waste identification requirements in any
acceptance plan. All detailed analysis or characterization is the
responsibility of the site user. All potential site users should notify
the site prior to the delivery of any new waste to the site.
(d) The site operator should evaluate each new waste to be disposed
at the site. A written storage/disposal plan should be prepared for each
new waste prior to its acceptance at the site.
(e) A blanket permit may be granted for up to jne year for disposal
of recurring waste items as long as the waste characteristics remain the
same as described in the original application. Recurring waste, for which a
waste permit is in effect, may be accepted upon 24 hours' notice to the site
operator. The permit and disposal plan for a recurring waste should be
renewed at least once every 12 months.
(f) Each incoming waste load should be inspected upon delivery to the
site to ensure proper identification and characterization.
(g) At least one person on the site operations staff should be involved
full time in accepting, inspecting, and sampling incoming waste loads.
(h) An analytical laboratory for screening and inspecting should be
operated on the site.
NOTICE
This document b ta priltalMry drift It to *>»
,. „ c A betn formally released *•» ^ *»»* "° rt » '
12 S3 ««. b, construe* M •*•«•«* Agency pocy.lt
is being circulated lor comment on lU b"**
=jcuiacy and policy
-------
.201 Hazardous wastes excluded.
.201—1 Requirement.
(a) The licensing/regulatory agencies and the site owner/operator shall
jointly determine specific hazardous wastes to be excluded, shall identify
them in the plans, and shall display a description of excluded wastes to
the users and the operating personnel.
(b) Hazardous wastes may be excluded at the operator's discretion
if:
(1) The waste is too hazardous for release to the environment by
disposal or possible escape from storage or transports, and full or
partial detoxification technology exists.
(2) Conversion is necessary to render the wastes suitable for storage
or disposal and is not available at the site.
(3) The waste is incompatible with site restrictions or a more suitable
hazardous waste site is reasonably proximate.
(c) Appeals to such discretionary decisions can be made to the licensing/
regulatory agencies, which may then require the acceptance of the waste for
disposal .
.201—2 Recommended procedures:
Design.
Provision should be made for the continuing assessment and evaluation
of both the site and new or changing waste types to derive recommendations
for acceptance or rejection by the licensing/regulatory agencies.
.201—3 Recommended procedures:
Operations.
All users of the site should be provided with up-to-date lists of
excluded wastes. These lists should be prominently displayed at the entrance
to the site. Exclusion rules should be rigorously enforced for all users.
.202 Site selection.
.202-1 Requirement.
Site selection and use shall be consistent with public health and
welfare, air- and water-quality standards, and appropriate land-use plans.
The selected site shall have the maximum capability to isolate wastes
from the environment as well as to observe, control, and monitor the
wastes and their by-products or effluents in perpetuity.
.202—2 Recommended procedures:
Design.
Not applicable.
NOTICE
This document Is In preliminary draft. It Ins i
baen formally released MM and should not at II
'i'ge by construed to represent flg:ncy policy.
's being circulated for comment on its technu
^uraoy and policy implications.
1260
-------
.202—3 Recommended procedures:
Operations.
"Hazardous Waste Land Disposal Site Screening/Selection
Guidelines," developed by the Hazardous Materials Management Task Force,
Western Federal Regional Council should be the preferred site-selection
tool so as to ensure that,environmental, political, and sociological
tradeoffs are addressed.( '
.203 Site Design.
.203-1 Requirement.
(a) Plans for the design, construction, and operation of new sites or
modifications to existing sites shall be prepared and approved by a registered
professional engineer and shall be submitted to the licensing/regulatory
agencies for review and approval prior to any operation. The design shall
maximize the isolation of wastes and all processing and operations from
the ground- and surface-water resources, from the public, and from wildlife.
(b) The design shall include all facilities necessary to ensure safe
and environmentally acceptable operation of the site.
(c) The site's operational design shall maximize the capacity of the
area to accept wastes.
(d) An environmental assessment shall be prepared for the licensing/
regulatory agencies before the plan and design of the site is completed.
.203—2 Recommended procedures:
Design.
(a) The design should be based on a thorough survey of the types
and volumes of hazardous wastes to be handled.
(b) The design should fully recognize the requirements for segregation
of incompatible wastes, the need for separate facilities for processing,
conversion, temporary storage, and disposal of wastes, and for the long-term
monitoring of the waste and site effluents.
(c) Site development plans should include the various design factors
addressed elsewhere, as well as:
(1) Hazardous Materials Management Task Force, Western Federal Regional
Council, "Hazardous Waste Land Disposal Site Screening/Selection
Gutde"nes-" <1975)' NOTICE
This document Is In prenmtaary drift It to not
been formally released 4M and should not at Ms
stage by construed to represent Agency policy. It
Is being circulated for comment on its technical
accuracy and policy implications.
1261
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(1) Initial and final topographies at contour intervals of 1 foot or
less.
(2) Land use and zoning within 10 miles of the site boundary, including locatio
of all residences, buildings, wells, water courses, mining operations,
roads, soil or rock borings, and water-supply utilities.
Location of all other utilities should be known within 500 feet of the
site boundary.
(3) Employee convenience and equipment maintenance facilities.
(4) Determination of soil excavation and compaction characteristics.
(5) Plans for construction, land removal and replacement, and building
placement.
(6) Plans for cutoff walls, impermeable barriers, and berms to
isolate or contain wastes. Also, plans for drainage ditches and diversion
structures to control runoff, spills, seepage, effluent from washdown areas,
and leakage from repackaging and processing areas.
(7) Plans for design and operation of areas for short-term storage of
wastes.
(8) Plans for retrievability of wastes that can be converted or
otherwise processed after storage.
(9) Area! extent of soil types, faults, and active and potential
landslip areas.
(10) Local wind patterns.
(11) Plans for segregation of wastes into compatible groups based on
recoverability (e.g., heavy metals, etc.) and chemical reaction prevention, etc.
(12) Plans for final grading and cleanup so as to close the site and
maintain it under surveillance.
(13) Intended points of entrance and exit.
(14) Interior roads and ramps with traffic flow patterns.
.203—3 Recommended procedures:
Operations.
Not applicable.
NOTICE
not
s-
1262
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.204 Water quality.
.204—1 Requirement.
The location, design, construction, and operation of the site
for hazardous waste conversion, storage, or disposal shall ensure reasonable
nondegradation of water quality. If standards for particular facets of
water quality exist, the site shall conform to the most stringent of
applicable water-quality standards established in accordance with or
effective under the provisions of the amended Federal Water Pollution
Control Act, '' the Safe Drinking Water Act,^' or other applicable more stringent
standards.
.204-2 Recommended procedures:
Design.
(a) The general criteria established by the California State Water
Resources Control Board for Class I sites are recommended as criteria in
selection and design of the site with regard to protection of water
quality.(3)
(b) In addition, the following topics should be addressed:
(1) Detailed determination of the groundwater and surfacewater
occurrence, natural water quality, and flow regimens within the site and
at least 1 mile beyond the site boundary.
(2) An inventory of all water uses within the potential area of
influence of the site, with projections of future potential uses.
(3) Sufficient determination of the regional groundwater and surfacewater
systems so that the effect of future land use in the immediate vicinity
can be projected in terms of site impact.
(4) Groundwater elevation and movement and the proposed separation
between the water table and any wastes in whatever mode of storage or
disposal.
(5) A thorough inventory of historical records and sources of information
on the local aquifers and surfacewaters to permit identification of
possible long-term hydrologic changes that may influence site design
and management.
(6) Description of the soil and geologic materials to a depth adequate
to allow evaluation of the water-quality protection provided by the soil
and geologic materials.
(1) PL 92-500 "Federal Water Pollution Control Act." (U.S. Code, Title 33,
Sec 1151, et. seq.)
(2) PL 93-523 "Safe Drinking Water Act."
(3) Title 23, Chapter 3, Subchapter 15, California Administrative Code,
"Waste Disposal to Land." NOTICE
This document h in prelimin.ry dr.ft. It his »«
been formally released IpWtand should not at tfctt
stage by construed to represent *&«-
12G3 Is be,ng circled for cormwrt on its
-.eciracy and policy implications.
-------
(7) An evaluation of potential leachate and effluent generation, and
the proposed control system for excluding it from the hydrologic environment.
(8) A detailed analysis of the background quality of water resources
in the potential zone of influence of the site. The analysis should
include (but not be limited to) measurements of: pH; hardness; BOD; COD; the
ionic, molecular, and/or atomic composition of suspended and dissolved
material at trace levels; and the types and concentration of organisms
which may be present. The background quality should be monitored for at least
one year prior to operations.
(9) The intended water-quality monitoring program, which must include
monitoring provisions during operation of the site and afterwards until
the site is no longer a credible threat to water quality.
.204—3 Recommended procedures'.
Operations.
(a) Surfacewater courses and runoff should be completely controlled
within the site so as to exclude all surfacewater inflow to the site,
to prevent infiltration to the greatest extent possible, and to channel
runoff from the site to treatment facilities or to other approved disposal
facilities. Site construction and grading should be such as to avoid
ponding or flooding and to avoid erosion. All effluent or surface runoff from
the site should be collected and treated to assure no discharge of
hazardous materials from the site. Hazardous wastes and leachates should
be continuously monitored to prevent contact with groundwater and surfacewater
resources.
(b) The site operator should be aware of the bases for all design
features and operating procedures so that any unforeseen circumstances
which can affect water quality may be properly evaluated.
(c) An analytical laboratory should be available for doing
routine water-quality analyses including, but not limited to, trace
elements, organic and inorganic compounds, and indicator or pathogenic
organisms.
.205 Air quality.
.205-1 Requirement.
(a) The site design, facilities, and operation shall be planned to
minimize the discharge of dangerous levels of .airborne hazardous materials
into the working environment of the site or the surrounding area.
NOTICE
This document is In preliminary draft. II hu «e»
been formally released «•** and should not at this
stage by construed to represent Agency policy. It
is being circulated for comment on its technical
accuracy and policy implications.
1261*
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(b) If standards for particular facets of air quality exist, the
design, construction, and operation of the facility shall conform to
applicable ambient air-quality standards and source-control regulations
established under the authority of the Clean Air Act.O) as amended, or state
or local standards effective under that Act, or other applicable, more
stringent standards.
.205—2 Recommended procedures:
Design.
(a) The site should be equipped with or have available,
state-of-the-art equipment for collecting, measuring, and analyzing the
airborne emissions of materials.
(b) All unit operations at the site should be equipped to adequately
prevent the discharge of dangerous levels of airborne hazardous materials.
(c) The monitoring plan should also include periodic on-site and off-site
sampling and analysis of soils and flora in order to detect the accumulation
of deposited hazardous substances that may have been discharged through the air.
(d) A detailed study of the meteorology of the site and its environs
should be performed in order to: determine the frequency and extent of
unfavorable and extreme weather; locate specific operational features
within the site; guide the planning of a monitoring program; and determine
preoperational ambient air quality.
.205-3 Recommended procedures:
Operations.
(a) Dust-control measures should be initiated as necessary to protect
the health and safety of facility personnel and nearby populations.
(b) A comprehensive air-quality monitoring program should be designed
to cover the period of operation of the site and until such a time that
the site is no longer a credible threat to air quality.
.206 Gas control
.206—1 Requirement.
Vapors and decomposition gases generated within the disposal site
shall be controlled on site, as necessary, to avoid posing a hazard to
occupants of adjacent property.
(1) PL-604 "Clean Air Act" (U. S. Code, Title 42, Sec 1857, et. seq.)
NOTICE
This document Is In preliminary draft. It 1m not
been formally released <••• and should not at this
stage by construed to represent Agency policy. It
is being circulated for comment on its technical
accuracy and policy implications.
1265
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.206-2 Recommended procedures:
Design.
Plans should assess the need for vapor and gas control and indicate the locatio
and design of any vents, barriers, or other control measures to be
provided.
.206-3 Recommended procedures:
Operations.
Vapors and decomposition gases should not be allowed to migrate
laterally from the disposal site to endanger occupants of adjacent properties.
They should be vented to the atmosphere directly through the cover material,
cutoff trenches, or ventilation systems in such a way that they do not
accumulate in explosive or toxic concentrations, especially within
structures.
.207 Vector control and wildlife protection
.207-1 Requirement.
Conditions shall be maintained that discourage the incursion, harboring,
feeding, and breeding of vectors.
.207—2 Recommended procedures:
Design.
Plans should include contingency programs for vector control and wildlife
protection and the operator should be prepared at all times to implement those
procedures.
.207-3 Recommended procedures:
Operations.
Vector control or wildlife protection contingency programs should be
implemented when necessary.
.208 Aesthetics.
.208—1 Requirement.
(a) The disposal site shall be designed and operated at all times
in an aesthetically acceptable manner.
(b) The disposal-site operator shall maintain a continuing program
to ensure orderly and systematic operation of the site so as not to
create odors and other public nuisances to neighboring communities, residents,
or other persons frequenting the area.
NOTICE
This document is In preliminary draft It hat rut
been formally released^!** and should not at this
stage by construed to represent Agency policy. It
is being circulated for comment on its technical
-ccuracy and policy implications.
1266
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(c) Programs shall be implemented to cover the handling, returning,
and disposing of emptied containers.
Operational noise will be minimized.
An effective litter-control program shall be included.
(d)
(e)
.208-2 Recommended procedures:
Design.
Not applicable.
.208-3 Recommended procedures:
Operations.
Not applicable.
.209 Cover material .
.209—1 Requirement.
Cover material shall be applied as necessary to minimize resuspension of
soil or wastes, fire hazards, infiltration of precipitation, odors, and blowing
litter; control gas venting and vectors; and shall be compatible with the
surrounding natural environment.
.209—2 Recommended procedures:
Design.
Plans should specify:
(a) Cover material sources and soil classifications.
(b) Surface grades and side slopes needed to minimize infiltration and
to promote maximum runoff without excessive erosion.
(c) Procedures to promote vegetative growth as promptly as possible
to combat erosion and improve appearance of idle and completed areas.
(d) Procedures to maintain cover material integrity, e.g., regarding
recovering.
.209—3 Recommended procedures:
Operations.
(a) Intermediate cover should be applied on areas where additional
cells are not to be constructed for extended periods of time; normally,
one day to one year.
(b) Final cover should be applied on each area as it is completed
or if the area is to remain idle for over one year.
NOTICE
Htft don*** H m prtllrtMfy drift
DM* fcrmttty wlMMd «•* «ml sho"
sttp by cflMtrurt to represent Ajencsr
is b*i«f drculitod for commsnt «l «$
accuracy W *«<»
1267
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.210 Safety.
.210-1 Requirement.
OSH/r 'and health and safety working orders of state and
local governments shall be observed as they relate to the general working
environment; design, operation, and maintenance of equipment; and the
handling of hazardous substances. A vigorous and continuing accident-
prevention and safety program shall be instituted at the site.
.210-2 Recommended procedures:
Design.
Adequate design, facilities, and equipment should be available to
ensure the safe handling of hazardous wastes and to respond to
emergencies that may arise. Storage areas should be designated as high-
security areas. All temporary storage should be protected from contamination
degradation, and loss.
.210—3 Recommended procedures:
Operations.
In preparation of the general operating plans of the site, safety
precaution and contingency procedures should be detailed. Site
personnel should know the characteristics of hazardous
wastes. They should be thoroughly trained for the proper operation and use o
equipment and safety gear, and on proper accident-prevention and emergency
procedures. They should be thoroughly familiar with chemical hazards.
.211 General operations.
.211-1 Requirements.
General operations shall be coordinated to assure that they are
compatible with the physical characteristics of the site
and provide for the health and safety of operating personnel.
(1) PL 91-596 "Occupational Safety and Health Act." (U. S. Code, Title 29,
Sec. 651, et. seq.) NOTICE
This document Is In preliminary draft It has not
been formally released ^Mfc and should not at thlt
stage by construed to represent Agency policy. It
is being circulated for comimnt on its tMhntoll
jccu.-acy and policy implication.
1268
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.211-2 Recommended procedures:
Design.
(a) A plan should be prepared that details all operations at the site.
It should include:
(1) Description of sequence of operations.
(2) Evaluation of waste compatibility.
(3) Periodic maintenance schedule.
(4) Emergency plans.
(5) A medical monitoring program.
(6) A safety program.
(b) The operational plan should not be confused with the planning and
design stages, which details the specific components of the site. The
plan should be kept current and contain information relating to site
operation.
(c) The operational plan should include a flow scheme indicating how
various wastes are processed, reclaimed, or disposed of, and should also
include the proposed development stages of processing systems or waste-disposal areas.
.211-3 Recommended procedures:
Operations.
(a) Operational details that should be included in the plan are:
(1) Acceptance of wastes.
(2) Monitoring and analysis of wastes.
(3) Safety and emergency procedures.
(4) Transportation of wastes within site.
(5) Unloading of wastes.
(6) Holding and storage of waste.
(7) Processing of waste.
(8) Disposal of waste.
(9) Equipment maintenance.
(10) Personnel qualifications.
(11) Record keeping.
(12) Site security.
(b) The operational plan should be reviewed periodically by the operator
and the licensing/regulatory agencies to ensure its adequacy.
.212 Records.
.212-1 Requirement.
The owner/operator of the disposal site shall maintain and
provide records and monitoring data to the licensing/regulatory
NOTICE
This doMMt b hi irttMMry draft It hn nt
been formally nktMd ••• and should not at tMs
stage by construed to represent Agency policy. It
is being circulated for comment on its technical
accuracy a*) policy
-------
.212-2 Recommended procedures:
Design.
(a) Plans should prescribe methods to be used in maintaining records
which document the operations of the disposal site. Information on
recording and monitoring requirements should be obtained from the
licensing/regulatory agencies.
.212—3 Recommended procedures:
Operations.
(a) Records should be maintained covering at least the following:
(1) Major operational problems, complaints, or difficulties.
(2) Qualitative and quantitative evaluation of the environmental
impact of the disposal site, with regard to the effectiveness of gas and
leachate control, including results of: (i) leachate sampling and analyses;
(ii) gas sampling and analyses; (iii) groundwater- and surfacewater-quality
sampling and analyses upstream and downstream from the site.
(3) Vector control and wildlife protection efforts.
(4) Dust--and litter-control efforts,
(5) Inventory of waste identification and location for all wastes
on the site (in perpetuity).
(6) Major site operations, especially with respect to their effects .
on the soil profile, topography, etc.
(7) Local meteorological data for a period of 10 years. These data
should include, but not be limited to, records of precipitation,
wind speed and direction, average daily temperature, and relative
humidity.
(8) Personnel health records.
.213 Monitoring and surveillance.
.213—1 Requirements.
Plans shall detail methods for detecting discharge of hazardous
materials from the site (in perpetuity), hazardous operations, hazardous
designs in the site, and creation of aesthetically unpleasing situations.
The licensing/regulatory agencies shall participate in monitoring and surveillanc
activities.
.213—2 Recommended procedures:
Design.
Not applicable.
.213—3 Recommended procedures.
Operation.
Not applicable.
NOTICE
1270
This fccmtiit h In prtHmimry dr«ft It h« not
been hrmilly teltwed »•» »nd should not it »b
stage fc construed to rtpresent Agency policy, it
is being circulated for comment on its techofctt
accuracy mi policy implications.
-------
.214 Quality-assurance program.
.214-1 Requirement.
A quality-assurance plan shall be written to cover all structures, systems,
components, and operations whose proper function is necessary to prevent
uncontrolled release of hazardous materials to the environment.
.214—2 Recommended procedures:
Design.
The foremost objective of the quality-assurance program should be to
assure that the site operator's procedures offer maximum protection to the
environment, all commensurate with the scope, complexity, and duration
of the task being undertaken.
.214—3 Recommended procedures:
Operations.
(a) As a minimum, the plan should include the following key elements:
a definite assignment of organizational responsibility for quality; a means
of specifying the level of quality required for the job; the procedures
for implementing the quality-assurance program; and an independent system
for verifying compliance with and adequacy of quality requirements.
(b) Consideration should also be given to inclusion of the following
elements in establishing a quality-assurance program:
(1) Indoctrination, training, and qualification of personnel.
(2) Document review and approval.
(3) Document release and change control.
(4) Control of interim storage and final burial of waste materials.
(5) Inspection, examination, and testing of waste materials when delivered
to the site.
(6) Measuring- and test-equipment calibration and control.
(7) Lifting, handling, storage, and shipping control.
(8) Nonconformance reporting and analysis.
(9) Corrective-action control.
(10) Process and equipment qualification.
(11) Operations control.
(12) Records collection, storage, and maintenance.
(13) An internal audit system to assure that actions of the plan are
properly implemented and that the plan is updated when necessary.
NOTICE
to recent Agency
is Mini elreutated for comment on it»
accuticy wd policy implicttions.
1271
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Appendix-Recommended Bibliography
1. Banta, J.» et al. Sanitary landfill; manual of engineering practices,
No. 39, American Society of Civil Engineers, 1959.
2. Black, C. A., D. D. Evans, J. L. White, L. E. Ensminger, F. E. Clark,
and R. C. Dinauer, EDS. Methods of soil analysis, Pt. 1. Physical and
mineralogical properties, including statistics of measurement and
sampling. Madison, His., American Society of Agronomy, Inc., 1965.
3. Brashares, W. C., and R. M. Golden. Occupational Safety and
Health Act. Special bulletin. Washington, National Solid Wastes Management
Association, 1972.
4. Brunner, D. R. and D. J. Keller, Sanitary Landfill Design and Operation,
Washington, U. S. Government Printing Office, 1972, 59 p.
5. Ottinger, R. S. et al, Recommended Methods of Reduction,
Neutralization, Recovery or Disposal of Hazardous Wastes, U.S. EPA,
,16 Vol. NTIS, U. S. Dept. Commerce, 5285 Port Royal Road, Springfield,
Virginia, 22161.
6. Zausner, E. R. An accounting system for sanitary landfill
operations. Public Health Service Publication No. 2007. Washington, U.S.
Government Printing Office, 1969. 18 p.
7. Federal Environment Pesticides Control Act of 1972; Public Law
92-516, 92d Cong., H.R. 10729, Oct. 21, 1972. Washington, U. S. Government
Printing Office, 1972.
8. -Guidelines for Hazardous Waste Land Disposal Facilities -
California Department of Health, 1973.
9. - Handbook of chemistry and physics. 54th ed., Cleveland, CRC
Press, Inc., 1973.
10. -Hazardous Waste Management, California Department of Health,
1973.
11. -The Solid Waste Disposal Act as amended; Title II of Public Law
89-272, 89th Cong., S. 306, Oct. 20, 1965; Public Law 91-512, 91st Cong.,
H.R. 11833, Oct. 26, 1970. Washington, U.S. Government Printing Office,
1971. 14 p. Reprinted 1972.
NOTICE
This toniMfit Is In preliminary draft. It has no*
been formally released ^•fc^nd should not at this
stage by construed to represent 't^ncy po'icy. It
is being ci-culated for comment on its technical
•-cu.-acy and policy implications.
1272
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Department of Defense
Office of the Assistant Secretary
for Health and Environment
Washington, D.C. 20301
JAN 15 1976
Mr. Charles Bourns
EPA (Rm 358)
100 California Street
San Francisco, Calif. 94111
SUBJECT: DoD Management of Waste Hazardous Materials
The subcommittee for the inventory and assessment of
Department of Defense waste hazardous materials respect-
fully submits the following report. All inventory data
was furnished by the Defense Supply Agency, Cameron
Station.
The Purpose of the subcommittee was to identify the
location, condition, and quantity of waste hazardous
materials generated by DoD installations within Region
IX. In order to limit the scope of the endeavor, the
following definition of hazardous materials was utilized:
"Those wastes that pose a substantial danger immediately
or over a period of time, to human, plant, or animal life
and as such must be handled and disposal effected with
special precautions."
Approximately thirty DoD installations within Region IX
are listed as possessing excess hazardous materials:
almost all of the material was pesticides and herbicides
and these items, other than DDT, were being disposed through
contractor operations .
During the past year, the Agency for International Develop-
ment (AID) entered into an agreement with the Government
of Mexico whereby the GOM would purchase all of the DoD
DDT. Since the negotiations have not yet been finalized,
the DoD has decided to proceed with the disposal of DDT
overseas and in the Continental United States except in
those states in close proximity to Mexico namely, Arizona,
California, Louisiana, Mississippi, New Mexico, and Texas.
A stock freeze was imposed upon those six states and any
redrumming costs incurred subsequent to July 25th 1975,
will be billed to AID when the transfer to GOM takes place.
Upon review of the entire disposal system, it appears that
the Department of Defense/Defense Supply Agency program is
functioning satisfactorily. If there are any "problems",
1273
-------
they are minor and resolution has always been effected. We
recognized that new legislation addressing the hazardous
waste disposal problem will be forthcoming eventually.
Based upon this premise, the following recommendations are
offered to ensure that all hazardous wastes are disposed
of in an environmentally acceptable manner.
1. That the Environmental Protection Agency continue its
efforts to designate items/classes of items that will
require disposal consideration.
2. DSA continue to monitor the excess listings for materials
requiring special handling and disposal.
3. All DoD incinerators and land fill operations be surveyed
to determine capabilities, capacities, and conditions
of facilities.
4. A Federal Agency be designated as lead agency to manage
the hazardous waste disposal program.
5. The Interagency Committee on Resource Recovery (ICORR)
evalue the merits of interagency disposal proposals
vs. continuation of existing programs of contractor
disposal.
Sincerely,
John P . Meade
LTC, USAF
OASD (H & E)
Pentagon, Wash., B.C.
-------
/\fji''.f- ^ 'X \ ij- Fj
"DOD PESTICIDE 'IANAO1?ENT fi DISPOSAL" -- LTC John PT^caJc
(A Report to the Federal Rational Task Force for Hazardous Katerials
Management, Annual Meeting, November 12-13, 1974;
One innovative management tool introduced into the Department of
Defense last year, was the concept of management by objectives. Under
this program, departments and agencies have now identified their most
important goals, termed Presidential objectives, and have established
regular monitoring procedures. These proposed objectives are submitted
each year for review by the Office of Management § Bureau for further
refinement and then submitted to the President. If the President
accepts the objectives, the agency is held accountable for achieving
them. This year, the Deputy Assistant Secretary for Environmental
Quality had our proposal accepted. The proposal was to exercise
environmental control in the accomplishment of the military mission.
There are eight sub-actions supporting this action. I'll address
the sub-action by developing a program for control of hazardous material
during use and disposal operations and dispose of in environrientally
safe manner 501 of the hazardous materials declared excess.
The first sub-action was to develop a program for the control of
hazardous materials. The first step was to review all Department of
Defense Pest Control Programs. The Armed Forces Pest Control Board and
the Federal Working Group on Pest f-hnagement, who was under charter of
CEQ (Council of Environmental Quality), is now reviewing all the
Department of Defense Pest Control Programs for (1) use of registered
pesticides, (2) use of pesticides in accordance with labeling, (3) if
the use is inconsistent with labeling, then alternative pesticides and
newer methods of application will be evaluated, and (4) on minor use
pesticides, when the manufacturer cannot or will not register the item
for a minor use, the Department of Defense will then seek to act as its
1215
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own registrant. We will follow all of the EPA procedures for registration
as any other agency or company would. Our goal under this program is
to insure that the Department of Defense Pest tenagement Programs are
being conducted in an environmentally acceptable manner. The program
is on track in meeting the Nov 74 milestone.
The second sub-action is to survey excess hazardous materials.
The Department of Defense has gone to DSA for identification and survey
of excess hazardous materials. This phase of the program is just that,
identification and survey the materials to obtain an estimate of the
quantities and types of materials we possess. This procedure could
also involve the identification of potential markets. For Region IX,
we will be contacting the various military commands for a more accurate
inventory. Once this channel is established, the data can be periodi-
cally updated to reflect current problems. One special interest item
that may be noted, the matter of DDT disposal. This is being handled
by the State Department. They are into negotiations with the govern-
ment of Mexico now for transfer of the material. Points now under
discussion involved Department of Transportation repackaging require-
ments and acceptance by the government of >fexico for funding of the
program. Another item of interest is herbicide orange. The draft
environmental impact statement submitted by the Air Force proposed
at-sea incineration on the Dutch Ship, Vulcanis. The Dutch ship, the
Vulcanis, conducted similar incinerations for Shell several weeks
ago under supervision by EPA personnel. The preliminary data indicates
that most test objectives were satisfied. The Air Force is also
considering selling that portion of the orange that meets commercial
12*l6
-------
criteria as a result of EPA dropping an injunction against usage of
245T. The Vulcanis is the first and only ship of its kind, and this is
a new concept. Although Shell contracted for use of the ship last
summer, EPA with strong urging from the National Wild Life Federation
announced on September 27th, that an ocean dumping permit would be
needed for incineration; this is a critical point. The permit was
granted on 10 October. The research permit issued to Shell to test the
potentially invaluable alternative to conventional dumping authorizes
as many as four test burns. Each trip into the Gulf of Mexico, about
130 miles south of Galveston, will burn about 4200 tons of chlorinated
hydrocarbon waste. A preliminary review of the high temperature incin-
eration process shows that it should destroy well over 99.5 percent of
the wastes, by converting them into harmless carbon dioxide and hydro-
chloric acid droplets which will quickly turn to salt after falling into
the sea. Operating temperatures of 2500 to 5000 ° F will be used on the
sailing incinerator.
The next sub-action is identification of DOD toxic wastes. In
addition to the so called normal effluents, the DOD is identifying and
evaluating the potentially hazardous waste products of waste incinera-
tion, land filling operations, and recycling programs. We are now
concerned with lechates, sludges, viruses, and pathogens. The military
departments will be reviewing their operations in reporting on these
wastes. At this time we are concerned with identification of the
materials. Later, tasks will be levied to develop control techniques
and technology for safe disposal of toxic and hazardous solid and liquid
sludge waste. We do not anticipate any difficulty in laeeting our
12'H
-------
.April 1975 milestone in so far as emission inventories have already
been completed at DOD facilities.
The next sub-item is the modification of DOD training and certifi-
cation program to meet the Federal Working Group Pest Management Standards.
The Federal Working Group for Pest Management, under the auspices of the
Council on Environmental Quality, is currently evaluating the Federal
Pesticide Applicator Certification Programs. The Federal Insecticide,
Fungicide and Rodenticide Act, as amended, Public Law 92-516, requires
that pest control personnel applying restricted use pesticides become
certified by 22 Oct 1976. The government agency plan will have as a
minimm the most stringent of state standards. The plan calls for the
Federal Working Group on Pest Management to be the central contact point
for the Environmental Protection Agency, and will incorporate common
elements of agency certification plans into one unit, to insure compar-
ability and consistency of agency programs. The states may then recognize
the acceptability and uniformity of the agency plans. The agencies will
issue appropriate, uniform credentials verifying applicator certification.
The Federal Working Group Pest Management Program will furnish certifi-
cation information to the administrator, EPA, for evaluation. We do not
envision difficulty in meeting the milestone of May 1975 for this program.
- END -
12", 3
-------
UNITED STATES •.,;,.
DEPARTMENT OF THE INTERIOR
GEOLOGICAL SURVEY ^ L
Water Resources Division
3t5 Middlefield Road
Menlo Park, California 9^025
December 30, 1975
Mr. Charles Bourns, Chairman
Task Force for Hazardous Materials Management
Western Federal Regional Council
U. S. Environmental Protection Agency
100 California Street
San Francisco,,CA
Subject: Smnnary of results — Ad hoc subcommittee
for assessment of non-Defense Department
federal agencies for hazardous waste
Mr. Chairman:
Between June and November, 1975, all federal agencies other than the
Defense Department with offices or operations within Region IX were
requested by mail questionnaire to report their annual hazardous material
waste load. The results of the assessment were reported to you by letter
preliminarily on October 28 and in more formal detail on November 6, 1975-
The attached summarizes these results.
Very truly yours,
W. L. Bumnam
Assessment Chairman
Enclosure
1273
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ABSTRACT
f
Results of an Assessment of Civilian Federal Agency Hazardous Wastes
in Region IX
As an ad hoc conmlttee function of the WFRC Task Force for Hazardous
Ifeterial Management all Federal agencies within Region IX other than
Department of Defense were inventoried to assess annual load and type
of non-radioactive hazardous wastes. All agency units believed to
generate or have disposal responsibility for hazardous materials
resiDonded, except one (GSA did not respond). Methods and accuracy of
documentation of waste loads varied greatly among agency units, with some
unable to provide quantitative reports. Narrative descriptions of opera-
' tions, however, along with detailed accounting by most agency units
suggests the assessment was reasonably complete and the indicated annual
load reported was essentially correct, although probably a minimum value.
The forty-three units of the twenty-six agencies responding reported
more than 4,500 tons and from 250,000 to 350,000 gallons of hazardous
waste generated, with 8,000 to 10,000 containers requiring disposal. In
addition to these quantities, large amounts of hazardous materials in
small-volume lots are utilized annually in laboratories and in normal
operations of some agencies. These yield no reportable wastes, but
there is a large estimated additional container disposal load not accounted
for in the reports.
Other than the large volume of non-radioactive waste materials resulting
from specialized functions of the Nevada Test Site (ERDA), the majority
of wastes and containers are the result of herbicide and pestcide uses
by the land-management agencies. Minor quantities of chemical wastes are
developed through laboratory functions and enforcement or policy activities.
The points of generation are widespread within the Region, and disposal
through commercial facilities, through return of unused materials and
containers to suppliers, and by modification or neutralization does not
appear to be a serious problem.
In addition to the indicated volumes and locations of waste generation,
the assessment revealed a need for more detailed and precise procedures
by most agencies and offices for the recording and documentation of
hazardous material handling. Such procedures, if utilized by all agencies,
would most probably reveal a waste material and container load considerably
greater than that indicated by the assessment.
-------
Task Force for Hazardous Materials Management
Western Federal Regional Council
Non-Defense Agency Assessment Subcommittee
Agency Assessment Listing
Key to Agency responses:
1. Report annual types and quantities of wastes.
2. Report annual types and quantities acquired, on-hand, or
used—waste quantities estimated.
3. Report annual types and quantities stocked or on-hand—waste
quantities not reported or estimated.
4. Report negative—no wastes requiring disposal.
5. Did not submit a report.
-------
I. Dept. of Agriculture (USDA)
A. Animal and Plant Health Inspection Service
1. California/Nevada District-Sacramento 4
2. Alameda, California
a. Hawaii/Pacific Islands 4
b. San Pedro, California 1
c. San Diego, California 1
d. San Francisco, California 1
e. San Luis, Arizona 1
f. Travis AFB, California 1
g. Nogales, Arizona 3
B. Agricultural Research Service
1. Berkeley, California
a. Brawley, California 1
b. Albany, California 1
c. Fresno, California 1
d. Indio, California 1
C. Forest Service
1. San Francisco, California, Region 5 3
2. Albuquerque, New Mexico, Region 3 1
3. Pacific SW Forest and Range Experiment
Station, Berkeley, California 1
4. Intermountain Forest and Range Experiment
Station, Ogden, Utah 4
5. Rocky Mountain Forest and Range Experiment
Station, Ft. Collins, Colorado 4
II. Dept. of Health. Education & Welfare (HEW)
A. San Francisco, California, Regional Office 4
B. Food and Drug Administration, Region IX 3
12G2
-------
III. Dept. of Housing & Urban Development (HUD)
A. Environmental Clearance Office, Los Angeles, CA 4
IV. Dept. of the Interior (USDI)
A. Bureau of Land Management
1. State Office, Sacramento, California
a. Folsom, California 1
b. Bakersfield, California 1
c. Riverside, California 1
d. Susanville, California 1
e. Ukiah, California 2
2. State Office, Reno, Nevada 1
B. Bureau of Reclamation
1. Mid-Pacific Region, Sacramento, California
a. Folsom, California 1
b. Willows, California 1
c. Red Bluff, California 1
d. Redding, California 1
e. Fresno, California 1
f. Tracy, California 1
C. Geological Survey
1. Regional Offices, Menlo Park, California 2
D. National Park Service
1. Western Region, San Francisco, California
a. Parks and sites in Arizona, California
and Hawaii 1
V . Dept. of Transportation (DOT)
A. U. S. Coast Guard
1. Twelfth Coast Guard District, San Francisco, CA 1
-------
VI. Dept. of Treasury (DT)
A. Bureau of Alcohol, Tabacco, and Firearms
1. San Francisco, California 4
B. U. S. Customs Service
1. San Francisco, California, Region VIII 1
VII. Environmental Protection Agency (EPA)
A. Region IX, San Francisco, California 1
VIII. Energy Research and Development Administration (ERDA)
A. Nevada Operations Office, Las Vegas, Nevada 1
B. San Francisco Operations Office, Oakland, California 1
IX. General Services Administration (GSA)
A. Regional Offices, So. San Francisco, California 5
X. Postmaster General (PO)
A. Western Region, San Bruno, California 1
XI. Veterans Administration (VA)
A. Regional Office, San Francisco, California 4
12fa«*
-------
Si-
§1
I
fe!
II
fft
Si
J,2j&5_
-------
Additions to Table 1
1. Footnote !_/ on Table 1 applies to agency VIII A which reports, in
addition to quantities shown, the following:
Type 12 — Trace quantities of 135 chemicals, the use of which
does not create reportable waste quantities.
Type 14 ~ 50-yard rolls Asbestos 20
50" x 50" x 1/8" sheets Asbestos 66
Gallons, Spent epoxy, catalyst, resin 110,000
Gallons, gasoline 2,500,000
Pounds of lead, as bricks 413,750
Pounds of lead, as shot 512,500
Sheets of lead, from
24" x 24" x 1/8" to 36" x 36" x 1/2" 130
2. Agency I C.I. reports use of large quantities of Type 3 materials in
small to large lots, but no waste. However, disposal of containers is
not reported. Assume some waste gallons and a large quantity of containers.
3. Agency II B reports laboratory use of a large number of chemicals
(Type 12), but no waste. Assume a quantity of containers, however.
4. Agency IV C reports laboratory use of various chemicals, but no large
waste volumes. However, assume a small number of containers.
1286
-------
Generalized List of Hazardous Materials, by Type
Type 1. ACID SOLUTION ,
Spent etching solution
Spent acid plating solution
Pickling liquor
Acid sludge
Battery acid
Type 2. ALKALINE SOLUTION
Alkaline caustic liquids
Alkaline chemical cleaners
Alkaline battery flgid
Acetylene sludge
Oakite
Wyandotte cleaner
Type 3. PESTICIDES
Unwanted or waste pesticides
Pesticide-containing wastes
from pesticide handling
or storage
Type 4. PAINT SLUDGE
Paint slops
Pigment sludges
Type 5. SOLVENT
Cleaning solvents
Data processing fluid
Attrix solvent
Type 6. LEAD SLUDGE
Wastes from tetraethyl lead
compounds
Type 7. CHEMICAL TOILET WASTES
Type 8. TANK BOTTOM SEDIMENT
Type 9. OIL
Floe
Oil Sludge
Acidic chemical cleaners
Electrolyte
Spent acid
Sulfonation tar
Copper bathing solvent
Caustic wastewater
Lime and water
Lfme sludge, wastewater
Line soda water
Spent caustic
Spent cyanide plating solutions
Unrinsed pesticide containers
Wash water from the cleaning
of pesticide containers or
application equipment
Paint waste from paint
application
Paint remover or stripper
Dry cleaning wastes and other
spent cleaning fluids
Sediments containing
tetraethyl and other
organic lead
Crude Petroleum
Waste Oil .
Toxic grease compounds
1267
-------
Type 10. DRILLING MUD
Type 11. CONTAMINATED SOIL AND SAND'
Sand and oil
Spent blasting sand
Type 12. LABORATORY WASTE
Spent or waste chemicals
Type 13. DRUGS
Hazardous, toxic, or legally
controlled drugs and drug
mixtures
Type 14. GENERAL
Incinerator ash
Lagoon, distillation
residues
Asbestos, Magnesium,
Beryllium wastes
Lagoon residue mixed with soil
Contaminated soil or sand from
spills
Cyanide, phenolic wastes
Spent catalyst, epoxy, resin
wastes
Sewage and septic tank sludges
determined hazardous
1266
-------
UNITED STATES
DEPARTMENT OF THE INTERIOR
•GEOLOGICAL SURVEY
Water Resources Division
345 Middlefield Road
Menlo Park, California 94025
November 6, 1975
Mr. Charles T. Bourns, Chairman
Task Force for Hazardous Materials Management
Western Federal Regional Council
U. S. Environmental Protection Agency
100 California Street
San Francisco, CA 94111
Dear Mr. Chairman:
The Task Force ad hoc subcommittee for the assessment of non-Defense
Department federal agencies for quantity and type of waste hazardous
materials submits the attached report.
The inventory was made through requesting letters (copies attached)
sent to all non-Defense agency units in Region IX thought to maintain
operations capable of generating hazardous material wastes. It did
not include contractors on federal projects. The responses summarized
1n the attached table are believed to be reasonably representative of
the taste problem within the non-Defense federal agencies. However,
quantities estimated probably are considerably less than those actually
generated.
The inventoried agencies reported annual waste quantities of more than
4,500 tons and from about 250,000 to 350,000 gallons, with 8,000 to
10,000 container units for disposal. In addition, some agencies reported
significant quantities of hazardous materials used in normal operations,
but were unable to report either a waste volume or disposal of containers.
Forty-three offices or units of the twenty-six agencies included in the
assessment reported their annual hazardous material handling procedures.
These units are grouped into four broad categories based on their
principal organizational function.
1. Research and Development agencies.
Includes: Agricultural Research Service (USDA)
Energy Resource and Development Administration (ERDA)
U. S. Geological Survey (USDI)
1269
-------
2. Land Management agencies.
Includes: U. S. Forest Service (USDA)
Bureau of Land Management (USDI)
Bureau of Reclamation (USDI)
National Park Service (USDI)
3. Regulatory and Control agencies.
Includes: Animal and Plant Health Inspection Services (USDA)
U. S. Coast Guard (DOT)
Postmaster General (USPS)
Environmental Protection Agency (EPA)
Bureau of Alcohol, Tabacco, and Firearms (DT)
U. S. Customs Service
4. Human Resource agencies.
Includes: Department of Health, Education & Welfare (HEW)
Department of Housing & Urban Development (HUD)
Veterans Administration ( VA)
Table 1 lists the waste quantities by type and category. As is clearly
Indicated, the majority of wastes are generated in the research and
development agencies and the large quantities are of only a few types.
However, the individual responses to the assessment also reported the
acquisition and use of large quantities of several material types, with
no reportable waste. From this, it must be concluded that larger
volumes of waste are actually generated, and that the reported container-
disposal volume is far too small. This is particularly true of the
agencies of category four. Some agency units in this category maintain
laboratory facilities and other functions requiring use of hazardous
materials. These operations are such, however, that no reportable waste
1s produced and the containers are apparently disposed of as returnable
to ttie supplier or through domestic solid-waste facilities.
The great majority of all non-Defense Department federal agency hazardous
waste is generated in the normal activities of only six of the agencies,
and of these one agency produces perhaps 80 percent of the total. From
this it is apparent that even though many agency units have need for
hazardous waste disposal facilities, the volume involved is not large,
and the majority have no real problem of management or disposal through
commercial facilities.
Sincerely,
'/ /
W.
X. L. Burnham
Assessment Subcommittee
Enclosures
1280
-------
Table 1. Types of waste hazardous materials reported
by pound, gallon and number of containers
Category
TOTALS
Type 1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
Type 1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.
Acid solution
Alkaline solution
Pesticides
Paint sludge
Solvent
Lead sludge
Chemical, toilet wastes
Tank bottom sediment
on
Drilling mud
Contaminated soil & sand
Laboratory waste
Drugs
General
TOTAIS
Acid solution
Alkaline solution
Pesticides
Paint sludge
Sol vent
Lead sludge
Chemical toilet wastes
Tank bottom sediment
on
Drilling mud
Contaminated soil & sand
Laboratory waste
Drugs
General
TOTAI3 -j -JC,1
1
1,750
22,200
8,075
8,000,000
120,000
2,710
230
8,154, 965l/
7,346
513
120
4,780
447
2,220
74
331
15,381^
Pounds
2
7,218
4,986
20
17,600
276,000
72.500
378,324
Gallons
47
185
6,823
198
2,386
103,000
12,000
7,317
3
8,400
140,359
3
341
41 ,500
281
8
42,130
763
208
281
397
6,101
1
50
45,707
672
3
54,183
1,750
22,200
7,559
4,986
8,075
0
20
0
17,600
8,000,000
437,500
2,991
0
72.7381/
8,575,419
8,156
906
7,224
5,375
8,934
1
103,000
12,050
55,244
0
0
749
8,734^
210,373
-------
Addition to Table 1
1. Footnote ™ on Table 1 applies to agency category 1 which reports,
1n addition to quantities shown, the following:
Type 12 -- Trace quanties of 135 chemicals, the use of which
does not create reportable waste quantities.
Type 14—66 large sheets and 20 large rolls of asbestos.
110,000 gallons of spent epoxy, catalyst, and resin.
Approximately one million pounds of lead; as shot,
sheets, and bricks.
2. Agencies of category 2 report, in addition to that shown, large
quantities of Type 3 materials in small and large lots, but no waste.
Additional large gallonage of waste and a large quantity of containers
must be assumed for disposal.
3. One agency reported 2,500,000 gallons of gasoline as waste.
This is considered a one-time disposal and not included as an annual
quantity estimate.
12S2
-------
UNITED STATES
DEPARTMENT OF THE INTERIOR
GEOLOGICAL SURVEY
Water Resources Division
345 Middlefield Road
Menlo Park, California 94025
HIM 12 1975
Agency Heads:
Heads of Offices:
Colleagues:
The Western Federal Regional Council, Region IX, sponsors an Inter-agency
Task Force for Hazardous Material Management. One primary objective of
the Task Force 1s to:
Assess the types and quantities of hazardous materials
which may become non-nuclear wastes to be stored in,
transported through, destined for, or to be disposed
of by the Federal Establishment of Region IX (Arizona,
Nevada, California, Hawaii and Pacific Islands).
The purpose of this correspondence is to request your assistance in this
assessment by listing on the attached form the annual quantities of hazard-
ous material wastes your agency manages. If you cannot furnish the
requested information, will you please forward this request to your Safety
Officer or other officer in your agency, unit, or office who is responsible
for the management and disposal of hazardous materials.
The assessment is not concerned with agency management or operations
procedures. ItTs concerned with obtaining data, or an estimate of the
types and quantities of waste hazardous materials (other than nuclear
wastes) for which the Federal Establishment in Region IX requires storage
and disposal capability. A separate assessment is being made of Department
of Defense agencies. From these sets of information it is hoped that a
combined Federal Agency storage and disposal site can be designed, estab-
lished, and operated so as to relieve the existing serious and costly
management problems many agencies are experiencing. Your cooperation and
assistance are earnestly requested.
To assist your response there is attached:
1. Definitions of "hazardous waste" and "extremely hazardous waste," taken
from State of California Statutes of 1972, Vol. 1, Section 1, Chapter 6.5,
Article 2.
Z. A listing of hazardous materials 1n five groups, taken from California
Department of Health Hazardous Waste Regulations, Title 22, Division 4,
Chapter 2, Article 2.
-------
3. A condensed list of hazardous materials by type, or common descriptive
term, that may be used to categorize materials for reporting purposes.
4. A form on which it is requested the types and quantities from lists 2
and 3 be reported. We suggest annual quantities be reported. Where
records are unavailable or inadequate, please report an estimate.
Your response is requested as early as possible and should be addressed to:
Task Force Assessment Chairman
c/o W. L. Burnham
U. S. Geological Survey, WRO
345 Middlefield Road (M.S. #66)
Nenlo Park, CA 94025
Phone: FTS - 415 323-2337
COMM - 415 323-8111, ext. 2337
If there is nothing to report for your agency or office, please so indicate
so that we may close out the assessment.
Please note that the assessment is for planning information with which to
estimate the magnitude and severity of the hazardous materials handling
and waste management problem. The information is needed for assessment
and planning purposes only:
Thank you for assisting in this inter-agency effort toward mutual benefit.
Sincerely,
W. L. Burnham
Assessment Chairman
Enclosures
-------
Attachment 1
'Hazardous Waste" - Means any waste material or mixture of wastes which
1s toxic, corrosive, flamnable, an Irritant, a strong sensltlzer,
which generates pressure through decomposition, heat or other means,
1f such a waste or mixture of wastes may cause substantial personal
Injury, serious Illness or harm to wildlife, during, or as a proxi-
mate result of any disposal of such wastes or mixture of wastes.
The terms "toxic," "corrosive," "flammable," "Irritant," and "strong
sensltlzer" shall be given the same meaning as in the California
Hazardous Substances Act (Chapter 13 (commencing with Section 28740)
of Division 21).
"Extremely Hazardous Waste" - Means any hazardous waste or mixture of
hazardous wastes which, if human exposure should occur, may likely
result 1n death, disabling personal Injury or illness during, or as
a proximate result of, any disposal of such waste or mixture of
wastes because of Its quantity, concentration, or chemical charac-
teristics.
1235
-------
Attachment 2
PRELIMINARY
From CaliTornia Department of Health
Hazardous Waste Regulations, Title 22,
Division H, Chapter 2. Article 2.
Listing of Hazardous Materials (in five groups)
AectoM cywhrdrln
•easidine
It-tainoiUphenyl
nlia «r»«n*t«, solid
, M-. P*nt*-. grleblc
•olid
Irudn*. «oUd
AntUooy gotn«i\» t«rtr*te
r nlftt*
AntJccay trichloride
A&Uacny trtflucrlto
Antljony trl oxide
! laid, Umta, or solid
«lA»t iQlld
Ar«enl= chloride, Liquid,
Aritolc iodide, »olld
Arsenic pcat**el«niae
Ar«talc peroxide, lolld
nrwMte. wild
Arjenlc aulflde, solid
Ar«tni= trlchlorid*, liquid
Aj-fenlc trioxldg. tolld
Arrtnleeg eanpcuodj or aixturei
ArMnl^tl dip, liquid
Arwnlc»l dtut
Afigocu* nid, solid
Ar««pcj«
-------
Attachment 2 (con't.)
rtmla^eyanide. «olld
BUric-aotaiBlu* lodidj. gelid
euric «ub»ulf»t«.
Bltronilliy
Mltrocblcrb«n«n«. orVho. liquid
U-mtrodlph«nyl
Bulfur. awUrd
gulftiryl fluorld*
euro! fMrcury nuel«at«). >oild
rsww frr°°id*t toiid
reuroua Elueon«t«. «olid
fcuroui iodidt. tclld
l dlthlo pyrophc«i*»t*.
»dde (blMk). lolld
^1 BU^Cfct*. talld
•r.-ury -u-. iv i-j_ 3.'tjd
i*tginf _bl siUf*>tg1_«fltd
uTc-ury ci.«pound» (organic)
frjury cy-tiidti. solid
a-mtroaodiacUtyl*ala«
Mltroxylol
a^c acid
f*r«altro«allln«. »olld
PmrfcthlQQ. liquid
f*r»tbloD. alrtur*. dry or liquid
ffcTll gT««B. tOiid
liquid
l dltblo pvrcphotptwte .
. llcuid
T»tr««iyl wrophospti»t« .
T«tr«aethyl lead
PtrtUTTY'l fluoride
ethyl bronid* and chlorplcria
o-ToIuidlM
5tfcyl brcreidt and ttlglene
dlbrontidt nlxturt
tthyl broeld*. liquid
ethyl chloroaethyl «th«r
TGL
Zinc m«nit«. solid
bi* (2-Chloro-
•alllM). Hoc*
Itttgl pyathion. liquid
lethyl per at hi on ^Ktuy*, dry or
liquid
kvlophQa. Pboidrio
looocbloraettont. «tab1J1a*d
Potmix* fcrttnt,t«. »olld
Pot>«ii«tt >rt«alt«. solid
fotaiilun blflvorid*
Pgt«»«lmabj.nozala.tit
lug flucrldg
(2) Caerctive rJ.A«
Brcttin* trin-ucrtf -
Bctyl trlcblaroai.*H«
Cftttatic _si>li>.11 mid
ChAoracetyl chloride
Chlorln* trifluorlJe
Chlorosulfcrde acid-sulfur-rioxitle
Cupri«thjltne-di«gin« tglution
Cy&lohtyl trichloro»ilane
o-Dichlorob«nteD»
Ty-tttehlorotejiMin
Pi«toyl <
Dod«eyltrieiiloroiil«Qt *
Etjyl ghlorsforaat*
EthVl Phenyl dlchlorotiluM
B?ffJlHoroph3lrohorie acid
Htnrt
»cid-
qplror-uoroaillcic acid
•_dieblcHd« Hyp^iori^ solution, .
tcra than Tt, «vallabl« cMor.rg
»u«t«tr^-dre?hthalic anhydride
-------
Attachment 2 (con't.)
Illtrte tcii
om tribrcaidg
ft-gpyl trlchloroiUaot
f!yro«ulfuryl chlorite
SlUcop cMoriJe
tillcon tttraetgoridi
ff^diua •JjiBliiata liquid
•odium chlorite •oUtJoo
§Unaie ehloridt
Bulfur cblorld.
,0yli^ trlojtidt.
gulfurout »cld
ftdfurri chiQTi
Ihiophotyhoryl chlorld*
vB__oigtrt ehlcrto*
tine chloride
-------
Attachment 2 (con!t.)
a _M gquiehlortd*
o«r K*
Methyl
Hrthyl trtchloro«il«M
hMartle «eid
a>*atn*M •op* *»!•» *qi ,
i of aitrccX
t« «t«d •ith «rfl^
ttarlm »»t*l.
,»tft*-
-------
Attachment 2 (con't.)
toner rttia «r«t«M coot**-^ *" "fT concentration, rtteriw
PtotntMrythriotol h»)»aitrrt«
aiivM- Mide
Clycol JliAtrat«
13GO
-------
Attachment 3
Generalized List of Hazardous Materials, by Type
Type 1. ACID SOLUTION
Spent etching solution
Spent acid plating solution
Pickling liquor
Add sludge
Battery acid
Type 2. ALKALINE SOLUTION
Alkaline caustic liquids
Alkaline chemical cleaners
Alkaline battery fluid
Acetylene sludge
Oakite
Uyandotte cleaner
Type 3. PESTICIDES
Unwanted or waste pesticides
Pesticide-containing wastes
from pesticide handling
or storage
Type 4. PAINT SLUDGE
Paint slops
Pigment sludges
Type 5. SOLVENT
Cleaning solvents
Data processing fluid
Attrix solvent
Type 6. LEAD SLUDGE
Wastes from tetraethyl lead
compounds
Type 7. CHEMICAL TOILET WASTES
Type 8. TANK BOTTOM SEDIMENT
Type 9. OIL
Floe
Oil Sludge
Acidic chemical cleaners
Electrolyte
Spent acid
Sulfonation tar
Copper bathing solvent
Caustic wastewater
L1me and water
Lime sludge, wastewater
Lime soda water
Spent caustic
Spent cyanide plating solutions
Unrinsed pesticide containers
Wash water from the cleaning
of pesticide containers or
application equipment
Paint waste from paint
application
Paint remover or stripper
Dry cleaning wastes and other
spent cleaning fluids
Sediments containing
tetraethyl and other
organic lead
Crude Petroleum
Waste 011
Toxic grease compounds
13G1
-------
Attachment 3 (con't.)
Type 10. DRILLING MUD
Type 11. CONTAMINATED SOIL AND SAND
Sand and oil Lagoon residue mixed with soil
Spent blasting sand Contaminated soil or sand from
spills
Type 12. LABORATORY WASTE
Spent or waste chemicals
Type 13. DRUGS
Hazardous, toxic, or legally
controlled drugs and drug
mixtures
Type 14. GENERAL
Incinerator ash Cyanide, phenolic wastes
Lagoon, distillation Spent catalyst, epoxy, resin
residues wastes
Asbestos, Magnesium, Sewage and septic tank sludges
Beryllium wastes determined hazardous
I3G2
-------
Attachment 4
WASTE HAZARDOUS MATERIAL
(Non-Nuclear)
Agency or Office
Date:
Telephone Contact:
Please report annual quantities (estimate 1f necessary) of hazardous
material wastes destined for, to be stored in, or to be disposed of by
these functions of your agency or office within Region IX (Arizona, Nevada,
California, Hawaii and Pacific Islands).
Material, by type
and/or spec, ident.
Annual
Quantity
Material, by type
and/or spec. Ident.
Annual
Quantity
Example:
Type3
Dieldrin
Containers
Type 5
30 gal.
100 bbls
125 gal.
I3G3
-------
UNITED STATES
DEPARTMENT OF THE INTERIOR
GEOLOGICAL SURVEY
Water Resources Division
345 Middlefield Road
Henlo Park, California 94025
September 10, 1975
This is a followup to the letter of request for your assistance in
assessing the problem of hazardous material wastes within the Federal
establishment. Eighty percent of the offices contacted have responded,
and I am expecting more in the next few weeks. At this time I want to
thank all of you, and your people who put so much of their time anc!
effort Into this request, for responding in such an outstanding manner.
I, and the members of the Task Force for Hazardous Materials Management
express our deepest appreciation for your prompt and detailed assistance.
We feel we now have nearly enough information on which to base plans
and decisions for a Federal program for disposal of hazardous material
wastes.
Largely because the Federal operations are so diverse, and partly
because my request was necessarily very general and non-specific for
certain kinds of operations, some of you responded with lists of
hazardous materials on hand, procured and stored, or used in routine
operations rather than the volumes of wastes produced or handled. For
some of these, it 1s possible to estimate the waste volumes, but for
others it cannot be done with any sense of reliability. Consequently,
there may be a follow-up request of clarification for a few agencies
soon. To save time, however, if you reported materials used or on
hand rather than wastes, and if you are able to determine or estimate
the waste volume, it will be greatly appreciated if you will send that
Infomation as soon as possible.
We again thank you all for your courteous and careful responses. It
Is our goal to report the assessment results to the full Task Force
by late October, and the results should be available to any who are
Interested soon thereafter. May I please hear from those who have not
yet responded?
Sincerely,
/ /,<',..../....
W. L. Burnham
Assessment Chairman
-------
.
DATABANK SYSTEM FOR RECYCLING, RECOVERY AND DISPOSAL
. fla/5 /20
1. SCOPE '3 75-
Hazardous materials may well be a very real part of our national resources.
Even though a material, hazardous or otherwise, may not be in apparent
demand at a particular time by its possessor, at another time or another
place it may be of some economic value. This portion of the study is
particularly concerned with a databank system for recycling, recovery, and
disposal. Lest we investigate the potentials out of context, let us examine
the total problem to provide a setting, a foundation on which to build.
a. Excess Hazardous materials may result from any of several actions
or sources, including:
(1) Acquisition of more product than was required due to over-
estimating; minimum quantity available for purchase greater than require-
ments; or subsequent development or change of plans resulting in lesser
requirement.
(2) A by-product of some activity.
(3) Excessive time "on-shelf".
(4) Materials necessarily held for some contingency, for which the
validity has expired.
b. It is rather obvious that some of these sources may be managed to'
reduce quantities of excess hazardous materials, but others are directly
related to mission and work which must be performed. Accordingly, first •
attention should be directed to minimizing excesses of hazardous materials
wherever feasible.
c. When excess of hazardous materials cannot be avoided, some series
of actions must be determined and followed for "disposal". Disposal in
•this sense includes all aspects of use and reuse, recycling, alternative
.uses, detoxification, destruction, and long term storage. The economics
of disposal must consider the potential of the material as a valuable asset,
perhaps in relatively limited supply, as well as costs for detoxification or
destruction or storage following determination that it is hazardous waste
without identifiable value.
d. Acceptable priorities for disposal method' can follow a logical
sequence, either by the owner or someone else.
0) Reutilization of material, as is.
(2) Modification or alteration of material such that all or part can
be used. (Including use as a fuel to produce energy.)
(3) Store for future use. l«-j5
-------
(4) Permanent storage, or abandonment.
(5) Destruction.
2. DATABANK POTENTIAL
Deslreability of identifying a local use, either direct or of modified
hazardous material,appears elementary. However, failing to establish
a local use, some attempt to determine "another time, another place" for
reutilization seems logical and worthwhile. Such procedures have been
adopted and practiced for many years for non-hazardous materials pre-
determined as having a ready market. So we must conclude that if excess
materials which can be readily marketed with minimal effort is feasible,
the re-entry into the economy of other materials, including many of those
which may be classified as hazardous, should warrant at least an attempt.
This is particularly emphasized when the high cost of destruction or
storage is considered.
a. Prior to the summer of 1974, the Department of Defense established
a Defense Property Disposal Service (DPDS) headquartered in Battle Creek,
Michigan, with a Defense Property Disposal Officer (DPDO) at many major
military activities. Included in their mission is the responsibility for
disposal of all DOD generated excess, surplus, exchange/sale and other
personal property authorized for turn-in which is salable.
(1) To carry out this assignment, DPDS established a procedure
for military activities to report such salable materials to a local DPDO.
If local sale exceeds his authority, or a buyer can not be located, the
material is referred ultimately to the computer databank in Battle Creek
for screening by predetermined priority to locate a user. Priorities
generally include defense activities and other government agencies,
donation to specified organizations, public sale, and abandon.
(2) Materials are identified by numerical designation, and minimum
quantities/values are prescribed. Material condition is coded, and location
Identified.
b. DPDS mission was modified on August 5, 1974, to include nonsalable
properties (other than refuse and trash). Property found to have no
utilization or sales value will be disposed of by the DPDO in landfills, by
Incineration, as sewage, or other authorized means. Accountability will be
accepted by the DPDO and recorded on disposal accounts. Physical transfer
or acceptance in place of the property will be predicated on local
circumstances and the types of property involved. The ability of the DPDO
to physically accept certain property possessing unique characteristics or
requiring special handling will be based on his existing resources, i.e.,
security, storage, material handling and other equipment, reclamation and
demilitarization capabilities. Where the DPDO lacks adequate/suitable
resources, or the technical expertise, to properly process property turned
in for disposal, he will arrange for such support with the local host
Installation or the generating activity on a case-by-case basis.
1306
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"(1) As this new DPDS function is implemented, the computer screening
process is integrated with the salable items.
(2) DPDS has legal and contract authority to hire consultants to
recommend potential users, including alterations and modifications which
may make the material more usable and salable.
(3) One difficulty encountered relates to inconsistencies in
reporting condition of the material, in contrast to the condition of its
container. Funding responsibilities for this screening is not fully and
clearly defined. When a DPDO accepts "accountability" for screening a
hazardous material, he normally does not have a capability for physical
custody, so particular care must be taken to assure the material receives
appropriate storage maintenance and does not "get lost in the system."
3. LIMITATIONS
A workable system for complete screening to exhaust every potential for
recycling and recovery of excess hazardous materials is currently available
for Department of Defense activities. As experience is gained by use of
the system, effectiveness can be expected to improve and problems of the
databank resolved.
a. This system is not available outside the Department of Defense.
Disposal of salable materials for other than DOD activities is the
responsibility of the General Services Administration (GSA).
4. RECOMMENDATIONS
a. Defense activities should continue striving to improve development
of the DPDS screening process to determine every potential for recycling
excess hazardous materials. Only when a complete "search" is unfruitful
should consideration be given to abandonment by permanent storage or land-
fill, or to destruction (such as by incineration), and only then can it
be appropriately labeled as "hazardous waste".
b. A central, single, databank for determination of potential recycling
for all Federal agencies has the obvious advantage of avoiding duplication.
. c. A joint effort by DPDS and GSA seems appropriate, for singleness of
purpose. Within their respective charters, mutual agreement is needed for
responsibility, including funding. If a statutory change is necessary the
problems of disposal of hazardous materials provides adequate justification
for a request to the Congress.
3-507
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SAMPLE FORMAT
HAZARDOUS MATERIAL DISPOSAL CAPABILITIES, REGION IX
FACILITY NAME: McClellan AFB, CA
INDIVIDUAL TO CONTACT/OFFICE SYMBOL: Nelson Chardoul/DEO
TELEPHONE (COMMERCIAL)(916)643-5004 (AUTOVON) 633-5004
MATERIAL DISPOSAL CAPABILITY AND RESTRICTIONS
Metallic Mercury Contaminated liquid mercury is reclaimed
through chemical reprocessing in the
Mercury Reclamation Unit, Bldg 368.
Acids Miscellaneous acids can be used for pH
adjustment In the Industrial Waste Treatment
Plant (IUTP), Bldg 714. Containers must be
in good condition to allow for outside
EI torage.
Cyanide Wastes A maximum of (/day can be treated in
line IVTTP, Bldg 714. Treatment costs of
approximately $ /gal must be reimbursed.
Chrome Hastes A maximum of #/day can be treated in
the IWTP, Bldg 714. Treatment costs of
approximately $ /gal must be reimbursed.
NOTE: This listing to be developed is intended to inform persons charged
with hazardous waste disposal within Region IX of locations where present
capabilities exist for proper disposal of specific materials through treat-
ment, neutralization, reclamation, etc. Each task force member is requested
to submit a brief listing of those materials for which adequate disposal
capability exists , showing any restrictions which would be necessary in
accepting materials from other facilities. Information submitted for this
listing will be of great practical value in developing a mutual cooperative
effort for hazardous waste disposal In Region IX, while recovery and disposal
capabilities are further developed in the future.
Submit inputs in the format shown above as early as possible but to
arrive not later Chan 27 Feb 1976. Send to:
Maj Wyatt L. McGhee
Chief, Bioenvironmental Engineering Svcs
USAF Clinic, McClellan/SGB
McClellan AFB, CA 95652
Copies of the completed listing will be mailed to each task force
member. Individuals must then make their own appropriate inquiries to
determine whether disposal at the listed facility can be arranged. Arrange-
ments would include: transportation and handling, use of proper containers,
limits on quantities acceptable, reimbursement for treatment costs, etc.
In all cases, the product to be disposed must be fully and accurately
described to the satisfaction of the facility contact listed, to assure that
proper treatment capability exists. 13G8
(NOTE: REPORT WILL NOT BE COMPLETE UNTIL MARCH 15, 1976)
-------
THE CHAIRMAN: Thank you, Major McGhee.
Do we have questions?
Mr. Kovalick.
MR. KOVALICK: We have been following with interest, of
course, the work of the task force.
There are several puzzling questions that we have been
giving consideration to. Perhaps you can share with us some
of the task force's thoughts on this.
In our other public meetings across the country we have
heard rather strong testimonials from the private hazardous
waste treatment industry as distinguished from the land site
only industry — those who actually engage in some kind of
treatment — as to the lack of motivation for industry to use
their facilities because they generally cost more than land
disposal.
And I was wondering if you have given some thought
to the implications of opening facilities presumably only at
the beginning to other Federal agencies for the treatment or
disposal of hazardous wastes in this part of the country'
and its potential impact on, if you will, the competition?
Has that point been discussed?
MAJOR McGHEE: I know our Air Force regulations quite
strongly state that it is Air Force policy that we will attempt
to join regional plans for, for example, sewage treatment. We
do not like to build sewage treatment plants. We like to get it
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into a regional system so that the Air Force bases do not have
to do this type of thing.
I would think that the military services particularly
would be most happy to try to follow this type of material
into acceptable private sector treatment facilities, disposal
sites.
MR. KOVALICK: I guess the add-on to that is the
opposite could occur if you all are particularly effective and
you find several of your brother and sister agencies also have
facilities similar to the one you described at your Air Force
base, that perhaps the private industry would argue that they
ought to have access to that particular facility and therefore
you find yourself perhaps not in the defense business but in
the waste management business.
Have you given some thought to that possibility?
MAJOR McGHEE: Right. We have had quite a few problems
in accepting waste from other Air Force bases trying to handle
the problems that they could not handle at their bases, because
we do happen to have an industrial waste treatment plant at
our base. But we do run into problems with the waste not being
properly identified so that we cannot treat it properly. They
have simply passed their problem on to us, and now we have the
problem.
This whole effort started more or less as a grass-roots
approach from our environmental engineers, our people at the
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various facilities that did have a problem, that recognize that
we do not have the solutions to it. And this is how it has
grown.
THE CHAIRMAN: All right, Mr. Mausshardt.
MR. MAUSSHARDT: Major McGhee, I have a question from
the floor.
Where can one obtain a copy of a directory of agencies
who assist in the management of waste disposal?
I believe this is the document you referred to
in your presentation.
MAJOR McGHEE: I believe Mr. Carl Neiling is here at
the conference and he was the one that was instrumental in
putting this thing together.
Would he raise his hand.
Right here (indicating). You might want to speak with
him individually. He would be able to get you a copy of it,
perhaps.
THE CHAIRMAN: All right. Mr. Bourns.
MR. BOURNS: I have a question from the floor.
I might mention, though, to take Carl off the hook
here a little bit,that this directory is published by the Navy,
and until they get clearance from on high, they cannot distribute
that outside the Federal establishment.
I have a question from the floor.
You mentioned that at McClellan you dispose of waste
loll
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and pesticides and chrome. Do you run a Class One site? And
do you follow state regulations for the facility?
MAJOR McGHEE: No, we do not run a Class One site.
We do treat industrial waste products in a multi-million dollar
industrial waste treatment plant which does destroy cyanides,
it does properly treat and reduce hexavalent chromium to a
trivalent chromium whereby the sludge is more or less in an
acceptable form for disposal in a regular sanitary landfill.
We do follow ovir extremely hazardous wastes and
hazardous wastes into existing Class One disposal sites. And
this is done on a contract basis.
MR. BOURNS: You mean the commercial sites?
MAJOR McGHEE: Right. The Air Force does not operate
such a site.
THE CHAIRMAN: Mr. Lazar.
MR. LAZAR: Major McGhee, do you do any monitoring at
that sanitary landfill where you put in some of the chromium
sludges? Is any monitoring being done there?
MAJOR McGHEE: Let me put it this way, we are attempti;
to build some drawing beds to properly de-water the sludge so
that it can be acceptable by Sacramento County for their centra
landfill, site that they have.
There are some problems in trying to handle it as a
wet sludge... Right .now the county has agreed to take all of the
material sludges so long as it can be properly dried. We have
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run tests on the sludge water mixture in trying to
decide whether it would be a problem in a sanitary landfill.
We have given all the data over to the county, and
they have agreed to take the sludge if we can de-water it. It
is simply a matter of them not being set up to handle wet
sludge to this degree. It is not a matter of the toxicity of the
sludge.
THE CHAIRMAN: Mr. Lindsey, do you have a question
from the audience? ,
MR. LINDSEY: I have one from the audience. I am not
sure whether it is directed to you, Major McGhee, or to us or
just in general, but I will throw it out and you can comment
on it if you can.
Would it be possible to have industry or government,
those people in the business of creating hazardous wastes,
file a disposal plan at the beginning of the cycle so that the
determination can be made if the wastes can be decontaminated
or safely disposed of?
Do you have any comment on that?
MAJOR McGHEE: I am not sure I understand the question.
Would you read it again, and I will see if I can cover it.
MR. LINDSEY: Okay. Would it be possible to have
industry or government and the people that are in the business
of creating hazardous wastes, file a disposal plan at the
beginning of the cycle so that the determination can be made if
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the wastes can be decontaminated or safely disposed of?
I do not know who they would file this with, but I
imagine it is talking about creating a plan ahead of time with
each waste disposal problem.
MAJOR McGHEE: Well, I can think of several things that
we do that may have a bearing on this.
For example, the N.ational Pollution Discharge Eliminatio
System, which covers all discharges, we do file that plan. We
also have to identify as a separate line item all pollution type
projects that we require to be able to meet all Federal,state
and local regulations as far as all environmental concerns,
not just hazardous wastes.
There are a number of these types of things.
I do not think that that is really an acceptable answer
to the question, however, bioenvironmental engineers at each
of these sites are charged with the responsibility for making
sure that Air Force bases do comply with all Federal, state and
local requirements.
As far as filing a separate plan to identify the types
of wastes, I do not really have an answer for that.
THE CHAIRMAN: Mr. Bourns.
MR. BOURNS: I have a question here from the floor.
What happened to the Freedom of Information Act?
MAJOR McGHEE: The Freedom of Information Act is giving
the services quite a problem as far as the magnitude — and I
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;hink the entire Federal government has problems with the magnitude
af the types of notifications that are having to be given as
Ear as just releasing routine information.
If I want to go on leave, I have to get permission for
ny Social Security number to be released. It has really given
as a problem. But the Federal services are really going over-
x>ard trying to comply with this right down to the letter.
THE CHAIRMAN: I think that is all the questions.
Thank you very much, Major McGhee.
Ladies and gentlemen, at this time I would like to
recess the meeting for lunch. I would like to reconvene the
neeting at 1:30 p.m. sharp. We have a number of speakers yet
:o come.
(Luncheon recess.)
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THURSDAY,, DECEMBER 11, 1975 1:30 O'CLOCK P.M.
oOo
THE CHAIRMAN: Ladies and gentlemen, I would like to
reconvene the meeting at this time.
There has been a slight reordering of the speakers for
this afternoon.
I would like at this time to call Mr. Alvin Simon of
Advanced Chemical Technology, City of Industry, California.
Is Mr. Simon here, please?
MR. ALVIN SIMON: Mr. Chairman, I would like to
preface my statement to this panel by emphasizing that the
opinions and recommendations that will be expressed are those
of our company — Advanced Chemical Technology — and are not
intended to reflect opinions or recommendations of any industrial
group or trade association.
One of the major areas of concern to those involved
in the managmenet of hazardous wastes is the problem of the
disposal of the container that was used to package and transport
the hazardous substance. It is to this aspect of the problem,
container disposal, that we offer our views, experience and
recommendations.
Advanced Chemical Technology is a major supplier of
containers utilized in the packaging of hazardous materials.
Our wholly-owned subsidiary, Ted Levine Cooperage,
reconditions steel drums for the petrochemical and allied
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industries.
