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Response:

     Our  knowledge  obviously  is  improving  substantially  in control  technology.    In
the past, there was not  very much  emission  data from various sources.   I  think  we
are starting to understand where the dioxins and  furans are  coming from  and  how  to
control  them.  There are  certain unresolved questions in our minds such  as:   how  to
best control substances  like  mercury?    What  is  really  the  collection  mechanism  for
dioxins  and furans?   If  you are  trying  to collect something  in  the downstream  air
pollution device, is it a condensation phenomenon or' is it  an absorption phenomenon?

     These are questions that have  some bearing and  impact on how  you design your
pollution  control   technology.    In   Europe,  they  have  largely  been  more  concerned
about mercury than we  are.   They have  gone  to  the wet scrubber system  which  we
are not really  using in this  country.   The idea  there  is to drop the temperature down
in  the  air  pollution  device  to the  extent  where  you  can  condense most  of  the
mercury.   There  is also one  thing  that  we  have not  really looked  at,  which is,  what
do  you  do  about  the  residues as  far  as  the  organics are  concerned.   We  do  not
appear  to  be  concerned  about the  residues, but there  is a  great deal of concern  in
Europe   over'  the  dioxins   and  the  furans  and  other   organics  in  the  residues
themselves.   They are  actually developing  processes  for  postcombustion  treatment  of
the residues to get the  organics out.    As  far  as  we  can see, there  does not appear
to be any environmental hazard.

Question:

     Is there any plan to study emissions of oxides of nitrogen 'and their control?

Response:

     I  think  the  Agency  is  looking  at  oxides of nitrogen  control technologies, but  as
far as the  amount of waste  that comes  from emission  waste sources,  from  a national
perspective, it  does not  appear  to  be a  major  contributor  to the  dioxide  of nitrogen.
We 'are  looking  at existing  technology for  controlling oxides  from  nitrogen:   selected
noncatalytic, selective and nonselective combustion, and furnace modifications.

     In  incineration  systems  it is   largely  fuel  nitrogen,  and  one  does  not normally
operate  at high enough  temperatures to  have  really elevated  levels  of NOX.   So  it  is
more  or less  a problem  of dealing with  a  fuel nitrogen  rather than  with a  nitrogen
fixation.

     Last  July OAQPS  issued a  guidance document.   It is  minimum  guidance and is
basically directed  to  people  involved in  writing  permits.    It  is presumptive  to  tell
permitters that  good combustion is an important component  of their permit.

Question:

     Is the current level of funding for R&D monitoring methodologies adequate?
                                             40

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Response:

     This  year there is  $100,000  in  the area of developing  monitoring methodologies.
The  other hazardous  waste programs  do  support  some  monitoring work.   We do feel
that it is underfunded.

Question:

     Will emissions control technologies differ for new and old incinerators?

Response:

     A  mere compliance  test,  just inlet and  outlet of  an air pollution control device,
doing acid gases, metals,  and organics,  is probably  going to cost  $300,000 to $400,000.
R&D costs approximately  a million dollars  or more.    One  of the  biggest  problems,
from  a  regulatory and  a  technical point of  view,  is  what do you  do about  the  old
incinerators?    We  know  we could  go  out there and  put  very  costly  FGC devices on
them,   but   is  there  an  intermediate   ground?    We  have   some  ideas  about  the
combustion  process.    A  less  expensive FGC  technology is  the  spray-dryer  fabric
filter,  but we  do  not  have  much  data which would  show  the performance of  the
devices.
                                             41

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2.3  Municipal Waste Combustion Ash Stabilization Program
     Carlton Wiles, U.S. EPA--OEETD, Risk Reduction Environmental Laboratory,
     Cincinnati, Ohio


     The other side of the combustion  issue  has to do  with  the  quality  of the ash,
what we  do  with  it  and its  contents,  and  its   controversial  aspects.    Our  work
includes  some  work  in  conjunction with the  Municipal Waste  Combustion Program,  as
well as  other  work.   The program is  not that  large.   In  the  1987  budget  we  took
some money,  around  $150,000,  from other  sources and  initiated activities  to  assist
OSW in  preparing  the  Report  to Congress.  In 1988 we had about $200,000 that went
to the program.   In 1989 approximately $325,000 went to the  base Residuals  Program.

     Another  program   is  the  Ash  Solidification/Stabilization  Program,   funded  at
approximately $500,000.   In the 1960s and 1970s, we were  doing a lot  of work  with
resource  recovery and  waste-to-energy projects.   We did  not  do  very much  with the
residues  at  that  time.    Most  of  the  studies  that  were  done  during  that  period
attempted  to  provide  the engineers  with   design and  operating   information  for
designing  their  facilities,  such   as  sagging   characteristics   and  other   information.
There  was  some  work  done  in   the  late   1970s   that  looked  at  the  potential  for
recovering  certain  components  from  the  ash  or residues,  and the Bureau  of Mines
process for recovering metals.

     The issue  became  controversial again  in  the past couple  of  years.   Whether  it is
a perceived  problem by the public or a technical problem is moot at  this  time.   It is
a problem.

     I will highlight some  studies  that the OSW did at the same time.   In  support  of
the  OSW's  responsibility  for  producing  a  Report to  Congress,  we  did  the  ash
characterization  study  that was  in  the  report  and  looked  at the physical  and the
chemical  characteristics of  the  ash  from  four different  facilities.     A  preliminary
study was  done  on  solidification  for treating  the  residues in  support  of OSW.   Some
of this information went into the guidance document produced by the OSW.

     The  preliminary  guidance  on  transportation,  handling,  and  management of  the
ash  was  in  the  document  that  OSW  developed.   It  dealt  with land disposal  and
monofills.    (This  document  has   been  distributed   to  several  states.)    Legislation  is
pending  in Congress that  would essentially tell  us  what  we  should or  should not  do
in that area.

     In  conjunction  with  this, OSW did some  studies to look  at  the  potential sources
of  cadmium and lead  in the municipal  waste  stream  (or  in  consumer  products  that
might end up  in the municipal waste  stream) that  could  potentially be  combusted and
affect  the  characteristics  of the ash.   The  report  from  the  project  may  be  available
in November.

     There  was  also a study  initiated  by  OSW  that  is  a cooperative  effort  between
the  Coalition on Resource  Recovery and  the  Environment (CORRE) and EPA to  look
at  the  characteristics of  ashes from six  or  seven  different combustors.    It  has  not
started  yet,  but  we  hope that it  will  before the end  of the  year.   That study will
include  some sampling  and  analysis of the  leachate  from several disposal  facilities  at
the sites.

                                             42

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      Last year we provided  support for the  continuation  and improvement of an ash
data  base at the University  of Massachusetts which primarily deals with  the residuals
from resource recovery  facilities.     The project  is on-line  now, and   hopefully  EPA
will continue support for the coming year.

      We  provided  some  money  in  conjunction  with  another  organization  from our
Cincinnati  laboratory  to develop  a  resource  document  on. the  different  options for
managing  or treating  the ash.   The main emphasis of  this  document is  to  provide
information   on   the    different  alternatives,  such   as   vitrification,   solidification/
stabilization,  monofills,  etc.,  and  to  give  information  as  to  where the potential  user
of that document could get more details.

      With regard to the field combustion tests,  we can do sampling of  the ash,   take
the  residues from  different  points  in  the  plant,  and  do  a  complete  chemical  and
physical  characterization  of  those  residues.       We   are  doing   this   project  in
conjunction with Environment  Canada.

      We  had  two  projects scheduled for  last year  that  were not  started  because  of
budget  reallocations at  the  end  of the  year.    The  first  one was  to  look at the
potential  migration  of  contaminants or  the potential attenuation  of those  materials  in
clay liners.  The University of  New Hampshire is doing some work in this area.

      One  thing  that  we  were  concerned  about  is  data  that  have come  across our
office show  that  the  chloride  complexes  of some of  the  metals will  move rather
rapidly  through  some  clay  liners.   We  are concerned about that since clay  liners are
an intricate component of most of the monofill designs.

      We  also  wanted  to  provide some support  to  look  at the reuse of  ash in the
ocean  environment  and  to look  at the  organic  components of  that material.   There
has  been  a lot  of  work done on  the  metals,  but little work  done  on  the  organic
components, and we wanted  to  provide  some  support for doing  that.   Whether or not
we  do this depends on the input that I would  like from my  workgroup.

      Activities   planned  for   1989   include   continuing   the  activities  of  the   base
Combustion  Program.    We  will  do  some  additional  work  in the  control  technology
area for  the residues.   I mentioned that  we  have  another program that was initiated
this past  year  and  that  is  going  to  go  into   full  swing  next  month.    We  are
attempting   to  evaluate  solidification/stabilization  technologies  for treating  the   ash
with an emphasis on the long-term utilization of that material.

     Solidification/stabilization  technology   has  been  studied  for  treating   the  ashes.
From a  technical point  of view,  we know that it can be done.   One big  issue that
remains  is  the  long-term effectiveness of   that  technology  if  we  are  looking  at
utilization of the  residues.

     Whether  it is a  public  perception  problem  or a  technical  problem,  the  Agency
has  a  test  based   on  toxicity   that  classifies  the ash  or  materials  as  hazardous  or
nonhazardous.   The ash will  fail  that  test.   In  some  cases,  tests  with fly ash  may*
have  a  50  percent  failure  rate.    The public  is saying  that  if a test  classifies an ash
as  hazardous or nonhazardous,   and  the  material  fails the  test,  then  it  is  hazardous.
We   believe  that  it would behoove  us  to evaluate  the  technology  for  treating the
ashes,  so  we  can  obtain some  credible  results.   The  emphasis  is  for  the  long-term,
safe utilization of that material.
                                              43

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     The first  phase of this program will rely upon the developers or  the  vendors of
that technology  to  do  the  solidification/stabilization at their,  own  expense.   This  is
very  similar  to the  SITE  Program.   EPA then  will pay  for the  cost of  evaluating
each  of  these  processes  or  treatment   techniques.    I  have  established  an  advisory
panel that will look  at  this plan.   This is the basic outline  for  purposes  of planning.
We hope to have  a  meeting in  a  couple  of  weeks,  at  which  time  the advisory  panel
will start making  recommendations  that  will  make this  a very  credible  and worthwhile
effort.

     The  basic design  is  to  emphasize  the  treatment   processes,  rather   than  the
different characteristics  of  the  ash.    If  we had  tried to  get  all  of the  different
characteristics  of  the  ash or  residues  from   many  different  facilities,  the cost  would
be  way more  than we could  bear.   We are, therefore,   trying  to  emphasize  in  the
design  the  evaluation of  the  different  processes.   Initially,  I  estimated approximately
18  months  to complete  the  program from start  to final report phase,  at an  estimated
cost of  around $650,000.    Field  demonstrations  were  not  considered,  but I  estimated
somewhere  between $200,000  and  $400,000 if we  decide   to do  demonstrations  at an
actual facility with  a full-scale process.

     I  believe  that  the  big  question we are  going  to have  to  satisfy for  the public is
what  are the long-term environmental effects of  the products.   We  are going to  need
to  assure those  people that this  material can  be used  safely.   Another issue is  what
is the potential liability situation.

     To  give you  an example  of the  potential  problem—and  I  want to  emphasize
"potential"—the  Netherlands  has  used   ash from  both  coal-firing  and  from  refuse-
firing  as roadbed   construction material   for  a number  of  years.   The Netherlands  is
also in the  process  of developing  criteria  for the amount  of pollutants that  they will
allow in  the soil.    Some  people are concerned that  hazardous  levels  of pollutants  are
coming  out  of  the material,  such  that they  may have  to  go  back  into an existing
roadbed that has used this material and remove or treat it.

Discussion

Question:

     /  am  assuming  that  you meant mixed  bottom ash and  residue  when   you  were
using the word "ash?"

Response:

     Combined.    The  real  term  is "residue."   We  are  looking  at both  the fly ash or
the fly residue and the combined ash. They are  being looked at separately.

Question:

     Assuming  a  worst case  that   the  ash  is  initially  considered  hazardous  prior  to
treatment, how does this impact your listing decisions or any of  your work?
                                              44

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Response:

     I  know  that  there  have  been  several  delistings  in  the  hazardous  waste  area
using  solidification/stabilization.     If  this  material  is  ever   declared  hazardous   and
requires   treatment,  and  if   you  can   delist  some   of  the  hazardous  waste   with
solidification, then you might have a  good  chance of  doing the same thing  with  this.
As   you   probably   know,   there  are   some   advantages   and  disadvantages   with
solidification, such as volume increases.

Question:

     Do  you think  that  delisting  would  be  associated  with  the plant, • and  therefore
be waste specific or site dependent?

Response:

     Delisting  is  always  dependent.   It  has  been that  way  in the  hazardous waste
area.   I do  not know if it  will  be any  different.   It  depends on how the  regulations
are put together.

Question:

     Is leaching from the plant the main concern?

Response:

     Cadmium and lead appear to  be  the main concern.  However,  there are technical
people who are concerned about soluble salts from the ash.

Question:

     //  you are using a roadbed, how do you know that the  lead did not come from
the automobile itself?

Response:

     You  can  characterize the ash before it ever goes  into a  roadbed, and  you know
that lead and cadmium are going to  be  there.   The material may leach,  but with the
rapid increased  use of  nonleaded  gasoline, I do  not  know how  much  of  a problem it
might be in the future.

Comment:

     This  is  one  of  the  difficult   technical  aspects   in  evaluating  these  ashes  in
roadbeds  from  an  environmental  perspective.   So the  environmental  margin  scheme is
going to have  to  be the  ashes.   This  reuse  scenario is going  to  be  a problem,  but we
are going to look at it.
                                             45

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Comment:

     I  failed to  mention  one thing in  some  planned  1989 activities.   We are hoping
to provide  some  support  next  year to  some  demonstrations  that  would  look  at  those
kinds  of issues.   Of  course,  we  are  helping to  provide some monetary support, but
we are  going  to  follow those demonstrations  and hopefully  get  some  of that type  of
information.

Question:

     Are  you  saying  that   in  Phase  I  you  are  going  to  evaluate  all  of  these
conclusions  of  the  18-month  objective?   On  what basis  are  you going to evaluate  the
performance standards for reuse of ash?

Response:

     That is  an  excellent  question.    I  have  been asking for  a  number of  years  that
the  Agency  move  toward   some  kind  of  performance  criteria   for   solidification/
stabilization  of hazardous  waste.   The  Nuclear  Regulatory  Commission  has  this  type
of  criteria.    This  is  a  topic  that  I  am   going  to  raise  for  the  advisory  panel.
However,  the  first  emphasis is  on  evaluating  the  technologies.    We   will  establish
criteria  to  make  that  evaluation  and  to  select those  technologies  that  will  be initially
involved  in the  program,  given limited resources.   Determining  long-term  criteria  is
an  area of research.    We have the same  problem  in  the hazardous waste  area.   The
lack of good  techniques  to  characterize  the  chemical  and  physical  performance  of
those materials over a long term is an area that needs more work.

Comment:

     I  would  hope that  we are  going  to  try  to look  at  reasonable   environmental
criteria .as well.

Response:

     From  a technical  point  of  view,  we  will do the  best job we  can, develop a good
set of criteria that  makes  sense, and  give  it  to  the  people who  make  the  policy
decisions.   We  need  to get  that information  together in  a  packet and then present it
in  a  way  that  the  public  will  have  confidence that, "We  have  answers, to  the
problems" or "We have solutions to the problems."
                                              46

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                         3. DESCRIPTION OF MITE PROGRAM
                    Fred Lindsey, Acting Director, U.S. EPA—OEETD


      I  want   to   discuss  the  Municipal  Innovative  Technology  Evaluation  (MITE)
 Program.    This  is not  an  existing  program,  it  is  a  concept.    I  am  interested in
 presenting  the  layout  to you and  getting feedback  from you  as  to whether this  kind
 of a program might be useful.

      The  purpose   of the   MITE  Program is to  spur development  in  the  use  of
 innovative  technology in  managing municipal  waste.   I am not  going  to  present  an
 exhaustive  list  of  what I consider  to  be municipal waste for this program,  but I am
 going to  give  you some  ideas.   It includes  household,  yard,  and commercial  wastes,
 but not  industrial  process  wastes.   I  think it  should also  include. hospital waste  and
 sewage  sludge.   In other words, wastes  or waste materials  that  are typically  handled
 by the municipal sector.

      What is  the  problem that we are  trying to solve?   Is there a problem  that we
 are trying  to  solve?  That   is an  open  question.   We obviously  think  that there  is  a
 problem or we would not have suggested this as a possibility.

      I would  like  to  describe  a scenario which you can comment  on.   It is my  view
 and the  view of others  that, with  the exception  of combustion,  there  has not  been  a
 lot  of innovation  in  the MSW  technology  area,  and that  most  recent  innovation in
 the area has come from Europe.  Is that statement true, and  if so, why?

      Another  possible scenario  is  that  the decision-makers in  this area are   largely
'local  government  people,  city  managers, and  architecture and engineering  firms  that
 work  with  the  local  governments'  utility  authority,  decision-makers,  and  so  forth.
 Generally speaking,  my  view  is  that  there  has  been  a tendency in  that  group  of
 people not  to  be  thrilled about trying new things.   Some  of  you who  represent  that
 part of our economy may take issue with this statement.

      First  of all,  when we  start  to  talk  about  the  need  to  do  something different
 with  regard to  MSW,   there  are  a  couple  reasons  why  you   might  not want  to
 experiment  with new  and  innovative  technologies.    One reason  is  that  it is a  big
 ticket item, and the  rate payers  and/or  taxpayers,  or whoever is  footing  the  bill for
 all of this, are going to be very interested in what gets done.

      Second, the decision-makers in  this area tend  not  to  make  these decisions  very
 often, unless the landfill fills  up and no other  alternatives  are available.

      Third, there  is  a  lack of  expertise  in  the associated technologies.   Thus,  the
 decision-makers  at  the  local level are  reluctant to   try  new,  unproven technologies.
 Therefore,  I think that  in   this scenario the  private  sector  does  not  respond  with  a
 lot  of R&D for development of innovative  technologies,  because  there  is an uncertain
 market  for those  technologies.    People are  reluctant   to  try  anything  that   is  not
 "tried and true," or that has been used in other places.

      The MITE Program  is designed to  try  to overcome what we  perceive  as  a
 barrier,   given  the   previous  scenario   and  our  perception that there  has  not  been  a
 great  deal  of  innovation  recently,  except  for  what  has  been imported  or  has been

                                              47

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forthcoming  in the  combustion area.   I am interested  in hearing whether you think
there is a barrier,  and the  way  in  which  the  MITE  Program  can provide  a  pathway
to   demonstrate  these   technologies   and   innovative    approaches   where  credible
information   can   be  developed  for   local  decision-makers.     These   innovative
technologies  could  then  facilitate the  potential  inclusion of  newer  technologies  into
their decision-making process.

   .  What will we  be  doing in that regard?  We are talking  about demonstrations,  or
maybe  a  better  term  is  an  "evaluation."    It  would not  be  unlike  the  Superfund
Innovative  Technology  Evaluation  (SITE)  Program,   which  is  a  program  we have
ongoing in the  Superfund area  for  demonstrating innovative technologies  and  cleanup
technologies.   We  would  be looking at  demonstrating  new equipment or  improvements
to  equipment or  processes.    It  might  be  a  new  sorting  device,  for  example,  or
perhaps  something  novel  in fire  box design for resource recovery incinerators.   We
might  be looking at  new  techniques and approaches to  source  separation,  methods  for
minimizing  waste,  risk assessment methodologies, or  demonstrating both  process  and
hardware.   We might also  look at  new, innovative  types of facilities  that  have been
built,  evaluating  the  cost  effectiveness of  the  whole  plant, and then  publicizing the
results.

     In  terms of  the demonstration, we are talking  about  some cost-sharing  between
the  Federal  government,  which   would  be  conducting  this  demonstration,  and  the
developer  and/or owner,   depending  on  the kind  of  technology   or  process  we are
talking about.   EPA's  responsibilities would include  that part of the demonstration
which  would  generate most  of  the numbers:  development of  the  trial  plan, sampling,
analysis,  Quality   Assurance/Quality   Control  (QA/QC)   work,  and  reporting  and
extrapolating results.

     The developer  and/or  owner of  the  facility would  be responsible  for operating
the equipment.   I think we  could do  this at any scale.   It would  not necessarily have
to be  done  on a commercial scale;  we  could do pilot-scale evaluations or  evaluations
even earlier in the developmental  program.

Program Structure

     The program  structure  would be  based on  something  which  we  have had some
experience with.  We  have  had both  positive and negative  experiences with the SITE
Program,  which  we  have  learned  from.   First,  we would  set up a steering  group  that
would  include  people  representing the several  program  offices  that  have  an  interest
in the  outcome of  this work,  as  well as people  from  our Regional Offices and some
state people as well.
                                   »
     I  see  the need for  an outside  workgroup,  perhaps not  unlike this group,  that
would   meet  probably  once  a  year.     It  would  include  city  managers,  engineers,
equipment manufacturers,  and others  who either  produce  equipment and/or  technology
in this field  and/or' who  use it.   The purpose  of this workgroup  would  be to  review
what  was  done  in  the past year in  terms  of demonstrations  or  evaluations,  provide
feedback, and provide  advice on  the  future, particularly  what the priority  needs are
regarding  specific  demonstrations  that  the  group  would like to see  the  program
undertake.
                                             48

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     Presumably, we would advertise this  program annually  to  ensure an  opportunity
for everyone  interested in participating to get  into  the  program.   We  would  also  have
what  we call in  the SITE  Program a  fast-track  option that  would  actively  try to
identify  innovative  technologies  and/or  facilities  for  demonstration  by  other  means.
One of  the  means  would  be  the  workgroup  meetings  where  interested  individuals
could develop a preproposal for review, and then a full proposal.

     The mechanism for doing  the  work would  be the  same kind of mechanism we
use in the  SITE  Program: a cooperative  agreement which in  some  cases would include
site owners and  in other cases involve developers, and  anyone who might  be involved
or have a direct interest and responsibility in conducting the program.

Criteria

     At  the moment, we do not  have any  money in this program.  The SITE Program
started the  same  way and has grown into a  substantial  program.   If this  new program
has usefulness, over  time  it  might  also grow  into  a  substantial  program.    We are
going  to  need to  develop criteria  for  deciding  what to  accept  and how  to rank the
kind of  work that  we need to do.   We  have  what we  think may  be  six  criteria that
we want  to use to rank the activities that we would undertake.

     1.  Stage  of  development.    Field  demonstrations  of full-scale  or  nearly  full-
         scale  equipment and/or  approaches  under  real-world   conditions  make  the
         most  sense  because  the  technology  in  that  circumstance  is  closest to  being
         field  usable  and  available  in the  arsenal of  alternatives that we  have for
         dealing  with municipal  solid waste.    I  would  give  a  high priority to  larger
         scale activities.

     2.  Potential benefit.   In  this case  we  will  recognize  the  Agency's  priorities for
         waste management.   The Agency's  published priorities  for  waste   management
         include   as   the  highest  priority  what  we  call   "waste minimization"  or
         "pollution   prevention"  (product  substitution,  source  separation,   etc).     We
         should try to  give  high  priority to  technologies  and  techniques  that fall in
         this   category,   and   less   priority   to   others,   however,   not   excluding
         technologies and techniques in other areas.

     3.  Potential for  commercialization.   We  want  to   look  at  the track  record  and
         the  financial structure  of the developer  or the  offeror  of  the technology.  It
         may  be  that many  organizations  (for example,  a university) are not the  ideal
         because  they  are  not typically  in the commercialization field.  The point is
         to have something commercial  that can be used.

     4.  Market  potential.    Are  we  talking  about  a potentially   big   market  for
         whatever this is?   I think the priority needs from the workgroup  would  be  a
         strong  consideration.    We  want  to  look  at   the   potential  cost/benefit;  in
         other  words,  whatever  are  the  costs of the  alternative  we   are  looking  at
         compared to other management options we  may currently have.

     5.  Site availability  and requirements.   We found from  the SITE  Program  that it
         is sometimes difficult to find a  site  that  fits the technology.   We  have  some
         projects   in  the  SITE  Program  from  the  first  round   of  demonstrations  for
         which we still have  not found  a suitable site.   Therefore, the availability of
         the site is another item that we will consider.
                                             49

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     6. Costs.   We  do  not  have  any  resources  for  this  program  as  it is only a
        proposal.   The  cost  of  doing  this,  based  on  our  experience  in  the  SITE
        Program,  in   full-scale  demonstrations  of  technology  can  be substantial,  on
        the  order  of half a  million  dollars.   The  cost to  the  developer and/or  the
        owner  of  the facility can  also be rather substantial.   If we are  talking  about
        evaluations at  an  earlier  phase,  pilot  scale  or smaller,  then  the  costs  could
        be considerably less.

Discussion

Question:

     One  of the aspects of  the waste field  is, of  course,  that  there  is no   innovative
program.    "If  it  goes  bust,  they  will  replace  it with something  that  works."   How
does that apply to the proposed MITE program?

Response:

     The  INA  Program is somewhat  different  and  would require  different authorities
than we  have now.   Money  is  one thing; authority  is  another.   In the INA  Program,
if a  town  or wastewater  authority  decides  to  use an  innovative technology,   the  risk
is underwritten.   If it does not meet specifications,  EPA  will  potentially come in and
pay for either upgrading the technology or building something different.

     An   interesting  question  is:    Would   such   a  process  be  necessary   for  this
program?    It would  probably be  necessary if local  governments are  going to actually
buy  the  technology.    We  are  currently  talking  about  a demonstration  program,  not
underwriting the actual use of a new technology by a city.

Question:

     How do you define technology?

Response:

     I  would  like  to hear some  thoughts from you  on  that  question.  Technology is
clearly  innovative  types of hardware,  such  as  new   treatment  devices.   I  think  it is
more than  that, though.   We could  be talking about protocols, methodologies, or risk
assessments—anything  of a technical  nature  that would  help  the decision-maker  at
the local level to evaluate his alternatives and/or provide an alternative.

Question:

     One  concern  I have  is  that  we do  not  repeat some of the  mistakes   made  in  the
past.    In particular.  I  am worried that  technology  would  be  defined narrowly  within
the  traditional   way  we  looked  at  hardware,  and   we  will  not  pay  much   attention
within  OEETD   to  economic  and  institutional arrangements  that are  closely related  to
the technology choice.
                                              50

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     Let  me give  an example.   One connection  that was never  looked at  when  we
were  in  this  business  during  the  last  decade   was  the  relationship  between  user
charges for  solid  waste  collection and disposal, and  the  choice  of technology.   A  lot
of  work  was done on taxes,  on  the  Resource Recovery  Act,  and  so on, but  a user-
charge  question  was never  looked at,  including  the  effect it  has  on  waste generation,
the  incentive it  has  for  source  separation,  and  the  impact  on  the  demand  for
separation.
     The  question  is:
feasible to think?

Response:
Does  that fit  what you have  been  thinking,  or  is  it  even
     I  do not know  whether  we have developed  it far enough to decide.   I  see cost
information as definitely being a part of it.

Comment:

     I  hope that  before  you  develop  this program much further,  you  think  of  how
the  original   208-demonstration  program  affected   implementation  of   solid   waste
management techniques  10  years  after  the  program  started  and  why  today  we  are
living  with the results  of the 208  program.   Remember,  with one  exception,  our 208
grants  all failed.   Then we  went to  Europe  to  see  what  they were doing.   Given  the
political situation  today, the decision-makers. are looking for  any  way to  avoid  facing
the issue.   A  nice EPA  demonstration  program  gives  them just what they  need  to
avoid facing the  issue.   They are  waiting  to  see  what  you  come up with.  Based on
what  we  came  up  with in  the  past,  it is  a big  mistake  to wait for  EPA to develop
something.

Response:

     Let  me  just say that I  do not  see this as  a  208 program.   It is an  interesting
question as  to whether  the  same   thing  would  result  or  whether  the problem  you
point out  would  ensue.    We  basically provided money  for  the 208 program  to  build
full-scale demonstration  facilities.    In this case,  we  are  not  going  to  be providing
money to build full-scale equipment.

Comment:

     How do  you  define cost  effectiveness?    Your  whole  program  is  based  on one
assumption: that  people are  not  eager  to spend money  on  innovative technologies and
the only  reason they  do  it is because there is a  legislative mandate  to  do  it.   In the
hazardous  waste  area, nobody cared  until  PRGRA, RCRA,  and  other  programs  were
instituted.  Once  those laws  were  put  into effect and  people were  faced  with  heavy
penalties, they started looking at innovation.

Response:

     I  submit  that this  is  a different situation  here,  that basically  in the  MSW  area,
cities and localities are  being forced to do  something  because their landfill  space  is
running out, if for no  other reason.
                                             51

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Comment:

     But there  is  export    export  to other  states,  export  to other  countries.   One
would  be  surprised to  know the amount  of  private  investment  that is  going on  in
facilities for  combustion.   There has  been over  $200  million  of  private  capital blown
in  pyrolysis,  and I  bet there will  be  another $50  million  spent  next  year,  of which
about  $2 million is public  money.   All  the  rest was private money.  If  you want  to
see an investment dollar get blown, watch mixed plastics.    Another one is  a field  of
processing  systems  that says "I  promise I  can  do  all  your  garbage."    I  think  that
there  are   many   technologies   like   that  which  need   evaluation,  but  maybe  not
demonstration. Do  they work?    Do  they fit  what  communities  need?   What  are  the
products they make?

Response:

     What  you  are  saying  is   that  this  is  a  question  of  what  is  a  demonstration
versus  an evaluation.   Are  you  saying  that we do  not really need to go out and  look
at the facility,  plant, or equipment,  or try it out?   Rather,  we can tell most of what
we need to know through paper study?

Comment:

     Yes.   I think  that if anybody  is concerned about where used-car  salespeople  are
in  high unemployment,  they  are  in  this  technology.   I  think  it  is  time  to  aid
municipalities and others by evaluating.   I think  your  procurement  process  might  be
able to get access to  the  technology and to evaluate it scientifically.

     The problem  is  political  decision-making.   The  technology  exists  because many
people  are  willing  to  invest  in it.   If somebody  wants  to  lose  money  on  it,  that  is
their problem.   If EPA wants to start  a  MITE  Program,  there must be  a  good reason.
Now,  if you  notice  what is happening  in some  places, the cost of disposal of MSW is
probably in  the  range  of  $6  million  for  the  entire  nation.   That  translates  to less
than $2 per  person  per month  as  a  disposal cost.    You  expect  an awful lot  from
people who  are  paying  so'little.  This $2 a  month  is less  than  a  videocassette  costs.
That is  the  level of expenditure of people  facing  MSW  disposal.    It is so  cheap that
they do not  give a damn.

     I think  the  local  officials  need a lot  of help.   They  are grappling  with decisions
for  which  they  are  totally  unprepared.    They  are  listening  to  the  blandishment  of
snake-oil salesmen.  So, whatever information you can provide has  got to help.

Question:

     Don't the people who push this equipment provide  data?

Response:

     No, or  at  least not credible data, and  the local  official is  not in a position  to
provide this or realize that the data are inapplicable.
                                             52

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Comment:

      One suggestion I  would  make  is  to  define  municipal waste  from  a  municipal
perspective.   I  just  made  a list  of the new  types of waste  a municipal  manager is
dealing with:   household  hazardous waste,  yard  waste,  asbestos  from  public  buildings,
contaminated soil  from  source  tank  leakage,  hospital waste, and sewage  sludge.    The
list  goes  on.   There are a  lot  of  new wastes  that municipal  officials  are  grappling
with,  including  how to  set  up a yard waste  collection  and  recycling  program.   There
are  a  lot  of  new  areas  where  I  think  new  demonstrations  and  more  and  better
information is needed.

      I would  also  suggest, to  get around  the problem  we  had  in  earlier days,  to  set
'up a performance-based demonstration where the municipality provides the site.

      Finally, I  would  echo  what  other  people  have said,   that is,  to concentrate  on
the  institutional implications  and  the  institutional  problems   of   new   technologies,
because  a lot  of the problems we are facing  now  are  not  really technological.   They
have a technological aspect.

Response:

      What  you  seem to  be  saying is that  you would  favor something  more  along the
lines of  the old INA Program in  the  sewage  area.  I  think that  is  going  to be hard
to do because it is very expensive.

Comment:
                                  \,                      •
      I am  suggesting a program  whereby the  amount of  money is  reduced.  Certainly
the  risk  is  on  the municipal  side,  and I  do  not think it is  very  good  to  ask the
municipality  to  share   the   risk   of  technology  registration.    They  have  problems
getting rid  of the  waste, and you do not  want to  put  them at  risk.   There  are  other
ways  to  do that,  such as setting up  a performance-based standard that a  facility has
to meet, and the municipality basically supplies the location.

Comment:

      We  have  seen situations where  things  have  been  identified as  being problems in
the  waste stream and there  has  to be mitigation  of some sort.   However,  at  the state
level,  which is where  most of   this  is  being discussed, the  state  is  told  that  they
have no  jurisdiction.   Federal law,  interstate  commerce,  et cetera,  stand in  the way
of some  innovative systems  that  might  be considered.    Everybody I  know  has  been
waiting  for  EPA  to come into  this  because  this  type of  assessment cannot  be  done
on a state-by-state basis.  They may run into  too  many barriers.

      For example,   in  discussing  whether  or   not  an incinerator should  be  built, the
question  is:    What  goes  in  there?    If  you  kept "X"  and   "Y"  out  or  mitigated
something,  would that make  a  difference?   Would  ash  residue  not  be as toxic?   It is
a  holistic way  of  looking  at it.   In  some cases,  certain things have  been  identified
that  ought  to  be  kept  out,  but  the  decision-makers have  been  told  that they  had no'
right to  make a decision on  packaging, for example, or other things  that may contain
constituents  that should  not  be in the incinerator.   That  is  just one  example;  what is
missing  is   an   overall  Federal  approach  because   the  states are  helpless  when  they
come  up with  these laws.   They  do not have the right  or the necessary  jurisdiction.
It is a political system we are talking about now.

                                             53

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Question:

     Somewhere in  those  criteria  you should  consider  a  systems approach.   A  lot  of
this  technology might  deal  with  a part of the waste  stream and still leave the  local
official  with  other  parts.    Sometimes,  the  planning   can  be   cross  purposed.    The
question  I had is:   How are you going to  treat pollution from new  technologies?   For
example,  you  were talking about  a  compliance  test for  incinerators:   How  would you
treat the initiatives program?

Response:

     In  doing  demonstrations,  not like  under  the  SITE  Program,  we actually  try  to
figure  out  what  is  coming  out of  the  technology  and we  try  to  evaluate  that.   We
might  do destruction efficiency, for example.    Maybe  that  is what  we  could do.

Question:

     How could  you  approach  a pyrolysis  process where you  are not  going to  have
much of an idea of either what is going in or what  is coming out?

Response:

     If  we  are  doing a  field  evaluation of either  an  existing  facility and a pyrolysis
unit that  has  been  built,  or  a developer  who  has   a scale  unit,  we  would  take
representative  MSW, feed  it  into  the  process  and  figure  out what we are  feeding  in
and  what  comes  out,  and  try  to compare  not  only the  results of emissions, but the
entire  technology, including  costs, to  other alternatives.    That  would  be  the  ideal.
That would be where we would try to head.
                                                                        -,
     The cost  of environmental  testing  could be substantial.   It could be prohibitive.
I do  not know that for  a fact.   We  do this  in the SITE Program, and  we  have not
found any yet that are prohibitive; however, that is a rather substantial program.

Comment:

     I think you make  a mistake by  starting  out this  program in saying,  "We  are not
going  to  deal  with the  industrial waste  stream  program,  even  on  the   nonhazardous
side."   I think you have  an  opportunity  right now  in  this  program to realize that
more of  the  industrial  waste stream  is  going  off-site because  of  capacity  problems,
location  standards,  and  everything  else.    Service  providers,   including community
leaders,  have  to  worry  about the infrastructure  for industrial waste  as  well as  MSW.
Now is the time to think about it, and not the next round of legislation.

