State Decision-Makers Guide for Hazardous Waste Management: Defining Hazardous Wastes, Problem Recognition, Land Use, Facility Operations, Conceptual Framework, Policy Issues, Transportation

JL
0
efining hazardous wastes, problem recognition, land useT '**
'''- 9

State

Decision-makers Guide \
management
>
efining hazardous wastes, problem recognition, land use, «,•*

10 ff

-------
i
ic
o
-O
5
O
D
01
defining hazardous wastes, problem recognition, land use,*

State

Decision-makers Guide

for Hazardous Waste
management

defining hazardous wastes, problem recognition, land use,
"D
This guide (SW-612) was prepared ip
under the editorial direction of Q
Walter W. Kovalick, Jr., ^.
by fllan Corson, Harold Day, ^
Ronn Defter, flrnold Edelman, w C
fTlurray Newton, (Tlichael Shannon, <_P
(Tlatthew Strauss and Donn Vivian!
U.S. Environmental Protection flgency
1977
For sale by the Superintendent of Documents, U.S. Government Printing Office, Washington. D.C. 20402
-------
An environmental protection publication (SW-612) in the solid waste management series.
Mention of commercial products or firms does not imply endorsement by the U.S. Government.
-------
CONTENTS
PAGE
1. Summary
BACKGROUND ......... ........... 1
LEGISLATIVE CONTEXT .................... 1
ISSUES OF CONCERN . .......... ....... 1

2. Background for Defining Hazardous Wastes ......... 3

FLAMMABILITY ......................... 3
I. Pure Liquids ........ ............. . 3
II. Solution ........................ 4
III. Sludges .................... 5
IV. Solids ..... .......... ... 6
CORROSIVENESS ............... . ... 7
REACTIVITY ....................... 8
SUMMARY ........................ . 9

3. Problem Recognition and Definition ............... 10

BACKGROUND ............................ 10
TYPES OF DAMAGE INCIDENTS ................... 10
TABULATION OF DAMAGE DATA .................. 10
EPA INDUSTRY STUDIES ....................... 12
Hazardous Waste Quantities ................... 13
Treatment/Disposal Technology ................. 14
National Impact of Hazardous Waste Practices ......... 14
OTHER SURVEY APPROACHES .................... 16
State Hazardous Waste Surveys ................ 17
Authority to Request Data .................. 18
Survey Procedure (On Site) ............... ... 18
Potential Generators ................... 18
The Survey Data Collection Guide ............... 19
Data Storage, Handling, and Display ......... 19
"208 "Planning Agencies ................... 20
SOURCES ............................ 20
ATTACHMENT A: DATA COLLECTION GUIDE FOR AN
INDUSTRIAL WASTE SURVEY .................. 22

4. Conceptual Framework for Effective Hazardous
Waste Management ..................... 26

WASTE MANAGEMENT ...................... 26
WASTE DISPOSITION HIERARCHY ................. 27
-------
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT

PAGE
Waste Reduction 27
Waste Separation and Concentration 27
Waste Exchange 28
Secure Land Disposal 28
WASTE TRANSFER CONCEPTS (WASTE EXCHANGE) 28
Energy/Material Recovery 28
Incineration/Treatment ... 29
THE PATHWAY APPROACH TO CONTROL 29
INTRA-INTERSTATE COOPERATION 30

5. Control of Hazardous Waste Transportation 32

LICENSING SYSTEM FOR TRANSPORTERS 32
HAZARDOUS WASTE MANIFEST 33
LABELING AND PLACARDING OF WASTE
CONTAINERS AND TRANSPORT VEHICLES 33
ACCIDENT AND INCIDENT REPORTING 34
INTERSTATE COOPERATION 34
CURRENT FEDERAL AUTHORITY 34
LIMITATIONS OF CURRENT FEDERAL AUTHORITY 35
SOURCES 36

6. Land L7se and Policy Issues Concerning Hazardous
Waste Management 37

DEFINITIONS OF STORAGE, TREATMENT, AND
DISPOSAL 37
DETERMINATION OF SAFE QUANTITIES FOR
DISPOSAL 37
GROUNDWATER PROTECTION 39
THE QUESTION OF USE OF PUBLIC LANDS 39
Federal Agency Policies 39
Other Issues Concerning Public Land Use . . 40

7. Facility Operations 142

PLANNING AND DEVELOPMENT 42
SITE SELECTION 44
Geological 44
Hydrogeologic 44
Topographical 46
Climatic 46
Ecological 47
Cultural 47
Public Acceptance 47
iv
-------
CONTENTS

PAGE<

OPERATION OF FACILITIES 48
Proper Handling Waste Compatability 49
Training 50
Site Personnel 50
Training Needs 50
Monitoring 57
Fiscal Responsibility of Owners—Insurance 51
Closure of Facilities 51
PLANNING LONG TERM CARE 51
Bonding 52
Perpetual Care Fee 52
Bonding/Fee Combination 52
Mutual Trust Fund 52

8. Waste Sampling and Analysis Methods;
Leachate Analysis Methods 54

WASTE SAMPLING METHODS 54
WASTE ANALYSIS METHODS 54
Solid Waste Evaluation Leachate Test 56
Summary 57
LEACHATE ANALYSIS METHODS 57
Metallic Species 59

9. State Programs for Hazardous Waste Management 62

INTRODUCTION 62
GOALS
ELEMENTS OF AN EFFECTIVE STATE HAZARDOUS
WASTE MANAGEMENT PROGRAM 63
Legislative Authority 63
Adequate Resources 63
Published Criteria and Standards 63
Established Permit Mechanisms 64
Surveillance and Enforcement 64
Manifest System 64
PROGRAM DEVELOPMENT PHASES 64

Appendix A: Model State Hazardous Waste Management
Act with Annotation 65

1. SHORT TITLE 66
-------
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT

PAGE

2. FINDING OF NECESSITY AND DECLARATION
OF PURPOSE 66
3. DEFINITIONS 67
4. POWERS AND DUTIES OF THE DEPARTMENT 68
5. PERMITS 70
6. HAZARDOUS WASTE TREATMENT/DISPOSAL
FACILITIES AND SITES 73
7. TRANSPORTATION OF HAZARDOUS WASTES 75
8. RECORDS; REPORTS, MONITORING 79
9. INSPECTIONS; RIGHT OF ENTRY 80
10. IMMINENT HAZARD 80
11. ENFORCEMENT 81
12. INTERSTATE COOPERATION 82
13. REPEALER 82
14. SEVERABILITY 83
15. EFFECTIVE DATE 83

Appendix B: Information Sources for Disposing of Small
Batches of Hazardous Wastes 84

IDENTIFYING HAZARDOUS WASTE 84
INFORMATION SOURCES 87
DISPOSING OF HAZARDOUS WASTE 87
SELECTING THE PROPER DISPOSAL OPTION 87
REUSE/RECYCLE 87
DISPOSAL IN HAZARDOUS WASTE MANAGEMENT FACILITY 87
IN-HOUSE TREATMENT/DISPOSAL 90
HAZARDOUS WASTE DISPOSALING MUNICIPAL
INCINERATORS 90
HAZARDOUS WASTE DISPOSAL IN SANITARY LAND FILLS ... . 90

Appendix C: Information on Disposal of Pesticides and
Pesticide Containers 91
REFERENCES 92

Appendix D: Polychlorinated Biphenyl-Containing
Wastes 93

Appendix E: Vinyl Chloride 97

Appendix F: Federal Agencies 100
-------
Chapter 1
summflRY
SUMMARY
This guide presents the key issues to be addressed
by State, regional, and local governments and agencies,
in creating effective hazardous waste management
programs. Basically a policy-oriented "checklist,"
the guide highlights topics which have been con-
fronted by existing hazardous waste management pro-
grams, or which can be expected to concern such
programs since the passage of the new Resource
Conservation and Recovery Act of 1976 (RCRA).
Background
EPA began work to survey, investigate, and eval-
uate options for hazardous waste management pro-
grams well before the passage of RCRA. Many of the
findings from studies performed both in-house and
under contract, which would be applicable to devel-
oping State programs, have not been restated specifi-
cally for State program managers, or have been avail-
able only as unpublished papers. Therefore, EPA,
Office of Solid Waste (OSW) determined the need to
collect these materials in one reference volume.
RCRA encourages broader State authorities on
many waste management issues, particularly in estab-
lishing a hazardous waste regulatory program. As a
result, the topics covered in this guide are especially
relevant to State programs that are just getting started.
This guide does not preempt regulatory decisions
yet to be made at Federal and State levels, since EPA
.intends to have broad public input before making
such decisions at the Federal level. This guide serves
to highlight issues about which decisions must be
made by responsible public officials.
Legislative Context
This guide was conceived in the context of pro-
viding State officials with a comprehensive legislative
base from which to develop a broad hazardous waste
control program. Such a base could be constructed
either by adapting existing legislation to cover the
multifaceted nature of the problem, or by devising a
comprehensive act to deal specifically with hazardous
wastes.
Appendix A is a Model State Hazardous Waste Act
developed through the assistance of many State waste
agency managers, the waste management industry,
and others. It represents a suggested model legislative
framework for dealing with the hazardous waste regu-
latory issues presented in this guide.

Issues of Concern
Eight major chapters are included in this guide
which broadly frame the topics to be addressed by
State decision makers:
• Definition of Hazardous Waste
• Problem Definition/Recognition
• Principles of Waste Management
• Transportation
• Land Use and Options for Hazardous Waste
Management
• Facility Operations
• Waste Sampling/Analysis and Leachate Analysis
• State Program Elements
Each chapter' attempts to summarize background
materials available to EPA and to relate these mate-
rials to the implementation issues facing State decision
-------
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
makers. EPA Regional Office staffs are available to
assist State program managers who wish to discuss
these issues in greater detail.
Two appendixes are included that address signifi-
cant hazardous waste disposal problems often cited
by State officials as particularly bothersome. Appen-
dix B summarizes the sources of information for dis-
posing of small batches of hazardous wastes. Appen-
dix C reviews the status of the regulation of the
storage and disposal of pesticides^ pesticide containers,
and pesticide-related wastes.
Appendixes D and E reprint disposal advice pre-
pared as guidance under the Solid Waste Disposal Act,
as amended. Wastes containing polychlorinated bi-
phenyls and vinyl chloride-containing aerosol cans
were specifically addressed under this earlier program.
Appendix F details the Federal agencies that deal
with the problem of hazardous waste disposal. This
guide does not purport to provide all of the answers
to State agency managers. It does categorize and
analyze many of the significant questions that need
to be addressed and suggests evaluative and back-
ground information to aid in reaching conclusions.
Many of the final Federal decisions must await the
outcome of the public participation process which be-
gan with the passage of RCRA and will culminate in
regulations that will respond to the need to control
hazardous wastes.
-------
Chapter 2
BPCKGROUND FOR DEFINING HPZRRDOUS WASTES
There are two major methodologies presently in
use to identify wastes as hazardous—a list approach
and a criteria approach. Both approaches are difficult
to implement. The criteria approach addresses the
problem more directly. It identifies those properties
of waste that cause hazardous effects to the environ-
ment and then recommends methods and procedures
to measure these properties (or effects). The list
approach, on the other hand, is more indirect. The
waste is analyzed for certain prescribed species, and
depending upon the presence of these species (and
possibly their concentration), a hazard judgement is
made. The following discussion will address methods
presently available to implement a criteria approach.
Since some aspects of the safe management of
hazardous waste are identical to safe management of
other regulated substances, some of the methods
mentioned herein are those recommended by other
agencies for the testing of these other regulated sub-
stances. Waste materials, however, do possess cer-
tain peculiarities of form and function for which
existing criteria may not be adequate or appropriate
to characterize a waste's hazardousness. In these
cases, the differences are mentioned and the problems
addressed. The criteria that will be discussed are:
flammability, corrosiveness, and reactivity. These
criteria can be viewed as properties of the waste as
disposed and can be measured by directly testing the
waste.
There are other criteria, such as waste toxicity,
etiologic activity, genetic activity, and tendency to
bioconcentrate, which must be considered in the
context of their routes of exposure. A waste contain-
ing a contaminant conforming to these criteria can
only be a hazard-if there exists a vector (exposure
route) by which this contaminant can be made avail-
able to the environment under disposal conditions.
In order to measure these criteria in a meaningful
way, the measurement must be done on the exposure
vector, be it eluent from the waste, vapor due to
waste evaporation and sublimation, or air float
particles from waste particulates. For example, a
waste may contain a toxic constituent, but if this
toxicant is bound up in the waste matrix in such a
way that it cannot leach (elute), vaporize, air-float
particulate, or sublimate under disposal conditions,
the waste does not present a toxicity hazard. There-
fore, any testing done to identify wastes that would
conform to the above criteria should ideally be done
on these vectors. Testing of this sort is complex and
still under development in both the public and private
sectors. This chapter will not deal with these criteria
further.

FLAMMABILITY
Flammability is one criterion for defining a waste
as hazardous. Flammable wastes may cause damage
directly, from h,eat and smoke production, or in-
directly, either by providing a vector by which other
hazardous wastes could be dispersed (such as convec-
tion currents carrying toxic particulates or dust), or
could cause otherwise benign wastes to become haz-
ardous (such as plastics which, when ignited, undergo
condensation reactions or depolymerize to emit toxic
fumes). For these reasons, it is desirable to identify
wastes that are flammable, so they can receive proper
handling.
One method by which the degree of flammability
-------
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
of a material can be defined is by the flashpoint
(FP) of the substance. This is the lowest tem-
perature at which evaporation produces sufficient
vapor to form an ignitable mixture with the air,
near the surface of the liquid, or within the vessel
used. (By "ignitable mixture" is meant a mixture
that, when ignited, is capable of the initiation and
propagation of flame away from the source of igni-
tion. By "propagation of flame" is meant the spread
of flame from layer to layer independently of the
source of ignition.)
The initiation of flame is always the result of the
progressive auto-acceleration of reaction, which be-
comes possible only under definite thermal conditions
brought about by an external source (for example,
spark discharge, hot walls of a vessel, etc.) Most com-
bustion reactions are exothermic (heat producing),
and as they proceed they raise the temperature of the
surroundings. Since reaction rate is a function of
temperature (a measure of available energy), these
reactions accelerate themselves by the thermal energy
they release in reaction. (The reaction here is oxida-
tion, that is, the exhaustive combination of the vapors
with the elemental oxygen in the atmosphere.)
In defining flammability, only the flash point need
be considered since direct vigorous oxidation of a sub-
stance not in the gaseous state is very rare at normal
temperatures. While all agencies and organizations
that define flammability use flash points as their lim-
iting criteria there is no consensus as to what that
limit should be (for example, Department of Trans-
portation P.P. < 100°F, California P.P. < 80°F). In
landfill situations, there are many available external
sources of energy which could provide the impetus
for combustion-electrical energy resulting from sparks
generated by bulldozers, thermal energy resulting
from the heat of neutralization when wastes of differ-
pH's are mixed, biologically initiated thermal energy
from the decomposition of organic wastes, etc. These
sources could raise the temperature at the landfill sur-
face above the ambient temperature. Data should be
gathered on the temperature and energy sources at
landfills to help address the question of what flash-
point limit should be chosen to avoid conflagrations
due to these external sources.
Another source of concern is the fact that disposal
sites often contain wastes that are not hazardous by
themselves, but when burned become hazardous (for
example, certain plastics give off noxious fumes when
burning, beryllium dust may leave the site by a vector
supplied by the fire, etc.) For this reason, it may be
desirable not only to require that flammable wastes
be placed in a hazardous waste facility, but also com-
bustible wastes. Combustible wastes can be managed
in a safe manner at these facilities by being segregated
from those wastes which become hazardous upon
burning.
The established tests for flammability take the
physical state of the substance into consideration,
since the state will affect the vapor pressure and con-
sequently change the flash point. Therefore, flam-
mability will be examined for the four following
physical states of wastes: (1) pure liquid; (2) solu-
tion; (3) sludge; (4) solid. The testing modifications
that must be made for each state, and a short discus-
sion of each state follow:
I. Pure Liquids
The vapor, as measured by the vapor pressure,
produced by a pure substance is directly proportional
to the ambient temperature. (The reference is pri-
marily to liquids, although there are certain solids,
e.g., camphor, that sublime, that is, change from a
solid to a vapor, at ordinary temperatures, and that
have a meaningful vapor pressure.) The "ideal vapor
pressure" of a substance is defined as the sum of the
vapor pressure of each constituent multiplied by its
mole fraction. Temperature is a manifestation of
molecular motion, which in turn is a physical con-
sequence of the kinetic energy of the molecules them-
selves. At any given temperature, the molecules in a
sample will have a "spread" of kinetic energies that
can be statistically described as a Boltzman distribu-
tion.
A molecule must possess a certain minimum
threshold energy in order to overcome the attrac-
tive forces of its neighboring molecules in the close-
packed liquid state. As the temperature is raised, the
entire curve shifts toward higher kinetic energy and
more molecules now possess the prerequisite energy
to escape into the gaseous state.
It has been suggested that flash points be standard-
ized to a particular atmospheric pressure, since baro-
metric pressure does vary with different locations,
and with time at the same location. The reason for
-------
BACKGROUND FOR DEFINING HAZARDOUS WASTES
this suggestion is as follows: Atmospheric pressure is
the measure of the amount of air available at any
given point. Thus, as the atmospheric pressure drops,
less vapor (that is, lower vapor pressure) is necessary
to attain that concentration which defines an ig-
nitable mixture, and the temperature which produces
this lower vapor pressure (that is, the flash point)
is also lower. One might assume then that if the
barometer drops appreciably after a flash-point deter-
mination is made, what was tested as a nonflammable
substance at the higher reading may be flammable at
the new pressure. However, this seems to be an un-
realistic concern since according to the National
Oceanic and Atmospheric Administration (NOAA),
the largest barometric deviation in a single day (ex-
cluding hurricanes and tornadoes) is Jess than 20 mm
Hg, and this would change a flash point of 80° C by
less than 3°C.
There are several common methods of determining
the flash point of a liquid. The methods vary only
slightly with the apparatus used, and these apparatus
are of two types-open cup testers and closed cup
testers. The method is basically as follows: the sam-
ple is placed in the sample cup and heated at a slow
but constant rate. A small test flame is passed across
the cup at regular, specified intervals. The flash point
is taken as the lowest temperature at which applica-
tion of the test flame causes the vapor at the surface
of the liquid to flash.
The apparatus on the market differ in four ways:
(1) sample cup type; (2) cup insulation type; (3) heat-
ing mechanisms; (4) agitation.
The most important of these is the type of sample
cup. Open cup testers as a class give higher flash
points than closed cup testers, and are normally used
for determinations on liquids with relatively high
flash points. These higher determinations result
from the fact that the design of the top of the sample
cup in an open cup tester allows the sample to be in
greater contact with the atmosphere, preventing any
quantitative buildup of vapors over the liquid as it is
heated. Closed cup testers have smaller openings
above the sample cup; this keeps the vapor from
quickly dissipating and results in a mixture richer in
vapor. Thus, dosed cup testers would be representa-
tive of the worst, or most dangerous situation.
There are two types of cup insulators (temperature
baths): liquid bath and air bath. Since the purpose
of these temperature baths is to ensure a uniform
temperature around the entire sample, a liquid bath
is superior to an air bath, due to the better thermal
transport properties of liquids as compared to air.
As far as temperature control mechanisms are con-
cerned, it makes no difference whether the apparatus
has a gas or electric burner. Both are equally accurate
at the low temperature of concern, and the choice be-
comes one of convenience (electric) versus economy
(gas).
The final choice that must be made is whether or
not to include a method of sample agitation in the
apparatus. If the sample to be tested is very viscous,
tends to skin over, or contains suspended solids, a
stirrer should be incorporated into the apparatus to
agitate the sample and prevent local temperature var-
iations. Since a pure nonviscous liquid can also be run
on such an apparatus without a stirrer, it is recom-
mended that a stirrer be incorporated into the ap-
paratus.
There are a number of different flash-point testers
offered by the vendors, Fischer and Sargent to name
two, with various combinations of the above features
(Table 1).
The following is a short discussion on three types
of physical state deviations from a pure liquid and
and how they should be handled.
II. Solution
A solution is the least complex deviation from a
pure liquid, and the procedures for ascertaining flash
points of solutions have also been developed. The
vapor pressure of solutions will vary either positively
or negatively from the ideal vapor pressure (where
the "ideal vapor pressure" is defined as the sum of
the vapor pressure of each constituent multiplied by
its mole fraction). Solutions can be tested in the
same manner as pure liquids with the following pro-
cedural change. If the flash point is determined to be
6.6°C (20°F) or higher, a sample of the liquid eva-
porated to 90 percent of its original volume should be
tested. The lower value of the two tests can then be
used as the flash point of the material. The purpose
of this procedure is as follows: Since the different
components in the mixture have different volatilites,
-------
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
TABLE 1
FLASH-POINT TESTERS

Type
Pensky -Martens (Fischer)
Pensky -Martens (Fischer)
Tagliague (Fischer)
Tagliague (Fischer)
Cleveland (Fischer)
Cleveland (Sargent)
Cleveland (Sargent)
Pensky -Martens (Fischer)
Pensky -Martens (Fischer)
Sample
Cup
Closed
Closed
Open
Closed
Open
Open
Open
Closed
Closed

Stirrer
No
Yes
No
No
No
No
No
No
Yes

Bath
Air
Air
Liquid
Liquid
None
None
None
Air
Air
Type of Temp.
Control
Electric
Electric
Electric
Electric
Gas
Gas
Electric
Gas
Gas
Cost
(1974)
$395
$470
$200
$300
$265
$120
$240
$330
$400
the composition of the liquid phase changes, which
produces a change in the composition of the resultant
vapor phase, which in turn will affect the flash point.
The evaporation of 10 percent of the more volatile
composition ascertains whether this change in com-
position will produce a flammable mixture.
III. Sludges
Sludges, including slurries, colloids, etc., pose a
much more difficult testing problem. Following is a
short discussion of some of the physical peculiarities
of sludges which might affect flash-point testing. If
the sludge is stratified, which is likely due to the dif-
fering densities of most substances, then the upper
layers will inhibit evaporation of the lower layers.
The evaporation of the lower layers will occur at the
normal rate only when they are in direct contact with
the atmosphere at either thermally or mechanically
produced holes. This problem can be overcome by
taking two testing samples, representing the two ex-
treme situations, these situations being: (1) no
mechanical or thermal agitation present so that only
the least dense (top) layer is in contact with the
atmosphere and able to evaporate; (2) the vigorous
agitation so that all components of the sample come
into contact with the atmosphere and can evaporate.
If two samples representing these extremes are
taken and tested (a sample of just the top layer,
and a sample of the waste when agitated) and neither
results in a flammable solution, then any linear com-
bination of the two situations should also be nonflam-
mable.
The theoretical rationale for this evaporation in-
hibiting effect of layer stratification is as follows: at
any given temperature the molecular motion, which
is simply a manifestation of the kinetic energy of a
sample, can be statistically described in terms of a
Boltzman distribution. Only those molecules with a
kinetic energy above a certain level have enough ener-
gy to escape the attractive forces of the other mole-
cules in the liquid phase and can escape into the gas
phase. Obviously, those molecules far below the sur-
face have a very small chance of reaching the surface
with this minimum kinetic energy intact, since they
are constantly being involved in inelastic collisions
(collisions where momentum, and hence kinetic
energy, is exchanged) and will, on the average, lose
energy in these exchanges since they are themselves
above the mean in energy.
IV. Solids
The final situation is one in which the sample to be
tested is a solid. In the burning of most substances,
the actual combustion takes place only after the sub-
stance has been vaporized or decomposed by heat to
produce a gas. Most solids have lower vapor pressures
than liquids, due usually to the stronger intermolecu-
lar forces existing in solids. For this reason, they are
less likely to be flammable since it takes more ener-
gy, that is, a higher "temperature," to volatilize them.
It is rare for a solid to have a flash or. fire point in the
normal temperature range except for those solids hav-
ing a meaningful vapor pressure, like napthol. Be-
cause of this fact, there is less danger of fire from
solids. Since solids can exist in many different
"states" (granular, amorphous, rigid, etc.), the flam-
mability testing procedures must be very general with "
few of the specific details one has come to expect in
standards.
Also tests which measure the ignition or flame
-------
BACKGROUND FOR DEFINING HAZARDOUS WASTES
point of solids tend to give results which are highly
dependent upon the conditions of heating. Solids, as
a rule, do not conduct heat as well as liquids, for this
reason localized hot and cold spots can develop when
testing a solid, and give rise to an observed ignition
point which may be different than the actual ignition
temperatures. Therefore, presently available testing
methods measuring such properties as the auto-
ignition point of solids do not seem to be useable in a
regulatory system, due to the inconsistency of the
available test methods, and the problems associated
with obtaining representative samples for testing.
What can be used in place of a testing method could
be a prose definition similar to that used by the State
of California: "A flammable solid is a solid which
may cause fire through friction or which may be ig-
nited readily and when ignited burns so vigorously
and persistently as to create a hazard ..."
CORROSIVENESS
Corrosive wastes are of two-fold concern. The
primary concern is for the safety of the waste hand-
lers (haulers and disposers). Wastes capable of dam-
aging tissue by corrosive action must be identified,
and then properly labeled to insure that they receive
cautious handling. The second concern is that if
wastes which are to be stored for a period in a con-
tainer are corrosive, they may corrode the container,
leak out, and cause damage. There are standard
methods available to judge if a specific waste might
be cause for either concern. The Food and Drug
Administration (FDA), the Department of Commerce,
the Occupational Safety and Health Administration
(OSHA), and the Department of Transportation
(DOT) all reference a test which can be used to
determine how corrosive a particular waste would be
to mammalian tissue (Title 21, CFR 191.10, .11).
The test specificies use of an albino rabbit, and there
is good correlation that substances corrosive to the
skin of an albino rabbit would also be corrosive to
human tissue. Unfortunately, this test is very expen-
sive and time-consuming when run on a regular basis,
that is, for each batch of waste.
The second area of concern, the corrosion or the
container holding a hazardous waste, can be addressed
by a standard test described by the National Associa-
tion of Corrosion Engineers. This test determines
how corrosive a sample is to certain metal alloys.
This is necessary if: (1) the waste is hazardous and
is to be stored in a metal container; and (2) the
waste will come into contact with metal containers
which contain hazardous wastes. This test is de-
scribed in the National Association of Corrosion En-
gineers Standard (TM-01-69). The test consists of
placing a sample of metal of known surface area into
the suspected corrosive waste and measuring the
weight loss due to corrosion after specified time inter-
vals. This weight loss is then manipulated by alge-
braic equations to give such information as mils of
metal corroded per year (perpendicular to the metal
surface).
It is important to realize that this standard was
written for the primary purpose of determining the
ability of a particular metal to withstand corrosion,
whereas our interest is in whether a particular "solu-
tion" (sludge, slurry, etc.) is itself corrosive. This dif-
ference in philosophy, however, does not affect the
validity of the test, and seems to necessitate only
minor procedural changes.
In the test as it was originally devised, the exhaus-
tion of the corrosive constituents of the sample solu-
tion was avoided by the addition of more corrosive
constituents, or by changing the solution during the
test. For waste identification purposes this is
unnecessary, for while the test was designed to deter-
mine the corrosion rate of a material which is being
constantly assaulted by fresh solution, our metal
containers are only in contact with a very limited,
specific amount of solution. As long as the ratio of
the surface of test alloy to the amount of test solution
is smaller than the ratio of the inside surface of the
container to the total amount of solution in the con-
tainer, any error will be on the safe side. Obviously,
the alloy tested should be the one of which the con-
tainer is made.
This protocol would not be foolproof. Pitting,
galvanic, intergranular and other types of corrosion
can cause leakage within a time period within which
the test results would indicate that no leakage would
occur. A decision would have to be made as to what
time period a waste might be allowed to remain
drummed before it would have to be tested.
Another alternative to specifying a corrosiveness
testing protocol is to specify container standards. The
container lining and drum gauges could be specified
-------
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
for wastes which are to be stored for stipulated
periods of time.

REACTIVITY
There are presently no recognized standard gen-
eral testing methods for reactivity. The present regu-
latory method of describing "reactive" materials is
to publish a list of such, and then give a catch-all
definition. These definitions do not, however, in-
dicate a positive test for reactivity, but rather describe
the physical peculiarities of these reactive materials,
for example, "a strong oxidizer" or "a self-pol-
ymerizer." This ambiguity results from the fact that
while "highly reactive" substances are found to be-
long to specific classes or chemicals (for example,
peroxides, etc.), there is no particular structure of
chemical composition that can be used as an a priori
indicator of "reactivity." This is because reactivity
is solely a function of the thermodynamic descrip-
tion of the initial, transition, and final states of the
reaction components.
These highly reactive hazardous substances are sub-
stances which:
I. Autopolymerize
II. React vigorously with air or water
III. Are unstable with respect to heat or shock
IV. Are strong oxidizing agents
V. React readily to give off toxic fumes
VI. Are explosive
These categories are not discrete, but overlap. For in-
stance some peroxides would fit four of the above
categories.
All these categories (except IV) usually require an
external impetus to precipitate the reaction either in
the form of energy as a "shock" or the addition of an
initiating agent.
One common link among highly reactive sub-
stances, and an important reason for their hazardous-
ness, is that their reactions can cause the formation of
steep temperature or pressure gradients with time.
There are standard methods of testing for and measur-
ing these effects. Differential Thermal Analysis DTA,
(ASTM E475) is one procedure that can be used to
identify wastes which give off large amounts of heat
when reacting. The procedure consists of confining
the sample in a specially designed vessel equipped
with a shielded thermal-couple.
The test assembly is put into a temperature bath
and then heated at a constant temperature increment
rate. The differential temperature (sample tempera-
ture minus bath temperature) is recorded versus bath
temperature or versus a thermally inert control mater-
ial. The differential temperature curve (that is, sam-
ple temperature, due to reaction exothermicity versus
bath temperature, due to constant thermal input),
is graphically analyzed to determine the threshold
temperature for initiation of measurable reaction.
Likewise, wastes which react to form high pres-
sure gradients can be identified by use of a reaction
vessel equipped with a pressure transducer. This can
then be heated and the pressure increase with time
analyzed graphically.
The problem with these two methods lies in the
fact that the results must be analyzed and a judgment
made. The results can be ambiguous and not readily
interpretable. For example, the pressure transducer
only reads the pressure increase, but gives no indica-
tion as to the nature of the vapor being formed.
There are standardized testing methods available
to identify those materials which are pressurs sensi-
tive, or can be detonated by shock, such as the
Picatinny Arsenal test.
A test method which could be used to identify
strong oxidizers would be use of a redox electrode.
Oxidation can be thought of as the loss of electrons:
a redox electrode measures the potential difference
between the test solution and a standard electrode.
From this potential, a test solution can be judged as
either oxidizing or reducing, and to what extent. This
test method can only be used on a liquid waste, and
specific protocols are not presently available to use
this method for determining the redox potential of
wastes.
The tests mentioned above are all specialized test-
ing procedures which should only be run on a small
percentage of wastes. An alternative method of
handling the identification of highly reactive wastes
would be to develop prose definitions of the effects
of these reactive wastes similar to the National Fire
Protection Association categories for reactive substan-
ces or oxidizers, with a sample listing for each.
-------
BACKGROUND FOR DEFINING HAZARDOUS WASTES 9

SUMMARY icy sense, a very complex task. The variety of op-
As the foregoing discussion illustrates, the defini- tions for definition of these simpler, physical param-
tion of a hazardous waste (as required by Section eters will compound greatly when the acute and
3001 of the Resource Conservation and Recovery chronic toxicity factors are addressed.
Act) promises to be both scientifically, and in a pol-
-------
Chapter 3
PROBLEfH RECOGNITION RND DEFINITION
BflCKGROUND
BACKGROUND
According to current estimates by the Office of
Solid Waste, 336 million metric tons (wet weight) of
industrial wastes are produced annually in the United
States, with a yearly growth rate of about 3 percent.
It is also estimated that about 10 percent of this
industrial waste is potentially hazardous. The inade-
quate management of these hazardous wastes has the
potential of causing an adverse impact on public
health and the environment. This impact combines
both the acute (short-range or immediate) and
chronic (long-range) effects of a hazardous com-
pound or a hazardous combination of compounds,
and is related to production quantities and distribu-
tion. In EPA's Report to Congress* on hazardous
wastes, EPA concluded that the prevailing methods of
hazardous waste management are inadequate and re-
sult in the uncontrolled discharge of hazardous resi-
dues into the environment.
TYPES OF DAMAGE INCIDENTS
OSW has compiled hundreds of case studies of
damages resulting from the improper management of
industrial residues, of which some have been pub-
lished. In the course of this data-gathering effort,
OSW has recognized six major routes of environ-
mental transport that can result in the improper land
disposal of hazardous wastes: (1) groundwater con-
tamination via leachate; (2) surface water contamina-
tion via runoff; (3) air pollution via open burning,
evaporation, sublimation, or wind erosion; (4) poison-
ing via direct contact; (5) poisoning via the food
*Seotion 212 of the Resource Recovery Act of 1970
required that EPA prepare a comprehensive report to Con-
gress on the storage and disposal of hazardous wastes.
chain; and (6) fire and explosion. Many cases docu-
ment the immediate and long-term danger to man or
his environment from improper disposal of such
hazardous wastes. Three examples follow:
• Fifteen thousand drums of toxic and corrosive
metal industrial wastes were dumped on farm-
land, resulting in the deaths of large numbers of
cattle from cyanide poisoning and the contamina-
tion of nearby surface water by runoff.
• Hexachlorobenzene (HCB) was dumped in a
rural landfill, where it sublimed into the air.
The HCB was ultimately absorbed into the body
tissues of cattle, resulting in the quarantine of
20,000 head of cattle by the Louisiana Department
of Agriculture at a loss of approximately 3.9 mil-
lion dollars to ranchers.
• Chemical wastes were illegally stored and
dumped, causing the contamination of the Co-
hausey aquifer by petrochemicals. This resulted
in the condemnation of 150 private wells.
TABULATION OF DAMAGE DATA
OSW has compiled an inventory of over 400 cases
of damage resulting from waste-disposal practices.
The majority of case studies in the inventory relate to
industrial processing waste disposal; however, dam-
ages from the disposal of pesticides and pesticide con-
tainers have also been incorporated. The primary
sources for this data-gathering effort were State en-
vironmental regulatory agencies.
Based on 421 industrial and pesticide waste-related
damage case studies compiled to date, OSW has pre-
pared a number of tabulations which may help in
reaching some preliminary conclusions about prevail-'
ing damage trends.
10
-------
PROBLEM RECOGNITION AND DEFINITION
11
Table 2 categorizes the damage mechanisms in-
volved in the analyzed case studies by disposal
method. It indicates that groundwater contamina-
tion is the most common type of damage reported,
followed by surface-water contamination. Moreover,
in most cases of established groundwater contamina-
tion, actual water supply wells (as compared to mon-
itoring wells) have been affected. The table also
shows that "other land disposal," which generally
refers to promiscuous dumping or dumping on land
not designated for this purpose, is the most signifi-
cant source of damage.
It should be noted that the data summarized in
the table are not nationally representative since 65
of the 421 cases studied were obtained from an in-
complete survey of one State that already has a per-
mit system for landfills and surface impoundments.
The most flagrant environmental offenses generally
occur in those States that do not have regulatory pro-
grams for industrial waste disposal. Further, such
States generally do not have adequate documentation
of damages.
The contaminants, listed in damage incidents by
disposal method, comprise a wide range of harmful
and potentially harmful substances (Table 3). The
largest category, miscellaneous organics (identified
in 88 separate incidents), includes some known and
suspected carcinogens. It should be emphasized,
however, that in most documented damage cases,
chemical analysis of the contaminants is incomplete.
This is mainly due to the expensive nature of thor-
ough laboratory analysis, especially when organic con-
taminants are involved.
Two other interesting observations derived from
the tabulation of case studies should be noted. One
is that in 63 percent of the incidents of damage, the
Table 2
MECHANISMS INVOLVED IN INCIDENTS OF DAMAGE BY DISPOSAL METHOD3
Disposal Method
Surface
Impoundments
Landfills,
Dumps
Other Land
Disposal13)
Storage
of Wastes
S meltings,
Slag, Mine
Tailings
Number of Cases

Damage Mechanism
(number of cases)
89
99
203
15
15
Groundwater
(259)
Surface Water
(170)
Air
(17)
Fires, Explosions
(14)
Direct Contact Poisoning
(52)
Wells Affected0^
(140)
a) The tabulation is based on 421 cases

32
studied thus far.
damage incidents involved more than one damage

64 117 10 11

49 71 8

5 9

11 3

6 40 5

28 74 4 2
The numbers in the matrix add up to more than 421 , because several
mechanism.
b) Haphazard disposal on vacant properties, on farmland, spray irrigation, etc.
c) Not included as a damage mechanism

Note: The data presented in this table have been derived solely from case studies associated with land disposal of industrial wastes.
-------
12
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
TABLE 3
CONTAMINANTS INVOLVED IN DAMAGE INCIDENTS
BY DISPOSAL METHOD
CASES STUDIED: 421
Disposal Method
Contaminant
As
Cd
Cr
Cs
Cu
Fe
Hg
Mn
Ni
Pb
Zn
a"
CN"
F"
NH3
N03-
SO4~
Inorgamc Acids
Misc. Inorganics
PCBs
Petrochemicals
Phenols
Misc. Organics
Bacteria
Pesticides
Radioactive
Unspecified Leachate
Total
•a
I
19
5
33
1
20
40
11
26
13
22
22
27
19
8
14
16
18
27
83
3
27
31
88
11
71
9
25
689
Surface
Impoundments
5
3
11

6
10
1
3
5
5
9
11
6
5
6
6
9
9
21

10
9
19
1
1
2
5
178
Landfills,
Dumps
4
1
9
1
4
20
1
15
2
6
5
6
4

2
2
2
4
25
1
5
10
25
2
6
3
18
183
Other Land
Disposal*
10
1
12

7
6
9
4
5
8
5
9
9
3
6
7
5
10
29
2
10
12
39
8
57
1
1
275
Smelting,
Slag, Mine
Tailings

3
4

4
1
3
3
1

2
4
6

1
1
34
Storage

7
2

19
*Disposing on vacant properties, on farmland, spray irrigation, etc.
causative waste disposal action occurred on the prop-
erty of the waste generator, although in many in-
stances the damage had spread off-site when it was
discovered. The second observation relates to the
time frame of discovery of damage. Sixty percent of
the available damage incidents were discovered during
the past 5 years; however, the acts of waste dis-
posal responsible for the damage may have occurred
years or even decades earlier.

