Office of Water &
Waste Management SW-826
Washington DC 20460 1980
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series
Waste Alert! A Citizen's Introduction to Public
Participation in Waste Management (SW-800)
What Is Waste Alert? (SW-814)
Operating a Recycling Program: A Citizen's Guide
(SW-830)
Source Separation/Waste Reduction (SW-832)
Cleaning Up America's Dumps: State Solid Waste
Management Plans Under RCRA (SW-831)
Public Participation Requirements for Federal, State,
and Local Agencies (SW-833)
Solid Waste Management Programs under RCRA
(SW-834)
Hazardous Waste Facts (SW-737)
This booklet was published by the Technical Information
and Communications Branch of EPA's Office of Solid
Waste. The work was prepared by Angela Wilkes
(project officer), Irene Kiefer, and Barbara Levine.
Photographs were contributed by: Janet DeBiasio, Steve
Caldwell, Richard Carnes, Lois Gibbs, Jon Johnston,
Rowena Michaels, Daniel Moon, Donald Oberacker,
Henry Owen, Marie Pozniak, Scott Ritchie, Jane Russo,
James Truchan, and Bruce Wilson.
COVER: Cleanup operations underway at 'Valley of the
Drums,' an uncontrolled hazardous waste disposal site in
Kentucky. The drums strewn about the site are being
stacked in rows. Trenches were dug to catch rainwater
runoff and any leaking chemical waste and to divert the
liquid to settling ponds and a temporary treatment system.
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everybody's problem:
hazardous waste
Every year, billions of tons of solid wastes are
discarded in the United States. These wastes range in
nature from common household trash to complex
materials in industrial wastes, sewage sludge, agricul-
tural residues, mining refuse, and pathological wastes
from institutions such as hospitals and laboratories.
The U.S. Environmental Protection Agency (EPA)
estimates that in 1980 at least 57 million metric tons of
the nation's total wasteload can be classified as hazard-
ous. Unfortunately, many dangerous materials that
society has "thrown away" over recent decades have
endured in the environment making household
words of 'Love Canal' and 'Valley of the Drums.' These
two incidents are not unique. EPA has on file hundreds
of documented cases of damage to life and the
environment resulting from the indiscriminate or im-
proper management of hazardous wastes. The vast
majority of cases involve pollution of ground water
the source of drinking water for about half of the U.S.
population from improperly sited or operated land-
fills and surface impoundments (pits, ponds, and la-
goons). In addition to polluting ground water, the
improper handling or disposal of hazardous waste can
cause several other kinds of environmental damage, as
illustrated by these case histories (often involving more
than one form of damage) from EPA records.
Hazardous waste can pollute ground water:
The water supplies of Toone and Teague, Tennessee,
were contaminated in 1978 with organic compounds
What appears to be a
pleasant rural landscape
actually hides ground
water contaminated by
a nearby industrial
landfill. The ground
water was the source of
water for the towns of
Toone and Teague,
Tennessee.
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A young man was
asphyxiated as he
discharged hazardous
waste from his truck
into this open pit in
Iberville Parish,
Louisiana.
when water leached from a nearby landfill. When
the landfill closed, about 6 years earlier, the site held
some 350,000 drums, many of them leaking pesticide
wastes. Because the towns no longer have access to
uncontaminated ground water, they must pump
water in from other locations.
Ground water in a 30-square-mile area near Denver
was contaminated from disposal of pesticide waste in
unlined disposal ponds. The waste, from manufactur-
ing activities of the U.S. Army and a chemical
company, dates back to the 1943-to-1957 period.
Decontamination, if possible, could take several years
and cost as much as $80 million.
Hazardous waste can contaminate rivers, lakes,
and other surface water:
At least 1,500 drums containing waste, primarily from
metal-finishing operations, were buried near Byron,
Illinois, for an unknown number of years until about
1972. Surface waters (and soil and ground water as
well) were contaminated with cyanides, heavy met-
als, phenols, and miscellaneous other materials.
Wildlife, stream life, and local vegetation were
destroyed. The disposal site suffered long-range
damage from the toxic pollutants that drained into
the soil.
About 17,000 drums littered a 7-acre site in Kentucky
which became known as 'Valley of the Drums'-
about 25 miles south of Louisville. Some 6,000 drums
were full, many of them oozing their toxic contents
onto the ground. In addition, an undetermined
quantity of hazardous waste was buried in drums
and subsurface pits. In 1979, EPA analyses of soil and
surface water in the drainage area identified about
200 organic chemicals and 30 metals.
Hazardous waste can pollute the air:
In 1972, waste containing hexachlorobenzene (HCB),
one of the family of toxic organic compounds that
contains chlorine, was disposed of in a landfill near
Darrow and Geismar, Louisiana. The HCB vaporized
and subsequently accumulated in cattle over a 100-
square-mile area. The cattle had to be destroyed,
representing a direct economic loss of over $380,000.
Elevated, although subtoxic, levels of HCB in blood
plasma were found in some area residents.
When industrial wastes ignite, they not only present the
immediate dangers of heat and smoke but can also spread
harmful particles over wide areas.
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SB
Hazardous waste was stored in large tanks
and drums at this disposal site in Chester,
Pennsylvania. Waste had also been
dumped directly on the ground, forcing
EPA personnel inspecting the site to wear
protective clothing and carry air tanks as
precautionary measures.
