REPORT TO CONGRESS
  DISPOSAL OF HAZARDOUS WASTES
          This publication (SW-115) was prepared
  by the OFFICE OF SOLID WASTE MANAGEMENT PROGRAMS
as required by Section 212 of The Solid Waste Disposal Act as amended
  and was delivered June 30, 1973, to the President and the Congress
        U.S. ENVIRONMENTAL PROTECTION AGENCY
                       1974

-------
                        An environmental protection publication
                      in the solid waste management series (SW-115)
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington, D.C. 20402 - Price $1.85

-------
                           FOREWORD
      Section 212 of  the Solid Waste Disposal  Act (P.L. 89-272) as amended
required that the U.S.  Environmental Protection  Agency (EPA) undertake a
comprehensive  investigation of the storage and disposal of hazardous wastes.
This  document  represents  EPA's Report to the  President and the Congress
summarizing the  Agency's investigations and  recommendations  in response to
the congressional mandate. The findings are based  on a number of contractual
efforts  and analyses  by Agency staff  carried out  since the passage  of the
Resource Recovery Act of 1970.
      The  report  is  organized  into  a summary,  five  major  sections,  and
appendixes. The  first  section discusses  the  congressional mandate and the
Agency's response to  it.  Next, the public health,  technological, and economic
aspects  of the problem of disposing of hazardous wastes are reviewed. A section
detailing the case for hazardous waste regulation follows. The  report concludes
with a discussion of implementation issues and a presentation of findings and
recommendations.
      Although  there  have  been minor editorial revisions, this publication is
essentially the same as that delivered on June 30, 1973, to Congress, except that
the references have been reverified and revised accordingly. Also, the report has
been typeset in a conventional style to improve its readability.
                                           -ARSEN J. DARNAY
                                            Deputy Assistant Administrator
                                              for Solid Waste Management
                                   in

-------

-------
                            CONTENTS
                                                                      PAGE

   Summary and Conclusions   	    ix

1. Introduction    	     1

         THE CONGRESSIONAL MANDATE    .                               1
         THE EPA RESPONSE  ...      ...            .  .        1
              First Study    .        ...        ....     1
              Second Study    .                   	       ,1
              Third Study                                      .    .        2
              Fourth Study      .        .    .       	     2
              Fifth Study         	        ....     2
              Strategy Analysis     .          .       .        .  .      .   .     2

2. Identification and Discussion of the Problem	     3

         THE NATURE OF HAZARDOUS WASTES	     3
              Toxic Chemical Wastes    	        4
              Biological Wastes     	     .    .    .        .  •        6
              Radioactive Wastes     ........                6
         FACTORS INFLUENCING THE GROWTH OF HAZARDOUS WASTES  .     7
         PUBLIC HEALTH AND ENVIRONMENTAL EFFECTS   .           .     7
         PRESENT TREATMENT AND DISPOSAL TECHNOLOGY  ...        8
              Public Use of Existing Technology      	       11
              Private Use of Existing Technology     .    .              .11
              The Hazardous Waste Processing Industry    .                 ,11
         ECONOMIC INCENTIVES    .           	11
         SUMMARY       .    .        .           	       .12

3. The Case for Hazardous Waste Regulations	    J5

         EXISTING  AUTHORITIES FOR HAZARDOUS V.'ASTE
            MANAGEMENT	      .        .     .    15
              Federal Control Statutes    .             .    .        ...    15
              State Control Statutes   .       ...      .    .      .   .    17
              Summary       .        .           .      .....       17
         PRECEDENTS FOR HAZARDOUS WASTE REGULATION  .  .    .   .    17
              The Clean Air Act    .      	      ...    18
              The Federal Water Pollution Control Act	         18
         CLOSING THE CIRCLE ON HAZARDOUS WASTES           .     .    20
              Persons and Activities Subject to Regulatory Controls  ...    20
              Types of Hazardous Waste Standards                    .     .    21
              Strategies for Hazardous Waste Regulation                .     .    21
         SUMMARY   .    .      	          ...         23

4. Issues of Implementation	    25

         HAZARDOUS WASTE MANAGEMENT SYSTEM  .        ...    25
              Costs	           ...      ...    26
              Variations      	    27
         COST DISTRIBUTION TO USERS      	       29
              Equity of Cost Distribution	      .     ,    29
              Analysis of Cost Impacts    	      .       30
              Benefit/Cost Analysis   ...          ...       30
         ROLE OF THE PRIVATE SECTOR                .      ....    30
              Capacity Creation  ...       .      .          .  .             31

-------
                      DISPOSAL OF HAZARDOUS WASTES
                                                                      PAGE
               Environmentally Sound Operation   	     33
               Reasonable User Charges   	     34
               Long-Term Care   	     34
         ROLE OF GOVERNMENT	     35
               Performance Bonding   	     35
               Financial Assistance	     36
               Economic Regulation   	     37
               Use of Federal or State Land   	     37
               Government Ownership and Operation of Facilities	     37
         SUMMARY	     38

5 .  Findings and Recommendations   	    39

         FINDINGS	     39
         RECOMMENDATIONS   	     40

    Appendix A -Impact of Improper Hazardous Waste Manage-

      ment on the Environment	    41

         WASTE DISCHARGE HAZARDS	     41
               Improper Arsenic Disposal   	     41
               Lead Waste Hazard   	     41
               Cyanide and Phenol Disposal   	     41
               Arsenic Contamination	     42
               Insecticide Dumping	     42
               Trace Phenol Discharge	     42
               Discharge of Hydrocarbon Gases Into River	     42
               Cyanide Discharge    	     42
               Arsenic Dump: Groundwater Contamination   	     42
               Poisoning of Local Water Supply	     43
         MISMANAGEMENT OF WASTE MATERIALS	     43
               Fish Kill    	     43
               Phosphate Slime Spill   	     43
               Mismanagement of  Heterogeneous Hazardous Waste    	     43
               Arsenic Waste Mishap   	     44
               Contaminated Grain	    	     44
               Radioactive Waste	     44
               Waste Stockpiling Hazard: Two Cases	     44
               Chlorine Holding Pond Breach	     44
               Malpractice Hazard   	    .  .     44
               Explosive Waste   	     44
               Unidentified Toxic Wastes   	     44
               Container Reclamation	     45
               Stockpiling of Hazardous Waste    	     45
               Pesticides in Abandoned Factory	     45
               Groundwater Contamination by Chromium- and Zinc-Containing
                  Sludge	     45
               Disposal of Chromium Ore Residues	     45
               Dumping of Cadmium-Containing Effluents Into the Hudson
                  River    	     45
               Pesticide Poisoning   	     45
               Improper Disposal of Aldrin-Treated Seed and Containers   ...     45
               Improper Pesticide Container Disposal	     46
               Ocean Dumping of Chemical Waste  	     46
         RADIOACTIVE WASTE DISPOSAL	     46
               National Reactor Testing Station	     46
               Decommissioning of AEC Plant    	     46
               Nuclear Waste Disposal	     46

    .Appendix B-Hazardous  Waste Stream Data	    47

    Appendix C-Decision Model for Screening and  Selecting

      Hazardous Compounds and Ranking Hazardous Wastes .  .    55

         DEFINITIONS OF ABBREVIATIONS USED IN THE SCREENING
            MODEL	     55

-------
                         CONTENTS                                        Vll

                                                          PAGE

     CRITERIA FOR SCREENING AND SELECTION	    56
     PRIORITY RANKING OF WASTES	    56

Appendix D-Summary of Hazardous Waste Treatment and

  Disposal Processes	   59

     PHYSICAL TREATMENT    	    60
     CHEMICAL TREATMENT    	    61
     THERMAL TREATMENT	    62
     BIOLOGICAL TREATMENT     -.  .    .  .     	         62
     ULTIMATE DISPOSAL      .     	    63

Appendix E-Decision Maps for On-Site Versus Off-Site

  Treatment and Disposal	   65

Appendix F -Summary of the Hazardous Waste National

  Disposal Site Concept	   71

     SITING OF HAZARDOUS WASTE TREATMENT AND DISPOSAL
       FACILITIES	    71
     HAZARDOUS WASTE MANAGEMENT METHODS AND COSTS   .      75
     DESCRIPTION OF MODEL FACILITIES   .              ....    76
          Hazardous Waste Processing Facility	    76
          Hazardous Waste Disposal Facility	    77
          Process Selection	      .    77
          Cost Estimates	    78

Appendix G-Proposed Hazardous Waste Management

  Act of 1973	   83

References	109

-------

-------
           SUMMARY AND CONCLUSIONS
      The management  of the Nation's  hazardous residues-toxic  chemical,
biological, radioactive, flammable, and explosive wastes-is generally inadequate;
numerous  case  studies  demonstrate  that  public  health  and   welfare  are
unnecessarily threatened by the uncontrolled discharge of such waste materials
into the environment.
      From  surveys conducted during  this program, it  is estimated  that  the
generation  of  nonradioactive hazardous wastes  is taking place at the rate of
approximately 10 million  tons yearly.1 About 40 percent of these wastes by
weight is inorganic material and about 60 percent is organic; about 90 percent
occurs in liquid or semiliquid form.
      Hazardous waste generation is  growing at a rate of 5 to 10  percent
annually as a result of  a number  of  factors, increasing  production  and
consumption rates,  bans  and  cancellations  of  toxic  substances, and energy
requirements (which lead to radioactive waste generation at higher rates).
      Hazardous waste disposal to  the land is increasing as  a  result of air and
water pollution controls (which capture hazardous wastes from other media and
transfer them  to land)  and denial  of heretofore  accepted methods of disposal
such as ocean dumping.2
      Current  expenditures by generators  for treatment and  disposal of such
wastes are low relative to what is required for adequate treatment and disposal.
Ocean dumping and  simple land disposal costs are on  the order of $3 per ton
whereas environmentally adequate  management  could  require as  much as $60
per ton if all costs are internalized.3
      Federal,  State, and  local legislation  and  regulations dealing  with  the
treatment and disposal of nonradioactive hazardous waste are generally spotty or
nonexistent. At the Federal level, the Clean Air Act; the Federal Water Pollution
Control Act; and the Marine Protection, Research, and Sanctuaries Act provide
control authority over the incineration, and water and ocean disposal of certain
hazardous wastes but not over the land  disposal of residues. Fourteen other
Federal  laws deal in a peripheral  manner with the management  of hazardous
wastes.  Approximately  25  States have  limited hazardous  waste regulatory
authority.
      Given  this permissive legislative climate, generators of  waste are under
little or  no pressure  to expend  resources for the  adequate management of their
hazardous wastes. There  is little  economic incentive  (e.g.,  the high costs of
adequate management compared with costs of current practice)  for generators to
dispose of wastes in adequate ways.
      Technology is  available to treat most hazardous waste streams by physical,
chemical, thermal, and biological methods, and for disposal of residues. Use of
such treatment and disposal processes is costly, ranging from a  low of $1.40 per

                                   ix

-------
                     DISPOSAL OF HAZARDOUS WASTES

ton for  carbon sorption,  $10  per  ton for  neutralization/precipitation, and
$13.60 per ton for chemical oxidation to $95 per ton for incineration.4 Several
unit processes  are usually required for complete  treatment and disposal of a
given waste stream.  Transfer and adaptation of existing technology to hazardous
waste management may  be necessary in  some cases.  Development of new
treatment and  disposal methods for some wastes (e.g., arsenic trioxide and
arsenites and arsenates of lead, sodium, zinc, and potassium) is required.5  In the
absence of treatment processes, interim storage of wastes on land is possible
using methods  that minimize hazard  to  the public and  the environment (e.g.,
secure storage and membrane landfills).
     A small private hazardous waste management industry has emerged in the
last decade, offering treatment and disposal services to generators. The industry
currently has capital investments of approximately $25 million and a capacity to
handle about 2.5 million  tons of hazardous materials yearly, or 25 percent of
capacity  required nationally. However,  the industry's current  throughput  of
hazardous waste is about  24 percent of installed capacity, or 6 percent of the
national total. The low level of utilization of this industry's services results from
the absence  of regulatory and economic incentives for  generators to manage
their hazardous wastes in an environmentally sound manner. This industry could
respond  over time  to provide needed capacity if  a   national program  for
hazardous waste management, with strong enforcement capabilities, was created.
This industry would, of course, be subject to regulation also.
     The chief programmatic requirement to bring about adequate management
of  hazardous wastes  is the creation  of demand and  adequate capacity for
treatment and  disposal of hazardous wastes.  A national policy on  hazardous
waste management  should take into consideration environmental  protection,
equitable cost distribution  among generators, and recovery of waste materials.
     A regulatory  approach is  best  for the  achievement of hazardous waste
management  objectives. Such an  approach ensures adequate protection of public
health and the environment. It will likely result in the  creation of treatment and
disposal capacity  by the private  sector without public funding. It will result in
the mandatory use of such facilities.  Costs of management will be  borne  by
those who generate the hazardous wastes and their customers rather than the
public  at  large,  thus, cost  distribution  will be  equitable.  Private   sector
management  of the wastes in a competitive situation can lead to an appropriate
mix of source reduction, treatment, resource recovery,  and land disposal.
     A  regulatory  program will not directly create a  prescribed  system  of
national  disposal  sites because of uncertainties inherent in the private  sector
response.  EPA believes that the private sector will  respond to a  regulatory
program. However,  full assurance cannot be  given that  treatment and disposal
facilities  will be available  in a timely manner for all regions of  the Nation nor
that facility use charges will be reasonable  in relation to cost of services. Also,
private  enterprise does not appear  well  suited  institutionally to  long-term
security and surveillance of hazardous waste storage and disposal sites.
     Given  analyses  performed to date,  EPA believes that no Government
actions to limit the uncertainties in private sector response are appropriate at
this time.  However,  if  private  capital  flow was  very  slow and adverse

-------
                       SUMMARY AND CONCLUSIONS                                     xi

environmental effects were resulting from the investment rate, indirect financial
assistance in forms such as loans, loan guarantees, or investment credits could be
used to accelerate investment. If facility location or user charge problems arose,
the Government could impose a franchise system with territorial limits and user
charge rate controls. Long-term care of hazardous waste storage and disposal
facilities could be assured by mandating use  of Federal or  State land for such
facilities.
      EPA studies indicate that treatment and disposal of hazardous wastes at
central  processing facilities  are  preferable to management at each  point of
generation, in  most cases, because  of economies  of scale, decreased environ-
mental risk, and  increased opportunities for resource recovery. However, other
forces may deter creation of the "regional processing facility" type of system.
For  example,  the pending effluent limitation guidelines now being developed
under authority  of  the Federal Water Pollution Control Act may force each
generator to install water treatment facilities for both hazardous and nonhazard-
ous  aqueous waste  streams.  Consequently, the absolute volume of hazardous
wastes requiring further treatment at central  facilities may  be reduced and the
potential for economies of scale at such facilities may not  be as strong as it is
currently.
      Given these uncertainties, several projections of future events can be made.
Processing  capacity  required  nationally  was estimated  assuming  complete
regulation, treatment,  and  disposal  of  all hazardous wastes at  the earliest
practicable time period. Estimates were based on a postulated scenario in which
approximately  20 regional  treatment and disposal  facilities  are  constructed
across  the Nation.  Of these,  5 would  be very large  facilities  serving major
industrial areas,  each treating  1.3  million tons  annually, and  15 would be
medium-size facilities, each treating  160,000  tons  annually. An  estimated 8.5
million tons of hazardous wastes would be treated and disposed  of away from
the point of generation  (off site);  1.5  million tons would  be  pretreated by
generators  on site,  with  0.5 million tons of residues transported to off-site
treatment and disposal facilities for further processing. Each regional processing
facility was assumed to provide a complete range of treatment processes capable
of handling all types of hazardous wastes; and, therefore, each would  be much
more costly than existing private facilities.
      Capital requirements to create the system  described are approximately
$940 million. Average annual operating expenditures (including capital recovery
and operating  costs) of $620 million would be required to sustain the program.
These costs are roughly estimated  to be equivalent  to 1 percent of the value of
shipments  from industries directly  impacted. In addition, administrative  ex-
penses of about $20 million annually for Federal and State regulatory programs
would be necessary.  For the reasons stated earlier, however, capacity and capital
requirements for a national hazardous waste management system may be smaller
than indicated, and more  in line with the capacity and capital availability of the
existing hazardous waste management industry.
      In  summary, the conclusions of the study are that (1) a hazardous waste
management problem exists and its  magnitude is increasing;  (2) the technical
means to solve the problem  exist for most hazardous waste  but are  costly in

-------
xii                                  DISPOSAL OF HAZARDOUS WASTES
               comparison with present practices; (3) the  legislative and economic incentives
               for using  available  technology are not  sufficient  to  cause environmentally
               adequate treatment and disposal in most cases; (4) the most effective solution at
               least direct cost to the public is a program for the regulation of hazardous waste
               treatment  and disposal; (5) a private hazardous  waste management service
               industry exists and is capable of expanding under the stimulus of a  regulatory
               program; (6) because of inherent uncertainties, private sector response cannot be
               definitely  prescribed;  (7)  several  alternatives  for Government  action  are
               available, but, based on analyses to date, EPA is not convinced that such actions
               are needed.
                     EPA  has proposed legislation to the  Congress that is intended both to
               fulfill the purposes of Section 212 of the Solid Waste Disposal Act as amended
               and to carry out the recommendations of this report. The proposed Hazardous
               Waste  Management  Act of  1973 would authorize a regulatory program for
               treatment  and disposal  of  EPA-designated hazardous wastes; the States would
               implement the program subject to Federal standards in most cases. All studies
               performed  in response  to  Section 212 will  be  completed in time to serve as
               useful input to congressional consideration of our legislative proposal.

-------
                      DISPOSAL OF HAZARDOUS WASTES
                                            Section  1
       THE CONGRESSIONAL MANDATE
   In  1970,  Congress  perceived  hazardous  waste
storage and  disposal  to  be a problem of national
concern. Section 212  of the Resource Recovery Act
of  1970  (P.L.  91-512-an amendment  to  P.L.
89-272), enacted on October 26, 1970, required that
EPA prepare a comprehensive report to Congress on
storage  and  disposal  of hazardous wastes. That
section stated the following:
The Secretary [*J shall submit to the Congress no later than
two years [t] after the date of enactment of the Resource
Recovery  Act of 1970 a comprehensive report and plan for
the creation of a system of national disposal sites for the
storage and disposal of hazardous wastes, including radio-
active,  toxic  chemical, biological, and  other wastes which
may  endanger public health or  welfare. Such report shall
include: (1) a list of materials which should be subject to
disposal at any such site; (2) current methods of disposal of
such materials; (3) recommended methods  of reduction,
neutralization, recovery or disposal of such materials; (4) an
inventory of possible sites including existing  land  or water
disposal sites operated or licensed by Federal agencies; (5) an
estimate of the  cost of developing  and maintaining sites
including  consideration of means for distributing the short-
and long-term  costs of operating such sites among the users
thereof; and  (6)  such  other  information as  may  be
appropriate.

              THE EPA RESPONSE
   This document  represents EPA's Report  to the
President and the Congress summarizing the Agency's
investigations  and   recommendations  concerning
hazardous  wastes in response to  the  congressional
mandate. All information required by the mandate is
included in the report and its appendixes. This report
provides  a definition  of  current status, issues, and
options.  It does not purport to provide a complete
      *The Secretary  of Health, Education, and Welfare.
Reorganization Plan Number 3 of 1970 transferred authority
to the Administrator, EPA.
      ^EPA requested and received a time extension for
submission of this  report  until  June 30,  1973, because
appropriation of funds to implement the Resource Recovery
Act of 1970 was delayed for 8 months after enactment.
solution  to the hazardous waste management prob-
lem.
   Section 212 requires an evaluation of a system of
national  disposal sites (NDS's) for the storage and
disposal  of hazardous  wastes as a solution  to  the
hazardous  waste  problem.  To  evaluate  the NDS
concept  properly, it  is necessary  to view it in  the
context  of  the total problem.  On  probing  the
problem,  EPA  determined  that  several  means  of
accomplishing the NDS objective  exist. To provide
the Congress  with maximum flexibility  of  action,
EPA  elected  to  investigate  and  evaluate  several
alternative solutions. A series of interrelated contrac-
tor and  in-house studies was undertaken  for  the
specific purpose of complying with Section  212 of
the Resource Recovery Act of 1970,
                   First Study
   The  first  study, upon which subsequent  efforts
were  based,  quantified  the  hazardous waste prob-
lem.6 From a thorough literature survey and contacts
with various trade and technical associations, Govern-
ment agencies,  and  industry, a list   of  hazardous
materials was compiled, and each  candidate substance
on this list was rated  according  to the nature and
severity  of its  hazardous  properties.  In addition,
volume and distribution data (both by geography and
by industry   groups)  were   gathered,  and  current
hazardous waste handling and disposal practices were
surveyed. It  was found that the magnitude  of  the
hazardous  waste problem was larger than originally
anticipated and  that current  disposal  practices  are
generally inadequate.
                  Second Study
   Next,  a more detailed  technical study  on  the
properties of these materials and  their  treatment and
disposal methods was conducted.7 A "profile report"
was written on each listed substance summarizing  its

-------
                                    DISPOSAL OF HAZARDOUS WASTES
physical, chemical, and  toxicological properties; its
industrial  uses; and  the  hazards  associated with
proper handling and disposal methods.  Each  profile
report incorporated a critical evaluation of currently
used  and  available technology  for the  handling,
storage, transport, neutralization,  detoxification, re-
use,  and disposal  of the particular  substance. Also,
advanced methods of hazardous waste treatment were
surveyed, and research and development needs were
formulated.  The  study showed that treatment and
disposal technology is available for most hazardous
wastes.
                   Third Study
   A  favorable public attitude is essential  for the
successful implementation of any nationwide hazard-
ous waste management program.  Therefore, a third
study was undertaken to determine citizen awareness
and attitudes regarding the hazardous waste problem
and reaction to the possibility of having a treatment
and  disposal facility located in the vicinity.8 The
majority of  citizens sampled were  found to  be  in
favor of regional  processing facilities for hazardous
wastes since such facilities would increase environ-
mental protection and  stimulate the economy of the
region.
                   Fourth  Study
   A fourth study analyzed and compared alternative
methods of hazardous waste  management.9  It was
concluded that there are three basic approaches: (1)
process hazardous wastes "on site" (i.e., at the plant
where  they are generated); (2) process "off site" at
some regional facility  (either  public or private); (3)
combine on-site pretreatment  with off-site treatment
and  disposal. These basic alternatives were evaluated
with  respect  to  economics,  risk,  and  legal and
institutional issues. The  study indicated that option
(2) is  preferable  for  most hazardous waste streams
and  option (3) is preferable for dilute aqueous toxic
metal wastes.*
                   Fifth Study
   A fifth comprehensive study examined the feasibil-
ity  of an  NDS  system  for hazardous  wastes.' °
Potential  locations for regional processing and dis-
posal sites were  identified. Conceptual  designs of
hazardous waste treatment and disposal facilities were
developed, based on multicomponent waste streams
characteristic  of  industry.  Capital and operational
cost estimates were  made, and funding and cost
distribution mechanisms were examined.

                 Strategy Analysis
   Lastly, a strategy analysis was performed, based on
information from the previous  studies. It  was con-
cluded that a regulatory program is the best approach
to  the  hazardous waste  problem.   The  case  for
hazardous waste regulation is  discussed in Section 3.
Issues  of implementation are evaluated in Section 4,
and  findings  and recommendations are  given in
Section 5. A review of the hazardous waste disposal
problem precedes these discussions.
                                                              *In this report the term "waste stream" refers to mass
                                                         flow in the engineering process sense and not necessarily to a
                                                         liquid stream.

-------
                                          Section  2
       IDENTIFICATION AND DISCUSSION OF THE PROBLEM
   Inadequate management of hazardous wastes has
the potential of causing  adverse public  health and
environmental  impacts. These  impacts are  directly
attributable to the acute  (short-range or  immediate)
or  chronic (long-range)  effects  of the  associated
hazardous compound or combination of compounds,
and production quantities  and distribution.11'12
Many cases document  the imminent and long-term
danger to man or his  environment from improper
disposal of such hazardous wastes. Three examples
follow.
   Several people in Minnesota were hospitalized in
1972 after drinking well  water contaminated by an
arsenic waste buried 30 years ago on nearby agricul-
tural land.
   Since 1953, an Iowa company has dumped several
thousand cubic yards of arsenic-bearing wastes on a
site located above an aquifer supplying a city's water.
Arsenic  content in nearby monitoring well  samples
has been measured as high as 175 parts per  million;
the U.S.  Public Health  Service drinking water stand-
ards recommend an arsenic  content  less than  0.05
part per million.
   In Colorado, a number  of farm cattle recently died
of cyanide poisoning caused by indiscriminate dis-
posal of  cyanide-bearing wastes  at a  dump site
upstream.  Additional case studies citing the effects of
hazardous waste mismanagement are given in Appen-
dix A.
   Discussed in this  section are the types,  forms,
sources,  and  quantities  of hazardous  waste;  the
current status of treatment and disposal technology;
and the economic  incentives bearing on hazardous
waste treatment and disposal.

    THE NATURE OF  HAZARDOUS WASTES
   The term "hazardous waste"  means any waste or
combination  of wastes  which  pose a  substantial
present or potential hazard to human health or living
organisms because such wastes are lethal, nondegrada-
ble,  or  persistent  in nature; may  be biologically
magnified; or may  otherwise cause or tend to cause
detrimental cumulative effects.13 General categories
of hazardous waste are  toxic chemical, flammable,
radioactive, explosive, and biological. These  wastes
can take the form of solids, sludges, liquids, or gases.
   The sources of hazardous wastes are numerous and
widely scattered  throughout the Nation. Sources
consist of industry, the Federal Government [mainly
the  Atomic  Energy  Commission  (AEC)  and the
Department  of  Defense  (DOD)],  agriculture, and
various institutions such as hospitals and laboratories.
   During this  study,  waste  streams  containing
hazardous compounds were identified and quantified
by  industrial  source  (Appendix  B).  These  waste
streams were selected by utilizing a decision model
(Appendix C)  that is relatively unsophisticated com-
pared  to  that  required for  standard-setting  pur-
poses.14  Therefore, the  hazardous compounds and
waste streams  cited in this report should be consid-
ered as illustrative and are not necessarily those that
should be  regulated.  From  these  data, the total
quantity of nonradioactive hazardous waste streams
generated by industrial sources in 1970 was estimated
to be  10 million tons (9 million metric tons),  or
approximately 10 percent of the 110  million tons
(100 million metric tons) of all wastes generated by
industry  annually.15   This  quantity includes most
industrial wastes generated from contractor-operated
Government facilities.
   Approximately 70 percent of industrial hazardous
wastes are generated in the mid-Atlantic, Great Lakes,
and Gulf Coast areas  of the United States (Table 1).
About 90 percent by weight of industrial hazardous
wastes are generated in the form of liquid streams,  of
which approximately 40 percent are inorganic and 60

-------
                                     DISPOSAL OF HAZARDOUS WASTES

                                                 TABLE 1
       ESTIMATED INDUSTRIAL HAZARDOUS WASTE GENERATION BY REGION* IN TONS PER YEAR (1970)'1'

Region
New England
Mid Atlantic
East North Central
West North Central
South Atlantic
East South Central
West South Central
West (Pacific)
Mountain
Totals
Inorganics in aqueous
Tons
95,000
1,000,000
1,300,000
65,000
230,000
90,000
320,000
120,000
125,000
3.345,000
Metric tons
86,000
907,200
1,180,000
59,000
208,500
81,700
290,000
109,000
113,500
3,034,900
Organics
Tons
170,000
1,100,000
850,000
260,000
600,000
385,000
1,450,000
550,000
5,000
5,370,000
in aqueous
Metric tons
154,000
1,000,000
770,000
236,000
545,000
350,000
1,315,000
500,000
4,540
4,874,540
Organics
Tons
33,000
105,000
145,000
49,500
75,000
44,000
180,000
113,000
50,000
794,500
Metric tons
30,000
90,600
132,000
45,000
68,000
40,000
163,000
103,000
45,400
717,000
Sludges,! slurries, solids
Tons
6,000
55,000
90,000
18,500
80,000
9,500
39,000
30,500
11,500
340,000
Metric tons
5,450
50,000
81,600
16,800
72,600
8,600
35,400
27,770
10,400
308,620
Total
Tons
304,000
2,260,000
2,385,000
393,000
985,000
528,000
1,989,000
813,500
191,500
9,849,500
Metric tons
275,450
2,047,800
2,163,600
350,800
894,100
480,300
1,803,400
739,770
173,840
8,929,060
Percent
of total
3 1
229
24.2
4.0
100
54
202
8 3
1 9
100 0
    ^Refers to Bureau of Census regions, as defined m Appendix B
    'Source  EPA Contract No 68-01-0762.
    1-Predominantly inorganic.
percent are organic materials. Representative hazard-
ous  waste substances have  been cross indexed by
industrial  sources  (Table  2).  It  is  important  to
recognize that these hazardous substances are constit-
uents of waste streams, and it is these waste streams
which require treatment, storage, and disposal.
   Sources of radioactive  wastes are nuclear power
generation  and fuel  reprocessing  facilities; private
sources,  such as medical, research and  development,
and  industrial laboratories; and Government sources
(AEC  and  DOD).  Quantities of radioactive wastes
generated in 1970 from the  first two  sources were
identified  (Table  3). Only  a  limited amount  of
information  is  available on  source material, special
nuclear  material,  or   byproduct  materials  from
Government operations. Such information is related
to weapons production and is therefore classified.
   Disposal of  uranium  mill tailings  represents  a
unique problem similar in magnitude to the  disposal
of all  industrial hazardous  wastes. Several  Federal
agencies  are working on the problem  at present; a
satisfactory disposal or recovery method has not yet
been defined. Aside from uranium mill tailings,  the
quantity  of radioactive wastes associated with  the
commercial nuclear electric power industry and other
private  sources is estimated to  be approximately
24,000 tons (22,000 metric tons) per year at  present,
or less than 1  percent of the total hazardous wastes
from all industry.
              Toxic Chemical Wastes
   Practically all of the estimated 10  million tons (9
million  metric  tons)  of  nonradioactive hazardous
waste generated annually .in  the United  States falls
into the toxic category. In the context of this report
toxicity is defined as the ability of a waste to produce
injury  upon  contact  with  or  accumulation  in  a
susceptible site in or on the body of a living organism.
Most toxic wastes  belong to one or more of four
categories: inorganic  toxic  metals, salts,  acids,  or
bases; synthetic  organics; flammables; and explosives.
There  is  considerable  overlap  within  these waste
categories. For  example,  a synthetic organic waste
may be flammable and  explosive, and it  may also
contain toxic metals. Flammable and explosive wastes
are  often  categorized as  separate hazardous waste
entities; however, they are generally toxic and will be
discussed here. Many radioactive and some biological
wastes are also toxic,  but  they will be  discussed
separately.
   Toxic Metals. Approximately 25 percent of the
metals in  common usage today are toxic.'2  The
concentration and  chemical  form of toxic  metals
determine  their potential  health  and  environmental
hazards.  Some  metals are essential  to life  at low
concentrations but are  toxic at higher concentra-
tions.12'16  Also,  a  pure metal is  usually  not  as
dangerous  as a metallic  compound (salt).'2  The
largest quantities of  toxic metal waste streams are
produced   by the  mining and metallurgy and the
electroplating  and  metal-finishing industries.  For
example, arsenic-containing flue dusts collected from
the smelting of  copper, lead, zinc, and other arsenic-
bearing ores  amount  to  40,000  tons (36,200 metric
tons) per year.  Approximately  30,000 tons (27,200
metric tons) of  chromium-bearing waste is discharged
by the metal-finishing industry annually.

-------
                             IDENTIFICATION AND DISCUSSION OF THE PROBLEM

                                                  TABLE 2
               REPRESENTATIVE HAZARDOUS SUBSTANCES WITHIN INDUSTRIAL WASTE STREAM
Hazardous substances
IndUStry « ™ Chlorinated . Miscellaneous
As Cd hydrocarbons* Cr Cu Cyamdes Pb H9 organicst Se z«
Mining and metallurgy V V
Paint and dye \/
Pesticide v'
Electrical and electronic
Printing and duplicating \/
Electroplating and
metal finishing v'
Chemical manufacturing
Explosives \/
Rubber and plastics
Battery V
Pharmaceutical v'
Textile
Petroleum and coal \/
Pulp and paper
Leather
V V V V V
V V \' V V
V v' V V
V V \f \' V
N/ V

V N/ V
\/ \/ V N/
V V V
V V V
v V
N/
v' V
V V
V
V

V
V

V


V
V
V

V
V

V
V
V V
V
V
V


V


V
V





      * Including polychlorinated biphenyls.
      ' For example, acrolein, chloropicrin, dimethyl sulfate, dinitrobenzene, dinitrophenol, nitroaniline, and pentachlorophenol.
                                                  TABLE 3
                            ESTIMATE OF RADIOACTIVE WASTE GENERATED IN 1970*
Waste stream source
Mineral extraction'''
(uranium)
Commercial nuclear
electric power
Form
Sludge
Solid or liquid
Total annual curies
9.0 X 101
4.0 X 107
Tons per year
4,400,000
2,240
Metric tons per year
4,000,000
2,000
Major radioactive
elements
Ra, Th, Pb, Po
U, Th, Ra, Pu, Ag,
Fe, H, Mn, Ni, Co,
Miscellaneous private    Solid or liquid    2.0 X lO''
   sources
Government sources    Solid or liquid    Not available
                                   11,000-22,000   10,000-20,000

                                   Not available     Not available
                       Ru, Cs, Ce, Sr, Sb,
                       Pm, Eu, Am, Cm
                    Co, Sr, Pm, Cs, Pu,
                       Am, Cm
                    Pu, Am, Cm
All known somces
Sludges, solids,    >4.0 X 10"
   or liquids
                                                        >4,413,240
>4,012,000
      *Source. EPA Contract No. 68-01-0762.
      ''Uranium mill tailings from extraction of uranium ores.
   Synthetic Organics.  Hazardous synthetic organic
compounds include halogenated  hydrocarbon pesti-
cides (such as endrin), polychlonnated biphenyls, and
phenols. An estimated 5,000 tons (4,540 metric tons)
of synthetic  organic  pesticide wastes were produced
in 1970.'7 DOD currently has 850 tons (770 metric
tons)  of dry  pesticides and 15,000 tons  (13,600
metric tons) in liquid form requiring disposal. Most of
the liquid form consists of agent  orange herbicide (a
mixture  of 2,4-D and 2,4,5-T) banned  from use in
                                    South Vietnam.'s  These stocks contain  significant
                                    quantities of a teratogenic dioxin. There are disposal
                                    requirements caused  by  the  increasing numbers  of
                                    waste pesticide containers as  well. Over 250 million
                                    pesticide containers of all types will be used this year
                                    alone.19
                                       Flammables.  Flammable wastes consist  mainly of
                                    contaminated organic solvents but may include oils,
                                    pesticides, plasticizers, complex organic sludges, and
                                    off-specification chemicals. Highly  flammable wastes

-------
                                     DISPOSAL OF HAZARDOUS WASTES
can pose acute handling and chronic disposal hazards.
Hazards  related  to  disposal  may  exceed  those  of
transportation   and  handling  if  sufficient  waste
volumes  are involved. The nationwide quantities of
flammable wastes have not been assessed as a separate
category  but are included in the totals given pre-
viously.
   Explosives.  Explosive wastes are mainly obsolete
ordnance, manufacturing wastes from the explosives
industry,  and  contaminated industrial  gases. The
largest amount of explosive  waste is  generated  by
DOD. An inventory by the DOD Joint Commanders'
Panel on  Disposal Ashore indicates that the military
has accumulated about 150,000  tons (136,080 metric
tons) of obsolete conventional ammunition.20 The
former  practice  of  loading  obsolete  munitions  on
ships and  sinking  them in the  ocean has  been
discontinued. Final disposal is being delayed until a
more suitable  disposal method is  available. A joint
Army, Navy, National Aeronautics  and Space Admin-
istration,  and Air Force group  is working to resolve
this  impasse. Most waste materials generated by the
c6mmercial explosives industry  consist of chemical
wastes that  are  not clearly separable from wastes
produced by large  industrial chemical  firms  (e.g.,
ammonia,  nitric  acid, sulfuric acid, and some com-
mon  organic chemicals).  These wastes  represent a
greater  problem  than  military wastes  because  of
uncontrolled  disposal practices.  Open  burning  of
explosives, which is widely practiced, can result in the
emission of harmful nitrogen oxides and other pollut-
ants.
                Radioactive Wastes
   Most  radioactive  wastes consist of conventional
nonradioactive  materials  contaminated with  radio-
nuclides.2 ' The concentration of the latter can range
from a few parts per billion to as high as 50 percent
of the total waste. Frequently, many radionuclides
are involved  in any given  waste. Radioactive wastes
are customarily  categorized  as low-  or high-level
wastes, depending upon  the concentrations of radio-
nuclides. However, the long-term  hazard associated
with each waste is not necessarily proportional to the
nominal  level  of radioactivity, but  rather to the
specific toxicity and decay rate  of each radionuclide.
The  most  significant radionuclides, from the stand-
point of waste management, decay with half-lives of
months  to hundreds of thousands  of  years. For the
purposes of this study, the term "high-level wastes"
refers to those wastes requiring special provisions for
dissipation of  heat produced by  radioactive decay,
"low-level wastes" refers to all others.
   The  biological  hazard  from radioactive  wastes  is
primarily  due  to  the  effects  of  penetrating and
ionizing radiation rather  than to  chemical toxicity.
On a weight  basis,  the hazard from certain  radio-
nuclides is more acute than the most toxic chemicals
by about  six orders of magnitude. The hazard from
radionuclides  cannot  be  neutralized  by  chemical
reaction  or  by any  currently  practicable  scheme.
Thus, the only currently  practical way  to  "neutral-
ize"  a radionuclide is  to  allow its decay. Storage of
wastes containing  radionuclides under carefully con-
trolled conditions to assure their  containment and
isolation is necessary during this decay  period. The
time period necessary  for decay  of radionuclides to
levels acceptable for release to the environment varies
with each  waste.
   Radionuclides  may  be  present  in  gaseous, liquid,
or solid form.  Solid wastes per se are not  normally
important as  potential contaminants in the biosphere
until they become airborne (usually as particulates)
or waterborne  (by leaching). Consequently, environ-
mental effects and existing regulatory limits  are based
primarily on concentrations in air and water.

                 Biological Wastes
   Biological wastes were  divided into two categories
for  this  study:   pathological hospital  wastes  and
warfare agents. Pathological wastes from hospitals are
usually  less infectious than  biological warfare agents.
Both types of wastes may also be toxic. For example,
toxins produced by various strains of micro-organisms
may be just as hazardous  as the associated infectivity
of the organism.
   Pathological   Hospital   Wastes.  Approximately
170,000  tons  (154,000 metric tons) of pathologic
wastes are generated  by hospitals annually, which  is
approximately 4 percent of the total 4.2 million tons
(3.7  million  metric  tons)  of all  hospital  wastes
generated per year.22'23  These wastes include malig-
nant or benign tissues taken  during autopsies, biop-
sies,   or surgical   procedures;  animal carcasses  and
wastes;  hypodermic needles; off-specification or out-
dated drugs, microbiological  wastes; and bandaging
materials.

-------
                             IDENTIFICATION AND DISCUSSION OF THE PROBLEM
   Biological  Warfare  Agents.  Biological  warfare
 agents are selected primarily because of their abilities
 to  penetrate  outer  epithelial tissues  of  plants  or
 animals and to spread rapidly. Antipersonnel agents
 like Bacillus anthrax  are cultured to affect a specific
 animal; anticrop agents  like Puccinia graminis  (Lx)
 (rice blast) are used to  inhibit growth  of specific
 plants. DOD representatives have advised EPA that all
 stockpiles of  biological  warfare agents,  including
 antipersonnel   and   anticrop   agents,  have   been
 destroyed.24 Because of the Administration's policy
 of restricting production of biological warfare agents,
 the- total  quantity to be disposed of should be small
 in the future.
   Chemical Warfare Agents. Production of chemical
 warfare agents such as HD (mustard), GB, and VX has
 been discontinued, but significant stockpiles of these
 agents  must  be  treated  and  disposed  of in  an
 environmentally acceptable  manner. The Department
 of the Army is in the process of demilitarizing HD
 (mustard) at Rocky  Mountain  Arsenal in Colorado
 and is presently studying the feasibility of demilitariz-
 ing GB and VX by means of incineration.  The exact
 quantity  of  chemical  agents  to be  incinerated is
 classified, but  it has been  estimated  that after the
 treatment process there will be approximately 70,000
 tons  (63,600 metric  tons) of residual salts that will
 require proper disposal.

