»EPA
            United States
            Environmental Protection
            Agency
            401 MSt., S.W.
            Washington, D.C. 20460
January 1979
            Solid Waste
Subtitle C, Resource Conservation
and Recovery Act of 1976

Draft Environmental Impact
Statement

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         <-:•:; STATES ENVIRONMENTAL PROTECTION
                    WASHINGTON. D.C  20 :oO
                   January 5, 1979
                      ADDENDUM
Addressee:

     We  appreciate your interest in the Environmental
Impact Statement for Subtitle C of the Resource
Conservation and Recovery Act of 1976 (RCRA) _   If yore
v;ish to  comment on this document, please forwasrcl your
comments  to  Michael Shannon,  U.S. Environmental
Protection Agency,  V7H-565, 401 M Street, S.W_,
Washington,  D.C.   20460.   The summairy sheet in  the
EIS states that the closing date for comments is 9O
days from the official  public notice of availability
in the Federal Register;  this is incorrect-
closing period for comments is 90 days after"
regulations  viere  proposed in the Federal Register-,
which was December 18,  1978.   Therefore, the comment
period for the EIS  closes March 16, 1979.  Please sub-
mit your comments on or before that date-

     Thank you very much.

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               DRAFT
ENVIRONMENTAL IMPACT STATEMENT
   SUBTITLE C, RESOURCE CONSERVATION
    AND RECOVERY ACT OF 1976 (RCRA)
             PREPARED BY
         OFFICE OF SOLID WASTE
 U.S. ENVIRONMENTAL PROTECTION AGENCY
         WASHINGTON, D.C. 20460
           STEFFEN W. PLEHN
    DEPUTY ASSISTANT ADMINISTRATOR
           FOR SOLID WASTE
             JANUARY 1979

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                            SUMMARY SHEET

              DRAFT ENVIRONMENTAL IMPACT STATEMENT FOR
           SUBTITLE C, RESOURCE CONSERVATION AND RECOVERY
                         ACT OF 1976 (RCRA)

                   Environmental Protection Agency
                        Office of Solid Waste

1.  Type of Action

    Administrative Action (Regulatory)

2.  Brief Description of Action

    The Resource Conservation and Recovery Act of 1976 (RCRA)
    Subtitle C, provides EPA with the authority to regulate the
    generation, transportation, treatment, storage, and disposal of
    hazardous waste in a manner that protects human health and the
    environment.  RCRA also authorizes States to implement their own
    program for the management of hazardous waste if it is, at a
    minimum, equivalent to the Federal regulations.  Compliance with
    the proposed regulations is mandatory; non-compliance is subject
    to penalty of law.

3.  Summary of Beneficial and Adverse Environmental Effects

    Promulgation of the proposed Subtitle C regulations would lead to
    reduced releases of air, water, and soil contaminants from the
    management of hazardous wastes and to resultant beneficial im-
    pacts to air quality, water quality, public health, and eco-
    logical systems.  The regulations would increase the cost of
    generating and managing hazardous wastes and could lead to some
    industrial plant closings and to increased administrative and
    paperwork requirements.  Many existing facilities would have to
    change their current hazardous waste management practices and
    some could close due, at least in part, to increased costs and
    more stringent requirements.

4.  Alternatives Considered

    a.  Proposed Action
    b.  No Action
    c.  Phasing of Generators
    d.  Enhanced Public Health and Environmental Protection
    e.  Lesser Degree of Public Health and Environmental Protection
                                  ill

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5.  Federal, State, and Local Agencies From Which Written Comments
    Have Been Requested

    The proposed Subtitle C regulations have been distributed to
    hundreds of individuals and organizations representing all
    sectors of our society.  The draft EIS is also being distributed
    to a diverse group of individuals and organizations including,
    but not limited to, the following examples:

    Federal Agencies

    Department of Interior
    Department of Health, Education, and Welfare
    Department of Agriculture
    Department of Commerce
    Department of Energy
    Department of Defense
    Department of Housing and Urban Development

    State Government

    50 State Solid Waste Management Offices
    National Governors' Association
    National Conference of State Legislators
    National Association of State Attorneys General

    Local Government

    National Association of Regional Councils
    National Association of Counties
    National League of Cities/U.S. Conference of Mayors

    Solid Waste Management Professional Groups

    National Solid Waste Management Association
    American Public Works Association

    Professional Associations

    American Society of Civil Engineers
    American Consulting Engineers Council
    Water Pollution Control Federation
    American Institute of Chemical Engineers
    Mining and Reclamation Council of America
                                  iv

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    Environmental,  Health,  and Citizens Groups

    Sierra Club
    Environmental Action, Inc.
    Environmental Action Foundation
    Environmental Defense Fund
    Natural Resources Defense Council
    National Wildlife Federation
    National Environmental  Health Association
    Izaac Walton League
    League of Women Voters
    Citizens for a Better Environment
    Central and Southwest Corporation, et al.

    Trade Associations
    American Mining Congress
    American Petroleum Institute
    Manufacturing Chemists Association
    American Water Works Association
    National Water Well Association
    American Textile Manufacturers Institute
    American Iron and Steel Institute
    National Forest Products Association

6.  Date Available To The Public

    The Draft Environmental Impact Statement has been provided to the
    Office of Federal Activities, EPA, for the purpose of publishing
    an official public notice of availability in the Federal Regis-
    ter.  This notice is anticipated by January 8, 1979.  The 90-day
    public comment period for the Draft EIS begins with the issuance
    of this notice.  The Integrated Economic Impact Assessment of
    Hazardous Waste Management Regulations (Regulatory Analysis Sup-
    plement) is also available for public comment during this period.
    Copies of these documents may be obtained by writing:  Mr. Edward
    Cox, Solid Waste Information Office, U.S. Environmental Protec-
    tion Agency, 26 West St. Clair, Cincinnati, Ohio  45260.  Copies
    may also be viewed at the library of all EPA Regional Offices.
    Comments should be sent to:   Mr. Michael Shannon, Office of Solid
    Waste, WW-565, U.S. Environmental Protection Agency, Washington,
    D.C.  20460.
                                  v

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                          ACKNOWLEDGEMENT
     This voluntary Environmental Impact Statement was  prepared  by
the U.S. Environmental Protection Agency (EPA)  with the assistance
of the MITRE Corporation under EPA Contract Number 67-01-4641.   The
Project Officer was Ronn N. Dexter, Office of Solid Waste.
                                 vii

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                               PREFACE


     The Draft Environmental Impact Statement (EIS) for Subtitle C

of RCRA presents an analysis of the proposed Subtitle C regulations

as drafted in September 1978, as well as an analysis of alternatives

to the proposed regulations which were considered.  It was necessary

to analyze the September 1978 version of the regulations due to time

constraints involved in preparing the proposed regulations and con-

ducting an environmental impact analysis of them.  As one would

expect, the regulations as analyzed in this document and the regu-

lations as proposed, differ slightly.  However, these differences

do not significantly change the impacts as identified in the Draft

EIS.  The differences between the September 1978 regulations and

the proposed regulations are highlighted here to assist the reader.

Although an attempt was made to identify all the differences, it is

possible that some differences may not be noted.

Section 3002 differences:

     •  Generators who ship hazardous waste to a foreign country are
        required to inform the foreign government by sending a copy
        of the manifest to the appropriate regulatory agency of the
        foreign country having jurisdiction over the designated
        facility, within one week of the shipment.

     •  Clarification of the Waste Oil Assumption of Duties Contract,
        and expansion to include all waste oil, not just automotive
        oil.

Section 3004 differences:

     •  Special Wastes:  Exemption of special wastes from human
        health and environmental (Section 250.42), storage (Section
        250.44), and treatment/disposal (Section 250.45) standards

                                  ix

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   for the present; insertion of specific general facility
   standards (Section 250.43) for each special waste in the
   regulations.

•  Interim Status:  Section 250.40(c)(2) has been included in
   the proposed regulations.  This section lists the applicable
   standards for treatment, storage, and disposal facilities
   that have been granted interim status.

•  General Site Selection:  No longer prohibits location of
   facilities in permafrost areas.  Regulations regarding loca-
   tion of facilities in 100-year floodplains has been replaced
   by two regulations:  (1) prohibition on facilities locating
   in a "regulatory floodway," and (2) restriction on facilities
   locating in a "coastal high hazard area."

•  Air:  Air human health and environmental standard specifies
   compliance with Clean Air Act.  Nonpoint source air contam-
   inant limits placed in "Treatment/Disposal Standards" (Sec-
   tion 250.45) as a "Note."  ACGIH limits replaced by OSHA
   permissible airborne contaminant exposure levels.

•  Groundwater and Leachate Monitoring:  Basis for deviation
   has been added to the regulation requiring a minimum of four
   groundwater monitoring wells.

•  Storage:  Storage tanks and containers must now also comply
   with OSHA's standards for storage of flammable and combusti-
   ble liquids.

•  Landfills:  No longer requires that landfilled wastes have
   a percent solids content of greater than or equal to 20 per-
   cent.  Instead, bulk liquids will have to be treated so as
   to make waste of a non-flowing consistency.

•  Landfarms:  Regulation prohibiting landfarming of wastes con-
   taining arsenic, boron, molybdenum, and/or selenium has been
   dropped.  Addition of regulations which requires stoppage of
   landfarming operations after wastes have migrated three times
   the depth of the zone of incorporation.  Growth of food chain
   crops in landfarms prohibited.

•  Incineration:  Specification of control technology standards
   (1,200 C, 3 seconds, 2 percent oxygen) for halogenated aro-
   matic hydrocarbon wastes (PCBs, PBBs, etc.).  Specification
   of fuel and waste flow rate monitoring.

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     •  Human Health and Environmental Standards:  Have been deleted
        from all "Notes" as a basis for deviation; will only be used
        to impose more stringent requirements as necessary when de-
        sign and operating standards do not adequately protect human
        health and the environment.

     •  Ignitable/Volatile/Reactive/Incompatible Wastes:  Prohibi-
        tion on disposal of these wastes in landfills, landfarms,
        and surface impoundments, however, "Note" allows deviations
        if facility owner/operator demonstrates it can be done
        safely.

     •  Residential and Agricultural Use Restrictions:  Have changed
        the restrictions regarding using land where hazardous waste
        has been disposed for residential and agricultural purposes.
        New standard allows any use which does not damage the struc-
        tural integrity of the site.

     A separate draft economic impact analysis report has been

prepared for the proposed hazardous waste management regulations.

The report (entitled "Integrated Economic Impact Assessment of the

Hazardous Waste Management Regulations (Regulatory Analysis Supple-

ment) - Draft Report") is a comprehensive analysis which measures the

economic impacts of Subtitle C Sections 3001, 3002, 3003, 3004, 3005,

and 3010 on the regulated manufacturing industries.  The regulatory

alternatives analyzed in the EIS are also analyzed in the economic

report.  As with the EIS, the economic impact analysis is based on

the September 1978 version of the regulations.

     At the present time, the Agency is in the process of integrat-

ing the permitting regulations mandated by Section 3005 of RCRA with

similar regulations prescribed under the National Pollution Discharge

Elimination System (NPDES) of the Clean Water Act and the Underground

Injection Control Program of the Safe Drinking Water Act.  Where EPA
                                  xi

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implements the hazardous waste program, the end result of this pro-


cess is expected to be a single integrated permit covering the requi-


rements of all of the Acts.  Thus, facilities subject to more than


one Act would only have to go through the permitting procedure once.


Because the final product of the integration effort has not been com-

                      •
pleted as this document goes to press, it has been necessary to use


the July 1978 version of the Section 3005 regulations.  While the


integrated regulations are expected to be less complex procedurally


than those currently in use in granting NPDES permits, they are ex-


pected to be similar to the RCRA regulations used in this analysis.


However, there will be some inherent benefits to the regulated com-


munity due to the fact that only one application is required in place


of three.   Therefore, the impacts of the permitting process estimated


herein are somewhat overstated.
                                 xii

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                          TABLE OF CONTENTS
LIST OF ILLUSTRATIONS                                            xxvi

LIST OF TABLES                                                  xxvii


                         CONTENTS OF VOLUME 1


S.O  SUMMARY                                                      S-l

S.I  Introduction                                                 S-l
S.2  Description of the Proposed Action                           S-l

     S.2.1  Identification and Listing of Hazardous
            Waste (Section 3001)                                  S-2
     S.2.2  Standards Applicable to Generators of
            Hazardous Waste (Section 3002)                        S-2
     S.2.3  Standards Applicable to Transporters of
            Hazardous Wastes (Section 3003)                       S-3
     S.2.4  Standards Applicable to Owners and Operators
            of Hazardous Waste Treatment, Storage, and
            Disposal Facilities (Section 3004)                    S-4
     S.2.5  Permits for Treatment, Storage, or Disposal
            of Hazardous Waste (Section 3005)                     S-5
     S.2.6  Authorized State Hazardous Waste Programs
            (Section 3006)                                        S-6
     S.2.7  Preliminary Notification of Hazardous Waste
            Activities (Section 3010)                             S-7

S.3  Description of the Reasonable Alternatives                   S-7

     S.3.1  No Action                                             S-8
     S.3.2  Phasing of Generators                                 S-9
     S.3.3  Enhanced Public Health and Environmental
            Protection                                            S-9
     S.3.4  Lesser Degree of Public Health and
            Environmental Protection                             S-10

S.4  Impacts of the Proposed Regulations                         S-ll

     S.4.1  Potential Primary Impacts                            S-13
     S.4.2  Potential Secondary Impacts                          S-30

S.5  Impacts of the Alternatives                                 S-39

                                 xiii

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                    TABLE  OF  CONTENTS  (Continued)

                                                                 Page

     S.5.1   No Action Alternative                                 S-39

     S.5.2   Phasing of Generators  Alternative                     S-40
     S.5.3   Enhancing Public  Health  and  Environmental
            Protection Alternative                               S-43
     S.5.4   Lesser Degree  of  Public  Health  and
            Environmental  Protection Alternative                  S-53

1.0  INTRODUCTION                                                 1-1

2.0  LEGISLATIVE BACKGROUND                                        2-1

2.1  Federal Legislation Leading to  RCRA                          2-1
2.2  RCRA and Subtitle C                                          2-4

     2.2.1   Definitions Relevant to  Subtitle C                     2-6
     2.2.2   Section 3001 of Subtitle C                             2-8
     2.2.3   Section 3002 of Subtitle C                             2-8
     2.2.4   Section 3003 of Subtitle C                             2-9
     2.2.5   Section 3004 of Subtitle C                             2-9
     2.2.6   Section 3005 of Subtitle C                            2-10
     2.2.7   Section 3006 of Subtitle C                            2-11
     2.2.8   Section 3007 of Subtitle C                            2-11
     2.2.9   Section 3008 of Subtitle C                            2-12
     2.2.10  Section 3009  of  Subtitle C                           2-12
     2.2.11  Section 3010  of  Subtitle C                           2-13
     2.2.12  Section 3011  of  Subtitle C                           2-13

2.3  Related Federal Legislation                                  2-13
2.4  The Status of State Solid  Waste and Hazardous
     Waste  Legislation                                           2-18

     2.4.1   The Status of  State Regulatory  Criteria Applicable
            to Generators  of  Hazardous Waste                      2-30
     2.4.2   The Status of  State Regulatory  Criteria Applicable
            to Transporters of  Hazardous Waste                    2-31
     2.4.3   The Status of  State Regulatory  Criteria Applicable
            to Off-site Treaters of  Hazardous Waste               2-32
     2.4.4   The Status of  State Regulatory  Criteria Applicable
            to Off-site Storers of Hazardous Waste                2-33
     2.4.5   The Status of  State Regulatory  Criteria Applicable
            to Off-site Disposers  of Hazardous  Waste              2-34
     2.4.6   The Status of  State Hazardous Waste Definition,
            Monitoring, and Enforcement                           2-35

                                  xiv

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                    TABLE OF CONTENTS (Continued)

                                                                 Page

3.0  DESCRIPTION OF THE PROPOSED ACTION                           3-1

3.1  Criteria, Identification, and Listing of
     Hazardous Waste (Section 3001)                               3-1
3.2  Standards Applicable to Generators of
     Hazardous Waste (Section 3002)                               3-2
3.3  Standards Applicable to Transporters of
     Hazardous Waste (Section 3003)                               3-5
3.4  Standards for Owners and Operators of
     Hazardous Waste Treatment, Storage, and
     Disposal Facilities (Section 3004)                           3-6
3.5  Permit System for Treatment, Storage, or
     Disposal of Hazardous Wastes (Section 3005)                 3-11
3.6  Guidelines for State Hazardous Waste Programs
     (Section 3006)                                              3-12
3.7  Preliminary Notification of Hazardous Waste
     Activities (Section 3010)                                   3-14

4.0  IDENTIFICATION AND SELECTION OF REASONABLE ALTERNATIVES      4-1

4.1  No Action                                                    4-3
4.2  Phasing of Subtitle C Regulations                            4-5
4.3  Enhanced Public Health and Environmental Protection         4-10
4.4  Lesser Degree of Public Health and Environmental
     Protection                                                  4-19

5.0  EXISTING HAZARDOUS WASTE GENERATION AND MANAGEMENT
     PRACTICES                                                    5-1
5.1  Characterization of Hazardous Waste Generation               5-1

     5.1.1  Hazardous Waste Characteristics                       5-1
     5.1.2  Sources of Hazardous Waste                           5-11

5.2  Characterization of Hazardous Waste Transport               5-22

     5.2.1  Generator/Transporter                                5-24
     5.2.2  Hazardous Waste Management Facility/Transporters     5-27
     5.2.3  For-Hire Transporters                                5-28

5.3  Characterization of Hazardous Waste Storage, Treatment,
     and Disposal                                                5-32

     5.3.1  Storage                                              5-32
     5.3.2  Treatment                                            5-34

                                  xv

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                    TABLE  OF  CONTENTS (Continued)

                                                                 Page

     5.3.3  Disposal                                             5-35
     5.3.4  Typical  Management  Practices  for Hazardous
            Industrial Waste                                      5-36
     5.3.5  Hazardous  Waste Management Service Industry          5-43
     5.3.6  State Data on  On-Site and Off-Site Disposal          5-48

5.4  Resource Conservation and  Recovery                          5-52

     5.4.1  Resource Conservation and Recovery Methods
            and Operations                                       5-52
     5.4.2  Resource Recovery and Recycling Estimates            5-56
     5.4.3  Constraints to Resource Conservation and Recovery    5-71

6.0  QUANTITIES OF HAZARDOUS  WASTES GENERATED AND CONTROLLED      6-1

6.1  Current Hazardous Waste  Generation                           6-1

     6.1.1  Manufacturing  Industries                              6-1
     6.1.2  Other Hazardous Wastes                                6-4

6.2  Hazardous Waste Generators                                  6-10
6.3  Estimation of Future  Hazardous Waste Generation             6-14
6.4  Hazardous Spills                                            6-15
6.5  Hazardous Wastes Under State Control                        6-21

7.0  IMPACTS OF THE  PROPOSED  ACTION                               7-1

7.1  Potential Primary Impacts                                     7-4

     7.1.1  Hazardous Wastes  to be Regulated                      7-5
     7.1.2  Changes  to Existing Generation, Transport,
            Storage, Treatment, and Disposal Practices
            and Procedures                                        7-9
     7.1.3  Administrative Changes                               7-38
     7.1.4  Air Impacts                                          7-58
     7.1.5  Water Quality  Impacts                               7-107
     7.1.6  Public Health  Impacts                               7-145

7.2  Potential Secondary Impacts                                7-161

     7.2.1  Impacts  to Physiography and Soils                   7-161
     7.2.2  Biological Impacts                                   7-168
     7.2.3  Social Impacts                                      7-183
     7.2.4  Hazardous Waste Management Facility Capacity        7-192

                                  xv i

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                    TABLE OF CONTENTS (Continued)

                                                                 Page

     7.2.5  Land Use Impacts                                    7-200
     7.2.6  Water Use Impacts                                   7-204
     7.2.7  Impacts to Resource Conservation and Recovery       7-206
     7.2.8  Energy Use Impacts                                  7-207
     7.2.9  Impacts to Special Interest Points                  7-207

7.3  Significant Uncertainties in the Impact Assessment         7-212

8.0  IMPACTS OF THE ALTERNATIVES                                  8-1

8.1  Potential Changes in Impacts Resulting from the
     No Action Alternative                                        8-1

     8.1.1  Primary Impacts                                       8-1
     8.1.2  Secondary Impacts                                     8-5

8.2  Potential Changes in Impacts Resulting from the
     Phasing of Generators Alternative                            8-6

     8.2.1  Primary Impacts                                       8-6
     8.2.2  Secondary Impacts                                    8-20

8.3  Potential Change in Impacts Resulting from the
     Enhanced Public Health and Environment Protection
     Alternative                                                 8-22

     8.3.1  Primary Impacts                                      8-22
     8.3.2  Secondary Impacts                                    8-48

8.4  Potential Change in Impacts Resulting from the
     Lesser Degree of Public Health and Environmental
     Protection Alternative                                      8-68

     8.4.1  Primary Impacts                                      8-69
     8.4.2  Secondary Impacts                                    8-99

9.0  MITIGATING MEASURES AND ADVERSE IMPACTS WHICH CANNOT
     BE AVOIDED                                                   9-1

9.1  Redistribution of Hazardous Wastes                           9-2
9.2  Impacts Unaffected by the Regulations                        9-8

     9.2.1  Siting                                                9-8
     9.2.2  Transportation                                       9-10


                                  xvii

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                    TABLE OF CONTENTS (Continued)
     9.2.3  Construction and Operation
     9.2.4  Closure

10.0 RELATIONSHIP BETWEEN LOCAL SHORT-TERM USE OF MAN'S
     ENVIRONMENT AND THE MAINTENANCE AND ENHANCEMENT
     OF LONG-TERM PRODUCTIVITY                                   10-1

11.0 IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES     11-1
                        CONTENTS OF VOLUME II

APPENDIX A - STATE HAZARDOUS WASTE REGULATIONS                    A-l

A.I  Regulations Applicable To Generators                         A-l

     A.1.1  California                                            A-l
     A.1.2  Georgia                                               A-2
     A.1.3  Illinois                                              A-2
     A.1.4  Maryland                                              A-3
     A.1.5  Minnesota                                             A-3
     A.1.6  Missouri                                              A-4
     A.1.7  Montana                                               A-5
     A. 1.8  Oklahoma                                              A-5
     A. 1.9  Oregon                                                A-6
     A. 1.10 Texas                                                 A-6
     A. 1.11 Washington                                            A-7

A.2  Regulations Applicable to Transporters                       A-7

     A.2.1  California                                            A-7
     A.2.2  Maryland                                              A-9
     A.2.3  Minnesota                                             A-9
     A.2.4  Missouri                                             A-10
     A.2.5  Montana                                              A-10
     A.2.6  Oklahoma                                             A-10
     A.2.7  Oregon                                               A-ll
     A.2.8  Texas                                                A-ll
     A.2.9  Washington                                           A-12

A.3  Regulations Applicable to Storers,  Treaters,
     and Disposers                                               A-13
                                 xviii

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                    TABLE OF CONTENTS (Continued)
A. 3.1
A. 3. 2
A. 3. 3
A. 3. 4
A. 3. 5
A. 3. 6
A. 3. 7
A. 3. 8
A. 3. 9
California
Georgia
Illinois
Maryland
Minnesota
Missouri
Montana
Oklahoma
Oregon
     A.3.10 Texas                                                A-20
     A.3.11 Washington                                           A-21

A.4  Examples of Other State Control Mechanisms                   A-22

     A.4.1  Nebraska                                             A-22
     A.4.2  Utah                                                 A-23

A.5  Hazardous Waste Legislation for the U.S.  Territories         A-24

     A.5.1  Territory of Guam                                    A-24
     A.5.2  Territory of American Samoa                          A-24
     A.5.3  Trust Territory of the Pacific Islands                A-25
     A.5.4  Puerto Rico                                          A-25
     A.5.5  The U.S. Virgin Islands                              A-25

APPENDIX B - PROPOSED SUBTITLE C REGULATIONS                       B-l

Subpart A - Criteria, Identification,  and Listing  of
            Hazardous Waste                                       B-l

     250.10  Purpose and Scope                                    B-2
     250.11  Definitions                                          B-3
     250.12  Criteria                                             B-5
     250.13  Hazardous Waste Characteristics                       B-7
     250.14  Hazardous Waste Lists                               B-15
     Appendix I - Explosion Temperature Test                      B-29
     Appendix II - Separation Protocol                           B-30
     Appendix III - Structural Integrity Procedure                B-32
     Appendix IV - pH Adjustment Procedures                      B-33
     Appendix V - Sampling Methods                               B-34
     Appendix VI - Pesticides                                    B-35
     Appendix VII - Department of Transportation (DOT)
                    Classification Poison A,  Poison B,
                    or ORM-A                                     B-37

                                  xix

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                    TABLE  OF  CONTENTS  (Continued)
     Appendix VIII -  Autoclave  Speifications
     Appendix IX - CDC  Classification  of  Etiologic  Agents
     Appendix X - Radioactive Waste Measurements
     Appendix XI - Detection of Gene Mutations
     Appendix XII - Bioaccumulation Potential Test
     Appendix XIII -  Controlled Substance List
     Appendix XIV - Priority Pollutants

Subpart B - Standards Applicable to Generators  of
            Hazardous Waste                                      B-74

     250.20  Scope and  Purpose                                    B-75
     250.21  Definitions                                         B-77
     250.22  Manifest                                            B-80
     250.23  Reporting                                            B-83
     250.24  Recordkeeping                                       B-91
     250.25  Containers                                          B-91
     250.26  Labeling Practices                                  B-92
     250.27  Confidential Information                             B-93
     250.28  Presumption                                         B-93
     250.29  Transfer of Liability Contract                      B-93

Subpart C - Standards Applicable to  Transporters  of
            Hazardous Wastes                                     B-97

     250.30  Scope                                               B-98
     250.31  Definitions                                         B-99
     250.32  Identification Code                                B-101
     250.33  Recordkeeping                                      B-101
     250.34  Acceptance and Transfer  of  Hazardous Waste         B-102
     250.35  Compliance with the Manifest                       B-103
     250.36  Delivery of Hazardous Wastes to  a  Designated
             Permitted Facility                                 B-105
     250.37  Spills                                             B-105
     250.38  Placarding/Marking of Vehicles                     B-108

Subpart D - Standards for Owners and Operators  of
            Hazardous Waste Treatment, Storage, and
            Disposal  Facilities                                 B-109

     250.40  Scope/Applicability                                B-lll
     250.41  Definitions                                        B-113
     250.42  Human Health and  Environmental Standards           B-127
     250.43  General  Facility  Standards                          B-130

                                  xx

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                    TABLE OF CONTENTS (Continued)
     250.44  Standards for Storage                              B-169
     250.45  Standards for Treatment/Disposal                   B-172
     250.46  Special Waste Standards                            B-210
     Annex 1 - Drinking Water Standards                         B-212
     Annex 2 - Threshold Limit Values for Chemical
               Substances                                       B-213
     Annex 3 - TSDF Report                                      B-221
     Annex 4 - Incompatible Wastes                              B-222
     Annex 5 - Methods for Determining Soil pH                  B-225

Subpart E - Permit System for Facilities Which Treat,  Store
            or Dispose of Hazardous Waste                       B-227

     250.60  Scope and Purpose                                  B-229
     250.61  Definitions                                        B-229
     250.62  Permit Provisions                                  B-235
     250.63  Application for a Permit                           B-244
     250.64  Formulation of Tenative Determinations
             and Draft Permit                                   B-253
     250.65  Request for Public Hearing and Notice of
             Public Hearing                                     B-256
     250.66  Administrative Record                              B-264
     250.67  Emergency Action                                   B-266
     250.68  Computation of Time                                B-266

Subpart F - Guidelines for State Hazardous Waste  Programs        B-268

     250.70  Scope and Purpose                                  B-269
     250.71  Definitions                                        B-269
     250.72  Authorization                                      B-271
     250.73  Interim Authorization                              B-279
     250.74  Federal Outsight of Authorized Programs             B-282
     250.75  Application Procedure                              B-285
     250.76  Withdrawal of Authorization                        B-287

Subpart G - Preliminary Notification of Hazardous Waste
            Activities                                          B-289

     250.800  Scope and Purpose                                 B-290
     250.801  Definitions                                       B-290
     250.810  Limited Interim Authorization                     B-293
     250.811  Application Procedures for States                 B-294
     250.812  Responsibilities and Authority of the EPA
              Regional Administrator                            B-295

                                 xx i

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                    TABLE OF CONTENTS (Continued)
     250.820  Who Must File Notification                        B-296
     250.821  When to File Notification                         B-298
     250.822  Where to File Notification                        B-299
     250.823  Information Required in Notification              B-299

APPENDIX C - CHARACTERIZATION OF POTENTIALLY HAZARDOUS
             WASTES GENERATED BY SELECTED MANUFACTURING
             INDUSTRIES                                           C-l

C.I  Textile Industry                                             C-3
C.2  Inorganic Chemicals Industry                                 C-6
C.3  Pharmaceutical Industry                                      C-7
C.4  Paint and Allied Products Industry and Contract
     Solvent Reclaiming Operations                               C-12

     C.4.1  Paint and Allied Products Industry                   C-12
     C.4.2  Contract Solvent Reclaiming Operations               C-16

C.5  Organic Chemicals, Pesticides,  and Explosives
     Industries                                                  C-17
C.6  Petroleum Refining Industry                                 C-17
C.7  Petroleum Rerefining Industry                               C-34
C.8  Leather Tanning and Finishing Industry                      C-35
C.9  Metal Smelting and Refining Industry                        C-39
C.10  Electroplating and Metal Finishing Industries              C-46
C.ll  Special Machinery Manufacturing Industries                 C-48
C.12  Electronic Components Manufacturing Industry               C-53
C.13  Storage and Primary Batteries  Industries                   C-55

APPENDIX D - TREATMENT AND DISPOSAL  OF HAZARDOUS WASTES           D-l

D.I  Treatment Methods                                            D-l

     D.I.I  Physical Treatment                                    D-2
     D.I.2  Chemical Treatment                                    D-6
     D.I.3  Biological Treatment                                  D-9
     D.I.4  Thermal Treatment                                    D-13

D.2  Methods for Ultimate Disposal                               D-19

     D.2.1  Open Dumping                                         D-20
     D.2.2  Landfills                                            D-21
     D.2.3  Landfarming                                          D-23
     D.2.4  Surface Impoundments                                 D-24

                                xxii

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                    TABLE OF CONTENTS (Continued)
     D.2.5  Incineration
     D.2.6  Road Application
     D.2.7  Detonation
     D.2.8  Engineered Storage

D.3  Treatment and Disposal Practices by Selected
     Manufacturing Industries                                    D-28

     D.3.1   Textiles Industry                                   D-28
     D.3.2   Inorganic Chemicals Industry                        D-30
     D.3.3   Pharmaceutical Industry                             D-33
     D.3.4   Paint and Allied Products Industries and
             Contract Solvent Reclaiming Operations              D-35
     D.3.5   Organic Chemicals, Pesticides, and
             Explosives Industries                               D-38
     D.3.6   Petroleum Refining Industry                         D-44
     D.3.7   Petroleum Rerefining Industry                       D-48
     D.3.8   Leather Tanning and Finishing Industry              D-51
     D.3.9   Metal Smelting and Refining Industry                D-54
     D.3.10  Electroplating and Metal Finishing
             Industries                                          D-60
     D.3.11  Special Machinery Manufacturing Industries          D-62
     D.3.12  Electronic Components Manufacturing Industry        D-64
     D.3.13  Storage and Primary Batteries Industries            D-67

APPENDIX E - CHARACTERIZATION OF THE HAZARDOUS WASTE
             TRANSPORT INDUSTRY                                   E-l

E.I  Generator/Transporter                                        E-3
E.2  Hazardous Waste Management Facility/Transporters             E-7
E.3  For-Hire Transporters                                       E-10

     E.3.J.  Common and Contact Highway Carriers                  E-10
     E.3.2  Rail Transport                                       E-14
     E.3.3  Air Transport                                        E-20
     E.3.4  Pipeline Transport                                   E-21
     E.3.5  Waterway Transport                                   E-22

APPENDIX F - POTENTIAL RECOVERY OF SPECIFIC HAZARDOUS WASTES
             GENERATED BY SELECTED MANUFACTURING INDUSTRIES       F-l

F.I  Potential Recovery of Hazardous Wastes Generated by
     the Inorganic Chemical Industry                              F-l
                                 xxiii

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                    TABLE OF CONTENTS (Continued)
F.2  Potential Recovery of Hazardous Wastes Generated by
     the Organic Chemical Industry                                F-4
F.3  Potential Recovery of Hazardous Wastes Generated by the
     Metals Smelting and Refining Industries                      F-4

APPENDIX G - INDUSTRIAL WASTE CLEARINGHOUSES AND EXCHANGES        G-l

G.I  Iowa Industrial Waste Information Exchange                   G-5
G.2  California Industrial Waste Information Exchange             G-7
G.3  National Clearinghouses                                      G-9

APPENDIX H - METHODOLOGY FOR THE DERIVATION OF HAZARDOUS
             WASTE GENERATION FACTORS                             H-l

H.I  Methods of Quantifying Hazardous Wastes                      H-l
H.2  Data Sources                                                 H-4
H.3  Development of Generation Factors                           H-12
H.4  Limitations of Generation Factors                           H-15

     H.4.1  Comparability of Data Sources                        H-15
     H.4.2  Possible Biases in Industry Coverage                 H-19
     H.4.3  Possible Inaccuracies Due to Company Responses       H-19
     H.4.4  Aggregation at the Two-Digit SIC Level               H-20
     H.4.5  Waste Generation per Employee                        H-23

H.5  Application of Generation Factors                           H-23

APPENDIX I - DOCUMENTATION FOR PHASING CALCULATIONS               1-1

I.I  Methodology                                                  1-1
1.2  Operation                                                    1-4
1.3  Output                                                       1-4
1.4  Limitations and Applicability of Methodology                 1-7
1.5  Program Listing                                             1-15
1.6  Glossary                                                    1-15

APPENDIX J - HAZARDOUS WASTE INCIDENTS                            J-l

J.I  Generation Incidents                                         j-1
J.2  Transport Incidents                                          j-2
J.3  Treatment and Lagoon Incidents                               j-3
J.4  Storage Incidents                                           J-10
J.5  Disposal Incidents                                          J-17
                                 xx iv

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                    TABLE-OF CONTENTS (Concluded)

                                                                 Page
APPENDIX K - UNITED STATES DISTRIBUTION OF MANUFACTURING
             FIRMS BY SIZE, IN STANDARD INDUSTRIAL
             CLASSIFICATIONS 20 AND 22 THROUGH 39 — 1972         K-l

APPENDIX L - BACKGROUND INFORMATION ON GROUNDWATER
             MOVEMENT AND CONTAMINATION                           L-l

L.I  Occurrence and Movement of Groundwater                       L-l
L.2  Contamination of Groundwater                                 L-6
L.3  Transport and Natural Attenuation of Contaminants            L-7

APPENDIX M - BACKGROUND INFORMATION ON INCINERATION OF
             HAZARDOUS WASTES                                     M-l

APPENDIX N - LITERATURE CITED                                     N-l
                                  XXV

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                        LIST OF ILLUSTRATIONS


                        CONTENTS OF VOLUME 1

                                                                 Page

5-1  Geographic Distribution of Hazardous Waste
     Management Facilities                                       5-45
6-1  Cumulative Size Distribution of Hazardous Waste
     Generators 1975                                             6-13
6-2  Cumulative Hazardous Waste Distribution 1975                6-14


                        CONTENTS OF VOLUME II

1-1  Cumulative Hazardous Waste Generation 1984                   1-8
L-l  Unconfined and Confined Aquifers                             L-2
M-l  Air Emissions from Incineration of Selected
     Pesticides of 1000 C and 2 Seconds Retention                 M-9
                                xxv i

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                           LIST OF TABLES
                        CONTENTS OF VOLUME 1
S-l   Comparison of Potential Impacts of the Proposed
      Regulations and the Enhanced and the Lesser Degree
      of Public Health and Environmental Protection
      Alternatives                                               S-44
2-1   State Regulation and Control Authority                     2-19
2-2   State Legislation Applicable to Hazardous Waste
      Generators                                                 2-24
2-3   State Legislation Applicable to Hazardous Waste
      Transporters                                               2-25
2-4   State Legislation Applicable to Hazardous Waste
      Treaters                                                   2-26
2-5   State Legislation Applicable to Hazardous Waste
      Storers                                                    2-27
2-6   State Legislation Applicable to Hazardous Waste
      Disposers                                                  2-28
2-7   State Approach to Hazardous Waste Definition,
      Monitoring, and Enforcement                                2-29
4-1   Phasing of Generators                                       4-8
4-2   Enhanced Public Health and Environmental Protection        4-12
4-3   Lesser Degree of Public Health and Environmental
      Protection                                                 4-20
5-1   Sources of Chemicals for Inclusion on the Initial
      List of the Toxic Substance Control Act Interagency
      Testing Committee                                           5-6
5-2   Examples of General Types of Potentially Hazardous
      Waste Constituents                                         5-12
5-3   Examples of Potentially Hazardous Waste Streams from
      Selected Manufacturing Industries                          5-14
5-4   Examples of Spills of Potentially Hazardous Materials      5-23
5-5   Relative Amount of Hazardous Wastes Transported
      Off-Site by Mode and Industry Segment                      5-25
5-6   Examples of Storage Practices in Selected Industries       5-33
5-7   Estimated Portion of Hazardous Wastes from Fourteen
      Manufacturing Industries Disposed by Method, 1973-1975     5-37
5-8   Estimated Percentage of Total Hazardous Wastes
      Treated/Disposed On-Site by Various Methods for
      Selected Industries - 1973                                 5-39
5-9   Estimated Percentage of Total Hazardous Wastes
      Treated/Disposed Off-Site by Various Methods for
      Selected Industries - 1973                                 5-40

                                 xxvii

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                     LIST OF  TABLES  (Continued)
5-10  Estimated Percentage  of Hazardous  Wastes
      Treated/Disposed or Recovered On-Site and
      Off/Site                                                   5-42
5-11  Estimated Percentage  of Hazardous  Wastes
      Treated/Disposed by Level I,  II, or III
      Technology for Selected Manufacturing Industries           5-44
5-12  Capacity of Selected  Hazardous Waste Management
      Service Industry Processes -  1974                           5-47
5-13  Types of Hazardous  Wastes Handled  and Typical
      Treatment/Disposal  Methods for the Hazardous
      Waste Management Industry                                  5-49
5-14  Estimated Percentage  of Hazardous  Industrial
      Wastes Disposed by  Location or Reclaimed  for
      Selected States                                            5-50
5-15  Distribution of Hazardous Waste Recovery  Operations
      in the United States                                        5-54
5-16  Examples of Hazardous Waste Recovery and  Recycling
      Practices in Selected Industries                            5-58
5-17  Waste Oil Sources and Uses, 1972                            5-62
5-18  Estimated Magnitude of Hazardous Wastes from
      Selected Industries that may  be Potentially
      Recoverable or Recyclable                                  5-65
5-19  Generation and Potential Use  of Organic
      Chemical Wastes                                            5-68
5-20  Industries and Hazardous Waste Types Studied  for
      Energy Recovery Potential                                  5-69
5-21  Estimated Annual Waste Quantities  and Total
      Recoverable Energy                                          5-70
6-1   Summary of Hazardous  Waste Generated by EPA Region-1975      6-3
6-2   Estimated Annual Generation of Potentially Hazardous
      Non-Manufacturing Wastes                                    6-6
6-3   EPA Hazardous Substance Spill File Summary
      (February 1977 - February 1978)                            6-17
6-4   Types of Discharges Reported  under Section 311,
      PL-92-500 1976                                             6-20
6-5   Sources of Discharges Reported under Section  311,
      PL 92-500 1976                                             6-22
6-6   Commodities Named Most Often  in Hazardous Materials
      Incident Reports                                           6-23
6-7   Summary - State Control over  Hazardous Wastes              6-25
6-8   Hazardous Waste Control in Large Generator States           6-26
                                xxviii

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                     LIST OF TABLES (Continued)


                                                                 Page

7-1   Number and Types of Reported Incidents  from the
      Improper Management of Hazardous Wastes                     7-3
7-2   Estimated Quantity of Hazardous Manufacturing
      Wastes and Number of Establishments Excluded
      from Regulation at a Generator Limit of 100 kg/mo           7-8
7-3   Number of Manufacturing Establishments  by  2-Digit
      SIC Code                                                   7-46
7-4   Number of Manufacturing Establishments  by  EPA Region       7-47
7-5   Potential Hazardous Waste Generators within Selected
      Manufacturing Industries by EPA Region                      7-49
7-6   Estimated Number of Potential Producers of Hazardous
      Wastes within Selected Categories                          7-50
7-7   Estimated Number of Potential Permittees                   7-54
7-8   Estimated Change in Vehicular Emissions in 1984  from
      Transport of Hazardous Industrial Wastes under
      Subtitle C Regulations                                     7-78
7-9   Gas Composition Data                                       7-83
7-10  Origins and Pollutants in 57 Cases of Ground Water
      Contamination in the Northeast Caused by Leakage
      of Waste Water from Surface Impoundments                  7-128
7-11  Summary of Data on 42 Municipal and 18  Industrial
      Contamination Cases                                       7-130
7-12  Groundwater Contamination from Industrial  Waste
      Land Disposal Sites                                       7-132
7-13  Properties of Wastes that are Hazardous to Living
      Systems                                                   7-169
7-14  Generalized Patterns of the Response of Biological
      Systems to Increased Levels of Environmental Stress       7-171
7-15  Estimated Change in Fuel Consumption in 1984 from
      Transport of Hazardous Industrial Wastes under
      Subtitle C Regulations                                    7-210
8-1   Regulated Hazardous Manufacturing Wastes During  the
      First Year of Phasing (1980) by Region  and SIC Code         8-9
8-2   Regulated Hazardous Manufacturing Wastes During  the
      Second Year of Phasing (1981) by Region and SIC  Code       8-10
8-3   Regulated Hazardous Manufacturing Wastes During  the
      Third Year of Phasing (1982) by Region  and SIC Code        8-11
8-4   Regulated Hazardous Manufacturing Wastes During  the
      Fourth Year of Phasing (1983) by Region and SIC  Code       8-12
8-5   Estimated Change in Vehicular Emissions in 1984  from
      Transport of Additional Hazardous Industrial Wastes
      under Subtitle C Regulations                               8-36
                                 XXIX

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                     LIST OF TABLES  (Continued)
8-6   Estimated Change in Fuel Consumption in 1984 from
      Transport of Additional Hazardous  Industrial Wastes
      under Subtitle C Regulations                                8-67
8-7   Estimated Quantity of Hazardous  Manufacturing
      Wastes and Number of Establishments  Excluded
      from Regulation at a Generator Limit of 1,000
      Kilograms Per Month                                        8-71
8-8   Estimated Change in Vehicular Emissions in 1984
      from Transport of Less Hazardous Industrial Wastes
      under Subtitle C Regulations                                8-87
8-9   Estimated Change in Fuel Consumption in 1984 from
      Transport of Less Hazardous Industrial Wastes under
      Subtitle C Regulations                                    8-115
                        CONTENTS OF VOLUME II
C-l   Typical Waste Solvents Generated by the
      Pharmaceutical Industry                                     C-9
C-2   Typical Potentially Hazardous Wastes Generated
      During Pharmaceutical Active Ingredient Production         C-10
C-3   Selected Potentially Hazardous Waste Constituents
      from the Paint and Allied Products Industry                C-14
C-4   Potentially Hazardous Components of Selected Waste
      Streams from the Organic Chemicals, Pesticides,  and
      Explosives Industries                                      C-18
C-5   Potentially Hazardous Waste Stream Components by
      Standard Industrial Classification, Organic
      Chemicals and Technical Pesticides Industries              C-21
C-6   Potentially Hazardous Constituents of Petroleum
      Refining Waste Streams                                     C-30
C-7   Potentially Hazardous Materials Contained in
      Petroleum Re-refining Sludge                               C-36
C-8   Potentially Hazardous Tannery Waste Constituents           C-38
C-9   Potentially Hazardous Waste Streams from Metal
      Smelting and Refining                                      C-40
C-10  Potentially Hazardous Waste Constituents Generated
      by Metal Smelting and Refining Industries                  C-42
C-ll  Typical Constituents of Potentially Hazardous
      Waste Streams in the Special Machinery Manufacturing
      Industries                                                 C-50

                                  xxx

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                     LIST OF TABLES (Continued)
C-12  Potentially Hazardous Waste Streams from the Production
      of Storage Batteries                                       C-57
C-13  Potentially Hazardous Waste Streams from the
      Production of Primary Batteries                            C-59
D-l   Typical Hazardous Waste Handling Procedures for
      the Textiles Industry                                      D-29
D-2   Typical Hazardous Waste Handling Procedures for
      the Inorganic Chemicals Industry                           D-31
D-3   Typical Hazardous Waste Handling Procedures for
      the Pharmaceutical Industry                                D-34
D-4   Typical Hazardous Waste Handling Procedures for
      the Paint and Allied Products Industry and
      Contract Solvent Reclaiming Operations                     D-36
D-5   Typical Hazardous Waste Handling Procedures for
      the Organic Chemicals and Pesticides Industry              D-39
D-6   Percentage of Hazardous Wastes Treated/Disposed
      On-Site and Off-Site at Selected Organic Chemical
      Plants in 1973                                             D-43
D-7   Typical Hazardous Waste Handling Procedures for
      the Petroleum Refining Industry                            D-45
D-8   Estimate of the Percentage of Wastes Disposed/Treated
      On-site and Off-site by Petroleum Refinery
      in 1973 and 1983                                           D-49
D-9   Typical Hazardous Waste Handling Procedures for the
      Petroleum Rerefining Industry                              D-50
D-10  Percentage of Potentially Hazardous Waste Disposed
      On-site and Off-site or Recycled in 1975                   D-52
D-ll  Typical Hazardous Waste Handling Procedures for the
      Leather Tanning and Finishing Industry                     D-53
D-12  Typical Hazardous Waste Handling Procedures for the
      Metal Smelting and Refining Industry                       D-55
D-13  Typical Hazardous Waste Handling Procedures for the
      Electroplating and Metal Finishing Industry                D-61
D-14  Typical Hazardous Waste Handling Procedures for the
      Special Machinery Industry                                 D-63
D-15  Typical Hazardous Waste Handling Procedures for the
      Electronic Components Industry                             D-65
D-l6  Typical Hazardous Waste Handling Procedures for the
      Storage and Primary Batteries Industries                   D-68
E-l   Relative Amount of Hazardous Wastes Transported Off-
      Site by Mode and Industry Segment                           E-4
E-2   Examples of Types of Vehicles Used by Generators Who
      Transport Wastes                                            E-6
E-3   Wastes Listed in the Hazardous Materials Table             E-16

                                 xxx i

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                     LIST OF TABLES (Continued)
E-4   Estimated Annual Carloads of Selected Potentially
      Hazardous Wastes Carried on Railroads in 1976              E-17
F-l   Summary of Technically Demonstrated Alternative
      Treatment Systems for Wastes Generated by the
      Inorganic Chemical Industries                               F-2
F-2   Cost Comparison of Resource Recovery Treatment
      Systems with Landfill Options for Wastes Generated by
      Inorganic Chemical Industries                               F-3
F-3   Summary of Alternative Treatment Systems for Waste
      Generated by the Organic Chemicals Industry                 F-5
F-4   Cost Comparison of Resource Recovery Treatment
      Systems with Landfill or Incineration Options for
      Wastes Generated by the Organic Chemicals, Pesticides
      and Explosives Industries                                   F-8
F-5   Summary of Alternative Treatment Systems for Waste
      Generated by the Metals Smelting and Refining
      Industries                                                  F-9
F-6   Cost Comparison of Resource Recovery Treatment Systems
      with Landfill Options for Wastes Generated by the
      Metal Smelting and Refining Industries                     F-12
G-l   Comparison of Clearinghouses and Exchanges                  G-2
G-2   Approximate Quantities of Hazardous Waste Listed on
      the Iowa Industrial Waste Information Exchange in 1976
      and 1977                                                    G-6
H-l   Data Sources for Generation Factors                        H-14
H-2   Generation Factors for the Calculation of Estimated
      Quantities of Hazardous Waste Generated by Manufac-
      turing Industries (Based on Employment)                    H-16
H-3   Standard Industrial Classification Major Group 31 -
      Leather and Leather Products                               H-22
H-4   Summary of Hazardous Waste Generated by EPA Region —
      1975 (1000 Metric tons per year)                           H-24
1-1   Approximate Distribution of Hazardous Manufacturing
      Wastes Subject to Regulation in 1984 - Generation Limit
      100 kg/mo (All wastes in 1000"s of metric tons per
      year)                                                       1-5
1-2   Employee Ratios, 1975/1972                                 1-11
1-3   Ratio of total Employees by Interpolation to Given
      Total - 1972                                               1-12
1-4   Program Listing                                            1-16
K-l   United States Distribution of Manufacturing Firms by
      Size for Standard Classifications 20 through 39 - 1972      K-2
                                 xxx ii

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                     LIST OF TABLES (Continued)
K-2   United States Distribution of Manufacturing Firms by
      Size for Standard Industrial Classification 22 -
      Textile Mill Products                                       K-3
K-3   United States Distribution of Manufacturing Firms by
      Size for Standard Industrial Classification 23 -
      Apparel and other Textile Products                          K-4
K-4   United States Distribution of Manufacturing Firms by
      Size for Standard Industrial Classification 24 -
      Lumber and Wood Products                                    K-5
K-5   United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      25 - Furniture and Fixtures                                 K-6
K-6   United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      26 - Paper and Allied Products                              K-7
K-7   United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      27 - Printing and Publishing                                K-8
K-8   United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      28 - Chemicals and Allied Products                          K-9
K-9   United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      29 - Petroleum and Coal Products                           K-10
K-10  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      30 - Rubber and Plastics Products                          K-ll
K-ll  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      31 - Leather and Leather Products                          K-12
K-12  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      32 - Stone, Clay, and Glass Products                       K-13
K-13  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      33 - Primary Metal Industries                              K-14
K-14  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      34 - Fabricated Metal Products                             K-15
K-15  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      35 - Machinery Except Electrical                           K-16
                                xxxiii

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                     LIST OF TABLES (Concluded)
K-16  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      36 - Electric and Electronic Equipment                     K-17
K-17  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      37 - Transportation Equipment                              K-18
K-18  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      38 - Instruments and Related Products                      K-19
K-19  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      39 - Miscellaneous Manufacturing Industries                K-20
L-l   Compounds Identified in Groundwater from Landfill
      Well                                                        L-8
L-2   Range of Leachate Composition in 18 Sanitary Land-
      fills in the United States                                 L-10
M-l   Characteristics of Incineration of Selected
      Hazardous Wastes                                            M-5
M-2   Trace Metals on Particulate Filters from Test
      Incineration of Methyl Methacrylate Wastes                  M-6
M-3   Uncontrolled Emissions from Combustion of Selected
      Munitions in Rotary Kiln Incineration                      M-12
M-4   Emissions Rates from Open Burning of Selected
      Energetic Materials                                        M-13
M-5   Detonation Products of Confined and Unconfined
      Explosions                                                 M-14
M-6   Mass Spectrographic Analysis of Exhaust Gasses from
      Fluidized - Bed Incineration of Solvent Recovery
      Sludges from Paint Production                              M-16
M-7   Analysis of Ash from Incinerated Solvent Recovery
      Still Bottoms at One Paint Production Facility             M-17
M-8   Ambient Air Concentrations of Lead Near Various
      Facilities Burning Waste Oil as Fuel                       M-19
                                 xxx iv

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S.O  SUMMARY

S.I  Introduction

     The objectives of the Resource Conservation and Recovery Act of

1976 (RCRA) are to promote the protection of health and the environ-

ment and to conserve valuable material and energy resources.  Sub-

title C of RCRA provides the U.S. Environmental Protection Agency

(EPA) with the authority to regulate the generation, transportation,

storage, treatment, and disposal of hazardous wastes in a manner

consistent with these objectives.  Subtitle C also authorizes states

to implement their own hazardous waste management programs pursuant

to Subtitle C and directs EPA to promulgate guidelines to assist

states in the development of such authorized programs.

S.2  Description of the Proposed Action

     The proposed action is the set of regulations and guidelines

being developed by the EPA under mandate of the following Sections of

Subtitle C:

     •  Identification and Listing of Hazardous Waste (Section 3001);

     •  Standards Applicable to Generators of Hazardous Wastes (Sec-
        tion 3002);

     •  Standards Applicable to Transporters of Hazardous Wastes
        (Section 3003);

     •  Standards Applicable to Owners and Operators of Hazardous
        Waste Treatment, Storage, and Disposal Facilities (Section
        3004);

     •  Permits for Treatment,  Storage, or Disposal of Hazardous
        Waste (Section 3005);
                                 S-l

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     •  Authorized State Hazardous Waste Programs (Section 3006);

     •  Preliminary Notification of Hazardous Waste Activities
        (Section 3010);

This Environmental Impact Statement (EIS) examines the potential

impacts that could result both from promulgation of the proposed re-

gulations and guidelines and from four regulatory alternatives.  The

specific regulations and guidelines being assessed in this EIS are

summarized below, and the four regulatory alternatives are summarized

in the following section.

     S.2.1  Identification and Listing of Hazardous Waste (Section

3001).  The Section 3001 regulations define those wastes that are to

be considered hazardous  and, therefore, subject to the other Subtitle

C regulations.  Two mechanisms are provided for determining those

wastes that are hazardous:  identifying characteristics and lists of

specific hazardous wastes and processes generating hazardous wastes.

Four identifying characteristics are specified for determining

whether a waste is hazardous:  ignitability, corrosivity, reactivity,

and toxicity.  Any waste which exhibits any of these characteristics

or which is listed (see  Appendix B, Subpart A), would be considered

hazardous and would have to be managed pursuant to the Subtitle C

regulations.

     S.2.2  Standards Applicable to Generators of Hazardous Wastes

(Section 3002).  The Section 3002 regulations establish standards for

manifesting and keeping  records of hazardous wastes shipped off the
                                 S-2

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site of generation; for containerization of hazardous wastes; for




labeling, placarding, and marking of hazardous waste shipments; and




for reporting the disposition of hazardous wastes.  These standards




would apply to those persons or Federal agencies, except households,




who generate and dispose of more than 100 kilograms (about 220




pounds) per month of wastes identified as hazardous under the Section




3001 regulations.  Any person or Federal agency producing and dis-




posing of 100 kilograms or less per month would not be required to




comply with the generator regulations; also any generator engaged




solely in retail trade or principally in farming would have to comply




with the regulations only with regard to waste automotive oil.  Gene-




rators excluded from compliance with the Subtitle C regulations




would, however, still be obligated to dispose their hazardous wastes




in an acceptable manner, e.g., in a landfill that meets RCRA Subtitle




D criteria.




     S.2.3  Standards Applicable to Transporters of Hazardous Wastes




(Section 3003).  The Section 3003 regulations establish standards for




the acceptance, loading, and stowing of hazardous wastes; for compli-




ance with the manifest system; for marking and placarding of trans-




port vehicles; for delivery of hazardous wastes; and for reporting




and cleaning up spills.  These standards would apply to any person or




Federal agency transporting, within the United States, hazardous




wastes that require a manifest under the generator regulations and




also apply to any transporter importing a shipment of hazardous
                                 S-3

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wastes from abroad.  Portions of the standards would also apply to




any transporter who consolidates and transports hazardous wastes not




requiring a manifest.  The transporter regulations would not apply to




persons or Federal agencies transporting hazardous wastes solely on




the site of generation or solely on the site of a permitted hazardous




waste management facility.




     S.2.4  Standards Applicable to Owners and Operators of Hazardous




Waste Treatment, Storage, and Disposal Facilities (Section 3004).




The Section 3004 regulations establish standards for protection of




air quality, groundwater quality, and surface water quality; for




general facility practices and procedures including site selection,




financial requirements, training, emergency preparedness, monitor-




ing, recordkeeping, reporting, and closure; for storage operations;




for treatment/disposal operations including landfills, incinerators,




surface impoundments, and landfarms; and for management of 'special




wastes' (i.e., cement kiln dusts, utility wastes, oil drilling muds/




brines, phosphate rock mining and processing wastes, uranium mining




wastes, and other mining wastes).




     These standards apply to owners and operators of any facility




that treats, stores, or disposes any quantity of any waste identified




as hazardous under the Section 3001 regulations, except 'special




wastes'.   All owners and operators of facilities that treat, store,




or dispose 'special wastes', and no other hazardous waste, would have
                                 S-4

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to comply only with selected general facility standards.  The stan-




dards do wastes from abroad.  Portions of the standards would also




apply to not apply to on-site storage by generators who store their




own wastes for less than 90 days prior to subsequent transport




off-site, but do apply to any such on-site storage which lasts for 90




days or longer.




     Certain practices that are controlled under other Federal acts




are not regulated under the treatment, storage, and disposal stand-




ards.  These practices include underground (deep-well) injection,




ocean dumping, discharges to municipal sewer systems, surface dis-




charges under a National Pollution Discharge Elimination System




(NPDES) permit, and all treatment, storage and disposal activities at




Publicly Owned Treatment Works (POTW) or by ocean dumping barges and




vessels.  However the treatment, storage, and disposal regulations




would apply to above ground storage or treatment of hazardous wastes




prior to underground injection, on-shore facilities associated with




ocean dumping activities, and surface impoundments associated with




NPDES permitted industrial wastewater treatment facilities and




hazardous sludges from such facilities.




     S.2.5  Permits for Treatment, Storage, or Disposal of Hazardous




Waste (Section 3005).  The Section 3005 regulations require that all




owners or operators of facilities treating, storing, or disposing




hazardous wastes obtain a permit prior to facility construction,




modification, or operation.  The regulations establish standards for







                                 S-5

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would be issued for the projected life of the facility.  The owners/




operators of new facilities would be required to obtain permits prior




to construction, and would have to certify that construction was




performed in compliance with the permit before commencing operation.




Special permits would be available for experimental facilities,




qualified hospital and medical care facilities, POTW's, and ocean




dumping barges and vessels.  Standards would be established for




including public participation in the permit review process.




     S.2.6  Authorized State Hazardous Waste Programs  (Section 3006).




Section 3006 provides that states are to be encouraged to apply for




authorization to administer and enforce their own hazardous waste




program pursuant to Subtitle C.  There would be three  types of




authorization for which states could apply:  full authorization, par-




tial authorization, or interim authorization.




     Full authorization would allow a state to carry out a hazardous




waste program in lieu of the Federal program under Subtitle C.  Par-




tial authorization would allow a state to administer and enforce




selected components of a hazardous waste regulatory program estab-




lished pursuant to Subtitle C.  EPA would retain responsibility for




the remaining components of the program.  States would be considered




for partial authorization only if state legislative authority did




not exist for all required program components.  In all cases, the




combination of the state and Federal program would have to meet the
                                 S-6

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requirements of a fully authorized program.  Partial authorization




would be granted for a period not to exceed 5 years, but could be re-




newed.




      Interim authorization would allow a state to carry out a haz-




ardous waste program in lieu of the Federal Program under Subtitle C




for a period not to exceed 24 months, beginning on the date 6 months




after the date of promulgation of regulations under Section 3001.




The purpose of interim authorization is to allow the state to make an




orderly transition from its present program to a program eligible for




full authorization.




     S.2.7  Preliminary Notitication of Hazardous Waste Activities




(Section 3010).  The Section 3010 regulations require that any person




generating or transporting hazardous wastes or owning or operating a




facility for treatment, storage, or disposal of hazardous wastes




notify the EPA Administrator of such activity not later than 90 days




after promulgation of regulations under Section 3001.  Section 3010




specifies in detail who would have to file notification of hazardous




waste activity, when and where such notification would have to be




filed, and the information that would have to be supplied in the




notification.




S.3  Description of the Reasonable Alternatives




     During the development of the proposed Subtitle C regulations,




numerous alternative regulations and regulatory approaches have been




considered.  The proposed set of regulations was selected from among






                                 S-7

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these many options based upon technical, environmental, economic,




institutional, and legal considerations.  Because of the enormous




number of ways in which these various options could be structured




into alternative sets of regulations, the approach taken in this EIS




is to select and to develop a manageable set of meaningful alter-




natives that reasonably bracket the overall objectives and the re-




sultant impacts anticipated from whatever set of regulations are




ultimately promulgated under Subtitle C.  With this approach it is




possible to show the range and types of potential impacts that could




result under various alternatives without having to explicitly con-




sider the almost infinite variety of options for accomplishing the




same or intermediate objectives.




     Four different sets of alternatives have been selected and




structured to reasonably bracket the potential impacts that could be




expected to result.  These alternatives are as follows:




     •  No Action;




     •  Phasing of Generators;




     •  Enhanced Public Health and Environmental Protection;




     •  Lesser Degree of Public Health and Environmental Protection.




     S.3.1  No Action.  The No Action alternative has been selected




for the purpose of analyzing the potential impacts that could result




from taking no action, i.e., not promulgating regulations for Sub-




title C.   For reasons discussed in Chapter 4, the No Action alterna-




tive assumes that no part of RCRA, including Subtitle C,  is to be






                                 S-8

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implemented and that hazardous waste management would continue as




currently practiced.




     S.3.2  Phasing of Generators.  The Phasing of Generators alter-




native has been selected for the purpose of analyzing the potential




impacts that could result from the promulgation of the proposed Sub-




title C regulations on a phased basis, rather than from their total




implementation at one time.  For purposes of analysis, a five-year




time frame measured from the proposed implementation date, is assumed




for the phasing of the regulations.




     While there are many different ways in which the levels for




standards and criteria could be phased in, most would have essen-




tially the same effect—a gradual expansion of the total quantity of




hazardous wastes being controlled by the hazardous waste program.




For purposes of analysis, the method selected emphasizes increasing




the quantity of wastes controlled during the first 5 years following




promulgation of the regulations by gradually expanding the number of




generators brought under control.  With this approach, the level of




the generator limit established under Section 3002 is to be reduced




annually over a five-year period of time in order to bring the larger




generators into the program first and the smaller generators into the




program later.  Furthermore, the generator limit is to be reduced so




that equal amounts of hazardous wastes are annually brought under the




programs's control over the five-year period, i.e., 20 percent of the




total industrial hazardous wastes per year.







                                 S-9

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     S.3.3  Enhanced Public Health and Environmental Protection.  The




Enhanced Public Health and Environmental Protection alternative has




been selected for the purpose of analyzing the potential impacts that




could result from modifications to the proposed Subtitle C regula-




tions designed to further increase public health and environmental




protection above that level afforded by the proposed regulations.




     The basic strategy of this alternative is to expand the defini-




tion of hazardous waste in order to bring additional wastes under




control of the program; to remove exclusions provided for hazardous




waste generators; to apply more stringent design and operational




requirements for storers, treaters, and disposers; to eliminate the




special standards for  "special wastes'; to reduce reporting intervals




for storers, treaters, and disposers; to eliminate the use of




delivery documents in lieu of manifests; and to decrease the life of




permits and impose additional restrictions on obtaining permits.




     S.3.4  Lesser Degree of Public Health and Environmental Protec-




tion.  The Lesser Degree of Public Health and Enviornmental Protec-




tion alternative has been selected for the purpose of analyzing the




potential impacts that could result from modifications to the pro-




posed Subtitle C regulations designed to provide a lesser degree of




public health and environmental protection than that afforded by the




proposed regulations.




     The basic strategy of this alternative is to contract the defi-




nition of hazardous wastes in order to bring fewer wastes under the






                                 S-10

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control of the program; to increase exclusions provided for hazardous




waste generators; to reduce manifest requirements; to apply less




stringent design and operational requirements for storers, treaters,




and disposers; to eliminate regulation of 'special wastes'; to de-




crease recordkeeping times for generators, transporters, storers,




treaters, and disposers; to increase the length of permit exclusions




for generators who store prior to off-site disposal; to eliminate




restrictions on interim authorization; and to ease restrictions on




full and partial authorization.




S.4  Impacts of the Proposed Regulations




     The potential impacts, both beneficial and adverse, that could




result from implementation of the proposed Subtitle C regulations are




summarized in this section.  Two major types of impacts are identi-




fied:  primary impacts and secondary impacts.  Primary impacts




include those effects that would be directly attributable to the




implementation of the proposed regulations.  Secondary impacts




include those effects that would be indirectly attributable to the




implementation of the proposed regulations.  In some cases, secondary




impacts might not be observed until years, or even decades, after




implementation of the regulations.




     Potential impacts are analyzed for two separate years:  1980,




the year of expected implementation of the regulations, and 1984, the




year by which the full effects of the regulations are expected to




become established.  For the reasons discussed in Chapter 7, it is







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anticipated that at least five years would be required for such




effects and resultant impacts to become fully established.




     The impact analysis is both generic in scope and conducted on a




national level due to the extreme waste-specific, process-specific,




and site-specific nature of most impacts, and due to the data limi-




tations noted in the text.   Because most available data relate to




manufacturing industries, the emphasis of the impact analysis is




necessarily directed toward manufacturing industries.




     Over 300 reported incidents of damage from the improper manage-




ment of hazardous wastes were reviewed to assist in identifying the




potential for beneficial impacts resulting from promulgation of the




proposed regulations.  From the way in which most of the incidents




have come to light, it is very likely that the vast majority of such




incidents go unreported, especially human health incidents which may




require many years of exposure and for which direct causative




relationships are difficult to trace or establish.  The reported




incidents indicate that there is often a considerable time interval




between the occurrence of those events which lead to damage and the




time when the damage becomes evident.  Since virtually all of the




reported incidents were discovered only after damage had already




occurred, there is, nationally, a very significant potential for many




similar damage incidents to be detected in the future from wastes




that have already been improperly transported, stored, treated, or




disposed.







                                S-12

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     S.4.1  Potential Primary Impacts.  The potential primary impacts

from implementation of the proposed regulations fall into the follow-

ing areas:

     •  Hazardous wastes to be regulated;

     •  Changes to existing generation, transport, storage, treat-
        ment, and disposal practices and procedures;

     •  Administrative changes;

     •  Air impacts;

     •  Water impacts;

     •  Public health impacts.

     S.4.1.1  Hazardous Wastes to be Regulated.  Approximately 35

million metric tons of hazardous manufacturing wastes could be con-

trolled under the Subtitle C regulations in 1980, and approximately

40 million metric tons of hazardous wastes could be controlled in

1984.  The wastes regulated would constitute slightly over 10 percent

of the total manufacturing wastes (hazardous and non-hazardous) gen-

erated annually in the U.S.  The generator limit of 100 kilograms per

month could exclude about 29,000 metric tons per year of hazardous

manufacturing wastes from regulation.  The excluded wastes would

represent less than 0.1 percent of the total hazardous manufacturing

wastes; approximately 26 percent of manufacturing establishments gen-

erating hazardous wastes would be excluded, by this generator limit,

from complying with the generator regulations.  In addition to manu-

facturing wastes, an indeterminate portion of other large volume

wastes, such as waste automotive oil, coal ash, oil drilling muds and

                               S-13

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brines, cement kiln dusts,  phosphate mining and processing wastes,




and uranium mining wastes,  could be more substantially controlled




under the regulations.




      S.4.1.2  Changes  to Existing Generation,  Transport, Storage,




Treatment, and Disposal Practices and Procedures.  The Subtitle C




regulations would lead  to a number of major changes in existing prac-




tices and procedures.  The changes would be caused by the enactment




of more stringent environmental requirements than those that cur-




rently exist, resultant increases in treatment  and disposal costs,




and specific procedural and operational requirements imposed by the




regulations.




     Generation.  The regulations would result  in procedural changes




in the methods used by  regulated generators for tracking and report-




ing hazardous waste shipments and for preparing such shipments for




transport.  Every generator would be required to provide a manifest




for each off-site hazardous waste shipment—intrastate, interstate,




and international—sent to a facility not owned by the generator and




to file annual reports  and keep records on such shipments.  Genera-




tors designating hazardous waste for an off-site facility owned by




the generator and located in the same state as  the generator would




have to provide a manifest, but would not have  to comply with the




reporting or recordkeeping requirements (although the facility itself




would be subject to reporting and recordkeeping requirements under




Section 3004); shipments to generator-owned facilities in other







                                S-14

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states would have to comply with the recordkeeping and reporting




requirements.  On-site shipments would not have to be manifested, but




would have to be sent to permitted on-site facilities and would have




to be reported to appropriate Federal or state authorities.  All such




hazardous waste shipments would have to be containerized, labeled,




and placarded in accordance with Department of Transportation (DOT)




regulations.  Currently, very few shipments of hazardous wastes are




subject to such requirements.




     In addition, since one major result of the regulations would be




to increase hazardous waste generation, storage, treatment, and




disposal costs, generators would have an incentive to modify proces-




ses so as to reduce and/or change the types and amounts of hazardous




wastes generated, and to enable the increased recycling of hazardous




wastes as process feedstocks.




     Transport.  There are numerous reported instances of hazardous




waste transporters dumping wastes surreptitiously; rather than deliv-




ering the wastes to an environmentally acceptable storage, treatment,




or disposal facility.  The manifest and reporting requirements should




significantly reduce, if not eliminate, such practices.  Furthermore,




the regulations would impose requirements that all transportation-




related spills of hazardous wastes be reported immediately and be




cleaned up by the transporter.  Requirements for accepting, loading,




and stowing hazardous waste shipments would potentially lead to fewer




accidents and spills from hazardous waste transport.  However, the
                                S-15

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average distance over which hazardous wastes are transported would
likely increase as  a result of the regulations.  Increased transport
distances would increase the potential for vehicular accidents.
Increased transport distances would also increase the potential for
spills, and this could off-set some of the benefits indicated above.
     Storage,  Treatment, and Disposal.  A major impact resulting from
the Subtitle C regulations would be the closing of those hazardous
waste management facilities (both off-site and on-site) that could
not or would not comply with the storage, treatment, or disposal
requirements.   It would also lead to the modification of other
hazardous waste management facilities to enable compliance.  It is
expected that  a large portion of existing facilities would require
modification in order to comply with the regulations.
     Those existing hazardous waste storage, treatment, and disposal
practices that are environmentally unacceptable according to the
Subtitle C regulations would be prohibited or restricted or would
have to be modified; some practices could be replaced by other, more
environmentally acceptable practices.
     Existing practices that are likely to be prohibited or severely
restricted by the Subtitle C regulations include:  open burning;
uncontrolled incineration; road application of hazardous waste oil;
the use of landfills without leachate collection systems and ground-
water monitoring systems; the use of surface impoundments without
leachate detection systems and groundwater monitoring systems; land-
farming of highly volatile wastes; the location of landfills, surface
                                S-16

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impoundments, and landfarms within 150 meters (500 feet) of func-




tioning public or private water supplies or livestock water supplies;




and the mixing of incompatible wastes in surface impoundments and




basins, except for the purpose of treatment.  In addition, the Sub-




title C regulations specifically prohibit such existing practices as




open dumping; the placing of reactive wastes, ignitable wastes, and




highly volatile wastes in landfills, surface impoundments, or basins;




the mixing of incompatible wastes in landfills and landfarms; the use




of waste application practices that allow the zone of incorporation




of landfarms to become anaerobic; and the use of continuous feed




treatment facilities without automatic waste feed cut-offs or by-pass




systems that are activated when a malfunction occurs.




     The Subtitle C regulations also impose specific requirements for




the closure of treatment/disposal facilities.  For example, at the




time of closure, all disposal operations would have to be completed




and all wastes removed from storage and treatment facilities for dis-




posal in accordance with the regulations.  Hazardous wastes and




hazardous waste residue would also have to be removed from all sur-




face impoundments that do not meet the standards for landfills and




disposed according to the regulations.  Contaminated soil-filter




medium at landfarms could also have to be removed and disposed




according to the regulations.  Monitoring and maintenance care would




have to be provided for a period that need not exceed 20 years from




closure.






                                 S-17

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     The Subtitle C regulations would likely lead to changes in the

portion of hazardous wastes treated/disposed on-site by generators

and off-site by the waste management industry.  For reasons discussed

in Chapter 7, it is not possible to accurately determine the extent

of any shift that could occur under the Subtitle C regulations.  For

purposes of analysis, a range of 13 to 25 percent off-site treatment/

disposal of hazardous manufacturing wastes in 1984 is used to assess

potential impacts of a shift in off-site disposal.

     S.4.1.3  Administrative Changes.  Implementation of the Sub-

title C regulations would necessitate a widesweeping series of

administrative changes that would affect industry, state governments,

and the Federal government.

     State Administration of Programs.  EPA staff estimates are that

between 45 to 50 of the 56 states and territories could qualify for

interim authorization under the Subtitle C regulations.  Of those

which could  qualify for interim authorization, 3 to 5 might also cur-

rently qualify for  full authorization.  No states would be able to

qualify for  partial authorization before the end of the interim auth-

orization period.

     Although RCRA  encourages states to administer their own author-

ized hazardous waste program in lieu of the Federal program, states

are not required to administer such programs.  If a state does not

choose to administer a program under Subtitle C of RCRA, there would

be a Federally run  program in that state.  RCRA, however, does not

prohibit states without authorized programs from enacting and
                                S-18

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enforcing their own more stringent or non-consistent hazardous waste
program to be run in the state in addition to the Federal program.

At this time, it is not known if any state would run such a program

in addition to the Federal program, or what regulations would be
promulgated under any such overlapping program.  Such additional
state programs, if enacted, would have the potential for creating
various impacts, including the imposition of conflicting and/or

duplicative requirements on hazardous waste generators, transporters,
storers, treaters, and disposers.
     Number of Generators Required to Comply with the Regulations.
It is estimated that on the order of 430,000 to 460,000 manufacturing

establishments, automotive service stations, hospitals, medical
laboratories, and research facilities could have to comply with the

generator regulations.  An indeterminable number of other potential
generators (e.g., "special waste1 generators) could also have to
comply.
     Number of Storers, Treaters, and Disposers Required to Obtain

Permits.  It is estimated that on the order of 29,000 manufacturing
establishments, hospitals, Federal installations, and hazardous waste

management service industry facilities could be required to obtain

permits.  An indeterminable number of other storers, treaters, and
disposers could also be required to obtain permits.

     Paperwork Requirement Under the Regulations.  The potential gen-

erators and permitters identified above would initially have to file
about 430,000 to 460,000 notifications, under Section 3010, with EPA
                                S-19

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or authorized states.   An indeterminable number of transporters and

other potential generators and permittees would also have to file

such notifications.   These permittees would also have to submit

approximately 29,000 permit applications and additional supplemental

material.

     It is estimated that there would be between 350,000 and 690,000

off-site shipments of hazardous industrial wastes annually by 1984,

necessitating industrial generators to prepare between 350,000 and

690,000 manifests annually.  The aggregated generators, transporters,

and owners/operators of hazardous waste management facilities would

each have to keep between 1.0 and 2.1 million manifests in storage on

an annual basis.  Most transporters currently keep at least 3 years

worth of delivery documents in storage due to various company, state,

and Federal requirements.  To the extent that transporters use ac-

ceptable delivery documents in lieu of manifests, or use manifests

in lieu of existing delivery documents, this recordkeeping require-

ment would not constitute an additional burden on transporters.

Each owner/operator of a permitted hazardous waste management fa-

cility would also have to keep an operating log for the life of the

facility, plus 3 years worth of specified records.

     It is estimated that generators and hazardous waste management

facilities could prepare upwards of 547,000 to 577,000 reports annu-

ally for submittal to permitting authorities.  Transporters could

have to file between 140 to 270 spill reports annually; some spill

reports are presently being filed by transporters under other acts.
                                 S-20

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      Most of this recordkeeping and reporting would represent addi-

tional requirements on generators and owners/operators of hazardous

waste management facilities, based upon the existing state

regulations.

     S.4.1.4  Air Quality.  Current hazardous waste generation,

transport, storage, treatment, and disposal practices involve a

variety of activities, each of which has the potential for releasing

air pollutants to the environment.  The potential for the release of

air pollutants by each of these activities would be affected in dif-

ferent ways by the Subtitle C regulations.  For the most part, the

regulations would lead to reduction in the release of air contami-

nants and to resultant improvements in air quality.

     Generation.  Subtitle C regulations would not have a direct

effect on air emissions resulting from activities generating hazard-

ous wastes.  However, to the extent that the regulations change the

economics of disposal or treatment and, thus, result in process modi-

fications engineered to recycle hazardous wastes or to reduce or

alter the quantity and/or types of hazardous wastes generated, Sub-

title C could indirectly result in changes in process air emissions.

     Transport.  Current practices in the transport of hazardous

wastes have the potential to release air emissions in three major

ways:

     •  Through fugitive emissions resulting from improperly covered,
        sealed, or containerized wastes;

     •  Through emissions resulting from spills or other accidental
        releases of hazardous wastes;
                                S-21

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     •  Through emissions resulting from the operation of the trans-
        port vehicle.

     Containerization requirements applied to both intrastate and

interstate shipments of hazardous wastes would reduce the potential

for fugitive emissions from the transport of hazardous wastes.

Requirements for the acceptance,  loading, and stowing of hazardous

wastes, especially incompatible wastes or leaking containers, would

greatly reduce the potential for explosions and spills to occur from

hazardous waste transport.  Requirements for spill clean-up would

reduce the potential for the release of air emissions following

spills. Increased transport distances could result in increased vehi-

cular emissions; however, any such increase in emissions would be

extremely small compared to total national vehicular emissions.

Increased transport distances would also increase the potential for

spills, and this could off-set some of the benefits indicated above.

     Storage.  Current practices in the storage of hazardous wastes

can lead to the release of air pollutants in three major ways:

     •  Through fugitive emissions resulting from improper storage of
        hazardous wastes;

     •  Through emissions resulting from spills, fires, explosions,
        and other accidental releases of hazardous wastes and/or
        their constituents;

     •  Through emissions occurring as the result of storage becoming
        the ultimate form of disposal of hazardous wastes.

     The regulations contain provisions that would reduce the poten-

tial for the release of air emissions from each of these sources.

Hazardous waste storage operations would have to be conducted in such

                                 S-22

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a manner that no discharge occurs; these storage operations would

also have to be monitored and inspected to detect any potential dis-

charge.  Hazardous wastes which, if stored in an open manner, could

release air emissions that could adversely affect human health or

environment would be required to be stored in tanks or other closed

containers.  Restrictions would be placed on the storage of incompa-

tible, explosive, ignitable, or highly reactive wastes to reduce the

potential for accidental releases to occur from improper storage.

Required spill containment measures and contingency plans could fur-

ther reduce the potential for accidental releases and the time neces-

sary to clean up any such accidental releases.  Hazardous wastes

would have to be removed from storage operations during facility

closure and be disposed in accordance with the regulations.

     Treatment/Disposal.  The major sources of air emissions from

current hazardous waste treatment/disposal practices are as follows:

     •  Fugitive emissions from land-based treatment/disposal acti-
        vities, such as landfills, landfarms, and surface
        impoundments;

     •  Emissions generated by explosions, fires, and other acci-
        dents ;

     •  Residuals from the combustion of hazardous wastes by inciner-
        ation or open burning;

     •  Fugitive emissions from other treatment facilities.

     The Subtitle C regulations contain requirements that should

reduce the potential for fugitive emissions from the land-based

treatment/disposal of hazardous wastes.  For example, volatile
                                S-23

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wastes—those with a true vapor pressure greater than 78 mm mercury




at 25 C—would not be allowed to be treated/disposed in landfills,




surface impoundments, or basins; such wastes could be landfarmed only




if the facility owner/operator could demonstrate, before landfarming




the wastes, that the specified air contaminant levels would not be




violated.  With regard to wastes that are landfilled, cover material




would have to be applied daily on active hazardous waste landfill




cells.  At facility closure, a final cover would have to be provided.




Where gases are generated, a gas collection and control system would




have to be installed to control the vertical and horizontal escape of




gases.




     The Subtitle C regulations contain provisions that should, to a




large degree, reduce the potential for fires, explosions, and other




accidents at hazardous waste treatment/disposal facilities.  The pri-




mary cause of most explosions and fires has been the mixing of incom-




patible wastes and the improper treatment/disposal of ignitable or




reactive wastes.  The manifesting, labeling, waste analysis, and




training requirements would reduce the potential for the improper




management of such wastes.  Restrictions on the treatment/disposal of




incompatible, highly reactive, or ignitable wastes and requirements




for contingency plans and spill containment measures would further




reduce the potential for the release of air emissions.




     The Subtitle C regulations contain provisions that should reduce




the potential for the release of air contaminants from the combustion







                                S-24

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of hazardous wastes.  The regulations would require the use of con-

trols for almost all combustion of hazardous wastes and would set

design and operational standards.  Open burning of hazardous wastes

would be prohibited in most instances.  All facilities would also be

required to comply with all applicable standards of the Clean Air

Act, as amended, in order to maintain their permits.

     The regulations would also set specific standards for the incin-

eration of hazardous wastes.  Incinerators would also have to be

designed, constructed, and operated such that fugitive emissions of

unburned hazardous wastes and combustion products are controlled and

such that waste feed is automatically cut-off if significant changes

occur in flame, combustion zone temperature, excess air, or scrubber

water pressure.

     The Subtitle C regulations contain provisions that should reduce

the potential for fugitive emissions from other hazarous waste treat-

ment facilities (e.g., biological, physical, and chemical treatment

facilities).  Fugitive emissions would be controlled, for the most

part, by the regulatory provisions previously discussed.

     To the extent that the Subtitle C regulations result in modifi-

cations to or construction of additional hazardous waste storage,

transportation, disposal, or treatment facilities, there would be an

increase in construction-related air emissions.  The major emissions

would include exhaust from motor vehicles, including construction

equipment,  and fugitive dust raised by such construction activities

as grading, excavation, and movement of equipment.
                                S-25

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     It should be noted,  however,  that there would likely be some




shift in the types of methods used to store, treat, or dispose these




additional wastes under the regulations as compared to the unregu-




lated current practices.   Such shifts would change both the types and




quantities of air emissions generated from the management of specific




wastes.  For example, a shift from landfilling to incineration of a




particular waste would result in the increased release of combustion




products and the reduced  release of particulate matter and/or vola-




tile gases.  Such shifts  could,  to an indeterminable extent, either




enhance or reduce the potential  for indicated reductions in specific




air emissions.  Furthermore,  the construction of new facilities could




lead to increased releases of air  emissions in the vicinity of the




facility and along any transport routes.   Closure of existing facili-




ties could lead to reduced releases of air emissions in the vicinity




of the facility and along transport routes.  The net result could be




both a localized and/or nationwide reduction in the releases of many




air contaminants from hazardous  waste management, and a localized




and/or nationwide increase in the  releases of other air contaminants.




Thus, while there would most  likely be improvements in air quality




under the regulations, there  could also be some localized degradation




of air quality.  All emissions and any localized degradation of air




quality would, however, have  to  be in compliance with all applicable




requirements (e.g., Clean Air Act, OSHA standards, state standards,




and Subtitle C standards).
                                S-26

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     S.4.1.5  Water Quality.  Surface water may be contaminated by

current hazardous waste management practices through spills; runoff

from storage, treatment, or disposal areas; discharges from generat-

ing or treatment facilities; or through discharges of contaminated

groundwaters.  Groundwater contamination may result from infiltration

of spilled materials or wastes stored or disposed on permeable sur-

faces, from percolation of leachate or runoff which has been in con-

tact with hazardous wastes, from leakage or infiltration of fluids,

from poorly sealed or unlined waste impoundments, or from injection

of wastes into aquifers.

     The Subtitle C regulations would potentially result in a small

decrease in the number and size of spills of hazardous wastes, pri-

marily through containerization requirements.  However, any shift to

off-site treatment or disposal would necessitate more handling and

farther transportation distances, and could tend to off-set some of

the potential for a decrease in hazardous spills.  The regulations

would, however, provide for more rapid notification of authorities

and for rapid initiation of clean-up procedures following spills.

     The Subtitle C regulations would result in a considerable

reduction in other surface releases of hazardous wastes.  The regula-

tions would require all generators to store, treat, and dispose of

their hazardous wastes in permitted facilities.  All owners/operators

of such facilities would be required to construct and maintain diver-

sion structures to prevent surface runoff from entering active por-

tions of facilities and to collect any runoff or other discharges
                                 S-27

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originating on the active portions.   All discharges from the

facilities would have to be confined to point sources which comply

with the regulations promulgated under the Clean Water Act.  Storage

facilities would be prohibited from making any discharges.  These

regulations would constitute a substantial improvement over the

present unregulated situation and should produce a decrease in the

number of surface water pollution incidents resulting from hazardous

wastes.

     Since there are no estimates of the extent of existing

groundwater contamination due to hazardous wastes, it is not possible

to quantify the improvements that would result from the regulations.

However, numerous incidents of severe groundwater contamination have

occurred as a result of actions which would be prohibited by these

regulations.  Although the regulations would not address the closure

and clean-up of existing abandoned sites, they would institute

siting, construction, operation, maintenance, and closure require-

ments designed to ensure that no contamination of any underground

drinking water source occurs as a result of any facility in operation

after the regulations are promulgated.

     It should be noted, however, that there could be shifts in the

types of methods used to treat/dispose the wastes brought under regu-

lation by this alternative.  As previously discussed, such shifts

could result in localized changes in the release of specific water

contaminants and, thus, could result in localized changes in water

quality.
                                 S-28

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     S.4.1.6  Public Health.  Appendix J summarizes over 300 reported




incidents that have resulted from the improper management of hazard-




ous wastes.  This improper management resulted in 49 separate




instances of traceable public health impacts, including death, and 84




instances of drinking water contamination, including contamination of




major aquifers.  From the way in which most of the reported incidents




have come to light, it is very likely that the vast majority of such




incidents go unreported, especially human health incidents which may




require many years of exposure, and for which direct causative




relationships are difficult to trace or establish.  The reported




incidents indicate that there is often a considerable time lag




between the occurrence of those events which lead to public health




impacts and the time when the impact becomes evident.  Since vir-




tually all of the reported incidents were discovered only after




damage had already occurred, there is, nationally, a very significant




potential for many similar public health impacts to be detected from




wastes that have already been, or currently are being improperly




transported, stored, treated, or disposed.




     The Subtitle C regulations should significantly reduce the




potential for such public health impacts to occur from future




management of hazardous wastes.  The regulations would reduce the




potential for the release of air, water, and soil contaminants from




hazardous waste management and, thus, for resultant public health




impacts.   Furthermore, requirement for recording where hazardous
                                 S-29

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wastes are disposed and prohibitions against using such sites for




residential or agricultural purposes could prevent future public




health catastrophes, such as that which occurred at Love Canal in




Niagara Falls, New York (see Section 7.1.6).




     S.4.2  Potential Secondary Impacts.  The potential secondary




impacts from implementation of the proposed regulations include




impacts to the following areas:




     •  Physiography and soils;




     •  Biological environment;




     •  Water use;




     •  Hazardous waste management facility capacity;




     •  Land use;




     •  Social impacts;




     •  Resource conservation and recovery;




     •  Energy use;




     •  Special interest points.




     S.4.2.1  Physiography and Soils.  The principal areas of envi-




ronmental concern regarding physiography and soils are soil contami-




nation, alterations of topography, and loss and physical disruption




of  soils.  At present, impacts to soils from hazardous wastes are




widespread, primarily as a result of spills and unregulated dumping.




The manifest system and permit requirements would eliminate most




irresponsible disposal of these wastes.  The closure of existing
                                S-30

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sites which do not meet the proposed standards would result in




additional impacts to both physiography and soils.  In some cases,




significant volumes of clayey soils would have to be acquired and




placed at new disposal sites.  Excavation of the clays would result




in alterations of topography.  Creation of new disposal sites could




result in contamination of additional soils; however,  any such con-




tamination would occur in a controlled manner and would be localized




in relatively few places, as compared to the present situation.




     S.4.2.2  Biological Environment.  The major routes of hazardous




waste transport to, and subsequent impact on biological systems  are




by:  groundwater contamination via leaching, surface water contam-




ination via runoff, air pollution, poisoning via direct contact,




poisoning via the food chain, and fires and explosion.  The proposed




regulations would substantially reduce improper transport, storage,




treatment, and disposal of hazardous wastes, and would result in the




containment and long-term separation of these wastes from biological




systems.  Although the impact of the regulations cannot be quanti-




fied, many of the types of incidents of contamination and associated




biological effects which have been observed in the past would be




prevented by promulgation of the regulations.  In general, biological




impacts due to contact with regulated wastes or from fires or explo-




sions involving regulated wastes would be minimized, while other




impacts would be reduced in proportion to the reduction of air;
                               S-31

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water, and soil contamination.  Creation of new disposal sites would




necessitate the preemption of land from existing uses.  Although




siting restrictions would protect wetlands and critical habitats of




endangered species, construction of disposal facilities in remote




areas could impact other habitat types that may be of value to wild




or domesticated animals.




      S.4.2.3  Social Impacts.




      Demographic Impacts.  Promulgation of the Subtitle C regulations




would likely cause some plant closings and job losses in a few seg-




ments of some industrial categories (e.g., textile industry, inor-




ganic chemicals industry, organic chemicals industry, metals smelting




and refining industry, electroplating and metal finishing industry).




Such  plant closings and job losses would have the potential to cause




relocations of some of the effected workers and their families.




There would be a potential for some out-migrations from communities




or areas for which plants being closed constituted the primary source




of employment.




      Operational requirements for hazardous waste management, under




the Subtitle C regulations, would likely result in additional workers




being required to track the hazardous wastes; to transport the




wastes; and to store, treat, or dispose the wastes both off-site and




on-site.  Additional workers would also be required to administer and




enforce the regulations at both the state and Federal levels.
                                 S-32

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Construction workers would also be required for necessary modifi-




cations to existing facilities or construction of new facilities.  It




is estimated that a total of at least 20,000 workers could be re-




quired nationally, by 1984, to store, treat, or dispose hazardous




wastes.  Data are not available to estimate how many of these would




be new workers due to the Subtitle C regulations.




     Some populations shifts could occur if the required number of




workers was not available where needed, particularly in the case of




treatment/disposal sites being located in rural or undeveloped areas.




Any such shifts in population are expected to be relatively small on




a national scale; however, there could be localized instances of a




relatively large influx of workers.




     Social Conditions.  Impacts to existing social conditions could




result from changes in the siting and operation of hazardous waste




management facilities and from any population shifts caused by the




regulations.  The increased public health protection that would be




derived from the regulations would provide significant social




benefits.  Many of the social costs related to the exposure of




workers and the general public to hazardous wastes and their resi-




duals, under current practices, would be reduced or eliminated.




     The regulations, while not applying to household wastes, could




also focus more public attention on the problems associated with the




improper treatment/disposal of hazardous wastes, and could result in
                                S-33

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increased care in the disposal of hazardous wastes and a further




reduction in public health impacts from such disposal.




     On the other hand,  an increased public awareness of problems




that have been associated with improper disposal of hazardous wastes




could, in the short-term, add to the opposition to local siting of




hazardous waste management facilities.  However, in the long-term,




promulgation of the regulations, accompanied by increased public




participation in the facility siting process and specific




demonstrations that the objectives of the regulations can be




achieved, could also serve to lessen such opposition in the future




and could lead to more effective siting of facilities.




     Social impacts could also result from the expansion of construc-




tion of hazardous waste management facilities and from any increase




off-site transport of hazardous wastes.  The construction and opera-




tion of new facilities,  especially off-site facilities, would have




aesthetic impacts and could result in localized noise impacts, both




in the vincinity of the facility and along any transportation routes.




     Shifts in population that may result from the Subtitle C regula-




tions would have the potential to cause social impacts.  The magni-




tude of any such impacts would be site-specific and would depend upon




such factors as the size of the shift relative to the size of the




existing population in affected areas, the rate of the shift, the




existing infrastructure in the affected areas, and the adequacy of




advanced planning.







                                S-34

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     S.4.2.4  Hazardous Waste Management Facility Capacity.  It is




estimated that there would potentially be sufficient process capacity




to manage hazardous industrial wastes shipped off-site in 1980.  In




the case of 13 percent off-site shipment, there would potentially be




sufficient process capacity to manage hazardous industrial wastes




shipped off-site in 1984.  In the case of 25 percent off-site ship-




ment, there would potentially be a shortfall of 2.6 million metric




tons of environmentally adequate off-site capacity for treating/dis-




posing hazardous industrial wastes in 1984.  Approximately 45 addi-




tional off-site facilities could be required by 1984.  Data are not




available to estimate if there would be any potential shortfall in




environmentally adequate, on-site, hazardous waste management process




capacity under the Subtitle C regulations.




     Even in those instances where sufficient capacity is estimated




to be available nationwide, localized shortfalls of capacity could




occur as discussed in Chapter 7.  Furthermore, treatment/disposal of




hazardous non-manufacturing wastes could create shortfalls or exacer-




bate existing shortfalls.




     S.4.2.5  Land Use Impacts.  More total land, off-site plus on-




site, would be required for hazardous waste management under the Sub-




title C regulations than for hazardous waste management under current




practices.  The additional land would be required, both for the




construction of permitted facilities necessary to meet any additional
                                S-35

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capacity shortfalls that could occur under the Subtitle C regula-




tions, and for such conjunctive developments as construction of




roads, power lines, and pipelines.   However, while more total land




would be required,  in the case of 13 percent off-site shipment, there




could be less off-site land use and more on-site land use by 1984




than under current  practices.  In the case of 25 percent off-site




shipment, there could be more off-site land use and less on-site land




use by 1984 than under current practices.




     Existing land uses would cease, either permanently or temporari-




ly, on all land converted to hazardous waste management areas.  Fol-




lowing closure of the hazardous waste management facility and rehab-




ilitation of the site according to  the closure plans, the land would




be available for limited new uses or, in some cases, previously




existing uses.  Sites from which hazardous wastes have not been




removed would be precluded from residential and agricultural uses,




and may be precluded from some recreational and grazing uses




following closure.   Any activity requiring excavation would also be




prohibited at sites where wastes are not removed.  Further, since the




regulations would require records to be kept of the location and




types of all hazardous wastes remaining at the site, the potential




for incidents, such as that which occurred at Love Canal in Niagara




Falls, New York, would be reduced.




      To  the extent that the regulations would prevent other lands




from  being contaminated by improper disposal, dumping, storage, or






                                 S-36

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treatment under current practices and regulations, there would be a




potential for offsetting land use benefits.




     S.4.2.6  Water Use Impacts.  The potential for the degradation




of both groundwater and surface water would be reduced under the reg-




ulations.  To the extent that degradation of water quality would have




resulted in a decreased supply of surface water or groundwater being




available to some or all consumers in the water use area, there would




be an additional supply of groundwater or surface water potentially




available to such consumers and fewer restrictions on the productive




use of such surface water and groundwater supplies.  New facilities




would, however, be additional consumers of water.




     S.4.2.7  Resource Conservation and Recovery.  Since one of the




major impacts of the regulations would be to increase generator's




costs and the costs associated with hazardous waste transport,  stor-




age, treatment, and disposal, there would be an incentive provided by




the regulations for generators to modify processes so as to enable




increased recycling of hazardous wastes as process feedstocks,  to




reduce the quantities of hazardous wastes generated by specific




processes, or to alter the nature of the wastes generated by treat-




ment.  Any changes would be extremely waste stream and process-




specific.  Furthermore, since the regulations prohibit the placing of




ignitable wastes in landfills, landfarms, surface impoundments, and




basins,  the potential for increased incineration of such wastes, with




possible energy recovery, would be greatly enhanced.







                                 S-37

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     S.4.2.8  Energy Use.   The facility modification and construction




that would be necessary under the regulations would result in




increased energy use.  More energy would also be used for the




construction of new facilities under the regulations than would have




otherwise been needed due  to requirements directed toward making




these facilities more environmentally secure.  Increased energy use




would also result from required changes in storage, treatment, and




disposal operations under  the regulations (e.g., higher incineration




temperatures and longer retention times).  While any increase in re-




source recovery would also likely require the initial input of addi-




tional energy, energy savings from increase energy recovery, from




further reduction in the quantities of wastes requiring storage,




treatment, or disposal, and from materials recovery and reuse, could




result in an overall energy savings from resource recovery




operations.




     The changes in energy use from the transport of hazardous wastes




would depend upon such factors as shifts in the portion of wastes




managed on-site and off-site and changes in transport distances.  The




estimated change in energy use in 1984 ranges from a decrease equiva-




lent to about 20,000 barrels of crude oil for an average 100-mile




round-trip distance with 13 percent off-site treatment/disposal, to




an increase equivalent to  about 2.2 million barrels of crude oil for




an average 1,000-mile round-trip distance with 25 percent off-site




treatment/disposal.
                                S-38

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     S.4.2.9  Impacts to Special Interest Points.  The Subtitle C




regulations contain provisions which, while not applying specifically




to the protection of special interest points, would provide indirect




benefits to special interest points and to the human enjoyment of




such features.  For example, restrictions on the siting of hazardous




waste management facilities in wetlands and critical habitats would




reduce the potential for adverse impacts to such areas.  Furthermore,




provisions that.would potentially reduce the release of air; water,




and soil contaminants from hazardous wastes management activities




would reduce the potential for these contaminants to infringe upon




special interest points and would increase, or at least maintain, the




opportunity for human enjoyment of such special interest points.




However, to the extent that additional lands would be disturbed by




facility construction and operation and by conjunctive developments,




there would be an increased potential for some infringement upon




other special interest points.




S.5  Impacts of the Alternatives




     This section summarizes the potential changes in impacts, rela-




tive to those of the proposed action, that could result from imple-




mentation of each alternative.  Impacts that would be substantially




the same as those of the proposed regulations are not presented in




order to avoid duplication.




     S.5.1  No Action Alternative.  Since implementation of RCRA is




mandated by an act of Congress, implementation of this alternative is
                                 S-39

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not considered to be feasible without an additional act of Congress




repealing RCRA.   However,  if implemented,  this  alternative would




result in a continuation of current hazardous waste management prac-




tices, modified by: the requirements of any further legislation enact-




ed by individual states.




     The overall control of hazardous wastes  would be much less




effective than with a national program.  The  public health and




environmental problems previously discussed would continue to occur,




though they could be mitigated by the enactment of more stringent




state regulations than those that currently exist.  In any state with




significantly less stringent regulations than it would have under the




Federal program, there could be a significant increase in public




health and environmental problems relative to those that would occur




under the Subtitle C regulations.  Impacts could also extend to




neighboring states.




     S.5.2  Phasing of Generators Alternative.   Under this alterna-




tive, a total of approximately 74 million metric tons of hazardous




industrial wastes could be excluded from regulation during the first




four years following implementation of the Subtitle C regulations.




This would be about a 50*percent reduction in regulated hazardous




industrial wastes, as compared to the proposed regulations.  There




would be no change in wastes regulated after  the first four years.




     During the first year, regulatory control would essentially be




limited to industries in SIC Codes 26 (Paper  and Allied Products), 28
                                S-40

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(Chemicals and Allied Products), 29 (Petroleum and Coal Products),




and 33 (Primary Metal Industries), with about 75 percent of the




uncontrolled wastes being generated within SIC Code 28.  While wastes




would be regulated within all EPA Regions, Regions III, IV, and V




would generate about 65 percent of the regulated wastes.  Approxi-




mately 230 manufacturing establishments could be regulated nation-




wide.