Our POLY-DRUM division introduced to America, in 1972,
was the first reusable, self-standing high molecular weight
polyethylene 55-gallon container. Also in 1972, our POLY-DRUM
passed the necessary physical tests to receive approval from the
Department of Transportation for use in the packaging and ship-
ment of certain hazardous materials.
Since that time we, and our customers, have encountered
and solved a variety of problems that relate to the packaging
of these hazardous substances. As a result of these experiences
we believe that a key part of any program relating to
hazardous waste management should be that "the container in whic
the hazardous substance is packaged shall not, itself, become
a hazardous waste." That container must be reused and/or the
materials of construction recovered.
The uncontrolled disposal of used containers which
previously contained hazardous materials is thoroughly documente<
as a public health and environmental hazard. Perhaps even the
word "disposal" is misused in this sense. What we are seeking
is "elimination." The practice of disposal by land emplacement
does not "eliminate." You cannot plant poison and expect to
harvest flowers. Land emplacement offers no finality, it is a
lethal legacy for future generations. In addition to the
threat to the future there are the dangers and disasters that
will, necessarily, be part of any land emplacement program. A
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prime example is the death of a bulldozer operator in 1974 at a
New Jersey landfill when drums containing chemical wastes
exploded. In April of this year, at a Coalinga, California
disposal site an explosion and fire resulted from the disposal
of undeclared chemicals in a 55-gallon steel drum. It took
over four hours to extinguish the fire; resulted in extensive
equipment damage and more important, the firemen and other
county personnel at the site all had to be hospitalized to be
screened f°r possible pesticide poisoning.
A recent study by the Oregon Department of
Environmental Quality included the results of a survey of 101
of Oregon's 220 commercial pesticide application firms to
determine their container disposal practices. Based upon
questionnaire response — 54 of the 101 firms responded — 87
percent of all containers are disposed of by land filling or on-
site burial. Additionally, the study revealed that of the
state's estimated 2.2 million containers used annually for
pesticide use and formulation, less than three percent were reused
or the materials of construction recovered.
Many pesticide containers are stored in open fields and
their labels are destroyed by exposure. Lack of proper
identification on containers further contributes to the problem
of proper disposal management and demonstrates an immediate
need for a positive identification system. Towards this
desired goal, Advanced Chemical Technology, in June of this year
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introduced an "embossed" POLY-DRUM which clearly shows in English
and Spanish that this container has been filled with a
hazardous substance. Anyone coming in contact with this
container is adequately warned of the eminent danger. Any
subsequent reuse of this container is therefore restricted by
the presence of the embossment — it cannot be erased, painted
over or removed.
The continued practice of packaging in one-way
containers generates problems other than hazardous waste manage-
ment. The one-way container represents a drain on our national
resources, a waste of vital energy and contributes to our
dependency on importation of virgin raw materials.
From our point of view there is only one solution that
is economically and environmentally efficient. As we stated
earlier,the container must be reused and, eventually, the
materials of contstruction recovered. We recognize that a
program of this depth would develop many problems that would hav
to be solved before it becomes the "law of the land."
For example, "How many times can we reasonably expect
to reuse a container?" "What method can be developed to recover
the basic materials once the container is no longer usable?"
And finally, "What can these recovered materials be used for?"
To seek out the answers to these and other questions
we recommend that you establish a joint industry-government
task force to review current container specifications and
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disposal practices. The primary objective would be arriving
at recommendations that could result in the reduction of those
single-trip containers that become part of the hazardous waste.
Advanced Chemical Technology, for one, and we are sure
many of our customers, would be more than willing to participate
in such an effort.
Thank you.
THE CHAIRMAN: Thank you, Mr. Simon.
Will you answer questions, sir?
MR. SIMON: Yes.
THE CHAIRMAN: Any questions?
Mr. Lindsey.
MR. LINDSEY: CouLd you comment for us a little bit
on the differences in the economics between what you call the
'single-trip container" and its disposal as compared to the
"multi-trip container" and the reconditioning of those.
MR. SIMON: Are you relating to the steel drum?
MR. LINDSEY: Yes.
MR. SIMON: I think perhaps the next speaker would be
a little better qualified to answer on the steel drums.
On the plastic drum I could comment that now that the
price of plastics has moved up high enough in the larger
containers, it is now more economically feasible to salvage
the material after it has been reused.
We have found with our plastic drums, because of their
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construction, because of the high molecular polyethylene can
be reused a number of times if filled with the same commodity.
Another part of the study would be: Can you use it for
different commodities?
If filled with the same commodity it can be recycled
at least a minimum of ten times.
MR. LINDSEY: Well, then, as a result of that, that
being the cheaper way to go, would you expect that as a natural
course' that recycled containers would tend to replace the single-
(
trip containers —
MR. SIMON: I would think so, yes.
MR. LINDSEY: — under present conditions?
MR. SIMON: I would think, yes. Especially in the
plastic area.
THE CHAIRMAN: Mr. Kovalick?
MR. KOVALICK: Could you comment on the use of your
container for other than pesticides?
MR. SIMON: Oh, yes. We have used it for other
hazardous materials, for other chemicals, for food products.
It has been used for almost anything other than for hydrocarbons
The only material that the polyethylene is subject to high
permeation from is in the hydrocarbon field. So in the chemicals
like acids, other than the highly concentrated nitric acids, in
most of the acid solutions, in the caustics, in the pesticides,
in water-based products, in everything, the container has been
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used successfully.
MR. KOVALICK: Also, you may realize that the EPA has
guidelines for pesticide containers relating to triple rinsing
and the fact that that does reduce the amount of material left
in the drum.
Have you had any rinsing experience in terms of data
with your plastic drum?
MR. SIMON: Yes. I think — and you must remember, we
have just received approval for pesticides I think earlier this
year or late last year — but those people that have been using
it have been rinsing it. And the plastic drum is a seamless
container. There are no chimes. There are no pitfalls once it
is rinsed. Our own particular design, incidentally, is a
completely emptying design. If you will think of a round
container or a steel drum, when you tip it, at the thumbhole
you have that flat portion which you never, even with a triple
rinse, fully empty.
With many of the plastic drums on the market,
especially ours, you can completely empty it upon rinsing. But
as to whether the people are doing it, I do not know.
THE CHAIRMAN: We have a note here from the audience.
Perhaps you might want to respond to it.
It is, .evidently, a clarification on one of your state
ments.
It says: Would like to correct Mr. Simon as to the
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hospitalization of personnel at the Coalinga site. They were
taken to the hospital as a precaution and were released
immediately.
Do you have any comment on that?
MR. SIMON: No, I have no comment. I am glad they got
out.
THE CHAIRMAN: Mr. Mausshardt.
MR. MAUSSHARDT: I have a question from the floor.
Is it the trust of the restricted articles law as
administered by the Department of Transportation for the single
use for one-way containers?
MR. SIMON: Is it the trust . . .
MR. MAUSSHARDT: Isn't it the thrust of the restricted
articles law as administered by the Department of Transportation
toward the use of single-use or one-way containers — what is,
I guess, your relationship to the Department of Transportation
in that position of one-way containers?
MR. SIMON: I do not think I can respond to that,
because I am not familiar with the law they are talking about.
THE CHAIRMAN: All right. Thank you very much, Mr.
Simon.
I would next like to call Mary Lee of Bay Area Sewage
Services.
Mary Lee, Bay Area Sewage Services. Is she in the
audience?
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PROM THE FLOOR: She will be here shortly.
THE CHAIRMAN: All right. We will return to her later.
We have one speaker who has a time problem, so at
this point I would like to call Ms. Nancy Buder, representing
the National Sierra Club.
MS. BUDER: I am Nancy Buder, a member of the National
Staff of the Sierra Club representing 150,000 members.
Today I would like to discuss with you the far-reaching
effects of hazardous wastes and toxic substances as opposed to
some of the technical presentations which have been analyzed
so far today.
Publication this last summer of the National Cancer
Institute's cancer maps of the United States,provided one of the
more graphic examples of the probable effects of environmental
pollution and toxic substances on human health.
The maps reflect adjusted death rates from cancer on
a county-by-county basis for 35 anatomical sites — liver, lungs
et cetera — of cancer.
The original data were obtained for 20 years, 1950 to
1969/from death certificates.
The maps reproduced show that cancer mortality is not
uniform, but is clustered in certain geographic areas. The
darkest areas indicate that a county's death rate from cancer
falls in the top ten percent of all counties in the nation.
There is a five percent possibility that this variation from the
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normal cancer death rate could be attributed merely to chance.
Knowing that 60 to 90 percent of human cancer is
environmentally caused, environmentalists have been quick to
note that particular conditions in certain counties appear to
play a role in the higher death rates for those counties.
The maps and back-up data demonstrate several relation-
ships that epidemiologists have already noted or predicted. For
example, cancer mortality rates are generally higher in urban
than in rural areas; non-white males have the highest death
rates from cancer, followed by white males and then females
regardless of race.
The map also reveals some previously unknown clusters
of cancer that correspond with some of our most polluting
industrial complexes. For instance, counties in the rural
West that have a relatively high number of workers employed in
smelters also tend to show higher cancer mortality rates.
Similarly, bladder cancer is highest among chemical workers who
are exposed to compounds experimentally proved to cause cancer
in animals. Thus, almost every county in New Jersey is shaded
black, as are Detroit, Chicago, and their environs. These areas
are the traditional homes of the chemical industry.
A final example: Some of the most notorious government
testing and chemical-worker facilities are located in the areas
of high lung cancer mortality. These include the Nevada
Proving Grounds; Pine Bluff, Arkansas; Dugway Proving Grounds in
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Utah; and China Lake, California.
At this point I would like to describe the events of
one particular city which has caused it to become a black area
on these cancer maps.
Not long after moving to Maryland's Little Elk Valley
in 1967, Dr. Petro U. Capurro and his family began to fall ill
with increasing frequency, exhibiting strange symptoms that Dr.
Capurro, a pathologist and; toxicologist, suspected were connecte
with the activities of a local chemical plant. So he set out to
discover just how widespread these symptoms were among the peopl<
in the valley. He learned that 12 of the 43 residents were
hospitalized from 1967 to 1970, showing signs of damage to the
pancreas, liver, or kidneys. Seven of the eight residents he
examined personally also showed malfunctions of the
liver and pancreas.
The Galaxy Chemical Company, the only industry in the
valley, has been the center of controversy among local residents
since 1969, when it began to reprocess solvents in its local
plant. The company uses a distillation process to purify more
than 20 different solvents, most of which are deadly in high
concentrations. One of these — benzene — is known to inhibit
the production of red blood cells and to cause leukemia. Others
can damage the liver, kidneys, pancreas, and central nervous
system. In the course of his investigation, Dr. Capurro
identified more than 25 of these solvents in the air and water
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of the valley. He reported in "Medical World News" that he
had found nine of these solvents in blood samples from various
valley residents. The nine solvents were benzene, carbon
tetrachloride, methyl chloride, methylene chloride, methyl
ethyl ketone, methyl isobutyl ketone, tetrachloroethane, and
toluene.
Most of the solvents processed by Galaxy contain an
unknown number of impurities that are discarded as wastes. No
one — not even company officials — knows what all the
impurities are. The State of Maryland has taken samples of the
wastes, but has been unable to determine their precise contents.
These wastes are illegally dumped in a nearby sand-and-gravel
quarry because Galaxy does not have the dumping license required
by the state. Residents of the community have continually
complained to the county health authorities about odors eman-
ating from the quarry.
In April, 1973, it caught fire, and fumes from the
burning chemicals were dispersed throughout the valley. After
the fire, the residents' complaints and health problems greatly
increased.
Previously, the State of Maryland had ordered the plant
shut down because of air- and water-pollution violations.
During investigations in 1970, the state had discovered
abnormally high amounts of methylene chloride, benzene, methyl
ethyl ketone, and other solvents in the valley air, thus
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confirming Dr. Capurro's findings. The state forced Galaxy to
eliminate its open evaporating ponds, but residents of Little
Elk Valley still suffer from the pollution. They must rely on
wells for water that the EPA has determined are contaminated.
The valley's air is so polluted that some parents will not
allow their children to play outside because the fumes make them
act "dopey."
As one mother recently explained to a reporter from
the "Baltimore Sun," "We'd have to house ourselves up like bears
and hibernate." Looking outside, she went on to say that she
could "see a blue fog settling through here laying right close
to the ground — or yellow, it would get real yellow looking."
The workers in the Galaxy plant, of course, receive
even stronger doses. One employee explained that while working
closely with the chemicals, he did not notice any odor, but that
as soon as he would go outside, he would faint. This man lost
20 pounds while working at the plant. He told the "Baltimore
Sun": "I didn't eat much — when you work around it, you just
don ' t eat . "
One woman explained that she and her 20-year-old
daughter had been diagnosed by Dr. Eloise Kailin, an
allergenist and specialist in environmental medicine serving as
a consultant to the state, as having contracted epilepsy from
exposure to chemical fumes. Dr. Kailin also found that the
woman's husband and son were suffering from pancreatitis. Upon
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examining the valley residents, Dr. Kailin found a total of 11
cases of pancreatitis, an incidence of 45 per thousand, as
compared to the rate of two per thousand in the rest of the
surrounding area. "When I put together all of the information
made available to me," Dr. Kailin told the "Baltimore Sun," "it
adds up to proof beyond any reasonable doubt that fumes from the
Galaxy plant have caused and are continuing to cause an epidemic
in Little Elk Valley."
Even more alarming, though more difficult to substanti-
ate, it is the unusually high incidence of cancer in the valley.
Or. Capurro determined that from 1967 to 1973, there were 15
deaths among the 120 people who, by his estimate, had lived in
the valley for at least two years — a death rate 2.2 times
higher than that of Cecil County as a whole. Of those deaths,
eight were attributed to cancer — a rate seven times greater
than that for the county. But as persuasive as these figures
seem to be, the case is difficult to substantiate because by the
end of 1973, more than 60 percent of the people living in the
area between 1968 and 1970 had either moved away or died.
John Madison worked at the plant several years ago, but
had to quit because he could not tolerate the fumes. He
explained to the "Baltimore Sun": "I got headaches from it. I
had them all the time." Madison's father had been a supervisor
at the Galaxy plant for 11 years prior to his death from cancer
last August. He died of throat cancer. His widow described the
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odors on her husband's clothes as being so strong that he had to
change his working clothes before coming into their home. John
Madison's family suffers from chronic sore throats. Along with
many residents of the valley, the Madisons can take no more
pollution. They are planning to move.
Little Elk Valley provides an extreme case of the
threat to human health and environmental quality posed by the
careless or mindless disposal of hazardous substances. But we
must mot mislead ourselves into thinking such instances are
unique. We are all, in some degree, in the position of the
valley residents, for the entire country — if not to say the
world itself — has been repeatedly exposed in the past century
to a staggering variety of toxic substances. Industrial society
has routinely trafficked in poison, and we are beginning to
pay the price. The common wastes of home and industry have
become a greater threat to human safety and environmental
quality than anyone could have foreseen. Even our best attempts
to contain many of these toxic substances have proven futile,
not to mention the appalling number of occasions when few if
any precautions were taken. Not only is the production of
hazardous wastes continuing, now increasing by some five to ten
percent annually, but the wastes of past generations — wastes
assumed to be long buried — are returning to plague us.
The practice of burying toxic substances in the ground
on the assumption they would eventually decompose into
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natural elements and remain permanently as benign constituents
of the soil has proven disastrously wrong in many communities.
For example, a large municipal landfill in the State of
Delaware, where both domestic and industrial wastes had been
buried for many years, was closed in 1968, and its contents
forgotten. Four years later, it was discovered that chemical
and biological pollutants had percolated into the local ground-
water. The Environmental Protection Agency esimates that some
$26 million will be required to correct this dangerous situation
and to stop further deterioration of an underground aquifer
that provides drinking water to over 40,000 people.
The kindred practice of confining certain wastes to
holding ponds has proven just as unreliable. In too many cases,
the pond has held little beyond our hopes. For example, since
the 1940's, a New York electroplating firm has been discharging
its waste water into what it considered to be safe settling
ponds. Even though the ponds were well constructed, they lacked
protective linings. As a result, seepage of toxic cadmium and
chromium has contaminated the local groundwater. This case also
points up the distressing fact that even the expenditure of
huge amounts of money may not eliminate the hazards posed by
latent toxic substances. Since 1958, considerable sums have
been spent on the chemical treatment of this waste water — all
in vain.
Nor is groundwater the only final receptacle of our
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wastes. In Tennessee, for example, a chemical company had
buried a hundred 55-gallon drums of chlorinated hydrocarbons
each week in shallow, unlined trenches. These poisons regularly
escaped from their containers to contaminate not only the local
groundwater supply, but a nearby creek as well. Our air may
also become the unfortunate destination of migrating wastes,
as is demonstrated by the hexachlorobenzene mystery of
Geismar, Louisiana. Hexachlorobenzene, along with other benzene
derivatives, is noted for is carcinogenic properties. So when
the U.S. Department of Agriculture discovered that unusually
high levels of the substance had accumulated in the fatty tissue
of local cattle, it placed the entire herd, numbering some 20,OOC
under quarantine.
Otherwise, the chemical could wel1 have been passed
on to the unsuspecting consumer. It turned out that one of
the many chemical plants in the area, following a practice
common to all, had dumped its hexachlorobenzene wastes on
adjacent land, assuming they would remain intact until they
could be properly treated . But weather conditions caused the
hexachlorobenzene to evaporate into the atmosphere, from whence
it proceeded to settle with the morning dew on nearby pastures,
where it was ingested by the grazing cattle.
Substances such as hexachlorobenzene and the host of
solvents emanating from the Galaxy Chemical Company are
relatively new arrivals in the world. They were created -in the
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retorts of modern science in an age when "progress through
chemistry" seemed not only promising, but inevitable. We may
regret our foolishness in so cavalierly handling these exotic
substances, in blithely assuming that the miracle of modern
chemistry was entirely benign, but at the same time we can under-
stand, perhaps, how it was that we failed to recognize the
deadly aspect of these new substances. It is far more difficult
to understand our similar casualness with such naturally
occurring poisons as arsenic, surely one of the most notorious
poisons in history. This ubiquitous element is present in
low concentrations in sea water and in somewhat higher
concentrations in carbonate springs and highly saline water.
Arsenic is also naturally present in the soil, although the
concentration increases greatly with the use of pesticides. It
is generally claimed that arsenic will tend to remain in the
topsoil, predominantly in an oxidized pentavelent state that
presents virtually no danger to well water or plant growth.
Because it is a naturally occurring element in our soil
and water, we long believed that if buried in the ground, even
arsenic would eventually be rendered harmless. Today, we know
differently, we know that this element will remain indefinitely
and reappear to infest later generations.
For example, in the late 1903's, a pesticide, contain-
ing arsenic was buried in western Minnesota. Thirty years
later, a building contractor expanded his facilities by buildinc
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a warehouse and office outside the city of Perham. A well was
drilled for his water supply. Almost immediately, workers
developed symptoms of arsenic poisoning. According to a study
conducted by Dr. Edward J. Feinglass, 11 of the 13 employees
suffered from symptoms of chronic (subacute) arsenic intoxica-
tion. More acute reactions were confined to those who had
ingested especially large quantities of the water. The
distinction between chronic and acute poisoning is significant.
An actue case will draw immediate attention, whereas chronic
poisoning may only produce an irritation that is tolerable for
many years. It is now believed that chronic arsenic poisoning
may lead to cancer.
The exact source of contamination in Perham was
difficult to determine. When an investigation began, several
possibilities for groundwater degradation were found. In
interviews with local residents, for example, it was discovered
that in the late 1930's, when grasshoppers threatened farmers'
crops, bait composed of arsenic, bran, and sawdust — a mixture
not unlike old-fashioned garden snail bait — was stored in pile
on the bare ground until needed. The excess bait was supposedly
buried. Perhaps it was the grasshopper bait that contaminated
the groundwater, perhaps it was the buried arsenic pesticide,
or perhaps it was something else altogether. But in any case,
here we find a clear instance where our carelessness cannot
merely be explained away by ignorance.
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We would be fortunate indeed if all we had to do in
order to solve the problem of hazardous wastes was to, say,
shut down a chemical company, or restrict the uses of certain
substances, or regulate how such substances are handled and
disposed.
Such steps are necessary, and we should do whatever
possible to assure that they are taken at once, but unfortunately
the problem is far too complex to be so easily solved. The
example of Perham, Minnesota, suggests that no simple solution
to this situation exists.
The circumstances I have described are not unique, but
merely representative.
The Sierra Club supports the passage and enforcement
of legislation to strictly regulate the production of, the
prevalence and the disposal of existing hazardous wastes.
The Sierra Club would also enthusiastically support
the pre-testing of hundreds of chemicals and substances which
enter the environment annually so as to remove Elk Valley and
other dark areas from future cancer maps.
THE CHAIRMAN: Thank you.
Will you accept questions?
MS. BUDER: Certainly.
THE CHAIRMAN: Any questions?
Evidently not. Thank you very much.
MS. BUDER: Thank you very much.
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THE CHAIRMAN: At this time I would like to call upon
Mr. David Baker of the California State Solid Waste Management
Board.
Mr. Baker, please.
MR. DAVID BAKER: Mr. Chairman, gentlemen, earlier
this year the State of California through the Solid Waste
Management Board began to recognize the importance of hazardous
liquid waste, hazardous chemical waste and what is known
commonly as non-sewerable industrial waste. This came about
because of problems that existed at various locations of the
state that came to our attention about disposals, illicit
disposals, changes of laws, regulations and so forth that
created a problem that eventually came to the State of California
Solid Waste Management Board. The chairman of that board,
Mr. Dies, appointed a committee to investigate and gain as much
factual data as possible throughout the State of California
either to confirm or to deny or to recognize the extent of the
problem and come forth with some recommendations as to some
kind of a solution.
So we began holding hearings throughout the state.
We asked industry, both the manufacturers of chemicals and other
types of representatives from the landfill operations, the
transporters, the chemical companies, local government
representatives, both elected and appointive, to offer testimony.
And our findings were varied.
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In various parts of the state the problem was compounde
more by urbanization and in the difficulties of weather , dispos-
ing of materials, transportation, economics, political-social
environment, reactions and what is being done about it.
And our findings showed that there was considerably
more non-sewerable liquid wastes produced than there was the
legal capability of the landfill sites to accept.
And what happened to that was, of course, bootlegging
— what we call moonlight disposition. Much of it was disposed
of in treatment plants by dumping in manholes at the various
locations, some of it pumped into a neighboring jurisdiction
in a flood-control channel, or some of it was hauled into
illegitimate, acceptable landfill operation sites.
Our findings from San Diego, the industrial development
of San Diego, the problems that exist in that area to the non-
manufacturing areas of Northern California —
The problem is greatest, of course, in the urban
area. The problem of transporting it is greater in the urban
areas. The cost is great.
We have heard many comments today, and all over the
country wherever we go we have heard statements, questions,
what happens, we have heard illustrations of what has taken
place. We have heard there is a definite need. But no one has
really come up with a positive, 100 percent solution to the
problem.
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So long as we have economic growth, so long as we have
industrial growth, so long as we have people, so long as people
produce, we are going to have residues. And we have to make
some kind of prepration to accept this. We have to realize
that there must be,in order to maintain an economic balance in
the State of California and elsewhere, a capability of disposing
of those wastes. Who does it?
It has been said, and opinions have been offered by
various legal counsels that it is the responsibility of the
manufacturer to dispose of his waste. No one would quarrel
with that. Perhaps that is true. But then how does he dispose
of it and where does he take it?
That, gentlemen, is the unanswered question.
Now, industry by itself cannot do that. Government
by itself cannot do that. The social-economic pressures, the
political pressures, in a particular community cannot accept
the landfill site, because any politician who is half as smart
as his mother thinks he is is not going to go against something
that his constituents do not want.
So then he is willing to put a landfill site or some
disposal station over into someone else's jurisdiction. And
that happens all over the State of California. It happens
wherever you propose one.
There is the environmental reaction of the people who
justifiably do not want it there. But those same people are the
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employees of the corporations or the company who produces that
and whose very jobs depend on the continuation of that company
or corporation to produce.
A recent study in Riverside County last year indicated
that one out of every four paychecks generated in that county
other than government was from an industry that produced a non-
sewerable waste.
Now, they have to have a place to put it. Their
alternatives, of course, are to close down and relocate. And
where do they relocate?
We have had testimony in Los Angeles where industry
was denied permits to construct in an economically deprived
area because they had no facilities for disposing of their
waste. What happens if one county tells another county that
they cannot dispose of their chemical wastes or their hazardous
wastes or any kind of wastes in their county? And I think they
have the right to make that determination. So then we are
confronted with a problem.
I am not a chemist, but we have chemists in our state
agency. Dr. Collins you heard this morning. A member of our
committee, Mr. Bonnerson, from the Water Resources Control Board
was part of our committee. They are the experts.
So I have to rely on them in our findings and make a
report back to the board.
It has been said that a mark of a good executive is a
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man who goes around with a worried look on the face of his
assistant. And so I have attempted to utilize the talents that
exist within our committee and within our staff and within the
state agency to find a reasonable solution. And at this point
in time our findings are that there is not yet the state of the
art that is readily capable of handling 100 percent recovery.
No matter how much you recover, there is still going to be
residue. There is still a definite need for landfill sites
wherever they are in the State of California.
It is also a definite fact that you cannot put landfil
operations or recovery systems or solar evaporation units in a
highly urbanized area. It is also a fact of life that you canr
put them in an area that has heavy rainfalls or that has a high
humidity factor. Therefore, it must go into an arid area with
a lot of sunshine, remote from urbanization. And there is much
in Southern California and Nevada and Arizona that could lend
itself to that. So how do we find where those lands are and
where those sites are?
Studies were made earlier by the state to make
determinations on what might be usable sites, but because of
environmental pressures these have been shelved and nothing has
been developed from them.
We are currently looking at a master plan, which is
part of our recommendation, that the state develop a master
plan of Class One landfill sites throughout the State of
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California.
This committee currently operating is asking the
legislature to appropriate funds to the State Division of Mines
and Geology to make borings and testings of those areas that
might lend themselves to the use of solar evaporation or land-
fill sites. This is in the process presently. It is one of the
recommendations that we are making.
Now, I served some 12 years as an elected official in
Orange County as a member of the Board of Supervisors, so I
know what home rule is. I also know that it is extremely
difficult in any urban area to do anything that is not
consistent with the wishes of the constituency. I also recogniz
the importance of having another agency big enough to meet the
challenge operate, enforce, and supervise any kind of an
operation that goes beyond the local jurisdiction. Such an
agency would be the State of California or perhaps the Federal
government.
We are recommending that the state acquire through
whatever funding process — eminent domain, negotiations — by
whatever means — any landfill sites that meet the criteria
within that enclosed basin that has no inflow or outflow of
under-water that is sufficiently removed from urbanization to
permit solar evaporation and recovery systems. This may be
called secondary mining or however you wish to describe it.
The problem is greater than most of us "realize. It has
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taken us some ten to twelve years to bring the problem of solid
waste disposal to that which is now a common household word.
Resource recovery, reuse, salvage or whatever.
It was not many years ago when people would just toss
everything over the back fence into a gulley or they would burn
it in a backyard incinerator, and no one really paid much
attention to what happened to it until urbanization forced
government into the landfill operation or private enterprise
into landfill operations, recovery systems.
But looming ominously in the background like a cloud
over a lawn party is the problem of hazardous liquid waste and
what do we do with it.
And this is probably — at least in my opinion — one
of the greatest problems that faces our country today. What
do we do with it? Not only from an industrial point of view,
but from a governmental point of view and a military point of
view, but from an economic point of view. We cannot ignore
the problem. We are trying to do something about it in the
State of California. We are developing this master plan as
rapidly as we possibly can through all the resources that are
available to us at this time.
You gentlemen as an agency of the Federal government
oftentimes have funds available to assist in projects of this
kind. It might well be as one of your recommendations or your
findings that you should participate in the acquisition and
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warehousing for such lands for future landfill operations of
this type.
Some of the finest farmlands in California or Southern
California, at least, and certainly most of the finest mineral
sand and gravel deposits are now under subdivision.
There are many areas in the south where the landfill
operations have been operating for some time and I suspect
that that has happened up here. Ten years ago it happened way
out in the open spaces. Today, right next door, are subdivision
and the housing. And the people down at the City Council are
protesting the landfill operations. So, consequently, they
will go the way of the dairies and the chicken farms that were
very prominent in Southern California a few years ago.
But that does not get rid of the problem. It is still
there. The solution is within our reach, I think, if we look
to the combined operation of government and private enterprise.
I do not believe that private enterprise can buy land
and warehouses and pay the taxes on them and store it until it
is needed, but government can. In 10 or 20 or 30 years or maybe
100 years we may have an entirely different system of life, but
today in the immediate foreseeable future we are an industrial
nation, and as such, we are a productive nation, and as a
productive nation we produce residues. And we have to dispose
of them one way or another.
Recycling, of course, is the most desirable thing.
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Resource recovery and reuse of all these chemicals and by-prod'
is a desirable thing. But when it gets beyond the economic
capability of industry to do it, then it becomes a problem. A
so long as there is no profit motive, industry cannot continue
or cannot afford to do it. Therefore, it becomes necessary fo
either government subsidy or partnership to produce.
If they are forced to do it, they will add that on to
the price of the product, and the consumer pays. The consumer
that is, you and I, the taxpaper, whomever. So it is a debata
question on whether it should be a subsidized program or wheth
there should be some incentive to industry — or however the
answer may be, we recommend that there be a melding, a partner
ship program" between government and industry to join hands to
reach a common goal, a solution that both can live with. We i
government, as representatives of the people, and industry as
the employers of industry.
In. the absence of that, we continue to go from moonlight
moonlight deposit, dumping into the sewer in some remote area
where there is a manhole that we can lift up. We even find
where they pulled the tanker trucks alongside the construction
project and pretended to be a water truck, emptied their mater
and left.
Well, in order to avoid that, one of our big
recommendations is that we charge a fee to all operators
regardless of what it is — not a selective few — to all
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operators for enforcement procedures.
We found that some industries and some operators were
legitimate, were following precisely the rules, paying their
fees and doing what was asked of them to do, only to be handi-
capped and discriminated against by an indiscriminate industry
who failed to do so by choice and economic reasons.
Orange County Sanitation District recently adopted an
ordinance that will go into effect very shortly, if it hasn't
already, that is source control over the chemipals that go into
the sanitation treatment plants. When they stop dumping
there, industry will have to locate another source or another
place to dispose of their waste.
If Los Angeles should say, for example, that they do
not want it there, what are they going to do with it? It is
going to be very costly to them, to dispose of this some way or
another. Transporation is not a real problem. San Diego
hauls to Nevada in some cases. That is probably in excess of
500 miles. If they can transport that far and find a reasonable
site at some distance, that may be partially the solution to
urbanization such as the lack of solar evaporation capability
here in the Bay Area.
You have a high water table here. It is difficult to
dispose of chemicals through that process.
Closed basin areas do exist. They are reasonable.
They can be controlled. They can be supervised in the long term
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through a levy of a charge for future administration and
protection, possibly the responsibility of the State Solid
Waste Management Board.
Mr. Chairman, that concludes my comments.
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DECEMBER 11, 1975
Testimony for EPA Hazardous Waste Management
Public Meeting
San Francisco, California
MY NAME is DAVID BAKER, MEMBER OF THE CALIFORNIA STATE SOLID WASTE
MANAGEMENT BOARD, AND CHAIRMAN OF THE BOARD'S INDUSTRIAL LIQUID
WASTES COMMITTEE. THANK YOU FOR THE OPPORTUNITY TO TESTIFY HERE
TODAY.
ALTHOUGH THE BOARD HAS NO REGULATORY AUTHORITY REGARDING HAZARDOUS
WASTES MANAGEMENT, CERTAIN OF ITS MANDATED PROGRAMS ARE RELATED TO
THE DEVELOPMENT OF EFFECTIVE HAZARDOUS WASTE PRACTICES THROUGHOUT
THE STATE, UNDER THE MANDATE OF SB 5 (1972), CALIFORNIA'S 58
COUNTIES ARE PREPARING COMPREHENSIVE PLANS FOR SOLID WASTE MANAGE-
<
MENT FOR SUBMITTAL TO THE BOARD BY JANUARY 1, 1976. PLANNING
GUIDELINES ADOPTED BY THE BOARD REQUIRE THE COUNTY PLANS TO
ADDRESS THE MANAGEMENT OF HAZARDOUS WASTES GENERATED WITHIN THE
COUNTY. IN ADDITION TO PROGRAMS BEING DEVELOPED BY THE STATE
DEPARTMENT OF HEALTH, DATA COMPILED FROM THESE COUNTY PLANS
SHOULD PROVIDE VALUABLE INSIGHT TO THE SCOPE OF THE PROBLEM IN
THIS STATE.
DURING JUNE AND JULY OF THIS YEAR, THE INDUSTRIAL LIQUID WASTES
COMMITTEE OF THE STATE SOLID WASTE MANAGEMENT BOARD CONDUCTED
EIGHT DAYS OF PUBLIC HEARINGS ON THE HANDLING AND DISPOSAL OF
NONSEWERABLE LIQUID INDUSTRIAL WASTES. I HAVE COPIES OF THE
COMMITTEE REPORT, WHICH I WILL LEAVE WITH YOU.
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THE FINDINGS IN THIS REPORT ARE BASED ON THE VIEWS OF THE
PRODUCERS, HAULERS, DISPOSAL SITE OPERATORS AND OTHERS PRESENT-
ING BOTH ORAL AND WRITTEN TESTIMONY RELATING TO (1) THE PROBLEMS
ASSOCIATED WITH THE ADEQUACY OF EXISTING SITES AND THE ESTABLISH-
MENT OF NEW SITES, (2) THE PROBLEMS OF ENFORCING CURRENT LAWS AND
REGULATIONS REGARDING THE PROPER DISPOSAL OF INDUSTRIAL LIQUID
WASTES, AND (3) OTHER SUGGESTIONS WHICH MIGHT FACILITATE THE
SATISFACTORY HANDLING OF THESE WASTES,
BRIEFLY, THE FINDINGS OF THE INDUSTRIAL LIQUID WASTES COMMITTEE
MAY BE SUMMARIZED AS FOLLOWS:
1) THERE is CURRENTLY A SHORTAGE AND MALDISTRIBUTION OF SITES
AVAILABLE FOR DISPOSAL OF HAZARDOUS WASTES, KNOWN AS CLASS I
*
SITES;
2) THE LACK OF ADEQUATE DISPOSAL SITES is RESULTING IN A
NEGATIVE IMPACT ON EMPLOYMENT IN SMALLER INDUSTRIES
PRODUCING LIQUID WASTES;
3) IN ADDITION TO PROBLEMS ASSOCIATED WITH LOCATING SITES PHYSICAL
CAPABLE OF MEETING CLASS I CRITERIA, ECONOMIC, POLITICAL AND
SOCIAL CLIMATES ARE SEVERELY LIMITING THE ESTABLISHMENT OF
NEW CLASS I FACILITIES;
4) CURRENT MONITORING AND ENFORCEMENT PROGRAMS NEED STRENGHTEN-
ING BOTH IN AREAS OF TRANSPORTATION AND DISPOSAL;
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5) LONG DISTANCE HAULS TO SUITABLE DISPOSAL SITES COUPLED WITH
LIMITED HOURS FOR DISPOSAL ENCOURAGE ILLEGAL DISPOSAL; AND
)) A DISPOSAL FEE LEVIED ON ALL NONSEWERABLE LIQUID WASTES, AS
,i
OPPOSED TO THE CURRENT FEE STRUCTURE FOR HAZARDOUS WASTES,
WOULD BE LESS BURDENSOME, MORE FAIRLY DISTRIBUTE THE COST
AND REDUCE THE INCENTIVE FOR UNAUTHORIZED DISPOSAL,
)N THE BASIS OF TESTIMONY RECEIVED DURING THESE PUBLIC HEARINGS,
,ND IN AN EFFORT TO COORDINATE THE ACTIVITIES OF THE VARIOUS STATE
AGENCIES INVOLVED IN REGULATING THE STORAGE, COLLECTION AND
ISPOSAL OF INDUSTRIAL LIQUID WASTES, THE COMMITTEE'S PRIMARY
:ECOMMENDATIONS WERE THAT THE STATE SOLID WASTE MANAGEMENT BOARD
INDERTAKE THE FOLLOWING.
<
.) DEVELOP A STATEWIDE MASTER PLAN FOR CLASS I DISPOSAL SITES
WHICH WOULD DETERMINE REGIONAL NEEDS, LOCATE SITES, AND
RECOMMEND METHODS OF IMPLEMENTING THE ESTABLISHMENT OF NEW
SITES,
) PURSUE, IN COOPERATION WITH OTHER STATE AGENCIES, STRONGER
MONITORING PROGRAMS AND ENFORCEMENT PROCEDURES, INCLUDING
THE DELEGATION OF ENFORCEMENT TO LOCAL AGENCIES WHERE SITES
ARE PRIVATELY OWNED; POOLING OF THE SEPARATE INSPECTION
ACTIVITIES OF VARIOUS STATE AGENCIES TO MAXIMIZE THE
EFFECTIVENESS OF STATE SURVEILLANCE RESPONSIBILITIES; AND
EXPANSION OF EXISTING STATE LICENSING REQUIREMENTS FOR
LIQUID WASTE HAULERS TO INCLUDE SOLID WASTE HAULERS, SEPTIC
1.31*9
-------
TANK PUMPERS AND ALL DISPOSAL SITE OPERATORS.
3) MODIFY THE CURRENT HAZARDOUS WASTE FEE STRUCTURE TO INCLUDE
NOT ONLY HAZARDOUS, BUT ALL NONSEWERABLE WASTES.
4) CONSOLIDATE ALL WASTES CONSIDERED DETRIMENTAL TO WATER
QUALITY OR HAZARDOUS TO PUBLIC HEALTH INTO A SINGLE LIST
AND REVIEW ITS APPLICABILITY IN RELATION TO THE PHYSICAL
CHARACTERISTICS OF EACH NEW AND EXISTING CLASS I SITE.
STAFF OF THE SOLID WASTE MANAGEMENT BOARD AND OTHER STATE AGENCIES.
INCLUDING THE STATE DEPARTMENT OF HEALTH, STATE WATER RESOURCES
CONTROL BOARD AND AIR RESOURCES BOARD ARE CURRENTLY INVESTIGATING
METHODS TO FACILITATE THE IMPLEMENTATION OF THESE RECOMMENDATIONS,
IN SEPTEMBER 1975, THE CALIFORNIA STATE LEGISLATURE ADOPTED
ASSEMBLY CONCURRENT RESOLUTION No. 79, RELATIVE TO A STUDY OF
WASTE DISPOSAL SITES FOR ENVIRONMENTALLY DANGEROUS SUBSTANCES.
ACR 79 REQUESTS THE SOLID WASTE MANAGEMENT BOARD, IN CONJUNCTION
WITH OTHER APPROPRIATE STATE AGENCIES, TO CONDUCT AN INVESTIGATION
WHICH INCLUDES AT LEAST THE FOLLOWING ELEMENTS:
A) DETERMINATION OF THE QUANTITY, TYPE AND LOCATION OF GROUP 1
WASTES NOW PRODUCED WITHIN CALIFORNIA, INCLUDING A PROJECTION
OF THOSE WASTES THAT WILL BE PRODUCED IN THE FUTURE DUE TO NEW
STRINGENT AIR AND WASTEWATER CONTROL REQUIREMENTS.
B) EVALUATION OF THE ROLE OF THE STATE IN ESTABLISHING NEW
CLASS I SITES. SUCH EVALUATION SHALL INCLUDE: (1) WHETHER
1350
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THE STATE SHOULD ASSIST IN THE LOCATION AND EVALUATION OF
POTENTIAL SITES, (2) IF THESE SITES SHOULD BE PURCHASED
AND OWNED BY THE STATE, AND (3) THE MANNER BY WHICH THE STATE
SHOULD CONTROL OR REGULATE THE OPERATION OF THE WASTE
DISPOSAL PROCEDURES.
c) ANALYSIS OF METHODS AVAILABLE TO MONITOR THE AMOUNTS OF WASTES
BEING GENERATED AND CORRELATE THOSE AMOUNTS WITH THE RECORDS
OF WASTE BEING DISPOSED OF AT CLASS I SITES.
D) EVALUATION OF THE STATE'S ROLE IN ASSURING THAT LONG-TERM
MAINTENANCE WILL EXIST FOR THE CLASS I DISPOSAL SITES BOTH
DURING SITE OPERATION AND AFTER SITE CLOSURE.
E) ANALYSIS OF THE SOURCES AND LEVELS OF REVENUES NECESSARY
TO FINANCE THE REQUIRED PROGRAMS.
A REPORT OF THE FINDINGS AND RECOMMENDATIONS OF THIS INVESTIGATION
ARE DUE TO THE LEGISLATURE BY JULY 1, 1976.
THE STATE'S ROLE IN IMPLEMENTING SOLUTIONS TO ENVIRONMENTAL
PROBLEMS IS BEING REINFORCED THROUGH THE DEVELOPMENT OF A STRONG
HAZARDOUS WASTE MANAGEMENT PROGRAM, WHICH, HOPEFULLY, WILL BE OF
ASSISTANCE TO OTHER STATES INITIATING SUCH PROGRAMS. V/E
BELIEVE THAT THE DEVELOPMENT OF STRONG FEDERAL AND STATE LEADER-
SHIP IN HAZARDOUS WASTE MANAGEMENT IS A NECESSARY REQUIREMENT
IN SOLVING THE OBVIOUS LOCAL AND REGIONAL PROBLEMS ASSOCIATED
WITH THE DISPOSITION OF ENVIRONMENTALLY DANGEROUS WASTES.
1351
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A SOLUTION TO THESE PROBLEMS IS ESSENTIAL TO THE CONTINUED
ECONOMIC STABILITY OF THE STATE, AND MOST IMPORTANTLY, TO THE
PROTECTION OF THE PUBLIC HEALTH AND SAFETY.
1352
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APPENDIX
THE PROBLEMS OF DISPOSING OF
NONSEWERABLE INDUSTRIAL LIQUID WASTES
Summary of presentations made to and
correspondence received by the
INDUSTRIAL LIQUID WASTES COMMITTEE
OF THE STATE SOLID WASTE MANAGEMENT BOARD
during June and July 1975
1353
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TABLE OF CONTENTS
;es
I. SAN DIEGO - July 22, 1975 1-3
II. LONG BEACH - June 23-24, 1975 4-10
III. DOWNEY - June 25, 1975 11-15
IV, MAKTINEZ - June 30, 1975 16-17
V. OAKLAND - July 1, 1975 18-21
VI. REDDING - July 14, 1975 22-23
VII. EUREKA - July 15, 1975 .• 24-26
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SAN DIEGO - July 22, 1975
.. L. McConville, Orange County Road Department, Santa Ana (Other)
- The entire basin area (Orange, Riverside, San Bernardino and Los Angeles
Counties) has entered into a study that anticipates to have a pre-
liminary final report late this fall. They will determine which areas
in the basin will be logical for location of a Class 1 site.
- In the Liquid and Hazardous Wastes Study for Orange County final report,
they inventoried the types of generators, quantities of hazardous
materials and where these materials were going at the present time.
- Largest amounts of hazardous wastes were the toxic inorganic materials,
basically the heavy metals. These materials, being not too difficult
to trace, are being generated in the metal processing industries. Of
the total amount of toxic materials that are generated, over half of
the total amount of waste at the present time are going directly into
the ocean.
- They found that some of the wastes that they had always worried about
(oils, detergents, etc.) have been overly stated. Many of these
materials are being processed at the source. Smaller quantities
are finding their way into the sewage systems.
- They favor materials being economically recovered at source, especially
the metals. If firms were given the chance and a little encouragement,
he feels that they would install facilities at their plants to recover
these meterials and not just to waste them. His department is going to
contact the producers to encourage them to consider some resource recovery.
- There is bootlegging going on for sure. The actual numbers and per-
centages of this are shown in the report.
- When the Resource Recovery Program was started in Orange County they
established an Advisory Committee with representatives from both the
Sanitary District and the Water District in the County. The two staffs
worked very closely together.
- He thinks that local government should pursue their responsibility and
locate sites. The role of the State should be to help local government
to encourage communities to study what their real problems are. The
State should study processing facilities and maybe establish a plant
for an area or region that could economically work.
>. Roy Stevens, Singer Company, Kearfott Division, San Marcos (Producer)
- Increased liquid hazardous wastes production due to local industriali-
zation and water pollution control programs is forcing increasing
amounts of hazardous liquid wastes to be disposed of in the landfill
sites. There is a shortage of proper disposal sites.
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- He briefly had looked into the recovery of the metals. Currently
this is not provitable to his firm.
'3. Ming-Shyong Yang, San Diego Regional Water Quality Control Board (Other)
- Increased liquid hazardous waste production due to local industrializatia
and water pollution control programs is forcing increasing amounts of
hazardous liquid wastes to be disposed of in landfill sites. There is
a shortage of proper disposal sites.
- Because of the shortage of disposal sites and long haul distance to
the approved disposal sites, some wastes may be illegally disposed of
in Class 2 sites and other locations.
- The serious impact from tie lack of adequate disposal facilities for
industrial hazardous liquid wastes is easily conceivable. The industry
may limit its capacity or move away and new industry may not move in.
People may lose their jobs and government may lose its revenue.
- There is not sufficient enforcement on the liquid waste hauling. Some
haulers, after their license has expired, do not even bother to renew it.
4. Bob Racine, Victor Equipment Company, San Diego (Producer)
- Since Calcium Carbide comes from energy related industries we have had
a large increase in the total cost of Acetylene gas. This increase
combined with the cost to discharge our lime slurry of over $12,000.00
for the year and a possible cost of $25,000.00 for the coming year may
make the manufacturing of Acetylene gas an uneconomical fuel gas.
5. Ray Edwards, Orange County Environment Management Agency, Santa Ana (Other)
- He will supply a draft statement in final within the next week.
- The completed Orange County study shows the emphasis in toxic waste
handling in the near future must be forcefully shifted to management
as opposed to disposal.
- If ocean discharge limitations are to be met and if sanitation ordinance
and State and federal pollution laws are to be effectively enforced, the
volumes of hazardous and liquid wastes to be dealt with by means other
than sewering will increase at a dramatic rate to levels more than one
hundred times those presently hauled to Class 1 sites outside of
Orange County.
- Appro>dmately one tenth or? one percent of all metal wastes are currently
going into Class 1 sites. In the early 1980's, the volume of such waste:
in Orange County alone is expected to exceed a million gallons per day.
- He believes in control at or near the source. Control in this content
may have any one of several meanings. In the case of toxic, environ-
mentally hazardous organic materials of little or no economic value,
control must consist of rendering the materials inert or harmless by
economical chemical treatment including, where necessary, controlled
JLwwO
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combustion or pyrolysis. In the case of solvents and petroleum
derivatives, the recovery and reuse as process feed materials or
fuels should be accomplished with economic fringe benefits to the
processor. Inorganic chemicals including the long list of so-called
heavy metals are not subject to chemical destruction, but many of
them have intrisic economic value and all of them represent nonrenewable
resources of strategic value.
- Basic chemical processes needed to achieve this control at the source
are already available. What remains to be developed is only the
technology of applying these processes in the most cost effective
manner to the operations.
- He hopes efforts of governments will be concentrated on solutions to
waste management problems rather than the searching for alternative
sites for the irretrievable disposal of valuable resources.
- He feels Orange County needs a Class 1 site and believes that the
people of Orange County would be delighted to see the State take the
responsibility for selection and operation of the site.
- One thing that he feels is needed in Orange County is a uniform
industrial waste code. Most of the cities make no attempt to enforce
any industrial waste ordinances. County has no restriction within
the 19 cities that did not adopt the county industrial wastes ordinance.
6. William M. Davis, City-County Solid Waste Management Task Force, S. Diego (Other
- In comparing totals, site for site, he found that there has been a
decline of about 20 percent at the Otay site and 44 percent at the
Omar site. Two possible reasons can be given for this decrease:
current recessive economic business conditions affecting both sites,
or a shift to other disposal sites by a major generator affecting
only the Omar site. While they have no hard evidence at this time
of any "midnight" dumping practices they strongly suspect that there
is a certain amount going on in the area.
- The County of San Diego in its operation has established a permit
system that is reponsive to the basic requirements of AB 598 as
regards to disposal site controls. While the city and county monitor
respective sewerage systems, they see a definite need for an inventory
of source generation and the establishment of a source inspection
program in the effort to eliminate the possibility of illicit disposal.
- The State should continue, however, to bear the responsibility for
regulating Class 1 disposal sites in order to avoid any possible
difficulties due to overriding local interests of local selfpolicing.
- In an effort to "close the circle" on the generation and disposal of
industrial liquid wastes and hazardous chemical wastes, they recommend
to the Committee that a hazardous waste management program for the
area be delegated to a local regional agency as allowed under AB 598,
including responsibility for regulation and surveillance of local
hazardous waste processing, source control and disposal.
- He feels that the local entity should coordinate out-of-county as
well as shipments coming into their site. 1 7R7
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LONG BEACH - June 23-24, 1975
1. Frank Ellison, THUMS, Long Beach (Producer)
Mr. Ellison read from a written statement, and accepted no questions.
- Any curtailment of their ability to dispose of wastes accumulated
while drilling and working on their wells would mean a reduction of
their activities. This means they would no longer be able to drill
or work over oil wells and would eventually cause a significant
decline in their existing production.
- The energy, jobs and money lost as a result of involuntary curtailment
of their operations would obviously have an adverse effect on the
state and local economy.
2. Harry Winston, Lockheed (Producer)
- Curtailment of their ability to dispose of chemicals such as acids,
chromates, and the like, would be a serious curtailment of their
ability to produce the aircraft, missiles and other products they
are manufacturing in the State of California.
- He feels that the State has a role to play in making sure t^iat the
industry has the necessary places where they can in turn dispose
of the chemicals.
- State role should be supervisory or regulatory only to the extent
that it would not infringe upon free enterprise of the businesses
that have the job of disposing and taking care of the wastes now.
- Shirvanian stated that private industry has problems between the
department's different lists of hazardous wastes.
- The Environmental Protection Group at Lockheed are made aware of
every chemical that comes into the plant, the amount of it, who is
going to use it and what it is being used for. They have very
complete control over the use, storage and disposal of any chemical
and maintain accurate records of what is disposed of and exactly
where it went.
- If Class 1 sites are taken away, then Lockheed will have a serious
problem that would effect thousands upon thousands of employees
and cost millions of dollars.
- He feels that there is a need for certification of when something
leaves a plant or a factor;/- that it does in fact get deposited in
a place where the State or county says is a legal place to put it.
- Tighter restrictions requiring them to make the water cleaner all
the time, means that there will be more left inside the plant that
will have to be disposed o:?, either through water treatment plants
which condense wastes down to solid sludge or other means.
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Donald Martin, Los Angeles Air Pollution Control District (Other)
- He believes that limiting hours of use of landfills by liquid wastes
haulers will cause problems from the District's point of view,
especially if the liquid waste is odorous. If wastes are dumped
only a few hours each week, and dumped all at one time and in
large volumes, the air passing over the dump site cannot reduce
the ordorous material by dilution and creates a local nuisance
problem.
- He thinks that trucks that dump liquid wastes should always be under
the direct supervision of the dump operator, and that dumping of
hazardous wastes should be limited to the daylight hours. He also
pointed out that dumping on weekends, when people are in their homes
or out in their yards, should be stopped or limited.
- Not limiting dumping hours may reduce the chances of combinations of
nonhazardous wastes, chemicals, etc., from interacting and becoming
dangerous.
Bernard Love, American Chemical Society (Other)
- He is concerned about the liability of the liquid waste producer.
Believes that liability and responsibility should be specifically
and definitively stated so that there is no confusion.
Carl Sjoberg, County of L. A. Engineering Dept. & Pollution Control Div. (Other)
- People who operate businesses in the Antelope Valley, who are trying
to honestly get ride of their wastes, don't have a means of disposal.
There are no approved Class 1 or 2 liquid waste disposal sites con-
veniently available to them in the Antelope Valley area. Of the two
suitable Class 2 sites that could be used, ope was turned down for
liquid wastes and the other one has declined to apply, because it
was not financially beneficial to get the site approved and a nuisance
to go through all the paperwork and procedures.
- Small waste producers (service stations and the like) have difficulty
disposing of possible hazardous wastes. Out of frustration or ignorance
they usually end up disposing of it illegally.
- A transfer site might be feasible for the area, but the regulation
would be difficult.
- Industries which produce hazardous material have been discouraged
from locating in the area, simply because of the fact that the sewage
system in the area is a closed system and cannot handle hazardous
material.
- There is a real need for control of the producprs of the wastes to
begin with, once it is at the disposal facility it is very difficult
to have any recourse.
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- Recommends having a standardized method at the disposal sites for
checking trucks as they come in. Checking only occurs after a
problem happens.
- Believes the solution should involve control at the source, rather
than at the landfill.
6. Ruth Kirby, Jurupa Mountains Cultural Center (Other)
- She is against increasing the number of Class 1 sites, and strongly
favors resource recovery.
- She believes that there should be an educational program on resource
recovery in the schools.
- She also feels that all disposal sites need a chemist at the entranc
7. Donald Brain, Fix and Brain Vacuum Truck Service (Hauler)
- He would like to see the landfills stay open for longer hours, rathe
than just from 8 am to 4 pm. The vacuum trucks are a 24 hour a day
service.
- He does not get involved in hauling industrial hazardous material
because he feels when involved in something like that he should have
a registered, qualified chemist on his staff. With the amount of
revenue he has, he cannot afford that type of individual.
8. Roy D. Owen, Routh Transportation (Hauler)
- He has had no real problem in disposing of material, except during
the rainy days during the winter months.
- His main problem is the hours that the disposal sites stay open. The
don't take care of industry on a 24 hour a day, seven day a week per
He feels that this factor is what might be encouraging "bootlegging"
They had to install portable tanks in the yard so that they could
temporary store liquid wastes until a dump was open where they coulc
haul it to. This is what hurts the very small operator.
9. John Lambie, Ventura Regional County Sanitation District (Disposer)
- After three years and two campaigns, one for the City of Ventura anc
the other for the District, what did we learn? There doesn't seem to
be an easy, effective local method to overcome opposition to new
Class 1 sites. The "pick—it-up, carry-it-around, but don't put it
down" philosophy is still here and it seemingly can't be countered
on a local level. Support from the State is needed to enable operat
to find, evaluate, and open new Class 1 sites.
- They ar'e literally being drowned by large volumes of liquids (over a
million gallons per month at peak times) and with the intensive effo
to clean up the water and air, the only sink left is the land.
1360
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- Their procedure will be to continue efforts to identify and plan
for a new site, but this takes time and money. About 18 months
for all the hearings and permits, and at least $60,000 for the
studies, reports, site selection and EIR's that are needed just
to reach the permit stage. Locally, they will do their best to
meet the challenge, but they need support from Sacramento, both
politically and monetarily.
- Industry is dependent on agencies such as theirs to provide long-
term sites for disposal of hazardous wastes. Without such repositories
the mandate is clear - close down.
After reading from his written statement, Mr. Lambie answered questions
from the Committee.
- There are only 11 locations in the State and that is completely
inadequate. Its asking industry an awful lot to travel a long
distance to reach an approved disposal location. He thinks that
the government must do a better job by trying to find an additional
facility for a Class 1 site.
- They are fighting a budget problem too. They cannot afford the luxury
of having someone there 24 hours a day. It runs their cost out of
sight since a Class 1 site is a break even business.
- Without sufficient facilities he personally believes that they are
going to have this problem of indiscriminate dumping.
- The first key is to get a network of sites where they are convenient.
He firmly believes that the situation as it is being handled now,
with the Department of Health administering the recent laws, the
hauler has a license, and the generator of the waste is responsible,
is a beautiful setup. He doesn't believe that it will work until
there are adequate sites to get to. The temptation is still there
to haul waste without a license.
— He recommends that if the licensed hauler does not get the wastes
to an approved location then his permit should be cancelled.
— He thinks that if the State actually owned the site and then issued
a license to operate said site to either the County Department of
Public Works or some other local entity or private enterprise is a
good approach. But if the county did not perform, then lift the
license from the county as well as you would if it were a private
enterprise.
- The county should be given a chance to get the sites approved, but
if they fail to act, then there is a need for a law to give the State
the authority to step in and establish sites.
- State agencies need to look at the criteria developed by the State
Water Resources Control Board which do not allow for a man-made or
unnatural barrier in a true Class 1 site.
,...3-361
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- He has received testimony that in the North only one barrel out of
ten was reaching disposal facilities.
- If they are going to get good enforcement, then they are going to
have to have more sites. Class 1 sites are getting a broad brush.
He thinks that they should be narrowed down, oil field wastes and
brines etc. should be pulled out and handled in specific areas. To
say that you take any wastes that might come along takes a tremendous
amount of proof that your geology is right and satisfactory so that
there will be no pollution.
- They are doing a research project attempting to recycle a good many
of these materials, to treat them, to condense them, to reduce the
volumes and neutralize them to cut down on transfer.
- It takes four years to get a site. You have to start now just to
get the various permits, EIR's and various things you have to go
through.
- There is a need for an educational program. The public needs to be
informed that if done right, hazardous wastes will not bother the
environment.
10. Russ Bryan, Crosby and Overton Transportation (Hauler)
- He would like to see the dump sites open for approximately 18 hours
instead of the hours that they are open now.
11. Larry Hettick, Long Beach Oil Development Company (Producer)
- A closer Class 1 site would benefit them. It is an 82 mile round
trip to the nearest site for dumping and it costs $1.57 per barrel
to dispose of this material.
12. E. T. Winter, B. K. K. Coirpany (Disposer and Hauler)
Mr. Winter will file a formal report to the Committee on July 2.
- His listing covering the period of August 1974 to May 1975 of liquid
wastes received and disposed of at the West Covina site shows a
dramatic decrease from 1125 loads per month to approximately 780 load;
- The problem with staying open longer hours to receive liquid wastes
is that they need solid wastes to mix them in with. They only receivi
solid wastes over a 10-hour period. They must provide daily cover of
the solids and cannot leave them open at the end of the work day.
They could accept acids which they place into their injection wells
and that do not require mixture.
- The B. K. K. site has a twenty year life according to their engineers,
and the capacity to accept 3.8 billion gallons of industrial liquids
which amount to over 15 million tons. There seems to be a discrepanc;
with the records in Sacramento. They seem to be working at only half
of their capacity today to accept industrial liquids. They do not
1362
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see a saturation of their current capacity for the near future,
and believe if increased capacity to absorb per day they could
find techniques to increase the solid waste input as well as to
maintain the two for one balance.
Eighty-one percent of the $100,000 monthly fee which could be
expected is not appearing, and therefore, perhaps 81% of our hazardous
wastes are being improperly disposed of, or the taxes are not being
paid if they are being disposed of, or the statewide estimate of the
waste quantities in this State is grossly overstated.
They have problems with material classifications which are found
in the separate listings of the state agencies (State Department of
Health and the State Water Resources Control Board). The terminology
of hazardous, extremely hazardous, Group 1 wastes - certain wastes
the Water Resources Control Board does not consider harmful, but the
State Department of Health does - results in confusion.
He suggested that the Committee consider a system which instead of
having multiple, conflicting, and confusing lists issued and used
separately by different state agencies, that the State of California
adopt a single list with simple straight-forward categories. For
example: Class A materials - those which may be disposed of only at
Class 1 sites, Class B - includes materials which may be disposed
of in Class 1 and/or Class 1 sites and so on. Maybe the last category
being sewerable liquid wastes. It is important to operators, haulers,
disposers to have a single list to operate by and, therefore, adhere to.
It is the B. K. K. Company's position that the present tax system,
which imposes a 600/ton fee on hazardous wastes disposed of is both
unfair and represents a real disincentive which financially penalizes
those producers, haulers and disposers who comply with the state law
and provides a beneficial incentive to those who violate the law.
Recommends that the Committee give consideration to recommending a
revision of AB 598, Dunlap, a law which requires only the institution
of a fee system and does not provide for a penalty system. They
believe that some modification thereto should be considered by the
Legislature. Alternatives to fee system: (l) impose an equal tax
per ton, per barrel, or per gallon on all nonsewerable industrial
liquid waste, whether they be hazardous, nonhazardous, extremely
hazardous or harmful by any standard. This would represent a fee
of one mil per gallon on all industrial liquids or 20 per ton on
all industrial liquids and raise the same amount of money for the
State support as the 600 per ton fees, or (2) institute a penalty
system which imposes severe penalties in the order of $100 per ton
on violators whether they be producers, haulers, or disposers.
They believe that a stiff penalty in the order of $100 per ton or
$2,000 per truckload would stop the infractions.
The State Board might consider, in order to find out the quantity
and the quality of everything that is in the market place, a total
monitoring program at all sites for a period of time.
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They feel that it might be hard to find a talent (chemist) able to
do the monitoring at the sites because the field is so specialized.
They are now actively pursuing the neutralization of liquid waste
and resource recovery of valuable minerals prior to disposal.
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DOWNEY - June 25, 1975
Ben Taylor, Douglas Aircraft (Producer)
- They have had no difficulty in getting rid of the liquid wastes pro-
duced by their agency.
- They have had some people in the last few years that have been interested
in trying to reclaim and remove chemicals, to get the metals out of
the chemicals - this doesn't seem to be the answer.
Dr. Collins requested him to make available to the Committee the statistics
of the total unsewerable liquid wastes produced by Douglas, the types of
wastes, and where they are being deposited in the Los Angeles Basin.
Mr. Robert Goodbaudy, Robert Goodbaudy Company (Resource Recovery)
Mr. Goodbaudy operates a company that reclaims plating wastes (cadmium,
chrome, copper, zinc). He recovers zinc from this material and returns
it back to them at less cost than it would be for them to go out and
buy the zinc on the market.
He takes a cadmium plating solution, which is a sianide solution that has
cadmium in it, removes the cadmium completely, and destroys the sianide
solution by an "ultra-sonic" process. Basically, what he has left is
water, after filtering, that is sewerable.
Dr. Collins requested an invitation from Goodbaudy to the Committee or
the state staff to visit his facility and become better acquainted with
what he is doing.
- He feels that recovery is the only way for people to handle the waste
problem, to eliminate the wastes that are created, to reuse them. He
feels that a person can recycle just about all the hard acid wastes,
plus all the metal wastes.
- He finds it difficult to find people who will buy the recycled material
back. If he cannot find a direct source to resell to, he won't take
the material.
Mrs. Gary Farris, San Bernardino/Riverside Liquid Wastes Haulers (Hauler)
- There are no Class 1 dumps in San Bernardino and Riverside Counties.
- Another major problem is the education of the general public. The
concerned citizens refuse sites even in the desert. They do not
understand that these materials would be taken care of properly.
- The forms that you have to fill out poses a problem to the small
producer of liquid wastes. They are reluctant to make out the form -
its such a large form for a very small amount.
1-3S5
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- She admitted knowledge of illegal dumping.
- She believes that having to haul hazardous wastes so far, and properlj
dispose of them at a large cost, is one of the major factors causing
illegal dumping.
4. Kenneth O'Morrow, Oil & Solvent Process Company (Resource Recovery)
OSCO regularly takes the dirty solvent from many customers, reclaims it
by distillation and returns the clean solvent to the customer. They alsc
purchase large quantities of dirty solvent from companies who wish to
dispose of it and for various reasons do not want clean solvent returned
to them. They take wastes, which become their raw material, and after
distilling and perhaps further processing they utilize the clean solvents
to sell as a reclaimed solvent or perhaps use in blends of reclaimed and
new solvents formulated for specific uses. They sell large amounts of
blends so they are always Looking for dirty solvents they can utilize
in these.
Their process obtains yields of about 65 percent. Their operation
prevents the waste of about 3 million gallons of reusable solvent each
year.
- They need Class 1 landfills now. We cannot allow industry to be
driven out of the State and people forced into unemployment because
residential communities are built next door to landfills which were
already in operation. Where this situation develops there should be
no doubt that the landfill prevails. Every effort should be made to
enlist the support required to make sure every Class 1 site now in
operation is utilized to the fullest extent possible. Hot one day
nor one ton should be excluded from its useful life.
- OSCO processes about 4 million gallons of predominantly flammable
solvents. They know how important this is because when the solvents
are rejected for disposal at the landfills they usually end up in thei
plant. They try very hard to take all these products because
they know that if they don't they may end up being dumped illegally.
- Needs legal means to allow them to take flammable material the dump
won't take, mix it with other waste material (which is much less
flammable), and then return it to the disposal site. This is much
less dangerous that the material they turned down originally because
it would be mixed with water, sludge, and other nonflammable materials
Then to set aside a portion of the dump, or somehow treat this in such
a way as to prevent a grader or cat from rolling over it and starting
a fire. Perhaps digging a hole and leaving it isolated for a day or
two, until that very small percentage of acitone evaporates into the
air to the point where they could cover it up and it would be safe. "
5. Ivan Tennant, Riverside County Hoad and Survey Department (Disposer)
- There are no Class 1 disposal sites in Riverside County since the
closing of the Stringfellow Quarry. One other proposal for a project
-------
west of the City of Covina as a Class 1 site, but that was turned
down by the Regional Water Quality Control Board. In both cases
there was strong oposition by local citizens.
- If the State were to step in, this would generate some heat at the
local level, but it may be the only alternative.
- He thinks that changes to the state regulations are needed so that
artificial barriers could be created that can be monitored for seepage
or leakage.
- The Mine and Geology did a study on the possibility of disposal in the
dry lakes in the desert. This is still an alternative that is open.
These would be very controversial. There is concern about what
happens in the desert areas. The site would have to be very remote.
Hank Yacoub, Los Angeles Regional Water Quality Control Board (Other)
- They are fully aware of the fact that there aren't enough Class 1
sites to accommodate the increasing rate of nonsewerable industrial
liquid wastes in California. There is a shortage of capacity in the
existing Class'1 sites. This shortage is compounded by recent
federal and state water and air pollution abatement programs which
are creating increasing volumes of liquid wastes that must find
their way to Class 1 landfills for ultimate disposal.
- The criteria for Class 1 disposal sites are so stringent that there
are very few such potential sites in this region. Compounding this
problem is the extremely large, relatively densely-packed population
in the Los Angeles Region, which means that any new site would have
to be located more or less close to residential areas and would
undoubtedly be resisted by the people living in those areas. This
points out the very urgent need for regional planning. Otherwise,
as legal sites are used up, more and more illegal dumping is bound
to occur. Short and long range solutions are urgently needed.
Gary Decker, San Diego County Dept. of Sanitation and Flood Control (Disposer)
- With the new EPA requirements with the point source discharge control
the problem is increasing.
- He feels that there does need to be a local regional control of hazardous
wastes. This type of authority not only would control the disposal at
sites, but control the activities within its jurisdiction area. They
have only control at the site itself as materials are coming in.
- In the total overall wastes, there has been some reductions. They
can't figure out what it is, maybe the economy or less production,
things like that. He would be afraid to guess what the percentage
of decrease would be.
David Anzures, Metal Finishing Association of Southern California (Producer)
- They have been severly affected by the EPA guidelines on effluent
discharge liquids.
1387
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- He feels that the State should preempt city authority mainly for
reasons that the decisions should not be based on politics, it should
be based on technical competence.
- As an industry, they have probably begun to decrease a little because
they have gone into "good housekeeping techniques" to reduce the amoun
of effluent discharge.
9. Dr. Kenneth Kehimian, VTN - Engineers, Architects, Planners (Other)
- When trying to identify how much waste was being exported to various
landfill sites in terms of Class 1 materials, they found that these
records were not available. He suggests in the area of proper record
keeping that:
1. Copies of all waste discharge permits should be sent to each
waste disposal engineer of each county or the appropriate person
responsible for the waste.
2. Waste disposal site operators who receive the waste should be
required to identify and report the waste discharged by county
of origin.
- Septic tank wastes should go into sewage treatment plants where appli-
cable and possible. There should be a listing of chemical toilet
agents that are nontoxic. The State should support the development
of these types of agents to reduce the amount of wastes that would
have to go into a site.
10. Ottis E. Pittman, Ott's Vacuum Truck Service (Hauler)
- Mr. Pittman complained that he had recently had five flats backing
over garbage to dispose of wastes at a landfill.
Extracts from correspondence:
1. G. A. Collins, Jr., Manager las Angeles Plant, Texaco Petroleum (Producer)
- During the first half of the year 1971 they disposed of approximately
31,700 barrels of such liquid wastes. For comparison in the first
half of the year 1974 they disposed of approximately 62,260 barrels.
These data indicate that the liquid waste from their facility has
increased 96 percent due to stringent environmental requirements
implemented during the 1971-74 era.
- They heartily agree that misguided regulations and the possible future
inability of the State to provide adequate disposal facilities could
represent a grave potential loss of industry and jobs. Therefore,
every possible effort should be made to provide adequate and environ-
mentally sound future disposal sites for industry as well as the
general public.
2. Ivan F. Tennant, Asst. Road Commissioner, County of Riverside (Disposer)
13G8
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Since the closing of the Stringfellow Quarry, the bulk of Group 1
wastes have been disposed of outside of Riverside County. Some
amount (estimated at 10 percent) of Group 1 wastes are disposed of
in Riverside County by various means. A portion is generated in
households and mixed with residential refuse, some is disposed of
through sanitary sewers, and a portion is illegally dumped.
Group 1 wastes are closely associated with the problems of water
and air quality and, therefore, the mechanics for handling this
extend beyond the local political boundaries. He is not advocating
another state agency, but some means of controlling these wastes
on a regional basis.
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MARTINEZ - June 30, 1975
1. Ottis Hunt, Aeroject Solid Propulsion Company, Folsom (Producer)
- He does not feel that the liquid wastes produced at Aerojet will
increase significantly in the next five years. To date he has not
had any difficulty in disposing of the wastes.
2. Victor Johnson, Industrial Tank, Inc., Martinez (Hauler and disposer)
- Operates two Class 1 sites in the Bay Area and part of a transfer
station in Santa Clara County named Industrial Environmental Services.
The iLsposal sites are open 24 hours a day, 365 days a year. After
waste is treated at the Martinez site it is disposed of through
solar evaporation. He employees six engineers and six chemists on
his staff who operate the two sites and the transfer station. He
has an approved laboratory for analysis.
- He believes in advance treatment at a site to prolong the site's life.
Both of his sites have a minimum of 25 years.
- Solar evaporation, as it relates to the options they have for disposing
of liquids, is the method that has the least number of inherent draw-
backs,, There is the potential for odor or air pollution relating
to this process. This is why they pretreat the material that goes
into these ponds and also into the extensive analytical work ahead of
time.
- Since the new regulations, he has noticed an increase in small pickups
in the Bay Area. The transfer station in San Jose was basically built
to service the small customer.
- His sites are not manned for 24 hours, but a technical man and a
management man are on on-call programs. Winter is probably a larger
generation time, primarily because many of the customers use the
same approach that they use, treatment followed by solar evaporation.
During the winter, if weather is severe, customer's evaporation ponds
fill up and they utilize his service.
- He shows a slight upward trend in amounts disposed of rather than a
decreasing one.
- He agrees that different state agencies' regulations and terminology
discrepancies do exist and are sometimes a problem, but has not been
a major hindrance to the operation of his firm.
- He supports a performance bond that operators and truckers would post
so that failure to comply with the laws and regulations would have
direct economic consequence to substandard truckers or substandard
operators.
1370
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- He believes resource recovery will come in selected classes of
wastes. Some of the wastes are much easier to recover than others.
His transfer station in San Jose is now contracting with solvent
recoverers. Solvents will be one of the first materials to see
resource recovery. Other materials have less value on the market,
so will be slower to come under resource recovery programs.
- In general, thinks that government can perform a very valuable
service by clearly explaining what is involved in the disposal of
Class 1 wastes. Supports ACR 79 which develops information that
will help the public understand the problem.
- Even though he recently a Class 1 proposal in Contra Costa Co.,
he still feels that it would be, in his opinion, not the best solution
to the problem to have some super agency designate the places for
sites. With inovative programs between existing state agencies,
industry and local government, and when the public has the under-
standing of the need, we can develop sites under the existing legis-
lative and administrative procedures.
3. Charles Gibbs and Daniel F. Murphy, BASSA, Berkeley (Other)
- The Bay Area Sewage Services Agency concurs with your concern for the
serious existing and potential problems associated with nonsewerable
industrial liquid wastes and hazardous chemical wastes, such as the
increased rate of production due to more stringent regulatory agency
control actions and the limited availability of adequate disposal
sites.
- They feel that a quantitative study of the toxic and hazardous wastes
generated in the Bay Area should be developed. Need to know where
they are originating so they can follow them through from their origin
to their ultimate disposal. Monitoring picks it up at some midpoint.
4. Jean B. Siri, West Contra Costa Conservation League, Richmond (Other)
- When considering Class 1 dump sites and the State managing or buying
or condemning land for Class 1 dump sites, you are going to have to
figure in residential buffers. Depending on the wind direction,
these buffers have to be a fairly decent size.
- She was asked by the West Contra Costa Conservation League to urge
for a change in policy direction in the way of resource recovery and
recycling. There is going to have to be some incentive policy to
inspire industry or force industry into resource recovery.
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OAKLAND - July 1, 1975
1. James Wiseman, Stauffer Chemical Company, San Francisco (Producer)
- Operates 12 plants and three research facilities in California.
Products include sulfuric acid and other industrial chemicals, PVC,
agricultural chemicals, cleaning compounds and food ingredients.
- Because of increased production capacity and the removal of some
materials from municipal treatment plants, we expect to see an increase
in the use of Class 1 and Class 2 sites in 1975 and 1976.