   FACTORS INFLUENCING THE GROWTH OF
             HAZARDOUS WASTES
   A  number of factors will increase the quantities of
hazardous wastes  generated in  the future  and will
affect their disposal  requirements. Some of  these
factors are production and consumption rates, legisla-
tive and regulatory actions, energy requirements, and
recycling incentives.
   National  production and consumption rates are
increasing 4 to 6 percent each year,  while resource
recovery from wastes is declining. During  the period
1948 to  1968, U.S.  consumption of selected  toxic
metals increased 43 percent.2S Since 1954, produc-
tion of synthetic organic chemicals has increased at
an average rate  of  10.5 percent per year.26 Included
in the latter category are  such materials as dyes,
pigments,  and  pesticides. Some of these products
contain heavy metals in addition to organic  constit-
uents. Similar data indicating production growth can
be cited for most industries that generate hazardous
waste.  There is a correlation between the amount of
production and waste generated. Therefore,  it can be
concluded that hazardous waste generation rates will
generally parallel industrial production rates.
   Changing product material content  also has an
impact. For example, increasing polyvinyl  chloride
plastics usage results in more mercury-bearing wastes
from the chlorine production industry;  in the com-
puter industry, changeover from vacuum tube tech-
nology  to  integrated circuit  board technology  has
resulted  in increased generation  of  acid   etchant
wastes  containing heavy metals.
   The  Nation's  projected energy  requirements  are
driving  utilities  toward  construction   of  nuclear-
powered facilities. As of September 1972, there were
28 nuclear power plants in operation; 52 were being
built, and 70 more  were being planned. Operation of
the  additional   122  nuclear  power   plants  will
definitely  increase  the   quantities of  radioactive
wastes.27  Shortages of clean-burning high-grade coal
have initiated a trend to utilize lower grades of coal,
which contain larger amounts of arsenic and mercury;
therefore, aqueous wastes from the scrubbers and
ashes from coal-burning  furnaces will  contain  in-
creased quantities of toxic wastes.
   Enforcement of new consumer and occupational
safety  legislation  could result  in  product bans, with
attendant disposal  requirements. More stringent air
and water effluent  controls, new pesticide  controls,
and the new restrictions on ocean dumping of wastes
will result in larger  quantities  of hazardous wastes in
more concentrated form  requiring disposal. As  air,
water,  and  ocean  disposal  options are closed off,
there will be increased pressure for improvements ii)
production efficiency, for recovery and  recycling of
hazardous substances, and for disposal of hazardous
wastes  on or under the land.

    PUBLIC HEALTH AND ENVIRONMENTAL
                    EFFECTS
   In order for an organic or inorganic hazardous
compound  within a waste to affect public health and
the environment,  it  must be present  in a certain
concentration  and  form.  Public health and  environ-
mental  effects  are  directly correlated with  the con-
centration and  duration of exposure.12'28  This has
been better documented  for  acute effects  resulting

-------
                                    DISPOSAL OF HAZARDOUS WASTES
from high concentrations over a short period of time
than for chronic effects resulting from low concentra-
tions over a long period of time.29 Most of the work
to establish chronic  effects has been done on lower
animals,  and extrapolating  the  evidence directly to
man  becomes  difficult  because  of species  varia-
tions.29
   Synergistic or antagonistic  interactions  between
hazardous compounds and other constituents within
the waste can enhance or modify the overall effects
of the particular  hazardous compound.  As an  exam-
ple, the effects of mercury salts with trace amounts
of  copper  will   be  considerably  accentuated in  a
suitable environment.
   The form of a hazardous waste is also very critical
because it determines if a toxic substance is releasable
to  the  ambient  environment.  As  an  example,  an
insoluble salt of a  toxic  metal bound  up within a
sludge mass that is to be disposed of at a landfill does
not present the  same degree of immediate threat to
public health and the environment as a soluble salt of
the same  metal  that is unbound going  to the same
landfill. The interaction  between biological systems
and hazardous wastes is unpredictable,  and in many
cases the end product is more lethal than the original
waste.  An  example  is the  conversion  of inorganic
mercury by anaerobic bacteria into methyl mercury.
Furthermore, persistent toxic substances can accumu-
late within  tissues of mammals as do certain  radio-
isotopes. Under  these circumstances, substances that
are persistent  in the  ambient environment  even
though in low concentrations will be magnified in the
living system. As  a result, critical concentrations may
accumulate in tissues and cause detectable physiologi-
cal effects.                                 r
   Cancers and birth defects are only a few of the
recorded physiologic  effects that have been correlated
with the presence of hazardous compounds in man.
Other milder effects  have also been recorded, such as
headaches,  nausea, and indigestion.  In  the  environ-
ment, the effects of  hazardous wastes are manifested
by such things as fishkills, reduced shellfish produc-
tion, or improper eggshell synthesis.30
   This  evidence  points to  the fact that hazardous
wastes  are  detrimental  to public   health and  the
environment. The real issue, therefore, is to  docu-
ment the fact that present management  practices for
treating, storing, or disposing of hazardous wastes do
not provide the necessary  reassurances that man or
the environment are being adequately protected.
     PRESENT TREATMENT AND DISPOSAL
                 TECHNOLOGY
   Treatment processes for hazardous  waste streams
should  perform  the  following  functions: volume
reduction  where  required, component separation,
detoxification, and material recovery. No single proc-
ess can perform all these functions; several different
processes  linked in series are  required for adequate
treatment. Residues  from these  processes,   or  all
hazardous  wastes  if treatment is  bypassed, require
ultimate disposal.
   Treatment and  disposal  technology  is available to
process most hazardous waste streams.  A range of
treatment  and  disposal processes  was examined
during  the  course of  this study  and  the general
applicability of these processes to types and forms of
hazardous  wastes  is  indicated (Table 4).  Many of
these   processes have  been utilized previously for
managing hazardous wastes in industry and Govern-
ment. Several processes have capabilities for resource
recovery.  Selection of appropriate methods depends
on the type, form, and volume of waste, the type of
process required to achieve  adequate  control,  and
relative economics  of processes.
   Several  treatment  processes perform more than
one function or are applicable to more  than one type
or form of waste. For example, evaporation provides
both volume reduction and component  separation for
inorganic  liquids.   Carbon  sorption  and  filtration
provide component  separation for both liquids and
gases  and are applicable to a  wide range of hetero-
geneous  waste  streams. Both carbon  sorption  and
evaporation are capable of large  throughput rates.
Neutralization,  reduction, and  precipitation are effec-
tive for separation of most heavy metals.3'>3 2
   Certain weaknesses are inherent in some treatment
processes. For example, the five biological treatment
processes  are inefficient when waste  streams are
highly variable  in  composition and concentration or
when solutions  contain more than  1  to 5 percent
salts.33 Furthermore, biological  treatment processes
require larger land areas for facilities than the other
physical or chemical  processes.  The  efficiency of
removal  of hazardous liquids and gases from waste
streams by carbon sorption is  strongly  dependent on
pH. Similarly, the four dissolved solid  removal proc-

-------
                              IDENTIFICATION AND DISCUSSION OF THE PROBLEM

                                                  TABLE 4
             CURRENTLY AVAILABLE HAZARDOUS WASTE TREATMENT AND DISPOSAL PROCESSES*
Process
Physical treatment
Carbon sorption
Dialysis
Electrodialysis
Evaporation
Filtration
Flocculation/settling
Reverse osmosis
Ammonia stripping
Chemical treatment
Calcination
Ion exchange
Neutralization
Oxidation
Precipitation
Reduction
Thermal treatment
Pyrolysis
Incineration
Biological treatment.
Activated sludges
Aerated lagoons
Waste stabilization ponds
Trickling filters
Disposal/storage
Deep-well injection
Detonation
Engineered storage
Land burial
Ocean dumping
Functions
performed"'

VR
VR
VR
VR
VR
VR
VR
VR

VR
VR
De
De
VR
De

VR
De,

De
De
De
De

Di
Di
St
Di
Di

, Se
, Se
, Se
, Se
, Se
, Se
, Se
, Se


, Se, De


, Se


, De
Di











Types

1,
1,
1,
1,
1,
1,
1,
1,

1,
1,
1,
1,
1,
1,

3,
3,

3
3
3
3

1,
6,
1,
1,
1,

3,
2,
2,
2,
2,
2,
2,
2,

2,
2,
2,
2,
2,
2

4,
5,






2,
8
2,
2,
2,

4,
3,
3,
5
3,
3,
4,
3,

5
3,
3,
3,
3,


6
6,






3,

3,
3,
3,
of waste J

5
4
4,6

4, 5
4, 5
6
4


4,5
4
4
4, 5



7,8






4,6,7

4, 5.6,7,8
4,5,6,7,8
4, 7, 8
Forms
of waste ^

L, G
L
L
L
L,G
L
L
L

L
L
L
L
L
L

S, L, G
S, L, G

L
L
L
L

L
S, L, G
S, L, G
S, L
S, L,G
Resource
recovery
capability

Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes


Yes
Yes

Yes


Yes
Yes

No
No
No
No

No
No
No
No
No
      •'-Sources. EPA Contract Nos. 68-03-0089, 68-01-0762, and 68-01-0556.
      1 Functions  VR, volume reduction; Se, separation; De, detoxification; Di, disposal, and St, storage.
      'Waste types  1, inorganic chemical without heavy metals; 2,  inorganic chemical with heavy metals; 3, organic chemical
without heavy metals, 4, organic chemical with heavy metals; 5, radiological; 6, biological; 7, flammable; and 8, explosive
      S Waste forms' S, solid, L. liquid; and G, gas
esses  (ion  exchange,  reverse  osmosis,  dialysis,  and
electrodialysis) are all subject to operational problems
when utilized for treating heterogeneous brines.3 3
   Radioactive emissions and effluents from produc-
tion or reprocessing facilities are routinely controlled
by  a variety of tieatment  methods. High  efficiency
filters are  used  to remove radioactive particulates
from gaseous effluents, caustic scrubbers of charcoal
absorbers are used to remove radioactive gases. Liquid
effluents  containing small  quantities  of soluble or
insoluble radioactive constituents are usually  treated
with conventional water treatment techniques such as
ion exchange,  settling,  precipitation, filtration,  and
evaporation.'1 J
   CoTi'i'c  :,ly  used disposal processes for  hazardous
wastes include land buna!, deep-well  injection,  and
ocean  dumping. Detonation and open  burning are
sometimes used for disposal of explosives. Incinera-
tion is used for disposal of some organic  chemicals,
biologicals, and flammables.
   All  disposal  processes  have potential for adverse
public   health   and  environmental  effects  if  used
unwisely or  without appropriate controls. Land dis-
posal sometimes consists  of indiscriminate dumping
on  the land, with  attendant public  health problems
from animal vectors, water pollution from surface
water runoff and leaching to groundwaters; and air
pollution from open burning, windblown particulates,
and gas   venting.  Sanitary  landfills   are   much
preferable to dumps in  that daily earth cover mini-
mizes vector problems and open burning and panicu-
late transport.  Unless  specially  designed, however,

-------
10
                                     DISPOSAL OF HAZARDOUS WASTES
sanitary landfills still have potential for  surface and
groundwater pollution  and  air  pollution from gas
venting. Deep-well  injection  of liquid and semiliquid
wastes can pollute  groundwaters unless great care  is
taken in site selection and construction and operation
of such wells. EPA  policy opposes deep-well injection
unless all other alternatives have been found to be less
satisfactory in  terms of environmental protection and
unless extensive  hydraulic and geologic  studies are
made to ensure  that groundwater pollution will be
minimised.  Environmental problems associated with
ocean  dumping  have  long  been  recognized. The
                        Congress  recently passed legislation to control ocean
                        dumping  of wastes (Section 3).  Incineration,  open
                        burning, and detonation all can result in air pollution
                        unless adequate controls are employed. The residues
                        from  incineration,  and  from  associated  pollution
                        control devices, may require special care in  disposal.
                           Selection of appropriate treatment and disposal
                        methods for a given waste is a complex process. It is
                        simplistic to  assume that a treatment and disposal
                        process is applicable to all wastes of a given category.
                        For  example, available treatment and disposal proc-
                        esses  for  three  types  of heavy   metal hazardous
 CONCENTRATED
 HfcAVY METALS:
HPXAVALfcNT
CHROMIUM
- fc

HEAVY METAL
REDUCTION AND
PRECIPITATION
                                                          HEAVY METALSLUDGE
                                                           DISPOSAL POLYMER
                                                             ENCAPSULATION
                                                               AND BURIAL
 CADMIUM, ARSENIC,
   AND MERCURY
HEAVY METAL
   SULFIDE
PRECIPITATION
HEAVY METALSLUDGE
  DISPOSAL: CEMENT
   ENCAPSULATION
     AND BURIAL
     HEAVY METALS
    WITH ORGANICS
ARSE NIC AND ORGANICS
(DILUTE HYDROCARBON)
HEAVY METAL
   SULFIDE
PRECIPITATION
HEAVY MFTALSLUDGE
  DISPOSAL CEMENT
   ENCAPSULATION
     AND BURIAL
                                                                                     INCINERATION OF
                                                                                  DILUTE HYDROCARBON
                                                                                     INCINERATION OF
                                                                                   DILUTE HALOGENATED
                                                                                      HYDROCARBON
                                                                                      AND SCRUBBING
                                                                                        ACTIVATED
                                                                                    CARBON TREATMENT
                                                                                        ACTIVATED
                                                                                  CARBON REGENERATION
      F'igure 1. Examples of interrelationships between hazardous wastes and treatment and disposal processes. (Source:  EPA
Contract No 68-01-0556.)

-------
                              IDENTIFICATION AND DISCUSSION OF THE PROBLEM
wastes-hexavalent chromium; cadmium, arsenic, and
mercury;  and  arsenic  and  organics  (dilute hydro-
carbon)-exhibit significant differences (Figure 1).
   Transfer and adaptation of existing technology to
hazardous waste  management  may be necessary in
some  cases.  Some  hazardous  waste streams  (e.g.,
those  containing  arsenites  and  arsenates  of  lead,
sodium, zinc, and  potassium,  and  arsenic trioxide)
cannot be treated or  disposed  of  adequately  with
existing technology.3^  Secured storage  is available
until the appropriate treatment  and disposal technol-
ogy is  developed. Synopses of treatment and disposal
processes are given in Appendix D.
         Public Use of Existing Technology
   AEC and DOD  presently utilize  almost all the
processes  identified (Table  4)  for management of
hazardous  wastes.  High-level radioactive  treatment
and  storage  sites operated  by  AEC  are  located at
Hanford, Washington; Savannah River, South Caro-
lina; and  the  National Reactor  Testing  Station in
Idaho. Similar  DOD-operated nonradioactive hazard-
ous waste treatment, storage, and disposal  sites are
located at  a great  number  of arsenals, depots, and
ammunition plants throughout the country.
         Private Use of Existing Technology
   Some large manufacturers, notably in the chemical
industry,  have established in-house hazardous waste
processing facilities  which utilize some of the  treat-
ment  and disposal  processes  identified  (Table  4).
EPA-held data on such in-house operations are sparse.
From  available ocean  and  land disposal  data,  it is
estimated, however, that only a small percentage of
the hazardous wastes generated by industry receive
treatment and are disposed of at in-house facilities.

      The Hazardous Waste Processing Industry
   In  recognition of this situation,  several private
companies  have built facilities  to treat,  dispose of,
and recycle many hazardous  wastes. These companies
sell waste processing services to  industries in  their
areas,  generally within  a 500-mile (805-kilometer)
radius. However,  largely because of lack of demand
for services,  these  regional  waste processing plants
still are few in number (about 10  nationwide) and
operate at about 25 percent of available capacity.
   The total processing capacity of  all  facilities is
approximately  2.5  million tons (2 3  million metric
                     TABLE 5
SUMMARY OF INFORMATION ON PRIVATELY OWNED
    REGIONAL HAZARDOUS WASTE PROCESSING
                     PLANTS*
           Item
                                    Amount
Number of regional plants
Estimated available capacity
Estimated utilization of
   available capacity
Available capacity as percent
   of required nationwide
   capacity
Regional distribution
Total capital investment
Resource recovery
Approximately 10
2,500,000 tons per year
   (2,272,000 metric tons
   per year)
25 percent

25 percent
Mostly in North Central,
  Mid Atlantic, and Gulf
  Coast Regions
$25 million
Limited at present mostly
  to solvents and metal-
  lic salts
      *This table does not consider very  small firms with
limited facilities (e.g., those plants that consist solely of an
incinerator).
tons) per year (Table 5). Operating at full capacity,
these private processing firms presently could handle
about 25 percent of the total nationwide nonradio-
active  hazardous  wastes.  None  of  these  facilities
provide a complete  range of treatment and disposal
processes capable  of handling all  types of hazardous
wastes (Table 5).
   As  stated  earlier,  nuclear weapons  production
facilities,  commercial nuclear power  reactors,  and
private  sources generate a  substantial  quantity of
high- and  low-level radioactive  wastes.  High-level
wastes are controlled by AEC.  Management of low-
level wastes by private companies  at AEC or  coopera-
tive  State  sites is a  highly  specialized  business with
limited  markets.  As a  result,  there  are only  two
companies  engaged   in  handling  and  disposing of
low-level radioactive wastes. The  quantities  of radio-
active wastes are expected  to increase exponentially
starting around 1980, and, as a result, the number of
nuclear  waste   disposal   companies   should   also
increase.
            ECONOMIC INCENTIVES
   The costs associated with proper hazardous waste
treatment and disposal are fixed capital intensive and
vary widely, depending on the particular treatment
process  that  is  required.  Examination of typical

-------
12
                                     DISPOSAL OF HAZARDOUS WASTES
capital and operating costs for a number of selected
processes that are applicable to medium-size regional
industrial  waste treatment  and disposal  facilities
illustrates that environmentally adequate technology
is  expensive  (Table 6). Moreover, to arrive  at  the
actual  costs  associated with  proper treatment  of
hazardous wastes, a combination of several treatment
processes is usually required.
   The  comparative economics of proper hazardous
waste management versus presently used environmen-
tally inadequate practices,  such as disposal in  dumps
or in the ocean, indicate that adequate treatment and
disposal  of  hazardous  wastes cost  10 to 40 times
more  than the environmentally offensive  alternatives
(Figure 2). With these kinds of economic differen-
tials, and in  the general absence of pressures to  do
otherwise, one realizes why the more environmentally
acceptable methods are seldom utilized. Available
technology cannot  compete  economically  with  the
cheaper disposal alternatives. Clearly,  there are sub-
stantial economic incentives  for  industry not to use
adequate  hazardous  waste treatment and disposal
methods.
   Should a generator elect to process his hazardous
wastes in an  environmentally acceptable manner, a
basic decision must  be made  whether the particular
waste stream should be processed on site or off site at
some  regional treatment  facility,  such  as existing
commercial waste processing plants. The cost analysis
of  this  problem,  as  it  applies  to  a number  of
commonly occurring industrial waste streams, was
conducted by means of a mathematical model that
produced  "economic   decision  maps."36  Typical
examples are attached in Appendix E. An analysis of
the decision maps indicates that cost factors generally
favor off-site treatment  and disposal of industrial
hazardous wastes with the exception of dilute aque-
ous  toxic metal streams.  Other factors, such as the
impact  of  pending water effluent  standards and
transportation problems, may alter this judgment.
                   SUMMARY
   EPA's findings relative to the current handling of
hazardous wastes can be summed up as follows:
   (1)  Current treatment and disposal practices are
inadequate and cause unnecessary hazards to all life
forms.
   (2)  Techniques  for  safe   and  environmentally
sound  treatment and disposal of  most  hazardous
wastes  have been developed. Adaptation and transfer
of  existing   technology  and  development  of new
methods are required in some cases. It is possible to
retain  hazardous wastes  for  which treatment and
disposal methods are unavailable in long-term storage
until their  chemical conversion  to harmless com-
pounds or their reuse  in  industrial practice becomes
feasible.
                                                 TABLE 6
                  COSTS OF REPRESENTATIVE HAZARDOUS WASTE TREATMENT PROCESSES*^

Process
Chemical oxidation of cyanide wastes
Chemical reduction of chromium wastes
Neutralization/precipitation
Liquid-solid separation
Carbon sorption
Evaporation
Incineration
Capacity
1,000 gal/day 1,000
25
42
120
120
120
120
1174

liters/day
94.8
159
452
452
452
452
**67
Capital costs t
($1,000)
400
340
3,000
9,000
910
510
4,900
Operating
$/ 1,000 gal
68
29
50
40
7
10
tt95
costs k
$71,000 liters
18
7.65
13.20
10.60
1.85
2.64
trios
      *Source: EPA Contract No. 68-01-0762.
      "^Data correspond to a typical medium-size treatment and disposal facility capable of processing approximately 150,000 tons
(136,000 metric tons) per year or 600 tons (545 metric tons) per day
      •tCapital costs include land, buildings, and complete processing and auxiliary facilities.
      § Operating costs include neutralization chemicals, labor, utilities, maintenance, amortization charges (7 percent interest),
insurance, taxes, and administrative expenses.
      1iTons per day.
     **Metric tons per day.
     ft Dollars per ton.
     -tt Dollars per metric ton.

-------
                              IDENTIFICATION AND DISCUSSION OF THE PROBLEM
                                                                                                            13
 ~ 400 (106.00)
 o
 o
 o
   300  (79 40)
 m 200  (52.80)
 O
 o
 o
 =  100
 •
        (26 40)
 c/i
 O
 O
 o
 z
 O
 O
 oc
 CL
50  (13.20)
15   (3.96)
 5   (1
t
                              A - ENVIRONMENTALLY ADEQUATE TREATMENT AND DISPOSAL
                              B = LAND DISPOSAL
                              C = OCEAN DISPOSAL
                      25
                     (94 6)
                                        120
                                        (454)
                                                 200
                                                 (758)
 1,000
(3,785)
                                       WASTE VOLUME [ 1,000 gal/day (1,000 liters/day)]
      Figure 2. Cost  comparison of proper versus improper hazardous waste management practices for aqueous wastes.  Data
include capital  writeoff but not transportation  costs  from  the generator to  the nearest treatment or disposal facility. Note the
economies of scale attainable by using large waste processing facilities. (Source. EPA Contract Nos. 68-01-0762 and 68-03-0089;
based on cost data from typical treatment and disposal  facilities capable of handling aqueous toxic wastes.)
   (3) There are substantial economic incentives for
industry not to use environmentally adequate treat-
ment and disposal methods.  Such methods are  sub-
stantially more expensive  than  current inadequate
practices, and in a climate of permissive legislation or
total  absence  of  legislation,  competitive economic
forces result in least-cost disposal regardless of  the
environmental consequences.
   (4) A small industry has  emerged  to treat  and
dispose of hazardous and other industrial wastes. This
industry is  not currently operating  at  capacity  be-
cause its services  are  being utilized only  by a  few
                                                      clients who  are  concerned  about  the  environment,
                                                      have  no cheaper disposal alternatives, or  sometimes
                                                      find themselves forced to use such services because of
                                                      environmental regulations.  This industry, however,
                                                      has  the  capability  to  expand to  meet demands
                                                      engendered by future Federal or State actions.

                                                         It  is evident that a need  exists for bringing about
                                                      environmentally  acceptable  and safe treatment and
                                                      disposal  of  hazardous  wastes.  A discussion of  the
                                                      need  for  a regulatory program to achieve this goal
                                                      follows in Section 3.

-------

-------
                                           Section 3
         THE CASE FOR HAZARDOUS WASTE REGULATIONS
   The potential for public health and environmental
damages from mismanagement  of hazardous wastes
and  the lack of  economic  incentives for proper
management has been described in Section 2. There is
a strong precedent for Federal regulation when health
damage is at issue. Regulation  is used because the
other conceptual alternative, massive economic incen-
tives, does not ensure  compliance. Some  forms of
regulation,  however,  may embody certain types of
economic incentives.  Federal and State  statutes have
attempted to regulate and control various parts of the
problem, but  there  has  never been  an attempt to
regulate  hazardous waste management in  a compre-
hensive manner.
   The following discusses legislative precedents  that
relate to hazardous wastes and illustrates a legislative
gap  in the regulation of  land disposal of hazardous
wastes.
   EXISTING AUTHORITIES FOR HAZARDOUS
            WASTE MANAGEMENT
   A large body of Federal and State law exists today
which  exerts a significant but peripheral  impact on
the land  disposal of hazardous wastes. The following
discussion reviews  existing laws and assesses  their
impact  on the  treatment, storage,  transportation,
handling, and disposal of hazardous wastes.
             Federal Control  Statutes
   Thirteen Federal statutes have varying  degrees of
direct  impact  on  the management  of  hazardous
wastes.  Four additional Federal statutes  are either
indirectly or  potentially  applicable  to  hazardous
wastes. The Clean Air Act, as  amended, and the new
Federal Water  Pollution Control Act (FWPCA) are
discussed in some  detail  later in this  section. The
other statutes  and their  impact on  the treatment,
storage, transportation, and handling of  hazardous
wastes are summarized in the following.
   Section  212  of the Resource Recovery  Act of
1970 directs the Administrator of EPA to study the
feasibility of a system of  national  disposal sites for
hazardous wastes.3 7 The act authorizes no regulatory
activities, however.
   The  Atomic  Energy Act of 1954,  as amended,
authorizes  AEC to manage radioactive  wastes gen-
erated in fission reactions by both AEC and private
industry.38   High-level   radioactive  wastes  from
weapons and reactor programs are controlled directly
by  AEC at  its  facilities; commercially generated
low-level radioactive wastes are generally disposed of
at facilities licensed and  controlled  by the  States.
Naturally occurring materials,  such as uranium mill
tailings  and radium, and radioisotopes produced by
cyclotrons are not subject to regulation under the act.
There is room for improvement at the radioactive
waste storage  and disposal facilities, but compared
with  the management of  other hazardous  wastes,
high-level radioactive waste management is well regu-
lated.
   The  Department  of  Transportation  (DOT)  is
responsible  for  administering five statutes  which
affect the transport of hazardous wastes. The oldest
of these, the Transportation of Explosives Act, pro-
hibits the knowing unregulated transport of  explo-
sives, radioactive materials, etiologic (disease-causing)
agents,  and  other  dangerous  articles  in interstate
commerce  unless the  public interest requires expe-
dited movement  or  such transport  involves "no
appreciable danger to persons or property."39 Supple-
menting this law is the Hazardous Materials  Trans-
portation Act of J 970, a nonregulatory statute which
authorizes the Secretary of DOT to evaluate hazards
associated with hazardous  materials transport, estab-
lish a central accident reporting system, and  recom-
mend improved hazardous material  transport con-
trols.40  The Safety Regulation of Civil Aeronautics
                                                 15

-------
16
                                    DISPOSAL OF HAZARDOUS WASTES
Act  authorizes the Federal Aviation Administration
to establish air transportation standards "necessary to
provide adequately for national security and safety in
air commerce.'"31  The Hazardous Cargo Act places
regulatory controls on the water transport of explo-
sives or dangerous substances, authorizing the U.S.
Coast  Guard  to  publish regulations  on packing,
narking, labeling,  containerization, and certification
of such substances.42 The Federal  Hazardous Sub-
s.ances LalK-ing f\ct authorizes the Secretary of DOT
10 identify hazardous substances and prohibits  the
transport of such  substances if their containers have
been misbranded or the labels have been removed.4 3
The act authorizes the seizure of misbranded hazard-
ous substances and requires the courts to  direct  the
ultimate disposition of such seized substances.
   The Federal Environmental Pesticide Control Act
of  1972  requires the  Administrator  of EPA  to
establish procedures and regulations for the disposal
or  storage  of  packages,  containers,  and   excess
amounts of pesticides.44  EPA is  also required to
"accept at convenient locations for safe  disposal"
those pesticides whose registration is suspended to
prevent an imminent hazard and later canceled if  the
pesticide owner so  requests.44
   The Marine Protection, Research, and Sanctuaries
Act of 1972 prohibits the transport from the United
States for the purpose of ocean dumping any radio-
logical, chemical, or biological warfare  agents, high-
level radioactive wastes,  or (except as authorized by
Federal permit) any  other material.43  In granting
permits for ocean  dumping, the  EPA Administrator
must consider "appropriate locations and methods of
disposal  or  recycling, including land-based  alterna-
tives, and the probable  impact of [such use]  upon
considerations affecting the public interest."46
   The Clean Air Act and the Federal Water Pollution
Control Act,  examined in detail later in this section,
provide extensive control authority over the incinera-
tion  and  water   disposal  of  certain   hazardous
wastes.47'48
   The  Poison Prevention Packaging Act authorizes
the  Secretary of Health, Education, and Welfare to
establish special packaging standards for  hazardous
household substances whenever it can be shown that
serious personal injury or illness to children can result
from handling, using, or ingesting such substances.49
Hazardous household substances already identified in
regulations include oven cleaners, cigarette and char-
coal lighter  fluids, liquids containing turpentine and
methyl alcohol, and economic poisons (pesticides).
   The Food,  Drug and Cosmetic Act prohibits the
adulteration and misbranding  of certain  consumer
items and requires the disposal  by destruction or sale
of any items seized under the act.5 °
   The first  of the Federal statutes that has a general,
nonregulatory impact on the management of hazard-
ous wastes is the National Environmental Policy Act
of 1969 (NEPA).51 Section 101(b) of NEPA requires
the  Federal  Government   to  "use  all  practicable
means"  to attain the widest range of beneficial uses
without degrading the environment or risking health
or safety. In order  to ensure that the environmental
policies  expressed  in  Section  101  are  effectively
carried out,  Section 102(2)(C) requires all agencies of
the Federal Government to  prepare detailed environ-
mental  impact  statements  for all  "major  Federal
actions  significantly  affecting  the  quality of the
human environment." All  Federal hazardous  waste
management activities thus clearly fall within NEPA's
ambit.
   The Armed Forces  Appropriation Authorization
Acts of 1969 and 1970 prohibit the use of Federal
funds for  the  transportation,  open-air  testing,  or
disposal of any  lethal chemical or biological warfare
agent in  the United  States  except under certain
conditions requiring prior determination of the effect
on national security,  hazards  to  public  health and
safety, and  practicability of detoxification prior  to
disposal.52'53
   The Coastal  Zone  Management Act  of 1972,  in
declaring it a national policy to preserve and protect
the resources of the Nation's coastal zone, recognizes
waste disposal as a "competing demand" on coastal
zone lands which has caused "serious environmental
losses."54 Because applicants for Federal coastal zone
managment  grants must define  "permissible land and
water uses within the coastal  zone," an applicant's
failure to regulate  hazardous waste disposal  within
such area so that it qualifies as a "permissible use"
can serve as a basis for denying program funds under
the act.
   The Occupational Safety and Health Act of 1970
(OSHA)  authorizes  the Secretary of Labor  to set

-------
                             THE CASE FOR HAZARDOUS WASTE REGULATIONS
                                                17
mandatory  standards  to  protect  the  occupational
safety and health of all employers and employees of
businesses engaged in interstate commerce.55 Section
6(b)(5) deals specifically  with toxic materials and
other harmful agents, requiring the Secretary to "set
the standard which most adequately  assures . .  . that
no  employee  will  suffer  material  impairment  of
health or financial capacity" from regular exposure to
such hazards. Employees of hazardous waste genera-
tors and treatment and  disposal facilities engaged in
interstate  commerce thus are clearly  entitled to the
act's  protection.  It  should be noted that standards
issued under the act can directly impact some phases
of hazardous waste management. For example,  the
OSHA-enforced asbestos regulation requires that cer-
tain wastes be packaged for disposal.

               State ControJ Statutes
   At least 25 jurisdictions  have enacted legislation or
published  regulations which control hazardous  waste
management  activities  to  some  degree.  The  most
effective of  these regulatory controls are currently
placed on  low-level radioactive wastes, AEC having
contracted  with  a  growing  number of  States  for
low-level radioactive waste disposal.  Nonradioactive
hazardous  wastes, however,  are  essentially  unregu-
lated in practice,  for none  of the 25 jurisdictions has
fully implemented its control legislation.  The major
reason for  this failure  is  the negative  approach-
broadly worded  blanket  prohibitions-utilized  by
virtually all of these States.
   Legislative strategies which rely on blanket prohi-
bitions rather than comprehensive management con-
trols are difficult or impossible to administer in any
meaningful, systematic fashion. In addition, many of
these States enact control statutes without providing
for  acceptable treatment  or disposal  facilities.  A
recent survey  of 16  of  the  25  "control"  States
reveals, for example, that less than  half of them have
treatment  and disposal facilities located within their
boundaries (Table 7).56 By failing to specify accept-
able alternatives to prohibited activities, such States
encourage hazardous waste generators to  ignore  the
law  altogether or to  select and  employ divergent
disposal alternatives unknown  to  the State control
authorities that may be more environmentally harm-
ful than the prohibited activity.
                    Summary
   With the exception of radioactive waste disposal,
which appears to be the subject of adequate Federal
and  State regulation,  land-based  hazardous  waste
treatment, storage, and disposal  activities are  essen-
tially unregulated by Federal and State laws. Because
this legislative gap allows uncontrolled use of the land
for hazardous waste  disposal,  there  has been  little
incentive  for the  use of proper  hazardous  waste
treatment  and disposal technology  to  date.  Until
nationwide controls are established, the pressure on
the land as a receptor for hazardous  wastes can be
expected  to  increase as the major hazardous  waste
disposal controls of the Clean  Air Act, the FWPCA,
and  the  new  Federal ocean  dumping statute are
tightened.  The latter statute's  mandate  to the EPA
Administrator to consider land-based disposal alterna-
tives  when  granting ocean dumping permits  seems
certain  to provide  opponents of  the  practice of
dumping toxic wastes into  the  ocean with  a new and
powerful legal tool. Depending on the courts'  inter-
pretation  of this   statute,  the  Marine  Protection,
Research, and  Sanctuaries Act of 1972 could add
significantly  to  the  pressure  on  land  as  the last
disposal medium for hazardous wastes.

    PRECEDENTS FOR HAZARDOUS WASTE
                  REGULATION
   Both the Clean Air Act and the FWPCA include
provisions  that  address  the  problem of  hazardous
waste management directly.4 ''4X The former statute
authorizes  the  control  of  hazardous air pollutants,
and  the  latter  controls the  discharge of  hazardous
pollutants into the Nation's waters.
   The  Clean Air  Act  best exemplifies  a control
strategy designed  to protect the  public  health and
welfare by placing the burden of standards compli-
ance on the air polluter. As with most environmental
control statutes, the costs of compliance are internal-
ized by the polluter and ultimately passed on to the
consumer, indirectly in the form of tax benefits to
the polluting industries, or directly in the  form of
higher prices for goods and  services.57  In the past,
Clean  Air Act  standards  have been  based almost
exclusively on health effects. As a result  of adverse
court  decisions  on  ambient air quality  standards,
however, EPA has expanded its efforts to consider, in

-------
18
                                     DISPOSAL OF HAZARDOUS WASTES
                                                 TABLE 7
                                SUMMARY OF STATE LEGISLATION SURVEY*
Solid waste
State

Alabama
California
Colorado
Illinois
Kansas
Maine
Michigan
Nevada
New Jersey
New York
Oregon
South Carolina
Texas
Vermont
Virginia
Washington


a e

Alabama
California
Colorado
Illinois
Kansas
Maine
Michigan
Nevada
New Jersey
New York
Oregon
South Carolina
Texas
Vermont
Virginia
Washington
Disposal
regulations
Yes
Yes
Yes
No
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes

Licensing of
disposal sites Disposal
Yes
Yes
Yes
Yes
Yes
No
Yes
No
Yes
Yes
Yes
Yes
Yes
No
No
Yes

Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Explosives
Radioactive material
Regulations on
Transportation Processing
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
No
Storage
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
No
Transportation
Disposal
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
No
Yes
Yes
Yes
Industrial
Pesticides
Regulations on
Transportation
Yes
Yes
No
Yes
Yes
No
Yes
No
No
No
Yes
No
-
No
No
No
safety
















Processing Storage
Yes
Yes
No
Yes
Yes
No
Yes
No
No
No
No
No
Yes
No
No
No
Presence of
regulations for

Disposal
_
No
No
-
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No

Yes
Yes
Yes

Regulations on

Transportation Processing Storage

Yes
No
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
-
Yes
Yes
Yes

No
No

Yes
-

No
Yes
Yes
No
No
-
Yes
Yes
No
_
Yes
No
-
Yes
-

Yes
Yes
Yes
Yes
No
-
Yes
Yes
Yes
DOT
regulations
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
Yes
No
Yes
Yes
No
Yes
Yes
No
No
Yes
No
Yes
No
No
No
existing
facilities
handling hazardous
Other +
__
Yes
No
Yes
Yes
-
Yes
No
-
-
No
Yes
Yes

-
No
materials
Yes
Yes
No

-
Yes
Yes
No
No
Yes
No
-

No
No
No
















Radioactive
Yes
-
No
Yes
Yes
No
No
No
Yes
Yes
No
Yes
Yes
No
No
Yes
















Hazardous -f
No
Yes
No
No

No
Yes
No
Yes
Yes
No
No
Yes
No
No
Yes
     ^Source EPA Contract No. 68-01-0762
     1 Includes hauling permits, vehicle registrations, material registrations, bills of lading, placard attachment, and vehicle standards
     1 Includes pesticides, toxir substances, and other chemicals
addition to health and welfare factors, (1) beneficial
and   adverse  environmental   effects,   (2)   social,
economic,  and  other  pertinent  factors;  (3)  the
rationale for selecting the standard from the available
options.58'60
   The  FWPCA Amendments  of  1972  generally
exemplify a  control  strategy  based on  factors  in
addition to human health and welfare. Typical of the
FWPCA's new regulatory provisions are those keyed
tp "best  practicable" control  technology and "best
available technology economically achievable," deter-
minations which are to be made by EPA from studies
of the  age,  size, and unit processes of the  point
sources involved and  the cost of applying effluent
controls.
                 The Clean Air Act
   Section 112 of the  Clean Air Act authorizes the
Administrator of EPA to set standards for hazardous
air  pollutants at any level  "which in his  judgment
provides an  ample margin of safety  to protect the
public health."6' Hazardous air pollutants are defined
as  those  which  "may cause, or  contribute to an
increase in mortality or an increase in serious irrevers-
ible or  incapacitating reversible, illness"  [Section
112(a)(l)].  Asbestos,  beryllium,  and  mercury are
three hazardous  pollutants for which  emission limits
under Section 112 have been promulgated.
      The Federal Water Pollution Control Act
   The  FWPCA contains a number of provisions with
direct impact on hazardous pollutant-bearing wastes.

