United States June 1980
Environmental Protection" OPA 98/0
Agency
Hazardous
Waste-
Fifteen Years
and
Still Counting
Thomas F. Williams*
It is a pleasure to be here at the annual meeting of the
Baltimore Environmental Center and to have this oppor-
tunity to share a few thoughts with you on hazardous
waste. In the first year of this new decade, the U.S. En-
vironmental Protection Agency will publish major regu-
lations under the Resource Conservation and Recovery
Act. After that there will be fewer excuses available to all
the segments of society who have important roles to play
as we begin to reverse a deplorable practice which has
prevailed throughout our history—the practice of dis-
posing of waste, hazardous or not, in the cheapest and
easiest way possible.
RCRA, which became law in December 1976, is struc-
* Deputy Director, Offi^4ifili
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tured to ensure that from now on our society takes its
waste management responsibilities seriously. Unfortu-
nately, it was not until the Act was about two years old
and the Love Canal tragedy forced our attention on the
magnitude of the residues of past neglect, that we
noticed RCRA's limitations. Except for an imminent
hazards provision, the Act does not address critical
problems which have recently come to light from a dark
legacy of incredibly careless waste management. We now
know that there are two hazardous waste problems—the
one we have inherited and the one RCRA is intended to
solve. We know also that neither can be neglected, ex-
cept at the cost of extreme peril to ourselves, our chil-
dren and people yet unborn.
We produce 57 million tons of hazardous waste each
year. There are more than 750,000 generators of hazard-
ous wastes, 10,000 transporters, and 30,000 treatment,
storage, and disposal facilities. At least 90 percent of the
hazardous wastes currently produced are disposed of im-
properly and unsafely. There are up to 50,000 uncon-
trolled closed and existing sites.
More than 60,000 chemicals are now in common use
in this country; thousands more are registered each week.
The adverse effects of mismanaged waste can reach us
through direct contact, through the air we breathe, the
food we eat and the water^we drink. It is of critical.im-
portance that we keep waste from' seeping irito the
groundwater. About half of the'drinking-water supply in
this country is taken from groundwater. Twenty percent
of the population drinks;groundwater untreated.
As you know, because EPA failed to produce RCRA
regulations within eighteen months as stipulated in the
law, civil actions have been brought against the Environ-
mental Protection Agency by the State of Illinois; the
Environmental Defense Fund, et al.; Citizens for a
Better Environment and the National Solid Waste Man-
agement Association. Last October, Douglas Costle,
Administrator of EPA, in a quarterly affidavit on EPA's
progress in developing final regulations, said "Among
the many pressing environmental problems currently
facing EPA and the Nation, I consider hazardous waste
the most serious," He indicated that EPA will publish
Section 3002 Generator standards, Section 3003 Trans-
porter standards and 3010 Notification regulations in
February 1980. In April, EPA plans to publish Section
3001 Waste Identification Methods, 3004 Interim Facil-
ity Standards, 3005 Facility Permit Requirements and
3006 Requirements for Authorization of State Hazard-
ous Waste Programs. We hope to have 3004 Technical
Design Standards out in October of this year. So we are
soon to begin the cradle to grave regulation of Rose-
mary's baby.
Mr. Costle also pointed out in the affidavit that we
have received more comments on RCRA than on any
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proposed regulations in the history of the Agency. At
that time we had 1,200 sets of public comments, some of
which were hundreds of pages in length.
At the same time that we have been involved in imple-
menting RCRA, we have had to begin to deal with the
problem of closed and existing uncontrolled sites, which
was not anticipated in the Act. Working with the De-
partment of Justice and the states, EPA has initiated a
remedial and enforcement program directed against
hazardous Waste sites which pose substantial risk to
public health and the environment. Regional offices
have been required to redirect hundreds of work years
towards this effort. Hundreds of sites have been investi-
gated and a number of major enforcement actions have
been initiated.
To provide funds for the clean up of abandoned sites
md to permit a more rapid response where health and
;he environment are threatened, EPA developed legisla-
:ion which was submitted by the President to Congress
.ast June to establish a multi-million dollar "superfund."
Hearings on the proposal have been held by several con-
gressional committees.