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A truck driver was killed in 1978 as he discharged
waste from his truck into one of four open pits at a
disposal site in Iberville Parish, Louisiana. He was
asphyxiated by hydrogen sulfide produced when
liquid wastes mixed in the open pit. The area was
surrounded by water and had a history of flooding.
Hazardous waste can burn or explode:
A fire broke out in 1978 at a disposal site in Chester,
Pennsylvania, where 30,000 to 50,000 drums of
industrial waste had been received over a 3-year
period. The smoke forced closing of the Commodore
Barry Bridge and 45 firemen required medical
treatment, mostly as a result of lung and skin
irritation from chemical fumes. A number of homes
are located within three blocks of the site; drummed
waste was kept only 20 feet from a natural gas
storage tank and liquefied natural gas tanks were
about 100 yards away. Waste was emptied directly on
the soil of the 3-acre site; some probably drained to
the tidal section of the adjacent Delaware River.
Waste may even have been dumped into the river.
A bulldozer operator was killed in a 1975 explosion at
a landfill in Edison Township, New Jersey, as he was
burying and compacting drums of unidentified
chemical waste. Of the 200 truckloads of waste the
landfill received daily, about 50 were industrial waste.
Hazardous waste can poison via the food chain:
In 1970, three children in an Albuquerque, New
Mexico, family became seriously ill after eating a pig
that had been fed corn treated with a mercury
An explosion at this
New Jersey landfill
killed a bulldozer
operator as he buried
and compacted drums
of unidentified
hazardous wastes.
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Boarded-up houses offer
mute testimony of the
environmental disaster
at Love Canal in Niagara
Falls, New York.
compound. Local health officials found several bags
of similarly treated corn in the community dump.
Over a 4-month period in 1976, an Indiana family
consumed milk contaminated with twice the
maximum concentration of polychlorinated biphenyls
(PCBs) considered safe by the Food and Drug
Administration. The milk came from the family's cow,
which had been grazing in a pasture fertilized with
the City of Bloomington's sewage sludge. The sludge
contained high levels of PCBs from a local
manufacturing plant. A Federal law passed in 1976
banned production of PCBs after January 1, 1979.
Hazardous waste can poison by direct contact:
The health of some residents of Love Canal, near
Niagara Falls, was seriously damaged by chemical
waste buried a quarter of a century ago. As drums
holding the waste corroded, their contents
percolated through the soil into yards and
basements, forcing evacuation of over 200 families in
1978 and 1979. About 80 chemicals, a number of
them suspected carcinogens, were identified.
In 1979, cattle on a Kansas farm were contaminated
with PCBs after waste oil was used in animal
backrubbers. The waste oil (from electrical transform-
ers) had been purchased from a salvage yard in
After being contaminated with PCBs, many cattle on a farm in
Kansas had to be destroyed and buried in this EPA-approved site.
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Hazardous waste was illegally disposed of into this buried tank by a "midnight dumper,"
who was observed entering the property by an eyewitness. Notified of the dumping,
the Michigan Department of Natural Resources had to dig up the property to locate the
tank, which was leaking and contaminating the soil and ground water.
1972, before the effects of PCBs were widely known.
Products from 54 head of cattle had been shipped to
a number of States and had to be traced and
disposed of properly; another 112 head had to be
destroyed. The farm and a feedlot where the cattle
had been shipped were also contaminated.
These examples provide dramatic evidence of damage
to life and the environment from mismanagement of
hazardous waste. It was in large part to prevent such
tragedies that, in 1976, Congress enacted Subtitle C of
the Resource Conservation and Recovery Act (RCRA),
Public Law 94-580. This law imposes strict controls over
the management of hazardous waste throughout its
entire life cycle. The costs for proper environmental
controls will be higher than amounts spent in the past
to manage these wastes. But the astronomical costs of
cleaning up damage caused by poor disposal practices
should be eliminated. An ounce of prevention, in this
instance, is a sound investment.
An EPA study made in 1979 indicated that cleaning
up abandoned hazardous waste sites and those operat-
ing under environmentally unsound conditions could
cost as much as $44 billion, only part of which is likely
to be paid for by the owners of the sites. The remainder
would have to come from other sources. But in many
cases it is impossible to assign dollar values to the
long-term harm to health and the environment that has
resulted from improper management of hazardous
waste.
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The National Program To Control
Hazardous Waste
In a report to Congress in 1973, EPA recommended
passage of a Federal law to regulate the handling of
hazardous waste. EPA reported that although existing
Federal legislation was adequate to protect the air,
surface waters, and oceans from improper disposal of
hazardous waste, there were no national controls over
its disposal on land. Moreover, the air and water
pollution laws requiring industry to adopt environmen-
tally acceptable treatment and disposal practices had
increased the amounts of hazardous waste being
dumped on the land, a relatively unregulated outlet for
disposal. Thus, a law was needed to close the circle of
Federal environmental protection by providing, for the
first time, control over disposal of hazardous waste on
land.
Congress responded by including hazardous waste
provisions in RCRAthe law that established a national
program to protect human health and the environment
from improper handling of solid waste and to encour-
age conservation of natural resources. Directed by RCRA
to take the lead in developing strict controls, EPA began
a three-pronged effort to attack the nation's hazardous
waste problem.
The first phase, the regulatory program under RCRA,
is intended to help States prevent any Love Canals in
the future. Central to this program is a national
"cradle-to-grave" control system to track all significant
If it is managed on-site...
