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 CONCLUSIONS
   An  investigation was conducted to determine  the  source of
 petroleum products  and its  transport mechanism in  soil. The
 following conclusions were reached:
 • Tanks in the vicinity of Monitoring Well MW-1 have not shown
   any evidence of leaking.
 • Although  the  gasoline  tanks adjacent to  Monitoring  Wells
   MW-2 and MW-3 are considered structurally tight, they may be
   leaking at a rate of 0.02 gal/hr.
 • An inventory of gasoline in regular and unleaded storage tanks
   is necessary. Any unaccounted-for loss in  gasoline will con-
   firm leakage from tanks.
 • Existing monitoring wells were monitored periodically  for
   product thickness and for spread of contamination caused by
   product.
 • The transport of  product in the soil and groundwater was
   through the granular backfill in the subsoil.
 • A pump will be placed in the vicinity of regular and unleaded
   tanks in the sand and gravel fill. As discussed earlier, product
   present in the granular material can be pumped.
REFERENCES
1. WDNR "Guidelines For Monitoring Well Installation," prepared by
  Bureau of Solid Waste Management, Wisconsin Department of Na-
  tural Resources, Madison,  WI, 1985.
2.  U.S.  EPA "Procedures Manual  for  Groundwater Monitoring at
   Solid Waste Disposal Sites," EPA SW-6711, Office of Water and
   Waste Management, U.S. EPA, Dec. 1980, Washington, DC.
3.  USGS "Techniques of Water Resources Investigations of the United
   States Geological Survey, Guidelines for Collection and Field Analy-
   sis of Ground Water Samples  for Selected Unstable Constituents,"
   Book I, Chapter D2, U.S. Geological Survey, Washington, DC
4.  Illinois State Water Survey, "Procedures for the Collection of Repre-
   sentative Water Quality Data from Monitoring Wells," Cooperative
   Groundwater Report 7, Illinois State  Water  Survey, 1981,  Cham-
   paign, IL.
5.  WDNR "Groundwater Quality 1985," Chapter NR 140, Department
   of Natural Resources, Wisconsin Administrative Code,  Sept. 1985,
   No. 357, p. 524-37, 523-53.
6.  Mickelson, D.M., Acomb, L., Brouwer, N., Edil, T.,  Haas,  B.,
   Hadley, D., Hess, C., Klauk,  R.,  Laska, N.  and Schneider, A.F.,
   "Shore  Erosion Study Technical  Report," Shoreline Erosion and
   Bluff Stability along  Lake Michigan and Lake  Superior Shorelines
   of Wisconsin, Wisconsin Coastal Management, 1977.
7.  Singh, P.N.,  Tatioussian, S.U. and Flagg, C.G., "A Study of the
   Geotechnical Properties of Milwaukee Area Soils." A special publica-
   tion on Geological Environment and Soil Properties,  ASCE Geo-
   technical Engineering Division,  Houston, TX, 1983,  269-309.
                                                                                        UNDERGROUND LEAKING TANKS    277

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                                Underground Storage  Tanks—
                   Leak  Prevention,  Leak  Detection, and  Design

                                         Jey K. Jeyapalan, Ph.D., P.E.
                                            James B.  Hutchison, P.E.
                              Wisconsin Hazardous Waste Management Center
                                             University of Wisconsin
                                               Madison, Wisconsin
ABSTRACT
  Three to five million underground storage tanks containing
hazardous substances exist in the United States. Several thousand
of these tanks are leaking and causing contamination of ground-
water, and the U.S. EPA has been charged with the implemen-
tation of RCRA to control this problem.
  In response to this problem, leak prevention and detection pro-
visions are becoming an integral part of the design and construc-
tion of underground storage tanks. Although several standards
and codes are in existence to yield proper design, many of these
are consensus standards and perhaps may not ensure structural
safety for ail anticipated loading conditions.
  This paper  presents the details of leak prevention and detec-
tion techniques. In addition, the important aspects of structural
design of these tanks are discussed.

INTRODUCTION
  In the Silicone Valley of northern California,  leaking under-
ground storage tanks  containing trichloroethylene  led to the
promulgation of model  underground ordinances which  cover
overfill protection equipment, secondary containment and leak
monitoring systems for all new facilities." The neighborhood gas
stations in Rhode Island had storage tanks that leaked and con-
taminated the water supply. The owners of the gas stations were
found liable for the cost of cleaning up the water supply and sup-
plying clean water to area residences. A Massachusetts gas sta-
tion owner was found liable for the cleanup of the contaminated
groundwater caused by a leaking underground storage tank. In
Long  Island,  leaks from underground  storage  tanks contami-
nated 25 basements. The owner of the tanks was forced to pur-
chase the 25 homes affected by the spill.
  Oliveira and Sitar" have reported the details of over 100 cases
of underground storage tank leaks and spills involving  organic
chemicals  in the Santa Clara Valley of California.  In most of
these cases, the groundwater was contaminated. These case his-
tories indicate only the tip of the iceberg.
  Three to five million underground storage tanks containing
hazardous substances exist in the United States. Of these,  100,000
are presently leaking and another 350,000 are expected  to start
leaking within the next 5 years.10 The users of these underground
storage tanks are listed in Table 1.

FEDERAL LEGISLATION
  RCRA was passed to control this growing problem. The act
covers a wide range of items which include  the storage of haz-
ardous materials in underground storage tanks.  RCRA  was re-
vised by the Hazardous and Solid Waste Amendments of 1984.'4
These amendments define underground storage tank as any one
                                                                                Tablt 1
                                                                     User* of Underground Storage Tank*
                                                       Airports
                                                       Auio Dealers
                                                       Auto/Truck Rental
                                                       Auto Repair Shops
                                                       Banks
                                                       Can* ashes
                                                       Cemetaries
                                                       Churches
                                                       Colleges
                                                       Commercial/Industrial
                                                         Office Buildings
                                                       Construction Companies
                                                       County & Local Governments
                                                         Fire Department
                                                         Police Department
                                                         Prisons
                                                         Sanitation Department
                                                         Public Bus System
                                                         Water Treatment Plant
                                                         Municipal Building
                                                         Highway Department
                                                       Convenience Store
                                                       Delivery Services (UPS,
                                                         Department Stores, Emery, etc.)
                                                       Distribution Companies
                                                       Elementary & High Schools
                                                       Farms
                                                       Federal Government
                                                         Dams
                                                         Federal Highway Department
                                                         Military Bases
                                                         Office Buildings
                                                         Post Office Department
                                                         Prisons
                                                       or a combination of tanks (including underground pipes con-
                                                       nected thereto) used to contain an accumulation of regulated sub-
                                                       stances where the volume (including the volume of the under-
                                                       ground pipes connected thereto) is lOVo or more beneath the sur-
                                                       face of the ground.
                                                         The amendment also requires the following items  to be in-
                                                       cluded in the regulations:
                                                       • Requirements for maintaining a leak detection system, an in-
                                                         ventory control system together with tank testing or a compar-
                                                         able system or method designed to identify releases  in a man-
                                                         ner consistent with the protection of human health and the en-
                                                         vironment
Home Owners
Hospitals
Hotels
Independently Owned
  Service Stations
Grocery Stores
Jobber Bulk Terminal
Major Oil Bulk Terminal
Major Oil Service Stations
Manufacturing Plants
Marinas
Mining Companies
Motels
Nursing Homes
Recreational Facilities
Residential Apartment Buildings
Restaurants
Slate Governments
  Prisons
  Highway Department
  State Office Buildings
School Bus Garages
Shopping Centers
Tire Stores
Transportation Services (Taxi,
  Limousine, Bus Lines)
Truck Stops
Trucking Firms
Utility Companies
278
UNDERGROUND LEAKING TANKS

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• Requirements  for maintaining records of any monitoring or
  leak detection system or inventory control system or tank test-
  ing or comparable system
• Requirements for reporting releases and corrective action taken
  in response to a release from an underground storage tank
• Requirements  for taking corrective action in response to a re-
  lease from an underground storage tank
• Requirements  for the closure  of tanks to prevent future re-
  leases of regulated substances into the environment
  The promulgation of any regulation takes time. In order to
minimize potential leaks of tanks which currently are being con-
structed, an interim  prohibition of underground storage tanks
was immediately imposed by the  Hazardous and  Solid Waste
Amendments of 1984. The interim prohibition states:

  "(1) Until the effective date of the standards promul-
       gated by  the administrator under  subsection (e)
       and  after one hundred and  eight days after the
       date of the enactment of the Hazardous and Solid
       Waste Amendments of 1984, no person may install
       an underground storage  tank for the purpose of
       storing  regulated  substances unless such  tank
       (whether of single or double wall construction)—
       (a) will prevent releases due to corrosion or struc-
          tural failure for the operational life of the tank;
       (b) is  cathodically protected  against  corrosion
          (Fig.  1), constructed of noncorrosive material,
          steel  clad with  a noncorrosive material,  or de-
          signed in a manner to prevent  the  release or
          threatened release of any stored substance; and
       (c) the material used in the construction or lining of
          the tank  is compatible with the  substances
          to  be stored.
    (2) Notwithstanding paragraph (1),  if soil  tests con-
       ducted in accordance with ASTM Standard G57-
       78, or another standard approved by the Admin-
       istrator, show that soil resistivity in  an installation
       location is 12,000 ohm/cm  or more (unless a more
       stringent standard is prescribed by the Adminis-
       trator by rule), a  storage tank without  corrosion
       protection may be  installed in that location during
       the period referred  to in paragraph (1)."
                                             WATER
                          Figure 1
                  Phenomenon of Corrosion

  The  amendment  also  establishes  civil  penalties of  up to
$10,000/tank/day for any owner or operator who fails to comply
with either state or federal regulations regarding  underground
storage tanks.
  These regulations are the initial steps taken to reduce the threat
of leaking  underground  storage tanks contaminating ground-
water. The implementation of these RCRA-UST regulations is in
progress and is continuing to gain momentum. As part of the
RCRA regulation promulgation, a proposed rule (The Hazardous
Waste Management  System; Standards for Hazardous Waste
Storage and Treatment Tank Systems) was published in the Fed-
eral Register on June 16, 1985.'
  Statistics provided  by the proposed rule on leaks due to cor-
rosion cause concern about the integrity of existing tanks and the
requirements for future tanks. "Seventy to eighty-five percent of
the leaks were due to tank and/or piping  failures from subsur-
face  corrosion," states a study of over 2,000 cases  of leaking
underground storage  tanks by the American Petroleum Institute
(API). A study conducted for API entitled "Underground Un-
protected  Steel Tank  Study-Statistical Analysis  of  Corrosion
Failure" indicated that 50% of all unprotected steel tanks will
develop a leak by the time they are 16 years old.  The National
Association of Corrosion Engineers (NACE) reported that  after
5 years, the accumulated number of leaks in underground pip-
ing increases by a factor of 10 every 5 years.
  The U.S. EPA and those involved in the design of underground
storage tanks are convinced that any tank will leak and a secon-
dary confinement is the most cost-effective way to address this
problem. Secondary confinement will determine the cause of a
leak, ensure detection of the leak and perhaps contain the leak-
ing material to avoid contamination of groundwater.
                                                                                          Figure 2
                                                                                   Rigid Double Wall Tank
SECONDARY CONTAINMENT
  A concept which has become an important ingredient in leak
prevention and monitoring required by new RCRA is secondary
containment. A  general definition of secondary containment is
the construction  of a barrier to resist free flow between the tank
and the environment. The barrier may be another tank wall or
shell (double walled tanks or jacketed tanks),22'23 as  shown in
Figures 2 and 3.  The shell may be a concrete pit (Fig. 4), a liner
composed of soils (Figs. 5 and 6) or a layer of soil sealant such as
                                                                                    UNDERGROUND LEAKING TANKS    279

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                HOLDOOWN CUPS
LEAK DETECTION AND MONITORING METHODS
  The federal legislation which is being implemented places em-
phasis on keeping leaks in underground storage tanks to a min-
imum. There is also the need to detect leaks early so that immed-
iate remedial action can be taken. To understand how leaks can
be eliminated best, it is beneficial to explore the causes of leaks in
underground storage tanks.
                                                                                                     Tible 2
                                                                                         Corrosion Type*; Causes & Corn
                                       V-
                           SECTION A-A


                            Figure 3
                    Flexible Double Wall Tank
soil cement, bentonite,  engineered  low  permeability soil sur-
rounding the tank. Secondary containment systems are designed
to be installed at the time of initial tank installation.  Secondary
containment systems can be retrofitted to existing tanks, but this
usually means excavating and removing the existing  tank to install
the system.
   Leak  detection and  monitoring are easier  on systems which
have secondary containment for two reasons: (1) the leaking ma-
terial must penetrate two barriers to get to the environment and
therefore takes more time; and (2) the space between the two bar-
riers provides a good location for the placement of leak moni-
toring devices, since material which leaked through the first bar-
rier (the tank wall) would accumulate in this space  prior to leak-
ing through the second barrier. Because of these reasons, secon-
dary containment systems always have a leak sensing system con-
nected to the space between the two barriers. Pipes also may have
a secondary confinement system as shown in Figure 7.
                                                                        Corrosion
                                                                        Types	

                                                                        Galvanic
 Stray Currents
Stress
Corrosion
 Biochemical
 Direct
 Chemical
 Attack
                ClUKi
                                              Com
                I. Occur* when dissimilar metals
                are connected by an electrolyte.
                2. Occurs when structural pipe
                or lank joins to different soil
                types.
                3. Dissimilarities on the surface
                of the  pipe.
4. Differential aeration of the
toil around the pipe.

5. Backfilling with mixed strati-
fied layers (local corrosion).


1. Direct current is discharged
from the pipe wall. (Other
sources of current near under-
ground structures with the
ground as pan of their circuit.)

I. Points of concentrated stress
near areas of uniform stress in
the presence of an electrolyte.


1. Bacteria in the soil affecting
the concentration of ions in the
electrolyte.
1. Chemicals directly attacking
the structures (i.e.. road salt).
I. Insulate
metals one from another.
2. Insulate structure
from soils.

3. Close adherence to
correct manufacturing
procedures.

4. Thoroughly tamp
backfill to one ft above
the pipe.
5. Control backfill
material.  (Backfill with
homogenous material.)

I. Must be defined for
each specific instance.
I. Reduce number and
magnitude of concen-
trated stress areas in the
tank and pipeline

1. Thoroughly tamp
backfill to one ft above
the structure. Remove all
deleterious materials
from the backfill.

I. Seal the surface
from infiltration.
                        MTCMCIO     ACCtt* TO TAH«
                                                                 Figure 4
                                                          Tank in Concrete Vault
280    UNDERGROUND LEAKING TANKS

-------
                    DRAINAGE
                     OtTCH
      LINEN ON
    WAaTEPROOP
    COATINQ ON
EN   CONCNCTI
                                                                            LEAK
                                                                         MOMTORMO
                                                                            powr
SEE 'TYPICAL OWE »Y«TEU-
    DRAWING FOH DETAIL*
                                                       •OIL COVEN
                                                     FOB EROaiON AND
                                                       ULTRA VIOLET
                                                       PROTECTION
                                                                                 LINEN ON
                                                                               WASTEPROOF
                                                                               COATINQ ON
                                                                                CONCRETE
                                                            Figure 5
                                                       New Inground Tank
                           LINEN
                         TURHIAOK
                                                                     MONITORINO POINT-
                                                                     aUITABLE PON LEAK
                                                                     DETECTION AND WITH-
                                                                     DRAWAL OP ACCUMU-
                                                                     LATED WATER
                                                  ,PAVEMENT
                                                             COLLAN TO.
                                                             CONNECT PIPE
                                                             TRENCH TO TANK
                                                               LINER
                                                                     • TRENCH
                                                                    TOP LINER
                                                                                          PIPE
                                                                                    FOR LEAK
                                                                                  DETECTION AND
                                                                                   WITHDRAWAL
                                                                                    OP WATER
                                                             Figure 6
                                                 Synthetic Membranes Around Tanks
Causes of Leaks
  External underground corrosion is by far the most common
cause of leaks in  steel  tanks.  Underground corrosion involves
chemical reactions and the flow of electrical current. Therefore,
corrosion occurs through an electrochemical process. The soil,
with its water content,  acts as an electrolyte. Corrosion occurs
when metal atoms go into solution and are transformed into com-
pounds as shown in Figure 1."
  It may be helpful to visualize the process of external corrosion
of an underground storage tank by viewing the tank/soil system
as an electrolytic cell. The corroding area of the tank is the mode,
the soil is the electrolyte and another area of the tank forms the
cathode. An anode is the electrode of an electrolytic cell at which
direct current is discharged and corrosion occurs.24 The cathode is
the electrode of an electrolytic cell at which reduction or preven-
tion of corrosion occurs. When an area of a tank wall corrodes to
the extent that the useful  wall thickness cannot carry external
pressures or internal pressures, a leak develops.
                                     The different types of corrosion, their causes and  cures are
                                   listed in Table 2.24'26-27 Cathodic protection is an important meas-
                                   ure taken to prevent corrosion. A sacrificial metal is placed near
                                   the tank and acts as the anode. Current flows from the sacrificial
                                   metal through the soil to the tank which acts as the cathode. The
                                   tank shall be protected from corrosion as long as the  sacrificial
                                   metal can transmit a current to the tank.
                                     Internal corrosion accounts for  10-29% of corrosion induced
                                   failures.' Internal corrosion has the same causes and cures as ex-
                                   ternal  corrosion, plus the additional factors of dynamic impact
                                   loads of the gauging stick and the loads  caused when  filling the
                                   tank. Installing a striker  plate below the fill pipe eliminates the
                                   possibility of scratching the liner with the gauging stick; it also
                                   diverts the incoming hazardous material, thus minimizing the im-
                                   pingement at the bottom of the tank.''
                                     Inadequate installation and design procedures  are another
                                   cause of leaks. Improper handling of coated steel tanks may cause
                                   scratches in the lining which expose the steel to corrosive activity.
                                                                                       UNDERGROUND LEAKING TANKS    281

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                                                          PAVIUIHT
                                         WELL COMPACTED NON CORH08I
                                               (CLIAN WAiH«0  IAHO OK •MAVtl)
                       LINIM ON WAIT1PMOOP
                       OOATIN* ON COHOMITf
                                                           Figure 7
                                               Underground Lined Trench for Piping
Neglecting hold-down straps or underdesigning them may cause
uplift of the tank when groundwater surrounds the empty tank.
Poor quality backfill or improper backfilling procedures may
cause excessive strains in flexible tanks. Filling the tank prior to
backfilling also may cause rupture of the tank due to lack of lat-
eral support from the backfill.
  Poor operating procedures  can  create leaks in underground
storage tanks. Puncture of the tank wall by the gauging stick or
filling/discharge pipe may cause a leak. Overfilling causes spills
and unexpected pressure head within the tank. Proper operational
practices such as the use of a level sensing device, level indicating
device, high level alarm, automatic shutoff control system, by-
pass prevention of overfill  prevention system and interlocking
loading process with overfill prevention system  so loading cannot
occur  without the overfill  prevention  system  being activated,"
will prevent spills which account for a large portion (± 40%) of
contamination.*

Leak Detection
  Tanks cannot be designed to be  virtually leak proof even at a
significant cost. Thus, vendors take the approach  of designing
tanks to last 30 to 50 years. Since  tanks will inevitably leak due
to one of many causes, it is best to design the tank with leak de-
tection and monitoring. Early detection and remedial action can
save millions of dollars.
  Testing for leaks can be classified into four general groups:"

• Volumetric leak tests (quantitative)
• Non-volumetric leak tests (qualitative)
• Inventory control and reconciliation analysis (trends)
• Effects monitoring (perceivable environmental changes)

Volumetric Testing
  Volumetric leak tests provide data which can determine if a
tank is leaking and at what rate it is leaking. This is perhaps the
most helpful information a tank owner or regulator can obtain.
Knowing the rate of the leak helps  to determine the needed level
of corrective action.
  The  rate of leak  is found by determining the  volume of de-
crease  of stored product by measuring properties associated with
  0.09


  0.08


  0.07


  0.06


_ 0.05
 o
 o>
«-i
°. 0.04


  0.03


  0.02


  0.01
                           J_
                                       I      I     I     J	1
                2000
                          4000       6000
                            Tank Size (90!)
                                                8000
                                                          10.000
                           Figure 8
  Change in Temperature of Gasoline Needed to Produce a 0.05 Gallon
             Volume Change as a Function of Tank Size
the change in volume. The volume of the stored material is mon-
itored constantly by a float inside the tank or by a pressure sen-
sor in the bottom of the tank. Since the temperature of the stored
material has an important effect on the volume of the material, it
must be measured. A small change in temperature, particularly
with a large volume as seen in Figure 8, may change the volume of
the material significantly. Vapor pockets within the tank may in-
fluence the measured volume of the material (for tests that re-
quire a full tank) because air or  vapors expand and contract at
different rates than fluids.
282
       UNDERGROUND LEAKING TANKS

-------
  Vibrations of vehicle traffic or mechanical machines can cause
a surface ripple in the stored substance causing the float to move
erratically.  Since the measurement of the depth of stored  ma-
terial must  be within fractions of an inch,  any vibration move-
ment should be eliminated.
  The presence of groundwater around  the tank will not affect
the volume of the stored substance, but will affect the rate  at
which the substance leaks.  This change in  rate is due to a de-
crease in differential pressure between the inside and outside  of
the tank. Evaporation and  condensation within the tank  may
cause errors in volumetric testing. These usually cause problems
only if the stored material is not sealed to atmospheric conditions
and can  be remedied by placing the cap back on the fill pipe.
Volumetric testing requires trained personnel and very accurate
measurements. These elements  make volumetric testing expen-
sive and time consuming.

Non- Volumetric Testing
  Data from  non-volumetric tests determine if a tank is leaking
or not but do not  determine the leak rate.  These data are valu-
able but not as useful as a volumetric test. Non-volumetric tests,
however, are  cheaper and easier to perform and may be used  to
determine which tanks, within  a field  of multiple tanks, need
further testing or may be used  as a  first alert for more serious
potential problems.
     Normal.
     After  40 minutes.
     Alarm  situation.
     After  90  minutes.
  Several methods are used for non-volumetric testing. Helium
leak detectors commonly are used: helium vapor pressurizes the
in situ tank and the amount of helium that diffuses through the
leak back to the surface is monitored. Although helium can dif-
fuse through asphalt and concrete, it takes time and, therefore,
boreholes may be cored for quicker detection.
  The vacuum/hydrophone tests involve creating a vacuum in a
sealed tank greater than the static head pressure of the liquid in
the tank.  The tank then is monitored with hydrophones for the
sound of bubbles being drawn in through the leaks. If the ground-
water table surrounds any of the tank, then the amount of water
within the tank should be determined before and after the test to
see if any water was drawn in through the leak.
  Direct buried cable sensing  is useful in long-term constant
monitoring situations.39 Two wires are placed within an insula-
tion jacket, as shown in Figure 9, which dissolves in the pres-
ence of petroleum; when the jacket dissolves, the two wires touch
and signal an alarm. Since the cable is  buried directly, it can be
placed in  areas where it will do the most good as shown in Fig-
ures 10 and 11.
                                                                                         Figure 10
                                                                        Direct Buried Cable Placement for No Water Table
                        Figure 9
             Direct Buried Cable for Leak Testing
                                                                                         Figure 11
                                                                        Direct Buried Cable Placement for High Water Table
  Vapor testing can be performed in the soil next to the tank sys-
tem within the space between the two  walls of a  double-walled
tank,  called interstitial testing, or within the space between  the
other  secondary  confinement structures.  This test  utilizes a
vacuum to draw the vapors through the monitoring device. Ob-
servation wells with either temporary or continuous monitoring"1
can be used.
                                                                                     UNDERGROUND LEAKING TANKS    283

-------
                         Figure 12
            Typical Service Station Tank Installation
   In the case of petroleum, continuous monitoring is done by
placing a float within the monitoring well as shown in Figures 12
and 13. The float is equipped with petroleum sensing equipment
which  can sense as  little  as 0.25 in. of petroleum floating on top
of the  water table. Direct sampling of the water can be done with
wells to determine the chemical make-up of the water.
   Interstitial flooding can determine a leak in one of the two walls
 of a double-walled tank. The interstitial space is flooded with a
 liquid  and the height of this liquid in  the fill pipe to the inter-
 stitial space is monitored as shown in  Figures 14 and 15. If the
 liquid suddenly goes down, this decrease in liquid level indicates
 that there is a  leak in either of the two walls.
   In the dye  method, a dye is  used in the stored substance. If
 this dye shows up in surrounding storm sewers, sanitary sewers,
 ditches, basements or any other low area, its presence indicates a
 leak in the pipe or the tank.
   It should be noted that these non-volumetric tests are versa-
 tile, and various tests may be combined or altered to collect more
 data. For example, a dye may be flooded into the interstitial space
 of a leaking tank to see if the inside wall is leaking, in which case
 the stored material will  carry the dye color, or if the outside wall
 is leaking, in  which  case the backfill will become dyed. The di-
 rectly buried cable also could be placed in the interstitial space
 to check the leaks.

 Inventory Monitoring and Reconciliation
   Symptoms of leaks can be observed if careful inventory mon-
 itoring of the stored substance is used." Leaks cannot be directly
 detected or measured by this method, but it can be a helpful tool
 in determining where there is a strong possibility of a leak. Symp-
 toms which appear when there is a leaking tank are an apparent
 loss or gain of stored substance when the substance has not been
 dispensed or filled, differences in the amount of substance dis-
 pensed and received,  a  hesitation in the delivery  of the material
 from a standard dispensing pump indicating a leak in the suction
 pipeline and odors of the stored material in places below ground.
   Factors which  influence the   inventory control  method are
temperature related  volume changes of the stored substance,
 faulty  or  erroneous  dipstick readings  and displays.  Computer
analysis of the data enhances the interpretation of the data, but
the data must first be as accurate as possible.
                                                                                  FH.Iol. ConUI Option*
                                   Conduit
                                            u vtholl Cow
                                                         Solid
                                                         flliw
                                                         Pip* (Not Suppll.cn
                                                  SlKvianJ Slotted Pip*
                                                  Monitoring Will VrMn
                                                  4' 8CM40PVCor
                                                  <• SttfnlM* SIM (No! Suppltod)
                             UNOcmnouNO INSTALLATION
                               (Typta* Ouollni Billion)
                                                                        AaOVCOflOUNO INSTALLATION
                                                            Figure 13
                                                        Monitoring Wells
284    UNDERGROUND LEAKING TANKS

-------
                                                                                                       XNATIVE
                                                                                                       '"-on
                                                                         •&&f"                   "•••'%
                                                                         ^l":--^   UrtLJ r*f\r*etf\at\it!    '7.W..
                                                           Figure 14
                                                     Double Wall Steel Tank
Leak Effects
  Monitoring  the environment immediately adjacent to  the
underground storage tank locations for any changes due to leaks
is another qualitative  method of finding leaks. A leak may be
discovered, but the quantity of leakage and the exact locations,
particularly if there is more than one tank at the location,  will
not be known.
                                       Liquid Media
                                       Reservoir
                                       Water Table

                                       Inner wall breach
                                       Liquid media goes into
                                       tank; prevents product
                                       from escaping.
                                       Outer wall breach
                                       Liquid media goes into
                                       tank excavation
Monitoring Methods
  Proposed legislation will require  proof of monitoring  and,
therefore, records will have to be kept. There  are  three basic
methods of compiling these records: (1) by hand, (2) by mechan-
ical means (or computer), or (3) by a combination of these two
means.
  Continuous monitoring almost always is compiled by mechan-
ical means.  Few continuous monitoring techniques yield  con-
tinuous data such as the direct buried cable, but will set off an
alarm whenever a leak is detected, even by a modem to the own-
er's remote location.
  Routine or scheduled compiling could verify such continuous
monitoring. This monitoring  would entail a daily or  weekly
checking of devices in place. Scheduled air samples or water sam-
ples could be taken and tested. Good record keeping will be the
owner's responsibility. Spot check monitoring with volumetric
tests should  be done when inventory reconciliation or leak detec-
tion alarms are triggered.
                          Optional Leak
                          Simulator*'
                                                           Figure 15
                                                  Interstitial Monitoring System
                                                                                      UNDERGROUND LEAKING TANKS    285

-------
       Reinforced concrete
       #5 rebar 8" OC both ways
       (2-layers)
                               -  24" x 24" manhole box
                                 with cover (not supplied)
  9V
                                             2" x4' x 3' mln or
                                             equivalent wood
                                             required to support
                                             riser
22S" sq
(opening in riser)
                                       1) Riser Is not load bearing
                                       2) Rebar mat must extend
                                         4 ft. in  all directions
                                         from center of riser
                          Figure 16
                      Manway Riser Pipe
         r
         l	j
                              Tank
                              top
                                        r
                                          Two filling
                                            option


                                                      |
                                              Plug
                                        I	I
                                       4	.	
                                       Fiberglas layup
                         Fiberglas
                         layup
                                         2" or 4" NPT
                                         half-couplings
* "X" Dimension on Double 2" Fittings Equals 5"
  "X" Dimension on Double 4" Fittings Equals 9"


                          Figure 17
                      Steel NPT Fittings
Tank Appurtenances
  In addition to requirements about leak detection devices, the
new tanks should  include several  types  of key appurtenances.
These include manway riser pipes, fittings, heating coils and lad-
ders for visual inspection as shown in Figures 16-19.
                                                                       Heating Coll
                                                                                        Material: carbon steel

                                                                                              28' dia  x  ',." thick
                                                                                                  24 - V holes on a
                                                                                                 /25^,." boll circle dia.
                                                                                                . 2" NPT couplings (optional)
                                                                            1".* coil inlet and outlet
                                                                                       Heavy-duty 22"
                                                                                       ID manway
                                                                                                               Varies
                                                                                                              with tank
                                                                                                              diameter
                                                                                                             4-0"
                                                                                                                8" min.
                                                                                           Figure 18
                                                                                      Helical Heating Coils
STANDARDS AND CODES
  One of the attempts tank  manufacturers have undertaken to
minimize leaks is the use of standards and codes for the design
of underground storage tanks. The following codes and standards
pertain to the design and performance  of reinforced fiberglass
and steel underground storage tanks:

• American Petroleum Institute Standard 6201
• American Society for Testing and Materials D 4021-18'
• National Association of Corrosion Engineers RP-01-69"
 286     UNDERGROUND LEAKING TANKS

-------
              22" manway on 6', 8', and 10' diameter tanks

                                     FRP slip lug
                          Figure 19
                        Tank Ladders
 • National Fire Protection Association  Codes 30 and 31 and
  Handbook29'31
 • Underwriters Laboratory Codes 58 and 131640'41
  There are three types of standards or codes for underground
 storage tanks. The first are the standards to be followed when de-
 signing these structures. The second are performance standards
 which list a series of tests or qualifications that must be passed by
 the manufactured underground storage tanks. The third are stan-
 dards or codes which specify how the manufactured tank should
 be installed and operated.


 Steel Tanks
  The standards which govern steel underground storage tank de-
 sign are UL 58,40 API 6202 and NACE RP-01-69. The UL 58 is
 the standard for steel underground tanks for flammable and com-
 bustible liquids. The  requirements  include:  capacities, dimen-
 sions, metal thicknesses, materials, shell seams, heads and head
 joints, compartment tanks, pipe connections, manholes, heating
 coils and hot  wells, manufacturing and production tests and
 markings.
  API 620 contains recommended rules for the design and con-
 struction of large, welded,  low-pressure storage tanks. The text
 includes: materials;  design  of walls, roofs,  internal and extern-
 al structural members, wall  openings, nozzle necks, bolted flange
connections, cover plates and joints (welds); inspection and tests;
and pressure and vacuum-relieving  devices. The  recommended
rule also contains a number of helpful appendices which include
suggested good practices regarding foundations, corrosion allow-
ance, attachment structures (internal and external), peening, in-
stallation, supporting  structures and determination of relieving
capacity required.
   NACE RP-01-69 is a recommended practice of control of ex-
ternal corrosion on underground or submerged metallic  piping
systems and pertains to underground steel structures. This stan-
dard is somewhat detailed in dealing with corrosion control. The
standard  deals with the following  list of thems: structural  de-
sign of corrosion resistance;  coatings for corrosion resistance
and their applicability; cathode protection and its criteria,  de-
sign, installation, operation and maintenance; control of inter-
ference currents; and corrosion control records.

Fiberglass Tanks
   The two codes listed for reinforced fiberglass tanks are both
performance standards. These codes are described below.
   The ASTM D 4021-81 contains  standard  specifications for
glass-fiber-reinforced polyester underground  petroleum storage
tanks and prescribes a  number of requirements the finished pro-
duct must fulfill.3 Tests  include the concentrated load test, ex-
ternal  hydrostatic  load test,  internal  pressure  tests,  fitting
moment test, fitting torque test, leakage test, internal impact test,
lifting lug strength test, negative pressure test, material property
tests and chemical resistance tests. Minimum thickness for shell,
pipe fittings and flange  also are given in this standard.
   The UL 1316 is  a standard for  glass-fiber-reinforced plastic
underground storage tank for petroleum products and this gives a
number of tests that must be fulfilled by the finished product.41
The test titles are virtually the same  as those in ASTM D 4021-81
standards, but the procedures are somewhat  different. The UL
1316 standard also  has additional marking requirements  along
with manufacturer installation requirements.
   Finally, the installation, usage and monitoring codes pertain to
all tanks regardless of the material used in making the tank. These
codes  are: NFPA  30  "Flammable and  Combustible  Liquids
Code,"24 NFPA 30 "Oil Burning Equipment  Code,"30  and the
NFPA "Fire Protection Handbook,"31 These  standards consider
the possibility of fires  and thus are written to reduce  the risk.
Methods of construction and abandonment  of existing under-
ground storage tanks also are detailed in these standards.
DESIGN CONSIDERATIONS
  A successful design of underground storage tanks should con-
sider the following:

• Loads
• Materials and properties
• Compatibility and life
• Tests
• Handling
• Installation
• Procedures for analysis
• Monitoring and management
  The design of underground storage tanks must take into ac-
count the various loadings that the tank will experience. Failure
to recognize these loads could result in collapse of structures as
shown in Figure 20. These loads include internal pressures (or
vacuum) caused by liquids and gases, the weight of the tank itself
and external loads. The external loads consist of traffic loads,
soil loads, reactions at the supports and pipe connections, wind
loads,  seismic loads, frost loads and hydrostatic  loads. Fatigue
loads caused by filling and  unfilling the tank also should be
addressed.
                                                                                     UNDERGROUND LEAKING TANKS    287

-------
                         Figure 20
                       Tank Failures
Loads
  The internal pressure loads depend on the properties of the ma-
terial being stored and the geometry and fiUing/unfilling pro-
cedures of the tank system. For example, if the material stored
is delivered hot and  evaporates, it may cause a vapor pressure
within the closed tank system.  If the filling pipe extends to an
appreciable height vertically above the tank  and  is filled to the
top, high pressure heads in the liquid  will develop. The weight of
the tank can be determined prior to the installation. This load
becomes important in empty tanks and tanks that are simply at
their ends.
  The external loads may be more difficult to determine than the
previously mentioned loads. The site at which the tank is to be in-
stalled must be characterized adequately to determine these loads.
Traffic loads are the dynamic loads  transmitted by moving ve-
hicles through the soil to the tank. These loads are a function of
the weight of the vehicle, size of the tire, the vertical and the hor-
izontal distance from the load to  the tank and the soil asphalt-
concrete structure between the load and the tank.
  Soil loads are a function of the type of soil surrounding the
tank, the depth of burial of the tank and the pressure of any load
producing structures such as foundations adjacent to the tank.
The weight of the soil above the tank minus any arching affect
the soil may possess, will load the tank. Dynamic loads such as a
foundation supporting vibrating machines or equipment may in-
duce additional loads on the tank and the piping system.
  Reactions at supports tend to localize the external loads on the
tank at the support areas. This increases the shear and moment
induced stresses and strains within the tank wall. The tank wall
material must be designed to withstand these stresses and strains.
  Wind, seismic and frost loads also should be taken into account
if they are applicable. Sites must be evaluated  for the severity
and likelihood of these loads.
  Hydrostatic loads are  loads imposed on the tank due to the
presence of water in the soil surrounding the tank. If the water-
table or the presence of static or flowing water is never encoun-
tered by the tank, the hydrostatic loads may be neglected. If the
tank is not designed with any hold down mechanisms and the
buoyant force is greater than the weight of the tank and the
stored  materials and the resistance from  the soil-asphalt-coo-
Crete above the tank, the tank will float out of the ground. Straps
and anchors should be designed approximately to withstand these
forces.
  Fatigue loads  caused by filling and discharging the tank also
should be considered in the design.  This consideration may in-
clude the design of a spill plate  below the filling pipe and extra
reinforcing around pump and pipe connections within the tank.
In addition, temperature effects and Poisson's effects need to be
considered.
  The various types of loads which need to be considered were
discussed in the previous section. The properties of materials con-
stituting the tank wall required to complete the design  are a*
follows:
• Strengths under tensile, compressive and shear loads
• Moduli under tensile, compressive and shear loads
• Stress-strain curves
• Poisson's ratio

Material Compatibility
  In order to ensure long life for the designed tank, the compat-
ibility of the stored  materials with the tank wall, stress  corro-
sion, strain corrosion and creep need to be accounted for in the
analyses, and proper allowances need to be made in the final de-
sign alternatives.

Handling WM! Installation
  Proper handling and installation of the tank are important for
the  tank to function adequately during its anticipated life. After
the  underground storage tank has passed a number of manufac-
turing tests (such as the 5 Ib/in.' air test and the x-ray test) and
has passed on-site delivery inspection, it is ready to be placed in
the  ground.  Care must be taken when handling  these tanks, es-
pecially the more flexible tanks,  to avoid unnecessary protective
coatings and other expenditures.  Manufacturers have recommen-
dations to follow to meet installation requirements.
  Once the tank is in place on its appropriate bedding material,
backfilling may begin. Most tank installation instructions prevent
filling the tank with the contents prior to backfilling. Because of
the  need to reduce the pressure of water and to provide adequate
lateral  soil support, it is necessary  to use a  granular material
which is backfilled and compacted in one foot lifts. Methods of
compaction to ensure uniform and complete compaction require
the  use of proper equipment to suit the types of backfill and tank
used. A  technique used  to  evaluate  how  well compaction is
achieved is to compare the field densities to standard or mod-
ified Proctor laboratory test data on samples of soil. If the field
288    UNDERGROUND LEAKING TANKS

-------
density is less than that required by the designer's specifications,
the backfill should be recompacted.
  It may be of interest that there is an optimum water content of
the soil where the soil compacts easiest. This value is obtained by
the Proctor test.  Field densities can  be determined by the sand
cone method or by a nuclear density test. Emphasis should be
placed on the importance of properly placed backfill to ensure
tank longevity.
  Once the tank has been backfilled, the ancillary equipment  and
piping system can be installed. The whole system should be con-
structed to achieve easy accessibility for  tank inspection (i.e.,
measuring stick,  etc.), tank filling and emptying. Access man-
holes  and vents should be located under low overhangs or adja-
cent to a wall.
  After installation, the 5 lb/in.2 air pressure (or water pressure)
test should be run on the underground storage tank and its pip-
ing system. The entire system is pressurized by air (or water),  and
the amount of pressure drop over a certain time period is meas-
ured.  If the leakage rate is too excessive, corrective measures must
be taken.

Analysis
  The soil  tank interaction  behavior also needs to be  analyzed
for groundwater induced seepage pressures, settlement, live load
induced  stresses, longitudinal stresses  and  circumferential
stresses. Finite element models provide reliable means of analyz-
ing even the most complex situations in  the  field. The senior
author has developed a series of analysis procedures for perform-
ing the above design computations. Further details are given in
Jeyapalan et a/.16~21  The analysis procedures also permit  the
following types of investigations:
• To  assess the structural adequacy of existing tanks
• To  assess the remaining life of existing tanks before these need
  replacement
• To assess the adequacy of new tanks sold by various vendors
• To provide backup analysis when outdated codes and standards
  are inadequate to ensure structural safety
  These procedures have been found useful when examining sev-
eral  underground  installations. Additional  information  can be
found in Jeyapalan, et a/.15~21

TESTING UNDERGROUND TANKS
  There are a number of non-destructive testing (NDT) methods
available to test the integrity of the underground storage tank
walls" (Table 3). Most of these methods require  access to both
sides of the tank wall, but two methods can be performed with
access to only one side of the tank wall. These methods may be
able  to test in situ tanks if inside (or outside) access to the tank is
safe and available.

Ultrasonic Testing
  The first method is ultrasonic testing.4'6'13 This method is used
to inspect voids, cracks and non-metallic inclusions and to deter-
mine the thickness of the tank wall. Residual strains within the
tank wall  can be measured, although material anisotropy makes
this measurement difficult. This method requires  a smooth sur-
face, a couplant between the probe face and the  material being
tested, point by point testing and skilled personnel to run the test.
Both steel and FRP tanks can be tested in this manner.

Acoustic Emission Testing
  The second method  is the  acoustic emission test using stress
waves.4'36  When a  defect such as a crack within a tank wall ex-
tends within a metal or FRP storage tank, it generates stress waves
which can be detected. A tank is tested under a loading to deter-
mine the extent of defects in the wall.  The results can be inter-
preted in terms of rate of crack growth, the quality of material
and the potential of failure of the structure.
                                                           Table 3
                                      Comparison of Common Nondestructive Testing Methods
Method
Ultrasonics
Radiography
Eddy Currents
Visual -Optical
Liquid
Penetrant
Magnetic
Particles
Characteristics
Detected
Changes 1n acoustic
impedance caused by
cracks, nonbonds, In-
clusions, or Interfaces.
Changes immaterial
density from voids,
inclusions, material
variations; placement
of Internal parts.
Changes in electrical
conductivity or mag-
netic permeability
caused by material
variations, cracks,
voids, or inclusions.
Surface characteristics
such as finish,
scratches, cracks, or
color; strain In trans-
parent materials.
Surface openings doe
to cracks, porosity.
seams, or folds.
Leakage magnetic flux
caused by surface or
near-surface cracks,
voids, inclusions, ma-
terial or geometry
changes.
Advantages
Can penetrate thick
materials; excellent
for crack detection;
can be automated.
Can be used to Inspect
wide range of 'materials
and thicknesses; versa-
tile; film provides re-
cord of Inspection.
Readily automated;
node rate cost.
Often convenient; can
be automated.
Inexpensive, easy to
use, readily portable,
sensitive to small sur-
face flaws.
Inexpensive, sensitive
both to surface and
near-surface flaws.
Limitations
Normally requires
coupling either by
contact to surface
or immersion in a
fluid. Orientation
can present problems
In detection or Inter-
pretation of defect.
Radiation safety re-
quires precautions; ex-
pensive; detection of
cracks can be diffi-
cult.
Limited to electrically
conducting materials;
limited penetration
depth. Interpretation
of defect signals can
be difficult.
Can be applied only to
surfaces, through sur-
face openings, or to
transparent material .
Flaw must be open to
surface. Not useful
on porous materials.
Limited to ferromag-
netic material ; surface
preparation and post-
Inspection demagnetiza-
tion may be required.
Example of
Use
Adhesive as-
semblies for
bond Integrity.
Detection of
creeks.
Pipeline welds
for penetration.
Inclusions, voids.
Verification of
parts 1n assemb! les.
Heat exchanger
tubes for wall
thinning and cracks.
Verification of
material heat
treatment. /
Paper, wood, or
metal for surface
finish and uni-
formity.
Turbine blades
for surface
cracks or porosity.
Railroad wheels
for cracks.
Detection of
weld defects.
                                                                                     UNDERGROUND LEAKING TANKS    289

-------
  Non-destructive testing methods which require access to both
sides  of the  tank wall are:  radiographic inspection (i.e., x-
rays),4-'3'5 eddy-current techniques which can be performed on
electrical conducting tanks,4'13'8 liquid  penetrant  which  detects
cracks on the surface of tanks, magnetic particle testing which
detects surface or near surface cracks, voids, inclusions and ma-
terial or geometric changes in ferromagnetic material and visual
inspection. Visual inspection may be an inexpensive initial step of
tank integrity investigation. Internal  inspection of a tank, either
through direct access or by the use of mirrors, may give the first
clues to the condition of the tank.
  New methods which eventually will be used by the industry in-
clude lasers and holographic methods.7

CONCLUSIONS
  The construction of many chemical industries, gasoline stations
and other facilities storing hazardous materials in large quantities
led to the installation of thousands of underground storage tanks
during  the  period from  1950 to  1970  throughout the  United
States.  Many of these tanks have exceeded their useful lives and
either are leaking now or soon will be leaking. The RCRA-UST
regulations introduced by the U.S. EPA to protect human health
and the environment from contamination are summarized in this
paper. In addition,  various leak detection and monitoring tech-
niques to avoid  groundwater contamination also  have been re-
viewed.
  The details of codes and standards  for steel and fiberglass tanks
have been presented. However, most of these are consensus stan-
dards and may not ensure structural design adequacy for all antic-
ipated loading and operating conditions. It is necessary to analyze
and design these storage  tanks using proper analysis techniques
and procedures of state-of-the-art design practices.
  The most important design considerations also were discussed.
The design principles applied for large diameter buried pipelines
during the last decade provide additional useful information for
the designers of new  tanks. The new tanks should  be designed
with  appropriate leak detection and  secondary containments.
They should  further have provisions for testing the integrity in
place. Proper tank management and operation procedure are re-
quired to ensure long life for these potentially hazardous under-
ground storage structures.


REFERENCES
 1.  Antonenko, E.V.,  "Stress-Strain  Conditions of Cylindrical  Con-
    tainers Sunk Into the Ground," Chem.  and Pel. Eng.,  June  1969,
    8-9.
 2.  API Standard  620, "Recommended Rules for the Design of Large,
    Welded,  Low Pressure Storage Tanks,"  API,  New  York,  NY,
    1956.
 3.  ASTM D4021-81, "Standard  Specifications for Glass-Fiber-Rcin-
    forced Polyester Underground Storage  Tanks," Annual Book of
    ASTM Standards, Vol. 08.04, ASTM, Philadelphia, PA, 1983.
 4.  Berger, H., "Nondestructive Evaluation," Pressure  Vessel and Pip-
    ing Technology-1985-A Decade of Progress, 1985, 591-599.
 5.  Berger, H., "Radiographic Inspection," Pressure Vessel and Piping
    Technology-1985-A Decade of Progress, 1985,633-647.
 6.  Birchon,  D., "Non-Destructive Testing," For the Design Council,
    the British  Standard Institute, and the Council  of Engineering In-
    stitute, Oxford University Press, 1975.
 7.  Birnbaum,  G.  and White,  G.S.,  "Laser Generated and Detected
    Ultrasound and Holographic Methods," Pressure Vessel and Piping
    Technology- 1985-A Decade of Progress, 1985,661-669.
 8.  Deeds, W.E. and Dodd, C.V., "Eddy-Current Technique," Pressure
    Vessel and Piping Technology-1985-A Decade of Progress,  1985,
    647-659.
 9.  U.S. EPA, "Hazardous Waste Management Systems; Standards for
    Hazardous Waste Storage and Treatment Tank Systems," Proposed
    Rules, Federal Register, 50, June 26, 1985.
10.  U.S.  EPA, "Leaking Underground Storage Tanks,"  Document
    EPA/530-SW-009, U.S. EPA, Washington, DC, Apr. 1985.
11.  Fitzgerald, III,  J.H.,  "Corrosion of Underground Storage Tanks
    ... Causes and Cures, "Plant Eng., 37. July 21, 1983,46-48.
12.  Callctly, G.D. and Pemsing, K., "On Design Procedures for the
    Buckling of Cylinders Under Combined Axial Compression  and
    External Pressure," J. of Pressure Technot. 106, May 1984, 134-142.
13.  Green, Jr., R.E., "Ultrasonic Methods," Pressure Vessel and Pip-
    ing Technology-1985-A Decade of Progress. 1985,601-611.
14.  The Hazardous and Solid Waste Amendments of 1984 (To amend
    the Solid Waste Disposal Act), Jan. 23, 1984.
15.  Jcyapalan, J.K.,  Proc. of the  International Conference of Ad-
    vances in  Underground Pipeline Engineering, Madison, WI, Aug.
    1985.
16.  Jcyapalan, J.K.  and Ethiyajeevakaruna,  S.W..  "JFLOW-IBM
    P.C.  Software for Flownct Construction and  Groundwater Seep-
    age Analysis."  Report of the  Wisconsin Hazardous  Waste Man-
    agement Center, Jan. 1986.
17.  Jeyapalan, J.K.  and  Elhiyajcevakaruna,  S.W., "JSTRESS-IBM
    P.C.  Software for Calculating  Stresses Induced by Surface  Sur-
    charge Loads and Traffic  Loads on Tanks and Other Buried Struc-
    tures," Report  of the Wisconsin Hazardous Waste Management
    Center. Jan. 1986.
18.  Jeyapalan, J.K.  and  Ethiyajeevakaruna, S.W.,  "JSETTLE-IBM
    P.C. Software for Calculating Settlement of Tanks and Pipes Under
    Loads," Report  of the Wisconsin  Hazardous Waste Management
    Center, 1984.
19.  Jeyapalan, J.K. and Ethiyajeevakaruna, S.W., "JLONG-1BM P.C.
    Software for Calculating Longitudinal Stresses and Strains in Under-
    ground Tanks and Pipes,"  Report of the Wisconsin Hazardous
    Waste Management Center, Jan. 1986.
20.  Jcyapalan, J.K. and Ethiyajeevakaruna. S.W.,  "JLAMINA-IBM
    P.C. Software for Calculating Stress and Strains in Composite FRP
    Under Combined Loads," Report  of  the Hazardous  Waste Man-
    agement Center, Jan. 1986.
21.  Jeyapalan, J.K. and Ethiyajeevakaruna, S.W.. "JSS1P-1BM P.C.
    Software  for Performing Finite Element  Analysis of Soil-Tank-
    Pipe Interaction Effects," Report of the Wisconsin Hazardous Waste
    Center, Jan. 1986.
22.  Joor, "Plasleel Composite Double Wall Tank" Product Literature,
    Escondido, CA, 1985.
23.  Karp, R.R., Duffey, T.A. and Neal, T.R., 1983, "Response of Con-
    tainment Vessels to Explosive Blast Loading," J. of Pressure Vessel
    Techno!.. 205. Feb. 1983, 23-27.
24.  Kinsey. W.R., "Underground Pipeline Corrosion," Paper presented
    at ASCE National Water Resources Engineering Meeting, Jan. 1972.
25.  Knopp, P.V., "Inventory Reconciliation," Proc. Underground Stor-
    age Tank  Management Seminar, Department of Engineering Pro-
    fessional Development, University  of  Wisconsin,  Madison,  WI,
    Dec. 1985.
26.  Myers,  J.R., "Causes and  Cures of  Corrosion in Fuel Tanks,"
    Air Force Civil Eng.. 14. Aug. 1973.
27.  Myers, J.R., "Fundamentals and Forms of Corrosion," Proc. Leak-
    ing Underground Storage Tank Seminar, Department of Professional
    Development, University of Wisconsin, Madison, July 1985.
28.  NACE  Standard RP-01-69, "Recommended Practice,  Control of
    External Corrosion on Underground or Submerged Metallic Piping
    Systems," National Association of Corrosion Engineers, Houston,
    TX, 1969.
29.  NFPA 30-1984, "Flammable Burning Equipment," National Fire
    Code, /, NFPA, Quincy, MA, 1984.
30.  NFPA 31-1984,  "Oil  Burning  Equipment," National Fire Code,
    /, NFPA, Quincy, MA, 1984.
290    UNDERGROUND LEAKING TANKS

-------
31. NFPA Standards Book, Fire Protection Handbook, ISthed., NFPA,
   Quincy, MA, 1981.
32. Oliveira, D.P.  and Sitar, N.,  "Groundwater Contamination from
   Underground Storage Tanks, Santa Clara,  California," Paper pre-
   sented at National Symposium  on Aquifer Restoration and Ground
   Water Monitoring, Columbus, OH, May 1985.
33. Owens-Corning, "Fiberglass Double Wall Tank," Owens Corning
   Fiberglass Literature, Toledo, OH, 1985.
34. Pollulert, "FD 103 Fluid Detection  System" Product Literature,
   Pollulert, Indianapolis, IN, 1985.
35. Rosenvasser, G.R., Ol'Mezov,  V.I. and Sanzharov, Y.A., "Normal
   Pressures on Walls of Subterranean Structures," Soil Mechanics
   and Foundation Eng., 17, May-June 1980.
36. Spanner, Sr., J.C., "Acoustic  Emission," Pressure Vessel and Pip-
   ing Technology- 1985-A Decade of Progress, 1985, 613-632.
37.  Steel Tank Institute Fact Sheet,  Northbrook, IL, 1985.
38. Tessitore, J.L., "General Guideline for Underground Storage Tank
    Management Seminar,  Department  of Engineering  Professional
    Development, University of Wisconsin, Madison, Dec. 1985.
39. Total Containment, "TC-3000 Lake Detection System," Corporate
    Literature, Charlotte, NC, 1985.
40. UL 58,  "Standard for Steel Underground Tanks  for Flammable
    and Combustible Liquids," Underwriter Laboratories, Northbrook,
    IL, 1981.
41. UL 1316, "Standard  for Glass-Fiber-Reinforced  Plastic  Under-
    ground Storage Tanks  for Petroleum Products," Underwriter Lab-
    oratories, Northbrook,  IL, 1983.
42. Wilcox,  K., Flora, J.D., Haile, C. and Gabriel, M., "Variables in
    Tank Testing," Proc. Underground Tank Management Seminar, De-
    partment of  Engineering Professional Development, University of
    Wisconsin, Madison, Dec. 1985.
43. Wong,  F.M.G., Craft, W.J. and East, Jr., G.H.,  "Stresses  and
    Displacements in Vessels due to Loads Imposed by Single and Mul-
    tiple Piping Attachments," J. of Pressure Technol., 107, Feb. 1985,
    51-59.
44. Wood,  P.H. and Webster,  D.E.,  "Underground Storage  Tanks:
    Problems, Technology, and Trends," Pollut. Eng., 16,  July 1984,
    30-40.
                                                                                           UNDERGROUND LEAKING TANKS     291

-------
             Performance  Evaluation  of Commercial Hazardous
                          Waste  Treatment  Facility Operations

                                                Ronald J. Turner
                            Hazardous Waste Engineering Research Laboratory
                                   U.S. Environmental Protection Agency
                                                Cincinnati, Ohio
                                                 Joan V. Boegel
                                              Metcalf & Eddy, Inc.
                                            Woburn, Massachusetts
ABSTRACT
  A number of the management processes employed by commer-
cial hazardous waste treatment facilities were evaluated under a
U.S. EPA research program. This program and the results of pro-
cess monitoring at two facilities are discussed.

TEST PROGRAM BACKGROUND
AND OBJECTIVES
  In  support of  RCRA and  the Hazardous and Solid Waste
Amendments of 1984 (HSWA), the U.S. EPA Office of Research
and Development (ORD)  is  seeking information on  the  ap-
plicability, effectiveness, capacity, cost and environmental impact
of existing  hazardous waste treatment technologies  which are
alternatives  to land disposal.
  The general waste types included in this study are several which
were identified  for  priority  action inthe  HSWA  legislation:
solvents, cyanides, metals,  corrosives and halogenated organics.
For solvents, the HSWA states that, effective 24 months after the
date of enactment, further land disposal is prohibited unless the
U.S.  EPA determines that such prohibition is not required in
order to protect human health  and the environment. If the Agen-
cy fails to  meet this deadline, these wastes  will  be banned
automatically from further land disposal.
  The  HSWA  specifically addresses the spent solvents  listed
under F001, F002, F003, F004 and F005. Some examples of other
waste types which are candidates for  land disposal restrictions are
F006 through F012 (metals and cyanides), D002 (corrosives) and
K015,  KOI6 and K029 (halogenated organics).
  A wide variety of established treatment processes, combina-
tions of processes and waste  streams are being considered for
evaluation under this phase of the ORD program which involves
commercial  off-site hazardous waste treatment  facilities. There
will be emphasis on the chemical and physical treatment methods
including cyanide oxidation, chromate reduction, neutralization
of corrosive wastes, heavy  metal  precipitation, evaporation,
steam  stripping and various forms of solvent  distillation. In-
cineration and other thermal treatment processes and the  waste
categories for dioxins (F020 to F023) and PCBs are being investi-
gated by others and are not included in this discussion.

APPROACH
  The primary criteria used  to select commercial facilities for
evaluation under this program are:

• Ability to treat hazardous wastes scheduled to be  banned or
  restricted  from  land disposal
• Well run facilities employing proven technology that could be
  representative of best demonstrated available technology
  A number of sources were used to develop a list of candidate
facilities, including the following:
• 1985  Industrial  and Hazardous  Waste  Management Firms
  Directory
• RCRA Part B computer listing
• State agencies
• Trade associations
• Equipment vendors
• Conferences and seminars
  Once  identified, the candidate  facilities were contacted about
the waste types they treated and the treatment methods used; we
also attempted to ascertain whether their company would be in-
terested  in participating in the program. With the cooperation of
the companies, arrangements were made to visit each site and to
discuss testing of specific operations. Based on these visits, several
facilities were selected for one week of sampling and monitoring.
The results of the first two field  tests are the subject of this paper.

PROCESS EVALUATIONS
  The treatment processes and  waste types of interest at two of
the hazardous waste treatment  facilities are given in Table 1.
                         Table 1
          Waste Treatment Processes and Waste Types
Facility         Process

   A      Distillation


   8      Fuel Blending


   B      Alkaline Chlorination
         Aqueous Waste Treatment
           Lime Precipitation
         Pressure Filtration
           Carbon Adsorption
  Waste Type (RCRA Codes)

Organic Solvents
(F001. F002. F003, F005)

Organic Liquids and Sludges
(0001, F003)

Cyanidp Liquids and Sludges
(F007. F008. F009, F010,
 F011, F012 and F019)

Metal-laden and Organics
(DOOZ. D007)
  Both facilities accept and treat corrosives, metal-laden aqueous
wastes,  aqueous  cyanide  wastes,  halogenated  and  non-
halogenated  spent solvents. The waste treatment processes are
described briefly and analytical results are presented.
292   SITE MANAGEMENT

-------
 Batch Distillation
   As illustrated in Table 2, Facility A processed several types of
 waste solvents from one or more generators during the test pro-
 gram. Wastes containing less than 40% of the major solvent com-
 ponent are  not  accepted by  this  facility due  to unfavorable
 economics for reclamation. Facility A places an upper  limit on
 suspended solids  content of the waste solvents  of about 10 to
 15%. Solvent wastes with higher solids content may be accepted,
 but the generator would be charged a premium for disposal of the
 excess solids.

                            Table 2
       Generator's Manifest Data for Waste Solvents, Facility A
Day  Batch  Generator  Industry Type   Major Components

          Electronics
                    Waste Code
           Electronics

           Biotechnology Research

           Electronics
           Plating
           Specialty Chemical
            Manufacturer
           Motor Rebuilder
1,1,1  trichloroethane   F001
freon  113
isopropanol

isopropanol            D001

methylene chloride      F002

methyl ethyl ketone     F005
   Figure 1 is a simple flow diagram for the batch distillation pro-
 cess. The feed is charged to the still pot and steam, in an internal
 coil, is applied to heat the liquid to boiling. Vapors rising from the
 still  pot are condensed by cooling,  and collected. Figure 2 il-
 lustrates the fate of the waste solvents processed during the test
 period. The major limitation  on batch distillation was the  140 °C
 maximum temperature achievable due to the capacity of the site's
 steam boiler. The facility plans to install a vacuum system to over-
 come this limitation.
   Data on the still bottoms from four batches of waste solvents
 are presented in Table 3.  The gas chromatograph data for the
 F001 waste was discounted because of the large discrepancy be-
 tween the reported Freon 113 concentration of the bottoms, the
percent chlorine and the process conditions. The principal organic
components analysis for the second waste (D001) accounted for
only 36% of the total mass as isopropanol, xylene  and ethanol.
However, the organic analyses accounted for 98% of the F002
batch and 70% of the F005 batch.

Fuel Blending
  Organic  waste  blending operations  constitute about 40% of
Facility  B's  business.  Incoming wastes for  the  process  are
segregated according to chlorine and moisture content, ground to
particle sizes of less than 3 mm  and placed in  agitated storage
tanks. The  final blend is homogeneous, easily pumpable and
suitable for burning in  a liquid injection incinerator.  The high
chlorine waste blends (up to 45% chlorine and free of PCBs) are
used by a manufacturer of low alkali cement. The  low chlorine
fuel blends (less than 6% chlorine) are sold to operators of kilns
or furnaces that are permitted to store and burn  U.S. EPA-listed
hazardous wastes. Figure 3 depicts the organic waste blending
operation.
  Two batches of organic wastes were processed during the test
period. The first waste was a low chlorine content waste drawn by
vacuum from drums of paint sludges (waste  code D001). The se-
cond waste was a mixture of varnish, paints, alcohols and xylene
(D001 and F003). As a result of the grinding process,  the suspend-
ed solids content  of the  treated organic  wastes increased, the
viscosity improved and a homogeneous material was produced.
Table 4 presents the results of tests on the two fuel blends. Ap-
proximately 80%  of the low chlorine waste  included in the first
blend was pumpable. The remainder of the material was solidified
with lime and transported to a land disposal facility.
                               IN-LINE
                               SCREEN
                                 t
                               SOLIDS
                                          SPENT FILTER
                                           BAG WITH
                                            SOLIDS
                       SAMPLE LOCATION
                                                            Figure 1
                                          Flow Diagram/Sample Points for Batch Distillation
                                                                                                     SITE MANAGEMENT    293

-------
                                  WASTE SOLVENT
                                  1543 GALLONS
                                                                    80JGALLONS
                                                                        52%
                   PRODUCT SOLVENT
                   FOR SALE
 604 GALLONS
63 GALLONS

    4%

55 GALLONS

   Ti%
19 GALLONS <
   i~2%'
                                                             Figure 2
                                                       Fate of Waste Solvent
                                                                                     REDISTILL	





                                                                                     FUEL



                                                                                     SOLIDIFY FOR LANDFILL


                                                                                     WASTEWATER TREATMENT
                            Table 3
              Still Bottoms Characterization, Facility A
Parameter
Viscosity (P25 C)
Paint Filter Test
Density
COO
Total Solids
Total Volati le Solids
Total Suspended Solids
Total Vol Sus Solids
Total Vol Dis Solids
Total Dissolved Solids
Silica
Metals
Copper
Lead
Chromi urn
Silver
Iron
Nickel
POC
Acetone
Butanol
Iso-Butanol
Dloxane
Ethanol
Freon 113
Isopropanol
Methanol
Methylene Chloride
Methyl Ethyl Ketone
1 ,1,1-Trichloroethane
Toluene
P-xylene, H-Xylene
0-xylene
TOX
EP TOX
TCLP
% Carbon
% Hydrogen
* Hater
BTU Content
Symbols:
LT Less Than
GT Greater Than
NS = Not Sampled
ND = Not Detected
Units
cSt
--
g/ml
mg/l
t
% of TS
mg/ t
mg/l
mg/l
mg/l
wet

mg/kg
mg/kg
mg/kg
mg/kg
mg/kg
mg/kg

mg/l
mg/l
mg/l
mg/ 1
mg/l
mg/l
mg/l
mg/l
mg/ 1
mg/l
mg/l
mg/ 1
mg/l
mg/ 1
wU Cl


wt£
wt$
wt*
Btu/lb

Batch
Day 1
(F001)
4.56
Fail
0.952
I
71
100
6700
5600
560000
560000
NA

NA
NA
NA
NA
NA
NA

NO
ND
ND
150000
ND
ND
ND
ND
ND
ND
37000U
ND
ND
ND
8.85
X
X
73.33
11.82
0.04
15722

NM Nol
NA = Nol
1
X
1 Batch
Day 2
(0001)

Fail
0.789
1
10
100
14
12
100000
1 00000
NA

NA
NA
NA
NA
NA
NA

ND
ND
ND
ND
2100
NM
360000
ND
NO
ND
ND
ND
ND
10000
0.071
X
X
66.73
13.98
2.86
15244

Measured
1 Batch 1
Day 3
(FOO?)

Fail
0.866
1
0.63
82
170
160
4100
4800
LT 0.005

2.3
NS
0.096
LT 0.05
1.4
NS

1300
7500
640
4000
14000
NM
98000
230000
ND
370000
NM
11UOOO
3100
LT 500
1.07
X
X
57.81
11.41
7.13
12339


Applicable Under Ihc Circum
Batch 2
Day 3
(F005)

Fail
O.R5H
I
6.7
98
1400
860
66000
66000
0.01

2.6
NS
0.65
0.052
44
NS

LT 500
11000
LT 500
6400
34000
NM
56000
14000
NO
530000
NM
18000
23000
4300
1.11
X
X
52.29
11.48
13.79
11555


siunccs
Interference Prevented Quantilalion
- Analytical Results Arc Nol Yet Available
                                                                   Alkaline Chlorination
                                                                     Alkaline chlorination is a well-established technology for the
                                                                   destruction  of simple  aqueous  cyanide mixtures.  Typically,
                                                                   cyanide oxidation is achieved by raising the pH of the wastewater
                                                                   to  8.5-9.0 and adding chlorine. In practice, many of the spent
                                                                   metal cyanide compounds require additional amounts of time and
                                                                   chlorine to complete the conversion of the complex cyanides to
                                                                   cyanates or to carbon dioxide, nitrogen and water.
                                                                     At   Facility  B,   cyanide-containing  aqueous   wastes   are
                                                                   segregated and treated in a single-stage process. Sodium hydrox-
                                                                   ide is used for pH adjustment if necessary, and sodium hypo-
                                                                   chlorite is used as the source of chlorine. Wastes containing more
                                                                   than  4%  cyanide are diluted to this  level  before  treatment to
                                                                   minimize the temperature effects on the reinforced fiberglas reac-
                                                                   tion vessels. Following the reaction, the waste is mixed with other
                                                                   aqueous wastes for further treatment (described in next section).
                                                                    The cyanide wastes treated  during  the sampling program at
                                                                   Facility B included cyanide rinse waters (F007-F012) and cyanide
                                                                   sludges (FOI9). Table 5 presents the results of the analytical tests
                                                                   performed on  these wastes. Based on  the data obtained during
                                                                   this test, the alkaline chlorination process effluent concentrations
                                                                   were  less than  5 mg/l.

                                                                   Aqueous Waste Treatment
                                                                    The aqueous waste treatment system at Facility B is comprised
                                                                   of a number of major unit processes arranged in a series: pH ad-
                                                                   justment, chemical reduction, lime precipitation, pressure filtra-
                                                                   tion,  neutralization  and granular activated  carbon adsorption
                                                                   (Fig.  4).  The aqueous wastes  were  characterized as  D002.
                                                                   However, they originated from several generators and some had
                                                                   received some previous treatment within Facility B.
                                                                    The effluent from the alkaline chlorination process (75<%) and
                                                                   non-cyanide aqueous wastes received at the site (25^o) are pumped
                                                                   to equalization tanks. The blended wastewaters then are pumped
                                                                   to pH adjustment tanks  for the addition of waste acid to  pH 2.
                                                                   This  acidification serves to  break  some  metal-organic chelate
                                                                  complexes, but primarily introduces metal wastes for removal in
                                                                   the next process, lime addition and precipitation of metal hydrox-
                                                                  ides. The resulting hydroxide slurry is dewatered by a plate-and-
                                                                   frame filter press  to approximately 45% solids. The sludge filter
                                                                  cake is trucked off-site for land disposal.
294    SITE MANAGEMENT

-------
            SEGRAGATED
            ORGANIC WASTE
            MATERIAL




OARSE TRASH
RINDER PUMP
UMP

F
C
P




INE
RINDER
UMP
.
*
                                                                         Figure 3
                                                            Organic Waste Blending, Facility B
                                                                                                        SEGRAGATED
                                                                                                        ORGANIC WASTE
                                                                                                        BLEND/STORAGE
                                                                                                        TANKS
                                                                                                                                    TO FUEL
                                                                                                                                    OR CHLORINE
                                                                                                                                    SUBSTITUTE
                                                                                                                                    OUTLET
                                                                          Table 4
                                               Analytical Results for the Fuel Blending Process, Facility B
                              Sample Period One
  Toxic Ketals

  Cadmium
  Total Chromium
  Copper
  Lead
  Nickel
  Zinc

  Other Analysis

  Total Organic Halide
  Total Solids
  Total Volatile Solids
  Total Suspended Sol ids
  Total Dissolved Solids
  Total Volatile Suspended Solids
  Total Volatile Dissolved Solids
  EP Toxocity
  TCLP
  * Carbon
  % Hyoroyen
  BTU Content
  % Water
                                   mg/kg
                                   mg/kg
                                   mg/kg
                                   mg/kg
                                   mg/kg
                                   mg/kg
                                   weight %
                                   ppm
                                   ppm
                                   ppm
                                   PPm
                                   ppm
                                   ppm
                                   we i gh t %
                                   weight %
                                   BTU/Ib
                                   weight %
          NS
          NS
          NS
          NS
          NS
          NS
       0.074
      69,000
      58,000
      26.00U
      43,000
      21,000
      37,000
          NS
          NS
          NS
          NS
       2,472
          NS
           NS
           NS
           NS
           NS
           NS
           NS
       NS
       NS
       NS
       NS
       NS
       NS
0.26
130,000
110,000
46,000
84,000
37,000
73,000
NS
NS
NS
NS
786
NS
0.78
120,000
100,000
70,000
50,000
55,000
45,000
NS
NS
23.13
10.71
2,179
80.56
     NS
     NS
     NS
     NS
     NS
     NS
                                                                                                             Sample  Period  Two
Pollutant
Units
Low Cl?
Organic
Li quid
Composite
Influent
Blend
Treated
Fuel
Blend
Organic
Liquid
On
S'
Non-1
                                                                                          Organic
                                                                                           Sludge
       220
       390
     3,900
    36,000
        62
     1,31)0
                                                                                                         Organic
                                                                                                          SIudge
                                                                                                       Non-Puropable
2.32
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
NS
410,000
240,000
NS
NS
NS
NS
X
X
40.45
7.94
5,217
NS
         3,400
           260
         5,100
        70,000
           260
         8,500
                                                          NS
                                                     560,000
                                                     540,000
                                                          NS
                                                          NS
                                                          NS
                                                          NS
                                                            X
                                                            X
                                                        59.15
                                                        10.33
                                                       15,350
                                                          NS
                                                                               Organic
                                                                                Sludge
                                                                             Non-Pumpable
            5,000
              170
              510
            8,600
               31
              610
                                                           NS
                                                      530,000
                                                      260,000
                                                           NS
                                                           NS
                                                           NS
                                                           NS
                                                            X
                                                            X
                                                        40.75
                                                         6.94
                                                        8.443
                                                           NS
                                                                                  Organic
                                                                                   SI udge
                                                                                Non-Pumpable	
              30,000
               1,400
                 800
               5,900
                 650
              14,000
                                                                                 Treated
                                                                                   Fuel
                                                                                  Blend
                   NS
                   NS
                   NS
                   NS
                   NS
                   NS
NS
690,000
620,000
NS
NS
NS
NS
X
X
64.85
10.91
14,765
NS
0.79
390,000
350,000
330,000
60,000
280,000
70,000
NS
NS
58.17
10.15
11,601
11.14
  NS = Not Suspended
  X = Analytical Results Are Not Available Yet
                                                                          Table 5
                                  Analytical Results for the Cyanide Treatment Process at Facility B (F007-F012, F019)
                          Sample  Period One
                               Cyanide
                              Treatment
                              Influent
Po]J_utant	Units

Toxic  Metals

Cadmium               mg/1
Total  Chromium        mg/1
Copper               mg/1
Lead                  mg/l
Nickel                mg/1
Zinc                  mg/1

Other  Analysjj
Total Organic Carbon  mg/1       20,000
Total Organic Halide  weight %    0.30
Cyanide               mg/1        5.8UO
 Cyanide    Cyanide
Treatment Containing
Ef f 1 uent	51 udge
                                   45
                                  2.3
                                1,300
                                  2.8
                                  450
                                3,200
    3.5
     12
     42
    1.9
    6.2
  1,000
                                           5,700
                                            0.68
                                            LT 5
» 11,000
   I 180
I 34,000
    I 36
   * 750
   I 750
                  NS
                  NS
            I  96,000
  NS = Not Sampled
  I  = Interference
                                                  Sample Period Two

             Cyanide    Cyanide    Cyanide     Cyanide     Cyanide     Cyanide     Cyanide     Cyanide
            Treatment  Treatment  Containing  Containing  Containing  Containing  Containing  Containing
            Influent   Effluent     Sludge	Sludge      Sludge	Sludge  	Sludge	Sludge
  230
   24
6,200
   21
1,400
1,500
             20,000
              10.19
             11,000
                              #  = mg/kg
                              X  = Analytical Results Are Not Available Yet
 160
  19
,300
 8.5
 730
 920
          6,900
         LT  0.6
          LT  5
» 1,500
   * 54
  » 150
   * 67
  * 280
* 1,200
 I 1,300
I 14,000
* 15,000
 I 1,900
   I 490
» 13,000
    # 24
* 26,000
I 15,000
 0 8,500
   0 270
 I 4,700
  I 120
   * 73
  0 720
  f 130
* 1,300
I 9,700
 » 2,400
* 15,000
I 21,000
 I 2,600
   » 430
* 46,000
                                                                                                                                                  *  7
I 1
  t
  I
,200
 250
 600
,700
 200
 480
NS
NS
',000
NS
NS
1 9,000
NS
NS
» 8,000
NS
NS
» 1,900
NS
NS
* I
NS
NS
0 69,000
                                                                                                                           SITE MANAGEMENT    295

-------
               WASTE ACID STORAGE
                                                                                   VIRGIN
                                                                                HYDROCHLORIC
                                                                                 ACID TANK
   AQUEOUS WASTE
   RECEIVING TANKS
                                                      FILTER PRESS
                                                      SURGE TANKS
                          MULTI-MEDIA  CARSON
                          FILTRATION   ADSORPTION
                          TANKS       TANKS
                                                                                          OEWATERED SLUDGE
                                                                                          TO LANDFILL
                                                           Figure 4
                                                Aqueous Waste Treatment Facility
  Filtrate from the press is neutralized with hydrochloric acid and
passed through two multi-media filters in series followed by two
beds of granular activated carbon (9100 kg each) before discharg-
ing into the public sewer collection system. Facility B's effluent
discharge permit contains  limits on heavy  metals, chlorinated
compounds,  phenol and total organic carbon. Phenol  break-
through  is monitored as an  indicator of carbon exhaustion.
Breakthrough typically occurs after about 20 to 25 days of opera-
tion.
  The analytical results for the principal components found in 3
days of sampling the filtrate, filter press sludge and carbon col-
umn effluent are given  in Table 6. Heavy metal concentrations in
the final effluent  were  acceptable for discharge. The carbon col-
umns removed the organic compounds amenable to adsorption
(trichloroethane,  toluene,  total  xylenes  and   phenol),  but
moderately high  concentrations of acetone were present in the
GAC column effluent.  The TOC concentrations were reduced by
an average of 90°7o.
                                                           Table 6
                                     Analytical Results for Aqueous Waste Treatment, Facility B
Pollutants
Methylene Chloride
Acetone
Trichloroethane
Toluene
Chlorobenzene
Ethyl Benzene
Total Xylenes
Phenol
Cadmium
Total Chromium
Copper
Lead
Nickel
Z1nc
Cyanide
TOC
Units
ug/1
-ui/l
ug/1
ug/1
ug/l
«JL/'
ug/1
ug/1
mg/l
mg_/l
mg/l
-J59/1
pg/1
mg/l
mg/l
mg/l
Discharge
Permit
Limits
21,400
__
6,160
76S
765
__
..
6160
1.1
2.16
4.8
3.43
11.48
4.26
1.33
1500
Filtrate
220,000; 43.000;
130,000
68,000; 61,000;
69,000
4200; 2500;
1600
13,000; 7700;
3900
ND; ND; ND
NO; NO; ND
ND: 8,000: ND
19,000; 4.J60;
5100
1.2; 7.9; 50
2.1; 1.9; 0.7
160; 170; 380
1.4; 0.8; O.fi
2.2; 2.3; 22
24; 16; 46
NS
2500; 2400;
5000
Filter
Press
Sludge
ND; 61.000:
79.000
260,000:
NO; ND
GAC Effluent
ND; ND:
30,000
140,000; 160,00;
55,000
'400'. 000; '160. 006;""
110,000 ND; ND; 1600
1,400,000:
580,000; 290.000
15,000; 34.000;
11,000
110,000; 73,000;
55,000
57.000; 720,000;
300,000
ND; ND; NP
12,000; 6,700;
2900
	 rtT.W; 23,000;
2200
50,000; 43.000;
25,000
1.300: 79(1;
830
9,300: 6,400;
1400
35,000; 14,000;
4000
900; 400;
	 650 	
NS
ND; ND; ND
NO; ND; NO
ND; NO; NO
NO; ND; ND
ND; NO; ND
0.15; 1.5; 1.4
0.1; 0.12; 0.09
0.32; 0.9; 0.6
0.56; 0.7; 0.6
2.2; 2.0; 1.8
1.4; 1.6; 0.7
NS
IlrjuTTSOU
1400
296    SITE MANAGEMENT

-------
CONCLUSIONS
  The treatment technologies evaluated at Facility A or Facility B
were batch distillations, fuel blending and alkaline chlorination/
aqueous waste treatment.  If simple batch distillation is the sole
waste solvent treatment process, the recovered solvent must be ac-
ceptable for  use either as recycled to the process which originally
generated  the waste solvent or in some other application.  This
limits the types and concentrations of impurities that can be ac-
cepted in the influent and this limitation is specific to the end use.
  The waste segregation,  blending and grinding operation ap-
pears to be a practical approach to management of organic solids
such as  resins, latex, paint sludges and distillation bottoms for
ultimate disposal as a fuel or chlorine substitute suspension.
  Finally,  the  alkaline chlorination/aqueous  waste treatment
system was effective in treating cyanide and metal-laden wastes,
producing an effluent suitable for discharge to a publicly owned
treatment works.
  The data from these two facilities and other locations will pro-
vide process and residual  characterization information that will
contribute  to  the  determination of the adequacy  of available
treatment options.