     During the second year, regulatory control would be extended to




SIC Codes 31 (Leather and Leather Products),  32 (Stone, Clay,  and




Glass Products), 34 (Fabricated Metal Products), and 35 (Machinery,




Except Electrical), with about 60 percent of  the controlled wastes




being generated within SIC Code 28.  Control  efforts would be  more




pronounced in EPA Regions III, IV, and V, though their overall share




of regulated wastes could decrease to about 61 percent, with one-half




of that being in Region V.  Approximately 1,500 manufacturing  estab-




lishments would be regulated nationwide.




     During the third year, regulatory control would be extended to




industries in SIC Codes 25 (Furniture and Fixtures), 30 (Rubber and




Miscellaneous Plastic Products), 37 (Transportation Equipment), and




39 (Miscellaneous Manufacturing Industries).   EPA Region V would gen-




erate about 29 percent of the regulated wastes, while Regions  II,




III,  IV,  and V would each generate between 10 and 16 percent.   About




4,300 manufacturing establishments would be regulated nationwide.
                                S-41

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     During the fourth year,  regulatory control would be extended to




establishments in all SIC codes  except 23 (Apparel and Other Textile




Products), 24 (Lumber and Wood Products), and 27 (Printing and




Publishing).  The distribution of regulated wastes among the EPA




regions would remain essentially the same as in the previous year.




Approximately 15,500 manufacturing establishments could be regulated




nationwide.




     A major benefit resulting from this alternative would be the




gradual expansion of administrative requirements, rather than the




abrupt imposition of such requirements.  Administrative requirements,




primarily paperwork, would be reduced during the first four years




following implementation of the regulations.  There could be a 50




percent reduction in manifests and over a 97 percent reduction in the




submittal of annual reports during this period, compared to the




proposed regulations.  Reduction in administrative requirements could




also encourage additional states to apply for interim or full author-




ization.  The longer transition period would also provide an in-




creased opportunity for planning and instituting measures to mitigate




the potential impacts of any population shifts or of any shortfalls




in hazardous waste management facility capacity.




     To the extent that the 74 million metric tons of hazardous in-




dustrial wastes excluded from the generator regulations, under this




alternative, were not to be managed in a manner equivalent to that




required under the Subtitle C regulations, there would be an







                                S-42

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increased potential for the release of air, water, and soil contami-

nants from these wastes.   Changes in public health and environ-

mental effects would be directly related to changes in the relese of

air, water, and soil contaminants.  To the extent that increased

releases were to occur, there would be an increased potential for the

occurrence of adverse public health and environmental impacts.  Both

chronic health effects, related to long-term, low-level exposure to

such contaminants, and water quality impacts could continue for many

years following improper disposal of such wastes.

     S.5.3  Enhanced Public Health and Environmental Protection

Alternative.  Table S-l indicates some of the changes under this

alternative, compared to the proposed regulations.  These and other

major changes are discussed below.

     S.5.3.1  Primary Impacts.

     Hazardous Wastes to be Regulated.  It is estimated that approxi-

mately 57 and 65 million metric tons of hazardous manufacturing

wastes would be controlled, under this alternative, in 1980 and 1984,

respectively.  This would represent about a 63 percent increase in

the hazardous industrial wastes controlled in both these years.

There would also be an indeterminable, but possibly quite large,
 It should be noted that as discussed in Section 7.1.2, it is
 expected that at least 5 years would be necessary to act upon and to
 issue all permits under the proposed regulations.  Thus, some inde-
 terminable portion of the 74 million metric tons of hazardous waste
 excluded under this alternative might not be managed under the
 proposed regulations as adequately as would be required following
 issuance of a permit.
                                S-43

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                                      TABLE S-l

            COMPARISON OF POTENTIAL IMPACTS OF THE PROPOSED REGULATIONS AND
                THE ENHANCED AND THE LESSER DEGREE OF PUBLIC HEALTH AND
                       ENVIRONMENTAL PROTECTION ALTERNATIVES*
Impact
area
Regulated manufacturing
wastes - 1984
Proposed
regulations
40 million
metric tons
Enhanced
protection
alternative
65 million
metric tons
Lesser degree
of protection
alternative
24 million
metric tons
Regulated non-manufacturing
wastes
Number of regulated
generators
Number of regulated
storers, treaters,
and disposers
Number of manifests
prepared annually - 1984

Number of reports
submitted annually
Number of workers required
to store, treat, or dispose
regulated wastes - 1984
Off-site process capacity
shortfall for hazardous
manufacturing wastes

      1980
      1984
        13% off-site shipment
        25% off-site shipment
 Change  in annual off-site
 landfill requirements after
 1984t
        13%  off-site shipment

        25%  off-site shipment
Potentially
large quantities
430,000-460,000


29,000
350,000-690,000

550,000-580,000

20,000
 2.6 million
 metric  tons
 (approximately
 45 additional
 facilities)
 -160 to  -320 acres
 800 to  1,600 acres
Potentially
large quantities

^2.2 million
not determinable
Potentially
small quantities

110,000-140,000


not determinable
580,000-1,100,000     200,000-420,000

8.9 million           140,000-170,000

33,000                12,000
2.7 million metric
tons  (approximately
45 additional facilities)

0.9 million metric
tons  (no additional
facilities)
9.6 million metric       -
tons  (approximately
160 additional
facilities)
 -260 to -520 acres    -95 to -190 acres
 1,300 to 2,600 acres  500 to 1,000 acres
 *Based upon methodologies  and  assumptions described  in Chapters 7 and  8.

 tThere would be commensurate changes  in  on-site  landfill requirements.
                                             S-44

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increase in hazardous non-manufacturing wastes regulated under this
alternative.
     Changes to Generation, Transport, Storage, Treatment, and Dispo-
sal Practices.  Additional changes to generation, transport, storage,
treatment, and disposal practices, similar to those discussed for the
proposed regulations, would be likely to occur under this alternative
due to the additional wastes being regulated; due to the additional
generators, transporters, and owners/operators of hazardous waste man-
agement facilities being regulated; due to the enactment of more
stringent environmental requirements; due to resultant increases in
storage, treatment, and disposal costs; and due to the imposition of
additional procedural and operational requirements.
     Administrative Changes.  Several changes in the administration
of hazardous waste management programs would result from promulgation
of the regulations within this alternative.  It is likely that fewer
states would apply for authorization under this alternative because
expansion of both the quantity of hazardous wastes and the number of
generators, transporters, storers, treaters, and disposers being
regulated, plus the increases in reporting frequencies, would lead to
increased administrative and manpower requirements for authorized
states.
     It is estimated that on the order of 2.2 million manufacturing
establishments, automotive service stations, hospitals, medical
laboratories, research facilities, farmers, and dry cleaning estab-
lishments could have to comply with the generator regulations under
                                 S-45

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this alternative.   This would represent over a 400 percent increase
in the number of generators  being regulated, compared to the proposed
regulations.  It is expected, however,  that there would be only a

relatively small increase in the number of permittees under this

alternative.
     It is estimated that the industrial generators could have to

prepare between 580,000 and  1.1 million manifests annually by 1984.
The aggregated generators, transporters, and hazardous wste manage-
ment facility owner/operators could each have to keep between 1.7

million and 3.4 million manifests in storage on an annual basis.
This would represent over a  60 percent  increase in both requirements,
as compared to the proposed  regulations.  It is estimated that gener-

ators and permittees could prepare upward of 8.9 million quarterly
reports on an annual basis—over a 1,500 percent increase.
     The identified generators and permittees would have to file over

2.2 million notifications under Section 3010—over a 400 percent

increase.  Furthermore, since potential permittees would have to

renew permits every 5 years, rather than being issued one permit good

for the projected life of the facility  as under the proposed regula-
tions, there could be up to  a six-fold  increase (in the case of a

30-year facility site life)  in the paperwork associated with obtain-

ing permits.  These potential permittees would also have to prepare

approximately 29,000 Supplemental Environmental Analyses as part of

the initial permit review procedure; these Supplemental Environmental

Analyses would not be required under the proposed regulations.
                                 S-46

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     Air and Water Quality.  The regulations under this alternative




would have the potential to cause further changes, primarily reduc-




tions, in the release of air emissions and water effluents from the




generation, transport, storage, treatment, and disposal of hazardous




wastes, as compared to the proposed regulations.  To the extent that




the requirements under this alternative would cause further changes




in the economics of storage, treatment, or disposal relative to those




of the proposed regulations, there would be a greater potential for




generators to make process modifications designed to further increase




hazardous waste recycling and to reduce the quantity and/or types of




hazardous wastes generated; any such process modifications would




likely lead to changes in air emissions and water effluents released




by processes generating hazardous wastes.  Furthermore, to the extent




that additional generators would be brought under control of the pro-




gram through the expanded definition of hazardous wastes and the eli-




mination of exclusions, the potential for such process modifications




and resultant changes in air emissions and water effluents would be




increased.




     The additional 25 million metric tons of potentially hazardous




industrial wastes (plus other hazardous wastes) estimated to be




brought under control of the regulations in 1984, by this alterna-




tive, would now have to be transported, stored, treated, or disposed




in accordance with the Section 3004 regulations.  Since most of these




wastes would otherwise have been transported, stored, treated, or
                                 S-47

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disposed by methods that are not likely to be environmentally accept-
able under the Section 3004 regulations,  the overall potential for
the release of hazardous air emissions or water effluents from the
management of such additional wastes  would be reduced.
     Additional requirements imposed  by this alternative would fur-
ther reduce the potential for the release of air and water contami-
nants from the management of both the additional 25 million metric
tons of hazardous industrial wastes controlled under this alterna-
tive, and the 40 million metric tons  also controlled under the pro-
posed regulations.  The major impact, with regard to air quality,
would result from changing the application of the Threshold Limit
Values  (TLV) from an air human health and environmental standard to a
mandatory standard with which facilities  must always be in compli-
ance, and the imposition of the TLV's as  a maximum concentration not
to be exceeded at any time, rather than as a time-weighted average
not to be exceeded over an 8-hour day and 40-hour week.  The major
impact, with regard to water quality, would result from requiring
lower permeabilities for soil liners  for  landfills and surface
impoundments.
     To the extent that additional storage, treatment, or disposal
facilities would have to be modified  or would have to be constructed
under this alternative, there would be an increase in fugitive dust,
vehicular emissions, and runoff from such construction activities.
     It should be noted, however, that there could be shifts in the
types of methods used to treat/dispose the additional wastes
                                S-48

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regulated under this alternative, compared to the unregulated methods




that would have been used under the proposed regulations.   As previ-




ously discussed, the net result could be both a localized and/or




nationwide reduction in the releases of many air and water contamin-




ants from hazardous waste management, and a localized and/or




nationwide increse in the total releases of other air and water con-




taminants.  Thus, while there would most likely be improvements in




air and water quality due to this alternative,  there could also be




some localized degradation of air and water quality.  All releases




and any localized degradation of air or water quality would, however,




have to be in compliance with all applicable requirements (e.g.,




Clean Air Act, Clean Water Act, OSHA standards, state standards, and




Subtitle C standards).




     Public Health.  The regulations under this alternative would




have the potential for further increasing the public health benefits




to be derived from the control of hazardous wastes.  The regulations




would reduce the potential for the release of air, water,  and soil




contaminants from hazardous waste management and, thus, for resultant




public health impacts.  Furthermore, since most of the additional




wastes to be regulated under this alternative would be potentially




toxic organic wastes, there could be a much greater potential for




significant reductions in chronic health effects related to long-




term, low-level exposure to residuals resulting from the improper




disposal of such wastes.







                                 S-49

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     S.5.3.2  Secondary Impacts.   The major changes in secondary

impacts that could occur,  as  a result of implementation of this

alternative, would result  from the control of an additional 25 mil-

lion metric tons of potentially hazardous industrial wastes,  plus

other hazardous wastes; the enactment of more stringent environmental

requirements with regard to transport,  storage,  treatment, and dis-

posal of hazardous wastes; and resultant increases in hazardous

wastes storage, treatment, and disposal costs.   To the extent that

these changes result in reductions in the release of air, water, and

soil contaminants, there would be further beneficial impacts  to the

biological environment, soils, water use, land  use, and special

interest points, as compared to the proposed regulations.

     The above changes would also provide increased incentives for

generators to modify processes so as to enable  increased recycling of

hazardous waste as process feedstocks,  to reduce the quantities of

hazardous wastes generated by specific processes, or to change the

nature of wastes generated.  Energy use could,  however, be increased

by the additional facility modification and construction required

under this alternative, by required changes in facility operation and

closure, and by any increases in  hazardous wa^te transport.  Changes

in resource recovery could lead to other changes in energy use,

including additional savings in energy use.

     Additional industrial plant  closings or relocations due to the

increased costs, under this alternative, could lead to additional

population shifts and resultant impacts.  Additional workers would
                                 S-50

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also be required to manage hazardous wastes, to construct facilities,

and to administer and enforce the regulations.  It is estimated that,

under this alternative, at least 33,000 workers could be required

nationally, by 1984, to store, treat, or dispose hazardous wastes;

this would represent over a 60 percent increase in this requirement,

compared to the proposed regulations.  Additional population shifts

could occur in response to the increased personnel requirements; any

such shifts would be expected to be small on a national scale, though

there could be localized instances of a relatively large influx or

outflux of workers.

     It is estimated that, under this alternative, there could be a

shortfall of 2.7 million metric tons of environmentally adequate off-

site capacity for hazardous industrial wastes in 1980.  Approximately

45 additional permitted off-site facilities could be required in

1980, compared to the proposed regulations.  In the case of 13 per-

cent off-site shipment, there could be a shortfall of 0.9 million

metric tons of environmentally adequate off-site capacity in 1984.

Since less capacity would be required in 1984 than in 1980 in the

case of 13 percent off-site shipment, no additional permitted off-

site facilities could be required in 1984.  In the case of 25 percent

off-site shipment, there could be a shortfall of 9.6 million metric

tons of environmentally adequate off-site capacity in 1984.  Approxi-

mately 160 additional permitted off-site facilities could be required

in 1984 to meet this shortfall.   Based upon the estimated shortfall

under the proposed regulations,  only 115 of the necessary permitted
                                S-51

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facilities would be attributable to this alternative.   Data are not




available to estimate potential  shortfalls  in environmentally ade-




quate on-site process capacity.




     More total land, off-site plus on-site,  would be  required under




this alternative than under the  proposed regulations.   This land




would be required both for the construction of the permitted facili-




ties necessary for the storage,  treatment,  and disposal of the addi-




tional wastes regulated under this alternative,  and for such conjunc-




tive developments as construction of roads, power lines, and pipe-




lines.  However, while more total land would be  required under this




alternative, in the case of 13 percent off-site  shipment, there could




be less off-site land use and more on-site  land  use by 1984, compared




to the proposed regulations.  In the case of 25  percent off-site




shipment, there could be more off-site land use  and less on-site land




use by 1984, compared to the proposed regulations.




     Existing land uses would cease, either permanently or temporari-




ly, on all land converted to hazardous waste management uses.  Exist-




ing animal habitats would also be disturbed on all such lands.  Fol-




lowing closure of the hazardous waste management facility and any




rehabilitation of the site, according to the closure and long-term




care plans, the land would be available for new or, in some cases,




previously existing uses.  The biological community on disturbed




areas could differ in species composition and diversity following




site rehabilitation.
                                S-52

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     The construction and operation of the required facilities, espe-




cially off-site facilities, would cause additional aesthetic impacts




and could result in additional instances of localized noise impacts.




Public opposition to the siting and construction of hazardous waste




management facilities could be further exacerbated by the increased




requirements for such facilities under this alternative.  However,




this opposition could be somewhat mitigated by the more stringent




environmental requirements under this alternative, by the require-




ment for the preparation of a Supplementary Environmental Analysis as




part of the permit review process, and by the requirement for permits




to be renewed every 5 years, rather than not at all.




     S.6.3  Lesser Degree of Public Health and Environmental Protec-




tion Alternative.  Table S-l indicates some of the changes under this




alternative, compared to the proposed regulations.  These and other




major changes are discussed below.




     S.6.3.1  Primary Impacts.




     Hazardous Wastes to be Regulated.  It is estimated that approxi-




mately 20 and 24 million metric tons of hazardous manufacturing




wastes would be controlled under this alternative in 1980 and 1984,




respectively.  This would represent about a 40 percent decrease in




the hazardous industrial wastes controlled in both these years.




There would also be an indeterminable, but possibly quite large,




decrease in hazardous non-manufacturing wastes regulated under this




alternative.
                                 S-53

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     Changes to Generation,  Transport,  Storage, Treatment, and Dispo-




sal Practices.  Fewer changes of the type discussed for the proposed




regulations would be likely  to occur to existing generation, trans-




port, storage, treatment,  and disposal  practices under this alterna-




tive due to the lesser amount of wastes being regulated; due to the




reduced number of generators, transporters,  and owners/operators of




hazardous waste management facilities being  regulated; due to the




enactment of less stringent  environmental requirements; due to




resultant reductions in storage, treatment,  and dispoal costs; and




due to the imposition of fewer procedural and operational




requirements.




     Administrative Changes.   Several changes in the administration




of hazardous waste management programs  would result from promulgation




of the regulations within  this alternative.   Additional states could




consider applying for full,  partial, or interim authorization due to




elimination of almost all  restriction on granting of interim authori-




zation, elimination of restrictions on  granting of full or partial




authorization to states with  more stringent  standards, and reduc-




tions in administrative and  manpower requirements.  However, the




elimination of the toxicity  characteristic could also off-set such a




potential for increases in state authorization.  If enough states




felt that the regulations  were not adequate  without the inclusion of




toxic wastes,  there could  be  an overall reduction in authorized




states under this alternative.  Furthermore, the less stringent







                                 S-54

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standards and reduced amount of hazardous waste controlled under this




alternative could increase the potential benefits to, and, thus, the




likelihood of, a state enacting a more stringent, independent,




hazardous waste program.




     It is estimated that on the order of 110,000 to 140,000 manufac-




turing establishments, hospitals, and medical laboratories could have




to comply with the generator regulations under this alternative. This




would represent a 70 percent reduction in the number of generators




being regulated, compared to the proposed regulations.  Data are not




available to estimate the reductions in the number of transporters




and owners/operators of hazardous waste management facilities to be




regulated.




     It is estimated that the industrial generators could have to




prepare between 200,000 and 420,000 manifests annually by 1984.   The




aggregated generators, transporters, and hazardous waste management




facility owners/operators could each have to keep between 200,000 nd




420,000 manifests in storage on an annual basis.  This would repre-




sent approximately an 80 percent decrease in both requirements,  as




compared to the proposed regulations.  It is estimated that genera-




tors and permittees could prepare between 140,000 and 170,000 reports




on an annual basis—a reduction of over 70 percent.  The identified




generators and permittees could have to file between 140,000 and




170,000 notifications under Section 3010—a reduction of at least 60




percent.







                                 S-55

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     Air and Water Quality.   The regulations under this alternative




would have the potential to  cause fewer changes affecting the release




of air and water contaminants from the generation, transport, stor-




age, treatment, and disposal of hazardous wastes, as compared to the




proposed regulations.  The primary result would be fewer beneficial




changes in air quality and water quality.  To the extent that the




requirements under this alternative would cause fewer changes in the




economics of storage, treatment, or disposal relative to those of




proposed regulations, there  would be less of a potential for genera-




tors to make process modifications designed to further increase




hazardous waste recycling and to reduce the quantity and/or types of




hazardous wastes generated;  any such reductions in process modifica-




tions would likely lead to fewer changes in the release of air and




water contaminants by processes generating hazardous wastes.  Fur-




thermore, to the extent that fewer generators would be brought under




control of the program, the  potential for such process modifications




and resultant changes in the release of air and water contaminants




would be further decreased.




     The 16 million metric tons of potentially hazardous industrial




wastes (plus other hazardous wastes) estimated to be removed from




regulation in 1984, by this  alternative, would not have to be trans-




ported, stored, treated, or  disposed in accordance with the Section




3004 regulations.  Since most of these wastes would not likely be




transported, stored, treated, or disposed by methods that are







                                 S-56

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environmentally acceptable under the Section 3004 regulations, the




overall potential for the release of hazardous air emissions or water




effluents from the management of such additional wastes would be




increased.




     With regard to the estimated 24 million metric tons of potenti-




ally hazardous industrial wastes (plus other hazardous wastes) that




would still be regulated under this alternative in 1984, the less




stringent requirements under this alternative would have the poten-




tial for increasing the release of air contaminants from the manage-




ment of these wastes, as compared to their management under the pro-




posed regulations.  The major impact, with regard to air quality-.




would result from less stringent incineration requirements and from




allowing volatile wastes to be placed in landfills, landfarms, sur-




face impoundments, or storage tanks vented directly to the atmos-




phere.  The application of the Threshold Limit Values (TLV's) as a




time-weighted average for a 24-hour day, rather than as a time-




weighted average for an 8-hour day and a 40-hour week, would further




allow an increase in air emissions from such non-point sources as




landfills, landfarms, surface impoundments, and storage areas.  The




major impact, with regard to water quality, would result from allow-




ing higher permeabilities for soil liners for landfills and surface




impoundments.




     To the extent that fewer storage, treatment, or disposal facili-




ties would have to be modified or would have to be constructed under
                                 S-57

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this alternative,  there would be a decrease in fugitive dust, vehicu-




lar emissions,  and runoff from such construction activities.




     It should be noted, however,  that there would likely be some




shift in the types of methods used to store, treat, or dispose both




the regulated wastes and the wastes excluded from regulation under




this alternative,  compared to the  methods that would have been used




to manage these wastes under the proposed regulations.  As previously




discussed, the net result could be both localized and/or nationwide




increases in the release of many air and water contaminants from




hazardous waste management, and localized and/or nationwide decreases




in the release of other air and water contaminants relative to the




proposed regulations.  The likely  result would be increased localized




degradation of air and water quality, along with some localized




improvement in air and water quality.  All releases and any localized




degradation of air or water quality would have to be in compliance




with all applicable requirements (e.g., Clean Air Act standards,




Clean Water Act standards, OSHA standards, state standards).




     Public Health.  The regulations under this alternative would




have the potential for reducing the public health benefits to be




derived from the control of hazardous wastes.   As discussed else-




where, the regulations would increase (relative to the proposed regu-




lations) the potential for the release of air, water, and soil con-




taminants from hazardous waste management and, thus, for resultant




public health impacts.  Furthermore, since most of the wastes to be







                                S-58

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removed from regulations under this alternative would be potentially




toxic wastes, there could be a much greater potential for significant




increases in acute and chronic health effects to result from the




improper disposal of such wastes.




     S.6.3.2  Secondary Impacts.  The major changes in secondary




impacts (relative to the proposed regulations) that could occur, as a




result of implementation of this alternative, would result primarily




from the removal of approximately 16 million metric tons of hazardous




industrial wastes (plus other hazardous wastes) from regulation annu-




ally by 1984; the enactment of less stringent environmental require-




ments with regard to the transport, storage, treatment, and disposal




of hazardous wastes; and potentially lower increases in storage,




treatment, and disposal costs as a result of these less stringent




regulations.  To the extent that these changes result in increases in




the release of air, water, and soil contaminants, there would be




fewer beneficial impacts to the biological environment, soils,  water




use, land use, and special interest points, as compared to the pro-




posed regulations.




     The above changes would also provide less of an incentive for




generators to modify processes so as to enable increased recycling of




hazardous waste as process feedstocks, to reduce the quantities of




hazardous wastes generated by specific processes, or to change the




nature of wastes produced.  Energy use could, however, be decreased




by the lesser amount of facility modification and construction







                                S-59

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required under this alternative,  by less stringent requirements for




facility operation and closure,  and by any resultant decreases in




hazardous waste transport.   Changes in resource recovery could lead




to fewer changes in energy  use,  including less recovery of energy.




     Fewer industrial plant closings or relocations, due to the




reduced costs under this alternative,  could lead to fewer population




shifts and resultant impacts.   Fewer workers would also be required




to manage hazardous wastes, to construct facilities, and to adminis-




ter and enforce the regulations.   It is estimated that, under this




alternative,  at least 12,000 workers could be required nationally, by




1984, to store, treat, or dispose hazardous wastes; this would repre-




sent approximately a 40 percent  decrease in this requirement, com-




pared to the proposed regulations.  Fewer population shifts could




occur in response to the reduced  personnel requirements; any shifts




would be expected to be small on a national scale, though there could




still be localized instances of  a relatively large influx or outflux




of workers.




     It is estimated that,  under  this  alternative, there could poten-




tially be sufficient, environmentally adequate, off-site capacity to




handle all hazardous industrial  wastes sent off-site in 1980 and




1984.  Data are not available to  estimate any potential shortfalls in




environmentally adequate on-site  capacity; however, there would be




less of a potential for any shortfalls to occur.




     Less total land, off-site plus on-site, would be required for







                                 S-60

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the construction of any storage, treatment, and disposal facilities




needed under this alternative, and for such conjunctive developments




as construction of roads, power lines, and pipelines.  Less addition-




al land would be required since fewer wastes would have to be sent to




permitted facilities; the wastes removed from regulation could use




existing facilities or other facilities that were not adequate under




the proposed regulations.  However, while less total land would be




required under this alternative, in the case of 13 percent off-site




shipment, there could be more off-site land use and less on-site land




use by 1984, compared to the proposed regulations.  In the case of 25




percent off-site shipment, there could be less off-site land use and




more on-site land use by 1984, compared to the proposed regulations.




     Existing land uses would not change on lands excluded from




hazardous waste management under this alternative; however, there




could be localized changes in land use from any additional shifts to




off-site management from on-site management, or to on-site management




from off-site management, as discussed above.  There would be fewer




disruptions of ecological communities as a result of the lesser land




disturbances.




     The construction and operation of fewer facilities, especially




off-site facilities, would cause fewer aesthetic impacts and could




result in fewer instances of localized noise impacts.  While public




opposition to the siting and construction of hazardous waste manage-




ment facilities could be reduced by the need for fewer facilities







                                S-61

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under this alternative,  any opposition that occurs could be exacer-




bated by the less stringent requirements under this alternative.
                               S-62

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1.0  INTRODUCTION

     This document is a draft Environmental Impact Statement (EIS)

addressing the potential effects of implementing proposed regulations

under Subtitle C of the Resource Conservation and Recovery Act of

1976 (RCRA).  Specifically, the proposed regulations addressed in

this document are being developed as Part 250, Hazardous Waste

Guidelines and Regulations, under Title 40.  Subparts form the basis

of the regulatory action to be assessed.  The Subparts are as

follows:

     •  Subpart A — Identification and listing of hazardous waste
             (Section 3001);

     •  Subpart B — Standards applicable to generators of hazardous
             waste (Section 3002);

     •  Subpart C — Standards applicable to transporters of
             hazardous waste (Section 3003);

     •  Subpart D — Standards applicable to owners and operators of
             hazardous waste treatment, storage, and disposal
             facilities (Section 3004);

     •  Subpart E — Permit system for treatment, storage, and dispo-
             sal of hazardous wastes (Section 3005);

     •  Subpart F — Guidelines for state hazardous waste programs
             (Section 3006);

     •  Subpart G — Preliminary notification of hazardous waste
             activities (Section 3010).

In addition to these major regulatory Subparts, the Environmental

Protection Agency (EPA) has responded to the mandate of all other

Sections  of Subtitle C, namely:

     •  Section 3007 — Inspections;

     •  Section 3008 — Federal enforcement;
                                 1-1

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     •  Section 3009 — Retention of state authority;

     •  Section 3011 — Authorization of assistance to the states.

     A summary of the major aspects of these regulations is presented

in Chapter 3 of this document,  and detailed descriptions of each of

the regulatory Subparts form the basis of Appendix B.   However, it

should be noted that the development of regulations is a dynamic,

changing process and that specific details of these regulations may

be expected to change both before and after promulgation. In the

event of major changes to the regulations presented herein, and/or in

the event of additional regulations affecting large volume special

wastes (i.e., cement kiln dusts, utility wastes,  oil drilling

muds/brines, phospate rock mining and processing  wastes, uranium

mining/milling wastes, and other mining wastes) a supplemental En-

vironmental Impact Statement would be prepared.

     The scope of this draft EIS includes all hazardous wastes within

the definition of Subpart A (see Appendix B). However^ the proposed

regulations, and thus the EIS,  do not address those wastes excluded

by the Act or by Congressional  intent, namely:

     •  Solid or dissolved material in domestic sewage;

     •  Solid or dissolved material in irrigation return flows;

     •  Industrial discharges which are point discharges subject to
        permits under section 402 of the Federal  Water Pollution
        Control Act, as amended (86 Stat. 880);
                                1-2

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•  Source, special nuclear,  or by-product material as defined by
   the Atomic Energy Act of  1954,  as  amended (68 Stat. 923);

•  Household wastes.
                            1-3

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2.0  LEGISLATIVE BACKGROUND

2.1  Federal Legislation Leading to RCRA

     The first Federal legislation relating to solid waste disposal

was the Refuse Act comprising Section 13 of the River and Harbor Act

of 1899 (30 Stat. 1152).  This Act states that:

          ...it shall not be lawful to throw, discharge, or deposit,
          or cause, suffer or procure to be thrown, discharged, or
          deposited either from or out of any ship, barge, or other
          floating craft of any kind, or from the shore, wharf, manu-
          facturing establishment, or mill of any kind, any refuse
          matter of any kind or description whatever other than that
          flowing from streets and sewers and passing therefrom in a
          liquid state, into any tributary of any navigable water
          from which the same shall float or be washed into such nav-
          igable water; and it shall not be lawful to deposit, or
          cause, suffer, or procure to be deposited material of any
          kind in any place on the bank of any navigable water, or on
          the bank of any tributary of any navigable water, where the
          same shall be liable to be washed into such navigable
          water, either by ordinary or high tides, or by storms or
          floods, or otherwise, whereby navigation shall or may be
          impeded or obstructed:  Provided, that nothing herein con-
          tained shall extend to, apply to, or prohibit the opera-
          tions in connection with the improvement of navigable
          waters or construction of public works, considered neces-
          sary and proper by the United States officers supervising
          such improvement or public work:  and provided further,
          that the Secretary of War, whenever in the judgment of the
          Chief of Engineers anchorage and navigation will not be
          injured thereby, may permit the deposit of any material
          above mentioned in navigable waters, within limits to be
          defined and under conditions to be prescribed by him, pro-
          vided application is made to him prior to depositing such
          material; and whenever any permit is so granted the condi-
          tions thereof shall be strictly complied with, and any
          violation thereof shall be unlawful.

Although the original intent of this Act was to prevent obstructions

to navigation, it did represent the first Federal regulation of open

dumping and is still in effect.
                                 2-1

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     The Solid Waste Disposal Act,  passed in 1965, was the first Act




of Congress dealing directly with the solid waste problem and was




primarily aimed at establishing a national research and development




program for new and improved methods of proper and economic disposal




of solid waste.  It authorized the Secretary of Health, Education and




Welfare to make grants to state and interstate agencies to conduct




surveys of solid waste disposal practices and associated problems.




     In 1970, the Solid Waste Disposal Act was amended by the Re-




source Recovery Act, which shifted its objectives to include the pro-




motion of resource recovery programs and added provisions for grants




to these programs.  It also required the Secretary of Health, Educa-




tion and Welfare to submit to Congress a report on the feasibility of




a system of national disposal sites for the storage and disposal of




hazardous wastes.  That report (Office of Solid Waste Management Pro-




grams, 1974c) was an important step in dealing with the problems of




hazardous waste management.  The Solid Waste Disposal Act has since




expired.




     The Environmental Protection Agency proposed the Hazardous Waste




Management Act (S.1086) early in 1973.  Although never enacted, this




Bill led directly to the Resource Conservation and Recovery Act of




1976 (RCRA).  There are several important differences between these




two pieces of legislation.  The objectives of the Hazardous Waste




Management Act included Federal regulation of certain hazardous




wastes and Federal guidelines for state regulation of others, while






                                 2-2

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RCRA aims to provide Federal assistance to state and  local  solid

waste management programs, thus giving the states more authority and

placing the Environmental Protection Agency in an advisory  capacity.

     The definition of hazardous waste in the Hazardous Waste Manage-

ment Act was:

          Any waste or combination of wastes which pose a substantial
          present or potential hazard to human health or living
          organisms because such wastes are nondegradable or persis-
          tent in nature or because they can be biologically mag-
          nified, or because they can be lethal, or because they may
          otherwise cause or tend to cause detrimental cumulative ef-
          fects.

In the RCRA the definition was expanded to:

          A solid waste, or combination of solid wastes,  which be-
          cause of its quantity, concentration, or physical, chemical
          or infectious characteristics may cause,  or significantly
          contribute to an increase in mortality or an increase in
          serious irreversible, or incapacitating reversible,  il-
          lness; or pose a substantial present or potential hazard to
          human health or the environment when improperly treated,
          stored, transported, or disposed of, or otherwise managed.

Other changes involve the definition of storage, treatment, and dis-

posal.  Under the Hazardous Waste Management Act, storage for more

than two years is considered disposal.  Under RCRA, storage may be

either temporary or for a period of years, but is not to constitute

disposal.  The definition of treatment was altered considerably from

"any activity or processing designed to change the physical form or

chemical composition of waste so as to render such materials non-

hazardous" in the Hazardous Waste Management Act to RCRA's "any

method,  technique,  or process,  including neutralization,  designed to

change the physical,  chemical,  or biological character or composition

                                 2-3

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of any hazardous waste so as to neutralize such waste or so as to

render waste non-hazardous,  safer for transport, amenable for recov-

ery, amenable for storage,  or reduced in volume."  Under the Hazar-

dous Waste Management Act,  disposal refers only to land disposal,

while RCRA considers disposal into or on any land or water3 including

groundwaters.  RCRA also deals individually with generators, trans-

porters, treaters, storers,  and disposers of hazardous wastes, where-

as the Hazardous Waste Management Act considered them all together.

     On October 21, 1976, the Resource Conservation and Recovery Act

of 1976 (Public Law 94-580)  was signed by the President and became

law.

2.2  RCRA and Subtitle C

     RCRA has as its objectives the protection of health and the en-

vironment and the conservation of valuable material and energy re-

sources.  These objectives are to be met by:

     •  Providing technical and financial assistance to state and lo-
        cal governments and interstate agencies for the development
        of solid waste management plans (including resource recovery
        and resource conservation systems) which will promote im-
        proved  solid waste management techniques (including more
        effective organizational arrangements), new and improved
        methods of collection, separation, and recovery of solid
        waste,  and the environmentally safe disposal of nonrecover-
        able residues;

     •  Providing training grants in occupations involving the de-
        sign, operation, and maintenance of solid waste disposal sys-
        tems ;

     •  Prohibiting future open dumping on the  land and requiring the
        conversion of existing open dumps to facilities which do not
        pose a  danger to the environment or to health;
                                  2-4

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     •  Regulating the treatment,  storage,  transportation, and dis-
        posal of hazardous wastes  which have adverse effects on
        health and the environment;

     •  Providing for the promulgation of guidelines for solid waste
        collection,  transport, separation,  recovery, and disposal
        practices and systems;

     •  Promoting a  national research and development program for
        improved solid waste management and resource conservation
        techniques,  more effective organizational arrangements, and
        new and improved methods of  collection,  separation,  and re-
        covery, and  recycling of solid wastes and environmentally
        safe disposal of nonrecoverable residues;

     •  Promoting the demonstration, construction,  and application of
        solid waste  management, resource recovery and resource con-
        servation systems which preserve and enhance the quality of
        air, water,  and land resources;

     •  Establishing a cooperative effort among the Federal, state,
        and local governments and  private enterprise in order to re-
        cover valuable materials and energy from solid waste.

     In addressing these objectives, Title II of RCRA, the Solid

Waste Disposal Act (the Act), is divided into eight subtitles:

     •  Subtitle A - General Provisions

     •  Subtitle B - Office of Solid Waste; Authorities of the
                     Administrator

     •  Subtitle C - Hazardous Waste Management

     •  Subtitle D - State or Regional Solid Waste Plans

     •  Subtitle E - Duties of the Secretary of Commerce in Resource
                     and Recovery

     •  Subtitle F - Federal Responsibilities

     •  Subtitle G - Miscellaneous Provisions

     •  Subtitle H - Research, Development, Demonstration, and
                     Information
                                 2-5

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     Subtitle C of the Solid Waste Disposal Act calls for regulatory

action and guidelines  within 11  separate categories  as follows:

     •  Section 3001 - Identification and Listing of Hazardous Waste

     •  Section 3002 - Standards  Applicable to Generators of Hazard-
                       ous  Wastes

     •  Section 3003 - Standards  Applicable to Transporters of
                       Hazardous  Wastes

     •  Section 3004 - Standards  Applicable to Owners and Operators
                       of Hazardous Waste Treatment,  Storage and Dis-
                       posal Facilities

     •  Section 3005 - Permits  for Treatment,  Storage or Disposal of
                       Hazardous  Waste

     *  Section 3006 - Authorized State  Hazardous Waste Programs

     •  Section 3007 - Inspections

     •  Section 3008 - Federal Enforcement

     •  Section 3009 - Retention  of State Authority

     •  Section 3010 - Effective  Date

     •  Section 3011 - Authorization of  Assistance to States

     2.2.1  Definitions Relevant  to Subtitle C.  Several definitions

listed in Section 1004 of the Act are particularly important to an

understanding of the scope  of Subtitle C and the mandate of each of

the Sections 3001 through 3011.   These definitions,  not detailed

elsewhere in the regulations, are:

     •  Disposal—the  discharge,  deposit, injection,  dumping,  spil-
        ling, leaking, or placing of any solid waste or hazardous
        waste into or  on any land or water so that such solid  waste
        or hazardous waste  or any constituent thereof may enter the
        environment or be emitted into the air or discharged into any
        waters, including groundwaters.
                                 2-6

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•  Hazardous waste—solid waste, or combination of solid wastes,
   which because of its quantity, concentration, or physical,
   chemical, or infectious characteristics may:

   (1)  Cause, or significantly contribute to, an increase in
        mortality or an increase in serious irreversible, or
        incapacitating reversible, illness; or

   (2)  Pose a substantial present or potential hazard to human
        health or the environment when improperly treated,
        stored, transported, or disposed of, or otherwise man-
        aged.

•  Hazardous Waste Generation—the act or process of producing
   hazardous waste.

•  Hazardous Waste Management—the systematic control of the
   collection, source separation, storage, transportation,
   processing, treatment, recovery, and disposal of hazardous
   wastes.

•  Resource Recovery—the recovery of materials or energy
   from solid waste.

•  Solid Waste—any garbage, refuse,  sludge from a waste treat-
   ment plant, water supply treatment plant, or air pollution
   control facility and other discarded material, including
   solid, liquid, semisolid, or contained gaseous material re-
   sulting from industrial, commercial, mining, and agricultural
   operations, and from community activities but does not
   include solid or dissolved material in domestic sewage or
   solid or dissolved materials in irrigation return flows or
   industrial discharges which are point sources subject to
   permits under Section 402 of the Federal Water Pollution Con-
   trol Act, as amended (86 Stat. 880), or source, special
   nuclear, or byproduct material as  defined by the Atomic En-
   ergy Act of 1954, as amended (68 Stat. 923).

•  Storage—the containment of hazardous waste, either on a tem-
   porary basis or for a period of years, in such a manner as
   not to constitute disposal of such hazardous waste.

•  Treatment—any method, technique,  or process, including neu-
   tralization, designed to change the physical, chemical, or
   biological character or composition of any hazardous waste
   so as to neutralize such waste or  so as to render such
   wastes nonhazardous, safer for transport, amenable for re-
   covery, amenable for storage, or reduced in volume.

                            2-7

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     2.2.2  Section 3001  of Subtitle C.   Section 3001 of Subtitle C,

Identification and Listing of Hazardous  Waste,  requires:

     •   The development  and promulgation of  criteria for identify-
         ing the characteristics  of hazardous waste and for listing
         hazardous waste,  taking  into account toxicity, persistence,
         degradability in nature,  potential  for accumulation in tis-
         sue,  flammability, corrosiveness, and  other hazardous
         characteristics;

     •   The promulgation of regulations identifying the character-
         istics of hazardous waste and listing  particular hazardous
         wastes which are subject  to the provisions of Subtitle C,
         based on the above criteria;

     •   The ability of the Governor of  any  state to petition the
         Administrator of the Environmental  Protection Agency to
         identify or list  a material as  a hazardous waste.

     2.2.3  Section 3002  of Subtitle C.   Section 3002 requires  the

promulgation of regulations establishing standards  applicable to

generators of hazardous waste.  These standards must establish

requirements respecting:

     •   Recordkeeping practices  that accurately identify the
         quantities of such hazardous waste  generated,  the con-
         stituents thereof which  are significant in quantity or in
         potential harm to human  health  or the  environment,  and the
         disposition of such wastes;

     •   Labeling practices for any containers  used for the  storage,
         transport or disposal of  such hazardous waste such  as  will
         identify accurately such  waste;

     •   Use of appropriate containers for such hazardous waste;

     •   Furnishing of information on the general chemical compo-
         sition of such hazardous  waste  to persons  transporting,
         treating, storing, or disposing of  such wastes;

     •   Use of a manifest system  to assure  that all such hazardous
         waste generated  is designated for treatment,  storage,  or
         disposal in treatment, storage,  or  disposal facilities
                                 2-8

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        (other than facilities on the premises where the waste is
        generated) for which a permit has been issued as provided
        in this subtitle;

     •  Submission of reports setting out:

        (1)  The quantities of hazardous waste identified or listed
             under this subtitle that have been generated during a
             particular time period;

        (2)  The disposition of all hazardous waste reported
             above.

     2.2.4  Section 3003 of Subtitle C.  Section 3003 requires the

promulgation of standards applicable to transporters of hazardous

waste.  These standards must include, but need not be limited to,

requirements respecting:

     •  Recordkeeping concerning such hazardous waste transported,
        and their source and delivery points;

     •  Transportation of such waste only if properly labeled;

     •  Compliance with the manifest system referred to in Section
        3002;

     •  Transportation of all such hazardous waste only to the
        hazardous waste treatment, storage, or disposal facilities
        which the shipper designates on the manifest form to be a
        facility holding a permit issued under this subtitle.

These standards must be coordinated with regulations of the Secretary

of Transportation regarding the transport of hazardous wastes that

are subject to the Hazardous Materials Transportation Act (88 Stat.

2156; 49 U.S.C. 1801 and following).

     2.2.5  Section 3004 of Subtitle C.  Section 3004 requires the

establishment of such performance standards, applicable to owners and

operators of facilities for the treatment, storage, or disposal of
                                 2-9

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hazardous waste identified or listed under Subtitle C, as may be

necessary to protect human health and the environment.  These

standards must include, but are not necessarily limited to,

requirements respecting:

     •  Maintaining records of all hazardous wastes identified or
        listed under this title which are treated, stored, or dis-
        posed of, and the manner in which such wastes were treated,
        stored, or disposed of;

     •  Satisfactory reporting, monitoring, and inspection and com-
        pliance with the manifest system referred to in Section
        3002;

     •  Treatment, storage, or disposal of all such waste received
        by the facility pursuant to such operating methods, tech-
        niques and practices as may be satisfactory to the
        Administrator;

     •  The location, design, and construction of such hazardous
        waste treatment, disposal, or storage facilities;

     •  Contingency plans for effective action to minimize unan-
        ticipated damage from any treatment, storage, or disposal
        of any such hazardous waste;

     •  The maintenance and operation of such facilities and re-
        quiring such additional qualification as to ownership, con-
        tinuity of operation, training for personnel and financial
        responsibility as may be necessary or desirable;

     •  Compliance with the requirements of Section 3005 respecting
        permits for treatment, storage, or disposal.

     2.2.6  Section 3005 of Subtitle C.  Section 3005 of Subtitle C

which deals with permits for the treatment, storage, or disposal of

hazardous waste requires:

     •  The promulgation of regulations requiring each person own-
        ing or operating a facility for the treatment, storage, or
        disposal of hazardous waste to have a permit; and

     •  The promulgation of regulations requiring certain infor-
        mation to be contained in permit applications, including:
                                  2-10

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       (1)  Estimates with respect to the composition, quantities,
            and concentrations of any hazardous waste identified
            or listed under Subtitle C, or combinations of any
            such hazardous waste and any other solid waste,
            proposed to be disposed of, treated, transported, or
            stored, and the time, frequency, or rate of which such
            waste is proposed to be disposed of, treated,  trans-
            ported, or stored; and

       (2)  The site at which such hazardous waste or the  products
            of treatment of such hazardous waste will be disposed
            of, treated, transported to, or stored.

Section 3005 also discusses permit issuance, permit revocation, and

interim status for persons who have filed applications for permits

for existing facilities.

     2.2.7  Section 3006 of Subtitle C.  Section 3006 pertains to the

authorization of state hazardous waste programs.  It requires the

promulgation of guidelines to assist states in the development of

such programs.  Procedures are given for any state to apply for

authorization of its hazardous waste program and provides  for interim

authorization of state programs which exist before the date 90 days

after the date required for promulgation of regulations under

Sections 3002, 3003, 3004, and 3005.  Any action taken by  a state

under an authorized program is given the same force and effect as

action taken by the EPA Administrator under Subtitle C.  Procedures

are also established for withdrawal of authorization by the

Administrator.

     2.2.8  Section 3007 of Subtitle C.  Section 3007 requires any

person who generates, stores, treats, transports, disposes, or

otherwise handles hazardous wastes to allow access to records

                                  2-11

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relating to these wastes to any officer or employee of the Environ-

mental Protection Agency designated by the Administrator or any duly

designated officer or employee of a state having an authorized

hazardous waste program.  Such officers or employees are authorized:

     •  To enter at reasonable times any establishment or other
        place maintained by any person where hazardous wastes are
        generated, stored, treated, or disposed;

     •  To inspect and obtain samples from any person of any such
        wastes and samples of any containers or labeling for such
        wastes.

Procedures are given for conducting such inspections.  In addition,

provisions are made for the public to obtain records, reports, or

information.

     2.2.9  Section 3008 of Subtitle C.  Section 3008 deals with

Federal enforcement of Subtitle C. Procedures are given for the

issuance of a compliance order and the commencement of a civil action

in  the  event  the Administrator determines that any person is in

violation of  any requirement of Subtitle C.  A public hearing may be

requested by  the person or persons named in the order or permit

revocation.   Any compliance order  shall specify the nature of the

violation and a  time limit for compliance.  Provision is made for

criminal penalties for violations  of Subtitle C.

     2.2.10   Section 3009 of Subtitle C.  Under Section 3009,

Retention of  State Authority, no state may  impose any requirements

less stringent than those authorized under  Subtitle C, except that  if
                                  2-12

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application of a regulation under Subtitle C is postponed or enjoined




by the action of any court, a state may not be prohibited from acting




on the matter until the regulation takes effect.




     2.2.11  Section 3010 of Subtitle C.  Section 3010 requires any




person generating or transporting hazardous wastes or owning or




operating any facility for treatment, storage, or disposal of hazar-




dous wastes to file a notification with the Administrator within 90




days of the promulgation or revision of regulations under Section




3001 identifying or listing such wastes as hazardous.  The regula-




tions under Subtitle C respecting requirements applicable to the




generation, transportation, treatment, storage, or disposal of




hazardous waste shall take effect six months after their date of




promulgation.




     2.2.12  Section 3011 of Subtitle C.  Section 3011 authorizes to




be appropriated $25 million for fiscal years 1978 and 1979 "to be




used to make grants to the States for purposes of assisting the




States in the development and implementation of authorized state




hazardous waste programs," and provides for the allocation of the




amounts authorized to be appropriated.




2.3  Related Federal Legislation




     A number of other Federal Acts are specifically addressed within




RCRA.  Section 1006 of RCRA states that "nothing in this Act shall be




construed to apply to...any activity or substance which is subject




to the Federal Water Pollution Control Act (33 U.S.C. 1151 and
                                 2-13

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following),  the Safe Drinking Water Act (42 U.S.C.  300f and follow-

ing), the Marine Protection,  Research and Sanctuaries Act  of 1972 (33

U.S.C. 1401  and following),  or the Atomic Energy Act of 1954 (42

U.S.C. and following),  except to the extent that such application...

is not inconsistent with the requirements of such Acts."

     The Federal Water  Pollution Control Act contains several sec-

tions which apply directly to the handling and disposal of hazardous

wastes.

     •  Section 301, dealing with effluent limitations, prohibits the
        "discharge of any radiological, chemical, or biological
        warfare agent or high-level radioactive waste into the
        navigable waters."

     •  Section 304(f)  requires EPA to publish guidelines  for the
        pretreatment of pollutants which are determined not to be
        susceptible to  treatment by publicly-owned treatment works.
        In accordance with the Clean Water Act of 1977, EPA is also
        directed to regulate the control of plant site runoff, spil-
        lage or leaks,  sludge or waste disposal, and drainage from
        raw material storage which are associated with the industrial
        manufacturing or treatment process of the designated
        industries, which may contribute significant amounts of pol-
        lutants to navigable waters.

     •  Section 306 deals with new source performance standards for
        industrial point sources.  EPA is authorized to determine the
        best available  demonstrated control technology, and require
        its installation for specified categories of sources.  If EPA
        determines that a zero-discharge standard is practicable,
        such a standard may be set.

     •  Under Section 307, the Administrator is directed to publish a
        list of toxic pollutants and effluent limitations.  These
        limitations may constitute an absolute prohibition against
        discharging.  Additionally, EPA must publish pretreatment
        standards requiring any industry discharging into  a municipal
        sewage treatment plant to pretreat its effluent so that it
        does not interfere with the operation of the plant or pass
        through the plant untreated or without adequate treatment.


                                 2-14

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     •  Section 311 is designed to protect the navigable waters and
        shorelines from "hazardous substance" discharges.

     •  Under Section 402, each state government is responsible for
        issuing permits under the National Pollutant Discharge
        Elimination System.  While EPA issues guidelines for state
        permit programs, it retains the right to review a state-
        issued permit affecting another state's water resources.

     •  Section 405 requires that a permit be issued by EPA for the
        disposal or relocation of sewage sludge that could affect the
        navigable waters.  Such disposal is prohibited without a
        permit.

     •  Under Section 504, the EPA Administrator may bring suit
        against any person contributing to a pollution source causing
        an imminent and substantial endangerment to public health or
        welfare.  In accordance with the 1977 amendments, EPA is also
        authorized to provide assistance in emergencies which may
        present an imminent and substantial danger to public health
        on welfare.  EPA may authorize emergency assistance "to prev-
        ent, limit, or mitigate the emergency; when "there is an im-
        mediate significant risk to public health or welfare and the
        environment;" and when "such assistance will not otherwise be
        provided on a timely basis."

     The Safe Drinking Water Act of 1974 authorizes EPA to regulate

underground injection of wastes (and other substances) to protect

underground sources of drinking water.  It also authorizes the EPA

Administrator to conduct a study of the impacts on underground water

supplies of surface water disposal of wastes.

     The Marine Protection, Research, and Sanctuaries Act of 1972

prohibits the marine transport and disposal into U.S. territorial

waters of any radiological, chemical, or biological warfare agents,

high level radioactive wastes, or any other material, except as

authorized by Federal permit.  In the granting of permits for ocean

dumping, EPA must consider "appropriate locations and methods of
                                  2-15

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disposal or recycling,  including land-based alternatives, and the




associated impacts of such actions.




     The Atomic Energy Act of 1954, as amended, authorizes both the




Atomic Energy Commission and private industry to regulate the




disposal of byproduct,  source, or special nuclear materials.




     In addition to the four acts specifically referred to in Section




1006 of RCRA, several other Federal acts affect the management of




hazardous wastes.  Selected acts are summarized below.




     The Toxic Substances Control Act of 1976 authorizes the regula-




tion of hazardous substances before they become wastes.  EPA is




authorized to require that data be developed by manufacturers con-




cerning the effects of chemical substances and mixtures on health and




the environment when EPA feels that such chemicals present an unrea-




sonable risk of injury to health or to the environment.  EPA may also




issue an order prohibiting or limiting the manufacture, processing,




distribution, or disposal of specified substances.




     The Clean Air Act of 1970 (Section 112) and its amendments




authorize the EPA to set standards for hazardous air pollutants at




any level which provides an ample margin of safety to protect public




health.  In accordance with the 1977 amendments, the Administrator




may instead promulgate design or equipment standards to protect




public health with an ample margin of safety.  The control strategy




of standards and/or design plans is meant to protect the public
                                 2-16

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health and welfare by placing the burden of standards compliance on

the air polluter.

     The Occupational Safety and Health Act of 1970 is designed to

protect workers from occupational hazards, including hazards

associated with contact of hazardous materials.  Section 6(b)(5)

deals specifically with toxic materials, requiring the Secretary of

Labor to "set the standard which most adequately assures...that no

employee will suffer material impairment of health or financial

capacity" from regular exposure to such hazards.

     The Federal Insecticide, Fungicide, and Rodenticide Act, as

amended by the Federal Environmental Pesticide Control Act of 1972,

requires EPA to establish procedures and regulations for the disposal

or storage of packages, containers, and excess amounts of pesticides

and to accept at convenient locations for safe disposal, those

pesticides whose registration has been cancelled or suspended.

     Under the authority of the Hazardous Materials Transportation

Act of 1974, the Department of Transportation promulgated regulations

listing hazardous materials and specifying procedures to be followed

when transporting those materials.  Furthermore, the responsibility

for documentation, prevention, and containment of spills of oil and

hazardous materials is divided between the Department of Transporta-

tion (including the U.S. Coast Guard) and the Environmental Protec-

tion Agency under the Hazardous Materials Transportation Act of 1974

and the Federal Water Pollution Control Act as amended by the Clean

Water Act of 1977.
                                 2-17

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     The Armed Forces Appropriating Authorizations of 1971 prohibits

the disposal of any chemical or biological warfare agent "within or

outside the United States unless such agent has been detoxified or

made harmless to man and his environment unless immediate disposal is

clearly necessary, to safeguard human life."

2.4  The Status of State Solid Waste and Hazardous Waste
     Legislation

     Every state has addressed the hazardous waste problem to at

least a limited degree,  with the level of state control over hazar-

dous waste presently ranging from essentially none to full and

comprehensive programs.   The majority of states exercise their

legislative authority over hazardous wastes under their existing

solid waste legislation, with authority extended under broadly-

worded provisions that do not contain guidelines, criteria, or

regulations specifically dealing with hazardous waste.  As a result,

enforcement and management are largely a matter of individual inter-

pretation by state regulatory authorities, with most states exer-

cising their legislative authority on a case-by-case basis.  In some

states, the principal regulatory control of hazardous wastes is

divided between two agencies.

     Table 2-1 presents  a summary of the extent of authority and

control currently exercised by each state and U.S. territory, and the

principal regulatory agency responsible for control within each state

and territory.  In accordance with the Solid Waste Disposal Act, all
                                 2-18

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                                      TABLE  2-1
                    STATE REGULATION  AND  CONTROL AUTHORITY*
STATES
Alabama
Alaska
Arkansas
California
Colorado
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Mississippi
Missouri
Montana
Nebraska
Nevada
Hew Jersey
Sew Mexico
New York
-North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Virginia
Washington
West Virginia
Wisconsin
Wyoming

Guam
Samoa
Pacific Islands
Puerto Rico
Virgin Islands

AGENCY




Dept. of Public Health
Dept. of Health

P

Dept. of Nat. Resources

P
8 y




Dept of Environ Protection
Uater Resources s Environ. Health Ad.in.


Board of Health
Dept. of Nat. Resources
Dept. of Environ. Control
n™t . of Health 4 Welfare
Environmental Improvement Agency
Dept. of Human Resources
Dept. of Health
Dept. of Health
p Q y
Dept. of Health
Dept. of Health & Environ. Control
Dept. of Environ. Protection
P
Dept. of Health
Dept. of Health
Dept. of Nat. Resources; Dept. of Health
Dept. of Water Quality

Environmental Quality Commission
Environmental Quality Board
Dept. of Public Works
SOLID WASTE
LEGISLATION
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
Y
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
11
1969
1973
1971
1971
1972
1971
1971
1974
1967
1974
1972
1972
1970
1970
196}
1971
1971
1950
1973
1970
1969
1965
1970
1974
1973
1969
1971
1971
1 Q71
1970
1974
1972
1969
1975
1967
1971
1969
1968
1963
1972
197?
1971
1969
1974
1967
1971
1971
1973
1967
1973
1978
1976
DATE OK LATEST
AMENDMENT
1972
1973
1977
1977
1977
1975
1971
1976
1974
1976
1974
1973
1975
1977
1966
1975
1973
1973
1973
1976
1976
1977
1976
1977
1Q7?
1977
1977
1976
1976
1976
1978
1977
1977
1977
1973
1974
1977
1977
1976
1977
1974
1976
1974
1973
1975

HAZARDOUS, SPECIAL OR
INDUSTRIAL WASTE LEGISLATION
X
X

X
X
X
X
X
K
X
X
X
A
X
X

IATE OF
ENACTMENT
1978
1973

1977
1976
1977
1976
1977
1976
1976
1978
1978
1977
1976

PROPOSED LEGISLATION
(BILL OR AHEiJDHEND

X
X
X
X
X
X
X
X
X
X


X
HAZARDOUS WASTE RECULA 1 IONS
OR GUIDELINES
proposed
proposed
X

X
X
X
X
X
proposed
X
X
X
X
X
X
X
X
X
X

HAZARDOUS WASTE c c w
DEFINITION £ 3 % o
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A
X
X
X
A
X
X
X
A
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
A
X
X
1J ..'AS
LATIO.f
11AZAR
E PROV
a
ee £
Q
X
X
X
X
X
X
X
X
X
K
X


X
X
! ADDRESSED AS A J2 8 "'
SEPARATE SECT I CM § ""
\
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
HAZARDOUS WASTE
SURVEY -COMPLETED

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

v-, °
II
X
X

X
X
X
X

X
X

* Bureau of National Affairs, Inc., 1977.
A Garretaon et al., 1978
                                          2-19

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states currently have laws regulating the management of solid wastes.




Even if no additional legislative action has been enacted within a




particular state, the management of hazardous wastes could be regula-




ted, to some extent,  under this existing solid waste legislation.




However, the effective regulation of hazardous wastes requires the




application of significantly different management standards than does




the regulation of conventional solid waste.   Furthermore, solid waste




legislation must often be interpreted broadly to be effectively




extended to the control of hazardous waste.   Also,  while various




aspects of hazardous  waste management could  be exercised under




existing authority, few designated regulatory agencies currently have




the resources or manpower necessary to run an adequate hazardous




waste program.




     Enabling solid waste legislation is often derived from early




state environmental control laws in which the management of solid




waste was first addressed.  As indicated in Table 2-1, specific solid




waste laws may date back many years, with updated versions presented




as amendments.  Many of the more recent amendments  specifically




address hazardous wastes, or mention hazardous wastes along with




solid wastes.  Almost every state so far has found  it necessary to




amend their current solid waste legislation at least once to meet the




increased need for more control.  Each state and territory now has at




least one principal regulatory agency that has the enabling authority




to control hazardous  wastes.  State authority to regulate hazardous







                                 2-20

-------
waste is difficult to compare from one state to another because the




individual interpretation of exercised authority varies widely.




     Fifteen states have passed separate and specific laws govern-




ing the management of hazardous wastes.  In these cases, authority is




clearly distinguished and hazardous wastes are defined for control




purposes.  Although the comprehensiveness of these laws varies among




states, management plans and approaches generally follow the require-




ments given in RCRA.  In addition to these 15 states, another 10




states and one territory have proposed legislation that is presently




pending approval of state legislatures.  These proposed laws have




been presented either as a bill, separate from any authority de-




signated under a state's existing solid waste legislation, or have




been presented as an amendment specifically governing hazardous




wastes under a state's existing solid waste legislation.  The re-




maining states use existing solid waste legislation to govern hazard-




ous wastes.




     Most states do not have specific regulations or guidelines for




hazardous waste management.  In those that do, the strength of




promulgated regulations may be a matter of the interpretation given




by the particular state.  Regulations may take, the form of an amend-




ment to the existing solid or hazardous waste legislation, or may be




a separate document generated and used by the principal state re-




gulatory agency.  In some states, the existing regulations may




clearly distinguish between the designated levels of authority over







                                 2-21

-------
hazardous wastes,  with specific criteria and procedures described,




while in other states the regulations may limit the scope of




authority to a particular hazardous waste category, such as pesticide




disposal.  As shown in Table 2-1,  16 states have promulgated specific




regulations or guidelines for the  management of hazardous wastes, and




an additional four states have proposed such regulations.  No attempt




has been made to compare the equivalency of these regulations.




     As indicated in Table 2-1, all but two of the states have addres-




sed the identification of hazardous waste in the definition section




of their general solid waste legislation or within a particular




section of the solid waste legislation.  The other two states have




defined hazardous wastes under separate hazardous waste legislation




that has been proposed or passed.




     Collectively, at least 37 states and two territories have thus




far addressed hazardous waste to a limited extent within their




existing solid waste regulations.   As illustrated in Table 2-1,




hazardous wastes may be either addressed "in part" for the regulation




of a particular activity, such as  disposal procedures, or may be




specifically addressed as a separate section within the general solid




waste regulations.  When regulated under the authority of existing




solid waste laws, the management of hazardous wastes is usually




handled on a case-by-case basis, with little systematic control on




the various levels of hazardous waste management, particularly for




on-site activities.
                                 2-22

-------
      Most of the states have initiated an effort to identify the




sources of hazardous waste generation within their boundaries by the




means of a survey-  In a few cases, a survey was not necessary since




such sources were previously identified for control through the use




of state tax department listings or through industrial directories in




conjunction with a working manifest system.  As indicated in Table




2-1, at least 24 states have presently completed such a survey, and




an additional nine states have surveys in progress.  Of the remaining




states, several are planning to conduct a survey in the near future.




     Tables 2-2 through 2-7 are directed to the various aspects of




state hazardous waste management as they apply to generators, trans-




porters, treaters, storers, and disposers, respectively.  The speci-




fic control mechanisms included in the tables are some of those




included in Sections 3002 through 3004 of RCRA, addressing standards




applicable to each group involved in the hazardous waste management




process.  The tables should not be intepreted as a comparison of




equivalency but, rather, are presented to illustrate the presence and




form of the mechanisms by which hazardous wastes are currently being




managed.  In four states, proposed regulations are far enough along




the legal path to be included in these tables for discussion pur-




poses.  In many states, legislation is currently being drafted for




future consideration; however, the majority of states are waiting for




Federal regulations on hazardous wastes to be approved before issuing




their own state regulations.







                                  2-23

-------
                                   TABLE 2-2

STATE LEGISLATION  APPLICABLE TO HAZARDOUS WASTE  GENERATORS*

//

Permit

Manifest
Record -
keeping

._

-

// /////// AV/// /*&/•? /A* */^ //«#"*/
States
Alabama (proposed)
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida (proposed)
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota (proposed)
Mississippi
Missouri
Montana
Nebraska
Nevada
Hew Hampshire
New Jersey
New Mexico
New York
North Carolina (proposed)
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Virginia
Washington
West Virginia
Wisconsin

Wyoming
/



Xt

X






X


X
X


X




X
X
X



X



X
X







X






/















X



X





X




X



X
X














f

X

X




X

X

X


X



X


X

X
X
X


'X
X

X

X
X
X

X
X

X
X
X

X


X

/



X








X


X



X


X







X




X






X


X




/

X

X




X

X


X


X


X


X

X
X
X


X
X

X


X
X

X
X


X


X
X

X

/



X





X












X







X




X






X


X




/

X

X




X

X

X
X


X


X


X

X
X
X


X
X

X


X
X

X
X


X


X
X



/



X





X


X









X







X




X






X


X




I

X

X

X

X
X

X

X


X



X


X

X
X
X



X




X


X
X


X
X

X
X



/
X


X


















X







X











X


X




/


















































    •Information presented in this table was received in personal communication with repres
     from the State offices liated In Table 2-1 and the Environmental Protection Agency.

    fFor extremely hazardous waste only.
                                       2-24

-------
                                    TABLE  2-3

STATE LEGISLATION  APPLICABLE  TO  HAZARDOUS WASTE  TRANSPORTERS*
States
Alabama (proposed)
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida (proposed)
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota (proposed)
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina (proposed)
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
//,
X



X

X
X
X


X
X

X
X


X
X

x+

X
X
X



X


X
X
X
X

X
X



X






Permit





X



X


X


X




X

X







X



X
X


X











5$
X

X

X


X

X

X
X

X



X


X

X
X
X


X
X



X
X
X

X
X

X
X
X


X

X

Manifest
%




X






X
X

X



X


X







X





X


X


X



X



Record-
keeping
//////
/ 5 ° / °o


X

X

X
X
X
X


X

X



X
X

X

X
X
X


X
X




X
X

X
X


X



X

X





X

X

X





X



X
X

X



X



X




X






X



X



Reporting



X



X
X
X
X


X

X



X
X

X

X

X



X




X
X

X
X


X



X









X

X





X




X

X







X




X










X



X

X

X

X
X
X
X


X







X



X
X
X



X




X
X

X
X






X



Inspection
/




X



X


X

















X







X











'*//







































       information presented in this table was
        from the State offices listed in Tabl
       tRegistration
 received In personal communic
2-1 and the Environmental Prot
ation with rep
ection Agency.
                                                                 resentatives
                                         2-25

-------
                                TABLE 2-4

STATE LEGISLATION APPLICABLE TO HAZARDOUS  WASTE  TREATERS*

States A
Alabama (proposed)
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida (proposed)
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota (proposed)
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina (proposed)
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
//I
X

X

X

X

X
X
X
X

X


X



X
X

X

X
X
X



X
X

X
X
X


X
X



X

X



Permit
7/t




X





X





X



X


X







X



X
X









X



%
X

X

X




X
X
X

X


X



X


X


X
X



X

X

X
X
X

X
X

X
X
X

X



Manifest
/ OJ° *»




X





X


X


X



X


X







X




X






X


X



/
-------
                              TABLE  2-5
STATE LEGISLATION  APPLICABLE TO HAZARDOUS  WASTE  STOKERS*

X
States
Alabama (proposed)
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Florida (proposed)
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Michigan
Minnesota (proposed)
Mississippi
• Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
Norch Carolina (proposed)
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
///
X

X

X

X

X
X
X
X

X


X
X


X

X

X
X
X



X


X
X
X
X

X
X


X
X





Permit 1 Manifest 1 keeping 1 Reporting I Inspection
*/£//*/?// */s//*/s//*/s//
y/*




X




X





X





X







X



X
X
X





X






7/1
X

X

X



X

X

X


xt



X

X

X
X
X



X

X

X
X
X

X
X

X
X






//*




X







X






X

X







X











X


X



7/1
X

X

X



X

X

X



X


X

X

X
X
X



X




X
X

X
X


X






7&




X







X






X

X







X











X







*Y/j
X

X

X



X

X

X



X


X

X

X

X



X




X
X

X
X


X







O / ~Y
f / 3




X







X








X







X











X






//£
X

X

X

X

X
X
X

X


X



X

X

X
X
X



X




X
X

X
X


X
X





/ 7




X










X





X







X











X























































  from the State offices listed in Table 2-1 and Environmental Protection Agency.
  Applicable to off-site only
                                  2-27

-------
                          TABLE  2-6



STATE LEGISLATION APPLICABLE TO HAZARDOUS WASTE DISPOSERS*
States
Alabama (proposed)
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida (proposed)
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota (proposed)
Mississippi
Missouri
Montana
1 Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina (proposed)
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania .
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
/<
/ v 3
/•? »»
X

X

X
X
X

X
Xi
X
X
X
X

X
X
X


X
X

X

X
X
X


X
X
X
X
X
X
X
X
X
X
X
X

X
X
X

X

X
X
Permit
Manifest
f/mf//i
X



X





X


X


X



X
X

X

X





X
X


X
X
X


X


X



X



X

X

X




X
X
X

X


X



X


X


X
X


X
X

X

X
X
X

X
X

X
X
X


X

X

from the State offices listed in Table 2-1 and E
X



X





X


X


X



X


X







X




X


X



X



X



Record-
keeping

3 $/ /§ ?/ . /
'mwmw
X

X

X




X
X
X
X
X
X
X
X
X


X
X

X

X
X
X


X
X
X



X
X
X
X
X
X
X
X
X


X
X
X
X




X





X


X
X

X



X


X







X




X
X

X



X



X

X



X

X




X
X
X
X
X
X
X
X
X


X
X

X

X
X
X


X
X
X



X
X

X
X


X
X


X
X


in personal communication w
ivironmental Protection Agency




X








X
X

X



X


X







X




X
X

X



X



X






.
///+ *////
W/////
® / 3 £ / S° *, /


X

X
X
X

X
X
X
X
X
X
X
X
X
X
X

X
X

X

X
X
X


X
X
X
X
X
X
X
X
X
X
X


X
X
X

X
X

X
th representat




X





X


a






X
X

X

X

X



X




X
X

X



X
X


X



ves










































  toff-aite only.

-------
                                TABLE  2-7

                STATE APPROACH  TO  HAZARDOUS WASTE
          DEFINITION,  MONITORING,  AND  ENFORCEMENT*
I Waste Definition 1 'tonitoring 1 Enforcement
A / /.*/&/,?/&/
/ $ / 3 / 5 sf / $ $ / IS o* / £ $ /
i r? /  f /.V m / rV C / tS 'a / C-i i_ f
State
Alabama (proposed)
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of Columbia
Florida (proposed)
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina (proposed)
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
/ /



X
X











X

X


X
x


X




X




X
X


X


X

X
X
X







X











X



X
X



X




X




X



X






X



/ /
X

X

X
X
X


X



X

X
X

X

X
K
X

X
X
X


X
X
X
X

X
X
X

X
X


X
X


X
X
X

X



X





X


X


X





X







X




X


X
X


X



X
xt


/ /
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X'
X
X
X
X
X
X
X
X
X
X
X

X


X
X

X
X
X
X
X
X
X
X
X
X
X
X

X


X

X




X
X


X


X
X


X

X

X
X
X


X
X
X


X
X
X

X
X


X



X
X
X

/


















































* Information presented in this table was received in personal
 from the State offices listed in Table 2-1 and the Environmer
A West Virginia - Standards for On-Site Only.
common ica t io ns
tal Protection
with repre
Agency.
                                    2-29

-------
     The various  regulatory criteria presented in Tables 2-2 through

2-7 relate to general enabling authority or to more detailed stan-

dards or regulations.  In a relative sense, the enabling authority

provides the formal power to regulate hazardous waste activities

while standards and regulations provide specific requirements.  En-

abling authority usually indicates that the particular state has the

power to control a particular acitivity. In the absence of specific

standards or regulations, this authority may be exercised on a

case-by-case basis, or it may extend to the regulation of only a

particular management activity, such as disposal.  In examining each

of these tables, it should be remembered that the status of state

legislation is in flux and that these tables are meant to present

only a general view of the nationwide status of hazardous waste man-

agement at this time.

     Appendix A provides a description of the specific hazardous

waste management regulations for selected states as summarized in

Tables 2-2 through 2-7.  These tables illustrate the general differ-

ences in existing regulatory approaches while the information in Ap-

pendix A provides more specific detail.

     2.4.1  The Status of  State Regulatory Criteria Applicable to

Generators of Hazardous Waste.  Table 2-2 illustrates the status of

the  regulatory criteria that are applicable to generators of hazard-

ous  waste.  Fourteen  states report  that  they have, or will  soon have,

the  enabling authority to  require generators who store, treat, or

dispose hazardous wastes to be permitted.  Six of  these states have
                                 2-30

-------
(or have proposed) standards for permits.  Twenty-five states cur-




rently have (or have proposed) the enabling authority over manifest-




type requirements pertaining to generators of hazardous wastes; ten




of these states have promulgated (or have proposed) standards for




such manifests.  Twenty-three states have (or have proposed) the




enabling authority over recordkeeping requirements applicable to




generators.  Seven of these states have (or have proposed) record-




keeping standards for hazardous waste generatiors; one additional




state also has recordkeeping standards.  Twenty-three states




currently have (or have proposed) a reporting requirement applicable




to generators of hazardous waste.  Eight of these states have (or




have proposed) reporting standards that apply to these generators;




one additional state also has reporting standards.  At present,




twenty-two states have (or have proposed) the enabling authority to




inspect a generator's facility; six of these states report that they




have (or have proposed) promulgated standards for such inspection.




Even where the enabling authority to control on-site activities does




exist, enforcement often depends upon voluntary compliance.




     2.4.2  The Status of State Regulatory Criteria Applicable to




Transporters of Hazardous Waste.  Table 2-3 presents the status of




the regulatory criteria that are applicable to transporters of




hazardous waste.  Twenty-three states report that they have, or will




soon have, the enabling authority to require transporters of hazard-




ous waste to be permitted.   Ten of these states have (or have






                                 2-31

-------
proposed) standards for the permitting of hazardous waste trans-




porters.  Twenty-five states currently have (or have proposed) the




authority to initiate a manifest system applicable to such trans-




porters; eleven of these states have standards for manifests.




Twenty-three states have (or have proposed) the enabling authority




over recordkeeping requirements; twelve of these states have (or have




proposed) recordkeeping standards.  Nineteen states have (or have




proposed) the authority to require reporting requirements; while




eight of the states have (or have proposed) reporting standards.




Eighteen states have (or have proposed) the enabling authority for




inspection of transporters; five of these states have regulations or




standards for inspection.




     2.4.3  The Status of State Regulatory Criteria Applicable to




Off-site Treaters of Hazardous Waste.  Table 2-4 illustrates the




status of the regulatory criteria that are applicable to off-site




treaters of hazardous waste.  Twenty-five states report that they




have, or will soon have, the enabling authority to require such




treaters of hazardous waste to be permitted; nine of these states




have promulgated (or have proposed) permit standards.  Twenty-three




states have (or have proposed) the enabling authority to require




treaters to comply with a manifest system; ten of these states have




promulgated (or have proposed) manifest standards.  Twenty-two states




have (or have proposed) the enabling authority to regulate record-




keeping requirements; eight of these states have promulgated (or
                                 2-32

-------
have proposed) recordkeeping standards for treaters.  Twenty states




(or have proposed) the enabling authority to require reports from




hazardous waste treaters; six of these states have promulgated (or




have proposed) reporting standards for such treaters.  Twenty-four




states have (or have proposed) the enabling authority to inspect




hazardous waste treatment facilities; seven of these states have (or




have proposed) inspection standards.




     2.4.4  The Status of State Regulatory Criteria Applicable to




Off-site Storers of Hazardous Waste.  As indicated in Table 2-5,




those states that have addressed the issue of off-site hazardous




waste storage have done so mainly from the standpoint of establishing




basic enabling authority.  Twenty-five states have reported that they




have (or have proposed) the enabling authority to require permits of




hazardous waste storers; nine of these states have enacted (or have




proposed) permit standards for storage.  Twenty-one states have (or




have proposed) the enabling legislation to require compliance with




the manifest system.  Six of these states have promulgated (or have




proposed) standards for manifest compliance; one additional state




also has manifest standards.  Eighteen states have (or have proposed)




the enabling authority to require recordkeeping by the storer; six of




these states have (or have proposed) recordkeeping standards.  Seven-




teen states have (or have proposed) the enabling authority to require




reporting by storers of hazardous waste; five of these states have




(or have proposed) standards.  Twenty-three states have indicated







                                 2-33

-------
that they have (or have proposed) specified authority to inspect




hazardous waste storage facilities; five of these states (or have




proposed) have inspection standards.




    2.4.5  The Status of State Regulatory Criteria Applicable to




Off-site Disposers of Hazardous Waste.  The issue of the disposal of




hazardous waste has thus far received more legislative attention than




has any other hazardous waste management activity.  Thirty-eight




states have reported that they have (or have proposed) the legal




authority to require permits for the operation of off-site disposal




facilities receiving hazardous wastes.  Seventeen of these states




have promulgated (or have proposed) standards specifically relating




to the permitting of such facilities.  Twenty-five states have (or




have proposed) the enabling authority to require compliance with a




manifest system; twelve of these states have promulgated (or have




proposed) standards for manifest requirements.  Thirty-four states




have reported that they have (or have proposed) the authority to




require recordkeeping practices from hazardous wastes disposers;




fifteen of these states have (or have proposed) standards for the




recordkeeping requirements.  Twenty-nine states indicate that they




have (or have proposed) enabling authority to require hazardous waste




disposers to report on the materials being handled; thirteen of these




states have promulgated (or have proposed) standards for reporting.




Thirty-nine states have (or have proposed) legal capabilities to
                                 2-34

-------
inspect hazardous waste disposal sites; fifteen of these states have




(or have proposed) standards specifically relating to the inspection




requirements of disposal sites.




     2.4.6  The Status of State Hazardous Waste Definition,  Moni-




toring, and Enforcement.  Table 2-7 presents the current status of




state hazardous waste definition, monitoring practices,  and  en-




forcement capabilities.  While all of the states have a textual de-




finition of hazardous waste, several states have developed a more




specific definition of hazardous waste.  Seven states presently de-




fine hazardous waste exclusively by the use of criteria; one ad-




ditional state defines hazardous waste exclusively by a listing of




particular substances; eight additional states employ the use of both




criteria and a list.




     Both monitoring and enforcement refer to authority that is




generally exercised only over disposal activities; however,  this




authority can be extended to include other hazardous waste management




activities.  Thirty states report that they have (or have proposed)




the enabling authority to control monitoring activities  related to




hazardous wastes; tweleve of these states have promulgated (or have




proposed) standards with regard to monitoring procedures and re-




quirements.  One additional state also has such standards.




     Forty-five states have (or have proposed) some type of  enabling




enforcement capabilities over hazardous wastes; twenty-four  of these
                                 2-35

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states have (or have proposed)  enforcement standards specifically re-




lating to hazardous wastes.   In most of the states,  the enforcement




power is interpreted as an extension of the authority vested through




existing solid waste enforcement capabilities.
                                2-36

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3.0  DESCRIPTION OF THE PROPOSED ACTION

     The proposed action is the set of regulations and guidelines

currently being developed by the U.S. Environmental Protection Agency

in response to the mandate of Subtitle C of RCRA.  These regulations

and guidelines fall within several broad areas, as follows:

     •  Definition of hazardous wastes subject to regulation.

     •  Control of hazardous waste from the generator to ultimate
        disposal.

     •  Guidelines for state hazardous waste programs.

Regulations have been developed under the mandate of Sections 3001

through 3006 and 3010 of Subtitle C.  Because of the extensive nature

of the proposed regulations, a summary of the most relevant  points is

presented in the following sections.  The specific regulations being

assessed in this EIS are described in Appendix B.

3.1  Criteria, Identification, and Listing of Hazardous Waste
     (Section 3001)

     The Section 3001 regulations delimit wastes that are to be

considered hazardous and, therefore, to be brought under regulatory

control.  The regulatory approach taken is to use both identifying

characteristics and lists of hazardous wastes, industrial processes,

and sources to be brought under regulatory control.

     The characteristics used to delimit hazardous waste are as

follows:
                                  3-1

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     •  Ignitability

     •  Corrosiveness

     •  Reactivity

     •  Toxicity

     Any waste which exhibits any of these characteristics or which

is listed (see Appendix B,  Subpart A),  would be considered hazardous

and would have to be managed pursuant to the Subtitle C regulations.

The hazardous waste lists identify specific hazardous wastes (e.g.,

water-based paint wastes),  sources (e.g., various departments of

hospitals), and processes which generate hazardous wastes (e.g.,

asbestos wastes from cell diaphrams in production of chlorine); and

indicate for each listed waste or waste stream the reason for its is

inclusion (e.g., ignitable,  corrosive,  reactive, toxic).   A generator

producing a listed waste may be exempted from regulation providing

that he could demonstrate that the reason for listing that waste does

not not apply to his particular waste stream.  The methods to be used

for such a demonstration include the four identifying characteristics

plus tests for low-level radioactivity, infectiousness, mutagenic

activity; bioaccumulation potential, and toxicity.

3.2  Standards Applicable to Generators of Hazardous Waste (Section
     3002)

     The Section 3002 regulations identify generators of hazardous
                                 3-2

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waste who would be subject to regulation and specify the responsi-




bilities of these generators.  The generator requirements would apply




to those persons or Federal agencies, except households, who produce




and dispose of more than 100 kilograms (about 220 pounds) per month




of wastes identified as hazardous under the Section 3001 regula-




tions.  Any person or Federal agency producing and disposing of 100




kilograms or less per month would not be required to comply with the




generator regulations; also any generator engaged solely in retail




trade or principally in farming would have to comply with the




regulations only with regard to waste automotive oil.  Generators




excluded from compliance with the Subtitle C regulations would,




however, still be obligated to dispose their hazardous wastes in an




acceptable manner, e.g., in a landfill that meets RCRA Subtitle D




criteria.




     The requirements of the generators of hazardous waste fall




within the following broad categories:




     •  Compliance with the manifest system




     •  Reporting




     •  Recordkeeping




     •  Containerization




     •  Labeling




     •  Furnishing information on general chemical composition.




     The key aspects of these regulations,  and the greatest benefits




to be derived,  revolve around the development  of a manifest system






                                  3-3

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and periodic reporting requirements.   The manifest system would




require that detailed information regarding each shipment of haz-




ardous waste is recorded, accompanies the waste during transport, and




serves as the basis for filing periodic reports.  This system would




serve to promote proper delivery and  disposal of all hazardous wastes




consigned by the generator.  Other aspects of these regulations




(e.g., containerization and labeling) have been developed to be




consistent with existing Department of Transportation (DOT) regu-




lations.




     The full set of reporting and recordkeeping requirements under




this section would be applicable only to generators designating




hazardous wastes for off-site treatment, storage, or disposal in a




facility not owned by the generator.   These generators would have to




submit both an annual report summarizing all hazardous waste




shipments and a quarterly report for  hazardous wastes which were




shipped, but not received by a permitted facility (as evidenced by




the failure to receive the signed original of the manifest or




delivery document from the designated disposal facility).  Generators




designating hazardous wastes for disposal at an off-site facility




owned by the generator and located within the same state as the




generator would not have to comply with any of the reporting or




recordkeeping requirements (although  the facility itself would be




subject to reporting and recordkeeping requirements under Section




3004).
                                  3-4

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Generators designating hazardous wastes for on-site treatment,

storage, or disposal would be exempted from manifesting, contain-

erization, and labeling requirements, though they would have to make

an annual report, keep records, and comply with the Section 3004

regulations.

3.3  Standards Applicable to Transporters of Hazardous Waste (Section
     3003)

     The Section 3003 regulations identify those transporters who are

subject to regulation and specify requirements that fall within the

following broad categories:

     •  Recordkeeping;

     •  Acceptance and transport of hazardous waste;

     •  Compliance with the manifest;

     •  Delivery of the hazardous waste to the designated, permitted
        facility;

     •  Emergency situations;

     •  Marking and placarding of vehicles.

     Many of  these controls are currently imposed upon some trans-

porters of hazardous waste by regulations under the Hazardous Ma-

terials Transportation Act.  Therefore, proposed regulations within

this section are designed to be consistent with current DOT regu-

latory practices.  Further, the proposed regulations would extend the

DOT regulations to intrastate, as well as interstate transportation

of hazardous wastes.  The most significant additions to existing reg-

ulations of these transporters of hazardous waste are the manifest
                                 3-5

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and delivery requirements that would assure that all hazardous wastes

are delivered to the designated,  permitted facility.  In the case of

spills during transport,  the transporter regulations would require

the transporter to immediately notify the specified authority, to

file a written report within 15 days, and to clean up all spilled

hazardous waste or take such action as required so that the spilled

hazardous waste no longer presents a hazard to human health or the

environment.

     The transporter regulations would apply to any person or Federal

agency transporting, within the United States, hazardous wastes that

require a manifest under the generator regulations and also apply to

any transporter importing a shipment of hazardous wastes from abroad.

Portions of  the standards would also apply to any transporter who

consolidates and transports hazardous wastes not requiring a mani-

fest.  The  transporter regulations would not apply to persons or

Federal agencies transporting hazardous wastes solely on the site of

generation  or solely on  the site of a permitted hazardous waste

management  facility.

3.4   Standards For Owners and Operators of Hazardous Waste Treatment,
      Storage, and Disposal Facilities (Section 3004)

      The Section 3004 regulations are intended to provide an adequate

degree of environmental  and public health protection during the

treatment,  storage, and  ultimate disposal of hazardous wastes.  These

standards include requirements relating to the general aspects of

facility operations (i.e., site selection, monitoring, training,

                                 3-6

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security, emergency procedures, and contingency plans, inspections,




closure, financial requirements, and recordkeeping/reporting) as well




as standards applicable to specific types of treatment, storage, and




disposal facilities (i.e., storage tanks, containers, landfarms,




landfills, surface impoundments, basins, incinerators, and chemical,




physical, and biological treatment facilities).




     With the few exclusions noted below, these standards apply to




owners and operators of any facility that treats, stores or disposes




any quantity of waste identified as hazardous under the Section 3001




regulations, except 'special wastes'.  All owners and operators of




facilities that treat, store, or dispose "special wastes', and no




other hazardous waste, would have to comply only with the general




facility standards.  The standards do not apply to on-site storage by




generators who store their own wastes for less than 90 days prior to




subsequent transport of-site, but do apply to any such on-site




storage which lasts for 90 days or longer.




     Certain practices that are controlled under other Federal acts




are not regulated under the treatment, storage, and disposal stan-




dards.  These practices include underground (deep-well) injection,




ocean dumping, discharges to municipal sewer systems, surface dis-




charges under a National Pollution Discharge Elimination System




(NPDES) permit, and all treatment, storage, and disposal- activities




at Publicly Owned Treatment Works (POTW) or by ocean dumping barges




and vessels.  However, the treatment, storage, and disposal regu-




lations would apply to above ground storage or treatment of hazardous



                                  3-7

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wastes prior to underground injection, on-shore facilities associated




with ocean dumping activities, and surface impoundments associated




with NPDES permitted industrial wastewater treatment facilities and




hazardous sludges from such facilities.




     The Section 3004 regulations have been divided into five major




sections: . Human Health and Environmental Standards, General Facility




Standards, Storage Standards, Treatment and Disposal Standards, and




Special Waste Standards.  Some of the standards are accompanied by




notes which either provide further explanation of the standard or




specify a basis for permitting authorities to allow deviations from




the standard.  No deviation is allowed from standards which do not




have accompanying notes.




     There are overriding standards for human health and envi-




ronmental protection:  Groundwater, Surface Water, and Air.  They




establish criteria for human health and environmental protection and




are intended to assure that the design, construction and operation of




hazardous waste facilities does not adversely affect human health or




the environment by degrading the groundwater, surface water, or air.




     The human health and environmental standards are used by EPA in




drafting and evaluating more specific standards and can be used in




designing facilities.  While human health and environmental standards




would be legally binding, they are not intended to be directly




enforced.  They are designed to be used on a case-by-case basis only
                                  3-8

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where there is reason to believe (e.g., a third party challenge) that




the standards are insufficient for human health and environmental




protection.  In such cases, EPA may monitor to determine if the




facility is in compliance with the human health and environmental




standards at issue.




     Furthermore, it is the burden of the government to show that a




facility is in violation of a human health and environmental standard




if the facility is in compliance with all other applicable standards.




Therefore, if a facility is in compliance with all other applicable




standards, but is, nevertheless, discovered to be violating a human




health and environmental standard, no penalty would be assessed to




the facility owner/operator for the period of time prior to that




discovery, and a reasonable time would be allowed for the facility to




be brought into compliance.




     Specific standards which provide measurable criteria and a means




to achieve the human health and environmental standards are necessary




for practical implementation of these regulations, and are required




by the statute.  Thus, the general facility standards, the storage




standards, and the treatment/disposal standards translate the human




health and environmental standards into us,efuLly enforceable require-




ments.  The details of these standards are presented in Subpart D of




Appendix B.
                                   3-9

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      General facility standards apply to every type of hazardous




waste management facility.  They must be complied with at all times




by all regulated facility owners/operators.  If these standards are




not complied with, the facility owner/operator would be considered to




be in violation of these regulations, and could be subject to en-




forcement action for the entire period of the violation.  Unless




exempted, the facility owner/operator has the burden of demonstrating




that he/she is in compliance.  Facility owners/operators may be




required to monitor, report, and otherwise demonstrate compliance




with the general facility standards.




     In addition to the general facility standards, facilities which




store hazardous waste must also comply with the storage standards,




which apply to storage tanks and storage containers, respectively.




The Act's definition of storage implies no discharge to groundwater,




surface water, or air.  The storage standards reflect this intent.




     In addition to the general facility standards, facilities which




treat or dispose of hazardous waste must also comply with the general




treatment/disposal standards.  Facilities with incinerators; land-




fills; surface impoundments; basins; landfarms; or chemical, physical




or biological treatment processes must comply with the standards




prescribed under these subsections.




     Several waste streams have been identified as being of special




concern due to their unique characteristics, and the techno-economic
                                 3-10

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uncertainties regarding their disposal.  These  'special wastes' are

high volume wastes which are often disposed on-site by generators,

for which traditional land disposal technology  is techno-economically

inappropriate, and whose environmental risk is  ill-defined.  These

"special waste1 streams include:  utility wastes (fly ash, bottom

ash), oil drilling muds and brines, cement kiln dusts, phosphate rock

mining and processing wastes, uranium mining wastes, and other mining

wastes.  In the event these wastes meet a hazardous characteristic or

are listed, unique facility standards will be developed for them.

However, these wastes would presently be subject only to general

standards for recordkeeping, reporting, etc.  EPA intends to

develop control technology standards for these wastes as soon as

possible.

3.5  Permit System for Treatment, Storage, or Disposal of Hazardous
     Wastes (Section 3005)

     Section 3005(a) of RCRA requires "...each person owning or

operating a facility for the treatment, storage or disposal of

hazardous waste identified or listed under this subtitle to have a

permit issued, pursuant to this section."  In these proposed regula-

tions as presented in Appendix B, Subpart E, a hazardous waste

management facility is defined as any land and appurtenances there to

used for the treatment, storage, and/or disposal of hazardous waste.

On the effective date of these regulations (i.e., 180 days after

their promulgation), no such facility would be allowed to accept
                                  3-11

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hazardous waste unless its owner or operator had applied for a per-




mit.  The purpose of such permits is to assure that facilities are




constructed and/or operated in a manner consistent with the objec-




tives of the Section 3004 standards.




     The Section 3005 regulations would require that all owners or




operators of facilities treating, storing, or disposing hazardous




wastes obtain a permit prior to facility construction, modification,




or operation.  The regulations establish standards for permit appli-




cations, permit issuance, and permit revocation.  Permits would be




issued for the projected life of the facility.  The owners/operators




of new facilities would be required to obtain permits prior to con-




struction, and would have to certify that construction was performed




in compliance with the permit before commencing operation.  Special




permits would be available for experimental facilities, qualified




hospital-medical care facilities, Public Owned Treatment works, and




ocean dumping barges and vessels.




     The Section 3005 regulations would also require the circulation




of a public notice of any tenative determination to issue, deny, or




modify a permit.  Within 30 days of publication of the notice, any




person would be able to request a public hearing on the determi-




nation.  The Regional Administrator would decide whether such a




hearing  is appropriate at his discretion.




3.6  Guidelines for State Hazardous Waste Programs (Section 3006)




     Section 3006 provides that states are to be encouraged to apply




for authorization to administer and enforce their own hazardous waste




                                 3-12

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program pursuant to Subtitle C.  There would be three types of auth-




orization for which states could apply:  full authorization, partial




authorization, or interim authorization.




     Full authorization would allow a state to carry out a hazardous




waste program in lieu of the Federal program under Subtitle C.  Par-




tial authorization would allow a state to administer and enforce




selected components of the program.  States would be considered for




partial authorization only if state legislative authority did not ex-




ist for all required program commponents.  In all cases, the com-




bination of the state and the Federal program would have to meet the




requirements of a fully authorized program.  Partial authorization




would be granted for a period not to exceed five years,  but could be




renewed.




     Interim authorization would allow a state to carry out a hazard-




ous waste program in lieu of the Federal Program under Subtitle C for




a period not to exceed twenty-four months, beginning on the date 6




months afer the date of promulgation of regulations under Section




3001.  The purpose of interim authorization is to allow the state to




make an orderly transition from its present program to a program




eligible for full authorization.  The guidelines describe the sub-




stantive and procedural requirements for States applying for auth-




orization, EPA's oversight of the State's hazardous waste program,




and for the withdrawal of authorization pursuant to Section 3006(e)




of Subtitle C.  Specific guidelines are drafted with respect to
                                 3-13

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equivalency of programs; consistency with the Federal program;

oversight; application procedures; and withdrawal of authorization.

3.7  Preliminary Notification of Hazardous Waste Activities (Section
      3010)

      These regulations (see Appendix B, Subpart G) define the

administrative procedures under which states may be granted authority

to receive notifications of hazardous waste activities (limited

interim authorization), and specify the procedures for filing such

notifications by persons generating or managing hazardous wastes.

     These regulations would allow states to receive a limited, one-

time authorization (expiring six months after promulgation of the

Section 3001 regulations) to receive notifications of hazardous waste

activities from generators, transporters, storers, treaters, and

disposers.  The states would not have authority to grant exceptions

to the filing requirements, and would have to maintain files of all

receipts, making these files available to EPA at the request of the

Regional Administrator.

      The filing requirements would apply to every person conducting

a hazardous waste activity at the time of promulgation of the Section

3001 regulations.  Such notification would constitute one of the

conditions for interim status for storers, treaters and disposers to

continue operations pending issuance of a facility permit.  The pro-

posed regulations would allow combination of notification require-

ments with application for an identification code by generators and
                                  3-14

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transporters, and with application for facility permits for storers,




treaters,  and disposers.
                                 3-15

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4.0  IDENTIFICATION AND SELECTION OF REASONABLE ALTERNATIVES

     Based upon the overall objectives of RCRA (see Chapter 2), the

major objectives for Subtitle C are to promote public health and en-

vironmental protection in the generation and management of hazardous

wastes, to enhance resource recovery from hazardous wastes, and to

encourage state participation in the hazardous waste management pro-

gram established under Subtitle C.  The proposed Subtitle C regula-

tions, summarized in Chapter 3, have been developed to achieve these

objectives in a feasible and enforceable manner.

     During the development of the proposed Subtitle C regulations,

numerous alternative regulations and regulatory approaches have been

considered.  The proposed regulations were selected from among the

many alternatives based upon economic, technical, environmental,

institutional, and legal considerations.*  The various alternatives

that were considered included changes in regulatory approaches (e.g.,

performance standards versus design and operating standards for haz-

ardous waste storage, treatment and disposal facilities) and changes

in the standards and criteria to be established by the regulations

(e.g., the level of hazardous waste generation at which generators are

designed for purposes of regulation under Section 3002).

     Because of the enormous number of ways in which the overall ob-

jectives, regulations, and standards could be structured and developed,
*Background papers prepared by EPA for each Section of Subtitle C pro-
 vide a detailed discussion of the major issues raised and the major
 regulatory options considered during the development of the proposed
 regulations.
                                  4-1

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the approach in this EIS is to select and develop a manageable set of




meaningful alternatives that reasonably bracket the overall objectives




and the resultant impacts anticipated from whatever regulations are




ultimately promulgated under Subtitle C.  The set of alternatives that




have been developed is meaningful in the sense that each is economic-




ally, technically, legally, and institutionally feasible and enforce-




able, and each provides an assessible shift in the potential impacts




that might result from the proposed regulations.   Also,  the alterna-




tives selected are within the scope of actions allowable under Sub-




title C (e.g., tax incentives to promote resource recovery are not




within the allowable scope of Subtitle C actions).  By reasonably




bracketing the overall objectives and the resultant impacts, it is




possible to show the range and types of potential impacts that could




result under various alternatives without having  to explicitly con-




sider the almost infinite variety of options for  accomplishing the




same or intermediate objectives.




     It is not meant to be implied that any one of the alternatives




selected and structured in this chapter would define the actual regu-




lations to be promulgated under Subtitle C.  Rather, the set of alter-




natives should only be viewed as representative cases for purposes of




analysis and as guidelines for assisting in the planning and develop-




ment of the Subtitle C regulations.




     Based upon the objectives of Subtitle C, four different sets of




alternatives, with respect to the proposed regulations,  have been
                                 4-2

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selected and structured to reasonably bracket the potential impacts




that could be expected to result.  These alternatives are as follows:




     •  No Action;




     •  Phasing of Subtitle C Regulations;




     •  Enhanced Public Health and Environmental Protection;




     •  Lesser Degree of Public Health and Environmental Protection.




     For each of these alternatives, the purpose and rationale for the




selection and structure of the alternative are discussed in the fol-




lowing sections.  To the extent practical,  the major options that were




not considered to be reasonable for inclusion are also indicated, and




the rationale for their elimination is presented.  In the discussion




of the structure of each alternative, all components of the proposed




Subtitle C regulations (see Appendix B) are assumed to be included




under each alternative, except for those specific modifications that




are indicated below.




4.1  No Action




     This alternative has been selected for the purpose of analyzing




the potential impacts that could result from taking no action, i.e.,




not promulgating regulations for Subtitle C.  There are two ways in




which the No Action alternative may be approached.  One way is to




assume that No Action involves not implementing any portion of RCRA,




including Subtitle C.  The other approach is to assume that No Action




involves implementing all portions of RCRA, except Subtitle C.
                                 4-3

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     Under the former approach,  hazardous wastes would continue to be




generated, stored,  transported,  treated,  and disposed in essentially




the same manner as  is currently  practiced.  Under the latter approach,




hazardous wastes would also continue to be generated, stored, trans-




ported, and treated in much the  same manner as is currently practiced;




however, disposal would be somewhat different due to the Subtitle D




regulations.  Open dumps would be prohibited and criteria would be




established with which sanitary  landfills would have to comply.  How-




ever, Section 4003(2) of Subtitle D specifically exempts hazardous




wastes from the requirement that solid wastes be utilized for resource




recovery or disposed of in sanitary landfills or otherwise disposed




of in an environmentally sound manner.  Thus, it is uncertain how Sub-




title D would affect hazardous waste disposal.




     It is not currently possible to prepare a meaningful assessment




of the No Action alternative that assumes that all of RCRA, except




Subtitle C, is to be implemented.  This conclusion is based upon the




unavailability of the final regulations and criteria under Subtitle D




for sanitary landfills, the unavailability of the state solid waste




management plan required under Subtitle D, and the many significant




uncertainties and lack of data about the ways Subtitle D and the rest




of RCRA would affect hazardous waste generation, storage, transport,




treatment and disposal.  Therefore, the No Action alternative to be




assessed in this report assumes  that no part of RCRA, including Sub-




title C, is to be implemented and that hazardous waste management




would continue as currently practiced.




                                 4-4

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4.2  Phasing of Subtitle C Regulations




     This alternative has been selected for the purpose of analyzing




the potential impacts that could result from the promulgation of the




proposed Subtitle C regulations on a phased basis, rather than from




their total implementation at one time.  For purposes of analysis, a




five-year time frame measured from the proposed implementation date is




assumed for the phasing of the regulations.  The primary objectives of




phased implementation are to ensure that resources (e.g., manpower,




disposal sites, and capital) would not be stressed beyond their capac-




ity to respond effectively to the proposed Subtitle C regulations.