EPA INDUSTRY STUDIES
Under Section 212 of the Resource Recovery Act
of 1970, the Office of Solid Waste began examining
problems associated with hazardous wastes. As re-
quired by the Act, EPA submitted a report to Con-
gress detailing their findings and conclusions, that
can be summarized as follows:
• Substantial quantities of toxic and otherwise
hazardous industrial waste are generated annually.
• Land disposal of these materials is increasing
as a result of increased production and consump-
tion, and due to the institution of air and water
pollution controls.
• Regulation of nonradioactive hazardous wastes
is, at present, nonexistent at the Federal level, and
variable in extent and inconsistent in enforcement
on both the State and local level.
• There is little economic incentive for generators
to dispose of their hazardous waste in an environ-
mentally adequate manner.
As a result, the Administration proposed that Con-'
gress enact legislation designed to prevent dangerous
and environmentally unsound hazardous-waste treat-
ment and disposal practices.
-------
PROBLEM RECOGNITION AND DEFINITION
13
It was apparent that should the proposed legisla-
tion pass, the preventive measures must be based on a
firm foundation of knowledge and indisputable evi-
dence in order for resulting standards to be practi-
cal, equitable, and implementable. This would re-
quire considerably more information on the genera-
tion and characteristics of hazardous wastes, and on
the technology available for adequate treatment and
disposal than had been developed to date. Therefore,
the Office of Solid Waste undertook a series of 14
industrial studies to determine: (a) types, quantities,
and sources of those potentially hazardous wastes
which are or will be generated by industry; (b) pre-
sent practices for treating and disposing of hazardous
wastes; (c) control technology which could be applied
to reduce the hazards presented by these wastes upon
disposal; and (d) the cost of control technology.
Hazardous Waste Quantities
The 14 industrial waste studies conducted by the
Office of Solid Waste began in January 1974, and
were completed in January 1977. The majority of
data collected were through telephone interviews,
plant visits, and a sample and analysis program.
Approximately 200 million metric tons of total in-
dustry waste and 29 million metric tons of potentially
hazardous waste (wet weight) were generated in 1974
by the 14 industrial sources (Tables 4 and 5).

TABLE 4
U.S. INDUSTRIAL WASTE GENERATION
(MILLION METRIC TONS ANNUALLY) (1974)
TABLE 5
POTENTIALLY HAZARDOUS WASTE QUANTITIES (U.S.)
(MILLION METRIC TONS ANNUALLY) (1974)

Industry Category
1. Batteries
2. Inorganic chemicals
3. Organic chemicals, pesticides,
explosives
4. Electroplating
5. Paints
6. Petroleum refining
7. Pharmaceuticals
8. Primary metals
9.< Textile dyeing and finishing
10. Rubber and plastics
1 1 . Leather tanning and finishing
12. Special machinery
13. Electronic components
14. Waste oil re-refining
Totals
Total
Dry
0.000
40.000

2.200
0.909
0.370
0.625
0.244
100.342
0.310
2.007
0.064
0.305
0.037
0.057
147.470
Total
Wet
0.010
68.000

7.000
5.276
0.396
1.757
1.218
109.902
2.099
3.254
0.203
0.366
0.060
0.057
199.598
Industry
Dry Basis Wet Basis
1.
2.
3.

4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
14.

Batteries
Inorganic chemicals
Organic chemicals, pesticides,
explosives
Electroplating
Paints
Petroleum refining
Pharmaceuticals
Primary metals
Leather tanning and finishing
Textile dyeing and finishing
Rubber and plastics
Special machinery
Electronic components
Waste oil re-refining
Totals
0.005
2.000

2.150
0.909
0.075
0.625
0.062 '
4.454
0.045
0.048
0.205
0.102
0.026
0.057
10.763
0.010
3.400

6.860
5.276
0.096
1.757
0.065
8.335
0.146
1.770
0.785
0.162
0.036
0.057
28.755
Two interesting observations derived from the
tables should be noted. First of all, the hazardous
portion of the waste is approximately 14 percent
(wet weight) of the total industrial quantity. This
percentage is larger than the 10 percent estimated
for all industrial wastes. Therefore, these particular
industries are thought to generate the majority of
the nation's hazardous wastes. The second observa-
tion is that four industrial categories-primary metals;
organic chemicals, pesticides, and explosives; elec-
troplating and metal finishing; and inorganic chem-
icals-account for 83 percent of the total hazardous
waste produced (wet weight) from the 14 industries.
The geographical distribution of potentially haz-
ardous waste quantities shows that the majority of
hazardous waste is generated in EPA Regions III,
IV, V and VI, which are the major industrial sectors
of the country, that is, the Mid-Atlantic Region,
Southeast Region, Great Lakes Region and Gulf
Coast Region (Table 6).
When the potential hazardous waste growth for
the years 1977 and 1983 is projected, indications are
that all 14 industries will generate a greater quantity
of hazardous waste (Table 7). The generation rates
will range from a 24 percent growth in the primary
metals industry to a 2000 percent growth in the bat-
teries industry. A large percentage of the growth is
-------
14
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
due to the institution of air- and water-pollution con-
trol technology that has been or will be added
(Figure 1).
Treatment/Disposal Technology
In conducting the 14 industrial waste studies,
treatment and disposal operations were also con-
tacted to assess the types of treatment/disposal

TABLE 6
POTENTIALLY HAZARDOUS WASTE QUANTITIES
BYEPAREGIONa'b)
(MILLION METRIC TONS ANNUALLY)
EPA Region
I
II
III
IV
V
VI
VII
VIII
IX
X
Total
Dry Basis
205,171
586,460
1,720,138
1,434,088
2,647,572
2,797,065
161,932
220,071
550,693
439,818
10,763,008
Wet Basis
1,208,486
1,920,524
3,888,173
4,451,865
6,541,708
7,120,978
558,595
517,736
1,487,911
1,059,038
28,755,014
(a) Quantity figures were obtained from contractor esti-
mates of those wastes which are potentially hazardous in 14
industrial categories.
(b) Appendix B indicates the States located in the dif-
ferent EPA Regions.
methods used for the various types of wastes. From
the studies, it was found that land disposal (that is,
landfill, surface impoundment, etc.) is the most pre-
valent method (approximately 83 percent) used by
industry to manage their potentially hazardous watses,
with treatment and recovery techniques (such as, in-
cineration, recovery, etc.,) making up the remaining
17 percent.
National Impact of Hazardous Waste Practices
In order to gain an understanding of the nation-
wide potential for health and environmental damages
related to industrial waste disposal, OSW made an
assessment of the environmental adequacy of cur-
rent disposal practices, as related to the estimated 29
million metric tons of potentially hazardous residuals
that have been identified in the industry categories
considered. The- assessment of environmental ade-
quacy was based on the disposal practices employed
by typical manufacturing facilities—those which em-
ploy average disposal technology relative to other
plants in the same industry. The modes of disposal
have been identified as environmentally adequate or
inadequate.
Prevailing disposal practices can be categorized on
the basis of estimated environmental adequacy, and
the percent of total wet weight attributable to each
TABLE 7
POTENTIALLY HAZARDOUS WASTE GROWTH PROJECTIONS

1974
Industry
1. Batteries
2. Inorganic chemicals
3. Organic chemicals, pesticides
and explosives
4. Electroplating
5. Paint and allied products
6. Petroleum refining
7. Pharmaceuticals
8. Primary metals smelting
and refining
9. Texile dyeing and finishing
10. Leather tanning
1 1 . Special machinery
12. Electronic components
13. Rubber and plastics
14. Waste oil re-refining
Totals (To Date)
Dry
0.005
2.000

2.150
0.909
0.075
0.625
0.062

4.454
0.048
0.045
0.102
0.026
0.205
0.057
10.763
Wet
0.010
3.400

6.860
5.276
0.096
1.757
0.065

8.335
1.770
0.146
0.163
0.036
0.785
0.057
28.755
(Mill.
Amount
Metric Tons/Yr.)
1977
Dry
0.082
2.300

3.500
1.316
0.084
0.715
0.070

4.732
0.500
0.050
0.094
0.036
0.242
0.074
13.795
Wet
0.164
3.900

11.666
4.053
0.110
1.841
0.074

9.104
1.870
0.143
0.153
0.078
0.944
0.074
34.174
1983
Dry
0.105
2.800

3.800
1.751
0.105
0.811
0.104

5.536
0.179
0.068
0.157
0.050
0.299
0.144
15.909
Wet
0.209
4.800

12.666
5.260
0.145
1.888
0.108

10.418
0.716
0.214
0.209
0.108
1.204
0.144
38.089
% Growth*
'74 - '83
2000
40

77
92
40
30
68

24
373
51
54
92
46 *
253
48
*Figures based on dry weight quantities.
-------
PROBLEM RECOGNITION AND DEFINITION
15
(106 METRIC TONS DRY WEIGHT)
[ | TOTAL WASTES

Y//\ POLLUTION CONTROL RESIDUALS
200-

175-

150-

125-

100-

75-

50-

25-
191.6
162.7
147.5
23.1
35.7
1974
1977

YEARS
Figure 1. Projected Growth in Waste Quantities for
Fourteen Industries
disposal practice can be estimated (Table 8). The
primary disposal method employed for hazardous
industrial wastes is lagooning in unlined surface im-
poundments, and this method accounts for nearly
half of the total of these wastes disposed. Lined
impoundments that were considered adequate receive
less than 0.1 percent of the total. Dumps or other
nonsecure land surfaces receive the second largest
quantity. Together, these forms of land disposal
account for approximately 80 percent of the total.
Incineration is the third major management practice
now in use, with uncontrolled incineration account-
ing for almost twice the amount adequately handled
through controlled incineration. The result is that
over 90 percent of the approximately 29 million
metric tons (wet weight) of potentially hazardous
waste generated yearly by the 14 key industries is
handled by disposal practices which do not seem ade-
quate to provide protection of public health and the
environment. This estimate may be somewhat pessi-
mistic because a small percentage of unlined surface
TABLE 8
ESTIMATED ENVIRONMENTAL ADEQUACY OF
DISPOSAL PRACTICES FOR POTENTIALLY
HAZARDOUS WASTES*

Percent of Total Wet
Disposal Practice Weight of Potentially
Hazardous Wastes

Environmentally Inadequate**

Unlined Surface Impoundments 48.3
Non-Secure Landfills 30.3
Uncontrolled Incineration 9.7
Deep-Well Injection 1.7
Landspreading .3
Use on Roads < .1
Sewered < .1
Total 90.4

Environmentally Adequate

Controlled Incineration 5.6
Secure Landfills 2.3
Recovery 1.7
Lined Surface Impoundments < .1
Wastewater Treatment < .1
Autoclaving < .1
Total 9.6

*Based on annual generation in 14 key industries during the
period 1973- 1975.
impoundments and nonsecure landfills may be located
in areas that preclude the escape of pollutants into
the environment. On the other hand, this estimate
may not be so exaggerated if one considers that the
locations for landfills and dumps traditionally have
been selected on the basis of economic rather than
environmental considerations. Waste disposal usually
takes place on land that has little or no value for
other uses, in such areas as marshlands, abandoned
sand and gravel pits, old strip mines, limestone sink-
holes, etc. Most of these sites have hydraulic con-
nections with natural waters. Similarly, most indus-
trial surface impoundments are unlined and were not
sited on the basis of hydrogeological considerations.
Therefore, one could venture to say that up to 90
percent of potentially hazardous wastes are disposed
of by questionable methods and are ultimately sus-
ceptible to escape into the environment.
There are other circumstances underscoring the
significant potential for nationwide damages from in-
dustrial waste disposal. One is that most manufactur-
ing industries are located in the "wet regions" of the
-------
16
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
nation, where groundwater and surface water con-
tamination are most likely. This point can be illus-
trated by superimposing the major areas of industrial
activity on a contour map combining rainfall and
evapotranspiration data (Figure 2). The areas of
maximum rainfall and minimum evaporation are gen-
erally in the eastern third of the nation, where most
manufacturing and, consequently, industrial waste
disposal take place.
A similar map shows where the nation's principal
underground aquifers are located in relation to indus-
trial concentration (Figure 3). One can draw three
general conclusions from this map. The first is that
most areas of high concentration are underlaid by
principal aquifers. The second is that some of the
most heavily used aquifers are located in dry regions
of the nation, where the risk of groundwater con-
tamination from land disposal practices is relatively
small. The relatively small risk is counterbalanced by
the fact that any contamination of these scarce water
resources would result in particularly severe environ-
mental and economic damage. The third conclusion
derived from this map is that many groundwater
aquifers in highly industrialized areas are not current-
ly exploited as major water resources. This inter-
pretation is somewhat misleading, however, since the
map does not designate those areas where ground-
water usage is moderate at present but expected to
increase significantly. From an environmental per-
spective, of course, the risk of groundwater con-
tamination should be viewed with concern, regard-
less of current usage rates.
OTHER SURVEY APPROACHES
The data collected from the 14 industrial waste
studies have been most helpful in presenting a broad
national picture of the hazardous waste management
problems. However, the quantities calculated are
based on a very limited data base. A comparison of
the number of personal visits made to the 14 indus-
trial categories with the actual number of facilities
Figure 2. Precipitation - Evapotranspiration Potential Contours and Industrial Centers of the Conterminous U.S.
-------
PROBLEM RECOGNITION AND DEFINITION
17
Figure 3. Major Aquifers, Well Withdrawals, and Industrial Centers of the Conterminous U.S.
operating, indicates that except for the waste oil re-
refining industry, no more than 7 percent of the in-
dustry was contacted and contributed data (Table 9).
Also, in only five of the industries was a sample and
analysis program performed (most of the samples
collected were grab samples). Additional surveys
should be performed on a smaller scale to increase the
confidence of these data. This could be accomplished
through State ) '.zardous waste surveys and through
information collected through the planning agencies
created under Section 208 of the Federal Water Pol-
lution Act as amended ("208" Planning Agencies).
State Hazardous Waste Surveys
As a first step in managing the increasing hazardous
waste problem, each State should conduct a statewide
hazardous waste survey to establish an information
base. For the short term, this information base will
demonstrate the magnitude of the hazardous waste
problem, document the need for legislation and regu-
lation, and identify the hazardous waste sources and
sinks that should be regulated. Over the long term,
the information base will indicate the effectiveness of
a State's hazardous waste management program. A
good irvey will also help establish surveillance priori-
ties and enforcement actions.

TABLE 9
NUMBER OF PLANT VISITS
Group I
No. Visits
Group II
No. Plants
Batteries
Inorganic chemicals
Petroleum refining
Organic chemicals, pesticides,
explosives
Pharmaceuticals
Paint
Primary metals
Electroplating
15
63
16

53
35
71
53
40
263
1607
247

2200
1058
1550
2717
20,000
Tanneries
Special machinery
Textiles
Rubber & plastics
Electronic components
Waste oil re -refining
28
35
80
85
23
5
386
3906
2000
2150
2855
27
-------
18
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
A comprehensive survey should include facilities
that generate hazardous wastes; facilities that receive
hazardous wastes for storage, treatment, and final dis-
posal; and the collectors and haulers who transport
hazardous wastes. The objective of the survey would
be to establish a statewide mass balance of hazardous
wastes. Surveying only one portion of the hazardous
waste life cycle will not define the total problem.
Authority to Request Data
In a few States, legislation has been enacted to
specifically regulate hazardous wastes. Pursuant to
that legislation, formal reporting, registration, or per-
mit systems are being implemented. The data from
these systems can provide the information necessary
for a hazardous waste survey. In some other States,
the solid waste management legislation is broad
enough to include wastes other than municipal solid
wastes, that is, hazardous wastes. In these cases, re-
porting, registration, or permit systems can also be
used to gather data.
If existing waste-management legislation is not
broad enough to require information from generators,
collectors and haulers, and disposal facilities, it may
be possible to use information-gathering authority
provided in other legislation (for example, air-
pollution-control legislation or water-pollution-con-
trol legislation). States can and have required genera-
tors to provide hazardous waste information with
their water discharge permit applications. This ap-
proach requires coordination with and the coopera-
tion of other State environmental programs.
In situations where a response is mandatory, the
data gathered should be fairly reliable and nearly
complete. Many States, however, will not be able to
use any existing information-gathering authority to
conduct a hazardous waste survey. In these cases, the
States will have to rely upon the good faith of the in-
dustries which they are surveying. States that have
conducted hazardous waste surveys by mail and with-
out data-gathering authority have received less than
50 percent response to their inquiries. Telephone
follow-up to the mailings has increased the response
to as much as 70 percent. Other States without data-
gathering authority have conducted on-site interviews
with potential generators with a much higher success
rate (greater than 90 percent). Therefore, the on-
site interview is the best approach to assure maxi-
mum coverage of hazardous waste sources and also to
minimize data of poor quality. It has been found that
even when industries respond, the reliability of the
data may be suspect, which is due in part to the reluc-
tance of industry to provide data which eventually
may be used to formulate regulations.
Survey Procedure (Onsite)
Each facility that generates or receives a hazardous
waste should be visited, and operating personnel at
each facility should be interviewed, if possible. The
State can achieve greater depth and increased accur-
acy of information, as well as better response rates
from a visit to each generator and disposal facility.
Firsthand knowledge of hazardous-waste problems
gained during interviews will be of lasting benefit to
the State hazardous waste program.
Most State environmental programs have field per-
sonnel (in regions or districts) who can assist in con-
ducting a survey. With minimal training, these indi-
viduals could conduct approximately 20 interviews
per month. Each individual conducting interviews
must receive basic training for the task, and should
review the technical literature before each interview
to familiarize themselves with the types of processes
and wastes which they are likely to encounter during
the interview.
Before actually beginning interviews, the proper
groundwork should be laid by identifying potential
generators and disposal facilities, developing interview
forms, and most importantly, soliciting the coopera-
tion of other organizations (for example, trade asso-
ciations, local health departments, other State agen-
cies, etc.). Without this cooperation, the results of
most surveys would not be as productive and useful.
Each generator, disposal facility, etc., to be sur-
veyed, should be contacted to make an appointment
and to briefly discuss the reasons for the survey.
Potential Generators
Several States have used Standard Industrial Classi-
fication (SIC) codes to identify groups of hazardous
waste generators and have found the codes to be in-
adequate. (SIC codes are established by the Office of
Management and Budget and are published in the
Standard Industrial Classification Manual.) The man-
ual and codes do not identify individual facilities
or potential generators, and they are not as descrip-
tive and inclusive as would be necessary for a com-
plete hazardous waste survey. The electroplating
-------
PROBLEM RECOGNITION AND DEFINITION
19
industry can be used to illustrate the problem. Ap-
proximately two-thirds of the electroplating industry
in the United States consist of "captive shops,"
which are not listed under the SIC code for the elec-
troplating industry. Therefore, if a hazardous waste
survey of the electroplating industry focused only on
those electroplating shops which could be identified
by the SIC codes, many electroplating waste streams
would be omitted.
Manufacturing directories, which may also be
based on SIC codes, do identify specific facilities but
do not include all of the industries which are poten-
tial generators of hazardous waste. Pesticide applica-
tors, utilities (railroads, electric utilities, etc.), mining
operations, and Federal and State facilities are exam-
ples of potential generators that are not usually in-
cluded in manufacturing directory listings. Manufac-
turing directories can also be out of date or incom-
plete. It is therefore recommended that other list-
ings (for example, air pollution emission inventories,
water discharge permit applications, etc.) be reviewed
to expand upon the basic SIC code and manufacturing
directory listings.
The Survey Data Collection Guide
A survey data-collection guide should be developed
and used by all interviewers to insure that they are re-
questing and gathering similar data during their inter-
views. Development of the data-collection guide is
one of the keys to a successful survey because the
types and format of the questions included in the
guide will dictate the quantity, quality, and useful-
ness of the data gathered. An individual with experi-
ence in conducting surveys and designing survey
forms should be consulted for this aspect of the pro-
gram.
Data should be gathered for a base year (for
example, calendar year 1974), so the information on
hazardous waste quantities, technologies, costs,etc.,
will be on a comparable basis with respect to time.
Attachment A is an outline of topics which are con-
sidered appropriate for a hazardous waste survey.
Much of the information described in Attachment
A can be obtained from air pollution emission inven-
tories, water-discharge permit applications, or other
State records. If information is available from these
or other sources, it should not be requested again
in the survey interview. Some of the information may
be considered confidential or proprietary, and will
therefore be difficult to obtain without adequate
authority. The main objective of the survey is to
learn about the life cycle of hazardous wastes. If
specific information concerning hazardous wastes is
not available, hazardous-waste generation rates can be
estimated by using waste generation factors. Waste
generation factors usually require data relating to a
facility's production capacity (for example, 0.324kg
of waste per 1000 kg of product). Comparisons can
also be made with similar facilities of known size,
production capacity, and generation rates to estimate
hazardous waste generation.
Various approaches can be taken in developing
a data-collection guide. Specific guides can be de-
veloped for each industry (electroplating, battery
manufacturing, etc.), or a single survey guide can be
developed to survey the various phases of the haz-
ardous waste life-cycle (generation, transportation,
treatment, disposal, etc.). The advantage of the latter
type of guide is that it is not limited to a single in-
dustry. Each State should tailor the data collection
guide to its individual needs.
Data Storage, Handling and Display
The data gathered during the survey should be re-
viewed for completeness and accuracy, and then
stored so that it is readily available and usable. The
data will probably first be used to produce a survey
report describing hazardous waste management prac-
tices in the State. Topics that would be of interest
for a hazardous-waste survey report include the types,
quantities, and distribution of hazardous wastes with-
in the State; the types, numbers, capacities, and dis-
tribution of treatment and disposal facilities that
handle hazardous wastes in the State; and the flow of
hazardous wastes into and out of the State. In order
to standardize hazardous-waste reporting, quantities
of hazardous waste should be reported on a dry-
weight basis. An estimate of the weight of the water
portion of hazardous waste should also be given.
Projections of future hazardous waste generation
based on growth projections for the State's popula-
tion and industry are also appropriate.
The hazardous waste survey will probably be sub-
ject to refinement as the hazardous waste manage-
ment program matures. For example, if a permit or
registration system were implemented, hazardous
waste generation and disposal data would become
more readily available and more accurate. From
-------
20
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
time to time it will probably be necessary to produce
new or supplementary survey reports to describe the
status of the program. The data storage and handling
system should be flexible enough to permit the
development of summary reports, to track the pro-
gress of the overall program, and to track the progress
of individual facilities.
"208" Planning Agencies
The Federal Water Pollution Control Act Amend-
ments of 1972 delineate water quality goals which
are to be met by 1983 and 1985. The Act calls for
the formation of state and area-wide planning agencies
to "encourage and facilitate the development and
implementation of area-wide waste treatment manage-
ment plans." These plans are to present an integrated
comprehensive system for managing water quality
problems.
Authority to Request Data. The Act calls for
planners to develop techniques to control the dis-
position of all residual waste generated within the
planner's jurisdiction that could affect water quality,
and to control the disposal of pollutants on land or in
subsurface excavations to protect groundwater and
surface water quality [Section 208 (b) (2) (J) and
Residual wastes are defined as those solid, liquid,
or sludge substances resulting from man's activities in
the urban, agricultural, industrial, and mining en-
vironment that are not discharged directly into water
after collection and treatment, if any. Residual
wastes include municipal solid waste, industrial
wastes and sludges, hazardous wastes, and sewage
sludge.
State (or designated area-wide) planning agencies
can develop alternatives to control the disposal of
residual wastes only after assessing the problem,
examining alternative practices, and soliciting ap-
propriate public participation.
Survey Procedure. The term Best Management
Practices (BMP) refers to a practice or combination of
practices that has been determined to be the most
effective and practicable (from a technological, eco-
nomic, and institutional standpoint) means of pre-
venting or reducing the amount of pollution generated
by nonpoint sources to a level compatible with water
quality goals. A BMP does not necessarily imply a
single approach; rather, a BMP for residuals may be
a combination of techniques and practices that must
be integrated into an overall effective residual waste
management system for a given area. This concept
can apply to a hazardous waste management system.
However, before the overall hazardous waste manage-
ment plan is derived, the State or designated area-
wide planning agency should determine the extent
of their problem. A survey technique similar to the
one discussed in the previous section "State Hazard-
ous Waste Surveys," would be most appropriate to
determine the hazardous waste management problem.

SOURCES
1. Abrams, E. F., D. K. Guinan, and D. Derkics [Versar,
Incorporated]. Assessment of industrial
hazardous waste practices, textiles industry.
Environmental Protection Publication SW-
125c. U.S. Environmental Protection Agen-
cy, June 1976. 276 p. (Distributed by
National Technical Information Service,
Springfield, Va., as PB-258 953.)
2. [Arthur D. Little, Inc.] Pharmaceutical industry;
hazardous waste generation, treatment, and
disposal. Environmental Protection Publi-
cation SW-508. [Washington], U.S. En-
vironmental Protection Agency, 1976.
178 p.
3. Battelle-Columbus Laboratories. Assessment of in-
dustrial hazardous waste practices; elec-
troplating and metal finishing industries-job
shops. U JS. Environmental Protection Agen-
cy, 1976. (In preparation; to be distri-
buted by the National Technical Informa-
tion Service, Springfield, Va.)
4. Calspan Corporation. Assessment of industrial haz-
ardous waste practices in the metal smelt-
ing and refining industry. U.S. Environ-
mental Protection Agency, Apr. 1975. 3 v.
(Distributed by National Technical Infor-
mation Service, Springfield, Va.)
5. Executive Office of the President, Office of Manage-
ment and Budget. Standard industrial
classification manual. Washington, U.S.
Government Printing Office, 1972.
6. Foster D. Snell, Inc. Assessment of'industrial haz-
ardous waste practices, rubber and plastics
industry; draft final report. U.S. Environ-
mental Protection Agency, Feb. 1977. 3v.
(In preparation; to be distributed by Nation-
al Technical Information Service, Spring-
field, Va.)
7. Ghassemi, M. [TRW Systems Group]. Analysis of a
land disposal damage incident involving
hazardous waste materials, Dover Town-
ship, New Jersey; final report. Washington*,
VS. Environmental Protection Agency, Of-
fice of Solid Waste Management Programs
May 1976. 121 p. (Unpublished report.)
-------
PROBLEM RECOGNITION AND DEFINITION
21
8. Gruber, G. I. [TRW Systems Group]. Assessment of
industrial hazardous waste practices, organic
chemicals, pesticides, and explosives indus-
tries. Environmental Protection Publica-
tion SW-118c. UJ3. Environmental Protec-
tion Agency, Apr. 1975. [355 p.] (Distri-
buted by National Technical Information
Service, Springfield, Va., as PB-251 307.)
9. Hazardous waste disposal damage reports. Environ-
mental Protection Publication SW-151.
[Washington], U.S. Environmental Protec-
tion Agency, June 1975. 8 p.
10. Jacobs Engineering Co., Inc. Assessment of industrial
hazardous waste practices, petroleum refin-
ing industry. U.S. Environmental Protec-
tion Agency, Nov. 1976. 369 pp. (Distri-
buted by National Technical Information
Service, Springfield, Va., as PB-259 097.)
11. Lund, H. F., ed. Industrial Pollution Control Hand-
book. New York. McGraw-Hill Book Com-
pany, 1971. 1 v. (various pagings).
12. Nemrow, N. L., Liquid Waste of Industry; Theories,
Practices, and Treatment. Reading, Mass.,
Addison-Wesley Publishing Company, 1971.
584 p.
13. Office of Solid Waste Management Programs. Haz-
ardous waste disposal damage reports. En-
vironmental Protection Publication SW-
151.2. [Washington], U.S. Environmental
Protection Agency, Dec. 1975. 11 p.
14. Office of Solid Waste Management Programs. Haz-
ardous waste disposal damage reports; docu-
ment no. 3. Environmental Protection
Publication SW-151.3. [Washington], U.S.
Environmental Protection Agency, June
1976. 12 p.
15. Ottinger, R. S., et al. [TRW Systems Group].
Recommended methods of reduction, neu-
tralization, recovery or disposal of haz-
ardous waste, v. 12. Industrial and munici-
pal disposal candidate waste stream con-
stituent profile reports—inorganic com-
pounds. U.S. Environmental Protection
Agency, Aug. 1973. 334 p. (Distributed by
National Technical Information Service,
Springfield, Va., as PB-224 591.)
16. Porter, C. H. State program implementation guide:
hazardous waste surveys. Environmental
Protection Publication SW-160. [Washing-
ton] , U.S. Environmental Protection Agen-
cy, July 1975. 38 p.
17. Report to Congress on hazardous waste disposal.
[Washington] , U.S. Environmental Protec-
tion Agency, June 30, 1973. 168 p.
[Restricted distribution.]
18. SCS Engineers, Inc. Assessment of industrial hazard-
ous waste practices; leather tanning and
finishing industry. U .S. Environmental Pro-
tection Agency, Dec. 1976. 244 p. (Distri-
buted by National Technical Information
Service, Springfield, Va., as PB-261 018.)
19. Shreve, R. N. Chemical Process Industries. 3d ed.
New York, McGraw-Hill Book Company,
1967.
20. U.S. Congress. Proposed Hazardous Waste Manage-
ment Act of 1973. 93rd Congress. 1st.
sess., Senate, S.1086, introduced Mar. 6,
1973. House of Representatives, H.R. 4873,
introduced Feb. 27, 1973, U.S. Environ-
mental Protection Agency, p. 25.
21. Versar, Incorporated. Assessment of industrial haz-
ardous waste practices, inorganic chemicals
industry. Environmental Protection Publi-
cation SW-104c. U.S. Environmental Pro-
tection Agency, 1975. [various pagings.]
(To be distributed by the National Technical
Information Service, Springfield, Va.; pre-
publication issue for EPA libraries and State
solid waste management agencies.)
22. Versar, Incorporated. Assessment of industrial hazard-
ous waste practices, storage and primary
batteries industries. [Environmental Protec-
tion Publication] SW-102c. U.S. Environ-
mental Protection Agency, Jan. 1975.
[209 p.] (Distributed by National Technical
Information Service, Springfield, Va., as
PB-241 204).
23. Vitberg, A. K., M. L. Rucker, and C. H. Porter. Im-
plementing "best management practices" for
residuals: the waste exchange. Report No.
EPA440/9-76-019. Washington, U.S. En-
vironmental Protection Agency, June 1976.
26p.
24. Wapora, Inc. Assessment of industrial hazardous waste
practices, electronics components industry;
draft. U.S. Environmental Protection
Agency, April 1977. (In preparation; to be
distributed by National Technical Informa-
tion Service, Springfield, Va.)
25. [Wapora, Inc.] Assessment of industrial hazardous
waste practices: paint and allied products
industry contract solvent reclaiming opera-
tions, and factory application of coatings.
Environmental Protection Publication SW-
119c. U.S. Environmental Protection
Agency, 1976. 296 p. (Prepublication issue;
to be distributed by National Technical In-
formation Service, Springfield, Va.)
26. [Wapora, Inc.] Assessment of industrial hazardous
waste practices—special machines manufac-
turing industries; draft report. U.S. En-
vironmental Protection Agency, Feb. 1977.
(In preparation; to be distributed by Na-
tional Technical Information Service,
Springfield, Va.)
-------
ATTACHMENT A
DATA COLLECTION GUIDE
FOR AN
INDUSTRIAL WASTE SURVEY
A. General information (to be obtained from each facility).
Facility name
Facility location ,
Facility owner
Facility mailing address
Facility manager _
Facility contact
SIC group name and four digit number. Primary _
Secondary
Time period for which data is representative
Number of employees Facility area
Telephone no.
Telephone no.
Either obtain a plat of the facility showing the location of onsite process waste storage, treatment, and
disposal from the facility personnel or sketch a diagram of the facility on the back of this page.
B. Waste characterization (applicable to generator, treatment, and incinerator facilities).
Process waste
Process origin .
Quantity of waste
Annual rate
Average hourly
rate
Maximum hourly
rate
Waste stream
composition
(weight basis)
Process products
Quantity

Attach flow diagrams of each process showing product and waste streams, if available.
22
-------
DATA COLLECTION GUIDE FOR AN INDUSTRIAL WASTE SURVEY
23
C. Storage methodology (applicable to generators, treatment and disposal facilities, and collectors and haulers).
Process wastes
stored
Quantity
Type of storage
Frequency of transfer
to the storage area
Frequency of transfer
from the storage
area
Methods of transfer
to and from
storage
Safety procedures
Emergency plans

D. Transportation methodology (applicable to generator, storage, and treatment facilities and collectors and haulers).
Wastes transported
Quantity
Destination
Waste
composition
Special handling
procedures
Emergency plans

-------
24
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
E. Treatment methodology (applicable to generator and treatment facilities).
Wastes treated
Quantity
Composition of
wastes treated
Treatment methods
Equipment used to
treat wastes
Products

Describe the wastes from the treatment facility using the waste characterization portion of the guide.
F. Disposal methodology (applicable to generator, treatment, and disposal facilities).