DISCLAIMER
  Although the research described in this article has been funded
wholly or in part by the U.S. EPA, it has not been subjected to
Agency review and therefore does not necessarily reflect the views
of the Agency and no official endorsement should be inferred.
                                                                                                   SITE MANAGEMENT    297

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                           An Examination of  Siting Problems
                                          for Off-Site  TSDFs

                                             Douglas  B. Taylor, P.E.
                                               AeroVironment,  Inc.
                                               Monrovia, California
ABSTRACT
  The number of off-site Treatment Storage and Disposal Facili-
ties (TSDFs) in  the United States is decreasing. Because of the
social stigma associated with a facility which manages hazardous
waste and the high public visibility of an  off-site  facility, pro-
posed commercial TSDFs are finding it increasingly difficult to
get approval to operate. Meanwhile, several factors are working
to close currently existing facilities.  This decrease in  TSDFs is
going to lead to an increasing problem for waste generators—how
to manage their waste.
  The Solid and Hazardous Waste Management Committee of
the ASCE has been researching this problem over the last year. A
previous study confirmed that a decrease in sites has occurred in
the period 1980-1985. In addition, the revisions to RCRA have
forced many land disposal facilities to close and may have a sim-
ilar impact on other types of facilities in the next 3 years. Addi-
tional work has  been done to evaluate the reasons for the overall
decline. Specifically, a state survey is being conducted to identify:
(1) why  existing facilities have shut down during 1980-1986 and
(2) what  has caused the denial  of permits  for most of the pro-
posed new sites during the same period.

INTRODUCTION
  The siting of new off-site Treatment,  Storage and  Disposal
Facilities (TSDFs) for hazardous waste management has become
increasingly difficult over the past several years. In addition,  exist-
ing facilities across the country are feeling increased pressures to
cease operations.  Such  pressures are being exerted by various
organizations: local citizens  who fear the long- and  short-term
health effects of a TSDF in their town; regulatory groups who
identify  technical design or  operational problems which violate
existing regulations; and insurance brokers and company manage-
ment who see long-term financial risks.
  Off-site facilities are  defined in this paper as TSDFs which
accept waste from generators who pay the  facility to handle the
waste for them. Most clients of off-site  facilities are small gen-
erators for whom  a dedicated on-site TSDF is not  economically
feasible. In many cases, the clients include federal, state and local
governments. Because an off-site TSDF is a commercial enter-
prise, it is highly visible and thus subject to close public scrutiny.
Off-site  facilities that are hazardous waste landfills particularly
attract attention.
  Much of the opposition to off-site hazardous waste manage-
ment derives from poor public  relations. No number of logical
technical discussions can overcome past  horror stories. The mere
mention of any hazardous waste facility causes an immediate pub-
lic outcry in opposition.
  Many engineers and scientists who work in the hazardous waste
management field are concerned that the country will soon face a
crisis in the effective management of hazardous waste. All three
types of facilities are being affected: (1) treatment, (2) storage
and (3) disposal. Land disposal is being phased out out as a result
of the RCRA amendments passed in 1984 (however, off-site dis-
posal usually is considered as a cleanup method at every uncon-
trolled waste site).
  Treatment technology has not advanced  far enough so that:
(1) absolute destruction  of the waste can be  assured and (2) pro-
cess upsets will not occur. As a result, a release is possible and the
public does not want to take that chance in their towns.
  Storage  facilities for  hazardous waste are  only  a temporary
measure and do nothing to solve the real problem. Storage mere-
ly  serves as an intermediary step. Long-term  storage is nothing
more than aboveground landfilling before disposal or treatment.
As a result of these technical and public relations problems, it is
difficult to open or continue operation of an off-site TSDF.

PREVIOUS WORK
  The  Solid  and Hazardous Waste  Management Committee
(SHWMC) of the American Society of Civil Engineers has been
investigating the  problems of siting  off-site  TSDFs. A survey of
states was conducted from January through April of 1985  to de-
termine the status of new facility siting. In May of  1985 the results
of the  SHWMC survey were presented at  the Hazardous Ma-
terial Control Research Institute's (HMCRI)  Hazardous Waste
and Environmental Emergencies Conference.  That  paper, "The
Status  of Off-Site TSDF Siting," provided information  on the
then current number of TSDFs operating, the change since 1980
(RCRA implementation) and the success rates of  proposed facil-
ities.' The results of that survey are summarized below:

• As of May 1985, 566  off-site TSDFs operated in  this country.
  Approximately 50 of  these sites were disposal.  Ten states had
  no TSDFs; California had 133.
• A total  of  118 facilities were closed between November 1980
  and May 1985. (No reasons were given.)
• A total of 119 facilities were proposed in that same period.
• Of the 119 proposed TSDFs,  only 33 began operations (five
  disposal facilities).
• The  number of off-site TSDFs decreased by about 13% from
   1980 to  1985. In that  same period, only 28% of proposed sites
  have been approved.

  The  SHWMC study was done prior to the Nov. 8, 1985 dead-
line for land  disposal facilities to submit a Part B application.
That deadline has had  the impact of further  reducing the num-
298
       SITE MANAGEMENT

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                       Sites Which Existed
                       in November of 1980

                      RCRA Implementation
                            Add —
                       New Sites Approved
                      Nov 19X0 - Mar 1986
                                       Question: What about
                                       sites which were pro-
                                       posed but not approved?
                          Subtract —
                      Sites Closed Between
                      Nov 1980 - Nov 1985
                                       Question: What were
                                       the reasons for the
                                       closure of these sites?
                          Subtract —
                   Disposal Sites Closed Due to
                 RCRA Land Disposal Regulations
                           Nov 1985
                                       Question: What was the
                                       specific reason for
                                       closure of each site?
                        Existing Off-Site
                  Treatment Storage 4 Disposal
                           Facilities
                                       Question: How many more
                                       land disposal facilities
                                       will be closed before
                                       final pennit is issued?
                                       Also, how many other
                                       facilities will be closed
                                       by Part B calls in
                                       Nov 19S6 and 1988?
                         Original Number of
                       Land Disposal Facilities
Nov 8, 1985
         Subtract —
     Those Facilities Which
     Did Not Submit Part B
Application and Other Documents
Nov 8, 1985
   thru
Nov S, 1988
         Subtract —
   Those Facilities Which Are
      Later Found To Be
        in Violation of
 the Application They Submitted
      (During Inspection)
                                                                       By
                                                                   Nov 8, 1988
                           Subtract —
                     Those Facilities Which Are
                     Denied Their Final Permit
                   Ultimate Number of Facilities*
*Does not include facilities which
 open after 1985 or voluntarily close.


                            Figure 2
         Effects of Part B Deadline on Land Disposal Facilities
                           Figure 1
           Summary of Change in the Number of TSDFs
her of disposal facilities.  The specific impact of this deadline is
not yet known (Fig. 1). A certain number of facilities have not
submitted a Part B application and have stopped operation. Un-
doubtedly, some percentage of  those  who submitted certifica-
tions in November ultimately will be found to be out of com-
pliance. This decrease in  facilities only adds to the problems of
commercial sites still available for hazardous waste management
(throughout our work we do not discriminate "good" sites from
"bad" sites and we do not wish to imply that a  reduction in sites
is a bad change).
  The  problems  with  opening or  keeping open a TSDF apply
both on-site and off-site. However,  SHWMC  selected  to study
off-site facilities in particular because of  the direct impact off-
site TSDFs have on the majority of generators. Generators  who
use off-site facilities have very limited options  if their  TSDF is
closed.
  The  results of SHWMC's study are being used  as a basis for
further work. This will include an assessment of  the impact of the
land disposal permit deadline. Our followup study is described
below.
METHODS
  The followup study being conducted by the SHWMC is using
information provided by state contact people responsible for per-
mitting TSDFs. This list was provided by the U.S. EPA and has
been updated during previous contacts. The states will be asked to
provide information about  the  up-to-date  number of facilities
operating in each state and the problems TSDFs are experiencing.
The following questions will be asked:
• How many off-site TSDFs currently operate (accept waste) in
  your state?  If possible, break this number  down into treat-
  ment, storage and disposal.
• What were the reasons for the closure of off-site facilities which
  were reported in the  1985  survey? The reasons will be grouped
  into general categories: technical, financial, political, capacity.
• How many off-site disposal facilities did not submit their Part
  B application in November 1985? Do you suspect that more will
  be closed after permit review?
• What were the reasons for the rejection of off-site facilities
  which were reported in the 1985 survey?
  Written responses are being requested, and the responses will
be verified and/or clarified by telephone contact.
  After responses are received from each of the states, they will
be tabulated. The summary table will show the current number of
sites, the number of closed sites, the number of new sites and the
reasons for site closure and application rejection. The results of
                                                                                                      SITE MANAGEMENT    299

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 the state survey will be presented in the table just as they are pre-      a basis for establishing that the number of sites has been decreas-
 sented.  Only the responses related to the reasons will  be inter-      ing in the past 5 years. This survey will both update the informa-
 preted. As mentioned, this information will be grouped into cate-      tion generated  one year ago and explore more fully the reasons
 gories which best describe the specific situation at each site.            for this decline.
   The results of this followup survey are intended to provide in-
 formation to SHWMC and other interested members of the scien-      REFERENCES
 tific community on the current  status of TSDFs throughout the      ,  Tay,or  D c  .1Jhe Sta(us of off.SUe TSDF si(jng .. Proc  0/Hn
 United States and on the problems which are causing the recent        ardoM  Waste and Environmenlai  Emergencies Conference, Cin-
 decline in the number of facilities. The previous paper served as        cinnati. OH, May 1985, 95-97.
300   SITE MANAGEMENT

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              Spatial Data Research for  Hazardous  Waste Sites

                                             Timothy W. Foresman
                                   U.S. Environmental Protection Agency
                              Environmental Monitoring Systems Laboratory
                                               Las Vegas,  Nevada
                                             Lynn K. Fenstermaker
                        Lockheed Engineering  and Management Services Company
                                               Las Vegas,  Nevada
ABSTRACT
  Analytical and numerical models are used throughout the haz-
ardous  waste  site industry to  assist managers  investingating
groundwater conditions. An investigation based on geographic
information systems (GIS) was initiated in the San Gabriel Basin
in Los Angeles County, California. The objective of the pilot pro-
ject is to determine operational capabilities of a spatial-based sys-
tem to enhance management of the hazardous waste site data. An
initial goal of the research is to demonstrate feasibility of using
the GIS to run various groundwater flow and transport models. A
project  design  is presented which describes the  hazardous waste
spatial data research processes leading to input into two classes of
groundwater models. Anticipated strength of the GIS approach is
in the management of the spatial site data for multiple modeling
interfaces to offer increased  analytical options for the U.S. EPA
Site Offices.

INTRODUCTION
  Numerous analytical and numeric models are being used to
provide imput  for engineering and management decisions at haz-
ardous  waste sites. Groundwater models require  significant re-
sources to build  data  sets, often taking  months or years to
assemble. Resources in time and money once expended should
not require wasteful repetition due  to phase changes or manage-
ment adjustments of a site study. The ability to  switch  or choose
among different models is important to the success of a site eval-
uation.  However, the availability of data may curtail the use of
some models.  Efforts to satisfy the data requirements of mul-
tiple models easily can surpass the resources allocated for a site.
Geographic Information Systems  (GIS)  have  demonstrated
robustness and flexibility in natural resource applications over the
past few years. In particular, GISs permit maintenance of spatial
data sets and preparation of these data for multiple use analysis
programs.
  A research program was initiated by the U.S. EPA's Environ-
mental Monitoring Systems Laboratory (EMSL) in 1985 to assess
the utility of GIS technology in providing an interface  capability
between input data  and standard groundwater models for haz-
ardous  waste sites. The primary benefit to be gained for an en-
hanced  interface capability is the multidisciplary use of the mul-
tiple types of hazardous waste site data. Such a trend in capabili-
ties would provide cost sharing of data and enhance uses of the
data sets. To investigate these issues in a real world context, the
San Gabriel Basin Superfund site was selected for this pilot study.

SITE HISTORY
  The San Gabriel Groundwater Basin is comprised of approx-
imately 444 km2 (165 miles2) of groundwater bearing,  urbanized
                               LOS ANGELES COUNTY LINE _
                    OI020llll«i

                    0 10 20 30 Kllom«U

                  Approximate Sell*
                         Figure 1
    San Gabriel Basin Geographic Information System Pilot Study
land in east Los Angeles County (Fig. 1). Groundwater in this
basin is used extensively for public water supply with over 400
known public and private wells. Approximately 47 water pur-
veyors supply drinking water to over 400,000 residents in over 33
communities.' The geologic structure is composed primarily of
coarse alluvium lying along the southern base of the San Gabriel
Mountains; aptly described as a large "sand box." This area is al-
most completely urbanized.
  In 1979, the first  incident of groundwater contaminated by
chlorinated hydrocarbons was reported. A concentration of 1800
ug/1 trichloroethylene (TCE) was discovered in  the central por-
tion of the basin. The state and federal standard for safe drink-
ing water is  5  ug/1  TCE. Further sampling by the California
Department of Health Services revealed a widespread situation of
contaminated groundwater which included  unsafe levels of car-
bon tetrachloride (CTC) and perchloroethylne (PCE). The U.S.
                                                                                            SITE MANAGEMENT    301

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EPA became involved because of the toxicity of the contaminants
and the magnitude of resources required to mitigate and manage
this hazardous waste problem.1
  The San Gabriel Basin is atypical of CERCLA sites by virtue
of its geographic range. It is, in fact, a groundwater basin im-
pacted by numerous contaminant sources, some of which prob-
ably were originated decades ago by post World War  II indus-
tries.1 The complexity and size of this site demands the examina-
tion of approaches oriented toward large, spatial data base man-
agement systems. Spatial management tools with the flexibility to
potentially  interfere  with  existing groundwater  models  were
selected for examination in this study.

RESEARCH APPROACH
  An important value of managing hazardous waste site data us-
ing spatially-based information systems lies in  the organization
and storage of the disparate types of information or data. These
data are the essential descriptors of a site's physical,  chemical
and biological characteristics. By examining steps leading up to
the processing of groundwater models, other uses of these pro-
cessing capabilities for site operations should become evident.
  A flow diagram of the processing steps  for this project is pre-
sented in Figure 2. Most  technically mature CIS packages will
have  similar programming capabilities. This  research used  pro-
grams or algorithms developed for the ARC/INFO GIS  package
and will be noted  by parentheses in the  following  descriptive
text.4 The reader is referred to references5'7 for a more thorough
description of GIS components and capabilities.

DATA COLLECTION
   Data collection was based on a thorough review of existing data
from the San Gabriel area. Emphasis then was placed on defining
appropriate data to be used as source input to transport and flow
models. Use of transport and flow models was based on an assess-
ment of operational U.S. EPA and contractor practices.
DATA COLLECTION
• EXISTING MAPPED DATA
• EXISTING DIGITAL DATA
• EXISTING REPORT DATA

t
DATA ENTRY

CREATE MAP BASE
STANDARDIZE MAP DATA
PREPARE/DIGITIZE MAP DATA
PROCESS EXISTING DIGITAL DATA
EDIT COVERAGE/BUILD TOPOLOGY
ENTER ATTRIBUTE DATA
CREATE VERIFICATION PLOTS
t
DATA PROCESSING


• CONVERT MAP DATA TO UTM
• DEVELOP IRREGULAR POINT DATA MATRIX
• DEVELOP REGULAR GRID DATA MATRIX
t
HYDROLOGIC MODELLING
• FINITE ELEMENT (SUTRA)
• FINITE DIFFERENCE (MODFLOW)

                          Figure 2
                    Processing Flow Chart
  Additional data collection incorporated information necessary
to define: (1) the extent and characteristics of the aquifer; (2) the
extent of contamination by  various chemicals; (3)  spatial dis-
tribution of pumpage and  water levels over time; (4) hazardous
substance activities within a given area; and (5) population serv-
iced by water supply wells. Data were obtained from engineer-
ing contractors, local and  state water  agencies and several fed-
eral agencies.  To spatially  integrate all of the data sets into the
GIS, a  base map  at 1:62,500 scale was created. The data then
were entered  as either point, line  or  polygon (area) informa-
tion. Attribute data, such  as well water quality, were then re-
corded and referenced to a correlated point or area.

DATA ENTRY
  Data  entry of the  data sets required  the steps depicted in Fig-
ure 2. These steps were required to  establish and maintain qual-
ity  control standards for automating the data in terms of precis-
ion and accuracy consistent with National Mapping Standards.
Fifteen U.S. Geological Survey 7.5-min quadrangle maps were re-
quired for a base scale of 1:62,500. Standardizing the map data
entailed the precise integration of common  boundaries between
map themes such as  geology,  streams and soil using DIGITIZE.
This standardization eliminated the artificially created phenom-
enon of boundary slivers.  Preparation and  digitization of map
data required  the careful transfer of data from templates of ex-
isting mapped data,  such as potentiometric surfaces and annual
precipitation, into computer files with the use of digitizing tables.
Careful attention to ambiguities during this stage can eliminate
erroneous output in later site analysis. Existing digital data on
pumpage, water levels, chemical analysis and elevation data then
were integrated into the GIS (GENERATE).
  To remove numerous input errors, editing was performed and
all  data sets were attached to the proper spatial coordinates to
provide correct topologic structuring. All supporting file informa-
tion was entered to  these data sets (ADDITEM, DROPITEM,
JOINITEM). These  attribute data are descriptive files, such as
the chemical analysis of wellwater over time, which relate spatial
coordinates to data  base information. Displays then  were pro-
duced for the different information themes (for example, ground-
water boundary, population service areas, soil types and precip-
itation) to use in the determination of the accuracies of these ver-
ification plots.

DATA PROCESSING
  Once all the base map coverages and attribute data were coded
and verified, processing, analysis and creation of higher order or
derived information proceeded. The analytical processes required
to prepare data for hydrologic models are presented in Figure 3.
  Well locations were recorded in Universal  Transverse Mecator
(UTM) coordinates,  while other data sets were in units defined
by the digitizing process. To relate or match well information to
other data sets, a coordinate transformation algorithm was re-
quired (ARC TRANSFORM)
  The next analysis  step entailed the  linkage of water service
areas as defined  by  the water purveyors to specific  well loca-
tions and attribute data. This step allowed further correlation of
population data with water  service and site-specific well informa-
tion.
  The capability of the GIS  includes the manipulation of both
vector and raster (grid) data  formats. These formats  have spe-
cific limitations and uses in cartographic processing, storage and
retrieval. The reader  again is referred to references5"7 for detailed
information on uses of the two formats.
  A standard  grid spacing  and point of origin were required to
establish the location and relationship of cells in advanced spatial
processing stages. Grid spacing was designed at 0.25 mile cell size.
302    SITE MANAGEMENT

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r
R (LINE)
DATA

UTM
CONVERSION





I
WELL (POINT)
ATTRIBUTE
DATA
WAT
SERVI
AREA
                          Figure 3
          Groundwater Data Flow for Hydrologic Models

 The grid structure then was used to assign reference cells to both
 line and point data sets. Topographic data defined by elevation
 points were registered on this grid  structure. These grid registra-
 tion steps enable analysis of aquifer parameters, such as calculat-
 ing aquifer thickness and effective porosity. Pumpage rates could
 be assigned as aggregates within cells and used in further model-
 ing efforts. The  aquifer parameters  data sets  (e.g.,  hydraulic
 conductivity  and potentiometric  surface) were then  available
 through various GIS algorithms in both grid data matrix (GRID
 TOPO) and point data matrix formats (TIN and TIN GRID). At
 this stage of analysis, the hazardous waste site parameters could
 be  filed, reformatted if necessary and input to groundwater
 models.

 GROUNDWATER MODELING
  Testing the effectiveness of the GIS for support data input to
 groundwater models has to be completed. Two types of standard
 categories of models were selected for the modeling analysis:
 finite difference  (MODFLOW) and  finite element (SUTRA).
 Finite difference models use hydraulic parameters structured in a
 grid base format,  both regular grid and irregular grid. Finite ele-
 ment models use these same parameters but as discretely spaced
 points, as in the location  of wells in  the San Gabriel Basin.
  Application of algorithms for establishing gridded and discrete
 point networks are  major contributions of the GIS's  flexibility
 for model interfaces (GRID TOPO and TIN). These algorithms
 soon will be used to prepare irregular point data into finite ele-
 ment format to run the USGS. SUTRA groundwater  transport
 model.' The algorithms also will be used to prepare grid data for
 a finite difference format to run the USGS MODFLOW ground-
 water flow model.'

 DISCUSSION
  The use of a GIS provides potential improvements over conven-
 tional approaches in three general areas. These are: (1) data man-
agement and storage; (2) identification of site data spatial rela-
tionships; and (3) data  interface options for  models and users.
While these areas presently are difficult to quantitatively compare
in any  formal analysis, results of  user  oriented pilot  studies
demonstrate GIS strength for these  areas.10'12 The San Gabriel
Basin GIS demonstration should help focus  these strengths for
hazardous waste management. Operational use of GIS for haz-
ardous waste studies over the next few years  should provide the
necessary technology experience base to validate and quantify the
system's value to federal, state and private sector users.
  Central collection and spatial formatting of voluminous site
data is of high functional value to hazardous  waste site manage-
ment. A site can be probed and analyzed by various teams of
federal, state and contractor personnel and can experience major
changes in chemical or physical states. A spatial data manage-
ment system to handle dynamic inputs and facilitate the automa-
tion of analysis can save time for data aquisition, data analysis
and data update functions. These improvements also should have
significant economic benefits.
  Site data spatial relationships are important to proper environ-
mental assessments. The ability to correlate text information to
points, lines and areas of a hazardous waste  site is mandatory.
GISs are the only data base management systems built on a spatial
architecture which enables an automated  capability to perform
spatial assessments and proximity analyses. As a built-in  func-
tion, topology or spatial structure is  significantly better adapted
to toxic transport and fate issues than systems which must add on
such capabilities.
  Communication of site data to multiple users for multiple
analyses is a key aspect of efficient  site management. Final re-
sults of the pilot studies' hydrologic groundwater modeling inter-
face tasks should verify the design hypothesis that enhanced com-
munication amongst industry,  public and federal agencies  is de-
pendent upon  spatial data management. Capabilities of the GIS
could be used to develop internal groundwater modeling rou-
tines. However, the anticipated strength of the GIS is in the man-
agement of the spatial site data for multiple modeling interfaces,
thereby relieving the U.S. EPA Site Officers from restrictive ana-
lytical options.
  There always will be limits for many models in using parame-
ters and variables existing at a site.  This  limitation will not be
overcome  by  any  single  system.   However,  basic  hydraulic
parameters should be usable on a majority of industry approved
flow, transport and particle tracking models. This interface man-
agement ability in data  systems communications  is  within the
technical range of current state-of-the-practice GISs. The  U.S.
EPA's research effort will continue to assess the issue of range
and applicability of a GIS approach to hazardous waste site man-
agement.
REFERENCES
 1. California Department of Water Resources, "Planned Utilization of
   Groundwater Basin, San Gabriel Valley, Appendix A: Geohydrol-
   ogy," CDWR Bulletin, No. 104-2, Mar. 1966.
 2. Ecology and Environment, Inc., "Summary  of FIT Data Gather-
   ing Efforts and Source Investigation Workplan, Main  San Gabriel
   Basin,  Los Angeles County, California,"  TDD No. R-09-8303-1,
   Oct. 1983.
 3. Epstein, S.S.,  Brown, L.O. and Pope, C.,  Hazardous Waste in
   America, Sierra Club Book, San Francisco, CA, 1982, 593.
 4. E.S.R.I., "ARC/INFO  Users  Manual,"  Version  3.0 Redlands,
   CA, 1985.
 5. Clarke, K.E., "The Functional Capabilities of Geographic Informa-
   tion Systems," NASA, Ames  Research  Center, Ames, IA,  No.
   NCA2-OR 305-201, 1983.
                                                                                                   SITE MANAGEMENT    303

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  6. Dangermond, J., "A Classification of Software Components Com-
    monly Used  in  Geographic  Information Systems,"  Design  and
    Implementation of Computer-Based Geographic  Information  Sys-
    tems, Amherst, NY, IGU Commission on Geographical Data Sens-
    ing and Processing, 1983.
  7. Marble, D.F.  and  Peuquet, D.J., "Geographic  Information  Sys-
    tems and Remote Sensing," Chapter 22 in Manual of Remote Sens-
    ing,  Second Edition, American Society of Photogrammetry,  Falls
    Church, VA, 1984.
  8. Voss, C.I., "Saturated-Unsaturated Transport (SUTRA)," Water
    Resources Investigative Report 84-4369, U.S. Geological Survey,
    Washington, DC, 1984.
 9.  McDonald, M.G. and Harbaugh,  A.W., "Modular Groundwater
    Flow Model (MODFLOW)," Open File Report 83-875, U.S. Geo-
    logical Survey, Washington, DC, 1983.
10.  Marble,  D.F., Calkins,  H.W. and Peuquet, D.J.,  "Basic Read-
    ings In Geographic  Information Systems," SPAD Systems, Ltd.,
    Wiliiamsville, NY, 1984.
II.  Tomlinson, R.F. and Boyle, A.R., "The State of Development of
    Systems for Handling Natural Resources Inventory Data," Carlo-
    graphica, 18, No. 4, 1981, 55-69.
12.  Von Braun,  M.,  "Demonstration of  a Geographic Information
    System in the Analysis of a  Hazardous Waste Site,"  U.S. EPA-
    MERL, Cincinnati, OH, 1984.
304    SITE MANAGEMENT

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                         Sensitivity  Analysis of  Remedial  Action
                         Alternatives for Hazardous Waste  Sites

                                                Elio F. Arniella, P.E.
                                           Camp Dresser & McKee Inc.
                                              Hazardous Waste Group
                                                   Atlanta,  Georgia
                                           E. Lawrence  Adams, Jr., P.E.
                                           Camp Dresser & McKee Inc.
                                              Fort Lauderdale,  Florida
ABSTRACT
  This paper presents the sensitivity analysis methodology used in
the economic evaluation of remedial action alternatives at hazar-
dous waste sites. The authors base their presentation on actual ex-
perience  in  conducting sensitivity analyses in the economic
evaluation of alternatives for such sites. The paper recognizes that
in the  evaluation  of  remedial  action  alternatives,  certain
technologies have a larger degree of sensitivity than others and
establishes procedures for the evaluation of possible sensitivity
factors. The methodology gives decision-makers a range of unit
costs and statistically calculated levels of confidence associated
with each alternative.
  The objective of the costing exercise is to develop criteria for
obtaining a range of probable project costs. Once the range of
possible project costs is obtained, basic statistical principles are
incorporated to obtain levels of confidence of the cost estimates.
  The authors establish a baseline (present worth) cost for each
alternative,  including the following components:
  Mobilization and startup
  General site work
  Off-site hauling
  Contractor's labor, overhead and profit
  Equipment and materials
  Energy
  Monitoring and safety
  Legal,  license and permits
  Engineering and administrative costs
  Post-closure costs (present worth)
  Sensitivity factors for  each  of  the above categories  are
established and present worth costs are  calculated for each case
using a computer program. Combinations of sensitivity factors of
the principal cost component are added to establish the possible
project costs.
  A statistical analysis is incorporated to determine the baseline
price (mean) and other parameters, including the level of con-
fidence.

INTRODUCTION
  There is a degree of uncertainty in costs for remedial action
alternatives at hazardous waste sites. It is important to recognize
and evaluate this uncertainty in selecting the alternatives  on a
cost-effective basis.  This evaluation is  known as  a sensitivity
analysis.
  This paper presents  a methodology  for doing  a sensitivity
analysis.  The methodology  focuses on presenting the decision-
makers with a range of unit costs and statistically calculated levels
of confidence associated with «ach alternative.
  Factors basic to a sensitivity analysis, such as discount rate in a
present value analysis, are straight forward and are not discussed.
REASONS FOR SENSITIVITY ANALYSIS
  Not only is there a wide range of alternatives for remedial ac-
tion, but also within each alternative the actual costs may differ
significantly from the costs estimated in the feasibility study. Not
considering the potential difference in costs could result in the
selection of an alternative with actual costs more than estimated.
Moreover, the selected system could have ended up with a cost
higher than the actual costs of other alternatives even though their
estimated study costs were higher.
  The sensitivity analysis gives the decision-maker an opportunity
to judge the possible range of costs  for a certain alternative and to
decide whether to accept this range or select  another alternative,
with an upper range of costs less than the  first, but a greater
calculated "best estimate" cost.
  In doing the sensitivity analysis for an alternative, each cost
component must be carefully evaluated with respect to magnitude
and degree of certainty. A cost component with a high uncertain-
ty but with a very small range of possible costs compared to total
costs  may not need to undergo sensitivity analysis. Similarly, a
cost component with  a relative high proportionate cost of the
alternative may have little or no uncertainty and, hence, may not
need a sensitivity analysis.
  Examples of cost components and related  factors that may be
subject to a sensitivity analysis  are set forth below.

Project Schedule
  The actual project schedule can affect several items in the pro-
ject cost including:  energy, materials, resources and labor. An
early project finish may result in significant savings. However, a
late finish (due to weather delays, equipment malfunctions, unex-
pected  site problems,  etc.)  can increase  the project  cost
significantly.

Unexpected Site Complications
  Cleanup  of hazardous  waste  sites  containing buried  toxic
materials that have not been qualified or quantified in detail may
present unexpected project expenses or  savings during remedial
action implementation. For example, during a remedial investiga-
tion (RI)  phase at  a hazardous waste site, heavy metals are
detected with no documentation of waste disposal activities.  Elec-
tromagnetometer (EM) studies  reveal the presence of metals; in
addition, the  ground water  is  contaminated  with metals  and
volatile organics (VO). The remedial action  decision consists of
excavating the site, removing the metals andtreating the ground-
water. During-excavation, buried drums with unclassified solvents
are  unearthed. This situation will cause  additional expenses for:
monitoring and analysis, added  personnel safety equipment, time
delays and  an overall  increment in the excavation and disposal
costs."On the contrary, another possible  scenario may present no
complications and reduce the actual cost of excavation.
                                                                                                SITE MANAGEMENT   305

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Off-site Disposal
  There are only a few off-site RCRA-approved disposal facilities
in the continental United States. A cleanup remedy may consist of
disposal of hazardous wastes at a chemical landfill. Due to uncon-
trolled conditions, the facility planned for waste disposal may not
be available at the time of cleanup. This change in disposal plans
may result in hauling the material  to  another  facility located
several hundred miles further than originally planned. In addi-
tion, this new facility may have higher tipping fees, require new
transportation permits and demand  other disposal taxes which
may (depending on the  waste quantities and material to be dis-
posed of) increase the off-site disposal costs significantly.

Research and Development
  A feasibility study (FS) recommendation could  be based on the
satisfactory performance of pilot testing of waste treatment units.
The apparent preferred technology identified in the FS phase may
not prove  technically feasible when site-specific  conditions are
tested. Therefore,  another  option must  be evaluated  and re-
searched, resulting in a significant increase in the engineering, ad-
ministrative and capital  expenditures.

Legal Fees and Permits
  Unknown situations during implementation  of a remedy may
result in an increment of legal fees and permit application and ap-
proval  costs.  This condition  may affect  the  project  cost
significantly.

Post-closure Activities
  After implementation of a remedy, the post-closure monitoring
may be scheduled and budgeted for several years. However,  site
cleanup probably will exceed  the cleanup goals and, after consis-
tent verification, the site may be determined clean and require no
additional  monitoring. This positive development may result in
significant  savings  in  present  worth  costs  for post-closure
monitoring and analysis.
STATISTICAL ANALYSIS
  The sensitivity analysis  methodology  used in assessing  the
possible cost variations of  remedial action  alternatives uses  the
principles of the "Central Limit Theorem"  to calculate the con-
fidence limits that can be attributed to a range of probable project
costs. The "Central Limit Theorem," first  stated by Laplace in
1812', formulates that:
"For almost all populations the sampling distribution of
the mean derived from the  universe will be  approximately
normally distributed provided that  the associated sample
size is sufficiently large."2
  In other terms, this theorem states that if a random sample of
size n is drawn from a population with mean p. and  variance a2,
then as n  increases, the distribution of
                                        X - u
                                       ~~
                                             approaches  the
standard normal distribution.  It  has  been demonstrated em-
pirically2 that a sample size with 30 or more observations will be
"sufficiently large"  to  produce  an  approximately normally
distributed sample mean.
  Based on previous experience in performing sensitivity analyses
of remedial action alternatives, it is estimated that the number of
"what ifs" or uncertainties of different cost estimate components
may generate combinations and permutations of possible project
costs exceeding 30 or more probable cost products. Therefore,  it
is reasonable to presume that if the possible project costs may ex-
ceed 30 or more products, the analyst can evaluate the confidence
level of the data using the normal distribution equations. The nor-
                                                                  mal distribution formulas for unclassified (not grouped in cost
                                                                  class intervals) and classified data are presented below.
                                                                  Normal distribution formulas for unclassified data

                                                                                X  =   X/n                                  (1)
                                                                  and
                                                                                       1
                                                                                s -  [-    i. (X-X)  ]*
                                                                                       -
                                                                                                                           (2)
                                                                 where:
                                                                    X  = mean project cost or base cost
                                                                    X  = variable project cost obtained from  one or more pos-
                                                                         sible  variations of  cost components of the sampling
                                                                         population
                                                                   n   =  number of possible project costs (  30), and
                                                                    s   =  standard deviation

                                                                 Normal distribution formulas for classified data
                                                                    If the data have been classified into k classes,  then by defini-
                                                                 lion:
                                                                 where:
                                                                                        k                k
                                                                           Si    [-L  (  £   fi  XI - £  (  L   fi Xi)')]
                                                                                       1=0              1=0
                                                                   Si  = standard deviation for the classified data
                                                                   Xi  = the midpoint (class mark) of the ith class
                                                                    fi  = the number of observations in the ith class
                                                                   w  = incremental value of the class interval
                                                                    n  = the normal number of observations
                                                                                          I (fi Xi)
                                                                           Xi  - Xo + w  ('
                                                                                               fi
                                                                                                                          (4)
                                                                 where:
                                                                   Xi  =  the sample mean
                                                                   Xo =  value of the midpoint class mark at i = 0

                                                                 Confidence Limits
                                                                   The confidence limits of the confidence interval of unclassified
                                                                 or classified data evaluation are obtained as follows:
          xl 1 x 1
                                                                                         or
                                                                                                   X1
                                                                                                                          (5)
where:
  X and Xi are the unclassified and classified means, respectively,
         and s and si are the unclassified and classified standard
         deviation, respectively
  X,  =  lower confidence interval =  X -  zs or Xi -  zsi
  X;  =  upper confidence interval =  X  +  zs or Xi +  zsi
   z  =  one-half the area under the normal curve within a speci-
         fied confidence interval
  The value of z can be obtained from  integration of the area
under  the  normal curve or  from normal curve areas tables
available in most statistics books. Common z values used in the
sensitivity analysis  are shown in Table 1.

APPLICATION
  As previously discussed, the purpose of the sensitivity analysis
is  to  assess  the  effect  of  variations in  specific assumptions
associated with the cost estimates of remedial action alternatives.
The sensitivity analysis is specifically concerned with those factors
that could bring significant changes in the overall costs with only
a small variation  in  value.  In addition, factors  with  the most
uncertain values are chosen  for the analysis.
 306   SITE MANAGEMENT

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                             Table 1
        Normal Curve Areas for Certain Confidence Intervals
Confidence
Interval
(%)
95
90
50
30


z
1.960
1.645
0.675
0.385
Taken from Wide'


  An actual study of a hazardous waste site in Florida is used as
an  example to illustrate the  application of  sensitivity analysis
methodology. This study involved a site located over a sole source
drinking water aquifer. Heavy metals and PCBs were the basic
contaminants. Possible remedial alternatives included solidifica-
tion, solidification/stabilization, solidification/containment, par-
tial off-site hauling/stabilization/solidification, extraction/solidi-
fication, extraction/containment and incineration/solidification.
A sensitivity analysis example  performed  on the  incineration/
solidification alternative is presented in this paper.
  The preferred remedial action identified in the feasibility study
consists of incineration of about 2,400 yd3 of soils with 50 ppm or
higher of PCBs and solidification/stabilization of approximately
44,000 yd3 of soils with PCB concentrations below 50 ppm and
heavy metals.  Cost  estimates  for this  alternative include  the
following components.
• Mobilization and startup
• General site work
• Off-site hauling
• Contractor's labor, overhead and profit
• Equipment and materials
• Energy
• Monitoring and safety
• Legal, license and permits
• Engineering and administrative costs
• Post-closure costs (present worth)

  Once  the base costs  are estimated for each component,  the
analyst evaluated the assumptions made to establish the base costs
and asks  "what if"  the  presumed cost estimating conditions
                                                                 Table 2
                                         Possible Sensitivity Factors for Remedial Action Alternative




Sensitivity Factor
1.







PROJECT SCHEDULE
1.1 Early Finish
• Site Work
• Energy
* Labor
• Equipment
• Engineering 4 Admn.
• Monitoring 8 Safely

Probable Cost,
$1,000


821
12.2
800
1,100
6% a
283
Difference
from Base
$1,000


-341
-1.4
-500
-742
-4% a
-57


Justification for Cost


Unit cost of $9/yd' instead of $16.5 $/ydJ
Facilities used less than estimated
Work done with 60 percent of estimate
Less cost of rental equipment
No research needed; Pre-assembled equipment
Good post closure results
                            1.2  Late Finish

                                * Energy              18            +4.4
                                • Labor               1,396         +280
                                * Equipment           2,300         +458
                                « Engineering & Adirin.   17% a         +7% a
                                * Monitoring           200           +22
                                • Permits and Legal     13            +3

                        2.  SITE COPLICATIONS

                                • Site Work           2,000         +500
                                • Engineering & Admn.   17% a         +7% a
                                «Monitoring           500           +150
                                t Labor              .1,500         +200

                        3.  RESEARCH 8 DEVELOPMENT

                                t Engineering & Adm'n.   10% a         -0% a
                                * Engineering & Adm'n.   20% a         +10% a

                        4.  LEG9L FEES * PERMITS

                                »Legal               5% a          -5% a
                                • Permits and Legal     15% a         +5% a

                        5.  POST CLOSURE

                                • Monitoring           150           -108
                                                    258           0
                                                    458           +200
   Use 257,000 kwh @ $0.07
   Labor hours increased by 20%
   Higher cost for use of incinerator
   Extensive research and duplicated design
   20% more time at $l,000/week
   Extension of temporary permit
   Site excavation cost of $21.50 $/yd'
   Redesign based on actual site conditions
   Unexpected sources are discovered
   Additional cost due to unexpected situations
   No ccmplications during design
   Preferred alternative is not implanentable
   No need for litigation
   Litigation and unexpected permits
   5 years monitoring
   30 years monitoring
   30 years with more intensive monitoring
                           ) of capital cost
                                                                                                             SITE MANAGEMENT    307

-------
                            COST COMPONENTS
                       SUBJECT TO HIGHEST SENSITIVITY
                     A.  »lTt won*
                     B,  COMTRACTOM LAiOH AND Oaf
                     C. tOUIPMIMT 1 M«Tim»ll
                     0. MONfTOimO 1 I«HTY
                      E, ICO*!, LIClMtl »
                      .  INQINEtHlMO i AOMIMHTHATIV1
                      C. POlT-CLOiU*K COtTi
     •  PCftCCNT Of THf tUU OP A.I.C AND 0
     • • AMOUNT! M THOUSANDS UNIIM
        OTHCHWIM tPCCVKD
                           Figure I
          Cost Components Subject to Highest Sensitivity
change due to justifiable  reasons.  In addition, the lower  and
higher possible costs are established based on possible or expected
conditions. Table 2 summarizes the possible sensitivity  factors
established for the case study analysis. These possible sensitivity
factors are screened, and those that have the highest possibility of
influencing significant cost changes are selected for the analysis
(as shown in Fig. 1). In this particular case, it is determined  that
possible mobilization,  off-site hauling and energy cost variations
will not influence significant total  project cost variations (less
than 2% of the cost). The  remaining cost components, judged to
yield significant changes, are selected.
   This arrangement can product 210 cost permutations [n!/(n-r>!
or 7!/4!]. However,  this  analysis will generate many repeated
combinations  of  cost  products,  and for practical  purposes the
overall normal distribution parameters may not have significant
difference if  a smaller  sample  size  (larger  than  30) is used.
Therefore, the cost combination pattern shown in Table 3  was
used in this case study. This pattern  produced a sample size of 39
possible project costs summarized in Table 4.
   These data are evaluated by either the classified or unclassified
methods previously stated.
                             Table 4
       Possible Project Cosu for Remedial Action Alternatives
                                                                                          CoiU In Thouund Dollan
1.
2.
3.
4.
5.
6.
7.
8.
9.
10.
11.
12.
13.
6.515
9,264
3.748
6.716
7.238
7,498
7.701
8,319
8.589
7.115
7.356
7,905
7,433
14.
15.
16.
17.
18.
19.
20.
21.
22.
23.
24.
25.
26.
8,412
9.064
5.701
5.101
4.211
4.129
4,033
3.904
6.408
6.199
5.939
5.864
5,263
27.
28.
29.
30.
31.
32.
33.
34.
35.
36.
37.
38.
39.
4.486
5,040
5,595
6,419
6,660
7,247
8,068
4,040
4,105
4.814
5.107
6,727
7,672
RESULTS
  The 39 possible cost products were classified in seven $1 million
class intervals ranging from $3 to $9 million, as shown in Table 5,
and  the frequency  histogram  is  presented  in  Figure 2. The
calculated  mean and standard deviations for the classified cost
data are $6.37 million  and $1.59 million, respectively. Likewise,
the sample mean and standard deviations for the unclassified data
are $6.30 million and $1.58 million, respectively. The results of
the evaluation and pertinent statistical parameters are summar-
ized  in Table 6.
                            Table 5
                    Analysis of Classified Data


Clm lnt*rwl
3.000-4.000
4,001-5.03)
5,001-6.000
6.001-7.000
7.001-8.000
8,001-9 .ODD
9,001-10,03]
TDTHL

Clm
*«..« F
3.500
4. SOD
5.500
6.500
1.500
8.501
9.500
-

n fvtknil
rt*»jcnc? fiv^gny
2 O.OSJ
7 0.1795
a 0.2DS1
7 0.17«
9 O.O09
4 1.10%
2 0.0513
J. 1

Cxulitlw
frWTC>
0.051)
0.2JOB
O.U»
0.6154
0^462
0.9<87
i.can

»
tkvtlttcn
fr^ ItV
Origin
0
1
2
3
4
5
t
21


fIJCI
0
7
16
21
36
20
12
112


rut
0
7
32
a
144
10)
72
418
                                                               Table 3
                                             Project Cost Combinations Used in the Analysis

A
B
C
U
E
F
G
1 2
1 2
1 2
1 2
1 2
1 2
1 2
1 2
3 4
3 1
3 1
3 1
3 1
3 1
3 1
3 2
5
1
1
1
1
1
2
2
6
1
1
1
1
2
2
2
7 8
1 1
1 1
1 2
2 2
2 2
2 2
2 2
9 10 11
1 2 2
2 1 2
2 1 1
2 1 1
2 1 1
2 1 1
2 1 1
12
2
2
2
1
1
1
1
13
2
2
2
2
1
1
1
14 15
2 2
2 2
2 2
2 2
2 2
1 2
1 1
16 17
3 3
1 3
1 1
1 1
1 1
1 1
1 1
IB
3
3
3
1
1
1
1
19
3
3
3
3
1
1
1
20
3
3
3
3
3
1
1
21
3
3
3
3
3
3
1
22
1
1
1
1
1
3
3
23 24
1 1
1 1
1 1
1 1
1 3
3 3
3 3
25
1
1
1
3
3
3
3
26 27
1 1
1 3
3 3
3 3
3 3
3 3
3 3
28
2
3
3
3
3
3
3
29
2
2
3
3
3
3
3
3D
2
2
2
3
3
3
3
31
2
2
2
2
3
3
3
32
2
2
2
2
2
3
3
33
2
2
2
2
2
2
3
34
3
3
3
3
3
3
2
35
3
3
3
3
3
2
2
36
3
3
3
3
2
2
2
37
3
3
3
2
2
2
2
38
3
3
2
2
2
2
2
39
3
2
2
2
2
2
2
         Nolc Refer 10 Fig I for actual values of A. B, C'. D, L. I- and G
             Numbers 1 ihrough 39 arc probable projcxi cosis.
308    SITE MANAGEMENT

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         s
         o
         o
         2
                             PROBABLE COST
                          ($ AMIS. IN MILLIONS)

                             Figure 2
                Histogram of Probable Project Costs
                                                                                                   Table 6
                                                                              Summary of Results for Economic Sensitivity Analysis
                                                                                        of Remedial Action Alternatives
                                                                      Statistical
                                                                      Parameters
                            Values for
                          Classified Data
    Values for
Unclassified Data
                                                                      Mean                            6.37
                                                                      Standard Deviation              1.59
                                                                      Coefficient of Variance"         0.25C

                                                                      Confidence Intervals
                                                      6.30
                                                      1.58
                                                      0.25°
-90%
+90*
-50%
+50%
3.74
9.00
5.30
7.45
3.70
8.90
5.23
7.37
                                                                      a In millions of dollars unless specified otherwise.
                                                                      b Coefficient of variance is defined as the ratio of the standard deviation(s) over the
                                                                        population mean (x).
                                                                      c Unitless.
CONCLUSIONS
  The alternative of incineration-solidification/stabilization of a
hazardous waste site shows that there is a place in the decision-
making process for sensitivity analysis of remedial action alter-
natives.
  The economic impact of various cleanup methods can be com-
pared in terms of levels of confidence of cost estimates using this
methodology.  By establishing possible variations  of cost com-
ponents for each alternative, the analyst can obtain a range  of
probable overall project costs. This range of project costs can  be
statistically analyzed to determine levels of confidence associated
with each alternative. The end results show that the apparent low-
est cost alternative may not necessarily be the one  with the least
economic risk.
REFERENCES
1.  Laplace, P.S.,  Theorie Analytique des Probabilities, 1st ed., Paris,
   1812.
2.  Parsons,  R.,  Statistical Analysis: A  Decision-Making Approach,
   Harper & Row Publishers, New York, NY, 1974.
3.  Camp Dresser  & McKee Inc., "Draft Feasibility Study Report for
   the Pepper's Steel and Alloys Site in Medley, Florida," Sept. 1985.
4.  Wine, R.L., Statistics for Scientists and Engineers, Prentice-Hall,
   Inc., Englewood Cliffs, NJ,  1964.
                                                                                                          SITE MANAGEMENT    309

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                     Design  of  a  Lateral  and  Vertical  Expansion
                            at an Existing  Interim  Status Landfill

                                                 Rodney T. Bloese
                                              Thomas G. Ryan, P.E.
                                        Foth & Van Dyke Industrial, Inc.
                                               Green Bay, Wisconsin
ABSTRACT
  The  Hazardous  and  Solid  Waste  Amendments  of  1984
(HSWA) have resulted in changes to the U.S. EPA's existing
hazardous  waste management program. Final rules  have im-
pacted lateral and vertical expansions of existing interim status
landfills. According to HSWA, the landfill expansion area must
comply with  minimum technological requirements of  RCRA
even if the facility no longer accepts or intends to accept haz-
ardous waste. An exception to the minimum technological re-
quirements would be possible if the expansion area were con-
structed and maintained as a separate and discrete  unit.  Within
the framework of the new rules,  proposed  remedial  work and
horizontal and vertical expansion at an existing zone of  satura-
tion interim status landfill site have been complicated.
  Control of seepage from in-place hazardous and solid waste
utilizing a groundwater containment structure was mandated by
the state regulatory agency (Wisconsin Department of Natural
Resources) as part of the existing  solid  waste landfill permit. A
program was developed and implemented to generate informa-
tion regarding containment design criteria and to define the pres-
ence of leachate at the site perimeter as well as the off-site migra-
tion potential of the leachate. The recommended design also is
impacted  by the HSWA; the potential exists that the  recom-
mended  containment structure meets  minimum  technological
RCRA requirements.
  The  proposed vertical and horizontal expansion design options
may have to be modified due to required separation of the exist-
ing hazardous waste unit from the  proposed solid waste  landfill
unit unless costly minimum technology RCRA designs, such as
double liner and separate leachate collection systems, are pro-
posed.  The design is further complicated by the lack of guidance
from the U.S. EPA as to what is an acceptable design for  separa-
tion of solid and hazardous waste units.

INTRODUCTION
  The  desire of  the  site operator was  to obtain a preliminary
indication from the state  regulatory agency as  to  the  potential
suitability of a lateral and vertical expansion to this existing in-
terim status landfill. The site operator desires an expansion that
will maximize refuse volume while producing final grades which
will conform  with the intended final use. In addition,  a con-
dition of the existing landfill operation  permit requires the con-
struction of a groundwater containment structure along two sides
of the existing site.
  Recent state and federal statutes have impacted the  design of
landfill expansions by limiting or complicating design options.
Presently, state statutes and guidelines are being revised.
  According to the U.S. EPA', a lateral expansion to an exist-
ing  interim status landfill must comply with the double liner and
leachate collection requirements. However,  this rule may only
apply to sites that continue to receive hazardous wastes.
SITE HISTORY
  The southwest portion of the existing landfill site (Fig. 1) was
used as a municipal dump in the early 1970s. Foundry sand and
municipal wastes fill this approximately 10-acre area. There are
no documented base grades  or leachate collection systems. Ac-
cording to a local contractor, a clay cutoff wall was constructed
along the western edge of the site. However, based upon incom-
plete construction documentation, the cutoff wall apparently did
not extend through a shallow sand seam.'
  The facility commenced operations as a sanitary landfill in the
mid-1970s. Four areas  were filled in a sequential manner. How-
ever, corridor 3 was constructed between corridors 1 and 2 by
excavating until the collapse of corridor 1 and 2 sidewalls pre-
cluded  further digging. These three corridors were constructed
without leachate collection systems and documented base grades.
Corridor 4 was excavated to a greater depth than the earlier dispo-
sal areas. Documentation of ultimate base grades or liner con-
struction was not performed. Installation  of a partial leachate
collection system was undertaken, but the system did not extend
to the base of corridor 4, and construction of the system was only
partially documented.'
  Corridor 5  was overexcavated by 5 to 10 ft. This excavation
resulted in backfilling the corridor with clay up to the approved
base grade. Documentation of the recompacted clay base and the
installation of the leachate collection system was performed.1
  The  area  between  the old municipal site and corridors  1
through 4 has been partially  filled with primarily foundry waste.
Again, the  base grade was not documented nor was a leachate
collection system installed.-'
                         Figure 1
                  Plan View Map of Landfill
310    RCRA SITE REMEDIATION & EXPANSION

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  Presently, corridor 6 has been constructed with  documented
base grades, 5 ft of documented compacted clay liner and a leach-
ate collection system. Approved for filling this corridor with solid
waste has been received from the state regulatory agency.
  The  site  operator was  licensed by the Wisconsin Department
of Natural Resources  (DNR)  to  receive hazardous waste from
1975 through 1982. On Nov. 19, 1980, Part A of the RCRA haz-
ardous waste facility permitting process was submitted to the U.S.
EPA. As a  result of submitting Part A and the Preliminary Notif-
ication on Aug. 18, 1980, the site received  "Interim Status" and
was allowed by the U.S. EPA to continue to accept hazardous
wastes. Since Nov. 19, 1980, various types of hazardous wastes
have been disposed with municipal solid waste in corridors 3 and
4. The hazardous wastes which have been  approved for receipt
and disposal under the federal Interim Status requirements in-
clude spent halogenated solvents, spent non-halogenated solvents
and spent plating bath solutions and wastewater treatment plant
sludges from electroplating operations.3 Hazardous wastes have
not been accepted at the site since Jan. 1,1983.

SITE GEOLOGY
  The  positions of the various strata  in the subsurface strati-
graphy are  illustrated in the generalized geologic cross-section in
Figure 2. The  strata are  comprised  of till  and proglacial fluvial
and lacustrine sediments of the Oak Creek Formation.4
  The  existing landfill and the  proposed expansion  area  are
located in  front of and  on the distal  slope  of the inner Lake
Border moraine. The moraine represents a  standstill position of
the ice margin. During glaciation, drainage to the  east was
blocked by the ice and  the north-south trending morainal  de-
posits and produced glacial ponding. These sedimentary units are
more likely to be continuous  parallel to the  former ice margin
(north-south orientation) rather than in an east-west direction.
The western part of the site area is dominated by lacustrine and
fluvial sediments while glacial and ice-marginal deposits are more
dominant in the eastern part of the site.4
  Redisposition of till and sorted sediment by mass-flow pro-
cesses is common in ice-marginal environments, and some of the
sediments  in the geologic section at the site probably resulted
from mass-flow.  Mass-flow at a ponded  ice-margin would re-
sult in mass-flow deposits interbedded  with fluvial or lacustrine
sediment.4  Because of the variety of processes involved in  the
deposition  of  sediments  at the site area,  the general geologic
cross-section (Fig. 2) may not be indicative  of true conditions
(i.e., the layers are probably not as interconnected or laterally
extensive).
                    EXIST  GROUND
                                  UNIT 6_	- - ~

                               UNIT 7
                          Figure 2
         Typical Geologic Cross-Section of Landfill Area
  The upper unit is composed of till. The lower units appear to
consist primarily of proglacial fluvial and/or lacustrine materials
with the exceptions of units 3 and 7, which may be in part till, and
unit 5, which may be a mass-flow deposit."
  Based  upon regional  data and nearby  water supply  well
records, the bedrock is at a depth of approximately 150 ft and is
composed of Silurian dolomite at the bedrock surface."
  In summary, the soils  beneath the site  are layered and non-
homogeneous. The geologic environment  is quite complex and
needs to be defined in greater detail.

SITE HYDROGEOLOGY
  The top of the zone of saturation (water table) exists generally
between 3 and 10 ft below the ground surface. The general trend
of groundwater flow is  toward the west, although the  water table
has been distorted by excavation and filling  within the  existing
site. The excavation within the present site has created a depres-
sion in the water  table  and an inward gradient toward the exca-
vation. However, along the south side and southwest corner  of
the  existing site, there is some question as to whether these inward
gradients are being  maintained due to possible leachate mound-
ing  within the filled areas.
  The shallow groundwater aquifers do not appear to be inter-
connected. The hydraulic conductivity  of the most shallow silt
and sand zone (unit 2) has a horizontal permeability range  of
several orders of magnitude (10~3 to 10~6 cm/sec). The grain size,
as measured by P2000 values, varies between 17  and  97%.4 The
fourth and sixth units also exhibit similar grain size and horizon-
tal permeability variations.

CONTAINMENT STRUCTURE
  As indicated previously in this paper, the NDR is requiring the
landfill owner to design and  construct a containment structure
around the south and west sides of the existing landfill site. The
purpose for requiring the containment structure is to ensure that
inward groundwater gradients are maintained into the landfill site
area. This design  will be intended to prevent the  outward migra-
tion of any contaminated water from the documented base areas
of the site.
  Three design options were developed for consideration by the
landfill owner for construction of the containment structure. The
first design  option  included the excavation of a trench  to con-
struct a soil/bentonite  slurry  wall. As part of the  design of the
slurry wall, the appropriate mixture of native soils and commer-
cially available bentonite and the compatibility of the soil/ben-
tonite slurry wall to leachate-contaminated groundwater would
be  determined. The leachate compatibility and soil/bentonite
mixture specifications would be determined in a series of labora-
tory tests and also would be based on the experience  of the geo-
technical contractor in similar applications. This option would in-
clude, in addition  to  the soil/bentonite slurry  wall, a second
trench constructed on the landfill side of the slurry wall to con-
tain a perforated groundwater  collection  pipe, which the state
regulatory agency requires to be installed. A  possible restriction
with this design is the sidewall stability of a narrow trench exca-
vated to a depth  of approximately 45 ft.  The possibility would
exist for the collapse of sidewall soils into the trench because of
high groundwater conditions  and layers of sandy and silty soils.
This  option would require all  pipe placement, bedding place-
ment and backfill to be accomplished by the contractor from the
ground surface.
  The second design option recommended a partial excavation
using scrapers  along the slurry wall followed by construction of a
soil/bentonite slurry wall and gravel filled trench similar to Op-
tion 1. The advantage of excavation along the containment struc-
                                                                              RCRA SITE REMEDIATION & EXPANSION    311

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                                                       OPTION  NO. 3
                                             EXCAVATION  WITH  PIPE PLACEMENT  AT  BASE
      POWER UNI
                                                           Figure 3
                                              Design Option—Containment Structure
ture to provide a workable base area for the slurry wall and pipe
trenching contractor would be to reduce the total depth of slurry
wall and trench excavation required. This design concept would
include the placement of a synthetic flexible membrane liner and/
or clay liner along the outward slope of the scraper excavation to
ensure that groundwater flow from the landfill would be inter-
cepted by the containment structure and routed to the collection
pipe.  The remainder of the excavated area would be filled with
earth  material or with approved solid waste to the original ground
surface.
  The third design option includes scraper excavation along the
containment structure extending to the design depth to install the
perforated  groundwater collection pipe. A cross-section view of
this option  is shown in Figure 3. The excavation would be an aver-
age of 45 ft deep over the 3700-ft  long containment structure.
Similar to option 2, a flexible synthetic liner or clay liner would
be constructed along the outward slope of the excavation to pro-
vide a low permeability barrier to seepage from the landfill area.
The landfill owner desires that the air space created by soil exca-
vation along the containment structure be approved  for filling
with solid  waste materials. In addition, solid wastes would  be
filled  above existing ground surface over this area, which would
result in a modified final grade for the landfill.
  The design  concept  of a refuse filled containment  structure
would result in revenue to the landfill  operator due  to the in-
creased waste  disposal  capacity  provided by the containment
structure and would modify the final side slopes on the south and
west sides of the site from an approximate 2:1 slope to a  final
slope  of 4:1. The landfill owner presently is under administra-
tive orders by  the DNR to modify the south and west slopes.
Therefore,  option 3  would provide a solution to issues associated
with the present 2:1  slope along the borders of the site and would
provide additional refuse fill capacity for the landfill owner. After
evaluating the advantages and disadvantages of each option, the
landfill owner has decided to prepare detailed plans and specifica-
tions for option 3 and to conduct the DNR relative to approval of
this design concept for the containment structure.
  The issue of minimum technical  compliance with hazardous
waste regulations for a  vertical and horizontal  landfill expansion
also will be addressed relative to  the proposed design of the con-
tainment structure. It is possible that the NDR may determine
that the proposed containment structure constitutes a lateral ex-
pansion to a hazardous waste landfill. The NDR also may deter-
mine  that previously  filled hazardous waste areas,  due to the
nature of closure and  lack of documented base areas or leachate
collection systems, do not constitute a separate and discrete haz-
ardous waste unit. If such a determination is made, it is possible
that the landfill owner may be required to comply with the min-
imum technology standards for a hazardous waste landfill for the
containment  structure area. This decision would require that a
double liner, equal to or equivalent with guidelines promulgated
in the HSWA, be compiled with for the design of the containment
structure. If this determination  is made, approval for the con-
tainment structure design would have to be obtained from the
hazardous waste section  of DNR as well as the U.S. EPA. In
addition, it is probably that the DNR will require the landfill own-
er to prepare the necessary feasibility reports, engineering plans
and specifications  for the landfill licensing process for the con-
tainment structure. In the State of Wisconsin, the landfill regula-
tory process can take from 3 to 5 years to complete. The land-
fill owner intends to prepare the necessary feasibility reports and
engineering plans to fulfill state licensing requirements for an ex-
pansion to an existing landfill site.

SITE EXPANSION
  Initial DNR reaction' to the  lateral solid waste site expansion
centered around the issue of separation of solid and hazardous
waste units. According to the State of Wisconsin regulatory agen-
cy interpretation, the  proposed lateral expansion (solid waste dis-
posal) must be physically and hydraulically separated from the
existing hazardous waste  unit.  Hydraulic separation  is required
due to the U.S.  EPA mixture rule which specifies that all leach-
ate from the existing site  would be considered hazardous. There-
fore,  a separate leachate collection  system  is recommended by
DNR for both the vertical and lateral expansion areas.
  There are six corridors remaining to be constructed and filled
in the existing landfill. A determination is needed as to whether or
not these corridors are considered to be part of the hazardous
waste unit under the HSWA. The remaining corridors have DNR
solid waste approval but have not been reviewed by the hazardous
312    RCRA SITE REMEDIATION & EXPANSION

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waste permit section. It was suggested by DNR that a clay wall of
"scraper width"  may be needed for physical separation of the
solid and hazardous waste units. However, redesign  of the re-
maining corridors within the existing permitted landfill area may
be required by DNR.
  A second possible alternative  was suggested by DNR—delist-
ing the site as  a hazardous waste unit. This procedure would in-
volve obtaining certification from the U.S. EPA that the haz-
ardous wastes  accepted at the site from 1975 through 1982 should
not have been characterized as  hazardous. Based  on the  waste
types disposed at the site, it is  unlikely that the recommended
certification could be made.
  Since the  DNR is not fully authorized under RCRA, the U.S.
EPA must determine what part(s) of the existing landfill  is the
hazardous waste  unit and what engineering  design options are
recommended to satisfy the separate and discrete unit issue.
  According to U.S. EPA guidance,1'6 a new unit or  lateral ex-
pansion of an existing unit operating under interim status may
continue to receive non-hazardous wastes without complying with
the minimum technological RCRA requirements. Apparently, the
minimum technological  RCRA  requirements  apply to  those
interim status  landfills that receive  hazardous wastes  after May
8, 1986.' In regard to placing waste over a partially or finally cap-
ped hazardous waste unit without complying with minimum tech-
nological RCRA requirements, the guidance6  suggests  that if the
new waste is effectively isolated from the waste within the cap-
ped unit, the new waste area will be considered as a new unit. In
addition, the U.S. EPA is concerned with closure  of  hazardous
waste units that no  longer accept hazardous wastes. Solid  waste
disposal over such a closed unit  would constitute a modification
of the closure  plan and would require U.S. EPA review and ap-
proval.
CONCLUSIONS
  A solid waste landfill adjacent to and over an existing hazard-
ous waste   landfill can  be engineered in an  environmentally
sound manner. A containment structure can be  designed to pro-
vide environmental protection along an existing  hazardous waste
unit and also be a source of revenue to the landfill owner.
  The U.S.  EPA and NDR must determine the applicability of
minimum technological RCRA requirements to solid waste land-
fill  expansions at interim  status  landfill facilities. Until  this de-
termination  is made,  it will be  difficult and perhaps costly to
develop acceptable design concepts.
  The containment structure design issue also is complicated by
the recent HSWA due to possible limitations on design concepts.
  Environmentally sound designs presently are available for land-
fill expansions and containment structures. However, compliance
with the recent HSWA may be expensive.

REFERENCES
1. U.S. EPA, "Hazardous Waste Management System; Final Codifica-
  tion Rule," Federal Register, 50, July 15, 1985, 28705-28711.
2. Wisconsin Department of Natural  Resources, "Determination  and
  Conditional Approval for a Plan of Operation Land Reclamation
  Sanitary Landfill," Dec. 1984.
3. Residuals Management Technology, "Feasibility/In-field Conditions
  Report Land Reclamation  Ltd.,"Mar. 1981.
4. FOTH & VAN DYKE Industrial, Inc., "Initial Site Report for the
  Land Reclamation, Ltd., Sanitary Landfill Expansion," 1985.
5. Meeting with Wisconsin  Department of Natural Resources Solid
  Waste Division, Dec. 4, 1985.
6. U.S. EPA, "Guidance on Implementation  of the Minimum Tech-
  nological Requirements of HSWA  of 1984, Respecting Liners  and
  Leachate Collection Systems," May 1985 (Draft).
                                                                               RCRA SITE REMEDIATION & EXPANSION    313

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                           Cost  Estimating for  RCRA/CERCLA
                                              Remedial Actions

                                                 Michael R. Morrison
                                              Gregory P.  Peterson,  P.E.
                                                     CH2M HILL
                                                   Corvallis, Oregon
  ABSTRACT
    Developing cost estimates for hazardous waste remedial actions
  is an integral part of the process of designing the remedial facility.
  This paper details the content of screening and feasibility cost
  estimates and their use in feasibility studies for remedial actions.
  Estimating terminology is defined, and key differences between
  "traditional" estimating and estimating hazardous waste projects
  are discussed.

  INTRODUCTION
    Estimates of the costs for remedial actions at hazardous waste
  sites are an essential, and often required, part of the feasibility
  study and  the process of determining the  most cost-effective
  method for site cleanup. During the feasibility process, techno-
  logical and cost criteria are weighed and compared several times
  during the  process of  refining  alternative  remedial actions
  (Fig.l).
    Initially,  comparative screening costs are generated to screen
  out disproportionately expensive alternatives. Subsequently, feas-
  ibility costs are developed and used in  the selection of the most
 cost-effective  alternative. The basic  procedures  for generating
 these two cost estimates are essentially identical, although greater
 accuracy is achieved for the feasibility costs through a more de-
 tailed evaluation of the alternatives and their related cost com-
 ponents.

 ESTIMATING DESIGN AND
 CONSTRUCTION COSTS
   The American  Association of Cost  Engineers (AACE) lists
 three levels of cost estimating accuracy to reflect the increasing
 definition of a remedy at three points in a project.  These three
 levels are: order of magnitude, budget and definitive. Feasibility
 studies are always order-of-magnitude estimates because  of the
 limited scope of work available at this stage in the project. AACE
 defines  order-of-magnitude estimates as approximate estimates
 made without detailed engineering data. Some examples  would
 be: an estimate  from cost capacity curves,  an estimate  using
 scaleup or down factors and an approximate ratio estimate.
 Order-of-magnitude estimates normally  are accurate within plus
 50% or minus 30%.
   Estimating ranges are not meant to be absolute limits, but in-
 stead imply that there is a high probability that the final project
 costs williall within a range. Contractors' bids often fall outside
 of these ranges, but cost estimates focus on predicting the selected
 low bid.
  When using cost estimating  terminology, it is important to dis-
criminate between the terms  "allowance" and "contingency."
The AACE defines allowances as incremental resources included

314   RCRA SITE REMEDIATION & EXPANSION
                          Figure 1
                   Project Interrelationships
  This Figure Diagrams the Inseparability of Scope, Schedule, and Cost.
 in estimates to cover known but as yet undefined requirements
 for individual accounts or subaccounts. An example of an allow-
 ance would be the inclusion of pipe supports and freeze protec-
 tion for a 3-in. above-ground pipe, estimated at $15/ft. The pipe
 supports and freeze protection are neither designed nor quanti-
 fied in the feasibility study; however, since good designers would
 include them in the completed design, an allowance of 70% could
 be included in the estimate for these items.
  Contingencies are defined as specific provisions for  unfore-
 seeable elements of cost within the defined project scope; partic-
 ularly important where previous experience has shown  that un-
 foreseeable events  which will increase costs are likely to occur. If
 escalation is included in the contingency, it should be a separate
 item, determined to fit  expected escalation conditions of the pro-
ject.

 HAZARDOUS WASTE ESTIMATING VS
TRADITIONAL ESTIMATING
  A defined scope  of work is the first requirement for developing
a cost estimate in the traditional manner. However, at the feasi-
bility stage, hazardous waste remedial actions do not have de-
fined scopes and the site often is incompletely characterized.

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  The feasibility analysis consists of comparing a number of op-
tions. These options may reflect different assumptions about the
characteristics of the site and a range of possible designs and pro-
ject scopes. For example, suppose a hazardous liquid is leaching
out of a municipal landfill. Remedial action options may include
excavating a range of soil volumes for disposal  at one of several
licensed disposal sites; a range of groundwater pumping and treat-
ment rates;  and a  range of on-site containment  options. The
geology, geohydrology and many other factors may be only par-
tially explored.
  There are two basic steps that can be taken to narrow this large
range of unknowns: (1) collect more data or (2) rely on the use of
good engineering judgment to make the necessary assumptions to
help quantify each alternative. In hazardous waste remedial work,
the collection of additional data can reduce the  range  of un-
knowns but  never will replace the use of good engineering judg-
ment in identifying a reasonable estimating scope. Since many of
the elements  of a remedial action involve subsurface conditions
and/or new  waste technology, a conservative viewpoint is essen-
tial for cost estimating.
  Furthermore, projects involving hazardous waste have certain
unique features that affect cost estimates. These may include:
• Reduced productivity due to personal protective gear
• Purchase and disposal cost of protective equipment
• Decontamination facilities
• Worker physical examinations and training
• Seasonal weather effects on construction costs
• Freeze protection for on-site facilities
• Nonconventional, multi-unit process treatment trains
• Extraordinary ancillary items
• High redundancy or conservative loads
• Disposal of treatment sludges and residues
  It is very important that all parties understand the inherent un-
certainty in feasibility cost  estimates. The estimated costs should
be used only in the light of the accuracy, context and scope under
which they were prepared. It is therefore necessary that all the
assumptions  about the scope be documented. This documenta-
tion, or at least the summary  of it,  should be  included in any
report, along with cautions about the limitations associated with
using any of the costs out of context.


FEASIBILITY STUDY COSTING
  Feasibility studies make  use  of screening costs and the some-
what more accurate feasibility costs. Screening  costs are used to
compare alternatives in order to eliminate those with higher costs
but no significantly greater environmental or public health ben-
efits. Prior estimates,  site cost experience and good engineering
judgment are needed to identify those unique  items in each al-
ternative which will control these screening estimates. Items com-
mon to all alternatives do not warrant substantial effort at the
screening stage.
  For alternatives  that survive screening, feasibility costs are
developed. The feasibility cost estimates are more detailed than
the screening cost estimates and include both capital and annual
operating costs. The annual operating  costs are viewed over a
predicted life and converted to life-cycle costs. A sensitivity analy-
sis  also can be done on the key items in the  alternatives.  The
latter steps are discussed later in this paper.

Capital and Annual Operating Costs
  Capital costs include only those expenditures that are initially
incurred to develop and install  a remedial action and major cap-
ital expenditures anticipated in future years. Both direct and in-
direct costs are included.
Direct Capital Costs
  The four types of direct capital costs discussed briefly below
should be line items in the estimate. These four line items may
include a number of other items, some of which are listed.
  Construction costs cover equipment, labor and materials re-
quired to install a remedial action. They also include site modifi-
cations, process  equipment, testing and monitoring equipment,
health and safety monitoring and site closure costs. Construction
costs  available from nonhazardous waste sites should be used
with care.  Normally, considerable modification of any of these
costs  is necessary. Labor costs will  include all fringe benefits,
workman's compensation and contractor fees.
  Land and site development expenses  include easements, devel-
opment of access roads,  access control (e.g., gates, fences) and
site preparation for equipment and buildings.
  Buildings and services  costs cover construction of temporary
and permanent buildings and establishing utilities.
  Construction of a hazardous waste remedial facility also may
require relocating affected populations. This may involve temp-
orary or permanent accommodations for nearby residents, mov-
ing allocations, temporary wage settlements and other associated
costs, as necessary.  Guidance for relocation costs is available
from  the  Federal  Emergency  Management  Administration
(FEMA).
Indirect Capital Costs
  Indirect  capital costs consist of engineering, financial,  super-
vision and other services necessary to carry out a remedial action.
They are not incurred as  part of actual remedial actions but are
ancillary to direct or construction costs. Indirect capital costs in-
clude allowances for design and engineering and contingency.
  All other costs, for example, monitoring and sampling, data
collection,  pilot testing, startup and  shakedown,  "debugging,"
operator training and initial field monitoring, should be listed
separately  in the estimate. For remedial  actions  involving an
extended (more than 6 months) construction schedule, an adjust-
ment can be made for interest and inflation during construction.
The assumed schedule and cost index date should be stated.
Allowances and Contingencies for Capital Costs
  Two categories of contingencies can  be added to  total  capital
costs for unforeseen circumstances which may result in additional
costs. Bid  contingencies  cover unknown costs associated with
constructing a given project scope such as adverse weather con-
ditions, strikes by  material suppliers,  geotechnical unknowns
and unfavorable market conditions for a particular project scope.
Bid contingencies may vary between 10 and 20% and are applied
against the construction subtotal for each alternative.
  Scope contingencies cover scope changes that invariably occur
during final design and  implementation. They are intended to
adjust the estimate so it can be used for budgetary purposes. Since
the site characterization is often incomplete and volume estimates
rudimentary, the scope contingency enables the use of engineer-
ing judgment to establish a reserve for project scope modifica-
tions. Scope contingencies will vary  between alternatives. They
may be 10  to 25 %  of the total capital costs for known technolo-
gies and sites with minimum elements of risk; they can be much
more for state-of-the-art technologies at  sites with higher  ele-
ments of risk. Even on well-defined conventional projects, order-
of-magnitude cost estimates tend to be 10 to 30"% below the actual
bid price. Below are some of the factors that determine the mag-
nitude of the scope contingency:
• A reserve of 6 to 8% of the total construction cost is desirable
  for change orders.
• Scope  changes during design  and/or  construction may be
  needed to meet performance-based criteria.
                                                                               RCRA SITE REMEDIATION & EXPANSION
                                                                                                                           315

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• Bidding competitiveness may be low; this, in turn, increases the
  bids.
• Vendors may provide over-optimistic performance data.
• Quantities may be inaccurately defined and listed.
• Performance histories for developing performance  specifica-
  tions may be lacking.
• Regulatory or policy changes may impact basic study assump-
  tions.
• Different  firms and agencies, with different operating  pro-
  cedures, can be involved from concept to cleanup.
Presentation of Total Capital Cost
  Superfund  site  cleanup  activities are classified  by  the U.S.
EPA as either planning costs (remedial investigation,  feasibility
study and design) or implementation costs (construction, con-
struction management and startup). Since funding for site clean-
up can come from more than one source, it is important  to format
the presentation of the estimate to  facilitate any cost sharing that
may  occur. For example,  the  cost  estimate required for the
Record of Decision and the fraction of the  cost that the state
shares, is a part of the implementation cost.
  Capital cost estimates for feasibility studies should  be struc-
tured as shown in Table 1, below. Note the compounding effect
of the calculation. If all calculated  costs shown were a percentage
of Item A only, a lower total would be calculated.
                           Table 1
        Formal and Method for Calculating Total Capital Costs
          Name

          Construction Subtotal
          Bid Contingencies
          Scope Contingencies
          CONSTRUCTION TOTAL

          Permitting and Legal
          Services During Construction
          Other Costs
          TOTAL IMPLEMENTATION COST

          Engineering Design Costs
          TOTAL CAPITAL COST
Method of Calc.

Prom estimate details
* of Item A
% of Item A
Sun of Items A 8 6 C
l of  Item D
% of  Item D
Varies with estimate
Sum of Items D E F & G

Usually % of D
Sum if Items H 6 I
Annual Costs
   Annual operating costs for a remedial action include the oper-
ating and maintenance (O&M) costs incurred following its con-
struction and/or installation, and, where  applicable, annualized
capital costs. Screening level annual costs  may be obtained from
such references as the Compendium of Cost of Remedial  Tech-
nologies at Hazardous Waste Sites' or from prior estimates. For
the detailed  feasibility analysis,  O&M cost estimates must be
based on  site-specific  information. Equipment vendors, similar
estimates  or  standard  costing guidance references may be con-
sulted. All estimates a year or more old should be updated with
current labor rates and price quotes.
O&M Costs
   The post-construction/installation activities necessary  to pro-
vide continued effectiveness of a remedial  action may involve the
following cost components:
•  Operating labor—all wages, salaries, overhead (which includes
   payroll  taxes, salaries,  etc.) and fringe benefits. Nonproduc-
   tive labor for vacations, sick leave, holidays and H&S training
   sessions can consume 16 to 18% of the standard 2,080-hr work
   year.
• Maintenance materials and labor—the costs for labor, parts
  and other materials required to perform routine maintenance
  of facilities and equipment.
• Auxiliary materials and energy—such items as chemicals and
  electricity needed for plant operations, water and sewer service
  and fuel costs.
• Purchased services—such items as  sampling costs, laboratory
  fees and other professional services for which the need can be
  predicted.
• Disposal—transportation and disposal of any waste materials,
  such as treatment plant residues, generated during the course
  of a remedial action.
• Administrative costs—all costs associated with administration
  of operation and maintenance not  included under  other cate-
  gories such as labor overhead. This item can be 10 to  \5% of
  the operating labor cost.
• Insurance, taxes and license—such  items as: liability and sud-
  den and accidental insurance; real estate taxes  on purchased
  land or right-of-way; licensing  fees for certain technologies;
  and permit renewal and reporting costs.
• Maintenance reserve and contingency costs—annual payments
  into escrow funds to cover anticipated replacement  or rebuild-
  ing of equipment and any  large unanticipated O&M costs, re-
  spectively.

Life-Cycle Costs
  Present-worth analysis is a method  of evaluating and compar-
ing costs that occur during different time periods by discounting
all future expenditures (i.e., replacement of worn parts) to a com-
mon base  year. The result is the total  cost, in today's dollars, of
the remedial action alternative.  The U.S. EPA has  indicated that
the current Office of Management and  Budget (OMB) guidance
should be followed for calculating life cycle costs. Many engineers
are familiar with life-cycle cost calculations, or a firm may employ
economists or statisticians to help with these calculations.