-------
                              THE CASE FOR HAZARDOUS WASTE REGULATIONS
                                                                                                          19
Section 502(13) defines  "toxic pollutant" as "those
pollutants. .  .  which . . .  after  discharge  and upon
exposure, ingestion,  inhalation or  assimilation into
any organism .  . . will cause death, disease, behavioral
abnormalities,  cancer, genetic mutations, physiologi-
cal malfunctions  . .  or  physical  deformations on
such  organisms  or  their  offspring." Section  115
directs EPA  to locate and contract  for "the removal
and appropriate disposal of [in-place toxic pollutant]
materials  from  critical port and  harbor areas." The
potential  for increased pressure for land disposal of
such toxic pollutants is evident.
   Title III  of the FWPCA contains four provisions
authorizing control over  toxic pollutants  discharged
into water from point sources. The importance of the
FWPCA's distinction between  point and nonpoint
sources cannot be  overemphasized from a hazardous
waste  management viewpoint,  for discharges from
point sources only are subject to  the act's regulatory
controls.* Because the act  defines "point source" as
"any discernible, confined and discrete conveyance,"
and offers as examples such things  as pipes,  ditches,
and tunnels, Congress seems not to have intended
that land disposal facilities are to be included within
the point source definition.62 In fact, the  opposite
appears  to  be true,  for  Section  304(e) of  the act
requires  EPA  to publish nonregulatory "processes,
procedures,  and methods to control pollution result-
ing from  . . . the disposal of pollutants in  wells or in
subsurface excavations" [emphasis supplied] .6 '
   Since  the types of pollutant  discharges normally
associated with improperly  managed hazardous waste
disposal facilities are runoff into navigable waters and
migration into  groundwater supplies, it seems safe to
conclude  that,  unless a  disposal facility discharges
toxic pollutants into a waterway through a "discerni-
ble, discrete  conveyance," such as an outfall pipe, it
will be exempt  from the act's proscriptions.
   Hazardous  waste treatment  facilities,  however,
should not escape  the act's reach.  Any toxic wastes
produced by such facilities and not treated on  site
must be stored and/or eventually transported in some
manner, and any  container or confined  means of
conveyance for such waste, by definition in Section
502(13) of  the act,  qualifies as  a potential  point
source of water pollution discharge.
   The  first  of  Title Ill's proscriptions against toxic
pollutant discharges may be found in Section 301(f),
which prohibits  the "discharge  of any radiological,
chemical, or  biological  warfare  agent,  or  high  level
radioactive  waste  into  the navigable  waters." The
other  statutory  authorities  which  impact  on  the
disposal of these wastes were discussed previously.
   Section 306  is the second reference  to hazardous
wastes.  It requires  EPA to publish  national standards
of  performance for  new point  source  categories
reflecting "the greatest degree of  effluent reduction
achievable . . . ,  including where practicable,  a stand-
ard permitting no discharge of pollutants."64 The act
singles out such new source categories as the organic
and   inorganic   chemicals  industries,   well-known
generators  of toxic wastes. These  standards, which
must take   into  account  the  cost  of standards'
achievement  and  "any  non-water quality environ-
mental  impact and energy  requirements,"* must  be
published not later than  January  1974.  Hazardous
waste generators and treatment facilities which other-
wise qualify as  "new" clearly are  comprehended in
Section 306(a)(3),  which defines new sources as "any
building,  structure,  facility,  or   installation  from
which there is or may be the discharge of pollutants."
This adds to the general qualification  of such facilities
as point sources.
   The third FWPCA provision affecting toxic pollut-
ants  is Section 307, which requires  EPA to identify
and  publish  effluent  standards  for a  list  of  toxic
pollutants or combinations  of such pollutants. Stand-
ards  are to be set "at that level which the Administra-
tor determines provides an ample margin of safety,"
and  are  to  take effect not later  than  1 year after
promulgation.65  Even though Congress'  standard-
setting process mandate  to EPA under this section
      *Section 301 (a) established FWPCA's broad prohibi-
tions  against  the "discharge of  any  pollutant '' Section
502(12) defines "discharge of pollutants" as "any addition of
any pollutant  to navigable waters from any point source"
| emphasis supplied |
      *Section  306(b)(l)(B).  The  FWPCA's  legislative
history, however, makes it clear that individual new sources,
rather than EPA, will determine which technologies will be
used to achieve Section  306(b)'s  performance standards.
Conference Report No. 92-1465,  FWPCA Amendments of
1972, 92d Congress, 2d Sess. (Sept. 28, 1972, p.128.)

-------
20
                                      DISPOSAL OF HAZARDOUS WASTES
was limited to consideration of toxid'y data alone,*
other factors, as previously discussed, likely will be
considered  to  produce judicially enforceable stand-
ards,   given  recent   air-pollution-related   court
decisions.58'60/
   Section  311 is designed to protect the navigable
waters and adjoining shorelines of the United States
and the waters of the contiguous zone from "hazard-
ous  substance" discharges.  EPA must designate as
hazardous  substances those elements and compounds
"which, when discharged in any quantity,  . . . present
an imminent and  substantial danger  to  the public
health and substantial danger to  the public welfare,
including  but not limited to fish, shellfish, wildlife,
shorelines,  and beaches."66  Designed primarily to
control spills from  vessels and onshore or offshore
facilities, Section 311 requires violators to  pay a fixed
cost  for each hazardous  substance  unit  unlawfully
discharged, -? with the President alone authorized to
permit  certain of  these discharges  when  he  has
determined them "not  to  be harmful."67  Coastal
zone area  hazardous waste generation  and treatment
facilities thus would clearly be subject to Section  311
controls and penalties.

    CLOSING THE CIRCLE ON HAZARDOUS
                     WASTES
   The  foregoing  discusses  the  many Federal  and
State statutes that have impact on hazardous  waste
      *Section 307(a)(2) requires the Administrator of EPA
to publish proposed toxic effluent standards (or prohibitions)
which  "shall  take  into account  (1)  the toxicity of the
pollutant, (2) its persistence, (3) degradability, (4) the usual
or potential presence of the affected organism in any waters,
(5) the importance of the affected organisms, (6) the nature
and extent of the effect  of  the toxic  pollutant on such
organisms . . . ." No  other  considerations are mentioned in
Section 307 or its legislative history.
      '''See Kennecott Copper v. EPA, U.S. App. D.C., _F.
2d _,  3  ERC  1682 (Feb. 18,  1972} (EPA must explain in
detail  the basis for sulfur oxide standards promulgated under
informal rulemaking); Anaconda Company v. Ruckelshaus,
D.C. Colorado, _F. Suppl. _,  4 ERC 1817 (Dec. 19, 1972)
[EPA  must hold adjudicatory (formal rulemaking) hearing
before promulgating State sulfur oxide emission standard
that applies to a single  company]; International Harvester
Co.  v. Ruckelshaus, U.S. App. D.C., _F. 2d_, 4 ERC 2041
(Feb.  10, 1973) (failure to support auto emission standard
with "reasoned presentation" requires  EPA to  reconsider
automakers' showing that  technology is not available to
achieve 1975 standards).
      ^Section 311(b)(2)(B)(IV) requires EPA to establish
units of measurement based on usual  trade  practices, with
penalties for each unlawful  unit discharged ranging from
$100 to $1,000 per unit.
management activities. The more detailed analyses of
the Clean  Air Act  and the  FWPCA illustrate  that,
whereas  the  toxic  effluents  of  hazardous  waste
generation  and  treatment  facilities will  probably
come under control, land-based facilities for  open
storage  or  disposal of such hazardous wastes remain
essentially  unregulated. As standards and regulations
published  under  recent  environmental  legislation
begin to close off water as a disposal medium, and as
enforcement of air  pollution standards  takes shape,
hazardous  waste generators can be expected  to turn
increasingly to  land disposal as a means of solving
their hazardous waste problems. The need for regula-
tions for land disposal will become more acute.
   The concluding part  of this  section  discusses the
persons  and  activities  that  would  be  subject  to
control  under  a  comprehensive  hazardous  waste
regulatory  program,  reviews in  some detail the type
of hazardous waste standards considered to be appro-
priate  under  such  a program,  and identifies and
evaluates  the  strengths  and  weaknesses  of  three
alternative regulatory program enforcement strategies.

          Persons and Activities Subject  to
                Regulatory Controls
   In order to  forestall  the  type  of environmental
degradation likely to occur from the uncontrolled use
of  the  land as an  ultimate sink  for  the Nation's
ever-increasing supply of hazardous wastes, the focus
of any hazardous waste regulatory program must first
be  on  land disposal activities and those  who provide
and utilize land disposal services. Persons subject to
disposal  controls should  include  all generators  of
hazardous  waste who opt  for on-site disposal, as well
as  those persons who  receive wastes  off  site for
disposal. Long-term sealed storage  should be consid-
ered disposal  for  the enforcement  purposes of such
regulation. The location of disposal sites should  be
permanently  recorded in the  appropriate  office  of
legal jurisdiction.
   The  next priority activity for regulation is treat-
ment since utilization of the appropriate hazardous
waste  treatment processes can  often detoxify such
wastes and render them safe for unregulated disposal
in sanitary landfill facilities or  at a minimum reduce
the need for long-term "perpetual care" and environ-
mental  risks inherent therein.  EPA has proposed a
regulatory  program  for  hazardous waste   streams

-------
                             THE CASE FOR HAZARDOUS WASTE REGULATIONS
                                                                                                         21
which incorporates treatment in order to lessen the
demand on land disposal alternatives All persons who
treat   the  same  hazardous  wastes,  either  on  site
(generators)  or off site  (contract service  organiza-
tions),  should  be  subject  to  the  same  treatment
standards.  Processes for recovery of recyclable con-
stituents from hazardous wastes should be controlled
adequately  by treatment regulations, for the tech-
nologies employed are often the same.
   Other hazardous waste management activities that
should be subjected to improved controh are hazard-
ous  waste  transport  and  handling.  As indicated
earlier, DOT administers a number of Federal statutes
designed to control the transportation of hazardous
materials  in  interstate  commerce.  These  statutes
should  be  amended  by  DOT  where  necessary  to
ensure that hazardous  wastes are properly marked,
containerized,  and  transported  (to authorized  dis-
posal sites). The packaging and labeling provisions of
all other Federal statutes that have a potential impact
on hazardous wastes should be reviewed by EPA and
amended where necessary to ensure their applicability
to such wastes
   It should be noted that control of toxic materials
before they become toxic wastes could greatly reduce
the size of  the overall hazardous waste management
problem.  The  proposed Toxic  Substances  Control
Act, now  pending before Congress, would provide for
regulatory controls  over toxic substances before they
become wastes. The proposed legislation authorizes
testing of  chemical substances to  determine their
effects on health or the environment and restrictions
on  use  or  distribution  of  such  chemicals  when
warranted. Such restrictions may include labeling of
toxic  substances as to appropriate  use, distribution,
handling,  or disposal,  and limitations  on particular
uses, including a total ban. This "front-end" approach
to toxic substances problems  should dovetail neatly
with a hazardous waste regulatory program.
        Types of Hazardous Waste Standards
  The foundation  of  any  regulatory program,  of
course, is  the body of standards the program estab-
lishes and enforces. The Clean Air Act and FWPCA
regulatory programs progressed from ambient air and
water quality standards to specific pollutant emission
and discharge standards as practical experience with
each statute's enforcement revealed the necessity for
such an evolution.0 8
    Because of the nature of the discharges associated
 with improperly managed hazardous waste, two types
 of standards  are  likely to be necessary in  order  to
 satisfactorily  regulate hazardous waste treatment and
 disposal  (1)  The "performance"  standard would set
 restrictions on  the quantity  and quality of  waste
 discharged  from the treatment process  and on the
 performance of  the disposal site (e.g., the amount and
 quality  of leachate  allowed),  (2)  the "process"
 standard  would  specify  treatment  procedures  or
 process conditions to be followed (e.g.,  incineration
 of certain wastes) and minimum  disposal site design
 and operating conditions (e.g., hydraulic connections
 are not allowed).
   The  performance  standards,  which  correspond
 directly to the  emission and discharge  standards  of
 the Clean Air  Act and the FWPCA, would be  designed
 to prevent hazardous pollutant discharges from treat-
 ment  and  disposal  facilities from reaching  air and
 surface waters in  excess  of  acceptable air and water
 limits. A major  advantage of this  type of standard is
 the  ability  to use health and environmental effects
 data and criteria already developed by EPA's Office
 of Air and Water Programs and Office of Research
 and Development
   Process standards would be designed to ensure that
 certain treatment  technologies and  minimum design
 and operating conditions are employed.  These stand-
 ards assume double importance because of the uncer-
 tainty  surrounding  the  FWPCA's  standard-setting
 authority regarding  discharges into  ambient  ground-
 waters,*  and  the act's clear  lack  of authority  to
 regulate diffuse discharges  from nonpoint  sources
 such   as  land  disposal sites.  Process  (design  and
 operating) standards, therefore, which are intended  to
 establish  controls at  the hazardous waste  sources,
 would  be  an  important  part  of  any  regulatory
 program.
      Strategies for Hazardous Waste Regulation
   Hazardous  wastes  can  be  regulated by  three
 distinct control  strategies.  (1) Federal only, (2) State
      * Although the broad  definition  given to "navigable
waters" in Section 502(7) of the FWPCA arguably includes
groundwaters, the restriction of the act's regulatory provi-
sions to discharges of pollutants from point sources virtually
eliminates the most  common source of groundwater pollu-
tion; i.e., runoff or  leachate from nonpoint sources. (See
earlier discussion of point sources.)

-------
                                     DISPOS \L OF HAZARDOUS WASTES
only,  (3) Federal/State  partnership.  Each of these
alternatives is examined.
   Federal Only.   The Federal-only type  of  control
strategy  requires  the  exclusive jurisdiction  of the
Federal Government  (Federal  preemption) over all
management activities for hazardous waste. The most
obvious advantages include  national uniformity of
standards, elimination  of State pollution  havens for
industries controlling  a significant portion of such a
State's economy,  and uniform administration  and
enforcement. The  major  disadvantages of this control
strategy are the difficulty in proving conclusively that
the hazards of human health  and the  environment
justify total  Federal  involvement,  the prohibitive
costs  and administrative  burdens  involved in main-
taining a nationwide Federal monitoring and enforce-
ment  program, and  the  total disincentive for State
involvement in what  is  essentially a  State problem.
The only comparable  Federal program is that involv-
ing the exclusive  disposal of  high-level radioactive
wastes by AEC.
   State  Only.  Under the State-only control strat-
egy, the Federal Government would establish "recom-
mended guidelines"  for  hazardous waste treatment
and  disposal  which  the States could adopt  as a
minimum, modify in  either  direction (more or less
stringent) in response  to local needs and pressure
groups, or ignore altogether. These Federal guidelines
could be used  to  recommend what would otherwise
be  process and  performance  standards under  a
Federal regulatory program, as well as the minimum
efforts the Federal Government believes are necessary
to administer  and  enforce an effective State control
program. States could finance activities themselves;
alternatively, the  Federal Government could  offer
technical  and  financial  support to  assist States in
program  development and enforcement.  The major
advantage of  this approach  is in its  low level of
Federal involvement and correspondingly low Federal
budget  requirements. Another advantage  includes
enhanced ability  to   tailor  solutions to  particular
problems  that  may be essentially  local in character.
The  disadvantages of  the  State-only  approach to
hazardous waste control  include its total dependence
on the States for  the  adoption and  enforcement of
voluntary guidelines,  the nonavailability  of  Federal
backup  enforcement  authority,  the  potential  for
extreme nonuniformity between the individual States
adopting control programs,  and the  much greater
period of time needed to enact and fully implement
such a control system nationwide.
   Federal/State  Partnership.  The   Federal/State
partnership  is  the  control  strategy that had been
adopted by the Nation's major environmental pollu-
tion control statutes. The Federal Government would
establish minimum Federal  hazardous waste treat-
ment and  disposal standards,  all States would be
required  to  adopt these as minimum State standards
within a specified time period. The States would bear
the responsibility for establishing and administering
EPA-approved  State  control programs.  Functions
could include operating a statewide hazardous waste
facility  permit program,  maintaining  an inspection
and  monitoring force, enforcing  statutory  sanctions
against violators,  and filing program progress reports
with EPA.  As in the Federal air and water pollution
control programs, States with approved implementa-
tion programs would be eligible for Federal  financial
assistance.  For those States  that  fail to submit
approved  programs,  or  that do not  enforce  the
Federal/State standards, backup Federal enforcement
powers could be exercised to ensure uniform compli-
ance  or Federal  program   grant  funds could  be
withheld.   Provision  could  also be  made  for  a
federally administered control and enforcement pro-
gram for certain hazardous wastes determined to pose
extremely   severe  hazards,  an  approach   already
utilized by AEC for high-level radioactive wastes. The
major advantage of this  control strategy stems from
the  well-established legislative precedents  discussed
earlier, land pollution control regulations employing
this  strategy would be capable of being fully inte-
grated with  existing controls  over  air and water
pollution.  Other  advantages include utilizing  the
Federal Government's superior resources to set stand-
ards and design programs, while retaining the concept
of  State  responsibility  for  what  are traditionally
recognized   as  State  problems;  minimal   Federal
involvement  once the States'  implementation  pro-
grams are fully underway, uniform minimum national
hazardous waste standards, with  States retaining the
power  to  set  more  stringent  standards  if local
conditions  so dictate, and reasonable assurance  that
the  standards will be enforced ultimately  by some-

-------
                            THE CASE FOR HAZARDOUS WASTE REGULATIONS
                                               23
one. The disadvantages of the  combined Federal/
State hazardous  waste control strategy  involve its
potential  for  delay in final  implementation, since
States  can  be  expected  to  demonstrate  varying
degrees of readiness and interest in gearing up State
machinery to  run their respective control programs.
The  major  drawback  to  this  approach, however,
involves its potential for large expenditures of Federal
manpower and funds should the States choose to sit
back and "let the Feds do it"; even worse is the
possibility that Federal standards for hazardous waste
control will  be  completely unenforced  in  laggard
States  simply  because of the lack of adequate  funds
to exercise the reserve  powers. This problem seems
capable of resolution, however, if adequate incentives
for State action are made available (Federal grants or
technical  assistance) and  if significant disincentives
are  applied  (such as  withholding air   and  water
program grant  funds or characterizing the State as
"irresponsible").
                   SUMMARY
   The earlier parts of this section describe the gap in
Federal  and State  hazardous  waste  management
legislation, a gap which if not filled soon by Congress'
adoption of a comprehensive hazardous waste control
strategy could well result in irreparable damage to the
health and environment of the Nation's citizens. The
most  viable hazardous waste control strategy would
consist  of  a Federal/State regulatory partnership in
which  the  Federal  Government  would  bear  the
responsibility for  setting process and  performance
standards applicable to all hazardous waste treatment
and disposal activities while qualified State govern-
ments  would  be   responsible   for  administering
federally approved  control  programs and enforcing
the Federal standards.

-------

-------
                                           Section  4
                           ISSUES OF IMPLEMENTATION
  The previous  section  spells  out the need for a
regulatory  program.  A  hazardous waste regulatory
program  does not directly create  an NDS system as
envisioned  in Section 212 of the Resource Recovery
Act  of 1970. However, such  a  system would be
ineffective  unless  its   use  is  mandated  through
regulations Even with total governmental subsidy of
its construction and operation,  such a system would
not  be assured  of  receiving  all  hazardous  wastes.
Therefore,  a  regulatory  program is  needed in  any
case.
   EPA believes that private industry will respond to
a regulatory  program,  but there are a number of
questions relating  to that response. Furthermore,
several options  are available to the Government to
modify a purely  private  sector system to circumvent
these questions if need be.
   In this  section,  estimates  are developed of a
hazardous  waste  management  system required to
implement  a hazardous waste regulatory program, the
cost  of such a system, and possible variations of the
system. Issues related  to cost  distribution,  private
sector  response,  and  the  role  of Government   are
discussed thereafter.
 HAZARDOUS WASTE MANAGEMENT SYSTEM
   A hazardous waste management program should
result in  creation of a  system  with certain charac-
teristics:  adequate  treatment  and  disposal  capacity
nationwide, lowest cost  to society consistent with
public health and environmental  protection, equitable
and efficient distribution of cost to those responsible
for  waste  generation, and  conservation  of  natural
resources  achieved  by  recovery  and  recycling of
wastes instead of their destruction.
   This system   should  combine  on-site (point of
generation) treatment of some wastes,  off-site (cen-
tral facility)  treatment  for hazard  elimination  and
recovery, and secure  land  disposal  of residues that
remain hazardous after treatment.
   Estimates of total required treatment and disposal
capacity, and the mix of on-site and off-site capacity,
are keyed  to  hazardous waste  source  quantities,
types,  and  geographical distribution;  the  degree of
regulation and enforcement, and the timing of regula-
tory and enforcement implementation. The hazard-
ous waste management scenario developed represents,
in EPA's judgment, a system with the aforementioned
characteristics. It is based on the best available source
data and  technology assessments, discussions  with
major  waste  generators and  disposal firms,  and
consideration of the following criteria:  earth sciences
(geology, hydrology,  soils,  and climatology), trans-
portation economics  and risk,  ecology, human en-
vironment,   demography,  resource  utilization,  and
public acceptance.0 '7'q>' ° The scenario assumes com-
plete regulation, treatment, and disposal  of all  non-
radioactive  hazardous  wastes (as defined in Appendix
B) and anticipates issuance of regulations and vigorous
enforcement of them at the earliest practicable  time
period
   The scenario  that follows  and the  cost estimates
derived from  the  scenario should  be viewed  with
caution. Given any reasonable degree of dependence
on  private   market choices on the part of waste
generators  and  waste treatment and disposal firms,
the actual  implementation  of  a hazardous waste
management  program in the  United  States is not
likely to follow predictable, orderly lines.  Numerous
interactive  factors  are likely  to influence  the shape
and the cost of the  system as it evolves- including
such factors as the impact  of air and  water effluent
regulations  on waste stream volume and composition,
the impact  of uneven response to regulatory pressures
from region to region, changes in  technology, and
                                                  25

-------
26
                                     DISPOSAL OF HAZARDOUS WASTES
shifting locational patterns. What follows, therefore,
should  be  considered  as  one  of  many  possible
permutations of the system. Nonetheless, the scenario
does  represent  EPA's current best  judgment  of a
reasonable,   environmentally  adequate   hazardous
waste management system.
   As  noted previously,  approximately  10 million
tons (9 million metric tons) of nonradioactive hazard-
ous wastes are  generated per year. Of these, about 60
percent by  weight are organics  and 40 percent are
inorganics;  about 90  percent of  these  wastes are
aqueous in form.
   Economic analyses indicate that on-site treatment
is  generally justified  only  for dilute  aqueous toxic
metal  wastes and only where the generation rate  is
high (Appendix E). From analyses of source data, it is
estimated that about 15 percent of the total wastes
(1.5 million tons or 1.36 million metric tons) are in
the dilute aqueous toxic metal category and would be
pretreated by generators on site. Since on-site facil-
ities are anticipated to be small in scale compared to
off-site facilities,  about  50  on-site  facilities  each
capable  of  handling  approximately  30,000  tons
(27,000 metric tons) per year would be economically
justified. About one-third  (0.5 million tons or  0.45
million metric  tons)  of  pretreated  wastes would
require further processing at off-site facilities.
   In this postulated scenario, therefore, most of the
wastes (8.5 million tons  or 7.7  million metric  tons
plus pretreatment residues) would be  transported to
off-site facilities for treatment and disposal. The size
and  location of  treatment  plants is likely to corre-
spond to  patterns of waste generation:  Larger facil-
ities would be located in  major industrial regions,
smaller facilities elsewhere. Background studies  have
identified the location of industrial waste production
centers and  the designs  and unit  costs  of small-,
medium-,   and   large-size  processing  facilities
(Appendix F).
   A reasonable prediction is that five large facilities,
each capable of handling approximately  1.3 million
tons (1.2 million metric tons)  per year,  would be
created to serve five major industrial  regions in the
United States,  and 15  medium-size treatment plants,
each  processing  approximately   160,000   tons
(145,000  metric tons), would be built elsewhere to
provide reasonable access from  other waste genera-
tion points. Such an array of treatment plants, taken
in conjunction with  existing privately owned facil-
ities, is capable of processing all the nonradioactive
hazardous waste  generated in  the United States at
present, with a 25-percent margin for future growth
in waste volume.
   Processing reduces aqueous waste volume by about
50 percent and usually results in the elimination of
hazard (detoxification, neutralization, decontamina-
tion, etc.). If the appropriate treatment processes are
used,  most processing residues will be harmless and
disposal in ordinary municipal landfills will be possi-
ble. A  small  portion (5  percent-225,000  tons  or
204,000 metric  tons) of  residues containing toxic
metals  would  require  disposal in  special,  secure
landfills.
   Under  the  assumption  that  maximum treatment
for hazard  elimination  and volume reduction  of
extremely hazardous waste  is carried out, no more
than  five  (and  possibly  fewer) large-scale  secure
landfills would be required. Facilities would transport
their toxic metal residues  to such land disposal sites
rather  than operating secure landfills of their own
given   the  scarcity  of  naturally secure  sites,  the
difficulty  in gaining public acceptance of such sites,
the additional  expense of artificially securing sites,
and the relatively low costs of long-haul transport.
                      Costs
   Based on the  above scenario, cost estimates have
been prepared for on- and off-site treatment facilities,
secure disposal, and waste transportation. (The actual
values  used for  estimation  purposes are shown in
Table  8; more detail is presented in Appendix F.)
Estimates are  based on comprehensive  engineering
cost  studies. Each  regional  processing  facility was
assumed to provide a complete range of treatment
processes capable of  handling all types of hazardous
wastes, and, therefore, each is much more costly than
existing private facilities that  are more specialized.
   Based on these estimates,  the development of this
version of a national hazardous waste management
system would require investments in new facilities of
approximately  $940 million. Average annual  operat-
ing expenditures  (including capital recovery,  operat-
ing costs,  and interest) of about $620 million would
be required  to  sustain  the program. In addition,
administrative  expenses of about $20 million annu-
ally for Federal and State regulatory programs would
be necessary.

-------
                                        ISSUES OF IMPLEMENTATION
                                                                                                         27
                                                 TABLE 8
                    COST ASPECTS (IN MILLIONS OF DOLLARS) OF AN EPA SCENARIO OF A
                           NATIONAL HAZARDOUS WASTE MANAGEMENT SYSTEM
Cost per unit
Item
On-site facilities
Off -site facilities.
Treatment (large)
Treatment (medium)
Secure disposal
Transport
Total
*Includes capital recovery
' Capital required based on
''. Dollars per ton.
S Transport required for 9
Capital
needed
1.4

86.0
24 1
2.5
'63.0

in 10 years and
new rail rolling

.0 million tons
Annual
operating'-*'
0.73

57.1
12.5
1.2
ill

interest at 7 percent
stock.

(8.25 million metric tons)

needed
51

5
15
5
(*)




of waste, average
Total
capital
required
71

430
362
13
63
' 939



distance from generator
Total
annual
COStA
37

286
188
6
99
616



to treatment
    ty is ii>u miles.
     *' Approximately $25 million has already been invested in current private sector off-site treatment facilities
   For this scenario, system costs fall into five broad
categories: (1) on-site treatment (about 6 percent of
total costs on an annualized basis), (2) transportation
of wastes to off-site treatment facilities (16 percent),
(3) off-site treatment (74 percent), (4) secure disposal
(1 percent), (5) program administration (3 percent).
The largest element of  cost  is  off-site  treatment.
Treatment followed by land disposal of residues is
not necessarily more expensive than direct disposal of
untreated wastes in secure landfills. Treatment before
disposal  would buy greater long-range protection of
public health and the environment.
                    Vana tions
   Although  the above scenario is  reasonable and
would  satisfy  requirements  for  environmentally
adequate hazardous  waste  management, it is not
presented as  a hard-and-fast specification of what a
national  system should look like There is no single
optimum system given such uncertainties as hazard-
ous  waste generator  response  to  air,  water,  and
hazardous  waste  regulations;  future  directions in
production and waste processing technology, timing
and level of enforcement, and public reaction to site
selection decisions. However, some comments can be
made about  variations in the system scenario  pre-
sented.
   It  is  unlikely  that more  large-scale and fewer
medium-scale   processing  facilities  would  be  con-
structed  unless specifically  mandated.  The higher
initial  capital  investment  of large-scale  processing
facilities  is  warranted  only  where  large  market
potential  exists, i.e.,  in  the major industrial regions
At  present,  addition  of only two more  large-scale
facilities (over the five in the scenario) would provide
sufficient capacity to treat all nonradioactive hazard-
ous wastes. Stated another way, two more large-scale
facilities could handle all the wastes  for  which 15
medium-size  facilities were postulated in the scenario
However, resulting increased  costs of transportation
from generators  to  these  larger treatment facilities
(because average  transport distances would increase)
would offset cost reductions due to better economies
of scale (Figures 3 and 4). The net result would be a
significant loss in convenience and increase in trans-
portation risks for  a fairly  insignificant  saving  in
capital cost and a higher  operating cost.
   Construction of a  larger number of medium-  or
small-scale plants (and consequently  fewer large-scale
plants) tends to drive capital costs up sharply (Figure
3).  Total system operating costs also rise because
transportation cost savings are not sufficient to offset
lost  economies of scale (Figure  4). Transportation
risk  would decline because of shorter haul  distances,
but inspection and enforcement costs would increase
because  of the larger number of plants  requiring
surveillance.  As will be discussed, however, a private
sector system may consist of more smaller plants and
thus may result in higher total costs.

-------
28
                                         DISPOSAL OF HAZARDOUS WASTES
      2,800
      2,400
      2,OOO
      1,600
  i  1,200
  ui
  h
  Ul
  O
  O
        800
       400
               L - LARGE FACILITY, PROCESSING  1,330,000 tons (1,210,000 metric tons) per year
               M  -MEDIUM FACILITY, PROCESS ING 162,000 tons (147,000 metric tons) per year
               S - SMALL FACILITY, PROCESSING 33,300 tons (30,200 metric tons) per year
                                                               40M 4
                                                                76S
                                                                                                          27 3S
                                                                        20M t
                                                                         176S
6L +
 7M
5L <
15M
                  4L +
                  24M
                                                    3L t
                                                    32M
                                    2L +
                                    40M
                                             1L +
                                             48 M
                                                                                56M
                800
                         851
                                  939
                                           1070
                                                    1 176
                                                             1234
                                                                      1392
                                                                               1497
                                                                                        1796
                                                                                                 2246
                                                                                                          2665
                                            INCRFAS'NGI Y SMAL LER FACILITIES
                                                	»_

      Figure 3. Fixed capital cost sensitivity of a national hazardous waste management system to fluctuations in number and size
of facilities. Each configuration includes $71  million for on-site facilities. $13 million for secure land disposal, and from $41 million
to $114 million for new transportation equipment (based on average distance and estimated turnaround time).
      1,400 r—
      1,200 —
   -  1,000  —
   in
   I-
   in
   O
   O
        800
        600
        400
        200
                L = LARGE FACILITY, PROCESSING 1,330,000 tons (1,210,000 metric tons) per year
                M --- MEDIUM FACILITY, PROCESSING  162,000 tons (147,000 metric tons) per year
                S -SMALL FACILITY, PROCESS ING 33,300 tons (30,200 metric tons) per year
                                                                                  273S
                                                                                  (1334)
                                                                         20M ^
                                                                         176S
                                                                         (1 142!
                 OPERATING
                    COSTS
                                           TRANSPORTATION
                                           TREATMENT AND DISPOSAL
                                                               40M t
                                                                 7 65
                                                                (932)
                 7L
                (627)
                 184
                 443
6L +
 7M
(603)
5L +
 15M
(616)
4L 1
24M
(639)
3L +
32M
(677)
                                     2L +
                                     40M
                                     (714)
                                                                       1L +
                                                                       48 M
                                                                      (751)
                                              56M
                                              (788)
                          129
                          474
                                    99
                                   517
                                             67
                                            572
                                                      61
                                                     616
                    56
                                                              658
                                                                        50
                                                                       701
                                                                                 43
                                                                                745
                                                        39
                                                                                          893
                                                                 39
                                                                                                  1 103
                                                                                                           1295
                                             INCREASINGLY SMALLER FACILITIES
      Figure 4.  Operating cost sensitivity of a national hazardous waste management system to fluctuations in number and size of
facilities. Each configuration includes $37 million in annual costs for on-site facilities and $6 million for secure land disposal

-------
                                         ISSUES OF IMPLEMENTATION
                                                                                                          29
   There could be  fewer disposal sites than assumed
in the scenario if land availability and suitability and
public  acceptance  problems arise. This  outcome is
likely  if,  for  instance,  only  arid  lands  with  no
hydrologic connection to surface and ground waters
are  deemed  acceptable  as  disposal  sites; i.e ,  if
disposal  siting standards are extremely strict. Trans-
portation costs would increase somewhat but not
linearly  with  distance. For example,  rail transport
costs are estimated at $35 per ton for 1,000 miles and
$49  per ton for 2,000 miles. Transport risks would be
greater,  but disposal risks and  enforcement  costs
would  decline because fewer sites would  be easier to
monitor.
   On  the  other hand,  as a  policy  decision, the
Government could  allow significantly more disposal
relative to processing. Many more, or  at least much
larger,  disposal sites would be  required  in  this case
since, for instance, approximately a 40-fold increase
in tonnage going  to  secure disposal sites would result
if  processing  were  bypassed altogether. The  total
system capital cost would be reduced since treatment
represents   a  large   capital expense  (Table 9).  If
disposal  siting standards  were  very  strict such that
arid  lands  in  the  Western States  were  the  only
acceptable sites,  transportation  costs would increase
substantially because of the large increase in tonnage
transported over longer distances. In fact, in this case,
annual operating  costs for this "disposal only" option
exceed  annual costs for  the treatment and disposal
system scenario discussed.
   Aside from economic considerations, what is more
important in EPA's judgment is  that the disposal only
option could  significantly increase public health and
environmental risk, perhaps to an unacceptable level,
given the long-term  hazard  of many toxic substances,
particularly if such  substances  are not converted to
relatively insoluble forms prior to disposal. Moreover,
transport risks would undoubtedly increase.

         COST DISTRIBUTION TO USERS
   With  the need for a hazardous waste regulatory
program and a hazardous waste management system
to implement  such  a program, there is the fundamen-
tal   issue of  who  should  pay  for  creation  and
operation of the  system. The two basic options are
that  hazardous waste generators pay or society pays.
                     TABLE 9
  COMPARATIVE COSTS (IN MILLIONS OF DOLLARS)
   OF HAZARDOUS WASTE REGIONAL TREATMENT
              VERSUS  DISPOSAL ONLY
Regional treatment
Item

Treatment'''
Disposal-!
Transportation ^
Total
costs
Fixed
capital
863
13
63
939
Annual
operating
511
6
« 99
616
Disposal only
costs A
Fixed
capital

386
252
638
Annual
operating
_
257
490
747
      *Cost data are from two large secure land disposal sites,
 both in the Western States, with 10 million tons per year of
 untreated  hazardous wastes shipped directly to these sites.
 The average distance  between  waste generators and secure
 land disposal sites is 2,000 miles
      'On-site treatment, 1.0  million tons; off-site  treat-
 ment, 9.0 million tons
      'Secure  land  disposal  regional  treatment,  0.225
 million tons;  disposal only, 10.0 million tons. Secure land
 disposal costs  are based on preliminary Office of Solid  Waste
 Management Programs estimates.
      S Indicated transportation costs  represent a minimum
 because bulk shipment by railroad in 10,000-gallon tank cars
 was assumed for all cases.
      ^ Annual freight charges
This issue hinges  on the principle of equity of cost
distribution and on an assessment of ability to pay.

            Equity of Cost Distribution
   The  usual  aim in  environmental legislation is to
cause costs to be internalized. Costs are internalized
when the generator  pays the full costs of actions for
which he is responsible. In  turn, he can either absorb
the costs ("taxing"  his  stockholders) or pass on the
costs in the price  of his products and services (taxing
those who benefit from  the use of his products and
services). Only those who have a direct relationship to
the generator are  required to pay for the generator's
actions.
   A publicly funded incentive distributes the costs
inequitably by assigning costs incurred by a special
group to the population at large, not in proportion to
the use of waste-related products by that public but
in proportion to income levels.
   The regulatory approach internalizes  the costs of
hazardous waste management. It forces generators to
pay for  such  management  while it ensures that  the
practices are  environmentally  acceptable.  The only

-------
30
                                     DISPOSAL OF HAZARDOUS WASTES
portion of the program's cost that must be borne by
the public as a whole is the small portion devoted to
the actual preparation  of  the  regulations  and their
enforcement, and the management of wastes gener-
ated by the Federal Government.
   The regulatory strategy, therefore, results in equit-
able cost distribution.  Only those institutions and
individuals who benefit  directly from the activities of
hazardous material production  and consumption are
required to bear the costs of waste disposal, and the
costs borne  are directly proportional to the amount
and type of wastes generated. Most hazardous wastes
are generated by  industry and the Federal Govern-
ment rather than municipalities. The strategy adopted
for dealing with  air  and water  pollution from indus-
trial sources  has  been the  regulatory  strategy. Thus,
this approach is  consistent with  the  total thrust of
environmental control efforts.  A subsidy strategy to
industry would represent a new  departure.
   It could   be  argued  that if some  sector of  the
economy  is  unable to bear the costs of a regulatory
program by nature of its institutional situation, fiscal
support of that sector may be justified to enable it to
meet  the regulatory requirements without serious
harm to the economy or interruption of vital services.
   However,  generators  of most hazardous wastes are
either  private, profitmaking industrial  organizations
or  governmental  entities.  Private  corporations  are
capable of accepting the additional costs of environ-
mental  control that  may be imposed by a hazardous
waste regulatory  program.  They  have  the  option of
passing on such costs to their customers or absorbing
the costs by reducing  the  return on  investment to
their owners. Government agencies have  the  usual
capabilities available  to such entities to seek budget-
ary support  for legally mandated activities.  Neither
sector  would fall into the hardship category if it had
to pay  the full costs of its waste generation.

              Analysis of Cost Impacts
   No   detailed  study  has  yet been  performed to
determine the cost  burden of specific hazardous
waste  regulations relative to the sales, costs, invest-
ment levels,  and employment levels of the industrial
sectors that  would  be affected.  Rough  aggregate
calculations  have  been  done for  the  following sec-
tors: chemicals, chemical products, petroleum refin-
ing,  rubber  production,  ordnance,  primary  metal
industries, pulp and paper, and mining. These aggre-
gate calculations indicate that the costs of hazardous
waste management would be roughly equivalent to 1
percent of the value of product shipments. Of course,
the  corresponding  percent  for  some disaggregate
categories may turn out to be much higher.
   A  general principle that recurs  throughout this
report is that the costs of hazardous waste manage-
ment should be  internalized in the  prices of the
commodities whose production  has generated the
hazardous waste.  This principle is consistent with the
President's environmental  messages. The results  of
preliminary  studies do not indicate that hazardous
waste management  costs would cause  drastic indus-
trial disruption.  EPA  is  giving a  high priority  to
detailed  analysis  of the costs and cost impacts  of
hazardous waste management.
               Benefit/Cost Analysis
   Because  of the cost  and  price  impacts  that
hazardous waste  regulations  could  impose, careful
consideration is being  given to benefit/cost  analyses.
Hazardous waste regulations  may  be  said  to  be
"benefit determined"  in  the sense  that  they  cover
situations in which  the benefit to society in the form
of a hazard reduction is shown to be large. Thus, the
first type of benefit/cost comparison is that involved
in placing a hazardous waste on the regulatory list as
a result of demonstrating that some regulatory option
is  preferable to  the  status  quo. The second, and
equally important, type of benefit/cost analysis is the
comparison  of all  the options, each  one involving
different levels of benefit and cost. One  may speak
rhetorically about rendering a  substance completely
harmless,  but in  fact that is only one  option. That
option may have  to be chosen in cases for which the
associated benefits  are large. In other cases, benefit/
cost comparisons may support a different process
alternative. To the extent possible, EPA tends to use
benefit/cost analyses to  explore  the  full  range  of
technological options for each hazardous waste.
        ROLE OF THE PRIVATE SECTOR
   As discussed earlier, processing economics appear
to  favor  off-site treatment  and disposal  in  most
instances. A private hazardous waste services industry
exists  which already  offers off-site  treatment and
disposal services,  but currently available  off-site ca-
pacity is clearly  insufficient to handle  the entire

-------
                                        ISSUES OF IMPLEMENTATION
                                                31
tonnage  of hazardous  waste materials that would
ultimately be brought under control. In light of this,
it  is obvious that off-site capacity must  be signifi-
cantly expanded if environmentally adequate hazard-
ous waste treatment and disposal is to take place.
   EPA believes that  private  industry should and will
respond  to  the proposed regulatory  program,  but
there are a number of questions related to  the nature
of that response:  Will  adequate capacity be forth-
coming7  Can  environmentally sound operations be
assured?  Can reasonable user charges be assured?  Can
the  private  sector provide  long-term care of treat-
ment, storage, and disposal sites? These questions are
taken up in what follows. The general issue of the
Government's role is discussed separately.