Land disposal
Waste
Quantity
Composition
Type of disposal
Liner type
Thickness
Leach ate
collection
Depth of facility
Distance to ground
water
Site security
Leachate
treatment
Burial methods
Types of leachate
analysis

Describe methods used to identify and mark the location of hazardous wastes.
-------
DATA COLLECTION GUIDE FOR AN INDUSTRIAL WASTE SURVEY
25
F. Disposal methodology (continued)

Incineration
Wastes
Quantity
Composition
Type of incinerator
Rated capacity
Auxiliary fuel used
Quantity
Design specifications
Temperature
Dwell-time
Air pollution
controls
Air pollution permits
Residue disposal
Waste storage prior
to incineration

F. Disposal methodology (continued)

Other disposal methods
Wastes
Quantity
Ocean dumping
Reclaimer
Well injection
Other
t

-------
Chapter 4
CONCEPTURL FRflfTlEWORK FOR EFFECTIVE
HRZRRDOUS WRSTE mflNRGEmENT
The potential for damage to public health and to
the environment from mismanagement of hazardous
wastes (see Chapter 3) justifies the need for imple-
mentation of an effective hazardous waste manage-
ment program.
Current EPA air and water legislation concerning
pollution discharges focuses on industrial stationary-
source emissions by requiring new source performance
standards and effluent limitation guidelines. Such
requirements on industrial categories are Congres-
sionally mandated. Emission controls appeared neces-
sary because (1) man-made ambient "controls" (other
than water dilution) are impossible, (2) sources are
geographically fixed, that is, each plant is faced with
an immediate problem of treatment, and (3) surveil-
lance and enforcement of emission limits are much
more practical than is waste-load allocation or
ambient-air modeling.
In other words, with regard to air and water dis-
charges, plants are stationary and emit to a moving
receiver (air or water). Thus, regulation at the
receiving end (ambient levels) is very difficult.
Sampling the emissions into the receiving medium and
exercising control at the discharge site is not only
logical but, perhaps, the only practical approach.
Also, with a moving receiving medium (air or water),
it is difficult to establish a direct link between a spec-
ific plant's emission in terms of its effect on the
environment and public health. In the case of air,
this is due to such variables as wind velocity and direc-
tion as well as the ambient levels to which the plant is
contributing. Similar vagaries exist with water dis-
charges. Streams have different flow rates, bottom
sediments have differing sorption characteristics, etc.
Land disposal, on the other hand, is a more readily
controllable medium. The sink (the land) is fixed,
and the wastes entering it are the variables subject to
control in terms of the capabilities of a particular site
to accept specific amounts of certain wastes.
WASTE MANAGEMENT
Industrial hazardous wastes (whether solids,
powders, cakes, sludges, slurries, liquids, or contained-
gases) are a unique problem because they are
transportable, and they may be immediate polluters
of the land as well as future hazards in the air and
water media on both a short- and long-term basis.
Thus, the integrity of the pathways which wastes seek
(land deposition, incineration, chemical treatment,
etc.) is the critical environmental factor to be con-
trolled.
Several important trends are evident from industry-
oriented hazardous waste studies. First, many wastes.
have similar characteristics in terms of the disposal
options selected. Waste disposal practices are usually
determined by the physical properties of the waste
(liquid, sludges, etc.) rather than by its chemical prop-
erties. Analysis of the studies shows more variation
within an industry segment in terms of treatment/
disposal methods than between the industry segments
surveyed. Also, characteristics of several diverse
wastes can often be exploited beneficially at waste
treatment/disposal centers.
Second, since wastes are often transported for
treatment/disposal, and off site treatment and disposal
are a significant private-sector business, waste streams
are not "stationary" in the sense that air and water
emissions are. Because economic waste treatment/
disposal usually requires an accumulation of sufficient
26
-------
CONCEPTUAL FRAMEWORK FOR EFFECTIVE HAZARDOUS WASTE MANAGEMENT
27
quantities for processing, the prospect of waste
movement, and the environmental integrity of such
transport is a major source of regulatory concern.
Finally, land deposition is the most popular waste-
disposal option. Current technological variety is
minimal at present; for many wastes, land disposal is
the process that needs regulation, not industrial
process streams. However, there is a finite amount of
land available for disposal of hazardous wastes.
A hazardous waste management program should
result in creation of a system with certain character-
istics: adequate treatment and disposal capacity,
lowest cost to society consistent with public health
and environmental protection, equitable and efficient
allocation of cost to those responsible for waste
generation, and conservation of resources achieved by
recovering materials and energy from wastes.
The system should combine onsite (point of gen-
eration) treatment of some wastes, offsite (central
facility) treatment for hazard elimination, and secure
land disposal of residues that remain hazardous after
treatment.
WASTE DISPOSITION HIERARCHY
Due to their high potential for public health and
environmental damage, some hazardous wastes require
special control procedures. Management of these
wastes means awareness and control over them from
the time of generation through their transportation,
temporary storage, treatment, and disposal (so-called
"cradle-to-grave" control). This comprehensive man-
agement of hazardous wastes should be conducted or
coordinated at the State level so that wastes may
reach environmentally sound treatment and disposal
facilities. Several States Jiave adopted waste transpor-
tation control systems involving manifests or "trip-
tickets" to monitor these waste flows. Such systems
appear to be the most effective method to assure
proper handling and tracking of wastes from genera-
tion to ultimate disposal. Effective identification and
labeling of wastes by the generators is essential to the
effective operation of any manifest-based system. A
discussion of these topics is contained in Chapter 5 of
this guide.
In addition,managementof hazardous waste means
more than careful disposal. It implies consideration
of alternate methods and schemes, both institutional
and technical, to reduce the amount and hazardous-
ness of wastes.
A hierarchical structure of waste management
options is offered below, based primarily on environ-
mental concerns, while recognizing that economics
will play a major role in the waste generator's decision
process.
Reuse, energy recovery, and material recovery as
well as treatment are desirable prior to ultimate
disposal, especially land disposal. Thus, the desired
waste management options are (in order of priority):
• Waste Reduction
• Waste Separation and Concentration
• Waste Exchange
• Energy/Material Recovery
• Waste Incineration/Treatment
• Secure Ultimate Disposal
Waste Reduction
Reducing the amount of hazardous waste at the
source, through process changes, is desirable. Reduc-
tion of hazardous chemicals used in operations,
substitution of less hazardous materials, and better
quality control to reduce production spoilage are all
examples of possible actions which would reduce the
amount of hazardous waste requiring disposal. The
less hazardous waste to be disposed, the less risk of
environmental damage.
Waste Separation and Concentration
Even with the minimum amount of waste, it is
possible to isolate the more hazardous or toxic waste
streams from the mixtures in which they occur.
Waste separation early in process-stream flows, as well
as simple isolation of similar wastes into separate
disposal containers, can reduce waste handling and
disposal costs. Moreover, isolation of such hazardous
wastes in separate storage areas would permit operat-
ing personnel to focus their attention on careful
management of those wastes.
Concentration of wastes by dewatering (with ap-
propriate air-pollution controls) will reduce the
amount of wastes requiring treatment or disposal.
This process not only reduces the cost of ultimate
disposal but, more significantly, minimizes transporta-
tion costs, which are frequently the major variable in
total waste-management costs. A savings in transpor-
tation costs could offset any added costs of dewater-
ing and might even reflect true savings to the waste
generator. Concentration of the wastes could cause
the waste to be defined as hazardous while it was not
-------
28
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
so in the diluted or watered stage. A trade-off exists
between the cost of handling and disposing of a
smaller amount (concentrated) of hazardous waste
compared to a larger amount of nonhazardous waste.
Waste Exchange
Next in priority is the concept of waste clearing-
houses where pretreated or untreated hazardous
wastes are transferred. These clearinghouses operate
on the principle that "one man's waste can be another
man's feedstock." At least six waste exchanges in
Europe and ten formally organized waste exchanges
in the United States testify to the feasibility of this
concept under a variety of institutional arrangements.
Such clearinghouses are desirable but may only be
feasible at a State or multi-State level. An EPA report
on this subject is available from the National Techni-
cal Information Service, Springfield, Virginia.* Since
this concept is relatively new, additional information
is provided in the next section.
Energy/Material Recovery
Recovery of potentially useful substances, energy,
or materials from hazardous wastes is desirable. Many
wastes contain valuable basic materials, some of
which are in short supply, making material recovery
logical from both resource conservation and environ-
mental viewpoints. Extraction of materials from con-
centrated waste usually requires less energy, and
generates far less air and water pollution, than the
mining and processing operations required to produce
the material from virgin resources. As material
shortages become more widespread, material recovery
from hazardous waste will become more attractive.
Likewise, the combustion of such wastes to re-
cover energy or heat value for other purposes is en-
dorsed. Such operations usually require special high-
temperature equipment with emission control sys-
tems and effluent monitors.
Other limitations are imposed by the "quality
control" aspects of waste utilization for energy. The
user facility must have an adequate supply of fuel
with consistent heat value on a regular or full-time
basis. Also, some provisions must be made for stand-
by or emergency operations. These limitations must
*"Waste Clearinghouses and Exchanges. New Ways
for Identifying and Transferring Reusable Industrial Process
Wastes,"PB-261287.
be carefully considered and integrated into the plan-
ning for any system using industrial wastes for fuel.
Incineration/Treatment
Incineration even without energy recovery is desir-
able, in its proper order of priority-mainly to destroy
organic wastes. Other nonburnable wastes should be
detoxified and neutralized to the greatest extent pos-
sible through physical, chemical, and biological treat-
ment. Careful attention to environmental emissions;
using control equipment and monitoring devices is
still required, regardless of the process employed.*
Alternate treatment techniques are being investigated
by the Office of Solid Waste and several reports will
be forthcoming.
Secure Land Disposal
For those hazardous wastes not amenable to re-
covery, treatment, or destruction, volume reduction
to minimize land-use requirements should be per-
formed prior to secure land disposal. Secure land dis-
posal either through encapsulation of small quantities
of waste or through the use, on a larger scale, of a
chemical waste landfill is recommended.
In general terms, a chemical waste landfill provides
complete long-term protection for the quality of sur-
face and subsurface waters from hazardous waste de-
posited therein, and prevents hazards to public
health and the environment. Such sites should be lo-
cated or engineered to avoid direct hydraulic con-
tinuity with surface and subsurface water flow into
and out of the disposal area. Monitoring wells should
be established, and a sampling and analysis program
conducted. Air emissions should be controlled and
monitored as well. Additional characteristics of a
chemical waste landfill are described in Chapter 6.

WASTE TRANSFER CONCEPTS
(WASTE EXCHANGE)
Waste transfer is both similar to and different
from the purchase and reuse of industrial by-products.
In both cases, an industrial process generates, in addi-
tion to its principal product, some material which is
not usable by the generating company, but which can
be sold economically for reuse by another company.
When the material has a well recognized value that
justifies the costs of recovery, handling, and transpor-
tation, it is known as a by-product. When the mater-
ial has a value which has not been recognized, it is a
potentially transferable waste. As long as disposal
-------
CONCEPTUAL FRAMEWORK FOR EFFECTIVE HAZARDOUS WASTE MANAGEMENT
29
is easy and inexpensive, disposal will be the waste
generator's economically preferred course. Transfer
to another plant or industry is economically attractive
only when disposal presents major problems, as will
increasingly be the case with tighter restrictions and
higher costs.
While some transfers occur directly through the
initiative of either the waste's generator or its poten-
tial user, larger-scale realization of the concept re-
quires a third party or "transfer agent." This is be-
cause the possible uses are not well established,
generators and potential users usually do not know
about each other, and companies are reluctant to re-
veal information about their processes and waste
materials. A transfer agent is needed therefore, to
identify generators and users to each other, while at
the same time protecting confidential information
until a promising match is identified. Even more
transfers can be made if the transfer agent is able to
offer additional services, such as assistance with nego-
tiations, consultation about uses and reprocessing re-
quirements, or actual handling of the materials.
The term "waste" has two meanings that are re-
lated but distinct. It can refer to damaged, defective,
or residual material resulting from an industrial
process, which retains some or much of its original
value; this is "scrap waste" or "scrap." In everyday
usage, "waste" can refer to any kind of refuse, with
no value, which can only be thrown away; this is
"trash waste" or "trash." What is considered trash
by one person may be considered useful by another.
This difference between two values seen in one waste
is central to both the economic and the technical
viability of waste transfer, and creates opportunities
for transfer agents.
Transfers can occur only after many conditions
have been established for both generator and user.
Each, depending upon his own business and perspec-
tive of what is important, must consider the fol-
lowing:
• Technical feasibility the matching of the
chemical and physical properties of available
waste streams with the specifications of raw
materials they might replace.
*Additional information on incineration may be.
found in EPA publication, Incineration in Hazardous Waste
Management (EPA/530/SW-141).
• Economic feasibility balancing of disposal
costs foregone and raw material costs saved
against the administrative and transport costs
of implementing a waste transfer.
• Institutional and marketing feasibility guar-
antees of supply and anonymity; and mutual
confidence among generator, user, and transfer
agent.
• Legal and regulatory feasibility protection
of confidentiality, legality, and unlikelihood of
liability suits.
When generators and users cannot satisfy all re-
quirements for a transfer by themselves, they may
seek help elsewhere. Their first recourse is to in-
formal networks of colleagues. The second is to
professional societies and the advertising columns of
technical journals.
The third is to an information clearinghouse,
which serves the limited function of linking interested
trading partners. A clearinghouse transfers only in-
formation, playing only a passive role in the transfer
process and leaving generators and users to negotiate
directly.
The fourth recourse is to a dealer, reclaimer, or
materials exchange that is equipped to handle, treat,
and certify the characteristics of chemical materials.
Such agents play an active role, because they stand
as intermediaries between generator and user. Of
course, many companies reclaim materials with well-
recognized reuse value.
THE PATHWAY APPROACH TO CONTROL
The differences between air and water pollution
clean-up programs, and programs of hazardous waste
management result from basic differences in the
nature of the problem, such as transportability, simi-
larities in waste treatment, and the threat by hazard-
ous waste to both air and water. These fundamental
differences coupled with the resource/enforcement
problems of other regulatory experiences have led to
the "pathway" control approach.
The regulation and control of the pathways which
wastes follow provide a more effective solution to the
problem of land-destined hazardous residuals com-
pared with control of specific industry by industry
sources. Not only is industry left with more flexi-
bility in terms of disposal options, but also, State
governments can minimize and target their enforce-
-------
30
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
ment and surveillance resources.
This approach permits the State to apply its tech-
nological resources in areas of its chartered expertise,
rather than having to meet challenges as to its knowl-
edge of industrial process techniques. Based on in-
dustry studies, the best regulatory approach seems to
be to channel wastes to environmentally adequate'
facilities, and to let innovative corporate managers
and technical decision makers choose among accept-
able options.
If wastes were free to flow to the most economic
treatment/disposal process, and if these processes
were environmentally sound (pursuant to air/water
emission limits), then environmental integrity and the
public health would be protected. At the same time,
the generating industry would be free to evaluate the
costs of different waste disposal options, both in
terms of impact on the manufacturing process and in
disposition of its wastes. This approach could also
protect any proprietary or competitive positions, by
not prescribing the specific means of compliance
with regulatory controls. Thus, industry would be
free to devise technologies to meet its needs (includ-
ing waste reduction and exchange opportunities as
alternatives to disposal).
Similarities among wastes which can provide use-
ful treatment/recovery opportunities as well as their
ease of movement are also accommodated by regulat-
ing the waste disposal "pathway."
In addition, from the perspective of the State,
resources can be concentrated on surveillance/en-
forcement activities at regionalized facilities as op-
posed to the regulation of thousands of individual
plant sites. Depending upon the costs associated with
off site treatment and disposal, however, some firms
may choose to treat/dispose onsite. These cases
would be handled by requiring permits for these
operations as well.
Included in a permit-oriented approach to regulat-
ing these waste "pathways" or destinations must be
an information system to assure that all hazardous
wastes generated are transported carefully and indeed
are received by permitted facilities. Thus, the con-
cept of waste transport manifests or "trip-tickets'7
has been introduced and is discussed in Chapter 5.
INTRA-/INTERSTATE COOPERATION
In many States, where hazardous waste regulation
is being or has been considered, it is the latest addi-
tion to a series of regulatory authorities. When plan-
ning for or developing legislation and regulations for
hazardous waste control, consideration should be
given to integration with other regulatory/control
authorities. It is desirable to use existing legislation/
regulation to provide the necessary degree of environ-
mental protection without an additional level of
bureaucratic authority. (It will also invite less opposi-
tion from the controlled industries by mitigating
grounds for complaints of overregulation and duplica-
tion of control.)
A prime example of the need for internal coordina-
tion lies in the area of transportation control of haz-
ardous wastes. Many States already have a Public
Service Commission (PSC) or Public Utilities Com-
mission (PUC) (or similar agency) which has regula-
tory control over hazardous material transportation.
From the Federal viewpoint, the Department of
Transportation has interstate authority and, based
on an interpretation of its legislative mandate, indi-
cates that its authority applies equally to intrastate
movements of hazardous materials. Be that as it may,
it would be advisable for the State environmental pro-
tection agency to attempt to use this existing author-
ity, rather than developing its own expertise on trans-
portation control. Morevoer, it may well be within
the legislative authority of the State transportation
authority to modify its regulations to include what-
ever environmental concerns are not already accom-
modated.
Internal coordination should also be pursued in
areas of planning. There may exist agencies that
were created pursuant to Section 208 of the Federal
Water Pollution Control Act, or other regional au-
thorities who have exercised and developed area-wide
planning techniques. These should be consulted and
perhaps integrated into the planning process. The
major concern in using organizations should be with
achieving the necessary environmental protection al-
though the management problems involved are recog-
nized.
-------
CONCEPTUAL FRAMEWORK FOR EFFECTIVE HAZARDOUS WASTE MANAGEMENT 31

These same levels of cooperation and coordination a negative impact on overall industrial growth of a

should be sought on an interstate level. Since State or region Interstate coordination, through a

commerce usually flows freely across state borders, common set of requirements, is more likely to pro-

consistency of regulation (and documentation) is a
, „„ . , , , , ,-, duce the desired environmental protection, since
worthy goal. Materials (and wastes) flow to meet an
. _ , . , there would be no easy way for the "gypsy dumper'
economic market. Over-regulation, such as a pro-

hibition of the importation of wastes, may well have to avoid regulatory control.
-------
Chapter 5
CONTROL OF HRZRRDOUS WRSTE
TRflNSPORTflTION
The primary objective of a comprehensive hazard-
ous waste management program is to assure that haz-
ardous wastes are properly handled to prevent undue
harm to public health and the environment. Elements
of a comprehensive hazardous waste management
program include reporting by waste generators, the
regulation of temporary waste receptors (storage), the
regulation of permanent waste receptors, and the
regulation of hazardous waste transportation. Al-
though control of hazardous waste transportation is
only one element of a hazardous waste management
program, it is a key element. By controlling hazard-
ous waste transportation, a State can follow the flow
of hazardous waste into and out of the State, and
monitor the movement of hazardous waste within its
jurisdiction. The key uses of a waste transportation
control program are to ensure that hazardous wastes
are transported to appropriate waste receptors and to
generate information for planning and surveillance
purposes.
A State's system for the control of hazardous waste
transportation should be developed to regulate all
types of hazardous wastes produced in any form
(liquid, solid, or contained gas) and transported by
any mode (surface, air, or water transport). The basic
elements necessary for a control system are: a licens-
ing system for waste haulers, a permit system for
treatment/disposal facilities, and a hazardous waste
manifest system. In addition, for a comprehensive
hazardous waste management program, there should
be proper containerization; labeling and placarding of
waste containers and vehicles; equipment identifica-
tion and requirements for equipment inspection;
provisions for accident and incident reporting; and
interstate cooperation.

LICENSING SYSTEM FOR TRANSPORTERS
Although not mandatory under requirements of
the Resource Conservation and Recovery Act, many
States have found a licensing system to be useful.
A licensing system should be designed to regulate
the transporter of the waste. Any individual or
corporation wishing to transport hazardous waste
within or through a State's jurisdiction would be
required to obtain a license. Existing State require-
ments for the licensing of intrastate carriers may be
sufficent with specific controls for hazardous waste
haulers. The approval of a license by the State would
indicate that the transporter has the proper equipment
to handle the wastes in a manner which provides for
the protection of public health and the environment.
The State licensing agency may have requirements
respecting operator training, tariffs, routing, insurance
coverage, handling of waste, etc. A license is different
from the permit issued to waste treatment/disposal
facilities in that the major criteria for the issuance of
a permit would be that the facility is designed and
operating in an environmentally acceptable manner as
defined by the State.
In addition to licensing the waste hauler and issuing
a permit to the treatment/disposal site, a State may
wish to require the registration of all waste transpor-
tation and handling equipment.
Equipment identification would make it easier for
hazardous waste shippers, hazardous waste disposal or
treatment-site operators, and State enforcement
personnel to identify equipment that has been
authorized to carry hazardous waste.
32
-------
CONTROL OF HAZARDOUS WASTE TRANSPORTATION
33
Each license applicant should be able to demon-
strate that a viable program for the inspection of the
transport equipment has been established. An inspec-
tion program should include a schedule for equipment
check-ups and a list of specific areas or points that
should be inspected.
HAZARDOUS WASTE MANIFEST
The major purposes of a hazardous waste manifest
are: 1) to provide the State with a means of tracking
the flow of hazardous waste within the State and
with data on the quantities and disposal locations of
the hazardous waste; 2) to certify that the wastes
being hauled are accurately described; and 3) to pro-
vide information for recommended handling, disposal/
treatment, and emergency response.
Hazardous waste haulers would carry a manifest
provided by the shipper which would describe the
hazardous wastes being transported, the composition
of the waste, the quantity of the wastes, specific
hazards, and the precautions which should be taken
in the event of any emergency. At a minimum, mani-
fests should contain the address of the permitted
storage/treatment/disposal site, the hauler, and oppor-
tunity for each party to certify completion of his
obligation. The State may require additional infor-
mation such as identification of the process that
generates the waste, information on the hazardous
properties of the waste, and recommended treatment/
disposal methods.
A certification by the shipper, hauler, and receptor
of the hazardous waste is needed in order to track the
flow of the waste. Certification by the shipper as to
the nature of the waste and its consignment to a
licensed hauler should be required. The carrier should
certify that the waste was hauled to a permitted
storage/treatment or disposal facility and the disposal
facility should certify that the waste was received.
The manifest should be used primarily by the State
as a means of tracking the flow of hazardous waste
within its jurisdiction and insuring the generator that
the waste was delivered. The manifest is filled out by
the waste generator and signed by the hauler. The
generator, who bears the responsibility of selecting a
licensed hauler and designating a permitted facility, is
assured by this process that the waste is being handled
by a responsible carrier. The carrier, in turn, is
assured as to the waste's properties and composition
because they are certified by the generator. After
receiving certification that the waste was received by
the hauler, the generator should maintain a copy for
his records.
Upon delivery of the waste to the disposal facility
and acquiring certification of receipt, the hauler
should maintain a copy of the shipping document for
his records. Again, the certification procedure assures
the hauler that the waste has been received by a
responsible waste disposal facility. For the manifest
system to work properly, the information entered on
the manifest by the waste generator, transporter, and
waste management facility should be made available
to the State. Based on these data, the State will be
able to verify that the hazardous waste has reached its
destination, and that the total amount of waste de-
livered to the transporter was received at the waste
management facility. In addition, data on the
manifest will provide the State with useful informa-
tion on the amounts and points of generation of the
hazardous wastes, and on the disposal locations of the
wastes. The data can also be used as a planning tool
to determine future needs for waste management
facilities.
LABELING AND PLACARDING OF WASTE
CONTAINERS AND TRANSPORT VEHICLES
Each person who offers a container containing a
hazardous material for interstate transport must label
and package in compliance with U.S. Department of
Transportation (DOT) hazardous materials regula-
tions. Proper labeling is important because it indi-
cates the danger while handling, transporting, and
storing the materials. DOT labels represent the desig-
nated classification of the hazardous material (that is,
explosive, flammable, corrosive, oxidizers, etc.). La-
bels are required on all shipments of hazardous
materials, except when an article is classified as ex-
empt from the labeling requirement because of size
and quantity or because of special packaging. Multi-
ple labeling is required for packages containing a
material classed as an Explosive A or Poison A. Mat-
erials that meet the definition of more than one
hazard class must be labeled as required for each class.
In addition, each package containing a material class-
ed as a flammable liquid, a flammable solid or an ox-
idizer, that meets the definition of a Poison B must
also be labeled.
-------
34
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
Many substances that are hazardous to the public
health or the environment (especially due to chronic
hazards) do not presently require distinctive labels
because they are not defined by DOT as a hazardous
material. The Resource Conservation and Recovery
Act of 1976 gives EPA the authority to work with
DOT to accommodate this need.
In addition to proper labeling of all materials, a
carrier may not move a transport vehicle containing a
hazardous material unless the vehicle is marked and
placarded. Any substance which does not require a
label does not require a placard.
A State program for hazardous waste transporta-
tion control must identify materials that are hazard-
ous to the environment and the public health in
addition to those listed in the Hazardous Materials
Transport Regulations (49 CFR 172). The labeling
and placarding requirements of DOT may not be
sufficient for environmental protection, since they do
not indicate that the material may present an environ-
mental hazard. Additional labeling and placarding
may be required to be developed pursuant to RCRA
for any substance designated as hazardous, to indicate
that a public health or an environmental hazard
would exist in the case of a spill or accident.
The additional labeling and placarding of environ-
mentally hazardous materials would notify emergency
response personnel that the material should be
contained and not washed away as a first response to
a spill or accident.
ACCIDENT AND INCIDENT REPORTING
DOT requires that any time there is an uninten-
tional release of hazardous materials (in any quantity),
the carrier must submit a hazardous materials incident
report to DOT. The basic information required
includes: the shipper's name, address, etc.; the
amount of materials released; the hazard of materials
involved; the nature of failure that caused the spill;
and a description of the essential facts of the incident.
To avoid duplicative effort by hazardous waste
haulers, each State may require that haulers submit
copies of the DOT report of accidents or incidents
involving hazardous wastes to the State. The haulers
should include on the report their State license
number.
Section 311 of the Federal Water Pollution Control
Act requires that immediate notification be given to
the Coast Guard in the event of a discharge of a
substance designated as hazardous from a vessel or
from an onshore or offshore facility. Currently 303
substances have been selected; the list of selected
hazardous substances should be promulgated in 1977.
These substances were identified as hazardous because
they present an " . . . imminent and substantial
danger to public health or welfare . . . '' EPA's
hazardous substance spill list is not identical to the
DOT hazardous materials list. The DOT list includes
explosives, compressed gases, and other substances
which do not necessarily constitute a significant
water pollution threat.
INTERSTATE COOPERATION
If a hazardous waste is generated in one State and
transported to another State for treatment or disposal,
the waste hauler may well be required to obtain hazard-
ous waste transportation licenses from the States
which he will pass through. Arrangements to ex-
change information concerning the movement of
interstate hazardous waste shipments are being con-
templated pursuant to RCRA regulation development.
The objective of this information exchange is to be
sure that the hazardous wastes are actually reaching
their assigned destinations and are not being dumped
in transit. There are two occasions on which the ex-
change of information is especially important. The
first occasion is when a State learns from its generator
or license applications, reporting system or other
means, that a waste generated within the State may
be shipped to another State. The other State(s) in-
volved needs to be notified and should respond by
sending license information to the hauler. The second
occasion is when a State learns through a reporting
system that a waste has been transferred from one
State to another. If the waste does not reach its desti-
nation, an investigation should be initiated to deter-
mine the disposition of the waste and the hauler's
fitness to continue to transport hazardous wastes.
CURRENT FEDERAL AUTHORITY
Federal authority for the regulation of interstate
transportation of hazardous materials is shared by the
Interstate Commerce Commission (ICC) and the
DOT. The ICC bears the broad responsibility for ec-
onomic regulation to assure that the public has an
adequate and efficient transportation system under
private ownership. One area of ICC involvement is
-------
CONTROL OF HAZARDOUS WASTE TRANSPORTATION
35
the licensing of interstate common and contract car-
riers of hazardous materials which are considered
property. In order to receive a license to operate, the
carrier must demonstrate the existence of a need for
his service, and his ability to provide the service in a
manner which assures highway safety, and protection
of the public and the environment. The licenses are
issued for a period of 5 years, at which time the
carrier must again demonstrate a need and his fitness
to perform the transportation service. If it is found
that a carrier is releasing hazardous substances to the
environment during the transportation of a hazardous
waste, the State or local government may request that
the ICC not issue or reissue a license for that carrier
to operate in interstate commerce.
According to the Hazardous Materials Transporta-
tion Act of 1974, "... any requirements of a State
or political subdivision . . . which is inconsistent with
any requirement set forth in this title, or in a regula-
tion issued under this title, is preempted." DOT has
indicated that the Hazardous Materials Regulations
may therefore pertain equally to inter- and intrastate
transportation of hazardous materials. The Hazardous
Materials Regulations basically require that all hazard-
out materials be shipped in DOT- (49 CFR 173)
approved containers, tank cars, tank trucks, etc.; that
a shipping paper, which may take the form of a
shipping order, bill of lading, or other shipping docu-
ment, must accompany all shipments of hazar-
dous materials; and that all containers, tank trucks,
etc., must be properly marked, labeled and placarded.
In addition, DOT must be notified in case of an
accident or spill that meets the incident reporting
requirements.
The Hazardous Material Regulations require that
each person who offers a hazardous material for
transportation shall describe the hazardous material
on the shipping paper. Each description of a hazard-
ous material on the shipping paper must include:
1) proper shipping name; 2) the class prescribed for
the material; and 3) total quantity of the hazardous
material. A shipping paper may contain additional
information concerning the material, provided that
the information is not inconsistent with the required
description. In addition, a shipping paper must
contain a shipper's certification that states: "This is
to certify that the above-named materials are properly
classified, described, packaged, marked, and labeled,
and are in proper condition for transportation accord-
ing to the applicable regulations of the Department of
Transportation."

LIMITATIONS OF CURRENT
FEDERAL AUTHORITY
The ICC does not regulate all transportation. State
governments retain jurisdiction within their States, al-
though no part of an interstate movement is subject
State control. ICC does not regulate any intrastate
transportation of goods or materials.
It is important to recognize that the hazardous
materials transport regulations are aimed at protecting
the transport workers and the general public from
acute hazard due to intermittent or one-time short-
duration exposure. EPA believes that substances
should also be considered hazardous because of their
chronic long-term effects or potential for environ-
mental degradation.
DOT has the authority to prescribe and enforce
safety regulations for motor carriers, oil pipelines, rail-
roads, etc., and for the transportation of explosives
and dangerous articles. DOT regulations are concerned
only with safety on the highways, airways, waterways,
or railways, and do not currently address themselves to
environmental protection. DOT has published an
Advance Notice of Proposed Rulemaking (HM-145
FR December 9, 1976), giving notice that it is con-
sidering whether new or additional transport controls
are necessary for classes of materials that present
certain hazards to the public health and to the en-
vironment and that are not currently subject to the
existing Hazardous Materials Regulations. DOT
Hazardous Materials Regulations classify materials
according to their nature; they do not provide spe-
cifically for any classification or designation of a
hazardous waste by name. Instead, the general
methodology is to categorize hazardous materials into
a limited number of generic classifications [for
example—explosives; flammable, compressed gases;
flammable liquids; combustible liquids; oxidizing
materials; and toxic materials (poisons)]. A waste
material may contain a mixture of different active
ingredients having differing hazard characteristics, for
example, flammability and toxicity. Under the DOT
Classification system, Section 173.2, a hazardous ma-
terial having more than one hazard must be classed
according to the following order of hazard. This will
-------
36
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
also pertain to a mixture: 1) Radioactive Material,
2) Poison A, 3) Flammable Gas, 4) Nonflammable
Gas, 5) Flammable Liquid, 6) Oxidizer, 7) Flammable
Solid, 8) Corrosive Material, and 9) Poison B,
Therefore, a waste mixture containing, for example,
acid sludge (corrosive material) and arsenic (Poison B),
is classified only as a corrosive material.
Under the placarding requirements, motor vehicles
containing less than 1,000 pounds of the following
substances need not be placarded:
• Class C Explosives
• Nonflammable Gas
• Chlorine
• Oxygen
• Combustible Liquid
• Flammable Gas
• Flammable Liquid
• Flammable Solid
• Oxidizer
• Organic Peroxide
• Poison B
• Corrosive Material
• Irritating Material
When a vehicle contains a mixture of these sub-
stances, the vehicle may be placarded DANGEROUS.
The regulations being developed under RCRA to
be promulgated April 21, 1978 will address many of
the subjects discussed. Generator standards that im-
pact the transporter will require the labeling of those
materials defined as hazardous waste, the furnishing
of information, the appropriate packaging of the
wastes, and the development of a manifest system.
For the transporter of hazardous wastes, the regula-
tions will address recordkeeping concerning hazard-
ous waste transported; acceptance of waste for
transport; compliance with the manifest system and
delivery of all the hazardous waste to the designated
facility. Delivery standards could include safe opera-
tion of vehicles, accident/spill reporting, and appro-
priate handling of leading containers.
SOURCES
1. Environmental Protection Agency. Hazardous Sub-
stances : Designation, Removability, Harmful
Quantities, Penalty Rates. F.R., December
30,1975. pp. 59960-60017.
2. Hazardous Materials Regulations. Title 49 (Transpor-
tation) Code of Federal Regulation, 1975.
parts 100-199.
3. Interstate Commerce Commission. Washington, U.S.
Government Printing Office, 1974.
4. Transportation Act of 1974: Hazardous Materials;
Title I of Public Law 93-633, 93rd Cong.
HR15223, January 3, 1975. Washington,
U.S. Government Printing Office, 1975. 9p.
5. U.S. Department of Transportation and U.S. Coast
Guard. Pollution by Oil and Hazardous
Substances (Liability) F.R.,March 25, 1976.
pp. 12628-12623.
-------
Chapter 6

LRND USE PND POLICY ISSUES CONCERNING
HPZPRDOUS WASTE mPNAGEmENT
The establishment of an effective State hazardous
waste management program requires the recognition
of a number of policy issues by the decision maker.
The purpose of this chapter is to highlight and elabo-
rate upon issues related to land disposal of hazardous
wastes such as the definition of disposal, safe quanti-
ties for disposal, ground water protection, public land
use, and others. The discussion in this chapter should
serve to focus attention on the need for explicit
consideration of these issues by the State official as
he moves to implement a viable hazardous waste
management program.
DEFINITIONS OF STORAGE,
TREATMENT, AND DISPOSAL
The complexity and structure of a State permit
granting process of the type specified in the Federal
Resource Conservation and Recovery Act of 1976
(RCRA) are affected by the definitions governing
storage, treatment, and disposal.
In Section 1004 of RCRA, the term, storage, as it
applies to hazardous waste, is defined as "the contain-
ment of hazardous waste, either on a temporary basis
or for a period of years in such a manner so as not to
constitute disposal of such hazardous wastes." The
term, treatment, when used in conjunction with haz-
ardous wastes is defined as "any method, technique
or process, including neutralization, designed to
change the physical, chemical or biological character
or composition of any hazardous waste, so as to
neutralize such waste or as to render waste non-
hazardous, safer for transport, amenable for recovery,
amenable for storage, or reduced in volume." The
term, treatment, also "includes any activity or pro-
cessing designed to change the physical form or
chemical composition, so as to render a waste non-
hazardous."
Finally, the term, disposal, is defined in Section
1004 as "the discharge, deposit, injection, dumping,
spilling, 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 con-
stituent thereof may enter the environment or be
emitted into the air or discharged into any waters,
including groundwaters." Although these definitions
draw rough distinctions between sites or facilities
having no or zero emissions to the environment (that
is, storage) and those having some emissions (that is,
disposal), these definitions require that a secure land
disposal site (no emissions) be included in the same
category as a tank farm storing hazardous wastes.

DETERMINATION OF SAFE QUANTITIES
FOR DISPOSAL
Central to the question of permitting land disposal
facilities is the development of a methodology for
considering how much of a particular waste can be
disposed on a specific plot of land without resulting
environmental degradation.
This decision requires:

• the development of a defensible procedure to
make such a judgment in a replicable way and;
• a policy that sets forth the degree of environ-
mental degradation (especially groundwater con-
tamination) allowable in the State.