Sensitivity Analysis
  Errors in estimating key variables may have a large effect on
the accuracy of the  overall cost estimate. A sensitivity analysis
can assess the effect on  the cost of varying specific assumptions
associated with economic conditions  or with the design, imple-
mentation, operation and effective life  of the remedial action
strategy.
  Through good engineering judgment, one should  be  able to
identify those items  that could bring  about a significant change
in overall costs  with only a small change in the value of the item.
Results of the analysis can be used to identify "worst case" scen-
arios and to revise estimates of contingency or reserve funds.
  In addition, sensitivity analysis can be used to optimize the final
design of a remedial action alternative. This analysis is particular-
ly useful where design parameters are interdependent,  such as for
treatment  plant capacity versus time for treating  contaminated
groundwater.
  The  following factors are primary candidates for considera-
tion in conducting sensitivity analyses:
• The effective life  of the remedial action. In estimating replace-
  ment costs, use base period dollars; do not adjust for inflation.
• How  clean is clean?  The  public health assessment normally
  provides a range  of cleanup criteria dependent on variation
  between the different  health standards and cancer risks. There
  often can be  a 10- or 100-fold difference between alternate cri-
  teria.
• O&M costs
• Duration of cleanup activities
• Availability of off-site treatment, storage and disposal facilities
316
       RCRA SITE,REMEDIATION & EXPANSION

-------
• Uncertainty regarding site conditions. This item includes the
  volume to be treated, materials present and treatment used.

CONCLUSIONS
  If there is one message to be gained from this paper, it is that in
the development of remedial actions for hazardous waste contam-
ination, perhaps more than  for  any other type of engineering,
cost and scope  (and,  of  course, schedule)  are  interdependent
and inseparable. This paper outlines some procedures for devel-
oping feasibility costs, including discussions of line items peculiar
to hazardous waste work.
  Estimating costs for hazardous waste facilities has many in-
trinsic risks. The authors' experience in defusing some of these
risks has been included where possible. However, in the space per-
mitted here, there is no way to cover all of the problems the cost
engineer may encounter in estimating hazardous waste remedial
action designs.

REFERENCES
1.  American  Association of Cost Engineers, "Cost Engineer's  Note-
   book," American Association of Cost Engineers, Morgantown, WV.
2.  Environmental Law Institute,  "Compendium of Cost of Remedial
   Technologies at Hazardous Waste Sites," Environmental Law Insti-
   tute, Washington, DC.
3.  Morrison,  M.R. and Anderson, G.P.,  "CH2M  HILL REM/FIT
   Cost Estimating Guide," CH2M HILL, 1985.
                                                                               RCRA SITE REMEDIATION & EXPANSION    317

-------
                     A  Modular Computerized  Cost Model  for
                     Remedial  Technologies  at  Superfund Sites
                                                 William Kemner
                                              John  Abraham, P.E.
                                                   Jack  Greber
                                                  Jay  Palmisano
                                              PEI Associates,  Inc.
                                                 Cincinnati, Ohio
ABSTRACT
  The  purpose of the research reported in this paper was to
develop prototype cost estimation models for response technol-
ogies at uncontrolled hazardous  waste sites. This research was
conducted for the U.S. EPA, Hazardous Waste Engineering Re-
search  Laboratory in cooperation with the Office of Emergency
and Remedial Response.
  The  model is designed for operation on a personal computer
and can provide levels of detail in the estimate as a function of
input parameters available. The cost estimation model takes into
account site, waste, workers safety and regional variations. Out-
put formats and types of cost calculations are consistent with the
U.S. EPA Remedial  Action Costing Procedures Manual. De-
fault values for interest  rates, discount rates, planned life, con-
tingency allowances, etc., are  consistent with  the costing  pro-
cedures manual.
  The  model can be used by U.S. EPA Headquarters and Reg-
ional Staff,  State personnel and  contractors (REM/F1T Con-
tractors, cleanup contractors, etc.) for quick, easy and effective
calculations of costs for evaluating and comparing a variety of
different remedial measures.

INTRODUCTION
  Computerized cost  estimating models are finding  widespread
use in the building and construction fields because of the advan-
tages of uniform procedures and access to  cost data bases they
provide. The U.S. Army Corps of Engineers has perhaps the best
established program, i.e., the Computer Assisted Cost Estimating
system (CAGES). The Corps requires that this program be used
by architects and engineers to generate cost estimates on Corps
projects. Other government entities (U.S. DOE, VA, Air  Force,
Navy, etc.) and private firms have computerized systems and data
bases for various applications.
  Remedial action technologies at Superfund sites employ many
conventional civil engineering elements with well-documented
costs as well as completely new technologies  for which little or no
cost data exist.  Both construction and chemical process com-
ponents are involved in cleanup technologies. This is a unique re-
quirement not encountered in other computerized models.
  With the huge backlog of Superfund site work and the com-
plexity of cleanup technology, it was apparent that some form
of computer-assisted estimating was needed  by the U.S. EPA for
use by both contractors and Agency personnel.
  The  Land Pollution Control  Division of the Hazardous Waste
Engineering Research Laboratory contracted with  PEI to develop
such a  system. The project is  being done in phases. This paper
presents the  results of Phase I; the development of the overall
design  and objectives of the computerized  system and develop-
ment of several cost modules. Work is currently underway to ex-
pand the cost data base and algorithms. The system is designed
to be flexible and dynamic; it is anticipated that new data con-
tinually will be used to update the cost data base.
  The system is designed to operate as an interaction program
on an IBM PC/XT or AT. The intended users include:
  U.S. EPA research personnel
  U.S. EPA policy analysts
  Superfund Regional Office personnel
  Superfund contractors
  U.S. EPA enforcement personnel
  The system is intended to be used to:
  Develop scoping costs for budget planning
  Calculate specific remedial site costs
  Check estimates performed by others
  Compare alternative technologies
  Evaluate costs proposed by potentially responsible parties
  Perform value engineering analysis
  Costs can be calculated as specific estimates or include prob-
ability ranges based on uncertainly input by the user. Net present
worth analysis also is included in the program.
  The advantages of the system include:
• Detailed, documented cost  elements consistent with the  Na-
  tional Contingency Plan (NCP) and EPA Cost Guidelines
• Uniform and consistent format for costs
• Rapid calculation  of cost and accommodation of changes in
  specifications
• Ability to consider  uncertainty in estimates
• Ability to compare alternatives for a given site
PROGRAM STRUCTURE AND OPERATION
  The program is structured to a level of detail based on the data
available prior to detailed design specifications and drawings by a
contractor.  Generally, a line item approach is used for output
specifying line  item detail for those users interested in the de-
tail level.
  The program is designed to be flexible. Some of the flexibility
features include:
• Ability to include specific values for input parameters or use de-
  fault values in the data base
• Ability to add write-ins for unusual items
• Ability to use adjustment  factors for such things as inflation,
  geographic location, job difficulty, labor productivity due  to
  health and safety requirements, geological effects, etc.
318    RCRA SITE REMEDIATION & F:\PANSION

-------
• Ability to have various levels of printouts with more or less de-
  tail
• Ability to override individual computed items of cost
• Ability to store partial or complete runs for recall and modifi-
  cation at a later date

  The system is designed to separate the data base from the cal-
culation requirements as much as possible. The data base includes
room for expansion and the ability to add or update data items
without affecting the program. This enables expansion and up-
dating by personnel who are only casually  familiar  with com-
puters.
  The costing system requires the user to  understand the tech-
nologies being used because relatively detailed design input data
are required. Unlike some other approaches, this system does not
rely on historical costs of previous remedial actions. Rather, the
remedial technologies are broken down to levels of detail which
can be costed based on sound engineering cost data.
  The program is designed to be transportable and operate on an
IBM PC/XT or AT or equivalent with at least 5 Mb of available
hard disk storage capacity and 256K RAM. The operating sys-
tem is MS DOS 2.0 or higher.  The program is written in Micro-
soft FORTRAN. LOTUS 1-2-3 spreadsheet software is an option
to enable users to change values on intermediate output. The data
base is structured using dBASE III.
                                                                       Current Data File  in  use
                                                                                                     NO FILE  IN  USE
                          Figure 1
   Overall System Flow Diagram for the Computerized Cost Model
  Overall system structure and flow are shown in Figure 1. The
program is designed around a series of menus used to select spe-
cific technologies and components. The general program control
menu is shown in Figure 2. The user is guided through the menus
in a logical fashion; experienced users can access  a specific com-
ponent directly without stepping through the menu hierarchy by
entering  the component I.D. Once at a component level, the
user enters the design parameters which determine the cost of
each subassembly.
                    Main Menu
      1)  Begin a  New Data  File
      2>  Edit Current Data File
      3)  Save Current Data File to  Disk -for Future Use
      4)  Load in  Previously Saved Data File -from Disk
      5)  Calculate  Costs -from Currant  Data File and
           Print  Report
      6)  Exit Program

Enter  your selection (1-6)

                          Figure 2
                 General Program Control Menu
  Two general input screens are used to enter information such
as date of run, title and various cost adjustment factors. Figures
3a and 3b are example general input screens.
  The unit cost data base contains the unit costs or cost equa-
tion coefficients for each line item. The data base consists of two
files:  one for linear cost relationships (i.e., line item extensions)
and one  for exponential cost relationships (i.e., cost estimating
relationships for process equipment).  Many conventional con-
struction line item costs are excerpted  from references  1 and 2.
The default factors file contains default values for items such as
interest rate, contractor overhead, etc. If values are not specified
for these parameters by the user, the default factors are used.
  A job input file contains the input data for a past run and en-
ables  the user to recall  and adjust past runs without reentering
all the data.
                                                                                      I REMEDIAL  RESPONSE  CONSTRUCTION I
                                                                                      I   COST  ESTIMflTING  SYSTEM     I
                                                                     DOTE	) 1£-17-B3<—1

                                                                     ESTIMATOR	>JDHN DOE
                               ANALYSIS NO.	> 13-333  <—I

                                    (— I
                                                                     SITE NAME-
                                                                                    -)SENERIC SITE ONE
                                                                     SITE LOCBTION	) ANYWHERE, USA              <—I
                                                                                   —)                         <—I
                                                                     ZIPCODE	) 12343<—I

                                                                     CONTRACT NO.	>12-033GKDFA-43NMK4  <—I

                                                                     CONTRACTOR	> ACME COMPHNY               (—I

                                                                     COMMENTS/SCOPE OF WORK I
                                                                     >EXAMPLE OF SUBSURFACE DRAIN MODULE CALCULATION FOR A
                                                                     >HYPOTHETICAL SITE.
                                                                      IS THE INFORMATION CORRECT ?  (Y/N)
                                                                                             Figure 3a
                                                                                        General Input Screen
                                                                                          GENERAL PROJECT  COST DflTA
   GENERAL CONDITIONS   . 0*

  GEOGRAPHIC LOCATION FACTOR I

   LABOR t EQUIPMENT  18.0 »
   MATERIAL

  ESCALATION t

    LABOR

    EQUIPMENT

    MATERIAL

  SALES TAX
                                                                                      3. 0 <
           GENERAL CONTRACTOR I

            OVERHEAD  10.0 *

             PROFIT   10.0 *

             E,D t I  13.0 X

    PERMIT/LICENSE FEE   l.o  *

             BOND      1.0 X

            INSURANCE   0.0 X

ADDITIONAL LAND COST •     33000
         ARE THESE CORRECT ? (Y/N)
                          Figure 3 b
                General Project Cost Data Screen
                                                                                RCRA SITE REMEDIATION & EXPANSION    319

-------
                  Currant  Data File in use i  FILE3.BIN
                                                                           Current  Data Film  in  use i FILE3.BIN

Technology
Level

1.0.0.0.0
2.0.0.0.0
3.0.0.0.0
4.0.0.O.O
S. 0.0. 0.0
6.0.O.O.O
7.O.O.O.O
8.0.0.0.0
9.0.O.O.O
Major Program Bubdl visions
Technology Categories

Control Technologies
Treatment Technologies
Excavation
Transportation (OH Bite).
Disposal
Alternative Water Supplies
Relocation
Oeneral Site Work
Building/Structure Decontamination
O
Modules
Chosen

O
0
0
0
0
0
0
O
0
1. 3. 4.0.0
Technology
Leve 1


1.3. 4. 1.0
1.3.4.2.0
1.3.4.3.0




Leachate Control
Technology Categories


Subsurface Drains (T)
Drainage Ditches   99 to return to the Main Menu
Input a  Technology Level  1

                           Figure 4
                   Major Program Subdivision


    The technology-specific data entry is based on the "menu"
  approach because this is a  proven approach which works well
  from a programming and organization standpoint and has found
  wide acceptance by noncomputer-oriented personnel.
    The hierarchy of menus is organized  by a numbering system
  and proceeds from broad categories of technologies to greater
  levels of detail in  specification of individual components. Once
  the finest level of detail menu is reached, the user is prompted
  for the specific design parameters required to estimate the cost of
  that component. Following the design data, general cost informa-
  tion is required from the user such as contingency, subcontractor
  overhead and profit and adjustment factors. Defaults  are pro-
  vided wherever feasible.
    The menu hierarchy is summarized below:

  X.                         Major Program subdivisions
  X. X.                       Technology categories
  X.X.X.                     Specific technologies
  X.X.X.X.                  Technology subcategories
  Data input within X.X.X.X.  Subcategory  modules and  sub-
                               assemblies
    Figure 4 describes the major program subdivisions and is the
  highest level of the menu hierarchy. Figures 5 and 6 are examples
  of menus progressing through finer levels of detail for technology
  selection.
                                                                Enter  —)  0.  to  return to the  Main Technology  Menu.
                                                                Enter  —>  99  to  return to the  Main Menu

                                                                Input  a Technology  Level . 1

                                                                                          Figure 6
                                                                                Detail Technology Category Menu
                                                                     1.3.4. l.O
                                                                         i
                                                                                  Subsurface Drains  (T)
                                                                                  MODULE  NUMBER 1

                                                                                Drain Pipe  size I material
                                                                                          Material
Size
4 in
6 in
8 in
1O in
12 in
18 in
1 Asbestos
! Cement
I 1
! 2
! 3
i 4
1 5
1
: Por ou s
! Concrete
: 6
! 7
1 8
i -
i 9
1 10
Vitrified
Clay
11
12
13
14
IS
—
pvc
IB
17
IB
19
20
"
                                                                              Enter  Drain Pipe  choice (1-20)7  14

                                                                                 Is  this screen  O.K.  ?   Y

                                                                                          Figure 7a
                                                                                      Input Data Screen
                                                                     1.3.4. 1.0
                                                                         i
                                                                                  Subsurface Drains (T)
                                                                                  MODULE NUMBER  1
                                                                             Non-perforated  Pipe size  4  material
                                                                                            Material
                   Current Data File  in u.e t FILE3.BIN
1.0.0. 0. 0    Control Technologies


                  Technology Categories
Technology
Level
                                                   Modules
                                                    Chosen
 1.1.0.0. 0    Air Emissions Controls                       9
 1.2.0.6.0    Surface Water Controls                       0
 1.3.0. e. 0    Ground Water Controls                        B
 1.4.8.8.8    Contaminated Water and Sewer Lines           0
 Enter —> 0.  to return to  the Main Technology Menu.
 Enter —> 99  to return to  the Main Menu

 Input a Technology Level  .3
                           Figure 5
                   Technology Category Menu
Size
4 in
6 in
8 in
10 in
12 in
18 in
Asbestos
Cement
	
21
22
23
24
—
Porous
Concrete
	
23
26
27
28
29
Vitrified
Clay
30
31
32
33
34
35
PVC
36
37
38
39
40
—
                                                                        Enter  Non-perforated Pipe choice (21-40)? 33
                                                                                 Is this screen O.K.  ? V

                                                                                          Figure 7b
                                                                                      Input Data Screen

                                                                   Items marked with "(T)" (for technology component) are at
                                                                the lowest level of the menu hierarchy. Selection of one of these
                                                                leads to a data input screen  for user input of design parameters
                                                                for that technology component. Menu selection can be bypassed
  320    RCRA SITE REMEDIATION & EXPANSION

-------
 at any level by the experienced user selecting the specific menu
 I.D. number; e.g., 1.3.4.1 will take the user directly to the input
 screen for that particular subcategory component. Numerical de-
 sign data are not required until the user reaches the technology
 level.  At this point, the specific input varies depending on the
 component as illustrated in Figures 7a through 7f.
                                                                                        REMEDIAL RESPONSE CONSTRUCTION
                                                                                           COST ESTIMATING SYSTEM
             Subsurface Drains CT)
             MODULE NUMBER 1
                       Pipe A Trench depth
3 feet
5 feet
3)  6 feet
4)  8 feet
                        5)  10 feet
                        6)  IS feet
                                     7)  1 <. feet
                                     S)  16 feet
 9) ia feet
te> 20 feet
                Enter Pipe t Tronch choice (1-10)7  7
      Total length of drainage pipe trench,  (feet)   214.00

      Tot a 1 1 engt h of Non-per for at ed pip* t rench i ng. < feet)   900. 00

      Manholes or Junction boxes  t  Number required?   3
                              i  Interior coating required ? Y


                           Figure 7c
                      Input Data Screen
 1.3.4.1.0
    1
             Subsurface Drains (T)
             MODULE NUMBER 1
                         Met Well Pump(s)

      Pump Capacity,  Gallons/Minute        I  23 I  50 I 100 I £00

      Number of Pumps required            I   01   0 >   31   0

      Stainless/Lined Pump necessary  (Y/N)  I  N  I  N  I  Y  I  N



                   Leachate Holding Tank  Capacity

         Tank Capacity, Gallons   I  1000 I 2800 I 10000 I  20000

         Number of Tanks required I   0  I   0  I    01    2

                     Is this screen O.K.  (Y/N) ? Y
1.3.4.1.0
    1
                          Figure 7d
                      Input Data Screen
              Subsurface  Drains  (T)
              MODULE NUMBER  1

                    100 Gallon/Minute  Capacity  Pumps

              Distance from  pump  to  leachate holding  tank

             Pump * i   see. 00
             Pump » Z   700.00
             Pump * 3   400.00
             Pump It 4  l£0e. e0
             Pump * 5  1400.00

                      Is  this screen  O.K.  (Y/N>?  Y

                          Figure 7e
                      Input Data Screen
  Table  1 is an example of the input (or cost factor) compon-
ents for  several example modules. Each component and  sub-
assembly shown in Table 1 and included in the cost file is ref-
erenced to a component "fact sheet" which documents the bat-
tery limits of that  component, the design, cost data sources and
all items  included  in the cost. An example fact sheet for 1.1.1-
Pipe Vents is shown in Figure 8. The numerical data values used
in this paper are for illustrative purposes only and are not neces-
sarily final or accurate.
  There are two levels of output: a detailed output by technology
component and subassembly, and a summary output for the en-
                                                                                         Drains  
                                                                                 MODULE NUMBER 1
                                                                      SUBCONTRACTOR 1
                                                                       OVERHEAD  14.00X
                                                                       PROFIT     7.SOX

                                                                      GENERAL CONTRACTOR MARKUP
                                                                      ON SUBCONTRACTED WORKI
                                                                       OVERHEAD   4. 08*
                                                                       PROFIT     s. sat
                                                                                   COST DATA

                                                                                      HEALTH S SAFETY FACTOR  33.00*
                                                                                      GEOLOGY FACTOR         22.38*
                                                                                      DECONTAMINATION FACTOR   3. 00*
                                                                                      CONTINGENCY           18.25*
                                                                                      START-UP                . 90X
                                                                                      NET PRESENT WORTHI
                                                                                       INSTALLATION PERIOD  1  YRS
                                                                                       OPERATING LIFETIME(X)  20  YRS
                                                                                       DISCOUNT RATE      10. 00X
                                                                          ARE THE VALUES CORRECT? (Y/N) Y

                                                                                Figure 7f
                                                                            Input Data Screen

                                                     tire site scenario. The detailed output format for capital costs is
                                                     illustrated by an example shown in Figure 9. This is an example
                                                     for the subsurface drains module  only and does not represent a
                                                     complete remedial scenario. Using the spreadsheet software, the
                                                     user will be able to change any output value. A Lotus  1-2-3 tem-
                                                     plate is provided to do all necessary extensions. All output is de-
                                                     signed to fit on 8.5-in. x 11-in. paper.
                                                       The job input file contains  all user input data. The cost data
                                                     base and default factors files  are created and maintained using
                                                     dBASE HI but are used by the program as ASCII files. Figure 10
                                                     contains an example record from the unit cost data base file.

                                                     Calculation of Capital Costs
                                                       Capital costs are calculated  as the sum of labor, material and
                                                     equipment costs. These are defined as follows:
                                                     Labor      Labor to install  components  at  the  site. Off-site
                                                                 labor involved in fabricating delivery material is in-
                                                                 cluded in the material cost.
                                                     Material    Material such as piping, concrete, etc., used to build
                                                                 a technology, and preconstructed items such as in-
                                                                 cinerators, clarifiers, etc. (Note the latter are usually
                                                                 referred to as "equipment" in typical process cost
                                                                 engineering).
                                                     Equipment  Construction equipment cost, typically   rental  of
                                                                 bulldozers, cranes, etc.
                                                       The general cost equation
                                                     y = (axb +  c)d
                                                                                                                            (1)
                                                                  where a, b, c are coefficients and d is the number of items,  is
                                                                  used to calculate the component costs. This form of the equation
                                                                  can be used to represent many cost characteristics. For example,
                                                                  a simple line item cost such as 100 ft of 4-in. PVC pipe at $4.507
                                                                  ft can be represented  as y  =  [4.50(1)' + 0](100). A more com-
                                                                  plex CER such as for a liquid injection incinerator with 50 x 10'
                                                                  Btu/hr capacity may be represented as y  =  [1.6(50 x 10')055](1)
                                                                  where the coefficients 1.6 and 0.55 have been determined from a
                                                                  least squares fit of cost data.
                                                                    For most components, additional calculations are required in
                                                                  the program to convert user-specified parameters into component
                                                                  cost  drivers. For example, in excavation components, the cost
                                                                  driver is cubic yards. While some users could input this directly if
                                                                  known, it is easier to enter dimensions so the program can calcu-
                                                                  late volume.

                                                                  Calculation of Operating and Maintenance Costs
                                                                    Operating and maintenance costs include those costs required
                                                                  to operate and maintain the system after the initial installation is
                                                                  complete. The user specifies  the  time period  over which O&M
                                                                                  RCRA SITE REMEDIATION & EXPANSION    321

-------
                                                             Table 1
                                Cost Input Data Requirements by Subcalegory Component and Subassembly

1.0.
1.1.1














i.i. r




















Component
Pipe vents














Trench vents




















Subassembly
Backfill

Piping and laterals




PVC
»BS
Galvanlied Iron
Other
Eihaust system
butterfly valves)


Eicavatlon, backfill, spreading,
and struts
Piping and laterals
(includes elbows and tees)



PVC
ASS
Galvanized Iron
Corrugated polyethylene
(uses PVC risers)
Evhaust system

L 1 ner
* Hyp* Ion
0 4 In. gunfte and mesh
* Other
" 6 1n. clay
* Other

I
Diameter
(feel)
Diameter








Mow rale
1 ,r ff,}
\ 1C I"! 1


Depth
( f PC t )

Dlamrlrr
( tnchrs 1








Flo. rate
(icfm)





data Input

Da
?
Depth (feet)

Depth (feet)








Pressure
{fl in. used
If not
ipec if ted)
terujth
(fret 1

len9th
( f>M i








drop
(8 In. used
i* not
specified)
ub-Jisembly da1




U require^
3


Cap type
• U-top
(not app) ic .
If lateral*
are used)








Width
( feet )

Cap i/(*
* Mushroom^
* u-top
(not appl Ic ,
If lateral*








a input)





4


L*t. length














lat. length
"eet]

















i
Number

humtter








Hunter





hyrtwr


















HF
1

1








I



I

,









'








u
t














'




















u



































        Nolc- HF. GF. DF denote whether the adjustment factors arc applied to this cost clement; HF is health and safcl> (aclor. til IN Rcolog> factor, and DF is decontamination factor
costs are to be incurred. Uniform annual costs are assumed; i.e.,
no inflation and no increase due to deterioration of equipment.
The expected useful life of equipment is included in the data base
and printed out with the capital cost calculation. Salvage value is
not considered in the net present worth calculation.
   O&M costs  include labor, electricity, service water, fuel, chem-
icals, maintenance materials, water  treatment, area maintenance
and similar items. Unit prices for these items are maintained in the
default rates file which the user can  update  for each run if de-
sired:
   Net present  worth is calculated from the formula:
          NPW
X /(I
(2)
where NPW  =  net present worth in dollars
X,  = expenditures in year t
i    = discount rate (10% or entered by user)
t    = year

Costs are not inflated beyond the base year.
  For capital costs, the cost data base file is  used to provide in-
stallation time. The longest duration item is used as total installa-
tion time. Alternatively, the user can input an  installation time, in
which case the total cost is equally divided by  year. For O&M
costs, the user provides the number of years the site is to be main-
tained.
ADJUSTMENT FACTORS

General Conditions Factor
  This factor is used to adjust costs to account for qualitative
factors related to job difficulty. This factor allows a user to ac-
count for such  things  as  unusual or difficult site conditions,
weather, local labor conditions, local economy, contractor com-
petitiveness and other factors that cannot otherwise be accounted
for quantitatively. The  factor ranges from zero (no  adjustment)
to any percentage value the user  thinks  is reasonable. For ex-
ample, a value of 10% will increase the cost by 1.1. The factor is
applied to labor, material and equipment.

Geographic Location Factor
  The geographic location of the Superfund site where the tech-
nology is to be implemented is another important consideration.
Construction costs, material and  labor vary  by regions of the
country. The variation can be significant,  as much as 30% above
or below an average national cost for the same category of items.
Values for these geographic factors are available in  various cost
estimating publications such as R.S.  Means and Dodge. The user
can provide whatever adjustment is considered appropriate by en-
tering a percentage to directly adjust costs upward or downward.
If no factor is provided, costs are based on national average.
322    RCRA SITE REMEDIATION & EXPANSION

-------
                                       I.D.:   1.1.1

                                       Subassemblies:
             COMPONENT  FACT SHEET

                               Title:  Pipe vents

                          1 - Excavation
                          2 - Piping and materials
                          3 - Exhaust system
                                                                    BUTTERFLY
                                                                    VALVES
                                                          SRAVEL
                        (<) ATMOSPHERIC
                            VENT
                         MUSHROOM TOP
(b) ATMOSPHERIC
    VENT
   "U" TOP
                                                                       (d) VERTICAL PIPE VENTS CONNECTED TO FORCED
                                                                             VENTILATION MANIFOLD SYSTEM
            Exhaust System Subassembly Line items
            Fan: Belt-driven, utility mount, weather cover, corrosion-resistant coating mounted
             1 on  foundation/ready  to connect to on-site electrical supply HP =  0.0001575
              (AP)(SCFM)
            Flow meter: Mounted on steel frame
            Moisture trap: Trap and drain connection
            Butterfly valves:

            Piping and Laterals Subassembly Line Items
            Slotted pipe
            Coupling
            Solid  pipe (lateral piping diam. = riser diam.  + 2 in.), 100 ft lateral added to
              user input from fan to treatment
            Caps (mushroom or U-top), or tees

                                                              Figure 8
                                                         Pipe Vent Fact Sheet
                                          Excavation Subassembly Line Items
                                          Excavate holes or trench
                                          Spread burden
                                          Backfill with gravel (nut size)
                                          Cover with 6 in. dirt
                                          Source: SCS, 1981 (Ref. 3), Modified by PEI for detail.
 Health and Safety Factor
   This factor is applied to labor and equipment and represents
 increased costs  because of decreased productivity due to person-
 nel protection requirements in Superfund work as compared with
 conventional construction.
   Worker health and safety considerations or precautions can sig-
 nificantly  impact worker productivity and thus costs for some
 technologies at  some remedial action sites. The impacts  are ex-
 pected to  be more significant for control  technologies than for
 treatment  technologies. A literature review has revealed only one
 source of information that directly addresses the issue.3
   The reported  range of adjustments is extremely broad. For one
 technology, the reported percentage adjustment ranged from 58
 to 1990%.
   The user enters an adjustment percentage to increase labor and
 equipment costs based on judgment.
   Users of the model will have to be somewhat familiar with the
 nature of the waste at the site to be remediated and with the de-
 fined levels of personnel protection. Four levels of protection are
 defined. Suggested values are as follows:
Personnel
protection level
D
C
B
A
         Adjustment
         factor
                   1.0
                   1.1
                   1.3
                   1.5
• Level A—Requires full encapsulation and protection from any
  body contact or exposure to materials (i.e., toxic by inhalation
  and skin absorption).
• Level B—Requires self-contained breathing apparatus (SCBA),
  and cutaneous or percutaneous exposure to unprotected areas
  of the body (i.e., neck and back of head) is within acceptable
  exposure standards (i.e., below harmful concentrations).
• Level C—Hazardous constituents known; protection required
  for low-level concentrations in  air;  exposure of unprotected
  body areas (i.e., head, face, and neck) is not harmful.
• Level  D—No  identified hazard present, but  conditions are
  monitored and minimal safety equipment is available.

Geology Factor
  This factor is applied to selected components (equipment and
labor) which are affected by a site's geology. Example  compon-
ents affected are pipe vents, wells, trenches, etc.  Base  costs are
calculated for  "typical" geology.  This is defined as unconsoli-
dated silty sand with a water table  10 to 100 ft deep. The geology
factor is a direct multiplier of the affected components; i.e., an
input of 10% will increase costs by 1.1.

Decontamination Factor
  This factor is applied to equipment and labor  and represents
increased cost  due to the requirement to decontaminate equip-
ment. The decontamination of buildings and structures is a sep-
                                                                                  RCRA SITE REMEDIATION & EXPANSION    323

-------
          12-17-83

          JOHN  DOE
        U.S.  ENVIRONMENTAL PROTECTION AOENCY

REMEDIAL RESPONSE CONSTRUCTION COST ESTIHATINO SYSTEM
          PILE I  FILE3.BIN

         ANALYSIS NO.  12-333
                                                   GENERIC  SITE  ONE


                                                   ANYIHERE.  USA
                                                             CONTRACTOR IACNE COMPANY


                                                            CONTRACT NO. 12-«336ICDFA-43NMI(4
                                         COMMENTS/  EXAMPLE  OF  SUBSURFACE  DRAIN  MODULE CALCULATION FOR A
                                    SCOPE OF WORK I  HYPOTHETICAL  SITE.
          1.3.4.1 Subeurface Dralne IT)


          ITEM ID             DESCRIPTION
                 • i CAPITAL COSTS ••
     OUANTITY   UN    LABOR    MATERIAL  EBUIPMCNT
                                                                                                     HF
NODULE NUMBER 1


   OF        DF
                                                                                                                                  TOTAL
          •2318812M Trnoh Excavtng 4P»id
                     botta tank alpd .9-1
                     IBFdp 2CY Hrpr«ad*r

          »232953«5« Piping,  Subdrainig*,
                     Vtrfitd Cl«7 p*rf. 2F
                     Ingth* C-211 l**di»

          •2M2141M Catch Baalna-Nanhol*
                     Slab top* pracaat «'
                     thick 4Fdlaa aanhol*

          •2M2142M Catch Baaina-Hanhola
                     Su«p 4ft.
                     incio* dlaMttr

          •29M2*114CCatch BMln.-B.nhol.
                     Pracact 4FID rla«r
                     •27.79 pvr TLF 14Fdp

          •9M39M4* Kail coating acrylic
                     glaud coatinga aai.
                     For confined apace

          132e94M2KSuep Pucp  Capacity
                     1MDPH 19Fdeep veil
                     Trench Depth 12F, 14F

          132t94ta6eCPuep coat addition
                     Stnlee atl or pletlc
                            cap tol9Fdpth
           1919M2S«*BPlpe  plaetic  fitting
                      3  .Ibo.e
                      2'dlaceter

           191ft»e449eBPlplng
                      Valvea
                      2'dlaeeter

           19149«2eMBPlpe  Flberglaea
                      Reinforced
                      IMFplpe  2*dia>
           4217CY        1263         •      4M7      3379      1333       3*3     11M9
           2637CY
           2697CY
                            •      73*6
                            •      397B
           2637CY       27499
                                                                              I      3976
                                                •     13124      6*49       1374     31*46
            1933CY         397         •       31t       366       146        33       1212
            1333CT         714
            1236ST        2*39
                                              2*1       9*3       2*1        43       1664
                                                •      1121
                                                                            1B1      37*9
                                                          1236NSF      13311      7846      433*     1MM      4323       902     43612
                          387       123e        37       244        97        22      2*37
               7Ea
                           349       323        133       263        1*6         24       14*2
               TEa         179*       14M       669       1328       331        12*       3794
               7VLF       2468      49M        933       1871        748        17t      11»92
              73SF
                           161         67
                                                          98        39
                                                                                       391
               SEa        4373     21779
               9Ea
                             I     2999*
              13Ea         63*       12*
               9Ea
                            33       193
                                                 •      24K       962       218     29736
                                                                               •     2939*
                                                         346       138        31      1263
                                                                    12
            42NLF      22680*     77279         •    124748     49893     11348    49M34
                                                                       Figure 9
                                                                     Cost Output
324     RCRA SITE REMEDIATION & EXPANSION

-------
1330898028 Tank Fbrglaa Undgrnd
           20e00gai.cap.  unese
           •arway I it. tholddvna

0231608200 Bulk Excavating
           Backho* Hyd.  eravler
           .td.  ICY cao. '45CYhr

0230030001 Backfill  By  hand
           no compaction
           Light (Oil

823083885* Backfill
           Air taap,  add

8232202400 Grading Site excav.t
           fill 1/4 puih dozer
           Hand grading,  finiah

0284602200 Seeding
           Feacue 5. 5«/HSF
           Tall puah apreader

1310001000BTotala for 100Faaln
           Includea diach. pipe
           elbova & tee 4*aain

1510002008BAdd or aubtract for
           •ore or lea* than
           100F   6-aain

02303Se001ATrench & Backfill
           coat for trench 4.3F
           dpxlMFlongxS'vide

0230380002AGrade/Flnlah
           coat for trench 4. 3F
           dexlMFlongx8*vide
        ~~~~~~
   2Ea        5240     23440         0      2882      1132       262     34976
 720CY         604
 328CY        2902
  84CY         2S1
 124SY         204
                      S06       775       310        70      2565



                        0      1396       638       145      5281



                       62       188        75        17       623


                        0       112        44        10       370
 124HSF       1535        787       436      1084       433        98      4373
   5Ea        2420      1525
3700LF        5216      3365
  42Ea         966
                                            1331       532       121      5929
                                           2868      1147       268     14856
                                  1260       1224       489       111      4050
               630       210        42        369       147        33      1431
 HEALTH C SAFETY COSTS

 GEOLOGIC COHSIDERATIONS

 DECONTAMIHATION COSTS
167271

 66898

 15197
                                  7739

                                  3091

                                   698
 GENERAL  CONDITIONS
 GEOGRAPHIC CONSIDERATIONS
 SALES TAX
                                                             55351      19158      2561
                                                             55351       9575
                                                                        9575
                                                                                 2561
                                                                                                                          67487
                                                                                                                           9575
 Sy§IQTAL_DIRECT_CQSTS	

 SUBCONTRACTOR OVERHEAD AND PROFIT
 GENERAL  CONTRACTOR OHtP
  ON  SUBCONTRACTOR
 GENERAL CONTRACTOR OHtP
           _664216	229880	30732_
                                                            _924769_


                                                             386506
                                                                                                                          27585
 SUBTOTAL	

 PERMIT/LICENSE


 INSURANCE


 BOND


 ENGINEERING


 STARTUP
                                                                       _1258B60_

                                                                           12388


                                                                           62943


                                                                           12588


                                                                          202046
 CONTINGENCY
 ESCALATION
                                                                        _154902S_

                                                                          278624


                                                                           54834
 I9Iit-CAPIIAL.COST_I_!!gDULE_NyHBER.l	1B82683__


                                                    Figure 9 (continued)


                                                                                 RCRA SITE REMEDIATION & EXPANSION    325

-------
CODE
UM
OESCJ
DESC_2
DE5C_3
UNIT_MAT
UNIT LAB
UNIT_EQP
HEALTH_FLG
GEOLGY_FLG
DECONT_FLG
REFERENCE
COST_OATE
0252933040
L.F.
Piping, subdrainage.
Concrete porous wall
Cone, drain 8"diam
2.25
1.87
0.28
0
0
0
Means
6/84
(CSI code)
(Unit of measure)
(Description)
(Description)
(Description)
(Unit material cost)
(Unit labor cost)
(Unit equipment cost)
(Health factor flag)
(Geology factor flag)
(Decontamination factor flag)
(Cost reference)
(Cost date)
(CSI Construction Standards Institute)
                          Figure 10
               Example Record in Cost Data Base
arate component and is not covered by this factor. The base costs
do not include any decontamination. The user can input a per-
centage that is directly applied to the appropriate components.
Note that the above three factors are applied only to those items
flagged in the data base (Fig. 10). A zero flag means the item cost
is unaffected by the given factor.

Escalation Factor
   Costs are calculated in mid-1985 dollars. An escalation factor
is used to adjust costs for inflation. Separate factors are provided
for labor (also used for equipment) and material if the user de-
sires to use different factors. These values can be obtained from
many references as the user desires. References include the CPI,
CE Index, etc. The value is applied to total cost. An entry of
10% will increase costs by 1.1.

Contingency Factor
  The  contingency factor  is  a broad adjustment factor to in-
crease costs for any aspects of the estimate the user believes are
unaccounted for otherwise. In this program, the contingency fac-
tor can be used in the conventional manner (i.e., enter a per-
centage which will  increase all costs accordingly) or to implement
the more sophisticated probabilistic feature of the program. The
latter is done by entering "P" in the contingency field. When
this is done, an alternate series of input screens will be activated
which require not only entry of a given data value, but also min-
imum and maximum values and selection of an appropriate  fre-
quency (probability) distribution for the data value.

PROBABILISTIC ESTIMATING
  Uncertainty in the cost estimates for a given site can be due to
several different factors:
• Uncertainty in the scope of the job
• Uncertainty in the technology
• Uncertainty in the cost model
  Typically, cost models deal only with the last item, cost model
uncertainty. Costs  are loosely referred to as "budget estimates,"
"study  estimates." "detail  estimates,"  "site specific,"  etc.
These items imply some  level of certainty expressed  as plus or
minus some percent. In fact, the uncertainty is not really calcu-
lated, but an arbitrary error band is applied after a point estimate
is calculated, for example, ±30%. This percent is applied as a
qualitative indicator of the amount of detail considered in the
estimate. An accurate  estimate is obtained only after a  specific
job is engineered with design  drawings,  detailed takeoffs  and
vendor quotations to a bid specification.
  At this writing, the probabilistic cost estimating feature has not
been  implemented. An option  is being planned  structured to
accommodate the uncertainty of all three types referred to above.
Furthermore, each element of the cost  will have its own uncer-
tainty in order to calculate a composite error range (i.e., a joint
probability density function).
  The probabilistic approach takes  into  account the  fact that
some  elements of the estimate  have  much different uncertainty
than others, and, simultaneously, each element does not have
the same effect on the  final estimate. Clearly,  the objective is to
identify what factors have the greatest impact and to obtain the
most accurate estimate for those factors.
  The greatest uncertainty in Superfund estimates usually is re-
lated to uncertainty in  the scope of the job. The extent of con-
tamination is really only defined  after detailed site investigation
and  characterization.   One  advantage  of  the  probabilistic
approach  is that  it helps the user to  organize the estimate and
see where uncertainty has the greatest impact. Monte Carlo simu-
lation of the cost  estimating procedure can be used effectively in
this application. This is superior to simply assuming all variables
simultaneously are at their maximum or minimum, respectively.
  Practical limitations to the application of this approach are:
• User sophistication in such an approach
• User knowledge of uncertainty in the data
• Execution time  for the model, especially on a PC
• Storage requirements for the additional data and program sub-
  routines

CONCLUSIONS
  The large amount of resources committed to Superfund remed-
ial actions make it very important that  thoughtful and accurate
cost estimates be  performed.  Cost-effectiveness decisions are an
important aspect of resource allocation and budget policy analy-
sis. Computerized cost estimation programs have a proven record
in other areas (e.g., construction, process equipment) for improv-
ing  the speed, accuracy and consistency of cost estimates. This
program is designed to address the special problems associated
with costing hazardous  waste  cleanup. These  factors  include
special worker safety considerations, geological factors and vari-
ous degrees of maturity  of  remedial action  technology (e.g.,
drainage ditches vs. biological treatment).
  It is hoped that this program will be a useful tool for U.S. EPA
personnel and contractors  through the detailed design stage of
remedial actions.  Strong emphasis was placed on the program's
user interface. Experience with other programs has shown this to
be essential in ensuring widespread usage. A minimum amount of
computer knowledge is required to allow the user to concentrate
on the application.


REFERENCES
I. Means, R.S., Means Cost Data Books. 1983, 1984.
2. Richardson Engineering Services, Inc., Construction Cost Estimating
  Standards, 1984.
3. Walsh, J., Lippett, J., Scott,  M., SCS Engineers, "Costs of Remed-
  ial  Actions of  Uncontrolled  Hazardous Waste  Sites—Impact of
  Worker Health  and  Safety  Considerations,"  EPA-600/D-84-019,
  1983.
326    RCRA SITE REMEDIATION & EXPANSION

-------
                   Using Cost/Risk  Analysis  in  Waste  Planning:
                               The New England Pilot  Project

                                                Debora C. Martin
                                    U.S. Environmental Protection Agency
                                                Washington, D.C.
ABSTRACT
  In the fall of 1984, the Office of Policy Analysis at the U.S.
EPA began a Pilot Project aimed at portraying the flows of haz-
ardous wastes in and around one  region of the country and at
characterizing the impacts of future changes in that regional waste
flow system. Selecting the New England six-state region as the
subject of the Pilot Project, staff from the U.S.  EPA's Inte-
grated  Analysis Branch and Temple, Barker and  Sloane, Inc.
developed a computerized model tying together data on the vol-
umes and locations of industrial wastes in each state, estimates
of the constituents present in each waste, the location and method
of treatment, storage or disposal for each waste, representative
exposure characteristics for each  location and available health
and ecological effects data.
  Working with representatives from state, local, environmental
and industry interests, a waste flow data base and  computer
model were developed—analysis of waste planning strategies is
currently underway and a similar project is beginning in another
region of the country. This  paper describes the Project approach
and Phase I findings.
INTRODUCTION
  The Amendments to  RCRA require that the United States
move away from the practice of land disposal of hazardous wastes
to alternatives that minimize present and future threats to human
health and the environment and encourage the reduction of haz-
ardous wastes at the point of generation. The New England Haz-
ardous Waste Pilot Project is hopefully one way to assist regional
and state decision-makers in implementing these broad goals by
pulling together what is known about a particular "waste  sys-
tem" so that the best strategies for  shifting to  alternatives to
land disposal and the best candidates for source reduction  can
be identified, given  what we know now about potential risks to
public health and the environment. Thus, the two major objec-
tives of the Pilot Project are: (1) to paint a believable picture of a
regional waste management system and (2) to use it, in conjunc-
tion with other information, to help point to the best waste man-
agement strategies given the particular mix and location of wastes
in that region.
  The paper is arranged in three sections; the first explains the
nature of waste flow data base developed for the New England
Pilot Project and, equally important, the process used to develop
and refine that data base. The second highlights other critical
data elements and methods that were  tied together in Phase  I of
the Project. The third is an overview of the cost/risk model to be
used in Phase II of the Project and of the kinds of scenarios to be
evaluated.
  In reading this paper, the reader should remember that, al-
though there is little argument about the advantages of develop-
ing better information about the movement and effects of haz-
ardous wastes, the acceptable and unacceptable uses for cost/
risk analysis in waste planning still are being identified by Project
participants. While the concepts of quantifying risks and focus-
ing on exposures across all environmental medium are not new,
to our knowledge this is the first attempt at applying these con-
cepts to regional waste planning issues.

DEVELOPING THE WASTE FLOW DATABASE
  Our first steps in developing a waste flow data base for a region
are to determine which wastes should and should not be counted
and to set in place a series of data collection activities and data
confirmation  processes.  Hazardous wastewater regulated by
water permits,  Superfund removals, waste  oils, asbestos and
PCB wastes are not included in the pilot analysis. These exclu-
sions are made to realistically approximate the annual amount of
waste to be managed in the region—or, the amount that might
need to be managed differently if capacity shrinks due to facility
closures.
  Superfund and wastewater exclusions are made based  on the
assumption that their inclusion artificially inflates the amount of
waste to be managed on  an annual basis. In other words, for
Superfund,  removals conducted in 1 year might not occur on an
annual basis and, for wastewater, there are few economic incen-
tives for redirecting the large volumes of wastewater currently
managed on-site to other types of treatment facilities. (The waste-
water exclusion applied to wastewater that is treated  in a treat-
ment system permitted by the National Pollutant Discharge Elim-
ination System but is reported as hazardous waste under the Re-
source Conservation and Recovery Act programs; in one of the
states studied, inclusion of these wastes  would have increased the
 volumes of hazardous waste to  be managed  by almost  80%.)
 Similarly, it is assumed that waste oils, PCBs and asbestos require
 specialized treatments and, hence, there are few alternative treat-
 ment options to explore. These assumptions are easily changed
 and some are changing in the second regional analysis.
   The project team begins with the information that each state is
 required to submit reports to the federal government on a biennial
 basis and the annual reports required by some state governments.
 These reports, and the detailed data they are drawn from, often
 do not  provide all the information needed to  accurately reflect
 the flows of waste between generators and waste management
 facilities. Thus, meetings with various project participants, fol-
 lowup with state officials, generators, waste managers  and,  in
 some cases, the process of elimination play an essential role  in
 creating the instant picture of the regional waste flow system.
                                                                                                RISK ASSESSMENT    327

-------
  Two groups of project participants assist the New England
Pilot Project team by serving as reality checks on the data base
as it  develops. First, the  Regional Coordinating  Committee
(RCC), includes a small group of representatives from regional,
state, local, environmental and industry groups who have exper-
ience  or  strong interest in hazardous waste  management issues.
Individuals associated with the New England Council, the New
England  Environmental Network, the Vermonters Organized for
Cleanup, the Tufts Center for Environmental Management, the
New England Congressional Institute, the  New England Gov-
ernor's Conference, the New Hampshire  Governor's Office, the
Rhode Island League of Cities and Towns, the Connecticut Haz-
ardous Waste Management Services, the  Small Business Admin-
istration of New England are members of the RCC. Second, a haz-
ardous waste  staff in each of the states  provides assistance by
directing the project team to the best sources of data, reviewing
the data base for their state and helping  to reconcile differences
between  the Project data base and other data  sources.
   Much  is learned in the process of confirming waste flow dates.
For example, generator annual report information  often  is not
appropriate for determining what  types of treatments are being
applied to shipped wastes  once they reach their final destination.
This is especially true where transfer stations arrange  for land-
filling or incineration is actually occurring at the  transfer station.
Review of facility annual reports or personal  followup with waste
management facilities is necessary to determine if, in fact, the re-
ported treatment and disposal technologies exist  at the facilities.
Also,  facility  closures sometimes occur after annual or biennial
reports are submitted. In these cases the team  works with the
states  to determine, where possible,  which facilities the affected
generators are currently using.

Data Base Description
   There are almost 15,000 computerized waste  records describ-
ing the New England waste flow system. Each waste records con-
tains types of waste generated by the U.S. EPA waste code, the
U.S. EPA generator identification number,  the Standard Indus-
trial Classification (SIC) code for  the generator, the amount of
waste generated and treated on-site,  the amount  of waste gener-
ated and treated  off-site,  the U.S. EPA  TSD number for treat-
ment,  storage and disposal facilities receiving the waste, the type
of treatment (by U.S.  EPA Appendix I  Code) being performed
at the  facility and the community location for generators and re-
ceiving TSD facilities.
   After  exclusions, the current data base tracks 326 thousand
metric tons generated  by  industrial  sources  across the  six New
England states. Since this figure is based on required reporting
mechanisms, it does not pick up any generators who fail to report
their  wastes. Thirty thousand  metric  tons  are  generated from
waste  management facilities,  including  both wastes that pass
through  transfer stations  and residuals  from waste treatments
such as solvent recovery.
   The highest  volumes of wastes  tracked in New England are
various  wastes  from  electroplating  operations, solvents and
wastes reported as "otherwise  unlisted corrosive or ignitable"
wastes. One third of the waste is treated by chemical, physical or
biological treatment processes located inside or  outside the reg-
ion,  excluding solvent recovery operations  which account for
about 10% of the total waste treatment load.
   Regionally,  about one-half of the  waste is treated  on-site (in-
cluding the amount in storage at the end of the year)  and one-
half is treated off-site, with a little less than 50% of the waste that
is shipped to commercial facilities going outside of the region for
treatment,  most to facilities in New York  and New Jersey. Figure
1  provides state-by-state summaries of the  amounts of wastes

9O -
SO •
70 -
? S°-
§
3
O
!§. 40 -
30 -
20 -
1O -
T
^
/
^
^
/
'.
/
/
/
/
/
/
/
/
/
/
/








^
\
\
\
\
\
\
N
S
s

J

7-

'.
/
/
/
/
/




i
\ Yt « n-i TfAvm . , mRl frrfTTI 171 rTJtK
CT MA NM VT Rl UE
1771 ON-SITE [V3 OFF/IN g%Zl OFF/OUT PS53 OUT NE
                          Figure 1
                  Waste Flows in New England
                      (1983 Metric Tons)
treated on-site and treated off-site in the same state, in  one of
the other states in the New England region and in other regions
of the country.

PREPARING FOR STRATEGY ANALYSIS
  A computer model, designed to analyze planning strategies in
four ways, is developed to support the Hazardous Waste Pilot
Project through the strategy analysis phase. The model calculates
changes in the probability of health effects across the  region as
measured  by potential changes in  the concentrations  of waste
constituents transferred to air, surface water and ground water;
exposed populations; and  dose-response information for various
health  effects. In separate modules, it relates the same changes
in concentrations to environmental effects measures and relates
the changes in the distances that waste is shipped to transporta-
tion risk measures. Finally, it calculates changes in regional costs.
To perform these analyses, several data elements described below
are assembled.

Constituents, Concentrations, Costs and
Capacity
  The  constituents  and concentrations of constituents present
in each hazardous waste stream are estimated based on average
or typical  characterizations used in other projects conducted by
the U.S. EPA. The certainty associated with each waste stream
that is characterized varies.' For example, there is more certainty
about the constituents and concentrations of discarded off-specif-
ication product  wastes  than  with wastes that  are reported as
"ignitable, not otherwise listed."
  Costs for on-site treatment, storage or disposal are, for the
most part, based on the capital and  operating costs developed
for the various waste management methods in other studies con-
ducted by the U.S. EPA.' They are annualized and divided by
the annual operating volumes to determine cost per ton or cost
per gallon for various waste types. Prices rather than operating
costs are used for off-site facilities, generally based on Massa-
chusetts cost data.1
  A capacity file is assembled to help assure that strategies for
redirecting waste flows are realistic. In other words, if we move
something to another  facility  to reduce risk, is there really room
for it?  Most of the information gathered to date relates to larger
commercial facilities.
328    RISK ASSESSMENT

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Characterizing Potential Exposure
  The exposure  characteristics  identified in the model  are not
based on site-specific data in the strictest sense.  Rather, they are
designed to eventually assist in pointing to large differences  in
exposures between areas. If and when significant differences are
found, some check against real monitoring data will need to be
made. Currently, the location of generators and handlers of haz-
ardous waste is characterized according to the closest major com-
munity, the approximate latitude and longitude of the commun-
ity, population and general air, surface water and groundwater
conditions. These environmental factors are used with fate and
transport models and waste volume data to calculate the changes
in exposure (i.e., changes in concentrations) that may result under
various   waste  management  scenarios. Each  waste handling
method is assumed to have some potential route of environmen-
tal release and some probable amount of release. These potential
releases may be routine (as in the case of air releases from incin-
eration) or episodic (as in the case of spills around many types  of
treatment facilities).1
  Specific release routes for storage technologies include volatil-
ization into air routinely or as  a result of spills, migration into
surface  water from  overtopping or spilling, and seepage into
groundwater from contaminated leachate or spilling. The routes
for treatment and  disposal technologies are similar, but also in-
clude for thermal  treatment,  consideration of residual organics
and metals emitted into the air, scrubber discharge into surface
water and potential leaching from residues. For chemical treat-
ment,  potential equipment  failure is  included;  for  biological
treatment, effluent discharges to surface water are included.
  Although disposal via underground injection or ocean disposal
is not currently practiced in  New  England, these management
methods are modeled for use in future studies.  Possible well head,
case or  formation  failure are  considered for underground injec-
tion, as well as the obvious fate of ocean-disposed wastes.'
  To convert mass air  emissions into ambient concentrations,
conversion factors for point sources and area sources are used for
five concentric distances ranging from 1.05 km to 35 km.4 Storage
facilities, oxidation/reduction  facilities,  stabilization/fixation
facilities, biological treatment and  landfills are  modeled as area
sources while thermal treatment and solvent recovery are modeled
as point sources. All communities in the study are assumed  to
have similar air  environments described by an afternoon mixing
height of 1200 m and an average ambient temperature  of 7°C.
This assumption is made after reviewing data on  mixing height,
temperature,  wind velocity and precipitation for New England
weather star stations and finding insignificant differences.
  For surface water,  each community environment included  in
the analysis is assumed to contain  one of three types  of surface
water environments: a small coldwater stream with low flow less
than 3 m'/sec and a maximum temperature less than 25 °C; a med-
ium coldwater stream with a low flow between 3  and 30 mVsec
and a maximum temperature  less  than 25 °C;  or a large cold-
water river with a low flow greater than 30 mVsec and a max-
imum temperature less than 25 °C. Mass loadings are converted
to concentrations across five stream compartments for  three cate-
gories of pollutants including metals, high transformation pollu-
tants and low transformation pollutants.'
  Groundwater  environment characterization involves gathering
and reviewing  information  on hydraulic  conductivity,  linear
velocity and depth to groundwater. These data are matched  to
three representative flow field environments, all assuming a single
shallow aquifer. The first flow  field is characterized by an aver-
age linear groundwater velocity of 10 m/yr in the horizontal direc-
tion and 1 m/yr  in the vertical direction, the second by a velocity
of 100 m/yr in a horizontal direction and 10 m/yr in  a vertical
direction and the third by a velocity of 1000 m/yr in a horizontal
direction and 100 m/yr in the vertical direction. The model used
to convert loadings to concentrations in groundwater assumes
that exposure points are directly downgradient of the source of
contamination  and that aquifer thickness is constant.' Concen-
trations are calculated  at 600 m for total population exposure
and at 60 m to calculate a maximum individual exposure.
  The concentrations  that are calculated  represent an average
over the first 70 years after initial contamination. This assump-
tion is made to  deal with the timing problem associated with
comparing and summing potential risk across air, surface water
and groundwater. Concentrations of substances in air and surface
water occur within a short time-frame and thus can be measured
using annual averages. However, concentrations of substances in
groundwater may not appear for several years and, assuming that
they occur in the first year, may lead to an over-estimation of
potential  risk given current monitoring and corrective action
activities. Nevertheless, the current assumption and others easily
can be changed to determine worst case or best case scenarios.
  Finally, populations for each of the five  distances used to cal-
culate air concentrations  are stored in the computer model for
each community  environment, as well as an estimate, based on
the largest town   in the  35-km area,  of the  percentage of the
population drawing drinking water from groundwater sources.8
These percentages are 100%,  75%, 50%, 25%  or 5%, and the
balance of the drinking water is assumed to be drawn from sur-
face water sources.

Health Risk, Environmental Risk and
Transportation Risk
  Available data on potential health effects  from exposure to
various pollutants are obtained and used to define dose-response
relationships. These relationships eventually are employed to esti-
mate  incidences of health effects given  various exposure levels.
Health effects  are  classified into seven broad categories—can-
cer, reproductive effects, liver effects, kidney effects, fetal devel-
opment effects, neuro-behavioral effects and  other effects. The
sum of estimated  incidences across effects and pollutants for each
waste handling strategy is the health risk score for the strategy
in the analysis phase. Currently, dose response curves are avail-
able for approximately 30 constituents of various  hazardous
wastes, and others are being researched on an ongoing basis.
  The environmental effects component consists of an index of
"ecological integrity" based on dose response information devel-
oped  for aquatic populations only. These dose response relation-
ships are constructed after review of available data on the effects
of  pollutants on aquatic organisms and are used to estimate
potential impacts on finfish, vegetation zooplankton, macroin-
vertebrates and non-fish vertebrates resulting from increases or
decreases in chemical discharge to surface water bodies.
  For transportation risk, an average risk per  km of 0.45 per
million truck km  for a releasing hazardous waste accident is used
to assess changes  in transportation risk.' This calculation is based
on  the probability of a releasing accident on  a composite high-
way trip (interstate, state and urban).

ANALYSIS OF WASTE MANAGEMENT
STRATEGIES
  The project team has three objectives in Phase II of the Pro-
ject. In the broadest sense, the team is trying to determine to what
extent this type of  approach can benefit waste planning  decis-
ions as measured  by the reception of the analyses by project par-
ticipants  from local, state, regional, environmental and private
concerns.  Analytically,  the team is trying to determine if meas-
urable and significant changes occur when the waste system  is
                                                                                                     RISK ASSESSMENT    329

-------
changed in a variety of ways given what we know now about the
characteristics and effects of hazardous wastes in the environ-
ment.  Finally,  in  tying together all  available information, the
team is trying to determine where the biggest data gaps are and
how important or insignificant they are to waste management de-
cisions.
  The kinds of strategies  that the project team currently is test-
ing include a series of "what if" questions ranging from waste
reduction queries to treatment capacity issues.  For example, what
if all  electroplaters—identified by SIC code in the data base-
could implement a particular waste reduction initiative? Or, what
if the  ratio  of on-site  versus off-site treatment changes? Will
either  of these scenarios show significant increases or decreases
in potential risks and costs?
  The kinds of strategies  to be evaluated in the coming months
depend largely on the  interests  of projeci participants.  These
strategies will be analyzed  using the computer model.

The Computer Model
  All data elements and exposure algorithms are linked in a fairly
large  but conceptually simple computer model. In the  baseline
analysis, the computer  model relates volumes and locations of
wastes (broken down by constituent  concentrations) to the pos-
sible  environmental releases  and  exposure conditions around
waste  management facilities and to the health and environmen-
tal effects associated with each waste  constituent. Baseline trans-
portation  risk and baseline  costs  are computed  in separate
modules.  Thus, the model works as  shown in a simplified flow
chart (Fig. 2).
VOLUMES OF BASTES
OR DISPOSED BY
WASTE TYPE AND
CONSTITUENT


	 >

EXPOSURE ACROSS
ENVIRONMENTS ,
WASTED, AND
CONSTITUENTS


	 >

REGIONAL RISK
METHOD, WASTE,
AND CONSTITUENT

           MILES WASTE IS
           TRANSPORTED FRO*
           GENERATOR TO
           TREATMENT STORAGE,
           OR DISPOSAL FACILITY
            ANNUAL COSTS OF
            TRtATMENT, STORAGE,
            AND DISPOSAL
REGIONAL
COST
                           Figure 2
     Flowchart Describing Baseline Transportation Risks and Costs
  The first step  in analyzing a strategy is to identify the key
changes that need to be made to the baseline situation. For source
reduction scenarios, this means the percentage of waste and kinds
of waste that might be reduced on  an annual basis.  For shifting
wastes to alternative facilities, either existing or new, the amounts
and  kinds of waste to be shifted and  the alternative facilities,
facility locations and treatment operations must be identified.
These changes are entered into the model to compute new risk
scores, costs and transportation accident probabilities. These re-
sults  then are compared to the baseline results to determine if
significant changes occur.
  After the changes are  calculated, the next step is to "dissect"
strategies to determine why  the changes occur. The purpose of
this important step is to see  to what extent general  changes are
driven by volumes of waste, waste  characterizations, environ-
mental settings and/or amounts of available effects information.
 In this way, we can begin to determine the relative importance of
 the many variables involved and to highlight critical uncertainties
 and data gaps.
  There are some important questions that this kind of analysis
 cannot answer. While it provides a context for comparing, across
 environmental media, the risks and  costs of a variety of waste
 management options at various locations, it does not compare the
 risks  at waste handling  operations to the risks  associated with
 other industrial operations at the same locations. This is prob-
 ably a valuable piece of information to communities which might
 be asked to accept risks associated with new waste treatment facil-
 ities,  no matter how minimal they appear relative to other pos-
 sible locations.

 CONCLUSIONS
  The New England Hazardous Waste Pilot Project is one way to
 assist in implementing the goals of federal and state legislation.
 In Phase  I we've learned that there is, in particular, a need  for
 better understanding of waste flow systems from a state, regional
 and possibly national perspective. We have learned that  by  re-
 solving  definitional   issues and  involving  key interests  in  an
 attempt to quantify  amounts of waste can dramatically change
 perceptions of the magnitude of a particular hazardous  waste
 system.
  In Phase II, the team will work to develop ways of maintaining
 waste flow information on an ongoing basis and continue to work
 with  project  participants  to analyze  waste  planning  strategies.
 By  continuing to work with participants  from the New England
 states and U.S. EPA officials, we hope to refine both the data
 and methods  used in the approach and to determine acceptable
 and unacceptable uses for Projeci outputs.

 REFERENCES
 I. ICF Incorporated, "The RCRA Risk-Cost Analysis Model Phase III
   Report," Submitted to the Office of Solid Waste Economic Analysis
   Branch, U.S. EPA,  Mar. I, 1984.
 2. Massachusetts Department of Environmental Management,  "Haz-
   ardous Waste Management in Massachusetts Environmental Impact
   Report," 1982.
 3. "1983 Connecticut  Hazardous Waste Generation and Management
   Analysis,"  ERM-Northwest,  Incorporated, Feb.  1985. "Environ-
   mental  Impact  Report,"  Massachusetts  Department of Environ-
   mental  Management, 1984. Telephone contacts  with Slate environ-
   mental program staffers in Vermont.
 4. Temple, Barker &  Sloane, Incorporated, "Risk and Cost  Assess-
   ment of Hazardous  Waste Incineration Regulation," (Draft), "1984
   Methodology adopted from Inhalation Exposure Methodology
   Modeling of Hazardous Waste Incinerators,"  prepared by MidWest
   Research Institute, 1984.
 5. Temple, Barker & Sloane,  Incorporated, "Foundry Industry Method-
   ology," 1983, methodology and results prepared by Arthur D. Little,
   Incorporated using EPA EXAMS Model.
 6. Ocean dumping exposure and risk assessment is taken from GCA's
   earlier sludge work, "Ocean Disposal of Sewage Sludge, April  1985."
   This work is currently being re-done by Aqua Terra  Consultants and
   we will  incorporate the  new results  into the  Regional  Hazardous
   Waste Model as appropriate.
 7. Geraghty & Miller,  appendix B to "Liner Location Risk and Cost
   Analysis Model," 1984, groundwater dispersions adopted from  the
   Random Walk Particle Tracking Model of Prickett, el al.
 8. For populations, U.S. EPA GEMS Modeling System is used;  for
   drinking water assumptions, U.S. EPA Office of Drinking Water Fed-
   eral Reporting Data Systems (FRDS) was used.
9. Albowsty, el al.. "Assessing the Releases and Costs  Associated with
  Truck Transport of Hazardous Wastes," 1984.
330    RISK ASSESSMENT

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                 Assessment of Potential  Public  Health Impacts
                       Associated  with Predicted Emissions  of
                         Polychlorinated  Dibenzo-Dioxins and
                       Polychlorinated  Dibenzo-Furans  from a
                                  Resource Recovery Facility
                                             David Lipsky, Ph.D.
                                            Dynamac Corporation
                                             Fort Lee, New Jersey
ABSTRACT
  This paper provides summary results of a risk assessment per-
formed by Fred C. Hart Associates for potential dioxin-related
impacts associated with a proposed resource recovery facility to
be constructed in  New York City by the NYC Department of
Sanitation.
  With the assumptions used in this risk assessment, the max-
imum increased cancer risk due to the complex mixture of PCDDs
and PCDFs present in the emissions ranges from less than 0.24 to
an upper-bound limit of less than 5.9 x 10~6 for inhalation, in-
gestion and dermal absorption exposure pathways combined. In
our opinion, within the context of the assumptions used in the
risk assessment,  the methods used to estimate risk and consider-
ing current regulatory practice regarding acceptable versus unac-
ceptable health risks, a worst-case upper-bound excess cancer risk
less than 5.9 x  10-6 is below levels found by many regulatory
agencies to require additional  review and probable action to
reduce risk.

INTRODUCTION
  The facility,  known as the Brooklyn Navy Yard Resource
Recovery Facility (BNYRRF), will be a 3,000 ton/day mass burn
facility that will include four 750 ton/day combustion units and
will incorporate the Martin stoker system.  The BNYRRF will
have natural gas auxiliary burners located at the point where
secondary air will be injected to maintain a minimum secondary
combustion temperature. Emission control systems will include a
high-efficiency (greater than 99.5%) fabric filter to meet an outlet
particular emission loading of 0.015 gr/dscf at 12% CO2. This
particular emission rate is well below the Federal New Source Per-
formance Standard (40 CFR 60.52) and the New York State emis-
sion limitation (Part 222). Subsequent to our completion of this
risk assessment,  a dry acid gas scrubber system was added to the
proposed pollution control ensemble.
  The risk assessment was completed after an extensive examina-
tion of the literature focusing on the high temperature behavior of
dioxins in incinerators. Reports of laboratory studies as well as
sampling and analysis data on flue gases from actual incinerators
were included. As  part of the risk assessment, the predicted am-
bient air concentrations and daily intake of polychlorinated di-
benzodioxins  (PCDDs)  and  polychlorinated  dibenzofurans
(PCDFs) were compared to applicable standards and criteria and
concentrations of  PCDDs and  PCDFs  known or suspected to
cause a toxic effect. As discussed below, a number of conservative
assumptions were utilized  in the risk assessment.
EXPOSURE ASSESSMENT
  Emission test data from a number of incinerators have demon-
strated a wide range of PCDF and PCDD emissions spanning
several orders of magnitude. However, the lowest emissions were
observed from incinerators with  the  same  basic design as the
BNYRRF. Actual emission data  from operating municipal re-
source recovery facilities were used to  predict PCDD and PCDF
emission rates from the BNYRRF. In selecting the test data, the
objective was to utilize data from facilities similar  in design,
operations and waste types to the BNYRRF. Furthermore, test
data had to be obtained using sampling methods that are compati-
ble with methods approved  by  the  U.S.  EPA for  sampling
organics in flue gases under rigorous quality control procedures.
The emission data selected as the most representative were ob-
tained fromthe Chicago Northwest facility1  and the Zurich-
Josefstrasse  facility.2 Both use a  furnace design similar to that
proposed for the BNYRRF; however, both use electrostatic pre-
cipitators rather than fabric filters for fly ash emission control.
  If the PCDFs and  PCDDs are emitted wholly in gaseous form,
then the emission data obtained from similar systems could be ap-
plied to the BNYRRF, regardless of pollution  control  system
dissimilarities. If the PCDF and PCDD materials are wholly ab-
sorbed onto particulate matter, more  of these materials  will be
trapped in the fabric  filter than in a comparably sized electrostatic
precipitator. Measurement data show generally higher concentra-
tions of PCDFs and PCDDs on emitted fly ash than  on  fly ash
trapped in electrostatic precipitators, indicating  a relationship
that is influenced by particle  surface area.  By utilizing particle-
size data and an assumption that PCDF and PCDD materials are
absorbed onto fly ash in proportion to the available particle sur-
face area, calculations were made concerning the amounts col-
lected and emitted.
  Since the partition between gas and  solid forms is not known,
emissions were calculated in two ways: (1) assuming all PCDF and
PCDD materials observed at the test facilities are gaseous and (2)
assuming all PCDF  and PCDD  emissions observed at the test
facilities are particulate.  If the emissions contain both gaseous
and particulate PCDFs and PCDDs, then the emission rates will
fall between these values. These emissions,  corrected for the size
of the BNYRRF, are shown in Table 1 as mass rates per unit time.
  To  assess the impact  of  the  emissions  from the  proposed
BNYRRF on the general population, computer modeling was per-
formed on the emission data presented above to predict down-
wind concentrations of PCDFs and PCDDs in the ambient air,
soil, dust and dirt. The predictions of ambient air concentrations
                                                                                           RISK ASSESSMENT   331

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                           Table 1
        Summary of Predicted PCDF and PCDD Emissions
          Brooklyn Navy Yard Resource Recovery Facility
                     (Outlet of Fabric Filler)
      TH-CDF
      Tetri-COF
      Ptnti-CDf
      Hoi-CDF
      Hepta-CDF
      Octa-CDF

      Ton I-CDF
      Trl-CDD
      Tttrt-CDD
      F-tnla-COF
      H««a-CDO
      Hepta-CDD
      Octa-COO

      Total-CDO
      2.3,7,6 T«tra-C00
51.16
15.35
 4.43
10.56
 1 28
 0,10

82 92
 2.22
 1.07
 1.79
 2.73
 1.30
 0.43

 9.54
   Cast 2
All Partkulau
  Emissions
  (ua/itc)

    23.95
    7.18
    2.07
    4.94
    0.60
    0.05

    38 79
    1.03
    0.51
    0 83
    1.28
    0.61
    0.20

    4.46
Case 1:  assumes all PCDF and PCDD materials are gaseous, therefore no additional collection
occurs in fabric filler above that collected by an electrostatic precipitator.
Case 2:  assumes all PCDF and PCDD materials are adsorbed on paniculatcs, therefore additional
fly ash collection in fabric filter reduces PCDF and PCDD emission.
  The emission rales may vary between these values if there arc gaseous and paniculate fractions
of PCDF and PCDD emissions.
of PCDFs and PCDDs quantify potential population exposure
through  the inhalation  pathway, while the deposition analysis
provides a quantification of potential human  exposure through
ingestion of contaminated dirt and dust as well as through dermal
contact with these materials.
  The model used for analyzing air quality impacts resulting from
the BNYRRF stack  emissions was the Multiple  Point Source
Gaussian Dispersion  Algorithm  with  Optional Terrain Adjust-
ment (MPTER) modified  specifically for use in the urban en-
vironment. When using this dispersion analysis methodology and
the PCDF and PCDD emission calculations from Case 1 and Case
2 of Table 1, it is assumed that all PCDFs and PCDDs are emitted
and that they behave in the atmosphere as a gas. Application of
these emission rates to  the maximum normalized concentrations
results in the maximum annual average concentrations shown in
Table  2.  Since these concentrations of PCDDs are extremely
small,  the units  presented are picograms/m'  (pg/m*  or 10-'2
g/mJ).
   In Case 2, it was assumed that all dioxins entering the fabric
filter enter attached to particulates. Those particulates that escape
the fabric filter, if heavy enough, will deposit on ground surfaces,
mixing with dust, dirt and soil for potential uptake through inges-
tion or dermal  pathways. To determine the rate at which the par-
ticles  settle to the  ground, a  computer model  with specific
capability  to analyze particulate deposition rates was selected.
This  model  is the  Industrial  Source Complex  (ISC) model
developed  under the sponsorship of the U.S. EPA by a private
contractor.'
   The maximum concentration of PCDDs in soils was estimated
by assuming a one centimeter mixing zone and a soil density of 1.6
g/cm' and estimating a build-up over a 20-year  period. The
estimate is clearly conservative, with no losses due to volatiliza-
tion, degradation or physical clearing.
   PCDD levels in  home dust  and street dirt  on  a  surface area
basis as opposed to a weight basis also were used in the estimate of
risk.  By  comparing  indoor deposition  and  accumulation  to
measured  lead data,  the  maximum  deposition  on floors was
estimated at 25% of the outdoor rate with a 30-day period of ac-
cumulation."
   There is some evidence to suggest  that a 30-day accumulation
period is overly conservative. The data provided by Solomon, el
a/.,' if extrapolated, indicates 0.6 10  1 g dust/m^  in single family
urban middle class homes (gas heated) in Champagne-Urbana, Il-
linois.  His data,  if applied  to the PCDD and total particulate
deposition rates,  would indicate that steady state conditions for
dust buildup in homes would be reached in 3 to 5 days.
   For  outdoor deposition,  the  accumulation  period in urban
streets is unknown. The Swiss EPS, in its assessment of dioxin
emissions from incinerators, used an estimated half life equal to
14 days for rural environments.2 Consistent with  this Swiss EPA
assessment, we have assumed a 30-day period of accumulation as
a reasonable accumulation period.
   Using the deposition model, the concentration of PCDDs in
street  dirt was determined  by dividing the PCDD deposition rate
by the  average  particulate deposition rate   from non-dioxin
sources. The deposition rate of non-dioxin particulates in Brook-
                                                             Table 2
  Predicted Maximum Exposure Concentrations of PCDFs and PCDDs Due to  Emissions from the Brooklyn Navy Yard Resource Recovery Facility


Trl-COF
Ttlra-COF
Ptnta-COF
Haia-CDF
H>pta-CDF
Octa-CDF
Total-CDF
Trl-CDO
Titra-CDD
P«nti-C00
Htia-CDD
Htpta-COD
Octa-COD
Total -COD
2.3.7.8 Tatra-CDO
Can 1: >CDF and fCDO
lilnloni Art Castoui.
Hixiaua Conctntratfon
In Air (pg/ar)
1.2281
0. )(84
0.1063
0.2539
0.0)0?
0.0024
1.9900
0.05)]
0.0257
0.04)0
0.0(55
1.0112
0.0101
0. 2290
0.001(8


Nanlatu* Concanlrallo
(n Air (po/.'l
0.574?
0.1721
0.0497
0.1187
0.0144
0.0011
0.9)09
0.0241
0.0012
0.0120
0.0)06
0.0146
0.0049
0.08*2
0.000782
CM. 2; All KOF and

n Haxlstai Ajmuil
Dapoilllon Ilia (m
4.790
1.43«
0.414
0.990
0.120
0.009
7.759
0.208
0.101
0.1(7
0.25(
0 122
0.041
0.195
0.0065
KDO Eiliilant Art Adiortad



. In Sail A(Ur Concantratloni In )
!/•*) OM Y.ar («J/j) Slr.it Dirt (iu>/a) II
299
90

e«
g
O.fe
4B&
._
*
10

1

M
0.41
44

.
13

0.1
104
j
]
2

J
«fij
12
0.087


IHIUy Acci^litlo
toufti Dust (DQ/B )




I*
.3
1U


Jc
, 9

2.S
_jj
i«
0.135
         Notes: The concentrations presented in this table assume no chemical/biological degradation or transformation of PCDF and PCDD compounds.
         pg/m^ — picograms per cubic meter
         ng/m^ — nanograms per square meter                 Pg/12 ~ picograms per gram
         fs/g — fentograms per gram                       pg/irr — picograms per square meter
332    RISK ASSESSMENT

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lyn was measured at 74 g/mVyear." Table 2 shows the average an-
nual deposition rate for 2,3,7,8-TCDD equal to 0.0065 ng/mV
year. At any point in time, this material is being diluted by 74
g/mVyear  of particulates from non-dioxin sources. Therefore,
for the purpose of this assessment, we predict a maximum 2,3,7,8-
TCDD concentration to equal 8.8 x 10-14 g/g of street dirt. This
is  a highly  conservative estimate, since the dioxin containing fly
ash will be diluted not only by other airborne particulate matter
but also by lint,  dirt, gravel, etc. already present on the surface.
The  estimates are particularly conservative in that no degrada-
tion, volatilization or  physical cleaning (e.g., runoff to storm
sewers) of TCDD is assumed.
   On a weight to weight basis, TCDD concentrations in home
dust were assumed to be equal to the concentration in street dirt,
an assumption which is used by CDC in its risk assessment and
supported by some studies of lead contamination in indoor versus
outdoor environments.3

RISK ASSESSMENT
   A risk  assessment  was  performed  to  estimate the  risks
associated  with predicted maximum PCDD and PCDF concen-
trations in ambient air, soil, dust and dirt  downwind of the
BNYRRF.  The assessment compared the predicted ambient air
concentrations and estimated daily intake levels for PCDDs and
PCDFs with: (1) applicable standards and criteria; and (2) con-
centrations of PCDDs and PCDFs known or suspected to cause a
toxic effect.
   Several conservative assumptions were incorporated into our
assessment. They include the following:
•  Use  of worst-case assumptions for three potential pathways of
   exposure: inhalation of gaseous or particulate emissions,  in-
   gestion and/or dermal absorption of particulates deposited on
   outdoor  and indoor surfaces. Typically,  risk assessments of
   point source emissions assess risks only for the inhalation path-
   way.
•  Application of a toxic equivalency multiplier equal to 59. This
   number provides an estimate of the non-carcinogenic toxicity
   of the complex mixture of PCDDs and PCDFs compared with
   the concentration of 2,3,7,8-TCDD.  This  equivalency factor
   also was used to estimate carcinogenic equivalency as a worst-
   case assumption although such an application is  speculative.
•  Reductions in potential PCDD  and PCDF concentrations in
   the environment due to volatilization or degradation or losses
   due to such actions as rainfall were not considered.
•  Exposure assessments for ingestion and dermal pathways were
   done for both indoor and outdoor exposure; although build-
   ings may have a filtering effect on airborne particles, indoor
   dioxin concentrations were assumed to be as high as outdoor
   ambient  concentrations  for  the analysis by  the  weight ap-
   proach.
•  Risks were calculated based on  exposure for 24 hours a day,
   over a 70-year lifetime, at the point of maximum impact.
•  No threshold for a safe level of dioxin exposure was assumed;
   any exposure to dioxin was assumed to pose some health risk.
   Moreover,  of  the accepted  models for extrapolating the po-
   tential risk of very low level exposure, the  most conservative
   model factor was used.
•  Conservative assumptions for bioavailability and rates of in-
   gestions  and dermal contact were included to estimate worst-
   case daily intakes of PCDDs and PCDFs.

   The  results of our risk analysis  are summarized below. Max-
imum average annual ambient air  concentrations (Table 2) were
predicted for ground-level and elevated receptors assuming that
all PCDDs and  PCDFs are emitted as  a gas. The maximum
average annual  ambient air concentrations are predicted  to  be
well below existing standards and guidelines  typically less than
1%. Only the NYSDEC performance guideline for evaluating
combustion sources  is  approached  but at only  28% of  the
guideline.
  Risks associated with inhalation of PCDDs and PCDFs  at the
maximum  average  annual  concentrations were  determined  by
comparing a predicted maximum daily intake through inhalation
(DIinh) with Acceptable  Daily Intakes (ADIs) and  cancer  dose/
response extrapolations.  The assumptions used to calculate DIjnh
are provided in Table 3.