     Also,  I think  there  is  a  need  to really  evaluate systems  that  do  a better job
and  not evaluate just hardware  or  technology  development.   I would suggest  to my
colleagues that  this may not  be the program in which  you  had  best do  that, however.
There  is  a  panel  tomorrow  that  deals just  with planning  and  management techniques.
I came into  this session thinking  that  one of  the things we  want  to  talk  about  in
that  panel is  innovative  ways  to  do  system planning  that  may tie outside  technology
evaluation programs.
                                              54

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     The  last  thing  I  want  to  say  is  that  I  still  think a  technology  evaluation
program is very important.   I  will speak  only for my company  in this  by saying that
we are  basically  a  service  provider.   If  something  works  and  we  can  incorporate  it
while providing a  service, we would  be more than happy to use it.   The truth  of  the
matter   is   that   in   the   large-scale  waste   services,   there  has   been  almost   no
technological  revolution  in  the  last  20  or  25  years.    I  think   we  would strongly
support  any program that  is  going to try  to get us a little bit  closer to  new ways  of
doing  business  over the next 20  or  25 years.   If this  program helps, I  think  we  all
ought to be behind it.

Comment:

     I  would  be  quite surprised if  you could see really  innovative  technology  in this
field  beyond what has  already been  investigated  at  one place  or another.   I  would
tend  to lean toward evaluation of  what  has  been attempted  and  separate  fact from
fiction,  because the  truth  of it is that right now we  are involved in hearings and we
are looking at getting into a community and dealing with  its solid waste.

     There is a  great  deal   of postulation  and theory  presented to  people who make
the decisions  on MSW management as to what a system will or will  not  do.   There  is
no  formal mechanism, other  than going to  the state  or going to  an evaluation  listing
of  what is out there  and what  are  the  real numbers as far as  what  recycling  really
can do, as  far as what incineration really can do.

Response:

     What  you  are  saying  is  that  they  have  not  been  evaluated  sufficiently  to
provide  information  about  existing  facilities  and programs, and  that   is  where  we
should start.

Comment:

     That  would  be my guess, and I have looked at  and  been involved with  RDF and
incineration  facilities and  recycling  processes in  the  last  15 years.   I  personally  do
not  expect   or   project   that   in  the  next  decade   we   will  observe  catastrophic
differences from what we are  currently doing.   I  think the difference is going  to be
fine-tuning our evaluation of those  systems so that we pick  the  one that is  optimum
for a given  community.   I think that we  need to take  what we  know, put the science
together,  and  do  an  evaluation.   That  may  involve  comparative  analysis  or  getting
people  who  are presenting from  a marketing  standpoint that they  can do "A," "6,"  or
"C," to  prove that they  can  do it.  When  you get recyclers who  say, "We can  recycle
100 percent," let  us have  them prove  that  they  can  do it,  because I  am getting tired
of hearing  it on the street.

     If  nothing else,  EPA   has  got  a  responsibility  to  communities to  have  these
demonstrations proven  or  not proven,  so  that engineers and  people  who  are  involved
in MSW handling  can  have  some  facts and  separate those  from theories.   At least we
should  have a foundation  of what is empirically, factually  proven  to date.   I do  not
think that there is any central area where anybody can go to get that information.
                                              55

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Response:

     Let me  ask  a  question  of  those  of  you  who  may  be  equipment  suppliers.
Suppose you  develop something  new, such  as  a better  way  of getting  the solid  waste
into an  incinerator,  or  a better  way  or a  more  cost-effective  way  of separating
aluminum or  tin  cans;  the thing seems to  work; you love it.   Can  you  sell  it  now?
Would  this  kind  of a  program  help to sell it?   That  was the  problem  in  the  SITE
Program, and that is basically the reason the SITE Program got put together.

     I  guess  the  question is:   Taking something like that  and having an  outside  third
party,   EPA   in   this  case,  doing   the   evaluation  and  providing  not  a  "Good
Housekeeping" seal  of  approval, we  never do  that, but  some  sort of  a  published
evaluation, would that be a help in getting a good innovative technology used?

Comment:

     We  have  developed a  lot of  innovative  things  in  relation  to  a combustion
system.   Our stoker was  made in  1929  and has been improved ever since.  We have
the  logic  in  our computers   to  control  the  combustion,  ferrous  recovery command,
single  versus  dual ram feeders,  all  of those  things.   We  develop  them.   They  assist
us  in  marketing the system,  probably only to the  extent  of lowering our costs.   We
would   not  sell that.    Along  with  some  other  people,   we have  developed  in-furnace
lime rejection.  It is for  our system, and  the  only thing we  have is  what we learned.
We cannot patent that. It has been patented SO times already.

     The way  Congress  is   going,  a  lot  of  these  technologies  to  improve  existing
plants  will  be  legislated  away.   There  is  a  limit  to  how much  effort  to put into
evaluation of  technologies  that Congress  will not allow  you  to use anyway.  We used*
to  have  a  technology  evaluations  program.    That was probably  Consumat's   best
marketing tool of small systems, a study that we published.

Response:

     The question is if you need a third party.

Comment:

     No, because  these decisions  are made emotionally, and  I do not  think  science
will change that.

Comment:

     I  think  it is useful sometimes to know that there are situations  that  have  been
resolved,  probably because some  of these  evaluations took  place.   A couple of  years
ago  I  was  doing  a  plan  for a  small community  that  did  not want to  get  a   larger
landfill  if  they  could  avoid  it.    They  wanted to  go with  some  kind of  modular
combustion  unit.    The problem was that there  were  a  lot of competing interests.
Not only were the  manufacturers presenting their data, there were also other groups
in the community who were anti-whatever.
                                             56

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     It would have  been extremely helpful if there  had been  some  kind of evaluation
process in  place  at the  Federal  level.   It  was  because there was not  that  the city
and  county  fathers  decided  they would not  proceed with  it,  because  they could  not
disengage themselves from all the competing  interests and  information  that was  being
put  to  them.   There was no  objective source that they could fall  back on.   That is
just  one  anecdote,  but  I think  an  evaluation  program  is  something  that would  be
extremely useful to have.

Response:

     I  am  hearing two  different points of  view.   If  we  are talking  about a major
alternative  technology  or  approach,   maybe  there is  a tot of benefit  to doing  an
evaluation  to   provide   credible  information.     If  we are   talking  about  a  rather
substantial improvement  to  something  like a  resource recovery incinerator, maybe  the
companies who offer that have  the  wherewithal  to  incorporate that into their  system.
Is that rational?

Comment:

     I  think you can  break  down  technology,  innovation,  and  improvements  into a
number of  different areas.   There  are  those areas  that the  manufacturers are going
to want to  do on their  own.  A good example is the RDF  manufacturers who  have a
problem with  keeping  their  carbon   monoxide  (CO)  levels down  within  the  furnace.
There  are several  things they  need  to do  to  make the feed of the  RDF  system  more
uniform and arrange the  combustion process  to  keep  the CO level down.   It behooves
them to  do  that  because   the  EPA  regulations  are  saying,  "Keep  your  CO  levels
down."  Therefore, there is going to be a lot of investment in that area.

     There  are other areas that are  not  driven  by regulation.  Right now we have no
NOX R&D  in  this country  because  there  is  nobody pushing  it except the people  in
the  State  of California.   You can look  at  NOX  technology development for acid  rain
and  SC>2.    We  are behind   the  rest  of the world  because   we  have  chosen  not  to
regulate those  things.  Germany has.   They are  doing a  lot of work on NOX and  SO2
control on the back end, and" so is Japan.

     If we  pushed  technology through  policy  or regulations,  then  a  lot  more  work
would  be done in  that  area.  Of course,  with  the  current way we set regulations  of
the  Clean Air Act,  there is  no  incentive for a  manufacturer  to improve  air pollution
control  technology because when  you  do,  EPA  says, "Hey,  there  is better  technology
out  there.    Now  you  have  got to  use  it."    In  fact,  our policy  has  a   built-in
disincentive  in  certain  areas.   Nobody wants to  get  a better system  because  if you
do, the Federal government is  going to force you to use  it.

Comment:

     There   is  nobody   refereeing  the  argument.    The  kind  of  overall  policy  and
technology  voice  that  EPA  used to  provide has been missing.    Now  everybody  is
talking  about whether  a system should be designed  to  remove some things  potentially
hazardous or  clean up afterwards.  You get  into  that argument,  and there  is  literally
no one to  turn to because  everybody will be very firm on whatever side they are on.
                                             57

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Comment:

     If  we  were  going to  do a  demonstration or  an evaluation of  the approach of
separating  batteries used in  France,  for  example, you could probably  do some sort of
a  paper study  to  evaluate  what  has been  done  in  France.   Another  approach  would
be  to  do  an evaluation here,  at a  medium-sized  town, and try to evaluate  what the
impact  is, including how  it works,  what the costs  are,  etc.   Who  would  EPA  work
with?  Who would be the sponsoring organization?

Comment:

     Then the  battery manufacturers would say  that if you  can dry cell  it,  you  would
alleviate the  problem.    You are going  to  have  to  continue  with  some analysis in a
resource recovery  facility,  rather  than the landfill.    I think  that  one  of  the  things
that is  important  is  to  provide  policy  analysis or  program  analysis.    The  MITE
Program may not  be   the  vehicle  for that  because there  are  other  divisions  in the
Agency with those  responsibilities.

Response:

     That is correct. The MITE Program would not do policy work.

Comment:

     The  point  is  for  people  not  to feel frustrated  because this program is  not going
to capture  all of their needs.

Response:

     No.   This  is  a  technically  oriented  program.    It  has  to  reflect  where we  are
coming from. There might be another program  to address different needs.

 Comment:

     There   are   a  lot  of   municipal   and   city/county   organizations  that   cover
technology.   There are groups  that work  with  local  governments  that  could get  the
word out,  if that is what you are asking.

Response:

     Do you think they would be interested in co-sponsoring this kind of program?

Comment:

     Yes.    I mean, in the  energy  area  we are doing  some work with  the  Department
of Energy.   One of  the  projects  is  a  yard  waste  recycling  and  collection project.
The cities actually do  the  work, and  we get  the  word out.   There are  mechanisms  to
get  the word out, and generally  cities  and  counties  are  interested  in at least  serving
as a demonstration site.
                                              58

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Comment:

     Some  of  the  monies  for  this  MITE  Program  should  be  spent on  evaluating
technologies  that  are already out  there.   It  is  being  done  continually  by consultants.
Papers are being  written  all the time  on the pros  and the cons  of various incinerator
types and air pollution  control  types.   It seems  that this  MITE  Program  should  be
developed  toward  improving   the  hierarchy  steps   number   one  and  two,  source
reduction and recycling,  where  there  is  a dearth  of  new technology.   How  do you
recycle  everything that is in this  room?   We  have recycling  technologies for only  a
few materials.   We  need  to  complete  the whole  cycle,  to separate  and to  reclaim
materials into new products.

Response:

     You agree  that  one of the  criteria  should be  that we would give  preference  to
things  higher  up  on  the hierarchical  setup  that   the  EPA. is  agreeing  with  at this
time, and  to evaluate technologies that already  have a  good track record, to  compile
articles   and   books  that  have   been  written  on   them,   and  to   compare  these
technologies.    Consultants  are  getting  the  bread and  butter  from  that.    It does  not
seem that it should pay to redo that.

Question:

     Would the funding  of the MITE  Program siphon off research dollars from other
areas?

Response:

     That is  a  hard question  to answer.   That  is  one  possibility.    In  terms  of
funding  something  like this,  one  of  the options is to  siphon  money  off from  other
areas.   Another  option  is  to try to  obtain new money.   We could go  either  way,  or
both ways for  that  matter.   I am not going  to  speculate on  how the  money might
show up, but there are several ways of exploring that.

     The first question is:   Is it  a needed program, is  it something  that  makes sense,
and how would we set it up?

Comment

     I would like to give an example  of how a program  like  this could help in  terms
of ash recycling or ash utilization.  Many  of us have worked  in this area, and know
that we  can  use  this  material,  but  we  have  questions  concerning environmental
impacts.   These  are  the types  of  programs  where  a demonstration is  needed.   We can
put  this  down  on paper  and can say  it  could be  done.   Unless somebody sees   it
actually done, it is never going to happen.

     I am not  sure  that  the MITE Program  is  structured  to  do  this  because I do  not
see  these  kinds  of  demonstrations as  a one-shot  deal.    We  may  be  talking  about
something  that  goes  into  the  environment  for  an  extended  period  of  time,  and one
has to look  at it over a  long  period  of time.  It  is clear that in this business, unless
you see it happen with your own eyes, you should  not believe  it.


                                             59

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     We are  trying  to  plan these types of  demonstrations  now because  we  know  we
are never  going  to make  it  happen  unless people  see it happen,  unless  they  can
monitor  it,   unless  they  can   make  certain  that   it  is   not  going   to  have  any
environmental  impact.     I  think  this  is  where  a  program  like  this  could be  of
assistance both  to  local  communities,  who have  a real problem,  and to  vendors, who
want  to develop  new  equipment  and demonstrate  the  idea  of recycling batteries or
removing batteries from a mixed recyclable stream of glass and cans, for example.

Response:

     Let me try  to  focus on  some  specifics.    One  of the  criteria  I  mentioned as
being useful in terms of trying to decide what to do and what not to do perhaps was
the question  of  the  stage  of  development:    that  it  would  make  sense  to  focus
"demonstration.1'   What  I  mean  is field-scale activities as  opposed  to equipment  or
ideas  on a  very small  scale—a  pilot scale, if it  is  equipment.   I guess  that  any kind
of protocol  or  methodology that we  would  use  would have  to  be at  field  scale to be
of any use.  I am not sure, however.

     Are there any  comments  on  that?   Does this  make sense?  How  important is  it
to do  field  work  as  opposed to  laboratory  work, in terms  of  providing this kind of
information?

Comment:

     There  is  nothing  like doing  a project,  being involved  with it,  handling  it, seeing
it done.   On the other  hand,  you have  got  a lot more  money involved when you  do
field-level evaluations than is typical if you do  it on a smaller scale.

Comment:

     I  think  that  the  disposal,   or  treatment  technologies,  whether   they  be  land-
filling  or  combustion,  the control technologies  are  there.    No matter what people
say,  they are  there.   On the  waste  reduction  and  toxicity reduction,  however,  there
is nothing.   Do a  demo on how  you  get the local  newspaper  to convert to  a water-
based ink.   That would have a greater  impact on the environment  than  demonstrating
CO destruction.

Response:

     All right, so you are agreeing again with the hierarchy.

Comment:

     I do not  disagree  with  you.   The concern that I  have  is that the  world does
not think like  us  and  there  is  an acceptance of combustion facilities  at  the moment
in the  country. However,  we  are also  dealing   with a  situation where people  want
integrated waste management,  which  has not come  up  here.   We have been talking
about  separate  elements  of  demonstration.    We  have  not  talked  about  trying  to
design something that proves that you can have  integrated waste management.
                                             60

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     The  things  that  drive people  crazy when  they think  about integration  are the
very things that we have just been  talking about  trying to find a  good way to take
hazardous  materials out of  the  waste area.   If you could go  to  a group  of people to
explain an incinerator project and assure them that  the integrated  waste management
system  has to remove from the MSW the things that are potentially  harmful,  such as
batteries,  then you would be in a much  more  sane environment.  However,  when you
talk about  putting  everything  in  the  incinerator and the public  knows  that some  of
those things cause problems, you cannot get them to accept it.

Comment:

     I  would like  to agree  with a lot  of the  comments  and  reiterate  what  I .said
before  about  doing a demo to  show how to  get newspaper publishers  to remove ink
and to make  a  newspaper.   That is called an  incentive, and it  is not  technology.   I
am  afraid  that   if  we  focus  just  on   technology  we   are  going  to  blur  the  very
important  interrelationships  and  articulations that  exist  between  getting things out  of
the waste  stream as opposed to  doing something  to safely dispose of  it.   I  would like
to  emphasize  that  we need to think  expansively  about  these  things and  not say,
"Well,  that  is  policy.   It does  not relate."  Otherwise, we will end up doing what was
done  in the  1970s, when we spent  hundreds of  thousands  of dollars  for  a  project or
two on waste tires.   The whole problem with  waste tires is that there is  no market
for them.   There is  no economic incentive.    The technology is  there.   It  is on the
shelf.   It  just is not  being  used.   We are in  danger of committing  the same mistake
if we just start looking at hardware again.

Comment:

     There is one  thing I am hearing that is  disturbing  me.  It seems  that  when you
listen to yourself long enough,  you believe  yourself.  I think we are jumping to  some
big assumptions  about where various compounds  are  coming  from.   My  concern  is to
deal with  it as an  engineer  and do  the  things  in its current frame.   I  think it  would
be  nice in  the  future  to  have a  better  handle  on the  use  of lead in   our  waste
stream, for example.    However, the reality of it  is  that  even  though we  may  have
believed that   things  have' been  evaluated  properly,  when  you  get  out  there in the
street,  it is not done.

     The   community  officials  and  many  of  the  state   officials  do   not  have  a
mechanism  to conduct a   reasonable,  fair comparison  between  existing  technologies.
For us to  jump to the assumption  that  they  have  this ability and   then  to say that
we  ought  to  be looking at  recycling because recycling is going to solve  any problem
with MSW  mass burn, is quite a big gap.

     I  personally do  not agree  that  taking  lead pigments  out of  paper is  necessarily
going to solve or  change  the physical variation of  lead  in  the  waste stream.  I  would
rather  solve  first  things  first.   There  is a  big question as  to the  technologies that
are currently   operating.   Let  us deal  with  those for  now and  make  sure  that is
resolved before  we start  looking at  new  technology.    I  think  you can  mix   them
together, but I think the priority should be on existing technology.
                                             61

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Comment:

     I  still  say  that  technology  is  not  the  problem  we  are facing.   It  is  not  the
question;  it  is a  question of  psychology.   The question  really creating the  problem  is
unwillingness to  make  a decision.   There are risks,  as there are  with everything.   If
a  political city or a county  is unable  to make  that  decision, then  they  are  going  to
have a problem, and they deserve to have  a  problem.
                                               62

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    4. "STRAWMAN" MUNICIPAL SOLID WASTE NATIONAL RESEARCH AGENDA
Background
                                                                     *
     The  nation's  mounting  problem  of how  to  effectively  manage  municipal  solid
waste  (MSW)  necessitates  reevaluation of  MSW practices  and  identification  of  new,
innovative  technologies   for  management  of  waste  material.   The  alternative   MSW
practices  relating  to  source  reduction  and  recycling  should be  evaluated to  reduce
the amount of  residuals  for disposal, and  to  conserve  raw  materials and  land  disposal
capacity.   New technologies  for  waste  management associated  with  combustion  and
composting  should   also   be   investigated   to  insure   that  human  health  and  the
environment  are protected.   Technical information  and  guidance  for use  by  municipal
officials,  designers,  engineers, and  owners  and  operators  responsible  for solid  waste
management need to be developed.

     To accomplish  these  goals,  a two-pronged effort  is  envisioned.   First,  there are
a  number  of technical  questions, issues  involving  technology,  technology  transfer  and
guidance needs, and  research  and  development  projects that the  nation should address
if we  intend to  improve  the cost  effectiveness of  MSW  management in the  United
States.    Much of the  needed  work  could  best  be done by the  production and  waste
management  industries  and  their consultants.  The rest would  fall  to  the universities,
states,  and  EPA.    Second,  there  are a  number  of emerging  innovative technologies
that  are becoming  available for use,  and in  some  cases have achieved  limited  use and
cost-effective  improvements  over traditional  waste  management  methods.   There  is,
however,  a   dearth   of   credible  information  on  the cost  effectiveness  of   these
technologies that has  been gathered and  packaged  in a way that  is useful to  decision
makers.   EPA  is  considering a  program,  called  MITE [Municipal (Waste) Innovative
Technology  Evaluation],  that   would  evaluate new,  privately  developed   technologies.
Goals for the MITE Program would be:

     1.  Provide  up-to-date cost-effectiveness and  environmental  information  to  local
         decision-makers  on  innovative  new  equipment and techniques  for  managing
         wastes;  develop expert systems for local decision-makers.

     2.  Accelerate  commercialization   of  new,  privately   developed  equipment   and
         waste  management  techniques  by sponsoring early  demonstrations.  Currently,
         there is resistance to first-time use of new and unproven technology.

     3.  Provide  support  and  lend credibility  to new  techniques  and  equipment  being
         developed  at  the  bench  and  pilot  scale  so  as  to  foster  development  of
         improved product  substitution,  recycling  and  recovery,  waste  treatment,  and
         disposal technology.

Specific RD&D Projects

     The following  list  of  specific  RD&D  projects has been developed to meet  MSW
and sewage sludge management  needs as  they were identified by ORD, the MSW  Task
Force,  and OSW program staff.   For crafting a final  research  agenda, comments  from'
industry,  academia,  trade  organizations,  environmentalists,   and  end-users  are  being
solicited.
                                         63

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Phase I Research and Development

1.   Reduce Volume and Toxicity of Waste

     a.  Case study of effective source separation program.

         Evaluate   at  least   one  good  multimaterial   source  separation   program  to
         document  costs,  recycle rates,  participation rates,  avoided  costs,  and  storage,
         collection,   and  transportation   techniques.     Ideal   candidate  would  be   a
         community that is realizing at least a 25 percent recovery rate.

     b.  Update the state of the art of front-end separation technology.

         Develop   a  compendium   describing  the   various   technologies   available  to
         mechanically separate components  of the  municipal  waste  stream.   Candidate
         components  for   examination  include:     nonferrous  metals  separation,   glass
         separation  and  color sorting,  magnetic  separation  of  ferrous  metals,   ballistic
         separators,   electromagnetic   separation,    froth    flotation,    eddy    current
         separators,  etc.    Air  classification,  shredding, and  densification  equipment
         would  also be examined.   Report  would  identify  the  current  technical status,
         performance  (product)   specifications, mass  balance,  sizes,  throughputs,  capital
         and  operating  costs, etc.    An assessment  of the environmental impacts  of the
         units would also be made.

     c.  Assess  environmental exposure  risks associated  with  recycling  operations and
         recycled products.

         Examine   the  effluent,  air  emissions, and  fugitive dust  releases  from  various
         recycling  processes  to   determine  if an  environmental  or health hazard exists.
         Identify  any  special problems associated   with the  management  of  residuals
         from  recycling operations.    Also  test  recovered materials for  the  presence  of
         trace pollutants that could pose a problem with their reuse.

     d.  Conduct   trace element  analysis   of a   wide  range  of  consumer  products  to
         identify targets for reduction.

     e.  Develop less toxic substitutes for various components of  commercial products.

         This  is  a  task  for private  industry,  with  coordination   and  encouragement
         from  the  various  trade groups.    EPA's  role  would  be  to  identify  the  needs
         and encourage industry to actively pursue product substitution research.

     f.  Reduce the impact of paper and paper products on the waste stream.

         There  are a  number  of research  activities that should  be addressed  by  the
         paper industry:

            Better  de-inking technology
            Technology for the handling, treatment, and/or reuse of de-inking
              sludges
                                           64

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       Increase "acceptability" of lower grades of recycled paper in
         more products
       Develop more products that can use recycled pulp instead of
         virgin pulp.

g. Guidance document on operating an "office paper" recovery program.

   Develop a guidance document  that will show building managers how to set up
   and operate a  high-grade  "office paper  recovery" program.   Include  economic
   projections  that  would  show  at  what combinations of  avoided waste  disposal
   costs and scrap  paper  values the  programs  would be  cost effective.    Work
   from case studies of actual programs.

h. Materials separation and recovery technology.

   Better  mechanical  systems  are   needed  to  extract  usable  quality  materials
   from the waste stream. Research is needed in the following areas:

       High-quality glass  cullet, free of contaminants
       Color sorting of glass  cullet
       Separation of plastics  from nonplastics
       Sorting of plastics by  polymer type
       Extraction of metals from dry cell batteries
       Nonferrous metals  recovery  from mixed waste, and from auto scrap.

i.  Evaluate effect of leaving grass clippings in place.

   Evaluate  effect  on residential  lawns of not bagging  grass clippings.   Look  at
   benefits  and  problems,  including  effect  on  appearance,  thatch   information,
   nutrient  value,   consumption  of  fertilizer,  pesticides,  and   herbicides,  etc.
   Provide guidance materials and promotion.

j.  Evaluation of biodegradable  plastics.

   Conduct  a  study of  the  currently available  biodegradable  plastics.   Examine
   the  products  of  degradation,  including air  and water  migration.   Also look  at
   the  effects   on  costs  and   weight  of  products.     Identify   potential  uses,
   advantages,  and  disadvantages.     Examine   impact  on  land  disposal   and
   incineration.

k. Evaluate use of recovered materials in asphalt  paving.

   Update  prior experience and  possible  new  techniques for using crumb  rubber
   recovered from scrap tires, or glass cullet in asphalt paving.

1.  Determine  potential   for   changes  in   processes   and   packaging  to  reduce
   plastics utilization and waste volume (workshop and report).

m. Assess potential new markets for development  of guidance documents.
                                     65
                                             ii !>• A^ril-'.''/'^-''''. L'

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     n. Determine  management  status  and  current  markets  for  special  waste  (e.g.,
        tires,  white  goods,  demolition rubble,  etc.)-    Determine  need  for incentives
        for   reuse/recycling.     Develop  guidelines  on  management  alternatives  for
        special wastes.

     o. Evaluate  health and environmental  effects  of current  practices for  managing
        hospital wastes and wastes generated by research facilities.

     p. Evaluate state of the art of sewage sludge disposal and identify RD&D needs.

2.   Improve the Safety of Incineration

     a. Evaluate  effect of  individual components  of the  waste stream on  combustor
        performance.

        Laboratory and full-scale  field  tests would be  conducted on  the impact on
        air  emissions  (and   fly  ash)  and  bottom  ash of  selectively  removing specific
        components  of  the  waste  stream,  as well  as from  selectively  increasing  the
        concentration  of specific  components.    For  some  components  such  as  tires,
        an effort  would be made to determine  the  upper limit  of concentration  which
        can   be   tolerated   without  causing   unacceptable   increases   in  emissions.
        Plastics,  dry  cell  and   lead  acid  batteries,  grass  clippings,  and  household
        hazardous   waste would   be  decreased  in  stages  to  levels  expected  to  be
        achievable  through   source  reduction  programs  in order  to measure  the  levels
        of reduction in emissions that  can be achieved.   Evaluate effects  of co-firing
        various wastes and fuels with MSW.

     b. Evaluate   effectiveness  of  new  air  pollution   control   devices   and   waste
        combustion systems.

        As  new   devices   come   on  line,  conduct  detailed  stack  tests  along   with
        comprehensive  waste  characterization studies to  determine  the  performance,
        economics, and viability of these devices.

     c. Develop   and/or  evaluate   new   equipment   for  testing,   monitoring,   and
        controlling municipal waste combustors.

        Better equipment is  needed to measure  and monitor  the  releases of pollutants
        from  municipal  waste  combustors,  especially  heavy  metals,  and  chlorinated
        dibenzo  dioxins and furans.   Stack-testing  equipment and in-plant monitoring
        equipment  that would  give a  continuous  reading of  emission  levels  and  plan
        performance  are needed  to  assure  operators, enforcement  officials,  and  the
        public  that   proper  operating  conditions   are  being  maintained.     Plants
        designed    with   more    sophisticated   combustion   controls   require    more
        performance   data   so   that  the  operating  conditions   can  be  continuously
        adjusted   to   achieve  optimal   performance.    Both   in-house  and   contract
        laboratories  can  be  employed  to conduct  performance  testing  on  commercial
        equipment and to develop new equipment.
                                             66

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     d.  Improve   environmental   exposure   and   risk   assessment   models   for  MSW
         combustors.

         Currently  available models need to  be  reexamined and improved  to give  a
         more  accurate  reflection  of the effect of  municipal waste  combustion (MWC)
         on the surrounding environment.   As we collect  better  data on  emissions,  we
         will need better tools to interpret the data.

     e.  Case studies of newer advanced waste combustion systems.

         Develop  case  study evaluations of  several different types (and  sizes) of  MWC
         facilities.     These  studies  should  summarize   the  technical  and  economic
         performance,  and  provide  good  data  that could  be  used  by  other decision-
         makers.

3.    MWC Ash Residuals Management

     a.  MWC residue treatment utilization.

         Studies   will   assess  various   techniques  (e.g.,  solidification,  acid  leaching,
         vitrification,  etc.)  to  treat  the  residues  to  eliminate  or  immobilize  toxic
         constituents.     Treated   residues  will  be  characterized  to  determine   their
         suitability  for  utilization.   Small-scale  studies  and  selected  field  studies  will
         assess  performance  of treated  ashes used  as commercial  products  (e.g.,  road
         bed,   construction  blocks,  etc.).    Emphasis  will   be   placed  on  determining
         environmental impacts.

     b.  MWC residue and leachate characterization.

         Residues (fly ash, bottom ash, scrubber  solids,  etc.) from representative  MWC
         and associated air pollution control devices  will  be physically and chemically
         characterized.    These  will be  assessed  for  their  potential  to  cause  adverse
         effects  on  human  health  and  the  environment.   . Ash  quench  waters  and
         leachates  from  the  disposal   facility  and  groundwater  at   the  site   will  be
         analyzed   for   constituents  of concern.    Appropriate   physical   and  chemical
         tests   and  toxicity criteria  will  be  used  to  evaluate  potential  adverse  effects
         of the ashes, leachates, and wastes.

     c.  MWC residue land disposal.

         Studies   will  evaluate   the  use  of  various  landfill  designs  for  containing
         untreated and  treated  ashes.    Studies will  determine  the  migration  potential
         of toxic  constituents   in   the  ashes when  disposed  of  in  soils,  in monofills
         (especially  designed for  ashes),  and/or  municipal  waste landfills (co-disposal).
         These  studies  will emphasize  the  performance of different  landfill  designs
         being proposed by the Agency for managing MWC ashes.

         Migration  through soils and clays:   Critical  evaluation of literature and  batch
         adsorption   studies  with   selected   soils  and  residual   types;   ash  pollutant
         migration rates in soil columns.
                                              67

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4.    MSW Land Disposal

      a.  Continue research into landfill gas emissions and recovery.

         Continue  and  expand  our efforts to  collect quantitative and qualitative  data
         on  gas emissions  from municipal  landfills.   Data need  to  be related to  the
         quantity of waste  in   place,  the  age  of  the  waste,  variations  over  time,
         effects  of  moisture  in  the fill,  and  effects  of  variation  in  composition of  the
         wastes.

      b.  Case studies of model sanitary landfills.

         Evaluate several  municipal  landfills.   Sites  should  be of different sizes and
         types,  and should  have  leachate  collection  and  treatment  systems,  and  gas
         collection   systems.      Evaluation    should   document   design,   operation,
         performance, and costs.

      c.  Develop   guidance   on   postclosure  care   and  corrective   action   for   MSW
         landfills, including long-term monitoring.

      d.  Improve  environmental  exposure  and  risk  assessment   models  for  sanitary
         landfills.

         Currently  available  models  need  to be  reexamined  and  improved  to give  a
         more  accurate   reflection  of   the   effect   of   landfills   on  the  surrounding
         environment.    As  we  collect  better  data  on  leachate and  gaseous  emissions,
         we will need better tools to interpret the  data.

      e.  Evaluate effectiveness of landfill liners.

         Field testing  of  one or more  state-of-the-art  landfill liner  systems needs  to
         be  conducted   to  determine  how  they  are  performing as they   get  older,
         Testing is  needed to determine if  there is  leakage  occurring and to  quantify
         the  amount  of  leachate  being  intercepted.   Assessments should  be made  of
         the  expected  life of  the  liner based on  examination of the  quality of  the
         liner  over  a  period . of  time.    A  site  should  be selected   that  is  as old  as,
         possible, but that has a liner that is  considered state of the art.

      f.  Develop effective leachate control and treatment technologies.

         Engineered collection systems work  needs  to be expanded  to include storage,
         treatment, and residue management  technologies.

      g.  Evaluate subsidence control techniques for subtitle D facilities.

         The   waste  characteristics  and  methods   of   waste  placement   in  sanitary
         landfills  are conducive to  significant  waste  settlement and   cover  subsidence.
         The  subsidence  potential (up to  30 percent  or  more of  the  original thickness)
         limits  the   further   use  of  closed  facilities.    Decreasing  the  potential before'
         closure  can  increase the opportunities  for  further use.   It   can  also minimize
         the  possibility   of  subsidence-caused  breaching  of  the  landfill  cover  and
         increased   leachate   generation.    Control   techniques  during  the   operational

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         period   can   include   refinement   of   waste   placement   and   compaction,
         surcharging   prior   to   final  cover  installation,  incineration  of  low-density
         materials,  and  mixing  of  wastes  with  materials  (i.e.,  fly ash)  to  increase
         density  and compressive strength.   A  research  project  would evaluate  each of
         the  alternatives  and  provide  a  guidance  document  on  the  prevention  and
         mitigation of subsidence  in sanitary landfills.

     h.  Evaluate vertical expansion  and  other  techniques to extend   the  useful  life of
         subtitle D facilities.

     i.   Research on attenuation of synthetic organics in MSW leachate by clay soils.

         Recent  monitoring   information  indicates  that substantial  amounts of  synthetic
         organics  (vinyl  chloride, TCE, PCB) are  found  in  MSW leachates.   This  task
         will collect  and  summarize  recent  studies of  retention and movement of MSW
         leachate  contaminants  in soil and  perform  a  limited  amount  of  laboratory
         testing to identify any additional work required.

     j.   Development  of  techniques  to   accelerate   the   physical,  chemical,   and
         biological  degradation of  MSW  landfills  with and  without industrial  wastes or
         incinerator residues.

     k.  Development  of expert  systems  to  assist in selection  of control  technologies
         to   effectively  and  efficiently   reduce  environmental   hazards  and   related
         human health risks associated with land disposal facilities.

5.   Municipal Planning  and MSW Management

     a.  Assess  state  of  the  art of  MSW  management.   Report on status  and needs
         (workshops).

     b.  Economic  and   benefits  assessment  of  MSW  management  alternatives  and
         provide  guidance tools.    Develop  models and protocols  as  guidance  for doing
         risk  analyses,  cost-effectiveness   analyses,  and  public  relations  analyses  for
         available options.

     c.  Develop   expert systems  for  evaluating  and  selecting   MSW   management
         options.

Phase II Technology Evaluations

     The  following  are  offered  as  examples   of technology  evaluation projects  that
might   profitably  be  undertaken.    No   contacts have been  made  nor  firm plans
developed to perform any of the listed projects. They are offered as examples only.

1.   Source Reduction/Recycling

     a.  Plastics   recycling:     Plant   accepts mixed   waste   plastics   and   softens  the
         plastics  for  extrusion   into   usable products  which  are  substitutes  for wood
         products.
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     b. Battery  recycling:    Plant in  conjunction  with  community has  warranted  for
        collection   systems   to   collect   all   batteries,   including  Ni-Cd   batteries.
        Collected batteries  are  sorted  at plant for  recovery of  silver  oxide, mercury,
        etc.

     c. Material  recycling  facility  (MRF):    Small-scale  central  collection/processing
        facilities  which  reprocess   MSW   for  recycling.    Includes  glass   separation,
        paper  baling,  plastics baling,  etc.   These  types  of facilities  may  be  key  to
        increased recycling in  the United States.

     d. Use of  shear  shredding:   Use of  shear  shredders rather than hammermills  to
        reduce  costs and improve safety,  which are  key issues  in  MSW  processing  for
        use.

     e. Mechanically  assisted hand  separation:  Mechanically  assisted  hand  separation
        improves quality of  recovered  items/materials.    Produces  refuse-derived  fuel
        (RDF) for cement kilns.

     f. Multiple  materials   recycling:     Recycling  of   organic   fraction  and   other
        materials from MSW.

     g. MSW  processing:   Recovers  compost  feedstock,  produces  densified  RDF, and
        processes remaining materials for reuse.

     h. Tires as  fuel:    Discarded tires are shredded, then used as fuel to fire cement
        kiln.

     i.  Recycling MSW and sewage  sludge:   A  recycling process  that  handles both
        MSW and dewatered sewage sludge.

     j. Densified RDF  materials  recycling:    Produces  RDF  energy  pellets  (50-60
        percent  of  the  waste); the  rest  of the waste  goes into recycle materials that
        are processed  for  sales or  reuse.   There  are operating systems that would be
        available to check the  economic efficiency.