In order to protect the public health and the
environment, EPA is developing a procedure that
State decision makers can use to evaluate any given
land site for its disposal potential for hazardous
37
-------
38
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
wastes. The procedure might incorporate a matrix, a
set of nomographs or criteria, or a mathematical
model, that will describe what is happening to the
contaminants in the soil.
The modeling of the dispersion of contaminants
through soil involves modeling of two distinct zones:
1) the unsaturated zone and 2) the saturated zone,
which also includes the aquifer (the water table and
below). Most research has been in the latter regime,
the saturated zone and the aquifer. Of most interest
to the State decision maker is the prediction of
activity in the unsaturated zone, because soil attenua-
tion of contaminants takes place mostly in this zone.
The mechanisms of adsorption, absorption, chemical
interaction (ion exchange, bonding and forming of
complex ligands, etc.) occur in the unsaturated zone,
and it is in this zone where contaminants must be
sufficiently attenuated, to protect the groundwater.
Modeling of the unsaturated zone is in its infancy.
Models and analogs do exist which treat this zone, but
they are for very specific contaminants and for very
specific boundary conditions. To be of use for the
implementation of a permit program for the land
disposal of hazardous wastes, a data matrix of waste
types and soil types should be developed based on
experimental and field data. The matrix should
consider the attenuation of wastes separately and in
combination with a range of soil types. The conspic-
uous absence of laboratory and field data addressed
toward the unsaturated zone will hamper efforts to
develop a generalized model for the zone. Further,
the specific applications for describing the attenuation
of wastes in the unsaturated zone require a large base
of very specific laboratory and field data over a long
period of time to calibrate and then to validate the
model.
An extensive data base is required to develop a
viable test procedure for the attenuation of hazard-
ous pollutants in soil for calibrating models of the
unsaturated zone. Additional monitoring data at
untested sites are necessary to validate the adequacy
of the model describing soil attenuation. Thus, only
after a model has been calibrated and validated, can it
be used as a predictor model with reasonable confi-
dence. When such a model is ready for use in con-
junction with a permit program, it must consistently
receive the proper input data, and the actual field site
must satisfy all boundary conditions of the model;
otherwise, the predicted results will be inaccurate. In
such cases, the degree of inaccuracy should be
determined, so that appropriate safety factors can be
applied. Confidence in such a model should be rather
high in order to realize consistent and equitable
decision making by State officials. This requires
concurrent data and model development to fit most
circumstances likely to be encountered in the field.
The use of safety factors will have to be incorporated
to allow for any shortcomings in confidence level and
to be certain that the model errs on the safe side from
a health protection standpoint, when granting permits.
The procedure that is developed to evaluate a given
land site should be analytically capable of assisting in
decision making to support a hazardous waste landfill
permit application and evaluating the attenuation ca-
pacity of various soils and various wastes separately
and in combination, as would be encountered in
typical field conditions. The procedure should also
provide a fairly high degree of replicability in terms
of consistency and repeatability of answers, and
extrapolation to new or untried sites, particularly sites
which may not exactly fit the assembled compara-
tive data base.
Desired inputs for such a procedure might include:
• Information pertaining to how much and what
kind of wastes have been, are being, and will be
deposited at the site being evaluated and the
disposal methods which were and are to be
used.
• Basic information about the soil characteristics,
the hydrogeology, and the climatology of each
disposal site. Wherever possible, predisposal site
conditions should be established for normal
background conditions.
It is important that the data inputs be easy to
obtain by State officials and permit applicants.
Furthermore, permit applicants should not have to
assume an undue financial burden or expend an
excessive amount of time in gathering input data for
the procedure.
The desired outputs of the procedure would
include:
- — — - - *
• A knowledge of how much and what kind of
wastes can be deposited on a given parcel of
land. The effects on the water can be compared
to drinking water standards or other water-
-------
LAND USE AND POLICY ISSUES CONCERNING HAZARDOUS WASTE MANAGEMENT
39
quality standards, such as natural background
levels (where in excess of drinking water stand-
ards).
• A prediction of the maximum potential con-
centration of each pollutant in the groundwater:
both immediately under the disposal site; and
at the owner's property lines contiguous with
other properties downstream of the site. The
model should also indicate when and for how
long this will occur. This information will be
useful for assessing potential long-term changes
and for settling possible court litigation suits.
• Information relating to the transport, distribu-
tion (at any given point or interface in the soil),
and chemical interaction of specific pollutants
through specific soils.
• Information on the attenuation of pollutants in
the unsaturated zone. It is desirable for atten-
uation of pollutants to occur mostly in this
zone so as to maximally protect the ground-
water. The actual mechanisms involved in
attenuation (adsorption, ion exchange, etc.)
need not be known, although this would be
useful information.
In order to facilitate implementation, the outputs
from the procedure should utilize charts, nomographs,
and other visual summary aids in lieu of actual model
runs, wherever this appears feasible.
The development of a predictive procedure designed
to evaluate a specific site for its waste-handling
capabilities will help to insure that land disposal of
hazardous wastes will not pose an undue threat to the
environment.
GROUNDWATER PROTECTION
The State policy with regard to groundwater
preservation/degradation may range from zero dis-
charge (implying nondegradation) to maximum utili-
zation of soil attenuation and dilution (implying some
possible added contamination). Another policy
scheme revolves around allocation of land use based
on aquifer usage. For example, the State of Maryland
is attempting to establish criteria to provide a way of
identifying the underground water supplies that need
to be protected. In this way, the State of Maryland
feels that better decisions can be made as to where
hazardous waste can be disposed. For the purposes of
controlling the pollution of groundwater, the Water
Resources Administration in Maryland has identified
four classes of aquifers and has also established criteria
for groundwater quality. Maryland has also set ef-
fluent limits for any solid, liquid, semisolid or semi-
liquid wastes disposed in aquifers. These limits are
based on the assimilative capacity of the aquifers and
groundwater quality standards, and will be measured
as determined by the Water Resources Administration.
By designating aquifer types and establishing
effluent limits, the Water Resources Administration
hopes to protect those aquifers that are used, or are
capable of being used, for drinking water or agricul-
tural and industrial water supplies.
Aquifers that are not designated as a source for
any types of water supply will be used for waste
storage and treatment. Since all aquifers cannot yield
groundwater in sufficient quantities and of suitable
quality to be useful, the State of Maryland has ruled
that the use of these aquifers for waste treatment and
storage represents a legitimate use of this resource.

THE QUESTION OF USE OF PUBLIC LANDS
Federal Agency Policies
Under RCRA, the EPA and the States have a
responsibility to decrease pollution, including environ-
mental purposes, including hazardous or solid waste
facility sites. Program strategy places emphasis on
private-sector initiatives for hazardous waste manage-
ment.
EPA does not have a formal policy position on the
use of public (Federal, State, local) lands for environ-
mental purposes, including hazardous or solid waste
facility sites. Program strategy places emphasis on
private-sector initiatives for hazardous waste manage-
ment.
The 1973 Report to Congress: Disposal of Haz-
ardous Wastes by EPA includes a short discussion on
the use of public lands. A partial reason for this stems
from the history of the report. It resulted from
Congressional concern about hazardous waste storage
and disposal, which subsequently led to Section 212
of the Resource Recovery Act of 1970 requiring that
EPA prepare a comprehensive report to Congress on
-------
40
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
the feasibility of creating a system of national disposal
sites. EPA research for the report resulted in the
conclusion that strategies other than a national dis-
posal site system should be emphasized for effective
hazardous waste management. This issue under-
standably became intertwined with the use of public
lands, especially Federal lands. To satisfy the require-
ments of Section 212, the report does present, in an
appendix, a comprehensive report and plan for a
system of national disposal sites, including hypothet-
ical locations of ideally located sites, some of which
are on public lands. Unfortunately, this appendix
created confusion because EPA had no intention of
recommending either specific sites or the concept
itself. In fact, EPA does not advocate a system of
national disposal sites involving the Federal Govern-
ment. The Report to Congress, however, did state
that it might be necessary to make public lands
available if adverse public reaction or other reasons
preclude the use of privately owned sites.
Experience does exist in the use of Federal lands
for the processing and disposal of solid waste. The
following discussion is presented to show the extent
of Federal agency involvement in this area and to gain
some insight into problems common to both hazard-
ous and solid waste management.
The Department of the Interior's Bureau of Land
Management (BLM) has State offices in many of the
western States for the management of the BLM lands
contained in a given State. In Colorado, the BLM
leases land to approximately 30 to 40 local govern-
ment units for solid waste landfills. The leases are
generally for a period of 5 years, and the annual
cost is nominal-about 25 cents per acre per year.
After site closure, the terms of the lease require site
restoration by the user which may be a governmental
unit or an independent contractor. The BLM requires
that sites be maintained according to State (Colorado)
standards which are based on EPA guidelines.
Generally, BLM officials do not foresee any
insurmountable problems for municipalities obtaining
BLM lands for solid waste disposal sites, provided that
suitable non-Federal lands are not available. Although
urbanized areas in Colorado are limited, the BLM
officials believe that pressures exist and will be
increasing for the use of Federal lands in Colorado
due to expanding national energy requirements.
Increased oil shale production will generate large
quantities of mill tailings, for example, which will
require proper disposal, and Federal lands are a logical
candidate for that disposal.
The U.S. Forest Service also manages large parcels
of land in Colorado. The Forest Service land is very
mountainous, and access is possible only 4 months
of the year due to heavy snows. However, it does
.have five solid waste land disposal sites which are
basically operated in a manner similar to those on
BLM land. A need for a disposal site must be demon-
strated in that suitable non -Federal lands are not
available and the governmental unit must meet State
standards which are based on EPA guidelines. The
use can be free (for a governmental unit) or on a fee
basis.
Regarding the use of Federal lands for hazardous
waste management, the BLM field instructions pro-
hibit the use of national resource lands for long term
hazardous waste disposal. Their guidance states that
leases be given for a maximum period of 5 years,
and that hazardous wastes that do not break down
into harmless components within that time should not
be disposed of on national resources land. This, in
effect, bans hazardous waste management on these
lands.
Other Issues Concerning Public Land Use
The use of public lands for hazardous waste man-
agement facilities is an intricate subject that overlaps
into many areas related to the overall hazardous waste
management issue (for example, public acceptance
and economic incentives). The remainder of this
section will examine several key issues concerning the
use of public land for hazardous waste management
facilities. The following questions will be discussed:
• Is the use of public land necessary to properly
manage hazardous waste and adequately protect
the environment and public health?
• Will the enactment of the RCRA and related
State laws provide enough incentive to hazard-
ous waste management operators so as to make
additional incentives or the use of public land
unnecessary?
• Can the use of public land be supported on
equity grounds?
Are Public Lands Necessary For Proper Hazardous
Waste Management? The factors that make some
existing public lands attractive for hazardous waste
management facility sites-remoteness and geological
-------
LAND USE AND POLICY ISSUES CONCERNING HAZARDOUS WASTE MANAGEMENT
41
suitability-may mitigate against the economic prag-
matism of the use of such lands. Transportation costs
of shipping hazardous wastes or residuals from their
origin in an industrialized area to suitable public
lands, possibly in a western State, can be prohibitively
expensive. Also, it is possible that public opposition
to the use of public lands-especially for wastes
shipped from an industrialized area in the East to a
western State-might be just as vehement as the
opposition to siting environmentally suitable facilities
in urbanized areas. The actual shipment of wastes
from one State to another calls attention to the
problem of disposal—witness the opposition encoun-
tered in early 1975 by Montgomery County, Maryland,
when it attempted to transport municipal waste to a
privately owned landfill in Ohio. Public opposition
by local Ohio citizens caused the proposal to be with-
drawn. It is purely speculative as to what the
opposition would have been if the disposal site were
on public land. Citizens and environmentalists may
have protested with the same result. Public confi-
dence in long term care may be enhanced by locating
facilities on public lands, but that is not a guarantee.
The objective of environmentally safe hazardous
waste management can be accomplished on private
lands. They can be just as technicaDy acceptable as
public lands. Adequate safeguards can be established
through the promulgation and enforcement of (State)
regulations, and through the use of requirements such
as bonding to ensure compliance and long term care.
The use of public lands is not necessary to protect the
environment and public health, and does not neces-
sarily provide an effective and efficient solution to
hazardous waste management. Further, their use does
not always solve the real problems of long term
security and public opposition to hazardous waste
disposal sites. There may be better ways of attacking
those problems, such as public education and strong
regulation to provide safeguards for the public.
Will the enactment of the Resource Conservation
and Recovery Act provide enough incentive to haz-
ardous waste management facilities so as to make
additional incentives or use of public lands unneces-
sary? The passage of the RCRA is of special
interest to the owners of hazardous waste management
facilities because it is likely to create a substantial
positive shift in demand for their services.
The provision of public lands either to generators
or service facilities for hazardous waste management
is, in reality, a subsidy or type of economic assist-
ance. With the likely increase in demand for the
services of hazardous waste management facilities that
will result from the enactment of RCRA, it is doubt-
ful that subsidies or incentives to the hazardous waste
management industry will be necessary. Enforcement
of the new regulations will create incentives for
development of new facilities by ensuring additional
markets for services. Regulatory activity should
improve the financial soundness of hazardous waste
management firms over time by increasing the rate of
use of these facilities and thereby increasing the prices
they can command for their services.

Can the use of public lands be supported on equity
grounds? A desired goal of environmental legislation
is to shift the costs of pollution control from society
in general back to the specific producers and con-
sumers of the pollution-producing products. In the
particular case of hazardous waste generators or
serviqe firm facilities built prior to hazardous waste
management regulations, an equity argument could be
made for providing assistance to outdated facilities
lacking advanced treatment and disposal technology.
The installation of new technology for established
firms can be costlier than installation performed
during original construction. The prices for hazardous
waste management facility services are not likely to be
affected because the new, more efficient facilities
tend to set prices, and older firms may not be able to
recover higher control costs through increased pro-
duct prices. However, the fact remains that hazardous-
waste-management regulations, in themselves, could
create a new market for the services of hazardous
waste management facilities (which treat and/or
dispose of 20 percent of all hazardous waste) and
could provide them with the business and benefits
that could form the basis of capacity expansion. On
balance, it seems inequitable to provide any additional
incentives, whether they be use of public lands or
some other form of subsidy, beyond the potential
economic stimulus arising from the regulation of
hazardous wastes. If it is one of the goals of the new
legislation to shift the burden of hazardous waste
management from society (the public) to the gen-
erators and consumers, then the use of public lands
cannot be justified on equity grounds.
-------
Chapter 7
FflCILITY OPERflTIONS
One of the most sensitive areas for decision-
making by State officials is the proper operation of
facilities designed to accept hazardous waste. In-
creased attention will be focused on these decisions as
a result of the Resource Conservation and Recovery
Act. Even as national minimum standards for facilities
are being developed under Sections 3004 and 3005 of
that Act, however, decisions must be made as to the
adequacy of ongoing and proposed operations. Thus,
this chapter is intended to highlight topical areas that
should be addressed by decision makers in approving
hazardous waste management facility operations.
Facility operations involve more than the day-to-
day operation of a waste management facility. This
chapter presents the State decision maker with a
discussion of some of the key elements to be aware of
and plan for in the proper storage, treatment, or
disposal of hazardous wastes. The chapter begins
with a discussion on planning for and development of
a hazardous waste management facility. Planning and
development not only involve a determination of the
need for such a facility, but also the site selection.
Site selection depends on various physical and cultural
variables: geologic, hydrogeologic, topographical,
climatic, ecological, and economic factors as well as
public acceptance.
After a facility has been constructed, it is impor-
tant for the protection of public health and the
environment that the facility be maintained properly
both during and after operation. The responsible
operation of an environmentally acceptable facility
from the receipt of the waste to its ultimate dis-
position constitutes a major component in the control
of hazardous waste facilities. Proper facility operation
includes proper handling of the waste; waste com-
patibility in treatment and disposal; safety at the site;
monitoring to assure protection of the environment;
operator training; and financial responsibility. The
final step in the control of hazardous waste facil-
ities is proper closure. The owners need to plan for
site closure, and long term surveillance, and the State
must determine what the future uses of the land will
be.
PLANNING AND DEVELOPMENT
With a data base describing the kinds and quan-
tities of hazardous wastes requiring disposition (see
Chapter 3), the decision maker can begin to consider
the need for facilities to manage such wastes. This
planning effort should be an integral part of the State
planning process for all wastes, to be established under
Subtitle D of the Resource Conservation and Recovery
Act of 1976. In addition, planning, underway or
contemplated pursuant to Section 208 of the Federal
Water Pollution Control Act, will need to be inter-
faced with State decisions regarding hazardous waste
facilities.
Regardless of the planning procedures used to
determine additional hazardous waste facility needs,
conscious decisions must be made as to the degree of
control to be accorded to planning process decisions.
At one extreme, no hazardous waste facilities except
those on an approved State plan would be permitted
to operate. In effect, this position could create State
"franchised" market areas which might ultimately
require economic regulation. On the other hand, a
less detailed plan for facilities with less stringent
facility operating standards opens the door to inade-
quate facilities due to undercutting competition from
42
-------
FACILITY OPERATIONS
43
poorly controlled facilities. Thus, the "mix" between
the degree of flexibility in the planning process and
the stringency of regulations needs to be carefully
balanced to meet the goals desired by the State for
safe environmental control of such facilities.
As an aid in analyzing the need for facilities at the
State level, EPA recently completed a contract report
analyzing the expansion capabilities of the hazardous
waste management industry. This report, Potential
for Capacity Creation in the Hazardous Waste Man-
agement Service Industry*, states a variety of fac-
tors increasing the demand for hazardous waste
management services: air and water pollution control
and land disposal regulations; industrial growth; pesti-
cide controls; and new restrictions on ocean dumping
of wastes. This increased demand for proper disposal
of hazardous wastes will apparently require full
utilization of the existing facilities and additional
construction of new facilities. Today, however, it is
estimated that only 53 percent of the overall capacity
of about 100 facilities operated by the commercial
hazardous waste service industry are currently used.
With the enactment of the Resource Conservation
and Recovery Act of 1976, an estimated 50 to 60
additional sites for commercial use will be needed to
adequately fulfill the demand for proper hazardous
waste handling, treatment, and disposal. (The esti-
mate includes the construction of approximately 20
secure landfills.) Typically, these facilities will be
designed to handle a greater amount of waste mater-
ials than current operations and will, in most cases,
offer both chemical treatment and incineration.
In order to determine whether a new facility is
needed or increased utilization of existing facilities
will adequately serve the future needs of the com-
munity, the distribution and current utilization of the
industry must be examined in a given geographic area.
On a national basis, the geographic distribution of
sites is concentrated in EPA Region II, V, and IX as
shown in the following list. These regions contain
approximately 60 percent of the sites. (EPA regions
are listed in Table F-l in Appendix F.)
EPA
Region

I
II
III
IV
V
VI
VII
VIII
IX
X
Percent of Total
6
16
8
6
25
9
7
1
17
5
Of the 110 facilities identified in the report as
hazardous waste management facilities, only nine are
municipally controlled. Eight of the nine are located
in Region IX and one is located in Region III.
Hazardous waste management facilities provide a
variety of services to customers in their own State
and other States including chemical treatment, incin-
eration, secure landfill, resource recovery, and deep
well injection of the hazardous wastes. Table 10

TABLE 10
FACILITY UTILIZATION (PERCENT UTILIZATION)

EPA Chemical Secure Deep Well Resource
Region Treatment Incineration Landfill Injection Recovery
I
II
III
IV
V
VI
VII
VIII*
IX
X
45
50
45
60
50
40
50
--
80
50
30
50
75
60
65
40
75
--
80
--
30
50
30
40
50 75
50 75
60

80
30
50
60
50

50
60
60
--
75
60
*Only one facility. Source:
industry interviews.
Foster D. Snell, Inc.
*Potential for Capacity Creation in the Hazardous
Waste Management Service Industry and Environmental
Protection Agency, August 1976 (PB-257 187).
shows the current estimated utilization as compared
to process capacity of the facilities nationally. The
highest facility utilization is in Region IX for all
processes, with the lowest in Region I.
Future treatment and disposal capacity of the
hazardous waste management industry is dependent
upon expansion plans, capital expenditures necessary
for regulatory compliance, and elimination of environ-
mentally inadequate disposal options as required
-------
44
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
under the Resource Conservatory and Recovery Act
of 1976.
SITE SELECTION
Assuming that the need for some facilities is
established, the decision maker is faced with the issue
of approving and/or participating in the selection of
specific sites for such facilities. Site selection should
be viewed as a phased decision process. The first
phase, site screening, should include the establishment
of a minimum set of criteria (by the State) that must
be met in order for the prospective site to be con-
sidered as a candidate for further investigation by the
owner. Site screening is the process of identifying and
evaluating a parcel of land for its suitability as a
hazardous or chemical waste land disposal treatment
or storage site. Specific site-screening criteria should
cover characteristics the site must possess naturally or
which can be achieved through modification. Geo-
logic, hydrogeologic, topographical, climatic, ecolo-
gical, and cultural aspects must first be examined
before any sites are considered for potential construc-
tion of a hazardous waste management facility. Eco-
nomic feasibility (cost benefit) and public acceptance
of the site may ultimately decide the fate of a
proposed site. The screening criteria based upon the
above parameters should ideally be set up to be
judged by the owner of the site on a simple accept-
able or nonacceptable basis. Either the site meets the
set of criteria or it doesn't.
Site screening can be used by the private sector as
an effective means of eliminating unacceptable sites,
for the construction of a hazardous waste facility
(treatment, storage, disposal), based upon minimum
criteria identified by the State.
A useful tool for the evaluation of site screening
criteria is a "decision tree"-a flow chart of "yes-no"
decision points (Figure 4). The desirable quality of
an individual site parameter is stated at each decision
point. In total, the "tree" constitutes a minimal set
of environmental parameters important to maintain-
ing the environmental quality of a given site.
Presented is an example of a "decision tree" and
general criteria for a hazardous waste disposal site
(Figure 4). The State decision maker should develop
specific site screening criteria for hazardous waste
disposal treatment and storage facilities. The criteria
for treatment and storage should address many of the
same parameters considered for the disposal facility.
By no means should the "tree" be interpreted as
necessarily representing the complete universe of
parameters, or the order in which they must be
evaluated. Other criteria established by the State such
as soil types, waste types to be handled, engineering,
cost/benefit analysis, legal issues, economic con-
straints, etc., may affect the site review and selection
process.
A naturally secure disposal site would be any site
whose set of environmental conditions satisfied the
parameters of the "tree" with no site modifications
required.
Geological
Hazardous waste management facilities should not
be located in areas where the geology of the site
presents an unstable environment. Sites exhibiting
historical seismic activity, karst landforms, landslide
potential, soil slump or solifluction, subsidence, vol-
canic or hot spring activities, etc., should be carefully
examined before the site is selected. In many loca-
tions, these areas cannot be avoided. Therefore, site
modification will be necessary.

Hydrogeologic
Location of a hazardous waste management facility
above a useful aquifer may necessitate site modifica-
tion to prevent leachate from reaching the water
table. This may include some form of leachate
collection coupled with a final capping of the site
after completion. It is important, therefore, to be
aware of the location of all useable aquifers along
with all perched water tables.
The groundwater within the saturated zone may
be an important water resource for drinking, agricul-
ture or industry; therefore, it is important to consider
its potential for use. Groundwater availability may
be estimated from the saturated zone's productivity
(pumpability). Productivity evaluations should be
based on local conditions, including the availability ,
of good quality groundwater resources and anticipated
demand for water from aquifer(s) in question. Satu-
rated zone discharge points, including perched water
tables, should be identified and mapped at the site. If
there are potential water supply points between the
site and the discharge points or if the perched water
table discharges outside the drainage area defined by
-------
FACILITY OPERATIONS
45
GEOLOGICAL

ACTIVE FAULTS
SUBSIDENCE
KARST LANDFORMS
ETC. . .
©
HYDROGEOLOGIC
LOCATION ABOVE AQUIFER
PERCHED WATERTABLE
USE OF GROUNDWATER
SOIL MOISTURE CONTENT
©
HAVE/CAN MODIFICATIONS
BEEN/BE MADE TO CORRECT
CONDITION?
NO
-REJECT
NEXT DECISION YES
TOPOGRAPHICAL
FLOODING
ERROSIVITY
ONSITE RETENTION
©
CLIMATIC
PRECIPITATION
RUN-OFF
©
CULTURAL
VISUAL AESTHETICS
©
CULTURAL
ACCESS LAND-USE
-»- NOT ACCEPTABLE-REJECT
CULTURAL
PUBLIC ACCEPTANCE
-^~ NOT ACCEPTABLE-REJECT
ECOLOGICAL
-^~ NOT ACCEPTABLE-REJECT
PROCEED TO SITE SELECTION
Figure 4. Decision Tree
-------
46
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
the site, measures should be taken to prevent con-
tamination of surface and groundwater from the
leachate. One such measure is the use of a double
liner arrangement with a leachate collection system
between the liners.
In addition to groundwater, the inherent soil-
moisture content will influence site selection. Field
capacity is the amount of soil moisture held in the
unsaturated zone against the normal downward pull
of gravity. Field capacity is expressed as either
moisture content per unit of soil weight, or as inches
of water per foot of soil. Procedures for making field
capacity determinations are described in the "Hand-
book of Soil Survey Investigations Field Procedures,"*
published by the U.S. Soil Conservation Service.
Field capacity measurements should be used as
indicators of the unsaturated zone's moisture-
conducting potential because of its positive correla-
tion with other soil parameters (such as texture), that
retard the rate of soil-moisture movement. If wastes
containing free moisture are permitted to be disposed
at the site, it is important that the unsaturated zone
contain enough available storage capacity to accom-
modate this free moisture.
If the field capacity is not sufficient to hold all of
the moisture associated with the waste, it is still
possible that the physical and chemical properties of
the soil may be capable of attenuating pollution
materials via ion exchange or reducing transport to
the aquifer below. If the available storage capacity is
sufficient in itself, it maynot'be necessary to go to the
expense and trouble of determining soil attenuation.
If the field capacity is not sufficient, however, and
there exists insufficient attenuative properties to pre-
clude potential contamination, then the use of
engineered modifications (liners, leachate collection,
etc.) will be necessary to reduce or eliminate leaching
from the site.
Topographical
The main topographic constraints that may render
a site undesirable for hazardous waste treatment,
storage, or disposal are susceptibility to flooding,
erosivity, and offsite drainage runoff.
The site should not be located in a flood plain,
shoreland, wetland or any other area subject to
inundation. If no such area is available, trade-offs
will have to be made. Erosion and sedimentation,
considered to be a nonpoint source of pollution,
should be containable within the site's boundary.
Areas with highly erodible slopes pose a problem to
site operations and should therefore be avoided. The
site should also contain sufficient area for the con-
struction of a runoff-holding pond to retain surface
and subsurface runoff which may contain soil as well
as hazardous substances in solution. Several EPA
publications provide useful information and are avail-
able from the U.S. Government Printing Office.*
Data necessary to make the soil loss calculations are
readily available from the US. Soil Conservation
Service.
Climatic
The primary climatic features which may adversely
impact on a site are the amount of precipitation and
incidence of severe storms. Surplus precipitation will
cause surface runoff and water infiltration through
the soil. Leachate, as a result of infiltration, will be
transported downward only as far as the water is able
to penetrate. If precipitation exceeds evapotranspira-
tion for any length of time, there is the potential that
the leachate will reach the groundwater. This,
however, depends upon local soil and hydrogeologic
conditions.
Because seasonal recharge may occur during a
period in the site's annual climatic cycle when precipi-
tation is excessive, the annual ratio of precipitation to
evapotranspiration is not the only indicator of
groundwater infiltration potential that should be
examined. More accurate indicators of infiltration
potential include weekly and monthly comparisons
of evapotranspiration and precipitation rates. Soil
permeability and the water-holding capacity of the
soil will also influence the amount of leachate
infiltration. This will vary from soil to soil and
*Soil Conservation Service. Handbook of Soil Survey
Investigation Field Procedures, U.S. Department of Agricul-
ture . Government Printing Office, Washington, D.C.
*Methods for identifying and evaluating the nature
and extent of nonpoint sources of pollutants (EPA 430/9-
73-014).
Processes, procedures, and methods to control pol-
lution resulting from all construction activity (EPA 430/9-73-
007).
Comparative costs or erosion and sediment control
construction activities (EPA 430/9-73-016).
-------
FACILITY OPERATIONS
47
therefore should be determined by soD analysis of the
potential site.
Runoff, that residual of rainfall that does not
infiltrate into the soil, depends on such factors as the
intensity and duration of the precipitation; the soil-
moisture content; vegetation cover; permeability of
the soil; and the slope of the site. Hazardous
constituents that may have percolated up to the
surface of the site could be carried off in the runoff.
Therefore, the runoff from a 100-year storm or
annual spring thaw, whichever is the greater, should
be containable by the site's natural topography. If
not, berms, dikes, and other runoff control measures
should be constructed to modify the site. (Runoff
may be estimated by applying the coefficients used to
design surface water drainage systems.)*
Minimum criteria for the above parameters should
be established by the State decision maker and
applied to the site by the prospective owner. If the
minimum standards are not achieved at the site, it
should either be rejected or undergo site modification.
For the ecological and cultural parameters, the option
of rite modification does not exist-the site is either
acceptable, or it is not.
Ecoiogj'cal
Since it is difficult to assess the limitations of an
ecosystem without initiating an exhaustive and time-
consuming study, it is recommended that site selec-
tion avoid areas which are undeveloped, including
wetlands and marshes, grazed and ungrazed grassland,
grazed or ungrazed forest and woodland, and eco-
systems which are in a delicate balance. Whether a
rite is a habitat for rare and endangered species or
used seasonally by migratory wildlife are also factors
to be determined before selection of the final site.
Cultural
Cultural site features are those elements that are a
direct result of human activities which modify and
effect the rite's desirability for hazardous waste
disposal-access, land-use, and aesthetics.
Adequate access to the rite should minimize both
the transportation costs and the risk of accident or
property damage. Distance from the waste source and
route congestion and suitability for bulk cargo
*Chow, Vente. Handbook and Applied Hydrology—A
Compendium of Water Resources Technology. McGraw-Hill
Book Co., New York, 1964, 14180.
vehicles are elements that must be considered for site
selection by the prospective owner of the rite.
Land areas zoned for nonresidential uses and areas
with adequate buffer zones should be considered as
possible locations for the siting of a hazardous waste
management facility. Heavy and light industry as
well as unproductive agricultural lands are preferable
land^use zones-reridential, commercial and recrea-
tional zones, on the other hand are not recommended
disposal rites. Whether zoned or unzoned, the
proposed site should ideally contain sufficient land
area to provide a concentric ring of unoccupied space
as a buffer zone between active storage, treatment,
and disposal areas, and the nearest area of human
activity.
Visual aesthetics are best measured by the unaided
eye. Line-of-right observations from commercial
business, residential or recreational areas should be
screened from the facility's activities. Vegetation,
topography, distance, and artificial barriers are all
potential means of modifying the site to achieve the
desired effect.
After all of the data are collected and analyzed, the
prospective owner will have to evaluate each param-
eter and decide what trade-offs will be necessary for
final site selection. Each parameter will have to be
assigned a "level of importance" to the community
and compared to the other rite-selection elements.
According to the location of the rite and specific rite
characteristics, each parameter may be assigned dif-
ferent values. For example, in California the location
of geologic faults will greatly influence the siting of a
hazardous waste facility, whereas in Florida, seismic
activity need not be considered. Trade-offs will then
have to be made for final site selection. In the final
decision process, a specific decision maker may be
able to trade-off access to paved roads, for example,
against the acreage of the site which would have to
be set aside for a water run-off catchment barin.
Public Acceptance
No matter in how much detail the above param-
eters are examined for the selection of a hazardous
waste management facility rite, public acceptance or
rejection may ultimately decide its fate. One of the
most difficult problems faced by the decision maker
(or the applicant) is that of gaining public approval
from a community for the construction of a waste
management facility.
-------
48
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
The first step toward the formation of favorable
public attitudes is for the prospective owner to design
and present to the community a comprehensive plan
for an environmentally safe, economically viable, and
aesthetically pleasing facility.
The comprehensive plan should include data on:
the population (industry) to be served; land avail-
ability and suitability; economic resources; zoning and
environmental regulations; and transportation net-
works. The comprehensive plan should also cover
management of the facility, manpower requirements
of the facility, financial needs, and implementation of
the plan.
The prospective owner must decide at what point
the public should become involved in the selection of
the site, and type of facility to be built. Public
participation in the planning stages may be a time-
consuming process; however, for the success of the
project, the public should be informed as early as
possible that a hazardous waste management facility
is being planned.
Even if every possible consideration were taken by
the planning body to provide an economically and
environmentally sound hazardous waste management
facility, there would still be no guarantee that the
project will be welcomed with open arms by the
community. Many times citizens look on hazardous
waste management facilities with distrust. This is
particularly true for sanitary landfills. The term
"sanitary landfill" normally has an unfavorable conno-
tation for many people. Often this type of facility is
associated with the unsightly, foul smelling, open
"dumps" that are still in use today.
An information and education program can help
to alleviate this problem by enabling the public to
take an active role in both the planning and operating
stages of the new facility. Furthermore, an informa-
tion program can increase public awareness of the
environmental benefits of a well-planned and well-
constructed facility, as well as the environmental cost
of unmanaged hazardous waste.
There are many ways in which to conduct a public
information/education program. Use of media, public
participation, citizen advisory committees, and door
to door canvassing are only a few methods commonly
employed to gain support.
The planner should begin the public information
program by explaining why a particular type of
facility is needed and the logic of its proposed loca-
tion. Emphasis should be placed upon the benefits
that will be realized from the facility both economi-
cally and environmentally. It is important for publip
awareness that the information go to all of the various
interest groups that should'be involved with the
project. Political leaders, public officials, environ-
mental groups, as well as public interest groups and
industry should be notified. Adjacent property
owners, although often not organized as a group,
probably have the most to lose from a poorly
conceived facility. Therefore, they should also be
made aware of and have an opportunity to input to
the decision-making process.
Increasingly, a situation exists where community
groups have opposed and successfully blocked the
construction of various private and public facilities.
For this reason, it may be necessary for the prospec-
tive owner to provide these groups with some form of
"additonal benefit" to serve as an incentive and
thereby increase the realized benefits.
Additional benefits to the community may involve,
for example, site restoration to facilitate a park or
recreation area. It must be kept in mind that if
"additional benefits" are to be successful in winning
public acceptance, the facility should be environ-
mentally and economically acceptable.
OPERATION OF FACILITIES
Once the facility is sited and constructed, proper
operation is necessary to protect and prevent adverse
impacts of the facility on the public health or to the
environment.
Proper facility operation, on a day-to-day basis,
includes proper handling of the waste, access to
laboratory facilities for waste analysis, treatment and/
or disposal; safety at the site; monitoring to assure
protection of the environment; operator training; and
financial responsibility of the owner.
The State decision maker should allow disposal of
hazardous waste only at permitted, approved facilities.
The criteria used for the permitting should allow the
State to close facilities that are not being operated in
an environmentally acceptable manner or which are
exceeding the established criteria.
-------
FACILITY OPERATIONS
49
Proper Handling Waste Comparability
Proper handling of the waste to include treatment
and disposal is needed in order to prevent environ-
mental damage. Without proper handling, there is a
danger for fire, explosion, and gas generation that can
arise from the haphazard mixing of wastes which are
not compatible. While empirical data exist concerning
the consequences of reactions between pure sub-
stances under laboratory conditions, very little work
has been done in the field of waste combination
reactions. Very seldom are wastes pure substances.
They are usually sludges, emulsions, suspensions or
slurries containing many different components. In a
landfill, these mixtures will not react in the same
manner that the pure substances comprising them
react in the laboratory. This is due to differences in
concentration, rates of mixing, heat capacities of the
surroundings, and the presence of other components
in large or trace amounts which might accelerate or
decelerate the reaction.
It-is evident from existing data that the largest
dangers inherent from incompatible reactions involve
strong acids or bases. Large deviations of the pH of a
waste from neutrality will also interfere with soil
attenuation, and can solubilize and release heavy
metals and other contaminants that might otherwise
be bound. For these reasons, it is desirable that acids
and bases be neutralized to within a pH range of 4.5
to 9 before being mixed with other wastes (possibly
acidic and basic wastes could be mixed in a controlled
manner to achieve pH neutrality). Even within this
restricted pH range, acids should be segregated from
acid-soluble sulfide and cyanide salts.
Wastes that are particularly toxic, including beryl-
lium, asbes is and all pesticide wastes, should be
segregated from highly flammable wastes, since fires
provide a ready vector for these wastes to enter the
immediate environment.
Also, wastes that react violently with water, or
react with water to give off a noxious or toxic gas
(wastes containing phosphorous trichloride, phos-
phorous pentachloride,thionylchloride,and elemental
sodium, potassium, or magesium) must be encap-
sulated in a moisture-proof container before land-
filling.
With the above inclusions, an example of a compat-
ibility matrix is depicted in Figures 5 and 6.* If it is
AMINES &
ALKANOL AMINES
HALOGENATED CMPDS
PEROXIDES & ETHERS
ALDEHYDES &
KETONES
MONOMERS &
POLYMERIZABLE ESTERS
ALKYLENE OXIDES,
NITRILES &ACID ANHYDRIDES
OXIDIZING AGENTS
1
V
X

x
x

5
X-
DENOTES INCOMPATIBILITY
DO NOT FORM THE FOLLOWING COMBINATIONS:
LEAD OXIDE WITH:
SODIUM ARSENITE WITH:
SODIUM ARSENITE
SODIUM CACODYLATE
SODIUM CHLORIDE
LEAD OXIDE
GOTHION
2, 4D
DEMETON
Figure 5
ACIDS
CAUSTICS
AMINES &
ALKANOL AMINES
HALOGENATED CMPDS
PEROXIDES & ETHERS
ALDEHYDES 81
KETONES
MONOMERS &
POLYMERIZABLE ESTERS
ALKYLENE OXIDES
NITRILES & ACID ANHYDRIDES
OXIDIZING AGENTS
1
x
x
X
X
X
x
X

X
x
><;
X
x

3
x
x

x
X

7
X-
Figure 6
-------
50
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
not feasible to neutralize acrid wastes and/or caustics
to within the prescribed pH range, then the matrix in
Figure 6 should be used. The successful use of any
compatibility system depends upon the labeling of
wastes to conform with the generic names used in the
system. These matrices will be modified and updated
as further information concerning waste compatibility
becomes available.
Facility operators should be aware of the problems
with mixing of incompatable wastes and, if at all
possible, guard against such practices. If consistent
mishandling occurs at a facility, the State can opt to
revoke the operation permit.
Training
Training of waste management facility personnel in
safety, first aid, and facility operation is another
important aspect of overall facility management. All
site personnel should undergo some sort of training
either in a classroom environment or on the job site.
The type and degree of the training will vary with the
responsibilities of the site personnel.
Site Personnel
A hazardous waste facility should have a manager,
a supervisor, and a technical advisor. The manager
should be responsible for the overall management of
the hazardous waste facility, knowledgeable about site
operations and equipment design, and able to give
specific waste handling instructions and safety pre-
cautions to the supervisor and equipment operators
on a continuing basis in consultation with the
technical advisor. The supervisor will direct the
everyday waste treatment/disposal activities and en-
sure that proper waste handling procedures are fol-
lowed and safety regulations are enforced. Other site
personnel, heavy equipment operators and laborers,
will be under the direct supervision of the supervisor.
The technical advisor should be available to answer
questions relating to waste compatibility and the
hazards of chemical toxicity, flammability, reactivity,
etc. The three positions, supervisor, manager, and
technical advisor fill the anticipated needs at an
average hazardous waste management facility; how-
ever, the operational needs of the facility may be
*UnpubIished Paper: Viviani, Don., A Rationale for a
Waste Compatibility Matrix. US. EPA Hazardous Waste
Management Division.
filled by fewer than the three people, since one person
may be able to perform more than one of these
functions.
Training Needs
The need for training and safety requirements
peculiar to the hazardous waste management industry
has been debated. In a recent series of public
meetings held by EPA in December 1975, several
industry representatives questioned the need for
safety and training requirements beyond those regula-
tions the Occupational Safety and Health Adminis-
tration (OSHA) already have in effect for products of
comparable hazard within the chemical industry.
Many in the hazardous waste management-service
industry believe that the most important safety
precaution is the proper characterization and identifi-
cation of hazardous waste. Therefore, it is very
important that the facility supervisor be able to
recognize the hazards associated with each of the
chemical wastes managed at the site. Training of the
management personnel should focus on operational
procedures of the facility, special handling procedures
for the hazardous waste, occupational safety, first
aid, and industrial wastes.
Employee safety is an important aspect of proper
facility operations as well. OSHA standards for safety
in the workplace should be enforced, and any viola-
tions recorded in the event of permit review. State
environmental officials may need to highlight for
State or Federal occupational health agencies the
unique problems involved at waste management-
facilities.
It would seem desirable that supervisor/manage-
ment personnel have either a degree in chemistry or
chemical engineering or have a strong background in
the subject matter. All site employees should be given
training on facility operations by the plant manage-
ment. In addition, site employees should be required
to attend a basic safety course. Areas of instruction
should include accident prevention, occupational
safety, first aid, and hazardous waste handling pro-
cedures. A basic safety course currently offered by
the National Safety Council is entitled, "Safety in
Chemical Operations." Because each facility may
have unique operations and handling requirements it
will be necessary for the management personnel to
provide additional training unique to the site involved.
-------
FACILITY OPERATIONS
51
Monitoring
In order to protect against pollution of surface and
groundwater, the site should have monitoring equip-
ment. Samples should be taken of the surface and
groundwater to determine if the facility is polluting
the water. In the event pollution is detected,
corrective steps can be taken. Also, monitoring of the
air quality and noise levels at the site should be
undertaken. Chapter VIII deals with some of the
sampling and analysis facets of this issue in detail.