     There are two basic mechanisms for phasing the implementation




of proposed Subtitle C regulations.  First, the regulations for each




of the different sections of Subtitle C (i.e., Sections 3001 through




3006 and 3010) could be promulgated one at a time, over a period of




time (e.g. , implementation of the 3001 regulations first, followed by




the implementation of the 3002 regulations 6 months later).  Second,




the regulations for all the sections of Subtitle C could be




promulgated at the same time, and the levels for the standards and




criteria established by the regulations could be phased to their




proposed values over a period of time (e.g., the generator limit under




Section 3002 could be set at 1,075 metric tons per month the first




year, 303 metric tons per month the second year, ..., and 100




kilograms per month the fifth year).
                                 4-5

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     Since RCRA states  that regulations  for each of the different sec-




tions of Subtitle C (i.e.,  Sections  3001  through 3006 and 3010)  are to




be promulgated within eighteen months  after enactment of the Act, the




time phasing or any extended delay of  the promulgation of regulations




for each of the different sections of  Subtitle C is not a feasible




alternative.  Additionally, the interdependence of the various sec-




tions of Subtitle C makes the phasing  of  individual sections unrea-




sonable.  As a result,  the  second mechanism discussed above (i.e.,




phasing of levels for standards and  criteria established by the  Sub-




title C regulations) has been selected as the basis for assessing the




potential impacts that  could result  from  the phased promulgation of




the Subtitle C regulations..




     While there are many different  ways  in which the levels for




standards and criteria  could be phased in,  most would have essen-




tially the same effect—a gradual expansion of the total quantity of




hazardous wastes being  controlled by the  hazardous waste program.  For




purposes of analysis, the method selected emphasizes gradually in-




creasing the quantity of wastes controlled by gradually expanding the




number of generators brought under control.  With this approach, the




level of the generator  limit established  urider 'Section 3002 is to be




reduced annually over a five-year period  of time in order to bring the




larger generators into  the program first  and the smaller generators
                                  4-6

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into the program later.*  Furthermore, the generator limit is to be



reduced so that equal amounts of hazardous wastes are annually brought



under the program's control over the five-year period,  i.e., 20



percent of the total industrial hazardous wastes per year.



     A second method based on gradually increasing the quantity of



wastes controlled through the mechanism of expanding the levels of the



characteristics used to identify hazardous wastes has been determined



not to be a reasonable alternative at the present time.   While it is a



simple matter to change the levels of the characteristics to include



more wastes under the program's control, available data  preclude the



setting of characteristic levels (e.g., specific changes in the pH



level) so as to increase the waste load annually by a specified



amount.  At the very least, such an alternative would result in diffi-



cult program management and enforcement problems.



     A further approach to phasing which involves the gradual phasing



of performance standards under Section 3004 and the permit require-



ments under Section 3005 has also been determined not to be a rea-



sonable alternative since no person can be reasonably expected to



construct a hazardous waste facility to meet regulations that would



be superseded by more stringent regulations in succeeding years.



     Table 4-1 presents the specific changes to each section of the



proposed Subtitle C regulations that are to be included  under this
fc
 The generator limit is the upper bound on the amount of hazardous

 wastes that can be produced and disposed monthly without being sub-

 ject to the Section 3002 regulations.



                                  4-7

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                         TABLE 4-1

                   PHASING OF GENERATORS


              3001 Modifications (Subpart A)*

•  No changes.


              3002 Modifications (Subpart B)*

•  Phase in the generator limit (250.21[6]).*
    1,075 metric tons per month during the first year;
      303 metric tons per month during the second year;
      125 metric tons per month during the third year;
       34 metric tons per month during the fourth year;
      100 kilograms per month during the fifth year.

•  Phase in the 90-day exclusion for generators who tempo-
   rarily store hazardous wastes prior to off-site disposal
   (250.61[dd]).*
      Twelve-month exclusion for the first two years, then
      decrease to 270 days, 180 days, and 90 days over the
      last three years.


              3003 Modifications (Subpart C)*

•  No changes.


              3004 Modifications (Subpart D)*

•  Phase in the time  limit for reporting of unmanifested wastes
   delivered  to permitted facilities (250.43 - 6(a)(4)).
      No reporting during the first year;
   -  Quarterly reporting during the second and third years;
   -  Monthly reporting during the fourth year;
   -  Immediate reporting during the fifth year.


              3005 Modifications (Subpart E)*

•  Phase in generator storage exemption as specified above under
   3002 modifications (250.61[dd]).*
                            4-8

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                        TABLE 4-1  (Concluded)







                   3006 Modifications (Subpart F)*




     •  No changes.







                   3010 Modifications (Subpart G)*




     •  No changes.
*Section in Appendix B that is being changed by this modification.




                                 4-9

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alternative.   All components  of the proposed regulations discussed in

Appendix B are assumed to be  included under this alternative,  except

for those specific modifications that are indicated in Table 4-1.

For ease in correlating the indicated modifications with the proposed

regulations summarized in Appendix B, the appropriate section of

Appendix B being modified is  given immediately following the change

presented in Table 4-1.

     While this alternative emphasizes the phasing of generators to be

regulated under the program,  the modifications presented in Table 4-1

are not limited solely to this one change.  Rather, two additional

modifications have been included to assist in fulfilling the stated

objectives of the phasing alternative.  These additional modifications

phase in the time limit that  generators may store hazardous wastes

prior to off-site disposal without being brought into the permit

system  and the time limit for reporting of unmanifested wastes.

     Since the proposed regulations provide for the phasing in of

state participation in the program through both interim authorization

and partial authorization, no additional modifications have been made
to promote phasing of state authorized programs.

4.3  Enhanced Public Health and Environmental Protection

     This alternative has been selected for the purpose of analyzing

the potential impacts that could result from modification of the pro-

posed Subtitle C regulations designed to further increase public

health  and environmental protection above that level afforded by the
proposed regulations.
                                 4-10

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     The basic strategy of this alternative is to expand the defini-




tion of hazardous waste in order to bring additional wastes under




control of the program; to remove exclusions provided for hazardous




waste generators; to apply more stringent design and operational re-




quirements for storers, treaters, and disposers; to eliminate special




waste standards; to reduce reporting intervals for storers, treaters,




and disposers; to eliminate the use of delivery documents in lieu of




manifests; and to decrease the life of permits and impose additional




restrictions on obtaining permits.




     Table 4-2 presents the specific changes to each section of the




proposed regulations that are to be included under this alternative.




As previously discussed, all components of the proposed regulations




discussed in Appendix B are assumed to be included under this alter-




native, except for those specific modifications indicated in Table




4-2.




     Under this alternative, the definition of hazardous wastes in




Section 3001 has been expanded by adding characteristics for defin-




ing infectious wastes and radioactive wastes as hazardous.  The char-




acteristic for identifying toxic wastes has also been expanded to




bring additional wastes under control of the regulations.




     The exclusion from the Section 3002 regulations for generators




who produce less than 100 kilograms per month of hazardous wastes has




been eliminated.  The exclusion for those generators engaged solely in




retail trade or principally in farming for all hazardous wastes







                                 4-11

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                              TABLE 4-2

         ENHANCED PUBLIC HEALTH AND ENVIRONMENTAL PROTECTION


                   3001  Modifications  (Subpart A)*

•  Add characteristics  for identifying infectious wastes and radio-
   active wastes as hazardous wastes (250.13).*
   (1)  A solid waste is an infectious waste  if it is generated from
        the sources listed in Appendix B,  Subpart A,  250. 14(a) (2) (i) ,
        unless the waste does not  contain  microorganisms or helminths
        of CDC Classes  2 through 5 of  the  Etiologic Agents listed in
        Appendix B, Subpart A,  Appendix IX.
   (2)  A waste is a radioactive waste if  it  is not source, special
        nuclear, or byproduct material as  defined by the Atomic
        Energy Act of 1954, as amended, and  if a representative
        sample of the waste has either of  the properties listed
        in Appendix B,  Subpart A,  250.14(b) (2) (F) (i)  and 250.14(b)
   Eliminate the toxic waste  characteristic  based upon the EPA Primary
   Drinking Water standards  and replace with the following character-
   istic for identifying toxic wastes  as hazardous ( 250.13[4] ) :*
   -  A solid waste is a toxic waste if the  extract obtained from
      applying the extraction procedure (EP) in Appendix B, Subpart A,
      250.13(b)(4) (i) to a representative sample of the waste has any
      of the following properties:
         (1)  Gives a positive response in any one of a set of re-
              quired tests for a mutagenic activity,  described
              in Appendix B,  Subpart A, 250.14(b) (2) (G) (i).
         (2)  Gives a positive result  in the Bioaccumulation Potential
              Test, defined  in Appendix B, Subpart A, Appendix XII.
         (3)  Contains more  than the specified concentration of any
              substance in Appendix B, Subpart A, Appendix XIII.
         (4)  Exceeds any of  the following thresholds, when applica-
              ble :
              (a)  Has a concentration of a  substance, for which an
                   EPA Primary Drinking Water Standard has been es-
                   tablished, greater  than or equal to 10 times that
                   criteria.
              (b)  Contains  any organic substance, which has a calcu-
                   lated human LD50 of less  than 800 mg/'kg, at a con-
                   centration in mg/1  greater than or equal to 0.35
                   times its  LD50 expressed  in units of mg/kg.
              (c)  Has a concentration of any substance listed below
                   greater than that specified:
                                4-12

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                     TABLE 4-2 (Continued)
                                       Maximum Permissable EP
                   Substance        Elutriate Concentration (mg/1)

                   Antimony                       ?
                   Beryllium                      ?
                   Copper                         ?
                   Dalapon                        3.5
                   Dichobenil                    10.
                   Diquat                        50.
                   Fenac                          1.0
                   Nickel                         ?
                   Picloram                       0.1
                   Thallium                       ?
                   Zinc                           ?
                3002 Modifications (Subpart B)*

Eliminate the 100 kilograms per month generator limit (250.21[6]).*
      Anyone, except households, generating any amount of the
      hazardous wastes identified under Section 3001 must comply
      with the Section 3002 regulations.

Remove exclusion from Section 3002 regulations for generators
engaged solely in retail trade or principally in farming
(250.20[f]).*
      Farmers and retail generators must comply with Section 3002
      requirements for all hazardous wastes identified under Sec-
      tion 3001.

Increase reporting frequency from annually to quarterly for all
generators (250.23).*
      All portions of the "previous" annual report are to be re-
      ported quarterly.

Increase the reporting frequency for manifests not received by the
designated facility from quarterly to monthly (250.23[aj[2j).*

Eliminate the use of a delivery document in lieu of a manifest
(250.21[3]).*
      All hazardous waste shipments must be accompanied by the
      manifest.
                              4-13

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                       TABLE 4-2 (Continued)
                   3003 Modifications (Subpart Q*

•  Eliminate the use of a delivery document in lieu of a manifest
   (250.31[a]).*
      -  All hazardous waste shipments must be accompanied by the
         manifest at all times.
                   3004 Modifications (Subpart D)*

•  Eliminate special waste standards for cement kiln dust waste,
   utility wastes, phosphate rock mining and processing wastes,
   uranium mining wastes, and oil drilling muds/brines (250.46).*
         These wastes, if hazardous under Section 3001, must comply
         with all Section 3004 standards.

•  Change the application of the threshold limit value for air con-
   taminents from non-point emission sources (250.42-3[b]) .*
         The threshold limit value is to be applied as a maximum
         concentration that is not to be exceeded at any time
         rather than as a t-ime-weighted average for an 8-hour
         day and 40-hour week.
      -  The threshold limit value is to be applied as a mandatory
         standard rather than a human health and environmental
         standard.

•  Increase the minimum distance active portions of facilities must be
   located from the facility's property line from 200 feet to 400 feet
   (250.43-l[h]).*

•  Increase the minimum distance surface impoundments, active portions
   of landfills, and treated areas of landfarms must be located from
   any functioning public or private water supply or livestock water
   supply from 150 meters (500 feet) to 300 meters (1000 feet)
   (250.45-2[aJ[3], 250.45-3[a][3],  and 250.45-5[c][3]).*

•  Increase the financial responsibility required of owner/operators
   of treatment, storage, or disposal facilities during site operation
   from a minimum of $5 million to a minimum of $10 million (250.43-2
   Lbj ;.*
                                4-14

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                        TABLE 4-2 (Continued)
•  Increase the time during which the owner/operator of a facility is
   to provide post close-out care from a period which need not exceed
   20 years from closure to a period which need not exceed 40 years
   from closure (250.43-8[k][1]).*
      -  The annual cash payment into the trust fund for post close-
         out monitoring and maintenance is to be adjusted based upon
         this 40-year period (250.43-2[aj[2]).*

•  Add a requirement that all inactive treatment, storage, and dis-
   posal facilities must comply with the Section 3004 regulations.'

•  Add a requirement that all wastes be treated using the best prac-
   tical technology (BPT) to reduce their waste solubility and over-
   all toxicity before disposal.'

•  For all landfills and surface impoundments,  increase the required
   permeability of the soil liner and of the final cover from less
   than or equal to 1 x 10-7 cm/sec, to less than or equal to 1 x
   10-8 cm/sec. (250.45-2[bJ[10],  250.45-2[b][12][ii], 250.45-2[b]
   [12][v], 250.45-2[c][l], 250.45-3[c][2], and 250.45-3[c][9]).*

•  Add the requirement that any landfarm that has the potential to
   discharge to groundwater must be monitored so as to detect any
   discharge (250.43-9).*
         Such landfarms must comply with the groundwater and leachate
         monitoring standards.

•  Reduce the maximum vapor pressure of wastes  that may be treated,
   stored, or disposed as indicated below from 78 mm of Hg at 25 C
   (250.44-HaJUJ, 250.45-2[b] [5] liii] , 250.45-3 [b] [1] [v] ,  250.45-4
   [2][e], and 250.45-5[1][ii]).*
      -  Wastes with a vapor pressure greater than 53 mm of Hg at
         25 C may not be disposed in landfills, placed in surface
         impoundments or basins, landfarmed, nor put in storage
         tanks vented directly  to the atmosphere.

•  Increase reporting frequency for report  based on manifest informa-
   tion from annually to quarterly (250.43-6[a][3]).*

•  Add a requirement that for those hazardous wastes determined by the
   permitting agency to have a  recovery potential within the reason-
   able forseeable future,  any  land disposal must be in a segregated
   manner.T
                                 4-15

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                         TABLE 4-2 (Continued)
                   3005 Modifications (Subpart E)*

•  Reduce the duration of permits from the projected life of the
   facility to a period no longer than 5 years (250.62-5).*
         Permits may be renewed for the maximum time period (5 years)
         an unlimited number of times.

•  Eliminate special permits for experimental facilities, qualified
   hospital-medical care facilities, ocean dumping barges or vessels,
   and publicly owned treatment works (POTW) (250.62-6, 250.62-7,
   250.62-8, and 250.62-9).*
      -  All these facilities must submit both Part A and B of the
         permit application and a supplementary environmental analy-
         sis described below (250.62-6[b], 250.62-7[b], 250.62-8[b],
         and 250.62-9[b]).*
         Experimental facilities and qualified hospital-medical care
         facilities must comply with all Section 3004 requirements
         (250.62-6[b] and 250.62-6[a][3]).*
      -  POTW's and ocean dumping barges or vessels must comply with
         Section 3004 requirements applicable to storage of hazardous
         wastes (250.62-8[b] and 250.62-9[b]) .*

•  Owners/operators of facilities for the treatment, storage, or dis-
   posal of special wastes (e.g., cement kiln dust wastes) must apply
   for Section 3005 permits and comply with all Section 3005 permit
   application requirements.'

•  All permit applicants must submit a Supplementary Environmental
   Analysis of the facility and its potential impacts.  The Supple-
   mentary Environmental Analysis is to contain:^
     (1)  An analysis of the impact of and methods proposed to comply
          with the following Federal statutes and published regula-
          tions where applicable:  The Endangered Species Act; The
          National Historic Preservation Act; The Historic Sites,
          Buildings and Antiquities Act; The Fish and Wildlife Coor-
          dination Act; and The Coastal Zone Management Act.
     (2)  A discussion of whether alternative methods for treatment,
          recovery, or recycling of wastes to be stored, treated, or
          disposed were considered, or whether the wastes will be
          treated prior to storage or disposal.
     (3)  A description of how hazardous wastes will be transported to
          the facility, including a listing of the access routes.
     (4)  The proximity of the site to population centers and size of
          the population centers.
                                 4-16

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                        TABLE 4-2 (Concluded)
      (5)  A description of any easements,  pipelines,  utilities,
           public roads, or rights-of-way located within the bounda-
           ries of the facility.
      (6)  A description of applicable local and state zoning or  land
           use laws in effect.
      (7)  A description of adjacent land uses within one mile of the
           facility.
      (8)  A description of the methods proposed to minimize and  con-
           trol impacts of dust, odors, and noise associated with
           construction and operation of the facility.
      (9)  A listing of applications submitted or permits obtained
           under local state, or Federal acts involving toxic or
           hazardous wastes.
                   3006 Modifications (Subpart F)*

•  No changes.


                   3010 Modifications (Subpart G)*

•  Eliminate the exclusion for owners of inactive hazardous waste
   treatment, storage, and disposal facilities.'
         The owner of inactive facilities must file a notification.
 Section in Appendix B that is being changed by this modification.
tNo equivalent regulation appears in Appendix B.

                                 4-17

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produced, except waste automotive oil, has also been eliminated.  All




hazardous wastes produced by such generators are to be managed in




accordance with the Subtitle C regulations.




     The use of delivery documents in lieu of manifests for hazardous




waste transport has been eliminated.  The reporting frequency for the




generator report on manifests not received by the designated facility




has been increased from quarterly to monthly.  Other reporting fre-




quencies for generators, storers, treaters, and disposers have been




increased from annually to quarterly.  A requirement has been added




that owners of inactive treatment, storage, or disposal facilities




comply with all Section 3004 regulations.




     Special standards for 'special wastes' (i.e., cement kiln dust




wastes, utility wastes, phosphate rock mining and processing wastes,




uranium mining wastes, and oil drilling muds/brines) have been




eliminated; such 'special wastes' must comply with all Section 3004




standards.  Design and operating standards for facility location,




non-point source air emission concentrations, post close-out care,




soil liner permeabilities, groundwater monitoring, financial




responsibilities, management of volatile wastes, and treatment and




segregation of wastes before disposal have been made more stringent.




     The duration of the permit life has been reduced from the pro-




jected life of a facility to a period not to exceed 5 years; permits




may be renewed an unlimited number of times.  Special permits for




experimental facilities, qualified hospital-medical care facilities,







                                 4-18

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ocean dumping barges or vessels, and publicly owned treatment works




(POTW's) have been eliminated; the former two have to comply with all




Section 3004 requirements, the latter two have to comply with Section




3004 storage requirements.  A requirement has been added that all




permit applicants submit a Supplementary Environmental Analysis.




4.4  Lesser Degree of Public Health and Environmental Protection




     This alternative has been selected for the purpose of analyzing




the potential impacts that could result from modifications to the




proposed Subtitle C regulations designed to provide a lesser degree




of public health and environmental protection than that afforded by




the proposed regulations.




     The basic strategy of this alternative is to contract the defi-




nition of hazardous wastes in order to bring fewer wastes under the




control of the program; to increase exclusions provided for hazardous




waste generators; to reduce manifest requirements; to apply less




stringent design and operational requirements for storers, treaters,




and disposers; to eliminate regulation of special wastes; to decrease




recordkeeping times for generators, transporters, storers, treaters,




and disposers; to increase the length of permit exclusions for gener-




ators who store prior to off-site disposal; to eliminate restrictions




on interim authorization; and to ease restrictions on full and partial




authorization.




     Table 4-3 presents the specific changes to each section of the




proposed regulations that are to be included under this alternative.
                                4-19

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                              TABLE 4-3

     LESSER DEGREE OF PUBLIC HEALTH AND ENVIRONMENTAL PROTECTION



                   3001 Modifications (Subpart A)*

•  Eliminate the characteristic for toxic wastes (250.13[4] ) .*
         Eliminate the listed wastes whose listing is based solely
         on the toxicity characteristic or on the Administrator's
         judgment (250.14).*

•  Exclude the following wastes from being identified as hazardous
   wastes under Section 3001:  cement kiln dust wastes,  utility
   wastes, phosphate rock mining and processing wastes,  uranium
   mining wastes, and oil drilling muds/brines (250.14[a]



                   3002 Modifications (Subpart B)*

•  Increase the generator limit from 100 kilograms per month to
   1000 kilograms per month (250.21[6] ).*

•  Increase the length of the permit exclusion for generators  who
   temporarily store hazardous waste prior to off-site disposal
   from 90 days to 1 year (250.61[dd]).*

•  For off-site shipments of hazardous  wastes by generators,  replace
   the Section 3002 manifest requirements with a new manifest  require-
   ment that all such shipments (interstate and intrastate) must be
   accompanied by shipping paper/bill of lading which designates
   delivery to a permitted storage, treatment, or disposal facility
   and which meets the requirements of  the DOT Hazardous Materials
   Regulations (250.21[3] and 250.22).*
      -  For example, spill information need not be provided on the
         shipping paper/bill of lading,  and the shipping paper/bill
         of lading need only be signed  as required under the DOT
         Hazardous Materials Regulations (i.e., must be  signed only
         by the generator shipping the  wastes).

•  Replace requirement for recordkeeping of manifest copy with a
   requirement for recordkeeping of shipping paper/bill  of lading
   (250.24).*
      -  Decrease recordkeeping time for shipping paper/bill  of
         lading used in place of manifest from 3 years to 1 year.


                                 4-20

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                        TABLE 4-3 (Continued)


•  Eliminate the reporting of shipping paper/bill of lading not re-
   ceived at designated facility (250.23[a][2]).*


                   3003 Modifications (Subpart  Q*

•  Replace the Section 3002 manifest requirements with a new manifest
   requirement that all shipments (interstate and intrastate) must be
   accompanied by shipping paper/bill of lading which designates de-
   livery to a permitted storage, treatment,  or disposal facility and
   which meets the requirements of the DOT Hazardous Materials Regu-
   lations (250.21[3]  and 250.22).*
         Eliminate need for signatures on shipping paper/bill of
         lading, except as required under the DOT Hazardous Mate-
         rials Regulations (i.e., must be signed only by the gen-
         erator shipping the wastes).

•  Replace requirement for recordkeeping of manifest with a require-
   ment for recordkeeping of shipping paper/bill of lading (250.33).*
      -  Decrease recordkeeping time for shipping paper/bill of
         lading from 3 years to 1 year, except  where DOT Hazardous
         Materials Regulations specify retention times longer than
         1 year.

•  Eliminate special emergency spill regulations (250.37).*
      -  Eliminate requirements for the transporter to notify
         appropriate officials in the case of a spill and to
         file a report on the spill.
         Eliminate requirement for transporter  to clean up spill
         or to take other action required to insure the spill no
         longer presents a hazard to human health or the environ-
         ment.

•  Eliminate requirement that if a transporter  consolidates shipments
   of hazardous wastes that do not require a manifest, the entire
   shipment must be delivered to a permitted facility (250.30[a]).*

                   3004 Modifications (Subpart  D)*

•  Eliminate special waste standards for cement kiln dust wastes,
   utility wastes, phosphate rock mining and processing wastes, ura-
   nium mining wastes, and oil drilling muds/brines (250.46).*
         Exclude these wastes from compliance with Section 3004
         regulations.
                                 4-21

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•
•
                     TABLE 4-3 (Continued)
Change the application of the threshold limit value for air conta-
minants from non-point emission sources (250.42-3[b] ) .*
   -  The threshold limit value is to be applied as time-
      weighted average for a 24-hour day rather than as a
      time-weighted average for an 8-hour day and 40-hour
      week.

Decrease the minimum distance active portions of facilities must
be located from the facility's property line from 200 feet to 100
feet (250.43-l[h]).*

Decrease the minimum distance surface impoundments, active portions
of landfills, and treated areas of landfarms must be located from
any functioning public or private water supply or livestock water
supply from 150 meters (500 feet) to 75 meters (250 feet) (250.45-2
[a] [3], 250.45-3[a][3], and 250.45-5[c] [3] ) .*

Decrease the financial responsibility requir.ed of owners/operators
of treatment, storage, or disposal facilities during site operation
from a minimum of $5 million to a minimum of $2 million (250.43-2
[b]).*

Decrease the time during which the owner/operator of a facility is
to provide post close-out care from a period which need not exceed
20 years from closure to a period which need not exceed 10 years
from closure (250.43-8[k] [1] ).*
      The annual cash payment into the trust fund for post close-
      out monitoring and maintenance is to be adjusted based upon
      this 10-year period (250.43-2[a] [ 2] ) .*

For incineration, reduce the destruction efficiency of the princi-
pal components of the waste from 99.99% to 99.9%, the combustion
efficiency from 99.9% to 99%, and halogen removal from exhaust
gases from 99% to 90% (250.45-1 [b] , 250.45-1
[d], and 250.45-1 [h] ).*

For all landfills and surface impoundments, decrease the required
permeability of the soil liner and of the final cover from less
than or equal to 1 x 10-7 cm/sec, to less than or equal to 1 x
10-6 cm/sec. (250.45-2[b] [ 10] , 250.45-2[b] [ 12] [ii] , 250.45-2[b]
[12][v], 250.45-2[c][l], 250.45-3[c] [ 2] , and 250.45-3[c] [ 9] ) .*

Limit to groundwaters that are underground drinking water sources
the requirement that all facilities, except landfarms, that have
the potential to discharge to groundwater must be monitored to
detect any discharge (250.43-9).*

                              4-22

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                        TABLE 4-3 (Continued)
         There does not have to be monitoring "of potential
         discharge to groundwaters which are non-underground
         drinking water sources.

•  For those facilities for which there is to be groundwater and
   leachate monitoring, eliminate the quarterly monitoring and
   minimum analysis of samples from both the leachate detection
   system and the groundwater (250.43-9[b][4] and 250.43-9[b][5]).*
      -  Eliminate the quarterly reporting of this monitoring
         data (250.43-9[d][l]).*
         Retain annual monitoring and comprehensive analysis
         (250.43-9[c][4] and 250.43-9[c][5]).*

•  Eliminate the restriction on the maximum vapor pressure of
   wastes that may be treated, disposed, or stored as indicated
   below (250.44-l[a][1],  250.45-2[b][5][iii], 250.45-3[b][1][v],
   250.45-4[2][e], and 250.45-5[1][ii]).*
         Wastes with a vapor pressure greater than 78 mm of Hg
         at 25 C may be disposed in landfills, placed in surface
         impoundments or basins, landfarmed, or put in storage
         tanks vented directly to the atmosphere.

•  Increase the time interval for completing training of personnel
   from 6 months to 1 year (250.43-5[a]).*

•  Eliminate the regulation of commercial products made from
   hazardous wastes (250.45-7).*
         Such commercial products are not to be considered
         hazardous wastes.

•  Replace requirements for recordkeeping of manifest copy with a
   requirement for recordkeeping of shipping paper/bill of lading
   (250.43-6[a][2].*
      -  Decrease recordkeeping time for shipping paper/bill of
         lading used in lieu of manifest from 3 years to 1 year
         (250.43-6[a][2]).*

•  Eliminate need for signatures on shipping paper/bill of lading,
   except as required under the DOT Hazardous Materials Regulations
   (250.43-6[a][l][a]).*
                                 4-23

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                        TABLE 4-3 (Concluded)
                   3005 Modifications (Subpart E)*

   Increase the length of the permit exclusion for generators who
   temporarily store hazardous wastes prior to off-site disposal
   from 90 days to 1 year (250.61[dd]) .*

   Eliminate the need for publicly owned treatment facilities,
   qualified hospital-medical care facilities, and ocean dumping
   barges or vessels to apply for a special permit (250.62-7[bj ,
   250.62-8[b], and 250.62-9[b]).*
         Such facilities are automatically granted the special
         permits.
                   3006 Modifications (Subpart F)*

•  Eliminate restrictions on granting of full or partial authori-
   zation to states with more stringent standards (250.72[a][ii]
   and 250.72[b][l]).*

•  Eliminate all restrictions on granting of interim authorization,
   except for the Memorandum of Understanding (250.73).*
         All states desiring interim authorization are to be
         granted it, providing that they have a Memorandum of
         Understanding


                   3010 Modifications (Subpart G)*

•  Retail generators need not notify (250.820[a]).*
 Section in Appendix B that is being changed by this modification.
                                 4-24

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As previously discussed, all components of the proposed regulations




discussed in Appendix B are assumed to be included under this alter-




native, except for those specific modifications indicated in Table




4-3.




     Under this alternative, the definition of hazardous wastes in




Section 3001 has been modified to include fewer wastes by eliminating




the characteristic for toxic wastes; listed wastes whose listing is




based solely on the toxicity characteristic (including those listed




based on the Administrator's judgment) have been removed from the




Section 3001 lists.  Special wastes (e.g., cement kiln dust wastes and




utility wastes) have been specifically excluded from being identified




as hazardous wastes under Section 3001.




     The exclusion from the Section 3002 regulations for generators




who produce less than 100 kilograms per month of hazardous wastes has




been replaced by an exclusion for all generators who produce less than




1000 kilograms per month.  The 90-day permit exclusion for tempo-




rary storage by generators prior to off-site disposal has been in-




creased to a one-year exclusion.  Retail generators have been excluded




from notification required under Section 3010.




     For off-site shipments of hazardous wastes by generators, the




Section 3002 manifest requirements are replaced by a requirement that




all such shipments (interstate and intrastate) must be accompanied by




a  shipping paper/bill of lading which designates delivery to a per-




mitted storage, treatment, or disposal facility and which meets the
                                  4-25

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requirements of the DOT Hazardous Materials Regulations.*  For example

the spill information required by the manifest is not required for the

shipping paper/bill of lading, and the signature requirements of the

manifest are replaced by signature requirements under the DOT

Hazardous Materials Regulations (i.e., only the generator shipping the

wastes needs to sign the shipping paper/bill of lading).

     The reporting of shipping papers/bills of lading not received at

the designated facility is eliminated.  Recordkeeping requirements for

shipping papers/bills of lading are reduced from 3 years to 1 year for

generators, transporters, storers, treaters, and disposers.  The spe-

cial emergency spill regulations for transporters have been elimi-

nated.

     Regulation of 'special wastes'  under Section 3004 has been elim-

inated.  Design and operating standards for facility location, non-

point source air emission concentrations, incineration, post close-

out care, soil lines permeabilities, groundwater monitoring, financial

responsibilities, management of volatile wastes, training of person-

nel, and commercial products have been made less stringent.

     Permit requirements for POTW's, qualified hospital-medical care

facilities, and ocean dumping barges or vessels have been eliminated.

Such facilities would be granted permits by rule and would not have to

comply with any Section 3004 requirements.
 The DOT Hazardous Materials Regulations are to be applied to both
 interstate and intrastate shipments of hazardous wastes.


                                 4-26

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     All restrictions on the granting of interim authorization,  except




the Memorandum of Understanding,  have been eliminated.   Any state




desiring interim authorization would be granted such status, providing




the state submits a Memorandum of Understanding that specifies how the




state plans to become eligible to attain full authorization at the end




of the interim authorization period.  States may also impose




considerably more stringent standards than those promulgated under




Sections 3001 through 3005 and still be authorized for  full or partial




authorization, even if there is no public health and/or environmental




protection basis for the more stringent standards.
                                 4-27

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5.0  EXISTING HAZARDOUS WASTE GENERATION AND MANAGEMENT PRACTICES




     This chapter provides a characterization of the types of wastes




that could be considered as potentially hazardous under the Subtitle




C regulations and identifies potential sources of hazardous waste




generation; examples of the types of potentially hazardous wastes




generated by .selected sources are also presented.  Prevalent trans-




port, storage, treatment, and disposal methods are described and




relevant aspects of typical hazardous waste practices are summarized.




Estimates of the quantities of hazardous wastes being generated are




provided in Chapter 6.




5.1  Characterization of Hazardous Waste Generation




     This section first presents a general description of the charac-




teristics of wastes that are considered hazardous.  This is followed




by selected examples identifying existing sources of hazardous waste




and the types of potentially hazardous wastes currently being gener-




ated.  It is the intent of this section to characterize hazardous




wastes only to the extent necessary to provide a general under-




standing of the various properties, types, and sources of such wastes




rather than to present an exhaustive delineation of potentially




hazardous wastes and their sources of generation.




     5.1.1  Hazardous Waste Characteristics.  The Subtitle C regula-




tions and the alternatives to the regulations (see Chapters 3 and 4)




contain characteristics and lists for identifying wastes that are to




be considered hazardous and, thus, to be brought under control of the







                                 5-1

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regulations.  The specific characteristics considered for use in

identifying hazardous wastes are as follows:

     •  Flammability;

     •  Corrosiveness;

     •  Infectiousness;

     •  Reactivity;

     •  Radioactivity;

     •  Toxicity.

     Appendix B (Subpart A) and Chapters 3 and 4 describe the

specific properties a waste must exhibit to be considered hazardous

under any one or more of these characteristics and list waste

materials which are considered hazardous.

     Wastes to which these characteristics apply and which could thus

be identified as hazardous under Subtitle C include garbage; refuse;

sludge  from a waste treatment plant, water supply treatment plant, or

air pollution control facility; and other discarded material,

including solid, liquid, semisolid, or contained gaseous material

resulting from industrial, commercial, mining, and agricultural

operations, and from community activities.*  Wastes specifically

exempted from regulations by RCRA  itself, and thus exempted from

Subtitle C, include solid or dissolved material in domestic sewage;

solid or dissolved materials in irrigation return flows or industrial

discharges which are point sources  subject to permits under Section
*However,  the Subtitle C regulations contain provisions  specifically
  exempting household refuse and household septic  tank pumpings  from
  regulation.

                                 5-2

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402 of the Federal Water Pollution Control Act, as amended (86 Stat.




880); and source, special nuclear, or byproduct material as defined




by the Atomic Energy Act of 1954, as amended (68 Stat. 923).   Any




waste, except those wastes specifically exempted from regulation,




which meets any one or more of the specified characteristics  or which




is listed, would be considered as hazardous under the Subtitle C




regulations.




     In attempting to characterize those wastes that could be consi-




dered hazardous under Subtitle C, it must be realized that most waste




streams consist of a mixture of waste materials and that it is this




mixture, not just individual components, which establishes the




hazardous nature of the waste.  Very rarely do wastes consist of just




one material.  The hazardous nature of every waste stream depends




upon several factors, including the types of materials present, the




concentration of each constituent, the interactions of the materials




present, and the physical form of the waste materials.




     The types of materials (both hazardous and nonhazardous) present




in any waste stream, and the relative concentrations of these




materials, vary from waste stream to waste stream and are very highly




dependent upon such factors as the types of feedstock utilized by the




process or activity generating the waste, the specifics of that




process or activity, and the presence of any pollution controls and




waste treatment practices.  No two waste streams are identical;




similar processes or activities can generate waste streams







                                 5-3

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that are very different in nature.   In fact, most waste generators

produce more than one type of waste stream, e.g., waste streams from

any generator may be in the form of liquids, solids, sludges, slur-

ries, containerized gases, or any combination of these and any one or

all of these waste streams may be classified as hazardous under the

Subtitle C regulations.  (Section 5.1.2 presents examples of poten-

tially hazardous waste streams and waste stream constituents for

selected generators.)

     With regard to the constituents present, the totality of the

waste streams generated in the U.S. is likely to contain, to some

degree, practically every type of substance or product produced in or

imported into the U.S. as well as nearly every type of material used

as  a feedstock in a manufacturing process along with many of the

intermediate materials generated by these processes.  Many of these

constituents are by themselves potentially hazardous and their

presence, in sufficient concentration, can make the waste stream

hazardous.

     A number of studies have attempted to define the characteristics

that make materials toxic and/or hazardous* and to identify and rank

such materials.  Most of these studies have dealt with pure sub-

stances and commercial products, rather than with wastes.  Thousands
*Materials which are toxic are hazardous.  However, toxicity is just
  one of several characteristics for judging a waste to be hazardous.
  Wastes do not necessarily have to be toxic to be hazardous.
                                 5-4

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of compounds have been listed as potentially toxic or hazardous.  For




example, the United States Toxic Substances Control Act, Interagency




Testing Committee has initially identified about 3,600 compounds as




representing the potentially most hazardous compounds within the




larger universe of around 60,000 chemicals used in U.S. commerce.




These 3,600 compounds represent a consolidation of nineteen separate




priority chemical lists compiled in recent years (U.S. Environmental




Protection Agency, 1978).  Table 5-1 indicates the sources of these




other 19 lists, the number of chemicals included, and the main




selection criteria.  For a more detailed discussion of the selection




criteria and the substances included on each list, see the individual




sources.  Every one of the thousands of materials contained in these




lists may appear in some waste stream, and the presence of any one




could, in sufficient quantity, result in the waste stream being




hazardous.




     While the types and the concentrations of materials present are




the prime determinants of the hazardous nature of the waste stream,




interactions among the various constituents can drastically alter the




hazardous nature of the waste stream.  Interactions which can occur




include synergisms, antagonisms, complex formation, and chemical




reactions.




     Synergism involves two or more materials acting together to




create a combined effect which is greater than the sum of their




individual effects or to lower the threshold level at which effects
                                 5-5

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                              TABLE 5-1

    SOURCES OF CHEMICALS FOR INCLUSION ON THE INITIAL LIST OF THE
      TOXIC SUBSTANCE CONTROL ACT INTERAGENCY TESTING COMMITTEE*
Source lists used
Number of
chemicals
included
  Main
selection
criteria
1.   Toxic Pollutants in Point Source Water       129           T
     Effluent Discharge, Environmental
     Defense Fund/EPA PL-92-500

2.   Scoring of Organic Air Compounds, June       337         T & P
     1976, MITRE,  MTR-6248

3.   Final Report  of NSF Workshop Panel to         80           P
     Select Organic Compounds Hazardous to
     the Environment, April 1975, Stanford
     Research Institute/National Science
     Foundation

4.   Potential Industrial Carcinogens and          88         T & P
     Mutagens, National Center for Toxico-
     logical Research

5.   Occupational  Carcinogens for Potential       116           T
     Regulatory Action, Department of Labor—
     Occupational  Safety and Health Admin-
     istration (OSHA)

6.   Chemicals Tested or Scheduled for Testing    174           T
     at the Fish-Pesticide Research Labora-
     tory, Department of Interior—Department
     of Fish and Wildlife

7.   Substances with Chronic Effects other         —           T
     than Mutagenicity, Carcinogenicity or
     Teratogenicity:  A Subfile of the NIOSH
     Registry (Source List 13)

8.   Criteria Documents Prepared or Planned       127         T & P
     by NIOSH, February 24, 1977

9.   Suspected Carcinogens; A Subfile of        1,900           T
     the NIOSH Registry
                                 5-6

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                        TABLE 5-1 (.Continued)
Source lists used
                                              Number ot
                                              chemicals
                                              included
19.  General List of Problem Substances,
     Environmental Contaminants Committee,
     Ottawa, Ontario, Canada, 1977
                                                  160
  Main
selection
criteria
                                                             E, T,  0
                                                              E & T
                                                              T & 0
10.   Suspected Mutagens;  A Subfile of NIOSH       100
     Registry

11.   Suspected Teratogens; A Subfile of the       200
     NIOSH Registry

12.   Department of Health Education and Wei-   21,453
     fare, National Institute for Occupa-
     tional Safety and Health,  Registry of
     Toxic Effects of Chemical  Substances,
     1976

13.   The Ecological Impact of Synthetic             9
     Organic Compounds on Estuarine Eco-
     systems, September 1976, EPA-1600/
     3-76-075

14.   Threshold Limit Values for Chemical          570
     Substances and Physical Agents in the
     Workroom Environment with  Intended
     Changes for 1976, American Conference
     of Government Industrial Hygienists

15.   National Occupational Hazard Survey        7,000
     (1972-1974)/National Institute for
     Occupational Safety and Health

16.   Chemicals Being Tested for Carcino-          372
     genicity by the Bioassay Program DCCP,
     National Cancer Institute, 1977

17.   EPA, Office of Toxic Substances List         162
     of Priority Toxic Chemicals, 1977

18.   A Study of Industrial Data on Candidate      650
     Chemicals for Testing, EPA Contract
     #68-01-4109, November 1976,  Stanford
     Research Institute
                                                              T & 0
                                                            0,  T, & P
  T & P
                                 5-7

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                        TABLE 5-1 (Concluded)
                                              Number of       Main
Other lists used for reference,                chemicals     selection
but not used as source lists	included	criteria

1.   Research Project to Gather  and Analyze     3,200         T & P
     Data and Information on Chemicals that
     Impact Man and the Environment, National
     Institute of Health, National Cancer
     Institute/Stanford Research Institute

2.   Other Potential Modifiers of the Strato-      41         E & P
     sphere, 1975, National Institute of
     Environmental Health Sciences/Stanford
     Research Institute

3.   EPA/Office of Research and  Development,       140           P
     Chemical Production, 1975
KEY:  T = Toxicity
      P = Production/Use
      0 = Occupational Exposure
      E = Environmental Persistence
*U.S. Environmental Protection Agency,  1978.
                                 5-8

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begin to occur.  For example, chlorinated aromatics become more toxic




in the presence of various solvents (Battelle Pacific Northwest




Laboratories, 1973).  Antagonism is the opposite of synergism and




involves two or more materials acting together to create a combined




effect which is less than the aum of their individual effects or to




raise the threshold level at which effects begin to occur.




     Complex formation in the waste stream involves the forming of a




chemical bond between a metal ion and a complexing agent, e.g.,




organic compounds.  This complex formation affects the solubilities




and reactions of the materials involved.  For example, the formation




of water soluble metal-organic complexes with heavy metals may




increase the concentrations of these constituents in leachate to




levels far in excess of their normal solubilities, while the forma-




tion of water insoluble complexes may decrease the concentrations of




these constituents  in leachate.  Chemical reactions in the waste




stream involve two  or more materials combining to produce a poten-




tially hazardous material which is not originally present in the




waste or combining  to neutralize or eliminate potentially hazardous




materials which are present.




     The net effect of all such interactions can be to make waste




streams hazardous even if they do not contain any individually hazar-




dous materials and  to render other waste streams nonhazardous even if




they contain individually hazardous materials.
                                  5-9

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      In addition to such interactions,  the physical form of both the

waste stream and its constituents can also influence the hazardous

nature of the waste stream.  For example, beryllium dust is toxic at

relatively low levels when inhaled; however, beryllium in water poses

little ingestive threat at equivalent concentrations (U.S. Environ-

mental Protection Agency, 1976a).

      With regard to identifying hazardous wastes, a number of pre-

vious studies (Booz-Allen, Applied Research, Inc., 1973; Battelle

Pacific Northwest Laboratories, 1973; Ottinger et al., 1973; Arthur

D. Little, Inc., 1973) have attempted to delineate the specific char-

acteristics that make wastes hazardous,  to list waste stream consti-

tuents whose forms and quantities could  make waste streams hazardous,

and  to identify sources of these potentially hazardous waste stream

constituents.  A series of more recent studies (Arthur D. Little,

1976b; Battelle Columbus Laboratories, 1976; Calspan Corporation,

1977; Jacobs Engineering Company, 1976;  SCS Engineers, Inc., 1976;

Swain et  al., 1977; TRW, Inc., 1976; Versar, Inc., 1975, 1975a, 1976;

Wapora, Inc., 1975, 1977, 1977a) have attempted to identify poten-

tially hazardous waste streams generated within selected industries,

using a few preselected hazardous constituents as the basis for the

determination.*

     All  of the above studies have indicated numerous problems in

identifying and characterizing hazardous waste streams and hazardous

waste constituents due to considerable data limitations, both with
*This group constitutes a series of EPA contractor studies on indus-
  trial hazardous waste practices in selected manufacturing indus-
  tries.  For ease in referencing these studies, the entire set will
  henceforth be called the Industry Studies (1975-1978).
                                  5-10

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regard to determining what materials are actually hazardous and the

levels at which they are hazardous and with regard to determining

what materials are present in different waste streams and the concen-

trations and interactions of the various constituents.  Furthermore,

the different studies have used different definitions of hazardous

wastes and hazardous material.  Therefore, the types and sources of

wastes identified as hazardous have varied among the studies and,  in

some cases, may be discrepant with the regulatory definition under

Subtitle C.  Detailed descriptions of the waste streams considered in

the Industry Studies are presented in Appendix C.  Table 5-2 lists

some of the general types of hazardous waste constituents most fre-

quently identified in the various studies.

     5.1.2  Sources of Hazardous Waste.  Waste is generated as a

byproduct of nearly every activity of man.  Sources of hazardous

waste generation can be broadly grouped into four categories:

     •  Manufacturing processes;
     •  End use activities;
     •  Finished products becoming unusable, unneeded, or unwanted;
     •  Spills of hazardous, nonwaste materials during transport.

     5.1.2.1  Manufacturing Processes.  Manufacturing processes

generate a wide variety of potentially hazardous waste streams and

waste stream constituents.  The types of hazardous wastes generated

by different manufacturing processes are characterized based upon the

findings of the Industry Studies (1975-1978).  These studies identi-

fied potentially hazardous waste streams within each of the following

thirteen manufacturing industries:


                                 5-11

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                         TABLE 5-2

    EXAMPLES OF GENERAL TYPES OF POTENTIALLY HAZARDOUS
                    WASTE CONSTITUENTS

Acids
Caustics
Cyanides
Dyes
Explosives
Fluorides
Heavy metals and their compounds
Organics
  - Oils
  - Phenols
  - Polynuclear aromatics
  - Other organic compounds and organic residues
Paints
Pesticides
Radioactive materials
Solvents
                             5-12

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        Textiles;
        Inorganic  chemicals;
        Pharmaceuticals;
        Paint and  allied  products and contract solvent reclaiming;
        Organic chemicals,  pesticides,  and explosives;
        Petroleum  refining;
        Petroleum  re-refining;
        Leather tanning and  finishing;
        Metal smelting and  refining;
        Electroplating and  metal finishing;
        Special machinery manufacturing;
        Electronic components manufacturing;
        Storage and primary batteries.

     Table 5-3 contains examples of the potentially hazardous waste

streams and waste  stream constituents generated by each of these

manufacturing industries.  Potentially hazardous wastes from manu-

facturing processes very seldom consist of pure materials; the wastes

usually consist of a mixture of materials from one part of the

process which are  then combined with  other mixtures of wastes from

other parts of the process.   A detailed description of each poten-

tially hazardous waste stream from each industry and an enumeration

of specific, potentially hazardous constituents within the waste

stream appears in Appendix C.

     It should be  noted that no one individual facility within any  of

these industries generates  all of the potentially hazardous waste

streams and waste  stream constituents shown in Table 5-3.  It is also

not meant to be implied that all waste streams and waste stream con-

stituents identified as potentially hazardous in Table 5-3 would

necessarily be considered hazardous under the Subtitle C regulations.
                                 5-13

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                             TABLE 5-3

        EXAMPLES OF POTENTIALLY HAZARDOUS WASTE STREAMS FROM
                 SELECTED MANUFACTURING INDUSTRIES
Manufacturing
  industry
 Potentially hazardous
     waste stream
 Potentially hazardous
     constituents
Textiles*
  (SIC 22)
Wastewater treatment
sludge

Discarded dye and
chemical containers

Solvents and still
bottoms
Heavy metals, dyestuffs,
chlorinated organic s,
other residual organics
Residual dyestuffs and
residual chemicals
Solvents and organic
residues
Inorganic
  chemicalst
  (SIC 281)
Wastewater treatment
sludges
Heavy metals, fluorides,
cyanides, pigments
                 Solids
                          Heavy metals, cyanides,
                          radioactive materials
Pharma-
  ceuticals-f
  (SIC 2831,
  2833, 2834)
Waste solvents
Still bottoms, t«r»,
and muds

Solids
Organic solvents
Organic residue*

Heavy metals, contaminated
high inert content wastes,
active ingredients
Paint and
  allied
  products §
  (SIC 285)
Raw material containers


Water treatment sludges
Solids

Waste products
                 Wash solvents and still
                 bottoms
Heavy metals, organic and
inorganic pigments, sol-
vents, additives

Heavy metals
Heavy metals

Heavy metals, solvents,
pigments, additives,
fungicides

Organic and inorganic
solvents, pigments,
organic residues
                                5-14

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                        TABLE 5-3 (Continued)
 Manu facturing
   industry
 Potentially hazardous
     waste stream
 Potentially hazardous
     constituents
Leather
  tanning and
  finishing§§
  (SIC 3111)
Fleshings

Trimmings and shavings

Buffing dust

Finishing residues


Wastewater treatment
sludges
Heavy metals
Heavy metals

Heavy metals

Heavy metals, organic
solvents

Heavy metals
Metal smelting
  and
  refining ***
  (SIC 33)
Sludges



Slurries

Dusts

Slag

Waste ammonia liquor

Waste pickle liquor
Heavy metals, fluorides,
cyanides, oils, phenols,
grease

Heavy metals

Heavy metals

Heavy metals

Phenols, cyanides

Heavy metals, acids
Electroplating
  and metal
  finishingttt
  (SIC 3471)
Wastewater treatment
sludges


Process preparation
wastes

Miscellaneous process
solids
                  Degreaser sludges
Heavy metals, cyanides,
acid and alkaline cleaners,
solvents, oils, grease

Heavy metals, lubricants,
buffing compounds

Process chemicals, heavy
metals, acid and alkaline
cleaners, plating salts,
organic additives, sol-
vents, cyanides, paints

Heavy metals, oils, grease,
buffing compounds, organic
solvents, paint pigments,
abrasives
                                 5-15

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                       TABLE  5-3  (Continued)
 Manufacturing
   industry
                  Potentially hazardous
                      waste stream
                          Potentially hazardous
                              constituents
Special
  machinery
  manufacturing'' ' '
  (SIC 355 and
  347)
                 Heat treating wastes
                  Electroplating wastes
                  Machining wastes
                  Coating wastes
                         Heavy metals, cyanides,
                         oils, additives, organic
                         solvents,  acid and alka-
                         line cleaners, organic
                         residues
                         Heavy metals, cyanides
                         organic solvents, acid
                         and alkaline cleaners,
                         oils, grease, scale
                         Oils, organic solvents,
                         heavy metals

                         Paints, solvents, acid
                         and alkaline cleaners
Electronic
  components
  (SIC 367)
            §§§
Wastewater treatment
sludges
Solvents and still
bottoms

Waste oils

Paint wastes

Metal scrap
Heavy metals, fluorides


Organic solvents, organic
residues, heavy metals,
oils,
Oils, heavy metals,
additives
Heavy metals, oils, sol-
vents, fungicides, resins

Heavy metals
Storage and pri-  Wastewater  treatment
  mary            sludges
 batteries****
  ,„__ „,„,   .    Rejected  and  scrap
  (SIC 3691 and
  3692)           battenes
                                           Heavy metals, electro-
                                           lytic solutions
                                           Heavy metals
                                 5-16

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                       TABLE 5-3  (Continued)
 Manufacturing
   industry
 Potentially hazardous
     waste stream
 Potentially hazardous
     constituents
Organic
  chemicals
  pesticides and
  explosives **
  (SIC 286, 2879
  2892)	
Petroleum
  refining tt
  (SIC 2911)
Liquid heavy ends
still bottoms
sludges
waste products
solids
semi-solids
See Appendix D.3.5 for
specifics
Tank bottoms
                  Process sludges
                  Filter clays
                  Wastewater treatment
                  sludges


                  Fines
Oil, phenols, polynuclear
aromatics, other organics
heavy metals

Oil, phenols, ammonia
salts, polynuclear
aromatics, other organics,
heavy metals, acids
Oil, phenols, polynuclear
aromatics, ammonia salts,
other organics, heavy
metals

Phenols, ammonia salts,
heavy metals, runoff
constituents

Phenols, ammonia salts,
heavy metals
Petroleum
  re-refining++
  (SIC 2992)
Sludges
                  Spent clay
                  Process water
Acids, caustics, heavy
metals, ammonia, cresol,
oils, polymers,  other
polar compounds,
asphaltenes
Oil, heavy metals,
polymers, other  polar
compounds

Heavy metals, oils,
polymers, other  polar
compounds, phenols,
sulfur compounds
                                 5-17

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                       TABLE 5-3 (Concluded )
*
 Versar, Inc., 1976

fVersar, Inc., 1975


 Arthur D. Little Inc., 1976
§
 Wapora, Inc., 1975
j^
  TRW, Inc. , 1976

  Jacobs Engineering Company, 1976

#
  Swain et.al. , 1977
§ §
  SCS Engineers Inc., 1976
***
   Calspan Corporation, 1977
ttt
   Battelle Columbus Laboratories, 1976
   Wapora, Inc., 1977
§§§
   Wapora, Inc., 1977a
****
    Versar, Inc., 1975a
                               5-18

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     5.1.2.2  End Use Activities.  Activities which involve the end

use of finished products generate four basic categories of poten-

tially hazardous wastes:

     •  Product containers with residual product;
     •  Spills of hazardous products;
     •  Used products containing hazardous materials;
     •  Residuals from product consumption.

     End use generators of potentially hazardous wastes include, but

are not limited to, households*, governmental agencies, utilities,

agricultural activities, service industries, construction activities,

wholesale and retail trade, and transportation activities.  For the

most part, the potentially hazardous waste streams from these end use

activities tend to be more homogeneous than those from manufacturing

activities.

     Different end use activities use or consume practically every

product manufactured, produced, or imported into the U.S.  As

previously discussed, many of these products are by themselves poten-

tially hazardous.  Such products usually are packaged  or container-

ized for delivery to the point of end use.  Following  this end use,

the product container or packaging is normally discarded as a waste.

These waste containers or packaging materials usually  contain resid-

ual amounts of the potentially hazardous product and,  thus, may

represent a potentially hazardous waste.  These residues may include

pesticides, paints, cleaning fluids, and oils.  Packaging materials
*Households are specifically exempted from regulation under Sub-
 title C.

                                 5-19

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containing pesticide residuals,  for example,  may be found in wastes




from households,  agriculture,  garden stores,  golf courses, and




organizations engaged in right-of-way maintenance such as govern-




mental agencies,  utilities,  and  railroads.




     End use activities may also result in spills of potentially




hazardous products.  Following cleanup, the spilled product is




usually discarded as a waste.   Both this waste product and the




materials which are used to clean up the spill represent potentially




hazardous wastes.




     A third category of potentially hazardous wastes from end use




activities are used, broken, or  nonfunctioning products that are




hazardous themselves or that contain potentially hazardous materials.




These products may include waste automotive oils and solvents; used




dry cleaning fluids; spent batteries and fluorescent tubes containing




mercury; nonfunctioning capacitors and transformers containing poly-




chlorinated biphenyls (PCB's); nonfunctioning smoke detectors con-




taining radioactive materials; and waste construction materials




containing asbestos.




     End use activities which consume part or all of a product may




produce residual materials which are potentially hazardous.  For




example, coal-fired power plants generate coal ash which may be a




potentially hazardous waste, depending upon its constituents.




     5.1.2.3  Unusable, Unneeded, or Unwanted Products.  Unusable,




unneeded, or unwanted finished products that are potentially hazar-




dous represent a further source of potentially hazardous wastes.




                                 5-20

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Finished products may become unusable, unneeded, or unwanted for a




variety of reasons, including governmental regulations prohibiting




the use of specific products; product recalls due to contamination,




decomposition, deficiencies, or other problems; and products becoming




obsolete or overage.  For example, a number of pesticides, such as




DDT, chlordane, and mirex have had their registrations canceled for




some or all of their uses, and the existing supplies have become




potentially hazardous wastes.  Recalled products that have become




potentially hazardous wastes include contaminated or decomposed lots




of Pharmaceuticals.  Obsolete military munitions, such as initiating




agents, propellants, pyrotechnics, explosives, and riot control




agents, represent a third type of finished product that has become a




potentially hazardous waste.




     5.1.2.4  Transportation-Related Spills of Hazardous Materials




That Are Not Wastes.  Spills of hazardous materials that are not




wastes occasionally occur during transport and are a further source




of hazardous waste. When many hazardous materials particularly




liquids, volatile materials, and fine materials, are spilled, this




material is likely to become a waste and would be subject to regula-




tion under Subtitle C if it exhibits the properties in Appendix B,




Subpart A.  Spills can also occur during the manufacture or end use




of any product or material; however, such spills are included in




existing waste streams from such activities and do not represent an




additional source of potentially hazardous wastes.
                                 5-21

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      Major sources of transportation-related spills of hazardous

materials include rail, truck,  barge,  and pipeline transport and

transfer operations.  Table 5-4 shows  examples of potentially

hazardous materials that have been spilled in recent years.

5.2  Characterization of Hazardous Waste Transport

     The basic role of the hazardous waste transport industry is to

move hazardous wastes from the point of generation to off-site

facilities for purposes of storage, treatment, and/or disposal.

Hazardous waste transport includes intrastate, interstate, and inter-

national movements by highway:  rail, air, pipelines, and waterway.

     Three hazardous waste transport industry segments have been

identified in a study by Arthur D. Little, Inc. (1978a).  These seg-

ments are as follows:  generator/transporter, hazardous waste manage-

ment facility/transporter, and for-hire transporter.

     •  Generator/transporters are hazardous waste generators who
        function as private carriers by self-hauling hazardous wastes
        off-site to hazardous waste management facilities (transport
        by this segment is invariably  by truck).

     •  Hazardous waste management facility/transporters are opera-
        tors of hazardous waste management facilities who also
        function as contract or private carriers in providing trans-
        portation from generators to storage, treatment, or disposal
        facilities (transport by this  segment is invariably by
        truck).

     •  For-hire transporters are common and contract carriers who
        transport hazardous wastes (and other property as well) but
        who do not generate, treat, store, or dispose of such wastes
        (transport by this segment is  primarily by truck, but
        includes rail, waterway, and air).
                                 5-22

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                            TABLE 5-4

      EXAMPLES OF SPILLS OF POTENTIALLY HAZARDOUS MATERIALS*
Acids
  arsenic
  chlorosulfuric
  hydrochloric
  muriatic
  nitric
  phosphoric
  su If uric
Acrylonitrile
Ammonia solution
Ammonium nitrate
Anhydrous ammonia
Batteries and electrolytic fluid
Benzene
Butyl cellusolve
Caustic soda
Chlorine
Coolants
Copper sulfate
Creosote
Cyanide
Cyclohexylamine
Denatured ethyl alcohol
Dyes
Ethylene diamine
Ethylene glycol
Ferric chloride
Ferrous sulfate
Formaldehyde
Gasoline
Hexane
Ink
Kepone
Latex
Lead oxide
Linseed oil
Methyl alcohol
Methyl bromide
Naptha
Nitrofur izone
Oils
  crude
  cutting
  fuel
  hydraulic
  lube
  turbine
Paint
Paint thinner
PCB
P enta ch or o phe no 1
Perchloroethylene
Pesticides
Phenol
Phosdrin
Phosphorus
Potassium hydroxide
Resins
Seed corn (containing captan)
Sodium hydroxide
Solvents
Toluene-
Tr imethylam ine
* U.S. Department of Transportation, Materials Transportation
Bureau, 1976; personal communication, J.E. Aho, Minnesota
Pollution Control Agency, 1977; State of Ohio, 1974; personal
communication, J. Dobbins, Ohio Environmental Protection Agency,
1977;  Illinois EPA Emergency Action Center, 1977.
                               5-23

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     According to the Arthur D.  Little,  Inc. study, neither the




number of firms within each industry segment nor in the industry as a




whole is known, nor is the rate  of firms entering or leaving the




industry.  Furthermore, the quantity of  hazardous wastes transported




annually by the industry is unknown, as  is the distribution of waste




transport by mode or by industry segment.




     To illustrate the magnitude of hazardous wastes being trans-




ported off-site, based upon the  waste quantities in Chapter 6 and the




average off-site disposal factor in Table  5-10,  there is on the order




of 8 to 10 million metric tons of potentially hazardous manufacturing




wastes currently being transported off-site on an annual basis.




Table 5-5 presents a qualitative estimate  of the relative amounts of




hazardous wastes moved by mode and by industry segment.  The vast ma-




jority of such wastes are transported by highway with a small amount




being transported by rail and even smaller amounts being moved by




waterway.  Appendix E contains a detailed  description of the three




industry segments, based on the  Arthur D.  Little, Inc. (1978a) study.




The following reiterates pertinent portions of that description.




     5.2.1  Generator/Transporter.  According to Arthur D. Little,




Inc., reliable data are extremely limited  with regard to generator/




transporters; most of the information available on generator/trans-




porters is contained in the Industry Studies (1975-1978) prepared for




EPA.  About 3.5 percent of the plants inventoried in the Industry
                                5-24

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                            TABLE 5-5

         RELATIVE AMOUNT OF HAZARDOUS WASTES TRANSPORTED
              OFF-SITE BY MODE AND INDUSTRY SEGMENT*

Mode
Air
Rail
Highway
Waterway
Pipeline
Generator/
transporter
None
None
Very small
None
Negligible
Hazardous waste
management facility/
transporter
None
None
Large
None
Negligible
For-hire
transporter
Negligible
Small
Large
Very small
None

Modified from Arthur D. Little, Inc., 1978a.
                               5-25

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Studies transported their own wastes off-site,  and less than three




percent of the total quantity of waste hauled off-site was trans-




ported by the generator.




     The tendency to self-haul is industry dependent.  For example,




waste oil re-refiners self-haul over 50 percent of their wastes going




off-site while the melting,  smelting,  and refining industry does




little or no self-hauling.  The limited data available suggest that




self-hauling firms tend to be the smaller firms in an industry and




tend to be located in rural areas where contractor services are not




available.  Wastes transported by self-hauling firms are usually




transported a distance of under 10 miles, and often are moved no more




than 1 to 2 miles.




     Wastes that are hauled by generators are typically transported




as generated, without treatment, and are usually taken either to a




site owned and operated by the company and dedicated specifically to




its wastes, or to a general-purpose municipal or private landfill




that also handles municipal wastes.




     Generators, at least the major generators, do keep records of




how much waste is shipped, who carried it, and where it went.  Such




records are usually kept for a period of at least seven years.  Self-




haulers transporting to a company-owned site typically prepare a sum-




mary report monthly on the quantity of material hauled (Arthur D.




Little, Inc., 1978a).
                                 5-26

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     5.2.2  Hazardous Waste Management Facility/Transporters.  In




1977,  there were approximately 110 hazardous waste management facili-




ties in the U.S. (Straus, 1977).  An estimated 50 to 67 percent of




these facilities also transport hazardous wastes (Arthur D. Little,




Inc., 1978a; Straus, 1977).




     Transportation activities of the hazardous waste management/




transporters tend to be interstate; 64 percent of the facilities con-




tacted in the Arthur D. Little, Inc. study have interstate transpor-




tation capabilities.  Further, 56 percent have locations in more than




one state or receive waste materials from out of state.  Those haz-




ardous waste management facility/transporters who operate intrastate




tend to serve a relatively small geographical area or section of the




state.  Those who operate interstate generally operate within one re-




gion rather than within several regions.  The portion of wastes han-




dled by each type of operation is not known, nor is the portion of




the interstate operator's business that is done outside his home




state.




     Nearly all the facilities contacted keep records which contain




limited information about the quantity, source, waste type, and




delivery point for each transport/disposal job.  These records are in




various forms and include:  billing records (invoices), shipping




documents or bills of lading, purchase orders or job tickets, and




self initiated or state required manifests.  Usually these documents




are filed together and are retained for several years, based in part
                                 5-27

-------
upon requirements by the Interstate Commerce Commission (3-year




retention), Internal Revenue (7-year retention),  state tax depart-




ment, and other state agencies (Arthur D. Little, Inc., 1978a).




     5.2.3  For-Hire Transporters.  For-hire transporters include




common and contract carriers that transport hazardous waste by high-




way, rail, air, pipeline,  and waterway.




     5.2.3.1  Common and Contract Highway Carriers.  According to




Arthur D. Little, Inc., very few data are available with regard to




common and contract highway carriers involved in the transport of




hazardous waste, and as a result, it was not possible even to develop




a representative sample for study purposes.  Thus, the information




reported by the study should only be considered as preliminary.




     About one-half of the for-hire transporters contacted do not




transport any hazardous waste across state borders.  Others indicated




that anywhere from 80 to 100 percent of their hazardous waste trans-




port is interstate.  Within those states which required permits for




transporting hazardous wastes, the transporters usually indicated




statewide service.  Smaller transporters tended to see states requir-




ing permits as the practical limit of their service radius.  Exclud-




ing the national common carriers who provided no estimates, transpor-




ters indicated trip distances ranging from 25 to 150 miles, with most




companies responding at 50 miles.  One common carrier indicated that




500 to 600 mile trips were normal.  However, the above figure may not




be representative of the entire industry.  Quantities of hazardous
                                5-28

-------
waste being transported interstate or intrastate could not be identi-




fied, nor, in most cases, could the total quantity of hazardous waste




being transported by individual companies.




     Very sketchy information is available on the nature of the




wastes transported.  Most of the firms contacted handled primarily




liquid wastes.  General transporters who handled the following types




of waste were identified:  liquids/solids/sludges, waste oils, sol-




vents for recycle, general hazardous trash, paint wastes, hydrocar-




bons, chlorine, acids, cyanide wastes, caustic wastes, hydrogen




fluoride, cleaning solutions, and radioactive wastes.  Though some




general transporters specialize in a particular waste, such as waste




oil  or spent acid, most handle many kinds of hazardous wastes.




     All of the firms contacted keep records.  The most common forms




for  recordkeeping are the bill of lading and the weigh ticket.  The




transporters indicated that records were retained for at least five




or seven years as a result of state, Internal Revenue Service, and/or




Interstate Commerce Commission regulations in addition to general




management practice.




     5.2.3.2  Rail Transport.  As common carriers under the ICC, the




railroads must accept all cargo tended to them that is properly pack-




aged and labeled.  One of the most important aspects of the practices




and  regulations in the transport of hazardous waste by railroad is




that the railroad does not directly handle the hazardous material as




such, but only transports rail cars ready for delivery.  The  shipper




must provide to the railroad the sealed or closed containers  of the





                                  5-29

-------
hazardous material or waste and certify in the bill of lading that




the shipment conforms to regulations.




     A small amount of hazardous wastes is transported by rail as




compared to highway transport.   Most rail shipments are by tank car.




Only a limited number of disposal sites accept hazardous waste by




rail, and only a small portion  of the total hazardous waste trans-




ported by rail is believed to go to such disposal sites; most of it




is believed to go to reclamation and recovery facilities.  For exam-




ple, nearly all spent sulfuric  acid and petroleum refinery treating




wastes transported by rail go to recyclers who have rail sidings on




their own property.




     The relevant documents for the transport of hazardous waste con-




sist of the bill of lading and  the waybill.  The bill of lading is




prepared by the shipper, the waybill by the railroad.  For hazardous




materials, a copy of the certified bill of lading must be kept on




file by the original carrier for at least three years, in accordance




with ICC regulations (Arthur D. Little, Inc., 1978a).




     5.2.3.3  Air Transport.  The amount of hazardous waste trans-




ported by air is very small, possibly on the order of several tons




per year.  Small amounts of waste acids, flammable metal shavings,




radioactive materials, and laboratory samples of hazardous wastes




have been identified as being shipped by air.




     The existing DOT and FAA regulations require that copies of




shipping papers, prepared by the shipper, must be carried onboard.
                                 5-30

-------
The originating carrier must then maintain a copy of the shipping
                                                                    •

paper for 90 days.  In addition to shipping papers, the air carrier


is to prepare a manifest for the total cargo of the shipment.


     5.2.3.4  Pipeline Transport.  Off-site pipeline transport of


hazardous waste is extremely limited.  On a national level, there are


no major pipelines for transporting wastes; the commercial pipeline


industry is almost entirely devoted to the transport of fuel


products.  Waste transport by pipeline is generally limited to a few


concentrated industrial areas in the U.S.  A number of isolated cases


of hazardous waste transport by private, not for-hire, pipeline were


identified by the Arthur D. Little, Inc. studyi


     5.2.3.5  Waterway Transport.  The quantity of hazardous waste


transported by barge on inland waters appears to be small relative to


highway transport.  No vessels other than barges are known to carry


hazardous wastes.  Shipments of hazardous waste move primarily on the


Gulf Intracoastal Waterway-Mississippi River System in tank barges


with a capacity range of 1,200 to 1,500 tons.  A typical one-way trip


may be on the order of 1,000 or more miles.  Most often, the waste


transported includes spent acids, spent caustics, and waste glycol.


The wastes are generally in liquid bulk form with a water content up


to 90 percent and normally are transported to resource recovery


facilities.
                                5-31

-------
     The bill of lading,  weigh ticket,  and shipping manifest papers

are the commonly used forms for recordkeeping.  The companies contac-

ted by Arthur D. Little,  Inc. stated that records are retained in

current files for 5 to 7  years because  of legal requirements as well

as administrative procedures.  In addition to the above forms, ship-

ping papers and a dangerous cargo manifest must accompany shipments

of hazardous packaged cargo and solids  in bulk.

5.3  Characterization of  Hazardous Waste Storage, Treatment, and
     Disposal

     Hazardous waste storage, treatment, and disposal currently oc-

curs both on and off the  site of generation.  When transported off-

site as described in Section 5.2, the hazardous waste goes to such

locations as dumps, hazardous waste management facilities, resource

recovery facilities, and  municipal and private landfills and incin-

erators.  This section presents a summary of typical hazardous waste

management practices; Appendix D provides a more detailed discussion.

     5.3.1  Storage.  Hazardous wastes are often stored before treat-

ment or disposal, both on-site by the generator and off-site by

treatment and disposal facilities.  In the case of off-site treatment

or disposal, the wastes are usually also stored by the generator un-

til economically transportable loads are accumulated.  Hazardous

wastes are typically stored in ponds, lagoons, basins, drums, tanks,

piles on the ground, tank trucks, and dumpsters (see Appendices D and

J).  Table 5-6 shows examples of storage practices in selected indus-

tries.


                                 5-32

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                                          TABLE 5-6

                     EXAMPLES OF STORAGE PRACTICES IN SELECTED INDUSTRIES*
    Industry
       Type of waste
Storage mode
Storage time
Pesticides
Pharmaceuticals
Paints and
  coatings
Rinsed and crushed 5-gallon
metal insecticide containers

Radiocative material
Emulsion sludge from tank
washings - 18% solids,
82% water
Bin
Packed in drums
with vermiculite

Holding tank
 3 months
 3-4 months
 1-2 days
Electroplating and
metal finishing
Waste oil re-
refining
Waste oil re-
refining
Plating sludges
Spent liquid PCB's
Tarry sludge
Oil soaked in earth
(filter medium)
Holding tank
55-gallon drums
Holding tank
Contractor sup-
plied containers
4 hours
5-10 days
3-7 days
5 days

*Arthur D. Little, Inc., 1978a.

-------
     Engineered storage is sometimes used when there is no safe




method of treating or disposing a particular hazardous waste.  Under




such circumstances the waste is containerized and buried or otherwise




stored until technologies are developed for treating or disposing it.




Wastes that have been subject to engineered storage in recent years




are discussed in Appendix D.




       5.3.2  Treatment.  The treatment of hazardous wastes is gen-




erally directed toward separating the hazardous components from the




non-hazardous components of the hazardous waste stream, concentrating




the hazardous wastes, rendering the wastes less hazardous, reducing




the volume of wastes requiring ultimate disposal, and/or recovering




materials or energy from the waste.  There are four basic types of




methods  typically used for the treatment of hazardous wastes:  physi-




cal treatment, chemical treatment, biological treatment, and thermal




treatment.




     Physical treatment consists of non-chemical means to remove sol-




uble and suspended constituents from aqueous waste streams and to




concentrate various constituents of the waste stream.  Chemical




treatment involves alteration of the molecular structure of waste




constituents so as to render the wastes less hazardous or to




separate specific constituents of the waste stream.  Biological




treatment involves the use of microorganisms to remove or degrade




organic materials present in wastewater streams by adsorption and




direct metabolism.  Thermal treatment employs heat to destroy







                                5-34

-------
hazardous wastes, to render the waste less hazardous, and to recover




materials and energy from the waste.  Appendix D describes typical




processes used for each of the four treatment methods and the types




of wastes amenable to treatment by each method.




     Treatment of hazardous wastes is at times limited to the appli-




cation of just one of the methods discussed above.  However, in many




instances, especially in the case of wastewater treatment or re-




source recovery, several of the methods are used in the course of




treating hazardous wastes.




     The treatment of hazardous wastes using the above methods does




not typically constitute the ultimate disposal 'of the waste.  Treat-




ment generally produces a residual (e.g., sludge, ash, still bottom,




concentrated waste) which may be hazardous and which is typically




disposed using the methods discussed in Section 5.3.3.  For example,




many of the various physical, chemical, and biological treatment




methods are used as part of primary, secondary, or tertiary waste-




water treatment and produce a sludge which is potentially hazardous




(see Table 5-3) and which requires disposal.




     Data are not available to estimate the portion of hazardous




wastes that are annually treated prior to disposal, nor to estimate




the portion treated using each of the four basic types of treatment




methods.




     5.3.3  Disposal.  Disposal of hazardous waste involves the dis-




charge, deposit, injection, dumping, spilling, leaking, or placing of




any of the waste into or on any land or water so that such waste or





                                  5-35

-------
any constituent thereof may enter the environment or be emitted into




the air or discharged into any waters,  including groundwaters.  Meth-




ods typically used for ultimate disposal of hazardous wastes include:




open dumping, landfilling, landfarming, lagooning (surface impound-




ment), incineration, deep-well injection,  discharge to municipal




sewer systems, surface discharge to rivers and streams, ocean dump-




ing, road application, and detonation.   In addition, engineered




storage is used in some instances.   Appendix D describes each of




these disposal methods and the types of wastes amenable to disposal




by each method.




     Data are not available to estimate the portion of all hazardous




wastes disposed annually by each method.  However, Table 5-7 provides




an estimate of the portion of hazardous wastes from 14 manufacturing




industries disposed annually by each method during the period from




1973 to 1975.  The table also provides an estimate of the portion of




wastes disposed by each method that were disposed in environmentally




adequate and  inadequate manners.  Less than 10 percent of these




manufacturing hazardous wastes are estimated to have been treated/




disposed in an environmentally adequate manner.




     5.3.4  Typical Management Practices for Hazardous Industrial




Waste.  Typical hazardous waste management practices are charac-




terized for thirteen manufacturing industries in Appendix D.  The




manufacturing industries discussed are as follows:  electronic




components manufacturing; electroplating and metal finishing;
                                  5-36

-------
                                                TABLE 5-7

                           ESTIMATED PORTION OF HAZARDOUS WASTES FROM FOURTEEN
                         MANUFACTURING INDUSTRIES DISPOSED BY METHOD, 1973-1975
Ln
I

Disposal method
Surface impoundment
Dump 1
Landfill )
Incineration
Deep-well injection
Land spread ing
Road application
Sewer
Othert
Weighted average

Percent disposed
by method^
48 §
33
151
2
0.3
< 0.1
< 0.1
2
-
Percent
environmentally
adequate
< 0.1
7
37
-
-
-
-
N/Ali
10
Percent
environmentally
inadequate
> 99.9
93
63
100
100
100
100
N/AU
90
      *0ffice of Solid Waste, unpublished data.
      tPrimarily resource recovery
      ±Due to rounding, total exceeds 100%.
      §An unknown portion of the wastes handled by this method were ultimately disposed by other
      methods, primarily landfilling and dumping.
      IINot available.

-------
inorganic chemicals;  leather tanning and finishing; metal smelting




and refining; organic chemicals,  pesticides,  and explosives; paint




and allied products and contract  solvent reclaiming; petroleum




refining; petroleum re-refining;  pharmaceuticals;  special machinery




manufacturing; storage and primary batteries; and textiles.




     Tables 5-8 and 5-9 indicate  the estimated portion of potentially




hazardous wastes treated/disposed by various  methods in four manufac-




turing industries for which data  are available.  Table 5-8 shows




estimated on-site treatment/disposal.  Table  5-9 shows estimated off-




site treatment/disposal.  Some of the methods listed, e.g., inciner-




ation and recovery^ may generate  hazardous residuals requiring




further disposal.  Data are not available as  to the disposal of such




residuals.  It should be noted that the data  in Tables 5-8 and 5—9




are based upon limited surveys of the industries and, according to




the various authors,  may not be entirely typical of the industry as a




whole.




     For the thirteen manufacturing industries, treatment of poten-




tially hazardous wastes is, for the most part, limited to dewatering




and some neutralization of hazardous sludges  from wastewater treat-




ment, segregation of some waste streams or waste stream components,




and incineration of specific wastes or waste  streams.  Where recla-




mation and recovery is practiced, it is typically Limited to on-site




recovery of solvents, metals, oil, products,  plating solutions, and




energy and to off-site recovery of solvents,  metals, and oil.
                                5-38

-------
                                                             TABLE 5-8

                                  ESTIMATED PERCENTAGE OF TOTAL HAZARDOUS WASTES TREATED/DISPOSED
                                    ON-SITE BY VARIOUS METHODS FOR SELECTED INDUSTRIES - 1973*
Ln

LO
                                                                   Treatment/disposal method
                                                                  (percentage of total generated)
Industry
Organic chemicalst,§
Pharmaceuticals^, 11
Petroleum refining^,**
Petroleum re-ref iningt ,tt
Biological
treatment /lagoon
< 1
2
18
-
Deep-well Incineration Landfarm
2 70 #
37
1-8
-
Landfill
15
-
17
12
Recovery Application
8
-
-
& n

         * 1975 data used  for petroleum  re-refining  industry.
         t Based upon dry  weight  of hazardous waste  stream.
         + Based upon wet  weight  of hazardous waste  stream.
         S TRW, Inc., 1976.
         It Arthur D. Little, Inc., 1976h.
         **Jacobs Engineering Company, 1976.
         ttSwain et.al., 1977.
         i+Small amount, data not available.

-------
                                                 TABLE 5-9

                     ESTIMATED PERCENTAGE OF TOTAL HAZARDOUS WASTES TREATED/DISPOSED
                       OFF-SITE BY VARIOUS METHODS FOR SELECTED INDUSTRIES - 1973*
•t*
o
                                                    Treatment/disposal method
                                                  (percentage of total generated)
                            Incineration    Lagoon    Landfill    Recovery    Road application

       Organic chemical          2            -           4          -
         chemicalt.§
Pharmaceuticals^,!!

Petroleum
  refining^,**

Petroleum
  re-refiningt,tt
                                51
                                              21
 9

34


70
                                                                                    6**
        * 1975 data used for petroleum re-refining industry!
        t Based upon dry weight of hazardous waste stream.
        4= Based upon weight of hazardous waste stream
        § TRW, Inc., 1976.
        II Arthur D. Little, Inc., 1976b.  "
        **Jacobs Engineering Company, 1976
        ttSwain et.al., 1977.
        ^Includes small amount treated/disposed on-site.

-------
     Table 5-10 presents the estimated portion of hazardous wastes

treated/disposed on-site and off-site and the portion going to re-

clamation for each of the thirteen manufacturing industries.  A

weighted average of about 82 percent of the hazardous wastes are

treated/disposed on-site and about 15 percent is transported off-site

for treatment/disposal.  It should be noted that these figures for

on-site and off-site treatment/disposal must be considered slight

overestimates since they include a very small amount of hazardous

wastes that are recovered on-site or off-site, but for which separate

data are not available.  It is estimated that such wastes comprise

less than two percent of the total hazardous wastes.  The weighted

average of wastes for which resource recovery is practiced is thus

estimated to be three to five percent.

     Three levels of treatment/disposal were identified for the thir-

teen manufacturing industries by the Industry Studies (1975-1978).

These levels are as follows:

     •  Level I - the level of treatment/disposal used commonly by
        the industry for a particular waste;

     •  Level II - the best technology employed commercially by the
        industry for a particular waste;

     •  Level III - the technology necessary for protection of
        health and the environment.

It was possible (though unusual) for Level I to be the same as Level

II for a given waste.  Levels II and III were frequently reported as

being the same (Battelle Columbus Laboratories, 1978).
                                 5-41

-------
                           TABLE  5-10

    ESTIMATED  PERCENTAGE  OF HAZARDOUS WASTES  TREATED/DISPOSED
               OR RECOVERED ON-SITE AND  OFF-SITE*
Industry
Electronic components
manuf acturing§
Electroplating and
metal finish ing §
Inorganic chemicalt
Leather tanning and
finishing^:
Metal smelting and
refining^
Organic chemical st
Paint and allied
products^
Petroleum refineryt
Petroleum re-refinery§
Pharmaceutical st
Special machinery
manufacturing §
Storage and primary
batteriest
Textiles^
Weighted average
Treated/
disposed
on-site
13
19
85-90
10

98
87
5
44
12
39
10
35
49
82
Treated/
disposed
off-site
66
81 11
10-15
90

2
5
90
56
76
60
90
65
51
15
Recycled/
reclaimed
21
*™
**
**

tt
8
5
*t
12
1
tt
tt
**
3§§
* Industry studies, 1975-1978.
t 1973 data.
$ 1974 data.
§ 1975 data.
f Includes 45% sent to sanitary sewer systems
**Data not available, small amount reclaimed included in off-site data.
ttData not available, small amount reclaimed included in on-site data.
rjrjData not available, small smount reclaimed included in off-site and
on-site data.
§§Small additional amount included in off-site and on-site data.
                                5-42

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      Table 5-11 provides, for four manufacturing industries for

which data are available, estimates of the portion of hazardous

wastes generated by each—industry that was subject to Level I,  II, or

III treatment/disposal during the year of assessment.  Data are not

available to provide similar estimates for the other nine manufac-

turing industries.  For the industries listed in Table 5-11, between

70 and 85 percent of the hazardous wastes were treated/disposed using

Level I technologies (i.e., one that is not the best technology com-

mercially available nor adequate for protection of health and

environment) and between zero and 5 percent were treated/disposed

using Level III technologies.

     5.3.5  Hazardous Waste Management Service Industry.  The hazard-

ous waste management service industry is engaged in the off-site

storage, treatment, disposal, and reprocessing/recovery of hazardous

wastes.  The industry operates independently of hazardous waste gen-

erators; however, as a service to generators, over half the firms in

the industry transport hazardous wastes to their facilities from gen-

erators (Arthur D. Little, Inc., 1978a).

     In 1975 there were approximately 95 firms active in the indus-

try, operating about 110 hazardous waste management facilities.  The

industry's facilities are concentrated in industrial areas, with

nearly 60 percent of both the facilities and the overall process

capacity  located in EPA Regions II, V, and IX.  Figure 5-1 shows
 Process capacity consists of the throughput capability for hand-
 ling hazardous wastes and includes storage, treatment, disposal,
 and recovery capacity.
                                5-43

-------
                             TABLE 5-11
      ESTIMATED PERCENTAGE OF HAZARDOUS WASTES TREATED/DISPOSED
                BY LEVEL I, II, OR III TECHNOLOGY FOR
                  SELECTED MANUFACTURING INDUSTRIES
        Industry                Level I     Level II      Level III
 Leather tanning and              85          10             5
   finishing*", 11
 Paint and allied                 70          25             5
   prod'uctst,H
 Petroleum re-refining^,**        78          22
 Special machinery                70          30
   manufacturing §,**

 *SCS Engineers, Inc., 1976.
 tWapora Inc., 1975.
 :£Swain et.al., 1977.
 §Wapora, Inc., 1977.
 U1974 data.
**1975 data.
                                5-44

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U1
I
                      j NORTH DAKOTA
                      I
                      'SOUTH DAKOTA"
             I MINNESOTA

             \    !Xi^«^^~W
                 r^7  vrirM
                 i      h7s<~—^  vs  j V-Y  r .2
                       !       !   ^ fead^  >-- .asess^.
	f..-.  _    !
  JNW MSOOO  T±_.^ OKLAHOMA m
  I     [TEXAS ~   9
                I
                'I

              —j_:—-\y	j
                        FIGURE 5-1

           GEOGRAPHIC DISTRIBUTION OF HAZARDOUS WASTE MANAGEMENT FACILITIES
    Source: Straus, 1977.

-------
the geographic distributions of the facilities.  Total employment

within the industry was approximately 2,000 persons in 1975 (Foster

D. Snell, Inc., 1976).

     At the end of 1974, the process capacity for the industry as a

whole was nearly 7.3 million metric tons per year, with about 53 per-

cent of the overall process capacity being utilized on an annual

basis  (Foster D. Snell, Inc., 1976).  Since some hazardous wastes

require several process stages (e.g., treatment and disposal), the

total quantity of wastes that can be handled is somewhat less than

the overall process capacity.  The Foster D. Snell, Inc. study es-

timated that about 5.3 million metric tons of the overall process

capacity might be considered environmentally adequate.   The study

further estimated that the overall process capacity would expand to

8.2 million metric tons at the end of 1977, with about 6.2 million

metric tons being considered environmentally adequate."1"  Table 5-12

shows, for selected processes, the daily capacity available in 1974

by EPA Region.
  According to the Foster D. Snell, Inc. study, the low capacity
  utilization is the result of poor regulations and/or poor enforce-
  ment of regulations applicable to hazardous waste treatment/
  disposal.

  The Foster D. Snell, Inc. study considered incineration, secure
  landfills, chemical treatment, biological treatment, and resource
  recovery as environmentally adequate processes.  Some unknown
  portion of these processes, however, might not be considered
  environmentally adequate under the Subtitle C regulations.
                                 5-46

-------
                                       TABLE 5-12

                          CAPACITY OF SELECTED HAZARDOUS WASTE    .,
                      MANAGEMENT SERVICE INDUSTRY PROCESSES - 1974
Process capacity
(thousands of gallons per 24 hour day)
EPA
region
I
II
III
IV
i
$ V
VI
VII
VIII
IX
X
Total
Number of
facilities
6
18
9
7
27
10
8
1
19
5
110*
Chemical
treatment
46
71
265
20
1,530
70
250
t
57
28
2, 337*

Incineration
4
153
35
44
361
60
5
t
14
-
676*
Secure Deep well
landfill injection
4
239
15
46
230 100
135 795
66
t -t
639
325
1,714* 895*
Resource
recovery
9
57
35
315
230
50
tt
400
405
1.481*
*Foster D. Snell, Inc., 1976.
tData are not available.
*Does not include EPA Region VIII.

-------
      The hazardous waste management service industry generally


groups the wastes it handles into five categories:  metals/metal


finishing; paints/solvents/coatings; organics;  petroleum; and


inorganics.  Table 5-13 lists, examples of the types of hazardous


wastes handled within each category and typical treatment/disposal


methods employed.


     5.3.6  State Data on On-Site and Off-Site  Disposal.  Very few


states have at this time accumulated sufficient data to estimate the
                      *

portion of hazardous wastes generated within the state that are being


disposed on-site and off-site of the generation facility.  Table 5-14


presents, for eight states and one EPA Region,  recent estimates of


the portion of each state's hazardous industrial wastes that are


disposed on-site and off-site, the portion of the wastes whose


disposal whereabouts is unknown, and the portion of the wastes being


reclaimed.  Table 5-14 also indicates the estimated portion of each


state's hazardous industrial wastes upon which  the disposal and


recovery estimates are based.  The fate of the  remainder of the


hazardous industrial wastes in these states is  not known.


     Except for Texas and Illinois, the data in Table 5-14 were


collected as part of studies to assess existing hazardous waste


management practices in the state and to determine needed changes in


the state's regulatory approach to hazardous waste management.  The


data for Texas and Illinois were reported to these states as required


under their hazardous waste regulations.  Comparable data for dispo-


sal and recovery practices either prior to or after enactment


                                5-48

-------
                            TABLE 5-13

           TYPES OF HAZARDOUS WASTES HANDLED AND TYPICAL
                TREATMENT/DISPOSAL METHODS FOR THE
                HAZARDOUS WASTE MANAGEMENT INDUSTRY
 Market category
       Typical
 treatment/disposal
       methods
    Types of
    hazardous
 wastes handled
Metals/metal
  finishing
Paints/solvents/
  coatings
Neutralization
Chemical treatment
Sanitary landfill
Secure landfill
Deep well injection
Ocean disposal

Incineration
Chemical treatment
Sanitary landfill
Secure landfill
Acid solutions
Metals containing
  sludges
Organics
Solvents
Organics
Petroleum
Inorganics
Incineration
Biological treatment
Chemical treatment
Sanitary landfill
Secure landfill

Incineration
Deep well injection

Chemical treatment
Ocean dumping
Secure landfill
Pesticides
Biologicals
Rubber
Plastics
Oily wastes
Aqueous
  solutions of
  salts, metals,etc.
 Foster D. Snell, Inc., 1976
                                5-49

-------
                     TABLE 5-14

 ESTIMATED PERCENTAGE OF HAZARDOUS INDUSTRIAL WASTES
DISPOSED BY LOCATION OR RECLAIMED FOR SELECTED STATES




Ul
Ln
O







State

Flo r Ida*, §
niinoisir

Kansas**
Marylandtt,^
Massachusetts §§
MinnesotaHU
Region X***
Rhode Islandttt
Texasttt

Percent of
wastes Included
in estimate*

NA§§§
100

23
NA
100
9-16
NA
NA
100
Disposal location
On- site

85
50

39
12
-
65
63
1
36
Off -site

8
18

49
33
14
25
22
81
9
Othert
Discharges Deep-well
injection
7 §
21 - 10

5
51 #
65 10
3
_
- 14
20 - 31
Reclaimed

-
_

7
4
11
7
15
4
4

-------
                                           TABLE 5-14 (Concluded)
        *  This is the estimated portion of the state's total,  hazardous,
        industrial wastes upon which the disposal and recovery  percentages are
        based
        t  Other includes disposal by methods which are not regulated under
        Subtitle C.  These include discharges to municipal sewer systems,  surface
        discharges under National Pollution Discharge Elimination System (NPDES),
        and deep-well injection.
        :£  Carter et.al., 1977.
        §  These data have been modified to eliminate a large volume of wastewater
        containing a small amount of hazardous wastes that is discharge to
        mun ic ipal s ewer s.
i        11  Personal communication, S. Miller, 1978.
H       ** State of Kansas, 1977.
        tt State of Maryland, 1977.
        rjrj: These data have been modified to eliminate a large volume of wastewater
        containing a small amount of hazardous wastes that is discharge  to
        municipal sewers and to streams.
        §§ Fennelly et.al., 1976.  If waste automotive oil is included, the
        percentages are as follows:  on-site - 0%, off-site - 8%, unknown - 68%,
        discharged - 6%, reclaimed - 18%.
        HH Battelle Pacific Northwest, 1977.
        ***Stiradley et.al., 1975.  Region X includes Alaska, Idaho, Oregon, and
        Washington.   .
        tttRhode Island Department of Health, 1977.
        ££{:State of Texas, 1976.
        §§§NA means not available.

-------
of the state's current hazardous waste legislation (or equivalent




legislation) are not available.   Differences in the portion of wastes




disposed on-site and off-site in the various states are due primarily




to factors such as differences in types of industries and wastes gen-




erated by these industries, availability of allowable on-site and




off-site disposal locations, and specific state regulations and




enforcement policies.




5.4  Resource Conservation and Recovery




     RCRA defines resource conservation as the reduction of the




amounts of solid waste that are generated, the reduction of overall




resource consumption, and  the utilization of recovered resources.




Resource recovery is defined as the recovery of material or energy




from solid waste.




     This section describes typical methods used for resource conser-




vation and  recovery  and the typical operations specializing in the




recovery of hazardous wastes.  Estimates of the extent to which




hazardous wastes  are presently being recovered or recycled are pre-




sented, along with examples of the potential for increasing the




recovery and  recycling of  hazardous wastes.  Factors which have




tended to constrain  the recovery and recycling of hazardous wastes




are summarized.




     5.4.1  Resource Conservation and  Recovery Methods and Opera-




tions .  There are three basic procedures  for recovering materials  and




energy from potentially hazardous wastes:   separation, material




conversion, and energy conversion (Sittig,  1975).




                                 5-52

-------
     Separation involves the removal of specific waste constituents




using the physical and chemical treatment methods discussed in Appen-




dix D.  Material conversion involves the transformation of waste con-




stituents from a form which is not acceptable for recovery or reuse




to one that is acceptable, using the chemical treatment methods dis-




cussed in Appendix D; the waste may not be in an acceptable form due




to such factors as its toxicity or its inability to yield to separa-




tion.  Energy conversion involves the direct utilization of the waste




as an energy source either through combustion using the incineration




methods discussed in Appendix D or by using the waste to drive a




chemical process.




     Operations that specialize in the recovery of hazardous wastes




can be categorized as follows:  solvent reclaimers, mercury reproces-




sors, metal reprocessors, petroleum rerefineries, industrial waste




information clearinghouses, and industrial waste exchanges (Straus,




1977).  Of these resource recovery operations, the industrial waste




clearinghouses and exchanges would likely have the most direct bear-




ing on increasing the recovery of hazardous wastes.  These opera-




tions are described in Appendix G.




     Table 5-15 presents the nationwide distribution of these types




of recovery operations.  A total of 131 solvent reclaimers, eight




mercury reprocessors, seven metal reprocessors, 28 petroleum




re-refiners, eight industrial waste information clearinghouses, and




one industrial waste exchange have been identified.  The states with
                                5-53

-------
                   TABLE  5-15
DISTRIBUTION OF HAZARDOUS  WASTE RECOVERY OPERATIONS
              IN THE UNITED  STATES*











State
Alabama
Alaska
Arizona
Arkansas
California

Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
en
M
QJ
s
rH
U
0}

4-J
Q)
,3

&
i

4

11

1
1
1
2
3


14
5
7
4
2


» 2
2
9


4

1


10

6
1

0]










S




2







1







1








1

1


nj
AJ
0)
E
M 3
M O
en 01

O C!
O O
M C

Pi












1
1















1

4





0
M
§£
•H
^H QJ
0 M
M 1
01 ^l
&J




4



3
1


1
1

1





1
2
1





1

1



a
4J CO
CO 01
3 J5 3

nj rt so
•H B C
4J O h
2 Hi 3
3 Ci 0)
T3 °H rH

H











^
M
i

a

NA

NA
1 Waste
Exchanj



1


1

1





e




NA









., one firm ocean
dumps



1




ane firm ocean
dumps

1






NA


NA

NA


NA
                      5-54

-------
                        TABLE 5-15  (Concluded)













State
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming


in
Q)
43
CD

O


4-1
g


O
CO
10

3
4

2
2

3
8



3

5

131
M
O
tn
to
0)
o

ex
Hi

d
u

01




1





1


_
ro
oJ
E
M
M P
M O
O V-i
VI 01
tn g
a T
o o
t-> C
o.
a;













Agent for ocean




8




7




to

QJ
C

r-l M
0 1
U 01
4-1 t->
QJ

1
1
1
2




1
3
1



QJ
iJ VJ
CO C M
Sod
•H O
1— 1 4-1 ,£
ra nj to
-H a c
•U O ^
vi n-i ro
d C Q)
-a -H --(
C! O
i—i








i
i


-going incineration ship


1

28




8









3
M
a
E
aj





NA


NA



NA


NA

NA

*Straus, 1977.
                                   5-55

-------
the greatest activity in this area are California,  with 17 reclaimers

and one industrial waste clearinghouse,  Illinois with 17 reclaimers

and one industrial waste exchange, New Jersey with  13 reclaimers, New


York with 13 reclaimers and one industrial waste clearinghouse, and

Texas with 12 reclaimers and one industrial waste clearinghouse


(Straus, 1977).

     5.4.2  Resource Recovery and Recycling Estimates.  This section

discusses the quantities of hazardous wastes currently being re-

covered and recycled and the potential for increasing the recovery


and recycling of hazardous wastes.

     5.4.2.1  Quantities Recovered and Recycled.  Extremely limited

data are available as to the extent to which resource recovery from

hazardous wastes currently occurs in the U.S.  The  available data

tend to be very industry and waste stream specific.  As discussed

below, the available data indicate that only a very small portion of

the total hazardous waste stream is subject to any  resource recovery,

probably less than 3 to 5 percent of all such wastes.  This recovery

rate is similar to, but slightly less than, that for post-consumer

municipal wastes.  In recent years between 8 and 10 percent of the

overall post-consumer municipal wastes have been recovered for re-

cycling, with waste paper accounting for over 85 percent, by weight,
                            *

of the material recovery (Office of Solid Waste, 1977b).  Section

5.4.3 discusses factors that have tended to limit the recycling and

recovery of all waste materials.
                                 5-56

-------
     Table 5-16 presents examples of hazardous waste recovery and re-




cycling practices for the manufacturing industries analyzed in the




Industry Studies (1975-1978).  Such practices are generally limited




to the recovery of solvents, oil, metals,  and energy and to some




recycling of off-specification and rejected products back into the




production process (see Appendix D for a more detailed discussion of




recovery and recycling practices).  For these industries, it is




estimated that on the order of 3 to 5 percent of the total hazardous




waste stream is annually subject to resource recovery (see Table




5-10).




     Table 5-14 shows, for eight states and one EPA Region, the




percentage of the industrial hazardous wastes that are estimated to




have been reclaimed in recent years.  These available data indicate




that four percent or less of the hazardous wastes are being reclaimed




in five of these states.  Only in Massachusetts and EPA Region X are




more than 10 percent of the hazardous wastes being reclaimed.




     The only specific hazardous waste components for which nation-




wide recovery data are available are waste oil and waste solvents.




Table 5-17 indicates sources of waste oil generation and uses of this




waste oil during 1972.  Over 51 percent of the waste oil is estimated




to have been recycled, with about 44 percent used as a fuel and about




8 percent re-refined to lube oil.