Disposal
Treatment Nonhazardous
Waste
A Hazardous Waste Will Be Tracked From "Cradle-to-Grave"
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quantities of hazardous waste from wherever it is
generated to its final disposal. The regulatory program
includes:
identification of hazardous waste
standards for generators and transporters of
hazardous waste
performance, design, and operating requirements for
facilities that treat, store, or dispose of hazardous
waste
a system for issuing permits to such facilities
guidelines describing conditions under which State
governments can be authorized to carry out their
own hazardous waste management programs
Along with its authority under RCRA, EPA is using
regulatory authorities under several other Acts it
administers. These include the Clean Water Act, the
Safe Drinking Water Act, the Toxic Substances Control
Act, and the Refuse Act. Under certain provisions of
these Acts, EPA has been able to:
fund the development of programs for management
and enforcement of hazardous waste activities by
State and local governments
fund cleanup of disposal sites
approve landfills and incinerators for PCB disposal
and treatment
provide technical assistance to State and local officials
to help them analyze and remedy existing or
potential problems caused by improper hazardous
waste management
The second phase of the national hazardous waste
management effort consists of EPA investigations to
identify dangerous abandoned or uncontrolled dump
sites, which the Agency estimated in 1979 to number as
many as 2,000. Under RCRA, EPA can force the owner to
clean up a hazardous waste disposal site if it causes an
"imminent and substantial" danger to human health
and the environment. EPA has stepped up its efforts
under this provision to discover, investigate, and clean
up abandoned disposal areas.
Unfortunately, the owners of dangerous sites often
cannot be found. Even when they are found, they may
not have the finances necessary for cleanup, or they
may deny any legal liability for damages attributed to
the site. Thus innocent victims must resort to long and
costly legal proceedings under State laws, and
government agencies are faced with cleanup expenses.
The third phase of the attack on hazardous waste is a
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1979 legislative proposal, termed the "superfund,"
developed by EPA and others to rectify the limitations
of the imminent hazard provision. The main purpose is
to provide funds that will permit Federal and State
governments to move quickly and effectively to deal
with the consequences of uncontrolled and abandoned
disposal sites, as well as spills of oil and hazardous
substances.
The Public Role
Of special importance in RCRA is a provision stating
that "public participation in the development, revision,
implementation, and enforcement of any regulation,
guideline, information, or program under this Act shall
be provided for, encouraged, and assisted" by EPA and
the States. This booklet is an example of the kind of
information EPA makes available to the public. It is
intended to help build an understanding of the
hazardous waste problem and thus promote effective
public participation in the development of Federal and
State programs for bringing the problem under control.
Abandoned or
uncontrolled sites
where wastes have
been dumped
indiscriminately have
been termed "ticking
time bombs." The search
for abandoned sites will
be a continuing process.
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a hazardous waste is *..
RCRA defines a hazardous waste as a solid waste that
may cause or significantly contribute to serious illness or
death, or that poses a substantial threat to human
health or the environment when improperly managed.
Hazardous wastes are among the leavings of a highly
technological society and come from many segments of
that society industry, hospitals, research laboratories,
and all levels of government. Industry is by far the
largest source, generating these wastes to manufacture
cars, fuel, paper, plastics, clothing, rubber, paint, pes-
ticides, medicines, and a host of other products that
Americans need or expect in their day-to-day lives.
Working from the RCRA definition, EPA has compiled
and proposed a list of hazardous wastes. Listing is the
most common method for defining hazardous waste in
European countries and in some State laws. EPA has
also proposed that a hazardous waste be identified by
testing it to determine if it possesses any one of four
characteristics. If it does, it will be subject to regulation
under RCRA. Three of the characteristics selected by EPA
produce acute effects likely to cause almost immediate
damage; the fourth creates chronic effects most likely
to appear over a longer time period. The four charac-
teristics are:
Ignitability, which identifies wastes that pose a fire
hazard during routine management. Fires not only
present immediate dangers of heat and smoke but
also can spread harmful particles over wide areas.
Corrosivity, which identifies wastes requiring special
containers because of their ability to corrode stand-
ard materials, or requiring segregation from other
Materials that corrode
and escape from their
containers pose a threat
to health and the
environment.
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The products
we use.
Plastics-
Pesticides
Medicines-
Oil, gasoline, and
other petroleum products
Metals
Leather-
Textiles
The potentially hazardous
waste they generate...
- Organic chlorine compounds
-Organic chlorine compounds, organic
phosphate compounds
- Organic solvents and residues, heavy
metals (mercury and zinc, for example)
-Heavy metals, pigments, solvents,
organic residues
Oil, phenols and other organic
compounds, heavy metals, ammonia
salts, acids, caustics
Heavy metals, fluorides, cyanides, acid
and alkaline cleaners, solvents,
pigments, abrasives, plating salts, oils,
phenols
Heavy metals, organic solvents
Heavy metals, dyes, organic chlorine
compounds, solvents
wastes because of their ability to dissolve toxic
contaminants.
Reactivity (or explosiveness), which identifies wastes
that, during routine management, tend to react
spontaneously, to react vigorously with air or water,
to be unstable to shock or heat, to generate toxic
gases, or to explode.
Toxicity, which identifies wastes that, when impro-
perly managed, may release toxicants in sufficient
quantities to pose a substantial hazard to human
health or the environment.
Several of the methods used to test for the charac-
teristics are identical to those used by the U.S. Depart-
ment of Transportation in its program to control trans-
port of hazardous materials.
