Solid Waste
Management
Strategy
U.S. ENVIRONMENTAL PROTECTION AGENCY
Office of Solid Waste Management Programs
October 31, 1974
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UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
WASHINGTON, D.C. 20460
OCT 3 : 1974
OFFICE OF THE
ADMINISTRATOR
TO: Waste Management and Resource Recovery Officials
The Environmental Protection Agency has been actively engaged
in developing and implementing programs directed toward a goal of
effective solid waste management and resource conservation under
the Solid Waste Disposal Act as amended. We view our activities
and the progress which has been made under this authority to date
as providing the basis for an environmentally sound national solid
waste management program. We believe that a continuation of the
programs begun under the Act is essential to the development and
maintenance of an effective State-Federal partnership in addressing
the solid waste problems we face today and those projected in the
next several years.
We view many of the environmental problems associated with
solid waste disposal as stemming in large measure from practices
of inefficient and wasteful consumption and careless disposal,
symbolized by our "throw-away" style of life. These practices
must be replaced by a more enlightened conservation which includes
reduction in both consumption and waste generation, as well as
increased recycling of wastes.
From our experience with solid waste management, we have become
increasingly aware of the need for national standards and special care
in the management of hazardous wastes. As we learn more about tha
components of hazardous wastes and their effects upon man and the
environment, we realize that we can no longer rely on the simple,
customary means of waste treatment and disposal. Based on our
findings in this area, we recognize that comprehensive Federal,
State or local regulations controlling hazardous wastes are required
to bring about a national program for environmentally acceptable
and safe treatment and disposal of hazardous wastes. Our proposed
"Hazardous Waste Management Act," forwarded to the Congress in
February of last year, provided for a strong Federal role in the
identification and issuance of standards for the storage, treatment,
and disposal of hazardous materials.
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This strategy document is part of a management system designed
to serve as a general guide for EPA Headquarters, EPA regional
offices and the States in implementing a coordinated Federal-State
program of Solid Waste Management. It is intended for their use
in setting annual objectives and allocating resources in support of
these objectives. It is meant to ensure that activities undertaken
will conform to this strategy and will be consistent with each other.
As a public statement of EPA's intentions it is intended to serve
as a means of promoting public comment and public participation.
This strategy should be viewed as a dynamic document intended to be
responsive to situations that develop as the Act is implemented.
A further element which we believe is integral to a viable waste
management and resource conservation program is a strong and
effective State and local program. In general, it has been our belief
that State and local programs should be self-financed to ensure that
they are responsive to local needs and to ensure that resources are
allocated in a most efficient manner. However, we have found that
the broad application of new technologies is a new and demanding
responsibility for the States, and that their own resource constraints
have hampered them in initiating and carrying out comprehensive and
effective programs of solid waste disposal and resource recovery.
Greater attention by EPA will be required to assist States and local
governments in meeting these new program demands.
This strategy envisions that the first and most significant role
of State government is the control of all land disposal sites where
any type of wastes are disposed. Further, this strategy relies
heavily on State implementation and envisions a broad State program
which would implement the Federal hazardous waste regulations
and enforcement. The general approach to management of solid
waste is to direct the most severe types of wastes to a few strictly
controlled process/disposal sites, leaving the overwhelming
number of other sites to process/dispose of "other" wastes.
While the program is currently constrained by existing legislation,
the strategy envisions direct Federal regulation and enforcement of
very hazardous wastes, Federal standard setting; and State
implementation of control of "other" hazardous wastes, and State
responsibility for "other" wastes with guidance provided by
Federal guidelines. Finally, this strategy sees the States as a
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catalyst and facilitating agent to bring about increased resource
recovery at the local and regional level. State government, because
of its ability to cross jurisdictional lines, can create the institutional
relationships that will provide a logical balance between recovery and
disposal.
Within the limits of our resources, the Environmental Protection
Agency will assist States in developing their programs to carry out
effective waste management ajad"feio\irce recovery programs.
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PREFACE
This first edition of the Solid Waste Strategy has been
prepared to assist Federal, State and local government
Officials in understanding EPA's solid waste program and for
the information of the public. This strategy encompasses
the activities of all EPA organizations involved in solid
waste related activities, and most activities described will
involve the participation of several offices within EPA.
The strategy is designed to provide a framework for develop-
ing and implementing a coordinated Federal-State solid waste
management program which addresses all types of wastes and
residuals disposed of on land. It is recognized that lead
activity related to some residuals falls under the aegis of
air or water programs or their respective research counter-
parts and that these wastes are covered by other agency
strategies in more detail.
On the use of the Strategy, it is emphasized that the
Strategy, while based on the law, is not law, nor is it a
regulation mandated by the law. It is guidance prepared for
use by Government agencies in implementing the Act. It is
part of a management system whose purpose is to insure that
program activities, by conforming to a single strategy, are
consistent with each other.
The Strategy Paper is written under the aegis of the
Office of Solid Waste Management Programs in EPA Headquarters.
While much of its development has been within this office, it
more fully reflects the work of individuals within all EPA
Headquarters program areas, and the participation of EPA's
Regional Offices.
Comments on the Strategy are welcomed. They should be
addressed tot
Deputy Assistant Administrator
for Solid Waste Management Programs (AW-562)
Environmental Protection Agency
401 M Street, S.W.
Washington, D.C. 20460
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TABLE OF CONTENTS
I.
II.
III.
IV.
V.
VI.
VII.
VIII.
Appendix A.
Appendix B.
Page
Purpose and Summary 1
The Problem 5
Major Causes of the Problem 7
Strategic Goals 10
Constraints to Strategic 11
Formulation
Tools 12
Discussion of Basic Strategic 13
Approach
Summary of Programmatic 18
Implementation
Summary of Program Thrust 19
Detailed Discussions on Program 20
Thrust
Environmental, Health, and Safety 34
Impacts of Improper Waste
Management
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SOLID WASTE MANAGEMENT STRATEGY
!• Purpose and summary
The purpose of this document is to present an EPA solid
waste program strategy for FY 1975. This document lays the
ground work for guidance to EPA headquarters, EPA Regions,
and to the states, it is meant to ensure that activities
undertaken will conform to this strategy and are consistent
with each other. As a statement of EPA's intentions, this
paper is also meant to serve as a means of promoting public
awareness, encouraging public participation and guiding the
public on EPA solid waste management policies. The strategy
should be viewed as a dynamic document, intended to be
responsive to situations that develop. It will undergo
revision to accommodate new needs, problems, and legislative
thrusts, but the basic philosophy and framework will be
continued.
This strategy is designed to encompass the activities of all
agency elements involved in solid waste related activities,
and most activities described will involve or require the
participation of several offices within EPA. The strategy
is designed to serve as a general guide for all types of
wastes and residuals disposed of on land, but it is
recognized that lead activity related to some residuals
falls under the aegis of water or air programs or their
respective research counterparts and that these wastes are
covered by other agency strategies in more detail.
In summary, the major issue being addressed is one of
improper waste management, resulting in problems ranging
from extreme health and environmental damages to resource
wastage.
The problem is caused by the fact that improper disposal is
cheap compared to environmentally acceptable practices.
Problems tend to result from improper actions over long
periods of time, and result from practices not easily
understood or visualized. Aesthetic damages are easily
visualized, and represent varying impacts on human health or
animal life, on the other hand, for example, groundwater
contamination which is not visible can result without a
proper understanding and application of the necessary
environmental control procedures.
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We know that leachate is formed in land disposal sites and
that this liquid enters groundwater aquifers. As rain water
percolates through soil, it is more or less purified
depending on the constituents of the leachate and the type
of soil through which it flows. In areas of high water
tables and high precipitation, there is a significant
potential for groundwater contamination. The extent and
seriousness of this problem is now being investigated, but a
current presumption of damage exists.
A number of causes for inadequate waste management have been
cited (e.g., municipalities have no money, technology is
inadequate, trained manpower is lacking) . However, EPA
believes that these problems could be overcome if a major
national commitment were made to control the adverse effects
of waste management. Such a commitment would result in
adequate standards and their vigorous enforcement. In turn,
fiscal and other barriers would fall or be minimized.
EPA has formulated two strategic goals: to achieve accept-
able and safe waste management, and to conserve natural
resources. EPA is constrained in effectively formulating
and implementing this strategy primarily by a lack of direct
regulatory power to assure proper land disposal or
groundwater quality protection. Authority to set standards
on hazardous wastes has been sought from Congress.