     Data are not available as to the total quantity of wastes sol-




vent generated annually; however, it is estimated that in 1974







                                 5-57

-------
                                               TABLE 5-16

                           EXAMPLES OF HAZARDOUS WASTE RECOVERY AND RECYCLING
                                    PRACTICES IN SELECTED INDUSTRIES*
          Industry
                             Hazardous waste stream
                                        Reclamation practice+
      Textiles (SIC 22)
                           Dye and chemical containers

                           Solvent and still bottoms
                                        Recycled

                                        Solvent recovery
01
I
Ul
00
Inorganic chemicals
    (SIC 281)
Mercury contaminated wastes

Chlorinated hydrocarbons


Chrome pigments production
Mercury recovery

Used inorganic chemicals
   manufacture

Metal recovery
      Pharmaceuticals
          (SIC 2831,  2833,
          and 2834)
                           Waste solvents
                                 Heavy metals
                                        Solvent recovery; energy
                                        recovery; production of
                                        low grade fuel

                                        Zinc and chromium recovery
      Paint and allied
          products  (SIC 285)
                           Discarded products and spills
                                        Recycled in lower grade
                                        products
                                 Waste wash solvents
                                                                   Solvent recovery

-------
                                               TABLE 5-16 (continued)
              Industry
     Hazardous waste stream
  Reclamation practicet
i
Ol
      Organic chemicals,       Heavy ends from mitrobenzene
         pesticides, and         production
         explosives (SIC 286,  Semisolid wastes from toluene
         2879, and 2892)         diisocynate production

                               Sludge from lead alkyls
                                 purification

                               Red water
                                       Energy recovery

                                       Energy recovery


                                       Lead recovery


                                       Recycled to kraft pulp mills
      Petroleum refining
         (SIC 2911)
Crude tank bottoms

API separator sludge

Dissolved air flotation float

Slop oil emulsion solids

Spent lime


FCC catalyst fines

Spent catalyst
Oil recovery

Oil recovery

Oil recovery

Oil recovery

Recycled to spent acid
  neutralization

Aluminum recovery

Metal recovery

-------
                                               TABLE 5-16 (continued)
              Industry
     Hazardous waste stream
  Reclamation practicet
      Leather tanning and
         finishing
         (SIC 3111)
Trimming and shavings
                               Finishing residues
Used in fertilizer, animal
  feed supplements, glue,
  leather articles

Solvent recovery
i
c^
o
      Metal smelting and
        refining (SIC 33)
Primary copper dusts

Primary copper slurries

Primary lead sludge

Primary zinc sludge

Primary aluminum potliners
  and pot skimmings

Iron and steel mill sludges

Iron and steel mill scales

Iron and steel pickle liquor
Metal recovery

Metal recovery

Metal recovery

Metal recovery

Cryolite recovery


Iron and tin recovery

Iron recovery

Acid regeneration
      Electroplating and
        metal finishing
        (SIC 3471)
Degreaser sludges
Solvent recovery

-------
                                                TABLE 5-16 (Concluded)
               Industry
                              Hazardous waste stream
  Reclamation practicet
       Special machinery
         manufacturing
         (SIC 355 and 357)
                         Machinery wastes



                         Electroplating wastes

                         Heat treating wastes
Solvent recovery; metal
  recovery; recovery and/or
  reuse of oils

Metal recovery

Solvent recovery, metal
  recovery
Ln
I
Electronics components   Solvents
  manufacturing
  (SIC 367)              Oils
                                Metal scraps
Solvent recovery

Recovery and/or reuse metal
  recovery
  3
Metal recovery
       Storage and primary
         batteries
         (SIC 3691 and 3692)
                         Wastewater treatment sludge

                         Rejected and scrap cells
Metal recovery

Metal recovery
       * Industry studies  (1975-78)
       t On-site and/or off-site reclamation practices

-------
                             TABLE 5-17

                  WASTE OIL SOURCES AND USES, 1972*
                                              Quantity
         Source and uses                  (million gallons)

Consumption of lube oils

   Automotive                                  1,100

   Industrial and, aviation                       700

   Other (includes government)                   400

     Total consumption                         2,200



Generation of waste lube oils

   Automotive                                    600

   Industrial and aviation                       400

   Other (includes government)                   100

     Total waste oil generation                1,100



Current uses of waste oil

   Fuel                                          480

   Re-refined                                     90

   Road oil and asphalt                          200

   Fate unknown                                  340t
     Total                                     1>110
*  U.S. Environmental Protection Agency, 1974
t  Includes 30 million gallons of re-refining wastes
                                 5-62

-------
contract solvent reprocessing operations reclaimed about 270,000




metric tons of waste organic solvents and that an unknown amount of




solvents was also recovered on-site by generators (Wapora, Inc.,




1975).  Two major categories of solvents are reprocessed.  One




category is halogenated solvents, such as methylene chloride, tri-




chloroethylene,  perchloroethylene, and 1,1,1-trichloroethane, which




result primarily from degreasing and metal cleaning operations.  The




other category is non-halogenated solvents which includes aliphatic




hydrocarbons, aromatic and naphthenic hydrocarbons, alcohols,




ketones, and esters.  These waste solvents are generated by the




chemical process industry, metal cleanings and coatings operations,




industrial painting operations, printing operations, solvent manu-




facture and distribution, and paint manufacture (Wapora, Inc., 1975).




     5.4.2.2  Potential for Recovery and Recycling of Hazardous




Wastes.  This section discusses the potential for increased resource




recovery and recycling of hazardous wastes.   Any evaluation of the




potential recoverability of hazardous wastes is complicated by the




diverse nature of both the wastes themselves and the processes for




recovering or for recycling the waste material.  Because of this




extreme diversity, each waste stream must be considered separately




within each industry, and often on a plant-by-plant basis, in order




to obtain an accurate picture of the recovery or recycling potential




for that type of waste.  In addition, the processes required for




recovery or recycling must also be considered to determine their
                                  5-63

-------
economic viability.  The following examples are presented to illus-

trate the potential for increased recovery and recycling.  Appendix F

presents several other examples of specific waste streams that have a

potential to be recoverable.

      Arthur D. Little, Inc.  (1976) examined the potential for trans-

ferring selected wastes from generators to other facilities that

could use the waste as a feedstock.*  Individual hazardous waste

streams identified as having a relatively high potential for recovery

or recycling are those which contain:   solvents, alkalies, concentra-

ted acids, catalysts, oils, combustibles, and high concentrations of

recoverable metals.  Based upon these potentially recoverable consti-

tuents, Table 5-18 presents estimates of the types and quantities of

selected hazardous wastes that might have a potential for being

recovered or recycled.  It should be noted that the quantities in

Table 5-18 are meant only as an order-of-magnitude estimate; the

listed wastes were selected by Arthur D. Little, Inc. based solely

upon the properties previously described, without regard to the eco-

nomic or technical feasibility of their recovery; the quantities

represent the estimated total amount of such wastes generated, not

necessarily the amount that could realistically be expected to be

recovered or recycled.  The listed wastes represent about 25 percent

of the hazardous waste stream from the industries included in the

Industry Studies and about 3 percent of the total solid waste stream
 The hazardous wastes examined were those identified in the
 Industry Studies (1975-1978).

                                 5-64

-------
                                          TABLE 5-18

           ESTIMATED MAGNITUDE OF HAZARDOUS WASTES FROM SELECTED INDUSTRIES THAT
                         MAY BE POTENTIALLY RECOVERABLE OR RECYCLABLE*
       Industry
         Waste
  Potential value
  for recovery or
  recycling
   Quantity as
g enera t ed (me tr ic
   tons/year)
Pharmaceuti cals
  (SIC 283)
Paint and allied
  products
  (SIC 2851)

Organic chemicals
  pesticides,
  explosives (SIC
  286, 2879, & 2892)

Petroleum refining
  (SIC 2911)
Leather tanning
  and finishing
  (SIC 3111)
Halogenated solvents,
tars, still bottoms,
carbon filter aid

Spoiled paint or
lacquer batches and
wash solvents

Chlorinated hydrocarbon
liquid heavy ends
Other still bottoms
Coke fines
FCC catalyst
fines

Sludges and trimmings
Degreasing solvents;
cleaning or paint
solvents; fuel

Solvent recovery,
upgrading
Degreasing solvents

Fuel
Fuel
Catalyst recovery
Leather composites
     160,000



      14,000



     247,000

   1,600,000
      13,000
     117,000
      12,000

-------
                                          TABLE 5-18 (Concluded)
       Industry
         Waste
  Potential value
  for recovery or
  recycling
   Quantity as
generated (metric
   tons/year)
Primary metals
   (SIC 331)

Electroplating
   (SIC 3471)

Special machinery
  manufacturing
   (SIC 355 & 357)

Primary batteries
   (SIC 3692)
     Total
Still pickle liquor
Begreaser sludges
6% sulfuric acid with
metals

Solvent recovery
Solvents, metals, oils,    Recovery and reclamation
acids, and alkalis
Reject cells

Wastewater treatment
sludge
Metal recovery (17-70%
Zn, Hg, Pb, Cd)
Metal recovery (40% Cr)
    3,500,000


      105,000


       73,000



        1,200

           25


    5,800,000
* Modified from Arthur D. Little, Inc., 1976.

-------
from these industries (Arthur D. Little, Inc., 1976).  It should also




be noted that an unknown portion of these wastes is currently being




recovered (see Appendix D).




     Table 5-19 shows, for selected industrial processes in SIC Code




28 and selected organic chemical wastes from these processes, poten-




tial uses to which the wastes might be recycled.  Again any such use




would be very dependent upon technical, economic, and environmental




considerations (Arthur D. Little, Inc., 1976).




     Reynolds, Smith and Hills (1977) examined the potential for




energy recovery from selected wastes from eight industries.  The




industries were chosen based upon the following criteria:  heating




value of their waste, annual volume of hazardous waste generated,




relative toxicity of hazardous components, and ability to use




recovered energy.  Table 5-20 summarizes the industries selected and




the potentially hazardous waste streams studied.  Table 5-21 shows




the total quantity of process related wastes (hazardous and non-




hazardous) from each industry, the total quantity of hazardous




process wastes included in the study, the estimated average heating




value of the waste streams studies, the maximum energy estimated to




be annually recoverable from the waste streams studied, and the esti-




mated annual fuel savings based upon this maximum energy recovery.




It should be noted that in determining the maximum recoverable




energy, it was assumed that the entire waste stream would be incin-




erated.  Of the waste streams studied, those of the paints and







                                 5-67

-------
                                                       TABLE 5-19

                                  GENERATION AND  POTENTIAL USE OF  ORGANIC CHEMICAL WASTES*
                              Wastes  Generated
                                                                                                Potential Uses
STtT
        Product manufactured/process
                                                    Waste constituents
2869    Ethylene Glycol

2865    Phenol


2865    Phenol/Cumene
Glycols and water

Phenol, cresol, off-spec In water
Acetophenone, phenol, cumyl phenol
evaporation residue
 2865     Iso and Tere-phthalic acids     Phthalic acid, toluic acid, benzole acid,
                                        trimellitic acid, aldehydes, acetic acid,
                                        Bi, Mn, Co-still bottoms
 2821    Acrylic acid
                                        Aqueous acrylic acid and hydroquinone
 2865    Phthalic anhydride/xylene       Pitralic anhydride/maleic anhydride tar
 2865    Maleic  anhydride

 2879    Carbaryl

 2869    Aromatic amines

 2843    Surface active agents


 2821    SANpolymers


 2869    Ethylene dichloride (EDC)


 2869    Hexachlorocyclobutadiene


 2869    Perchloroethylene (Perc)


 2833    Pharmaceuticals





 2869    Sulfonic Acids

 2822    Urethane


 2869    Tetraethylorthosilicate



 2833    Penicillin


 2833    Alkaloids


 2865    Nitrobenzene


 2869    Ethyl  chloride

 2869    Epichlorohydrin


 2821    Methyl methacrylate

 2869    Dicumyl peroxide
Maleic anhydride tars

Naphthol residues

Long  chain amines  (solid)

C-8-C-18 fatty alkyl acids, nitriles,
amines

Styrene and acrylonitrile
 EDC,  tri-  and  tetra-chloroethanes;
 sludge

 Chlorinated  toluenes,  pentanes,
 benzenes

 Perc., CC1;;  chlorinated hydrocarbons-
 liquid still bottoms

 Various solvent wastes-chlorobenzene,
 toluene, methanol,  methylene  dichlo-
 ride, tetrachloroethane
 Emulsified oils and sulfones

 Mixed polyols and phosphate esters
 Tetraethyl orthosilicate, iodine, alcohol,
 Genusolu D
 Butyl acetate and butyl alcohol


 Chlorinated solvents


 Benzene, nitrobenzene stripping


 Ethyl chloride, chloroethanes,

 trichloroethylene, etc.   liquid still
 bottoms

 Hydroquinone; polymer heavy ends

 Organic perioxides
Solvent reclamation

Wood preservative for boat or
fence post manufacture

Wood preservative
                                                                                      Film forming in paint manufacture
Acrylic emulsion paints

Polymeric binder for  shingles
wood chips, grinding  wheels,
retractory bricks,  etc.

Polymeric binder

Dye intermediate

Ore Benefication

Ore Benefication
Film  forming
Molding  Compounds

Dry cleaning
Degreasing  of metal parts

Degreasing  solvents
 Dry cleaning solvents
 Degreasing solvents

 Solvent recovery
 Degreasing
 Cleaning
 Paints

 Leather lubricant and treatment

 Molding compound
 Filler for wood, wallboard

 Stone or concrete preservation
 Mortar
 Paints

 Solvent reclamation  (done
 routinely)

 Degreasing
 Reclamation

 Paint Formulation
 Degreasing

 Paint remover solvents

 Degreasing
 Paper board binder

 Paint industry-film  formers
  *Arthur D.  Little,  Inc.,  1976.
                                                          5-68

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                            TABLE 5-20

           INDUSTRIES AND HAZARDOUS WASTE TYPES STUDIED
                  FOR ENERGY RECOVERY POTENTIAL*
        Industry
   Types of hazardous wastes
           considered
Organic chemicals
      SIC 286
Distillation column bottom sludges,
evaporator residues, filter
residues
Plastics
      SIC 282
Distillation column bottoms
Pharmaceuticals
      SIC 283
Petroleum refining
      SIC 291

Tires and inner tubes
      SIC 301

Fabricated rubber products
      SIC 306

Paints and allied coatings
      SIC 285

Solvent reclaiming
Waste solvents (halogenated and
non-halogenated,  organic chemical
residues, contaminated inerts

Tank bottoms, API separator sludges,
DAP sludges, slop oil emissions

Floor sweepings,  air pollution
equipment dust

Air pollution equipment dust, floor
sweepings

Solvent recovery still bottoms,
waste solvents

Distillation column bottoms
*Reynolds, Smith and Hills, 1977.
                                5-69

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                                                         TABLE 5-21

                               ESTIMATED ANNUAL WASTE QUANTITIES AND TOTAL RECOVERABLE ENERGY*

Total process
related wastes
Industry (10^ metric
(SIC code) tons) (1977)t
'•Wet
Organic Chemicals 10900%
(286)
Plastics (282) 2335
Petroleum Refining 1504
(291)
Tires & Inner 236
Tubes (301)
l-n Fabricated Rubber 210
^, Products (306)
O (Dry Process Only)
Paints & Allied 450
Coatings (285)
Solvent Reclaiming 72
(No SIC Code)
Pharmaceuticals 19105
(283)
Total hazardous Average heating Maximum total Annual fuel
wastes considered value** recoverable savings (10^
(103 metric tons) energy (1977) equivalent
barrels of oil)
Wet KCal/Kg Btu/lb KCalxlO1^ BtuxlO12
3430 3900 7040 8.05 31.9 6700

n u u u n n
758 6010 10820 2.73 10.8 2275

223 7220 13000 0.97 3.8 808

210 7410 13340 0.93 3.7 778


14 8300 14940 0.11 0.44 88

72 6940 12500 0.30 1.20 253

66 6180 11120 0.25 1.0 204


*  Reynolds, Smith and Hills, 1977
t  Includes hazardous and non-hazardous wastes
+  This includes those streams which are diluted for hydraulic transport for deep well injection or lagooning.
Practically all wastes streams (ca.98%) are dry as discharged from the process.
§  This contains large quantities of mycellium which are non-hazardous.
'  Not determinable
** For purpose of comparison, bituminous coal has a higher heating value of  approximately 6,200  KCal/kg  (12,000 Btu/lb)

-------
allied coatings industry (.SIC 285) had the highest estimated heating




value—8,300 KCal/kg (14,940 Btu/lb)—and those of the organic chemi-




cals industry (SIC 286) had the lowest estimated heating value—




3,900 KCal/kg (7,040 Btu/lb).  These heating values can be compared




with an approximate higher heating value of 6,700 KCal/kg (12,000




Btu/lb) for bituminous coal.




     The Reynolds, Smith and Hills study found that the organic




chemicals, plastic, petroleum refining, pharmaceuticals, paint, and




solvent reclaiming industries have considerable potential for




incineration with heat recovery.  The study found that the tire and




fabricated rubber industries do not have a high potential due to the




fact that hazardous wastes from these industries are primarily floor




sweepings with a large ash content.




     5.4.3  Constraints to Resource Conservation and Recovery.  There




are several basic factors that have tended to limit the application




of resource conservation and recovery measures to wastes in general




and to hazardous wastes in particular.  These factors include:




national policies favoring the use of virgin materials, economics,




technological considerations, and institutional constraints.




     The Federal government has historically played a major role in




stimulating natural resource development.  Special tax laws relating




to mining and forestry and Federal subsidies for raw materials




exploration, research, and development all have favored virgin raw
                                 5-71

-------
materials and encouraged a materials-intensive economy.  In addition,

a number of laws and agency policies have tended to discriminate

against recovered or recycled materials and waste reduction measures

(Office of Solid Waste, 1977b).  Similarly, most state laws have

either tended to favor the use of virgin materials or not to have

encouraged the recovery and recycling of waste materials.

      Economic factors affecting resource recovery and recycling

include both the cost of recovery and the cost of the transportation

required to bring the wastes where needed, as well as the relation-

ship of recovery costs to disposal costs and to costs of virgin

materials.  As indicated above, tax laws and subsidy policies have

tended to favor the use of virgin materials.  Furthermore, due to the

nature of most wastes, recovery costs have tended to be high compared

both to disposal costs under existing practices and to virgin

material costs, thus also favoring the use of virgin materials (see

Appendix F).  Historically, environmental costs from inadequate

hazardous waste disposal practices have tended to be borne by society

in general or by third parties rather than by the waste generators

whose disposal practices have caused damages; as a result, such costs
                                 /
have not generally been included in the economic decision process.

Furthermore, the very limited data on the location and quantities of

wastes available for recycling and on the specific characteristics

of the diverse waste materials have tended to limit markets for waste

recycling (Office of Solid Waste, 1977b; Arthur D. Little, Inc.,

1976; Sittig, 1975).

                                 5-72

-------
      Development of technologies for the recovery and for the reuse




or recycling of waste materials have tended to lag behind the




development of technologies for utilizing virgin materials due to the




factors discussed above.  Technologies for recovering and reusing




many waste materials are still in a conceptual stage or have not been




commerically demonstrated (Versar, Inc., 1977; Arthur D. Little,




Inc., 1976; Sittig, 1975).




     Institution factors include the general lack of industrial,




institutional, and public acceptance or encouragement of resource




recovery practices.  For example, some generators hesitate to release




wastes to others for recycling purposes for fear either of possible




injury to their reputation for quality or of legal liability for




incidents associated with the transfer (Arthur D. Little, Inc.,




1976).  Federal agency policies and standards have also tended to




discriminate against the use of recycled materials (Office of Solid




Waste, 1977b).  There have also been few formalized programs by




industry to encourage resource recovery, especially with regard to




potentially hazardous wastes.  The National Ash Association, for




example, has a formalized program and has estimated that ash re-




cycling has risen to 20 percent from 12.3 percent in a recent 10-year




period (National Ash Association, 1977).
                                 5-73

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6.0  QUANTITIES OF HAZARDOUS WASTES GENERATED AND CONTROLLED

     This chapter presents estimates of the quantities of hazardous

wastes currently generated by both manufacturing and non-manufactur-

ing sectors, estimates of hazardous waste generation in 1980 and

1984, discussions of the magnitude of hazardous spills, and a discus-

sion of the amount of wastes currently under various aspects of state

control.

6.1  Current Hazardous Waste Generation

     Estimation of the amount of hazardous wastes which is currently

generated in the United States is complicated by a lack of comprehen-

sive data.  Data which are available are usually based on surveys

performed by many different groups with difference objectives who

consequently used varying definitions for hazardous wastes.

     6.1.1  Manufacturing Industries.  For the purpose of estimating

hazardous waste generation by the manufacturing industries at the

national level, data from the nine most consistent sources were used

to calculate generation factors for industry groups categorized by

the 2-digit SIC (Standard Industrial Classification) codes 20, 22-39.

The sources used represented data from eight states and one EPA

region:

     •  Illinois (Personal communication, S. Miller, Ohio Environ-
        mental Protection Agency, 1977)
        Kansas (State of Kansas, 1977)
        Maryland (State of Maryland, 1977 and 1977a)
        Massachusetts (Fennelly, et al., 1976)
        Minnesota (Battelle, Pacific Northwest, 1977)
        Mississippi (State of Mississippi, 1975)
                                 6-1

-------
     •  Texas  (.Personal  communication,  J.  Carmichael,  Texas
        Division of Solid Waste  Management,  1977)
     •  Washington (State of  Washington,  1974)
     •  EPA Region X (Stradley,  et  al.,  1975)

     The generation factors were derived based  on  the  assumption that

the ratio of the amount  of hazardous  wastes  generated  by an industry

to the number of employees in that  industry  is  approximately constant

among all establishments in each industry (as  grouped  at the 2-digit

SIC code level).  The methodology used  is presented in Appendix H,

with a description of each data  source,  and  a  discussion of the

assumptions and limitations.   As discussed in Appendix H, inaccura-

cies may have resulted from inconsistencies  in  data sources, possible

biases in the coverage of industries, errors introduced in the state

surveys, over-generalization  of  industry groups, and from variations

in actual hazardous waste generation per employee  within industry

groups.  Nevertheless, it is  felt that  the computed generation fac-

tors represent the best presently available  method of  estimating the

total quantities of hazardous wastes  generated  by  manufacturing

industries in the U.S.  The generation factors  were used with U.S.

census data (U.S. Department  of  Commerce, 1977) to estimate the

amounts of hazardous wastes  generated by each  industry in each

Federal region.  Table 6-1 summarizes the estimates by SIC code.

     Based on these estimates, the  manufacturing industries generated

approximately 47.5 million metric tons  of hazardous wastes during

1975.  Approximately 60 percent  of  this, or about  28.7 million metric

tons, was generated by industries in SIC code 28 (Chemicals and

                                 6-2

-------
                                                          SUMMARY OF HAZARDOUS WASTE GENERATED BY EPA REGION — 1975*
                                                                         (1000 metric tons per year)

Standard Industrial Classification
20 Food and kindred products
22 Textile mill products
23 Apparel and other textile products
24 Lumber and wood produces
25 Furniture and fixtures
26 Paper and allied products
27 Printing and publishing
28 Chemicals and allied products
29 Petroleum and coal products
30 Rubber and misc. plastics products
31 Leather and leather products
32 Stone, clay and glass products
33 Primary metal industries
34 Fabricated metal products
35 Machinery, except electrical
36 Electric and electronic equipment
37 Transportation equipment
38 Instruments and related products
39 Misc. manufacturing industries
TOTAL**
Percent of Total
	
ENVIRONMENTAL PROTECTION AGENCY REGION
I
10
10
7.0
4.0
9.5
290
9.0
1,060
25
20
130
65
140
140
370
20
65
10
40
2,440
5

II
25
10
30
3.0
20
350
20
5,290
95
25
95
160
290
170
450
30
55
15
55
7,190
15

III
30
15
20
7.0
25
290
15
3,600
85
20
70
210
870
180
400
20
60
5.5
20
5,940
13

IV
45
100
40
20
75
530
15
5,920
50
35
90
230
350
180
420
25
80
4.0
35
8,240
17

V
70
3.5
10
10
50
760
30
5,770
160
75
120
350
1,520
700
1,830
55
350
15
60
11,900
25

VI
10
2.5
10
8.0
15
200
8.0
3,270
330
15
35
120
190
150
350
10
60
2.0
15
4,810
10

VII
25
0.5
4.0
2.5
7.5
120
8.5
1,230
45
10
85
60
110
85
290
9.0
60
2.0
10
2,170
5

VIII
9.0
<0.5
1.0
2.0
1.5
10
3.0
170
30
2.0
8.5
35
75
20
80
1.5
10
1.5
6.0
470
1

IX
35
2.0
10
8.5
25
180
10
1,880
110
20
10
130
200
160
400
25
150
8.0
20
3,380
7

X
15
0.5
1.0
20
2.5
130
2.5
460
20
2.0
1.5
30
95
25
60
1.0
45
1.5
5.0
920
2


Total
290
140
130
80
240
2,870
130
28,700
950
220
640
1,390
3,830
1,800
4,650
200
940
65
270
47,500



of Total
0.5
0.5
0.5
<0.5
0.5
6
0.5
60
2
0.5
1.5
3
8
4
10
0.5
2
<0.5
0.5




Ranking
10
15
16
18
12
4
17
1
7
13
9
6
3
5
2
14
8
19
11


1 1
CT>
 I
U)
        *See individual tables on state contributions to hazardous waste for footnotes on data sources.

       **Totals may not balance due to rounding of numbers.

-------
Allied Products;.  The next largest generators were industries in SIC

codes 35 (Machinery,  except Electrical), 33 (Primary Metal Indus-

tries), and 26 (Paper and Allied Products), with about ten, eight,

and six percent of the total U.S. generation, respectively.

     Also indicated in Table 6-1, about 25 percent of the wastes are

generated in the six north-central states of EPA Region V, while the

eight  southeastern states of EPA Region IV account for about 17 per-

cent.  Application of the generation factors to individual state

employment  indicates  that seven states account for approximately half

of  the total U.S. generation.  These states are in alphabetical

order:*  California,  Illinois, New Jersey, New York, Ohio, Pennsyl-

vania,  and  Texas.  Following the national pattern, most (46 to 83

percent) of the  hazardous wastes generated in these five  states are

produced in SIC  code  28, with industries in SIC codes 35  and 33 rank-

 ing either  second or  third.  These three industry  groups  account  for

between 73  and 90 percent  of the hazardous wastes  generated in each

 of  the five states.

      6.1.2   Other Hazardous Wastes.  Besides  the manufacturing indus-

 tries, there are numerous  other  sources  of potentially hazardous

 wastes.  These include  non-industrial  waste  oils,  hospital wastes,
  Since the generation factor  approach  relies  to  a large  extent on
  averaging over large areas,  its  accuracy  decreases  when applied to
  smaller areas such as states.  Therefore,  individual  estimates of
  waste generation are not presented on a state-by-state  basis.
                                 6-4

-------
agricultural wastes, household wastes, military wastes, fly ash, oil
well brines and muds, cement kiln dusts, dredge spoils, and phosphate
slimes.  Additionally, administrative and other government agencies
often engage in activities such as research and demonstration proj-
ects and pest control, which produce significant amounts of hazardous
wastes.
     The degree of hazard associated with the above mentioned wastes
varies considerably, both among and within the different categories.
Data on the amounts of waste generated and on the fractions of the
total which are associated with a particular degree of hazard are
incomplete.  Table 6-2 and the following discussions present the best
available estimates of the amounts of potentially hazardous waste
generated in each category, though it should be recognized that
amounts meeting the definition of hazardous waste in Section 3001
may be significantly different.
     The primary sources of non-industrial waste oils are from the
transportation industry.  The U.S. Environmental Protection Agency
(1974) estimates indicate that about 56 percent of the automotive and
aviation oils sold in 1972 were not consumed and hence became waste
oils.  Applying this factor to the total U.S. 1975 automotive and
aviation oil sales (1.2 million gallons - U.S. Department of Com-
merce, 1977c) yields an estimated waste oil generation of 2.5 million
metric tons per year.  This is approximately twice the Battelle
Columbus Laboratories (1978) estimate of 1.3 million metric tons from
service stations alone.
                                 6-5

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                                     TABLE 6-2

                ESTIMATED ANNUAL GENERATION OF POTENTIALLY HAZARDOUS
                             NON-MANUFACTURING WASTES
         Waste
     Stream/ Source
       Volume
(million metric  tons)
     Reference
  Waste oils


  Service stations


  Hospitals




  Pesticide containers

  Households


  U.S.  Armed  Forces

  Coal  ash -  total

    Fly ash

    Bottom ash
    Boiler slag

  Oil brines

  Drilling muds


  Cement kiln dust

  Dredge spoils
    Corps of  Engineers

    Other

Phosphate slimes
  Tailings and
   benef iciation

  Phosphoric  acid
   production



Administrative/government
          2.5


          1.3


          .06

          1-2


          .02

         10.5


    Not Available

           54
           38

           12
            4

          1.9

          2.3


         23.8


      330-420

          210




      82


   20-27



 Not available
Based on U.S.  EPA,  1974
and U.S. D.O.C.,  1977c

Battelle Columbus Labs,
1978

Battelle Columbus Labs,
1978;
Based on Singer,  et al.,
1973; and Kiefer, 1974

Trask, 1977

Based on personal communication,
Morris,  OSW, 1977 and U.S. D.O.C.,
1977b.
Faber, 1976
OSWMP, 1977

Environmental Research Co .,
1978

Personal  communication,  Portland
Cement Assoc.,  1978
Council of Environmental
Quality,  1975
American  Society  of Civil
Engineers, 1977
Personal  communication,  Palm,
G. F. Palm Assoc.,  1978

 Environmental Quality
 Systems,  1976; and
 U.S.  EPA, 1974a
                                           6-6

-------
     Battelle Columbus Laboratories (1978) estimates the annual 1977




hazardous waste generation from hospitals as 58,000 metric tons.  If




the rapidly increasing volumes of disposable items are included, this




number could reach 1 to 2 million metric tons (based on data from




Singer et al., 1973; Kiefer, 1974).




     The primary hazardous wastes associated with agricultural activ-




ities are used pesticide containers which still contain residual




amounts of pesticides.  Based on information compiled by Trask




(1977), approximately 98 million pesticide containers (mostly bags)




were used in 1971 by 2.5 million farmers.  The total container weight




(empty) was estimated at 20,000 metric tons.  Additionally, it was




estimated that 39 percent of the farmers using pesticides hired cus-




tom application services, and only 5 percent rinsed their containers.




Other estimates (Energy Resources Co., 1978) are that 25 to 40 mil-




lion small containers (made of glass, plastic, or metal) and 250,000




to 500,000 large containers (30 to 50 gallon steel drums) are used




annually.




     Based on an estimated hazardous waste generation of 7.5 pounds




per household per year (Personal communication,  M. Morris, Office of




Solid Waste,  1977) and 1975 Census data (U.S. Department of Commerce,




1977b), hazardous waste generation by individual households could




reach 10.5 million metric tons per year.  This figure may include




some of the waste automotive oils discussed above, plus various




cleaning fluids, caustics, pesticides, and miscellaneous chemicals.
                                 6-7

-------
     The amounts of hazardous wastes generated by the U.S. Armed




Forces is unknown.   However,  the armed forces own and operate many of




their own supply and maintenance facilities, including munitions




plants, chemical production facilities,  metal plating shops, and




foundries.  The military services maintain large stockpiles of muni-




tions which must be periodically replaced due to deterioration.




Additionally, the military services store large quantities of unused




and retrograde chemicals, primarily pesticides, which no longer have




valid registration for use or have deteriorated.  It can therefore be




expected that the amounts of hazardous wastes generated or stored by




the military are large and may approach the amounts produced by all




the manufacturing industries combined.  Most of the services are be-




ginning to survey their hazardous waste generation as of the fall of




1978.




     Estimates of the 1975 U.S. coal ash production are on the order




of 38 million metric tons of fly ash, 12 million metric tons of bot-




tom ash, and 4.2 million metric tons of boiler slag (Faber, 1976). Of




these amounts, about 8.9 million metric tons (16.3 percent) was uti-




lized in secondary products, primarily in the cement and concrete,




and in the manufacture of lightweight aggregates (Faber, 1976).  The




inclusion of many of the potentially toxic trace elements and other




constituents (e.g., complex organic compounds) originally contained




in the coal may result in the designation of at least some ash as




hazardous.
                                6-8

-------
     The U.S. Army Corps of Engineers either conducted or contracted


for the dredging of between 310 and 390 million cubic yards (330 to


420 million metric tons) of bottom materials per year during the



period 1970 through 1975 (Council on Environmental Quality: 1975).
                                                I

Of this, at least 24.8 million cubic yards (29 million metric tons)



was considered contaminated (U.S. Army Corps of Engineers, 1977).  An


additional estimated 200 million cubic yards (210 million metric


tons) are dredged annually by port authorities, municipalities,  and


other government agencies (i.e., U.S. Navy and Coast Guard)  (American


Society of Civil Engineers, 1977).


     Industry sources estimate that 135 million tons of overburden


and 90 million tons of tailings, clay, and mud ball slimes (excluding



overburden) are generated each year from phosphate mining and benefi-


ciation operations in Florida (the source of 78 percent of the phos-


phate rock mined in the U.S.) (Personal communication,  G. Palm,


Gordon F. Palm and Associates, 1978).  In addition, estimates of the


annual gypsum slime waste generation from phosphoric acid production


range from 22 million tons per year (Environmental Quality Systems,



Inc., 1976) to about 30 million tons per year (U.S. Environmental



Protection Agency, 1974a).  These wastes are generally radioactive,


and contain fluorine and trace contaminants.  The gypsum slimes from



acid production also exhibit very low pH.


     The amounts of hazardous wastes generated by non-military gov-



ernment agencies are not known.  Typical potentially hazardous wastes
                                 6-9

-------
generated by such agencies  include unused pesticides,  empty pesticide




containers,  waste oils  and  solvents,  paint sludges,  petroleum wastes,




laboratory wastes,  expired  and unusable medicines,  pathological and




infectious wastes,  and  other miscellaneous chemical wastes.  Bourns




et al. (1978) reported  that non-military Federal agencies in Region




IX generate at least 5,000  metric tons/year (including 3,600 metric




tons of drilling muds), stating that  the "quantities estimated prob-




ably are considerably less  than those actually generated".




     The wastes discussed in this section do not represent all of the




potentially hazardous non-manufacturing wastes generated in this




country.  Other sources include mining operations;  construction com-




panies; dry cleaning plants; testing, research and  development labor-




atories; cleaning, disinfecting and exterminating services; retailers




and wholesalers of drugs, chemicals,  paints, solvents, and other




products; marinas; and others.  Although data on generation from




these sources are sparse, it can be concluded that  the total amounts




of potentially hazardous wastes from non-manufacturing industries are




very large  (on the order of several hundred million tons) and could




greatly exceed the 50 million metric tons attributed to the manufac-




turing industries.




6.2  Hazardous Waste Generators




     U.S. Census data indicate that there were 313,000 establishments




engaged in  the manufacturing industries in 1972 (U.S.  Department of




Commerce, 1976).  SIC codes 27 (Printing and Publishing) and 35







                                 6-10

-------
(.Machinery, except Electrical) contained the largest number of estab-




lishments with about 40,000 each.  SIC codes 24 (Lumber and Wood




Products) and 34 (Fabricated Metal Products) accounted for 34,000 and




30,000 of the establishments, respectively.  SIC code 28 (Chemicals




and Allied Products), the largest generators, ranked tenth in the




number of establishments with 11,000.




     Figure 6-1 shows the cumulative size distribution of hazardous




waste generators in the manufacturing industries.   The horizontal




axis represents the annual waste generation of a single establish-




ment, and the vertical axis represents the number  of establishments




which generate more than that value.  Figure 6-2 shows the cumulative




percentage of the total amount of hazardous wastes generated as func-




tion of firm size (i.e., the fraction of total wastes generated by




all establishments exceeding a particular annual generation value).




These figures are plots of the output of the cycling option of the




phasing program as described in Appendix I.  They  were based on the




generation factors developed in Appendix H and on the U.S. manufac-




turing establishment size distribution data published by the U.S.




Department of Commerce (1976 and 1977).  Examination of the two




figures reveals that although less than three percent of the manufac-




turing establishments generate more than 1,000 metric tons of hazard-




ous wastes per year, those establishments account  for 78 percent of




the total hazardous manufacturing wastes generated in the U.S.  Simi-




larly, the 25 percent of the establishments which  generate more than
                                6-11

-------
M
to
       O
       &
       H

       g
       w
       O
      H



      O
      W
      CM
1UU
90
80
/O



30
20
J.U
n







\
V









^^
^— - —

annual g







• — • 	 	 	

eneration







••

amount g:









ven on he









rizontal









axis.




























                   100      200       300      400      500      600      700


                                   HAZARDOUS WASTE GENERATION PER ESTABLISHMENT

                                                (METRIC TONS/YR)
800
900
1000
                                                 FIGURE 6-1

                     CUMULATIVE SIZE DISTRIBUTION OF HAZARDOUS WASTE GENERATORS 1975

-------
w
H
I/I
a
o
H
o
Pi
PM
100

 90

 80

 70

 60

 50

 40

 30

 20

 10
              *Percent of total hazardous wastes generated  by all manufacturing establishments
               exceeding annual generation amount given  on  horizontal axis.
              100
                     200
300
400
500
600
700
800
900
1000
                               HAZARDOUS WASTE GENERATION PER ESTABLISHMENT
                                             (METRIC TONS/YR)
                                              FIGURE 6-2
                          CUMULATIVE HAZARDOUS WASTE DISTRIBUTION 1975

-------
25 metric tons per year are responsible for about 98 percent of the

total hazardous wastes.  It should be noted that these estimates are

subject to several important assumptions,  the implications of which

are in Appendices H and I.   Additionally,  they do not account for the

relative hazardousness of different waste streams.

6.3  Estimation of Future Hazardous Waste Generation

     1980 has been selected as the base year, and 1984 as the target

year for estimating the full impacts of implementation of the Sub-

title C regulations.  Estimates of the rate of increase of hazardous

waste generation were developed using data presented in the Industry

Studies (1975-1978) discussed in Chapter 5.   The total increase in

hazardous waste generation projected by these studies between 1974

and 1983 is 42 percent, or about 3.6 percent per year.  Much of this

increase is attributed primarily to increased sludge volumes result-

ing from the more effective air and water pollution equipment being

brought on line in response to recent environmental legislation.

Many other factors also affect future hazardous waste generation,
*
 The Industry Studies (1975-1978) are a set of studies of hazardous
 waste generation in 13 major industrial segments.  They were per-
 formed by individual contractors using their own definitions for
 hazardous wastes.  As a result of the differences in definitions and
 the incomplete coverage of potential waste sources, these studies
 were not used in the development of the hazardous waste generation
 factors.  However, it was assumed that the rate of increase of haz-
 ardous waste generation projected by the studies was applicable to
 all hazardous manufacturing wastes as estimated using the generation
 factor approach.
                                6-14

-------
but there are no reliable means of estimating their effects.  These




factors include changes in manufacturing processes, increased use of




coal and synthetic fuels, and growth in manufacturing industries in




general.  Although different industries will be affected to different




degrees, the average rate of 3.6 percent per year has been applied to




all SIC groups in the absence of more complete data.  The resulting




estimated annual hazardous waste generation from manufacturing indus-




tries is about 57 million metric tons in 1980 and 65 million metric




tons in 1984.




6.4  Hazardous Spills




     Spills of hazardous materials must be handled as hazardous




wastes regardless of whether the spilled material was originally a




waste or a valued product.  In addition to the volume of material




spilled, a much larger volume of soil, water, and/or sorbent or other




cleanup material often also becomes contaminated.  In most cases,




such contaminated materials must also be considered and handled as




hazardous wastes.




     As discussed in Chapter 2, the responsiblity for documentation




of, and dealing with, hazardous spills is presently divided between




the U.S. Coast Guard (USCG), Department of Transportation (DOT), and




the Environmental Protection Agency (EPA).  All releases of hazardous




materials (as defined in 49 CFR 172) during the course of transporta-




tion must be reported to DOT's Hazardous Material Regulation Board.




All discharges of hazardous quantities of oil or hazardous substances
                                 6-15

-------
Us defined in 40 CFR lib and 118.)  to navigable wastes must be




reported to the National or Regional Response Centers or to regional




offices of either EPA or USCG.   Spills of materials not meeting the




definitions cited above, and spills which are not related to trans-




portation and which do not threaten the broadly interpreted "naviga-




ble waters" are not presently subject to reporting requirements.




     Table 6-3 presents statistics  on the spill incidents reported to




EPA during the one year period from February 1977 to February 1978.




Since the regulations listing hazardous wastes subject to reporting




requirements  (40 CFR 116) were not  promulgated until March 1978, the




non-oil wastes listed in the table  were reported voluntarily.  Of the




75 cases presented, 39 are either exclusively oil spills or are oil




mixed with other hazardous substances.  Although oil-related spills




represent 52  percent of the total for the year, this figure may be




unrepresentative due to the lack of a definition and, therefore, of




specific reporting requirements for hazardous substances during that




period.  Data on volumes are presented to give some idea of the quan-




tities  of materials spilled in individual incidents.  Calculation of




the total volume of material spilled during the period would be un-




realistic due to the number of estimated ranges that were given and




due to  the number of incidents reported where the spill volume was




not even estimated.  For comparison purposes, however, the volumes of




reported spills range from 500 gallons to as much as 150 million gal-




lons, though  only two spills exceed 1 million gallons and most were
                                 6-16

-------
                                 TABLE 6-3




EPA HAZARDOUS SUBSTANCES SPILL FILE SUMMARY (FEBRUARY 1977 - FEBRUARY 1978)
DATE OF
REPORTED
OCCURKA11C£
3 Feb 1977
3 Feb 1977
3 Feb 1977
3 Feb 1977
21 Mar 1977
21 Mar 1977
21 Mar 1977
21 Mar 1977
29 Mar 1977
31 Mar 1977
31 Mar 1977
31 Mar 1977
1 Apr 1977
1 Apr 1977
11 Apr 1977
11 Apr 1977
11 Apr 1977
11 Apr 1977
11 Apr 1977
22 Apr 1977
29 Apr 1977
10 May 1977
13 May 1977
19 Hay 1977
19 May 1977
19 May 1977
3 Jun 1977
3 Jun 1977
o Jun 1977
24 Jun 1977
28 Jun 1977
28 Jun 1977
5 Jul 1977
5 Jul 1977
MATERIAL SPILLED
NR 6 oil
NR 6 oil
Oil
on
Oil
Gas
Oil
Oil and PCBs
pentadlene
Oil (sa 6)
Crude oil
Ammonium nitrate
Formaldehyde
PCB and oil
Crude oil
NR 2 oil
Oil
Oil
Oil
Oil
Sodium aulfide
Crude oil
Anhydrous ammonia
NR 6 oil
2 ethyl, 4 methyl, i,J,
dioxolane, toluene,
xylene, methylene
chloride, heptane, iso-
Crude oil
Oil and chemicals
Naptha
Oil
NR 6 oil
PCB
Crude oil

Q
10,000 gallons
500 gallons
2,000 gallons
134,000 gallons
546,000 gallons
32,000 gallons
131,100 gallons*
38,000,000 cu ft*
210,000 gallons
600,000 gallons
25,000 tons sludge
21,000 gallons
20,580 gallons
Unknown
20,000 gallons
2,500 drums
42,000 gallons
2,000 gallons
2,000 gallons
Unknown
Unknown
Unknown
3.5 tons
8,400-10,500 gallons
16,800 gallons
15,000 gallons
Unknown
1,000 gallons
16,800 gallons
9-10,000 gallons oil
24-30,000 gallons
chemicals
Unknown
5,000 gallons
168,000-210,000 gallons
165 gallons
12,600 gallons
UPLAND OR

Waterway Heating plant
Waterway Barge spill
Waterway Tanker spill
Waterway Tanker spill
Waterway Gas well blowout
Air
Upland Lagoon overflow

y
y p
Air Railroad spill
Waterway Railroad spill
Waterway
Waterway Pipeline break
Waterway Barpe spd 1 1
Waterway Ship spill
Waterway Unknown
Waterway Unknown
Waterway Unknown
Waterway Company spill
Upland Company spill
Waterway Pipeline break

Waterway Barge spill
Waterway Chemical company discharge

Waterway Lagoon spill
Waterway Company spill
Waterway Barge spill
Waterway Barge spill
Upland Company spill
GEOGRAPHIC LOCATION
Perch Amboy, NJ
Washington, D.C.
Buzzards bay, MA
Marcus Hook, PA
Atlantic Ocean
Cuazanilla Bay, PR
Louisiana/Texas
Oregon, Ohio
Os-;=go, NY
Louisville, FY
Rockingham, NC
Hardin Coundy , TX
Rockingham, NC
Sanford, NC
Diltner, MO
White Oak, TX
Philadelphia, PA
Cape San Martin, CO
Del. Bay, NJ
Key West, ri.
New Martinsville, VA
Grant County, OK
Mississippi
Baltimore, MD
Lenolr, NC
Crockett, TX
Kernersville, NC
Weirton, WV
Akron, OH
YorktowB, VA
Calcosiew, LA
Brookuood , AI,
Stuart, OK
                                    6-17

-------
TABLE 6-3
(Concluded)
DATE OF
REPORTED
OCCURRENCE


6 Jul 1977
/ Jul 1977
13 Jul 1977
20 Jul 1977
25 Jul 1977
28 Jul 1977
28 Jul 1977
16 Aug 1977
16 Aug 1977


11 Oct 1977
2 Nov 1977
4 Nov 1977
10 Nov 1977
18 Nov 1977
1 Dec 1977

13 Dec 1977
5 Jan 1978
10 Jan 1978
11 Jan 1978
11 Jan 1978
16 Jan 1978
16 Jan 1978
19 Jan 1978
26 Jan 1978
26 Jan 1978
26 Jan 1978
26 Jan 1978
30 Jan 1978
31 Jan 1978
31 Jan 1978
MATERIAL SPILLED.


Oil
polymer emulsion
Hydrobromic acid
Malathion
Oil
Tritium
Crude .Jil
Xylene
Latex
magnesium sulfate;
paradichlo tubenzene;
monolsopropanolamine ;
dlene; monochlorobenzene
alcohol

end r in
PCB and oil
Crude oil
Gasoline
Anhydrous ammonia
Acrylamide
Hydrogen peroxide
ammonia
y
ethyl acetate; nitroben-
zene; PCB
Xylene
SulEurtrioxide
Gasoline
Crude oil
Crude oil
Methyl ethyl ketone;

Assorted chemicals
NR 2 oil
Edichlorohydrin
Oil
Acrylonitrile; LPG
NR 6 Oil
Liquid c>xygen
QUArfTm-SP-H LED-

42,000
38,000 gallons
280,000 gallons
10,000 pounds
550 gallons
20,000 gallons
9,000 gallons
60,000 gallons
unknown
Unknown
Unknown
21,000-126,000 gallons
8,000 gallons
Unknown
5,000-6,000 gallons
l^known
8,000-20,000 gallons
Unknown
84,000 gallons
Unknown
495,000 gallons
10,000 gallons
12,600 gallons
300 gallons/hr
12,000,000 gallons
20,000 gallons
14,000 gallons
150,000,000 gallons
15,000 gallons
20,000 gallons
50,000 gallons
Unknown
Unknown
Unknown
UPLAND OR
WATERWAY SPILL
Waterway
Waterway
Waterway
Upland
Waterway
Waterway
Waterway
Waterway
Waterway
Waterway
Waterway
Upland and waterway
Waterway
Waterway
Waterway
Upland ; waterway
and air
y
Waterway
Upland
Waterway
Air
Waterway
Upland
Upland
Waterway
Waterway
Waterway
Waterway
Upland and waterway
Upland
Waterway
Air
Waterway
Air and waterway
TYPE OF SPIEL
Company spill
Pipeline spill
Company spill
Plane crash
Natural flood
Nuclear power plant spill
Barge spill
Railroad bpill
Unknown
Unknown
Railroad spill
Company spill
Company spill
Tank truck spill
Railroad spill
P
Railroad spill
Company spill
Pipeline spill
Company spill
Barge spill
Company spill
Railroad spill
Tanker spill
Railroad spill
Railroad spill
Lagoon spill
Company spill
Railroad spill
Barge spill
Railroad spill
Barge spill
Company explosion and spill
bhUbKAfHIt LULATIUN
Port Washington, Wl
Upshur County, TX
Rainey Park, NY
Dartmouth, MA
Rockwood, TN
Sheridan, WV
Johnston, PA
Pittsburg, PA
Anaheim, CA
Mile 161, LA
Novi, Mi
Ocean City, MD
N. Miami Beach, FL
Kennegaw, GA
Philadelphia, PA
Kansas City, MO
Alexandria, VA
Pensacola, FL
Evergreen, AL
West Virginia
Frankfort, KY
Logan Township, NJ
Danville, IL
Baltimore, MD
Long Island, NY
Hertford, NC
Dansville, MI
Uhric-bfiville, r>H
Sao Paulo, Brazil
Milstead, AL
Pond Eddy, PA
Pascagoula, MS
Dresden, NY
Point Pleasant, UV
Galveston, TX
Leon, KY
Portsmouth, Nil
Moundsville, W1'
 *Assuming all 9.5 cu ft of gas and 104 bai
**Assuraing 1 ton = 500 gallons.
:ondensate produced per day  escape to the air and the water,  respectively For 4  days.
                                                                 6-18

-------
less than 100 thousand gallons.  Most of the reported incidents




involved spills to a body of water; however, it must be kept in mind




that the reporting of upland spills (not directly involving or




threatening U.S.  waters) is not mandatory.




     Table 6-4 shows all discharges recorded by the USCG Pollution




Incident Reporting System (PIRS), primarily oil and hazardous dis-




charges reported to the National Resource Center, or other USGS and




EPA offices, but also includes' releases subject to the Hazardous




Materials Transportation Act, and other spills reported voluntarily




or collected from other sources.  The PIRS file contains only those




discharges into,  or which threaten, the waters of the United States.




Assuming a range of densities from six to ten pounds per gallon, the




total weight of the spilled materials shown in the table amounts to




90 to 150 thousand metric tons.  Table 6-4 includes the 7.5 million




gallon spill of fuel oil by the Argo Merchant, which accounts for 22




percent of the total volume of discharges during the year.  Excluding




that single spill the largest category in terms of volume is "other




pollutant", including sewage, dredge spoil, and chemical wastes, with




6.5 million gallons (about 25 percent of the total volume excluding




the Argo Merchant spill).  Much of the volume of spills such as that




reported in this table cannot be recovered and therefore could not be




placed in RCRA-approved disposal facilities.  However, as discussed




above, in the cases in which removal of spills is possible, the
                                6-19

-------
                              TABLE 6-4

     TYPES OF DISCHARGES REPORTED UNDER SECTION 311, PL 92-500
                                1976
Number of
Incidents
Crude oil
Fuel oil
Gasoline
Other distillate fuel oil
Solvent
Diesel oil
Asphalt or residual fuel
oil
Animal or vegetable oil
Waste oil
Other oil
Liquid chemical
Other pollutant (sewage,
dredge spoil, chemical
wastes, etc.)
Natural substance
Other material
Unknown material
Total
2,667
909
658
251
34
2,063
132
93
1,217
2,636
296
130
94
146
1,329
12,655
% of
total
21.1
7.2
5.2
2.0
0.3
16.3
1.0
0.7
9.6
20.8
2.3
1.0
0.7
1.2
10.5
100.0
Vo lume in
gallons
4,990,691
9,780,886
764,168
462,140
95,317
1,100,133
4,982,195
94,513
131,377
724,294
2,110,048
6,468,940
6,468
2,120,386
20,274
33,851,830
% of
total
14.7
28.9
2.3
1.4
0.3
3.2
14.7
0.3
0.4
2.1
6.2
19.1
0.0
6.3
0.1
100.0

Source:   U.S.  Department  of  Transportation,  Coast  Guard,  1977.
                                 6-20

-------
clean-up operations must usually remove a large volume of contami-




nated soil and water in addition to the original volume of spilled




material.  This volume would greatly increase the amount of material




requiring disposal in RCRA-approved facilities.




     Table 6-5 gives the distribution of spills by source category.




The largest category of spill sources was non-transportation related




facilities other than refineries, bulk storage, and production facil-




ities.  These sources were responsible for 29 percent of the total




spill volume and 90 percent of the total non-oil spill volume.




     Table 6-6 is included to illustrate the type of commodities




which were named most often in hazardous materials incident reports




as documented by the U.S. Department of Transportation for the period




from January 1, 1971 to December 31, 1975.  This list does not imply




a ranking of risk or hazard to the public.  For example, most of the




paint spills (comprising 20.5 percent of the total number of reports




recorded) were less than 5 gallon amounts, and most of the battery




acid spills (comprising 11 percent) were less than one quart amounts.




Many of the gasoline spills, however, (comprising 13.5 percent of the




total number of reports recorded) were of 100 gallons or more.  This




table is intended to show only which commodities were reported most




often.




6.5  Hazardous Wastes Under State Control




     As discussed in Chapter 2, existing state programs to control




hazardous waste range in scope from non-existent to highly







                                 6-21

-------
                             TABLE 6-5

     SOURCES OF DISCHARGES REPORTED UNDER SECTION 311, PL 92-500
                               1976

Vessels
Dry cargo ships
Dry cargo barges
Tank ships
Tank barges
Combatant vessels
Other vessels
Total
Land vehicles
Rail vehicles
Highway vehicles
Other/unknown vehicles
Total
Non-transportation-related
facilities
Onshore refinery
Onshore bulk/storage
Onshore production
Offshore production
facilities
Other facilities
Total
Pipelines
Marine facilities
Onshore/offshore bulk
.Cargo transfer
Onshore/offshore fueling
Onshore/offshore nonbulk
Cargo transfer
Other transportation
Related marine facility
Total
Land facilities
Misc. /unknown
Total
Number of
incidents
41
324
623
976
179
1,153
3,296

82
335
47
464


101
365
242
1,358

1,055
3,131
653

321

88
23


;.28
560
182
4,379
12,655
% of
total
0.3
2.6
4.9
7.7
1.4
9.1
26.0

0.6
2.6
0.4
3.6


0.8
2.9
1.9
10.7

8.3
24.6
5.2

2.5

0.7
0.2


1.0
4.4
1.4
34.6
100.0
Volume in
gallons
11,679
24,840
8,930,029
1,953,442
26,987
245,013
11,191,990

269,440
323,391
20,968
613,799


211,614
5,873,932
349,053
274,732

9,759,869
16,469,200
4,530,094

333,712

21,708
15,643


5,787
376,850
442,730
227,167
33,851,830
% of
total
0.0
0.1
26.4
5.8
0.1
0.7
33.1

0.8
1.0
0.1
1.9


0.8
17.4
1.0
0.8

28.8
48.0
13.4

1.0

0.1
O.C


0.0
1.1
1.3
0.7
100.0

Source:  U.S.  Department  of Transportation, Coast Guard, 1977.

                                6-22

-------
                               TABLE 6-6

 COMMODITIES NAMED MOST OFTEN IN HAZARDOUS  MATERIALS  INCIDENT REPORTS

Section 172.5 Commodity
Paint and paint related compounds
Gasoline
Batteries and electrolyte fluid
Compounds, cleaning, liquid (Cor.)
Sulfuric acid
Cement, liquid, n.o.s.
Flammable liquids, n.o.s.
Hydrochloric acid
Corrosive liquids, n.o.s.
Insecticides, liquid (Poison B)
L.P.G.
Poisonous liquids, n.o.s. (Poison B)
Ink
Alcohol, n.o.s.
Acids, liquids, n.o.s.
Caustic soda liquid
Nitric acid
Resid solution
Anhydrous ammonia
Compounds, tree or weed kill (Poison B)
Compounds, cleaning, liquid (FL)
Total
Total of All Reports Received
Number of
Reports
(1971-1975)
6,590
4,243
3,593
2,194
1,081
903
844
825 '
714
422
395
364
355
337
316
304
265
240
222
215
211
24,633
32,000
Approximate % of
All 32,000 Reports
Received
2Qh
13*5
11
7
3>5
3
21-2
2%
2%
Ik
1%
1
1
1
1
1
0 3/4
0 3/4
0 3/4
0 3/4
0 3/4
77
100

Source:   U.S.  Department of Transportation,  Materials Transportation
         Bureau,  1976.
                                  6-23

-------
comprehensive.   Due to the variability in the degree of control and




the uncertainties in estimating individual state generation,  the




amount of hazardous waste presently under state control cannot be




estimated with  confidence.




     Table 6-7  shows the number of states with legal mechanisms




allowing control of hazardous  wastes,  as  summarized from Chapter 2.




Less than one-fifth of the states presently have standards or regula-




tions controlling any of the facets of hazardous waste activities,




although just over half of the states  have provisional authority to




require permits for and/or inspect disposal sites.   Only six states




presently have regulations instituting some type of manifest tracking




system.




      Table 6-8 shows the status of state control in the seven states




which generate about 50 percent of the potentially  hazardous manufac-




turing wastes in the U.S.  The trend towards manifest systems in




these states is obvious, though only two  of the states are presently




operating such a system under specific regulation.   Also, apparent




are the relatively high degree of regulation over disposal and the




corresponding lack of authority over storers and treaters.  Addition-




ally, two of the states have essentially  no control over activities




other than disposal, and another has only provisional authority with




no specific standards.




     It should be emphasized that both the comprehensiveness of exis-




ting standards  and regulations, and the degree to which they are
                                6-24

-------
                                           TABLE 6-7

                         SUMMARY - STATE CONTROL OVER HAZARDOUS WASTES




Permit

I
to
un



Generators
Transporters
Storer
Treater
Disposers

3
6
6
8
28

2
4
4
2
9



Manifest
p* s**
12
11
5
8
12

6
8
6
6
6



Record keep ing
p* s**
12
5
3
4
18

3
3
0
1
9



Reporting
p* S**
11
1
2
3
15

4
2
1
1
7



Inspection
p* s**
3
1
2
2
26

0
0
0
0
4

 *Number of states with provisional authority.
**Number of states with regulatory standards.

-------
                                                            TABLE 6-8

                                       HAZARDOUS WASTE CONTROL IN LARGE GENERATOR STATES*
I
NJ
State
California
Illinois
New Jersey
New York
Ohio
Pennsylvania
Texas
Totals
(S)
(P)
All
Specific State Legislation Applicable to:
Generators
(S) M, Rp
(PS) M
(P) M,Rc,Rp
	
(S) P; (P) M
	
(S)M,Rc,Rp
P M Re Rp I
13120
02110
15230
Transporters
(S) P, M, Rp
(PS) M
(P) M,Rc
	
(S) P; (P)M
	
(S)M,Rc
P M Re Rp I
23110
02100
25210
Storers
(S) M,Rp
(PS) M
	
	
(S)P; (P)M
	
(S) M
P M Re Rp I
13010
01000
14010
Treaters
(S) P.M.Rp
(PS) M
	
(P) P
(S)P; (P)M
	
(S) M
P M Re Rp I
23010
11000
34010
Disposers
XS) P.M.Rp.Rc.I
(PS) M.Rp.Rc;
(PS) P,I
(P) P,M,Rc,Rp,I
(S) P; (P) Rc,Rp,I
(S)P; (P)M,I
(P) P,Rc
(S)P,M,Rc,Rp
P M Re Rp I
43331
32324
75655

                 * These states generate about one half of  the potentially hazardous manufacturing wastes  in
                     the United States  (see text)


                 Key:   (S) - existing standards;  (PS) - proposed  standards;  (P)  -  provisional  authority only;
                        (PP) - proposed  provisional authority; P - permit; M  - manifest;  Re  - record  keeping;'
                       Rp - reporting;  I - inspection

-------
enforced, vary widely from state to state.  The information presented




in the table is based in part on telephone interviews with state




officials.  No attempts were made to evaluate the comparability of




various definitions, disposal requirements, or enforcement mech-




anisms.  In fact, only 17 states presently have officially defined




hazardous wastes by either criteria or listings.




     As discussed in Chapter 2, the existence of a provisional mech-




anism to regulate hazardous wastes indicates that the state has the




enabling authorities to control a particular activity, even though it




may lack specific regulations detailing the control procedures.  The




extent to which the various states actually exercise such provisional




authority varies greatly.  Many states (e.g., West Virginia) use




their provisional authority on a case-by-case basis and then usually




in response to specific incidents.




     Some states may also exert limited control over hazardous wastes




based on solid waste or other legislation in the absence of regula-




tions or enabling authority specifically addressing hazardous wastes.




For example, the State of Illinois has been operating a manifest sys-




tem for several years without specific hazardous waste legislation.




The state legislature is presently considering a set of proposed




regulations which would revise and add additional authority to the




existing control system.




     In summary, even when considering the subjective nature of the




data presented in Tables 6-7 and 6-8, it may be concluded that at
                                 6-27

-------
present,  state control of hazardous wastes is fragmented,  and that,




although  some states  exert very good control, the potential for




damage from uncontrolled disposal  of hazardous wastes is  substantial!
                                6-28

-------
7.0  IMPACTS OF THE PROPOSED ACTION
                          *


     This chapter addresses the potential impacts, both beneficial



and adverse, that could result from implementation of the proposed



Subtitle C regulations.  Two major types of impacts are analyzed:



primary impacts and secondary impacts.  Primary impacts include those



effects that would be directly attributable to the implementation of



the proposed regulations.  Secondary impacts include those effects




that would be indirectly attributable to the implementation of the



proposed regulations.  In some cases, secondary impacts might not be



observed until years or even decades after implementation of the



regulations.



     Where practical, potential impacts are analyzed for two separate



years:  1980, the year of expected implementation of the regulations,



and 1984, the year by which the full effects of the regulations are



expected to become established.  For the reasons discussed in Section



7.1.2, it is anticipated that at least five years would be required



for such effects and resultant impacts to become fully established.



     The impact analysis is, for the most part, both generic in scope



and conducted on a national level due to the extreme waste-specific,




process-specific, and site-specific nature of most impacts, and due



to the extensive data limitations previously indicated.  Because most



available data relate to manufacturing industries, the emphasis of



the impact analysis is necessarily directed toward manufacturing
                                 7-1

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m,
industries.   To the extent the limited available data allow, impacts




are assessed quantitatively.




     Over 300 reported incidents of damage from the improper manage-




ment of hazardous wastes were reviewed to assist in identifying the




potential for adverse impacts resulting from current hazardous waste




 anagement practices.  Appendix J briefly describes each of these




reported incidents.  Table 7-1 summarizes the type and extent of the




adverse impacts that have been reported.   From the way in which most




of the incidents have come to light, it is very likely that the vast




majority of such incidents go unreported, especially human health




incidents which may require many years of exposure and for which




direct causative relationships are difficult to trace or establish.




The reported incidents indicate that there is often a considerable




time interval between the occurrence of those events which lead to




damage and the time when the damage becomes evident.  Since virtually




all of the reported incidents were discovered only after damage had




already occurred, there is, nationally, a very significant potential




for many similar damage incidents to be detected in the future from




wastes that have already been improperly stored, treated, or




disposed.




     It should be noted that a potentially large category of hazard-




ous wastes, termed "special wastes," are only briefly addressed in




the impact analysis.  "Special wastes" include cement kiln dusts,




utility wastes, oil drilling muds/brines, phosphate rock mining and
                                   7-2

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                                                  TABLE 7-1


                               NUMBER AND TYPES OF REPORTED INCIDENTS FROM THE

                                  IMPROPER MANAGEMENT OF HAZARDOUS WASTES*
I
LO

Management
Method
Generation
Transport
Storage
Dumping
Landfill
Lagoon
Incineration
Resource
recovery
Other
treatment
TOTAL
Air
quality
impacts
1
6
5
5
1
4
2
2

5
—
31
Water
quality
impact s+
4
1
23
73
69
55
1
4

3
—
233
Soil
contami-
nation
-
-
2
4
3
2
-
—

1
—
12
Identifiable
public health
impacts
1
4
9
12
16
2

2

3
— —
49
Drinking
water
contamination
-
1
9
25
27
19
1
2

-
—
84
Identifiable
biological
impacts
2
-
7
37
20
19
1
2

2
—
90

           *Summary  is based  on  approximately  300  reported  incidents  listed  in Appendix J.

           +Includes  drinking water  contamination  incidents.

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processing wastes,  uranium mining wastes, and other mining wastes.

Any "special wastes" identified as hazardous under the Subtitle C

regulations would be subject to a limited portion of the Subtitle C

storge, treatment,  and disposal regulations (see Sections 7.1.2.3 and

7.1.2.4).  As a result, it is not likely that there would be any

significant change in the current storage,  treatment, or disposal

practices for such wastes.  EPA is presently planning to promulgate

specific Subtitle C requirements for the management of each of these

"special wastes".  An additional environmental impact statement or

supplementary statement would be prepared for these "special wastes",

if warranted, at such time.

7.1  Potential Primary Impacts

     The potential primary impacts from implementation of the pro-

posed regulations are analyzed within the following areas:

     •  Hazardous wastes to be regulated;

     •  Changes to existing generation, transport, storage, treat-
        ment, and disposal practices and procedures;

     •  Administrative changes;

     •  Air impacts;

     •  Water impacts;

     •  Public health impacts.

     In discussing the primary impacts of the proposed regulations,

especially air, water, and public health implications, a limited

number of incidents are used to illustrate  the potential benefits of

the regulations.  It should be noted that Appendix J contains many

                                     7-4

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additional examples of adverse incidents that have occurred under




present hazardous waste management practices.




     7.1.1  Hazardous Wastes to be Regulated.  The Section 3001 regu-




lations (Appendix B, Subpart A) define the wastes that are to be con-




sidered hazardous and, thus, subject to the Subtitle C regulations.




Two mechanisms are provided for determining those wastes that are




hazardous:  identifying characteristics and lists of specific hazard-




ous wastes and waste streams.  The identifying characteristics are




ignitability,  corrosivity, reactivity, and toxicity.  Wastes which




exhibit any of these characteristics, or which are listed, would be




considered hazardous and would have to be managed pursuant to the




Subtitle C regulations.




     Chapter 6 contains estimates of potentially hazardous waste gen-




eration within manufacturing and non-manufacturing industries.  The




estimates for the manufacturing industries have been determined using




the generation factors described in Appendix H; the estimates for the




non-manufacturing industries have been developed as described in




Chapter 6.  The quantity of wastes that would be identified as hazar-




dous under the Section 3001 regulations would, however, be less than




the quantities indicated as hazardous in Chapter 6 due to the pro-




posed definition of the Section 3001 toxicity characteristic.  The




toxicity characteristic is to be based solely upon the EPA Primary




Drinking Water Standards and, as a result, many wastes that are po-




tentially hazardous due to other indicators of toxicity, especially
                                 7-5

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organic wastes,  would presently be excluded from regulations.*

However, many other such wastes are specifically included on the

lists of hazardous wastes and,  thus,  would be subject to the Subtitle

C regulations.

     It is expected that the primary effect of the present toxicity

characteristic on manufacturing wastes would be to eliminate from

regulation a large portion of the potentially hazardous wastes pre-

viously estimated to be generated by industries within SIC Code 28

(Chemicals and Allied Products).  EPA staff estimates are that about

35 percent of the potentially hazardous wastes previously estimated

to be generated within SIC Code 28 could be identified as hazardous

under the Subtitle C regulations.  It is therefore estimated, based

upon Chapter 6, that approximately 35 million metric tons of manu-

facturing wastes could be identified as hazardous under the Section

3001 regulations in 1980, and that approximately 40 million metric

tons could be identified as hazardous in 1984.  The distribution of

these regulated wastes among the manufacturing SIC codes and EPA

Regions would be essentially that shown in Table 6-1, except that the

wastes  in SIC Code 28 would be reduced by 65 percent.
*EPA is planning to expand the toxicity characteristic to bring a
 greater number of these potentially hazardous wastes under the
 regulations in the future and would prepare an additional environ-
 mental impact statement or supplementary statement for .the expanded
 toxicity characteristic, if warranted, at such time.  The specific
 revisions are not known at this time.  The "enhanced public health
 and environmental protection alternative" assessed in Chapter 8
 does, however, include an expanded toxicity characteristic.
                                  7-6

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     Only those persons or Federal agencies who produce and dispose




of more than 100 kilograms (about 220 pounds) per month of wastes




identified as hazardous under the Section 3001 regulations would be




considered generators subject to the Subtitle C regulations.   As




shown in Table 7-2,  this generator limit of 100 kilograms  per month




could exclude about  29,000 metric tons per year of hazardous  manufac-




turing wastes from regulation.   The excluded waste would be less than




0.1 percent of the total hazardous manufacturing wastes.  However,




about 26 percent of  manufacturing establishments generating hazardous




wastes could be excluded.




     For purposes of comparison, almost 350 million metric tons  of




total manufacturing  wastes (hazardous and non-hazardous) are  estimat-




ed by EPA to be generated annually.  Thus, over 10 percent of the




total manufacturing  wastes would be regulated as hazardous wastes.




Over 60 percent of the manufacturing wastes identified as  hazardous




in Chapter 6 would be regulated.




     In addition to  manufacturing wastes, the identifying  character-




istics and the lists would identify other wastes as hazardous.   Sev-




eral large volume, non-manufacturing waste streams are specifically




listed as being hazardous.  The listed waste streams include  uranium




mining wastes, phosphate mining and processing wastes, and pesticide




containers that have not been triple rinsed.  As discussed in Chapter




6, phosphate mining  and processing wastes amount to about 220 million




tons annually (however, as discussed in Section 7.1.2, these  wastes
                                  7-7

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                                               TABLE  7-2

                         ESTIMATED QUANTITY OF HAZARDOUS MANUFACTURING  WASTES
                             AND NUMBER OF ESTABLISHMENTS EXCLUDED  FROM
                            REGULATION AT A GENERATOR LIMIT  OF  100  KG/MO
I
00


EPA Region
I
II
III
IV
V
VI
VII
VIII
IX
X
National
total
Number of
manufacturing
establishments
excluded
5,270
13,200
7,180
14,900
14,200
7,090
3,760
2,110
9,750
3,820

81,420
Percent of total
manufacturing
establishments
excluded
23
25
25
33
21
.29
26
33
26
34

26
Hazardous
Percent of total.
manufacturing hazardous
wastes excluded manufacturing
(1000 metric tons) wastes excluded
1.9
4.1
2.7
5.5
5.0
2.7
1.5
0.9
3.5
1.5

29.3
< 0.1
< 0.1
< 0.1
< 0.1
< 0.1
< 0.1
< 0.1
< 0.2
< 0.2
< 0.2

< 0.1

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would be subject to a limited portion of the Subtitle C storage,




treatment, and disposal regulations).




     Waste pesticide containers from persons engaged principally in




farming or solely in retail trade would not be subject to the




Subtitle C regulations.  This exclusion, coupled with the unknown




portion of waste pesticide containers already included in the




estimates of manufacturing wastes, precludes any determination of the




quantity of waste pesticide containers that would be subject to the




regulations.  The remainder would, however, be subject to the




requirements of the Federal Insecticide, Fungicide, and Rodenticide




Act of 1972, as amended.




     The identifying characteristics could result in the regulation




of such other large volume wastes as waste automotive oil, coal ash,




oil drilling muds and brines, cement kiln dusts, and dredge spoils.




Estimates of the annual production of these wastes are presented in




Chapter 6.  The portion of such wastes that could be identified as




hazardous by the characteristics is not known.




     7.1.2  Changes to Existing Generation, Transport, Storage,




Treatment, and Disposal Practices and Procedures.  Typical practices




and procedures used by generators, transporters, storers, treaters,




and disposers of hazardous wastes are discussed in Chapter 5.  The




Subtitle C regulations would lead to a number of major changes in




these existing practices and procedures.  The changes would primarily
                                  7-9

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be caused by the enactment of more stringent environmental require-




ments than those that currently exist, resultant increases in treat-




ment and disposal costs, and specific procedural and operational




requirements imposed by the regulations.   The intent of this section




is to indicate the scope of applicability of the Subtitle C regula-




tions and the major changes likely to occur in existing practices and




procedures as a result of the promulgation of the regulations.




     It is anticipated that at least five years would be required for




the changes in existing practices and procedures to become fully




established.  Several years would be required for hazardous waste




generators to become fully aware of the specific economic implica-




tions of the regulations, to assess the alternatives available to




them (e.g., process modification, increased recycling of hazardous




wastes, shifts in on-site and off-site treatment/disposal practices),




and to implement any changes.  Due to resource constraints, several




years would also be required for EPA or authorized states to act upon




all permit applications and to issue permits to acceptable storage,




treatment, and disposal facilities.  Facilities requiring modifica-




tions as a condition of their permits would then have up to three




years to complete such modifications.  Furthermore, the necessary




integration and coordination of RCRA requirements with those of other




acts (e.g., Federal Water Pollution Control Act and Safe Drinking
                                  7-10

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Water Act) requires that there be some delay in permit issuance.  For




example, in those instances where a treater or disposer has a Nation-




al Pollution Discharge Elimination System (NPDES) permit, issuance of




the RCRA permit would be delayed until the time that the NPDES permit




is to be renewed.  In addition, since very few states would currently




be qualified to attain full authorization, regulatory requirements in




those states granted interim authorization would be changed over




several years as the states become qualified for full authorization.




     7.1.2.1  Generation.  The regulations applicable to generators




(Section 3002 of Subtitle C) apply only to those persons or Federal




agencies, except households, who produce and dispose of more than 100




kilograms (about 220 pounds) per month of wastes identified as haz-




ardous under the Section 3001 regulations.  Any person or Federal




agency producing and disposing of 100 kilograms or less per month




would not be required to comply with the generator regulations; also




any generator engaged solely in retail trade or principally in




farming would have to comply with the regulations only with regard to




waste automotive oil. Generators excluded from compliance with the




Subtitle C regulations would, however, still be obligated to dispose




of their hazardous wastes in an acceptable manner, e.g., in a




landfill that meets RCRA Subtitle D criteria.




     The Subtitle C regulations would result in procedural changes




described below in the methods used by these regulated generators for




tracking and reporting hazardous waste shipments and for preparing




such shipments for transport.  The regulations could also lead to



                                  7-11

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process changes that would allow increased resource conservation

and/or recovery of hazardous wastes.

     Manifest.  Under the Subtitle C  regulations, every generator

would be required to provide a manifest for each off-site hazardous

waste shipment—intrastate, interstate, and international—sent to a

facility not owned by the generator and to file reports and keep

records on such shipments.  Generators designating hazardous waste to

an off-site facility owned by the generator and located in the same

state as the generator would have to  provide a manifest, but would

not have to comply with the reporting or recordkeeping requirements

(although the facility itself would be subject to reporting and

recordkeeping requirements under Section 3004); shipments to

generator-owned facilities in other states would have to comply with

the reporting and recordkeeping requirements.  On-site shipments

would not have to be manifested, but  would have to be sent to

permitted on-site facilities and would have to be reported to

appropriate Federal or state authorities.*  Appendix B, Subpart B

describes the required content of the manifest and reports.  The

major purposes of the manifest would be to ensure that off-site

shipments of hazardous wastes are sent only to permitted storage,

treatment, or disposal facilities and to ensure that all such wastes

are actually delivered to the facility to which they are sent
*0ff-site as used throughout this statement means any facility or
 location not on a generator's property.  On-site means any facility
 or location on a generator's property.
                                   7-12

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(Appendix J describes numerous incidents from the indiscriminate




dumping of wastes in transit)-




     Currently, there are very limited mechanisms for tracking of




hazardous wastes.  Based upon Tables 2-3 and 2-4, only 10 states have




(or have proposed) standards for manifesting of hazardous wastes by




generators and only two other states have standards for manifesting




by transporters; an additional 14 states have (or have proposed)




enabling authority to enforce manifest requirements, but do not have




standards.  Nine states have (or have proposed) reporting standards




applicable to generators; 15 others have (or have proposed) enabling




authority for enforcing reporting by generators.  In addition,  for




the small portion of hazardous wastes that meet the Department  of




Transportation (DOT) criteria of a hazardous material under the




Hazardous Materials Transportation Act (49 CFR 100-189),  any inter-




state or international shipment of such wastes by common or contract




carriers must be accompanied by shipping papers prepared and signed




by the consignor (generator).  In addition, over 30 states have cur-




rently adopted, with or without modification, the DOT Hazardous




Material Regulations and apply them to intrastate shipments by  common




and contract carriers.




     Due to these limited tracking mechanisms, generators, state




authorities, and Federal authorities, have little or no information




as to what currently happens to a large portion of the hazardous




wastes that are shipped off the generator's site; state and Federal




authorities also have little or no information about what happens to



                                 7-13

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a considerable amount of the wastes that remain on the generator's




site for treatment or disposal.   Furthermore,  in states which do not




have manifesting or reporting requirements, the ultimate fate of the




wastes is not known for a very large portion of the wastes; for




example, in Kansas the disposal  location is not known for almost 80




percent of the industrial wastes generated in the state and




in Massachusetts the disposal location is not known for about 65




percent of the industrial wastes (see Table 5-14).  Even in those




states with manifest and reporting standards,  the disposal location




is not always known; for example, in Texas, the fate of about 20




percent of the hazardous wastes  is not known.




     To remedy this, the Subtitle C regulations would make the gen-




erator responsible for determining where his hazardous wastes are to




be delivered when sent off-site  and for identifying those shipments




that may not have been delivered to the designated destination.  The




manifest (or the equivalent delivery document) would have to be




signed by authorized representatives of the generator, the trans-




porter, and  the designated delivery facility; after the waste is de-




livered to the designated treatment, storage, or disposal facility,




the signed original of the manifest (or equivalent delivery document)




would have to be returned to  the generator to verify that the waste




has been delivered.  Generators  would have to file quarterly reports




on all manifested shipments for which a signed manifest copy (or




equivalent delivery document) is not returned.  In addition, genera-




tors designating wastes  for off-site shipment would be required to



                                  7-14

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file annual reports based on the information in the manifests and to




keep a copy of each manifest for a period of three years.  Generators




who designate hazardous wastes for on-site treatment, storage, or




disposal would also have to file annual reports identifying the types




and quantities of wastes managed on-site.




     Containerization and Labeling.  Under the Subtitle C regula-




tions, the generator would also be required to containerize all




wastes for transport in accordance with the DOT regulations on pack-




aging under 49 CFR 173, 178, and 179.  If no specific packaging is




required, the generator would have to place the hazardous wastes in a




package in accordance with the DOT regulations on standard require-




ments for all packages (49 CFR 173.24(a), (b), and (c)(2)-(9)).  In




addition, the generator would have to label and placard each shipment




in accordance with DOT regulations on hazardous materials (49 CFR




172) and mark each package in accordance with DOT regulations on




marking (49 CFR 172.300) or with the EPA hazardous waste name (see




Appendix B, Subpart A, 250.14), as applicable.  Each package must




also contain the manifest document number and the generator's




identification number.




     The DOT regulations cited above currently apply only to inter-




state or foreign shipments by common or contract carriers or to




intrastate shipments by common or contract carriers in those states




which have adopted the DOT regulations.  The Subtitle C regulations




would extend these DOT regulations to all hazardous waste shipments.







                                   7-15

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     Process Changes to Promote Resource Conservation and Recovery.
In addition to these procedural changes, the Subtitle C regulations
would have the potential to cause generators to modify processes that
generate hazardous wastes in order to increase resource conservation
and recovery.  Since one major result of the regulations would be to
increase generator's costs and those costs associated with hazardous
waste transportation, storage, treatment,  and disposal, generators
would potentially have an incentive to modify processes so as to
reduce and/or change the types and amounts of hazardous wastes gen-
erated by such processes and to enable the increased recycling of
hazardous wastes as process feedstocks.  According to a recent study
on hazardous waste management, (Foster D.  Snell, Inc., 1976), there
is currently a trend in hazardous waste producing industries to
recover, reuse, or recycle waste products  that were once either
treated or dumped; the primary reasons being economics and public
relations.
     As discussed in Section 5.4, the potential for process modifi-
cations to promote resource conservation and/or recovery would be
extremely waste stream and process specific and would depend upon
such factors as the economics of disposal,, treatment, and transport;
the cost of raw materials and energy; the availability of markets for
and sources of recyclable hazardous wastes; and the availability both
of the necessary technology for specific resource conservation or
recovery applications and of environmentally adequate disposal meth-
ods.  Due to the many complex interrelationships among these factors,
                                  7-16

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the determination of specific process modifications and resultant
changes to waste streams that could occur as a result of promulgation
of the Subtitle C regulations is beyond the scope of the EIS.
     7.1.2.2  Transport.  The regulations applicable to transporters
(Section 3003 of Subtitle C) apply to any person or Federal agency
transporting, within the United States, hazardous wastes that require
a manifest under the generator regulations and also apply to any
transporter importing a shipment of hazardous wastes from abroad.
The transporter regulations do not apply to persons or Federal agen-
cies transporting hazardous wastes solely on the site of generation
or solely on the site of a permitted hazardous waste management
facility.  While the transporter regulations do not apply to hazar-
dous waste shipments not requiring manifests, if any person or Fed-
eral agency consolidates for shipment and transports any quantity of
unmanifested hazardous wastes from more than one source, the entire
shipment would have to be delivered to a permitted facility and would
have to comply (for both interstate and intrastate shipments) with
applicable DOT Hazardous Materials Regulations (49 CFR 100-189)
concerning shipping papers, labeling, marking, placarding,  and trans-
portation.  Data are not available to estimate the number of trans-
porters that would be affected by the tranporter regulations (see
Appendix E).
     As discussed below, the Subtitle C regulations would signifi-
cantly curtail the 'midnight dumping' of hazardous wastes and would
likely result in changes in the handling of transportation-related
                                 7-17

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spills,  in the distances  over which hazardous wastes are transported,
and in existing operational  procedures  and practices used for the
transport of hazardous wastes.
      Midnight Dumping.  There are  numerous reported instances of
hazardous waste transporters dumping wastes surreptitiously rather
than delivering the wastes to an environmentally acceptable storage,
treatment, or disposal facility (see Appendix J).  Because such il-
legal disposal often occurs  at night, this practice has been termed
midnight dumping.  Data are  not available to quantify the total num-
ber of  such incidents, nor  the amount  of wastes disposed annually
through midnight dumping; however,  the  following example illustrates
the potential magnitude of the problem.  New Jersey shut down its
last legal land disposal site to chemical waste dumping nearly three
years ago.  The site was handling about one million gallons of chemi-
cal wastes per week when it  was eliminated.  At this time it is not
known where most of the wastes that formerly went to such landfills
are currently being disposed, but there are reported incidents of
illegal disposal throughout  New Jersey (Richards, 1978).
     The manifest and reporting requirements discussed in Section
7.1.2.1 should significantly reduce, if not eliminate, the practice
of midnight dumping.  These requirements effectively transfer the
opportunity for midnight dumping from the transporter to the genera-
tor and, to a  lesser degree,  to the receiving facility.  To the ex-
tent that generators manifest all off-site hazardous waste shipments
and truthfully indicate the type and quantity of hazardous waste
                                  7-18

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being transported, midnight dumping should be nearly eliminated,  pro-
viding the receiving facility accurately confirms the contents of
wastes delivered.
      Spills.  Section 2.3 indicates existing laws for the reporting,
prevention, and containment of transportation-related spills of haz-
ardous substances.  Only those hazardous wastes and other spilled
materials which meet the definitions and criteria for hazardous
materials under the DOT Hazardous Materials Transportation Regula-
tions or which are specifically listed under Section 311 of the
Federal Water Pollution Control Act as amended would come under these
existing spill regulations.  The Hazardous Materials Transportation
Regulations require reporting, but not clean up or containment, of
transportation-related spills of hazardous materials.  These require-
ments, however, apply only to interstate commerce or to intrastate
shipments in those states which have adopted the Hazardous Materials
Transportation Regulations.
     Section 311 of the Federal Water Pollution Control Act applies
only to spills of* the listed substances which threaten navigable
waters and which are into or upon the navigable waters of the U.S.,
adjoining shorelines, contiguous zones, or which may affect appli-
cable natural resources.  Section 311 requires the reporting and
clean-up of such spills by the responsible party.
     The Subtitle C regulations extend reporting and clean-up re-
quirements to all transportation-related spills of hazardous wastes
or hazardous materials which become hazardous wastes under Section
                                  7-19

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3001 when spilled.   In the case of a spill,  transporters would have
to immediately telephone either the National Response Center (U.S.
Coast Guard) or the government official predesignated as the on-
scene coordinator,  pursuant to 40 CFR 1510;  a written report would
have to be filed within 15 days with the DOT Office of Hazardous
Materials Operations.  The transporter would also have to clean up
all spilled hazardous waste or take such action as may be required by
Federal, state, or local agencies so as to ensure that the spilled
waste no longer presents a hazard to human health or the environment.
     Transport Distances.  The average distance over which hazardous
wastes are transported would likely increase as a result of the Sub-
title C regulations.  This increase would result from several
factors.  First, the portion of wastes being shipped to off-site
facilities for treatment and disposal, rather than remaining at
on-site facilities, would most likely increase as discussed in
Section 7.1.2.4.  Second, all hazardous wastes would have to be
transported to permitted facilities, not just to any nearby disposal
site.  Since it would not likely be economically or environmentally
practical to site permitted facilities near every generator, the
average distance wastes would have to be transported should increase.
Third, increases in disposal costs resulting from the proposed regu-
lations should increase the distance over which waste may be economi-
cally transported for resource recovery purposes.

     According to a recent hazardous waste transport study (Arthur D.
Little, Inc., 1978a), most hazardous waste transport is by truck with
                                  7-20

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typical off-site transport distances ranging from 25 to 150 miles;




most of the surveyed firms reported transport distances of about 50




miles.  However, based on the limited number of firms replying to




the survey- the study concluded that the reported truck transport




distances might not be representative of the industry as a whole.




Most hazardous wastes transported by rail or barge are reported to go




to reclamation or resource recovery facilities; transport distances




on-the-order of 100 or more miles are common for such shipments.




Data are not available to determine by how much typical transport




distances are likely to increase as a result of the Subtitle C




regulations.




     Existing Practices and Procedures.  The Subtitle C regulations




would modify existing practices that have in the past led to re-




leases of hazardous wastes during transport and would impose addi-




tional procedural requirements on transporters to enable easier




identification of both the transporter and the wastes being trans-




ported.  For example, the regulations require that the transporter




not accept shipments of hazardous wastes unless such shipments are




accompanied by a manifest signed by the generator and are in con-




tainers which are not leaking or damaged and which are properly




labeled and marked.  In addition, the transporter (and any other




subsequent transporter(s)) is to sign the manifest; insure that the




manifest (or equivalent delivery document) accompanies the shipment




at all times; placard and mark the transport vehicle; deliver the




entire quantity of hazardous wastes to permitted facilities; and keep



                                  7-21

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a copy of the manifest (or delivery document) for at least 3 years.




If the transporter consolidates  or mixes hazardous wastes from




different generators or separate wastes from the same generator, the




transporter would also have to comply with the generator regulations




if the consolidated mixture was  no longer adequately identified by




the manifest.




     Not all of the above requirements represent entirely new re-




quirements on all transporters.   For example, as discussed in




Appendix E, most transporters presently keep delivery documents for




at least 3 years due to various  Federal and state regulations.  In




addition, common and contract carriers engaged in the interstate




transport of hazardous materials, as defined in the DOT Hazardous




Materials Transportation Regulations, have to comply with equivalent




placarding requirements and are  not to accept shipments of hazardous




materials unless accompanied by shipping papers signed by the con-




signor (generator).




      7.1.2.3  Storage.  RCRA defines storage as the containment of




hazardous wastes, either on a temporary basis or for a period of




years, in such a manner as not to constitute disposal.  The regula-




tions applicable to storers (Section 3004 of Subtitle C) apply,




except as noted below, to all storage at off-site storage, treatment,




or disposal  facilities and to all on-site storage by generators prior




to on-site treatment or disposal; the regulations do not apply  to  on-




site  storage by generators who store their own wastes for less  than




90 days prior to subsequent transport off-site, but do apply  to any



                                   7-22

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such on-site storage which lasts for 90 days or longer.  Facilities




specifically excluded from complying with the storage regulations




include Publicly Owned Treatment Works (POTW) and ocean dumping




barges and vessels.  In addition, facilities that store only 'special




wastes', and no other hazardous waste, would have to comply only with




the General Facility Standards (e.g., manifest system, recordkeeping,




reporting—see Appendix B, Subpart D, 250.43) and not with any other




storage regulations.  All facilities regulated would require permits




under Section 3005 of Subtitle C.  Section 7.1.3.5 contains estimates




of the number of potential permittees.  Data are not available to




estimate the quantities of wastes that would be affected by the




storage regulations.




     As discussed below, the Subtitle C regulations would result in




the elimination of current storage practices that lead to or become a




form of disposal and would result in changes in the current design




and operation of storage facilities.




     Indefinite Storage.  Currently there are few regulations, if




any, that limit the time that wastes may be left in storage.  As a




result, there are a number of reported incidences of hazardous wastes




being placed in storage for indefinite periods of time, sometimes in




very large quantities (see Appendix J).  In many such instances, the




wastes in storage are ultimately abandoned, rather than being dis-




posed in an acceptable manner, and are left to enter the environment.
                                  7-23

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Even when the wastes are not abandoned,  overly long storage times

have resulted in weathering and/or corrosion of containers and

weathering of storage piles, causing the eventual release of the

stored wastes into the environment.

     The Subtitle C regulations contain provisions that would

eliminate the indefinite storage of hazardous wastes.  At facility

close-out*, all hazardous wastes would have to be removed from all

storage and treatment operations, including surface impoundments that

do not meet the Subtitle C criteria for landfills, and would have to

be disposed as required by the regulations (see Section 7.1.2.4).

Facilities would have to post a bond that would be held until the

completion of both closure and post close-out care to ensure com-

pliance, t

     Facility Design and Operation.  The Subtitle C regulations would

prohibit or restrict existing storage practices that result either in

the  discharge of hazardous wastes or in the storage of such wastes in

an environmentally unacceptable manner.  For example, the regula-

tions require that storage operations be conducted in such a manner

that no discharge occurs and such that storage facilities be moni-

tored and  inspected for the purpose of detecting any potential
 *Close-out  is the point in time at which facilities stop accepting
  hazardous  waste for treatment, storage, or disposal.
 TClosure  is the series of actions to be completed within 3 years
  following  close-out during which a facility is to be secured
  pursuant to Subtitle C regulations.  Post close-out is the period
  which  need not exceed 20 years following closure during which
  required monitoring and maintenance activities are to be conducted.
                                   7-24

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discharge; that all storage areas be constructed so as to be capable




of containing any run-off or spills that occur, plus have sufficient




freeboard to allow for collection and containment of precipitation;




that storage areas be constructed of materials that are compatible




with the wastes to be contained; that incompatible wastes (see




Appendix D, Subpart D, Annex 4 for examples) not be mixed together;




and that facilities not be located on or near active fault zones or




in areas where they could be inundated by a 500-year flood.   As indi-




cated by the reported incidences listed in Appendix J, such  regula-




tions would necessitate many changes both in the design and  in the




operation of hazardous waste storage facilities.  Data are not avail-




able to estimate the number of facilities that would be affected,  nor




to determine the specific changes that would be required for most




such facilities.




     7.1.2.4  Treatment/Disposal.  With the few specific exclusions




noted below, the regulations applicable to treaters and disposers




(Section 3004 of Subtitle C) apply to owners and operators of any




facility that treats and/or disposes any quantity of any waste




identified as hazardous under the Section 3001 regulations (Appendix




B, Subpart A),  except those wastes listed as "special wastes'.  All




owners and operators of facilities that treat and/or dispose of




"special wastes', and no other hazardous waste, would have to comply




only with the General Facility Standards of the treatment and dis-




posal regulations (Appendix B, Subpart D, 250.43).
                                 7-25

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      Certain disposal practices  that are controlled under other




Federal acts are not regulated under the treatment and disposal




regulations of Subtitle C.   These practices include underground




(deep-well) injection, ocean dumping,  discharges to municipal sewer




systems, surfaces discharges under a National Pollution Discharge




Elimination System (NPDES)  permit,  and all treatment and disposal




activities at Publicly Owned Treatment Works (POTW).  However, the




treatment and disposal regulations would apply to above ground stor-




age or treatment of hazardous wastes prior to underground injection,




on-shore facilities associated with ocean dumping activities, and




surface impoundments associated with NPDES permitted industrial




wastewater treatment facilities and hazardous sludges from such




facilities.  All facilities regulated would require permits under




Section 3005 of Subtitle C.  Section 7.1.3.5 contains estimates of




the number of potential permittees under the Subtitle C regulations.




     As discussed below, the Subtitle C regulations would lead to the




closing or modifying of many existing treatment/disposal facilities




and to significant changes  in current treatment/disposal practices.




In addition, the regulations would likely affect the portion of




hazardous wastes treated/disposed on-site and off-site.




     Facility Closing or Modification.  A major impact resulting from




the Subtitle C regulations  would be the closing of those hazardous




waste management facilities (both off-site and on-site) that could




not or would not comply with the treatment/disposal requirements and
                                 7-26

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the modification of other hazardous waste management facilities to




enable compliance with the requirements.  Facilities requiring




modifications would have to make such modifications in accordance




with compliance schedules contained in permits issued to them under




the Section 3005 regulations.  The modifications would have to be




made within 3 years from the original date of issuance of the




compliance schedule; for compliance schedules exceeding 6 months,




interim compliance requirements would also have to be met every 6




months.




     Data are not available to estimate the number and type of




hazardous waste treatment/disposal facilities that would have to




close down or be modified as a result of the proposed regulations.




However, based on the reported incidences in Appendix J and other




available data discussed below, it is expected that a very large




portion of existing facilities would require modification to be able




to comply with the treatment/disposal requirements.  For example,




less than 10 percent of hazardous manufacturing wastes from 14 major




generating industries are estimated to have been treated/disposed in




an environmentally acceptable manner in recent years (see Table 5-7).




While some of this environmentally unacceptable treatment/disposal




could be made acceptable by the use of alternative treatment methods




instead of by facility modification,  it is likely that the vast




majority of existing treatment/disposal facilities handling such




wastes would require modifications in order to comply with the







                                  7-27

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treatment/disposal requirements.   For example, of 80 estimated




hazardous waste management service industry landfills currently




handling some form of potentially hazardous waste, approximately 20




could meet secure landfill standards (Foster D. Snell, Inc., 1976;




Straus, 1977).  Furthermore,  according to the Industry Studies




(1975-1978), the vast majority of hazardous industrial wastes that




are disposed in landfills are disposed in general purpose landfills




rather than secure landfills  (see Appendix D).  Additionally, about




16,000 land disposal sites accepted municipal wastes in 1976; most




also received some industrial waste; only about 100 had impermeable




linings and only about 200 had leachate collection systems (Waste




Age, 1977).  Appendix D discusses other examples of facilities that




could require modifications.




     Changes in Current Treatment/Disposal Practices.  Those existing




hazardous waste treatment/disposal practices that are environmentally




unacceptable according to the Subtitle C regulations would be pro-




hibited or restricted or would have to be modified; some practices




could be replaced by other, more environmentally acceptable prac-




tices.




     Existing practices that  are likely to,be prohibited or severely




restricted by the Subtitle C  regulations include:  open burning;




uncontrolled incineration; road application of untreated waste oil;




the use of landfills without leachate collection systems and ground-




water monitoring systems; the use of surface impoundments without







                                   7-28

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leachate detection systems and groundwater monitoring systems;




landfarming of highly volatile wastes or wastes containing arsenic,




boron, molybdenum and/or selenium in concentrations greater than soil




background conditions; the location of landfills, surface impound-




ments, and landfarms within 150 meters (500 feet) of functioning




public or private water supplies or livestock water supplies; and the




mixing of incompatible wastes in surface impoundments and basins,




except for the purpose of treatment.  In addition, the Subtitle C




regulations specifically prohibit such existing practices as open




dumping; the placing of reactive wastes, ignitable wastes, and highly




volatile wastes in landfills, surface impoundments, or basins; the




mixing of incompatible wastes in landfills and landfarms; the use of




waste application practices that allow the zone of incorporation of




landfarms to become anaerobic; and the use of continuous feed treat-




ment facilities without automatic waste feed cut-offs or by-pass




systems that are activated when a malfunction occurs.




     The Subtitle C regulations also impose specific requirements for




the closure of treatment/disposal facilities.  For example, at final




closure all disposal operations would have to be completed and all




wastes removed from treatment facilities and disposed in accordance




with the regulations.  Hazardous wastes and hazardous waste residue




would also have to be removed from all surface impoundments that do




not meet the standards for landfills and disposed according to the




regulations.  Any contaminated soil-filter medium at landfarms would






                                  7-29

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also have to be removed.   Monitoring and maintenance care would have
to be provided for a period  that  need not exceed 20 years from

close-out.
     For the most part,  data are  not available to enable an estimate
of the quantity of hazardous wastes  currently treated/disposed by
each of the above practices, the  number of off-site or on-site
treatment/disposal facilities that would be affected by such pro-
hibition or restrictions,  nor any potential shift likely to occur in
the quantities of hazardous  waste treated/disposed by various methods
as a result of the regulations.   Specific changes would be dependent
upon such factors as treatment/disposal economics; waste characteris-
tics; adequacy of available  pollution control devices; availability
and adequacy of alternative  treatment/disposal methods; and site-
specific conditions such as  climate, soil characteristics, and
groundwater characteristics.
     As previously discussed, available data indicate that about 90
percent of the hazardous manufacturing wastes from 14 major generat-
ing industries are estimated to have been treated/disposed in an
environmentally unacceptable manner  in recent years.  For each method
used for treating/disposing  of these wastes, the portion of the waste
estimated to have been treated/disposed in an environmentally unac-
ceptable manner using that method is as follows (see Table 5-7):
surface impoundment—over 99.9 percent; dumping and landfilling—
about 95 percent; incineration—about 65 percent; other (road appli-
cation, landfarming, deep-well injection)—almost 100 percent.
                                 7-30

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      Table 5-11 shows, for four of these 14 industries, the esti-




mated percentage of hazardous wastes treated/disposed by environmen-




tally inadequate methods in recent years.  Between 95 and 100 percent




of the hazardous wastes were treated/disposed by such methods in




these industries.  Battelle Columbus Laboratories (1978) has esti-




mated, for selected hazardous waste streams from these 14 industries,




the percentage of the generating facilities in the industry that have




been using environmentally inadequate treatment/disposal methods in




recent years.  For most of the hazardous waste streams reviewed, 70




percent or more of the facilities were estimated to have used




environmentally inadequate treatment/disposal methods.




     Due to the enactment of more stringent Federal and state en-




vironmental regulations in the period since these 14 industries were




surveyed (1973-1975), it is likely that a somewhat greater portion of




hazardous waste is now being treated/disposed in an environmentally




acceptable manner in these industries.  For analysis purposes, based




upon a hazardous industrial waste generation of about 40 million




metric tons in 1984, and assuming, as an upper limit, that 90 percent




of such wastes would continue to be treated/ disposed in an environ-




mentally inadequate manner without the promulgation of the Subtitle C




regulations, it is estimated that these regulations could result in




up to an additional 36 million metric tons of hazardous industrial




wastes being treated/disposed in an environmentally adequate manner




annually by 1984.






                                  7-31

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     Change in Hazardous  Wastes  Treated/Disposed On-site and Off-

site.  The Subtitle C regulations  would likely lead to changes in the

portion of hazardous wastes treated/disposed on-site by generators

and off-site by the waste management industry.  Based upon the Indus-

try Studies (1975-1978),  about 82  percent of all hazardous industrial

wastes are typically treated/disposed on-site by the generator; about

15 percent are treated/disposed  off-site; about 3 percent are re-

claimed.  The percentage  treated/disposed on-site and off-site, how-

ever, varies widely from  industry  to industry (see Table 5-10).*

     The trend in at least one industry is to increase the portion of

hazardous wastes being treated/disposed on-site.  A study of hazard-

ous waste practices in the petroleum refining industry (Jacobs En-

gineering Company, 1976)  indicated that on-site treatment/disposal

was expected to increase  from 44 percent in 1974 to 73 percent by

1983; most of the change  was expected to be due to increases in on-

site landfarming and landfilling.   The major reasons reported to be

given by the industry (prior to the enactment of RCRA) for the poten-

tial increase in on-site  treatment/disposal are as follows:

     •  The emerging stringent water and air emission requirements
        dictate that increasing volumes of hazardous wastes may need
        to be discharged  to the land since'land disposal is not as
        stringently regulated at the present time;
*These percentages are based upon a survey of a limited number of
 establishments within each manufacturing industry.  According to the
 Industry Studies, while the numbers for each industry are typical
 of those establishments which replied to the survey, they may not be
 representative of each industry as a whole.
                                  7-32

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     •  The legal protection surrounding the use of private property
        (as observed in a review of existing solid waste laws as they
        apply to private on-site versus public off-site disposal)
        sometimes allows industry to dispose of industrial wastes on
        its own property without the necessity of permit,  monitor-
        ing, or supervision and control by regulatory agencies;

     •  The present trend is one of increasingly stringent require-
        ments by regulatory agencies surrounding disposal  of in-
        dustrial wastes to outside municipal or private landfills;

     •  The closure of many dumps, lagoons, and sumps over the past
        few years has seriously reduced the availability of nearby
        disposal sites;

     •  The cost of transporting large volumes of wastes long dis-
        tances to certified secure hazardous waste disposal sites
        would bring about significant economic and price dislocations
        to a segment of the industry and place certain refineries at
        an immediate disadvantage.

     The Subtitle C regulations would likely reverse, or signifi-

cantly reduce, such a trend to on-site treatment/disposal  since the

regulations contain stringent requirements for the treatment/

disposal of hazardous wastes and apply these requirements  equally to

on-site and off-site treatment/disposal.  Thus, one of the primary

advantages given for on-site treatment/disposal—little or no

regulation—would be eliminated.