- Sees a great amount of expectation in recycling and resource recovery
as a solution to disposal problems. Within his company a considerable
amount of business is recycling or resource recovery. There are
practices in use today that his company cannot except. Numerous
companies buy damaged, outdated, off-spec., contaminated material.
Sometimes these are reprocessed and sometimes they are sold to the
public and not uncommonly under the original label. This is one
reason why his company insists on proper disposal, and not recycling
in some instances. They have found reclaimed insecticide pails for
sale in hardware stores where the new paint did not completely cover
the original painting. They have no idea if the decontamination was
complete. Confidence in recycling or recovery of this type of material
has been reduced.
2. George Laakso, Engineering Department, San Mateo County (Disposer)
- As a result of the deliberations of the Solid Waste Management
Committee of the County Engineers Association of California (CEAS)
and the Environmental Management Committee of the County Supervisors
Association of California (CSAC), both have adopted a policy on
Group 1 wastes as follows:
Of all types of solid waste, the disposal of hazardous wastes presents
the greatest difficulty at local governmental levels and requires
state assistance in resolving the problems. In cooperation with
the local agency involved as to land uses and service areas, the State
shoxild assure the availability and funding of Class 1 disposal
facilities within reasonable haul distance as needed to adequately
protect the environment and the general public interest. This type
of facility warrants strict regulation and monitoring.
- The basic thought behind the policy statement, which is concurred in
by most counties, is that the State should assume the responsibility
of guaranteeing that Class 1 disposal facilities are available for
all users and that individual counties cannot resolve the problems
for these type wastes produced within each county area.
' 1.372
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3. H. M. Schneider, Romic Chemical Corporation, E. Palo Alto (Recovery,
Producer and Hauler)
- Reclaims 80$ of the solvents, chemicals, aircraft hydraulic fluids
and turbine oils generated in the Bay Area. Organic materials only,
anything that can be distilled or fractionated.
- Any questions they have, before they go to a Class 1 site, are referred
to the State Department of Health.
- Their use of the Class 1 site vd.ll be restricted somewhat in the near
future by the laws stating that you cannot put any photo-reactive
chemical in the atmosphere, and they cannot be ponded.
- He believes that if a good operator of a Class 1 site can be found,
the sites should be run by private industry but under the auspicious
of the Department of Health. They should also have strict regulations.
He does not believe the State should supply the Class 1 site, but only
to expedite procedures and "red tape".
- Overlaping authority is a problem to him and operators of Class 1
sites. Believes the sites should be privately owned, but the State
should have control over them.
- People are concerned about liability when signing the forms. Also,
the PPM's make it difficult to analyze waste that have 20 components.
It takes pretty sophisticated equipment to do this. Now that the
guidelines are out he finds practically no resistance about filling
out the forms. If people won't tell him what is is, then he doesn't
want to haul it.
4. Phillip Moe, PMC Corporations, San Jose (Producer)
- They expect a 15 percent increase in the future.
- There is a need for a Class 1 site in the South Bay Area.
- If the Class 1 site in Richmond were to close down they would have
a definite problem. His wastes are not reclaimable. They have had
several people come in which they have given 8 to 9,000 gallons to
play around with and they have never seen them again.
5. Betty Croly, Alameda County Planning Department, Hayward (Other)
- Who should own the Class 1 disposal sites, the public or private
operators? After the determination of hazardous waste disposal needs,
the problem of site ownership should be addressed and policies developed
at the State level concerning ownership of sites and facilities by
the State, local government, or by private business.
— Who should own reclamation facilities and what is the potential for
resource recovery from hazardous or dangerous wastes? The recovery
potential from hazardous wastes should be identified in any study that
is conducted along with the costs associated with recovery.
1373
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- Policy formulation should include consideration of centralization or
decentralization of disposal facilities.
/
- Should the State become more involved in the designation of areas
acceptable for Class 1 disposal sites? Develop criteria specific
to the location of Class 1 sites and policies for the involvement
of the State in location problems.
- There is some confusion at the county level about the separate lists
of hazardous wastes put out by different state agencies. Another
problem is not knowing where the waste generators are.
6. Dr. Paul Palmer, Zero Waste Systems, Oakland (Resource Recovery)
- They have established that over half of the hazardous wastes being
dumped today could be recycled. Estimates that twenty or fifty years
from now 80 percent of the wastes that would have been dumped in 1975
will be providing raw materials for manufacturing. In the absence of
hidden subsidies for virgin materials and dumping, the economics favor
recycling.
- Recycling cannot yet compete with depletion allowances which arti-
ficially lower the prices of virgin materials. Recycling cannot pay
higher freight rates than the rates for identical loads of virgin
materials.
- Class 1 dumpsites represent a waste of resources. If we can recover
these resources then why should we even consider putting them into
the ground.
- Recovery of material resources has already proved itself economical,
in many cases, it already has surpassed the cost of virgin materials
on an equal basis, but they are not on an equal basis. Virgin materials
are subsidized, in many ways, and recycling has a difficult uphill
battle in every paticular case. Just recently involved in a case that
had 50 tons of very noxious material that they were hired to find a
way to recycle it. They did find a way to successfully recycle this
and it would have saved the dumper money and yet the individual company,
who had the option to dump anyway, decided to dump the material. It
was more a question of attitudes than of the economics, because the
economics were favorable. This situation happens time and time again.
- Recycling is not considered as an option today, because people have
the philosophy of the word "garbage". There is a feeling that recycling
is just an alternative to dumping. A recycling project has to start
directly at the beginning - in the design of the system. The speaker
before stated that he gave several thousand gallons of wastes to various
people for recycling and found that nothing came of it. He is not
surprised, because it is too Late at that point.
- He would favor a new law structured in such a way that a person would
be required to recycle if it was economically advantageous to him.
Then he would not have the option to refuse to recycle if it could
be shown that he would be saving money.
1371*
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7. Roy Miller, Miller and Gibson Industrial Pumping, Cupertino (Hauler)
- There is a must for a Class 1 disposal site around the Santa Clara
Valley area. Some of the smaller companies cannot afford the costs
of conveying the waste materials a great distance and therefore they
are getting rid of it anyway they can.
- The new manifest has been an asset to the haulers because now they
know what they are hauling, where before they never knew.
- He believes that the septic tank haulers, the pumpers, should be
licensed by the State Water Resources Control Board.
8. Jim Lemieux, Department of Fish and Game, Yountville (Other)
- Mr. Lemieux was concerned about radioactive materials being disposed.
Dr. Collins said that he would send Mr. Lemieux a copy of the regulations
adopted by the State Health Department regarding disposal of radioactive
materials.
9. Dave Eubanks, Solano Health Department, Vallejo (Other)
- He thinks that it would make regulation much easier if there were one
basic guideline either by the State or by all the counties in general
regarding the control of this problem. It is impossible to regulate
dumping} even the licensed haulers on occasion dump illegally. The
problems are worse with trucks from out of the county.
Summary of correspondence:
1. William C. Hern, Executive Director, Peninsula Manufacturers Association,
Palo Alto (Producers)
- Unless concerted planning is promptly undertaken, public and industrial
users will soon be confronted by cost burdens of major proportions.
- In the absence of any developing competition fees charged for use of
these sites have increased significantly and will continue to do so.
An attendant threat is posed at the privately owned sites where trucks
may be turned away without explanation.
- Government should be encouraged to cooperate more actively to assist
the scavenger companies in their efforts to develop replacement sites.
- The tactics of pressure groups must be counteracted by the dissemination
of information which describes the scavenger's growing difficulty in
providing satisfactory disposal of wastes within reasonable environ-
mental and economic limits.
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REDDING - July 14, 1975
1. Quintin Narum, Simpson Lee Paper Company, Anderson (Producer and Disposer)
- They operate a Class 2 landfill in Shasta County on leased property
and also a liquid waste treatment plant. In his 11 years of operation
he has not had a serious problem with hazardous liquid wastes. They
store approximately 10 barrels of materials that they could not put
into the liquid waste treatment plant on the millsite in an earthen
confinment. If a centralized facility were available to handle these
wastes, they would use that opportunity.
- He would favor the State developing a Class 1 landfill site plan end
participating in acquisition of sites, then releasing them to private
operators; especially in an area like Northern California because of
the sparsity of population and industry.
- Due to the very small amounts of wastes in Shasta County and in
Northern California generally - a transfer station would be quite
appropriate.
2. Mike Stevenson, Regional Water Quality Control Board (Other)
- If there is a significant number of Group 1 wastes in the area, then
they would like to have a Class 1 site, but at this time they do not
know of the quantity or types of Group 1 wastes in the area.
3. Bruce Wade, County Agricultural Commissioner (Other)
- Without a Class 1 site they are severly limited in the means of disposa
of pesticide containers. Feels that they don't have sufficient volume
of these materials, containers or anything else, to justify a Class 1
dump site locally, but feels that there is a need. Because of this lac
of facilities, he is sure that there is moonlight dumping of these waste
which is impossible to enforce.
4. Richard Curry, Director of Public Works, Shasta County (Other)
- He feels that there has to be a need for sites. To take inventory
of the need is the first thing that must be done, because he feels
that the need is very minimal in his county.
- Thinks that there would possibly be opposition to a Class 1 site from
the public.
5. Carl Arness, Public Works Director, City of Redding (Other)
- They had an environmental impact report on an expanded land use program
a few weeks ago and there were petitions submitted opposing the expansic
- The public felt that the EIR was inadequate in answering questions about
all the alternative sites, control of leachate gas, dust, noise, odor,
and blowing paper.
- He agrees that there should be an inventory of need.
:. 1376
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6. Bill Hiler, City of Redding (Other)
- Mr. Hiler was concerned about chemical toilet refuse.
7. C. R. Conroy, Chico Plating, Chico (Producer)
- Mr. Conroy did not feel that Northern California really has a disposal
problem.
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EUREKA - July 15, 1975
1. Don Burres, Oil Terminal Company, Eureka (Producer)
- Feels that an approved disposal site is needed. He has to store
wastes in tanks, which might last for another two to three years.
At periodic times he has to clean his tanks, but now he has nowhere
to put the wastes.
2. Pat Garrett, Humbolt Bay Oil Spill Co-op, Eureka (Other)
- Intent is to prevent oil spills on Humbolt Bay. Trains personnel
on the correct procedures of transfer of petroleum products. The
second function of the Oil Spill Co—op is to stop, contain, clean
up, and dispose of any spillage that should occur on Humboldt Bay.
Even though they have adequate equipment and personnel to handle
oil spills, efforts will be severaly curtailed by the fact that in
Humboldt County there is no place to dispose of any hazardous materials.
Spillage would have to be trucked to San Francisco. They are 100
percent in favor of Class 1 disposal site located in Humboldt County.
- They have attempted to stimulate interest in this matter and have
not been able to make any headway. Any help the State could give
them would be appreciated. They would favor anything that would
give them a Class 1 disposal site.
- Jack Pickett added that it was his understanding that the Coast
Guard can commandeer a Class 1 dump in the case of an emergency.
- He also operated oil storage facility and cannot dispose of his tank
bottom wastes, just holdJjig onto it. Haulers quit hauling in October
1974.
3. David Carlson, Union Oil Company, Eureka (Producer)
- Local haulers have no disposal site for solid waste and cannot compete
with contractors from the San Francisco Bay Area. This takes work
away from local people and contributes to unemployment in Humboldt
County.
4. Jack H. Pickett, Standard Oil Company of California, Eureka (Producer)
- The site of a Class 1 dump in this area would seem to be important to
the community as a local problem with a local solution.
- He questions whether the tank bottom wastes would be combustible mainly
because there is considerable amounts of water content in the bottoms.
That is where it accumulates. It could be incinerated with outside
heat or drying. A local disposal site would facilitate the clean up
of the entire area more readily than transporting it to the Bay Area.
- Feels that the community in Eureka will support a Class 1 site selected
by the State and possibly run by private or local agencies.
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— He doesn't feel that the bottoms waste material can be recycled, but
they are considering reclaimed oils.
>. Joe Creisler, Humboldt-Del Norte County Health Department, Crescent
City (Other)
- In order to protect the public health and safety and to prevent a
possible secondary spill in transportation they have set up an
emergency disposal site for the handling of oil and hazardous waste
materials from a spill on county property. While this is not an
approved Class 1 disposal site as set forth by rules and regulations
of the State Water Resources Control Board, they felt they had no other
alternative but to set up an emergency site in order to expedite the
proper removal of this type of material which could be a possible
public health and safety hazard.
— It is his hope that the Committee will look into the matter of the
problem of cleanup and disposal of petroleum and hazardous materials
from spill incidents which occur in rural areas some distance away
from authorized Class 1 disposal sites.
- He felt that one of the problem is that the program is so fractionized
that hazardous materials are handled in one way, oil spills another,
sewage a third, and pesticides a forth. There is no unity in the
approaches or contingency plans by federal and state agencies.
- They have attempted to have all hazardous wastes (oil, pesticide,
etc.) under county control. Problem of bootlegging occurs when the
county or state agency does not know where this stuff is going.
- He feels that there is no chance of finding a suitable area for a
Class 1 site. There is no potential with existing criteria, but
perhaps with membranes and changed criteria it may be possible.
6. Tom Dunbar, Regional Water Quality Control Board, Santa Rosa (Other)
- Nothing is being done about finding a Class 1 site in Northern
California. He doesn't think that anybody has had a significant
amount of wastes or problems with wastes yet to the point where they
have to go out and look for a site. The County, in their Solid Waste
Management Plan, has recommended that the State look into, develop,
and operate a Group 1 disposal site.
- Transfer stations appear to be a feasible alternative.
- They also have a problem with municipal incinerator residue in the
statewide criteria as a Group 1 waste.
7. Richard Smith. Director of Environmental Health, Humboldt-Del Norte
County (Other)
- Septic tank pumpings need, because of the hydrological conditions that
exist on the north coast, a Class 1 disposal facility for disposal.
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- Due to terrain, rainfall, rivers and the bay they are in very poor
position in order to effect a site that will please everybody. In
order for an individual to obtain a land disposal site for septic
tank pumping he needs the approval of the Health Department, Regional
Water Quality Control Board, Coastal Zone Conservation Commission,
and also the County Planning Department.
- The State should take into consideration the various regional or
unique features of an area that create this hardship in adopting
and applying regulations with respect to the removal and disposal
of these materials.
— The State should help in site selection, expenses in appropriating
sites and share or help provide for the means of removing these
materials to an acceptable site outside of the area.
- In his opinion, it would be almost impossible to find a site in the
area.
8. David Long, Mendocino County Health Department, Ukiah (Other)
- He feels that every county should have or have access to a Class 1
dump. They do have pesticide container problems. He would like
someone from the agency to come and look at some sites that they
have in mind for a central collection depot or transfer station.
Doubts that the driteria set up now could be met.
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THE CHAIRMAN: Thank you, Mr. Baker.
I believe we have some questions.
Mr. Kovalick.
MR. KOVALICK: Mr. Baker, I am interested in your
comments, and I gather it is the conclusion of the State of
California that it intends to play the role of possibly acquirin
facilities in the longer run — that is, the warehousing
facilities for future use.
If that is indeed the case, could you share with us
some of your thinking regarding the long-term care of those
facilities — that is, presuming, for example, they were
properly closed out — that is, filled and closed.
Is it the Board's position then that the taxpayers of
the State of California in the long term will pay for whatever
monitoring or observation of that site after its proper and
adequate closure?
MR. BAKER: It was the feeling of the committee that
after the site be obtained that it be let to private enterprise
to operate the landfill site. A user fee would be charged,
a percentage of which would be returned to the state for the
administration, both currently and after the operation was
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closed. The constant monitoring, the constant surveillance
of that — you know, we do not really know how long that
material will stay in the ground. It may be there ten or 10,000
years.
Yes, that is the recommendation of our committee.
THE CHAIRMAN: Yes, Mr. Kovalick. Do you have another
question?
MR. KOVALICK: Yes. Related to that, much of your
discussion seemed to relate to the placement and planning for
the Class One type disposal site.
Does your state plan address the location or the future
what I would call "treatment facility" — that is, not use land
disposal, but use chemical treatment or physical treatment. Is
that part of that planning process?
MR. BAKER: That at this point in time is not part of
the process. That is the treatment facility's. If you are
referring to such things as the sanitation district board or
information centers as to where materials might be or who might
be able to use part of that material — no. That at this point
is not recommended. It is not closed, either.
MR. KOVALICK: So the treatment industry is still part
of the long-term plan of California; it just is not a part of
this particular plan?
MR. BAKER: It is not at this time. And it is
definitely a part of the long-term plan.
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THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: Yes. I have a question from the
audience here.
You mentioned that San Diego has some unique disposal
problems. Could you please elaborate on that.
MR. BAKER: They have two Class One sites in San Diego
County that take certain types of chemicals, liquid wastes.
Others, which are very odorous, which are not acceptable, they
will not accept. And so they must be disposed of in an area
that will take them.
They are currently hauling through a contractor from
that area to a site in Nevada.
THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: Yes. I have a question from the
audience.
We have the State Solid Waste Management Board doing
a really fine job. Why do we need another layer of government,
in effect, duplicating much of the state's efforts?
MR. BAKER: I am not sure I know what is meant by
another layer of government.
If they are referring to a city or a county, that, by
California Constitution,exists. But those things which go beyon^
the jurisdictional capability of that county then must be by a
state agency in my opinion.
If they are referring to you, gentlemen — this is not
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necessarily a California problem. This is a national problem.
And there are areas of the nation that have an even greater
problem, perhaps than we have, and perhaps they have a greater
capability of solving it than we have. If what we can do here
is helpful to them, then wonderful. If it is not, then we will
not have at least lessened our efforts in California.
I think that much of the problem that we have is
because much of the imports; come from other states — that is,
the raw materials. And perhaps much of ours is exported to
other states. So it becomes a national or interstate problem.
I do not see how it can be confined to any one state.
If we are looking for, for example, an arid area for
solar evaporation and secondary mining, then it would be
necessary if there are no closed basins within a reasonable
area here, to transport that material to another state. So I
look at this as an interstate problem, not just a California
problem.
THE CHAIRMAN: Mr. Bourns.
MR. BOURNS: Mr. Eiaker, I have a question from the
audience.
It says: What agency will determine regulations of
hazardous wastes in California? Is that the State Health
Department or the California Solid Waste Management Board?
MR. BAKER: There are certain regulations already
established by the State Health Department. We will accept thos
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We also accept what your agency has outlined as a hazardous
waste description.
As I say, I am not a chemist. And all I know about
chemistry is that one part scotch and two parts soda is equal
to one big headache.
(Laughter.)
THE CHAIRMAN: Mr. Mausshardt.
MR. MAUSSHARDT: I have a question from the floor.
Provided that the state legislation does not allow
the right of eminent domain so that the state can acquire land
to lease to private enterprise for disposal site locations,
do you have any other thoughts on how to overcome the uninformed
public opposition to disposal site location?
MR. BAKER: I think through the educational process,
seminars such as you are conducting here, primarily in the
university areas or highly urbanized areas, where the employ-
ment of the people who are dependent on industrial firms who
have a non-sewerable waste problem is probably the alternative.
It takes time.
We have addressed that question. What happens if it
doesn't? Then we would look to you for assistance — that is,
your agency for assistance. Or some branch of the Federal
government. Whether it be in California or another state,
that, of course, must come to pass sooner or later.
I am of the opinion currently that there is sympathy foi
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the most part in the legislature for our program. Whether there
will be funding at this point in time, that only remains to be
seen.
THE CHAIRMAN: Mr. Lindsay.
MR. LINDSEY: Another question from the audience.
Is the state considering construction of a regional
incinerator for both liquid and solid wastes?
MR. BAKER: The state has no plans to my knowledge at
this time — at least not of the Solid Waste Management Board
to construct any incinerating plant.
There are funds proposed in the budget to assist in
recovery systems or development of systems that would assist
in the reduction, either in source reduction or recovery
programs. We are currently involved in a study to determine
which is the best method to go. We have hired a company. A
$400,000 grant to make surveys of the various sites available
and determine the best way to go into resource recovery.
Incineration is unlikely in California, at least in
the Los Angeles air pollution basin. There are many problems
there. And at least to my knowledge at this point in time
there is no method that totally meets the Los Angeles air
pollution standards.
THE CHAIRMAN: Mr. Baker, can I just ask if you might
clarify the study on resource recovery that you mentioned, does
that include both domestic waste and industrial waste?
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MR. BAKER: Solid waste, chemical waste, liquids,
sewerage, where it goes and what might be used, what might be
recovered or what by-products could be produced from it.
That is the important part of why government and
private enterprise should join hands.
Government cannot send salesmen in to the field to sell j
the products that they recover. Industry can. Government can-
not hire staffs to do research and development. They can
appropriate funds and go into contract for doing] that, but they
cannot do it. Private industry can.
And so with the two agencies working together — that
is, private and governmental agencies, I am convinced that
with this kind of cooperation it can be resolved.
THE CHAIRMAN: Mr. Bourns.
MR. BOURNS: Mr. Baker, I would like to ask you to do
a little prophesying as to what the situation might be in
Southern California as to their hazardous waste disposal. We
hear rumors that the big disposal sites down there are in
danger of being closed for reasons other than physical
capability.
Would you like to clarify that?
MR. BAKER: Yes, there is definitely that problem.
It is urbanization. Very definitely.
There are two major sites that are threatened. That
is the political implication, the effect of communities being
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developed and encroaching on existing landfills, people complain-
ing to the city council, the city council responding to their
constituency and keeping tight regulations on them.
This is primarily more towards private enterprise
than it is towards governmental operations. Sanitation districts
sanitary districts and large combinations thereof are difficult
to approach, and yet an enforcement agency can focus in on a
single operator. This does pose a bit of a problem. It could
very well be that political pressures are being brought that
could cancel use variance of an operation. That would seriously
impact that area economically.
As for a place to put them, it would have a serious
effect on Southern California's industrial economy.
THE CHAIRMAN: Mr. Baker, I have a question. Do I
read correctly from what you said that you would support future
landfill sites, and for that matter, processing and treatment
facilities, and that there be a buffer zone around these so
that you could prevent this type of encroachment in the future?
Would that be a reasonable solution?
MR. BAKER: That would be a large part of the solution
to the problem of both future and present operating sites.
There are several ways that that could perhaps be accomplished.
Acquisition of the buffer zone or obtaining air rights over
that zone or obtaining the "over rights" much in the same
manner as the airports regulate the land underneath them by
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what they call navigational easements. This is one possibility.
Open space zoning, which is difficult to accomplish because
there is still that basic fundamental property right of a land
owner to use his land. Agricultural zoning adjacent to it
possibly is a solution.
Yes, I do wholly support the buffer zone concept. And
I think that that is the consensus of the Board, the Solid
Waste Board.
THE CHAIRMAN: I believe we have one more question.
Mr. Bourns, do you have a question?
MR. BOURNS: You mentioned you were supervisor in
Orange County, and you mentioned the hazardous waste problem
in Orange County.
Do you have any Class One sites in Orange County?
MR. BAKER: No.
MR. BOURNS: What do you do with your waste?
MR. BAKER: Testimony at one of our hearings indicated
that they kind of turned their heads when the trucks came in
with known hazardous wastes, with known chemical wastes; allowed
them to dump them in those sites.
This is not only there, but many areas of the state.
That was offered in testimony both in confidence and in public
testimony.
Currently much of the industry will dump it into the
sewer system. It ends up at the sanitation treatment plants.
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However, much of it is also being transported over into an
adjacent landfill in Los Angeles County.
THE CHAIRMAN: Yes, Mr. Lindsey.
MR. LINDSEY: Yes. I have this one from the audience.
How do you view the dilution factor of hazardous
wastes being handled through ocean outfalls, specifically at
San Aleto?
MR. BAKER: Well, I do not think that pollution by
dilution is the solution.
(Laughter.)
MR. BAKER: I do not think that the oceans should be
the depository or anything of this kind. I am reminded of
what happened to Lake Erie a hundred years ago and what
happened today and what happened to many of our waterways in
the central United States. And while it may not be a problem
in the immediate foreseeable future — by that I mean the next
ten years — how do we know what is going to happen in 50 or
100 years?
So I am firmly convinced that the ocean should not be
the depository of anything but pure water.
THE CHAIRMAN: Thank you very much, Mr. Baker. We
appreciate your testimony.,
I would like to call upon Mary Lee, the Bay Area
Sewage Services«
Will you answer questions, ma'am?
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MS. MARY LEE: Yes.
I am Mary Lee, Chief Administrative Officer of the
Bay Area Sewage Services Agency. We are a regional governmental
agency representing the nine Bay Area counties.
Our board is composed of 21 locally elected representa-
tives from sanitary districts and cities that operate sewage
treatment facilities. The agency supports and calls for the
establishment of a regional hazardous waste study, through
the Section 208 planning process of Public Law 92-500. This
study should determine the present and future quantities of
hazardous wastes, and advance specific collection, treatment,
disposal and recovery systems for toxic and hazardous industrial
wastes on a regional basis. Such systems could take a variety
of forms such as regional or subregional treatment and recovery
facilities which are properly planned, designed and operated.
Solutions could be developed utilizing both existing private
systems and public facilities.
The agency is concerned that at the present time there
has not been adequate planning in regard to hazardous wastes
produced or expected to be produced in the region. Several
recent county solid waste management reports contain comments
that no estimates of the wastes are available or that solutions
must be addressed on a state or regional level. The existing
situation has been marked by environmental uncertainties,
inadequate proposals for additional Class One sites and a lack
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of application of advanced technological solutions for this
complex problem.
There is no reliable determination of the quantity of
hazardous wastes which are produced and no reliable estimate of
future production in the San Francisco Bay Region. Although
the State Department of Health is maintaining a record-keeping
system of the quantity of wastes delivered to Class One disposal
sites , this estimate does not account for wastes which are
illegally disposed of through unauthorized collection and
dumping either through manholes or disposed of through the
sewage system.
In addition, many communities in the Bay Area have
adopted or will soon adopt strong source control ordinances,
many of them using the Model Wastewater Discharge Ordinance
which was developed by the California Water Pollution Control
Association and my agency over the last two years.
The additional quantities of hazardous wastes which
will be removed from the sewers and conveyed to Class One sites
has not been adequately addressed. A related problem is the
form in which the hazardous wastes exist. A substantial portion
of the hazardous wastes now being produced are discharged to
sewers in liquid form. Due to more stringent source control
regulations, pretreatment of these wastes will be required
which will result in compounds of a different nature, depending
upon the pretreatment systems used.
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The data base in the Bay Area is poor. No adequate
solution can be planned until a good determination of these
quantities can be made.
We feel the logical mechanism for addressing hazardous
wastes in the Bay Area, including that of proposing solutions,
would be through the Section 208 planning process which is now
in its formative stages in the San Francisco Bay Region under
the direction of the Association of Bay Area Governments. This
program has the necessary prerequisites for success. Through
the policy and technical committees, all responsibile agencies
and organizations, public as well as private, can be represented
Data collection and proposed alternatives can be developed
within the time span of the 208 study, which is approximately
two years. And most importantly, the mechanisms for solutions
involving the legal, financial and managerial aspects necessary
for success can be developed.
The adoption of local source control ordinances will
not, in themselves, solve the problems. Specific treatment,
disposal and reclamation facilities which are adequately
planned on a regional level, properly financed, managed and
operated must be developed in order to provide hazardous waste
producers with a location for the wastes.
In addition, proper incentives must be developed in
order to insure that these facilities are used. These incentives
can be developed through the Section 208 planning process. It
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should be noted that for the 208 planning process in our area,
implementation of solutions has been and will continue to be
stressed.
Although a statewide study of Class One disposal sites
is underway, such a study will not provide the solutions needed.
Consideration of alternative solutions must include more than
just the need for additional disposal sites, although these are
sorely needed. The feasibility of hazardous waste treatment
must be considered along with the potential for resource
recovery and alternatives for construction, operation and
financing. Solutions need to be developed with the cooperation
of regional interests and organizations. This mechanism is
available in the 208 planning process.
Benefits from an adequate regional hazardous waste
facility and management program are numerous. I will enumerate
just a few.
Additional reliability for public treatment works by
elimination or reduction of toxic wastes which would cause
upsets.
Greater potential for reclamation and reuse programs
for water and sludge by public agencies through increased
reliability and lower degree of risk due to lesser amounts of
toxic and hazardous wastes in the system.
Enhanced reliability and safety through proper handling
disposal, treatment and reclamation of hazardous wastes with
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reduction in the quantity of toxic wastes entering the air,
ground and water environments.
Increased potential for reclamation and reuse of
hazardous and toxic wastes through economies of scale.
Possible monetary savings to industrial and commercial
establishments through economies of scale by providing
alternatives to remote Class One sites.
I would also like to acquaint you a little more with
the work of the California Water Pollution Control Association
Uniform Industrial Waste Ordinance Subcommittee. The Sub-
committee has broad representation of governmental and regulator
organizations, public wastewater dischargers and industries.
The overall purpose of the Model Ordinance, developed over the
last two years, was to provide a standard source document which
could be used by a variety of public agencies to assist in
the control of discharge of hazardous and toxic wastes to sewage
treatment works. Specific purposes of the Model Ordinance
included:
Establishment of uniform practices for enforcement
and facilitation of disposal of waste pollutants.
Promotion of greater efficiency among regulatory and
municipal agencies in carrying out industrial source control
programs.
Provision of a basis of equity to industry and private
wastewater dischargers who must comply with regulations which
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can vary from community to community.
Elimination of undesirable relocations of industries
from one waste treatment jurisdiction to another.
The Subcommittee has been encouraged by the degree of
interest and success expressed with the Model Ordinance. As a
next step to assist in the practical implementation of source
control measures, the Bay Area Sewage Services Agency and the
Uniform Ordinance Subcommittee are developing a proposal for
Industrial Waste Source Control Administration, Education and
Training. This program is directed toward personnel in public
agencies and industries including public agency administrators,
industrial wastewater inspectors, plant managers and employees
to provide the necessary tools and knowledge to advance the
purposes of source control.
In conclusion, BASSA believes that the problem of
hazardous wastes is an important one in the entire region. The
time and situation are opportune for developing a regional
approach for implementable solutions in the Bay Area through
the Section208 planning process of Public Law 92-500.
Thank you.
THE CHAIRMAN: Thank you, Ms. Lee.
I had a question. We have heard previous speakers
indicate that in their opinion the hazardous waste management
problem was best addressed at a state level. And as I under-
stand your feeling, it would be addressed at the regional level.
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Could you comment on that.
MS. LEE: Yes. We suggest the regional level, first of
all, because we are regional government.
Secondly, the 208 planning process in the San Francisco
Bay Area is already funded. It is approved. The work plan
began i,ts development two weeks ago using two of my top staff
people, one from J.B. Gilbert Consultants who is a top
consultant in our area, and two of Association of Bay Area
Government's top level people.
Once the program is developed it is due to be submitted
to EPA on March 31st. Then the implementation and the detailed
work will begin.
Now, source control is already included in the work
plan that was approved by EPA for four million dollars of fund-
ing for the 208 plan.
THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: I was wondering if you could describe
the relationship as you see it between the product of the
planning process that you are engaging, in and the solid waste
management plan that Mr. Baker just described.
It seems to me that at least some of the elements of
what you are interested in they will be addressing presumably
in your area.
And as a part of that question, I am interested in
whether you will be addressing residuals in your plan that are
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not waterborne — processes from the normal manufacturing
process that have never gone into the water, but that are still
a waste management problem, if you get what I mean.
MS. LEE: Yes, 1 understand what you mean. I am not
sure I can give you an adequate answer, as to whether the
residuals that are not waterborne will be addressed.
The 208 planning process does look at more than just
water pollution. It is land use, air pollution and all of the
environmental factors.
So I would imagine that as the work plan is developed
that all residuals will be addressed in some manner.
As to our interface with the State Solid Waste
Management Board, the Director of Regional Services of my agency
has been working very closely with the State Solid Waste
Management. He is on the Technical Advisory Committee. We are
quite aware of their studies. We are trying not to duplicate,
but to assist in every way we can.
THE CHAIRMAN: I had another question.
You mentioned the importance you place on source
control.
MS. LEE: Yes.
THE CHAIRMAN: And by that I presume you mean what we
would call "pretreatment" prior to discharge to the sewers.
MS. LEE: That is a portion of it.
THE CHAIRMAN: A portion of it?
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MS. LEE: We are also talking about the illegal
disposals, the simply opening of a manhole cover and dumping
it down.
I know when I was working in Berkeley we had a terrible
problem with industry simply putting their hazardous chemicals
into the storm drainage system because they did not know any
better.
THE CHAIRMAN: Well, my follow-up question is you
talked in terms of plant upset, the obvious implication being
that the material being illegally or surreptitiously discharged
was toxic to the microorganisms In the sewage treatment plant.
Is that the extent of your concern? There must be a
number of toxic materials which pass directly through the sewage
treatment plant into the sludge and have no effect --
MS. LEE: Yes.
THE CHAIRMAN: — on the microorganisms.
MS. LEE: Yes. We have several studies running through
our agency on all kinds of residuals.
We have a residuals management study for some two
million dollars. The lead agency for that is East Bay Municipal
Utility District along with the City and County of San
Francisco, San Jose, BASSA, and the Sanitary District in Contra
Costa County.
And we are looking into the sludge management problem
in that study.
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And all of our efforts interface and interrelate not
only within our own agency and the 208 program, but with all
the state programs in the county solid waste management plans.
THE CHAIRMAN: Mr. Lazar.
MR. LAZAR: Ms. Lee, based on your current estimates,
what percentage of the sewerage effluents comes from industrial
versus domestic sources?
MS. LEE: I have no idea.
Mr. Chu, do you have any information on that?
FROM THE FLOOR: I think this question is kind of
difficult to answer because everybody has different estimates.
But we do have some kind of figures if you are interested.
MR. LAZAR: Are you aware of any sewage situations
which have exclusively domestic waste and no industrial waste?
Is this common at all?
MS. LEE: Not as far as I know.
THE CHAIRMAN: Would you perhaps provide for the record
the figures that Mr. Chu referred to.
MS. LEE: Yes, I will be happy to.
THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: VJe have had some discussions in the
other meetings of the problems of the private hazardous waste
treatment industry and of course the sewage treatment, the
municipal sewage treatment, often in most places in the
country ,has been the role of the municipalities — at least in
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large measure .
Would you expect that the end result of your planning
process — that is, what it is you intend to implement — will
forecast a larger or smaller role for privately owned waste
treatment and disposing firms versus the public ones?
MS. LEE: Well, it is very difficult to judge since
the studies are just now underway. We do have private industry
represented on all of our technical advisory committees. Their
input is very vital to all of our programs. I would say it
would probably depend on the extent of pretreatment. Municipal
sewage treatment plants are now being upgraded to secondardy
and tertiary treatment and a lot of consolidation of treatment
plants in the Bay Area has been required.
I am not certain that those facilities would be able
to handle much more pretreatment of toxic wastes. It may be
that a private treatment works would be needed.
MR. KOVALICK: Well, given that some kind of additional
facilities are required, regardless of the reason for that, what
would be the decision rule for deciding whether it should be
publicly or privately owned — I guess that is what I am getting
at — given that some are required.
MS. LEE: I am sure it would be economics.
MR. KOVALICK: You mean whether or not someone could
make a profit at it. Is that what you mean by "economics"?
MS. LEE: That would be involved. It would also entail
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whether or not federal funds would be available for construction
of additional facilities. The municipal and special districts,
I am sure, would not have the additional funding necessary to
build extra pretreatment works at this point in time.
THE CHAIRMAN: I think that is all the questions we
have.
Thank you very much, Ms. Lee.
Next I would like to call Mr. Walter Umstead of the
Western Oil and Gas Association.
Is Mr. Umstead here?
FROM THE FLOOR: I am Mr. Knowlton for Mr. Umstead.
THE CHAIRMAN: All right. Will you please identify
yourself for the record.
Will you answer questions, sir?
MR. HAROLD D. KNOWLTON: Yes.
THE CHAIRMAN: Thank you.
MR. KNOWLTON: My name is Harold D. Knowlton and I am
employed by Chevron Research Company, Richmond, California, where
my professional responsibilities involve refinery environmental
control activities. I am also a member of the Committee on
Solid Waste Management of the American Petroleum Institute. I
am submitting these comments on behalf of the Western Oil and
Gas Association and the American Petroleum Institute.
I would like to express appreciation for this
opportunity to comment concerning development of guidance on the
0*1,2
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environmentally safe management of hazardous wastes. My
comments will be limited specifically to Discussion Topics 1
through 4 and Topics 6 and 16.
Discussion Topic 1.
It is difficult to define a hazardous waste. The
definition must be sufficiently comprehensive to satisfy the
complex conditions and circumstances applicable to sound
hazardous waste management. Recognizing this problem, we are
currently sponsoring several studies which we hope will assist
i
in defining hazardous waste.
The results of these studies will of course be made
available to EPA. We understand that EPA is conducting
similar studies. We would urge that the final regulatory
definition of hazardous waste await the outcome of these various
studies. Until such time as a specific, satisfactory definition
is developed, the following general working definition of
hazardous waste seems to us to be reasonable and appropriate:
"Any waste or combination of wastes which,
because of its quantity, concentration, or
characteristics, presents a real and measurable or
potential hazard to human or animal health or
causes permanent damage to the environment by its
disposal."
Criteria used to distinguish hazardous from non-
hazardous wastes should cover the following questions:
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One. Hazardous to what?
Two. Hazardous for what reasons?
Three. Hazardous to what degree?
Four. Hazardous under what conditions and
circumstances?
The principal criterion should be effect on the
environment. For example, merely because a waste contains a
toxic chemical, it does not necessarily follow that the waste
is hazardous to the environment. Material properties should
not be the sole basis for defining hazardous wastes. In
implementing solid waste legislation, regulatory agencies must
consider that wastes of the same general type do sometimes vary
in actual composition, and therefore should not necessarily be
considered hazardous simply because they fall into a categorized
list of hazardous wastes.
We take serious issue, for example, with a regulation
prohibiting the disposal of any industrial waste containing
any concentration of any materials in a list of "toxic
substances." Such a regulation could cause havoc in this
industry and other industries as well as in the government
agency administering the regulation since, given the capability
of modern chemical analysis, almost any waste generated could
contain some minimal concentration of one of these substances.
As we noted before, the criteria for establishing a
hazardous waste should be based on the total quantity of harmfu
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materials, the concentration of the materials, their character-
istics, and resultant effects on health or the environment.
With respect to the last two questions of Discussion
Topic 1 concerning collection of waste samples and analytical
methods, the American Petroleum Institute is sending you a copy
of the sampling methods and analytical techniques which API
has prescribed for its current survey of petroleum refining
solid wastes. These methods and techniques represent the
best technology developed by experts in our industry.
Discussion Topic 2.
As to who should bear the responsibility, liability,
and costs of hazardous waste disposal, we believe that
One, The generator should be obligated to collect and
safely contain all hazardous wastes. Further, the generator
should be responsible for accurately characterizing and represen
ing the wastes, contracting with a properly licensed hauler,
treater, or disposer and for maintaining records. The generator
should be responsible for issuing a contract which requires
compliance with all applicable regulations. The contract
should document the method of hauling the material, the method
of treatment, and the method and location of ultimate disposal.
The hauler, treater, or disposer should furnish a copy of his
operating license to the generator.
Two. The transporter should be responsible for pbtainin<
a hauling license and for maintaining records of origin,
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destination, and characteristics of material hauled.
Three. The treater of hazardous waste should be
responsibile for adequate processing facilities for safe
handling and treatment, for storing treated wastes properly,
and for maintaining records of the waste process, the generator,
and the hauler. The treater should also be responsible for
complying with applicable emission regulations.
Four. The disposer should be responsible for maintain-
ing records of wastes received and disposal techniques employed,
for obtaining an operator's license, and for complying with
applicable emission regulations.
Five. If any of the conditions of the contract are
violated by the hauler, treater, or disposer, these violators
should be liable, not the generator. The generator should not
be liable for poor operating practices by the hauler, treater,
or disposer that violate license requirements.
Six. The costs of proper waste disposal should be
borne first by the generator. However, the consumer ultimately
pays the bill. For that reason we must insure that the cost
of solid waste regulation is not disproportionate to its
benefits.
Discussion Topic 3.
No specific requirements or prohibitions should be set
governing the recovery, reuse, or disposal of industry wastes.
Wastes are generated under different circumstances, and the
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feasible disposal method can vary significantly among generators
because of location conditions and other factors. Obviously,
all wastes should be disposed of in an environmentally acceptabl
manner. Recovery and reuse where practical has been and continue
to be pursued in the petroleum industry. This practice is
particularly applicable to oily wastes, where oil can be
separated and recovered. However, because of their individual
properties some oil wastes cannot be de-oiled economically.
Energy required to de-oil certain wastes exceeds the energy
recovered, making such a process uneconomical and wasteful.
In such a case an environmentally sound, alternate disposal
method such as land spreading — which utilizes the natural
decomposition process and a minimum of energy — is employed.
Disposal methods (b) through (f) under Discussion Topic
e should be options of the generator who should process and
dispose of the wastes in an environmentally acceptable manner.
For example, incineration is used by some refineries. However,
it is one of the most expensive methods in terms of capital,
operating costs, and energy consumption, and an ash residue
disposal problem remains. Similarly, land emplacement is used
by many refiners; however, this technique may be impractical
where land is scarce.
Discussion Topic 4 .
We are limiting our comments here to leaded gasoline
storage tank sludge, a common toxic waste. It has been a
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widespread practice for many years in the petroleum industry to
detoxify leaded gasoline storage tank sludge by a weathering
technique. Leaded gasoline storage tank sludge has also been
buried in designated areas. Of the two methods, weathering is
preferred because of its inherent ecological advantages. Field
experience indicates no air, water, or soil contaminat:
problems. It is a safe, effective, and economical technique.
In brief, the weathering technique consists of spreadit
the sludge to a depth of three inches in the tank farm area or
in an area remote from habitation. After four weeks of weather-
ing, sludge can be treated as any other nontoxic industrial
waste, provided that lead-in-sludge tests indicate less than 20
ppm organic lead. A pertinent reference — API Publication
2015A, "A Guide for Controlling the Lead Hazard Associated
with Tank Entry and Cleaning" — is being sent to you by the
American Petroleum Institute.
Discussion Topic 6.
There are abundant government and industry publication
outlining recommended safety and security procedures for the
treatment, storage and disposal of hazardous materials.
Existing procedures for the handling of hazardous materials
before they become incorporated in wastes are adequate and
additional regulations are not required.
Government regulations developed for hazardous waste
management should be consistent with existing Federal regulatio
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such as:
a. Department of Transportation, CFR Title
49, Parts 100-199, 1973.
b. Occupation Safety and Health Administration
(OSHA) regulations Section 1910, Hazardous
Materials.
In addition, a National Fire Protection Association
pamphlet, No. 49, 1975 edition, is an excellent reference used
by many segments of our industry.
We feel that the generator, the treater, and the
disposer should each be responsible for all facets of employee
training to insure compliance with hazardous waste management
regulations.
Discussion Topic 16.
All industry is dynamic. The demand for products and
the technology avilable for their manufacture are continually
changing.
The production of by-products and wastes likewise
changes continually, both as to characteristics and quantities.
The industry providing waste treatment and disposal services
must be just as dynamic as the generators it serves.
The private and competitive business community can
provide necessary services at lowest possible cost, keep pace
with the varying needs of generators, and provide facilities
which will satisfy environmental restrictions. It is likely
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that government involvement in hazardous waste disposal would
lead to requirements that generators guarantee specified feed
streams to certain disposal facilities over long-term contract
periods. This could be environmentally counter-productive.
The proper and effective government role, we feel, is
to set minimum standards and monitor activities as necessary
to protect health and welfare. The reality that the operation
of hazardous waste disposal facilities can impact on the
environment indicates that emissions should be regulated (as
the emissions of other sources are), but this is not an argument
for either government operation or government establishment of
a regulated monopoly.
Generators should be free to increase or decrease waste
production rates, terminate waste production, treat their own
waste, and negotiate treatment or disposal service contracts
in a free and competitive market.
We thank the EPA for this opportunity to present our
views.
Thank you.
11*10
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nerlcan Petroleum Institute
)1 L Street Northwest
ishington, D.C. 20037
2-457-7000
. W. Umstead
202) 457-7084
December 17, 1975
r. John P. Lehman
irector, Hazardous Waste Management Division
'ffice of Solid Waste Management Programs (AW565)
Invironmental Protection Agency
ashington, D.C. 20460
'ear Mr. Lehman,
The enclosed documents, referred to in the statement presented
iefore the Environmental Protection Agency at the San Francisco public
leeting of December 11, 1975 on hazardous waste management by
r. H. E. Knowlton on behalf of the Western Oil and Gas Association
.nd the American Petroleum Institute are forwarded for your infor-
lation.
Sincerely, ,
WU:lab
:c: H. E. Knowlton
Incl. (1) American Petroleum Institute Refinery Solid Waste Survey
1976, sampling methods and analytical techniques. (Referred
to under Discussion Topic 1, p.3)
Incl. (2) A Guide for Controlling the Lead Hazard Associated with
Tank Entry and Cleaning, API Publication 2015A (Referred
to under Discussion Topic 4, p.6)
equal opportunity employer
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AMERICAN PETROLEUM INSTITUTE
REFINERY SOLID WASTE SURVEY
1976
Instructions
and
Appendixes
Department of Environmental Affairs
American Petroleum Institute
2101 L Street, N. W.
Washington, D. C. 20037
H*12
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INTRODUCTION
This survey develops data on the life cycle of solid wastes generated by
petroleum refineries. The results of the survey will enable the industry to
respond to solid waste management legislation expected to be enacted by the
Congress and implemented by EPA in 1976.
The survey questionnaire is designed to collect data on refinery
characteristics, types, quantities, generation rates, and composition of refinery solid
wastes, as well as methodology currently used by the refineries in the treat-
ment and disposal of these wastes.
QUESTIONNAIRE
The survey questionnaire is comprised of individual information sheets on
each of the subject areas enumerated below:
REFINERY:
1. Intake Waters
2. Crude Oils
3. Background Soil
SOLID WASTES:
1. Once-Through Cooling Water Sludges
2. Cooling Tower Sludges
3. HF Alkylation Sludge
4 Waste FCC Catalyst
5. Treating Clays
6. Tank Bottoms
7. Storm Water Silt
8. API Separator Bottoms
9. Air Flotation Float
10. Waste Biological Solids
TREATMENT AND
DISPOSAL METHODS:
1. Sludge Dewatering
2. Sludge Farming
3. Incineration
These information sheets are to be filled in as completely as possible.
They may be completed in pencil or ink or typed so long as they can be
adequately reproduced on a zerox machine. Where actual data are not avail-
able, estimates should be provided. It is not necessary to revalidate data
already in hand from previous relevant work. Existing data are acceptable as
long as they are representative of actual conditions.
Included in the information sheets of the questionnaire are requests to
take and analyze samples relating to refinery characteristics, solid wastes,
and treatment and disposal methods. An Analytical Data Sheet is to be used to
report the analytical data pertaining to each sample. A blank Analytical Data
Sheet is included with the questionnaire and at page 10 of these instructions.
Additional copies as necessary should be,duplicated by the refinery. Every
11*13
-------
effort should be made to take and analyze samples as requested in the question-
naire. If samples are not obtainable or existing data are insufficient to
prepare the Analytical Data Sheet, it is nevertheless requested that the
applicable information sheet be completed.
In completing the Analytical Data Sheets care should be taken to insure
that the notation used to describe the samples in the individual information
sheets of the questionnaire is also used in the corresponding Analytical Data
Sheets. Likewise the Laboratory Number entered in the Analytical Data Sheet
should be repeated in the corresponding information sheet. Laboratory
numbers may be assigned from the regular numbering system or from a series
assigned especially for this survey.
The data being requested in this survey relate to solid wastes normally
encountered in a refinery. In the event that a refinery generates solid
wastes of a different type, data on such wastes should be furnished on supple-
mentary sheets. Note, however, that information is not being requested for
sludges resulting from clarifying, softening, or otherwise the intake water,
since these sludges would not be different from those generated by public
utilities or other manufacturing plants.
A period of about five months is being provided to the companies for
completion of the survey questionnaire. This should allow ample time for the
sampling of tank bottoms. Completed questionnaires including applicable
Analytical Data Sheets and schematic diagrams as requested below should be
returned to the following address not later than May 1, 1976.
Mr. Walter V*. Umstead
Department of Environmental Affairs
American Petroleum Institute
2101 L Street, N.W.
Washington, D.C. 20037
(2Q2) 457^7084
Upon receipt of the questionnaire, API will assign it an API Code Number
remove the cover sheet on which the company name appears and forward the
questionnaire identified only by the API Code Number to Engineering-Science,
Inc. Engineering-Science will tabulate and correlate the survey results and
prepare the survey report.
When Engineering-Science has finished its work and the final report is
approved, the completed questionnaires will be returned to the companies.
SCHEMATIC DIAGRAMS
It is requested that schematic diagrams be submitted as follows:
(1) Provide a general schematic diagram of the sewer system including
impoundment facilities, to assist in understanding the sources of the sludges
accumulated in the API separator(s), and the storm and/or the process waste wate
impoundment facilities.
-------
(2) Provide a solids flow schematic diagram, to assist in understanding
the solids handling system within the refinery. All of the sludges described
in the questionnaire should be included in this diagram. Each of the solids
flow lines, as applicable, should be labeled in accordance with the informa-
tion sheets. All sources are to be included along with all solids handling,
dewatering, and disposal facilities.
SAMPLE COLLECTION
The following are guidelines for the collection of representative samples:
1. Many of the samples required for this survey have three distinct
phases (hydrocarbon, aqueous, and solid) As this is not usually the case in
refinery sampling, care should be taken to preserve the ratio of the three
phases in the sample taken.
2. A sample should be collected in sufficient volume to minimize
sampling errors and to provide enough sample for analytical aliquots to be
taken. Four-fifths of a gallon in a 1-gallon can is suggested
for a majority of the samples. Samples from tank or vacuum trucks should
be no less than 4 gallons in a 5-gallon crimped-top pail to be representa-
tive.
3. Plastic sample containers should not be used for field samples.
4. As a minimum, samples should be labeled to include the following
information:
a. Date
b. Source
c. Person sampling
d. Identifying number
e. Any special sampling conditions (i.e., rainy, windy, etc.)
5. The discharge from sludge removal or conveyance pumps, such as the
pumps on the bottoms of an API separator or on the float from an air flota-
tion unit, can be sampled as for any refinery flowing stream.
6. Sludge removed by vacuum and tank trucks should be sampled at the
place where it is discharged. Samples should be representative of the bottom,
middle, and top of the truck contents.
7. The background soil sample should be taken at a point close enough
to assure that the data are representative of the background soil conditions
at the refinery. This sample should be collected at a minimum depth of one
foot below the ground surface. This background soil sample will indicate the
virgin soil conditions within the refinery; and it, therefore, should be taken
from a relatively undisturbed area.
8. Field samples should be separated on the day collected into equiva-
lent analytical aliquots. The field sample should be made as homogeneous as
possible by the use of a paint shaker, if available, or by vigorous stirring.
Ten analytical aliquots should be taken, each in 100-110 ml volumes. Aliquots
should be stored in glass.
9. If the aqueous extraction procedure as defined in the Analytical Measure-
ments sections is postponed, the aliquots should be refrigerated at 33°F to 35°F
until the extraction is made.
IklS
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ANALYTICAL MEASUREMENTS
The various solid wastes and the phases to be analyzed are listed in
Table I. The individual analytical constituents are listed on the
survey's comprehensive analytical data sheet.1 Existing analytical
data on any of the waste sources can be used; however, these data
should be representative of the true waste composition and the
information supplied on the survey information sheets.
Figure 1 has been prepared as a working scheme for sample separa-
tion and analysis. A narrative explanation is presented below to
provide more details.
The field samples collected in accordance with the suggestions in
the preceding section are brought to the lab for characterization.
Each fluid or semifluid sample is homogenized with a paint shaker
or by vigorous stirring and broken into ten equivalent analytical
aliquots with a volume of approximately 110 ml. These aliquots are
to be stored in a refrigerator until the analyses are complete. Extra
samples should be kept until you see the final survey report.
Analytical Aliquot No. 1 is used for Part 1 of the analytical sequence,
Ever" refinery involved in the survey is expected to complete Part 1.
Part 1 involves the determination of the bulk density and phase
partition of the sample into percent benzene extractables, percent
water, and percent solids by weight. The well-shaken aliquot is
poured into a tared 100-ml graduated clylinder and weighed to get
the bulk density. The cylinder contents are then transferred with
benzene into a 500-ml capacity ASTM D 95 flask. The percent by
weight of water is determined by a modification of the ASTM D 95
procedure using benzene and reported on the respective analytical data
sheet for the sample. Benzene is chosen because it is the best
solvent for defining the hydrocarbon phase we want to separate
out of the sample, can be more easily separated from the oil than
a higher boiling solvent, and will ensure getting all the benzo-
a-pyrene and asphaltenes. Its use in the water-by-distillation
step will result in a long elapsed time in carrying out this part
of the analysis.
The residue in the D 95 flask is further extracted with benzene
in a Soxhlet extractor. The dried residue is reported as percent
solids. The benzene extractables are reduced in volume by
removal of the benzene solvent and weighed. The benzene is
removed by distillation with reflux to minimize hydrocarbon loss.
It is suggested that the Kuderna-Danish evaporative concentrator
and a tube heater (Kontes catalogue) be used in finishing off
this separation. This extract is representative of the quantity
of hydrocarbon or oil phase.
1.
An Analytical data sheet form is inserted at page 10.
1A16
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TABLE 1
SAMPLE PHASES TO BE ANALYZED
Phases to be Analyzed
Hydrocarbon Aqueous Solid
ifinery Data
Intake Waters X X
Background Soil X
Crude Oil X X
ilid Wastes
Once Through Cooling Water Sludge X
Cooling Tower Sludges X
Alkylation Sludge X X
Waste FCC Catalyst X
Treating Clays X X
Tank Bottoms X XX
Storm Water Silt X
API Separator Bottoms X XX
Air Flotation Float X XX
Waste Biological Solids X XX
•eating Methods
Sludge Dewatering X X
Sludge Farming X XX
Incineration • XXX
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'hese Part I data provide a very important set of characterization
numbers,since all of the Part 2 detailed analytical information
nust be reported by relating the Part 2 data to the phase percen-
:ages by weight from Part 1. These analyses will then be the
jases of the industry projection which the survey contractor will
nake. Any loss in material in this separation will be thought of
is due to a light hydrocarbon or light water-soluble organic phase.
.'his loss number is included with the analytical data for com-
pleteness but is not a suitable measurement for any industry projec-
:ion.
?art 2 of the analytical sequence diagram starts with water washing so
is to provide an idea of what the first rain may wash out of the oily
sludge. It is, therefore, important that no other chemicals or treat-
lent be used before the representative water is removed.
?art 2 of the scheme does not require the quantitation that Part 1
lid. However, as one goes through the scheme, the phase separations
should be as clean as practicable. Nine analytical aliquots are
available for Part 2 use. It is preferable to do Part 2 work on
i single sample because of the volumes of solvent involved.
towever, if a single aliquot is insufficient for one of the phases
>ased on Part 1 data, several samples are combined to provide
:he necessary volume. One separate aliquot is used for the
>henolic content determination using STORET Method 32730.
'he water extraction method using a single aliquot is carried out
is follows.
Mix the analytical aliquot with deionized, distilled water
ihown to have negligible metals content in a volumetric 1:4
ratio of sludge material:water at room temperature. This can be
one by the method of volumetric displacement, which is as follows:
a. 100 ml of water is placed into a 1-liter graduated
:ylinder or other calibrated container that can be handled on
in automatic shaker.
b. Sample material is added until the mixture reaches a volume
>f 200 ml.
c. The vessel is filled to 500 ml with purified water.
:. Cap tightly and shake vigorously on a mechanical shaker.
After shaking, the suspension is allowed to settle overnight.
After settling, the aqueous phase is carefully removed with
i syringe (or by decanting or siphoning), leaving behind the
•mulsion cuff.
-------
In making this separation, one should strive for an emulsion cuf
as small as practicable. Centrifugation may help provide a clea
phase partition. Three alternate schemes for getting the repre-
sentative water, depending on the oiliness of the sample and the
size of the cuff, are shown in Figure 1 and further described be
a. If the volume of the emulsion cuff is less than 5% by
volume of the total sample volume (e.g., 25 ml) and the sample
does not appear to have an oily phase, then a suitable volume of
the drawn-off water is filtered through a 0.45-^ji membrane filter
This separated water is the representative aqueous phase for the
Part 2 analysis. Oil content for such a sample is ignored unles
oil specifically shows up when the solids are dried by distillat
extraction.
b. If the volume of the emulsion cuff is less than 5% by
volume but the aqueous phase is oily, then the water removed is
washed with benzene. The benzene washes are added to the benzer
extractable phase. The benzene-washed water is then filtered
and analyzed.
c. If the volume of the emulsion cuff is greater than 5% bj
volume, then all liquid (oil, water, and cuff) is drawn off sol:
Suitable volumes of benzene are added to the liquid, and benzem
and aqueous phases in the absence of the solid will hopefully
separate. The aqueous phase is filtered and analyzed as require
The benzene washings are added back to the solids phase for fur-
separation.
The solids and oil phases remaining after the aqueous phase
extraction are acidified with 1:1 sulfuric acid to spring the
organic acids bound to the solids. The sample is dried with
benzene by the modified &STM D 95 method. The solids are
separated by filtering and further washing with benzene. The
benzene-soluble phase after reduction in volume is now ready
for analysis. There is no need to remove the
last traces of benzene. An aliquot is related to the whole
by the Part 1 analysis. The solids are dried at 105°C to const
weight. If the solids are to be analyzed by several different
methods for the different elements, now is the time to homogeni
the solids and take aliquots.
Suggestions for analysis of the various phases follow. The
generally requested level of detection is 0.1 ppm. Where
analytical sensitivity is readily obtainable at lower levels,
the lower level number will be appreciated. If plus and
minuses can be put on the answers to indicate the number of
significant figures, this will also be appreciated.
1. Hydrocarbon Phase
Benzo-a-pyrene is a difficult analysis, but one which is often
made. Two methods for making this measurement are included in
-------
the Appendix, They come from two different companies. Nickel
and vanadium can be measured by atomic absorption. In the
Part 2 analysis, preparation of the oil phase, high grade benzene
redistilled in glass, such as is available from Burdick and
Jackson, must be used to avoid contamination.
2. Aqueous Phase
The aqueous phase should be analyzed for the constituents
stipulated on the analytical data sheet by whatever methods
you have developed for testing refinery effluent waters. If
you don't have experience, we suggest the following approaches.
Wet chemical analyses should be used for cyanide and fluoride.
The designated elements can be analyzed by atomic absorption.
The recommended reference is the latest EPA volume entitled
"Manual for Chemical Analysis of Water and Wastes, 1974."
Another useful reference is the 13th edition (1971) of "Standard
Methods for the Examination of Water and Waste Water" prepared
and published jointly by the APHA, AWWA, and WPCF.
Hexavalent chromium can be measured by the EPA wet chemical
method or the special AA procedure provided in the Appendix. It
is unlikely that hexavalent chromium will show up in•the waters
drawn off of oily samples. However, this is a point we would
like to get information on in this program.
3. Solids Phase
The solids phase is to be analyzed for the constituents stipulated
on the analytical data sheet. Each laboratory should choose
methods with which they have the most experience and in which they
have the greatest confidence. These may include emission
spectroscopy, X-ray fluorescence, neutron activation analysis,
electrochemical methods, and atomic absorption. Here again, we
are seeking numbers as low as the 0.1 ppm level. In the
absence of other experience, it is suggested that the Simple Wet
Ashing Procedure, 211.1A, in the 13th edition of Standard Methods
followed by an AA finish be used. A digestion procedure especially
for the recovery of arsenic, mercury, and selenium is listed
in the Appendix with the special analytical Methods.
-------
ANALYTICAL DATA SHEET
Sample Description __ Lab No,
Part 1
Bulk Density: _ 3/100 ml. Phase Portions
Hydrocarbon Phase _
Aqueous Phase _
Solid Phase _
Loss _
100.0%
Part 2 _ CONSTITUENT CONCENTRATIONS
_ Parameter mg/kg of Phase mg/kg of Total Sample
HYDROCARBON PHASE
Benzo-a-pyrene _ _
Nickel _ _
Vanadium
AQUEOUS PHASE
Arsenic _ _
Cadmium _ _
Chromium (Total) _ _
Chromium (Hexavalent) _ _
Copper _ _
Cyanide _ _
Fluoride _
Lead _ _
Mercury
Nickel _ _
Selenium _ _
Vanadium
Zinc
SOLID PHASE
Arsenic _ _
Cadmium _ _
Chromium _
Copper _ _
Lead _ _
Mercury _ _
Nickel _ _
Selenium _ _
Vanadium _ _
Zinc _ _
Total Sample
Phenolics
API Code Number
-------
AMERICAN PETROLEUM INSTITUTE
REFINERY SOLID WASTE SURVEY
1976
APPENDIXES
Appendix Special Analytical Method
A Exxon method for Benzo (a) pyrene
B ARCO method for Benzo (a) pyrene
C Chevron method for Hexavalent
Chromium
D ARCO method for Wet Ashing
Procedure for As, Hg, and Se
-------
APPENDIX A
Method for Benz(a)anthracene, Benzo(a)pyrene,
And Other Polynuclear Aromatic Hydrocarbons in
Automobile Exhaust, Gasoline and Crsnkcase Oil
Introduction
This method was developed to determine polynuclear aromatic
hydrocarbons in gasoline, crankcase oil, and tar froa auto exhaust.
Scope3
Th,e method covers polynuclear_ aromatics (PNA) ranging from pyrene
to benzo(g,h,i)perylene. As described herein, eleven PNA's are measured,
including: pyrene, benz(a)anthracene, chrysene, triphenylene, ir.etl-.ylbenz-
(a)anthracene, dimethyl and/or ethylbenz(a)anthracene, benzo(a)pyrene
benzo(e)pyrene, methylbenzo(a)pyrenes, methylbenzo(e)pyrenes and benzo(g,h,i;
perylene. Additional PKA's can be included. The procedure was successfully
demonstrated for gasoline, exhaust tars and crankcase oils.
A sample to be analyzed is spiked with known Quantities of carbon-1^
labeled benzo(a)anthracene (BaA) and benzo(a) pyrene (BaP). Some polar com-
pounds are removed by a caustic treatb and then a PNA hydrocarbon concentrate i
obtained by solvent elucion off a column of partially deactivated alumina.
The solvents are cyclohexane, cyclohexane-benzene, benzene, and benzene-methane
The fraction containing the PNA's is reduced to a small volume by evaporation
on a steam bath. An aliquot of this sample is injected into a gas chromatcgrap
and fractions are collected for measurement by UV and, in the case of 3aA and
BaP peaks, also for carbon-14 activity. These activities, compared with knovn
concentrations originally added, give factors by which to relate the concen-
trations of each PNA to its total weight in the sample.
5
Apparatus & Isotope Dilution
1. The Gas Chromatograph is equipped with a flame ionization detectc
a linear temperature programmer and a flow controller. The injection port con-
sisted of an aluminum block with a stainless steel tube which slides into the
block. A quartz sleeve fits inside of the stainless steel Cube. The chror.a:o-
graph is modified by the addition of a by-pass and trap so that 157. of the
column effluent will gc to the detector and 857. to the trap. This arrangement
shown in Figure 3 (P-9).A Perkin-Elmer 900 chronatograph was used in the de-
veloptr.enc of this method, but equivalent instruments should perform sacistactor
a » At the time of this report, work is in progress to also include fluoranthen
benzo(b)fluoranthene, benzo(j)fluoranthene, benzo(k)fluoranchcne, peryle
and coronene.
b « The caustic treat is done on tar samples only.
Excerpt from CRC-APRAC Project Final Report CAPE -12-68 U.S. Public
document #PB219-025 - Author Exxon research personnel R. A. Brown,
T. D. Searl, W. H. King, H. A. Dietz, and J. M. Kelliher. 1971.
-------
2. Recorder. 0-t millivolt, 2 Bin./inch chart speed.
3- Trapping Tubes. 20 or more stainless steel tubes, 18 cm long by
0'.32 cm diameter.
4. Column, 300 cm of .22 cm I.D.stainless steel tubing packed with
21 SE-30 (GC Grade) on Chromosorb G (acid washed and DMCS treated), 80/100 mesh.
5. Syringe, 10 microllter.
6. Spectrophotometer. spectral range 225-400 nanometers, with spectral
•lit width of 2 nra or less. Under instrument operating conditions for these
absorbance measurements, the Spectrophotometer shall also meet the following
performance requirements: absorbance repeatability, ± 0.01 at 0.4 absorbance;
absorbance accuracy, + 0.05 at 0.4 absorbance; wavelength repeatability, + 0.2 nm;
wavelength accuracy, +1.0 nm.
7. Spectrophotometric Cells, fused quartz cells having optical path
lengths of 1.000+ 0.005 cm and 5 cm cells. The 5-cm cells are microcells and
contain about 3 ml of solution.
6. Graduate Glass. 5 ml.
9. Vials, one- and three-dram with cap.
10. Steam Bath equipped with nitrogen outlet for purging vials.
11. Medicine Dropper, with tip drawn out.
12. Special Low UV Emission Room Lights. Westinghouse W-40-gold
fluorescent lamps.
13. Chroma tographlc Column, two feet long 0.5 inch OD and 0.43
inch ID with 300 ml receiving bulb on top and stopcock with Teflon barrel on
the bottom.
14. Radiation Counters used are Intertechnique SL-20 and Packard
Tri-Carb.
15. Counting Vials, 20 ml with cap.
Reagent and Materials
Reagent grade chemicals must be used throughout. Benzo(a)pyrene was
repurified but other polynuclear compounds were used as purchased. Compounds
of comparable purity from other suppliers may be employed.
1. Cyclohexane. As a large amount of cyclohexane is used, it must
be of highest purity. To check purity, evaporate 180-ml down to 5 ml. Run a
UV scan on this residue In a one-cm cell from 280-400 nm. The absorhancc should
-------
not exceed 0.01 units. To purify, percolate through activated silica gel.
Grade 12, in a glass column, 90 cm long and 5-8 cm diameter. "Distilled in
Class Solvents" are generally of suitable purity.
2. Toluene.
3. Acetone.
4. Sodium hydroxide.
5. Hydrochloric Acid.
6. Benzene B&J.
*
7. Methanol B&J.
8. Benz(a)anthracene CjoH^, «W 228, Eastman 4672.
9. Benzo(a)pyrene C2C)H12, MW 252, Eastman 4951.
10. Pyrene C,,H,n, MW 202, Eastman 3627.
~~— J.D 1U
11. Benzo(g. h. pperylene C22H12> KW 276, Columbia Organic.
12. Test Blend.
CAUTION
Exercise care when handling these conpounds to avoid inhaling
them or getting them on the skin. Wash hands thoroughly after handling.
Weigh exactly 25.0 mgs of each of the four compounds listed as Items 8
through 11. Place in a 25-ml volumetric flask, add 20 ml of toluene and swirl
until compounds are in solution. Then make up to volume. This will contain
1 microgram of each compound per microliter of solution. Pour into a small,
narrow neck brown bottle and keep in a cool, dark place, preferably a refrigerator.
13. Organic Counting Solution, 8 gm of BBOT in a liter of toluene.
Works.
14. "C benz(a)anthracene, 14C benzo(a) pyrene, Mallinkrodt Chemical
-------
Mtthod
Precautionary >?ote: Because of the sensitivity of the test,
the possibility of errors arising from contamination is great. It is of
the greatest importance that all glassvare be scrupulously cleaned to re-
•ove all organic natter such as oil, grease, detergent residues, etc.
Examine all glassware, including stoppers and stopcocks, under ultra-
violet light to detect any residual fluorescent contamination. As & pre-
cautionary measure it is recoirjnended practice to rinse all glassware with
purified iscoctane imediately before use. No grease is to be used on
stopcocks or joints. Great care to avoid contamination of sanples in
handling and to assure absence of any extraneous material arising iron
inadequate packa'ging or storing is essential. Because some of the poly-
nuclesr hydrocarbons sought in this test are very susceptible to photo-
oxidation, the entire procedure is to be carried out under subdued lizht.
Avoid use of fluorescenc iair.ps. Special yellow lights are available.
Tygon tubing must absolutely be avoided to eliminate di-isooctyl phthalate
(DOP) contamination which interferes in both the GC and UV.
Radioactive Materials must be handled and disposed of by accepted
methods. Glassware should be rinsed with chloroform-acetone solvent and
washed in dichromate-sulfuric acid cleaning solution.
A. Sample Preparation
1- Distillation of Tar Samples
Before commencing the distillation prepare the radioactive
BaA and BaP spikes. Add 50 A of BaA to a 25 ml. volumetric flask
and 50 Xof BaP to a second. Make up to volume with cyclohexane and recove
duplicate lOOXaliquots from each for counting. Pour the contents of t^e
flasks into the still and rinse out well .with cyclohexane and acetone.
Conduct the distillation as described elsewhere (1A)•
2. Gasoline
The volume of starting sample is varied according to the level of
PNA's. PNA-rich gasolines can be analyzed by using 50 ml and spiking with
50 \.each of ^C labeled BaA and BaP. For gasolines of low PNA content,
1000 ml of sample is spiked with 10 A. each of the BaA and BaP internal
standards.
3. Used Crankcase Oil
A weighed amount of sample ('*' 500 mg) is made up to 25 ml of cyclo-
hexane which has been previously spiked with 10 X each of carbon-14 labeled
BaA and BaP.
(1A) G. P. Gross, "Gasoline Composition and Vehicle Exhaust Gas Polynuclear
Aromatic Content," U.S. Clearinghouse Federal Science Technolosy
Information, PB Rep. Issue No. 200266 (1971) 124 pp.
-------
B. Caustic Extraction (Tar Samples)
I. The volume of still bottoms vtll be about "one liter. Take exactly
one-half of this and place in a one-liter separator? funnel.
2. Add-SO ml of 0.5 N aqueous sodium hydroxide solution, shake one
minute, and remove lower aqueous phase..
3. Repeat, the extractions with 30 and 20 ml portions of sodium hydroxide.
4. Wash with 50 ml of water, then 50 ml of 1/10 N HCl.
5. Finally, wash with 25 ml of water.
6. Evaporate cyclohexane to about 150 ml and filter, if necessary.
7. Evaporate filtrate to below 50 ml, place in a 50 ml volumetric flask
•nd make up to volume with cyclohexane.
8. Take 25 ml for placing on the alumina chromatographic column.
C. Column Chromatographic Separation
1. Seventy-five grams of Woelm Neutral alumina is dried for one hour
at 150*C. The alumina is transferred to a bottle and allowed to reach room
temperature. 1.5 ml of water are added dropwise with shaking. The bottle is
capped and placed on a paint shaker for 15 minutes to obtain a uniform mixture.
2. A glass wool plug is placed in the end of the chromatographic
column and the alumina is poured in along with gentle tapping to pack the alumina.
The column is filled to within one inch of the top and another glass wool plug
is placed on top. K
3. Ten ml of cyclohexane are placed on top of the column and allowed
to run into the column under nitrogen pressure of 2 pounds. The sample is then
poured into the 200 ml bulb on top and allowed to run into the column. 90 ml
cyclohexane is added to the bulb.
4. When the cyclohexane has run into the column below the top glass
wool plug, 100 ml of cyclohexane benzene (4:1) are added and run into the column.
The first 100 ml of cyclohexane is collected and set aside. The following solutions
are collected in 3-dram vials and capped. Each should contain 10 ml of solution.
5. After the cyclohexane/benzene (4:1) is below the top of the glass
wool plug, 100 ml of benzene are added to the column. Collection of 10 ml fractions
is continued.
-------
6. After all the benzene has passed the top glass wool plug, 100 ml
if benzi-ne/methanol (1:1) Is added to the column. The benzene/methanol front
•n usually be followed by the movement of an orange colored band. The front
an also be detected by a warm front moving down the column which is apparent
o the touch or it can be followed by a UV lamp. When the front reaches the
nd of the column, a two-phase system becomes visible in the collecting vial.
t this point, the remaining solution is collected in one large bottle and
Ilowed to run off the column (cut 3). The column should not be stopped or
llowed to run dry between solvent additions.
7. The solutions in the individual three-dram vials are scanned in
rder of elution on a UV spectrophotometer. The peak at 340 nm is used as a
uide in determining the start of elution of tetracyclic PNA compounds. The
olution whose spectrum shows a 340 peak is the start and all remaining solutions
re combined as the PSA fraction (cut #2).
i. Preparation of Concentrated PNA Solution
1. Transfer the contents of the first 4 vials of cut #2 to a
.50 ml beaker and rinse each vial twice with 1 to 2 ml of cyclohexane and
combine with the contents of the beaker.
2. Place the 150 ml beaker on the steam bath under a small jet
BŁ nitrogen.
3. As evaporation progresses, add the contents of the remaining
irlals with similar rinsing to the beaker. Do not evaporate to less than
wo mis and in no case let the contents go to dryness.
4. Transfer the concentrated solution to a one-dram vial.
fash beaker with cyclohexane and add to vial.
5. Place the vial in a 30 ml beaker for support. The beaker is
>laced on a sceam bath under a gentle jet of nitrogen.
6. Rinse the 150 ml beaker with 3 or 4 small portions of cyclo-
texane (~1 ml) and combine with the contents of the one-dram vial as
ivaporation proceeds.
7. If, as is preferable, it is unnecessary to obtain the weight
if the PNA residue, evaporate the solution down to about 50 .ul (0.05 ml).
idd about 0.5 ml of acetone and again evaporate to 50>il.