Fiscal Responsibility of Owners - Insurance
The owners and operators of any waste manage-
ment facility have a responsibility to the public to
operate in a manner which will not adversely affect
the environment or the public health. Within the
broad realm of this responsibility is the financial
responsibility of the owner to acquire financial
protection against liability. The amount of financial
protection required by the waste management facility
should be the amount of liability insurance available
from private sources. It is assumed that the private
insurance industry will be able to provide adequate
liability coverage. A hazardous waste management
facility ideally should be required to obtain coverage
over all aspects of operating a hazardous waste facility
including transportation, contamination incidents,
and other risk activities associated with long term
consequences, even after closure of a facility and/or
a change in ownership. The protection should extend
to any persons who may be legally liable for a hazard-
ous waste incident.
The policy should cover liability for bodily injury
and property damage, and should contain a single
aggregate limit of liability for all losses and loss
expenses for bodily injury and property damage
arising during the policy period.
The service firm, as a condition for seeking
insurance, would be required to meet all State or EPA
standards associated with the operation of a hazard-
ous waste facuity. By the same token, a permit
application must contain the names and addresses
of the applicant's current or proposed insurance
carriers, including copies of insurance policies in
effect.
Closure of Facilities
The final step in the control of hazardous waste
facilities is proper closure of the hazardous waste
management facility. Because hazardous waste con-
stituents may enter the environment after the day-to-
day maintenance of the facility has ceased, the owners
of the facility must plan for site closure and long term
surveillance, and the State must consider future uses
of the land. The funding requirements of the plan
must be estimated, and a means derived to acquire the
necessary funds.
Landfills for hazardous waste disposal will ulti-
mately reach capacity and must be closed; but the
potential for harmful occurrences would still remain.
Regardless of the kind of firm originally or currently
owning such a facility (whether public or private),
liability for damages is an important fact or burden
that someone will have to bear. The possibility
certainly exists that the owner and operator of a
closed hazardous waste facility still under his owner-
ship could be held liable for long term damages.
The problem is more complex when ownership has
changed. In order to provide protection in the event
of future occurrences after closures, the liability
insurance requirement might include coverage for
long term damage regardless of whether ownership is
retained or not.
The advantages of this system are as follows:
(1) it is easy to implement and involves minimal cost
to the government; (2) the private sector (insurance
carriers) operates the liability insurance mechanism;
(3) it is self-enforcing, that is, if a company cannot
afford the insurance, it does not qualify for a permit;
and (4) it provides current and future liability protec-
tion against hazardous waste occurrences.
The disadvantages of this system are as follows:
(1) the insurance cost may be very expensive and lead
to an uneven cost burden within the private sector;
(2) the cost may force firms out of business; (3) firms
may be unwilling to buy insurance after they close or
sell a facility; (4) the insurance coverage from the
private sector may not be adequate to protect the
public health and the environment; and (5) adequate
amounts of insurance per facility and per incident are
unknown.
PLANNING LONG TERM CARE
The owners of a hazardous waste management
facility need to plan for long term care which should
address decontamination of equipment and structures
prior to sale; removal and disposal of remaining
hazardous materials; modification to disposal areas to
-------
52
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
render the site secure; and expected resource commit-
ments or requirements. In addition, along term care
plan (for disposal areas only) should be developed and
implemented after closure of the site. It should
include monitoring, sampling, analysis of groundwater
and surface waters in the vicinity of the site,
maintenance of the site (that is, cap maintenance or
replacement), containing operations to prevent
leachate from reaching the groundwater and surface
waters, and identification of officials responsible for
implementation of the plan.
Sufficient funding will be necessary to implement
the above plan. Provision for the financing of long
term care of waste sites can be generally secured via
a posted bond, a perpetual care fee, or a combination
of both mechanisms. A mutual trust fund may also
be used. These mechanisms are explained in the
following discussion.

Bonding
One method of ensuring long term site care is to
require deposit of a cash bond or maintenance of a
surety bond by the waste disposal site operator. The
bond should be of sufficient size to assure sufficient
funds for proper site closing and site monitoring,
surveillance, and maintenance for a number of years.
The appropriate bonding level varies with site charac-
teristics (size, geology, hydrology, etc.), the particular
hazardous materials destined for disposal, and the
degree of waste treatment prior to disposal. The
likelihood of offsite damages which is related to such
factors as proximity to population centers could be
considered as well when choosing an appropriate
bonding level, although it has not previously been a
factor.
A surety bond which is a certain level of insurance
maintained for the purpose of securing adherence to
certain procedures or regulations, would probably be
less burdensome to the site operator than a cash bond
of an equivalent amount. The premium paid for a
surety bond would presumably be less than the cost
of a loan needed for deposit of a cash bond.
In the case of a cash bond, adequate provision for
perpetual site care is assured if the annual real rate of
return (that is, the return on the principal over and
above the rate of inflation) offsets the cost of site
upkeep. A portion of the bond could be used to
correct major site deficiencies or to offset damages
caused by leachate runoff or migration. Sufficient
funds would have to remain on deposit to provide for
annual site upkeep subsequent to such expenditures.
If a change in site operators occurs before site closure,
then the former site operator should be allowed to
withdraw the bond's principal and the new operator
required to deposit an equivalent amount.
Perpetual Care Fee
An alternative to the required bond deposit is
assessment of a perpetual care fee on each user of the
waste facility. The user surcharge would be fixed on
a volumetric basis. Site operators should not allow
this fee to vary with the type of incoming waste. The
aggregate fees are deposited in an account, and when
a level sufficient to maintain long term care of the
site has been reached (including accrued interest), the
fee may be discontinued. (Of course, the fee may be
calculated such that the desired fund level will not be
reached until the site is full.) The major drawback to
this method of financing long term site care is that
the operator can cease site operations without having
accumulated a fund large enough to assure adequate
site closure and perpetual care.
Bonding/Fee Combination
Either a cash or surety bond can be combined with
a perpetual care fee to provide for perpetual site care.
A cash bond deposited with the State could be
withdrawn when an equivalent amount accumulated
through aggregate perpetual care fees had been
deposited by the site operator. Alternatively, a surety
bond, equal to the difference between the apparent
required sinking fund and the expected size of the
sinking funds for that year (that is, the cumulative
perpetual care fees plus the accrued interest), could
be required of the site operator. The apparent
required sinking fund would be a site-specific reserve
sufficient to provide funds for routine maintenance,
surveillance, and monitoring costs, as well as contin-
gency funds in the event of major site repair. In
essence, this method of assuring long term site care
would require the site operator to purchase declining
term insurance to protect the State against early
close-out of site operations.
Mutual Trust Fund
Rather than accumulate a perpetual care fund for
each disposal site, a mutual trust fund could be
developed for all sites within a given jurisdiction, for
-------
FACILITY OPERATIONS
53
example, within a State. This proposal could be
funded by any of the foregoing mechanisms. The
trust fund would provide a larger reserve to cover
unexpected site repairs or damage claims. Also, due
to the pooling of the risk of major site repair, the
contingency reserve required of each site operator
would be less than that needed if a separate sinking
fund were maintained for each site. Private operators
might not be as careful in site construction and main-
tenance if they were not directly liable for these
costs, however. The enforcement agency would have
to provide the incentive for continued site care.
FUTURE LAND USE OF CLOSED FACILITIES
The State should require that the use of a site for a
hazardous waste management facility be recorded on
the deed to the property. This information is neces-
sary to prevent future improper uses of the land.
After use as a land disposal facility, the site should
not be an area zoned for commercial or residential
construction. Construction of any structure on the
site should be limited to only those areas where waste
was not disposed of. The use of the site for a
recreational area or park may be the best use for the
land. However, the location of the facility in a
highly industrial area may limit the appeal of such a
recreational facility. In the planning stages of the
hazardous waste management facility, the State deci-
sion makers should decide if future land use restric-
tions will be necessary in the context of what uses
of the land can serve.
-------
Chapter 8
WPSTE SnmPLING PND RNPLYSIS fTlETHODS
PND LEPCHPTE PNPLYSIS fflETHODS
This chapter surveys the presently known methods
needed to sample and analyze the wastes placed in
landfills and to sample and analyze any leachate that
may come out of the land disposal sites. Both types
of sampling and analysis are required in fulfilling a
comprehensive hazardous waste management plan:
1) to ultimately determine the proper disposal me-
thods for the waste and 2) to determine (from the
leachate) whether a disposal site is operating properly
as far as health and environmental effects are concerned.
WASTE SAMPLING METHODS
The cornerstone of any viable waste management
system is the procedure used to retrieve those
samples that are analyzed to determine how the waste
should be managed. Unless the sample taken is
representative of the waste material as an aggregate,
the information extracted from the sample will be
misleading. The need for standardized sampling pro-
cedures is obvious, but unfortunately, most discus-
sions of waste sampling merely discuss the problems
involved in a general manner, without giving specifics
on how to deal with these problems, or descriptions
of particular sampling procedures.
There are methods presently being employed,
however, for sampling waste products and also for
sampling materials with consistencies similar to waste
products that can be adapted for use in waste
sampling. These methods are of primarily two kinds:
those that can be used for fluids and those that can be
used for granular nonfluid materials. Examples of
the former include the California Department of
Health's Coliwasa sampler and the oil thief for non-
viscous fluids [see American Society for Testing
Materials (ASTM) Standard D270-23]. Examples of
the latter include soil augers (see ASTM Standard
D452-19) and grain sampling triers.
There is still a need, however, for validated,
standardized step-by-step waste sampling protocols.
Several organizations are presently working on de-
veloping such protocols. It is unlikely that a single
waste sampling protocol will emerge from these
concurrent efforts, since different waste types may
well require different procedures. At this point, it is
apparent that the methods evolved will contain the
following elements:
• A method of obtaining either a continuous
vertical sample or many different point samples
on the vertical axis.
• Specifications as to when a stream is to be
tested (that is, beginning of process, after
process, randomly, etc.).
• Separate procedures for different physical char-
acterizations of the waste (and possibly a
procedure for determining that characterization
or state).
• Methods of sample preservation.
• Protocal to avoid cross-contamination by resi-
dues left in the sampler.
Very few specific sampling protocols have been
developed.
WASTE ANALYSIS METHODS
The analysis of waste materials is complicated by
the following factors. The composition of waste
constituents often ranges over a wide variety of
chemical types and over many orders of magnitude of
concentration. The presence of other constituents in
a sample under analysis can introduce intelference.
54
-------
WASTE SAMPLING AND ANALYSIS METHODS; LEACHATE ANALYSIS METHODS
55
Since wastes often contain many of these other
constituents, it is very difficult to compensate for
their presence in the interpretation of the analytical
data. Also, most wastes are not in a physical form or
state that is amenable to analysis. For a standard
analytical methodology to be prescribed, the wastes
must be in some sort of "standard state." For this
reason, significant amounts of pretreatment are often
required before analysis can begin. The following is a
discussion of how various organizations are addressing
the problem of waste analysis.
The United States Environmental Protection
Agency does have recommended procedures for waste
analysis; these are contained in the "Manual of
Methods for Chemical Analysis of Water and Wastes"
(Reference 1). It is recognized that these methods are
not applicable to the analysis of all waste streams, and
the Agency is researching analytical methods for
wastes.
The Federal Republic of Germany has a handbook
entitled "German Standard Procedures for Analysis of
Water, Effluent, and Sludge" (Reference 2) which
addresses the problem of waste analysis. A short
summary of those sections pertinent to waste analysis
are presented here:
• Determination of Water Content and Dry Res-
idues. This is a procedure for preparing a dry
residue of the waste by evaporation (including
the removal of most water of crystallization
from wastes with high inorganic content).
• Determination of Loss on Ignition of Dry Res-
idue. The method described is a measure of
organic content. The method is an ashing
procedure (run at 550°C) and has some inter-
ference from water of crystallization, magne-
sium carbonate releasing carbon dioxide, and
organics which volatilize slowly at this tempera-
ture.
• Determination of Hydrogen Jon Concentration
(pH Value). The method described employs a
pH meter, and describes sample preparation and
handling as well as meter calibration, and
possible interferences (that is, fats and oils).
In this treatment, it is recommended that the
test be run as soon after sampling as possible to
prevent gas exchange (pH can, to a large extent,
be a function of carbon dioxide concentration).
Not yet contained in the German Standard Method
are standard analytical procedures for free cyanide or
total mercury. These are available in preprint and are
summarized as follows:
• Determination of Total Cyanides. Detection by
the German Standard Method, D13, Part 1
(total cyanides) 7th Serial, Verlog Chemie
GmbH, Weinheim/Bergstor).
This method detects most CN groups including
metal cyanides, and various cyanocomplexes, such as
with iron. (The cobaltcyanide complex is only partly
decomposed by the method and, therefore, not
totally detected.) The method is applicable for
cyanide concentrations up to 100 mg/liter. Both a
volumetric and a photometric method are described.
The photometric method is more sensitive, but also
is more susceptible to interference from reducing
agents.
A rapid field-test method for cyanide analysis in
wastewater is described by J. Bertlisg (Haus der
Technik Vortragsveroffentlichung No. 283). This
method can be used in samples containing from 1 to
100 mg/liter of easily liberated cyanides. In this
method, hydrogen cyanide is liberated by mixing the
waste with acidic solution. Detection is by visual
colorimetric means. The liberated HCN is seen in a
standardized test tube (Hg C12/methylred). Inter-
ference is caused by free chlorine; this, however, can
be overcome by using a reducing agent such as
sodium arsenite beforehand.
The 'Analytical Chemistry' Working Group of the
Caucus on Waste Disposal of the Lander (LAG) has
proposed analytical techniques for the determination
of cyanides in water samples, and it is working on
techniques for the determination of heavy metals in
solid wastes.

• Detection of Mercury. In order to determine
mercury content, organically bound mercury
must be transformed into inorganic mercury.
In this procedure, intense UV radiation in an
acidic, oxidizing medium, is used to accomplish
this transformation. This method is suitable for
all types of wastewaters, and for mercury
concentrations from .05 to 10 g/liter. The
method of detection is atomic absorption,
utilizing a hollow cathode lamp as a radiation
source.
-------
56
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
Another important aspect of waste sample pre-
treatment is elutriation of the waste followed by
analysis of the elutriate for various chemical species.
The "leaching" of a waste by the various waters with
which it comes into contact is one of the primary
vectors of pollution from land disposal. Therefore,
this type of waste sample pretreatment is very
appealing, since the elutriation process can be thought
of as a leaching process. Some leaching or elutriation
tests attempt to mimic natural leaching processes,
while others simply attempt to indicate whether
there is a "potential" for leaching for a particular
waste and do not attempt to recreate in the elutria-
tion solvent physical parameters identical to the
natural leachate.
The Federal Republic of Germany has such a
pretreatment procedure. It does not attempt to
reproduce the exact parameters of natural leachate,
but only serves to determine if various chemical
species may dissolve when the waste is in contact
with water.
The following is a general outline of the procedure.
The waste is separated into a liquid and solid phase
by centrifugation or filtration. The filter residue (or
solid phase) is mixed in a 1:10 ratio with distilled
water and vigorously shaken or stirred for 24 hours.
As the agitation is proceeding, electrical conductivity
measurements may be taken to determine whether
solubility equilibrium has been reached. This mixture
is then filtered and standard water analysis methods
are used on both the original liquid filtered off and
the filtrate from the elutriation process.
Also, performance of multiple elutriations may be
desirable both to simulate natural processes and to
distinguish between the following situations:
• Wastes containing contaminant species with
such a high solubility or which occur in such
minute quantities that they are leached quan-
titatively in the course of the initial elutriation.
• Wastes containing species with such low solu-
bility, or in such a large quantity that they
become dissolved only partially in the initial
dilution.
• Wastes with contaminants which show changes
in behavior, when they come into contact with
the leachate.
It is important to distinguish between these
various waste types for operational management
purposes. The technique of multiple elutriation
involves repetitive dehydration and filtration followed
by elutriation with fresh solvent. Each resultant
elutriate is analyzed separately.
Finally, the solubility of contaminants in a waste
under conditions of various pH's may be of interest.
Wastes may come into contact with waters of pH's
other than neutrality due to dissolved CO2, actions
of other wastes, the presence of biological by-
products of waste degradation, etc. Depending on
the interest of the experimenter, the elutriate test
may be run using .1 N hydrochloric acid, .1 N sodium
hydroxide, or water saturated with carbon dioxide
substituted for distilled water.
There is at present ho official Federal elutriation
method for wastes. The State of Texas, however,
has recommended the following elutriate test, pro-
mulgated by the State Water Quality Board.
Solid Waste Evaluation Leachate Test
1. A 250 gm. representative sample of the "dry"
material should be taken according to the Asso-
ciation of Official Analytical Chemists or the
American Society of Testing and Materials
Standard methods and placed in a 1500 ml
Erlenmeyer flask.
2. One liter of deionized or distilled water should
be added to the flask and the material stirred
mechanically at a low speed for 5 minutes.
3. Stopper the flask and allow to stand for 7
days.
4. Filter the supernatant solution through a 45
micron glass filter.
5. The filtered leachate from step 2 should be
subjected to a quantitative analysis for those
component or ionic species determined to be
present in the analysis of the waste itself.
Note: Triplicate samples of trie waste should
be leached in order to obtain a represen-
tative leachate.

The U.S. Environmental Protection Agency is
presently doing research on the development of a
standard elutriate (leachate) test, as are other or-
ganizations such as American Society for Testing
-------
WASTE SAMPLING AND ANALYSIS METHODS; LEACHATE ANALYSIS METHODS
57
Materials (ASTM) and American Petroleum Institute
(API).
Summary
Extensive separation is often required before
wastes can be analyzed, and the interpretation of the
analytical data is often ambiguous. Unless the analyst
has some fairly good idea as to what organics are
present in the waste, presently available methods are
too expensive and time consuming to be of use in
routine waste analysis.
Elutriate tests presently being used are not com-
parable to natural leaching action. Natural leachate
solubilizes waste components because of many phys-
ical parameters of the leachate including pH, di-
electric constant, organic content (which can act as
chelating agents, buffering agents, etc.), temperature,
redox potential, and others. Also, standard infiltra-
tion and centrifugation methods must be developed.
Leachate analysis can suffer from different inter-
ferences and matrix effects (due to high organic
content, turbidity, etc.) than those of wastewater
and waste analysis.

LEACHATE ANALYSIS METHODS
The leachate resulting from the land disposal of
wastes can contaminate ground and surface water,
causing environmental damage and a hazard to health.
It is frequently necessary to analyze this leachate for
various hazardous contaminants. Unfortunately, the
chemical analysis of leachate is not as straightforward
as the analysis of most aqueous samples with which
the analytical chemist is familiar. These leachates
contain a large variety of constituents whose concen-
trations vary over a wide range. These factors cause
interference, and necessitate extensive pretreatment
procedures, making the interpretation of the analytical
data ambiguous. This interpretation can be further
muddied by the significant chemical and biological
changes that may occur within the leachate during
sampling, transportation, and storage. For these
reasons and others, it is difficult to develop standard
procedures for leachate analysis. The procedures
cited here are not infallible, but are presently being
used in leachate analysis, and in some cases have been
endorsed by particular organizations.
The analytical procedures discussed will be for
those contaminant species for which drinking water
standards exist (Table 11) and for purposes of this
discussion, have been separated into two classes, the
metallic and the nonmetallic species.
Metallic Species
The two most widely utilized methods for heavy
metal determinations are colorimetric spectropho-
tometry and atomic absorption spectrophotometry
(A.A.).
In A.A., a metal atom is volatilized (usually by
means of a flame). A beam of monochromatic (single
wavelength) electromagnetic radiation is passed
through this gaseous sample. The radiation is specific
for a transition of the metal from the ground state to
an excited state. Since most of the atoms will be in
the ground state, much of this energy will be
absorbed, hence the name atomic absorption. The
beam continues on to a photoreceptor. The amount
of absorbance is used as an index of metal con-
centration.
Like A .A., colorimetry is an absorption technique.
The observance of the species depends upon its ability
to coordinate with some highly conjugated organic
molecule (for example, diphenyl carbazide) so that it
has a molecular orbital transition (as opposed to an
atomic orbital transition for A.A.) in the visible range.
A beam of visible radiation is passed through the
sample (the chromatics being controlled and changed
by a filter, grating or prism) and the amount of
absorbance is recorded. Since we are dealing with
visible radiation, visual colorimetry is possible. In this
technique, known standard solutions are prepared
and the unknown solution is visually matched to see
which standard it most closely resembles [with
respect to color (shade)]. This visual method is a less
precise, less reproducible method than the instru-
mental. It requires that many standards be accurately
made and remade, since many have a finite lifetime.
The results are often qualitative and depend on
the experience and expertise of the operator. The
advantages are that it is considerably cheaper than
any instrumental method and can be done in the
field, if no extensive sample workup is necessary.
Colorimetry, in general, requires more sample
pretreatment than A.A. The advantage conferred by
the ability in colorimetry to perform multiple species
scanning without changing the radiation source (as is
required in A .A.) does not compensate for the strong
interferences to which colorimetric methods are
subject. This is especially valid given the often
-------
58
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
TABLE 11
METHODS FOR ANALYSIS OF LEACHATE FOR SUBSTANCES
COVERED BY DRINKING WATER STANDARDS
Metallic
Species

Arsenic
Barium
Cadmium
Chromium
Lead
Mercury
Selenium
Silver
Non-
Metallic
Species
Aldrin
DDT
Dieldrin
Cyanide
Nitrate
(asN)
Atomic
Absorption

Yes (A)
Yes (A, B)
Yes (A, B)
Yes (A, B)
Yes (A, B)
Yes (A, B)
Yes (A)
Yes (A, B)
Gas
Chromato-
graphy
Yes (A, B)
Yes (A, B)
Yes (A, B)
No
No

Instrumental
Photospectro-
scopy
Yes (A, B)
No
Yes (A, B)
Yes (A, B)
Yes (A, B, C)
No
Yes (B)
Yes (A, C)
Instrumental
Spectrophotometry
No
No
No
Yes (A, B)
Yes (A, B)

Visual
Color-
imetry
No
No
No
Yes (B)
No
No
No
Yes (C)

Polar -
graphic

No
No
Yes (B)
No
Yes (B)
No
No
No
Wet
Analysis ;
No
No
No
Yes (A, B)
No

Wet
Analysis

No
No
No
No
No
No
No
No
Visual
Spectro-
photometry
No
No
No
No
Yes (B)

(A) EPA Method of Choice
(B) Standard Methods Recommended
(C) Standard Methods Tentative
complex nature of the leachate matrix.
Procedures. The methods^endorsed by EPA for
heavy metal determination in "Methods for Chemical
Analysis of Water and Wastes" (Reference 1) and the
methods endorsed by "Standard Methods for the
Examination of Water and Wastewater" (Reference
2) are outlined in Table 11.
A.A. Analysis. There are several types of A.A.
spectrophotometers that are commercially available,
with different options for radiation source and sample
volitalization technique. The two types of radiation
sources available are the hollow cathode lamp, and
the electrodeless discharge lamp (EDL). EPA recom-
mends the single element hollow cathode lamp
(Reference 1). This is the most widely used radiation
- source and the most familiar to analysts. The
electrodeless discharge lamp is more expensive; how-
ever, its use may be indicated for selenium and arsenic
determination. The EDL's are both brighter than the
corresponding hollow lamps and more long lived for
these elements.
The sample atomizer may well be the most
important component of the A.A. spectrophotometer,
especially in leachate analysis, given its potential xfor
high organics content. There are two types of sample
atomizers commercially available: flame, and furnace
(and other flameless). Flame A.A., as the name
suggests, produces this vapor by means of a graphite
cylinder that is heated by an electric current.
The most widely used and best documented
method is flame A.A. This technique is the least
expensive of the three. The method works well for
all the contaminants of interest except selenium and
arsenic. There is spectral interference by the flame
gases for the major resonance lines of these elements.
Furnace A.A. does not produce this interference and
has been used successfully for the detection of
selenium and arsenic (arsenic and selenium can also
be generated by use of the gaseous hydride method
(References 1 and 2)). There are several types of
each of these general methods. Flame A.A., for
example, can be either total combustion or premixed
-------
WASTE SAMPLING AND ANALYSIS METHODS; LEACHATE ANALYSIS METHODS
59
and each of these types has advantages and dis-
advantages.
A related instrumental method is emission spectro-
scopy. This relies on atomic emissions rather than
absorption for the detection of metal ions. There are
commercially available plasma emissions spectro-
photometers that analyze for up to 20 elements
simultaneously. This instrument operates in the
following manner: The liquid sample is sprayed into
a very hot ionized argon gas (plasma) which causes
the sample to break down into elements. In the
8000-K heat, the elements emit light. The wavelength
of light always appears at the same location of the
spectrum. Photomultiplier tubes, which detect light
and convert it to electricity, are placed at the
locations along the spectrum where light will be
produced when any of the elements being sought are
present. A computer can identify the element from
the concentration from the intensity of the light. In
designing the instrument, one wavelength that would
be unlikely to be produced to any great extent by
other elements samples was chosen for each element.
The small interferences that do exist are taken into
account in a computer program before the results
are printed out.
Plasma R.F. is a relatively new technique and the
results using this technique by different investigators
seem inconsistent. Also the equipment necessary is
at least an order of magnitude more expensive than
what is necessary for A.A. Plasma emission and the
two A.A. techniques are compared in Table 12. (This
comparison merely comments on the general tend-
encies of the methods. Each type within the method
may exhibit the advantages or disadvantages cited to
a greater or lesser degree depending on the equipment
and procedures used.)
Specific procedures for the determination of the
metallic species in Table 11 (both colorimetric and
atomic absorption) can be found in References 1 and
2. It must be stressed, however, that these procedures
were not specifically developed for the analysis of
leachate, but for the analysis of wastewater, and that
the complexity of leachate composition often in-
troduces interferences and error into these methods.
EPA has recently published a "Compilation of
Methodology Used for Measuring Pollution Param-
eters of Sanitary Landfill Leachate" (Reference 3)
which evaluates these methods as they are applied to
leachate analysis. This reference points out some of
the difficulties which may arise and how to address
these problems.
A final analytical method (for selenium) is recom-
mended in the seminar proceeding reports of "Pro-
cedures for the Analysis of Landfill Leachates"
sponsored by the Canadian Environmental Protection
Service and is found in Reference 4.
Nonmetallic Species
Due to the complexity of organic and other non-
metallic species, analysis for these species is much
more complicated. The instrumental methods pres-
ently available for this type of analysis are: chroma-
tography (thin-layer, column, and gas liquid), and
colorimetric (spectrophometric and filter photo-
metric). There are also wet analysis methods
available. Table 11 illustrates what methods are
available for each species.
All the methods except chromatography have been
discussed in the previous section on the analysis of
metals. Chromatography is a general technique for
separating or concentrating one or more components
from a physical mixture. It consists of two phases,
a moving phase and a stationary phase. The moving
phase contains the species of interest along with
other species and a solvent (either liquid or gaseous).
The species in the moving phase are dissolved or
absorbed into the stationary phase (which is usually
a solid support with a liquid absorbed on it). The
species that are more soluble (in the liquid of the
stationary phase) spend more time in the stationary
phase and hence become more displaced than the less
soluble species which spend more time in the moving
phase. This displacement is the basis for separation
and ultimately detection of the various species. This
technique can be an instrumental gas liquid chroma-
tography (glc) or a wet technique (column or thin
layer), but all three have their basis in the above
physical principle.
Methods and procedures for the determination of
the nonmetallic species in Table 11 can be found in
References 1 and 2. Again Reference 3 can be used
as an invaluable aid since it takes these standard
methods for wastewater and evaluates their utility for
leachate analysis.
In the proceeding report of the "Procedures for
the Analysis of Landfill Leachate" (Reference 5), the
following alternative method and observations were
-------
TABLE 12

COMPARISON OF ALTERNATIVE METHODS FOR ANALYSIS
Flame
Advantages Disadvantages
- Least expensive - Not recommended
for As or Se.

- Best documented - Small percentage
of atomic vapor
concentration
available.

- Most chemists - Longer memory
are familiar with of previous sam-
procedures. ples(esp.in
pre-mix type).

Flameless
Advantages
- Better than
flame for
atomization
when matrix is
complex.
- Better able to
dissociate metal
oxides than flame.

- Can be used for
As or Se.
- Little or no
ionization effect.

(Furnace)
Disadvantages
- Technically
not as well
documented as
flame.

- Must use stan-
dard addition
technique. (Stan-
dard addition
technique is also
recommended for
flame A A.)
- Sample injection
is in ul. range,
so that final re-
liability of data
may be limited by
errors inherent
in reproducing
these small volumes.
- All laboratory
apparatus must be
ultra clean .
- Takes longer than
flameless.
Plasma
Advantages
- Can operate
on multichannels,
up to 23
elements can be
analyzed at once.
- Thermal energy
available is the
largest, 10,000
Kcal, so that all
oxides are dis-
sociated.

Disadvantages
- Technically
these are the
least well known
and documentation
is scant.
- Most complex
and expensive.

- Application is
limited to those
metals which do
not readily
atomize.

-
M

O
M
O
l/l

i
§
5
M
>n
O
G
O
c
i
S,
-------
WASTE SAMPLING AND ANALYSIS METHODS; LEACHATE ANALYSIS METHODS
61
reported as being used in leachate analysis of the
indicated species.
Cyanide - analyzed as in Reference 6.
Nitrates as N -The cadmium reduction methods in
References 1 and 2 are recommended. The samples
generally require pretreatment to remove turbidity,
and the cadmium column may have a short life if oil
and grease are not removed from the sample.

REFERENCES

1. Office of Technology Transfer. Methods for Chemical
Analysis of Water and Wastes. Environ-
mental Protection Publication PB 211 968.
Washington, U.S. Government Printing Of-
fice, 1971. 298 p.
2. American Public Health Association. Standard Methods
for the Examination of Water and Waste-
water, 14th ed., Washington, U.S. Govern-
ment Printing Office, 1976.
3. Chian, E. S. K., and F. P. DeWalle. Compilation of
Methodology Used for Measuring Pollution
Parameters of Sanitary Landfill Leachate.
Illinois University of Urbana Champaign.
October 1975. 176 p.
4. Raihle, J. A. Fluorometric Determination of Selenium
in Effluent Streams with 2, 3 Diamino-
napthalene. Environmental Science and
Technology 6(7): 621-622, July 1972.

5. Mooij, H. Procedures for the Analysis of Landfill
Leachate in Appended Seminars Proceedings
Report, R. D. Cameron, E. C. McDonald,
eds. EPS-4-EC-75-2. Dept. of Civil Engi-
neering. University of British Columbia,
Canadian Environmental Protection Service,
1976.
6. Scoggins, M. W. Ultraviolet Spectrophotometric Deter-
mination of Cyanide Ion. Analytical Chem-
istry 44(7) 1294-1296, June 1972.
-------
Chapter 9
STPTE PROGRflfTlS FOR HflZPRDOUS
WRSTE mRNRGEmENT
This chapter describes the recommended goals of a
State hazardous waste management program, and dis-
cusses the elements which would make such a
program effective and the phases of developing a
State program.

GOALS
The major goals of a State hazardous waste man-
agement program may be summarized in the follow-
ing way: cognizance; control; capability; alternatives;
and prevention.