     Several factors would affect the portion of hazardous wastes

treated/disposed on-site and off-site under Subtitle C.  For the most

part, these factors would be very industry; waste stream,  and site

specific and, as a result, it is not possible to accurately determine

the extent of any shift that could occur ujader the Subtitle C regu-

lations.
                                  7-33

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      Factors that  would tend to  increase the portion of wastes

treated/disposed off-site under the Subtitle C regulations are as

follows:

     •  An indeterminable portion of the  existing on-site treatment/
        disposal facilities  would not be  able to be modified to
        comply with the Section 3004 requirements and would have to
        cease operation;

     •  A portion of generators,  especially small generators,  who
        currently dump or otherwise dispose wastes on-site in  an en-
        vironmentally inadequate  manner would not be able to afford
        permittable treatment/disposal facilities or would not want
        to construct such facilities and  would have to ship
        wastes off-site;

     •  Certain existing practices would  be prohibited or severely
        restricted and a portion  of those on-site facilities
        employing such practices  would likely send wastes off-site
        instead of using alternative on-site practices;

     •  In some states off-site treatment/disposal currently tends to
        be more stringently  regulated than on-site disposal;
        enactment and enforcement of stringent regulations applicable
        both off-site and on-site treatment/disposal would tend to
        make on-site treatment/disposal less advantageous;

     •  Off-site hazardous waste  management facilities in EPA  Region
        IX have the highest  capacity utilization rates in the  U.S.
        for every type of treatment/disposal practice due to strict
        and uniform enforcement of treatment/disposal in the region
        compared to most other regions and due to siting problems re-
        sulting in restricted hazardous waste management capacity
        (Foster D.  Snell, Inc., 1976).

     Factors that could tend to limit any potential increase in the

portion of hazardous wastes  transported off-site include:

     •  Public opposition to siting of off-site facilities;

     •  The inability to locate permittable off-site facilities
        relative to generator needs and the treatment/disposal
        capacity available at such facilities;
                                  7-34

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     •  Potential increases in volume reduction and in resource con-
        servation and recovery practices as a result of Subtitle C
        which could reduce the quantity of hazardous wastes requiring
        disposal.

     To quantify the potential shift in on-site and off-site dispos-

al,  available state data were reviewed to determine whether such

shifts have occurred in states that have enacted hazardous waste

legislation,  and the extent of any such shifts.  As indicated in

Section 5.3.6, only a few states currently have accumulated suffi-

cient data to enable an estimation of the portions of hazardous

wastes generated within the state that are being treated/disposed

on-site versus off-site (see Table 5-14).  Comparable historical data

are not available from these states to enable a determination of any

change in the portion of wastes treated/disposed on-site and off-site

following enactment of the state's hazardous waste (or equivalent

solid waste)  legislation (personal communication with representatives

of the following state agencies:  California Department of Health,

Vector Control Section, 1978; Florida Department of Environmental

Regulation, Solid Waste Section, 1978; Illinois Environmental Pro-

tection Agency, Division of Land Pollution Control, 1978;  Kansas

Department of Health and Environment, Bureau of Environmental Sani-

tation, Solid Waste Section, Hazardous Waste Unit, 1978; Maryland

Department of Health and Mental Hygiene, Environmental Health Admini-

stration, Division of Solid Waste, 1978; Massachusetts Bureau of

Solid Waste Disposal, 1978; Minnesota Pollution Control Agency,
                                 7-35

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Division of Solid Waste,  Hazardous Waste Section,  1978;  Rhode Island




Department of Health,  Division of Solid Waste Management,  1978; Texas




Division of Solid Waste Management,  1978).




     In Illinois, on-site disposal is  reported to  be down  and off-




site (including out-of-state)  disposal up following enactment of the




state's solid waste legislation;  the percentage change is  not avail-




able (Personal Communication,  Illinois Environmental Protection




Agency: Division of Land Pollution Control,  1978).  In California,




the hazardous waste going off-site is  not expected to decrease as a




result of the state's  hazardous waste  legislation  (Personal communi-




cation, California Department  of Health, Vector Control  Section,




1978).  Estimates of the direction of  any other potential  shifts are




not available from the other states.




     Of those states listed in Table 5-14,  Illinois and  Texas cur-




rently have hazardous  waste regulations closest to those that would




be promulgated under Subtitle  C.   In addition, the data  for Illinois




and Texas in Table 5-14 are based upon the required reporting of




current practices; the data for all the other states are based upon




less recent, limited surveys directed toward determining existing




hazardous waste practices in each state and needed changes in the




state's hazardous waste regulation.  Furthermore,  Illinois and Texas




have permitted facilities both on-site and off-site while  several of




the other states, e.g., Kansas and Rhode Island, do not  have
                                  7-36

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permitted off-site facilities (most wastes go out-of-state in such




instances).




     For the reasons cited above, the Illinois and Texas data are




used, solely for analysis purposes, to provide an estimated range for




the portion of hazardous wastes that might be disposed off-site by




1984 under the Subtitle C regulations.  It should be noted that these




data are being used as a surrogate to analyze potential impacts that




could occur from a shift in on-site and off-site disposal, should




such a shift occur, and not as a firm estimate of the magnitude of




any such shift.




     Under this surrogate method, and assuming that the wastes whose




disposal location is unknown in these two states are disposed on-site




and off-site in the same ratio as those wastes whose disposal loca-




tion is known (see Table 5-14), about 25 percent of the hazardous




wastes in Illinois and about 13 percent of the hazardous wastes in




Texas are estimated to be disposed off-site.   For 1984, a range of 13




to 25 percent off-site treatment/disposal of hazardous industrial




wastes  is thus used to analyze the potential impacts that could




occur from probable shifts in off-site and on-site disposal under the




Subtitle C regulations.  For 1980, it is assumed that 15 percent of




hazardous industrial wastes would continue to be treated/disposed




off-site.  It should be noted that the range used for 1984 includes




both eventualities previously discussed—a slight decrease or a
                                  7-37

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moderate increase in the portion of hazardous wastes currently esti-

mated to be shipped off-site for treatment/disposal.

     7.1.3  Administrative Changes.  Implementation of the Subtitle C

regulations would necessitate a widesweeping series of administrative

changes that would affect industry, state governments, and the

Federal government.  Potential effects are assessed in the following

sections with regard to:

     •  State administration of programs;

     •  Overlapping Federal and state hazardous waste programs;

     •  Number of generators required to comply with the regula-
        tions

     •  Number of transporters required to comply with the
        regulations;

     •  Number of storers, treaters, and disposers required to obtain
        permits;

     •  Paperwork requirements under the regulations.

     7.1.3.1  State Administration of Programs.  As specified in

Section 3006 of RCRA, states are to be encouraged to apply to the

U.S. Environmental Protection Agency for authorization to administer

and  enforce their own hazardous waste program pursuant to Subtitle C.

There would be three different types of authorization for which

states could apply:  full authorization, partial authorization, and

interim authorization.

     Full authorization would allow a state to carry out a hazardous

waste program in lieu of the Federal program under Subtitle C.

According to RCRA, a state application for full authorization must be

                                  7-38

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approved unless the state program is determined:  not to be equi-

valent to the Federal program; not to be consistent with the Federal

program or with those programs authorized by EPA in other states; and

not to provide adequate enforcement of compliance with the require-

ments of Subtitle C.

     To be considered equivalent, a state program would have to have

legislative authority, published criteria and standards, a permit

mechanism, a manifest system, identification of resources, inter-

agency delineation of responsibilities (if applicable), and public

participation.  To be consistent, a state program would have to allow

for the free movement of hazardous wastes (e.g., no ban on the impor-

tation of hazardous wastes from other states) and would not be al-

lowed to have standards that are more stringent than necessary (e.g.,

standards designed to discriminate against out-of-state wastes).

Adequacy of enforcement would be judged on a state-by-state basis; no

quantifiable standards have been set.

     Partial authorization would allow a state to administer and en-

force selected components of a hazardous waste regulatory program es-

tablished pursuant to Subtitle C.*  EPA would retain responsibility

for the remaining components of the program.  States would be con-

sidered for partial authorization only if state legislative authority
*Individual program components include a waste tracking system (mani-
 fest system); control of treatment,  storage,  and disposal of hazar-
 dous wastes through a permit system; conducting inspections and
 taking samples; and regulations governing hazardous waste generators
 and transporters and owners/operators of hazardous waste treatment,
 storage, and disposal facilities.

                                  7-39

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did not exist for all required program components.  The state would




be expected to run those program components for which it had legis-




lative authority, providing the state program was enforceable, con-




sistent with, and equivalent to the Federal program.  In all cases,




the combination of state and the Federal programs would have to meet




the requirements of a fully authorized program.  Before granting




partial authorization, EPA would expect the state to agree to submit




proposed legislation to the state legislature so as to remedy the




deficiencies preventing full authorization.  It is expected that




partial authorization would not be available during the two year




interim authorization period discussed below.  Partial authorization




would be granted for a period not to exceed five years, but could be




renewed.




     Interim authorization would allow a state to carry out a hazar-




dous waste program in lieu of the Federal program under Subtitle C




for a period not to exceed twenty-four months, beginning on the date




six months after the date of promulgation of regulations under




Section 3001.  The purpose of interim authorization is to allow the




state to make an orderly transition from its present program to a




program eligible for full authorization.  To be eligible for interim




authorization, a state would have to have a hazardous waste program




pursuant to state law in existence prior to the the date 90 days




after the date of promulgation of regulations under Sections 3001 of
                                  7-40

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Subtitle C.  To achieve interim authorization, the state program




would have to be substantially equivalent to the Federal program and




would have to provide an Authorization Plan which describes the




addition or modifications necessary to qualify for full authorization




together with the schedule for such additions or modifications.




Substantial equivalency encompasses:  legislative authority, iden-




tification of resources, a permit mechanism, surveillance and




enforcement, and public participation.  In addition, the state would




have to agree with EPA on an oversight procedure which would allow




EPA to monitor the state's program to ascertain that the program was




being administered and enforced in accordance with RCRA.




      To achieve full, partial, or interim authorization, a state




must have prior legislative authority to provide the necessary pro-




gram components.  Chapter 2 contains a detailed description of the




existing and proposed state hazardous waste legislation.  Currently,




15 states have separate and specific laws governing the management of




hazardous wastes; another 10 states and one territory have proposed




hazardous waste legislation.  Thirty-six states (including the




latter 10) and two territories have currently addressed hazardous




waste management as a separate section within their solid waste




legislation.  The state programs vary widely with regard to such




factors as wastes controlled,  published criteria and standards,
                                 7-41

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on-site and off-site control of wastes,  and importation bans.*

     EPA staff estimates  are that between 45 and 50 of the 56 states

and territories that could qualify for interim authorization under

the Subtitle C regulations.  Of those which could qualify for interim

authorization, 3 to 5 might also currently qualify for full authoriza-

tion.  No states would be able to qualify for partial authorization

before the end of the interim authorization period.

     7.1.4.2  Overlapping State Programs.  Although RCRA encourages

states to administer their own authorized hazardous waste program in

lieu of the Federal program, states are not required to administer

such programs.  If a states does not choose to administer a program

under Subtitle C of RCRA, there would be a Federally run program in

that state.  RCRA, however, does not prohibit states without auth-

orized programs from enacting and enforcing their own more stringent

or non-consistent hazardous waste program to be run in the state in

addition to the Federal program.

     At this  time, it is not known if any state would run such a

program in addition to the Federal program or what regulations would

be promulgated under any such overlapping program.  Such additional


*Six states currently have specific  importation bans.  These states
  are Louisiana, Maine, Massachusetts, New Hampshire, Rhode Island,
  and Vermont.  In addition, Oklahoma has legislation equivalent to an
  importation  ban.  Such bans preclude full authorization. .A recent
  U.S.  Supreme Court decision (No. 77-404; June 23, 1978; City of
  Philadelphia et al. _y_. New Jersey et al.) struck down New Jersey's
  statutory importation ban.  It  is not clear how importation bans in
  other states would be affected  by this  decision.
                                   7-42

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state programs, if enacted, would have the potential for creating




various impacts.  Some of the major potential problems that could




result from the enactment of overlapping Federal and state programs




are briefly illustrated below.




      An overlapping state program would likely subject hazardous




waste generators, transporters, storers, treaters, and disposers to




conflicting and/or duplicative requirements and regulations.  For




example, storers, treaters, and disposers could be required to obtain




two permits, with potentially different requirements, before they




could construct or operate facilities.  Generators could be required




to fill out two separate manifests for each off-site shipment or




could be required to manifest wastes that would not be considered




hazardous under the Federal program.  Everyone generating or managing




hazardous wastes within such states could be required to prepare and




store two different sets of overlapping reports or to prepare and




store reports not required under the Federal program.  Economic




dislocations could result to firms located within such states if the




more stringent standards significantly increased the firm's cost of




doing business relative to that of firms in other states.  Under such




conditions some generators might choose to relocate to other states.




     Increased transportation demands and distances could result if




more wastes had to be shipped further distances within the state or




to out-of-state facilities due to increased controls within the gen-




erating state, or if wastes formerly going to one state had to be
                                  7-43

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shipped to a more distant state due to enactment of import bans.




However, transportation demands and distances could also be reduced




in some states if increased controls or import bans in adjacent




states significantly reduced the amount of wastes being shipped out-




of-state. Localized shortfalls in storage, treatment,  and disposal




capacity could result from or be exacerbated by stricter regulations




and import bans.  In the short run, there could be increased




instances of illegal or less desirable disposal in states with such




capacity shortfalls.  In the long run, there could be additional




waste treatment or process modifications.




     Furthermore, while an overlapping state program would likely




afford increased protection to the residents of that state, it would




likely hinder the effectiveness of the Federal program on a national-




scale and could result in a reduced level of protection for residents




of other states.  For example, importation bans or other regulations




hindering the free movement and/or disposal of wastes  could result in




some hazardous wastes being managed in a less effective or less de-




sirable manner than would otherwise have occurred.




     7.1.3.3  Number of Generators Required to Comply with the




Regulations.  Potential hazardous waste generators within the scope




of this EIS are expected to fall within the following SIC Codes:




     •  Agriculture, forestry, fishing (SIC 07-09);




     •  Manufacturing (SIC 20-39);




     •  Transportation and public utilities (SIC 40-46  49)-
                                  7-44

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     •  Wholesale trade (SIC 50-51);




     •  Retail trade  (SIC 52, 54-55, 58-59);




     •  Services (SIC 72-73, 75-76, 78, 80, 82, 84, 88-89);




     •  Public administration (SIC 95-97).




Not all producers of hazardous wastes within these SIC codes would be




required to comply with the Subtitle C regulations.  Section 7.1.2.1




delineates those hazardous waste producers who would be considered




generators subject to the Subtitle C regulations.




     Available data generally relate to the manufacturing industries




and to selected other industry categories in which large numbers of




establishments are likely to produce hazardous wastes.  These indus-




try categories are discussed below to illustrate the potential mag-




nitude of both the number of hazardous waste producers and the number




of generators required to comply with the regulations based on a




generator limit of 100 kilograms per month.




     Magnitude of Potential Generators of Hazardous Wastes.




     Manufacturing Industries.  There are over 313,000 manufacturing




establishments in the United States (See Tables 7-3 and 7-4).  While




every one of these manufacturing establishments is not likely to be a




potential producer of hazardous wastes, the limited data available




preclude an accurate determination of the number that are.  An esti-




mate,  solely for purposes of analysis, is made as described below.




     A recent study (Fred C. Hart Associates, 1978) summarizes the




available data as to the number of establishments generating
                                  7-45

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                              TABLE  7-3




      NUMBER OF  MANUFACTURING  ESTABLISHMENTS  BY 2-DIGIT SIC CODE*
Industry
Food and kindred products
Textile mill
Apparel and other textile
Lumber and wood
Furniture and fixtures
Paper and allied products
Printing and publishing
Chemicals and allied products
Petroleum and coal products
Rubber and plastics
Leather and leather products
Stone, clay, and glass
Primary metals
Fabricated metal products
Machinery, except electrical
Electric and electronic equipment
Transportation equipment
Instruments and related products
Miscellaneous
TOTAL
SIC code
20
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
-
Number of establishments
28,185
7,204
24,430
33,931
9,242
6,047
42,103
11,430
2,080
9,271
3,206
16,025
6,795
30,299
40,795
12,268
8,804
5,989
15,185
313,289
*Based on Appendix K.
                                    7-46

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                              TABLE 7-4

         NUMBER OF MANUFACTURING ESTABLISHMENTS BY EPA REGION*

EPA Region
I
II
III
IV
V
VI
VII
VIII
IX
X
Number of Establishments+
23,258
52,302
28,213
45,729
68,994
24,360
14,322
6,619
38,126
11,366

*Based on Appendix K.
+SIC Codes 20, 22-39.
                                  7-47

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hazardous wastes within major industrial groups.  That study cautions

that the data provided on the number of hazardous waste producers can

only be regarded as tentative because the data are based on many dif-

ferent reports in which different criteria were used for identifying

hazardous wastes and hazardous waste generators.  Table 7-5 shows the

manfacturing SIC Codes considered in that study and indicates, by EPA

Region, the estimated number of establishments and hazardous waste

producers within the selected SIC Codes.  Based on Table 7-5, an esti-

mated 90 percent of the manufacturing establishments in the selected

manufacturing SIC Codes generate some hazardous wastes.  Assuming

that this percentage holds for all manufacturing establishments,

based on Table 7-3, it is estimated that about 282,000 manufacturing

establishments produce some hazardous wastes.

     Other Major Categories of Generators.  Other than the manufac-

turing industries, industry categories in which there would likely be

large numbers of hazardous waste generators include, but are not

limited to, automotive service stations*, hospitals, medical labora-

tories, and research facilities.!  It is estimated that there would

be up to 283,000 potential generators within these categories (see

Table 7-6).
*Automative service stations include gasoline service stations,
 general automotive repair operations,  and motor vehicle dealers.
tAs discusssed in Section 7.1.2.1,  any  hazardous waste generator
 engaged solely in retail trade or  farming would be considered a
 generator subject to the regulations only with regard to waste
 automotive oil.  It is expected that as a result of this exclusion,
 there would be very few such generators subject to the regulations.
                                  7-48

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                                                                                    TABLE 7-5
                                                                  POTENTIAL  HAZARDOUS WASTE GENERATORS WITFIN
                                                                SELECTED MANUFACTURING  INDUSTRIES BY EPA REGION*
 I
-P-

Industry
Organic chemicals, pesticides
and explosives
Ferrous metals

Electroplating
Job shops
Captive shops
Inorganic chemicals

Nonferrous metals
Textiles
Petroleum refining
Plastics materials and
synthetics
Special machinery
Leather tanning
Paint and allied products

Pharmaceuticals
Petroleum re-refining and
processing
Rubber

Electronic components
Batteries
TOTAL

SIC codes
2861, 2865, 2869,
2879, 2892
3312, 3313, 332,
3399

3471
N.A.t
2812, 2813, 2816
2819
333, 33A1
22
2911
282

355, 357
3111
2851
N . A
N.A. t
2831, 2833, 2834
2992 + others

3011, 3021, 3031,
3041, 3069
367
3691, 3692
-

Number of
establishments
2,226

1,780


2,254
12,000
1,600

346
5,300
247
462

4,610
517
1,544
on
yu
45,000
1,100
1,544

1,539

2,855
262
85,276

I
72

1


326
1,741
2

10
258
	
36

439
103
81
5
54
	

178

367
17
3,690

II
336

15


277
1,476
16

37
367
7
53

715
71
294
17
282
23

186

588
17
4,777
Number of
III IV
286 401

63 37


176 157
936 327
15 27

41 34
206 998
18 16
59 94

322 528
15 11
120 182
7 10
115 106
15 37

128 193

230 173
24 44
2,776 3,875
potential
V
388

59


861
4,584
21

91
71
35
99

990
42
393
eeners
VI
275

12


99
528
34

40
30
80
55

192
4
118
23 /
215 68
37

495

524
52
8,980
23

82

132
24
1,803
tors In
VII
135

2


115
612
4

16
15
13
8

147
5
77
4
81
15

47

78
18
1,392
EPA reeion
VIII
75

3


31
168
4

12
4
29
2

47
5
14
1
20
9

18

36
7
485
IX
198

12


163
863
9

45
49
37
54

538
15
221
13
143
33

187

694
41
3,315
X Total
60 2,226

10 214


49 2,254
265 12,000
6 138

20 346
9 2,007
12 247
2 462

130 4,048
6 277
44 1,544
3 90
16 1,100
14 206

25 1,539

33 2,855
13 257
717 76,810
                 *Modified from Fred C.  Hart Associates,  Inc.,  1977.
                tNot available.  Captive shops are counted under the SIC Code of the parent
                  establishment.

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                           TABLE 7-6
     ESTIMATED NUMBER OF POTENTIAL PRODUCERS OF HAZARDOUS
               WASTES WITHIN SELECTED CATEGORIES
Category
     Number of
potential producers
Service industry
  Hospitals*
  Medical laboratories*
  Research facilities*
    Sub-total
Retail industry
  Automotive service stationst
Special wastes
  Cement manufacturing^:
  Coal-fired utilities §
  Oil drilling
  Phosphate rock mining and processing
  Uranium mining
  Other mining
       7,200
       3,200
       5,700
      16,100
     267,000


         100
       250-275
     Not available
     Not available
     Not available
     Not available
*Fred C. Hart Associates,  Inc.,  1977.
tModified from Fred C.  Hart Associates estimates based upon
 EPA staff estimates that  only 90 percent of gasoline service
 stations would produce hazardous wastes; the other 10 percent
 are self-service stations which are not likely to produce
 hazardous wastes.
^Holberger et al.,  1978.
SPersonal communications,  National Ash Association  1978.
                              7-50

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     With regard to 'special wastes' that would be hazardous under




the Section 3001 regulations, up to about 375 cement manufacturing




plants and coal-fired utilities could potentially be producers of




such wastes (see Table 7-6).  Data are not available to estimate the




number of potential producers of other hazardous 'special wastes';




however, the number could be large.  For example, 10,000 to 20,000




oil wells have been drilled annually in recent years with about 60




percent of these wells being successful (U.S. Department of the




Interior, 1976); however, the number of currently producing wells




generating potentially hazardous brines and muds is not known.




     Number of Hazardous Waste Generators Required to Comply With the




Subtitle C Regulations.  The generator regulations provide that




establishments producing and disposing of more than 100 kilograms per




month of wastes are to be identified as hazardous waste generators




subject to regulation.   Table 7-2 shows, by EPA Region, the esti-




mated number of manufacturing establishments producing less than 100




kilograms of hazardous wastes per month and the total amount of




hazardous wastes produced annually by such establishments.  Over




81,000 manufacturing establishments could potentially be excluded




from complying with the regulations based upon a generator limit of




100 kilograms per month.  While these establishments represent about




26 percent of all manufacturing establishments within the SIC Codes




considered, they produce less than 0.1 percent of the total hazardous




wastes produced by all manufacturing industries within these particu-




lar SIC Codes.



                                   7-51

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     Based upon this information and a study by Fred C. Hart Asso-




ciates (1976),  the total number of manufacturing establishments




generating hazardous wastes that potentially may not have to comply




with the generator regulations is estimated to range between 81,000




and 112,000.  The total number that potentially may have to comply is




estimated to range between 201,000 and 232,000.  The establishments




required to comply are estimated to generate over 99.9 percent of all




hazardous wastes produced by the manufacturing industries.




     With regard to automotive service stations, EPA staff estimates




are that about 35 percent of all gasoline service stations would be




likely to generate 100 kilograms or less per month of hazardous




wastes; thus, up to 210,000 automotive service stations could have to




comply with the generator regulations.  In addition, up to about




16,100 hospitals, medical laboratories,  and research facilities could




have to comply (see Table 7-6).




     Thus, there would potentially be on the order of 430,000 to




460,000 generators within these three categories who could be subject




to the generator regulations.




     7.1.3.4  Number of Transporters Required to Comply with the




Regulations.  Hazardous wastes are transported, by highway; rail,




waterway, air, and pipeline, with the vast majority being transported




by truck (see Appendix E).  Hazardous waste transporters include




hazardous waste generators, treaters, and disposers as well as estab-




lishments engaged solely in transport activities.  According to a
                                 7-52

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recent study of the hazardous waste transport industry (Arthur D.




Little, 1978a), the number of firms currently transporting hazardous




wastes is unknown, both for the industry as a whole and for each of




its segments.




     7.1.3.5  Number of Storers, Treaters, and Disposers Required to




Obtain Permits.  Sections 7.1.2.3 and 7.1.2.4 delineate those hazard-




ous waste storers, treaters, and disposers who would be required to




obtain permits.  A study by Battelle Columbus Laboratories (1978)




attempted to estimate the number of potential permittees under the




regulations.  Table 7-7 shows the Battelle Columbus Laboratories'




estimate of  the number of potential permittees for the manufacturing




industries (listed in Table 7-5), Federal installations, hospitals,




automotive service stations, and the existing hazardous wastes




management service industry.  There are estimated to be about 29,000




potential permittees within these groups.  According to that study,




data are not available to estimate the number of potential permittees




within other categories.




     With regard to treaters, storers, and disposers of 'special




wastes', there could be potentially a large number of permittees.




For example, in Wyoming alone there are about 10,000 lagoons used for




the disposal of oil drilling muds and brines.  Data are not available




to estimate  the portion of  'special wastes' that would be identified




as hazardous, nor the number of potential permittees managing such




hazardous 'special wastes'.







                                  7-53

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                               TABLE 7-7
               ESTIMATED NUMBER OF POTENTIAL PERMITTEES*
                                                      Number of
      Category                                  potential permittees

Manufacturing industry
  Electronic components                                 325
  Electroplating and metal finishing
    Job shops                                           7A4
    Captive shops                                     4,000
  Explosives                                            577
  Inorganic chemicals                                   138
  Leather tanning and finishing                          30
  Metals smelting and refining                          549
  Organic chemicals                                     845
  Paint and allied products                             235
  Pesticides                                            512
  Petroleum refining                                    143
  Petroleum re-refining                                   7
  Pharmaceuticals                                       421
  Plastics                                              462
  Rubber products                                        65
  Special machinery                                     781
  Storage and primary batteries                          52
  Textiles                                              190
  Miscellaneous                                      11,659
     Sub-total                                       21,735
Government
  Federal installations                                 241
Service industry
  Hospitals                                           7,174
  Hazardous waste management                            HO
     Sub-total                                        7,284
Retail industry
  Automotive  service stations                            o

  Total                                              29,260
 *Modified from Battelle Columbus Laboratories, 1978.

                                 7-54

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      7.1.3.6  Paperwork Requirements Under the Regulations.  The




Subtitle C regulations establish reporting and recordkeeping require-




ments for generators, transporters, storers, treaters, and disposers




of hazardous wastes.  Many of these reporting and recordkeeping re-




quirements would be in addition to existing requirements.




     Generators would be required to prepare a manifest for each




off-site hazardous waste shipment, keep a copy of each manifest for




three years, submit a quarterly report on manifested shipments for




which the signed original manifest (or delivery document) is not




returned, and submit an annual report based on the manifests or on




wastes managed on-site.  Transporters would be required to keep a




copy of manifests (or delivery documents) for a perid of at least




three years.  Owners/operators of permitted hazardous waste manage-




ment facilities (i.e., storers, treaters, and disposers) would be




required to keep a copy of each manifest (or delivery document) for 3




years and also to prepare and keep for 3 years, records of specified




operating conditions, records of employee training,  and records of




groundwater monitoring.  In addition, each owner/operator would be




required to prepare and keep until facility closure a log containing:




the location and types of wastes disposed at the facility, required




waste analyses, required monitoring data, results of required visual




inspections, and records of any human health or environmental damage




caused by the facility.  Each owner/operator would also be required




to submit both an annual report based upon manifests received during
                                  7-55

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the year and a quarterly report on groundwater and leachate moni-
toring,  if applicable.   Each  owner/operator would also have to submit
a permit application and appropriate supplemental material.  In
addition, within 90 days following promulgation of the Section 3001
regulations, all generators,  transporters,  storers,  treaters, and
disposers would be required to notify the EPA Regional Adminis-
trator (or an authorized state) that they fall into one of these
categories.
     Number of Manifests.  Based on the assumptions stated in Section
7.1.4.1, it is estimated' that there could be between 350,000 and
690,000 off-site shipments of hazardous industrial wastes annually by
1984, necessitating industrial generators to prepare between 350,000
and 690,000 manifests annually.  An indeterminable number of mani-
fests could also have to be prepared by other generators.  The aggre-
gated generators, transporters, and owners/operators of hazardous
waste management facilities would each have to keep between 1.0 and
2.1 million manifests in storage on an annual basis.  Most transport-
ers currently keep at least 3 years worth of delivery documents in
storage due to various state and Federal requirements (see Appendix
E).  To the extent that transporters use acceptable delivery docu-
ments in  lieu of manifests or use manifests in lieu of existing
delivery documents, this recordkeeping requirement would not consti-
tute an additional burden on transporters.  However, as indicated in
Chapter 2, most states do not require generators or hazardous waste
management facilities to prepare or retain records on hazardous waste
                                   7-56

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shipments and, as a result, much of such recordkeeping under subtitle




C would represent an additional requirement.




     Other Recordkeeping Requirements.  Generators would also have to




keep records on wastes managed on-site to enable preparation of an-




nual reports.  Each owner/operator of a permitted hazardous waste man-




agement facility would have to keep an operating log for the life of




the facility, plus 3 years worth of those records specified above.




Most of this recordkeeping would represent an additional requirement,




based upon existing state regulations.




     Number of Recurring Reports.  Approximately 430,000 to 460,000




annual reports could potentially be prepared by the previously iden-




tified generators, assuming that generators who dispose wastes both




on-site and off-site prepare one combined annual report for both




types of disposal.  Permittees would have to prepare annual reports




only if they receive manifested wastes.  Most of the potential permit-




tees listed in Table 7-7 would be on-site facilities and would not




have to prepare additional annual reports.  Hazardous waste manage-




ment service industry facilities and Federal installations could




prepare about 350 additional annual reports.  An indeterminable




number of additional annual reports would also have to be prepared by




other generators and hazardous waste management facilities such as




generators or disposers of "special wastes'.




     Each permittee would also have to submit four monitoring reports




annually,  if there was a potential for discharge to groundwater from
                                  7-57

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the facility.  Based on Table 7-7,  there could be up to 117,000 such




monitoring reports submitted annually.




     Thus, there could be upwards of 547,000 to 577,000 reports pre-




pared and submitted annually by generators and hazardous waste man-




agement facilities.  Most of these reports would represent additional




reporting requirements, based upon existing state regulations.




     Number of Non-recurring Reports.  The previously identified gen-




erators and permittees would have to file about 430,000 to 460,000




notifications under Section 3010 with EPA or authorized states.  An




indeterminable number of transporter and other potential generators




and permittees would also have to file such notifications.




     Transporters could potentially have to file between 140 and 270




spill reports annually, based upon Section 7.1.4.1.  Permittees would




have to file an indeterminable number of incident reports annually.




The potential permittees identified in Table 7-7 would have to submit




approximately 29,000 permit applications and additional supplemental




material.  The permit application consists of two parts which may be




submitted separately or together.  Most of these submittals would




represent additional requirements, based upon existing state regu-




lations.




     7-1.4  Air Impacts.  This section discusses potential impacts




that could occur with regard to air quality and climate as a result




of promulgation of the Subtitle C regulations.
                                   7-58

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     7.1.4.1  Air Quality Impacts.  Current hazardous waste genera-




tion, transport, and storage, treatment, and disposal practices in-




volve a variety of activities, each of which has the potential for




releasing air pollutants to the environment.  The potential for the




release of air pollutants by each of these activities (e.g., land-




filling, incineration, containerization) would be affected in differ-




ent ways by the Subtitle C regulations.  This section discusses




current sources of air pollutants from each of these activities,




incidents that have occurred from current practices, and the ways in




which the proposed regulations could affect potential air pollutant




releases from these sources and practices.




     Air Quality Impacts Relative to the Generation of Hazardous




Waste.  The Subtitle C regulations would apply only to those air




emissions, and resultant air quality impacts, that are produced by




activities occurring after the generation of hazardous wastes.   The




regulations would not apply to those air emissions produced during




the generation of hazardous wastes, nor to those air emissions pro-




duced from the reuse of hazardous wastes as an integral part of




subsequent process steps without intervening storage.  Thus, the




Subtitle C regulations would not have a direct effect on air emis-




sions resulting from hazardous waste generation.  However, to the




extent that the regulations change the economics of disposal or




treatment, and thus result in process modifications engineered to




recycle hazardous wastes or to reduce or alter the quantity and/or







                                   7-59

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types of hazardous waste generated,  Subtitle C could indirectly

result in changes  in process  air emissions.

     Air Quality Impacts Relative to Storage of Hazardous Wastes.

Current practices  in the storage of  hazardous wastes can lead to the

release of air pollutants in  three major ways:

     •  Through fugitive emissions resulting from improper storage of
        hazardous  wastes;

     •  Through emissions resulting  from spills, fires, explo-
        sions, and other accidental  releases of hazardous wastes
        and/or their constituents;

     •  Through emissions occurring  as the result of storage becoming
        the ultimate form of  disposal of hazardous wastes.

As discussed below, the Subtitle C regulations would reduce, to vary-

ing degrees, the existing potential  for release of air emissions from

each of these sources.  In addition, any facility construction and/or

modification required by the  Subtitle C regulations would affect

construction-related air emissions.

     Fugitive emissions are currently likely to occur in a number of

ways.  The loading or placing of hazardous wastes into storage con-

tainers, storage piles, or surface impoundments currently results in

the release of fugitive emissions containing the hazardous waste

itself.  For example, the loading of solid wastes, particularly fine

waste materials, onto open storage piles is  likely to result in

particulate matter which contains hazardous  waste constituents

becoming airborne in the vicinity of the loading area.  The loading

of hazardous wastes containing volatile materials into tanks or other

containers is also likely to  result  in the escape of fugitive air
                                  7-60

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emissions.  In both cases, the amounts of fugitive emissions emitted

is dependent upon the characteristics of the specific wastes being

stored, the degree of controls employed (e.g., dust or vapor recovery

systems), and the adequacy of maintenance operations, particularly

for pump seals, joints, flanges, and other equipment used with

volatile wastes.

     A major current source of fugitive emissions is the escape of

air pollutants from hazardous wastes which have not been properly

covered or containerized during storage.  Such wastes may be subject

to the release of particulate matter containing the hazardous waste

as a result of wind erosion.  Volatile wastes stored in containers

without adequate controls are also a potential source of fugitive

emissions.  The quantity of fugitive emissions produced is dependent

upon the volatility of the waste, the adequacy of the container and

its seals, and the effectiveness of any control equipment present.

Liquid wastes stored in surface impoundments and basins are also a

source of fugitive emissions due to evaporative losses and/or

volatilization of hazardous components.

     While data are not available to estimate the magnitude of fugi-

tive emissions presently occurring from hazardous waste storage, the

following reported incidents illustrate the types of air quality

problems that have occurred under current practices (see Appendix J

for other incidents):

     •  Since 1867, asbestos product manufaturers have accumulated
        nearly 2 million cubic yards of assorted industrial wastes in
        open piles in a small Pennsylvania town.  The original

                                  7-61

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        generator of the wastes  went out of business in 1962.  Since
        then two other  companies have been responsible for enlarging
        the spoils piles.  The air in the vicinity of the piles has
        been observed to contain asbestos fibers due to wind erosion.
        An air-monitoring program conducted by the U.S. Environmental
        Protection Agency in October 1973 indicated ambient back-
        ground levels of asbestos in the area to be 6 ng/m-*.  An
        asbestos level  of 9.6 ng/m3 was  found at a playground near
        the largest waste pile.   Values  obtained near active disposal
        piles ranged from 114 to 1745 ng/m3 (Office of Solid Waste
        Program, 1974a).

     •  A firm engaged  in the disposal of spent chemicals was storing
        and disposing of toxic chemical  wastes at two Louisiana
        locations.  At  one of these sites,  several thousand drums of
        waste (s-ome with and some without lids) were in s-tora-g-e-^
        Many of the drums were popping their lids and leaking; vis-
        ible vapors were emanating from the area.  The pine trees
        beside the storage area were all killed as a result of this
        leakage (Office of Solid Waste Programs, 1974a).

     The Subtitle C regulations contain provisions that should, to a

large degree, reduce the potential for such fugitive air emissions

from the storage of hazardous wastes.  For example, the Section 3005

regulations would require that all owners/operators of hazardous

waste storage facilities, except storage facilities operated by

generators who store hazardous wastes for 90 days or less prior to

off-site treatment/disposal in an approved facility, obtain a permit

for such storage.  To obtain and keep a  permit, such storage facili-

ties would have to comply with the Section 3004 storage regulations.

According to these regulations,  hazardous waste storage operations

would have to be conducted in such a manner that no discharge occurs-

these storage operations would also have to be monitored and inspec-

ted to detect any potential discharge. Hazardous wastes which could

release air emissions that could adversely affect human health or the

                                  7-62

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environment if stored in an open manner would be required to be
stored in tanks or other closed containers.  Hazardous wastes to
which this requirement would apply include those which could poten-
tially release air contaminants in concentrations, measured at the
surface of the storage area, exceeding the Threshold Limit Values
(TLV) listed in Appendix B, Subpart D, Annex 2.   For example, the
asbestos-containing wastes previously discussed would likely have to
be stored in closed containers under the Subtitle C regulations
rather than placed in open piles.
     Furthermore, the regulations require that containers used to
store hazardous wastes must not be opened, handled, or stored in any
manner which could rupture the container or cause it to leak.  Wastes
in containers whose contents begin to leak would have to be recon-
tainerized.  Also, storage containers and tanks would have to be con-
structed of materials, or contain a liner, which are compatible with
the wastes stored.  These requirements would apply, for example, to
the hazardous wastes stored in leaking containers at the Louisiana
storage site previously discussed.  Under the Subtitle C regulations,
such wastes would have to be recontainerized and stored in another
manner less susceptible to leakage.
     In addition, volatile wastes—those with a true vapor pressure
greater than 78 mm mercury at 25 C—would not be allowed to be stored
in surface impoundments or basins under the Subtitle C regulations.
Storage tanks with a capacity in excess of 19,000 liters (5,000 gal-
lons) would not be allowed to be vented directly to the atmosphere if
                                 7-63

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they contained such volatile wastes.  Examples of listed hazardous




waste constituents (Appendix B,  Subpart A, Paragraph 250.14(a)) which




have vapor pressures greater than that specified above and which have




also been identified in hazardous industrial waste streams (see




Appendix C) include:  acrolein,  benzene, chloroform, methyl bromide,




trichloroethane, and vinyl chloride (Perry et al. , 1973).  The




Louisiana landfill incident cited above illustrates one type of inci-




dent that has occurred from fugitive emissions from the storage of




volatile wastes.




     Spills, fires, explosions,  and other accidents represent a




second major source of potential air emissions from current hazard-




ous waste storage practices.  Improper storage and mixing of incom-




patible wastes and the improper storage and handling of potentially




explosive or ignitable wastes have been major contributors to fires




and explosions in hazardous waste storage areas in the past.  Incom-




patible wastes are those wastes unsuitable for commingling with




another waste or material because the commingling might result in:




extreme heat or pressure generation; fire; explosion or violent reac-




tion; formation of substances which are shock-sensitive, friction-




sensitive, or otherwise have the potential of reacting violently;




formation of toxic dusts, mists, fumes, gases, or other chemicals;




volatilization of ignitable or toxic chemicals due to heat genera-




tion.  Appendix B, Subpart D, Annex 4 presents examples of potential-




ly incompatible wastes.
                                  7-64

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     Volatile wastes and wastes composed of fine materials are those




most likely to release air contaminants emissions as a result of




storage accidents.  In addition, ignitable wastes which catch fire as




a result of an accident are a further source of emissions.  Fires




could also create and release additional hazardous air contaminants




not originally present in the hazardous waste itself (Appendix M




describes some of the emissions that could occur from the combustion




of hazardous wastes).




     The following data illustrate the potential for such impacts




under current practices.  In 1976 there were, from sources other than




transport activities, approximately 4,000 spills of hazardous materi-




als (not generally wastes) reported under Section 311 of the Federal




Water Pollution Control Act (see Section 6.4.).  Over 1,300 of the




total reported spills (transportation and non-transportation related)




involved waste materials, primarily waste oil.  In 1976 in Ohio there




were another 160 reported spills involving potential air pollution




problems (this includes spills of both hazardous wastes and nonwaste




materials from storage and transportation).  Of the 160 reported




spills, 39 involved hazardous air pollutants such as ammonia, chlo-




rine,  acetone, hydrochloric acid, dimethoate, hexamethylene, para-




thion,  vinyl chloride, propargyl alcohol, perchloroethylene, xylene,




butyl  acrylate, titanium tetrachloride, chlorinated hydrocarbons,




hydrogen peroxide, ethyl ether, and nitric acid (State of Ohio,




1976).
                                  7-65

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     The following incidents identify some of the types of accidents

that have occured with a potential for releasing air pollutants.

Additional examples of such incidents are discussed in the section on

treatment/disposal of hazardous wastes and in Appendix J.

     •  In 1973, a major chemical company in Virginia contracted with
        a processing firm in Alabama to pick up, haul, and dispose
        approximately 10,000 drums of aramite waste, containing 30
        to 80 percent sulfuric acid.  Most of the wastes were shipped
        in 208 liter (55-gallon) steel drums and 190 liter (50-
        gallon) fiber drums.  The wastes brought to Alabama were
        never processed and remained in two open storage areas and in
        one enclosed warehouse.  Due to weathering, physical stress,
        and the corrosive and harsh nature of the wastes, many of the
        drums stored in the two open areas disintegrated and their
        contents spread over the adjacent ground.  In addition to
        contamination of local waters (chemical analysis of samples
        of drainage water from the storage site indicated very high
        acidity and high concentrations of heavy metals), the storage
        of waste at the three locations prsented a great fire hazard.
        On March 9 and 10, 1976, a fire broke out at the site, and
        two firefighters became ill, presumably due to inhalation of
        toxic fumes.

     •  At a land disposal site in Southern California, a tanker
        unloaded a waste listed as "waste acid" into a subsurface,
        bottomless tank through an open stack above the ground.
        Shortly after the unloading operation commenced, yellowish-
        brown clouds of nitrogen dioxide began to emanate from the
        open stack.  The reaction appeared to have subsided when the
        discharging of the wastes ceased.  However, an hour later,
        additional nitrogen dioxide started to spew from the stack.
        The emission was halted by filling the stack with soil.
        There were no reported injuries; however, there were many
        complaints from nearby businesses, and a factory was
        evacuated.

     •  The following incident while it did not involve wastes per
        se, illustrates the potential for combustion of wastes due to
        fire and the associated problems.  In April 1971,.a fire
        occurred in the warehouse in Okanogen County, Washington,
        where about 2 tons of pesticides were stored, including
        guthion, parathion, endrin, dieldrin, DDT, and other chlori-
        nated hydrocarbons.  Nearly 50 tons of fertilizer were also
        stored in the building.  Toxic emissions from the burning of
        these chemicals forced the evacuation of nearby residents.
                                   7-66

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        Officials also feared the possibility of explosions caused by
        the fertilizers.   Nearly 2 million gallons  of water were
        required to extinguish the fire.   Much of this water spilled
        into the street and flowed through gutters  and storm sewers
        to the Okanogen River 1/2 mile away-  Endrin at a level of
        0.8 ppm was detected in the run-off into the river in early
        April.  Also,  a city well about 500 feet from the fire site
        showed a nitrate concentration of 34.4 ppm in early June.
        Expectant mothers and small children were cautioned to avoid
        drinking the city water for a period of 2 weeks after the
        incident.

     The Subtitle C regulations contain provisions  that should reduce

the potential for fires,  explosions, and other accidents at hazardous

waste storage facilities and the potential for impacts from any acci-

dents that do occur.  For example, the Section 3004 regulations

require that storage containers holding wastes that are incompatible

would have to be separated from each other or protected from each

other in order to prevent the wastes from mixing should the con-

tainers break or leak.  Storage areas would have to be constructed to

contain any spills that might occur.  Explosive, ignitable, or highly

reactive wastes (see Appendix B, Subpart A, Section 250.13) would  not

be allowed to be stored in surface impoundments or  basins.  Incompat-

ible wastes would not be allowed to be mixed in storage basins, nor

in surface impoundments except for treatment purposes.

     One of the major causes of the mixing of incompatible wastes  or

the improper storage of explosive, ignitable, or highly reactive

wastes has been the lack of accurate information about the waste

being provided to the waste handler (Office of Solid Waste, Hazardous

Waste Management Division, 1978a).  The manifesting and labeling

requirements under Section 3002 would make such information more
                                  7-67

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readily available and would further reduce the potential for acci-




dents from the improper storage of such wastes.




     In addition, owners/operators of storage facilities would have




to inspect storage areas daily for rust, corrosion, cracks, and




spills.  Also, hazardous waste storage facilities would have to




prepare contingency plans to minimize human health or environmental




damage in the event of an accidental discharge of hazardous materials




to the surrounding air, surface,  or subsurface environment (see




Appendix B, Subpart D, 250.43-4).  To the extent that this latter re-




quirement and the spill containment requirement reduce the time




necessary to clean up spills or prevent additional accidental dis-




charges, there would be a reduction in air pollutants and resultant




impacts from any such accidental  releases.  Furthermore, other




reductions in fugitive emissions, as previously discussed, would




reduce the potential for fires and explosions from such emissions,




especially from volatile wastes.




     A third source of air emissions are current practices in which




hazardous wastes are placed in storage for indefinite periods of




time; in many such cases the hazardous wastes are ultimately aban-




doned rather than being disposed.  Such wastes may be stored in con-




tainers or may be stored in an open manner.  Due to such factors as




weathering and/or corrosion, containers eventually rupture or leak




releasing their contents to the environment.  As discussed above




volatile, flammable, or fine waste materials are the most likely






                                 7-68

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sources of air emissions following such releases.  Also, any such

releases increase the potential for the mixing of incompatible wastes

with the resultant consequences described above.  Wastes which were

not originally containerized would be subject to erosion and/or

volatilization during the time that they were in storage.

     Several incidents have previously been cited illustrating the

potential problems from indefinite storage of hazardous wastes (i.e.,
                                                                    *
asbestos storage piles in Pennsylvania and aramite waste in Alabama).

The following incident further illustrates the potential problem:

     •  In 1971, a major chemical company in New Jersey contracted
        with an independent waste transporter to remove and dispose
        of 55-gallon drums containing petrochemical wastes.  The
        wastes included acrylonitrile, acetone, epichlorohydrin, and
        a number of other chemicals possessing toxic, flammable,
        explosive, and oxidizing properties.  A total of about 6,000
        of these drums were hauled away and were to be disposed of at
        a landfill.  However, approximately 4,500 of the drums were
        dumped by the transporter on a section of a former chicken
        farm in Dover Township, New Jersey.  The land had been leased
        to the transporter under the assumption that he was in the
        drum salvaging business and empty drums were to be stored
        there.  A few months later the owners detected unusual odors
        emanating from the leased land and discovered thousands of
        drums, many leaking, buried, and strewn about.  In 1974, it
        was discovered that an unknown portion of the Cohansey
        Aquifer, a major groundwater table aquifer, had been con-
        taminated by the wastes (State of Minnesota, 1977).

     The proposed regulations contain provisions that should, to a

large degree, reduce the potential for air emissions that result from

the indefinite storage of hazardous wastes.  The Section 3004 regula-

tions require that at facility close-out, all hazardous wastes would

have to be removed from storage operations and disposed as required
                                   7-69

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under Subtitle C.  In addition,  the manifest requirements under




Section 3002 would help to insure that wastes are delivered to




permitted facilities and not stored or abandoned in an environment-




ally unacceptable manner.  It should be noted that acceptable




treatment/disposal methods would not necessarily exist for every




hazardous waste  (see Chapter 5 for a discussion of wastes that have




required engineered storage in recent years), and any such wastes




could have to be stored for indefinite periods until treatment/




disposal methods were developed.  However, any such storage would




have to be in compliance with all the requirements previously




discussed.  Based upon Appendix D, large quantities of industrial




wastes are known to be stored in surface impoundments; such storage




quite often constitutes disposal.




     One other source of air pollutant generation common to all




hazardous waste  management activities would be the construction of




necessary hazardous waste management facilities and related con-




junctive developments (e.g., roads, pipelines, power lines, reser-




voirs).  To the  extent that the Subtitle C regulations result in




modifications to or the construction of additional hazardous waste




storage, transportation, disposal, or treatment facilities, there




would be an increase in construction related air emissions.  The




major emissions  would include exhaust from motor vehicles, including




construction equipment, and fugitive dust raised by such construction




activities as grading, excavation, and movement of equipment.







                                  7-70

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     Vehicle emissions during construction would consist primarily of

nitrogen oxides, hydrocarbons, and carbon monoxide.  The emission

levels would be extremely site-dependent.  The magnitude of fugitive

dust emissions would depend upon such factors as soil and terrain

characteristics, time of year, method of construction, size of the

area disturbed, and type of control measures utilized.  Cowherd et

al. (1974) summarized the available information on emissions from

fugitive dust sources and found that while activity levels signifi-

cantly influence emission rates, the relationship can not be

quantified.

     Air Quality Impacts Relative to Transport of Hazardous Wastes.

Current practices in the transport of hazardous wastes have the

potential to release air emissions in three major ways:

     •  Though fugitive emissions resulting from improperly covered,
        sealed, or containerized wastes;

     •  Through emissions resulting from spills or other accidental
        releases of hazardous wastes;

     •  Through emissions resulting from the operation of the trans-
        port vehicle.
                                                t.
As discussed below, the Subtitle C regulations would affect, to

varying degrees, the potential for the release of air emissions from

each of these sources.  In addition, construction related air emis-

sions could be affected by construction and/or modification of trans-

portation facilities as a result of the Subtitle C regulations.

     There are several potential sources of fugitive emissions from

the transport of hazardous wastes.  These include emissions released

                                  7-71

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during the loading and/or unloading of hazardous wastes that have not

been containerized or that have not been properly covered and/or

containerized for transport.   Appendices D and E indicate that a size-

able portion of hazardous wastes are typically transported without

being containerized.  Potential sources and types of fugitive emis-

sions from the loading,  unloading,  and transport of hazardous wastes

would be very similar to those discussed under storage and are not

repeated here.  In addition,  solid  hazardous wastes which are not

properly covered or containerized during transport would be subject

to wind erosion and would be a potential source of particulate matter

emissions.  Such particulate matter would be composed of the hazard-

ous waste material itself.

     Fugitive emissions during transport could result in adverse

impacts in the vicinity of the route of travel, as illustrated in the

following examples:

     •  A truck driver noticed that one of the drums he was hauling
        through the village of Mundelein was leaking titanium tri-
        chloride, a chemical that changes to an hydrocloric acid mist
        on contact with the air.  Fourteen people were hospitalized
        for exposure to the fumes.   The four drums of chemicals were
        neutralized and buried (Office of Solid Waste, Hazardous
        Waste Management Division,  1978b).

     •  In the San Francisco Bay Area, an attempt was made to recover
        alkyl lead from organic lead wastes.  The wastes were trans-
        ported by truck to a recovery plant.  Toll collectors on a
        bridge along the truck route to the recovery plant became ill
        as a result of vapors escaping from the transporting truck
        (Office of Solid Waste Programs, 1974a).

     The regulations contain provisions that should, to some degree,

reduce the potential for fugitive air emissions from the transport of

                                  7-72

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hazardous wastes.  The Section 3002 regulations would require that




every generator containerize his hazardous wastes in accordance with




the Department of Transportation (DOT) regulations on packaging under




49 CFR 173, 178, and 179.  If no specific packaging is required, the




generator would have to place the hazardous waste in a package in




accordance with the DOT regulations on standard requirements for all




packages under 49 CFR 173.14(a), (b), and (c) (2-9).  Since the DOT




regulations currently apply only to interstate shipments of hazardous




materials, the effect of the Section 3002 regulations would be to ex-




tend the DOT regulations to interstate shipments of hazardous wastes




that are not identified as DOT hazardous materials and to most intra-




state shipments of hazardous wastes (about 27 states have adopted the




DOT Hazardous Materials Regulations in toto or have similar regula-




tions; about twelve others have adopted parts of the Hazardous




Materials Regulations).  According to a study by Arthur D. Little,




Inc. (1978a), about one-half of the hazardous wastes transporters




surveyed did not transport wastes across state borders.




     While the regulations do not contain specific provisions to




reduce fugitive air emissions from the loading and/or unloading of




uncontainerized wastes, nor from the placing of wastes in containers,




the air, human health and environmental standard would reduce the




potential for the release of such emissions at permitted faclities.




     A second major source of air emissions from hazardous waste




transport are accidents which result in spills or other releases of




hazardous wastes.  The two most likely causes of such releases are



                                  7-73

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accidents involving the transport vehicle itself and explosions

occurring within the transport vehicle as the result of the mixing of

incompatible wastes.  Once the waste material has been released,

those wastes which are relatively volatile or which are composed of

fine particles are most likely to become sources of air emissions.

In addition, wastes which are ignitable can catch fire following an

accident and become the source of additional air emissions. Such

combustion can create additional hazardous air contaminants not

originally present in the waste itself and would serve to disperse

those air pollutants generated.

     The following incidents illustrate some of the types of air pol-

lutant problems that have occurred during hazardous waste transport:

     •  An industrial waste truck exploded in a truck bin on the Dan
        Ryan Expressway in Chicago spewing barrels of flames over
        cars and across all eight lanes of the roadway.  The chemical
        waste which exploded was believed to be sodium nitrate which
        was part of the load being carried by the truck (Office of
        Solid Waste, Hazardous Waste Management Division, 1978b.).

     «  In Richmond, California, a hazardous waste hauler mixed a
        liquid waste containing butyl acetate in xylene,  with an
        etching waste containing sulfuric acid, nitric acid, and
        hydrofluoric acid.  A hydrolysis reaction took place.  Pres-
        sure was generated in the tank, and the safety relief valve
        was blown off while the truck was travelling through a
        residential area.  A private residence was sprayed with the
        hazardous mixture.  No one was injured, but considerable
        clean-up was required (DeVera et al., 1977).

     The regulations contain provisions that should reduce the

potential for explosions and spills resulting from the mixing of

incompatible wastes during transport.  The Section 3003 regulations
                                   7-74

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contain the.requirement that the transporter must load and stow




hazardous wastes so that those which are incompatible would not come




into contact with each other.  The Section 3002 requirement that




generators must label hazardous wastes and must furnish information




about the general chemical composition of each hazardous waste on the




manifest to be provided to the transporter would aid the transporter




in identifying incompatible hazardous wastes.  To the extent that




transporters can increase the identification of incompatible wastes




during transport, there would be a reduction.in air incidents from




the mixing of hazardous wastes during transport.




     The proposed regulations do not contain provisions that would




directly reduce vehicular accidents, and subsequent spills, of




hazardous wastes during transport.  However, the regulations do con-




tain provisions that would reduce the potential for air emissions




following such accidents and spills.  The proposed regulations




require that the manifest provide either immediate response informa-




tion regarding what actions should be taken in an emergency situation




or a 24-hour telephone number for obtaining such information.  The




manifest would also aid in identifying the general chemical compo-




sition of the spilled hazardous waste.  This information would likely




aid in cleaning up the spill.  To the extent that the time for clean-




up is reduced, the potential for the release of air emissions would




be reduced.  It should also be noted that any reduction in the mixing




of incompatible wastes would also result in a decrease in accidents








                                  7-75

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during hazardous waste transport and would result in fewer spills




generating air emissions.   Based upon an estimated spill rate of one




transportation-related spill per 37,500 metric tons of hazardous




waste transport (Office of Solid Waste, Hazardous Waste Management




Division, 1978a) and 40 million metric tons of hazardous industrial




waste generation in 1984,  it is estimated that under the Subtitle C




regulations these could be on the order of 140 spills annually with




13 percent off-site treatment/disposal and on the order of 270 spills




with 25 percent off-site treatment/disposal.  Based upon a typical




transport vehicle size of 14.5 metric tons (Arthur D. Little, Inc.,




1978a), approximately 2000 to 4000 metric tons of hazardous wastes




could be involved in such spills.  Data are not available to estimate




potential air emissions likely to be released by such activities.




     The spill rate used above is based upon reported incidences from




the transport of hazardous materials which are predominantly not




wastes.  Such hazardous materials are currently subject to essential-




ly the same containerization, labeling, and placarding regulations as




would be required for hazardous wastes under the Subtitle C regula-




tions.  While the spill rate is a reasonable approximation of what




could happen under the Subtitle C regulations, it is not a reasonable




measure of what could happen without the Subtitle C regulations since




there would likely be a higher rate of spills due to improper con-




tainerization and to the mixing of incompatible wastes.  Thus, the




reduction in the number of spills under the Subtitle C regulations




cannot be estimated using this spill rate.




                                  7-76

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     Another major source of air pollutants  from hazardous waste




transport are emissions from the transport vehicle itself.  To the




extent that the regulations shift hazardous  waste transportation




patterns, there would be a change in the total amount of vehicle emis-




sions from hazardous waste transport.  At present, the relatively




high cost of long-distance transportation of hazardous wastes and the




lack of hazardous waste treatment and disposal regulations combine to




minimize the distances over which hazardous  wastes are hauled.  As




discussed in Section 7.1.2.2, the regulations would likely increase




transport distances involved in hazardous waste management.




     Table 7-8 presents estimates of the potential magnitude of the




change that could occur in vehicular emissions in 1984 as a result of




promulgation of the Subtitle C regulations.  The estimates are




presented for both 13 and 25 percent off-site shipment of hazardous




wastes in 1984 (see section 7.1.2.4).  Since data are not available




to determine the average transport distances likely to occur in 1984




under the regulation, the potential change in emissions is estimated




for four possible transport distances.




     The estimates in Table 7-8 are determined as follows.  According




to the hazardous waste transportation study by Arthur D. Little, Inc.




(1978a), most hazardous wastes shipped off-site are currently trans-




ported by truck with typical reported transport distances of 50 miles




(100 miles round trip) and typical vehicle capacities of about 14.5




metric tons (18 tons).  Typical on-site transport distances are about







                                  7-77

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                      TABLE 7-8

ESTIMATED CHANGE IN VEHICULAR EMISSIONS IN 1984 FROM TRANSPORT
OF HAZARDOUS INDUSTRIAL WASTES UNDER SUBTITLE C REGULATIONS

Change in emissions (metric
Wastes Round-trip
transported distance
off -site (miles)
13 percent 100
^ 200
i
" 500
1,000
25 percent 100
200
500
1,000
Carbon monoxide
-160
880
4,000
9,100
780
2,800
8,700
18,600
Hydrocarbons
-20
140
630
1,500
120
440
1,400
3,000
Nitrogen
oxides
-110
640
2,900
6,600
540
2,000
6,300
13,500
tons)
Particulates
-10
40
180
410
40
120
390
840

Sulfur
oxides
-20
90
390
890
80
270
850
1,800

-------
two miles round trip.  These typical transport distances are assumed




to be the baseline for estimating the changes in vehicular emissions.




The change in the quantity of hazardous wastes transported on-site




and off-site on an annual basis in 1984 is determined as discussed in




Section 7.2.5.  The estimated change is a decrease of 0.8 million




metric tons in off-site shipments in the case of 13 percent off-site




treatment/disposal and an increase of 4.0 million metric tons in




off-site shipments in the case of 25 percent off-site treatment




disposal.  The change in the number of off-site and on-site hazardous




waste shipments is determined based upon the typical vehicle capacity




of 14.5 metric tons.  For each of the four selected 1984 transport




distances, the change in emissions is estimated based upon emission




factors for heavy duty, diesel-powered trucks (U.S. Environmental




Protection Agency, 1977a).




     For purposes of comparison, total U.S. emissions of carbon




monoxide, hydrocarbons, nitrogen oxides particulates, and sulfur




oxides were 85.7, 26.1, 22.0, 14.3, and 25.9 million metric tons,




respectively, in 1975.  Total U.S. area emissions from heavy-duty




diesel powered vehicles in 1975 were 0.7, 0.2, 1.5, 0.1, and 0.2 mil-




lion metric tons of carbon monoxide, hydrocarbons, nitrogen oxides,




particulates, and sulfur oxides, respectively (U.S. Environmental




Protection Agency, 1978a).  The emissions in Table 7-8 for the




1000-mile round-trip distance with 25 percent off-site treatment/




disposal represent an increase of less than 0.06 percent in each of







                                  7-79

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the total U.S.  emissions and of less than '3 percent in each of the

total U.S. area emissions from heavy-duty, diesel-powered vehicles.

The emissions for the 100-mile round-trip distance with 13 percent

off-site treatment/disposal represent a decrease of less than 0.0005

percent in each of the total U.S.  emissions and of less than 0.02

percent in each of the total U.S.  area emissions from heavy-

duty, diesel-powered vehicles.

     Air Quality Relative to Treatment/Disposal.  The major sources

of air emissions from current hazardous waste treatment/disposal

practices are as follows:

     •  Fugitive emissions from land-based treatment/disposal
        activities such as landfills, landfarms, and surface
        impoundments;

     •  Emissions generated by explosions, fires,  and other
        accidents;

     •  Residuals from the combustion of hazardous wastes by
        incineration or open burning;

     •  Fugitive emissions from other treatment activities;

     •  Fugitive emissions from facility construction or
        modification.*

The Subtitle C regulations would affect the potential for release of

air emissions from each of these sources as discussed below.

     Such land-based activities for the treatment/disposal of

hazardous wastes as landfills, landfarms and surface impoundments

currently release air contaminants through several mechanisms.
*These fugitive emissions are discussed under storage and are not
 repeated in this section.
                                  7-80

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Activities which result in soil disturbance, such as excavation,




trenching, covering, grading, and compaction, generate fugitive dust.




The magnitude of fugitive dust emissions depends upon such factors as




soil and terrain characteristics, time of year, type of equipment




utilized, size of the area disturbed, and type of control measures




employed.  Vehicles and equipment used in land disposal are a further




source of emissions from such activities, as previously discussed.




Fugitive emissions also occur when the hazardous waste is initially




being deposited in the treatment/disposal site.  Such fugitive




emissions usually consist of the waste and/or its constituents and




would be similar to those previously discussed under storage and




transportation.




     Following placement of the waste in the treatment/disposal




site, gaseous materials that are potentially hazardous are often




generated and released under current practices.  Such emissions




generally result from volatilization, sublimation, chemical reaction,




and/or decomposition of the wastes.  The rate of generation and




release of such gaseous materials is a function of many factors in-




cluding the nature, water content, and depth of any cover material;




chemical characteristics and composition of the waste materials; and




temperatures in the treatment/disposal site and temperature of the




waste.  With regard to volatilization, numerous instances of air




pollution problems have been reported under current practices, as




indicated below:
                                  7-81

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     •  An industrial solvent reprocessing firm in Maryland dumped
        large quantities  of volatile organic liquid wastes, con-
        taining benzene,  carbon tetrachloride,  acetones, ketones,
        mythelene chloride, and other solvents  into a sand and gravel
        quarry.  The wastes,  even though volatile, were often left
        open in an evaporating pool  before being covered.   Many of
        the solvents contained in the waste were detected in signifi-
        cant concentrations in the air in the vicinity of the quarry
        (see Section 7.1.6, Public Health) (Office of Solid Waste,
        Hazardous Waste Management Division, 1978b).

     •  In July 1977 several  truckloads  of organohalides,  amines, and
        hydrocarbons were dumped by  a waste disposal  firm at a
        disposal site near San Francisco,  California.  The wastes
        were deposited in an evaporation pond,  where  they soon
        floated to the top and began to  evaporate. A visible and
        odoriferous plume of white mist  hovered over  the area for
        several hours, provoking nausea  and other complaints from
        residents downwind of the site.   At least one building in
        the area had to be evacuated (Office of Solid Waste,
        Hazardous Waste Management Division, 1978b).

     Air quality problems from existing  land disposal practices are

also associated with the  products of chemical and microbial transfor-

mations.  Chemical reactions  from the mixing of incompatible wastes

have occurred on numerous instances  and  are described in the subse-

quent discussion of explosions, fires, and accidents.  The disposal

of organic wastes can produce gases  through the decomposition and

chemical reaction of the  waste material.  Gases produced usually

include methane, carbon monoxide, carbon dioxide, hydrogen, and

oxygen.  Most studies of  gas  generation  through decomposition of

organic wastes have focused only on  municipal solid wastes.  Streng

(1976) is studying the effects on gas production from the codisposal

of six industrial wastes  with municipal  solid wastes.  Table 7-9

shows the gas composition data measured  in the  six industrial waste


                                  7-82

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                                                 TABLE 7-9


                                            GAS COMPOSITION DATA*»
•-j
I
oo
U)

Study cell contents^
Municipal solid waste only
Refinery sludge
Battery reproduction waste
Electroplating waste
Inorganic pigment waste
Chlorine production
brine sludge
Solvent based
paint sludge
02
0.3
0.2
1.1
0.3
0.2
0.1

0.4

N2
29.9
26.4
22.3
16.4
2.9
16.6

47.0

CH4
0.0
17.1
0.0
1.1
0.0
0.0

4.9

C02
69.2
56.1
76.5
81.9
96.9
83.3

41.0

H2
0.0
0.0
0.0
0.0
0.0
0.0

6.4


                     *Streng, 1976.

                     tPercent of gas produced by volume.
                     fContents in addition to municipal solid waste.

-------
test cells and one municipal solid waste test cell at the time of the

report.  According to Streng,  most of the study cells were progres-

sing from an anaerobic nonmethanation stage to the early phases of

methanation at the time of the report.   However,  the addition of re-

finery wastes to the municipal solid wastes appeared to have sped up

the decomposition of the municipal solid wastes and the resultant

production of methane.  In a later report,  Streng (1977) noted that

the test cell containing the mixture of the solvent based paint

sludge and municipal waste produced less than the theoretical minimum

amount of gas expected to have been generated, indicating that this

industrial waste exerted an adverse effect on gas production.

     Migration of methane and other combustible gases resulting from

current landfill practices has caused explosions  and other problems.

For example:

     •  A landfill in Deck Quarry, Montgomery County, Pennsylvania
        accepted municipal and industrial wastes  until it closed in
        1969.  Two explosions and the contamination of residential
        drinking water resulted from the generation of methane gas
        and its migration through rock fractures.  Residents have had
        to evacuate their houses permanently (Office of Solid Waste,
        Hazardous Waste Management Division, 1978b).

     •  Migration of gases from a landfill containing household and
        industrial wastes, along with sewage sludge, resulted in the
        deaths of over 70 peach trees in Glassboro, New Jersey be-
        tween 1971 and 1975.  Combustible gases and carbon monoxide
        were found along with low oxygen concentrations in the root
        zones of the trees up to 24 meters (80 feet) from the land-
        fill (Flower, 1976).  Many similar cases, some with the
        potential for explosions affecting homes  have also been re-
        ported for municipal landfills (Flower et al., 1976, 1977;
        DeGeare, 1976; James, 1977).
                                  7-84

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     The Subtitle C regulations contain requirements that should re-

duce the potential for fugitive emissions from the land-based treat-

ment/disposal of hazardous wastes.  For example, the Section 3005

regulations would require that all hazardous waste treatment/

disposal facilities obtain a permit before construction and opera-

tion.  To obtain and keep a permit, treatment/disposal facilities

would have to comply with the applicable Section 3004 air regula-

tions.

     The objective of the Section 3004 air regulations would be to

insure that treatment/disposal facilities are located, designed, con-

structed, and operated in a manner such that air emissions from such

facilities do not adversely affect human health or the environment.

The air regulations applicable to non-point emission sources (e.g.,

landfills, landfarms, and surface impoundments) would consist of two

sets of requirements:  mandatory standards with which all facilities

must always comply and air human health and environmental standards

which would be applicable, on a case-by-case basis, only when there

is reason to believe (e.g., a third party challenge) that the manda-

tory standards are insufficient for human health and environmental

protection.  If a facility is in compliance with all applicable man-

datory standards, it would be assumed to be in complaince with the

air human health and environmental standards; the burden of proof

would be on the permitting authority to show that the facility was

actually in violation of the air human health and environmental

standard.
                                  7-85

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     The air human health  and environmental standard would require




that non-point sources  of  air emissions  not contribute any listed air




contaminant (see Appendix  B,  Subpart  D,  Annex 2)  to the atmosphere,




at the surface of the non-point  source,  in concentrations exceeding




the listed Threshold Limit Value (TLV)  for that contaminant,  nor con-




tribute two or more listed air contaminants in a  manner which causes




the sum of the individual  concentrations divided  by the individual




TLV's to exceed unity.   Examples of air  contaminants from the pre-




viously discussed incidences  to  which the air human health and




environmental standard  could  apply include acetone, asbestos, ben-




zene, carbon monoxide,  carbon tetrachloride,  methane, and methylene




chloride.  However, the application of  this standard could occur only




after the standard was  violated; it would not be  a means to initially




prevent release of air  contaminants in  violation  of the standard.




The mandatory standards discussed below would,  however, prevent the




initial occurrence of most such  incidents.




     All facility owners/operators would have to  obtain an analysis




of each type of waste to be treated/disposed for  the purpose  of iden-




tifying the principal hazardous  components and characteristics of the




waste so as to enable the  waste  to be treated/disposed in compliance




with the Section 3004 requirements.  All ownerss/operators would also




have to sample waste shipments or batches received to confirm that




the contents match the  previous  analysis.  Owners/operators of all
                                 7-86

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treatment/disposal facilities would also have to visually inspect the


facility daily to determine if there were any fugitive emissions.


     Volatile wastes—those with a true vapor pressure greater than


78 mm mercury at 25 C—would not be allowed to be treated/disposed in


landfills, surface impoundments, or basins; such wastes could be


landfarmed only if the facility owner/operator could demonstrate, be-


fore landfarming the wastes, that the air human health and environ-


mental standard would not be violated.  Examples of air contaminants


from the previously discussed incidents which have vapor pressures


greater than 78 mm mercury at 25 C and which could not be treated/


disposed under the Subtitle C regulations in the manner that caused


the indicated incidents include acetone, benzene, carbon tetrachlor-


ide, methylene chloride, and vinyl chloride.


     With regard to wastes that are landfilled, a minimum of 0.15


meters (6 inches) of cover material would have to be applied daily on


active hazardous waste landfill cells.  Cells which do not have addi-


tional wastes placed in them for at least one week would have to be

                                                JL,
covered with 0.3 meters (12 inches) of material.   Where gases are


generated, a gas collection and control system would have to be


installed to control the vertical and horizontal escape of gases.  At


facility closure, a final cover of at least 0.15 meters of clay soil
 Different thicknesses or rates of application could be used if the
 owner/operator could demonstrate that the air human health and envi-
 ronmental standard would not be violated.
                                  7-87

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under a minimum cover of 0.45 meters (18 inches) of soil would have

to be provided.*  The facility would also have to be secured such

that discharges of wastes harmful to human health or the environment

would not occur.  These requirements would reduce air emissions that

occur under current landfill practices which often do not employ such

measures (see Appendix J).

     For example,  emissions of hexachlorobenzene wastes are reported

to be reduced from 317 kilograms  per hectare per year when disposed

uncovered to 4.564 kg/ha/yr. when covered with 0.02 meters of soil

and to 0.07 kg/ha/yr. when covered with 1.2 meters of soil (Farmer et

al., 1976).  Other studies, however, have indicated that even cover-

ing some wastes may not completely prevent the release of air emis-

sions.  A study by Markle et al.  (1976) indicated background air

concentrations of  about 0.1 to 0.3 ppm VCM exist at landfills where

PVC sludge has been disposed for  several years.   Peak concentrations

on the order of 1.0 ppm VCM were  observed at normal breathing heights

as long as 24 hours after the PVC sludge deposits were covered.  The

required gas collection and control system could remove such emis-

sions as well as volatile gases generated by waste decomposition,

including methane  and carbon monoxide.
*
 Different thicknesses or rates of application could be used if the
 owner/operator could demonstrate that the air human health and envi-
 ronmental standard would not be violated.
                                  7-88

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     With regard to surface impoundments, the Subtitle C regulations




would require that there be no discharges to the ambient air unless




the facility owners can demonstrate, before treatment/disposal, that




any discharges would not violate the air human health and environmen-




tal standard.  Furthermore, upon close-out, all hazardous wastes and




waste residuals would have to be removed from surface impoundments




which do not meet the requirements for landfills.  Also after clo-




sure, surface impoundments would have to be secured such that dis-




charges of wastes harmful to health or the environment would not




occur.




     It should be noted that the Subtitle C regulations do not cover




all types of potentially hazardous fugitive air emissions from land-




based treatment/disposal.  The air human health and environmental




standards only apply to those emissions for which there are TLV's




listed in Appendix B, Subpart D, Annex 2.  Other emissions which




could consist of the hazardous waste itself or various hazardous




constituents (e.g., trichloroethane) would not be subject to any




emission standards.  There are also no specific requirements aimed at




reducing fugitive dust emissions from treatment/disposal activities




which result in soil disturbance.




     Explosions, fires, and other accidents represent another major




source of air contaminants resulting from current hazardous waste




treatment/disposal practices.  The primary causes of most such




explosions and fires have been the mixing of incompatible wastes and
                                 7-89

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the improper treatment/disposal of ignitable or reactive wastes.

Often wastes involved in such accidents are those whose identity or

nature were not known prior to treatment/disposal.  Resultant fires

have led to the creation, release, and dispersion of additional air

pollutants which have threatened persons living or working in the

vicinity of the treatment/disposal facility.  Appendix M describes

types of emissions that can result from the combustion of hazardous

wastes.  A less obvious danger of fire occurring within an under-

ground storage or disposal cell is the possibility of destruction of

liners meant to protect groundwater.  While this has not been docu-

mented, since most liner materials cannot withstand temperatures in

excess of 150 to 200 C (3UO to 400 F) it is theoretically possible

(Office of Solid Wastes, 1977d).

     Numerous instances of fires and explosions have been reported at

hazardous waste disposal areas.  The incidents presented below illus-

trate some of these occurrences and the subsequent problems.

     •  At a sanitary landfill near Dundalk, Maryland, a 2,000-gallon
        liquid industrial waste load containing iron sulfide, sodium
        sulfide, sodium carbonate, and sodium thiosulfate, along with
        smaller quantities of organic compounds was discharged into a
        depression on top of an earth-covered area of the landfill.
        When it reached eight to ten feet below the point of dis-
        charge, the liquid started to bubble and fume blue smoke.
        The smoke cloud quickly engulfed the truck driver and dis-
        abled him.  Several nearby workers rushed to his aid and were
        also felled.  During the clean-up operation, one of the coun-
        ty firefighters also collapsed.  All six of the injured were
        hospitalized and treated for hydrogen sulfide poisoning.  It
        was not determined whether the generation of hydrogen sulfide
        was due to the instability of the waste or the incompatibil-
        ity of the waste with some of the landfill material (De Vera
        et al., 1977).


                                  7-90

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     •  At a dump in Contra Costa County-, California, a large number
        of drums containing solvents were deposited in a landfill.
        In the immediate area were leaky containers of concentrated
        mineral acids and several bags containing beryllium wastes in
        dust form.  The operators failed to cover the waste at the
        end of the day.  The acids reacted with the solvents during
        the night, ignited them, and started a large chemical fire.
        There was possible dispersion of potentially hazardous beryl-
        lium dust (De Vera et al., 1977).

     •  In Los Angeles County, a tank truck emptied several thousand
        gallons of cyanide waste onto refuse at a sanitary landfill.
        Another truck subsequently deposited several thousand gallons
        of acid waste at the same location.  Reaction between the
        acid and the cyanide evolved large amounts of toxic hydrogen
        cyanide gas.  A potential disaster was averted when a local
        chlorine dealer was quickly called to oxidize the cyanide
        with chlorine solution (De Vera et al., 1977).

     •  A load of empty pesticide containers was delivered to a dis-
        posal site in Fresno County, California.  Unknown to the site
        operator, several full drums of an acetone-methanol mixture
        were included in the load.  When the load was compacted by
        a bulldozer, the containerized waste ignited, engulfing the
        bulldozer in flames.  The ensuing fire involved dispersion of
        pesticide wastes (Office of Solid Waste, Hazardous Waste Man-
        agement Division, 1978b).

     •  A disposal site in central California accepted a load of
        solid dichromate salts and dumped it in a pit along with pes-
        ticide formulations and empty pesticide containers.  For sev-
        eral days thereafter, small fires erupted in the pit due to
        the oxidation of the pesticide formulations by the dichro-
        mate (De Vera et al., 1977).

     •  In October 1974, a bulldozer operator was killed in an ex-
        plosion at an industrial landfill in Edison Township, New
        Jersey, as he was burying and compacting several 55-gallon
        drums of unidentified chemical wastes.  The victim died as a
        result of burns covering approximately 85 percent of his body
        (Lazar, 1975).

     The Subtitle C regulations contain provisions that should, to a

large degree, reduce the potential for fires, explosions, and other

accidents at hazardous waste treatment/disposal facilities.  For
                                 7-91

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example, one of the major causes of many such accidents has been the




lack of accurate information about the identity or nature of the




wastes being treated/disposed (Office of Solid Waste, Hazardous Waste




Management Division, 1978a).  The manifesting and labelling require-




ments under Section 3002 would make such information readily avail-




able.  The requirement that facility owners/operators obtain an




analysis of each type of waste handled from every source (e.g.,




generator) would enable a prior determination of how the waste should




be treated/disposed.  The requirement that the facility owner/opera-




tor sample shipments or batches received to confirm that the contents




match the initial analysis would reduce the possibility of improper




handling due to undetected changes in the waste composition.  Fur-




thermore, the requirement for training of all personnel in hazardous




waste management procedures relevant to the facility operation would




make such employees less likely to handle or mix wastes in a manner




that could cause fires or explosions.




     Incompatible wastes, both containerized and non-containerized,




would also have to be disposed in separate landfill cells.  Landfarms




would have to be constructed and operated such that potentially in-




compatible wastes do not come in contact. 'Incompatible wastes would




not be allowed to be mixed in surface impoundments and basins, except




for treatment purposes, providing the treatment does not violate the




air human health and environmental standard.  Furthermore, highly




reactive or ignitable wastes, as defined in Appendix B, Subpart A,







                                  7-92

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would not be allowed to be disposed in landfills, surface impound-




ments, basins, or landfarms.  Appendix B, Subpart D, Annex 4 lists




examples of incompatible wastes.  Appendix C describes potential




sources generating many of these potentially incompatible wastes.




Examples of wastes identified as potentially hazardous due to reac-




tivity or ignitability (see Appendix C, Subpart D, 250.14) which have




been disposed in landfills, landfarms, and surface impoundments in




the past include slop oil emission solids and DAF sludge from petro-




leum refining (see Table D-7) ; semisolid wastes from toluene diisocy-




nate production (see Table D-5); and solvent and still bottom wastes




from the textile, paint, organic chemicals, special and electronic




components industries (see Tables D-l, D-4, D-5, D-14, and D-15).




     Hazardous waste treatment/disposal facilities would have to




prepare contingency plans to minimize human health or environmental




damage in the event of an accidental discharge (see Appendix B, Sub-




part D, 250.43-4 for specific requirements).  To the extent that the




contingency plan would reduce both the spread of the discharge with a




resultant reduction in the possible mixing of incompatible wastes and




the time required to stop and clean up the discharge, there would be




a reduction in the release of air contaminants and resultant impacts




from such accidental discharges.




     The intentional combustion of hazardous waste as a method of




treatment, energy recovery, or disposal represents another major




source for the release of air emissions.  The combustion of wastes
                                  7-93

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typically occurs either as open burning or as controlled or uncon-




trolled incineration.




     Open burning is defined under Subtitle C as the combustion of




any material without control of combustion air to maintain adequate




temperature for efficient combustion,  containment of the combustion-




reaction in an enclosed device to provide sufficient residence time




and mixing for complete combustion,  or emission of the gaseous com-




bustion products through a stack or  vent adequate for both visual




monitoring and point source sampling.   Open burning of hazardous




waste results in the uncontrolled release of hazardous gases and




particulate matter (see Appendix M for potential emissions from com-




bustion of hazardous wastes).  In addition, open burning may result




in the release of smoke (i.e., particulate matter) which can inter-




fere with visibility.  For example, smoke from open burning in a dump




resulted in a chain accident on the  New Jersey Turnpike several years




ago (Lazar, 1975).  Open burning is  being phased out as a method of




most hazardous waste disposal due to implementation of the Clean Air




Act.  It should be noted that open burning is currently used by the




military to dispose of explosive wastes which cannot be incinerated




or treated by other means (Shapira et  al., 1978).  Open burning is




currently the method most commonly used for such disposal (TRW, Inc. ,




1976).





     Incineration is defined by Subtitle C as an engineered process




using controlled flame combustion to thermally degrade materials
                                  7-94

-------
(e.g., hazardous wastes).  Devices normally used for incineration

include rotary kilns, fluidized beds, and liquid injectors (see

Appendix D).  To the extent that incineration produces an ash or re-

sidue which is hazardous under Section 3001, incineration is a treat-

ment method (e.g., volume reduction) rather than a disposal method.

     It is estimated that in the period from 1973 to 1975, over 15

percent of the hazardous wastes from 14 selected manufacturing indus-

tries were incinerated or open burned with over 60 percent of this

incineration and open burning being uncontrolled (Office of Solid

Waste, unpublished data).  It should be noted that the percentage of

controlled incineration is likely to be higher now due to require-

ments of the Clean Air Act, as amended.  Tables 5-8 and 5-9 show the

portion of hazardous wastes estimated to be incinerated by selected

manufacturing industries during this period.  Data are not available

to estimate the quantity of air emission released by such incinera-

tion of hazardous wastes.

     In addition to the release of potentially hazardous emissions,

incineration of volatile, flammable, or explosive wastes have led to

many instances of explosions and fires in the past:

     •  The Harrisburg, Pennsylvania incinerator, for example, has
        experienced explosions in both 1972 and 1975 as a result of
        the incineration of hazardous wastes (Office of Solid Waste,
        Hazardous Waste Management Division, 1978b).

     Appendix M contains a detailed discussion of destruction effi-

ciencies achieved for the incineration of selected hazardous wastes,

potential air residuals from such incineration, and the nature of

                                 7-95

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solid residuals produced by the incineration.  Based upon this dis-




cussion, a vast number of different hazardous waste materials, rep-




resenting a broad spectrum of physical and chemical characteristics,




can be essentially destroyed or used for energy recovery by inciner-




ation.  Generally speaking, organic materials are the prime candi-




dates for incineration.  The amount of destruction of any specific




hazardous waste is dependent to a large extent on the relationship of




incineration temperature to dwell time (residence time in the incin-




erator) at that temperature and to a lesser extent on turbulence in




the combustion zone and the amount of excess oxygen available.  The




higher the temperature used, the shorter the dwell time necessary to




achieve a given destruction ratio.  As a general rule, the principal




components of most organic hazardous materials can be virtually com-




pletely destroyed at 1000 C (1830 F) with a dwell time of 2 seconds.




Many are destroyed at lower temperature/dwell time conditions; a few




require more rigorous conditions.  However, the knowledge of specific




incineration criteria for individual wastes is very limited.




     Very limited information is also available as to the fate of




hazardous waste constituents produced by the incineration.  Most




studies of emissions from the incineration, of hazardous wastes have




considered only the fate of the gross components of combustion, com-




ponents for which regulations have been promulgated, or components




for which historical data have been accumulated regarding harmful ef-




fects.  Most studies have not given consideration to emissions which







                                  7-96

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result from side reactions, such as the formation of polynuclear aro-




matics (PNA's) from the incineration of wastes containing chlorinated




hydrocarbons, nor to the constituents of particulate matter entrained




in stack gases.  Also, little is known about the potential health




effects from long-term, low-level exposure to many of the gaseous and




particulate products of hazardous waste combustion.




     The Subtitle C regulations contain provisions that should reduce




the potential for the release of air contaminants from the combustion




of hazardous wastes.  As indicated, in recent years over 60 percent




of the hazardous wastes that were burned (either by incineration or




open burning) were burned in an uncontrolled manner.  The Subtitle C




regulations would require the use of controls for almost all combus-




tion of hazardous wastes and would set standards for the release of




many air contaminants.  Open burning of hazardous wastes would be




prohibited unless the facility owner/operator could demonstrate prior




to such open burning that the air human health and environmental




standard would not be violated.  All facilities would also be re-




quired to comply with all applicable standards of the Clean Air Act,




as amended, in order to maintain their permits.




     The regulations also would set specific standards for the incin-




eration of hazardous wastes.  Incineration used to thermally degrade




hazardous waste containing more than 0.5 percent halogens would be




required to be equipped with wet scrubbers capable of removing 99




percent of the halogens from the exhaust gases.  Incinerators used to
                                  7-97

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burn pesticide wastes or wastes which are hazardous due to toxicity




would be required to maintain greater than a 1000 C combustion zone




temperature, greater than 2 seconds retention,  and greater than 2




percent excess oxygen during incineration.  Such incinerators, except




for pathological incinerators, would also be required to be designed,




constructed, and operated to maintain a destruction efficiency of




99.99 percent of the principal toxic components of the pesticide or




toxic waste going into the incinerator.  All incinerators would be




required to be operated at a combustion efficiency equal to or great-




er than 99.9 percent.  All hazardous waste incinerators would also be




required to be operated in a manner that assures that emissions of




particulate matter do not exceed 270 milligrams per dry standard




cubic meter (0.12 grains per dry standard cubic foot) at zero excess




air.  Compliance with this latter requirement could be achieved by




having particulate emissions that when corrected to 12 percent carbon




dioxide are less than 180 milligrams per standard cubic meter (0.08




grains per dry standard cubic foot).




     In addition, incinerators would have to be designed, construc-




ted, and operated such that fugitive emissions  of unburned hazardous




waste and combustion products are controlled and such that waste feed




is automatically cut off if significant changes occur in flame, com-




bustion zone temperature, excess air, or scrubber water pressure.




Also, owners/operators of hazardous waste incinerators would be




required to conduct trial burns for each hazardous waste that is
                                  7-98

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significantly different than any one previously demonstrated under




equivalent conditions.  The trial burn would have to include:  an




analysis of the exhaust gases for concentrations of the principal




hazardous components, hydrogen halides, carbon monoxide, carbon diox-




ide, excess oxygen, and total particulates;  an analysis of the ash




residue and scrubber effluent for the principal hazardous components;




an identification of sources of fugitive emissions and their means of




control; a measurement of the combustion temperature; and a computa-




tion of residence time, combustion efficiency, destruction efficien-




cy ; and scrubber efficiency in halogen removal.




     Data are not available to estimate the extent to which the above




regulations would reduce the overall release of specific air emis-




sions from hazardous waste incineration.  Any reduction would depend




upon such factors as changes in types and quantities of hazardous




wastes  incinerated, changes in the types of incinerators utilized,




and changes in control devices employed.  As previously indicated,




ignitable, volatile, and reactive wastes would, for the most part, be




prohibited from landfills, landfarms, and surface impoundments.  It




is likely that a large portion of such wastes would be incinerated as




an alternative means of treatment/disposal under the Subtitle C regu-




lations.  Such a shift would likely result in the increased release




of combustion products from these wastes, but would also reduce the




release of other emissions, such as particulates and volatile gases,




that would have occurred from land disposal of these wastes.  There
                                  7-99

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would also be other shifts in the types of methods used to treat/




dispose other wastes under Subtitle C regulations compared to current




practices.  All such shifts could either enhance or reduce the poten-




tial for reductions in specific air emissions under the Subtitle C




regulations.  Furthermore, the construction of new facilities could




lead to increased releases of air emissions in the vicinity of the




facility and along any transport routes.  Closure of existing facil-




ities could lead to reduced releases of air emissions in the vicinity




of the facility and along transport routes.  The net result could be




both a localized and/or nationwide reduction in the total release of




many air contaminants from hazardous waste management and a localized




and/or nationwide increase in the release of other air contaminants.




This could cause both localized improvements in air quality and some




localized degradation of air quality; however all emissions and any




localized degradation would have to be in compliance with all applic-




able standards (e.g., Clean Air Act, OSHA Standards, RCRA Standards,




State Standards).




     It should be noted that the incineration standards set limits




only for the destruction of the principal toxic components of the




waste feedstock and on the emission of halogens and total particu-




lates.  As indicated in Appendix M, combustion of hazardous wastes




can also generate and release other combustion products such as cya-




nides, sulfur compounds, hydrochloric acid, trace metals, nitriles,




ammonia, pyrophosphates, cyanogen, polycyclic hydrocarbons,








                                 7-100

-------
polynuclear aromatics, and other organics.  While the regulations re-

quire that such combustion products from incineration be controlled,

no standards are set for such control.   Thus, such combustion

products would still likely be released, but in quantities less than

those that would occur without the subtitle C regulations.  Further-

more, there could be small releases of the hazardous waste and/or its

principal toxic components; up to 0.01 percent of the principal toxic

components originally present in the waste could be released.  Little

is currently known about the potential for adverse health effects or

environmental effects from long-term, low-level exposure to such

potential emissions from hazardous waste combustion.

     Appendix M also indicates that while 99.99 percent destruction

has been demonstrated for many hazardous wastes, such destruction ef-

ficiencies have not yet been reported to have been demonstrated for

most hazardous wastes.  Furthermore, in spite of the impressive per-

formances of the incinerators reported in the literature in destroy-

ing hazardous wastes, it should be noted that most studies were per-

formed under extremely controlled conditions and only specific

products of combustion were sampled in many cases.  Problems could

occur due to requirements for frequent maintenance and extensive
 For example, as indicated in Appendix M, hydrogen cyanide is
 generated from the destruction of nitrogen-containing pesticides.
 Temperatures much higher than those required for 99.999 percent de-
 struction of the nitrogen-containing pesticide are needed for de-
 struction of this hydrogen cyanide.
                                 7-101

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operator education in order to ensure proper functioning.  Mainte-

nance could be an especially serious problem since many wastes burned

in incinerators are either extremely caustic or produce caustic

products when burned.

     Other types of hazardous waste treatment constitutes a further

source for the release of potential air contaminants.  Such treatment

can be classified as biological treatment, physical treatment, or

chemical treatment (see Appendix D).  Fugitive emissions represent a

major source of emissions from such treatment.  The potential for the

release of fugitive emissions during treatment would be similar to

that previously discussed and is not repeated here.  In addition,

some chemicals and/or reagents used in treatment processes are poten-

tial sources of fires and/or explosions if not properly stored and/or

handled.  The combustion of fuel to provide steam or energy to treat-

ment processes is another source of emissions, primarily particulate

matter, sulfur oxides, nitrogen oxides, carbon monoxide, and hydro-

carbons.  The burning of coal could also result in aldehydes and

trace elements being emitted.  The following two incidents indicate

potential problems from hazardous waste treatment processes (other

incidences from treatment have been previously indicated):

     •  Organic lead waste from manufacturing processes for alkly
        lead in the San Francisco Bay area had been disposed in ponds
        at an industrial waste disposal site.  Attempts to process
        this waste for recovery resulted in alkyl lead intoxication
        of plant employees in one case.  In another instance, not
        only were plant employees affected, but employees of firms in
        the surrounding area were exposed to an airborne alkyl lead
        vapor hazard.  Toll collectors on a bridge along the truck

                                  7-102

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        route to the plant became ill from escaping vapors from
        transport trucks (Office of Solid Waste Management Programs,
        1974a).

     •  The Air Compliance Division of the Connecticut Department of
        Environmental Protection closed down two organic solvents re-
        covery operations in Southington, Connecticut due to air pol-
        lution caused by incineration of the wastes.  A similar oper-
        ation in Beaver Falls, Connecticut was also closed due to air
        pollution problems (Office of Solid Waste, Hazardous Waste
        Management Division, 1978b).

     The Subtitle C regulations contain provisions that should reduce

the potential for fugitive emissions from hazardous waste treatment

processes.  Most of these provisions and potential impacts have pre-

viously been discussed under storage, treatment, and disposal and are

not repeated here.  Additional requirements include the need for the

treatment facility to demonstrate the capability to handle hazardous

wastes during facility or equipment breakdown and for all continuous

feed facilities to be equipped with an automatic waste feed cut-off

or by-pass system which is activated when a malfunction occurs.  All

hazardous wastes would have to be analyzed prior to selection of a

treatment process to determine if the waste contains components or

contaminants which could cause the uncontrolled release of toxic

gases or fumes or which could form highly toxic components with

treatment chemicals or reagents.  These requirements in conjunction

with the previously discussed requirements would reduce the potential

for air emissions from hazardous waste treatment.  However, any

increased treatment occurring as a result of promulgation of the Sub-

title C regulations could offset the potential for such reductions to
                                 7-103

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an unknown degree.   There could also be other offsetting reductions




in the release of air emissions if the treatment reduced the quanti-




ty of wastes requiring disposal.




     7.1.4.2  Climate.  The potential effect of specific actions on




global, regional and local climates is not well understood at pres-




ent.  As a result,  very few conclusions can be drawn as to the effect




of various hazardous waste management related actions on the climate.




Furthermore, even for those potential impacts that can be identified,




the effect on climate conditions would be so site-dependent as to




preclude quantification.  The following discussion describes poten-




tial changes that could result both from any construction of addi-




tional hazardous waste management facilities and from changes in




operational procedures as a result of the Subtitle C regulations.




     Average temperatures could be slightly increased in the vicinity




of a hazardous waste management facility as a result of both heat re-




leased from the facility and increased reflection of heat from




cleared and paved surfaces on the facility site.  Heat would be re-




leased by incinerators, auxiliary boilers, and various treatment pro-




cesses.  This heat would increase the temperature slightly in the




immediate vicinity of each facility.  The heat would also cause local




convection currents, minor increased air turbulence, and slightly




greater instability in the immediate layer of air over the facility.




     Low-level wind patterns in the facility area could be slightly




modified as a result of the facility structure and minor topographic







                                 7-104

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changes.   Wind speeds could be slightly decreased and air turbulence




increased.  Aerodynamic effects of buildings could cause wake and




down-wash effects which could modify dispersion of low-level atmo-




spheric emissions.  Any such effects would be very localized in




nature.




     The  creation of reservoirs and storage and treatment lagoons and




ponds would increase the surface area of water exposed to the atmo-




sphere and to solar radiation.  This would cause increased evapora-




tion which could influence the microclimate of the surrounding area.




The significance of such changes is not well understood at present.




     The precise role of airborne particulate matter and other aero-




sols emanating from hazardous waste management facilities with regard




to weather modifications cannot be determined completely.  Their in-




fluence on the amount of short-wave solar radiation is well estab-




lished and has important implications both on a global scale




(Mitchell, 1971) and on a regional scale.  In principle, aerosol par-




ticles could also act as condensation nuclei and either enhance or




inhibit rainfall.  A considerable body of knowledge regarding cloud




seeding has been built up over the past 25 to 30 years (Byer, 1974;




Elliott,  1974) and numerous precipitation management programs are in




progress, notably in the U.S., Australia, Israel, and the Soviet




Union.




     While certain aspects of intentional weather modifications are




still regarded as controversial, it is generally recognized that







                                 7-105

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artificial nucleation can be effective in producing increases or




redistributions of precipitation under very specific meteorological




conditions and through the use of appropriate techniques.  A defini-




tive answer as to whether or not a local change in the concentration




of atmospheric aerosols resulting from dust or industrial emissions




would cause a significant change in precipitation patterns cannot be




given (Simpson and Dennis, 1974).  A few instances of anomalous snow-




falls have been recorded; industrial and urban emissions are thought




to be instrumental in producing generally light snowfalls in these




cases (Landsberg, 1974).   An increase in cloudiness due partly to the




aerosol condensation nuclei and partly to the heating effect of




cleared surface areas appears to be a more likely phenomenon than




persistent alterations in precipitation characteristics.




     The most frequently cited factor associated with inadvertent




climate modification is the increasing carbon dioxide content of the




atmosphere (Machta and Telgadas, 1974; Massachusetts Institute of




Technology, 1970).  The steady growth observed in carbon dioxide con-




centration is attributed to the rapidly increasing use of fossil




fuels since the turn of the century.  Although the potential effects




of atmospheric carbon dioxide on global temperature and climate have




serious implications—the greenhouse effect through which the temper-




ature could increase—no significant localized or regional weather




effects from carbon dioxide emissions are anticipated from changes in




hazardous waste incineration.  This is due to the relatively small







                                  7-106

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quantity of carbon dioxide expected to be produced from hazardous




waste incineration in relation to the production from other sources.




     7.1.5  Water Quality Impacts.  The primary mechanisms by which




surface water may be contaminated with hazardous wastes are spills




(including deliberate dumping); surface runoff from storage, treat-




ment, or disposal areas (including overflows from impoundments);




direct discharges from generating or treating facilities; and dis-




charge of groundwater contaminated by subsurface migration of pollu-




tions.  Groundwater contamination can occur with almost any facet of




hazardous waste handling and disposal as now practiced.  It may occur




due to infiltration of spilled materials or wastes stored on perme-




able surfaces, due to percolation of leachate or runoff which has




been in contact with wastes either in storage or in landfills, or due




to leakage or infiltration of fluids from poorly sealed waste impound-




ments .




     These mechanisms may be generalized into three major pathways




through which contamination can occur:  spills, other surface releas-




es (including runoff and direct discharges), and underground dis-




charges (primarily off-site movement of leachates).  The following




sections discuss the effects of the Subtitle C regulations on these




pathways with respect to each of the steps in the hazardous waste




management sequence.




     A general discussion of the effects of the combined regulations




on each pathway is followed by discussions of the effects of any
                                 7-107

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specific parts of the regulations which further control one of the




individual hazardous waste management activities (e.g., transporta-




tion) .




     7.1.5.1  Spills.  The Subtitle C regulations would potentially




result in a small decrease in the number and size of hazardous waste




spills.  This would occur primarily as a result of the requirements




for maintenance of adequate containerization,  and indirectly, as a




result of the increased awareness of the waste hazard due to the




manifest system and labeling requirements.   The regulations would




not, however, significantly affect the frequency of major vehicular




accidents during transport resulting in spillage (available data on




the number and volumes of hazardous spills  are presented in Chapter




6).




     It is expected that the effects of any spill which may occur




would be reduced due to the requirements for prompt reporting of all




spills to the National Response Center and  for immediate action to




remove the spill in the most expedient manner.  These provisions




would complement those developed under Section 311 of the Clean Water




Act, and in effect, would extend the National Contingency Plan to




include upland spills as well as those into navigable waters.




     One of the side-benefits of the regulations would be the quanti-




fication of the amounts of hazardous material spilled, a presently




unknown figure, which is important for planning the size and deploy-




ment of emergency response teams as well as for assessing the need
                                 7-108

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for more stringent transportation safety codes.  At present it is

estimated that there may be about 2,000 spills of hazardous sub-

stances, including wastes, per year (U.S. Environmental Protection

Agency, 1977b).

     Transportation.  The effects discussed above would apply to all

segments of the hazardous waste management sequence.  As indicated in

Section 7.1.2.1, the generator regulations (Section 3001) would fur-

ther reduce the likelihood of spills through the imposition of speci-

fic containerization requirements for the transport of hazardous

wastes.  These requirements would reduce the likelihood of rupture

and spillage of wastes during shipment.  Further, the transporter

regulations also prohibit transportation of containers of hazardous

wastes which are leaking or appear to be damaged, or the transport or

consolidation of incompatible wastes.  The regulations could also

prevent the types of incidents due to vehicle cleaning, as indicated

below:

     •  An insecticide (endrin) applicator rinsed and cleaned his
        truck into the Cuivre River at Moscow Mills, Missouri.  As a
        result, approximately 100,000 fish were killed, and the river
        was closed to fishing for one year by the Missouri Game and
        Fish Commission (Office of Solid Waste Management Programs,
        1974a).