2.    Municipal Waste Combustion

     a. Method  to produce  heat and  CO^    U.S.  patent process  burns carbon-based
        fuel,   removing  gases,  recovering  heat,  and  producing  CO2  by  fluid  bed
        combustion.

     b. Two-stage  gasification/combustion of  MSW:   The  O2-enriched  MSW (gasified)
        is cleaned and combusted a second time with excess air.

     c. In-duct   injection   of advanced  sorbents  into  flue  gas:   This  process  uses
        recently  developed calcium  silicates,  which are  highly reactive toward HC1
        and SC>2  and  contain  large waters  of  hydration,  to  remove acid  gas, trace
        organic,  and  heavy metal pollutants  from  municipal  waste combustor flue gas.
        It  is  suited to  both new and retrofit  applications, and promises to  be more
        cost   effective    than    conventional    scrubbers,   particularly   for   retrofit
        applications.


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      d.  Enhanced  Hg  control  via  spray drying:   Activated  carbon  is  added  to  the
         lime  spray   dryer  [retrofitted   to  an   electrostatic  precipitator   (ESP)]   to
         enhance  Hg  removal  for  meeting  stringent  Hg  control  requirements.   With
         this   modification,   the   process  achieves  high   pollutant  (acid  gas,  trace
         organic,  trace  heavy  metals,  and  particulate)  control  at  a  cost  advantage
         over wet scrubbing.

      e.  In-furnace sorbent  injection:   Alkali sorbents  (lime  or limestone)  air injected
         into  the furnace  burning MSW  to  remove  HC1 and  SO2  as well as  to  inhibit
         formation  to  PCDD/PCDF  or other products of  incomplete combustion  (PICs).
         The  process  is  especially  suited  to  retrofit  applications,  but  may also   be
         more  cost  effective  for  new MWC applications  with  moderate  emission  limits
         than conventional scrubbers.

      f.  Fluidized-bed combustion with  sorbent  in  bed:  Sewage sludge  or RDF from
         MSW is  burned  in a fluidized  bed containing  an  alkali  material (limestone  or
         dolomite) to  effect  pollutant (acid  gas,  trace  organic) control.   This process
         is very compatible with refuse  recycling.

      g.  Integrated  control  of MWC  emissions:    This  process  uses  dry  lime  injection
         into  a  slightly  quenched flue  gas  from  a municipal  waste combustor  and  a
         fabric  filter  to  effect  high  removal of  acid  gases,  trace organics,  trace  heavy
         metals,  and  particulate  matter.    A low-temperature selective  catalytic  reactor
         following the fabric filter permits high NOX control.

      h.  MWC  pollutant  control   with zero-effluent  discharge:    This  process  uses  a
         spray dryer  to  evaporate liquid effluents  from wet  scrubbers  used to remove
         acid   gases,  trace  organics,  and  trace  heavy,  metals  (especially  mercury).
         Particulate   collection  follows   the  spray  dryer.     This  system  can  very
         effectively  control all pollutant emissions (particularly heavy metals).

      i.  Municipal  hearth  sewage sludge incinerators:   This  technology  evaluation  is
         needed   to  show  that_proper  operation  of  sludge  incinerators  alone can
         significantly reduce emission  and odor levels.

3.    MWC Ash/Residuals Management

      a.  Ash  as aggregate  for  road  building:   Ash will be  used as  road bed material
         for   limited   highway   section;   environmental    monitoring;   evaluation   of
         engineering integrity. Paving to begin May, 1989.

      b.  Ash-concrete  admixture  for  reef construction:    Stabilization/immobilization  of
         constituents of  concern  in  combined  ash  for  concrete blocks;  lab  evaluation
         completed;  blocks submerged in marine prototype. Field evaluation underway.

      c.  Ash-concrete  admixture  for  predisposal  treatment  and  as  landfill   final  cover:
         Concrete  admixture   of   combined   ash  solidified  for  use  as  landfill  (ash
         monofill)   final   cover   and   as   construction  material   for   small  houses;
         environmental  monitoring;  evaluation   of  engineering   integrity.     Pilot-scale
         field evaluation underway.
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I
                     d.  MWC   ash  utilization:     Characterization  of   MSW   feed  to   incinerator;
                         processing  bottom ash  as  aggregate  for  concrete  and  asphalt; stabilizing  fly
                         ash with  cement;  characterization and  evaluation.   Pilot-scale  field  evaluation
                         underway.

                     e.  MWC ash  processing:   Uses  sink-float  process  to  recover  numerous metals  in
                         MWC ashes.   Remaining  ash  components are  used  to  produce road  barriers
                         and other  products.   Plant has  been operational,  but  requires  crusher  for full
                         evaluation.

                     f.  Mining  of metals  from  MWC  ash monofills:    There  are  several  potential
                         companies/locations,  and  several  companies  are investigating  the feasibility  of
                         mining  MWC  ash  monofills  for  metals  recovery.    This  technique could  be
                         ready for evaluation rather quickly.

                     g.  Vitrification  of   MWC   ashes:    Several  locations  use  electric arc or   other
                         means to  vitrify  or  fuse MWC  ashes as treatment  for utilization.    Techniques
                         currently used at several  facilities in Japan but not in the United States.

                     h.  Stabilization  of   auto   fluff  combustion  ashes   and  other   MWC  residues:
                         Metasilicate  stabilization  process  for  treating  ash/residues  from  incineration
                         of  auto fluff  (a  hazardous  waste  produced  in  processing  junk   autos  for
                         recycling).    This process  has been successfully  used  at  four  to  six locations
                         in California to  delist   the  hazardous  waste.    Also  potentially applicable  for
                         treating MWC ashes.

                4.    MSW Land Disposal

                     a.  Innovative   gas   recovery.      Recovers   gas   from   landfills   and   processes
                         condensate  to reduce toxicity.

                     b.  Use  of artificial  landfill  cover  materials—several  locations:   Evaluate use  of
                         Sanifoam and artificial covers for  landfills.

                     c.  Bio-barrier  root  control fabric  for landfills:    A  combination  barrier made  up
                         of fabric  called  typar  and herbicides  that can be  used  for  up to  a hundred
                         years  to keep  roots  out  of the compacted  clay  in  a  cover  system  product
                         developed  by the  Department of Energy,  Battelle-Northwest,  and  is  ready  to
                         be field tested.

                     d.  Composting/odor  control:      A  system  for  controlling   the   odors   from
                         mechanical  and static  pile  sewage  sludge composting.   An  ongoing  survey  of
                         composting   plant  operating  problems  has   found   odor   problems   to  be
                         widespread  and   to  be  threatening   the  future   operation  of  many  plants.
                         Proprietary   air   scrubbing  systems,   soil   filters,  and   scrubbers   containing
                         finished  compost  need   to  be  compared  to  determine their  effectiveness and
                         relative  costs,   and  the   information  needs   to  be   transferred  to the   user
                         community.
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      e.  Autothermal   thermophilic   aerobic   digestion   (ATAD):      Evaluate   ATAD
         treatment  of sewage  sludge for  economic  operation  and  a  high  degree of
         pathogen  destruction.   This  approach to  digestion has  been used  in a number
         of  other  countries,  especially in  Europe, but has  not  been  accepted  in  the
         United  States.   Permitting  of sludge  disposal,  required  by  the  Clean  Water
         Act  of  1987,  is  expected  to require  upgrading  of  many  aerobic  digestion
         systems.   If  ATAD  is effective, it will provide an  approach  to this upgrading
         that can  be   widely  applied.  Modular systems are  manufactured  by  at  least
         three companies.

      f.  Composting/materials  recycling: Compost  production  and  materials  processing/
         recovery,

      g.  MSW composting  systems—several  developers:   Several  new   process  systems,
         including  plastic  drum  use,  have  emerged  in  recent  years.    Few  data  are
         .available to compare and select best systems.

Discussion

      What  we  are concerned, with  is  making  sure  that  the  decision-maker  has  the
information  he  needs.    If  he  chooses not  to  use  it, if he chooses  not  to  make a
decision, that is  not  our  responsibility.    It  is the responsibility  of   the  people  who
voted for him.

      While  I  personally  agree  that  there  are  technologies  available,   I  do  not  know
that  they "have  been   evaluated.     I   know  my   feelings  are  very   strong   that
technologies,  and  innovative   technologies   particularly,  have  not been well evaluated.
If the information is there, it is a well-kept secret.

      We repeatedly said  that  one aspect of  our program that  we consider  to  be  very
important  is  outreach.    Let  the decision-maker know  what  tools and alternatives  are
available, so  that if he should make a decision, it can be an intelligent one.

Question:

      Do  you want to  break  it  down  into  near-term  research  goals,  or  do you  want
immediate and long-term research goals?

Response:

      One  of the  things  the  facilitators discussed  was  the  criteria  for ranking.    Part
of  the  criteria  is time  lines, not only how long  it  would  take to develop a project
and complete it,  but  also  the startup  time.   By startup time,  I  mean how long  and
how far along the  R&D  track  a  project already is, and how  much  work  remains  to be
done;  e.g.,  is it  a brand  new  concept?    Those are  the   types  of  criteria that  the
facilitators are going to help  you use to rank these  things in terms of priorities.

Question:

      How are we  going  to handle  things  in  an  interface area, in  say the combustion
area,  that are going   to  need  technology  transfer  and deal   with  localities?   Will  the
group on municipal planning handle those kinds of issues?

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Response:

      Those  are  the  kinds  of  issues—outreach  and  getting  the  information to  the
planner—where there is going to be some overlap.

Question:

      // there is overlap, how do we decide whether to include it in the group?

Response:

      Unless  you know  for  a fact that someone else  is going  to  cover  it,  include  it
and we will sort it out.

      Even  if they  do include it—even if you know for a  fact  someone  else is  going
to  cover  it—your thoughts on that subject are  still what we  want.  Some topics may
be discussed in all five groups.  Nothing is wrong with that.

      I think  that  there  have   been  some   fairly  definite  goals  laid   out  for  the
workgroups  in terms of  what we expect  and what we would like to  see come from
the workgroups.   It should  flow fairly  smoothly  in  terms of  format.   We want  to
emphasize  that  this  is  a  national  research agenda.   It  is a part of the  MSW agenda
for action  strategy  that  the  Agency  has embraced.    Within  that  context   we  want
.your thoughts  on what  needs to  be  done and  the  order in which you  would  ideally
like to see it done.

      The  Agency people  are  not  here to expound on  Agency views or  anything, else.
They  are here to listen.   The purpose of the workshop is  to  get your  views, and that
is  important  to  all  of the  Agency  people.    That  is  why  they  are  spread  throughout
the workgroups, and that  is why they are here.
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 5.1
                5. PRESENTATIONS BY WORKGROUP FACILITATORS
Source Reduction and Recycling
Conrad Simon, U.S. EPA—Region II
      We  went  into  this  workshop  in a  very  structured fashion  but soon  agreed to
 operate  as  freely  and  as  spontaneously   as  possible  while  trying   to  achieve  some
 specific  goals.   We listed the types of information that we  needed.   We did not  press
 the  need  to  get  them  now  because  we  hoped  and  believed  that  there  will  be
 opportunities ahead to do that.   What  we  tried to do was  make sure that good and
 substantive  ideas came out  of  this workgroup, and  got on  the  record.   I believe this
 workgroup had a wealth of very  good ideas and information.
                       '
      Unabashedly,   we   want  to   emphasize  our  belief that  source  reduction   and
 recycling  are   the   most  important   elements  of  an   integrated  MSW   management
 program.   This is  particularly  true because  what happens  up front in the process  to a
 great extent determines  what is  available  and what  has  to  be  dealt with  later down
 the line.   Just as  importantly, these  are the  areas that have had  the least amount of
 government attention over  the  past  several  years.    This  is  true  for  the  Federal
 government, and to  a great extent for industry.   The  many  people  who  have  done
 work in the area  have  done so  on  a  shoestring budget.   So  it  is  an  area that has
 been neglected--not  partially—but  rather extremely.   Because of  this, and  because of
 their   importance,  source  "reduction^ 'and   recycling   represent   perhaps   the  greatest
 opportunity and  potential for  action  by EPA.   This  does  not  mean that the major
 work is  done  by  EPA,  rather that  EPA  becomes the  initiator  of activities  in these
 areas.

      One of the questions  we planned  to  answer was  who  should do what.   We did
 not  succeed in  developing  those  answers  in  this  session.    Having completed   this
 round of discussions, we expect to provide feedback to EPA on who should do what.

      Many  of  the  activities that  we  are  suggesting  are low-cost items.   Therefore,
 we  believe  that they  represent  the  .kinds  of things  that EPA  can  get  started  with
 implementing even while its budget is low.

      For convenience, we  divided  the workgroup  discussions  into  two  major areas.
 One  set  of topics  involved^soujrce_ reduction;''the other  recycling.   Prior  to coming to
_jhe___workshop,—we~~asked  two  people  to  develop proposals  for • discussion purposes  in
 each of  those  two  areas.   We spent most of  the morning  discussing those proposals
 at  some  length.  In the afternoon we got  to the strawman  agenda and  merged some
 of the  proposals from  the  morning's  meeting to the  strawman  agenda;  however, we
 are entering the completed presentations on those proposals into the record.

      We struggled  with  the issue of  what  really could be  addressed by  RD&D  as
 opposed  to what policies  and programs  should  be put in place.   We found that we did
 not  cut  that line very finely.  Although you  will see  many  specific   RD&D  proposals,
 we  are  giving you   issues  that  should  be  addressed  by EPA  in   other  ways  than
 technologically.    In  fact, many  of the items  relating  to technology  development are
 really about technology transfer.
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     One of  our major conclusions  was  that source  reduction  is  maybe  90  percent  a
matter of  education.   So  we  would recommend that education  become  a big  part  of
future activities by EPA in solid waste management.

     Since  imported products  represent  a major  part of  the  goods  that  we use, we
believe  that EPA  will  need to  pay a  great  deal  of attention  to the  whole  issue of
these imported products  in terms  of  their composition  and  packaging.   We  cannot
look just at American products.

     With  respect to  recycling,  we  need to  look  at it  more  as a  service,  and not
primarily a money-making  venture.  That has been a trend that  might have  occurred
in the past.

     We need not  wait to develop  a  lot of new  studies and  guidance.   EPA did  a
number of  studies in this  area in  the 1970s.  One of the  things we can do  initially is
to dust off some of those studies, update them, and utilize them.

     The  manufacturing  and  packaging  industries  need  to be major participants  in
what we plan to do in  this area.  EPA needs to  arrange  another meeting  with the
manufacturing  community,  with  the packaging  people,  and  others; and this  time we
should  go   with   the  intention  of  listening  to  what they have  to  say,  not  just  to
preach  to  them.    Although we  had some  of  their  representatives here  today, we do
not  believe that  they  were sufficiently  represented.   This is  one meeting  we would
like  to see happen sometime soon.

     We believe  that a major effort must  be  made to  reduce  disposables—not just  in
terms of packaging, but also in terms of equipment.

     In  the area of medical waste, which has become  a hot  topic  in  EPA  recently,
the use of disposable items is probably the major cause of the problem.

     We need to explore  ways of recognizing  positive efforts  by  industry.   This  may
be achieved by giving awards to industry for the creation of good quality products.

     We need to explore  ways of recognizing  positive efforts  by  industry.   This  may
be achieved by giving awards to industry for the creation of good quality products.

     We need to  develop  models  to determine^ the extent to  which  source  reduction
and  recycling provisions can be built into decisionTtKat 'vrfmatie'.'****^,..,

     We  need  to do   a   major job of  identifying  what  toxic constituents  exist  in
materials moving  through  commerce, what kind of  harm  to the environment  they  may
cause, and  what changes can be made to make them recyclable or reuseable.

     If  we turn  to  the strawman  agenda, we  will  find  the  following  elements applied
to source reduction:   D and  E as well as  I,  J, and  L of Phase I.   There  were  none
under Phase II. All other elements dealt with recycling.
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 Source Reduction (Nancy Wolf)

      We ranked  the issues  in  terms of  toxicity reduction and  volume reduction.   We
 felt that toxicity  reduction  should be  the first  area  of emphasis and concern.   First
 of all,  there  needs to be  an  identification of  the hazardous constituents  of members
 of the MSW stream.   Right now we have identified  certain  things  in the category of
 household hazardous  waste.   We  know  here  and  there of  products,  either  stabilizers
 or  plasticizers  as  in  plastic  or   coatings,   etc.     There  really  needs  to  be  a
 comprehensive  list  of  what products and  which constituents  are in  the  MSW  stream.
 That study  would  also look at those particular substances.   Some have ideas  of  what
 the impacts of those particular constituents are on the  environment.

      The  second   area  is   clearly  the  encouragement  of  the  use  of substitutes  for
 hazardous  constituents.    This  is  an  area  where  there  was   some   debate   by   our
 subgroup  as  to   whether  or  not  the   development  of   such  substitutes  was   an
 appropriate  role for  the  EPA.    I  think the majority of the group  felt  that  industry
 should be encouraged to use fewer toxic ingredients in their products.

      We listed some  of  the ways in  which  we  thought those  accomplishments could
 be sped up.   First is to obviously have  the  Agency provide  a  guidance document.  It
 is  also  important  for us  to know there has  been progress.  We have seen that  this
 has become  especially  important in  the hazardous  waste area.   In  this case, we  need
 to   know   in  MSW   where   the   aspects  of  substitution  have   been   successfully
 implemented.   Certainly,  we then  need  to publicize  those  accomplishments.    A  little
 praise  goes   a long  way  by   serving  as  a  catalyst  to other  manufacturers  to  do
 likewise.  We wish that  there  would be more  meetings  where  people could come  and
 talk  that  would  include  the environmental and industrial sectors.   We feel that  the
 Agency  has  a vital  role  to   play  in  collecting,  documenting,  and  making available
 information  on  these  types of activities.    We  also  felt   that  there should be a
 comparative  analysis  of the nonhazardous  constituents  that  are being  chosen  because
•we certainly do not want to do away with  the lead,  in  our hurry,  for example,  and
 come  up with a  component that  is  going to  be  far  more  deleterious or  difficult to
 manage  in  the solid waste  stream.    Some  felt that in  this  analysis  we would  look at
 all  the  environmental   impacts,   including  the  cost,  so   that  you  would  really
 understand what you were getting and what the impact is.

      The  next area  is labelling.   There was  a  great feeling that  encouraging  change
 in  the  toxicity .area  could  be  accomplished  by having   manufacturers   label   their
 products  with the  fact  that it  was  a  hazardous constituent.    There  also  would  need
 to  be possibly some symbol.  It might not be  sufficient for  the  public in  all cases to
 have  a  list  of constituents  if   they  did  not  appreciate  that  constituent A  or  B   had
 toxic characteristics, so  there  might  be a  hazardous symbol  that could be used.   We
 heard from  Gerald  Powell about the work that Canada is  doing  on some  recyclability
 issues,  including  symbols  for  the  hazardous  constituent.   We  also  feel that labelling
 is  exceedingly  important  in terms   of  letting   the public  know the  durability  of a
 product,   i.e.,   its   lifetime,    and   whether   or   not  there   are   certain   disposal
 recommendations.    The  Agency has  as  a requirement,  right  now, wrapping household
 pesticides in newspaper to put  in  the  garbage.   I will bless the man  or  woman  who
 does  away  with that  recommendation.   I  just  do  not  understand how  that gets to  be
 a   recommendation   from  this   Agency  as  a  disposal • recommendation for household
 pesticides.    Again,  clearinghouse information  is  needed for  the  public,  for industry,
 and for government officials around the country.

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     In  terms of  volume  reduction, we  believe that two guidance  documents  need  to
be  prepared.    One  is  a  design  protocol.   Clearly,  we  must  begin  to  see that new
products  are  developed  with  integrated  waste  management,  including  waste reduction
and  recycling, emphasis  in mind,  and  consideration of the  impact of  that  product  on
the  waste stream  designed into  the  product  from  day  one.   There  clearly  is  work
underway.   The  American Society  for Testing and Materials (ASTM) has something
coming  up in  Toronto.   Ed  Carais,  from  the  Society  for  Packaging  and  Handling
Engineers, has  begun  to  develop  some  sort  of protocol.   We need  to get  these into
the  design  schools  and  used  by  companies  so  that   as  a  product  is designed,
opportunities  for  waste  reduction, for  recycling,  and its  impact on incineration   or
disposal are all taken into account.

     At   the  same  time,  a waste reduction  opportunity  assessment  manual  is  needed.
We have  one now that the Agency,  the RD&D people, have prepared, but  it  really  is
more an  opportunity  assessment manual  that  has  been done  for  hazardous waste.  We
feel a comparable assessment should be done for solid waste as well.

     We  picked up on the  issue  of  biodegradation  and  photodegradation.    We  felt
that  it could  equally  belong  under the  landfill area  in  this  particular meeting.   It  is
recommended  that the  study  should   be   far broader  than   was  proposed  in  the
strawman agenda.   It  should not  focus just  on plastics,  as  in the  strawman  research
agenda.    There  were  also  many  questions  raised  regarding  whether   this  was  an
important thing  that  should deserve some  quick  attention.    There clearly has been  a
growing  feeling  that  degradability is  excellent, and  since  plastics do  not  biodegrade,
supposedly  they are  bad.    Maybe  degradation  is  beneficial  in the  ocean,  but we
should look at  its impact  on  recycling.   Do we want  plastics to degrade if they are
going to  be recycled?   We  do  not  know  whether or not  degradable plastics  that are
put back into  use  as  a resin  will have  a negative  impact.   We also  felt that we need
to really  study the issues  of durability,  repairability,  reusability,  and remanufacturing.
We need  to  study  ways  to increase  these elements  in  our society.   Certainly,  this has
been  something  we  can   all. see:   less durable,   nonrepairable,  nonreusable   products
being increased in our country over the past few years,

     An  interesting  suggestion  was  made  under  repairability  that  we  could  possibly
design a  machine  so that  if you put a  product into  it,  it  would let  you know  where
the problem was.   You  could design components that could  be slipped in,  so  you do
not have  to go  back  to the  repairman.   In  other  words,  make repairability something
that  is  easy.    Right  now, we  have a  lot of rechargeable  cadmium batteries in the
rechargeable  appliances,  e.g.,  the dust  busters,  the  grass   clippers.    The cadmium
batteries   are  sealed   into  the  products  so   you  cannot  get  them   out.     The
manufacturers say  that  is  so  people do not  put  in a nonrechargeable  battery  because
some  explosion  may  occur.   It is a safety  element.   How  do we,  who  are interested
in getting that cadmium  out  of  the  waste  stream,  get  access  to  that  battery  when
the product  life  is over?   Somehow  that  particular product  must   be  designed  with
durability, repairability, and remanufacturability so that the  battery  can  be removed.
All these things need to  be  looked  at more  closely.   We need to look at the full
impact  of  durable  versus throwaway   items,  including  the   cost,   the   lifetime,  the
environmental  costs,  and  the  environmental  impacts of  producing   throwaway  versus
disposable products.  These were some of the key items.
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     The composting issue was something  that  was discussed by our  group.   We  felt
that we  need  to  know  the  environmental  impact of grass or composting   materials
that have  pesticides or herbicides  on  them.  We have  to  find out what the  impact is
on those items we are going to reutilize.

Discussion

Question:

     What  are   the  factors  driving  the   lack  of  attention   on   the   part  of  the
manufacturers  and   design  specialists  to   incorporate   waste  management  consideration
into products?   There  is  no  incentive to  take  these  into  account.   Did' you address
the incentive issue at all?

Response:

     We did  not discuss  that.  We were trying  to find more hard, technical  things  to
focus on, and already a lot of things that  we have here are  more policy  or  economic
analysis.  That  is one area where there is  a certain amount of  frustration in the  fact
that at the moment EPA  does not address this.   There was some talk  of a products
chart.   However, so  many of  the issues that we wanted  to discuss  did not  fit neatly
into the idea of  a  R&D  scenario.  Much of it  had to do with  policy, but I think as
time goes  on, all of the  things will  come  together  and be  addressed by  some  unit  of
EPA.   I think  we saw  from the strawman  research  agenda  that  there  were certain
things  that we  could  skip because  they are  being done  in  other areas.   Hopefully,
that information  is  being disseminated  widely,  and  EPA  may  help to  disseminate
information  about  research  being  done, field  studies, and  research  being  done   by
states and other jurisdictions.

     The first  thing we  are  suggesting  is   that  we systematically  assess exposure  and
risk associated  with  all  recycling opportunities   and products.    I think  we  felt  that
was  an  extremely important  point  because   sometimes  there is the idea  that  recycling
is always  best,  that recycling  is going  to   protect the  envorinment,  and  therefore  we
always  go to that  choice.'  There  are  a  lot  of unknowns  there.   There may  be  all
kinds  of things  about recycling that  we  need  to know  to properly assess  its  role
within  an integrated waste  management  system.   So  we  felt that  was  an  important
point.

     Second,  there  is  no  doubt  that  EPA  needs  to provide  a  vital  clearinghouse
function for  technologies,  for  all kinds  of information that  people  have  been  trying
to get  at  around the country.   What we   have now  is  localities and states  working
almost  independently,  although  there  is some  swapping  of information.    However,
there has  not been a real national  clearinghouse established.   We believe  this should
be  EPA's  prime  function.   Also,  EPA  should  do a study  of international technology
and  techniques  that  may  be  applicable, and put this together   in  a  systematic  way
that is useful to  everyone.    The  Agency   should  also  be in  charge  of  implementing
that information  on a  systematic  basis so everyone  can  begin  to  plan and  make
decisions  as  a national prerogative  and  national  priority rather than  state  by state  or
locality by  locality.   Also,  we believe that as this happens,  EPA's role  is to evaluate
and  in  some ways  prioritize  certain  systems that seem to  be  better  than  others  in
terms of solving  our waste management  problem.  This  is  a very firm  recommendation
that we assume is going to be implemented.

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     On  the  strawman agenda there was  something  on reducing  the impact  of paper
and paper products  on the  waste  stream.   There  is  a very long  list on  the  strawman
agenda.    We  took  that  list  and  added  to   it.     I  think  people  now have  vast
expectations  for paper  and  paper  products in terms  of waste  management.   However,
paper  is  not without  problems of its  own.   We  believe  all  of the  items  on  the  list
under  1.F to  be a  very important  part  of research  that  EPA  should undertake.   We
added  three other items to that list.

     One  would  be  to  research  the viability of  why the paper  industry says  it can
only  use  SO percent  recycle  content  in  making  its paper  products.   Is  that really.
true?  Why is it true?  Why is it not true? Just find out exactly what that means.

     Second,   research   is   needed   on   alternatives   to  chlorine   bleach  in  paper
production because that is obviously something that is causing problems.

     Third,   research  new   sources  of carbon  black  for  printing   ink   because   the
process in  itself  is  a  polluting process.    There  were  a  number  of things  regarding
paper and paper products that we thought were important.

     It is important  to develop  minimal  standards for the handling  of regulated waste
with incentives for  reuse  and recycling,  meaning  that as  we find  certain  wastes  that
are  problems  in  the  waste  stream or that must be specially  managed  or   handled,
minimal  standards for  doing  this  will be a  matter  of course.   Those   wastes  would
then be  regulated  under EPA's rules,  and EPA  itself would set the  standards.   Reuse
and recycling should  be encouraged  as  much  as  possible  for  any   waste  that might
have to be regulated because it has certain problems.

     We  felt  that  certain  projects  not being  done  elsewhere  would be  better  done
nationally  by  EPA.    For example,  battery recycling;  this  has  so  many  ramifications
that it would be an  ideal bit of  research for EPA.   It has  ramifications  in  terms  of
recycling,  in  terms  of the  fact that  some  people want to put deposits  on  batteries,
and that  they   are   believed  to   be a  problem   in  incineration   or   land  filling.
Consequently,  it  is  just one of those  things  that  needs  to  be addressed and settled
for everybody.   The use of shear shredding  was considered to  be a  very good  bit of
research  that EPA  should  undertake  because this  may aid the  work  and  investigation
leading to more and better recycling.

     The  feed  stock  in terms of  composting  needs  to be examined,  especially if  you
want  to  go  into  the food  composting  angle.   We believe that there should  be more
research  on  this.    Most of the work  that  has  been done  on  that  so  far deals with
gas and clippings.

     An  important area of research is the  classification  of  what  actually constitutes
a  MSW  problem.   This really needs  to  be  more  clearly  defined.    What are  various
problems  in   MSW?   Prioritization of  health  and  environmental standards in  terms  of
these   problems  are   needed  if  analysis  shows  specific  problems.    Obviously, some
problems  will turn  out  to   be  far  more   important  than  others.   Research is  needed
regarding  the amount  of  waste  reduction necessary   to  achieve  a   collection  savings,
i.e., how much reduction or recycling  is   needed before you  will  be  able  to  cut back
on  the  number of  garbage  trucks  or human  resources  needed.    This  is  what  the
Sanitation  Men's Union in  New York City is most afraid of.   They are making sure

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they  handle  recycling because  they  know  that if  New  York  or  any  other  major
municipality gets  into  recycling  in  a serious way,  sooner  or  later the  point is going
to  come  where  cost  savings  can  be  shown  in  terms  of  collection   routes.    The
question  is, is  there some kind  of model that  can be  set  that  shows  when one  will
be approaching that point to help planners around the country?

      There  should  be  a  field  study  of   the  general  composition  of  solid  waste.
Assuming the country is  structured so that  roughly the  same  types of  things occur
around  the country,  notwithstanding  differences  in  regions  and  differences  within
those  regions,  there  ought  to  be  some  kind  of  real-life  field  study,  not  just  a
literature search,  done  by EPA.  It would serve as a  kind of guide  or  benchmark on
waste generation  and its  composition so  that people  could begin  to plan  better for
what they  think they  may  do to manage  it and  how  much we could reasonably expect
reduction or recycling to ensue from it.

Question:

      Do we need data before we do our risk assessment for resource recycling?

Response:

      Well,  I  think it is  quite  possible  that  some  of our  studies will be  put  together
very  effectively.   If you  are going  to  do a systematic  assessment,  then probably  one
of those  points could  be the classification of- what  is really a  MSW problem.  I think
it is  quite likely  that anybody who  has  studied this  list  would probably  put  certain
things together.

Question:

      Did the group and  experts  in  your  group  discuss the type  of data that  may  be
available even on that particular subject?

Response:

      No, we did  not discuss  that  in  any  major  way;  so obviously,  if  anyone  has
information to  hand  in on that,  even the  lack  thereof  or the  sources thereof,  I think
that should  be sent in.
Question:

     What  about  research   into  either  incentives  or  evaluating
different approaches to get people to separate their wastes?

Response:
the  effectiveness   of
     We  did not  discuss  that, and all  I  can  say  from our  own  experience in  doing
programs  is  that  it is not a  problem.   I  think there  is a perceived problem by  many
people  who  have  not actually  done  a recycling  project,  that  somehow  people  do  not
want  to  cooperate.   All I can say  is  that  the  experience  of everyone that I  know
who has  actually  implemented  a program shows  that if you design it  in  a way that
makes  it  possible  to  be done within any  reasonable  way,  people  will  cooperate.   You
are never going to get  100  percent, but  the  participation rate and  generation  rate  of
the projects  that have  been  done,  that  I  am  aware  of, show a  very  high  willingness
to cooperate.

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Question:

     How many separations are reasonable?

Response:

     Well, as far  as  we  are  concerned, the best mark of  reasonableness is if you  can
do  it  just  as  you  do  your other  garbage system.   The  best and  most  successful
recycling programs  we   have  seen  are  those  that  join  in  some  way   the  regular
garbage.  You  put your  recyclables in a bag  or whatever,  and  then  the garbage in  a
place  that  is  either  very   close  by  or   immediately  adjacent to  that  where  the
recyclables go.   We  have done  this in  apartment  buildings and we have done  it at
the curbside—that  is  the  way which  makes  most sense.   This way you  do not have to
turn yourself inside-out  in order to  take  something to be recycled.   Dedicated people
of  course will  drive  all over town  and waste  a lot of gas  trying  to find a recycling
center.    I  do  not  think anyone  considers  that  to  be   the recycling   option  of  the
future.
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 5.2   Municipal Waste Combustion
      James Kiigroe, U.S. EPA--OEETD


      We  did  not  try  to  identify  any specific  organization  which  would  do  the
 research  program  that  we  were  talking  about,  nor  did  we  identify  any  specific
 amount  of money  that  would  be required to  fund  such research.   What we basically
 did  was  to divide  the  research into  a number of  different topic areas.   The first  one
 I will talk about is the health and risk assessments.

      One of the  problems  is that while we need information for  regulatory  purposes,
 we  also  need some scientific evidence  to  persuade  ourselves that  incineration is safe.
 Then  we  need further  information  for the public  to  assure  them  that incineration  is
 also  a safe  alternative  for solid waste  management.    We  looked  at  the health  and
 risk  assessment  area   and  saw  that  there   was  a  need  for   standardization   of
 methodologies.   By that we mean  that  a lot of  the  different  model  parameters  that
 are  put into  the risk assessment  models are not  used  consistently  around the country.
 Ten  different  people   may  be   doing   a  risk  assessment on  incineration  using   10
 different  types  of  model  parameters  or data inputs  for that  risk  assessment.    So
 there' is  a short-term,  high-priority  need  to  develop  standardized methodologies  for
 risk  assessment  and  incineration.     We  felt  there  must  be   some  sort  of  a
 clearinghouse   or   group  that  standardizes  what  is  acceptable   as   far  as  incinerator
 emissions.  This  obviously  is something that has  to  be done.   We  have  not  identified
 who should do it,  but it is a need that we have identified.

      We   also  have  to  do  research  and  to  develop  and  improve  risk  assessment
 methodology,  both for  indirect  exposure and direct  exposure.   There  are  a  lot of
 models for indirect  exposure.    Models  for  bioaccumulation  and  uptake  of  different
 chemical   compounds  lack  justifiable  research  information.    Therefore,   there   is
 research that  has  to  be done in  order  to  put together  models  that are credible.   We
 think this kind of research is  probably a medium priority.  As  far as direct exposure
 is  concerned^jthere—is^some  concern  about  the  techniques  that   are  currently  used,
 such'as  taking  a single  compound and looking at  its effect  upon  inhalation or  dermal
 contact.    A  better  approach would  be  a  bioassay that examines  the  whole  mixture,
 then  compare  the  bioassay  total-mixture  approach  to  the   single-chemical  approach,
 which is traditionally used.   We  think that this improved risk  assessment methodology
 would be more effective  in persuading  the  public  and ourselves   that incinerators do
 not pose too high a risk.

      There is  also  a need to  do  some degree  of environmental   monitoring.   That
 requires   measuring  emissions  from   incinerators,  not  only emissions  themselves,   but
 also  measuring  ambient  air quality around the  incinerators.   There  may  be some need
 for  looking at  things  like  dairy products;  however,  we  think that   potentially poses  a
 much  lower  risk  than  the  ambient  air  quality  around an incinerator.    One   can
 examine ambient  air sample bioassays and  chemical analyses, and   decide  whether or
 not  the  incinerators really  constitute a  risk.    Our  health-effects  people at EPA have
done this  to  some  extent  on  other  emissions  and   have   been  able  to   determine
 whether   or  not   these  things   really  constitute  a  high   or   relatively  low  risk.
 Additional  risk assessments  are  also  needed comparing  alternative   waste  management
 techniques,  e.g.,    incineration,   recycling,   and   all   the  other   waste   management
alternatives.   Finally,  a better  risk  assessment is  needed  for control alternatives  for
a given  incinerator.   For example, what  kind  of a scrubber is required in combination
 with  residual  disposal   techniques  and  the   types  of  technologies  used  to  control
emissions from incinerators?   Risks  from those  different  control technologies need to
 be examined.

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     Next,  we looked  at  the  problem of  waste  characteristics.    Obviously,  there  is
much  concern  about  the  impacts  of  different  components  within  the  solid  waste
stream  and their effects  on  emissions  and  residues.   This is a  high-priority  research
area;    We  think  that  specifically  we  have  to  address  the  problem  of  household
hazardous  waste  and  hospital  and  infectious  waste.    The  Agency  is  faced  with  a
problem if we are  going  to  regulate  municipal waste  incinerators.   That is,  do  you
include  or  exclude  wastes  such  as   household  hazardous  or   infectious   waste  in
regulation?   Therefore,  there is   a  high priority  for getting scientific information to
make decisions on how to handle these wastes.