                Capacity Creation
   The  central  question  is  whether  a regulatory
program  will result in  sufficient investment in new
capacity by  the private sector. Basic issues of capacity
creation include the availability of investment capital
and  the  willingness to  invest capital in view of the
risks involved, i.e., the factors influencing investment.
Related to the broad question of private investment
are other issues dealing with the availability of trained
manpower  and tho availability  of suitable land for
facility siting.
   Private Investment Sources.  Under a  regulatory
program, capital is likely to be available from at least
three private sources: hazardous waste service firms,
generators, and solid  waste management conglomer-
ates.
   In the initial stages of a regulatory program (e.g.,
the first year), no major new  investments are likely to
be required. Existing service firms will respond to
new demand by increasing their throughput. Soon,
however, demand is likely to outstrip  supply of such
services in  a climate of  vigorous enforcement,  and
new investments will be  required.
   The  ability  of present service  firms to  provide
internal capital and to attract outside investments has
been limited   because  of  generally   poor  earning
records in  the past.  This situation  results from the
absence of  regulatory and  economic incentives for
generators to utilize  their services. Increased regula-
tory  activity,  however,  should  improve  the  fiscal
abilities of these companies  over time by increasing
their rate of facility utilization and (under conditions
of strong demand) by increasing the prices they can
command  for  services.  In  fact, the utilization and
earnings rates  of  most  of these firms have  been
increasing  as industries  respond to water  pollution
control regulation. This  will improve  the ability of
this  industry  to  retain  earnings for investment and
also  its ability to attract outside capital. This source
of capital,  however, is expected to be  limited in the
early years of a regulatory program.
   Two other sectors of the economy, however, are
expected   to  become  more  involved in capacity
creation and to attract substantial investment capital
to the field.
   Major generators of  hazardous wastes (e.g., the
chemical and  metal  industries) will  have a strong
interest in  assuring that off-site facilities will be made
available for their use because off-site handling will be
more economical. These  financially strong organiza-
tions-some of which already  operate treatment and
disposal systems  for their  own use-may enter the
service  field  by  acquisition or other routes or may
underwrite the activities of others by provision of
long-term contracts or use of other devices.
   During  the  past 5  years,  large and financially
strong private  solid waste management "conglomer-
ates" have  emerged, offering management services for
nonhazardous wastes. These organizations have estab-
lished strong lines of credit at attractive interest rates.
Although   most  of these firms lack  the  technical
know-how  to manage hazardous wastes today, they
are likely to acquire know-how and to enter this field
under  the  stimulus of  a regulatory  program in a
logical extension  of their current services to industry.
Some have already  established  a position in this field
by the  acquisition of hazardous waste management
subsidiaries.
   As a result, it  is concluded  that sources of private
capital to build new capacity potentially is available.
This  does   not  mean,  however,  that  it  will  be
forthcoming.
   Factors  Influencing  Investment.  Private  sector
investment in hazardous waste management facilities
entails  significant  risks,  and  these risks generally
increase as the  size  of  the proposed facilities  in-
creases. There are uncertainties regarding waste gener-
ator  response  to air,  water,  and hazardous  waste
regulations; generators  may install  new production
processes which result in  fewer wastes or wastes with

-------
32
                                    DISPOSAL OF HAZARDOUS WASTES
different characteristics, generators may elect to treat
wastes on site  future breakthroughs in processing
technology  may  render  the  proposed  plant  pre-
maturely  obsolete; further  environmental standards
may impact on  the proposed plant, economic forces
may result in geographical shifts in  waste generator
plant locations;  and there are uncertainties relating to
the future activities of competitors.
   These  factors may (1) deter investment of any
kind, (2) lead to  investment in treatment processes
only  for  wastes generated in high  volume  or  for
wastes that are relatively inexpensive to treat, (3) lead
to investment in smaller,  less risky facilities that are
more expensive  to operate on a unit cost basis, or (4)
lead to processing plant siting only in locations where
major industrial  waste sources are assured.
   In view  of  these  uncertainties,  the degree and
timing of private  capital investment  in  new capacity
will  depend  heavily on the quantity of waste regu-
lated and the level and timing of enforcement. Also,
the ultimate private sector network that results may
include many smaller facilities and  therefore repre-
sent,  in the aggregate, a more expensive system than
the scenario depicted.
   Quantity  of  Waste Regulated. Regulations  that
affect  a  significant  tonnage  of waste  will spur
investments more  than regulatory activity aimed at a
small proportion of the Nation's hazardous wastes.
   A regulatory  program is most likely to be aimed at
the control of specific waste compounds rather than
the waste  streams in  which the  compounds occur.
Justification  of regulatory action must  be tied  to
health and  environmental effects,   which  can  be
established most conclusively by studying the effects
associated with specific chemicals.
   Unlike the regulator, the generator must dispose of
and the service firm must manage  waste streams that
may contain a  number of hazardous substances in
mixture.
   Background studies performed  for EPA have pro-
vided  useful  data on the  composition  of waste
streams.  These  data indicate that  regulatory control
of a limited number of the most hazardous substances
could  result in the   treatment  and disposal of a
substantial  proportion of  the  total waste stream.
Several hazardous substances are  usually present in
chemical  and  metallurgical  hazardous  waste  dis-
charges,  and  selective treatment  of one or  two
components of  the waste  does not  appear  to be
economical. Not all hazardous substances  must be
regulated immediately, in other words, to cause most
wastes to be treated and disposed of under controlled
conditions.
   This suggests  that  regulatory activity can  move
ahead  based  on  regulation  of groups  of a  few
substances  at  a  time-in  a manner similar to  that
adopted to  implement the  hazardous effluent  pro-
visions of air and water mandates -while still ensuring
that substantial quantities of hazardous wastes will be
treated.
   Level and Timing of Enforcement.  The key to
capacity creation appears to be vigorous enforcement
of regulations to force the use of existing capacity by
generators.   Enforcement  of  regulations  wherever
possible will impose costs on generators which may
exceed  costs  of  treatment  and  disposal in  new
facilities  more  appropriately  located  relative to
regions of waste generation and will  build pressure for
rapid investments. Such enforcement will also create
incentives  for new  ventures by ensuring markets for
services.
   The regulatory approach most likely  to result in
private investment  would  be  one  that encouraged
incremental additions to capacity by mandating their
use as soon as they are created. The approach should
be  tied to a terminal date  by which  all  regulated
wastes must be managed as mandated.
   The incremental approach has the drawback that it
initially impacts more  heavily on generators that are
near existing treatment and disposal facilities. Thus,
other generators that have no such services available
to them  have a  potential  advantage.  However, this
approach protects the public and the environment as
soon as possible wherever it j's possible.
   The  incremental approach  is  contrasted  to  a
strategy  where  regulations  are  announced at one
point in time but provide some  reasonable time for
creation of capacity nationwide by generators or their
agents before any enforcement takes place. This latter
approach would provide fewer incentives for invest-
ment in  increments of capacity and,  by  bunching
capital demand  in  the  reasonable waiting period,
would also tax  the fiscal capacities  of industry to
respond.  If no capacity is  created by the deadline

-------
                                       ISSUES OF IMPLEMENTATION
                                                33
period, appeals to delay enforcement would be likely.
   In summary, timely investment of private capital
to create capacity is anticipated  if the regulatory
program affects a substantial portion of the Nation's
hazardous wastes and if a vigorous but incremental
enforcement approach  over  time is  adopted. These
conditions will assure an investor that the facilities he
builds will be used, but will avoid excessive demands
on available  capital at the outset of the program.
   Government activity in some fiscal role can poten-
tially speed up timing of investments by private
service firms  where high investment risks  must be
overcome; this  is  discussed later in  more detail. A
governmental fiscal role, however, is also subject to a
number of constraints.
   Availability   of  Manpower.  The  technology of
hazardous waste processing is capital intensive, and a
significant increase in capacity will  require only a
limited  expansion  of labor.  Much of the expertise
required for the expansion of the hazardous waste
management industry already exists in the metallur-
gical and petrochemical industries and the engineering
and construction firms that service these. Similarly,
the skills required at local, State, and Federal levels of
government  are essentially the same  as those neces-
sary  for the  operation of  air and water  pollution
control programs. Capacity creation is not thought to
be constrained by a shortage of manpower under any
reasonable implementation timeframe (for example, 5
years).
   Availability of Land.  Land suitable for the siting
and operation of hazardous waste treatment facilities
has been identified as part of  EPA's  background
studies  (Appendix  F).  There  is  no  shortage of
appropriate   land   for  treatment  facilities  in   the
vicinity  of or immediately within the Nation's major
hazardous waste generation regions.
   Land used for disposal by burial should be secure,
i.e., it should be sealed off  from underlying  ground-
waters by impervious materials. Ideally, such sites
should be located in areas where cumulative precipita-
tion is less than evaporation and transpiration so that
rain cannot  accumulate in the sealed landfills. Such
conditions prevail only in  the western desert  regions.
   Ideal  conditions  for disposal sites need  not be
present if the secure landfill is located near hazardous
waste treatment plants where water accumulations
can be removed from the disposal site and treated in
the plant. Sites with appropriate geological features
are available in areas other than the Western States.
   Probably the most important potential problem
associated  with the land-use aspect of hazardous
waste management is that of public resistance to the
location  of  such  facilities  in their communities.
Although EPA's  public  attitudes  survey indicates
public support of  central treatment and disposal of
hazardous wastes  under controlled  conditions, it is
not at all certain that the public will express the same
attitude when faced with an actual siting decision.
   Although siting problems are anticipated by EPA,
there are indications  that  such  constraints  can  be
overcome. The private hazardous waste management
industry  and  AEC  contractors have been able  to
obtain sites in most cases. Treatment and ultimate
disposal facilities will represent employment in areas
that  are  of necessity  low in population density  (if
sites are chosen to minimize  safety  hazard) and in
need of industrial development.

         Environmentally Sound Operation
   The private sector, following a profit motive, has
incentives to  run  only  as good  a hazardous  waste
management operation as it takes to obtain and keep
business  and  to comply with governmental regula-
tions. Customers may demand more stringent opera-
tions  to  benefit their image  or for legal and  other
reasons, but the private sector hardly can be expected
to go all out  to maximize the environmental sound-
ness of its operations.
   It  is anticipated, however, that  environmentally
acceptable  operation  of  private facilities can  be
assured  by  appropriate  governmental  and  citizen
activities. The basic standards and regulations govern-
ing hazardous waste management operations must not
only be environmentally adequate in themselves but
also  must  provide for effective  administrative and
legal sanctions against potential offenders. Adoption
of appropriate criteria for facility licensing can filter
out candidates who do  not possess  resources  suffi-
cient  to  provide sound  facility construction,  opera-
tion, maintenance, and surveillance. Vigorous inspec-
tion  and enforcement  by Government,  with the
attendant threat of licensing suspension or revocation
actions, can assure  sound operations over time.

-------
34
                                     DISPOSAL OF HAZARDOUS WASTES
   If the regulatory legislation contains provisions for
citizen suits,  which is likely given the trend of recent
environmental  legislation,  citizens  may bring legal
pressure to bear on both the Government and private
industry  to force  compliance with existing Federal,
State, and local regulations.

             Reasonable User Charges
   The issue of whether a private market situation
will result  in reasonable user charges is dependent
upon  quite complex interactions  involving facility
scale and location, risk, competition, and transporta-
tion rates.
   As has  been discussed, significant  economies  of
scale are possible in the processing of toxic waste. To
the extent that such  economies  are  realized and
passed on to users of processing facilities, user charges
will be reasonable. To the extent that economies of
scale are not achieved or that  economies are achieved
but savings are absorbed  as monopoly profits, charges
for the use of processing facilities may be  unreason-
able.
   Unfettered operation of the  market  system may
not result  in the  construction of plants of  optimal
size initially. Because of a desire  to minimize or avoid
the risk  factors  discussed  earlier,  there may be  a
tendency to  build a number of  small, high unit cost
plants  where  one  large  economical plant  would
suffice. On the other hand, although small plants may
result in  higher  unit costs of operation, their  lower
investment requirements may spur competition and
reduce opportunities for monopoly profits. Thus, in
the scenario  described  earlier in which  large plants
with large  investment costs and low operating costs
predominate,  there is  potential  for monopolistic
behavior and, consequently, unreasonably  high prof-
its and user charges. The possibility of monopoly is
increased by the relatively few companies  nationally
which have the resources and  technical qualifications
to enter this field.
   Factors  other than  the risks associated  with large
investments tend to counter  monopolistic behavior,
however. Given the relatively low cost of transport in
comparison  to  processing costs  and  the  relative
insensitivity of transport charges to increase in haul
distances,  tradeoffs  between  transportation  charges
and at-the-plant user charges should result in some
overlap among service regions and thus should stimu-
late  competition.  A second potential limitation on
unreasonably high user charges is the ability of waste
generators  to operate  their  own  waste processing
plants  if projected processing charges appear exces-
sive. Also, the  Federal  Government  could  use  the
processing  and  disposal of  its own  wastes, which
would  be sent to the low bidder on a service contract,
as leverage to keep charges reasonable. The  revenue
and cost  information which the Federal Government
typically requires as part of the procurement process
should itself provide a means of tracking the reason-
ableness  of processing charges on a continuing basis.
   Although  it  is  difficult  to predict  how  these
opposing forces  will operate  under  a free market
situation, there  is no indication at this  time of the
need for  additional Government control (beyond that
derived from  Federal  Government procurement) of
hazardous  waste service charges. Competition  exists
now in  the  general  absence of specific hazardous
waste  regulations,  and additional competition is
anticipated if new  regulatory legislation  is passed.
Overall system costs, even if many small plants are
the rule  (Figure 4), should not be so unreasonably
high that they merit Federal intervention.

                 Long-Term  Care
   As indicated  earlier, some nonradioactive hazard-
ous wastes  cannot be converted to an innocuous form
with presently available technology, and some resi-
dues from waste treatment  processes may  still be
hazardous.  Such materials  require special storage or
disposal and must be controlled for long periods of
time.
   In some respects such materials resemble long-lived
radioactive wastes:  both are toxic and retain essen-
tially forever  the potential for public  health and
environmental  insult.  There  are  differences,  how-
ever:  Nonradioactive hazardous wastes normally do
not  generate  heat  nor do they  require radiation
shielding.
   Until  recently, essentially all  radioactive wastes
were generated by the Federal Government itself as a
result of nuclear weapon, naval propulsion, and other
programs.  This  established a precedent for Federal
control of  radioactive wastes that has  carried over to
the commercial nuclear power generation and fuel

-------
                                        ISSUES OF IMPLEMENTATION
                                                                                                        35
reprocessing industry. No such precedent exists for
nonradioactive  hazardous  wastes  from  industrial
sources.
   AEC  has  established the  policy of  "engineered
storage" for long-lived radioactive wastes because of
difficulties in  assuring long-term control  of these
wastes if they are disposed of on or under the land or
in the ocean. Designs of such storage facilities will
vary with the nature of the wastes involved, but the
general principle is  to  provide long-lived container-
ized, or otherwise separated, easily retrievable storage
units. These units generally will require heat removal,
radiation shielding, surveillance, and security.
   The storage and disposal facility requirements for
nonradioactive hazardous wastes are anticipated to be
less  severe than for radioactive  wastes  since  heat
removal and shielding are not required, but many of
the problems remain. Such facilities  should be secure
in the  sense that there are no hydrologic connections
to surface and ground waters. Long-term physical
security and surveillance of storage and land disposal
sites are required. Also, there  should be contingency
plans for sealing off the facilities or removing the
wastes if hydrologic connections are subsequently
established by earthquakes or other phenomena.
   From an institutional viewpoint, the private sector
is not  well suited  for a role in which longevity is a
major factor. Private enterprises may  abandon storage
and  disposal  sites  because  of  changes in  ownership,
better investment opportunities, bankruptcy, or other
factors  If sites  are abandoned, serious questions  of
legal liability could arise.  This issue led the State of
Oregon,  in its  recently  adopted hazardous waste
disposal program, to  require that  all privately oper-
ated hazardous waste disposal sites be deeded to the
State and that  a  performance bond be posted  as
condition for obtaining a  license  to operate  such a
site.
   Traditionally, waste generators pay a one-time fee
for waste disposal.  If this  concept were  carried over
to hazardous waste  disposal,  private operators  of
disposal sites would have to charge fees sufficient to
cover expenses of site security and surveillance for a
long, but  indeterminant, time period. Another option
would  be to  consider hazardous waste disposal as a
form  of long-term storage. Generators would  then
pay  rent  in perpetuity. Because of such factors as
uncertainties of future market conditions and infla-
tion, neither of these options would appeal to either
the  waste  generator  or disposer,  nor  would  the
options preclude legal problems  if either party were
to file for bankruptcy.
   There are grounds, therefore,  to consider the role
of the private  sector in  hazardous waste storage and
disposal as fundamentally different in character from
its role in  hazardous waste treatment  EPA believes
that, given a regulatory stimulus, the private  sector
can and will provide necessary facilities for hazardous
waste  treatment  that are operated  in  an  environ-
mentally sound manner with reasonable user charges.
However,   the  issue  of  long-term care  of privately
owned and operated hazardous  waste  storage and
disposal  sites poses significant problems  not  easily
resolved. Some form  of Federal or State intervention
may be required.

            ROLE OF GOVERNMENT
   The implementation strategy described assigns to
Government the limited role of promulgating and
enforcing  regulations.  In view of the potential prob-
lems discussed, however, a more extensive  Govern-
ment role  may be justified  under certain  circum-
stances.  Options  for more  extensive  Government
intervention  which might be determined to be  re-
quired include  performance bonding, financial assis-
tance, economic regulation, use of Government land,
and  Government   ownership  and  operation  of
facilities

               Performance Bonding
   The  Government  could  require  a  performance
bond of private firms as  a  condition  for issuing a
license or  permit  for operation  of hazardous waste
treatment or disposal facilities. The bond would help
to ensure  environmentally sound operation  of proc-
essing  facilities and long-term care of disposal sites.
This system is used,  for example,  by the State  of
Oregon for all  hazardous waste disposal sites and  by
the State of Kentucky for radioactive waste  disposal
sites.
   Performance bonding presents a paradox, however.
The bond must be large to be effective, but the larger
the bond, the more likely it is to inhibit investment.
Used unwisely,  the performance bond concept could

-------
36
                                     DISPOSAL OF HAZARDOUS WASTES
result in no  private sector facilities or in a monop-
olistic  situation  with a very limited number of large
firms in the business.
   EPA believes that a performance bonding system,
wisely  applied, could be beneficial in establishing the
fiscal soundness of applicant firms. (If fiscally weak,
the firm could not be bonded.) The bonding system
could be adopted within a regulatory program in the
licensing procedures with very little, if any,  cost to
Government.

                Financial Assistance
   Some form of fiscal support of capacity creation
may be justified  if the private sector fails to invest the
capital  needed  for  new  facilities.  If  that happens,
environmental damage will continue and the potential
hazard to public health and safety will increase.
   Current indications  are that  private  capital will
begin to flow under a regulatory approach. It may be
argued,  however, that  capital  flow may be slow and
uneven  on a national basis. In  some areas capacity
may be created,  in  others not. Investors might play a
wait-and-see game  because of  potential risks, etc. In
such a  situation governmental fiscal support might
speed up implementation or ensure that all generators
have facilities available for use.
   A governmental  fiscal  role  in  capacity creation is
not  warranted-on  equity and  other  grounds dis-
cussed  earlier-unless  capital  flow  is actually very
slow and adverse environmental effects are resulting
from the investment rate. If  support is  warranted,
various  types of support  are likely to have different
effects.
   Indirect  Support.  A  loan  guarantee  program,
probably  the most  indirect form  of  fiscal support
available,  may  be   more effective  in  speeding  up
implementation  than direct, massive support of con-
struction. If capital is available (in the absolute sense)
but  is  not  obtainable  practically  because  of risks
associated with  investments in such ventures,  a loan
guarantee program can induce  investments by remov-
ing or  cushioning the risk. At the same time,  such a
program would  be  less vulnerable  to  budgetary
constraints and  less likely to lead to a slowdown in
private investments  than direct support.
   A loan program, while preferable to direct support
on  equity  grounds, would depend on budget avail-
ability  and would act to slow down implementation.
   Other  indirect  approaches,  such as investment
incentives  based  on  investment credits  or  rapid
writeoff provisions, are comparable to a loan program
in that they have a budgetary impact (by  affecting
Government tax income) but would be less likely to
slow down implementation because no positive budg-
etary action would  be required to  implement such
support.
   These approaches, much like direct support, would
be  difficult  to justify  for  a  part  of  the Nation
only- that is, to support building of capacity only in
areas  where  private  action  is  not  resulting  in
construction.
   Direct  Support.  Direct fiscal support might con-
ceivably  take the form of  construction  grants  or
direct  Government construction of facilities. Such
action can ensure capacity creation.  Programs of this
type, even  in  the environmental area, have  often
failed  to meet originally established  timing goals
because of  budgetary  constraints and other factors.
To the extent  that local government involvement is
sought in a Federal  program, a further potential for
delay is introduced. The availability of public funding
also has a stifling effect on  private initiative. It is
economically unwise to invest private money if public
funds are available.
   This approach, while it can guarantee that ulti-
mately capacity will be built, does not promise to be
effective  in  speeding  up  the  implementation rate.
Where the objective is  to provide capacities in regions
where investments are  lagging, direct fiscal support is
extremely difficult to justify for only one area to the
exclusion of others.
   The advisability  of  Government  construction
support  may  also be viewed in  the  context  of
Government competition  with private industry. A
fledgling service industry exists. These firms would
object to the entrance of the Government into  the
field  as a competitor  (direct Government construc-
tion) or Government  action  to set up competition
(grant programs). To the extent that  private resources
have already been committed  to this field, great ca-e
would have to be exercised to avoid driving existing
firms out of the market with the resultant economic
loss to the Nation.  It may  be necessary on equity
grounds  to  compensate existing companies for their
investments-by outright  purchase  or post-factum
grant  support.  Determining  the   value  of  these

-------
                                       ISSUES OF IMPLEMENTATION
                                                37
companies' investments may be difficult  in the face
of probably increasing demand for their services.
               Economic Regulation
   The  Congress could mandate a hazardous  waste
management  system patterned after the public utility
concept. In this type  of system, Government  could
set up franchises with territorial limits and regulate
user charge rates.
   The  hazardous  waste management field  shares
many characteristics of currently regulated industries
in any case. There are public service aspects, relatively
few plants are required per region, and these facilities
are capital intensive. Further, there is  potential for
natural  geographic monopolies because barriers to a
second entrant in a given region are high.
   Government  control  of  plant  siting,  scale, and
rates  could lessen  the potential for environmental
impacts  and provide  greater incentive for private
sector investment since there would be no threat of
competition and consequently less risk  of failure. On
the other hand, some  companies may not enter the
field on a utility basis because  of potentially lower
rate  of return on investment.  Further,  lack  of
competition   could  inhibit  new   technology
development.
   Economic restrictions  can  be  applied directly
through  a governmental  franchise board or commis-
sion or  indirectly through administrative actions such
as licensing and permitting.  Government  control of
franchising shifts the burden of market determination
and related business decisions into the public sector,
which is not inherently better equipped to make such
decisions than is private industry.
   Licensing and permitting of treatment and disposal
facilities appear  to be  better  approaches for  the
exercise  of economic control since they can be  used
to  influence  (rather than dictate) plant  locations,
sizes,  and rates. Some  form  of  Government control
over such facilities  is desirable in any case to ensure
their proper operation.
   Administrative   rather  than direct  regulatory
actions  would  be  less costly to Government.  New
legislation  would  be  required  to  authorize  either
direct or indirect economic sanctions.
           Use of Federal or State Land
   Although suitable sites for hazardous waste  proc-
essing facilities  are  generally available  to  the private
 sector,  adverse  public reaction  to such  sites may
 preclude their use. If this occurs, it may be necessary
 to make public lands available to private firms. These
 lands could  be  leased or  made  available  to  private
 firms.  These lands could be leased or made available
 free of charge, depending on circumstances. As noted
 earlier,  the  State of Oregon requires that hazardous
 waste facilities be located on State-owned land; other
 States may elect to follow this precedent.
   There are compelling reasons for the use of public
 lands for hazardous waste disposal sites. The need for
 long-term care  of  disposal  sites  and the potential
 problems associated with private sector ownership of
 such  sites have  been  discussed previously. Publicly
 owned  disposal  sites  could  be  leased  to  private
 operating firms,  but legal  title would remain with the
 governmental body.
   Use  of  Federal  or State lands  for  privately
 operated hazardous waste processing or disposal sites
 is one  means of reducing the capital cost and risk of
 private  sector investment  while  reducing environ-
 mental  risk  as   well.   Conceivably, some form  of
 Government influence over user  charges could be a
 condition of  the lease, in  order  to avoid potential
 monopolistic behavior on the part of the lessee. The
 initial  cost to Government  of these measures would
 be  minimal; however,  Government maintenance  of
 disposal sites may be necessary if the lessee defaults.

  Government Ownership and Operation of Facilities
   The  option of Government ownership and opera-
 tion of facilities provides maximum control over the
 economic and environmental  aspects of  hazardous
 waste management. The issues of potential monop-
 olistic  behavior  (and  consequent  unreasonably high
 user charges) and long-term care of hazardous waste
 disposal sites   could   be  circumvented.   Environ-
 mentally sound  construction and  operation of proc-
essing  and disposal  facilities  could be  assured but
 would   be dependent  on  public budgets for  imple-
 mentation. Resource recovery could be mandated.
   Public lands  suitable for hazardous  waste proc-
 essing and disposal  sites exist in  the Western States
but may not be available in the Eastern States.  If
Government  ownership and operation of facilities is
mandated by Congress, the Government may have  to
 purchase private lands  for this purpose The potential
for adverse public reaction would be present.

-------
38
                                     DISPOSAL OF HAZARDOUS WASTES
   The  Government does  operate some hazardous
waste treatment, storage, and disposal facilities now,
but  these are generally  limited to handling  wastes
generated by  Government  agencies. There  is  no
obvious advantage of Government  operation of facil-
ities intended  to  treat  and  dispose of hazardous
wastes originating in the private sector. In fact, under
Government operation, there could be a tendency for
selection  of more  expensive  technology than is
actually  required and  less  incentive for efficient,
low-cost operation.
   This option  represents,  of course,  the maximum
cost to Government of those considered here. If  use
of  Government-owned  and  Government-operated
facilities is mandated, capital and operating costs of
processing  plants can be  recovered through user
charges. Some subsidy of disposal operations is likely,
however, since  security and  surveillance of disposal
sites are required in perpetuity.
                   SUMMARY
   For a hazardous waste regulatory  program, issues
of  implementation  of  a nonradioactive hazardous
waste management system hinge on the incentives for
and inherent problems of private sector response and
the appropriate  role of Government. Past experience
with air and water environmental  regulation over
industrial processes indicates that  the private sector
will invest in pollution control facilities if regulations
are vigorously enforced. EPA anticipates that  similar
private sector investment in hazardous  waste proc-
essing facilities will be forthcoming if a regulatory
program  is legislated and enforced.  There is no real
need for massive Government intervention or invest-
ment in  such facilities. The makeup of  a hazardous
waste processing  system fully prescribed by free
market forces is difficult to predict, however.
   The storage and ultimate  disposal of hazardous
residues  presents a significant problem  of basically
different character since the private sector is not well
suited to a role of long-term care of disposal sites.
Options  for Government action to mitigate this
problem  include (1) making new or  existing Federal-
and  State-owned  and  Federal- and State-operated
disposal sites available  to private industry; (2) leasing
Federal or State lands to the private sector, subject to
a performance bonding system, (3)  allowing  private
ownership and operation of storage and disposal sites,
subject   to  strict  Federal or  State  controls. The
optimum control scheme will depend upon the nature
of  the  regulatory  program,  but  Federal or State
control  of storage  and land disposal sites is  clearly
implied in any case.
   On balance, EPA believes that, with  the possible
exception noted, the  preferred approach to  system
implementation is to allow the private sector  system
to evolve under appropriate regulatory  controls,  to
monitor  ciosely  this evolution, and  to take remedial
governmental action if necessary in the future.

-------
                                           Section 5
                     FINDINGS AND RECOMMENDATIONS
                   FINDINGS
   Under the authority  of Section 212 of the Solid
Waste Disposal Act, as amended, EPA has carried out
a study of the hazardous waste management practices
of industry, Government, and other institutions  in
the United States. The key findings of this study are
presented in this section.
   Current   management  practices  have   adverse
effects.  Hazardous  waste management practices  in
the United States are generally inadequate. With some
exceptions,  wastes  are  disposed  of  on the  land
without adequate  controls and safeguards. This situa-
tion results in  actual and potential damage  to the
environment and endangers public health  and safety.
   Causes of inadequate management are economics
and  absence of legislative  control The causes  of
inadequate hazardous waste management are twofold.
First,  costs  of treating  such  wastes  for   hazard
elimination and of disposing of them in a controlled
manner are high. Second, legislation which mandates
adequate treatment and disposal of  such wastes  is
absent or  limited in scope. The consequence is that
generators of hazardous wastes can use low-cost but
environmentally  unacceptable  methods of handling
these residues.
   Authorities for radioactive  wastes are adequate.
Under the  authority of  the Atomic  Energy Act  of
1954, as amended,  the  management of  radioactive
wastes is placed under  control. Although the actual
implementation of  the  act  may be improved, the
legislative tools for  accomplishing such an end exist.
   Air and  water pollution  control authorities are
adequate. The Clean Air  Act of 1970 and the FWPCA
of  1972 provide  the necessary authorities  for the
regulation of the  emission of hazardous compounds
and  materials to the air and to surface waters from
point sources.
   Legislative  controls over  hazardous waste land
disposal are inadequate.  The legislative  authorities
available for the control  of hazardous waste deposi-
tion on land-and  the consequent migration of such
wastes into the air and water media from land-are
not  sufficient to  result  in  properly  controlled
disposal. This legislative gap literally invites the use of
land as the ultimate sink  for materials removed from
air and water.
   Land protection regulation is needed. In order to
close the  last  available  uncontrolled sink  for  the
dumping of hazardous waste materials and thus to
safeguard  the  public and  the environment,  it is
necessary to place legislative control over the disposal
of hazardous wastes.  In the absence  of such control,
cost considerations and  the competitive posture of
most generators of waste will continue to  result in
dangerous  and harmful  practices with  both short-
range and long-term adverse consequences.
   The technology for hazardous waste management
generally is adequate. A wide  array of treatment and
disposal options is  available for management of most
hazardous  wastes. The technology is in use today,  but
the  use is not widespread  because of economic
barriers in  the absence of legislation. Transfer and
adaptation of existing technology to  hazardous waste
management may be necessary in some cases. Treat-
ment technology  for  some hazardous wastes is  not
available (e.g., arsenic trioxide and arsenites  and
arsenates of copper,  lead, sodium, zinc,  and potas-
sium).  Additional  research and development is re-
quired as the national program evolves. However, safe
and controlled storage of such wastes is possible now
until treatment and disposal technology is developed.
   A private  hazardous waste management  industry
exists. A small service industry has emerged in the  last
decade offering waste treatment services to industry
                                                  39

-------
40
                                    DISPOSAL OF HAZARDOUS WASTES
and  other  institutions.  This industry is  operating
below capacity  because  its services  are high in cost
relative to other disposal options open to generators.
The  industry is  judged  capable of expanding  over
time to accept most of the Nation's hazardous wastes.
   Hazardous waste management system  costs  are
significant.  Estimates  made by  EPA indicate  that
investments  of  about $940 million and  operating
costs  (including  capital recovery)  of about  $620
million  per  year  will be  required  to implement a
nationwide  hazardous  waste  management  system
which  combines  on-site  (point of generation)  treat-
ment  of some wastes,  off-site (central facility)  treat-
ment  for hazard elimination and recovery, and secure
land disposal of  residues  which  remain hazardous
after treatment.
   The private sector appears capable of responding
to a regulatory program. Indications are that private
capital will be available  for the creation of capacity
and that generators of waste will be able to bear the
costs  of management under new and more exacting
rules.  Private sector response to a demand created by
a  regulatory program  cannot be well defined, how-
ever,   and   the   characteristics   of  the   resulting
hazardous  waste  management  system  cannot  be
definitely  prescribed.  Uncertainties inherent  in a
private  sector system  include availability of capital
for facility construction and operation  in  a timely
manner for all regions of the Nation, adequacy of
facility  locations relative to waste generators such as
to minimize environmental hazard and maximize use,
reasonableness of facility use charges in relation to
the cost of services, and  long-term care of hazardous
waste storage and disposal facilities (i.e., such  facil-
ities  will  be adequately  secured for the life of the
waste,  irrespective of economic  pressures on private
site operators).
   Several  alternatives for Government  action  are
available if such actions are subsequently determined
to be required:  If capital flow was very slow and ad-
verse environmental effects were resulting from  the
investment rate, financial assistance would be possible
in indirect forms such as loans, loan guarantees,  or
investment credits,  or direct forms such  as construc-
tion grants. If facility location or user charge problems
arose, the Government could impose a franchise sys-
tem with territorial  limits  and user  charge  rate con-
trols. Long-term care of hazardous waste storage and
disposal facilities could be assured by mandating  use
of Federal or State land for such facilities.
              RECOMMENDATIONS
   Based  on the findings,  it is recommended that
Congress enact  national  legislation  mandating safe
and environmentally sound hazardous waste manage-
ment.
   EPA has  proposed such legislation  to Congress,
embodying  the  conclusions of studies  carried  out
under Section 212 of the Solid Waste Disposal Act
   The proposed Hazardous Waste Management Act
of 1973 calls for authority to regulate the treatment
and disposal  of  hazardous wastes.  A  copy of  the
proposed  act is presented in  Appendix  G.  The key
provisions of the proposed legislation are the follow-
ing: (1) authority to designate  hazardous wastes  by
EPA; (2) authority to regulate treatment and disposal
of  selected waste categories by the  Federal Govern-
ment at  the discretion of the  Administrator of EPA,
(3) authority for the setting of Federal treatment and
disposal standards for designated waste categories; (4)
State  implementation  of  the  regulatory  program
subject  to  Federal  standards  in  most cases;  (5)
authority for coordination and conduct of research,
surveys, development, and public education.
   EPA believes  that no further Government  inter-
vention  is  appropriate  at this time.   It  is EPA's
intention to carry on its studies and analyses; EPA
may make further recommendations based  on these
continuing analyses.

-------
                                       Appendix  A

  IMPACT  OF IMPROPER HAZARDOUS WASTE MANAGEMENT
                               ON THE ENVIRONMENT
   Improper management of hazardous materials or
wastes is manifested in  numerous ways. Waste dis-
charges  into  surface waters can decimate  aquatic
plant  and animal life.  Contamination of land and
groundwaters  can result  from improper  storage and
handling techniques, accidents in transport, or  indis-
criminate disposal acts
   A  few of  the  many  cases documented by  EPA
which illustrate hazardous waste mismanagement are
listed  categorically in the  following compilation. Most
of these examples are water pollution related because
there  have  been more monitoring and enforcement
actions in this area
         WASTE DISCHARGE HAZARDS
            Improper Arsenic Disposal
   Because  of the lack  of  treatment and  recovery
facilities, arsenic  waste  materials generally are dis-
posed of by  burial. This  practice  presents future
hazards since the material is not rendered harmless.
   As  a  result  of arsenic  burial  30  years  ago on
agricultural  land in Perham, Minnesota, several people
who recently  consumed  water contaminated by the
deposit  were  hospitalized. The water came from  a
well that was drilled near this 30-year-old deposit of
arsenic material. Attempts to correct  this contamina-
tion  problem are  now  being studied.  Proposed
methods of approach include (1)  excavating the
deposit  and contaminated  soil and  diluting it by
spreading  it  on  adjacent   unused  farmland, (2)
covering  the   deposit  site  with  a  bituminous or
concrete apron to prevent groundwater leaching, (3)
covering  the deposit temporarily and excavating the
soil for use  as ballast in future highway construction
in the area,  (4) excavating the material and placing it
in a registered landfill.  None  of these  methods is
particularly acceptable since the hazardous property
of the material is  not  permanently eradicated, but
they at  least protect the public health and safety in
the short run.
               Lead Waste Hazard
   Annual production of  organic lead waste from
manufacturing  processes for alkyl  lead in the San
Francisco Bay  area amounts to 50 tons (45.4 metric
tons). This waste was previously disposed of in ponds
at one  industrial waste disposal site. Attempts to
process  this waste for recovery resulted in  alkyl lead
intoxication  of plant employees in one instance, in
another   instance, not only  were plant  employees
affected, but employees of firms in the surrounding
area were exposed to an  airborne  alkyl  lead vapor
hazard.  Toll collectors on a bridge along  the  truck
route to the plant  became ill  from escaping  vapors
from transport trucks. Currently, the manufacturers
that generate  organic lead waste  are storing this
material  in  holding  basins at the  plants pending
development of an acceptable recovery process.
           Cyanide and Phenol Disposal
   A firm in Houston, Texas, as  early as  1968 was
made aware that its  practice of discharging such
hazardous wastes as cyanides (25.40 pounds per day,
or 11.5  kilograms per day), phenols (2.1 pounds per
day, or  0.954  kilogram  per day),  sulfides,  and
ammonia into the Houston ship channel was creating
severe environmental debilitation. The toxic wastes in
question are  derived  from  the  cleaning  of  blast
furnace  gas from coke plants. According  to expert
testimony, levels as low as  0.05 milligram per liter of
cyanide  effluent are known to be lethal to shrimp and
small fish of the species found in the Galveston Bay
area.
                                                 41

-------
42
                                    DISPOSAL OF HAZARDOUS WASTES
   Alternative disposal  methods  involving deep-well
injection  were recommended by the firm and  the
Texas  Water  Quality   Board.   EPA  rejected  this
proposal and the film in question  was enjoined by the
courts to cease and  desist  discharging these  wastes
into the  ship channel. Subsequently, the courts have
ruled in  favor of EPA  that deep-well injection of
these wastes is not  an  environmentally  acceptable
disposal method at this site.
              Arsenic Contamination
   A chemical company in Harris  County, Texas, that
produce",  insecticides,   weed  killers,  and   similar
products  containing  arsenic has been involved in
litigation  over the discharge of arsenic waste onto the
land and adjacent waters. Charges indicate that waste
containing excessive arsenic was  discharged into, or
adjacent  to, Vmce Pay'': causing arsenic-laden water
drainage  into pubh.  u  urs. This company  and its
predecessor  have  a long history of plant operation at
this site.  Earlier, waste disposal was accomplished by
dumping the waste solids in open pits and ditches on
company  property. This practice was abandoned in
1967 in  favor  of  a proposed  recycling process.
However,  as of August 1971, actions were taken on
behalf of the county to  enjoin manufacturing opera-
tions at the plant because of alleged excessive arsenic
discharge  into the public waters. No other informa-
tion is available regarding the current status of court
actions or disposal practices.
               Insecticide Dumping
   Mosco  Mills, Missouri.  In mid-1970, an applicator
rinsed and cleaned a truck rig after dumping unused
Endrin into  the Cuivre River at Mosco Mills, Missouri.
This  act  resulted in  the   killing of an  estimated
100,000 fish, and the river was closed to fishing for 1
year by the Missouri Game and Fish Commission.
   Waterloo, Iowa.   In mid-1972, a chemical  manu-
facturing  company  in Waterloo,  Iowa, burned tech-
nical  mevinphos  (phosdrin), resulting in  gross con-
tamination  to the plant area. Approximately 2,000
pounds   (908  kilograms)  of previously  packaged
material  were dumped  and left  for  disposal. After
discussion with EPA Region VII office personnel and
apph priate  Iowa agencies,  the area  was neutralized
with alkali and certain of the materials were repack-
aged  for  disposal  by  a  private hazardous  waste
disposal firm in Sheffield, Illinois.
              Trace Phenol Discharge
   During  1970,  the Kansas  City,  Missouri, water
supply contained objectionable tastes and odors due
to a phenolic content. It was alleged, and subsequent
investigation indicated, that fiber-glass waste dumped
along the river bank upstream was the source of the
tastes and  odors. The waste was coated with phenol
and was possibly being washed into the river. Action
was taken to have the dump closed and sealed.