EPA may add to or delete from the list of hazardous
wastes or characteristics identifying a hazardous waste.
Any changes will be published in the Federal Register,
and the public will be given an opportunity to com-
ment on proposed changes.
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Some Facts About Hazardous Waste
Understanding problems related to managing hazardous waste requires much detailed information.
including the kinds and quantities of waste generated, where they are generated, how they are
managed, and costs of managing them properly Accurate information of such a broad scope is
difficult to obtain. Inaccuracies result from inconsistencies in data sources, overgeneralizations, and
variations in actual wastes generated within industrial groups, however, the figures presented here
The chemicals and allied products industry generates 60 percent
of industrial hazardous waste:
All others
Stone, day. and glass products
Fabricated metal products
Paper and allied products
Primary metals
Machinery (except electrical)
Chemicals and allied products
% of Total Hazardous Waste
in the United States
Source EPA, Draft Environmental
Impact Statement, 7979
Geographically, hazardous waste tends to be concentrated in certain
regions. About 60 percent is generated in 10 States: New Jersey, Illinois,
Ohio, California, Pennsylvania, Texas, New York, Michigan, Tennessee,
and Indiana.
3-8% Fvtj 0.5-2%
2-3% I I below 0.5%
% of Total Hazardous Waste
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Source EPA, Draft Environmental Impact Statement, '979
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were the best available when this book/ei was published. As new and improved data are collected,
EPAs figures will be revised and made available to the public, meanwhile, these data provide a
realistic basis for understanding the hazardous waste problem in the United States
Generation of hazardous waste by U S manufacturing industries in 1980 is estimated at 57
million metric tons (wet} - over half of this is from the chemical industry, a broad industrial category
that produces such common materials as plastics, synthetic fibers, synthetic rubber, fertilizers,
medicines, detergents, soaps, cosmetics, paints, pigments, adhesives, pesticides, and explosives, as
well as numerous other organic and inorganic chemicals used by various industries
Most hazardous waste is disposed of by environmentally unsound
methods:
% of Total Hazardous Waste in the United States
- 90% unsound
10% sound
Source: EPA Industry Studies, J 975-1978.
Environmentally sound technologies are available for treatment and
disposal of hazardous waste. Costs vary widely, according to type and
volume of waste handled, and are substantially in excess of unsound
practices:
Land-
spreading
Secure Incineration Physical,
chemical (land-based) chemical, or
landfill
Technology
biological
treatment
Source: EPA, Draft Economic Impact Analysis, 1979.
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good management:
there are better ways
The Love Canal tragedy, contamination of ground
water in Toone, the dumping of PCBs along North
Carolina's roads, the thousands of drums piled high in
Kentucky's 'Valley of the Drums,' and similar incidents
served to focus attention on what can happen when
hazardous waste is improperly managed. Although
technologies exist for environmentally sound man-
agement, they have not been widely used because of
their higher costs and because there was no legal
requirement for their use.
Proper management means more than just careful
disposal. It means consideration of a range of options
that depend upon such factors as characteristics,
volume, and location of the waste. In order of priority,
the desired options for managing hazardous waste
are:
minimize the amounts generated by modifying the
industrial process involved
transfer the waste to another industry that can use
jt
reprocess the waste to recover energy or materials
I
Incineration can be carried out in a manner
that will protect the environment...
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separate hazardous from nonhazardous waste at the
source and concentrate it, which reduces handling,
transportation, and disposal costs
incinerate the waste, or subject it to treatment that
makes it nonhazardous
dispose of the waste in a secure landfill (one that is
located, designed, operated, and monitored even
after it is closed in a manner that protects life and
the environment)
Transferring a hazardous waste to another industry is
an option that is receiving increasing attention. Operat-
ing on the principle that one company's waste may be
another's raw material, this option can take two forms:
the materials exchange, which is equipped to handle,
treat, and physically exchange wastes and the informa-
tion exchange, which acts only as a clearinghouse,
leaving generator and potential purchasers to negotiate
directly.
The first information exchange started in The Nether-
lands in 1972. Since then, the idea has spread quickly in
Europe and is beginning to spread in the United States.
At least 20 information exchanges and 3 materials
exchanges are now in operation in the United States.
The first information exchange in the United States was
established in 1975 by the St. Louis Regional Commerce
and Growth Association. Typically, information ex-
... or it can be carried out carelessly without adequate
environmental safeguards.
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changes are run by chambers of commerce or other
nonprofit groups. In contrast, materials exchanges are
usually operated by profit-oriented private concerns.
Probably only a small percentage of hazardous waste
is suitable for exchange. Purer, less-contaminated wastes
stand the best chance of being exchanged. Also, waste
is more likely to be exchanged where the purchaser is in
the same or a nearby locality, which minimizes transpor-
tation costs. The waste exchange, though not a
panacea, makes a valuable contribution by reducing the
amounts of material to be managed by less desirable
options.
Related to the exchange option is the recovery of
energy or materials. With shortages of raw materials
and tighter restrictions on disposal of wastes, recovery
will become a more viable alternative. Many wastes
contain valuable basic ingredients. And the extraction
of materials from concentrated wastes requires less
energy and generates less water and air pollution
than the mining and processing of virgin materials.
Consequently, when energy or materials are recovered
from hazardous waste, natural resources are conserved
and the environment is protected.
Incineration is a proven method of destroying organic
waste without posing a threat to the environment. EPA
has conducted a number of research and field-scale
projects on incineration methods for chemical wastes.