     Technology  evaluation was   divided  into  municipal  waste  combustors  and  other
types  of combustors.    This  meant a  traditional  municipal  waste  combustor,  rather
than  sewage sludge  incinerators.    For  example, we felt  that a  high priority  was to
look  at  retrofit  technologies  for   controlling  emissions   from  existing  incinerators.
The  Agency   is   currently   evaluating  the   best   available   technology  for   new
incinerators,   and   we  think  fairly  good   information  based   on   those  kinds   of
technologies  will  be forthcoming.   However, when  local or  state  authorities  have to
make  decisions  regarding  how  to   fix   old  incinerators,  there   is  a  dearth   of
information on the  performance  of  different types of  technology in  controlling  trace
elements, acid  gases,  and  organics.    So  we  have  to  go  back  and look  at  retrofit
technologies.

     We  felt  that emerging  and  advanced  technologies also  deserve  consideration.  We
have  to  go  out  and  evaluate   these  because  the. public  basically  is  going  to  ask
questions,  such  as  should   we  use  this  technology  and  is  it environmentally
acceptable?    If it  does  not  get  some  type of credible  evaluation,  then  of course  it
will stay off  the  marketplace.    There  is  a  feeling that we  also have  to  do a better
job  of  bench-  and  pilot-scale  research.    There  has  to  be  a  fairly  good  balance
between research activities and   full-scale evaluation activities.   One  of  the problems
is  that  there  are  a lot  of  mechanisms  that  we  need  to  understand,  e.g.,   how to
control dioxin—is  it  a condensation phenomenon  or is it  an adsorption  phenomenon?
You have to  look  at  that  in the flue  gas  cleaning, in  addition  to  other  areas.    One
must  find out where  dioxins are being created,   how  to  prevent  their  creation,  and
how  they  can  be  destroyed  in  the  combustor.    There   is   much  research   and
development that has to go on in this area.

     We  also  felt that greater attention  has to be placed  on NOX  control  techniques.
While  NOX  emissions  from  incinerators  are not  a  large  national  problem, there  are
many  localities that feel  NOX control  techniques   should  be  required.   If you design
an  incinerator  ignoring the NOX emissions,  you may  get a  different product  than if
you try to optimize NOX  control and  organic  emission control at  the same  time.   A
case in  point  are  the  Japanese who  have optimized  their incinerators  for  NOX control
while   ignoring   organic   emissions,  whereas  the   Europeans  have  optimized   their
incinerators for organic  emissions control and  have  largely  ignored NOX.   There  has
to  be  some  middle ground, and  we  have  to look  at combustion and flue  gas  cleaning
techniques which will both control  organics and NOX along with other pollutants.

     There is  also  a  need to  do  a greater amount  of risk assessment  for   mercury
emissions.   That  is a  major  environmental  concern in  Europe, and we can  envision  it
becoming one  in  the  United States as  well.   There  is  a sense that some of  those
environmental  concerns are excessive and what is needed  is  to  go back  and  look at
how  much  of a  risk mercury  really  poses, and  then determine how you control  it
from the emissions of the incinerators. There has to be additional work in this  area.
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     Sampling  analysis needs  to  have a  high  priority.    There  are two components
here; one  is  the  continuous  emissions monitors, and  the  other is  the  operators  and
designers  of  incinerators  who   obviously  have  a  hard  time  keeping  these  monitors
online.

     Essentially,   many   state   and   local   governments   are   requiring  continuous
monitoring  of  pollutants, and  the operators  want  to  have more  reliable instruments.
There  is  also  a  need for  improved sampling  analysis  techniques  for  the  emissions
from the  incinerators and residues.   One of  the things we  really have  not done  is  to
look at the speciation of metals.  Generally,  when one measures metal  emissions  from
an  incinerator,  it  is  assumed  that it is  an  oxide  or  just  a  metal.  Essentially,  that
does not  tell anything  about its mobility  or  impact  on  the environment.   One needs
to  examine whether  it is a  chloride, an  oxide, etc.,  because  that  has  an impact on
how it moves  through  the  environment  and  how  it  is  taken  up  by  humans  or other
organisms.

     We also need to do a better job of looking  at four  specific  organic compounds.
We  essentially  have  not looked  for  any  of  the  nitrogenated  organics.   These are
generally  the  more  hazardous  ones,  and  we have not  looked  at  them in  past  test
programs.    We also  need  to  look   at  the   volatile   organic  compounds.    There  is
virtually  no   information  on   volatile   organic  emissions   from   waste  combustion.
Obviously,  an  approach   of  looking  at emissions  both  from a  bioassay  and  chemical
characterization point of view has much merit.

     There  are  other  combustors  that we  were  concerned  about.    There is  not much
information on  sewage sludge  incineration, and we must admit that the  members of
this group  did  not have  much  expertise in the  sewage sludge  area.   However, it  was
our perception  that  there is  not  a  lot of  information on  the  emissions  from  sewage
sludge  incinerators.   There  probably  has  to  be  more risk assessment  and a better job
of  characterizing  the  combustion  techniques   used  in  the   flue  gas  cleaning  devices.
Sewage sludge  incinerators  traditionally  have used  the  multiple-hearth  technology or
newer  technologies, such, as a  fluidized  bed  combustor and a  wet  scrubber,  which  is
not  as  good  for controlling trace  elements as it is for  organics.   We  believe  that  if
we  both  examine  the  technologies  and  have  tougher  regulations,  we  would have  a
whole  different set  of  technologies  used  in  municipal  waste   incineration.   We  also
think  that  this  will   be  a  growing issue  in  this country.   Tougher regulations would
force  us  to  use better   technology.    We  know  that  better technology  exists.    It  is
just that  we  have not   been  forced  to  use  it.   There  is also the question  of  tar
combustors  and  other  special types of combustors.   We need  to look at  the  emissions
from these  and try  to   assess  the risk  from  those  combustors  and  identify  whether
the technologies that are used in those types of systems are good or bad.

     Finally,  there are  the hospital  waste incinerators,  and the  Agency  is  going  to
have  to move  ahead  to  do  something  about regulating these.    The larger  ones are
similar  to  municipal  waste  combustors, while  the smaller ones  are  somewhat different.
We are going  to  have to  look at the combustion process  and  the flue gas  cleaning
technology  used in them.   Ultimately, somebody is going to have  to make a decision
whether  to  continue  using  these incinerators  or  some  other method  for  getting rid of
hospital waste.   One  of  the things talked  about was  including  the  burning  of hospital
waste  with  municipal waste combustors.   We  think  the answer is  probably  yes,  but
the types of combustor used and the conditions for  burning have to be laid out.
                                             85

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Discussion

Question:

      Did your group discuss the subject of performance standards for incinerators?

Response:

      Yes.    That  really goes  back  to  the heart  of the  Agency's  current  approach  in
having  combustion  guidelines,  and  there are  also  the  emission  performance  standards
for  incinerators.   I  did not  include  or  say very  much about these because  I  think
that it  is  inherent in  what we are doing.   I do not know  to what extent there has
to  be any national  policy for developing uniform  standards  for  incineration.   There
are  issues  such  as  requiring  operator  training  or  certification.    The  Agency  is
currently looking  at  these  types  of  things.   We  think that  there probably  will  be
requirements for training and certification of operators.

Question:

      Are you  saying  that as  far as  air emissions  are  concerned,  standards are  going
to be put on everything?

Response:

      We  are  involved in a  process.   Yesterday, we  said  we were going  to  propose
standards  in   November  of  1989  and   essentially  promulgate  them,  that  is,   finalize
standards in  December  of  1990.   So,  we are in  a process of trying  to put  together
standards for  a whole  host  of different pollutants  for  incineration.   This- is  on  the
emissions line.

Question:

      /  noticed  in  your group  discussion  you  came  up  with  a  list  for  sampling
analysis.   We have  metal •speciation and  organic  species.   Could  it  also  be the  intent
to validate these test methods on this particular stationary source?

Response:

      Yes.    We  are  setting   up  standards  right  now  using  methods  that  are not
validated.   However,  traditionally  the  Agency  sets standards and  then comes back and
sets  up  a  standard  method.    That  is  sort  of  backwards,  but  that is  what  happens
because  we  do  not  have  money,  resources,  and  time  sometimes  to  validate  the
sampling  method up  front.   You  do that in  the  process of collecting data  for setting
the standards and then, obviously, you hope that you have done the right thing.

Question:

      But you want to move forward in this with the intention of validating?

Response:

      Yes.

                                              86

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Question:

     And also in terms of methods development?

Response:

     That is right.   In  terms of validation,  the answer  is  yes.   I think  the point is
that we do not  always  have  all the  validated  test  methods  we would  like  to have
when we put  together  regulations.   We take some  of the test  methods  that  have been
on  the books as  standard test  methods  to be used  under  various  regulations.   They
are still not standardized.  That is a fact of life.

Question:

     What about  continuous  emission monitoring  correlation  of dioxins and furans and
things that cannot be monitored continuously?

Response:

     We  tried  to  identify  what  constitutes  good  combustion,  and  there are certain
things  such  as temperature  and CO  that  will give  an indication that  dioxins  should.
be  low.   There  is  no absolute certainty  that the dioxin is  going  to be  low.    There is
not  enough  scientific  evidence  right  now to draw  good  correlations  between  those
parameters that are available in dioxin emissions.

Question:

     Is that something we should work toward?

Response:

     We are  trying  to  work in that direction, but  we  do not  have sufficient  research
dollars.

Question:

     The point is, should that be. a priority?

Response:

     Yes, it should be a moderately high priority.

Question:

     Why did not you not identify residuals in the environment?

Response:

     Another  group  will  be  dealing  with  the  ash  if  that  is  what  you are talking
about.   We have  not really  gotten  to the ash, but,  in  my opinion,  there has  to  be a
pretty good interaction between the combustion and the flue gas, and the residuals.

                                             87

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Question:

      You  can  go  ahead  with  metal speciation,  but I  do  not think  that  the  bulk  of
the  health-effects  research  has  gotten  to  the  necessary  level   of  speciation.    For
example, lead  is lead.   We  do not  particularly care at  this point or  have enough data
on  whether it  is  qualified  as sulphide or oxide.   That is one  point.   The  second point
is  actually  a  question.    You  seem to  indicate  that  you  are  going to  try  to  keep
special wastes  separate  and  deal  with  them  separately.   Is there  not  a possibility that
sewage sludge could be co-incinerated, as could tires?

Response:

      I   think   this  is  especially  important,  particularly  in  the  area  of   household
hazardous  waste  where  the  waste management costs of dealing  with it as  a  separate
entity  are  astronomical.   I  agree  with  your  comments,  but  we  do  not   have any
information  about  those subjects  on which to base decisions  right  now.   This would
be a high-priority area.
                                              88

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5.3  Municipal Waste Combustion Residuals Management
     Carltoa Wiles, U.S. EPA—OEETD/RREL


     I  want  to clarify the  research  items.    We  did  not limit ourselves strictly  to
R&D  activities.    The charge according  to  the  agenda  was  to  look  at actions  or
barriers  that   were  causing   problems  in  implementing  a  management  plan  for  the
community, implementing a  reuse  technology,  and similar  kinds of  things.  Therefore,
we did not limit ourselves strictly to R&D efforts.

     Our strategy  was that  we will  rank  the  research  needs  or  activities  when  the
proceedings come  out,  so  that we  can rank  specific items  rather than  trying  to rank
categories.     The  problem  there   was  that   everybody  represents  a  different   need.
Some  are  interested  in  looking  at  reuse  right away,  but  others  are  interested  in
looking at  land disposal and what  kind  of  options  there are  because  that  is their
immediate need.  Therefore, we dropped any attempts to try to rank these.

     There needs   to  be a  document or  documents  containing  fact-sheet   type  of
information that is pulled together  as to where we  stand  today with  ash  management,
including   land  disposal,  reuse,  and  characteristics.    This   can  be  distributed  to
engineers,  designers,  the  public,  and so  forth so that  they  know  the true  facts
regarding  ash.   The  suggestion was that EPA should take  a  strong  leadership role  in,
this   area   whether   or  not   it   is   the   clearinghouse,   in  conjunction with   the
clearinghouse,  or whatever.   EPA  needs  to  have a  strong role so  that the states and
the  people  have  someone  whom  they  can  ask questions  of and who   will  provide
information.  This was number one on everybody's list.

     The  type of things we  talked  about under the ash  sampling and analysis  dealt
with  developing and evaluating  a  set  of sampling  procedures  that take   into  account
the  intended  use  of the sample,  whether  it  is  for regulatory use or  compliance,  or
whether  it  is for  a scientific-technical study,  or   other  cases.   There  appear  to  be
some problems with  the  techniques  that  are in existence  today.  There  is a  need  to
evaluate  these   techniques  and  to   further  develop  sampling  protocols   taking  into
account the   intended  use  of  the  sample.    Evidently,  analysis procedures  used  for
providing  true chemical and physical  characteristics  of ash  are lacking, and it  is felt
that  there needs to  be some work done in this area.

     Technology transfer transcends  all of  this.   This is  an item  that   needs  .to  be
considered  throughout everybody's   activity.   However, in  the ash  area it appears  to
be  a  special   need  and  we  identified  it  as such.   In  ash  handling the  discussion
centered on  the fact that we believe as  a  group that  there  needs  to be some  actual
sampling  done  in   plants,   during  transportation,   and"  so   forth,  as   to   potential
emissions,  etc.,  that  may  be  taking ' place.   There  is a  need  to  characterize  these  as
to whether or not  they  could cause potential  human health  problems.    In  addition,
there is  a  need to  provide  essentially  the  status of the  way  things  are being done
today  and to  show  good  operations  and  how they  have  been  handled.   Once  again,
guidance is needed  and must be distributed to the people who need it.

     We also   felt  we need  to pull  together  the available information  on  ash  toxicity,
bioavailability, and  biotoxicity.   As far  as  we can  determine, not  much has   really
been done in  this area.  There needs  to  be  a  strategy developed  on how you  handle
or look  at the  data  that  come out.   What  do  the  results  mean?    How   do  they

                                             89

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yP.rj^fc^p-.xVt.^g^iA^-.-
  compare  with other management options?   There was some discussion  in this  area as
  to  the  type  of information  that  we  are going  to  have  to have  in the  long run to
  convince  the public that  reuse  of this material  is  an  acceptable  option.   This  could
  be  a big-ticket item  and it could be a  long-term  item, but  there  needs to  be some
  consideration about  how  we can  do  this and  what  the information  means  once  it is
  developed.

        Under  treatment/reuse, we  essentially  decided  to  consider  treatment  and  reuse
  separately.    Treatment includes  treatment for  land  disposal and  for  reuse purposes.
  There  are   several  different  items  that  require evaluation  or  research under  each
  one of   these  categories.     For   example,  treatment   for  land   disposal  includes
  immobilization, chemical   and physical  stabilization,  and  other  solidification  activities
  and  on-site  and  in  situ stabilization parameters  such  as   moisture  optimization  and
  compaction  that  would be  required  in in  situ  stabilization  or  solidification activities.
  There were a  number of these types  of  things  listed related  to what  to  do with the
  ash in the landfill to reduce leachate, if leachate were a problem.

        Some  of the same items appear  again  under reuse.  Reuse also  includes  recovery
  of  precious metals from  the ash,  whether or not it is  in the  ashes  that come out of
  the facility  or  perhaps even in  the model landfills  that have been around the  country
  for  several  years.     In  all   these   things, economic  analysis  from  primarily   an
  engineering point of'view would be included.                                              ,

        It  is   recommended  that  a  CERI-type document  be  produced  for  technology
  transfer.   CERI is the Center  for Environmental  Research Information.   This  needs to
  be  done  in  different  aspects  of  the ash  sampling,  analysis,  treatment, management,
  etc.,  so  that  information  can  be  disseminated  to   the  public.   We  also  discussed
  producing a  fact  sheet  that would provide  a  rational  stance  regarding the  true  facts
  associated with ash management  because evidently the press and the public  hear  only
  the negative aspects, and not the positive side or the true facts.

        We  also addressed  institutional   and  political  problems  and barriers,  such as  the
  lack  of  a  standard  interpretation of regulatory  intent.    This varies  from  state  to
  state and region  to region,  as  do problems such as  liability.   If there  is  a liability
  problem  or  if  there is any indication of a liability problem  in the  future,  people are
  not going  to reuse this  material.   That  is  a  type  of institutional  barrier  that  needs
  to be rectified.

        Mentioned  earlier  was  the  need  to  produce   a  document   immediately   that
  essentially tells everybody what  the state  of the  art is and  what  the status is on  ash
  management. That was the number one priority.

  Discussion

  Question:

        Did  you  discuss all  ashes  together  or  were  ashes   originating  from  different
  sources dealt with separately?
                                                90

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Response:

     We  thought of  residual reuse  in  general, whether it be  fly  ash or  bottom. ash.
However,  there  was  some  consideration  about looking  at separating  the  ash so  you
could  treat only the  fly ash  and not have to worry  about problems  with combined or
bottom ash.

     We   decided   at  the   beginning   that   the   objective  was   to   provide  credible
information  so  that  ash  management  strategies  or  plans could be  implemented  on
community levels.

Question:

     One  of the ways to begin  looking  at  residues  is  from  the recycling  perspective.
Do you  think  that  this  type  of  program  could  be applied  to ashes  or  residues  from
other thermal processes?

Response:

     Yes.    There   are  residues  from  other  thermal  processes  of  other   thermally
degrading  waste.    However,  if  it  is  a   hazardous  waste, there  is  a specific  set of
regulatory criteria that you must be concerned with.              -                          ;

Question:

     No,  1 am talking about, for example,  ash from steel  recycling  and  ash from a
whole Host  of processes and industries.

Response:

     Yes,  although   there  might  be   some  specific  things   associated   with  a  very
specific waste.

Question:

     Was there any discussion of anything other than MSW?

Response:

     No.   We  decided at the  beginning   that their charge was the residues  from the
combustion of a MSW.
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5.4  Land Disposal
     Robert Landreth, U.S. EPA--OEETD/RREL


     When we started looking at  landfills, we made  the decision we were going to
address MSW, nonhazardous industrial waste,  and sewage sludge.   The things  that  we
are talking about today apply to that type of categorization.

     The  overlying  theme that came out when  we  first started to  discuss  this  was
the  fact  that  we  did not  necessarily  feel  we  had  top  priority.    Rather,  we  felt  that
land disposal deserves top  priority, but  we really did not  want to say that.  What  we
are saying, though, is that it should  have some priority.  It should not be last.

     One  of  the  waste  management  firms  indicated  that there  was  a good  potential
for  sharing,  or  at  least  identifying,  other data  that  might  be  available.   In  doing
some things,  depending  on the site-specific  project  or the  project  that  we   have in
mind, they may be willing to work with us.  We will pursue this.

     We  addressed  the  issue of siting.    We  looked  at  design.    We  looked  at
construction,   operational,   and  monitoring  activities.     We  looked  at   closure/post-
closure.   We  also had a category   for what we could  not shove  into  the  other boxes,
and we called it miscellaneous.
                                                                                         i
     Siting.    One  of  the  urgent needs right  now  is  to  define  what  the  waste
characteristics  are.   We  need  to know what is going  into  these  landfills.    We  need to
know  what  type of  site  is required.    Characteristics  of the site are  very important,
obviously.    We  find  that in  certain cases  people are  siting  landfills without  really
paying attention to some of the  criteria that one would normally look at.

     Vertical  expansion.    We  put this  down  as  a  high  priority,  realizing that  it is
relatively  site  specific.   If one looks at  people  on  the East Coast,  they  might think
that this  is an  urgent  need  because  they are  running  out of  landfills.    Activity in
this  area  would  help them substantially.   We  also  have  people  from Oklahoma  and
Kansas, for instance,  who do not necessarily share that same experience.   However,
we put it down as a high-priority category.

     Monitoring.   I  think  you will find  that  in just about  every case that we  have in
every  category,  monitoring  is  needed across  the  board, including  monitoring of the
particular sites.

     Design.    We  wanted to  look  at  extended  performance  of  clay   and  flexible
membrane liners.  There is some  concern that we  do not  know  enough about  these in
long-term  performance.     We  need. to   look  at  the  extended  performance of   these
materials that we are  putting into the landfill in the control technology.

     Leachate collection  and  removal system.   Again,   these systems  are   being  used,
but  they  are  probably not  designed  or  based  on any given  research  data.   They are
almost  designed  just  by  chance.    We   need   to  look  at  collection  systems,   drainage
gravels, geosynthetics, and similar things.   We  are starting  to  get  a handle  on the
geosynthetics.   A lot of  the   procedures  are  not  standardized.    A  lot of  the design
criteria are  incomplete.    The  overburdening  pressures that we  need  to be concerned
about  are  absent.   Also,  the  long-term  performance  of these materials is not known.
We  felt   that  these  things   really   need  to  be   addressed  and   addressed   almost
immediately.

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     Again, we need  to  be aware  of monitoring considerations  in  any  type  of design.
Monitoring  can go across the  board  in  terms of requiring just  a QA/QC  program, or
a specific set of individual things like the procedures for overall characteristics.

     Runoff  control.   We felt  that  runoff control  is  a need from the standpoint of
active  sites.   How  do we handle runoff control?  What  type  of controls do we need?
Does  every  site   need a  National  Pollution Discharge  Elimination  System  (NPDES)
permit, and so on?

     Gas  recovery.    Issues  that  need  to  be  addressed include  how you  design a
recovery  system and  the  characteristics  of  such a  system.    There is  probably  some
information that could be pulled together relatively quickly.

     Although  I  have not presented the  time  frames  during  this  presentation,  we
have identified  them and  hope that they would give some guidance to  the Agency in
addressing their  resources.

     Construction.    We had a  single  item:   to  better  define  the procedures.   This is
an  urgent  need.    We  find that we  can  sit  at the drawing board and   design  these
facilities.    We  draw  nice straight  lines.    We  say  that  material  in that  band  right
there has a permeability  coefficient of about  10~7  cm/sec.  It  has  a nice flat surface .
on  top of  which  we put a flexible  membrane  liner,  and  that is a  composite  liner.
However, it cannot be done in practice.

     We  do not know how to do  it  and we cannot tell  them.  We can show  them on
a drawing,  but  you  go  to  the field and  the contractors  cannot  put that  10 to  the
minus  7  into the  facility  because  they do  not know how to  do it.  We do not  know
how to tell  them to  do it.  We do not know what the  parameters  are.  We  think we
have a feel for it, but  it has  never been  verified.   We  have  never really  gone  the
extra step to do that.    We  probably need to back  up  and  better  define  each of  the
procedures  for  constructing a facility.   This  is more than just a QA/QC  problem.   It
has  to  be  a design  type  of construction  activity.    You really  need to get  in  there
and  tell  these people  how to  implement the  design.   Sometimes  it  is  going to  be a
retraining  tool  because,   in  some  cases,  we  are dealing  with  the  wrong  professions,
for  example, clay  liners  being built by  road  builders, and  there  is  no  disrespect
intended  to  the road builders.   We  have a  lot of good roads around the   country,  but
that  is  not the type of  facility that  we are  designing. There is  a different approach
to it.

     Operational  monitoring.    There  are  several  things that  need  to be  addressed
during the operational phase of a landfill.

     We  wanted to  look  at some  of the alternatives to daily  covers.   We  find that a
fair,  percentage  of the air  space   within  a  landfill  is  taken up  by the  daily  cover
requirement.  Are  there   alternatives  that  we can  use  to  minimize this?    Are  there
things that we can do to minimize the need for daily covers?

     Raoid  stabilization.     We  think  that  the  landfill—and   this  is  not   Agency
policy—should be  used as a bioreactor.   There  is some  thought now that, rather than
mummifying  the landfill—putting  it  aside  and  letting  it  sit  there  as  a time  bomb-
maybe  we ought to do something  with  that facility.   We have  got  it lined,  hopefully.

                                             93

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We have  got it  designed so  that we can  keep  it in  a nice environment.   Let  us  do
something  to that, let it work  itself.   Let  us  keep recycling  the  leachate,  do  the
chemistry with  it, work with it, let  it  stabilize so  that  if, in the  future—and let  me
remind you  I said "if—that  liner  fails, it will not pollute the environment.   This  is
something  that  we have  some  pilot-scale  information  on,  and we  think  it  is  a very
good system.

     Improved  monitoring.    This  is  a multimedia approach.    What  we are  talking
about  is  the instrumentation.   Does  that need  to  be  improved?    Do  we  need  to
improve particular networks?   What  are the  parameters?   People were  asking:   Why
do  we need to  have the  Appendix  8  sampling  and  analysis?   Are  all  of  those
necessary, or can we  back off  and monitor a  few indicators?   Again, this would be a
function of  the  type  of  waste  characterization  work  that  we  might do  on  the  front
end.

     Leachate reduction.   We  felt that there  are some  ways that might be  able   to
reduce  the  amount of leachate that  is being  generated  during   the active  life  of  a
landfill.

     Leachate collection and  removal  system.    We  are starting to  find   that some   of
these   systems   are    biologically   and  chemically  clogging   with  precipitates   and
biologicals.    We  need  to  address  this- issue  and  find out ways  of either-preventing
the problem  or  designing a  way  in  which we can go  in and  clean  the system out*
again.  Runoff control needs to be addressed  in this particular area.

     Addition of  sewage sludge  and  seotage.    There  is  a whole host  of things that
can be done here.  The question  for septage  is  whether it can  be put  into landfills.
Evidently,  from  the   discussions  that  we   had, there  was  an  indication  that  a  fair
amount of the states  do not  allow  septage  to  be  put  into  landfills,  and some of them
now are not  allowing  it to be  put  into  Publicly Owned Treatment Works  (POTWs).   It
creates a problem for certain parts of the country, and that needs to be addressed.

     Gas  emission and recovery.   Again,  this  is an  area  that probably  needs  to   be
looked at in terms of operational  aspects.

     Odors.   Obviously,  everybody has a  concern  about  the  odors.   Perhaps  in the
new landfills it  is not going  to   be  as much  of  a  problem because  of the  barrier
situation that most landfills   have,  but  at  least  odors  should  be  addressed.   We need
to be aware of this when we pick a particular site.

     Leachate evaporation with landfill eas.  This  is  our  first  MITE  candidate.   We
think that might be one  that is  immediately available  fer  demonstration  in the  MITE
program at a facility.

     Closure, and T, oostclosure.   We felt  that  there was a need  to revisit  some of the
older  sites to see  if  there  is a way  in which  we can close  those  to  prevent further
degradation.    Perhaps  we  would  have to  do  something  else  with  them.    In this
regard,  we   need  to  look at that  and  demonstrate  that  those  systems   are  different
from  the  new systems.  We  need  to  convince the public that the new systems  can   be
designed so that they will be nonpolluting.
                                             94

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      A big  question  came  up of, when do we  close?   Maybe we should not  put the
final  cover  on   until  the   15th   year  of  the  postclosure  period.    If  we  examine
recirculation,  we  need  to  look at letting  the landfill work biologically.   Let  it  start
to  settle  and  subside,  and so  on,  and then  in  a few years,  after everything  has
happened,  put that final  cover on.   And then  that  cover  should be  long lasting and
durable.

      Corrective action.   It  is  one of those. things that  we  felt will  probably go  along
with  some of  the older sites.   Corrective action is  somewhat  of a  plume management
sort of scheme.   If we look  at  some  of the older facilities,  we must  know  if  odors
are a problem.

      Miscellaneous.   Case  studies  was  top on our list.   We felt  that  there is  a lot to
be  gained  from  case studies,  and we  need  to  do something  immediately to  convince
the  public  that  these  landfills can  be used  safely,  and also  that  they  are going  to
remain  a part of waste management.   In  the  future we are  going  to  have  landfills,
and so  we  need  to have  some type  of convincing argument for  the people.  We  need
to  do some  case  studies  to find out a variety  of things.   Are  the systems working?
What systems are not  working?    If they  are working, why did  they work?   If  they
are not working,  why  not?   Were the  designs wrong?   What can  we learn in terms  of
the  degradation  rates  other than what we  know  now?   So  we  feel  that the  case
studies  can  provide a  wealth  of information,  and this is a  very  important,  urgent
need right now.

      Characterization   of   the   waste.     We  wanted  to  stress  the  importance  of
characterizing the  types of wastes that are going  in.

      Technology  and  information transfer.  There is a definite need to get something
out  immediately  to tell  the  people  that here  is  what you  can  use,  here  are  the
systems that can  be designed,  here are the techniques that you might want to employ
at landfills,  and  here  are  some  good things  about  them.   We  need to  identify where
we are doing  research, and at least tell  the  people what we  are doing.   Do  not try
to hide  it right now.  Let us get some good tech transfer information out there.

      Exposure  risk  assessment.   Again, we felt  that there  is a need  to  do this.   We
owe  it  to  the  people  working and  living  around  landfills  to  look at  that  particular
assessment.

      Ash,  sewage sludge,  and' hospital/lab-tvoe  waste.    Research on  those is needed
because it is in the public's view right now.

      The  question came up of model  fill or the ATAD.   This is  an urgent need.   I
think that model fills provide a lot of information to city managers.

      We also felt that there could be  a need for a national standard  for compost.   A
lot of people do not  know when compost is done, that is, when it is ready to use.

      We need  that  standard not only for "when it  is soup," but  also  how we can use
it and  what the  benefits  are  of  using  that.   We  think that  is very good information
to have.
                                             95

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    .  We  considered  source separation  and  preprocessing  before  landfilling waste,  to
see if that would improve the overall characteristics of operation of the landfill.

      Then  we  identified two  additional items  for the MITE Program.   One is landfill
mining.   There have  been some  proposals  regarding  this.   We  have  some  information
that  suggests  that  there is a technique  that allows  us  to mine  these  facilities  for
some  of  the  metals  or   other   materials,   or  use  some   of  the  compost  or  other
degradable  material  as  interim  cover. This  fits  very  nicely  with  the  recirculation
effort in that we would use a bioreactor for  a  period of time and develop a working
system so that we could have a continuous site.

      Pretreatment.   This is a  technique,  wet  pulping,  that  the  people  in  England are
using right now.   They think that they  are getting  better  air space  utilization  within
the landfill.

Discussion

Question:

      Hans  Bnater,  of  the  Swiss  Federal  Water  Pollution  Institute, believes  that  any
more than  about 2  to  4  percent  carbon  in a  landfill  is  very  dangerous  because  you
get a bioreactor, and a lot  of  bad  things happen.   I  believe that  what  is  in these,
landfills  is not  waste, but  rather  it is stuff that is incinerated.  Do  you have  any  idea
about trade-offs  of the  kind of  a policy,  for example,  if  we went  in the direction  of
having something that is not a bioreactor?  Is a bioreactor all good or all  bad?

Response:

      No.   I think  that   the  potential  use  for  a  bioreactor  is  more  or  less  site
specific.   With  the total  volume  of  waste,  obviously,  it  would  not work.    I  do  not
think it would work  for places like  New York,  for  example, and  Wellington, Kansas,
probably  does not  have enough waste with which  to build a reactor  in  20  years.   I
do  think  that  there   are  locations around  that  are  suitable.   I  think that  what we
have  to do  is  to develop  technology  or individual techniques and  approaches that fit
categories of cities.

      One  thing  I forgot to mention  in the tech transfer.   What  we  would  propose is
some sort of expert  system approach  for the  city  manager  that  would  say, "Here  are
your  options  for  managing  your waste.    You can  either incinerate them  and  go
through  that  type of  scenario, or  you can  landfill them and  go  through  that type  of
scenario.   You  might want to  do something  else, but look at  all of  those options."
He knows  what  his  individual characteristics are.   He Knows what costs he can  play
with, and so on.   He then puts  that  information into the  system,  and it comes back
and  gives him his  best options,  including  costs.   This  would  allow him  to  make his
own decision.

Question:

      /  guess  my  question  was   that  the   Swiss  are  saying,   "We  shall  not  landfill
anything  except  the  mine waste,"  and   anything  which   could  potentially   form  a
bioreactor,  they  say   is   not  acceptable.     So  everything,  essentially,   has   to  be
incinerated.

                                              96

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Response:

     Well,  our  pilot-scale  information  would  say  that  it  is  a  doable situation,  that
there are some  benefits to be  gained by it, especially  when you  compare that to the
mummified situation  of a  landfill.   Now,  maybe  they  are thinking  of a  mummified
case where  in  the  future,  if  something ruptures  or  the  integrity  of the  system  is
breached, there  is a problem.   I think  it is  a case of land  availability.  The Swiss do
not have much land, so they want to  minimize their land use.

Comment:                                     •

     It  would  be really nice  to  go  out and look at old  landfills,  to see what the
pollutant  potential  is  from   those   versus  new   landfills   which  have   all   this
engineer-controlled  technology  associated with  them  to  alert  the  public  out  there
that a  landfill  is  not  necessarily an open  dump, but  an engineered  site  and  as  such,
that there  are  "benefits" to  be  derived from a new  landfill  versus  an  old  landfill.
Where  are  the  data  to show  that there are  improvements in  landfill design in the
sense that there are fewer pollutants being generated?
                                              97

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5.5  Municipal Planning and Waste Management
     Tniett DeGeare, U.S. EPA—OSW


     We  tried  to focus  early  on  research  that would  help  local  waste  managers  in
dealing with  the  problem  of  everyone  wanting  them  to  pick up the  garbage, and
nobody wanting  them  to put  it  down.    We looked  at the  current  Federal  statute,
which   puts  the  primary responsibility  on  local  and   state   governments.    We  also
looked  at  bills that  are pending in Congress  and  the  fact  that  this situation  is  likely
to continue.    There  is  not  going  to  be  a  Federal program that is going  to  come  in
and  solve  the  problem  for  the  nation.    Rather, local  government working  in  a
private-public partnership is going to continue to do the job.

     We quickly  came  to a realization that we are not  talking  just about engineering
research and  technology;  we   must  also  address   economic  and policy  analyses  that
have  to be  dealt with  by  local  waste  managers.   What  we  all  talked  about were
mostly  Federal roles;  that  is,  research that  seems  to  be  appropriately  conducted  at
the Federal level to serve local waste  management.

     The  number one  need that surfaced  was  guidance to help solid  waste managers
evaluate alternatives,  including simply what  questions  they  should  be  asking  and
where  they can get the answers.
                                                                                        •I

     There is a  need  to develop  basic  information on costs,  benefits,  and risks  on
each  of   the  technologies   that  we  have  been   talking  about,  including  recycling,
composting,  waste  to   energy,  and  landfilling.     This   should  be  done   on   a
material-specific basis so  people can  decide  at a  local  level  whether  they should  be
recycling  glass, whether  plastics  is  something that  is appropriate for  them to recycle
or something they should be pulling out of their  waste stream.

     There  is  also   a  need to  look  specifically  at special   waste streams,  such  as
household  hazardous  waste,  and decide  whether  there  is  a   value  in collecting  that
material separately or whether  there is some other  better  way  to  handle  it, such  as
with  latex paints.    Is  there  a  better way to handle   those  than  to  go  through  an
expensive  collection  and  treatment  system?   Medical waste  was  also brought out as  a
special area of focus.

     As others pointed  out, there  is a lot of information  that  the  Agency, in concert
with states and others,  developed back in the 1970s that still  could be of value.   We
ought  to  be looking  at dusting some of  this information off  and  recycling that back
into the system to try to  help local waste managers.

     There is a  need  to focus on siting  and  get  information  out  to state  and local
government  officials  about  what  works  and what  does not  work,   and  to  look  at
incentives  to  try  to ease  the   siting   burden.  There  was  also a  discussion  on  fee
systems and  user fees,  and  ways to get people  to  have  a more  personalized ownership
of  the  problem  that  they are  creating as they  produce  waste,  and  how  better  to  get
that cost back to the waste generator.
                                              98

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     We  talked  about planning  and the  need  to  provide state  and  local governments
with  better  characterization  techniques  so  that  they  can  determine  what  they  are
going to  be dealing with  and know how  changes in  the waste stream, such  as  those
caused  by pulling out a particular component  for  recycling, might affect other parts
of their system.   The EPA  should be providing information; it  should be a  source of
information, providing accessibility to and facilitating the exchange of information.