8. If the weight of the residue must be obtained, exercise
rent care as the solution approaches dryness. Keep the vial under conitint
bservation and the instant all the solvent has been removed, cool and weigh
he vial.
9. Return the vial to the beaker under nitrogen for an additional
inute, cool and reueLgh. Repeat t*us procedure until a conitant volght It
cached. For the GC analysis add 10 to 20 mlcrollters of no-tone to lower
he viscosity of the sample. Cap and save.
U23
-------
X. Ca» Chronatographic Analysis
Parameters
The following parameters are employed in developing the gas
chromatographic separation with the Perkin-Elmer 900. Other instruments
night use different conditions.
Carrier Gas - Helium
Flow Rate - 30 ml./min.
Hydrogen and Air - at manufacturers
recommendation, or optimum rates.
Injection Port - 300*C.
Detector - 340°C.
Program - 175"C to 300*C at 4* per
minute. The temperature is held at
300* until all peaks are eluted, but
in any case, for 20 minutes.
Column Conditioning
1. The Supelco Co. states that only minimum conditioning is
needed on the column specified in (4) of apparatus. Connect the column
to the inlet of the GC but not with the detector.
2. Pass helium through at 30 ml. per minute program at one
degree ptr minute from 150*C to 275*C. Keep at 275 for 30 minutes. Cool
and connect to the detector.
i 3. If SE 30 as supplied by the manufacturer is used in place of GC
grade, connect as in (1). Purge with helium for 10 minutes and then put a cap
on the exit end, keeping a helium pressure on the column.
4. Raise the oven l:o 350*C and bake for 3 hours.
5. Cool to room temperature, remove cap, pass helium through
at 30 ml. per minute and continue conditioning column as shown below
without attaching to the detector.
Teop., *C. 150 200 250 275
Time, Kin. 30 30 30 60
6. Cool to room temperature and attach to detector. The column
It now ready for use.
-------
Performance Test
This test is used Co measure retention times and demonstrate
•ultable recovery of individual PNA's. Recoveries of > 837. are required
except for benzo(g,h,i)perylene. For this compound, a recovery of > 757.
Is satisfactory. With the column conditioned and the parameters set as
described in 1, prepare to inject a sample.
7. Flush the 10 fil syringe twice with the test blend.
8. The third time fill the syringe and hold vertically point
up. Stick the tip in a rubber septum and depress the plunger to compress
air bubbles which rise to the top.
'• Now advance the plunder to the desired amount, for instance
2/il; the rubber is removed, snd the plunger retracted until the air-liquid
•enlscus enters the glass bore.
10. Note the volume from meniscus to plunger.
11. Insert the syringe up to the hilt In the CC injection port,
depress the plunger. Start the recorder.
12. Remove the syringe from the port and retract the plunger.
13. Not* the volume remaining (generally about 0.2 jil) and sub-
tract from the previously noted voluae to detercine the net volume
injected.
14. Have stainless steel trapping tubes and or.e-dran vials
available. The vials should be supported in small holes drilled in a
board. A plastic cup filled with ice surrounds the stainless steel insert.
IS. As a peak approaches, insert a tube. Remove as the trace
returns to the baseline. Mark the peak No. 1 and place the tube in a one-
dram vial labeled 1.
16. Continue taking cuts, putting each tube in a separate vial
libeled 2, 3, etc.
17. Typical retention times obtained in setting up this method
are shown in Table IA.
IsSl
-------
Table IA
OBSERVED RETENTION TIMES *'
Compound Retention Time, Min.
Pyrene 13.6
Triphenylene 19.4
Benz(a)anthracene _ 19.4
Chrysene 19.6
Methylbenz(a)anthracenes 21.4
Dimethyl/ethylbenz(a)anthracenes j3 3
Benzp(e)pyrene 25J7
. Benzo(a)pyrene 2j]g
Methylbenzo(e)pyrenes|' ) 27.5, 28.0, <:9.u
Methylbenzo(a)pyrenes j
Benzo(g,h,i)perylene 31^
a » Conditions given on page 40.
b « Measured in three different peaks.
18. When the run is completed take the first tube and place in
a S-B! graduate. With an elongated medicine dropper add enough cyclohexanea
through the top of che tube to fill the spectrophotonetric cell to be
used. In developing this method, 3.8 ml was a convenient volume to en-
ploy, but all cuts must be made up to the same volume.
19. Pour the solution into the original vial, cap and protect
from light. Rinse out the graduate with cyclohexane and use for the next
tube. Save the fractions for UV, and calculation of recoveries.
20- When the run is cocp_leted, neasure and record the retention
time in minutes from infection poinr for each conpound including the in-
ternal standard.
Analysis of Samples
21. From the vial containing Che PNA concentrate, take 5-10 (*i of
sample and inject into the GC unit. Trap the peaks at the retention times
obtained on the test blend and also trap any other peak that might be of interest.
Trapped fractions must be made up to the same volume employed for the test blend.
a - At the time of this report, some preliminary dats indicated that benzo(g,h,i)•
perylene might not be completely dissolved by cyclohexane, resulting in low
recovery. A preferred step wovild be to use acetone. In this case, the UV
measurement might be done with the cyclohexane/acetone mixed solvent or it
might be necessary to replace the acetone with cyclohexane by careful
evaporation.
1^32
-------
F. Ultraviolet Spectrophotometric Analysis and Scintillation Counting
1. Prepare solutions of known concentrations of each PNA in
cyclohexane, e.g., 2.4 /ig/ml.
2. With cyclohexane In the reference cell, obtain the spectrum
of each solution from 400 to 225 nm.
3. From the spectra obtain the absorbances of the various compounds
at the wavelength shown in Table IV (p. 12). Calculate absorptivity from
Che known concentrations. Typical calibration data are also shown in the
cable.
4. Rinse the cell thoroughly with cyclohexane between spectra
and remove the* last traces of solvent by vacuum or a gentle jet of air.
5. Obtain the UV spectrum of each selected fraction as directed
la step E-21. Measure the absorbance at the specified wavelength and
reference point as determined by the base line having anchor points as
listed in Table IV.
6. One ml of each fraction containing BaA and BaP is placed in
• counting vial, along with 9 ml of toluene and 10 ml of counting solution.
Counts per minute are measured using a scintillation counter.
-------
6. Calculation to a Sample Basis
1. To calculate the micrograms of the individual PNA's in the sample,
Che aliquot factor (activity ratio) must be determined based on radioactivity
per ml of the cyclohexane solutions of GC fractions containing WC BaA and BaP,
respectively.
Equation 1.
M " activity ratio
Q • activity in DPM added to sample
K • average CPM in a measured volume (ml) of the solution
containing the CC fraction
L " background in CPM
N • counting efficiency CPM per DPM
CPM is counts per minute
DPM is disintegrations per minute.
The concentration of each component Is determined from the UV absorbance.
Equation 2. D » *
BC
D « concentration of each PNA (fig/ml)
A • absorbance of each PNA
B « absorptivity of each PNA (ml/^g cm)
C « cell length (cm)
The weight of added radio tracer is determined.
Equation 3. X » -*-
X » weight of radio tracer added, e.g., 1 ug of l*C BaP.
S • specific activity (DPM/p.g)
Q • activity in DPM added to sample.
Calculate weight of PNA in the sample.
Equation 4. T - MVD - X
T • weight of PNA in the sample. "
V « volume in ml of the solution containing the CC
fraction taken for counting.
The subtraction of X (Equation 4) is d<->ne only for BaA and BaP. The weight of benzo
(8»h,l) perylene is corrected upward, by 1.10 (p. 8).
Where more than one internal standard is used, all components eluting
in the same peak with a standard are calculated based on chat standard's activity
ratio. All other components are calculated using the smallest activity ratio
since this represents the maximum recovery of standard.
-------
AManficRichi'ieldComiuny Hjt«ey Technical Center
Analytical Department
APPENDIX B ARCO Aiulytiui Metl
s
POLYCYCLIC AROMATIC ANALYSIS IN SOLID WASTE
In analyzing polycyclic aromatics (PCA) in solid
waste, the sample is separated into water, solids,
and cyclohexane soluble fractions. The separation
of the PCA's in the eyclohexane fraction is based
uppn work by Norris S Hill(i) and White & Howard(2).
The general scheme is outlined in Figure I.
The first alumina column is used to "clean up" the
sample which is necessary for high boiling petroleum
stocks, cokes, and complex samples such as obtained
from the API Separators. The second column (2.53!
HgO) is used to provide concentrates of polycyclic
aromatics (PCA's) of interest. Cut 3 should contain
the 4 and 5 ring compounds and cut 4 should contain
the larger PCA's. Experimental work to date
Indicates that cut 3 contains sone of the larger
PCA's. Cuts 3 and 4 are concentrated and apolied
to 20% acetylated cellulose TLC plates, developed,
and regions of interest removed. The regions of
interest are extracted with hot nethanol , concen-
trated, and analyzed by HPLC using a reverse phase
system, consisting of a Vydac TP column and methanol-
HjO as the solvent.
Each of the above procedures are described in detail
in the attachment, "Analytical Procedures".
To date, the separator bottoms from an API separator
sample has been analyzed using this procedure. The
analysis of the HPLC chronatograms are not complete,
but concentrations for 1 ,2-benzanthracene , 3,4-
benzpyrene and chrysene have been obtained and are
1 isled below i n ppm:
1,2 - Benzanthracene 254 nm 288 nn
on cyclohexane extractable basis 111 29
on total sample basis 31 7
3,4 - Benzpyrene 254 nn 296 nn
on cyclohexane extractable basis 46 47
on total sample basis 13 13
254 nm
on cyclohexane extractable basis 78
on total sample oasis 22
-------
Two U.V. detectors were used 1n series, the Perkin-
Elmer which is fixed at 254 nm and the Schoeffel,
which is a variable wavelength detector. There is
no agreement for 1,2-benzanthracene for-the two
wavelengths, suggesting that interferences are
present at 254 nm. The agreement for 3,4-benzpyrene
suggests .that either it is fairly pure or that any
Interferences have the same absorptivity at both
wavelengths.
M.S., G.C., and G.C.-M.S. procedures are being
developed.to aid in the analysis. We can analyze
the TLC portions by M.S. using a probe, but some of
the TLC portions are very complex, and G.C.-M.S.
would be useful. In the future, we plan to take
fractions from the hPLC separation and subject these
to additional analysis. At the present, sample size
appears to be a limiting factor, and additional work
will have to be done to'determine the lower limit of
detection.
1. "Polynuclear Aromatic Hydrocarbons in Petroleum
Products", M. S. Morris & E. D. Hill, of Gulf,
presented at API 60, June 1974, not published.
2. R. H. White & J. N. Howard, Chromatog., 29
(1967) 108-114.
-------
FIGURE I
Cyclohexane Soluble Fraction
Alumina Column
10-11X H20
I
Alumina, 2.5% t^O Column
4, -b 4* -if
Cut 1 Cut 2 . Cut 3 Cut 4
Cyclohexane 80/20 Cylclohexane 50/50 Cyclohexane Benzene
Benz"ene Benzene i
Same as Cut 3
20% Acetylated Cellulose TLC
J'
HPLC
(reverse phase)
-------
ANALYTICAL PROCEDURES
I. Sample size
API Separator, cyclohexane extractables = 1 gm
II. Alumina Separations
1. 10-11X H20
30 gm of deactivated alumina are prewet with
cyclohexane, the sanple applied as a solution; and
200 ml of cyclohexane used to eluate the sample, and
concentrated to = 20 ml.
2. 2.5* H20
30 gm of the deactivated alumina are prewet
with cyclohexane, the sample applied, and eluated
with the following solvents: cut 1 - 200 ml cyclo-
hexane, cut 2 - 150 ml 80/20 cycl ohexane/benzene,,
cut 3 - 400 ml 50/50 cyclohexane/benzene, and cut 4 -
400 ml benzene. Cuts 3 and 4 are concentrated to
« 0.4 ml.
III. 20X Acetylated Cellulose TLC
20 x 20 cm, 1 mm thick plates of 2Q% acetylated
cellulose plates are prepared. The samples are
Streaked at = 1.5 cm from the bottom, with a standard
applied at one side of the plate. The plates are
developed in a chamber containing 68% ethanol, 16%
H20, and 16" toluene until the solvent front reaches
up to = 1-2 cm from the top of the plate. The regions
Of interest are removed by vacuum and extracted with
3-10 ml portions of hot methanol . The methanol
extracts are concentrated to a known volume (1 to 5 ml).
IV. HPLC
A 25 cm Vydac TP' ' reverse phase column is used
with 80/20 methano!/H20 at 30°C and 1 ml/min. iP = 1200
pslg. A 5 pi loop is used to inject the sample and
Identification is based upon retention tine. A
calibration is made at least once a day, to correct
for changes in temperature. A Perkin-Elner detector
9 254 nm and a Schoeffel variable wavelength detector
are used for quantitation. A typical calibration is
attached. Figure II.
-------
00 «-< i—i r-. ro
OJ +J
o c
o>
c ">>
O> *-
O >,>>*
•— C O- O--C
>j fO *—^*^-» "
C •f~* QJ , S_ O) OJ OJ O>
»—iC\JOr)^±LD^or-«.COCT>i—t t—«
-------
APPENDIX .C
CHEVRON Ri.SIJARCH COMPANY
RICHMOND, CALIFORNIA
DETERMINATION OF Cr+6 IN THi^ APRIL 1, 1974
PRESENCE OF LARGE AMOUNTS OF Cr+3
Author - J. 0. Larson
Due to recent EPA water quality requirements, the Process Desigr
Division needed a reliable method for separating and determinini
1-10 ppb of Cr+s (chromate) in the presence of a hundredfold
excess of Cr+3 (chromic) in refinery effluent v;aters. This
report describes a method based on an ammonium pyrolidine dithic
carbamate (APDC) chelation of Cr+6 (leaving Cr+3 unreacted).
extraction of the chelate with methyl isobutyl ketone (MIBK),
followed by direct carbon rod atomic absorption analysis of the
extract. The method is rapid (8-10 samples per day), has good
sensitivity and accuracy (l ppb + 0.5 ppb), and shows remarkable
selectivity (l part Cr+6 in 2000 parts Cr+s).
Sampling
Samples should be taken in l-qus,rt Teflon bottles, frozen, packe
in Dry Ice, and shipped to Chevron Research as soon as possible
This is to prevent conversion of Cr+e to Cr+3. For the same ret
son, these samples must Mot be acidified as in the case of samp-
ling for other metals analyses. Presence of dissolved and
suspended organic matter will accelerate this reduction in an
acid medium.
Analytical Procedure
1. Bring the samples to room temperature and filter through a
0.45-micron Millipore filter if they appear turbid or if sus-
pended solids are present.
2. Pour 200 ml of sample into a graduated 400-ml beaker. Add
10 ml of \% APDC solution and mix.
~5. Add the contents of one "pH-5 Hydricn Buffer" capsule
(potassium phthalate and tartaric acid) and allow the powder to
dissolve completely. Using a magnetic stirrer will speed the
process.
4. Usinn the pH meter, adjust the pH to 2.5 by dropwise addi-
tion of 1:1 HN03.
5. Transfer the sample to a 250-ml volumetric flask, add 20 ml
of MIBK, and shake well I'or three minutes. Set the flask aside
for 10 minutes to allow the aqueous and organic phases to
separate. Go onto the next sample.
End. - Table
-------
6. Add sufficient demineralized water to the volumetric flask
to force the MIBK (upper layer) to the top of the neck. The
sample is now ready for atomic absorption measurement. If con-
venient, the sample solution is stable enough to stand overnight.
7. Prepare a reagent blank from 200 ml of 0.5 M Nad solution
and carry through Steps 1-5.
8. Likewise, prepare a 50-ppb Cr+e check standard by addition
of 1 ml of the Cr+s standard solution to 200 ml of 0.5 M Nad.
9. To determine the extent of recovery of Cr+s, a(jd 1 ml of
the Cr+6 standard solution to 200 ml, of one of the samples and
repeat Steps 1-6.
10. The atomic absorption measurement is done by direct addi-
tion of 5 I-1! of the MIBK solution to the Varian-Techtron carbon
rod atomizer. Typical instrumental parameters are as follovjs :
Dry: 6/30 Inject sample 10 seconds after start.
Ash: 7/30
Atomize: 8/3 Cool 2 minutes and inject next sample.
Uo Scale Expansion
Span: 10 M
Slit: 100 V
Chemicals and Equipment
1. pH meter and pH-4 Buffer solution (WR 34179-200) for
standardization of pH meter.
2. Magnetic stirrer, Teflon-coated magnetic stirring bars, and
stirring bar retriever.
3. 0.45-U Millipore filter and filter assembly.
4. pH-3 Hydrion Buffer powder (WR 3'H75-06o).
5. HOO-ml beakers and 250-ml volumetric flasks.
6. Cr+6 standard solution. Pipette 1 ml of Harleco 1000-ppm
Cr+s standard solution into a 100-ml volumetric flask, add 1 ml
of 1:1 HN03, and dilute to mark with detnineralized water.
7. 1:1 HNOq,. Mix 50 ml of Baker Ultrex nitric acid and 50 ml
of demineralized water.
8. 1$ aqueous APDC. Dissolve 2 g of 1-pyrrolidine carbodi-
thionic acid, ammonium salt (Baker U 712) in 200 ml of
1M.1
-------
demineralized water. Filter through No. 541 Whatman paper.
Prepare fresh daily.
9. MIBK (Baker's Q879) 4-Methyl-2-Pentanone
10. 1 ml MLA Precision pipette and a 5 ill Eppendorf pipette.
-------
TYPICAL RESULTS
1.
2.
3.
4.
5.
6.
7.
8.
9.
0.
Sample
0.5 M NaCl + 1000 ppb Cr+3
0.5 M NaCl + 2000 ppb Cr+3
0.5 M NaCl + 250 ppb Cr+3
250 ppb Cr+6
Outfall Canal
Final Effluent
No. 5+50 ppb Cr+6
No. 4 Pond Effluent
No. 7+50 ppb Cr+6
No. 4 Pond Effluent (HgS)
No. 9 + 50 ppb Cr+6
Found, ppb
Total Recovery of
Cr Cr+6 Cr+6, %
<1
<1
247 99
110 <1
2
52.6 101
1300 1.9
50.4 97
36 <1
30 60
CHEVRON RESEARCH COMPANY
RICHMOND, CALIFORNIA JOL
3-27-74
-------
APPENDIX D
WET ASHING PROCEDURE1
FOR As, Hg, AND Se
1. Preferably, new glassware should be cleaned with hot nitric
acid followed by 1:1 nitric acid and deionized water rinses.
The digestion apparatus should consist of a 500-ml two-neck
flask, a distillation receiver equipped with two-way glass stop-
cock, an addition funnel, and a Friedrlchs condenser. All
Joints should be lubricated with concentrated sulfuric acid.
2. Add 25 ml of sulfuric and 50 ml of nitric acid to the
weighed sample in the digestion flask. Reflux the mixture
until no more nitrous fumes are evolved. (More nitric acid
should be added as required to maintain oxidizing conditions
until all organic material is gone.)
3. The mixture is evaporated to sulfuric acid fumes and allowed
to fume for five minutes, the distillate being collected in
the receiver.
4. The mixture is allowed to cool. When cool, 25 ml of nitric
acid is added dropwise; and the digestate is again taken to
fuming sulfuric and fumed five minutes.
5. After cooling, the distillate is returned to the flask; and
the mixture is refluxed for 15 minutes. The flask contents are
again distilled, the distillate being collected in the receiver.
Once cooled, the distillate is returned to the flask, the mix-
ture is briefly refluxed, allowed to cool. The condenser and
receiver are rinsed with deionized water.
6. The digested mixture Is filtered through glass paper. The
flask is rinsed with deionized water. This preparation is
especially designed to recover arsenic, mercury, and selenium.
7. This mixture can be used for all the metal analyses except
lead. Note the high acidity. Standards will have to be pre-
pared in a similar acidic medium.
8. Water-insoluble metallic sulfates are left in the flask
and glass paper. If these insoluble sulfates are dissolved in
ammonium acetate solution., they may be made up to volume and
used for lead analysis.
:clr
1ARCO - unpublished method.
-------
Pub. 2015 A
First Edition
May 1975
A Guide for Controlling the Lead Hazard
Associated with
Tank Entry and Cleaning
A Supplement to API RP 2015
Cleaning Petroleum Storage Tanks
American Petroleum Institute
180 IK Street N.W.
Washington, B.C. 20006
3M5
Price: $1.00
-------
CONTENTS
0. Introduction
1. Scope and application
2. Organization for lead hazard tank entry and cleaning
2.1 General
2.2 Organization
3. Check list for lead hazard tank entry and cleaning
3.1 General
3.2 Check list of key points
4. Guide for use of lead-in-air analyzer
4.1 General
4.2 Precautions
4.3 Lead-in-air analyzer
4.4 Sampling location
4.5 Interpretation of results
5. Disposal of sludge
5.1 General
5.2 Methods
5.3 Weathering procedure
The data and methods described in this publication may be used by anyone desiring to do so, but the American Petroleum In*
shall not be held responsible or liable in any way either for loss or damage resulting therefrom or for the violation of any F«
state or municipal regulation with which they may conflict.
IMS
-------
A GUIDE FOR CONTROLLING THE LEAD HAZARD ASSOCIATED WITH TANK ENTRY AND CLEANING
INTRODUCTION
s purpose of this guide is to provide information on
potential hazards and the steps to follow to prevent
lecessary exposure of personnel when entering and
aning tanks which have been used for leaded petro-
m products.
SCOPE AND APPLICATION
tanks which have been used for leaded petroleum
iducts will contain residual lead of varying concen-
lions. They must be regarded as dangerous to the
ent that respiratory and skin protection must be used
il the tank is determined to be thoroughly cleaned
safe for entry without personal protective equip-
nt.
s guide outlines safety precautions and procedures
controlling the lead hazard associated with entry
I cleaning activities in storage tanks which have con-
led leaded products. It does not cover specific fire
mention measures or control of other hazards not
ated to the lead hazard problem.
s intended to be used with API RP 2015 Recom-
nded Practice for Cleaning Petroleum Storage Tanks
ich contains additional information related to asso-
ted hazards. It should be regarded as a manual and
: as an industrial standard.
is guide only relates to the following:
a) The company system for lead hazard tank entry
and cleaning.
)) The check list to be followed for tank entry and
cleaning as related to the lead hazard.
c) The use of the lead-in-air analyzer.
d) How to dispose of sludge from leaded gasoline
storage tanks.
ORGANIZATION FOR LEAD HAZARD
TANK ENTRY AND CLEANING
General
ich company should organize and maintain a system
responsibility for lead hazard tank entry and clean-
policies. Procedures should be established to pro-
le controls within the company on tank entry and
waning activities for the purpose of:
a) Ensuring that only competent personnel are em-
ployed.
b) Making certain personnel are familiar with the
hazards, precautions and procedures.
2.2 Organization
Each company should have a firm, written, well-defined
tank entry and cleaning policy.
Persons who have the direct responsibility to authorize
the entry or cleaning of a leaded tank should know the
proper tank cleaning procedures. No tank should be
entered without their approval and a work entry permit.
3. CHECK LIST FOR LEAD HAZARD TANK
ENTRY AND CLEANING
3.1 General
A check list which outlines safety precautions and pro-
cedures for controlling the lead hazards associated with
tank entry and cleaning should be prepared. The items
to be considered before, during and after a tank is
cleaned should be reviewed and used as a guide by the
personnel responsible for supervising safe tank entry
and cleaning as well as by those who do the actual
cleaning.
3.2 Check list of key points
3.2.1 Review: •
a) Company policy regarding tank entry and clean-
ing.
b) Contract (if used) for cleaning work.
c) API RP 2015 Recommended Practice for Clean-
ing Petroleum Storage Tanks.
d) API PSD 2202 Dismantling and Disposing of
Steel from Tanks Which Have Contained Leaded
Gasoline.
e) API PSD 2207 Preparing Tank Bottoms for Hot
Work.
f) ANSI Z88.2 Practice for Respiratory Protection.
g) ANSI Z117.1 Safety Requirements for Working
in Tanks and Other Confined Spaces.
3.2.2 Discuss safety precautions with supervisor
Be sure the supervisor understands and knows:
a) The work entry permit procedure.
b) The difference between gas free and lead hazard
free.
c) Why tank cleaners should wear proper clothing
and equipment.
d) That the ventilation of a tank must be main-
tained continually.
e) That personnel must be properly trained and re-
quired to use respiratory protection equipment.
f) The safe location of a blower type air supply:
1) Upwind.
2) Away from manhole.
• 1M.7
-------
AMERICAN PETROLEUM INSTITUTE
3) Away from sludge disposal site.
g) The need for continual surveillance of men in
the tank.
h) How to avoid undue exposure at manhole by men
outside of tank.
i) The safe handling of sludge.
j) The requirement that men must wash before eat-
ing and smoking.
k) That men must bathe and change clothing at end
of each day's work—or immediately if wet and dirty
with sludge
I) The cleanup requirements for personal protective
equipment and tools.
m) The things to avoid during progress of work.
1) Removing lace piece while in tank
2) Removing gloves
3) Twisting hose.
4) Wet sludge on clothing.
5) Blower type air supply unattended
6) Handling of sludge and equipment removed
from tank by outsiders without gloves.
7) Hose left in tank or outside and dirty over-
night.
8) Entry to tank by anyone for any purpose with-
out protective equipment before tank is thorough-
ly cleaned and is lead hazard free
9) Poor housekeeping.
3.2.3 Discuss personnel with supervisor
a) Are they sufficient in number?
b) Do they have experience?
1) Have they cleaned tanks'?
2) Have they worked while wearing masks'
c) Are they in good physical condition9
d) Are they trained to use respiratory protective
equipment?
3.2.4. Describe tank
a) Tank number.
b) Capacity
c) Size.
d) Location.
e) Type roof.
f) Coated bottom or sides.
g) Location and number of manholes.
h) Date of last cleaning
1) Tank history; types of products stored.
3.2.5 Discuss reason for cleaning
a) Repairs—note whether hot work is required.
b) Change producls.
c) Routine cleaning.
d) Inspection.
e) Dismantling—note whether hot work is required.
3.2.6 Discuss sludge disposal
a) Select the method
1) Weathering.
2) Burying.
3) Other.
b) Select a site according to company rules.
3.2.7 How to prepare the lank
a) Remove all hydrocarbon possible through exist-
ing connections.
b) Remove any sources of ignition from the area.
c) Blank off all lines to tank.
d) Lock out mixer (if there is one).
e) Remove manhole cover on side and/or roof after
it has been determined that vapors will disperse
safely.
f) Remove balance of hydrocarbon through man-
hole or water draw-off.
g) Ventilate tank.
3.2.8 A rrange for tools and equipment
a) Approved pump for removing sludge and liquid
from tank—check on fire and explosion-proof drive,
switches, etc.
b) Shovels.
c) Brooms.
d) Scrapers
e) Squeegees
f) Buckets.
g) Rags or drying compound
3.2.9 Arrange for personal protective equipment
a) Clothing (from skin out as needed for weather
condition)
1) Quantity (depends on length of job and num-
ber of men used in tank and handling sludge and
equipment outside of tank).
2) Clean clothes for each shift with spares to
change to if needed.
3) Underwear, socks, caps and coveralls.
4) Gloves (gauntlet)—impervious to gasoline.
5) Boots—impervious to gasoline.
6) Location of shower facilities—if remote, how
are personnel transported?
7) Location of cleanup facilities.
b) Air-supplied respiratory protective equipment.
1) Approved type.
2) Full face piece masks and hose, clean and in
good working condition.
3) Respiratory protection for each man in tank
4) Ample supply of breathing quality air and
sufficient hose for each man to reach farthest
point in tank.
5) An extra complete set of air-supplied equip-
ment for emergency rescue use.
6) Each hose connection properly made up (tight
-------
A GUIDE FOR CONTROLLING THE LEAD HAZARD ASSOCIATED WITH TANK ENTRY AND CLEANING
and washer in place).
7) Harness and safety line (when required) for
each man in tank.
.10 Discuss tank entry
i) Check work entry permit procedure—be sure it
s available and followed.
>) Check to be certain gas test has been made as
jer API RP 2015, Recommended Practice for Clean-
ng Petroleum Storage Tanks.
;) Check men for proper attire.
i) Check breathing air supply.
1) If blower type air supply pump is used, check
wind direction and locate up wind. Check wind
direction frequently and change pump location if
wind direction changes.
2) If air is supplied from cylinders check to make
sure it is breathing quality air (do not use oxy-
gen).
:) Put on air mask and check for seal—note beard
rowth, glasses, etc.
') Check each man for sufficient air.
) Check for odor coming through mask.
i) Check for compliance with all safety regulations.
) Assist men through manhole.
) Watch air line hose and (when used) safety line
o keep free and untwisted.
c) Assign observer and review his duties.
.11 Inspect tank
i) Wear protective attire and use air-supplied res-
)iratory equipment.
j) Make a thorough visual inspection.
:) Check these four conditions:
1) Has all sludge been removed?
2) Have all loosely adherent material been re-
moved from the portion of the tank that has been
in direct contact with the sludge?
3) Is the tank essentially dry and free of liquids?
4) Be sure the tank does not contain absorbent
material such as wood or concrete (see section
4.5.2).
.12 Analyze lead-in-air
sure a qualified individual understands:
a) The use of proper sampling procedures (see sec-
tion 4).
1) After tank inspection.
2 ) The method of sampling.
j) How to interpret results.
c) The need to clean up lead-in-air equipment and
dispose of reagent containers.
.13 Clean-up
At end of day or job:
a) Join air line hose ends to prevent interior con-
tamination.
b) Wash exterior of air line hose thoroughly with
soap and water.
c) Wash and sanitize face pieces.
d) Wash and thoroughly flush sludge pump and
hose.
e) Wash all tools.
f) Dispose of dirty water with sludge.
g) Scrape ground around manhole and dispose with
sludge.
h) Wash boots and gloves with kerosene and then
water.
i) Shower and change clothes.
j) Launder clothes used during tank cleaning sepa-
rately (not with other clothing). Clothes wet with
sludge should be rinsed in kerosene, then in soap and
water before laundering with other tank cleaning
clothes.
4. GUIDE FOR USE OF LEAD-IN-AIR
ANALYZER
4.1 General
Before making a lead-in-air test, the tank must be
cleaned, dried and ventilated in accordance with appli-
cable provisions of API RP 2015 Recommended Prac-
tice for Cleaning Petroleum Storage Tanks. The use of
the analyzer is a supplement to the visual inspection of
the cleaned tank. It should be used only after all the
necessary steps have been completed to clean the tank.
At this point the analyzer is used to measure the lead-
in-air concentration in the tank to determine if people
can enter without respiratory protective equipment.
The person making the lead-in-air test must wear rec-
ommended attire and air-supplied respiratory equip-
ment with a full face piece mask as prescribed in API
RP2015.
4.2 Precautions
Do not use a lead-in-air analyzer to determine if a tank
has been in leaded service. A tank which has had a his-
tory of leaded service or has an unknown history since
previously being declared lead hazard free will always
be considered a lead hazard tank until:
a) The tank has been cleaned and all sludge re-
moved.
b) Loosely adherent materials have been removed
from the portion of the tank which has been in direct
contact with sludge.
c) The tank is essentially dry and free of liquids or
puddles.
IM3
-------
AMERICAN PETROLEUM INSTITUTE
d) A satisfactory lead-in-air analysis has been ob-
tained after the above three steps have been com-
pleted, showing the lead-in-air concentration to be
within the prescribed limits shown in section 4.5.
Samples for lead-in-air analysis should not be taken
while forced ventilation is being used, since an analysis
at such time will be diluted and not reflect the most
severe conditions that would be encountered during
work.
Do not enter a tank for the purpose of taking a lead-in-
air sample until the tank is gas-free.
4.3 Lead-in-air analyzer
The analyzer which is used to measure the concentra-
tion of lead-in-air should be capable of determining the
organic lead content of the tank atmosphere.
The operating instructions to be followed when using a
lead-in-air analyzer should be those recommended by
the equipment manufacturer with special emphasis be-
ing given to its proper operation each time before use.
4.4 Sampling location
In order to obtain representative samples of the atmos-
phere within the tank, samples should be collected
while operating the analyzer and walking near the in-
side periphery of the tank and diagonally across the
tank.
Always collect at least two samples which should be in
close agreement before interpreting results. If the two
sample results do not agree, collect a third referee sam-
ple.
4.5 Interpretation of results
The current standard under the Occupational Safety
and Health Act of 1970 (Subpart G, 1910.93; Table
G-l) or as amended, limits personnel exposure to or-
gano lead compounds to 0.075 mg/m3 (2 ug/ft1) time
weighted average on any 8 hour shift in a 40 hour week.
The following table can be used to determine permis-
sible exposure times for men working in tanks without
respiratory equipment provided conditions outlined
above have been satisfied and the tank has been thor-
oughly ventilated.
Permissible Exposure Times Based on Values Given in
Table G-l, 1910.93, Occupational Safety and Health
Standards, 1974—0.075 mg/m3
Analyzer Results (ug/ft3)
2
3
4
8
Time Allowed in Tank
per Day
8hr.
6hr.
4hr.
2hr.
The above criteria applies to the lead hazard only a
is without regard to other hazards which may be pr
ent It must be emphasized that the tank is lead haz:
free only for the conditions described above and d<
not apply when:
a) Surfaces of the tank which have been in cont
with the leaded material are to be heated above i
normal temperature as with cutting, burning, we
ing or steaming unless all iron rust, scale or ot
foreign material have been removed from the an
to be heated.
b) The tank contains absorbent materials which n
continue to release lead.
c) There is apparent evidence of a leaky bottom
this is the case, frequent lead-in-air analysis sho
be made to insure safe conditions throughout the j
d) Conditions in the tank change. Should this occ
repeat lead-in-air analysis to ensure safe conditii
are present.
S. DISPOSAL OF SLUDGE
5.1 General
The residue remaining in leaded gasoline storage tar
after all recoverable gasoline has been removed, c
sists of a liquid phase and a solid phase. The Ik
phase is primarily water and a small quantity of hyc
carbons which readily float on top of the solids. '
efficient recovery of gasoline from the storage tan
necessary to minimize the amount of hydrocarbons c
tained in the liquid phase. This liquid phase can t
be disposed of as waste water in a manner consisl
with current industry practice.
The solid phase is a mixture of insoluble deposits v
ted with water and hydrocarbons containing orgi
lead. This mixture is referred to as sludge.
5.2 Methods
Two methods are commonly used for disposing
sludge from leaded gasoline storage tanks. They
'burying' and 'weathering.' Both methods are rec
nized by API RP 2015 Recommended Practice
Cleaning Petroleum Storage Tanks. Thermal meth
are effective but not commonly used because incin<
tion equipment is not always available.
a) Burying—In this method a pit is dug. The slu
is dumped into the pit and then covered with on<
two feet of fresh earth. This area should be adequi
ly marked so that no one inadvertently uncovers-
buried sludge. Experience indicates that buried
ganic lead compounds decompose slowly. If a d
or trench is dug through the sludge pit, organic 1
compounds may be uncovered.
b) Weathering—This method is safe, effective i
economical. Laboratory tests show that organic I
I<*50
-------
A GUIDE FOR CONTROLLING THE LEAD HAZARD ASSOCIATED WITH TANK ENTRY AND CLEANING
;ompounds in sludge, when exposed to the elements,
will decompose to inorganic lead compounds. Labo-
ratory and field tests indicate that when the proce-
dures, as outlined in the prescribed method are fol-
owed, there has been no air, soil or water contami-
nation problem.
The reason for this is indicated to be:
1) The total quantity of organic lead in a sludge
weathering bed is small. Concentrations rarely
exceed the normal range of 0.1 to 0.4 pounds of
organic lead per ton of sludge.
2) The amount of organic lead exposed to the
atmosphere at the surface of the weathering bed
is very small. Lead-in-air tests taken directly
above or immediately downwind of the weather-
ing bed indicate that lead-in-air concentrations
are low. This indicates that the atmosphere in the
area is safe from an occupational health hazard
as soon as the sludge is spread.
;) Organic lead compounds are dissolved and held
n the liquid hydrocarbon fraction of the sludge and
md do not migrate into the soil or ground water.
Weathering procedure
cation of disposal area:
i) The site selected for sludge disposal should be in
in area where it can be fenced off from the public.
t should be located away from buildings and be far
mough from the tank being cleaned so that the pos-
iibility of gasoline vapor affecting the tank cleaning
operations is eliminated.
)) The disposal area should be located so that per-
ionnel working in, on or around the tank .will not
valk in the spread out sludge.
:) The disposal area can be a bare ground, grass or
:oncrete surface.
1) The area must be fairly smooth and well drained
;o that water will not stand on it.
i) The location should be remote from streams or
"ivers.
) The total area, whether in one or several patches,
must be sufficiently large to permit spreading the
sludge in a layer not over three inches thick. The
total area required will be determined by the amount
of sludge in the tank.
g) It should be so located that air can circulate
freely over the surface of the sludge. Exposure to the
sun is desirable but not necessary.
Remove sludge from the tank in the usual manner fol-
lowing the safety recommendations contained in API
RP 2015, Recommended Practice for Cleaning Petro-
leum Storage Tanks.
The sludge can be moved from the tank to the spread-
ing area by wheelbarrows, buckets or other small con-
tainers. Dump trucks, lugger buckets, etc., may be
used for longer distances. All containers used should
be made of metal. After use, they should be washed
thoroughly with water.
The sludge can be spread with hoes, rakes or shovels.
It should be spread as uniformly as possible to a maxi-
mum thickness of three inches. If the area permits it, a
thinner spreading is desirable. After use, hoes, rakes or
shovels should be washed thoroughly with water.
Personnel handling and spreading the sludge should be
dressed in protective clothing as recommended for tank
cleaning. Respiratory equipment will not be necessary
unless there is very little air movement (0 to 5 mph).
If respiratory equipment is necessary, it can be full-face
canister type (approved for organic vapors).
After the spreading is completed, the sludge patch or
patches should be roped off and marked so that no one
will walk through or stand in the sludge.
While sludge will normally weather within four weeks
when the sludge temperature is above 0°C (32°F),
lead-in-sludge tests should be made before declaring it
free of the lead hazard. If after the four week weather-
ing period the organic lead content is 20 parts per mil-
lion or less (0.002 weight percent) as determined by
lead-in-soil analysis, the sludge from an organic lead
standpoint may then be treated as any other nontoxic
industrial waste material Signs and fences may then be
removed.
I if 51
-------
AMERICAN PETROLEUM INSTITUTE
Order No. 800—2015A
3M—May 1975
-------
THE CHAIRMAN: Thank you. We have a question.
Mr. Lindsey?
MR. LINDSEY: Yes, sir. We are quite interested in
the weathering process that you discussed and that we have heard
about from other people from the Petroleum Institute in other
cities.
If possible, could you make data available to us on
the study which you undertook on which you base your statement
here for the record?
MR. KNOWLTON: If you put a question in writing, we
will be glad to give you a written answer on the,question.
MR. LINDSEY: Okay. I will do that right after the
session.
One other question. You indicated in one statement
here, I think on Page 7, "We feel that the generator, the treate
and the disposer should each be responsible for all facets of
employee training to insure compliance ..." and so forth.
Do you see a permitting system for either generators,
treaters and/or disposers in order to accomplish this or to be
sure that this is being done? How do you see that?
MR. KNOWLTON: To be very honest with you, I do not
think we addressed that question in our discussion.
If you look back further, I think the definition of
the responsibility of the various people are covered under
Discussion Topic 2, I believe.
THE CHAIRMAN: All right. I had a question.
MR. KNOWLTOM: Sure.
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
SAN FRANCISCO, CALIFORNIA 941Q2
TEL (415) 673 7747
-------
THE CHAIRMAN: On your testimony on Page 4 you say,
"The disposer should be responsibile for maintaining records
of wastes received and disposal techniques employed, for obtain-
ing an operator's license, and for complying with applicable
emission regulations."
What if the generator is also the disposer?
MR. KNOWLTON: In many cases in the petroleum business
we would expect that to be true, and we would expect to maintain
the applicable records.
THE CHAIRMAN: Well, I am also referring to obtaining
an operator's license and so forth, and complying with that.
In other words, in your view would the same rules and regulations
and requirements for licenses and so forth apply to on-site
disposal as well as off-site disposal at some contractor's
facility?
MR. KNOWLTOH: I am a member of a committee. I would
think in all fairness the answer would be "yes." The answer
would be "yes."
THE CHAIRMAN: All right.
Mr. Kovalick.
MR. KOVALICK: With regard to your statement where
you describe the sets of requirements that a responsible
generator — starting on Page 3 and 4 — the responsible
generator, the responsible treater should follow, we have had
a similar statement in at least one of the other cities, as I
SCHILLER & COMBS, INC
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recall. And I would like to ask you the same question I asked
those individuals: Given that contract document with which this
is all constituted as a legal one -- and, of course, not every-
one is as responsible as they might — what is to prevent
waste from not entering one of the links in the system?
That is, suppose that the generator did his responsible
part and the transmitter did his responsible part, but that the
waste never reaches the ultimate treater — or move back a link
and we talk about the midnight dumping or other kinds of
irresponsible disposal.
I guess what I am really interested in is your comment
on the manifest system that California uses, which I gather
from Dr. Collins' comments this morning which he feels partially
addresses that issue.
Does the API have a position on the manifest issue?
MR. KNOWLTON: As of this moment, I would have to
say no. If you would like us to give you our opinion, I would
be glad to do so.
MR. KOVALICK: Fine. I would appreciate that.
Could I ask some more questions?
MR. KNOWLTON: Sure.
MR. KOVALICK: On Page 5 you say that, "Obviously, all
wastes should be disposed of in an environmentally acceptable
manner." And then you describe the fact that some of those
environmentally acceptable processes are more expensive.
SCHILLER & COMBS, INC
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And I was wondering what your feeling was on how you
motivated individuals to adopt those more expensive methods,
given that they are desirable?
MR. KNOWLTON: I would say that if two methods are
both environmentally acceptable, we should use the less expensiv
method. Because the consumer obviously is ultimately going
to pay the costs of the disposal.
MR. KOVALICK: But what are you recommending to at
least get bhe least expensive one adopted to prevent
environmentally unacceptable methods?
MR. KNOWLTON: I think that in our industry we are
responsible people, and we will follow all the rules. That is
my answer to you. And I have seen no indication that that is
not true.
MR. KOVALICK: I was not speaking necessarily of your
industry. I mean how does one motivate people to take the
higher cost option without some kind of guidance or some kind
of a program that Dr. Collins described here today?
MR. KNOWLTON: Once again, if the higher cost option
is the only option that is environmentally acceptable, then I
would assume that your permit system — the man has no choice.
But obviously if you have an option — obviously, incineration
versus land spreading as we see it, incineration is much more
expensive in our opinion, and it also is least effective. And
we would like to use the one that does the job best at the least
SCHILLER & COMBS, INC
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cost.
MR. KOVALICK: One more clarification, Mr. Chairman.
I was reading along with you when you were reading your
statement with regard to training on Page 7, and you indicated
that there are abundant industry publications outlining
recommended safety and security procedures for the treatment,
storage and disposal — and your statement says in writing,
"hazardous materials." But you said, "wastes." You meant to
say "materials"?
MR. KNOWLTON: I meant to say "materials," right.
MR. KOVALICK: There are extensive materials available
on hazardous wastes.
MR. KNOWLTON: Right.
THE CHAIRMAN: Mr. Lazar.
MR. LAZAR: Mr. Knowlton, you mentioned that the
proper and effective government rule should be to set minimum
standards and to monitor activities as necessary to protect the
health and welfare.
In your opinion, should the monitoring activities be
done only by the government, or do you believe that industry
should do a part or all of it?
I am thinking of such things, for example, as monitori
the ground water at the on-site disposal sites, for instance.
MR. KNOWLTON: When we use the word "monitor activitie
we did not have in mind the government actually running leachat
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
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monitors in a land spreading operation. We had in mind the
same type of monitoring activity that you do in the solid waste
office where you monitor by reports coming into you. And if you
wish to sample on occasion, sure. But the actual job being
done by the waste disposer himself.
MR. LAZAR: But what about in the case of, let's say,
an on-site disposal, would you say that the generator should
assume the expenses of monitoring to prove that nothing has
been done to harm the environment?
MR. KNOWLTON: I would say that we would assume
presently today in the waste water system we assume the cost
of monitoring our waste water.
I assume in this, particular case, in solid waste treat
ment facilities, we would assume the cost of monitoring those
waste treatment facilities.
THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: We have spent much time puzzling as we
have been at these meetings over the kinds of guidance, and
that led to the kinds of discussion topics. And the sense I
got from your statement was that we should leave as many
technology options open as possible to the generator of wastes
so that they can properly choose an economically feasible one
that is also environmentally acceptable.
I was following that drift of argument, and then I
got towards the close of your statement. And if I can quote
11*58
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that — Page 8 — "Regulations should be developed designating
a reasonable timetable for the phase-out of environmentally
unacceptable waste disposal practices."
I was just curious if you could elaborate on that a
little bit.
Are you saying that certain kinds of treatment and
disposal processes ought to be identified as environmentally
unacceptable, say, perhaps for certain kinds of wastes and
therefore — you see, that is a little more specific than the
initial testimony that I thought you were giving. I am a little
confused.
MR. KNOWLTON: I would like on this particular one to
return you an answer after discussing this with the other member
of the committee.
As you might recognize, this statement is prepared by
committee, and this particular item I am not that familiar with.
MR. KOVALICK: All right. But is my question clear,
though, from that point of view, in terms of not specifically
addressing particular waste streams or specific technologies.
And this would seem to be back on that point.
MR. KNOWLTON: All right.
THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: I have a question from the audience.
Isn't it true that your recommended practice of spreading
TEL -- tetraethyllead — depends on volatilization of organic
I** 5 3
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lead followed by subsequent oxidization in the atmosphere to
*j
the inorganic form and then precipitation'
Is that true?
MR. KNOWLTON: There is one item left out. There is
the photochemical reaction process which takes place v/ithin
minutes of spreading the material on the ground which separates
the lead from the hydrocarbon.
I would be happy to give them a written statement in
detail which we will stand behind.
THE CHAIRMAN: All right. Any other questions?
Thank you very much.
MR. KNOWLTON: Thank you.
11+60
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terican Petroleum Institute
)1 L Street Northwest
ishington, D.C. 20037
M57-7000
. W. Umstead
202) 457-7084
January 30, 1976
:. John P. Lehman
ffice of Solid Waste Management Programs
.S. Environmental Protection Agency
ishington, D.C. 20460
sar Mr. Lehman,
Your letter of December 22, 1975 raised two questions regarding
le text of the American Petroleum Institute - Western Oil and
is Association statement presented before EPA at the December 11,
)75 meeting held in San Francisco on Hazardous Waste Management.
We agree that the sentence in question in our discussion of
spic 16 is inconsistent with the position advocated earlier in
le text concerning emission regulations. Enclosed is a revised
age 8 to replace pages 8 and 9 of the statement submitted in
an Francisco.
Also enclosed, in response to your question on weathering/land
nreading, is a paper entitled Assimilation of Oil By Soil Bacteria
lich includes technical information on the weathering/land
sreading process.
Sincerely,
«J:lab
nclosures
c: K. E. Blower
H. E. Knowlton
K. C. Hunt
TEXT CORRECTED
equal opportunity employer
-------
ASSIMILATION OF OIL BY SOIL BACTERIA
R. L. Raymond, J. 0. Hudson, and V. W. Jamison
Sun Ventures, Inc., Marcus Hook, PA
-------
recommendation of wide-spread use of the soil disposal process we must
determine if residues remain 1n the soil and if so, their consequences
to the environment.
Probably the most extensive study of application of oils to soil
was that reported by C. B. Kincannon (3) at the Shell Oil Company re-
finery at Deer Park, Texas. He reported rates of degradation of the
order of 70 bbls/acre/month for crude oil tank-bottoms, a fuel oil
(Bunker C), and a waxy raffinate. Bacterial assimilation was assumed
to be responsible for the oil's disappearance, but the increased num-
ber of microbial populations observed were not shown to be hydrocarbon-
utilizing bacteria. Very high initial concentrations of oil (10%) in
the test plots and lack of data on quantities of the various oils
added makes it difficult to draw any conclusions as to levels of non-bi-
odegradable residues which remained at the conclusion of this study.
In a more recent publication, Francke and Clark (2) state that
"a biological assimilatory process for the disposal of plant oil waste
products has been successfully demonstrated." The process to which
they refer involves adding used crankcase and vacuum pump oils to
fairly large experimental field plots (0.088 acres) in Oak Ridge, Tenn.
They, like the Shell study, depended upon the natural soil flora to
degrade the oil. They did not demonstrate with the microbiological
techniques employed a direct relationship between oil degradation and
hydrocarbon-utilizing bacteria. For a three-month period they calcu-
lated a degradation rate of approximately 100 bbls/acre/month with
approximately 405! of the applied carbon being degraded at the end of
that period. The length of study period reported does not permit any
evaluation of possible residue levels.
Studies in colder climates have been reported by Cook and Westlake
(1) and Parkinson (6). Parkinson, working with Artie terrestrial
ecosystems, found that spilling a crude oil (Norman Wells, N.W.T.)
stimulated the microflora but he did not distinguish between non-
hydrocarbon and hydrocarbon-utilizing microorganisms. It was conclu-
ded that addition of nitrogen and phosphate speeded up the utilization
of the alkane fraction of the crude oil which had been spilled on the
soil. The overall degradation of the crude oil cannot be deduced from
the data reported. In more extensive studies Cook and Westlake deter-
mined the influence on degradation of such factors as fertilizer and
oil-utilizing bacteria application to field plots in the Norman Wells
area of the Northwest Territories and in the Swan Hill area of north
central Alberta. Applications of the crude oils obtained from wells
in these areas were made at a rate of 170 bbls/acre (60 1 per 9 sq.m.).
1M>3
-------
ASSIMILATION OF OIL BY SOIL BACTERIA
R. L/"Raymond, J. 0. Hudson, and V. W. Jamison
Sun Ventures, Inc. P.O. Box 1135
Marcus Hook, Pa., 19061
INTRODUCTION
The removal of oil that has been accidently or purposefully
spilled into the environment is of great concern to the petroleum
industry. The present study was undertaken to develop ecological
background data which would give a better understanding as to ways
in which biodegradation might be speeded up and to determine what
might be the environmental consequences of oil disposal in soils
in the United States.
The literature on the subject of microbial assimilation of
petroleum and it's products is quite voluminous. Because it has
been reviewed so frequently in the past few years, we shall take
the liberty of citing only a few recent papers which we consider
most pertinent to oil degradation in soils.
Before doing this, however, we would like to point out several
areas of concern to experienced microbiologists in the petroleum
industry relative to microbial assimilation of hydrocarbons. It
seems to us that there is a lack of appreciation on the part of many
microbio'logists and engineers for the complexity of composition of
petroleum. The seemingly facile microbial utilization of "simple"
substrates such as alkane cuts used to produce single cell protein
or a paraffinic crude from Louisiana cannot be assumed for a Bunker
C fuel oil or a heavy asphaltic crude. Microorganisms have a high
degree of specificity for substrates. Each species is usually very
limited in the type of compounds which can be utilized for growth.
Another area of concern is the lack of understanding of the nature
of the environment in which microbial systems function. The rate at
which a single species may grow on hexadecane in an isolated environ-
ment such as a fermentor or shaken flask, may be orders of magnitude
faster than having that same microorganism mixed into the complex
environment of soil. It is imperative that the above factors be taken
into consideration. From our viewpoint, this means extensive examin-
ation of the degradative process of the many different types of petro-
leum under as well defined field conditions as possible. Before
-------
Industrial sources could Influence the mlcrobial populations at all
three locations. In the year prior to the test the Marcus Hook and
Corpus Christl locations had very heavy weed cover. The Tulsa site
had a very heavy Bermuda grass cover.
Oil Characterization, Application and Tilling. As shown in Figure 1,
six oils were selected for study. Properties of these oils are given
in Tables 1, 2 and 3. The oils were poured from five gallon cans onto
the leveled plots, lightly raked into the surface with the results
shown in Figure 2. The oils were then incorporated into the top four
to six inches of soil with a rototiller. The equipment used at Tulsa,
shown in Figure 3, was a Howard Rotovator manufactured by Rotary
Hoes, Limited. West Horn, England. It was necessary to use smaller
but similar equipment at Corpus Christi and Marcus Hook for incorpora-
tion and tilling. All plots at Tulsa and Corpus Christi were tilled
once a month for the first three months, followed by tilling at three
month intervals for the remainder of the project life. At Marcus Hook
it was not possible, due to frozen soil, to till in January and
February. Additional tilling was carried out in March, April and May
so that the amount of cultivation was equal at all three sites.
Runoff and Leachate Water Collection. Before application of oils a
hole was drilled in the center of each plot to accomodate a quart
bottle holding a funnel filled with glass wool (Figure 4). This col-
lectorwas positioned and covered with soil so that the top of the fun-
nel was approximately one foot below the soil surface. Water was re-
moved from these bottles with a syringe or hand vacuum pump.
The runoff water collectors were five-gallon plastic tubs posi-
tioned about five feet from the center of the plot, six inches be-
low grade (Figure 5).
Analytical Methods. Residual oil remaining in the soil was determined
on a composite sample taken from five locations in each plot. Immedi-
ately following sampling, samples (2-3 kilograms each) were shipped by
air from the Tulsa and Corpus Christi sites to Marcus Hook. In theory,
the shipping process should not have taken more than sixteen hours, but
in practice delays after turning the samples over to the airlines re-
sulted in most deliveries taking from 24-72 hours. Samples from the
Marcus Hook site could be processed almost immediately. Samples were
held at 4°C if delays were encountered. Once the samples arrived at
-------
This rate produced significant increases in the microflora but no ef-
fort was made to assess what fraction of the total were hydrocarbon-
utilizing types. Chromatographic separations of recovered oils in-
dicated that extensive degradation of the alkane fractions was taking
place but no data were given for quantities of residual oil remaining
with time. They concluded from the Chromatographic data that fertil-
izer speeded up degradation. They also suggested that application of
oil-utilizing bacteria to the natural flora was beneficial.
Odu (4) reported that the microbiological activity of a sandy
sedimentary well-drained soil in Nigera was enhanced by an oil spill
that resulted from a blowout of an oil well. No indication was given
as to proportion of hydrocarbon-utilizing flora present in those enum-
erated.
In the work to be described below we have attempted to define the
magnitude of the stimulation of the specific hydrocarbon-utilizing
flora in the soil following the addition of six different oils to
small field plots. The ultimate goal is to determine if residues re-
main which are harmful to the environment.
MATERIALS AND METHODS
Field sites. A location on or near refinery property was chosen in
Marcus Hook, Pa., Tulsa, Okla., and Corpus Christi, Texas. The lay-
out of the experimental plots as shown in Figure 1 was the same at
each location. Following plowing and discing, soil samples were
taken and submitted to Penn State University Soil and Forage Testing
Merkle Laboratory, and the Texas A&M University Agricultural Extension
Service for determination of soil nutrient levels. Limestone and gyp-
sum were added at Marcus Hook to correct a low pH. The fertilized
plots at Marcus Hook received a 10-5-5 (N:P:K) mixture at a rate of
3000 Ibs/acre. At Tulsa the fertilized plots received a 10-20-10 mix-
ture at a rate of 6000 Ibs/acre. The Corpus Christi plots had suffi-
cient phosphorus, potassium, and a satisfactory pH necessitating only
the addition of 6000 Ibs/acre of ammonium sulfate to the fertilized
plots.
All sites were chosen with the intent of using land that proba-
bly had in the past been under cultivation or grazing and had not been
exposed to intentional petroleum hydrocarbon contamination. It was
recognized, however, that air contamination from automobile and
"' 3A66
-------
the laboratory they were thoroughly mixed and allquots removed for
biological analyses. The remaining soil was then dried at 105°C and
sized through a ten-mesh screen. A 50 gram aliquot was extracted as
follows: the soil and 100 ml of reagent grade benzene were heated
to boiling in a 400 ml beaker containing a Teflon coated stirring
bar; the mixture was permitted to settle and the benzene decanted
off; the above procedure was repeated three times with 50 ml aliquots
of benzene; the benzene extracts were combined, reduced in volume by
evaporation, centrifuged to remove sediment and the residual benzene
removed carefully on a warm steam table.
Residual oil determinations in run-off and leachate waters were
carried out using the procedure for oil and grease given in "Standard
Methods for the Examination of Water and Sewage, 13th Edition 1971."
After extraction for residual oil the leachate waters were ex-
haustively extracted with diethyl ether to recover water soluble or-
ganic compounds.
Metal analyses were carried out using emission spectroscopic or
atomic absorption techniques on 10% nitric acid solutions. For soils,
this involved boiling ten grams of benzene extracted soil with 25 ml
of 10% nitric add for one hour with stirring. Water samples were
reduced to dryness and dissolved in 25 ml of 10% nitric add.
Silica gel fractlonatlon of oils was carried out by the follow-
ing procedure. Silica gel (Davison Co.) 100-200 mesh, was activated
prior to use at 150°C overnight. Glass columns (18 cm in length and
9 mm in diameter) were filled with 9 grams of activated gel. A 30 to
50-mg portion of the residual oil, dissolved in 5 ml. aliquots of the
solvents being used as eluants, was placed on the column prewet with
3 ml. of rv-hexane, and the column was eluted successively with 15 ml.
each of rv-hexane, carbon tetrachlorlde, benzene, and methanol. The
fractions eluted by each eluant were collected separately, and like
fractions of the same sample were combined. The fractions were re-
covered by blowing to constant weight at 40°C.
Microbiological Methods. Ten gram aliquots of soil were shaken in
90 ml distilled water blanks and appropriate dilutions made for enum-
eration of the hydrocarbon-utilizing population by the spread plate
-------
technique. Two different media were used. For bacteria, a basal
mineral salts medium described previously (6) was modified by sub-
stituting ammonium nitrate for ammonium sulfate. For enumeration
of hydrocarbon-utilizing fungi and yeast the following agar medium
was employed: K,HPOa, l.Og; NaNO,, 3.0 g; MgSO..-7H,0, 0.5 g;
KC1, 0.5 g; FeS6.-7^H20, 0.01 g; penicillian G, 0.05g; chloroam-
phenicol, 0.5 g; streptomycin, 0.025 g; agar, 20.0 g; in 1,000 ml
of distilled water. The antibiotics were added as filter-sterilized
solutions to the autoclaved, cooled agar medium. The pH was ad-
justed to 4.0 with concentrated HC1 after antibiotic addition. Hydro-
carbon substrates were placed on filter paper discs in the lid of
the petri dishes.
RESULTS
Incorporation of the oils was accomplished without difficulty
at all three locations except for residual fuel oil (#6). This oil
was very viscous and was not readily adsorbed into the soil at any
of the three sites as is shown in Figure 6. After rototilling it
was distributed in the plots as hard black lumps (1-2 inches in dia-
meter). With each succeeding tilling these lumps became smaller,
breaking up into light brown friable balls. It was still possible,
after one year, to find small discrete lumps in the plots treated
with this oil. At the application rate of 100 bbls/acre the other
oils changed the appearance of the soil only slightly. When com-
pared in the laboratory with the control soils,the soils from the
plots containing used crankcase oil from diesel trucks and the
Arabian Heavy crude oil were perceptibly darker in color. The char-
acteristic odor of all six oils could be detected in the sample bags
of soil up through the ninth month of the field trials.
The data for residual oil concentrations and the microbial re-
sponses at three month intervals after application of oils in
November and December 1973, as measured by growth on different hydro-
carbon substrates, are shown in Figures 7-12. In these figures the
results shown were derived from averages of data from all the plots
treated with similar oils, i.e., in Figure 7 the initial concentra-
tion of used crankcase oils (32 g/kg soil) at Marcus Hook resulted
from an average of the concentrations found in the soil from fertil-
ized and unfertilized plots treated with used crankcase oil from cars
and trucks (4 plots). Similarly the concentration of microorganisms
found in the soil after an interval of three months which could use
n-hexadecane as a growth substrate, result from combining the data
from the two control plots to give an average value of "900,000/g
11*68
-------
and the four crankcase oil-treated plots an average value of
10,000,000/g. Data for the oil-utilizing fungi have not been shown
due to the lack of difference between numbers in control and treated
plots. Colony forming units of fungi were generally in the range of
5,000-10,000/gsoil for each of the hydrocarbons employed as substrates.
The data in Figures 7-12 indicate that microbial degradation was
occurring but significant quantities of these oils were still present
after one year. The magnitude of this degradation is shown in Table 4.
The lack of significant differences in the degree of degradation be-
tween the cooler Marcus Hook site and the wanner Corpus Christi site
seems to indicate that termperature was not a factor. There is some
indication that the heavier tilling equipment used at Tulsa may have
contributed to somewhat better degradation at this location.
Changes in the microbial populations as the result of the oil ad-
ditions are illustrated in Figures 13 and 14. In the top photograph
of Figure 13, a soil sample has been plated on a mineral salts agar
and incubated for 30 days over home heating oil (#2). These colony
types were typical for all three sites in November and December 1973
before any oil had been applied. The middle and bottom photographs
illustrate the large increase in numbers by April 1974 of a relatively
minor population as the result of adding the home heating oil to the
plots. Typical microbial responses to the addition of Arabian Heavy
crude and residual fuel (#6) are shown in the middle and bottom photo-
graphs of Figure 14. The top and middle photographs illustrate typi-
cal paraffin-utilizing colony development as determined by a plating
technique employing ji-hexadecane as the only carbon source.
Results of analyzing the run-off and leachate waters at Marcus
Hook for oil are shown in Tables 5 and 6. Using the rototilling
method of incroporation, it does not appear that application at a
rate of 100 bbls/acre results in loss of oil through the water route.
Comparable results for run-off waterwere obtained at Tulsa. Collectior
of run-off water was not accomplished at Corpus Christi and the leach-
ate collection system was unsatisfactory at both Tulsa and Corpus
Christi.
The data in Table 7 probably indicate that acidic organic water
soluble compounds were formed as the result of oil degradation. These
compounds are now under study.
The fate of lead present in the used crankcase oils at the three
sites is shown in Tables 8, 9, and 10. The lead apparently does not
11*63
-------
move with the water systems but stays fixed in the oil or soil phase.
At the present time we have no explanation for the differences at the
three locations 1n concentration df lead In the extracted oils. We
have recently carried out a depth study in an attempt to determine
if there was any physical movement of lead and the results are shown
1n Table 11. We conclude there 1s no downward movement.
Other Biological Effects. One of the primary goals of this research
was to determine if residual oils do remain in the soil and, if so,
what effects they may have on other biological systems. We employed
two systems 1n an attempt to evaluate these effects. In one case we
measured the concentration of free-living nematodes in the soil. Gen-
erally, we found significant reductions in these populations as the
result of the oil application. Further work will be required to es-
tablish if this is a long-lasting effect.
The second method of evaluating residual effects Involved plant-
Ing vegetables in the experimental plots. Here, as above, significant
phytotoxic effects were noted when seeds of radishes, beans and tur-
nips were planted ten months after application of the oils; but long-
term residual effects cannot be predicted at this time. The details
of these last two studies will be published at a later date.
CONCLUSIONS
The results of this study establish that at three widely separ-
ated geographical locations in the United States (Marcus Hook, Pa.,
Tulsa, Okla., and Corpus Christi, Tex.) a naturally occurring mlcro-
blal hydrocarbon-utilizing flora is present at concentrations of
1 x lO'-l x 10° microorgan1sms/g of soil. The addition of six types
of oils; used crank case oil from cars, used crankcase oil from diesel
trucks, Arabian Heavy crude oil, a Gulf coast mixed crude oil, a
home heating oil (#2), and a residual fuel oil (#6), to frequently
tilled field plots at a rate of 100 bbls/acre stimulated this natural
population to a level of 1 x 10? microorganisms/g of soil throughout
the year following application. Under the conditions employed, the
rate or degree of degradation did not appear to be influenced by dif-
ferences in temperature resulting from differing geographical loca-
tion of these experimental plots. After one year the magnitude of
degradation in order of decreasing rate (% degraded) was as follows:
home heating oil (12) 87.3, used crankcase oils 67.9, crude oils
61.9, and residual fuel oil (#6) 57.8. Examination of run-off and
lH?0
-------
leachate waters failed to demonstrate any movement of oil or lead out
of the Immediate plot area. Significant increases in ethyl ether ex-
tractable matter in leachate waters indicated that incomplete degra-
dation of some individual components in the oils was taking place.
ACKNOWLEDGMENTS
We thank Mrs. Joyce Rizzo and Mr. J. 0. Johnson of Sun Oil
Company for their assistance in maintaining and sampling field
plots at Corpus Christi and Tulsa, respectively.
This study was supported by a grant from the American
Petroleum Institute.
U71
-------
LITERATURE CITED
1. Cook, F. D., and D. W. S. Westlake. Biodegradability of
Northern Crude Oils. Canada—Task Force on Northern Oil
Development Report No. 73-20. Information Canada Cat. No.
R72-8373 (1973).
2. Francke, H. C., and F. E. Clark. Disposal of Oil Wastes
by Microbial Assimilation. U.S. Atomic Energy Report
Y-1934 (1974).
3. Kincannon, C. Buford. Oily Waste Disposal by Soil Culti-
vation Process. U.S. Environmental Protection Agency Re-
port— EPA-R2-72-100 (1972).
4. Odu, C. T. I. Microbiology of Soils Contaminated With
Petroleum Hydrocarbons. I. Extent of Contamination and
Some Soil and Microbial Properties After Contamination.
J. Inst. Pet. 58,, 201-208 (1972).
Parkinson, D. Oil Spillage on Microorganisms in Northern
Canadian Soils. Canada—Environmental-Social Committee
Northern Pipelines, Task Force on Northern Oil Develop-
ment Report No. 73-25. Information Canada—Cat. No.
R72-8573 (1973).
6. Raymond, R. L., V. W. Jamison, and 0. 0. Hudson. Microbial
Hydrocarbon Co-oxidation. I. Oxidation of Mono- and
Dicyclic Hydrocarbons by Soil Isolates of the Genus Nocardia.
Appl. Microbiol. 15, 857-865 (1967).
-------
TABLE 1
PROPERTIES OF OILS USED IN BIODEGRADATION STUDY
Gravity, API/60°F
Vis., SUS/77°F
Vis., SUS/100°F
Vis., KV/100°F cs
Vis., SFS/122°F
Flash - PM, °F
Pour Point, °F
Silica Gel
Fraction
Paraffinic
Cycloparaffinic
Aromatic
NSO
Arabian Gulf Coast Home Heating
Heavy Mix Crude Fuel Oil
Crude Oil Oil (#2)
27.4 23.6 35.0
164.0 324.0
103.0 161.0
2.4
<40.0 88.0 140.0
+10.0 <-50.0 -20.0
TABLE 2
CHARACTERIZATION OF OILS APPLIED TO
EXPERIMENTAL PLOTS
Type Of Oil
Heavy Coastal
Crankcase Arabian Mix #2
70.5* 45.8 53.6 52.0
9.5 13.3 9.7 3.2
8.6 26.4 22.8 34.7
11.3 14.4 13.8 10.1
Residual
Fuel Oil
(*6)
16.0
160.0
200.0
+55.0
16
37.1
11.2
35.0
16.7
Sulfur
0.3
3.01
0.38
.15
.66
* per cent
. lkl'3
-------
TABLE 3
METALS IN OILS
Used
Crankcase
Oil (car)
CA 700
BA 480
P 1400
ZN 1500
MG 1600
B 10
AL 22
NI
PB 7500
SN 5
CU 17
FE 260
CR 21
AG
SI 18
NA 51
HO 10
V
HN 3
PERCENTAGE
Used
Crankcase
011 (truck)
780
36
1350
1300
1100
-
10
-
75
3
18
180
3
-
8
39
4
-
REDUCTION IN
(ppn)
Arabian
Heavy Gulf Coast
Crude Crude
21
-
-
21 17
-
-
-
23 2
-
-
-
3 5
-
-
-
9
-
65
TABLE 4
OIL CONCENTRATION AFTER ONE
16 Oil
17
-
-
12
21
-
-
13
-
3
-
18
1
-
-
27
-
38
2
YEAR
Location of Field Slles
Tjfpe of 011
Used crankcase oils
Crude oils
Home heating oil
Residual oil
(#6)
Marcus Hook,
Pa.
69.2
64.2
86.0
48.5
, *
Tulsa, Corpus Chrlstl
Okla. Texas
73.8 60.8
77.5 54.2
90.0 86.0
65.5 59.4
Iklk
Average
67.9
61.9
87.3
57.8
-------
TABLE 5
OIL .IN «JN-OFF HATER FROU CONTROL AND OIL-TREATED SOIL PLOTS
TABLE 6
MARCUS HOOK. PA.
Dates - 12/73 3/74 4/74 5/74 9/74 11/74
IL PLOT
wtrol 11 4.3" 2.8
:** - 1.9
: » F 7.8 3.1
: - 0.9
: + F 5.9 2.7
1C - 1.5
1C + F 6.8 3.5
.C - 2.6
C * F 3.9 2.4
' - 1.7
' + F 6.6 3.5
i - 1.8
i * F 3.0 6.4
introl 12 4.3 2.0
* Values 1n ppm
0.6 3.7 1.7 2.4
0.5 3.6 1.3 1.7
1.6 1.8 2.5 2.1
1.6 1.7 1.3 2.0
1.4 2.5 1.6 1.4
1.6 1.9 1.6 1.2
2.4 2.7 3.0 1.3
1.8 3.1 4.0 1.9
1.8 3.1 3.1 1.4
1.1 5.4 1.2 2.3
1.6 2.8 1.1 1.7
1.4 3.3 2.3 1.6
2.5 3.5 2.4 1.5
2.1 3.3 2.8 1.8
OIL IN LEACHATE WATER FROM CONTROL AND OIL-TREATED SOIL PLOT!
DATE 3/74
Soil Plot
Control 11 1.8
CC* 5.4
CC * F
DC 3.7
DC * F 2.7
KAC 3.2
HAC + f
CLC
CLC + F 2.4
12 4.1
12 + F 4.9
16 2.9
*6 * F 3.2
Control 12 3.3
* See Table 5
MARCUS HOOK, PA.
4/74 5/74
4.0
1.9
6.0 8.4
3.6 7.5
5.1 6.8
8.9 18.2
7.5 8.6
5.9 36.0
4.9 7.1
2.4 8.7
2.2 21.0
9/74 11/_74
4.5 7.3
5.0 8.0
5.8 7.4
10.1 14.7
14.0 7.0
15.9 3.7
11.3 6.6
3.9 3.9
3.9 3.9
40 0 17.7
4.1 3.6
** CC - car crankcase oil; CC * F - *1th fertilizer; DC-d1esel
truck crankcase oil; HAC - Arabian heavy crude oil; CLC -
coastal oil; 12 - home heating oil (12), 16 - residual oil
(#6).
TABLE 7
ETHER EXTRACTABLES IN LEACHATE HATER FROM CONTROL
AND
DATE 3/74
Soil Plot
Control 11 36.5
CC* 30.5
CC * F
DC 50.2
DC + F 73.0
HAC 32.0
HAC * F
CLC
CLC * F 53.0
n 55.0
12 t F 32.0
If, 18.5
*6 * F 42.0
Control 12 12.0
* See Table. 5
OIL-TREATED SOIL PLOTS
MABCUS HOOK. PA.
4/74 5/75 9/74
13.0 - 10.0
26.6 - 61.0
23.0 37.5 58.5
21.5 95.5 180.0
26.5 28.5 126.5
73.2 149.5 251.5
70.5 104.5 154.5
87.0 34.0 107.0
23.0 36.0 105.5
53.0 82.0 121.0
12.5 23.3 95.0
5A75
11/74
153.0
164.0
172.0
351.5
282.0
1339.0
2019.5
1336.0
49.5
201.0
148.5
-------
TABLE 8
DISTRIBUTION OF LEAD IN SOIL PLOTS FOLLOWING APPLICATION OF USED, CRANKCASE OILS
Marcus Hook, Pa.
Date
11/73
3/74
4/74
5/74
9/74
11/U
Recovered Oil
Car
90*
33
0
0
7
102
Truck
0
7
0
0
2
100
Control
34
125
100
190
135
100
Soil
Car
448
325
221
320
295
275
Leachate
Truck
31
53
50
110
52
55
Control
0.2
0.2
0.0
0.2
0.6
Car
0.2
0.0
0.0
0.4
0.0
Truck
0.2
0.0
0.0
1.4
0.3
* Values in ppm
TABLE 9
DISTRIBUTION OF LEAD IN. SOIL PLOTS FOLLOWING APPLICATION OF_ USED CRANKCASE OILS
TULSA. OKLAHOMA
Date
Recovered Oil
Soil
Run-Off Water
12/73
' 1/74
2/74
3/74
6/74
9/74
12/74
Car
495*
580
586
493
676
-
525
Truck
160
<10
40
24
<10
-
49
Control
14
20
25
9
50
50
27
Car
198
128
338
313
155
162
147
Truck
9
6
5
23
10
35
8
Control
0.3
0.8
0.03
Car Truck
0.2 0.1
1.2 0.3
0.03 0.03
* values in ppm
-------
TABLE 10
DISTRIBUTION OF LEAD IN SOIL PLOTS FOLLOWING
APPLICATION OF USED CRANKCASE OILS
Corpus Christi, Texas
Recovered Oil
DATE
12/73
1/74
2/74
4/74
6/74
10/74
12/74
Car
600*
830
480
12
23
0
41
Truck
43
35
98
0
16
4
12
Control
2
25
55
25
45
50
21
Soil
Car
325
280
288
62
110
215
268
Truck
47
63
90
62
130
70
63
* values in ppm
TAB LE 11
CONCENTRATION OF LEAD IN SOIL AT VARIOUS DEPTHS
pth in Inches Control Plot Used Crankcase Oil & Fertilizer Plot
0-4 108 247
4-8 108 94
8-12 69 42
1W7
-------
A
o
*y
o
eg
O
in to c 4->
IU •!- 1-
0 JQ +J -0
^t
t- -
U 1
S-
3 O
c
o
as
1 U
O C
IO
S-
•• O
(/>
•!-> TJ
O 01
1 — I/I
0. 3
•O 1
1—
Q>
O> CO i — *
o; • s-
T3^^+J
3 »D C
I- =«= O
o — • o
Xi— 9>
•!- 1- c
E O O
IO IO C
4-> 3 10
l/> "O
IO f- •
O CM
O 0
3- — •
O
»>!—
1C i-
_l O
!ŁŁ
: o o.