Two successful projects carried out in 1979 involved
several types of commercial incinerators and 20 differ-
ent chemical wastes, including 9 pesticides. These
wastes were almost totally detoxified or destroyed. The
successful use of cement kilns to destroy chlorine- or
bromine-containing organic wastewhich is very toxic
because it resists degradation and accumulates in living
tissues is one of the more important results of EPA's
demonstration project. The chlorine or bromine in the
waste reduces the alkalinity of the residue left after
combustion, simplifying disposal. The heat value of the
In EPA studies, this
industrial incinerator
was successful in almost
totally destroying DDT;
it has also been able to
destroy transformer oils
containing PCBs.
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waste also replaces some of the fuel needed to
manufacture cement.
Another promising approach to disposing of chlorine-
or bromine-containing organic waste is to burn it at sea
aboard special incinerator ships. This technique,
pioneered in Europe, has been used on several
occasions by the United States, including the disposal of
the Air Force's surplus stock of Herbicide Orange, the
defoliant used in Vietnam. The incineration was aboard
a Dutch vessel, the Vulcanus. The possibility of building
American incinerator vessels is being considered.
Three kinds of processes can be used to render a
hazardous waste less hazardous or nonhazardous:
physical processes, such as carbon or resin
adsorption, distillation, centrifuging, flocculation,
sedimentation, reverse osmosis, and ultrafiltration
chemical processes, such as fixation into solids that
are more readily disposed of, neutralization, ion
exchange to remove heavy metals, oxidation, and
precipitation
biological processes, such as activated sludge
treatment to destroy organic compounds,
composting of organic-rich wastes, trickling filters to
promote decomposition, and controlled application
on land ("landfarming") to degrade organic
compounds
These various options can reduce the amounts of
hazardous waste that must be disposed of directly on
land, a crucial contern because the land available for
disposal is decreasing, while waste tonnages are
increasing. The hazardous waste management industry,
major waste-generating industries, and EPA are
devoting increased attention to development of new,
improved, and less expensive treatment technologies.
But even with new technology, some hazardous waste
will always be destined for land disposal.
A Dutch vessel, the
Vulcanus, can incinerate
hazardous organic
wastes at sea. This
disposal method is
controlled in the United
States under the Marine
Protection, Research,
and Sanctuaries Act.
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bad management =
environmental disasters
Sound technologies may be available to manage
hazardous wastes, but EPA studies of 17 industries
between 1975 and 1978 indicate that they are not being
used for 90 percent of the waste generated. The
predominate practice is disposal in unlined impound-
ments (pits, ponds, and lagoons) and landfills. Up to 80
percent of hazardous waste is disposed of on the
generator's property.
The least expensive environmentally sound method of
disposal is a secure landfill; however, only a limited
number of secure landfills are in operation in the
United States. Many commercial incinerators pollute the
air when they burn hazardous waste. Dumping at sea,
an inexpensive alternative for companies holding the
required EPA permits, will be sharply reduced in 1981
when all provisions of the 1972 Marine Protection,
Research, and Sanctuaries Act are in effect. The
cheapest alternative of all is the "midnight dumper."
With only a truck and a total disregard for public safety,
midnight dumpers can take hazardous waste off gen-
erators' hands for relatively modest fees and then
dispose of it in any one of a number of ways flushing
it into sewers and ditches, dumping it in lakes and
rivers, dropping it off ships at sea, burying it in
farmland, concealing it in municipal waste for disposal
in sanitary landfills, and storing or dumping it on open
lots or fields.
The common practice of open storage has led to
some of the most damaging incidents caused by mis-
management of hazardous wastethe 'Valley of the
Drums' and a site in Lowell, Massachusetts, being
flagrant examples. The Lowell site dates back to 1970,
when a private corporation was set up to salvage and
reprocess waste from area industries. In 1977, the
company declared bankruptcy, leaving some 20,000
barrels, many rusted and leaking, containing 1 million
gallons of toxic waste. Some of the barrels were only a
few hundred feet from a stream that flows into the
Concord River, a tributary to the Merrimack. Several
communities get their drinking water from the Mer-
rimack. Another 250,000 to 300,000 gallons were left in
leaking storage tanks. This 5.2-acre site was located only
a few hundred yards from some residences in the Town
of Lowell. With the company bankrupt, the State of
Massachusetts had to appropriate $1.5 million to clean
up the site.
Drums were stored in
the open at this site in
Lowell, Massachusetts.
The company that
operated the site went
bankrupt, leaving the
State of Massachusetts
with the formidable
task of clean up.
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The goal of the new national program to
control hazardous waste is to prevent
environmentally unsound disposal
practices such as those shown here.
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DANGER
ACID
DISPOSAL
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RCRA:
moving toward a
safer environment
Under RCRA regulations,
companies that
generate wastes may
test them to determine
if they are hazardous.
Harm to human health and the environment caused
by past mismanagement of hazardous waste led to
incorporation in RCRA of a "cradle-to-grave" control
system. This system calls for regulation of hazardous
waste from the time it is first generated through
transport to final treatment or disposal. The concept
uses a pathways approach, so-called because the
movement of hazardous waste destined for storage,
treatment, or disposal is constantly monitored and
controlled. This approach is basically different from that
used to regulate air and water pollution, where specific
standards are tailored for each industrial category. The
pathways approach was chosen because hazardous
waste is mobile and can be disposed of at locations far
from where it was generated. In contrast, sources of
industrial air and water pollution are fixed and rela-
tively easy to identify.