• Cognizance.-The State should assure itself that
it has cognizance over the quantities, sources,
types, destinations, and disposition of hazard-
ous wastes within its borders. This includes
wastes which are generated within the State and
which never leave, but it should also include
wastes which are imported into or exported
from a State to other States. This cognizance is
a necessary precondition to understanding the
nature and dimensions of the hazardous waste
problem in any State, and to planning the
solutions to it.
The State can assure that it has cognizance over
hazardous waste through two devices: conduct-
ing a survey to establish baseline data; and,
instituting reporting and monitoring systems
that allow the State to remain current at all
times. Conversely, the State cannot expect to
manage hazardous waste adequately without
basic information on what wastes are being
generated and where they are going.
• Control-The State should establish control
over hazardous wastes for the entire life cycle
of those wastes. EPA has long advocated
"cradle-to-grave" control, which means that the
State should control the storage and transporta-
tion of hazardous wastes, as well as their
treatment and disposal. EPA does not advocate
the "control" of generation, nor does it require
generator permitting; the State can best assure
"cradle-to-grave" control by requiring sufficient
generator reporting to give the State cognizance
over the existence of hazardous wastes, thus
allowing the State to monitor those activities it
does control (storage, transportation, treatment,
and disposal).
Capability-The State should seek the capabil-
ity to provide technical assistance to those
requesting it, and to monitor and enforce its
regulatory program. This may be expressed
primarily as personnel resources, but must be
seen as more than establishing a large staff. The
mix of skills must allow the State to deal with
problems of chemistry, engineering, geology,
and hydrology, to name only four areas.
Alternatives—A major goal should be to offer
alternatives to those practices the State deter-
mines to be inadequate or unacceptable. The
provision of alternatives includes an oppor-
tunity for the private sector to respond to a
State's new regulatory climate, which pre-
sumably will be more favorable to those seeking
to provide the service of hazardous waste
treatment and disposal. The concept of alter-
natives also includes a determination by the
State as to which existing facilities are adequate
for hazardous wastes. This would allow the
62
-------
STATE PROGRAMS FOR HAZARDOUS WASTE MANAGEMENT
63
State to prevent hazardous wastes from being
landfilled at one location, while at the same
time identifying an area where the wastes could
be taken. The State may otherwise find itself
preventing the use of the only available treat-
ment or disposal practices, sites, or facilities.
• Prevention-Prevention of damage to the public
health or environment should be the central
goal of any State hazardous waste management
program, as it is for the Federal program.
ELEMENTS OF AN EFFECTIVE STATE
HAZARDOUS WASTE MANAGEMENT PROGRAM
An effective State program ought to have the
following elements:
• Legislative Authority
• Adequate Resources
• Published Criteria and Standards
• Established Permit Mechanisms
• Transportation Manifest System
• Surveillance and Enforcement Functions
Each of these is an essential element in an ef-
fective State hazardous waste management program.
An effective program will probably involve functions
and responsibilities beyond those listed above, but
the omission of any of them would severely hinder
the State program.
Legislative Authority
Many States will find their existing authorities
inadequate for establishing a hazardous waste
management program, and will have to seek new
legislation for this purpose. EPA does not require
new legislation in order for the State program to be
authorized; EPA's expectation is rather that the State
have (or seek) legislation which authorizes the imple-
mentation, administration, and enforcement of an
effective program. This should include authority to
issue permits for storage, treatment, and disposal; to
require a transportation manifest system; to require
the keeping of records and the submitting of reports;
to conduct inspections and take samples; to establish
criteria and standards for storage, treatment, and
disposal; and to institute enforcement proceedings
against violators.
Some States that have this type of legislation for
water or air pollution control may be able to use
those other authorities for managing land disposal.
The existence of sufficient authorities in other areas
of environmental management does not, however,
guarantee that those authorities are applicable to
hazardous waste management on the land.
State legislation should not exclude those who
treat or dispose of their own wastes at the site of
generation ("onsitevdisposal"). This is a potentially
large loophole, and one of which the States should be
aware. Failure to include onsite hazardous waste
management activities would leave a significant por-
tion of the problem unregulated.
Adequate Resources
A State program cannot be considered effective
where the State does not commit sufficient resources
to administer and enforce an otherwise approvable
program. States must base the judgment as to the
effectiveness of their programs upon an assessment of
the actual performance to be expected, a judgment
largely dependent upon the resources a State invests.
The term 'resources' includes both personnel and
dollars. The former would be assessed in terms of
numbers of people assigned to specific tasks, as well
as in terms of the mix of skills and the usefulness of
that mix for the administration and enforcement of a
hazardous waste management program.
The other category of resources (dollars) includes
considerations such as the adequacy of laboratory
analysis facilities (or services), the availability of data
processing facilities (or services), and the availability
of appropriate surveillance and monitoring equip-
ment.
Published Criteria and Standards
An effective State program should have adopted
and published criteria and standards for the storage,
treatment, and disposal of hazardous wastes; for the
transportation of hazardous wastes; and for the non-
process aspects of generation of hazardous wastes
(e.g., reporting, recordkeeping). EPA neither recom-
mends nor expects that each State will invest
significant amounts of its own time or resources in
repeating the developmental work performed by EPA
or other State agencies. Each State should review
the Federal standards, and those of authorized State
programs, with an eye toward adopting similar or
identical criteria and standards for themselves. States
will necessarily alter certain criteria and standards
adopted by other jurisdictions to account for unique
-------
64
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
circumstances or conditions, but EPA encourages
States to seek the greatest possible agreement of each
State's standards with those of the Federal program,
and with those of authorized State programs.
Established Permit Mechanisms
No State program should be considered "effective"
unless it has the capability to issue and enforce
permits for the storage, treatment, and disposal of
hazardous wastes. The permit function is central to
the administration and implementation of the Act.
Consequently, an effective State program should
include the administrative framework to identify and
notify those who must apply for permits; to process
applications for permits; to monitor renewal and
expiration of permits; and to monitor compliance
with the terms and conditions of permits.
Surveillance and Enforcement
The State should demonstrate both the willingness
and the ability to assure that the program it has
developed is being implemented. This requires the
State to make inspections and to take samples from
those who are managing hazardous wastes, and to
require that prescribed practices for reporting, record-
keeping, and labeling (to name only three) are being
followed. It further requires that those who are
violating the law be prosecuted, and that the State
be able to suspend or revoke permits, and impose
fines which are sufficient to deter other would-be
violators. Consequently, a State program which did
not include surveillance and enforcement provisions
should not be considered ."effective."
Manifest System
Section 3002(5) of the RCRA directs that EPA
require the use of a manifest to assure that hazard-
ous wastes which leave the site of generation are
taken only to permitted storage, treatment, or
disposal sites. This requirement is based upon the
experience or expectations of several States which
believe the manifest to be an essential element in
managing hazardous wastes, a belief which EPA
shares. The State will not be able to effectively
control hazardous wastes by regulating only the
treatment and disposal sites. The "cradle-to-grave"
concept implies knowledge of the existence and
movement of hazardous wastes throughout their life
cycle.
An effective State program will necessarily include,
therefore, a manifest system. The form used, and
specific information required, should be consistent
and compatible with the manifest developed for the
Federal program, and with those in use in other
authorized State programs.
PROGRAM DEVELOPMENT PHASES
The State should expect to go through two distinct
phases in developing an effective hazardous waste
management program. These may be called "De-
velopment and Implementation" and "Operational"
phases. The first phase can require from 1 to 3 years,
while the second phase encompasses everything there-
after.
During the "Development and Implementation"
phase, the State should develop procedures; develop
and promulgate standards, criteria, and guidelines;
obtain staff members; and emphasize training of both
the regulatory staff and of the regulated community
(in the sense that the regulated community should be
made familiar with the requirements of the new
program).
The "Operational" phase will see the State begin-
ning its emphasis on enforcement, surveillance, and
monitoring activities. During this phase, the State
should allocate about 75 percent of its personnel
resources to the above activities; the remaining 25
percent will be used to continue the developmental
tasks, and for administration and management. This
is in contrast with the initial phase, in which about
10 percent of the available resources may be expected
to go to administration and management, with the
remaining 90 percent going to development of the
program.
A second contrast between the two phases is in
the importance of field work. The State should give
field investigation and surveillance activities a lower
priority than in-house tasks during the developmental
stages of the program, but should reverse this ordering
of priorities in the operational phase.
-------
Appendix R
mODEL STATE HAZARDOUS WASTE mANAGEfTlENT
ACT WITH ANNOTATION
Recent Federal and State environmental management legislation has
addressed the quality of our air, our water, and our oceans. One result of
this legislation has been to curtail the disposal of potentially hazardous ma-
terials into these media, thereby improving the quality of our air, water, and
marine resources. But there has been a second result: potentially hazardous
wastes continue to be generated which can no longer go to other media, so they
are placed on or into the land. The 375 million tons of industrial wastes gen-
erated in the United States in 1974 included about 30 million tons of potentially
hazardous wastes.
New Federal legislation, the Resource Conservation and Recovery Act
(RCRA) (P.L. 94-580), controls the disposition of potentially hazardous wastes
on land. Congress made clear that Federal and State partnership is intended for
the implementation of this new pollution control program. Regulatory provi-
sions of the new Act are scheduled to take effect in October 1978. States should
begin to develop their own control programs now.
An essential element in any State hazardous waste management program is
the enabling legislation. In some cases, existing legislation authorizes parts of
what would constitute the State's program; in other cases, existing legislation
may be reinterpreted in such a way as to cover some of the threats posed by the
mismanagement of potentially hazardous wastes. Most States, however, will find
that an effective program requires new legislation explicitly delineating the
obligations and responsibilities of those who generate, store, transport, treat, or
dispose of these wastes; but even here, States should consider the possibility of
supplementing existing solid waste legislation with the appropriate hazardous
waste management authority. Whether or not the State develops a separate
hazardous waste management act, the State must obtain adequate legislative
authority to develop and implement its program.
This document includes a text and annotation. The latter is intended to
explain the reasons for including certain phrases or ideas, or for choosing one or
65
-------
66 STATE DECISION MAKERS BUIDE FOR HAZARDOUS WASTE MANAGEMENT
another among various options, and to highlight potential difficulties in interpre-
tation or implementation of the text. Further, this document is intended to
show the reader the kind of legislative authority the State may find useful in
developing an effective hazardous waste management program. Readers should
not construe this Model Act as showing what EPA will consider to be an
"equivalent" State program, or as setting out the criteria against which applica-
tions for authorization under Section 3006 of RCRA will be judged; the Model
Act is not so intended.
MODEL STATE HAZARDOUS WASTE MANAGEMENT ACT
Section 1 Short Title
Section 2 Finding of Necessity and Declaration of Purpose
Section 3 Definitions
Section 4 Powers and Duties of the Department
Section 5 Permits
Section 6 Hazardous Waste Treatment/Disposal Facilities and Sites
Section '7 Transportation of Hazardous Wastes
Section 8 Records; Reports; Monitoring
Section 9 Inspections; Right of Entry
Section 10 Imminent Hazard
Section 11 Enforcement
Section 12 Interstate Cooperation
Section 13 Repealer
Section 14 Severability
Section 15 Effective Date
SHORT TITLE
Section 1
This Act may be cited as the Hazardous Waste Manage-
ment Act of 19
FINDING OF NECESSITY AND
DECLARATION OF PURPOSE
Section 2
(A) The legislature of this State finds:
(1) that continuing technological progress, in-
creases in the amounts of manufacture, and
the abatement of air and water pollution
have resulted in ever-increasing quantities of
hazardous wastes;
(2) that the public health and safety, and the
environment are threatened where hazardous
wastes are not managed in an environmentally
sound manner;
-------
MODEL STATE HAZARDOUS WASTE MANAGEMENT ACT
67
(3) that the knowledge and technology necessary
for alleviating adverse health, environmental,
and aesthetic impacts resulting from current
hazardous waste management and disposal
practices are generally available at costs with-
in the financial capability of those who gen-
erate such wastes, but that such knowledge
and technology are not widely used; and
(4) that the problem of managing hazardous wastes
has become a matter of State-wide concern.
(B) Therefore, it is hereby declared that the purposes
of this Act are:
(1) to protect the public health and safety, the
health of living organisms and the environ-
ment, from the effects of the improper, in-
adequate, or unsound management of haz-
ardous wastes;
(2) to establish a program of regulation over the
storage, transportation, treatment, and dis-
posal of hazardous wastes; and
(3) to assure the safe and adequate management
of hazardous wastes within this State.
DEFINITIONS
Section 3
When used in this act:
(A) The term, Department, means the Department of
this State charged with the administration and
enforcement of this Act.
(B) The term, Disposal, means the discharge, deposit,
injection, dumping, spilling, leaking or placing of
any hazardous waste into or on any land or water
so that such hazardous waste or any constituent
thereof may enter the environment or be emitted
into the air, or discharged into any waters, includ-
ing groundwaters.
(C) The term, Generation, means the act or process of
producing waste materials.
(D) The term, Hazardous Waste, means any waste or
combination of wastes of a solid, liquid, contained
gaseous, or semisolid form which because of its
.quantity, concentration, or physical, chemical, or
infectious characteristics, in the judgment of the
Department may (1) cause, or significantly con-
tribute to, an increase in mortality or an increase
in serious irreversible or incapacitating reversible
illness; or (2) pose a substantial present or poten-
tial hazard to human health or the environment
DEFINITIONS
Section 3
The definitions have been worded so as to be con-
sistent with the new Federal solid waste legislation.
(B) "Disposal"-This definition is taken from the
RCRA, (P.L. 94-580). The definitions of dis-
posal and storage taken together mean that the
traditional landfill can be construed as disposal
if there is any leaching or other discharge; a non-
leaching landfill, however, would be considered
storage (albeit very long term). The rationale
for this is partly to increase awareness that one
has not done away with hazardous constituents
by simply putting them into the ground. Where
there is no discharge or emission, the hazardous
waste has been retained in one place and requires
monitoring and/or care-hence "storage."
(D) "Hazardous Waste"-This definition is consistent
with that in RCRA, (P.L. 94-580). EPA recom-
mends that enabling legislation contain a generic
definition, and that it not contain specific cri-
teria, lists, or wastes. The definition should
instead give generic examples of hazardous
wastes, such as "... including, but not limited
to, toxic, flammable, etc " The listing of
-------
68
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
when improperly treated, stored, transported, dis-
posed of, or otherwise managed. Such wastes in-
clude, but are not limited to, those which are
toxins, corrosives, flammable materials, irritants,
strong sensitizers, or materials that generate pres-
sure through decomposition, heat, or other means.
(E) The term, Hazardous Waste Management, means
the systematic control of the collection, source
separation, storage, transportation, processing,
treatment, recovery, and disposal of hazardous
waste.
(F) The term, Manifest, means the form used for iden-
tifying the quantity, composition, origin, routing,
and destination of hazardous waste during its
transport.
(G) The term, Person, means any individual, trust,
firm, joint stock company, corporation (including
a government corporation), partnership, associa-
tion, State, municipality, commission, political
subdivision of a State, or any interstate body.
(H) The term, Storage, means the containment of haz-
ardous wastes, either on a temporary basis or for
a period of years, in such a manner as not to con-
stitute disposal of such hazardous wastes.
(I) The term, Transport, means the movement of
wastes from the point of generation to any inter-
mediate points, and finally to the point of ultimate
storage or disposal.
(J) The term, Treatment, means any method, tech-
nique, or process, including neutralization, de-
signed to change the physical, chemical, or
biological character or composition of any haz-
ardous waste, so as to neutralize such waste or
so as to render such waste nonhazardous, safer for
transport, amenable to recovery, amenable to stor-
age, or reduced in volume.
(K) The term, Treatment Facility, means a location at
which waste is subjected to treatment and may in-
clude a facility where waste has been generated.
POWERS AND DUTIES OF THE DEPARTMENT
Section 4
(A) Within one year after the effective date of this Act,
the Department shall conduct and publish a study
of hazardous waste management in this State, which
shall include, but not be limited to - -
(1) a description of the sources of hazardous waste
generation within the State, including the types
examples shows to the Department, the courts,
industry, and the public, what the legislature
intends the term, hazardous, to mean.
(H) "Storage"- This definition is similar to that in
RCRA. If the State does not use the concepts
of storage and disposal as they are used in RCRA
(and in this paper), any substitute definition of
storage must limit the duration for which a waste
may be stored. One reason for this limitation is
that indefinite storage, or storage for a long
period of years, may otherwise become a way
for generators to avoid the controls which the
State exercises over disposal. A second reason
is to avoid the enforcement problem of the
possessor's intent. Where the State defines
storage or disposal to include the concept of
"intending to reuse or recover," or "intending
to hold for future use," the State invites the
difficulties attendant to proving intent. Third,
the longer one stores a hazardous waste, the
more closely one approaches the environmental
effects and consequences of disposal. For all
these reasons, where the more traditional defi-
nition of storage is used, it should include a
phrase such as, "Storage in excess of [one year,
for example] shall be considered disposal for
the purpose of this Act."
(K) "Treatment Facility "-This definition explicitly
includes onsite hazardous waste management.
The law thus recognizes that the environmental
threat is no less from those wastes managed at
the site of generation than from those wastes
managed anywhere else. It is for this reason that
the State's regulation of hazardous waste treat-
ment or disposal facilities must include regulating
those who manage their own wastes at the site of
generation.
POWERS AND DUTIES OF THE DEPARTMENT
Section 4
Subsection (A) directs the Department to conduct and
and publish a study of hazardous waste management
within the State. Inclusion of this requirement is*in-
tended partly to assist the Department in gathering
information it needs, but which it may not have ex-
plicit authority to elicit under existing statutes.
-------
MODEL STATE HAZARDOUS WASTE MANAGEMENT ACT
69
and quantities of such wastes; and
(2) a description of current hazardous waste man-
agement practices and costs, including treat-
ment and disposal, within the State.
(B) Within 6 months after the publication of the study
required by Section 4(A) of this Act, the Depart-
ment shall develop and publish a plan for the safe
and effective management of hazardous wastes
within this State. Such plan shall include, but not
be limited to - -
(1) identification of those locations within the
State which are suitable for the establishment
or disposal facilities or sites; and
(2) identification of those locations within the
State that are not suitable for the establish-
ment of hazardous waste treatment or dis-
posal facilities or sites.
(C) Within 2 years after the publication of the study
required by Section 4(A) of this Act, the Depart-
ment shall, after adequate notice and at least one
public hearing on the record, adopt, and may re-
vise as appropriate - -
(1) criteria for the determination of whether any
waste or combination of wastes is hazardous
for the purposes of this Act;
(2) rules and regulations for the storage, treat-
ment, and disposal of hazardous wastes;
(3) rules and regulations for the transportation,
containerization, andlabeh'ng of hazardous
wastes, which shall be consistent with those
issued by the United States Department of
Transportation;
(4) rules and regulations specifying the terms
and conditions under which the Department
shall issue, modify, suspend, revoke, or deny
such permits as may be required by this Act;
(5) rules and regulations establishing standards
and procedures for the safe operation and
maintenance of hazardous waste treatment
or disposal facilities or sites;
(6) a listing of those wastes or combinations of
wastes which are not compatible, and which
may not be stored or disposed of together;
(7) procedures and requirements for the report-
ing of the generation, storage, transportation,
treatment, or disposal of hazardous wastes
pursuant to Section 8 of this Act;
The subsection specifies that the study must address
the costs of current hazardous waste management
practices. This allows the State to assign likely costs
to its regulatory decisions, making possible an analysis
of the economic consequences of many of the Hazard-
ous Waste Management Act's provisions. This process
is analogous to the Federal government's "Economic
Impact Analysis'*T?rocess for its own actions.
Subsection (B) requires the Department to identify
locations suitable for hazardous waste treatment or
disposal sites. This phrasing is not intended to pre-
clude engineered sites. The Department should seek
those locations which have been favored by geology,
climate, and other relevant factors, and which offer
natural protection to the environment; EPA recog-
nizes, however, that there is a need for facilities in
States, and sections of States, which have no suitable
natural sites, and that this need can only be met
through artificial devices which protect the environ-
ment. Where the soil does not meet acceptable
standards of impermeability, for example, artificial
liners may be substituted. This means that the
Department should include those areas where a site
is needed, but in which a site would have to be engi-
neered to protect the environment.
Subsection (B) additionally requires the State to iden-
tify those parts of the State which are not suitable for
the location of hazardous waste treatment or disposal
sites. This decision, as well as the above decision that
sites should be located in certain areas, must be based
on a number of factors besides geology and hydrology.
EPA encourages the kind of determination which re-
sults in certain areas being designated as "critical" or
"sensitive" for ecological or other reasons, and in
which the State would allow the location of hazard-
ous waste treatment or disposal facilities with great
reluctance and under especially high standards of
design, construction, and operation. An example of
such a "critical area1' might be a major aquifer.
Subsection (C) (3) requires that the State rules and
regulations for the transport of hazardous wastes be
"consistent" with those of the UJ3. Department of
Transportation (DOT). This does not mean that
States must adopt the DOT rules by reference or un-
changed; however, where the State chooses to estab-
lish any rule or regulation for transport that is
different from (including stricter than) DOT's, it will
-------
70
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
(8) rules and regulations establishing standards
and procedures for the certification of su-
pervisory personnel at hazardous waste treat-
ment or disposal facilities or sites as required
under Section 6(A) (3) (a) of this Act; and
(9) procedures and requirements for the use of
a manifest during the transport of hazardous
wastes.
(D) In complying with this Section, the Department
shall consider the variations within this State in
climate, geology, population density, and such
other factors as may be relevant to the manage-
ment of hazardous wastes.
PERMITS
Section 5
(A) Beginning 6 months after promulgation of the
regulations required under Section 4(C) of this
Act, no person shall construct, substantially alter,
or operate any hazardous waste treatment or dis-
posal facility or site, nor shall any person store,
transport, treat, or dispose of any hazardous
waste without first obtaining a permit from the
Department for such facility, site, or activity.
(B) Permits issued under this Section shall be issued
under such terms and conditions as the Depart-
ment may prescribe under the authority of Sec-
tion 4 of this Act, and under such terms and
conditions as the [appropriate State agency]
may prescribe for the transportation of hazard-
ous wastes under Section 7 of this Act.
be incumbent upon the State to avoid conflict with
the latter.
Subsections (C) (5) and (C) (6) are important for
occupational health and safety, as well as for environ-
mental protection. EPA has documented cases where
an individual disposing of hazardous wastes has been
injured or killed because of handling unmarked con-
tainers without the caution one would use were the
containers prominently labeled to show their poten-
tial danger. Similarly, EPA has documented cases
where the disposal of incompatible wastes (such
as acids being disposed of with cyanide wastes)
has resulted in injury or death. Subsections (C) (5)
and (C) (6) are an important part of the State's effort
to assure that those who handle hazardous wastes are
fully informed as to the nature of the hazard, and as
to the safest method of handling those wastes.
Section (C) includes a requirement for a "public hear-
ing on the record." Readers should be aware that the
use of this phrase will, in many States, trigger the use
of an "Administrative Practices Act" or equivalent.
This entails the advantages and disadvantages of a
formal proceeding, including the keeping of a tran-
script, and so on.
Subsection (D) gives the Department an opportunity
to recognize the differing regions within the State.
Nevertheless, the Department must establish certain
minimum standards above which the environment will
be protected; it is in the process of determining how
far above this minimum the State sets specific require-
ments that Subsection (D) comes into play.
PERMITS
Section 5
The word "permit" has been used throughout this
document to stand for the process by which the State
can insure cognizance of, as well as control over, vari-
ous activities. The provisions and requirements of each
permit system should be explicitly stated in the regu-
lations which implement the State Hazardous Waste
Management Act; consequently, the reader should be
aware that certain uses of the word "permit" here may
refer to a license or registration concept, and need not
imply the detailed criteria and compliance schedules
attendant to the kind of permit issued under the Fed-
eral Water Pollution Control Act Amendments*of
1972 (P.L. 92-500),
Subsection (A) requires a permit to construct, "sub-
stantially alter," or operate any hazardous waste
-------
MODEL STATE HAZARDOUS WASTE MANAGEMENT ACT
71
(C) Permits shall be issued for a period not to ex-
ceed 5 years, and may be renewed at the
option of the issuing agency.
(D) Any permit issued under this Section may be re-
voked by the issuing agency at any time when
the permittee fails to comply with the terms and
conditions of the permit, PROVIDED, no permit
shall be revoked until the Department has pro-
vided the affected party with the opportunity for
an adequate hearing, and with written notice of
the intent of the Department to revoke the per-
mit and the reasons for such revocation.
(E) Where the application for or compliance with any
permit required under this Section would, in the
judgment of the Department, cause undue or un-
reasonable hardship to any person, the Depart-
ment may issue a variance from the requirements
of this Section. In no case shall the duration of
any such variance exceed one year; renewals or
extensions may be given only after opportunity
for public comment on each such renewal or ex-
tension.
(F) Beginning 6 months after promulgation of the
regulations required under Section 4(C) of this
Act, any person undertaking one of the activities
for which a permit is required under this Section
or under Section 7 of this Act, or violating any
term or condition under which a permit has been
issued pursuant to this Section or pursuant to
Section 7 of this Act, shall be subject to the en-
forcement procedures of Section 11 of this Act.
treatment or disposal facility. This poses at least two
issues for the State to address: defining "substan-
tially alter;" and, deciding whether construction and
operation entail two separate permits.
The phrase "substantially alter" is intended to allow
the State latitude in deciding what kinds or degrees
of alteration change the environmental impact of a
site enough as to make reassessment necessary.
Neither the State nor the site operator wants to re-
peat the permit application and evaluation process
each time there is a change to the site, no matter how
trivial or irrelevant that change may be. Therefore,
the State regulations should describe the circum-
stances under which an existing site would be
required to apply for a revised or amended permit.
The Model Legislation is purposely vague on the
issue of separate versus combined permits for con-
struction and operation. Some States issue a permit
to construct, but require the permittee to apply for
an entirely separate permit after construction to op-
erate the site. Other States issue a single permit for
the construction and subsequent operation of a site.
The State should be explicit in describing which of
these systems it is using.
Subsection (A) requires a permit to "store" hazardous
wastes. As stated above, this use of the word "permit"
is not intended to parallel the use of the word in the
Federal Water Pollution Control Act, or even in other
parts of this Model Legislation. The provision is
nevertheless an important one. It is intended to con-
trol the environmental abuse from "storage"' which
is really "disposal," and which has the same (degrad-
ing) environmental result as improper disposal. Con-
sequently, the State might require a permit from
those who store hazardous materials in large, open
areas (pits, ponds, lagoons) for some period sufficient
to threaten the environment. The State should also
use this provision to control the creation of large
piles of tailings or mining residuals above the surface,
as there are cases of such residuals remaining long
after the generator has gone out of business or other-
wise left the scene. Conversely, the State might not
require permits of those who store small quantities
in closed tanks awaiting shipment, or those holding
residuals for short periods awaiting use or reuse.
The State should use the permits it does issue for storage
as a source of information, so that the State is aware of,
and can track, wastes through their life cycle, and as a
-------
72 STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
way of preventing such abuses that might otherwise
follow from the misnamed "storage" of hazardous
wastes described here.
Subsection (A) explicitly applies also to generators that
treat or dispose of their own wastes. This frees the
State from having to allege that someone treating his
own wastes at the site of generation is operating a
treatment or disposal site; this Subsection renders such
an issue moot, since anyone treating or disposing of haz-
ardous wastes (including his own wastes, and including
on his own property) may be required to use proper
management practices.
Subsections (A) and (B) require permits for the trans-
portation of hazardous wastes; as elsewhere in this doc-
ument, however, the word "permit" is not intended
to imply the kind of detailed criteria and compliance
schedules attendant to permits under the Federal Water
Pollution Control Act. (A number of States have elected
to regulate the transporters of hazardous wastes, several
through the use of a "trip ticket" or "manifest" system.
These systems are described in the annotation for
Section 7.)
Subsection (B) includes the phrase "appropriate State
agency," a phrase which appears throughout the Model
Law where the subject is the transport of hazardous
wastes. Institutional arrangements and responsibilities
for the transport of hazardous wastes vary widely from
one State to another, making it impossible to generalize
in a document such as this. The reader should distin-
guish, however, between the economic aspects of re-
gulation (usually assigned to the State Public Utilities
Commission or equivalent agency) and other aspects
such as transportation safety (often assigned to the
State Highway Patrol or equivalent agency). The Model
Law addresses only the latter function; where the eco-
nomic and safety aspects are divided between two
agencies, all transport responsibilities specified in the
Model Law would logically be assigned to the latter
agency.
Subsection (C) suggests a term of 5 years for all per-
mits. This figure is presented for example only and
is admittedly arbitrary. The State should issue permits
for a sufficient term so that investors will commit neces-
sary funds, but not for a period which is so long as to
obligate the State to continue an unsatisfactory*situa-
tion any longer than it must.
Subsection (E) provides for variances. The State may
choose to issue variances for durations other than
-------
MODEL STATE HAZARDOUS WASTE MANAGEMENT ACT
73
HAZARDOUS WASTE TREATMENT/DISPOSAL
FACILITIES AND SITES
Section 6
(A) No permit shall be issued to any hazardous waste
treatment or disposal facility or site unless that
facility or site meets such terms and conditions
as the Department may direct. Terms and condi-
tions shall include, but not be limited to - -
(1) Evidence of liability insurance in such amount
as the Department may determine to be neces-
sary for the protection of the public health
and safety and protection of the environment;
(2) Evidence of financial responsibility in such
form and amount as the Department may
determine to be necessary to insure that,
upon abandonment, cessation, or interrup-
tion of the operation of the facility or site,
all appropriate measures are taken to prevent
present and future damage to the public
health and safety and to the environment;
(3) Evidence that the personnel employed at the
< hazardous waste treatment or disposal facil-
ity or site have met such qualifications as to
education and training as the Department
may determine to be necessary to assure the
safe and adequate operation of the facility
or site:
(a) Persons charged with the direct super-
vision of the operation of any facility or
12 months; the figure used in this Model Legislation
is for example only.
The State should also decide whether variances may be
renewed, and, if so, how many such variances may be
given to one applicant or permittee. This decision must
take into account the environmental effects of variances,
since continued noncompliance with minimum standards
creates no less a problem for being sanctioned by the
authority of a variance. Balancing this is the realization
that many factors may militate against immediate
closure of a permittee who can be brought into com-
pliance within a finite period if allowed to continue to
operate. The Model Law includes a requirement that
the public be allowed to comment on any renewal or
extension of a variance. This is intended to make ex-
plicit the State's authority to continue variances, but
also its responsibility to demonstrate to the public the
reasons for so doing.
HAZARDOUS WASTE TREATMENT/DISPOSAL
FACILITIES AND SITES
Section 6
This Section includes several subjects which could be ad-
dressed separately in hazardous waste legislation. These
include: funding or other provisions for long term care
of sites; insurance requirements; training requirements
for operating and supervising personnel at sites; and, a
possible method for financing the State regulatory pro-
gram. The State should be certain that the first three
areas above are addressed somewhere in the authorizing
legislation, if not in the section describing the duties
and responsibilities of treatment/disposal site operators.
The initial paragraph in Subsection (A) is intentionally
broad in order to give the State wide latitude in deter-
mining those requirements necessary to the safe opera-
tion and environmentally-sound design of treatment/
disposal rites. The State should use its regulations to
detail the terms and conditions required of all permit
holders. Terms and conditions will vary (as they should)
between permit holders, depending upon geology, hy-
drology, geography, and many other factors, and the
Regulations should recognize this by stating that the
Department may require such other terms and con-
ditions as are necessary to meet the purposes of the
authorizing legislation. General terms and conditions
will include such things as a specific monitoring and
sampling system approved by the State, and evidence of
financial responsibility in such form and amount as the
-------
74
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
site shall be certified by the Department
according to the regulations required
under Section 4(C) (8) of this Act and
after a review of the types, properties,
and volume of hazardous wastes to be
treated or disposed of at the facility or
site.
(b) The Department may require the recer-
tification of supervisory personnel where
there is any significant change in the
types or properties of hazardous wastes
being treated or disposed of at the facil-
ity or site.
(B) The Department is authorized to establish a sche-
dule of fees to be paid to the Department by haz-
ardous waste treatment or disposal facilities or
sites.
Department deems necessary.
Subsection (A) (2) does not suggest the specific type of
financial responsibility to be required. There are two
separate concerns involved in "long term care": The
first is the expense of continued monitoring and main-
tenance of the site after cessation of operations; the
second is the potential expense of environmental
damage occurring (or being discovered) after cessation.
The first concern is relatively inexpensive and can be
estimated in advance. The State can, therefore, require
an amount equal to X dollars a year for Y years. For
example, the State might require a bond of $10,000
based upon monitoring and maintenance costs of
$1,000 each year for 10 years. This would assure the
integrity of fences, signs, monitoring wells, and so
on, for whatever period the State determines appro-
priate.
The second concern is considerably more difficult to
quantify. The type of damage which could occur, the
cost of correcting that damage (if it can be corrected),
and the gestation time between closing a site and the
discovery of any damage are all relative unknowns.
States have devised different responses to these un-
knowns in order to protect their citizens. One ap-
proach has been to require that any site licensed for
hazardous waste disposal or treatment be deeded to the
State, in effect making all sites public land. States which
have done this believe that the State will ultimately be
responsible for correcting any environmental damage
caused by hazardous waste treatment or disposal sites
anyway, making it prudent that such sites be on public
land from the start. EPA does not necessarily endorse
this concept, as there are many facets to the issue of
public versus private disposal or treatment facilities,
not all of which favor public ownership. Most States
have instead required some form of bonding. The
chief drawback to this approach is the difficulty in de-
termining an adequate amount for such a bond. A third
alternative is some type of trust fund or revolving account
which would receive money from currently operating
sites, to be used to correct damage caused by any treat-
ment or disposal site, even if closed long ago. The
specific course chosen is less important than the fact
that the State have legislative authority to address the
problem of potential environmental damage from haz-
ardous waste treatment or disposal sites, and to institute
some type of protection for the public before that damage
occurs.
-------
MODEL STATE HAZARDOUS WASTE MANAGEMENT ACT
75
TRANSPORTATION OF HAZARDOUS WASTES
Section 7
(A) Following adequate public notice, and not less than
one public hearing on the record, the [appropriate
State agency], in consultation with Department,
shall issue rules and regulations for the transporta-
tion of hazardous wastes. Such rules and regula-
tions shall be consistent with applicable rules and
regulations issued by the United States Depart-
ment of Transportation, and consistent with any
rules, regulations, and standards issued pursuant
to Section 4 of this Act. The [appropriate State
agency] shall comply with this Section within
3 years after the effective date of this Act.
(B) The provisions of this Section shall apply equally
to those persons transporting hazardous wastes
generated by others and to those transporting
hazardous wastes they have generated them-
selves, or combinations thereof.
Subsection (B) describes a system that would make the
State regulatory program self-supporting, which is
similar to the system used in California. The logic of
such a system is that the "polluter pay," and Subsection
(B) offers one way by which the generators of hazardous
wastes might be charged for the costs of a State program
to assure adequate treatment and disposal of those wastes.
If the State does choose to establish a special fund for
hazardous waste management, or any similar area, the
legislature will have to amend the State revenue code;
legislation such as a State hazardous waste management
act is not the proper vehicle for this.
Whether or not the State establishes any new fund,
thought should be given to some type of mechanism
which will allow the hazardous waste management sys-
tem to be self-sustaining. The State may elect a vari-
ant of this system, such as returning a surcharge from
treatment/disposal sites to the General Fund while
allocating the same amount to its regulatory program
through the usual appropriations process. In this case,
the State would avoid establishing any special accounts
within the General Fund.
TRANSPORTATION OF HAZARDOUS WASTES
Section 7
Many States have recognized the importance of trans-
portation in the "cradle-to-grave" life cycle of hazardous
waste management, and several have initiated hazardous-
waste hauler permit or control systems as their first step
in managing these wastes. The Congress has also recog-
nized the importance of transport control in managing
hazardous wastes, as demonstrated by the inclusion of
a manifest system in the Resource Conservation and
Recovery Act of 1976.
The Model Law directs the "appropriate State agency,"
rather than the environmental management agency, to
issue rules, regulations, and permits for the transport of
hazardous wastes. The wide variation in institutional
arrangements and responsibilities for the transport of
hazardous wastes make it impossible to specify the
"appropriate" agency for each State in this document.
The reader should distinguish, however, between the
economic aspects of regulation (usually assigned to the
State Public Utilities Commission, or equivalent agency),
and other aspects such as transportation safety (often
assigned to the State Highway Patrol, or equivalent
agency). The Model Law addresses only the latter
aspects.
-------
76 STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
Environmental agencies in a few States have been charged
with the responsibility for control of hazardous waste
haulers. Where a legislature chooses to do this, Sub-
section (A) should read: "... the Department shall issue
rules and regulations for the transportation of such

wastes."*
Note that P.L. 93-633 provides as follows:
Sec. 112. (a) General.—Except as provided in sub-
section (b) of this section, any requirement of a State
or political subdivision thereof, which is inconsistent
with any requirement set forth in this title, or in a
regulation issued under this title, is preempted.
(b) State Laws.—Any requirement, of a State or
political subdivision thereof, which is not consistent
with any requirement set forth in this title, or in a
regulation issued under this title, is not preempted if,
upon the application of an appropriate State agency,
the Secretary determines, in accordance with pro-
cedures to be prescribed by regulation, that such re-
quirement (1) affords an equal or greater level of
protection to the public than is afforded by the re-
quirements of this title or of regulations issued under
this title and (2) does not unreasonably burden com-
merce. Such requirement shall not be preempted to
the extent specified in such determination by the
Secretary for so long as such State or political sub-
division thereof continues to administer and enforce
effectively such requirement.
(c) Other Federal Laws.—The provisions of this
title shall not apply to pipelines which are subject to
regulation under the Natural Gas Pipeline Safety Act
of 1968 (40 U.S.C. 1671 et seq.) or to pipelines which
are subject to regulation under chapter 39 of title 18,
United States Code.
EPA and DOT are presently consulting upon implemen-
tation by regulation of Sec. 112 as hereinabove set forth
and relevant requirements of RCRA of 1976.
The State can achieve several ends through regulation
of the transportation of hazardous wastes: v

(1) The State must be aware of the whole life

cycle of hazardous waste, from "cradle-to-
grave." Were the State to regulate only the

treatment and disposal sites, there would be
no way of knowing which wastes should
have been delivered to such sites but were
not. Neither would the State know where
those wastes had gone. A system which re-
quires the hauler to report where he on-

loaded and where he offloaded wastes al-
lows the State to be sure that wastes really
went into the sites that the State directs.
*EPA has published a guide to assist the States in imple-
menting the kind of transportation control systems authorized
under this Section: "State Program Implementation Guide:
Hazardous Waste Transportation Control," EPA/530/SW-512.
-------
MODEL STATE HAZARDOUS WASTE MANAGEMENT ACT 77