-------
Figure 2. Appearance of field plots after application of oils at a rate of
100 bbls/acre.
Figure 3. Howard Rotovator used to incorporate oil into field plots and
subsequent tilling operations. ._ k
14(9
-------
Figure 4. Leachate collectors
Figure 5. Run-off water collector in place.
-------
Figure 6. Residual fuel oil (#6) after application to field plots.
-------
8
7
6
5
_, 4
O
to 3
E
» 2
0
o
o 8
o
^ 7
o
o 6
5
4
3
2
1
O
USED CRANKCASE OILS
•
•
•
•
•
X,
.
• x.
'
^v.
'
X
HOME HEATING OIL (#2)
•
•
•
-
•
X
-^
--,
CRUDE OILS
^
^>
V,
^.
*•*
'
-
—
m
-
RESIDUAL OIL (#6)
^
"X
"»
I
--,
-
-
-
40
30
20 _i
0
10 m
0 ^
O
Ł
40
30
20
10
n
\Z
9 \2
MONTHS
Figure 7. Numbers of hexadecane-utilizing microorganisms and
residual oil concentrations in Marcus Hook, Pa. ex-
perimental plots. Numbers in control plots
Numbers in treated plots Oil concentration
~~~_~. The values are averages of both unfertil-
ized and fertilized plots.
-------
8
7
6
5
_i 4
0
OT 3
E
at
* 2
en
z i
CO
"Z. f\
< °
0
tc
O
O 8
a:
o
Z 7
C9
3 e
5
4
3
2
1
O
USED CRANKCASE OILS
-
-
-
-
-
\
H
-
x
•»«^,
1
•**—
i
HOME HEATING OIL (#2)
_
-
-
-
-
-
-
s.
--
*— -
_,
CRUDE OILS
%
^_
v^
i
._
•*-.
-~
-
"
•
-
RESIDUAL OIL (#6)
^.
•X
^
--
=-»
-
-
-
—
40
30
20
10
40
30
20
10
O
6 9 12
9 12
MONTHS
Figure
9. Numbers of hexadecane-utilizing microorganisms and residual
oil concentration in Corpus Christi, Tex. experimental plots.
See Figure 7 for explanation of symbols. .
o
CO
o
E
-------
O
V)
E
o>
tn
•s.
V)
IS
a:
o
o
ac
o
o
o
8
7
6
5
4
3
2
1
0
8
7
6
5
4
3
2
1
O
USED CRANKCASE OILS
-
-
-
-
-
-
-
-
"
1
v.
-->.
HOME HEATING OIL (#2)
_
-
-
-
-
-
-
^s
*
I
-
tr-—
i*_~.
CRUDE OILS
-^
---,
1
^^^*-
-
-
_
RESIDUAL OIL (#6)
\
ss
fc
***
I
"
--
.
-
-
I
40
30
20 .
10 !
0 >
c
1
40
30
20
10
O
12
12
yONTHS
Figure 8. Numbers of hexadecane-utHizing microorganisms and residual
oil concentration in Tulsa, Okla. experimental plots. See
Figure 7 for explanation of symbols.
-------
8
7
6
5
_, 4
0
v> 3
o> 2
s 1
MICROORGANISI
-W CO O
0
o 6
5
4
3
2
1
0
HEAVY ARABIAN CRUDE
-
-
-
-
-
X
_
^
^,
i
HOME 1
-
-
-
-
•x
^
X.
»
^,
*,
1
*->
SEATING OIL (#2)
-^
^
^,
COASTAL LUBE M\X
X
X.
i
s.
^i
»
1
-
i
•^
-
i
,^
•
.
:
-
-
_
RESIDUAL OIL (#6)
•X
•>
^.
^s
-
1
•^.
^
-
-
-
-
40
30
20
10
0
40
30
20
10
O
o
o>
O
E
12
12
MONTHS
Figure 10. Numbers of oil-utilizing microorganisms and residual oil
concentration in Marcus Hook, Pa. experimental plots. See
Figure 7 for explanation of symbols.
-------
8
7
6
5
_, 4
o
to 3
E
o. 2
S I
o>
2C O
o
1
•«v
">*>
1
•*-.
1
-
-
•
_
RESIDUAL OIL (#6)
\
*
1
s
*.
^
' —
1
M
_
-
-
40
30
20
10
40
30
20
10
O
12
3 6 9 12
O
v
e
o
MONTHS
Figure 11. Numbers of oil-utilizing microorganisms and residual oil
concentration in Tulsa, Okla., experimental plots. See
Figure 7 for explanation of symbols.
-------
8
7
6
5
_, 4
O
co 3
E
" 2
Z 1
CO
I °
0
**•
MICROOF
-J 00
(9
3 6
5
4
3
2
1
0
HEAVY ARABIAN CRUDE
-
-
-
-
-
_
_
j
*.
^
i —
M
.
—
HOME HEATING OIL (#2)
-
•
-
-
-
-
MMM
1
d
L
A
COASTAL LUBE MIX
X
>•
.
.
*>Si
^— .
.
•w
.
•»*
•
1
-
.
-
m
RESIDUAL OIL (*6)
^
%
|
*>>
*
^
».
•*^.
»
-
-
-
4O
30
20
10
0
40
30
20
10
n
12
(2
MONTHS
Figure 12. Numbers of oil-utilizing microorganisms and residual oil
concentration In Corpus Chrlstl, Texas experimental plots.
See Figure 7 for explanation of symbols.
O
CO
O
E
-------
..^Mftfe. -
Figure 13. Home heating oil-utilizing bacterial colonies found
in control and treated plots.
Top - Tulsa soil before application of oil.
Middle - Corpus Christi soil 4 months after application.
Bottom - Marcus Hook soil 5 months after application.
-------
Figure 14. Bacterial types found in control and treated plots.
Top - Typical colony types found in control soils
which use paraffim'c hydrocarbons.
Middle - Typical response to treatment with residual
fuel oil (16).
Bottom - Typical response Arabian Heavy crude oil.
-------
SESSION ON CURRENT SAFETY ASPECTS OF LHG
Wednesday, May 14, 1975 - 2:00 P.M.
Developer:
N. E. Sumner, Sun Oil Co., Philadelphia, PA
Presider:
G. E. King, The Standard Oil Co. (Ohio), Cleveland, OH
Considerations in Siting ING Terminals
R. F. Hill
Federal Power Commission
Washington, DC
Safety Considerations in the Design and Operation
of a Refrigerated LP-Gas Marine Terminal
R. A. Reid
Petrolane, Inc.
Long Beach, CA
Safety Considerations for Liquefied Natural Gas
D. A. Dundore
Philadelphia Gas Works
Philadelphia, PA
Panel Discussion:
General Safety Developments in LHG Facilities
(No transcript available.)
Moderator:
T. E. Davis, Continental Oil Co., Houston, TX
Panelists:
D. A. Dundore, Philadelphia Gas Works, Philadelphia, PA
R. F. Hill, Federal Power Commission, Washington, DC
W. H. Johnson, National LP Gas Association, Chicago, IL
D. Levine, Federal Railroad Administration, Washington, DC
R. A. Reid, Petrolane, Inc., Long Beach, CA
1HSO
-------
THE CHAIRMAN: All right. Next I would like to call
JoAnn Ferguson of the U.S. Naval Facility, Hawthorne, Nevada.
MS. JOANN FERGUSON: I am JoAnn Ferguson, and I am
representing the Naval Ammunition Depot, Hawthorne, Nevada,
Management Association. The Management Association is composed
of supervisors and management personnel at the Naval Ammunition
Depot in Hawthorne.
What I have today is an approach to some of the problem
I have heard this afternoon. And this afternoon I am going to
tell you about the disposal of hazardous wastes generated during
the demilitarization of military items.
And hereinafter I will refer to it as "Demil,"because
demilitarization is a mouthful.
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
SAN FRANCISCO, CALIFORNIA 94102
TEL (415) 673 7747
-------
I will tell you how the Demil is accomplished now, then
how a modern facility under construction at Hawthorne, Nevada
will accomplish this task, and lastly how this facility could
be utilized in a disposal mission other than ammunition.
The basic Denil is:
One. Reduce ammunition to components;
Two. Salvage useful items;
Three. Dispose oE the remainder in a safe and
environmentally acceptable manner.
At present, Demil is done on a piecemeal, as required
basis, both functionally and geographically. Basically,
hazardous waste is disposed by open burning or detonation i~r
through deep water dump — which is, they load an old barge
with all the old ammunition and take it out to sea and sink it.
All three of those are environmentally disastrous.
The new facility under construction will accomplish
this task under controlled conditions that will utilize state-
of-the-art equipment that meets or exceeds EPA standards for
environmental protection.
This is a composite of the facility under construction
(indicating). It is a one-of-a-kind facility complete with equip
ment designed especially for the demilitarization of conventional
ammunition.
Briefly it operates as follows: The material is off-
loaded and the ammunition designated for Derail/Disposal is
H32
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
Ml POLK, SUITE 103
SAN FRANCISCO, CALIFORNIA 941OT
TEL (415) 673 7747
-------
ransferred directly to a storage area. Dependent upon the type
: ammunition and loads, it is then sent to one of the break-
Dwn facilities for further demilitarization.
Of specific interest is the Washout/Steamout Building.
'.ght next to it is a water treatment plant. The contaminated
iter goes through a process of purification so that when it
>mes out it is virtually ready to drink. The only reason we
>n't pump it into the depot water supply is that the water is
scycled into the building -- again, to go through the washout/
:eamout process.
Notice the several evaporation ponds situated through-
it the facility. In the dry climate of Hawthorne the water
.sappears rapidly with little or no problem of stagnation and
;aves residue that can be readily collected for cycling through
ie incineration process. Throughout the total facility, water
id air are so treated that tons of ammunition and explosives
n be processed without adverse effect on the environment.
We envision an extended role for this facility to
elude decontamination and disposal of all hazardous waste
d other undesirable commodities. Bear in mind that the basic
.ndamentals for waste disposal are the same as for
militarization: breakdwon, salvage and disposal without
dversely affecting the environment. This extension would
icorporate a DOD wide waste disposal facility that could be
:panded to a national hazardous waste facility. Capabilities
HS3
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
SAN FRANCISCO, CALIFORNIA 94102
TEL (415) 673 7747
-------
we have at NAD Hawthorne are :
One., A modern facility now under construction.
Two.. State-of-the-art machinery and processes.
Three. Costly overhead items such as utility systems,
fire protection and security systems, OSHA requirements, and
administrative conveniences are already provided for.
Four. Unlimited space for expansion. (85 percent of
the State of Nevada is Public Domain.) Encroachment in our
area is non-existent.
Five. Expertise and management capabilities.
Six. A near temperate climate.
Seven. Transportation facilities — rail and truck —
to the door. You know, it is only a couple of hours from her
to Nevada, or three, depending upon how you observe the 55-mil
speed limit.
And as we have heard today, most waste disposal
requirements are looked upon as a headache and an expense and
a continuing problem, but looking at it from a positive point of
view, we feel with proper capabilities that they can become a
paying proposition.
For example, TNT washed out of projectiles in a
present day Derail facility sells for 22 cents a pound.
TNT melted out and reclaimed in the Demil process und
the new facility sells for 85 cents per pound. It has been
estimated that the net annual revenue from this facility will I
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
60) POLK, SUITE 103
SAN FRANCISCO, CALI FOR Nl A 9410i
TEL (415) 473-7747
-------
$4.4 million from ammunition alone.
We believe that there are comparable revenues from
the disposal of non-ammunition commodities.
Further, an R & D capability could be established on-
site for ongoing development of disposal and salvage technology.
It is estimated the current capital investment for the
Western Demilitarization Facility as it is now envisioned is
between 55 and $75 million. We believe that a nominal
additional investment would considerably widen our scope of
operation in the disposal of hazardous waste.
All the basic assets are already in existence at the
Naval Ammunition Depot in Hawthorne, Nevada.
And what I am saying is now is the time to take a look
at this facility and expand it to include a nationwide
Waste disposal facility.
While this is under construction, with very few additional
taxpayer dollars, we feel it could be incorporated to take care
of some of the present day problems.
Thank you.
THE CHAIRMAN: Thank you, Ms. Ferguson.
Do we have questions?
Mr. Lindsey.
MR. LINDSEY: Just a point of clarification. I think
I understand this correctly. At the present time the Navy is
building this facility, is that correct?
SCHILLER & COM8S, INC
COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
SAN FRANCISCO, CALIFORNIA 94102
TEL 1415) 673 7747
-------
MS. FERGUSON: Right.
MR.. LINDSEY: And you are advocating or your organizati
is advocating that it be expanded into a larger facility to
handle, essentially, all DOD type hazardous wastes, is that the
idea?
MS. FERGUSON: That, is correct. And further expanded
to become the national waste1 facility to handle industry w^ste.
MR. LINDSEY: I see.
THE CHAIRMAN: Mr. Lazar.
MR. LAZAR: Ms. Ferguson, has anyone at the Navy made
any calculations as to the practical feasibility — i.e., from
transporting wastes from the East Coast to Nevada — the
transportation costs?
Would this be a viable option for a waste generator
who is on the East Coast?
MS, FERGUSON: Yes. I think it would.
No,, no one has made any studies.
MR. LAZAR: Are there any plans to make a study, since
you made the recommendation?
MS. FERGUSON: We have made this recommendation, and
we would like to have all the endorsement possible. Because
we have to go higher. And this would be included in a standard
study, no doubt, as to the feasibility of making this facility
a nationwide disposal facility.
THE CHAIRMAN: Mr. Mausshardt?
SCHILLER & COMBS, INC
COURT AND DEPOSITION REPORTERS
601 POLK, SUITE 103
SAN FRANCI'iCO, CALIFORNIA 94102
TEL (415) 673 7747
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MR. MAUSSHARDT: I have two questions here from the
floor.
Let me read the second question first; it is shorter.
The current international price of TNT is 31 cents per
pound. Who will pay 85 cents for TNT?
MS. FERGUSON: The prices I have quoted are the ones
that we have been using. And no doubt they have changed,
because prices change from day to day, but the ones we have
basically used in our demilitarization facility is in the
presentation.
MR. MAUSSHARDT: The second question is: Aren't most
all of the military explosives now sold surplus to private
industry? In fact, hasn't there been some second thought about
completing the final phases in light of the high prices of these
explosives fixing — I believe that is the word — in light of
•T
the high prices of these explosives.
MS. FERGUSON: A lot of the explosives are now sold on
bid to competent contractors. And the contractors probably work
and recycle it back into private industry.
What we have done in Hawthorne -- upon the completion
of the facility -- what is not sold, some of it can be reused
within the Department of Defense for ammunition production.
This question I cannot answer fully because I am not
equipped to go into all the technical questions.
I am here to sell an idea.
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THE CHAIRMAN: Ms. Ferguson, could we perhaps clarify
for the record the nature of the NAD Hawthorne Management
Association. Is this a public or private organization, is this
a private organization but not associated with the Department
of Defense?
MS. FERGUSON: It is a private organization composed
of supervisors and management personnel working for the Naval
Ammunition Depot in Hawthorne, Nevada.
We operate under an executive order for this type of
association. It is like blue collar workers and lower-rated
people have their unions. And we are here to improve the
management capability of MAD, Hawthorne and try to expand it
throughout the Department of Defense and the government.
THE CHAIRMAN: Thank you. Now, Mr. Kovalick?
MR. KOVALICK: I was curious as to whether the
association has had a chance to explore what we feel is a fairly
significant policy question. And I am interested as to whether
you have any thoughts on it. That is that by advocating such
a facility and its expansion to the non-government trade, if you
will, you are advocating putting the government in the business
of treating and disposing of wastes. And I was wondering if you
had a chance to bounce that concept off the industry, those
already in the business, or have thoughts as to what the
relationship of these kinds of facilities ought to be to people
who are in that business already.
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MS. FERGUSON: No.
THE CHAIRMAN: It doesn't appear as if we have any
other questions. Thank you very much, Ms. Ferguson.
MS. FERGUSON: Thank you.
THE CHAIRMAN: Ladies and gentlemen, we are very close
to the time we have been asked to take a break.
I do not anticipate that this meeting will go into the
dinner hour or will require another day's session.
I would like to take a short break at this time for
15 minutes and reconvene at 3:40.
(Short recess.)
THE CHAIRMAN: Ladies and gentlemen, please take your
seats.
I want to indicate to the audience that Mr. Baker from
the California State Solid Waste Management Board has his
written testimony as well as his oral remarks, and his written
testimony will be made a part of the record.
At this time I would like to call Sanford Jay
Fleisher of the S. Rose Cooperage Company, Montebello,California.
Mr. Fleisher, please.
MR. SANFORD JAY FLEISHER: Mr. Chairman, members of
the panel, ladies and gentlemen.
My name is Sanford Fleisher, and I am here today on
behalf of our firm, S. Rose Cooperage Company of Montebello,
California, and as a member of the Western Region of the National
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Barrel and Drum Association from whom you have already heard
speakers in Newark, New Jersey and Rosemont, Illinois.
For about one year our firm has been engaged in a new
program of decontaminating and reconditioning used pesticide
containers. This program was set up under permit from the
California Department of Agriculture. To date we have success-
fully reconditioned several thousand of these containers for
reuse or recovery.
The Environmental Protection Agency's publication,
"Hazardous Wastes," illustrates in depth some of the many
problems associated with improper disposal, storage and land
emplacement associated with these containers.
As an industry we are aware of the problems associated
with the transportation, storage, and employee safety involved
in reconditioning these containers, and we for one feel that
these problems can be dealt with, thus resulting in the reuse
and recovery of these materials from the hazardous waste
stream.
The pesticide container disposal problem is an old one
and a large one to chemical formulators, applicators, farmers
and regulatory agencies. I feel that we can make substantial
inroads on this problem by the reuse and recovery of these
containers wherever economically feasible; and by this approach
reduce injury to humans, livestock and the environment.
There exists, throughout every area of the country,
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reconditioning plants, many of which I feel would be willing to
participate in a plan aimed at the recovery and reuse of these
containers.
There does, however, exist one area of concern that
would hinder the efforts to utilize the reconditioning industry
as an alternative to land emplacement of used pesticide container
Our industry has discussed that problem with members of your
staff and the Office of Pesticide programs in August of this
year.
The problem is that under existing Federal Insecticide,
Fungicide, and Rodenticide Act Regulations, any container which
bears a label directing the user to puncture and bury the
container whem emptied, cannot be reconditioned. Under a plan
submitted by Dr. Hooper of W & H Industries, Incorporated during
the August meeting, this problem could be eliminated by the
issuance of a Pesticide Enforcement Policy Statement or by
modification of the existing regulations.
To date no action has been taken on that plan. My
recommendations to this panel are as follows:
One. Review with the Office of Pesticide Programs
a modification of its existing regulations, or the issuance
of a PEPS to authorize the reconditioning of all used pesticide
containers.
Two. Adopt guidelines recommending that land emplace-
ment of pesticide containers, with a capacity greater than five
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gallons be prohibited, except where reuse or recovery could
not economically be achieved.
Thank you.
THE CHAIRMAN: Thank you, Mr. Fleisher. Do we have
questions?
Mr. Lazar.
MR. LAZAR: Mr. Fieisher, just one question. How can
you recondition a drum which has been punctured? I did not
understand that particular part of your presentation.
MR. FLEISHER: What I was calling attention to is that
under the existing regulations — where a label says
to puncture or crush that drum — in other words, to dispose of
it --
MR. LAZAR: You are against it?
MR. FLEISHER: That is right. We need an alteration
of the regulations to change that.
THE CHAIRMAN: I believe we have questions in
preparation here.
Mr. Kovalick?
MR. KOVALICK: Mr. Fleisher, we have had several sets
of testimony from the National Barrel and Drum Association, and
we have had none from the container manufacturers. And if they
were not in existence you would not be in existence.
MR. FLEISHER: That is correct.
MR. KOVALICK: Would you care to comment on their
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reaction or attitude towards the kinds of recommendations that
you and Dr. Hooper have made?
Is their silence indicative of anything special, or do
you think it is just that you have taken the interest?
MR. FLEISHER: I do not think I am qualified to comment
on their position.
THE CHAIRMAN: Mr. Kovalick?
MR. KOVALICK: From the audience.
How do you guarantee that a pesticide container has
been properly decontaminated?
MR. FLEISHER: What we are doing is following to the
letter the prescribed procedures as set down in regulations by
the California Administrative Code. And we are one of two
reconditioners in the state that are licensed to transport,
store, and decontaminate and recondition these drums.
And the regulations call for burning the drum out,
removing the lid of the drum and burning the drum out at 1400
degrees and 1650 degrees through our afterburner. And we are
following those standards.
MR. KOVALICK: Presumably then you are subject to some
kind of an inspection at the option of the State of California?
MR. FLEISHER: They are welcome to come in at any time.
THE CHAIRMAN: Any other questions? Apparently not.
Thank you, Mr. Fleisher.
I would like to call at this time Dr. Joseph Hooper of
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W & H Industries.
DR. HOOPER: Mr. Chairman and members of the panel.
W & H Environmental Systems Division of W & H
Industries, Inc. is a firm which in part has specialized in
pollution abatement technology development predicated on resouro
recovery.. Our research in this area is both pure and applied
based upon specific client needs and involves an inter-disciplin.
approach.
Much of our v/ork during the past three years has
concerned itself with development of technology to reduce the
volume of materials required to be disposed of by land
emplacement from industry. One observation that we can make at
this point in our work is that most hazardous wastes can best
be managed by a resource recovery approach if not cross
contaminated with other hazardous wastes.
A second observation that we can make is that there is
no lack of technology in the area of resource recovery but
rather it is the cost of implementation. Only when the regulate
criteria begins to compel more extensive and costly environmenta
safeguards over disposal practices than now exist will the
resource recovery approach to management of hazardous waste
blossom.
Some hazardous waste management problems could be
resolved or the impact reduced at this point in time without
additional legislation. This would require an educational
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program aimed at the producer of these wastes to show him how
he might reduce his operating cost by utilizing certain in-
house recovery programs.
We can cite the example of a client who utilized a hot
tank cleaning operation in his plant which required frequent
changes and disposal of 83,500 gallons of hazardous solution
per year. A system was designed and built for the client at a
totoal cost of $3,500. It resulted in a reduction of offsite
disposal by 65 percent and reduced the clients' purchases of
new chemicals by $7,300 per year.
Another problem area we have worked with which we feel
can be minimized at this time is the disposal of used containers
which contained either pesticides or other hazardous substances.
Much of our work in this area has already been heard by this
panel at other public meetings and therefore need not be
covered again, but if the panel has any questions regarding
that work I would be glad to try and answer them at the close
of my statement.
Other hazardous substances could best be managed by
the development of regional reclaiming centers which should be
generated as a cooperative program between government and
the private sector. Government efforts taking the form of
special tax incentives to encourage private sector participation
and grants to defray a portion of the initial capital costs.
In recent years virgin raw material costs have increased in part
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as a result of higher energy costs to industry. This condition
in the marketplace is beginning to create a place for reusable
raw materials which could be recovered from the hazardous
waste stream at such centers.
Hazardous waste generated by industry is taking
their toll on our available land emplacement disposal sites
with an annual increased demand for land emplacement increasing
by an estimated ten percent. Unless this tide is turned we are
going to find ourselves with a number of new inadequate sites
receiving hazardous wastes and resulting in damage to the
environment and public health.
In conclusion, it is our recommendation that a National
Hazardous Waste Policy be developed that differentiates between
recoverable and non-recoverable wastes and that all wastes
determined to be recoverable and reusable wherever feasible be
prohibited from disposal by land emplacement.
Thank you.
THE CHAIRMAN: Thank you, Dr. Hooper.
Do we have questions?
Yes, Mr. Lindsey.
MR. LINDSEY: Yes. Dr. Hooper, with regard to your
work on the barrel reclamation project, could you give us any
cost information on what it costs the user to use a new 55-
gallon drum as compared to a reclaimed or reused one?
DR.. HOOPER: Currently there is one thing that we have
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to point out. When we held meetings on, I believe, August 12th
with members of your staff and the Office of Pesticide Programs,
the Department of Transportation and National Agrochemists
Association — the new container manufacturers were invited, by
the way, but did not choose to attend the meeting, to clarify
an earlier question — members of the reconditioning industry
and other concerned parties. It was pointed out that there
exists now a problem in the DOT Class B poison regulations
which specifically prohibit anything but a single-trip container
of those substances, so that you could not reuse that container,
but that container could be reused for a lesser toxic substance
or a lesser hazardous substances as defined by DOT.
For example, what is referred to as 5-B drum is
commonly used for a shipment of technical grade parathyome
between manufacturer — formulator. That drum could not be
reused to ship technical grade parathyome under DOT regulations
as they now exist. But that drum could be recovered,
reconditioned, and reused,for example, for the packaging of
sodium hydroxide.
MR. LINDSEY: Under present regulations?
DR. HOOPER: Yes, under present regulations.
MR. LINDSEY: Would you like to go further and state
why this paradox exists?
DR. HOOPER: As I recall, there was a statement made
by a member of the DOT staff at the August 12th meeting which
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said, based upon a request from EPA, quote-unquote — he didn't
specify what part of EPA — DOT would be willing bo review that
regulation and modify the Class B poison regulations that now
exist.
I frankly do not think that that would oosne to pass
too quickly.
MR. LINDSEY: Could you, however, speculate on what
the cost would be if it were allowed?
DR. HOOPER: Let us talk about the cost of a new drum.
Regardless of what its use is going to be. And we are talking
somewhere — depending on the specific drum and the specification
of the drum — but we are talking between probably 15 to $20
for that drum new.
He are talking a reconditioning drum market, probably
the best with everything built into it that they are going to
want, the upper limit of it would be around $11.
If it was a service reconditioning., tihe cost "would be
far less. I think the national average right now for service
reconditioning is under $4.
THE CHAIRMAN: Yes, Mr. Lindsey.
MR. LINDSEY: I have one here from the floor, and I
think perhaps you have answered it, but 1 will just be sure
and ask it again.
Why does the inside of, for instance, a pesticide
drum have to be cleaned if destined for the same reuse?
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I guess the answer is because as far as you are concerne
the DOT requires that, is that right?
DR. HOOPER: Well, cross contamination being one point.
Number two, something that others — Dr. Hayes, for example, ;
originally with the Department of Public Health, pointed out j
recently in his book, "Toxicology of Pesticides," there is a
big problem in the whole area of these containers. And you
heard Mr. Simon address that problem this morning.
Look at the photographs in front of the room
(indicating) and start counting the containers that you cannot
identify. You cannot tell me what was in those containers.
Because there is no way, once that drum is put out in the
environment and the label is lost, to identify what was in that
container. So who is going to take the gamble of cross
contamination? I think the liability would be horrendous to
a reconditioner.
THE CHAIRMAN: Mr. Kovalick?
MR. KOVALICK: I wanted to explore one of the sentences
in your statement regarding regional reclaiming centers and one
suggestion was that government efforts take the form of special
tax incentives to encourage the private sector or perhaps grants
to defray a portion of the initial capital costs were suggested.
Again, I would like to bring up the fact that there is
an industry already in existence, and I guess from an economist1;
point of view, it could be viewed as a subsidy from the
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\
government to this new entrance into this industry, thereby
putting those who are already in this business at a disadvantage
Would you care to comment on that?
DR. HOOPER: I am not particularly advocating that we
create a new marketplace or a new industry in the marketplace.
What I am saying — the best example that I can cite
to you is chromates.
We all know the issue of toxicity of chromates. There
are many small generators, particularly the plating industry,
of chromate wastes. Chromate costs have increased steadily in
the past few years. It is a raw material which we have no
domestic supply of whatsoever in this country. Every bit of it
is imported, and imported from countries which to say the
least we are not on friendly terms with other than our trade
relationship with those countries. And yet here we are talking
about a problem with disposal of these types of wastes.
The technology readily exists for reclaiming chromates
in the same form that they are sold back to the industry.
Yes, there is high initial capital cost. There are
transportation problems associated with getting those substance
to one center where it would be economically feasible to
recover them.
Do we want to continue spending tax dollars to study
the problem or do we want to take those tax dollars and put
them someplace to solve the problem?
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And do we want to do that in the form of a tax
incentive or an outright cash outlay to get something done about
the problem?
I think you only have to look at Tricell in Montreal
or the Tricell program that is going on in Toronto, and we can
get some very good demonstrations of joint government-private
sector participation in the management of hazardous wastes.
THE CHAIRMAN: Any other questions? Apparently not.
Thank you very much, Dr. Hooper.
At this time I would like to call Mr. Ron Eggers from
Alameda County, California.
Mr. Ron Eggers, Alameda County, California?
Is he in the audience, please?
Perhaps he stepped out, we will come back.
I would like to call Mr. Leonard Tinnan of the BKK Company.
MR. LEONARD TINNAN: My name is Leonard Tinnan . I am
technical director of the BKK Company located in the Los Angeles
area.
Our company, including its subsidiary divisions, is
the only organization licensed by the State of California to
both transport and dispose of all forms of non-radioactive
solid and liquid hazardous wastes. By quantity of waste disposec
hazardous waste disposed, we are the largest disposer of
hazardous wastes in the State of California.
In much the same way that the State of California
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pioneered sanitary landfilling throughout the United States,
the State of California is pioneering the management of hazardous
wastes in the nation. The BKK Company is pleased to have been
with the State of California, the pioneer for the design,
construction and operation of sanitary landfills, and we are
pleased to be the pioneer in the State of California for the
land disposal of hazardous wastes within this pioneering state.
Among other operations our company operates a 600-acre
Class One disposal site located in the City of West Covina,
California in Los Angeles County.
The site is a fully contained site, meaning that any
materials which enter the site, liquids or leachates, resulting
from waste deposited cannot leave the site.
Part of that self containment was derived from natural
origin, meaning we started with a geological bathtub;
we had a geologic substructure such that material could not
vertically migrate into ground waters. But our bathtub is a
little tilted and a little open at one end. And we have over
the past several years designed and built artificial hydraulic
barriers to prevent the migration laterally, the potential
migration into drinking waters, ground waters.
In addition to the barriers, we have leachate collectio
provisions, leachate monitoring and leachate pumping provisions
at the site to assure that the barriers are in fact intact and
provide for full containment of materials within the facility.
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We believe that the experience in the West Covina Class
One landfill demonstrates full well that land disposal of
hazardous wastes is environmentally effective and probably
the lowest cost mechanism for disposal of non-recoverable wastes
Now, at our site, every liquid load which enters is
sampled upon entry and prior to disposal. Measurements are made
of such parameters as temperature, pH, explosivity and odor
evaluation and other special examinations.
The primary reason for this evaluation is neither to
decide whether to accept or reject the load, since our site is
capable of accommodating all forms of non-radioactive wastes,
but is principally to assure the public health and safety of
the truck driver bringing in the load, of our own personnel
operating at the site, problems which could arise during the
dumping operation itself.
After the chemical evaluation is made of the incoming
waste load, the chemical technician gives to the truck driver
a placard with a number which indicates the specific disposal
technique and the disposal area which the foreman on the working
deck then leads or directs the truck driver to. Certain types
of materials highly corrosive and malodorous materials, for
example, are placed in deep injection wells. Other materials
of a less toxic nature can be pooled in the daily intake of
rubbish, which by the end of the day is fully compacted and
covered with at least six inches of earth material.
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Other materials such as highly dangerous cyanide
materials are directed to remote disposal points, special holes
are cut while the truck is there, load is dumped, and the load
is immediately covered.
We do not and are not permitted to operate solar
evaporation ponds in Southern California as exist in some areas
up here, for example, the highly discussed and controversial
Contra Costa County operations that were discussed earlier today
Now we do occasionally upon examination of the liquid
waste manifest, which has been discussed by Dr. Collins and
many others today, after a careful assessment of what it says
about the character of the chemical and our own chemical
evaluation, may choose to reject a waste load. The contemptuous
waste load which was discussed by Ms. Siri earlier today, which
traveled from Contra Costa County to Southern California to
Nevada and back to Contrsi Costa County was rejected at the
BKK disposal site. The generator had properly identified the
material. But it was clcissified — it is a material which is
extremely hazardous and requires State Department of Health
approval prior to moving on the roadways. That approval had
not been obtained by the Department of Health.
The material was highly toxic from inhalation, and
had it been permitted to be dumped openly could have killed personnel
operating at the site. In addition, it was highly odorous and
that was the basis for it being rejected. It was a load proper!
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identified by the producer. It was collected and transported by
a legitimate waste hauler without prior state approval and
then it was eventually disposed of improperly at a site not
authorized to accept same.
We believe that the techniques and the facilities,
the procedural steps, the techniques for evaluating loads and
disposing of them properly do exist, but they do need to be
enforced rather rigidly. And I wish to touch upon that aspect
as I proceed through this statement.
Waste disposal in the State of California is actually
regulated by the Water Resources Control Board. Unfortunately,
not represented at this hearing today. We have had an
excellent presentation by Dr. Collins from the State Department
of Health. Their concern is with hazardous materials which are
hazardous from a public health and safety standpoint. But land-
filling practices and landfilling disposal of wastes in this
state are principally a water quality problem regulated by the
Water Resources Control Board at the state level and by the
regional Water Quality Control Boards. There is a document
which is issued periodically. This blue book is entitled "Waste
Discharge Requirements for Waste Disposal Land" issued November,
'75 by the California State Water Resources Control Board. It
is from that agency that we as a landfill operator obtain our
permit to operate a disposal site.
We must of course adhere to all health regulations, all
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the policies and the criteria the State Solid Waste Management
Board promulgates- we must comply with all air pollution control
district regulations as well, but this is our boss. This agency
which puts out this document is the boss and they in fact are
unfortunately not represented here today.
Now, the reason I make that point is because we think
that much of the confusion by generators, transporters, treaters
and disposers of hazardous industrial liquid waste is in fact
due unfortunately to the terminology "hazardous."
With due deference to the committee and the title of
this hearing, I acknowledge that the word "hazardous" has a
tremendous impact, but what we are concerned with is non-sewerab
industrial liquid wastes. They may be hazardous in some cases
from a personal safety standpoint, health and safety standpoint.
They may in other cases be quite harmful from a water quality
standpoint.
We urge and have urged the state committee with Dr.
Collins and Mr. Baker who are representatives here in the state
that have reported here earlier, we have urged that a consolidat
state listing or consolidated state set of criteria be establish
to avoid or minimize any future confusion which does exist.
Let me give you a couple of interesting examples of the
problem that exists for a waste disposal operator. The State
Water Resources Control Board classifies as Group One wastes,
acceptable only by Class One disposal sites, such materials as
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brines from food processing industries. The State Department
of Health does not consider that hazardous. But they are
unacceptable from a water quality standpoint for disposition
in any place other than a Class One disposal site. So the
generating industry of brine, the food processing industry, does
not have to mark as the producer of that material that it is a
hazardous waste because it is not hazardous by state definition.
But it still must be directed to a Class One disposal site.
Drilling muds, likewise, are considered Group One
wastes, acceptable for disposal only at Class One disposal sites
Again, in many cases, in most cases, they are not classified as
hazardous materials by the State Department of Health.
And the fact that these two types of materials -- just
as examples — are not defined or marked or identified on the
manifest as hazardous, has allowed some people the room, if you
will, to interpret that they are suitable as Group Two wastes
for disposition at Class Two sites. They are not hazardous
by state definition, but they are detrimental to water quality.
And that is where some of the Group One wastes are going and
how they are going into Group Two sites. Class Two sites.
Let me offer the other side of the coin. Chemical
toilet wastes are not considered detrimental to water quality.
They are considered as Group Two wastes by the Water Resources
Control Board, but they are considered as hazardous materials
by the State Department of Health. Settling sludges are
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considered as Group Two wastes, but, likewise, are identified as
hazardous.
Now, here are materials which are hazardous and can
be shown and marked properly identified on the manifest as
hazardous and still end up in a Class Two disposal site because
the Water Resources Control Board identifies them as Group
Two waste materials.
Those are some of the anomalies that must be eliminated.
And the terminology "hazardous" is not the indication. We need
a list that does not need a name. If in fact a list is possible
— just a list of what can go into a specific site. And I do
not think one could even generalize. Each site probably has
certain types and quantities of materials it could accept.
Now, without intending to be facetious, let me give
you another example of this problem of identifying or titling
materials as hazardous.
Suppose we had a vacuum truck rolling in this after-
noon carrying four or five thousand gallons of lemon juice.
People would tend to scoff at this being hazardous. Some of
my colleagues in discussing this example said they ought to get
5,000 gallons of water and a hundred pound bag of sugar and
open the largest lemonade stand in California. But lemon juice
is citric acid and would show a pH of about three — fairly
acidic, fairly acidic indeed.
Now, if we took this harmless lemon juice and placed
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it in a disposal area such that it could possibly comingle with
cyanide base, we could in fact release highly dangerous gas,
cyanide gas. And the cyanide materials may have previously been
placed, an(j it was the lemon juice that in fact became the
hazardous contributor to this chemical reaction.
In our judgment, then, we are not sure that any list
will ever be made which can properly identify all hazardous
situations, and that in fact nothing will supplant logic,
technical knowledge and skilled operators in terms of effective
handling of wastes. We think that lists and sets of criteria
can serve as guidelines, but skilled and trained personnel, we
believe are the answer for handling all materials, whether they
be labeled hazardous or not.
Now, the question arose this morning, a member of the
committee asked the question I think of Dr. Collins about
training materials and training programs, are they adequate or
suitable.
While our company believes that every company involved
in the handling, either of the producing, the transporting, the
treating or the disposing of the waste materials should
institute and maintain a rigorous self-training program which
is tested by the state in a means that produces certification
or a licensing of all personnel, facilities, and equipment
associated with the handling of these types of waste materials.
So we have training, self-training, with state
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certification, and then with state enforcement with a system
that has teeth in it such that after one or two minor
violations which might result in monetary fine.s, revocation of
that license or certifcate would be the penalty.
Now, if I am a habitually bad driver, I get fined the
first one or two times in the court, and then my license is
suspended or revoked. Why can't we use the same sort of though
pattern on this type of operation? Let us license our people,
make sure that they are properly trained, skilled in the
procedures and care, and then penalize them with revokation of
that ability to do business should they violate the law.
Now, in fact, the State of California has a major
anomaly in the legislation governing waste materials. In fact,
the law permits a negative incentive or disincentive on the
legal disposition of hazardous waste materials.
Everytime a hazardous waste that is properly disposed
of in an approved Class One disposal site is taxed 60 cents
per ton, and that fee goes back to the state to help administer
the surveillance program that Dr. Collins spoke of earlier
today. But keep in mind the impact on the producer and the
transporter or both if they are trying to save a buck. If you
dispose of the material, if you mark it improperly, meaning you
mark a hazardous material as non-hazardous or if you dispose of
it illegally, it does not get taxed. So one is actually
encouraged to engage in illegal operations.
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The waste producer first, then the waste transporter.
The waste disposer does not care. We collect the tax when it
comes in as a hazardous material and we pay it to the state
as one does in any other form of taxation. But we have got to
stop the principle that the legislation requires legal disposal
and that illegal disposal be permitted to go free. And in fact
we have recommended to the state committee that as an alternate
to the 60 cent per ton imposition on hazardous materials, some-
thing like two cents a ton be imposed on all liquid wastes,
and the same revenues could be derived by the state. And in
fact, monitoring by the state agencies, the Water Resources
Control Board and the State Department of Health and others,
really needs to be at the Class Two sites rather than at the
Class One sites. Class One sites can accept these materials.
Class One sites should be required to institute chemical
sampling of all the incoming loads so that the disposition
can be properly directed, but the monitoring should be at Class
Two sites to insure that loads that are not suitable at that
area should be rejected.
I would like to close with one thought which deals
with the legal liability. Mr. Knowlton, representing the
Western Oil and Gas Association, expressed some thoughts that
we share and endorse completely. We do, however, disagree as
to where the liability of the producer stops.
Waste dispoers like ourselves, the disposal industry,
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obviously is responsible for assuring once it is in their hands
at the proper site that odor control, air pollution, water
quality control provisions are all enforced.
Now, the waste producer, we believe now that either
Federal and/or state legislation should be enacted which makes
the ultimate disposal the legal liability of the producing
industry, and in that way, number one, the producer will proper.
identify the materials. Number two, he will select a legitimat<
transporter. Number three, he will direct that transporter to
an appropriate and approved disposal site. And then the
responsibility of the disposal operator takes over.
It is very easy for industry to fill out his part of
the waste manifest, identifying properly what the material is,
and then goes to low bid for the waste hauler, and the waste
hauler got the job because he underbid it, not calculating in
waste disposal charges that the BKK Company or the LA County
Sanitation District or others would charge, and then dumps it
down a manhole or in some other outlawed disposal technique.
He did not have to pay a disposal fee. He therefore could
reduce his price.
So it does not suffice for the waste producers simply
to pick a low bid waste hauler. It is his responsibility by
picking a licensed and certified hauler to assure and directing
the disposal site to make sure it gets to the proper dispositio
The direct cost for the producer may be a little highe
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as Mr. Knowlton pointed out, and may have to be passed on to the
consumer or the products in that industry. But that technique
will certainly avoid the potential downstream huge liability
costs that may be legally the producers if he does not do that.
Thank you.
THE CHAIRMAN: Thank you. Do we have questions?
Mr. Kovalick?
MR. KOVALICK: You mentioned that you are in the
transport business as well as the disposal business.
Is there any portion of your hauling that is done
interstate, and, if so, what have been your experiences with
that?
MR. TINNAN : yes. We haul interstate.
We do our transportation through a subsidiary known
as Chansler, Ogden, Incorporated. We utilize materials being
brought Into this state or being hauled out of this state, the same
liquid waste hauler manifest that we do for materials starting
and ending inside .the state.
MR. KOVALICK: Related to that, then, you would have
to comply with DOT regulations for labeling and placarding if
you are hauling interstate.
And it is not often that we get to ask directly of a
transporter this kind of question, but we have had some state-
ments in other cities that the information required for a DOT
label of a hazardous material — for example, corrosives — is
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that information sufficient for you to use at the treatment and
disposal site, or do you require additional information than
that which is required for the transporter to the disposal site?
MR. TINNAN : we do not really use the labeling or
placards as any more than a first order warning. The manifest
is the thing we depend upon, first. And secondly, our own
chemical evaluation upon receipt at the disposal facility. So
the placard is simply a warning so it doesn't go astray, if you
will.
MR. KOVALICK: So the information is not sufficient on
the placard. You need additional information.
MR. TINNAN : i ttiink that is correct.
THE CHAIRMAN: Before we go on to another question, I
would like to request Mr. TINNAN , because you mentioned and
showed the audience the November, 1975 document from the
California State Water Resources Control Board. And I was
wondering if you would introduce that for the record, too, since
it is part of your testimony.
MR. TINNAN : Yes, I would be pleased to.
THE CHAIRMAN: Thank you. Let us now go on with the
questions.
Yes, Mr. Lazar.
MR. LAZAR: I have a question concerning your sampling
procedures. You mentioned that every load is sampled. And am
I correct in understanding that there is a trained chemist at
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the gate who is able to do laboratory analysis while the truck
driver is waiting;
MR. TINNAN : That is correct.
MR. LAZAR: Now, I have a question from the audience.
What sampling and analysis procedures of incoming
wastes do you recommend for — long-term — for the proper
operation of the Class One site? What type of testing do you
do now, and what do you think should be done to assure long-
term safety?
MR. TINNAN : Is this again referring to sampling upon
entry?
MR. LAZAR: Yes, yes.
MR. TINNAN : Well, what we have instituted is, if you
will, fairly cursory evaluation based upon available information,
quick reaction portable instruments. It is unfortunate, that
it does not exist, there do not exist many instruments that
will allow us to do a much more complete spectroscopic or chromato-
graphic analysis of materials. They take time. We cannot keep
a driver waiting that long.
So the basic purpose is one — we have loads that come
in with a pH reading of 11, and the pH is really one or two.
Well, that could give us a real problem had we dumped what
appeared to be an alkaline material in an area that should have
been reserved for acids. So we provide that kind of safeguard
for ourselves. We think the pH is a measurement which must be
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made in all cases simply to verify the manifest.
We are strong believers of the state's policy of liqu.
waste manifests. We use it first to verify the pH. We do an
odor evaluation, not from a public health and safety standpoin
but we have to live as a good neighbor in the City of West
Covina. And we can get fined very heavily should those odors
permeate. So we do the odor evaluation so as to know whether
we can take the non-toxic material. Cannery wastes, for examp
— we simply pool it in the rubbish pool which is a temporary
pool. It is not an evaporation pond. Or we determine whether
we have to make a special hole immediately for that truck and
cover it immediately. So the odor evaluation is important
from a good community relations standpoint. The explosivity
evaluation, which can be done with good portable meters, is, I
think, its benefit is obvious.
We would urge that anything else that could be done
to check the load without more than a five-minute tie-up.
MR. LAZAR: My last question concerns the potential
incompatibility of wastes. Now, you mentioned the example of
lemon juide and cyanide. That is a rather simple example.
But I presume, there must be waste loads where you
really do not know whether it may be compatible with the
material that had been deposited earlier. Or even if you take
the simple example of cyanide, what safeguards do you have
that later on at the same site someone might pour some
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hydrochloric acid on it?
MR. TINMAN : Let me take the second point first.
Materials like cyanide are in designated areas that
are not and will not be used for other materials such as acids.
So we simply have kind of a land use plan of our own, if you
will.
As far as the first question is concerned, there are
many strange materials that arrive. And if we do not know what
it is, in those cases that truck will be stopped and pulled
aside at the gate and our chemist or one of our management
team will actually call the producer and get a detailed
explanation of it and an explanation of the potential hazards
that are not clear from the manifest itself.
We have materials that cone in — they will not make
any sense to us. We have not heard of them before or the load
is not fully explained. In that case we will delay the operator.
We cannot risk it going in and say, oh, well, it's probably
all right. So he is pulled aside and stopped.
MR. LAZAR: Do you have shipments that are hetrogeneous,
that come from various sources on the same truck or from research
laboratories where you have a variety of potential hazardous
materials?
MR. TINMAN : We often get liquid waste haulers with
their vacuum trucks bringing in two or three loads. But we get
the liquid waste manifest, a separate record on each one of them.
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So a truck could come in, we get three records. And we look at
those and determine whether they were compatible with each other
And part of the test was that they survived the trip that far.
(Laughter.)
And then as far as the laboratory portion, Mr. Lazar,
many of those are individual packages in drums, cans, other
containers, rather than being mixed together. And then they are
isolated by type.
THE CHAIRI1AN: Mr. Mausshardt.
MR. MAUSSHARDT: I have a question from the floor. It
is a question of liability which you raised in your paper
earlier.
If you propose to place the legal liability ultimately
on the producers, what assurance does a producer have that you
will properly dispose of the material when in fact you have no
legal obligation to that particular producer?
MR. TINNAN ; Perhaps I have oversimplified the dividing
line.
What I meant to say was that the producer has the
legal liability through the point of delivery to a state
approved disposal site for that material.
But the trucker serves only as his agent, and indeed
therefore maintains the liability for that agent until it is
accepted at the disposal site.
If we turned away from our gate and it was still in
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that truck, that producer still has a responsibility until final
disposal at some point.
I really did not mean for him to take the responsibility
of the legal disposer.
THE CHAIRMAN: Mr. Lindsey.
MR. LINDSEY: In that same regard, if the producer
were to mislabel the material — whatever it was — on the
manifest, and through disposal created some sort of damage
incident, either people or whatever, who would have liability
in that case — you, the producer, you together, or what -- as it
stands now?
MR. TINNAN . V7ell, if it were improperly completed
either through negligence or malintent, I think the law would
find the right person to be liable.
MR. LINDSEY: I have one from the floor.
Do you practice any treatment processes in addition
to the land-to-land disposal?
MR. TINNAN : Through an R & D arm of our company we are
quite active in trying to reclaim many waste materials that
are coming in.
I can cite an example which is strong in our current
plan. We handle huge quantities of acids, waste acids, sulfuric,
phosphoric, nitric. If our current engineering and economic
studies work out we are currently producing methane gas from
our wells, from four wells at the West Covina landfill. Should
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these studies continue, the results continue as they now show,
the conversion of this landfill gas into a pure methane by
essentially a separation of CO2 and other impurities, provides
us with a valuable feedstock from which ammonia can be synthesized
And then the ammonia can be blended with the sulfuric acid, for
example, to make ammonia sulflate , and it would end up as
fertilizer, as an ingredient in a final fertilizer product, and
would not require land disposition and would not have to go
back into sulfuric acid in its use.
THE CHAIRMAN: Mr. Bourns, you had a question?
MR. BOURNS: Yes. I had a question that came to mind
in your discussion when you were talking about the fee being
collected by the state for monitoring of 60 cents a ton and
collected at the site by the site operator.
I wonder if moving this fee up to the producers or
generators would not do several things, like encourage pre-
treatment or recycling or correct identification of the waste
and correct disposal. Because no longer would the hauler have
this responsibility. It would not be a dead consideration.
Do you have any thoughts on that?
MR. TINMAN : Well, I am sure that the intent of the
legislation originally was to motivate source reduction. And
I think that is what you just said if we move it back to him.
Well, he pays it anyway. We collect it from the transporter,
but the transporter simply bills it back to the producers. He
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is paying it, whether he is paying it through us or directly to
the state.
I have no way of assessing what real effect it has on
source reduction.
THE CHAIRMAN: Mr. Kovalick.
MR. KOVALICK: From the audience.
If you get waste in drums, one, do you puncture them
or bury them whole, and, two, do you require a waste manifest
for it?
MR. TINNAN: Well, the second question first, yes, they
require a liquid waste manifest whether they come in bulk in the vacuu
truck or come in by drums, bottles or whatever have you.
The first part of the question is, depending upon the
nature of the material, we either bury intact or we will empty
the drums.
MR. KOVALICK: I suppose a logical follow-up on that
would be what do you do with the drums?
MR. TINNAN : Bury them.
MR. KOVALICK: Bury the empty drums?
MR. TINNAN : As some of the people have testified
earlier, if they would like these drums, we would be glad to
give them these drums free.
THE CHAIRMAN: I had a point of clarification from a
member of the audience. Perhaps you would like to comment on
this.
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As a point of clarification, both the State Department
of Health and the State Water Resources Control Board classify
chemical toilet waste as Group One or hazardous waste. There
are two chemicals on the market that are accepted. Do you
have any comment on that? I believe your testimony indicated
that it was not --
MR. TINNAN : Well, then that must be a change or a
clarification revision from our previous information.
THE CHAIRMAN: All right. Do we have any more ques-
tions?
Apparently not.
Thank you very much, Mr. TINNAN .
MR. TINIIAH : Thank you very much.
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THE B. K. K. CO.
3O3I EAST I STREET
WILMINGTON. CALIF. 8O744
830-7662 • 775-3607
December 15, 1975
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs (AW-565)
Environmental Protection Agency
Washington, D. C. 20460
Dear Mr. Lehman:
Our Company deeply appreciates the opportunity that it had to offer
its statement and views at the EPA's Public Meeting on Hazardous
Waste Management in San Francisco on December 14. We commend you
and your staff on your excellent handling of this highly important
and informative meeting. We hope that our statement contributed
information that will be of value in your continuing studies and
analysis.
In my haste to catch a scheduled airline flight at the end of the
meeting, I inadvertently failed to leave with you a copy of the
California State Water Resources Control Board document entitled
"Waste Discharge Requirements for Waste Disposal to Land," which
was entered into evidence as part of our statement. Therefore, I
am submitting a copy of this document as you had requested as an
enclosure to this letter.
As pointed out during our presentation, the B.K.K. Company is highly
active in the transport and disposal of hazardous waste in the west-
ern United States. The enclosed "Capabilities" brochure depicts
some of the B.K.K. operations, facilities and equipment engaged in
such waste management activities. We are particularly proud of the
Class I sanitary landfill which we operate in the City of West Covina
(Los Angeles County), California.
We believe that our West Covina disposal site—with its unique waste
sampling and handling procedures--may, in fact, serve as a "model"
for hazardous waste disposal operations elsewhere in the United
States. Further, the existing facility, its trained operational
personnel and associated equipment may well permit the site's effec-
tive use for research and development functions of current interest
to the EPA's Hazardous Waste Management Division. I and other B.K.K.
representatives currently expect in the Washington, D. C. area in
mid-January 1976. We would like the opportunity to visit with you
and other members of your Division at that time to explore the possi-
bility of applying our capabilities and physical resources to hazard-
ous waste problems of high current interest to the EPA. With your
1533
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permission, I will call your office shortly after the holidays to
schedule such meetings.
In the interim, should you require any additional data relative to
our San Francisco testimony or any other matter, please let me
know.
Sincerely,
THE^B.K.K. COMPANY
Leonard M. Tinnan
Technical Director
LMT: plb
Enc: Document and
Brochure
BROCHURE DETACHED AND RETAINED
IN SOLID WASTE MANAGEMENT FILES
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THE CHAIRMAN: I would like at this time to call Mr.
Glen Barlow, Citizens Against Pollution of Berkeley, California.
MR. GLEN BARLOW: Approximately three weeks ago a
Congressional subcommittee on health and the environment release
a report which was published in the mass media. This report
said that they now believe 70 to 90 percent of all human cancers
are induced by environmental pollution.
In the last 40 to 50 years hundreds and thousands of
nev; chemical formulas and products have been invented and
introduced into our environment. Most of these chemicals were
not adequately tested as to their effects on the ecosphere
before they were released into our environment. Also the
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ability of these products to react chemically with other
substances is not well understood, as emphasized by the
previous speaker's example of lemon juice and cyanide.
There are literally thousands, hundreds of thousands
of chemicals that are being poured into our air, into our water,
and into the land where there is no understanding of how they
are mixing with each other, how they are entering the food
chain, entering the agricultural products and other animals
in our environment. And through the food chain, entering the
human body and concentrating — even though they may — we
frequently see standards that allow minimum releases — as low
as practical releases — these are very small amounts. And then
they get into the water, into the plants, into the animals, and
they concentrate there. And then when they come into us through
the food chain they concentrate even more. And they are often
filtered out by kidneys and livers and concentrate there.
I would like to suggest that we are about to experience
a new national awareness of the health effects of hazardous
substances. And yet in this health subcommittee report which
I mentioned, it noted that American medicine says no adequate
means of diagnosing diseases that are caused by specific
environmental pollutants — and I think the significance of
this is tremendous. We are being exposed to all of these new
chemicals that have been invented and released into the
environment within our lifetime or within the last two
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generations. And yet the American Medical Association and the
National Cancer Institute are just at a loss to decide which
specific cancers were caused by which specific chemicals. And
the reason is that cancer does not have a little sign on it or
a flag saying this cancer was caused by this pollutant. Cancers
are there. They are caused by one of hundreds of thousands
of chemicals.
And I think that this is very frightening and the
potential consequences of this are enormous.
There was a meeting of the National Council on
Environmental Quality recently, and their report is in today's
Chronicle. They said that now the environmental pollution
control industry now employs one million people for environmenta
pollution control. And I think that with all our unemployment
and economic problems, what we should do and what this committee
should recommend in its report is that the Federal government
and state and local governments and industrial generators of
pollution and businesses that handle environmental pollutants
should look towards the future with an attitude of hiring and
employing even more people.
I xvas very impressed by the last speaker's suggestion
that perhaps the licensing of transporters and other people
that are involved with the handling of hazardous wastes is not
adequate on a state, Federal or local level. And I think that
this is very frightening. And I think that we need more and
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more people to be employed in the special field of handling
each pollutant and each chemical that we are having to deal
with.
I think one of the most frightening things about all
of this, and I do not mean to sound like an alarmist, because
I am really trying to be rational in my approach to all this.
I do have a medical background, and I was going to be a doctor.
And I think the really frightening thing is that
many times I have read and heard explained that a lot of these
chemicals will not kill you or cause you to get sick immediately,
but the thing is that they build up, they concentrate in the
environment, in the food chain, in our bodies, and over a period
of time -- which can be easily up to 20 years, 30 years or 40
years -- the concentrations build up. And then they cause
cancer. And by then, 30 years later, you do not know why you
are dying of cancer. You do not know which pollutant it was
that you breathed or ate or drank that has concentrated in your
body and caused the cancer.
And I think that we can no longer be so lax in our
controls and in our approach to environmental pollution.
Just because it is not killing off thousands of people
today or this year does not mean that it will not be killing
millions of people ten or twenty years from now or thirty years
from now.
I think that we really have to reevaluate all standards
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at all levels of what we are allowing and what the Federal
government agencies are allowing industries and business to
introduce into our environment.
Are we going to be known in the future as history looks
back at us and analyzes this period in our history -- it may
well be seen as the carcinogenic era. The cancer rates are
increasing tremendously. Lung cancer rates have gone up — I
forget the percentages. And almost every single kind of cancer
has increased in the last 50 years at an alarming rate at the
same time that all of these hundreds of thousands of new
chemicals have been invented and introduced into our environment.
And we think that we have such a high standard of
living. We often compare ourselves to other countries. And in
many ways the United States has many, many advantages supposedly
over other societies that are non-industrialized and undeveloped,
and yet perhaps we are going to have more cancers and more
deaths in the future from these environmental pollutants than
any other country. Maybe we have overdeveloped too quickly
without an awareness of what these pollutants and chemicals
can do to us.
And I am just asking the EPA to carefully reconsider and
reevaluate the entire system that allows industries to pour
pollutants into our air and onto the lands.
Thank you.
THE CHAIRMAN: Thank you, Mr. Barlow.
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Do we have questions?
Mr. Lazar.
MR. LAZAR: Mr. Barlow, in your statement you stressed
the difficulty of associating chronic health effects such as
cancer with chemical pollutants.
Do you feel that considerable research is required in
this area, and if yes, who should take that leadership?
MR. BARLOW: The National Cancer Institute has been
researching it, and I am sure many other agencies also have
been researching it for the last 30 to 50 years. And apparently
their research has not been enough. And my point is that we
can research and research and research for the next 100 years,
and it is not going to stop these industries from pouring the
pollution into the environment. I noticed recently the EPA has
finally added to its list of — all right, you originally
stopped DDT. Now it has taken years for the environmental defense
plan to persuade the EPA to finally ban aldrin and dieldrin and
chlordane and heptachlor. So there are now five
pesticides that are not going to be allowed.
But it took us how many years to reach this point
where EPA would finally bem those five pesticides? And we have
just thousands more that may be carcinogenic. And the point I
am making is related to that. The reason they did not ban these
pesticides before was because they said, oh, we need more
research. And the reason they are still allowing thousands of
152*0
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other pesticides and chemicals into our food and water chain
is because we need more research.
Now, the reason we are not banning aerosol sprays is
because we need more research.
Well, meanwhile, it is accumulating, and maybe we will
have increased skin cancer rates.
And my point is that can we in terms of public health,
can we afford to wait years and years for more research? Are
we going to continue to give the advantage to the industries
which are polluting or are we going to take a serious public
health stance and say that the burden of proof is on the
industry initially and that before any new chemical can be
introduced into our vast environment it must be proven beyond a
shadow of a doubt that it will not accumulate, that it will
not react with other chemicals and that it will not concentrate
in our food chain and cause cancers.
I do not think we can wait for research to prove it
and because of that just allow them to go ahead and pour the
pesticides on the land. And meanwhile we have waited — we hav
aldrin and dieldrin and chlordane and heptachlor. For
how many years did those poisons go into our food and water?
And finally the research proved that they caused
cancer.
MR. LAZAR: I understand that our principal and
criminal law, namely that a person is innocent until proven guilty does not
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apply to environmental pollution.
Is that what you are saying?
MR. BARLOW: Should not apply to industries and
corporations. And I will show you why.
I did some special research on the town of Minomota,
Japan, and I read a book which was recently published that was
written by Eileen and Eugene Smith who lived there for three
years.
In Japan the Keeso Chemical Company manufactured its
products, which released mercury into the bay. They started in
1925. And it was not until the '70's before it was finally
proven that the industry, Keeso, was the cause of the health
damages that were causing people in Minomota.
Well, what happened was, after years and years in
court, it was about a 15 -year legal court battle, the courts in
Japan decided that the Keeso Industry was responsible for the
health damages and deaths that had been caused by the mercury.
And they have to pay so many millions — I think it is $35
million at this point, and it is still going up — so many
millions of dollars to the people who suffered from their
pollution that it has put them bankrupt, and they are going out
of business. .
And there is a new law in Japan that makes — the
speaker before me was talking about liability. There is a new
law in Japan now that makes the chemical — and the industries
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liable for any health problems that they cause by their pollutio
And I think it is just incredible that we do not have a law
like that in this country. We need a law that makes the
industries responsible for any health hazards they cause. And
if it puts them bankrupt, then they should never have gone into
the business of poisoning our environment.
THE CHAIRMAN: Mr. Barlow, I believe we are getting a
little far afield from t he subject of this meeting which is
hazardous waste management.
Now, I am sure you are aware that the general thrust
of what you are saying is recognized by a number of people, and
the Toxic Substances Control Act which is pending in Congress
would address many of the points that you have made.
MR. BARLOW: Would it make industries liable?
THE CHAIRMAN: Well, that I am not sure of. But, sir,
the purpose of this meeting is to discuss hazardous waste
management and not the entire aspect of toxic —
MR. BARLOW: Well, you will be recommending new
regulations, I assume, will you not?
THE CHAIRMAN: Not at this time, no. You perhaps are
not aware that the Federal government does not have a regulatory
program for hazardous waste management.
MR. BARLOW: So here we are in 1975 without regulatory
control of hazardous wastes and without liability, that the
industries are not liable.
151*3
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THE CHAIRMAN: Well, sir, I do not want to get into —
MR. BARLOW: Are you saying that you are not going to
make recommendations for changes?
THE CHAIRMAN: Sir, I am not going to get into a
dialogue with you. That is not the purpose. I want to hear you.
opinions. We want to hear questions from the audience and from
the panel and your response to them.
Certainly the input of all the speakers will be gathered
and used in our work. That is the purpose of this meeting, to
gather input to our work which is to develop guidelines. But
you must realize that these guidelines are advisory and not
regulatory.
MR. BARLOW: I would just like to comment that a lot
of recent polls that have been in the mass media say that the
American people are losing faith in the Federal government.
And I would like to suggest that — I would really like to have
faith in EPA. I think of all the Federal agencies that we have,
that the EPA is most hopeful in helping us survive the
environmental crisis we are going through. But I mean, you have
to do something.
THE CHAIRMAN: Okay. Any other questions?
Thank you very much, Mr. Barlow.
I would like now to return to call on some speakers
who we called on earlier and who were not in the room at the
time.
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I would like to call upon Mr. James Burch of Project
Survival. Is Mr. Burch in the audience?
Please let the record reflect that a second call for
Mr. Burch has been made and that he has not responded and did
not present a statement.
I would next like to call upon Mr. Ron Eggers of
Alameda County, California. I gather, the Alameda County
government .
FROM THE FLOOR: The Planning Department is my under-
standing.
THE CHAIRMAN: Is Mr. Eggers in the audience, please?
Please let the record show that on the second call
Mr. Eggers was not in the audience and did -not present a state-
ment.
Ladies and gentlemen, that concludes the list of people
who have asked for time to present their statements to us.
I would like to page one last call for anyone who at
this time would like to make a statement before this panel.
Please let the record show that no one indicated an
interest in doing so. Let me remind you once again that written
statements will be accepted for the record until January 31st,
1976. So if as a result of these proceedings you feel you have
some information or wish to make some further input into this
process, we will accept written statements on that until
January 31st, 1976.
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I would like to thank all of the speakers. We heard
many thoughful presentations today. I am sure there was a great
deal of effort that went into the presentation of many of these
statements. And I want to give special thanks to the people
who did that.
And it is my hope that the audience received as much
valuable information from these presentations as we did. And
you can be sure that we will use this information as we return
to Washington and prepare guidelines on the hazardous waste
management issue.
And lastly, I would like to give special thanks to
the Region IX office for the administrative support that went
into putting together this public meeting here in San Francisco.
If there is no further business, I now adjourn the
meeting.
Thank you very much.
oOo
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WRITTEN COMMENTS
ON
HAZARDOUS WASTE MANAGEMENT
(Written comments submitted by any of speakers have been included
with their oral statement in these proceedings.)
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ALUMINUM COMPANY OF AMERICA
ALCOA BUILDING - PITTSBURGH, PENNSYLVANIA 15319
January 29, 1976
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs (AW-565)
Environmental Protection Agency
Washington, D. C. 20460
Dear Mr. Lehman:
The Aluminum Company of America would like to take this opportunity to
comment briefly on the questions of hazardous waste management posed in
the Federal Register, Page 42993, of September 17, 1975. Alcoa owns and
operates a number of aluminum refining, smelting and fabricating facilities
in many different locations in the United States. Each of these facilities
produce solid wastes of varying types, some of which would fall under the
classification of hazardous solid waste. Alcoa has been and will continue
to be concerned about the generation, handling and ultimate disposal of
these wastes. We offer the following comments concerning their management.
Alcoa feels very strongly that the regulation of solid and hazardous wastes
be retained on a state and local level wherever possible. Several states
already have developed or are developing regulations covering the management
of these wastes. EPA should give due consideration to these existing laws,
many of which contain good definitions of hazardous wastes, monitoring tech-
niques, and record keeping requirements. Although it is possible to categorize
some hazardous wastes on a national level, we feel that it would be unwise to
dictate handling and disposal techniques over such a broad area when disposal
conditions can vary greatly from one place to another.
Alcoa suggests that a reasonable set of regulations would cover the following:
1. Definitions of hazardous wastes, standard sampling techniques,
and analytical methods.
2. Provisions for permitting and licensing of generators and disposers
of hazardous wastes, including specific limitations of liability
for generators who chose to have others dispose of their wastes.
We feel that if generators of hazardous wastes are held liable
for the ultimate disposal of their wastes then there will be few
of them who will take the risk of allowing others to handle that
disposal. It seems more reasonable that when a licensed disposer
accepts shipment of a properly labeled hazardous waste he also
accepts liability for its proper disposal.
-------
Mr. John P. Lehman
January 29, 1976
Page Two
3. Provisions for proper and safe transportation, labeling,
reporting, and record keeping, both at the generation and
disposal points.
4. Provisions for proper monitoring by a local agency of dis-
posal sites to assure that hazardous wastes remain in an
environmentally acceptable condition. These methods
could include periodic inspection, groundwater monitoring
and permanent marking of the site.
5. Provisions for penalties for improper disposal of
hazardous solid wastes commensurate with the potential
clean-up costs and/or damage caused by improper practices.
In addition to the above, Alcoa strongly suggests that EPA fund and support
studies to better define hazardous solid wastes and disposal methods. Many
wastes which are now thrown away have potential fuel or chemical values,
or could be used to neutralize other hazardous wastes. The detailed source
inventory of generators of potential hazardous wastes would be of great value
to better determine what the problems are, where they are, and how they can
best be solved. There appears to be a growing effort in the private sector
to develop effective ways to reprocess and reuse waste materials. EPA activity
should be designed to encourage these efforts through realistic support programs.
Economic incentives are developing through the marketplace but additional
information services and R & D programs are needed.
We feel that the role of EPA should be one of research and broad supportive
regulation rather than specific limitations of operating practices. To this
end, Alcoa suggests that regulations requiring certain disposal or handling
methods for specific wastes should be avoided. Attainment of acceptable goals
can be made through proper permitting and monitoring procedures rather than
through dictation of operating practices. Certainly generators and disposers
of hazardous wastes would welcome suggestions which would lead to elimination
or reduction in waste generation, recovery of potential values in wastes, and
better disposal methods. They should, however, be allowed to choose the most
cost-effective of these methods commensurate with environmental acceptability.
Alcoa feels that this is an excellent opportunity for EPA to move slowly enough
and with enough scientific background to develop truly workable and acceptable
regulations dealing with hazardous solid wastes. We feel that EPA should take
an immediate role in funding basic research in this area. Only after the problem
is well-defined can it be properly regulated. We offer our full cooperation in
this effort and we will welcome an opportunity to supply more detailed information
at your convenience.
Very/^truly .yours,
3Lfa
Roy n. Carwile/^^
Environmental Control Engineer
RHC:vb
j.550
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AMERICAN CYANAMID COMPANY
WAYNE, NEW JERSEY O74TO
January 12, 1976
Mr. A. Corson
U01 M. St S.W.
Rm 2108 B
Environmental Protection Agency
Washington, D.C. 20k6Q
AW-465
Dear Mr. Corson:
American Cyanamid Company appreciates the opportunity to respond to
your request for comments on environmentally safe hazardous solid waste
management practices as stated in the Federal Register Vol Uo, No. 181,
September IT, 1975-
Cyanamid is a diversified manufacturer of agricultural, chemical,
consumer, and medical products.
Our sales in I9Jh were approximately $1.8 billion. While our
principal market is the United States, there has teen a continuing and
growing demand for Cyanamid products and technology throughout the world.
As a result, some 36 percent of our 197^* sales were made in more than 125
countries abroad. In addition, nonconsolidated, jointly-owned companies
outside the U.S. had sales of about $275 million.
Cyanamid employs more than 38,000 persons around the world. We
operate 59 plants and 6k sales offices in the U.S. Overseas, we have U2
manufacturing plants and 1*6 sales offices in 36 countries. Worldwide,
Cyanamid manufactures 2,500 products.
The following comments we have to make are answers to the questions
occurring in the Federal Register.
Question 1
To our knowledge the Environmental Protection Agency has not nor has
there been any authoritative evaluation and determination of which chemical,
physical or biological criteria should be used to determine if a material
should be considered as a "hazardous material" as far as environmentally
sound waste management practices are concerned. Therefore, we recommend that
each material should be individually reviewed by a panel of qualified experts
before being classified as a hazardous waste. These experts should review
the entire range of physical, chemical and biological properties of the
material that would make the substance hazardous to humans, animals or the
environment. As well as considering these properties the quantities necessary
1551
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-2-
to produce adverse effects on human, animal life or the environment need to
be determined. Also the circumstances of disposal need to be considered.
It is possible that large quantities of some hazardous substance could be
disposed of in a land fill in an environmentally safe manner by proper
packaging and sealing of the hazardous materials.
Question 2
Below we have outlined the areas of responsibilities, costs to be
borne by, and liabilities to be assumed by waste generators, waste treaters ,
and ultimate waste disposers. Cyanamid believes the environmentally safe
disposal of hazardous wastes involves the clearest possible spelling out
of the responsibilities of each waste manager, i.e. generator, treater, and
disposer.
Each waste manager must be directly responsible for his own costs.
Some governmental assistance in the form of grants, tax incentives, etc.
may be necessary to assist waste treaters and ultimate waste disposers to
develop new technologies. We also believe that each waste manager should
assume complete liability for his portion of the waste management process.
WASTE MANAGER
W '•.e Generator
RESPONSIBILITIES
1. Characterize waste
COSTS ASSUMED
All Costs
LIABILITIES
Spill prevent
& control
liabilities
Waste Treater
2. Assures waste hauled by
responsible parties
3. Provides safe handling
safeguards
1. Uses currently economically
available technology
All Costs
All Costs
All Costs
Spill prevent
& control
liabilities
2. Verifies character of received
wastes
3. Control emissions/effluents
h. Characterizes treated wastes
All Costs
5. Researches and evelops new
treatment technology
Receives grant
assistance
1552
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-3-
ASTE MANAGER RESPONSIBILITIES COSTS ASSUMED LIABILITIES
Itimate Waste 1. Uses currently economically All Costs with Full liability
isposer available technology and some grant assis- for waste
practices on landfill site. tance accepted
2. Monitors facilities for All Costs
environmental impact
3. Researches and develops Receives some grant
new disposal technology assistance
Question 5
To our knowledge, reliable cost data are available for only very few
processes and techniques for disposing of hazardous wastes. Hazardous waste
disposal data will remain inadequate until major efforts are made to iden-
tify and characterize these problems.
The above cited Federal Register notice states that the Administrator
wishes to gain a better national perspective on needed guidance for the
proper management of hazardous wastes. The proper management of hazardous
wastes does require the proper regulatory environment, therefore, we offer
the following guidelines that should be followed in developing sound
regulations for the environmentally safe disposal of hazardous solid
wastes.
The Heed for a Technical Advisory Committee for Input of Industry Expertise
to Establish Environmentally Safe Hazardous Waste Disposal Management Practices
The Environmental Protection Agency should establish a Technical
Advisory Committee having among its members industry representatives from
industries having hazardous waste disposal expertise. Such a committee could
be of valuable assistance to the administrator in such critical areas as;
identification of proper criteria for identifying hazardous vs. nonhazardous
wastes and identifying the proper techniques and practices for disposal of
hazardous wastes.
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-k-
Hazardous Waste Disposal Sites^
Proper hazardous waste management practices should include the funding
and acquisition of a national system of regional (state) hazardous waste dis-
posal sites. Logically the program should encompass:
(l) Designation of disposal sites
(2) Promulgation of standards for designated sites
(3) Enforcement of standards allowing sufficient time for owner-
operators of such sites to develop and implement the necessary
control technology.