     Storage and Disposal.  Spillage or other unintentional releases

from storage and disposal facilities would be decreased due to the

requirements to maintain waste container integrity by recontaineriz-

ing the materials whenever their original container begins to fail.

Additionally, any spills occurring at a storage or disposal facility


                                 7-109

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would be contained at the site by dikes and impervious surfaces which




would prevent migration of the wastes until cleanup operations can be




completed.




     7.1.5.2  Other Surface Releases.  The regulations would signifi-




cantly decrease the number of, and environmental damage resulting




from, surface releases of hazardous wastes.  Many parts of the regu-




lations apply.  All generators of wastes designated as hazardous




would have to comply with all of the Subtitle C regulations.  These




stipulate that all hazardous wastes designated for on-site or off-




site treatment, storage, or disposal would have to be sent to a




permitted facility.  The regulations would institute a manifest and




reporting system to enable tracking of wastes to ensure compliance.




All storage, treatment, and disposal facilities would have to use




diversion structures to prevent runoff from upland areas from flowing




onto active portions of the facilities.  Further, such facilities




would have to confine all runoff or any other discharge to a point




source which complies with the regulations promulgated under the




Clean Water Act of 1977.  The combined effects of these regulations




would be to eliminate most non-point surface discharge of wastes




defined as hazardous.  Specific effects of the various regulations




are discussed below.




     Characteristics, Identification, and Listing.  A large number of




hazardous wastes are either listed or fall under the characteristics




contained in the Section 3001 regulations.  Many have been involved








                                 7-110

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in past damage incidents.  The occurrence of such incidents would be




reduced as a result of the regulations.  However, many potentially




hazardous wastes are not listed and would not be included by the




characteristics.  At present, numerous potentially toxic, carcino-




genic, or mutagenic organic chemicals would not be included by the




toxicity characteristic that is based entirely on EPA Primary Drink-




ing Water Standards.  At present, Primary Drinking Water Standards




are promulgated for nine inorganic contaminants and six organic con-




taminants (all pesticides).  Although the number of contaminants reg-




ulated under the Drinking Water Standards will probably increase in




the future, it is likely that many potentially hazardous wastes would




escape regulation under this rule.  The Environmental Protection




Agency plans to expand this characteristic at a later time.




     Generators.  As mentioned above, generators of hazardous wastes




would not be allowed to dispose such wastes without also receiving a




permit as a disposal facility.  However, there would be a few exemp-




tions to these regulations.  Generators engaged solely in retail




trade or principally in farming would be regulated only with respect




to waste automotive oil.  Household wastes would be entirely exemp-




ted.  Further, generators who generate less than 100 kilograms per




month of hazardous wastes would not be subject to regulation.  These




exemptions would allow a small quantity of hazardous wastes to escape




regulation.  However, it is expected that the regulations issued by




EPA under the Federal Insecticide, Fungicide and Rodenticide Act







                                  7-111

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(FIFRA) of 1972 would adequately control pesticides from farmers; and


it is estimated that the 100 kilogram per month generation limit


would exclude less than 30,000 tons of hazardous industrial waste per


year in 1984, less than 0.1 percent of the total hazardous industrial


waste.  Wastes from these excluded generators could be disposed of as


nonhazardous wastes using current practices, could go into sewer sys-


tems or any other conventional disposal area, and could conceivably


eventually contaminate surface waters.  The impacts of this genera-


tion limit are difficult to define.  However, it is likely that the


excluded wastes would continue to cause essentially the same types of


impacts as they currently are causing.  With proper disposal of the


regulated wastes, the total impact of hazardous wastes on surface


waters should be significantly reduced.  Thus, although it is true


that some unregulated releases of hazardous wates could continue to


occur and that some hazardous wastes may cause significant damage in


any amount, such occurrences would be much less frequent and, gener-


ally, less severe than those which occur in the present uncontrolled


case.


     Transportation.  The transporter regulations would require that


transporters deliver all hazardous wastes io a- designated permitted


storage, treatment, or disposal facility.  In addition, transporters


could not transport containers which are leaking or appear to be dam-
                                                    tat

aged.  These requirements would eliminate willfull dumping of hazard-


ous wastes by transporters.  A typical incident of 'midnight dumping1




                                  7-112

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which could be precluded by the proposed regulations is as follows:

     •  In March 1972 a considerable amount of xylene was dumped into
        a drainage ditch along the Pennsylvania Turnpike.  The liquid
        waste flowed down the ditch, across a field, and into a
        nearby stream causing a fish kill (Cartwright and Lindorff,
        1976).

     As discusssed previously, the Subtitle C regulations would re-

duce the likelihood of spills of hazardous wastes and their associ-

ated surface water contamination by extending the DOT Hazardous

Materials Regulations to cover intrastate as well as interstate

transportation.

     Storage, Treatment, and Disposal.  The human health and environ-

mental standard for surface water would require that all facilities

be located, designed, constructed, and operated so that no discharges

from the facility violate the Water Quality Standards promulgated

under Section 303 of the Clean Water Act, or constitute a spill of

hazardous substances under Section 311 of that Act.   As previously

indicated, more specific regulations (General Facility Standards)

would require the use of diversion structures to prevent surface run-

off from flowing onto the facility and the use of dikes or other con-

taminant structures to collect runoff originating on the facility.

All discharges from such facilities, including discharges from leach-

ate and/or runoff collection systems, would have to be confined to

point sources and must comply with the regulations promulgated under

the Clean Water Act.  Further, siting limitations would restrict

facility siting on floodplains and in wetlands.  Additionally, each
                                 7-113

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type of facility (storage,  treatment,  and five types of disposal




facilities—incineration,  landfills,  surface impoundments, basins,




and landfarms) would have  to meet other standards which are discussed




in following sections.




     These regulations  would constitute a substantial improvement




over the present unregulated situation and should result in a signif-




icant decrease in the number of pollution incidents resulting from




hazardous waste storage and disposal.   However,  even though a dis-




charge may meet all presently promulgated standards (including those




under the Clean Water Act), it could  still decrease receiving water




quality up to the maximum  allowable limit for each regulated constit-




uent.  Since these limits  were picked  to ensure  adequate protection




of the environment and human health,  such an impact would likely be




minimal.  In addition,  there are many  potentially hazardous constitu-




ents of these wastes for which no standards have yet been promul-




gated.  This may be due to lack of adequate substantiation of




suspected human health effects, or to  lack of information on toler-




able levels to ensure the  absence of  chronic health effects.  It is




possible that some potentially harmful properties of other contami-




nants are not even suspected at this  time.  In this respect, waste




discharges could conceivably meet all  applicable standards and still




contribute to environmental degradation with potential human health




effects.  It must be emphasized, however, that such effects are now




occurring to a much greater degree without the controls that would be







                                 7-114

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instituted by the proposed regulations.  In addition, where the




permitting agency is able to document such a threat, they could




stipulate additional permit requirements on the authority of the




human health and environmental standard.




     The potential impacts of regulating the various types of facil-




ities are as follows:




     Storage.  The Subtitle C regulations would require that hazard-




ous waste storage operations be conducted, monitored, and inspected




in order to ensure that no discharge occurs.  Specific requirements




include impervious construction and the use of diversion and contain-




ment structures, such as dikes or trenches, to prevent the release of




runoff or spills.  Provisions are included requiring leakproof con-




struction of storage tanks and containers and for recontainerization




of leaking wastes.  Records of the identity and location of all




stored wastes must be kept during the entire storage period.  In




addition, the proposed regulations would require that all hazardous




waste facilities must receive a permit and are subject to inspection




at any time to ensure that they are being properly maintained.




     Since there are presently no requirements to report the loca-




tions or amounts of hazardous wastes in storage, there is no way of




quantifying even the existing pollution problems due to waste stor-




age, let alone the potential improvement due to the regulations.  In




the current unregulated situation, hazardous wastes may be stored in




drums, sacks, or even in piles or unlined ponds.  They might be







                                  7-115

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housed in warehouses or sheds,  or left in the open, occasionally cov-

ered with tarpaulins or other materials.  In addition, hazardous

wastes may be stored for extended periods of time because all avail-

able methods have been considered too expensive to be utilized with-

out the legal requirement to do so.   As a result, water pollution

incidents from improper storage of hazardous wastes are common.  A

typical incident that could have been prevented by the proposed reg-

ulations is described in EPA files:

     •  A herbicide manufacturer stored many tons of arsenic salt
        wastes on his plant site in Wisconsin.  As a result, both the
        Menominee River and local groundwater have been contaminated
        with water containing up to 1.0 ppm arsenic (The National
        Interim Primary Drinking Water Standard is 0.05 ppm) and
        sediment containing up to 35 ppm arsenic (Office of Solid
        Waste, Hazardous Waste Management Division, 1978b).

     Other incidents have occurred in which unregulated storage piles

have produced surface water contamination as a result of fires:

     •  One and a half million gallons of water were used to extin-
        guish a warehouse fire in Oroville, Washington where two tons
        of various chlorinated pesticides and 50 tons of fertilizer
        were stored.  Much of the water flowed through storm sewers
        to the Okanogen River,  where 0.8 ppm endrin was detected.
        Elevated levels of nitrate and pesticides were also detected
        in the groundwater (Office of Solid Waste, Hazardous Waste
        Management Division, 1978b).

     Incidents such as this would be addressed under the regulations

only if the warehouses contained waste, outdated, or off-spec pesti-

cides awaiting disposal.

     Treatment.  The specific regulations for treatment facilities

stipulate that all facilities must have the capability to safely

handle hazardous wastes in the event of an emergency or equipment

                                  7-116

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failure of any sort.  Such capabilities include automatic cut-off or




by-pass systems on continuous feed processes, emergency transfer of




reaction vessel contents, and emergency storage capacity.  Further-




all treatment chemicals, reagents, and wastes must be stored in com-




pliance with the regulations for storage; any basins used for treat-




ment must comply with the regulations for basins; and the entire




facility must be designed, constructed, operated, and maintained in




accordance with the human health and environmental standards.  Any




wastes produced from a treatment facility would also be subject to




the Subtitle C regulations.  If such a waste is hazardous in accor-




dance with the characteristics or listing regulations, the treatment




facility would have to comply with all other standards promulgated




under Subtitle C, including initiating a manifest and ensuring proper




disposal.  Upon final closure of the facility, all hazardous wastes




and residuals would have to be removed and properly disposed.




     The Subtitle C regulations would specifically exclude Publicly




Owned Treatment Works (POTW's) which are in compliance with applic-




able regulations promulgated under the Clean Water Act.  The Subtitle




C regulations would require only compliance with manifest require-




ments for wastes received at POTW's by truck or rail.  Industries




which discharge wastes into municipal sewer systems would not need to




comply with manifest requirements, but would have to meet all applic-




able pretreatment standards under the Clean Water Act, and would have




to obtain the approval of the municipal sewer system authority.







                                 7-117

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Sludges from POTW's would be exempt from the Subtitle C regulations,

but would still have to comply with the regulations promulgated under

Section 405 of the Clean Water Act.  Application of these regulations

could eliminate the following type of incident:

     •  In Louisville,  Kentucky in March 1977,  a wastewater treatment
        plant was shut  down after receiving large amounts of
        hexachloro-cyclopentadiene and octachlorocyclopentene.  Con-
        centrations of  "hexa" reached 47,000 ppm in sewer sediments,
        and 32 plant employees experienced watering eyes, respiratory
        ailments, or other ill effects due to the heavy vapors asso-
        ciated with the contaminants.  As a result, 105 million gal-
        lons per day of raw sewage was discharged to the Ohio river
        for more than two months.  It was estimated that the total
        diversion amounted to over 9 billion gallons of raw sewage
        while clean up  costs reached over $450,000 (State of
        Minnesota, 1977).

     Many similar, though less spectacular, incidents have also oc-

curred but would likely be avoided following implementation of the

proposed regulations.  In such cases, wastes introduced to sewer sys-

tems often travel through municipal treatment plants without affect-

ing the plant and without being affected by treatment.  These then

flow out with the discharge and may cause fish kills or water supply

contamination downstream, as illustrated below:

     «  Two fish kills  were noted in August and November 1975 in the
        Crow River near Hutchinson, Minnesota.   It was determined
        that they were  caused by cyanide levels as high as 0.31 mg/1
        in the stream.   The source was identified as the Hutchinson
        wastewater treatment plant which received ferrocyanide from a
        local industry.  Ferrocyanide dissociates in the presence of
        sunlight to release ionic cyanide which forms highly toxic
        hydrocyanic acid.  This dissociation process is accelerated
        with decreasing pH; therefore, the fish kills were only
        noticed during periods when the pH of the river or sewage
        effluent was lower than normal (State of Minnesota, 1977).
                                 7-118

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     Incineration.  In terms of potential to cause water pollution,




disposal facilities using incinerators are essentially the same as




treatment facilities.  Accordingly, the regulatory approach for pre-




vention of water contamination from the two types of facilities is




similar.  Both are treated as temporary facilities which would have




to comply with storage regulations, treat any residuals in accordance




with the Subtitle C regulation, and remove all wastes at the time of




closure.  Since incinerators have little direct impact on water qual-




ity- this segment of the regulations would not likely constitute a




significant improvement over existing conditions.  However, applica-




tion of the general facility standards (including the storage regu-




lations) would help eliminate incidents such as one reported by the




State of Minnesota (1977), where sloppy housekeeping at a hazardous




waste incineration facility resulted in a fire and in possible water




contamination.




     Landfills.  Pertinent features of the Subtitle C regulations




applicable to surface water pollution from landfills include the




requirement that landfills be located or designed, contructed, and




operated to prevent direct contact between the landfill and navi-




gable water, and that all active portions of landfills must be at




least 150 meters from any public, private, or livestock water supply.




The regulations also specify that diversion structures would have to




be constructed to prevent surface runoff from entering the landfill




and to collect all runoff originating on the landfill for treatment,







                                 7-119

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if necessary.  The regulations would allow the use of one of several




designs.  Where natural conditions allow,  the bottom and sides of the




landfill would have to consist of at least three meters of natural




in-place soil exhibiting a permeability equal to or less than 1 x




10"^ cm/sec and which satisfies certain other plasticity; pH, com-




position, and grain size requirements.   Such facilities would not




require a leachate collection system if it could be demonstrated that




liquids would not accumulate in the landfill to the extent that they




might be discharged to the surface in any  manner or to the ground-




water in a manner that violates the groundwater human health and




environmental standard.  Where naturally occuring soils do not meet




the above criteria, the regulations would  require the use of either a




1.5 meter soil liner and a leachate collection system; or a one meter




soil liner, a 20 mil synthetic liner, a leachate collection system,




and a leachate detection system. Other designs would be acceptable if




it could be demonstrated that they could provide equivalent contain-




ment.  Further, all landfills would have to either include leachate




collection systems or demonstrate that  liquids would not accumulate




in the landfill such that they may be discharged to the surface in




any manner (or to the groundwater in violation of the groundwater




human health and environmental standard).   Upon closure, the landfill




would have to be graded such that water would not pool over the land-




fill and such that erosion would be prevented.
                                7-120

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     These regulations should result in a significant decrease in

surface water contamination from landfills.  Quantification of the

magnitude of the impact is not possible since neither the number and

area distribution of landfills receiving hazardous waste nor the mag-

nitude of environmental problems associated with them are known with

any degree of accuracy.   However, the Office of Solid Waste Man-

agement Programs (1977) estimates that there are about 18,500 land

disposal sites in the United States which accept municipal wastes,

most of which also receive some industrial wastes.  In addition, the

number of unauthorized and uncontrolled dumping grounds may reach

150,000 (TEMPO, 1973).  Most of these were located without concern

for potential environmental contamination and, as a result, many of

them probably cause some degree of water pollution.  Examples of sit-

uations which could be avoided are numerous.  Many such incidents are

included in Appendix J.  The following example illustrates a typical

incident which would be avoided as a result of implementation of the

proposed regulations:

     •  In 1974, an investigation sparked by the deaths of three head
        of cattle near Byron, Illinois, discovered an abandoned dis-
        posal area for many industrial wastes, including cyanides,
        arsenic, cadmium, chromium, petroleum products, acids, and
        other wastes.  Soil, surface water, and groundwater con-
        tamination along with extensive damage to wildlife, aquatic
        life, and local vegetation were documented.  U.S. Drinking
 EPA is currently expecting to develop an inventory of industrial
 landfills during the second year following the publication of its
 hazardous waste disposal criteria (Office of Solid Waste, 1977a).


                                 7-121

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        Water Standards  were violated by at least five constitutents
        in surface water entering Rock Creek,  1.5 miles from the
        site:  arsenic,  60 ppb;  cadmium, 340 ppb; chromium, 17,200
        ppb;  cyanide,  365,000 ppb; and phenols,  8 ppb (standards for
        these contaminants are 50 ppb, 10 ppb,  50 ppb, 200 ppb, and 1
        ppb,  respectively) (State of Minnesota,  1977, Cartwright and
        Lindorff,  1976;  Office of Solid Waste,  Hazardous Waste Man-
        agement Division, 1978b).

     Surface Impoundments.  Pertinent features  of the regulations

regarding surface  water  pollution from surface  impoundments include a

mandate against any direct connection with navigable waters; a mini-

mum separation of  150  meters from any public,  private or livestock

water supply; a requirement for impervious natural or artificial

liners and leachate detection systems; and a system of dikes which

would prevent seepage  of wastes either vertically or horizontally.

Design parameters  for  the liner and dike systems are specified which

include minimum thicknesses and permeabilities  of liners as well as

minimum freeboard  and  capacities of dikes.  In  addition, periodic

monitoring and inspections and rapid correction of any deterioration

are required.  At  the  time of closure, all wastes must be removed,

unless the impoundment meets the criteria for,  and is closed in

accordance with, the regulations for landfills.

     As in the case of landfills, surface water contamination due to

failure of hazardous waste impoundments would  be greatly reduced by

the implementation of  these regulations.  Quantification of the mag-

nitude of the impact is  not possible since neither the total number
                                 7-122

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of existing lagoons nor the number of leaking lagoons is known.

It is currently estimated that there are a total of 100,000 indus-

trial impoundments in the U.S. and that 1.7 trillion gallons (6.4

billion cubic meters) per year of industrial wastewaters (not neces-

sarily hazardous) are pumped to oxidation ponds or lagoons in the

U.S. (Office of Solid Waste Management Programs, 1977).  It has been

further estimated that 100 billion gallons per year of the wastes

placed in the secondary treatment lagoons leak to the groundwater

(Office of Solid Waste Management Programs, 1977).  The total leakage

from all lagoons is unknown, but is probably significantly greater.

It is known, however, that numerous incidents have occurred.   Many of

them are described in Appendix J.  A typical incident, described in

EPA files, is as follows:

     •  A copper reclamation company located in a mid-Atlantic state
        from 1965 to 1969 bought industrial wastes from other plants,
        extracted the copper and stored the remaining liquids in ce-
        ment lagoons.  Three of the lagoons developed open seams and
        leaked toxic pollutants into an adjacent creek, killing all
        its aquatic life.  After an injunction was issued requiring
        the wastes to be treated, the company defaulted,  leaving 3.5
        million gallons of toxic wastes on the site.   Heavy rains in
        April, 1970 overflowed the lagoons into a tributary of the
        Delaware River, forcing county officials to build a dike
        around the area.  The wastes were finally neutralized and
        ocean dumped at the state's expense of $400,000 (Office of
        Solid Wastes, Hazardous Waste Management Division, 1978b).
"fe    .
 EPA is currently expecting to develop an assessment of surface
 impoundments and their potential for contaminating water.  The
 assessment will fulfill EPA's mandates under the Safe Water Drinking
 Act and RCRA (Office of Solid Waste, 1977a).


                                 7-123

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     Basins.  The proposed regulations would define basins as uncov-




ered devices constructed of artificial materials, used to retain




wastes as part of a treatment process, usually with a capacity of




less than 100,000 gallons, e.g.,  open mixing tanks, clarifiers, and




open settling tanks.  Such structures are generally temporary, and




operated in conjunction with other treatment facilities.  The regula-




tions would require impermeable construction and mechanical integrity




sufficient to prevent discharge of wastes to navigable water; daily




monitoring or inspection, and immediate repair of any damages; and




removal of all waste upon final closure.  As in the case of surface




impoundments, these regulations would result in a decrease in surface




water contamination compared to that occurring in the present unregu-




lated situation.  Due to the lack of data on the number of basins in




use, the degree of the impact cannot be determined.




     Landfarms.  Pertinent sections of the proposed regulations con-




cerning the potential for water pollution from landfarms include the




prohibition against the use of landfarms for certain water soluble




toxic inorganics; the requirement that landfarms shall be located,




designed, constructed and operated to prevent direct contact between




the treated area and navigable water; and a minimum separation of 150




meters between the treated area and any public, private, or livestock




water supply.  Other requirements are that the potentials for stand-




ing water or erosion are both minimized and that waste application




shall not occur when the soil is saturated, or when its temperature







                                 7-124

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is at or below 0 C.  Although the regulations specifically pertaining




to landfarming would include no provisions for runoff control, the




general facility standards would require that all runoff be collected




and confined to a point source which is in compliance with the regu-




lations promulgated under the Clean Water Act.




     Although the concept of landfarming has been applied to munici-




pal sludges for many years, experience with, and data on landfarming




of hazardous industrial sludges are sparse.  The regulations contain




several provisions to reduce pollutant migration.  They would limit




application of arsenic, boron, molybdenum, selenium, and volatile




wastes; require the use of fine grained soils consisting primarily of




silts and clays; require maintenance of a minimum pH of 6.5 and pre-




vention of anerobic conditions in the zone of incorporation; require




semi-annual soil monitoring; and would restrict the growth of food




chain crops.  While these requirements would certainly reduce water




contamination relative to existing uncontrolled disposal methods, the




regulations would not address rates of application; they would not




specifically require runoff monitoring; and they would not address




other toxic elements or organic wastes, some of which have caused




concern in land application facilities for municipal sludges.




     Although it is true that most municipal sludge landfarming oper-




ations were oriented towards agricultural crop production, and that




under aerobic conditions and at a pH greater than 6.5, most toxic




inorganics are relatively insoluble, the potential for water







                                 7-125

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degradation would still exist.  (It should be noted that the trans-




formation of Cr+3 to Cr+(> is favored by oxidizing conditions and




high pH; and that CrO^=, the predominant ionic form under those




conditions, was not adsorbed by the common clay minerals tested by




Griffin et al., [1976].)  Additionally, the presence of acidic wastes




and wastes which exert high oxygen demands may make it difficult to




maintain the required pH and aerobic conditions, which could allow




dissolution of some previously precipitated toxic elements.




     7.1.5.3  Underground Discharges.  Groundwater pollution is pos-




sible in any situation in which hazardous wastes are placed in or on




the ground with a hydraulic connection to an aquifer.  Such a hydrau-




lic connection consists of a permeable pathway from the wastes to an




aquifer.  It may be composed of unconsolidated sands and gravels,




permeable bedrock such as some sandstones, or a system of fractures




or joints in the bulk rock.  A more complete discussion of ground-




water and its contamination is contained in Appendix L.




     There are no existing estimates of the amount of hazardous




wastes which presently contaminate groundwater.  However, it is esti-




mated that there are about 18,500 land disposal sites in the United




States which accept municipal wastes, most of which also receive some




amount of industrial waste (Office of Solid Waste Management Pro-




grams, 1977).  It is further estimated that these disposal areas




cover a total of approximately 500,000 acres and that they receive




approximately 135 million tons of refuse per year.  Based on average







                                  7-126

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infiltration rates, it is estimated that these sites generate a total




of 90 billion gallons of leachate per year (Office of Solid Waste




Management Programs, 1977).  In addition, the number of unauthorized




and/or otherwise unregulated dumping grounds in the U.S. may reach




150,000 (TEMPO, 1973).  EPA is currently planning to inventory indus-




trial landfills beginning the second year following promulgation of




its hazardous waste regulations (Office of Solid Waste, 1977a).




     It is estimated that there are a total of 100,000 impoundments




in the U.S. (Office of Solid Waste Management Programs, 1977).  Data




are insufficient to estimate the total volume of wastes sent to all




impoundments, but  is has been estimated that secondary treatment




lagoons, such as oxidation ponds, receive 1,700 billion gallons of




industrial, though not necessarily hazardous, wastes per year and




leak 100 billion gallons (approximately 6 percent) (Office of Solid




Waste Management Programs, 1977).  Other types of surface impound-




ments may contribute additional hazardous leachates.




     Tables 7-10 and 7-11 summarize some of the hundreds of reported




incidents of groundwater contamination due to hazardous waste dis-




posal in impoundments and in landfills.  Table 7-10 summarizes in-




cidents due to leakage of wastewater from surface impoundments and




lists the major resultant pollutants, and Table 7-11 summarizes in-




cidents due to landfill leaching.  The fact that Table 7-11 lists




more municipal landfills than industrial landfills is due to a lack




of data regarding the location and operation of industrial landfills








                                 7-127

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                            TABLE 7-10
         ORIGINS AND POLLUTANTS IN 57 CASES OF GROUND WATER
         CONTAMINATION IN THE NORTHEAST CAUSED BY LEAKAGE OF
             WASTE WATER FROM SURFACE IMPOUNDMENTS *
Type of Industry or Activity
                                     Number
                                    of Cases
              Principal  Pollu-
              tant (s)  Reported
Chemical
13
Metal processing and plating
 Electronics
 Laboratories  (manufacturing
   and processing)
 Paper

 Plastics
 3

 3
Ammonia
Barium
Chloride
Chromium
Iron
Manganese
Mercury
Organic chemicals
Phenol
Solvents
Sulfate
Zinc

Cadmium
Chromium
Copper
Fluoride
Nitrate
Phenol

Aluminum
Chloride
Fluoride
Iron
Solvent

Arsenic
Phenols
Radioactive
  materials
Sulfate

Sulfate

Ammonia
Detergent
Fluoride
                              7-128

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                   TABLE 7-10  (Continued)
Type of Industry or Activity
Sewage treatment
Aircraft manufacturing
Food processing
Mining sand and gravel
Oil well drilling
Oil refining
Battery and cable
Electrical utility
Highway construction
Mineral processing
Paint
Recycling
Steel
Textiles
Number
of Cases
3
2
2
2
2
2
1
1
1
1
1
1
1
1
Principal Pollu-
tant (s) Reported
Detergents
Nitrate
Chromium
Sulfate
Chloride
Nitrate
Chloride
Chloride
Oil
Oil
Acid
Lead
Iron
Manganese
Turbidity
Lithium
Chromium
Copper
Acid
Ammonia
Chloride

*Miller et al.,  1974.
                             7-129

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                          TABLE 7-11

          SUMMARY OF DATA ON 42 MUNICIPAL AND 18 INDUSTRIAL
                         CONTAMINATION CASES *
                                                 Type of Landfill
 Findings                                       Municipalt  Industrial


Assessment of principal damage
   Contamination aquifer only                      9            8
   Water supply well(s) affected                  16            9
   Contamination of surface water                 17            1

Principal aquifer affected
   Unconsolidated deposits                        33           11
   Sedimentary rocks                               1            3
   Crystalline rocks                               2            4

Type of pollutant observed
   General contamination                          37            4
   Toxic substances                                5           14

Observed distance traveled by pollutant
   Less than 100 feet                              6            0
   100 to 1,000 feet                               8            4
   More than 1,000 feet                           11            2
   Unknown or unreported                          17           12

Maximum observed depth penetrated by pollutant
   Less than 300 feet                             11            3
   30 to 100 feet                                 11            3
   More than 100 feet                              52
   Unknown or unreported                          15           10

Action taken regarding source of contamination
   Landfill abandoned                              5            6
   Landfill removed                                1            2
   Containment or treatment of leachate           10            2
   No known action                                26            8

 Action taken regarding ground water resource
   Water supply.well(s) abandoned                  4            5
   Ground water monitoring program established    12            2
   No known action                                26           11

 Litigation
   Litigation involved                             8            5
   No known action  taken                          34           13


     *Miller  et al.,  1974.
     tMany of these  municipal  landfills also accept  some industrial
 sludges and liquids  in addition  to septic wastes and sewage sludges.
                                  7-130

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and to the comparatively large number of well documented studies of




municipal landfills.  In fact, it is estimated that, at least in the




northeast, industrial landfills are far more abundant than municipal




landfills (Miller et. al.,  1974).




     The fact that many currently operating landfills are leaking and




that this leakage may not be detected for significant periods of time




is amply illustrated by a recent study performed for EPA (U.S. Envi-




ronmental Protection Agency, 1977c).  The study selected 50 landfill




sites representing a variety of geohydrologic and climatic condi-




tions, disposal methods, and a wide range of industrial wastes.  The




sites were a minimum of three years old, with no history of known or




suspected contamination.  Four of the sites had some kind of leachate




control system.  Thirty-two sites had existing monitoring systems.




Five others had water supply wells near enough to be used for moni-




toring.  At sites where no monitoring system existed, or where the




existing system was not considered adequate, new wells were placed.




Each site was covered by several monitoring wells and at least one




background well.  The results of sampling are summarized in Table




7-12.  It was determined that at 43 sites definite migration of haz-




ardous constituents had occurred.  The seven other sites were also




contaminated by hazardous materials, though it could not be shown




that their contamination was due to the disposal sites.  At 26 sites,




hazardous inorganic constituents in water from one or more monitoring




wells exceeded the EPA drinking water limits.  Only one of the four







                                 7-131

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                                      TABLE 7-12

                     GROUNDWATER CONTAMINATION FROM INDUSTRIAL WASTE
                               LAND DISPOSAL SITES*


Contaminant


Arsenic
Barium
Chromium
Cobalt
Copper
Mercury
Molybdenum
Nickel
Lead
Selenium
Zinc
Light Volatile Organics
Heavy Volatile Organics
Halogenated Organics
Alkyl Benzenes
Benzene
Butyl Alcohol
Camphor
Chlorinated Phenols
Cyanide
Heptachlor
Methyl Ethyl Ketone
Napthalene
Polychlorinated Biphenyls
Tr ichlor oe thylene
Toluene
Xylenes
# of Wells
Which Exceeded
Background

5
29
12
15
19
5
2
18
3
28
13
18
9
21
2
2
1
1
2
20
1
2
1
1
2
3
4
# of Wells
Above EPA
Drinking Water
Standards
3
3
3
t
2
1
t
4-
3
23
2
t
t
t
t
t
t
+
j-
t
t
4-
t
t
4.
j
f
Max Cone.
Observed
(mg/1.)

5.8
3.8
420
0.22
2.8
0.0008
0.24
0.67
19
0.59
240
1000
0.59
0.006
Detected
Detected
Detected
Detected
0.003
14.0
Detected
Detected
Detected
0.002
0.3
Detected
Detected
   *Complied from data presented  in  U.S.  Environmental  Progection Agency,  1977c.
This study examined 50 disposal sites  using  a  total  of  112  monitoring wells in
addition to background wells  at each site:   Eighty-six  wells  at  43 sites con-
tained one or more hazardous  substances which  were determined to have migrated
from the site.  Wells at 26 sites contained  hazardous  inorganic  contaminants
which exceeded EPA Drinking Water Standards.   The wells ranged from 10 to 1500
feet from the disposal sites.
   NOTE:  Three additional wells  were  contaminated by  heavy metals, one with
light volatile organics, and  one  with  halogenated organics; however, no back-
ground data was available for comparison.
   •"•Not presently covered by  EPA  Interim  Primary Drinking Water  Standards.
                                         7-132

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"controlled" landfills showed no contamination greater than back-

ground levels; one showed a slight increase in one constituent above

background levels; and the remaining two showed significant increases

of several contaminants.   Both of the leaky landfills had design

failures which allowed portions of the leachate to escape.  The con-

clusions reached by the study group were that:

     •  Groundwater contamination at industrial waste land disposal
        sites is a common occurrence;

     •  Hazardous substances from industrial waste land disposal
        sites are capable of migrating into and with groundwater;

     •  Few hydrogeologic environments are suitable for land disposal
        of hazardous waste without some risk of groundwater
        contamination;

     •  Continued development of programs for monitoring industrial
        waste land disposal sites is necessary to protect groundwater
        quality;

     •  Most old industrial waste disposal sites, both active and
        abandoned, are located in geologic environments where
        groundwater is particularly susceptible to contamination;

     •  Many waste disposal sites are located where the underlying
        aquifer system can act as a pipeline for discharge of
        hazardous substances to a surface water body;

     •  At sites presently monitored, the use of wells as an aid in
        evaluating groundwater conditions is generally poor, due to
        inadequacies with respect to one or more of the following
        parameters:
        —number of wells
        —distance of wells from potential contamination source
        —positioning of  wells in relation to groundwater flow
        —sealing against surface water contamination, or
            inter-aquifer water exchange
        —completion methods, such as development, maintenance, and
            protection against vandalism;
                                 7-133

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     •  At sites  presently  monitored,  the sampling program is
        generally poor due  to inadequacies with respect to one or
        more of the following parameters:
        —obtaining a sample representative of aquifer water
        —sample preparation
        —frequency of sampling
        —availability of background water-quality data
        —selection of constituents  to be analyzed
        —availability of laboratories
        —maintaining records in usable form.

These conclusions emphasize the care with which hazardous waste land-

fills must be located, constructed,  and monitored.

     With respect to surface releases, the Subtitle C regulations

would allow no surface or subsurface discharges of hazardous wastes

by generators, transporters, or storers.  The  specific regulations

applicable to storers would require  impervious construction and mon-

itoring to ensure that no groundwater contamination occurs.  Compli-

ance with these regulations would effectively  eliminate contamination

of groundwater with the regulated hazardous wastes originating from

generators, transporters, and storers.  Many of the incidents repor-

ted in Appendix J could be avoided under the regulations.  The exis-

tence of the Section 3002 manifest system could make the following

type of incident highly unlikely to occur:

     •  In 1971 a major chemical company contracted with a trucker to
        haul approximately 5,000 drums of petrochemical wastes, in-
        cluding acrylonitrile, acetone, epichlorohydrin, and a number
        of other toxic, flammable, explosive,  and/or oxidizing chemi-
        cals for disposal in a landfill.  Instead, approximately
        4,500 of the drums were transported to an abandoned chicken
        farm in Dover Township, New Jersey where they were stock-
        piled and subsequently dumped.  Although the drums and some
        contaminated soil were removed under court order in 1972, in
        1974 it was discovered that a large but unknown portion of
        the Cohansey Aquifer, a major regional aquifer, had become

                                 7-134

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        contaminated with petrochemicals, resulting in the condemning
        of approximately 150 private wells.  The cost of extending
        public water supply into the area was about $300,000.  More-
        over,  this incident resulted in adverse impact on local
        building and development.  The exact magnitude of the envi-
        ronmental and economic damage has not yet been determined
        (Office of Solid Waste Management Programs, 1976; State of
        Minnesota, 1977).

     The regulations for the other potential sources of groundwater

contamination (I.e., treatment and disposal facilities) are more

intricate.  The groundwater human health and environmental standard

for the proposed treatment and disposal (Section 3004) regulations

states the objective that no facility shall degrade groundwater such

that Underground Drinking Water Sources (UDWS) anywhere off the

facility property would at any time be endangered.  The proposed reg-

ulations would define UDWS as an aquifer which currently supplies a

public water system; has less than 10,000 mg/1 total dissolved sol-

ids; or is designated as a UDWS by the Administrator of EPA after a

public hearing.  The proposed regulations would consider a UDWS en-

dangered if operation of a facility caused the violation of a Nation-

al Primary Drinking Water regulation; made it necessary to treat or

increase treatment of the water for any present or future use; or, if

such practice could otherwise adversely affect the health of persons,

such as by adding a substance that would make the water unfit for hu-

man consumption.

     The general facility standards for hazardous waste treatment and

disposal would require that discharges to groundwater not occur un-

less the facility owner/operator can demonstrate that the discharge

                                 7-135

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will not violate the groundwater human health and environmental stan-




dard.  Additional general standards would prohibit location of facil-




ities in the recharge area of sole source aquifers would require




periodic groundwater monitoring for all facilities except landfarms,




and would reuqire leachate monitoring for landfills and surface im-




poundments.  Additional specific requirements that would affect each




type of disposal facility are discussed below.




     Landfills.  The proposed regulations for landfills would require




a minimum separation of 1.5 meters between the bottom of the liner or




natural barrier and the historical mean water table, unless the land-




fill owner or operator can demonstrate that no direct contact will




occur between the landfill and the water table.  Further, the pro-




posed regulations would not allow disposal of bulk liquids or sludges




containing less than 20 percent solids; they would require a minimum




separation of 150 meters from any public, private, or livestock water




supply; and they would specify certain design characteristics, inclu-




ding minimum thicknesses, permeabilities, and other characteristics




of  liner systems.  Where natural geologic conditions permit, land-




fills would be allowed to use in-place soils (meeting certain thick-




ness, permeability and structural requirements) without a leachate




collection system.  Otherwise, a leachate collection system would be




required.  In some cases, a double liner system (one synthetic and




one  soil liner), with a leachate collection system and a leachate de-




tection system would be required.  Other designs would be acceptable







                                  7-136

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if it could be demonstrated that they provide equipment containment.

The choice of design would have to be approved before construction of

the facility began.

     Successful implementation of these regulations would result in a

significant reduction in groundwater contamination caused by hazard-

ous waste landfills.  As discussed at the beginning of this section,

the extent of the reduction cannot be quantified since the amount of

contamination presently occurring is unknown.  However, many examples

of situations which could have been prevented by these regulations

are summarized in Appendix J.   A prominent example of the effects of

no control is as follows:

     •  Between 1960 and 1960, a large landfill near Llangollen, in
        New Castle County, Delaware, accepted industrial wastes of
        unknown character and origin, in addition to residential and
        commerical wastes.  The wastes were placed in an abandoned
        sand quarry underlain in part by a thin layer of sandy clay
        which separated it from the unconsolidated Potomac Aquifer, a
        major source of water supply for the area.  It turned out
        that the clay layer was absent beneath part of the site and
        that some of the clay was excavated for cover material at the
        landfill.  Groundwater contamination was first noted in 1972
        in a well 800 feet from the fill.  The resulting investiga-
        tion discovered a large plume of contaminated groundwater
        moving towards a well field producing 4 to 5 million gallons
        per day (mgd) located about 5,000 feet from the hill.  A mas-
        sive pumping operation now removes 3 mgd from the aquifer,
        while the well field is pumping at a reduced rate of 2 mgd,
        the deficit made up by other sources at the County's expense.
        Presently a dozen wells are pumping contaminated water to
        create a cone of depression near the site, and 35 wells are
        monitored monthly.  So far, expenses have reached $800,000
        for monitoring,  pumping, and replacing water supplies. It is
        expected that is will cost more than $20 million if the dump
        must be moved, and that it will require 10 years to restore
        full usage of the aquifer (Cartwright and Lindorff, 1976;
        Garland and Mosher, 1975).
                                 7-137

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     Surface Impoundments.  The regulations specific to surface im-




poundments would require the facility to be designed, constructed,




operated, and maintained such that no discharge to ground or surface




water would violate the respective human health and environmental




standards.  Other requirements would prevent direct contact between




the impoundment and the water table; maintain a separation of 150




meters from any public, private or livestock water supply; and would




specify certain design parameters, including the minimum thickness




and characteristics of liner systems.  Two types of design are cited,




though others could be acceptable if they provided equivalent con-




tainment.  Where natural conditions allow, the bottom and sides of




the impounument would consist of at least three meters  of natural,




in-place, clay-rich soils having a maximum permeability of 10~'




cm/sec and certain structural characteristics.




     A leachate monitoring system would also be required.  Under




other conditions, the impoundment would require a double liner system




and a leachate detection system.  The regulations would allow an




artificial liner meeting given specifications.  If such a liner were




used, the regulations would require removal of all wastes at the time




of facility closure.  If an impoundment does not contain an artifi-




cial liner, and if it also meets the landfill standards, the proposed




regulations would allow its closure as a landfill.  Otherwise, the




hazardous wastes would have to be removed at the time of closure.
                                 7-138

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     Implementation of these regulations would significantly decrease

the occurrence of groundwater contamination by hazardous wastes.  As

in the case of landfills, the extent of the decrease cannot be quan-

tified due to the lack of information on the extent of present con-

tamination by improperly located and operated impoundments.  However,

as discussed in the beginning of this section, the problem is known

to be significant.  Numerous incidents of contamination have been ob-

served, some of which are summarized in Appendix J.  The following

example illustrates the potential magnitude of a single incident:

     •  An aircraft plant, operating in South Farmingdale on Long
        Island during World War II, generated large quantities of
        electroplating wastes containing chromium, cadmium, and
        other metals.  It has been estimated that 200,000 to 300,000
        gallons per day of these wastes were discharged into unlined
        disposal basins throughout the 1940's.  A treatment unit for
        chromium was built in 1949, but discharge of cadmium and
        other metals continued.  The local groundwater occurs in
        three unconsolidated aquifers resting on crystalline bedrock.
        The uppermost aquifer consists of beds and lenses of fine-
        to-coarse sand and gravel and extends to within 15 feet of
        the land surface. Groundwater contamination by chromium was
        first noted in 1942 by the Nassau County Department of
        Health.  Extensive studies in 1962 indicated that a huge
        plume of contaminated groundwater had been formed, measuring
        up to 4,300 feet long, 1,000 feet wide,  and extending from
        the surface of the water table to depths of 50 to 70 feet
        below the land surface. _Maximum concentrations of both hexa-
        valent chromium and cadmium were about 10 mg/1 in 1962.
        (Hexavalent chromium had been measured as high as 40 mg/1 in
        1949.)  This huge contaminated plume cannot be removed or de-
        toxified without massive efforts and will take many more
        years of natural attentuation and dilution before it becomes
        usable again.  Meanwhile,  it is still slowly moving, threat-
        ening a nearby creek and other wells in the area (Tinlin,
        1976; State of Minnesota,  1977.)

     Landfarms.  The regulations for landfarms would prohibit direct

contact with the water table; would require the use of fine grained

                                 7-139

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silts and clays chosen to prevent vertical migration of the wastes




more than three times the depth of waste incorporation; would require




closing any caves, wells, or other direct connections to the subsur-




face environment; would require grading to prevent water from ponding




on the facility; would require maintenance of aerobic conditions and




a pH of 6.5; and would prohibit waste application when the soil is




saturated or frozen.  With respect to surface waters, implementation




of these regulations would help reduce both ground and surface water




contamination by hazardous wastes.  However, the regulations would




not require groundwater monitoring on the theory that any waste mi-




gration towards the groundwater would be detected by the required




semi-annual soil core analyses.  Further, although the proposed reg-




ulations specify soil types and certain structural characteristics




(liquid limit greater than 30, and plasticity index greater than 15),




they do not specify permeability or compaction of the soils or re-




quire liners or other base preparation.  While the soil types that




would be required are generally relatively impermeable and although




the regulations include the constraint that vertical migration of




hazardous constituents must not exceed three times the depth of waste




incorporation, the possibility of groundwater contamination would




still exist.  Such contamination could occur due to variabilities in




soil permeability (e.g., due to the inclusion of local sandy zones




within the silts and clays), or due to variations in the thickness or




compaction of the soils.  Additionally, although most toxic elements







                                 7-140

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are relatively immobile at the required pH and in oxygen rich envi-




ronments, formation of the hexavalent form of chromium  (CrO^~) is




favored under those conditions.  Although the chromate  ion may be




precipitated by the presence of a few other metals  (e.g., lead),




chromate is not adsorbed by two of the major clay minerals—the only




two tested by Griffin et al. (1976).




     Other Treatment and Disposal Methods.  Discharges  to ground-




waters would be allowed from treatment facilities and basins, provid-




ing that such discharges would not violate the groundwater or surface




water human health and environmental standards.  The regulations




would also require facility maintenance to avoid leaks and emergency




releases due to equipment malfunctions, and would require compliance




with applicable standards for storage facilities or surface impound-




ments.  These regulations would contribute to the reduction of water




contamination with hazardous wastes, though, as discussed previously,




quantification of the improvement is difficult.




     The regulations do not specifically deal with underground injec-




tion or ocean disposal of hazardous wastes.  It is anticipated that




these activities will be regulated by standards promulgated under the




authority of the Marine Protection, Research, and Sanctuaries Act and




the Safe Drinking Water Act.  This ommission does not preclude use of




these techniques,  and any storage or transportation of hazardous




wastes in conjunction with these activities would be subject to the




appropriate RCRA regulations.







                                 7-141

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     Taken collectively, the proposed regulations would eliminate

most of the pathways by which hazardous wastes presently contaminate

both surface water and groundwater.  The regulations would, there-

fore, result in a substantial reduction in the number of incidents in

which such contamination occurs.  However, a few pathways would re-

main, as discussed in the previous sections.  The following incident

serves to point out the potential for contamination by hazardous

wastes which could escape regulation:

     •  In May 1972, when a private commercial well was dug for a new
        office of a small contractor in Perham, Minnesota.  Within
        the same month, 5 of 13 employees became ill with gastroin-
        testinal ailments.  Six other employees also became ill with-
        in the next 10 weeks, two requiring hospitalization including
        one who lost the use of his legs for six months due to severe
        neuropathy.  After several weeks it was discovered that the
        well was located 20 feet from a site where approximately 50
        pounds of grasshopper bait had been buried between 1934 and
        1936.  The bait, which consisted of arsenic trioxide,  bran,
        sawdust, and molasses, had been buried at a depth of 7 feet,
        while the affected well was 31 feet deep.  Well samples con-
        tained up to 21 ppm arsenic (U.S. Interim Primary Drinking
        Water Standards are 0.05 ppm).  Soil samples contained up to
        12,600 ppm of arsenic in the vicinity of the burial spot.  To
        date the affected well has been capped and an alternate water
        supply obtained at a cost of about $300.  Twelve nearby wells
        are also monitored periodically to establish the threat to
        the Perham municipal well field three-fourths a mile away.
        It has been estimated that removal of the contaminated soil
        would cost up to $25,000 (Walker, 1973; Office of Solid Waste
        Management Programs, 1975a; Cartwright and Lindoroff,  1976;
        State of Minnesota, 1977).

     During two years only 50 pounds (about 23 kg) of wastes were

disposed, and 40 years later 11 people was seriously ill as a result.

This amount of waste would easily qualify for exclusion from the reg-

ulations under the generator limit even if it was generated in one
                                  7-142

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month.  Wastes thus excluded are essentially unregulated, and may be

disposed in conventional landfills, sewers, or by other less-

controlled methods.  As a result, although incidents due to the dis-

posal of large quantities of wastes would be reduced, the potential

for incidents, such as that which occurred at Perham, Minnesota,

would still exist.

     Such random disposal of small amounts of wastes does not neces-

sarily result in discrete identifiable incidents.  Perhaps a more

serious problem is the widespread increase in non-specific environ-

mental contamination by hazardous substances which has been occur-

ring across the nation, as evidenced by the following example:

     •  In May 1975, the U.S. Food and Drug Administration halted an
        interstate shipment of carp taken from Lake Pepin (located on
        the Mississippi River on the border between Minnesota and
        Wisconsin) by a commercial fisherman.  About 20,000 pounds of
        fish were destroyed when analysis revealed that some of the
        fillets exceeded the FDA limit of 5 ppm PCB.  At about the
        same time, an Inter-Agency Task Force on PCB's was formed to
        investigate PCB contamination in the Mississippi River.
        Their results indicate variable concentrations of PCB in the
        water; concentrations of up to 500 ppb in sediments in Spring
        Lake and up to 1000 ppb in sediments in Lake Pepin; con-
        centrations in individual fish ranging from 0.03 to 33 ppm;
        and average concentrations for fish species ranging from 0.04
        to 3.97 ppm, with the highest concentrations in white bass,
        carp, and channel catfish.  Significant damages have been
        sustained by both commercial fishermen and mink farmers.  The
        task force concluded that the contamination was probably
        caused by a large number of small inputs including municipal
        wastewater treatment plants, industrial discharges, re-
        suspension of bottom sediments during dredging, leachate from
        landfills, and fallout from the air after burning PCB con-
        taminated materials (State of Minnesota, 1977).

     Following successful implementation of the Subtitle C regula-

tions and associated regulations under FWPCA and other acts, the only

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unregulated sources of hazardous contaminants to surface waters would

be resuspension of bottom sediments; leachate from presently leaking

landfills or other dumps which are inactive when the regulations go

into effect, or are inadequately sealed following enactment; leachate

or other discharges from facilities receiving nonregulated wastes;

and spilled materials which escape clean-up attempts.   Thus, although

several of the major sources of contamination would be eliminated,

situations like this one may continue to occur due in part to uncor-

rected existing problems (e.g., abandoned dumps and contaminated

river and harbor sediments), and in part to unregulated waste streams

(e.g., those from households and from generators not producing more

than 100 kilograms per month,  and unlisted, potentially toxic

wastes).

     The problem of dealing with existing sites which cannot be modi-

fied to qualify for a permit is not specifically addressed in the

regulations.  These sites include marginal operations which may be

abandoned rather than complying with the closure procedures outlined

in the regulations.  It is likely that these facilities cannot be

properly closed without removing all the waste materials and the con-

taminated soils from the site, as illustrated .by the following ex-

ample:

     •  During the 1960's, chromium from a waste lagoon in New Jersey
        contaminated several wells and a nearby stream.  The contam-
        ination continued for about 10 years before the problem was
        recognized in 1970.  By then, the total chromium concentra-
        tion was 150 ppm at a well 700 feet from the lagoon.  Since
        then, the source of contamination has been eliminated, but

                                 7-144

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        again, the plume of polluted groundwater is still there.  As
        a result, a former municipal drinking water well is currently
        used  for industrial purposes only (Office of Solid Waste,
        Hazardous Waste Management Division, 1978b).

     In such  cases, the regulations would provide the beneficial im-

pacts of identifying the unacceptable facilities and preventing their

continued use, although the procedures for preventing the on-going

pollution from wastes already in place at such sites are not clear.

     An analogous situation is the problem of former disposal sites

which have already been abandoned.  These sites may or may not even

have been recorded.  Due to the often long time periods required for

groundwater contamination to progress to the point where it is iden-

tified, such  sites have the potential for creating severe problems

over the next few years.  This problem is particularly important in

light of the  recent EPA study (U.S. Environmental Protection Agency,

1977c) reporting that at least 43 out of 50 randomly chosen landfills

which had never been suspected of leaking, were, in fact, contribu-

ting to groundwater contamination, with wells at 26 of the sites

exceeding U.S. Drinking Water Standards.  The major impact of the reg-

ulations would be to prevent the creation of such problems in the

future, though discoveries of groundwater pollution due to improper

hazardous waste disposal in the past would probably continue to occur

for some time to come.

     7.1.6  Public Health Impacts.  Inadequate hazardous waste man-

agement practices have frequently led to cases of injury to human

health.  The  two major pathways by which public health may be

                                 7-145

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affected by hazardous wastes are direct contact (e.g., occupational




exposure) and secondary contact (through the media of contaminated




air, water, or soil).  The severity of the potential impacts is




illustrated by the numerous incidents described in Appendix J.  This




appendix documents 49 separate instances of traceable public health




effects, including deaths, and 84 instances of contamination of




drinking water, including major water supplies.




     From the way in which most of the reported incidents have come




to light, it is very likely that the vast majority of such incidents




go unreported.  Factors which contribute to under-reporting are the




long periods of exposure and/or gestation often required before




health effects are noted, the difficulties in establishing direct




causative relationships, and the synergistic effects of exposure to




pollutants from other sources in addition to hazardous wastes.




     As discussed in Chapter 6, the quantities of potentially hazard-




ous waste generated are expected to increase both as a result of ex-




panding industrial outputs and the progressive implementation of air




and water pollution control programs, ocean dumping bans, and associ-




ated environmental legislation.  Thus, in the absence of specific




regulations, inadequate hazardous waste management could be expected




to continue to result in numerous cases of potentially severe health




effects.




     Further, as witnessed by the examples cited in Appendix J, there




is often a considerable time lag between the occurrence of a







                                 7-146

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contamination event and the time at which its impact becomes evident.

Since virtually all the reported incidents were discovered only after

damage had already occurred, there is, nationally, a very significant

potential for many similar public health impacts to be detected from

wastes that have already been or currently are being improperly

transported, stored, treated, or disposed.

     A major incident recently came to light which illustrates the

magnitude of the potential health effects which can occur in the ab-

sence of regulatory control.  Although the incident was only recently

brought to national attention, its history dates back to 1947, when a

chemical company in Niagara Falls, New York used Love Canal as an

industrial toxic waste dump:

      •  Thousands of drums containing toxic chemicals were dropped
         or buried into the receding water of Love Canal and its
         banks.  The site was last used as an industrial dump in
         1952.  In 1953, the surrounding land was sold and a school
         and homes were built on the site.  During the construction
         of the La Salle Expressway to the south of the original
         landfill site, noxious fumes, corrosive waters, and oily
         materials were encountered, according to State personnel and
         local residents.  When other locations within the 16-acre
         site were also developed, drums were exposed during excava-
         tion work allowing the release of noxious fumes and oily
         liquids, causing several work stoppages.  Noxious fumes and
         hazardous liquid chemicals were also detected in various
         storm sewers throughout the site.  To date, land subsidence
         in the grammar school playground, located over the actual
         canal and landfill, occurs regularly.  The subsidence holes
         are periodically filled with soil.  School personnel have
         reported to the County Health Department that children have
         received burns while handling waste phosphorus (Fred C. Hart
         Associates, Inc., 1978).  Organic contaminants have surfaced
         over the fill of the canal and in residential backyards.
         All through the 1970's, residents have experienced unpleas-
         ant odors in their cellars, particularly after rains during
         the summer.  Basement sump pumps have also been affected by
         oily liquids.
                                 7-147

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In 1976,  after six years of abnormally heavy rains, the canal
overflowed its underground banks and at least 82 different
compounds, 11 of them suspected carcinogens, began percolat-
ing upward through the soil into backyards and basements of
the homes and school along the canal site.  Air monitors
placed by the EPA in the basement of surrounding homes have
detected significant levels of benzene and 24 halogenated
organic compounds, with concentrations of total halogenated
organics ranging from 8 to almost 1800 micrograms per cubic
meter in seven locations (Fred C. Hart Associates, Inc.,
1978).

The more common contaminants have been identified and mea-
sured in the analytical work done by several private con-
tractors.  Several of the chemical compounds detected are
listed on the U.S. Environmental Protection Agency's list of
priority Toxic Substances, as established by the Natural Re-
sources Defense Council Consent Decree in 1976, and iden-
tified as potentially carcinogenic,  teratogenic, and/or
mutagenic.  Among the substances identified in samples of
ponded water by the Division of Laboratories and Research,
New York State Department of Health were trichlorophenol,
lindane,  hexane, methyl cyclopentane, benzene, toluene,
chlorobenzene, benzychloride, dichlorobenzene, ortho-
dichlorotholuene, trichlorobenzene,  and tetrachlorobenzene
(Fred. C. Hart Associates, Inc., 1978).

Although the site has not been used as an industrial dump in
25 years, the recent adverse effects to human health have
been numerous.  Children and dogs have been burned while
playing in the fields, visitors have had the soles of their
shoes corroded through, backyard trees have been killed by
chemical action, gardens have been destroyed, fence posts
have been eaten away, and local residents have indicated that
many persons in the neighborhood have died of rectal, blood,
and breast cancer.  New York State Department of Health
studies of the residents of the area indicate a prevalence of
problems in the areas of fetal malfunctions, miscarriages,
and liver disfunctions (Fred C. Hart Associates, 1978).  In
the area to the south of the canal,  four out of 24 children
were born with malfunctions.  Malformations in the female
children included subcleft palate, deformed ears and teeth,
hearing defects, mental retardation, abnormalities of the
renal pelvis, and ureters with reflux.  In the male chil-
dren, congenital deafness occurred.
                         7-148

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        Data collected by the City of Niagara Falls identified 20
        homes where wastes were volatilizing and infiltrating into
        basements.  Further investigation has indicated that an ad-
        ditional 10 homes are also affected.  According to Calspan
        Corporation (1977b),  extensive abatement measures will be
        necessary to protect  the health of the residents of these
        homes.  The recommendations include the installation of
        sealed sump pumps, and the sealing of basement walls and
        floors with an epoxy  paint.

        The specific causes of the health and safety hazards that
        have occurred at Love Canal are numerous; however, the sub-
        surface migration of  hazardous pollutants continues to pose
        the major problem.  On June 21, 1978, an Emergency Health De-
        claration under the State Public Health Law, Section 1303,
        was issued for the Love Canal site.  Further investigation on
        this area is planned.

     One of the major stated  objectives of the Resource Conservation

and Recovery Act is to promote the protection of health and the envi-

ronment.  Implementation of the proposed regulations would result in

the institution of a program of responsible hazardous waste manage-

ment which would decrease the incidence of uncontrolled releases of

hazardous wastes to the environment.  This program is designed to

meet the above objective by limiting both direct and indirect public

exposure to hazardous wastes.  Direct exposure would be reduced by

requirements for treatment, storage, and disposal in permitted facil-

ities with minimum separation distances from buildings, roads, and

water supplies; by facility personnel training requirements; and by

facility security requirements.  Indirect exposure would be reduced

by limiting the movement of hazardous constituents of the wastes

through air, water, and soils, as discussed previously.
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     The following sections briefly describe the public health im-




pacts of some of the specific sections of the regulations.




     7.1.6.1  Public Health Impacts Relative to the Generation of




Hazardous Wastes.  Except for incidents due to occupational exposure,




few health incidents have been documented as having occurred during




the generation stage of hazardous waste management.  Most health




incidents are related to subsequent transport, storage, treatment, or




disposal.




     Generators of hazardous wastes would not be permitted to dispose




of such wastes on-site without also receiving a permit as a disposal




facility and complying with the Section 3004 regulations.  Further,




any on-site storage for 90 days or more would also require a storage




permit.  As discussed previously, these requirements would effective-




ly reduce environmental contamination with hazardous wastes due to




illicit disposal activities or improper storage procedures by genera-




tors.  However, as also discussed in previous sections, a small quan-




tity of potentially hazardous wastes would escape regulation due to




exemptions for households, retailers, and farmers, and due to the




generator limit of 100 kilograms per month.  Although it is expected




that regulations promulgated under other Acts would partially control




these wastes, the uncontrolled fractions could be disposed as non-




hazardous wastes using practices such as discharge to sewer systems




or any other conventional disposal method (though such disposal would




have to conform to regulations promulgated under Section 4004 of







                                 7-150

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RCRA).  However, the reduced degree of control could conceivably




result in the eventual contamination of some surface waters and in




subsequent potential human exposure.  However, the effects of these




exclusions would be much less harmful to public health than those




which occur now in the absence of any hazardous waste regulations.




Thus, although it is true that some unregulated releases of hazardous




wastes could continue to occur, and that some hazardous wastes may




cause significant damage in any amount, such occurrences would be




much less frequent, and generally less severe than those which occur




in the present, uncontrolled case.




     7.1.6.2  Public Health Impacts Relative to the Transport of Haz-




ardous Wastes.  The regulations regarding the transport of hazardous




wastes could be expected to favorably affect public health by reduc-




ing the potential for incompatible wastes to be combined for trans-




port, by requiring use and maintenance of adequate containerization,




by extending the DOT regulations to specifically include intra- and




inter-state transport of hazardous wastes, and by providing for spill




notification and abatement procedures.  These regulations would en-




hance the measure of protection'afforded to persons involved directly




with the transport of a waste and to the general public.




     Without the promulgation of regulations for the transport of




hazardous wastes, incidents similar to those described in Appendix J




could be expected to continue to occur.  One of the more serious cur-




rent problems associated wi'th the transport of hazardous wastes is






                                 7-151

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that,  in the absence of a manifest tracking system,  willful dumping




is very difficult to control.   Such dumped material  is frequently




placed in a location where environmental degradation can occur, with




resultant adverse public health effects.  Both Sections 7.1.4  and




7.1.5  discuss the types of environmental degradation that can occur




in the absence of hazardous waste regulation during  transport.  The




institution of a manifest system would allow enforcement agencies to




relatively easily locate the responsible parties for any dumping in-




cidents involving hazardous wastes subject to these  regulations.




These  regulations, in combination with hazardous spill regulations to




be promulgated under the newly amended Section 311 of the Clean Water




Act, would act as a deterrent  to anyone contemplating such activ-




ities.




       Any increase in the amount of hazardous wastes transported to




off-site facilities, or in the distance over which the wastes are




moved, would create a potential for increased health effects due to




hazardous spills from transport accidents.  Although the containeri-




zation and other requirements  would reduce spillage  en route due to




leakage or poor packaging, the regulations would not significantly




affect accidents due to collisions or derailments.




     7.1.6.3  Public Health Impacts Relative to the  Treatment, Stor-




age, and Disposal of Hazardous Wastes.  It is in this area that the




regulations would provide the most significant benefits to public




health.  The Section 3004 regulations would effectively insulate the







                                  7-152

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public from regulated wastes by requiring all storage, treatment, and




disposal to be restricted to permitted facilities that would be de-




signed and operated to prevent harmful discharges.  As in the case




with transporters, implementation of a manifest system and periodic




reporting requirements would facilitate tracking the wastes to ensure




that they are received at a permitted facility.  The regulations




would require periodic inspections by facility personnel and would




give the Regional Administrator authority to perform additional




inspections to ensure that the facility does not violate its permit




conditions.  Restrictions on siting, including a minimum separation




of 200 feet between the active portions of a facility and its prop-




erty line, and 500 feet between active portions of disposal facil-




ities and public, private, or livestock water supplies would further




contribute to the reduction of adverse public health effects.  Rules




for segregating wastes within a facility and prohibiting the mixing




of incompatible wastes, as well as rules requiring employee training




programs for hazardous waste facility personnel would reduce some of




the adverse health effects due to occupational exposure.




     Public health would be further enhanced by the increased public




awareness of the potential dangers of hazardous wastes.  The labeling




requirements for containers and transport vehicles used in connection




with hazardous waste and the public participation procedures which




would be required under the Subtitle C regulations, as well as other




related regulations,  would act to reinforce the mounting publicity







                                 7-153

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given to the potential dangers associated with the improper manage-

ment of hazardous waste.  Thus, though these regulations specific-

ally exclude households, most retailers, and most farmers from the

requirements, the regulations may indirectly provide some reduction

of the harmful effects associated with wastes from these generators

as well.  The following subsections discuss specific public health

benefits with respect to storage, treatment, and disposal of hazard-

ous wastes.

     Storage.  Although numerous reported incidents of environmental

contamination have resulted from improper storage of hazardous waste,

most reported incidents have not been directly identified as causing

adverse health effects.  However, there have been several reported

cases of health effects due to occupational exposure.  A typical

example of an occupationally-related incident from improper hand-

ling procedures at a storage facility is as follows:

     •  An employee was transferring two 5-gallon cans of waste vinyl
        cyanide and water from a still to a supposedly empty waste
        drum.  As the employee rolled the drum to a storage area
        across the road, it exploded.  The exothermic reaction cata-
        pulted the drum into a steel guard post, spraying the con-
        tents, causing thermal and possible chemical burns to the em-
        ployee (DeVera et al., 1977).

     •  In another incident 18 persons were exposed to deadly fumes
        from a stored canister of rat fumigant.  The stored canister
        was  leaking a mixture of methyl bromide and chloropicrin.  At
        least 21 persons were affected by the incident including
        seven firemen who were hospitalized.  Two of the firemen have
        since retired with permanent disabilities.  Among the effects
        suffered from the gas incident are permanent lung damage to
        two  individuals, and possible brain damage to another (Office
        of Solid Waste, Hazardous Waste Management Division,  1978b).
                                 7-154

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     As can be seen from the incidents presented, the lack of regula-




tion over the storage of hazardous wastes has resulted in impairment




to the health of many persons.  Stored wastes have often been forgot-




ten or abandoned.  The regulations for storage should significantly




reduce the possibility for stored wastes to be abandoned or left for




extended periods of time.  In compliance with the regulations, any




generator who stores hazardous wastes for a period exceeding 90 days,




and all off-site storage facilities would have to obtain a permit and




would be subject to recordkeeping and reporting requirements.  As




discussed in Section 7.1.5, no discharges would be permitted from




storage facilities.  Without these regulations, various occurrences




resulting in fires, explosions, the emission of toxic fumes or dusts,




and ground and surface water degradation due to reactions, corrosion,




or leaks have resulted.  Each such unexpected occurrence would have




the potential to impact public health.  See Section 7.1.4 for the




sources of emissions that may occur as a result of storage activi-




ties, and Section 7.1.5 for the related sources of water contamina-




tion that may affect public health.




     Treatment/Disposal.  The most common method of treatment for




hazardous wastes involves the use of lagoons or stabilization ponds.




This method of treatment relies on the process of settling and evap-




oration.  Prior to the implementation of regulations, wastes have




been "treated" in unlined ponds or lagoons, or in otherwise unaccept-




able containment areas.  Such "treatment" areas have frequently been







                                 7-155

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subject to seepage and subsequent groundwater contamination; overflow

or rupture, and subsequent surface water contamination;  and/or air

emissions of potentially harmful volatile substances.  The potential

for, and interactions between these occurrences are discussed in

previous sections.  Many such occurrences have considerable potential

for public health problems.

     An example of the type of health effects which have occurred as

a result of both direct and indirect exposure to hazardous wastes

during unregulated "treatment" is as follows:

     •  A chemical company dumped chemical solvent wastes at a quarry
        in Maryland between 1960 and 1974, often leaving the chemi-
        cals open to evaporate before covering them up.   Residents in
        the quarry area as well as company employees had complained
        of headaches, nausea and vomiting, chronic fatigue, weight
        loss, and memory loss—classic symptoms of chemical fume ex-
        posure. One doctor found that seven out of eight area resi-
        dents he had examined had abnormalities of the liver and/ or
        pancreatic functions.  Another doctor foumd carbon tetra-
        chloride, which is highly toxic to the liver and kidneys, in
        the blood of three area residents.  Cancer deaths from
        lymphoma malignancies were found in the quarry area and among
        employees to be 44 times higher than the national incidence.
        The death rate was 2.2 times greater than that of the rest of
        the county.  The death rate due to cancer was seven times
        greater than that for the county, the victims usually living
        within direct proximity to the chemical plant. Among the
        solvents dumped at the site were benzene, which is known to
        damage blood-forming organs and to cause leukemia; carbon
        tetrachloride, acetone, ketones, and methylene chloride.
        Many of these substances, when measured, were found to be
        present in abnormal amounts in the air at the site.  The
        company was ordered to cease dumping at the quarry in 1974,
        and by 1975 had removed most of the wastes (Office of Solid
        Waste, Hazardous Waste Management Division, 1978b).

     The Subtitle C regulations would control such activities under

the requirements for surface impoundments and ponds.  As discussed in
                                 7-156

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the sections dealing with air and water impacts, the regulations




would significantly decrease the release of hazardous contaminants to




the environment from such facilities.  Such decreases would result in




corresponding decreases in the adverse impacts of hazardous wastes on




public health.




     Other forms of treatment addressed by the regulations include




incineration; landfarms (if wastes are removed at closure); and chem-




ical, physical, and biological treatment facilities.  Except for




landfarms, each of these treatment methods is to be regulated in much




the same way.  Each must comply with any other applicable regula-




tions, such as those for storage facilities and basins, and those




affecting facility si-ting, security, and personnel training; each




must manifest its wastes if they meet the Section 3001 regulations;




and each must remove all wastes during facility closure.




     The effects of these regulations on air, water, and soil contam-




ination are discussed elsewhere.  Any decrease in the contamination




of these media would result in corresponding decrease in adverse im-




pacts on public health.  Additionally, the regulations would directly




affect the health of facility personnel, through improvements in em-




ployee training, standards for facility design, requirements for doc-




umentation and verification of waste composition, and through the




requirements for the creation of emergency contingency plans to deal




quickly and knowledgeably with any accidents.
                                 7-157

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     Two graphic examples of occupationally-related incidents that

occurred during the treatment of hazardous wastes resulted in fatali-

ties which might have been avoided if the personnel were adequately

trained:

     •  Two youths were cleaning scale from a cyanide plating waste
        tank at a treatment plant.  When they were checked during the
        afternoon, they were using their safety equipment, the cya-
        nide level in the tank had been checked, there was positive
        purge in the air lines, and work was progressing normally.
        Later, both were found dead, the compressor for the purge had
        been turned off, and the gas masks had been removed.   Appar-
        ently a cyanide pocket had been encountered (Office of Solid
        Waste, Hazardous Waste Management Division, 1978b).

     •  Two men died as a result of fatal burns received at a metal
        processing plant.  One employee was working off an elevated
        work platform while the other man was operating a forklift.
        The resulting injuries were caused by contact with the ex-
        treme temperatures of a hydrogen explosion and zirconium
        fire.  The explosion and fire were caused when zirconium
        shavings, contaminated with oil and dirt, were dumped from an
        unlined 55-gallon steel drum into an unlined steel hopper to
        be scrubbed in water and detergent.  Ignition of the shavings
        through friction resulted in a violent explosion and fire
        that engulfed the two workmen (State of Oregon, Accident Pre-
        vention Division, 1975).

     Landfarming may be considered as a treatment (if the wastes are

removed during closure), or as ultimate disposal (the proposed regu-

lations would not require removal of the wastes if the landfarm can

be closed so that food chain crops could be grown on the treated area

without violating specified human consumption standards).  In evalu-

ating the use of land application for hazardous wastes, consideration

must be given to the potential for offensive odor nuisances and pub-

lic health hazards that are peculiar to the use of spray irrigation

systems.  Groundwater quality is a primary consideration; however,

                                 7-158

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the effect of aerosols, physical contact with the waste by the public




or facility employees, insects and rodents, isolation from the pub-




lic, stormwater runoff and erosion from the site, and contamination




of crops and potential for bioaccumulation, are all important effects




that are possible in any disposal method.




     Odors generally result from the spraying of industrial waste-




water that has been inadequately treated or has not been treated at




all prior to land application or lagooning.  The condition may be




compounded by excessive ponding at the irrigation site.  Sludge ap-




plication to the land potentially poses a relatively more serious




odor problem if not handled properly.  At this time almost all states




either prohibit or strictly regulate the use of this method of land




disposal in areas where crops are grown for human consumption (Was-




botten, 1976).  Information on the causes of groundwater contamina-




tion, the resulting discharges to the environment, and on the impacts




of the regulations on such discharges can be found in Section 7.1.5.




To the extent that the regulations for landfarms would reduce the po-




tential for water contamination, they would also reduce the potential




for adverse public health effects.




     The types of ultimate disposal facilities addressed in the pro-




posed regulations are landfills, some surface impoundments, and some




landfarms.  The public health effects of the regulations concerning




surface impoundments and landfarms are discussed above.  Additional




requirements affecting public health include minimum separations from







                                 7-159

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water supplies, maintenance of permanent records of waste types and




locations, restrictions on the types of wastes which may be land-




filled, application of daily cover on active cells, and requirements




for postclosure maintenance.




     These regulations should effectively prevent the creation of




future health disasters such as that which occurred at Love Canal.




Additionally, the regulations should also contribute to an overall




decrease in exposure to low concentrations of hazardous substances




resulting from environmental dispersion of hazardous wastes.




     Several sources of potentially adverse health effects would re-




main unaffected by these regulations.  As previously discussed, some




potentially hazardous wastes would not be regulated under the Sub-




title C regulations.  Further, EPA does not have the authority to




promulgate regulations concerning inactive and abandoned hazardous




waste disposal sites.  From the incidents discussed in this chapter




and those presented in Appendix J, it is apparent that there may be




many hundreds of such sites scattered around the country, whose loca-




tions may not even be recorded.  The potential for health disasters




caused by these sites is considerable.




     However, in spite of these omissions, it is evident that the




regulations would result in substantial benefits to public health




through the reduction of both chronic and acute exposure to contamin-




ation resulting from improper handling and disposal of hazardous




wastes.  The regulations have the potential to control and require






                                 7-160

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the safe disposal of nearly 40 million metric tons of hazardous




wastes per year by 1984.  In the absence of the regulations, these




wastes would have a significant potential to cause environmental deg-




radation and subsequent severe human health effects.




7.2  Potential Secondary Impacts




     The potential secondary impacts from implementation of the pro-




posed regulations include impacts to the following areas:




     •  Physiography and soils;




     •  Biological environment;




     •  Social impacts;




     •  Hazardous waste management facility capacity;




     •  Land use;




     •  Water use;




     •  Resource conservation and recovery;




     •  Energy use;




     •  Special interest points.




     7.2.1  Impacts to Physiography and Soils.  The principal areas




of environmental concern pertaining to physiography and soils




include:




     •  Alterations of topography;




     •  Loss and physical disruption of soils;




     •  Soil contamination.




     Physiography and soils are impacted by hazardous wastes in many




ways.  In the existing unregulated situation, the major adverse







                                 7-161

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effects resulting from the management of hazardous waste relate to




soil contamination through indiscriminate disposal.  If the proposed




regulations are implemented, adverse effects to soils and physiogra-




phy would still occur, though their nature and severity would change.




For instance, soil contamination would still occur, but in more con-




trolled situations where the physical area affected is limited and




contaminants are retained at one location.  Erosion of disposal sites




would be reduced, though physical disruption of the soils may in-




crease during construction of facilities.




     Because the proposed regulations would be expected to drive a




portion of the hazardous waste that is now disposed in environmental-




ly questionable on-site facilities to permitted off-site facilities,




it can be anticipated that there would be considerable effort made to




upgrade and expand existing off-site process capacity and physical




capacity and also to develop new off-site treatment and disposal




facilities.  The effects of such activities would be site specific in




nature and would have to be addressed on a case-by-case basis.  How-




ever, the types of potential impacts that could result can be dis-




cussed generically, in terms of facility construction, facility oper-




ation, and facility closure.




     7.2.1.1  Facility Construction.  The construction of new or




expanded hazardous waste management facilities would involve several




types of effects on physiography and soils:
                                 7-162

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     •  Alteration of site topography;

     •  Alteration of off-site topography due to excavation of
        materials  for liners and soil barriers;

     •  Loss of soil through erosion;

     •  Alteration of soil physical properties by disturbance and
        compaction;

     •  Degradation of soil quality by pollutants generated by
        construction vehicles, equipment, and materials.

     Most of these impacts are inevitable consequences of construc-

tion operations in general and are thus not unique to hazardous waste

facilities.   Any such impacts would be extremely site-dependent.

     The Subtitle C regulations would require the use of  natural or

artificial liners of specific thicknesses and structural  characteris-

tics for landfarms and surface impoundments.  Storage facilities and

basins would be required to use impermeable, continuous bases.  All

facilities would have to have diversion structures capable of divert-

ing the runoff from a 24-hour, 25-year storm,  and would  also have

to construct some means of containing any runoff from the site.  Land-

farms would have to be graded such that their slope would be between

zero and 5 percent, and such that no ponding of water occurs.  All of

these regulations would involve alteration of off-site and/or on-site

topography, and alterations of physical properties of the soil.

     In most cases, the adverse environmental impacts of  such actions

would be negligible.  The most significant impacts would occur during
 A storm of 24-hour duration whose frequency of occurrence is once
 in 25 years.

                                 7-163

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the construction of large landfills or surface impoundments which

cannot use the natural in-place soils as liners.  A two acre landfill

not using a synthetic liner would require about 8,000 cubic yards of

silty clay soils for its liner, plus about 1,000 cubic yards of perme-

able materials for the leachate-drain layer.  Additional soils would

be required for daily operation and closure.  Surface impoundments

would require a larger amount of clayey soil for construction of

dikes around the impoundments.

     7.2.1.2  Facility Operation.  Principal impacts on physiography

and soils that may result from the operation of hazardous waste

facilities include:

     •  Erosion, sedimentation, and other geomorphic processes;

     •  Soil contamination by hazardous materials during the course
        of normal operations or as a result of accidental
        discharges;

     •  Alteration of the physical properties of soils by equipment
        usage and other operational maintenance activities;

     •  Induced geological instability (e.g., micro-earthquakes).

     Soil contamination would be an especially important concern,

especially because soils are widely used as an ultimate sink for the

disposal of hazardous wastes (Davidson, et al., 1976).  Numerous

instances of soil contamination by accidental discharges of hazardous

wastes have been documented.  Many of the incidents of hazardous

waste impacts that are cited in the sections of this chapter dealing

with impacts to air, water and the biological environment pertain to

soil and soil contamination and are not repeated here.  Suffice it to

                                 7-164

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note that the soil contamination is a frequent result of current haz-

ardous waste management practices.   For example, during a recent 2.5

year period, more than 200 hydrocarbon spills were reported in

Pennsylvania; many of these spills  resulted in soil contamination

(Osgood, 1974).   For hydrocarbon spills that occur as a result of

transportation accidents, it is common practice to wash the spilled

materials directly into soil as rapidly as possible.

     The Subtitle C regulations that would specifically address

physiographic and soil aspects of facility operation include the

following:

     •  Groundwater and leachate monitoring systems are to be in-
        stalled at all hazardous waste treatment, storage, and dispo-
        sal facilities (except landfarms) that have a potential for
        groundwater pollution;

     •  Soils of the treated area of landfarms are to be monitored
        for vertical migration of the waste or its consituents;

     •  Landfills and landfarms are to be located, designed, con-
        structed, and operated to prevent erosion, landslides, and
        slumping;

     •  Landfarms are to be sloped  at less than 5 percent to prevent
        erosion, but greater than zero percent to prevent wastes or
        water from ponding or standing;

     •  All earthern dikes used for surface impoundments are to have
        an outside protective cover to minimize erosion by wind or
        water.

     •  Contingency plans are required at treatment, storage, and
        disposal facilities to minimize adverse impacts of subsurface
        discharges of hazardous materials;

     •  Soils contaminated by accidental discharges from hazardous
        waste facilities are to be  considered to be a hazardous waste
        and are to be managed accordingly.
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     The  regulations  are  expected  to  have the following impacts:

     • A substantial reduction in the  contamination of soils in
       areas  surrounding treatment,  storage, and  disposal facilities
       owing  to specific provisions  pertaining to soils as well as
       measures designed to  prevent  contamination of air and water
       quality, including accident contingency plans;

     • A substantial reduction in soil contamination resulting from
       disposal of hazardous wastes  at unauthorized and unsuitable
       sites;

     • A reduction  in erosion, sedimentation,  and landslides at
       landfarms, landfills, lagoons,  and ponds;

     • Substantial  upgrading of the  disposal of soils  subject to
       accidental exposure of hazardous wastes discharges from
       treatment, storage, and disposal facilities.

     7.2.1.3  Facility Closure.  The  impacts on physiography and

soils that would occur as a result of facility closure  are similar to

those which would occur during construction.  Basins, some surface

impoundments,  most landfarms, storage,  and treatment facilities would

all have  to be emptied of hazardous wastes, including any soils con-

taminated during operation.  The only impacts that these facilities

would have would be  due to the requirement for filling the empty

impoundments,  and any changes in topography that occurred.  The re-

moval of  wastes from these facilities could increase any impacts

occurring at the ultimate disposal sites for the wastes (including

facility  shortfall,  as discussed elsewhere in this statement).

     Landfills, some surface impoundments, and a few landfarms would

be the ultimate disposal sites of any hazardous wastes not treated or

incinerated.  The minimum cover depth for a landfill would be 0.6

meters (2 feet).  If deep-rooted vegetation is to be planted on site,

                                  7-166

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the minimum cover thickness would be just over 1 meter (3.5 feet).




Surface impoundments would have to be treated to render their solids




content greater than 20 percent, and then closed in accordance with




the requirements for landfills.  It is probable that a very large




volume of soil would be needed to adequately cover and contain such a




semi-solid mixture of hazardous wastes.  Landfarms would have to be




closed such that food chain crops could be grown on the treated area




without resulting in human consumption of substances listed in the




EPA Primary Drinking Water Standards, or food additives banned by the




U.S. Food and Drug Administration.  Since the landfarm design and




operation regulations would prevent waste migration from the site




(i.e., all wastes would remain at the site), meeting the closure re-




quirements without removing the wastes could be difficult.  Closing




such a facility would probably (at a minimum) require burial with




sufficient soil to prevent the roots of the crops from ever reaching




the wastes.  Additionally, a protective impermeable layer may be nec-




essary to prevent leaching of wastes by percolating irrigation




waters.




     7.2.1.4  Transportation of Hazardous Wastes.  Provision for the




extension of existing interstate safeguards to the intrastate trans-




portation of hazardous wastes could reduce the relative frequency of




accidental spills and associated incidents of soil contamination.




Manifest requirements should eliminate most incidents of dumping and
                                 7-167

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improper disposal and their resultant impacts to soils.  Contamina-




tion incidents due to improper cleaning of vehicles also would be




prevented and improved spill contingency measures could reduce soil




exposure to hazardous wastes.   Conversely, increases in the distan-




ces over which hazardous wastes were to be transported could result




in an increased number of spills and in subsequent incidents of soil




contamination.




     7.2.2  Biological Impacts.  This section addresses potential




impacts of the proposed regulations in terms of:  1) the welfare and




status of non-human biota, ecological systems, and habitats; 2) the




human amenities that are derived from these resources.  The scope of




the section includes agricultural as well as natural systems.




     Of particular importance from the perspective of biological




effects is the nature of hazards posed by waste materials to living




systems.  Two relevant aspects are the hazardous nature of the mate-




rial in question, and the degree to which environmental systems may




be exposed to the hazard.  The latter factor is dependent on the par-




ticular conditions under which hazardous materials are handled and




disposed.  As shown in Table 7-13, the intrinsic harmful properties




of hazardous wastes to living systems include:  flammability, reac-




tivity, toxicity, bioconcentration, and genetic change.




     An equally important consideration is the response of biological




and ecological systems to the stresses imposed by hazardous wastes




and their management.  The specific responses would depend on the
                                 7-168

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                                                                              TABLE 7-13

                                                     PROPERTIES OF WASTES THAT ARE HAZARDOUS  TO LIVING SYSTEMS*
               Hazardous  roperty        Types of wastes involved
                                                                                                Hazards to living systems
               Flammability
Contaminated solvents
Oils
Pesticides
Plasticizers
Complex organic sludges
Off-specification chemicals
                                                                         An acute and latent danger to  organisms  and  habitats.  Kill  radii  of  115  ft.
                                                                         and 230 ft.  may be associated  with  ignition  of  9,000  gal.  and  30,000  gal.
                                                                         tank cars of  flammable liquid.   Because of  large volumes  of wastes,  danger
                                                                         at disposal  sites may be greater than in transportation.   Secondary fires
                                                                         and detonations may occur.   Flammability Is  a hazard  during  all phases  of
                                                                         the hazardous waste cycle.
               Reactivity
                                      Explosive manufacturing
                                       wastes
                                      Contaminated industrial
                                       gases
                                      Old ordinance
                                   An acute and latent danger to organisms and habitats. Detonation may be
                                   caused by thermal or mechanical shock, electrostatic charge or contact of
                                   incompatible materials.  Kill radius is typically less than for comparable
                                   volumes of flammable liquids.  Detonation may result in secondary explosions
                                   or fire.  Reactivity may occur at all phases of the hazardous waste cycle and
                                   may pose a greater danger after disposal if sufficient amounts of reactive
                                   material are accumulated.
M
               Toxiclty
Toxic wastes may be derived
 from any industry. (Toxi-
 city may result from pure
 compounds, combined effects
 of more than one component
 or combined action of two
 individually non-toxic
 materials).
The capability to produce Injury upon contact with a suitable site on or in
the body.  Wastes may be acutely or chronically hazardous to plants or
animals.  Phytoxic wastes may reduce chlorophyl production, retard growth or
interfere with specific chemical processes when present in soil, atmosphere
or water.  In mammals, acutely toxic wastes may cause damage via inhalation,
ingestion, or skin contact.  Chronic toxicity may occur for materials that
are bioaccumulated or that cause cumulative irreversible damage.  In aquatic
organisms, toxicity often results from the transfer of toxic materials across
the gill membranes.  Water is probably the most common vector, but atmospheric
emissions may be more readily dispersed.  Direct contact is the most easily
controlled route of exposure.  Exposure of organisms to toxic substances may
occur in all phases of the hazardous waste cycle.
               Bioconcentration
Various elements and compounds
including:  cadmium, lead,
mercury, polychlorinated
biphenyls, carbon tetra-
chloride
                                                                         The  hazard  posed  by materials  that  are  concentrated  In an  Individual  organism
                                                                         or magnified  at successive  levels of  the  food  chain  until  toxic  concentrations
                                                                         are  reached.   Threshold  levels  of toxicity  often  occur in  vertebrates,  Includ-
                                                                         ing  man,  and  may  result  in  death.   Bioconcentration  generally  occurs  when  a
                                                                         contaminant is present in low  ambient levels and  is  probably of  greatest danger
                                                                         following the disposal of waste materials.
              Genetic Change
               Potential
Dye plant wastes
Petroleum sludges
Carcinogenic, mutagenic or teratogenlc effects on organisms, as evidenced by
mitotic or meiotic malfunction.  Exposure is usually by direct and continuous
route.
                       *Battelle  Pacific  Northwest  Laboratories,  1973  .

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amounts and types of hazardous materials involved, the modes by which




living systems were to be exposed, and other sources of environmental




stress, as well as the organisms involved.   Because of the wide range




of materials and methods involved in hazardous waste management, and




of tolerances of different types of organisms, effects on living sys-




tems vary substantially and would be situation dependent.  However,




as shown in Table 7-14, it is possible to generalize about the ways




in which living systems, from individual organisms to biological com-




munities, would respond to various levels of environmental stress.  A




moderate degree of stress, such as low level emissions of aerial pol-




lutants from a treatment/disposal site, could affect the behavior of




individual organisms, reduce the competitive ability of various popu-




lation segments and species, and ultimately lead to a shift in spe-




cies composition of the community.  At the other end of the spectrum,




extreme stress, as represented by the massive discharge of toxic




wastes into a stream, could result in the death of individual organ-




isms and the total collapse of the existing aquatic community.




     On the basis of available literature, present knowledge regard-




ing the effects of current non-radioactive hazardous waste management




practices on biological systems are based largely on scattered re-




ports of individual incidents rather than comprehensive surveys or




investigations.  Moreover, available reports deal largely with acute




effects from direct exposure of organisms to high concentrations of




hazardous substances and rarely consider chronic effects resulting







                                 7-170

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                                                           TABLE ?-14

                                    GENERALIZED PATTERNS OF  THE RESPONSE OF  BIOLOGICAL
                                   SYSTEMS  TO INCREASED LEVELS OF ENVIRONMENTAL STRESS*
         Degree

        of Stress
                        Individual organism
                            Response  at  indicated  level of organisation

                                  Population                   Species
                                                              Community
        Moderate
-Some metabolic and behav-
 ioral Interference.

-Reduced competitive  abl-
 llty.

-Reduced resistance to
 parasites and predators.

-Reduced capacity for re-
 production .
-Reduced competitive  ab-
 ility  of most  sensitive
 individuals.

-Some genetic  selection
 for more tolerant  Indi-
 viduals .
-Host sensitive  popula-
 tions undergoing  selec-
 tion for hardiest indi-
 viduals, hence  losing
 genetic diversity.

-Most tolerant popula-
 tions little affected.
-Noticeable shifts in re-
 lative species abundance
 as the most sensitive
 species suffer reduction
 In numbers while more
 tolerant competitor spe-
 cies remain the same or
 increase in abundance.
        Heavy
I
M
^J
-Individual under heavy
 stress load.

-Survival not  in jeopardy,
 but individual^ weakened
 and susceptible to  para-
 sites, disease, and pred-
 atlon.

-Reproduction  greatly
 curtailed.
-Elimination of  most
 sensitive Individuals.

-Increase  In more tol-
 erant  individuals.

-Population level may
 or may not be  affected.

-Reduction in genetic
 diversity.
-Most sensitive  popula-
 tions eliminated.

-Most tolerant popula-
 tions losing  sensitive
 individuals,  hence  los-
 ing genetic diversity.
-Significant shifts in
 species composition as
 sensitive species are el-
 iminated and hardy com-
 petitors remain and often
 increase.

-New hardy species ma;  -;-.-
 ter from.elsewhere.
        Severe
-Severe metabolic and  be-
 havioral interference.

-Individual survival  in
 ques tion.

•Reproduction no  longer
 possible.
-Survival  of  only  the
 most toleranf  individ-
 uals .

-Population  level  may
 or may  not  be  reduced.

-Severe  reduction  In
 genetic diversity.
                                                                            •-Only the hardiest indi-
                                                                             viduals of the most tol-
                                                                             erant populations still
                                                                             survive.
                           -Great  shifts  in  species
                            composition.

                           -Most  species  reduced  or
                            eliminated.

                           -Hardy  species  may  become
                            very  abundant.

                           -Total  system  greatly  sim-
                            plified.

                           -Community metabolism
                            greatly modified.

                           -Stability severely reduced.
        Total
                              Death
                                                      Elimlnat ion
                                                                                    Extinction
                                                                                                               Collapse
               *Darnell,  1976.

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from long-term exposure to low concentrations (Office of Solid Waste

Management, 1974a).   The focus of most reports has been directed to

individual organisms or populations rather than to communities or

ecosystems.

     Determination of hazardous waste effects is complicated by vari-

ous phenomena, including:

     •  Synergistic or antagonistic interactions between waste
        constituents that could enhance or modify overall effects;

     •  The importance of the physical and chemical form of the waste
        on the mobility of toxic substances;

     •  The physical and chemical conditions  of the receiving waters
        (such as pH, existing oxygen demand and availability, and the
        presence of ions or materials which could immobilize toxic
        substances by precipitation or adsorption or could combine
        with them to increase their toxicity);

     •  Upredictable nature of interactions between biological
        systems (e.g. , bacteria) and hazardous wastes such that the
        end point is more dangerous than the  original waste;

     •  Accumulation by mammals of persistent toxic substances such
        that low ambient concentrations may be magnified in tissues
        (Office of Solid Waste Management Programs, 1974a).  It has
        also been established that most pollutants are capable of
        crossing the placenta of mammals; cross effects on features
        have been demonstrated for high mercury and PCB exposure
        (Susten and Raskin, 1976).

     Despite limitations, the available information is sufficient to

establish that current hazardous waste management practices may pose

a substantial threat to biological systems.  Appendix J and the pre-

vious sections of this analysis describe many incidents in which

improper management of hazardous wastes has resulted in damage to

ecological systems.  Analysis of these incidents indicates that the
                                  7-172

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major routes of hazardous waste transport to biological systems are




as follows (Lazar, 1975):  groundwater contamination via leaching,




surface water contamination via runoff or spills, air pollution,




poisoning via direct contact, poisoning via the food chain, and fire




or explosion.




     The potential effects of the proposed regulations on biological




species and processes can be perceived in terms of principal stages




of the hazardous waste cycle, discussed below:




     7.2.2.1  Generation.  Improper handling or containerization of




hazardous wastes by generators could expose biological populations




and habitats to hazardous residuals.  Such exposure may result in




death and injury to organisms, the dispersal of hazardous materials,




and the degradation of aquatic, terrestrial and atmospheric environ-




ments.




     The proposed regulations would require all generators of hazard-




ous wastes to treat, store or dispose of that waste in a permitted




facility in accordance with all Subtitle C regulations.   A manifest




and reporting system would be instituted to track the wastes and




ensure compliance.  All generators designating wastes for transport




to an off-site facility must containerize that waste in accordance




with DOT hazardous materials transportation regulations in 49 CFR.




The generators managing wastes in on-site facilities must obtain a




permit under the Section 3005 regulations and must comply with the




standards under Section 3004.
                                 7-173

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     These regulations would result in a decrease in the release of

hazardous wastes to the environment from all generators covered by

the regulations.  This decrease would result in reduced air and water

quality degradation as discussed earlier, and subsequently in reduced

exposure of biological systems.  To the extent that some potentially

hazardous wastes would remain uncontrolled (see previous sections)

some adverse ecological impacts could continue to occur as they are

at present.

     7.2.2.2  Transportation.  Principal biological considerations

associated with hazardous waste transportation include:

     •  Emissions from improperly containerized wastes that may
        degrade habitat values;

     •  Leakages and spillages of transported wastes that kill or
        injure organisms, degrade habitats, and create odors and
        other nuisances to organisms;

     •  Accidental large-scale discharges of hazardous wastes
        resulting in fires and detonation;

     •  Vehicular emissions;

     •  Vehicular collisions with wild and domestic animals.

     The regulations would require all transporters of hazardous

wastes to comply with the manifest system and to ship all hazardous

wastes to a permitted facility.  They would require specific labeling

and containerization procedures, and prohibit the transport of leak-

ing or damaged containers.  Further, the regulations would extend

certain DOT hazardous material regulations to intrastate trans-

portation and would reinforce hazardous spill notification
                                 7-174

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procedures established by DOT and EPA through the National Response

Center.

     As discussed previously, these regulations would have the poten-

tial for reducing air, water, and soil contamination from uncon-

trolled transportation of hazardous wastes.  Additionally, the poten-

tial for hazardous spills caused by improper containerization during

transport would decrease.  To the extent that these regulations would

reduce air, water, and soil contamination, there would be a corres-

ponding reduction in ecological degradation and other associated

adverse biological impacts.

     7.2.2.3  Storage.  The principal hazards to biological systems

associated with hazardous wastes storage may result from:

     •  Aerial emissions and effluent seepages from improperly stored
        wastes;

     •  Accidental spills, fires, and explosions of stored
        hazardous wastes during handling.

     The impacts resulting from such events would depend on the

nature and amounts of materials involved and on site specific charac-

teristics.  The regulations would allow no discharge from any storage

facility.  They would require pe'riodic monitoring and inspection to

detect any potential discharges to air or water.  They would require

construction of an impervious, continuous base for the storage facil-

ity and of sturdy, leak-proof tanks and containers.  The regulations

would also require diversion of upland runoff and containment of run-

off and spills in the facility.  With respect to water quality, these
                                 7-175

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regulations would reduce the potential for water pollution from regu-

lated hazardous waste storage facilities.   Any reductions in water

pollution would result in a corresponding decreased potential for

adverse ecological and biological impacts.

     7.2.2.4  Treatment.  As with other phases of the hazardous waste

cycle, the potential effects of hazardous waste treatment facilities

on living systems would be site-specific and would depend on the

types and amounts of materials handled, the processes employed, and

the ecological setting of the facility.

     Any increased treatment of hazardous waste that could result

from the regulations should reduce the dangers associated with haz-

ardous waste disposal, but could increase those associated with the

treatment.  Adverse effects that are principally associated with haz-

ardous waste treatment are:

     •  The substantial land requirements for lagooning and resultant
        pre-emption of habitat and displacement of biological popula-
        tions;

     •  Leachate and overflow problems for lagoons and ponds that are
        improperly sited, constructed or managed and resultant
        impacts on aquatic systems;

     •  Air emissions from incinerators that may degrade habitats.

     All hazardous waste treatment facilities would be subject to any

applicable section of the standards for hazardous waste storage,

treatment, and disposal facilities.  For example, a resource recovery

facility may be subject to the regulations for storage, treatment,

surface impoundments, basins, incinerators, and/or for commercial


                                  7-176

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products from hazardous wastes.  These regulations would greatly

reduce or eliminate hazardous discharges from facilities subject to

regulation, and would therefore significantly reduce or eliminate

adverse biological or other ecological effects due to improperly

conducted treatment or resource recovery operations.

     7.2.2.5  Disposal.  The ultimate disposal of hazardous wastes

poses unique and substantial environmental problems.  Major site-

specific problems associated with the handling and disposal of haz-

ardous wastes include:

     •  Leachate contamination of surface and groundwaters resulting
        in hazards to biota and ecological systems;

     •  Air pollution hazards to vegetation and fauna due to
        fugitive emissions;

     •  Exposure of environmental systems to hazardous materials due
        to indiscriminate or illegal dumping of wastes because of
        insufficient or expensive disposal facilities (Washington
        State Department of Ecology, 1977).

     Improper land disposal of hazardous wastes could result in a

wide range of effects depending on the types and amounts of wastes

involved, site characteristics and facility safeguards.  The princi-

pal single site-specific concern would likely be the contamination of

surface and groundwater systems, and resultant impacts on organisms

and communities, due to leaching of toxic effluents.  In terms of

future changes, an increase in the number of facilities or in the

volume of wastes handled would be expected to increase the potential

for localized environmental problems while improvements in facility

safeguards and more stringent disposal standards would significantly

                                 7-177

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reduce the potential for adverse effects.   It is recognized that haz-




ardous wastes by their nature pose a potential threat to the environ-




ment, during either short periods prior to their destruction or over




very long periods for those materials not  subject to detoxification.




     A universal impact of hazardous waste disposal facilities, re-




gardless of types of wastes or site environment, is their preemption




of land from other uses including habitat  for natural and agricul-




tural biota.  An EPA study has determined  that land disposal of haz-




ardous wastes is increasing because of the implementation of air and




water quality standards and legal limitations on other disposal meth-




ods such as ocean dumping (Office of Solid Waste Management Programs,




1974a).  Legislation of particular importance in this regard includes




the Clean Air Act of 1973 as amended, the  Federal Water Pollution




Control Act Amendments of 1972, and the Marine Protection, Research,




and Sanctuaries of 1972, as amended.  Thus, it is likely that terres-




trial biological systems may be subject to increasing potential




stress.




     The regulations would eliminate discharges from hazardous waste




storage, treatment, and disposal facilities to groundwater unless it




can be demonstrated that the discharge would not endanger an under-




ground drinking water source (UEWS).  The  regulations would require




that all waterborne effluents including runoff and leachates must be




confined to point sources, and that all point source discharges to




navigable waters must comply with the regulations of the Clean Water






                                 7-178

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Act.  Since almost any aquifer which could be used as a water source

for wildlife would be classifed as a UDWS, and since navigable waters

is quite broadly defined, these regulations would greatly reduce the

occurrence of waterborne contamination of biological and other eco-

logical systems by hazardous wastes.  One incident which is illustra-

tive of the type of impacts which could be avoided by these regula-

tions is as follows:

     •  Near the Rocky Mountain Arsenal in Colorado, complex hazard-
        ous wastes (consisting of by-products of pesticides, herbi-
        cides, and chemical warfare agents) stored in unlined holding
        ponds infiltrated a shallow water table aquifer and migrated
        through groundwater.  As a result, crops on 6.5 square miles
        of farmland were damaged and water fowl were killed.  Results
        of the groundwater contamination were still evident 24 years
        following the initial report of damage and 15 years after
        remedial action was taken.

     Additional regulations would require specific design parameters

for landfills, surface impoundments, and basins that would minimize

leakage and emphasize structural integrity.  Monitoring, inspection,

reporting, and permit requirements would reinforce these regulations.

This group of regulations would decrease the potential for environ-

mental damage and adverse biological impacts from failure of inade-

quately designed and constructed containment structures.  Two

prominent examples of the type of incident which could be prevented

are as follows:

     •  In Pennsylvania the rupture of refining waste lagoons near
        the Allegheny River resulted in the death of approximately
        4.5 million fish in one incident, and the death of about
        450,000 fish along a 60-mile stretch in another incident (Of-
        fice of Solid Waste, Hazardous Waste Management Division,
        1978b).