Transportation control is an effective sub-
stitute for generator reporting, There may
be political or other obstacles which prevent
the State from requiring that generators re-
port the fact that they have produced haz-
ardous wastes. These obstacles probably
will not interfere with a system requiring
generators to tell transporters what they
are consigning, which effectively makes the
information available to the State.
(2) Another use of transportation control is to
insure that hazardous wastes actually reach
the treatment or disposal sites to which
they are directed by the State. Several
States have developed "manifest" systems
to this end. (The use here of the word
"manifest" is intended to represent the
several systems already in effect. These sys-
tems usually use the words "manifest" or
"trip-ticket" to distinguish such documents
from the shipping papers used in ordinary
commerce, such as billsof-lading.)
The two basic variants of the manifest sys-
tem use either the single-part or the multi-
part document. In the single-part variant,
the generator is required to give the mani-
fest to the hauler, who, in turn, surrenders
it to the treatment or disposal site operator.
Each party fills in his part of the document,
so that the final product includes certifica-
tions as to the origin, composition, quantity,
disposition, and handlers of each load of
wastes. The State may then require the
treatment or disposal site operator to sub-
mit reports on the manifests received, and
to maintain copies of them for specified
periods of time so that the Department may
inspect them. The hauler is required to have
the manifest in his possession while he has
the wastes, and must be prepared to show
it to authorized persons. The generator,
through filling out his portion, makes a full
disclosure to the hauler as to what it is that
he is consigning, and may be subject to such
penalties as obtain for perjury, where he is
not truthful. The multi-part system varies
in that each party submits his copy of the
manifest directly to the Department as he
-------
78 STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
finishes it. The State can then compare the
forms which are submitted, identifying ship-
ments sent to specific sites which have not
acknowledged their receipt. The State can
then determine whether the wastes were
disposed of at some other (possibly unac-
ceptable) site, or whether the reporting sys-
tem has malfunctioned. Either of these
variations on the manifest system meets the
first purpose of controlling the movement of
hazardous wastes from generation to treat-
ment or disposal. The single-part system is
simpler, and generates less paper; the cost to
the regulatory agency is that there is no se-
parate submittal from the generator to match
with the form that arrives (or fails to arrive)
from the treatment/disposal site. Conversely,
the cost to the State in using the multi-part
system is a large increase in the amount of
paper to be monitored. In many States this
would require automatic data processing
equipment, with the attendant increase in
costs and personnel.
(3) The manifest system serves an important
function in expediting emergency response
actions. Both variations of the manifest
system described above require the hauler to
have a copy of the manifest system in his
possession when he has the wastes. A prop-
erly designed and accurately completed man-
ifest tells emergency response personnel what
the material is, the dangers it presents, and
the proper procedures to follow to mitigate
damages. Equally important, the State en-
sures that the hauler is fully aware of what
he is carrying by requiring full disclosure
from the generator at the time of consign-
ment.
Existing DOT regulations require only that
the material be marked as "flammable,"
"toxic," or whatever the appropriate hazard
may be. The waste hauler, treatment/disposal
site personnel, and emergency-response person-
nel all need a fuller description of the material
being carried. This is especially true because
of hazardous wastes: there may be combina-
tion and mixtures of any number of different
substances, possibly posing several different
-------
MODEL STATE HAZARDOUS WASTE MANAGEMENT ACT
79
RECORDS; REPORTS; MONITORING
Section 8
(A) The Department shall adopt, and revise as appro-
priate, rules which prescribe:
(1) the establishment and maintenance of such
records;
(2) the making of such reports;
(3) the taking of such samples, and the perform-
ing of such tests or analyses;
(4) the installing, calibrating, using, and main-
taining of such monitoring equipment or
methods; and
(5) the providing of such other information as
may be necessary to achieve the purposes of
this Act.
(B) Six months after promulgation of the regulations
required under Section 4(C) (7) of this Act, it
shall be unlawful for any person to generate, store,
transport, treat, or dispose of hazardous wastes in
this State without reporting such activity to the
Department according to the procedures described
in said regulations.
types of threats.
(4) The manifest system is useful to the State in
compiling information on the quantity and
disposition of hazardous wastes within the
State. Because it is, in effect, a self-reporting
system for generators (generators must dis-
close information to the hauler which is later
submitted to the State), the State can monitor
the aggregate generation and treatment or dis-
posal of hazardous wastes throughout the
State. Any manifest system must be manda-
tory, including a prohibition against the
hauler accepting any wastes without a prop-
erly executed form.
Subsection (B) includes explicit coverage of those haul-
ing hazardous wastes "... they have generated them-
selves." This is an important provision and the State
should be certain that any regulations of hazardous waste
haulers include this or a similar phrase. Some States re-
gulated; this can be a significant loophole. Wastes are
no less hazardous, and the need for State cognizance no
different, for the fact that the hauler and the generator
are the same person. The existence of this loophole may
leave a large segment of the hazardous waste problem
unregulated.
RECORDS, REPORTS, MONITORING
Section 8
This Section allows the State to require submittal of the
information it needs to assure "cradle-to-grave" control
over hazardous wastes. This is a crucial element in the
State hazardous waste management program, as the
State must be aware of the kinds and quantities of haz-
ardous wastes for which it is responsible, the origins and
destinations of these wastes, and the integrity of the
treatment or disposal method used. The State can do
these things most effectively through rules or regulations
describing what is needed.
Section 8 explicitly covers all main participants in
hazardous^waste management. The State can only assure
sound management if it is aware of all potentially haz-
ardous wastes in the State, including those which remain
at the site of generation.
Subsection (E) is especially important to generating indus-
tries. Those States which have begun their own hazardous
waste management programs have encountered concern
from generators that trade secrets, or other proprietary
information, could be deduced from their wastes, or
-------
80
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
(C) Six months after promulgation of the rules required
under Section 8(A) of this Act, it shall be unlawful
for any person to generate, store, transport, treat,
or dispose of hazardous wastes within this State
without complying with the procedures described
in said rules.
(D) Any person violating any requirement authorized
by this Section shall be subject to the enforcement
provisions of Section 11 of this Act.
(E) Information obtained by the Department under
this Section shall be available to the public, unless
the Department certifies such information to be
proprietary. The Department may make such
certification where any person shows, to the sat-
isfaction of the Department, that the information,
or parts thereof, if made public, would divulge
methods, processes, or activities entitled to pro-
tection as trade secrets. Nothing in this Subsec-
tion shall be construed as limiting the disclosure
of information by the Department to any officer,
employee, or authorized representative of the
State concerned with effecting this Act.
INSPECTIONS; RIGHT OF ENTRY
Section 9
For the purposes of developing or enforcing any rule
or regulation authorized by this Act, any duly author-
ized representative or employee of the Department may,
upon presentation of appropriate credentials, at any
reasonable time - -
(A) enter any place where hazardous wastes are gen-
erated, stored, treated, or disposed of;
(B) inspect and obtain samples of any waste, includ-
ing samples from any vehicle in which wastes are
being transported, as well as samples of any con-
tainers or labels; and
(C) inspect and copy any records, reports, informa-
tion, or test results relating to the purposes of this
Act.
IMMINENT HAZARD,
Section 10
(A) Notwithstanding any other provision of this Act,
the Department, upon receipt of information that
the storage, transportation, treatment, or disposal
of any waste may present an imminent and sub-
stantial hazard to the health of persons or to the
environment, may take such action as it determines
to be necessary to protect the health of such per-
from reports to the State concerning their wastes. The
State should recognize and accommodate this concern
in establishing its program. However, the State should
retain the prerogative of determing that the release of
information would not be harmful if the claim of trade
secret is not valid. The Model Legislation includes the
requirement that persons seeking protection of informa-
tion demonstrate "... to the satisfaction of the Depart-
ment ..." that the information is indeed a "trade
secret."
INSPECTIONS: RIGHT OF ENTRY
Section 9
This Section parallels a common provision of existing
State and Federal environmental statutes. Subsection
(B) is of special importance to States regulating land
disposal and treatment of hazardous wastes.
Industrial wastes have traditionally been mobile, and the
State cannot effectively regulate the management of
these wastes without authority to monitor their move-
ments. The State must be able to inspect waste-carrying
vehicles to ensure that they are hauling what they say
they are, and that Federal and State safety provisions
have been met.
IMMINENT HAZARD
Section 10
The purpose of this Section is to allow the Department
to act immediately Where the potential for environ-
mental damage may be realized before the completion
of normal administrative or judicial remedies. *The
corollary to this is that the Department would use this
Section to prevent or minimize such damage only in
situations where immediate action was essential.
-------
MODEL STATE HAZARDOUS WASTE MANAGEMENT ACT
81
sons or the environment. The action the Depart-
ment may take includes, but is not limited to - -
(1) issuing an order directing the operator of
the treatment or disposal facility or site, or
the custodian of the waste, which consti-
tutes such hazard, to take such steps as are
necessary to prevent the act or eliminate the
practice which constitutes such hazard, which
may include permanent or temporary cessa-
tion of operation of a facility or site; and
(2) requesting that the Attorney General or ap-
propriate District Attorney commence an
action enjoining such acts or practices, and
granting a permanent or temporary injuc-
tion, restraining order, or other order upon
a showing by the Department that a person
has engaged in such acts or practices.
(B) In any civil action brought pursuant to this Section
in which a temporary restraining order, preliminary
injunction, or permanent injunction is sought, it
shall not be necessary to allege or prove at any
stage of the proceeding that irreparable damage
will occur should the temporary restraining order,
preliminary injunction, or permanent injunction
not be issued; or that the remedy at law is inade-
quate, and the temporary restraining order, pre-
liminary injunction, or permanent injunction
shall issue without such allegations and without
such proof.

ENFORCEMENT
Section 11
(A) Whenever the Department finds that any person
is in violation of any permit, rule, regulation,
standard, or requirement under this Act, the De-
partment may issue an order requiring such person
to comply with such permit, rule, regulation,
standard, or requirement, or the Department may
request that the Attorney General of this State
bring a civil action for injunctive relief in [the
appropriate] court; or, the Department may re-
quest that the Attorney General of this State
bring a civil enforcement action under Subsec-
tion ll(C)of this Act.
(B) Any person who knowingly violates any order
issued by the Department pursuant to this-Section
shall be liable for a fine not to exceed $25,000 per
The Section provides considerable flexibility. Where
the Department chooses, it may issue an administra-
tive order, but the Section also allows the Department
to seek a court order if it prefers.
Subsection (B) includes the phrasing ". .. it shall not be
necessary to allege or prove .. . that irreparable damage
will occur.. .sor that the remedy at law is inadequate
..." for the Department to take immediate action
under this Section. Such a waiver is a useful element in
any imminent hazard provision the State includes in its
hazardous waste management legislation. Its purpose is
to prevent lengthy legal delays over the correctness of
the Department's judgment that a threat is immediate,
and delays caused by affected persons forcing the De-
partment to exhaust such other (slower) legal remedies
as may be available to the Department. This phrasing
may be of special interest in those States where the
courts have been reluctant to consider limited environ-
mental damage to be "irreparable."
ENFORCEMENT
Section 11
Section 11 provides the mechanism by which the De-
partment can enforce the permits, rules, regulations,
standards, and requirements promulgated under the
authority of this Act.
The Department has three options under the Recom-
mended Legislation's enforcement provisions:
(1) the Department can issue an order
to the violator instructing him to
comply with whatever rule (or re-
gulation, etc.) he is violating;
(2) the Department can ask that an
action be brought for a penalty
against a violator; or
(3) the Department can obtain an
injunction against a violator.
-------
82
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
day of violation, imprisonment for not to exceed
one year, or both.
(C) Any person who violates any permit, rule, regula-
tion, standard, or requirement pursuant to Sec-
tions 4, 5, 6, 7, or 8 of this Act shall be liable for
a fine of not to exceed $25,000 per day of viola-
tion.
(D) Each day of noncompliance with any order is-
sued by the Department pursuant to this Section,
or of noncompliance with any permit, rule, regu-
lation, standard, or requirement pursuant to Sec-
tion 4, 5, 6, 7, or 8 of this Act shall constitute a
separate violation of this Act.
(E) An order issued under this Section shall be de-
livered by personal service and shall be served on
the person designated by the laws of this State as
appropriate to receive service of process.
INTERSTATE COOPERATION
Section 12
The legislature of this State encourages cooperative
activities by the Department with other States for the
improved management of hazardous wastes; for im-
proved, and so far as is practicable, uniform State laws
relating to the management of hazardous wastes; and
compacts between this and other States for the im-
proved management of hazardous wastes.
REPEALER
Section 13
The following laws of this State are hereby repealed on
the effective date of this Act:
These options provide the Department with wide lat-
itude in enforcing the rules and regulations promul-
gated under the Act. The Department may choose to
simply issue an order preventing an act or the contin-
uation of a practice which violates applicable regula-
tions, where the act or practice does not pose an
imminent threat of extreme hazard. Section 11(B)
then allows the Department to invoke criminal
penalties where such an order has been knowingly
violated.
Where damage has already occurred, and where that
damage appears to warrant compensation, the De-
partment may choose to seek civil penalties.
Last, the Department may choose to seek injunctive
relief for those situations where the potential hazard of
an act or practice appears to make that appropriate.
Subsections H(C) and 11(D) specify the Sections of
this Act which, if violated, can result in the imposition
of penalties. Failure to specify those Sections which
carry such sanctions may result in problems of "due
process," as persons subject to the Act must be given
clear notice of the sanctions which may result from
a violation. The State legislation should clearly
identify those provisions which carry penalties.
Subsection 11(E) is similarly important for reasons of
due process: the violator must receive "effective
notice" that he ]jas violated an order which may result
in criminal sanctions.
INTERSTATE COOPERATION
Section 12
Interstate cooperation is especially important in the
management of hazardous wastes. While air pollution
moves as the climate dictates, and water pollution as
geography and geology dictate, residuals destined for
the land move at human whim. Wastes going to the
land can and are transported by all manner of vehicle
to sites in any direction as far away from the point of
generation as economics allows. Many large industrial
centers are at or near the boundary of a neighboring
State, with the movement of wastes from generation in
one State to treatment or disposal in another State
being part of longstanding residuals management prac-
tices as a result.
The Congress has recognized this in the Resource
Conservation and Recovery Act of 1976, Section 1005
of which encourages certain interstate compacts. Where
States do not establish formal agreements, they may
-------
MODEL STATE HAZARDOUS WASTE MANAGEMENT ACT 83

SEVERABILITY find it useful to at least recognize publicly that inter-
Section 14 state co°Perati°n is especially important in managing
If any provision of this Act, or the application of any hazardous wastes by including phrasing similar to that
provision of this Act to any person or circumstances, » Section 12 of the Model Law * their own Hazardous
is held invalid, the application of such provision to Waste Management Acts.
other persons or circumstances, and the remainder of
this Act, shall not be affected thereby.
EFFECTIVE DATE
Section 15
This Act shall take effect on
-------
Appendix B
INFORfTlATION SOURCES FOR DISPOSING
OF SfTIALL BOTCHES OF HAZARDOUS WASTES
Mismanagement of industrial waste and indiscrim-
inate disposal of certain business and commercial
wastes and household items have already resulted in
numerous documented cases of air contamination,
land and water pollution, property damage, and in-
juries and death of humans and animals. Small
batches of hazardous wastes are generated as dis-
carded household items (for example, battery acid or
small pesticide cans), or as chemical wastes from small
business and manufacturing establishments, and from
commercial, university, and high school laboratories.
The objective of this guide is to outline informa-
tion sources on waste handling and disposal, and to
present available methods and options to advise the
waste holder on the disposal of small batches of haz-
ardous wastes.
It also provides a step-by-step procedure on what
to look for, who to ask, and what steps to take if you
suspect you have hazardous waste or material that
must be disposed of. It will enable you to answer the
following crucial questions concerning the disposal of
hazardous wastes:
• What are they?
• How do I identify them?
• How do I properly dispose of them?

IDENTIFYING HAZARDOUS WASTE
A hazardous waste is a waste that poses a threat to
life and property. It can contaminate the environ-
ment by virtue of being toxic, radioactive, explosive,
or flammable, as well as nonbiodegradable and bio-
accumulative.. When a hazardous chemical used in the
workplace or the lab is contaminated, or no longer
useful, the material is a potential threat if disposal is
not carried out properly.
The fundamental fact about these hazardous wastes
is that they are a menace to human health and the
environment. They can poison, burn, maim, blind,
and kill people and other living organisms immediately
when inhaled, swallowed, or brought in contact with
the skin, or they may wreak their havoc slowly over
time, affecting the nervous system, causing cancers,
or spawning birth defects. Some are nondegradable
and persist in nature indefinitely. Some may ac-
cumulate in living things. Some may work their way
into the food chain.
Hazardous wastes are found in a wide variety of
solid, liquid, or gaseous forms. They may be packaged
in small jars, bags, drums, cyclinders, cans, or aerosol
containers. Table B-l provides a partial list of com-
monly encountered sources of hazardous waste.
According to the Resource Conservation and Re-
covery Act of 1976, EPA must formally define a
hazardous waste by Spring 1978. Meanwhile, several
Federal regulations already deal with the hazardous
properties of chemicals, and the transportation of
these chemicals, or certain commercial products that
contain hazardous components. Several States do
maintain lists or criteria for hazardous wastes which
makes those agencies an excellent source of informa-
tion for determining what is hazardous.
All pesticides are regulated under the Federal
Insecticide, Fungicide, and Rodenticide Act (FIFRA),
as amended, and disposal must be in accordance
84
-------
INFORMATION SOURCES FOR DISPOSING OF SMALL BATCHES OF HAZARDOUS WASTES
85
TABLE B-l
COMMONLY ENCOUNTERED HAZARDOUS MATERIALS AND PRODUCTS
FOUND IN SMALL BATCHES OF WASTE
TYPICAL WASTE SOURCES
HAZARDOUS MATERIALS
1. ACIDS
Pickling Liquor
Battery Acid
Acidic Chemical Cleaners
Spent Acid
Plating Operations
Laboratory Glassware Acid Baths
Glass Etching Solutions

2. ALKALIES
Miscellaneous Caustic Products
Alkaline Battery Fluid
Caustic Wastewater
Cleaning Solutions
Lye

3. ORGANICS (Mainly Non-Hdogenated)
Capacitor Fluids
Chemical Cleaners and Solvents
Chemical Toilet Wastes
Electrical Transformer Fluids
Furniture and Wood Polishes
Laboratory Chemicals
Paint Removers
Silver Cleaning Agents
Shoe Polish

4. HALOGENATED ORGANICS
Cleaning Solvents
Laboratory Chemicals
Paint and Varnish Removers
Dry Cleaning Solutions
Capacitors and Transformers
Containing PCB

5. INORGANICS
Catalysts
Chemical Toilet Wastes
Laboratory Chemical Wastes
Paint Sludge
Plating Solutions
Fluorescent Lamps
Germicidal and "Disinfectant"
Solutions
Paints
Fluxes
Aluminum Cleaning Agents
Chromic-sulfuric acid mixture, hydrobromic acid, hydro-
chloric acid, hydrofluoric acid, nitric acid, perchloric
acid, sulfuric acid
Ammonia, lime (calcium oxide), potassium hydroxide,
sodium hydroxide, sodium silicate
Aromatic compounds, organic amides, organic mercaptans,
organonitriles, nitrobenzene, phosgene, thioureas
Carbon tetrachloride, chloroform, methylene chloride,
polychlorinated biphenyls (PCB)
Ammonium fluoride, ammonium silicofluoride,
antimony salts, arsenic salts, asbestos products and
fibers, beryllium compounds, barium salts, borane
compounds, cadmium salts, chromium salts, cyanide
compounds, inorganic halides (potassium bromide,
sodium iodide), lead compounds, mercury salts,
selenium salts, sodium silicofluoride, vanadium com-
pounds, zinc chloride
-------
86
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT

TABLE B-l

COMMONLY ENCOUNTERED HAZARDOUS MATERIALS AND PRODUCTS
FOUND IN SMALL BATCHES OF WASTE (CONTINUED)
TYPICAL WASTE SOURCES
HAZARDOUS MATERIALS
6. EXPLOSIVES
Illegal Explosive "Firecrackers"
Laboratory Wastes
Obsolete Explosives
Track Torpedoes
Blasting Caps
Detonators
Commercial Pyrotechnics for Private Use
7. PESTICIDES
Waste Pesticides
House and Garden Discarded Pesticide Cans
Waste Water from Cleaning of Pesticide
Containers
Containers and Pesticide Application
Equipment
Ammonium nitrate, ammonium nitrate-fuel oil mixtures
(ANFO), dynamite, mercury fulminate, nitroglycerin,
2,4,6-trinitrotoluene (TNT), water-gel explosives
Chlorinated hydrocarbon pesticides, organophosphate
pesticides, phosphorothioate pesticides, organic
carbamates, organic thiocarbamates
8. GASES
Welding Gases
Laboratory Gas Cylinders
Local Anesthetic "Aerosol" Cans
Medical Oxygen Cylinders
9. BANNED PRODUCTS
Banned Pesticides
Banned Hair Sprays
Banned Aerosol Bathroom Cleaners
Waste Lead-Base Paints
Acetylene, ammonia, carbon monoxide, chlorine, ethyl
chloride, hydrogen, hydrogen sulfide, methyl chloride,
nitrogen dioxide, oxygen, other gases under high
pressure
Aerosol products containing vinyl chloride as propellant,
aldrin products, lead-based paints containing 0.5 percent
lead or greater
-------
INFORMATION SOURCES FOR DISPOSING OF SMALL BATCHES OF HAZARDOUS WASTES
87
with label directions or with regulations and pro-
cedures published pursuant to Section 19 of the Act
(see Appendix C). Published guidelines provide for
the disposal of single containers of household pesti-
cide products that are securely wrapped in several
layers of paper in regular municipal solid waste dis-
posal facilities.
INFORMATION SOURCES
Detailed information on the hazardous charac-
teristics of laboratory chemicals and on the most
commonly used commercial and household products
can be obtained from the manufacturers/suppliers,
from open literature, and by contacting appropriate
governmental agencies.
Most chemicals used in the laboratories, or pro-
ducts used in the household or in small commercial
and business establishments carry warning labels as to
the hazards involved, if they contain hazardous sub-
stances or if they may be hazardous under certain
conditions of use. Thus, if the original label still
remains on the container, it should be read very
carefully as a first step toward waste identification
(and for safe handling and disposal). If the name of
the manufacturer or distributor of a product is known,
this source can be contacted for information on haz-
ardous characteristics of the product and on proper
handling and disposal procedures.
There are five reference manuals, available in many
public libraries and in most chemical laboratories,
that can be consulted on properties, uses, and hazard-
ous characteristics of laboratory chemicals and many
consumer products (Table B-2). Generally, descrip-
tions of the material's hazardous nature will be in
terms' of its toxicity, flammability, reactivity, explo-
siveness, or corrosive nature. The reference manuals
noted describe the hazardous nature of the material
in these terms, and some may give a relative rating of
its danger. Some of these references also tell whether
or not these materials are potentially carcinogenic
(cancer-causing).
Federal agencies can also be contacted for assist-
ance in the identification of hazardous material. A
list and brief description of these agencies are
presented in Appendix F.
DISPOSING OF HAZARDOUS WASTE
Some pertinent reference materials on treatment
and disposal are given in Table B-3. These references
identify treatment methods that have been used by
universities and industrial trade organizations (for
example, the Manufacturing Chemists Association).
The treatment and disposal methods given in these
references generally have not been evaluated by EPA
for their effectiveness and should be carried out only
by qualified personnel.
SELECTING THE PROPER DISPOSAL OPTION
Depending on the nature of the waste, the specific
location where the waste is generated, and the appli-
cable local ordinances and State regulations on waste
disposal, small batches of hazardous wastes can be
disposed of in a number of ways including, in order of
preference:

• Recycling or returning to supplier
• Transporting to a hazardous waste management
facility
• Using available laboratory equipment for treat-
ment/disposal
• Disposing of material in appropriate municipal
incinerators with permission of local and State
agencies (only if the previous three options are
not available)
• Disposing of material in "appropriate" landfills
with permission of local and State agencies
(and only as a last resort)

REUSE/RECYLE
The first disposal option selected should be to re-
turn the material either to the supplier or manufac-
turer or to the approved chemical trader, broker, or
reclaimer who can reuse or recycle the waste for some
useful end product. Lists of local laboratory supply
houses can be found in the "yellow pages" of the
telephone d'rectory or in certain publications such as
the American Chemical Society Publication 1975-76
LABGUIDE.
DISPOSAL IN HAZARDOUS WASTE
MANAGEMENT FACILITIES
Throughout the United States there are over 100
centralized facilities for processing and/or disposal of
hazardous wastes. Although a large number of these
facilities are owned and operated by private waste-
disposal service companies, there are also some which
are operated by municipalities and county agencies
(for example, County Department of Public Works in
several California counties). Some facilities, especially
-------
88
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
TABLE B-2
REFERENCE MANUALS ON HAZARDOUS PROPERTIES OF LABORATORY CHEMICALS
AND COMMERCIAL/INDUSTRIAL PRODUCTS
REFERENCE
CONTENTS
Gleason, Marion N., et al. Clinical toxi-
cology of commercial products;
acute poisoning. 3ded. Baltimore,
The Williams & Wilkins Co., 1969.
various pagings.
Stecher, P.G., et al. The Merck >
index; an encyclopedia of chemi-
cals and drugs. 8th ed. Rahway,
N.J., Merck & Co., Inc., 1968.
1713 p.
Sax, N.I., et al. Dangerous properties
of industrial materials. New York,
Reinhold Publishing Corporation,
1957. 1467 p.
Weast, R.C. Handbook of chemistry
and physics. 56th ed. Cleveland,
CRC Press, 1975-1976. various
pagings.
Christensen, H.E., Luginbyhl, T.T.,
and B.S. Carroll. Registry of
toxic effects of chemical sub-
stances; 1975 edition. Washington,
U.S. Government Printing Office,
June 1975. 1296 p.
Contains alphabetical compilation of 3,000 major
chemical substances (ingredients) found in widely used
commercial products, and gives toxicity information
and a toxicity rating for each ingredient. In addition,
the manual contains a trade name index for 17,000
products, identifies the manufacturers and lists the
ingredients for each product and identifies the toxic
components.
Describes 10,000 individual substances, provides data on
their toxic effects on humans and test animals, and lists
common uses for selected entries. In addition, the index
lists poison control centers and first aid procedures. A
cross-index of chemical names and formulas is also
given.
Lists 9,000 general chemicals and products;gives
descriptions of physical properties and toxicity, explo-
sion, fire, and radiation hazard ratings. For each
chemical, pertinent data are provided on personal hygiene,
ventilation, disaster control, shipping regulations, and
storage/handling procedures.
Identifies physical and chemical properties of most
organic and inorganic chemicals. The handbook gives
toxicity of select chemicals, and general information on
chemical hazards, fire precautions and first aid.
Identifies toxicity (to man, animals, and aquatic life) of
most known organic and inorganic chemicals and identi-
fies carcinogenic, teratogenic, and mutagenic nature, if
any.
-------
INFORMATION SOURCES FOR DISPOSING OF SMALL BATCHES OF HAZARDOUS WASTES
89
those operated by public agencies, handle a variety of
wastes including small batches of hazardous material.
At these facilities, a certain area within the disposal
site is set aside for handling hazardous wastes. A
number of waste disposal companies also provide
waste hauling service to their customers. Others that
do not provide hauling service usually request their
regular major clients to use only the services of re-
gistered waste haulers to bring wastes to the disposal
site. Unlike most regular refuse disposal sites which are
open 8 to 10 hours a day, 5 to 6 days per week,
some hazardous waste disposal sites have a very
restricted business-hour schedule, with a few accepting
wastes only by prior appointment. Nearly all facili-
ties require the waste generators to provide some data
on the general characteristics of their wastes and their
hazardous constituents. Such data are needed to
assure safe waste handling and disposal.
TABLE B-3

SELECTED LIST OF PERTINENT PUBLICATIONS ON TREATMENT AND DISPOSAL
OF SMALL BATCHES OF HAZARDOUS WASTES
REFERENCE
CONTENTS
Laboratory waste disposal manual
Washington, Manufacturing Chemists
Association, May 1970, 176 p.
How to dispose of hazardous household
wastes. Sacramento, California State
Water Resources Control Board.
(In preparation.)
Steere, Norman V., ed. CRC hand-
book of laboratory safety.
Cleveland,The Chemical
Rubber Co., [1971]. 854 p.

Shih, C.C., and D.F. Dal Porto
(TRW Systems and Energy).
Handbook for pesticide disposal
by common chemical methods.
Washington, U.S. Environmental
Protection Agency. (In
preparation.)

Lawless, E.W., T.L. Ferguson, and
A.F. Meiners (Midwest Research
Institute). Guidelines for th e
disposal of small quantities of
unused pesticides. Publication
No. EPA 670/2-75-057.
Washington, U.S. Government
Printing Office, June 1975. 331 p.
(Also distributed by National
Technical Information Service,
Springfield, Va., as PB-244 557.)
The manual stresses safe procedures for on-site waste disposal from
small laboratories, especially those in small communities not possess-
ing sophisticated equipment. Gives detailed waste disposal procedures
for 25 classes of chemicals (covering 1,121 individual chemicals) in
common use in laboratories and related facilities. Also provides
several recommended methods for the recovery of certain spilled
chemicals. Data on physical properties and hazardous properties of
the chemicals are also provided.

Lists 10 types of hazardous wastes most commonly found around the
home, and gives a brief description of the options available for the
disposal of these materials including direct disposal to the land, use of
municipal sewage treatment systems, use of special collection pits at
gasoline stations, etc. The booklet also provides hints for handling
hazardous wastes.

Gives procedures for the disposal of hazardous wastes and presents
chemical, biological, radiation, fire, and other hazards associated with
several thousand chemicals. The handbook also contains general
laboratory safety procedures.

Contains step-by-step chemical degradation/detoxification and dis-
posal procedures for 20 major pesticides which are representative
of the several hundred pesticides currently in use. The handbook also
contains an extensive review of the pertinent literature on various
reported chemical methods for the degradation and/or detoxification
of the selected pesticides.
Provides 14 detailed methods for the treatment and disposal of 550
pesticides and discusses treatment of small spills of pesticides and
methods for the disposal of empty pesticide containers. The manual
contains reference charts of pesticide properties pertinent to disposal,
and a cross index of chemical names, common names, and trade
names. The manual is intended to be used by regulatory authorities
in advising the layman on the disposal of pesticide wastes.
-------
90
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
In areas where hazardous waste disposal facilities
are readily accessible, small batches of hazardous
wastes should definitely be taken to such sites for
disposal. These sites, which are generally operated by
professionals with training and expertise in waste
management, utilize disposal methods which assure
minimum environmental damage. These facilities also
operate under permits from one or more governmental
agencies and are regularly inspected by the regulatory
agencies to assure compliance with the conditions of
their permits and all applicable regulations.
EPA has published a list of such facilities (EPA/
530/SW-146) called "Hazardous Waste Management
Facilities in the United States," which is available
through EPA, Office of Solid Waste.
"IN-HOUSE" TREATMENT/DISPOSAL
After it has been determined that the recycle/reuse
disposal option is not available and that the services
of a commercial hazardous waste disposal facility are
also unavailable, the generator of a small batch of
hazardous waste may investigate "in-house" treatment
possibilities for "on-premises" or "offsite" disposal.
Under appropriate conditions, and if regulations
permit, small batches of certain hazardous waste can
be disposed of "on-premises" after the waste is ren-
dered harmless or less hazardous (that is, detoxified,
neutralized, or encapsulated, e.g., in cement) by proper
treatment. In some cases, the treated waste may be
suitable for disposal in sanitary landfills or municipal
incinerators. Certain hazardous wastes, such as explo-
sives, for example, should not be handled "in-house."
HAZARDOUS WASTE DISPOSAL IN
MUNICIPAL INCINERATORS
Small batches of certain combustible hazardous
wastes can be incinerated in municipal incinerators
if it is determined that the disposal will not result in:
(a) explosion or emission of products which can be
damaging to the equipment or injurious to operating
personnel, and (b) generation of pollutants which
cannot be adequately controlled by the existing emis-
sion control equipment and procedures. Municipal
solid waste incinerators generally are not appropriate
for incineration of pesticides other than casual house-
hold containers. For regulations concerning destruc-
tion of hazardous wastes in municipal incinerators,
the local agency responsible for operation or regula-
tion of the incineration facility should be contacted.
In general, information on waste quantities and char-
acteristics would be required in order to determine
whether a hazardous waste can be safely handled in a
municipal incinerator. For all hazardous waste dis-
posal in municipal incinerators, obtain approval from
the local and State agencies responsible for solid or
hazardous waste disposal.

HAZARDOUS WASTE DISPOSAL IN
SANITARY LANDFILLS
Specific regulations on disposal of hazardous
wastes to sanitary landfills vary from locality to
locality and from State to State. As examples, some
States, such as Illinois, allow disposal of small amounts
of hazardous chemical wastes in certain sanitary land-
fills, whereas other States, such as Florida, prohibit
any land disposal of hazardous wastes unless they have
been "detoxified" prior to disposal. Generally, single
containers of household pesticides can be wrapped in
several layers of paper and discarded in the regular
municipal solid waste collection system. Local and
State agencies responsible for the operation or regula-
tion of a sanitary landfill should be contacted for
regulations on waste disposal before any hazardous
waste is taken to the sanitary landfill for disposal.
For all hazardous waste disposal in landfills, obtain
approval from the local agency responsible for solid or
hazardous waste disposal. >
-------
Rppendix C
INFORmPTION ON DISPOSAL OF PESTICIDES
flND PESTICIDE CONTRINERS
As State hazardous waste problems may include
disposal of pesticides or pesticide containers, some
background on current recommendations and infor-
mation sources is useful. Pesticides are regulated by
EPA under the Federal Insecticide, Fungicide, and
Rodenticide Act, as amended. Section 19(a) of this
Act requires EPA to establish recommended pro-
cedures and regulations to control the disposal and
storage of pesticides, and pesticide containers, and
accept for safe disposal those pesticides canceled
under Section 6(c). Thus far, EPA has published two
declarations on this subject.
On May 1, 1974, "Recommended Procedures for
Disposal and Storage of Pesticides and Pesticide
Containers" 39 FR 15236 was promulgated. This
publication provides guidance on the subjects of
disposal and storage (Subparts C and D) to the public,
but they are only regulatory for Federal agencies or
where Federal funds or property are involved. This
document also provides regulations relating to the
acceptance by EPA of suspended and canceled pesti-
cides (Subpart B).
Subpart C separates pesticides into three specific
categories for purposes of disposal-organic, organo-
metallic, and inorganic, with appropriate recom-
mended disposal procedures for each group. It also
cautions against the use of certain disposal procedures
which pose threats to the environment. Pesticide
container disposal is addressed in a similar fashion.
Finally, criteria and recommended procedures for
storage of pesticides and containers are outlined.
Subpart D relates to pesticide-derived wastes; if
such wastes are part of an industrial waste stream,
then the Federal Water Pollution Control Act or Safe
Drinking Water Act permits may apply; otherwise,
such waste should be handled as specified under Sub-
part C.
To provide control of the worst acts of pesticide
disposal, regulations were proposed on October 15,
1974, 39 FR 36867 to prevent water dumping and
ocean dumping except by permit, and open dumping,
open burning, well injection, and storage which could
lead to contamination of food or feed. These regula-
tions would amend the previously issued recom-
mended procedures and prohibit those procedures not
recommended (165.7). These regulations are ex-
pected to be promulgated in 1977.
The state-of-the-art on pesticide disposal and
storage is not well developed. Criteria for pesticide
incineration, disposal in landfills, rinse solution dis-
posal, chemical degradation methods, photodegrada-
tion, and storage have not been completed; grants and
contracts to answer these questions are planned and in
progress. The Solid Waste Management Representa-
tive in the EPA Regional Offices is the best source
of information on current regulations and status of
the developing pesticide disposal technology.
Included in this Appendix are several publications
addressing pesticide disposal and storage issues. These
publications deal with information sources, disposal
of pesticides, including dilute solutions, current pesti-
cide disposal research, the reconditioning of pesticide
containers, etc., and should be consulted for details:

• Regulations for Acceptance and Recommended
Procedures for Disposal and Storage of Pesti-
cides and Pesticide Containers, 39 FR 15236,
May 1, 1974
91
-------
92
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
Proposed Regulations for Prohibition of Certain
Acts Regarding Disposal and Storage of Pesti-
cides and Pesticide Containers, 39 FR 36867,
October 15, 1974
REFERENCES

Day, H. R. Disposal of dilute pesticide solutions. En-
vironmental Protection Publication SW-519.
[Washington], U.S. Environmental Protec-
tion Agency, June 1976. 18 p.
Day, H. Pesticide disposal information sources; a guide for
EPA personnel. [Washington], U.S. En-
vironmental Protection Agency, 1976. 11 p.,
app. [Prepublication copy.]
Ghassemi, M., and S. Quinlivan [TRW Systems Group]. A
study of selected landfills designed as pesti-
cide disposal sites. Environmental Protec-
tion Publication SW-114c. U.S. Environ-
mental Protection Agency, Nov. 1975.143 p.
(Distributed by National Technical Informa-
tion Service, Springfield, Va., as PB-250
717.)
Munnecke, D., H. R. Day, and H. W. Trask. Review of pesti-
cide disposal research. Environmental Protec-
tion Publication SW-527. [Washington], U.S.
Environmental Protection Agency, 1976.
76 p.
Shin, C. C., and D. F. Dal Porto [TRW Systems Group].
Handbook for pesticide disposal by common
chemical methods. Environmental Protec-
tion Publication SW-112c. U.S. Environ-
mental Protection Agency, Dec, 1975. 103 p.
(Distributed by National Technical Informa-
tion Service, Springfield, Va., as PB-252
864.)
Staton, W. S., and J. G. Lamperton [Oregon State University,
Environmental Sciences Center]. Pesticide
container processing in commercial recondi-
tioning facilities. Environmental Protec-
tion Publication SW=88d. [Washington],
U.S. Environmental Protection Agency, Nov.
1976. 21 p.
[Versar, Incorporated.] A study of pesticide disposal in a
sewage sludge incinerator. Environmental
Protection Publication SW-116c. U.S. En-
vironmental Protection Agency, 1975.186 p.
(Prepublication issue; to be distributed by
National Technical Information Service,
Springfield, Va.)
-------
Appendix D
THURSDAY, APRIL 1, 1976
PART V:
ENVIRONMENTAL
PROTECTION
AGENCY
POLYCHLORINATED
BIPHENYL-CONTAINING
WASTES

Disposal Procedures
Errata:

1. p. 14134, 1st column, 4th 1, 8th line: Insert to read
"The possible adverse effects on animals (Including nan)..."
2. p. 14135, middle column, 4th 1, 5th line: should read
"checking to assure that the materials are being properly
handled, treated, transported..."
3. p. 14136, 1st column, 1st II, 2nd line: should read "burial"
instead of "bureau"...