     The last point I would make would  be about capacity planning.  We talked about
the need to  look,  not just  at  the  MSW  stream, but  also  at  the  huge  nonhazardous
waste,   industrial  waste stream  from  a couple  of  perspectives:    one  being  economic
development and  the  desirability of a  community to  want  to  continue to serve  their
businesses  and  industry  and  to  be  able  to accommodate that  waste  stream,  and the
other to  plan for  capacity  and the possibility that some  of  those  wastes  might  be
diverted into the municipal landfills.
                                             99

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                              6. GENERAL DISCUSSION
Question:

      We  really  did  not  hear  in  the  proposed  research  agenda  a  great  deal  of
emphasis   on   understanding   the   biochemistry  of   landfills   in  terms   of   better
management,   i.e.,   whether  gas   production  can   be  beneficial,   whether   enhanced
degradation is desired to minimize leachate production, etc.

      I  know from  reviewing  degradation  studies  that  there  is an apparent  movement
in this  country  to  really  understand the  chemistry  of  landfills.    In  addition,  we  are
having   a  continuous  discussion  with   members   of   industry   regarding   household
hazardous waste.    We  need  to  know,  what  happens  when  you  put  these  into  a
landfill?  How do these contribute to constituents found in the leachate?

Response:

      In  other  words,  is  it important  to  know  from a  landfilling  perspective,  in  terms
of the  adequacy or inadequacy of  landfills,  where the various pollutants  come from?

      I  think that  the use  of  a landfill  as a  bioreactor  is  an  all-inclusive  type  of.
program  in  that we would be investigating  the kinetics,  the  degradation  process,  the'
end-products  from  those  processes, along  with  a  variety  of  things  under  that whole
area.    For  example,  we  would  look at  the  addition  of  sewage sludge  to  enhance
biological  activities  or   use  chemicals  as  the  solvent in  the  recirculation  area  to
maximize  the  teachability  for  the  removal  of certain  pollutants,  and  then  fix  those
pollutants in another  manner.

Comment:

      The  point was not  clear.   I  assume  what  you  are  talking  about is  looking  at
different  strategies  for using   the  bioreactor  concept.    You  can  take  one  concept  of
maximizing bioreactivity  so that over  the  period  of  time when  you  have  a leachate
collection and control system, you are getting rid of almost all of the bad  actors.

      If one  takes the  opposite approach, which is to  minimize the  bioreactivity,  then
while you are  looking at the. landfill for  the next  100  years,  there   is no problem.
However,  later  on,  in  ISO  years,  bioreactivity  builds up  and  there  are   potential
problems  that  you  cannot readily solve.    I think  there  is an  analogy  between that
and  acid  mine  drainage.    There are a lot  of old  coal  mines  out  there, and  they still
cannot  fix the  acid mine drainage  problem because  the  biological  activity  is below
the ground.

      Therefore,  it might  be  better  to  maximize biological activity  over a short period
of  time,   get   rid  of  most  of  the  bad   actors,  and  then have a  relatively  lower
reactivity  rate   over  the  long  haul,  rather  than  trying   to  suppress   the   activity
initially and  then  have it build up  later.   I do not know  if you are doing  research to
look at those.
                                              101

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     Hundred-year-old landfills are still there.   The materials  are still there and very
discernible; they  are  not degrading  because  they  were  put in  a mummified  sort  of
situation.   When  the  integrity of  the  controlled  system  is  breached,  then we  have
another  problem, and  that  is  what a lot  of Superfund  sites are  about.   We  do  not
want to do that.   We  want to make  sure  that whatever we do  in using the landfill as
a bioreactor is an  end system.   In fact, we would like  to  reach the point where  we
can  complete  the  cycle  in  10  years,  and  after  10 years, the  liner  just  disintegrates.
We  would not have  to worry  about  a cover system  that will  last forever.   We could
just  let the  leachate  loose  through  the  ground  and  not  worry  about  polluting  the
groundwater.

     That is the kind of concept that is in the back of our minds.

Response:

     Just  to  reinforce  this,   let   me state that  one  situation  is a  closure  that  is
perpetuity.   Let  us  assume, however,  that  the  closure  integrity  lasts  a finite  period
and  it is 30  years.   I think  there   is an overrunning  consideration  that  perhaps it
would be  prudent to  remove  potential contaminants in the time  frame  where we  have
a  responsible  party,  and  get  the  landfill  to   a   form  that is  not  only  biologically
stable, but is also reasonably safe from the standpoint of future contamination.

     If  there  is a liner  system that  will work  in  the 30-  to  50-year  time frame,  let
us make use  of  that and  also  the opportunity  where  those  pollutants  can be  purged,
treated,  and  removed,  so   that  future  generations  do  not  have  to   be  the  ultimate
recipients of these.

     So  the   consideration  here  was  not  only  on  the  bioreactivity,  but also  the
structural stability and the gas migration.

Comment:

     It  seems to  me that  most  everybody is  putting everything  in  plastic  bags these
days,  wrapping it  up  and  throwing  it  away.    That  is  what  ends up going  into  the
landfill.    Is  it  practical to  think  of using  rhe modern-day  landfill  as a  bioreactor,
when  everybody  has  their own   little  encapsulated  goodies?    There  is  a  strong
interest  in bioreactors,  and  that  is  why  it  was   listed  as  a  research  area.   Recent
studies show  that  excavated waste  9  years old still  contained  chicken  with meat  on
the  chicken bone  and carrots  were orange  in  color.   They were wrapped  in  plastic.
Therefore,  the plastic bag concept  or  use  of  plastic   bags in  landfill environments
appears to go against the grain of using  landfills as  bioreactors.

     There  are  air   and   water  going  through  the   site,  so   you   can  maximize
bioreactivity.    This  means  you  have  to get people  to  stop using plastic bags.   An
interesting   research  question  is  whether  that   is   really   desirable   from   other
perspectives.

     One  additional  point.   At  the  University  of Arizona they  have  looked  at  the
constituents  that  form the  waste  stream.   They  have analyzed  the  pollutants  in  the
pesticide  bottle that  is thrown out, and they  have analyzed the  pollutants  that  are in
the waste medicine bottle, and in other  things like that.


                                              102

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      So  we  basically  know  what  constituents  are  in  there  from  the  standpoint of
liquids  that are  in  containers,  and  from  looking at all of  those containers we know
that  there  are hazardous  wastes  that  are  in  the  waste streams.   Therefore,  we  have
a  handle  on   the  characterization  of  the  leachate  or  the  liquids  that  are  already
inherent in the waste stream.

Question:

      This is  a question  of  clarification for the source reduction  and  recycling  plans.
There was an emphasis  on  hazardous  constituents, but  I  did not hear any discussion
on  hazardous  concentrations  and  the  whole  issue  of  toxicity  independent  of   the
inherent hazardousness.   Is your  approach  basically  saying  that if a product  contains
any   level of  a  constituent  that  is considered  hazardous,  then  there  needs  to be a
regulatory  program  directed  at  minimizing  that,  or is  there an additional  question
that   needs  to  be  asked   of  the   potential  accessibility   of  that  constituent  in   the
commercial  system,   whether  it  be  in  the  waste  stream  or  whether  it  be  in   the
product?

Response:

      I  think that there are  a few  forces  operating.   Some  forces  say that we should
not rely  on man  as  he designs,  operates,  and  regulates black boxes or systems in  the .
solid  waste  arena, rather  that  we  should  get  toxins  out  instead of  relying on   the
system  to  deal  with  them.    There  are  people   who  are  offended  by  hazardous
constituents.   There  are  also people  who  are  now using  that element as  a tool, a
weapon, a  big stick  against the siting  of  a recycling facility,  or an  incinerator,  or a
landfill.

      This perception  is  certainly  driving  a lot  of  activity  and  action.    We do   not
have  the  quantifiable  data.   We  just  do  not  know   what  the   real  risks  or health
effects  are.   In the absence of that data,  I am afraid that public  policy  decisions  are
being made,  and  we  are  getting people's  concerns,  fears,  or even  basic  attitudes  on
what  is right  and wrong for  industry  to do, or what burdens they are willing to bear
rather than a  risk-based  or a health impact decision.  I do not  know that the data--
even  if you  begin  to  collect  them, I  think it is  probably  too late—can  change  that
momentum.

Question:

      fs the  recommendation  coming  out   of   the  group  that  EPA  should  make  an
attempt at  defining  whether or not  just the existence  of the  constituent  is a  problem
in itself, or  whether there  is some  definable  standard  that  might allow  you to accept
some  of the constituents?

Response:

      There is a  duality  here, I agree.  You have  the forces  that  are  saying,  "Get  the
stuff  out,"  and at the  same time also asking  for  more  data to quantify  what  the  real
impacts are.
                                              103

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Comment:

     One  of  the  groups  was  talking  about  the  lead  and  cadmium  paints  on  white
goods, for  example, and  the  question  of whether that poses a  real  hazard  or  just  a
perceived hazard.  Just because it is there, it is a problem.

Response:

     Well, that is the same issue  everywhere.  It is  the same issue with ash.  What I
think is being said  is  that  in  the absence of knowledge of  whether  it is a  problem,
the fact that  a hazardous  constituent is present  tends  to  make  people  say,  "Well, we
need  to  err  on the  safe side."   I am not saying that we are getting  ready to regulate
white goods or anything  else;  on  the other  hand, this is the kind of thing that is  of
concern.

Questions:

     So the white good stays   in  the landfill where  it  starts  to  rust  and  then goes  in
the groundwater. Is that a problem?

Response:

     It is going  to  rust,  but  whether  or not it  migrates depends on  what form  it is'
in. However, it is in the landfill.

Question:                    •              .

     So now  do  you  have  a  hazardous  waste  site  on  your  hands  because it has
hazardous waste in it?

Response:

     I do not know.  Do you?

Comment:

     Solely  because  you   took  an  overly conservative  approach   to begin  with,  there
was  no incentive  for anybody ,to recycle.   The  crux  of the  issue is  toxicity,  and  your
whole  approach to the  problem of toxicity  is that when  in  doubt, call it toxic.  We
are down to parts per billion of everything.

Question:

     Yes.   Do you  think  it is  public opinion  that forces that kind of decision in  your
mind set?

Response:

     No.   I think  it  is   the chicken and egg thing,  where  you guys have  started it
and the public  picks up,  and it goes back to you guys, and it goes right back in.
                                             104

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Comment:

      I would  add  that the  household  hazardous  waste  collection  programs, per  se,
take  a variety  of forms, but  certainly try and deal with  the  past.   All  the jawboning
with  industry,  the  education  of  the  consumer,  et cetera, is  trying to  deal with  the
future.   Those  are nonregulatory  approaches  where you  try  to  educate the consumer
to  properly  dispose  of that material rather  than pour  it  down the drain or put  it  out
in the backyard.

      You are  trying  to  encourage  them  through  education  to  buy  alternatives  or
encourage the  manufacturer  to  manufacture  products  without  hazardous  constituents.
Those are not, in that respect, regulatory attempts.

Response:

      Yes.

Question:

      With respect to  recycling,  I  do not think  I  have  heard  anything concerning  the
markets   or  evaluation  of  potential markets.    What  would  happen  in  the  event New
York  City began  to recycle 25 percent of its  waste?   What  would happen  to the  glass
market, the  paper market  in the  Northeast  area?   Some  type of  guidance as  to how a-
market is going to accept this is needed.

      In  a similar  vein, with  technological  improvements,  could  we  improve  the size of
a  market for a given kind  of material,  paper, for example?  If we could find  better
ways  of  separating  or  de-inking  or  taking  out  dyes,  etc.,  could we improve  the  size
of a market for certain materials, like paper?

Response:

      You will find  discussions in the record on  markets.  When  you go  into that, you
will find  that  this  is  one  of  the big issues.   However,  one of the key  observations
that was  brought  up  was  not  to  be  guided  or misguided by  the sense that you  have
to  have   a  profitable  system  for  recycled  materials or  for  recycling to be preferred.
It might be a necessary thing to meet other community needs.

Question:

      There  is a  point here,  because  our group did discuss  backup methods at length.
What  does one do if the market fails and you are stuck with this  waste?

Comment:

      As   a  matter of fact,  shear-shredding  actually  should  be just shredding, because
a shredder can be  an integral  piece  of equipment that  will  enable a community  to  do
something with paper or plastics  that have  failed markets for recycling.    A shredder
can  be used for  doing other  things  with  that  material,  shredding  it  first,  and  then
doing  other  things  with the  material   Markets  are  always  going  to  rise  and fall.
You can develop some kind of strategy.
                                             105

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                                                                                         <-s,*l^s^~i*-~*:" --••
Question:          .

     /  have  not  heard  any  discussion  whatsoever  about  what  may  be  one of the
major risks with  solid  waste, and that is bacteria  and  virus. We know that if  MSW
does  not  get managed,  it starts  spreading bacteria  and  virus  around.    Short  of  war,
poor  solid  waste  management is  the  leading  cause  of  death since the  beginning of
time,  if you  remember the plagues in  Europe.    Why  does nobody seem to care  about
the pathogens  in  waste  and  ways  to  reduce  the movement  of  those  pathogens  into
the environment?  They are there.

Response:

     There has  been quite a  bit  of work done at the  National  Center for  Resource
Recovery.    There was  actually  an  ASTM subcommittee  that  was  involved in  health
and safety  aspects of  MSW.   In  Ames,  Iowa,  quite  a bit of work  continued in  that
area,  sampling  in the  plant  and  in  an  area around  the plant.    However, I do not
know that  they  ever really identified any major problems  with pathogens  in  the solid
waste that would cause serious health problems.

Question:

     Maybe it  is  an  issue that  needs  to be looked  at  again.   Do  you  ever  want to
correlate that flu  that  is  going  around with  the fact  that  maybe  the garbage  did not
get picked up that week on time?

Response:

     We did an  analysis years ago that  began  with pathogen or  virus  survival in the
municipal  landfill.   They did not survive  in   the  landfill  leachate, and  the  survival
time was very  low.   Of course,  what has happened since then is  that  there has  been
an  increase  in  disposable  diapers  that  have  come  into the  landfill,  and we have not
done any studies on that.

Comment:

     That would be a fun job to work on!

Comment:

     Part of the reluctance  of our  group to go into  all of these policy or  economic
analyses  was due to  the thinking  that  they  might  fit  in  some other part of the
Agency.     So  we  just  stayed   away  from  market  development  type  of  research,
although everyone would  agree  that* is  a necessary  element  in  terms  of what  and
where to recycle.
                                             106

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                             7. CONCLUDING REMARKS
                  John Skinner, Acting Deputy Assistant Administrator
                                   U.S. EPA—ORD
     Thank  you all  for your participation in this 2-day  workshop.   It is obvious  that
you  have  worked  very hard.   The list of  research  areas  that  you  have put  together
is very impressive.     It  is really  overwhelming  just  to  see  the length  and  the
sophistication of  the  important issues  that  we  have  to deal  with, and there  have
been  a lot  of  good  suggestions.    Let  me tell  you  what I  think the next  steps  are.
They are really  the  next steps  for the  EPA  people.   I  have questions about each  one
of these,  and I  think we  need to  go back  over them and  ask  the following types of
questions about every item that is on these lists.

     1. In   what  areas  should   EPA   be   conducting   research   to  understand  the
        fundamentals?

     2. In what areas should  we be evaluating private sector activities?

     3. Where  are we  talking about  the need for EPA  to  simply  put together  existing
        information  on the  state of  the  art  and package it in  documents that people
        can use?
                                                                                       ;
     4. In   what areas should  we establish  standards of  good  practice  that  can  be
        used by state agencies  in  overseeing  and  regulating  activities  at  the  state
        level?

     5. In what areas is it appropriate for EPA to do actual development work

     I  would like to go  back and  look  at  all  the  workgroup recommendations  with
these points  in  mind and  then  lay out  a  plan that would extend  over a 5-  or 7-year
period.    I   think an  intensive  effort and commitment  are going to be  necessary in
order to answer some of  these questions.   These questions  are  the same  questions we
were  asking  5   or   7  years  ago.    There are  some  new   questions, but  if  we  had
conducted  the research necessary  to  answer  the previous ones,  we  would  be  farther
along  today.    We  need  to  lay  out a research program  that  will  extend  over  that
period of  time,  resulting  in  both short-term  and long-term  outputs,  and  see  what  sort
of effort we are  talking  about on  a national  basis.    We  need to work  that  through
the Agency  and through the  Congress.  I  would  like  to invite all  of you to  make the
same  presentations that you  made  today   to  our Appropriations  Committee when they
consider this next year, because they are  the people  who are really going to  have to
agree to proceed  in  this direction.   These are the next  steps, and I  see  us coming up
with a  national R&D  program over the course of 6  months or so.   We should  suggest
research that needs  to be  done  by  others  as  well as  by EPA.  We should define  what
EPA's  role  will  be  in stimulating  that research,  and  what research the Agency  will be
doing.    We must bring our plan  forward to the  Bush Administration  to make it  a
priority and try to get the support we need to get the research done.
                                          107

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                           8. CONCLUDING DISCUSSION
Comment:
     Regarding the concept  of a  clearinghouse,  there  should be  a two-way exchange
of  information.   There is an  awful lot going on out there.   For  example, CONEG,
which  is the  Conference  of Northeast  Governors,  held  a workshop  regarding  siting
methods  analysis  in order to try to show some of the  trade-offs and how one  goes
about  siting in  a more  equitable  manner.   I  would  also  suggest  this  in order  to
understand some of the environmental impacts.  A good  example of this  can be found
in  two  completed documents:    one,  in  the  paper  and  paper board  industry,  1982;
another  one,  in  the  steel  industry,  again  1982.    These   were  effluent  limitation
guideline documents.

     There  is  a  lot of  information  in  those  about the  effluents and  emissions  from
certain types of recycling  facilities.  Ordinarily,  you probably  would not  go into  that
because  it is not in the OSW  or OEETD.  You  are going to  find that  in  the  Office
of Water programs.

Response:

     Let me just say that the  Office  of Water and  the  OAQPS, along  with  OSW,  will
be involved with this oreview.

Comment:

    • I know this meeting  is  not  really the  forum  for talking  about  the economic
aspects of these issues,  but  I  would like to  point out  that  our nation's entire  export
economy  depends principally  upon  the  economic  well-being  of  only   about  230
companies, which are only  marginally competitive in the international  marketplace.   I
hope the point I am  making is  taken into consideration  when  we talk about product
modification.   In other  words, the  effect of  doing  product modification work  on  the
competitive position of the American industries must be considered.

Comment:

     Even though these  groups  were  working  in  different  areas,  there  were  some
common  themes  that went through  all of them.   One of  these was the  idea of  tech
transfer  and the  need  for guidance  documents  in  various  areas,  particularly  looking
at dusting off  some of  the old  reports that  are around.   There  is an awful  lot  of
information  that  is  probably still relevant to  this that  needs  to  be looked at.   The
point is:   Do  not reinvent  the  wheel until  you  know  what  the wheel  looks  like  to
start with.

     A  couple  of other common areas  that  I think are  important  include  looking  at
the comparative  risks  in  various  technologies,  so  that  we  are  solving  the  problem
without  creating  another  one.    In addition, we  have  not  really  looked at  waste
characterization  for  a  while.   I  thought that was an  important  thing.    Of  course,
technology evaluation and sampling analysis were a couple of other common  themes.
                                            109

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      Finally, although  I  think we have tried  to steer  away from it a  little bit, the
issue of siting  was a theme  that  I  think carried  through all of these groups.   It may
be tied into this idea of comparative risk.

Comment:

      A  point on  waste  characterization.  I  think we need  better techniques  that can
be applied for local waste characterization.

Response:

      The  common thread with regard  to waste characterization had  to do with  toxins
and  the fact that  there are toxins in some of these wastes.  I do not think  we ever
really looked at the  aspects of lead  and  paint on the white goods,  for  example.  We
have sort  of taken  the first  crack  at this in terms  of identifying  the  major  sources
of what we  think are the  major sources of lead/cadmium in the  consumer products
stream. We are  starting  to do that kind of work and  are aware of the  problem.

Comment

      I  think you have  to  be  careful  when  you  talk about  waste  characterization
because  there are  a  number of  different  levels  of  characterization.    Are  you  talking;
about  characterization  for  recycling,   or  talking   about   waste  characterization  for
combustion or  for some  other  purpose?  Each  process  has  a different  characteristic
that   you  are interested in,  so  you  have  to  be well  aware  of  that  sort  of onion-like
affair in that one process is interested in a different property than another process.
                                             110

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II. SUMMARY OF WORKGROUP CONCLUSIONS/RECOMMENDATIONS
                          111

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yp^fgpyggy^

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                      SOURCE REDUCTION AND RECYCLING


Rationale

     The U.S.  EPA Municipal  Solid  Waste  (MSW)  Task  Force recommended source
reduction to  be the favored  option  in  the  hierarchy  of "integrated  waste  manage-
ment.*   The  goals  of  source reduction  are  to  decrease  the  volume  and  toxicity of
waste.    Recycling  is   the  preferred  waste   management  option  to  further  reduce
potential risks  to human  health and  the environment,  divert waste  from  diminishing
landfill   and incinerator  capacity,  and  slow  the  depletion  of  nonrenewable  natural
resources.   Research, development, and demonstration  (RD&D)  are  needed  to  develop,
evaluate, and  implement  strategies and  technologies  for maximizing  source separation
and  recycling  in  an  integrated  waste  management  approach.    The task  of  this
workgroup was to:

     o   Identify  what  technological   barriers   impede  effective  and  efficient  source
         reduction and recycling of MSW

     o   Identify research areas that address those technological barriers

     o   Recommend specific RD&D projects that meet MSW management needs.          ;

Participants
   Conrad Simon (facilitator)
   U.S. EPA—Region n

   Jim Bridge*
   U.S. EPA—OEETD

   Marjorie J. Clarke
   Inform

   Dana Duxbury
   Dana Duxbury and Associates

   Marge Franklin
   Franklin Associates, Ltd.

   Erica Gunman
   Rhode  Island  Solid Waste  Management
     Corporation
Bruce Perlson, Ph.D.
Plastics Environmental Affairs

Gerald Powell
Resource Recycling

Darlene Snow
National  Solid Waste  Managers
   Association

Marion Sills
Environmental Defense Fund

Joseph Visalli, Ph.D.
NY State  Energy Research and  NJ
   Development Authority

Nancy Wolf
Environmental Action Coalition
                                           113

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Research Areas

      The  workgroup  identified  six  areas requiring  further  RD&D.    Each  of  these
areas  deals  with   reclamation  or  utilization  through   design,   manufacturing,  and
disposal  at various stages in the flow of materials:

      1.  Durability

      2.  Reusability

      3.  Remanufacturing

      4.  Design for Recyclability

      5.  Toxicity Reduction

      6.  Composting.

      Our  society  is  characterized  by a  "throwaway"  lifestyle, i.e.,  many  products  are
designed and  purchased to  be  disposable  following  a  solitary  use.   Other durable
products are designed  with  limited usable  lifespans  and  in ways  that  make  repair
unfeasible.   Many - products require  disposal  because  they are not designed  for  reuse,
recycling,   or  remanufacturing.    Often  these  products  contain  materials   that  are
potentially  harmful   to  human health  and/or  the  environment  when  incinerated  or
landfilled.   In  addition, the volume of these products  requiring  disposal  places  great
stress on existing disposal facilities.

      Disposable   products   comprise  a  large   proportion   of   the   total  MSW stream.
Development  of  products   that  can  be  reused,  repaired,  remanufactured,  or  recycled
can  significantly  reduce  the   total  volume  of  MSW  requiring  disposal.    Following
minimal   treatment,  reusable  products may  be  utilized  by  consumers  for  either  the
same purpose  for which they  were originally  purchased or for an alternative  purpose.
These include, products  that can be reused after simple  cleaning,  like  resealable food
and  beverage  containers,  and  diapers.    Recyclable  products  are  those that  may  be
reprocessed, using part  or all  of  the products'  constituent materials  in  manufacturing
the same or other  products.   Examples  of recyclable products include paper, beverage
containers, and batteries.

      Durability  is the quality  of  a product  to  withstand  wear  and  tear, and  decay.
Products  with  low   durability   are  used  and  discarded   relatively  faster  than   more
durable  products.   Increasing  product durability  prolongs  the  potential  usable  lifespan
of a  product and thus the time  between  production and-ultimate  disposal.   Related to
durability  are  repairability and remanufacturability.    Many  products are  designed  so
that   repair  or   remanufacture   is   impracticable;  e.g.,   sealed   units,  absence   of
replacement parts  or   repair  and  remanufacture   facilities.    When  such  products
malfunction, the entire unit requires disposal.

      RD&D in  these areas is  important  to  educate  consumers,  change  market forces,
and  encourage  industry  to develop and  implement  economical  and efficient source
reduction  and   recycling.     Incorporating reuse,   recycling,   repair,  remanufacturing,
and/or  durability  into  product design  must  be  economically  feasible.    One of the
problems encountered in implementing source  reduction and  recycling programs  is to

                                             114

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demonstrate  that  the  actual  cost  of a  product  can  be much  higher  than the  initial
outlay as a  result of secondary  fees  like  repair, replacement,  downtime,  and  disposal
costs.    For  market  forces  to  favor  product  designs  incorporating  source  reduction
and  recycling considerations,  consumers need  to  be  convinced  that  a  larger  initial
outlay for a product will result in long-term economy.

     Data  are needed  relating  the  cost of  a product  to  its  potential  usable  lifespan
for  a number  of  durable  goods  within  various  price ranges.    Standards  that  rate
goods  for  quality  and  expected  lifespans,  as well as studies and surveys  on  labelling
effectiveness, need  to  be  developed  so  that  effective  consumer  education  can  be
initiated regarding  initial  apparent costs of  products relative  to actual product costs.
In  addition,  there   is  a  need  to  develop cost-efficient  technologies  and  explore
programs that  encourage  manufacturers  to  develop  more  durable,  repairable,  and
recyclable  products   and  prevent  planned  obsolescence,  without  negatively  affecting
competitiveness.     Institutional  barriers to   procuring   remanufactured  and   recycled
goods  should be  identified.     Data   are  needed  regarding  costs   of recycling  and
remanufacturing,  including  labor,  energy,  waste  management,  resource  costs,  and
environmental impact.     Toxins  in   the  waste  stream  need  to   be  identified  and
quantified, and. use  of  nontoxic and  biodegradable  alternatives in  product design  and
manufacturing should  be  explored.  Finally,  composting of  grass and  clippings  should
be encouraged to reduce the quantity of yard  waste entering the waste stream.

Recommendations/Conclusions

     The  workgroup  recommended that  all  of  the following activities   be   initiated
immediately in the area of recycling, volume reduction,  and toxicity reduction.

Recycling

      1.  Systematically   assess   exposure  and  risks  associated   with   all   recycling
         operations and products.

     2.  Research  technologies,   both   national   and   international,   and  disseminate
         information   through  a  clearinghouse.     Systems   should   be  evaluated  and
         prioritized.

     3.  Reduce the impact of paper and paper products on the waste stream.

     4.  Develop minimum standards  for handling  of regulated wastes,  with  incentives
         for reuse and recycling.

     5.  Research battery recycling.

     6.  Research use of shear-shredding.

     7.  Research compost feedstock in MSW processing.

     8.  Classify  what  constitutes  a   MSW  problem.    Prioritize  health and  environ-
         mental standards vis-a-vis problems.

     9.  Research  amount  of  waste  reduction   necessary  to  achieve  MSW  collection
         cost/savings.

     10.  Conduct field studies of generation and composition of waste streams.

                                              115

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Volume Reduction

      I.  Guidance  documents  should  be  prepared  on  design  protocols  and  waste
         reduction opportunity assessment.

      2.  A  study is  needed on biodegradation and photodegradation of  materials  in
         MSW and environmental impacts of MSW options.

      3.  A  study is  needed on ways  to increase  durability, repairability,  reusability,
         and remanufacturability.

      4.  A  comparative analysis should be  undertaken  of durable  versus  throw-away
         cost, lifetime cost, and environmental cost.

Toxicitv Reduction

      1.  A  study of  hazardous constituents in MSW including environmental  effects,
         composition, emissions,  ash, and leachate.

      2.  To encourage the development of products without hazardous constituents:

         a.  Document and publicize accomplishments
         b.  Sponsor more meetings, workshops, and conferences
         c.  Develop an information clearinghouse.

      3.  A comparative analysis of nonhazardous constituents is needed.

      4.  Labeling  of  domestic  and  imported  products  to include  hazardous constitu-
         ents, durability/lifetime, and disposal  information.

Addendum

    Erica  Guttman   made  the   following  proposal  on  source  reduction  issues.   The
questions and discussion points are divided into six sections:

    I.   Durability

    II.   Reusability

    III.  Remanufacturing

    W.  Design and Recyclability

    V.   Toxicity Reduction

    IV.  Composting.
                                            116

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I.    Durability

    A.   Data  are  needed  on  ratio  of cost of  product  to  lifetime  of product  for a
         number of types of durable goods within various price ranges.

    B.   Can  we  develop  standards  for  "rating"  durable  goods  for  quality/expected
         lifetimes?

    C.   How  can  we encourage the  development  of  products  that are  more  readily
         repairable?      Can    we   work   with   manufacturers   to   prevent   planned
         obsolescence?  (Imports need attention too.)

    D.   Study/survey  labelling   effectiveness;   can   we   (how   can   we)   convince
         consumers to  spend  more  on a  product  today  so  that  they  will spend  less
         tomorrow?

II.  Reusability

    A.   Quantify disposables.

    B.   Gather  data  on  full  costs   (including  water,  waste  management,  energy,
         resource  depletion,   environmental   "heirloom,"  etc.)  of  disposables   versus .
         reusables for common types of products (e.g., diapers, dishes, linens).

    C.   Identify possible institutional  barriers.

III.  Remanufacturing

    A.   Gather reliable  data on lifetimes  of  remanufactured   products   to  costs  of
         labor,  energy,  resources, etc.   (How  much  do we save  by  remanufacturing
         versus producing/procuring "new"?)

    B.   Examine institutional barriers to procuring more remanufactured goods.

IV. Design for Recvclabilitv

    A.   Costs/benefits of complex, multimaterial packaging.

    B.   Processing technologies to recycle complex packaging

         1.  Cost-effective collection and processing
         2.  Markets?

    C.   Redesign  coated   cardboard   (chipboard)   packaging   to   be   more   readily
         recyclable/commonly recycled.

    D.   Biodegradable  plastics  study  (Research  Agenda) should  examine  impact  on
         recycling   systems,   technologies,   end-products,  as   well   as   impact   on
         incinerators and landfills.

    £.   Gather data on surveys of consumer attitudes of "recycled."
                                             117

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      ^
V.  TpxjcjtY_ Reduction

    A.   Quantify problem of toxics in MSW.

    B.   Develop nontoxic alternatives.

VI. Composting

    A.   Gather  data  to  determine  impact  of   herbicides,   pesticides,  and  chemical
         fertilizers on compost/food.

Additional comments included the following;

    A.   The  EPA  papers were  primarily concerned with  technical  research  questions;
         however,  most   source  reduction  and   recycling  questions   are   nontechnical,
         "soft" issues;  must  also  focus  on research  questions  for innovative  planning
         programs.   Although this  may be  done in  another division of EPA  (e.g.,
         OSW), it must be addressed.

    B.   Education  is  clearly  a major  key  to   successful  source  reduction  programs.
         Each of the issues on the handout has education elements.

         1.  Durability.    We have  a sense that  quality products  will last  longer,  but
          .  we  do   not  really  know for  which   products  this  is  true or how  much
            longer  they  really  last.    This   is  one  of the   tougher public  education
            issues, yet critical  to  successful  source  reduction programs.    We' need  to
            be able  to  tell  consumers  how  much longer a product  will last and how
            much money  will be saved.

         2.  Reusability.   We need  to know how  serious the disposables problem  is  and
            where we  should  place  our energies.    This   has  the potential  to  be  an
            easier  public  education  message  than  durability, if  we can  show  true
            costs.

         3.  Remanufacturing.    Similar  to   reusability; probably  more  applicable  at
            industrial level;  corporate and agency policies   that favored  procurement of
            remanufactured  goods  could go   a  long  way  toward  increasing  reuse,  but
            we  cannot  expect. people  to  adopt  such  policies  if  we  cannot provide
            cost/benefit data.

         4.  Design  for  Recyclability.   Buying recyclables   is  one  of  the easiest  public
            education messages.  In Rhode Island, we  want  to be  able  to say:   "Buy
            the product in the package-that will go  in your blue  recycling box."

    C.   Source reduction elements  can  be applied to  different problems  in  the  waste
         stream:

         1.  Tires:

            a. Durability (e.g., high-mileage tires)
            b. Reuse/remanufacture (e.g., retreading)
            c. Design for recyclability (if unable to retread)

                                              118

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         2.  White goods/brown goods:

            a.  Durability (long life, easily repaired)
            b.  Remanufacture
            c.  Recyclability (easy to segregate materials)
            d.  Toxicity reduction (capacitors or metals)

    Marge  Franklin  made  the  following  suggestions  for  a source  reduction research
agenda.  The suggestions are divided into two sections:

    I.   Reduction of Toxicity
    II.   Reduction of Volume.

I.   Reduction  of Toxicitv

    A.   Identify  toxic  constituents  in  products  in  MSW.   (Considerable  research  has
         already  been  done   on  lead,  cadmium,  and  household  hazardous  wastes.
         Consistent data base on laboratory analyses is lacking.)

    B.   Determine  the actual  effects  of  heavy metals and other toxic constituents  on
         MSW  management  alternatives—recycling, combustion,  landfill.   (See research;
         agenda in other areas.)

    C.   Focus  on  materials/products identified  as most  potentially harmful • in (A)  and
         (B), and investigate methods of source reduction.

         1.  Investigate substitutes for harmful constituents.            .         .

         2.  Compile and evaluate experience  in existing  state and local  programs,  and
            other countries.    (Unfortunately,   there  is  little  long-term  experience  in
            the United States)

         3.  Compile and evaluate  existing  educational  programs  to reach  two  distinct
            groups:

            a.  Industry
            b.  Consumers.

         4.  Evaluate  Federal   role  in  reduction  of  toxicity.   Choices range between
            two  extremes—from outright   ban  of toxic  constituents  to  education  and
            "jawboning."

II.  Reduction  of Volume

    A.   Investigate  economic   and  social  trends that  lead  to  increases  (and  decreases)
         in  generation  of  MSW.    (Economic  incentives   for  industries  to  decrease
         materials use; new products,  e.g.,  facsimile machines that use  more  materials;
         demographics  that  influence   use  of throwaway  products  and  packaging;  and
         effect  of economic growth and  recessions, etc.)
                                             119

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    B.  Investigate   the   pros  and   cons  of  degradability   of  plastics  and   other
        materials, such as litter, in the water, recycled, incinerated, landfilled.

    C.  Repeat items (2) and (3) above.

    D.  Evaluate Federal role in volume reduction.

    Joe Visalli, Program Manager  of NY State Energy Research  and  NJ  Development
Authority, made the following points during his presentation.

I.   New York State Energy Research and Development Authority (NYSERDA)

    A.  Public benefit corporation of New York State

    B.  RD&D of alternative energy concepts

    C.  Nonrecourse  bonding program

    D.  Low-level  radioactive  waste management

    E.  Facilities management—West Valley, Saratoga

    F.  Funded  from  utilities assessment, fees  from nonrecourse bond  sales,  royalties *
        from  R&D  projects,  fees from  waste  generators, rents,  and  site management
        funds.

II.  Municipal Wastes
                                                               *
    A.  Solid wastes

        1.  Existing and planned incinerators
        2.  Combustion quality and air pollution control
        3.  Recycling and waste reduction
        4.  Ash management
        5.  Landfill management
        6.  Advanced systems.