                                  7-179

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     •  A waste pond dike ruptured at a phosphoric acid plant at Fort
        Meade,  Florida,  releasing 28 billion gallons of slime com-
        posed of halides and phosphatic clays.   The discharge contam-
        inated  the adjacent creek, the Peace River, and the estuary
        of Charlotte Harbor.  Extensive mortality of benthic biota
        occurred, and no live aquatic organisms were found in the
        Peace River up to 8 miles downstream of the adjacent creek
        (Office of Hazardous Waste Management Programs, 1974a).

     These latter wastes are specifically listed as hazardous under

the Section 3001 regulations, and are classifed as 'special wastes'

under the Section 3004 regulations.   Since the Section 3004 'special

waste' standards for phosphate were not developed as of the time of

this document,  their impact is uncertain.  However, definition of

these wastes as hazardous and implementation of specific disposal

standards would certainly reduce the potential for adverse biological

impacts due to  these wastes.

     Other parts of the  proposed Section 3004 regulations would

restrict open burning of hazardous wastes and require compliance with

the regulations developed under the Clean Air Act.  These provisions

would reduce the potential for adverse biological impacts caused by

air pollution.   Additional requirements and permit restrictions would

prevent the growth of food chain crops where they may contact hazard-

ous wastes, and would require fencing around active portions of

facilities.  Further, implementation of the manifest and facility

permitting system in general would result in a large decrease in un-

controlled open dumping  of hazardous wastes.  The combined effect of

these provisions would greatly reduce the potential biological
                                 7-180

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impacts caused by ingestion or other contact with hazardous wastes.

An example of the type of incident which could be avoided is as

follows:

     •  In September 1971, six or seven cows died from arsenic
        poisoning, resulting from improper disposal of a cotton de-
        foliant in a Texas City landfill.  Approximately 100 boxes,
        each containing four "empty" plastic containers holding a
        small amount of residual arsenic, had been placed at the
        landfill by a warehouseman of a chemical company.  The graz-
        ing cattle had entered the landfill from nearby pasture
        lands.

     In summary, the proposed regulations for preventing or minimiz-

ing the degradation of air, surface waters, subsurface waters, soils

and other physical features, could substantially reduce the stresses

imposed on living systems by current hazardous waste management prac-

tices.  The implementation of such regulations would reduce the

direct exposure of biota and habitats to hazardous wastes.   The over-

all benefits accrued would generally correspond to the amounts of

hazardous wastes brought under control and to the rate and uniformity

at which such control is implemented.

     The proposed regulations would result in the closing of existing

environmentally inadequate hazardous waste storage, treatment, and

disposal facilities and the construction of new facilities that would

be in compliance with the regulations.  This would have the following

principal impacts:

     •  Biological systems that occur in the vicinity of existing
        sites which would be closed could be subject to a reduced
        level of risk;
                                 7-181

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     •  The construction of new hazardous waste facilities would
        result in localized destruction and displacement of biota and
        the temporary degradation of local habitats due to noise,
        emissions, effluents and other construction impacts;

     •  Increased transportation of hazardous wastes would expose
        biota and habitats along transportation routes to increased
        outputs of vehicular emissions and increased frequency of
        accidental spills;

     •  The establishment of new hazardous waste facilities and the
        expansion of existing suitable facilities could reduce the
        habitat available to wild and domesticated biota by a
        presently undeterminable amount;  a shift from on-site to
        off-site disposal could result in the placement of some new
        facilities in largely remote and  rural areas, and thus could
        preempt habitats that support fish, wildlife and other
        natural biota in addition to exposing new communities to
        hazardous waste management activities.

     Although these regulations would afford a significant amount of

protection from contact with hazardous waste to the larger terres-

trial animals in the immediate vicinity of facilities and to biologi-

cal systems in a particular group of habitat types (e.g. , critical

habitats of endangered species and wetlands), the proposed regula-

tions do not include any special provisions for the protection of

waterfowl that may be attracted to hazardous wastes surface impound-

ments.  Thus, incidents such as that reported by Snyder et al.

(1976), in which migratory waterfowl were killed by alighting on

storage lagoons containing residues from a waste oil refinery plant,

could continue to occur.

     Additionally, the regulations apply only to safeguards at the

facility site itself.  No provisions are  specified for the siting of

facilities in relation to many other land use or habitat types that
                                  7-182

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may be of value to wild or domesticated biota (e.g., prime agricul-




tural lands; upland wildlife habitats, habitats and ranges of state




designated rare and endangered species, areas in major migratory




routes, commercially valuable forests, unique plant communities,




etc.).  It is likely, however, that permit application and review




procedures would provide a mechanism for considering such impacts




prior to facility approval.  The regulations also make no specific




provision for compensation or mitigation of losses of habitat and




biota that may occur as a result of the installation or operation of




hazardous waste facilities or as a result of accidents that may




result during their operation.




     7.2.3  Social Impacts.  Two major types of impacts could occur




as a result of promulgation of the Subtitle C regulations:  demo-




graphic changes and changes in existing social conditions.




     7.2.3.1  Demographic Impacts.  Potential sources of demographic




changes from the promulgation of the Subtitle C regulations include




closings or relocations of industrial plants; construction or modifi-




cation of hazardous waste management facilities; changes in opera-




tional requirements for hazardous waste management; and administra-




tive requirements for program management.




     As indicated in the Integrated Economic Impact Assessment of




Hazardous Waste Management Regulations (Regulatory Analysis Supple-




ment) , promulgation of the Subtitle C regulations would likely cause




some plant closings and job losses in a number of industrial segments







                                 7-183

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(e.g., textile industry, inorganic chemicals industry, organic chem-




icals industry, metals smelting and refining industry, electroplating




and metal finishing industry).   Such plant closings and job losses




would have the potential to cause relocations of some of the affected




workers and their families.  The nature and extent of any such relo-




cations and population shifts would be site-specific and dependent




upon such factors as number of workers affected, local and national




unemployment rates, number and types of jobs available, worker




skills, age of affected workers, and willingness of workers to relo-




cate.  There would be a potential for large-scale out-migrations from




any communities or areas for which plants being closed constituted




the primary source of employment.




     The Subtitle C regulations would result in modifications to




existing hazardous waste management facilities and the construction




of new facilities.  Due to the small number of construction workers




who would be required at any individual facility, it is unlikely that




there would be a significant amount of relocations or population




shifts due to construction requirements.  However, there could be




some localized instances of worker relocations, especially in the




case of facility construction in rural or undeveloped areas.  Any




such relocations would likely be of a temporary nature.




     Operational requirements for hazardous waste management under




the Subtitle C regulations would likely result in additional workers




being required to track the hazardous waste (due to the manifesting,







                                 7-184

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reporting, and recordkeeping requirements), to transport the wastes

(in the case of increased off-site disposal), and to store, treat, or

dispose the wastes both off-site and on-site.  Additional workers

would also be required to administer and enforce the regulations at

both the state and Federal levels.

     Some population shifts could occur if the required number of

workers were not available where needed, particularly in the case of

treatment/disposal sites being located in rural or undeveloped areas.

Any such shifts in population are expected to be relatively small on

a national scale; however, there could be localized instances of a

relatively large influx of workers, particularly for facilities

located near small towns or in rural areas.

     Based upon a study of the hazardous waste management service

industry (Foster D. Snell, Inc., 1976), about 500 workers (including

clerical and professional employees) are required to handle a million

metric tons of hazardous wastes per year.  Using this requirement as

the minimum number of workers likely to be required under the Sub-

title C regulations,  it is estimated that at least 20,000 such

workers could be required by 1984 to handle hazardous wastes.

Approximately 2,600 to 5,000 of these workers could be required at

off-site facilities, and approximately 15,000 to 17,400 could be
 This number does not include the additional workers that would
 likely be needed to trace the hazardous wastes under the Subtitle C
 regulations.  Some additional operational employees could also be
 required.


                                  7-185

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required at on-site facilities.   Based upon Section 7.2.4, this would




represent a decrease of 400 workers at off-site facilities in the




case of 13 percent off-site shipment and an increase of 2,000 workers




at off-site facilities in the case of 25 percent off-site shipment




(there would be equivalent, but opposite, changes at on-site facili-




ties).  It should be noted that changes in employment at off-site fa-




cilities would be more likely to cause population shifts than changes




at on-site facilities.  In 1975 approximately 2,000 workers were em-




ployed off-site at hazardous waste management service industry facil-




ities (Foster D. Snell, Inc., 1976).  Data are not available as to




the number of workers employed at on-site facilities, nor to estimate




the increase in the total number of employees that would be required




at all facilities under the regulations.




     7.2.3.2  Social Conditions.  Impacts to existing social condi-




tions could result from changes in the siting and operation of haz-




ardous waste management facilities and from any population shifts




caused by the regulations.




     The increased public health protection that would be derived




from the regulations would provide significant social benefits.  Many




of the social costs related to the exposure of workers and the gener-




al public to hazardous wastes and their residuals under current prac-




tices would be reduced or eliminated.  This exposure is known and/or




suspected to have caused numerous instances of adverse health ef-




fects, including death (see Section 7.1.6).  Much of the individual







                                 7-186

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grief and suffering associated with such incidences, as well as the




resultant economic losses, would be reduced or eliminated.




     The regulations, while not applying to household wastes, could




focus more public attention on the problems associated with the




improper treatment/disposal of hazardous wastes.  This could result




in increased care in the disposal of hazardous household wastes and a




further reduction in public health impacts from such disposal.  A few




examples of health problems that have resulted from the improper dis-




posal of hazardous household wastes are presented in Appendix J.




This awareness could also result in more citizen pressure on authori-




ties to see that hazardous waste is properly managed and that gener-




ators, transporters, storers, treaters, and disposers comply with the




regulations.




     On the other hand, an increased public awareness of problems




that have been associated with improper disposal of hazardous wastes




could add to opposition to local siting of hazardous waste management




facilities.  Citizen reaction to the siting of hazardous waste facil-




ities has been mostly negative.  A number of communities and states




have been unable to overcome citizen opposition in attempts to site




hazardous waste landfill or treatment facilities.  Such opposition is




not usually centered upon specific data regarding the adequacy of the




proposed facility with respect to public health or the environment.




Rather, it is usually based upon reported incidents and the belief
                                 7-187

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that such incidents could not be prevented from reoccurring, regard-




less of the precautions  to be taken.   For example, residents in




Bordentown, New Jersey,  have recently shown extremely strong opposi-




tion to the siting of a  chemical waste landfill whose construction




specifications appear to be well in excess of specific requirements




under subtitle C regulations (Waldron, 1978).  This type of opposi-




tion represents an educational and attitudinal problem which solid




waste management officials could find to be a pivotal constraint and




issue in the development of alternatives and solutions.  Any inabil-




ity to effectively site  or to provide necessary treatment or disposal




facilities would render  other steps less effective in providing envi-




ronmentally adequate hazardous waste management (Office of Solid




Wastes, 1977a).  However, promulgation of the regulations accompanied




by increased public awareness and participation in the facility sit-




ing process, and specific demonstrations that the objectives of the




regulations can be achieved, could also serve to lessen such opposi-




tion in the future and could lead to more effective siting of facil-




ities.




     Other social impacts could also result from the expansion or




construction of hazardous waste management facilities and from any




increased off-site transport of hazardous wastes.  The construction




and operation of new facilities would have aesthetic impacts and




could result in localized noise impacts.  Construction of new facil-




ities, especially off-site facilities, and conjunctive developments







                                 7-188

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such as road construction would create new jobs, but would also rep-




resent an intrusion on the existing aesthetic environment.  This




intrusion would consist of visual, auditory, and olfactory altera-




tions.  Forms, colors, lines, textures, sounds, and smells could be




changed.  The perception of these alterations would depend upon many




variables including the context in which the alteration appears, the




terrain masking the alteration, the distance from which the altera-




tion is viewed, the magnitude of the alteration, and the weather con-




ditions at the time of perception.  Proper planning, while not able




to eliminate these aesthetic and noise impacts, could make them less




perceptible.




      Facility construction and operation, including the additional




truck traffic associated with new facilities, could increase noise




levels in the vicinity of such facilities, especially in the case of




off-site facilities, and also along transport routes.  Changes in




noise levels would be extremely site-specific and would depend upon




such factors as existing noise levels in the area, type of facility




constructed, increase in truck traffic, distance to population cen-




ters, local topography, and local meteorological conditions.  Active




portions of facilities would have to be located at least 200 feet




from the facility's property line under the Subtitle C regulations.




Any changes in off-site shipments of hazardous wastes or in the dis-




tances such wastes are transported would also change the potential




for accidents from such transport.  Assuming that the average round
                                  7-189

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trip haul distance would increase to 200 miles and that there would




be 8.9 truck accidents per million vehicle miles (National Safety




Council, 1975), based upon Section 7.2.4 there could be about 270




additional accidents annually in 1984 in the case of 13 percent off-




site shipment and 850 additional accidents in the case of 25 percent




off-site shipment.




      The Subtitle C regulations do not contain specific provisions




for planning the siting of hazardous waste management facilities or




transportation routes.  However, the Section 3005 permit application




review procedure, including the opportunity for public hearings on




the permit application, would provide a means for consideration of




such factors at the state and local levels.  Other Federal laws, such




as OSHA noise regulations, and state and local laws and ordinances




could also serve to mitigate potential noise and aesthetic impacts.




     Implementation of the regulations could potentially have long-




term beneficial impacts through the establishment of a framework of




"equivalent" and "consistent" state programs.  This could reduce the




likelihood for a state to implement importation bans or overly strict




standards directed towards preventing the entry of wastes into any




particular state.  This could prevent states from becoming isolated




in terms of their ability to dispose of hazardous wastes.  This con-




sistency between states could, in turn, reduce the potential for geo-




graphic shifts by industry to escape strict regulations.  However, as
                                 7-190

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previously discussed, in the near term there could be individual




plant closings or relocations from the enactment of the regulations.




     Any shifts in population that result from the Subtitle C regula-




tions would have the potential to cause social impacts.  The magni-




tude of any such impacts would be site specific and would depend upon




such factors as the size of the shift relative to the size of the




existing population in affected areas, the rate of the shift, the




existing infrastructure in the affected areas, and the adequacy of




advanced planning.




     Large, rapid, population outfluxes could be unavoidable within




some areas if the regulations caused industrial plant closings or




relocations, especially if the plant were the primary source of




employment for the area.  Such out-migration could have a deflation-




ary impact on the local area; however, the remaining residents could




also be hard-pressed to maintain existing public services and facili-




ties, and local tax rates could have to be increased.  Unemployment




would increase in the retail and service sectors, and the number of




people requiring financial assistance programs would also likely




increase.  Daily living patterns could be drastically changed for




many of the remaining residents.  Stress would likely increase and




could lead to increases in mental and physical health problems.




     Large, rapid, population influxes associated with relocation of




industrial plants or with construction of new hazardous waste manage-




ment facilities could create inflation, social tensions, and a






                                  7-191

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shortage of housing and necessary infrastructure.   Provision of




necessary services and facilities could result in  increases in local




tax rates. Large,  rapid, population influxes could also create




tensions and disputes between the existing population and the




newcomers, especially if the existing residents were forced to modify




their daily living patterns to accommodate the changes in their




environment.  Increases in crime and in mental health related




problems (e.g., alcoholism, drug abuse, child abuse, divorce) have at




times accompanied large, rapid, population influxes (Institute for




Social Science Research, 1974).  On the otherhand, any growth could




also provide increased job opportunities and an expanded local tax




base in the long term.




     Population shifts need not necessarily result in adverse




impacts.  Small shifts, which would be the more likely occurrence in




the case of construction or closure of hazardous waste management




facilities, could have beneficial impacts or no noticeable impacts.




For example, a small population influx could provide additional in-




come, tax revenues, and jobs in the local community without placing




any noticeable strains on the existing infrastructure or daily living




patterns.  A small population decline could reduce any existing unem-




ployment and strains on public services and facilities without no-




ticeably affecting local income, tax revenues, employment, or daily




living patterns.




     7.2.4  Hazardous Waste Management Facility Capacity.  There are




two measures of hazardous waste management capacity—process capacity



                                  7-192

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and physical capacity.  Process capacity represents the throughput

capability of the hazardous waste management facility for handling

hazardous wastes (e.g., tons per day, gallons per year).  Physical

capacity, on the other hand, represents the constraint imposed by the

facility site itself on the total amount of wastes that can ultimate-

ly be stored, treated, or disposed at the facility (e.g., landfilling

of a total of 100,000 metric tons to a depth of 5 meters over the

life of a landfill).

     7.2.4.1  Process Capacity.  The impact of the Subtitle C regula-

tions on the availability of sufficient on-site and off-site process

capacity is addressed below.

     Off-site Capacity.  A recent study of the hazardous waste man-

agement service industry (Foster D. Snell, Inc., 1976) indicated that

at the end of 1974, the process capacity for the industry as a whole

was nearly 7.3 million metric tons per year, with up to approximately

5.3 million metric tons being considered environmentally adequate.*

The study further estimated that the process capacity would expand to

8.2 million metric tons by the end of 1977, with up to about 6.2 mil-

lion metric tons being considered environmentally adequate.  This

represents a 4.0 percent annual growth rate for total process capa-

city and a 5.5 percent annual growth rate for environmentally ade-

quate process capacity.
*It should be noted that all capacity considered environmentally
 adequate by the Foster D. Snell Study may not be considered
 environmentally adequate under Subtitle C.  Thus, the Foster D.
 Snell numbers should be viewed only as an upper limit on
 environmentally adequate capacity.

                                 7-193

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     Assuming that the 4 percent annual growth rate for total process




capacity would continue between the end of 1977 and the start of 1984




if the Subtitle C regulations were not promulgated, it is estimated




that there would potentially be 8.9 and 10.4 million metric tons of




total process capacity at the start of 1980 and 1984, respectively.




     Assuming that "environmentally adequate", as defined in the




Foster D. Snell study, is compatible with the requirements of the




regulations and that the 5.5 percent annual growth rate of such




capacity would continue between the end of 1977 and the start of




1984, it is estimated that under the regulations there could poten-




tially be as much as 6.9 and 8.5 million metric tons of environ-




mentally adequate process capacity available at the start of 1980 and




1984, respectively.




     Currently, about 15 percent of all hazardous industrial wastes




are shipped off-site for treatment/disposal (see Table 5-15).  For




purposes of analysis, it is assumed that any shift in off-site




treatment/disposal under the Subtitle C regulations would occur




gradually and that approximately 15 percent of the hazardous indus-




trial wastes would continue to be shipped off-site in 1980 (the first




year the regulations would be in effect).  As discussed in Section




7.1.2.4, for 1984, the fifth year the regulations would be in effect,




a range of 13 to 25 percent off-site shipment for treatment/disposal




is assumed for analysis purposes.




     Approximately 35 and 40 million metric tons of hazardous indus-




trial wastes could be generated annually in 1980 and 1984,



                                 7-194

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respectively.  Thus, it is estimated that about 5.3 million metric




tons of hazardous industrial wastes could be shipped off-site in 1980




and that between 5.2 and 10.0 million tons could be shipped off-site




in 1984.  This would represent no change in off-site shipments under




the Subtitle C regulations in 1980.  The change in off-site shipments




in 1984 under the regulations would range between a decrease of 0.8




million metric tons and an increase of 4.0 million metric tons.




     Assuming that treatment/disposal facilities would utilize on an




annual basis an average of about 90 percent of the available process




capacity, approximately 6.2 and 7.7 million metric tons of the envi-




ronmentally adequate capacity could be utilized in 1980 and 1984,




respectively.  The estimated 6.2 million metric tons of environ-




mentally adequate capacity that could potentially be utilized in 1980




would be sufficient to handle the estimated 5.3 million metric tons




of hazardous industrial wastes shipped off-site.  Even if there was




no growth in environmentally adequate capacity between 1977 and 1980,




there would still potentially be sufficient capacity in 1980.




     The estimated 7.7 million metric tons of environmentally ade-




quate capacity that could potentially be utilized in 1984 would be




sufficient to handle the estimated 5.2 million metric tons of hazard-




ous industrial wastes shipped off-site, assuming 13 percent off-site




shipment.  Again there would potentially be sufficient capacity even




if there was no growth in capacity between 1977 and 1984.
                                 7-195

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     In the case of 25 percent off-site shipment, there would poten-

tially be a shortfall of 2.6 million metric tons of environmentally

adequate capacity for treating/disposing hazardous wastes in 1984.*

Without any growth in environmentally adequate capacity, this short-

fall could be 4.9 million metric tons.  Shortfall in process capacity

would first occur in 1984 in the former case and in 1981 in the

latter case.  Based upon an average utilizable facility capacity of

60,000 metric tons per year (Foster D. Snell, Inc., 1976), approxi-

mately 45 additional off-site facilities could be required by 1984 in

the former case and approximately 80 additional off-site facilities

could be required in the latter case.

     It should be noted that the estimated availability of necessary,

off-site, process capacity is based only on the treatment/disposal of

hazardous industrial wastes.  As indicated in Section 7.1.1, an inde-

terminable quantity of other hazardous wastes would be generated and

an unknown portion of such wastes would be treated/disposed off-site

and could cause shortfalls in capacity.  Furthermore, these estimates

assume that the available capacity would be of the type that is spe-

cifically required (e.g., secure landfills, incinerators, surface

impoundments).  However, it is possible that there could be short-

falls of specific types of capacity even in those cases where the

total available capacity appears to be more than adequate.  Further-

more, since not all of the available capacity would necessarily be
*The actual shortfall would be 2.3 million metric tons.  However,
 with a utilization rate of 90 percent, 2.6 million metric tons of
 capacity would  be required.
                                 7-196

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sited where it is needed, there could be localized shortfalls of

process capacity even if the total process capacity were sufficient.

Any shortfall in on-site capacity as discussed below, could create

localized shortfalls in off-site capacity.  It should also be noted

that if any generators were to send potentially toxic wastes that

would not be considered hazardous under the Section 3001 regu-

lations to permitted facilities in order to obtain more secure

treatment/disposal, there would be an increased potential for

localized shortfalls in off-site capacity.

     On-site Capacity.  Data are not available to estimate if there

would be any potential shortfall in environmentally adequate, on-

site, hazardous waste management process capacity under the Subtitle

C regulations.  Based upon the assumption stated above, about 28.7

million metric tons of hazardous industrial wastes would be treated/

disposed on-site in 1980 and between 28.8 and 33.6 million metric

tons would be treated/disposed on-site in 1984 •  This would

represent no change in 1980.  The change in 1984 would range between

a decrease of 4.0 million metric tons and an increase of 0.8 million

metric tons.  As indicated in Section 7.1.2.4, the Subtitle C regula-

tions would likely result in an indeterminable decrease in existing

on-site process capacity and, as a result, could potentially cause

shortfalls in on-site process capacity in both 1980 and 1984.  The
 The remainder of the hazardous industrial wastes would be recycled
 or sent to resource recovery operations, both on-site and off-site.
                                 7-197

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requirement that at facility closure wastes must be removed from




permitted surface impoundments that do not meet Subtitle C landfill




standards could exacerbate any shortfalls, both on-site and off-site.




Increased resource conservation and recovery and use of more effi-




cient processes would lessen the potential for on-site shortfalls.




     7.2.4.2  Physical Capacity.  Few data are available to estimate




the overall physical capacity of facilities to store, treat, or




dispose hazardous wastes.  EPA recognizes the need for data on




physical capacity and will be conducting a series of inventories




toward that end.  Under the mandate of the Safe Drinking Water Act,




an inventory of surface impoundments will be conducted.  Under the




mandate of RCRA, an inventory of open dumps, solid waste landfills,




and sludge disposal sites will be conducted (Office of Solid Waste,




1977a).




     Any increase in the use of on-site or off-site landfills would




accelerate the rate at which the physical capacity of such landfills




would be exhausted.  Although the rate of exhaustioji of such land-




fills cannot be determined, it is possible to estimate the change in




the necessary on-site and off-site landfill acreage between 1980 and




1984.  Assuming that the shift in on-site and off-site disposal would




be apportioned equally over this period (e.g., 15 percent off-site




treatment/disposal in 1980, 17.5 percent in 1981, 20 percent in 1982,




..., 25 percent in 1984), there could be a total decrease of 1.9 mil-




lion metric tons in hazardous industrial wastes sent off-site during




this period, assuming 13 percent shipment off-site in 1984, and there




                                 7-198

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could be a total increase of 9.3 million metric tons in hazardous




industrial wastes sent off-site, assuming 25 percent shipment




off-site in 1984.




     Based upon Table 5-7, about 80 percent of hazardous industrial




wastes are disposed in landfills and surface impoundments.  Since




wastes treated in surface impoundments would be required to be dis-




posed in landfills if the surface impoundments do not meet the




Subtitle C landfill standards and since approximately 99.9 percent of




hazardous wastes are placed in surface impoundments that are environ-




mentally inadequate (see Table 5-7), it is assumed, for purposes of




analysis, that up to 80 percent of hazardous industrial wastes would




ultimately be disposed by landfilling.  Thus, there could be up to a




1.5 million metric ton decrease in off-site landfilling in the case




of 13 percent off-site shipment and up to a 7.5 million metric ton




increase in off-site landfilling in the case of 25 percent off-site




shipment.




     Assuming an average waste density of 0.8 metric tons per cubic




meter and a landfill depth of 10 feet, one to two acres would be




required for every 5,000 cubic meters of waste disposal (personal




communication, J. Schaum, EPA, 1978).  Thus, up to 400 to 800 fewer




acres could be committed to off-site landfilling between 1980 and the




end of 1984 in the case of 13 percent off-site shipment and up to




1900 to 3800 additional acres could be committed to off-site land-




filling between 1980 and the end of 1984 in the case of 25 percent




off-site shipment.  In the former case, after 1984 there could be 200



                                 7-199

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to 400 fewer acres required off-site annually compared to require-
ments without the regulations.  In the latter case, after 1984 there
could be an additional 1,000 to 2,000 acres required off-site annu-
ally compared to total requirements without the regulations.  There
could he commensurate changes in on-site land requirements in each
instance.
     For purposes of comparison, based upon an average, secure, com-
mercial landfill size of 270 acres (U.S. Environmental Protection
Agency, Office of Toxic Substances, 1977), these land requirements
would be equivalent to siting 1 to 3 fewer off-site secure landfills
by the end of 1984 in the case of 13 percent off-site shipment.  In
this case, the equivalent of 1 to 2 fewer off-site landfills could
have to be sited annually after 1984.  The land requirements would be
equivalent to siting 7 to 14 additional off-site secure landfills by
the end of 1984 in the case of 25 percent off-site shipment.  In this
case, the equivalent of 4 to 8 additional off-site landfills could
have to be sited annually after 1984.
     7.2.5  Land Use Impacts.  More total land, off-site plus
on-site, would be required for hazardous waste management under the
Subtitle C regulations than for hazardous waste management under
current practices.  The additional land would be required both for
the construction of permitted facilities necessary to meet any
additional capacity shortfalls that could occur under the Subtitle C
regulations and for such conjunctive developments as construction of
roads, power lines, and pipelines.  However, as indicated in Section
                                 7-200

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7.2.4, in the case of 13 percent off-site shipment there would be




fewer hazardous industrial wastes sent off-site by 1984 under the




Subtitle C regulations than under current practices.  Thus, while




more total land would be required, there could be less off-site land




use and more on-site land use in this case.  In the case of 25




percent off-site shipment, there would be more hazardous industrial




wastes sent off-site by 1984 under the Subtitle C regulations than




under current practices.  Thus, there could be more off-site land use




and less on-site land use in this case.  Estimates of potential




changes in off-site land requirements for landfills (and commensurate




changes in on-site land requirements) are presented in Section 7.2.4.




     It should be noted that while shifts to on-site land use could




reduce off-site land requirements in the short term, such shifts




could also accelerate the exhaustion of the relatively limited




on-site physical capacity and could result in increased pressure for




off-site facilities in the long term.  Increases both in resource




conservation and recovery and in treatment practices resulting in




volume reduction (e.g., incineration) that occur as a result of the




Subtitle C regulations would have the potential for reducing land




requirements, both on-site and off-site, in the long term.




     Existing land uses would cease, either permanently or temporari-




ly, on all land converted to hazardous waste management uses.  Some




agricultural, grazing, forest, recreational, and other lands could be




removed from their existing uses.  The regulations would prohibit







                                 7-201

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facility construction, and thus not affect existing land uses, on




100-year flood plains, on or near active fault zones,  in wetlands, in




critical habitat areas, or in recharge areas of sole source aquifers.




     Following closure of the hazardous waste management facility and




rehabilitation of the site according to the closure plans, the land




would be available for new or, in some cases, previously existing




uses.  Sites at which hazardous wastes have not been removed would be




precluded from residential and agricultural uses, and  may be pre-




cluded from some recreational and grazing uses following closure.




Any activity requiring excavation would be prohibited  at sites where




wastes are not removed.  Further, since the regulations would require




records to be kept of the location and types of all hazardous wastes




remaining at the site, the potential for incidents such as occurred




at Love Canal in Niagra Falls, New York would be reduced.  (This




incident is discussed in Section 7.1.6).




     To the extent that the regulations would prevent  other lands




from being contaminated by improper disposal, dumping, storage or




treatment under current practices and regulations, there would be a




potential for offsetting land use benefits.  Sections  7.1.4, 7.1.5




and 7.2.1 describe the potential for the generation of air, water,




and land residuals which could affect existing land uses under cur-




rent practices and regulations.  These sections also discuss the po-




tential for reducing these residuals under the proposed regulations.
                                  7-202

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     In addition to land use changes brought about by facility




siting, operation, and closure, the proposed regulations could have




an impact on a few current land use practices associated with poten-




tially hazardous wastes.  For example, landspreading of sludges is




specifically addressed in the regulations.  The requirements that




landfarms be operated so as not to allow waste migration, and be




closed so that food chain crops could be grown on site would both




minimize the areal extent of contamination and would allow continued




productive use of the land after waste applications ceases.  Another




example would be the regulation of road oiling for dust control.




This practice is not specifically addressed in the proposed regula-




tions, although numerous incidents of environmental contamination




have occurred as a result of road oiling.  (Some of these incidents




are described in other parts of this chapter and in Appendix J.)  The




proposed regulations would require generators of over 100 kilograms




per month of waste automotive oils to comply with the regulations.




Additionally, hydraulic and cutting oil wastes are listed as hazard-




ous wastes, and other waste oils may be included under the various




criteria.  Therefore, any waste 'oils which are considered hazardous




under the proposed regulations would have to be treated so as to be




rendered nonhazardous before being used for road oiling.  This pro-




cedure would reduce the environmental damage and resultant adverse




impacts to land use that have occurred due to unregulated road




oiling.
                                 7-203

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     7.2.6  Water Use Impacts.   The Subtitle C regulations would




affect water use in two ways—through a reduction in groundwater and




surface water contamination and through increased water demand by




expanded and new hazardous waste facilities.  It is estimated that




almost one half of the population of the United States depends on




groundwater as a source of drinking water, and that over one third of




the nation is underlain by groundwater reservoirs capable of yielding




at least 75,000 gpd to an individual well (Office of Solid Waste Man-




agement Programs, 1977).  It is further estimated that industrial




impoundments account for over 100 billion gallons of contaminant per




year to groundwater and residential, commercial and institutional




land disposal sites and account for about 90 billion gallons of lea-




chate to groundwater annually (Office of Solid Waste Management Pro-




grams, 1977).  It is apparent that the potential dangers of uncon-




trolled disposal of hazardous wastes are a serious problem.  With the




implementation of the regulations regarding disposal and treatment of




hazardous wastes, a significant reduction in groundwater leachate




should occur, thereby decreasing the potential danger to private and




public underground water supplies.




     The potential for the degradation of both groundwater and sur-




face water would be reduced under the regulations.  To the extent




that degradation of water quality would have resulted in a decreased




supply of surface water or groundwater being available to some or all




consumers in the water use area, there would be an additional supply




of groundwater or surface water potentially available to such




                                 7-204

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consumers and fewer restrictions on the productive use of such
surface water and groundwater supplies.
     Implementation of the proposed regulations would necessitate
that some existing facilities currently accepting hazardous wastes be
upgraded in order to make them environmentally adequate, and that new
facilities be sited to minimize potential capacity shortfalls.  New
facilities would be additional consumers of water for purposes such
as:
     •  Dust control;
     •  Soil compaction;
     •  Washing and cleaning of equipment and containers;
     •  Biological treatment;
     •  Spill control;
     •  Laboratory requirements;
     •  Fire control and other emergencies;
     •  Site rehabilitation;
     •  Wet scrubbers for air pollution control;
     •  Miscellaneous uses, including cooling water.
     Such demands would affect the water budget of the localities in
which the facilities were located to varying degrees  depending upon
such factors as the type of facility sited, its water requirement,
and the potential water availability in the area.   The additional
water requirement would be somewhat offset by the amount of water (if
any) that would have otherwise been used for the treatment/disposal
of these additional wastes under current practices and regulations.
                                  7-205

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     7.2.7  Impacts to Resource Conservation and Recovery.  As




discussed in Section 5.4.2,  approximately 3 to 5 percent of hazardous




industrial wastes have been subject to resource recovery in recent




years with most efforts directed toward the recovery of solvents,




oils, metals, and energy.  The Subtitle C regulations contain few




provisions directed specifically toward increasing the portion of




hazardous wastes that would be subject to resource conservation and




recovery efforts.




     However, since one of the major impacts of the regulations would




be to increase generator's costs and the costs associated with




hazardous waste transport, storage, treatment, and disposal, there




would be an incentive provided by the regulations for generators to




modify processes so as to enable increased recycling of hazardous




wastes as process feedstocks, to reduce the quantities of hazardous




wastes generated by specific processes, or to change the nature of




the wastes produced (e.g., to produce wastes that are less hazar-




dous).  In addition, the Section 3004 regulations direct that where




practical, disposal of hazardous wastes would have to be avoided and




alternatives, such as resource recovery, reuse, or other methods of




recycling, would have to be employed.  Furthermore, since the




regulations prohibit the placing of ignitable wastes in landfills,




landfarms, surface impoundments, and basins, the potential for




increased incineration of such wastes, with possible energy recovery,




would be greatly enhanced.







                                 7-206

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     As previously indicated, the potential for the implementation of




process modifications or other changes to promote resource




conservation and/or recovery would be extremely waste stream and




process specific and would depend upon such factors as changes in the




economics of disposal, treatment, and transport; the cost of raw




materials and energy; the availability of markets for and sources of




recyclable hazardous wastes; and the availability both of the




necessary technology for specific resource conservation or recovery




efforts and of environmentally adequate disposal methods and




capacity.  Chapter 5 presents some examples of the potential for the




increased resource recovery from and recycling of hazardous wastes.




Due to the complex interrelationships among the above factors, it is




not possible to determine the specific changes that could occur with




regard to resource conservation and recovery, nor the overall extent




of any such changes.




     7.2.8  Energy Use Impacts.  Promulgation of the Subtitle C




regulations would cause changes in energy use in the following areas:




hazardous waste management facility construction, facility operation,




hazardous waste transport, and hazardous waste resource conservation




and recovery.




     The facility modification and construction that would be neces-




sary under the regulations would result in increased energy use (see




Section 7.1.2).  More energy would also be used for the construction




of new facilities under the regulations than would have otherwise
                                 7-207

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been needed due to requirements directed toward making these facili-




ties more environmentally secure (e.g. , requirements for site prepa-




ration, landfill liners, diversion structures, monitoring systems,




pollution control equipment).




     There would also be increased energy use resulting from required




changes in storage, treatment, and disposal operations under the reg-




ulations.  For example, requirements for application of daily cover,




for higher incineration temperatures and longer retention times, for




increased removal of potential air contaminants, for periodic moni-




toring and analysis, for removal of wastes from surface impoundments




at facility closure, and for post close-out care would all poten-




tially result in increased energy use.   However, any increase in




resource conservation occurring under the regulations would reduce




the quantity of wastes that would have  otherwise been stored,




treated, or disposed and could thus off-set the increase in energy




use.  Previously discussed changes in resource recovery would also




lead to other changes in energy use.  While any increase in resource




recovery would likely require  the initial input of additional energy,




energy savings could result from increased energy recovery; from




further reductions in wastes requiring storage, treatment, or




disposal; and from materials recovery and reuse.  This could result




in an overall energy savings from resource recovery operations.




     The changes in energy use from the transport of hazardous wastes




would depend upon such factors as shifts in the portion of wastes
                                 7-208

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managed on-site and off-site and changes in transport distances.




Table 7-15 presents estimates of the magnitude of the potential




change in energy use that could occur annually by 1984 from changes




in transport distances and shifts in off-site and on-site treatment/




disposal.  Changes in transport distances are estimated as discussed




in Section 7.1.4.1; the change in energy use is estimated assuming




that trucks average 7.5 miles per gallon of fuel.  The estimated




annual change in energy use ranges from a decrease equivalent to




about 20,000 barrels of crude oil for a 100-mile round-trip distance




with 13 percent off-site treatment/disposal to an increase equivalent




to about 2.2 million barrels of crude oil for a 1,000-mile round-trip




distance with 25 percent off-site treatment/disposal.




     7.2.9  Impacts to Special Interest Points.  Special interest




points consist of natural, modified or artificial features of the




environment that are of special aesthetic, cultural, and recreational




significance.  Such features include archaeological and paleonto-




logical sites; cultural areas; historical sites; parks and recrea-




tional areas; scenic areas and other aesthetic resources; unique




geological formations; wilderness areas; wild and scenic rivers; and




wildlife refuges and other natural areas.  The extent to which




current hazardous waste management practices may have resulted in




adverse impacts to such resources is not documented.  However, the




types of incidents previously discussed would have had the potential




to cause adverse impacts, primarily through the release of air,
                                  7-209

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                                             TABLE 7-15



                     ESTIMATED  CHANGE  IN FUEL CONSUMPTION IN 1984 FROM TRANSPORT

                     OF HAZARDOUS  INDUSTRIAL WASTES UNDER SUBTITLE C REGULATIONS
I
N>
O

Wastes Round -trip
transported distance
off-site (miles)
13 percent 100
200
500
1,000
25 percent 100
200
500
1,000
Change in fuel consumption
(million gallons)
-0.7
4
18
42
4
13
37
86
Crude oil
equivalent*
(1,000 barrels)
-20
100
460
1,100
90
320
920
2,200

   *Assumes 95 percent  efficiency  in  producing  diesel  fuel  from crude oil.

-------
water, and soil contaminants that could disturb or degrade such




special interest points.




    The Subtitle C regulations contain provisions which, while not




applying specifically to the protection of special interest points,




would provide indirect benefits to special interest points and to the




human enjoyment of such features.  For example, restrictions on the




siting of hazardous waste management facilities in wetlands, perma-




frost areas, and critical habitats would reduce the potential for




adverse impacts to such areas.  Furthermore, provisions that would




potentially reduce the release of air, water, and soil contaminants




from such facilities would reduce the potential for these contami-




nants to infringe upon special interest points located in the vicini-




ty of hazardous waste management facilities.  Reductions in air,




water, and soil contaminants would also increase, or at least main-




tain, the opportunity for human enjoyment of such special interest




points.  Requirements applicable to the closure of facilities such as




landfills, landfarms, and surface impoundments would increase the




potential for revegetation of such facilities and would reduce the




potential for adverse aesthetic impacts.




     To the extent that additional lands would be disturbed by




facility construction and operation and by conjunctive developments,




there would be an increased potential for infringement upon special




interest points.  Construction of additional hazardous waste man-




agement facilities would represent an intrusion on the existing






                                  7-211

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aesthetic environment and could also result in the disturbance of




archeological or historical sites.  The clearing of trees or other




vegetation could result in substantial alterations to the visual




characteristics of the site.  Noise, dust, emissions, and other




disturbances associated with site preparation, facility construction




and operation, and hazardous waste transport could adversely effect




nearby special interest points and could discourage their use or




enjoyment.  The perception of these alterations would depend upon




many variables, as discussed in Section 7.1.3.  Proper planning,




while not able to eliminate these alterations, could make them less




discernible.  The Subtitle C regulations do not contain specific




provisions for planning the siting of hazardous waste management




facilities or transportation routes with regards to special interest




points.  However, the Section 3005 permit application review proce-




dure, including the opportunity for public hearings on the permit




application, would provide a means for consideration of such factors.




Other Federal laws, such as the Archeological and Historic Preserva-




tion Act of 1974, and state and local laws and ordinances would also




serve to mitigate any potential impacts to special interest points.




7.3  Significant Uncertainties in the Impact Analysis




     The impact analysis is subject to a number of significant




uncertainties.  Limited data are currently available with regard to




both the generation and the management of hazardous wastes.




Uncertainties exist as to the types and quantities of hazardous
                                  7-212

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wastes generated by various sources, especially non-manufacturing




sources.  Uncertainties also exist as to the number, distribution,




capacity, and adequacy of existing hazardous waste management




facilities.  Data are sparse on the generation and release of




specific hazardous air, water, and soil contaminants by various




storage, treatment, and disposal methods.  Data and methodologies are




not available, for the most part, for determining the movement,




transformation, and ultimate fate of most contaminants released to




the environment.  Human and biological health effects which are a




function of both the concentrations of such contaminants and the




duration of exposure are, therefore, uncertain.  Dose-response data




are not yet established for determining health effects from many




potentially hazardous contaminants.  These limited data, coupled with




the site, process, and waste specific nature of most impacts,




necessitates a qualitative assessment.  Estimates of the probable




range of changes and worst-case analyses have both been used to bound




the magnitude of potential impacts.  The emphasis of the impact




analysis has necessarily been placed on hazardous manufacturing




wastes, though large volumes of some other hazardous wastes may also




be generated.




     Furthermore, uncertainties exist with regard to the adequacy of




existing technologies and methods for controlling the release of




environmental contaminants.  The long-term effectiveness of landfill




and surface impoundment liners in preventing the discharge of
                                 7-213

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leachate and other water contaminants is uncertain.  Over long peri-




ods of time even materials such as clay and polymeric membranes,




which are usually considered inert, may react with leachate or waste




components and may fail or become more porous.   Considerable research




is currently underway to determine the long-term capabilities of




various liner materials.  Also, while 99.99 percent destruction effi-




ciencies have been demonstrated for the incineration of many hazar-




dous wastes, such destruction efficiencies have not been demonstrated




for most hazardous wastes.  Furthermore, in spite of the impressive




performances of the incinerators reported in the literature in




destroying hazardous wastes, most studies were performed under




extremely controlled conditions and only specific products of combus-




tion were sampled in many cases.  Problems could occur due to




requirements for frequent maintenance and extensive operator educa-




tion in order to ensure proper functioning.  Maintenance could be an




especially serious problem since many wastes burned in incinerators




are either extremely caustic or produce caustic products when burned.
                                 7-214

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8.0  IMPACTS OF THE ALTERNATIVES

     Four reasonable alternatives to the proposed regulations have

been developed to bracket the overall objectives and the resultant

impacts anticipated from the regulations to be ultimately promulgated

under Subtitle C.  Each of the four alternatives is assessed in this

section to the extent that the proposed regulatory changes would

elicit changes in impacts as they would result from implementation of

the proposed regulations.  Impacts of the alternatives that would be

substantially the same as those of the proposed regulations are not

presented in order to avoid duplication.

8.1  Potential Changes in Impacts Resulting from the No Action
     Alternative

     As previously discussed, the No Action Alternative is defined as

meaning that no part of RCRA, including Subtitle C, is to be imple-

mented and that hazardous waste management would continue as current-

ly practiced, modified by any future state legislation developed

without Federal guidance.  However, since implementation of RCRA is

mandated by an act of Congress, implementation of this alternative

would not be feasible without an. additional act of Congress repealing

RCRA.  The No Action Alternative, therefore, is not realistically

considered a viable alternative at the present time.  The following

discussion briefly outlines some of the potential impacts which could

occur in the unlikely event that this alternative were followed.

     8.1.1  Primary Impacts.  In the absence of a Federal hazardous
                                 8-1

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waste control program under RCRA, the primary means of controlling




hazardous waste management activities would be through programs




developed by individual states and through various sections of other




Federal laws, notably, the Safe Drinking Water Act, the Federal Water




Pollution Control Act, and the Clean Air Act, as amended.  Since




there would be no established mechanism to encourage states to enact




equivalent regulatory approaches and consistent means of control, it




is probable that the states would continue to take different




regulatory approaches and to exert very different levels of control.




Such approaches would depend on the individual needs, the types and




amounts of waste generated, and the political climate in each state.




Approaches could range from no control to regulations more




restrictive than the proposed Subtitle C regulations.  Furthermore,




state programs would remain subject to pressures for sending most




hazardous wastes to other states, for banning hazardous waste




shipments from other states, and for the enactment of more stringent




or less stringent regulations than neighboring states.  Differences




in definitions and in criteria for characterizing hazardous wastes




would likely be a common occurrence.  The present splintered and




uncoordinated development of hazardous waste control programs would




continue.  This inconsistency of programs would result in the less




effective control of hazardous wastes and would allow the continued




occurrence of those types of incidents previously discussed.




     A detailed discussion of existing state regulations for selected
                                  8-2

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states that have promulgated hazardous waste programs is presented in

Appendix A.  Many of the states currently manage hazardous waste

problems on a case-by-case basis.  At present, 35 states do not have

specified criteria or lists for identifying hazardous waste.  Most

states instead identify hazardous materials through broad or

generalized definitions.  At this time, 35 states have not enacted or

proposed permit system regulations specifically for the disposal of

hazardous waste; 39 states do not have any standards or regulations

for a manifest program; 31 states do not have any recordkeeping or

reporting standards or regulations; 35 states have no formalized

inspection standards or regulations for hazardous waste facilities;

and 38 states do not have a specific monitoring program standards or

regulations with regard to hazardous waste.  Many of the states do,

however, have the enabling authority to control each of these

activities; however, most of these state have been waiting for

Federal action before proceeding with its own programs.  Without such

action, it is difficult to determine the outcome of pending waste

management programs.

     It is likely that on-site activities would continue to escape

regulation under many states laws.  Existing regulations are often

times applicable only to off-site facilities, operated in a

non-private capacity.  Without a Federal requirement for on-site

control, a large percentage of waste managed on-site could continue

to go unregulated.  The widely used concept of case-by-case

management would also likely continue and, as a result, many wastes
                                 8-3

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would continue to escape any control.  Intrastate movement of




hazardous wastes would likely continue to be poorly controlled.




     The present trend toward control of hazardous wastes is slowly




but steadily increasing, as more states extend the limits of their




enabling authority to include hazardous waste management.  It is not




possible to determine whether this trend would continue to occur




independent of the requirements and goals provided by Subtitle C.




National awareness of the hazardous waste problem is increasing as




more environmental problems occur due to the improper management of




hazardous waste  However, individual states desiring to initiate




hazardous waste programs would not have the aid of the Federal




funding authorized under the regulations.  Depending on the extent of




the control needed, the financial requirements for effective program




implementation could be a substantial constraint to some states.




      The impacts to air and water quality and to public health that




would occur as a result of this alternative would be a continuation




of the present effects previously discussed.  In many cases, even




strict state control could not protect the state from air or water




pollution originating in neighboring states.  Incidents such as those




described in Chapter 7 would continue to occur, though state regula-




tions may produce local reductions.  Large amounts of poorly




controlled or uncontrolled hazardous wastes could contaminate many




water supplies, air sheds, and large areas of land in many
                                 8-4

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scattered locations.  Public health effects from these materials

could be manifested in many ways.  Of particular concern are the

often insidious effects of long-term, low-level exposure to toxic

materials; such effects often may not become apparent for many years.

      8.1.2  Secondary Impacts.  Current impacts to physiography and

soils, ecological systems, social conditions, land use, water use,

energy use, resource recovery, and special interest points would

continue to occur, though they could be mitigated by the enactment of

more stringent state regulations than those that currently exist. The

implementation of strict state controls would not always protect

states from air and water contaminants originating in neighboring

states with less stringent regulations and from the secondary impacts

of such air and water contaminants.  Incidents such as those

described in Chapter 7 would continue to occur,  particulary in those

states that exert little control over hazardous wastes.

     At present, most states do not have regulations or standards for

hazardous waste disposal sites or for disposing wastes in such sites.

As a result, even though there may actually be a shortage of

environmentally acceptable dispdsal sites, there is technically no

shortfall since few states have requirements to use such sites.  As

additional states develop strict disposal regulations, local

shortfalls of environmental adequate treatment,  storage, and disposal

capacity could occur.

     Variations in the degree of control of hazardous wastes among

the states could also create a tendency for industries to relocate in
                                 8-5

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states with the least stringent control requirements.  Other indus-

tries might elect to ship their wastes to such states if treatment

and disposal costs in their own state were to be considered too high.

This indirect encouragement of industrial development in certain

states could lead to increased incidents of environmental degradation

and potential public health problems in such states.  Any widespread

implementation of import bans, if constitutional, could have severe

effects on states whose soils, climate, and geologic conditions are

generally unsuitable for secure waste disposal.

8.2  Potential Changes in Impacts Resulting from the Phasing of
     Generators Alternative

     This section discusses the potential changes in impacts (rela-

tive to those of the proposed regulations) that would occur as a

result of promulgation of the regulations contained in the Phasing of

Generators Alternative.  To avoid considerable duplication in the

presentation, potential impacts discussed in Chapter 7 that would not

be changed under this Alternative are not repeated.  Only major

changes in potential impacts are discussed.

     8.2.1  Primary Impacts.  The change in primary impacts that

could occur under this alternative are discussed below.

     8.2.1.1  Hazardous Waste to be Regulated.  The objective of this

alternative is to reduce the potential for overtaxing resources

(e.g., manpower, capital, disposal sites) beyond their capacity for

responding effectively to the proposed Subtitle C regulations.  This

would be accomplished by phasing in, over a five-year period from


                                8-6

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1980 through 1984, the generators to be regulated (larger generators
first, then smaller generators), such that approximately twenty per-
cent of the total hazardous waste would be controlled during the
first year with an additional twenty percent being controlled each
subsequent year.  This alternative would be implemented by changing
the generator limit defined in the proposed regulations.  Under this
alternative, the generator limit would be quite large the first year,
and would be reduced each succeeding year, such that by the fifth
year it would be 100 kilograms per month.  This procedure would
exclude those hazardous wastes that do not meet the generator limit
from compliance with the generator requirements, though certain
disposal requirements would still apply.  Again, emphasis is placed
upon hazardous wastes generated by the manufacturing industries for
the purpose of analysis.
     To develop phasing limits, data on hazardous waste generation
from the manufacturing industries have been analyzed to estimate
quantities of hazardous waste generated by SIC Code and by EPA
Region, as well as to estimate the number of generating firms.
Appendix H describes the methodology used for estimating the total

potentially hazardous waste generation in the manufacturing indus-
tries.  Appendix I describes the computer program used to determine
the amounts of wastes and number of industries which would be con-
trolled in each year of the phasing alternative.  As in the analysis
of the proposed regulations, this alternative is based on the assump-
tion that only about 35 percent of the estimated potentially
                                8-7

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hazardous waste generated in SIC Code 28 would be subject to




regulation, due to the nature of the toxicity characteristic (see




Section 7.1.1 for more detail).




     Using these methods, the generator limit is determined for




each year of the five-year program.  Then, using summary data from




Appendix K, the number of establishments and the EPA Region in




which they are located is determined.  Tables 8-1 through 8-4 show




the distribution of the wastes regulated in each year.  Because of




assumptions and data limitations discussed in Appendices H and I,




Tables 8-1 through 8-4 do not present the specific quantities of




wastes or number of firms that would be subject to regulation during




each year of phasing, but only indicate the EPA Regions and SIC codes




in which the regulated wastes are contained.




     In order to bring 20 percent of the manufacturing wastes




that are hazardous under control in 1980, it is estimated that the




generator limit would have to be set at 12,900 metric tons per year;




all establishments generating hazardous waste quantities greater than




approximately 1,075 metric tons  per month would be regulated during




the first year.  This would limit control efforts to SIC Codes 26




(Paper and Allied Products), 28  (Chemicals and Allied Products), 29




(Petroleum and Coal Products), and 33 (Primary Metal Industries), as




shown in Table 8-1.  About 75 percent of the controlled wastes would




be from SIC Code 28.  All EPA Regions would be involved to some




extent; though, as indicated, Regions III, IV, and V would generate

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OO
I
VO
                                                                 TABLE 8-1

                                            REGULATED HAZARDOUS MANUFACTURING WASTES DURING THE
                                           FIRST YEAR OF PHASING (1980)* BY REGION AND SIC CODE

Cod Totals
e
I II III

26 X X
28 XXX
29 X
33 XX

IV V

X X
X X
X
X X

VI VII VIII IX X

X X
XX XX
X X
X X X X
Wastes
(1000 metric
tons)
157
5170
263
1310
Number of
establishments
aff ectedt
c
f
c
d
        Totals-

        1000     156   964   1430   1570  1540  938   109    35    78     76         6890
        metric
        tons

        Number of
        establish- bdd      d      edaa      aa
        affectedt
        *Based on a generator limit of 1075 metric tons/month,  chosen to include approximately  20  percent  of
         the total estimated hazardous wastes (see Section 7.1.1).   An "X"  indicates  that  at  least some  hazardous
         wastes generated in the appropriate SIC Code would probably be subject  to  Subtitle C requirements
         in the corresponding region.

        tThe number of establishments subject to Subtitle C requirements are presented  as  ranges:   a=l-5;
         b=6-10;  c=ll-25; d=26-50;  e=51-100; f=101-250;  g=251-1000;  h=1001-2500;  i=2501 or more.

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                                                            TABLE 8-2

                                          REGULATED HAZARDOUS MANUFACTURING WASTES DURING
                                       THE SECOND YEAR OF PHASING (1981)* BY REGION AND SIC CODE






00
I-1
0

SIC Code
26
28
29
31
32
33
34
35
EPA Region
I
X
X
X

X
X
X
X
II
X
X
X

X
X
X
X
III IV V
XXX
XXX
XXX

X X
XXX
X
XXX
VI
X
X
X


X
X
X
VII
X
X
X

X
X
X
X
VIII IX X
X X
XXX
XXX
X

XXX
X
X X
Totals
Wastes (1000 metric tons)
947
8790
619
8
104
2790
165
1440
Number of establishments
affectedt
f
g
e
a
d
g
e
f
Totals
1000
metric     552  2090  2380  2640  4090  1670   532
tons

Number of
establish-  e    f     f     f     g     f     e
ments
affectedt
117
       549   246
       e     d
14,900
*Based on a generator limit of 303 metric tons/month, chosen to include approximately 40 percent of the total estimated hazardous
 wastes (see Section 7.1.1).  An "X" indicates that at least some hazardous wastes generated in the appropriate SIC Code would
 probably be subject to Subtitle C requirements in the corresponding region.

tThe number of establishments subject to Subtitle C requirements are presented as ranges:  a=l-5; b=6-10; c=ll-25; d=26-50; e=51-100;
 f=101-250; g-251-10001 g=1001-2500; 1=2501 or more.

-------
                                                                   TABLE 8-3

                                              REGULATED HAZARDOUS MANUFACTURING WASTES DURING THE
                                              THIRD YEAR  OF PHASING  (1982)* BY REGION AND SIC CODE
00

I
25
26 X
28 X
29 X
30
31 X
32 X
33 X
34 X
35 X
37 X
39 X
Totals
1000
metric 1150
tons
Number
of g
establish-
ments
affectedt
EPA Regions
II III IV V VI VII VIII IX X
XXX
XXXXXX X XX
XXXXXX X XX
XXXXXX X XX
X XX
XXXXXX X X
X X X X X X
XXXXXX X XX
XXXXXX X X
XXXXXX X XX
XXXXXX X XX
X X


2890 3140 3550 6380 2240 934 205 1120 419


g g g h g f a g e



Totals
Wastes (1000 metric tons)
9
2470
9960
898
9
360
360
3660
486
3000
803
6


22000






Number of establishments
affectedt
e
g
h
f
a
f
f
8
f
g
f
b





i



       *Based on a generator limit of 125 metric tons per month, chosen to include approximately 60 percent of the total estimated hazardous wastes
        (see Section 7.1.1).  An "X" indicates that at least some hazardous wastes generated in the appropriate SIC Code would probably be subject
        to Subtitle C requirements in the corresponding region.

       tThe number of establishments subject to Subtitle C requirements are presented as ranges:  a=l-5;  b=6-10;  c=ll-25; d=26-50; e=51-100;
        f=101-250; g=251-1000; h=1001-2500; i=2501 or more.

-------
                                                              TABLE 8-4

                                         REGULATED HAZARDOUS MANUFACTURING WASTES  DURING THE
                                        FOURTH YEAR OF PHASING (1983)* BY REGION AND  SIC CODE
SIC Code

20
22
25
26
28
29
30
31
32
33
34
35
36
37
38
39
Totals
1000
metric
tons
Number of
establish-
ments
affectedt
EPA Regions

I


X
X
X
X
X
X
X
X
X
X
X
X
X
X

1740



h



II
JC

X
X
X
X
X
X
X
X
X
X
X
X
X
X

3970



h



III
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

4080



h



IV

X
X
X
X
X
X
X
X
X
X
X
X
X

X

4740



h



V
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X

8830



i



VI


X
X
X
X
X
X
X
X
X
X
X
X
X
X

2940



h



VII
X

X
X
X
X
X
X
X
X
X
X
X
X

X

1430



g



VIII
X


X
X
X
X
X
X
X
X
X
X
X
X
X

330



f



IX



X
X
X
X
X
X
X
X
X
X
X
X
X

1960



h



X



X
X
X


X
X
X
X

X
X


594



g


Wastes (1000 metric tons)

14
26
60
3,440
12,600
1,070
87
686
1,070
4,730
1,340
4,330
94
966
22
93

30,600






Totals
Number of establishments
affectedt
d
e
f
h
i
g
f
g
h
h
h
i
f
g
c
f





i


*Based on a generator limit of 34 metric tons per month, chosen to include approximately 80 percent of the total estimated hazardous wastes
(see Section 7.1.1).  An "X" indicates that at least some hazardous wastes generated in the appropriate SIC Code would probably be subject
to Subtitle C requirements in the corresponding region.

tThe number of establishments subject to Subtitle C requirements are presented as ranges:  a=l-5; b=6-10; c=ll-25; d=26-50; e=51-100-
f=101-250; g=251-1000; h=1001-2500; 1=2501 or more.

-------
about 65 percent of the regulated wastes.  Approximately 230 estab-
lishments would be regulated nationwide.
     In order to bring 40 percent of the manufacturing wastes that
are hazardous under control in 1981, it is estimated that the
generator limit would have to be set at 3,630 metric tons per
year;all establishments generating quantities of hazardous waste
greater than approximately 303 metric tons per month would be
regulated during the second year.  This would extend control efforts
to SIC Codes 31 (Leather and Leather Products), 32 (Stone, Clay, and
Glass Products), 34 (Fabricated Metal Products), and 35 (Machinery,
Except Electrical), as shown in Table 8-2.  About 60 percent of the
controlled wastes would originate in SIC Code 28.  Control efforts
would be more pronounced in EPA Regions III, IV and V, though their
share would decrease to about 61 percent, with one-half of that being
in Region V.  Approximately 1,500 establishments would be regulated
nationwide.
     In order to bring 60 percent of the manufacturing wastes that
are hazardous under control in 1982, it is estimated that the gener-
ator limit would have to be set at 1,500 metric tons per year (125
metric tons per month).  Control efforts would be further expanded to
industries in SIC Codes 25 (Furniture and Fixtures), 30 (Rubber and
Miscellaneous Plastic Products), 37 (Transportation Equipment), and
39 (Miscellaneous Manufacturing Industries), as shown in Table 8-3.
Wastes from SIC Code 28 would still predominate, contributing about
45 percent of the total.  EPA Region V would contain about 29 percent
                                8-13

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of the wastes, while Regions II, III, IV, and V would each contain
between 10 and 16 percent.   About 4,300 establishments would be
regulated nationwide.
     In order to bring 80 percent of the manufacturing wastes that
are hazardous under control in 1983, it is estimated that the gen-
erator limit would have to be set at 410 metric tons per year (34
metric tons per month).  This control effort would now expand to
cover portions of the hazardous wastes generated by establishments
in all SIC codes except 23 (Apparel and Other Textile Products), 24
(Lumber and Wood Products), and 27 (Printing and Publishing), as
shown in Table 8-4.  Again, SIC Code 28 would predominate, though its
share would be reduced to about 41 percent.  Distribution among the
EPA Regions would remain essentially the same as in 1982, though an
additional 8.5 million metric tons would be controlled.
Approximately 15,500 establishments would be regulated nationwide.
     In the fifth and final year of phasing, all hazardous waste
generators would be regulated except those producing 100 kilograms
or less per month.  Table 1-1 presents the quantities of hazardous
wastes from manufacturing industries that would be phased into the
program in 1984, as well as the distribution of the regulated estab-
lishments.  During this final year, industries in virtually every
manufacturing SIC Code and each EPA Region would be involved in
regulatory actions.  Approximately 232,000 manufacturing establish-
ments would be regulated.
     The net effect of this alternative is that a total of about 74
                                8-14

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million metric tons of hazardous industrial wastes could be excluded

from regulation during the first four years following implementation

of the Subtitle C regulations.  These wastes represent about 50

percent of the total hazardous industrial wastes that could be

regulated under the proposed regulations.

     8.2.1.2  Changes to Existing Generation, Transport, Storage,

Treatment, and Disposal Practices and Procedures.  Since this alter-

native only reduces the number of generators who would be subject to

the generator regulations during the first four years following their

implementation, there would be few changes in the impacts previously

discussed.  Those changes that do occur would be limited to the first

five years following implementation of the regulations. Longer-term

impacts would not change.

     Generators who continue to produce a quantity of hazardous waste

exceeding the generator limit in all years would not be affected by

this alternative.  Generators who produce a quantity of hazardous

waste that exceeds the generator limit of the proposed regulations,

but that does not exceed the generator limit of this alternative,

would be excluded from the generator regulations under this

alternative.  These excluded generators would not have to comply with

the manifesting, reporting, recordkeeping, or containerization

requirements discussed in Section 7.1.2.1.  However, as in the case

of the proposed regulations, these generators would still be required

to treat/dispose their wastes in a responsible manner.

     The major options available to these generators would be
                                8-15

-------
disposal in an approved sanitary landfill meeting RCRA Subtitle D




requirements (this would not be allowed for these generators under




the proposed regulations); treatment/disposal in a permitted off-site




facility; or treatment/disposal in a permitted on-site facility




(although the generating establishment would not be subject to the




generator regulations, treatment/disposal of hazardous wastes on-site




would still require permitting of the treatment/disposal facility,




unless it was an approved landfill meeting Subtitle D criteria).  It




should be noted that without requirements for manifesting and




reporting of these wastes, there would be a greater potential for




generators not to comply with these disposal requirements and a




lesser potential for determining if generators did not comply.  It is




therefore likely that additional wastes would be treated/disposed in




an environmentally unacceptable manner.




     There would be few changes in transport, storage, treatment, or




disposal practices under this alternative.  Transporters would still




have to comply with all regulations for the transport of manifested




wastes; however, there would be fewer such manifested shipments.




Transport distances would likely decrease during the first four years




since the excluded hazardous wastes could be sent to sanitary land-




fills which would likely be more abundant and situated closer than




off-site permitted facilities.  To the extent generators would send




their wastes to Subtitle D landfills, there would potentially be a




lesser number of treatment/disposal facilities, primarily on-site






                                 8-16

-------
facilities, that would have to be modified during the first few years




following implementation of the regulations.  However, to the extent




that generators reverted to on-site treatment/disposal when again




subject to the generator regulations, their facilities would have to




be modified as before.  There would be no change in the requirements




for facilities that store, treat, or dispose hazardous wastes.




     It should be noted that this alternative would allow most gener-




ators a longer time to familiarize themselves with the implications




of the regulations before being required to comply.  They would have




a better opportunity to develop plans for compliance and be less sub-




ject to making quick decisions.  Also, there would be an opportunity




to detect any unexpected problems that arise from the implementation




of the regulations and to make any necessary modifications in the




regulations before all generators were included.




     8.2.1.3  Administrative Changes.  A major benefit resulting from




this alternative would be the gradual expansion of administrative re-




quirements, rather than the abrupt imposition of such requirements.




Administrative requirements, primarily paperwork, would be reduced




during the first four years following implementation of the regula-




tions.  The reduction in these administrative requirements could also




encourage additional states to apply for interim or full authoriza-




tion.




     The estimated change in the number of hazardous waste generators




who could be required to comply with the generator requirements is







                                8-17

-------
shown in Tables 8-1 through 8-4.  Based upon the assumptions dis-

cussed in Section 7.1.3.6,  it is estimated that industrial generators

could have to prepare a total of between 660,000 and 1.3 million

manifests during the period from 1980 to the start of 1984.  This

represents about a 50 percent reduction in the number of manifests

that would have to be prepared by industrial generators during this

period under the proposed regulations.   During the first year, the

industrial generators could have to prepare 72,000 manifests, an 80

percent reduction.

      During the first 6 years,* the aggregated generators,

transporters, and owners/operators of hazardous waste management

facilities could each have  to keep a total of between 3.2 million and

5.2 million manifests in storage; this  would represent over a 30

percent decrease in manifests in storage during this period.  During

the first year, 72,000 manifests could  have to be stored, an 80

percent reduction.

     During the first four  years, it is estimated that industrial

generators could have to prepare a total of about 22,000 annual

reports; this would represent over a 97 percent decrease in such

annual reports.  During the first year, about 230 annual reports

could have to be prepared,  a 99.9 percent reduction.
*Due to the requirement for three-year storage of manifests, the
 impact of this alternative on the number of manifests in storage
 would continue for the first six years.
                                3-18

-------
     It is estimated that transporters could have to file a total of




between 280 and 400 spill reports during the first 4 years, a reduc-




tion of over 45 percent.




     As previously discussed, there would be, at most, a small re-




duction in the number of permitted facilities during the first four




years.  As a result, there could be a small reduction in the number




of most reports prepared by permittees.  However, since the addi-




tional hazardous wastes that would not be subject to the generator




requirements under this alternative and would have to be sent to




approved sanitary landfills or to permitted facilities, there would




likely be an increase in the number of unmanifested shipments




received at permitted facilities.  Consequently, permittees could




have to prepare an increased number of reports on the receipt of




unmanifested wastes.  The increase in the length of the reporting




interval for such reports under this alternative would serve to




reduce the number of additional reports prepared.




     8.2.1.4  Air and Water Impacts.  To the extent that a total of




74 million metric tons of hazardous industrial wastes excluded from




the generator regulations under this alternative were not to be




managed in a manner equivalent to that required under the Subtitle C




regulations, there would be an increased potential for the relese of




air and water contaminants from these wastes.  These air and water




contaminants could be released as described in Sections 7.1.4.1 and




7.1.5, and could result in the types of incidents and impacts
                                8-19

-------
discussed in those sections.  The release of air and water con-
taminants could continue for many years following the disposal of
such wastes.
     8.2.1.5  Public Health Impacts.  Changes in public health
effects would be directly related to changes in the release of air,
water, and soil contaminants.  To the extent that increased releases
were to occur, there would be an increased potential for the types of
public health impacts discussed in Section 7.1.6 to continue to
occur.  Chronic effects related to long-term, low-level exposure to
such contaminants could continue to occur for many years following
improper disposal of such wastes.
     8.2.2  Secondary Impacts.  To the extent that a total of 74 mil-
lion metric tons of hazardous industrial wastes were not to be man-
aged in a manner equivalent to that required under the Subtitle C re-
gulations, there would be an increased potential for additional soil
contamination, as described in Section 7.2.1.  Changes in impacts to
the biological environment, to water use, to land use, and to special
interest points would be directly related to these changes in the re-
lease of air, water, and soil contaminants.  To the extent that
increased releases were to occur, there would be an increased poten-
tial for the type of impacts discussed in Section 7.2 to continue to
occur.  These impacts, especially biological and water use impacts,
could continue to occur for many years following improper disposal of
such wastes.
     There would be less potential for demographic changes during the
                                8-20

-------
first four years due to reduced economic demands on generators that




would in turn reduce the potential for plant closings or relocation,




due to reduced demands for new hazardous waste management facility




capacity, and due to the reduced administrative requirements.




However, demographic shifts that were just delayed during the first




four years could start to occur following the fourth year.  The




longer transition period would, however, provide an increased oppor-




tunity for planning and instituting measures to mitigate the poten-




tial impacts of any population shifts.  The longer transition period




could also reduce the potential for some plant closings by providing




generators with an increased opportunity to evaluate  alternatives




available to them.




     With regard to hazardous waste management facility capacity,




Section 7.2.4.1 indicates that under the proposed regulations there




would potentially be sufficient capacity for managing hazardous




industrial wastes during the first four years, with one exception.




In the case of no growth of existing environmentally adequate capac-




ity and 25 percent off-site shipment, there could be a capacity




shortfall by 1981, the second year of regulation.  Under the phasing




alternative, the potential for such a capacity shortfall could be




delayed until 1983, the fourth year of regulation.  In addition,




there would be a lesser potential for any shortfalls to occur in all




the other cases examined in Section 7.2.4.1.  Furthermore, there




would be increased time for planning the siting of any new facilities




that could be required.



                                8-21

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8.3  Potential Change in Impacts Resulting  from  the Enhanced  Public
     Health and Environment Protection Alternative

     This section discusses the potential changes in  impacts

(relative to those of the proposed regulations)  that  could occur  from

the promulgation of the regulations contained in the  Enhanced Public

Health and Environmental Protection Alternative.  To  avoid

considerable duplication in the presentation, potential impacts that

would not be changed under this alternative are  not repeated.  Only

major changes in potential impacts are discussed.

     8.3.1  Primary Impacts.  The major changes  to primary impacts

that could occur as a result of implementation of this alternative

are discussed in the following sections:

     •  Hazardous Wastes to be Regulated;

     •  Changes to Existing Generation, Transportation, Storage,
        Treatment, and Disposal Practices and Procedures;

     •  Administration Changes;

     •  Air Impacts;

     •  Water Impacts;

     •  Public Health Impacts.

     8.3.1.1  Hazardous Waste to Be Regulated.  Under this alterna-

tive, two additional hazardous waste characteristics would be added

to the Section 3001 regulations and the existing toxicity criteria

would be expanded so as to bring additional potentially hazardous

wastes under regulation.  It is expected that the expanded toxicity
                                 8-22

-------
characteristic would result  in  the regulation of most,  if not all, of




the potentially hazardous organic wastes that would be  excluded from




regulation under the proposed regulations, as discussed in Section




7.1.1.  Additionally, this alternative would eliminate  the 100




kilogram per month generator limit and the previously discussed




exclusion for generators engaged solely in farming or retail trade.




Thus, all generators of any amount of wastes considered hazardous




under the Section 3001 regulations (except household wastes) would




have to comply with all Subtitle C regulations.




     Based upon the expanded toxicity characteristic and the proce-




dures described in Chapters 6 and 7 and Appendix H, it is estimated




that approximately 57 and 65 million metric tons of hazardous




manufacturing wastes would be controlled under this alternative  in




1980 and 1984, respectively.  The expanded criteria could also result




in the inclusion of potentially large volumes of non-manufacturing




wastes such as those described in Section 6.1.2.  The portion of




these wastes which would be identified as hazardous by the




characteristics is unknown, but it could be quite large.




     There could thus be a minimum of 22 and 25 million metric tons




of additional wastes declared hazardous and brought under regulatory




control with this alternative in 1980 and 1984, respectively, as com-




pared to the proposed regulations.  This would represent about a 63




percent increase in the hazardous wastes controlled in both these
                                 8-23

-------
years.  The hazardous wastes controlled under this alternative would

represent about 16 and 19 percent,  respectively, of the total annual

industrial solid waste stream currently estimated to be generated.

     8.3.1.2  Changes to Generation, Transport, Storage, Treatment,

and Disposal Practices.  Additional changes to generation, transport,

storage, treatment, and disposal practices would be likely to occur

under this alternative due to the additional wastes being regulated;

due to the enactment of more stringent environmental requirements;

due to resultant increases in storage, treatment, and disposal costs;

and due to the imposition of additional procedural and operational

requirements.

     Generation.  Under this alternative,  many additional generators

would be required to comply with the generator regulations.  The ad-

ditional generators to be regulated include those previously ex-

cluded due to the generator limit of 100 kilograms per month, farmers

and retailers who generate hazardous wastes other than waste automo-

tive oil, and generators who produce wastes that now meet the ex-

panded toxicity characteristic or the new infectious or radioactive

characteristics.  Section 8.3.1.3 presents estimates of the number of

additional generators to be regulated.  These generators would be

required to change their existing practices and procedures with

regard to manifesting, reporting, recordkeeping, containerization,

and labeling.  In addition, these generators and the previously

regulated generators would be subject to shorter reporting intervals,

as indicated in Table 4-2.
                                 8-24

-------
     Due to further increases in hazardous waste generation, trans-




port, storage, treatment, and disposal costs under this alternative,




all regulated generators would potentially have an increased incen-




tive to further modify their processes so as to reduce and/or change




the types and amounts of hazardous wastes generated and to enable the




increased recycling of hazardous wastes as process feedstocks.




    Transport.  Due to the additional wastes subject to the generator




regulations, additional transporters would likely have to comply with




the transporter regulations discussed in Section 7.1.2.2.  As a




result there would likely be fewer instances of midnight dumping and




spills from the transport of these additional wastes, as compared to




existing practices.  However, any increases in the average distance




over which hazardous wastes are transported under this alternative




could lead to an increase in vehicular accidents.  This would off-




set some of the potential for a reduction in spills.




     The average distance over which hazardous wastes are trans-




ported would be likely to increase due to several factors.  The more




stringent treatment and disposal requirements under this alternative




would likely further decrease both the amount of existing on-site and




off-site treatment/disposal capacity that could be permitted and the




number of sites acceptable for construction of new facilities.  Any




such decreases in available facilities and sites would potentially




lead to increased transport distances.  Reductions in permittable on-




site treatment/disposal capacity could further result in additional
                                  8-25

-------
wastes being sent off-site for treatment/disoosal.  Increases in




treatment/disposal costs could also further increase the distance




over which wastes could be economically transported for resource




recovery purposes.  However, increased on-site resource conservation




and recovery could reduce the quantity of wastes sent off-site.




     The elimination of the use of a delivery document in lieu of a




manifest would further affect existing transportation practices.  The




use of specific delivery documents is now required under Interstate




Commerce Commission (ICC) regulations for transporters engaged in




interstate commerce and under DOT regulations for the interstate




transport of hazardous materials; as previously indicated, some




states have also applied the DOT regulations to intrastate shipments




of hazardous materials.  The requirement under this alternative that




all hazardous waste transporters use manifests, not delivery




documents, could result in those transporters now being required to




use delivery documents to also carry a manifest.




     Storage.  Due to the additional generators and wastes regulated




under this alternative, additional storage facilities would likely




have to comply with the storage regulations discussed in Section




7.1.2.3.  Some of these existing storage facilities would be required




to be modified or to close.  Existing practices at most of these




storage facilities would also have to be changed as previously indi-




cated.  In addition, all regulated storage facilities would have to
                                8-26

-------
comply with the additional requirements contained in Table 4-2.  As




indicated in Section 7.1.2.3, data are not available to estimate the




number of facilities that would be affected, nor the quantities of




wastes that would be affected.




      Treatment/Disposal.  Due to the additional generators and




wastes regulated under this alternative, additional treatment/




disposal facilities would have to comply with the treatment/ disposal




regulations discussed in Section 7.1.2.4.  Types of facilities likely




to come under regulation under this alternative include those




facilities used exclusively for 'special wastes' and those facilities




used solely by farmers.  Some of these facilities would be closed




because they could not comply with the regulations or could not be




economically modified.  Some previously regulated facilities that




would be permitted under the proposed regulations could be closed




under this alternative or could require additional modifications




because of the more stringent requirements.  To the extent that




existing on-site facilities were closed, increased quantities of




hazardous wastes could be sent off-site; however, increased on-site




resource conservation and recovery applications could off-set such a




change.




      Existing practices would have to be changed at most of the




additional facilities to be regulated under this alternative, as




indicated in Section 7.1.2.4.  In addition, these additional facili-




ties as well as all previously regulated treatment/disposal
                                 8-27

-------
facilities would now have to comply with the more stringent require-

ments contained in Table 4-2.  Due to these more stringent require-

ments and due to the costs associated with them, there would also be

a potential for increases in the treatment of wastes for such pur-

poses as volume reduction, energy recovery, and resource recovery.

The regulation that the permitting authority could require poten-

tially recoverable wastes to be land disposed in a segregated manner

could further increase resource recovery from such wastes.

     8.3.1.3  Administrative Changes.  Several changes in the admin-

istration of hazardous waste management programs would result from

promulgation of the regulations within this alternative.  These regu-

lations would affect:

     •  State administration of the program;

     •  Overlapping Federal and state programs;

     •  Number of generators required to comply with the regulations;

     •  Number of transporters required to comply with the
        regulations;

     •  Number of storers, treaters, and disposers required to obtain
        permits;

     •  Paperwork requirements.

     State Administration of the Program.  It is likely that fewer

states would apply for authorization under this alternative because

expansion of both the quantity of hazardous wastes and the number of

generators, transporters, storers, treaters, and disposers being

regulated, plus the increases in reporting frequencies, would lead to


                                 8-28

-------
increased administrative and manpower requirements for authorized
states.
     Overlapping Federal and State Programs.  Since Subtitle C

prohibits any state from enacting less stringent regulations than
those in the Federal program, the potential for overlapping Federal

and state programs would be reduced under this alternative.  The more
stringent standards and increased amount of hazardous waste con-

trolled under this alternative would reduce the potential benefits
to, and thus the likelihood of, a state enacting a more stringent,

independent, hazardous waste program.  It is not possible at this
time to estimate the number of states, if any, that would wish to
have their own independent programs in addition to the Federal
program under this alternative.
     Number of Generators Required to Comply with the Regulations.
As indicated in Section 8.3.1.2, there would be an increase in the

number of generators required to comply with the regulations.  Under
the proposed regulations, approximately 430,000 to 460,000 generators
are identified as potentially having to comply with the regulations.
The elimination of the generator' limit could result in up to an addi-

tional 81,000 manufacturing generators and 80,000 gasoline service
stations being required to comply (see Section 7.1.3.3).  The elim-

ination of the exclusion for farmers and retailers, coupled with the
elimination of the generator limit, could result in up to 1.5 million

farmers (Trask, 1977) and up to 42,000 dry cleaning facilities (Bat-
telle Columbus Laboratories, 1978) being required to comply.  An
                                  8-29

-------
indeterminable number of other generators (e.g., 'special waste gen-




erators'  and other retailers) could also be required to comply due to




the expansion in the wastes identified as hazardous as well as to the




elimination of the other provisions previously discussed.  Thus, on




the order of 2.2 million generators within these identified cate-




gories could be required to comply with the regulations under this




alternative.  This would represent over a 400 percent increase in the




number of generators being regulated.




     Number of Transporters Required to Comply with the Regulations.




The increased amounts of regulated hazardous wastes that would poten-




tially be transported off-site would likely result in an indetermin-




able increase in the number of transporters carrying hazardous




wastes.




     Number of Storers, Treaters, and Disposers Required to Obtain




Permits.  Since there are no permit exclusions under the proposed




regulations for storage, treatment, or disposal facilities that




handle only small quantities of hazardous wastes, all facilities




storing, treating, or disposing hazardous wastes would be required to




obtain a permit under the proposed regulations with the exception of




generators who store for less than 90 days prior to off-site trans-




port.  With one exception, only those facilities that handle wastes




that would not be classified as hazardous under the proposed regu-




lations, but that would be classified as hazardous under this alter-




native, would be additional -permittees.  The exception is that the






                                 8-30

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additional facilities that could be needed to satisfy the potential




capacity shortfall under this alternative (see Section 8.3.2.4) would




also require permits if they were to be constructed.  Based upon




Section 8.3.2.4, approximately 120 additional facilities could




require permits by 1984.  However, to the extent that additional




capacity would be added to existing facilities there would be a




lesser number of such additional permittees.




     Paperwork Requirements.  Based upon section 8.3.2.4, the indus-




trial generators could have to prepare between 580,000 and 1.1




million manifests annually by 1984.  The aggregated generators,




transporters, and hazardous waste management facility owner/operators




could each have to keep between 1.7 million and 3.4 million mani-




fests in storage on an annual basis.  This would represent over a 60




percent increase in both requirements as compared to the proposed




regulations.  This increase would even be greater for any transpor-




ters who would now have to keep both a delivery document and a mani-




fest in storage.  In addition, transporters would have to file a




total of between 220 and 440 spill reports annually—approximately a




60 percent increase.




      The 2.2 million identified generators would have to prepare




about 8.8 million quarterly reports on an annual basis; this would be




almost a 2,000 percent increase in such annual reporting.  As indi-




cated in Section 7.1.3.6, most potential permittees would be on-site




facilities and would not prepare additional quarterly reports based







                                  8-31

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on the manifests.   Hazardous waste management service industry

facilities and Federal installations could,  however, prepare about

1400 such reports—a 300 percent increase.   The permittees identi-

fied in Section 7.1.3.5 could prepare up to  ir7,000 monitoring

reports annually;  this would not represent  any change.  Thus, there

could be upwards of 8.9 million quarterly reports prepared annually

by generator, storers, treaters, and disposers—over a 1,500 percent

increase.

     The identified generators and permittees would have to file over

2.2 million notifications under Section 3010—over a 400 percent in-

crease.  Furthermore, since potential permittees would have to re-

new permits every 5 years rather than being  issued one permit good

for the projected life of the facility as under the proposed regula-

tions, there could be up to a six-fold increase (in the case of a

30-year facility site life) in the paperwork associated with obtain-

ing permits.  These potential permittees would also have to prepare

approximately 29,000 Supplemental Environmental Analyses as part of

the initial permit review procedure; these  Supplemental Environmental

Analyses would not be required under the proposed regulations.

     8.3.1.4  Air Impacts.

     Air Quality.   The regulations under this alternative would have

the potential to cause further changes, primarily reductions, in air

emissions resulting from the generation, transport, storage,

treatment, and disposal of hazardous wastes, as compared to the

proposed regulations.
                                  8-32

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     Generation.  As previously discussed, the Subtitle C regulations

would not have a direct effect on potential air emissions resulting

from activities and processes generating hazardous wastes.  However,

to the extent that the requirements under this alternative would

cause further changes in the economics of storage, treatment, or

disposal relative to those of the proposed regulations, there would

be a greater potential for generators to make process modifications

designed to further increase hazardous waste recycling and to reduce

the quantity and/or types of hazardous wastes generated; any such

process modifications would likely lead to changes in air emissions

released by processes generating hazardous wastes.  Furthermore, to

the extent that additional generators would be brought under control

of the program through the expanded definition of hazardous wastes

and the elimination of exclusions, the potential for such process

modifications and resultant changes in air emissions would be

increased.

     Transport.  As indicated in Section 7.1.4.1, there are three

major ways air contaminants are released by the transport of hazard-

ous wastes:

     •  Through fugitive emissions resulting from improperly covered,
        sealed, or containerized wastes;

     •  Through emissions resulting from spills or other accidental
        releases of hazardous wastes;

     •  Through emissions resulting from the operation of the
        transport vehicle.
                                  8-33

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As discussed below, this alternative would affect, to varying

degrees, the potential for the release of air emissions from each of

these sources.

     To the extent that the additional 25 million metric tons of

potentially hazardous industrial wastes (plus other hazardous wastes)

brought under the regulations by this alternative would otherwise

have been improperly covered, sealed, containerized, or segregated

during any transport, the potential for the release of fugitive

emissions by such transport and from any resultant spills or ex-

plosions would be reduced as described in Section 7.1.4.1.  The

following example illustrates an incident that occurred from the

transport of a hazardous waste that would not likely be regulated

under the proposed regulations but which would likely be regulated

under this alternative:

     •  In southern Louisiana, industrial wastes containing
        hexachlorobenzene (HCB), a relatively volatile material, were
        transported over a period of time to municipal landfills in
        uncovered trucks.  High levels of HCB have since been
        reported in the blood plasma of individuals along the route
        of transport.  In a sampling of 29 households along the truck
        route, the average plasma level of HCB was 3.6 ppb, with a
        high of 23 ppb.  The average plasma level of HCB in a control
        group was 0.5 ppb with a high of 1.8 ppb (Farmer et al.,
        1976).

     Both the total quantity of regulated hazardous wastes being

transported and the average distance over which such wastes are

transported could increase under this alternative, as previously
                                 8-34

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indicated.  Additional transport would result in increased vehicular

emissions and in an increased potential for vehicular accidents which

could further release air emissions.  However, transport of hazardous

wastes in accordance with the regulations discussed above would

reduce the potential for spills and explosions from improper trans-

port and from resultant vehicular accidents.  This would off-set some

of the potential for increased vehicular accidents to result from

increased transport distances.  The changes in both the vehicular

emissions and emissions resulting from accidents would be dependent

upon such factors as the increase in travel distances, the change in

portion of hazardous wastes transported off-site, and the increase in

the amount of regulated wastes being transported.

     Using the methodology and assumptions described in Section

7.1.4.1, the potential change in vehicular air emissions from the

transport of the hazardous industrial waste regulated under this

alternative has been estimated for four possible transport distances

for both 13 and 25 percent off-site shipment of hazardous wastes in
    j^
1984 .  Table 8-5 shows the change in vehicular emissions relative

to those of the proposed regulations (as presented in Table 7-8).

For example, for a 100-mile round-trip distance with 13 percent
*In this estimate, it is assumed that under the proposed regu-
 lations there would be 15 percent off-site shipment for those
 hazardous wastes that would not be regulated under the proposed
 regulations, but which would be regulated under this alternative.
                                 8-35

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                         TABLE 8-5

ESTIMATED CHANGE IN VEHICULAR EMISSIONS IN 1984 FROM TRANSPORT OF
ADDITIONAL HAZARDOUS INDUSTRIAL WASTES UNDER SUBTITLE C REGULATIONS

Change in emissions (metric
Wastes
transported
off -site
13 percent



25 percent



Round -trip
distance
(miles)
100
200
500
1S000
100
200
500
1,000
Carbon monoxide
-100
550
2,500
5,700
480
1,700
4,900
11,600
Hydrocarbons
-15
90
400
910
80
280
100
1,900
Nitrogen
oxides
-70
400
1,800
4,200
350
1,300
3,600
8,500
tons)
Particulates
-5
25
110
260
20
80
220
530

Sulfur
ox ide s
-10
50
240
560
50
170
480
1,100

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off-site treatment/disposal, the decrease in each air emission under

this alternative could be equal to about 60 percent of that which

could occur under the proposed regulations.  For a 1,000-mile

round-trip distance with 25 percent off-site treatment/disposal, the

increase in each air emission under this alternative could be equal

to about 60 percent of that which could occur under the proposed

regulations.  In this latter case, the additional increase in each

air emission would be less 0.04 percent of the total U.S. emissions

of that air pollutant and less than 2 percent of the total U.S. area

emissions of that pollutant from heavy-duty, diesel-powered vehicles.

     Based upon the methodology and assumptions described in Section

7.1.4.1, there could be on the order of 220 to 440 transportation-

related hazardous wastes spills annually by 1984.  As previously

discussed, it is not possible to estimate the number of spills that

would have occurred if the additional 25 million metric tons of

hazardous wastes were not regulated under this alternative.

     Storage, Treatment, and Disposal.  As discussed in Section

7.1.4.1, there are several major ways that air contaminants can be

released by current hazardous waste storage, treatment, or disposal

practices:

     •  Through fugitive emissions resulting from improper storage of
        hazardous wastes;

     •  Through fugitive emissions from ground-based treatment/dis-
        posal activities such as landfills, landfanns, and surface
        impoundment s;
                                 8-37

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     •  Through  emissions  occurring  as  the  result  of  storage becoming
        the  ultimate  form  of  disposal of hazardous wastes;

     •  Through  emissions  generated  by  spills,  fires,  explosions,  and
        other accidents;

     •  Through  the  combustion  of  hazardous wastes by incineration or
        open burning;

     •  Through  fugitive emissions from other  treatment  activities;

     •  Through  fugitive emissions from facility construction or
        modification.

This alternative would affect the  potential for the release of air

emissions from each  of these  sources as discussed  below.

     The additional  25 million  metric tons  of  potentially hazardous

industrial wastes (plus other hazardous wastes) estimated to be

brought under control of the  regulations by this alternative would

now have to be stored, treated,  or disposed in accordance with the

Section 3004 regulations.   Since,  as previously discussed,  most of

these wastes would otherwise  have  been  stored,  treated,  or disposed

by methods that  are  not likely  to  be enviromentally acceptable under

the Section 3004 regulations, the  overall  potential for  the release

of hazardous air emissions from the  management of  such additional

wastes would be  reduced as described in Section 7.1.4.1.

     It should be noted, however,  that  there would likely be some

shift in the types of methods used to store, treat, or dispose these

additional wastes under this  alternative  compared  to  the unregulated

methods that would have been  used  under the proposed  regulations.

Such shifts would change both the  types and quantities of air
                                  8-38

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emissions generated from the management of specific wastes.  For




example, a shift from landfilling to incineration of a particular




waste would result in the increased release of combustion products




and the reduced release of particulate matter and/or volatile gases.




Such shifts could, to an indeterminable extent, either enhance or




reduce the potential for reductions in specific air emissions under




this alternative.  Furthermore, the construction of new facilities




could lead to increased releases of air emissions in the vicinity of




the facility and along any transport routes.  Closure of existing




facilities could lead to reduced releases of air emissions in the




vicinity of the facility and along transport routes.  The net result




could be both a localized and/or nationwide reduction in the re-




leases of many air contaminants from hazardous waste management and




a localized and/or nationwide increase in the total releases of other




air contaminants.  Thus while there would most likely be improvements




in air quality due to this alternative, there could also be some lo-




calized degradation of air quality.  All releases of air contaminants




and any localized degradation of air quality would, however, have to




be in compliance with all applicable requirements (e.g., Clean Air




Act, OSHA standards, state standards, and Subtitle C standards).




     The following two examples illustrate incidents that occurred




from the disposal of hazardous wastes that would not likely be




regulated under the proposed regulations but which would likely be




regulated under this alternative:
                                  8-39

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     •  The hexachlorobenzene wastes,  previously discussed under
        transportation,  were disposed  in  landfill items  in southern
        Louisiana;  some  of  this  relatively volatile waste was covered
        following  disposal, some was not.   Soil  and plant samples
        taken near the landfill  area showed a decreasing HCB content
        as  distance from the landfill  increased.  The HCB levels in
        the plasma of  landfill workers was reported to range from 2
        to  345 ppb; the  average  level  in  a control was 0.5 ppb with a
        high of 1.8 ppb.

     •  Vinyl chloride monomer  (VCM) is retained in sludge wastes
        produced during  polyvinyl chloride (PVC) processing.
        Following  disposal, the  gaseous VCM escapes from the sludge
        if  not removed before disposal.  A study by Markle et al.
        (1976) indicated background air concentrations of about 0.1
        to  0.3 ppm VCM exist at  landfills  where  PVC sludge has been
        disposed for several years.  Peak concentrations on the order
        of  1.0 ppm VCM were observed at normal breathing heights as
        long as 24 hours after  the PVC sludge deposits were covered.
        Other air  samples collected in the vicinity of a New Jersey
        landfill indicated  that  vinyl  chloride was continuously
        emitted from the landfill; vinyl  chloride levels as high as
        0.4 ppm were found  in a  residential area one mile from the
        landfill (Office of Solid Waste,  Hazardous Waste Management
        Division,  1978b.)

      Additional requirements imposed  by  this alternative would

further reduce the potential for the release of  air contaminants from

the management of  both the  additional  25  million metric tons of

hazardous wastes controlled under this alternative and the 40 million

metric tons also controlled under the  proposed regulations.  The

major impact would result from  changing the application of the

Theshold Limit Values  (TLV) from an air human health and environmen-

tal standard to a  mandatory standard with which  facilities must

always be in compliance, and the imposition of  the TLV's as a maximum
                                 8-40

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concentration not to be exceeded at any time rather than as a time-




weighted average not to be exceeded over an 8-hour day and 40-hour




week.  To the extent that non-point source emissions, such as those




from landfills, landfarms, surface impoundments, and storage areas




(see section 7.1.4.1 for specific examples), would exceed the TLV's




under the proposed regulations there would be further reductions in




the release of air contaminants under this alternative.




     The reduction in the maximum vapor pressure (from 78 mm mercury




at 25 C to 53 mm mercury at 25 C) of wastes that may be placed in




storage tanks vented directly to the atmosphere or treated/disposed




in landfills, landfarms, surface impoundments, or basins would fur-




ther reduce the potential for the release of emissions from the




management of these volatile wastes, as described in Section 7.1.4.1.




Examples of wastes constituents which have a vapor pressure between




53 and 78 mm mercury at 25 C and which could be identified as hazar-




dous under the expanded Section 3001 lists and characteristics




include boron tribromide, 1,2-dichloropropane, methacrylonitrile, and




thiophene.




     The requirement that owners/operators of inactive storage,




treatment, or disposal sites would have to comply with the Section




3004 regulations would reduce the potential for releases of air




emissions from wastes remaining in such inactive sites.
                                 8-41

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      To the extent that additional storage,  treatment, or disposal




facilities would have to be modified or would have to be constructed




under this alternative (see Section 8.3.2.4), there would be an in-




crease in fugitive dust and vehicular emissions from such construc-




tion activities.  These emissions would be extremely site dependent




as previously indicated.




     Climate.  Localized impacts to temperatures,  humidities, and




low-level wind patterns could occur in those  areas in which addi-




tional facilities were to be constructed and  operated.  Any such




effects would be expected to be extremely localized.




     8.3.1.5  Water Quality Impacts.  The regulations under this




alternative would have the potential to further decrease adverse




water quality impacts results from generation, storage, transport,




treatment, and disposal of hazardous wastes as compared to the




proposed regulations.




     Many of the potential changes to groundwater  and surface water




impacts would occur in much the same manner as the potential changes




discussed under air quality.  To avoid redundant discussions, such




changes are briefly summarized below rather than discussed in detail,




Following this summary, additional major changes are described.




     Any process modifications designed to further reduce the




quantity and/or types of hazardous wastes generated or to increase




recycling of such wastes would likely lead to changes in water
                                  8-42

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effluents produced by such processes, thus changing the potential for




groundwater and surface water contamination by such effluents.  To




the extent that additional generators were to be brought under the




control of the program through the expanded definition of hazardous




wastes and the elimination of generator exclusions, the potential for




such process modifications would be increased.




     Increases in the quantity of hazardous wastes being transported




subject to the Subtitle C regulations would reduce the potential for




midnight dumping and spills and for resultant impacts to ground-




water and surface water.  However, increases in the average distance




over which wastes are transported would increase the potential for




vehicular accidents and could off-set some of the potential for a




reduction in spills.  Increased transport distances would also result




in increased vehicular emissions and in an increased potential for




oil, grease, and the hydrocarbon and heavy metals contained in




vehicular exhausts to be carried into waterways by run-off.




     The major beneficial impacts to groundwater quality would result




from the elimination of the special waste standards for facilities




dealing with large volume wastes (e.g., phosphate slimes); from the




added requirement that inactive facilities'must comply with the




Section 3001 regulations; from the lower permeability required for




soil liners for landfills and surface impoundments; and from the
                                 8-43

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control of at least an additional 25 million metric tons of poten-




tially hazardous wastes by 1984.




     Under the proposed regulations there is a requirement that there




be no discharge from a hazardous  waste storage, treatment, or




disposal facility to the groundwater, unless it can be demonstrated




that such discharge does not endanger Underground Drinking Water




Sources anywhere outside the facility's property.  (Endangerment




means degradation such that the water exceeds a National Interim




Drinking Water Standard, or that  it becomes necessary to treat the




water more than would otherwise have been necessary for any present




or future use.)  This alternative would have the potential for




further reducing discharges of hazardous wastes to groundwater (and




thus degradation of groundwater)  over and above those reductions




which would occur under the proposed regulations.  This would result




both from further reductions in discharges from permitted facilities




and from an increase in the amount of wastes subject to regulation.




Section 7.1.5 describes the potential for reducing groundwater and




surface water impacts by control  of these additional wastes.




     It should be noted, however, that there could be shifts in the




type of methods used to treat/dispose the additional wastes regulated




under this alternative compared to the unregulated methods used under




the proposed regulations.  As previously discussed, such shifts could




result in localized changes in the release of specific water
                                 8-44

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pollutants under this alternative compared to the proposed re-




gulations .




     A number of incidents cited in Appendix J involve wastes which




might not be controlled under the proposed regulations, but which




would be controlled under this alternative.  For instance, the inci-




dent of groundwater contamination by arsenic, discussed in Section




7.1.5, would escape control under the proposed regulations




due to the small quantities of waste involved (less than 100 kilo-




grams per month) and due to the fact that the waste was generated by




farmers.  This alternative would eliminate both of those exclusions




and would require such wastes to be manifested and sent to a permit-




ted disposal facility.




     8.3.1.6 Public Health Impacts.  Under this alternative, the




potential for providing public health benefits would be increased




relative to that of the proposed regulations.  Section 7.1.6




discusses public health under the proposed regulations.




     In addition to the 40 million metric tons of potentially




hazardous manufacturing waste which would be controlled under the




proposed regulations, another 25 million metric tons would be brought




under control by 1984.  Most of this increase would be attributable




to the additional toxic wastes that would now be considered hazardous




under the Section 3001 regulations.  Part of the increase would also




be due to the inclusion of additional infectious wastes and




radioactive wastes.  Based upon current practices, a large portion of






                                  8-45

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these wastes would have  been transported,  stored, treated, or

disposal in a manner that would not be acceptable under this

alternative.  Due to the inclusion of these wastes, there would be

less potential for the release of air, water, and soil contaminants

and for fires, explosions, spills and other accidents.  As a result,

there would be less of a potential for the occurrence of associated

public health incidents.  Furthermore, the more stringent standards

for hazardous waste management under this  alternative would reduce

the potential for release of contaminants  and for the occurrence of

associated health problems from the management of those wastes

already controlled under the proposed regulations (see Sections

8.3.1.4, 8.3.1.5, and 8.3.2.1).

     Although the characteristics and lists under the proposed

regulations identify many hazardous wastes, a number of other

potentially hazardous wastes would not be  regulated.  In particular,

many potentially toxic wastes which are suspected to be carcinogenic,

mutagenic, or teratogenic substances are not specifically listed and

could be excluded from regulation.

     The following examples illustrate health incidents that occurred

from the management of hazardous wastes that would not likely be

regulated under the proposed regulations,  but which would likely be

regulated under this alternative:

     •  In southern Louisiana, industrial  wastes containing
        hexachlorobenzene (HCB) were transported in uncovered trucks
                                 8-46

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        and left uncovered at  landfills.  In a sampling of residents
        from 29 households situated along the transport route, the
        average plasma  level of HCB was 3.6 ppb, with a high of 23
        ppb.  The range for the landfill workers exposed to HCB was 2
        to 345 ppb.  In comparison, the average plasma HCB level in a
        control group was 0.5  ppb, with a high of 1.8 ppb (Farmer et
        al., 1976).  HCB is considered to be a moderately toxic
        substance.  In  cases where persons were exposed to HCB
        through oral ingestion, over long periods, the health effects
        observed included cases of permanent focal alopecia, corneal
        opacity, atrophic hands, and hypertrichosis with dermal
        lesians.  Recovery usually followed termination of exposure,
        but relapses were known to occur (Gosselin et al., 1977).