Such a program would assure waste generators of a place to dispose of their
wastes and prevent regulatory agencies from prematurely closing sites before
corrective technology was developed or safe alternatives found for disposing
of hazardous wastes. It is important in the regulatory process that site
designation precede standards and enforcement. Industry came close to an
almost catastropic situation in New Jersey when the State failed to approve
the monitoring systems in use at existing disposal sites and consequently
the sites were required to close. Fortunately, the State lifted its deadline
for closing the disposal sites allowing their continued operation.
Heed for Research and Development Grants to Assist Ultimate Waste Disposers
of Hazardous Wastes to find Environmentally^ Safe Disposal Practices.
Due to the vitality of American industrial ingenuity thousands of
new products are produced by American industry each year. An environmentally
safe disposal method outside of landfilling may not exist for some of these
products which are socially desirable to produce. A safe method of disposal
may have to be researched and developed. Environmentally safe disposal
management practices should include research and development and grant
assistance to ultimate waste disposers for these products.
Technology
Environmentally safe has;ardous waste disposal management practices
should be based on currently economically available technology where possible
but these practices should include incentives (tax, direct finding, bond
issues, etc.) to ultimate waste disposers to assist them in finding technical
solutions to their problems. The use of such techniques as "waste exchange"
(one manufacturers waste is anothers feedstock), recycle of wastes, energy
recovery and application of technology transfer techniques should be
promoted by incentives (tax, grs.nts, etc.).
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-5-
Cost/Benefit Consideration Where a Socially Desirable Product may Generate
Hazardous Wastes Which may Present Disposal Problems
Environmentally safe hazardous waste disposal management practices
should include, before banning a product from land disposal, the weighing
of cost/benefit relationships including economic and social benefits as
well as environmental impacts where the manufacture of a socially desirable
product involves creating potentially hazardous solid waste which has no
economically feasible alternative to land disposal as a means of ultimate
disposal.
We urge your careful consideration of these recommendations.
Very truly yours ,
C. P. riesing
Director
Environmental Protection
Department
CPP:tp
1555
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Phone (OR) 503 752
(AK) 907 225
Beaver Buildings, Inc.
Fabricators and Erectors of STEEL SPAN Buildings
(X) P.O. Box 804
3410 S.E. Van Buren
Corvallis, Oregon 97
( ) P.O. Box 1271
Ketchikan, Alaska 9'
November 25, 1975
Mr. Edward Tuerk, Assistant Administrator
Air & Waste Management
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Tuerk,
I am in receipt of your mailing of the Federal Register of 17
September, 1975, concerning hazardous waste management.
In as much as I am unable to attend the scheduled hearings, I
must comment via this letter.
As we review the problems created by wastes and their "disposal"
or lack of disposal, it would be appropriate to present a
"financial impact statement" with the proposed disposal system.
Environmental, political and social impact statements in other
areas are beneficial in allowing the appropriate agency to
study, in more depth, the ultimate result of a given ruling
or decision.
As we look for better systems of waste management each industry
affected must accept the cost thereof, It then becomes obvious
that these additional costs must be passed along to the con-
sumer. Rather it be additional cost per quart of milk for the
daryman; cost per tire for the tire manufacturer; cost per
automobile for the steel manufacturer.
We have made voluntary improvement in automobile exhaust
emissions; much to the approval of the general public. How-
ever; considering that we have nearly doubled the fuel con-
sumption; can we as individuals or as a nation, really afford
such a radical improvement?
Vy suggested financial impact statement would allow our
consuming public to see the impact expressed in terms that
are meaningful to each and every citizen.
I do appreciate you attention to my suggestion.
1556
C. Davis
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INtRAL AND WEST BASIN
WATER REPLENISHMENT DISTRICT
LLOYD C LEEDOM
7439 BAST FLORENCE AVENUE CHARLES D. BARKER,
. *.. iwrarwrw r>ATrom>ivTA ot»An D. w. FERGUSON,-I
ft'*"»»Jg DOWN BY, CALIFORNIA 90240 RUSSELL L. HARDY
TELEPHONE 927-2611 « 773-5790 ""S A- CROCHET
•
JOHN G. JOHAH, JR.,
January 16, 1976
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs
Environmental Protection Agency
Washington, D. C. 20460
Subject: Hazardous Haste Management
The Central and West Basin Water Replenishment District is charged with the
responsibility for management and protection of the ground water resources in
the Central Basin and West Coast Basin in the Los Angeles, California area.
These ground water basins provide a major portion of the supplies to approxi-
mately three million persons.
Our major concern with respect to hazardous wastes is that they be managed in
a manner consistent with elimination of the risk of degradation of ground
water resources. Accordingly, we believe that the following principles should
be observed:
(1) Although all elements of the environment should be protected
from possible damage from discharge of hazardous wastes in
inland areas, the number one priority must be the protection
of fresh ground water resources which are used as a source of
domestic water.
(2) Under no circumstances should hazardous wastes be disposed of
in a manner where they could reach usable ground water. In
particular, no site should be considered for the land disposal
of hazardous wastes unless engineering and geologic evidence
has clearly demonstrated beyond a doifct that there is no
possibility of hydraulic continuity between the disposal site
and usable ground waters.
(3) Hazardous wastes should be excluded from any waste water system
the effluent from which may contribute to ground water (either
under a planned reclamation program or under conditions where
incidental and unplanned recharge of ground water occurs).
We wish to express our appreciation for being provided the opportunity to pre-
sent our views on this very important subject.
John G. Joham, Jr.
General Manager
JGJ:ab
!5bT
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CHAUTAUQUA COUNTY
DEPARTMENT OF PUBLIC WORKS
DIVISION OF ENVIRONMENT
Memo to: Mr. John P. Lehman
From: Kenneth Fladie
Date: January 29,1976
Re to: Letter of January 23,1976.
The letter addressed to you of January 23,1976, was prompted by an
article found in the Federal Register of Spetember 17,1976. This article
referred to the newly proposed Hazardous Waste Act.
I hope this will verify .any questions you may have had about the recent
letter. If there is any further questions please feel free to contact me.
1558
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CHAUTAUQUA COUNTY
DEPARTMENT OF PUBLIC WORKS
DIVISION OF ENVIRONMENT
phone (716) 753-7111 Ext. 271
January 23,1976
Mr.John P. Lehman
Director, Harzardous Waste Mgm't Division
Office of Solid Waste Mgm't Programs (AM-565)
Environmental Protection Agency
Washington, D.C. 20U60
Dear Mr. Lehman:
This letter is relatively short, not because of the lack of
available content, but rather to concisely highlight the issue. I
am an appointed administrator-engineer with the County and have been
put in the dubious position of working out the industries' hazardous
waste disposal problems. I speak from a knowledgable, non-emotional
stance.
Prior to the environmental consciousness, the waste (paint thinner,
waste wash solvents, paint sludges, cutting oils, grinding coblants, alka-
line cleaner sludges, and trichloroethylene sludges) were disposed in the
City of Jamestown landfill. Waste treatment sludges (metal hydroxides)
were not yet on line. Now these are not allowed to be arbitrarily "dumped"
at the landfill sites. The costs, controls and ambiguous or non-existent
regulations for land disposal of these wastes make it difficult to go this
route.
Hazardous Waste Management Facilities are available: however, for
our non-metropolitflncounty, the nearest site is nearly 100 miles away,
1559
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and the average costs for disposal comes in the range of $15 to $20 per
drum. This impalatable cost includes barrel costs, transportation and tae
facility cost. The reaction of industry is strong.
Thorough, practical research, which will render results?usable
yesterday, is needed. Means of incorporating local, decentralized disposal, or/
and reuse sites should be included in this research. Therefore the PARAMETERS
are COSTS, ENVIRONMENTAL CONTROL, and DECENTRALIZATION (to reduce costs).
Note; I have included a schematic of a potential system which might accomplish
these aims. It is modular and simple, however; research into economics,
markets of products and the ability of the clay to really lock in the heavy
metals is needed.
Respectfully
Kenneth Fladie
Director, Division of Environment
Department of Public Works
KF:beb
enc.
15SO
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CONSERVATION CHEMICAL COMPAf*
215 W. PERSHING RD., SUITE
KANSAS CITY, MO. 6
December 29, 1975 Area Code 8i6-42i-
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Program
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Lehman:
Due to the pressures of operating my business, I could not personally
attend the meeting held at O'Hare Airport on December 4, 1975. I wish
to make a statement directed to some of the questions raised in your
Notice of a Public Meeting, Federal Register, Volume 40, Number 181,
Wednesday, September 17, 1975, page 42993.
Although small, our firm is well diversified in the field of environ-
mental services. We treat hazardous wastes prior to landfilling, re-
cycle wastes for return to commerce, manufacture and supply waste
treating chemicals, operate in a number of states and regions, and
have perhaps the longest history of waste detoxification of any other
firm established in the United States. Economic pressures generated
by the general decline in the economy, but principally due to severe
competition from landfill operations, threaten the viability of our
company. Based on my past experience of sixteen years in this field,
I sincerely believe that the private sector cannot provide adequate
facilities for landfilling of hazardous wastes. I believe a federally
regulated and federally owned facility can best do this specific job.
The facility could be operated under contract to a chemical firm
specifically qualified for these functions. This is somewhat analogous
to operation of ordinance plants by various private firms. I further
suggest that there are many obsolete ordinance facilities throughout
the country that have ample room for the construction of such regional
hazardous landfills.
My reasons for reaching this conclusion follow:
1. Our competitive free-enterprize system is based on the principle
that lowest priced contractor generally gets the business.
Interpretation and enforcement of environmental laws for hazardous
landfills from state to state vary substantially. The reality of
what actually goes into the fill is such that the operator that
cuts the most corners very often winds up with the most business.
At one point, a regulatory official might pounce on excessive
sulfates and at another location, all varieties of organics,
1562
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-2-
heavy metals, etc., are dropped into gravel beds and ravines. Even
where regulation is fairly uniform, there is no provision in the
financial structure of the landfill operator to secure the landfill
after revenue ceases or provide burial custodial care after the
landfill is "capped off". Is provision made if the property is
abandoned? Should care be provided for 10 years, 50 years, 1,000
years?
2. The private landfill operator could wind up in control of all the
waste business. Through discriminatory pricing, delays in acting
on requests to receive materials generated by a recycler by requiring
greater detail and assays, sampling, and pre-treatment; the recycle-
oriented company is at the mercy of the landfill operator. Even
discriminatory limited hours for access by outside vendors creates
economic pressures.
3. Illegitimate disposal of highly toxic wastes is highly lucrative.
Economic pressures or economic incentives are so great that localised
policing is not effective. Wastes can be and are hauled across state
lines. To my knowledge, once the material leaves a state, there is
no accounting for it. I believe many of the laws and regulations
were developed more for the garbage and domestic wastes which
generally are short hauls. The handling of wastes are not fully
delineated in regulation. In one Solid waste Management Law, there
is no mention of the word "liquid" nor a specific language,or guide-
line for pre-treatment of liquids prior to disposal.
In your discussion topics, you have raised many good questions. Some of
which I would like to make a contributory answer. However, economic sur-
vival of my company commands most all my energies. Until a regulatory
climate prevails that will ensure survival of waste treatment operations
(as opposed to only landfill operations), the questions you raised are
irrelevant.
In addition to recommending federally owned and regulated regional hazar-
dous landfill sites, I would like to make two other suggestions:
1. Regulatory officials apply a chemical engineering principle of mass
balance in understanding the chemistry of a given region. That is,
chemicals coming into a region can generally be determined, accounting
for their usage and ultimate disposition should be done to a degree.
This-principle is used at a unit or plant level by professional
engineers.
2. Supplementing an existing law, regulatory people should develop an
index of priorities in tackling waste problems. Specifically,
every waste has a specific relative toxicity to all other wastes.
The mass of this specific component in a given environment can be
determined. The cost to detoxify or remove the specific waste
from the environment can be determined. A term, which I will call
a "priority factor" is the product of the relative toxicity of the
waste times its mass divided by the cost to treat. A waste with
a high "priority factor" would be very toxic, there would be a lot
of it, and it would not cost much to treat.
1503
-------
-3-
To illustrate what I mean, there is a community where unregulated dumping
was permitted in ravines and gravel pits. One owner with good financial
resources and a strong public consciousness removed toxic material down
to fractions of parts per million. Meanwhile, years later, the owner
across the road has done absolutely nothing and probably never will. We
live in a society with a finite ability to meet its social obligations.
Here is a very obvious face-to-face example where taking the very worst
wastes that were easy to pick up should have been done on either side of
the road. There are many examples in the country that are by no means
as obvious.
I feel your forum will be constructive to achieving a higher quality of
our environment. I have come to realize that I cannot achieve my own
objectives by working only within my own company. Hence, I would be
very glad to support your program in any way I can.
Yours very truly,
Nornfan "B. Htersted '
Professional Engineer and President
gc
Francis T. Mayo, Regional Administrator, Region 5
Kansas City Regional Office, Region 7
1561*
-------
'AST
COUNCIL FOR AGRICULTURAL SCIENCE AND TECHNOLOGY
encan College
/eterinary
cicologists
encan Forage and
ssland Council
erican Meteoro-
cal Society
erican Society for
ticultural Science
erican Society
Agricultural
lineers
erican Society of
onomy
lencan Society of
mal Science
ociation of Official
d Analysts
incilon Soil Test-
and Plant Analysis
p Science
.tety of America
iltry Science
Delation
•al Sociological
lety
tety of
natologists
I Science Society
America
jthern Weed
ence Society
ed Science Society
America
December 1, 1975
Agronomy Department
Iowa State University
Ames, Iowa 50011
Phone 515-294-2036
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management
Program (AW-565)
Environmental Protection Agency
Washington, D. C. 20460
Dear Mr. Lehman:
This is in response to the announcement of the public meetings you
will be holding on hazardous waste management.
The Council for Agricultural Science and Technology, which is an
association of agricultural science societies, does not wish to present
a prepared statement because the subject is so complex and extensive
that a substantive statement on the total subject would necessarily
be very long and involved.
We do, however, wish to call your attention to the fact that the
problems you are considering are relevant to agriculture and soil sci-
ence and that we have the capability of calling on all the scientific
disciplines that can contribute factual information on which a reasoned
decision can be based. When specific questions are under consideration,
we hope you will call on us to respond.
Sincerely yours,
Charles A. Black
Executive Vice President
cc: M. Stelly
C. E. Howes
B. P. Cardon
dk
1565
-------
CITY OF DALLAS
December 18, 1975
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs (AW-565)
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Lehman:
This statement is being submitted pursuant to my attendance at the public hearing
on December 9, 1975, held at Houston, Texas, for the purpose of considering
hazardous waste management regulations.
There was considerable testimony relating to the need to increase enforcement on
generators and transporters which, to me, fails to address the key problem --
namely, the need to establish a suitable network of approved facilities to which
the regulated wastes may be routed.
Until we unlock the problem of acquiring sites for safe and adequate disposal,
efforts to increase pressure on generators and transporters -- illegal disposing —
will not, as a practical matter, be productive.
In my view, there must be at least moral support by EPA of state, regional, and
local efforts to establish proper sites because much of the opposition to such
sites comes from people who rather diligently follow EPA publications and infor-
mational releases. It is essential that minor imperfections or questions regarding
site characteristics not be permitted to continue to frustrate efforts to establish
adequate sites. Total perfection is an elusive goal -- we have not abandoned the
automobile in American life although it is a deadly killer; however, we are in-
stantly ready to condemn a site application over a minor flaw although the degree
of hazard from the entire program has thus far been rather limited on its impact
on American society. We must begin to make progress on this problem without
further delay over minute objections based on relatively minor and emotional reasons
I think EPA must provide the national climate of understanding and reasonableness
that will help temper opposition to adequate sites with a practical degree of
tolerance that will allow a badly needed site network to be achievable.
Sincerely,
John A. Teipel
Director
DEPARTMENT OF STREET AND SANITATION SERVICES 272 LMy^lGlf AL STREET DALLAS. TEXAS 75215 TELEPHONE 214 / 748-9711
-------
John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs
Environmental Protection Agency (AW-55)
Washington, D. C. 20460
r* *
" ~:3;.Q f,'C?"C)1
gj;p f__ ;f:^.^) J\. 1
DEAR MR. LEHKAN: Pursuant to the hearings Thursday, December 11, 1975 in
San Francisco, the following comments are for your information and consid-
eration:
It is disconcerting that staff of this organization sustains sub-
stantial demoralization -- and from listening to serial discrepen-
cies set forth in testimony one can understand why being able to
do nothing takes its toll.
Strong reason exists to eliminate duplication of costs throughout
all strata of responsibility regardless of locations T services, agencies.
The remarkable emphasis on "technology" more as ends in itself than
as means to ends is disjointed on various counts'. 1) Although they
usually receive only scorn and disdain individual innovators could
contribute substantially to this aspect of environmental management
at costs vastly less than that farmed out to the proprietary biggies
with their toes in the various federal doors — as Lockheed heavily
subsidized with mismanagement and bailed out for its contract fail-
ures represents; 2) Qnphasis and support properly accrue to these
individuals ~ not with the idea of forcing them to give the govern-
ment their patents or products but with the specific focus of getting
the best equipment for the job in the most efficient fashion; J)
This could be done in the manner hearings were conducted and legal
or other routine elements represented toward coordinate ends and im-
plementation! 4)Eliminate impedimentia from business routines, for
example, tax exempts deadweight legitimate business at the hazard
of independent businesses and needs to be stopped; 5) Prevention needs
attention and instrumentation with violations and enforcement costs
placed with violators — not people victimized and currently comman-
deered to subsidize what no body wants.
EPA frequently finds itself committed to proper action only to have
an issue diluted or virtually removed from corrective or preventive
action. How can presentation of indirect costs which take heavy
costs, as an example, be used to reinforce such cases?
I find it disillusioning to see pork barrellers in action — and wonder
why a munitions cleaning operations especially for national operation
isn't located where munitions manufacturers are. Why isn't this kind
of activity billed to munitions makers who alone profit from that stuff?
I think it makes sense to do a forum dispersing such information about
firms as Zero Waste Systems and studies such as that done in Berkeley
a couple years ago called A Technical and Economic Study of Waste Oil
Recovery.
Nothing is free — and waste, hazard, degredation cost more than the
sane options to prevent or to deal with them. This emphasis seems
lost to convenience, status quo, let John do it, and other impossible-
to-sustain mind sets.
How does anyone find out true extent ~ in dollars, types, volume, and
destruction — hazardous wastes prevail? Often recitals not only seem but
obviously are phoney. How could EPA use or coordinate such economic in-
formation as that composed by the Council on Economic Priorities in this
domain? So much cost information maintains "our figures" devoid of either
cogence or accuracy and out of context or tiny domains leave much to be
desired, now can you emphasize that it pays to prevent, to not despoil,
to not generate hazard?
156? December 31, 1975
-------
Robert Gartner
6319 Sheringham
Houston, Texas
January 16, 1976
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Environmental Protection Agency
Washington, D. C.
Dear Mr. Lehman:
As an employee of Houston City government in the Water
Pollution Control Division of the Health Department, I feel
I have certain possibly useful comments to offer on the sub-
ject of Hazardous Waste Management. I speak also with a know-
ledge of other local and statewide regulatory activities and
existing lasw pertaining to waste control. Environmental con-
cerns have long been my interest.
On this subject of Hazardous Waste Management I have strong
feelings that existing incentive in the form of legislation is
grossly minimal. Specifically, existing laws addressed to solid
waste disposal seem insufficient. Officers to enforce these laws
are in short supply. Our division employs only one person for
supervising solid waste disposal activities both authorized and
non-authorized for the City of Houston.
I see P. L. 92-500 creating violations to the earth. Our
city has a sanitary sewer water discharge standard that roughly
paralles Texas state standards. As enforcement toughens, many
will obviously seek the evasive solution of dumping. I have
witnessed two such places in Houston last month where a disposal
tank truck drained it's liquid waste onto the ground. These wastes
contained high quanties of oil and heavy metals.
It is my understanding that solid waste authorized landfill sites
are classified as to what they can handle. In Houston, I see the
possibility of many violations of landfill laws. Houston has fire
breaking out nearly once a month at one landfill with which I'm
familiar and that means air pollution!
As to solutions, I find it difficult to address myself to the
list of questions for which you have so kindly solicited input in
the September 17, 1975 issue of the Federal Register.
One solution for which I feel might be effective on some points
is one which Texas recently adopted requiring "trip tickets" of com-
panies involved with generation, transportation and disposal of wastes,
15&8
-------
Page 2 January 16, 1976
After hearing input at the public hearing you held at the
Holiday Inn in Houston, December 9, 1975 I learned that private
Companies who treat wastes indicated positiveness in their ability
to detoxify various industrial liquid wastes. One concern of theirs
was what to do with a small quantity of a product of detoxification
as a marketable substance like methanol. These Companies also indi-
cated that defining incoming wastes could be greatly simplified be-
cause very often the generating industry has a good knowledge about
them. I feel this could be true.
As to your Question #3, I don't know enough about the various
wastes and their characteristics, but I feel that all these alter-
natives you mentioned should be considered in dealing with a waste.
As to people who transport wastes I feel that they should be
liscensed. This should include septic tank cleaning companies so
to dissuade them from shipping other types of wastes to places other
than an appropriate disposal sites.
I would like to add an opinion as a member of the Houston Group
of the Sierra Club and say that the Club is concerned with the health
aspects in all areas involving toxic waste substances.
If I can be of any further assistance please contact me.
Thank you again for the opportunity to participate in the ana-
lysis of the question of hazardors waste management.
Sincerely,
Robert Gartner
1?69
-------
Environmental Activities Staff
General Motors Corporation
General Motors Technical Center
Warren, Michigan 48030
January 29, 1976
Mr. Walter Kovalick
Office of Solid Waste Management Programs
U.S. Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Kovalick:
Enclosed is a text of a presentation made by myself at a
Hazardous Waste Conference sponsored by the Michigan De-
partment of Natural Resources January 28, 1976. Basically,
the text calls for rules and regulations which will en-
courage risk venture capital to enter the solid waste
processing business, presenting waste generators a choice
of vendors who will provide a level of service and cost
choice to the generator.
I have been told that this text would be of value if sub-
mitted for the record as comments for the Public Meetings
on Hazardous Wastes as announced in the September 17, 1975,
Federal Register. This copy is submitted for that purpose.
Very truly yours,
D.. Vanzle, Manage
Power Systems & Resource Recovery
Plant & Environmental Engineering
DKV/rw
enc.
-------
Michigan Department of Natural Resources
Hazardous Waste Seminar
January 28, 1976
Speaking Text
Good morning Ladies and Gentlemen. It is an honor to share
the podium with such distinguished company, and I appreciate
the opportunity to present the viewpoint of one industrial
representative. I represent a generator of waste which may
or may not be hazardous. These are my views:
In my home my wife prepares food and generates food wastes;
my son pursues his photography hobby and generates chemical
wastes; I fertilize the lawn and spray the trees and generate
pesticide wastes; I paint the house and throw away the cans
with paint residues. At home I generate maybe a ton of wastes
a year, some of which may or may not be hazardous. These
wastes are collected by a private firm-in compactor trucks,
and the wastes disappear and I never have to worry about
them again. In truth, these wastes go to a landfill. The
only processing is some compacting.
Then I go to work. The average worker in my company generates
approximately ten tons of waste a year -- the byproduct of
his efforts to earn a living. Should the photographic chemi-
cals, the fertilizer and pesticides, and the paint residues
from one industrial worker be treated any differently than
the street collected residues from ten people at home? In
many instances I believe there is a tendency to recmlate
the disposal of some industrial wastes solely because they
1571
-------
are easy to control when, in truth, these wastes could easily
be landfilled with the similar wastes from street collections.
Far better that we regulate the construction of landfills so
they can safely accept most wastes. They should be sealed and
then industry and commerce can dispose of many of their wastes
along with the balance of the community. I maintain that onl-y
a small percentage of industrial wastes should be subjected to
special controls.
I would like to discuss the special controls in use in General
Motors plants. First, before we ever worry about hazardous
waste disposal, we must back down the line to materials pur-
chased and brought into the plant. The principles here apply
to all industry, large and small. Prior to purchase of any
new material, some basic questions should be asked:
"Does this material represent any type of a
hazard to my employes or to my facility?"
If the answer to that question is "yes," that material should
be identified, if only on a little 3" X 5" file card. Verbal
instructions and trusting to memory are inadequate procedures
when your facility or your employes are endangered. Key em-
ployes get sick and take vacations. 'Therefore, a written instruction
however brief, is necessary for hazardous materials identifying
*Too often, after an accident, we hear that the employe making
the mistake was new and inexperienced.
1572
-------
the material, the hazard, and proper procedures for handling,
storage, use, and disposal.
Of course it makes sense that once you have identified a
material as hazardous, you might want to consider a substi-
tute that presents no hazard. Regarding substitutes, I'm
reminded of a series of Burma Shave roadside signs I once saw:
SUBSTITUTES LIKE UNKNOWN BARTER
OFTEN MAKE ONE SAD BUT SMARTER
Hopefully, substitutes won't make you sad but smarter; but
you should always evaluate a non-hazardous material for the
first chosen material which is hazardous.
A second principle for industrial materials, hazardous or not:
Don't discard the residue.
If the difference between profit and loss to a butcher is to
get everything out of the pig but the "oink," how can we in-
discriminately waste materials? Over 50 percent of the waste
from GM plants is recycled directly into another GM plant or
sold for reuse by someone else. I've been told that in the
early days, Henry Ford specified the size of the wooden
packing crates his parts came in. Then he tore the crates
1573
-------
apart and used the wood for floor boards. Unique, cost
savings, sure! And he didn't have a wood waste disposal
problem either. Here in Detroit, in those same early days,
the boilers at Fisher Body-Plant 21 were fired with wood
left over from manufacturing wooden bodies. Later that
plant took over the wooden die and pattern making responsi-
bilities and the boilers continued to use wood as a fuel
until very recently. Are equal cost savings measures availa-
ble for solid waste that might be deemed hazardous? I be-
lieve so. Last year GM plants burned over 4 million gallons
of oil and oily sludges; this waste was used as a fuel in
our boilers. Our Chevrolet-Livonia plant uses waste pickle
liquor for cleaning prior to some plating processes. There
are some instances where ways can be found to utilize a waste
to advantage; it is always worthwhile to look for that possi-
bility. But recycling and resource recovery must be thought
of as volume reduction methods. There is almost always some
residue that must be disposed of.
We must never lose sight of the lona-term advantages
that accrue to volume reduction of waste. The same amount of
waste in a smaller volume must be more highly concentrated.
Thought of in terms of a raw material (or ore), the more con-
centrated the ore, the better chance it can be utilized in a
material resource recovery scheme. I'm particularly concerned
about liquids and chemical fixation processes. In most waste
I57»t
-------
liquids there is water and a contaminant. Where the water
can be evaporated off, leaving a concentrated solid contami-
nant, that solid can be easily handled, stored, accumulated,
and at some later date, reused. Chemical fixation processes
add materials to pumpable liquids, utilize time, energy, costs,
and raw materials to process one waste into a larger volume
of waste, and preclude any future hope of materials reclamation.
It is my belief that chemical fixation should never be required
by regulation and that chemical fixation should be used only
as an interim measure by waste generators and waste processors.
I've just introduced a new concept in this discussion —
Waste Processors! Who handles your waste? We are very
fortunate in Michigan, and particularly here in the south-
eastern corner, to have a wide selection of firms that
specialize in waste processing. Most regions of the U.S.
are not that fortunate, and many wastes that should be specially
treated are dumped elsewhere on the ground. Waste processing is a
highly specialized industry that has received too little
positive help from Government. Industrial firms with a
conscience (plus industrial firms stomped on by regulatory
agencies) are the bulk of the customers of these few firms
that specialize in waste processing. Those private business-
men that have invested money in facilities to treat waste have
ventured into a risky business, and they are generally in need
1575
-------
of help across the country today. They have too few customers,
too high an operating cost when compared to just plain dumping,
and too many complaints from neighbors because it is an un-
sightly business. Necessary — but unsightly! To compound
their problems, there is Eilways the uncertainty of Government
action. Would you be willing to gamble your livelihood on a
business dependent upon industrial customers willing to patro-
nize you at higher costs merely because of their conscience?
You are dependent upon Government regulations to increase
your business and bring in more customers, but fear that
Government action may also go into direct competition with
you or class your business as a polluter and shut you down.
As I said, we are fortunate here in southeastern Michigan
with several firms in the waste processing business. As
one citizen concerned with the environment, I would like to
see more incentive nationwide for others to go into the waste
processing business. It has been said that the lawyer who
defends himself in court has a fool for a client. He should
hire professional, objective council. The waste generator
likewise; is often well advised to hire a professional, ob-
jective waste processor.
Government regulation of waste management is necessary.
Too many people would foul their neighbor's nest if some
form of regulations did not exist. Moreover, Government
1576
-------
regulation must not begin and end with street collected
residential refuse. All refuse must be regulated: Resi-
dential, commercial, and industrial. And prior to regu-
lation must come planning. In some states, New York State
for example, industry is given no consideration in waste
management planning. I've seen municipalities vote to align
themselves with the NYS Environmental Facilities Corporation,
an authority for waste management. The first action of the
authority was to take over all local landfills and decree
that due to limited life, no industrial waste would be ac-
cepted. Remember -- an employe generates more waste at
work than when he is at home. It is not a very forward
looking Government that fails to make provisions for a worker
to earn a living. Solid waste planning must include all
waste from all sources: Residential, commercial, and in-
dustrial. And it must include all wastes, including hazardous
and toxic wastes.
Upon conclusion of the planning, there must be some action;
and by action I mean regulations and policies. I surely
wouldn't interpret action to mean direct Government operation
of the solid waste processing plants. I would hope that as a
result of the current planning in Michigan, there would be
action which would encourage risk venture capital to enter
the solid waste processing business. Those firms already
1577
-------
here should find encouragement to improve their operations,
and I believe there is room for others to enter the business.*
Equally important, all waste generators must be treated
equally. There must be consistent regulation for everyone.
A generator likes to see a selection of vendors, such that
he can choose a level of service and cost. Please don't be-
lieve that because GM is big, we can afford to spend more
for waste treatment than everyone else. Our GM plants are
run each like a small business. Each plant manager is held
accountable for his operation; he must produce a product and
make a profit just like any other small businessman. And
small business or large, quantity of waste does not change
toxicity or hazard. What a difference — ten pounds in one
day or ten pounds in ten days? All I ask is consistent regu-
lation for all waste generators; I believe that stability
in regulatory action is required to protect the environment,
particularly when considering hazardous and toxic wastes.
*(An example of the type of Government regulation of hazardous
waste which would benefit generators and waste processors a-
like was cited today by John (Jack) Lehman of the Federal EPA.
If, by regulation and law, the waste processor takes full title
to the waste and full responsibility for the waste at the time
he removes it from the generator's property, he has a selling
point that will cause generators to utilize his services.)
A waste generator who contracts with a processor licensed by
the state should be able to depend upon the state licensing
powers to guarantee that the waste processor is competent and
qualified and that the generator will be relieved of any fur-
ther legal liability. In today's climate, the generator is
never fully relieved of liability, even after paying top dol-
lar for treatment to a licensed processor. Generators should
have regulatory incentives to utilize waste processors.
1578
-------
In general, when discussing hazardous wastes, it is essential
that Government regulations cover the situation, that these
Government regulations are uniformly enforced for everyone,
and that the generator pay the true cost of environmental
safe disposal. Further Government regulations must not he
blind to total environmental impact. We can't have air pol-
lution regulations that inhibit burning of waste, especially
where there is heat recovery to help solve the energy shortage.
And we can't have solid waste regulations that inhibit the
scrubbing of power plant emissions where necessary to solve
an air pollution problem. Picture Fred Kellow saying to
Lee Jager: "You won't let my constituents burn their waste;
I won't let yours dump their scrubber sludge!" And look
who's caught in the middle -- the poor man trying to pro-
duce a product to make a living.
I divide hazardous wastes into three categories for my con-
sideration: Liquids, sludges, and solids.
Liquids
I've already discussed liquids. I believe liquids should
be reduced to minimum volume through concentration and/or
incinerated where necessary. We have found in some cases
that waste plating solutions can be so vrell concentrated
they can be reused in the plating tank again. Thus the
15V 3
-------
liquid does not require disposal. Even if you can't reuse
the liquid, concentration reduces it to a sir.aller volume
for treatment prior to disposal. Some liquids such as
PCB's must be incinerated. Again, the use of a professional,
objective, well qualified waste processor is advisable.
Sludges
Sludges come in many forms. Some people define dirty dish-
water as a sludge. I personally don't like to call a pump-
able liquid a sludge. In a wastewater treatment plant, the
sludge taken from the bottom of the clarifier is pumpable.
All GM wastewater treatment plants installed since 1970 have
installed thickeners, vacuum filters, centrifuges, or filter
presses such that the sludge is reduced in volume to a shovel-
able solid. For manufacturing plants the most common waste-
water treatment plant sludge is an oily sludge from the acid-
alum treatment process. This sludge can be reduced in volume
in a process redesign to polyelectrolyte treatment of the
water. Last year GM plants recovered over 4 million gallons
of oil from similar wastewater treatment operations. Another
common wastewater treatment plant sludge is a metal- hydroxide
sludge. We are now leaning toward ponding of the sludges,
using sludge drying beds, and atmospheric evaporation of the
water from the sludge. This does take some acreage, and it's
not new; such technology has been in use in the paper in-
dustry for years.
I5LO
-------
The plant can put in a drying lagoon with a sand covered
tile field draining back to a sump. The vacuum filter can
now be shut down and sludge pumped direct to the drying bed.
In one location we have five separate drying beds a:id use a
different one each day of the week. Instead of hauling 100
tons per day of sludge, we now accumulate sludge for six
months, and the final product instead of being like vaseline
is now mote like a damp talcum powder cake. It is loaded in-
to dump trucks with a front end loader for the trip to the
landfill. As a future benefit, the metals are much more con-
centrated and, hopefully, we will find a practical recovery
method to treat this ore for recovery of the metals — a
step that was never close to being practical with the old
vaseline-like metal hydroxide sludge. Metals recovery is
now being investigated; we have not yet found a way to do it.
Along with wastewater treatment plant sludges, we have air
pollution control device residues to handle. Many pollutants
that must be removed from the air or from the water are
toxic or hazardous and disposal should be controlled. A
particularly troublesome air pollution residue we are now
generating is the sludge from SO2 scrubbers at coal-burning
power plants. Again, this sludge is mainly water; it comes
off the vacuum filter with a slippery feel — somewhat similar
to vaseline — and it comes in enormous quantities. The
basic constituent is calcium sulfate and calcium sulfite —
1581
-------
the same materials found in dry wall plasterboard. We tried
to sell the material or give it away for use in plaster-
board, but we were not successful. Nobody wanted to use
waste to build a product that retails for abouh $1.50 for
a 4' X 8' sheet. To keep the economics right, wallboard
manufacturers cannot work with many small sources of supply.
What to us is a mountain of sludge is to a wallboard manu-
facturer a source of material too small to warrant processing!
At the present time, we must landfill these sludges.
Another category of sludge is the industrial process sludge.
Typical would be the material removed from the bottom of a
water wall paint booth, from an industrial parts washing
machine, or the blowdown material from backflushing a Dia-
tomaceous Earth Oil Filter. These sludges must be dewatered
and usually landfilled.
Dry Solids
The final category of toxic waste I will discuss is the dry
solids. These include poisons, pesticides, and some other
materials such as cyanide salts from hardening furnaces.
Just as we neutralize the toxicity of liquids prior to dis-
posal, it is quite common for us to put these solids into a
liquid state, mix in the chemicals to neutralize the toxicity,
then concentrate the material to minimum volume, and landfill
1552
-------
the residues. In most cases, I would not approve of direct
burial of a toxic solid without first treating it to mini-
mize the toxicity and hazard.
In summary, an industrial operation must of necessity bring
into the plant some materials which may present a hazard to
the facility, the employe, and to the environment if im-
properly handled. We must have written procedures to mini-
mize the risk. We must have a place to send the residues
for environmentally safe disposal. I believe that with
proper Government planning, policies, and regulations, the
private businessmen a]rec
-------
C3DDRX
LABORATORIES INC. 8 VAFVCK siHbfci.NEW YORK.N.Y. 10013
CLINICAL AND RESEARCH INSTRUMENT* TH.(212)CA6-2M4
January 26,1976
Mr. John P. Lehman
Director, Hazardous Waste Management Division
Office of Solid Waste Management Programs AW565
Enviromental Protection Agency
Washington D.C. 20460
RE: HAZARDOUS WASTE MANAGEMENT. Comments on Discussion Topics.
Dear Mr. Chairman;
I want to call the panel's attention to the results of
our research: the potentials of completely eliminating the pollution
caused by the users of chromic acid and sulfuric acid mixtures,
the socalled dichromates.
Dichromates are used to clean laboratory glassware in
research, chemical and medical laboratory. Large organizations
like pharmacutical and research facilities therefore are disposing
significant amounts of dichromates into the sewer system,aggravating
the pollution of the environment.
I would like to place the enclosed published article on
the record. It deals with the above problem and presents a simple
solution to eliminate entirely this particular source of pollution.
If requested we can name a significant number of privat
and governement organizations which are already succesfully using
this replacement material accomplishing the same desired result as
with dichromates.
Respectfully,
\tse~S-r*- \t "Ł—
/ George Gotta
' President
6 Encl.
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-------
104? Bush Street / Apartment Three San Francisco 94109 January 23, 19?6
John P. Lehman, Director SENATORS Cranston . Proxmire
hazardous Wastu Management Division Nelson Tunney
-ffice of Solid Waste Management Programs Dole Pearson
Environmental Protection Agency (AW-55) AIMNISTRATOR Russell Train
Washington, D. C. 20460 ADVISOR Rogers C. B. Morton
PURSUANT TO DECEMBER EPA HEARINGS IN SAN FRANCISCO, these comments and suggestionsi
EPA might gather support and clout from "grass roots" elements never recognized if
properly "briefed" ~ something with more stamina and cogent information than press
releases. Particulary important carriers include publications of Sierra Club and
Friends of the Earth's NOT MAN APART, for example. For publications to do readers
any service they must receive materials sufficiently ahead of time to 1) get pub-
lished and 2) allow readers receiving them to act. Individuals could be useful too,
but they must have sufficient lead time to act coherently. Many of us outside the
streams of communication could participate effectively in small but concerted ways
provided proper knowledge and time. Organizations run by war models almost unvier-
sally refuse anything associated with many areas of your coverage, and refuse as
well any but their own, frequently heavily loaded, figures. Such middle and upward-
ly mobile management prevails as they are almost exclusively recipient of this type
information and can stop it at their pleasure.
Congress remains derelict and remiss to refuse removal of all MfcXtol tax amenities
by exemption, deduction, nonprofit to any and all entities, beginning with churches,
and all their encumbering appendages and self-perpetuating proliferates, unions, all
trade associations, "consultants", do—gooders and hangers-on generally. Inflationary
deficits they inflict effectively preclude genuine citizen participation and assure
^osts of agency services and all other goods and services at levels persistently
debtmaking. The net effecti no citizen representation or participation, as these
people paying taxes (high percentages do not) remain outside even th? possibility to
conduct their own affairs, of which those of government and your operation are parts,
EPA properly makes no grants to any tax amenitied group or individual. Rather, the
thrust of investigation and invention properly assigns to individuals. To my knowl-
edge they are never sought. Those seeking meet holier-than-God and other we-must-
see-that-the-people*s-money-is-well-spent excuses to stand pat, put down, and get ri<
of legitimate inquiries and their makers. Congi-essioral appropriateions need to cent<
on competent individuals and design, as ZESO WASTE SYSTEMS representative clearly sa:
There could not possibly be greater cost than with such pathologies as Lockheed, any
of the distesiperate transportation episodes. Anyone could set up testing and buy da'
collection and elicit visibility -with that kind of money. Unfortunately, tootsie re-
mains the game, your agency looses face, and money buys only pretense and false ad-
vertising.
Furthermore, individuals and small firms must be paid in good order upon completion
and acceptance of work contracted by government. One organization paid 14$ at the
bank to cover payroll while the government delayed some time in meeting its obliga-
tion on a few (small) thousands of dollars. It makes special legislation for the
friendly friends of the friends.
If you don't know about these people, you shouldi
1. Project Eliminate Waste Eagle Kashaya
P 0 Box 24136 He, I understand, helped put Zero Waste
San Francisco 94124 Systems together, comes from business,
(415) 648 4251 and knows what he's about, '^his is a
situation in which a nonprofit organi-
sation was the only way to go under status
1586
-------
John P. Lehman
Donald Aitken, Ph. D., Director
Environmental Studies Program
California State University
San Jose, California
3. Capt. Frank Cheek, Pilot
Eastern Airlines
SEE The National Observer
January 1?, 19?6
5.
6.
Unfortunately another tax amenitied in-
stitution and restrictive to that extent.
This astrophysicist with a range of con-
tacts that include solar and other "it
can't be done" energy nodes that work now
on efficient useful scales, participates
in and coordinates applciations you should
look at. PREVENT hazardous wastes!
Jet Descent Homograph, he invented to
save jet fuel in landing, reported as
incredibly simple — considered the rea-
son for slow acceptance. It's also not
a mint or indebtedness and nobody commis-
sioned it which relieves spurious credit!
Migma Fusion A bona fide engineer out of the nuclear
Dr. Bogdan Maglich r«hs who apparently got short shrift at
Fusion Energy Corporation Laboratories the government's doors for reasons of
Princeton, New Jersey professional interference — another
way to derail legitimate prospects worthy
of consideration rather than put downs
where imperatives of energy sovaees CLEAN
and available arise.
This format, in the unofficial conference
especially, properly includes individuals
and their innovative, pertinent technology.
Instead the State Dapartnsr.t will cor.duct
its usual glossy and useful ideas seem less
than likely. I've had a great runaround.
* did not contact State as I felt it an
exercise in total futility for any serious
purpose of exposure of individual perform-
ance, technology that performs as represented,
or applies without outrageous price and ped-
dling pressures.
VENTRA-VAC is equipment for its day, applies
wherever water quality maintenance and con-
trol is at issue, and rather than obstructions
and dredging in current marine constructions
needs real consideration —• which when visi-
bility overtures can be followed up may ma-
terialize. Removes no hazards, but circulates
and aerates water in the manner of a fast mov-
ing stream, bringing oxygen to the systems,
supporting them to completion, and aiding
various marine situations coexisting.
Descriptive information for your reference.
Any questions contact me or Webb.
About a year ago I contacted various individuals, groups, and legislators (with
no proprietary assertions or embarrassomhh, as here) about ane'il recycling sys-
tem. I was informed by the Department of Agriculture that oil recycling in ag-
riculture was outside their purvue. Dust abatement is a cheap shit refusal to
deal — and as my family farms and off-the-cuff figures I get astoundt GET WITH IT.
156?
HABITAT, the conference on human
settlement in Vancouver, 19?6,
conducted by the United Nations
I am not personally convinced of
the veracity of the official con-
ference or its concerted exclusion
of Western industry of meritj the
unofficial conferencei bravo!
William G. Webb
36W Santa fiita Road
Pleasanton, California 9^566
CH5) 1*62 3642
-------
John F. Lehman
8. I know someone working on absolutely clean, no way to pollute, energy. He is
not ready to discuss either his ideas or make this generally known. When he
5s ready to work out his concept there should be revenue available sans hassle,
as he is an individual of personal integrity and veracity, withou t, however,
the trappings and lures of grantmanship, beholdenness, and institutionalized
hanging-on. Until and unless he is ready to go public, I cannot name him. In
the meantime it is greatly to be hoped that funding goes to get today's work
done in good order, rather than in cost-no-object treatment after deficit spend-
ing has bought bungling and overruns and equipment that does not work and does
not perform as represented. Thsre are better ways to go.
Public briefings frequently advise only moguls of industry and business accustomed
to talking with themselves. One such transaction plainly underscored this fact I
already krmv, I answered the telephone in a trade association office (tax exempt,
tax deductible, nonprofit, membership service, limited public service), took a mes-
sage for the executive director which I delivered, that the Department of Commerce
as I recall, had a new research vessel in the SFO Bay aboard which a special "public
information briefing" was being held and to which he was invited. I asked who was
included in such presentations. I was tald "business leaders and executives". I
asked if such reputable proups as Sierra Club and Friends of the Earth were also
invited. They were not important, this was for the public, I was told! This was
PUBLIC information — to brief the PUBLIC! As an entirely competent individual I
greatly resent the absence of participation in such things to which wives universally
pad the premises for the ego aggrandizement of those briefed!! I despise the atten-
dant lies and deceit surrounding such overtures. At the same time I fully appreci-
ate the infantileness some "environmental crusaders" exhibit and understand criticism
properly attaches accordingly to disparities among these ranks. They are the same
stuff their counterparts exhibit in restricting audience and incestuousness derivitivej
Ae fact I can handle information does not give me either time or money to partici-
pate, as one paying tribute ahead of all other costs sustains further pressurized
abuses -- all extremely hazardous waste. Barricades that force me to pay full cost
in any amount that provides freeloading deadbeats in tow for any reason for events
or conferences must be elimisted. Public agencies are perfectly intractable and as-
sinine on this score ~ interfering with information dispersal rather than fostering
it. Karriage licenses* elastic dollar value needs removal. Only identical per capita
cost properly prevails. Ko cost for access on any but per capita makes the only sense,
Anything else is oneuTsuanship, pure tribute to extensive, expansive, abuse. Hospi-
tality commonly devises brutality and restriction via excessive displaced costs that
clearly place information secondary to a "che^J if not free woman (most such spouses
are female) in hand.
What does this organization do to apprise candidates of things they do not want to
heart Of apprising constituents of realities? This area of your primary trust stands
void to proper recognition and any action to get on with the business of retainbg
currency with the shrinking landscape and resources by whatever name, and emphasizing
that best-run companies seem most environmentally sound and most profitable. Is it
possible that the Council on Economic Priorities could reinforce EPA's position at
complementary points? Why not? They do a second-to-nobody job. Why would they not
be invited and utilized for their excellence and veracity? And maintain this posi-
tion, rather than hire prostitutes in the service...?
I am sure some of the best-spent Federal advertising money is under EPA jurisdiction.
Federal advertising penerally,generally riddled with holes of caveat,leaves much to
a desired and needs to be removed from such budgets. Among these energy has to be1
a highpowered bastard, and social security and AFDC which omits faces that tell truths
, feristina M. Groth
15B8
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GUAM ENVIRONMENTAL PROTECTION AGENCY
POST OFFICE BOX 2999
AGANA, GUAM 96910
TELEPHONE 749-9901. Ext. 372
Mr. John P. Lehman OCf 1 6 1975
Director
Hazardous Waste Management
Division
Office of Solid Waste Management
Programs
U.S. Environmental Protection Agency
(AW-565) Washington, D.C. 20460
Dear Mr. Lehman:
I have noted your intention to hold a hazardous waste
management seminar in San Francisco on December 11, 1975.
I am enclosing earlier correspondence with the Region IX
office concerning hazardous waste management. I hope, sane
of these topics will be discussed at your meeting and any
results produced filtered back to us for our information.
ncerely yours,
RRY L/ WAGER I
ffead, Planning & Program
Development Division
Enclosures
1563
"ALL LIVING THINGS OF THE EARTH ARE ONE"
-------
Mr. Frank Covington Mi| lc
Director, Air and Hazardous JUL 1D
Materials Division
U.S. Environmental Protection Agency
100 California Street
San Francisco, California 94111
Dear Mr. Covington:
Subject: Comments on Proposed Hazardous Wastes Study for the
Pacific and Proposed Guidelines for Procurement of
Products that Contain Recycled Materials.
Hazardous Wastes
We were asked by Mr. Chuck Bourns to provide some input on the scope
of services for your proposed hazardous waste study for the Pacific
Islands. It follows:
(1) Present current costs for (a) on-island transportation,
(b) storage, (c) treatment (if any), (d) handling,
(e) ocean transportation, (f) handling and transportation
on the mainland, (g) disposal/treatment on the mainland
for commonly encountered hazardous wastes. Recommend who
should bear these costs. Who is the contact person/position
regarding shipment of hazardous materials? What federal and
local regulations already apply to shipment of these materials?
(2) Determine if port facilities in each island have sufficient
area for storage, repackaging, containing spills, and handling
these materials. Assess the individual personnel capability
at each port to safely handle the wastes. If not, what
training will be needed and who will accomplish it? What
special equipment is needed in each area?
(3) Contact military facilities to do an in-depth analysis of
the hazardous materials they generate and their local capability
for handling, treatment, and disposal. Will they program into
their budgets costs associated with hazardous waste disposal?
Who is the contact person/position at each facility regarding
hazardous wastes?
(4) How will local OSHA offices be involved in this study and
subsequent disposal of wastes?
1530
-------
Mr. Frank Covington
Page 2
(5) What are existing shipping lines and their travel frequencies
capable of handling hazardous wastes in the Pacific; what
special requirements would have to be met by the shipper?
(6) What wastes are currently and can expected to be generated
on each island by civilian and military facilities? What are
the existing ways of handling hazardous wastes? What needs
must be planned for (a) immediately (b) 2-5 years (c) 5 years+?
(7) What will be the major trans-shipment points in each area and
what port improvements (both physical and personnel) will this
require?
(8) Identify potential users of present and anticipated wastes in
the islands so that disposal can be avoided if possible. If
recovery techniques are already available for certain wastes,
identify them. Recovery and reuse of these wastes should be
paramount.
Guidelines for Procurement of Recycled Materials
We think the guidelines are good and certainly overdue. We have trans-
mitted a copy of them to island Air Force and Naval Commands for their
information with a copy of this letter. One item that has major impact
on Guam, and that these guidelines do not appear to have relevance to,
is the use of returnable beverage containers. Guam suffers from an
abundance of nonreturnable containers causing severe litter problems
and contributing to our vector control problems. Military exchanges
generate nearly 70% of Guam's beverage containers, all of which are
nonreturnable. The increasing reliance on one-way containers has also
contributed to the closure of bottling operations on the island. If
these guidelines cannot be used to stimulate the use of returnable
bottles by federal facilities, what is the federal government doing to
alleviate this problem?
Sincerely yours,
0. V. NATARAJAN, Ph.D.
Administrator
Admiral, U.S. Navy
Air Force Base Commander
Governor's Office
Chief of Operations, Public Works
15S.
-------
Mr. Paul DeFalco, Jr.
Administrator, Region IX
U.S. Environmental Protection Agency nl/G 18 1975
100 California Street
San Francisco, California 94111
Dear Mr. DeFalco:
As you know, our Agency is engaged in building a comprehensive pesticide
control program. The recent workshop here, sponsored by your Agency, did
much to spread information about local pesticide programs and problems, as
well as federal activities in this vital area. However, the portion of the
workshop dealing with pesticide disposal regulations and programs highlighted
what we consider to be a potential problem in federal program coordination.
Recently, we wrote to Mr. Frank Covington in response to a verbal request
from your Agency for suggestions on the content for a scope of services to
study hazardous waste disposal practicies in the Pacific area (copy enclosed).
The disposal of pesticides is a very obvious problem in this area, particu-
larly in view of (1) the Yap pesticide incident in 1974, and (2) recent
federal actions suspending registration of Aldrin, Dieldrin, Chlordane, and
Heptachlor. We assumed that the proposed hazardous waste study for the
Pacific would include an analysis of the impact of federal registration sus-
pensions and how to solve the disposal problems they will create. Additionally,
there are existing stocks of old pesticides, at least on Guam, for which there
is no longer a foreseeable use.
Comments by federal officials at the recent workshop, in response to questions
about evaluation of pesticide disposal problems, indicated that such subjects
may not be included as part of the study. We think this would be a serious
oversight.
I hope that the proposed study will Indeed include pesticide disposal
problems in its analysis and I am anxious to see how our earlier suggestions
were incorporated into the final scope of services.
Sincerely yours,
0-
0. V. NATARAJAH, Ph.D.
Administrator
Enclosure
cc: Governor's Office
-------
UNITFD STATES ENVIRONMENTAL PROTECTION AGENCY
Dr. O. V. Nataru_,an, Administrator
Guam Environmental Protection Agency
P.O. Box 2999
Agana Guam 96910
- &
Dear Dr. Natarajan:
,,Thank you for your letter of July 16, 1975 in reference
to the proposed "Hazardous Waste Study for the Pacific" and
the "Guidelines for Procurement of Products that Contain
Recycled Materials". Your comments concerning the proposed
hazardous waste study will be taken into consideration in
drafting the scope of work and procedure.
In regard to your questions concerning stimulating the
use of returnable bottles at Federal facilities, the EPA has
promulgated draft "Guidelines for Beverage Containers" and
is now seeking comments from interested parties. We have
attached a copy of the draft guidelines for your infor-
mation, arid y_ou_ may send comments directly to the address
shown in the Guidelines under the section Response Requested.
We have reviewed your "Beverage Container Report" of
May 1974 and are aware of the acute beverage container
litter problems that Guam experiences. The beverage con-
tainer guidelines, as they are presently written, will
require Federal Agencies to impose a minimum 5Ł deposit on
all beverage containers sold at federal facilities. Though
these containers are not necessarily refillable, it is
anticipated that the minimum deposit will encourage people
to return their empty containers and thereby alleviate the
litter problems associated with them. In addition, it is
hoped that secondary materials dealers will recycle the
relatively uncontaminated, non-refillable containers back
into the production cycle. Of course, the Guidelines urge
use Of refillable containers wherever possible.
15S3
-------
We have also enclosed a news clipping quoting the
Administrator of the Environmental Protection Agency which
sets forth .tha position of the Agency on this subject.
Sincerely,
Frank Covington, Director
Air & Hazardous Materials Division
15S«*
-------
MARTIN M. SHEETS
1973 W. GRAY, RM 4
HOUSTON, TEXAS 77019
TELEPHONE: 523-1975
GEOLC GIST
January 9, 1976
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs
(A.W. 565)
Environmental Protection Agency
Washington, D.C. 20460
Dear Sir:
It was my pleasure to attend the hearing conducted by your
group on December 9, 1975 at the Holiday Inn Medical Center, Houston,
Texas . It was my feeling that the hearing and others on the same day
and related days were very good and beneficial both to your agency
and the public. I would like to compliment you on the meetings and
the way in which they were conducted.
No statement was presented here by any geologist, to my know-
ledge, so I wish to present the enclosed statement for inclusion in the
final report. I hope it will be a help. If I can be of any other assistance
I'd be pleased to hear from you.
Yours sincerely.
Martin M. Sheets
Houston Geological Society
Environmental Committee
P.S. Would you please put me on your mailing list to receive notices
of similar meetings in the future.
MMS/mm
Enclosure
-------
STATEMENT to be included as part of the record of the E.P.A. Hearing on Hazardous
Waste Management held at the Holiday Inn Medical Center, Houston, Texas, Decem-
ber 9, 1975.
Geologists of the Houston area are very concerned aboutithe subject problems and
feel that they can make a useful contribution to their solution. To that end, they
submit the following statement:
Storage, general: As far as practical, storage of hazardous wastes should be confined
to topographically undralned basins, so that any spills which occur could not find the
way into the ocean. Such basins are common in the western U. S.
In areas such as the Gulf Coast and all other salt basins, salt deposits may provide
the most versatile and safest medium of storage.
In order to immobilize wastes, it is suggested that, where useful and practical, the
wastes be converted to pellets, heavy mud slurries, or mixed in cement.
Regarding siting: All plants where hazardous wastes are produced or stored should be
located far away from streams, rivers and oceans because a spill into a major river or
the ocean would be absolutely uncontrollable.
Geological Aspects, Subsidance and Active Surface Faulting: In the Gulf Coast, and
no doubt many other areas, surface faults are actively moving. Such movement can
cause rupture of pipelines, storage tanks and other surface handling facilities. It
could also cause railroad derailments and perhaps damage -to other modes of transpor-
tation .
Near sea level, subsidence of the land surface makes storage and handling facilities
more vulnerable to damage from hurricanes and other storms. Such surface subsidenc
is occurring in the Houston vicinity and many other areas and will continue to be a
problem.
Such Geologic problems are not unique to the Gulf Coast and no doubt also apply to a
greater or lesser degree in many other areas. It is recommended that consultation wit
a thoroughly trained and experienced local geologist be made a mandatory part of ever
project.
Disposal: We would agree with some others that, where practical, the best method
of disposal should include detoxification and recycling.
-------
STATEMENT on
Hazardous Waste Management
page two
Monitoring: All phases of hazardous waste management should be very carefully
and continually monitored. Consideration should be given to making non radioactive
wastes slightly but not dangerously radioactive to facilitate monitoring. It would
seem that the transportation phase of the hazardous waste management problem is
perhaps the most difficult to monitor and at the same time the area in which the great-
est improvement is needed. Two truck transporters presented ideas at this hearing
but no representatives of any railroad or barge company presented any statement.
All such people should be pressed into service to help solve the problems. All pre-
sent regulations regarding transportation should be rigorously enforced.
Penalties: Hazardous waste management is a very serious responsibility, in some
cases involving great risks. It is extremely important that violations be eliminated
and violators apprehended. To that end it is recommended that very severe penalties
be imposed, perhaps scaled according to the severity of the hazard or the resulting
possible damage. In this regard it is imperative that all persons involved be thor-
oughly educated as to the seriousness of the problem.
HOUSTON GEOLOGICAL SOCIETY
ENVIRONMENTAL COMMITTEE
Martin; M. Sheets, Chairman
-------
LEAGUE OF WOMEN VOTERS OF NEW JERSEY
460 BLOOMFIELD AVENUE, MONTCLAIR, NEW JERSEY 07042 TELEPHONE 746-1465 AREA CODE 201
HAZAJ^XTOS WASTE MANAGEMENT
Comments on Discussion Topics of Public Meetings
Conducted by the Environmental Protection
Agency. December 1975
Margaret Hoffman, Solid Waste Chairman
January 30, 1976
Thank you for this opportunity to comment upon the need for a better national perspec-
tive on needed guidance for the proper management of hazardous wastes. We in the
League of Women Voters recognize that the generation of hazardous and extremely hazardoi
wastes is a constantly increasing and vexatious problem. In the past our concern for
environmental integrity has been evidenced by our support of prohibitions on the dis-
posal by incineration of such wastes, with its resultant pollution of the air, and of
dumping into waterways and oceans with a potential for future degradation of disastrous
proportions. The institution of more stringent controls upon air and water pollution,
however, have affected past disposal practices at the price of a significant increase
in disposal to the land.
In this time of mushrooming development in the field of new products, especially
chemicals, the vast majority of consiumers is unfamiliar with the composition of the
greater part of the products they use, or with their potential for hazard in use or
in disposal. At the same time we are constantly made aware of new dangers from chemi-
cals, such as the recent Kepone incident in Virginia; danger from biologicals and
mutations developed for warfare, some of which are reported to have no known antidote;
danger from radioactive materials disposed of on sea and land in containers that will
wear out long before their contents lose their power; dangers from the dumping of PCVs
and acid wastes in shallow wells on industrial sites, with resultant contamination of
ground waters — a chilling list that grows with each new day. Such threats demand mor
than compliance measures, or the good references of past performance, such as has been
evident in the field of pathology. For the protection of present and future health and
safety, regulations must be established to control the disposal of a wide spectrum of
substances, both presently and potentially hazardous.
(more)
15S8
-------
LWVNJ Comments on Hazardous Waste Management
Initially, a comprehensive definition of hazardous waste must be established, with
guidelines for the inclusion of other substances, or combinations of substances,
that are subsequently revealed to be hazardous in nature.
All materials that have a potential for hazard in disposal must be distinctly and
uniformly identified, in the manner of the "skull and crossbones" emblem that is
universally accepted as a symbol for poison.
Areas of responsibility for hazardous waste disposal must be clearly defined, from
the initial inception of the product, through itsmanufacture, shipment, sale and
use. This definition of responsibility would include the training and qualifications
of all handlers of radioactive, pathogenic or chemical substances found to be hazardous
in disposal, and a guarantee of compliance with regulations must, at all times, rest
with a specified party.
Every effort should be made to withhold the use of products until there are measures
available to alleviate any harmful effects from disposal of these products.
The successful execution of any hazardous waste management plan demands a nationwide,
uniform code of regulations, adequately funded and policed to insure compliance.
While some industries have instituted excellent procedures in disposal practices,
many have shown a shocking irresponsibility toward the public good, and demonstrated
the absolute necessity for scrupulous monitoring of any safeguards that are instituted.
While presently describing hazardous wastes as "the particularly dangerous discards of
a highly industrialized, technology-based society," we must always recognize that,
in fact, all wastes have the potential for hazard, at certain times, in certain con-
centrations and most especially in certain combinations.
The suggestion has been offered to designate suitable areas for the disposal of
hazardous and radioactive wastes, but there is always the danger of such a plan en-
couraging the "out of sight, out of mind" climate. We must constantly assess every
detoxificating method for existing wastes, including those that have been disposed of
improperly by land or sea.
As we reap the benefits of our technologically blessed society, we must accept the
moral responsibility for controlling its enormous potential for harm. We will leave a
poor inheritance if we devour the fruits of our technology and bequeath the garbage
detail Co our children.
15S9
-------
LOS ANGELES COUNTY FLOOD CONTROL DISTRICT
A E BRUING1ON
CHIEF ENGINEER
HOWARD H HAILE
PO BOX 2418, TERMINAL ANNEX
LOS ANGELES C ALI FORM ]A 9OO5 1
TELEPHONE 226.4IOI
December 15, 1975
ASS 7 CHIEF DEPUTY ENGINEERS
OMER D HALL
CHESTER MAGNESS
JOHN M TETTEMER
ADMINISTRATIVE DEPUTY
JAMES R POLLEY
IN REPLY PLEAbE REFER TO
FILE NO 2-19.07
Public Meeting of the
Environmental Protection Agency
Regarding Hazard Waste
Management Problems
December 11, 1975
San Francisco, California
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Program
U.S. Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Lehman:
The Los Angeles County Flood Control District, although not represented
at the public meeting, is very concerned with the hazardous waste manage-
ment problem. As operators of a large drainage system and having
experienced hazardous wastes in our system, we would like to present
the following items for consideration in the preparation of your program:
1. Accidents or plant upsets can transform any hazardous
material into a hazardous waste material. Once a
material leaves its pipeline, tanker, storage tank,
or other confinement, it becomes a waste product.
2. Surface discharges almost always enter existing storm
drainage facilities and the local storm drainage agencies
must be included in any inland waste management program.
They alone have access to and are familiar with flow
patterns in their system and are aware of the location
of any men and equipment in the affected area. This is
especially true when the drainage facilities are subsurface.
J>. The waters in local drainage facilities which consist of
natural flows, rainfall run-off, urban run-off, National
Pollution Discharge Elimination System Permit waste
discharges, sewage plant effluent, and all other gravity
flows may travel miles in underground conduits. Only the
local storm drainage agency has authority, jurisdiction,
knowledge of, and the necessary men and equipment to
safely work in its system.
I6CO
2250 ALCAZAR STREET LOS ANGELES
-------
Mr. John P. Lehman, Director
Page 2
December 15, 1975
4. The local storm drainage agency is probably not a Federal
or State agency and, therefore, has no guarantee of recovery
for funds expended in the containment or removal of hazardous
materials under existing legislation.
5. Once a hazardous material is in a local drainage system, it
is difficult to recognize or identify the material so that
appropriate precautions may be taken. It is at this time
that the local agency needs maximum assistance and guidance.
We believe that an effective waste management program must include immediate
notification of the local storm drainage agency and should have a 24-hour
information service for consultation regarding safe procedures for
identifying, containing, treating, removing, and disposing of hazardous
wastes. Legislation should be enacted to authorize, assist, and protect
the operators of local drainage facilities in their interaction with
hazardous wastes.
This District has a program whereby experienced personnel and equipment are
available 24 hours a day to respond to and assist in the location and
handling of any waste material entering or tributary to our drainage
system. The effectiveness of this program is due to the excellent
cooperation of Federal, State, and local agencies and others who
frequently interact with accidental waste discharges. We would appreciate
any program which will provide for early notification and identification
of a problem as well as the most up-to-date control and disposal technology.
We thank you for this opportunity to comment on the hazardous waste problem
and, if we can be of assistance, please contact Mr. John K. Mitchell at
(213) 226-^386.
Yours very truly, j
—,Ł-•
//
DKC:gf -*-• E. Bruington, Chief Engineer
cc: Mr. Paul DeFalco, Director
Environmental Protection Agency, Region IX
100 California Street
San Prancisco, CA 94-111
Mr. Harry L. Hufford
Chief Administrative Officer
713 Hall of Administration
500 West Temple Street
Los Angeles, CA 90012
Mr. John H. Larson
County Counsel
648 Hall of Administration
500 West Temple Street
Los Angeles, CA 90012
-------
F C Aldrich
Manager Environmental Control Division
Marathon Fmdlay Ohio 45840
Oil Company Telephone 419/422 2121
January 8,, 1976
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs
Environmental Protection Agency
Washington, D.C. 20^60
Dear Mr. Lehman:
Marathon Oil Company appreciates the opportunity to comment on
Hazardous Waste Managenent Discussion Topics as defined in 40
PR 92993 September 17, 1975- Marathon's comments are directed
to two points of concern: the disposal of biodegradable oily
wastes which can be disposed of in an environmentally acceptable
manner and therefore should not be considered along with and
subject to the same rigorous controls as the disposal of toxic
or dangerous wastes; and the potential liability to a waste
generator for the actions of a waste treater and/or disposer.
Marathon production, transportation, and refining operations
generate oily solids and oily sludges associated with the
dewatering and storage of crude oil plus the treatment of re-
finery waste waters. Marathon has found as have many other oil
companies that land farming of oily solids and oily sludges is
a safe, environmentally acceptable, and non-energy intensive
method of degrading the oil associated with these wastes through
the activity of soil bacteria. Marathon believes that the dis-
posal of such wastes are not hazardous, even by EPA criteria,
when such disposal is by land farming. Because of this, Marathon
believes that land farming of oily solids and oily sludges with
adequate safeguards for adjacent surface waters and underground
waters should not be subjected to the rigorous controls and
reporting requirements applied to toxic or dangerous wastes.
Marathon Oil Company believes that the ultimate liability for
the disposal of a hazardous waste should rest with the contractor
treating and disposing of the waste so long as the generator of
the waste has properly defined or identified it to the contractor
16u2
-------
Mr. John P. Lehman -2- January 8, 1976
and so long as the generator of the waste has determined that
the contractor is licensed to dispose of the hazardous waste
in question in an approved disposal area.
Very truly yours,
P. C. Aldrich
FCA:sJs
-------
NICHOLAS I. MELAS
PRESIDENT
Bart T. Lynam
General Superintendent
751-5722
KURD or T*U«TM*
JOANNE H, ALTER
JOAN a AMDEMON
JEROME A. COMMTINO
VALENTHIE JAMCKI
WILLIAM A. JAIKULA
JAMES C. KIRIE
CHESTER P MAJEWKI
MKHOLM i KELAI
January 30, 1976
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solids Waste Management Programs
AW-565, Environmental protection Agency
Washington, D. C. 20460
Subject: HAZARDOUS WASTE MANAGEMENT
Dear Mr. Lehman:
In the Federal Register for Wednesday, September 17, 1975
at page 42993, a Notice was published inviting comments
on the matter of hazardous waste management. We are
informed that there is a possibility that sludge from
municipal sewage treatment plants may be considered a
hazardous waste. We feel strongly that such designation
would be highly inappropriate and would place many munici-
pal agencies at a disadvantage and under redundant regulation.
Disposal of sludges from municipal sewage treatment plants is
already under regulation by other Federal, State and Local
programs.
Attached for your information is a statement which we would
like you to include as part of the record which is in
response to the above referenced Public Notice.
If you have any further questions, please contact this office.
Very truly yours.
Bart T. Lynam
General Superintendent
BTL:CLH:RL:r
att.
-------
STATEMENT ON HAZARDOUS WASTE MANAGEMENT
TO THE EPA
The Metropolitan Sanitary District of Greater Chicago
(District) has prepared a statement concerning the United States
Environmental Protection Agency request for information regarding
Hazardous Waste Management published in the Federal Register
(Vol. 40, No. 181, p. 42993) on September 17, 1975. In
particular, the District has prepared a comprehensive document
describing the utilization of municipal sewage sludge in the
agricultural sector for fertilizer and reclamation of low
fertility soils. Before beginning this statement, the District
would like to address those specific topics in the Federal
Register regarding Hazardous Waste Management which are in our
area of expertise and relate to the Utilization of Municipal
Sludge for fertilizing row crops and reclaiming soils. We will
itemize the topic areas as they appear in the Federal Register.
No. 1. The question of "What is a hazardous waste?" as
related to municipal sludge utilization is discussed
in general in our comprehensive document which
follows these specific comments on the topics in
the Federal Register.
No. 2. The responsibility for waste management should rest
with whoever has physical possession of the waste.
The supplier has responsibility to inform receiver
of the nature of the hazardous waste.
-1-
Ibu5
-------
No. 3. As stated later in our presentation, it is the
opinion of MSD that municipal sludge should not
be considered as a hazardous waste.
No. 4. In the case of digested municipal sewage sludge,
it is the opinion of MSD that anaerobic digestion
for 10 days at 35°C followed by 60 days in a lagoon
at 20°C or 120 days at 4°C will stabilize sewage
sludge and reduce pathogens to a minute level.
The soil serves as sink to inactivate many toxic
metals. Research findings in Illinois indicate
that 40 to 70% of the metals in sewage sludge are
retained in the soil plow layer. The metals are
thought to be precipitated or fixed to the colloidal
fraction of the soil.
No. 6. Safety precautions at municipal sludge application
sites should include limited access to the site
and existing OSHA standards for employees working
at sewage treatment facilities.
No. 7. In the case of using digested municipal sludge as a
crop fertilizer, we recommend periodic chemical
analyses of the sludge applied and if less than
15 dry tons per acre (34 mt/ha) applied no other
monitoring is needed at the farm.
In the case of using digested municipal sewage
sludge for land reclamation or soil improvement
*hich results in high per acre application rates,
1606
-------
we recommend periodic monitoring of surface and
groundwater in the area of sludge application.
No. 10. If digested municipal sludge is used as a crop
fertilizer, the controlling constituent in the sludge
should be nitrogen. The sludge application on crop
land should be limited to the nitrogen required for
optimum crop yields.
No, 11. With digested liquid municipal sludge, methane may
be generated. Current Department of Transportation
regulations are sufficient to handle this situation.
No. 12. The present regulations on labelling are acceptable to
the MSD. Such regulations will naturally depend upon
the agency which has jurisdiction.
No. 13. See comments made in topic area 6.
The following statement represents the major thrust of
the District presentation regarding Hazardous Waste Management.
In the following, the District will present an overview of the
utilization of municipal sewage sludge in fertilizing crops
and reclaiming soils.
The disposal of the solid residues from wastewater treatment
has traditionally been the most difficult problem facing munici<-
pally and privately owned treatment facilities.' In general, there
exists sufficient technology to remove various pollutants from
wastewater, but the disposal of the resulting solids has been a
difficult technical as well as social problem.
1607
-------
Sludge Production
Dean (1973) has estimated that the actual national production
of sludge in 1972 was approximately 10,000 dry tons (9,072 cetric
tons) per day. The estimate is probably low since it is based
only upon the sewered population and includes the effect of process
variations such as digestion and incineration. By 1990, he
estimated that the quantity of sludge will increase to 13,000 tons
(11,800 metric tons) per day.
Clearly, as the cities grow and reach for higher standards
of living, while preserving the quality of the environment, there
will be an increasing demand for more sophisticated and advanced
wastewater treatment processes. Older waste treatment practices
which produced little if any solids will soon give way to processes
which, in general, will generate larger quantities of sludge.
Also, traditional sludge disposal techniques such as lagooning
will progressively lose social and economic acceptance and thus
will require new and more innovative approaches to existing
solids disposal techniques.
In addition, as the population of many states becomes nore
urbanized, it will become increasingly difficult to find locations
in or around large cities where sufficient space can be allocated
for solids disposal. That is, wastewater solids will become in-
creasingly out of place in relation to their point of orgin.
16G8
-------
Ultimate Sludge Disposa] Alternatives
There are many combinations and variations of sludge disposal
alternatives available to municipalities, but the basic processes
are:
1) Land Spreading
2) Incineration and Ash Disposal
3) Ocean Disposal, and
4) Land Fill
Land Spreading
Land spreading of sludge has become a method which is being
increasingly considered by many municipalities in the U.S. and in-
deed, throughout the world. It offers the advantage of recycling
nutrients back to the land at low cost, and of reclaiming lands
bespoiled by strip mining. Sludge is first stabilized by anaerobic
digestion or other suitable means before application on land. Such
stabilization eliminates obnoxious odors and vermin problems.
Yields of grain and forage crops are increased bjr the nutrients and
water supplied by irrigating with digested sludge. Digested
sludge organic matter accumulates in and imparts favorable charac-
teristics to soils because of its normally high humus content. The
process of land spreading of sludge affords the opportunity for
urban areas to recycle the fertilizer value of sludge to the
farming areas from which much of the organic materials and nutrients
originate. With the current shortage of fuels, and the high
requirements for inorganic fertilizer production, sludge recycle
for agricultural production offers a ready opportunity to reduce
16b9
-------
the energy requirements of the agricultural sector. Also, since
many municipalities can offer their sludge at practically no cost
to the farmer, a significant cost savings is effected both for
the farmer and the municipality which produces the sludge.
Incineration
The current fuel shortage and the high cost of clean stack
emissions make this disposal method impractical. Many areas are
also imposing local constraints on the operatiois of incinerators.