    B.  Sewage treatment

        1.  Existing facilities
        2.  Anaerobic pretreatment
        3.  New systems.

    C.  Sludge management

        1.  Basic anaerobic microbiology
        2.  Integrate  biological and engineering requirements
        3.  Incineration and heat recovery
        4.  Composting
        5.  Ultimate  disposal.
                                         120

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nL MSV^ Program Basis

    A.  Produce and/or conserve energy

    B.  Environmental impacts—all alternatives

    C.  Landfills necessary but minimize use

    D.  Site-specific needs—difficult to generalize

    E.  Integrate technological alternatives and provide for backup approaches

    F.   Need for improved process efficiency and reliability

    G.  Need for improved product quality and increased acceptance

    H.  Large capital investment/complex technologies—need for training.

IV. NYSERDA Program Plan Ob iectives—Recycling

    A.  Evaluate  collection  and  preprocessing  methods  for  recovery  efficiency  and
         ability to meet market specifications

    B.  Develop  and  demonstrate  innovative  processes  to  produce new  or  improved
         products, or. to improve  recovery yields

    C.  Develop  and  demonstrate  interim  backup  methods  for collected  wastes  that
         cannot be marketed

    D.  Test   emissions,  effluents,   and  solid   residues  from  recycling  systems  and
         evaluate "remaining wastes"

    E.  Evaluate  sociological/psychological   factors  affecting  household   participation
         rates, and evaluate the effectiveness of public information programs

    F.   Evaluate consumer product composition for hazardous constituents.

V.  NYSERDA R&D Recycling Projects

    A.  Broome County recycling demonstration

         1.  Newspaper and glass
         2.  Baling and color sorting/crushing
         3.'  Three collection methods
         4.  Operational cost estimates
         5.  Air emissions/residue testing.

    B.   Pilot-scale intensive recycling and composting in the town of East Hampton

         1.  Household source separation
         2.  Mixed paper, glass, cans, food/yard wastes composted with sludge
         3.  Metals, organics, bacterial air emissions testing for metals and pesticides.

                                             121

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C.  Co-composting and sod production

    1. Yard waste composting with sewage sludge using windrows
    2. Determine best operational control parameters/mixes
    3. Identification of product quality/market relationship.

D.  Assessment of residential participation behavior in recycling programs

    1. Assess  demographics,  sociological  and  psychological  factors,  educational
       methods of importance in two to three communities.

£.  Yard waste management technology transfer program

    1. Set up central core of expertise at Cornell ("SWAT team")
    1, Develop   various   management    scenarios    and    equipment/economics
       interactive   computer   model   for   use   by   county   agents  and   local
       governments
    3. Develop training films and educational handouts/work forms
    4. Hold a statewide conference for training county agents
    5. Set up local training programs in all counties
    6. Feedback • economics   from  local   governments/county  agents  to  Cornell
       model for updating
    7. Evaluate effectiveness of overall program.

F.  Composting of solid wastes and sewage sludge

    1. Waste paper, yard  waste,  sawdust,  and  wood  ash composting with sewage
       sludge
    2. Windrows and in-vessel composting
    3. Air emissions, leachate,  and product testing.

G.  Recycling of individual polymers from mixed plastics wastes

    1. Lab science testing of five different polymer mixtures
    2. Two or three different solvents/temperature regimes
    3. Testing of  physical properties  of  recovered  polymers  and  comparison  to
       virgin polymers
    4. Optical testing for purity
    5. Sludge quantification.

H.  Multimaterial  recycling and  production of  animal  bedding from  mixed  waste
    paper

    1. Produce animal  bedding (mixed paper, glass, cans,  yard waste).
    2. Compost used bedding
    3. Evaluate collection method and use of drop-off containers
    4. Quantify costs and revenues of Potsdam and surrounding communities
    5. Test air emissions, bedding, and compost quality.
                                        122

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    Jerry  Powell, editor of  Resource  Recovery Magazine,  developed a list  of research
needs  following discussions with  readers  of the  magazine.   The list was submitted to
Conrad  Simon  (the workgroup  facilitator)  on  October  13,  1988.   The list  is  divided
into three sections:

    I.   Material-Specific Research

    II.  Recycling Facility Research

    III.  Recycling Economics Research.


I.   Material-Specific Research

    A.  Special wastes

         1.  Tires
            a.  Evaluate various tire processing technologies, such as pyrolysis.
            b.  Assess  the   air pollution issues  involved in  tire-derived and  whole-tire
               fuel use.
            c.  Attain a better understanding of rubber-asphalt use.

         2.  Plastics
            a.  Research the separation of polyolefins from mixed plastics.
            b.  Assess opportunities for on-route densification of residential plastics.
         ,  c.  Develop specifications for mixed thermoplastic products.
            d.  Describe methods of sorting plastic containers by resin type.

         3.  Yard wastes
            a.  Assess specifications for yard waste compost products.
            b.  Perform  research  into   yard  waste  compost  contamination  from  fer-
               tilizers and pesticides.
            c.  Research techniques for on-site yard waste composting.

    B.   Bulk materials

         1.  Waste paper
            a.  Research animal bedding production (costs, uses, specifications).
            b.  Assess  the  potential  for  using  magazines   in  the  production  of  de-
               inked newsprint.

         2.  Glass containers
            a.  Analyze the  experience in using glass in asphalt (glassphalt).
            b.  Evaluate mechanical and optical sorting of containers by color.

         3.  Metals
            a.  Assess  manual  methods  for removing PCB-contaminated  capacitors  from
               scrap white goods.
            b.  Research  the   environmental   aspects   of ferrous   scrap-shredder  fluff
               handling and disposal.
                                              123

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n.  Recycling Facility Research

    A.   Describe  the  environmental   impact  of  various  recycling  processing   tech-
         nologies.

    B.   Research  the  effectiveness  of proposed  mixed waste  processing systems, such
         as Orfa, Sorain-Cecchini, Renter, etc.

HI. Recycling Economics Research

    A.   Evaluate  the  recycling  and  waste  reduction  effects  of  waste collection  rate
         schemes per container.

    B.   Estimate  the  amount   of  waste  recovery  needed  to  attain  waste  collection
         cost savings.

    C.   Evaluate the quality of selected products made from waste materials.
                                             124

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                         MUNICIPAL WASTE COMBUSTION
Rationale                                                            '  .

     Incineration  technology   has   developed   new  and  more  efficient  methods  of
burning  solid wastes as suitable sanitary  landfill  space  has become less available  and
more  expensive.    This includes  technology  for both  single-purpose  incineration  and
co-generation  plants.     However,  mounting  concern   for  possible   health   and
environmental  risks  associated  with  municipal  waste  combustion  (MWC)  residuals
management  and stack emissions has  resulted in apprehension  for siting  incineration
facilities.

     This  workgroup was  tasked  with - identifying  technical approaches  and  RD&D
priorities  for  emissions  control  and  combustion  process  modifications   related  to
products of  incomplete combustion, products of combustion,  and monitoring associated
with incineration technology.
Participants

   James Kilgroe (Facilitator)
   EPA--OEETD

   Theodore Brna
   EPA—AEERL

   James Crowder .
   EPA—OAQPS

   David DeMarini
   EPA—ORD/HERL

   Larry Fradkin
   EPA—ECAO

   Holly Hattemer-Frey
   Oak Ridge National Laboratory

Research Areas
David Linz
Gas Research Institute

Jack Lyman
IRR

Al Ruben
EPA—OW/OWRS

Walt Shaub
CORRE/U.S. Conf. of Mayors

David Sussman
Odgen Projects, Inc.

Curtis Travis
Oak Ridge National Laboratory
     The  workgroup  identified  three  major areas  where  RD&D is  needed  to  improve
the acceptability of incineration technologies:

     1. Risk assessment analyses

     2. Understanding the effects of the waste stream on incinerator performance

     3. Understanding  and  controlling  regulatory  effects  on  MWC   processes  and
        technologies.
                                           125

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^^mir^
              Risk  assessments  are  conducted   to   evaluate  the  potential  risk  of   proposed
        actions on human  health and the  environment.   These  assessments  take the  form  of
        system  models   that  estimate  emissions  of   hazardous  substances  from   proposed
        facilities.    They  utilize  characteristics  of  the  proposed   facility   along   with  data
        gathered  from similar,  already existing  facilities.    These  estimates  are  then  used  in
        additional  models  to  estimate the  potential   health  risks   to  different demographic
        groups at various distances from the site.

              The  working  group  identified the  following  six  aspects  of risk assessment where
        EPA should focus RD&D efforts:

              1.  Standard methods for conducting risk assessments

              2.  Health effects subcomponents of risk assessments

              3.  Comparative analyses

              4.  Effects of direct and indirect exposures

              5.  Emission source monitoring and deposition data

              6.  Changes in the waste stream and their effect on incineration.

              Standard methods  for  conducting  risk  assessments are  lacking.   Currently,  each
        proponent of  a facility  can  select from numerous  risk  assessment methods,  many  of
        which are  either poorly validated or are  untested modifications of  more widely  used
        methods.    The  results  of  these  assessments  are  not  necessarily  comparable.    To
        determine   comparability  often  involves  major   effort  on   the   part  of  regulatory
        personnel.   Methods  can  be  selected  to  favor or  disfavor a proposed action,  de-
        pending  on the objectives  of  the analyst.   The solution to  this problem could be  to
        standardize  risk  assessment   methods  for  routine  evaluations  of  incinerator  appli-
        cations.   These  standard methods  should include specified  protocols, data sets for use
        in  rate functions, and assumptions for  use  in  the assessment.  Subcomponents of the
        methods  should  include   probabilistic   components   and   uncertainty   analyses  when
        inadequate data are available or when data  indicate that large variances  could exist.

              Existing  risk   assessment  model  subcomponents   that   deal   with  health  effects
        often  rely  upon  insufficient  .data for  meaningful  evaluations.    Available  data  for
        specific  exposure pathways  and  all  reasonable  pathways  of  exposure  are insufficient.
        In  general, emission  data from incinerators  tend to be the  highest  quality data,  fol-
        lowed by  transport  and  fate data.   However,  data  about  bioaccumulation  in   food
        chains related to  emissions are  almost  nonexistent.    Standard  data  sets with known
        error  estimates  are   needed  for  use- in  many  of  the  health  effects  subcomponents.
        For example,  a  data  set  of  the  ingestion rates  for  human  populations  of  varying
        demographic  composition  would  be  very  useful  in  all  risk  assessments  related  to
        incinerators. Similar data sets are needed for biological  accumulation processes.

              Risk  assessments   should  include   comparative  analysis  of  the  risks  associated
        with  alternatives  to  incineration,   as  well as  alternative  incineration technologies  and
        locations.    For  example,  risk assessment  alternatives  should  include  assessments  of
        recycling   and  waste  reduction   efforts.    Disposal   methods  and  waste  reduction
        approaches  and  evaluation  of the  risks   associated with  everyday  activities  and   con-

                                                      126

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ditions  should  be.  considered  in  addition  to  comparing  the  risks  associated  with
alternative  incineration  technologies,  i.e.,   analyses  of  risks  associated  with  cigarette
smoking,  heating with wood  stoves,  and diesel  exhaust  emissions  would be  useful as
public education devices to compare with estimated risks from incinerators.

      Additional data are  needed  regarding  the effects  of direct and  indirect  exposure
to  incinerator  emissions.    These  data should include  the  toxicity  results of  exposure
tests  using  single  compound exposures  as   well  as  mixtures of whole emissions  gases.
Indirect  exposure data are  needed  in addition to data sets about fate, transport,  and
bioaccumulation processes.     Prioritized  rankings  of  the   hazards  associated  with
compounds would be very useful.

      Monitoring efforts at  emissions  sources should  be  expanded  to  provide  data for
risk assessments.   Data  are needed  for organics,  trace elements,  fugitive  dusts,  and
mixtures  of  compounds  in stack emissions  and at receptor sites.   In  addition,  deposi-
tion rates on various surfaces, e.g.,  forest  soils,  pastures, and open water  at  various
distances  from  sources  would  help  refine  risk  assessment  models  and  improve  their
reliability.

      Waste  minimization,  recycling,  and product  substitutions will affect the  volume
and characteristics  of the  waste  stream  to  municipal  waste  incinerators  in   coming
years.    However,  few data are  available   that  indicate  the  sensitivity  of  incineration
processes  to  changes  in the chemical  and  physical nature of the  waste  stream.   There
is  an extreme  need  for data in  this  area.    Data  should  be  collected as  soon as
possible,  before  expected   policy  requires  mandated  changes  in  the  waste   stream.
Questions that cannot be answered, given current data, include:

     o   Should  EPA  policies  minimize  the  presence  of some trace elements  in the
         waste stream based upon environmental risk?

     o   What concentrations of  various  materials,  such  as  tires,  can  be tolerated in
         the waste stream without adversely affecting emissions?

     o   What effects  do  increases  and  reductions  of  biomedical  waste  in  the  waste
         stream have on emissions and ash  characteristics?

     Although  many different  incineration  technologies  exist or  can  be developed,  all
share the characteristic  of  burning  a fuel to heat  and incinerate  the waste  stream.
The  best  measure  of good combustion  design  and  incineration  effectiveness  is  the
heat  release  rate per cubic foot of  fuel  and  waste  mixture.    The  heat  content of
common  fuels   is   readily  established.    An  ideal  incinerator  would  allow  complete
release  of  the  heat  content of  the  fuel.    However,  actual  incineration technologies
allow  varying  degrees of  heat release  from  fuels.     These  varying  release  rates are
measures  of  the efficiency  of the  incineration  technology.   This  concept also  applies
to  incinerators  that  use  MSW  as fuel.  Since the  heat release  rate  of  varying  MSW
streams  is   not  well  known,  it  is difficult   to   design  a  reliable  and   efficient
incinerator.    As a  result, MSW  incinerators  have utilized various  control  technologies,
such  as  flue  gas  cleaning, to  ensure  reduced  emissions  resulting  from   incomplete
combustion.    Changing  technologies  in  incinerators   may make such  controls  obsolete
by achieving the desired emissions during combustion.
                                              127

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     Regulatory approaches address  the  use  of specific  best  management  practices
(BMPs).    These BMPs  are often thought of  as mandated technologies for  achieving
specified  levels  of  control.   Although  desirable as  a  means of showing  levels  of
achievable  control,  the  use  of  BMPs  to  guide  design  development can  tend  to
suppress  innovation and  improvements   in  combustion   processes.    Currently,  incin-
erator  design  uses  concepts and equipment  that  were approved  earlier by regulatory
bodies.    Responsibility for  performance  of  these designs resides  with  the  operator  of
the  incinerator.    The  workgroup felt  that  EPA should either  be  willing to  accept
direct   responsibility  for  the  operational  performance   characteristics   of   incinerators
designed   according  to   BMP   guidelines,   or  should   provide   "performance-based"
standards  that  allow   for  innovation   on  the  part  of  operators  and  require   the
operators to assume responsibility, for the performance of their incinerators.   Implicit
in the  use of performance standards  is  the  need for  an  integrated program  of RD&D
that  addresses  concept,  bench,  pilot,  and operational scale  efforts,  and  an  adequate
testing  and  evaluation  program  for  proposed incinerator  designs.    This should apply
both to new  designs  and  to  retrofitting  existing facilities  with  upgraded  incineration
or flue gas cleaning equipment.

     Additional  efforts  in  monitoring  and   control  of  "new"   pollutants,   such  as
mercury  and  oxides  of   nitrogen,   should  be  pursued.    Concern  regarding  these
pollutants  relates  to  indirect  exposure  through  biomagnification  of  heavy  metals  in
food chain organisms,• and to  the potential  ecological  effects  of  oxides of  nitrogen  in.
the atmosphere and in precipitation.   The National Science Foundation (NSF) recently'
recommended  that  research  should be  conducted to  determine  the fate of metals  in
flue   gases,   including   both  metal   oxides   and   metal  halides.     The  workgroup
recommended  that  NSF scientists  be  contacted  to  assist  in  developing a  strategy  for
basic research and cooperation in this area.

     Monitoring costs  at  incinerators can be  extremely  high,  and  additional RD&D
efforts  are  needed  to  achieve  two  specific  objectives:     1)  to   reduce  the  cost  of
Continuous  Emissions   Monitoring (CEM),  and  2)  to   increase   the   effectiveness  of
monitoring  efforts.   Both  of these  objectives  can  be   achieved  by   use  of limited
numbers  of monitors  that are  carefully  selected and well located in  the incinerator
and  stacks.    For  example,  two  excellent  measures  of   efficiency that  can  be  well
correlated  to  emissions  are the  temperature of  the  control  devices  and  the rate  of
particulate  emissions.   Use of  continuous  monitors  for  these  measurements, coupled
with a  measurement or  a surrogate  of  opacity, should provide adequate monitoring  at
most  facilities.   A  surrogate  for opacity  that  uses low-cost,  reliable measurements
would help to lower the total cost of CEM.

     The  list  of pollutants  subject  to CEM requirements  should  be  trimmed to  only
those  of   known   biological  or  ecological  significance,  plus  those  that   may   be
reasonably  expected  to  participate  -in   adverse  atmospheric  transformation  processes.
When optimum  combustion  and  control  systems  performance  can  be  ensured through
monitoring,  permit  specifications  should  allow   reduction  in  emissions  monitoring  to
the  extent   that   it   can  be   demonstrated   that   hazardous   or   environmentally
unacceptable  compounds   cannot  be  formed  in   the  existing combustion  process  or
cannot  exceed  specified  levels  in  the  emission.    The  use  of  alternate  control  and
monitoring  approaches  that  achieve  the  desired  results  should be acceptable  to  EPA.
RD&D  efforts  should  be  increased in the areas  that  expand the  number of acceptable
choices  for both combustion and monitoring/control  technologies.


                                             128

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Recommendations/Conclusions

     Items  of high priority  were  identified  throughout the  session.   The consensus of
the workgroup was that primary importance should be given to the following items:

     o   CEM  should  be  increased  and  focused  toward  filling  data  requirements of
         risk assessment models.

     o   The cost of  implementing CEM at incinerators should be reduced  by focusing
         efforts on the biologically active components of emissions.

     o   An  EPA-approved  risk  assessment  method  or  set of methods  should  be
         established.

     o   An  ambient  monitoring  program  should  be  established  that  is  based  on
         bioassays  of   full  suites   of  compounds   associated  with   emissions   from
         incinerators.

     o   Sensitivity  analyses  of  MWC  processes should  be conducted on  emissions and
         ash  characteristics  to  evaluate  the  effects  of  changes  in  the  waste  stream.
         These  analyses  should  utilize  monitoring  efforts  at  operating  facilities at
         which it is possible to control the quality of the waste stream.

     o   Research  is  needed to  determine  whether  biomedical  wastes  can  be  suc-
         cessfully  incinerated in municipal  waste  combustors, and  if  so,  under  what
         conditions.

     o   An  assessment  should   be conducted   to  estimate   the  health  risks  associated
         with  mercury   emissions  at   present   levels   and  the  efficacy  of  existing
         technology for  mercury  control to  determine  the  need for  developing  new
         mercury control technologies.

     o   More  effort should be  directed  to   demonstrating  additional  approaches to
         CEM and to lowering the cost of CEM.

     The following  recommendations  were  suggested to further  the  RD&D efforts of
EPA:

     o   Improve  coordination   between EPA   and  other  Federal   agencies,   including
         NSF, to better focus  research  efforts on applicable topics.

     o   Better  coordination   and  relationships  between' EPA  headquarters   and  the
         Regional   Offices  to   increase  technology  transfer,  uniformity  in  the  ap-
         plication  of standards, and stimulation of RD&D activities.

     o   Standards  for   incinerators  should  be  evaluated   and   possibly  rewritten to
         assure  that they  relate  to  performance  of  facilities,  as  opposed to  design.
         Whenever  required,  the  words "or  equivalent"  should   be  applied  to  design
         specifications to ensure that  desired  levels of  performance are achieved and
         that incinerator designs are not  unduly constrained.
                                             129

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130

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           MUNICIPAL WASTE COMBUSTION RESIDUALS MANAGEMENT
Rationale
     Incineration of  MSW  may  reduce the volume  of waste .requiring landfill by  90
percent.    However,  proper  management  of  combustion  residuals   is  necessary  to
minimize  potential  hazard  to  human health and  the  environment.   The  presence  of
heavy  metals  and  some  organics  in  MWC  ash  has  increased  concern  that  these
materials  may  leach  from ash that is landfilled and migrate  into ground  and  surface
water supplies.   This workgroup was  tasked  with identifying  the technical and social
problems  hindering  implementation   of   residuals  management  options and   possible
RD&D solutions  to these  problems.   The  group agreed that the overall objective for
RD&D efforts  is  to  provide technically  correct information  for  use  in implementation
of community ash management.
Participants

   Carlton Wiles (facilitator)
   EPA—OEETD

   Warren Chesner
   Chesner Engineers

   Phil Cook
   EPA/ERL Duluth

   Ken Cundari
   Malcolm Pirnie & Co.

   Dr. Taylor Eighmy
   DCE—University of New Hampshire

   Mike Flynn
   EPA—MSWP
Keith Forrester
Wheelabrator Environmental
  Systems, Inc.

Hector Mendieta
ASTSWMO—Texas DOH

Dr. Frank Roethel
MSRC—State University of N.Y.

Sheree Stewart
HDR, Inc.

Bob Van Deman
Florida—DSWM
Research Areas

     The   workgroup  identified  eight  areas  where  RD&D  efforts  are   needed  to
facilitate better  residuals management  in  communities.   Discussions  centered  on  both
combined  ash (fly plus  bottom  ash)  and discrete  ash  sources  due  to  the  different
possible management  approaches  necessary because of  differences in the chemical  and

physical  properties of  fly  and  bottom ash.   The  eight  research focus areas  are as
follows:

     1. Sampling protocols and analytical (chemical and physical) methods

     2. Handling of ash

     3. Toxicity, bioavailability, leachability

                                           131

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      4.  Landfilling

      5.  Treatment and reuse

      6.  Technology    and   information   transfer   (both  technical   and   management
         information)

      7.  Sociopolitical aspects of reuse acceptability

      8.  Formulation  and dissemination  of interim  guidelines/recommendations  by the
         Agency.

      Discussion   of  ash  management   stressed  the  importance  of   identifying  the
objectives  of  monitoring  efforts, i.e., the  differences  between the  goals  of  research,
engineering,  and  regulatory/enforcement  programs  may  require   different  monitoring
strategies.   Existing data bases   in  many areas are  inadequate as  a  result  of the  lack
of  goal-oriented  monitoring  strategies and application  of  diverse  methods  in  analysis
and sampling.    The   ability  to  model  performance  of  disposal  and  reuse  strategies
depends  on  comparability  of   data.     Therefore,   effort  is  needed   to  standardize
methodologies  for sampling  and  analytical programs.  There  is also  a  need to define
data  quality  objectives  in studies so  that  accuracy, precision, sensitivity, and  system
variability   can be  assessed  to   add  statistical certainty  to   monitoring and  modeling
efforts.

      Development of   better  measurement  tools  to  assess  relative  bioavailability  and
toxicity  of hazardous   materials   is also needed.   The relevance  of  extraction  methods
that do not  reflect  true solubility  or bioavailability of  toxins  is  debatable.   Leach
testing  methods  are needed that  are more predictive of  various  engineering operation
scenarios.

      Of primary  importance in  research  on handling  of ash  is the  need  for  protocols
that evaluate options  for  ash  disposal or reuse.  There is also a  need to address the
problems  associated  with - transportation,  storage,   processing,  and  final   disposal  of
ash.   In  the case  of remote   disposal,  total  management  by the  MSW  manager is
virtually impossible  because of  the  number and  remoteness  of handling  steps.   Little
if  any  data  appear   to  be  available   to  assess   risks;  existing  data  are  usually
contractor   proprietary   information.    The greatest   need  in  this   area  is  for  data to
evaluate exposure and  risk  associated  with  remote disposal.   These  could  be  most
useful  in  the development  of  BMPs.    Research  in this • area  should  seek to  assess
current knowledge on BMPs and provide interim  guidance.

      In  the areas of   ash  toxicity,   teachability, and bioavailability,  the greatest  needs
are  for  compilation  and  assessment  of  existing  information.   There  has been  some
research in the  areas of  teachability and  bioavailability  in   aquatics.    Work  in the
Saugus   (MA)  Marsh,   where  ash has  been   disposed   in  a  landfill  adjacent  to  the
brackish  marsh  for several  years,   has  not  demonstrated  any measurable  detrimental
effects  on the  fauna.   In  addition,  environmental impact   versus  human  toxicologic
effects  relative  to  risk  assessment  should  be  differentiated.    Methods and  strategies
for  assessment,   evaluation,   and interpretation  of   bioassay  data with   reference  to
effects  on  human populations  need  to be  developed.  There  is also  a  need to  develop
predictive  models.

                                              132

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      Of  several  research  needs  identified  in  the  area of  landfill disposal,  the  first
was  the  necessity  to  produce  performance  standards  for  landfill  construction  that
restrict  toxic  material  leaching.    The  second  was  the  need  to   develop  better
methodologies  to   minimize  leachate   loss  from  ash  fills,  including  application  of
innovative  technologies.     This  would  involve  documentation  of   incentives   for
community  or  vendor application of  innovative  technologies.   The  third  need  was  to
compile and disseminate information on  potential effects  of co-disposal.

      In  the  area  of ash treatment  and  reuse,  several needs  were  identified,  including
the  compilation and dissemination  of  BMP  "success  stories";  full-scale demonstration
of  reuse  and   treatment   technologies;  .development   of   protocols  for  evaluation  of
demonstrations;   review  and  acceptance  of technologies  by  the  Agency   as   BMPs;
characterization  and  reduction  of liabilities  in  reuse  and  treatment; development  and
adoption  of  Federal legislation  to  create  incentives  for   technology  utilization  by
state,  county, and  municipal authorities; development  of economic  incentives  for  reuse
by  MSW managers,  including  clearinghouses for seeking  markets  for  reuse  materials;
and more effort  to advance  research  technologies to  the  utilization  stage.   A  high
priority was given to developing  performance criteria for reuse options technologies.

      For each  of  these research  areas, there is  a  need for  more  effective  technology
and  information  transfer.    Many  developments  in  the  technology  application  and
management  approach go  unnoticed because the  Agency  is  not  effective  in the  area
of  technology  and  information  transfer.    The  workgroup  saw  clear  needs  in  the
following areas:  evaluation of  delivery  mechanisms;  creation of  an EPA  clearinghouse
for  direct  information  transfer;  provision  of  fact   sheets  for  various  technologies;
provision of  technical  evaluation information  in the  form  of  CERI-style  documents;
press  briefings  to  enhance coverage  in  the "popular  press";  and  formulation  of an
international committee to expedite cooperation and sharing of new information.

      There are sociopolitical aspects  of  MSW  residual  management  that  are  intrinsic
to  each   research   area.     In   many  cases,   political   discomfort   with   alternative
technologies  in ash  disposal is   caused by  a paucity  of empirical information  on  risk,
cost,.and liability.    An effort  should be  made  to overcome  the concepts  that  ash  is
toxic  pending  demonstration to  the  contrary.      There  needs  to  be  a  coordinated
effort in  information  dissemination  that  provides  timely  and  complete   information
affording credibility  to the  Agency  and to the technology.   Persuasive  information on
risk  comparison  (re: oil   versus coal   versus  gas)  may   be  valuable  in   addressing
political   concerns.    It is  also  important  to   implement  sound  technology  transfer
methods   to  avoid  disproportionate negative  press.   Factors  worth considering  in  this
area   are  potential   liabilities;  conflicting  regulations   resolution;   impedimentary
regulations  relief;  enhancing   the  Agency's  capability to.  provide   information  and
willingness  to   invoke   supremacy  over  state   authority;   and   the  current   lack   of
consistency in these policies at the Agency.

      Finally,  the  panel discussed the need  for  EPA  leadership  in  providing  interim
guidelines for BMPs.   This would  go far in convincing the  public that the Agency is
serious about  the   application   of  appropriate  technologies   and  is  willing  to  assist
interested parties in  compliance  with  innovative approaches.   Approaches to  guideline
formulation   may   include   high-priority  testing   of  technologies  on  expedited   time
scales;   development   of   surrogate    test    methods   for   toxicant    measurement;
implementation  of  screening  tests and  surveys;   and  acceptance of  interim  measure-
ments for rapid data base development.
                                              133

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     The  workgroup  felt  that  the  highest  priority  item  was  the  formulation  and
promulgation of  interim  guidelines  for BMPs.   However, with  the  knowledge that  this
and  many  of  the  other tasks  are  interconnected, the  panel  felt  that the  remaining
seven  research areas  were  equally  deserving  of major effort.   Work  on  these  action
items  should  be  directed  as tasks  through  OEETD,   with  the active  participation  of
interested parties  in industry and state, local, and Federal governments.
                                             134

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                                  LAND DISPOSAL
Rationale

     Historically,   the  responsibility   for  managing   MSW   has  fallen   under   the
jurisdiction of  local  and  county  governments.   During  the  past  20  years,  landfills
have  evolved  from large  open pits  where  wastes  were periodically burned to reduce
their  volume,  to  today's  modern  sanitary  landfills  where  wastes  are covered  by a
layer  of soil at the end of  the  workday.   Many of these modern  landfills incorporate
subsurface leachate collection  systems,  the use  of  artificial  and  natural   liners,  and
systems   to   recover   generated  gas   as  an   alternative   energy   source.     These
technological advances  were  implemented  as  a result of regulations by state and local
governments  to  improve  the  operating  systems of landfills in  an  effort to  control  the
migration of gases and leachate.

     Operating  deficiencies  of the  older  landfills have led  to  a  lack of  public  con-
fidence in landfills as a  waste management technique   and  serious  siting  problems  for
new  facilities.    As  a  result  of  this  and  an increase  in   the  quantity of  waste
generated,  landfill  capacity   is  rapidly   declining.     Over  one-third  of  currently
operating  landfills  will reach saturation capacity and close within the next 5 years.

     Concern  over  rising  disposal  costs,  limited and  uncertain disposal facilities  and
siting  problems,   and  changing   regulations   and   legislation   has  led   the  Federal
government to  reevaluate  MSW practices  and  identify  new,  innovative   technologies
for the  management  of MSW.   This  workgroup  on   land  disposal  was   convened  to
develop specific  RD&D  needs for  a national research  agenda by  soliciting comments
from   industry;  trade  organizations,  academia,  and  government.    The  goal  of  this
workgroup  was   to   identify  and   prioritize   specific   research   that  addressed
environmental and health  concerns  and other  impediments  to  expanding land  disposal
capacities.
Participants

   Robert Landreth (facilitator)
   EPA—OEETD/RREL

   Kurt Fisher
   Center for Environmental Management
   Tufts University

   Roy Herndon
   Center for Biomedical and Toxico-
     logical Research and Hazardous
     Waste Management

   Vic Lambou
   EPA--OADEMQA

   James McNab
   EPA—ORD
Hal Monague
EPA—Region III

Ky Ostergaard
Technical Resources, Inc.

Ronald Poland
Waste Management of North America

Norbert Schomaker
EPA—OEETD

N.C. Vasuki
Delaware Solid Waste Authority
                                            135

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Research Areas

     Those  areas  where  the  workgroup  felt  research  was  needed immediately  were
programmatic  areas   that   would  affect  the  siting,  design,  operational  monitoring,
construction,  and  closure  and  postclosure  process  of  municipal  landfills.    Identified
research needs  included  a  better  understanding  of wastes  and  waste  streams,  more
case  studies  of  landfills,  long-term  performance  assessment  of  liners  and  leachate
recovery  systems,  technology  transfer,  and   research  into  monitoring  requirements.
Some   concern   was   expressed   regarding   the   hierarchy   of   "integrated   waste
management"  recommended  in the  "Agenda  for Action," prepared  by  the  U.S.  EPA—
OSW.   One  member  of the  workgroup  felt  that  future MSW  disposal  requirements
would make  land disposal  the  preferred method  for waste  management, and  not the
last consideration in the hierarchy.

     Research into these areas  is mandatory if the  technology  of solid waste  disposal
is  to  keep  pace  with  increasing demand.   There  is  a  need  to  demonstrate  to the
public  that  land disposal  is   safe,  reliable,   and  a  long-term  solution  for   MSW
management.    Public  confidence  that  human health  and  the   environment   are  not
adversely  affected by  landfills  is  required  if  more  state-of-the-science landfills are to
be  constructed  to meet  the needs of  municipalities.   Technology  to improve operating
efficiencies and  monitoring programs  will  result  in significant cost  savings for  local
governments managing  land disposal  facilities.   Increased  land costs and liability,  and
limited land  availability  will  drive research  into looking at  new  alternatives  to use
existing disposal facilities, such as vertical expansion  techniques.

Recommendations/Conclusions

     The  research concerns that  follow were  identified by  topic and  the  time frame
required  for  completion.    It  was  the  consensus  of   the  workgroup  that  the  areas
identified  would  best  be  implemented  by  the  Federal  government  and  that effort
should  be  made   to   disseminate   available   information   to   state   and   municipal
governments  as   quickly  as possible.    Research  needs  were  prioritized  within  each
topic relative to their perceived need for attention.

List of Research Needs

Siting

        Urgent priority (U)/Short Term  1-3 years (ST)         Waste characteristics

        U/ST                                                Characteristics of site

        High priority (H)/ST                                  Vertical expansion

        Medium  priority (M)/ST                              Monitoring (baseline
                                                              data)

        M/ST                                                Odors
                                             136

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Design
        U/Short and Long Term (SLT)


        U/ST


        U/SLT

        H/ST

        H/ST

Operational Monitoring

        U/ST


        U/Long Term 3-5 years (LT)


        U/SLT


        H/ST

        H/SLT

        H/ST

        H/ST


        H/ST

        M/ST

        Candidate for MITE Program (MITE)

Construction

        U/ST
Extended performance of
clay and FML (liners)

Leachate recovery
systems (LCRS)

Monitoring

Run-off control

Gas recovery
Daily covers and
alternatives

Rapid stabilization of
wastes (bioreactors)

Improved monitoring
(cost effective)

Leachate reduction

LCRS

Run-off control

Addition of sewage
sludge to system

Gas emission/recovery

Odors

Leachate evaporation
with landfill gas
 Better define QA/QC
 procedures
                                           137

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Closure/Postclosure

        U/ST


        U/ST

        H/ST

        M/ST

Miscellaneous Research Needs

        U/SLT

        U/ST

        U/SLT



        U/SLT


        U/ST
        H/ST


        M/ST



        M/ST
Old versus new site
requirements

Time of closure

Corrective action

Odors



Case studies

Characterization of waste

Technology and
information  transfer
(expert systems)

Exposure/Risk
assessment

Ash, sewage sludge,
hospital, and
pathological
waste (co-disposal
issues)

National standard for
composting (methodology)

Source separation/pre-
processing/pretreatment
(MITE)

Landfill mining
(composting, liner
replacement)
                                            138

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                MUNICIPAL PLANNING AND WASTE MANAGEMENT
Rationale
     Although  a  national concern,  management of  MSW  is  largely  the  responsibility
of local  government.   Local  and regional  MSW managers  are  the  "end-users" of MSW
technology.   Proper planning  based on sound data  is  an  essential  element  of  the
integrated  waste   management  approach.     The   problems,   needs,   concerns,   and
resources   of  individual  regions   and  communities   must   be   incorporated   into
management  strategy.    There  are  several  factors  that  need  to  be  considered when
deciding among alternative MSW programs, including:

     o  Composition and  volume of the waste stream

     o  Existing and planned disposal and recycling facilities

     o  Availability of. natural resources, including land

     o  Local economics

     o  Geography and geology

     o  State and local laws and regulations

     o  Public  opinion.

     Empirical  data on  which planning decisions  can be  made  must  be  available  for
use by local and  regional MSW managers.   Further,  managers  need  to  know  how  and
where  such  data  can  be acquired,  and how  to best  make  use of  these  data  in  the
MSW  planning  process.   The  goal  of  this  workgroup  was to  assess the  state  of  the
art  of MSW management and  to  report on  the  status and  needs of  MSW managers.
In doing  so, the  workgroup  was  to  identify  areas  that  MSW  managers  feel  require
more  data for  effective  MSW  planning, and to suggest  how  further RD&D  could be
used to fill these data gaps as well as assist in the planning process itself.
Participants

   Truett DeGeare (facilitator)
   EPA—OSW

   Richard F. Anderson
   Wheelabrator Environmental
     Systems, Inc.

   David L. Eger
   County of Fairfax, Virginia

   Haynes Goddard
   EPA/University of Cincinnati

   Joseph M. Greenblott
   Technical Resources, Inc.
Jeremy O'Brien
Public Technologies, Inc.