     Discharge of Hydrocarbon Cases Into River
   In July 1969, an assistant dean at the University of
Southern  Mississippi died of  asphyxiation while
fishing in a boat in the Leaf River near Hattiesburg,
Mississippi. The victim's boat drifted into a pocket of
propane  gas that reputedly had been discharged  into
the river through a gasline  terminal wash pipe from a
petroleum refinery.

                Cyanide Discharge
   Part of the Lowry Air Force Base Bombing Range,
located  15 miles  (24.1 kilometers)  east  of  Denver,
was declared surplus and given to Denver as a landfill
site. As of July 1972, the  Lowry site was accepting,
with the exception of highly radioactive wastes, any
wastes delivered without inquiry  into  the contents
and  without  keeping anything more than informal
records of quantities delivered.
   Laboratory tests of surface drainage have indicated
the presence of cyanide in  ponded water downstream
from the  site. Significant amounts of cyanide are
discharged in pits at the disposal site, according to the
site  operator.  Short-lived  radioactive wastes from a
nearby  medical  school and a  hospital are  also
accepted at this site. These wastes are apparently well
protected but are  dumped directly into the disposal
ponds rather than being buried separately.
   The  Denver County commissioners  received  a
complaint  that some cattle had died as the result of
ingesting material  washed downstream from this site.
Authorities feel  this  occurred  because  of  runoff
caused by an overflow of the disposal ponds  into
nearby Murphy Creek after a heavy rainstorm.
    Arsenic Dump: Groundwater Contamination
   A laboratory company in the north-central United
States has been utilizing the same dump site since
1953 for solid waste disposal. Of the total amount
(500,000 cubic feet or 14,150 cubic meters) dumped

-------
              IMPACT OF IMPROPER HAZARDOUS WASTE MANAGEMENT ON THE ENVIRONMENT
                                                                                                     43
as of 1972, more than half is waste arsenic. There are
several superficial monitoring  wells  (10 to  20 feet
deep or 3.05 to 6.10 meters deep) located around the
dump site. Analyses of water samples have produced
an arsenic content greater than 175 parts per million.
The  dump site is located above a limestone bedrock
aquifer, from which 70 percent  of the nearby city's
residents  obtain  their drinking  and  crop irrigation
water. There are some indications that this water is
being contaminated  by arsenic seepage through the
bedrock.
          Poisoning of Local Water SuppJy
   Until approximately  2 years prior to June 1972,
Beech Creek, Waynesboro, Tennessee, was considered
pure enough  to be a source of drinking water. At that
time,  waste  polychlonnated biphenyls (PCB)  from a
nearby  plant   began  to  be  deposited  in  the
Waynesborc city dump site. Dumping continued until
April 1972.   Apparently  the waste,  upon  being off-
loaded at  the dump,  was pushed  into a spring branch
that  rises  under the dump and  then empties into
Beech Creek. Shortly after depositing of such wastes
began, an  oily substance appeared in the Beech Creek
waters.  Dead fish,  crawfish,  and  waterdogs were
found, and supported wildlife also was being affected
(e.g.,  two raccoons were found  dead). Beech  Creek
had been  used for watering stock, fishing, drinking
water,  and  recreation  for  decades.  Presently,  the
creek seems to be affected for at least 10 miles (16.09
kilometers)  from  its source  and the  pollution  is
moving steadily  downstream to the Tennessee  River.
Health officials have  advised that the creek should be
fenced off to prevent cattle from drinking the water.
   MISMANAGEMENT OF WASTE MATERIALS
   In  the  presence of locally imposed  air  and water
effluent restrictions and prohibitions, industrial con-
cerns  attempt  to  manage  disposal problems  by
storage,   stockpiling,  and  lagooning.   In   many
instances,  the waste quantities  become excessive and
environmental perils evolve  as a result of leaching
during flooding  or  rupturing of storage lagoons.
Reported  instances of this type of waste management
problem are shown in the following.
                     Fish Kill
   On June  10,  1967, a dike containing an alkaline
waste lagoon for a steam generating  plant at  Carbo,
Viigmia,  collapsed and  released  approximately 400
acre-feet (493,400 cubic meters) of fly ash waste into
the  Clinch  River.  The resulting contaminant slug
moved at a rate of 1 mile per hour (1.6 kilometers per
hour) for several days until it reached Norris Lake in
Tennessee, whereupon, it  is estimated to have killed
216,200 fish.  All food  organisms in  the  4-mile
(6.43-kilometer) stretch of river immediately below
Carbo  were  completely eliminated. The practice of
waste  disposal  by lagooning is a notoriously inade-
quate  method  which  lends  itself to negligence and
subsequent mishaps.
               Phosphate  Slime Spill
   On  December  7, 1971, at a chemical plant site in
Fort Meade, Florida, a portion of a dike forming a
waste pond ruptured, releasing an estimated 2 billion
gallons (7.58  billion  liters)  of  slime  composed  of
phosphatic clays and insoluble halides into Whidden
Creek.  Flow patterns of the creek led to subsequent
contamination of the  Peace River and the estuarine
area of  Charlotte  Harbor. The water of  Charlotte
Harbor took on  a thick milky  white appearance.
Along  the river, signs of life were diminished, dead
fish were sighted,  and normal surface fish activity was
absent. No living  organisms  were found in Whidden
Creek downstream of the spill or in the Peace River at
a point 8 miles downstream  of Whidden Creek. Clam
and  crab gills were  coated with the  milky substance,
and in  general all  benthic aquatic life was affected in
some way.
 Mismanagement of Heterogeneous Hazardous Waste
   A firm engaged in the disposal of spent chemicals
generated in the  Beaumont-Houston area ran into
considerable opposition in Texas and subsequently
transferred its  disposal operations  to  Louisiana.  In
October 1972, this  firm was storing and disposing of
toxic  chemicals  at two  Louisiana  locations: De
Ridder and De  Quincy. At the De Ridder site, several
thousand  drums   of   waste  (both   metal-  and
cardboard-type, some with  lids  and some without)
were piled up at the end  of an airport runway apron
within  a pine  tree seed orchard. Many of the drums
were popping their lids and leaking, and visible vapors
were emanating from the area. The  pine trees beside
the storage area had died.  At the same time, the firm
was  preparing to bury hundreds of drums of hazard-
ous  wastes  at the De Quincy location,  which is
considered   by   EPA   to  be  hydrogeologically

-------
44
                                    DISPOSAL OF HAZARDOUS WASTES
unsuitable  for  such  land  disposal. Finally,  court
action enjoined this firm from using the De Ridder
and De Quincy sites; however, the company has just
moved  its  disposal  operations near Villa  Platte  in
Evangeline Parish, where the same problems exist.
              Arsenic Waste Mishap
   Since August  1968,  a  commercial laboratory  in
Myerstown,  Pennsylvania,  has disposed of its arsenic
waste by surface  storage within the plant area (form
of waste materials not known). This practice appar-
ently  has led to  contamination of the ground and
subsequent  migrations  into  groundwaters  through
leaching, ionic migration actions, etc., abetted by the
geologic and edaphic character of the plant site.  In
order   to   meet    discharge   requirements  and/or
eliminate the waste hazard, the company has had to
design and  construct a  system of recovery wells  to
collect the arsenic effluent  from groundwaters in the
area.  Recovered  arsenic and  current arsenic waste
(previously stored on the  land) are now retained in
storage  lagoons.  Presumably,  the sludge from  these
lagoons  is  periodically reclaimed  in  some  way.
Lagoons of  this type are generally not well attended
and frequently result in environmental catastrophes.

               Contaminated Grain
   Grant County,  Washington.  In 1972,  mercury-
treated  grain was  found at  the Wilson Creek dump in
Grant   County,   Washington,  by   an  unsuspecting
farmer.  He hauled it to his farm for livestock feed.
The  episode was discovered  just before the farmer
planned to utilize the grain.
   Albuquerque, New Mexico.  Three children in  an
Albuquerque, New Mexico, family  became seriously
ill, in 1970, after  eating a  pig that had been fed corn
treated  with  a  mercury   compound.  Local health
officials found several bags of similarly  treated corn
in the community dump.
                Radioactive  Waste
   Low-level radioactive waste is lying  exposed  on
about 10 acres (4.05 hectares) of ground in Stevens
County, Washington, and is subject to wind erosion.
The  waste comes from an old uranium processing
mill.  County and  State  officials are concerned
because, although it is of low radioactivity  level, it is
the same type that caused the public controversy at
Grand Junction, Colorado.
       Waste Stockpiling Hazard: Two Cases
   King County,  Washington. Case 1.  All types of
waste  chemicals  have  been dumped into  the old
Dodgers  No.  5 Coal  Mine  shaft in King  County,
Washington, for  years. Much  of this  practice has
stopped but sneak violations still occur.
   King County,  Washington- Case 2.  In the same
county, expended pesticides that  are very susceptible
to fire have been stored in old wooden buildings in
the area.  Several fires have occurred.  In addition,
large  numbers of  pesticide containers have  been
stacked at open dumps.
           Chlorine Holding Pond Breach
   A  holding  pond and tanks  at a  chemical  manu-
facturing  plant in Saltville,  Virginia, failed,  spilling
chlorine, hypochlorites, and ammonia into the north
fork  of  the  Holston  River. River  water samples
showed concentration levels at 0.5 part per  million
hypochlorite and 17.0 parts per million of  fixed
ammonia. Dead fish were sighted along the path of
the flow in the river.
                Malpractice Hazard
   Several drums of a 15-year-old chemical used for
soil sterilization were  discovered in the warehouse of
the weed control agency in  Bingham County, Idaho.
The chemical was taken to a remote area where it was
exploded  with a rifle blast. Had it been disturbed
only slightly while  in  storage, several people  would
have been killed.

                 Explosive Waste
   In .Kitsap County, Washington, operations at  a
naval  ammunition depot  involved washing RDX (a
high explosive) out  of shells from 1955  to 1968, and
the resulting wash water went into a dump. In routine
monitoring of wells in the area, the RDX  was found
in the groundwater and in several cases the  concentra-
tions exceed the  health tolerance level of 1 part per
million.

            Unidentified Toxic Wastes
   A disposal company undertook to dispose of some
drums containing unidentified toxic residues.  Instead
of properly disposing  of this material, the company
dropped these drums  at a dump located in Cabayon,
Riverside  County, California. Later, during a heavy
flood,  the drums were unearthed, gave off poisonous

-------
               IMPACT OF IMPROPER HAZARDOUS WASTE MANAGEMENT ON THE ENVIRONMENT
                                               45
gases, and contaminated the water. Steps were taken
to properly dispose of the unearthed drums.
              Container Reclamation
   At a drum reclaiming plant in northern California,
15  men were  poisoned  by gases given off from
drums  It is presumed that this incident  occurred
because  of  inadequate storage  procedures by  the
company involved.
          Stockpiling of Hazardous Waste
   Several sheep and cattle and a foxhound died, and
many cattle became seriously affected,  on two farms
close  to a factory producing rodenticides and pesti-
cides  in Great  Britain  (This  case illustrates  the
similarity  of problems that exist in highly industri-
alized  nations.)  The drainage from the  factory  led
into a succession of ponds to which the animals had
unrestricted access and from which they are therefore
likely  to have  drunk.  Investigations showed that  a
field on the site was a dumping ground for large metal
drums and canisters, many of which had rusted away,
and their contents were  seeping  into  the  ground.
Residues from  the manufacture of fluoroacetamide
were  dumped on the  site and percolated  into  the
drainage ditches  leading to the farm ponds.  Veteri-
nary evidence indicated the assimilation of  fluoro-
acetamide was  possible if  the animals  had drunk
contaminated water. Ditches and ponds were dredged
and the sludge deposited on a site behind the factory.
All sludges and contaminated soil were subsequently
excavated, mixed with cement,  put into steel drums
capped with bitumen, and dumped  at sea.  The
presence of fluoroacetamide in the soil and associated
water  samples persisted at very low but significant
levels and  thus  delayed the resumption of normal
farming for nearly 2 years.
         Pesticides in Abandoned Factory
   In  the summer of 1972, approximately  1,000
pounds (454 kilograms) of arsenic-containing pesti-
cide were discovered in an abandoned factory build-
ing in Camden  County, New Jersey.  The  building
used  to belong  to  a leather  tannery  that had
discontinued its operations.
  Groundwater Contamination by Chromium- and
             Zinc-Containing Sludge
   An  automobile manufacturing  company in the
New York area is regularly disposing of  tank truck
quantities of chromium- and zinc-containing sludge
through a contract with a trucking firm that in turn
has a subcontract with the owner of a private dump.
The sludge is dumped in a swampy  area, resulting in
contamination of the groundwater. The sludge consti-
tutes a waste residue of the automobile manufac-
turer's paint priming operations.
        Disposal of Chromium Ore Residues
   A major chemical company is currently depositing
large quantities of chromium ore residues on its own
property in a major  city on  the East Coast. These
chromium  ore  residues are  piled up  in the open,
causing probable  contamination  of  the groundwater
by leaching into the soil.
  Dumping of Cadmium-Containing Effluents Into
                 the Hudson River
   A battery plant  in New York State for years was
dumping  large   amounts  of  cadmium-containing
effluents  into  the  Hudson   River. The sediment
resulting from the plant's effluents  contained about
100,000 parts per million of cadmium. The firm now
has  agreed to  deposit these  toxic sediments  in  a
specially insulated lagoon.
               Pesticide Poisoning
   On  July 3, 1972, a 2y2-year-old  child in Hughes,
Arkansas,  became ill  after playing  among a pile  of
55-gallon (208-liter) drums.  He was admitted to the
hospital  suffering  from  symptoms   of   organo-
phosphate  poisoning.   The   drums  were  located
approximately 50 feet (15 meters) from the parents'
front door on city property. The city had procured
the  drums  from  an aerial applicator  to be  used as
trash containers. The residents were  urged to pick up
a drum in order to expedite trash collection. It has
been determined  that these drums contained various
pesticides,   including   methyl  parathion,   ethyl
parathion,  toxaphene,  DDT,  and others. The  con-
tainers were  in various states of deterioration, and
enough concentrate was in evidence to  intoxicate  a
child or anyone else who came into contact  with  it.
     Improper Disposal of A/drin-Treated Seed
                  and Containers
  On  July  9,  1969, in Patterson,  Louisiana, the
owner  of a farm noticed several pigs running out of a
cane field;  some  of  the animals  appeared  to be
undergoing convulsions. It appears that aldrin-treated

-------
46
                                    DISPOSAL OF HAZARDOUS WASTES
seed and containers had been dumped on the land in
a field and that the pigs, running loose, had encoun-
tered this material. Eleven of the pigs died. Analysis
of  rumen contents showed 230.7 parts per  million
aldrin and ]  13 parts per million dieldrin.
       Improper Pesticide Container Disposal
   In May 1969,  in Jerome,  Idaho,  Di-Syston  was
incorporated into the soil in a potato  field.  The
"empty" paper bags from the pesticide were left in
the field, and  the wind blew them into the adjacent
pasture.  Fourteen head  of cattle died, some  with
convulsions,  after licking  the  bags.  Blood samples
showed 0.0246 part per million Di-Syston.
         Ocean Dumping of Chemical Waste
   The Houston Post reported in December 1971  that
large quantities of barrels containing chemical wastes
had turned  up in shrimpers'  nets  in  the Gulf of
Mexico approximately 40 miles (64.3 kilometers) off
the Texas coastline. In addition to physical damage to
nets  and  equipment  caused  by the  barrels,  the
chemical  wastes caused  skin  burning and  eye  irri-
tation among exposed shrimper crewmen. Recovered
barrels  reportedly bore the names of two Houston-
area plants,  both of which apparently  had used a
disposal  contractor specializing  in deep-sea disposal
operations.
        RADIOACTIVE WASTE DISPOSAL
          National Reactor Testing Station
    In October  1968, the Idaho Department of Health
and the former Federal Water Quality Administration
made an examination of the  waste treatment  and
disposal practices at the AEC  National  Reactor
Testing  Station (NRTS)  near  Idaho Falls, Idaho.
There were three types of plant wastes being gener-
ated:  radioactive  wastes,  chemical  or  industrial
wastes,  and sanitary wastes. It was found that there
were no observation  wells to  monitor the effects of
ground burial  on  water quality, that low-level radio-
active wastes were being discharged into the ground-
water,  that  chemical and radioactive  wastes  had
degraded the groundwater  beneath  the NRTS,  and
that some sanitary wastes were being discharged into
the groundwater supply by disposal wells.
    In a report  issued in  April  1970,  authorities
recommended  that  AEC  abandon  the  practice of
burying  radioactive  waste above  the Snake Plain
aquifer, remove the existing buried wastes to a new
site remote to the NRTS and hydrologically isolated
from groundwater supplies, and construct observation
wells needed to monitor the behavior and fate of the
wastes.
          Decommissioning of AEC Plant
   The Enrico Fermi nuclear reactor just  outside of
Detroit is  closing.  However,  there still  remains  a
substantial waste management problem. The owner of
the plant has set aside  $4  million for decommis-
sioning the  plant. A preliminary  decommissioning
plan and cost estimate have been submitted to AEC.
However, AEC acknowledges  that costs and proce-
dures for decommissioning are still unknown since
few nuclear plants (and never one such as Fermi) have
been decommissioned. As of this date, an answer is
still being sought to this waste disposal problem.

              Nuclear Waste Disposal
   After a fire on May 11, 1969, at the  Rocky Flats
plutonium production plant near Denver, Colorado, it
was  discovered that since 1958 the company that
operated the plant had been storing 55-gallon drums
of laden oil contaminated with measurable quantities
of plutonium outside on  pallets. The drums corroded
and the plutonium-contaminated oils leaked onto the
soil in the surrounding area. Soil sample  radioactivity
measurements made in  1970 and 1971  at various
locations on  the  Rocky  Flats site  indicated that the
contamination of the surrounding area was 100 times
greater than  that  due  to  worldwide fallout. The
increase in  radioactivity as defined by the health and
safety laboratory of AEC was  attributed  to  the
plutonium  leakage from  the stored 55-gallon drums
rather  than any  plutonium  that  might have been
dispersed as a result of the 1969 fire. Later, the area
where  the plutonium-contaminated laden  oil was
spilled was covered with a 4-inch slab of asphalt and
isolated by  means of a fence. The 55-gallon drums
were moved to a  nearby  building and the  plutonium
was salvaged from the oil. The oil was dewatered and
solidified  into a  greaselike consistency.  Then  the
drums and the solidified oil were sent to and buried
at the NRTS at Idaho Falls, Idaho.

-------
                                       Appendix B
                     HAZARDOUS WASTE STREAM DATA
   Identifying and  quantifying the Nation's hazard-
ous waste streams proved to be especially formidable
because historically there has been little interest in
quantifying specific amounts of waste materials, with
the exception of radioactive wastes.
   Distribution and volume data by Bureau of Census
regions were compiled on those nonradioactive waste
streams designated  as  hazardous (Table 10). The
approach used  is predicated on the assumption that
the hazardous  properties of a waste  stream will be
those of the most hazardous pure compound within
that waste stream. .Wastes containing compounds with
values  more  than  or  equal  to threshold  levels
established  for the  various hazardous properties are
classified as hazardous. This approach takes advantage
of the available hazard data on pure chemicals and
avoids  speculation  on  potential  compound  inter-
actions  within  a waste stream.  A  list follows to
illustrate types  of chemical compounds  in  the
Nation's waste  streams that could  be regarded as
hazards to public health and the environment:
       Miscellaneous inorganics
         Ammonium chromate
         Ammonium dichromate
         Antimony pentafluoride
         Antimony trifluoride
         Arsenic trichloride
         Arsenic trioxide
         Cadmium (alloys)
         Cadmium chloride
         Cadmium cyanide
         Cadmium nitrate
         Cadmium oxide
         Cadmium phosphate
         Cadmium potassium cyanide
         Cadmium (powdered)
         Cadmium sulfate
Calcium arsenate
Calcium arsenite
Calcium cyanides
Chromic acid
Copper arsenate
Copper cyanides
Cyanide (ion)
Decaborane
Diborane
Hexaborane
Hydrazine
Hydrazine azide
Lead arsenate
Lead arsenite
Lead azide
Lead cyanide
Magnesium arsenite
Manganese arsenate
Mercuric chloride
Mercuric cyanide
Mercuric diammonium chloride
Mercuric nitrate
Mercuric sulfate
Mercury
Nickel carbonyl
Nickel cyanide
Pentaborane-9
Pentaborane-11
Perchloric acid (to 72 percent)
Phosgene (carbonyl chloride)
Potassium arsenite
Potassium chromate
Potassium cyanide
Potassium dichromate
Selenium
Silver azide
Silver cyanide
                                                47

-------
48
                                    DISPOSAL OF HAZARDOUS WASTES
        Sodium arsenate
        Sodium arsenite
        Sodium bichromate
        Sodium chromate
        Sodmm cyanide
        Sodium monofluoroacetate
        Tetraborane
        Thallium compounds
        Zinc arsenate
        Zinc arsenite
        Zinc cyanide
     Halogens and interhalogens
        Bromine pentafluoride
        Chlorine
        Chlorine pentafluoride
        Chlorine trifluoride
        Fluorine
        Perchloryl fluoride
     Miscellaneous organics
        Acrolem
        Alkyl leads
        Carcinogens
        Copper acetoarsenite
        Copper acetylide
        Cyanuric triazide
        Diazodinitrophenol (DDNP)
        Dieldrin
        Dimethyl sulfate
        Dinitrobenzene
        Dinitro cresols
        Dinitrophenol
        Dimtrotoluene
        Dipentaerythritol hexanitrate (DPEHN)
        Gelatinized nitrocellulose (PNC)
        Glycol dinitrate
        Gold fulminate
        Lead 2,4-dinitroresorcinate (LDNR)
        Lead styphnate
        Mannitol hexanitrate
        Mercury compounds (organic)
        Methyl parathion
        Nitroaniline
        Nitrocellulose
        Nitroglycerin
        Parathion
        Picric acid
        Potassium dinitrobenzfuroxan (KDNBF)
        Silver acetylide
        Silver tetrazene
        Tetrazene
        VX fethoxymethylphosphoryl-N,W-
           dipropoxy-(2,2)-thiocholme |
     Organic halogen compounds
        Aldrin
        Chlordane
        Chlorinated aromatics
        Chloropicrin
        Copper chlorotetrazole
        ODD
        DDT
        2,4-D (2,4-dichlorophenoxyacetic acid)
        Demeton
        Endnn
        Ethylene bromide
        Fluorides (organic)
        GB | propoxy-(2)-methylphosphoryl
           fluoride]
        Guthion
        Heptachlor
        Lewisite (2-chloroethenyl dichloro-
           arsine)
        Lindane
        Methyl bromide
        Methyl chloride
        Nitrogen mustards (2,2',2"-
           trichlorotriethylamine)
        Pentachlorophenol
        Polychlorinated biphenyls (PCB)
        Tear gas (CN) (chloroacetophenone)
        Tear gas (CS) (2-chlorobenzylidene
           malononitrile)

It should be noted that this list is not an authoritative
enumeration of hazardous compounds but a sample
list  which  will be modified on the basis  of further
studies.  Compounds  on  the  list  should  not  be
construed  as those  to be regulated under the pro-
posed Hazardous  Waste Management  Act  Table  11
identifies  those radioactive  isotopes  that are  con-
sidered  hazardous   from  a  disposal  standpoint.
Detailed data  sheets  describing the  volumes,  constit-
uents, concentrations, hazards, disposal techniques,
and data sources  for each waste stream  are available
in EPA Contract No. 68-01-0762.

-------
HAZARDOUS WASTE STREAM DATA
                                                            49





















*
S

w
PH
E-



C/]

•>
^
til

!-<
U
o <
^ 0
w 5
BQ g

E— • ^
^ o
o
<
E-
Q

o:
g

CO
















^
fi
E
C
C£




OJ
G
O














tn
o;
[_.
rt
o

a
S
en

Cn
>.
a/
en
n;
c;
u
OJ
P-.









•S \

CO £








CU
n
t-
a
_n
















,-,
n
:=-




>


S


U
CO
^


(j






C/l


r .
g
^

U
S
W

S

u
S

o
T3
o

























6
I
™
S
O O O O O
X X X X x-
CN -. ^_ LO CN

O CO

O
-JD sO
O — i ^
0 O O
0
^ o

o CN o •— o
0


^r t>
O CN ^ O CN
o


CO O

LO —1 vD i-H CN
O

LO LO "xT
O O — < O
O

•^T LD LO
O — i O CN — '
O
CO LO
f- — i ND — ' C~-
<-* — < O CN O
O

0 CN 0 0 0
O

CN O •— '

CN CO CO CO CO
CN C-J CN CN OJ





a>
QJ "«

C
wastes from textile dyem
reduction bnne sludges
chromate production waf
ster production wastes
,te agricultural product w

S S .2 5 zi v
V
S
cr
<












o o
X X
-i CO


1 sD

O
o o

^

•^



1 ^
o



QN

O


i sO
O


O LO
o — <

CN
O


O
O

to

CN CN



>>
a; ^
S s
3 tu

icid)
works from ammonium
d lead-bearing petroleum

1 § S.!
1 o '
£ o




c
o
3 0
"o ^
1/5 3
•O "^
S • — '
rt -2
U S


o> cu o >o > > > >
XXXXXXXXQXO- oooo
cNa-LnLOLninTrcoSr-H^cN^SSS


tO ' ^-iCNNDO^^D^D^ONO-ONDvOONO


OOO— 'OOOOOOOOOO

rj- ^r sDNO^vo^ovONONONO

oooooooooooooooo



LO LOLnLnrOLOLnLOLnu-jLO
oooooooooooooooo



•O CO OOOOOOOOOO

OCNOOOOOOOOOOOOOO


\O sO\OsOLTiNDsONO^OOND
OOOOOCNOOOOOOOOOO


*3* ooo-HCT-ocr-ooa^


o- 00^,000.0.^00
CNcNtOt-T— '.— *'-!.—(

CN^fOCNuO^^^^tO^^^^^^
CNOOOPO^^---^^^--

-H CN

'-' CN tO tO tO tO tO


3
o
Cn
rt


1 §
r- «3 w
„ •£ 5 CD
a, ro S w
20 ^t^SG M 5
2^ ? 034--^! a>>«
S |5" aHltglal
1 i -1 S1 s"8 la g-s s * « §
g.5£a| ^c^Sa^g-s^
|||||s|||^8^|||

: £ £ T) g c w 3





 ^ 0 O O O C
o ^t x x x x
^ ^ ^r m ^r CN c


vO tO -^ NO CN


— i -3- EO tO .-< tO
o o — • o o o

NO -H CN LO

o o o o o



LO CN O tO
O O O O O LO



o ' — ! to r^ i

O O -H 0 O


NO LO [> tO O
0 O O O O O


CT- o o r- o


O CO CN CO O


^ 5 ^, 5 ^ g
- OJ 0 	 0


LD <"S
co to to co •





S
« s

plating wastes
ung chromic acid
s and photography waste
circuitry manufacturing v
itmg wastes
ver blowdown
o •*•»••-* ^ ^
5 ^ o o "o c









g, ^ JJ,
'§'§'§
CO tO CO




D O O O O
w x; x < x
~- ' — i cO tO i — i


LO [--





O tO CN] O
<> O O LO




Z!





o o —







o o o ^


o




CO CO CO CN

CO co co cO
CN CN CN CN





O

(Tl CU
s methanol production w;
yde production wastes
ehydrogenatlon butadien
ion wastes
nufactunng wastes
3 "« -C ^ o 2
2 fi-S £.§ °
d =1 a o s
n >. C 3 Q, n
0 0« 3
u [J U, C &
"S
to

O












oooo
- x- x.
^ LO CN CN

NO
•^1

^
LO
O

o

o



o
o



[>• O1 tO

^1 NO CO






o r^
o o

O M O
co NO i_n
--• o o

S C> £)
-- — 1 LO 0



co oo CO cO
CN CN CN] CN



Q c
O g,

jj "
oj ,rl
rbicide wastes (DOD)
i aliphatic herbicide wast.
3 herbicide wastes (DOD)
d aliphatic hydrocarbon I
& % £ S
3 |-^l
S ° g5
«SS£5
















0
X
— I


CN

*t
O












to
to
O






o
o

2:
o
^
o
o
o

o

CO
CN





Q
0
n
DODl
sphate pesticide wastes (1
— o
wastes
Organoph
















o
X
CO
•^
o
0
Q

CN
O
O
o

o
^f
"-*



o
cO


CO
o
o
p


I


t>
o
o

o
o
o
(N
O
0
o

o
r-
co
CN








erbicide wd^iua
n
Phcuoxy
























































CJ
3

-------
50
DISPOSAL OF HAZARDOUS WASTES
















QJ

g
§
U

tn
S
"^
u
BJ
H
C/3
w
H
00
§
0 >
1— 1 t-1
W t)
CQ §
cj; «
^§
Di
S
o
DS
o
u.
j
E-.
Q
^



1
s





J<1
nj
OJ
&


v -^
H £
0 £




*


S


u

<;
03
QJ

J CO

Q.
fO

cu <
& in
a>
f °
"c ^
s ^
a!

w


<


M
z

•H a
nj i-i QJ
T3 "5i T3
C 3 0
rt -o 0
to S


0)
EJ
0)
t-i
O
s











00 0
XX X
to -i to
m r~> eg

^ in PS
; p-. |

p

1 fo |
bo
p


1 ^ 1
0
o


co vc p-

cq p eg

sD to eg
o o o
Op p

| CO CN

O O

1 eg \D

CO
CN

>>
rrl
and explosives
Contaminants and waste from pnm<











o
X
OH



o
0
0

1




1




eg

^

^r

I



_
o

i





CM
ON
CO
eg

iminated
explosives production
Nitrocellulose base propellant conte


 O O JP
O *"* *J ^ 'M *"* c
£ £• £ o £• .S3 o
O ,0 3 u ,Q 3 o

pH J -O O ^3 T3 0
CO CU £


ooooo oooooooooo o ooo o o o o ooo
XXXXX XXXXXXXXXX X XXX X X X X XXX
<— < \o PS to ^o i— 'cocMinco^tocototo <— < ej co eg in m eg ^ ^otof
eg| ^ i ^-"in^soeg^m soo | o c** m to o totoo

o to o p CM m CN o — • -H o o^ CM o -; p -H i-; eg •-< ~ CM
a- w*

o p p op^oooooOi-i o p o p pop

^ |i\or-co|ics.rs.o^'— < eg imto o tocototoco
o o ej^-iLnp~to\oom \cto o ^o o^ o o^cr^o
po o— 

tO TfO*?1 CN m O O •— < O 0 O -H-^^ ^H ^-i ,-< ^- ^H^^^-I

^fi'^ps ^egjtf1^1"1 11 1 f" 1 1 c?1 to o totoo
c^ incopso tnincO"-^ ^ co PSCOP^PSCO
CO ^ytO'- min^o
otoo^eg i— i in ^^ts-^H^Hps
p popo p o ,-1 o *-t —« p





oo^oo^c^ cj\oc7>oO'-(cy*i— ir-irH ^H^HCM eg to p- PS pspsr^
COCQCOCOCO COCOCOCOCOOO^tOpsps \OCOCO CO CO CO CO COCOCO
egegegcMeg cMegegcMegrgegtoa^o egegeg eg eg eg eg egegeg

2 1
** vt +3 e 2
O *"* QJ o U fe ™
™ & "° a " -H-3
. !i« 1 Js ai i II I.»
i. HI I 1 } ill f I J «!'
ils||i 1 5 * is!*! . & 1 111
|-SS|g| i fs 8| iilH | | 1 S||
||l:*|BS s ii s|s -g^lfil * | § 111
c'g2o3-og»gS2LjjS?« a « c 'S. E S o g, i>a°{
8lsIS^iIgf|l|s| Sgg|8 B f S 111
i§o5^g-|-g|;-3|gl|8 |5||g s | g.^
S^gSg^xSsS^S^sS0 -S u^&ScS g ^ „ % „£ S£
|Nl!il!!l!!H?J| 1 Illill 1 If! !
*^§oS3a3333g§'g-3;§~ W Og|gTjS ^ ^^^&&,g
X£aw<: &^^^2UtSuSO gQ
-------
                                                                 HAZARDOUS  WASTE STREAM DATA
                                                                                                                                                                                                   51
                                                                                                                    O CN ^-< Csl CN p— i O O OO —< O O O O O

o

r-
0) _0)
> >
*- *4
CN
                                                                                                                                                                                      ^l  J3 XI  ^ XI
       CN  CN

       O  O
   O ON  CN
   OOO
  tN QN •—' tO ^
  O ^f ^ O CN
  O O — O O
tO  CN             I   •—'  co
tocNmoin     ,—<  —i  [—
ooor-cN     O-HO
                                -HO     tO         00     cO\OLOC--CNtO     ^-I-H

                     CN     tOtOO     O  tO O  --i     CNO'-'OO--'     OO
                         L^     CO  LO

                      LO r—<  \O O  O

                      --H O  ^ ^-1  —t
                                to
                         ^ to  -^
<  — CNO^--<     tO  tO     10
'OO'tOCN'—'     OCN     CNOtO^-i
•O'-'O^rCN     O--H     O'-'OO
                         xO     CN         CO
                      ON O  vO CN   '      CN  O- CO
                      O O  >-> O         CN  —( CN
                                                                                                                                           XI  JD     J3 XI
                                                                                                                                            rtj  ^ro      re  n  ,

                                                                                                                                            >  > CN  >  >
       CN  CN

       O  O
   ^      OCO     t>         ON        CO in  >—i  tO  oO     CNcO     LO •—*

•—* —<  O  O ^     OOOO        O •—'  tO  O  •—'     tOO     OOOO
                                                                                                                                                                 o  o
                                                                                                                                                                 2  2
    tO O^  O1

    CN CN  CN
                      o-ootoo     oooo        o  o f-i  —' o     to to     -nomo
                      LO     CN p—i   '      OCNtOcO     OCNLntOcOO     CNvD     CONDintOmOtO'^J'CO
                      O     OO         —                tOCOtOtOtOtO
                                                                                                                                    tOOON                ^-t  ^-t (-<  ^-t r-H  ^-(
                                                                                                                                    OOOCNOCOCOCOCOCOCOOOCO
                                                                                                                                    ^-.^H—.CNCNCNCNCNCNCNCNCNCN


'etraethi
3
T3
O
(-.
a
o
1-1
ex
ro
!
ous inorganic (insufficient quant
HI
<
* ^
_*« m (0
3 " H S
» s •» c 25 a
£t;2s*S s » o>
J=S>!«Sc" g"2-S
gSc^S-sS-^Sago^
Sco^^l-a^^SSac
•2S|fl^a2| S^^sB
ffimiisiB-m
vls:sa|ali&sss
l2o°IIl§ll|||g
§ £ &6 >,i | S S.^S£-g^
a0gggi)gn>gC'SDDaj
•ocS-gsss-gS'SsaSsisi
CN2uS£:u5;
-------
52
                                   DISPOSAL OF HAZARDOUS WASTES

































o
i—4
w
J
CQ


13
3
"o
c
o
u
1
e/3
W
PS
H
w
e
™

C/3
<
s
w
>
B
ej;

o

5
<
PS
§
a
B:
o
b
<
E-
<
D
>•
«;
<


^a.
5
00








1;
re
E
K



01
"o
>














S
n3
^
a
ro


Oi
>>
XI
en
QJ
o
OJ
0-












"H ""
•S -S
" *

ra "

LO S





_a
t
|
Q
V
n
S











Q




^


^
S




CO

U
CO




CO


u
1




y
w





W




0
"o








'
1











_ 3
x g1
- S
0 0

o o

o o
CN CN
0 0



in LO
\D sO

_ _,
—1 r-H



in m
,— 1 r-H


r> [-•
o q




LO LO


0 0
*-< ^

LO lO

O O




\o 0s

CO CO
CN CN


QJ
*o

Chromate wastes from pigments and
Arsenic wastes from purification of



*_ ^
"o .2
§ e
a 2
si
T3 ^
O
£

3- 33- - 33- 33 "S- - - - - 3
^S^^SS &'§i2"s>'eiro22222&
oTx^^xx 'QT'§1x'§''g''oxxxxxFJ1
ScNSSCNCN Z2CN2I2SCNCNCNCN(N2
\DV^ i^ot^-tN inincN ; i ICOCOCQCOCO '

qo oqo ^H^H,-I ooooo


in to LO >— i i — i^p ' '^j'^f^Tj'^
qq o ooo oqqqo



r^- ["> | r-- i— ' •— i oo^* ooooo^


OO OCOco tOCOTT OOOOO
CNCN CNJ f-H — i OO.-H CNCNCNCNCNO
'-'



r-i r-, •-H'^'^r -"-.-HCN -M-CNCNCNCNCN-1-1-


muo ILOCOCO o^o t | i^^r^r^rr •
qo qoq ooo ooooo



\o vo , vo I-H f-i cotoo- |LnLnminin
vO\O ^OOO CO CO — i -^ 'p -^ ^T ^ tj* rj"
. •>_- — - "*




r>o 0^0^ vosoc- LOLOLOLOLOI
oo o^^r mino1 ^ooooo
oo ooo ooo ~^_ ooooo




tT* 0s 0s 0s i— « I-H inO^OO^ rjvCJ^OrJ'C^

COCOCOCOCOCO QOCOCOCOCOCOCOCOCOCOCOCO
CNCNCNCNCNCN CNCNCNCNCNCNCNCNCNCNCNCN

M
1 „ i
&1> ro
w D ^ .S
ri •— "O « w •"*
S 13 <- r 2^° S
tU .- I! |I
c'C£^ MS Sa -a5c °
Cnlga • 1
in
q o
§ ' '
o



CO '
0


to | i
^



CN | |

to

— ' 1
CN O

[-- 1 1
CO '
0




O 0s 0s
ON tO CO
CO tO CO
CN CO CO





(arsenites)
Electrical fuse manufacturing wastes
BeryUium salt producti6h~Wstes
Thallium production wastes











J^-'/C -^
,-H -^ «
X X 'o
-, - 2
r-l UO LO
tO vO O
q -H r-*


1 to to
q o



CO (N CN
CN tO CO

' 2 S
o o




o o q


-. I> £>
000



ooo

tO r-t l-(

v£) CN CN
^ to to

LO CO CO

,-H -H ^H




LO CO


CO CO CO





Rotogravure printing plate wastes
Computer manufactunnq wastes
Electronic tube production wastes











fO - _ _rO ffl
ro x x rO ro

z ^ ~ z z
o ^r
•& CO ^~-
q -H*_

! CN

o ^~
"~"


o o o
sD LO i— i

^ CN —'
OOO
QJ 0>
3 3


O — ' O > >
• ra ra
0 0

CN •— i ^f
--) --. q




\D CO LO
rH CN LO

vOOco
CO CS f-*

~-< o o

•-< q o




O .— ( CN


to to co -^ 'j-


i*
u
3
T3
C
Magnetic tape production wastes
Battery manufactunng wastes
Mercury cell battery wastes
Railroad engine cleaning
Arsenic wastes from transportation i











ro JS
> > c
oo x
Z 2; c\















fa OJ
3 3


> >
nJ n)
"o o
^ 2


















, 	 , ^H


O O





Military cadmium wastes from platir
Military sodium chromate











_ -°
b |
- o
CN S
CN
vQ


CM
^r
o



^!-
r-

T
— '
0)
X!
t^ —
^i) S
CM >
Tl
"o
o
o



r-
— j
_

o
o

r>
o
O




^^ , 	 |
o^ --*
^r r-
CN O^


ro
ro ^
TJ ,13
n "o
me (insufficient quantity or distnbutK
Spent wood-preserving liquors
Off-specification "agent orange" def
fl
cr
6