Ocean Disposal
Ocean disposal offers, to coastal cities, a readily available
ultimate sink for sludge. This means of disposal' is not available
to inland cities. This method of disposal has name under increased
governmental scrutiny and may soon be severly restricted. Costs
are very low for this process and include only transportation
costs although some cities are beginning to diged. their sludge
prior to ocen disposal.
Landfill Operations
Landfill operations are practiced by many cuties and included
under this general term is sludge lagooning. Laidfill operations
waste the organic content of sludge while consi&rable expense is
involved in sludge dewatering either for lagoon decanting operations
or prior to landfill operaitons. Disposal sites often are useless
for other purposes following landfill and some are never returned
to the tax rolls. Few sites can be used for 20 to 30 years after
1610
-------
being landfilled with municipal sludges. Oftentimes, such sites
will produce methane gas which could cause a potentially dangerous
situation for other land uses. Leachate collection and treatment
may be required thus increasing the costs for this disposal method.
Many sites are unsuitable due to problems with leachate capture.
.r /•» v f
ibxl
-------
SLUDGE PROPERTIES
Sewage sludge is derived from the organic and inorganic
matter removed from wastewater at sewage treataent plants. The
nature of sludge depends on the wastewater sources and the method
of wastewater treatment. If waste solids are to be evaluated
as a soil amendment or as a fertilizer, it is important to under-
stand their chemical and biological properties. A comparison of
sludge analyses from various treatment plants would be confounded
by the individual treatment processes; therefore, some of the
more common wastewater treatment methods will be described.
The first treatment process is usually graviity separation
of solids from wastewater. This process is comnamly known as
primary settling or primary treatment. Secondary sewage treatment
may be accomplished by physical-chemical or faioiagical processes.
The physical-chemical processes include chemical precipitation
using lime, alum, or ferric chloride. Biological] secondary
treatment includes trickling filters or some variiation of. the
activated sludge process where aerobic suspended bacteria treat
primary treated wastewater. These biological processes result in
nutrient consumption by microorganisms and the formation of bio-
logical floes which are later settled out and subsequently pumped
to concentration chambers for further processing.
The wastewater solids separated by these primary and secondary
wastewa.ter treatment processes may then be drieQ for marketing AS a.
low analysis dry fertilizer, or subjected to various stabilization
treatments. Some current sludge stabilization processes include:
aerobic or anaerobic meso- or thermophilic digestion.
1612
-------
Following any of these latter processes the stabilized sludge
may be further concentrated by drying beds, vacuum filtration,
pressing, centrifuging, or decanting.
Some typical fertilizer values for sewage sludge from the
District, the state of Illinois, and seven other states in the
United States are presented in Table !_.
The metal contents of sewage sludges from Chicago, seven states
in the USA, and 42 locations in England and Wales (Berrow and
Webber, 1972) are presented in Table 2.
1613
-------
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1616
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SOIL AND CROP RESPONSES
TO SLUDGE APPLICATION ON LAND
Sewage sludge when applied to soils provides a readily
available source of plant nutrients and it is an effective soil
amendment. The chemical quality of sewage slvdges is dependent
upon wastewater sources and the methods of wastewater treatment
as discussed earlier. Sludges applied to land provide major plant
nutrients such as N, P, K, micro plant nutrients such as Cu, Fe and
Zn and organic matter for improving the soil structure (e.g.,
better aeration and water holding capacity). The effectiveness of
sludge as a soil improving agent depends upon the composition of
the sludge, the characterisitcs of the soil to which it is applied
and the plant species to be grown (U.S.D.A., 1974).
The nutrient contents of municipal sludges vary considerably
and nitrogen, phosphorus and potassium levels are about one-fifth
of those found in typical chemical fertilizers (Table 1). Much of
the N and P in sludge is in organic combination and it must be
mineralized before becoming available to plants. The rate of
mineralization for N and P is dependent upon local conditions such
as soil type, temperature, soil pH, soil water and, other soil
chemical and physical characteristics.
Crop Responses
Crop responses to sewage sludge application have been evaluated
by the Metropolitan Sanitary District of Greater Chicago for many
years. To determine the environmental effects of sludge on
1617
-------
agricultural lands, experimental corn plots were developed from
a 7-acre (2.8 ha) field at the Hanover Park Wastewater Reclamation
Plant in 1968. The original experimental design was a randomized
block with five replications and three sludge loading rates of 0,
1/4, and 1/2 inch (0, 6 and 12 mm) of sludge/week. Sludge was
applied to the plots at weekly intervals in furrows between growing
corn rows.
Corn yields from 1968 to 1973 are presented in Table 3_.
Sludge applications consistently produced yield increases for corn
grown on the Drummer silty clay loam soil with poor natural drainage.
In another experiment on the Northeast Agronomy Research Center
of the University of Illinois near Joliet, Illinois, digested
sludge from wastewater treatment plants operated by the District
has been applied at various rates each growing season on 20 X 44 ft.
(6.1 by 12.2 m) plots on & Blount silt loam soil continuously planted
to corn since 1968 (Hinesly et al., 1974). The maximum loading
rate of sludge was 1 inch (2.54 cm) of liquid containing 2 to 4%
solids applied by furrow irrigation as often as weather conditions
and available labor permitted- Lesser amounts of sludge were applied
on 1/2 and 1/4 maximum treated plots on the same day sludge was
applied on the maximum treated plants. Each spring before plowing,
the control plots received 300 Ib/acre (333 kg/ha) of N and 100 Ib/acj
(111 kg/ha) of P as a broadcast application. All plots received
an application of 100 lb/A(lll kg/ha) of K each spring before
plowing until 1974 when the K fertilizer application was doubled.
Limestone has been applied at rates calculated to maintain the
1613
-------
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1613
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soil pH between values of 6 to 6.5. The four treatments were
replicated four times in a randomized block design.
The amounts of sludge applied each year on maximum treated
plots are shown in Table Ł.
Corn grain yields in response to sludge applications are
shown in Table 5_. Grain yields were significantly increased
by sludge treatment over those obtained from heavily fertilized
control plots in only 1970 and 1973, when total applied sludge
solids on maximum treated plots amounted to 118 and 139 ton/acre
(52.7 and 62.6 mT/ha) in each of the respective years.
Since 1969 a similar experiment has been conducted with digested
sludge on the Blount silt loam using soybeans (Hinesly, et al., 1974).
Soybean yield responses were compared with respect to applications
of phosphorus 105 Ibs/A/yr. (118 kg/ha/yr.), and water and sludge
applied at the rates shown in Table 6_. Yield responses of soybeans
to sludge, phosphate and water treatments are shown in Table 7_.
Soybean yields in Table 7_ were shown to have been increased
significantly by sludge application during each of the five years.
However, in 1972, the response to maximum sludge treatment was
negative. Annual applications of superphosphate did not affect
soybean yields even though the site soil, a silt loam was somewhat
deficient in available phosphorus. In 1972 when sludge applications
had a significant negative affect on soybean yields, the plant
toxicity symptoms observed may be attributed to phosphorus toxicity,
a soil-plant salt interaction, or both.
1620
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1623
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Metal Translocation
The implication in the proposed Hazardous Haste Management
Regulation is that some heavy metals cannot be safely disposed of
*
on crop land. The best contradiction to this claim lies with the
Werribee Farm. Melbourne has operated a sewage farm since 1897 at
Werribee, Australia. Johnson, e_t ad. (1974) analyzed tissue from
selected sites on the farm and they concluded that in regard to
food chain effects, forage contained neither excessive nor deficient
amounts of trace elements. These results are very significant for
helping to determine the long-term effects of slusdge application
to land.
The Agronomy Department of the University of Illinois has been
conducting, for 7 years, experiments to evaluate tie environmental
effects of sludge application to land as mentioned previously.
Metal uptake by agronomic plants in these experiments has been
studied. Table j[ shows the element concentration in the tissues
of mature corn receiving sludge at the rate described in Table Ł.
The Zn and Cd contents in corn leaf, grain, and mature plant
residues were increased by greater annual applications of sludge.
However, metal concentrations in corn plant tissues were not
elevated by increasing years of sludge application at the high
rates used in this experiment. Concentration lewis of Zn and Cd
reached a fairly constant value in corn plant tissue and these
levels were not changed by increasing accumulati-ve amounts of
sludge applied in subsequent years. With respect to Cu and Ni con-
r'entrations in the corn plant tissues, there was in some years •
ijttle apparent relationship with the amount of sludge applied.
1625
-------
For example, in 1971, the Cu. levels in corn grain were significantly
reduced by increasingly greater application rates of digested
Sludge. There is evidence that the Cd, Cu, Ni and Zn levels in
tissue do not reflect the accumulative amounts of digested sludge
applied during the experiment.
Table Ł shows the element concentration in the tissue of
soybeans receiving sludge at the rate described in Table 6_. An
examination of the data shows that Zn, Ni, and Cd contents of
soybean tissues were increased by different sludge application
rates. Compared to the amounts in plants from control plots, the
Cu concentration in plant tissues either remained the same or
decreased. The greatest increase in metal concentration occurred
in 1972 when the phosphorus or salt interaction occurred. With
respect to the treatments the data suggest that plant metal levels
remain nearly the same each year and they do not reflect the
accumulative yearly applications of sewage sludge.
The corn and soybean data presented in Tables Ł and 9_ show
that under the local soil, climatic and experimental conditions
during the seven year study (1968 - 1974) that no phytotoxic
conditions or abnormal metal concentrations resulted from heavy
metal translocation in a Blount silt soil receiving up to 164
tons/acre (369 mT/ha) of sludge on continuous corn and up to
114 tons/acre (255 mt/ha) on continuous soybeans.
1626
-------
TABLE 8
Average contents of several chemical elements in tissues of corn continuously
grown and annually fertilized with various loading rates of digested sludge.
Values are ppm dry weight of plant tissues (Unpublished Data, Hinesly, et al).
I Year
Loaf
Ck
'A Max to Max
Grnin
Max | Ck
'4 Max
•1 .Max
Max
filature Plont Residues
Ck
i Max ' ;•> '.'a
,..ax
ZINC mm
1970
1971
1972
1973
53
23
56
60
85
95
139
113
133
158
253
223
! 212"
! 259"
j 381 "
328"
32
24
22
29
40
36
29
37
50
36
40
51
i 65"
53"
1 50"
58"
43
39
133
94
237
193
340
337"
COPPSI! fj?ni
1970
1971
1972
1973
8.9
10.4
12.4
9.0
9.2
13.6
7.8
10.2
9.5
14.3
6.6
3.7
5.6
15.4
7.2
2.5
2.4
2.8
2.4
3.6
2.6
3.0
2.6
2.9
2.2
2.9
2.6
4.2 '
2.0 •
3.1
2.0
10.0
2.3
8.2
2.3
8.5
2.7
7.8
3.0
NICtdiLpuft
1970
1971
1972
1973
1.5
1.5
3.5
1.1
1.9
1.5
2.9
2.6
2.2
1.9
1.7
4.3
2.6
2.4"
3.0
2.3
0.3
0.6
1.2
3.0
0.8
0.8
0.9
2.2
1.2
1.3
1.3
3.1
•3 C "
3.5
2.2"
1.7
1.4
0.7
1.2
0.7
1.6
0.7
2.0
1.4'
CADi.JUf.'! fjyni
1970
1971
1972
1973
0.9
0.2
1.1
0.4
1970
1971
1972
1973
107
93
159
126
3.0
3.4
9.0
2.3
5.3
7.5
10.8
6.9
84
93
160
US
101
93
154
124
11.6-
10.3"
22.2"
13.7"
0.30
0.14
0.14
O.OS
112
90
144
us
36
19
30
0.60
0.70
0.45
0.15
HiOH
33
16
30
0.79
0.65
0.83
0.25
pirn
34
20
32
1,00"
0.92"
1.10"
0.61"
0.4
0.3
36
19
35
211
90
4.8
0.8
8.9
4.2
231
99
286
32
13.2"
12.9"
166
61
'"lAiSGAi-'BE p!>ni
1970
1971
1972
1973
81
59
64
64
83
57
60
40
92
79
126
44
116'
151 "
180"
54"
6.0
3.4
8.2 :
6.0
2.4
6.8
5.5
3.1
6.8
8.2"
4.6"
6.6"
35
29
38
31
47
38
72'
36
Significant at 5% level.
Significant at 1% level
THE METROPOLITAN SANITARY DISTRICT
OF GREATER CHICAGO
ENGINEERING DEPARTMENT
D.F.M. & W.B. MARCH 197S
IG27
-------
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1628
-------
TABLE 9
Average contents of several chemical elements in tissues
of soybeans fertilized with various loading rates of
digested sludge. Values are ppm dry weight of plant tissue
(Unpublished Data, Htaesiy, et ol).
Year
Leaf and Petiole
H20
Ck
U Max
'/; Max
Max
Seed
H,0
Ck
'/< Max
7: Max Max
Z!MC ppm
1970
1971
1972
1973
29
77
45
42
mm
49
50
41
80
107
146
82
--
162
222
122
180
203
444
191
59
57
50
49
58
58
51
53
68
72
72
69
73 83
81 85
82 94
77 85
COPPFP. nsm
1970
1971
1972
1973
4.9
6.6
8.9
7.5
mm
5.9
8.4
6.6
5.7
6.6
8.6
7.5
.-
6.7
8.0
7.8
4.1
5.9
9.0
6.3
13.1
10.8
13.0
14.0
14.0
11.4
13.0
14.0
14.9
10.7
12.0
13.0
12.5 12.2
9.6 9.5
13.0 : 14.0
11.0 14.0
H!C2El
1970
1971
1972
1973
3.5
2.7
3.0
3.4
• •
3.0
2.0
3.7
4.7
4.5
5.1
4.5
..
5.2
6.3
6.3
4.3
5.5
10.9
5.4
6.1 | 10.1
7.4
4.2
5.3
11.7
6.5
8.6
9.4
13.4
9.9
10.5 10.5
15.7 17.8
10.2 : 16.5
8.4 9.9 10.6
970
971
972
973
0.42
0.26
0.33
0.50
--
o.so
0.54
0.47
1.70
0.90
2.14
1.10
--
3.16
4.46
2.00
10.3
7.0
13.9
4.2
0.12
0.35
0.19
0.20
0.12 ! 0.38 i Q.60 1.08
0.33 | 0.47 0.96 1.61
0.35 ! 0.55 1.00 3.06
0.25 ! 0.36 0.59 0.79
THE METROPOLITAN SANITARY DISTRICT
OF GREATER CHICAGO
ENGINEERING DEPARTMENT
O.F.M.&W.B. MARCH 197S
1623
-------
Animal Responses
Of concern to some individuals regarding the use of sludge
fertilized forage for animal feed is the possibility of problems
with animal health. Naturally, the grazing animals will have
direct contact with the sludge while they are grazing. This is
not to say that grazing animals should come into contact with
municipal sludge immediately following application. On the con-
trary, it is advisable to allow an 8 to 10 day resting period
following sludge application to pastureland or alternatively that
the applied sludge be allowed to dry before resuming grazing.
The Board of Works Sewage Farm at Werribee, Australia was
established in 1897 as a sewage farm serving the City of Melbourne,
Australia which has a population of about 2.5 million people
(Johnson et al., 1974). The daily amounts of raw sewage arriving
at the farm vary but the average flow in 1973 was 144 MGD (546,000
m-Vday). This farm is about 10,376 acres (4,200 ha) and is a raw
sewage irrigated pastureland. The irrigated pastures are sown with
a mixture of grasses and legumes to provide balanced production.
Raw sewage is applied in a flood irrigation method to a depth of
4 inches (10 mm). Just before irrigation, the grazing animals are
removed and the surface is allowed to dry one week before they
are returned.
Despite the fact that the pasture is irrigated with essentially
raw sewage, the health of the animals bred at the farm is excellent
and there is no prohibition of the sale of the animals for human
consumption. Between July 1946 and June 1972, out of a total of
1630
-------
116,266 animals marketed there were only 29 rejections or 0,025%.
In an Australian area where pastureland is used with no sewage
products, namely, Victoria and Tasmania, a rejection rate of .041%
was recorded based on examination of 506,625 animals and 208 re-
jections.
Clearly, the Australian data indicates that if there is no
difficulty in the rejection rate of animals foraging on pastures
fertilized with raw sewage, one can conclude that there should be
no difficulty with the use of digested sewage sludge.
Fitzgerald and Jolly (1974) studied the possibility of trans-
mission of parasitic organisms from digested sludges sprinkled on
Sudax grass to cows and/or calves. In this study, 91 pregnant
Hereford-Angus-Charolais cows were released on municipal sludge
fertilized Sudax pasture. The sludge was liquid digested sludge
from the Metropolitan Sanitary District of Greater Chicago. A
control herd of 19 pregnant cows were pastured on Sudax in a land
area not receiving digested sludge.
At monthly or shorter intervals fresh individual or random
fecal samples were examined to determine the species and relative
abundance of parasites of each herd. In addition, frequent visual
observations of the animals were made. A comparison was made of
the parasite species present, egg and oocyst discharge quantity,
and visual clinical signs between the 2 groups of animals to
determine the effects of sludge on the health related factors in
the pasture environment.
After the examination of 614 fecal samples from the cattle
foraging on the sludge fertilized pasture and 255 samples from the
S -\ r .*
Ibol
-------
control herd, it was found that there was no significant difference
between the two groups. In Figure J[ is plotted the nematode egg
discharge during 14 months of the study. Generally, the test and
control herds followed a similar pattern with levels of nematodes
remarkably similar. mhe average discharge of coccidian oocysts
seen in Figure II was actually higher in the control than the test
animals over a 14-month period.
Fitzgerald and Jolly (1974) concluded from this study that
sludge irrigation had not introduced unusual or additional common
bovine pathogens to the pasture environment, nor otherwise increased
the incidence of common bovine disease. Digested sludge in the
pasture environment has not influenced the normal parasitic load
of the herd.
The available evidence indicates that the use of municipal
sludge as a fertilizer for pastureland is a practice without hazard
to the health of the grazing animals. There is no available
evidence to suggest that the health of grazing cattle would be
affected. It would appear that many countries in the world would
wish to pursue the use of municipal sludge in growing forages for
cattle production. As the demand for meat increases among the
nations of the world, and wxth the increasing problems of obtaining
fuel for producing sufficient nitrogen fertilizer, it would seem
that municipal sludges would be a useful product in increasing the
productivity of the pastureland.
1602
-------
800
200-
o
E
Ł
o
«>
a.
a-
-------
FIGURE ii
Cumulative total coccidlan oocysts per gram of feces
per animal based on random or individual monthly
field samples (Unpublished Data, Fitzgerald,et al).
a
6
a
e
o
o
o
O
2500
2000
1500
1000
500
Control Animals
Test Animals
Aug Stp Oct Nov D»c Jan Ftb Mar Apr Ma/ Jun Jul Aug Sep
I97S
1974
THE METROPOLITAN SANITARY DISTRICI
OF GREATER CHICAGO
ENGINEERING DEPARTMENT
W.B.
MAR. 1975
-------
SUMMARY
The District is very concerned that the EPA does not make
unnecessary and inoperable regulations on the disposal of municipal
sewage sludge. The potential problems of disposing of ca. 10,000
dry tons of sludge per day in the United States by some exotic
method could result in some astronomical difficulties,
Research findings indicate that land utilization of municipal
sewage sludge is the best available method of handling massive
quantities of these materials with the least insult to the environ-
ment.
It is our recommendation that municipal sewage sludge not be
considered as a hazardous waste.
Ibot)
-------
LITERATURE CITED
1. Berrow, N. L. , and J. Webber. 1972. Trace elements in
sewage sludges. J. Sci. Fd. Agric. 23:92 - 100.
2. Dean, R. B. 1973. Disposal and reuse of sludge and sewage.
In Proc. of Conf. on Land Disposal of Municipal Effluents
and Sludges, Rutgers Univ., New Jersey, "Mar."
3. Fitzgerald, P. R., and W. R. Jolly. 1974. The use of
sewage sludge in pasture reclamation: parasitology,
nutrition and the occurrence of metals and polychlorinated
byphenyls. Unpublished report to the Metropolitan Sanitary
District of Greater Chicago from the College of Veterinary
Medicine, University of Illinois, Urbana.
4. Hinesly, T. L., 0. C. Braids, R. I. Dick, R. L. Jones, and
J. A. E. Molina. 1974. Agricultural benefits and environ-
mental changes resulting from the use of digested sludge
on field crops. Report from the University of Illinois,
Urbana, to the Metropolitan Sanitary District of Greater
Chicago, unpublished.
5. Johnson, R. D., R. L. Jones, T. L. Hinesly, D. J. David.
1974. Selected chemical characteristics of soils, forages
and drainage water from the sewage farm serving Melbourne,
Australia. Department of the Army, Corps of Engineers.
6. United States Environmental Protection Agency. 1974.
Technical bulletin on evaluation of land application
systems. Office of Water Programs Operations, Washington,
D. C. 20460.
16ob
-------
STATE OF MICHIGAN
— RL T JOHNSON
1 LUT*L> WILLIAM G MILLIKEN, Governor
ueAN PfUOQEON
SNELL DEPARTMENT OF NATURAL RESOURCES
HOWARD A. TANNER, Director
CHARLES 0 VOUNQLOVE
January 30, 1976
U.S. Environmental Protection Agency
Office of Solid Waste Management Programs (AW 565)
Washington, D. C. 20460
Attention: Mr. John P. Lehman, Director
Hazardous Waste Management Division
Dear Mr. Lehman:
This letter is in response to Federal Register, Vol. 4, No. 181,
Wednesday, Sept enter 17, 1975 Notice of Invitation to submit comments
on hazardous waste management. It is being submitted by the Hazardous
Waste Disposal Committee in Michigan. This committee was formed by
the Environmental Protection Branch of the Michigan Department of
Natural Resources. It consists of representatives of various state
agencies, (Oil and Hazardous Materials Control, Solid Waste Management,
Water Quality Appraisal, Public Health), universities and industries.
The committee was charged with the responsibility of preparing recommen-
dations regarding the definition of hazardous wastes, environmentally
acceptable disposal methods and prepare proposed regulations to supple-
ment existing laws. As a result, this group has spent considerable
time studying many of the matters which you listed in your discussion
topics.
We urge that you consider the use of a decision model in defining a
hazardous waste. There is considerable risk in the use of lists of
compounds. Principally, lists of compounds are often incomplete,
become large and difficult to use as a tool to solve a problem.
Our committee has specifically addressed several questions listed in
the subject register.
We believe that the generator is responsible for ultimate environmentally
safe disposal of hazardous wastes. In Michigan, however, the licensing
of liquid industrial wastehaulers lifts some of the burden of responsi-
bility. It becomes necessary that the generator utilize a hauler licensed
and approved to transport the particular type of waste to an approved
disposal facility. The cost should be borne by the generator but will
ultimately be reflected in product cost.
1637
-------
John P. Lehman -2- January 30, 1976
Recovery and reuse programs should be directed most vigorously at non-
renewable resources, particularly those in short supply. Incineration
should be used to destroy difficult to handle wastes (PCB's, PBB's, etc.).
Research in effective heat recovery methods should be encouraged. Land
emplacement of hazardous wastes should be permitted only when adequate
safeguards for groundwater are provided and an ongoing monitoring program
is required.
We believe that reports should be prepared by the generator, transporter
and disposer of hazardous waste. These records should be available to
regulatory agencies to assure that safe disposal has occurred. These
records should include volume and such analytical data as necessary to
determine the level of risk posed by the wastes.
In 1970, the year Michigan implemented its Liquid Industrial Waste
Haulers licensing act (Act 136, P.A. 1969) insurance companies were
very reluctant to provide the necessary surety bond. The risk was
undetermined. Presently, bonds as required by statute, are readily
available.
We urge that any federal programs which may be implemented would be an
overview approach for states which presently have hazardous waste manage-
ment programs. Regulations or guidelines should provide a uniform
national approach to hazardous waste management.
Sincerely,
David M. Dennis, Chief
Oil & Hazardous Materials Control
Section
DMD:ns
1638
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The Mid-Ohio Health Planning Federation
POST OFFICE BOX 11S9 COLUMBUS, OHIO 4S116
September 24, 1975
MM un UOAO man
Mr. John P. Lehman, Director
Hazardous Waste Management Director
Office of Solid Waste Management Programs
AW-565
U.S. Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Lehman:
I read with great interest the announcement of the Hazardous Waste
Management Public Meetings in the September 17, 1975, issue of the
Federal Register. My Agency has for some time had great interest and
activity in one category of hazardous waste, that is waste emanating
from health care institutions. I would like to share with you some of
our findings and guidelines.
Attached are two items of correspondence which represent the culmination
of our studies and activities in the disposal of solid waste. One is a
letter from the Ohio EPA describing those components of hospital solid
waste which might be considered hazardous. I would like to mention that
these six named components, by our studies, represent roughly only 3%
of the waste generated fay a general community hospital in Columbus.
The second letter is an agreement by the City of Columbus to accept all
our hospital solid waste (30 tons a day), less the hazardous components,
and consider it normal municipal waste.
I hope our findings and actions will be useful to you. I feel too often
hospitals are considered large generators of hazardous waste, which they
definitely are not. If you have any questions about our studies and
activities in this area, please do not hesitate to let us know.
Yours truly,
THE MD-OHIO HEALJH PLANNING JEDERAT,
Charles A. Turner, III
Director
Extended Care Systems Planning
CAT/djb
Attachments •- Ł>•• q
-------
October 30, 1974
QNciFft
JohnJ. uilligan
(aovernor
Or. Ira L Whitman
Director
Mr. Charles A. Turner, III
Director
Environmental Health Planning
Mid-Ohio Health Planning Federe.tio.i
P.O. Box 2239
Columbus, Ohio 43216
Dear Mr. Turner:
This letter is in response to your lettet of October 16, 1974,
concerning the Ohio Environmental Protection Agency's position
on the disposal of hospital solid waste.
This Agency realizes that the amount of wastes generated in
hospitals have increased tremendously over the years and that
an efficient and economical method of disposal of this waste needs
to be found. This Agency also recognizes that the composition
of hospital waste has changed due to the increasing use. of dis-
posables and the improved methods of isolating pathogen contaminated
vaste from the main waste stream.
Hospital waste can contain several potentially hazardous components,
namely:
1. Human wastes emanating from pathology, surgery
Oi% autopsy
2. Experimental animal tissue waste
. 3. Contaminated wastes emanating from care for patients
which are presently }n isolation either because of
t diagnosed communicable disease or prior to diagnosis
when a prognosis of such communicable disease has been
made, and
4. Radioactive wastes.
5. Used needles, syringes, and other such Implements.
6. Waste drugs and medicines.
16UG
-------
hr. Charles A. Turner, III
October 30, 1974
Paue Two
If the above hospital solid waste components are kept out of the
solid waste stream the remaining hospital solid waste should have
the same environmental and health hazard impact as municipal refuse.
These materials could be landfilled, incinerated, pulverized,
utilized in energy or material recovery processes, or disposed
by any other normal disposal method. - The Ohio Environmental Protection
Agency would not require any special handling of disposal methods
for the wastes. The Agency would still -require that "all precautions
be taken to properly dispose of the remaining potentially hazardous
-wastes.
I hope this has explained the Ohio Environmental Protection Agency's
position on the disposal of hospital waste. If you have any further
questions or if we can be of assistance to you in any way, please
contact me.
Yours truly,
DONALD E. DAY
assistant Chief
Division of Waste Management
and Engineering
DED:WK:pd
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CITY OF COLUMBUS
RICHARD D. JACKSON. P.«. ROBERT C. PARKINSON
OHIO AMI-TAUT OI..CTO.
DEPARTMENT OF PUBLIC SERVICE
ZIP CoDCt 43215
Hoveinber 15, 1974
The Mid-Ohio Health Planning Federation
Mr. Charles A. turner, III
Director
Environmental Health Planning
P. 0. Box 2239
Columbus, Ohio 43216
Dear Mr. Turner:
I wish to acknowledge and thank you for your letter dated November 13,
1974. I have arranged for Mr. Hunt to attend your meeting on November 26,
1974.
In response to your two (2) questions, the following information is pro-
vided:
1. It is correct to conclude that if the hospitals of Franklin County
separate the specific materials cited by the Ohio EPA from their
solid waste, then the remainder will be acceptable in any municipal
refuse system the City of Columbus may operate in the foreseeable
future.
2. We do not presently have firm figures on disposal fees, however,
we do estimate the charge of $6-8 per ton.
Very truly yours,
DEPARTMENT OF PUBLIC SERVICE
RDJ:RJH:bab
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LAND OF QUALITY POODS
STATE OF MINNESOTA
DEPARTMENT OF AGRICULTURE
STATE OFFICE BUILDING
SAINT PAUL, MINN. 55155
December 1, 1975
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs (AW-565)
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Lehman:
In accordance with Federal Register Notice, Volume 40, No. 181, dated
Wednesday, September 17, 1975, the Minnesota Department of Agriculture
requests that the following statement be Included in the record on
Hazardous Waste Management.
The Minnesota Department of Agriculture sees hazardous waste management
at this time and for this purpose as involving the management of excess
or unwanted pesticide materials and pesticide containers. It suggests
that the pesticide-area should further be considered when hazardous waste
management regulations or guidelines are being developed as having both
obsolete highly toxic materials and also having those materials that are
less toxic and which have just recently been cancelled or suspended.
The Department sees as a source of such materials—agriculture, the home
owner, industrial or manufacturing firms, and public organizations such
as utilities and hospitals.
It is suggested that at least the following considerations must receive
substantial attention in the development of procedures for disposing of
such materials:
1. What is the toxicity-hazard to man and the environment both
immediately and in the long run?
2. What are the practical problems for handling such materials?
3. What are the economic factors and considerations, that is total
cost, and who is responsible for assuming these costs?
4. What are the transportation problems and what is the available
means of transportation?
ENJOY THE HIGH QUALITY AND INFINITE VARIETY OF MINNESOTA FOODS
EQUAL OPPORTUNITY EMPLOYER
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Mr. John P. Lehman December 1, 1975
Page 2
Disposal, a major consideration, has not been included in the above because
we see this as a separate item. The first item relating to disposal is the
collection of the products referred to in paragraph one. Collection can be
accomplished; however, collection alone Is not disposal and we will comment
further on this. Open burning of the less toxic materials and the paper
containers is one means of disposal that is, in many areas, relatively
adequate for the agricultural community. It is not as practical for the
other sources.
Burying of excess materials and containers Is a further means of disposal.
This is a possible solution for all sources, however, much more appropriate
for smalI amounts such as the home owner might have. Disposal by burying in a
landfill is a means that is appropriate for all sources, however, we suggest
that it, too, should be limited to small amounts, probably those from the home
owner and not from other sources.
Incineration Is certainly the most desirable means to dispose of excess
materials and containers; however, relatively few areas of the country have
adequate incineration facilities. Therefore, we must include with Incinera-
tion the problems of handling transportation and the costs associated with
these.
Reprocessing of all appropriate materials that can be returned to the manu-
facturer is another means of disposal. Here, too, there may well be a problem
of transportation because of the regulations presently In effect under the
Department of Transportation.
One means of disposal not looked upon with favor by many individuals and
organizations is to continue the use of the product In accordance with label
directions until it Is all gone. This reduces transportation problems,
reduces costs, and when used according to label directions, should not create
undue hazard to man or the environment.
The Minnesota Department of Agriculture has had no difficulty in arranging to
collect excess materials and containers and has also forwarded a suggested
experimental plan for collection to the Environmental Protection Agency.
However, collection, as we have indicated, is not a problem but disposal
after collection becomes an even greater problem than before because agencies
or firms have larger amounts concentrated In one location. This, in turn,
creates greater problems of handling and transportation as well as possible
hazard to man and the environment. Unless research agencies and regulatory
agencies, both at the federal and state level, arrive at practical suggestions
for disposal, collection alone is not the answer. Minnesota has several
examples of this. One relates to the finding of arsenic burled in the 1930's
and recently contaminating a well. The well was contaminated because It
happened to be placed through the spot where the arsenic was buried. Some
several hundred cubic yards of sand and earth could have been removed and
spread over several hundred acres of land or other means of reducing the
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Mr. John P. Lehman December 1, 1975
Page 3
possible movement of the arsenic in the soil could have been taken, however,
federal and state agencies could not agree. We still suggest that the best
means to handle this situation would have been to dilute the effect by
spreading the material as Indicated. A further solution would have been to
cover the area with an impervious material so that surface water would no
longer assist In moving the material in the soil.
We also have in Minnesota a situation where some excess material was burled
in a landfill, and the public is now concerned that this material may even-
tually contaminate some water supplies. As a result, they are requiring that
some $80,000 to $100,000 be expended just to locate the material to say nothing
of disposing of it.
As shown with the two examples given, we again suggest that disposal of such
materials is a critical problem and one which the Minnesota Department of
Agriculture and other state agencies are well aware of. It is also one which
no agencies have addressed adequately and unless addressed along the lines of
practicality for the considerations listed, will continue to be a problem
regardless of any other actions taken by state or federal regulatory agencies.
This is an area that we have long felt and indicated to many should have been
addressed even before the classification of such products was considered.
Should you wish further suggestions or comments please contact us.
Sincerely,
MINNESOTA DEPARTMENT OF AGRICULTURE
Roll in M. Dennistoun, Ph.D.
Department Administrator
RMD:hk
cc: Emery Lazar, EPA, Washington, D.C.
Charles Lincoln, EPA, Chicago
-------
EUGENE J WIN
EXFJ U1IVE1 D 3
Sofifl ^Ulirtes v-Ainnagement Association
1730 RHODE ISLAND AVENUE NW • SUITE 800 • WASHINGTON, DC 20036
TELEPHONE (202) 659^1613
January ?f>, 1975
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs
Environmental Protection Agency
Washington, D.C. "O'tGO
Dear Mr. Lehman:
'We would like to clarify that our letter on hazardous waste management,
dated December 23, 1975, was in response to the public hearings held
in December, 137^. Please accept our statement as part of the public
record.
cc. Allen Coorson
INSTITUTE OF WASTE TECHNOLOGY
• CHEMICAL WASTE COMMITTEE
• NATIONAL SANITARYLANDRl L COMMITTEE
• RESOURCE RECOVERY COMMITTEE
WASTE EQUIPMENT MANUFACTURERS INSTITUTE
-------
Wionaf So&fl1 pastes ^-Management Association
1730 RHODE ISLAND AVENUE NW • SUITE 800 • WASHINGTON, DC 20036
TELEPHONE (202) 659-i613
UE«LNj-J/E™'aJ"""-,
-------
Mr. John P. Lehman
December 29, 1975
transfer at the time of each transaction, the responsibilities and hence
liability should remain a shared liability between the generator and dis-
poser of the wastes. The responsible agency should be required to develop
a system of recordkeeping to tabulate the nature, volume and location of
hazardous wastes generated and/or disposed of within the state. The Asso-
ciation has recommended that the recordkeeping consist of a manifest form.
The manifest should identify the amount of the waste, the general chemical,
physical and mineral composition of such waste identified by probable max-
imum and minimum percentages; as well as, information on antidotes, first aid
and safety measures. The person transporting or handling the hazardous waste
would be required to have the manifest in his possession while transporting
or handling the hazardous waste. The manifest is then transferred to the
person responsible for processing or disposal of the waste at the time of de-
1i very.
The generator should be responsible for identifying on the manifest the
origin and destination of the waste. He should also be required to insure
that the wastes are properly labeled, that they are processed and/or disposed
of at permitted sites and maintain records at the point of generation. The
transporter of hazardous wastes should be responsible for completing the
manifest form in conjunction with the generator of the hazardous wastes, insure
that all hazardous wastes are brought to a permitted hazardous waste processing
and/or disposal site and maintain his copy of those records. The hazardous
waste processor and/or disposal site operator should be required to acknowledge
receipt of the hazardous wastes accompanied by the manifest form, assure that
all hazardous wastes accepted are processed and/or disposed in accordance with
the applicable regulations, standards and guidelines promulgated by the Depart-
ment, and maintain records of all hazardous wastes treated and/or disposed. In
addition, responsible state agency procedures should be developed to insure that
trade secrets used by a person regarding methods for generation, handling, pro-
cessing and disposal of hazardous waste, which are disclosed to the Department,
be kept confidential and not otherwise disclosed without the consent of the per-
son involved.
A critical element of any hazardous waste program is the development of a
definition of hazardous wastes. Defining hazardous wastes becomes more
complex than defining a hazardous material since wastes are a mixture of
different materials not pure chemical components, and often these materials
cannot be readily identified. A general definition of hazardous wastes
should focus upon five basic questions:
Hazardous to What? Injury or harm can be sustained by a variety of
entities: humans, animal life, vegetation, property, and the envir-
onment. Primary concern has typically been associated with human
health and property. More recently, attention has also turned to
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Mr. John P. Lehman
December 29, 1975
other living organisms and the environment. The final term is some-
what of a catch-all which, if taken literally, includes the previous
three. Whereas in years past, general legislative definitions could
easily have been restricted to human health; current thinking calls
for consideration of all potential receivers, both human and non-
human.
Hazardous for What Reason? Once the injured entities have been
defined, it is necessary to delineate the attributes of hazards
that are to be considered. Candidate attributes include: Ability
to bioconcentrate; toxicity (Via all Routes); flamiability; ex-
plosiveness; reactivity; irritation, or sensitization potential:
and coorosivity. Radioactivity, genetic change potential, and
etiology, need not be considered since a large body of law and
supporting regulations exist to deal with these materials. Radio-
activity may also be considered as a subset of toxicity, as can
genetic change potential. Genetic change potential and etiology
are often grouped in a more general category such as "otherwise
damaging" because of vagueness in defining them. Specification of
which of these attributes are of concern in the definition of
hazardous wastes, clearly identifies the types of criteria to be
applied in designating specific wastes.
Hazardous to What Degree? In dealing with hazardous wastes, it
must be recognized that a hazard is not an either/or situation,
but a matter of degree. That is, hazard for any given material
is a continuous function dependent on the level and conditions
of exposure. Therefore, some sense of threshold must be estab-
lished to identify the point at which hazard becomes significant
enough to warrant regulation. This can be dealt with qualitatively
for definitions which are destined to be included in a legislative
definition through use of terms like "substantial" or "significant".
A more quantitative treatment is required for a truly working definition
as discussed in succeeding sections.
Hazardous at What Times? A working definition of hazardous wastes
should also address the question of when the hazard is existent.
This can be viewed in a functional manner, e.g., during handling,
transportation, treatment, storage, and/or disposal; or it can be
viewed in a time-related sense, e.g., present hazard or potential
future hazard. The two views are not completely independent.
Handling, transportation, and treatment activities are concerned
almost exclusively with present hazards. Storage and disposal act-
ivities may involve both present and potential future hazards. Many
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Mr, John P. Lehman
December 29, 1975
documented incidents involving damage or injury from improper haz-
ardous wastes management surfaced some time after storage or dis-
posal was effected. Since damage is not minimized by the nature of
the activity under way at the time, the time-related view, using
present or potential future to delineate at what times a waste is
hazardous, is appropriate.
Hazardous Under What Conditions? It is finally important to note
the conditions under which the hazard is evidenced. Pertinent factors
include quantity, concentration, form, and the presence of other ma-
terials which may add to or detract from the hazard. These factors
are very complicated and consequently difficult to deal with in any
but a general manner in the context of a legislative general definition.
To insure proper implementation of the general definition, hazardous wastes
should be further defined by specific, quantitative criteria developed by
the regulatory agency. In formulating a criteria emphasis should be focused
upon the waste itself rather than the individual constituents in the waste.
If the focus is placed on the individual constituents a waste could incor-
rectly be declared hazardous because it contains a substance such as mercury
or phenol which is considered hazardous. This fails to account for the fact
that dilution, neutralization, chemical reaction, or the presence of inter-
acting materials can mitigate the potential hazard associated with hazardous
component in wastes. Therefore, the criteria should be applied to the waste
itself to insure proper consideration to the degree and conditions of the
hazard involved. When issuing permits the Department should also be allowed
to adopt varying guidelines and standards for different areas of the state
depending upon population density, climate, geology and other factors rele-
vent to hazardous waste management. In formulating a criteria for identifying
hazardous waste we suggest consideration be given to the following:
Does the waste contain radioactive constituents greater than a maximum
permissible concentration level?
Is the waste subject to bi concentration?
Is the waste flammable in NFPA Category 4?
Is the waste reactive in NFPA Category 4?
Does the waste have an oral lethal dose less than a certain amount?
What are the measures of the inhalation toxicity of the waste as a gas,
mist or dust?
Is the dermal penetration toxicity less than a certain level?
IS50
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Mr. John P. Lehman
December 29, 1975
Is the dermal irritation reaction less than a certain level?
How does the waste behave in an aquatic environment?
Is the waste phytotoxic?
Does the waste cause genetic changes?
To insure proper implementation of a hazardous waste program and continuity
of existing operations the Association recommends that existing processing
facilities and disposal sites be granted a permit variance subsequent to
sufficient evidence being presented at a hearing to assure that the facility
is or will be within a reasonable period of time, in compliance with the re-
gulations, guidelines or standards. NSWMA also recommends, to avoid costly
duplication of existing services and facilities, that the Department encourage
the utilization of private enterprise to the maximum extent in the planning,
design and management of hazardous waste management facilities.
In summary, the Federal role in hazardous waste management should involve
establishing guidelines for the regulation of the handling and disposal of
hazardous wastes. ' The guidelines should establish minimum performance levels
to be obtained by all hazardous waste management practices necessary to pro-
tect public health and welfare. The Federal government should also provide
technical assistance and provide the necessary coordination and dissemination
of information on technology and ongoing hazardous waste management practices.
Each state should be responsible for developing a statewide hazardous waste
management program. A specific agency should be charged with establishing
regulations and standards necessary to comply with the Federal guidelines.
Regulations should specify general requirements for the handling, processing
and disposal of hazardous wastes. Standards should be based upon perfor-
mance-oriented goals, rather than procedure oriented approaches. Finally,
It is critically important that Congress accurately recognize the proper
balance of responsibilities between the private and public sectors. The
private sector currently handles over 90% of the industrial waste. We
believe Federal policy and legislation should recognize the roles and re-
sponsibility of this industry and should provide for the maximum encourage-
ment and full utilization of the resources and capabilities of the organ-
izations in this industry.
Warren T. Greg
Director of LtoislbtivS Affairs
WTG/dam
1G51
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CapitoTr-e&mplex
STATE OF NEVADA
DEPARTMENT OF HUMAN RESOURCES
DIVISION OF HEALTH
CARSON CITY. NEVADA MOMX 89710
November 18, 1975
Mr. John P, Lehman, Director
Hazardous Waste Management Division
Office of Solid Haste Management Programs (AW-565)
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Lehman:
Thank you for bringing to our attention the public meetings you are holding
on Hazardous Waste Management (FRL 432-5). While this office will be unable
to attend you meetings in person, we wish to submit this as our position
for the record.
It is our opinion that the regulations on Hazardous Wastes and their Management
are not only necessary, but overdue. Several accidents and near accidents
in this State have served to further point out this need.
The Discussion Topics (Federal Register 40:181) about which we are most
concerned, are 6, 11, 12, 15 and 16. In this State we have a special
problem since we have several active Federal Facilities: e.g., Nellie A.F.B.,
Fallen N.A.S., Tonopah Test Range, and the Energy Research and Development
Administration's Nuclear Test Site. In addition, because of the geography of
this State, hazardous wastes must be transported over long distances. In
these areas of the State, it is especially important that local emergency
response personnel be trained to handle hazardous waste accidents, since
outside help is not readily available.
It is our opinion that any program dealing with the management of Hazardous
Wastes should include specialized training for first line emergency responders.
This training would include management of the incident, proper care of such
victims and preventative measures.
Sincerely
/ JAMES P. HAWKE
Chief, EMS Planning Section
CC: Reba L. Chappell
Chief, EMS Section
Dr. William Edwards
Chief, Community Health Services
JPH:sjb
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ew York State Department of Environmental Conservation
0 Wolf Road, Albany, New York 12233
Ogden Reid,
Commissioner
January 21, 1976
Mr. John Lehman
Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs (AW-565)
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Lehman:
Herein are comments directed towards selected discussion topics
of hazardous waste management as published in the Federal Register,
dated 17 September 1975. Discussion topics responded to are those
involved within the program areas of the Division of Pure Waters.
Topic 1 - A definition of a hazardous material from an engineering
standpoint would include; an element or compound which when dis-
charged in any quantity into or upon waters of the State or ad-
joining shorelines, presents an imminent and substantial danger
to the public health or welfare, including, but not limited to,
fish, shellfish, wildlife, shorelines, and beaches. In other words,
any material which causes contravention of surface and/or ground-
water standards (see attachment #l) is a hazardous substance. From
a biological viewpoint a hazardous material is any substance in
sufficient quantity that causes a kill of fish or aquatic life or
causes excessive stress on aquatic organisms. For collection and
analytic/laboratory methods, the latest edition of Standard Methods
for the Examination of Water and Wastewater is used (see attachment
#1).
Topic 2 - The generator must retain ultimate responsibility for
proper handling, treatment, and/or disposal. The liability for
these functions must rest with the individuals involved during
their period of successive possession. The owner/operator of
the disposal area must bear the cost of assuring environmentally
safe disposal.
1653
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Mr. John Lehman - 2 - January 21, 1976
Topic 3 - A specific treatment for each waste must be considered
individually, but generally;
a) Recovery and reuse is preferred whenever possible.
b) Incineration may be necessary for substances such as PCB's
or other organic materials which contain fractions toxic to
biological processes and requiring a structural breakdown
before discharge.
c) Chemical treatment can be used to solubilize leachable toxic
pollutants.
d) Physical treatment is useful in separation processes.
e) Biological treatment may be required to destroy organic
material in order to avoid odors or reduce discharges of
high BOD substances to the environment.
f) Land emplacement is not a favorable method of disposal and
will require containment and treatment 6f polluted leachate.
Each of the above must be prohibited if discharges cannot meet
State and/or Federal Standards.
Topic 13 - This question can be answered with a self explanitory
list: DDT, Phenols, Mercxiry, Nutrients, Vinyl Chloride, PCB's,
Cadmium, etc., etc.
Very truly yours,
Eugene
Dire*
Division of Pure Waters
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A
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PART 701
CLASSIFICATIONS AND STANDARDS OP QUALITY AND PURITY
(STATUTORY AUTHORITY: ENVIRONMENTAL CONSERVATION LAW,
SECTION 15-0313 AND SECTION 17-0301)
Section
701.1 Definitions
701.2 Conditions applying to all classifications and standards
701.3 Class N
701.4 classes and standards for fresh surface waters
701.5 Classes and standards for saline surface waters
Section 701.1 DEFINITIONS. The terms, words or phrases used in
Part 700, 701, 702 and 704 shall have the following meaning.
(a) "Commissioner" shall mean the Commissioner of the
Department of Environmental Conservation.
(b) "Administrator" shall mean the Administrator of the
United States Environmental Protection Agency.
(c) "Best usage of waters" as specified for each class shall
be those uses as determined by the Commissioner and the
Administrator in accordance with the considerations
prescribed by the Environmental Conservation Law and
Public Law 92-500.
(d) "Approved treatment" as applied to water supplies shall
mean treatment accepted as satisfactory by the authorities
responsible for exercising supervision over the sanitary
quality of water supplies.
(e) "Source of water supply for drinking, culinary or food
processing purposes" shall mean any source, either
public or private. the waters from which are used for
domestic consumption or used in connection with the
processing of milk, beverages or foods. (When water is
taken for public drinking, culinary or food processing pur-
poses, refer to New York State Department of Health
regulations 10 NYCRR 170).
(f) "Primary contact recreation" shall mean recreational
activities where the human body may come in direct contact
with raw water to the point of complete body submergence.
1656
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Such uses include swimming, diving, water skiing,
skin diving and surfing.
(g) "Secondary contact recreation" shall mean recreational
activities where contact with the water is minimal and
where ingestion of the water is not probable. Such
uses include but are not limited to fishing and boating.
(h) "Saline surface waters" shall mean all waters which are
so designated by the Commissioner.
(i) "international boundary waters" shall mean those waters
to which the water quality standards developed and
adopted pursuant to the Boundary Water Treaty of 1909
and the Great Lakes Quality Agreement of 1972 apply.
(j) "Sewage", "industrial waste" and "other wastes" shall
have the meanings given in Section 17-0105 of the
Environmental- Conservation Law.
(k) "Estuary" shall mean the tidal portion of a river or
stream.
(1) A "thermal discharge" is one which results or would
result in a temperature change of the receiving water.
(m) "Heat of artificial origin" shall mean all heat from
other than natural sources including, but not limited
to, cumulative effects of multiple and proximate
thermal discharges.
(n) "Coastal waters" shall mean those marine waters within
the territorial limits of the state other than estuaries
and enclosed bays. Long Island Sound is designated as
coastal waters for the purposes of thermal discharges.
(o) "Enclosed bays" shall mean those marine waters within
the territorial limits of New York State, other than
coastal waters or estuaries, in which exchange of
sea water is severely limited by barrier beaches.
For the purposes of thermal discharges, the following
are designated as enclosed bays: Jamaica Bay,
Hempstead Bay, Great South Bay, Moriches Bay,
Shinnecock Bay and Mecox Bay.
.1857
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Section 701.2 CONDITIONS APPLYING TO ALL CLASSIFICATIONS AND
STANDARDS.
(a) In any case where the waters into which sewage, industrial
wastes or other wastes effluents discharge are assigned
a different classification than the waters into which
such receiving waters flow, the standards applicable
to the waters which receive such sewage or wastes
effluents shall be supplemented by the following: "The
quality of any waters receiving sewage, industrial wastes
or other wastes discharges shall be such that no
impairment to the best usage of waters in any other class
shall occur by reason of such sewage, industrial wastes
or other wastes discharges."
(b) Natural waters may on occasion have characteristics
outside of the-limits established by the standards.
The standards adopted herein relate to the condition
of waters as affected by the discharge of sewage,
industrial wastes or other wastes.
1658
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Section 701.3 CLASS N
Best usage of waters. Enjoyment of water in its natural condition
and where compatible, as source of water for drinking or culinary
purposes, bathing, fishing and fish propagation, recreation and
any other usages except for the discharge of sewage, industrial
wastes or other wastes or any sewage or waste effluent.
Quality Standards for Class "N" Waters
Items Specifications
1. Sewage, industrial wastes. None
or other wastes, waste
effluents or any sewage
effluents not having had
filtration resulting from
at least 200 feet* of lateral
travel through unconsolidated
earth.
2. Deleterious substances, hydrocarbons. None
substances which wculd contribute
to eutrophication or surface runoff
containing any of such substances.
* A greater distance may be required if an inspection shows that
due to peculiar geological conditions 'this distance is
inadequate to protect the water from pollution.
1659
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Section 701.4 CLASSES AND STANDARDS FOR FRESH SURFACE WATERS
The following items and specifications shall be the standards
applicable to all New York fresh waters which are assigned the
classification of AA, A, B* C,or D, in addition to the specific
standards which are found in this Part under the heading of each
such classification.
Quality Standards for Fresh Surface Waters
Items
Specifications
1. Turbidity
2. Color
3. Suspended, colloidal or
settleable solids.
No increase except from natural
sources that will cause a sub-
stantial visible contrast to
natural conditions, in cases of
naturally turbid waters, the
contrast will be due to increased
turbidity.
None from man-made sources that
will be detrimental to anticipated
best usage of waters.
None from sewage, industrial wastes
or other wastes which will cause
deposition or be deleterious for
any best usage determined for the
specific waters which are assigned
to each class.
4. Oil and floating
substances.
5 . Taste and odor^producing
substances, toxic wastes
and deleterious substances
No residue attributable to sewage,
industrial wastes or other wastes
nor visible oil film nor globules
of grease.
None in amounts that will be
injurious to fishlife or which in
, any manner shall adversely affect the
flavor, color or odor thereof, or
impair the waters for any best usage
as, determined for the specific waters
which are assigned to each class.
1660
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6. Thermal discharges
(See PART 704 of this Title.)
CIASS "AA"
Best usage of waters. Source of water supply for drinking,
culinary or food processing purposes and any other usages.
Conditions related to best usage of waters. The waters, if
subjected to approved disinfection treatment, with additional
treatment if necessary to remove naturally present impurities,
will meet New York State Department of Health drinking water
standards and will be considered safe and satisfactory for
drinking water purposes.
Items
1. Coliform
Quality Standards for Class "AA" Waters
Specifications
PH
Total Dissolved Solids
The monthly median coliform value
for one hundred ml of sample
shall not exceed fifty (50)
from a minimum of five examinations
and provided that not more than
twenty percent of the samples shall
exceed a coliform value of two
hundred forty (240) for one hundred
ml of sample.
Shall be between 6.5 and 8.5
Shall be kept as low as practicable
to maintain the best usage of waters,
but in no case shall it exceed 500
milligrams per liter.
1661
-------
Items
4. Dissolved Oxygen
5. Phenolic compounds
6. Radioactivity
a. Gross Beta
b. Radium 226
c. Strontium 90
Specifications
For cold waters suitable for trout
spawning, the DO concentration shall
not be less than 7.0 mg/1 from other
than natural conditions. For trout
waters, the minimum daily average
shall not be less than 6.0 mg/1.
At no time shall the DO concentration
be less than 5.0 mg/1. For non-trout
waters, the minimum daily average shal
not be less than 5.0 mg/1. At no time
shall the DO concentration be less
than 4.0 mg/1.
Shall not be greater than 0.001 mil-
ligrams per liter (phenol).
Shall not exceed 1,000 picocuries per
liter in the absence of Sr90 and
alpha emitters.
Shall not exceed 3 picocuries per
liter.
Shall not exceed 10 picocuries per
liter.
Note 1: With reference to certain toxic substances affecting
fishlife, the establishment of any single numerical
standard for waters of New York State would be too
restrictive. There are many waters, which because of
poor buffering capacity and composition will require
special study to determine safe concentrations of toxic
substances. However, most of the non-trout waters
near industrial areas in this state will have an
alkalinity of 80 milligrams per liter or above.
Without considering increased or decreased toxicity from
possible combinations, the following may be considered
as safe stream concentrations for certain substances to
comply with the above standard for this type of water.
Waters of lower alkalinity must be specifically con-
sidered since the toxic effect of most pollutants will
be greatly increased.
-------
Note 1 Cont'd
Ammonia or Ammonium Compounds Not greater than 2.0 milligrams
per liter expressed as NH3 at
pH of 8.0 or above.
Cyanide Not greater than 0.1 milligrams
per liter expressed as CN.
Ferro-or Ferricyanide Not greater than 0.4 milligrams
per liter expressed as Fe(CN)6.
Copper Not greater than 0.2 milligrams
per liter expressed as Cu.
Zinc Not greater than 0.3 milligrams
per liter expressed as Zn.
Cadmium Not greater than 0.3 milligrams
per liter expressed as Cd.
CLASS "A"
Best Usage of waters. Source of water supply for drinking, culinary
or food processing purposes and any other usages.
Conditions related to best usage of waters. The waters, if subjected
to approved treatment ecrual to coagulation, sedimentation, filtration
and disinfection, with additional treatment if necessary to reduce
naturally present impurities will meet New York State Department of
Health drinking water standards and will be considered safe and
satisfactory for drinking water purposes.
Quality Standards for Class "A" Waters
Items Specifications
1. Coliform The monthly median coliform value
for one hundred ml of sample shall
not exceed five thousand from a
minimum of five examinations and
provided that not more than twenty
percent of the samples shall exceed
a coliform value of twenty thousand
for one hundred ml of sample and the
monthly geometric mean fecal coliform
value for one hundred ml of sample
shall not exceed two hundred (200)
from a minimum of five examinations.
*' 1663
-------
2. pH
3. Total Dissolved Solids
4. Dissolved Oxygen
5. Phenolic Compounds
6. Radioactivity
a. Gross Beta
b. Radium 226
c. Strontium 90
Shall be between 6.5 and 8.5.
Shall be kept as low as practicable
to maintain the best usage of waters,
but in no case shall it exceed 500
milligrams per liter.
For cold waters suitable for trout
spawning, the DO concentration shall
not be less than 7.0 mg/1 from other
than natural conditions.' For trout
waters, the minimum daily average
shall not be less than 6.0 mg/1.
At no time shall the DO concentration
be less than 5.0 mg/1. For non-trout
waters, the minimum daily average
shall not be less than 5.0 mg/1.
At no time shall the DO concentration
be less than 4.0 mg/1.
Shall not be greater than 0.005
milligrams per liter (Phenol).
Shall not exceed 1,000 picocuries
per liter in the absence of Sr90
and alpha emitters.
Shall not exceed 3 picocuries per
liter.
Shall not exceed 10 picocuries per
liter.
Note 1: Refer to note 1 under Class "AA" which is also
applicable to Class "A" standards.
CLASS "B"
Best usage of waters. Primary contact recreation and any other
uses except as a source of water supply for drinking, culinary
or food processing purposes.
ISS(»
-------
Items
Quality Standards for Class "B" Waters
Specifications
1. Coliform
2. pH
3. Total Dissolved Solids
The monthly median coliform value
for one hundred ml of sample shall
not exceed two thousand four hun-
dred from a minimum of five
examinations and provided that not
more than twenty percent of the
samples shall exceed a coliform
value of five thousand for one
hundred ml of sample and the monthly
geometric mean fecal coliform value
for one hundred ml of sample shall
not exceed two hundred (200) from
a minimum of five examinations.
This standard shall be met during
all periods when disinfection is
practiced.
Shall be between 6.5 and 8.5
None at concentrations which will be
detrimental to the growth and
propagation of aauatic life. Waters
having present levels less than
500 milligrams per liter shall be
kept below this limit.
For cold waters suitable for trout
spawning, the DO concentration shall
not be less than 7.0 mg/1 from other
than natural conditions. For trout
waters, the minimum daily average
shall not be less than 6.0 mg/1.
At no time shall the DO concentration
be less than 5.0 mg/1. For non-trout
waters* the minimum daily average
shall not be less than 5.0 mg/1.
At no time shall the DO concentration
be less than 4.0 mg/1.
Note 1: Refer to note 1 under Class "AA" which is also
applicable to Class "B" standards.
CLASS "C"
lest usage of waters. Suitable for fishing and all other uses except
is a source of water supply for drinking, culinary or food processing
Durposes and primary contact recreation.
4 1665
4. Dissolved Oxygen
-------
Items
1. Coliform
Quality Standards for Class "C" Waters
Specifications
2. pH
3. Total Dissolved Solids
4. Dissolved Oxygen
The monthly geometric mean total
coliform value for one hundred ml
of sample shall not exceed ten
thousand and the monthly geometric
mean fecal coliform value for one
hundred ml of sample shall not
exceed two thousand from a minimum
of five examinations. This standard
shall be met during all periods
when disinfection is practiced.
Shall be between 6.5 and 8.5.
None at concentrations which will
be detrimental to the growth and
propagation of aauatic life. Waters
having present levels less than
500 milligrams per liter shall be
kept below this limit.
For cold waters suitable for trout
spawning, the DO concentration shall
not be less than 7.0 mg/1 from other
than natural conditions. For trout
waters, the minimum daily average
shall not be less than 6.0 mg/1.
At no time shall the DO concentration
be less than 5.0 mg/1. For non-trout
waters, the minimum daily average
shall not be less than 5.0 mg/1.
At no time shall the DO concentration
be less than 4.0 mg/1.
Note 1: Refer to note 1 under Class "AA" which is also
applicable to Class "C" standards.
CLASS "D"
Best usage of waters. These waters are suitable for secondary
contact recreation, but due to such natural conditions as inter-
mittency of flow, water conditions not conducive to propagation
of game fishery or stream bed conditions, the waters will not
support the propagation of fish.
Conditions related to best usage of waters.
suitable for fish survival.
The waters must be
-------
Quality Standards for Class "D" Waters
Items Specifications
1. pH Shall be between 6.0 and 9.5.
2. Dissolved Oxygen Shall not be less than 3 milligrams
per liter at any time.
Note: Refer to note 1 under Class "AA" which is also
applicable to Class "D" standards.
1S67
-------
701.5 CLASSES AND STANDARDS FOR SALINE SURFACE WATERS
The following items and specifications shall be the standards
applicable to all New York Saline Surface Waters which are
assigned the classification of SA, SB, SC or SD, in addition to
the specific standards which are found in this Part under the
heading of each such classification.
Quality Standards for Saline Surface Waters
Items
1. Garbage, cinders, ashes,
oils, sludge or other
refuse.
2. pH
3. Turbidity
4. Color
5.
Suspended, colloidal
or settleable solids.
6.
Oil and floating
substances.
Specifications
None in any waters of the marine
district as defined by Environmental
Conservation Law (§ 17-0105).
The normal range shall not be
extended by more than one-tenth (0.1)
pH unit.
No increase except from natural
sources that will cause a substantial
visible contrast to natural conditions.
In cases of naturally turbid waters,
the contrast will be due to increased
turbidity.
None from man-made sources that will
be detrimental to anticipated best
usage of waters.
None from sewage, industrial wastes
or other wastes which will cause
deposition or be deleterious for
any best usage determined for the
specific waters which are assigned
to each class.
No residue attributable to sewage,
industrial wastes or other wastes,
nor visible oil film nor globules
of grease.
1668
-------
7. Thermal discharges
(See PART 704 of this Title.)
CLASS "SA"
Best usage of waters. The waters shall be suitable for shellfishing
for market purposes and primary and secondary contact recreation.
Items
Quality Standards for Class "SA" Waters
Specifications
1. Coliform
2. Dissolved Oxygen
3. Toxic wastes and
deleterious substances.
The median MPN value in any series
of samples representative of waters
in the shellfish growing area shall
not be in excess of seventy (70)
per one hundred ml.
Shall not be less than 5.0 mg/1 at
any time.
None in amounts that will interfere
with use for primary contact
recreation or that will be injurious
to edible fish or shellfish or the
culture or propagation thereof, or
which in any manner shall adversely
affect the flavor, color, odor or
sanitary condition thereof or impair
the waters for any other best usage
as determined for the specific waters
which are assigned to this class.
1663
-------
CLASS "SB"
Best usage of waters. The waters shall be suitable for primary
and secondary contact recreation and any other use except for the
taking of shellfish for market purposes.
Items
Quality Standards for Class "SB" Waters
Specifications
1. Coliform
2. Dissolved Oxygen
3. Toxic Wastes and
deleterious substances.
The monthly median coliform value
for one hundred ml of sample shall
not exceed two thousand four hundred
from a minimum of five examinations
and provided that not more than
twenty percent of the samples shall
exceed a coliform value of five
thousand for one hundred ml of
sample and the monthly geometric
mean fecal coliform value for one
hundred ml of sample shall not
exceed two hundred (200) from a
minimum of five examinations.
This standard shall be met during
all periods when disinfection is
practiced.
Shall not be less than 5.0 mg/1 at
any time.
None in amounts that will interfere
with use for primary contact recreatioi
or that will be injurious to edible
fish or shellfish or the culture or
propagation thereof, or which in
any manner shall adversely affect
the flavor/ color, odor or sanitary
condition thereof, or impair the
waters for any other best usage as
determined for the specific waters
which are assigned to this class.
1670
-------
CUSS "SC"
Best usage of waters. The waters shall be suitable for fishing
and all other uses except for primary contact recreation and
for the taking of shellfish for market purposes.
Quality Standards for Class "SC" Waters
Items
1. Coliform
2. Dissolved Oxygen
3. Toxic wastes and
deleterious substances.
Specifications
The monthly geometric mean total
coliform value for one hundred ml
of sample shall not exceed ten
thousand and the monthly geometric
mean fecal coliform value for one
hundred ml of sample shall not exceed
two thousand from a minimum of five
examinations. This standard shall
be met during all periods when
disinfection is practiced.
Shall not be less than 5.0 mg/1 at
any time.
None in amounts that will interfere
with use for secondary contact
recreation or that will be injurious
to edible fish or shellfish or the
culture or propagation thereof, or
which in any manner shall adversely
affect the flavor, color, odor or
sanitary condition thereof or impair
the waters for any other best usage
as determined for the specific waters
which are assigned to this class.
1S71
-------
CLASS "SD"
Best usage of waters. All waters not primarily for recreational
purposes/ shellfish culture or the development of fishlife and
because of natural or man-made conditions cannot meet the renuire-
ments of these uses.
Quality Standards for Class "SD" Waters
Items
1. Dissolved Oxygen
2. Toxic wastes and
deleterious substances.
Specifications
Shall not be less than 3.0 mg/1
at any t ime.
None alone or in combination with
other substances or wastes in
sufficient amounts to prevent
survival of fish life or impair
the waters for any other best usage
as determined for the specific
waters which are assigned to this
class.
1S72
-------
PART 702
SPECIAL CLASSIFICATIONS AND STANDARDS
(STATUTORY AUTHORITY: ENVIRONMENTAL CONSERVATION LAW,
SECTION 15-0313 AND SECTION 17-0301)
Section
702.1 Class A-SPECIAL (International boundary waters)
702.2 Class AA-SPECIAL (Lake Champlain drainage basin)
702.3 Special classes and standards for the lower Hudson River
Arthur Kill, Kill Van Kull, Harlem River, Raritan Bay
and Lower East River drainage basin, New York Bay area,
Nassau County including Long Island Sound, Suffolk
County, Upper East River, Long Island Sound drainage
basins within Queens, Bronx, and Westchester counties,
and Jamaica Bay drainage basin within Kings and Queens
counties including a certain portion of Rockaway Inlet.
702.4 Class AA-SPECIAL (Upper Hudson River drainage basin)
Section 702.1 CLASS A-SPECIAL (INTERNATIONAL BOUNDARY WATERS)
(GREAT LAKES WATER QUALITY AGREEMENT OF 1972)
Best usage of waters. Source of water supply for drinking, culinary
or food processing purposes, primary contact recreation and any other
usages. Conditions related to best usage. The waters, if subjected
to approved treatment, equal to coagulation, sedimentation, filtration
and disinfection with additional treatment, if necessary, to reduce
naturally present impurities, meet or will meet New York State Depart-
ment of Health drinking water standards and are or will be considered
safe and satisfactory for drinking water purposes.
Quality Standards for Class A-Special Waters
(International Boundary Waters)
ITEMS SPECIFICATIONS
1. Coliform The geometric mean of not less than
five samples taken over not more
than a thirty-day period should not
exceed 1,000 per 100 ml total coli-
form nor 200 per 100 ml fecal coliform
1S73
-------
ITEMS
2. Dissolved Oxygen
3. Total Dissolved Solids
SPECIFICATIONS
In the rivers and upper waters of
the lakes not less than 6.0 rag/1 at
any time. In hypolimnetic waters/
it should be not less than necessary
for the support of fishlife, partic-
ularly cold water species.
Should not exceed 200 milligrams per
liter
4. pH
Should not be outside the range of
6.7 to 8.5.
5. Iron
Should not exceed 0.3 milligrams per
liter as Fe.
6. Phosphorus
7. Radioactivity
8. Taste and odor-producing
substances, toxic wastes
and deleterious substances
Concentrations should be limited to
the extent necessary to prevent
nuisance growths of algae/ weeds and
slimes that are or may become injurious
to any beneficial water use.
Should be kept at the lowest practi-
cable levels and in any event should
be controlled to the extent necessary
to prevent harmful effects on health.
None in amounts that will interfere
with use for primary contact recrea-
tion or thatwill be injurious to the
growth and propagation of fish, or which
in any manner shall adversely affect
the flavor, color or odor thereof or
impair the waters for any other best
usage as determined for the specific
waters which are assigned to this
class.
9. Suspended, colloidal or
settleable solids
None from sewage, industrial wastes
or other wastes which will cause
deposition or be deleterious for any
best usage determined for the specific
waters which are assigned to this class.
167%
-------
Items Specifications
10. Oil and floating substances No residue attributable to sewage,
industrial wastes or other wastes nor
visible oil film nor globules of grease.
11. Thermal Discharges (See PART 704 of this Title.)
To meet the water quality objectives referred to in the "Great Lakes
Water Quality Agreement of 1972," the standards listed above shall
be subject to revision from time to time after further hearings on
due notice.
Note: Refer to note 1 under Class "AA" which is also
applicable to Class A-Special (International
Boundary Waters) standards.
Section 702.2 CLASS AA-SPECIAL (LAKE CHAMPLAIN DRAINAGE BASIN)
CIASS AA-SPECIAL
Best usage of waters. Any usage except for disposal of sewage,
industrial wastes o' other wastes.
Quality Standards for Class AA-iSpecial Waters (Lake Champlain Drainage
Basin)
Items Specifications
1. Floating solids; settle- None attributable to sewage,
able solids; oil; sludge industrial waste or other wastes.
deposits; toxic wastes;
deleterious substances;
colored or other wastes
or heated liquids.
2. Sewage or waste effluents. None into waters of this class.
1675
-------
Section 702.3 Special classes and Standards for the Lower Hudson
River, Arthur Kill, Kill Van Kull, Harlem River,
Raritan Bay and Lower East River Drainage Basins,
New York Bay area, Nassau County including Long
Island Sound, Suffolk County, Upper East River,
Long Island Sound Drainage Basins, within Queens,
Bronx and Westchester counties and Jamaica Bay
Drainage Basin within Kings and Queens counties
including a certain portion of Rockaway Inlet.
This section applies to the waters within the following areas,
which constitute the Interstate Sanitation District:
1. The drainage basin of the Lower Hudson River from the
mouth to northern Westchester-Rockland county lines, except
Saw Mill River and Sparkill Creek drainage basins.
2. The drainage basins of Arthur Kill, Kill Van Kull, and
Harlem River, and Raritan Bay.
3. The drainage basin of Lower East River from the mouth to
a line across East River north of Wards Island between Stony
Point in Bronx County and Lawrence Point in Queens County.
4. New York Bay including Gravesend Bay, Coney Island Creek,
Atlantic Basin, Erie Basin, Gowanus Bay, Gowanus Canal. The
Narrows and Atlantic Ocean waters off Coney Island lying
westerly of a north-south line from Light Inlet at the south-
easterly tip of Coney Island Peninsula to the south tip of
Rockaway Point, thence along the jetty to Rockaway jetty light,
thence due south to the New York-New Jersey boundary line.
5. Nassau County including the waters of Long Island Sound
between Nassau-Queens and Nassau-Suffolk county lines and the
waters of Atlantic Ocean to the three mile limit between said
county lines.
6. The area within Suffolk County lying west of a north-south
topographical limit line and its extensions to a point in
Long Island Sound at the New York-Connecticut. State boundary
line due north of Miller Place Beach and to Blue Point on the
south mainland thence southward across Great South Bay to Water
Island, thence three miles due south to a point in the Atlantic
Ocean at the south State boundary line.
i'678
-------
7. Certain tidal waters which are within the Upper East River
and Long Island Sound drainage basins within Queens, Bronx,
and Westchester counties.
8. Jamaica Bay drainage basin within Kings and Queens counties
and including Rockaway Inlet east of a north-south line drawn
from Light Inlet at the south easterly tip of Coney Island
peninsula near Manhattan Beach to the westerly shoreline west
of Lookout Tower on Rockaway Point.
>. Said classes and standards of auality and purity applicable
thereto are set forth hereinafter and designated Class I and
Class II.
CLASS
est usage of waters. The waters shall be suitable for secondary
ontact recreation and any other usage except for primary contact
ecreation and shellfishing for market purposes.
Quality Standards for Class "I" Waters
terns
Garbage, cinders, ashes,
oils, sludge or other refuse.
Coliform
Dissolved Oxygen
pH
Specifications
None in any waters of the marine dis-
trict as defined by Environmental
Conservation Law (§17-0105).
The monthly geometric mean total
coliform value for one hundred ml
of sample shall not exceed ten
thousand and the monthly geometric
mean fecal coliform value for one
hundred ml of sample shall not exceed
two thousand from a minimum of five
examinations. This standard shall be
met during all perioctewhen disin-
fection is practiced.
Shall not be less than 4.0 mg/1 at
any time.
The normal range shall not be extended
by more than one-tenth (0.1) pH unit.
1677
-------
5. Turbidity
6. Color
No increase except from natural
sources that will cause a substantial
visible contrast to natural conditions.
In cases of naturally turbid waters,
the contrast will be due to increased
turbidity.
None from man-made sources that will
be detrimental to anticipated best
usage of waters.
7. Taste and odor-producing None in amounts that will interfere
substances, toxic wastes with use for secondary contact
and deleterious substances, recreation or that will be injurious
to edible fish or shellfish or the
culture or propagation thereof, or
which in any manner shall adversely
affect the flavor, color, odor or
sanitary conditions thereof, or
impair the waters for any other best
usage as determined for the specific
waters which are assigned to this
class.
8.
Suspended, colloidal or
settleable solids.
9.
Oil and floating
subbuances.
10. Thermal Discharges
None from sewage, industrial wastes
or other wastes which will cause
deposition or be deleterious for
any best usage determined for the
specific waters which are assigned
to this class.
No residue attributable to sewage,
industrial wastes or other wastes,
nor visible oil film nor globules
of grease.
'(See PART 704 of this Title.)
IS 78
-------
Section 702.4 CLASS AA-SPEC1AL (UPPER HUDSON RIVER DRAINAGE BASIN)
CLASS AA-SPECIAL
Best usage of waters. Any usage except for disposal of sewage,
industrial waste or other waste.
Quality Standards for Class AA-Special Waters
(Upper Hudson River Drainage Basin)
ITEMS
1. Floating solids, settleable
solids, oil, sludge deposits,
toxic wastes, deleterious
substances, colored or other
wastes or heated liquids
2. Sewage or waste effluents
SPECIFICATIONS
None attributable to sewage, in-
dustrial wastes or other wastes.
None into waters of this class.
1679
-------
CIASS "II"
Best usage of waters. All waters not primarily for recreational pur-
poses/ shellfish culture or the development of fishlife.