Ed Skernolis
Waste Management, Inc.

Jack Stanton
EPA—ORD/Tech.  Transfer Office

Edith A. Tanenbaum
Long Island Regional Planning Board
                                         139

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Research Areas

     Regardless  of sanctions,  local  politics  is often  the determining  factor of  MSW
planning decisions.    In  order  to  overcome  this  situation, people  must  be  both con-
vinced  that  chosen  alternatives  are  safe  and  encouraged  to  accept decisions  through
economic   incentives   and  penalties.    Information  is  needed  that  is  credible  to  the
public  on   both  new and existing  technologies.    Often, the  public   is  reluctant  to
believe  information even when adequate data exist.

     There  are  existing,  emerging,  and  new  MSW  technologies.    Proposed  RD&D
programs   for  MSW  place   the  majority   of  resources  into  new  and  emerging
technologies  by  emphasizing  increased  source   reduction  and   recycling.     However,
there appears  to  be  a deemphasis  on  existing technologies  in  solving  MSW  problems.
In order to  know where  resources should be placed,  the  planning  process itself must
be examined.  The planning process can be divided into four steps:

      1. Goal Identification

     2. System Analysis

     3. Alternative Evaluation

     4. Implementation.

     Goal  identification  refers to the  process of  delineating  the problems  and  needs
for  which  a  solution   must   be   found.     In  this   step,   the  specific   problems,
environmental  concerns,  and  waste, characteristics  of  a  locality  need  to be addressed.
However,   communities  need  better  waste  characterization  technology  and  sampling
methodology   to   accurately    assess    their    waste    stream,    including   industrial
nonhazardous solid waste, household hazardous  waste, and institutional wastes.

     A system  analysis   refers  to  determining  parameters  of  a specific  MSW  tech-
nology.   There  seems to  be  little difficulty  in  performing  system analysis.  However,
the  ability   to  perform • accurate   and  credible  analyses  between   various   MSW
technologies  is  limited.    Lack  of  data  and  methodology  for  performing  alternative
evaluation  is a  serious  impediment  to  deciding  from  among  various  processes  and  in
implementing an  integrated  MSW  management  plan.    Alternative evaluation   should
include  analysis  of all steps in MSW management,  including how  changes in the  waste
stream  result from  treatment  and  handling   processes, and  how  source  reduction and
recycling  will  affect   subsequent  MSW  management processes.   The evaluation  should
encompass  both environmental  and  economic  analysis  of waste  reduction,  composting,
recycling,  incineration, ash  management,  and  land disposal,  and  determine  both  the
costs  and  benefits  of individual  treatments  and  technologies.    This  includes  impact
assessments,  "cradle   to  grave" systems  analysis,  materials  selection analysis,  capacity
planning, and collection impact analysis.

     Implementation   of   MSW  management   plans  is  sometimes  difficult   even  when
adequate empirical data  exist  to support  management decisions.  The  public  is  often
reluctant  to  accept   the  credibility  of  data  supplied by  vendors  or  even local and
state  authorities.   Guidance  is  needed  in the areas  of enforcement,  compliance, and
implementability  of  MSW  management  decisions.    This   guidance  should  address  crisis
issues,  public  participation  models,  and  separate  and   integrated  fee  systems.    In

                                          140

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addition,  there  is  a  need for  analysis and development of  incentives  for  siting  MSW
facilities  and  for  assessment  and  guidance pertaining  to  the  decision-making  process
itself.

Recommendations/Conclusions

     The workgroup  concluded  that  there  is  a need  for a stronger leadership role on
the  part  of  the  Federal  government  in the  form  of  guidance  to  local  and  regional
MSW  planners  and  managers.     Guidance   is  needed  to   help  evaluate   alternative
management  plans; to  establish  what considerations  and  data  are  important  in  the
evaluation;  and  to aid  planners  in obtaining, analyzing, and  using the  acquired  data
in  the decision-making  process.    The  workgroup   recommended  that  the  following
activities be undertaken by the U.S. EPA to provide guidance and data:

     o Revise  the  1970s  and  1980s  literature   on   recycling  and  the   documents
        pertaining  to facilities  siting,  including  the  OSW report  (Centaur  Report) on
        hazardous   waste  (addressing   siting   issues  and  public  participation)  to  be
        applicable to  MSW.

     o Conduct  a national review of  alternative  technologies  from  a costs, benefits,
        and  risks  perspective,  including  recycling,   source   separation,   composting,
        waste-to-energy processes, and land  disposal.   The  review  should emphasize
        analyses   based  on  specific  materials  and  on waste   stream  characteristics.
        Analyses   should   also   include    macro-    and   micro-economic,  analysis,
        demonstrations, and case studies.

     o Prepare a siting  methods  analysis,   including  case   studies  of  failures  and
        successes.

     o Prepare  guidance  to  help  MSW  managers  evaluate  alternative  management
        plans,  including  what  questions   need  to   be  asked  and  where  to  go  for
        answers.

     o Fill  data   gaps  regarding  MSW   technologies  and  prepare  credible  analyses
        when necessary.
                                          141

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III.  LIST OF PARTICIPANTS
           143

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Richard F. Anderson, Ph.D.
Environmental Affairs Manager
Wheelabrator Environmental
 Systems, Inc.
55 Ferncroft Road
Danvers, MA  01923
(617) 777-2207

Jim Bridge
EPA/OEETD/RREL
26 W. Martin Luther King Drive
Cincinnati, OH 45268
FTS 684-7683

Theodore Brna, Ph.D.
EPA/AEERL  (MD-65)
Research Triangle Park, NC  27711
FTS 629-2683

Carl Brunner,  Ph.D.
Chief, MWWB
EPA/RREL
26 W. Martin Luther King Dr.
Cincinnati, OH 45268
(513) 684-7655
                 •
Warren Chesner, P.E.
Chesner Engineers
2171 Jericho Turnpike
Commack, NY 11525
(516) 499-1085

Marjorie J. Clarke
Program Director
Municipal Solid Waste Research
Inform
381 Park Avenue South
New York, NY  10016
(212)689-4040

David Colbert, Esq.
Chief Counsel
Subcommittee on Transportation,
 Tourism & Hazardous Waste
House Annex  II
Room 324
3rd & D Streets, SW
Washington, DC  20515
(202) 225-9304
Phil Cook, Ph.D.
EPA/ERL-Duluth
6201 Congdon Boulevard
Duluth, MN  55804
(218) 720-5553

James Crowder, Ph.D.
EPA/OAQPS
MD-13
Research Triangle Park, NC  27711
FTS 629-5596

Ken Cundari
Malcolm Pirnie
2 Corporate Park  Drive
Box 751
White Plains, NY  10602
(914) 694-2100

Truett DeGeare
Branch Chief
Municipal Solid Waste Program
US EPA—Office  of Solid Waste
OS-301
Washington, DC  20460
(202)382-3345

David DeMarini,  Ph.D,
ORD/HERL
MD68
Research Triangle Park, NC  27711
FTS 629-1510

Gerry Dorian
U.S. EPA-OEETD
West Tower G3C
401 M Street, SW
Washington, DC 20460
(202) 382-2583

Dana Duxbury
151 Hidden Road
Andover, MA  01810
(508) 470-3044

David Eger
Director
Fairfax County Division of Solid Waste
Fairfax,  VA  22030
(703) 256-5040
                                     145

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Taylor Eighmy, Ph.D.
Department of Civil Engineering
University of New Hampshire
236 Kingbury Hall
Durham, NH 03824
(603) 862-2206

Kurt Fischer
Associate Director of Research
Center for Environmental Management
Curtis Hall
Tufts University
Medford, MA 02155
(617) 381-3486

Mike Flynn
Branch Chief
Municipal Solid Waste Program
U.S. EPA—Office of Solid Waste
OS 323
Washington,.DC 20460
(202) 382-7920

Keith Forrester
Senior Environmental Engineer
Wheelabrator Environmental
  Systems, Inc.
55 Ferncroft Road
Danvers, MA  01923
(508) 777-2207

Larry Fradkin
EPA/ECAO
26 W. Martin Luther King Drive
Cincinnati, OH 45260
FTS 684-7584

Marge Franklin
Franklin Associates, Ltd.
4121 West 83rd Street
Suite 108
Prairie Village, KS  66208
(913) 649-2225

Holly Hattemer-Frey
Oak Ridge National Laboratory
P.O. 2008
Bldg, 4500 S.
Oak Ridge,  TN 37831-6109
FTS 626-2128
Hayes Goddard
EPA/RRL
Room 236
26 W. Martin Luther King Drive
Cincinnati, OH 45268
FTS 684-7685

John Greenberg
Browning-Ferris Industries
1150 Connecticut Avenue, NW
Suite 500
Washington,  DC 20036
(202) 223-0659

Joseph Greenblott
Environmental Scientist
Technical Resources, Inc.
3202 Tower Oaks Boulevard
Rockville, MD 20852
(301) 231-5250

Erica Guttman
Environmental Program Planner
Rhode Island Solid Waste Management
  Corporation
Waste Exchange Center
260 West Exchange Street
Providence, RI 02903

Mark Hammond
GRCDA
Solid Waste Authority of Palm Beach
  County
5114 Okeechobee Boulevard
Suite 2C
West Palm Beach,  FL  33417
(407) 471-5770

Roy Herndon, Ph.D.
Director
Center for Biomedical and
  Toxicological Research and
  Hazardous  Waste Management
361 Bellamy Building
Florida State University
Tallahassee,  FL 32306
(904) 644-5524
                                      146

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Dick Kattar
President
New England Crinc
74 Salem Road
N. Billerica, MA  01862
(508) 667-0096

James Kilgroe, Ph.D.
EPA/OEETD
AEERL (MD-65)
Research Triangle Park, NC 27711
FTS 629-2854

Vic Lambou
EPA/OADEMQA/EMSL-L V
LaPlaza
4220 S. MD Parkway
Plaza Building C
Las Vegas, NY 89119
(702) 798-2259

Robert Landreth
EPA/OEETD/RREL
26 W. Martin Luther King Drive
Cincinnati, OH 45268
(513) 569-7836

Will Laveille
EPA/OEPER
RD682
401 M Street, SW
Washington, DC 20460
(202) 382-5990

Steve Levy
OSW/MSWP
OS-323
401 M Street, SW
Washington, DC 20460

David Linz
Gas Research Institute
8600 W. Bryn Mawr Avenue
Chicago, IL 60631
(312) 399-8198

Rod Lowman
Vice President Government Affairs
Council for Solid  Waste
1275 K Street, NW
Suite 300
Washington, DC 20005
Jack Lyman
Director IRR
NSWMA
1730 Rhode Island Avenue, NW
Suite 1000
Washington, DC 20036
(202) 659-4613

Jim McNabb
Chief, EAEB
EPA/ORD/OEPER
Kerr Laboratory
P.O. Box 1198
Ada, OK 74820
FTS 7432216

Hector Mendieta
Chair, RCRA Subtitle D
Implementation Task Force ASTSWMO
Director, Division of Solid Waste
Texas Department of Health
1100 W. 49th Street
Austin, TX  78756
(512) 458-7271

James J. Nobel
Tufts University
Center for Environmental
 Management
Medford, MA 02155
(617) 381-3468

Jeremy O'Brien
Public Technology, Inc.
1201 Pennsylvania Avenue, NW
Suite 704
Washington, DC 20004
(202) 626-2471

Susan O'Keefe
Municipal Solid Waste Program
US EPA-Office of Solid Waste
WH565B
Washington, DC 20460
(202) 382-4489
                                    147

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Ronald Poland
Director of Environmental
 Engineering
Waste Management of North
 America
3003 Butterfield Road
Oakbrook, IL 60521
(312)572-3034

Gerald Powell
Editor
Resource Recycling
P.O. 10540
Portland, OR 97210
(503)227-1319

Sheila Prindiville
Program Director
NSWMA
1730 Rhode Island Avenue, NW
Washington, DC 20036
(202)659-4613

Bruce Pulson, Ph.D.
Manager
Plastics Environmental Affair
Quantum U.S.I. Division
11500 Northlake Drive
Cincinnati, OH 45249
(513) 530-6642

Frank Roethel, Ph.D.
State University of New York
MSRC SUNY
Stony Brook, NY  11794-5000
(516) 632-8732

Al Ruben
EPA/OW/OWRS
WH585
401 M Street, SW
Washington, DC  20460
(202)475-7311

Walt Schaub, Ph.D.
CORRE/U.S. Conf. of Mayors
Suite 600
 1620 I Street, NW
Washington, DC  20006
(202) 293-7330
Norbert Schomaker
EPA/OEETD/RREL
26 W. Martin Luther King Drive
Cincinnati, OH  45268
(513) 569-779

Roland Schrecongost
Deputy Division Dir.
EPA/Region III
3HWOO
841 Chestnut Building
Philadelphia, PA 19107
FTS 597-9492

Marion Sills
Environmental Defense Fund
1616 P Street, NW
Washington, DC  20036
(202) 387-3500

Conrad Simon
Director
Air and Waste Management Division
EPA/Region II
26 Federal Plaza
New York, NY  10278
(212) 264-2301

Ed Skernolis
Director of Regulatory Affairs
Waste Management, Inc.
1155 Connecticut Avenue
Suite 800
Washington, DC  20036
(202) 467-4480

Jack Stanton
EPA/ORD/OTTRS
RD 672
Washington, DC  20460
FTS 3827669

Sheree Stewart
HDR Inc.
Suite 225
5100 West Kennedy Boulevard
Tampa, FL 33609
(813)287-1960
                                      148

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David Sussman
Vice President for Environmental
 Affairs
Ogden Projects, Inc.
5301 Eisenhower Avenue
Alexandria, VA 22304
(703) 751-2523

Edith Tanenbaum
Long Island Regional Planning Board
H. Lee Dennison Building
Veterans Memorial Highway
Hauppauge, NY  11778
(516) 360-5195

Curtis Travis, Ph.D.
Oak  Ridge National Laboratory
P.O.  2008
Bldg. 4500 S.
Oak  Ridge, TN  37831-6109

Bob Van Deman, P.E.
Director of Solid Waste Management
2800-11Oth Avenue N
St. Petersburg, FL 33716
(813)892-7565
N.C. Vasuki
General Manager
Delaware Solid Waste Authority
P.O. 455
Dover, DE  19903
(302) 736-5361

Joseph Visalli, Ph.D.
Program Manager
NY State  Energy Research and NJ
 Development Authority
2 Rockefeller Plaza
Albany, NY 12223
(518) 465-6251

Carlton Wiles
EPA/OEETD/RREL
26 W. Martin Luther King Drive
Cincinnati, OH  45268
(513) 569-7795

Nancy Wolf
Environmental Action Coalition
625 Broadway
New York, NY  10012
(212)677-1601
                                     149

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               APPENDIX




COMMENTS TO DRAFT WORKSHOP PROCEEDINGS
                  151

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TO: Norb Schomaker

FROM: Jin Bridge

RE: NSW Researcft-jfgencft Review

DATE: January 20, 1989


Attached are my comments to the HSW Research Agenda Preliminary Draft for
Discussion.  Most of my notes reflect the Phase I R&D portion which has the
list of projects to reduce volume and toxicity of waste .

To summarize:
1.  We need  to  include a  project  to  go  back  to the  earlier  studies  for
reevaluation, especially at the curb, to determine the changes in  the
waste stream due to new technologies, new products on the market,  lifestyle
changes, and changes in costs.  The old recommendations with certain cost
factors may be acceptable today.
2. Some of the projects need to be expanded to include more of the "Pollution
Prevention" concept.  I normally see  this concept  shortchanged by the hazardous
waste minimization folks, but also recognize it when treatment and disposal
people gather to discuss research. Most of  these  projects focus on wastes that
have  been  generated.   For  example,  project  "e"  only mentions  less  toxic
substitutes rather than both toxicity and volume reduction.
3. It looks like we really need an assessment manual with economic benefits
for NSW much like our waste minimization opportunity assessment manual and
companion economics benefits manual being developed  by the Pollution Prevention
Office.
4. Item "g" should include federal facilities and particularly EPA through
the Regions.  The old "glass house" adage applies here!  Procurement practices
also fits with this project.
5. In item "1" ,  we must include all  of the  foreign products and packaging when
determining recycle and even process changes and product durability.  Haybe we
can figure a way to control import goods that generate wastes.
6. The WREAFS Program can help in  item "o" through studies with the  VA hospitals
and  technology  transfer  to other hospitals.    Because in  most  cities  like
Cincinnati, the hospitals are located in close  proximity to one another as well
as  clinics  and  doctors  offices,  there  should be some  consideration  for
centralized waste management practices.
7. Finally, I don't want to sound like the "L" word,but there is a need for
socio-politico-economic studies to determine the barriers to good HSW management.
I am aware that there are a myriad of reasons why people don't act the way we
think  they  should.    For  instance,  I  am aware  of  one  mainstream  Church
denomination that is making an issue on the "Theology of World Preservation".
This include world conservation as well as world peace, and this is certainly
an untapped avenue.  Education and indoctrination is needed through all groups
and organizations.
                                      153

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gft^{^3                                                      r^:

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  INFORM
  381 Pork Avenue South • New York, N.Y. 10016 • (212).689-4040
 Kenneth f. Mountcasfle. Jr.
 Chairman of the Board

 Linda Stamato
 Vice Chairman

 James B. Adier

 Michaei J. Feeiey

 Barbara D. Fiorito '

 Jane I?, fitzgibbon

 Kiku Hoagiand Hanes

 C. Howard Hardesty, Jr.

 Timothy L Hogen

 Lawrence S. Huntington

 Sue w. Kelly

 Martin Krasney

 Jay T. Last

 Charles A. Moron

•     Reich man

     r. Thoelen

 Grant P. Thompson

 Edward H. Tuck

 Frank A. Weil

 Anthony Wolff

' Joanna D. Underwood
 Executive Director
Gerry Dorian
OEETD, USEPA
RD-681
401 M St. SW
Washington, DC

Dear Gerry:
                                                            January  13,  1989
20460
     I have  looked over the draftProceedings of  the
Workshop on  Municipal Solid Waste Technology and overall
it is a good presentation,  and I hope the final  version
includes what EPA's response is to all the
recommendations  as well as the specific funding  requests
to Congress  for  research it will make and for what,  as
well as the  programs and regulations it proposes to
initiate in-house  to accomplish them.  In addition,  I
hope the final report gets wide dissemination,
particularly to  municipalities and state governments
where local  decisions are made, and to places of
research, including universities and private research
institutions,  as well as serious consideration,  cross-
fertilization, and implementation within EPA itself.  In
the very limited time I have had to review the document"),
I do have a  few  comments on the draft/ though, and they
follow:

#    page/para.      comment
1.   61        To  infer that the people who push
                     technological solutions to the solid
                     waste problem are not also in some
                     cases those who provide the  data is
                     rather naive, in that it ignores the
                     contribution and salesmanship of the
                     Jeff Hahns (Ogden), David Beachlers
                     (Westinghouse), Jim Donnellys
                     (JOY/NIRO), Mike Coopers (Foster
                     Wheeler),  etc....What is said in the
                     previous paragraph is true;  there
                     must be an independent, unbiased,  and
                     knowledgeable institution (e.g.  EPA,
                     in addition to INFORM) to evaluate,
                     sift,  and present useful information
                     and options to municipalities.
                        77
                     As regards source reduction  and
                     recycling being the most important
                     aspect of integrated solid waste
                     research, we were not coming up with
                     totally original thinking here.   In
                     the Agenda for Action and New York
                     State law, we noted that EPA had
                     already decided that these are the
                     most important waste management
                                          154

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77 cont'd      options.  Also,. I disagree that the source
               reduction group did not discuss who should do
               what.  We did say that EPA should be the
               Initiator, that is, the granting institution
               and the one which prompts what research is a
               priority.  That also means that there would be
               grantees, such as universities, private
               laboratories/consultants, industry labs, and
               even EPA labs which could do the necessary
               research.

78             Recycling is not only a service, it is more
               importantly a waste mangement option, just
               like resource recovery, landfilling and source
               reduction, which should be considered
               alternatives which are equally eligible to
               receive not only municipal dollars for the
               disposal/management of wastes, but also
               federal and state dollars for research into
               superior technologies (In terms of technical
               feasibility, economics, and environmental
               impact).  In short, there should be an equal
               playing field for all alternatives — none
              x should "have to pay for themselves" or "be
               left to industry to study" which is what the
               recycling.and source reduction options,
               respectively, have been required to do in the
               past.  It is the latter attitudes which have
               left incineration and landfilling the dominant
               means of waste management today.

     79       .1 don't believe we said that medical waste is
               the largest problem as regards disposables,
               though it was recognized that medical waste
               does consist largely and increasingly of
               disposables (perhaps unnecessarily on many
               counts).  I think it unlikely that medical
               waste, which is a small fraction of total
               solid waste, would be the major contributor to
               disposables in the solid waste stream.

               Also, I don't believe we said that we should
               identify the toxic constituents in materials
               so as to make them NONrecyclable!  I think
               there are two different issues here:  (1) to
               identify toxics in the waste stream items and
               (2) to encourage and design consumer products
               to be recyclable.  Regarding the latter, we
               also stressed the need for products to be
               designed so that they are easily repairable,
               reusable, refillable, rechargeable, etc.... —
               preferably so that the consumer him/herself
               could purchase and install replacement parts

                            155

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               and not just batteries,  as was described on
               page 82 but also all working/exhaustible
               parts.   Bicycles,  for example, are rather
               complex machines,  but they are, nonetheless
               designed so that the consumer can buy a book
               or take a course and purchase any replacement
               Item necessary,  Including the frame,  and make
               the necessary adjustment, installation,
               replacement or repair.  There are also many
               bike repair shops for people who don't want to
               bother.  Also, there are opportunities for
               trading-in rather than throwing away used
               models, and for buying used bikes.  Finally,
               bike stores still train people to be bike
               mechanics, so the continuation of this trade
               may continue into the future.   Unfortunately,
               none of this is possible for most other
               consumer products, and this list of reusable,
               repairable, etc.. items is becoming shorter
               daily.

80             An editorial comment:  Though the group did
               say EPA should convene more meetings with
               .industry and environmental sectors on source
               reduction, the one held by EPA last summer
               (sponsored by Conservation Foundation) did, by
               our accounts, not produce anything in the way
               of substance regarding industry's prior or
               planned actions in implementing or researching
               source reduction.  Thus, industry seems to
               require more incentive to move in this area.
               EPA could provide such incentive—be it
               economic, regulatory, informational, etc....

81             Regarding the training of people in schools,
               this extends not only to designers of consumer
               products as was indicated, but also the design
               of packaging.  For instance, Pratt Institute
               in Brooklyn has a whole degree program in
               packaging.  Who knows what is being taught
               there and whether minimization is even
               considered, much less encouraged, since many
               of the graduates undoubtedly end up on Madison
               Avenue designing the latest in chic
               (trendy=disposable, rather than classic, well-
               made=durable) fashions, furnishings, other
               products, and their packaging.

82             As regards who wants plastics to degrade if
               they are going to be recycled, the question
               should really be, why is plastic, an
               inherently indestructable material, being used
               in disposable items at all?  Since one of our
               most important tasks is to minimize the

                            156

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               creation of disposable, shoddily-made,
               unrepairable, unrefillable,  unreusable items,
               why not encourage that plastics not be used
               for such purposes at all, rather they (and
               preferably natural,  durable, or renewable, and
               recyclable materials such as paper, metals,
               ceramics, glass) should be used for durable
               products.  Certainly incentives could be
               structured to bring this about as a long-term
               strategy.

               In addition to the necessity to examine the
               lifetime, environmental costs and impacts of
               producing throwaway items (not throwaway vs.
               disposable as indicated on p. 82 which is the
               same thing), I mentioned that it is also
               necessary to examine the natural resource
               costs of this practice.  How long will the
               supplies of aluminum and other metals, and
               petroleum last if we continually plunder these
               finite resources for throwaway items (cans,
               batteries, gasoline, packaging, dinnerware,
               etc...)  A long-term solution necessitates
               consideration of the hope that the human race
               will survive for many millenia, but that the
               many of the Earth's resources and even
               renewable resources are now being depeleted at
               a fast rate, and that they can only be
               stretched so far before they are gone or can't
               be renewed any more.

83/3           Though it is a good idea to assess the
               environmental impacts of recycling processes
               already developed, it is a mistake to consider
               that recycling of a particular item might be
               less desireable than, say burning or burying
               it if (1) the two alternatives have not been
               compared on an even basis — that is, with
               BACT or LAER and the other best control
               technologies for both, and, if the recycling
               technology examined still seems inferior to
               burning or burying, (2) there is no impetus to
               do research to arrive at a environmentally,
               technically and economically superior
               recycling technology.  Not following this
               procedure is another example of an uneven
               playing field tilted in favor of the overall
               less favored solid waste management strategies
              .insofar as the EPA hierarchy is concerned.

128/2          One of the reasons that the actual cost of a
               product can be much higher than the initial
               outlay as a result of secondary fees like
               repair, replacement, downtime, etc... is that

                            157

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               the economy has moved not only  to throwaways,
               but the repair and reuse industries  have
               literally  dried up.  For whatever reason,  one
               cannot get certain things repaired anymore
               even  if one looks around and offers  to  pay a
               premium.   Some small electronics  are typically
               Just  thrown away when brought in  for repair
               even  when  all that is needed is a tiny  wire to
               be soldered or replaced.  Perhaps being a
               repairman  is not seen as a glamorous job and
               no one wants to do it anymore,
                 perhaps the reason is that there  is  no
               where to get the training to be a repairman,
                 perhaps the companies who make new products
               price replacement parts at an exorbitant price
               so it is not economically practical  either for
               the customer to pay for the  repair or for  the
               repairman  to keep a business going (this
               maximizes  profit for the manufacturer of new
               products — to keep sales and revenues  up),
                 perhaps the thrift shops  (Salvation  Army,
               Goodwill,  etc... have gotten finicky, greedy,
               etc... so  they won't pick up in certain
               neighborhoods, or they won't take anything if
               it has a scratch or a stain  because  they don't
               want  to fix it and don't think  it can be sold
               as is.   I have personally experienced  many of
               these things and  I suspect that all  of  these
               contribute to the overall problem, and  that
               financial  incentives by government would
               contribute to the solution.   As long as these
               issues are not addressed  and corrected, I
               don't believe that significant  source
               reduction  can occur.

               Additionally, since the per  capita generation
               of waste  rises at about  1% per  year  (Franklin
               & Associates)  —  this  due, I'm  sure, to the
               increasing number of  disposable,  shoddily-made
               consumer products on  the  market and  increasing
               sale  of these items  —  any source reduction
               must  be preceded by cessation of  design of new
               types of  disposables  and  reversal of the  trend
               towards nondurability in  manufacture.  If this
               issue is  not  addressed,  then implementation of
               other methods to encourage reusability .will
               likely be  an  uphill  struggle.

129/VR 3-4     These two  suggestions  need elaboration.
               Though the studies need  to be done,  they  are  a
               first step.   In  order  for society to act  in
               ways  which allow for  purchase and reuse of
               durable goods which have  minimum  environmental
               and natural resources  costs, it is necessary

                           158

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     133/11.A
     134-7
to spell out definitively how the findings of
the study will be implemented.  It does no one
any good to have a study gathering dust which
points out the ways to increase durability,
etc... and the comparative assessments of
durable vs. throwaway goods in terms of
disposal, lifetime, and environmental costs if
there is no mechanism to provide industry and
commerce the incentives to use the findings
and change "business as usual"or to provide
disincentives for not changing.

As regards fax machines, though it may be true
that they use more or environmentally
deleterious materials (paper), it is also true
that their use saves packaging for sending by
mail, saves handling by the post office or
overnight carrier, saves costs of the same,
saves gasoline, reduces the need for some
trucks (postal/overnight carrier), as well as
saving time.  Any comparisons between
alternative consumer products or technologies
must, to be fair, compare all environmental,
resource, economic, and technological costs
and benefits.

The outline of Visalli's talk does not give
the reader a good, complete picture of his
presentation.  Could more of the notes taken
by the recorder be added so that the
recommendations he may have made insofar as
EPA's research programs be made more clear?
     Again, thank you for the opportunity to participate in this
workshop and to review and comment on the Proceedings.  I will be
interested to see the final product and the plans for its
implementation both in terms of the research agenda, but also
whether and in what form other parts of the Agency (e.g. Office of
Solid Waste) will be.acting on some of the recommendations.  Also,
I would very much appreciate being given additional time to
comment on the incineration portion of the document.  If this is
possible, would you please let me know?

                                   Sincerely,
                              Marjorie J. Clarke
               Program Director, Solid Waste Research
                                 159

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                  FRANKLIN ASSOCIATES, LTD.
                 Engineering/Environmental/Management Consultants
                       4121 West 83rd Street, Suite 108
                        Prairie Village, Kansas 66208
                            913-649-2225
                       February 4, 1989
Ms. Gerry Dorian  (RD-681)
Office of Environmental Engineering
   and Technology Demonstration
U.S. Environmental Protection Agency
401 M Street, S.W.
Washington, D.C.  20460

Dear Gerry:

I have started to write this letter of  comments on the Source
Reduction and Recycling Workgroup  meeting October 3 several
times, but have found  it a  difficult  area to get a focus on.
Here is another try.

Source Reduction

1.  I agree that source reduction  should be at the top of the
management hierarchy,  but progress will be very difficult .to
measure.

2.  I agree that education  is the  most  important tool in
reducing waste.

3.  I agree that more  research is  needed into the effects of
removal of certain products (or  constituents)  in the waste
stream.

4.  I disagree with  some members of the Workgroup who thought
that EPA should be involved in the actual redesign of
products.  EPA  (and  its consultants;  are not qualified to do
that.  Toxic constituents could  be banned,  if necessary, but
industry would have  to be involved in finding substitute
products.  I do believe that focusing attention on the
problems  (e.g., education)  stimulates industry to come up
with solutions.

Labeling to identify toxic  constituents of products would
probably have the same effect, that is,  stimulating industry
to lower toxics, but that would  require some investigation.

5.  I agree that a Clearinghouse for  information is badly
needed.  I hear requests for this  everywhere I go.
                                 160

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Gerry Dorian    •                            February 4, 1989


6.  The issues of phot odegradat ion and biodegradation need a
lot more thought and investigation, and not just for
plastics.  I believe that the Subtitle D landfill criteria
will prevent many materials from degrading by keeping water
out.  That presumably also keeps their constituents out of
the groundwater.  On the other hand, it would be nice if
wastes in the ocean or littered would go away.  The effect on
recycling is a question, too.-  Some organizations other than
EPA are also working on this issue.

Recycling

1.  The lead/cadmium report confirms that battery recycling
should receive top emphasis in terms of reducing toxic
constituents in MSW.

2.  I agree that composting should get high priority because
of the large volume of yard wastes in most parts of the
country.

3.  Paper recyucling is also a high priority.   New/better
markets are needed for some waste paper grades.  For
instance, animal bedding is being tried as a use for old
newspapers.  Also,  hydromulching for roadsides (pulp made of
old newspapers mixed with grass seed)  could be considered as
a federal procurement item.

4.  A lot of good information is already becoming available
on methods for collection of recyclable materials:  curbside,
drop-off, buy-back, etc.  Technology transfer is needed.

5.  The suggested field work on waste composition will be
very expensive.  It looks like New York City will be spending
up to $1 million for theirs.  Better dissemination of
techniques and available data from other sampling activities
would be helpful right away.

I appreciate the opportunity to be part of these discussions.

                               Sincerely,
                               MarjorielA.  Franklin
                                161

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                         UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                    Atmospheric Research and Exposure Assessment Laboratory
                         Research Triangle Park, North Carolina  27711
   Date:  January 26, 1989

Subject:  Review of the Municipal  Solid Waste Research Agenda and Material  for Inclusion

   From:  Joseph E. Knoll, Chemist &Di*J<~<'^£j*£^~-^
          Source Methods Standardization Branch/QAD/AREAL (MD-77A)

     To:  Gerry Dorian
          OEEDT (WH-565B)
               The plan described in the MSW research agenda comes to grips with the
          municipal  waste problem in a way that is both appropriate and timely.   It
          divides the research needs into a number of areas which are sufficiently
          inclusive  to encompass any activity one might propose in the municipal
          waste area.  There is also a nice blend of practical  and innovative ideas.

               The enclosure contains a number of additions that deal with emissions
          and ash testing.  These need emphasis because of the  important effects
          stack emissions and ash have on the environment.   There is also the further
          consideration that such testing may be required by future legislation.

          Enclosure
                                            162

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Background
    An essential element in ash disposal is its categorization.  Ash that is
hazardous should be handled as a hazardous material, and ash that is not
hazardous should be treated in a different way and not be allowed to burden
hazardous waste disposal facilities.  Thus it is important to characterize ash
by developing sampling protocols, developing chemical and toxicity testing
protocols, and developing guidelines for separating ash into different categories,
according to the results of chemical and toxicity testing.
    If RCRA is reauthorized, regulations for municipal waste combustors may
require testing for emissions of particulate matter (total and fine), opacity,
sulfur dioxide, hydrogen chloride, oxides of nitrogen, carbon monoxide, lead,
cadmium, mercury, halogenated organic compounds, dioxins, and dibenzofurans.
Further, information about emissions of the following substances may also be
required:  volatile organic compounds, beryllium, hydrogen fluoride, antimony,
aresnic, barium, chromium, cobalt, copper, nickel, selenium, zinc, polychlorinated
biphenyls, chlorobenzenes, chlorophenols and polynuclear aromatic hydrocarbons.
Test methods for particulate matter (but not for fine particulate), the metals,
hydrogen chloride, dioxins and dibenzofurans are being validated at MWCs, but
will have to be developed for the other substances cited here.
    Further, as the Agency promulgates testing requirements, quality assurance
materials and procedures will  be needed to ensure that compliance tests are
competently performed, and that continuous emission monitors (CEMs) are cali-
brated and operated properly.
                                       163

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                         Phase I Research & Development

1.  TO REDUCE VOLUME AND TOXICITY OF WASTE
    b.  Update the State-of-the-Art of front-end separation technology.
        (Insert) A feasibility study on the use of robotics in waste separation
        will be conducted.
    c.   Assess environmental exposure and risks associated with recycling
         operations and recycled products.
         (insert) The emission of biological pathogens from air classifiers
         and pneumatic transport systems will be studied.
2.  IMPROVE THE SAFETY OF INCINERATION
    b.   Evaluate effectiveness of new air pollution control devices and waste
         combustion systems.
         As new devices come on line, conduct detailed stack tests, along with
         comprehensive waste characterization studies to determine the perform-
         ance, economics, and viability of these devices.  Develop, evaluate,
         and validate stack test methods for the criteria pollutants, semi-
         volatile organics, opacity VOCs, halogenated organics and hydrogen
         fluoride.  Develop methods for non-gas chromatographable compounds
         and for the speciation of metals in stack emissions.   Develop methods
         for the use of indicator compounds and indicator organisms to test
         the efficiency of combustion.  Validate continuous emission monitors
         and develop quality assurance materials and calibration standards to
         ensure that emission testing is competently performed.
                                       164

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MWC ASH/RESIDUALS MANAGEMENT
b.   MWC Residue and Leachate Characterization.
     (insert) Protocols for ash sampling and for chemical and toxicity
     testing will be developed.  Guidelines will be developed for separat-
     ing ash into different categories, on the basis of chemical and
     toxicity properties.  Methods for metals speciation will be developed
     to determine migration potential.
MSW LAND DISPOSAL
a.   Continue research into landfill gas emissions and recovery.
     (insert) Methods to determine biological pathogens, organo-mercury
     and sulfur compounds in landfill gas will be developed.
                                   165

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•:^K.;>M3&sgaMg^^^

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335 research institute
                                               January 12, 1989
        Ms. Gerry Dorian
        Office of Environmental Engineering
          and Technology Demonstration
        U» S» Environmental  Protection Agency
        RD-681
        401 M Street, S.W.
        Washington, DC   20460

        Subject:  Comments on MSW Workshop Proceedings

        Dear Ms. Dorian:

        Comments are provided on the combustion sections of the proceedings only
        (5.2,/Section II).   The transcription of the proceedings seems complete.
        However, there are numerous typographical errors and in some dases the wrong
        words have been  used.