EPA can (1) stimulate regulation by others, (2) provide
limited planning support to States, (3) carry out research,
development, and demonstration, and (4) provide technical
assistance.
A. Environmental grotection
The strategy to achieve environmentally acceptable, safe
solid waste management relies primarily on the eventual
establishment of a regulatory approach. It is the most
direct attack on environmental, health, and associated
problems. The approach is to direct the most dangerous
types of wastes to a limited number of strictly controlled
processing/disposal sites, leaving a larger number of sites
to process and dispose of less hazardous wastes.
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This strategy relies heavily on the States. From the State
perspective, the problem is one of land disposal. States
generally have the power to issue regulations for all wastes
and all sites and to relate the degree of control to the
potential degree of hazard. Typically, however. States have
issued site regulations that prohibit acceptance of
hazardous wastes. The exclusion of certain wastes from
disposal sites has virtually resulted in no controls for
these excluded wastes. State enforcement of these
regulations is severely hampered by low resources. A
principal objective of the strategy is to strengthen the
State role, particularly with regards to establishing
authority over the disposal of all wastes. Adequate
disposal site control also implies control of the movement
of at least hazardous waste from generator to disposal sites
lest indiscriminate dumping take place.
The major headquarters thrust will include: developing a
data base on hazardous wastes; demonstration programs to
advance certain treatment and disposal methods; developing a
hazardous waste regulatory strategy; augmenting knowledge on
the inter-media effects of land disposal; consolidating
technical/economic data on all aspects of solid waste
management; and technical assistance support to improve
local practices.
B. congervat&on
The approach to natural resource conservation by waste
recovery and source reduction relies primarily on technical
assistance. The primary barriers to waste recovery
implementation are institutional constraints.
The plan is to concentrate on the evaluation and
dissemination of information about existing systems to
reduce perceived risk, and on working with communities
seriously considering recovery options, helping them make
sound decisions.
Headquarters will conduct a program of studies related to
th« concept of conservation through source reduction.
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primarily addressing benefit/cost trade-offs of economic
product regulation.
Some States have emerged as strong supporters of recovery
system implementation, primarily through the provision of
financial assistance. Connecticut has a unique program in
that it addresses institutional problems through a Waste
Management Authority. The Authority puts together a package
(site, system, financing backed by State bonding, contracts
with firms to operate the system) for a competitive disposal
fee, which covers the full cost of the system. This concept
is attractive for disposal sites, as well as for resource
recovery. The approach is to utilize Federal demonstration
funds in one or more states to stimulate establishment of
similar institutions.
c. Regional Activities
The Agency approach anticipates a strengthening of the role
of EPA Regional offices primarily to (1) provide better and
more intensive relationships with States to help achieve
national objectives; (2) to support enforcement efforts by
States and to utilize existing enforcement powers where
appropriate, and (3) to become the cutting edge of technical
assistance efforts for waste management and resource
recovery.
The headquarters role in support of the regions is to (1)
provide policy guidance, (2) assess specific approaches
taken by the Regions; (3) develop the knowledge on the
state-of'the-art of all types of waste management practices;
and (U) provide the specialized expertise for technical
assistance.
D. Basic strategy Assumptions
The Federal solid waste management program was originally
established to improve solid waste management nationally
through research, development, demonstration, training, and
planning activities. The major focus of the program in the
1965-1970 period was on municipal waste collection,
processing, and ultimate disposal activities; and on State,
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local, and regional planning. In the 1970-1973 period, the
focus was broadened to resource recovery, support of
regulatory activities by States, and investigation of
hazardous waste management problems.
It is assumed that the program will continue to evolve in a
generally regulatory direction related to waste treatment
and disposal activities, while in the resource recovery
activities the Federal role will consist of implementation
stimulation through technical assistance, information
dissemination, planning activities, and demonstrations.
In FY 1975, the program is expected to operate under an
extension of the Solid Waste Disposal Act, as amended.
However, passage of legislation incorporating the provisions
of the proposed Hazardous Haste Management Act is expected
ultimately.
II. £he Problem
Waste management presents a spectrum of problems, from
extreme health and environmental hazard to municipal
management inefficiency. The extremely diverse nature of
the wastes (dead animals, mercury-rich industrial sludges,
dredge spoils, abandoned cars, septic tank p urn pings,
residential solid waste, infectious hospital wastes,
demolition debris, feedlot wastes, etc.) and their manner of
occurrence (in or near concentrations of population, in
rural areas, etc.) , means that the dimensions of waste
management are very diverse. Any abstraction of the problem
into categories is a dangerous oversimplification.
The problem cannot be disaggregated neatly into "hazardous"
and "non-hazardous" components. Solid waste is not merely
residential trash and food wastes. Such an oversimpli-
fication obscures the real situation. The early stress on
municipal solid waste (by the program and by others) was
because this waste is most apparent to concerned
environmentalists and is easier to understand than the
management of many closely related industrial, institu-
tional, and agricultural residuals.
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The basic problem is improper land disposal of wastes—all
wastes—with adverse environmental consequences. Appendix B
provides a more detailed discussion of this subject. A
categorization, recognizing the fact that it oversimplifies
the issue, follows:
• flealth apfl Environmental Effects Occur ynder Five
Headings
Water. Ground and surface waters can be polluted by land
deposition of wastes. The problem ranges from contamination
of waters by heavy metals and other toxic chemicals to
introduction of organics and soluable gases (CO-).
Air. Air pollution can result from incineration, open
burning, or sublimation of chemicals at land sites; odors
are also associated with processing and disposal facilities,
especially with organic waste dumps and lagoons.
Health. Disease vectors arise from improper waste
management and waste movement and disposal. The problem is
associated especially with improper storage and collection
of residential wastes in the inner city.
LfiBlLjise. Waste disposal alters soil biota and soil
chemistry and thus affects future potential land use. For
example, land contaminated by heavy metals cannot be used
for food or feed crop production.
Human gafetv is endangered in accidents during waste
collection and at land disposal sites where hazardous wastes
are handled. Migration of methane or carbon monoxide from
land sites to confined areas can cause explosion or
suffocation respectively.
• Aesthetic and other Problems also accompany waste
management, especially the following:
Litter, ugly accumulations, and uncontrolled dumping;
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Adverse economic impact of disposal sites on land values—
due to historically poor practice in management of disposal
sites;
Inequitable population effects—disposal sites typically
impact on a small portion of the population but serve the
total population; and
Inefficient management of wastes—which causes higher than
required expenditures on this function by the people.
• Resource Wastage. Waste management is accompanied by
little or no materials or energy recovery because
recovery is most often more expensive than simple
dumping. This activity is wasteful so long as simple
dumping is an unacceptable practice for other
reasons.
The resource aspect of waste management, however, goes
beyond the fact that waste materials are not usually
recovered. Waste generation is itself a symptom of national
practices that impact on the ability of the economy to
supply materials and energy at requisite levels.
ill. Ma-jor Causes of the Problem
The chief environmental problems exist for a number of
interrelated reasons:
• Regulatory and Enforcement Gags. Some States do not
regulate disposal effectively and most do not enforce
regulations vigorously because of low manpower
resource commitments.
• Resource Allocation. Municipalities do not devote
required resources to environmentally sound disposal
and efficient management where such poor practice is
tolerated by an apathetic population or where the
impacted population has no political power.
• A£fi£h.j&i£ Xfj. Eny4.ronmen$a,L control. Since litter
and ugliness ar* typically the most obvious target of
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popular displeasure, municipalities may manage
disposal "cosmetically" but not environmentally—no
blowing paper, no odor, but leachate into the
groundwater—unless environmental regulations are
enforced.
Barriers £g Recovery. Poor disposal practice is
cheaper than resource recovery, and the cheap option
retards the consideration of recovery or other more
environmentally sound practices. In this connection,
however, it should be noted that recovery today is
primarily a residential/commercial waste management
option and not a solution for all types of wastes.
Especially acute is the effect of an absence of
regulation in the industrial, and above all the
hazardous waste areas, where the cost differential
between dumping and proper treatment may be twenty
fold or greater. This results in under-utilization
of the private sector industrial waste
detoxification, treatment, and disposal services (the
existing, small industrial waste management industry
operates at 25 percent capacity).
Typically a number of other "causes" for the problem
are cited—e.g., municipalities have no money,
disposal technology is inadequate, manpower resources
are lacking or poorly trained, consultants are poorly
qualified, etc. All of these are true to some extent
somewhere. However, where a community makes a
commitment to control the adverse effects of waste
management, such problems can be overcome.