-------
HAZARDOUS WASTE STREAM DATA
53
^
u
o g
Sec
™ 3  /> >v- 2 3 3 o TJ j 3
— -2 rT' _T^ r. — — ^ J3 p ,2 -S- -a J2 JS

> > OOO> & ° en ° >O> O Tj >OO>O O O
fO TO — 1 i— 1 i— 1 fO "^-liir-H CO CJ re '""'C ft (— t i-H (!) P— * i— 1 •— 1
2 Z CNJ — i cs 2: Z ^> Z co S D 2 co Z co T 2; co ^r cs


| O O CO | , ^ CO

pop ^ o o o


i O O . CO vO
r-j ^ ' 
CO ' — ' O sD O
•—i -~* O3 O O (N
1—1 QJ Qj O) 0) OJ OJ
X) 3 X! X3 Xi -Q



^ -H oa > Ofocs >>>>>

o o o o- o o
Z Z Z Z Z Z
\ co O *3* , | CO '  i— i i— i co r-> c-^c^-o
O CNlNCSCNrj^fC* OO(NO O^ O* C* 1 i
s
« S I 1 „
8 - S ° 1 i l-a
£ s „ | g| | | | J|
1 -ss 1 M §• § ^lS-1
w S> -H a -fl *• 6 £ t?£ II S
y S ^ o C § -3'3'H^S
*•* 'r* "^ "S ^ SO'S " '^S'O'd'O SS^cw
3,.5flJ^ wojO 0 DO^C.S •Owpi-fl)
O.O 2 °'°'o<3^S'>.^'So *3 "002^0)^ *iM-t>*c3^ -^ ^
fiO t/1 O^gaj^gjU^g-S CO ^•32C'Tj"'& S 3 "3* §* "3 °* w
S ^ 3 ^
0* 0
 -5 G ra
fi - - "J
c -5 « ±
/v ^3 £
o w
•o w •£ 8
C —2 —
t "O rf X
C flJ

o («" h S
i^4 4~' c 5)
S^O
41 n (- nf
2 '-' -a 13
- -C n >
^ +J O !T*
K o ^ 2
^ "3 fO
^ -W g
> j^ I; j2
£ <" j C

•° w 2
u » _
C .M- 'Q J^

< s g "
2 ^ S ""

(D ^ O
Q r^J O
c£ O ^
2 § - «"
. 3 fO C
4^ 5 2 O
C S N

s « - 5
" 1 c

1 is §
- 0 ™ S
"O >-« CJ S
c «
. « _, JS li
t; 'a 2 3 «;
o - g o 2
A. 0) K [/j ._
0) -u 0) i/J
£ o o M- 5J
3 ^ ^ _5 ^

t"g S "g g,
I * g I

ffi •£ Q CN.
|sg|l ^q
| a g 1 g §, | ^

•o 2 o ~ -3 Ic -^
gj^U.rogw T3J3

*This is an updated version of the table that app
tNE = New England- Connecticut, Maine, Mass
L Central: Illinois, Indiana, Michigan, Ohio, and 1
tic. Delaware, District of Columbia, Florida, Ge<
'ennessee; WSC = West South Central: Arkansas,
(Pacific): Alaska, California, Hawaii, Oregon, and
^Exists but quantity is unknown.
§ Total liquid discharge for the larger 3-digit stani
' Percentage for the Mountain and Pacific areas c
*•• S «-•
o 3 "^ S
Z < S S

-------
54
                                        DISPOS ^L OF HAZARDOUS WASTES
                                                    TABLE 11
                                  POTENTIALLY HAZARDOUS RADIONUCLIDES*
Nuclide
H-3
Be- 10
C-14
Na-22
Cl-36
Ar-39
Ca-41
Ca-45
V-49
Mn-54
Fe-55
Co-60
Ni-59
Ni-63
Se-79
Kr-85
Sr-90v
Zr-93^
Nb-93m
Nb-94
Mo-93
Tc-99
Ru-106F
Rh-102m
Pd-107
Ag-llOm
Cd-109
Cd-113m
Sn-121m
Sn-123
Sn-126
Sb-125
Te.l27m
1-129
Cs-134
Cs-135
Cs-137"!
Ce-144l
Pm-146
Pm-147
Half -life (years)
12.33
1,600,000
5,730
2.601
301,000
269
130,000
.447
.907
.856
2 7
5.27
80,000
100
65,000
10.73
29
950,000
12
20,000
3,000
213,000
1.011
.567
6,500,000
.690
1.241
14.6
50
353
100,000
2.73
.299
15,900,000
2.06
2,300,000
30.1
.779
5.53
2.5234
Source'
1,2,3
2
2
2
2
2
2
2
2
2
2
2,3
2
2
1
1
1, 3
1
1,2
2
2
1
1,3
1
1
1
1
1
1
1
1
1,2
1
1
1
1
1, 3
1,3
1
1, 3
Nuclide
Sm-151
Eu-152
Eu-154
Eu-155
Gd-153
Ho-166m
Tm-170
Ta-182
W-181
Ir-192m
Pb-210l
Bi-210
Po-210
Ra-226-F
Ra-228 F
Ac-227±
Th-228'f
Th-229i
Th-230l
Pa-231-F
U-232:!
U-233t
U-234*
U-236
Np-237
Pu-236-r
Pu-238l
Pu-239
Pu-240t
Pu-241
Pu-242:'
Am-24lt
Am-242m:f
Am-243:!
Cm-242t
Cm-243-t
Cm -244 1
Cm-245t
Cm-246i
Cm-247*
Half -life (years)
93
13
8.6
4.8
.662
1,200
.353
.315
.333
241
22.3
3,500,000
.379
1,600
5.75
21 77
1.913
7,340
77,000
32,500
72
158,000
244,000
23,420,000
2,140,000
2.85
87.8
24,390
6,540
15
387,000
433
152
7,370
.446
28
17.9
8,500
4,760
15,400,000
Source"''
1
1
1
1
1
1
3
3
2
3
1,2
1
2, 3
1,2
1
1
1
1
1, 2
1
1
1
1
1
1
1
1,3,2
1, 2
1, 2
1, 2
1
1, 3
1
1
1, 3
1
1, 3
1
1
1
      ^Criteria for inclusion of nuclides: (1) They must have half-lives greater than 100 days. Nuchdes with half-lives less than 100
days are assumed to decay to insignificance before disposal or are included in their long half-life parents  Note that this excludes
nuclides such as 1-131 with an 8.065-day half-life. (2) They shall not be naturally occurring because of their own long half-lives.
This table excludes such nuclides as K-40,  Rb-87, Th-232, U-235, and U-238 with half-lives greater than 10" years. There are also
75 potentially hazardous radionuchdes that occur in research quantities that have not been included in this table.
      ' Source terms  1 = Found m high-level radioactive wastes from fuel reprocessing plants, both Government and industry.
2 = Found m other nuclear power wastes such  as spent fuel  cladding wastes, reactor emissions, and mine and mill  tailings.
3 - Found in wastes  of nonnuclear power origin such as nuclear heat sources, irradiation sources, and biomedical applications.
      . Indicates hazardous daughter radionuclides are present with the parent.
   It is important  to emphasize that although Table
10 is sufficiently accurate for planning purposes, the
indicated  total  national nonradioactive  hazardous
waste volume  of 10 million tons (9  million metric
tons) per  year is not a firm number but an estimate
based  on  currently  available  information.  A  more
accurate  indication  of  actual waste  volumes will
become available only after a comprehensive national
waste  inventory  has been accomplished for  specific
waste streams.

-------
                                       Appendix C

       DECISION MODEL FOR SCREENING AND SELECTING
                            HAZARDOUS COMPOUNDS
                    AND RANKING HAZARDOUS WASTES
   A preliminary decision mode] was developed for
interim use in order to screen and select hazardous
compounds and  rank hazardous wastes. The decision
model used for purposes of this study is not nearly as
sophisticated  as that  required for  standard-setting
purposes.  An explanation of  the terminology and
definitions utilized are included.
   It is essential to make a clear distinction between
development and application of criteria for purposes
of designating hazardous wastes and development and
application of a priority ranking system for hazardous
wastes  despite the fact that similar or  related data
must be  manipulated.  The  distinction  is that the
hazardous waste criteria relate  solely to  the intrinsic
hazard  of the waste on uncontrolled release  to the
environment regardless  of quantity  or pathways to
man or other critical  organisms. Therefore criteria
such as toxicity, phytotoxicity, genetic activity, and
bioconcentration are utilized.
   In  contrast,  in the development of  a priority
ranking system,  it  is obvious that the threat to public
health and environment from a given hazardous waste
is strongly dependent upon the quantity of the waste
involved,  the extent   to  which  present  treatment
technology and  regulatory activities  mitigate against
the threat, and the pathways to man or other critical
organisms.

  DEFINITIONS OF ABBREVIATIONS USED IN
           THE SCREENING MODEL

   Maximum   permissible  concentration   (MFC)
levels: Levels of radioisotopes in waste streams which
if continuously maintained would result in maximum
permissible doses to occupationally exposed workers
and  which  may  be  regarded  as  indices of  the
radiotoxicity of the different radionuclides.
   Bioconcentration (bioaccumulation, biomagnifica-
tion): The process  by which living organisms concen-
trate an element or compound to levels in  excess of
those in the surrounding environment.
   National Fire Protect/on .Association (NFPA) cate-
gory 4 flammable materials: Materials including very
flammable gases, very volatile flammable liquids, and
materials that in the form of  dusts  or mists readily
form explosive mixtures when dispersed in air.
   NFPA  category  4  reactive materials:  Materials
which in themselves are readily capable of detonation
or of explosive decomposition or reaction at normal
temperatures and pressures.
   Lethal dose fifty (LD50):  A calculated  dose of a
chemical substance  which is expected  to kill 50
percent  of a  population  of  experimental animals
exposed through a route other than respiration. Dose
concentration is expressed in milligrams per kilogram
of body weight.
   Lethal concentration fifty  (LC$0): A calculated
concentration  which  when  administered  by  the
respiratory route is expected to kill 50 percent of a
population of experimental animals  during an  expo-
sure of 4 hours. Ambient  concentration is expressed
in milligrams per liter.
   Grade  8   dermal  irritation:  An  indication  of
necrosis resulting from  skin  irritation  caused  by
application of a 1-percent chemical solution.
   Median  threshold limit (96-hour TLm)  That con-
centration  of a material at which it is lethal  to 50
percent  of  the  test  population  over  a  96-hour
                                                55

-------
56
                                    DISPOSAL OF HAZARDOUS WASTES
exposure period. Ambient concentration is expressed
in milligrams per liter.
   Phytotoxicity:  Ability  to  cause  poisonous  or
toxic reactions in plants.
   Median  inhibitory limit (ILm):  That concentra-
tion at which a 50-percent reduction in the  biomass,
cell  count,  or photosynthetic activity  of  the test
culture  occurs compared to a control  culture over a
14-day period. Ambient concentration is expressed in
milligrams per liter.
   Genetic  changes:  Molecular alterations  of the
deoxyribonucleic or ribonucleic acids of mitotic  or
meiotic  cells resulting from  chemicals or  electro-
magnetic or particulate radiation.
  CRITERIA FOR SCREENING AND SELECTION
   The  screening  criteria are  based purely on the
inherent or intrinsic  characteristics  of the  waste  as
derived  from its constituent hazardous compounds.
The problem in seeking a set of criteria becomes one
of establishing for  public health and  the environment
some acceptable level of tolerance. Wastes displaying
characteristics outside of these predetermined  toler-
ance levels are designated as hazardous.  This approach
requires  that defensible thresholds  be selected for
each tolerance level. For  example, if the toxicity
threshold is defined as an LDSO of 5,000 milligrams
per  kilogram of  body  weight or  less,  all wastes
displaying  equal  or lower  mean  lethal dose  levels
would   be   designated  hazardous.  Similar  numeric
threshold  values  were  developed  for  other  basic
physical, chemical, or biological criteria utilized  in
the  screening phase of the decision model. Ideally
then, the decision criteria  for  designating hazardous
wastes  could be based upon numeric evaluations  of
intrinsic toxicological, physical, and chemical data.
   In addition, a criteria system for screening hazard-
ous wastes must retain a degree of flexibility. This is
self-evident  because all  potential wastes, let  alone
their composition, cannot  now be identified. Conse-
quently, it  appears  that  a  technically sound and
administratively  workable criteria  system must  have
levels of tolerance against which any waste stream can
be compared.
   As a result,  a  preliminary  screening model was
developed as illustrated in Figure 5. Each stage of the
screening mechanism compares the characteristics  of
a waste stream to some preset standard. Qualification
due  to  any  one  or more  screens  automatically
designates a waste as hazardous,
        PRIORITY RANKING OF WASTES
   There is little doubt that, on the basis of intrinsic
properties alone, many wastes will qualify as hazard-
ous wastes. Therefore it  was necessary to rank these
wastes in priority fashion so that those presenting the
most  imminent threats  to public  health  and  the
environment receive the greatest attention.
   To  assess  the  magnitude of the threat posed by
hazardous  wastes  is difficult.  Such a  determination
requires input concerning the inherent hazards of the
wastes, the quantities  of waste produced,  and the ease
with  which  those hazards can be  eliminated or
circumvented.  These considerations  were  incor-
porated into numerical factors, which in turn were
used  to  determine  the priority  of  concern of  a
particular  waste.   The  final    numerical  factor  is
designed to represent  the volume of the environment
potentially polluted  to  a  critical  level by a  given
waste.  The assumption is made that all sectors of the
environment  are   equally  valuable  so  that a  unit
volume of soil is  as  important as a unit volume of
water or air. This simplification does not reflect the
fact that atmospheric and  aquatic contaminants are
more mobile  than  terrestrial ones but does recognize
the problem  of   environmental transfer from one
phase to another.
   The numerical  factor is derived by  dividing the
volume of a waste by its lowest critical product. This
may be expressed mathematically as
where
       R =  ranking factor
       Q =  annual production quantity for the waste
            being ranked
      CP =  critical  product  for the  waste  being
            ranked

   CP is the  value  of  the  lowest concentration at
which any of the hazards of concern become manifest
in  a  given  environment  multiplied  by  an  index
representative  of  the  waste's  mobility  into  that
environment.  Hence, for a waste that will be  dis-
charged to water or to a  landfill where leaching  will

-------
DECISION MODEL FOR SCREENING AND SELECTING HAZARDOUS COMPOUNDS
                                                                                                57
WASTE
STREAM
DOES WASTE CONTAIN
RADIOACTIVE CONSTITUENTS
> MPC LEVELS?
1
NO
IS WASTE SUBJECT TO
BIOCONCENTRATION?
1
NO
IS WASTE FLAMMABILITY
IN NFPA CATEGORY 4?
'
NO
'
IS WASTE REACTIVITY
IN NFPA CATEGORY 4?
1
, NO
DOES WASTE HAVE AN ORAL
LD, „ < 50 mg'kg?
i
NO
IS WASTE INHALATION TOXICITY
200 ppm AS GAS OR MIST?
LCsn < 2 mg/ Her AS DUST?
^
f NO
IS WASTE DERMAL PENETRATION
TOXICITY LD, , < 200 mg/kg?
i
, NO
IS WASTE DERMAL IRRITATION
REACTION < GRADE 8?
i
NO
DOES WASTE HAVE AQUATIC
96 hr TLm < 1,000 mg/liter?
i
NO
r
IS WASTE PHYTOTOXICITY
IL, „ < 1,000 mg/liter?
1
, NO
DOES WASTE CAUSE
GENETIC CHANGES?
\
NO
r
OTHER WASTES
YES
YES
YES
YES
^~
YES
YES
YES

YES

YES

YES

YES
1

HAZARDOUS WASTES
          Figure  5. Flowchart  of the hazardous waste screening model.

-------
                                    DISPOSAL OF HAZARDOUS WASTES
occur, the product might be the 96-hour TLm to fish
for that waste (e.g.,  1 milligram per liter) multiplied
by  its  solubility  index (SI).  SI  is  defined  as a
dimensionless  number between  1  and infinity ob-
tained  by dividing  10'' milligrams per liter by the
solubility of the waste in milligrams per liter. A waste
soluble in water to 500,000 milligrams per liter has a
solubility index calculated as follows.
                         106
                   SI -
                       5 X  10"
This presumes that all wastes miscible  in  water or
soluble to more than  1,000,000 milligrams per liter
will  have similar mobility patterns and  thus should
receive a  maximum index of 1.  CP for the example
waste would then be calculated as follows.
            CP -- 96-hr TLm X SI
               ~- 1 milligram per liter X 2
               = 2 milligrams per liter
   Similarly, for atmospheric pollutants, CP might be
LC50 multiplied by the volatility index.  This index
would be derived  by  dividing atmospheric pressure
under ambient conditions by the vapor pressure of
the waste. Potential for  suspension of dusts in air
would be given a mobility index of 1.
   The aqueous and atmospheric environments are of
greatest concern since discharge to the land represents
major hazard in the form of volatilization of wastes
or leaching. Where data are available on phytotoxicity
or other hazards related to direct contact with wastes
in soil, CP for ranking  would be derived from use of
the  critical  concentration  at which the  hazard
becomes apparent and a mobility index of  1.
   Actual  waste stream  data are most desirable for
use in  the  priority ranking formulation. However,
since  such data ai\j generally  lacking, the additive
estimations  recommended for interim use  can be
employed for priority ranking until waste stream data
become available.

-------
                                        Appendix  D
           SUMMARY OF HAZARDOUS WASTE TREATMENT
                            AND DISPOSAL PROCESSES
   The objectives of hazardous waste treatment are
the destruction or recovery for reuse of hazardous
substances and/or the conversion of these substances
to innocuous forms  that are acceptable for uncon-
trolled disposal.  Several  unit processes  are  usually
required  for  complete  treatment  of a given waste
stream. In some cases, hazardous residues that cannot
be  destroyed, reused,  or  converted to  innocuous
forms result from treatment. These residues, there-
fore, require controlled storage or disposal.
   This appendix presents a description of each of the
treatment and disposal  processes  examined during
this study. No  claim is made that these hazardous
waste treatment processes or combinations of proc-
esses and storage or disposal methods  are environ-
mentally  acceptable. Treatment technology  can be
grouped  into the  following  categories:  physical,
chemical, thermal, and biological. These processes are
all utilized to some extent  by both the public and
private sectors. However, treatment processes have
had  only limited  application in  hazardous  waste
management because of economic constraints, and, in
some cases, because of technological constraints.
   The physical treatment  processes  are utilized to
concentrate waste brines and remove soluble organics
and ammonia from aqueous wastes. Processes such as
flocculation, sedimentation,  and filtration are widely
used throughout industry, and their primary function
is the separation of precipitated solids from the liquid
phase.  Ammonia  stripping  is utilized for removing
ammonia  from  certain  hazardous  waste streams.
Carbon sorption  will remove many soluble organics
from aqueous waste streams. Evaporation is utilized
to concentrate brine wastes  in order to minimize the
cost of ultimate disposal.
   The chemical treatment processes are also a vital
part   of  proper  hazardous  waste   management
Neutralization is carried out  in part by reacting acid
wastes with  basic  wastes.  Sulfide precipitation is
required in order to remove toxic metals like arsenic,
cadmium,  mercury,  and   antimony.  Oxidation-
reduction  processes are  utilized in treating cyanide
and chromium-6 bearing wastes.
   Thermal treatment methods are used for destroy-
ing or converting solid or liquid combustible hazard-
ous wastes. Incineration  is the standard process used
throughout industry  for destroying liquid and  solid
wastes. Pyrolysis is a relatively new thermal process
that  is used to convert hazardous wastes into more
useful products, such as fuel gases and coke.
   Biological treatment processes can also be used for
biodegrading  organic wastes; however, careful  con-
sideration needs to be  given to the  limitations  of
these processes. These systems can operate effectively
only within narrow ranges of flow, composition, and
concentration variations. Biological systems generally
do not work on solutions containing more than 1 to 5
percent  salts. Systems that provide the full range of
biodegradation  facilities usually  require large  land
areas. Toxic substances present  a constant  threat to
biological cultures.  In summary, biological treatment
processes should be used only when the organic waste
stream is diluted and fairly constant in its  composi-
tion.
   Disposal methods currently  used vary depending
upon the form of the waste stream (solid or liquid),
transportation costs, local ordinances,  etc. Dumps
and  landfills  are utilized for all types of hazardous
wastes;  ocean disposal and  deep-well injection are
used  primarily for liquid hazardous wastes  Engi-
                                                 59

-------
60
                                     DISPOSAL OF HAZARDOUS WASTES
neered storage or a secure landfill should be utilized
for those  hazardous  wastes for which no adequate
treatment processes exist.
   Each  of the processes evaluated  by EPA is de-
scribed in this appendix in some detail. An assessment
of the waste handling capabilities is also  included.
The  most  widely applicable  processes are incinera-
tion, neutralization, and reduction.

             PHYSICAL TREATMENT
   Reverse  osmosis:  The  physical   transport  of  a
solvent across a membrane boundary, where external
pressure  is  applied  to  the  side  of less solvent
concentration so  that  the solvent will flow  in  the
opposite  direction. This allows solvent  to be  ex-
tracted  from a  solution,  so  that   the  solution is
concentrated  and the extracted solvent is  relatively
pure.  Almost any dissolved solid can be treated by
reverse, osmosis, provided the concentrations are not
too high and it is  practical to adjust the pH to range
from 3 to 8.
   Dialysis: A process by which various substances in
solution  having widely  different molecular weights
may be separated by solute diffusion through semi-
permeable  membranes.  The  driving  force  is  the
difference  in chemical activity of  the  transferred
species on  the two sides of the membrane. The oldest
continuing commercial  use of dialysis is in the textile
industry.  Dialysis  is  particularly  applicable  when
concentrations are high and dialysis  coefficients are
disparate. It is a suitable means of separation for any
materials on  the  hazardous  material  list that form
aqueous solutions.
   Electrodialysis' Similar to  dialysis in  that  dis-
solved solids  are  separated  from  their  solvent by
passage   through  a  semipermeable  membrane.  It
differs from  dialysis in  its dependence on an electric
field as the driving force for the separation. Electro-
dialysis is applicable when it is desired to separate out
a  variety  of ionized  species  from   an  un-ionized
solvent  such as water.  lonizable nitrates and phos-
phates [e.g.,  Pb(NO3)2, Na3PO4 | are removed with
varying degrees  of efficiency. With regard to NDS's,
electrodialysis is applicable for the treatment of waste
streams   for  which it  is  desirable  to reduce  the
concentrations  of ionizable  species in  the  inter-
mediate range (10,000 to 500 parts per million) over
a broad range of pH (e.g., 1 to 14).  If an effluent of
concentration lower  than 500  parts  per  million is
desired, the electrodialysis effluent could be fed into
another treatment process.
   Evaporation:  The  removal  of solvent  as  vapor
from  a solution or  slurry. This  is normally accom-
plished by bringing the solvent to its boiling point to
effect  rapid vaporization. Heat energy is supplied to
the solvent, and the vapor evolved must be continu-
ously removed from above the liquid phase  to prevent
its  accumulation.  The vapor may  or may not  be
recovered, depending on its value. Thus, the principal
function of evaporation is the transfer of heat to the
liquid  to be evaporated. Evaporation processes are
widely used throughout industry  for the concentra-
tion of  solutions  and for  the production of  pure
solvents.  Evaporation represents  the  most versatile
wastewater processing  method  available  that  is
capable of producing a high-quality effluent.  It is,
however,  one of  the most costly processes  and is
therefore  generally   limited  to   the  treatment  of
wastewater with  high solids concentrations  or  to
wastewater where  very high  decontamination  is
required (e.g., radioactive wastes).
   Carbon sorption: A process in which a substance
is brought into contact with a solid and is held at the
surface or internally  by physical and/or  chemical
forces. The solid is called the  sorbent and the sorbed
substance  is  called  the sorbate.  The  amount  of
sorbate held by a  given quantity of sorbent depends
upon several  factors, including  the  surface area per
unit volume  (or  weight)  of the  sorbent and  the
intensity  of  the attractive forces. Activated carbon
has been  historically used to  remove  organic and
other  contaminants from  water. Activated carbon
sorption has been used to remove dissolved refractory
organics  from municipal waste streams and to clean
up  industrial  waste  streams.  It has  been used  to
remove some heavy metals and other inorganics from
water. Carbon sorption can remove most types of
organic  wastes  from water.  Those  that  have low
removal  by carbon include  short carbon chain polar
substances  such  as  methanol,   formic  acid, and
perhaps acetone. This process is being utilized to treat
herbicide plant  wastes. Also,  full-scale carbon sorp-
tion units have been  successfully used for  petroleum
and petrochemical wastes.

-------
                   SUMMARY OF HAZARDOUS WASTE TREATMENT AND DISPOSAL PROCESSES
                                                                                                        61
   Ammonia  stripping:  The  removal  of ammonia
from alkaline  aqueous wastes by stripping with steam
at atmospheric pressure.  The waste stream, at or near
its boiling point, is introduced at the top of a packed
or  bubble  cap  tray-type  column  and  contacted
concurrently  with  steam. Ammonia, because of  its
high partial pressure over alkaline solutions, is readily
condensed and reclaimed for sale, and liquid effluents
from a properly designed steam stripping column will
be  essentially  ammonia free. This  process is quite
useful in the  treatment  of  ammonia-bearing wastes.
However,  it  can also  be  used  to remove various
volatile  and   organic   contaminants  from  waste
streams.
   Filtration:  The  physical removal  of  the solid
constituents from the aqueous waste stream by means
of a filter medium.  A slurry  is forced against the filter
medium. The  pores of the medium are  small enough
to prevent the passage of some of the solid particles;
others impinge on  the fiber of the  medium. Conse-
quently,  a cake builds up on the filter, and after the
initial deposition, the cake itself serves as the barrier.
The  capacity of this process is governed by the flow
rate  of the fluid filtrate through the bed formed by
the solid particles. Most of the  aqueous hazardous
waste streams  which contain solid constituents will be
treated by this process.
   Sedimentation   (settling)'  A  process  used   to
separate  aqueous waste streams  from  the particles
suspended  in  them.  The suspension is  placed  in a
tank, and the particles are allowed to settle out, the
fluid can then be removed from above the solid  bed.
The  final state is that of a  packed bed resembling a
filter  cake  if the process is allowed to continue long
enough.  Sedimentation  is  widely used throughout
industry  for treatment of waste streams for  which
there is a need for separation of precipitated solids
from the liquid phase.
   Floccidation:  A process  used when fine particles
in a  waste stream are difficult to separate from the
medium  in  which  they  are  suspended.  These waste
constituents are in the low and fractional micrometer
range of sizes, they settle too slowly for economic
sedimentation  and  are often difficult to filter. Thus,
this  process  is  applied  to gather these  particles
together  as flocculates,  which allows them to settle
much faster. The resulting sediment  is less dense and
is often mobile. The particles also filter more readily
into a cake which is permeable and does not clog.
Like  sedimentation,   flocculation is  widely  used
throughout industry for treatment of waste streams
for which there is a need for separation of precipi-
tated solids from the liquid phase.

            CHEMICAL TREATMENT
   Ion exchange: The reversible  interchange of ions
between  a solid and a liquid phase in which there is
no permanent change in the structure of the solid It
is a method of collecting and concentrating  undesir-
able materials from waste streams. The mechanism of
ion exchange  is chemical, utilizing resins that react
with either  cations or anions.  Ion exchange  tech-
nology has been available  and has been employed for
many  years  for removing objectionable  traces of
metals and  even cyanides  from  the  various waste
streams of the metal process industries. Objectionable
levels of fluorides, nitrates, and manganese have also
been removed from drinking water sources by means
of ion exchange. Technology has been developed to
the extent that the contaminants that are  removed
can be recycled, readily transformed into a harmless
state, or safely disposed of.
   Neutralization:  A   process  utilized  to  prevent
excessively acid or alkaline  wastes from being  dis-
charged in plant effluents. Some of the methods used
to neutralize such wastes are (1) mixing wastes such
that the  net  effect is a near-neutral pH,  (2) passing
acid wastes  through  beds of limestone,  (3) mixing
acid with lime slurries, (4) adding proper proportions
of concentrated solutions of caustic soda (NaOH) or
soda  ash to  acid  wastewaters,  (5)  blowing waste
boiler-flue gas through alkaline wastes,  (6) adding
compressed  CO2  to  alkaline  wastes,  (7) adding
sulfuric  acid  to alkaline wastes. Neutralization is
utilized  in   the   precipitation   of   heavy  metal
hydroxides or hydrous oxides and calcium sulfate.
   Oxidation:  A process  by which  waste  streams
containing reductants are  converted to a less hazard-
ous state. Oxidation may be achieved with chlorine,
hypochlorites, ozone,  peroxide, and  other common
oxidizing agents.   The   method  most  commonly
applied on  a large  scale is oxidation by chlorine.
Oxidation is used  in  the treating of cyanides and
other reductants

-------
62
                                     DISPOSAL OF HAZARDOUS V/ASTES
   Reduction- A process whereby streams containing
oxidants are treated with sulfur dioxide to reduce the
oxidants to less noxious materials. Other reductants
that can be used are sulfite salts and ferrous sulfate,
depending  on  the availability  and cost of  these
materials. Reduction is used to treat chromium-6 and
other oxidants.
   Precipitation.  A process of separating solid con-
stituents from an aqueous waste stream  by chemical
changes. In this process, the waste stream is converted
from one  with  soluble  constituents to one with
insol ble constituents  This process is applicable to
the  treatment  of waste  streams  containing  heavy
metals.
   Calcination' The  process  of   heating  a  waste
material to a high temperature  without fusing in
order to effect useful  changes,  such as oxidation or
pulverization. Calcination is commonly applied in the
processing of high-level radioactive wastes.
             THERMAL TREATMENT
   Incineration:  A controlled process to convert  a
waste to  a less  bulky,  less toxic, or less noxious
material. Most incineration systems contain four basic
components  a waste  storage facility, a burner and
combustion chamber, an effluent  purification device
when warranted,  and a vent or a stack. The 11 basic
types  of  incineration  units are open pit,  open
burning, multiple chamber, multiple hearth, rotary
kiln,  fluidized  bed,   liquid  combustors,  catalytic
combustors, afterburners, gas combustors, and stack
flares  The type  of waste for which each  of these
incineration units is best  suited is detailed  diagram-
matically in Figure 6.
   Pyrolysis  The thermal decomposition of a com-
pound  Wastes are subjected to temperatures of about
1200 F t- 300 F (650 C ± 150 C), depending upon the
nature  of  the wastes, in an essentially oxygen-free
atmosphere. Without oxygen, the wastes cannot burn
and are broken down (pyrolyzed) into steam, carbon
oxides,  volatile vapors, and charcoal. Most municipal
and industrial  wastes that are  basically organic in
nature can be converted to coke or activated charcoal
and gaseous mixtures which may approach natural gas
in heating values through the utilization  of pyrolysis.
           BIOLOGICAL TREATMENT
    Activated sludge:  A process in which biologically
active growths are continuously circulated and con-
tacted with organic waste in the presence of oxygen.
Normally,  oxygen is supplied to the system in the
form  of fine air bubbles under turbulent conditions.
The activated sludge is composed of the biologically
active  growths  and contains  micro-organisms  that
feed on the organic waste. Oxygen is required  to
sustain  the growth  of the micro-organisms.  In the
conventional  activated  sludge  process,  incoming
wastewater  is mixed  with recycled activated sludge
and the mixture is  aerated for  several hours in  an
aeration tank. During this period, adsorption, floccu-
lation,  and various  oxidation reactions take place
which  are  responsible for removing much of the
organic matter  from  the  wastewater.  The  effluent
from  the aeration tank is  passed to a sedimentation
tank where  the flocculated micro-organisms or sludge
settles out  A portion of this sludge is recycled as seed
to  the  influent  wastewater.  The  activated sludge
process  has been applied  very  extensively  in  the
treatment  of refinery,  petrochemical, and  biode-
gradable organic wastewaters.
   Aerated lagoon: The use of a basin of significant
depth [usually 6 to 17 feet (1.83 to 5.19 meters) | in
which  organic waste stabilization is accomplished  by
a  dispersed  biological growth system and where
oxygenation is provided by mechanical or diffused
aeration equipment.  Aerated lagoons have been used
successfully as an economical  means to treat indus-
trial  wastes where  high-quality  effluents  are  not
required.
   Trickling filter' The use of artificial beds of rocks
or other porous  media through which the liquid from
settled organic waste is percolated. In the process, the
waste is brought into contact with air and biological
growths. Settled liquid is  applied intermittently or
continuously over the top surface  of the  filter  by
means of a distributor. The filtered liquid is collected
and discharged at the  bottom. The primary  removal
of  organic  material  is  not  accomplished  through
filtering or  straining action. Removal is the result of
an  adsorption  process  similar to  activated sludge
which occurs at  the surfaces of the biological  growths
or slimes covering the filter media. Trickling filters
have been  used  extensively in  the treatment of such
industrial  wastes  as  acetaldehyde,  acetic   acid,
acetone,  acrolein,  alcohols,  benzene,  butadiene,
chlorinated  hydrocarbons, cyanides, epichlorohydrin,
formaldehyde,  formic acid, ketones, monoethanol-

-------
                  SUMMARY OF HAZARDOUS WASTE TREATMENT AND DISPOSAL PROCESSES
                                                                                                        63
     SOLIDS
    LIQUIDS
      GASES
                                                                                            SECONDARY
                                                                                            ABATF.ME NT
                                                                                             E-UUIPMt NT
                               Figure 6, Types of incinerators and their applications.
amines,  phenolics,   propylenedichloride,   terpenes,
ammonia,  ammonium   nitrate,  nylon  and nylon
chemical intermediates, resins, and rocket fuels.
   Waste  stabilization   ponds: The   use   of large
shallow basins [usually  2 to 4  feet  (0.61  to  1.22
meters) deep]  for  the  purpose  of purifying waste-
water by storage under climatic conditions that favor
the growth  of algae. The conversion  of organics to
inorganics, or stabilization, in such ponds results from
the combined  metabolic activity of  bacteria, algae,
and surface  aeration. Waste stabilization ponds have
been widely used where  land is plentiful and climatic
conditions are favorable. They have been used exten-
sively in treating industrial wastewaters when a high
degree of purification is not required. More recently,
stabilization  ponds have proven to be successful m
treating steel mill wastes

              ULTIMATE DISPOSAL
   Landfill disposal' A  well-controlled arid  sanitary
method of disposal of  wastes upon land. Common
landfill disposal methods are (1) mixing with soil. (2)
shallow burial, (3) combinations of these. The utiliza-
tion of landfill proceduies for the disposal of certain
hazardous waste materials at an NDS, in an industrial
environment,  or  in municipal applications  will un-
doubtedly be required in the future,
   Deep-well  disposal.  A system  of disposing of raw

-------
64
                                     DISPOSAL OF HAZARDOUS WASTES
or treated filtered  hazardous waste by pumping it
into deep wells where it is contained in the pores of
permeable subsurface  rock separated from  other
groundwater  supplies by impermeable  layers of rock
or clay.  Subsurface  injection  has been extensively
used  in  the  disposal of oil  field brines  (between
10,000 and 40,000  brine injection wells in the United
States).  The  number of industrial waste  injection
wells in the United  States has increased to more than
100. Injection wells can be used by virtually any type
of  industry  that   is  located in  a  proper geologic
environment  and that has a waste product amenable
to this method. Some industries presently using this
method  are  chemical  and  pharmaceutical plants,
refineries, steel and metal industries, paper mills, and
coke plants.
   Land   burial  disposal: A method  adaptable  to
those hazardous materials  that  require  permanent
disposal.   Disposal  is  accomplished  by either  near-
surface  or deep burial. In  near-surface burial, the
material is deposited  either directly into the ground
or is deposited  in  stainless steel tanks or concrete-
lined pits beneath  the ground.  In  land burial, the
waste is  transported  to a selected site where it is
prepared  for final  burial.  At   the  present  time,
near-surface burial  of both radioactive and chemical
wastes  is  being conducted  at  several   AEC and
commercially operated burial sites. Pilot plant studies
have  been conducted for deep burial  in salt forma-
tions and hard bedrock. Land  burial is a  possible
choice  for the  hazardous  materials that require
complete  containment and  permanent disposal. This
includes  radioactive  wastes as well as highly  toxic
chemical  wastes. At the  present time, only   near-
surface burial is used for the disposal of most wastes.
   Ocean  dumping.  The  process of  utilizing  th
ocean as  the ultimate disposal sink for all types of
waste materials  (including hazardous wastes).  There
are three  basic  techniques for ocean disposal  of
hazardous wastes. One technique is bulk disposal for
liquid  or slurry-type  wastes. Another technique  is
stripping obsolete or surplus World War II cargo ships,
loading the  ships with  obsolete munitions,  towing
them   out  to  sea,  and  scuttling  them  at some
designated spot. The third technique is the sinking at
sea of containerized  hazardous toxic wastes. The
broad  classes of hazardous wastes dumped at sea have
been   categorized   as  follows'   industrial   wastes,
obsolete,  surplus, and nonserviceable  conventional
explosive ordinance; chemical warfare wastes; and
miscellaneous hazardous wastes.
   Engineered  storage. A  potential system  to  be
utilized for those hazardous wastes (especially radio-
active) for which no adequate disposal methods exist.
An engineered storage facility would  have applica-
bility  until such time as a method for permanent
disposal of these  wastes is developed. A near-ground-
surface engineered storage facility must provide safe
storage of the solidified  hazardous wastes for long
periods of time and retrievability of the wastes at any
time  during this storage.  The  ultimate goal is  to
transfer  these  wastes  to a permanent disposal  site
when  a suitable  site is found.  This process is being
proposed for  the  long-term storage  of high-level
radioactive wastes, some  low-level radioactive wastes
will   probably   also  go  into  engineered   storage
facilities.
   Detonation: A process of exploding a quantity of
waste  with  sudden  violence.  Detonation  can  be
performed by  several  means which include thermal
shock,  mechanical  shock, electrostatic  charge,  or
contact with incompatible materials. Detonation of a
single  waste may be  followed by secondary explo-
sions  or fire. Detonation is most  commonly  applied
to explosive waste materials. However, several flam-
mable waste streams can also be detonated.

