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                   Decision-makers Guide

                      for  Hazardous Waste

defining hazardous wastes, problem recognition, land use,
                        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
           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.

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
             INDUSTRIAL WASTE SURVEY ..................   22

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

          WASTE MANAGEMENT ......................    26
          WASTE DISPOSITION HIERARCHY .................   27


                Waste Reduction	   27
                Waste Separation and Concentration	   27
                Waste Exchange	   28
                Secure Land Disposal	   28
                Energy/Material Recovery	   28
                Incineration/Treatment	     ...   29

5.   Control of Hazardous Waste Transportation	   32

          SOURCES	  36

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

             DISPOSAL	   37
             DISPOSAL   	   37
                Federal Agency Policies	   39
                Other Issues Concerning Public Land Use	      .  .   40

7.   Facility Operations	   142

          SITE SELECTION	   44
                Geological  	   44
                Hydrogeologic	   44
                Topographical	   46
                Climatic  	   46
                Ecological	   47
                Cultural	   47
                Public Acceptance	   47



           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

                Solid Waste Evaluation Leachate Test	   56
                Summary	   57
                Metallic Species   	   59

9.    State Programs for Hazardous Waste Management	  62

           INTRODUCTION	   62
             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

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

      1.    SHORT TITLE	   66



            OF PURPOSE	  66
     3.    DEFINITIONS	  67
     5.    PERMITS	  70
            FACILITIES AND SITES	  73
    10.    IMMINENT HAZARD	  80
    11.    ENFORCEMENT	  81
    13.    REPEALER	  82
    14.    SEVERABILITY	  83
    15.    EFFECTIVE DATE	  83

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

       INCINERATORS	  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
    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).
    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
   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
   • 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

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
   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
   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

   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
  One method by which the degree of flammability

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
   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-
   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

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
   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-
   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,

                                                TABLE 1
                                          FLASH-POINT TESTERS

Pensky -Martens (Fischer)
Pensky -Martens (Fischer)
Tagliague (Fischer)
Tagliague (Fischer)
Cleveland (Fischer)
Cleveland (Sargent)
Cleveland (Sargent)
Pensky -Martens (Fischer)
Pensky -Martens (Fischer)


Type of Temp.
 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-
   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
   Also  tests  which measure  the ignition  or flame

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 ..."
   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
    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

 for  wastes  which  are  to  be  stored for  stipulated
 periods of time.

   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
   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
   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
   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.
   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.
  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.

                                 PROBLEM RECOGNITION AND DEFINITION
   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
Disposal Method
Other Land
                                                                                  of Wastes
S meltings,
Slag, Mine
Number of Cases

Damage Mechanism
 (number of cases)
Surface Water
Fires, Explosions
Direct Contact Poisoning
Wells Affected0^
a) The tabulation is based on 421 cases





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
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.

                                                 TABLE 3
                                           BY DISPOSAL METHOD
Disposal Method
Inorgamc Acids
Misc. Inorganics
Misc. Organics
Unspecified Leachate



Other Land

Slag, Mine











  *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.

   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
   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
                     TABLE 5

Industry Category
1. Batteries
2. Inorganic chemicals
3. Organic chemicals, pesticides,
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


Dry Basis    Wet Basis


Inorganic chemicals
Organic chemicals, pesticides,
Petroleum refining
Primary metals
Leather tanning and finishing
Textile dyeing and finishing
Rubber and plastics
Special machinery
Electronic components
Waste oil re-refining

0.062 '

   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

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
EPA Region
Dry Basis
Wet Basis
(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
   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

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)




Metric Tons/Yr.)








% Growth*
'74 - '83


46 *
 *Figures based on dry weight quantities.

                                 PROBLEM RECOGNITION AND DEFINITION
              (106 METRIC TONS DRY WEIGHT)
                 [     | TOTAL WASTES









  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
              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

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.
   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
           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
Group I
                           No. Visits
Group II
                                        No. Plants
Inorganic chemicals
Petroleum refining
Organic chemicals, pesticides,
Primary metals


Special machinery
Rubber & plastics
Electronic components
Waste oil re -refining

   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
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-
   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

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
   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
   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.

 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
 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,
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.
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 _
     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
Maximum hourly
Waste stream
(weight basis)
Process products

       Attach flow diagrams of each process showing product and waste streams, if available.