     •  As indicated in Section 8.3.1.4, vinyl chloride monomer (VCM)
        is retained in  sludges produced during polyvinyl chloride
        (PVC) processing.  Landfilling of such sludges has resulted
        in release of the VCM.  In 1974 the deaths of four workers in
        the polyvinyl chloride processing industry was believed  to
        be attributable to VCM exposure.  Since that time,
        angiosarcoma of the liver, a rare and fatal tumor, has been
        identified in at least 15 workers in U.S. PVC facilities.  In
        addition, other forms  of cancer, certain nonmalignant liver
        diseases, and acroosteolysis, a unique occupational disease,
        have also been  found in such workers.

     •  In 1972 in Perham, Minnesota, eleven out of 13 persons using
        a well that had been dug on a construction site exhibited
        symptoms of arsenic poisoning.  Five of the employees became
        ill with gastrointestinal symptoms and others exhibited
        symptoms of nausea, vomiting, abdominal pain, and diarrhea.
        Two persons required hospitalization and treatment, including
        one victim who  lost the use of his legs for about six months
        due to severe neuropathy.  After analysis, it was discovered
        that the affected well contained arsenic concentrations of up
        to 21 ppm.  The drinking water standard for arsenic is 0.05
        ppm.  Human deaths have been reported in South Africa due to
        water containing 12 ppm arsenic.  The source of the
        contamination was traced back to the mid-1930"s when about 50
        pounds of excess grasshopper bait containing arsenic trioxide
        was buried by farmers  in the area (see Section 8.3.1.5)
        (State of Minnesota, 1977).

     Due to the small amount of wastes involved in this latter

incident and the fact that the wastes were generated by farmers, this

waste would not be controlled under the proposed regulations.  It

should be noted that nature and persistance of arsenic is a health
                                 8-47

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hazard in even small quantities.   Other waste materials that would be

brought under regulation by this  alternative could also constitute a

threat to public health from disposal of small quantities of the

waste.
     8.3.2  Secondary Impacts.  The major changes in secondary

impacts (relative to the proposed regulations) that could occur as a

result of implementation of this  alternative are discussed in the

following sections.  These changes would result primarily from the

control of an additional 25 million metric tons of potentially

hazardous industrial wastes plus  other hazardous wastes; the

enactment of more stringent environmental requirements with regard to

storage, treatment, and disposal  of hazardous wastes; and further

increases in hazardous waste storage, treatment, and disposal costs.

     8.3.2.1  Physiography and Soil Impacts.  The major change in

impacts to physiography and soils under this alternative would result

from bringing an additional 25 million metric tons of potentially

hazardous manufacturing wastes under regulation annually by 1984,

from the elimination of exclusions for other hazardous waste

generators (e.g., farmers and retailers), and from the enactment of

more stringent regulations for the storage, treatment, and disposal

of  "special wastes' (e.g., utility wastes).

     All such wastes would have to be stored, treated, and disposed

in  accordance with  the Section 3004 regulations.  To the extent that

these wastes would  otherwise have been stored, treated, or disposed

by  methods which would not be acceptable under the Section 3004
                                 8-48

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regulations, the potential for soil contamination would be reduced as

described in Section 7.2.1.

      Disposal of the large volumes of  "special wastes' that could be

brought under control by this alternative could create a significant

demand for low permeability clays.  Such a demand could be especially

significant in areas having a high density of such hazardous waste

generators, such as west-central Florida which produces over 200

million metric tons of phosphate rock overburden and gypsum slimes

from phosphoric acid production (see Section 6.1.2).  Local clay

supplies in such areas may not be sufficient to meet the demand.

Even where sufficient clays are available, their extraction would

result in severe alternation of local topography.

     Increases in the quantity of hazardous wastes being transported

subject to the Subtitle C regulations would reduce the potential for

midnight dumping and spills and for resultant impacts to soils.

However, increases in the average distance over which wastes are

transported would increase the potential for vehicular accidents and

could off-set some of the potential for a reduction in spills.

Increased transport would also result in increased vehicular

emissions and in an increased potential for oil, grease, and the

hydrocarbons and heavy metals contained in such emissions to be

carried onto soils by run-off.

     An example of a soil contamination incident associated with

improper transportation and disposal of a waste that would likely be

regulated under this alternative, but not under the proposed
                                 8-49

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regulations,  occurred in Louisiana in 1972.  This incident, which
resulted in contamination of soil, area residents,  vegetation, and
beef cattle in a 200 square-mile area,  is discussed in Section
8.3.1.4.
     To the extent that additional storage, treatment, or disposal
facilities would have to be constructed to handle the potential
increase in the shortfall of capacity (See Section 8.3.2.4), there
would be a potential for further impacts to soils and physiography.
Additional land and soils could also be disturbed by conjunctive
developments such as construction of roads, power lines, pipelines,
and housing.  However; all these additional land requirements would
be offset to the extent that land would also be required for the
storage, treatment, and disposal of these additional wastes under
current practices.  Potential impacts to soils and physiography from
construction would be essentially the same as those described in
Section 7.2.1.
     8.3.2.2.  Biological Impacts.  Existing vegetation would be
destroyed on the additional lands disturbed by construction and
operation of hazardous waste management facilities and conjunctive
developments.  Present plant succession would cease on such lands.
Following rehabilitation of the site after closure of the facility,
the plant community on the disturbed areas would likely differ in
species composition and diversity.
     These construction and operational activities could also result
in the direct destruction of animal habitat.  Some of this
                                 8-50

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destruction would be permanent; other areas would be impacted only




temporarily and would, over a period of time, recover in value as a




habitat.  However, the habitat and, consequently, the wildlife




species composition following such recovery might be different from




that which existed prior to disturbance of the area.  In addition,




the direct destruction of some wildlife could also result from




activities which excavate, bury, overturn, clear, or grade large




areas of previously undisturbed terrestrial habitat.  While direct




mortality would be rare to big game and other animals which have the




ability to flee, many small animals with limited ranges may be killed




by construction and operation activities.  Operations which cause




additional dewatering of aquatic habitats would result in the death




of fishes, aquatic invertebrates, and amphibians in certain life




stages.  Furthermore, any increase in transport distances would




increase the potential for road kills and, possibly, spills that




could disrupt aquatic ecosystems.




     These potential adverse impacts from land disturbance would,




however, be offset by several potentially beneficial effects of the




regulations under this alternative.  An additional 25 million metric




tons per year of potentially hazardous industrial wastes (plus other




hazardous wastes) would be brought under regulatory control by 1984.




Based on current practices, a large portion of these wastes would




have been stored, transported, treated, dumped, or disposed in a
                                   3-51

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manner that would not be environmentally acceptable under this alter-

native and would have had the potential to create the types of im-

pacts dicussed in Section 7.2.2.  By bringing these additional wastes

under control of the program, the potential for such impacts would be

greatly reduced.  It should be noted, however, that in bringing these

wastes under regulation, there could be shifts in the methods used to

treat dispose the wastes as described in Section 8.3.1.4.  The

potential for beneficial impacts to the biological environment would

be modified to the extent of any such shift.

     The following example illustrates an incident that occurred from

the disposal of a hazardous waste that might not be controlled under

the proposed regulations but which would likely be controlled under

this alternative:

     •  Waste oil containing dioxin was sprayed in horse arenas and
        on an adjacent road in Missouri for dust control.  This
        resulted in the death of six dogs, 12 cats, at least 63
        horses, and a large number of birds, rodents, and other
        animals, there were also 26 abortions and six birth
        abnormalities among horses from this incident (Office of
        Solid Waste Management Programs, 1975b).

     For both the additional wastes to be regulated under this

alternative and for those wastes that would already be regulated

under the proposed regulations, the potential for water quality

impacts, and subsequent adverse impacts to both aquatic ecosystems

and wildlife using contaminated water supplies, would be further re-

duced by the requirements for the use of less permeable liners for
                                 8-52

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landfills and surface impoundments.  The potential for air quality




impacts, and subsequent adverse biological impacts, would be further




reduced as discussed in Section 8.3.1.4.  Furthermore, the potential




for soil contaminant, and subsequent adverse impacts to biological




productivity, would be further decreased as discussed in Section




8.3.2.1.




     The requirement for the preparation of a Supplementary Environ-




mental Analysis (SEA) as part of the permit process would provide an




additional means for mitigating or preventing adverse impacts to the




biological environment.  The SEA would require that the permit appli-




cant analyze the impact of and methods proposed to comply with the




following federal statutes and regulations:  the Endangered Species




Act, the Fish and Wildlife Coordination Act, and the Coastal Zone




Management Act.




     8.3.2.3  Social Impacts.




     Demographic Impacts.  Additional industrial plant closings




or relocations due to the increased costs under this alternative




could lead to additional populations shifts as described in Sec-




tion 7.2.3.1.  In addition, there would be an increased need for




construction workers due to the increased facility modification and




construction under this alternative; there would be an increase in




the number of personnel required for hazardous wastes management




activities due to the additional operational requirements and the
                                 3-53

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increase in wastes  being  regulated;  and  there would be an increase




in the number of personnel  required  to administer and enforce the




regulations due to  the increase in both  the quantity of hazardous




wastes and the number of  generators,  disposers,  and permittees being




regulated.  Additional population shifts could occur in response to




these increased personnel requirements as discussed in Section




7.2.3.1.  Any such  shifts would be expected to be small on a national




scale; however, there could be  localized instances of a relatively




large influx of workers,  particularly for hazardous waste management




facilities located  near very small' towns, or there could be located




instances of a relatively large outflux  of workers, especially in




a case where a plant being  closed constituted the primary source of




employment in an area.




     Based upon a minimum requirement of 500 workers to handle




(store, treat, or dispose)  a million metric tons of waste per year,




it is estimated that at least 32,500 such workers could be required




nationally by 1984; this  would represent over a 60 percent increase




in this requirement compared to the  proposed regulations.  Approxi-




mately 4,200 to 8,100 of  these workers could be required at off-




site facilities; about 24,400 to 28,300  of these workers could be re-




quired at on-site facilities.  This  would represent over a 60 percent




increase at both types of facilities.  To the extent that personnel




would still be required to  manage these  additional wastes even if




not regulated, there would  be fewer  new  workers required nationally.








                                  8-54

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     Social Conditions.   The  increased public health benefits  to be




derived from this alternative would  provide increased social benefits




as discussed in  Section  7.2.3.2.   Reductions in  chronic and acute




health effects would also reduce the social and  economic costs asso-




ciated with such effects, e.g., increased mortality, birth defects,




lowered productivity, lost wages.




     The  increased potential  for population shifts under this  alter-




native would increase the impacts  associated with such shifts.  As




discussed in 7.2.3.2, any large, rapid, population influxes could




cause inflation, strains on the existing infrastructure, social ten-




sions, changes in daily  living patterns, and increased physical and




mental disorders.  Large, rapid, population outfluxes could cause




problems  in maintaining  the existing infrastructure, deflation, addi-




tional unemployment, social stress, changes in daily living patterns,




and increased mental and physical health problems.




     Public opposition to the siting and construction of hazardous




waste management facilities could be further exacerbated by the




increased requirements for such facilities under this alternative.




However, this opposition could be mitigated by the more stringent




environmental requirements under this alternative and by the




requirements for the preparation of a Supplementary Environmental




Analysis as part of the permit review process and for permits to be




renewed every 5 years rather than not at all.
                                 8-55

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     Increases in the necessary construction of hazardous waste




management facilities and in the off-site transport of hazardous




wastes could cause several adverse social effects.  Aesthetic im-




pacts would occur from the construction of new facilities.  Noise




levels would increase both in the vicinity of new facilities and




along access routes to such facilities.  Any increased transport




of hazardous wastes would also increase the potential for vehicular




accidents.  Based upon the methodology and assumptions discussed




in Section 7.2.3.2, it is estimated that there could be about 170




additional vehicular accidents annually in 1984 in the case of 13




percent off-site shipment and about 540 additional vehicular acci-




dents annually in the case of 25 percent off-site shipment.  This




would represent about a 63 percent increase in vehicular accidents




in both cases compared to the proposed regulations.  The requirement




for the preparation of a Supplementary Environmental Analysis as part




of the permit process would provide an additional means under this




alternative for mitigating the above types of adverse impacts.  The




Supplementary Environmental Analysis would require that the permit




applicant describe such factors as proposed access routes; the




promixity of the proposed site to populations centers; and the




methods to be used to minimize noise, dust, and odors associated with




the construction and operation of the proposed facility.




     The requirement that inactive sites be required to comply with




the Section 3004 requirements cause adverse social and economic







                                  8-56

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impacts.  People who own property which contains an inactive hazard-

ous waste disposal site could be required to comply with the Section

3004 regulations even if they brought the property after all disposal

activities had ceased at the site and were unaware of such former

activities.  The need to comply with the Subtitle C regulations in

such cases would undoubtedly be tested in the courts.

     8.3.2.4  Hazardous Waste Management Facility Capacity.

     Process Capacity.  Based upon the methodology and assumptions

described in Section 7.2.4.1, it is estimated that about 8.6 million

metric tons of hazardous industrial wastes could be shipped off-site

for treatment/disposal in 1980 and that between 8.5 and 16.3 million

metric tons could be shipped off-site in 1984.  This would represent

an increase of approximately 3.3 million metric tons of regulated

wastes required to be sent to permitted off-site facilities in 1980

and an increase of between 3.3 and 6.3 million metric tons of regu-

lated wastes required to be sent to permitted off-site facilities in

1984.

     Based upon the estimate 6.2 million metric tons of environmen-

tally adequate off-site capacity that could be utilized in 1980,

there could be a shortfall of 2.7 million metric tons of off-site

capacity in 1980.*  Without any growth in environmentally adequate
*A11 estimates of shortfall are based upon a 90 percent utilization
 rate for the additional capacity required.  The indicated shortfall
 is thus the difference between the quantity of wastes requiring
 treatment disposal and the utilizable capacity, all divided by 0.9.
                                 3-57

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off-site capacity between 1977 and 1980,  this shortfall could be 4.2




million metric tons. It is estimated in Section 7.2.4.1 that under




the proposed regulations there could be sufficient off-site capacity




for hazardous industrial wastes.   Based upon a utilizable facility




capacity of 60,000 metric tons per year,  approximately 45 additional




permitted off-site facilities could be required in 1980 in the former




case and approximately 70 additional permitted off-site facilities




could be required in the latter case.




     Based upon the estimated 7.7 million metric tons of environmen-




tally adequate off-site capacity that could be utilized in 1984, in




the case of 13 percent off-site shipment  there could be a shortfall




of 0.9 million metric tons of environmental adequate off-site




capacity in 1984.  Without any growth in environmentally adequate




off-site capacity between 1977 and 1984,  this shortfall could be 3.2




million metric tons.  It is estimated in Section 7.2.4.1 that there




could be sufficient off-site capacity for the treatment disposal of




hazardous industrial wastes under the proposed regulations in both




instances.  Since less off-site capacity  would be required in 1984




than in 1980 in the case of 13 percent off-site shipment, no




additional permitted off-site facilities  would be required in 1984.




     In the case of 25 percent off-site shipment, there could be




a shortfall of 9.6 million metric tons of environmentally adequate




off-site capacity in 1984.  Without any growth in environmentally




adequate off-site capacity between 1977 and 1984, this shortfall
                                 8-58

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off-site capacity 11.9 million metric tons.  It is estimated in


Section 7.2.4.1 that under the proposed regulations there could be a


shortfall of 2.6 million metric tons in the former case and a


shortfall of 4.9 million metric tons in the latter case.


Approximately 160 additional permitted off-site facilities could be


required in 1984 in the former case and approximately 200 additional


permitted off-site facilities in the latter case.  Based upon the


estimated shortfall under the proposed regulations, only 115 of the


necessary permitted facilities would


be attributable to this alternative in the former case and only 120


would be attributable to this alternative in the latter case.


     Data are not available to estimate potential shortfalls in envi-


ronmentally adequate on-site process capacity.  Industrial generators


could send 46.7 million metric tons of hazardous wastes to permitted


on-site treatment/disposal facilities in 1980 and between 46.8 and


54.6 million metric tons of hazardous wastes to permitted on-site


facilities in 1984.*  This would represent an increase of approxi-


mately 18.0 million metric tons of regulated wastes required to be


sent to permitted on-site facilities in 1980 and an increase of be-


tween 18.0 and 21.0 million metric tons of regulated wastes required


to be sent to permitted on-site facilities in 1984.
*The remainder of the hazardous waste would be recycled or sent to
 resource recovery operations, both on-site and off-site (see Table

 5-10).
                                 8-59

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It should noted that more stringent treatment/disposal requirements

under this alternative would likely result in a decrease in the

existing on-site capacity.   Any such decrease would further increase

any potential for a shortfall in on-site capacity.

     Section 7.2.4.1 discusses other factors  that could affect the

size of the potential shortfall in both on-site and off-site process

capacity.  In addition to those factors, the  potentially large quan-

tity of 'special wastes'  that could be hazardous would significantly

exacerbate any shortfall.  Also, the more stingent  requirement under

this alternative could reduce the number of sites at which facilities

could be located.

     Physical Capacity.  Based upon the methodology and assumptions

discussed in Section 7.2.4.2, relative to the proposed regulations

there could be a further decrease of approximately 1.3 million metric

tons in the total hazardous industrial wastes sent  off-site during

the period from 1980 through 1984, assuming 13 percent shipment off-

site in 1984, and there could be a further increase of 6.1 million

metric tons in the total hazardous industrial wastes sent off-site

during this period, assuming 25 percent shipment off-site in 1984.*

     Up to 250 to 500 fewer acres could thus  be committed to off-

site landfilling during this period in the case of 13 percent
*In this estimate, it is assumed that under the proposed regulations
 there would be 15 percent off-site shipment for those hazardous
 wastes that would not be regulated under the proposed regulations
 but which would be regulated under this alternative.
                                  8-60

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off-site shipment and up to 1,200 to 2,400 additional acres could be
committed to off-site landfilling during this period in the case of
25 percent off-site shipment.  In the former case, after 1984 there
could be 100 to 200 fewer acres required off-site annually compared
to total requirements under the proposed regulations.   In the lat-
ter case, after 1984 there could be 500 to 1,000 additional acres
required off-site annually compared to the total requirements under
the proposed regulations.  In all instances there could be commen-
surate change in on-site land requirements.
     For purposes of comparison, based upon an average, secure,  com-
mercial landfill size of 270 acres (U.S. Environmental Protection
Agency, Office of Toxic Substances, 1977), these land requirements
would be equivalent to siting one to two fewer off-site secure
landfills by the end of 1984 in the case of 13 percent off-site
shipment.  In this case, the equivalent of less than one fewer
off-site secure landfill could have to be sited annually after 1984.
The land requirements would be equivalent to siting five to nine
additional off-site secure landfills by the end of 1984 in the case
of 25 percent off-site shipment.  In this case, the equivalent of two
to four additional off-site landfills could have to be sited annually
after 1984.
     8.3.2.5  Land Use Impacts.  More total land, off-site plus
on-site, would be required under this alternative than under the
proposed regulations.  This land would be required both for the
construction of the permitted facilities necessary for the storage,
                                  8-61

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treatment,  and disposal of the additional hazardous wastes regulated

under this  alternative and for such conjunctive developments as

construction of roads, power lines, and pipelines.  However, as

indicated in Section 8.3.2.4,  in the case of 13 percent off-site

shipment there would be fewer  regulated hazardous industrial wastes

sent off-site by 1984 under this alternative than there would be

total hazardous wastes sent off-site under the proposal regulations.*

Thus, while more total land would be required under this alternative,

in the case of 13 percent off-site shipment there could be less

off-site land use and more on-site land use.  In the case of 25

percent off-site shipment, there would be more regulated industrial

wastes sent off-site by 1984 under this alternative than there would

be total hazardous wastes sent off-site under the proposed

regulations.  Thus, there could be more off-site land use and less

on-site land use in this case.  Estimates of potential changes in

off-site land requirements for landfills (and commensurate changes in

on-site land requirements) are presented in Section 8.3.2.4.

     In should be noted that while shifts to on-site land use could

reduce off-site land requirements in the short term, such shifts

could also accelerate the exhaustion of the relatively limited on-

site physical capacity and could result in increased pressures for
*The total hazardous wastes consist of those wastes regulated under
 the proposed regulations plus the additional wastes that would not
 be regulated under the proposed regulations but which would be re-
 gulated under this alternative.
                                 8-62

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off-site facilities in the long term.  However, additional increases




in resource conservation and recovery and in treatment practices




leading to volume reduction (e.g. , incineration) under this alterna-




tive would also provide a greater potential for reducing total land




requirements, both on-site and off-site, in the long term.




     Existing land uses would cease, either permanently or temporar-




ily, on all land converted to hazardous waste management uses.  Some




agricultural, grazing, forest, recreational, and other lands could be




removed from their existing uses.  Following closure of the hazardous




waste management facility and any rehabilitation of the site accord-




ing to the closure and long-term care plans, the land would be avail-




able for new or, in some cases, previously existing uses.  Sites at




which hazardous wastes have been disposed would be precluded follow-




ing post-close-out care from certain future uses (such as residen-




tial, recreational and grazing uses, and any activities requiring




excavation).  To the extent that the regulations under this alter-




native would prevent other lands from being contaminated by improper




dumping, treatment, or disposal of the hazardous wastes not regulated




under the proposed regulations, there would be off-setting land use




benefits.  Section 7.2.5 describes the types of land use benefits




that could occur.




     8.3.2.6  Water Use Impacts.  As previously discussed, the poten-




tial for the degradation of groundwater and surface water would be
                                  8-63

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further reduced under this alternative.   To the extent that degrada-




tion of water quality would have resulted in a decreased supply of




surface water or groundwater being available to or all consumers in




the water use area,  there would be an additional supply of ground-




water or surface water potentially available to such consumers and




fewer restrictions on the productive use of such surface water and




groundwater supplies.




     The additional  on-site and off-site permitted hazardous waste




management facilities that could be required would be additional con-




sumers of the available water supply.  This water could be required




for such purposes as dust control, soil  compaction, biological treat-




ment, wet scrubbers  for incinerators, and site rehabilitation.  This




additional water requirement would be reduced to the extent that




water would otherwise have been consumed in the management of the




additional wastes now regulated under this alternative.




     8.3.2.7  Resource Conservation and  Recovery.  The major changes




in resource conservation and recovery would result from bringing an




additional 25 million metric tons of hazardous manufacturing wastes




under the Subtitle C regulations annually by 1984 and from the




further increased hazardous waste generation, transportation, stor-




age, treatment, and disposals costs associated with the more strin-




gent requirements under this alternative.  As discussed in Section




7.2.7, these changes would provide increased incentives for gen-




erators to modify processes so as to enable increased recycling of






                                  8-64

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hazardous waste as process feedstocks, to reduce the quantities of




hazardous wastes generated by specific processes, or to change the




nature of wastes produced.  In addition the requirement that the




permitting authority could require that wastes which could be re-




coverable in the foreseeable future would have to be land disposed




in a segregated manner would increase the potential for future re-




source recovery from such wastes.  Chapter 5 presents examples of




the potential for increased resource recovery from and recycling




of hazardous wastes.




     8.3.2.8  Energy Use.  Energy use would be impacted under this




alternative by changes in facility construction, facility operation,




hazardous waste transport, and resource conservation and recovery.




The additional facility modification and construction that would be




necessary under this alternative would result in increased energy




use.  The requirement for decreased permeability of landfill and




surface impoundment liners and for reduced non-point source air




emissions from these facilities would increase the energy use




required for construction of such facilities.




     There would also be increased energy use associated with re-




quired changes in facility operation and closure.  Management of the




additional 25 million metric tons of hazardous industrial wastes re-




gulated under this alternative would require increased energy use as




discussed in Section 7.2.8.  The additional 20-year period over which




post close-out care could be required would increase the energy use







                                8-65

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associated with such care.   Additional energy could also be required




for control equipment used  to insure that the non-point source air




emission standard was not violated.




     Previously discussed changes in resource recovery would lead to




other changes in energy use.  While  any increase in resource recovery




would likely require the initial input of additional energy, there




could be a net savings in energy from recovery operations as dis-




cussed in Section 7.2.8.




     The changes in energy  use from  the additional transport of haz-




ardous wastes would depend  upon such factors as shifts in the por-




tion of wastes managed on-site and off-site and changes in transport




distances.  Based upon the  methodology and assumptions described in




Section 7.2.8, Table 8-6 contains estimates of the magnitude of the




potential change in energy  use (compared to that under the proposed




regulations) that could occur annually from changes in transport




distances and shifts in off-site and on-site treatment disposal.




The estimated change in energy use under this alternative ranges




from an annual decrease equivalent to approximately 10,000 barrels of




crude oil for a 100 mile round-trip  distance with 13 percent off-site




treatment/disposal to an annual increase equivalent to approximately




1.4 million barrels of crude oil for a 1,000-mile round-trip distance




with 25 percent off-site treatment/disposal.




     8.3.2.9  Impacts to Special Interest Points.  To the extent that




unregulated treatment/disposal of the additional wastes brought under






                                 8-66

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                                             TABLE 8-6

                    ESTIMATED CHANGE IN FUEL CONSUMPTION IN 1984 FROM TRANSPORT OF
                    ADDITIONAL HAZARDOUS INDUSTRIAL WASTES UNDER SUBTITLE C REGULATIONS
00

Wastes Round- trip
transported distance
off-site (miles)
13 percent 100
200
500
1,000
25 percent 100
200
500
1,000
Change in fuel consumption
(million gallons)
-0.5
3
11
26
2
8
23
54
Crude oil
equivalent *
(1,000 barrels)
-10
60
290
660
60
200
580
1,400

    *Assumes  95  percent  efficiency in producing  diesel  fuel  from crude  oil.

-------
control by this alternative would have disturbed, destroyed, or

intruded upon special interest points, there would be a commensurate

reduction in such adverse effects as discussed in Section 7.2.9.

However, the additional lands, especially off-site lands, that

would be disturbed by the increased requirements for facility

construction and associated conjunctive developments under this

alternative would increase the potential for the disturbance

and/or destruction of such special interest points as sites of

aesthetic, archaeological, historical, paleontogical, or recreational

value.

     The  requirement for the preparation of a Supplementary Environ-

mental Analysis  as part of the permit process would  provide an ad-

ditional  means  for mitigating such adverse  impacts.  The SEA would

require  the  permit applicant to  analyze the impact of and methods

proposed  to  comply within  the following Federal  statutes and pub-

 lished  regulations,  if  applicable:  The Endangered Species Act;  The

National  Historic Preservation Act; The Historic Sites,  Buildings,

and Antiquities Act; The Fish and Wildlife  Coordination  Act; and The

 Coastal  Zone Management Act.

 8.4  Potential Change  in  Impacts Resulting  from the  Lesser  Degree of
      Public  Health and  Environmental  Protection Alternative

      This section  discusses  the  potential  changes in impacts

 (relative to those of  the  proposed  regulations) that could  occur as a
                                 8-68

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result of promulgation of the regulations contained in the Lesser

Degree of Public Health and Environmental Protection Alternative.  To

avoid considerable duplication in the presentation, potential impacts

that would not be changed under this alternative are not repeated.

Only major changes in potential impacts are discussed.

     8.4.1  Primary Impacts.  The major changes to primary impacts

that could occur as a result of implementation of this alternative

are discussed in the following sections:

     •  Hazardous Wastes to be Regulated;

     •  Changes to Generation, Transportation, Storage,
        Treatment, and Disposal Practices and Procedures;

     •  Administrative Changes;

     •  Air Impacts;

     •  Water Impacts;

     •  Public Health Impacts.

     8.4.1.1  Hazardous Waste to be Regulated.  Under this

alternative, the toxicity characteristic and wastes whose listing is

based solely on toxicity or Administrator's judgment (AD) would be

removed from the Section 3001 regulations identifying hazardous

wastes and 'special wastes'  (e.g., utility wastes and oil drilling

muds and brines) would be specifically excluded from regulation.

Additionally, this alternative would increase the generator limit

from 100 kilograms to 1,000 kilograms per month.  EPA staff estimates

are that eliminating the toxicity criteria and the wastes whose
                                8-69

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listing is based upon toxicity would result in the exclusion of about




40 percent of the manufacturing wastes which would be regulated under




the proposed regulations.  Further, the 'special wastes' and some




portion of the other large volume wastes discussed in Section 6.1.2




(e.g., utility fly ash and toxic dredge materials) which may have




been included under the proposed regulations, would be excluded,




either directly (i.e., fly ash) or through elimination of the




toxicity criteria (i.e., dredge materials).




     Based upon the procedures described in Chapter 6 and 7 and




Appendices H and I, it is estimated that approximately 20 and 24




million metric tons of hazardous manufacturing wastes could be




controlled under this alternative in 1980 and 1984, respectively.




These estimates include an adjustment for wastes that would not be




regulated due to the change in the generator limit.  Table 8-7 shows




the estimated quantity of hazardous manufacturing wastes and the




number of generating establishments that could be excluded from




regulation based upon a generator limit of 1,000 kilograms per




month (due to the reduction in wastes considered hazardous under




this alternative, some of these generators would also be excluded




even without the increase in the generator limit).  In addition, an




unknown portion of the potentially hazardous non-manufacturing wastes




discussed in Section 7.1.1 would also be excluded from regula-




tion.
                                 8-70

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                                              TABLE 8-7

                      ESTIMATED QUANTITY OF HAZARDOUS MANUFACTURING WASTES AND
                       NUMBER OF ESTABLISHMENTS EXCLUDED FROM REGULATION AT A
                          GENERATOR LIMIT OF 1,000 KILOGRAMS PER MONTR
00

EPA
Region
I
II
III
IV
V
VI
VII
VIII
IX
X
National
total
Number of
manufacturing
establishments
excluded
13,300
34,200
16,100
28,300
35,500
14,800
8,300
4,400
23,900
8,000
186,500
Percent of
total manufacturing
establishments
excluded
57
65
57
62
52
61
58
68
63
70
60
Hazardous
manufacturing
wastes excluded
(1000 itietric
tons /year)
28
68
32
50
70
29
17
10
50
17
371
Percent of total
hazardous
manufacturing
wastes excluded
1
1
<1
<1
<1
<1
<1
2
2
2
<;L

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      There could thus be a decrease of at least 14 and 16 million




metric tons in potentially hazardous wastes brought under regulatory




control in 1980 and 1984, respectively, as compared to the proposed




regulations.  This would represent approximately a 40 percent de-




crease in regulated hazardous industrial wastes in both years.  The




hazardous wastes controlled under this alternative would represent




about 6 and 7 percent, respectively, of the total annual industrial




solid waste stream (hazardous and non-hazardous) currently estimated




to be generated.




     8.4.1.2  Changes to Generation, Transport, Storage, Treatment,




and Disposal Practices.  Fewer changes to generation, transport,




storage, treatment, and disposal practices would be likely to occur




under this alternative due to the lesser amount of wastes being




regulated; due to the enactment of less stringent environmental




requirements; due to resultant reductions in storage, treatment, and




disposal costs; and due to the imposition of fewer procedural and




operational requirements.




     Generation.  Under this alternative, fewer generators would be




required to comply with the generator regulations.  Those generators




specifically excluded from regulation under this alternative include:




those whose generate between 100 and 1,000 kilogram per month of any




identified hazardous wastes; those who store hazardous wastes on-site




for 90 days to 1 year prior to off-site disposal; those who generate
                                 8-72

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only 'special wastes'; and those who generate only wastes identified




as toxic under the proposed characteristics and listings.  Section




8.4.1.3 presents estimates of the number of generators to be excluded




from regulation.  These generators would not be required to change




their existing practices and procedures, as is indicated in Section




7.1.4.1, with regard to manifesting, reporting, recordkeeping, con-




tainerization, and labeling.  In addition, those generators who would




still be regulated under this alternative would be subject to reduced




manifesting and reporting requirements, as indicated in Table 4-3.




     Furthermore, due to likely reductions under this alternative




both in hazardous waste generation, transport, storage, treatment,




and disposal costs relative to those of the proposal regulations and




in the number of regulated generators, there would be a lesser incen-




tive for generators to modify their processes so as to reduce and/or




change the types and amounts of hazardous wastes generated by the




process and to enable the increased recycling of hazardous wastes as




process feedstocks.




     Transport.  Due to the lesser quantity of wastes subject to the




generator regulations, fewer transporters would likely have to comply




with the transports regulations discussed in Section 7.1.2.2.  As a




result there would likely be increased instances of midnight dumping




and of spills from the transport of these additional wastes.




Elimination of the requirement that generators report on hazardous




wastes not received at the designated facility would further increase






                                  8-73

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the potential for midnight dumping.  Any decreases in the average




distance -over which hazardous wastes a^re transported -under this




alternative could lead to a decrease in vehicular accidents.  This




would off-set some of the potential for an increase in spills.




     The average distance over which hazardous wastes are transported




would be likely to decrease due to several factors.  The less




stringent treatment and disposal requirements under this alternative




would likely increase both, the amount of existing on-site and




off-site treatment/disposal capacity that could be permitted and the




number of sites acceptable for construction of new facilities.  Any




such increases in available facilities and sites would potentially




lead to reduced transport distances.  Furthermore, increases in




permittable on-site treatment/disposal capacity could result in fewer




wastes being sent off-site for treatment/disposal.  Decreases in




treatment/ disposal costs could also reduce the distance over which




wastes could be economically transported for resource recovery




purposes.  Elimination of the requirement that consolidated wastes




not requiring a manifest must be delivered to a permitted facility




would likely decrease the average distance such wastes would be




transported.  However, any reduction in on-site resource conservation




and recovery could increase the quantity of wastes sent off-site.




     The replacement of the proposed Section 3002 manifest require-




ments with a new manifest requirement that all shipments (interstate
                                  8-74

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and intrastate) must be accompanied by shipping paper/bill of lading




which designates delivery to a permitted storage, treatment, or dis-




posal facility and which meets the requirements of the DOT Hazardous




Materials Regulations would further reduce changes to existing trans-




port practices.  The use of such delivery documents is now required




under Interstate Commerce Commission (ICC) regulations for transport-




ers engaged in interstate commerce and under DOT regulations for the




interstate transport of hazardous materials; as previously indicated,




some states have also applied the DOT regulations to intrastate




shipments of hazardous materials.  Thus, except for the requirements




that the shipping paper/bill of lading must designate delivery to a




permitted facility, those transporters now required to prepare




shipping papers/bills of lading would not have to modify their




existing practices.  However, those transporters who make intrastate




shipments or who do not transport hazardous wastes that are also




identified as DOT hazardous materials would still have to modify




their practices.  Similarly, the reduction in required recordkeeping




times would not likely affect those transporters currently required




to prepare shipping papers/ bills of lading since, as indicated in




Appendix E, most such transporters keep such records for at least 3




years due to various existing requirements.




     The elimination of the emergency spill requirements for notifi-




cation and clean up would also not affect transporters carrying in-




terstate and some intrastate shipments of hazardous wastes that are






                                   8-75

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also identified as DOT hazardous materials.   Such transporters are




currently required to report and clean up such spills.   Also, any




spill by any transporter that could threaten navigable  waters or




which are into or upon navigable waters,  adjoining shorelines, or




contiguous zones, or which may affect applicable natural resources




would still have to be reported and cleaned  up under Section 311 of




the Federal Water Pollution Control Act.




     Storage.  Due to the lesser number of generators and quantities




of wastes regulated under this alternative,  it is likely that fewer




storage facilities would have to comply with the storage regulations




discussed in Section 7.1.2.3.  In addition,  the increase in the per-




mit exclusion from 90 days to one year for generators who store on-




site prior to off-site disposal would further reduce the number of




generators subject to the storage regulations.




     As a result, fewer storage facilities would be required to be




modified or to be closed.  Existing storages practices  would not




have to be changed at facilities excluded from regulation under this




alternative.  In addition, those storage facilities that would still




be regulated under this alternative would be subject to reduced




construction, operational, and closure requirements as  indicated in




Table 4-3 and would have to make fewer changes to existing practices.




     Treatment/Disposal.  Due to the lesser  number of generators and




quantities of wastes regulated under this alternative,  it is likely




that fewer treatment/disposal facilities would have to  comply with







                                  8-76

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the treatment/disposal regulations discussed in Section 7.1.2.4.




As a result, fewer of these facilities would be closed because they




could not comply with the regulations or could not be economically




modified.  In addition, fewer regulated facilities would be required




to be modified; in those cases requiring modification, the changes




would likely be less extensive.  Regulated facilities would have to




make fewer changes in their existing operation and closure practices.




     Due to the less stringent requirements, the associated reduced




costs, the associated reductions in costs, and fewer wastes and




generators being regulated, there would also be a lesser potential




for treatment of wastes for such purposes as volume reduction, energy




recovery, and resource recovery.  Furthermore, to the extent that




fewer existing on-site facilities were closed and fewer wastes and




generators were regulated, there would be a potential for fewer




wastes to be sent off-site for treatment/disposal.  However,




reductions in on-site resource conservation and recovery practices,




as described above, could off-set such a change in wastes sent




off-site.




     8.4.1.3  Administrative Changes.  Several changes in the admin-




istration of the hazardous waste management program would result from




promulgation of the regulations under this alternative.  These




regulations would affect:




     •  State administration of the program;




     •  Overlapping Federal and state programs;




     •  Number of generators required to comply with the regulations;



                                 8-77

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     •  Number of transporters required to comply with the
        regulations;

     •  Number of storers,  treaters,  and disposers required
        to obtain permits;

     •  Paperwork requirements.

     State Administration of the Program.  Several factors would

increase the potential for states to  apply for full, partial, or

interim authorization under this alternative.  Elimination of all

restrictions on granting of interim authorization, except the

Memorandum of Understanding, would make every state eligible to be

granted interim authorization.  The elimination of restrictions on

granting full or partial authorization to states with more stringent

standards would also enable additional states, including the six with

importation bans identified in Section 7.1.1.3, to qualify for full

or partial authorization.  In addition, reductions in the quantities

and types of wastes considered hazardous and the raising of the

generator limit would decrease the number of potential generators,

transporters, storers, treaters and disposers that the state would

have to regulate.  This, plus the reductions in reporting require-

ments, would lead to further reductions for administrative and

manpower requirements for authorized  states and could increase the

willingness of states to apply for authorization.

     However, the elimination of the toxicity characteristic could

off-set any potential for increased state authorization.  If enough
                                 8-78

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states felt that the regulations were inadequate without the




inclusion of toxic wastes, there could be an overall reduction




in authorized states under this alternative.




     Overlapping Federal and State Programs.  Since Subtitle C




prohibits any state from enacting less stringent regulations than




those in the Federal program, the potential for overlapping Federal




and state programs would be increased under this alternative.  The




less stringent standards and reduced amount of hazardous waste con-




trolled under this alternative would increase the potential benefits




to, and thus the likelihood of, a state enacting a more stringent,




independent, hazardous waste program.  It is not possible at this




time to estimate the number of states, if any- that would wish to




have independent programs in addition to the Federal program under




this alternative.




     Number of Generators Required to Comply With the Regulations.




As indicated in Section 8.4.1.2, there would be an increase in the




number of generators required to comply with the regulations.  Under




the proposed regulation, 430,000 to 460,000 generators are identified




as potentially having to comply with the regulations (see Section




7.1.3.3).




     The increase in the generator limit could result in approximate-




ly 105,000 additional manufacturing generators being excluded from




compliance with the regulations (see Tables 7-2 and 8-7).  The total




number of manufacturing generators excluded would represent about 60







                                8-79

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percent of all manufacturing generators; however, they are estimated




to generate less than 1 percent of the total hazardous manufacturing




wastes.  Some additional manufacturing generators could also be




excluded by the elimination of the toxicity characteristic and




listings, however data are not sufficient to estimate the number of




additional exclusions.  EPA staff estimates are that most, if not




all, of  the 210,000 automotive service stations and 5,800 research




facilities that could to be potential generators under the proposed




regulations could be excluded by the increased generator limit under




this alternative.  An indeterminable number of other generators could




also be  excluded.  Thus, on the order of 110,000 to 140,000




generators within the categories identified could be required to




comply with  the regulations under this alternative.  This would




represent  approxi-mately a 70 percent reduction in the number of




generators being regulated.




     Number  of  Transporters Required to  Comply with the  Regulations.




The decreased amounts  of regulated hazardous wastes that would poten-




tially be transported  off-site would  likely result in a  decrease  in




 the number of transporters  carrying hazardous wastes.  However,  since




 the number of such  transporters under the  proposed regulations  is  not




known, it is not possible  to  estimate the  decrease that  could occur




under  this alternative.




      Number  of Storers,  Treaters,  and Disposers  Required to Obtain




 Permits.  Since there are  no  permit  exclusions  under  the proposed







                                8-80

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regulations for storage, treatment, or disposal facilities that




handle only small quantities of hazardous wastes, all facilities




storing, treating, or disposing hazardous wastes would be required to




obtain a permit under the proposed regulation, with the exception of




generators who store for less than 90 days prior to off-site




transport.  Thus, with one additional exception, only those




facilities that handle wastes which are classified as hazardous under




this alternative, would be excluded from the requirements to obtain a




permit under this alternative.  The exception is that generators who




store hazardous wastes between 91 days and one year would also be




excluded under this alternative.  Data are not available to estimate




the reduction in potential permittees under this alternative.




     Paperwork Requirements.  Based upon the estimated number of off-




site shipments (see Section 8.4.2.4), the industrial generators could




have to prepare between 200,000 and 420,000 shipping papers/bills of




lading annually by 1984.  This would represent about a 40 percent




decrease in the number prepared under the proposed regulations.  The




aggregated generators, transporters, and hazardous waste management




facility owner/operators could each have to keep between 200,000 and




420,000 shipping papers/bills of lading in storage on an annual




basis.  This would represent about an 80 percent decrease in record-




keeping requirements as compared to the proposed regulations.  This




decrease in both the number of new manifests prepared and stored




under this alternative would be even greater to the extent that







                                 8-81

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generators and transporters were able to use and store shipping




papers/bills of lading that would also have to be prepared and stored




under other existing regulations (see Section 8.4.1.2).




     The 110,000 to 140,000 identified generators would have to




prepare 110,000 to 140,000 reports on an annual basis; this would




represent about a 70 percent decrease in such annual reporting.  As




indicated in Section 7.1.3.6, most potential permittees would be




on-site facilities and would not have to prepare additional annual




reports based on the manifests.  Transporters would not have to




prepare any spill reports under this alternative as compared to




between 140 and 270 under the proposed regulations; however, some




transporters would have to prepare spill reports to satisfy require-




ments under other existing laws (see Section 8.4.1.2).  The reduction




in the number of permittees is not determinable, but is expected to




be small as previously indicated.  Due to the relatively small number




of off-site permittees (see Table 7-7) and due to the potentially




small decrease in such permittees, any reduction in the number of




annual reports based upon manifested wastes to be prepared by such




permittee should also be small.  There could, however, be a large




decrease in the number of monitoring reports prepared by permittees




under this alternative.  Permittees would have to prepare such




reports annually rather than quarterly.  There could be up to 117,000




such monitoring reports under the proposed regulations.  Using the




number of potential permittees from the proposed regulations as an







                                  8-82

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upper limit of the number under this alternative, there could be up




to 29,000 monitoring reports prepared annually under this alternative




— a reduction of at least 75 percent.  Overall there could be a




total of 139,000 to 169,000 generator and permittee reports prepared




annually under this alternative — a reduction of over 70 percent.




     There would also be a slight decrease in the number of permit




applications prepared.  Again using the number of potential




permittees identified under the proposed regulations as an upper




limit, identified generators and permittees could have to file at




most between 139,000 and 169,000 notifications under Section 3010—




a reduction of at least 60 percent.  The likely reduction in the




number of regulated transportees would also reduce the number of




transporters who would be required to file notifications under




Section 3010.




     8.4.1.4  Air Impacts.




     Air Quality.  The regulations under this alternative would have




the potential to cause fewer changes in air emissions resulting from




the generation, transport, storage, treatment, and disposal of




hazardous wastes, as compared to the proposed regulations.




     Generation.  As previously discussed, the proposed regulations




would not have a direct effect on potential air emissions resulting




from activities and processes generating hazardous wastes.  However,




to the extent that the requirements under this alternative would




cause fewer changes in the economics of storage, treatment, or
                                 8-83

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disposal relative to those of the proposed regulations, there would

be less of a potential for generators to make process modifications

designed to increase hazardous waste recycling and to reduce the quan-

tity and/or types of hazardous wastes generated; any such reductions

in process modifications under this alternative would likely lead to

fewer changes in air emissions released by processes generating

hazardous waste.  Furthermore, with fewer generators being brought

under control of the program, the potential for such process

modifications and resultant changes in air emissions would be further

decreased.

     Transport.  As indicated in Section 7.1.4.1, there are three

major ways air contaminants are released by the transport of hazard-

ous wastes:

     •  Through fugitive emissions resulting from improperly covered,
        sealed, or containerized wastes;

     •  Through emissions resulting from spills or other accidental
        releases of hazardous wastes;

     •  Through emissions resulting from the operation of the trans-
        port vehicle.

     As discussed below, this alternative would affect, to varying

degrees, the potential for the release of air emisions from each of

these sources.

     By 1984, approximately 16 million metric tons of potentially

hazardous industrial wastes (plus other hazardous wastes) would be

removed annually from regulations under this alternative as compared

to the proposed regulations.  As a result, transport of these wastes

                                 8-84

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would not have to be in accordance with the Section 3002 contain-

erization requirements or the Section 3003 transport requirements

unless the wastes were also identified as hazardous materials under

the DOT Hazardous Materials Transport Act.*  Thus, to the extent that

these wastes would be containerized or transported using methods not

acceptable under the proposed regulations, the potential for the

release of fugitive emissions by such transport and from any

resultant spills or explosions would be increased under this

alternative.  Section 7.1.4.1 discusses the potential for the release

of air emissions from unregulated transport practices.  Furthermore,

the elimination, except as previously noted, of the requirement that

transporters need to report and clean up spills would further

increase the potential for air contaminants to be released from such

spills under this alternative.  The elimination of spill information

from the manifest could further increase the time for spill clean up

and thus increase the potential for the release of air contaminants.

     Both the total quantity of regulated hazardous wastes being

transported and the average distance over which such wastes are

transported could decrease under this alternative, as previously

indicated.  Any such reductions would lead to the release of fewer

vehicular emissions and to a reduced potential for vehicular

accidents to occur and to release air emissions.  However, less
*In such a case, for all interstate transport and some intrastate
 transport, these wastes would be subject to essentially the same
 containerization and transport requirements as under the proposed
 regulations.

                                 8-85

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transport of hazardous  waste in accordance with the regulations would




increase the potential  for spills  and explosions from improper




transport and from resultant vehicular accidents.   This would off-set




some of the potential for fewer vehicular accidents to result from




reduced transport distances.  The  changes in both  the vehicular




emissions and emissions resulting  from accidents would be dependent




upon such factors as the decrease  in travel distances, the change in




portion of hazardous wastes transported off-site,  and the decrease in




the amount of regulated wastes being transported.




     Using the methodology and assumptions described in Section




7.1.4.1, the potential  change in vehicular air emissions resulting




from the reduced transport of regulated hazardous  industrial waste




has been estimated for  four possible transport distances for both 13




and 25 percent off-site shipment of hazardous wastes in 1984.  Table




8-8 shows the change in vehicular  emissions relative to those of the




proposed regulations (see Table 7-8).  For example, for a 100-mile




round-trip distance with 13 percent off-site treatment/disposal,




there could be an increase in each vehicular air emission equal to




about 40 percent of that which could occur under the proposed




regulations.  For a 1,000-mile round-trip distance with 25 percent




off-site treatment/ disposal, there could be a decrease in each air




emission equal to about 40 percent of that which could occur under




the proposed regulations.  In the former case, the increase in each




air emission would be less than one one-thousandth of a percent of






                                8-86

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                         TABLE 8-8

ESTIMATED CHANGE IN VEHICULAR EMISSIONS IN 1984 FROM TRANSPORT
OF LESS HAZARDOUS INDUSTRIAL WASTES UNDER SUBTITLE C REGULATIONS

Change in emissions (metric tons)
Wastes Round- trip
transported distance
off-site (miles)
13 percent 100
Oo
23 200
500
1,000
25 percent 100
200
500
1,000
Carbon monoxide
+ 60
-350
-1,600
-3,600
-310
-1,100
-3,200
-7,400
Hydrocarbons
+ 10
-55
-250
-580
-50
-180
-510
-1,200
Nitrogen
oxides
+45
-250
-1,200
-2,700
-230
-800
-2,300
-5,400
Particulates
+ 3
-15
-70
-170
-15
-50
-140
-340
Sulfur
oxides
+6
-35
-150
-360
-30
-110
-310
-730

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the total U.S. emission of that air pollutant and less than 0.007

percent of the total U.S.  area emission of that pollutant from

heavy-duty, diesel-powered vehicles.  In the latter case, the

decrease in each air emission would be less than 0.03 percent of the

total U.S. emission of that air pollutant and approximately 1 percent

of the total U.S. area emission of that pollutant from heavy-duty,

diesel-powered vehicles.

     Based upon the methodology and assumptions described in Section

7.1.4.1, there could be on the order of 80 to 180 transportation-

related hazardous wastes spills annually by 1984 from the transport

of the regulated wastes.  As previously discussed, it is not possible

to estimate the change in the number of spills that would occur from

the removal of 16 million metric tons of hazardous waste from

regulation by 1984.

     Storage, Treatment, and Disposal.  As discussed in Section

7.1.4.1, there are several major ways that air contaminants can be

released by current hazardous waste storage, treatment, or disposal

practices:

     •  Through fugitive emissions resulting from improper storage of
        hazardous wastes;

     •  Through fugitive emissions from ground-based treatment/
        disposal activities such as landfills, landfarms, and surface
        impoundments;

     •  Through emissions occurring as the result of storage becoming
        the ultimate form of disposal of hazardous wastes;

     •  Through emissions generated by spills, fires, explosions, and
        other accidents;


                                 8-88

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     •  Through the combustion of hazardous wastes by incineration or
        open burning;

     •  Through fugitive emissions from other treatment activities;

     •  Through fugitive emissions from facility construction or
        modification.

This alternative would affect the potential for the release of air

contaminants from each of these sources as discussed below.

     To the extent that fewer storage, treatment, or disposal

facilities would have to be modified or would have to be constructed

under this alternative (see Section 8.4.2.4), there would be a

decrease in fugitive dust and vehicular emissions from such

construction activities.  Such emissions would be extremely site

dependent.

     By 1984, approximately 16 million metric tons of potentially

hazardous industrial wastes (plus other hazardous wastes) would be

removed annually from regulation under this alternative as compared

to the proposed regulations.  These hazardous wastes would not have

to be stored, treated, or disposed in accordance with the Section

3004 regulations.  Since it is likely that most of these wastes would

not be managed by methods that are environmentally acceptable under

the Section 3004 regulations the overall potential for the release of

air contaminants from the management of such wastes would be

increased under this alternative relative to the proposed

regulations.

     With regard to the estimated 24 million metric tons of

potentially hazardous industrial wastes (plus other hazardous wastes)
                                8-89

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that would still be regulated under this alternative in 1984, the




less stringent requirements under this alternative would have the




potential for increasing the release of air contaminants from the




management of these wastes as compared to their management under the




proposed regulations.   For example, many of the incineration require-




ments under the proposed regulations apply only to the incineration




of pesticide wastes or to wastes that are hazardous due to toxicity.




The proposed regulations require that such wastes be incinerated at




1,000 C with greater than 2 seconds retention time and greater than 2




percent excess oxygen  and that the incineration achieve 99.99 percent




destruction of the principal toxic components of the wastes.




Elimination of the toxicity characteristic under this alternative




would remove the incineration of almost all regulated wastes from




compliance with the above requirement.




     Only pesticide wastes that are hazardous due to a characteristic




other than toxicity would still have to be incinerated under the




above operating conditions.  The incineration would, however, have to




achieve a 99.9 percent destruction efficiency of the principal




components of the pesticide waste rather than a 99.99 percent




destruction efficiency; thus, there could be up to a 900 percent




increase in the release of the principal components from the




incineration of such pesticide wastes (however, as indicated in




Appendix M, incineration under the conditions specified above can




result in better than 99.99 percent destruction of the principal







                                  8-90

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components of many pesticides).  Incineration of other wastes




regulated under this alternative that would have been identified as




toxic under the proposed regulations (e.g., slop oil emission solids




from petroleum refining — see Table D-7) would also be removed from




complying with the incineration requirements noted above.  Thus,




under this alternative there would be a much greater potential for




incineration of these wastes to release hazardous air contaminants.




     Furthermore, the incineration of all regulated wastes would be




subject to less stringent requirements for combustion efficiencies




and for halogen removal under this alternative.  Required combustion




efficiencies would be reduced from 99.9 percent to 99 percent;




required halogen removal efficiencies would be reduced from 99




percent to 90 percent.  Thus, there could be up to a 900 percent




increase in the release of halogens and carbon monoxide under this




alternative.  In addition, the reduced combustion efficiencies could




also result in the less complete destruction both of other combustion




products and of hazardous waste constituents with a resultant




increase in their release to the atmosphere.  Thus, incineration




under this alternative would likely lead to locally higher ambient




air concentrations of many of the hazardous air contaminants




generated by the incineration.  However, all emissions and resultant




changes in air quality would have to be in compliance with all




applicable requirements (e.g., Clean Air Act standards and state




standards).
                                 8-91

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     Other changes that would potentially increase the release of air




contaminants under this alternative include the removal of the




prohibition against placing volatile wastes in landfills, landfarms,




surface impoundments,  or storage tanks vented directly to the




atmosphere (see Section 7.1.4.1 for examples of volatile hazardous




wastes).  To the extent that regulated volatile wastes would be




stored, treated, or disposed by such methods under this alternative,




there would be an increased release of air contaminants as described




in Section 7.1.4.1.  The application of the Threshold Limit Values




(TLV's) as a time-weighted average for a 24-hour day rather than as a




time-weighted average  for an 8-hour day and a 40-hour week would




allow increased emissions from such non-point sources as landfills,




landfarms, surface impoundments, and storage areas.  The reduction in




the minimum distance that active portions of facilities must be




located from the facility boundary, coupled with the above changes,




would likely lead to increased ambient air concentrations of




hazardous emissions beyond the facility boundary.  Increases in the




time interval for completing required training would also increase




the potential for personnel to improperly manage hazardous wastes so




as to cause fires, explosions, or other accidents that could release




air contaminants.




     It should be noted, however, that there would likely be some




shift in the types of  methods used to store, treat, or dispose both




the regulated wastes and the wastes excluded from regulation under







                                  8-92

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this alternative compared to the methods that would have been used to




manage these wastes under the proposed regulations.  For example, the




elimination of restrictions on the management of volatile wastes




could reduce the incineration of such wastes and increase their




landfilling, relative to the proposed regulations.  Such shifts would




change both the types and quantities of air emissions produced by the




management of specific wastes.  For example, a shift from incinera-




tion to landfilling of a particular waste would potentially result in




a decrease in the release of combustion products and an increase in




the release of particulate matter and/or gases contained in the




waste.  Such shifts could either enhance or reduce the potential for




this alternative to cause increases in the release of specific air




emissions in any given locality.  All emissions and any localized




degradation of air quality would have to be in compliance with all




applicable requirements (e.g., Clean Air Act standards, OSHA




standards, state standards).




     Climate.  Fewer hazardous waste management facilities would




potentially have to be constructed under this alternative than under




the proposed regulations.  Thus, there would be fewer localized




impacts to temperatures, humidities, and low-level wind patterns from




such construction.




     8.4.1.5  Water Quality Impacts.  While the regulations under




this alternative would reduce the potential for adverse impacts to




water quality resulting from generation, storage, transport,







                                8-93

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treatment and disposal of hazardous wastes, the potential reduction

in impacts would be significantly less than the potential reduction

which would result from implementation of the proposed regulations.

     Many of the potential changes to groundwater, and surface water

impacts under this alternative would occur in much the same manner as

the potential changes discussed under air quality.  To avoid redun-

dant discussions, such changes are briefly summarized below rather

than discussed in detail.  Following this summary, additional major

changes are described.

     Since generators would be less likely to make process

modifications designed to increase recycling or to reduce the

quantity and/or types of hazardous wastes generated, this would lead

to fewer changes in water effluents produced by such processes and

thus to fewer changes in groundwater and surface water contamination

by such effluents.  With fewer generators being brought under the

control of the program, the potential for such process modifications

would be further decreased.  Furthermore, to the extent that this

alternative would bring less storage by generators under the Section

3004 regulations,* the potential for groundwater and surface water

contamination by spills and runoff from storage of these additional

wastes would be increased.
*Generators who store hazardous wastes for less than 1 year prior to
 off-site shipment would not be required to obtain a permit under
 this alternative; under the proposed regulations, this permit
 exclusion would be limited to 90 days storage.
                                 8-94

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     Decreases in the quantity of hazardous wastes being transported




subject to the Subtitle C regulations would increase the potential




both for midnight dumping and spills and resultant impacts to




groundwater and surface water quality.  However, decreases in the




average distance over which wastes are transported would decrease the




potential for vehicular accidents and could at least partially




off-set the potential for an increase in spills.  The elimination,




except as previously noted, of the requirement that transporters need




to report and clean up spills and that manifests need to contain




spill information would further increase the potential for water




quality impacts to result from such spills under this alternative.




Decreased transport distances would also result in decreased




vehicular emissions and in a decreased potential for oil, grease, and




the hydrocarbons and heavy metals contained in vehicular exhausts to




be carried into waterways by run-off.




     One major change in water quality impacts would result from the




removal of 16 million metric tons of hazardous industrial wastes




(plus other hazardous wastes) from regulation annually by 1984 under




this alternative as compared to the proposed regulations.  These




potentially hazardous wastes would not have to be treated/disposed in




accordance with the Section 3004 regulations, though they could be




subject to applicable regulations under Subtitle D of RCRA and other




State and Federal legislation (e.g. , the Clean Water Act and the Safe




Drinking Water Act).  Based on current practices, most of these






                                   8-95

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wastes would not be stored, treated, or disposed by methods which are




environmentally acceptable under the Section 3004 regulations.  Thus,




the overall potential for groundwater and surface water degradation




would be increased.  Section 7.1.5 describes the potential for




surface water and groundwater impacts from the treatment/disposal of




such wastes under current practices and requirements.  Many of the




incidents reported in that section involve toxic wastes which would




not be regulated under this alternative.  These include all incidents




exclusively involving pesticides or heavy metals (e.g. , the Moscow




Mills, Missouri endrin incident, and the groundwater contamination




incident involving chromium and cadmium from an aircraft plant in




South Farmindale, Long Island).  Similar types of incidents would




also not be prevented by the regulations under this alternative.




     Additional impacts to water quality could also result from the




enactment of less stringent regulations for the treatment/disposal of




the 24 million metric tons of potentially hazardous industrial wastes




(plus other hazardous wastes) that would still be under control of




the program.  This alternative decreases the required minimum dis-




tance between the active portions of facilities and water supplies;




allows the use of more permeable soil liners for surface impoundments




and landfills; limits groundwater monitoring requirements to facili-




ties which have the potential to discharge to underground drinking




water sources; eliminates quarterly groundwater monitoring while




retaining the requirement for annual monitoring; and decreases the






                                 8-96

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time requirement for post close-out care.  To the extent that more

permeable liners would allow more rapid movement of leachates and

that less frequent monitoring would delay detection of liner failure,

there would be an increased potential for degradation and contamina-

tion of groundwater and of surface waters recharged by the ground-

water.  Similarly; the other changes would also increase the poten-

tial for undetected groundwater and surface water degradation.

     It should be noteds however, that there could be shifts in the

type of methods used to treat/dispose regulated wastes and wastes

removed from regulation under this alternative, compared to methods

used under the proposed regulations.  As previously discussed, such

shifts could result in localized changes in the release of specific
water pollutants under this alternative, compared to the proposed

regulations.
     8.4.1.6  Public Health Impacts.  This alternative would have the

potential to reduce the public health benefits that would be derived
from the proposed regulations.  The impacts to public health under

the proposed regulations are discussed in Section 7.1.6.

     Approximately 16 million metric tons of potentially hazardous

industrial wastes would be removed from regulation annually by 1984

under this alternative as compared to the proposed regulations.  This

decrease would primarily be attributable to the large quantity of

toxic substances that would be excluded from regulation.  Based upon

current practices, a large portion of these wastes would potentially

be stored, transported, treated, and disposed in a manner that was
                                 8-97

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not environmentally acceptable under the regulations.  Also through

the imposition of less stringent standards, there would be a greater

potential for the regulated wastes to release air, water, and soil

contaminants that could cause adverse public health impacts (see

Sections 8.4.1.4, 8.4.1.5, and 8.4.2.1).  The removal of all toxic

wastes from regulation would result in many wastes that are known

or suspected to be carcinogenic, mutagenic, or teratogenic being

excluded from regulation.  Of particular concern is the possibility

for the occurrence of additional disasters similiar to that of Love

Canal in Niagara, New Falls, New York (see Section 7.1.6).  In that

incident, an undeterminable quantity of toxic chemicals had been

improperly disposed, homes had been built adjacent to the disposal

site, and numerous public health problems resulted.

     An example of wastes containing potentially toxic substances,

such as  cadmium or chromium compounds, that might not be regulated

under this alternative, but that could be controlled under the

proposed regulations is as follows:

     •  An aircraft plant in Nassau County; New York generated and
        disposed large quantities of electroplating wastes contain-
        ing chromium, cadmium, and other metals during World War
        II.  An estimated 200,00*0 to 300,000 gallons per day of
        these wastes were discharged into unlined disposal pits
        throughout the s.  Groundwater contamination by chromium
        was first noted in 1942 by the Nassau County Department of
        Health.  Subsequent studies indicated that a hugh plume of
        contaminated groundwater had been formed, extending from the
                                 8-98

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        surface of the water table to depths of 50 to 70 feet below
        the surface.  In 1962, test wells revealed concentrations of
        hexavalent chromium up to 14 ppm, and concentrations of
        cadmium up to 3.7 ppm.  The contaminated plume cannot be
        removed or detoxified without massive efforts and will take
        many more years of natural attentuation and dilution before
        it becomes usuable again.  Meanwhile, it is still slowly
        moving, threatening a nearby creek and other wells in the
        area (Tinlin, 1976; State of Minnesota, 1977).

     For comparison purposes with regard to this incident, the

National Interim Primary Drinking Water Standard for chromium is .01

ppm and .05 ppm for cadmium, respectively.  Although the harmful

effects of this incident are believed to be limited to groundwater

contamination, it is important to note that the incident which began

in the 1940's continued for over two decades.  Although hexavalent

chromium has been found to be toxic to some aquatic species,

information on its chronic effects to humans is limited almost

entirely to data on occupational health effects.  Lung cancer,

ulceration and perforation of the nasal septum, and other respiratory

complications and skin effects have been observed (U.S. Environmental

Protection Agency, 1976a).  In 1941, it was reported that a group of

29 school children experienced violent nausea after eating popsicles

containing 13 to 15 ppm of cadmium (U.S. Environmental Protection

Agency, 1976a).

      8.4.2  Secondary Impacts.  The major changes in secondary

impacts that could occur as a result of implementation of this
                                 8-99

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alternative would result primarily from the removal of approximately




16 million metric tons of hazardous industrial wastes (plus other




hazardous wastes) from regulation annually by 1984; the enactment of




less stringent environmental requirements with regard to storage,




treatment, and disposal of hazardous wastes; and potentially lower




increases in storage, treatment and disposal costs as a result of




these less stringent regulations.




     8.4.2.1  Physiography and Soils Impacts.  The major change in




impacts to physiography and soils would result from the elimination




of 16 million metric tons per year of hazardous industrial wastes




(plus other hazardous wastes) from regulation.  To the extent that




these wastes would be stored, transported, treated, or disposed by




methods which are not environmentally acceptable under the proposed




regulations, the potential for adverse impacts to soils would be




increased.  Section 7.2.1 describes the types of impacts to soils




that could occur from such methods.  The potential for adverse




impacts to soils would be further increased by allowing longer




storage of wastes by generators without requiring a permit.




     Reductions in the quantity of hazardous wastes being transported




subject to the Subtitle C regulations would increase the potential




both for midnight dumping and spills and for resultant impacts to




soils.  However, decreases in the average distance over which wastes




are transported would decrease the potential for vehicular accidents
                                8-100

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and could off-set the potential for an increase in spills.  Reduced




transport would also result in decreased vehicular emissions and in a




decreased potential for oil, grease, and the hydrocarbons and heavy




metals contained in such emissions to be carried onto soils by




run-off.




     To the extent that fewer storage, treatment, or disposal facili-




ties would have to be constructed under this alternative due to a




potential reduction in the off-site process capacity shortfall (see




Section 8.4.2.4), there would be a lesser potential for physical




impacts to soils and physiography.  Allowing the use of more per-




meable soil liners would allow more disposal sites to use natural,




in-place soils, and would therefore reduce the demand for, and




impacts of off-site excavation of clays.   Less land and soil would




also be disturbed by facility construction and by conjunctive devel-




opments such as construction of roads, power lines, pipelines, and




housing.  However, these reduced land requirements would be off-set




to the extent that land would still be required for the storage,




treatment, and disposal of the wastes excluded from regulation under




this alternative.  Potential impacts to soils and physiography from




construction would be essentially the same as those described in




Section 7.2.1.




     8.4.2.2  Biological Impacts.  Land requirements for facility




construction and operation and for conjunctive developments would be




reduced under this alternative.  As a result, the potential for







                                  8-101

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adverse impacts to flora,  fauna,  and ecological systems from land dis-




turbance would also be reduced.   In addition, the reduction in the




transport of hazardous wastes could lead to a reduction in road




kills.




     These potential benefits to  the biological environment would,




however, be off-set by several other changes that could occur under




this alternative.  Approximately  16 million metric tons of poten-




tially hazardous industrial wastes (plus other hazardous wastes)




would be removed from regulation.  Based upon current practices, a




large portion of these wastes would potentially be stored,




transported, treated, or disposed in a manner that was not




environmentally acceptable under  the proposed regulations.  To the




extent that these wastes were to  be handled in such a manner, the




potential for adverse impacts to  the biological environment would be




increased.  Section 7.2.4 describes the types of impacts that could




occur from practices not regulated under Subtitle C.




      It should be noted, however, that in removing these wastes from




regulation, there could be shifts in the methods used to treat/dis-




pose  these wastes.  This could result in localized changes in the




quantity of specific air, land, and water residuals generated by the




treatment/disposal of these wastes as described in Section 8.3.1.4.




The potential for increased adverse biological impacts from these




residuals would be modified to the extent of any such shifts.




     For those hazardous wastes that would still be controlled under






                                 8-102

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this alternative, the potential for water quality impacts, and sub-




sequent adverse impacts to aquatic ecosystems and to wildlife using




contaminated water supplies, would be increased by the use of more




permeable liners and by other changes discussed in Section 8.4.1.5.




The potential for air quality impacts, and subsequent adverse eco-




logical impacts, would be increased as discussed in Section 8.4.1.4.




Furthermore, the potential for impacts to soils, and subsequent




adverse impacts to biological productivity, would be increased as




discussed in Section 8.4.2.1.




     8.4.2.3  Social Impacts.




     Demographic Impacts.  Fewer industrial plant closings or reloca-




tions due to lesser increases in costs under this alternative could




lead to fewer population shifts as described in Section 7.2.3.1.   In




addition, there would be a decrease in the number of construction




workers required due to the lesser amount of facility modification




and construction necessary under this alternative; there would be a




reduction in the number of personnel required for hazardous waste




management activities due to both the less stringent operational




requirements and the decrease in wastes being regulated; and there




would be a decrease in the number of personnel required to administer




and enforce the regulations due to both the quantity of hazardous




wastes and the number of generators, disposers, and permittees being




regulated.  Fewer population shifts could also occur in response to




these reduced personnel requirements as discussed in Section 7.2.3.1.






                                8-103

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Any such shifts would be expected to be small on a national scale;




however, there could still be localized instances of a relatively




large influx of workers, particularly for hazardous waste management




facilities located near very small towns, or of a relatively large




outflux of workers, especially in the case where a plant being closed




constituted the primary source of employment in an area.  Based upon




a minimum requirement of 500 workers to handle (store, treat, or




dispose) a million metric tons of waste per year, it is estimated




that at least 12,000 such workers could be required nationally by




1984; this would represent about a 40 percent decrease in this




requirement compared to the proposed regulations.  About 1,500 to




3,000 of these workers could be required at off-site facilities;




about 9,000 to 10,500 of these workers could be required at on-site




facilities.  This would represent about a 40 percent decrease at both




types of facilities.  To the extent that pesonnel would still be




required to manage the wastes excluded from regulation under this




alternative there would be a lesser reduction in the number of




workers required nationally.




     Social Conditions.  The lesser public health benefits to be




derived from this alternative relative to the proposed regulations




would provide fewer social benefits as discussed in Section 7.2.3.2.




Fewer reductions in chronic and acute health effects would also




result  in an increase in the social and economic costs associated




with such effects, e.g., increased mortality, birth defects, lowered






                                  8-104

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productivity, lost wages.




     A reduction in population shifts would decrease the potential




for impacts associated with such shifts.  However, as discussed in




Section 7.2.3.2, any large, rapid, population influxes could still




cause inflation, strains on the existing infrastructure, social




tensions, changes in daily living patterns, and increased physical




and mental disorders.  Any large rapid, outfluxes could still cause




problems in maintaining existing infrastructures, deflation,




additional unemployment, social stress, changes in daily living




patterns, and increased mental and physical health problems.




     Public opposition to the siting and construction of hazardous




waste management facilities could be reduced by the need for fewer




facilities under this alternative.  However, any opposition that




occurs could be exacerated by the less stringent environmental




requirements for such facilities under this alternative.




     Decreases in the construction of hazardous waste management




facilities and in the off-site transport of hazardous wastes could




result in several beneficial social effects.  Reductions in facility




construction would eliminate the potential for noise impacts,




aesthetic impacts, land use impacts, water use impacts, and pressures




on existing infrastructures that could be associated with the




facility.  Any decrease in the transport of hazardous wastes would




have the potential for a reduction in vehicular accidents.  Based




upon the methodology and assumptions discussed in Section 7.2.3.2, it






                                  8-105

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is estimated that there could be  approximately 110 fewer vehicular

accidents annually in 1984 in the case  of 13 percent  off-site

shipment and about 340 fewer vehicular  accidents in the case of 25

percent off-site shipment.  This  would  represent about a 40 percent

decrease in vehicular accidents  compared to the proposed regulations.

     8.4.2.4  Hazardous Waste Management Facility Capacity.

     Process Capacity.  Based upon the  methodology and assumptions

described in Section 7.2.4.1, it  is  estimated that approximately 3.0

million metric tons of regulated  hazardous industrial wastes could be

shipped off-site for treatment/disposal in 1980 and that between 3.1

and 6.0 million metric tons could be shipped off-site in 1984.  This

would represent a decrease of 2.3 million metric tons of regulated

wastes required to be sent to permitted off-site facilities in 1980

and a decrease of between 2.2 and 4.0 million metric  tons of regu-

lated wastes required to be sent  to permitted off-site facilities in

1984.

     Based upon the estimated 6.2 million metric tons of environment-

ally adequate off-site capacity that could be utilized in 1980, there

would potentially be sufficient capacity to handle the estimated 3.0

million metric tons of regulated hazardous industrial wastes shipped

off-site.  Even if there was no growth  in environmentally adequate

off-site capacity between 1977 and 1980, there would still

potentially be sufficient capacity in 1980.  Under the proposed

regulations there would also potentially be sufficient off-site

capacity available in 1980.
                                 8-106

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     The estimated 7.7 million metric tons of environmentally

adequate off-site capacity that could be utilized in 1984 would be

sufficient to handle the estimated 3.1 million metric tons of

regulated hazardous industrial wastes shipped off-site in the case of

13 percent off-site shipment.  Again there would potentially be

sufficient off-site capacity even if there was no growth in capacity

between 1977 and 1984.  Under the proposed regulations there would

also potentially be sufficient off-site capacity available in 1984.

     In the case of 25 percent off-site shipment, sufficient off-site

capacity would also potentially be available in 1984.  However,

without any growth in environmentally adequate off-site capacity

between 1977 and 1984, there could potentially be a shortfall of

almost 0.5 million metric tons in 1984.*  In this latter case,  1984

could be the first year of shortfall.  Based upon a utilizable

facility capacity of 60,000 metric tons per year, approximately eight

additional off-site facilities could be required in 1984 in this

latter case.  It is estimated that under the proposed regulations

that there could be a shortfall of 2.6 million metric tons of

capacity in 1984 in the former case and of 4.9 million metric tons in

the latter case.  Thus, approximately 45 fewer permitted off-site

facilities could be required under this alternative in the former
*The actual shortfall would be 0.4 million metric tons; however, with
 a utilization rate of 0.9, approximately 0.5 million metric tons of
 capacity would be required.
                                8-107

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case and 72 fewer permitted off-site facilities could be required in

the latter case.

     Data are not available to estimate the potential for shortfalls

in environmentally adequate on-site process capacity.  Industrial

generators could treat/dispose approximately 16.4 million metric tons

of regulated hazardous wastes  on-site in 1980 and between 17.3 and

20.2 million metric tons  of regulated hazardous wastes on-site in

1984.*  This would represent a decrease of approximately 12.3 million

metric tons of regulated  industrial wastes required to be sent to

permitted on-site facilities in 1980 and a decrease of between 11.5

and 13.4 million metric tons of regulated wastes required to be sent

to permitted on-site facilities in 1984.  It should be noted that

less stringent treatment/disposal requirements under this alternative

would likely result in an increase in the existing on-site capacity.

Any such increase would further decrease any potential for a

shortfall in necessary on-site capacity.

     Section 7.2.4.1 discusses other factors that could affect the

size of any shortfall in  both  on-site and off-site process capacity.

The wastes removed from regulation would still have to be

treated/disposed, both on-site and off-site.  While such wastes could

be treated/disposed in non-permitted facilities, their management

could increase the potential for an overall shortfall in capacity;

however, any resultant shortfall would be less than that under the
*The remainder of the waste would be recycled or sent to resource
 recovery operations, both on-site and off-site.
                                8-108

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proposed regulations.  The less stringent requirement under this

alternative would also increase the number of sites at which

facilities could be located.

     Physical Capacity.  Based upon the methodology and assumptions

discussed in Section 7.2.4.2, relative to the proposed regulations

there could be an increase of approximately 0.6 million metric tons

in the total hazardous industrial wastes sent off-site during the

period from 1980 through 1984, assuming 13 percent shipment off-site

in 1984, and there could be a decrease of 4.3 million metric tons in

the total hazardous industrial wastes sent off-site during this

period, assuming 25 percent shipment off-site in 1984.*

     Up to 120 to 240 additional acres could thus be committed to

off-site landfilling during this period in the case of 13 percent

off-site shipment and up to 860 to 1,700 fewer acres could be

committed to off-site landfilling during this period in the case of

25 percent off-site shipment.  In the former case, after 1984 there

could be 65 to 130 additional acres required off-site annually com-

pared to total requirements under the proposed regulations.  In the

latter case, after 1984 there could be 320 to 640 fewer acres re-

quired off-site annually compared to the total requirements under the

proposed regulations.  In all instances there could be commensurate
*In this estimate, it is assumed that under this alternative there
 would be 15 percent off-site shipment for those hazardous wastes
 that would be regulated under the proposed regulations but which
 would not be regulated under this alternative.
                                  8-109

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change in on-site land requirements.

     For purposes of comparison,  based upon an average, secure

commecial landfill size of 270 acres  (U.S.  Environmental Protection

Agency, Office of Toxic Substances,  1977),  these land requirements

would be equivalent to siting about  one additional off-site secure

landfill by the end of 1984 in the case of 13 percent off-site
shipment.  In this case, the equivalent of less than one additional

off-site secure landfill could have  to be sited annually after 1984.

The land requirements would be equivalent to siting three to six

fewer off-site secure landfills by the end of 1984 in the case of 25

percent off-site shipment.  In this  case, the equivalent of one to

two fewer off-site landfills could have to be sited annually after

1984.

     8.4.2.5  Land Use Impacts.  Less total land, off-site plus on-
site, would be required for the construction of any storage, treat-

ment, and disposal facilities needed under this alternative and for
such conjunctive developments as construction of roads, power lines,

and pipelines.  Less additional land would be required since fewer
wastes would have to be sent to permitted facilities; the wastes re-

moved from regulation could use existing facilities or other facili-

ties that were not adequate under the proposed regulations.  How-

ever, as indicated in Section 8.4.2.4, in the case of 13 percent off-

site shipment there would be more total hazardous wastes (those regu-

lated plus those removed from regulation) sent off-site than there

would be in the similar case under the proposed regulations.  Thus,
                                  8-110

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while less total  land would be required, there could be more off-site

land use and less on-site  land use in this case.  In the case of 25

percent off-site  shipment, there would be less total hazardous wastes

sent off-site than there would be in the similar case under the

proposed regulations and,  thus, there could be less off-site land use

and more on-site  land use.  Estimates of potential change in off-site

land requirements for landfills (and commensurate changes in on-site

land requirements) are presented in Section 8.4.2.4.  Existing land

uses would not change on lands excluded from hazardous waste

management under  this alternative; however, there could be localized

changes in land use from any additional shifts to off-site management

from on-site management or to on-site management from off-site

management as discussed above.

     It should be noted that while shifts to on-site land use could

reduce off-site land requirements in the short term, such shifts

could also accelerate the  exhaustion of the relatively limited on-

site physical capacity and could result in increased pressures for

off-site facilities in the long term.  Furthermore, any lesser

increases under this alternative both in resource conservation and

recovery and in treatment  practices leading to volume reduction

(e.g., incineration) would also provide a lesser potential for

reducing total land requirements, both on-site and off-site, in the

long term.

     To the extent that the regulations under this alternative would

result in additional lands being contaminated by improper storage,
                                8-111

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treatment or disposal of hazardous wastes,  there would be off-setting




adverse impacts  to existing  land uses.   Section 7.2.5 describes the




types of impacts that could  occur.




     8.4.2.6  Water Use Impacts.  The potential for the degradation




of groundwater and surface water quality would be increased under




this alternative as previously discussed.  Increased degradation of




water quality would result in a decreased supply of surface water or




groundwater being available  to some or all consumers in the water use




area and increased restrictions on the productive use of the water.




     Since fewer hazardous waste management facilities could be




required, less water would be required under this alternative for




operation of such facilities.  This reduced water requirement would,




however, be off-set to the extent that water would still be consumed




in the management of the wastes removed from regulation.




     8.4.2.7  Resource Conservation and Recovery.  The major changes




in resource conservation and recovery would result from excluding 16




million metric tons of hazardous manufacturing wastes from control




under the Subtitle C regulations annually by 1984 and from the




relatively lower hazardous waste generation, transportation, storage,




treatment, and disposals costs associated with the less stringent




requirements under this alternative.  As discussed in Section 7.2.7,




these changes would provide less incentive for generators to modify




processes so as to enable increased recycling of hazardous wastes as




process  feedstocks, to reduce the quantities of hazardous wastes






                                  8-112

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generated by specific processes, or to change the nature of wastes




produced.  Chapter 5 presents examples of the potential for increased




resource recovery from and recycling of hazardous wastes.




     8.4.2.8  Energy Use.  Energy use would be impacted under this




alternative by changes in facility construction, facility operation,




hazardous waste transport, and resource conservation and recovery.




The lesser amount of facility modification and construction that




would be necessary would result in a decrease in energy use.  Less




stringent requirements for soil liner permeabilities and for




non-point source air emission releases would further decrease the




energy use associated with facility construction.




     There would also be less energy use associated with changes in




facility operation and closure under this alternative.  Removal of 16




million metric tons of hazardous industrial wastes (plus other haz-




ardous wastes) from regulation would reduce energy use as discussed




in Section 7.2.8.  The reduction in the post close-out period from 20




years to 10 years would decrease the energy use associated with post




close-out care.  Less energy would also be required due to less




stringent requirements for such activities as incineration and




leachate and groundwater monitoring.




     Previously discussed changes in resource recovery would lead to




other changes in energy use.  While any reduction in resource re-




covery would result in less energy being initially required for such




activities, there would be a lesser potential for net energy savings






                               8-113

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from resource recovery  activities.




     The changes  in  energy  use  resulting from a reduction in the




transport of hazardous  wastes would  depend  upon such factors as




shifts in the portion of  wastes managed  on-site and off-site and




changes in transport distances.  Based upon the methodology and




assumptions described in  Section 7.2.8,  Table 8-9 presents estimates




of the magnitude  of  the potential change in energy use (compared to




that under the proposed regulations)  that could occur annually from




changes in transport distances  and shifts  in off-site and on-site




treatment disposal.  The  estimated change in energy use under this




alternative ranges from a decrease equivalent to approximately




870,000 barrels of crude  oil  for a 1,000-mile round-trip distance




with 25 percent off-site  treatment/disposal to an increase equivalent




to approximately 7,000  barrels  of crude  oil for a 100-mile round-trip




distance with 13 percent  off-site treatment/disposal.




     8.4.2.9  Inpacts to  Special Interest Points.  To the extent that




treatment/disposal of  the wastes removed from regulation under this




alternative would disturb,  destroy,  or intrude upon special interest




points, there would be  less of  a reduction  in adverse effects to such




special interest points as  discussed in  Section 7.2.9.  However, to




the extent that fewer  lands,  especially  off-site lands, would be dis-




turbed for facility construction and operation and for conjunctive




developments under this alternative, there  would be a lesser




potential for the disturbance and/or destruction of sites of
                                 8-114

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                                           TABLE 8-9

                  ESTIMATED CHANGE IN FUEL CONSUMPTION  IN 1984 FROM TRANSPORT OF
                  LESS HAZARDOUS  INDUSTRIAL WASTES UNDER SUBTITLE C REGULATIONS

Wastes Round-trip
transported distance
off-site (miles)
13 percent 100
200
500
1,000
25 percent 100
200
500
1,000
Change in fuel consumption
(million gallons)
+0.3
-2
-7
-17
-2
-5
-15
-35
Crude oil
equivalent *
(1,000 barrels)
+7
-40
-180
-420
-40
-130
-370
-870

*Assumes 95 percent efficiency in producing diesel fuel from crude oil.

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aesthetic,  archaeological,  historical,  paleontological,  or




recreational value.
                               8-116

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9.0  MITIGATING MEASURES AND ADVERSE IMPACTS WHICH CANNOT BE AVOIDED




     In a sense, the Subtitle C regulations are themselves a miti-




gating measure acting to reduce the adverse environmental impacts of




uncontrolled storage and disposal of hazardous wastes.  Although




these beneficial impacts are not discussed in this section, it is




recognized that they far outweigh any adverse environmental impacts




which may result from the regulations.  The major adverse effects




which would result from the regulations would be economic.  These are




discussed in the Integrated Economic Impact Assessment of Hazardous




Waste Management Regulations (Regulatory Analysis Supplement).  Most




non-economic, adverse, environmental impacts associated with these




regulations could be mitigated by making each corresponding portions




of the regulations more strict (i.e., increasing the number of wastes




defined as hazardous, decreasing the allowable permeability for soil




liners in landfills, etc.).  Many of these types of changes are




addressed in the Alternatives Chapter, Section 8.3 (Greater Degree of




Protection).  Any such reduction in adverse environmental effects




would, however, be accompanied by increased economic costs.




     The major, non-economic adverse effects of these regulations




would primarily be the continuation of impacts presently occurring




and may be grouped into two categories.  One group of impacts




involves the redistribution of hazardous wastes and their associated




environmental problems (which would be at least partially




diminished).  This would occur as existing treatment and disposal






                                 9-1

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sites which do not meet the standards (including many on-site




facilities) close down and the wastes are sent elsewhere.  The second




group of impacts arise from areas not covered or specifically




excluded from the regulations.  Again, any adverse impacts resulting




from such exclusions would not be directly caused by the regulations




since the impacts are occurring now.




9.1  Redistribution of Hazardous Wastes




     When the regulations go into effect, they could force the




closure of a large number of disposal facilities which currently




accept hazardous wastes.  A recent EPA study (U.S. Environmental Pro-




tection Agency, 1977c) indicated that environmental contamination




from existing landfill sites may .be more widespread than previously




realized.  Out of 50 randomly chosen sites which had never before




been suspected of leaking and of which 32 were already being




monitored, 43 sites were determined to be causing local groundwater




degradation, 26 to such a degree that one or more EPA drinking water




standards were exceeded.  Poor groundwater quality was noted in six




of the remaining sites, but could not be definitely linked to the




disposal operation.  Closure of1 a large portion of existing disposal




sites, primarily on-site facilities,  could create an immediate and




potentially severe shortfall of facility capacity.




     Another factor which would exacerbate any such shortfall would




be the closure of on-site disposal facilities.  Since the total
                                9-2

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capacity of existing sites is not known, it is difficult to determine




the ultimate impact of this relocation of wastes.  However, it is




essential that situations such as occurred in New Jersey do not recur




on a national scale.  Enactment of strict environmental regulations




in New Jersey forced the closure of the last legal land disposal site




for chemical wastes in 1976.  Since then, the costs of acceptable




disposal methods have increased tremendously; and many companies have




been faced with the alternatives of paying much higher treatment




costs or using illegal disposal methods.  The result has been a




series of indiscriminate dumping of hazardous wastes throughout New




Jersey and in neighboring states (Richards, 1978).




     Such a situation may be mitigated by one or a combination of




several methods.  One temporary measure is to delay the closing of




currently polluting sites until there are acceptable alternate




disposal or storage methods for all of the wastes presently going to




each facility.  This could be accomplished by delaying action on




permit application by such facilities for several years.  The




advantage of such a strategy would be that, since these sites already




have large amounts of waste that must at some point be cleaned up, it




would not create any significant new problems to continue using them




for a short period of time.  These sites should be prohibited from




accepting any wastes from new sources and every effort should be made




to relocate the wastes presently going to the sites as quickly as
                                 9-3

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possible, but the consequences of immediately closing the site

without acceptable alternatives could lead to the creation of new

problems in previously uncontaminated areas.

     Volume reduction, resource recovery, and recycling of wastes are

other measures which would help mitigate the problems of finding more

disposal capacity.  These are partially addressed in the regulations

by the mandate that "where practical, disposal of hazardous wastes

shall be avoided and alternatives such as resource recovery, reuse,

or other measures of recycling shall be employed."  As a further

method of coping with the short-term shortfall of capacity, this

requirement could be extended to include treatment for volume reduc-

tion.

     A third measure to cope with the shortfall of capacity is to

provide assistance for the rapid expansion of existing facilities to

the greatest extent possible.  Such assistance could take the form of

guaranteed loans, grants, large-scale demonstration projects, and

provision of technical expertise.

     In addition, it would undoubtedly be necessary to site and

construct facilities in order to meet the increased demands for

disposal.  This process could be greatly expedited by effective

cooperation between the permitting agencies (state or Federal), waste

generators, and disposers in order to compile and evaluate

information on needs, the quantities and types of wastes generated,

available transportation, and location of suitable disposal areas.

Information and advice should be solicited from the state geologic
                                9-4

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surveys, local offices of the Soil Conservation Service, Fish and

Wildlife Service, and other pertinent agencies early in the siting

search.  In addition, experience in California, Illinois, and New

Jersey has indicated that there is substantial public resistance to

the siting of new facilities, resulting in long delays and

considerable expense. It is possible that a well-conceived public

information program on both national and local levels could help

alleviate this problem.  Points that could be emphasized are the

required procedures to limit groundwater and air pollution, the

necessity of disposing of the waste in an acceptable manner, and the

physical and geologic conditions which make a particular location a

suitable site.  It may also be advisable to prohibit the construction

of new  facilities which would generate significant quantities of

hazardous wastes unless either an acceptable local hazardous waste

disposal facility has sufficient excess capacity to handle the new

wastes, or unless such a facility could and would be constructed in

conjunction with the new generator.  Such a requirement would help

off-set the public aversion to disposal facilities with the economic

benefits of additional local employment and a larger tax base due to

the presence of the generating facility.  This requirement could also
                                                   ~--^,
reduce  transport distances, result in lower costs, and reduce

potential for spills resulting from transporting hazardous wastes.

     Relocation of waste shipments from existing environmentally

unacceptable disposal sites to acceptable sites may produce some
                                9-5

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local impacts in the area of the new sites.  Since the regulations

require strict compliance with all state and Federal laws regarding

air and water quality, these impacts should be relatively negligible.

However, the creation of large facilities in remote areas (as may be

required by public opposition or the location of suitable geologic

conditions) could result in the loss of potentially valuable habitat,

range lands, or prime agricultural lands.  In addition, some degree

of socio-economic impact could occur as a result of the added

manpower and support facilities which may be required to construct

and operate the disposal facilities.  The Integrated Economic Impact

Assessment of Hazardous Waste Management Regulations (Regulatory

Analysis Supplement) addresses the latter types of  impacts, while

coordination of planning efforts with the Fish and Wildlife Service,

and the USDA Soil Conservation Service should help mitigate the

former.  Additional potential for hazardous spills and vehicle

emissions are also expected to result due to the necessity to

transport more wastes off-site and to the probable longer distances

to acceptable disposal facilities.  Air emissions may also result

from the construction and operation of new resource recovery

facilities, though, again, these emissions are required to be within

all applicable air standards.

     Impacts could occur to water quality as a result of discharges

of treated effluents from waste treatment facilities.  Such discharg-

es would have to meet all applicable water quality standards includ-

ing those promulgated under the Clean Water Act (P.L. 92-500, as
                                9-6

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amended), and under the various state laws, and would have to be




approved by the permitting agency.  However, even though a discharge




meets all applicable standards, it could still reduce receiving water




quality up to the maximum allowable limit.  Since this limit was




picked to ensure adequate protection of both environmental and human




health, such an impact should be minimal, though it may involve some




loss of value to local water users.  However, there are many




potentially hazardous constituents of these wastes for which no




standards have yet been promulgated.  This may be due to lack of




adequate substantiation of suspected human health effects, or to lack




of information on tolerable levels to ensure the absence of chronic




health effects.  In addition, it is possible that some potentially




harmful properties of these wastes are not even suspected at this




time.  In this respect, waste discharges could conceivably meet all




applicable standards and still contribute to environmental




degradation with potential human health effects.  It should be




emphasized that such effects are now occurring to a much greater




degree without the controls which would be implemented by the




proposed regulations. They could be further mitigated by requiring




that all waste streams be sent to permanent disposal facilities.




     In spite of any local increase in impacts which might occur, the




net effect of the relocation of hazardous waste disposal operations




to acceptable facilities in other areas would produce a marked




decrease in the overall adverse environmental impact of the wastes.







                                9-7

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     An additional group of adverse impacts would be associated with




increased paperwork requirements and the enlargement of the govern-




ment bureaucracy to deal with those regulations,  It is estimated




that about 430,000 to 460,000 generators could be required to notify




EPA within 90 days of promulgation of the regulations.  An additional




29,000 facility permit applications could also require processing.




Further, monitoring reports and annual summaries of receipts of mani-




fested wastes could produce up to 500,000 reports per year.  Manpower




to deal with these documents is not presently available in either




EPA, or in most state governments.  These regulations would therefore




require the establishment of new government jobs and procedures which




could both increase the size and unwieldiness of many bureaucratic




systems and the size of government payrolls.  Reducing notification




or reporting requirements would, however, weaken the effectiveness of




control over hazardous wastes.




9.2  Impacts Unaffected by the Regulations




     9.2.1  Siting.  The proposed regulations prohibit locating haz-




ardous waste facilities on active fault zones, in wetlands, on 100-




or 500-year flood plains, in the recharge zone of sole source




aquifers, or in the critical habitat areas of endangered species,




with certain exceptions.  In addition, it is required that landfills,




surface impoundments, and landfarms be located, constructed, and




operated so as to prevent landslides, slumping, and erosion.
                                9-8

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However, other siting considerations which could have or cause

adverse impacts are not addressed.  These include siting areas prone

to subsidence or to geothermal activity; areas on migration pathways

or rangelands of important regional (though not necessarily

endangered) species; or in areas of prime agricultural lands.

Although formally increasing the permit review process to include

state geologic surveys, the Fish and Wildlife Service, and local soil

conservation services is not desirable due to resultant increased

paperwork and processing times, there should be some means of ensur-

ing coordination with these agencies in order to assure that all

potential problems have been considered.  The information require-

ments for permit applications could also be expanded to include eco-

logical data on the site area which lists any local migratory path-

ways and identifies the occurrence of any browsing or burrowing ani-

mals which could obtain access to the material stored or disposed of

at the site.

     As discussed previously; it may also be desirable to examine

siting considerations before beginning the construction of major new

facilities generating of hazardous wastes.  This should be studied in

light of both the local environmental impacts, as well as the

location and capacities of potential disposal facilities.

     In any case, all siting of hazardous waste facilities would also

be subject to a number of additional constraints, besides those cited

in the regulations.  These include restrictions promulgated under the

following laws protecting fish, wildlife, and natural resources:
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     •  Endangered  Species  Act  of  1973  (16  U.S.C.  1531-1543)

     •  Federal  Aid in Wildlife Restoration Act  (16  U.S.C 669)

     •  Protection  of  Wild  Horses  and Burros (16 U.S.C.  1331-1340)

     •  Fish and Wildlife Act of 1956 (16 U.S.C. 742-754)

     •  Fish and Wildlife Coordination  Act  (16 U.S.C.  661-667)

     •  Forest  and  Rangeland Renewable  Resources Act (16 U.S.C.
        1601-1610)

     •  National Environmental  Policy Act of 1969 (42  U.S.C.
        4321-4347)

     •  Administration of National Wildlife Refuge System (16 U.S.C.
        668)

     •  Open Space  Land (42 U.S.C. 1500)

     •  Protection  of  Bald  and  Golden Eagles (16 U.S.C.  668)

     •  Wild and Scenic Rivers  Act (16  U.S.C. 1271-1287)

     •  Wilderness  Act and  Amendments (16 U.S.C. 11-31-1136;  P.L.
        93-662)

Other constraints would include national, state, and local forests,

parks, trails,  and  historic sites.

     9.2.2  Transportation. The proposed regulations  require that  if

the waste meets the DOT definition and  criteria  for a hazardous

material (49 CFR 171.8 and  173)', it must be handled in accordance

with the provisions of certain  DOT regulations  in 46 and 49 CFR.

These regulations contain  detailed requirements  for the construction,

inspection, handling,  and  labeling of hazardous  materials and other

containers.  The proposed  regulations  for hazardous wastes also

specify that transporters  must  not transport containers which are
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 leaking or appear  to be damaged, and  that  leaks which  are  discovered




 enroute be treated as emergency situations.




     Except for  the restrictions on accepting damaged  containers,




 there are no other provisions in the  proposed regulations  designed to




 prevent spillage or other accidental  releases during transport. This




 could be alleviated by requiring studies to determine  a route from




 the generating site to the  treatment/disposal site which presents the




 least chance of an accident and which would involve the least amount




 of damage to human health and the environment in general.  Such




 studies might prove especially useful if the total ton-miles of




 hazardous waste  transport increase.




     9.2.3  Construction and Operation.  The regulations mandate that




 landfills, landfarms, and surface impoundments "shall be located, or




 constructed and operated, so as to prevent landslides,  slumping or




 erosion."  This requirement does not  specifically include  the imple-




 mentation of a sediment control plan  during construction activities,




 though the effective use of such a plan would mitigate most physical




 impacts of construction.  Requirements to minimize the construction




 impact on wildlife would provide additional benefits.  Such plans may




be required by state or local statutes.




     Although the regulations require that "facilities shall have




fencing completely surrounding all active portions of the  facility,"




 they do not make provisions for securing the facilities against small




burrowing animals and birds.  The case of waterfowl at ponds and







                                9-11

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lagoons may present particular problems.  Burrowing animals may be




excluded by constructing fences which are buried several feet in the




soil, the exact depth determined by the types of animals which might




be present in the region.  Solution of the problem of birds may be




more difficult, but may be attempted by growing non-palatable vegeta-




tion such as Phragmites (Martin and Uhler, 1951) or pine trees around




the perimeters of the area.  Intermittent noise makers may also be




used when necessary.




     The regulations would prohibit endangerment of underground




drinking water sources (UDWS).  Such sources are defined as those




which currently supply a public water system; or an aquifer with a




total dissolved solids content of less than 10,000 mg/1; or an aqui-




fer otherwise designated as usable by the Administrator.  It is pos-




sible, especially in water-short areas, that some groundwaters that




are not classified UDWS may at some point be required for salinity-




tolerant industrial uses such as dust control, ash quenching, or cool-




ing purposes.  Contamination of these waters with hazardous wastes




could prevent such use and require the use of freshwater instead,




possibly contributing to existing water shortages.  This occurrence




could be avoided by extending the regulations to protect all ground-




waters.  Alternately, the Administrator could limit exemptions to




this procedure to areas which are highly unlikely to experience water




shortages, or could designate all aquifers in potential drought areas




as UDWS.






                                 9-12

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     Adverse impacts could occur as a result of potentially hazardous

wastes which are not covered by the regulations* or which are pro-

duced by generators who produce less than the generator limit and are

thereby excluded from regulation.  These wastes would be subject to

all other applicable state and Federal regulations, including the

Clean Water Act, Safe Drinking Water Act, Clean Air Act, Subtitle D

of RCRA, Federal Insecticide, Fungicide, and Rodenticide Act, and

others.

     Any remaining impacts resulting from these uncontrolled wastes

could be further mitigated by specifically requiring proper labeling

and disposal of all potentially hazardous wastes (while excluding

generators producing less than 100 kilograms per month from the

paperwork and other requirements of the regulations).

     9.2.4  Closure.  One additional area not specifically covered in

the proposed regulations is the impact resulting from disposal sites

which already have been abandoned or which would be abandoned rather

than modified to meet the regulations.  The Section 3004 regulations

would require that facility owners/operators close all portions of

their facilities which do not comply with the regulations.  Such

closure is to be in accordance with the specified closure procedures.

However, most of the closure requirements are directed at new
*As discussed in Chapter 7, EPA is planning to expand the toxicity
 criteria to regulate a greater number of potentially hazardous
 wastes at a future time.  An additional environmental statement or
 supplementary statement would be prepared covering this change, if
 warranted at that time.

                               9-13

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facilities and those existing facilities able to obtain permits;




previously abandoned facilities and those existing facilities which




could not Be modified to obtain permits could not satisfy many of the




requirements (e.g., financial requirements, submission of closure




plans before beginning operations, certification of closure in




accordance with permit, and preparation of a survey plat showing




types of waste and their location at the site).   While some owners of




these latter facilities could be located, there  are no specific




provisions for insuring proper closure, for financing the cleanup and




closure, or even for locating previously abandoned facilities.  While it




is EPA's intent that all hazardous waste facilities be closed in




accordance with the regulations, some abandoned  facilities may have




to be satisfactorily closed using public funds.




     Lastly, it should be repeated that the regulations themselves




are an important and potent mitigating measure.   The administrating




agencies must ensure that the location, design,  construction, moni-




toring, and closing of all facilities are all carefully planned and




that all provisions of the regulations are strictly followed and




enforced.  This point is emphasized^by the recent study (U.S.




Environmental Protection Agency, 1977c) which discovered that a large




percentage of sites which were presumably secure and already being




monitored were actually causing groundwater pollution.
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10.0  RELATIONSHIP BETWEEN LOCAL SHORT-TERM USE OF MAN'S ENVIRONMENT
      AND THE MAINTENANCE AND ENHANCEMENT OF LONG-TERM PRODUCTIVITY

     The Subtitle C regulations may result in some localized adverse

impacts, though as discussed previously, they would essentially be

continuations of adverse impacts which are already occurring.  On the

other hand, the regulations would also result in a significant over-

all reduction in the impacts of hazardous waste managemen