This evening it is not my intention to explore further
with you the dozens of horror stories about hazardous
waste mismanagement which could keep us occupied for
weeks unending. Instead, I should like to try to get a
glimpse of the roots of this toxic efflorescence which has
io suddenly become visible in our country. We cannot
lo so without looking back. I have been around too long
:o beaqualified member of the"me" or "now" genera-
ions. I ascribe to the view that unless we know where we
lave been, we are ignorant in the present and blind to the
uture.
The original progenitor of RCRA was born in 1965.
That means we are on the verge of beginning to move
igainst hazardous waste fifteen years after the first federal
aw to deal directly with the waste problem was enacted,
en years after the historically significant Earth Day cele-
jrations occurred and three years after the Resource
Conservation and Recovery Act was signed into law.
iVhy has it taken so long? Well, for those who enjoy the
nusic of the environmental movement, but do not pay
nuch attention to the lyrics, the reasons are simple. Cor-
)orations are evil and so are bureaucrats at all levels of
government who, wittingly or unwittingly, are in collu-
ion with them—and that's all you have to know about •
listory. But if it were that simple perhaps a few hundred
tudents could gather key hostages from industry and
jovernment and hold them until the last abandoned
lumpsites were cleaned-up and all the provisions of
ICRA were implemented, and that would be that. It is,
)f course, not that simple.
I think it is significant that a reluctance and an am-
nvalence about the waste issue was already apparent in
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1964, the year that the original Solid Waste Disposal Act
was being developed. Passage of the Act was stimulated
by the fact that air pollution control authorities in the
Public Health Service of HEW, who had plenty of other
problems to worry about, found themselves confronted
with thousands of open-burning dumps throughout the
country. Even though the original Act was attached to
air legislation, the solid waste management business was
considered to be so far outside the mainstream of envi-
ronmental and public health considerations at that time
that some of the officials of the Air Pollution Program
who needed the Act to meet their objectives, nevertheless
felt that the program should be placed in HUD instead
of HEW. As it turned out, of course, they did not get
their wish, but they continued to regard the waste issue
as alien to their territory.
The new Solid Waste Act authorized the creation of a
modest program of research and technical assistance to
states, local governments and interstate agencies. Major
emphasis was placed on municipal waste disposal—
where it remained for many years to come.
Indeed, during the first full five years of the program's
life, virtually no attention was paid to groundwater
problems, to hazardous waste or to source reduction or
recycling. Helping municipalities replace open dumps
with sanitary landfills, which at the very least were
aesthetically superior to dumps and did not add to air
pollution, was perceived as the only issue in need of im-
mediate attention. Unless there are countervailing forces
from the outside,institutions tend to do what they orig-
inally set out to do and, evidently, to go on doing it
forever.
In 1970, the Congress amended the original law and
produced the Resource Conservation and Recovery
Act, which was given a three year life span during which
new information was to be developed to help Congress
better determine what kind of "permanent" federal legis-
lation would be most effective. Actually this amounted to
a compromise stand-off between the key congressional
committees, who, the new Nixon Administration feared,
were about to convert the Solid Waste Disposal Act into
a vast public works program and the new Administra-
tion, which as subsequent developments made clear, was
not certain solid waste management needed any federal
involvement at all.
The 1970 Act called for several studies on various
aspects of resource recovery but it also called for a
comprehensive investigation of hazardous waste man-
agement practices in the United States, with formal
reports to be submitted to the Congress. Those responsi-
ble for the program in HEW were barely able to see
copies of the new Act when they and their program
moved to the newly created Environmental Protection
Agency.
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For an assortment of reasons, ambivalence prevailed
and all the required reports were delayed. In the new
Agency this program was subjected to benign as well as
malignant neglect. Operating funds were delayed. The
new manager of the program understandably—seemed
rather uncertain as to whether his primary job was to im-
plement the law as written or to administer it in such a
way as to diminish or nullify its stated purposes. The
host agency, for its part, gave the Solid Waste
Management Program all the tender loving care of an
unwanted orphan in an institution which at that time
seemed to regard only air and water pollution as
legitimate offspring.