                           Table 3
 Upper-Bound Estimated Percentage of Acceptable Daily Intake (ADI)
  Attributable to Inhalation of PCDD and PCDF Emissions from the
         BNYRRF at Ground Level and Elevated Receptors

                          Acceptable Daily Intake (ADI)
                 Canada ...Netherlands,,,   NYSDOH ,,„,    CDC   ,..,
               10 pg/kg-day(B) 4pg/kg-dayti>) 2pg/kg-dayt1"' l.Spg/kg-day"1'
Upper-bound
Daily Intake-
Inhalation
Pathway

2,3.7,8-ICDO(a)
(2.7 > 10"4pg/kg-day)


TCDD'")
(4.2 x 10~3pg/kg-day)
 TCDO Toxic
   Equivalency^'
 (1.6 x 10"2 pg/kg-day)
                  0.0027X
                 0.16X
                           D.007X
                           0.11X
                          0.40X
                                      0.014X
                                      0.21X
                                    0.80X
                                                 0.23X
                                                0.89X
Assumes
  DIinh (g/day) = PCDD (g/m3) x ventilation rate (mVday) x particulate reten-
  tion (%) x bioavailability (%)
  75% of the inhaled particles are retained by the body12
  15 m3 of air are exchanged in one day"
  100% of the inhaled particles are bioavailable
  Maximum ambient air concentration of 2,3,7,8-TCDD equals 0.00168 pg/m3
  70 kg/person inhaling .00168 pg/m3 of 2,3,7,8-TCDD
(a) DIinh  (pg/kg-day) = DIinh  (g/day)/70kg = 1.9 x 10"2 pg/day/70 = 2.7 x
   10-4 g/day
(b) DIinh (TCDD) = DIinh (2,3,7,8-TCDD X  15.5)
(c) DIinh  (Toxic Equivalents) = DIinh (2,3,7,8-TCDD x 59)


As shown  in Table 3,  the  maximum daily intake DIinh of
2,3,7,8-TCDD, TCDD and TCDD toxic equivalents are predicted
to be well below (less  than 1%) any ADI promulgated by any
regulatory agency. These ADIs provide a margin of safety and
they identify a very safe dose, below which risks are insignificant
for non-carcinogenic toxic effects.
  An upper-bound to carcinogenicity risk was also determined by
comparing  DIinh with  three  different  cancer  dose/response ex-
trapolations. The most conservative dose/response extrapolation
is that used by the U.S. EPA (unit risk estimate equal to 1.56 x
10~7).7  As shown in Table 4, the upper-bound excess risk due to
exposure to 2,3,7,8-TCDD and HCDD, at the point of maximum
impact, ranges from less than .0019 to less than 0.055 X 10-6 or
less than six cases per 100 million people exposed to the maximum
concentration over a 70-year  lifetime.
  The sensitivity of the risk estimates  derived for the inhalation
pathway to the additional risks that might be  attributable to the
ingestion and dermal pathways was  tested. These two pathways
were not considered in the initial risk assessment of the inhalation
pathway due to the high degree of uncertainty in the  estimates of
ingestion, absorption and bioavailability rates and due to the dif-
ficulties in modeling PCDD concentrations in soil, dirt and dust.
                                                                                                     RISK ASSESSMENT    333

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                             Table 4
    Upper-Bound Estimated Increased Cancer Risk for Population
     of One Million People Exposed for a 70-Year Period to (he
         Maximum Daily Intake via the Inhalation Pathway

                       Dose for  1 x IQll Excess Cancer  Rlak
                       Klmbrough     Klmbrough      EPA
                       (1.4 pq/kq-    I .028 MAa±   I .0064 pq/Ra-
                         day)         day)          day I

                       Upper Bound Excesa Riik for 70 Kg man
        Daily Intake

        1.9 x 10-2
         pg/day
        (2.J.7.8-TCDD)
        0.15 po/day
        (1,2.3.6.7,1
        and
        1.2.3,7,8.9-HCDDI
A range of  daily  intake  estimates was calculated (DIing and
Dldertn)- Tne assumptions used to calculate DIing and DIdcrm are
provided in Tables  5 and 6.

                             Table 5
          Estimaled  Daily Intake of 2,3,7, 8-TCDD through
                      the Ingestion Pathway
                                 Source of Exposure
                              Ho«e Oust*
                                          Street Olrt
                                                     Soil'
A. Height Approach


Concentration of 2.3.7.8-ICDD    fl.8xlo"14o/g  S.SxlO"14 g/8   8 2xlo"15g/g


Mechanist.                             Daily Intake (g/day)
Ingestion of:
100  «g/day -  30X Bloavail
                                        2.6.10"
                                 .-14
410  «g/day - 801 Bioavail      2.9.10""    2.9.10"


B. Surface Area Approach


Concentration of 2.3.7.8 TCDD    1.3.1013g/"2  5.3«10"13g/»J


                         Dally Intake (g/day)
                                                        2.5.10"
                                                        2.7.10"
    HechaniSB
    Contact with:
    0.0033 «2/day - 30* Bloavail


    0.016 «2/day - BOX BioavalI
                         1 3.10"16    5 2.10"16    5 2.10"
                                    6.8x10"
                                                    •15
   ' 20-year accumulation period
   2 Assumes 30-day accumulation period al 25% of outdoor accumulation rate


   As summarized in Table 7, for the low end of this range, the
 data indicate that the predicted  additional 2,3,7,8-TCDD intake
 from  ingestion  or dermal absorption  of paniculate emissions
 from the BNYRRF would be negligible.  Using worst-case assump-
 tions regarding the maximum rates of exposure through ingestion
 or dermal in absorption, the total daily intake of 2,3,7,8-TCDD
 would  increase by  2.4 times  the amount from inhalation alone.
 Under this "worst-case" scenario, ingestion  becomes the major
 pathway of exposure.
   The general conclusions regarding the level  of risk posed by the
 BNYRRF are not significantly altered if the maximum total daily
 intake  of 2,3,7,8-TCDD increases 2.4 fold. This additional daily
 intake  of 2,3,7,8-TCDD equals only 0.036%  of the most conser-
 vative ADI (1.8  pg/kg-day)  and a toxic equivalent daily intake
 which is only 2.1% of this ADI.
                                                                                               Table 6
                                                                     Estimated Dally Inlake of 2,3,7,8-TCDD from Dermal Absorption

                                                                                                     Sourc* of Exposure	
                                                                                                Ham, Ou.t	Street Dirt   OT

                                                                      A  Weight Approach

                                                                      Concentration of 2,3.7.8-ICOO    8.8.10"" g/g 8 8.10"14 g/g  8.2.10   g/g

                                                                                                           Dally Intaka (g/day)

                                                                      055 g of dust -1* Absorption    4.8.10""    4.8»10~16     4.5.10"1

                                                                      0 55 g of dust -10)1 Absorption   4.8.10"15    4 8.10"      4.5«10

                                                                                                  	Source of Exposure	
                                                                      B  Surface Area Approach

                                                                      Concentration of 2.3.7.8-tCDO
                                                                      0 028 •  of surface
                                                                          • re« -U Absorption
                                                                                                    13 . 10"13 g/.2
                                                                                                                   Street Dirt"
                                                                                                                  i.3 . 10"U 9/m2
                                                                                                3 6 . 10
                                                                          0 14 .  of surface
                                                                              4fci -10t Absorption
                                                                                                          •15
                                                                                                            Dally Intake (g/day)


                                                                                                               1.5 x 10"16

                                                                                                                    -15
                                                                                                1 8 . 10""       ; 4 . 10

                                                                   ' PCDf) concentration* in M>iK on a Mjrfacc area bam arc a-«umed lo be identical wilh Hrecl din.
                                                                                               Table 7
                                                                         Calculation of a Total Daily Inlake of 2,3,7,8-TCDD for
                                                                          Inhalation, Ingeslion and Dermal Absorption Pathway

                                                                          Case 1   PCDOs and PCOfs inter fabric filter in Gaseous Phase

                                                                                 01 "»,„. ""ing""*™
                                                                                 01  1 9 x 10"" -0-0
                                                                              Cast 2  PCODs and PCDFi Enter fabric filter Attached to
                                                                                                                 4 . 10
                                                                                                                      "15
                                                                                     Dl  .  = 1 0 x 10
                                                                                     OIWI = 45. 10"   g/«ay
                                                                      The upper-bound carcinogenic risk estimates will also increase
                                                                   by a  factor of 2.4 assuming the most  conservative estimates for
                                                                   the ingestion and dermal absorption pathways. This would result
                                                                   in an upperbound increased cancer  risk for a population exposed
                                                                   to the maximum 2,3,7,8-TCDD and HCDD concentrations over a
                                                                   70-year lifetime ranging from 0.0046 x 10-6 to less than 0.13  x
                                                                   10-6.
                                                                      As a further measure of conservatism, we examined the poten-
                                                                   tial carcinogenic risks due to exposure to the complex mixture of
                                                                   PCDDs and  PCDFs emitted  from the BNYRRF for all three
                                                                   potential pathways of exposure. Because no actual animal studies
                                                                   have  been conducted to assess the carcinogenicity of most of the
                                                                   individual PCDD/PCDF isomers on the complex mixtures pre-
                                                                   sent in fly ash  emissions, another  conservative assumption was
                                                                   made:  that the  carcinogenic  effect   of these  compounds  is
                                                                   equivalent to their toxic effect  (i.e., that carcinogenic equivalency
                                                                   equals a  toxic equivalency). However, this assumption is highly
                                                                   speculative. With  these conservative assumptions, the maximum
                                                                   increased cancer risk due to the complex mixture of PCDDs and
                                                                   PCDFs present in the emissions ranges from less than 0.24 to an
                                                                   upper-bound limit of less than 5.9 x 10-6 for an these pathways
                                                                   combined.
                                                                      In  our opinion, within the context of the  assumptions used in
                                                                   the risk assessment, the methods used to  estimate risk and con-
                                                                   sidering current regulatory practice regarding acceptable versus
                                                                   unacceptable  health risks,  a  worst-case upper-bound excess
334    RISK ASSESSMENT

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cancer risk less than 5.9 x  10-6 is below levels found by many
regulatory agencies to require additional review and probable ac-
tion to reduce risk.

REFERENCES
 1.  Redford,  D.P.,  et al.,  "Emission of  PCDD  from Combustion
    Sources," International Symposium on Chlorinated Dioxins and Re-
    lated Compounds,  Arlington, VA,  Oct. 1981.
 2.  SFOEP (Swiss Federal Office for Environmental Protection), "En-
    vironmental Pollution Due to Dioxins and Furans from Communal
    Rubbish Incineration Plants," Schriftenreihe Unweltschutz, No. 5,
    1982.
 3.  Cramer, H.E.  Co., Inc., "Industrial Source Complex (ISC)  User's
    Guide," Vol. I. NTIS PB80-133044, 1979.
 4.  Nudelman, H., New York  City Department of Environmental Pro-
    tection, 1984.  Personal communication  to  Ben  Miller,  New York
    City Department of Sanitation, June 29, 1984.
 5.  Harrison,  R.M., "Toxic Metals in Street and Household Dusts,"
    Science Total Environ. 11,  1979, 89.
 6.  Solomon,  R.L. and Reinbold,  K.A., "Environmental Contamina-
    tion by Lead and Other Heavy Metals," National Science Founda-
    tion. Publ. No. NSF/RA 770681-5, 1977.
 7.  U.S. EPA, 1984, Ambient Water Quality Criteria for 2,3,7,8-Tetra-
    chlorodibenzo-p-dioxin. Office of Water Regulations and Standards,
    U.S. EPA, Publ. No. 440/5-84-007.
 8.  Harding,  D.H., "Chlorinated Dioxins and Chlorinated  Dibenzo-
    furans: Ambient Air Guideline," Health Studies  Service, Special
    Studies and Services Branch, Ministry of Labor, 1982.
 9.  Heigden, et al., "Royal Institute of Public Health,  Bilthoven, The
    Netherlands, Report DOC/LCM 300/292, 1982.
10.  Kim,  N. and Hawley,  J.,  "Revised Risk Assessment,  Binghamton
    State  Office Building, Albany, NY, New York State Department of
    Health, Bureau of Toxic Substance Assessment, Jan. 17, 1984.
11.  Kimbrough, R., et al., "Health Implications of 2,3,7,8-Tetrachloro-
    dibenzodioxin  (TCDD)  Contamination in Residential Soil," Center
    for Environmental Health, Centers for Disease Control, 1983.
12.  U.S.  EPA, "Interim Evaluation of Health Risks Associated with
    Emissions of Tetrachlorinated Dioxins from Municipal Waste Re-
    source Recovery Facilities," Office of the Deputy  Administrator,
    U.S. EPA, Nov. 1981.
13.  Brunekreef, B., et al.,  "Blood Lead Levels of Dutch City Children
    and Their Relationship  to  Lead in the Environment," JAPCA,  33,
    1983, 872-876.
                                                                                                          RISK ASSESSMENT
                                                                                                                                  335

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                  Improving the  Risk  Relevance of Systems  for
                               Assessing  the Relative Hazard
                                     of Contaminated  Sites

                                                 Ellen D. Smith
                                      Lawrence W. Barnthouse, Ph.D.
                                          Glenn W. Suter II, Ph.D.
                                            James E. Breck,  Ph.D.
                                       Oak  Ridge National Laboratory
                                      Environmental Sciences Division
                                             Oak Ridge, Tennessee
                                                Troyce D. Jones
                                       Oak  Ridge National Laboratory
                                    Health and Safety  Research Division
                                             Oak Ridge, Tennessee
                                           Dee Ann Sanders, Ph.D.
                  U.S. Air Force Occupational and Environmental Health Laboratory
                                        Brooks Air Force Base,  Texas
ABSTRACT
  The  ranking  system  (Hazard Assessment Ranking  Meth-
odology, or HARM) used to evaluate the relative hazard of con-
taminated sites during the records-search phase of the U.S. Air
Force Installation Restoration Program (IRP) has been revised to
priorities for later phases of the IRP. The resulting methodology,
HARM II, is designed to use data obtained in preliminary site in-
vestigations and is expected to provide better approximations of
relative site risk than could be obtained with the original HARM
or with the U.S. EPA's Hazard Ranking System. This paper
describes the  methodological  enhancements in HARM II  and
reports the results of preliminary testing of HARM II.

INTRODUCTION
  The U.S. EPA "Superfund" program and other federal and
state waste site remedial action programs set remedial action
priorities using various  methodologies that  rank contaminated
sites according to their relative hazard. Ideally, the site rankings
produced by these methodologies would closely correlate with the
actual health and ecological risks posed by individual sites;  i.e.,
the relative scores would  indicate relative potential for adverse ef-
fects, taking into account the relative probabilities of exposures to
contaminants  and  the relative consequences of such exposures.
We call this property "risk relevance."
  While risk relevance was a critical consideration in the design of
such widely used site-ranking systems as the U.S. EPA Hazard
Ranking System  (HRS)'  used in the  Superfund  program,
methodological simplifications needed to permit scoring of large
numbers of sites in a short time with limited site-specific data
often diminish  the risk relevance of the  resulting scores.
Simplified ranking systems are appropriate for preliminary iden-
tification of sites where cleanup may be necessary, but final deci-
sions on allocating remedial action resources among sites should
use methods  that relate more  directly to  actual health  and
ecological risks.
1. Research sponsored by the U.S. Air Force, under Imeragency Agrcemcnl No.
40-1413-83 with the U.S. Department of Energy, under Contract No. DE-AC05-
840R21400 with Martin Marietta Energy Systems, Inc.
  In this paper,  the  authors describe a modification of the
Hazard  Assessment  Rating Methodology  (HARM),  a site-
screening system developed by the U.S. Air Force for use in the
initial phase of its Installation Restoration Program (IRP). The
Air Force used HARM to evaluate sites of suspected contamina-
tion based on information obtained from a records search. The
new  site-rating  methodology  (Hazard Assessment  Rating
Methodology II, or HARM II) is intended to set  priorities for
detailed  site investigation and possible remedial action in later
phases of the IRP. It uses data obtained from preliminary field
surveys of sites identified during the  records  search as being
potentially hazardous. The primary  reasons for  modifying
HARM were to permit effective use of new field data and to im-
prove the methodology's ability to discriminate between sites on
the basis of actual risk. Although HARM is designed specifically
to meet  the  needs of the Air Force, features incorporated in
HARM II to improve its risk relevance may  be useful in other
decision-making problems involving hazardous materials  and
waste sites.

THE HAZARD ASSESSMENT
RATING METHODOLOGY
  The original HARM methodology is a close relative of the
HRS.' As in the HRS, sites are scored on the basis of potential for
contaminant  transport ("Pathways"), contaminant character-
istics ("Hazard") and potential receptors ("Receptors") along
each of several possible exposure pathways. Subscores for these
three  risk  categories are  obtained  by evaluating  the sites with
respect to several rating factors, multiplying factor scores by ap-
propriate factor weights and summing the weighted factor scores.
The resulting subscores then are averaged to arrive at a single
overall site score.
  Only hydrologic transport and exposure pathways are con-
sidered in HARM;-air exposures are not included.  Other dif-
ferences between HARM and HRS  include the use of standard
four-point (i.e., 0-1-2-3) factor rating scales throughout HARM,
inclusion of a few different rating factors (e.g., distance from the
site to a facility boundary) appropriate to Air Force applications,
assignment of different ranges of values (e.g., of local population
336   RISK ASSESSMENT

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                            Receptors
                                                                    Waste Characteristics
       START
DETERMINE
WASTE
QUANTITY/
HAZARD SCORE

"*"
APPLY
PERSISTENCE
FACTOR


APPLY
PHYSICAL
STATE
FACTOR



CALCULATE
WASTE CHAR.
SUB8CORE



                                                                                 Waste_Managernent
                                                                                      Practices
                                                             Figure 1
                                        Hazardous Assessment Rating Methodology Flow Chart
and waste quantity) to individual factor scores and use of additive
algorithms (instead of the multiplicative and root-mean-square
algorithms employed  in HRS) to combine subscores. Figure 1 il-
lustrates the structure of the original HARM.2
  The  structure of HARM II (Fig. 2) is  significantly different
from that of the original HARM. In the original HARM (Fig. 1),
three contaminant  migration routes (Surface Water, Flooding
and Groundwater) are evaluated in determining the subscore for
the Pathways category, but a single subscore was determined for
each of the three categories (i.e., Pathways, Hazard and Recep-
tors) regardless of the mode of contaminant migration. To ensure
that the factors considered in Receptors scoring are relevant to the
expected mode(s) of  contaminant migration and  that Hazard
scores reflect the  sensitivity of the exposed populations, HARM
            II requires separate calculation of scores for each  of four ex-
            posure pathways:  (1) Surface Water Migration/Human Health
            Receptors, (2)  Surface Water Migration/Ecological Receptors,
            (3) Groundwater Migration/Human Health Receptors,  and (4)
            Groundwater  Migration/Ecological  Receptors.  Subscores  for
            each of the three rating categories are aggregated to arrive at an
            overall pathway score, and the four pathway scores then are com-
            bined to  arrive at a single overall  site score. In HARM II, the
            Flooding migration route from the original HARM has been in-
            corporated into the  Surface Water migration  route, and  the
            Waste Containment factor from the original HARM  has been in-
            corporated into the Pathways scoring category. Other features of
            HARM II intended to  improve its risk relevance are described
            below.
                                  CALCULATE SW/HEALTH
                                   HAZARD SUBSCORE
                                      (SECT. 3.2.1)
CALCULATE SURFACE
WATER PATHWAY
SUBSCORE
(SECT. 3.1)


	 1






CALCULATE SW/ECOLOOICAL
ISECT. 322}
CALCULATE SW/HEALTH
 RECEPTOR SUBSCORE
    (SECT. 3 Jl
CALCULATE SW/HEALTH
  PATHWAY SCORE
    ISECT. 3.41
                                                       CALCULATE SW/ECOLOCICAL
                                                         RECEPTOR SUBSCORE
                                                            ISECT. 3.3)
                     CALCULATE SW/ECOLOO.ICAL
                        PATHWAY SCORE
                          ISECT. 3.4)
CALCULATE GROUND
WATER PATHWAY
SUBSCORE
ISECT. 3.11


	 1






CALCULATE QW/ECOLOOICAL
ISECT. 3.2.21
CALCULATE OW/HEALTH
HAZARD SUBSCORE
ISECT. 3J.1I


CALCULATE GW/HEALTH
RECEPTOR SUBSCORE
ISECT. 3.3)
                                                                               CALCULATE OW/HEALTH
                                                                                 PATHWAY SCORE
                                                                                   (SECT. 3.4)
                                                       CALCULATE OW/ECOLOOICAL
                                                         RECEPTOR SUBSCORE
                                                            ISECT. 3.3)
                     CALCULATE QW/ECOLOOICAL
                         PATHWAY SCORE
                          ISECT. 3.4)
                                                             Figure 2
                                             Flow Chart for HARM II Site Rating System
                                                                                                        RISK ASSESSMENT    337

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HARM II Contaminant Hazard Scoring
  The most important limitation in the contaminant hazard scor-
ing portion of the original HARM is the method's reliance on the
Sax Toxicity  Rating.5 The Sax method, which is widely  used in
site-ranking methodologies such  as  the  HRS,  assigns  toxicity
scores  on the  basis  of  a  substance's observed  biological
mechanism of action, independent of the  dose level at which the
substance is toxic. Also, Sax  ratings  do not indicate hazards to
nonhuman ecological receptors and sometimes are not relevant to
the modes of exposure that would be expected along environmen-
tal exposure pathways (e.g., a chemical whose fumes are highly
toxic  may not be very toxic when  ingested in drinking water). A
second problem with HARM that is common to most site-ranking
methodologies is the use of only the most  toxic chemical at a site
to characterize  the site  hazard. When  a  site's hazard rating is
based only on the most toxic  chemical, it is possible to assign a
high score to a site having a large quantity of low-hazard wastes
solely due to the presence of a  very small quantity of high-toxicity
wastes.
  The risk relevance of HARM II contaminant hazard scores has
been enhanced by replacing the Sax rating with  a set of toxico-
logical benchmarks and by scoring hazard on the basis of com-
parisons between  the benchmarks and measured  contaminant
levels. Separate sets of benchmarks are used, and separate scores
are calculated for human-health hazards and ecological hazards.
As in HARM, the score for site contaminant hazard is obtained
after  applying   contaminant  persistence and   waste  quantity
multipliers to the toxicity score.
  Human-health  hazard scores  are based on ingestion of con-
taminated water and consumption of  fish  that have accumulated
waterborne contaminants.  Ecological  hazard scores are based on
acute lethality to fish and aquatic invertebrates and effects on ter-
restrial plant  production due to contamination of growth media.
If data are available on contaminant concentrations  in  surface
waters  or groundwaters,  these  concentrations  are  used  to
calculate hazard quotients, which  are ratios of the estimated in-
take rates of the detected contaminants  to the toxicity bench-
marks of the contaminants. The specific formula used depends on
the existing or potential uses of the contaminated water;  the
human-health hazard contribution of a contaminant found in sur-
face  water that supplies drinking  water would  be calculated as
follows:
  Q = (Cw x Fw + Cr x Ff)/Bh
                                                        (1)
where:
   Q

  Cw
  Fw
  Cf
  Bh  =
         human-health hazard quotient for the contaminant of
         interest
         contaminant concentration in surface water 0*g/l)
         estimated individual drinking water intake (2 I/day)
         concentration in fish 0*g/g) = Cw x Bb, where Bb
         bioaccumulation factor (1/g) for the contaminant of
         interest
         estimated mean daily individual fish consumption
         (6.5 g/day)
         health effects benchmark (>ig/day) for the contaminant
         of interest
Where more than one contaminant has been detected, quotients
for the individual contaminants are summed. Hazard scores are
assigned on a scale of 0 to 6, based on the order of magnitude of
the sum of quotients.
  Procedures have  been specified' for obtaining contaminant-
specific benchmarks for  effects on humans, effects on aquatic
and terrestrial biota and potential bioaccumulation in fish.  For
regulated chemicals, the human-health toxicity benchmarks used
in HARM II are based on the U.S. EPA's drinking water quality
standards (40 CFR 141) or on the "permissible concentrations"
promulgated by the National Institute for Occupational  Safety
and Health. For unregulated contaminants, benchmarks are ob-
tained by evaluating test data available in such published compila-
tions  as the Registry  of Toxic  Effects of Chemical Substances
(RTECS),' using the relative potency technique described by
Jones, el at.' Similarly, benchmarks for ecological effects are ob-
tained from U.S. EPA water quality criteria for protection of
aquatic life or from the U.S. EPA's on-line data bases on toxicity
to aquatic  organisms  (QUIRE) and terrestrial plants (PHYTO-
TOX). Bioaccumulation factors for estimating the contribution
of contaminated food  chains to human intake, are obtained from
published compilations,710 or estimated from structure-activity
relationships, e.g., from the octanol-water partition coefficient.
  If contaminant migration has not been detected along  a par-
ticular migration route  or  if water  concentration  data are
unavailable, hazard scores are based on the characteristics of the
most toxic contaminant. A score from 0 to 6 is assigned, based on
the toxicological benchmarks of the most toxic contaminant. For
this case, the scale used in scoring  human-health hazards is based
on the range of potencies of 60 chemicals drawn at random from
RTECS,' and the scale used in scoring ecological hazards is based
on the range of toxicities for chemicals listed in the AQUIRE data
base.
  The calculations and data assessments required to implement
this portion of HARM II  are significantly more complex and
time-consuming than those involved in either the original HARM
or the HRS. However, because it is unlikely that HARM II users
will have the expertise needed  to determine appropriate contami-
nant benchmarks, Oak Ridge National Laboratory is determining
benchmarks for all nonradioactive contaminants that have been-
found at Air Force facilities. Their results will be published in a
user's manual for HARM II.  Given this tabulated information,
determination  of HARM  II  contaminant hazard  scores can
become a routine microcomputer spreadsheet application.

HARM II Pathways Scoring
  The "Pathways" portion of HARM  II rates the potential for
contaminants from  a waste  site to  enter surface waters via
overland flow routes or to enter groundwater. As in the HRS and
the original HARM,  if contaminants from a site have already
been detected in water, the maximum possible pathway score is
assigned. Thus,  the Pathways scoring procedures are applied only
if contamination has not yet been  detected.
  Factors in the Pathways scoring category in HARM II are listed
in Table 1.  The  HARM II surface  water pathways scoring system
is very similar to that used in HARM, with the notable exception
that the potential for floodwater transport of contaminants is in-
cluded in the surface  water pathway in HARM II. This change
was made to reflect the fact that floodwater transport is only one
of several routes for overland transport of contaminants to sur-
face waters, and factors affecting risk from floodwater transport
are similar  to those affecting risk  from other overland transport
routes. A few factor weights were adjusted to better reflect their
relative  importance to overland transport or overflow from im-
poundments.
  The scoring system  for the groundwater pathway was modified
slightly from HARM to make better use of the new data obtained
in site investigations.  The original HARM included two factors
related to the length of the pathway between the waste and the
groundwater: (1) depth to groundwater from the land surface and
(2) potential for subsurface flows (i.e., the water table) to in-
tersect the base of the waste. HARM II replaces these with  a
single new  factor: depth to seasonal high groundwater from the
base of the waste or contaminated zone. This new scoring factor
338
       RISK ASSESSMENT

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                             Table 1
     Listing of HARM II Pathways and Receptors Scoring Factors
     Category
                                Scoring Factors
              Surface water migration
                                      Groundwater migration
  PATHWAYS
  HtCEPTUKS
   Human health
              Distance to nearest surface
                Mater
              Net precipitation
              Surface erosion potential
              Rainfall intensity
              Surface penneability
              Flooding potential
              Containment effectiveness
                        Depth to groundwater from oase
                          of Maste or contaminated zone
                        Permeability of unsaturated zone
                        Potential for discrete features
                          to "short circuit" pathway to
                          the water table
                        Infiltration potential
                        Containment effectiveness
              Population serveo by surface
                water supplies within 3 miles
                (4.8 km) downstream
              Hater quality classification
                of nearest surface water
              Population within 1000 ft
                (305 m) of site
              Distance to nearest
                installation boundary
              Land use and zoning within 1
                mile (1.6 km) of site
   Ecological
                        Mean groundwater travel time to
                          nearest downgradient well
                        Groundwater use of uppermost
                          aquifer
                        Population served by affected
                          downgradient aquifers within 3
                          miles (4.8 km)
                        Population served by affected
                          aquifers not in downgradient
                          direction within 3 miles
                          (4.8 km)
                        Mean groundwater travel time to
                          downgradient surface waters
                          that supply domestic uses or
                          food-chain agriculture
                        Population within 1000 ft
                          (305 m) of site
                        Distance to nearest installation
                          boundary

Importance/sensitivity of      Mean groundwater travel time to
 biota/habitats in potentially    downgradient habitat or
 affected surface waters        natural area
Presence of "critical         Importance/sensitivity of
 environments" within 1 mile     downgradient habitats/natural
 (1.6 km)                   areas
                        Presence of "critical
                          environments" within 1 mile
                          (1.6 km)
 uses information that may not have been available before site in-
 vestigation, and it should enhance the ability of the method to
 identify sites where there is a real potential for contamination of
 groundwater. Another feature of this portion of HARM II that
 represents a change from the original HARM is the addition of a
 factor  called  "infiltration  potential,"  which  is based  on  an
 estimate of the amount of water available to cause waste leaching
 or infiltration. Infiltration potential is determined as a function of
 net precipitation (a Pathways scoring factor included in the waste
 hazard score in the original HARM). This new scoring factor is
 expected to be a better indicator of the hydraulic potential for
 waste constituents to reach groundwater.
   The waste containment effectiveness factor, which was applied
 to the overall site score in the original HARM, is  applied only to
 the Pathways scores  in HARM  II, because effective waste con-
 tainment reduces the  potential for contaminants to enter water
 but does not affect the other major risk categories considered in
 HARM. HARM II includes separate rating scales for waste con-
 tainment  effectiveness  for  surface  water and  groundwater
 pathways, permitting separate evaluation of factors limiting sur-
 face water or groundwater transport. The HARM II rating scales
 for containment effectiveness were derived from  the "waste
 management factors" in HARM2 and the "containment values"
 intheHRS.1

 HARM II Receptor Scoring
   The "Receptors" portion of HARM II evaluates the potential
 for human populations and  ecosystems to  be  exposed to con-
 taminants present in surface waters or groundwaters. This portion
 of HARM II  has been modified significantly from the original
 HARM, primarily to permit use of groundwater information ob-
 tained through site  investigation.
   Factors in the Receptors scoring category in HARM II are listed
in Table 1. The scoring factors  for human  health receptors af-
 fected by surface water migration are essentially unchanged from
HARM. The dominant factors in this category are those related
 to the  potential  for  humans  to ingest contaminated surface
 waters,  either as drinking water or in foods. Three other factors
 related to the site's proximity to human populations (i.e., popula-
 tion within 1,000 ft [305 m], distance to installation boundary and
 land use and zoning) are included because they indicate a poten-
 tial for  humans to come into contact  with contaminated waters
 through routes other  than  ingestion  (e.g.,  direct contact  by
 children playing near contaminated drainage ditches).
   The scoring  factors for human receptors affected by ground-
 water migration are significantly different from those used in the
 original HARM. This portion of HARM, like the analogous por-
 tion of HRS, is concerned primarily with distances to water sup-
 ply wells and does not consider the direction or rate of ground-
 water flow. Initial  field investigations should have supplied the in-
 formation needed to estimate groundwater velocities  and  flow
 directions,  so  HARM  II  receptors scores can  be based on
 estimates of the actual potential for contaminants to reach points
 of groundwater use. HARM  II  assigns more weight to receptors
 that are found to  be hydraulically downgradient from the waste
 site and incorporates a measure  of the urgency of a particular
 contamination  problem by including  scoring  factors based on
 estimated groundwater travel times to  sites  of groundwater use.
 Also, because surface  waters are often outlets for groundwater
 discharge, the human health receptors  category for groundwater
 migration includes scoring factors related to the uses and suscep-
 tibility of surface  waters hydraulically downgradient from con-
 taminated sites. These features of HARM II are intended to en-
 sure that scores are  based on consideration of the populations
 that are  actually at risk.
   The groundwater travel time parameter in HARM II is similar
 to  the travel time criterion adopted by  federal  regulators as a
 measure  of the  isolation  of  radioactive  wastes  in  geologic
 repositories.11'12 Mean groundwater travel time is calculated from
 the estimated hydraulic conductivity of the affected aquifer (k),
 the hydraulic gradient  in the affected aquifer (i), the distance to
 the well  (d) and the effective porosity of the affected aquifer (n),
using the following equation:
                                                            Travel time = dn/ki
                                                                                                                    (2)
                                                       This calculation will provide an estimate of the mean travel time
                                                       of a nonreactive contaminant,  neglecting  the effects  of disper-
                                                       sion. It is recognized that the data needed for this calculation will
                                                       not always be available. To promote consistency in evaluating this
                                                       parameter,  guidance  has been  developed"  for estimating  input
                                                       values when appropriate data are unavailable. For consistency in
                                                       applying HMAR II, "downgradient" is defined to mean a 90- to
                                                       120-degree  arc  containing  the best  estimate of the direction  of
                                                       groundwater flow at  its center. Where the  direction of ground-
                                                       water  flow  is highly  uncertain  or indeterminate,  all travel-time
                                                       scoring is based on an estimated travel time to the nearest well or
                                                       surface water in any direction.
                                                         The method  for scoring the  potential exposure of  ecological
                                                       receptors has been expanded  from  the  original HARM and  the
                                                       HRS,  both  of which emphasize the  proximity of the site  to
                                                       various critical environments.  HARM II also considers  the poten-
                                                       tial ecological importance or sensitivity or ecosystems likely to be
                                                       exposed to  a particular transport pathway but not necessarily
                                                       "critical environments." These  include all permanent  streams,
                                                       lakes,  wetlands and irrigated land areas.

                                                       Aggregation of HARM II Subscores
                                                         In the original HARM (Fig. 1), the overall site score is obtained
                                                       by simple arithmetic averaging  of  the Pathways,  Hazard and
                                                       Receptors subscores. This method of aggregating scores is simple
                                                       to apply, but its results are not well correlated with actual risks of
                                                                                                          RISK ASSESSMENT    339

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toxic exposures. Three factors must be present to result in an ex-
posure risk: toxic contaminants ("Hazard"), potential for migra-
tion ("Pathways") and a potentially exposed human population
or ecological resource ("Receptors"). If an additive algorithm
(such as arithmetic averaging) is used to combine subscores for an
exposure pathway, it is possible to obtain a relatively high score
for a pathway along which only two of these three factors are pre-
sent and for which risk is therefore rather low. For example, a site
with highly toxic contaminants and  a large receptor population
but very little potential  for aqueous transport of contaminants
poses relatively little risk, but could receive a high score. To avoid
this outcome, HARM II uses a multiplicative algorithm similar to
that in the HRS' to combine subscores into a  single pathway score.
The three subscores are multiplied together, and,  to normalize to
a 100-point scale, the product is divided by 10* (the product of the
highest possible category scores). With this algorithm,  an ex-
posure pathway with a very low or zero subscore for Pathways,
Receptors or Hazard will receive a very low  or zero score, consis-
tent with the low pathway risk.
  Several different approaches were available for obtaining  an
overall  site score  from  the four HARM  II exposure pathway
scores.  Arithmetic averaging was  not  used  for  this purpose
because this method assigns equal weight to high-  and low-risk ex-
posure pathways. A site with a high risk via one exposure pathway
is a high-risk site even if it  has a low risk  via another exposure
pathway.  Although such a site should receive a higher score than
a site with a moderate risk via both pathways, the two sites might
receive  the same  score if  the  pathway scores  were averaged
arithmetically. The objective of assigning greater weight to high-
risk pathways could be achieved by setting the overall site score
equal to the single highest exposure  pathway score, but this ap-
proach is  inappropriate because it does not  reflect the fact that a
site with high risks along two or more exposure pathways presents
greater risk than a site with high risk along  only one pathway.
  A weighted root-mean-square algorithm was selected for com-
bining the four HARM II exposure pathway scores  into a single
overall site score.  The HRS uses a root-mean-square algorithm
for combining exposure pathway scores because this approach
reflects the contributions of several pathways while it gives greater
weight to pathways with higher scores." Explicit factor weights
are also applied in combining HARM II pathway scores in order
to give  human health risks greater weight than ecological risks.
Thus,  the following algorithm is used to  obtain the final site
score:

  Sf = [5(S,ih)2 + (Ss,e)2 + 5(Sg,h)2  + (Sg,e)2] 1/2/3.464      (3)
where
    Sf   =  final score
  Ss h   =  score for human health risk via surface water pathway
  SSie   =  score for ecological risk via surface water pathway
  Sg h   =  score for human health risk via groundwater pathway
  Sg e   =   score for ecological risk via groundwater  pathway
The weight of 5 for the human health scores was selected because
the  original HARM assigned factors related  to human receptors 5
times the weight given  to factors related  to  ecological receptors.
The divisor 3.464 is the square root of 12, which is the sum of the
weights assigned to individual pathway scores.

TESTING OF HARM  II
  As a preliminary test of the methodology, HARM II was ap-
plied to a  representative Air Force  facility  that  contained nine
contaminated sites for  which both preliminary site investigation
data and original HARM scores  were available.' The nine sites
that were  assessed represented a  diverse  range  of  waste
characteristics,  waste quantities  and physical settings.  As in-
                                                                 dicated by the scores  in Table  2,  HARM  II produced a clear
                                                                 separation between a group of high-scoring sites (i.e., the 46-55
                                                                 range) and a group of  relatively  low-scoring sites (i.e., the 15-30
                                                                 range), whereas scores  from the original HARM had been spread
                                                                 fairly evening over a range  from 51 to  88. This improved score
                                                                 separation, which is largely due to the change from an additive to
                                                                 a multiplicative algorithm, should be helpful  in setting  and
                                                                 defending remedial action priorities. In general, scores assigned
                                                                 with HARM II were lower than  those assigned with the original
                                                                 HARM, largely because the change to a multiplicative algorithm
                                                                 resulted in significantly lower overall scores for sites that had low
                                                                 subscores  in one of the three rating categories. Since the HARM
                                                                 systems are tools for evaluating relative site hazards and are not
                                                                 correlated with absolute degrees of risk,  the lower range of scores
                                                                 obtained with HARM II does not mean that the sites pose any less
                                                                 risk now than they did  when the original HARM was applied.
                                                                   HARM  II  also produced a different ranking of sites  than the
                                                                 original HARM. The most dramatic changes in site rank were at-
                                                                 tributable  to new information obtained during site investigations.
                                                                 For example, in applying the original HARM, the chrome waste
                                                                 pit (Table  2) had been scored as having a small quantity of waste
                                                                 and a low potential for contaminant migration,  but it later was
                                                                 found  to contain a large quantity of waste and to have caused
                                                                 significant  groundwater  contamination. A variety of smaller
                                                                 changes in scores and site ranks could be attributed to new data,
                                                                 changes in individual  scoring factors  and  changes in scoring
                                                                 algorithms.4

                                                                                            Table 2
                                                                             Comparison of Scores for Sites Evaluated
                                                                                With Both HARM and HARM II
                                                                                                             KMH II score
                                                                                                               Una rinft
Undf 111 r 1
Ldndttll fj
tusle ol 1 pits
01(1 fuel Stor«g« ttnk 1 1 IV
Die ytrQ cheated! pits
f ire-lrttnlng Durn pit »6
Chroac M4SIC pit
Two other f Ire-lrainlnq (Kirn pill*
SS
«,
It
n
M
ss
55
si-se
ID
HI
(11
l«)
(5)
(61
18)
(6-9)
47
SS
«6
H
54
IS
54
11-30
(«)
(>>
(S)
(7)
(2)
(9)
U)
(6-8)
                                                                  Individual burn pus rated *ilh HARM ft could nol be directly correlated with specific burn pits
                                                                 rated with HARM
                                                                   This testing indicated that it is feasible to apply HARM II with
                                                                 the types of data available for contaminated sites on Air Force
                                                                 facilities and gave a preliminary indication that the method will
                                                                 provide meaningful distinctions between high- and low-risk sites.
                                                                 More extensive test applications and sensitivity analyses are now
                                                                 being performed to confirm these observations, to evaluate the
                                                                 methodology's effectiveness for comparing a wide variety of sites
                                                                 in  different  geographical  areas and  to  identify any  needed
                                                                 refinements in HARM II.

                                                                 CONCLUSIONS
                                                                   HARM  II is  expected to  provide  a  better approximation of
                                                                 relative risk than has been available previously in scoring systems
                                                                 suitable for wide application in setting remedial action priorities.
                                                                 Although HARM H was designed specifically to meet the needs of
                                                                 the Air Force, the concepts employed in  HARM II should find
                                                                 application in other decision-making problems involving hazar-
                                                                 dous materials and waste sites. Important  innovations in HARM
                                                                 II include estimation of contaminant hazard using actual risk ap-
                                                                 proximations and the use of field data in  determining the actual
                                                                 susceptibility of groundwater receptors.  Like the original HARM,
                                                                 the HRS and other similar systems, HARM 11 is not a formal risk-
                                                                 assessment methodology but is designed  for routine application to
340
       RISK ASSESSMENT

-------
large numbers of sites. Although the method is expected to pro-
duce reasonable approximations of relative risks, it is not possible
to objectively relate the numerical scores to absolute levels of
potential health and environmental hazard.
  Additional changes could be made in HARM II  to  produce
scores that would more closely resemble risk-assessment results.
For example, the Receptors scoring categories might be expanded
to include factors related to surface water dilution, aquifer disper-
sion or contaminant sorption in aquifers. However,  most such
refinements would imply greater data availability and reliability
than  can  be  realistically expected,  and any  potential  im-
provements in scores do not appear to justify the additional effort
that would be required to implement the system.
REFERENCES
 1. U.S. EPA, "National Oil and Hazardous Substances Contingency
    Plan," Appendix A: "Uncontrolled Hazardous Waste Site Ranking
    System: A User's Manual," Federal Register 47, 1982, 31219-31227.
 2. Engineering-Science, Inc., "Installation Restoration Program Phase
    I: Records Search, Tinker AFB, Oklahoma," Atlanta, GA, 1982.
 3. Sax, N.I., Dangerous  Properties of Industrial Materials, 5th  ed.,
    Van Nostrand Reinhold Co., New York, NY, 1979.
 4. Barnthouse, L.W., Breck, J.E., Jones, T.D., Kraemer, S.R., Smith,
    E.D. and Suter, G.W., II, "Development and Demonstration of a
    Hazard Assessment Rating Methodology for Phase II of the Installa-
    tion Restoration Program,"  ORNL/TM-9857, Oak Ridge National
    Laboratory, Oak Ridge, TN, in press.
 5. Lewis, R.J., Sr.  and Tatken, R.L., "Registry of Toxic Effects of
    Chemical Substances," U.S. Department of Health and Human
    Services, Washington,  DC, 1982.
 6.  Jones, T.D., Griffin, G.D. and Walsh, P.J., "A Unifying Concept
    for Carcinogenic  Risk  Assessments," J. Theor.  Biol. 105, 1983,
    35-61.
 7.  Callahan, M.A., Slimak, M.W., Gabel, N.W., May, I.P., Fowler,
    C.F., Freed,  J.R., Jennings, P., Durfee,  R.L., Whitmore, F.C.,
    Maestri,  B., Mabey, W.R., Holt, B.R. and Gould, C., "Water-Re-
    lated Environmental Fate of 129 Priority Pollutants. Vol. I: "Intro-
    duction and Technical Background, Metals and Organics, Pesticides
    and PCBs,"  EPA-440/4-79-029a, Office of Water Planning and
    Standards, Office of Water and Waste Management, U.S.  EPA,
    Washington, DC,  1979.
 8.  Callahan, M.A., Slimak, M.W., Gabel, N.W., May, I.P., Fowler,
    C.F., Freed,  J.R., Jennings, P., Durfee,  R.L., Whitmore, F.C.,
    Maestri,  B., Mabey, W.R., Holt,  B.R. and Gould, C.,  "Water-
    Related  Environmental Fate of 129 Priority Pollutants." Vol.  II:
    "Halogenated Aliphatic Hydrocarbons, Halogenated Ethers, Mono-
    cyclic Aromatics,  Phthalate Esters, Polycyclic Aromatic Hydrocar-
    bons, Nitrosamines, and Miscellaneous Compounds," EPA-440/4-
    79-029b,  Office of Water Planning and Standards,  Office of Water
    and Waste Management, U.S. EPA, Washington, DC, 1979.
 9.  Trabalka, J.R. and Garten, C.T., Jr., "Development of Predictive
    Models for Xenobiotic Bioaccumulation in Terrestrial Ecosystems,"
    ORNL-5869, Oak Ridge National Laboratory, Oak Ridge, TN, 1982.
10.  U.S. EPA, "Ambient Water Quality Criteria for Phthalate Esters,"
    EPA 440/5-80-067, 1980.
11.  U.S.  EPA, "Environmental Standards  for the Management and
    Disposal  of Spent Nuclear Fuel,  High-Level and Transuranic Radio-
    active Wastes (40 CFR 191)," Federal Register 50, 1985.
12.  U.S.  Nuclear  Regulatory Commission,  "Disposal of High-Level
    Radioactive Wastes in Geologic  Repositories (10 CFR 60)," Federal
    Register 48, 1983,  28222-28229.
13.  Caldwell, S., Barrett, K.W. and  Chang, S.S., "Ranking Systems for
    Releases  of Hazardous  Substances," Proc. of the First National
    Conference on Management of Uncontrolled Hazardous Waste
    Sites, Washington, DC,  Oct., 1981, 14-20.
                                                                                                         RISK ASSESSMENT    341

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                                     Soil Cleanup Criteria for
                                  Selected Petroleum Products

                                                 Sofia K.  Stokman
                                               Richard Dime, Ph.D.
                            New Jersey Department of Environmental Protection
                                   Hazardous Site Mitigation  Administration
                                               Trenton, New Jersey
ABSTRACT
  A large number of sites are contaminated with petroleum prod-
ucts which may pose a potential health hazard. Therefore, risk
assessment and acceptable soil cleanup levels for these products
are urgently  needed.  This  paper  compares alternatives  for
developing  cleanup objectives  for soil  contaminated  with
petroleum products. A soil cleanup objective based on the con-
centrations of total petroleum hydrocarbons versus a soil cleanup
objective based on the concentration of individual chemical con-
stituents of concern is investigated.
  A review of the chemical composition of crude oil, gasolines,
petroleum naphtha,  fuel oil No. 1 Get fuel, kerosene),  fuel oil No.
2 (heating oil, diesel oil), fuel oil No. 6 (Bunker "C"), lubricating
oil, fresh motor oil and used motor oils (over 5,000 and 10,000 km
usage) was undertaken  to  identify  individual chemical consti-
tuents that would be harmful to public health and/or the environ-
ment.  The  carcinogenic  polycyclic  aromatic  hydrocarbons
(CaPAHs) and benzene were identified as constituents of con-
cern. A lifetime soil exposure model based on pica tendencies and
inhalation of soil was used to estimate soil concentrations of these
constituents that would  result in a one in  a million (1 x 10 ~6)
cancer risk if exposure were to occur. These levels were compared
with residual concentrations of CaPAHs and benzene in soil after
cleanup to 110 ppm total petroleum hydrocarbons (PHs) for each
petroleum product studied. For those constituents remaining in
concentrations which would exceed a 1 x 10 ~6 if exposure were
to occur, a soil cleanup objective which reduces the health risk to
an  acceptable level  was  proposed.  In addition,  the proposed
cleanup objectives were compared to "normal" soil background
levels  of CaPAHs and benzene.
  With the exception of motor oils used over  10,000 km, using
100 ppm of total  PHs as the soil cleanup  objective results in
residual soil levels of CaPAHs and benzene not yielding a 1  x
10~6 cancer risk. Changing the soil  cleanup objective from 100
ppm to 60 ppm  will reduce CaPAHs from used motor oils over
10,000 km to an acceptable cancer risk level of one in a million.
"Normal" background soil levels of benzene are exceeded in  all
products for which data were available.
  Determination of soil cleanup objectives based on residual soil
levels  of CaPAHs and benzene cannot be further refined at this
time due to the limited information available on the concentration
of these compounds in petroleum products and in "normal" soil
background levels.

INTRODUCTION
  Large-scale terrestrial pollution can result from the production,
transportation, storage and voluntary land disposal of petroleum
products. Exposure to these products may result in adverse effects
on public health and on the environment. This paper examines
alternatives for developing acceptable soil cleanup levels (ASCLs)
for soil contaminated with petroleum products. The focus is  on
exposure to contaminated soils through ingestion (pica) and in-
halation and  on the migration of  petroleum compounds into
groundwater. The literature was reviewed to identify constituents
in  petroleum products that are toxic and/or harmful in the en-
vironment. ASCLs were determined for carcinogenic constituents
using  risk assessment  techniques.  Soil cleanup levels for car-
cinogenic constituents were compared to a total petroleum hydro-
carbons (PHs) cleanup objective of 100 ppm.

DETERMINATION OF ACCEPTABLE
SOIL  CONTAMINANT LEVELS
  Risk assessment and soil cleanup objectives are presented only
for individual chemical constituents of petroleum products which
have the highest toxicity, the ability to migrate and/or are present
in significant amounts. Emphasis was placed on chronic toxic ef-
fects (particularly carcinogenic) due to long-term exposure to con-
taminated soils. In  order to accomplish this task, the following
was performed: (1) review of physical/chemical properties, health
effects and environmental fate of selected petroleum products; (2)
identification of carcinogenic constituents and estimation of con-
centrations present in each particular petroleum product; (3) esti-
mates of residual soil concentrations of carcinogenic constituents
when  100 ppm total petroleum hydrocarbons is used as a cleanup
objective; and  (4) comparison of estimates with concentrations
resulting in a cancer risk of one in a million (1  x 10-6) and with
"normal" background soil levels to determine if any of the car-
cinogenic constituents  remain in the soil in concentrations that
may pose a threat to public health.  Comparison to background
also was made since many regulatory agencies consider cleanup to
background an appropriate remedial objective.
  Due to space limitations, all areas reviewed are not covered in
detail. This paper discusses briefly the toxicity and environmental
fate of selected petroleum  products.

IDENTIFICATION AND TOXICITY OF
CONSTITUENTS IN PETROLEUM  PRODUCTS
  The following petroleum products are reviewed in this  paper
for identification of toxic constituents:  crude oil, petroleum
naphtha, gasolines,  fuel oil No.  1 (jet fuel, kerosene), fuel oil No.
2 (heating oil, diesel oil), fuel oil No. 6 (Bunker "C"), lubricating
oil, fresh motor oil, and used motor oils (over 5,000 and 10,000
km usage).
  A review  of the literature indicates that the most  toxic consti-
tuents of petroleum  products  are  the  aromatics.  After the
aromatic fractions, toxicity  decreases  from  olefins through
naphthanes to paraffins.1  Within each group, the hydrocarbons
of lower molecular weight tend to be more toxic.1  Exposure to
high   and  low  boiling fractions of  petroleum  (crude  oil)  is
associated with carcinogenic effects. Moreover, exposure to poly-
cyclic  aromatic  hydrocarbons  (PAHs) present  in certain  heavy
342   RISK ASSESSMENT

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residual oils2 and to benzene present in unleaded gasoline3 cur-
rently is being investigated for carcinogenic effects of these prod-
ucts. Crude oil is mutagenic4 and is at the present time under toxic-
ity review.5 Kerosene currently is being tested for carcinogenicity.6
  This paper primarily is concerned with chronic effects due to
long-term exposure to soils contaminated with petroleum prod-
ucts. Of all the constituents identified, the carcinogenic polycyclic
aromatic hydrocarbons (CaPAHs) and benzene (a known human
carcinogen) are of most concern,2-6 and cleanup objectives for
soils contaminated with petroleum products are based on these
compounds.

ENVIRONMENTAL FATE
  Little is known about the environmental chemistry and ultimate
fate of petroleum  hydrocarbons in the soil environment. Their
fate in land is affected primarily by their distribution, volatiliza-
tion and  leaching potential.7 Low molecular weight aromatic
hydrocarbons such as benzene, toluene, xylene, etc., which have a
high Henry's Law constant,  tend to partly evaporate.  The re-
mainder will migrate to different depths of the soil column where
little or no volatilization to the atmosphere occurs.
  The proportion of the petroleum hydrocarbons that will bind to
soil versus those which will continue to migrate toward ground-
water  depends  primarily  on  the  type  of soil, the particular
petroleum product, the size of the spill and the amount of rain-
fall.7 In general, leaching to groundwater is favored by high rain-
fall and  permeable soils and increases for chemicals with high
solubility, low diffusion coefficients and low absorption coeffi-
cients' such as the aromatics benzene, toluene and xylene.
  Biodegradation is an important factor for removal of PAHs in
general, but high molecular weight multiring compounds such as
polycyclic aromatic hydrocarbons (PAHs) tend to remain in soil
for long periods of time. Biodegradation may be enhanced in soils
previously contaminated with PAHs. Naphthalene, a PAH with
two rings, behaves differently from other PAHs because of its
lower molecular weight and relatively high water solubility.8 The
rate of microbial degradation of PAHs in subsurface soil and in
groundwater is favored under aerobic conditions.
  Although migration of contaminants to groundwater is of con-
cern, this paper is concerned primarily with chronic effects due to
long-term exposure to contaminated soils.

ESTIMATED CONCENTRATIONS OF
CaPAHs AND BENZENE
  Concentrations of CaPAHs and of benzene in petroleum prod-
ucts vary depending on the type of crude oil and on the fractiona-
tion process used to derive the petroleum products. Table 1 sum-
marizes  information  on  the  concentration  of CaPAHs and
benzene in the various petroleum products studied. The CaPAHs
(benzo[a]pyrene  (BaP),  benzo[b]fluoranthene,  chrysene,
dibenz[a,h]anthracene, fluoranthene and  indeno[l,2,3,c-d]py-
rene) often are  present in crude oils in very small quantities
relative to the other PAHs.10  However, as indicated in Table 1,
used or spent petroleum products are enriched in content of BaP
and other CaPAHs by as much as 200-fold in some cases.2
  Information on  the concentration of benzene in the various
petroleum products studied is very limited. Of all the products
listed, gasoline has the highest concentration of benzene ranging
from 0.6 ppm to 2.9 mg/1 for all grades and octanes. Of the
gasolines, the concentration of benzene is highest in leaded gaso-
line (regular) during winter time.  The concentrations of total
benzenes  (benzene, toluene,  xylene  and other  substituted
benzenes) of 10.2% in a highly aromatic fuel oil No. 2 and of
1.0% in fuel oil No. 6'° indicate, as expected, that higher concen-
trations of benzene are found in low boiling  fuels than in high
boiling fuels. The concentration of benzene alone in these two
products was not reported.
                           Table 1
      Estimated Concentrations (ppm) of CaPAHs and Benzene
                 in Selected Petroleum Products
Petroleum Product
                                Total
                                CaPAHs*, ppm
                   Benzene, % Vol.
Crude Oil
Gasoline (regular)
Gasoline (high octane)
Gasoline (low octane)
Gasoline (unleaded)
Petroleum naphtha
    12;26.3(a)
Below  100(b)
      22.6(c)
       9.3(c)
       7.4(c)
                                                 0.2(e)
                     0.6-2.3(g)
                     0.2(h)
Fuel Oil No. 1 (jet fuel)
Fuel Oil No. 1 (kerosene)
Fuel Oil No. 2 (heating oil)
Fuel Oil No. 2 (diesel oil)


Fuel Oil No. 6 (Bunker "C")
Lubricating Oil
Fresh Motor Oil
Used Motor Oil
Used Motor Oil (5,000+ km)
Used Motor Oil (10,000+ km)
0.15(d)
0.05(b)
4.0(a)
0.7(b)
0.03(c)
37.3(d)
329(a)
0.3(c)
0.2(c)
5.8(c)
303. 6(c)
466. 6(c)
 'Ranging from one to four CaPAHs from a total of six depending on the study and on the par-
 ticular  petroleum product:  Benzo[a]anthracene,  chrysene,  benzo[a]pyrene  fluoranthene,
 dibenz[a]anthracene and indeno[ 1,2,3,c-d)pyrene.
 -Insufficient information available
 (a) National Academy Press10
 (b) U.S. EPA"
 (c) Verschueren11
 (d) U.S. EPA"
 (e) Sachanen"
 (0 Shelton"
 (g) Shelton"
 (h) Mellanl!
ESTIMATED RESIDUAL SOIL
CONCENTRATIONS OF CaPAHs AND BENZENE
  Assuming a soil cleanup level of 100 ppm of total PHs, residual
levels of CaPAHs  and of benzene  in  soil contaminated with
petroleum  products were estimated.  Residual  soil levels were
estimated using the highest concentrations of CaPAHs and of
benzene reported in the various studies reviewed. It was assumed
that no losses of these compounds occurred due to evaporation,
biodegradation or migration to groundwater. Residual soil levels
of CaPAHs and benzene were then compared to concentrations
of CaPAHs and benzene which would result in a one in a million
cancer risk if exposure were to occur. The residual soil concentra-
tions also were compared to "normal" soil background levels of
CaPAHs and benzene.

Calculation of Acceptable Soil Contaminant Levels
  The acceptable soil contaminant level (ASCL) that would pro-
tect  human health is  based on direct contact exposure with the
contaminated soil. A worst case exposure model  for carcinogens18
modified from Ford and Gurba" is shown below:
 / Acceptable Soil
  Cleanup Level
                                            1000 g/kg
                             (1)
                                                                                                    RISK ASSESSMENT    343

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where:
  A = Acceptable cancer risk =  1  x 10 ~6 (one in a million)
  C = Carcinogenic potency factor (U.S. EPA CAG)
         =  11.53 (mg/kg/day) - i for BaP-and 0.0052 (mg/kg/
        day)~ '  for benzene
     •  1000 g/kg = conversion factor
   L  = Lifetime average daily soil intake  = 0.0028 g/kg/day
  The model takes into account exposure  to contaminated soils
over a lifetime. Soil exposure is based on pica tendencies (in chil-
dren),  hand to mouthing and inhalation of dust.  It is assumed
that a  1  x  10-6 cancer risk is acceptable. Potency factors were
obtained from the U.S. EPA, Cancer Assessment Group (CAG).
The modified model does not take into consideration the half-life
of the contaminant in soil. Intake of soil during peak pica years is
assumed to be 2.5 g/day and not the 10 g/day contained in  the
original model.
  Unfortunately, carcinogenic  potency factors do  not exist  for
specific CaPAHs except for BaP. It is assumed that all CaPAHs
are as  carcinogenic as  BaP, and the potency factor for BaP was
used in the calculation. This  assumption  is consistent with  the
U.S. EPA's approach to estimating cancer risks from exposure to
mixtures of PAHs.  Acceptable soil contaminant levels of 0.03
ppm and 6.9  ppm were calculated for CaPAHs  and benzene,
respectively.

Soil Background Levels of CaPAHs and Benzene
  Information on soil background levels of CaPAHs and benzene
was obtained  from the literature. Limited  information exists on
soil background levels of PAHs in general.
                           Table 2
     Estimated Residual Soil Concentrations (ppm) of CaPAHs
     Exceeding Concentration of CaPAHs at 10 - ' Cancer Risk
         and "Normal" Soil Background Level of CaPAHs



Petroleum Product

Crude oil
Gasoline (regular)
Gasoline (high octane)
Gasoline (low octane)
Gasoline (unleaded)
Petroleum naphtha
Fuel Oil No 1 (jet fuel)
Fuel Oil No 1 (kerosene)
Fuel Oil No 2 (heating oil)
Fuel Oil No 2 (dlesel oil)
Fuel Oil No 6 (Bunker "C")
Lubricating Oil
Fresh Motor Oil
Used Motor Oil
Used Motor Oil (5,000+ Km)
Used Motor Oil (10,000+ Km)


Total
CaPAHs*,
ppra
3xlQ-3(a)
9xlO~£(b)
7x10" (b)
2x10 (b)

j
2xlO"'(c)
5xlO~°(d)
4x10". (c)
4x10 j(c)
3x10 ,(b)
3x10 '(a)
2xlO"'(b)
6xlO"*(b)
3x10 , (b)
5x10 (b)
Total
CaPAHs
Exceeding
Cancer
Risk**
N
N
N
N


N
N
N
N
N
N
N
N
N
Y
Total
CaPAHs
Exceeding
"Normal"
Soil
Background* *
N
N
N
N


N
N
N
N
N
N
N
N
N
N
*One 10 four CaPAHs from a tola! of six depending on study and on particular petroleum prod-
uct: Benzofajpyrene, benzo[a]anthraccnc, benzo(b)ftuoranthene, chryscne, dibcnz[a,b]amhra-
cenc, and indeno[l,2,3,c-d]pyrenc.
"CaPAHs at 10 ~6 cancer risk (based on BaP): 003 ppm
•""Normal" soil background of PAHs: 0.05 ppm
- Insufficient information available
Y Exceeding
N Not exceeding
(a) National Academy Press,"'
(b) Verschuercn"
(c) U.S. EPA"
(d) U.S. EPA"
  Natural  PAHs are due to plant synthesis, forest  and prairie
fires, volcanoes, etc.  Anthropogenic sources are primarily from
the extraction, processing and burning of fossil fuels.  Most of the
research on soil background levels of PAHs has been performed
on BaP. Therefore, selection of "normal" soil background levels
of PAHs was based on BaP.
  The concentration of total PAHs (the sum 5 to 20 PAHs) usual-
ly exceeds 10 times the concentration of BaP.'° BaP levels ranging
from less than 5 to  10 ppb are  generally found  in  agricultural
soils.1 Typical concentrations of  BaP in soils of the world range
from about 100 to 1,000 ppb, and values exceeding 100,000 ppb
have been  reported near known sources." It has been suggested
that endogenous BaP concentrations in soil are 1-3 ppb and never
exceed 10 ppb.10 A level of 50 ppb was selected as the "normal"
background of total PAHs in soil  since this level is typically found
as background.'
  Limited  data are available on  benzene levels in soils. Levels
ranging  from 13  to   115 ppb of  benzene were  reported in soil
samples  taken in the  vicinity of chemical  plants that  use or pro-
duce benzene." No information exists on the level of benzene in
"clean" soils. A soil background level of less than  10 ppb was
selected  since this level Is  within the range  of "normal"  soil
background levels  of most organics.'
  The ASCL of  30  ppb  for CaPAHs (assuming a 1  x \Q-6
cancer risk) is within  the range of typical soil background levels of
PAHs.  However,  the ASCL of  6.9 ppm  for benzene exceeds
typical soil background levels of benzene.
  Examination of Table 2 reveals that, after site remediation to
110 ppm of total PHs, only soil  contaminated with  used motor
oils over 10,000 km will have concentrations of CaPAH that ex-
ceed a I  x  10-6 cancer risk (by approximately 67%). As shown

                           Table 3
    Estimated Residual Concentrations (ppm) of Benzene Products
      Exceeding Concentration of Benzene at 10-* Cancer Risk
         and "Normal" Soil Background Level of Benzene
Petroleum Benzene. ppn
Crude oil 0.2U)
Gasoline (regular) l.l-2.9(b)
Gasoline (high octane)
Gasoline (low octane) 1.1-?. 9(b)
Gasoline (unleaded) 0.6-2.3(c)
Petroleum naphtha 0.2(d)
Fuel Oil No. 1
(Jet fuel)
Fuel Oil No. 1 (kerosene)
Fuel Oil No. ! (heating oil)-
Fuel Oil No. 2 (dlesel oil)
Fuel Oil No. 6
(Bunker "C")
Lubricating Oil
Fresh Motor Oil
Used Motor Oil
Used Motor Oil
(5,000+ Km)
Used Motor Oil
(10,000+ Km)
Benzene
Exceeding
10
Cancer
Risk**
N
N
N
N
N
N




-


_
_
_

.


Benzene
Exceeding
"Noroal"
Soil
Background**
Y
Y
Y
Y
Y
Y

.




.

_
.

_

-
"ASCL for CaPAHs at 10 ~ * cancer rijk: 6.9 ppm
""Normal" SBL of benzene: less than 0.01 ppm
- Insufficient information available
Y Exceeding
N Not exceeding
(a) Sachancn"
(b) Shelton"
(c) Shellon"
(d) Mellan"
344    RISK ASSESSMENT

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in Table 3, soil contaminated with crude oil, naphtha and gasoline
(all grades and octanes) has benzene levels below the ASCL for
benzene.  Comparison with  "normal"  soil  background levels
reveals that residual soil concentrations of CaPAHs are within the
range of "normal" soil background levels of PAHs. However,
residual soil concentrations of benzene from contamination with
crude oil, petroleum  naphtha  and gasoline  (all grades and oc-
tanes) are above the "normal" soil background level of benzene
as expected.  The residual soil concentrations of benzene from
crude oil and naphtha exceed the soil background level of benzene
in excess of 20 times and that from gasoline by 90 times.

CONCLUSIONS AND RECOMMENDATIONS
  Assuming a soil cleanup level of 100 ppm for total petroleum
hydrocarbons, most of the residual soil  levels of  CaPAHs and
benzene are below their corresponding concentrations resulting in
a 1 x  10~6 cancer risk. An exception is the residual soil level of
CaPAHs from contamination  with used  motor oils over 10,000
km which has a risk of 1.6 x 10~6. In this case, lowering the soil
cleanup level of 100 ppm  to 60 ppm for total PHs, will decrease
soil concentrations of total CaPAHs from contamination of the
above  product to levels resulting in a cancer risk of 1 x  10 ~6.
Alternatively, testing soil samples for CaPAHs could be per-
formed after soil is cleaned to 100 ppm of total PHs to determine
if CaPAHs levels remaining in  soil are acceptable.
   Comparison  of residual soil levels of CaPAHs and benzene
with their respective  soil background  levels,  indicates that, in
general, residual levels of CaPAHs are within the range of typical
soil background levels of PAHs. On the other hand, residual soil
levels of benzene exceed the assumed "normal" soil background
level of benzene. Further refinement of this comparison cannot be
made at this time due to  limited information  on "normal" soil
background levels of these compounds  and due to the volatiliza-
tion of benzene with time.
   A more extensive data base on petroleum products is needed to
refine the risk assessment  approach proposed.  Specifically, more
data on  the identification and  concentration of chemical consti-
tuents, behavior in the soil environment, toxicity and normal soil
background concentrations are needed.
   More toxicity testing of petroleum products and individual con-
stituents is needed to better understand the carcinogenic potency
of individual CaPAHs and  of mixtures  before a more  refined
ASCL can be estimated.
   In  summary,  with the  exception of  motor oils used over
 10,000 km, 100 ppm of total PAHs as a soil cleanup objective ap-
pears to  result in residual  soil levels of CaPAHs and benzene not
exceeding a 1 x  10~6 cancer risk.  Although this cleanup objec-
tive is protective in a direct soil contact scenario, it may not ade-
quately address ground water protection.

ACKNOWLEDGEMENTS
   We greatly appreciate the assistance of  Professor Richard Bar-
tha,  Rutgers University, Dr. Neill  K.  Weaver,  American
Petroleum Institute and Dr. Merry L. Morris, New Jersey Depart-
ment of Environmental Protection, in  the development of this
manuscript.

REFERENCES
  1. Curl, H. Jr. and Donnel K., "Chemical and Physical Properties of
    Refined Petroleum Products," Boulder, CO,  National Oceanic and
    Atmospheric Administration/Environmental Research Laboratories,
    Marine Ecosystems Analysis Program, NOAA Technical Memoran-
    dum ERL MESA-17, U.S. Department of Commerce (Oct. 1977),
    5-26.
 2. Bingham,  E., Trosset, R.P. and Warshawsky, "Carcinogenic Po-
   tential of Petroleum Hydrocarbons. A Critical Review of the Litera-
   ture," J. of Environ. Path, and Toxicol. 3, (1979, 483-563.
 3. U.S. EPA, "Estimation of the Public Health Risk From Exposure to
    Gasoline Vapor Via the Gasoline Marketing System." Staff Paper
    submitted for review to the Science Advisory Board, Office of Health
    and Environmental Assessment, Office of Air Quality and Planning
    and Standards, U.S. EPA, Washington, DC, June 1984.
 4. Sheppard, E.P., Wells,  R.A. and Georghiou, P.E., "The Mutagen-
    icity of the Prudhoe Bay Crude Oil and Its Residues from an Experi-
    mental In Situ Burn," Environ. Research 30, (1983), 427-441.
 5. National Institute for Occupational Safety and Health, "Registry of
    Toxic  Effects of Chemical Substances," 1983 Supplement to the
    1981-82 Edition, U.S.  Government  Printing Office, Washington,
    DC, [DHHS(NIOSH), 84-101], 1984.
 6. Sittig,  M., Handbook of Toxic and Hazardous Chemicals and Car-
    cinogens, 2nd. Ed., Noyes Publications, Park Ridge, NJ, 1985.
 7. Bossert, E. and Bartha, R., "The Fate of Petroleum in Soil Ecosys-
    tems." In: Petroleum Microbiology, Ronald H. Atlas, Ed., Mc-
    Millan Publishing Company, New York, NY 435-470.
 8. American Petroleum Institute, "The Land Treatability of Appendix
    VIII Constituents Present in Petroleum Industry Wastes," American
    Petroleum Institute, Washington, DC, API  Publication 4379 Docu-
    ment B-974-220, May 1984.
 9. Bonazountas, M.,   "Mathematical  Pollutant  Fate  Modeling of
    Petroleum  Products in  Soil Systems," Lectures at  Conference on
    Environmental and  Public Health Effects  of Soils  Contaminated
    with Petroleum Products, University of Massachusetts, Amherst,
    MA, Boston, MA, Epsilon International Inc., Oct. 1985.
10. National Academy Press, "Chemical  Composition  of  Petroleum
    Hydrocarbons Sources." In: Oil in  the Sea, Inputs, Effects, Na-
    tional Academy Press, Washington, DC, 1985, 17-42.
11. U.S. EPA, "An Exposure and Risk Assessment for Benzo(a)pyrene
    and Other Polycyclic Aromatic Hydrocarbons," Final Draft Re-
    port, Office of Water Regulations and Standards, U.S. EPA, Wash-
    ington, DC, 1982, 5-187.
12. Verschueren, K., Handbook  of Environmental Data  on  Organic
    Chemicals, 2nd. Ed., Van Nostrand Reinhold Company, Inc., New
    York,  NY, 1983.
13. U.S. EPA,  "Quantitative Analysis of Polynuclear Aromatic Hy-
    drocarbons  in Liquid  Fuels,"  Environmental  Sciences Research
    Laboratory, U.S. EPA, Research Triangle  Park, NC, EPA-600/2-
    80-069, Apr. 1980.
14. Sachanen, A.N.,  "Hydrocarbons in Gasolines, Kerosenes, Gas Oils,
    and Lubricant Oils." In:  The Chemistry of Petroleum Hydrocar-
    bons, Reinhold Publishing Corporation, New York, NY, 1,  1954.
15. Mellan, I., "Pure Hydrocarbons," In: Handbook of Solvents, Rein-
    hold Publishing Corporation, New York, NY, /, 1957.
16. Shelton, E.M. and Dickson, C.L., "Motor Gasolines, Winter 1984-
    85," National Institute for Petroleum and  Energy  Research, Bar-
    tlesville, OK. Work performed  for the American Petroleum Insti-
    tute, Washington, DC, NIPER-140PPS 85/3, June 1985.
17. Shelton,  E.M. and Dickson,  C.L.,  "Motor Gasolines, Summer
    1984," National Institute for Petroleum and Energy Research, Bar-
    tlesville, OK. Work performed  for the American Petroleum Insti-
    tute, Washington, DC, NIPER-138PPS 85/1, Feb. 1985.
18. Dime,  R. and Greim, B., "Calculation of Cleanup Levels for Con-
    taminated  Soils," Unpublished Manuscript, N.J. Department of
    Environmental Protection, Hazardous Site  Mitigation Administra-
    tion, Trenton, NJ, 1985.
19. Ford, K.L. and Gurba,  P., "Health  Risk Assessment For Contam-
    inated  Soils," Proc. of the 5th National Conference on Management
    of Uncontrolled  Hazardous Waste Sites, Washington,  DC, Nov.
    1984.
20. Edwards, N.T., "Polycyclic Aromatic Hydrocarbons (PAHs) in the
    Terrestrial Environment—A Review," /. Environ. Qual., 4, (1983),
    427-441.
21. U.S. EPA, "An Exposure and Risk Assessment for Benzene," Final
    Draft Report, Office of Water Regulations and Standards,  U.S.
    EPA, Washington,  DC, 1980.
                                                                                                       RISK ASSESSMENT    345

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                                 Risk Management:  Personnel,
                                     Equipment and Indemnity
                                                  Denny M.  Dobbs
                                                  Arlene B.  Selber
                                                  HAZTECH,  Inc.
                                                  Atlanta,  Georgia
ABSTRACT
  Risk management always has been a key ingredient in the over-
all management scheme of the hazardous materials cleanup and
site restoration industry. Since the industry's beginnings in the
early 1970s, companies have been  practicing risk management,
whether or not identified b.y that particular name. As the industry
has evolved and more has been learned about potential risks, the
need for a well-defined risk management program has increased.
Current health and safety regulations, increased litigatory actions
and the ominous problems with insurance  coverage have pro-
duced a realization of the critical nature and overall importance
of risk management. Three areas where risk management  can
have a significant impact on company operations are personnel,
equipment and general indemnity.
INTRODUCTION
  Risk management can be defined as the management or con-
trol of the possibility  of loss  or injury. This management has
both a social or moral aspect as well as practical ramifications.
A waste of manpower, time, resources  and efficiency are just a
few of the effects  of accidents  that could have been managed or
prevented. In order to manage risk, one  must identify the follow-
ing for all potential risks: degree of hazard or danger; probability
of occurrence; methods of prevention; and preferred health and
safety plan.
  Identifying and  managing risk has become so important to the
hazardous waste industry and  to society that  many  universities
have recently added risk management courses to their core insur-
ance curriculums.  Businesses are beginning to employ people that
have risk management as their prime job function. Personnel,
equipment and general indemnity  are the three areas that this
paper will address.
PERSONNEL
  The one area most often overlooked in an active growing com-
pany  is  the area of personnel  management. Personnel manage-
ment  encompasses a wide range of functions, but for the pur-
poses of this paper, only the area of risk management will be dis-
cussed.  Risk management as it relates to personnel involves min-
imizing  exposure to hazardous conditions, providing and requir-
ing proper training, publicizing and maintaining employee  inter-
est in safety and instituting an efficient record-keeping system.
  Hazardous materials cleanup work involves, by its very nature,
a certain degree of exposure to risk. The job of risk management
is to minimize the degree and quantity of that exposure. The de-
gree of  exposure relates to the  individual's physical exposure,
while quantity relates to the number of individuals actually ex-
posed. Both of these concerns usually arise in operational settings
where prior planning is the best solution to potential problems.
Exposure
  Physical exposure is minimized by a thorough knowledge of
the work site and conditions present. What  chemicals are in-
volved?  What  properties, concentrations, etc., did the analysis
reveal?  Is there potential exposure to irritants, poisons,  skin
absorption, etc?
  Once  the hazardous conditions are defined, the proper selec-
tion of protective equipment  and safety measures can be made.
The equipment selected may include what types of boots, gloves,
respirators or supplied air system, protective suit or coveralls, are
required. Once the proper type of equipment has been selected,
management must make  sure that the employees use and main-
tain the equipment correctly.
  The investment in time and effort required to correctly  pro-
tect employees and minimize physical exposure pays significant
dividends in workplace efficiency and decreases the risk of litiga-
tory actions.
  Quantity exposure as described earlier involves numbers. Gen-
erally, in the hazardous materials business, numbers relate most
directly  to  the number of  employees  specifically  involved.
Thorough planning before a  job begins is the best method of
controlling quantity exposure. A careful study of the scope of
work and the proposed work  plan will allow the project manager
to properly select his  project  team. The project manager's work
plan should  be designed to expose the  fewest number of em-
ployees. Fire departments, police departments and military units
have successfully  followed  this principle  for many  years. In
reality,  basic common sense plus careful  analysis and safety
planning will minimize the number of persons exposed.

Training
  How  important is training? Would you fly with an untrained
pilot? Would you hire an untrained lawyer? It is obvious, given
the current regulatory  attitude toward the work place, that proper
employee training is critical.  In  the early days of this industry,
many things  were done without adequate training because the in-
dustry was so new and procedures and standards were ill-defined.
As the industry has grown and aged, it has defined many of the
skills required  to work safely and can now train people in these
skills.
  Training in the hazardous materials industry is a cross between
EMT, fire department and military training programs. A train-
ing program should include a discussion of standard work prac-
tices,  personal hygiene, first aid, CPR, etc. Detailed training in
the selection and proper wearing of protective equipment is essen-
tial. Training with the proper content and attitude  is like preven-
tive maintenance for your work force.
346    RISK ASSESSMENT

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Record Keeping
  The last area that will be discussed under personnel is record
keeping. So far, the discussion of risk management has had a pure
health and safety theme. Record keeping, however, is necessary
to facilitate the treatment of an employee and to serve as proof
that adequate training was offered and required. The question of
risk management versus liability will be  discussed in the last sec-
tion of this paper.
  Keeping accurate records is proof that a particular health con-
dition was or was not job related, or that someone  was or was
not injured by exposure to a hazardous situation. Given the occu-
pational health and safety  and workmen's compensation laws
currently in existence, detailed personnel records are  an absolute
must.