The Congress intended that the individual States
develop their own hazardous waste control systems,
subject to EPA approval. To receive approval, the State
program must be equivalent to the national regulatory
program developed by EPA. EPA handles the program
only in States that choose not to implement their own
programs or that fail to get approval.
EPA has developed and proposed a set of six regu-
lations to control all stages of the hazardous waste
management cycle, whether the waste is managed
"on-site" (at the point of generation) or transported to
an "off-site" waste management facility. Promulgation
of all of the hazardous waste regulations in final form
was scheduled for 1980, to take effect 6 months later.
Proposed regulations are always subject to change;
therefore, the following discussion focuses on basic
requirements under the Act.
Generators
Those who generate potentially hazardous waste in
their operations are required to determine if the waste
is hazardous under the RCRA definition. Thus, the
definition of hazardous waste is the cornerstone of the
national regulatory program. Once a waste is identified
as hazardous, RCRA requires that all significant quan-
tities be tracked throughout their life cycle by means of
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Protection of the environment is the primary goal of the
Resource Conservation and Recovery Act. This law provides
for Federal assistance to States to develop and enforce their
own hazardous waste management programs, subject to
EPA approval.
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Transporters of
hazardous waste play a
key role in the
" crad le-to-g rave"
control system of
tracking hazardous
waste from the
generator to the
disposer.
a transport manifest and by stringent recordkeeping
and reporting requirements. In order to identify a
waste as hazardous, the generator refers to a list of
wastes or tests the waste against the characteristics in
the final regulations. Or, the generator may simply
declare the waste is hazardous. Generators disposing of
their waste on-site must be issued a permit but would
not need a manifest because no transportation is
involved. ,
Generators are the key link in the transport control
system. Under the proposed RCRA regulation, they
must:
originate a transport manifest, describing the
amount, composition, origin, routing, and destina-
tion of each shipment
use approved containers and label them properly
select a responsible company to transport the waste
specify the facility to which the waste is to be
delivered and assure that it has a valid permit
confirm that a waste reaches the intended facility
keep records of information in the manifest and
report it to an authorized State or to EPA
notify authorities of international shipments
Transporters
Transporters must deliver hazardous waste shipments
to the facility designated by the generator, keep appro-
priate records, and report any spills enroute. Hazardous
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waste transporters do not need permits in the Federal
system, but some States require transporters to register.
Many of the major problems in the past have been
caused by irresponsible actions of some transporters.
After being paid to take hazardous waste to disposal
facilities, they have instead merely dumped the waste
indiscriminately, without regard for the effects of their
actions. For example, the sewage treatment plant in
Louisville, Kentucky, had to be shut down for several
months in 1977 after a local transporter dumped several
tons of pesticide waste into the sewer system. During
the clean-up, which cost Federal, State, and local
agencies $3 million, raw sewage had to be discharged
directly into the Ohio River. The manifest system is
designed to prevent such practices because generators
can quickly notify authorities if the designated facility
does not receive a shipment.
Some portions of the RCRA regulation on transpor-
ters overlap with provisions of the Hazardous Materials
Transportation Act (HMTA) administered by the U.S.
Department of Transportation (DOT). Regulations issued
under HMTA have been amended to make them more
compatible with the RCRA regulation, thus avoiding
duplication of administrative and enforcement ac-
tivities. Overlapping provisions of the two Acts, covering
labeling, packaging, and placarding of hazardous waste
by generators, are being administered similarly. EPA and
DOT jointly enforce regulations when they share au-
thority. EPA regulations take effect if DOT lacks
authority.
Standards and Permits for Facilities
Owners and operators of facilities that treat, store, or
dispose of hazardous waste must comply with minimum
standards for assuring that the facilities operate safely.
These standards cover containing, testing, and destroy-
ing wastes so that they cannot contaminate ground
water, surface water, or the atmosphere. There are also
standards for safety and emergency measures to be
used if hazardous waste is accidently discharged, for
training of personnel in emergency situations, and for
keeping records and filing reports. Owners and opera-
tors of facilities are also required to demonstrate
financial responsibility for their operations.
The owner of a hazardous waste facility must apply
for a permit within a specified time. Under the RCRA
regulation, the applicant must provide information on
the site and the amounts and types of hazardous waste
to be handled. To receive a permit, an applicant must
meet the standards set for the specific type of facility.
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The permit describes the terms, conditions, and
schedules of compliance, as well as monitoring, rec-
ordkeeping, and reporting requirements.
Many procedures of the permit program under RCRA
are similar to permit requirements under other EPA-
administered laws. The Agency has consolidated these
programs into one set of regulations. EPA's objective is
to move in the direction of processing an applicant's
hazardous waste permit simultaneously with any other
required permits. EPA's consolidated permit program
includes:
the hazardous waste management program under
RCRA
the underground injection control program under
the Safe Drinking Water Act
the national pollutant discharge elimination system
under the Clean Water Act
the dredge or fill program under the Clean Water Act
the program for prevention of significant deteriora-
tion of air quality under the Clean Air Act
State Hazardous Waste Programs
States must be authorized by EPA to conduct their
own hazardous waste management programs. In order
to receive authorization, the State program must be
equivalent to the national program. Among other
things, the State must have legislation and regulations
that are no less stringent than the Federal standards,
and the State must show that it has the resources to
administer and enforce the program. If a State's pro-
gram does not fully comply with EPA requirements, EPA
may grant the State interim authorization for 2 years,
during which time the program should be further
developed to meet all authorization requirements.
i
State and local governments have important responsibilities in
handling environmental emergencies. Denver's fire department
includes a hazardous materials response team and stages mock
drills (bottom photo) to improve its emergency operations.