The report on hazardous waste, due October 26, 1972,
was released to Congress on July 3, 1973. Even worse—a
half year he/ore that, in January 1973, wh&n the Presi-
dent's environmental budget was announced, it con-
tained a surprising request for $5.8 million for EPA's
Solid Waste Management program in fiscal year '74—
down from about $36 million in fiscal year 73. The staff
was cut from 300 to 120 persons. The program was
ordered to focus exclusively, however, on hazardous
waste, which on the surface seems at least half intelli-
gent, until you stop to consider that with 5/6 of the
budget and 2/3 of the staff removed there was little to
focus with, however narrow the scope. The Solid Waste
Management program, an orphan before President
Nixon announced his new environmental budget in
lanuary 1973, had become an outcast. Few seemed to
:are, within or outside of EJ?A. That included the major
Dublic interest groups orthe environmental community
which were still apparently intoxicated by the bold regu-
atory moves in air and water pollution which engaged
:hc passions and interest of the leaders of the new
\gency. That is the way it was. If what the Federal gov-
ernment does is a reflection of what active public opin-
on wants and 1 believe it usually is—not many people
;ave a damn about waste, hazardous or otherwise.
Later, in 1973, the Congress passed a one year exten-
sion of the 1970 Act, appropriated $8.7 million for
• P A's solid waste effort, freed $6 million of unobligated
!08 Demonstration funds which had been held in OMB,
md requested that 60 people be added to the 120 posi-
ions remaining in EPA's Office of Solid Waste Manage-
iient Programs. This represented some improvement, of
xnirse, but the patient's recovery in the executive branch
>f government was not destined to be rapid.
What was left of EPA's Office of Solid Waste pulled
tself together and worked on. Despite abundant evi-
lence that its existence was not a matter of high priority
o EPA or to anyone else, it practiced what ex-President
"Jixon had preached some years before when he said, "In
he final analysis the foundation on which environmen-
al progress rests in our society is a responsible and in-
5
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formed citizenry."
The program carried out its unique and always en-
dangered technical and public information activities in
such a way as to encourage broad understanding of the
essence of the technical, institutional and economic facts
involved in solid waste management and to encourage
public participation in the efforts needed to reverse
trends toward environmental degradation and the waste
of resources. This played a significant part, ultimately, in
engaging the attention of environmental and other
public interest groups at a time when most people still
believed that environmental problems could be solved by
damming or damning the major outfalls and stacks of in-
dustries and municipalities. As most people now know, a
clear focus on the final link of the great American pro-
duction, distribution, consumption and throwaway
chain can reveal a lot about the true nature of the en-
vironmental issue.
Between 1973 and the passage of RCRA. the areas of
program activity which received the most support from
conservation, environmental and other public interest
organizations were those which had to do with conserva-
tion and waste reduction. It is significant that these are
the areas which also received primary emphasis within
EPA. The program's work on the reduction of waste
generation through the redesign of products or by
changing the patterns of production and consumption
were, of course, focused mainly on containers and pack-
aging, the largest and fastest growing product category
in the municipal solid waste stream.
O n the basis of data on the Sesirable environmental
and economic effects of container deposit laws. EPA's
Deputy Administrator, in May 1974, testified before
the Congress in favor of a nationwide deposit law that
would be phased In over a substantial period of time to
minimize economic dislocations. This event added im-
petus to the already formidable lobbying and public in-
formation efforts that had been mounted on behalf of
the nonreturnable container by the container, soft-drink
and beer producing segments of industry, and by some
of the unions to which their workers belonged. In those
days EPA's solid waste program staff members used to
provide testimony on their findings and observations on
deposit systems before state and local legislative bodies
who were considering anti-nonreturnable legislation of
one kind or another. This activity provoked very strong
protests from the container, beverage and beer interests
which in the 1974-75 period reached such a crescendo
that EPA's support of state and local legislative efforts in
this area was considerably toned down and restricted.
At the same time, efforts were under way to determine
and describe the dimensions of the hazardous waste
problem but these received limited interest from outside
organizations. The Division of Hazardous Waste initi-
6
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ated a modest program called damage assessment but
there was so little feeling that hazardous waste was really
significant within EPA or outside, that, in bureaucratic
terms, publishing the reports was almost as hazardous as
the subject matter with which they dealt.
By 1975 the need for hazardous waste regulation was
acknowledged by a few public interest groups and by im-
portant segments of industry. Congress began to hold
hearings toward the end of fashioning a new law to
supersede the Waste Recovery Act of 1970.