Absence of regulatory control (environmental
standards, strictly enforced) is due to some of the
following factors:
Ignorance of the Prob.lejn. The problem has been
identified recently. This is the case with highly
hazardous wastes and with the potential of
qroundwater contamination by leachate. General
recognition of the special nature of these wastes or
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effluents and their adverse effect on life and the
environment is a recent phenomenon.
Absence of Alternatives, courts or regulatory
agencies do not move against disposal site operators
if there is no alternative available. Shut-down of
an operation is impossible politically unless wastes
can be placed somewhere else. Site operators can
"blackmail" the public by threatening shut-down
rather than expending resources for upgrading. This
problem is closely linked with the next one, and is
probably the chief obstacle to environmentally
acceptable waste management where standards exist but
are not enforced.
Resistance to Disposal Type Land yse. Public
resistance to the siting of a new disposal site is
usually intense and flows from public knowledge of
poor disposal practices in the past and reduction of
land values (real or presumed) . This makes creation
of alternatives very difficult, prevents institution
of the most economical logistical systems, and
thwarts enforcement of regulations where they are in
force.
Imbalance in, Power Between S^ateg and Large
Metropolitan Areas. This phenomenon sometimes
results in enforcement of regulations in small, rural
places by the state but a "hands off" policy vis-a-
vis large cities that have political and fiscal
strength.
Absence of Proven/Tested Technology. This phenomenon
is applicable especially for hazardous waste disposal
sites. It is difficult to mandate, for instance, the
disposal of pesticides in landfills without
hydrological connections unless such sites exist. It
is difficult to establish such sites without the
necessary engineering and testing programs to
identify appropriate designs and to ascertain their
viability. To a lesser extent, this issue also
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retards recovery of some types of resources—e.g.,
n on ferrous metals and glass.
IV. strategic GoaJ.s
From the problem statement the following goals are
formulated for solid waste management:
• Achieve acceptable and safe waste management to
protect public health and welfare and the
environment.
• Conserve natural resources through institution of
resource recovery or by other means where
economically feasible.
Acceptable and safe waste management (for environmental,
health, and safety reasons) necessarily results in the
elimination of most site-rrelated land and groundwater
pollution, litter and blight, should improve the land values
around disposal sites, will minimize adverse inter-
population effects, and (by imposing higher costs on
disposal operators) will create incentives for fiscal
efficiency and other environmentally acceptable options.
Road-side litter, accumulations of abandoned automobiles or
other bulky wastes, and similar littering without a health
or environmental impact would not be addressed by this goal.
Resource conservation would be indirectly aided by the
achievement of this goal in that it would raise the costs of
disposal and thus make higher cost recovery a better option.
Conservation through recovery and other means, while
indirectly supported by environmental, health, and safety
related upgrading of waste management, is singled out as a
national goal because resource recovery is a new activity at
this time, not yet a self-evident waste management option.
Institution of recovery systems (or other measures) will
require more than regulatory pressure to achieve.
Achievement of the highest feasible recovery is seen as a
worthwhile national goal for national efficiency, strategic.
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and general public welfare reasons—to forestall shortages
and disruptions attendant on shortages.
Both national goals are appropriate Federal or EPA goals.
Environmental and health protection is the chief mission of
EPA. Resource conservation is the mission of the FEA (for
energy) and of Interior (for minerals) . Conservation of
materials and energy from wasifce can and should properly be
an EPA mission in that the achievement of such recovery is
inextricably intertwined with considerations of waste
management and ultimate disposal and achievement of
environmental and conservation objectives are mutually
supportive.
v- Constraints to Strategy Formulation
A. Regulatory Power.
There is no Federal regulatory power directly applicable to
all land disposal sites and land disposal practices. The
Federal Water Pollution Control Act does address the issue
of land application systems for the treatment of municipal
wastewater. The Clean Air Act is fairly effective in
addressing problems from open burning. But no effectively
clear control over groundwater exists for the many other
kinds of wastes and disposal practices. Control over
surface water pollution from disposal sites is weak.
Section 209 of the existing Solid Waste Disposal Act
provides the authority to issue guidelines which are
mandatory for Federal agencies but no one else. Until
regulatory power is provided to the Agency, work will be
carried out under the authority and mandates of Section 209.
B. Knowledge.
The extent of systematic knowledge (suitable for broad
trade-off analysis and regulatory program justification) is
relatively poor. This is especially true with regard to (1)
industrial hazardous (and not-so-hazardous) waste quantities
and compositions as they actually occur; current data are in
the form of chemicals, not chemicals in actual waste
streams; (2) land, air, water inter-media consequences of
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various types of disposal, (3) the effect of hazardous and
toxic materials on plant and animal life, (4) hazardous
waste treatment and disposal technology, and (5) the
qualities, nature, occurrence, and handling methods related
to numerous special wastes not heretofore given priority
(crop wastes, animal wastes, hospital wastes, demolition
debris, dredgings, and a variety of nonhazardous or
"situationally" hazardous sludges, (6) treatment and
processes of the consequences of the use of the land as a
disposal media, and (7) the costs and benefits of product
regulation for recovery or source reduction.
c. 94.versitv.
State and municipal government structures, philosophies, and
procedures vary greatly from region to region and within
regions. Differences in geography, geology, population
density, and many other factors exist. A uniform strategy
for all States or all wastes or all regions is unrealistic
and probably counterproductive.
VI. Tools
Basic tools that could be used to achieve the strategic
goals are listed below. Not all of these are available
under existing authorities.
• Regulatory action at various levels (Federal, state,
local) including combinations such as Federal
standards, state enforcement, local implementation,
etc. This includes the semi- regulatory use of
guidelines and recommended procedures. Land
condemnation procedures would fall into this
category.
support such as grants, loans, subsidies, tax
credits (to various levels of government and various
types of organizations for a diversity of purposes)
designed primarily to support capital acquisition
and/or operations. This category could include
provision of land as a fiscal support mechanism.
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• Research, development, and demonstration, in-house or
through contracts and grants, aimed at systems
development and testing and environmental * health,
and safety assessment.
• Technical assistance, consultation, and other forms
of communications to transfer knowledge, to
facilitate project or program implementation, to
persuade others, etc.
VII« Discussion of Basic Strategic Approach
A general strategic approach to achieve the two goals
formulated above is presented and discussed here. A program
array for the period of this strategy assessment is pre-
sented in the next section.
A. strategy to Achieve Egvlrpflmentallv Acceptable and
gage Haste Management, and Protect Public Health
The basic elements to achieve this strategy include:
(1) Regulatory control of waste storage, treatment and
disposal.
(2) Mixed Federal and State implementation based on
degree of harm associated with types of wastes.
(3) Program thrust supported by fiscal support to States,
R&D, demonstrations and technical assistance.
(<*) Direct regulation and enforcement relative to Federal
facilities.
Discussion. A regulatory approach is the single strategy
likely to achieve a number of ends as discussed earlier. If
consistently followed over a period of time, it moves toward
the most equitable distribution of the costs of control,
provides for maximum participation by the private sector,
provides incentives for efficiency and thus for cost
reductions, and represents the most &{£££ attack on
environmental, health, and associated safety problems.
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Significant differences in environmental and health damage
are associated with types of waste, from innocuous (glass
bottle) to severe (arsenic-containing pesticide) . The level
of attention that should be paid by the Federal government
to waste management can be related to the degree of harm
involved, the inter-state or national extent of damages
resulting from poor management, etc. Given the ever-present
resource constraints it is logical to some extent to
concentrate Federal action in those areas where waste
management problems have the most direct adverse impact.
General Approach. The approach is to direct the most severe
types of wastes to a few, strictly controlled
processing/disposal sites, leaving the overwhelming number
of other sites to process/dispose of other wastes. Thus the
above strategy envisions a "cascading" regulatory strategy
with direct Federal regulation and enforcement of very
hazardous wastes. Federal standard-setting and state
implementation of other hazardous wastes, and State
responsibility for "other" wastes guided by Federal
guidelines.
It is stressed that a clean demarcation between "hazardous"
and "non-hazardous" wastes does not exist except at the
extremes of the spectrum. As more experience is gained the
basic strategy is expected to change as well and reflect the
gaining of clearer views of the demarcation.