C.   Storage methodology (applicable to generators, treatment and disposal facilities, and collectors and haulers).
Process wastes
Type of storage
Frequency of transfer
to the storage area
Frequency of transfer
from the storage
Methods of transfer
to and from
Safety procedures
Emergency plans

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

E.   Treatment methodology (applicable to generator and treatment facilities).
Wastes treated
Composition of
wastes treated
Treatment methods
Equipment used to
treat wastes

       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
Type of disposal
Liner type
Leach ate
Depth of facility
Distance to ground
Site security
Burial methods
Types of leachate


        Describe methods used to identify and mark the location of hazardous wastes.

F.   Disposal methodology (continued)

Type of incinerator
Rated capacity
Auxiliary fuel used
Design specifications
Air pollution
Air pollution permits
Residue disposal
Waste storage prior
to incineration

 F.   Disposal methodology (continued)

     Other disposal methods
Ocean dumping
Well injection

                                        Chapter  4
                   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.
   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-
  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

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
   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
   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

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
                                     be carefully considered and integrated into the plan-
                                     ning for any system using industrial wastes for fuel.
                                       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

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-
   •  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
   •  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
   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  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-

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.
   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-
   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-


   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
   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
   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.

   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.

   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.
   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
   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.

   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.
   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
   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

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
   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

   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

 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.
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

                  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.
   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-
   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.

                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

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
   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
   •  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
                              -  —  —       - -   *
   •  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-

      quality standards,  such  as natural background
      levels (where in excess of drinking water stand-
   •  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
   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.

             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-
   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-
   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

 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
    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
      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
    • 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

 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
   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
   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

                                          FACILITY OPERATIONS
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.)

Percent of Total
   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

  EPA   Chemical            Secure  Deep Well Resource
Region Treatment Incineration Landfill Injection Recovery
50 75
50 75


      *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

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
   A  naturally secure disposal  site would be any site
whose set of environmental conditions satisfied the
parameters of the  "tree" with  no site modifications
   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.

   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

   ETC. . .
                                                            HAVE/CAN MODIFICATIONS
                                                            BEEN/BE MADE TO CORRECT
                                    NEXT DECISION   YES
                              -^~ NOT ACCEPTABLE-REJECT
                                     Figure 4.  Decision Tree

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.
   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
   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
   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-
       Processes, procedures, and methods to control pol-
lution resulting from all construction activity (EPA 430/9-73-
       Comparative  costs or erosion and sediment control
construction activities (EPA 430/9-73-016).

                                          FACILITY OPERATIONS
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.
   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 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
   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.

   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
                                       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
       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-
   With the above inclusions, an example of a compat-
ibility matrix is  depicted in Figures 5 and 6.* If it is








2, 4D
              Figure 5











               Figure 6

 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 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
                                                       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-
                                        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
   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
               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
   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

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.

   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
   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
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.
   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
                  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.
   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
   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.

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
   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-
   •  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
   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

   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
  •  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
   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

 Materials (ASTM) and American Petroleum Institute
   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.

   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
   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-
   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

                                                 TABLE 11
                                 COVERED BY DRINKING WATER STANDARDS


Yes (A)
Yes (A, B)
Yes (A, B)
Yes (A, B)
Yes (A, B)
Yes (A, B)
Yes (A)
Yes (A, B)
Yes (A, B)
Yes (A, B)
Yes (A, B)

Yes (A, B)
Yes (A, B)
Yes (A, B)
Yes (A, B, C)
Yes (B)
Yes (A, C)
Yes (A, B)
Yes (A, B)

Yes (B)
Yes (C)

Polar -

Yes (B)
Yes (B)
Analysis ;
Yes (A, B)


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

and  each of  these  types  has  advantages  and dis-
   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

Advantages Disadvantages
- Least expensive - Not recommended
for As or Se.

- Best documented - Small percentage
of atomic vapor

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

- Better than
flame for
when matrix is
- Better able to
dissociate metal
oxides than flame.

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

- Technically
not as well
documented as

- 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
- 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-

- 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




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.


 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,
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.

   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

      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.
   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-
           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

 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
    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.
   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-
   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
   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
   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
                      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

                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.
                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
                   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;

     (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.
                    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
                    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

      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
 (F)   The term, Manifest, means the form used for iden-
      tifying the quantity, composition, origin, routing,
      and destination of hazardous waste during its
 (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.
                    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
                   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.

          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
     (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

      (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
 (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.
                    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.
                    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

(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-
(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

                                                       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
                                                       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

                    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.
                     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

              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
          (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
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-
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

                    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.
                    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

                                                           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

                                                           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.