Without doubt, the need for legislation to regulate
hazardous waste received support from those who dis-
liked EPA's emphasis on source reduction. They favored
legislation whose commitment to resource conservation
would be more titular than substantial and probably sur-
mised that implementing a hazardous waste regulatbry
program could keep a/1 the program's employees fully
occupied and then some. Sidestepping the issue of re-
turnable beverage containers and deferring for further
study the concept of requiring product prices to reflect
the cost of their disposal, RCRA placed major emphasis
on a strenuous new effort to deal nationally with the
problem of hazardous waste. That the effort was needed
and long overdue, no one can now deny.
Despite imperfections in the Act, it is alkey part of the
country's environmental charter. It combines a concern
for public health with a concern for conservation of re-
sources. In this respect, 1976 was a good year. It was also
the year in which the Toxic Substances Control Act was
passsed, which openly acknowledges that cleaning up
environmental residues after they have been produced is
only part of the job that lies before our society. The,
other, and in the long run, the most critical part, is to
prevent or avert the random release of harmful residues .
in the first place.
While 1976 was a good year for environmental legisla-
tion, I hope my brief survey of the rocky road the Fed-
eral waste program had travelled helps you to see why I
believe it was a foregone conclusion that EPA could not
possibly place a hazardous waste regulatory program
into motion within eighteen months. Likewise, State and
local governments, with few exceptions, could not rea-
sonably be expected to meet the Act's requirements in
the time allowed.
Most Federal executive branch programs are very re-
sponsive to active public opinion just as Congress is. For
many years after passage of the Solid Waste Disposal
Act of 1965, the principal outside influence on the
program came from those concerned with eliminating
the open dumping of municipal wastes. The environ-
mental and other public interest groups who have long
supported and abetted air and water pollution control
efforts were not really involved. When they did become
interested, their major area of emphasis was recycling
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and waste reduction and the program responded accord-
ingly. Interest in hazardous waste grew slowly and had
limited support almost up to the moment that RCRA
was enacted.
In contrast, public interest in water pollution has
grown steadily since 1948 and in air pollution since 1955
Current legislation in these areas is the product of an
evolutionary learning process, during which, despite dif-
ferences in opinion as to how, when and where controls
should be applied, the objective has always remained con-
stant. This cannot be said of hazardous waste. Even
though the original Federal law appeared in 1965, our
society did not focus on hazardous waste until RCRA
was passed in 1976 and did not take the issue seriously
perhaps until 1978 when the Love Canal tragedy
surfaced.
Last September, our failure to deal with hazardous
waste was documented in a report submitted by Con-
gressman Eckhardt, Chairman of the Subcommittee on
Oversight and Investigations of the House of Represen-
tatives' Committee on Interstate and Foreign Commerce.
Here are a few direct quotations from the introduction:
"Federal and State efforts to control disposal of
hazardous wastes are totally inadequate. With
adoption of the Resource Conservation and Re-
covery Act (RCRA) in the fall of 1976, Congress
established for the first time a Federal program to
regulate the disposal of hazardous wastes. While
the Congress may have been unrealistic in giving
EPA only 18 months to develop national standards
for the proper disposal of these wastes, there can
be no excuse for EPA's failure to promulgate
regulations in the nearly three years since the
statute was enacted. EPA also has failed to con-
duct a comprehensive search for hazardous waste
sites and to pursue enforcement actions vigorously.
"It must also be said that industry has shown laxicy,
not infrequently to the point of criminal negligence,
in soiling the land and adulterating the waters with
its toxins. And it cannot be denied that Congress
has shown lethargy in legislating controls and
appropriating funds for their enforcement.
"As a result, even an extraordinary effort, com-
menced immediately, cannot achieve adequate
protection for the American public for years to
come. In the interim, it is our duty—that is the
government's duty—to sound a warning. That is
what your Subcommittee is doing here. We also
are recommending how protection for the Ameri-
can public against these chemical and biological
hazards can ultimately be achieved.
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"Although major improvements in EPA's admin-
istration of RCRA will provide greater protection
against the improper disposal of hazardous wastes,
the problem is far larger than that Act anticipated.
Funds must be provided to clean up dangerous
sites and the Federal government must promote
the development of environmentally safe disposal
and treatment facilities, as well as safer and cheaper
methods of incinerating, recycling and reprocess-
ing hazardous wastes."