EQUIPMENT
  Risk management with regard to equipment, particularly over-
the-road equipment, in view of the current insurance crisis and
large injury awards for equipment-related injuries must be an in-
tegral part of business strategy. The following example illustrates
this.
  An employee driving a company truck is involved in an "at
fault" accident. It is determined that the employee was DUI in a
truck with faulty brakes, and the other  driver sustained injuries.
Is this scenario not an example of the importance of driving safely
and adhering to company policy adequately communicated to the
driver? No business can afford to fail to communicate the impor-
tance of proper equipment maintenance to its operations depart-
ment. The difficulty of obtaining insurance continues  to reinforce
the necessity of the proper maintenance and use of equipment.
  The hazardous waste industry requires a variety of equipment
including trucks, cars, heavy equipment, protective suits, respira-
tors,  masks, hand  tools, eye  wash bottles, decontamination
equipment, etc. Often, the major emphasis or interest is focused
on equipment which can be driven on public highways. However,
no piece of equipment should be placed in operation until it has
been inspected by a qualified person and found to be in safe oper-
ating condition. Routine inspection after each project should be
made, and inspection reports and  service records should be kept
on file.
  Obviously, the most logical way to minimize equipment related
injuries and  losses is through the proper maintenance and use of
that equipment. A U.S. Army Corps of Engineer study revealed
that a "great majority of accidents were  caused by inadequate
maintenance of equipment,  insufficient instruction in safe prac-
tices or lack of insistence that safe practices be observed." Un-
safe practices contributed to 80% of all injuries. Remember the
example given earlier in this section: equipment related losses can
become extremely complicated and costly if they are not posi-
tively affected by good risk management practices.

INDEMNITY
  According to Webster, indemnification is "the action of secur-
ing against hurt, loss or damage." Nothing causes more concern,
argument, loss of coverage or law suits than the subject of indem-
nity. The most difficult  area to negotiate for any contract is the
indemnity section. Ideally, you would want to be indemnified
for everything and yet give indemnification for nothing. Prac-
tically, you must negotiate the best  position you can with the
other party. One of the important things to remember is that most
insurance  coverages are  tied very  closely to indemnification and
how it affects the risk that you are being insured against. The first
rule of good business practice is to be absolutely sure that you can
live with the indemnification you  agree to  because you just may
have to live with it. Never agree to accept a risk expressly prohib-
ited by your insurance coverage unless you intend to self-insure
that risk.
  This paper  will not discuss all the legal ramifications of indem-
nities. However, one major point  should be recognized. The law
does not make an engineer completely responsible for a project's
success. Engineering is not a perfect science, and "acts of God"
can occur  even when an  engineer exercises professional judgment
and utilizes adequate skills. Indemnification clauses, written to
the advantage of your client, can make the engineer (and your
company) a guarantor, an insuree, of a project's success.  Do not
agree to this.
  Indemnification is a major vehicle to either increase or decrease
risks, so be aware of what you agree to indemnify. It is the recom-
mendation of the authors  that you only be liable for your  own
negligence.

CONCLUSIONS
  Risk Management is a function of management that requires
thought, planning, implementation and considerable expertise.  It
becomes more important as the  hazardous waste industry con-
tinues to be plagued by loss of insurance  coverage, workmen's
compensation claims, litigation and huge jury awards. The im-
portance of managing risk is being recognized by industry and
academia and is fast becoming an integral part of successful com-
panies' management plans. Good risk management in the areas of
personnel, equipment and indemnification  is good business, and
good business is what makes a good profit.
                                                                                                    RISK ASSESSMENT    347

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                      Innovative Approach  to  Site Remediation
                            Involving an  RCRA  Part B  Permit

                                            Michael J. Conzett, P.E.
                                             Michael E. Harris,  P.E.
                                    HDR  Environmental  Technologies,  Inc.
                                                Omaha, Nebraska
ABSTRACT
  A preliminary investigation of an abandoned industrial waste
disposal site indicated the presence of materials containing haz-
ardous substances and groundwater contamination. The parties
involved are the owner, the Iowa Department of Water, Air and
Waste Management (IDWAWM) and the U.S. EPA Region 7. As
a result of the preliminary investigation, a stipulation between
the owner and IDWAWM was enacted. A detailed site investiga-
tion confirmed the following:
• A complex geophysical structure
• The presence of material containing hazardous substances
• The presence of a layer of floating volatile organic compounds
  (VOCs)
• The presence  of contaminated groundwater in the vicinity of
  the site
  To date, the owner has undertaken the remedial investigation
activities and proposes to voluntarily undertake  the  feasibility
study and cleanup. To meet the needs of the owner and satisfy the
requirements of the regulatory agencies, it was determined that a
Part B permit for Waste Piles would be required as part of an
innovative approach to site remediation.

INTRODUCTION
  Industrial wastes resulting  from the manufacture of paint and
varnish products were placed into a land disposal facility.  The
aquifer directly under the site is utilized as a source of water for
domestic and agricultural uses throughout the area. This prox-
imity of waste and groundwater was sufficient  cause to place the
site on the proposed  National Priority List. In this paper, the
authors describe the following: site history; remedial  investiga-
tion activities; summary of releases/contamination; proposed re-
medial action plan; owner/regulatory agencies  relationship; Part
B permit; and the innovative approach to site remediation.

SITE DESCRIPTION AND HISTORY
  Prior to the early 1970s, the owner disposed of his  wastes by
open burning. Enactment of the Clean Air Act, however, pro-
hibited this practice, and an  alternate method of disposal  was
necessary. The owner sought the aid of the Stale of Iowa, and an
agreement was reached whereby the owner's wastes were to be
disposed at an abandoned gravel pit in rural Iowa.
  Between 1971 and 1979, solid and liquid wastes generated from
the owner's paint and varnish  manufacturing operations were dis-
posed in a series of 12 trenches at the site (Fig. 1).  The trenches
were slot-dozed  to a depth  of between 8 and 12  ft.  After the
trenches were opened, they v»ere filled with waste fluids poured
from 55-gal drums. Each trench remained open for an extended
period of time to allow for evaporation of volatile hydrocarbons.
Before a trench was closed, it was topped off by placing in it a
relatively large quantity of drums and small buckets containing
waste paint sludges, resins, solvents and general trash. After the
level of  waste material  in each trench approached the natural
ground surface, the trench was covered with 1 to 2 ft of the clayey
silt loess soils initially excavated from the trenches.
                         Figure 1
             Plan View of Waste Disposal Trenches
  Although accurate records were not kept by the owner, an esti-
mated  150 to 300 drums (55-gal) were buried at the site and as
many as 43,000 gal  of liquids were dumped in the trenches. The
wastes  contained approximately 6,000 Ib of heavy metals (e.g.,
lead, cadmium, chromium, zinc and mercury) and an unknown
quantity of volatile organic compounds (e.g.,  xylene,  toluene,
ethylbenzene, methylethyl ketone and mineral spirits).
  The  waste disposal site was closed  in 1979. Wastes generated
after 1979 were disposed in properly permitted facilities.

REMEDIAL INVESTIGATION
  Remedial investigation activities began in 1979 at the request of
the State of Iowa.  The ultimate goal of these  activities was to
obtain  sufficient information regarding the soil and groundwater
contamination at the site so that a closure plan could be devel-
oped and implemented. Because of the complex geophysical na-
348
       RCRA AMENDMENT l-.XPCRH-.NC'I.

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ture of the site, remedial investigation activities were conducted
in several phases between 1979 and the end of 1984. A brief sum-
mary of the activities performed during this time is presented be-
low.

  1979—Activities were limited to a subsurface investigation to
determine potential off-site migration of wastes. Thirty of thirty-
five borings were drilled on and immediately adjacent to the site.
Only water level measurements were taken, and the borings were
subsequently backfilled.
  1982—Five monitoring wells were installed. Floating hydrocar-
bons were detected in one of the wells and samples were taken
during subsequent months for chemical analyses.
  1983-1984—The presence of a substantial thickness of floating
hydrocarbons  in  two  of  the monitoring wells  prompted
IDWAWM to issue an administrative order requiring contain-
ment  and recovery of the contaminant plume, proper disposal
of recovered waste and proper closure of the site.
  May 1984—Observation pits were dug at the site to determine
the approximate  quantities  of waste materials  buried  in  the
trenches. Samples  also were  taken  from the trenches and from
other soil borings to determine the concentrations of hazardous
constituents in the trenches and soil. The geological stratigraphy
of the site was evaluated. Seventeen monitoring wells were in-
stalled and developed.  Groundwater samples were subsequently
obtained and analyzed for contamination.
  August 1984—IDWAWM  ordered the owner to remove float-
ing hydrocarbons  periodically  and to take quarterly  samples
from the monitoring wells.
  September  1984—Nine additional  monitoring  wells were in-
stalled and developed.  Testing was conducted to determine the
aquifer characteristics.
  Present—The owner continues to remove floating  hydrocar-
bons, make biweekly water level measurements in the monitor-
ing wells and take quarterly groundwater samples.

SUMMARY OF RELEASES/CONTAMINATION
  As  a  result of the disposal of hazardous waste liquids in the
trenches beginning in 1971, the most immediate impact has been
the release of hazardous materials to the underlying shallow
aquifer system. A secondary impact due to the continuing deteri-
oration of buried drums probably is resulting in more recent and
continual releases of hazardous materials to the aquifer.
  Due to  the unique characteristics of the hydrogeology in the
area of the site, the extent of groundwater contamination appears
to be limited  to the site and to a distance only several hundred
feet away from the site. The degree of groundwater contamina-
tion depends on the compound. The maximum concentration of
the volatile organic compounds ranges from 28 mg/1 for toluene
to 260 mg/1 for xylene. The maximum concentration  of heavy
metals ranges  from 50 ng/1 for lead to 80 ug/1 for chromium.
  The extent  of soil contamination is limited primarily to  the
waste disposal trenches and the vadose zone directly below the
site. The maximum degree of soil contamination ranges from 15
ppm for chromium to 1,700 ppm for xylene.
  As mentioned in the remedial investigation section, there is a
floating layer  of relatively pure hydrocarbons that is unique to a
small  portion of  the groundwater adjacent to the site. These
hydrocarbons are removed by  pumping biweekly as part  of an
IDWAWM stipulation.

PROPOSED REMEDIAL ACTION PLAN
  A feasibility study currently is being written to compare vari-
ous remedial action alternatives for cleanup of the disposal site.
The objective of the feasibility study is to recommend a remedial
action plan for cleanup of soil and groundwater that effectively
provides protection of human health and the environment at the
least cost.
  The proposed remedial action plan will likely include the clean-
up activities discussed below.

Source Removal and Ultimate Treatment
  Hazardous wastes will be exhumed from the trenches and will
be disposed in properly permitted facilities or will be treated in a
manner to render the wastes non-hazardous.
  Free-standing liquid wastes in the trenches and liquids taken
from drums will be stored temporarily in a tanker truck. Then
the liquids either will be recovered in the owner's distillation
equipment or will be sent off-site and ultimately destroyed by in-
cineration.
  Solid wastes (e.g., contaminated soil, drums, buckets,  trash,
etc.) will be stored temporarily on-site  in above-ground concrete
bunker silos. Treatment technologies for the solid wastes will be
investigated and/or tested while the wastes are safely stored in
the silos. Treatment methods may include incineration, air strip-
ping, encapsulation, biodegradation and physical/chemical treat-
ment.

Recovery and Treatment of Groundwater
  Groundwater will be pumped, treated and reinjected into the
aquifer. The  treatment/flushing action will  continue until the
groundwater is rendered non-hazardous. Treatment methods like-
ly will include air stripping and carbon adsorption.

Owner's Involvement
  The owner has  expressed a high degree of interest in the pro-
posed remedial action plan presented above. His basic philosophy
is to have as much control of his present and future liability as
possible. He believes that the proposed remedial action plan will
provide effective remediation of the site at the least cost and with
the least liability. In addition, the least  cost treatment technology
which will render  the wastes non-hazardous may be found while
the waste is safely stored on the owner's property.  Not surpris-
ingly, this general type of remedial action (i.e., on-site storage/
treatment) is favored by the U.S. EPA.

OWNER/REGULATORY AGENCIES
RELATIONSHIP
  Three parties (the owner, IDWAWM and the U.S.  EPA Region
7) are involved with the cleanup of the disposal site. Due to the
nature of the relationships among the  three parties, there could
have been some potential problems. The owner is a responsible
private party willing to finance  the remedial investigation/feasi-
bility study and site cleanup. IDWAWM is responsible for the
cleanup and monitoring of uncontrolled hazardous waste disposal
sites in the State of Iowa. The U.S. EPA Region 7 is responsible
for all RCRA programs.
  The State of Iowa returned RCRA  responsibility to the U.S.
EPA in mid-1985. Included in the U.S. EPA's RCRA responsi-
bility is  the issuing of Part B permits for treatment, storage and
disposal facilities  and the monitoring of these  same facilities.
Cooperation among the three parties in the past and at the pres-
ent time has allowed effective progress toward site cleanup.
  When the owner expressed  interest in storing the  exhumed
wastes on-site, a meeting was convened with the regulatory agen-
cies to discuss the ramifications of this proposed action. Although
the owner's disposal  site is on the proposed National Priorities
List (NPL), the owner learned that an RCRA permit would be re-
quired prior to the construction of the storage facility.  Because
the site was not under an emergency cleanup order, the require-
ments of other environmental laws (e.g., RCRA) would have to
be followed. The  regulatory review of a Part B permit applica-
                                                                                    RCRA AMENDMENT EXPERIENCE    349

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tion can take a great deal of time. The owner wished to Icean up
the site as quickly as possible and  was naturally disappointed
when he learned a permit was required.  It would have  been easy
for the owner to criticize the U.S. EPA for "dragging its feet"
regarding the cleanup of the site; however, the requirements of
the RCRA permit program were seen by the owner as  necessary
to protect human  health and the environment from  potential
damage as a result of the cleanup.
   It is especially important to develop good relationships between
the owner and the regulatory agencies involved in a site cleanup.
Issues can be addressed and problems can be solved only if each
party  keeps  an  open  mind and  communicates  and cooperates
with the others.

PART B PERMIT
   To  fulfill the owner's desire to store the exhumed hazardous
wastes in  an above-ground facility, a Part B permit was required.
As mentioned previously, the cleanup  of  this site required  the
adherence to other environmental laws, most notably RCRA. The
filing of a Part B permit application  for this innovative approach
to site remediation is unique.  Historically,  cleanup of an uncon-
trolled waste site involves the transportation of the wastes to an
off-site RCRA-permitted disposal facility. This  action does not
require the owner of the uncontrolled waste site to wait while a
permit is  reviewed  and approved; however, it  also does not give
the owner much control over his liability. In the  case study re-
ported in this paper, the owner is willing to wait for a Part B per-
mit in order to implement an innovative  approach that allows him
to better control his liability.
LOCATION CT CONCRETE -*•   •  C.HION
1TOHAOI IlLOS U«0 TO   /
 1TOAI ElMtMEO WASTE
 NO CONTAMINATED  SOIL   /

         V         I
                            Figure 2
           Location of Bunker Silos Relative to Disposal Site
 Facility Description and Use
   The Part B permit application was made for a new on-site stor-
 age facility comprised of four above-ground bunker silos located
 adjacent to the waste disposal site (Figs. 2 and 3). Each silo will be
 rectangular with its dimensions being 56 ft wide, 104 ft long and
 a wall height  of  12 ft. Each silo is expected to store,  in piles,
 approximately 1,750 yd' of waste.
                                            DNAINAOC O'TCN
                                            torn HUM OM
                                            COMTMOL V"^
                                                                 Figure 3
                                                          Site Plan of Bunker Silos
                                                                     The sole purpose of the facility is to temporarily store contam-
                                                                  inated soils and other hazardous solid wastes that will be removed
                                                                  from the waste disposal site. Liquid wastes or soils containing free
                                                                  liquids will not be stored. These materials are to be either solidi-
                                                                  fied on-site prior to storage or manifested  and transported to a
                                                                  licensed facility for incineration.
                                                                     The waste materials are to remain in storage while various tech-
                                                                  nologies are investigated and/or tested to  treat them. The ulti-
                                                                  mate goal is to treat the materials in the storage facility to perma-
                                                                  nently render them nonhazardous. Then the waste materials can
                                                                  be delisted. The treated soils can be returned to the disposal site,
                                                                  and the other solid materials can be disposed as non-hazardous
                                                                  wastes.
                                                                                  ACC1S1 PANfl
                                                                                  '01 WASTI
                                                                                  PLACtUfNT
                                                                                                          WlM* VCNT1LATIOM
                                                   *—ACCCIS DOOR
                                                                              SUMP NOOM-
                                                                  Figure 4
                                                     Elevation View of Typical Bunker Silo
 350    RCRA AMENDMENT EXPERIENCE

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  Bunker Silo Design Elements
    The bunker silos  are designed to provide protection of the
  waste piles from precipitation so that neither runoff nor leach-
  ate is generated. Each silo will have a reinforced concrete base,
  concrete walls and a steel roof (Figs. 4 and 5). A 6-in. concrete
  curb will surround the silo, thus providing protection from sur-
  face water run-on. Because the waste pile will be enclosed by walls
  and a roof, the wastes will not be dispersed by the wind. Because
  liquids will not be placed in the piles, leachate is  not expected to
  be generated  by biological or chemical degradation during the
  time the piles are in existence. Each silo also will be equipped with
  a ventilation fan to  minimize the buildup of organic vapors to
  explosive levels.
    The above elements of the structure are considered sufficient to
  allow the owner to request an exemption from liner and leachate
  standards and from  groundwater monitoring requirements under
  the 1984 RCRA Amendments. Although a request was  made for
  the above exemptions, it is the owner's stated intent to provide
  a state-of-the-art facility.  Therefore, for added protection  of
  human health and the environment resulting from the potential
  release of hazardous wastes, a double synthetic liner system will
  be installed accompanied by leak detection and  leachate collec-
  tion systems (Figs. 5  and 6).
6" CONCRETE CUHI
EXTENDING 6"
ABOVE GRADE
             -CONCRETE FOOTING
                          a- REINFORCED'
                          CONCRETE SLAB
LEAK DETECTION
SYSTEM - r-0- GRANULAR
BED WITH 4- PVC
PERFORATED PIPE (TYPICAL)
                           Figure 5
        Typical Cross Section of Silo Showing Design Elements
    The owner chose to include synthetic liners and leak detection/
  leachate collection systems in the design of  the storage silos to
  serve as an additional safety factor. The owner had enough fore-
  sight to  realize that,  for a  relatively small increase in cost,  he
  could decrease his liability considerably by minimizing the poten-
  tial for a non-sudden release of hazardous waste.

  Placement of Wastes
    An auger will be used to transfer the waste materials into each
  silo via open panels in the roof. Inside the silo, a small end loader
  will move the materials into  a pile. Plastic sheeting will be placed
  on the ground around the auger to collect spillage. Portable wind
  screens near the auger will prevent wind dispersal of dry waste
  materials.

  Closure of Facility
    As mentioned previously, the goal of the remediation program
  is to ultimately treat the soils and wastes so that they can be dis-
  posed as non-hazardous materials. The duration of storage in the
  bunker silos is unknown and will be dependent upon the develop-
  ment of appropriate technologies and subsequent testing of these
                                                                    ACCESS RAMP OPENING-
                                        ' LEAK DETECTION SUMP—
                                         <2'-0-i2'-0-*3'-0- DEEP)
                                                                   'PRECAST CONCRETE
                                                                    WALL
                                                                                                 SUMP ROOM -
                                                                  ^SYNTHETIC
                                                                  '  LINERS
                                                                   -TYPICAL PERFORATED
                                                                   PVC PIPE (FOR LEAK
                                                                   DETECTION)
                                                                                                               - LEACHATE
                                                                                                                COLLECTION  SUMP
                                                                                                                (2''0~x2''Q~x3''0~ DEEP)
                                                                                              Figure 6
                                                                              Plan View Cross Section of Typical Bunker Silo
technologies on the stored wastes to determine what constitutes
effective treatment. It is possible that future technologies will not
prove completely effective and that one or more of the silos may
need to be repermitted as disposal facilities.
  If treatment technologies are proven effective and the wastes in
the piles are removed and rendered non-hazardous, the storage
silos will be closed. The bunker silos and equipment  stored with-
in them will be tested  to determine if they are contaminated.
Appropriate procedures will be used to decontaminate any con-
taminated structure or equipment.

INNOVATIVE APPROACH TO SITE
REMEDIATION
  Because the owner wanted to clean up his site as soon as pos-
sible,  a two-stage  approach to remediation originally was  con-
ceived. The scenario was  as follows.  The first stage of this ap-
proach would involve removal of the source of contamination. A
feasibility study addressing source removal  would  be written,
followed by review and approval by ISWAWM. Following ap-
proval, the cleanup of the source would begin and take approx-
imately 6 to 7 months using the services of local contractors.
  While the source is  being removed,  the second stage  of the
approach, remediation of groundwater, would be addressed.  A
feasibility study for this stage  would  be prepared. Following
IDWAWM review and approval,  tne groundwater cleanup would
begin in the subsequent calendar year.
  When it was learned that a Part B permit would be required
for on-site storage, it was determined that a two-stage approach
would  not  work. Instead, the owner was faced with making a
choice between two options concerning the logistics of remedia-
tion. The first, and more traditional, option involved writing a
feasibility  study  for  total  site remediation,  followed  by
                                                                                        RCRA AMENDMENT EXPERIENCE    351

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 IDWAWM review and approval of the recommended alternative.
 If a Part  B permit was required before site cleanup  could be-
 gin, the permit application would then be prepared, followed by
 U.S. EPA review and approval. The problem with  this option is
 that it would take a minimum of 1 year to receive a Part B permit
 after the U.S.  EPA received the application. All parties involved
 (owner, ISWAWM and U.S.  EPA)  thought that this option
 would unnecessarily delay site cleanup and  a second option was
 considered.
   The second  option involved a more innovative approach to re-
 mediation. This  option involved first preparing a Part B permit
 application under the assumption that the on-site storage  alterna-
 tive ultimately would  be the approved alternative for source
 cleanup. In conjunction with the U.S.  EPA review  of the permit
 application, a  feasibility study for total site remediation would be
 prepared,  followed by IDAWAWM  review and approval. Copies
 of the Part  B  permit application and feasibility study  would be
 shared  by  both regulatory agencies  so  that a  coordinated
 approach  to site cleanup would result.  The major  risk involved
 with this option  would be that if on-site storage was not  the ap-
 proved  alternative, the  expense of  preparing a Part  B permit
 application would be wasted.
   The owner chose to pursue the second, more innovative, op-
 tion to  site  remediation. At  the present time, a Part  B permit
 application for the on-site bunker silos is being reviewed by the
 U.S. EPA. A  feasibility study is being written concurrently and
 will be reviewed  by IDWAWM. Because the owner and  regula-
 tory agencies discussed the options at an early stage, the  risk in-
 volved in  pursuing the innovative approach is considered mini-
 mal. The result of this action likely will be a faster cleanup of an
 NPL site (savings of time of at least 1 year) than if the traditional
 approach was pursued.
CONCLUSIONS
  The proposed remediation of an uncontrolled waste disposal
site in rural Iowa is being implemented using an innovative altern-
ative for storage of wastes and an innovative approach to  the
regulatory review process. Conclusions made from the work per-
formed to date are:
• Off-site storage  of  exhumed solid wastes in  above-ground
  bunker silos is an attractive and innovative alternative com-
  pared to simply transporting and disposing the wastes in a dis-
  tant  landfill. The owner of the wastes is  better able to control
  his liability with an on-site facility, and the wastes can be stored
  safely while subsequent testing is conducted to  determine the
  most effective and least costly ultimate treatment  alternative.
• Although  the above-ground silos  are  designed  to effectively
  contain the waste, the owner likely will implement  a double
  synthetic liner system to give added protection.
• An innovative approach to the regulatory process is being im-
  plemented whereby a Part B permit application for the storage
  facility is being submitted prior to the submission of a feasibil-
  ity study addressing site remediation. This approach likely will
  result in a  more expedienl cleanup  of the site relative to a tra-
  ditional approach.
• Innovative approaches to the regulatory process are more like-
  ly to be successful if all  parties  involved in the  process (e.g.,
  owner, regulatory agency) can effectively communicate, coop-
  erate and keep an open mind. This is especially important when
  more than one regulatory agency  is involved.
352    RCRA AMENDMENT EXPERIENCE

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                                    Overview  of  the  Proposed
              Natural Resource Damage  Assessment Regulations
                                                Richard J.  Aiken*
                                            Willie R. Taylor, Ph.D.*
                                        U.S. Department of the Interior
                                          CERCLA 301  Project Team
                                                Washington, D.C.
 ABSTRACT
  This paper describes and explains the natural resource dam-
 age assessment regulations issued in proposed form in December
 1985. These regulations were developed by the U.S. Department
 of the Interior under the authority of section 301 (c) of CERCLA.
 The regulations are to be used for assessing  damages to natural
 resources which result from a release of a hazardous substance or
 oil. Claims for such damages can be presented to a responsible
 party under the liability provisions of CERCLA, section 311(f)(4)
 and (5) of the Clean Water Act or the Superfund. Some examples
 of the resources involved include groundwater,  surface water,
 park and recreation areas, wetlands,  wildlife habitat, fish and
 wildlife, air and soil. They are applicable to all Federal and State
 agencies that manage natural resources including, among others,
 the U.S. Department of Defense, State  fish  and game agencies,
 the U.S. Department of Energy and State park authorities.

 INTRODUCTION
  CERCLA and the Clean Water Act are the major federal
 authorities for responding to releases of hazardous substances
 and oil. Although the response authorities and the funding mech-
 anism for these responses constitute the focus for most discus-
 sions of these laws, this paper focuses on the issues embodied in
 the second half of CERCLA's title: compensation and liability.
 Specifically, the paper deals with the liability of the parties re-
 sponsible for  the release for resulting  damages to  natural re-
 sources and the appropriate measurement of the compensation.
 These issues form the nucleus of the proposed natural resource
 damage assessment regulations required by section 301(c) of
 CERCLA and promulgated by the  U.S. Department of the In-
 terior in December 1985.
  Although promulgated by the Department  of Interior, the sec-
 tion 301(c) natural  resource  damage assessment regulations are
 written for the use of all Federal and State agencies which claim
 trusteeship for natural resources  under CERCLA. CERCLA
 broadly defines natural resources to include  all elements of the
 environment, including such living resources as fish, wildlife and
 other  biota and such physical resources as  land, air, drinking
 water and groundwater. Examples of agencies that may make use
 of the regulations include park authorities, fish and wildlife agen-
 cies, and land and water management  agencies.  A rebuttable
 presumption is a legal mechanism which effectively gives  the
 claimant an advantage in any administrative or litigative actions.
 The use of these rules in some instances will provide a rebuttable
 presumption for the assessment.

'This paper represents the views of the authors and  not those of the U.S. Depart-
ment of the Interior.
  Section 301 (c) requires that two types of regulations be devel-
oped; the so-called type A and type B regulations. The type A
regulations are to  be standard procedures for simplified assess-
ments involving minimal field work. The type B procedures are
to include alternative protocols for the assessment of damages On
a case-by-case basis. This paper provides an overview of the en-
tire damage assessment process and focuses on the type B assess-
ment procedures. It does not address the type A procedures.

DAMAGES ARE THE RESIDUAL OF
RESPONSE ACTIONS
  Section 107(a) of CERCLA outlines  the liability of respon-
sible parties for CERCLA-covered releases to include:
• The costs  of removal and remedial  action  incurred by the
  United States Government or a State that are  not inconsis-
  tent with the National Contingency Plan
• Any other necessary costs of response incurred  by any other
  person consistent with the National Contingency Plan
• Damages  for injury to, destruction of, or loss of natural re-
  sources, including  the reasonable costs  of assessing such in-
  jury, destruction or loss resulting from such a release
  Liability under CERCLA can be  summarized to removal, re-
medial actions (jointly referred to as response actions) and dam-
ages (hereafter referred to as "damages"). Liability for the  first
two components  has  long  been  an established  part  of the
CERCLA program. However, liability for damages only recently
has been raised as a concern. A major reason for this situation is
the lack of a consistent understanding throughout all levels of
government, industry and the general public as to what consti-
tutes damages. CERCLA's definition of damages provides little
guidance. Section 101(16) of CERCLA simply states that damages
"means  damages for injury or loss of natural resources..."
  The first boundary on the  term "damages" is provided by the
method in which CERCLA establishes the liability. Section 107(a)
discusses the three elements  of liability (costs by the Federal or
State government,  costs by any other party and damages) as sep-
arate and distinguishable components. Therefore, damages are
those injuries or losses of natural resources that are not covered
by the first two components. In other words, damages are those
residual  impacts that remain after factoring in the effects of the
removal and remedial actions.
  The remainder of this paper looks more closely at the issue of
what constitutes damages. In so doing, the paper discusses what
constitutes "injury to, destruction  of, or loss of natural re-
sources," how these injuries should be measured and finally, the
process  of natural resource damage assessment proposed in the
Department of the Interior's regulations.
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WHAT ARE DAMAGES?
  CERCLA requires that damages be determined for the injury,
destruction or loss of a natural resource due to the release of a
hazardous substance or oil. For simplicity, the terms  "injury,"
"destruction," or "loss" all can be referred to generically  as in-
jury since they refer to degrees of injury. In common law, at least
two major categories of damages are recognized: punitive  dam-
ages and compensatory damages.  To determine which  type  of
damage applies to CERCLA cases, both the statute and its legis-
lative history need to be examined.
  That CERCLA requires compensatory, rather than punitive,
damages is clear  from its  language. Section 301(c)  of  CERCLA
requires that an assessment of damages be performed using the
"best  available procedures." Use of best available procedures
would not  be required if damages were to be punitive.  If Con-
gress had meant damages under CERCLA  to be punitive, all that
would be needed is a penalty  table. This penalty table  could
have been but was not included in the legislation.
  The legislative history  of  CERCLA  also  demonstrates that
punitive damages were  not intended. For example, the Senate
Committee on Environment  and Public Works stated that the
type B regulations should  contain "methodologies for  determin-
ing value [for injury to natural resources due to a release of a
hazardous substance or oil]..." This determination of value,  as
discussed below,  is a critical part of determining compensatory,
not punitive, damages.
  Damages are thus  the compensation for an injury to a natural
resource. Liability for this compensation is to the agency acting
as trustee of the  injured natural resource. As compensation for
the injury resulting from the release, the agency is entitled  to be
made  "whole," at least in monetary terms. That is, the agency
should be made approximately as well off as it was prior to the
release.

HOW ARE DAMAGES MEASURED?
  Economics, common law and CERCLA  agree that when meas-
uring damages, making  the agency "whole" should be achieved
in a cost-effective manner. This requirement gives the agency the
lessor  of: (1) the costs of restoration, rehabilitation,  replace-
ment or acquisition  of an equivalent to the injured natural re-
source (restoration for short); or (2) the amount of lost use values
resulting from the release.
  That is, if use values are higher than the  costs of restoration, it
would be rational to restore  the injured natural resource  to its
former condition. In this case, society regains its lost uses  for a
cost that is less than the value of those  lost uses. Conversely, if
restoration costs  are higher  than  the  value  of lost  uses,  it is
rational to compensate society by giving  it  the value of those lost
uses. In the latter case, society receives the value of  the lost uses,
which  is less  than the costs of restoration  of the resource which
would regain those lost uses.
  Federal and State agencies should be required to decide whether
restoration or use values will form the basis of further work  to
determine damages.  This decision  should  be made early in the
assessment process. "Off-the-shelf" information should  be used
to make this decision. Past studies on restoration techniques and
valuation estimates should be used to obtain an "order  of magni-
tude"  estimate of restoration costs and  use values.  These rough
estimates are a surrogate  for the site-specific determination  of
either restoration  costs or the loss of use  values that will be  made
later in the damage assessment process. The sole purpose of this
early estimate is  to determine whether  restoration  costs or use
values will form the basis for further analyses.
  One major reason  for requiring  the decision between  restora-
tion and use values relatively early in the assessment  process is
that it helps focus the assessment process on the determination of
damages rather than on general research. This agreement can be
achieved by an early meeting of the entire group of specialists that
will perform the assessment. In  most instances, these personnel
will have different areas of specialization. These individuals must
work together if reasonable costs, as discussed later in this paper,
are to be achieved. If these individuals do not get together early
in the assessment process, there is a possibility that either the
information collected in the measurement of injury will not be
useful in determining damages, or that the demands for informa-
tion to  determine damages  will  be unrealistic. These problems
have been acute in several previous damage assessments.
  Congress and State  legislatures have determined that certain
natural resources are worthy of protection, even if their use values
are relatively low. In effect, these legislative bodies have removed
these special resources  from the ordinary  workings of economics
and common law. If agencies were held to a strict rule of the
lessor of a loss  of use values or restoration costs, some  of  these
special resources might be left unrestored which would be con-
trary to Congress' or the State legislature's intent. Therefore, it
would be rational to assume that when a special resource  is in-
jured due to a release,  restoration costs would be the measure of
damages.  However, even in these cases, the costs of restoration
should not be grossly disproportionate to the benefits of restora-
tion.
  To determine restoration costs, the Federal or State agency
must determine the services lost due to the release. Natural re-
sources  provide services to other resources and also to people.
When people are the ultimate recipient of the service, the  serv-
ice  is called a use. Restoration costs are the costs of restoring
the lost services previously provided by  the injured natural re-
source. For example, a lake can serve as a  habitat for a fish popu-
lation.  If a hazardous substance is  released into  the lake, the
water may be contaminated to a point where the lake is no longer
habitable  for the fish.  In this  instance, the services provided by
the lake have been lost to the fish population. Restoration would
entail  the restoration of the lake as a suitable habitat for a fish
population. In this example, replacement of the fish population
should not be attempted if the habitat would not be restored to
support the fish population. However, damages based on restora-
tion are limited to the amounts required to return the resource to
its baseline condition. The costs  of enhancement of the resource
beyond  its baseline condition  should not be included in deter-
mining compensation for an injury.  In the above example, this
would imply that the lake be restored to a suitable habitat for the
species of fish that existed in the body of water prior to the re-
lease, not to a species that an agency would like to introduce.
  The  restoration  of  services, not simply  the  replacement of
organisms, is paramount in determining the costs of restoration.
This concept was affirmed in  the decision reached in the Com-
mon wealth of Puerto  Rico v. The SS Zoe Colocotroni, 628 F.
2d 652, 673 (1st Cir. 1980) where  the cost of replacement was held
not to be a measure of damage if the replacement is not  contem-
plated.
  In determining damages based on restoration costs, the loss of
use values, over the time required for restoration to be completed,
would also be compensable  to the agency. This compensation is
owed because society suffers a real loss by not being able to utilize
the resource at its fullest potential during the period of time re-
quired for its restoration.
  In addition to defining restoration in terms of services, agencies
must consider the ability of the resource to recover naturally. Sec-
tion 301(c)(2) of CERCLA requires that  the "ability of the eco-
system or resource to  recover" be factored into the determina-
tion of  damages. The  time required for  the resource to recover
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naturally will provide the period during which a loss of use will be
experienced  if no restoration actions are performed. Thus, the
natural ability of the aforementioned lake to recover must be in-
cluded in determining restoration costs.
  Uses, as stated above, refer to the human use of services pro-
vided by natural resources. In the example, fishing may have been
a use of the lake. If so, the loss of fishing  could be an alterna-
tive to restoration  costs in determining damages.  Common law
and economics dictate that an ordering of methodologies be used
to value injuries to natural resources under CERCLA. This order-
ing would start with the change in market prices when applic-
able.  Second, if market prices are not applicable, appraisals
should be used. Third, if neither prices nor appraisals are applic-
able, certain types of non-market methodologies should be used.
The  logic for this ordering is that  if a market or a  comparable
market  exists for the  injured natural resource, the information
from these markets always should be used to  value the resource.
  If neither the market price nor appraisal methodology is appro-
priate, a non-market methodology that measures  either willing-
ness to pay or willingness  to  accept compensation would be
appropriate. Willingness to pay and willingness to accept com-
pensation are the fundamental concepts which underlie the com-
pensation principle in economics. As such,  any methodology to
determine compensation must be  consistent with one  of these
concepts.
  A paramount concern in determining damages  is  the type of
values for which the agency may be compensated. CERCLA pro-
vides that a Federal or State agency is acting as a trustee when
seeking to recover  for an  injury to a natural resource  resulting
from a release. As such, the agency can collect only losses to the
public at large because of the release. These include:  (1) losses in
recreation or other public uses;  (2) losses in fees and other pay-
ments made to the public for the private use  of the public's re-
source; and (3) economic rent lost due to the  release.
  The third type of loss may need additional explanation.  Eco-
nomic rent is the excess  of the total earnings of a producer  of a
good or service over the payment required to induce that producer
to supply the same quantity currently being supplied.  This  eco-
nomic rent usually exists because the agency  does not  charge a
price or fee for the private use of the  public's resource. These
amounts are compensable to the agency as  the use value of the
resource in place, i.e., the value of the natural resource in the
production of marketed goods  when the government does not
charge a fee or price for the use of its resource.
  Two categories of revenues associated with the  private use of
the public's resource  should be excluded in  the calculation of
damages. First, losses in tax revenue should not be  included in
damages. Taxes are transfers of income from individuals to the
government. As such, taxes are  not considered "real" damages.
Second, wages and other income lost by private individuals, with
the exception of economic rent, should not be compensable to the
agency. This income does not accrue to the  agency or the public
at large and may be subject to privately brought non-CERCLA
law suits.
  To determine damages,  the  existing and planned uses  (and
services) of  the injured natural resource must be determined.
The  determination of damages  is dependent  upon the uses (or
services) forgone because of the release. The basis for determin-
ing damages should be the committed use of the resource prior
to the release. Committed use would mean that a current or plan-
ned use has  been documented through a financial, legal, budge-
tary or other similar type of commitment made by the agency or
some other individual or body with the authority to  commit the
use of the resource. That agencies must be able to document cur-
rent  and prospective uses follows  from the need to determine
compensatory damages. To determine compensatory damages,
purely speculative uses of the injured natural resource cannot be
allowed.

WHAT CONSTITUTES AN INJURY
TO A NATURAL RESOURCE?
  To this point, the discussion has focused on methods for cal-
culating compensation for damages to natural resources. How-
ever, damages are for injury to a natural resource. Therefore, to
calculate a damage, an injury first must be established.
  The first step in identifying what constitutes  an injury is to
provide a general definition  of the term. This definition should
develop from  the purposes to which the definition will be put.
The purpose to which this concept of injury will be put is to pro-
vide justification for a compensation. Since the level of compen-
sation will be tied to the level of injury, the first element that must
be included in the concept of injury is measurability. Compen-
sation obviously implies a loss or some reduction. Therefore, the
second element of this definition, this reduction, can be viewed
as a decrease  in those basic characteristics that constitute the
quality of that resource. Finally, in the discussion of the liability,
CERCLA states that the injury must have resulted from the re-
lease. Therefore, injury can  be viewed as a measurable adverse
change in the  physical, chemical or biological characteristics of
the resource which resulted from the release.
  To this definition should be added CERCLA's guidance that
requires the inclusion of long-term and short-term as well as direct
and indirect injuries.  In addition, the term "resulting from the
release"  would have to include products of the substances  re-
leased and reactions caused by such products or substances.
  This general definition needs to be translated into specific re-
source definitions for applicability. As stated earlier, CERCLA
covers a wide  range of natural resources. These  resources need
to be grouped into some manageable number that  still provides
meaningful guidance.
  The emphasis on physical, chemical and biological characteris-
tics in the general definition suggests distinguishing between
physical and biological resources.  Although biological resources
can be considered as one group of resources,  physical resources
are more easily discussed as  either air, groundwater,  surface
water or geologic resources. All of these resource groups include
a wide range of resources. However, the type of guidance that
can be provided in such a general set of regulations suggests that
these five groups of resources are adequate.
  The physical, chemical or biological characteristics of concern
in an injury  definition would be those characteristics that relate
to the quality of the resource relative to the services that it is ex-
pected to provide. The concept of services as explained earlier
includes such services  to people and the environment as drinking
water supplies, habitat and growth medium for vegetation. The
most obvious services that can be considered include those link-
ages that exist between resources that may cause exposure  and
injury to other resources. In the earlier example, a body of water
may have been contaminated  such that the fish within that body
of water die. Obviously, the fish are injured, but the  water can
be considered injured as well since it no longer serves as a healthy
environment for the  resources that depended upon it. Similar
linkages  exist  among  all of the resource groups.  These linkages
are easier to identify in some resources than in others.  However,
in no cases should the linkages between the  resource groups con-
stitute the only method of identifying an injury.
  Several of the resource groups include Federal  and State stan-
dards which can be viewed as defining a characteristic of quality
for the resource. The clearest sample of such standards are the
water quality  criteria developed  under the Clean Water Act.
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These standards were developed with a view toward the services
that the water provided. Frequently, these standards were focused
on  the  potential affects on aquatic life.  Similar  quality stan-
dards or threshold  levels exist  for drinking water  and air. For
geologic and biological resources, equivalent standards have had
to be developed.
  Geologic resources include such  elements of the  Earth's crust
as soils, rocks and minerals. The major services provided by geo-
logic resources  include providing a medium for growth of vege-
tation, a habitat for biota (soils), a source of minerals for devel-
opment purposes and the unsaturated zone for aquifers.  After
a release, geologic resources also may qualify as hazardous sub-
stances under the provisions of RCRA. The physical,  chemical
and biological characteristics of geologic resources that affect the
quality of the  resource to provide such services (i.e.,  respira-
tion, pH or microbial populations) can be defined and used as
an easily identified standard to judge if the resource has been in-
jured.
  The primary  service of concern in biological resources is con-
tinuation of the species or  population viability. However, for a
small but important  subset of biological  resources (those that
are consumed)  a resource should be considered injured if con-
centrations of the substance released within the edible portions of
the resource  exceed applicable  Food and  Drug Administration
(FDA) action or tolerance levels  or equivalent State standards.
  Examples of  injuries that affect population viability are death,
disease,  behavioral  abnormalities,  cancer,  genetic mutations,
physiological malfunctions and physical deformations. Unfortun-
ately, determining whether or not one of these injuries has occur-
red as a result  of the released substance is difficult. Studies on
the toxicity of  chemicals on  various non-human biological re-
sources are not widespread and frequently are not universally
accepted. Examples abound of results appearing in  laboratory
situations that  cannot be  replicated  in field studies and vice
versa. However, if the use of the procedure is to provide a rebut-
table presumption to the assessment, it is critical to include only
those responses that are caused by the substance released. If a
procedure cannot prove that a particular chemical  caused an
effect,  the procedure  should not  be used in any litigative  or
administrative action. Therefore, the specific definition of injury
to a biological  resource is necessarily tied  heavily to the testing
procedure for the biological response.
  This  last point highlights a dilemma inherent in CERCLA's
damage assessment requirement. CERCLA requires that the regu-
lations include  the  best available procedures for assessment  of
damages.  Clearly, it  is not advisable to  hinder research  into
natural resource injuries caused  by chemical releases by requiring
the use of the few techniques currently available, given the  state-
of-the-art of assessment techniques. In addition, it is not feasible
to include every testing procedure that has ever been attempted
in a set of regulations that  is general in nature. The solution to
this problem is to provide criteria by which the techniques can be
judged rather than specific techniques. Such criteria would neces-
sarily center on  the general acceptability of the procedure and the
replicability of the results.
  Identifying that a resource has suffered an injury is insufficient
for the  purposes of establishing a  damage  claim. CERCLA re-
quires that some linkage between the source of the release and the
injured resource be established. This process requires the identifi-
cation of a potential pathway through which the substance  could
have traveled. Each of the resource groups has  the capability of
acting as a component in this pathway.
Substances may  be transported through  direct exposure,  the
food chain or via one of the air or water mechanisms. Model-
ing  or sampling would be appropriate means of determining the
pathway.
   In  summary,  injury  for the  purposes  of  liability  under
CERCLA  can be viewed  generally as a measureable, adverse
change in the physical, chemical or biological characteristics of
a  resource that resulted  from a release. This general definition
can be applied to specific groupings of resources so that clearly
recognizable affects can  be attributed to the substance released.
Once identified as injured, these resources can be measured, and
the extent of the impacts can be calculated.

HOW IS INJURY MEASURED?
   The measurement of injury is the link between the physical and
biological demonstration of injury and  the monetary determina-
tion  of damages. Injury determination demonstrates that either:
(1) a  physical or  chemical  based standard has been  violated;  or
(2) an adverse biological response is the result of a release. This
injury determination  must then be measured  to calculate how
much of the resource has been injured, how badly the resource
has been injured and over what time period the injury has taken
place. This process is the quantification of the injury.
   One major task in the quantification of the injury is to deter-
mine  the changes in services previously provided by the injured
resource. To quantify the effects of the release, the agency must
determine baseline services; the amount, type and quality of serv-
ices that would have been supplied by the injured natural  re-
source in  the absence of the release. This amount is then com-
pared to the amount, type and quality of services supplied by the
injured natural resource.  The difference between these two quan-
tities  is the reduction in  services  that an agency can use as the
basis  for either restoration  costs or use values when determining
damages.  Since damages are the residual after any response ac-
tions, the quantification of the injury must incorporate the effects
of any actual or anticipated response actions on the current and
future services of the resource.
   Quantification  extends to baseline,  rather than standards or
conditions causing the biological responses,  and is a direct con-
sequence  of  providing  compensation  to   make  the agency
"whole." Because baseline is  the  point from which compensa-
tion  is determined, the agency is being compensated  for what
would have occurred had the release not occurred.
   As mentioned  earlier, any quantification of injury must in-
corporate the ability of the resource to recover naturally. In addi-
tion, recovery rates of the resource with alternative management
actions  need to be specified. This calculation allows specifica-
tion  of alternative costs of restoration which, in turn, allows
selection of the most  cost-effective alternative to restore the re-
source.

THE NATURAL RESOURCE DAMAGE
ASSESSMENT PROCESS
   The concepts of damage and  injury are important for the
understanding of the  proposed natural  resource damage assess-
ment  process. However, there are three additional important
concepts that surface  throughout the proposed natural resource
damage assessment process. These concepts,  discussed briefly be-
low, include:

•  Cost-effectiveness and reasonable costs as  they apply to the
   assessment process
•  The involvement of the public and the potentially responsible
   party in the damage assessment process
•  The application of any awards for restoration purposes

Cost-Effecllveness/Reasonable Costs
   CERCLA requires  that natural  resource damage assessments
achieve reasonable costs.  CERCLA's legislative history also indi-
cates that these assessments be cost-effective.  Cost-effectiveness
is  the achievement of an objective with the  least expenditure of
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financial or other resources. Agencies should use cost-effective-
ness  in  determining  how  they  will perform  all aspects of the
assessment process. To achieve this requirement, agencies must
have well-defined goals. For example, testing and sampling for
injury to surface water should be limited to those tests which can
determine the injury  as opposed to any general research studies.
Given local conditions, the agency should select, from the set of
tests that could show injury, the one which is the least costly.
  Section 107(a)(4)(C) of CERCLA stated that a responsible
party is liable for the "reasonable costs of assessing..."  injury
as well  as the amount of damages determined in the damage
assessment. The concept of reasonable costs incorporates the con-
cept of cost-effectiveness, but is broader in scope.  Reasonable
cost  criteria require  that the benefits of alternative testing or
estimation procedures outweigh their costs.
  In addition, reasonable cost criteria require that the parts of an
assessment plan be coordinated  and supply only the information
necessary to move from  one section to another. This require-
ment exists because the sole purpose of a damage assessment is
to determine the damages caused by a release.

Involvement of the Public and
Potentially Responsible Party
  As indicated by the previous discussion,  a damage assess-
ment requires a significant number of choices. The performance
of a damage assessment requires the selection of methodologies
to:  (1) test and  sample for injury; (2)  determine the pathway
which exposed the resource to the release; (3) measure of the ex-
tent of injury; and (4) determine a dollar amount due the agency
as compensation for the injury.  Given the universe of methodol-
ogies that exists, the selection of appropriate methodologies to
perform all of these tasks is difficult.
  The  amount of discretion available argues for the use of an
administrative process in the damage assessment. Administrative
processes are characterized by their openness and ability to gain
the views of all interested individuals. The outcome of such a pro-
cess generally is perceived to be fair because all parties have an
opportunity  to review and comment on the process. This per-
ception of fairness is an important issue in the performance of a
damage assessment. If the courts do not perceive the assessment
process as being an impartial assessment of damages, the likeli-
hood that the results of the assessment will  be successfully chal-
lenged in court increases. This increases costs for all involved.
  Any  administrative process to determine damages must give
final authority to the agency performing the assessment for the
selection of methodologies. Input from the public and potentially
responsible parties should be useful in selecting methodologies
for and actual performance of damage assessments. In addition,
there may be instances when the potentially responsible party may
wish to perform the damage assessment. However, the agency
generally will have the management authority for the resources
in question and must have the  final  authority to determine  all
aspects of the assessment  process as an extension of its manage-
ment responsibilities.

The Application of Any Awards for
Restoration Purposes
  One final concept that  needs  to be highlighted in the process
is the requirement in CERCLA that all  funds received as  com-
pensation for the natural resource injuries be made available for
restoration. This concern for the disposition of the awards was
taken very seriously in the development of the proposed rule and
is considered critical for  the general credibility of the damage
claim. In the Zoe Colocotroni case, one reason that the courts
disallowed the initial claim was the determination that the gov-
ernment had no intention to restore the resources, and the re-
placement of resources formed  the basis of the claim. There-
fore, the commitment to restoration should strengthen the accep-
tability of the damage claim.
  Obviously, restoration is not always feasible. In those instances
when restoration is not feasible, the acquisition of resources pro-
viding services similar to those lost is a viable alternative.

PROPOSED NATURAL RESOURCE
DAMAGE ASSESSMENT PROCESS
  The natural resource damage assessment process proposed by
the Department of the Interior is  designed to be performed in
phases. The more costly phases occur after several screens have
been passed to ensure that assessments  are not performed need-
lessly. The major steps in the  process are provided on Table 1.
The remainder  of this paper will briefly describe each of these
steps.
Initiation of Process
  Natural resource damage assessments should be a follow-on to
any removal or  remedial  actions taken by the U.S. EPA,  the
U.S. Coast  Guard or any other agency designated as  the lead
agency under the National Contingency Plan. That plan requires
that the lead agency notify trustees of any potential natural re-
source injuries. In instances where  the agency identifies a pos-
sible injury  to resources under  its  jurisdiction and suspects a
CERCLA or CWA covered source,  the agency is directed to  the
procedures in the National Contingency Plan for reporting  the
release. Regardless of how the agency was  notified, once alerted
to the potential injury, the agency should determine whether any
emergency restoration actions are necessary.

Emergency Restorations
  Section lll(i)  of CERCLA provides authority for emergency
restorations. Emergency restoration actions are those limited ac-
tions necessary to abate a  continuing threat to or the immediate
destruction  of the resource. The agency should notify the Na-
tional Response  Center of the need  for emergency action. If the
U.S. EPA or the U.S. Coast Guard cannot take the necessary
actions, the agency may use whatever authorities it has to pre-
vent the  transport of the substance to the  resource. Upon com-
pletion of the limited actions, the agency would start the natural
resource damage assessment process.

Pre-Assessment Screen
  The first  step  in the assessment process is the pre-assessment
screen. The purpose of this screen  is to determine whether  the
release justifies a natural resource damage assessment. This screen
is viewed as a "desk  top"  review of existing data, capable of be-
ing completed in a matter  of days. It should not duplicate or re-
peat information gathered by the agency or by other parties as
part of the response action.
  A documented determination is required upon completion of
this screen. The  determination to proceed will be based upon en-
suring that:
• The release was covered by CERCLA or the CWA
• It  might have  resulted in some injury to a resource under the
  jurisdiction of the agency
• The resource and the extent of potential injury was of sufficient
  concern to the agency to continue
  If,  as a result of the pre-assessment screen, the agency deter-
mines that a natural resource damage assessment is in order, the
agency will initiate the Assessment Plan phase.
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                             Table 1
             Natural Resource Damage Assessment Process
PREASSESSMENT PHASE


Initiation of process
Decision on whether
 emergency exists
Determination of
 whether to proceed
 with a damage assessment
ASSESSMENT PLAN PHASE


Planning for the assessment


Decision on A or B
                                    Injury to Resource
                                    Suspected CERCLA or
                                    CWA Source
                        Notification	|
                            Not
                          Confirmed
                          End
Confirm presence in
 resource (Type B only)
Restoration costs or use
 value (Type B only)

TYPE B ASSESSMENT
Determine whether an injury
 has occurred that is linked
 to CERCLA Of CWA release
Review of planned methodologies,
 especially Economic Methodology
 Deteonination/ in light of results
 of Injury Determination Phase
                               Assessment Plan
                                   Phase
                               Type A or Type B


                            Confirmation of Exposure
                                     Economic Methodology
                                        Determination
                                                            Type A
                                        Type
                                         B
                                        Injury Determination
                                             Phase
                                     Review
                                 Assessment Plan
                      CERCLA or CWA Injury
                      Not Confirmed	
                    End

Quantification of effects
 of release
 -Identification of  service';
 -Baseline
 -Recovery time and  ability
Estimate of loss of value
 or restoration or replacement
 costs
PO6T-ASSESSMENT PHASE

Documentation of results of the
 assessment

Establishment of trust fund and
 development of Restoration Plan
                                  Quantification
                                     Phaae
                                Damage Determination
                                    Phase
                                Report, of Assessment |
                             I     Post-Assessment    |
Assessment Plan Phase
  The agency should document its decisions on the selection of
the methodologies that will be performed.  This documentation
must  be given in an Assessment Plan. This  Assessment  Plan
should ensure that the mandate to keep assessment costs reason-
able will be fulfilled.
  There are several  efforts that  need to be undertaken  by the
agency  prior to developing the Assessment Plan. These  efforts
center on  initiating the  involvement of multiple trustees,  poten-
tially responsible parties and the public in the assessment.
  The potentially responsible party or  parties  should be  identi-
fied. A Notice of Intent to Perform an Assessment must be sent
to any identified potentially responsible party (PRP). This notice
is intended to involve the PRP early in the assessment in an at-
tempt  to  minimize  disagreements in the performance  of the
assessment. However, all decisions concerning the assessment are
ultimately the responsibility of the lead official.
  The public is encouraged to become involved  in the Assessment
Plan.  The  public participation element of the  Assessment  Plan
includes a 30-day review period prior to implementation  of the
plan or major modifications. Any comments and responses must
be maintained as part of the administrative record.

  There are  several requirements  specific  to  a  type B  assess-
ment  that  must be included in the  Assessment Plan. These re-
quirements include:
• Confirmation of exposure
• Quality Assurance Plan
• Objectives of testing and sampling for injury or pathways
• Economic Methodology Determination

  The confirmation  of exposure is the second screen in the dam-
age assessment process. It is intended to ensure prior to initiating
an expensive type B assessment that the released  substance has
actually come  into contact with the resource of concern. The
Quality Assurance Plan should  be prepared following the same
requirements that apply to other actions taken under CERCLA.
The testing and sampling objectives should clearly state the pur-
poses of all proposed testing and sampling.
  The Economic  Methodology Determination is where the agency
must  make a  choice between using the costs of either restoring
or replacing the injured resource of the value of lost uses as the
measure of damages.  The  decision will  affect the choice  of
methodologies to be selected in the second phase of the assess-
ment, referred to as  the Quantification phase, and to a lesser ex-
tent in  the first phase, referred to as the  Injury Determination
phase. Therefore, the decision must be made early, but may be
deferred or changed  after the Injury Determination phase is com-
pleted.
   The selection of use value or restoration costs only affects the
method of damage determination. It does not imply any decisions
concerning whether  the resources will be restored.  Except in the
case of defined special resources, the method of determining the
damage will be the lesser of the lost use value or restoration costs.

Type B Assessment
   Performing a damage assessment by using a type B procedure
involves three general steps:
•  Establishing that an injury has occurred and  that the injury re-
   sulted from the release
•  Quantifying the effects of the release on the injured resource
•  Determining the damage
 358
RCRA AMENDMENT EXPERIENCE

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Injury Determination Phase
  This phase of the type B assessment acts as the third screen of
the natural resource damage assessment. To assert a natural re-
source damage claim, the agency would have to establish that an
injury occurred or to link that injury to the release. The Injury
Determination phase is where the agency must determine whether
one of the specific definitions  of injury for the five resource
groups has been met. Acceptance criteria for determining when a
procedure meets the requirements for the rebuttable presumption
are provided to assist the agency in making this determination.
Finally, it is in this phase that the agency must determine the path-
way that the substance  could have traveled to reach the  injured
resource.

Review of the Assessment Plan
  Upon  completion  of  the Injury Determination phase,  the
agency will review  the methodologies selected in the Assessment
Plan. The purpose  of this review is to ensure that the selection of
methodologies for  the last two phases of the type B assessment
is compatible with the findings  of that first phase. If an injury
cannot be determined or  cannot be linked to the release, the re-
sults of the  Injury Determination phase should be documented
and any further assessment efforts included in the plan should be
deleted.
  If it is determined that the injury resulted from the release, the
agency will ensure that the methodologies selected for the next
two phases are consistent with the findings of the Injury Determi-
nation. At this stage, if the agency has not previously done so, a
decision must be made on whether use value or restoration or re-
placement costs will  form the basis of the damage determina-
tion.

Quantification
  Having established that a resource was injured by the  release,
the second step in the type B assessment is to quantify the effects
on the injured resource. As the purpose of the natural resource
damage assessment is compensation rather than a decision on the
cleanup level, this phase requires ascertaining the  baseline level
for the resource. The baseline level is compared  to the level pro-
jected upon  the completion of any response actions to determine
the residual change resulting from the release. The baseline level
will include consideration  of  the resource's   natural  cyclical
changes.

Damage Determination Phase
  The outputs of the second step should act as inputs to the third
general step in the type B process, estimating the damage. The
method of estimating the damage, either using the cost of restora-
tion or replacement or the loss of use, was determined earlier dur-
ing the development of the Assessment Plan.
  If restoration or replacement is  to be the measure, a plan for
the restoration or  replacement, referred  to as  the Restoration
Methodology Plan, must be developed in  this  Damage Deter-
mination phase. This plan must have sufficient  detail to ensure
that all major elements of costs are included and that these costs
represent the cost-efficient means  of restoring or replacing the
services lost  as a result of the release. This plan also will serve as
the foundation for the final restoration plan that must be devel-
oped after the award.
Report of Assessment
  In some instances, damage assessments using this natural re-
source damage assessment process will receive a rebuttable pre-
sumption. To assert this rebuttable presumption, at the conclu-
sion of a type B assessment, the agency must document the results
of the major steps of the  process in  a report referred to as the
Report of Assessment. These major steps include the Pre-Assess-
ment  Screen Determination, the Assessment Plan with all com-
ments and responses, the Injury Determination, the Quantifica-
tion Determination and the Damage Determination, including the
Restoration Methodology Plan if prepared.

Post-Assessment
  Based upon CERCLA's  mandates,  funds recovered as a result
of the assessment process provided in the proposed rules must be
available for restoration, rehabilitation, replacement or the acqui-
sition of the equivalent of the injured resource. To accomplish
this mandate, a trust fund must be established to hold all awards
except those amounts which represent reimbursement of costs in-
cluding  assessment, administrative and litigative costs.  These re-
imbursements may be returned to the general treasury of the gov-
ernmental unit that incurred the costs. The agency shall prepare
a Restoration Plan. This plan shall be based upon the decisions
made in the Restoration Methodology Plan, if one has  been pre-
pared; the  plan shall be  modified to the extent necessary to
accommodate new information before calculating the amount of
the award. The trust fund  will be used to pay for the implemen-
tation of this Restoration Plan.
  In recognition of the fact that restoration of some injured re-
sources  is technically infeasible,  replacement and acquisition of
the equivalent are defined to include acquisition of resources that
provide similar services to the injured resource. However, there is
a limitation on the use of the fund. Where acquisition of similar
resources would involve purchase of  land  for federal manage-
ment, the award must be paid to the general treasury. The appro-
priations process must be  used  where land is being acquired to
expand the total federal landholdings.

CONCLUSIONS
  CERCLA and the  Clean Water Act authorize liability for re-
sponse actions and damages to natural resources caused by re-
leases of hazardous substances and oil. This paper has  examined
the extent of the liability of parties responsible for the release and
resulting damage to natural resources and the proposed  process
through which these damages can be calculated.
  The proposed process is driven by  two  basic premises:  dam-
ages under CERCLA are  compensatory;  and a rebuttable pre-
sumption attaches  to assessments performed in accordance with
these  regulations. The fact that damages are compensatory stems
from  a reading of the law and its legislative history. The rebut-
table presumption is specified in section 11 l(h)(2) of CERCLA.
  The concepts discussed in this paper are the basis of Interior's
proposed natural resource  damage assessment regulations. These
regulations provide a proposed procedure  for agencies to deter-
mine  damages under CERCLA. It is hoped that by exploring the
issues of damages, injury  and the appropriate measure of these
terms, the proposed rule has initiated a discussion of the appro-
priate role of natural resource damages in the overall hazardous
material control strategy.
                                                                                     RCRA AMENDMENT EXPERIENCE    359

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                               Regulatory  Impact  Analysis  for
                                    the Toxicity Characteristic

                                                 John  L. Warren
                                         Center for Economics  Research
                                           Research Triangle  Institute
                                    Research Triangle Park, North Carolina
ABSTRACT
  The U.S. EPA is expanding the use of the toxicity character-
istic as a means of identifying hazardous waste.  Because of the
projected impact of this new regulation, a detailed Regulatory
Impact Analysis (RIA) was prepared to support the development
of the new regulations. This RIA addresses the benefits and costs
of the regulation including a benefit/cost assessment, risk assess-
ment and uncertainty analysis. This paper provides an overview
of the methodology  employed and the results obtained; it does
not represent the views of the U.S. EPA.

INTRODUCTION
  The U.S. EPA is  proposing to  expand its  regulation of haz-
ardous wastes to comply with  RCRA by regulating additional
wastes. Executive Order 12291 requires regulatory agencies to
maximize the net social benefit of regulations and  to conduct a
Regulatory Impact Analysis (RIA)  for any major rule. A major
rule is one likely to result in one or more of the following:
• An annual effect on the economy of $100 million or more.
• A major increase in costs or prices for consumers; individual
  industries; Federal, State or local government agencies; or geo-
  graphic regions.
• Significant  adverse effects  on competition, employment, in-
  vestment,  productivity, innovation or the ability of United
  States-based enterprises to compete in d< mestic or export mar-
  kets.

  This RIA provides an analysis  of tne U.S. EPA's  proposed
regulation based on the guidelines  contained in the Office of
Management and Budget's "Interim Regulatory Impact Analysis
Guidance"  (June 12, 1981) and the U.S. EPA's Guidelines for
Performing Regulatory Impact Analysis (1983).

PROPOSED ACTION
  The U.S. EPA is proposing to expand the existing Extraction
Procedure Toxicity Characteristic (EPTC) (40 CFR 261.24). This
characteristic currently involves a leaching test (known as the Ex-
traction Procedure or EP), which is used to determine how much
a toxic chemical would leach if a  waste containing it  were  dis-
posed of along with municipal wastes in a sanitary landfill. A
problem with  the EP toxicity test is that it originally was not de-
signed to  measure leaching  of organic chemicals from solid
wastes. It was designed primarily to model the leaching of metals.
  Currently, wastes containing toxic constituents are designated
as hazardous primarily through the listing mechanism. Listing is a
slow,  resource-intensive  process that  is specific  to  hazardous
wastes generated in a particular industry. At present, only a small
percentage of potentially hazardous wastes containing toxic con-
stituents are listed  because the U.S. EPA has had limited  re-
sources to devote to the  industry studies program that prepares
the listings.
  The U.S. EPA perceived a need for a more comprehensive
and self-regulating means of identifying wastes as hazardous and
believed the best way to meet this need is  to expand the existing
EPTC. The expanded EPTC (known as the Toxicity  Characteris-
tic Leaching Procedure—TCLP) applies to  all wastes, not just
metals and pesticides, and requires the waste generator to deter-
mine if its waste exceeds an acceptable concentration level.
  The U.S. EPA is proposing to initially regulate the 52 chemicals
listed in Table 1. These chemicals have been selected for regula-
tion on the basis of:

• Existence of an acceptable exposure level
• Existence of adequate fate and transport data needed to run the
  groundwater transport  model

  For a given toxic constituent, the U.S. EPA proposes to de-
termine  a toxicity threshold of that constituent in groundwater.
For noncarcinogens, the  toxicity threshold can be approximated
using a percentage of the acceptable daily intake (ADI). The per-
centage  used depends  on the extent to which simultaneous ex-
posure through air and ingestion occurs. The ADI is the amount
of a chemical (in mg/day) that can be ingested every day for a
70-year lifetime without adverse health effects. (Criteria for estab-
lishing ADIs are discussed in 45  FR 79318.) The resulting frac-
tion of the ADI is referred to as the Health Based Starting Limit
(HBSL). For  carcinogens,  the U.S. EPA's Carcinogen Assess-
ment Group (CAG) has calculated the probability of cancer aris-
ing per unit dose. This unit cancer risk (UCR) is the risk of cancer
for a dose of 1 mg/kg per body weight/day over a  70-year life-
time. The dose corresponding to a cancer risk of 1 in 10* for each
carcinogen is  derived from the UCR.  That level is  the virtually
safe dose (VSD). For  carcinogens, the HBSL can  be approxi-
mated using the VSD.
  Once the HBSL is established for a toxic waste constituent and
the degree of attenuation between the disposal site leachate and
the well water is estimated, the level of the constituent in a leach-
ate that yields constituent concentrations at or above  the HBSL at
a well near a land disposal facility is calculated.  That level is called
the regulatory level (RL). The RL determines the leachate con-
centration of a constituent (as measured by the TCLP) that would
cause the waste containing that constituent to be considered haz-
ardous under RCRA.  Any waste that has a  TCLP concentra-
tion greater than its RL  is hazardous  by  definition and subject
to regulation under  RCRA as a hazardous waste.
360   RCRA AMENDMENT EXPERIENCE

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                           Table 1
      Selected Chemicals Considered for Regulation Using TCLP
  Acrylonitrile
  Arsenic
  Barium
  Benzene
  Bis(2-chloroethyl)ether
  Cadmium
  Carbon bisulfide
  Carbon tetrachloride
  Chlordane, technical
  Chlorobenzene
  Chloroform
  Chromium(VI)
  o-Cresol
  m-Cresol
  p-Cresol
  2,4-D, salts and  esters
  1,2-Dichlorobenzene
  1,4-DiChlorobenzene
  1,2-Dichloroethane
  1,1-Dichloroethylene
  2,4-Dinitrotoluene
  Endrin
  Heptachlor
  Hexachlorobenzene
  Hexachl orobutadiene
  Hexachloroethane
Isobutanol
Lead
Lindane
Mercury
Methoxychlor
Methylene chloride
Methyl  ethyl ketone
Nitrobenzene
Pentachlorophenol
Phenol
Pyridine
Selenium
Silver
1,1,1,2-Tetrachloroethane
1,1,2,2-Tetrachloroethane
Tetrachloroethy1ene
2,3,4,6-Tetrachlorophenol
Toluene
Toxaphene
1,1,1-Trichloroethane
1,1,2-Trichloroethane
Trichloroethy1ene
2,4,5-Trichlorophenol
2,4,6-Trichlorophenol
2,4,5-TP
Vinyl chloride
 REGULATORY ALTERNATIVES ANALYZED
   Benefits and  costs  are  determined  for  the  following  three
 selected regulatory alternatives and the Status Quo (i.e., no regu-
 lation):

 • Alternative 1: Includes all currently unregulated wastes that
   would produce a TCLP extract containing any of the 52 con-
   taminants  at a level greater than or equal to  100 times the
   chronic health based threshold.
 • Alternative 2: Includes all currently unregulated wastes that
   would produce a TCLP extract containing any of the 52 con-
   taminants  at a level greater  than  or equal to  10  times the
   chronic health based threshold.
 • Alternative 3: Includes  all currently regulated wastes  that
   would produce a TCLP extract containing any of the 52 con-
   taminants at a level greater than or equal to 1,000 times the
   chronic health based threshold.
 • Status Quo: No regulation.
   Benefits and costs for each regulatory alternative are compared
 to those of the baseline Status Quo. Under the Status Quo, indus-
 try does  not incur additional waste management costs for  more
 stringent requirements. However, society will  incur the costs of
 not regulating these wastes. These social costs  of the Status Quo
 are assumed  to be  the benefits  that would occur if  the wastes
 were regulated; they vary with the number of affected facilities.

 AFFECTED INDUSTRIES
  Because the proposed action is chemical-specific rather than in-
 dustry-specific, it affects  a wide range of industries. Table 2
 shows the affected  industries by Standard  Industrial Classifica-
 tion (SIC) code. Most of the plants that produce and use the pro-
posed chemicals appear in the  chemical industry. Any facility
that has one of the selected chemicals in a waste stream at con-
centrations greater than the RL will be affected.  (Those wastes
currently regulated under RCRA are not included in the analysis.)
The number of affected facilities may include plants that produce
or use more than one of the chemicals.

ECONOMIC IMPACT METHODOLOGY
  A partial equilibrium multimarket (PEM) model is employed
to project the economic impacts of the regulatory alternatives.
All 11 industries that would be directly affected by the regulatory
alternatives are modeled.
  The primary objective of the PEM model is to project changes
in equilibrium  prices and output rates in both directly  and in-
directly affected industries. Related impacts on industry employ-
ment also are projected by the model.
  The projected economic impacts are of interest for two reasons.
First, they indicate the types and magnitudes of industry changes
that might be expected as a consequence of the regulatory altern-
atives.

                           Table 2
                    Directly Affected Sectors
        Industry
                                                   SIC Code No.
Plastics materials  and resins

Synthetic rubber

Medicinals and botanicals

Soap and other detergents

Surface active agents

Paints and allied products

Cyclic crudes and intermediates

Industrial organic  chemicals

Agricultural chemicals

Petroleum refining

Nonferrous wire drawing and insulating
2821

2822

2833

2841

2843

2851

2865

2869

2879

2911

3357
                               Second, the price and output rate impacts represent resource
                            reallocations  that impose  costs on affected parties.  The  pro-
                            jected equilibrium impacts are thus the key ingredient in the regu-
                            latory cost projections.
                               As modeled, industry supply curves are perfectly elastic. Regu-
                            latory price impacts thus reflect production  cost changes. The
                            model accounts for both direct cost changes attributable to con-
                            trol and indirect cost changes attributable to inter-industry trans-
                            actions.
                               Demand curves for outputs of  modeled  industries are down-
                            ward sloping.  When product prices increase, c uantities demanded
                            decline. Production rates  decline to restore  equilibrium, and
                            changes in employment and  capital expenditures  result.  The
                            model does not account for demand shifts that might occur, but
                            these are believed to be insignificant.

                            BENEFIT ESTIMATION METHODOLOGY
                               Regulation  of wastes containing any one of the selected chem-
                            icals should result in a reduced risk of groundwater contamina-
                            tion and  subsequently contamination of the drinking water  of
                            many communities. If the contaminating chemical is  a carcino-
                            gen, drinking  the water may result in an excess incidence of can-
                            cer cases in the population. Ingestion of noncarcinogenic chem-
                                                                                       RCRA AMENDMENT EXPERIENCE    361

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icals in drinking water at a level  above the ADI may be corre-
lated with toxic,  reproductive or genetic effects,  depending on
the particular chemical. Switching to an alternative water source
to avoid drinking contaminated groundwater imposes substantial
costs for the affected communities. Often, if a chemical has been
detected in the groundwater, the contaminated aquifer is cleaned
up and the landfill treated, resulting in additional costs to  the
community.
   For each chemical, estimates are made of  the health effects,
switching and cleanup costs (corrective costs) attributable to  the
presence of that chemical for wastes currently disposed of in  un-
regulated landfills. Regulation of the  waste is assumed to prevent
these estimated  health effects and corrective costs completely.
The estimated benefits attributable to the regulation  are the  ad-
verse health effects and corrective costs avoided by its implemen-
tation.
   Four steps are used to determine benefits:
•  Estimate quantity and concentration of chemical in landfill
•  Estimate concentration of chemical in leachate
•  Estimate chemical concentration at well
•  Estimate health effects and corrective costs attributable to con-
   tamination of the wellwater.
   The unregulated wastes are assumed to be disposed of in a land-
fill each year for 20 years (the average lifetime of a landfill). The
amount of the chemical contaminant that  leaches through  the
landfill and the leaching duration are determined  using data on
the persistence and mobility of each chemical and the form of the
waste stream. From the bottom of the landfill, the contaminant is
transported through the aquifer to the community well. The con-
centration of the contaminant at the  well varies over  time and is
tracked over a maximum of 100 years. The  attenuation factor
assumed depends both on dilution of leachate in the aquifer and
on the specific properties  of the chemical. The adverse health
effects and corrective costs attributable to the contaminated well
are then estimated. Excess cancers are estimated using a life table
model. For noncarcinogenic  health effects, the person-years of
exposure above the HBSL are estimated.
   The Base Case Method  is employed  to estimate  the  concen-
tration of the  chemical in the  leachate and at the well.  Key
assumptions of this method include:
•  The landfill receives predominantly domestic refuse, with only
   5% of the landfill holding industrial waste.
•  The character of the leaching fluid  to which wastes are exposed
   is primarily a function of the noninduslrial material  in the land-
   fill.
•  The landfill is located over an aquifer that is a source of drink-
   ing water for 2,000 persons in the region of the landfill.
•  Soil below the landfill has limited attenuative capacity.
•  The nearest drinking  water wells  are 150  m (500 ft) down-
   gradient from the landfill.
•  As constituents migrate from  the landfill through  the  un-
   saturated and saturated zones to the source of drinking water,
   they are attenuated by a factor of 100.

COST ESTIMATION METHODOLOGY
   The current disposal costs  or baseline must be  established to
estimate the increased disposal costs incurred by waste generators
resulting from the proposed regulation. Current disposal costs are
a function of the  disposal alternatives in use. Where the waste is
not a listed hazardous waste, current disposal practices are iden-
tified by examining the technical literature, by analogy to similar
wastes for which disposal practice is known, or by assumption.
   Some baseline disposal alternatives may understate the actual
treatment and disposal applied to that waste because no effort  has
been made to determine which wastes may be affected by State
and local regulations that are more stringent than Federal regula-
tions. This also may occur because firms may be voluntarily ap-
plying  more thorough  treatment and disposal than required by
regulation. The result of this potential understatement of baseline
treatment and disposal alternatives is that the estimated increase
in disposal costs to comply with the  characteristic approach will
be greater than the actual increase.
  For currently landfilled wastes not  listed as hazardous but sub-
ject to the regulation,  disposal practice after regulation will be-
come more stringent and  costs will increase. Disposal costs are
assumed to remain  the same for wastes currently incinerated or
deepwell-injected.  Solvent wastes  and  a few other wastes that
have been assumed  to be landfilled will be containerized prior to
disposal.
  Using model  plant information, estimates of the incremental
disposal and operating and maintenance costs associated with the
implementation of the alternatives are projected. These estimated
costs then are compared to the cost of contracting with com-
mercial disposal services to estimate properly the minimum costs
incurred by the affected facilities.  These costs are annualized to
reflect  an accurate measure of the  increased  production costs
associated with  the  new regulation. Estimates of percentage cost
changes are generated  for use in  the  production/consumption
model.  Under  the  assumption of full-cost pricing, these  per-
centage estimates are determined by  dividing the annualized in-
cremental costs  by the value of shipments in affected SIC indus-
tries.
  The economic impacts model is used  to derive all costs or wel-
fare  losses borne by consumers of  directly affected products.
Consumers suffer a welfare loss when regulatory compliance in-
creases  prices because they lose consumer surplus, or the value
placed on consumption in  excess of  the  amount  required  to
purchase a product. Economic theory  allows the estimation  of
total consumer costs through impacts  in the directly affected mar-
kets. Thus, input and output market data are not required.
  Consumer surplus losses represent the only recurrent or annual
costs. Changes in waste disposal methods in response to a regula-
tion are represented by an upward shift in the  supply function.
The higher production  costs that result create a new equilibrium
and a consumer surplus loss. The new equilibrium will have lower
production at a higher cost than the initial equilibrium. A real
resource cost is the value of the additional costs incurred at the
new lower level  of output. A deadweight loss is the loss in surplus
value consumers placed on those  units that no longer will  be
produced.
  Extension of the above analysis to a  multimarket situation is
straightforward. Because impacts  in input and output markets
need not be considered to project approximate welfare costs, total
welfare costs are developed  by summing welfare costs in the 11
directly affected markets.
  Consumer surplus and deadweight costs represent annual costs.
Within  this analysis, all baseline data are presented for the year
1982. However, consumer surplus  losses will be incurred for an
unknown  number of years. To develop cost estimates for future
years, costs first are estimated for  1982 and then assumed to be
constant for all subsequent years. This simplifying assumption is
used because time constraints precluded  the projection of market
trends.
  Implementation  costs, consisting of transaction costs and em-
ployment  losses, represent one-time  losses in welfare. Transac-
tion costs represent the value of resources that would be expended
to determine  if  a waste stream  is to be regulated. These costs are
based on an estimated cost of sampling and analyzing each waste
stream by  affected  facilities. Employment losses  occur because
362    RCRA AMENDMENT EXPERIENCE

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consumption of goods and services are foregone when individuals
are unemployed. Losses are based on the projected changes  in
production  and employment-to-output ratios for each directly
affected market.  These losses are not valued in dollar terms be-
cause it is difficult to project the length of time an employee
will be  unemployed. Also, the value placed  on this time period
depends on a variety of such  unknown parameters  as  an indi-
vidual's job skills, age, education and personal dislike of being
unemployed.