93
-------
94
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
14134

ENVIRONMENTAL PROTECTION
AGENCY
|FRL 514-41

PCB-CONTAINING WASTES
(INDUSTRIAL FACILITIES)
Recommended Procedures for Disposal
On December 22, 1975, the Adminis-
trator of the Environmental Protection
Agency announced an action plan of
regulatory and administrative actions to
help ensure that polychlorinated biphen-
yls currently in service do not enter the
environment. One portion of that pro-
gram includes investigation and recom-
mendation of •appropriate disposal pro-
cedures for industrial users of this fam-
ily of chemicals or products containing
them. The Agency is also evaluating the
consumer waste disposal problem and
may issue further guidance on that sub-
ject at a later time.
Purpose.—Pursuant to Section 204
-------
POLYCHLORINATED BIPHENYL-CONTAIMING WASTES
95
NOTICES
i-ii.rv
oxidation or other types of chemical deg-
radation explains their persistance and
accumulation in animal tissue.
The chemical inertness and resistance
to metabolism of PCBs account for their
low acute toxicity. Chronic toxic effects
vary in different animal species; they in-
clude skin, liver, and kidney lesions in
rabbits as well as chloracne and hepato-
toxic effects in man.
The low solubility of PCBs in water
probably limits the rate at which they
are dispersed by water systems. PCBs
discharged into a river or lake will ac-
cumulate in the sediment in relatively
high concentrations. Plants and animals
can concentrate PCBs above their level
in water alone. Some fish species taken
from Lake Michigan in 1970 and 1971
have exhibited PCB concentrations
greater than 5 ppm. Shrimp and oysters
exposed to 10 ppb of Aroclor 1254 have
shown bioaccumulations from 130- to
3300-fold; bioaccumulations in some
species of 40,000 to' 75,000 have been
experienced.
PCBs are not intended to get into the
environment, but they do because their
unique chemical properties prevent them
from' being destroyed by usual waste
treatment methods. Thus, they inadvert-
ently escape and become widely dis-
persed. Environmental transport models
for PCBs have not been developed. Con-
clusions regarding their behavior, par-
ticularly their distribution and transport
in the environment, are based largely
upon the results of DDT research. Recent
data indicates that aerial transport may
play a major role in the worldwide dis-
semination of PCBs, although dumping
and river runoff may contribute more im-
portantly to local contamination of fish,
wildlife, and drinking water sources.
Degradation characteristics of PCBs are
not well understood. Some dibenzofu-
rans, which are extremely toxic, may be
degradation products of PCBs.
Disposal ot PCB-Containing Wastes.—
The persistence of PCBs necessitates ex-
tremely careful attention to final dis-
position of PCBs and PCB-containing
materials. First, the use of PCBs should
be reduced. Manufacturers or users
should use more environmentally accep-
table substitute materials whenever pos-
sible. However, spills, damaged goods,
and housekeeping materials will require
disposal. All absorbents and other clean-
up materials should be carefully selected
with disposal implications in mind.
Reclamation of PCBs is usually feasi-
ble only with relatively uncontaminated
liquids and should be carried out only if
there is virtually no chance of PCB losses
to the environment. Recycling is advisa-
ble only as long a adequate substitutes
for PCBs are not available. Monsanto
maintains a toll-free telephone number
(800/325-38501 for the public for advice
on scrap PCBs. If liquids cannot be re-
used, these liquids should be disposed of
by high temperature incineration.
Recycling of transformer fluids is ac-
complished by several companies. The
tank and inside copper of the trans-
former is reclaimed; the PCB liquids, if
they cannot be reused, should be
incinerated.
PCBs can be leached from solid manu-
facturing wastes with a suitable solvent.
eg., trichloroethylene or acetone. The
decontaminated waste can then be dis-
posed. The solution containing PCBs may
be separated by distillation into PCB,
which may be reclaimed, and the solvent.
which may be used again The distilla-
tion technique is also applicable to re-
move PCBs from contaminated liquids.
This technique 'of leaching and recla-
mation i is especially useful after acci-
dential spills of liquid PCBs. Spills could
be absorbed on dry sand. ash. sawdust,
or commercial absorbents and thpp
processed as above.
As noted on Figure I, there are ap-
proximately 750 million pounds of PCBs.
incorporated into products, currently in
service. These products will utilmately
require disposal. If a capacitor or trans-
former has a label identifying one of the
trade names shown in Appendix A, it
should be handled as a PCB. and the
options listed below followed. If the con-
tents are unknown, but the manufac-
turer is one of those listed in Appendix
A. an inquiry should elicit information
on the contents of the equipment or
product.
Effective safeguards should be em-
ployed in the handling and transport of
the PCB-containing wastes. These in-
clude the use of protective clothing,
closed containers for transportation, and
adequate labeling to alert personnel to
hazards from routine disposal as well as
emergency response in the event of a
spill or accident.
Anyone responsible for the disposal of
PCBs should select high-quality firms
for the transport and disposal of their
PCB-containing wastes. Also, spot-
check to assure transported, and disposed
is recommended. The generator of the
waste should take responsibility for
proper waste management.
Recommended options for the disposal
of PCB-containing wastes (in priority
order) are;
Incineration
Controlled land disposal

Incineration—The proper incinera-
tion of waste PCB must involve a suita-
ble balance among temperature in the
incinerator, dwell time in the firing
chamber, and oxygen availability. Also, a
suitable scrubber should be provided on
the exhaust stack to remove the hydro-
chloric acid mist that is formed. Exhaust
gases should be monitored to assure com-
pliance with air regulations.
Recommended requirements are: d>
2-second dwell time at 1100 C (2000 F)
and 3 percent excess oxygen in the stack;
or d) 1"2 second dwell time at 1500 C
(2700 F) and 2 percent excess oxygen in
the stack gas.'. Open hearth and other
incinerators used for municipal refuse In-
cineration are not normally suitable; the
relatively low operating temperature of
such equipment would only volatilize the
PCBs and pollute the atmosphere. In
addition, instrumentation and handling
equipment are usually not sufficient for
managing hazardous materials. There-
fore, PCB-containing waste should not be
sent to such municipal incinerators for
disposal.
The above recommendations are suit-
able for liquids Incineration of solid
wastes containing PCBs has not been
demonstrated However, such destruction
does appear feasible. For example, a
rotary kiln furnace, with an afterburner
and scrubbing system, could probably
safely incinerate solid wastes containing
PCBs. Likewise, other smaller, high
temperature incinerators with sufficient
residence times may be satisfactory for
the smaller waste generator.
As a service. Monsanto will incinerate
i for a fee i any returned liquids in their
high temperature incinerator. A tech-
nical description of the Monsanto in-
cinerator is provided in Appendix B.
EPA publication, Hazardous Waste
Management Facilities (EPA/530/SW-
146 i.- provides information on some in-
cineration facilities. Use of these facili-
ties for incineration of PCB-containing
waste should be checked with EPA
Regional and State representatives to
assure that the facilities have adequate
environmental controls to meet Federal/
State local regulations.
Land Disposal—Wastes containing
PCBs should not be dispo^ of with
other mixed wastes in a sanitary landfill
(See EPA Guidelines on Thermal.Proc-
essing and Land Disposal of Solid Waste,
Federal Register, August 14. 1974).
Characteristics of transport of PCBs
through the soil are not definitively es-
tablished. The interaction with other
decomposing wastes is not well under-
stood. Some landfills may contain or
accept wastes which could cause the re-
lease of PCBs. The ubiquity and per-
sistence of PCBs indicate that their dis-
posal should be carefully controlled until
additional data aie developed. While
these data are being gathered, PCBs
(when disposed to the land) should only
be placed in a secure chemical waste
landfill.
In general terms, a chemical waste
landfill provides complete long-term pro-
tection for the quality of surface and sub-
surface waters from hazardous waste de-
posited therein, and against hazards to
public health and the environment. Such
sites should be located or engineered to
avoid direct hydraulic continuity with
surface and subsurface waters. Gen-
erated leachates should be contained,
and subsurface flow into the disposal
area eliminated. Monitoring wells should
be established, and a sampling and
analysis program conducted. Additional
characteristics of a chemical waste land-
fill are described in EPA publication,
Landfill Disposal ol Hazardous Wattes:
A Review ot Literature and Known Ap-
proaches (EPA/530/8W-165).'
1 These values are from ANSI C107.1-1974.
Guidelines for Handling and Disposal at
Capacitor and Transformer-Grade Askarels
Containing Potychlorlnated Blphenyls,
American National Standards Institute
- Document* referenced here m»y b« ob-
tained from Solid Waste Information, UJB.
Environmental Protection Agency, Cincin-
nati. Ohio 46268
FEDERAL REGISTER, VOL. 41, NO. 44—THURSDAY, APRIL 1, 1976
-------
96
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
11136

Encapsulation of wastes in cement
prior tq .bureau in a sanitary landfill has
been used for small quantities of solids
or sludges. This is usually done by cast-
ing the waste in concrete inside^a drum
prior to deposition in the landfill.
Only those specific sites which have
been State-approved lor PC1J wastes
should,be used. The EPA publication,
Hazardous Waste Management Facili-
ties, (EPA/530/SW-146 provides some
information to potential disposers; these
data when used in consultation with
State solid waste nuinnKcment officials
can assist in IL disposal action.

Dated: March 26, 1976.
ROGER STRELOW,
Assistant Administrator
lor Air and Waste. Management.

APPENDIX A
LISTING OF NAMES USED FOR I'C'BS BY
MANUFACTURERS
Name: Manufacturer
Aroclor Monsanto.
Asbostol . . American Corp.
Asknrcl ... _. (')
Chlorcxtol _. Allls Chalmers.
Dlaclor San{-.inio Electric.
Dykanol .. Cornell Dublller.
Klcmcx .- ... McGraw Kdlson.
Hyvol - . Acrovox.
Inertcen . Wcstlnfjhouse
Electric.
No-Flamol ... Wanner Electric.
Pyranol . _ General Electric.
Saf-T-Kuhl _ _ Kuhlman FHcclrlr.
Clophcn . Bayer (Germany).
DK .. Cuirnro (Italy).
FeiAlor Cairaro tHaly).
KoimcrHlor _. Mlt.suul.shl (Japan).
Phc'noclor Prodelec (Prance).
Pyralenc _ _. Prodelec (Prance).
Santothcrm _. Mitsubishi (Japan).
1 Generic name used for Insulating liquids
In capacitors and transformers: may contain
PCBS.

APPENDIX B—DESCRIPTION op MONSANTO
INCINERATION FACILITY

SAUGET. ILLINOIS

Background.—The Krummrich Plant
is one of Monsanto's large chemical
manufacturing plants. The product line
Includes sulfuric acid, benzene, chlorine,
polychlorinated biphenyls. several rub-
ber compounds, and various chemical
intermediates. The plant Is located Im-
mediately south of East St. Louis, 111.
near the Mississippi River. Since June
1971, Monstanto has operated a liquid
Injection Incinerator to dispose of in-
NOTICES

house liquid wastes and contaminated
PCBs from customers.
Waste Characteristics.—The large
majority of the wastes burned are PCB
derivatives. The sources of Ihese wastes
are process still bottoms and contami-
nated transformer oils. The heating
value of -the materials is about 9000
BTU/lb. Other in-house high BTU
liquid wastes are also incinerated. Phos-
phorous compounds cannot be burned
due to the formation of particulates-1
iP.O.i which foul the injection system.
The system is not equipped to handle
.suspended solids. Four 20,000 gallon
tanks are available for storage. The
wastes are typically stored for several
days before incineration to allow undis-
solved solids to settle. After the settling
period, the wastes are pumped directly
from the tanks to the liquid combustor.
Incinerator Description.—The in-
cinerator is a liquid injection type
housed in a horizontal cylinder 20 ft.
long and 9.5 ft. in diameter. High pres-
sure steam is used to atomize the waste
liquid and inject it into the liquid com-
bustor. The feed rate measures 2 gal/
min. An additional gun which burns nat-
ural gas is also positioned inside the
plenum. The natural gas serves as an
auxiliary fuel to supplement the heating
value of the waste if necessary. The
operating temperature varies from 2000"
to 2200 P. If the temperature .is too high,
water can be sprayed into the chamber
to act as a heat sink. The cylinder is
protected from the heat by a lining of re-
fractory brick. High alumina brick is
used -in the plenum chamber. A blower
supplies 25% excess air forcing the fumes
from the plenum and through an oxi-
dizer. The residence time inside the
oxidizer is 2-3 seconds.
The unit Is operated 24 hours/day re-
quiring 2 men/shift. Initial capital costs
were $740,000. The disposal cost has
averaged 10<71b.
Air Pollution Control.—The fumes exit
the oxidizer and enter a water quench
column. The main purpose of the quench
is to reduce the temperature of the hot
fumes. Particulates are removed next in
a high energy venturi scrubber. Finally,
the emissions are cleaned in a packed
bed (polypropylene packing) at the base
of the stack. The 40 ft. stack is equipped
with a demister.
BIBLIOGRAPHY
1. Polychlorinated btphenyls and the en-
vironment. Interdepartmental Task Force on
PCB's. Depts. of Agriculture, Interior, HEW,
Commerce and EPA. May 1972.
2. Carnes, R.. Doerger. J.. Spearks, H. L.
Polychlorinated biphenyls In solid waste and
solld-waste-related materials. Cincinnati.
1973.
3. American National Standards Institute
( ANSI ) . Guidelines for handling and disposal
of capacltor-and transformer-grade askarels
containing polychlorinated biphenyls. New
York, January 1974.
4. Peaksall. D. B. PCB's and their environ-
mental effects. Crltfcal Reviews in Environ-
mental Control. CRC. 1975. .
5. Broadhurst, M. Use and replaceablllty of
polychlorinated biphenyls. Environmental
Health Perspectives. Oct. 1972.
6. Versar. Inc. Assessment of wastewater
management, treatment technology, and as-
sociated costs for abatement of PCBs concen-
Ind
rt}.
(Draft report}.
7. Bremer. K. State of concerns, of the Lake
Michigan Toxic Substances Committee re-
lated to PCB. Chicago. Internal EPA Report.
8. Aroclor. Polychlorinated polypheyls (bi-
phenyls). Technical Bulletin 6-FF/IR. St.
Louis: Monsanto Industrial Chemicals Com-
pany. NOV. 1971.
9. PCB's — environmental Impact. Environ-
mental Research. 1972.
10. PCB's their use and control. Organiza-
tion for Economic Cooperation and Develop-
ment. Paris. 1974.
11. Sewage sludge incineration: Section IV.
Effect of Incineration on metals, pesticides,
and polychlorinated biphenyls. EPA Task
Force. March 1972.
12. PCB Conference. National .Swedish En-
vironment Protection Board. 1970, pg. 83-86.
13. Hazardous waste management facilities
in the United States. Leshendok, T. Environ-
mental Protection Agency SW-146, revised,
1976. .
14. Scurlock, A. et al. Incineration In haz-
ardous waste management. Environmental
Protection Publication SW-141. 1974.
15. Llndsey, A. and Fields, T: Landfill dis-
posal of hazardous wastes: review of litera-
ture and known approaches. Environmental
Protection Publication SW-16S, 197S.
16. Farb. D. and Ward, S. D. Information
about hazardous waste management facil-
ities. Environmental Protection Publication
SW-145, 1975. . , , .
17. Tucker, E., et al. Migration of PCB's in
soil Induced by percolating water. Monsanto
Co. Bulletin of Environmental Contamina-
tion and Toxicology, Vol. 13. 1975.
18. ASTM. Standard method of test for
rapid gas chromatograpblc estimation of
higher boiling homologues of chlorinated bi-
phenyls for capacitor askarels. Specification
D 3303 (1973).
19. ASTM. Analysis of environmental mate-
rials for polychlorinated biphenyls. Specifi-
cation D 3304 (1974).
20. HEW. Registry of toxic effects of chem-
ical substances. 1975 Edition NIOSH June
1979.
21. Mitre Corp. Environmental cycling ol
PCB's. 1975 (unpublished draft report).
|FR Doc.76-9420 Filed 3-31-76:8:45 am|
1101329
SW-516
FEDERAL REGISTER, VOL. 41, NO. 64—THURSDAY, APRIL I, 1976
-------

0
Appendix E
WEDNESDAY, JUNE 9, 1976
PART I:
ENVIRONMENTAL
PROTECTION
AGENCY
VINYL CHLORIDE
Recommended Procedures
for Disposal of Aerosol Can
97
-------
98
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
VINYL CHLORIDE
Recommended Procedures for Disposal of
Aerosol Cans

Background. On January 22, 1975, the
Environmental Protection Agency In
the FEDERAL REGISTER canceled certain
indoor aerosol pesticide products which
contain vinyl chloride as a propellant (40
P'R 3494). Following that action, the Of-
fice of Solid Waste Management Pro-
grams (OSWMP) of EPA developed in-
ternal guidance for the use of its Re-
gional Offices should they be requested
to provide disposal advice to affected
parties.
On September 5, 1975, and again on
February 6, 1976, the Consumer Product
Safety Commission (CPSC) reaffirmed
in the FEDERAL REGISTER its regulation
declaring any self-pressurized products
intended or suitable for household use
that contain vinyl chloride monomer as
an ingredient or In the propellant to be
"banned hazardous substances". That
action included certain repurchase re-
quirements for manufacturers and had
obvious disposal implications. In fact,
CPSC in the September 5, 1975, FEDERAL
REGISTER notice requested appropriate
Industry officials to conduct their repur-
chase and disposal actions in accordance
with EPA guidelines (40 FR 41170). It
was also noted "* * • that many
States and municipalities have adopted
codes for the disposal of hazardous
wastes • • • [which, in many instances]
are in conformity with EPA guidelines
and will insure the proper disposal of
the products involved." No seizure ac-
tions have been initiated to date, but the
CPSC, if necessary, "will recommend to
the Courts disposal methods consistent
with EPA guidelines."
Purpose. Pursuant to section 204(b)
(1) of the Solid Waste Disposal Act, as
amended, the Administrator may Issue
guidance and recommendations to State
and local government, industry, organi-
zations, and individuals, related to the
disposal of waste materials.
The purpose of this publication is to
provide guidance for the disposal of
vinyl chloride-containing aerosol cans.
This guidance is'addressed primarily to
holders1 of large quantities of vinyl
chloride-containing aerosol cans, al-
though the recommended procedures are
appropriate to disposal of any such
wastes. These recommended procedures
represent the best Information available
on preferable disposal options for vinyl
chloride-containing aerosol cans.
When the problem of disposal sur-
faced, little was known about the chemi-
cal interactions of vinyl chloride mono-
mer (VCM) with the environment.
While the chemical and physical prop-
erties of VCM as they generally relate to
its manufacture and use are known, there
Is limited information on how VCM re-
acts in a land disposal site environment.
However, comparison of the known prop-
erties of VCM to those of other gases has
been attempted in order to provide a base
for recommended procedures for the dis-
posal of VCM-containing aerosols. The
following recommendations acknowledge
recommended procedures for pesticide
disposal as well as procedures for dis-
posal of heavy-metal containing mate-
rials.
Technical background. Vinyl chloride
monomer (VCM) is a chlorinated alkene
hydrocarbon with a density of twice that
of air. Since VCM boils at -13.37 C, It is
a gas at normal atmospheric temperature
and pressure. Vinyl chloride is highly
flammable having a flash point of —78
C. The explosive limits are from 4 to 22
percent VCM in air by volume.
VCM Is soluble In organic solvents,
but not very soluble in water. The quan-
tity of VCM that dissolves in water de-
pends on the partial pressure of the gas
above the solution. If the partial pres-
sure of the gas above the water is re-
duced, VCM will escape into the gas
phase and be released to the ambient air.
Chemical reactions, which can occur be-
cause of water impurities, might tend to
inhibit escape of vinyl chloride. Certain
salts have the ability to combine with
VCM; for example, soluble silver and
copper salts increase the solubility of
VCM in water by forming complex dis-
solved salts.
VCM makes up about 20 percent by
volume (equivalent to about 18 percent
of the net weight) of the propellant in
most of the canceled pesticide aerosols.
The pesticides Involved are mainly pyre-
thrins, llndane, and malathion. In hair
sprays, deodorants, paints, etc., however,
VCM may constitute as much as 40 to 45
percent by volume of the contents. Other
propellants are chlorpfluorocarbons 11
1 The CPSC estimated In Its September 6,
1976, Federal Register notice that an esti-
mated 3.3 million cans of vinyl chloride
aerosols were In existence. Of these, approxi-
mately one million were In the hands of
manufacturers, wholesalers, and retailers
The remaining 2.3«nllllon cans were In ih<-
possession of the consumer. «,
FEDERAL REGISTER VOl. 41, NO. 112—WEDNESDAY, JUNE 9, 1976
-------
VINYL CHLORIDE
99
and 12 (e.g., Preon). Although EPA has
no data on the Ingredients of non-pesti-
cide aerosols, halrsprays, for example,
would be expected to consist mainly of
organlcs, while paints may contain heavy
metals such as cadmium, lead, chro-
mium, or mercury.
Disposal of VCM-contatntng aerosol
cans. Final disposal of VCM-contalning
aerosol cans should be undertaken using
methods listed in order of preferred
priority:
1. High temperature Incineration (except
for products containing heavy metals)
2. Burial In a State-approved chemical (or
hazardous) waste landfill
3. Burial In a separate area of a State-
approved sanitary landfill.

It should be noted that chemical treat-
ment to recover the active materials may
be technically feasible, but would re-
quire special handling techniques to
remove the contents from the cans. Since
this process is very costly, Its feasibility
depends largely upon the value of the
recovered materials.
Incineration. Incineration should be
used when possible for final destruction
of the materials. This method is limited
to heavy duty rotary-kiln or other In-
cinerators that (1) can handle aerosol
cans without damage, (2) operate at a
temperature of 1000 C with two seconds
dwell time, and (3) are equipped with
appropriate pollution controls to meet
State or local air pollution control re-
quirements. Inclnceratlon should not be
used where the product contains more
than trace quantities of heavy metals
such as lead, mercury, cadmium and
chromium.
High temperature incineration of
pesticides, VCM, and the other propel-
lants and solvents or carriers found in
aerosol units can effectively be carried
out at 1000 C with a dwell time In the
combustion zone of two seconds. Al-
though VCM probably is destroyed at a
lower temperature (one source indicated
700 C was sufficient), preparations con-
taining pesticides may not be complete-
ly combusted. Additionally, the hair
sprays, deodorants, etc. contain unknown
resins which may require higher* tem-
peratures for complete destruction.
Since the cans explode and produce
shrapnel at high temperatures, only
heavy duty rotary-kfln or equivalent
units should be considered If more than
about 13 cans are to be disposed of at
one time. Incincerator feed mechanisms
should be adjusted to prevent injury or
damage from blow-back which may oc-
cur when several aerosol unite (nich
as one case) are Introduced simultane-
ously.
A pollution control system will be re-
quired to remove potential air con-
taminants. Most of tbew aerocols con-
tain ddanOuorocarboD propeUanto as
NOTICES

publication. Hazardous Waste
Management Facilities (EPA/530/8V-
146.2),' provides information on some
Incineration facilities. Use of these fa-
cilities for Incineration of VCM-con-
taining aerosol cans should be checked
with EPA Regional and State represent-
atives to assure that the facility has
adequate environmental controls to meet
Federal/State/local regulations.
Chemical Waste Landfills. In some
areas there are public or commercial
landfills that have been approved by
State agencies to accept industrial haz-
ardous wastes. Such sites are located,
engineered, or constructed to avoid hy-
draulic continuity with either surface or
ground water. Disposal of VCM aerosols
in these facilities does, however, require
extraordinary care above that given to
other toxic or hazardous wastes (such
as sludges), because the gases that could
be released upon rupture of the unit are
highly volatile and flammable as well as
toxic.
Further details on the recommended
site criteria and operating procedures for
landfllling are given in the following sec-
tion. Specifically, however, in the case of
VCM disposal in a chemical waste land-
fill, special bottom liners would not be
needed, although all other criteria and
procedures f.liould be followed.
State-approved Sanitary Landfills.
Sanitary landfills for disposal of aero-
sols containing VC, should only be con-
sidered if an adequate incinerator or
chemical waste landfill is not available.
Even then, special conditions should be
observed to assure proper disposal. Such
a landfill should be located an.
•Befennoed document may be obtained
from SDBd Waste Information, U.S. Enrtron-
Agency,
23227

by the clay fraction of the soil. Soil
moisture also impedes the dispersion of
gases in soils; however, the best medium
to contain gases would have a moisture
content approaching 50 percent of field
capacity. Such soils also normally con-
tain a large, varied population of micro-
organisms including several species that
might attack the organic compounds
found in aerosols.
Recommended Procedures for Land-
fllling. State-approved sanitary landfills
that are located, designed, and operated
in accordance with EPA's "Guidelines
for the Land Disposal of Solid Wastes"
(40 CFR Part 241) published August 14,
1974, in the Federal Register (39 FR
29328) are acceptable, provided that the
following special criteria and procedures
are utilized:

(1) Advance notice Is given to the appro-
priate State agency:
(2) A facility Is chosen which has ground-
water monitoring facilities or such facilities
are provided prior to disposal of the cans
Quarterly monitoring for heavy metals or
other potential pollutants should be carried
out:
(3) The burial site Is specifically recorded
In the property records;
(4) A separate, clearly marked area Is set
aside so that the bottom of the trench (In
which the aerosol cans are to be placed) Is at
least one foot above the 60-year high water
table:
(5) A trench with minimum depth of 10
feet Is dug:
(6) A high-density polyethylene film (20
to 30 mil) (or equivalent material) Is prop-
erly Installed at the bottom of the trench:
(7) One foot of topsoll covers the film (see
note);
(8) A single layer of ra~es. or randomly
distributed cans do not exceed 12 inches In
depth and 3 feet In width:
(9) One foot of topsoll covers the cans Kee
note);
(10) Six feet of cover material Is com-
pacted over the topsoll (see note);
(11) A high-density polyethylene film liner
(30 to 30 mil) Is laid over the compacted
cover;
(12) One foot of final cover Is compacted;
and
(13) The following safety precautions are
observed during disposal:
No smoking or open flames, since VCM is a
flammable gas.
No direct compaction of cans Is under-
taken elnce rupture will expose workers to
hazardous or toxic vapors, ^
Each day's accumulation Is covered with at
least one foot of topsoll and fl feet of cover
and compacted.
NOTE.—Organic matter, clay, and moisture
contents of soils will provide additional pro-
tection by Interfering with the movement of
chlorinated hydrocarbon pesticides and VCM
to the surface or to the water table. The top-
soil and cover material should contain less
than the optimum moisture content for com-
paction. In order to provide more pore space
for the absorption of gases. The final cover
should be mounded to approximately six
Inches above grade In the center to promote
runoff and reduce infiltration.

Dated: June 4.1978.

ftocnt Snziow,
AttMaxt Administrator for
Air and Watte Management.
[is DM.7B-UM7 FIM t-t-n-.t-.u amj
MDBUt HOtCTR, VOL 41, NO. 11J—WEDNESDAY. iVN* t, 1*7*
-------
Pppendix F

FEDERflLflGENCIES
The activities in hazardous waste management at
the Federal level are concentrated in the EPA, Office
of Solid Waste (OSW). Within OSW, the Hazardous
Waste Management Division (HWMD) is primarily
involved in: (a) building a data base in the hazardous
waste management area, particularly in connection
with public health and environmental damage assess-
ment, quantification of hazardous waste generation,
and definition of applicable treatment and disposal
technology; (b) development of guidelines and stand-
ards for hazardous waste management; and (c) pro-
gram implementation involving assistance to States in
development of hazardous waste management pro-
grams. HWMD has sponsored numerous studies on
hazardous waste management and has an extensive
data file on pertinent literature publications and do-
cuments.
The EPA has ten Regional Offices. Each Regional
Office has a solid waste management representative to
whom inquiries; should be directed. Figure F-l
contains a map locating the regional offices and their
coverage; Table F-l lists addresses and telephone
numbers for the Regional Solid Waste Management
representatives, Air and Hazardous Materials Division,
and the Regional Administrator.
In addition to the Office of Solid Waste, a number
of other EPA offices have certain programs and re-
sponsibilities related to identification, handling, and
regulation of hazardous substances. A listing of the
most pertinent of these agencies is shown in Table F-2.
Major Federal agencies other than the EPA, which are
concerned with various environmental aspects of haz-
ardous materials, are listed in Table F-3 along with a
brief description of their responsibilities.
ALASKA
J^

VJ
TRUST TERRITORIES
HAWAIIAN
•• -..ISLANDS
IX**
IGUAM

VIRGIN
ISLANDS .—..-'
u •
PUERTO RICO
Figure F-l. United States Environmental Protection Agency, regional offices.
100
-------
FEDERAL AGENCIES
101
TABLE F-l
ENVIRONMENTAL PROTECTION AGENCY REGIONAL OFFICE

Region
I
II
III
IV
V
VI
VII
VIII
IX
X
SWM Representative
Address as:
Solid Waste
Management Rep.
EPA Region No.
Street
City, State, Zip
(617) 223-5775
(212) 264-0503/4/5
(215) 597-8116
(404) 881-3116
(312) 353-2197
(214) 749-7601
(816) 374-3307
(303) 837-2221
(415)556^1606/7
(206) 442-1260
Air & Hazardous
Materials Division
Address as:
Director
Air & Hazardous
Materials Division
EPA Region No.
Street
City, State, Zip
(617)223-5186
(212)264-2301
(215) 597-8131
(404) 881-3454
(312) 353-2212
(214) 749-1121
(816) 374-3307
(303) 837-3895
(415) 556-0217
(206) 442-1236
Regional
Administrator
Address as:
Regional
Administrator
EPA Region No.
Street
City, State, Zip
(617) 223-7210
(212) 264-2525
(215) 597-9814
(404) 881-4727
(312) 353-2000
(214) 749-1962
(816) 374-5493
(30; , 637-3895
(415) 556-2320
(206) 442-5810

Address
John F. Kennedy Building
Boston, Massachusetts 02203
Federal Office Building
26 Federal Plaza
New York, N. Y. 10007
Curtis Building
6th and Walnut Street
Philadelphia, Pennsylvania 19106
345 Courtland Street, N.
Atlanta, Georgia 30308
230 South Dearborn Street
Chicago, Illinois 60604
1201 Elm Street - First Intl Bldg.
Dallas, Texas 75270
1735 Baltimore Avenue
Kansas City, Missouri 64108
1860 Lincoln Street
Denver, Colorado 80203
100 California Street
San Francisco, California 94111
1200 6th Avenue
Seattle, Washington 98101
-------
102
STATE DECISION MAKERS GUIDE FOR HAZARDOUS WASTE MANAGEMENT
TABLE F-2
EPA OFFICES CONCERNED WITH ENVIRONMENTAL ASPECTS OF HAZARDOUS MATERIALS
OFFICE
PERTINENT RESPONSIBILITIES
Hazardous Waste Management Division
Office of Solid Waste Management Programs
U.S. Environmental Protection Agency
Waterside Mall, Room 2111
401M. Street, S.W.
Washington, D.C. 20460
(202)755-9185
Division of Water and Hazardous Materials
Office of Water Program Operations
U.S. Environmental Protection Agency
Waterside Mall East, Room 1113C
401M. Street, S.W.
Washington, D.C. 20460
(202)426-3971
Pesticides Registration Division
Office of Pesticides Programs
U.S. Environmental Protection Agency
Waterside Mall East, Room E539A
401M. Street, S.W.
Washington, D.C. 20460
(202) 755-8036
Office of Radiation Programs
U.S. Environmental Protection Agency
401 M. Street, S.E., E. Tower, Room 611
Washington, D.C. 20460
(202) 755-4894
Air Pollution Technical Information
Center (APTIC)
Office of Air and Waste Management
U.S. Environmental Protection Agency
Research Triangle Park, North Carolina 27711
(919)688-8146
Office of Toxic Substances
U.S. Environmental Protection Agency
401M. Street, S.W.
Washington, D.C. 20460
The office quantifies hazardous waste generation and defines
applicable treatment and disposal technology, develops
guidelines and standards; directs technical assistance to
Regions, States, organizations and private individuals
on treatment and disposal of hazardous wastes.
The office provides information on the government's role
in the safe handling of hazardous materials. It also estab-
lishes regulations for the prevention, control and clean up
of oil and hazardous material discharges to water.
Areas of interest include pesticide toxicology, pesticide
residue tolerances, pesticide analytical standards, and
pesticide chemical methodology. The office also answers
letters of inquiry about the status of pesticide uses under
the provisions of the Federal Insecticide, Fungicide, and
Rodenticide Act.
The office publishes Radiation Data and Reports (monthly).
Other services are provided to Federal and State agencies,
scientific organizations and industry.
APTIC collects basic data on the chemical, physical and
biological effects of varying air quality, and other informa-
tion on the prevention and control of air pollution.
Citations, abstracts, and extracts from the literature file
are provided. APTIC prepares state-of-the-art reviews and
publishes Air Pollution Abstracts.
Areas of interest include toxic chemicals. The office
collects basic data on such chemicals and also answers
inquiries.
-------
FEDERAL AGENCIES
103
TABLE F-3
SELECTED FEDERAL AGENCIES (OTHER THAN EPA) CONCERNED WITH VARIOUS
ASPECTS OF HAZARDOUS WASTE MANAGEMENT*
AGENCY
Food and Drug Administration
U.S. Department of Health, Education
and Welfare
5401 Westbord Avenue
Bethesda, Maryland 20016
(301)496-7691
Medical Library
Bureau of Drugs, BD-45
Food and Drug Administration
5600 Fishers Lane
Rockville, Maryland 20852
(301)443-3182

U.S. Consumer Product Safety Commissioji
Washington, D.C. 20207
(800) 638-2666 (toll free)
(800) 492-2937 (Maryland residents only)

Office of Hazardous Materials
U.S. Department of Transportation
400 Sixth Street, S.W.
Washington, D.C. 20590
(202) 426-0656

Mail Classification Division
U.S. Postal Service
Washington, D.C. 20260
(202)961-7405
Environmental Mutagen Information Center
Environmental Information System Office
Oak Ridge National Laboratory
P.O. Box X
Oak Ridge, Tennessee 37830
(615)483-8611 Ext. 3-7998
Division of Technical Services
National Institute for Occupational
Safety and Health
U.S. Department of Health, Education,
and Welfare
5600 Fishers Lane
Rockville, Maryland 20852
(302)443-2140
PERTINENT RESPONSIBILITIES
The FDA acts to recall consumer products which have been
determined to be hazardous, and publishes recall reports
on such products. This agency also investigates, sets
standards, and enforces regulations on safety of food, drug,
and cosmetic items. FDA has offices in most major cities.

Areas of interest include adverse effects of drugs, cosmetics,
household chemicals, and feed and food additives; packag-
ing and containers for above items; natural occurrence of
food toxicants; contaminants of foods, drugs, and cosmetics.
The library also has books, periodicals, microfilm, audio
equipment, extensive card indices on toxicants and their
adverse effects. The library also answers inquiries and
provides references.
This agency publishes periodic fact sheets which provide
information on dangerous consumer products (exclusive
of food, drug, and cosmetic items). It answers inquiries
and compiles data on reported product hazards and
product-related injuries.
This office establishes regulations on the transportation of
hazardous materials via public carriers and provides infor-
mation and advice on regulations and procedures for safe
handling, transportation, and clean up of spills of hazard-
ous chemicals. The agency has 14 district offices across
the country.
This office establishes standards for what can be sent
through the mail and how it should be packaged.

Maintains a data base of chemical mutagenesis information.
Evaluates and analyzes data and makes them available to
researchers. Publishes state-of-the-art reviews, critical
reviews, and a newsletter.

The division answers inquiries and provides consulting
services on questions related to industrial safety, medicine,
hygiene, toxicology, working conditions, and sanitation.

•Based in part on the information contained in the following reference which should be consulted for additional listings:
Selected Information Resources on Hazardous Materials, National Referral Center, Science and Technology Division,
Library of Congress, Washington, D.C.
P01510
*U.b. GOVERNMENT PRINTING OFFICE . 1977 0-720-313/400]
-------