The report says elsewhere that EPA requested far less
than the authorized ceilings for fiscal years 78 and 79
and then after the Congress appropriated more than they
requested, EPA failed to spend what the Congress had
appropriated. It also states that EPA proposed inade-
quate regulations in that they do not require testing for
four of the eight characteristics of hazardous waste, use a
procedure for testing for toxicity that does not ade-
quately simulate real world conditions, fail to list as
hazardous a number of known carcinogens, wrongly ex-
empt some generators of highly dangerous hazardous
wastes simply because the quantity of wastes disposed is
not large, and do not adequately regulate the use of re-
cycled wastes.
The report went on to explain that deficiencies in
RCRA have left important regulatory gaps. (1) The Act
is prospective and applies to past sites only to the extent
that they are posing an imminent hazard. Even there the
Act is of no help if a financially responsible owner of the
site cannot be located. (2) RCRA does not authorize
EPA and the Department of Justice to subpoena docu-
ments or persons suspected of illegal or inadequate haz-
ardous waste disposal practices. (3) RCRA does not
require people to reveal the existence of, and monitor
possible pollution from, inactive waste disposal sites.
And (4) RCRA provides inadequate funds for state
hazardous waste programs.
We may be sure that EPA, as it revises its draft regula-
tions, will give full attention to the statements made
about EPA in the Subcommittee report.
The Report makes it clear that there is enough blame
to go around—industry, state and Federal agencies, and
the U.S. Congress are specifically cited. All of these in-
stitutions are supposed to serve the public, so it is cer-
tainly proper to blame them. At the same time, it is im-
portant to bear in mind that we have an open society and
all the institutions cited in the Eckhardt report are in-
fluenced by active public opinion.
The opportunity to deal intelligently with hazardous
waste has been available for many years. The reasons we
have been so reluctant to grasp it cannot be boiled down
into a simplistic indictment of bad guys in industry or
government. Bad guys win only when the public is on
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their side and that happens when citizens, as voters or as
members of public interest groups, are not sufficiently
well informed and vigilant. I know this places a heavy
burden on voluntary organizations such as those you
represent but, without you, we apparently cannot man-
age to enact legislation or to implement it in a timely
fashion.
The arduous, long-term task of dealing with hazard-
ous waste is just beginning. Potentially, there are many
things that can be done with hazardous wastes besides
burying them into a landfill that will meet RCRA's re-
quirements. Certain waste can be recycled and sent back
for reuse. Other wastes can be used by others without
processing. Wastes can be dealt with by incineration,
chemical neutralization, separating or blending to yield a
useable product or supplemental fuel for firing industrial
furnaces, and "biological destruction", in which micro-
organisms consume the hazardous material and render it
harmless.
Ideally, disposal should be the procedure of last
resort. Since RCRA's regulations will make this proce-
dure much much more expensive than it's ever been be-
fore, eventually the widespread use of other methods
should be achieved. For a good while, however, there is
no question that the procedure of last resort will be the
procedure of first and greatest use. Moreover, proper
disposal will be needed even years from now when we
will have drastically altered our perceptions and prac-
tices with regard to wastes. There will still be a great
many materials that are too low in value to recycle, too
difficult to degrade or to inject into deep wells and too
contaminated with nonflammable materials to
incinerate.
Proper burial under RCRA will be a far cry from
dumping. Serious attention to properly engineered land-
fills with liners, covers, gas generation techniques and
monitoring operations will come into being. The chemical
solidification of wastes, now used for only a very small
percentage of hazardous materials will no doubt become
more popular. And disposal of the wastes will not end
the scrutiny process. Disposal site operators will have to
monitor and maintain closed sites for many years to
make sure that there is no migration into soil or drinking
water supplies. There will be liability for each incident of
damage that occurs while the site is operating. And
money will have to be set aside to close and maintain in-
active sites. Violators will be subjected to serious civil
and criminal penalties. RCRA calls for truly drastic
changes in the way we deal with wastes.
Yet the entire promise and purpose of the Act could be
aborted by the strong and widespread public view that
treatment and disposal facilities are all right, provided
they are located on another planet or at least on another
continent. Considering the current low level of public
in
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confidence in Congress, industry and the State and Fed-
eral executive branches of government, you voluntary
citizens represent perhaps the only key that will open the
lock.