RESULTS—
Aggregate Benefits
   Continued use of current practices for managing wastes con-
taining the selected chemicals is expected to result in the deteriora-
tion of environmental quality. This  deterioration may elevate
risks to human health and reduce the quality of environmental
resources, such as  uncontaminated drinking water.  The  major
route expected to affect environmental  quality is through the
leaching of contaminated wastes into groundwater. Over 50% of
the U.S.  population uses  groundwater for  drinking water.
Further, contaminated groundwater can enter surface water, re-
ducing its quality. The capacity of both groundwater and surface
water to assimilate toxic chemicals is limited.
   If people drink contaminated  groundwater, a  wide range of
health effects may occur, from simple gastrointestinal problems
to cancer  and birth defects. We focus on the possible excess can-
cer cases if the selected chemicals are not regulated. We assume
that contaminated water would continue to be used as a drinking
water source  unless  the concentration reached  taste or  odor
thresholds of the  average person.  If that threshold is attained, we
assume  they would switch to alternative water sources and no ad-
verse health effects would occur. When a landfill is recognized
as a source of groundwater contamination,  we also  assume the
municipality would take action to prevent further leaching of the
chemicals. Switching and cleanup incur significant financial costs.
Estimates were developed for a representative community  of
2,000 persons and were aggregated to obtain national totals. The
aggregation process  assumed that each plant's waste affected a
single community. Because this aggregation process  is not very
precise, the reader is cautioned to interpret the results carefully.
The results  for each regulatory  alternative  are summarized in
Table3.

Aggregate Costs
   Benefits of the regulatory alternatives would be accompanied
by costs.  Total costs of the regulatory alternatives include real
resource costs, deadweight consumer surplus losses, deadweight
producer surplus  losses (capital value losses), employee disloca-
tion costs and government transaction costs.
  Two  of these welfare costs  have not been projected in this
analysis. Employee dislocations have been quantified, but their
social costs  have not  been evaluated. Capital value losses in-
curred by owners of affected  capital also have not  been eval-
uated.
  Projected real resource and deadweight consumer surplus costs
of the three regulatory alternatives are reported in Table 3. Pro-
jected employee dislocations also are presented.

BENEFIT-COST ANALYSIS
  Table 3  summarizes the benefits and costs  of the three regula-
tory alternatives. The differences between the monetized benefits
(i.e., avoided  corrective costs) and monetized costs (i.e., real
resource and deadweight consumer surplus costs) are compared
using the annualized method. The differences are positive for all
regulatory alternatives. Thus, each alternative would provide an
                            Table 3
                     Benefit-Cost Assessment
                                         Regulatory Alternative
          Benefits/costs
Monetized benefits:

  Avoided cost of alternative water
  source
    Present value ($106)b
    Annualized ($106/yr)
3,218
  378
  Avoided  cost of aquifer cleanup
    Present value ($106)b         11,897
    Annualized ($106/yr)           1,398

Monetized  costs:

  Real  resource cost
    Present value ($106)b          1,285
    Annualized ($106/yr)             151

  Deadweight consumer  surplus cost
    Present value ($106)b          1.15
    Annualized ($106/yr)           0.14

  Transaction cost ($106)''         1.22

Net monetized benefits:

  Present  value ($106)b           13,830
  Annualized ($106/yr)            1,625

Nonmonetized benefits:3

  Avoided  cancer  cases               54

  Avoided  person-years of exposure    4.8
  above the HBSL  (106)

Nonmonetized costs:

  Employment dislocations           407
3,317
  390
           12,316
            1,447
            1,287
              151
            1.16
            0.14

            1.26
          14,345
           1,685
              54

               4.8




             407
3,174
  373
           11,719
            1,377
            1,186
              139
            1.03
            0.12

            1.17
          13,706
           1,610
              53

               0




             372
aBenefits are based on the Base Case Method.
b20-Year cost discounted at 10%.
cOne-time cost incurred first year.
dMonetized benefits minus monetized costs excluding transaction costs.
eHBSL =  Health based starting limit.

improvement in economic welfare. The maximum improvement,
ignoring health benefits, is under Regulatory Alternative 2.
  An evaluation  of Regulatory Alternatives 1 and 2 will allow a
comparison of the results of the 100 x HBSL and the more strin-
gent 10 x HBSL regulatory levels. These two alternatives  have
virtually no differences in health benefits. However, Regulatory
Alternative  2 yields  an increase  in  net  monetized  benefits of
$60.59 million annually.
  Moving from Regulatory Alternative 1  to Regulatory Alterna-
tive 3 results in a decrease in the stringency of the regulatory level
from 100 x  HBSL to 1,000 x HBSL. As a result of this change,
avoided cancer cases will decrease slightly by a total of 0.39 cases.
However, the  4.8  million  person-years  of avoided exposures
above the HBSL in Regulatory Alternative 1 decreases to 0 under
Regulatory  Alternative 3.  Additionally, net monetized benefits
are $14.44 million annually higher in Regulatory Alternative 1
than in Regulatory Alternative 3.

CONCLUSIONS
  The proposed expansion  of the toxicity characteristic will pro-
vide an additional, cost-effective method for the U.S. EPA to use
in regulating hazardous wastes. For those regulatory alternatives
analyzed,  the benefits are significantly greater than the costs of
regulating additional wastes containing any of the 52 chemicals.
                                                                                        RCRA AMENDMENT EXPERIENCE    363

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                 Preliminary Assessments  and Site  Investigations
              Under  the Corrective Action Authorities  of RCRA;
                                Analysis of Early  Experiences
                                                 John W. Butler
                                               A.T.  Kearney,  Inc.
                                              Alexandria,  Virginia
                                               Robert D. Volkmar
                                            Michael Baker,  Jr.,  Inc.
                                              Beaver,  Pennsylvania
ABSTRACT
  Implementation of Section 3004(u) of RCRA requires the eval-
uation of solid waste management units not regulated under
other RCRA authorities to determine if these units have contin-
uous releases of hazardous wastes or constituents. The first step
of this evaluation, a preliminary assessment and site investiga-
tion (PA/SI), often is conducted in conjunction with the RCRA
Part  B permit  application review  process.  The authors have
assisted the U.S. EPA in conducting several of the earliest RCRA
PA/SIs. In this paper, the authors  present a composite descrip-
tion of the PA/SI methodologies employed in those reviews, dis-
cuss critical  obstacles encountered and describe the process used
to determine the need for RCRA permit conditions to address re-
leases of hazardous wastes or constituents to the environment.

INTRODUCTION
  One of the most important new authorities provided  to the
U.S. EPA under the Hazardous and Solid Waste Amendments of
1984 (HSWA) is Section 3004(u) which requires that  all RCRA
permits issued to treatment, storage and  disposal facilities after
November 1984 shall require corrective action for all releases of
hazardous wastes or constituents from solid  waste management
units at these facilities. In addition, under Section 3008(h), the
U.S. EPA is given authority  to issue corrective action enforce-
ment orders to facilities managing hazardous  waste under RCRA
interim status. Another extremely  important related  provision.
Section 3004(v),  extends RCRA corrective action authority be-
yond the boundaries of the facility.
  The authorities  provided under  these provisions  extend the
scope of RCRA well beyond  that to which treaters, storers and
disposers of hazardous waste previously had been covered. Prior
to the amendments, facilities and operators had to be concerned
with obtaining permits for regulated units used for treating, stor-
ing and disposing  of hazardous wastes as defined by the U.S.
EPA under 40 CFR Part 261. Now, a new process has been put
into place which extends the permitting process to include a re-
view of essentially every unit within a facility's boundaries which
is used or has been used to manage solid wastes.
  The U.S.  EPA is approaching implementation  of these new
authorities under a process involving three general steps which
roughly parallel the process used under CERCLA:'

  Stage 1: Assessment of Need for Corrective Measures. This
stage usually involves a preliminary  assessment and site investiga-
tion (PA/SI), which includes an evaluation  of readily available
information to determine if releases posing  a threat  to human
health and the environment have occurred or if there is a likeli-
hood that such releases may have occurred. The U.S. EPA issued
a draft guidance document on August 5,  1985, providing pro-
cedures for conducting RCRA PA/SIs.'
  Stage 2: Remedial Investigation and Development of a Pro-
posed Program  of Corrective Measures. If the  results of the
PA/SI indicate that releases have occurred or may be occurring
at one or more units, owners and operators will be required to
conduct a remedial investigation  to make a more definitive de-
termination regarding the potential for releases and to identify
the nature and extent of releases that are found.
  The second step in this phase of the corrective action process
is the development of a program of corrective measures to clean
up the releases found in the remedial investigation. If this pro-
gram is developed as part of a RCRA permit condition, the per-
mit will need to be modified to incorporate the corrective meas-
ures program after public comment is solicited and received on
the proposed measures.
  Stage 3: Selecting and Performing Corrective Measures. This
stage is the actual establishment and implementation of the
corrective measures program, which may be carried out accord-
ing to schedules of compliance in the facility's modified RCRA
permit or under an enforcement order.
  The authors have assisted the U.S. EPA in conducting some
of the earliest PA/SIs under this process,  using the procedures
in the Agency's August 1985 guidance. The guidance currently is
being reviewed by the U.S. EPA based on the results of field test-
ing of the document. From their early experiences with the RCRA
PA/SI process, the authors present  some observations  which
they believe will be helpful to facility owners and operators in
determining how they can participate most effectively in the PA/
SI reviews of their facilities and  to regulatory officials who are
faced with the challenging task of conducting RCRA PA/SIs.

CONCEPTUAL APPROACH TO PA/SIs
  The approach used by the authors in conducting RCRA PA/
Sis roughly involves a sequential exclusionary process  for each
unit  at a  facility  in which solid waste  management  units
(SWMUs) are systematically eliminated from further considera-
tion if certain criteria are met. Figure 1 illustrates the line of in-
quiry used  by the investigator in this process. In practice, data
limitations restrict the ability of the investigator to make simple
"yes/no" determinations. Rather than being a sequential pro-
cess,  the  actual  process almost always requires a degree of pro-
tessional  judgment in weighing a number  of factors. Neverthe-
less, in an ideal situation, the investigator would have all the in-
formation needed and the line of  inquiry would take place as fol-
lows: Is the unit an SWMU?
     Units at a  facility which are considered SWMUs for pur-
poses of RCRA corrective action reviews are very broadly de-
364    RCRA AMENDMENT EXPERIENCE

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fined. In general, the types of units include:  landfills,  surface
impoundments, waste piles, land treatment units, incinerators, in-
jection wells, tanks (including 90-day accumulation tanks), con-
tainer storage areas, transfer stations and waste recycling op-
erations.  Units specifically  exempted from RCRA  regulation
under 40 CFR Part 264 are included in this universe, i.e., waste-
water treatment and elementary neutralization tanks.  Units may
be active, inactive or completely abandoned. Units which are not
managing or have never managed RCRA-regulated  hazardous
wastes still are considered as SWMUs  subject to review,  since
the potential for the release of hazardous constituents also must
be evaluated.

Does the Unit Manage Hazardous Waste?
  Waste  characterization is one of the most critical steps in the
PA/SI process. The scope of materials of concern is considerably
larger than wastes which are regulated under RCRA on the basis
of listing or hazardous characteristics. In a PA/SI, units which
manage or have managed wastes  containing hazardous  constit-
uents included in 40 CFR Part 261, Appendix VIII, must be re-
viewed for the potential of releases of these constituents to the
environment.  Further,  units used to manage bulk  putrescible
wastes (such as sanitary sludges) must be assessed for the poten-
tial of methane gas generation and subsequent migration of sub-
surface gases to adjoining structures.
   In an ideal case, the PA/SI investigator would have detailed in-
formation available about the types, volumes and locations of
waste within the units. If the data clearly show that no hazardous
wastes, hazardous constituents or wastes capable of methane gen-
eration have ever been managed  in  the unit,  the  unit  may be
eliminated  from further  consideration. If hazardous wastes or
constituents are present,  the chemical/physical properties, tox-
icity, persistence and mobility of the wastes can be evaluated to
determine the potential of the wastes for releases to air, ground-
water, surface water and/or soils; also the threat posed to human
health and the environment by such releases can be assessed.
(1)
DOES OR HAS
UNIT MANAGED
HAZARDOUS
WASTE
OR CONSTITUENTS*


1

(J)
DOES UNIT HAVE
A HISTORY
OF OR POTENTIAL
FOR RELEASE 7

              (41
         DO RELEASE SPOSE

          A THREAT TO
          HUMAN HEALTH
              AND
          ENVIRONMENT »
   IS THERE A

'.SIGNIFICANT RISK
 TO POPULATIONS?
                          Figure 1
                Conceptual RCRA PA/SI Process
Is There a Potential for Releases?
  If the investigator has key design and operating data, he can
make a reasonable evaluation of the potential for releases from
the unit. A common unit investigated is a tank which has an ade-
quate secondary containment system, closed roof and sufficient
flood protection; commonly available are records demonstrating
that the tank has  been inspected frequently and  maintained. In
this case, the investigator may  eliminate the unit from further
consideration on the basis of the unlikely potential for releases,
regardless of the types of wastes or constituents managed.
Is There a Threat to Human Health and
the Environment?
  At this point in the "idealized" evaluation, the investigator has
determined that a solid waste management unit has managed haz-
ardous wastes or wastes which have hazardous  constituents and
that  there is  a high likelihood of  releases. It still may be pos-
sible to eliminate this unit on the  basis of consideration of the
pathways available to the releases into each environmental med-
ium. For example, subsurface releases may not present a threat to
groundwater  if the  underlying aquifer is deep,  if soils are rela-
tively impermeable  and/or if the aquifer underlays sufficiently
impermeable  bedrock. Even if the hydrogeological setting indi-
cates that there  is a potential for  infiltration to the underlying
aquifer, the owner/operator may have monitoring data available
demonstrating that no  contamination  attributable to  releases
from the unit are occurring.

Is There a Risk to the Neighbors?
  Even if the unit has failed all of the above tests, it may be pos-
sible to determine that the risks posed by the releases do not pose
a threat to human health and the environment. For example, air
releases may not be  of concern if there are no downwind popula-
tions. However, since U.S. EPA policies regarding risk assess-
ment in RCRA PA/SIs still are evolving, the role of risk in the
process is unclear at  this time.

Key Information Used in RCRA PA/SIs
  The process just described assumes that the investigator has in-
hand all necessary information required  to make the determina-
tions just described.
  The  most important pieces  of information and their common
uses  in RCRA PA/SIs are displayed in Figure 2. The  following
discussion summarizes the  common roles of these data  in RCRA
PA/SIs.
  In many circumstances, the PA/SI for a  facility will begin
after submission of a Part B permit application  and  after the
owner/operator has responded to the regulatory  agency's request
for information  about its solid waste   management units. Al-
though these information requests have been fairly general  in
practice, there are certain specific data items which should be
included in each letter responding to such information requests.
These  include identification  of each  solid waste management
unit:3
• Description of the type of unit
• Location of each unit within the facility on a topographic map
• Dimensions and available information on release controls
• Status and history of operation
• Description of wastes managed
  All available information which could indicate the potential for
releases from  any of the units,  including:

• Available environmental monitoring data (groundwater, sur-
  face  water,  air, soil samples)
• History of releases to any environmental medium

  Information in the applicant's response to this information re-
quest,  combined with the  RCRA Part B application,  generally
provides the core of data for  initiation of a PA/SI. Some of the
most relevant data for PA/SIs which are generally found in Part
B applications include:
  Waste Characterization: Although the waste  analyses in Part
Bs are only applicable to those wastes which are managed at regu-
lated units in  the application, the information may be useful for
providing  a general picture of waste generation trends at  the
facility.
                                                                                     RCRA AMENDMENT EXPERIENCE    365

-------

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                                                           Figure 2
                                        Information Sources Frequently Used in RCRA PA/Sls
    General Facility Description: Descriptions of the facility can
 be used by the PA/SI investigator to gain some understanding of
 the overall  facility layout, surrounding land use and  general
 topography.
    Floodplain Delineation: The determination of whether or not
 individual solid waste management units are situated in flood-
 plains is a critical part of the  PA/SI.  Corrective measures  for a
 unit which may not otherwise  have a potential for releases to the
 environment may be required if flooding could threaten the struc-
 tural integrity of the unit and/or result in direct runoff or dis-
 charge to adjoining surface waters.
   Hydrogeological Data: For Part Bs for land disposal units, an
 extensive amount of data regarding the hydrogeologic setting of
 these units is required. While these data are specific to the  regu-
 lated units at the facility, they sometimes  can be used in PA/SIs
 of other units at the facility in lieu of available information for
 these units.
   Exposure Information:  Under Section 3019 of RCRA, permit
 applications  for landfills  and surface impoundments must in-
 clude exposure information reports. This information is valuable
 in determining the potential migration pathways of contaminants
 released from SWMUs and for identifying populations potential-
 ly at risk from such releases.
   Contingency Plans: Contingency plans, required of all RCRA
 permittees, may be  useful in determining if the permit applicant
 has identified all SWMUs at the facility.  For example, the  plan
 may provide for temporary storage or impoundment  of  haz-
 ardous wastes in specific areas at the facility; these areas would
 be solid waste management units which should be included in the
 PA/SI review.
  As indicated in Figure 2, there are numerous other important
 sources of information which should be available to the investi-
 gator to supplement the facility's Part B  and SWMU informa-
 tion letters. These sources are noted below.
  CERCLA  Sources: If a preliminary assessment and/or site in-
vestigation has  been performed for  the  facility  under  the
CERCLA program, the results and supporting documentation
are clearly a critical imput to the RCRA PA/SI. Hazard Ranking
 System documentation  and CERCLA Section 103(c)  notifica-
 tions also can be valuable information sources. The most im-
 portant differences between CERCLA and RCRA PA/SIs, which
 will be described in the  following paragraphs,  must be  borne in
 mind when using this information.
   U.S. EPA/State Inspection Files: Generally, the PA/SI inves-
 tigator will find it extremely beneficial to perform a file search of
 the regulatory agency's  (State or U.S.  EPA) records of inspec-
 tions performed previously at the facility. RCRA inspections, as
 well as inspections performed under the NPDES program, some-
 times can help the investigator identify environmental problems
 and releases which have occurred. Inspection records for State-
 regulated units, such as  non-hazardous solid waste landfills,
 also can be extremely valuable.  An unquantifiable, but never-
 theless important, aspect of this review is the general insight pro-
 vided about general environmental management practices at the
 facility.
  Monitoring Data:  Any  relevant type of environmental mon-
 itoring data, even if the monitoring  was not performed for
 RCRA-hazardous constituents, may be important to the PA/SI
 investigation.  Indications  of conventional  contaminants  in
 groundwater, for example, may be indicative of releases of other
 constituents of concern from a solid waste management unit.
  Other  Data Sources:  Other sources of information, such as
 aerial photography, may be very important to the PA/SI investi-
 gator. Basically, any  type of information which can help the in-
 vestigator understand the nature and operation of the unit, its his-
 tory,  wastes managed and operational practices should be con-
 sidered in the review.

 Relationship Between RCRA and CERCLA PA/SIs
  There  are obvious analogies between the PA/SI procedures
used in the CERCLA and RCRA programs. Generally, the same
types of factors are considered by the investigator, including the
 types of wastes managed at the unit, environmental setting, struc-
tural  integrity of the unit  and release controls, history of unit
operation, history of releases and surrounding land uses.  For
this reason, prior CERCLA investigations are generally extremely
useful sources of information for the RCRA PA/SI.
366   RCRA AMENDMENT EXPERIENCE

-------
  While many of the procedures for conducting PA/SIs for facil-
ity SWMUs under RCRA are similar to those used by CERCLA
field teams, there  are fundamental differences between these two
processes that may render different outcomes in terms of result-
ing requirements placed upon facility owner/operators. The most
basic difference is in the ultimate objectives  of each  of the re-
views.
  The objective of a CERCLA PA/SI is to develop information
sufficient to develop a score under the Hazard Ranking System
(HRS), which in  turn is used to establish priorities for further
action at the site. Ultimately a site may be placed on the National
Priority List with subsequent remedial investigations, feasibility
studies and selection and  implementation of remedial actions.
An HRS score is established for an entire facility and may be the
result of cumulative environmental impacts of a number of units
within the facility.
  In contrast to the CERCLA process, the objective of an RCRA
PA/SI is to  determine whether or not releases may be occurring
at individual units within a facility. The outcome of the investi-
gation is not a numeric score, but a finding for each unit regard-
ing its potential for releases to the environment. This distinction
can  mean that  facilities which  have relatively low HRS scores
may nevertheless  be required to conduct  corrective measures
under RCRA.
 OBSTACLES TO THE PA/SI REVIEW
 PROCESS
  The conceptual RCRA PA/SI process has been described in
 detail to highlight two of its  most significant features: first, an
 extensive amount of information is needed to fully complete every
 step of the process and, secondly, facility owners and operators
 need to be actively involved in the process to assure that the most
 accurate and timely information is used. The lack of data neces-
 sary to derive conclusions regarding the likelihood of releases of
 hazardous wastes and constituents to the environment likely will
 result in RCRA permit conditions requiring  the  facility owner
 and operator to develop the needed information under  man-
 dated deadlines.
  It is clearly in the facility  owner/operator's best interests to
 come forward with all available relevant information at the PA/
 SI stage of the permitting process rather than to  defer substan-
 tive input  until the RCRA  permit reaches  the formal proposal
 stage. Of course, in many cases, critical information may not be
 available to the owner/operator. Facilities simply did not have a
 need to keep records  on many of their units operated prior to
 RCRA enactment. The lack of adequate records poses one of the
 most critical obstacles to the RCRA PA/SI process.
  The most frequently occurring  data problem  is inadequate
 characterization of the wastes  placed in the unit. Without reliable
 waste management data, it  is not possible to  determine if there
 are or are  not hazardous constituents within the waste material.
 Since the entire corrective action program is keyed by releases of
 hazardous constituents, the PA/SI process is truncated by lack of
 waste characterization data. A case frequently encountered is a
 landfill unit known to have been used to dispose  of plant trash
 which may (or may not) have included off-specification produc-
 tion products with hazardous constituents or containers with haz-
 ardous residues.
  In some cases, it has been possible to ascertain the presence of
 hazardous constituents in a particular disposal  facility through
 process knowledge of the industry in question. In many cases,
 however, this is not possible—particularly where several disposal
 areas have been utilized  and no records have been kept to define
 the wastes placed in each area.
  In these cases, the PA/SI review process essentially becomes
stalled until adequate data are obtained. In some cases, this re-
view  has  been  accomplished  by  mandating data  collection
through permit conditions in the RCRA permit. In other cases,
facility owners and operators have been able to provide historical
data  on general facility waste management  practices which
demonstrated  that the facility's hazardous wastes were trans-
ported off-site during the period of operation of the unit in ques-
tion.
  Another frequent obstacle to the PA/SI review  process is in-
adequate description of the surrounding environment, primarily
those elements which serve as vehicles for contaminant trans-
port (soils, groundwater and surface waters). Typically, existing
waste management units  are not located in proximity to aban-
doned units. As a result, environmental information provided
in the Part B application or Exposure  Information Report may
not be germane to remotely located, abandoned units. If the Part
B application is for non-land disposal units, facilities are not re-
quired to provide hydrogeologic information which might be
helpful to the PA/SI review.
  Lacking critical information,  such  as  soils permeability or
depth to groundwater, it is not possible  to make reasonable judg-
ments regarding the potential for releases of hazardous constit-
uents, even when the presence of hazardous constituents in the
unit has been  firmly established. Again, in this case it is  likely
that the responsibility for providing the needed data will fall to
the owner/operator. Often,  this step requires  extensive  field
studies, including  soils testing,  groundwater  investigations or
sampling of surface waters.
  A third obstacle that frequently  impedes the PA/SI decision-
making process is the lack of evidence regarding releases  from
SWMUs.  This is especially true in the case of long-abandoned
units that predate the current era of environmental awareness. In
these and  other cases, the facility has no reason to monitor
groundwater, surface waters, air or soils. Lacking direct evidence
of releases, it sometimes  is possible to make judgments regard-
ing the  potential for or probability of a release. This decision
can be made when the properties of the waste and the local trans-
port media (groundwater, etc.) are well defined.
  More often than not,  however,  only sketchy information is
available. In those cases, there are two approaches that can re-
move the decision-making obstacles. The first  step is to directly
monitor the appropriate media to detect evidence of contamina-
tion resulting from a release from the unit in question. This pro-
cess frequently involves monitoring of surface of ground waters.
  Alternatively,  it may be more feasible to conduct the studies
necessary to assess the potential for release. This  approach in-
volves investigation of the waste properties and characterization
of the surrounding environmental media.
  In some complex situations, a hybrid of both approaches must
be used. This can occur when there are  several units in proximity
and knowledge  of environmental  conditions  is insufficient to
properly design  a monitoring program to  detect releases.  This
situation presents a more difficult  case where both background
environmental studies (e.g., geohydrological investigations) and
monitoring must be undertaken to  detect contamination.
  Another obstacle arises when environmental data indicate that
there is a problem at the facility,  but the PA/SI investigation
cannot identify the unit or units most likely to be causing the
problem. This situation can arise,  for example, when ground-
water monitoring data from samples collected at various locations
within the  facility indicate concentrations of hazardous constit-
uents above natural  background levels,  but inadequate hydro-
geologic data preclude  determining the source. In  this case, the
facility might be required to conduct a remedial investigation for
                                                                                     RCRA AMENDMENT EXPERIENCE    367

-------
 the area of the facility where the problem has been found. The
 remedial investigation may, in certain cases,  be  mandated  for
 the en tire facility.
   Finally,  difficulties in identifying and locating all solid  waste
 management units  within a facility often  are encountered. In
 some cases, facility owners and operators have not understood
 that units  which have not  previously been  considered in  the
 RCRA program, such as 90-day waste accumulation areas, non-
 hazardous waste disposal units and  elementary  neutralization
 tanks, are  now included in the PA/SI process. In other cases, the
 owner/operators were not aware of the existence  of abandoned
 units until the PA/SI investigators  questioned how wastes were
 measured at the facility prior to initiation of current management
 practices.  In answering these questions, which may require  the
 owner/operator to  interview current or past facility employees,
 the owner/operator may be surprised by the number of old  waste
 disposal units within the facility's boundaries. In the authors' ex-
 perience, it is not uncommon  for older, large chemical manu-
 facturing facilities, particularly those which  are  more than 20
 years old, to have 20 or more SWMUs which must be evaluated.
   This discussion has focused on  the critical obstacles exper-
 ienced while conducting some of the first PA/SIs  under RCRA.
 More experience by PA/SI investigators and an increased under-
 standing of the process by facility  owners  and operators  likely
 will serve to sharpen  the analytical  and implementation proced-
 ures to address these issues.

 CONCLUSIONS
   This paper has provided an  explanation of the  RCRA PA/SI
 process, likely sources of data and their uses in the process and
 some of the critical obstacles which have impeded the process.
   Several conclusions can be derived:
• The RCRA PA/SI process requires the use of as much relevant
  available data as can be reasonably assembled. Key informa-
  tion sources include the facility's Part B application, response
  to the regulatory authorities' request for SWMU information,
  RCRA and other environmental program  inspection files and
  previous CERCLA  investigation data. Facility owners and op-
  erators should be prepared to provide significantly more infor-
  mation in response to RCRA PA/SIs than to  the pre-HSWA
  permitting  process.
• The fundamental differences between RCRA and  CERCLA
  PA/SIs may  result  in different  outcomes. Facilities with rela-
  tively low MRS scores may nevertheless be  required to perform
  corrective measures under RCRA.
• Since the lack of dala during an RCRA PA/SI review can re-
  sult in mandatory requirements  to obtain the needed data, it is
  in the  best  interests of facility owners  and  operators to collect
  and provide as much relevant information as possible and to be
  involved early in the process.
REFERENCES
I.  McGraw, J.W.,  "Reaulhorization Statutory Interpretation #3: Gui-
   dance on Corrective Action for Continuing Releases," Office of Solid
   Waste and Emergency Response. U.S. EPA memorandum dated Jan.
   30, 1985.
2.  "RCRA   Preliminary  Assessment/Site   Investigation  Guidance
   (Draft)," Permits and Slate Program Division, Office of Solid Waste,
   U.S. EPA, Aug. 5,  1985.
3.  McGraw, J.W.,  "RCRA  Reauthorization Statutory  Interpretation
   #3: Immediate Implementation of New Corrective Action Require-
   ments," Office of Solid Waste and Emergency Response, U.S. EPA,
   memorandum dated Feb. 5, 1985.
368    RCRA AMENDMENT EXPERIENCE

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               Assessment of  the Application of RCRA Part 264
                       Standards  to  CERCLA Site Remediation

                                             Rebecca N. Fricke, P.E.
                                       EMPE, Inc., Consulting Engineers
                                               Nashville,  Tennessee
                 (Formerly: Technical Coordinator, Tennessee State Superfund  Program)
ABSTRACT
  The purpose of this investigation was to evaluate recent revis-
ions to the National Contingency Plan requiring application of
RCRA Part 264 standards to CERCLA site remediation. This
assessment was conducted in three phases. The first phase in-
volved review of the regulatory background to determine consis-
tency  with  existing  laws and regulations.  The second phase
assessed technical validity and identified technical problem areas
of the proposed policy with particular attention to requirements
of Part 264 Subparts F and G.
  The third phase investigated the cost-effectiveness of applying
RCRA Part 264 standards to CERCLA sites. Two National Prior-
ity List sites were studied. Costs were based on actual closure
costs under the original NCP policy and projected  expenditures
for closure under the revised policy  requiring application of
RCRA Part 264 standards. Effectiveness was quantified in terms
of risk reduction using the U.S. EPA Hazard Ranking System
and a computerized deterministic groundwater risk model for cal-
culation of lifetime mortality risks.

INTRODUCTION
   In the Feb. 12, 1985, Federal Register, the U.S. EPA proposed
revisions to the National Contingency Plan (NCP) which would
require that CERCLA (Superfund) remedial actions "attain or
exceed all applicable or relevant Federal public health or environ-
mental standards."  The U.S. EPA specifically explained in the
Federal Register that this includes compliance with RCRA Part
264 standards.1
  On  Oct. 10, 1985, Lee Thomas, U.S. EPA Administrator,
signed the final version of the revised National Contingency Plan.
The final version is virtually the same as the version proposed in
February with a change in the phrase "applicable or relevant"
to "applicable or relevant and appropriate." The addition of the
words "and appropriate" suggests that the U.S. EPA received
sufficient public  comment to recognize the problems associated
with strict application of Federal public health standards, includ-
ing RCRA Part 264.
  Among the comments received by the U.S. EPA was an exten-
sive study conducted by this author as an employee of the State of
Tennessee. The study specifically  assessed the  applicability of
RCRA Part 264 standards to closure of CERCLA sites. The pur-
pose of the following report is to relate the results of that study.
The study was broken into three phases; regulatory review, tech-
nical assessment and cost-effectiveness investigation.

PHASE I: REGULATORY REVIEW
  The pertinent laws and regulations reviewed in  association with
this issue were: (1) RCRA and its amendments;  (2)  RCRA Part
264 Standards for Owners and Operators of Hazardous Waste
Treatment,  Storage  and  Disposal  Facilities;  (3)  CERCLA
(authorizing the Federal Superfund program);  and (4) the NCP
used to direct Superfund activities. The review  of these laws and
regulations revealed information on the intentions of Congress
and the U.S. EPA.
  RCRA Section 3004 directed the development of regulations
for "treatment, storage or disposal of hazardous waste...as may
be necessary to protect human health and environment."3 The
same section also required that the Administrator shall, where
appropriate, distinguish in such standards between new and exist-
ing facilities. Through these sections Congress limited the regula-
tory requirements to that which is actually necessary for protec-
tion and provided recognition of the problems associated with
applying new standards to existing facilities.
  Part 264 standards were originally promulgated in the July 26,
1982, Federal Register. Section VI.A.I. of the Preamble listed
five important considerations involved in the U.S. EPA's strategy
for protection of groundwater: (1) avoid complicated uncertain
predictions;  (2) recognize  the  ability to  limit the  impact of
polluted groundwater by limiting use; (3) prevent stifling of inno-
vation; (4) provide timely  and expeditious regulation; and (5)
use limited financial resources in the most cost-effective man-
ner possible."
  Section 105  of CERCLA specified that the NCP provide a
means of assuring that remedial action measures are cost-effective
(Section 105(7)). The law also required the NCP to provide cri-
teria for determining priorities among releases  or threatened re-
leases and methods  for determining the appropriate extent of re-
medial action to be conducted, "including analyses of relative
costs" (Section 105(2,3,8))[5].
  The NCP was revised pursuant to CERCLA Section 105 to pro-
vide  for  Superfund activities.  It was published in the Federal
Register on  July 16,  1982, and became effective on Dec.  10,
1982.6'7 Section 300.68 defined the method of selection for remed-
ial action at a Superfund site.  The final selection criteria in the
NCP were dependent  on cost-effectiveness, i.e., the  lowest cost
alternative that is technologically feasible and reliable and which
effectively minimizes damage to and provides  adequate protec-
tion  of public health, welfare  or the environment."6 Thus,  the
three factors involved in the  cost-effectiveness selection were
cost, technical feasibility and adequate risk reduction. An ob-
vious question is "What is adequate?"
  The proposed revisions to the NCP published in the Feb. 12,
1985, Federal Register were signed into effect on Oct. 10, 1985.
The  final version was not available at the time of this writing.
U.S. EPA officials  state that the final version was virtually the
same as  the proposed version.  The final selection  process as re-
vised deleted the reference to the "lowest cost alternative" and
added a  requirement to attain  or exceed "all applicable or rele-
                                                                                RCRA AMENDMENT EXPERIENCE
                                                                                                                   369

-------
vant and appropriate" Federal public health  standards.2 Al-
though the term "cost-effective" remains in the selection criteria,
it is overridden by the requirement to attain or  exceed  public
health standards.
  The only situation in which cost would override the require-
ment to attain standards  is in "Fund-balancing" of Federal
Superfund dollars.  In  a situation where limited Federal Super-
fund dollars cannot take care of all sites requiring remediation
and the site represents less hazard than other sites, a lesser alterna-
tive can be accepted. Unfortunately, this waiver does not extend
to State Superfund programs with multiple sites and limited funds
or to Responsible Parties with multiple environmental problems
(possibly including more serious air, water, solid waste or radio-
logical waste problems).
  The elimination of cost-effectiveness as one of the major cri-
teria in  selecting remedial actions creates a conflict with the
apparent intentions of  Congress stated in RCRA, Part 264 (Pre-
amble), CERCLA and the original NCP

PHASE II: TECHNICAL ASSESSMENT
  In the preamble to the proposed version of the National Con-
tingency Plan, the U.S. EPA specified that RCRA  Part 264 stan-
dards would be considered relevant to response at CERCLA
sites.1 The purpose of this section is to assess the technical validity
of applying Part 264 standards to CERCLA sites. The two major
subparts of Part 264 which would be of importance to CERCLA
sites are Subpart  F—Groundwater Protection and Subpart F—
Closure and Post-Closure Standards.
  Subpart F—Groundwater  Protection  regulations  outline  a
three phase  program:  (1) detection monitoring; (2)  compliance
monitoring;  and (3) corrective action. The standards defined by
Subpart  F generally could be applied to CERCLA sites to help
establish the point(s) of compliance, location of monitoring wells,
frequency and duration of sampling, analytical parameters and
cleanup levels.  However, two areas of controversy exist  which
create severe problems in the utilization of the Subpart F stan-
dards in the CERCLA  program. These two areas are the analyti-
cal  requirements for the 375 constituents  in 40 CFR Part 261
Appendix VIII and the determination  of Alternate Concentra-
tion Limits (ACLs).
  The major problems associated with analysis of 40 CFR Appen-
dix VIII  constituents involve the high cost of analysis, technical
questions on the  validity of analytical techniques required,  in-
stability of some contaminants in water (which are therefore not
expected to appear in sample analysis) and frequency of analysis.
The U.S. EPA recognizes that these problems exist  and is making
efforts to address these concerns. The U.S. EPA has proposed a
revision to Appendix VIII to exempt requirements for 23 constit-
uents which are unstable in water for  for which no laboratory
standard for analytical calibration  has been developed.  Until
other concerns are resolved, the public  still is required to follow
the standards as written.'
  Subpart F—Groundwater Protection standards  provide three
bases for groundwater cleanup. The three cleanup levels which
are considered acceptable for groundwater under Subpart F are:
(1)  Background Levels, (2) Maximum  Concentration  Limits
(MCLs for Drinking Water Standards), and (3) Alternate Con-
centration Limits (ACLs, standards for compliance  at the site
based on acceptable levels of exposure some distance from the
site). It is anticipated that for most CERCLA sites it will not be
technically or economically practicable to achieve background or
MCL levels. Therefore, groundwater protection standards typic-
ally will be based on Alternate Concentration Limits.
  Section 264.94(b) outlines the standards used in the develop-
ment of ACLs. These standards provide a reasonable frame-
 work for information which should be collected.  However, the
 level of detail required by the U.S. EPA in the guidance docu-
 ment for ACLs' requires  time-consuming and burdensome data
 development and collection programs. For example, detailed in-
 formation is required on  exact waste quantities and types, de-
 finitive hydrogeologic data and specific lexicological effects (in-
 cluding synergistic effects of combinations).
   Although all of these pieces of information are important,  it
 is questionable whether precise  quantification  is possible and
 whether  it will appreciably improve assessment over that attain-
 able with more generalized information. It is technically incon-
 sistent to require extensive detailed  investigations to obtain high
 levels of confidence in some of the data used in an ACL determin-
 ation while recognizing the large number of speculative input fac-
 tors involved,  such  as meteorological conditions, population
 growth in the area and future uses of surface water and ground-
 water over the life of the site. It is suggested that a greater degree
 of consistency among the required  levels of  accuracy be estab-
 lished. The excessive  quantities of time and money currently re-
 quired for field and laboratory research could better be invested
 in remedial action activities.
   The RCRA Part 264 Subpart  G—Closure and  Post Closure
 standards provide general  closure performance standards. These
 standards emphasize  prevention and base closure  on a "to the
 extent necessary"  performance  criteria (Section 264.11).  This
 approach allows the most  cost-effective methods of closure to be
 used and provides for site specific interpretation of the "to the
 extent  necessary" terminology. In contradiction to this approach,
 Subpart  G references closure standards in Subpart  N—Land-
 fills where closure criteria  more specifically require use of a final
 cover which provides  long-term minimization  of liquid migration
 through the closed landfill  (Sections 264.310(a)).

  The  RCRA Guidance Document entitled  Landfill Design-
Liner Systems and  Final Cover, July, 1982,'° defines the min-
imum cover design considered acceptable. The required cover de-
sign consists of 2 ft of clay (with  a permeability of 10"7 cm/sec
or less) overlain with  1 ft of gravel (with a permeability of 10"'
cm/sec or greater) for  drainage. These two layers are covered by a
layer of soil (1.5 ft) and topsoil (0.5 ft) graded  and seeded to sup-
port vegetation.  For sites  having  an impermeable  underliner, a
synthetic membrane liner is required between the clay and gravel
layers.'"
   Strict application  of these RCRA Part 264 closure requirements
is not technically valid for  remediation of all CERCLA sites. For
many inactive hazardous substance sites, prevention or minimiza-
tion of infiltration is not a critical factor. Some situations where
sites would not greatly benefit by direct application  of these tech-
nology based standards are: (1) sites where waste materials are vir-
tually insoluble; (2) sites subject  to surface-water  flooding and
subsequent rising groundwater; and (3) sites located  in quarries or
hollows where underground springs feed into the waste. For these
sites, an impermeable  cap would not provide a cost-effective solu-
tion to the problem  and, for the second and third cases, would be
completely ineffective in preventing  liquid migration through the
site.
   It is  recommended that each CERCLA site be assessed to deter-
 mine the potential sources  of liquids which may reach the site and
 the potential impact of liquid migration through the site on pub-
lic health and the environment. Following this assessment, the
original language of  Section 264.11 concerning "to the extent
 necessary" should be considered instead of the strict infiltration
 technology based standards. Flexibility in closure design must be
 allowed in order to  provide appropriate and cost-effective remed-
 iation on a site specific basis.
370
       RCRA AMENDMENT EXPERIENCE

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PHASE III: COST-EFFECTIVENESS INVESTIGATION
  The purpose of this phase was to investigate the cost-effective-
ness of applying RCRA Section 264 standards and guidelines to
closure of CERCLA sites. The investigation was conducted using
two case studies: the North Hollywood Dump Site in Memphis,
Tennessee and the Hardeman County Dump  Site (also called the
Velsicol Chemical Corporation Dump) near Toone, Tennessee.
Both sites are on the CERCLA National Priority List and have
been closed under the original NCP policy. Three site conditions
were considered: (1) the original condition of the site when dis-
posal activities ceased prior to any remedial action activities, (2)
the condition of the site following closure under the original NCP
policy (as published on July 28,1982) and (3)  the condition of the
site if closed under the revised policy by following RCRA Part
264 standards and ensuing guidance.
   Costs for the cost-effectiveness determination  were  developed
 from actual closure costs under the original NCP policy including
 emergency  remedial  action  activities,  Remedial Investigation/
 Feasibility Study (RI/FS) development and covering/capping of
 the sites. Both sites under study have been closed under the orig-
 inal NCP policy, so actual costs for closure were available.11'12'13
 Estimated costs for closure under RCRA Part 264 included costs
 for emergency remedial actions, extensive RI/FS  development,
 ACL determination and a RCRA cap as required under Subpart
 G guidance. Costs for extensive RI/FS development and ACL de-
 termination for the sites were drawn from U.S. EPA Region 4
 estimates and work plans.14'15'16 Costs for RCRA capping activ-
 ities were based on  contractor estimates  for cap construction."
 The cost of the closure activities conducted when disposal ceased
 (nominal covering) was not taken into account for  this study,
 allowing the original condition to be the baseline for cost. Table 1
 provides a summary and comparison of costs for  closure under
 each policy for Hollywood and Hardeman County Dump Sites.
   The cost for closure of the Hollywood Dump using RCRA Part
 264 standards was estimated to be $9,212,300, over four times the
 cost for  the  current  closure  under  the original NCP  policy
 ($1,693,600). The largest cost increase was due to the addition of
 $5.07 million for RCRA capping activities.
   The difference  between closure costs for Hardeman County
 under the two policies was less dramatic, although  there was still
                           Table 1
  Summary and Comparison of Costs for Closure Under Each Policy for
           Hollywood and Hardeman County Dump Sites
  Site/Activity
                         Cost in Dollars
                    original       RCRA
                     Policy        Policy
                                                Increase in Cost3

                                             Dollars      Percent
HOLLYWOOD DUMP SITE
                       $  605,000   $1,963,500   $1,358,500  225%
RI/FS
Alternate Concentration
   Limit Determination       	b    1,091,800    1,091,800
                                             5,068,100
 Remedial Action

 TOTAL CLOSURE COST
                      1,080,600

                     $1,693,600
 6,157,000

$9,212,300
$7,518,700   "i<
-------
  The Hazard Ranking System was not developed to assess clos-
ure options and may not be sensitive enough to properly assess
effectiveness of the two policies. However,  it cannot be  disre-
garded. The model was developed by the U.S. EPA for the pur-
pose of assessing site hazards and is one of the nationally standard-
ized systems for prioritizing hazardous waste sites. Due to  the
many uncontrolled influences  on a site, the physical differences
between closure under the original NCP policy and closure under
the revised NCP policy may not be significant when incorporated
into the variable framework of the entire site surroundings.
   The second method used to assess effectiveness involved the use
of a computerized deterministic groundwater model to quantify
risk associated with each site in terms of annual and lifetime mor-
tality risk. The model used hydrogeological, demographic, chem-
ical, physical and lexicological data with  a one-dimensional ad-
vection-dispersion equation to project contaminant  concentra-
tions and levels of annual and lifetime mortality risk at selected
points." This groundwater risk model is  schematically depicted
in Figure 1. The acceptable level of lifetime mortality risk for this
study was based on the U.S. EPA's designated level of 10~4 to
 J0-8M-2*
   The hazards under consideration for each site were drinking
 water risk associated with contaminated groundwater, direct con-
 tact/erosion  hazards and  risk associated with  consumption of
 contaminated fish in nearby surface waters. Indicator parameters
 used for modeling were chosen based on toxicity, prevalence in
 the site  and relative mobility.  Chlordane was chosen as the indi-
 cator parameter  for Hollywood Dump Site.19-27 Carbon tetra-
 chloride, chloroform and heptachlor were chosen for Hardeman
 County Dump Site to respectively represent two highly soluble,
 prevalent compounds and one highly insoluble low level concen-
 tration compound.20-22
   Table 3 summarizes the results of this risk modeling effort for
 each site under the three site conditions being studied. A variety
 of site specific and technical information references was used to
 develop these results.19'20-22-27-"
   Drinking water risk for the Hollywood Dump Site was extreme-
 ly low under the original site conditions due to the deep layer of
 relatively impermeable clay beneath the  site. Since the original
                                                                                 INFILTRATION
                                                                                                  EXPOSED
                                                                                               POPULATION
                                                                    DEGRADATION,
                                                                    SOLUBILIZATION,
                                                                    LEACHING
                                               INGESTION
                                                          RISK
                                                                               ADVECTION,
                                                                               DISPERSION
                                                                               RETARDATION,
                                                                               DEGRADATION
                                                                             Figure I
                                                           Schematic Diagram for Groundwater Risk Model
                                                  risk was so low, mitigation would be unnecessary. Therefore, clo-
                                                  sure under either policy would not be cost-effective for mitigation
                                                  of this hazard. Alternatively, the drinking water hazard for the
                                                  Hazardous County Dump Site was so high that neither closure
                                                  method could adequately remediate the site to provide acceptable
                                                  risk levels. Therefore, the groundwater would still be unusable
                                                  and neither policy provided a cost-effective solution.
                                                    Since model calculations were based on  ingestion,  direct con-
                                                  tact hazards were not quantified.  Direct contact hazards were
                                                  considered to be completely mitigated under either  method by
                                                              Tible3
                   Summary of Risk Reduction Provided by Closure Options, North Hollywood and Hardenwn Count; Damp Sites
                    Site/Hazard Category
                                                       Maximum Lifetime Mortality Risk
                                                Original
                                                Condition
                                                                                                   Risk Reduction
                                              Original
                                               Pol icy
               (RCRA) Policy
                                                                                                 Policy
                                           R«vi««d
                                         (RCRA) Pol.o
North Hollywood Dump

   Drinking Water
   Direct Contact/Erosion
   Fiih Ingettion
       (Maximum Consumption)

Hardeman County Dump

   Drinking Water

       Carbon Tetrachloride,
         ecu
       Chlorolorm, CHCIj
       Heptachlor, C\oHjClj

   Direct Contact/Erosion

   Fish Ingellion
       (Worst Case Scenario
       Minimum Consumption)
                                               9.0 « 10'' J
                                               _ c

                                               3.9
-------
creating an earthen barrier which eliminates access to waste ma-
terials. For this hazard category, the additional cost for closure
under the more stringent and expensive revised policy is not con-
sidered cost-effective.
  The risk associated with fish ingestion at both sites under orig-
inal conditions was above the acceptable EPA  range of 10~6 to
10~8. Risk is decreased by closure under the original NCP policy
at each site but remains just above acceptable levels. The applica-
tion of RCRA Part 264 standards draws the risk value within the
U.S. EPA's acceptable range but results in a dramatic increase in
costs (see Table 1).
  At this point, the cost-effectiveness issue reverts to a more sub-
jective debate. The type of risk is a voluntary risk where the ex-
posed individual has been warned of the risk through posting of
signs and,  at Hollywood, has been limited by fencing. The risk
calculations were based on worst case conditions using high solu-
bility values and the unlikely consumption rate  for an individual
of 21  kg/yr of fish strictly from these waters every year for 70
years."  Recognizing  that the citizens have been appropriately
warned, that the risk values were purposely inflated and the risk
under the original NCP policy is close to the suggested U.S. EPA
risk range, it  is concluded that the  greatly increased cost asso-
ciated with closure under  the revised policy is not justifiable for
purposes of decreasing fish ingestion risk.
  Figure 2 provides a graphical representation of the costs  of
closure under the two policies versus the lifetime mortality risk
associated  with  fish ingestion at both sites and with drinking
water (carbon tetrachloride and chloroform) at Hardeman Coun-
ty.  The U.S.  EPA target risk range is shown for comparison.
Additional comparison is provided by the insertion of some "gen-
erally accepted" risks along the top of the figure."
CONCLUSIONS
  RCRA Part 264 standards provide a reasonable framework for
assessment and cleanup of hazardous waste sites but strict adher-
ence to standards and guidance eliminates the flexibility neces-
sary for remediation of CERCLA sites.  RCRA Part 264 Subpart
F—"Groundwater Protection"  standards  outline  a  rational
methodology for assessment  and remediation of groundwater
contamination.  However, compliance with  Appendix VIII  and
ACL determination requirements would be time consuming, cost-
ly and  technically questionable. If  problems in dealing  with
Appendix VIII analytical requirements and ACL  determinations
can be resolved, the approach outlined in Subpart  F would be de-
sirable for application to CERCLA  sites. RCRA Part 264 Sub-
part G—"Closure and Post-Closure" standards in Section 264.11
are reasonable but the standards specific to landfills in Subpart
N, Section 264.310 and  the ensuing  guidance  are too restrictive
to be technically valid for application to all CERCLA sites.
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                                                                                   RCRA AMENDMENT EXPERIENCE    373
-------
  The cost effectiveness of the original  and the revised policies
was investigated through estimates of cost and quantification of
risk reduction. It was determined that  the revised policy, requir-
ing application of  RCRA Part 264 standards and ensuing guid-
ance to CERCLA  sites, was not cost-effective for mitigation of
any of the hazard categories investigated at either site studied in
this report. This determination was based on the high incremen-
tal cost required to achieve little or no  incremental risk reduction
under the revised policy.
  The proposed revisions to the NCP required compliance with
"all applicable or relevant" Federal public health standards. The
final  revised version of the NCP changed these  words to read
"all  applicable or relevant  and appropriate."1  It  is  recom-
mended that RCRA Part 264 standards be considered as a refer-
ence rather than a requirement for CERCLA sites and that site
specific conditions dictate when  RCRA  Part 264 standards are
"appropriate."
REFERENCES
 1.  U.S.  EPA, "40 CFR Part 300, National Oil and Hazardous Sub-
    stances Pollution  Contingency  Plan—Proposed Rule,"  Federal
    Register, 50, No. 29. Feb. 12, 1985.
 2.  "Revised  National Contingency Plan Reflects  Proposal, Includes
    "How Clean is Clean Policy," Environmental Reporter, Oct.  18,
    1985, p. 1044.
 3.  "Resource Conservation Recovery Act of  1976," Public Law  94-
    580, 94th Congress, Oct. 21, 1976.
 4.  U.S.  EPA, "40 CFR  Part 264, Standards for  Owners and Oper-
    ators of Hazardous Waste Treatment Storage and Disposal Facilities
    —Final Rule," Federal Register, 47, No. 143, July 26, 1982.
 5.  "Comprehensive  Environmental  Response,  Compensation,  and
    Liability Act of 1980," Public Law 96-510,  96th Congress, Dec.  11,
    1980.
 6.  U.S.  EPA, "40 CFR Part 300, National Oil and Hazardous Sub-
    stance Contingency Plan—Final Rule," Federal Register 47,  No.
    137, July 16, 1982.
 7.  U.S.  EPA, "40 CFR Part 300, National Oil and Hazardous Sub-
    stances Contingency Plan—Notice of Effective Date,"  Federal
    Register 47. No. 238, Dec.  10, 1982.
 8.  Price, C.M., Assistant Administrator for Enforcement and Com-
    pliance Monitoring and  L.M. Thomas, Assistant Administrator,
    Office of  Solid  Waste  and Emergency  Response, "Enforcing
    Groundwater Monitoring  Requirements in RCRA Part  B Permit
    Applications," Memo to Regional Counsels, Regions 1-10; Air and
    Hazardous Materials Division Directors, Regions 1-10, U.S. EPA,
    Washington, D.C., Aug. 16,  1984.
 9.  Office of Solid Waste, U.S.  EPA,  Priliminary Draft—Alternate
    Concentration Limit Guidance—Based on Section  264.94(b)  Cri-
    teria, Nov. 1984.
10.  U.S.  EPA, Draft—RCRA Guidance Document, Landfill Design,
    Liner Systems and Final Cover, July 1982.
11.  Velsicol Chemical Corporation, "Hollywood Dump Site Accounting
    Records, Memphis,"TN, Dec. 21, 1984.
12.  Apple, J.M., Deputy Director, Division of Solid Waste Manage-
    ment, Nashville, TN, Interview on Mar. 29, 1985.
13.  Velsicol Chemical Corporation, "Miscellaneous  Project Status  Re-
    port,   February  1985;  Hardeman County Dump   Accounting,"
    Memphis, TN, Feb. 1985.
14.  E.C.  Jordan  Company, "North Hollywood Dump,  Supplemental
    Remedial Investigation/Feasibility Study Work Plan," prepared for
    NUS  Corporation (Contractor to  U.S.  EPA),  Portland,  ME, Feb.
    1985.
 15. E.C. Jordan Company. "Addendum to Work Plan for Supplemen-
    tal  Remedial Investigation/Feasibility Study,  North Hollywood,
    Memphis, TN," prepared for NUS Corporation (Contractor to U.S.
    EPA), Portland, ME, Jan. 1985.
 16. Jeter, C.R., U.S.  EPA Region 4 Administrator,  Letter  lo Saralee
    W.  Terry,  Director, Tennessee State Planning Office, regarding
    Hardeman County Dump Site, Jan. 4,  1985.
 17. Loyd, R.,  Loyd Excavating Company, Murfrecsboro,  TN,  Inter-
    view on Mar. 26, 1985.
 18. Tennessee Division of Solid Waste Management, "Hazard  Ranking
    System Work Sheets and Documentation Record; North Hollywood
    Dump Site," Aug.  9, 1982.
 19. E.C. Jordan Company, "North Hollywood Dump  Environmental
    Assessment and Action Plan, Task Element V-B, Corrective Action
    Alternatives  Report," prepared for NUS  Corporation (Contractor
    to U.S. EPA), Portland, ME, Jan. 1984.
 20. ERM Southeast, Inc., "Environmental Evaluation and Assessment
    of Control Measures at the Velsicol Disposal Site; Hardeman Coun-
    ty, TN," prepared for Velsicol Chemical Corporation, Brentwood,
    TN.Feb. 1985.
 21. Tennessee Division of Solid Waste Management, "Hazard Ranking
    System Work Sheets and Documentation Records, Hardeman Coun-
    ty Dump Site," Aug. 6. 1982.
 22. Rima, D.E., Brown, E.,  Litz,  D.F.G. and Law, L.M., "Potential
    Contamination of  the Hydrogeologic  Environment from the Pesti-
    cide Waste Dump in Hardeman County, TN," United States Depart-
    ment of the Interior, Geologic Survey, Aug. 1967.
 23. Broshears,  R.E., PhD Dissertation—Working Papers,  Vanderbilt
    University, Apr.  1985.
24. "Superfund to Determine 'How Clean is Clean' Using Wide Can-
    cer Risk  Range," Inside EPA  Weekly Report, 5, No. 48. Nov. 30,
    1984. p.  1 and 6.
 25. U.S. EPA,  "Effect of RCRA on Remedial Superfund Activities."
    Hazardous Site Control Division In-House Training  Outline, Jan.
    1985.
 26. "Effect  on  RCRA on Remedial Superfund Activities," Hazardous
    Waste Report. 6, Feb. 4, 1985.
 27. E.C. Jordan Company.  "North Hollywood Dump Environmental
    Assessment  and  Action Plan;  Task  Element V-A, Data Interpreta-
    tion Report," prepared for NUS Corporation (Contractor  to U.S.
    EPA), Project No.  0705-01, Portland, ME,  Jan. 1984.
 28. Lyman,  W.J., Reehl,  W.F. and Rosenblatt,  D.H., Handbook of
    Chemical Property Estimation  Methods, McGraw-Hill Book Com-
    pany, New York. NY. 1982.
 29. U.S. EPA.  "Water Quality  Criteria Documents;  Availability,"
    Federal Register, 45. No. 231, Nov. 28, 1980.
 30. Zeith, G.D.. DeFoe.  D.L.  and Bergftedt. B.J..  "Measuring and
    Estimating the Bioconcentration Factor of Chemicals in Fish," J. of
    Fisheries Research Board of Canada. 35, 1979, 1040-1048.
 31. Jacobson,  J.C. and Hastings, D.W., Population Projections for
    Tennessee Counties by Age and Sex;  1990 and 2000; University of
    Tennessee Department of Sociology, Knoxville, TN, May 1983.
 32. Wilson,  J.T. and  McNabb, J.F., "Biological Transformation of
    Organic  Pollutants in Groundwater," EOS, 
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                      Small  Quantity  Generators:  The  Maryland
                        Approach  to  Regulation and  Assistance

                                              Alvin L. Bowles, P.E.
                                Maryland Waste Management Administration
                                               Baltimore, Maryland
ABSTRACT
  With the enactment of the Hazardous and Solid Waste Amend-
ments of 1984 (HSWA), the universe of regulated hazardous
waste generators nationwide increased by 1,000%. The provis-
ions  for  small quantity generators are the prime reason for the
increase. While the U.S. EPA and various states rush to under-
stand the amendments and meet Congressionally mandated due
dates and requirements, the State of Maryland is actively im-
plementing its program.
  The Maryland Department of Health and Mental Hygiene re-
ceived the statutory authority for regulating small  quantity gen-
erators, that is, those generators producing 100  kg to 1,000 kg/
month of hazardous waste, in July  1984. This  authority came
from the State legislature. The law  is more stringent than the
HSWA provision,  and the  regulations supporting the  law are
more stringent than those proposed by  the U.S. EPA. These
facts, in addition to earlier effective dates for manifesting and
disposing at hazardous waste facilities, confuse the business com-
munity.  However,  the State developed an approach that helps
ease  the burden of notification and manifesting  requirements
and helps the small businesses to identify  their hazardous wastes
and means for disposal.

INTRODUCTION
  During the one-year grace period, from July 1, 1984 to July 1,
1985, provided in the legislation, the State  participated in  a multi-
media effort to inform the  newly regulated community and to
offer technical assistance and  information. The  approach in-
volved the Maryland Chamber of Commerce, the  University of
Maryland, the Controlled Hazardous Substances Advisory Coun-
cil, the Maryland Environmental Service and the Department of
Health and Mental Hygiene (DHMH).
  Through the production and distribution of  a  question  and
answer brochure,  mass mailings of regulatory requirements and
seminars with trade  associations  and county  governments, the
State reached the vast majority of affected businesses and munic-
ipal and  local governments. While the response may not  be con-
sidered favorable, it has been cooperative. The interaction with
the affected community has helped to identify problem areas in
existing regulations and has  led to regulatory amendments. Par-
ticularly  troublesome areas involved recycling  and  on-site treat-
ment at non-permitted facilities. The approach is proving  instruc-
tive to the regulatory agency and responsive to the needs of those
being regulated.

REACHING THE REGULATED
  The first response to the new legislation lowering the  exemp-
tion limit to 100 kg/month of generated hazardous waste was in
effect no response. Very few inquiries  were  received  after the
first  mass mailings. Notices of  new regulations and legislation
were probably treated as unwanted junk mail. Many were prob-
ably  never read by small business people.  When  the Adminis-
tration directly contacted the trade associations of some of these
small businesses, a frequent response was  "we do  not have a
problem; this legislation does not affect us."
  It was obvious to the Administration that the lack  of response
was not an indication of complete compliance, but  one  of not
understanding the breadth of the law. As a public agency, the
Administration could not wait for the law to become effective
and then enforce it against an unknowing regulated community.
That approach  can be very effective in getting attention and
compliance, but it creates resistance and ill will.
  During the initial phase of notifying the public, contact was
made with the Maryland Chamber of Commerce. It was felt that
the Chamber could further disseminate information to the busi-
ness  community. At the same time, the U.S. EPA was accept-
ing proposals for grants to assist in the dissemination of informa-
tion  about the small quantity generator requirements.  The
Chamber, along with the Maryland Environmental Service,  pro-
posed a multi-faceted program  involving the business, govern-
ment and university sectors with the Chamber taking  the lead.
Rather than draw on its resources only, the Administration joined
this effort. After several months of work, this group produced
a question and answer brochure that attempted to lead affected
persons through the maze of requirements of the new law. It was
distributed to nearly 7,000 businesses and organizations.
  In addition to the brochure and regulation mailouts, the Ad-
ministration made itself available to speak to various groups
and organizations to further explain the law  and requirements.
Also, a second part of the grant provided for technical assistance
by the University of Maryland.
  The total program is basically  structured as follows: the Mary-
land  Chamber  of Commerce is the lead agency since it has the
primary contacts with the business community. The Maryland
Environmental Service (MES), which is an agency  of the  De-
partment of Natural Resources, works closely with the Chamber
since it, too, has many contacts with industry; MES  also admin-
isters the grant. Also working with these two groups is the Con-
trolled Hazardous Substances Advisory Council, which is the
State advisory board for hazardous waste. It was reasoned  that,
with  the non-governmental groups  in the lead, the business com-
munity would be more receptive to the assistance.
  The role of the  Waste Management (WMA) is to explain the
requirements and  assist the business sector to come into com-
pliance. The University's role is to provide technical assistance to
business  on an industry-wide rather than individual basis: for
                                                                           STATE, REGIONAL & LOCAL PROGRAMS    375
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example, the University is prepared to work on problems of the
drycleaning industry, but not for individual drycleaning estab-
lishments. Hopefully they can study two or three representative
facilities  and develop solutions  that can  be  applied  industry-
wide.
  The business community is not the only regulated sector.  Fed-
eral,  State and  local government agencies  also  are  affected.
County school systems generate hazardous waste in their science
laboratories and maintenance shops.  State, county and munici-
pal maintenance shops generate hazardous waste from automo-
tive maintenance. People in these agencies usually do not apply
the requirements to themselves and certainly do not budget for
the increased costs of hazardous waste management.

PROBLEM AREAS
  The most significant problem for the small quantity generator
consists of two parts: understanding the  requirements and deal-
ing with the paperwork.  RCRA was the most massive regulatory
program ever, prior to  the HWSA of 1984.  The amendments
have expanded RCRA even more. Although only a small portion
of the Act affects  the small quantity generator, it is enough to
be overwhelming.  Small business people in  particular are  not
familiar with environmental requirements. They are not prepared
to deal with the information needs and the paperwork.  They sel-
dom have technical backgrounds or knowledgeable staff to coor-
dinate the paperwork.
  One must add that the increase in paperwork affects  the regu-
latory agency too.  All of the  manifests go to an agency for re-
view. The WMA receives 30,000 manifests per year as of FY
85. Estimates of the increase  for FY86 range from 10,000 to
80,000 manifests. These higher  numbers will  have a significant
impact on personnel resources.
  A second problem is the amount of helpful  information avail-
able.  One would think that more information on a topic would
be better. With  the small quantity generator requirements, this is
not the case. Primarily,  the problem  lies in the fact that Mary-
land implemented its own regulatory program  before RCRA was
enacted. Businesses, through their trade organizations, receive in-
formation on the Federal program.  At the same time, they re-
ceive  information on the State program. Since the two programs
are somewhat different, the business person becomes  confused
or frustrated.
  Recycling of hazardous waste is also  complicated. State  law
requires that hazardous wastes being recycled must be treated as
hazardous waste. In the case  of listed wastes and sludges,  they
must  be  manifested and transported by  certified haulers. The
statute also can be read to include characteristic wastes under the
transportation requirements. There is also a very thin-line distinc-
tion between what  is a recycling activity and what is  a treatment
activity.  Recycling  is  exempt  from permitting  activities  while
treatment must go  through  the entire RCRA  review and permit
process.  The  WMA  encourages recycling  and  makes  every
attempt to be open to new ideas.
  A good example  of the difficulty with recycling involved a new
car dealer association. The question was whether or not the body
shop  was a TSP facility. One dealer  had installed a solvent re-
covery still in  the  autobody shop. The distillation process was
very simple, consisting of a hot oil jacketed still and a condenser;
4 to 6 gal of paint solvent can be distilled in four hours. The clean
solvent is reused in paint or reused as a degreaser  in the shop.
The still bottoms are removed and shipped as  hazardous waste.
No off-site solvent is distilled.
  A fourth problem area that has serious potential is the existence
of numerous exempt sources.  When hazardous waste is shipped
from  a generator, it must go to a RCRA-permitted facility.  Ex-
empt quantities (that are non-liquid) may go to a permitted san-
itary landfill.  Exempt generators,  such as schools  and county
garages, may not generate more than 100 kg/month or  accumu-
late that quantity on an individual basis. In the aggregate, they
likely do exceed the exempt limit.
  Existing  regulations  prohibit the establishment  of a central
collection center unless it is a RCRA-permitted facility. In theory,
this center could serve as the generator. For example,  all the haz-
ardous waste from the school system would go to the central loca-
tion  where it is properly packaged and transported  to a proper
treatment, storage or disposal (TSD) facility. This approach can-
not be  used in Maryland because the central site is, in effect, an
unpermitted TSD facility.  Schools, being  individually exempt,
may then dispose of their hazardous  wastes in  municipal  land-
fills. Thus the move to more properly manage hazardous waste
from numerous small sources is abridged.
  Another problem  that is closely related to the previous one in-
volves the transporters. Maryland regulations allow for stoppage
of a vehicle hauling  hazardous waste for no more than 72 hr at a
permitted TSD facility. The waste load must be transported to a
facility or out-of-state within 5 days from initial pickup. Haul-
ing companies are having difficulty meeting these requirements
because of the dispersed location  of small generators and the
small quantities of generated waste. It takes longer than the per-
mitted  periods of time in the rural areas of the State to collect a
full truck load of waste.
  One  last area that may become a problem is transportation
and treatment/disposal capacity. Several trade organizations and
counties have raised the question: Is there sufficient capacity to
handle the additional hazardous waste? That is a difficult ques-
tion to answer.  Although the State has no hazardous waste  land-
fills and only three  TSD facilities that accept off-site generated
waste, there does not seem to be difficulty in shipping waste. The
real question may be a related question: Is there an economical
means  for  transporting/disposing of hazardous waste?  This
question is more pertinent  to the  small  generator,  and partic-
ularly so to a small generator in a rural area. The owner can ship
the waste if willing to pay the price. The capacity is there but per-
haps not within the financial means of the generator.

ANSWER TO PROBLEMS
  It is  very difficult to ensure that all the regulated community
understands the regulatory requirements.  As described previous-
ly, Maryland's  approach to multiple  mailings and seminars or
talks to specific groups is  the  most  practical approach. Keep-
ing the message simple and to the point is imperative. A  regu-
lated business owner need only hear what the State requires him
to do.  The owner does not need a discussion of what the U.S.
EPA and the other  states are doing. Information sent to a  busi-
ness  should provide the following: (1) regulatory requirements;
(2) types  of waste that the  business may generate that are haz-
ardous; (3) application packets for U.S.  EPA ID numbers; (4)
how to order and use manifests; and (5) telephone numbers for
help. Also, the State agency should  have listings of certified  haul-
ers and TSD facilities.
  The  anticipated increased volume of manifests did generate
concern in the WMA about how to cope with the increase. One
particular area where the number of manifests can be reduced is
the batch toll operation. This operation involves a company that
in effect leases  cleaning/degreasing solvents to commercial con-
cerns such as auto maintenance shops. When the material needs
to be replaced, the  company delivers new solvent and removes
the old. The company claims that  the material is not generated
by the  commercial  shop but  that it is owned by the company.
Thus, the company is the generator.
376    STATE, REGIONAL & LOCAL PROGRAMS
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  If the commercial shop or user is considered the generator, it
needs a fully completed manifest with each shipment of used sol-
vent. The WMA is not  anxious to receive possibly  50,000 to
60,000 additional manifests for this type of operation from one
company. The State, after review of its statutes and regulations,
reached a compromise: the company distributing the solvent is the
generator; the generator may use one manifest  per  collection
truck per day; each pickup must be recorded on the manifest, but
the name and location of the pickup is not needed; each solvent
(if more  than one at a pickup site) must be listed individually;
daily totals must be shown on the manifest; and  the agreement
only applies to generators of less than 1,000 kg/month  of haz-
ardous waste. It is estimated that this method of handling the
manifest  will reduce the  number of manifests by 80%  for one
company.
   Recycling activities have required extensive review of the Mary-
land statute and regulations along with the redefinition  of solid
waste. The WMA sought the advice of the Office of the Attorney
General in determining whether or not an  auto body shop redis-
tilling its own solvents was a treatment facility. The factors lead-
ing to the determination of whether or not it was  a TSD facility
and required a permit were: the distillation product is reused
directly in the original process;  it is generated on-site;  the still
bottoms  are treated as hazardous waste; and used solvent is not
stored before recycling.
   This decision fits very well into the redefinition of solid waste
as promulgated by the U.S. EPA on  January 4, 1985 (40 CFR,
Parts 260-266). However, there  are parts  of the new definition
that are difficult to understand and apply. It is going to be partic-
ularly difficult to apply the regulations to the small quantity gen-
erator.
   A question being asked is: "Can the waste from multiple small
sources in one system be collected at a central location and ship-
ped from that point?" The argument raised in favor of this con-
cept is that it is efficient to ship from one central location and
that it will provide for environmentally safe disposal. It is argued
further that, left to individual means, each school probably will
dispose of hazardous waste in municipal  waste  sites. This dis-
posal practice certainly is legal under the small quantity generator
regulations, but it defeats their intent.
   An answer is to allow diverse generators of a single school sys-
tem or government agency to centralize waste collection  without
requiring the central location to become a permitted TSD facility.
County and municipal governments are reluctant to pursue a haz-
ardous waste facility permit. This issue is under review.
  Another of the problems that does not have a definite solution
is that of stoppage. An attempt has been  made to allow longer
stoppage periods in Maryland (7 to 10 days). Consideration has
been given to  providing for stoppage or holding  terminals that
would be exempt from the need for a permit. These terminals
would be required to have a bond and to meet certain hazardous
waste management requirements. However,  no  transfer could
take place at the terminals.
  There are problems with this approach because enforcement of
storage times would be difficult. Also, haulers may choose to
use large trailers  to collect waste since no transfer at the terminal
would be permitted. This system could cause a safety hazard by
having large trailers  full of hazardous waste making collection
runs.  The WMA decided to leave its regulation unchanged and
review problems on a case-by-case basis.
  If there is a problem with TSD capacity, the business commun-
ity must solve it. The question is raised: "Why doesn't the State
open facilities?" The State, through MES, unsuccessfully made
an attempt to operate a hazardous  waste landfill. For  various
reasons, it could not compete with industry and was closed. The
difficulty  with bringing industry into the off-site TSD facility
business is that the cheap and easy method of landfilling is no
longer a viable alternative. A new hazardous waste landfill will be
extremely difficult if not impossible to build. The other methods,
incineration and chemical treatment or recycling, are expensive
and technology-intensive. Supply and demand will create the in-
centive and wherewithal to deal  with any capacity problems. A
market is emerging.

CONCLUSIONS
  The small quantity generator requirements appear massive on
first impression. With work, they can be made less imposing and
can be presented to  the generator in understandable language.
Every effort needs to be  made to accommodate  recycling and
disposal needs within the regulations. Waste from small quantity
generators can be minimized as evidenced in the recycling efforts
of the automobile dealers.  If an agency takes too strict a posture,
the  small quantity generator may seek out environmentally dam-
aging or illegal alternatives for disposal.
                                                                               STATE, REGIONAL & LOCAL PROGRAMS    377
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                           Siting  Efforts  in  Southern California

                                                  Kieran D.  Bergin
                       Los Angeles County  Hazardous  Waste Facility  Siting Project
                                                Whittier, California
INTRODUCTION
  The management of hazardous waste in Southern California is
closely linked to the history of the  development of this area.
Southern California, particularly Los Angeles County, developed
extensively following the turn of the century with  an even speed-
ier pace after the second World War. There were  several factors
that predisposed the area to rapid development at this time. The
first  was the fact that large quantities of water  were available
throughout  Los  Angeles  County,  primarily from imported
sources. In the  1910s, the  City of Los Angeles constructed an
aqueduct to bring water approximately 270 miles from the Owens
Valley (in the Eastern Sierra Nevada Mountains) to Los Angeles.
In the 1930s work began on  an aqueduct from the Colorado River
(at the California-Arizona border) to move water  approximately
300 miles across the Colorado desert.
  A second factor that was  very important in the region's growth
was the presence of large petroleum deposits. Development of oil
began around the turn of the century in Los Angeles and financed
a great deal of the public improvements that were constructed in
the form of aqueducts. Oil  also provided a great deal of the eco-
nomic vitality of the region.
  A third factor that played a very large part in the development
of the  region was  its climate. The Mediterranean-type climate
of Southern  California was  an excellent place for testing aircraft.
This  led  to  a cluster of aircraft manufacturers, including the
Douglas Aircraft Company, Northrop, Lockheed and Hughes.
This industry, which was very important during the second World
War, eventually led to a high concentration of technical talent in
the aircraft and,  later, the  aerospace  industries and fostered the
development of the aerospace, defense and transportation indus-
tries as major components of the Southern California economy.
  The last factor that contributed to  the development of South-
ern California was a general attitude  on the part  of government
that government intervention was not only acceptable, but neces-
sary, in order to develop and foster the economy of the area. This
philosophy led to government involvement in the development  of
aqueducts,  in the dredging and  filling of harbors  around the
Ports of Los Angeles and Long Beach and in the construction  of
an extensive system of  flood control that allowed the develop-
ment of many otherwise unavailable areas.

HAZARDOUS WASTE DISPOSAL HISTORY
  The  history  of hazardous waste disposal in  Southern Cali-
fornia is  not as well recorded as that of other major develop-
ments.  However, evidence  from the unearthing of old industrial
sites and from the legacy of past improper disposal gives us a rea-
sonably good idea of what  occurred. Prior to 1965 most of the
hazardous wastes generated by the region's industries were dis-
posed of at the point of generation, offshore or into the closest
municipal landfill. Around 1965 three Class I disposal sites were
opened in the Palos Verdes Peninsula, the San Jose Hills in the
City of West Covina and in the Santa Monica Mountains west of
the San Fernando Valley. These sites, which were allowed to take
virtually all wastes except  radioactives and explosives,  became
the backbone of the disposal system for hazardous waste within
the County for approximately 20 years.
  During this same time period, the nation was becoming more
conscious of the environmental consequences of its actions and
began, through a series of Federal Laws, to clean the nation's air
and water. Major federal legislation in these areas was enacted in
1970 and 1972, respectively. These laws, which were designed to
protect the air and water, did so by concentrating pollutants that
formerly were dispersed and placing them upon the land.  In the
late 1970s, it was becoming increasingly obvious that all three en-
vironmental media (air, water and land), needed protection, and
that careful attention had to  be paid to pollutants going into all
three.

RCRA IMPACT
  In 1976 Congress passed the first version of RCRA which made
much progress in regulating hazardous wastes but, unfortunately,
did little to force hazardous wastes to go to treatment facilities.
In  1984, with the  major  amendments to  RCRA,  Congress
changed the law radically and will require virtually all hazardous
waste to receive treatment prior to land disposal.
  In 1980 two of the previously mentioned sites, Palos Verdes
and Calabasas, were dosed. The first because it was full and the
second because the  geologic requirements  for hazardous waste
disposal sites had changed (whereas the geology  of the site had
not). This left Los Angeles County heavily dependent upon one
hazardous waste disposal site, the BKK Landfill in West Covina.
Pressure immediately began to build; the citizens of West Covina
wanted closure of this landfill, which they felt represented an ex-
cessively large threat to the community.
  In early 1981 the Environmental Protection Agency, the State
Health Department,  the State  Water Resources  Control Board
and the Counties  of Ventura, Los Angeles, Orange, San Diego,
Imperial, Riverside and San Bernardino banded together to form
the Southern California Hazardous Waste Management Project.
The initial charge of this study was to find replacement disposal
sites for BKK.

Search for Alternatives
  There was soon an increasing awareness at the State level that
treatment without disposal would be unacceptable both environ-
mentally and politically. The efforts of the Southern California
378    STATE, REGIONAL & LOCAL PROGRAMS
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project were redirected to include substantial work toward getting
waste treated  close to its generation. This included performing a
detailed waste characterization  and facility  needs  assessment,
developing goals and policies for hazardous waste management
and developing detailed siting criteria for hazardous waste treat-
ment and disposal facilities. However, the redirected project was
unable to come to terms with the hard practical question of where
to site hazardous waste treatment and disposal facilities.

BKK Closes to Hazardous Waste
  At that time it was assumed that there were  many locations
where hazardous waste treatment could be performed  and that
the private sector would  be  willing to establish treatment facil-
ities in Southern  California. As it turned out, the extremely vola-
tile nature of the business  of hazardous  waste management,
coupled with the lack of any firm guarantees of business  for
treatment facilities, has thus far prevented  the establishment of
any major hazardous waste treatment facilities in Southern Cali-
fornia. Therefore, when the BKK Landfill announced  that  it
would cease accepting hazardous waste at the end of November
1984, the Board of Supervisors of Los Angeles County asked the
Los Angeles County  Sanitation Districts and the Department of
Public Works to prepare a report listing specific locations that
would be suitable  for hazardous waste treatment and disposal
sites. The Board initially asked  for this report  in 90 days and
appropriated a total of $500,000 for this effort.