Federal Facilities. The chief exception to this general
strategy is waste management on Federal facilities which is
controlled under sections 209 and 211 of the Act and
Executive Order 11752. Relative to these sites, the
strategy is development and direct enforcement of Section
209 guidelines (mandatory for Federal agencies) together
with the necessary supporting technical assistance and
administrative efforts.
State Role. This strategy relies heavily on State
implementation of a Federal hazardous waste regulatory
program and on a vigorous state regulation and enforcement
of "other" waste management. This strategy envisions
strengthening the state role through fiscal support on a
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flexible basis for both enforcement and for other
preparation for a greater hazardous implementation role.
Thus, EPA is attempting to "strengthen the State role" in
all aspects of waste management.
From the state perspective, the problem is one of land
disposal, states generally have authority to promulgate
regulations for disposal sites and to relate the degree of
regulation to the potential degree of hazard. Many States
have issued regulations only for sites that receive non-
hazardous wastes; a few have regulations promulgated for
both. First, states that do not have the power to issue
disposal regulations should acquire that capability.
Second, states that have general authority should issue
regulations. Third, states that have issued regulations
should implement them, emphasizing the establishment of
hazardous disposal sites separate from sites for other
wastes where needed, available in proximity to the major
waste generators. Thus, to "strengthen the State role"
implies more aggressive use of existing state permit, site
approval, and enforcement powers—particularly with regards
to using existing legislation to develop stricter criteria
for hazardous waste disposal sites, distinct from "other"
sites. Finally, states must take a more aggressive role in
regulating all sites.
states can get ready for the control of hazardous waste.
Current EPA concepts rely on a waste stream-by-stream
approach to direct the worst wastes to selected sites and
requires generators to show the disposition of their wastes.
Few states have .the authority to place similar requirements
on generators, and none have implemented authority (although
the NPDES does provide some leverage). States that do not
have this power should obtain authority; those with
authority should implement it. As a first step, this
approach implies that States should obtain knowledge of
generators of wastes, and present management practices.
States can act to provide a facilitating role (apart from
the incentives which result from appropriate enforcement)
for desirable practices if the State dealrea—for resource
recovery, hazardous waste disposal, or municipal waste
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disposal. Actions may include State involvement in local
siting actions, use of State eminent domain powers,
implementation of low cost, self-financing concept. The
Connecticut Authority appears to be an attractive approach
to address institutional and financial constraints in
disposal, as well as in resource recovery.
To achieve the strategy, EPA will use its existing
authorities to support planning and demonstration activities
at the state level that (a) achieve progress toward
hazardous waste control, (b) increase the pace of standard-
setting and enforcement relative to "other" wastes, and (c)
lead to the establishment of facilitating institutions for
implementation of resource recovery and hazardous waste
treatment facilities.
It is recognized that the states will require some incentive
for stepped-up action. Current authorities limit the range
of Federal influence over State action. However, it is
assumed that a Federal standard-setting role will emerge
from the current legislative cycle, which would require
state implementation. Failing that, EPA will depend on
persuasion and fiscal support for carrying out the strategy.
Hazardous Waste Technology and Effects. Because the level
of knowledge is very low about control technology and
effects of hazardous wastes, and because the Federal
government will require hard data for standard-setting, a
RSD and a demonstration element is absolutely necessary as a
means of developing and justifying standards.
"Other" Wastes. In the "other" waste areas, the level of
knowledge about the environmental and health effects
associated with the many waste streams (animal, crop, and
mining wastes; industrial slags; septic wastes; dredge
spoils; various sludges and residues; and urban waste mixed
or disposed of in combination with special wastes) is
inadequate—particularly inter-media effects, effects on
ground and surface waters, relationships between types of
soils and leachate generation, etc. This strategy envisions
investigations to obtain such understanding to guide better
the assessment of Federal strategies in the future.
16
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B. strategy to conserve Natural Resources by Waste
Recovery and source Reduction
The basic elements to achieve this strategy include:
(1) Technical assistance to promote implementation of
energy and materials recovery systems.
(2) one-time state recovery program support.
(3) Limited demonstration of technology to enlarge the
technical options.
(4) Investigation of cost/benefit aspects of product
regulation and other source reduction methods.
Discussion. The fundamental barriers to implementation of
waste recovery are (1) institutional constraints arising
from the need to form novel institutional arrangements to
practice recovery and (2) the high risk associated with full
scale demonstration of new technology, which prevents
demonstration of such technology with private or State/local
funds.
EPA analyses indicate that resource recovery is already
economically feasible in many areas, will become more so as
regulatory thrusts are initiated, and is not impeded by
fiscal constraints (state, private, and municipal funds are
available) .
The ability of the consulting community to provide technical
aid and consultation is severely limited — largely by the
fact that new systems are proprietary and the basic
information is Federally held (in demonstrations). Thus
this strategy envisions a two-fold thrust — to provide
technical assistance to communities and States and to
improve the ability of the consulting community to provide
services.
Some States have emerged as strong supporters of recovery
system implementation: Connecticut, for instance, with
Federal support, established a state-wide plan, an
17
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independent, authority with funding powers ($250 million in
bonding authority) , and a strong state regulatory program
(to foreclose cheap options) . The state-wide scale provided
by such programs, the state financing potentially available
after an initial planning/implementation effort* and the
ability to establish large and intelligently located
facilities (that provide needed specialized as well as
general purpose facilities) indicates that the State role in
recovery can be strengthened by intelligent use of Federal
resources.
Measures to reduce the generation of waste in essence
represent changes in products and distribution systems
undertaken either voluntarily or by legislative fiat. Such
interventions, unless minor, tend to be associated with
costs to the economy in terms of disruption (jobs lost,
equipment obsoleted, locational shifts, etc.) and must be
carefully weighed against benefits. The benefits are
reduced pollution, conservation of raw materials, and
avoidance or minimization of the disposal function. Because
the benefits of reduced consumption (achieved through less
materials-intensive or longer-lived products or through
substitution of reusable for one-time-use products) are very
significant, assessment of such conservation options is a
key part of the EPA strategy. However, because of the great
variety of products that must be examined, the approach will
be selective, targeted to products or product categories
that promise the most success of achievement at lowest cost.
VIII. SUfflmary, 2£ Programmatic implementation
Through FY 1975, the following program thrusts are en-
visioned to carry out the strategies broadly described
above. The programs are arranged in order of priority
within each major goal area and are presented in categories
that group related activities as closely as possible.
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SUMMARY OF PROGRAM THRUST
A. Environmental Protection
1. Prepare for a hazardous waste regulatory role
a. Develop the data base—health/environmental
effects, quantification/qualification of waste
streams, treatment/disposal technology
b. Develop a regulatory strategy—type of standard,
State role, fiscal and land-use issues
c. Strengthen States to implement a hazardous waste role
d. Implement Section 19, FIFRA
2. Support Federal/State/local efforts
a. Develop technical expertise in special wastes
b. Consolidate/augment technical knowledge or
inter-media effects of land disposal
c. Consolidate/disseminate technical/economic data
on processing and disposal methods
d. Support State regulatory/enforcement programs
e. Implement Section 209 guidelines at Federal
Facilities
f. Other (complete demonstrations and provide
technical assistance)
B. Resource Conservation
1. Promote implementation of energy recovery from mixed
urban wastes
a. Technical assistance to States, localities, and
the private sector
b. Operation and evaluation of projects—EPA demon-
strations and others—to support TA thrust
c. Support of selected State implementation programs
d. Identification and demonstration of new technological
concepts
2. Promote materials recovery through technical assistance
and information exchange in the establishment of separate
collection/recycling programs
3. Conduct a program of studies related to the concept of
conservation through source reduction
a. Benefit/cost trade-offs of economic product
regulation
b. Development and dissemination of information to
foster voluntary source reduction practices
4. Promote the consumption of secondary materials through
Federal procurement and other actions
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Appendix A
Detailed Discussions of Program Thrust
A. Environmental Protection
Two major activities are envisioned to carry out the
strategy: (1) preparation for a hazardous waste regulatory
role and (2) support of Federal, State and local efforts in
the control of other wastes. The major program elements
under each activity are listed and then the activity is
discussed.
1. Prepare for a hazardous waste regulatory role.
a. Develop the data base.
b. Develop a regulatory strategy
c. stregthen states to implement a hazardous waste
regulatory role.
d. Implement Section 19, FIFRA.
Discussion. This is the highest priority activity of the
program. The activity array is a reflection of the current
state of knowledge and is designed to prepare EPA to assert
leadership in the hazardous waste management area in an
orderly manner as soon as possible.