-------
                                        Appendix  E
                   DECISION MAPS FOR ON-SITE VERSUS
                   OFF-SITE TREATMENT AND DISPOSAL
   When a hazardous waste generator elects to treat
or dispose  of his  hazardous waste in an environ-
mentally acceptable manner,  he  must make the
important economic decision as to whether a particu-
lar waste stream should be processed on site or off
site at some regional treatment  facility. In order to
make  a sound  business  decision  between  these
options,  an  industrial  manager must consider  a
number  of  variables   such  as  the following: the
chemical composition of the particular  waste stream,
the on-site availability and  unit cost of a satisfactory
treatment process, the quantity of the waste stream,
and the  distance to and user charge of the nearest
off-site processing facility.
   To provide a general insight into the economics of
this problem,  information  was  compiled on  eight
commonly  occurring   industrial hazardous  waste
stream types, and a mathematical model was formu-
lated. The mathematical model resulted in economic
decision maps for each of the eight industrial waste
categories (Figures  7  through  15).  (Nine  decision
maps appear because two maps are included for heavy
metal sludges.)
   As a result of this analysis, it was concluded that
economic considerations favor the off-site treatment
and disposal of seven out  of the eight waste stream
types  examined.  Only  in the case of dilute aqueous
heavy metals  (Figure 15)  is the strategy of on-site
treatment more economical.
   The decision map for concentrated  heavy metals
(Figure  7) is  typical. The following discussion will
identify and interpret, point by  point,  those aspects
of the map that are considered significant.
   Point A on the map represents data collected for a
sample of actual waste sources. This point is defined
by the mean separation between  sources (the average
distance between some waste sources actually found
within  a particular region) and the mean source size
(size as measured by  waste  stream  volume).  The
position of Point  A on the map  shows whether the
on-site or off-site treatment alternative is economi-
cally  preferable.  Here,  Point  A lies  comfortably
within  the  "off-site" region of the map, therefore,
off-site treatment  of wastes collected from multiple
sources is the most logical choice.
   The vertical lines corresponding to  the smallest
and largest  sources in the sample  are also shown for
perspective. For each of the stream types, an attempt
was made to include the largest single producer of the
waste in the country.
   Two other points on the map are of interest. Point
B defines the  separation between  sources that would
be required if on-site processing is  to be feasible.
assuming no change  in the sample mean. For concen-
trated heavy  metals, this change-of-strategy separa-
tion distance is 360  miles (580 kilometers) compared
to the mean value of 81 miles (131 kilometers)
   Point C  defines  the source  size at which on-site
processing becomes  feasible for sources separated by
the sample mean separation. For concentrated heavy
metals,  this size  is 16  million gallons (61 million
liters) per year, compared  to  the sample  mean of
325,000 gallons (1.2 million liters)  per year and a
sample maximum of  950,000 gallons  (3.6 million
liters) per year. Clearly, off-site processing is prefera-
ble for concentrated heavy metal wastes. A mean
volume  concentrated  heavy metal waste producer
would  have to be nearly 400 miles (640 kilometers)
from any other similar waste producer before on-site
treatment would become attractive.
   An examination of the  succeeding eight decision
maps (Figures 8 through 15) makes it apparent  that
                                                 65

-------
66
               37,850

           1,000
                            DISPOSAL OF HAZARDOUS WASTES


                                  SOURCE SIZE (liters/yr)

                    378,500              3,785,000             37,860,000
         a>
         UJ
         O
         DC
         n
         o
         i-
         UJ
         03

         Z
         O
         z
         <
         UJ
100
              10
                                                                     ON-SITE TREATMENT
                                                378,500,000

                                               	11,610
                SMALLEST

                 SOURCE
                               MEAN SOURCE
               1

              10,000
                                     I
                                                LARGEST SOURCE
                                                                    OFF-SITE TREATMENT
                                                                               I
                                                            tn
                                                            uj
                                                            O
                                                            oc

                                                        161 o
                                                            §

                                                            UJ
                                                            m

                                                            z
                                                            O


                                                        16.1 <

                                                            <
                                                            a.
                                                            u
                                                                                                         UJ
                                                                                                         s
                     100,000
                                                      1,000,000

                                                SOURCE SIZE (gal/yr)
                             10,000,000
                                                                              1.6

                                                                      100,000,000
                                         Figure 7. Concentrated heavy metals.
    37,850

 1,000
     1

   10,000
            378,500
   SOURCE SIZE

3,785,000
                                        liters/yr)

                                          37,850,000
                                                                       378,500,000
3,785,000,000
        1,610
                                                                                                           - 161
                                                                                                           - 16.1
                                                                                                      W
                                                                                                      UJ
                                                                                                      O
                                                                                                      oc
                                                                                                      3
                                                                                                      O
                                                                                                      w

                                                                                                      z
                                                                                                      ui
                                                                                                      UJ
                                                                                                      Z

                                                                                                      UJ
                                                                                                      CD

                                                                                                      Z
                                                                                                      O
                                                                                                                   UJ
                                                                                                                   5
100,000            1,000,000          10,000,000

                       SOURCE SIZE (gal/yr)


            Figure 8.  Dilute metals with organic contamination.
                                                                     100,000,000
                                                                1.6

                                                        1,000,000,000

-------
                 DECISION MAPS FOR ON-SITE VERSUS OFF-SITE TREATMENT AND DISPOSAL
                                                                                                                 67
                     37,850
                                             SOURCE SIZE  (liters/yr)

                                           378,500             3,785,000          37,850,000
                                                                              378,500,000
                                                                                     1,610
   ,000
                      10,000
                   100,000             1,000,000           10,000,000

                      SOURCE SIZE (gal/yr)

       Figure 9. Asphalt encapsulation of heavy metal sludges.
                                                                1 6
                                                         100,000,000
    3,785
1,000
37,850
SOURCE SIZE (liters/yr)

378,500           3,785,000
                                                              37,850,000
378,500,000
       1,610
                                                                                                           - 161
                                                                                          O
                                                                                          cc
                                                                                          D
                                                                                          O
                                                                                          C/J
                                                                                          2
                                                                                                                  2
                                                                                                                  O
                                                                                                           - 1G 1
                       10,000               100,000            1,000,000

                                              SOURCE SIZE (qal/yr)
                                                          10,000,000
                                                                                                             1 6
                                                                               100,000,000
                               Figure 10. Cement encapsulation of heavy metal sludges.

-------
 68
                                         DISPOSAL OF HAZARDOUS WASTES
      3,785
                     37,850
                       SOURCE SIZE (liters/yr)

                    378,500             3,785,000
                                                                                   37,850,000
 1,000
in
U
X.
D
O

-------
                   DECISION MAPS FOR ON-SITE VERSUS OFF-SITE TREATMENT AND DISPOSAL
                                                                                                                69
            1,000
         CO
         111
         u
         o
         CO

         z
         111
         LU
         5
         h
         III
         CD

         Z
         O


         <
         c
         <
         Q.
         UJ
         CO

         Z
                 3,785
                                 37,850
                        SOURCE SIZE (liters/yr)


                                378,500
                                3,785,000
        37,850,000

               1,610
             100  -
                                                                            \      ON-SITE

                                                                                TREATMENT
                                                                                               -  161
                                                                         - 16.1
                 1,000
            10,000             100,000

                        SOURCE SIZE (gal/yr)


                      Figure 13. Dilute cyanides.
                                                                        1,000,000
                                                                                                  1.6
                                                 10,000,000
                                                                                 in
                                                                                 HI
                                                                                 O
                                                                                 DC
                                                                                 Z
                                                                                 UJ
                                                                                 UJ


                                                                                 (-
                                                                                 UJ
                                                                                 CO

                                                                                 Z
                                                                                 O
                                                                                 0.
                                                                                 LU
                                                                                 CO

                                                                                 Z
    37,850

10,000
  378,500
     SOURCE SIZE (liters/yr)


 3,785,000           37,850,000
378,500,000
3,785,000,000

       16,100
        SMALLEST SOURCE

         AT 1,000 gal/yr
   10

   10,000
100,000
1,000,000          10,000,000

    SOURCE SIZE (gal/yr)
                                                          100,000,000
                        16.1

                 1,000,000,000
                            Figure 14. Chlorinated hydrocarbon and heavy metal slurries.

-------
 70
                                      DISPOSAL OF HAZARDOUS WASTES
  1,000
       3,785
                         37,850
                                        SOURCE SIZE (liters/yr)

                                      378,500            3,785,000
                                      37,850,000
                                                                                               378,500,000
                                                                                                       1,610
UJ
0
IT
D
O
tf>
z
UJ
UJ
g
h
UJ
CO

2
O


<
c
UJ
in
100 —
                                                                                                — 161
                                                                  tn
                                                                  UJ
                                                                  O
                                                                  It
                                                                  D
                                                                  O
                                                                                                        UJ

                                                                                                        h
                                                                                                        LU
                                                                                                        CD

                                                                                                        Z
                                                                                                        o
                                                                                                       16.1
                                                                                                        CL
                                                                                                        UJ


                                                                                                        Z

                                                                                                        LU

                                                                                                        5
       1,000
                   10,000
100,000            1,000,000

    SOURCE SIZE (gal/yr)


Figure 15.  Dilute heavy metals.
10,060,000
         1.6

100,000,000
each is different because each particular waste stream

has its own cost characteristics as a result of different

treatment and/or  disposal requirements. Only in the

case  of dilute  heavy  metals  (Figure  15)  is  the

above-defined Point A within the "on-site" region of

the map. Accordingly, the average generator of dilute
                                                      heavy  metal wastes  would  logically choose  on-site

                                                      treatment.  Development of the model on which the

                                                      decision  maps  are  based was made in an  earlier

                                                      study.31  Included among other important results of

                                                      that particular study are discussions of location and

                                                      spacing of regional treatment facilities.

-------
                                       Appendix F

                  SUMMARY OF THE HAZARDOUS WASTE
                     NATIONAL DISPOSAL SITE CONCEPT
   In the course of investigating the NDS concept for
hazardous wastes as mandated by Section 212 of the
Solid Waste Disposal Act (P.L. 89-272, amended by
P.L. 91-512), important and relevant information was
developed. Appendixes B and D, respectively, provide
a list of hazardous wastes subject to treatment at such
sites and summaries of current methods of treatment
and disposal. This  appendix summarizes the findings
related to site selection, methods and processes that
are likely to be used  at a typical site, and costs for
developing  and maintaining such sites.  An earlier
study  contains the detailed analyses performed and
the rationale for this information.1
  SITING OF HAZARDOUS WASTE TREATMENT
          AND DISPOSAL FACILITIES
   The general approach to the site selection process
was to  first  regionalize  the  conterminous  United
States  into  41 multicounty regions (spheres of
influence for major industrial waste production areas,
which are closely related to hazardous waste produc-
tion areas, served  as  the basis for regional delinea-
tion).
   (1) Seattle,  Tacoma, Everett, and  Bellingham,
Washington
   (2) Portland, Oregon; Vancouver and Longview,
Washington
   (3) San Francisco Bay Area, California
   (4) Ventura,   Los  Angeles,  and Long Beach,
California
   (5) San Diego, California
   (6) Phoenix, Arizona
   (7) Salt Lake and Ogden, Utah
   (8) Idaho Falls and Pocatello, Idaho
   (9) Denver, Colorado
   (10) Santa Fe and Albuquerque, New Mexico
   (11) El Paso, Texas
   (12) Fort Worth, Dallas, and Waco, Texas
   (13) Austin,  San A ttonio, and  Corpus  Christi,
Texas
   (14) Houston,  Beaumont,  Port  Arthur,  Texas
City, and Galveston, Texas
   (15) Oklahoma  City,  Tulsa,  and  Bartlesville,
Oklahoma
   (16) Wichita, Topeka, and Kansas City, Kansas
   (17) Omaha and Lincoln, Nebraska;  Des Moines,
Iowa
   (18) Minneapolis, St. Paul, and Duluth, Minnesota
   (19) Cedar  Rapids,  Michigan;  Burlington  and
Dubuque, Iowa; Peoria, Illinois
   (20) St. Louis, Missouri; Springfield, Illinois
   (21) Memphis, Tennessee
   (22) Shreveport, Baton Rouge, and New Orleans,
Louisiana; Jackson, Mississippi
   (23) Mobile  and  Montgomery,  Alabama; Talla-
hassee, Florida;  Biloxi and  Gulf port,  Mississippi,
Columbus, Georgia
   (24) Huntsville  and  Birmingham,  Alabama;
Atlanta and Macon, Georgia; Chattanooga and Nash-
ville, Tennessee
   (25) Louisville, Frankfort, and  Lexington,  Ken-
tucky, Evansville, Indiana
   (26) Albany,  Troy, and Schenectady, New York
   (27) Indianapolis, Indiana; Cincinnati and  Day-
ton, Ohio
   (28) Chicago and Kankakee, Illinois; Gary, South
Bend, Hammond, and Fort Wayne, Indiana
   (29) Midland,  Saginaw, Grand Rapids,  Detroit,
Dearborn, and Flint, Michigan, Toledo, Ohio
   (30) Columbus,  Cleveland,  Youngstown,   and
Akron, Ohio
                                               71

-------
72
                                    DISPOSAL OF HAZARDOUS WASTES
   (31)  Pittsburgh,  Johnstown,  and  Erie, Pennsyl-
vania
   (32)  Charleston, West Virginia; Portsmouth  and
Norfolk, Virginia
   (33)  Charleston, South Carolina;  Savannah  and
Augusta, Georgia
   (34)  Winston-Salem,  Raleigh,  Greensboro,  and
Charlotte, North Carolina
   (35)  Baltimore, Maryland
   (36)  Philadelphia,   Allentown,   and  Harrisburg,
Pennsylvania;  Camden and Elizabeth,  New  Jersey;
Wilmington, Delaware
   (37)  New York, New York; Newark and Paterson,
New Jersey
   (38)  Buffalo,  Rochester,  Syracuse, and  Water-
town, New York
   (39)  Boston, Massachusetts
   (40)  Orlando, Tampa, and Miami, Florida
   (41)  Little Rock,  Pine Bluff,  and Hot Springs,
Arkansas
Thirty-six  waste treatment regions were  identified,
based upon the distance from the 41 major industrial
waste production centers. These  are shown in Figure
16  Distances of about 200 miles (322 kilometers) in
the East and 250 miles (402  kilometers) in the West
were  selected as the  maximum  distances any treat-
ment site  should  be  from  the  industrial  waste
production centers in  a given subregion. Some of the
regions do not contain an industrial waste production
center;  however,  their boundaries are defined  by
surrounding regions containing waste production cen-
ters. No region was generally permitted to cross any
major physiographic barrier. Notably,  the  regions are
smaller in the East than in the West.
   Criteria for site  selection were defined. The major
emphasis  was  placed  on health  and  safety  and
environmental considerations. It  was recognized early
that two  general types  of sites would need to be
identified:  waste processing plant sites and long-term
hazardous  waste  disposal and  storage  sites   Site
selection criteria and  numerical weightings are pre-
sented in Table 12.
   Based on  the site  selection  criteria,  a ranking,
screening,  and weighting  procedure  was developed
and  applied to all  counties located in the 36 regions
which cover  the country. The county-size areal unit
appeared to be of manageable size for the survey. The
output  lising  of all  3,050 counties in  the conter-
minous United States, grouped by regional ratings, is
too  voluminous  for inclusion  here.1  This  listing
allows for  the orderly and  rational  selection of
counties within each region, for site-specific  recon-
naissance, and for later detailed field studies  that
would be required in order to prove out the feasibil-
ity  of a candidate site. From the total list that rates
and ranks all counties, 74 appear to be potentially the
best areas for locating hazardous waste treatment and
disposal  sites.  These are  presented  as  follows by
State-
     State.
     Alabama
     Arizona

     California
      Colorado
      Connecticut
      Florida
      Georgia
      Iowa
      Illinois
      Indiana
      Kansas
      Kentucky
      Maryland
      Massachusetts

      Michigan

      Mississippi
      Missouri
      Montana
      Nebraska
      Nevada
      New Jersey
County:
Sumter*
Dallas
Yuma
Fresno
Inyo
Kern*
Ventura
Weld
Hartford
Alachua
Dooley*
Howard
Jasper
Livingston*
Ogle
Vermilion
Jackson
Ellsworth
Franklin
Carroll
Franklin*
Worcester
Isabella*
Shiawassee
Lincoln
Audrain
Custer
Kearney
Nye*
Pershing
Washoe
Sussex
      *Potential site for large-size processing facility.

-------
SUMMARY OF THE HAZARDOUS WASTE NATIONAL DISPOSAL SITE CONCEPT
73
                                                                           a
                                                                           o
                                                                           •&
                                                                           I
                                                                           I

-------
74
                                    DISPOSAL OF HAZARDOUS WASTES
                   TABLE 12
            SITE SELECTION CRITERIA
            General criteria
        Total
                                         Weighting
Earth sciences (geology, hydrology. soils,
   climatology)                                   31
Transportation (risk, economics)                     28
Ecology (terrestrial life, aquatic life, birds and
   wildfowl)                                     18
Hu.nan envnonment and resources utilization
   (demography, resource utilization, public
   acceptance)                                   23
     Virginia
     Washington

     West Virginia
     Wyoming
Brunswick
Caroline
Fluvana
Pittsylvania
Benton
Lincoln
Doddridge
Campbell
Laramie
                                              100
New Mexico


New York




North Dakota
Ohio


Oklahoma


Oregon
Pennsylvania


South Carolina

Tennessee

Texas








Utah
Eddy
Quay
San Juan
Albany
Onondaga
Otsego
Steuben
Wyoming
Grand Forks
Carroll
Darke
Wayne
Atoka
Custer
Kay
Deschutes
Clinton
Montgomery
York*
Barnwell
Greenwood
Gibson
Montgomery
Bell
Erath*
Gillespie
Grimes
Harris*
Haskell
Kendall
Polk
Sutton
Tooele
In addition, the following are the existing or potential
Federal and  State  hazardous  waste treatment and
disposal sites:
   Existing sites operated by AEC:
        Fernald, Butler/Hamilton Counties, Ohio
        Hanford Works, Benton County, Washington
        Los   Alamos   Scientific  Laboratory,  Los
           Alamos County, New Mexico
        National Reactor  Testing Station, Bingham
           County, Idaho
        Nevada Test Site, Nye County, Nevada
        Oak Ridge, Anderson County, Tennessee
        Pantex Plant, Randall County, Texas
        Rocky  Flats  Plant,   Jefferson  County,
           Colorado
        Savannah River Plant,  Aiken County, South
           Carolina
   Existing sites operated by DOD:
        Anniston Army Depot, Alabama
        Edgewood Arsenal, Maryland
        Lexington Bluegrass Army Depot, Kentucky
        Newport Army Ammunition Plant, Indiana
        Pine Bluff Arsenal, Arkansas
        Pueblo Army Depot, Colorado
        Rocky Mountain Arsenal, Colorado
        Tooele Army Depot, Utah
        Umatilla Army Depot, Oregon
   State-licensed radioactive waste sites1*
        Barnwell, South Carolina
        Beatty, Nevada
        Hanford Works, Washington
        Morehead, Kentucky
        West Valley, New Yo:k
      ''Potential site for large-size processing facility
      *The Sheffield, Illinois, site is directly licensed through
AEC jut is not operated by AEC,

-------
                  SUMMARY OF THE HAZARDOUS WASTE NATIONAL DISPOSAL SITE CONCEPT
                                                                                                           75
Data  on the  Beatty,  Nevada; Hanford,  Washington,
and  Morehead,  Kentucky,  sites  are presented  in
Tables 13 to 15
   It  should  be  noted  that  the suitability  of a
particular candidate site  can only be determined by
additional  field studies,  field testing, and technical
analyses of the data.
HAZARDOUS WASTE MANAGEMENT METHODS
                   AND COSTS
   The  approach  used  in  this  phase of the study
involved development of a model facility capable of
processing a wide  variety  of hazardous  wastes (ex-
cluding radioactive wastes or chemical warfare agents
generated or  stored  at  AEC  or DOD installations).
Conceptual design  and cost estimates were prepared
for a complete waste  management system to  process
and dispose of the wastes. In addition to treatment
and disposal, peripheral functions such as transporta-
tion, storage, and environmental  monitoring were also
considered.
   The  basic  objective  of  waste  treatment  at a
hazardous  waste  processing facility is the conversion
                    of hazardous substances to forms that are acceptable
                    for disposal or reuse. Since the majority of hazardous
                    waste  streams  are  complex  mixtures  containing
                    several  chemical  species,  treatment  for   removal
                    and/or conversion of certain nonhazardous substances
                    from the waste stream will also be required  in order
                    to comply with pollution control regulations. In a
                    number of instances,  treatment for the nonhazardous
                    substances  will dictate the type of process used and
                    will entail the most significant operational costs (e.g.,
                    acid neutralization).
                       Broad treatment capability in a central processing
                    facility  will  permit  the  processing  of many  non-
                    hazardous  wastes  which  could give the facility the
                    advantage of economy of scale. In order to maintain a
                    competitive position  in  the waste processing field in
                    the  case  of  a  privately operated   facility,   it  is
                    anticipated  that all  wastes which can be processed
                    with some return on investment will be accepted. It is
                    possible that the volume  of nonhazardous wastes will
                    exceed the volume of hazardous  wastes, perhaps by
                    wide  margins, in  many  areas.  Inclusion  of  non-
                                                 TABLE 13
              REPRESENTATIVE COMMERCIAL RADIOACTIVE WASTE BURIAL SITE CHARACTERISTICS
                                           BEATTY, NEVADA, SITE
    Ownership
    Population density in area
    Distance from nearest town
    Area
          Site
          Controlled land
    Communications
    Precipitation
    Drainage
    Bedrock
          Depth
          Type
    Surficial material
          Depth
          Type
    Groundwater:
          Depth
          Slope
    Land and water use downstream
    General soil characteristics
    Monitoring instruments and devices
    Trenches:
          Dimensions
          Design
    Waste handling
          Transportation
          Machinery
          Processing
          Burial
State of Nevada, leased to the Nuclear Engineering Company, Inc
Virtually uninhabited
About 12 miles (19 kilometers) southeast of Beatty

80 acres (32 hectares)
No land controlled—desert
Good; U.S. highway 95
2 5-5.0 inches (6,35-12.7 centimeters) per year
Adequate

Estimated to be 575+ feet (175+ meters)
Sedimentary and metamorphic

575 feet (175 meters)
Alluvial clay, sand, etc.

275-300 feet (84-92 meters)
Southeast, approximately 30 feet per mile (5.67 meters per kilometer)
Very little, desert conditions
Semiand desert; deep soil
14 survey instruments, film, air monitors, etc.

650 by 50 by 20 feet  (198 by 15.2 by 6.1 meters)
Standard, drain to sump; 4-foot (1.2-meter) backfill, no water collected

By company
Tank truck, trailer trucks, bulldozer, 35-ton crane
Liquids solidified
Special nuclear materials spaced at bottom, slit trench for high-activity materials

-------
76
                                      DISPOSAL OF HAZARDOUS WASTES
                                                 TABLE 14
           REPRESENTATIVE COMMERCIAL RADIOACTIVE WASTE BURIAL SITE CHARACTERISTICS;
                                       HANFORD, WASHINGTON, SITE
    Ownership
    Population density in area
    Distance from nearest town
    Area-
         Site
         Controlled land
    Communications
    Precipitation
    Drainage
    Bedrock:
         Depth
         Type
    Surficial material:
         Depth
         Type
    Groundwater:
         Depth
         Slope
    Land and water use downstream
    General soil characteristics
    Monitoring instruments and devices
    Trenches:
         Dimensions
         Design
    Waste handling:
         Transportation
         Machinery
         Processing
         Burial
State of Washington, leased to the Nuclear Engineering Company, Inc.
No resident population
25 miles (40 meters) north of Richland

100 acres (40 hectares)
1,000 acres (405 hectares) State owned
Good; AEC Hanford reservation
6-8 inches (15-20 centimeters) per year
Well drained

Estimated to be 250-450 feet (76-137 meters)
Basalt

150-350 feet (47-107 meters)
Silty sand, gravel, clay

240 feet (73 meters)
North and east, approximately  15-35 feet per mile (2.8-6.6 meters per kilometer)
Columbia River—all uses
Little precipitation; deep, dry soil
Survey  instruments, film, counters

300 by 60 by 25 feet (92 by 18 by 7.6 meters)
Standard; no water collects in sump

By companv
Crane, shovel, bulldozer, forklifts, etc.
Liquids solidified
Special nuclear materials spaced; separate trench for ion-exchange resins
hazardous  waste processing also increases  the oppor-
tunities  for  resource  recovery  (e.g.,  recovery  of
metals, oils, and solvents).
   It  must be  emphasized that  the  model facility
developed  in this  study was  primarily  designed for
processing hazardous wastes.  Therefore,  processing
facilities  designed for  both  hazardous wastes and
nonhazardous  wastes  may  be  different  in  many
respects. A number of factors will dictate individual
design variations for a given facility. Foremost will be
the volumes and types of wastes, both hazardous and
nonhazardous, that will be received  for  processing.
One  facility  may  require  many  different processes
whereas  another may  require only one. Furthermore,
processes  selected  for  the model facility are  not
inte ided to  be  all  inclusive. A  wide  variety  of
processes,  in addition to those selected for the model
faciLty,  is available to meet the needs of a particular
location.
                          DESCRIPTION OF MODEL FACILITIES

                             Hazardous Waste Processing Facility
                       The  model hazardous waste processing  facility
                    incorporates  the  various functions related to waste
                    treatment and disposal at one  central location.  The
                    facility is basically a chemical  processing  plant  that
                    has  design features for safe operation in a  normal
                    industrial area. Effluents discharged from the facility
                    will be  limited to  those that meet applicable water
                    and air  standards.  Local solid waste disposal will be
                    limited  to nonhazardous wastes that are  acceptable
                    for burial at a conventional landfill. The conventional
                    landfill  may  be located adjacent  to the  processing
                    facility  or a  short distance away. In general,  non-
                    hazardous  waste  brines resulting from  hazardous
                    waste treatment will be disposed of by ocean dump-
                    ing  where appropriate to  avoid potential  quality
                    impairment of fresh  water sources. Land disposal of

-------
                   SUMMARY OF THE HAZARDOUS WASTE NATIONAL DISPOSAL SITE CONCEPT
                                                                                                              77
                                                   TABLE 15
               REPRESENTATIVE COMMERCIAL RADIOACTIVE WASTE BURIAL SITE CHARACTERISTICS:
                                          MOREHEAD, KENTUCKY, SITE
  Ownership
  Population density in area
  Distance from nearest town
  Area:
       Site
       Controlled land
  Communications
  Precipitation
  Drainage
  Bedrock
       Depth
       Type
  Surficial material:
       Depth
       Type
  Groundwater
       Depth
       Slope
  Land and water use downstream
  General soil characteristics
  Monitoring instruments and devices
  Trenches
       Dimensions
       Design
  Waste handling'
       Transportation
       Machinery
       Processing
       Burial
State of Kentucky, leased to the Nuclear Engineering Company, Inc.
Sparse (rural- Maxey Flats)
10 miles (16 kilometers) northwest of Morehead

200 acres (81 hectares)
1,000 acres (405 hectares)
Fair; State highway runs north and south
46 inches (117 centimeters) per year (heavy storms)
Well drained

Estimated to be 50-75 feet (15-23 meters)
Shale, sandstone, siltstone

Estimated to be 50-75 feet (15-23 meters)
Shale, clay, siltstone

35-50 feet (11-15 meters) ["perched" 2-6 feet (0.61-1.83 meters)]
Erratic
Very little nearby; no data exist at great distances
Very impermeable; good soil sorption
14 survey instruments, film, air monitors, etc.

300 by  50 by 20 feet (92 by 15 by 6.1 meters)
Standard, sump; water is pumped

By company
Crane, bulldozer, forklifts, etc.
Liquids solidified
Performed according to the Radiation Safety Plan developed by the Nuclear Engineering
   Company, Inc.
these brines is  a potential alternative method that is
less  desirable  and  that will be  used  only in arid
regions, and even there infrequently. All such disposal
operations will be in accordance with applicable  local,
State, and Federal standards.
   In order to accomplish  treatment  and  disposal
objectives,  the  facility  will  also  contain equipment
and  structures  necessary for transporting, receiving,
and  storing both wastes and raw material. Another
important feature will be a laboratory which provides
analytical services for process control and monitoring
of effluent and environmental samples and pilot scale
testing services  to assure satisfactory operation of the
processing plant.  The latter  normally is not required
in a conventional chemical processing plant, but
because  of the highly  variable nature  of the waste
feed  in  this  case,  pilot scale  testing is considered
essential.
                                 Hazardous Waste Disposal Facility
                          For  purposes of  the  model, the hazardous waste
                       disposal facility will consist of a secure landfill and
                       the appropriate equipment and  structures necessary
                       to carry out burial and surveillance of the  hazardous
                       solid wastes. Special measures are to be taken during
                       backfilling to minimize water infiltration. It is possi-
                       ble that  low-level radioactive burial  sites currently
                       used  in arid  regions of the  Western  United States
                       could also be used, with appropriate segregation, for
                       disposal of the hazardous solid wastes.
                                         Process Selection
                          Conceptual design objectives for the model facility
                       included broad treatment capability to permit proc-
                       essing of  all hazardous wastes of significant volume
                       generated  across  the  country.  Important  process
                       selection  criteria  include demonstrated applicability
                       to the treatment  and disposal of existing hazardous

-------
78
                                     DISPOSAL OF HAZARDOUS WASTES
wastes and flexibility to handle a  wide variety  of
different waste streams.
   The objectives  of waste  processing at the model
facility are the  removal of  hazardous and polluting
substances and/or  conversion  of these substances  to
forms that are acceptable for disposal or reuse. From
the hazardous waste  identification portion of this
study described  in Section  2  and  in Appendix B, it
was  determined that  in order to accomplish these
objectives the model facility  should include treatment
processes   for  neutralization  of  acids  and  bases,
oxidation of cyanides and other reductants, reduction
of chromium-6 and other oxidants, removal of heavy
metals, separation  of solids  from liquids, removal  of
organics,  incineration of combustible wastes,  removal
of ammonia, and concentration of waste brines.
   Treatment  processes selected for inclusion in the
model facility were neutralization, precipitation, oxi-
dation and reduction, flocculation and sedimentation,
filtration, ammonia stripping, carbon sorption, incin-
eration,  and evaporation. Disposal processes  selected
were  ocean dumping  and  landfill.  (Appendix  D
describes the major characteristics of these processes.)
A conceptual flow  diagram, which integrates the
various treatment  steps in modular form, was devel-
oped  for the model hazardous waste facility (Figure
17).   The  flow  pattern  represents  that normally
expected and provides for additional piping to permit
alterations when necessary.

                  Cost Estimates
   Design capacities, capital, and operating costs for
typical  small-,   medium-,  and  large-size processing
facilities  are summarized in Table  16  The costs
include   estimates  for  land,  buildings,  laboratory
offices,  and auxiliary equipment It  should be noted
that  these  cost data are  based on preliminary esti-
mates which have been developed from a number of
basic  assumptions, and are only intended to indicate
the norm  of a range  of costs. The following list
identifies  in  sequence those basic assumptions that
have  been utilized  to  arrive at the number, fixed
capital,  and  operating costs of large, medium, and
small   hazardous   waste  treatment  and  disposal
facilities.
   (1) All  hazardous  wastes  will  be treated and
disposed of in an environmentally acceptable manner.
                                      Figure 17.  Conceptual modular flow diagram.

-------
         SUMMARY OF THE HAZARDOUS WASTE NATIONAL DISPOSAL SITE CONCEPT

                                      TABLE 16
PRELIMINARY MODULAR CAPITAL AND OPERATING* COST ESTIMATE SUMMARY FOR SMALL-,
                   MEDIUM-, AND LARGE-SIZE PROCESSING FACILITIES
                                                                                             79
Fixed
Module capital cost
(dollars)
Small-size facility.
Aqueous waste treatment' ••
Receiving and storage 1,262,000
Ammonia stripping 298 700
Chemical treatment 1,827,300
Liquid/solids separation 3,460,000
Carbon sorption 363,000
Evaporation 193,000
Rounded totals 7,410,000
Incineration Av'
Incmeratoi 1 ,880,000
Scrubber vvastewater treatmentt '
Rounded total
Medium-size facility
Aqueous waste treatment' 3- '
Receiving and storage 3,270,000
Ammonia stripping 773,800
Chemical treatment 4,734.000
Liquid/solids separation 8,963,700
Carbon sorption 941 ,000
Evaporation 514,000
Rounded totals 19,200,000
Incineration. S ?
Incinerator 4,873,000
Scrubber wastewater treatment*1 *
Rounded tolal
Large-size facility
Aqueous waste treatment. ***•
Receiving and storage 1 1 ,543,000
Ammonia stripping 2,731,500
Chemical treatment 16,710,600
Liquid/solids separation 30,915,700
Carbon sorption 3,322,000
Evaporation 3,413,000
Rounded totals 68,600,000
Incineration. '" • '
Incinerator 17,201,700
Scrubber wastewater treatment -"T
Rounded total
*Operation 260 days per year
'3,785 liters.
^Capacity. 25,000 gallons (94,600 liters) per day.
fc Includes processing cost for incinerator scrubber wastewater.
Daily
operating cost
(dollars)


1,881
461
^3,298
* 3,888
S?58
^635
10,900

3,201.
-



6.424
952
^ 1 1 ,307
Sg.516
fc 1,578
^2,173
32,000

7,000




38,150
3,180
S 60 ,630
^34,687
"6,290
s 15,947
159,000

27.374
-





Average cost
per 1 ,000 gallons"1
(dollars)


6620
18.40
150.50
' 80.10
17.50
14 60
347.00






4640
7.80
84.70
' 39 60
7.40
10.20
19600






33 60
3.18
53.83
* 17.18
3.62
9.16
121.00








Average cost
pei ton
(dollars)










213.00
185 00
398 00










94.60
80 60
175 00










45.10
55.70
101 00




1' Excludes processing cost for clarifying incinerator scrubber wastewater.
"Capacity 15 tons (136 metric tons) per diy.
1 1'Capacity: 18,450 gallons (70,000 liters) per day.
•!•'' Capacity. I 22,000 gallons (462,000 liters) per day.
^ S Capacity 74 tons (67 metuc tons) per day.
'' ' Capacity. 90,000 gallons (341,000 liters) pet day.
***Capacity 1,000,000 gallons (3,785.300 liters) per day
"! "' "' Capacity. 607 tons (550 metric tons) per day.
•': ! Capacity 738,000 gallons (2,800,000 liters) per day.

























-------
80
                                      DISPOSAL OF HAZARDOUS WASTES
   (2)  All hazardous wastes will be treated prior to
being  disposed  of at  designated sites to  minimize
hazard and volume of wastes deposited on land.
   (3)  Treatment and disposal facilities will be  dedi-
cated to hazardous wastes. Treatment facilities should
have those capabilities indicated in Table 16.
   (4)  Certain  types  and quantities  of  hazardous
wastes  will be  treated  on site  (at  the  source) and
others   at off-site  facilities.  [The  estimated  total
amount  of  hazardous wastes  to  be  treated  and
disposed of is 1.0 X 107 tons (9 X  10"  metric  tons)
per year.  Approximately 4.0 X  106  tons (3.6 X 106
metric tons) are inorganic and 6.0 X 106 tons (5.4 X
106 metric tons) are organic.1 |
   (5)  EPA  economic  studies indicate that on-site
treatment facilities  will  be  small  plants  treating
primarily  dilute aqueous  acidic  toxic metal wastes,
which  constitute approximately 15 percent by weight
of all hazardous wastes. Small on-site facilities will be
capable of neutralizing wastes and precipitating toxic
metals  from  the  wastes, but will produce a toxic
residue  which  will  require  further   treatment at
off-site facilities. Small facilities will have a capacity
of 2.94 X  104 tons (2.6 X  104 metric  tons) per year.
Approximately  51  small  on-site  facilities will be
required to treat the estimated 1.5 X  106 tons (1.36
X  106 metric tons) per year. Approximately  one-
third of wastes treated on site | 5 X 105  tons (4.5 X
10s  metric tons) per year]  will be shipped to off-site
facilities for further treatment
   (6) To  achieve  economies of  scale, off-site treat-
ment facilities will be large- or medium-size treatment
plants.  Approximately 9.0  X 106 tons  (8.2 X  106
metric  tons)  per  year will  be processed at  off-site
facilities. Large facilities will have a capacity of  1.33
X  106  tons (1.2  X  10" metric tons)  per  year, and
                                                 TABLE 17
             CAPACITIES AND COSTS OF HAZARDOUS WASTE TREATMENT FACILITIES ASSUMED IN
                            HAZARDOUS WASTE MANAGEMENT SYSTEM SCENARIO
Item
Capacity:
Aqueous waste processing:
Gallons per day
Liters per day
Tons per day (9 pounds per gallon)
Metric tons per day (9 pounds per gallon)
Combustible waste processing:
Tons per day
Metric tons per day
Total processing:
Tons per day
Metric tons per day
Tons per year
Metric tons per year*
Cost:
Fixed capital (dollars)
Operating:
Dollars per day
Dollars per year'f
With capital writeoff t (dollars per year)
Approximate number of facilities required §
Total fixed capital costs (million dollars)^
Total operating costs (million dollars per year)**

Large facility


1,000,000
3,800,000
4,500
4,080

607
550

5,107
4,627
1,330,000
1,210,000

86,000,000

186,400
48,500,000
57,100,000
5
430
286
Off site
Medium facility


122,000
462,000
550
498

74
67

624
565
162,000
147,000

24,100,000

39,000
10,130,000
12,540,000
15
362
188

Small facility


25,000
95,000
113
102

15
14

128
116
33,300
30,200

9,300,000

14,100
3,660,000
4,590,000
_
_
—
On site
small facility


25,000
95,000
113
102

-
-

113
102
29,400
26,600

1,400,000

2,265
589,000
729,000
51
71
37
     *Assuming actual plant operation of 260 days per year.
     tlncludes neutralization chemicals, labor,  utilities, maintenance, amortization charges (at 7 percent interest), insurance,
taxes, and administrative expenses.
     110-year straight line depreciation.
     § Based on data from EPA Contract No. 68-01-0762 and EPA system variation analysis.
     ^Total off site and on site, $863 million.
    **With capital writeoff; total off site and on site, $511 million per year.

-------
                   SUMMARY OF THE HAZARDOUS WASTE NATIONAL DISPOSAL SITE CONCEPT
                                                                                                          81
medium facilities a capacity of 1 62 X 105 tons (1.47
X  10s metric tons) per year. System variation studies
indicate that  the configuration combining least cost
and  adequate geographical distribution  consists of 5
large- and  15 medium-size facilities. Therefore, large
off-site  treatment facilities will process approximately
6.5 X 106  tons (6.0 X  106  metric tons) per year and
medium facilities  will  process  approximately 2.5 X
106  tons (2.27 X 106 metric tons) per year.
   (7) Current treatment technology does not  allow
complete   neutralization/detoxification   of  all
hazardous  wastes.  It  is estimated  that treatment
residues constituting 2.5 percent of the incoming
waste f 225,000 tons  (200,000 metric tons) per year]
will  still be hazardous.1  Hazardous residues resulting
from treatment facilities will be disposed of in secure
land disposal sites. The most convenient location for
secure land disposal  sites is in association with  the
large  treatment facilities. Therefore, five large secure
disposal sites would initially be required.  Hazardous
wastes generated at other off-site  treatment facilities
would also be disposed of at these  sites.

This  information was  then  utilized to develop  the
configuration  for the  scenario of a hazardous waste
management system cited in Section 4.
   A  more detailed  comparative cost analysis that
identifies  and  summarizes capacities,  fixed  capital,
and operating costs associated  specifically with treat-
ment facilities has been developed in Table 17. These
data were utilized in developing  the cost aspects of
the system scenario.

-------

-------
                 Appendix G
            PROPOSED
             Hazardous
                   Waste
          Management
                       Act
                  of 1973
            93d Congress,
               1st Session
              IN THE U.S. SENATE
                     Bill S. 1086
          Introduced by Senator Baker
                   March 6, 1973
   Referred to Committee on Public Works

IN THE U.S. HOUSE OF REPRESENTATIVES
                   Bill H.R. 4873
    Introduced by Representative Staggers
                     for himself
           and Representative Devine
                 February 27, 1973
             Referred to Committee
     on Interstate and Foreign Commerce
             83

-------
84                         DISPOSAL OF HAZARDOUS WASTES
                               A  BILL
          To assure protection of public health and other living organisms
              from the adverse impact of the disposal of hazardous wastes,
              to authorize a research  program with respect to hazardous
              waste disposal, and for other purposes.
           1      Be it enacted by the Senate and House of Representa-
           2  lives of the  United States of America in Congress assembled,
           3      'SECTION 1. This Act may be cited as  the "Hazardous
           4  Waste Management Act of 1973".
           5                  FINDINGS AND PURPOSE
           6      SEC. 2. (a) The Congress finds—
           7          (1)  that continuing  technological progress,  im-
           8      provement in the methods of manufacture, and abate-

-------
         PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973                  85
 1       ment  of air  and  water pollution has  resulted in  an
 2       ever-mounting increase  of hazardous wastes;
 3           (2) that improper land disposal and othor manage-
 4       ment practices of solid,  liquid,  and scmisolid  hazardous
 5       wastes  which are a part of interstate commerce are re-
 6       suiting  in adverse impact on health and oilier living or-
 7       ganisms;
 8           (3) that the knowledge and  technology  necessary
 9       for alleviating adverse  health,  environmental, and es-
10       thetic  impacts associated with  current waste manage-
11       ment and  disposal practices are generally available  at
12       costs within the financial capacity of those who generate
13       such wastes, even though this knowledge and technology
14       are not widely utilized;
15           (4)  that private  industry  has  demonstrated  its
16       capacity and  willingness to  develop, finance,  construct,
17       and operate facilities and to perform other activities for
18       the  adequate disposal  of hazardous  and  other waste
19       materials;
20           (5) that while the collection and disposal of wastes
21       should continue to he a responsibility of private individ-
22       ual's and 'organizations and the concern of State, regional,
23       and local  agencies, the  problems  of  hazardous waste
24       disposal as set forth  above and as an intrinsic part  of

-------
86                          DISPOSAL OF HAZARDOUS WASTES
           1      interstate commerce have become a matter national  in
           2      scope and in  concern,  and necessitate Federal  action
           3      through regulation of  the  treatment and the disposal  of
           4      the most hazardous of these wastes, and through techni-
           5      cal and other  assistance in the application of new and
           6      improved methods and processes to provide for proper
           7      waste disposal practices and reductions in the amount  of
           8      waste and unsalvageahle materials.
           9       (b)  The purposes of this Act therefore are—
          10            (1) to protect  public health and other living orga-
          11      nisms through Federal regulation in the treatment and
          12      disposal of certain hazardous wastes;
          13            (2)  to  provide  for  the promulgation of Federal
          14      guidelines  for State  regulation  of the treatment and
          15      disposal of hazardous  wastes not subject to Federal reg-
          16      ulation;
          17            (3)  to  provide  technical  and other  assistance  to
          18      public and private institutions  in the application  of ef-
          19      ficient and  effective waste management systems;
          20            (4) to promote a national research program relat-
          21      ing  to the health and other effects of hazardous  wastes
          22      and the prevention of adverse impacts relating to health
          23      and  other living organisms.