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DEPARTMENT
HAZARDOUS MATERIAL
RESPONSE TtAM
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key problem areas
As EPA continues to develop the national program
for hazardous waste management, key issues are
surfacing. One is the very scope of the program. Some
700,000 generators, transporters, treaters, storers, and
disposers of hazardous waste must notify EPA of their
activities and, thus, be brought into the program.
Contacting these individuals and informing them of the
new RCRA requirements called for development of
complex administrative procedures within the Agency's
headquarters and regional offices.
Another issue invojves the interstate movement of
hazardous waste. Some States believe that the U.S.
Constitution allows them to ban the disposal of waste
originating in other States. This approach runs counter
to the concept of large regional hazardous waste
facilities which, by drawing wastes from several States,
could operate at lower costs than smaller facilities. State
importation bans could also discourage private invest-
ment in new facilities, thus leading to a shortage of
acceptable facilities to accommodate all the hazardous
waste being regulated under RCRA. The issue of
importing waste is politically and emotionally charged
and may take years to fully resolve. However, in 1978
the U.S. Supreme Court ruled that certain types of State
waste import bans are a restraint on interstate com-
merce and, therefore, unconstitutional.
Citizen opposition to the siting of facilities in their
communities is another problem. In fact, a facility in
Illinois, with valid State permits, was closed down by
court order in September 1978 as a result of local
opposition. The citizens' role in the new regulatory
program is of ultimate importance, not only from the
environmental viewpoint but for the continued prosper-
ity of their communities. Without support by citizens to
site new waste treatment, storage, and disposal fa-
cilities, conveniently located for industry, some indus-
tries generating hazardous waste may choose to locate
elsewhere. Lack of citizen involvement and support for
effective hazardous waste management can thus have
an adverse economic impact upon communities.
The requirement of financial responsibility for owners
and operators of hazardous waste facilities is still
another concern. In the past, some owners took in large
quantities of hazardous waste for treatment, storage,
or disposal, but then declared bankruptcy or simply
abandoned the site without adequately disposing of
the waste. State and local governments were then
faced with cleaning up the site at taxpayers' expense.
RCRA's financial requirements could force some small
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operators out of business, thus adding to the problem
of insufficient capacity. However, RCRA provides that
existing facilities may obtain interim status before a
permit is issued. This period can be viewed as a safety
valve while the program is starting up.
informing and
involving the public
Successful development and implementation of the
national hazardous waste regulatory program depend
upon public support, which, in turn, depends upon
public understanding of the many complex technical,
political, social, and economic issues involved. RCRA
provides several mechanisms that afford the public an
opportunity to assume an active role in the program
and seek to increase public understanding of hazardous
waste issues.
Public Hearings and Meetings
RCRA directs that public hearings and meetings be
held by agencies Federal and State during the
development, revision, implementation, and
enforcement of activities required under the Act. This is
to assure that the public has an opportunity to
understand and comment on significant issues and that
the agency gives full consideration to those comments
in making final decisions. The regulations developed by
EPA reflect a careful analysis and integration of the
comments received in the public participation stages. As
Public hearings and
meetings are among
several mechanisms that
afford citizens
opportunities to take an
active part in RCRA
programs. Other
mechanisms include
citizen suits, public
notification
requirements, and
public education and
training programs.
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Information materials
help citizens to gain an
understanding of solid
waste issues. With this
knowledge, they can
participate effectively in
decisions that, in the
past, were made largely
by technical experts.
the Federal regulations are revised and further
developed, and the State hazardous waste programs
are developed and implemented, citizens will have the
same opportunities to participate.
Citizen Suits
RCRA provides to citizens the right to file suit in
Federal court when other means have failed. Two kinds
of legal actions are possible:
citizens suits may be brought against any person
(including Federal, State, and local governments) who
allegedly violates "any permit, standard, regulation,
condition, requirement, or order which has become
effective" under RCRA.
citizens may request that the Federal courts review
the decisions of the EPA Administrator on final
regulations.
Public Information
The public must be informed if it is to participate
constructively in the decisionmaking process. To assure
citizens an opportunity to become well informed, RCRA
requires EPA to develop and disseminate information
on solid waste management. In carrying out this
directive, EPA's Office of Solid Waste produces a variety
of technical reports and other information and makes
them available to the public free of charge. All
materials produced by the Office since 1966 are listed in
Available Information Materials on Solid Waste
Management. This catalog is thoroughly indexed by
subject and updated periodically.
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Another RCRA provision calls for EPA to develop and
implement citizen training programs. Since 1972, EPA
has made grants to civic, scientific, environmental, and
consumer groups and labor unions for informational
activities on solid waste problems. In 1979, EPA
launched a long-term public information program.
Funded by EPA grants, the program Waste Alert! was
undertaken by the American Public Health Association
(as coordinator), the Environmental Action Foundation,
the League of Women Voters Education Fund, the
National Wildlife Federation, the Technical Information
Project, and the Izaak Walton League of America. With
their national memberships and supporters, plus the
knowledge acquired in earlier EPA public education
programs, the coalition is well qualified to reach a
national audience.