Base. The level of understanding of the problems and
solutions in their various aspects (quantification, hazard
levels, and treatment/ disposal technology) is extremely low.
EPA's level of understanding has been over-stated in the
past based on incomplete data; now it has become clear that
the program has barely begun to understand the hazardous
waste problem. Consequently, the data base development
(which goes far beyond surveys) is an essential first step
toward implementation of a hazardous waste regulatory
program and support of EPA's legislative proposal. This
work is essential regardless of the ultimate Federal
strategy adopted.
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The data base program includes (1) the scientific work
needed to assess hazard of chemicals and waste streams as an
evidentiary base for standard setting, (2) quantification,
(3) technology assessment, development, and demonstration,
and (4) the necessary benefit/ cost trade-off analyses for
standard setting justification.
RegujLatpry Strategy. The proposed HWMA is extremely broad
and flexible in the authorities that it provides. The
specifics of standard setting are not spelled out and many
issues are unresolved in the proposed legislation itself as
well as in general. Thus, it is imperative to focus
resources on the orderly development of a regulatory
strategy to implement HWMA. This work depends to some
extent on data base development (which is ongoing) but much
of it can be carried out in parallel. Major issues that
require resolution include orientation of the regulations
(toward waste streams or chemicals or both; toward
processing or disposal or both) , the precise nature of the
State role, the issue of system financing, land-use
implications of regulations, the issue of "perpetual care,"
the extent of Federal enforcement and the trade-offs between
Federal financing of state programs and Federal enforcement
resource commitments — to name a few.
Support. The proposed HWMA requires a major State
role in implementation. States must be prepared to assume
responsibility for hazardous waste management. This
suggests the need for a major extension of the current State
posture (which is focused toward land disposal site
control) . The strategy calls for strengthening the State
role. Determination of precise State action is impossible
until major policy issues are decided and the legislation
passes. Thus the intent is to assist States to get ready in
the following ways: (1) by using existing powers to
segregate sites, having well controlled sites for hazardous
wastes, distinct from "other" disposal sit«s, but full
control over all sites; (2) by conduct of surveys of
generators of hazardous wastes and establishment of
reporting systems; (3) by acquisition of skilled staff with
requisite experience; (
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hazardous waste disposal/processing sites; and (5) by
general purpose procedural, logistical, and fiscal planning.
To achieve this end, it is essential, first, to ensure a
continuing State role *in solid waste management in general
and, two, to provide some type of seed money to assist
States to extend their activities into hazardous waste
management. EPA will use existing planning grant and
demonstration grant authorities to achieve this end, with
the lead assigned to Regional Offices (see below for a
discussion of the RO role) .
The need to maintain, as a minimum, a viable State solid
waste role is stressed here. From the state1s perspective,
hazardous waste management represents a very different and
new approach to the regulation of waste management. In most
states, hazardous and other wastes are disposed of in the
same site, and from the State*s viewpoint, there is only one
problem—that of disposal.
A State program must have reached a critical mass before the
necessary differentiation between hazardous and non-
hazardous waste can be made at the state level. Thus in
order to ensure a viable state hazardous role, it will be
necessary in some states to ensure first a viable solid
waste role across the board*
§£££i2Q 12x Pesticide Disposal. Under FIFRA as amended, EPA
has regulatory authority over excess pesticides.
Regulations and recommended procedures have been published.
The pesticide disposal issue represents, in a microcosm, the
hazardous waste disposal problem and thus affords EPA with a
test-bed for exploring the issues and problems of hazardous
waste regulation. Thus implementation of Section 19
supports the Agency1s preparation for a broader regulatory
role. The strategy envisions provision of technical assis-
tance to Regional Offices, States, and disposers and the
necessary investigatory, testing, and demonstration work
needed to improve upon the regulations/procedures already
published. It is expected that work under this program
element will be widely applicable for other hazardous waste
standard-setting work later.
22
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2. support efforts in the control of other wastes.
a. Develop technical expertise in special wastes.
b. Consolidate/augment technical knowledge of
inter-media effects of land disposal.
c. Consolidate/disseminate technical/economic
data on processing and disposal methods.
d. Support state regulatory/enforcement programs.
e. Implement Section 209 guidelines at Federal
Facilities.
f. Other
Discussion. The basic strategy related to protection of the
environment from the effects of other wastes is to support
efforts by other levels of government and the private sector
through information dissemination, technical assistance and
guideline promulgation drawing upon past and current
research, studies, and demonstrations. Relative to Federal
facilities, the strategy also relies on a monitoring and
enforcement activity.
The total area of waste management has not been uniformly
explored by EPA. Most of the stress has been on residential
and commercial solid wastes. Very little knowledge about
special wastes exists. Therefore EPA also plans to
concentrate on these wastes to identify their degree of
hazard, impact on the environment (at various levels of
concentration and in various combinations) in order that a
better Federal posture may be developed in succeeding
strategy formulations.
Similarly, groundwater contamination from land disposal
sites of all types has only recently been recognized as a
potentially serious problem (by the emergence of several
cases of severe groundwater pollution). Technology for the
capture and treatment of leachate is not proven. The EPA
strategy therefore will involve the further quantification
and assessment of the problem and development/demonstration
of leachate collection and treatment processes.
23
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Special Wastes. As a consequence of Federal research,
development, and demonstration, the state-of-the-art and the
state of knowledge in residential and commercial solid waste
collection, processing and disposal has been substantially
advanced in the last eight years. However, national under-
standing of a wide variety of special wastes is extremely
low as concerns quantities generated, geographical
occurrence, damage and hazard, control methods and costs.
Many such wastes can be presumed to have adverse, and
possibly seriously adverse, effects on the environment. It
is essential, as part of a national program, to explore this
area in some depth now that what has traditionally been
considered the chief problem in waste management—
residential/commercial waste—is better understood.
Emphasis of this exploratory program element will be on the
following special wastes:
• Sludges and semi-liquid residuals (e.g., paper plant
sludges, waste chemicals, industrial dyes, tannery
wastes, septic tank pumpings, and the like)
• Pollution control residuals, especially new wastes
(e.g., sulfur removal system sludges)
• Dredge spoils
• Animal wastes, especially confined animal raising
facility wastes
• Crop wastes, especially where currently open burning
is the only "practical" disposal method
The objective of the program element is to acquire the
necessary management know-how in order to advise States and
localities and to determine the level of control (Federal or
other) that should be applied. Guideline promulgation
under Section 209 of the current Act may result from the
investigations. The work under this element is also viewed
as supportive of EPA enforcement actions under the 1899
Refuse Act and the Federal Water Pollution Control Act (PL
92-500).
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Land Disposal. The objective of this element is to
consolidate, disseminate, and augment as necessary existing
technical knowledge about land disposal — in part as support
for EPA hazardous regulatory work, in part as support of
state and local control activities. Too little is known
today about the relationships between such factors as ground
and surface water quality, geology, soil types,
precipitation, seasonal factors, population density, and
similar factors on the one hand and waste disposal on the
other. A body of information has been assembled as part of
EPA* s planning efforts in solid waste and as a result of
other program activities. This information must be made
useful to guide decision-making at all levels of government,
especially in terms of standard setting and cost/benefit
evaluation. Some areas of investigation, especially
concerning lea chat e generation, must be expanded to
establish exact levels of national damage. Leachate
collection and treatment will be evaluated and demonstrated
to show methods available for preventing groundwater
pollution at low cost. The results of this work will
eventually be promulgated as Section 209 guidelines.
Technical/ Economic Data o£ Process ing/Pi sposal . A very
important national support function to states and localities
is the provision of objective, unbiased technical and
economic information to allow appropriate local decision-
making. The Federal government has invested around $50
million in technology development through demonstrations and
studies. One objective of this element is to consolidate
and to disseminate the results of this work. Another is the
development of such data about special waste handling, with
emphasis on special disposal methods that are poorly
understood, e.g., deep well disposal, such study and
dissemination activity is a proper national activity in that
at the Federal level significant economies can be achieved
and a national perspective developed. Good technical and
cost information is a necessary adjunct of good regulatory
activity (at all levels) and thus directly supports envi-
ronmental protection objectives. Under this program
element, additional Guidelines under Section 209 of the Act
will b« iaau«d.
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State support. It is envisioned that state programs will be
supported on a limited scale in close coordination with the
hazardous waste thrust as already discussed above.