Quality Standards for Class "II" Waters
ITEMS SPECIFICATIONS
1. Floating solids, settleable
solids, sludge deposits
2. Garbage, cinders, ashes,
oils, sludge or other
refuse
3. Dissolved Oxygen
4. Toxic wastes, oil,
deleterious substances,
colored or other wastes,
or thermal discharges
None which are readily visible and
attributable to sewage, industrial
wastes or other wastes or which
deleteriously increase the amounts
of these constituents in receiving
waters after opportunity for rea-
sonable dilution and mixture with the
wastes discharged thereto.
None in any waters of the marine
district as defined by Environ-
mental Conservation Law (§17-0105).
An average of not less than 30 per
cent saturation during any week of
the year, provided such saturation
levels insure adenuate oxygen to
support fish and shellfish life at
all times.
None alone or in combination with
other substances or wastes in suf-
ficient amounts to be injurious to
edible fish and shellfish, or the
culture or propagation thereof, or
which shall in any manner affect
the flavor, color, odor or sani-
tary condition of such fish or
shellfish so as to injuriously
affect the sale therof. or which
shall cause any injury to the pub-
lic and private shellfisheries of
this State. See Part 704_for
thermal discharges.
1680
-------
enn
P.O. BOX 340 BROOKVILLE, PA. 15825 • TEL. 814/849-7328
November 18, 1975
Mr. Edward Tuerk
Assistant Administrator
for Air and Waste Management
c/o Federal Register
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Dear Mr. Tuerk:
This letter to you results from our receiving a copy of the Federal
Register in today's mail. Enclosed you will find a catalog containing
literature covering our product line on flash economizers, silencers,
exhaust heads, inlineS", blowdown separators, and accessories. I
thought the literature on the flash economizer and silencer might be
of particular interest to you ari& the Environmental Protection Agency
because of your coneezn under point three of Discussion Topics in
the Federal Register. If you desire any additional information and/or
li**rature, please feel free to write or call us.
Thank you for taking the time to read this letter and our literature.
Very truly yours,
Perm Separator Corp.
'John A. McNeil
Sales Manager
JAMcN/pjm BROCHURE DETACHED AND RETAINED
Enclosure: 1 IN SOLID WASTE MANAGEMENT FILES
1681
-------
PROJECT
SURVIVAL
366 California Ave., Palo Alto, California 94306 8 December 1975
(415) 329-0450
Mr. John P. Lehman, Director
Hazardous Waste Management Division
U. S. Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Lehman:
Recent developments make it impossible for us to appear
on December 11 at the Hazardous Waste Management meeting in San
Francisco.
We are especially concerned with disposal of wastes from
nuclear power plants and other facilities within the nuclear fuel
cycle.
Because we can't come, we are submitting the following
comments:
1. Low-level wastes: These wastes have already begun to
leak into the environment at Maxey Flats, Kentucky, West Valley, New
York, and Hanford, Washington (trench wastes). Projected amounts of
plutonium in low-level wastes generated in the future from nuclear
power plants will equal or exceed the amount of plutonium in the high-
level waste stream from the reprocessing plant. We urge you to study
the adequacy of present methods of disposal of low-level wastes and
set standards appropriate to the long storage time and toxicity of
plutonium and other transuranics in low-level wastes.
2. Mines and Mills: Leaks have already resulted in con-
tamination of drinking and irrigation water in New Mexico and Colorado.
We urge you to set strict standards to prevent future contamination of
water supplies from this source.
3. Mill tailings: Abandoned mill tailings pose a substan-
tial threat to human health due to the decay of uranium into daughter
products such as radon gas. Because millions will die over the next
80,000 years as a result of this source, we urge you to set strict
standards requiring stabilization and disposal of mill tailings in
such a way that radioactivity will not be released into the environment
from this source. We further urge that a determination be made
quickly as to who should bear the expense and responsibility of
disposing of mill tailings, both at the 22 abandoned sites in the U.S.
1682
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Mr. John P. Lehman 8 December 1975
and at presently operating mills.
4. High-level wastes: We are especially concerned at the
present state of affairs with regard to management of high level
wastes. Security is inadequate to prevent sabotage of spent fuel
storage ponds at reactor sites. Continued storage of large quantities
of spent fuel at reactors around the country poses a threat to our
health and our security. We are appalled that more radioactive wastes
are being generated despite the fact that there is no proven means to
safely dispose of these materials. We urge a moratorium on further
construction of nuclear power plants pending the solution of this
matter to the satisfaction of a majority of society.
We would be happy to answer any questions and present further
information on this subject.
Sincerely,
James E. Burch
President
PROJECT SURVIVAL
JEB/hl
cc: Dr. Leslie Grimm
1G63
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SOLVENTS RECOVERY SERVICI
OF NEW JERSEY, INC.
12OO SYLVAN STREET LINDEN, N J O7O36
PHONE (2OI) 925-860O
December 9, 1975
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs
(AW-565)
Environmental Protection Agency
Washington, DC 20460
Dear Mr. Lehman:
We would like to present as part of the EPA's Public Hearing
on Hazardous Waste Management the following comments for the record
SRS is probably one of the largest and oldest resource recovery op-
erations in the United States. We have been recovering solvents fr<
waste streams for the paints and coatings industries for nearly
forty years and, as such, have developed a tremendous amount of
technology in the resource recovery of flammable and nonflammable
solvents. We were extremely disappointed with your program and
meeting in Newark which we attended in that we noted that not
enough attention was presented to the resource recovery field. We
feel that proposing a program to solve hazardous waste disposal
through use of landfills or deep well disposal techniques can only
be considered a stopgap measure in that it only provides a storage
facility for such problem wastes for hopeful solutions in the futur
1. In regard to proper methods for collection and analysis of
waste samples, we would propose that the generator of the waste
be responsible to provide the recipient of hazardous waste with
an appropriate analysis of the waste, sufficient enough to allc
the waste disposer or recoverer to handle it in a safe manner.
Sampling of hazardous waste presents a tremendous problem,
particularly when handling drum lots of material.
2. We feel the responsibility and liabilities for the solid wastes
should rest with the generator of the wastes until such time
as the material has been properly transferred to a registered
or licensed disposal or resource recovery corporation. Both
the generator and the processor of the hazardous wastes should
approve the method of disposal and, at the same time, it shoulc
be sanctioned by the State and/or Federal Government. This is
the only way which will alleviate the possibility that lawsuits
can be brought by third parties and/or the Federal Government
against a generator and processor of solid wastes as a result
of any future problems which might occur.
ISiiU
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Mr. John P. Lehman - 2 - December 9, 1975
EPA
3. A major incentive should be provided for any process which in-
volves resource recovery and/or reuse of materials, as this
process is the only process which does not merely store the
hazardous material for future generations or create a real or
potential air pollution or water pollution problem. We feel
that all incentives should be provided and a firm requirement
made to utilize resource recovery for all hydrocarbon or waste
by-product streams. We have been successful in utilizing re-
source recovery techniques on almost all classes of solvents,
that is, esters, ethers, fluorocarbons, general purpose hydro-
carbons, toluenes, alcohols, amines, aromatics and chlorinated
solvents. We have provided this service to the paints and
coatings industries, the pharmaceutical, general purpose chem-
icals, printing, electronic, metalworking, magnetic tape, and
many other industries. We feel an incentive is required in
that this method sometimes can be more costly than other dis-
posal techniques, such as landfill, but when you review the
overall benefits to a long range environmental protection plan
many limited .incentives in this area will have tremendous future
returns.
4. Many hazardous wastes can be rendered harmless through removal
of recyclable materials which many times result in a general
solid waste by-product which can be landfilled in regular land-
fills.
5. We have a tremendous amount of cost data available as a result
of our nearly forty years in the resource recovery operation.
The generalized cost data, however, cannot be issued in that
each individual case or stream must stand on its own from an
economic viewpoint.
6. The minimum safety and security precautions for transportation
of solid wastes are covered in enough detail in the existing
DOT regulations and covered basically at disposal sites under
existing OSHA regulations.
7. In regard to recordkeeping and site monitoring, we feel that
the program set up by the State of New Jersey is an excellent
basic program in this regard.
8. We feel that the Federal Government and/or State Government
should also be empowered to provide financial assistance either
in the form of grants and/or long term financing to any resource
recovery operations which will serve as an alternate to other
1S85
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Mr. John P. Lehman - 3 - December 9, 1975
EPA
less desirable hazardous disposal programs/ such as land-
filling or incineration. We also feel that hazardous waste
legislation should be made country-wide so as to make it
desirable to operate a hazardous waste generating business or
a hazardous waste disposal or recovery business in any part of
our country.
I would like to thank you very much for taking the time to
enter the above into the record. If we can be of any further service
to you, please let us know.
Very truly yours,
''John P. O'Connell
JPOCibjk
1611
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SOUTHERN METHODIST UNIVERSITY
ARCHAEOLOGY RESEARCH PROGRAM
Department of Anthropology
DALLAS, TEXAS 7527S
November 21, 1975
Mr. John P. Lehman
Director, Hazardous Waste Management Division
Office of Solid Waste Management (AW-565)
Environmental Protection Agency
Washington, D. C.
Dear Mr. Lehman:
I wish to file the following comments with your office in res-
ponse to the EPA's notice of public meetings to be held in
December 1975, concerning the management of hazardous wastes.
Since I will be unable to attend any of the meetings, I would
appreciate having my comments placed on the meeting record.
Discussion topic two touches on the problem of defining the
liabilities and responsibilities of waste generators, treaters,
and disposers. It is my concern that the EPA consider the
effects on cultural resources resulting from various hazardous
waste management practices. In particular, it is important to
have an accurate and detailed field derived inventory and evalu-
ation of the cultural resources in any area where land surface
modifications are planned, so that the adverse effect of the
modification on the resource base can be minimized and controlled.
Cultural resources can be narrowly defined here to mean all
prehistoric and historic archaeological remains.
The decision as to who should bear the costs of this inventory,
evaluation, and possible mitigation is not within the realm
of this archaeologist's expertise. It is my belief, though,
that this resource base must be recognized and that its pro-
tection must be considered in the planning of facilities for
the handling of hazardous wastes in the future.
' / -<<.
'joe G. Gallagher^
Research Archaeologist
JGG/cd 16b"
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SYSTEC
30 January 1976 environmental specialists m engineering consultants • systems designers & fabr
SYSTEMS TECHNOLOGY CORPORA
MR. JOHN P. LEHMAN, DIRECTOR 3131 Encrete Lane . Davton^Ohio
HAZARDOUS WASTE MANAGEMENT DIVISION Area Code blJ/29
OFFICE OF SOLID WASTE MANAGEMENT PROGRAMS (AW-565)
Environmental Protection Agency
Washington, D. C. 20460
Subject: Hazardous Waste Management
Dear Mr. Lehman:
Systems Technology Corporation is submitting this letter in
response to the request for comments regarding "Hazardous
Waste Management" published by the U.S.E.P.A. in the Septem-
ber 17, 1975 Federal Register.
As you know. Systems Technology Corporation specializes in
environmental technology. We operate three Systech Waste
Treatment Centers that provide disposal services for indus-
trial liquid wastes. Furthermore, our firm is engaged in
many environmental consulting and, research projects. The
comments submitted below are based on the extensive experience
that we have gained in the subject area.
The management of Systems Technology Corporation is of the
opinion that there is a serious need for legislation to pro-
vide a more positive control over hazardous waste disposal
practices. There are many reasons for this need but the
most compelling one is that existing regulations are at best
inconsistent throughout the Country. As such they are inade-
quate for protecting the public health and welfare from the
immediate and long term risks associated with the highly
technical, highly complex, and highly mobile materials cate-
gorized as "Hazardous Wastes." The need for hazardous waste
legislation parallels the needs that led to the legislation
regarding air and water quality standards. Improper disposal
of hazardous wastes threatens all of the earths media and
has the potential of long term pollution of land and ground
water. The only difference is that hazardous wastes tend
to be in smaller more easily transported quantities. Thus,
the pollution effects are more isolated and less visable.
Nevertheless, the many studies of the U.S.E.P.A. demonstrate
the risk potential associated with the disposal of these
materials.
A Subsidiary of Systems Research Laboratories, Inc.
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30 January 1976
SYSTEMS TECHNOLOGY CORPORATION page 2
In our opinion there are at least three major objectives to
be accomplished by Federal legislation regarding "Hazardous
Waste Management."
1) The first objective is to establish a technically
strong and uniformly applied requirement for the
proper and environmentally sound disposal of hazar-
dous wastes. Without such a requirement waste
generators will not commit the extra expense needed
to properly treat these wastes and the development
of a hazardous waste disposal industry will be
stunted. In addition, there will be a tendency to
transport wastes from one area to another in order
to escape strict disposal requirements.
2) The second objective should be to establish minimum
treatment/disposal standards for the various generic
types of wastes considered to be hazardous wastes.
The intent here is to establish the minimum treat-
ment/disposal results that are acceptable and not to
dictate specific treatment techniques.
3) The third objective should be to establish a method to
insure that contract hazardous waste processors have
the resources necessary to meet the minimum treatment
requirements. This could be accomplished through a
licensing or permit program. Such a mechanism is
necessary because the highly mobile nature of the
waste makes circumvention of treatment standards
more likely. Furthermore, a licensing program
would provide the waste generator with a reasonable
assurance that his wastes are being properly handled.
The problem of Hazardous Waste Management is a highly technical
problem that is National in scope. As such it requires the
application of the Nations best technical resources. Typically,
these technical resources are beyond the reach of state and
local agencies that are currently administering the disposal
of these materials. Because of this we stongly support the
promulgation of Federal legislation to meet the objectives
outlined above. However, as a practical matter it may be
desirable to have the states implement the enforcement as they
do for air and water programs.
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30 January 1976
SYSTEMS TECHNOLOGY CORPORATION page 3
We recommend that those preparing recommendations for legis-
lation consider some of the following problem areas.
1) The definition of Hazardous Wastes is particularly
difficult. The name itself causes some people to
think of only "high-risk" materials such as explo-
sives, unstable materials, extremely toxic materials
radioactive materials etc. At the public hearings
in Chicago one speaker implied that oily wastes, acids,
caustics, etc. did not need treatment and were suitable
for land disposal. We strongly disagree with that
position. We believe that all industrial wastes should
be pretreated to the best level practical prior to
returning them to the environment. Pretreatment
minimizes the volume of wastes requiring disposal and
minimizes the risk associated with returning these
materials to the environment. The problem here would
be for the legislation to establish the best practical
level of treatment required prior to final disposal.
2) Circumvention of regulations is one problem that may
be significant and should be considered in the prepara-
tion of legislation. Circumvention is more of a pro-
blem for hazardous wastes because they can be readily
transported by trucks. Consider for example, the use
of waste oils for dust control on rural roads. In
Michigan road oilers are not bound by the regulations
controlling industrial waste haulers of processors
even though the waste oils come from industrial sources.
As a result it is easy for generators to mix other
wastes with oily wasts. This mixture would then be
widely disposed over the roads. This type of circum-
vention could lead to more cases like the Missouri
Horse Arena Poisoning incident.
Any new legislation should insure that there is good
accountability required on the part of the waste genera-
tor, the waste transporter and the waste processor.
3) The problem of properly identifying and transporting
waste also needs significant attention. Existing regula-
tions by the Department of Transportation may already
adequately provide the mechanism for accomplishing
this control. Yet, there is a need for developing
specific identification standards for hazardous
wastes. It would be desirable for the EPA to work
closely with the DOT on this matter.
IbSO
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30 January 1976
SYSTEMS TECHNOLOGY CORPORATION page 4
The above comments are of a general nature and do not relate
to the technical specifics. The objective of this letter
is to demonstrate the need for strong, technically sound
legislation to provide positive control for "Hazardous
Waste Management." The management of Systems Technology
Corporation strongly supports the activities of the U.S.
E.P.A. in this matter.
Sincerely,
SYSTEMS TECHNOLOGY CORPORATION
Thomas J. Wittmann, P.E.
President
TJW/ds
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THE UNIVERSITY OF TEXAS AT DALLAS
January 5, 1976
INSTITUTE FOR
ENVIRONMENTAL SCIENCES
John Lehman
Director, Hazardous Waste Program
Environmental Protection Agency
Office of Solid Waste Management (AW-565)
Washington, D. C. 20460
Dear Mr. Lehman:
Please find enclosed a statement that I would like
to have introduced into the record of the US EPA public
meeting that was held in Houston concerned with hazardous
chemical wastes. I would be pleased to discuss with
you or with any of your staff any of the comments made
in the attached statement.
Sincerely
Director
6FL:sp
Enclosure
AN EQUAL OPPORTUNITY/AFFIRMATIVE ACTION EMPLOYER
214 BOO-2238 BOX .388 RICHARDSON, TEXAS 7OO8O
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STATEMENT FOR PUBLIC MEETING ON HAZARDOUS WASTE MANAGEMENT
US EPA, HOUSTON, TEXAS - DECEMBER, 1975
By
G. Fred Lee, Director
Center for Environmental Studies
University of Texas at Dallas, Richardson, Texas 75080
Increasing emphasis has been placed during the past few
years on control of air and water pollution at the Federal,
state, and local level. This situation has given increased
attention to land disposal of municipal and industrial wastes.
While land disposal of waste is often relatively simple to
practice, and inexpensive where cheap land is readily avail-
able, it is not without significant potential environmental
problems, the most important of which is ground water contam-
ination. In many parts of the U.S., the states' water poll-
ution control regulations do not provide adequate power to
the water pollution control authorities to enable adequate
protection of ground water resources.
It is my opinion that protection of the quality of ground
water resources of the U.S. has been a grossly neglected
area which needs immediate attention. The passage of the
December, 1974 "Drinking Water Act" provides the legislation
necessary to protect the ground water resources of the U.S.
from contamination by the disposal of various types of
waste on land; however, it appears to be the mood of the
Federal and State governments to curtail spending and as
a result, the funds needed to properly implement the pro-
tection of the nation's ground water resources have not
been, nor will they likely be, forthcoming in the near
future. In light of this situation, it is imperative that
the limited research funds made available for control of
ground water contamination be focused on the most important
potential problems. It is my opinion that one of the areas
that deserves the highest priority for funding is studies
designed to determine the fate of chemical contaminants in
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on-land disposal. Particular emphasis should be given to
organic contaminants arising from industrial processes. The
essential complete prohibition of ocean dumping in the U.S.
coupled with the high cost of fuel and air pollution control
equipment have caused increased interest on the part of in-
dustry in land disposal of processing-manufacturing chemical
wastes. Further, the stricter controls on air and water
pollution have generated large amounts of solid or semi-
solid wastes associated with waste treatment processes
which today are being disposed of on land. Many of these
industrial wastes are highly toxic to plants, animals, and
man, and will likely, when placed in pits or in a landfill
or disposal system will migrate through the sub-surface
strata and eventually contaminate ground waters.
While soils have a capacity to remove certain types of
contaminants, this capacity is, in most cases, finite. Once
exceeded the contaminants will move through the soil system
and eventually cause water quality problems. One of the
aspects of ground water contamination which is significantly
different from that of surface water contamination is that
usually the contamination does not show up as a water quality
problem for many years after the time the contaminants are
added to the land disposal system. Further of great signif-
icance is the fact that once ground water contamination has
occurred, it is virtually impossible to eliminate the con-
tamination. In surface water systems, contaminated waters
will usually recover rapidly after the source of the contam-
inant is controlled. For ground waters, this is rarely the
case and usually it can be expected that the ground water
resource will be more or less permanently destroyed under
conditions of severe contamination.
During the past several years, there has been a major
shift from water disposal to land disposal of waste. This
is in the eyes of some thought to be more ecologically
sound; however, this is not necessarily the case, and in fact,
I Bin
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the opposite may be true. A prime example of situations
where land disposal may actually be more injurious to the
environment than previously practiced open-water disposal
is with respect to sediments dredged from U.S. waterways.
It is becoming increasingly clear today that there are
situations where land disposal of grossly contaminated
dredged sediment may, in fact, be more damaging to environ-
mental quality than previously adopted open-water disposal
methods.
It is my opinion that the process being utilized today
at the federal and state levels are often not adequate to
properly protect ground waters from contamination from both
municipal and industrial disposal of liquid and solid wastes
on .land.
There are sufficient number of incidents of ground water
contamination from land disposal of waste to warrant, under
the auspices of the December, 1974 "Drinking Water Act", the
initiation of strict guidelines governing all such disposal
including the industrial disposal on their own property.
These guidelines should describe a general approach that
must be followed to develop suitable land disposal systems,
and most importantly develop the general approach that must
be followed by private individuals, municipalities and in-
dustry to monitor land disposal of waste practices to insure
that such practices do not lead to surface or ground water
contamination. I believe every major installation, being
utilized for land disposal of waste must be ringed with a
series of monitoring wells and that at no less than quarterly
initially, and then after about a year, bi-annually and poss-
ibly ultimately annually, samples be taken for detection of
significant movement of contaminant from the disposal site
into the surrounding strata.
One of the major goals of the US EPA's program to pro-
tect the ground water resources of the U.S. must be the
development of a testing procedure that can be utilized to
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screen potentially hazardous waste for the potential for
migration through any liners that may be employed in the
disposal site area and through the sub-surface strata of
the region. Ultimately these tests would be employed on
a routine basis in order to provide the regulatory agencies
and the individuals responsible for disposal of waste with
a tool that could give a "go" or "no go" information for a
particular type of waste in a particular land disposal
system.
It is imperative that work begin immediately on
developing procedures which can be used to evaluate whether
certain types of municipal and industrial waste may safely
be disposed of in landfills and other on-land or sub-surface
disposal systems. These procedures should be relatively
simple tests which could be used by industry and water poll-
ution regulatory agencies to ascertain whether the contam-
inant, once added to a particular land disposal system,
would remain at the disposal site or would, in time,
tend to be transported from the disposal site to ground
water in the region.
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Sidney B. Tuwiner, Ph. D.
Consulting Engineer
52 Vanderbilt Avenue
New York, N. Y. 10017
212 OR 9-6499
December 30, 1975
Mr. John P. Lehman
Director, Hazardous Waste Management Div.
Office of Solid Waste Programs (AW565)
Environmental Protection Agency
Washington, D. C. 20460
Dear Sir:
The attached comments are those of the under-
signed, a consultant of Phelps Dodge Refining Corporation, and
they are in agreement with the opinions and position of this
Company.
We wish in particular to take exception to the
inclusion of copper among the parameters to be monitored and
reported in solid waste as we believe that copper is in no way-
harmful to the environment as a constituent of waste in landfill.
SBT:ss
Enclosure
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January 2, 1976
COMMENTS:
SENATE BILL S. 2150
"THE SOLID WASTE UTILIZATION ACT OF 1975"
Control technology presently mandated for control of
emissions and discharges now results in generation of solid waste
which requires on-land disposal. Certain of these solid wastes
may be regarded as hazardous because of danger to public safety
or environment. These comments are directed solely to disposal
of a class of wastes consisting largely of gypsum and heavy metal
compounds from the treatment of metal-containing wastewater with
lime.
The presumed danger resulting from on-land disposal of
these wastes is solely from the potential discharge of the metals
into ground and surface water. It is proposed that there should
be provided under a permit system a procedure called Standard
Leaching Test (SLT) to determine if the waste is hazardous by agi-
tating with an acid to determine if inorganics, specifically
metals, are leachable. There: would also be provided a Standard
Attenuation Procedure (SAP) to simulate the transport of the
elements from the on-land waste to the soil and aquifer.
The EPA has recommended that where there is a danger of
attenuation of harmful elements from the on-land waste that liners
shall be used in the disposal areas to hold these elements in
place.
It is a fact that most of the solid waste generated by
the metal and metal finishing industries is in the form of
sludges with comparatively low solids content with gel-like
properties of thixotropy. There is very little risk that in
such sludges there will be a leaching action of water penetrating
the solid waste and flowing out into the ground.
The real problem in almost all instances is that rain
water will raise the level of the sludge due to its impenetra-
bility and finally overflow carrying solids. The correct engineer-
ing solution of this problem is to provide a basin with correctly
graded subsoil to retain the solids while permitting a controlled
percolation of water. This would accomplish a thickening and
dewatering of the sludge and provide greater solids retention per
unit area with reduced risk of breakthrough.
i U o' 3
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There is available a sufficiency of knowledge of soil
science for the design of grading specifications for subsoil to
provide a complete range of penetrability from that of gravel
to almost zero permeability in aggregate combinations similar to
those used in earth dams with greater reliability and lower cost
than for membrane liners in most cases.
Cement liners, which are highly recommended, are un-
suited for holding large volumes unless they are provided with
expansion joints and footings at prohibitive cost.
For the large number of owners with individually small
volumes of sludge for disposal, there should be a simplification
of requirements for reporting. For those cases of small volumes
of marginally toxic waste, there should be an easing to permit
disposal as ordinary landfill. This is recommended especially
for metal-containing sludge in which the metal contents are com-
parable with those of domestic solid waste disposal of which in
ordinary sanitary landfill is current practice.
There is no logical reason ecologically or in justice
for requiring greater stringency in disposal of solid waste by
industry than in the disposal of domestic waste which presently
contains substantial amounts of the heavy metals. The same
requirements should be imposed for wells around the disposal
site to detect leaching from sanitary landfill into ground water.
Just as the domestic homeowner is relieved of responsi-
bility for waste after it is collected by a scavenger, the same
relief should be afforded to industries generating small volumes
of solid waste from wastewater treatment, provided that the
scavenger is properly authorized or licensed.
While acknowledging that heavy metals, such as arsenic
and lead, occurring in solid waste generated by the copper refin-
ing industry, are potentially harmful and toxic, we wish to main-
tain that copper should not be included among the metals to be
reported and monitored as it is biodegradable in the true sense
of that term and ecologically benign.
S. B. Tuwiner
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IN REPLY REFER TO'
United States Department of the Interior 2912 022)
BUREAU OF LAND MANAGEMENT
WASHINGTON, D.C. 20240
Mr. John F. Lehman
Director, Hazardous Waste
Management Division
Environmental Protection Agency .... n 7 1Q7C
Washington, D.C. 20460 JAN 6 « W/0
Dear Mr. Lehman:
This is in response to your Federal Register announcement requesting
comments on the environmentally safe management of hazardous wastes.
Our particular interest is the potential use of national resource
land for disposal of hazardous wastes.
Briefly, our position is that the private sector should be encouraged
to dispose of hazardous wastes in an environmentally safe manner, but
that Federal Government subsidies in the form of cheap land for dis-
posal sites should not be allowed.
We advocate the use of privately acquired sites, but we recognize that
in some cases federally owned lands may be the most suitable sites for
disposal facilities. However, we do not feel that under existing author-
ities it would be proper to lease national resource lands (Bureau of
Land Management administered lands) for the disposal of long-term
hazardous wastes. In case of noncompliance by the lessees, our only
recourse would be to terminate the leases, but then the Bureau of Land
Management (BLM) would be left with contaminated sites and we have
neither the authority nor the capability to manage them.
We feel that consideration should be given to authorizing a single
Federal Agency to administer federally owned lands for this use with
the consent of the holding Agency, and to provide the long-t<5rm main-
tenance necessary to monitor these sites. We do not feel that the
private sector can be depended upon to assume long-term responsibility
for them.
All leases should be made at fair market value with a bond sufficient to
insure compliance with the stipulations of the lease. In addition, the
future projected costs to the public of maintaining the site should be
discounted to the present time and paid by the lessee.
17CO
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We have issued Instructions to our field Offices prohibiting the disposal
of long-term hazardous wastes on national resource lands, and we intend to
maintain this policy until we receive Congressional authorization to
proceed otherwise.
Sincerely yours,
lsti*>-C+W
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United States Department of the Interior
GEOLOGICAL SURVEY
RESTON, VIRGINIA 22092
OFFICE OF THE DIRECTOR
JAN 3 0 1976
Mr. John P. Lehman
Director, Hazardous Waste Management Division
Office of Solid Waste Management Programs (AW-565)
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Lehman:
We are submitting the following comments on hazardous waste management
in response to your agency's notice in the Federal Register of
September 17, 1975.
In general, we believe that the sixteen discussion topics mentioned in
the Federal Register are pertinent but that they fail to include the
essential matter of geologic and hydrologic characteristics of disposal
sites. It should be recognized that some sites should be rejected because
of geologic or hydrologic considerations, regardless of such protective
measures as linings, concrete, or other engineered works. Attention needs
to be given to the probability that some hazardous material will escape
eventually from any engineered disposal site. In fact, the Geological
Survey and the EPA Office of Radiation Programs are actively studying
current problems of this kind at Maxey Flats, Kentucky and West Valley,
New York.
Solid radioactive wastes in general.
Pertinent references include Geological Survey open-file report IDO-22053
and Professional Paper 717. The latter illustrates (p. 39-48) some of
the kinds of problems concerned with shallow-land burial and disposal of
radioactive wastes, while the open-file report illustrates the development
of a model for predicting the fate of some liquid radioactive materials
discharged to ground water.
With regard to the general principles which should be used in the management
of radioactive wastes, we believe that the guiding principle should be that
there is no such thing as a harmless dose of radiation, in view of the presen
incomplete state of knowledge on risks to humans from exposure to radiation.
CONSERVE
Save Energy and You Serve America!
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We note that the National Council on Radiation Protection has reiterated
from its predecessor, the National Committee on Radiation Protection, that
"there may be some degree of risk at any level of exposure," and that
"it is not unreasonable to follow the assumption of a linear relationship
between dose and effect in the low dose regions." The International
Commission on Radiological Protection has stated that: (1) "it has been
assumed that even the smallest doses involve a proportionately small risk
of induction of malignancies;" (2) "the Commission sees no practical
alternative, for the purposes of radiological protection, to assuming a
linear relationship between dose and effect, and that doses act cumulatively;"
and (3) "this assumption implies that there is no wholly 'safe* dose of
radiation." The National Academy of Sciences has also stated that "the
linear, nonthreshold hypothesis warrants use in determining public policy
on radiation protection." All of the foregoing quotes are from AEC's draft
environmental statement for Management of Commercial High Level and
Transuranium-Contaminated Radioactive Waste (WASH-1539, dated approximately
September 1974, pages A. 1-14 to A. 1-19).
"Low-level" or "other than high-level" solid radioactive wastes.
These wastes, produced by the commercial nuclear power industry, are currently
being disposed mainly by shallow, "sanitary land-fill" methods at six commerci
disposal facilities in the United States. The Geological Survey's concerns
about the management of commercial radioactive solid wastes have been expressed
in Department of the Interior NEPA-related reviews of Nuclear Regulatory
Commission (NRC) draft environmental statements for power reactors and
other nuclear facilities. Our comments and NRC (formerly AEC) replies
have been published in a large number of final environmental statements.
Our concerns may be summarized generally as follows. The disposal of radio-
active wastes is common to every aspect of nuclear energy use. The wastes
are currently being produced in a bewildering variety of solid, liquid,
and gaseous forms, are being treated in complex ways, and are currently
being stored or disposed of by a variety of methods. Decisions related
to disposal and storage are complex because of the great ranges in con-
centrations of various radionuclides in various wastes and the great ranges
of their biological hazard potentials. Decisions concerning the methods
and sites for disposal are complicated by the fact that hydrologic and
geologic environments vary greatly from place to place. For these reasons,
the disposal of the "low-level" and "other than high-level" wastes that
are being produced and that will be produced by operating light-water
reactors and fast-breeder reactors as well as from the fabrication and
reprocessing of fuels present an environmental impact of nuclear-energy
use that should be carefully evaluated, not only for specific facilities,
but also in its totality.
Lai
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In various of our NEPA-related reviews, the Geological Survey has recommended
that environmental statements for commercial nuclear facilities should
include sections on radioactive wastes specifying the kinds of radionuclides
in the wastes, their physical states, their concentrations in the wastes,
and the estimated total volumes of wastes for the expected operating life
of the facility. Additionally, we have recommended that the environmental
statement for each facility should include an evaluation to determine the
suitability of a proposed disposal site for the particular wastes generated
by the facility.
We have recommended that environmental statements should be prepared for the
disposal sites themselves. Such statements should include discussions
of Federal and State licensing provisions, criteria, and responsibilities
in connection with: (1) determination of the hydrogeologic suitability
of the site to isolate specific wastes from the biosphere for specific
periods of time; (2) current and continuing surveillance and monitoring
of the site; and (3) any remedial or regulatory actions that might be necessary
throughout the specific period of time in which the wastes will be hazardous.
The ultimate size and radionuclide inventory of the site and the future
land use also should be considered.
A basic requirement of burial sites for low-level or other-than-high-
level wastes is that the site must have geological, hydrological and
climatological characteristics that will ensure that the radioactive
constituents of the buried waste will not migrate into water supplies or
become available for ingestion or inhalation by man. For these wastes,
the original containers are generally not depended upon for containment,
but instead geologic and hydrologic factors of the burial site, particularly
the ion-exchange properties of the underlying materials, are relied upon.
We believe that quantitative definitions of critical limits to these factors
are required in order to permit selection of naturally suitable sites,
or in order to determine what construction procedures are required to create
artificially those conditions that are lacking in the natural environment.
For example, the critical values of ion exchange capacity of underlying
materials should be specified, such that if lesser values existed naturally
this unsuitable material would be excavated and backfilled with suitable
materials. We are particularly concerned with recent announcements that,
of the six commercial land burial facilities authorized to receive and
bury other-than-high-level wastes, two burial grounds are under reevaluation
because of findings of trace levels of radioactivity through the environmental
monitoring program or because of concern as to control of precipitation
(ERDA's draft environmental statement for U.S. Nuclear Power Export Activities,
dated approximately September 1975, p. 3-238).
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The above-cited environmental statement predicts that by the year 2000
nuclear power-related exports by the United States may reach $250 billion
annually, or about 3.6 percent of anticipated U.S. export revenues at that
time. Although the United States is not engaged in the storage of radio-
active wastes from the use or recycling of U.S.-exported nuclear materials,
these exported materials and the fission products generated from them could
have potential adverse environmental impacts on world populations for extremely
long periods (thousands of years) unless ultimately disposed of according
to standards at least as high as those accepted for management of domestic
radioactive wastes. It should not be .assumed that the radioactive wastes
will be safely managed by all countries, particularly in view of the fact
that two of the six commercial land burial facilities authorized to receive
and bury other-than-high-level wastes in the United States are under reevaluation,
as noted above. We support the conclusion, expressed in ERDA's recent
environmental statement, that establishment of regional waste repositories,
on a world-wide basis, needs to be given more attention than has been the
case to date (p. 3-236).
High-level and transuranium-contaminated radioactive wastes.
New regulations require transfer of commercial high-level radioactive wastes,
after solidification, to Federal custody as soon as practicable, or within
five years after generation, and require transfer of transuranium-contaminated
commercial waste containing more than a specified number of nanocuries
of transuranium activity per gram of waste. Previously, transuranium-
contaminated commercial waste has been disposed of at the six commercial
burial grounds, which in 1972 were estimated to contain a total of about
80 kilograms of plutonium and 480 kilograms of enriched uranium. It has
been predicted that by the year 2010, the custody will occupy 75,000
canisters measuring about one foot in diameter by ten feet long, and
will contain 50 billion curies of fission products and one billion curies
of actinides (i.e., transuranium nuclides).
The favored plan for storage of the high-level wastes is evidently retrievable
storage of canisters in artificially-cooled water basins, in what is termed
a Retrievable Surface Storage Facility (RSSF), while the transuranium-
contaminated wastes would be held in a shallow landfill with about three
feet of earth cover, also designed for easy retrieval (information from
AEC's draft environmental statement for Management of Commercial High Level
and Transuranium-Contaminated Radioactive Waste, WASH-1539, dated approximately
September 1974).
Our concerns with the proposed plan for management of high-level and
transuranium-contaminated radioactive wastes include: (1) the ultimate
disposition of the transuranium-contaminated waste already buried in the
six commercial burial grounds; (2) the methods by which transuranium-
contaminated wastes will be segregated from those not so contaminated,
i". ^5
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and by which compliance will be monitored, in view of the low penetration
characteristics of alpha radiation and infeasibility of measuring such
activity from outside a waste container; (3) concerns relating to the
environmental characteristics of the landfill disposal site or sites,
similar to those expressed above in regard to commercial low-level burial
sites; (4) methods to be used for inventory of radioactive wastes or other
means for detecting losses; (5) method of solidification of liquid high-
level wastes prior to their transfer to Federal custody; (6) waste-
management activities, including solidification of liquid wastes, at major
Federal facilities such as Hanford Reservation in Washington, Oak Ridge
National Laboratory in Tennessee, and Savannah River Plant in South Carolina;
and (7) the need for an ultimate long-term plan for disposal of all such
radioactive wastes.
Nonr a d i oactiye hazardou s was t e s.
Some of the problems encountered in disposal of hazardous wastes at sanitary
landfill sites are exemplified by the West Contra Costa Sanitary Landfill
Project, situated 1.2 miles from the edge of residential North Richmond
at the southeast edge of San Pablo Bay, California. This is one of four
sites in the San Francisco Bay region that accepts Class I (hazardous)
wastes, and is the only Class I general purpose solid-waste disposal site
in the region. The landfill site is designated for ultimate use as a park
and shoreline recreation area. Class I waste is confined to a separate
section of the site. During a three-month period of 1974, the site received
three million gallons of chemicals and 7,422 55-gallon drums. Only about
60 percent of customers contacted provided information that was requested
concerning liquid waste dumped at the site.
Fifty-six known fires have occurred at the site from 1961-1973, 17 of them
since October 1972, and at least three have occurred at the Class I disposal
area. On two known occasions in the last five years, chemical drums have
ruptured and/or exploded, causing fires and fumigation, one instance prompting
criminal action against the landfill operators. It is also noteworthy
that the accident frequency rate among disposal-site operators is one of
the highest in all industries and municipal activities. (Foregoing information
was obtained from the Corps of Engineers' draft environmental statement
for West Contra Costa Sanitary Landfill Project, regulatory permit application,
Contra Costa County, California, dated approximately June 1975).
Among the concerns that should be given further consideration in management
of hazardous wastes at this and similar disposal sites are: (1) detailed
provisions for segregation of noncompatible wastes; (2) possibility that
radioactive chemical wastes might have been dumped at the sites; (3) pro-
visions to protect workers and the public from sealed containers of skin-
contact poisons or other hazardous materials that may be buried and that
-------
might rupture at some future date if the sites were graded for use as parks,
recreation areas, or other uses; and (4) need for long-term water-level
and chemical monitoring in the vicinity of the disposal areas by means
of one or more wells tapping underlying aquifer(s).
Comments on specific Discussion Topics.
Item 6. — Environmentally sound management of hazardous waste storage and
disposal sites will require assurance of containment when one considers
the natural processes such as wind, surface and subsurface erosion, surface
transport and subsurface transport.
All waste management sites must be in environments where the hydrogeological
regimen is fully understood. The site must be amenable to solute transport
modeling. It is economically impossible to construct and engineer any
site into one of complete containment. It should, however, be possible
to identify sites which will provide containment for X number of years
and thereby allow for disposal of specific waste with reasonable assurance
of containment.
Item 7. — To adequately monitor a disposal site, one must be able to construct
a digital solute transport model of the area. To adequately model the site,
one must have hydrogeological parameters for hydrologic model plus geo-
chemical and geophysical parameters for the solute model. These latter
include a complete knowledge of the chemistry of the waste material, the
mineralogy of the aquifer materials, and the chemistry of the natural occurring
waters. If one has these data, then meaningful monitoring of wells can
be installed and sampling procedures can be designed to detect and follow
waste movements.
Item 9. — The monitoring program outlined above should provide adequate
control for operating as well as decommissioned burial sites. An adequate
monitoring program should provide data on waste movement prior to the time
when something must be done to protect the biosphere. With advance warning,
engineering techniques will have to be developed for handling the problem.
When a site is selected, the monitoring system must be designed and then
monitoring will have to be continued into the future.
We appreciate the opportunity to comment on this important topic.
Sincerely yours,
^Lc^~^-^^~ <-~/
irector (
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DEPARTMENT OF TRANSPORTATION
MATERIALS TRANSPORTATION BUREAU
WASHINGTON, D.C 20590
8 MAR 1375
Mr. John P. Lehman
Director
Hazardous Waste Management Division
Office of Solid Waste Management
Programs (AW-565)
Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Lehman:
This refers to the September 17, 1975 Federal Register Notice
(FRL 432-5) , concerning a series of public meetings held by
your agency on Hazardous Waste Management. As you are aware,
this Office has had several discussions with your Office
during the past year regarding the regulation of hazardous
wastes during transportation, and has been cooperating with
you on the NATO/CCMS Subproject on transport of hazardous
wastes.
The following comments are offered with respect to items
11 and 12 of the discussion topics listed in the September 17,
1975 Notice:
11. To what extent are existing transportation safety regula-
tions~and definitions useful and sufficient ro govern the
transport (both interstate and intrastate) of hazardous wastes,
as distinguished from substances?
At present, the transport safety regulations for hazardous
materials do not provide specifically for any classification
or designation of "hazardous wastes" by name. Instead, the
general methodology of most transport regulations worldwide,
including the USA, is to categorize "hazardous materials"
into a limited number of "generic" classifications, i.e.,
explosives, flammable compressed gases, nonflammable compressed
gases, flammable liquids, combustible liquids, flammable solids,
oxidizing materials, toxic materials (poisons), etiologic
agents, radioactive materials, and corrosive materials.
i'l 03
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Specific hazardous materials may then be listed by name as
being in a designated classification or, as in the USA when
not listed by name, may be regulated as an "n.o.s." (not
otherwise specified) material. The regulations then provide
quantative or qualitative classification criteria which
enables a shipper to determine if his material is subject to
the regulations as a hazardous material for purposes of trans-
port. A number of complications are presented when one tries
to correlate such a scheme to the broad context of "hazardous
wastes." Specifically, hazardous wastes may be of very low
concentration with respect to the "active ingredient" and,
therefore, may not be subject to our regulations during trans-
portation. Secondly, a waste material may contain in its
matrix, a mixture of different "active ingredients" having
differing hazard characteristics, i.e., flammability and
toxicity.
It is extremely important to also recognize the philosophy
on which the hazardous materials transport regulations are
principally based at the current time. Containment during
transport is aimed at protecting the transport worker and
general public from the acute hazard due to intermittent or
one-time short duration exposures. With hazardous wastes,
however, the chronic long-term low-level exposure or environ-
mental degradation aspects would appear to be a dominant
consideration.
These regulations for hazardous materials are further
typically structured so as to prescribe specific packaging
requirements, generally as detailed engineering design
standards, performance-oriented criteria, or a combination of
both. Such prescriptions generally relate the degree of
packaging integrity under normal conditions of transport so
as to provide the required degree of containment.
Recent legislation, i.e., the Transportation Safety Act of
1974 (P.L. 93-633), has established a new definition for
"hazardous material." In 8 103(2) of the Act, a hazardous
material means "a substance or material in a quantity or
form which may pose an unreasonable risk to health and safety
or property when transported in commerce" (emphasis added).
In view of this new definition, we are presently reconsidering
the issue of whether the existing philosophy of regulating
hazardous materials in transportation only, on the basis of
their acute hazard to safety, is still appropriate.
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12. To what degree should labeling and placarding of waste
shipments be required? What are the most effective and
accepted systems for such labeling and placarding?
The required degree of labeling and placarding of waste ship-
ments, as well as their packaging, are the basic parameters
that would have to be established should a determination be
made to regulate hazardous materials (including hazardous wastes)
on a basis other than acute safety hazards, as discussed in
#11 above.
Should a decision be made to include hazardous wastes into the
regulatory framework for hazardous materials, the initial
task will be to establish the proper shipping name descriptors.
To this end we would look to your agency for guidance and
recommendations. Going further from that, the required degree
of labeling and identification needs to be established, and
then the packaging. Of all the parameters, the communications
requirements, i.e., labels and placards, appear to be the most
important for early consideration. We are not aware of any
major problems in the packaging area and it appears that the
presently required degree of packaging would be adequate to
contain the hazardous wastes for purposes of transportation
and handling.
Sincerely,
Alan I. Roberts
Director
Office of Hazardous Materials
Operations
cc: W. J. Burns
IV10
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VENTURA REGIONAL
COUNTY SANITATION DISTRICT
December 22, 1975
JOHN A LAHEQG
CHIKF ENQINSKR
L MANAGER
MEMBER AGENCIES
VENTURA COUNTY
CITIES
Camanlh
Fillmore
Of*
Oxnard
fort Hueneme
San Bufnaventunt
Sana faula
Sun, Valley
Thousand Oaks
SPECIAL DISTRICTS
Camarilla Sanitary
Camrosa
County Water
Chan
Com
Island,
later
Memer, Oaks
Santtary
Montaho Municipal
improvement
Moorfark County
Sanitation
Oat Viem Santtary
Sattcoy Sanitary
Simi Valley County
Sanitation
South Coast County
Sanitation
South Coast County
Sever Maintenance
Tnunfo County
Sanitation
Sanitary
Ventura County
Waterworks Districts
Not I, » and 16
Environmental Protection Agency
Office of Solid Waste Management Programs
AW-565
Washington, D. C. 20460
Attention Mr. John P. Lehman, Director
Hazardous Waste Management Division
Dear Mr. Lehman:
Hazardous Waste Management
Your office, as indicated in the Federal Register, Volume 40, No. 181,
September 17, 1975, has solicited comments on the subject topic.
This Regional District, the only one of its kind in California, is responsible
for meeting the disposal needs of 440,000 persons in a 1,900-square-mile
area. Our Class I sanitary landfill located at Simi Valley is one of eleven
operating sites in this state.
The biggest problem facing both governmental agencies and private industry
involved in hazardous waste disposal is in obtaining replacement sites.
There is no question that tightening of air and water controls will markedly
increase quantities of material now being sequestered in sanitary landfills.
It is also true that this disposal method, if done properly, is the most
cost effective solution to a crucial problem.
We have tried on two separate occasions to obtain replacement Class I
sites only to be turned back by the tide of public opinion. The politicians
could not cope with the onslaught of aroused citizenry and further consider-
ation was stopped at the Environmental Impact Report stage. People seem
to realize there is a need for such a facility, but say "don't put it here. "
With the capacity of our remaining site due to expire in 1983, positive
action must begin now.
Mati4ng A
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Mr. John P. Lehman - EPA December 22, 1975
What part can the federal government play in solving this problem? In
California, the approach should be to work through the State Health Depart-
ment, Vector Control Section, and the State Solid Waste Management Board
according to the following strategy:
1. A detailed statewide inventory of all hazardous and potentially
hazardous wastes. (Work has already started in two counties:
Ventura and Alameda)
2. Determine the number and location of Class I sites to meet the
state's projected needs. Consider use of federally owned lands
where applicable. Consider regional transfer station for more
sparsely populated areas.
3. Fund Class I site acquisition and start-up costs similar to the
State's Clean Water Bond Act program now in effect. (12-1/2%
local, 12-1/2% state, 75% federal funding)
Local government should be required to face the responsibility of providing
suitable disposal methods or sites for hazardous wastes. If they fail to act
then, and only then, should the state or federal government become involve
The current shortage of Class I sites in California is largely due to the
provincial attitude of letting someone else take care of their problems. Ho
fully, current efforts by the State Solid Waste Management Board to evalua
the Class I disposal situation will establish direction for further action.
Thank you for the opportunity to comment.
Very truly yours,
John A. Lambie
Chief Engineer-General Manager
PAB:sgs
cc: Al Marino, SSWMB
Harvey Collins, SHD
it .1.2
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Eugene T Jensen
Executive Secretary
Post Office Box 11143
(804)766-1411
COMMONWEALTH of V1RQINIA
STATE WATER CONTROL BOARD
2111 Hamilton Street
INREPtY,
REFER TO:
JAN 2 S 1976
1-PR
BOARD MEMBERS
J Leo Bourassa
Denis J Brlon
G«orge M. Cornell
Millard B. Rice, Jr
Mr. John P. Lehman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs (AW-565)
U. S. Environmental Protection Agency
Washington, D. C. 20460
Dear Mr. Lehman:
Provided herewith is a paper titled "Hazardous Wastes and Their
Management"f prepared for submission in response to the invitation
appearing on Page 42993 of the Federal Register dated Wednesday,
September 17, 1975 (Volume 40, No. 181).
It is hoped that the information provided in the paper accompanying
this letter will be of substantial assistance with respect to the
question of hazardous wastes management.
Sincerely yours,
Eugene T. Jensen
Executive Secretary
/Is
Enclosure
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HAZARDOUS WASTES AND THEIR MANAGEMENT*
Introduction:
Many categories of naturally occurring materials present potential
safety problems which become actual hazards under conditions which
alter an existing equilibrium condition. For example, the use of
natural foods may present hazardous conditions, either from the
standpoint of over-consumption or non-consumption in the simplest
instance. For example, a number of common foods reportedly con-
tain substances which produce cyanide during digestion and some
traces of the free cyanide ion. In addition, naturally occurring
waters contain constituents such as fluorides and other compounds
which could prove to be hazardous. Naturally occurring are com-
pounds of mercury in geologic formations which during the evolu-
tionary process provides exposure to life forms with varying
degrees of toxic effects.
It is rather obvious that nothing is wholly safe or dangerous in
or of its own self but that it is the quantity involved, the man-
ner and conditions of use, and the susceptability of the organism
which determines the degree of hazard or safety.
Judgments regarding safety of materials must involve knowledge
of the material and its inherent capacity to cause harm and of
the conditions of use which determine to what extent this
capacity for harm will be realized. It should be recognized
* Prepared for submission to the Director, Hazardous Waste
Management Division, Office of Solid Waste Management
Programs, U. S. Environmental Protection Agency, Washington, D.C.
By Eugene T. Jensen, Executive Secretary, Virginia State Water
Control Board, January 27, 1976.
I I i^
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that safety is a pathway between hazards, some of which are
recognizable and measurable with others unknown and indistinct.
There is no escape from all risk no matter how remote. There
are only choices among risks. Safety lies in proceeding on a
path through balance and moderation rather than indulgence in
extremes.
Man in his evolution has struggled to protect himself, his food,
and his belongings from the ravages of nature. Among the tools
that he has used are compounds which kill or suppress pests.
These compounds include insecticides, fungicides, bactericides,
herbicides and rodenticides to name a few. Such materials, and
other toxic compounds, have contributed to human welfare in many
ways both with respect to human health and to the production of
food and fiber and other economic goods of benefit to humanity.
Toxicity is the inherent capacity of a material to cause harm
whereas hazard is the risk that, under any particular set of
circumstances, harm will occur. A highly toxic material may be
safely manufactured, handled and applied with little hazard and
conversely, a material of relatively low toxicity may be handled
or used in a hazardous manner.
The objective with respect to the use of toxic materials should
lead us to the making of better balanced decisions to ensure that
positive effects on the environment are balanced against negative
ones and that nonenvironmental effects are duly considered. Such
decisions should be made with knowledge sufficient to eliminate
surprises which in turn will allow an assessment of the risks
involved. > , ' ^
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Toxicity is the ability of a material to produce injury to life
forms in the environment when those life forms are exposed to
that material. Hazard is.the probability that injury will be sus-
tained by exposure to toxic materials.
The term "hazardous waste" has been defined in' the proposed
Hazardous Waste Management Act of 1973' as "any waste or combination
of wastes which pose a substantial present or potential hazard to
human health or living organisms because such wastes are nondegradable
or persistent in nature or because they can be biologically magnified,
or because they can be lethal, or because they may otherwise cause
or tend to cause detrimental cumulative effects". The May 1975
Environmental Information Bxilletin, published by the U. S.
Environmental Protection Agency, characterises hazardous wastes as
"wastes that pose a substantial danger, immediately or over time,
to human, plant, or animal life and which, therefore, must be handled
or disposed of with special precautions. They may be chemical,
biological, flammable, explosive, or radioactive substances." These
definitions appear to cover the subject well; however, in view of
the fact that the degree of hazard involved is a function of handling-
use, application, disposition, and exposure, it would be well to
include these considerations in any discussion of the definition of
hazardous wastes.
In the manufacture of toxic materials, it appears to be most difficul
if not near to impossible, for any single regulatory agency or any
combination of regulatory agencies effectively to determine the
characteristics of existing and evolving compounds and to determine
1716
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appropriate measures .for their handling, use, application, and
disposition in order to minimize adverse effects of such compounds
upon living organisms to which they may be exposed. The burden of
responsibility with respect to such determinations more properly
should rest with the generator of potentially toxic and hazardous
compounds prior to the determination by a regulatory agency ol the
efficacy of handling, use, application, disposition and exposure.
The generator of potentially toxic and hazardous materials should
bear the burden of determining, in addition to the foregoing,
detoxification processes appropriate to apply to insure environmental
protection.
Storage and Transport:
The minimization of adverse effects to the environment by potentially
toxic and hazardous materials may be accomplished to a significant
degree through a requirement of manufacturers, handlers, users,
and disposers, by regulation to develop plans designed to
prevent escape of such materials to the environment to include
measures for containment and hazard elimination in the remote
event of escape.
Use of Toxic Materials in Manufacturing and in Agriculture
Since the beginning of recorded history man has been exposed to toxic
and potentially hazardous materials which have occurred naturally,
as well as to those which have evolved during his evolutionary
efforts to provide for and to protect himself. Use of these materials
has presented man with dangers as well as with benefits and indeed
toxic materials are necessary elements in the production of food and
fiber, in manufacturing, for health considerations, and in general
they are necessary for day-to-day living. Proper management of the
I'll''
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generation, handling, use, application, disposition and exposure to
the environment of toxic materials in such a manner as to minimize
adverse effects to the environment is fundamental to any program
with which to deal effectively in avoiding hazards and in realizing
the benefits to be derived from those materials. Management should
lead to the making of decisions balanced so that positive effects on
the environment are realized and negative effects minimized or
eliminated. ,
Regulatory Experience:
The Commonwealth of Virginia, since 1946, has been engaged in a pro-
gram of water pollution control, the purposes of which include the
protection of the quality of waters of the State; to restore other
State waters to such condition of quality that will permit reasonable
public uses; will support the propagation and growth of aquatic life;
and provide for the health, safety and welfare of the citizens of the
State. The State has had a program of responding to water pollution
complaints which provides for the reporting on the part of citizens,
industries, agencies, and others, of pollution incidents of all types
on a 24 hour a day basis. Experience of the agency has demonstrated
somewhat less than 100 per cent effectiveness in an ability to:
1. Determine where and when potential hazardous materials
will occur in the environment as a result of mismanage-
ment and/or accident.
2. Determine and evaluate immediately the potential impact
on the environment of potentially hazardous materials.
3. Implement immediately procedures for containment, cleanup, and
detoxification of toxic wastes entering the environment.
1718
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4. Depend on the voluntary assistance of the generator,
user, and discharger of toxic materials, in attempts
to minimize or to eliminate hazards to the environment.
The experience of the State Water Control Board in the pollution
complaint program during a recent four-year period permits the
categorization of incidents involving toxic materials identified
as follows:
Category of Incident Percentage of Incidents
1. Irresponsible accumulation
of and/or improper disposal 25
of toxic materials
2. Lack of containment of toxic
materials at industrial facil- 22
ities (accidental non-trans-
portational)
3. Discharge of toxic materials
16
with inadequate treatment
4. Transportation (accidental by
truck, rail and waterborne 15
vessels)
5. Misapplication through use 12
6. Miscellaneous 5
7. Discharges through wastewater
4
treatment plants
8. Natural disasters 1
The majority of the incidents experienced by the State Water Control
Board with respect to the various categories clearly involve
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categories 1 through-5. An analysis of these categories emphasizes
the need for management to be directed toward the arena of contain-
ment and prevention of excape and disposal of toxic materials
through regulation. Comments relative to regulation in the five
cagetories are as follows:
1. The mechanism for an effective deterrent relative to
this category could be provided through a liability/
penalty system as described in Section 311 of the
Federal Water Pollution Control Act Amendments of
1972. The effectiveness of regulation through this
mechanism might be somewhat less than wholly
effective due to the difficulties involved in the determi-
nation and designation of extant and evolving toxic
compounds and materails. Regulations and/or guidelines
with respect to proper land disposal of toxic materials
should prove to ameliorate adverse environmental effects
potentially imposed by this category.
2. Release to the environment under conditions described
in category 2 might well be ameliorated with application
of regulations comparable to the regulations promulgated
by the U. S. Environmental Protection Agency relating to
the prevention of oil pollution as found in Title 40,
Chapter 1, Part 112 of the Code of Federal Regulations.
Such a regulation would require the owner or operator
of a facility where toxic materials are generated, used,
or stored, to prepare and implement a plan which would
prevent discharge to the environment of such toxic
materials.
1720
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3. This category should be properly handled through
application of the National Pollutant Discharge
Elimination System and compliance therewith with
respect to pretreatment and final treatment of
wastewaters.
4. The category applicable to release to the environ-
ment of toxic materials through mishaps in trans-
portation could be approached through promulgation
and enforcement of stringent regulations requiring
suitable containment vessels of such nature as to
withstand mishap-imposed stresses with provisions
for primary, secondary and tertiary containment
hulls utilized in transport facilities.
5. The question of misapplication and abuse in the
use of toxic materials has primarily involved
exposure to the environment of compounds which kill
or suppress pests some of which are in the process
of being regulated under the provisions of the
Federal Insecticide, Fungicide and Rodenticide Act,
as amended in 1972. Reexamination of that act and of
regulations promulgated under the provisions of
that act is in order with respect to the need for
broader application and/or more effective enforcement.
The question of biochemical, biological, and/or chemical
synergism where there is cooperative action of discrete substances,
the total effect of which may be greater than the sum of the
discrete substances when taken independently, needs to be considered
in any management plan involving exposure to the environment of
1721
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potentially toxic materials. This aspect of the subject is
exceptionally complex and presents its own unique problems which
should not be minimized.
Conclusion:
The minimization of adverse effects of toxic materials to living
organisms in the environment substantially can be improved by
altering exposure to these materials by gathering knowledge so as
to:
1. Understand more fully the biochemical mechanisms by
which toxic materials affect living organisms
within the environment.
2. Improve and expand investigations of the impact of
toxic materials to which there is environmental
exposure.
3. Improve the gathering of information relative to
the characteristics of existing and evolving toxic
materials and how these materials should be safely
manufactured, handled, and applied to reduce
environmental threats through balanced decision
making.
4. Make the public aware, routinely and timely, of
the data concerning existing and evolving toxic
materials used or proposed for use.
The State Water Control Board believes that reaction to the
toxic materials question and hazards and benefits relative thereto
should be positive and that economic, nutritional, and health
welfare must be balanced against occupational and environmental
safeguards with more precise definition and assessment of the
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situation being requisite to the formulation of appropriate
management programs.
Recommendations:
In summary, recommendations need to be based on as clear a view
as possible of the overall problem considering economic,
nutritional, and health benefits derived from potentially toxic
materials, all balanced against environmental safeguards.
Specifically the following recommendations are made:
1. The formulation of a discharger liability/penalty
system conforming in general with the provisions
of Section 311 of the Federal Water Pollution
Control Act Amendments of 1972.
2. Promulgation, implementation and enforcement of
prevention, containment and detoxification plans
applicable to those generating, handling, applying,
using, and storing toxic materials.
3. Development, promulgation, and enforcement of
regulations which would cause the provision of
more suitable containment vessels for transport
of toxic materials.
4. Expansion and enforcement of regulations regarding
use and misuse of potentially toxic and toxic
compounds.
5. Formulate regulatory mechanisms whereby generators
of and manufacturers of toxic materials bear the
burden of responsibility for the designation of
extant and evolving toxic and potentially toxic
and hazardous compounds, to include a determination
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of the acute and chronic levels of toxicity to
living organisms within the environment.
6. Formulation of regulations placing with the
manufacturer or generator of potentially toxic
and hazardous materials the responsibility for
establishing processes and procedures for
detoxification of final and intermediate products
and residuals.
7. Provision of a mechanism whereby access may be
had to facilities for destruction and/or detoxifi-
cation of toxic and hazardous materials and their
residuals.
8. Provision for further emphasis on placing with
dischargers to municipal waste treatment plants of
potentially toxic and hazardous materials the
responsibility for pre-treatment and the responsi-
bility for notification to the potential receiver
of such materials their characteristics relative to
potential toxicity, hazards, and detoxification
processes and procedures required to eliminate or
minimize potential adverse environmental effects of
such materials.
9. The provision of a national data bank for ready access
which could be interrogated by public emergency
services entities for the purpose of facilitating
the identification of materials and their hazards,
and advice for their handling in order to minimize
their potential adverse environmental effects.
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10. The evaluation of the extent to which environmental
aspects might be enhanced in the wastewater treat-
ment train by the provision of "multiple barriers"
in the treatment train where waste streams involve
potentially toxic and/or hazardous materials for
the purpose of the potential development, promulgation,
and enforcement of regulations which would require
"multiple barriers" as appropriate.
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Waste Management inc.
900 Jorie Boulevard • Oak Brook, Illinois 60521 -312/654-8800
December 29, 1975
Mr. Timothy Fields, Jr.
Acting Program Manager
Hazardous Waste Assessment
Hazardous Waste Management Div. (AW-465)
Office of Solid Waste Management Programs
U.S. Environmental Protection Agency
Washington, D.C. 20460
Dear Mr. Fields:
Please include my enclosed letter of December 29, 1975 as part of the
public record with regard to the public meetings held this December on
Hazardous Waste Management.
Thank you.
Sincerely,
DLS:cb
Enclosure (1)
5avid L. Smillie
National Accounts Manager
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Waste Management inc.
900 Jone Boulevard • Oak Brook, Illinois 60521-312/654-8800
December 29, 1975
Mr. Timothy Fields, Jr.
Acting Program Manager
Hazardous Waste Assessment
Hazardous Waste Management Div. (AW-465)
Office of Solid Waste Management Programs
U. S. Environmental Protection Agency
Washington, D. C. 20460
Dear Mr. Fields:
Confirming our telephone conversation of December 22, 1975, following
are our reasons,for believing the thirteen industrial hazardous waste contract
studies are vital to an early understanding of our national hazardous waste
problems and a positive force for solving those problems in a fully practical
manner.
If the two contract studies we've reviewed (Inorganic Chemicals and
Batteries) are typical of what we can expect to see in the remaining eleven
studies, they represent the first practical data accumulation with which to
depict the parameters of our hazardous waste problems.
These studies provide a data base that can be manipulated mechanically
(through EDP programs) to project the nature and quantity of hazardous waste
streams, thus disclosing treatment and disposal markets for the private service
companies to concentrate upon. They will help us design and operate private
and public systems for minimizing the environmental impact of these effluents.
Our intent is to quantify and qualify waste stream identification for each
major plant in our present service areas. This information can be added to our
base data.
We can then run various analyses to establish statistical indicators or
factors which can be applied against similar installations outside our operating
areas to project their anticipated generations of waste by type and volume.
Our program can become a marketing tool designed to tell us probable
return on investment in unknown markets and what equipment, personnel and
technologies should be represented for best return in these new markets or
in existing markets where profitable new service capabilities could be
established.
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Mr. Timothy Fields, Jr.
December 29, 1975
Page Two
We needed the contract studies on hazardous waste because they give us
a dimension on hazardous waste not readily attainable due to the extraordinary
complexity of the hazardous waste field. Keyed to SIC codes, like our base
data, your information can be manipulated in our program to attain our immediate
information objectives.
However, there is an obvious problem with the SIC codes in any data
manipulation program. Each plant generally has more than one SIC code —
and frequently, as many as six SIC codes. They perform more than one type
of classified work at one location. It's virtually impossible to quantify
waste streams where multiple SIC codes pertain unless you verify volumes of
work performed within specific SIC's, and these volumes shift continuously.
This "Catch 22" requires interviews with knowledgeable personnel at
the site, which we're set up to do in a special interview sequence either locally
or by working through cooperative executives at the corporate level.
From commercial data sources, we already have EDP manipuldtable
information identifying specific industrial facilities with a good range of
statistical data such as:
SIC Codes (type of work performed on site)
Number of Employees
Dollar Sales
Key Plant Executives
Mailing Addresses and Phone Numbers
Types of Metal Processes (at metal working plants)
HQ, Branch or Single Location Identifiers
Parent Companies, Divisions, Subsidiaries and Affiliates
From our customer records, we can determine solid waste and secondary
recoverable wastes data by type and volume, and we have working relationships
with client personnel to develop additional waste stream identification data.
Our operating divisions have good knowledge of private and public
treatment, disposal and recovery facilities, current and projected for near term.
.A : •<- 3
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Mr. Timothy Fields, Jr.
December 29, 1975
Page Three
By some estimates fewer than 1,000 companies control 80% of the
manufacturing and distribution assets in this country. Each of these firms
has anywhere from one to 5,000 locations but possibly fewer than 50,000
locations employ over 100 employees. Far fewer than that employ over
500 employees at single locations where hazardous waste is generated in
significant quantities.
If employment, weighted by SIC (type of work performed) is a good statistical
indicator of effluent generation, then perhaps fewer than 10,000 locations are
the principal generators of hazardous waste. We then have a manageable
number of plants for which to design treatment systems to minimize the effect
of the major portion of hazardous waste.
Your hazardous waste studies, together with other available machine
processable data, give us the means to project quantified and fully identified
hazardous waste streams on a plant site by plant site basis.
From this data, we may be able to better determine which of these
waste streams (and where) can be handled by the private sector and which ones
will require partial or total government funding.
Reducing the risk element for capital investment planning encourages
private financing of treatment, recovery and disposal facilities and allows
us to suggest better deployment of government funds where the risk factors
or project size are beyond private capital resources.
The 13 contract studies alone are not enough data to produce such a
profound effect in the short term. However, it allows us to reduce the number
of major identifiable generators to a few thousand and trace their ownership
back to a few hundred companies. We can then initiate an interview system
to refine our initial projections into acceptable parameters for facility planning
without adding an enormous market research burden.
Once we determine source, quantity and nature of hazardous waste, our
task becomes relatively simple. We, as a private service company, can
determine which waste streams justify service within our capability resources.
We'll know where and to what extent we can respond to projectable handling
and treatment requirements.
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Mr. Timothy Fields, Jr.
December 29, 1975
Page Four
There is substantially only one additional equation needed in order to
assure our design and construction of necessary facilities — reliable knowledge
of regulatory parameters and the degree of uniform enforcement of those control
measures. That's the really tough part because it is a political problem.
Every intelligent human being wants to preserve, if not enhance, the
quality of life — if it's free. A community wants the use of a landfill, for
example, but it wants it located in someone else's backyard. Politics — the
art of compromise — is the medium through which such problems are resolved.
Knowing the dimensions and locations of the problem is important because
it points to the significant options that can be negotiated through politics.
The more information you can give us — like these 13 hazardous waste
studies — the better able we are to cooperatively suggest model legislation and
regulatory interpretation to produce optimum results with minimum economic
dislocation.
There has always been a high price paid for waste treatment and disposal.
The price for bad disposal practices is paid in human lives, impaired health
and economic disaster.
For example, one drum of hazardous chemical waste hidden within a
relatively innocuous load of solid waste can lead to the death of a landfill
compactor operator and the total destruction of a $100,000 piece of equipment
as described in your June, 1975 Hazardous Waste Disposal Damage Report.
Properly identified, that one drum might have cost its generator $20 or
$30 to dispose of properly rather than incur the cost of a man's life and $100,000
worth of equipment. If that drum contained low flash point spent solvent, there
might even have been a secondary material recovery market for it to reduce
the net cost of handling and disposal.
Measured in these terms, the cost of beneficial disposal, treatment and
recovery is paid in a very modest amount of money. Under uniform inspection
and enforcement, that cost can be absorbed in manufacturing or distribution
costs with minimal economic dislocation.
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Mr. Timothy Fields, Jr.
December 29, 1975
Page Five
Total system engineering directed toward resource recovery rather than
terminal waste disposal can reduce disposal costs for secondary materials
and conserve finite virgin materials.
We know that hazardous waste treatment and disposal is where the money
is going to be in our service industry. But, under present conditions, it is
a capital intensive, high risk investment in an area of great complexity and
swifty changing control parameters.
That's why we're working on our EDP system and why we want your
input. We can reduce our risk and deploy our finite capital resources better
when we can be intelligently selective about which waste streams we will
handle, the quantities and locations of it, and when enforcement will apply
to make our facility design economically viable.
It would be idiotic for us to build a ten or twenty million dollar facility
if we knew that unresponsible operators would be allowed to continue to use
country roads in the dark of the night as unsupervised "shallow well injection
systems."
So, we're paying tribute to the old adage, "in the land of the blind, a
one-eyed man can become king." The more we know about these waste
streams, the better able (and more willing) we'll be to put our knowledge
and capital to work solving the problems created by them.
Your continued help is not only appreciated — we consider it vital.
We are looking forward to proceeding with our planning models upon receipt
of the remaining 11 studies as well as the benefits your own EDP programs will
represent for the entire industry and our country at large.
Sincerely,
>avid L. Smillie
National Accounts Manager
cc: Donald B. Mausshardt
William Sanjour
1731
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A
Weyerhaeuser Company
Tacoma, Washington 984O1
(2O6) 924-2345
January 29, 1976
Mr. Emery Lazar
U. S. Environmental Protection Agency
Hazardous Waste Management Division
Waterside Mall, 401 M Street, S.W.
Washington, D. C. 20460
Dear Mr. Lazar:
It was a pleasure meeting you at the Hazardous Waste Manage-
ment meeting in San Francisco last December.
The management of solid/hazardous wastes is a formidable
task because, to a very large extent, the public is an
important contribution to these wastes. Thus any efficient
management system will require a change in lifestyles.
With that perspective, perhaps it is best then that EPA
promulgate advisory guidelines for the time being. This
would allow opportunity for public education on the subject,
and also allow EPA to gain some more understanding about
the return of materials to the environment. Effective
education remains the only long-term hope for constructive
participation in this problem.
The road ahead is challenging. I wish you well.
Sincerely,
Lee
Vivien Lee, Ph.D.
Environmental Impact Analys
VL:jh
", 7
«J
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January 27, 1976
Mr. John P. Helman, Director
Hazardous Waste Management Division
Office of Solid Waste Management Programs
Environmental Protection Agency
Washington D. C. 20460
The Wichita-Sedgwick County Environmental Resource Advisory Board
respectfully submits the following comments in response to the Notice
of Public Meeting concerning Hazardous Waste Management dated
September 11, 1975, FR Volume 40, No. 181 - Wednesday, September 17,
1975.
The Environmental Resource Advisory Board (ERAB) believes that the
EPA published estimate of 10 million tons for the quantity of hazardous
waste generated may be conservative. A recent survey conducted by
the Kansas Department of Health and Environment for 143 industrial
firms in and around Wichita, Kansas, indicated that over 2 million tons
of hazardous waste was generated from this area alone.
The Board believes that it is in the best interest ofiindustry and the
community that properly licensed hazardous waste disposal facilities
exist. Such depositories should allow for safe and economic disposal
of hazardous materials without compromising the health and safety of
the public. The Board appreciates the fact that proper handling--
processing and/or disposal—may require joint participation of industry
and government (local, state and federal).
In the area of management of hazardous wastes, the Board recommends
that efforts be directed to eliminating unacceptable methods of disposal
such as discharging to sanitary sewers and open on-site dumping of
hazardous wastes. Improvement in the technology of disposal and storage
of hazardous wastes should result in greater safety to a community and
would facilitate reclamation and recycling of waste products when such
becomes economically feasible.
\Nbhita -Sedg\\ibk ©unly Department of ©mmuni'1)/ Hzafth
19OO East Nrth StreefANcrtta, Knsas 67214 (316)268-8201
$3> )OO% recvcfed paper
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Mr. John P. Helman
Page Two
We understand that production of hazardous waste can be reduced
considerably through improved production technology, recycling and
improvements in reclamation of waste products.
We appreciate the opportunity to comment on this subject and offer our
advisory view for your consideration.
Barbara Keltner, Chairperson
Environmental Resource Advisory Board
BK:pp
CONCURRENCE BY
tor
partment of
Jarhes F. Aike*n, Jr. ,
Environmental: Health DJr
' Wichita-Sedgwick County'
ommunity Health
L i
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Wichita-Sedgwick County Environmental Resource Advisory Board
This Board was established through a Resolution of the governing
body of the City of Wichita, Kansas, the Board of County
Commissioners of Sedgwick County, Kansas, and the Wichita-
Sedgwick County Board of Health.
The purpose of the Board is to develop long-range community
objectives relating to the environment and to have the responsi-
bility on their initiative or at the request of one or more of the
appointing bodies or any city or county department for
investigating environmental concerns including but not limited
to water quality, air quality, solid waste, land use, open space,
noise and housing and providing recommendations relating thereto.
They also recommend projects and sources of funding for such
projects. Evaluate existing environmental efforts with recom-
mendations for change where appropriate. Provide public
information and education.
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Sox 234
Oakland, N. J. 07456
Mr* John Wnmon, Director
Hazardous "-aste t'i a nag errant Division.
Office of i>olici Waste Kanfis;«S!«nt Programs (AV.'-.5So)
Environmental Protection fg.ency
Washington, D. C. 20460
Dear Sir:
I hope th.it the dangers of nazardous wastes nave come through
loud p nd clear at the hearings held in December. The •* re fact
that the EPA has seen fit to single out certain wastes annearing
in the environment :mil to classify them as "Hazardous" should be
sufficient to place an immediate ban on their continued release
into the environment.
I appreciate the desire of the EPA to proceed in a democratic
fasr.lon, thus enabling all parties to come forth to slats/their
position; however, I believe the EPA should sat on an s-nergancy
basis in msny area?. For example, if » building is bur-ling, the
procedure is to extinguish the fire as quickly as possible in the
best interests of life snd property. In a sense, one could say
that emergency powers have bean granted for the purpose of fight-
ing fires. Y.'hy not to fight dangers to
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