                                        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

                                                                  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-
                                                                  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

                    Section 8
(A)  The Department shall adopt, and revise as appro-
     priate, rules which prescribe:
     (1)   the establishment and maintenance of such
     (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
                    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

(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.
                    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
              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
                    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.

     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.

                   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."
                    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.

     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-
 (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.
                     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.
                    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
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.
                    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
   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?

   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

                                             TABLE B-l
                                 FOUND IN SMALL BATCHES OF WASTE
        Pickling Liquor
        Battery Acid
        Acidic Chemical Cleaners
        Spent Acid
        Plating Operations
        Laboratory Glassware Acid Baths
        Glass Etching Solutions

        Miscellaneous Caustic Products
        Alkaline Battery Fluid
        Caustic Wastewater
        Cleaning Solutions

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

        Cleaning Solvents
        Laboratory Chemicals
        Paint and Varnish Removers
        Dry Cleaning Solutions
        Capacitors and Transformers
          Containing PCB

        Chemical Toilet Wastes
        Laboratory Chemical Wastes
        Paint Sludge
        Plating Solutions
        Fluorescent Lamps
        Germicidal and "Disinfectant"
        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


                                               TABLE B-l

                              FOUND IN SMALL BATCHES OF WASTE (CONTINUED)
           Illegal Explosive "Firecrackers"
           Laboratory Wastes
           Obsolete Explosives
           Track Torpedoes
           Blasting Caps
           Commercial Pyrotechnics for Private Use
           Waste Pesticides
           House  and Garden Discarded Pesticide Cans
           Waste Water from Cleaning of Pesticide
           Containers and Pesticide Application
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
           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
Aerosol products containing vinyl chloride as propellant,
aldrin products, lead-based paints containing 0.5 percent
lead or greater

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.
   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
   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.
   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.
   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

   •  Recycling or returning to supplier
   •  Transporting to a hazardous waste management
   •  Using available laboratory equipment for treat-
   •  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)

   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
   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

                                                 TABLE B-2
                                  AND COMMERCIAL/INDUSTRIAL PRODUCTS
        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
        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
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
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

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

                               OF SMALL BATCHES OF HAZARDOUS WASTES
  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

  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.

   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.
   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."
   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.

   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
                        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

      Proposed Regulations for Prohibition of Certain
      Acts Regarding Disposal and Storage  of Pesti-
      cides and Pesticide Containers, 39 FR 36867,
      October 15,  1974

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
                                        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
                                        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:

           Disposal Procedures

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"...



                   |FRL 514-41

        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
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
  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
  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
  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;
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
  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
  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


           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
         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
           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


                     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-

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.
  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.
  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-
(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
  21.  Mitre Corp. Environmental cycling ol
PCB's. 1975 (unpublished draft report).
   |FR Doc.76-9420 Filed 3-31-76:8:45 am|
                                           FEDERAL  REGISTER, VOL. 41,  NO. 64—THURSDAY, APRIL  I, 1976


             Appendix E
          WEDNESDAY, JUNE 9, 1976
           Recommended Procedures
           for Disposal of Aerosol Can

                                                     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
                                            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-
  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
 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
   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
   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-
  A pollution control system  will be re-
 quired to  remove potential  air con-
 taminants. Most of tbew  aerocols con-
 tain ddanOuorocarboD propeUanto as

         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
   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-

 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
   (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
   (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
   (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
   (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
   (12) One foot of final cover Is compacted;
   (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

  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-
   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.


ISLANDS .—..-'
u •
                 Figure F-l.  United States Environmental Protection Agency, regional offices.

                 FEDERAL AGENCIES
                    TABLE F-l

SWM Representative
Address as:
Solid Waste
Management Rep.
EPA Region No.
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
(206) 442-1260
Air & Hazardous
Materials Division
Address as:
Air & Hazardous
Materials Division
EPA Region No.
City, State, Zip
(215) 597-8131
(404) 881-3454
(312) 353-2212
(214) 749-1121
(816) 374-3307
(303) 837-3895
(415) 556-0217
(206) 442-1236
Address as:
EPA Region No.
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

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

                                              TABLE F-2
   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
   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
   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
    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

                                         FEDERAL AGENCIES
                                             TABLE F-3
Food and Drug Administration
U.S. Department of Health, Education
and Welfare
5401 Westbord Avenue
Bethesda, Maryland 20016
Medical Library
Bureau of Drugs, BD-45
Food and Drug Administration
5600 Fishers Lane
Rockville, Maryland 20852

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
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
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.
                                                             *U.b. GOVERNMENT PRINTING OFFICE . 1977 0-720-313/400]