Federal Activities. Executive Order 11752 and Section 211
of the Solid Waste Disposal Act make EPA solid waste
guidelines mandatory for Federal agencies and all land
disposal activities carried out on Federal land. In
essence, these mandates establish a regulatory program for
all types of land disposal at Federal facilities. This
program is a high priority effort by EPA to show leadership
by the Federal government to clean up its own activities.
The effort involves (1) administrative and planning efforts
to establish a Federal compliance program, (2) monitoring
progress, and (3) providing guidance and technical
assistance to other agencies in implementation.
other. This activity includes completion and evaluation of
currently funded demonstrations related to land disposal,
transportation, and processing. Technical assistance (TA)
will also be provided, but with a changed thrust and focus.
Increasingly TA will be provided from the regional rather
than the national office; (recognizing the limitation, at
least through FY 75, of manpower in the Regions) . Where TA
is provided, environmental as well as economic improvements
will be considered-with the recognition that the two may be
inextricably intertwined or that achievement of an
environmental goal may require technical assistance that
saves the recipient money.
B. Resource conservation
Four major activities are envisioned to carry out the over-
all strategy: (1) promotion of energy recovery; (2)
promotion of materials recovery; (3) studies of conservation
through source reduction measures; and (4) promotion of
secondary materials consumption through Federal activities.
1. promote implementation of energy recovery (and
incidental, related materials recovery) from mixed
urban wastes
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a. Technical assistance to states, localities,
and the private sector
b. Operation and evaluation of projects—EPA
demonstrations and others—to support TA
program
c. State implementation program support
d. Identification and demonstration of new
technological concepts • ^ ,<.
' 0
Discussion. The basic rationale for energy recovery from .
mixed urban wastes has already been presented. Here it
should be noted that this program activity directly supports
State and local regulatory efforts aimed at residential and
commercial solid wastes by providing a viable alternative to
land disposal of most of such waste (but note that energy
recovery has not yet been proven as a solution to most
industrial residues that are now going to disposal).
Technical assistance is seen as the best method of
implementing energy recovery (which is typically accompanied
by metal and glass separation and recovery). Barriers to
energy recovery are largely institutional—energy recovery
requires new types of fiscal, marketing, management, legal,
and technical approaches. Increasingly the technical
assistance delivery function will be transferred to the
Regional Offices, while investigatory, evaluation, and other
TA support functions will be maintained in headquarters.
Such support work flows from the operation of EPA
demonstrations as well as the evaluation of projects in
which EPA has no financial interest. Results of evaluations
will be issued in the form of guidelines under Section 209
of the Act,
Based on the experience in the State of Connecticut (and in
other states as well) the State can play an important role
in making energy recovery happen. The State role, ideally,
is that of the system planner, the source of financing
(through bonding authorities), and the coordinator of state-
wide marketing. Strengthening the State role thus appears
an intelligent way to achieve energy recovery. The strategy
selected is to provide initial, one-time funding support to
a selected number of states (three to five) to launch atate-
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wide recovery programs. This strategy will be implemented
as soon as resources allow. The support would be
constrained so that the best possible program—with such
features as an independent but non-regulatory authority; an
independent, state-backed fiscal program; a strong
environmental control thrust; and a rational
logistical/processing plan (based on waste-shed or similar
concepts)—results from the Federal involvement.
Current activities in energy recovery have been sparked
largely by EPA demonstration of new technology at full scale
(begun some years ago—before the energy crisis) . The
private sector has shown a willingness and ability to
develop prototype technical solutions. However, industry
has been unwilling to invest in full-scale demonstrations
while cities have been equally reluctant to take risks on
new technology. They want to see a plant in operation
before investing in the technology for themselves. Thus the
EPA demonstration program has been extremely successful in
overcoming risk. A large number of cities are now actively
pursuing implementation of the St. Louis shredded-fuel
concept, and two cities have already committed to move
forward with projects. Thus there is evidence that Federal
demonstrations will be implemented by other cities without
Federal funding support.
A Federal demonstration activity is thus seen as desirable
to provide demonstration of improved technology. In the
time-frame of this strategy document, it is planned to take
a cautious but positive attitude toward demonstrations
(especially in light of six on-going projects, only two of
which are operational at this time). Active identification
and evaluation of new technical concepts will be undertaken.
Resources permitting, new demonstrations may be launched
late in FY 1975.
2. Promote materials recovery through technical
assistance and information exchange in the
establishment of separate collection/recycling
programs
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Discussion. Technological processing of waste is only one
approach and not suitable to a number of important waste
categories or components. Paper, abandoned automobiles,
rubber tires, and waste oil are best managed as separate
streams—paper being source-segregated as a preliminary to
recycling, while the others usually occur in concentrated
form or in isolation from other types of wastes. Recycling
of such wastes—especially in the current shortage
situation—is impeded by logistical difficulties rather than
weak markets. Abandoned automobile collection has
logistical as well as legal ramifications (titling laws).
The emphasis will be placed, in this program element, on
aiding States, localities, and the private sector to
initiate effective collection programs. This will be
accomplished by evaluating successful programs and by
transferring the information to those attempting to set up
new ventures. Priority will be given to paper, an area
where the recycling technology is well developed and
collection system start ups can materially increase supplies
in a shortage situation.
3. Conduct a program of studies related to the concept
of conservation through source reduction
a. Benefit/cost trade-offs of economic
regulation of products to achieve
conservation of materials and energy
b. Development and dissemination of
information to foster voluntary source
reduction practices
Discussion, source reduction is a conceptually appealing
and potentially very conservative notion. Where it occurs
naturally (as a result of shortages or as a consequence of
voluntary citizen buying choice) , the result is beneficial
from a resource point of vantage and (to a less certain
extent) from an environmental point of vantage as well.
However, where source reduction is achieved by public policy
measures—while the same benefits will result—the issue of
coata/b«nefita ariaes.
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Source reduction is fundamentally economic regulation to
achieve an economic benefit at an economic cost. There is
very little precedent for prohibitory type of economic
regulation of this type—although there are numerous
instances of regulation for health and safety reasons and
the provision of positive incentives to promote economic
well being (e.g., tax laws favoring minerals exploration).
Source reduction, thus, represents a new national venture,
analogous to current energy conservation measures, with one
notable difference: source reduction is a relatively
indirect approach to conservation in attempts to change
product use (thus indirectly impacting on materials and
energy consumption to make the product).
Source reduction approaches can be regulatory, voluntary, or
some combination of these (e.g., voluntary product
standards). By the very nature of the subject, different
approaches are applicable and desirable for different
products or product categories. In some instances,
legislative solutions may be best; in others voluntary
efforts can achieve the same results; in yet others, a do-
nothing approach may be necessary.
The study component of this activity will sort out the
cost/benefit issues involved in source reduction—and will
also track the effect of shortages on product use patterns--
so that policy decisions can be made in the future on
whether or not to pursue a legislative route to achieve
conservation by product regulation. The information
dissemination element will be to inform the public about
product consumption issues so that voluntary conservation
actions can be taken in light of the best information.
source reduction efforts are said, by some, to conflict with
resource recovery efforts in that valuable commodities are
removed from the waste stream, thereby adversely affecting
the economics of recovery. EPA analyses show that the
critical parameter in recovery system feasibility is the
price received for the fuel component of waste (on the order
of $12 per ton in favorable cases); the revenue received for
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materials is quite low by comparison (on the order of $2.50
per ton of input), For this reason--and because of much
higher overall resource/energy benefits associated with
source reduction, the conflict is more apparent than real.
U. Promote the consumption of secondary materials
through Federal procurement and other actions
Discussion. This is the continuation of an existing
activity, which includes joint projects with GSA, ICC, DOD,
FMC, FTC, and other agencies to re-orient Federal actions
that tend to inhibit secondary materials consumption.
Studies are underway on the potential for secondary
materials inclusion in construction materials and
lubricating oils; a joint study with DOT may result in
uniform retreaded tire standards (feasibility is not
certain) ; a study is also underway to examine the potential
for energy recovery from waste at Federal facilities. In
addition, various other inter-agency contacts are being
pursued to aid other agencies or to urge their action on
such issues as procurement, labelling, separate collection,
packaging re-design, and the like.
It is planned to continue such activities as part of the
general resource conservation strategy.