-------
         PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973                  87
 1                        DEFINITIONS
 2      SEC. 3. When used in this Act:
 3       (1)  The term "Administrator" means the  Administra-
 4  tor of the  Environmental Protection Agency.
 5       (2)  The term "State"  means  a State, the District of
 6  Columbia,  and  the Commonwealth of Puerto  Eico.
 7       (3)  The term  "waste" means useless,  unwanted,  or
 8  discarded solid, semisolid or liquid materials.
 9       (4)  The term "hazardous  waste"  means any waste or
10  combination of  wastes which pose a substantial present or
11  potential hazard to human health or living organisms because
12  such wastes are nondegradable or  persistent  in  nature or
13  because they can be  biologically magnified, or because they
14  can be lethal, or because they may  otherwise cause or tend
15  to cause detrimental cumulative effects.
16       (5)  The term "secondary material"  means a material
17  that is  or  can  be utilized  in place of a  primary or raw
18  material  in manufacturing a  product.
19       (6)  The term "generation" means the act or process
20  of producing waste materials.
21       (7)  The  term  "storage"  means the  interim contain-
22  raent of waste after generation and prior to ultimate disposal.
23  Containment for more than two years  shall be considered
24  disposal.
25       (8)  The  term  "transport"  means the  movement  of

-------
88                          DISPOSAL OF HAZARDOUS WASTES
           1   wastes  from the  point  of  generation  to any  intermediate
           2   transfer points, and finally to  the  point  of ultimate dis-
           3   posal.
           4       (9)  The term "treatment" means any activity or proc-
           5   cssing  designed to  change the  physical form  or chemical
           6   composition of  waste so as to render  such  materials non-
           7   hazardous.
           8       (10)  The  term  "disposal  of  waste"  means  the dis-
           9   charge, deposit, or  injection into subsurface  strata  or exca-
           10   vations  or  the  ultimate  disposition  onto the  land  of any
           11   waste.
           12       (11) The term "disposal site" means the location where
           13   any final deposition of waste materials occurs.
           14       (12)  The  term "treatment  facility" means a location
           15   at  which waste is subjected to  treatment and  may include
           16   a facility where waste has been generated.
           17       (13) The term "person" means any individual, partner-
           18   ship, copartnership, firm, company,  corporation, association.
           19   joint stock  company, trust, State, municipality, or any legal
           20   representative agent or assigns.
           21        (14)   The term "municipality"  means a city,  town,
           22   borough, county, parish, district, or other public body  created
           23   by or pursuant to State  law with responsibility for the plan-
           24   ning or administration of waste management,  or an  Indian
           25  tribe or an authorized Indian tribal organization.

-------
          PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973                   89
 1       (15) The term  "waste  management"  means  the  sys-
 2  tematic control of the generation, storage, transport, treat-
 3  ment, recycling, recovery, or disposal of waste materials
 4    STANDARDS AND GUIDELINES  FOR STATE KEGrLATION
 5      SEC. 4.  (a)  Within  eighteen months after the  date  of
 6  enactment of this Act, and from  time to time thereafter, the
 7  Administrator pursuant to this section and after consultation
 8  with representatives of appropriate Federal agencies shall by
 9  regulation—
10           (1)  identify hazardous wastes;
11           (2)  establish standards for treatment  arid disposal
12      of such  wastes;  and
13           (3)  establish guidelines for State programs for im-
14      plementing such standards.
15       (b)  In  identifying  a waste  as  hazardous, pursuant  to
16  this  section,  the  Administrator shall specify quantity,  con-
17  centration, and the physical, chemical, or biological  proper-
18  ties of such  waste, taking into  account  means of  disposal,
19  disposal  sites, and available  disposal practices.
20       (c)  The standards established under this  section  shall
21  include minimum standards of performance required to  pro-
22  tect human health and other living organisms and minimum
23  acceptable criteria as  to characteristics and conditions of dis-
24  posal sites and operating  methods, techniques, and practices
25  of hazardous wastes disposal taking into  account the nature

-------
90                           DISPOSAL OF HAZARDOUS WASTES
           1   of the hazardous waste to be disposed. Such standards shall
           2   include but not be limited to  requirements that any person
           3   generating waste must (1) appropriately Idbel all containers
           4   used  for  onsite  storage  or  for  transport of  hazardous
           5   waste; (2)  follow appropriate procedures for treating haz-
           6   ardous waste onsite;   (3)  transport all hazardous  waste
           7   intended  for  offsite disposal  to a hazardous  waste disposal
           8   facility for which a permit has been issued. In establishing
           9   such standards the Administrator shall  take into account
           10   the economic and social costs  and benefits of achieving such
           11   standards.
           12        (d) The guidelines established under paragraph (a) (3)
           13   of this section shall provide that—
           14            (1)   with respect to disposal  sites for hazardous
           15        wastes,  the  State  program requires that any person
           16        obtain from  the  State a  permit to  operate such  site;
           17            (2)  such  permits   require  compliance  with  the
           18        minimum standards of performance  acceptable site  cri-
           19        teria  set by the guidelines;
           20            (3)  the State have  such regulatory and other au-
           21        thorities as may be necessary to carry out the purpose
           22        of this Act, including, but not limited to, the authority
           23        to inspect disposal  sites  and records,  and to judicially
           24        enforce  compliance  with the requirements  of an  ap-
           25        proved program against  any person.

-------
         PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973                   91
 1       (e)  Within  eighteen  months of the promulgation of
 2   final regulations under this  Act,  each State  shall submit to
 3   the Administrator evidence, in .such  form as he  shall re-
 4   quire, that the State has established a State program which
 5   meets the requirement of the guidelines of paragraph  (a)
 6   (3) of this section. If a State fails to submit such evidence,
 7   in  whole or in  part, the Administrator shall  publish notice
 8   of  such failure  in the Federal Register and provide  such
 9   further notification, in such form as he considers appropriate,
10   to  inform the public in such State of such failure.
11                    .FEDERAL  REGULATION
12       SEC. 5.  (a)  Within eighteen months  after the date of
13   enactment of this  Act and from time to time thereafter,  the
14   Administrator  after  consultation  with  representatives  of
15   appropriate  Federal  agencies  may  with  respect to  those
16   hazardous wastes  identified pursuant to subsection  (a) (1)
1^   of section 4  determine in regulations those of such wastes
18   which because of their quantity or concentration,  or because
19   of their chemical  characteristics, could if allowed to be dis-
20   persed into the  environment result in,  or contribute to,  the
21   loss of human  life or substantial  damage  to human health
22   or to other living organisms.
23       (b)   The  Administrator may promulgate  regulations
24   establishing   Federal  standards   and  procedures  for  the
25   treatment and disposal of such wastes. Such Federal stand-

-------An error occurred while trying to OCR this image.

-------
         PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973                  93
 I       (d) Within eighteen months after the date of enactment
 2  of this Act, the Administrator shall promulgate regulations
 3  establishing requirements for generators of hazardous wastes
 4  subject to regulation under this section to—
 5           (1) maintain  records  indicating  the quantities of
 t,      hazardous waste  generated  and the  disposition  thereof;
 7           (2) package hazardous waste in such a manner so
 8      as to protect human health and other living organisms,
 9      and label such packaging so as to identify accurately
10      such wastes;
11           (3) treat or dispose  of all hazardous  waste at a
12      hazardous  waste  disposal site or  treatment facility  for
13      which  a permit has been issued under this Act;
14           (4) handle and store all hazardous waste in such a
15      manner so as not to pose a threat to human health or
16      other living organisms;
17           (5) submit  reports to the Administrator, ait such
18      times  as  the Administrator  deems  necessary,  setting
19      ou1>—
20               (A)  the quantities of hazardous  waste subject
21          to Federal regulation under this subsection that he
22          has generated;
23               (B)  the nature and quantity of any other waste
24          which he has generated which he has reason to be-

-------
94                          DISPOSAL OF HAZARDOUS WASTES
           1           lieve may have  a  substantial  adverse  effect on
           2           human health and other living  organisms; and
           3               (C)   the  disposition of  all  waste  included  in
           4           categories (A) and (B).
           5       (e)  The Administrator  may  prescribe  regulations re-
           6   quiring any person who stores, treats, disposes of, or other-
           7   wise handles hazardous wastes subject to  regulation under
           8   this section to maintain such  records with respect to their
           9   operations as the  Administrator determines are  necessary
           10   for the effective enforcement of this Act.
           11       (f)  The Administrator is  authorized  to enter into coop-
           12   erative agreements with  States to  delegate  to any State
           13   which meets such minimum requirements  as the  Administra-
           14   tor may establish by regulation the authority to  enforce this
           15   section against any person.
           I6                   FEDERAL ENFORCEMENT
           17       SBC. 6.  (a)  Whenever on the basis  of any  information
           18   the Administrator determines that any person is in violation
           19   of requirements under  section 5 or  of any standard under
           20   section 4 (a) (2)  under this  Act, the Administrator may
           21   give notice to the violator  of his failure to comply  with such
           22   requirements or may request the Attorney General to com-
           23   mence a civil action in the appropriate United States district
           24   court for appropriate relief, including temporary or perma-
           25   nent injunctive relief.  If such  violation extends  beyond the

-------
       PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973                  95
 1  thirtieth day after the Administrator's notification, the Ad-
 2  ministrator may  issue an order requiring compliance  within
 3  a  specified time  period  or the Administrator  may request
 4  the  Attorney General to  commence  a civil action  in  the
 5  United States district court in the district in which the vio-
 6  lation  occurred for appropriate relief, including a temporary
 7  or permanent injunction:  Provided, That,  in the case  of a
 8  violation of any standard under section 4 (a) (2) where such
 9  violation occurs in a State  which has submitted  the evidence
10  required under section 4(e),  the Administrator shall give
11  notice to the State  in which such violation  has  occurred
12  thirty  days prior  to issuing1 an order or requesting the  Attor-
13  nej7  General to commence  a civil action. If such violator fails
14  to take corrective action  within  the  time  specified  in  the
15  order,  he  shall be liable for a civil penalty of not more than
16  §25,000  for each day  of  continued  noncompliance.  The
37  Administrator may suspend  or revoke any permit issued to
18  the violator.
19       (b)  Any  order  or  any  suspension or revocation of a
20  permit shall become final unless, no later than 30 days after
21  the order or notice of the suspension or revocation is served,
22  the person or persons named therein request a public hear-
23  ing.  Upon such  request the Administrator shall promptly
24  conduct a  public hearing.  In connection with any proceed-

-------
96                          DISPOSAL OF HAZARDOUS WASTES
           1  ing under this section the Administrator may issue subpenas
           2  for the attendance and testimony of witnesses and the produc-
           3  tion of relevant papers, books,  and documents,  and  may
           4  promulgate  rules for discovery procedures.
           5       (c)  Any order issued under  this section shall state with
           6  reasonable specificity the nature of the violation and specify
           7  a time for compliance and assess a penalty, if any, which the
           8  Administrator determines is a reasonable period and penalty
           9  taking into account the seriousness of the violation and any
          10  good faith efforts to comply with the  applicable requirements.
          11       (d)  Any person who knowingly violates any  require-
          12  ment of  this Act or commits any prohibited act shall, upon
          13  conviction, be subject to a fine  of  not more than  $25,000
          14  for each day of violation, or to imprisonment not to exceed
          15  one year, or both.
          16  EESEAECH,  DEVELOPMENT,  INVESTIGATIONS,  TECHNICAL
          17             ASSISTANCE AND  OTHER ACTIVITIES
          18       SEC. 7.  (a) The Administrator shall conduct, encour-
          19  age, cooperate with, and render financial and  other  assist-
          20  ance to  appropriate public (whether Federal,  State, inter-
          21  state, or local) authorities, agencies, and institutions, private
          22  agencies and institutions, and individuals in the conduct of,
          23  and promote the coordination of, research, development, in-
          24  vestigations, experiments, surveys, and studies relating to—

-------
         PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973                  97
 1           (1) any adverse health and welfare  effects on the
 2      release  into the  environment  of material  present in
 3      waste, and methods to eliminate such effects ;
 4           (2) the  operation or financing of waste manage-
 5      ment programs;
 6           (3) the  development and  application of new and
 7      improved methods of collecting and disposing of waste
 8      and processing and  recovering materials and  energy
 9      from wastes; and
10           (4) the reduction of waste generation and  the re-
11      covery  of  secondary  materials  and energy  from  solid,
12      liquid, and semisolid  wastes.
13       (b) In carrying out the provisions  of the preceding
34  subsection, the  Administrator is authorized to—
15           (i) collect  and  make available,   through  publica-
1°'      tion and other appropriate means, the results of, and
17      other information  pertaining to,  such research and  other
18      activities,  including  appropriate  recommendations  in
19      connection therewith;
20           (2) cooperate with public  and  private  agencies,
21      institutions, and organizations, and with any industries
22      involved, in the preparation and the conduct of such re-
23      search and other activities; and
24           (3j make grants-in-aid to and contract  with public

-------
98                          DISPOSAL OF HAZARDOUS WASTES
            1       or private agencies and institutions and individuals for
            2       research, surveys,  development, and  public  education.
            3       Contracts may be entered into without regard  to sections
            4       3648 and 3709 of the Revised Statutes  (31 U.S.C. 529;
            5       41 U.S.C. 5).
            6       (c) The Interstate Commerce Commission, the Federal
            7   Maritime Commission,  and the  Office of Oil and Gas in the
            8   Department of the Interior, in consultation with the Environ-
            9   mental Protection Agency  and  with other Federal agencies
           10   as  appropriate,  shah1 conduct within twelve months of the
           11   date of  enactment of this  Act  and submit to Congress,  a
           12   thorough and complete study of rate setting practices with
           13   regard to  the carriage  of  secondary materials by rail and
           1-1   ocean carriers.  Such study shall include  a comparison  of
           15   such practices with  rate  setting practices with  regard  to
           16   other materials and shall examine the extent to which, if at
           17   all, there is discrimination  against secondary materials.
           18                        INSPECTIONS
           19       SEC. 8.  (a)  For the purpose of developing or assisting
           20   in  the  development of any regulation or enforcing  the
           21   provisions of this Act, any person who stores,  treats,  trans-
           22   ports, disposes  of, or otherwise handles hazardous  wastes
           23   shall, upon request of any officer or employee of the Environ-
           24   mental Protection Agency  or of any State or  political sub-

-------
        PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973                  99
 1  division,  duly  designated by the Administrator, furnish  or
 2  permit such person at all reasonable times to have access to,
 3  and to copy all records relating to such wastes.
 4       (h)  For the purposes of  developing  or assisting in the
 5  development of any regulation  or  enforcing  the provisions
 6  of this Act, officers or employees  duly designated by  the
 7   Vdministralor arc authorized—
 8           (1) to  enter  at reasonable  times  any establish-
 9      ment or other place  maintained  by any  person where
10      hazardous wastes are stored, treated, or  disposed of;
11           (2) to inspect and obtain samples from any person
12      of any such wastes and  samples  of  any containers  or
13      labeling for such  wastes. Before  undertaking such in-
14      spection, the officers  or employees must  present to the
15      owner, operator, or agent in charge of the establishment
16      or  other  place  where hazardous wastes  are  stored,
17      treated, or  disposed  of  appropriate  credentials and  a
18      written statement as to  the reason for  the inspection.
19      Each such inspection shall be commenced  and completed
20      with reasonable promptness. If the officer or employee
21      obtains any samples, prior  to leaving the premises,  he
22      shall give to  the owner,  operator, or agent in charge
23      a receipt describing the sample obtained and if requested
24      a portion of each such sample equal in volume or weight.

-------
100                         DISPOSAL OF HAZARDOUS WASTES
           1       to the  portion retained. If an analysis  is made of such
           2       samples, a copy of the results  of such analysis  shall be
           3       furnished  promptly  to the owner,  operator, or  agent
           4       in charge.
           5        (c)  Any records,  reports, or information obtained from
           6   any  person under this  subsection shall be  available to the
           7   public, except that upon a showing satisfactory  to  the Ad-
           8   ministrator by any person that records, reports, or informa-
           9   tion, or particular part thereof, to which the Administrator
          10   has access  under this section  if made public, would divulge
          11   information entitled to  protection under section  1905 of
          12   title  18 of  the United  States  Code, the Administrator shall
          13   consider such information or particular portion thereof con-
          14   fidential in  accordance  within the purposes of that section.
          15     ENCOURAGEMENT OF INTERSTATE AND 1NTEELOCAL
          16                         COOPERATION
          17       SEC. 9. The Administrator shall encourage  cooperative
          18   activities by the States  and local governments in connection
          19   with waste disposal programs, encourage, where  practicable.
          20   interstate,  interlocal, and  regional planning for,   and the
          21   conduct  of,  interstate, interlocal,  and  regional  hazardous
          22   waste  disposal programs; and encourage the enactment of
          23   improved and, so far as practicable, uniform State and local
          24   laws  governing waste  disposal.

-------
          PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973                 101
 1                      IMMINENT HAZARD
 2       SEC. 10.  (a) An imminent hazard shall be considered to
 3   exist when the  Administrator has  reason to believe  that
 4   handling or storage of a  hazardous waste  presents an  im-
 5   minent and substantial danger to human health or other liv-
 6   ing organisms  the continued operation of a disposal site will
 7   result in such danger when a State  or local  authority  has
 8   not acted to eliminate such risk.
 9       (b)  If an imminent hazard exists, the  Administrator
10   may request the Attorney General  to  petition  the district
11   court of the United States in the district where such hazard
12   exists, to order  any disposal site operator  or other person
13   having custody of such waste to take such action as is neces-
14   sary to  eliminate the imminent hazard, including, but  not
15   limited to, permanent or temporary  cessation of operation of
16   a disposal site, or such other remedial measures as the court
17   deems appropriate.
18                      PROHIBITED ACTS
19       SEC. 11. The following acts and the causing thereof are
20   prohibited and shall be subject to  enforcement  in accord-
21   ance with the provisions of subsection 6(d) of this Act:
22       (a) Operating any  disposal site for  hazardous  waste
23   identified pursuant to section 5 without having obtained an
24   operating permit  pursuant to such section.
25       (b) Disposing  of hazardous  waste  identified pursuant

-------An error occurred while trying to OCR this image.

-------
         PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973                 103
 1   but additional exemptions may be granted for periods  of not
 2   to  exceed one year upon  the President's or his designee's
 3   making  of a  new determination.  The  Administrator shall
 4   ascertain the exemptions granted under this subsection and
 5   shall report each January to the Congress all  exemptions
 6   from the requirements of this section granted during the pre-
 7   ceding calendar year.
 8       (c) Within eighteen months after enactment of this Act
 9   and from time to time thereafter,  the Administrator, in con-
10   sultation with  other  appropriate Federal  agencies,  shall
11   identify  products which can utilize significant quantities of
12   secondary materials and shall issue guidelines with respect
13   to the inclusion of such secondary materials to the maximum
H   extent  practicable in products  procured  by the  Federal
15   Government.
16       (d) In any proceeding initiated before  the Interstate
17   Commerce  Commission or  the  Federal Maritime  Commis-
18   sion after the  enactment of this Act  where a determination
19   is made  by such Commission as to any individual  or joint
20   rate,  fare,  or  charge  whatsoever demanded, charged,  or
21   collected by any common carrier or carriers, a specific find-
22   ing by the Commission will be required that such rate, fare,
23   or charge does not or  will not cause discrimination against
24   secondary materials.

-------
104                          DISPOSAL OF HAZARDOUS WASTES
           1                        CITIZEN SUITS
           2       SEC. 13. (a) Except as provided in subsection (b) any
           3   person may commence a civil action for injunctive relief on
           4   his own behalf—
           5            (1)  against  any person  who is  alleged to  be  in
           6       violation of any regulation promulgated or order issued
           7       under this Act ;
           8            (2)  against  the Administrator where  there  is al-
           9       leged a failure of  the Administrator to perform any act
          10       or duty under this Act  which is not discretionary with
          11       the Administrator.
          12   Any  action under paragraph  (a) (1)  of this subsection
          13   shall be brought in the district court for the district in which
          34   the alleged violation occurred and  any action brought  under
          15   paragraph  (a)  (2) of this  subsection  shall  be brought  in
          16   the District Court of  the District  of Columbia.  The district
          17   courts shall have  jurisdiction,  without regard to the amount
          18   in controversy  or the  citizenship of the parties, to enforce
          19   such regulation or order, or to order  the  Administrator  to
          20   perform such act or duty as the case may be.
          21        (b)  No action may be  commenced^—
          22            (1) under subsection  (a) (1)  of this section—
          23                (A)  prior to  sixty days  after the plaintiff has
          24           given notice  of  the  violation  (i)  to the Adminis-

-------
         PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973                  105
 3           t rat or, (ii)  to the State in which the alleged viola-
 L>           tion occurs, and  (iii) to any alleged  violator of the
 I!           standard, limitation, or order, or
 4                (B) if the Administrator or State has caused to
 5           be commenced and is diligently prosecuting a civil
 (>           or criminal action  in  a court of the United States
 7           or a State  to require compliance with requirements
 8           of this  Act or  order  issued hereunder;
 9            (2)  under subsection  (a) (2)  prior to sixty days
10       after  plaintiff  has  given notice  of  such action to the
11       Administrator.
12          Notice  under  this  subsection  shall be  given  in
13      such  manner as the Administrator shall prescribe by
14       regulation.
15           (3) in such action under this section, if the United
16       States is not a party, the Attorney General may  inter-
17       vene as a matter of right.
18       (d) The court, in issuing any final order in any action
19  brought pursuant to this section, may award costs of litiga-
20  tion (including reasonable attorney and expert w'tness fees)
21  to any party, whenever the court determines such award is
22  appropriate.
23       (e)  Nothing  in this  section  shall  restrict  any right
24  which any person  (or class of persons)  may  have under any
25  statute or common law to seek enforcement of any regulation

-------
106                          DISPOSAL OF HAZARDOUS WASTES



          1   or to seek any other relief (including relief against the Ad-



          2   miiiistrator or a State agency).



          3                      STATE AUTHORITY



          4       SEC.  14.  (a)   If the Administrator has promulgated



          5   regulations  under section  5  no State or municipality  may



          6   without  the approval of  the Administrator impose more



          7   stringent  requirements than  those imposed  under the  pro-



          8   visions of section 5  on the transport,  treatment,  or disposal



          9   of hazardous wastes.



         10       (b)  No State or municipality shall  impose,  on  wastes



         11   originating in other States or municipalities, requirements re-



         12   specting the transport of such wastes into or disposal within



         13   its jurisdiction which are more stringent than those require-



         14   ments applicable to  wastes originating within such receiving



         15   States and municipalities.



         16            AUTHORIZATION AND APPROPRIATION



         17       SEC.  15.  There is hereby authorized  to be appropriated



         18   to the Environmental Protection Agency such sums as may



         19   be necessary for the purposes and  administration of this Act.



         20                      JUDICIAL  REVIEW



         21       SEC.  16.  (a)  A petition for review of action of the Ad-



         22   ministrator in promulgating  any regulation pursuant  to sec-



         23   tions 4 or 5 shall be filed in  the United States Court  of Ap-



         24   peals for  the District of  Columbia, Any person who  will be



         25   advertwry affected by a final order or other final determine-

-------
         PROPOSED HAZARDOUS WASTE MANAGEMENT ACT OF 1973                  107
 1   tion  issued under section  6  may file  a  petition with  the
 2   United States Court of Appeals for the circuit wherein such
 3   person resides or has his principal place of  business, for  a
 4   judicial  review of such order or  determination. Any such
 5   petition shall he filed within thirty days from the date of such
 6   action or order,  or after such date if such petition is  based
 7   solely on  grounds arising  after  such thirtieth  day.
 8       (b) Action  of the Administrator with respect to which
 9   review could have been obtained under subsection (a) shall
10   not be subject to judicial review in civil or criminal proceed-
11   ings for enforcement.
12       (c) In any judicial  proceeding  in  which review is
13   sought of an action under this Act required to be made on
14   the record after  notice and opportunity for hearing,  if any
15   party  applies to  the  court for leave  to  adduce additional
16   evidence, and shows to the  satisfaction of the court that such
17   additional  evidence is material and that there were reason-
18   able grounds for the  failure to adduce  such evidence in  the
19   proceedings before the Administrator,  the  court  may  order
20   such additional evidence  (and evidence in rebuttal  thereof)
21   to be taken before the Administrator,  in  such  manner and
22   upon such  terms and  conditions  as  the  court may  deem
23   proper. The Administrator may modify his  findings  as to
24   the facts, or make new findings,  by reason of the additional
25   evidence so taken and he  shall  file such modified or new

-------
108                          DISPOSAL OF HAZARDOUS WASTES



           1  findings, and his recommendation, if any, for the modifica-



           2  tion or setting  aside of his  original  determination,  with the



           3  return of such additional evidence.




           4               BKLATIONSHIP TO OTHER LAWS



           5       SEC. 17. (a) This Act shall not apply to—




           6           (1) any source  material, special nuclear  material,




           7       or  byproduct material  subject  to regulation or control



           8       pursuant  to  the  Atomic Energy  Act  of  1954,  as




           9       amended;



          10           (2)  lethal chemicals  subject  to  regulation  pur-




          11       suant  to title 50,  United States Code,  section 1511,




          12       and the following, as amended.



          13       (b) This  Act shall  not be construed to  relieve any




          14  person from any present or future requirement arising  from




          15  any other Federal law.

-------
                                              REFERENCES
  1. Swift,  W. H.  Feasibility  study  for development of a
         system of hazardous waste national disposal sites.
         v.l. [Richland,  Wash], Battelle Memorial  Insti-
         tute, Mar.  1, 1973. p.III-63. (Subsequently pub-
         lished  as Program for the management of hazard-
         ous wastes. July  1973. 385 p.)
  2. U.S. Congress. House of Representatives. Marine Protec-
         tion,  Research,   and  Sanctuaries  Act of  1972.
         Public Law 92-532, 92d Cong., H.R.9727, Oct. 23,
         1972.  [Washington,  U.S.  Government  Printing
         Office] 12 p.
  3. Smith,  D. D.,  and R. P. Brown.  Ocean  disposal  of
         barge-delivered liquid and solid wastes from U.S.
         coastal cities. Washington, U.S. Government Print-
         ing Office, 1971. p.10.
  4. Swift,  Feasibility study for development of  a system of
         hazardous  waste  national  disposal   sites,  v.2
         p.IV-D-1 to IV-D-42.
  5. Ottinger,  R, S. Recommended methods  of reduction,
         neutralization, recovery,  or disposal of hazardous
         waste,  v.l. [Redondo Beach, Calif.), TRW Systems
         Group, Inc., June 1973.
  6. Booz-Allen Applied Research, Inc. A study of hazardous
         waste  materials,  hazardous effects and  disposal
         methods. [Bethesda, Md.], June 30, 1972. 3 v.
  7. Ottmger, Recommended methods of reduction, neutrali-
         zation, recovery, or disposal of hazardous waste,
         15 v.
  8. Lackey, L. L., S. R. Steward, and T. O. Jacobs. Public
         attitudes toward  hazardous waste disposal facili-
         ties. [Columbus, Ga.J, Human Resources Research
         Organization, Feb. 1973.
  9, Funkhouser, J. T. Alternatives to  the management of
         hazardous wastes at national disposal sites, [Cam-
         bridge, Mass.] , Arthur D. Little, Inc., May 1973. 2
         v.
10. Swift,  Feasibility study for development of  a system of
         hazardous waste national disposal sites,  2 v.
11. Christensen,  H. E., ed.  Toxic substances  annual list,
         1971,  National Institute  for Occupational Safety
         and  Health Publication  DHEW (HSM) 72-10260.
         Washington,  U.S.  Government  Printing  Office,
         1971. 512 p.
12. Council on  Environmental Quality. Toxic  substances.
         Washington,  U.S.  Government  Printing  Office,
         Apr. 1971. p.2.
13. U.S. Congress.  Proposed Hazardous Waste Management
         Act of 1973. 93d Cong.,  1st sess., Senate, S.1086,
         introduced  Mar,  6, 1973, House of Representa-
         tives, H.R.4873,  introduced Feb. 27, 1973. [Wash-
         ington] ,  U.S.  Environmental  Protection Agency.
         25 p.
14. Swift, Feasibility study for the development  of a system
         of hazardous  waste national disposal sites, v.l,
         p.III-2.
15. Environmental  quality; the first annual report  of the
         Council on Environmental  Quality together  with
         the President's message to  Congress. Washington,
         U.S.  Government  Printing Office,  Aug.  1970.
         p.107.
16. Mahler, H.  R., and  E, H. Cordes. Biological chemistry.
         New York, Harper & Row, Pub., 1966. 872 p
17. Johnson,   O    Pesticides    '72.    Chemical   Week,
         110(25):33-48,   53-66,  June   21,   1972,
         111(4):1746,  July 26,  1972.
18. Jansen,  L  L.  Estimate of  container number  by size,
         type,  and  formulations involved.  In  Proceedings;
         National  Working Conference on Pesticides, Belts-
         ville, Md., June 30-July 1, 1970. U.S.  Department
         of Agriculture, p.27-30. (Distributed by National
         Technical Information  Service, Springfield, Va.,as
         PB 197 145.)
19. Jansen, Estimate of  container number by size, type, and
         formulations involved, p.27-28.
20. Ottinger, Recommended methods of reduction, neutrali-
         zation, recovery, or disposal  of hazardous waste.
         v.14, p.199.
21. Swift, Feasibility study for development of a system of
         hazardous  waste national disposal sites, v.l, p.V-1
         to V-218.
22. Booz-Allen Applied  Research, Inc., A study of hazardous
         waste  materials,  hazardous effects  and  disposal
         methods, v.l, p.A-II-1 to A-II-22.
23. Proceedings; American Hospital  Association [Institute
         on  Hospital Solid Waste Management), Chicago,
         May 18-20, 1972. v.3.
24. Personal  communication. Chemical  Biological Warfare
         Office, U.S. Army  Materiel Command, Washing-
         ton.
25. Council on  Environmental   Quality,  Toxic substances,
         p.8.
26. U.S. Tariff Commission. Synthetic organic chemicals;
         United States  production and sales [1954-1970].
         Washington, U.S.  Government Printing Office. [15
         v.]
27. Commissioner  Ray stresses positive  understanding. Han-
         ford News [Hanford,  Wash.|, p.5, Oct. 27, 1972.
28. Ottinger, Recommended methods of reduction, neutrali-
         zation, recovery,  or disposal of hazardous waste,
         v.2, p.5.
29. Council on  Environmental   Quality,  Toxic substances,
         p.9.
30. Committee  on Toxicology. Toxicological reports. Wash-
         ington,  National  Academy of Sciences-National
         Research Council, 1971. 219 p.
31. Funkhouser, Alternatives  to the management of hazard-
         ous wastes at  national  disposal sites, v.l, p.3.5.1.
32. Swift, Feasibility study for development of a system of
         hazardous  waste  national disposal   sites,  v.l,
         p.IV-11.
33. Swift, Feasibility study for development of a system ot
         hazardous  waste  national disposal   sites,  v.l,
         p.IV-12.
                                                         109

-------
110
                                        DISPOSAL OF HAZARDOUS WASTES
34  Swift, Feasibility study for development of a system of
         hazardous  waste  national  disposal  sites,  v.l,
         p.I-41-42
35, Ottinger, Recommended methods of reduction, neutrali-
         zation,  recovery, or disposal of hazardous  waste,
         v.l, p.135-298.
36. Funkhouser, Alternatives to the management of hazard-
         ous   wastes   at   national  disposal  sites,  v.l,
         p.3.24-3.33.
37. U.S. Congress. House  of Representatives. Resource Re-
         covery  Act  of  1970.  Public  Law 91-512, 91st
         Cong., H.R.I 1833, Oct.  26,  1970. [Washington,
         U.S. Government Printing Office | [9 p.)
38. U S. Congress. House of Representatives.  Atomic Energy
         Act   of  1954.  Public  Law  703,  83d  Cong.,
         H.R.9757,  Aug.   30,  1954.  (Washington, U.S.
         Government Printing Office |  [41 p. |
39. US. Code, Title 18, ch.39. Explosives and other danger-
         ous  articles,  sec.831-835   Washington,   U.S.
         Government Printing Office, 1971.
40. U.S  Congress.  Senate.  [Federal  Railroad  Safety  and
         Hazardous  Materials  Control |  Act.  Title Ill-
         Hazardous materials control, sec 302.  Public Law
         91^58, 91st Cong., S.1933, Oct. 16, 1970. [Wash-
         ington,  U.S.  Government Printing  Office)  [p.7.]
         (U.S. Code, Title 46, sec.1761-1762 )
41. U.S. Congress. Senate.  Federal Aviation Act of  1958.
         Title VI—Safety  regulations of civil aeronautics.
         sec.601. Public Law 85-726, 85th  Cong., S.3880,
         Aug. 23,  1958.  [Washington, U.S.  Government
         Printing Office) [p.45-46.| (U.S. Code, Title 49,
         sec.1421.)
42. U.S. Code, Title  46,  ch.7.  Carriage  of explosives or
         dangerous substances,  sec.170. Washington, U.S.
         Government Printing Office, 1971.
43. U.S. Congress.  Senate.  Federal  Hazardous Substances
         Labeling Act  sec.17.  Public  Law 86-613, 86th
         Cong., S.I 283, July  12,  1960. [Washington, U.S.
         Government  Printing  Officej  [p.9.|  (U.S.  Code,
         Title 15, sec.1261 et seq )
44. U.S. Congress. House of Representatives. Federal Envi-
         ronmental Pesticide Control Act of 1972. sec.19.
         Disposal and  transportation.  Public Law 92-516,
         92d Cong., H.R.10729, Oct. 21, 1972.  [Washing-
         ton, U.S Government Printing  Office)  p.23-24.
45. U.S. Congress, Marine Protection, Research, and Sanctu-
         aries Act   of  1972,  Title   I-Ocean  dumping,
         sec 101, p.2.
46. U.S. Congress, Marine Protection, Research, and Sanctu-
         aries Act   of  1972,  Title   I—Ocean  dumping,
         sec.!02(a), p.3.
47. U.S. Congress.  House  of  Representatives.  Clean Air
         Amendments  of  1970. Public Law 91-604, 91st
         Cong.,  H.R.17255, Dec  31,  1970. [Washington,
         U.S. Government Printing Office]  [32 p.|  (U.S.
         Code, Title 42, sec.1857 et seq.)
48. U.S. Congress. Senate. Federal Water Pollution Control
         Act  Amendments of  1972. Public Law 92-500,
         92d  Cong.,  S.2770, Oct.  18,  1972. [Washington,
         U.S. Government Printing Office | 89 p.
49. U.S. Congress. Senate. Poison Prevention Packaging Act
          of 1970.  sec.3. Public Law  91-601,  91st  Cong.,
         S.2162, Dec. 30,  1970. [Washington, U.S Govern-
         ment Printing Office] [p.1-2.|
50. U.S, Congress. House of Representatives. Animal  Drug
         Amendments of  1968.  Public Law 90-399,  90th
         Cong.,  H.R.3639, July 13,  1968. [Washington,
         U.S. Government Printing Office]  [Amendment to
         the Food, Drug, and Cosmetic Act of 1938. |
51. U.S. Congress.  Senate.  National Environmental Policy
         Act of 1969.  Public  Law  91-190,  91st Cong.,
         S.1075, Jan. 1, 1970.  (Washington, US. Govern-
         ment Printing Office] [5 p.|  (U.S. Code, Title 42,
         sec.4321 et seq.)
52. U.S. Congress.  Senate.  [Armed Forces Appropriation
         Authorization,  1970)  Act.  Public Law 91-121,
         91st Cong.,  S.2546, Nov.  19, 1969. [Washington,
         U.S. Government Printing Office]  [10 p.]
53. U.S. Congress. House of Representatives. [Armed Forces
         Appropriation  Authorization, 1971.)  Public Law
         91-441, 91st Cong,  H.R 17123, Oct.  7,  1970.
         (Washington, U.S.  Government  Printing Office)
         [10 p. |  (U.S. Code, Title 50, sec.1511-1518.)
54. U.S. Congress. Senate. Coastal Zone Management Act of
         1972. Public Law 92-583,  92d Cong., S.3507, Oct.
         27, 1972. [Washington, U.S. Government Printing
         Office]  10 p.
55. U.S. Congress. Senate.  Occupational  Safety and Health
         Act of 1970. sec.6(b)(5). Public Law 91-596, 91st
         Cong., S.2193,  Dec. 29, 1970.  [Washington, U.S.
         Government Printing Office] [p.16.)
56. Swift, Feasibility  study for development of a  system of
         hazardous   waste  national   disposal sites, _v.l,
         p.IX-32 to IX-33.
57. Reitze, A. W., Jr.  Tax incentives don't stop pollution. In
         Environmental  law. Washington,  North  American
         International, 1972.
58. Kennecott Copper v. EPA,  U.S. App. D.C.,_F. 2d_, 3
         ERC 1682 (Feb. 18, 1972).
59. Anaconda Company v.  Ruckelshaus, D.C Colorado, _F.
         Supp._, 4 ERC 1817 (Dec. 19, 1972).
60. International  Harvester  Company v.  Ruckelshaus, U.S.
         App. D.C.,  _F.  2nd_, 4 ERC  2041  (Feb. 10,
         1973).
61. U.S. Congress. Senate.  Clean Air Amendments of  1970.
         sec.H2(b)(l)(B). Public Law 91-601, 91st Cong.,
         S.2162, Dec. 30, 1970. [Washington, U.S. Govern-
         ment Printing Office |  [p 16. [
62. U.S. Congress, Federal  Water  Pollution  Control Act
         Amendments of 1972,  Title V-General provisions,
         sec.502(14), p.72.
63. U.S. Congress,  Federal Water  Pollution Control Act,
         Title   III —Standards   and   enforcement.
         sec.304(c)(2)(D).  Public Law  92-500.  (Washing-
         ton, U.S. Government Printing Office] p.36-37.
64. U.S. Congress,  Federal Water  Pollution Control Act,
         Title III, sec.306(a)(l), p.3940.
65. U.S. Congress,  Federal Water  Pollution Control Act,
         Title III, sec.307(a)(4)(6),  p.42.
66. U.S. Congress,  Federal Water  Pollution Control Act,
         Title III, sec.311(b)(2)(A), p.48.
67. U.S. Congress,  Federal Water  Pollution Control Act,
         Title III, sec.311(b)(3), p.49.
68. Reitze, Tax incentives don't stop pollution,  ch.Sd and
         4g.
                                                                                                              po837r
       OUS GOVERNMENT PRINTING OFFICE ,''74

-------