Waste Alert! has four goals:
to stimulate public support for effective management
of solid and hazardous waste
to help the public understand the issues and
problems related to siting solid waste facilities
to encourage citizen participation in resource
conservation and recovery programs that can
decrease reliance on disposal
to promote cooperation among public health and
environmental groups, State and regional waste
agencies, industry, elected officials, and citizens'
groups.
EPA launched Waste
Alert!, a major citizen
participation program,
in 1979, with a
conference in New
Orleans. Under this
long-range program, a
series of conferences is
being held across the
country to involve
citizens in solid waste
issues.
To achieve these goals, Waste Alert! began by
holding conferences in all the EPA regions across the
country. The objectives of this first phase of the
program are:
to identify and train citizen leaders concerning
legislation affecting waste management
to assure that the public has the opportunity to
understand official programs and proposed actions
and that the government fully considers the public's
concerns
to keep the public informed about significant issues
and proposed changes in projects or programs
to assist in planning for State conferences and
encourage information programs at the local level
The second phase of Waste Alert! consists of
workshops at the State and local community levels.
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To be part of the solution to the hazardous
waste problem
recognize that we are all part of the problem
hazardous waste inevitably results from the
production of the many material goods that help
Americans to enjoy a high standard of living
reduce the amount of materials we waste this will
not only reduce the quantities of hazardous waste
generated, but will also conserve natural resources,
reduce solid waste disposal problems, and save us
money
understand the many complexities of the hazardous
waste problem EPA, public interest groups, and
State and local governments are sources of
information
participate
join Waste Alert! by writing to EPA, by working
with a local group already concerned with solid
and hazardous waste issues, or by getting an
existing organization to expand its program to
address such issues
take advantage of the many opportunities RCRA
provides for the public to participate
recognize that there are no easy solutions
This abandoned disposal site in Deerfield, Ohio, discharged chemical waste
to a stream which flows into the nearby Berlin Reservoir. From 10,000 to
15,000 drums, some of which contained waste from the manufacture of
re;
if
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everybody's problem
Because of the many times in the past when
hazardous waste was mismanaged out of carelessness,
indifference, or ignorance, most communities resist new
sitesand sometimes continuing operation of an
existing site. Hazardous waste facilities share a common
characteristic with many other "undesirable" neighbors
prisons, highways, airports, and sewage treatment
plants, for example. No one denies the need for them,
but no one wants them nearby.
The resistance to new sites exists for a variety of
reasons, including lack of knowledge about hazardous
waste and hazardous waste facilities (what they are and
what they do); distrust of government decisions;
increase in noise, truck traffic, and odor; aesthetics;
potential effect on land value; uncertainty of how a
community that allows a disposal facility will benefit;
and the belief that the facilities may do substantial
harm to human health and the environment. These
fears may not be based upon the community's own
experiences, but rather upon published accounts of past
incidents in other locations.
New sites for treatment, processing, and disposal
must be found as the national hazardous waste
management program goes into effect. Some existing
disposal sites must be closed if they are unable to meet
pesticides and plastics, were dumped here. The State has appropriated
over $4 million to clean up the site. An important objective of RCRA is to
prevent such uncontrolled practices.
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Citizens and
governments working
together hold the key to
the solution of
hazardous waste
problems.
the new standards. At the same time, the tonnages
requiring disposal will increase because industrial
production is increasing. Moreover, wastes formerly
handled by environmentally unsound and often illegal
methods will have to be disposed of by sound methods
in legally permitted disposal sites.
The national regulatory controls will very likely
encourage conservation practices. Waste management
costs generally rise as safer methods are required, which
should be an incentive to reduce generation of wastes.
Similarly, higher disposal costs will make resource
recovery processes comparatively more economical. But
in the foreseeable future, there will be some wastes
that must be disposed of on land. RCRA regulations are
intended to ensure that new landfill sites are located in
areas that are geologically suitable and designed and
operated to protect public health and the environment.
Pogo, the famous comic-strip character, once
observed: "We have met the enemy and they are us." In
terms of the nation's hazardous waste problems, Pogo
might have said: "We have found the sources of
hazardous waste, and they are us." The American way
of life as we know it today depends upon an
abundance of manufactured material goods, and their
manufacture generates hazardous waste as a
by-product. If we are to continue to enjoy our present
lifestyle, we must begin as a nation to accept
responsibility for working toward a solution of the
hazardous waste problem.
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For further information contact your EPA regional
solid waste office.
Region 1
Solid Waste Program
John F. Kennedy Building
Boston, MA 02203
677-223-5775
Region 2
Solid Waste Section
26 Federal Plaza
New York, NY 10007
272-264-0503/4/5
Region 3
Solid Waste Program
6th and Walnut Streets
Philadelphia, PA 19106
275-597-0980
Region 4
Solid Waste Section
345 Courtland Street, NE
Atlanta, GA 30308
404-881-3016
Region 6
Solid Waste Section
1201 Elm Street
First International Building
Dallas, TX 75270
274-767-2645
Region 7
Waste Management Section
324 East 11th Street
Kansas City, MO 64108
876-374-3307
Region 8
Solid Waste Section
1860 Lincoln Street
Denver, CO 80203
303-837-2227
Region 9
Solid Waste Program
215 Freemont Street
San Francisco, CA 94105
475-556-4606
Region 5
Solid Waste Program
230 South Dearborn Street
Chicago, IL 60604
372-353-2797
Region 10
Solid Waste Program
12006th Avenue
Seattle, WA 98101
206-442-7260
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