C. Headquarters and Regional Office Roles
It is the intention of EPA to strengthen the Regional office
role in three areas: (1) implementation of State programs,
(2) creative use of existing Federal regulatory powers, and
(3) delivery of technical assistance. At the same time, it
is intended to improve the headquarters services and
technical/scientific/economic support and delivery to the
Regions.
State Programs. The Regional offices already administer all
EPA state programs, including existing solid waste planning
grants (but not state demonstration grants). The unique
ability of the Regional Administrator to coordinate,
integrate, and to trade-off various components of EPA's
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program support, to States should be fully exploited; such a
stance is also consistent with the recognition that the
State programs are very diverse and require flexible yet
cross-EPA management.
The Regions should provide better guidance to State programs
and manage EPA solid waste grants to achieve the overall
national policy. The States need to articulate a cogent
solid waste strategy, commit to attaining outputs relating
to environmental performance and commit to applying
appropriate inputs (staff, expertise) to solid waste
efforts.
EQfojrcement and/or Assistance in Enforcement. There is no
Federal solid waste regulatory power, but, to a degree.
Regions can and should use other legislation—Air, Hater,
1899 Refuse Act—to eliminate insults from offensive solid
waste practices. Also, the Regions should offer assistance
to States in enforcement actions, particularly where States
are reluctant to act. Finally, Regions should assure that
maximum leverage is obtained over land disposal practices
through other permit systems, primarily NPDES, as discussed
in the Water Strategy.
Technical Assistance. Regions now provide a bewildering
variety of technical assistance with commendable results.
Ideally, TA services should be available as close to the
requestor as possible and be handled by staff maximally
aware of local/regional conditions. To achieve such a
situation, EPA plans, over time, to increase Regional Office
TA resources and to develop appropriate headquarters
services to regions to back-up TA delivery. Specialized TA
services would continue to be provided from headquarters,
but the general strategy will be to make the Regional
Offices the cutting edge of TA delivery first in non-
hazardous wastes and eventually in hazardous wastes.
In some instances. State leaders and legislatures will need
assistance, for instance, to gain and implement authority
for regulatory efforts over a variety of wastes or for
establishing new institutional arrangements to stimulate
resource recovery, other regional assistance efforts should
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be directed toward areas where states or others have little
expertise—primarily in hazardous wastes or resource
recovery.
D. OSWMP and ORD Roles
It is contemplated that the existing OSWMP/ORD roles would
be continued, with ORD responsible for a program of R&D
responsive to OSWMP guidance. The current research
priorities are: (1) hazardous wastes health/environmental
effects R&D, (2) hazardous waste technology R&D, (3)
resource recovery R&D, and (4) general land disposal
investigations.
Demonstration work and short-term policy studies will
continue to be an OSWMP responsibility. A detailed guidance
document is transmitted to ORD annually.
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APPENDIX B
Environmental, Health, and Safety Impacts
of Improper Waste Management
The purpose of this appendix is to (1) generally describe
the problems of improper waste management as well as
possible, given the sparcity of adequate data at this time,
and (2) to describe the efforts being undertaken by EPA to
better define the problems. Adverse impacts have been
usually portrayed by examining the potential for damage, by
examining the kinds and types of wastes disposed, and
illustrating damages from case histories. Although a
pattern of adverse effects emerges, the magnitude of the
impact and its comparison to other environmental problems
has not been well expressed. This appendix attempts to draw
some generalizations that are widely applicable.
A. Waste Volumes
Solid wastes are a disparate collection of unwanted materials—
the residues of production and consumption, solid by-products
of removing pollutants from air and water, litter discarded on
the countryside, the "unusable" overburden of mining operations,
the unharvested or inedible remainder of agricultural and animal
production activities. Waste volumes are large, estimated at
4.5 billion tons per year. The management of these volumes costs
approximately $6 billion annually. The following is representa-
tive of the kinds and amounts of wastes which are disposed of,
totalling nearly 200 million tons annually.
Thousand Tons Per Year
Mixed municipal wastes 125,000
Pesticides and pesticide containers 150
Waste Oil 2,275
Industrial wastes currently dumped
in the ocean 4,400
Dredge spoils currently dumped in
the ocean 38,428
Explosives 120
Sewage sludges 4,400
Radioactive wastes (solids and liquids) 7
Selected suspended industry solids
currently discharged into the water 1,111
Utility stack sulfur sludges (current
dry weight with ash) 1,824
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B. Pollution and Health Damages
Ground and Surface Water Pollution from Waste Disposal;
Ths most difficult damage to document is the impact on
ground and surface waters. Waters become polluted from
leachate generated at a disposal site. The quality,
quantity, and effect of leachate is variable from site to
site, and an extrapolation to a national level is difficult.
Some of the more critical variables in the quantity and
quality of leachate and its effects are:
• Composition of waste inputs: Composition affects the
quality of leachate, but in almost all cases the
levels of contamination of leachate far exceeds that
of groundwater. Certain wastes, namely sludges, are
high in moisture content and rich in heavy metals.
The leachate generated from such wastes is obviously
very detrimental.
• Soils: The type of soil and soil depth between the
bottom of wastes and the water table determines the
quality and quantity of leachate finally reaching
groundwater. Soil biota act on bacteria and soils
absorb heavy metals. The degree of attenuation is
primarily related to the length of time the leachate
remains in the soil and the exchange capacity of the
soil. Leachate passes quickly through sandy soils
and slowly through more clay-like soils.
• Water input to the site: After the landfill has
reached its moisture capacity, further water input
will result in an equivalent leachate flow. The
amount of water input to the site depends on a number
of variables; the primary one is rainfall.
• Water table: The height of water tables affect the
depth of soil available to attenuate leachate. Water
tables vary nationally, location to location, and
seasonally. The direction of flow would indicate
where possible damages might result. In some cases
groundwater would be discharged into a nearby stream
or swamp; in other cases it could be part of a
regional aquifer used as a drinking water supply.
The degree of flow of groundwater near a site affects
mixing, dilution, and the time for it bo be cleansed.
Groundwater flow may be very slow; damage may have
long term effects. *
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EPA does not have broad regulatory control over the many
wastes and disposal practices that may affect groundwater.
The Federal Water Pollution Control Act does address the
issue of land application systems for the treatment of
municipal wastewater. The NPDES permit system does provide
some additional leverage over land disposal practices, but
the degree of control is limited.
The potential damage that may result from contamination of
groundwater may be significant but is not yet known. Half
of the population is served by groundwater supplies for its
drinking water. Ninety-five percent of our rural population •
relies on groundwater for its drinking supply. Municipal
drinking water systems typically rely more on treatment of
surface water than groundwater.
The potential for groundwater contamination by leachate does
not occur uniformly across the nation. For example, most of
the West is arid and has generally low water tables. Areas
with greatest potential problems are generally in the
Pacific Northwest and all land east of the Mississippi, with
acute problems in coastal areas and in some States in the
Southeast and Northeast. There are roughly 9000 disposal
sites east of the Mississippi, out of a total of over 15,000
sites nationally.
Based on a limited number of leachate samples examined by
ORD, the quality of leachate is significantly worse than raw
sewage or drinking water standards (probably the applicable
comparison, since groundwater has limited dilution/cleansing
capacity). For example, BOD levels of leachate are
typically 10,000 - 15,000 ppm, roughly 200 times that of raw
sewage and 15,000 times that for drinking water. Iron
content is 1000-10,000 times that of raw sewage and roughly
20,000 - 200,000 times that for drinking water. Note that
these figures are for leachate from non-hazardous wastes.
Over 70 percent of all sites accept hazardous wastes; leachates
from these sites may be significantly worse. Leachate
flow can be significant. An average site (roughly 20 acres)
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discharges roughly 20,000 gallons/day, if the annual net
infiltration rate is 12 inches. Sites range up to 300
acres.
Data obtained in 1968 indicate that roughly 20 percent of
land disposal sites east of the Mississippi are in direct
contact with groundwater. Thus, discharge from land
disposal sites, even assuming soil attenuation at the
majority of sites, is significant.
More than fifty cases of various kinds of damage resulting
from waste disposal have been recently documented by EPA.
Several examples of damages are (1) contamination, from a
municipal disposal site, of a drinking water supply serving
40,000 people in Wilmington, Delaware, (2) stream
contamination with PCB's due to dumping directly into a
spring in Tennessee, and (3) cyanide poisoning of animals
from wastes dumped in contact with groundwater in Colorado.