        In general, Section  5.2 is a good summary of the discussion in the work
        group.  On page  90,  the first paragraph discusses retrofitting of existing
        incinerators.  I want to emphasize the importance of this activity and that it
        should be given  high priority, especially in view of the fact that
        retrofitting of  technologies like spray dryers and fabric filters may be very
        costly and difficult on some of these existing units, particularly the older
        ones.

        Paragraph 2 on page  90 outlines the need for more basic research and
        understanding of the mechanisms involved with waste combustion.  I agree with
        the need for this and that it should be very high priority.  In addition,
        I would add that there are other pollutants which are equally Important
        besides organics such as dioxin.  The other pollutants include metals, of
        which the questions  would be the effect of temperature and partitioning of
        metals to the flue gas stream versus the residues.  Another important
        pollutant is NOZ.  The effect of the combustion process on NOX formation
        and NOX emissions levels should also be investigated.

        In paragraph 3 on page 90, the last sentence talks about a "middle ground"
        between controlling  organics and controlling NOX.  The implication is that
        there is some trade-off or compromise between emission levels of organics and
        NOX.  This in general is true for a simple single-stage combustion; however,
        it is well known that fuel or air staging can achieve reduced levels of NOX
        ang very high combustion efficiencies (i.e., low levels of organics and CO and
        NOX).  Examples of this are the NKK waste incinerator concept used in Japan
        and the use of reburn for NOX control in coal-fired utility boilers.

                                               166
       Gas Research Institute, 8600 West Bryn Mawr Avenue, Chicago, Illinois 60631   312/399-8100

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Ms. Gerry Dorian
January 12, 1989
Page Two
One final item that could be mentioned in Section 5.2 is that of
co-incinerating waste, e.g., as municipal waste with other types of wastes
such as sewage sludge or tires or perhaps even medical wastes.  The R&D issues
associated with this practice would be the development of control systems such
that this co-incineration process could take place in a well controlled and
efficient manner; and the range of applicability and limitations of the
co-incineration concept.

In contrast to Section 5.2, the summary of work group conclusions/
recommendations section, which for the combustion work group begins on
page 139, in my opinion is not very well done and does not in all cases
reflect the discussions of the work group.  I believe this section needs major
revisions; unfortunately, I don't have the time or resources to rewrite the
section.  I will offer a few comments, however.  In general, I think the
combustion technologies have been short changed in comparison with the
extensive discussions on risk assessment.  There are some statements in this
section that are policy-type statements and I don't feel these appropriate for
a discussion of an R&D agenda.

On page 143, the first full paragraph right in the middle of the page, a
sentence that starts, " The work group felt . . ."is such a policy statement
and I don't think it was endorsed by the entire work group as the sentence
implies.

On page 144, the second paragraph is another example of a policy-type
statement, "Permit specification should allow reduction ..."  This should
not be the subject, but rather, this section should outline the R&D issues or
technical issues that should be addressed to demonstrate that proper
monitoring of an incinerator operation will ensure good operation and
acceptable emissions performance.  This is the technical issue which needs to
be researched.

On page 142, the paragraph at the bottom of the page is very confusing.  The
sentence that begins, "The best measure of good combustion ..." may express
the opinion of one working group member; however, this matter was not
discussed in the work group.  This discussion is incomprehensible and, I
believe, incorrect.

Turning to the Recommendations/Conclusions on page 144, the very first item
"GEM should be increased . . ."is confusing as written.  Furthermore, I
disagree with the focus completely.

Missing from the list of items in this section are two which I think are the
most important.  The first is the recommendation that more work should be done
on understanding the combustion process, including the formation mechanisms
and release of NOX, metals, organics*  A better basic understanding  of the


                                        167
                              Gas Research institute

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Ms. Gerry Dorian
January 12, 1989
Page Three
combustion process is important, both as a basis for lowering emissions and as
a basis for improved monitoring to better control and measure the efficiency
of the combustion process.

Another item deserving high priority is the validation of the best combustion
practices, guidelines and various retrofit strategies.  This information will
be especially important because of the organizations most likely involved or
interested in this information—that is, municipalities.

Finally, the last item on page 145 is another example of a policy-type
statement that doesn't belong in this section.

If you have any questions on my comments, please call me at 312/399-8198.

                                       Sincerely,
                                       David G.
                                       Manager
                                       Land and Water Quality Research
DGL:Djm
                                        168
                              Gas Research Institute

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              UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                              REGION III
                          841 Chestnut Building
                      Philadelphia, Pennsylvania 19107
                                                      JAN 10 1989
Ms. Gerry Dorian
OEETD
U.S. Environmental  Protection Agency
RD-681
401 M Street, S.W.
Washington, DC  20460

Dear ^/Dorian:

     Thank you  for  the opportunity to review and comment  on
the draft proceedings  of  the Workshop on Municipal Waste
Technology.  We believe the proceedings have been  identified
the major areas of  concern that the agency should  address in
its future research activities.  Of equal importance  is the
availability of adequate  funds to support all of these
initiatives.  We  would like to review the final program plan
when it  is complete^
                               Very truly yours,
                               Albert Montague, P.E.
                               Regional Solid Waste Manager
cc:  Robert  Allen
                                   169

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          UNITED  STATES ENVIRONMENTAL PROTECTION AGENCY

                   OFFICE OF RESEARCH AND DEVELOPMENT

                   RISK REDUCTION  ENGINEERING LABORATORY
                              CINCINNATI, OHIO 45268
DATE:     January 27, 1989

SUBJECT:  Municipal Solid Waste Research Agenda
          Workgroup Task
FROM:     Norbert B. Schomaker
          Acting Director, Waste Minimization, Destruction
          and Disposal Research Division, RREL

TO:       Gerry Dorian
          Workgroup Chair


      My comments relate to the proposed format and to the concluding remarks
of the Workshop Proceedings.  In regard to .the proposed format, my comments
are as follows:

      Background:  I agree that we need to identify which waste streams
      we are discussing.  (1) Residential household waste, (2) sewage
      sludge, (3) commercial waste, (4) yard waste, (5) agricultural
      waste, (6) industrial nonhazardous wastes and (7) demolition
      rubble waste are the primary waste streams which relate to
      Subtitle "D" regulations.  Are we to pursue research into all of
      these waste streams.  If so, I would propose that we research them
      in the priority order as listed above.  Also, an appendix could be
      identified in this section which lists, by categorical research
      areas, the previous reports published by the Agency on this
      subject.

      Research Area:  The research areas identified follow the general
      hierarchy of integrated waste management as discussed in the
      "Solid Waste Dilemma:  An Agenda for Action."  The hierarchy
      included:  source reduce, recycle, incinerate and landfill.  The
      one component missing is collection.  I believe new techniques
      relating to waste collection needs to be considered.  Also, I
      concur that some write up is needed to briefly explain the
      recommendations listed under the research areas.  I have reviewed
      the previous documents on the subject and I believe the following
      outline is appropriate.

      1.    Waste Reduction* (Includes Source Reduction and
            Recycle)

            a.  Process Manufacturing Change

            b.  Market Development (Includes Product Development)

            c.  Separation


                                       170

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      d.  Recycling
      e.  Biodegradation
      f.  Toxicity Reduction
      g.  Risk Assessment (Includes Health and Environmental)
      h.  Case Studies
      i.  Technology Transfer
2.    Waste Collection*
      a.  Curbside Containers (Includes Household Containers)
      b.  Residential Truck Modification
      c.  Transfer Truck Modifications (Includes Transfer Station)
      d.  Rail Haul
      e.  Barge Haul
      f.  Case Studies
      g.  Technology Transfer
3.    Municipal Waste Combustion*
      a.  Combustton Performance
      b.  Emission Control
      c.  Monitoring (Includes Sampling Protocol)
      d.  Waste to Energy
      e.  Risk Assessment
      f.  Case Studies
      g.  Technology Transfer
4*    Municipal Waste Combustion Residuals Management
                    j
      a.  Ash Handling
      b.  Emissions Control
      c.  Monitoring (Includes Sampling Protocol)
                                   171

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           d.  Treatment  (Includes  Metal  Recovery)
           e.  Market  Development  (Includes  Product Development)
           f.  Risk Assessment
           g.  Case Studies
           h.  Technology Transfer
      5.    Land  Disposal*
           a.  Landfill  Performance
           b.  Emission  Control
           c.  Monitoring (Includes Sampling Protocol)
           d.  Biodegradation  (Includes  Composting)
           e.  Expert  Systems
           f.  Closure/Post  Closure
           g.  Corrective Action
           h.  Risk Assessment (Includes Siting)
            i.  Case Studies
           j.  Technology Transfer
      6.    Municipal Planning  and Waste  Management*
            a.  Workshops (Includes Attitudinal  Problem)
            b.   State of the Art
            c.   Economics
            d.   Expert System
            e.   Case Studies
*Refers to all  waste streams mentioned earlier.
      From the above outline, it can be seen that certain research topics
appear commonly throughout all  the research areas (i.e., market development,
monitoring, risk assessment,  case studies, and technology transfer).  These
topics could become research areas to themselves.  Also, note the asterisk
above relating to all waste streams.  This means that, for example, sewage
                                       172

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sludge would be investigated under all research topics.  I am sure that sewage
sludge alone could merit its own research program just like combustor
residues.  This needs to be considered.

      Comments regarding the concluding remarks from the workshop proceedings
are as follows:

      1.    In what areas should EPA be conducting research to
            understand the fundamentals?  From a fundamental
            research standpoint, I do not believe we need to do
            research in any area except the market development
            aspect.  Fundamental research has been done and I
            believe many of the concepts derived from this
            research are still applicable.  The cost/economics of
            this application to the current market needs to be
            addressed.  We can expand on our current knowledge to
            have a better data base to render decisions.  This
            data base expansion has been identified in the above
            comments relating to the proposed research outline.

      2.    In which areas should we be evaluating private sector
            activities?  In the above discussed research outline,
            this subject is identified as "Case Studies."  I
            believe we should evaluate the private sector in all
            of the research areas discussed.

      3.    Where are we talking about the need for EPA to simply
            put together existing information on the state of the
            art and package it in documents that people can use?
            I believe we need to put together a SOA document in
            each of the research areas initially, just to set the
            stage for fu-ture development.  Over the last ten years
            there have been SOA documents published in these
            research areas.  We are currently working with OSW on
            an update to the "Sanitary Landfill Guidance Document
            for MSW."  These SOA document preparations need to be
            coordinated with OSW who are also processing the
            development of various SOA documents covering a
            variety of topics.  After the initial SOA document is
            prepared, then periodic updates depending upon
            generation of new data is appropriate on a regular
            time cycle.  In the area of waste collection, since
            this area was not identified in the hierarchy of
            integrated waste management and since no research has
            been pursed by the Agency for the last 15 years, this
            might be an area of strong interest under the pending
            MITE program.

      4.    In what areas should we establish standards of good
            practice that can be used by state agencies in
            overseeing and regulating activities at the state
            level?  From the standpoint of "we" as Federal

                                       173

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      facilities (including DOD and DOE) I think we could
      establish standards of good practice in all the topics
      mentioned in the previously discussed research
      outline.  If "we" means USEPA, I think the good
      practice standards could relate to waste reduction,
      specifically source separation and recycling.
5.    In what areas is it appropriate for EPA to do actual '
      development work?  Actual development work for EPA
      could be pursued in the following research topic areas
      as identified under the research outline below:
      1.    Waste Reduction
            a.  Process Manufacturing Change
            b.  Market Development
            f.  Toxicity Reduction
            g.  Risk Assessment
      2.    Waste Collection
            No development work except for co-funding under the MITE
            program.
      3.    Municipal Waste Combustor
            a.  Combustion Performance
            b.  Emission Control
            c.  Monitoring
            e.  Risk Assessment
      4.    Municipal Waste Combustion Residuals Management
            a.  Ash Handling
            b.  Emissions Control
            c.  Monitoring (Includes Sampling Protocol)
            e.  Treatment
            f.  Market Development
            g.  Risk Assessment
                                  174

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5.    Land Disposal
      a.  Landfill Performance
      b.  Emission Control
      c.  Monitoring (Includes Sampling Protocol)
      d.  Biodegradation
      e.  Expert Systems
      f.  Closure/Post Closure
      g.  Corrective Action
      h.  Risk Assessment (Includes Siting)
6.    Municipal Planning and Waste Management
      c.  Economics
      d.  Expert System
                            175

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                                                Walter M. Shaub, Ph.D.
                                                  Technical Director
                                         Coalition on Resourca Recovery and the Environment
                                         U.S. Conference of Mayors
                                          1620 Eye Street. N.W.
                                         WMhiacton. D.C. 2000«
January 10, 1989

Ms. Gerry Dorian
Office of Environmental  Engineering
     and Technology  Demonstration
U.S. Environmental Protection Agency
RD-681
401 M Street,  S.W.
Washington, D.C.  20460

Dear Gerry,

I have  received  your  letter of  December 15,  1988  in  which you
request  review  and  comments   regarding  the    Draft  of  the
Proceedings of the  Workshop  on Municipal Solid Waste Technology
that I participated  in  on October  3-4,1988.   My  comments are
appended  to   this   letter.   They are restricted  to  observations
regarding the  material that is presented  on pages 139-145 which
appears to  be a   synthesis of  the actual  discussions  that took
place during  the  session on Municipal Waste Combustion at which I
was  a  participant.    The  synthesis appears  to  be  nicely done.
Consequently  my comments are either to  clarify some  points that
were  raised   or   to  indicate  areas  where  I feel  I have minor
disagreements  with the general sense of the group.

The Draft  report  also  contains a  summary by   Mr. James Kilgroe,
U.S. EPA—OEETD of the group activity.  This appears  on  pages 88-
95.   Mr.  Kilgroe  made his  remarks at   the time   of the meeting
without   benefit   of  the  tape  recording  of  the group meeting.
Therefore  I  regard his remarks  as  being representative  of his
personal   opinion  of  what  transpired.  Everyone is entitled to
their  own opinion, therefore it seems  to  me  inappropriate to make
any  observations  about   Mr.  Kilgroe's  remarks,  as  I  assume the
Draft  is  a faithful re-counting of  exactly what   it  was  that he
said.

 I  was   not  a  participant  at  other   sessions  of the Workshop.
Therefore I am hot  making any comments  about   other sections of
the Draft  report.   Thank you  for allowing  me to participate in
this  exercise.

 Sincerely,
(202)293-7330
Dr. Walter M. Shaub
Technical Director, CORRE

end.
                                 176

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            COMMENTS REGARDING OEETD OCTOBER 3-4 WORKSHOP

                          Remarks made by:

               Dr.  Walter  M.  Shaub,  Technical Director
         Coalition  on Resource Recovery and the Environment
                    The U.S.  Conference of  Mayors
                          Washington,  D.C.

  On  page 139.

  1.  My last name is spelled  HShaub,11 not "Schaub."

  On  page 140...

  2.  Perhaps  the phrase "...risks to different demographic groups11
  could be written  as "...risks to  different biological receptors*
  to  emphasize  that risk   analyses  consider more than just impacts
  upon  human populations.

  3.  Regarding the  six aspects of risk assessment, I feel  that the
  highest priority  item is item 13 - Comparative analyses.

  On  oaae 141...

  4.  I'm not so sure that  food chain data is "almost non-existent,"
  but certainly It  would  be  useful   to put .all the  data  into one
  place and evaluate its reliability.

  5.  Given the  level of funding that EPA appears likely to  receive,
  I think that  to   develop standard  data   sets  may  require some
  inter-governmental Agency interactions.

  On  page 142.

  6.  Regarding  the  comment  per  sensitivity of the incineration
  process to  changes in  the chemical  and physical  nature of the
  waste stream,  that there  is an  "extreme" need for data in this
  area:  I would not use the  word "extreme" to indicate the present
  situation.    We know  a  fair  amount about  physical and  chemical
  processes associated with incineration.  Consequently we  are able
  to  use  scientifically based  heuristic reasoning to infer likely
  effects absent a  lot of  data.  The role of the data  is to refine
  our understanding  and to check our reasoned inferences.   So far,
  what  data has become  available seems  in my  opinion to  Indicate
  that  there aren't likely to be any surprises, i.e., outcomes that
  differ substantially from what can  be  inferred.    In addition,
  given that  control and   treatment technologies can be applied to
  incineration, there are  opportunities  to  control  emissions and
  residue absent  direct data-based  knowledge of effects associated
  with  changes  in the solid waste stream.
                                  177
. *-'Ji.'-'f i i*™''_*i> •*:•'„• "*.!•'•' • ";"•• '•<'.'•

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7, per the statement  that "The  best measure  o£ good combustion
design and  incineration effectiveness  is the  heat release rate
per cubic foot of fuel and waste mixture.":

First, in a direct sense, I think it may be important to consider
design and  effectiveness as two separate aspects of Incinerators
- we don't speak of monitoring design; we do  speak of monitoring
effectiveness (e.g.,  emissions monitoring).  Second, in relation
to the latter aspect of  incinerators,  my  own  opinion  Is that
combustion stability is the most important Indication of reliable
performance, whether it be relevant  to  power  generation  or to
emissions minimization.

if emissions  minimization associated with combustion performance
in the combustion  chamber  is  of  Interest  then  I  think (for
reasons that  I can  justify absent  any experimentally developed
correlations) It Is Important to maintain  stability in  the long
term  in  carbon  monoxide  emissions.  Post-combustion emissions
characteristics and pollution  abatement  control  devices  are a
separate  aspect  of  incineration  which  I think are reasonably
discussed on page 144 of the draft report.

On page 143...

8. If the intent is to  suggest that  we don't  .know how,  then I
disagree  with  the  statement,  "...it  Is difficult to design a
reliable and efficient incinerator."   In  fact, actual operating
experience and  tests have  shown that we do know how to design a
reliable and efficient incinerator.   If  there are shortcomings,
it is  more related  in my  opinion primarily  to lack of a clear
establishment  by  legislators   and   regulators   as   to  what
performance is required or expected; secondary issues are related
to operational requirements and to monitoring requirements.  None
of  these  issues  are  associated, however, with shortcomings in
system design expertise.

9. Regarding the comment that "The workgroup felt that EPA should
either  be  willing  to  accept  direct  responsibility  for  the
operational performance characteristics of  incinerators designed
according  to  BMP  guidelelnes,  or should provide 'performance-
based'  standards  that  allow  for  innovation  on  the  part of
operators and  require the operators to assume responsibility for
the performance of their incinerators":

I give the higher  priority  to  performance  standards.    In my
opinion, BMP guidelines should only be a consideration when there
is no metric of performance readily available at reasonable cost.
Given that  there are  surrogate indicators  that can  be used to
gauge performance I feel that  the  only  acceptable  use  of BMP
guidelines is with the proviso that implicit in BMP guidelines is
the concept embodied in the phrase, "or equivalent."  Absent such
an understanding  we might as well throw technological innovation
out the window, because  in my  opinion that  is exactly  what is

                                178

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likely to  happen if  unreasonably restrictive BMP guidelines are
established.  ...And what happens  if  more  affordable  means to
accomplish the  same ends are developed but cannot be implemented
due to overly restrictive BMP guidelines?

10.  I  would  rephrase  the  statement  "Additional  efforts  in
monitoring  and  control  of..."  to read, "Additional efforts in
understanding/evaluating  prospects  for  monitoring  and control
of..."

On page 144...

11.  I  would  rephrase  the  statement,  "The list of pollutants
subject to CEM requirements should be  trimmed..." to  read, "The
list of  pollutants subject directly - or indirectly, if there is
an  appropriate  surrogate  -  to  CEM   requirements  should  be
trimmed..."

12. I  would change  "CEM should  be Increased and focused toward
filling data requirements of  RA models"  to read  "CEM should be
focused   toward   demonstrating   compliance   with  performance
standards."

on page 145..,

13.  I  would  change  "An  ambient   monitoring  program  should
be%	.from incinerators"  to read "Research aimed at an ambient
mon*itoring program  should  be	from  incinerators* recycling
plants, landfills, compost operations, etc."
14. In  regard to  an assessment
mercury and mercury control....
of health risks associated with
...have you  examined the  evaluation of  Impacts associated with
mercury  emissions  that  was  discussed  in  the risk assessment
prepared by Dr. Allan  Smith, Ph.D.,  M.D. for  the Brooklyn Navy
Yard Resource Recovery Facility?

...have you seen the OECD document which indicates what technical
and economic problems have been encountered  regarding control or
reduction of mercury in OECD member nations?

...if not,  I can  provide you with this information if it is not
available to you.

15. I think the very last observation on  the bottom  of page 145
should be bold-faced when the report is printed.
                                179

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                     UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
                                          REGION II
 DATE:    JAN  1 2 jggg


           EPA's Research Agenda for Solid Waste

 FROM:      Conrad Simon, Director
           Air and Waste Management Divisl

           Gerry Dorian
           Environmental Scientist and Engineer

           Thanks for the copy of the proceeds.  My review indicated that the workshop
           was successful in getting a large number of ideas which need to be converted
           into specific projects.  I don't feel that I can make this conversion as
           well as potential contracters can if a solicitation were made.

           I am sorry that I did not get a chance to edit the transcript of my remarks
           in chapter 5.  I believe that there is sitll something to be gained from
           correcting pages 77-80 to make them more readable.  Thus I have provided
           substitute pages.
                         [ Ed. note: The substitute pages have been incorporated

                         in the Proceedings and therefore do not appear in the

                         Appendix.]
                                               180
REGION II FORM 132O-1 (9/86)

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           HDR Engineering, .Inc.
D  R
                    Suite 225
                    5100 W. Kennedy Boulevard
                    Tampa. Florida
                    33609-1806
Telephone:
813287-1960
           January 14, 1989
Ms. Gerry Dorian
OEETD
U. S. Environmental Protection Agency
RD-681
401 M Street, SW
Washington, DC  20460

Dear Ms. Dorian:

Thank you for the opportunity to comment on the draft  proceedings  of the
Workshop on Municipal Solid Waste Technology.  I  enjoyed  participating
in the workshop and found it very positive and thought-provoking.

In general, the question/response sections would  be much  more
informative if they were rewritten by the appropriate  participants from
EPA.  Due to the format and time limits of the sessions,  it  was
impossible for the EPA participants to formulate  good  answers  to the
individual questions.  If these sections are to be included  in the final
Research Plan, the responses should be rewritten  and expanded.

It is unfortunate that there is limited input from public officials.
Perhaps it would be useful to solicit comments from several  more county
and local government officials before finalizing  the Research  Plan.

The comments included herein are not limited to any one area of  the
program.

Municipal Waste Combustion Residuals

The summary of the workshop session on residuals  management  (pg. 146)  is
very informative.  Of all topics discussed in the session, one
particular area that did not receive enough attention  was standards  for
landfill/monofill construction.  In developing the final  Research  Plan,
consideration should be given to examining the standards  recommended in
the EPA Draft Guidance (1988).  EPA should consider the applicability of
uniform design standards to construction of monofills.  If design
standards are the preferred approach, local government should  have the
option to implement performance standards in lieu of design  standards.
EPA could specify certain (limited) parameters that could be used  to
re-evaluate the standards for construction.  For  example,  local
government may only consider three parameters:  1) leachate  quantity,  2)
operating controls and 3) background groundwater  quality  as
justification to change standards.  The ORD workgroup  should give
consideration to recommending that the EPA Draft  Guidance be expanded
and re-issued as soon as possible.
                                           181

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Ms. Gerry Dorian
Page Two
January 14, 1989

Municipal Waste Combustion Program (pg. 11)

EPA is collecting an impressive amount of data in the Municipal Waste
Combustion Program.  The type of data being collected appears to be
appropriate for the purposes of standard setting.  However, EPA's intent
regarding the format and extent of the NSPS for waste combustion is not
clear.  Therefore, the adequacy of their data collection program cannot
yet be assessed.

In setting NSPS, and in their research program, EPA should carefully
consider the heterogeneous nature of solid waste and hence, the
variability in emissions.  This should affect the averaging times for
NSPS that are set as emission limitations.  In addition, EPA should
consider the variability in stack sampling and analysis techniques in
their standard setting.  In particular, EPA should consider the parallel
testing efforts conducted at the Commerce facility by the Los Angeles
County Sanitation Districts and the California Air Resources Board
(CARB) in July and August of 1988.  This effort shows that differences
in results can occur even when much effort is made to exactly duplicate
test conditions.  This is particularly a problem when considering the
extremely small quantities per sample of the trace metals and organics.

Municipal Waste Combustion (pg. 88, 139)

Regarding continuous emission monitoring (CEM), it is not clear what is
meant by focusing efforts only on "biologically active" components of
emissions.  If this means that these are the only pollutants that should
be monitored, then we disagree with this recommendation.  Components of
the flue gas such as 02 and CC>2 should be continuously monitored if they
can be used as a surrogate for the continuous monitoring of other
substances such as toxic organics.  EPA should expend a considerable
amount of effort to determine those parameters that can be continuously
monitored in order to give a continuous evaluation of facility
performance.  In terms of the cost.of monitoring, EPA should consider
whether additional CEM data could be used to eliminate or reduce the
need (and associated costs) for frequent stack sampling of trace metals
and organics.

The research program identified by workgroup participants to improve the
various components of health risk assessment has some merit.  However,
it seems even more important that EPA determine how health risk
assessment can be used as a tool to aid agency decision-making and
standard setting.  Perhaps this is part of the workgroup recommendation
for standardization of risk assessment approach.  This allows the
comparison of the results of risk assessments for different projects.

In discussing the use of risk assessment (p. 141), it is stated that
there should be comparative analysis of the alternatives to
incineration.  Recycling and waste reduction efforts are given as
examples.  We do not think it is appropriate to compare recycling and

                                182

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Ms. Gerry Dorian
Page Three
January 14, 1989

waste reduction directly with incineration as these approaches are not
capable of addressing the same quantities of solid waste.  In addition,
all three of these "alternatives" are not really alternatives, but
rather potential components of an overall waste disposal strategy.  As
such, it is not valid to compare the risks of individual components of
solid waste management, but rather it is valid to compare alternate
strategies of waste disposal.  These strategies may consist of various
amounts of reliance on recycling, waste reduction, composting,
incineration and landfills.

Thank you, again, for the opportunity to comment on the draft
proceedings.  Please don't hesitate to contact me if there are any
questions.  I also look forward to participating in the Solid Waste
Technology conference in San Diego later this month.

Sincerely,

HDR ENGINEERING, INC.
        . Stewart:
Project Manager

SLS/tl
TL-SS-Q

cc:  Richard J. McCormack, VP, HDR Engineering, Inc.
                               183

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OGDEN MARTIN
SYSTEMS,  INC.
 301 EISENHOWER AVENUE                                             AN QQDEN COMPANY
ALEXANDRIA, VIRGINIA 22304

DAVID B. SUSSMAN
VICE PRESIDENT
ENVIRONMENTAL AFFAIRS        .        December 27, 1988
(703)751-2523
      Gerry Dorian
      OEETD  RD-681
      US Environmental Protection Agency
      Washington DC 20460


      Dear Gerry:

           I've reviewed the draft proceedings of the Workshop on
      Municipal  Solid Waste Technology and  found them to  be an
      accurate reporting of the meeting.  There are,  however, a few
      items worthy of comment.

           First, I do not believe there is as much support for the
      MITE program as the proceedings indicate.  In other words, we
      hate it.  Let's not stop the wheel again.

           Secondly,  as  the Agency  cannot  make up it's mind with
      regard  to  NOX emissions  and BACT,  I suggest more effort be
      directed toward resolving that internal conflict. . Whether it
      be  development  or evaluation  of control technologies,  or a
      decision as to what BACT is, a position is necessary.

           The last item is CEM.   The requirement for  "reasonable"
      CEM  is extremely"  important.   EPA  should  focus on  what is
      necessary  to protect  public  health, and  should  strive to
      lower  the  cost  and complexity of systems.  We cannot have a
      viable  industry  if  we  have  to monitor  everythingI    In
      addition,  in the  first paragraph on page  144, there  is  a
      discussion about opacity.  Opacity is a low-cost  CEM which is
      a surrogate  for  gross  particulate  emissions.   From  the
      discussion,  one could get  the  idea that  opacity CEM  is  a
      problem.

           Should you need any more  information, please call.

                               Sincerely,
                            David B. Sussman
                                   ISA

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       Long Island  Regional Planning Board
Edward Cook
  Chairman
John J. Hart
  Vice Chairman
Patrick F. Caputo
Paul J.Fitzpat rick.
John Wickham
John W. Wydler
Lee E. Koppelman
  Executive Directors. Gerry Dorian
             Office of Environmental Engineering
               and Technology Demonstration
             U.S. Environmental Protection Agency
             SD-681
             401 M Street, S.W.
             Washington, D.C.  20460
                                             H. Let Dennison Executive Office Building
                                       Veterans Memorial Highway, Hauppauge, LI., N.Y. 11788
                                                 Area Code (516) 360-5189
                                         January  11,  1989
                       Proceedings of the Workshop on Municipal
                       Solid Waste Technology
      Re:
Dear Ms.  Dpriaq:

     I  have read the draft of the Workshop Proceedings.   The task was
•far less  onerous than I had anticipated.  EPA and  its  consultants have
done an excellent job of summarizing the comments  and  translating our
thoughts  into coherent and comprehensible language.

     As per instructions, I am enclosing a list of typo's,  questions and
corrections.   I'm sure most of them have already been  reported but,  for
what they're worth,  here they are.

     Best wishes for a happy and healthy 1989.

                                    Sincerely,
                                    Edith G. Tanenbaum
                                    Bi -County Planning Coordinator
 EGT:sm
 Enc.
                                   185

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SeSKS555SSsiSJ!|^sS!S«S!*aS3>
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                     Proceedings of the Workshop on
                    Municipal Solid Waste Technology
p.87      First paragraph, line four — third word should be
          "cooperate."
          Final paragraph, line four -- isn't the word "recyclables,"
          not "unrecyclables?"
          The sentence is not clear.
p.88      First paragraph, line four -- third word should be "was.1
          Second paragraph, line three -- last word should be
          "assure."
          Second paragraph, line ten — sentence starting "So there
          is...," not clear.
p.101     Third paragraph, line one — believe the last word "flammable"
          is incorrect.
          Fourth paragraph, line six — fifth word should be "are."
p.117     Second paragraph, line three — word should be "dyes," not
          "dies."
p.118     Second paragraph, line one -- is it National Center for or of
          Resource Recovery?
p.120     Last paragraph, line seven -- fourth word should be farther.


p.122     First paragraph, last line -- first word should be "effluent."


p.128     First complete paragraph, last three lines — sentence needs
          punctuation or other clarification.


p.130     "Addendum," line one -- spelling of last name doesn't match
          that indicated in list of participants.
          "Durability." line one -- fourth word should be "ratio."
p.137     Paragraph "H," line six — sixth word appears to be incorrect.
          There is a Potsdam, N.Y.
p.138     Paragraph "II," line four -- fourth word should be
          "Sorain-Cecchini."

                                 186

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                        BROWN    UNIVERSITY
Center for Environmental Studies
          Box 1943
Telephone: (401) 863-3449
                                                                         21 January 1989
   Gerry Dorian
   Office of Environmental Engineering
          and Technology Demonstration
   USEPA
   Washington, DC, 20460

   Dear Gerry,

   Erica Guttman has been kind enough to pass along a copy of the draft proceedings of the
   workshop on Municipal Solid Waste Technology and to invite my comments on it. Since I
   am somewhat  past your suggested deadline  of 15 January, I am sending my comments to
   you directly with a copy to Erica.  As you  will see, most of my comments are similar to
   ones I made to you directly at the Rhode Island Solid Waste Corporation outing in Little
   Compton in  early November.

   All  of comments relate to  the  sections of the Proceedings dealing with  source reduction
   and recycling.  This is in part because I have worked more extensively in this area, and in
   part because I believe this section is significantly  weaker than the parts  of  the reports
   dealing with landfilling and with burn technologies.  Therefore my first point is:

   1.      If we truly mean to give  priority to reduction and recycling, that priority should
   show up in our planning studies.  In this case, a simple measure like the number of pages
   allocated to each subject suggests that the  minds  of the proceedings' writers still dwell
   more heavily  on the  "hard"  engineering solutions  than on the more  kind  and gentle
   changes  in  incentive structure  and information  systems  that favor reduction  and
   recycling. Perhaps  the final version  of the Proceedings could set research priorities that
   make clear  that, in a  case of limited budgets, the reduction and recycling work will be
   done before  demonstration  projects on burning and  burying.

   2.      Product  labeling  is a  highly  promising approach to  encourage  reduction  and
   recycling, and thus should be given  a high  priority in  the research  agenda.   Labeling is
   discussed briefly at different places  in the Proceedings.  This discussion would be more
   effective if it was integrated.  For "durable"  goods, the label should give an estimated
   annualized cost, much as  appliances now give  annualized energy costs.  On appliances,
   annualized capital cost (purchase price divided by expected lifetime) should appear right
   along with the annual energy cost.  The label  also  could contain information on content.
   of recycled  materials, recyclability of materials, hazardous materials contained therein,
   repairability,  and perhaps much  more.  My own  view  is that these will be  much  less
   influential with the consumer, more controversial and, in the case of repairability, more
                                                187
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difficult to  quantify.   Therefore, I would give high  priority to developing  a testing
protocol for annualized capital cost measurements (why not give a contract to Consumer's
Report?), but would give lower priority to the other labeling possibilities.  / would propose
a federal  labeling requirement only for  annualized cost, because asking for everything will
almost certainly get you nothing.  Even if Congress is reluctant to impose national labeling
standards,  a  few progressive states are  quite likely to do so, once the testing protocol is
developed.  Of course, as soon a  few states do  so, preferably with some differences  in
their approach, manufacturers will be begging for the protection of federal standards.  It
is not even unthinkable that a few states will try setting minimum standards for lifetimes
for certain products; that certainly will  get the manufacturers attention.

3.      Research  on  technologies   for   reprocessing  recycled  materials  not  presently
generally regarded as recyclable and for marketing materials  after processing should be
given a high priority.  As  the Northeast is discovering,  and will  feel even more keenly
very soon, we  know quite  a lot more  about collecting  recyclable materials  than we do
about selling  them.  How  about some  federally  funded  studies of markets, with  some
creative ideas about state action to favor these markets.   Should a coalition of states, for
example, be building mills  to  accept secondary fibers at  the same time as they  build the
materials reprocessing facilities? And how about some work on technologies to cope with
coated paper (magazines) and with  glue.  There are beginnings here, but there is a ways to
go.  The states are going to be frantic for this type of information very  soon, but except
for the  biggest ones, are not well positioned to run research projects of these types.

4.      Description and evaluation of existing systems for source separation in  a few major
commercial/industrial operations would be quite helpful.   The states share  information on,
for example, offices separate  paper, how bars  deal with glass, etc.,  but  usually there  is
little or no evaluation, and few studies are comprehensive.  Even looking at the dozen
largest generators of common materials would be worthwhile. To pick an  example close  to
my heart, someone needs to do a generalized plan for colleges and universities.  They are
ideal places to  begin, since  waste is recycled and  graduates are trained to  recycle,  both at
the same time.

5.      Describe and evaluate options for taxing products  based on durability, recyclability,
toxic content, etc.   Having read the lips of Mr.  Bush, I  assume there  is  not  likely to be
much interest  in federal taxes of  this type.  But if a  nice taxation  scheme was there,
ready  for  a state  to  pick up, a few states might do so.   When  several  do, again
manufacturers  will be looking for federal regularity.

6.      Get some of  these  research needs  on  the  broader  EPA  agenda.  I  was quite
disappointed  to  find  that  the   1989   Topi  Catalog  for  the  National Network  for
Environmental Management Studies (NNEMS) had little or  nothing on solid waste, and
absolutely  nothing on  reduction   or   recycling.    Why  not  take  advantage  of  these
possibilities, and get graduate students  interested  in questions of these types at the same
time?
                                              188
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         The imminent beginning of the next semester prevents me from going on at greater length,
r, ^^v   I would be pleased to discuss any of these with you if you like, just give me a call.
         cc: Erica Guttman
                                                            'Harold R. Ward
                                                             Professor of Chemistry and
                                                             Environmental Studies
                                                     •189
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