TASK FORCE ESTABLISHED
  The task force for this project began screening to eliminate
grossly unsuitable  areas  from any further consideration. This
process was carried out for both treatment and disposal facilities.
For treatment facilities, it was decided that compatible land use
was the most  important criterion and, therefore, the search cen-
tered on the industrial areas in the County. Other significant fac-
tors entering  into the siting  of a treatment facility were access
(primarily by road), isolation from homes and availability of ade-
quate sewer connections to remove treated waste water.
  After the industrial areas were screened using these criteria, an
industrial real estate  firm was hired to find available properties
between 5 and 15 acres in size that potentially could be used as
waste treatment facilities. The realtor reported that there were 56
such properties available. The project then  studied these further
and came out with a list of the best 20.
Potential Sites Identified
  Concurrent with the search for waste treatment facilities, a
search for disposal sites in the County was done.  Los Angeles
has a  population of approximately 7.5 million  people,  and a
variety of land uses preclude waste disposal sites in  all but a few
areas of the County. State law requires that waste disposal facil-
ities be at least 2,000 ft from any homes. The central part of Los
Angeles  County is occupied primarily by National Forests which
are excluded from consideration  by Federal  law.  In addition,
most of the valleys are geologically unsuited for hazardous waste
disposal.
  Using these criteria, eliminating earthquake zones, flood-prone
lands and significant ecological areas, the project quickly focused
on eight areas as potential sites for  hazardous waste disposal.  The
disposal operations that are envisioned in these areas would be for
treated residuals only  and would  not take raw,  untreated haz-
ardous waste. The sites would accept no liquids and would be
specially engineered and operated to keep rainwater infiltration to
a minimum.
  Preliminary geologic investigations of available literature were
performed on all eight perspective locations.  One piece of land,
on County-owned property, was drilled to determine if the sub-
surface met the promise that the surface provided. At the time of
this writing, attempts are being made to obtain permission to drill
three other pieces of property.
CONCLUSIONS
  In 1985 several  of the  counties around Southern California
formed a Joint Powers Agency dedicated to better management
of hazardous wastes throughout the region. At the time of its in-
ception, Los Angeles County (which  dominates the region  in
terms of waste generation)  declined to join this Joint Powers
Agency. The regional political dynamics of Southern California
make it imperative for Los Angeles to have a system in place for
managing its wastes. Unless this happens, other political jurisdic-
tions will be reluctant to site hazardous waste management facil-
ities, fearing that these will become magnets for waste from Los
Angeles.  Therefore, it is critical that Los Angeles County lead
the area in terms of hazardous waste management in  Southern
California.
                                                                               STATE, REGIONAL & LOCAL PROGRAMS    379
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                    The California Site Mitigation  Decision Tree

                                                   Paul W. Hadley
                                                    William Quan
                                        Toxic Substances  Control  Division
                                   California Department of Health Services
                                              Sacramento, California
ABSTRACT
  The California Department of Health Services has developed a
process that provides state decision-makers with a consistent ap-
proach to  mitigating abandoned  and uncontrolled  hazardous
waste sites.  This process, called the California Site  Mitigation
Decision  Tree Process, contains unique elements  that:  specify
how exposure criteria, known as Applied Action Levels (AALs),
will be developed; identify site characterization data that must be
collected or developed; present  preferred data collection strate-
gies  and  techniques;  and set appropriate site mitigation  criteria
for various  alternative remedial actions. Selection of the best
alternative remedial action is based upon technical and scientific
evaluations  concerning  protection of  public health and  the
environment while considering other nontechnical factors such as
demography, land use and input from the public.


INTRODUCTION
  The mitigation of  abandoned  and uncontrolled  hazardous
waste sites is a challenge faced  by federal, state and local agen-
cies across the United States. The  citizens of California demon-
strated their concern and commitment to facing this challenge
by overwhelmingly  passing Proposition 27, the $100 Million
Hazardous  Substance Cleanup Bond Act of  1984. With the pas-
sage  of Proposition 27, the Toxic Substances Control Division
(TSCD) of the California Department of Health Services (DHS)
was designated the lead state agency responsible for investigating,
characterizing and mitigating abandoned and uncontrolled haz-
ardous waste sites ranked on the California  Site  Priority Rank-
ing List (SPRL).
  To facilitate expeditious and  consistent mitigation of sites on
the SPRL as well as other  unlisted  hazardous  waste sites,  the
Alternative   Technology  and   Policy  Development  Section
(ATPDS) of TSCD developed the California  Site Mitigation De-
cision Tree Manual.  The Decision Tree Manual provides stale
decision-makers with a technical guidance document that pre-
sents a systematic and standardized  method  for evaluating the
existing and potential public  health and environmental risks asso-
ciated with  hazardous waste sites  under  various alternative re-
medial actions.
THE DECISION TREE PROCESS
  The Decision Tree Process,  as presented in the Decision Tree
Manual, consists of five basic components:

• Preliminary Site Appraisal
• Site Assessment
• Risk Appraisal
• Environmental Fate and Risk Determination
• Development of Site Mitigation  Strategies and  Selection  of
  Remedial Action
  Each of  these five basic components is made up of several
steps, procedures and decision points developed to provide a tech-
nical and scientific basis for selecting remedial actions to miti-
gate hazardous waste sites. Each of the five basic components
of the Decision Tree Process is discussed below. Also presented is
a discussion of the relationship between risk management and risk
appraisal under the Decision Tree Process.

Preliminary Site Appraisal
  The Decision Tree Process is activated through discovery and
ranking of an abandoned or uncontrolled hazardous waste site
on the SPRL. The procedures used  by the State of California to
assign a numerical score for migration potential and public health
and environmental impacts to a site are identical with those devel-
oped by the U.S.  EPA. However, once the site has been scored
according to its potential public health and environmental im-
pacts, the California procedure assigns a final rank to the site
after also developing a preliminary cost/benefit  analysis. Thus,
DHS can more efficiently manage its resources by focusing initial-
ly on those sites that can be most effectively mitigated.
  Those hazardous  waste sites with sufficiently  high numerical
scores for migration potential and public and environmental im-
pacts are submitted to the U.S. EPA to be placed  on the National
Priority List (NPL). Funds made available through passage of
Proposition 27 can be utilized lo provide the Slate's share of costs
associated with NPL sites within California. By utilizing  both
state and federal Superfund processes, DHS can direct stale re-
sources to mitigate those sites with  the greatest potential public
health benefits per unit cost and can still direct federal resources
to those sites that require the greatest costs.

Site Assessment
  Under the Decision Tree Process, hazardous waste sites are re-
garded as  consisting of source materials (including wastes and
contaminated soils) and exposure pathways that  facilitate trans-
port of hazardous chemicals from the  location of the source to a
point of exposure. Thus, there are two major objectives of the
Site Assessment component.  The first objective  is to character-
ize the nature and extent of chemical contamination in all perti-
nent media of exposure. The second objective is to characterize
the  migration or accumulation of chemical contaminants along
pertinent exposure pathways.
  The first objective of the Site Assessment component is  satis-
fied through the collection and chemical analysis of samples of
the  various exposure media to determine the extents of contam-
ination and concentrations of chemicals of concern. Guidance is
offered throughout the Decision Tree  Manual on preferred sam-
pling, handling and analytical techniques. A section on the neces-
sary quality assurance/quality control (QA/QC) procedures to
verify the accuracy and representativeness of chemical analyses
is also included.
380   STATE, REGIONAL & LOCAL PROGRAMS
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  With regard to the  second objective, pathway characteriza-
tion, the Decision Tree  Manual includes discussions  of those
data, parameters and interpretations necessary to characterize a
pathway. The manual also presents preferred and recommended
techniques  for  sample  collection and  analysis.  For  example,
recommended components of a drilling program may include, as
appropriate, continuous  coring, collection and analysis  of un-
disturbed samples, as well as paired borings where the strati-
graphy and observations  made in the first boring can focus and
direct the collection of  samples for chemical analysis  in the
second. With regard to groundwater investigations, discussions of
preferred data collection techniques include drilling methods, well
and piezometer design, construction, development and sampling.
  The representations of transport pathways are referred to as
modules and are developed from data collected in the Site Assess-
ment Phase. Each module may consist  of observations,  deduc-
tions, calculations, numerical models  and professional judgments
that allow the analyst to make scientifically and technically de-
fensible statements and conclusions regarding the behavior and
transport of chemical contaminants at the site.

Risk Appraisal
  In the  third component of the Decision  Tree  Process,  Risk
Appraisal, a basis is developed for evaluating risks  of adverse
toxicological effects associated with exposures to chemical con-
taminants identified at  a given site. The basis for evaluating the
risk of an adverse toxicological effect is  a  numerical  criterion
known as the Applied Action Level (AAL).
  The key to understanding the risk appraisal concept is that an
AAL is an exposure criterion. An AAL is developed in  a consis-
tent and documented manner  as  specified in the  Decision  Tree
Manual and is intended for use only to evaluate  potential  risks
of adverse effects associated with chronic, low level exposure to
toxic chemicals on hazardous waste sites. The appropriate loca-
tion for evaluating potential risk through the Decision Tree Pro-
cess is at the terminus of an exposure pathway where a sensitive
organism, referred to as a sensitive biological  receptor, may come
into contact with toxic chemicals associated with the particular
hazardous waste  site. An AAL is a media-specific, biological re-
ceptor-specific  criterion that is applicable statewide to  evaluate
the risk of an adverse toxicological effect from exposure to toxic
chemicals.
  The formal evaluation of risk associated with exposure to con-
taminants  on a hazardous waste site can be accomplished by
applying a series of three risk appraisal tests. These risk appraisal
tests evaluate single medium/single chemical exposure,  multiple
media/single chemical  exposure  and multiple media/multiple
chemical  exposure,  respectively.  Risk  appraisal  tests  are  per-
formed first to determine if existing  exposures of biological re-
ceptors present a risk of an  adverse  toxicologic effect. If so,  a
risk management process should be initiated to mitigate  that risk
by an interim remedial measure.
  The first test in the risk appraisal process compares the level of
exposure in a medium,  abbreviated as Cmedium, with the AAL
criterion for that medium, AALmedium- The first risk appraisal
test is:
 If
                   medium
(1)
then the test fails, a sensitive biological receptor is considered to
be at risk of an adverse impact and a risk management process
should be initiated.
  The second test in the risk appraisal  process considers risks
posed to a sensitive biological receptor  through exposure to a
         single contaminant via all  pertinent media of exposure. The
         second risk appraisal test is:
         If
                      medium  =  1
                             medium
                           AAlmedium
                                               >  1,
                                                                  (2)
         then the test fails, a sensitive biological receptor  is considered
         to be at risk of an adverse impact and a risk management pro-
         cess should be initiated.
           The third test  in  the risk  appraisal mechanism  determines
         whether a sensitive biological receptor may be considered at risk
         due to exposure to an aggregate of substances that produce the
         same toxic manifestation. Lacking data that are contradictive of
         the assumption of additivity, the third test in the risk appraisal
         mechanism is:
         If
                    Sub = 1  Medium  = 1
                                  medium.  sub
                                             sub
                                                           >  1,
                                                                  (3)
then the test fails,  a sensitive biological receptor  is considered
to be at risk of an adverse impact and a risk management process
should be initiated.

Environmental Fate and Risk Determination
  The fourth component of the Decision Tree Process, Environ-
mental  Fate and Risk  Determination,  is designed to evaluate
potential future risks associated with a particular  site. The en-
vironmental fate and transport modules  developed from  data
collected under the  Site Assessment component are employed in
the fourth  step to project  environmental  impacts  from current
conditions  associated with  the site to future conditions on and
distant  from the site at points  where sensitive biological recep-
tors might be exposed to contaminants.
  The three tests of the risk  appraisal  mechanism  again are
applied to  evaluate whether sensitive biological receptors could
be at risk in the future, utilizing projected concentrations in the
various exposure media. Thus, the potential risks associated with
contaminants on a  waste site are evaluated for existing current
exposures under the Risk Appraisal Component and for possible
future exposures under this step, Environmental Fate and  Risk
Determination. If a sensitive biological receptor is evaluated to be
at risk through either risk appraisal or risk determination, a risk
management process should be initiated.

DEVELOPMENT OF MITIGATION STRATEGY
AND SELECTION OF REMEDIAL ACTION
  The first four components of the Decision Tree Process focus
on evaluating risks associated with exposure to  contaminants
from hazardous waste sites. Once it has been determined that a
sensitive biological receptor currently is, or will be at risk of being
adversely affected, mitigation of that risk should be investigated.
The development, evaluation and  selection  of remedial alterna-
tives to mitigate that risk are discussed in  this section. Although
this component is presented as the final section of the Decision
Tree Manual, activities associated  with  development,  evaluation
and selection of remedial alternatives actually should  begin with
the second  component,  Site Assessment,  and run concurrently
with the subsequent three components.  In this manner, remedial
alternatives can be evaluated and screened throughout the site
assessment and characterization project as constraints and limi-
tations  of various alternatives become  evident enough to justify
exclusion from further  evaluation. As the extent of contamina-
tion in each medium of exposure and the  processes associated
with transport and accumulation of contaminants along exposure
                                                                               STATE, REGIONAL & LOCAL PROGRAMS    381
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pathways become better  understood,  likely  remedial  strategies
and alternatives  can be  selected for further evaluation,  and
unique data needs can be met concurrent with other site assess-
ment activities.
   The contents of the last component have  been derived  prin-
cipally from those guidance documents available on  the  U.S.
EPA's feasibility study process. The Decision Tree Process, there-
fore, is consistent with the U.S. EPA's specified process of select-
ing remedial alternatives for federal Superfund sites. The Decis-
ion Tree Process also is consistent with  the  remedial investiga-
tion process set  forth in U.S.  EPA guidance documents; sile
characterization activities are designed to develop the data base
necessary for selecting the technically appropriate remedial action
plan.

Risk Management and Risk Appraisal
   The Toxic Substances Control  Division (TSCD) of  DHS is
organized into a central headquarters and three regional offices.
In general, those issues and problems that require uniform state-
wide solutions  are referred to DHS headquarters. Those issues
and problems that require solutions consistent  with other regional
operations are addressed by DHS regional offices, with technical
support available from headquarters upon request. One example
of this division  of responsibility is in the area of hazardous waste
management. The headquarters office of  DHS is responsible for
making determinations and classifications on a statewide basis as
to which wastes are hazardous and which are non-hazardous.
The regional offices of DHS are responsible  for  overseeing the
management of those wastes, including  issuance of waste dis-
posal variances where mitigating factors such as volume and con-
centration justify disposal in other than a Class I facility.
   With the passage of Proposition 27,  the activities and respon-
sibilities  associated with  mitigating hazardous waste sites  also
have been  distributed between  DHS headquarters and regional
offices. Through the development of the  Decision Tree Manual,
the DHS headquarters office has provided a consistent technical
approach to investigating, characterizing  and  mitigating hazard-
ous waste  sites. Through the ongoing development of AALs,
DHS headquarters also provides statewide  exposure criteria for
toxic chemicals associated with  waste  sites. The  DHS regional
offices, on the other hand,  are responsible  for the  day-to-day
progress at waste sites. This includes developing working relation-
ships with  other state and local  agencies  whose jurisdictions in-
clude environmental monitoring and management as well as inter-
acting with the interested public and their elected representatives.
   On an organizational level, staff in  DHS regional offices are
responsible  for risk management; staff  in DHS headquarters
offices are  responsible for risk appraisal, as well as for providing
technical support  and guidance.  Risk management includes pro-
ject management  to ensure collection  of  accurate and represen-
tative site characterization data, identification  of sensitive biolog-
ical receptors, identification of likely remedial alternatives based
upon a working understanding  of technical  and  cost consider-
ations  pertinent to each site and identifying  non-technical  con-
siderations including demographics, land  use,  politics and public
sentiment.  Risk appraisal  includes evaluation of risk associated
with potential exposures  not completely  eliminated by remedial
action. Thus, the DHS  approach allows development of risk
management decisions based upon a  consistent  risk appraisal
process.
   Finally, it is  noted that consistency in  the  risk appraisal pro-
cess does not equate to statewide uniformity in  site mitigation
criteria. For example, a level of residual contamination could be
allowed to  remain on one  particular site and poteniial exposures
to that contamination could be managed by engineering and legal
controls such as capping and a notice on the title to the property.
On  another site where the environmental,  economic,  demo-
graphic and political factors are different, it might  be unaccep-
table to allow that same level of contamination to  remain on the
site without physical control or management beyond that required
for the first site. In both cases, statewide consistency is achieved
by having  a uniform exposure criterion to evaluate risk and by
having a risk  management process that addresses the same gen-
eral  technical  and nontechnical considerations, though the rela-
tive importance of each issue may vary from site to site.
APPLICATIONS OF THE DECISION
TREE PROCESS
  Two representative examples of the application of the Decision
Tree Process are presented below.

Arsenic Contaminated Site
  This first example site had been a pesticide formulating facility
for more than 40 years; it is located adjacent to a saltwater marsh.
Extremely high levels of arsenic were measured in soils underlying
former waste disposal impoundments and storage areas and near
former loading and handling areas. Elevated levels also were
measured across the site as a result of waterborne transport of
contaminants by seasonal flooding.
  Arsenic contamination  also was observed  in shallow, saline
near-stagnant groundwater underlying this site. Deeper ground-
water zones approximately 200 ft below the shallow zone are ex-
ploited for drinking water at  a series of wells  located hydraulic-
ally upgradient of the site. These  deeper zones are separated from
the shallow zone by approximately 100 ft of low permeability de-
posits.
  As a result of site characterization studies, the site manager was
able to identify human beings as  the sensitive biological receptors
of concern and contact with  contaminated soils as the only sig-
nificant exposure pathway. The  remedial alternatives being con-
sidered included various amounts  of excavation and capping in
conjunction with notices attached to the deed on the property to
limit  potential  usage of the land, thereby limiting future ex-
posures to those associated with on-site activities that might dis-
rupt the capping mechanism. At this site, the site manager had
identified a  likely remedial action  plan. The Decision Tree Pro-
cess was therefore activated to make an appraisal of the potential
risks associated with a particular remedial alternative and to de-
termine what level of contamination could be  allowed to remain
on-site.
  Two exposure scenarios were considered for this site.  In the
first, exposures for on-site construction workers whose  activities
might disturb the capping mechanism were evaluated. The appro-
priate  exposure criterion for  this scenario was the 8-hour time-
weighted occupational standard of 0.01 rog/m' for arsenic in the
workplace rather than a long-term exposure criterion. The second
scenario was to evaluate  potential off-site exposure to wind-
blown dust particles contaminated with arsenic.
  The data  necessary to evaluate these scenarios included char-
acterization of on-site soils and pertinent meteorological informa-
tion.  In addition to environmental data, the literature and prac-
ticing industrial hygienists were surveyed to develop a reasonable
estimate of dust levels that might result from on-site construction
activities. An upper bound 25m8/mJ of on-site dust  and particu-
lates was arrived at through review of survey results. Based upon
this upper bound of 25m8/m-1, the level of arsenic allowable in on-
site  soils stays below the occupational exposure  standard of
0.01m8/3 arsenic and was calculated to be 400 ppm of arsenic.
382    STATE, REGIONAL & LOCAL PROGRAMS
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  The second scenario required evaluation of the potential off-
site exposures to wind-borne arsenic contaminated  soils  should
the capping mechanism be disrupted. The particulate emissions
from the site were estimated with standard air dispersion methods
described in the Decision Tree Manual. With a residual level of
400 ppm arsenic in on-site soils, the level of arsenic in airborne
particulates was undetectable and therefore would not represent
a measurable risk to nearby residents. Thus, through the exposure
assessments just described, a basis for setting site mitigation cri-
teria was established for a site where the question "how clean is
clean?" had previously seemed unanswerable.

Leaking Underground Fuel Tanks
  In California, a statewide task force has been established to
develop a guidance document on leaking underground fuel tanks
(LUFT). Members of the task  force include representatives of
various State agencies, county health departments and water
agencies. The format of the guidance document will follow that
of the California Site Mitigation Decision Tree Manual and is ex-
pected to be available for distribution in the spring of 1986.
  The LUFT task force is organized into subcommittees parallel-
ing the five basic components  of the Decision Treel Process.
Thus, as with the Decision Tree Manual, a multi-disciplinary
approach has been adopted that  allows task force  members to
contribute in their particular areas of technical expertise.
   Specific guidance will be presented on preliminary site apprai-
sal and site assessment. Applied action levels for selected com-
ponents of fuels are being developed, and the transport and en-
vironmental  fate of fuels are being examined so that the risk
appraisal and risk determination processes can be applied to leak-
ing underground fuel tank problems.  Remedial alternatives are
being researched and evaluated  with respect to their efficiencies
and applicabilities under various site conditions. This application
of the Decision Tree Process will fill a major need in California
for developing a technical guidance document to address the in-
vestigation and mitigation of contamination from leaking under-
ground fuel tanks.
CONCLUSIONS
  The California Site Mitigation Decision Tree Process provides
decision-makers with a consistent approach in investigating, char-
acterizing and mitigating abandoned and uncontrolled hazardous
waste sites. The Decision Tree  Process provides  a basis for
appraising potential risks associated with  alternative remedial ac-
tions  at hazardous  waste sites. The  Decision Tree  Process has
been utilized by the Department of Health Services and other
agencies within California and currently  is being followed  by a
multi-agency task force to develop a technical guidance docu-
ment on leaking underground fuel tanks.
                                                                                STATE, REGIONAL & LOCAL PROGRAMS    383
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                               Hazardous  Waste  Management:
                      The  Role  of  the  Local  Health  Department

                                               Michael J. Pompili
                                                 Philip G. Brown
                                         Columbus Health  Department
                                       Division of Environmental  Health
                                                 Columbus,  Ohio
ABSTRACT
  The Columbus Health Department (CHD) has  defined three
functional areas for participating in the  management  of  haz-
ardous waste on a local level. These areas are: (1) coordination
of local agencies, (2) emergency response and (3) review of haz-
ardous waste facility permit applications.  A core  group of city
agencies was formed at the Health Commissioner's request to re-
view existing local responsibilities relative to  hazardous waste
management. Among the documents produced by this group for
the city were notification procedures and functional responsi-
bilities of agencies responding to a hazardous material  incident
and evacuation procedures and policies.
  The CHD has identified its primary responsibility as the in-
vestigation of health effects from a hazardous material (HAZ-
MAT) incident. A procedures manual for CHD was developed
using the Centers for Disease Control document "A System For
Prevention, Assessment, and Control of Exposures and Health
Effects from Hazardous Sites" as  a guide. The CHD  manual
later was used for the investigation of health effects from  an acci-
dental discharge of hazardous substances within  the city by a
chemical plant.
  The CHD also has reviewed applications submitted by several
industries for federal and state permits to store hazardous waste.
These reviews have resulted in written agreements between the
City of Columbus and  the permittee that go beyond the federal
and state statutory requirements.

INTRODUCTION
  Since 1980, a national regulatory framework administered by
the U.S. EPA has been  in place to protect the public's health and
safety from the improper management or illegal disposal of haz-
ardous wastes. Under this federal legislation, states may  exercise
primary responsibility for administration and enforcement  of a
hazardous waste management program under state law in lieu of
the federal U.S. EPA program provided the state program meets
certain minimum federal standards.
  On a local level, however, a combination of federal and state
rules often precludes local authorities from passing laws and/or
adopting  regulations pertaining to the treatment, storage or dis-
posal of hazardous wastes.  Although such a preclusion  exists in
Ohio's hazardous waste laws,' the Columbus Health Department
has attempted to initially define  a role for our local government
in managing hazardous  wastes and materials.

REVIEW OF PERMIT APPLICATIONS
  The CHD's  initial involvement began with the review of a
Part B Permit application for a local branch of a national inde-
pendent distributor of chemical products. The company intended
to collect spent solvents in 55 gal drums from its customers and
store them  at its Columbus location until an economic truck-
load could be arranged (this might necessitate storing the waste
for longer than  90 days) for transfer to a reclaiming facility in
an adjacent state. The Mayor of Columbus, as a statutory party
to the judication hearing before the State of Ohio Hazardous
Waste Facility Approval Board (HWFAB), requested that the
CHD review the application and represent him at the hearing.
Since the application had been reviewed previously by both the
U.S. EPA and Ohio EPA for compliance with their respective
regulatory standards, the CHD's task was to identify the poten-
tial hazards posed by the facility to the  surrounding community
and attempt to minimize any adverse environmental impact pre-
sented by these hazards. The CHD's first action was to form a
committee of various city agencies to review the application.
  The committee was comprised of representatives from the city's
Fire, Police, Sewerage and  Drainage,  Water and  Health De-
partments. Recommendations from each agency were recorded.
Based upon tl'ese recommendations, a staff member of the CHD
prepared testimony for presentation at a  public hearing scheduled
by the HWFAB.
  Following the public hearing, a meeting was arranged between
the statutory  parties and  applicant by the administrative law
judge  for this case. The goal of this meeting was to reach an
agreement on those concerns raised  at the public hearing. With
the administrative judge acting as a facilitator, the CHD nego-
tiated  an agreement  with the applicant. The negotiated agree-
ment,  or Memorandum of Understanding,  incorporated  the
committee's recommendations and was to be  included as a con-
dition of the permit, if granted. The terms of this agreement in-
cluded the following: (1) quarterly inspections of the hazardous
waste storage area by the Division of Fire, (2) an alternative route
 for the  transportation of hazardous materials and wastes enter-
 ing and leaving the facility to bypass a nearby residential area,
 (3) the  installation of a backflow device to prevent contamina-
 tion by  the hazardous waste of the public water supply and (4)
 payment of the performance of a community health assessment
 survey by the Columbus Health  Department  in the event of an
 incident at this site.
   Two  additional Columbus facilities  have  submitted applica-
 tions for a  Part B Permit to the U.S. EPA. Each application has
 undergone  the  same review process as described above. Al-
 though  Memorandum  of Understandings have been signed by
 each applicant and the CHD, each agreement addresses  those
 concerns particular to that facility. For example, one company
 which failed to make familiarization arrangements with the Fire
 and Police Divisions as required  in Section  264.37 of 40 CFR
 signed an agreement that such arrangements would be  made.
 Another company agreed to permit the Division of Water to
384    STATE, REGIONAL & LOCAL PROGRAMS
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conduct a cross connection survey of its facility and then cor-
rect any identified deficiencies. To date, only three of the 13 haz-
ardous waste storage facilities in the City of Columbus have
sought a Part B Permit; consequently, the Health Commissioner
has requested the formation of a standing committee to review
the remaining applications.

COORDINATION OF LOCAL AGENCIES
  The  CHD's role in the management of hazardous substances
within  the city expanded as a result of the application review
process. Within a year, the CHD had initiated the development
of three documents which became the backbone of the city's re-
sponse to hazardous material incidents.
  At the request of the Health Commissioner, a committee com-
posed of representatives from Emergency Management Services,
the Divisions of Fire  and Police,  the local chapter of the Amer-
ican Red Cross and the CHD was established to review and re-
vise evacuation procedures to be taken during a hazardous  ma-
terials  incident. After months of discussion, the committee pro-
duced  a document that contained a series of guidelines designed
to serve as an assurance that every reasonable effort would be
made to preserve life and protect property but at the same time
recognizing that these policies and procedures could not be a gov-
ernmental guarantee  of absolute  safety to area residents when it
was necessary to withdraw from an area due to a hazardous ma-
terials  incident. Highlights of this document include: (1) six basic
premises that form the basis for the policies and procedures, (2)
organizational responsibilities of  these agencies responding to an
incident, (3) key activities associated with each phase of an evac-
uation process and (4) planning considerations for facility admin-
istrators who manage large populations which  generally are diffi-
cult to evacuate. The evacuation  policies and procedures are not
site-specific, but they apply to any fixed site or transportation in-
cident  which would  require an  evacuation of the surrounding
area.
   During the evacuation planning meetings, committee members
were cognizant of the need to understand the role of each agency
when responding to an incident.  Consequently, a document was
developed which formalized alert notification procedures and ex-
plained the  functional responsibilities of  responding  agencies.
The key to the notification chain is the Division of Fire. If, in
the judgment of a responding Battalion Chief, a hazardous inci-
dent warrants the expertise or assistance of another city agency,
the notification plan is initiated.

EMERGENCY RESPONSE
   Since the  CHD had taken the responsibility for investigating
human health effects from exposures to  hazardous  materials
which  occur within the  city, an intra-departmental procedures
manual was  formulated. The procedures within this manual were
based  upon  the Centers for Disease Control  guide,  "A System
for Prevention, Assessment and Control of Exposures and Health
Effects from Hazardous Sites."2  This response procedures man-
ual outlines  CHD's involvement in any response and describes
the methodology for performing a health assessment study.
  With internal response procedure in place, the CHD sought to
improve the Environmental Health Division's response capabil-
ities. To achieve this objective,  access to  a computer database
was obtained and  personnel protective gear and sampling equip-
ment were purchased. With the  acquisition  of  "Hazardline,"
an  on-line, interactive, time sharing database,  the risk assess-
ment process was made  more timely and efficient. "Hazard-
line"  contains hundreds  of pieces  of data for approximately
4,500 chemicals. The  information includes physical and chemical
properties,  needed  personnel protective  equipment,  chemical
toxicology, symptoms of exposure, and  leaks and spills  pro-
cedures.
  A self-contained breathing unit,  chemical  splash suits, half-
face respirators and a variety of other gear were purchased to pro-
tect the CHD's response personnel. For site assessment and inves-
tigation purposes, a high/low  flow pump,  charcoal collection
tubes and a detection tube test kit were purchased.
  A test  of  CHD's  internal response  procedures occurred 5
months after its initial involvement in spill response. On May 7,
1984, a chemical manufacturer accidentally released 2,000 Ib of a
phenol-formaldehyde resin into the air in less than 5 min. A slight
northeasterly wind blew the resinous mixture over a residential
area, although a  great percentage of the material  precipitated
onto the company's ground. Sixty-eight individuals in 18 house-
holds were potentially exposed.  The CHD collected water and
soil samples within a 2-mile radius of the plant. Initial samples
were analyzed for  phenol  and  formaldehyde with subsequent
samples analyzed only for phenol. Wellwater samples collected
from the 18 households indicated no contamination from the in-
cident.
  The  CHD's role within hazardous material incidents became
more clearly defined with this incident. It was evident that OEPA
and the Columbus Division of Fire were capable of handling the
emergency response procedures during this incident. What was
missing, however, was the evaluation of health effects on the area
residents. Ohio EPA response teams have a natural tendency to
worry more about the environment than the residents, while the
CHD's training is based upon worrying about the residents first
and the environment second. In this incident,  the two agencies
complimented each other's actions to the benefit of both parties.
  Upon completion of a study of the incident, the  CHD released
a document that explained what  was released, what amount was
released, who was affected  and whether any long-term health
effects were expected.  Furthermore, the CHD recommended that
followup soil and  water  testing  for phenol be continued for a
definite period to ensure there  was no  contamination of the
ground water.  The company which had  the  accidental  release
agreed to pay for any and all required testing using CHD guide-
lines as well as the cost  of  the  complete CHD study. None of
the information about health effects to the residents would have
been available through any  government agency other than the
CHD.

CONCLUSIONS.
  Although local governments often lack the statutory authority
to regulate hazardous waste  facilities, much can be done outside
the legal framework to ensure that local concerns about such sites
are addressed. Without  benefit  of legislation,  the Columbus
Health Department secured voluntary agreements with local haz-
ardous waste facilities which surpassed federal and state legal re-
quirements.
  In addition, the CHD coordinated the formulation of spill re-
sponse procedures and evacuation policies which are implemented
through interagency cooperation. The CHD believes that local
governments have a role to play in the management of hazardous
materials and  wastes, notwithstanding the existence of formal
regulations; it is the CHD's conviction that this involvement must
complement, not duplicate, federal and state program efforts.

REFERENCES
1. Chapter 3734 of the Ohio Revised Code.
2. CDC, "A System for Prevention, assessment, and  Control of Ex-
  posures and  Health Effects  from Hazardous Sites (S.P.A.C.E. for
  Health)", Chronic Diseases Division of the Center for Environmental
  Health, Centers for Disease Control, Atlanta, GA, Jan. 1984.
                                                                               STATE, REGIONAL & LOCAL PROGRAMS    385
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                    U.S. EPA's  Initiatives for Expanded  Public
                 Involvement in  the  RCRA  Permitting Program

                                                Vanessa Musgrave
                                    U.S.  Environmental Protection Agency
                                                Washington, D.C.
                                                    Edwin Berk
                                                ICF Incorporated
                                                Washington, D.C.
ABSTRACT
  The purpose of this paper is to provide an overview of the U.S.
EPA's  initiatives for public involvement  in the permitting of
hazardous waste treatment, storage and disposal facilities under
RCRA. The authors first discuss the rationale for fostering early
and expanded public involvement. They then  describe the ap-
proach and  main  steps recommended by the  U.S.  EPA to
facilitate public involvement in decision-making on a permit. The
authors conclude with a brief discussion  of some  of the U.S.
EPA's supporting activities in this area.

INTRODUCTION
  In the 1970s, the  potential threat to human health and the en-
vironment posed by hazardous wastes emerged as  the nation's
most prominent environmental issue. In scores of communities
throughout the country, citizens banded together to press for the
cleanup of abandoned hazardous waste disposal sites or to pre-
vent new waste management facilities from being created. More
often than not, these  citizens  had little prior experience with
political  activism  and  were far from  being  traditional en-
vironmentalists; their concern was over the direct personal health
and economic effects of a particular hazardous waste facility. It
usually made little difference whether the facility was inoperative
and already the cause of extensive contamination or newly pro-
posed and designed according  to the strictest safety guidelines:
hazardous wastes became perceived as potential threats under any
circumstances and  were regarded as generally  intolerable in
anyone's "backyard." The concerns raised at scores of localities
led to national attention and, ultimately, major federal hazardous
waste regulatory and cleanup legislation.
  Public  concern over hazardous waste has continued and, if
anything, intensified through the 1980s. The primary  source of
the concern remains localized; that is, public concern over hazar-
dous waste arises among citizens who consider themselves and
their children to be  directly affected by a particular  disposal site
or waste management facility. The U.S. EPA has recognized that
to fulfill its legislative mandates to protect human health and the
environment from the threat of hazardous wastes, an active, ef-
fective public involvement program is essential. There is no ques-
tion of whether or  not to involve the local public  in the U.S.
EPA's decisions. The question  is how to involve the local  public
so that public participation is constructive and results in sounder
environmental decision-making.
  In the  context of the permitting program  conducted  under
RCRA, the U.S. EPA's answer to this question has  taken the
form of initiatives to foster early and expanded public involve-
ment. These efforts are being pursued in accordance with the U.S.
EPA's  National  Permits  Strategy.  They  incorporate, but go
beyond,  public participation  requirements in RCRA section
7004(b)(l) and  in  U.S.  EPA  regulations on procedures  for
decision-making in 40 CFR Part 124, Subpart A.

IMPORTANCE OF EARLY PUBLIC
INVOLVEMENT IN RCRA PERMITTING
  The U.S. EPA's  initiatives for public involvement in RCRA
permitting are aimed at enabling the local public to have meaning-
ful and constructive input to decision-making on a facility's per-
mit. For public input to be meaningful, it must occur early in the
permitting process,  before  a permit has been drafted: that is,
before all the major decisions on the permit and the actual condi-
tions it is to include  have been made. The public participation re-
quirements in the regulations cited above, however, ordinarily
would result in public involvement late in the permitting process,
so the activities they call for must be supplemented. Thus, the
U.S. EPA's  National Permits  Strategy calls  for early and ex-
panded public involvement.
  There are several  reasons why meaningful and early public in-
volvement is important to the RCRA permitting program:
• Public involvement can yield  information of value to decision-
  makers in evaluating a permit application and drafting a per-
  mit.  For  example,  it can yield information concerning  the
  facility's operational history and site characteristics.
• Public opposition often arises when citizens feel they are being
  excluded from decision-making that will have direct and long-
  lasting  effects on their community; that they are being "rail-
  roaded" by a distant government agency. This kind of opposi-
  tion  is always unnecessary.  It can  largely  be  avoided by
  ensuring that the comments  and concerns of the local public
  are considered throughout the process of debate and delibera-
  tion leading to decision-making. The result will be a permitting
  process focused on the technical merits of a facility rather than
  on the public's dissatisfaction with its lack of opportunity for
  participation.
• Public involvement from an early stage in the permitting  pro-
  cess helps government staff  identify  areas of concern to the
  community  before a permit has been drafted. When identified
  in  advance, such concerns often can  be addressed in the draft
  permit. Less time and energy will be spent developing permits
  that later provoke public opposition by failing to address com-
  munity concerns.

  Early public involvement in RCRA permitting is also important
because of the enactment of the 1984 RCRA amendments. These
amendments are a direct consequence of the increased public con-
cern over the issues  of hazardous waste management. In return,
because of certain provisions in  the 1984 RCRA amendments and
386   PUBLIC COMMUNICATIONS
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the debate over enactment of those amendments, public interest
in the RCRA permitting program has broadened and public in-
volvement in the program has become more complex. The follow-
ing issues, in particular, are likely to be the focus of special public
interest as the permitting program develops.

Groundwater Protection
  There has been widespread failure to comply with  RCRA's
groundwater protection requirements. The  removal of  wastes
from Superfund sites to RCRA facilities has intensified concern
over the possibility of groundwater contamination and its effects
on human health.

Protective Standards and Enforcement
for Operating Units
   Public interest  is already  strong on the question of whether
RCRA's design standards and operating specifications (e.g., land-
fill liner requirements) are strict enough and are being met.

Exposure Assessments
   RCRA section 3019 requires each final permit application for a
landfill or surface impoundment to be accompanied by informa-
tion on the potential for the public to be exposed to hazardous
constituents released from the facility. Citizens also can submit
exposure information. There often will be considerable local in-
terest in this information.

Corrective Action
   Significant public interest  can be expected in all facets of cor-
rective action requirements.  Have releases occurred from a facil-
ity? How will  releases be cleaned up? Will corrective action be
sufficient to prevent future releases? What kinds of investigations
will be conducted to determine the need for corrective action?

Permit Process Itself
   The length of time involved in issuing  a permit as well as the
adequacy of public involvement opportunities are examples of
issues related to the permit process (as opposed to the contents of
permits) that can be of public concern.

Transportation of Hazardous Wastes
   Many times  the public's strongest concern centers on the
transportation of hazardous wastes  to or from a facility. The
possibility of traffic accidents and the proximity of transportation
routes to homes and schools heighten the public's  concern over
releases during transportation. Often, though, the sheer volume
of traffic and  the associated noise and congestion are of even
greater concern.

Evacuation Plans
   The very existence of evacuation plans implies that accidents
can and will occur. Moreover, the public has shown interest in the
adequacy of evacuation  plans. Who will be evacuated? How will
they be notified? Who pays? Fire and explosion emergency plans
also acknowledge the potential for threats to the public's  safety;
despite their value, their existence may undercut assurances that
such occurrences are unlikely.

Omnibus Provision
  RCRA section 3005(c) states that "each permit .  . . shall con-
tain such terms and conditions as the Administrator (or the State)
determines necessary to protect human health and the  environ-
ment." The public may be inclined to read great flexibility into
this provision.
Consequences of Permit Denial
  Whether an operating permit is approved or denied, the conse-
quences will be of interest to the public.  The denial of a permit
will cause special concern because  of the potential impacts on
employment, property values and the local tax base. Moreover,
the public may not at first appreciate the  environmental implica-
tions of permit denial. Denying a permit for incineration, for ex-
ample, might mean that the  applicant has to continue to landfill
wastes.

U.S. EPA'S APPROACH TO PUBLIC
INVOLVEMENT IN THE PERMITTING PROCESS
Guidelines
  Early public involvement in the permitting process for a waste
management facility means doing more than simply fulfilling the
formal public  participation requirements  in federal regulations.
How much more, however, is something  that depends upon the
particular circumstances  of  each case. Thus, the U.S. EPA's
policy for public involvement in RCRA permitting does not in-
clude the addition of long lists of requirements. In fact, there are
no new requirements.  Instead, the U.S. EPA offers the following
general guidelines:
• Public involvement efforts should be tailored to the  distinc-
  tive issues and individual features of the facility and the sur-
  rounding community.
• The  applicant and other responsible  government  agencies
  should have a role in public involvement efforts, especially to
  help clarify or resolve issues that may be related to the facility
  and its  operations but cannot be addressed appropriately by
  the RCRA permit process.
• Small-scale,  low-profile, informal communications  techniques
  are  preferred. Public meetings may be held in informal set-
  tings, before small  audiences and without elaborate presenta-
  tions (e.g., in living rooms). They need not be conducted by
  high-level staff.
• In general, public involvement actions  should  extend  beyond
  providing information to the public; they should actively reach
  out to the public, encourage participation and  provide an op-
  portunity for public input on permit decisions made by EPA
  or the State.

Targeting
  Following the above guidelines,  public involvement efforts
should be targeted to individual circumstances; the same program
of activities will not be necessary, and would not be effective, in
every case. Public involvement efforts also should be targeted in a
second sense:  the  limited resources available to a U.S. EPA
regional office or State agency for public  involvement should be
concentrated on those facilities where the need is greatest.
  Targeting in this second sense means that certain facilities will
have to be selected  for special attention. The selection of facilities
for early and expanded public involvement should be based not
only on environmental significance (i.e., the potential  to pose
significant risks to  human health and the  environment), but also
on social significance (that is, the extent of public interest already
generated and the  potential  to arouse significant interest in the
future). While the development of widespread interest as the per-
mitting process unfolds cannot be predicted with certainty, the
following are good indicators of the potential to  generate public
interest:

• The owner or operator of the facility lacks credibility with, or
  the trust of, the  public or  local officials
• The public perceives that the facility poses major health risks
                                                                                           PUBLIC COMMUNICATIONS    387
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• Major hazardous  substance  releases  or  accidents have been
  publicized recently in the area
• The type of technology proposed in the permit (e.g., incinera-
  tion, underground injection, landfill, etc.) has a negative repu-
  tation in that particular area
• Facility non-compliance or violations have been highly publi-
  cized or will be made known by the permit process (in general,
  the more serious  the continuing non-compliance,  the  more
  public interest likely to be generated)
• The facility has been or likely will become an election issue
• The permit could allow the transportation of Superfund haz-
  ardous wastes to or  from the facility
Permit writers in the U.S. EPA regional offices and in State agen-
cies have found that  often there is little correlation between a
facility's environmental significance and its  social significance. It
is not uncommon  for  an environmentally significant  facility  lo
meet  an apathetic reaction from the local  community, while a
smaller facility creates  intense public concern.

The Field Assessment and
Public Involvement Work Plan
  Two critical elements in  a public involvement effort  for a
targetted facility are the "field assessment"  and "public involve-
ment  work plan." Both help to ensure  that public  involvement
efforts are well-planned and meet the distinctive needs of a partic-
ular community and a particular facility.
  A field assessment consists of interviews, both  in person and
over the telephone, with local citizens and officials to  obtain in-
formation on the following points:
• Major community concerns regarding a facility
• The citizens, community leaders and officials in the area who
  are especially interested in the facility and should be kept ap-
  prised of developments
• The best means  to provide information to the public and,  in
  return, to obtain public comment and input

  To this end, the community interviews conducted  for the field
assessment address the following topics:
• The local history  surrounding the  facility (e.g.,  the circum-
  stances under which it was built); any  past or present opposi-
  tion to  the  facility;  previous relations between citizens, gov-
  ernment  agencies  and the  facility's  owner or operator; and
  news stories about the facility. (For instance, it might be use-
  ful  to know that the local newspaper has opposed the facility's
  operation for ten years and has just finished publishing a series
  on  the facility's non-compliance with  interim status require-
  ments.)
• The negative as  well as the positive economic impacts of the
  facility's operation  on various segments of the  community.
  This information  is useful for  anticipating and  interpreting
  people's concerns and positions.
• The current level of information and  understanding that the
  public (including local officials)  has  about the  facility's op-
  eration. This information is needed to assess what additional
  information will be  necessary to  enable the public to partici-
  pate intelligently.
• Other significant political  or social events or  circumstances
  that might  affect  the community's attitude or  involvement
  with the facility's permitting.  It would  be imperative to know,
  for example, that the recently elected mayor campaigned on a
  promise to close the facility.
  After two or three days of interviewing to gather such informa-
tion, a public involvement work plan can be prepared. This plan
will include the following elements:
• A capsule facility description
• An identification of major community concerns and leaders
• An outline  of the  minimum activities  the  U.S. EPA or  the
  State will conduct to ensure both that the local  public is well-
  informed about permitting decisions and also has meaningful
  input into those decisions
• An indication of the timing of these activities
  The public involvement work  plan provides a strategy for en-
abling the public to have meaningful input  to the decision-making
process for a  permit. It also serves to coordinate the roles and
responsibilities of the various participants in  the public involve-
ment effort: The U.S. EPA, the State, local officials, the owner
or operator and the general public. And it  reassures local citizens
that there indeed has  been some forethought given to providing
opportunities for meaningful public involvement.

Public Involvement Activities
  Public involvement activities will vary  by facility and by the
stage in the permitting process at which public involvement ef-
forts are initiated. The following types of activities, however, will
be conducted in each  instance:
• Outreach activities, such as informal informational briefings
  and meetings, including public notice of the draft permit
• Dialogue and assimilation activities,  such  as work sessions,
  public meetings and public hearings (if appropriate)
• Response activities,  including informal responses to questions,
  concerns and requests from the public during the permit pro-
  cess as well as formal, final responses to public comments
The only activities that are required are those specified in RCRA
section 7004 and 40 CFR 124 Subpart A, the  most important  of
which is the public comment period on the draft permit. These re-
quirements hold for every determination on an  RCRA final per-
mit application, including those for facilities that are not targeted
for expanded public involvement.
  Often the most effective public involvement activities are very
different from "textbook" information techniques. For example,
a permit writer in Hawaii  responded to citizen concern over the
permitting  of a waste management  facility by serving as an in-
termediary between  citizens  and the  owner,  encouraging the
owner to modify his operating procedures in a way that could not
have been specified in the permit but that  successfully addressed
public concerns.

Roles and Responsibilities
  Public involvement  in the RCRA  permitting process is a team
effort, with contributions from the U.S. EPA and the State. And
within each permitting agency, there will  be roles and  respon-
sibilities for staff from a number of offices. For example,  each
EPA regional office, and each State authorized to issue final per-
mits, should already have designated someone on its staff as the
RCRA permitting program public involvement coordinator. The
coordinator works with permit writers, enforcement personnel
(both U.S. EPA  and  State), facility owner/operators and other
appropriate individuals or groups to implement public  involve-
ment activities. Permit writers may take the lead in discussions of
specific permit conditions  on facility operations;  they  may  be
responsible for providing information to answer public inquiries.
  In some  cases, the owner or operator may contribute to public
involvement activities  conducted by the U.S. EPA or the State in
addition to his own independent outreach  or public information
efforts.  In fact, owners and operators are encouraged to take
steps to inform and involve the local public, although in so doing,
the distinction between the owner or operator's interests and the
government's regulatory mission should be made absolutely clear
to the public.
388
       PUBLIC COMMUNICATIONS
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SUPPORTING INITIATIVES
  The U.S. EPA's Office of Solid Waste is pursuing a number of
supporting initiatives  to advance the policy for public involve-
ment outlined above. The goal is for local public involvement to
become a regular feature  of the U.S. EPA and State decision-
making on each RCRA permit, with the extent of the public in-
volvement effort for each facility and the scope of the activities
conducted in the locality scaled to the need.
  First, we are now providing a two-day training course in public
involvement  techniques for RCRA  staff in each  U.S. EPA
regional office. State staff also are invited to these sessions,  and
we expect to offer the training in authorized States in the future.
The training  covers the rationale  for early and expanded public
involvement in RCRA permitting, the targeting of facilities for
special attention, procedures for conducting field assessments and
developing public involvement work plans, as well as techniques
for conducting effective public meetings and handling relations
with the news media.  There is also instruction in  basic skills for
minimizing or resolving disputes and conflict between govern-
ment and  local citizens.
  Second, we are preparing a variety of educational and informa-
tional materials for the lay public on the RCRA permitting pro-
gram. Already in draft is  a "Citizens' Guide to RCRA Permit-
ting" that explains the steps in deciding whether to grant a final
permit to a hazardous waste management facility, the conditions
that may be included in a permit and the role of the local public in
decision-making  on the permit. We plan to prepare brief  fact
sheets on specific topics of widespread general interest (for exam-
ple, corrective action requirements and exposure assessments).
Fact sheets also  will be prepared  on individual facilities, when
needed, to explain to the public the technical features of the facil-
ity, the operation and design standards to which it is subject  and
progress in reviewing the facility's permit application.
  Finally, we are  continuing  to  analyze  the  best approach to
public  involvement  and  community  relations  in  special  cir-
cumstances (for example, in siting new hazardous  waste manage-
ment facilities or in conducting exposure  assessments).  As the
analyses reach completion,  we will prepare guidance materials to
assist the regional and State staff who will be on the "front line"
in public involvement efforts. As noted, the U.S. EPA already
has issued draft guidance on public involvement in  RCRA permit-
ting.
CONCLUSIONS
  The discussion in this paper should serve to dispel any impres-
sion that the U.S.  EPA's initiatives for public involvement in
RCRA permitting will just "stir the pot," creating public opposi-
tion where there would otherwise have been none and ultimately
forcing  the closing  of facilities that could treat and dispose of
hazardous wastes in an environmentally sound manner. That is
not, of course, the desired consequence of these initiatives.  In-
stead, these initiatives are aimed at preventing needless public  op-
position, the opposition rooted in public distrust of government
motives, rather than in the technical flaws of a facility or permit,
and are precipitated by neglecting the local public in government
decision-making. They are, moreover, aimed at ensuring that
RCRA permits  take local concerns fully into account and protect
the local public's health, welfare and environment. Early and  ex-
panded public  involvement in  RCRA permitting  can  thereby
facilitate the permitting process and lead to better environmental
decision-making.

BIBLIOGRAPHY
 1.  A National Permits Strategy for Implementation of the  Resource
    Conservation and Recovery Act, U.S. EPA Office of Solid Waste,
    Aug. 1984, as revised on Sept. 9, 1985.
 2.  Bleiker, Annemarie and Hans,  Citizens Participation Handbook
   for Public Officials  and Other Professionals Serving the Public,
    1981.
 3.  Community Relations in Superfund: A Handbook, prepared by 1CF
    Incorporated for the U.S. EPA, Sept. 1983.
 4.  Environmental Protection Agency Regulations on Procedures  for
    Decisionmaking, 40 CFR Part 124, Subpart A.
 5.  EPA and the Public: A Handbook on Public Participation Con-
    cepts and Skills, Barry Lawson Associates,Inc., 1981.
 6.  Guidance on Public Involvement in the RCRA Permitting Pro-
    gram, U.S. EPA Office of Solid Waste, Permits Branch, Dec. 1985.
 7.  Implementation of the Resource Conservation and Recovery Act,
    U.S. EPA, No. EPA/530-SW-84-007, 1984.
 8.  Jordan, Barry H., How  to Write a Public Notice: A Collection of
    Examples, U.S. EPA Water Program Operations, Dec. 1979.
 9.  Resource Conservation and Recovery Act,  Section 7004(b)(l),  PL
    96-482.
10.  "Responsiveness Summary and Preamble on Public  Participation
    Policy," Federal Register, 46, No. 12, 1981.
                                                                                             PUBLIC COMMUNICATIONS    389
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                      Cleanup  in the Sunshine:  Florida  DOT's
              Public Information  Program  at  the Fairbanks  Site

                                               Robert  C. Classen
                                              O.H. Materials Co.
                                                Atlanta, Georgia
                                                Charles C. Aller
                             Florida Department of Environmental Regulation
                                              Tallahassee,  Florida
ABSTRACT
  A routine safety inspection of the  Florida Department of
Transportation (DOT) Bureau of Materials and Research Labora-
tory was conducted in November 1982. This inspection indicated
that chemical waste generated at  the laboratory was being dis-
posed at a borrow pit located on DOT property in the rural com-
munity of Fairbanks, Florida, 7 miles northeast of Gainesville.
  In January 1983, a number of private water supply wells in
Fairbanks were tested for volatile organic compounds (VOCs).
The results indicated the presence of VOCs in some of these wells.
  In response to public health concerns, the well sampling pro-
gram was intensified, and a comprehensive site investigation was
initiated. The purpose of the investigation was to determine the
source of VOC contamination  affecting private wells to estimate
the extent of VOCs in the groundwater, to develop immediate re-
medial procedures  and to recommend a water supply alternative
for the Fairbanks community.
  The results of the site investigation indicated that the  DOT
borrow pit was the source of VOC contamination affecting pri-
vate water supply wells. Laboratory waste materials which form-
erly were disposed of at the sand pit had seeped into a multi-
aquifer  system.  This contamination had entered  the shallow
aquifer in substantial concentrations within a limited area near
the sand pit and had slowly leaked into the uppermost secondary
artesian aquifer. VOCs  that had entered the upper  limestone
aquifer spread to private wells through the natural flow system
and in response to pumping.
  Remedial actions were implemented to eliminate the source of
VOCs and to cleanse the shallow aquifer. These actions included
the removal of drums of buried waste from within the borrow
pit and the installation of a recovery well system designed to pre-
vent further movement  of contaminated groundwater in the
shallow aquifer, as well as to treat the groundwater by removing
VOCs.
  After the initial sampling, when it was determined that private
water supply wells were contaminated, bottled water was distrib-
uted to the community.  At that  time,  an understandably high
level of anxiety existed in the  community. For this reason, the
DOT decided to initiate  a public  information  program consist-
ing of a newsletter, weekly public information  meetings and lia-
ison with the citizens' group.  By the  end of  the crisis, it was
apparent that the program was extremely successful.

INTRODUCTION
  During a routine safety inspection of the Florida Department
of Transportation (DOT) Bureau of Materials and Research Lab-
oratory, the Second District Industrial Safety Manager noted that
chemical waste generated by the DOT laboratory was  being dis-
posed at Fairbanks Sand Pit (FSP), located on DOT property
approximately 7 miles northeast of Gainesville in Alachua County,
Florida (Fig. 1).
  Private water supply wells in the vicinity of the borrow pit were
sampled, and the results of these tests indicated that 9 of the 18
wells sampled were contaminated with  the  same halogenated
chemical solvents disposed at FSP or with the degradation pro-
ducts of these solvents. The DOT immediately began distributing
bottled water to the residents of Fairbanks, the rural community
which surrounds FSP.
  On Feb. 4, 1982, Dames & Moore was retained by the DOT to
work with the agency toward resolution of the Fairbanks prob-
lem. It  was agreed  that a detailed study of the Fairbanks prob-
lem was necessary and that this work should incorporate a com-
prehensive hydrogeologic investigation of the site.
                                              FAIRBANKS
              MILES
                         Figure 1
                       Site Location
Problem Definition
  The initial objective of the project was to provide a compre-
hensive analysis of the nature, extent and transport mechanisms
causing the observed groundwater contamination. Specifically,
the work included:
390    PUBLIC COMMUNICATIONS
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• Implementation of immediate procedures to clean up and re-
  move chemical waste contamination within the borrow pit
• Characterization of historical waste disposal at the borrow pit
  and adjacent areas
• Evaluation of adjacent off-site areas  relative to potential con-
  tamination sources
• An estimate of the  horizontal and vertical  extent of contam-
  ination in the aquifer(s)
• Development of conceptual control/abatement alternatives for
  the zone of groundwater contamination

  As the investigation progressed, the information developed led
to expansion of the scope of work outlined in the plan of study to
include: additional investigation of the extent and rate of travel of
contamination in confined aquifers; logging  of private water
supply wells;  toxicological analysis; design, installation and per-
mitting of a recovery system;  and an analysis of alternatives for
providing potable water to the residents of the community.

PROGRESS OF THE INVESTIGATION
  A major objective of the program was to  establish the areal
and vertical extent of the contamination affecting the aquifer sys-
tem in Fairbanks.

Sampling
  Sampling of private water supply wells had indicated that vola-
tile organic compounds (VOCs) were  contaminating one or more
 aquifers in the Fairbanks area.  The first step was to determine if
     I OBSERVATION WELLS

     JAREA OF CONTAMINATION
                                              N.E. S3 TEBR.
the Fairbanks Sand Pit was, in fact, a source of this contamina-
tion. In order to determine the types of waste present in the pit, as
well as historical disposal practices, DOT  laboratory personnel
(the generators) and maintenance personnel (who had placed the
chemicals in the pit) were interviewed.
  Next, four clusters  of two monitoring wells each were placed
on  the pit's  perimeter (Fig.  2), sampled and analyzed for the
chemicals on the U.S. EPA's Priority Pollutants  List. The re-
sults indicated that the chemicals which were buried in the pit or
their  degradation products  were  contaminating  the  surficial
aquifer and that among these chemicals were the same chemicals
detected in the private water supply wells.
  The next task was to construct eight clusters  of two wells
around the pit at a distance of 500 ft. Analysis of samples and
water levels from these wells showed that the direction of flow in
the surficial aquifer was to  the north, towards  Hatchet Creek,
and that  VOC contaminated groundwater was leaving the pit in
this direction.
  The next monitoring wells were placed downgradient of other
borrow pits in the vicinity of FSP to determine if they were con-
tributing to the contamination problem. They were not.
  Other  wells were placed into the semi-confining unit at the
base  of  the surficial aquifer  and north  of  Hatchet Creek.
Analysis  of samples from these wells indicated that the contam-
ination was penetrating the semi-confining unit but was not cross-
ing Hatchet Creek.
  With this information, work shifted from the shallow to the
deeper aquifers. First, borings were made to determine the posi-
tion and  continuity of water-bearing units in the Fairbanks area.
When these units had  been mapped, deep monitoring wells were
placed so that each of the three aquifers identified could  be sam-
pled and  aquifer characteristics could be measured (Fig. 3).
  While the field program was underway, additional information
on private water supply wells was being collected through a house
to house well inventory and well logging.
                          Figure 2
  Monitoring Well Location and Approximate Lateral Extend of VOC
              Contamination in the Shallow Aquifer
                                                                     • TEST BORING LOCATION ONLY

                                                                     ® ARTESIAN AQUIFER MONITOR WELL
                                                                      AND TEST BORING LOCATIONS
                           Figure 3
          Location of Artesian Wells and Deep Test Borings
                                                                                            PUBLIC COMMUNICATIONS    391
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Pit Closure
  Another of the project's objectives was to properly close, con-
current with the field investigation, the Fairbanks Sand Pit, elim-
inating it  as a source  of contamination. Closure consisted of a
magnetometer survey  to ensure that all buried drums had  been
located, excavation and proper disposal of the drums and installa-
tion of a  recovery system  to control the movement of contam-
inated water in the immediate vicinity of the pit.
   Residents in Fairbanks whose water supply wells were contam-
inated were using bottled drinking water. A priority objective of
the project was to restore potable tap water to the community as
soon as possible. Thus, while the field program and pit cleanup
were underway, an analysis of alternatives  to provide potable
water was conducted. Completion of this analysis was timed so
that important information from the  geohydrological program
could be considered in deciding on the recommended alternative.
   Although the residents were  drinking bottled water,  another
issue of concern was whether or not they would be able to safely
eat (1) fruit and vegetables in  which  contaminated water was
used in the process of home  canning  or freezing and (2) meat
from livestock which had consumed contaminated water before
slaughter. To answer these and other health questions, a toxicol-
ogist was  retained and samples of food were analyzed. The food
samples were found to be free from contamination.

PUBLIC INVOLVEMENT
   The need for  public involvement was, from the outset, iden-
tified as vital  to the successful resolution  problem. When De-
partment  of Transportation (DOT) and Dames & Moore project
personnel arrived on-site  in February  1983,  it was evident that
the level of community concern was extremely high.  Following
an on-site review, a press conference was held to announce plans
to initiate site investigation and cleanup activities. This press con-
ference was the beginning point for a project which, from the
start, focused local, state and national attention on public agency
response to a serious groundwater contamination incident.
   Development of the project plan of study proceeded with close
coordination between all involved governmental agencies:
•  Alachua County, Board of County Commissioners
•  Alachua County Health Department
•  Florida Department of Environmental Regulation
•  Florida Department of Health and Rehabilitative Services
•  City of Gainesville, Utilities Department
•  St. Johns River Water Management Dr'.rict
   The plan of study was publicly presjnted at an evening meet-
ing in the County Commission board room in mid-March 1983.
Public comment at that time made it clear that, although the
Department of Transportation had done an excellent job of con-
sulting with other agencies and local elected  officials, members of
the Fairbanks  community  felt excluded from the decision-mak-
ing processes.

Community Group Formed
   During this time, in response  to the crisis,  people living in the
area joined together in a voluntary group known as the Fairbanks
Community Association  (FCA).  They  held meetings,  elected
officers, began to develop  an agenda of concerns relating to the
contamination and  contacted a local  legislator, Representative
Sid Martin (D-Hawthorne), who was active  in environmental and
conservation issues. In late March, Representative Martin chaired
a volatile and well attended, legislative committee meeting which
provided a mechanism for  DOT, Dames &  Moore and local resi-
dents to begin  the process of working together. From this point,
an extensive community involvement program began which in-
cluded the following key elements.
Community Involvement
• Daily contact between the DOT project  manager, the FCA
  President, the Alachua County Administrator (acting for the
  Board of County Commissioners) and the County Health De-
  partment.
• At a minimum, weekly contact  with legislative staff and  the
  Department  of Environmental  Regulation.  Other  involved
  agencies were contacted regularly as the situation required.
• A series of evening community meetings (weekly during April
  and May 1983,  then  biweekly for the project duration) was
  conducted at the Fairbanks Baptist Church.  The purpose of
  these meetings was to brief residents on project programs and
  provide an opportunity to  air questions and  respond to con-
  cerns.  Prior to each of these meetings,  face-to-face briefings
  were provided to FCA officers and their concerns were solicited.
• Site visits were arranged for interested residents.
• A newsletter  was published and mailed to  all  community resi-
  dents, not just to FCA members.
• Community members and agency representatives were invited
  to participate in all meetings involving major project decisions,
  including:
  -Study design
  -Monitor well construction
  -Monitor well and test boring location
  -Sampling protocol
  -Borrow pit closure
  -Water supply alternatives analysis
• Complete public and media accessibility of DOT project man-
  agement personnel.
  The cornerstone of the public involvement program  was the
open attitude and effort to maintain communication on the part
of DOT  personnel; from the beginning,  all project operations
were open to public  scrutiny. Of the elements  briefly reviewed
above, the most critical to project success probably involved the
meetings with the residents and the newsletters.

Public Meetings
  At the outset, the FCA meetings were well attended with heated
discussion. Residents were understandably  scared, angry and
frustrated. As the project progressed, DOT, Dames & Moore and
community members began  to work together to  resolve issues of
mutual interest. Examples include:
• Site excavation cleanup and progress
• Bottled water deliveries
• Site security
• Monitor well construction and testing progress
• Private water supply sampling
• Safety of foods grown and irrigated or preserved with contam-
  inated water
• Provision of  independent lexicological expertise  for respond-
  ing to health concerns
• Community well construction survey
• Rumor control
• Property values
• Long-term project planning
• Remedial action water supplies alternatives
REMEDIAL PLANS
  The  last item noted probably is most representative of the
overall success of the public involvement program. A final pro-
ject step required an analysis of possible solutions to the contam-
ination problem, the election of a  preferred remedy and imple-
mentation of an equitable settlement for the residents.
392   PUBLIC COMMUNICATIONS
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  This remedial evaluation process, which examined drilling new
wells, home filtration systems, a community water supply and
connection to an extension of the Gainesville Municipal system,
was jointly conducted by DOT and a citizens committee of 12
volunteer  community members.  Issues of  fire protection and
financial settlements also were considered. The result of this work
was a decision to connect residents to the Gainesville water sys-
tem, provide enhanced fire protection (hydrants) and include a
water rate subsidy for a specified period of time.

COOPERATION ATTAINED
  Toward the end of the site cleanup and contamination inves-
tigation activities, the remedial action decision for water system
connection was announced at a well attended public  meeting
which received extensive media coverage. Unlike earlier meetings,
the only hostility toward the DOT was evidenced by media repre-
sentatives not familiar with the project.  Residents and officers of
the FCA voluntarily spoke in support of the different phases of
project activities and on behalf of DOT.
  The final few public meetings on this project clearly demon-
strated the accomplishment of this multifaceted public involve-
ment and educational program. A community, completely frus-
trated and angry at the state over the contamination of the water
supply, eventually became totally involved  in all phases of the
project. The initial hostility gradually led to an active participa-
tion which  resulted in a sense of satisfaction on the part of resi-
dents in having played an important part in the solution.
                                                                                           PUBLIC COMMUNICATIONS
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            Public Involvement in  the  RCRA Permitting Process-
                                         A  Facility Perspective
                                                    Gordon Kenna
                                        Chemical  Waste Management,  Inc.
                                                  Emelle, Alabama
INTRODUCTION
  Few issues in America today generate more public concern than
that of hazardous waste handling and disposal. By statute, reg-
ulation, policy and  inclination, the U.S. EPA and the states en-
courage public involvement in permit decisions. While the prin-
ciple is well established, there is little agreement on how best to
accomplish the objective.  There  also is considerable debate on
how best to evaluate, respond and act on issues raised by the pub-
lic. As a result, regulatory agencies sometimes find themselves in
the uncomfortable position of being sued on the same issue by in-
dustry for over-regulating and  by  citizen  and  public interest
groups for under-regulating. Moreover, while the agencies have
the ultimate responsibility for making and  defending their de-
cisions, they must consider issues raised by citizens even though
those issues may not be germane to the subject or within the scope
of the regulatory agency.
  With this  responsibility is also the reality that the regulatory
agency does not have the  staff, resources or ability to know the
real community consensus and composition  in depth. As  is well
known, those  who  attend public meetings and  write comments
are nearly always a very small minority of the population. The
majority of citizens who are aware of the issues but do not make
their opinions known are,  more often than not, supportive of the
applicant or the agency's professional judgment. Imperfect as the
process is, it is a fact of life in major regulatory actions.

CITIZEN PARTICIPATION ENHANCEMENT
  The primary variable available to improve the quality of citi-
zen participation is  the owner/operator working with citizens to
promote a full  understanding of the issues. Ideally, this is done at
three  levels  of involvement—the company  in the community,
the company in concert with  similar groups acting as an industry
or trade group and  the company coordinating its approach with
the regulatory agencies.
  Obviously, the industry can and should do more to generally
educate the public about siting and permit issues; but even if this
were to occur, the effects  would be  very limited on specific de-
cisions. This approach is most widely and effectively used in leg-
islative and rule-making activities.
  A coordinated  approach between  government and industry is
certainly a good idea but  is fraught with problems. Aside from
the regulatory resource limitations already mentioned, a cooper-
ative effort often leads to the allegation that the agency and appli-
cant are too close or "in bed with one another." It is, of course,
the nature of a highly regulated industry to have a  close rela-
tionship and intimate knowledge of operations and issues. While
distance must be maintained, the  agencies should do a better job
of publicizing their responsibility and the need for close commun-
ication and coordination.
ROLE OF REGULATORY AGENCY
  At a minimum, the regulatory agencies should plan and dis-
cuss the public involvement program with the applicant well in
advance of implementation. An exchange of information should
include citizen comments received to date, an exchange of any
community relations or public involvement plans, suggestions for
action by either party and  joint informal meetings,  workshops
and information booths to identify issues in advance of a formal
public hearing. The burden  of this activity should be on the own-
er/operator/applicant,  but  the regulatory  community can im-
prove the effectiveness and  "reach" of the program significantly
through their participation. In so doing, the agency also will en-
hance the quality of public comment and its own image as a
public agency.
  In reality,  however, there are severe limits to how much the
government as a regulatory  agency really can participate. Except
in the case of the largest and most visible sites or permit issues,
the agency will be able to provide little more than a cursory over-
view of the community dynamic. It  is the local  site that must
take the lead  for generating understanding that will give way to
acceptance in the  community. Guidance, participation and en--
dorsement from government regulators of this local effort simply
lend credibility and acceptance to the  process. It is most assured-
ly a process and not an overnight sensation.

PUBLIC INVOLVEMENT PROGRAM
  There are  many  considerations in  planning a public involve-
ment program. Among  the most important is timing, and there
are several key elements in that. It is not possible to  start too
early. There will be public involvement sooner or later; the earlier
the public has an opportunity to become familiar with the process
and the issues, the better. One common citizens' complaint is that
there  was no opportunity to be involved until after the major
issues had been cast in a draft permit.
  Public interest at this early stage  may not be evident, so it
usually is necessary to identify those who are potentially inter-
ested  and solicit their participation.  The ultimate objective in
this effort is an exchange of information and ideas—a two-way
dialogue. To  set the stage for this two-way communication, the
community members need  to  feel that it is  early enough in the
process to make a difference, that they are being dealt with open-
ly and honestly and that they have access to information  and to
key regulatory and company personnel.

Communications
  Some of this feeling of openness and availability can be com-
municated by the press; they, too, certainly need to have a regu-
lar and  reliable point of contact and access to key people. It is
very difficult for a complex and controversial issue to be consis-
394    PUBLIC COMMUNICATIONS
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tently well done by the press, but the press can convey the mess-
age that the company is open and invites honest inquiry. Discuss-
ing the  public involvement  strategy with the press  or allowing
coverage of a tour or meeting with citizens can be a good way to
communicate that feeling of openness. Failing to generate  that
feeling of being open  and responsive  seems to make virtually
everyone suspicious and undermines credibility.

Newsletter
  Another means of communicating that open feeling and giving
people information about the operation is through a newsletter
or other general printed information. Although this is a one-way
effort, it is a good precursor for a real exchange. The newslet-
ter is also a good way for the operator to focus attention on issues
of his choice. A newsletter also can  be  used to feature informa-
tion about tours,  meetings with environmental groups, question
and answer columns and other two-way exchanges.  The regular
appearance of a newsletter is also proof  that the facility has made
an effort to  communicate with and  involve citizens. The longer
the newsletter comes out, the more knowledgeable people become
about the issues and people at the facility. Moreover, the reader-
ship  seems to increase  with each issue as the product and place
become more familiar.

Documents Repository
   Another important means of making information available is
a  local  repository for documents, applications, permits and so
forth. Traditionally, these documents have been kept at a court-
house or other government  office (i.e., the local health depart-
ment). Sometimes this "official" repository is not  available to
the public during evening or weekend hours or is not seen  as a
neutral location. A more appropriate location would be a public
library or local  school. The library has the added advantage of
having other research resources available for serious inquiry. In
addition to the required documents  for review and inspection,
other material should be placed on reserve. This reserve list might
include: newsletters and other company  publications; indepen-
dent material such as state  and  federal regulations; and books
and pamphlets on chemistry, industrial hygiene and safety, re-
search reports and so forth. A summary of the important issues
and the process for resolution of these issues also should be avail-
able. A good summary will be sufficient for many people and
can offer a clear  perspective and context for understanding the
issues.
   There are many other means of disseminating information
that are, although basically one-way vehicles, good for educat-
ing citizens about certain activities and people and encouraging
participation in meetings and other "feedback" opportunities.

COMMUNITY RELATIONS
   The  most important opportunity  for generating  community
understanding and confidence  is simply a presence  in the com-
munity. The extent to which facility  management and employees
are integrated into the social fabric of the community is of critical
importance.  First, this means  that  personnel from the facility
should live in and have  roots in the area and be visible and active
in the community. Employee community involvement programs
and a recognition and  incentive system are  good tools for en-
couraging that presence.
  Corporate involvement in community  projects is also an impor-
tant means of demonstrating a commitment to the community.
Without being able to demonstrate that  presence in the commun-
ity and  commitment to citizenship,  other efforts are seriously
hampered. It is important to understand, however, that the objec-
tive is citizen understanding and acceptance  and, in the case of
controversial facilities, much more than community involvement
and a presence is required. The emphasis must be education and
an exchange of ideas.

Tours
  One of the best ways to accomplish this community presence
is to give tours of the plant or facility with ample opportunity
for questions about what is on the tour or any other issues that
might arise. These tours should be personalized as much as pos-
sible to the particular tour groups. Involvement by senior man-
agement in these tours and question and answer sessions is very
important to maximize credibility and commitment to public in-
volvement. The importance of first-hand observations cannot be
over-emphasized; often a facility will "sell itself" on such a tour,
and the strong positive image from such an experience will make
a lasting impression.

Speeches
  Talks and speeches to interested audiences are another way to
reach out to a particular group  and encourage understanding
and exchange of views.  However, it is difficult to have enough
time to cover the major issues and respond to questions as well.
The question and answer session following a talk is probably the
most important part of this kind of effort.

Meetings
  The activities that can be expected to go the furthest in clarify-
ing issues and settling disputes are the small informal meetings
and one-on-one discussions. These meetings may  take  several
forms but have several common characteristics: listening for key
points,  responding to questions and concerns and generally in-
teracting as an equal.
   While the exchange that occurs in these meetings is critical, it is
also important that there be  appropriate follow-up and eval-
uation. These meetings should be targeted for those people who
clearly want to know more and are likely to vocalize their feel-
ings.
   Groups likely to be targeted are environmental organizations,
elected officials, local community organizations, residents, ad hoc
groups  and public interest groups. While it is important to an-
ticipate issues and prepare for them with an agenda  and objec-
tive, it is equally important to make that agenda flexible if the
group demands it.
   It is also  useful to have such  meetings for anyone willing to
come rather than just targeting a particular group. Ideally, these
meetings should be fairly regular, held in a neutral place and have
a specific objective relative to the permit issue. These meetings
are designed to explain the issue and draw out opinion  on the sub-
ject. Once positions are  disclosed, follow-up work is appropriate
to influence or support the opinion.

Information Booth
   A variation of this is an "information booth" approach that
encourages local residents to ask questions or offer  their  opin-
ions on a permit issue. Regulators  have  much more credibility
in this role than operators, but it is an area where the two interests
can work effectively together. This kind of open-ended  small
meeting can be unpredictable but  may  produce unexpectedly
good results.
   An exchange of information is the most powerful and useful
communication that can be used to convince and persuade. Tar-
geting the right audience for this dialog is very important since
the process  is very labor and  time intensive. An even distribu-
tion of public  sentiment might  look like a  "bell curve"  with
communication techniques overlain:
                                                                                           PUBLIC COMMUNICATIONS    395
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                 One way communication:
 Community position, newsletter, press, handouts, perception
                        Neutral
 Speeches, personal contact, information booth, meetings, two-
                         way talks.
  It is the groups predisposed to be against a permit that a small
meeting may be best able to influence. If these groups are iden-
tified and are willing to meet  and discuss issues, some movement
is possible. While these dynamic two-way exchanges are at the
core of the objectives in a public involvement program,  it is the
static  or one-way  information  program  that educates, builds
support and makes the opportunity for an exchange of informa-
tion more meaningful and more difficult to resist.
   Somewhat surprising to those concerned with this activity may
 be citizens who resist such small meetings and will not verbalize
 issues of importance to them. There may be several reasons for
 this including:

 •  Uncertainty about their grasp of technical issues
 •  Unwillingness to disclose their position because of a preference
   to "surprise" the applicant
 •  Unwillingness to believe anything  that regulator or applicant
   says
 •  Unawareness of opportunity
 •  Personal embarrassment and other reasons
   At any rate, many of these reasons become unimportant at a
 public hearing or in front of a television camera. It seems that
 nearly everyone wants to make his  feelings known at that point. It
 is important to become aware of the feelings early so they can be
 identified, responded to and dealt with. Otherwise they represent
 "new" issues  and come as a surprise. If there are  no questions
 from the public, do not assume that  there are no problems.

 GENERAL TO THE SPECIFIC
   As with most problems, work on  the issue should move from
 the general (where some agreement and common ground can be
 identified)  to  the specific (where  differences are most evident).
 Even with  early identification of  issues,  good  listening and
 analytical skills and a spirit of compromises, many problems may
 remain. However, if any semblance of a working relationship has
 evolved  between the two parties, there  will  be room for some
 respect for the other's position and possibly an acknowledgement
 that there is some legitimacy to the position.  If true,  then the
 minimum outcome is  the recognition of having acted  in good
 faith—an important achievement in  and of itself.

 CONCLUSIONS
   In chronological summary, the basic objectives of a public  in-
 volvement program are to:
                                                          •  Inform
                                                          •  Educate
                                                          •  Target
                                                          •  Listen
                                                          •  Respond
                                                          •  Follow  up
                                                            This movement and trend toward negotiation and mediation of
                                                          environmental issues directly between citizen groups and corpora-
                                                          tions is clearly a positive development. Certainly it is more effi-
                                                          cient than litigation and through early identification of the issues
                                                          can go a long way to help prevent problems.
                                                            In  the RCRA permitting process, however, it is especially im-
                                                          portant to begin this process of exchange and negotiation early
                                                          enough to accomplish the major objectives before the public hear-
                                                          ing process has  run its course. The process needs to be open-
                                                          ended to the extent that the agenda may include new issues raised
                                                          during the process and  may continue indefinitely past the hearing
                                                          dates, but some priority for dealing with major differences should
                                                          be established.  Initially,  those priorities should  be outlined,
                                                          ranked  and agreed upon by both parties.  Any area of agreement
                                                          and  common ground  related to this issue should be used as a
                                                          preface and introduction to begin talks.
                                                            If agreement fails to emerge  from this process after a consis-
                                                          tent,  determined  effort,  the participants still are rewarded for
                                                          having tried. Some of these benefits are:

                                                          •  Respect from  all sides, especially from press and public, for
                                                            initiating  a good faith effort
                                                          •  Improved public understanding
                                                          •  A narrower range of critical comments
                                                          •  A lack of surprises in the hearing process

                                                            There is no substitute for an early start  to educate, inform and
                                                          involve the public in RCRA permit decisions. There is no magic
                                                          recipe for success either. Each approach should be specific to the
                                                          community  involved and to the nature of the permit under ap-
                                                          plication.  The goals of  a program generally are consistent and in-
                                                          clude such things as:
                                                          •  Being open to inquiry
                                                          •  Being responsive and flexible
                                                          •  Making a real effort to inform and educate the public
                                                          •  Anticipating issues and being prepared
                                                          •  Being cooperative with the community
                                                          •  Being innovative and creative with new techniques
                                                          •  Being persistent in your efforts
                                                            While these are elements in a  community based program, these
                                                          elements also are applicable to working with the press.
                                                            A  closing thought—not an afterthought.  There is a natural
                                                          tendency to concentrate on those who are contentious since that is
                                                          where the conflict and the interest are found, but it may be just as
                                                          important to work with those who are neutral or likely to be sup-
                                                          portive of the application. There are several reasons for this posi-
                                                          tion: (1) the neutral group frequently includes the majority of the
                                                          citizens and hence usually is neither organized nor recognized; (2)
                                                          this group can give the regulatory body a bigger "comfort zone"
                                                          in which to make a decision; and (3) people  often want to help,
                                                          they simply do not  know how to do it.
                                                            This   neutral  group   may  include   customers,   suppliers,
                                                          employees,  elected officials, industrial development groups and
                                                          others.  Many of them are your friends;  at least let them know
                                                          what you are going through and what they may be able to do to
                                                          help. In the final analysis, we are all in this effort together and we
                                                          need support and understanding wherever we can find it.
396
PUBLIC COMMUNICATIONS
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                                  Public Participation  in  Siting
              Hazardous  Waste Management Facilities  in  Alaska
                                                Sharon O. Hillman
                                       Sohio Alaska Petroleum Company
                                                Anchorage,  Alaska
ABSTRACT
  Hazardous waste management remains a major controversial
issue in Alaska. The RCRA amendments provided impetus for
immediate action on the issue of disposal of hazardous waste. The
State of Alaska was directed by the Alaska Legislature, specif-
ically the Committee Substitute for Senate Bill (CSSB) 503, in
June of 1984 to address the problem of hazardous waste dis-
posal.
  Alaska Statute (AS) 46.03 assigns the Alaska Department of
Environmental Conservation  (DEC) the responsibility  to study
and identify a viable hazardous waste management and disposal
facility for Alaska. This task is a large undertaking with consid-
erable opportunity for controversy among various interested par-
ties. One approach would be to address the issue actively with
public participation from various groups including  state agencies,
local government, environmental groups  and industries. The
group could assist in the development of action plans and pro-
vide recommendations for the best options for in-state hazardous
waste management facilities including disposal.