I believe that citizen-based organizations with no par-
ticular economic or political axes to grind contain the
people who must best understand where we have been,
where we are, and where we are going. You are the only
ones, perhaps, who are truly free to help all of us make
rational sense out of the cross currents of chaotic events
in the stream of history which, at times, seem to be intent
on sweeping our lives and institutions hither and yon
aimlessly. You are the ones who can help the public take
reliable bearings with a compass more solid and reliable
than an accountant's profit and loss ledger or the
periodic soundings of a political pollster.
Those .of us who1 work in institutions, even when we
make our best efforts to accommodate ourselves to the
public's demands, find our tasks made much more diffi-
cult by widespread distrust and cynicism. Environmental
agency staffs at all levels of government enjoy a much
lower level of the resources they need than is widely
understood—particularly in the environmental area
where there are so many long neglected and hard prob-
lems in search of quick and easy answers. Resources
needed to do the job almost always trail several months
or years behind newly minted authorities, and responsi-
bilities.
The solid waste management problem is even more il-
lustrative of the need for sustained and successful public
understanding, involvement and criticism than are other
environmental issues which received national attention
earlier. For decades now, the public has demanded air
and water pollution control efforts and the public has
paid directly or indirectly for the controls placed on
automobiles, industries and municipalities. Even though
few members of the public have been personally in-
volved, almost all segments of the public have been rep-
resented by public interest groups of all varieties, which
in this decade have influenced the development of legis-
lation and its implementation. But air and water pollu-
tion problems have npt.pr.esented^ay^hing quite com-
parable to the dilemma faced b^yjgQverriment officials
charged with hazard,ous.wastecontrdl tes'p'onsi'bilities.
These public serVahts'rnUs't somfefibw meet the public ex-.
. pectations for protection agaiteS'ior^'nfegle^te&additn^
sidious problem at the same time that the public seems to
feel that treatment and disposal cannot be permitted.
Without a high degree of public understanding and par-
ticipation at the grassroots level which will not transpire
without your continued and intensified involvement and
understanding, ha/ardoig-^aste, control will not emerge'yj
from promise to reality
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EPA is charged by Congress to protect the Nation's land, air and water
systems. Under a mandate of national environmental laws focused on air
and water quality, solid waste management and the control of toxic
substances, pesticides, noise and radiation, the Agency strives to formula)
and implement actions which lead to a compatible balance between huma
activities and the ability of natural systems to support and nurture life.
If you have suggestions, questions
or requests for further information, they
may be directed to your nearest
EPA Regional public information office.
EPA Region 1 • JFK
Federal Bldg. • Boston
MA 02203 « Connec-
ticut, Maine. Massachu-
setts, New Hampshire,
Rhode Island, Vermont •
617-223-7223
EPA Region 2« 26
Federal Plaza • New
York NY 10007. New
Jersey, New York, Puer-
to Rico, Virgin Islands •
212-264-2515
EPA Region 3 « 6th
and Walnut Streets •
Philadelphia PA 19106
• Delaware, Maryland,
Pennsylvania, Virginia,
West Virginia, District of
Columbia •
215-597-4081 *
EPA Region 4 • 345
Courtland Street NE •
Atlanta GA 30308 •
Alabama. Georgia,
Florida, Mississippi,
North Carolina, South
Carolina, Tennessee,
Kentucky •
404-881-3004
EPA Region 5. 230 S.
Dearborn • Chicago IL
60604 « Illinois, Indiana,
Ohio, Michigan, Wiscon-
sin, Minnesota •
312-353-2072
EPA Region 6 « 1201
Elm Street* Dallas TX
75270 • Arkansas. Loui-
siana. Oklahoma, Texas,
New Mexico •
214-767-2630
EPA Region 7« 324
East 11th Street.
Kansas City MO
64106 « Iowa, Kansas,
Missouri, Nebraska •
816-374-6201
EPA Region 8« 1860
Lincoln Street «
Denver CO 80295. Cc
orado, Utah, Wyoming,
Montana. North Dakota,
South Dakota •
303-837-3878
EPA Region 9. 215
Fremont Street« San
Francisco CA 94105 •
Arizona. California, Haw
Nevada, Pacific Islands
• 415-556-1840
EPA Region 10. 1200
Sixth Avenue * Seattle
WA98101 .Alaska,
Idaho, Oregon, Washinc
ton .206-442-1203
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