Efforts are now underway to define better the problems
resulting from the land disposal of wastes. The most
visible part of this work will consist of the acquisition of
leachate samples and other environmental data from 15 to 20
actual land disposal sites representative of conditions
across the nation. But associated with this work will be
continuation of several other projects carried out by EPA's
Office of Solid Waste Management Programs, and Office of
Research and Development.
Air Pollution from Waste Processing or Disposal
Air pollution results from incineration and from open
burning of wastes. In 1968, the estimate of contribution to
air pollution was 8 percent; in 1971 the contribution was
roughly 4 percent, a marked decrease. The contribution from
incineration of wastes is small, less than 1 percent of the
total.
Existing incinerators and burning at land disposal sites are
subject to controls set forth in state implementation plans.
Incinerators are on a schedule to meet ambient air quality,
as set forth in the plan. Purposeful open burning is
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prohibited in most areas, although exceptions may be granted
for sparsely populated regions. In addition to compliance
schedules set by implementation plans new incinerators are
subject to new source performance standards under the Clean
Air Act.
The most valid measure of the problem is the amount of
pollution caused by variances from implementation plans.
These data are not readily available, although known
violations occur and damages do result. For example, air
implementation plans can not prevent "accidental or
spontaneous" fires that may occur. One such fire occurred
near the New Jersey Turnpike, added to poor visibility and
contributed to numerous collisions resulting in nine deaths.
As part of its overall hazardous waste, energy recovery
work, and other programs, EPA is examining the thermal
degradation of a number of wastes, or components of wastes
where standards have not been set. Of primary concern is
the level of emission of heavy metal compounds from the
incineration of municipal solid waste, water treatment
sludges, and industrial sludges. A special concern is the
degradation of other compounds, e.g., pesticides, and those
resulting from the burning of plastics.
Vectors ajt Land Disposal Sites.
Vectors (rats, flies, etc.) can find food and harborage from
improperly operated landfills. Under certain climatic and
demographic conditions (e.g., desert, sparse population),
health hazards from vectors have not been documented. Under
densely populated conditions, they present a greater menace.
Rats seldom travel more than 150 feet from an operating
site, although site closings may cause these rodents to move
farther afield in search of new food sources. There are
known cases of rat bites resulting from dump operations (as
opposed to those from improper storage practices). Fly
borne diseases are now rare in the United States, and in an
extensive study carried out on behalf of EPA, no such cases
of diseases were found.
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Vectors from Improper Storage and/or Collection.
Vectors from improper storage and/or collection mostly
affect the inner cores of cities. The 30 million Americans
residing within inner city areas of our cities share their
environment with upwards of 100 million rats. A nationwide
study by DREW indicates that more than 45,000 people are
bitten by rats each year. The majority of those bitten are
small children and the elderly. Rat bites are a traumatic
experience and have resulted in disfigurement, sickness, and
death. The prompt and efficient removal of solid waste from
inner city areas is the key to reducing rat populations. An
EPA study on inner city problems showed that residents did
not get adequate collection service in some cases, but that
underlying social-economic problems and citizens' personal
habits were greater factors in eliminating health hazards.
Safety at Land Disposal Sites.
Accident hazards exist at land disposal sites. National
Safety Council figures show a frequency of injury in solid
waste disposal operations of nine times that of all
industry, and man-hours lost of eight times the average for
all industry. The annual totals of deaths at landfill sites
is not known but is likely to be less than 20 deaths.
Deaths primarily result from equipment operator accidents
involving exposure to hazardous wastes, especially flammable
chemicals.
Safety o£ the Collection of Wastes.
National Safety Council figures show a frequency of injury
11 times and an intensity five times that of all industry.
A study of 30 solid waste organizations found that the
direct and indirect costs of injury may amount to as much as
20 to 25 percent of labor costs in this labor intensive
industry, or potentially $1 billion annually.
Fires resulting from Improper Storage and/or Collection.
The National Fire Prevention Association reports that the
total number of fires in the United States in cities of
25,000 or more for 1972 was 1,050,000. These fires took the
lives of 11,900 persons. No national figures exist for the
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fires caused by solid waste accumulations: figures for
Washington, D. C. show that 50 percent of fires are related
to solid waste; 50 percent of all fires in New York City are
associated with solid waste; Seattle statistics show that
solid waste was the first material ignited in 17 percent of
all fires. From these estimates, a sizeable percentage,
perhaps 40 percent of the deaths resulting from fires,
involved unacceptable waste accumulations.
Hazards at: Land Disposal Sites.
Hazards caused by improper land disposal sites: (1) reduced
visibility from smoke, (2) bird collisons with aircraft, and
(3) explosions or suffocation resulting from the migration of
decomposition gases (methane) or combustion gases (carbon
monoxide) to confined areas. The discussion of air
pollution cited the 1973 example of reduced visibility from
a burning dump contributing to poor visibility which resulted
in 9 deaths; in addition, smoke has contributed to poor
visibility at airports (e.g., San Francisco), but has not
been blamed for accidents. Birds attracted by a continuing
food supply at a near-by open dump collided with a landing
aircraft in Atlanta in 1973. The aircraft crashed, killing
15 people; similar cases have occurred in Boston and in
Maryland. In 1973, two members of a Pennsylvania family
were killed and others were paralyzed when carbon monoxide
from an underground fire in a dump migrated to their home.
The sites east of the Mississippi generate 300 billion cubic
feet of methane annually, a significant explosion potential.
(This also represents a significant opportunity; this is
enough energy to supply the natural gas needs for about
1,000,000 homes). Proper design and operating procedures at
a land disposal site can minimize these damages.
C. Aesthetic and Other Damages
Aesthetics.
Measurement of aesthetic degradation is difficult. The
problem lies in quantifying how much litter, for example,
detracts from one's enjoyment of a particular landscape or
lowers the value of the land. Such impacts might be
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quantified by ascertaining how much people are willing to
pay to avoid the aesthetic degradation of improper waste
management. But difficulties center around the fact that
the person who objects to litter is not the one who litters;
or the person who would be willing to pay an equitable share
to close an open dump in his neighborhood is normally not
the same as the one whose wastes go into that dump and who
may wish to pay nothing since the problem is not in his
neighborhood or jurisdiction. The best indicator of
aesthetic degradation may be the significant level of
interest in measures to prevent such degradation,
principally bills to ban one-way beverage containers or to
eliminate unsightly junkyards.
Adverse Economic Impact.
Improper solid waste disposal (principally open dumping) has
been demonstrated to have an adverse economic impact on land
values. Although no national figures exist on such impact,
studies in California and Virginia have shown, for example,
that the operation of a sanitary landfill on a specific
parcel of land can raise the land's value by as much as 100
percent, depending upon the end-use (e.g., recreation) for
which the land is planned once the fill is completed. Open
dumps, on the other hand, were found in the same study to
reduce land values by as much as 90 percent. Land use and
conservation of land resources is clearly a problem
connected with the improper management of urban wastes.
In addition to the impact on health, fires result from
improper storage of wastes in inner-city areas. The total
damage of all fires in 1972 in cities over 25,000 was over
$2 billion. Solid waste contributed to 40 to 50 percent of
these fires, or accounted for an estimated cost of about
$1 billion.
Rats also are a cause of property damage. The cost of
destruction is in excess of $1 billion each year. Most of
this damage is from rats feeding or contaminating stored
grain, but some damage results from improper waste
management in inner-city areas.
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Inequitable, Inter-personal, and Inter-population Effects.
Like air and water pollution, improper solid waste
management also creates inequitable inter-personal and
inter-population effects. The person who lives in an area
in which wastes are disposed of in an open dump suffers the
costs of that dump. Persons whose wastes go into that dump
do not. This problem is real, and has been the subject of
court suits. A review of these suits clearly indicates that
such effects cross local jurisdictional and State lines.
What is more, this impact is normally levelled on poor
groups without political power in their communities. A
study for EPA of 83 land disposal sites found a one-to-one
correlation between income/race indices and the quality of
disposal sites. Of the 83 sites studied, 17 were proper
sanitary landfills. All were in high income, white areas.
The remaining 66 were open dumps; all were in low income,
black neighborhoods.
Other inequitable effects are found in different levels of
collection service between inner-city poor areas and more
well-to-do suburbs. Persons in the inner-city suffer the
costs of inadequate collection but are dependent upon the
well-to-do suburbs to help defray the costs of adequate
collection. The well-to-do suburbs, however, receive none
of the benefits of adequate inner-city collection, and hence
have demonstrated a remarkable resistance to help shoulder
part of the bill.
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