INTRODUCTION
  The  1981 Alaska State Legislature passed a law (Chapter  93
SLA 1981)  requiring the Alaska Department of Environmental
Conservation (DEC) to develop hazardous waste  regulations at
least equivalent to the requirements of the  federal RCRA.  Such
regulations would be the basis for a federally approved hazardous
waste program in Alaska. In order for Alaska to be in a position
to receive RCRA authorization, the U.S. EPA determined that
the original state legislation must be changed to provide  civil and
criminal penalties of at least $10,000 per day. This legislation was
introduced in the 1984 Alaska Legislature, and several bills affect-
ing the DEC hazardous waste program were introduced as a re-
sult. Eventually, the chair of the Senate Resources Committee
proposed merging the bills into one compromise bill (CSSB 503)
to address the diverse positions of the parties. The compromise
legislation, which was  passed into law, included  the following
three points:
• DEC shall develop and implement a program to educate busi-
  nesses and the general public about their responsibilities under
  the regulations.
• DEC shall evaluate and select in-state sites for hazardous waste
  management.
• DEC shall track the transportation of hazardous waste through
  the state.
  These points were based on input from the Hazardous Waste
Advisory Work Group (HWAWG), an advisory committee to the
state. The HWAWG group was originally formed in 1982 and met
throughout the year to address the 1981 legislation and provide
input for developing regulations. In addition to the DEC staff,
the group included representation from the Associated General
Contractors, the Alaska Oil and Gas Association, the Alaskan
Air Command, the Alaska Center for the Environment, the Sierra
Club, the League of Women Voters, the  Alaska  Federation of
Natives, the Alaska Truckers Association and the Alaska Public
Health Association. The new Alaska legislation and accompany-
ing funding renewed the process for a comprehensive hazardous
waste program. New mandates address not only the problems
of hazardous waste generated by businesses, but also those of
household waste, tracking waste shipments and hazardous waste
disposal facilities.
  The ability of the states to implement and enforce the RCRA
program adequately is the subject of controversy.  Until and un-
less a state is authorized by the U.S. EPA  to implement RCRA,
the U.S. EPA is required to implement the RCRA regulations, in-
cluding the issuance of permits for waste storage, treatment and
disposal facilities in that state.
  RCRA regulations primarily address the permitting and oper-
ating of hazardous waste  management facilities. RCRA does not
specify the process for selecting a hazardous waste management
site. However,  RCRA does state that certain regulatory require-
ments must be met before hazardous waste  management activities
may be  performed legally at the  site. Several states have estab-
lished programs for siting hazardous waste management facilities.
These programs generally specify  the process to be followed in
selecting a site, provide for public participation and determine the
role of state and local government in site selection and permitting.
  Many hazardous waste management facilities may require state
and federal permits or approvals in addition to the RCRA facility
permit(s).  These  permits  may govern: facility construction, air
pollution emissions,  water usage, wastewater discharge, under-
ground injection or disposal, highway rights-of-way and leasing
of state lands.
  The 1984 Amendments to RCRA have further forced the siting
issue to the forefront. The 1984 Amendments address the phase-
out of land disposal for hazardous  wastes, greatly increase the
number of hazardous waste generators by lowering the regulated
quantities, require the study and listing of additional materials
as hazardous waste, add a citizen's suit provision and increase
the penalties for  violations. The amendments increase the costs
and decrease the options currently available for disposal in the
lower 48 states. Currently, no disposal site  is available in Alaska;
however, many generators exist, and a site is needed.
  An evaluation of a proposed facility should include an assess-
ment of the need for hazardous waste management facilities of
some sort (what's generated, where and how much).  Additional
                                                                                       PUBLIC COMMUNICATIONS    397
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concerns to be addressed include whether the proposed facility
represents  the  most appropriate technology  for  handling  the
particular wastes generated and whether the location proposed
for such a facility  is suitable given environmental, social and
economic concerns in Alaska.
  There are three basic types of facilities which may provide in-
dependent or complementary management:
• Storage—holding  the  waste  prior to  treatment, disposal  or
  transportation to another state
• Treatment—turning the waste into something less hazardous
  or reducing its volume
• Disposal—final placement of waste
  The siting process should:
• Be well thought out by government agencies, the Alaskan pub-
  lic, industry and potential site developers
• Provide for early and full public information and participation
• Be understandable to tne public
• Provide  the public with accurate information concerning the
  benefits, risks and alternatives to a proposed facility
• Address the legitimate concerns of all parties
• Be a shared consultative process among site developers, facility
  operators,  communities,   government  agencies  and  other
  affected parties
• Provide  opportunities  for all concerned to negotiate areas of
  dispute
  Hazardous waste management sites are needed within the state
boundaries. Landfills, injection wells and process facilities all are
becoming more strictly regulated. Proper design, siting, permit-
ting and construction of a hazardous waste disposal facility could
take more than  10 years. Alaska must start now and not plan to
send its wastes to other states.

COMMUNITY INVOLVEMENT IN FACILITY
SITING—THE PROBLEM
  Environmental and health problems resulting from some  im-
proper hazardous waste management practices have caused peo-
ple to raise legitimate concerns about the nation's ability to man-
age  hazardous   wastes  effectively. Appropriate  technologies
should be applied at environmentally acceptable storage,  treat-
ment and disposal locations for hazardous waste. Public informa-
tion and participation programs that include the public early in
the siting process are increasingly viewed as necessary  steps for
addressing public concerns and for public acceptance of the tech-
nologies. The fact that hazardous wastes can be dangerous and
that the management of hazardous waste  is a highly  technical
area has been well documented.
  Another problem  with  the siting  of hazardous waste facilities
is the  "not in my back yard" syndrome—which has stopped the
permitting  of many  otherwise acceptable sites.  The fact that no
one wants to live near a hazardous waste facility further empha-
sizes the need for public participation in the siting process.

THE PROCESS
  Components  of  public information/participation programs
that facilitate negotiation, cooperation  and dispute resolution
can help overcome mistrust and skepticism and avoid legal con-
flict. Once a facility has been proposed, there may be only a short
time to institute dialogue before polarized viewpoints are  estab-
lished. Dialogue should be based, among other things, on cred-
ible information about the environmental integrity of a site, the
need for the facility, the performance characteristics of the facil-
ity and the financial stability and competence of the facility oper-
ator. The real challenge to industry and government is to provide
the public  early in  the  planning process with non-adversarial
points of contact that can reduce polarization and provide an
opportunity for addressing questions and concerns with candor
and clarity.
  What is being  suggested is the need for consensus  building
through an innovative process of private and public cooperation.
This is an important starting point which will:
• Foster positive involvement and dialogue among the interested
  and affected parties
• Help focus the issues and narrow the areas of real disagreement
• Provide ideas and information that may improve the quality of
  solutions and facilitate decision-making
  For hazardous waste management facility siting in Alaska, the
1984 legislation mandated  the consideration of several factors in-
cluding:  economic  feasibility,  intrinsic suitability of the site,
pollution control regulations, the risk  and effects on local resi-
dents, consistency of a facility with local land use planning and
potential adverse effects on agriculture or natural resources.
  The design of a  public information/participation  program
communicates how  much  the public's  involvement is valued or
desired. Providing information and avenues of response to pub-
lic concerns may  earn  public approval of the facility, result in
changes that make the facility  acceptable or justify disapproval of
a proposed facility. Regardless of the outcome, the actions will
help the community and the  state to  make decisions which en-
sure that new facilities will  be as safe as possible.
  RCRA has established the following procedure for public par-
ticipation after the notice to issue a draft RCRA permit is estab-
lished:
• The intention to issue  a draft RCRA  permit  must be pub-
  lished in major newspapers or  broadcast over local radio sta-
  tions
• This notice of intent  must  be sent to each unit of local gov-
  ernment that has jurisdiction over the area where the facility is
  proposed and to each state agency with authority over the con-
  struction or operation of the facility
• At least 30 days  must  be  allowed  for  comments on a draft
  permit
• Hearings are required, if requested, within 45 days of public
  notice of intent to issue a draft RCRA permit
• Public notice of  a hearing must  include, whenever  possible,
  the date, time, location and nature and purpose of the hear-
  ing. The hearing must  take  place  in  a location convenient,
  whenever possible, to the population center nearest to  the pro-
  posed facility.
• A fact sheet for every draft hazardous waste permit  must be
  prepared by the chief officer for the state's U.S. EPA-approved
  program, if the officer  finds  that the permit application is of
  widespread public interest or raises major issues.
  Since the State of Alaska has not yet promulgated siting regu-
lations, conditions for confrontation rather than cooperation are
enhanced. It  is  important for  individuals and groups to meet with
appropriate State officials to  encourage the development of a sit-
ing process and to open up the decision-making process in a way
that seeks public involvement, keeps the public informed and in-
corporates viable suggestions about  decisions that may affect
public health and the environment.
  State and  local government officials and potential site devel-
opers should recognize the planning and providing opportunities
for all concerned to participate in a proposed project will facil-
itate timely siting decisions that are supported by the community.
An important  aspect of the  process involves assuring the pub-
lic that its concerns will be considered, and, when appropriate,
will  influence decisions on whether or how to proceed  with the
siting and operation of a hazardous waste management facility.
398    PUBLIC COMMUNICATIONS
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THE PARTICIPANTS
  Participants in the siting process range from the general pop-
ulation to community leaders to those who may have a particular
interest in or may be affected by siting decisions. Serious efforts
must be  made  to inform, involve and respond  to these some-
times overlapping groups during different phases of a public in-
formation/participation program. Possible participants are:
• Public representatives:
  -Public officials, both elected and appointed
  -Federal, state and local government agencies
• Generators and Users:
  -Businesses and industries
  -Hazardous waste generators
  -Site developers and facility operators
  -Property owners in the vicinity of the site
  -Consulting scientists, engineers and other experts
• Public and Interested Parties:
  -General public
  -Public interest groups
  -Environmental and conservation groups
  -Local scientists and engineers
  -Ad hoc citizen groups
  -Civic associations
  -Community and religious groups
  -Consumer groups
• Other Organizations:
  -Trade, industrial, agricultural and labor organizations
  -Public health, scientific and professional societies
  -Educational institutions
  -Media, including editorial boards

THE TECHNIQUES
  The use of early and broad public information and consulta-
tion techniques will inform interested parties about the facts of a
proposed facility and may help to narrow areas of potential con-
flict and promote understanding. Many  fears about  sites  are
based on unknown factors or concern that another "Love Canal"
will result without the people having any input, therefore exten-
sive public education and input programs are essential. Whether
information and participation programs are designed by  govern-
ment regulation or by community/developer interaction, numer-
ous techniques may be used  to encourage understanding and
evaluation of a proposed siting project:
• Information Dissemination:
  -Fact sheets
  -Agency and interest group newsletters
  -Education of the media for proper use of use of print, radio
   and TV education
  -Letters to people on mailing lists
  -Information centers and public libraries
  -Spring Cleanup  (agency-sponsored  hazardous waste collec-
   tion)
  -Hotlines
• Consultations:
  -Advisory committees drawing on  major interest groups and
   representatives of the affected local community
  -Technical advisors
  -Public workshops for large and small group discussion
  -Public opinion surveys
  -Small group meetings covering specific concerns
  -Use of models
  -Public tours and walk-throughs of facilities
  The critical influence of the facility's type and location on the
potential  for adverse environmental impacts makes it important
to have comprehensive state or regional siting criteria and man-
agement plans for hazardous waste facilities. These criteria and
plans should be developed with public participation and should
identify, based on hazardous waste management needs and en-
vironmental sensitivity, the most environmentally acceptable type
of facility and location for the state.
  The plans must be realistic in  evaluating what is technically
feasible and economically supportable given the type, quantity
and  generation rate  of hazardous waste. The Alaska DEC re-
cently has initiated such a plan for Alaska. The  first part of this
plan includes  a  "Waste  Disposal Study" to be completed by
January 1986,  and a  second study, "A survey of Approaches by
Other States in Establishing Criteria for the Location of Haz-
ardous Waste Facilities," also to be completed in January. Both
of these studies are in support of the draft regulations to be issued
in early 1986.

COSTS AND BENEFITS
  A community may experience increased costs as a result of the
new facility. One major concern is the remote possibility of health
and  environmental injuries that may  arise if there  are releases
from the facility. Other increased costs may be related directly to
the site: security patrols, fire equipment and new tasks for fire
and police personnel. For example-, a small local fire department
or hospital might need new equipment and different or additional
training to handle emergencies related to the facility.
  While the developer and/or  operator of  a hazardous waste
facility is interested in  a profitable investment as well as a safe
and effective business, the community's prime concerns relate to
health, quality of life and property values. If the proposed  facil-
ity is viewed as a threat to these values, the community may want
some sort of community benefit in return for accepting the facil-
ity.
  The community may request the operator to provide funds for
services related to the facility including additional fire-fighting or
hospital equipment or improved roads in the vicinity of the site.
Alternatively, the developer or operator could contribute a fixed
sum to the local government for needs that may arise in connec-
tion with the project. Another solution could be a type of sales
tax whereby the operator would pay a fixed percentage of oper-
ating revenues  to the local government.
  These additional costs,  whether a part of the initial investment
or a part of higher operating costs, will add to  the general eco-
nomic feasibility of the project. As such, it is very important in
studying the project economic viability to address all costs at the
very beginning. In some cases, the state may  assist the local gov-
ernment in mitigating potential community impacts,  especially if
they encompass a larger area or population such as would be the
case in Alaska.

CONCLUSIONS
  The key to developing a good program which involves the pub-
lic in the siting process must:
• Provide adequate information to the community
• Provide a means to listen to and address the community's con-
  cerns
• Develop sound methods of interaction among all interested
  parties
  Communities have developed their own task  forces, advisory
committees, information systems and other educational and com-
munication methods. Volunteer leaders have been used to work
with site developers,  facility operators and the government. Po-
tential sources of funding for community participation programs
are government, civic,  industry and other groups. The goal is to
develop a program which will work effectively toward a disposal
                                                                                           PUBLIC COMMUNICATIONS    399
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 answer for the state while enhancing the cooperation and direct-
 ing the efforts of all interested parties toward the right answers.
   Introduction of the public  to  hazardous waste  management
 facilities and siting options could create a greater  appreciation
 and knowledge of the  complexity of properly managing haz-
 ardous waste  in  Alaska. Several objectives would be accom-
 plished including bringing  more  affected entities into the dis-
 cussions, educating the regulators to practical application and
 focusing  the hazardous waste issue on  an area  of common
 ground. This process should lead to a viable hazardous waste dis-
 posal option in Alaska.
   The Hazardous Waste Advisory Work Committee should be re-
 established to work with the DEC in developing a plan of action
 for disposal option(s) and site(s) in Alaska. The committee would
 include  representatives of state agencies, local governments, en-
 vironmental groups, industries and the state legislature. The draft
 regulations currently being  developed should be shared with this
 group to get early input prior to  the legislative deadline of July
 1986 for the adoption of regulations. The State DEC should con-
 tinue its current effort to use newsletters,  fact sheets and spring
 cleanups to promote the  local education process.
   A  balanced picture of  the hazardous  waste  threat  to the
 Alaskan environment and its people is an important perspective
 for the State to consider. The current DEC study will help answer
 this question. A strong emphasis on the conservation and recov-
 ery aspects of the Resource  Conservation and  Recovery  Act
 (RCRA) program  will provide direction for the Alaskan agencies,
 public and industry to educate each other about the hazards  in-
 volved and to minimize the  hazards (by reduction and treatment)
 to the maximum  extent  possible. And last, but  not  least,  one
should recognize that this is not  a one-time education process,
but one that is required on a continuing basis for all of us to live
in our world, together.
REFERENCES
1. Fawcett, H.H.. Hazardous and Toxic Materials, Safe Handling and
   Disposal, John Wiley & Sons, New York, NV, 1984.
2. Peirce, J.J. and Vesilind. P.A., Eds, Hazardous Waste Management,
   Ann Arbor Science Publishers, Ann Arbor, MI, 1981.
3. Quarles, J.,  Federal Regulation of Hazardous Wastes, A Guide  to
   RCRA,   Environmental  Law  Institute, Washington,  DC,  1982.
    (RCRA," 42 U.S.C. 6901-6987 1986 and Supp. Ill 1979) as amended
   by the Solid  Waste Disposal Act Amendments of 1980.
5. Rodgers,  W.H., Jr.,  "Directions  of Environmental  Law  in the
   1980's", presented at the Hazardous  Waste Law and Management
   Conference,  University  of Washington Law School, Seattle, WA,
   1984.
6. The Committee Substitute for Senate Bill 503 (Finance), in the Legis-
   lature of the Slate of Alaska. Thirteenth Legislature—Second Ses-
   sion (CSSB 503). May 25, 1984.
7. The Conservation Foundation, Siting Hazardous Waste Management
   Facilities.  White Plains, MD, 1983.
8. The Hazardous and Solid Waste Amendments of 1984, Title II, Pro-
   visions Relating Primarily 10 Subtitle C of the Solid Waste Disposal
   Act (Subtitles A, B and C)
9. Wood,  L.,  "Alaska  Department  of Environmental Conservation
   Hazardous Waste Management Program  Annual Narrative, 1983-
   1984," Proc. Hazardous Waste Law and Management Con/., Uni-
   versity of Washington Law School, Seattle. WA, 1984, 258-273.
400    PUBLIC COMMUNICATIONS
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              Developing  a  Comprehensive  Public  Affairs Policy
                     for  New and  Existing Industrial  Operations
                                                   Ann E.  Burke
                                           Environmental Impact, Inc.
                                             Baton Rouge, Louisiana
ABSTRACT
  The primary public affairs policy problem faced by most indus-
tries involved in the handling of hazardous wastes/materials is
simply devising specific programmatic approaches to the desired
audiences. This paper offers specific program suggestions for five
groups defined as the most important audiences for an industrial
public affairs program: the Media, the Community, Government
officials, Customers and Employees. The focus of the suggested
strategies is the constructive dissemination of unbiased, technical-
ly sound information to all these groups.

INTRODUCTION
  Your secretary buzzes your office. You detect a note  of trepida-
tion in her voice. Suddenly, the dread words waft over the inter-
com..."Mr. Johnson—there's a Morley Safer here to see you...
and Mr. Johnson, he wants permission to film while he talks to
you...Mr. Johnson?...Mr. Johnson!...."
  There are four possible outcomes at this point:
• With luck, you will wake up.
• You will refuse comment and be made to look like Attila the
  Hun on next week's Sunday night broadcast.
• You will go into the interview unprepared and watch  yourself
  be battered by the reporter who has already researched the en-
  tire story, who has made up his mind about the guilty party
  (undoubtedly you) and who is only in your office to fulfill his
  "ethical" duty to get your rebuttal.
• You will be prepared for  the interview since one of  your com-
  munity contacts  will have alerted you  days earlier that the
  "60 Minutes" crew  was in town. Your staff will have ap-
  proached the crew and offered them  access to your facilities
  and personnel. Your  interview  will be your opportunity  to
  make a coherent and well researched statement about the issue
  at hand.
  To many of you, this final outcome seems unlikely at best. Yet,
it is my  firm belief that structured, organized and  well-directed
public affairs policies can produce a positive scenario such as that
I have recounted.
  To most industries, the advantage of anticipating the inquiries
and needs of their public has been ignored or overlooked  in favor
of adopting reactive public affairs postures. We allow the story on
our new waste incineration process to be "uncovered" by the
media and thereby sensationalized without benefit of fact or our
own point of view. We meet our  community in a forum of litiga-
tion rather than negotiation, thereby immediately casting  our-
selves  as the uncommunicative, overbearing industrial warlord.
  1 would like to recommend several very specific program strat-
egies that can be implemented to begin to  change our public re-
sponse posture from reactive to anticipatory and constructive. I
have had the opportunity to design and administer many of these
programs  for  one of  the  major waste disposal  companies,
CECOS International. I have since designed similar programs for
other clients and have seen  the positive impact that a well de-
signed outreach program  can  have on industry's image in the
community.

INTERNAL STRATEGIES—THE FIRST STEPS
  The focus of your public affairs policy should be sharply and
clearly delineated prior to  structuring the actual programs.  New
projects will require different  strategies from existing projects.
Although this  may seem obvious, it  is extremely important to
understand that while you may have the opportunity to shape and
direct perceptions about a new project, you will have to acknowl-
edge and accept perceptions about existing operations.
  I suggest that a small (no more than four people) committee be
formed and given one full day to:
• Describe the project
• Describe the need for the project
• Outline any community impact (positive and negative)
• For a new project,  describe the desired perception of the pro-
  ject by the community.
• For  an existing project, describe present perceptions  of the
  project and desired perceptions.
• Select a Public Affairs Representative for the project.
  Above all, it is important to be realistic in your goal  setting
with regard to the project. For example, you will never get 100
people to turn out at a public  hearing to voice their enthusiasm
for a new hazardous  waste site. However, you may be able to
minimize the number  of opponents to the  project by disseminat-
ing clear, straightforward project information to the public.
  Once a Public Affairs Spokesperson has been chosen, resource
people should  be selected. It is important to have at least one
management and one technical contact for the  Spokesperson.
These people will be  kept continually informed by the Spokes-
person and will be prepared to handle special interview situa-
tions (press conferences, technical journal interviews, etc.). Con-
versely, these resource people will serve as cotiduits to the Spokes-
person for new project information.
  After the  foregoing has been established, the  Spokesperson
can begin to develop  a Comprehensive Public Affairs Policy. I
will outline some specific ideas for  such a  program in  the re-
mainder of my presentation.

IDENTIFYING THE AUDIENCE
  You will note that I have selected five target audiences  for my
policy  archetype:  Media,  community,  government officials
(elected and non-elected), customers and employees. I would like
to comment briefly on specific suggested contacts within these
general groups.
                                                                                       PUBLIC COMMUNICATIONS    401
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Media

• National Media: National magazines,  national newspapers
  (USA Today, Christian Science Monitor, Wall Street Journal),
  network news, CNN News (they will cover what others do not),
  national radio shows (Talk Net,  Larry King,  National Public
  Radio)
• Local Media: Local television (contact all local talk and inter-
  view shows—do not forget PBS), newspapers (do  not forget
  Pennysavers, small community tabloids), local magazines  (es-
  pecially Chamber of Commerce  and business  oriented tab-
  loids), local radio (especially all-talk and all-news  formats),
• Trade Media: National and local trade journals  (Chem-week,
  various industrial/regulatory newsletters)

Community
• Citizens within your immediate community or some specified
  radius of your facility. Address lists can be purchased by zip
  code.
• Professional Groups and Societies
• Fraternal  Groups:  Lions,  Rotary,  Kiwanis  Clubs,  Garden
  Clubs, PTAs
• Schools

Government Officials
• Elected and Non-Elected (the Sewer Board,  the Planning Com-
  mission, the Health Inspector, etc.)

Employees
• The most valuable and most under-utilized resource that you
  have. Certain programs also should include your employees'
  families.

SUGGESTED PROGRAMS
Programs for the Media
Facility Tour and Press Conference
  This obvious  and  tremendously valuable  strategy  is almost
never implemented in an organized fashion  by  industries. It is
most important to familiarize media personnel with your facility
and/or project. By conducting a tour, you are allowing access to
the press as well as getting an opportunity to tell your company's
story.  Without sanctioned access, the media will  portray your
company as a series of locked gates and employees hiding their
faces. By arranging constructive photo opportunities with a sub-
sequent press conference, you will be able to  direct the image of
your company/project as it is fashioned by the media.
  I suggest that a tour-related press conference be conducted and
directed by the Spokesperson. The CEO and technical resource
should be available for specific press inquiries as directed to them
by the Spokesperson.
  At  the time of the Press Conference, a carefully constructed
Press Guide should be distributed. This Press Guide should con-
tain:
• A company history
• Brief biographies of top management
• Economic impact of the project
• Description of the project
• Reproducible diagrams or charts
• Name  of contact  person (with  home and office  telephone
  numbers)
Press Releases/Story Opportunities
  Press releases should be an on-going part of any  Public Affairs
Program. All research programs, promotions, earnings  reports
and new technologies should be subject to press releases.
 Story  opportunities  should be presented to  individual media
 members as they occur. Story opportunities can present anything
 from interesting employee/public interest stories to exclusive in-
 formation on acquisitions or new technology breakthroughs. Re-
 serve your  "story opportunity"  approaches to the media for
 especially interested cases.
 Individual Relationships with the Media
   One of the  first responsibilities of any Project Spokesperson
 should be to develop an individual relationship with those mem-
 bers of the  media with which he/she most frequently interacts.
 Personal facility  tours and meetings enhance not only the re-
 porter's knowledge of the facility, but also serve  to foster a per-
 sonal acquaintance between the reporter and the Spokesperson.
 It is much more difficult to write a totally biased story about a
 company  when  you have  had personal contact with  its  em-
 ployees.
 Meetings with Editorial Boards
   Each large newspaper has a select group of personnel who com-
 prise the Editorial Board. The Board selects the topics and view-
 point for the papers' editorials. I have found meetings with  Edi-
 torial Boards to be the single most helpful tactic in receiving posi-
 tive  press coverage. Editorial  Boards should be briefed on the
 project/company by the CEO and the Spokesperson.
   In the case of existing projects and facilities, samples of un-
 fair coverage by the  paper  should be assembled and discussed.
 A succinct but professional  presentation on the project should be
 made. Full contact information for any future inquiries should
 be readily available.
 Technical Resource Center
   The media should  be made aware that all the company  per-
 sonnel are available for technical  consultation or project or re-
 lated technical issues. At CECOS, we were able to have several of
 our staff used as experts by the media in articles relating to  gen-
 eral hazardous waste issues. All company reference and research
 materials also should be made available to the media.
   Both of these programs lend technical credibility to your  per-
 sonnel and organization as  well as giving your company stature
 as an expert in the field.
No, No Comment
   It  is my policy  to advise  clients against ever adopting a  "no
 comment" stance except in cases under litigation. The public  per-
 ceives "no comment" responses as one of three things:
 •  You do not  know the answer and are uninformed about your
   company's affairs
 •  You are hiding something
 •  Both of the above
   You cannot  benefit from  a  "no comment" response.  I recom-
 mend that if anyone is faced with a question he does not feel qual-
 ified or inclined to answer at  the moment, he should get the re-
 porter's name and number and give him a response at a later  (but
 definite) time.  Do not be afraid to tell the press that you do not
 have the  facts with you, but that you will assemble them and re-
 spond later. Another alternative is to offer a full interview the
 next day rather than an answer to a single question. Be resource-
 ful—but always comment.

 Programs for the Community
 Facility Tour and Open House
   Most people who vehemently oppose a project or facility  have
 no idea what such a facility looks like or what takes plate at  one.
 Therefore, the first community program that should be imple-
 mented is the  facility tour and open house. The tour should be
402    PUBLIC COMMUNICATIONS
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held on a Saturday and always should be preceded by a full pres-
entation on the company, its history and facilities. The tour
should be followed by an open question and answer session with
company personnel.  The names  and addresses  of all attendees
should be recorded and kept for future activities and mailings.
  The  Open House should be advertised in all local papers, and
all local media should be invited to cover the event.
Openline
  A toll-free number of citizen inquiries should be established. I
resist the title of "hot line" because I feel it is associated with
some  type  of disaster—"openline" has a more informational
overtone. All inquiries received on the Openline  should receive a
written followup response.
Directed Mailing Program
  A program of directed mailings to the community should be
implemented either immediately after the announcement of a new
project or to address specific issues related to an existing project.
   Examples of topics for directed mailings might  include:
•  Economic impact of the facility on the community (taxes, pay-
   roll, vendors, etc.)
•  New technological  developments
•  Industries dependent on this facility—service performed for in-
   dustries
Community Newsletter
   This newsletter should be published quarterly for  distribution
to the targeted citizens and citizens' groups in  the community.
Some suggested topics include:
•  New facility development
•  Profiles of employees (spotlight personal and professional in-
   terests)
•  New technological  developments at your facility
•  Recent community events
•  Community contributions by the company
   There should be some response  mechanism in the newsletter
—a prepaid card  for comments, requests for tours or speakers,
etc.
Speakers' Bureau
   Employees with specific expertise should be identified and in-
volved in  a Speakers'  Bureau.  A brochure  listing all available
topics should then be distributed to all professional, fraternal,
civic and educational organizations in the community. Be certain
to include employees  vocational and avocational interests.
Financial Contributions to Community Causes
   In most organizations, contributions to community causes  are
made without thought to their overall impact. In many instances,
$100 and $200 contributions  are made without being part of a
larger  focussed giving program. For example, at  CECOS we were
able to identify over $10,000 per year  in contributions that were
being  distributed without an overall giving  strategy. Once this
amount was identified, we selected one major, visible community
project for funding. We provided matching funds for a project to
buy a new fire truck  for the community in which one of our dis-
posal sites was located. This single contribution had a much more
far-reaching and visible impact on the community than a  series
of $100 and $200 contributions.
School Programs
   Secondary schools, colleges and  universities  always  welcome
speakers from local industries. Contact department  chairmen as
well as placement and guidance  counsellors with Speaker's Bur-
eau information.
   For secondary schools, a company sponsored essay contest on
the environment will highlight the company's involvement  in the
community and provide an excellent media coverage opportunity.
Household Chemical Disposal Days
  For industries with disposal facilities, a day for the free dis-
posal of household chemicals will highlight the pervasive problem
of hazardous materials in our society.

Programs for Government Officials
  As discussed previously, tours and open houses are one of the
most effective mechanisms for removing the mystique surround-
ing your operation.
  In general, major elected officials should have personal tours of
the  facility while others, such as a Town Council, can  receive
group tours. Meetings  with top  management officials  always
should follow these tours. Special emphasis on the economic con-
tributions of the company to the community should be made.
  A systematic program of followup contacts  should be estab-
lished following the tours. A contact person in the organization
should be selected and identified for all governmental inquiries.
  The personnel and reference resources of the company should
be detailed for government officials and made available to them
for  legislative  research.  Expert witnesses also  should be made
available.

Programs for Customers and Vendors
  Customers and vendors can be an important source of sup-
port within  the  community. Customers, in  particular,  can be
valuable  resources at public hearings and can help focus atten-
tion on the importance of your facility/project to the community.
Many of the aforementioned programs (Open Houses, Tours and
Newsletters) would have  obvious benefit to your customers. I also
would suggest  that you distribute periodic legislative updates to
your customers. The development of structured lobbying organ-
izations in response to specific legislative proposals will augment
the credibility of your leadership within the industrial community.

Programs for Employees
Tour of Your Facility
  A survey conducted at CECOS revealed that  over 70% of our
office personnel had never visited our disposal  site—despite the
fact that it was only 20 min away. After a full  day of tours  and
presentations for our employees, we got  a universally enthusiastic
response. An extensive period of questions and answers followed
the  tour  and presentation.  Afterward,  people  commented that
they felt  much better equipped to act as advocates for the com-
pany.
Newsletter for Employees
  A newsletter can serve as a vehicle  for developing company
morale as well as a tool for  disseminating information about
new technological or financial programs  for the company.
Employee/Legislative Liaison Program
  All employees living in the immediate area of the facility should
be asked to  make contact with their various legislative represen-
tatives. When specific legislative issues arise, employees can be
asked to write or call their legislators.
CONCLUSIONS
  I hope this paper has convinced you to take the first step to-
ward  establishing a comprehensive  public affairs program for
your organization. If you do not, you will condemn yourself to
repeating the same reactive posture you always have taken with
the press and the community—with the same unsatisfactory re-
sults.

  And, who knows, this time Morley really may be outside the
door.
                                                                                           PUBLIC COMMUNICATIONS    403
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                        Behind the  "F" in  Public  Education  for
              Hazardous Waste  Management:  A  Case for Special
                  "Tutoring"—Plus Some Tips  for Better  Grades
                                               Howard A. Coffin
                                                 Patricia Hunt
                                        Fanfare Communications, Inc.
                                          Philadelphia,  Pennsylvania
                                               L.T. Schaper, P.E.
                                                Black & Veatch
                                             Kansas City,  Missouri
 ABSTRACT
   In recent years, engineers and waste management companies
 have been winning the battle of technology but losing the war of
 public opinion. Hundreds of waste management projects have
 been scuttled  in the face of overwhelming public opposition
 traceable to the waste management industry's inability to com-
 municate its side of the story with any real impact or credibility.
 Engineers and waste management technicians have some built-in
 limitations in this regard, but they can learn to do better—with
 some professional help and some practical tips contained in this
 article.
Where jrubl.ir acceptance in concerned, nil ounce of
is worth a i>oun
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 American industry doesn't care how  many wells it poisons or
 what it does to the air we breathe.
   These sizeable handicaps notwithstanding, the hazardous waste
 management industry is still the leading culprit in the failure of
 public education. Talk about "slow to learn!" Over and over
 again, companies in  the waste management field  have invested
 huge sums of money  in feasibility studies, geologic surveys, pro-
 perty acquisitions and design and engineering fees, only to have
 their projects fail the test of public acceptance. But while be-
 moaning the fortune that keeps going down the drain, and know-
 ing full well that public relations and politics, not  technology, is
 the problem, the industry still refuses to spend any real money for
 professional public relations and marketing help. Instead, it has
 tackled  the highly specialized task of public acceptance  on its
 own. Countless companies turn to  outside help  only after com-
 munity opposition already has become so impacted that the pro-
 ject is doomed to failure.
    Judging from its abysmal record, one would think the industry
 would finally admit that the engineers, scientists and other experts
 who are so  knowledgeable about the technology of hazardous
 waste treatment have a lot to learn about how to sell the public on
 their plans. Not only  do they have a lot to learn, most of them are
 constitutionally ill-equipped to do the job themselves. Here's why
 the technical experts  can't hope  to succeed without a massive in-
 fusion of expert  tutoring and  direct, ongoing  assistance  from
 specialists skilled at persuading the public.
Winning over the public can be the key to a winning project.
  WHY PROFESSIONAL PUBLIC RELATIONS
  EXPERTS ARE NEEDED
  Engineers and Scientists Naive
   Sheer  naivete is at  the  heart of the industry's  problem.
  Engineers and scientists are rationalists. They tend to believe that
facts are—or should be—as persuasive to others as they are to
themselves. They have a hard time seeing things from the perspec-
tive of the general public. If they make a logical case for a project,
then back it up with solid facts and research, they think the public
should react favorably. They forget that there are a lot  of other
ways  to  look at waste management  problems than  from  a
technical, engineering perspective.

Operations-, Not  Marketing-Oriented
  A  second,  closely  related,  issue  is  that  engineers  and
engineering-based companies, including large waste management
firms,  traditionally  have  been  very  operations-oriented, not
marketing-oriented. Even some of the biggest firms  have been
slow  to  develop  anything more than  the  most  rudimentary
marketing communications  and public relations efforts.
  This tendency is consonant  with the personality type of the
engineers and waste management specialists Fanfare Communica-
tions has come to  know (and respect) in more than seven years of
dealing with  environmental issues. They  are generally uneasy
wrestling with subjective judgments. They prefer to avoid situa-
tions calling for salesmanship and the manipulation of other peo-
ple's feelings. They are more comfortable dealing with tangible,
quantifiable things. How much? How many? What weight? How
high?
  Even the professionals who do spend a fair amount of time sell-
ing rarely have much experience dealing with the general public.
Engineers don't sell their services to the man-in-the-street; they
sell to other engineers or to technocrats, who see the world as they
do.

Technicalese
  A third factor compounding the communications problem  of
many science and engineering types is that they don't even talk the
same  language other people do. Even when they're trying their
level best to  communicate with a lay audience, they talk  in
"Technicalese" without realizing it. "Leachate collection zones"
and "low-permeability soils" are simple enough terms to a waste
management specialist, but  they don't communicate much to an
untutored citizen.
  For example, one of the  country's  largest  waste management
firms  last year published a "Fact Sheet"  aimed at clearing up
public misconceptions about  hazardous  waste management.
"PCBs: What Are They?"  said the fact sheet, implying that the
answer which followed would clear up this mystery once and for
all. That possibility was quickly dashed. What would your non-
technical friends or spouse make of this explanation?
  "The name stands  for polychlorinated biphenyls, and  contrary
to popular belief,  PCBs are not one chemical but a class of com-
pounds. These compounds are two benzene rings joined  together
at one carbon on each ring. The rings are then substituted with
one to ten chlorine atoms."

Too Expert to Communicate?
  Fourth,  as specialists in demanding technical fields where
depth, not breadth, of knowledge is the common measurement of
true expertise, engineers and scientists are prone to write  off their
inabilities as public communicators with such rationales  as, "I'm
an engineer, not an actor." As a consequence, they invest little ef-
fort in improving  their skills and may simply avoid situations that
highlight weaknesses in this area. Like most people, if given a
choice, they'll define their jobs and responsibilities to emphasize
their strengths, not their liabilities.
  Finally, in  organizations  that traditionally have rewarded per-
sonnel for their  engineering and  operational know-how, and
which recruit new professionals by those same criteria,  qualified
professionals are  often reluctant to make marketing and com-
                                                                                            PUBLIC COMMUNICATIONS    405
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Some Practical Suggestions
  These, then, are the key participants for a successful public ac-
ceptance effort. But how should they proceed, and what mistakes
should they be careful to avoid?
  Whole books and lengthy manuals have been written on the
subject of public  participation programs  for waste management
projects, but they pay far more attention to the rules and regula-
tions for formal hearings and proceedings than to the more fun-
damental issue of winning public acceptance.  Space doesn't per-
mit a full exploration of all key components of a sound public ac-
ceptance program, but here are some practical suggestions gleaned
from the experience of Fanfare Communications and its clients in
the waste management industry.

In General
• Think carefully before trying to go around the public. It rarely
  works. Have a  good public acceptance program ready to put
  into place even though you think it won't be  necessary.
• It's usually easier to  control public reactions if  you take the
  initiative instead of being forced to react.
• Communicate a sense of full disclosure. Better that YOU tell
  people the bad news than for the public to hear it  from another
  source and think you've been deceiving people.
• The bottom line is not to be declared "right"; it is to get enough
  people in the community to believe enough  of your story to
  allow your company to do what it hopes to do.
 • "Walk in the public's shoes" if you want to understand a com-
  munity's concerns. If you do not understand its concerns, you
  will never gain  its acceptance.
 • Never lie to the public or "shoot from the hip" with a  state-
  ment you might later have to retract.
 • Never make up an answer and then try to support it later.
 • Communicate in  such a way that people who know absolutely
  nothing about  the environmental sciences, chemistry or en-
  gineering can understand what you say. It makes people nerv-
  ous, worried, embarrassed and  angry to be confused.
 • Even if you can't win  outright public acceptance, try to es-
  tablish an atmosphere calm enough to permit regulatory  agen-
  cies to do their jobs free  of  public  hysteria and excessive
  political pressure.
 • Public acceptance programs do not succeed  because of what
  YOU know, but because of what the public FEELS.
 • Internal communication is critical. Develop a consistent pro-
  ject narrative and description, and make sure all parties stick
  to it.
 • Do not think of "the public" as a single entity. Think of com-
  munity residents  in terms of "active, intractable opponents,"
   "passive opposition," "disinterested neutrals,"  "persuadable
  neutrals," "allies" and "latent allies." There are also opinion
  leaders,  special  interest groups (labor, churches, business,
  environmental  groups, the PTA, ethnic concentrations,  etc.),
  the news media, elected officials, regulatory agencies and civic
  groups. "Target" messages appropriate to  each  sub-group,
  but never make contradictory statements.
 • Have  specific,  detailed objectives for  all the communication
  tools you employ, including: the official project  spokesperson
  (The Communicator), speeches  to specific groups of people,
  public information  meetings, printed brochures and  book-
  lets, audiovisual presentations,  individual meetings  with of-
  ficials and opinion leaders, radio and TV commercials, posters,
  targeted mailings, publicity releases, news conferences and an-
  nouncements, official hearings, public debates and news media
  interviews.
 • Tap the resources and  trade associations of  waste generators
  in a  community to participate in general education efforts
  about the importance of sound waste management.
 •  Line up friends.  Harness their self-interest and provide them
   with the materials and support to  make it easy for them to
   help.

 Spokespersons
 •  Insist  on having  one  official project  spokesperson.  Many
   mouths make hard work, lots of headaches and embarrassing
   contradictions.
 •  It is essential to level with the media as much as possible, es-
   tablish trust and not be  seen as pro-company zealots. Give
   them the freedom to succeed for you.

 At Public Meetings
 •  Urge all company speakers and respondents to questions to be
   "real people"  and let (the good sides of)  their personalities
   show. Humor, at the proper time, can be a real trust-builder.
 •  Your personal manner and appearance communicate at least as
   much information about your project as what you say about it.
   Look confident and  relaxed.  If you cannot, do not appear in
   public meetings.
 •  Use standard persuasion techniques, including always starting
   where your audience is, not where you are or where you want
   them to be.
 •  Insist on getting professional training in public speaking and
   responding to  hostile questions for all  company representa-
   tives likely to make public appearances.
 •  Use videotape cameras to  record the way company representa-
   tives look and sound  at public meetings and  to help them prac-
   tice their presentations beforehand.  There is no better way for
   people to learn than to see  themselves  as others see them—
   especially if they are  going to be seen on television.
 •  Address the intent of people's questions, not just the specific
   wording, which is often inarticulate. It  makes you appear to
   be more forthcoming.
 •  Always schedule ample time for give-and-take with the  public
   and for  clarifying questions and answers. Do not put  this
   crucial component of public meetings on an "if there's  time"
   basis.
 •  Be clear  about what you want to convey in  all public  utter-
   ances.  Have simple,  modest  goals for your statements.  Com-
   plexity bewilders. Bewilderment breeds anxiety.
 •  Avoid  jargon and "technicalese."  It separates you from the
   audience just when you want them to be with you.
 •  The purpose of public meetings is  to generate credibility and
   better feelings, not to flood people with a vast quantity of in-
   formation. It is not  your message that matters; it is how the
   public  feels about you and your project.
 •  Do not disengage from the audience by constantly staring down
   at a prepared speech and reading in a monotone. Master the
   material  so  that  you  can look up frequently.  Engage the
   audience.  Be expressive.
 •  Learn to tolerate people directing their  angry comments and
   concerns at  you.  It  is seldom truly personal, and it usually
   helps to defuse public hostilities when people are allowed to
   spout off at someone—unpleasant as that may be.

Audiovisual Programs
 •  Unless they are accompanied by a  skilled speaker  or are  de-
   signed  to  allow interaction with the audience,  one-projector
   slide shows without a soundtrack can be pretty static and bor-
   ing. The best format  is a technically  uncomplicated, not  overly
   slick,  two-projector  program with a pre-recorded, synchron-
   ized soundtrack.  Numerous studies have shown that  it sus-
   tains interest  better  and  produces  much fuller information
   recall.
                                                                                           PUBLIC COMMUNICATIONS   407
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 •  Try to put  only one  idea  on each slide.  Detailed charts,
   lengthy lists  and wordy graphics are a staple of engineering
   presentations, and  they are almost worthless as communica-
   tion devices.
 •  If the eye cannot quickly grasp and easily "hold on to" the
   visual information in a  slide, it is a bad slide.
 •  The use of all capital letters tends to be less readable than capi-
   tal and lower case letters combined—the way they are in 99%
   of the things we read every day.
 •  The typography in many slides resembles "The Lord's Prayer"
   written on the head of a pin.  Keep type clear and large enough
   to be quickly legible.
 •  Audiovisual  programs that present  information only and  fail
   to address and affect people's feelings  are failing to use the
   full potential of the medium.

 News Media Relations
 •  Educate the  news media patiently. Keep giving them  clear, in-
   formative information and their coverage  will improve.
 •  Establish your company as a dependable source of  informa-
   tion about waste management in general,  not just as  it relates
   to your  company.  It makes reporters more knowledgeable
   and builds useful bridges with the news media.
 •  See every potential story about your project as the press might
   see it. Your perspective is not a reliable index of how the media
   will, or should, deal with news about your company and its
   projects.
 •  Keep your cool when "correcting" the news media for erron-
   eous stories.  Mistakes rarely are intentional, and you will bene-
   fit in the future from not insulting a reporter who  gets things
   wrong. Never "demand"  retractions unless you  have  firm
   legal grounds for doing so. A firm request often  gets better
   results.
Booklets and Brochures
• Good printed materials should adhere to the same communica-
  tions guidelines stated for other media.  They  should  avoid
  "technicalese,"  be clear and  understandable to non-experts
  with only a high  school education and address the readers'
  interests and concerns, not simply hammer home the com-
  pany's message.
• Printed materials should communicate well on several levels:
  they should use boldface or color-emphasized headlines, sub-
  heads that add  details and  interest to the headlines, photo-
  graphs and  illustrations that convey visual information, and
  caption material that expands on them. All of these elements
  help "pull the reader in," and at a time when people are being
  bombarded with a vast amount of printed matter, every read-
  ership encouragement helps.
• Generally, waste management companies  should avoid  using
  excessively slick and sophisticated publications that may convey
  too strong a "big business'V'big money" impression to people
  in a particular community. Sometimes,  however, it is impor-
  tant to  convey a  very substantial image, in which case the
  graphic  presentation and paper quality can signal your  com-
  pany's ample resources.
• Consider using targeted mailings to direct specific messages to
  specific  audiences.  It is expensive, but effective.

Radio, TV and Print Advertising
• If you are frustrated by repeated failures  in getting the  news
  media to pay  sufficient attention to your side of the story,
  consider using advertising to communicate a message that you
  and you alone control. But get professionals to create the copy
  and graphics. Advertising that  misses the boat from a message
  standpoint, makes  no strong impression or  fails to get people's
  attention in the first place is a terrible waste of precious  com-
  munications resources.
  Now get out there  and start educating!
408    PUBLIC COMMUNICATIONS
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                 Recycling  of  Dust  from  Electric  Arc  Furnaces-
                                   An  Experimental  Evaluation
                                             E. Radha Krishnan, P.E.
                                                 William F.  Kemner
                                              Gopal Annamraju,  P.E.
                                                PEI Associates, Inc.
                                                  Cincinnati, Ohio
ABSTRACT
  Dust generated from electric arc furnaces (EAFs) employed
in steelmaking plants currently is listed as a hazardous waste.
Disposal of the waste at a controlled landfill is becoming expen-
sive as disposal sites become more scarce and remote from the
point of origin. Even with current standards of environmentally
acceptable disposal, long-term liability is a concern. This has led
the steelmaking industry to look to other viable options for han-
dling the dust.
  The dust from carbon and low-alloy steel plants represents a
potential source of heavy metals such as iron and zinc, the recov-
ery of which appears to  be  a logical alternative to disposal. In
addition to providing a dust management option,  material con-
servation would result from  this approach. Centralized recovery
facilities do not appear to be economically attractive for EAF
dust because it is generated in small quantities at a large number
of locations distant from industrial centers. Recycling to the
furnaces to achieve additional iron recovery and produce a zinc-
enriched blowdown dust stream for sale appears to represent the
most sensible route for managing the dust. This paper discusses
the approach  and presents results  of  an experimental program
for investigation of key issues pertaining to EAF dust pellet re-
cycling. These issues are the fate of zinc and other volatile ele-
ments in the dust, electrical energy consumption in the furnace
during recycling, effect on steel quality and the economics of re-
cycling. The research was conducted under  a grant from the U.S.
EPA's Small Business Innovation Research Program.

INTRODUCTION
  Each year  the  electric arc  steelmaking industry generates
approximately 650,000 tons  of dusts containing valuable metals
such as iron, zinc, lead and  chromium. These electric arc furn-
aces (EAFs) are becoming increasingly popular for the  produc-
tion of carbon and low-alloy steels and currently account for
about 35% of total steel production. Although only a relatively
small amount of dust is generated from the furnaces at  any one
steel plant, the cumulative quantity from all plants is large and
represents  a significant loss  of heavy metals and scarce  alloying
elements.
  More importantly, EAF dust currently is listed as a hazardous
waste  because  of the leachability  of  its toxic constituents; its
U.S. EPA-assigned hazardous waste number is KO61. Disposal
is becoming costly as disposal sites become more scarce and re-
mote from the point of  origin. Disposal costs  (including Jrans-
portation)  of $100 per ton of dust are quite common. Further-
more,  even with current standards of environmentally accep-
table disposal,  long-term liability is a  concern. This has led the
steelmaking industry to look to other viable options for handling
the dust.
  Alternatives to the landfilling option for EAF dust manage-
ment include chemical fixation, regional recovery processes and
on-site recycling. The major shortcomings of the various pro-
cesses suggested for  recycling metallic values from EAF dust
(e.g., SKF Plasmadust process, AMAX Caustic Leach—Elec-
trowin Zinc process) have been the high capital cost of the equip-
ment and the need  for large quantities of dust  for the processes
to be economical. Furthermore, the processes require dusts with
zinc contents greater than 20%. EAF dust generally is not amen-
able to these processes because it is generated in small quantities
at a large number  of locations distant from  industrial centers
where regional recycling might occur.
  Recycling to the furnaces is a logical alternative for managing
EAF dust. The recycling operation should result in the genera-
tion of a dust enriched in volatile elements such as zinc and lead;
this blowdown  dust stream  could be removed for  sale to zinc
smelters. The main advantages of the  recycling process are its
low capital cost, relative insensitivity to EAF  dust composition
and applicability to both minimills and large mills. This process
can be applied to carbon and low-alloy steel plants in both the
basic steel and steel foundry industries to recover contained min-
eral values in the dust and thus avoid costly disposal of this waste
in hazardous waste landfills.

Plant Experience in Recycling
  Several steel  plants including Bethlehem Steel,  Babcock  &
Wilcox,  Empire-Detroit Steel, LASCO  in Whitby, Ontario and
Armco at their  Kansas City  Works have conducted trials of re-
cycling with  either pellets (of dust and water)  or briquettes. On
balance, there appears to be  no clear consensus on the effects of
EAF dust recycling  in the steel industry. Although some dissatis-
faction with recycling exists,  it appears to offer  the most immed-
iate, lowest-cost alternative to disposal at this time.

Experimental Research Program
  Based on the results of a feasibility study by PEI and the exper-
ience of previous researchers, PEI designed an experimental pro-
gram to obtain data  under controlled conditions for investiga-
tion of several critical issues for the commercial application of re-
cycling: (1) the partitioning (upon recycling) of heavy metals such
as zinc,  lead and cadmium between the slag and the dust gener-
ated; (2) the effect  of recycling on energy  consumption; (3) the
effect on steel quality; and (4) the economics  of recycling. The
tests were conducted  at the Green  River Steel EAF shop  in
Owensboro, Kentucky, during the summer of 1985.
  Green River's Owensboro  site has two 65-ton electric arc furn-
aces rated at 24,000 kVA each (370 kVA/ton). The furnaces pro-
duce low-alloy and specialty carbon steels that are sold to  the
forging industry for use in the aerospace, bearings,  defense, en-
                                                                                               REUSE & RECOVERY    409
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 ergy exploration  and production, machine tool,  power trans-
 mission and  generation, mining  and transportation industries.
 Oxygen is injected with hand-held pipes;  lime is injected pneu-
 matically. Three to four charges of scrap are used per heat. The
 furnaces are equipped with  side-draft  hoods,  which semi-sur-
 round the electrodes and canopy hoods in the roof. Both furn-
 aces are vented to a  14-compartment baghouse that discharges
 into screw conveyors. These  conveyors  ultimately join into one
 cross conveyor that discharges into a  flexible tube. The dust then
 falls about 6 ft through the tube into a large sealed rolloff box
 situated on the ground. After being filled,  this box is hauled to a
 hazardous waste facility.

 EVALUATION OF PELLETIZING EQUIPMENT
   Prior to plant selection, fresh dust was  obtained from two oper-
 ating EAF shops representing low-alloy medium carbon steels
 (Plant A) and plain  carbon steels (Plant  B). Manufacturers  of
 pelletizing equipment were contacted for conducting pelletizing
 tests. (The agglomerating of EAF dust with water is often called
 "greenballing." In this paper, however, we refer to the product as
 pellets and the process as pelletizing.) Teledyne-Readco of York,
 Pennsylvania, was selected to run laboratory-scale and bench-
 scale tests on these dust samples.
   Based on the bench-scale test results, the following equipment
 was selected for conducting the pilot-plant studies:
 1.  3-ft-diameter disc pelletizer and hopper
 2.  8-in-diameter pin mixer
 3.  3-ft5 live bin feeder
 4.  Heavy-duty base supports for pelletizer, pin mixer and feeder

   Two feeder tubes were also used to provide the  flexibility  to
 bypass the  pin mixer. Even though  the bench-scale pelletizing
 tests did not warrant the use of a pin  mixer, one was included  to
 provide preslaking of lime in the event that this was required.
                                                                                      Table 1
                                                                   Elemental Concentration! In Electric Arc Furnace Dusts
                                                                                   (% by Weight)
          100
           90
           so
           70
           60
           50
           40

           30
           20
        5  n
            2 -
           I   I   I   I   I  I    I
          I STEEL PLANT A
          I STEEL PLANT B
                       _l	1	L   1
                                  _L
                                       _L
            1
            10   20  30 40 50 60 70  80   90  95  98 99
            CUMULATIVE PERCENT  LESS THAN  STATED DIAMETER

                          Figure 1
     Particle Size Distribution of Electric Arc Furnace Dusls from
                       Two Steel Plants
Element
Caa
ff"
Zn"
Pbb
Steel plant
A
9.17
16.7
?6.9
2.24
B
3.18
32.1
20.9
3.85
C
2.81
32.9
20.6
5.08
D
14.71
28.2
12.9
0.83
                                                             'Analyzed by ASTM Reference Method J682
                                                              Analyzed by ASTVt Reference Meihod J683
CHARACTERIZATION OF EAF DUSTS
   As part of the preliminary activities  for the experimental re-
search program, PEI conducted physical and chemical character-
ization tests for EAF dusts.
   PEI performed Bahco analyses for analyzing particle size dis-
tribution  of two EAF dusts (Fig. 1); the Bahco analyses were
performed  on  minus- 100-mesh  material,  which  represented
98.8% (by weight) of the sample for dust from Steel Plant A and
65.5% of  the sample for dust from  Steel Plant  B. The results
show that the EAF dusts were composed of  fine particles and
that approximately 50% of the dust was below 5 microns.
   Table 1 illustrates the variability of important metallic constit-
uents in the dust. The EAF dust analysis varies from heat to heat
and during a heat, depending on the materials charged, stage of
the heat and  other factors. Consequently,  the recycling  tech-
nique must be relatively insensitive to changes  in both the chem-
ical and physical characteristics of the dust.
   Some of the pellets produced during the bench-scale tests were
subjected  to weatherability tests. These pellets were kept in the
open for a period of 5 months. Ninety-rive percent of the pellets
retained their shape without  any  breakage. All  the  pellets re-
tained a strength of over 50 Ib. Although the weatherability tests
indicated reasonably good weathering characteristics without any
impact on pellet  strength or breakage of pellets, in an ongoing re-
cycling operation, pellets would not be stored for more than a few
days.
   Tests were conducted  to measure the temperature change of
EAF dust/water mixtures over time. The  dust contained 20.6%
lime.  For  one test,  the dust/water mix  was  formed into pellets
3/8 in. to 1/2 in. in diameter; for the other, the mix was left as a
solid  cake. The mixtures were held  in insulated cups and the
temperature was measured by imbedded thermocouples.
   Figure 2 shows the time-temperature curves for the pellets and
the solid cake. Maximum temperature reached in the  solid cake
was higher than in  the pellet test; however, the more  important
observation is that in both tests, temperatures increased quickly
at first and then  gradually rose to a maximum sometime after the
dust and water were mixed. The time required  to reach the max-
imum temperature was 80 and 105 min, respectively, for the solid
cake and pellets. The thermal mechanism  demonstrated in these
tests indicates the  lime  slaking and curing phenomenon taking
place.

PELLETIZING OPERATION
   Figure 3 illustrates the  pelletizing process flow diagram for the
Green River installation. The temporary storage hopper, which is
completely enclosed, receives the EAF dust from the baghouse.
The pelletizing operations were enclosed in a temporary shelter.
410
REUSE & RECOVERY
-------
                   120
                   no
                   100

             K-
             UJ

             I      90

             I


                    80
                                                                             SOLID CAKE
                                                                _L
                                                                80      100

                                                                TIME, minutes
                                                                                 120
                                                           Figure 2
                                        Results of Time-Temperature Tests on EAF Dust Pellets
The pellets produced were stored either in cardboard drums or
wooden boxes lined with polyethylene. All the pellets produced
were transferred and stored in  a covered  warehouse  before
charging into the furnaces. These arrangements met the neces-
sary regulatory requirements. Figure 4 shows the temporary en-
closure and the auxiliary facilities for the pelletizing system.
  The test pelletizer unit was a pilot model and, as such, was open
to allow adjustment of water spray or dust feed  locations. Dur-
ing pilot model operation, some dusting occurred around the ma-
chine; this would be circumvented on a production model as it
would be covered and vented to the baghouse.
  Dust composition appears to be the most important parameter
affecting pellet quality. Fortunately, variations in size (  < 1/4 in
to > 3/4 in.) did not affect the efficacy of recycling.
  The initial arrangement of the system included the pin mixer,
which was believed to offer the advantage of premixing water
with the dust to start the slaking of the lime before the dust en-
tered the pelletizer. After several trials, however, the pin mixer
became clogged with wetted dust,  which hindered the process;
therefore the mixer was removed. Even though the Green River
EAF dust varied from 10 to 20% lime, the pellet quality without
the pin mixer was not noticeably different from the pellet quality
with the pin mixer.
                        FLEXIBLE
                          TUBE
                                                           Figure 3
                                            Dust Pelletizing Process Flow Schematic for
                                                  Green River Steel Installation
                                                                                                   REUSE & RECOVERY    411
-------
                                        Temporary Weather Enclosure Over Pelletmng Equipment
                                            at Green River Steel EAF Shop. Owensboro, Ky.
                  Day Bin Constructed by Green River Steel
                           for fcAl Dust Storage
Auger Supplying Pelleti?er Feeder
                                                              Figure 4
                                               Pcllcimng Facility at Green River Steel Co.
412    REUSfc&KECOVhRY
-------
Pellet Quality
  Pellet strength tests were mostly qualitative, i.e., the pellets
were squeezed by hand. In some cases, however, a flat strip was
used to press the pellets on a scale, and the pellets showed break-
ing strength of 9 to 10 Ib (green strength). Pellets from the pelle-
tizer as made were strong enough to withstand shoveling and/or
dropping into the container.
  After aging for 24 hr, the pellets increased in strength. Tests on
three different batches (of different sizes) showed a crush strength
of 18 to 25 Ib. The  same batches showed a crush strength of
35 to > 80 Ib after 48 hr of aging,

RECYCLING OPERATION
  Transportation of pellets to the furnace and the timing of their
charging are important for a successful recycling program. Pref-
erably, the pellets should be charged into the furnace through the
use of a separate box or skip pan. They should be charged while
a slag layer is present on the molten metal from the meltdown of
scrap charged earlier. This facilitates quick assimilation of the
pellets into the bath and reduces flash off as dust. The scrap back-
charge can  take place immediately after the pellets are charged.
Another variation in charging consists of "sandwiching" the
pellets between the scrap in the charging bucket.
  At Green River, the recycling  operation involved moving the
drummed or crated pellets by a forklift to a warehouse area and
then to the melt shop floor, where they were dumped into a skip
pan. The skip pan was weighed and emptied into the furnace by
crane. The  pellets  were charged prior to the second  charge of
scrap (first  backcharge).  Figure 5 schematically illustrates both
methods of charging.

RESULTS
  Results  of pellet recycling  were analyzed  by comparison with
collected baseline data to determine:
   Effect on heat time and productivity
   Effect on power consumption
   Effect on yield
   Effect on quality of the steel
   Effect on carbon and electrode consumption
   Effect on lime and ferroalloy consumption

   The tests were conducted in two blocks. The main objective of
 the Block I tests was to determine the effect of recycling fresh
 pellets on power consumption and other furnace variables, where-
 as the primary objective of the Block II tests was to determine the
 fate of heavy metals under continuous recycling conditions. Table
 2 summarizes the data for the heats with pellet charging in Blocks
 I and II. Because the shop operation was not continuous during
 the experiments, some heats were made after  the furnace had sat
 idle for an entire turn, whereas others were made immediately
 after the previous heat. This situation affects apparent power use
 in kWh/ton and heat time regardless of pellet use. The heats are
 therefore divided into these  two categories  ("first heat,"  i.e.,
 cold furnace, versus "not first heat," i.e., continuous operation)
 for more  accurate analysis. Table 3 summarizes similar data for
 baseline heats, i.e., heats without pellet charging. The data for
 these heats were obtained largely from the plant's heat log sheets.
  During the Block  I test period, both furnaces operated 16 hr per
 day. Later, one of  the two furnaces was shut down for repairs
 and only one furnace remained in operation. During the night
 turn,  the  furnace roof  was  kept  open and  the  furnaces were
 allowed to cook down. The data collected during the Block I  and
 Block II tests include  a variety  of heats representing the normal
product mix. The operators paid no special  attention to, nor im-
plemented  any changes  in, the  steelmaking practice (other than
 adding extra carbon) because of the testing program.
  The Block II tests  were limited to 4 days of continuous re-
cycling because of  the  plant operating schedule.  During  this
period, pellets were made directly from the baghouse catch and
                                             PELLETS SANDWICHED
                                                 IN SCRAP
            PELLETIZER
                                                  PELLETS CONVEYED BY FORK LIFT
                         PELLETS HELD IN BASKETS
                              OR BOXES
                                                          Figure 5
                                      Schematic of EAF Dust Pelletizing/Recycling Operations
                                                                                                  REUSE & RECOVERY    413
-------
      TOTAL OBSBRVATIONS:
                                                                        Table 2
                                         Comparison of Data for Heals with Pellet Charging In Blocks I and II

                                  •ATS win PELLET  CHARGING  (nusT BAT ON FCTWACI Arm IMMMUM)

                                 14


N OF CASES
MINIMUM
MAXIMUM
MEAN
STANDARD DBV
TAPTAP
HRS
14
4.830
9.670
7.319
1.217
PWRUSBD
KWH/TON
14
536.960
670.740
616.919
40.442
TOTYIBLD
*
14
86.550
93.800
89.909
2.752
NETYIBLD
*
14
79.600
93.600
86.693
3.734
OPBNCRBN
*
14
0.070
0.471
0.270
0.120
FNALCRBN
*
14
0.150
0.480
0.362
0.113
COKBCHRQ
LBS
14
0.
3200.000
1132.143
799.425
PLLTCHHG
LBS
14
910.000
2180.000
1129.286
322.090
      TOTAL OBSBRVATIONS:    24
                                                 BEATS WITH PILOT CHARGING  (NOT FIBST BUT)


N OF CASES
MINIMUM
MAXIMUM
MB AN
STANDARD DBV
TAPTAP
HRS
24
4.500
8.000
5.872
0.953
PWRUSED
KWH/TON
24
493.830
672.500
560.903
37.725
TOTYIKLD
*
24
82.500
98.900
91.231
3.656
NBTYIELD
*
24
65.500
93.900
85.788
5.494
OPBNCRBN
*
24
0.050
0.860
0.349
0.203
FNALCRBN
*
24
0.160
0.470
0.338
0.112
COESCRRO
LBS
24
100.000
2000.000
1060.000
521.703
PLLTCHHO
LBS
24
100.000
2155.000
1083.542
328.019
Variable names are as follows:
TAPTAP       Tap-to-lap heal lime (in hours)
PWRUSED     Power used (in kilowall-hours, Ion).
TOTYIELD     Yield of sleel as tapped as percentage of lolal metallic charge including scrap.
                ferroalloys, and pellets.
NKTYIEl D     Yield of prime sieel as poured (in percentage)
OPENCRBN    Opening carbon m both (in percent).
I INAI l~RBN   Final tap carbon in both (in percent)
C'OKEC'HRCi    Coke charged (in pounds)
PI I UHRC.    Pellets charged (in poundi)
                                                                        Table 3
                                                        Comparisons of Data for Baseline Heats

                                             BASELINE BEATS  (FIRST BEAT ON FOHNACI  AFTO
       TOTAL OBSBRVATIONS:    28


N or CASES
MINIMUM
MAXIMUM
MB AN
STANDARD DBV
TAPTAP
HRS
28
4.670
9.083
6.777
1.211
PWRUSED
KWH/TON
28
483.220
766.090
592.898
74.942
TOTYIBLD
*
28
83.400
97.100
90.118
3.438
NBTYIBLD
X
28
73.000
96.600
87.172
4.799
OPBNCRBN
*
27
0.060
1.170
0.348
0.295
FNALCRBN
k
27
0.110
1.070
0.381
0.271
COOCHRG
LBS
28
0.
2500.000
1078.571
654.532
PLLTCHHG
LBS
28
0.
0.
0.
0.
                                                                BASILINS BEATS (NOT FIRST  BUT)
     TOTAL  OBSBRVATIONS:    35


N OF CASES
MINIMUM
MAXIMUM
MEAN
STANDARD DBV
TAPTAP
HRS
36
4.083
9.250
6.093
1.204
PWRUSBD
KWH/TON
35
466.440
634.440
540.882
37.959
TOTYIBLD
*
35
86.000
96.500
91.180
2.712
NBTYIBLD
«
35
71.000
96.600
87.397
4.290
OPBNCRBN
*
35
0.090
1.040
0.336
0.257
FNALCRBN
k
35
0.100
1.060
0.350
0.203
COKBCHRG
LBS
35
0.
2300.000
788.571
546.447
PLLTCHRG
LBS
35
0.
0.
0.
0.
 Variable names arc as follow1.:
 TAPTAP       Tap-lo-lap tieal lime (in hour1.).
 PWRUSfcD      Power used (in kilowati-hours/ion)
 TOTYIELD     Yield of sicel as lapped as percentage of lotal metallic charge including snap,
              ferroalloys, and pellets
NI TV 11-1 n     Yield of prime steel as poured (m percentage).
OPL-NCRBN    Opening carbon in Haiti (in percent).
KINAl CRBN   I'liml tap carbon in bath (in percent).
COKI-CHRG    tokc charged 
-------
                                                            Table 4
                                        EAF Dust Analysis in Block I and Block II Experiments
                                                         (% by weight)
Constituents
Phosphorus
Sulfur
Cadmium
Calcium oxide
Chromium (+3)
Chromium (+6)
Copper
Iron
Lead
Magnesium
Manganese
Molybdenum
Nickel
Potassium
Silica (SIO?)
Sodium
Vanadium
Zinc
Sample No., date (1985), and type"
!
06/12

N11
0.50
0.02
15.3
0.3!
Nil
0.1
18.4
0.76
1.87
3.0
0.14
0.17
0.8
1.8
0.6
<0.01
24.4
?
06/13

Nil
0.47
0.02
15.5
0.26
Nil
0.09
18.7
0.67
2.02
3.3
0.1
0.13
0.8
1.9
0.6
<0.01
23.0
3
06/14

Nil
0.44
0.02
15.5
0.23
Nil
0.08
18.2
0.70
1.96
3.3
0.8
0.12
0.9
1.6
0.6
<0.01
27.9
4
06/14
G.S

Nil
0.47
0.02
14.4
0.25
Nil
0.08
17.3
0.68
1.91
3.0
0.1
0.13
0.9
1.6
0.6
<0.01
26.9
5
06/14

Nil
0.47
0.02
13.9
0.22
N11
0.07
15.5
0.63
1.79
3.0
0.07
0.11
1.0
1.6
0.6
<0.01
25.0
6
06/17
Block I
Nil
0.43
0.0?
13.4
0.25
N11
0.07
16.7
0.56
1.88
3.0
0.09
0.12
0.8
1.5
0.5
<0.01
26.6
7
06/17
G.S

N11
0.47
0.02
13.8
0.26
Nil
0.08
16.1
0.52
1.87
3.1
0.10
0.11
0.9
1.6
0.5
<0.01
26.1
8
06/18

N11
0.55
0.02
14.3
0.32
Nil
0.09
16.9
0.47
1.79
3.2
0.12
0.13
1.0
1.8
0.6
<0.01
20.1
9
06/19
C

N11
1.0
0.01
17.5
1.8
0.01
0.08
21.1
0.59
1.76
2.6
0.05
0.14
0.7
3 2
0.5
<0.01
24.6
10
07/02
G

Nil
0.41
0.01
21.1
3.1
0.004
0.1
25.6
0.65
1.03
2.0
<0.01
0.16
0.3
4.1
0.4
<0.01
12.0
11
07/02
G

Nil
0.40
0.02
12.0
0.42
0.004
0.05
14.8
0.45
2.36
3.0
0.09
0.12
1.0
1 9
0.6
<0.01
32.7
12
08/26
C
13
08/27
C
14
08/28
C
15
08/29
C
Block II
0.03
0.50
0.01
19.0
0.58
0.002
0.09
24.4
0.66
3.63
5.0
0.14
0.29
1.0
3 1
0.5
<0.01
9.0
0.03
0.47
0.02
15.1
0.44
0.006
0.08
21.2
0.58
2.29
3.5
0.16
0.24
1.0
2 8
0.5
<0.0!
12.4
0.04
0.63
0.02
18.1
0.57
0.003
0.13
26.7
0.65
2.64
4.5
0.37
0.27
1.2
3 0
0.7
<0.01
12.3
0.02
0.58
0.02
16.1
0.62
0.002
0.1
28.5
0.65
2.77
4,4
0.33
0.27
1.1
3 l
0.7
<0.01
14.7
            aC = composite sample, G   grab sample, S = pellet size change.
recycled to the furnace. Two furnaces operated 16 hr per day
during this period. Slag and dust samples were collected to eval-
uate the fate of zinc.  Table 4 presents the analytical results for
dust/pellets, and Table 5 presents the results for slag analysis.
  A long shutdown occurred at the plant prior to the Block II ex-
periments. Because of uncertain  business conditions,  inventory
was reduced by consuming all available scrap in the plant during
the Block  II tests  without  regard  for a balanced scrap mix.  The
zinc content of this cleanup  scrap  was significantly lower than
that of the scrap usually used. No high-zinc scrap was observed
during the Block II testing; consequently, the zinc content of the
recycled dust was lower than in  Block I despite  the  recycling.
An increase in the zinc content of the  dust from 9% to approx-
imately 15%, however, was observed during the continuous re-
cycling period.
  Several area samplers with AA millipore membrane filters were
located in the shop to measure heavy metal concentrations in the
shop atmosphere—two at  5 ft above the ground level and two
above  the furnace level and just below the crane runway. Table
6 presents the analytical results for these samples. Although zinc,
lead and cadmium were all detected on the filters, the concentra-
tions were very low. These results indicate that general loss of zinc
and other heavy metals through fugitive concentrations is not a
significant factor in the zinc balance during recycling operations.
  During Block I testing, the  zinc content of the dust  was fairly
constant, varying between 20 and 25% based on composite sam-
ples. On the other hand, two grab samples taken within 30 min of
each other showed a marked variation in zinc content (12 and
32.7%).  The zinc content of the slag was less than 0.01% in al-
most all samples.
                                                            Table 5
                                         EAF Slag Analysis in Block I and Block II Experiments
                                                          (% by weight)
                                                   Sample No., date (1985), heat No., and type of sample
Constituents
A1203
CaO
FeO
MgO
MnO
SiO
Cr
Cu
Pb
Zn
1
06/26
69568
FS
2
06/26
69569
FS
3
06/27
69571
FS
4
06/27
69570
IF

7.21
41.2
6.87
10.7
9.36
16.8
1.22
0.01
<0.01
<0.01
7.79
41.0
3.96
15.3
4.49
17.1
0.29
0.04
<0.01
<0.01
7.48
42.4
3.25
11.6
4.98
20.3
0.48
0.02
<0.01
<0.01
4.96
41.7
18.1
10.6
6.15
7.32
0.67
0.02
<0.01
<0.01
5
07/01
69575
IF
6
07/02
69576
IS
7
07/02
69577
IS
Block I
4.99
40.3
15.4
6.86
6.69
13.9
0.87
O..01
<0.01
<0.01
5.47
39.8
11.0
9.31
7.60
17.1
1.13
<0.01
<0.01
<0.01
5.59
42.3
17.9
6.40
8.09
13.1
0.9
0.05
<0.01
<0.01
8
07/02
69578
IS

5.89
42.0
15.5
9.39
4.55
13.0
0.6
0.02
<0.01
<0.01
9
07/03
69579
IS

5.78
42.4
22.4
7.49
4.52
8.80
0.64
0.01
<0.01
<0.01
10
08/28
50028
IS
11
08/28
50028
IF
12
08/29
50030
IS
13
08/29
50031
IF
14
08/29
69616
IF
Block II
2.66
36.1
27.5
2.61
7.40
7.42
2.72
0.02
<0.01
<0.01
3.30
39.5
18.1
5.31
10.6
9.13
2.22
<0.01
<0.01
<0.01
3.93
31.1
39.5
5.89
5.49
5.86
1.07
0.02
<0.01
<0.01
4.22
33.0
26.7
5.81
8.86
10.3
1.67
0.02
<0.01
<0.01
5.54
36.2
18.4
5.99
7.68
15.1
1.25
0.01
<0.01
0.06
            = fjna) slag, IF = inside the furnace (in-site sample, IS = initial slag.
                                                                                                    REUSE & RECOVERY    415
-------
                                                             Table 6
                       Analysts of Contents of Area Samplers Located Inside the EAF Shop During Block II Experiments
Constituents
lotjl pirtk-
uljtfS
Clfolw
Ifld
Zinc
S«aplf ""»• Kite)
1* (8/26/85)
ug (gr)'
•2.0 < 10'
(0.1 « 1C'4)
<0.2
(«3.1 . IO'6)
<4.0
(•6.1 i IO"5)
7.7
(I.? . 10"4|
no/liter (gr/scf)f
•0.75
(O.J « 10"5)
.0.00075
(<3.3 • 10"')
-0.015
(.4.6 « IO'6)
0.026
11.3 . 10"5)
2b (S/28/85)
vt (gr)
1.71 i 10J
(4.2 . 10"')
.0.2
(O.I • 10"')
10.0
(1.55 • Ifl-'l
211
(1.26 • 10°)
vg/lllrr (gr/tcr)
3.49
(1.5 . I0'3|
•0.000)
(-1.14 • 10"')
0.013
(5.7 • 10"')
O.J6
(4.6 • IO"S)
Jc (8/2»/«S)
»g (gO
1.57 • IO3
(2.4 . 10'?)
•0.2
(0.1 i 10"')
• 4.0
(6.2 . IO"S)
2>l
(1.26 • IO"3)
i>9/llttr (gr/icf)
5.23
(2.J • 10"J)
.0.0007
(«2.» « 10'')
0.01}
(5.1 « 10"')
O.M
(I.I « 10"')
4* (t/n/ss)
i »g (gr)
r 3.4 > 10*
IS. 3 . 10'1)
•0.2
(O.I • I0"*|
.4.0
(.6.2 i 10'*)
60.7
(1.4 • 10"')
i)(/llt>r (gr/tcM
O.t
(3.S i 10'*)
.0.0005
(.2.1 . If'}
•a on
M.I a I0'*l
0.14
(6.) • IO"5)
         aSample I—Total volume. 267 I; duration, 133 min; location, 3 ft. above ground
         bSample 2—Total volume, 7701; duration. 390 min; location, above furnace and below crane girder
         'Sample 3—Total volume, 3001; duration, I SO min; location, above furnace and below crane firder.
         "^Sample 4—Total volume, 4Z5 1; duration, 210 min; location, 5 ft above ground.
         'Two types of uniu are indicated: micrograms (jig) and grains (gr).
          Two types of uniu are indicated: micrograms per liter (ug/liier) and grains per standard cubic foot (gr/tcf).
   Results of pellet charging on heat time are inconclusive. Heats
with pellets on a cold furnace took longer, while heats with pellets
during continuous operation were shorter. In neither case,  how-
ever, are these differences statistically significant.
   Power consumption for heats on a cold furnace was about 10%
higher than during continuous operation where pellets were used
or not. The use of pellets caused an increase in power use of about
4°7o; this was consistent for both cold furnace heats and contin-
uous operation, but the test of statistical significance is  conclu-
sive only for continuous operation. This increase in power con-
sumption is consistent with results reporttxj by some other inves-
tigators.
   Average total yield for the heats to which pellets were added did
not differ significantly from the base line heats (no pellets added).
It should be noted that several factors other than  pellet addition
affect yield. If all the iron contained in the pellets were recovered,
an improvement in yield of 0.2 to 0.3% could  be expected. Net
yield is not a significant  parameter in this analysis because it is
affected by physical  factors such as spillage, short ingots and off-
product unrelated to metallurgical yield.
   Green River produces quality steels in medium-carbon and low-
alloy grades suitable for forgings in several industries,  including
the aircraft industry. The quality and internal cleanliness of steel
are extremely important in meeting the stringent specifications for
this use. To assess the effect of recycling on steel quality, the plant
metallurgical department kept a special vigil and followed all the
heats charged with pellets from the ingot stage through  the dis-
patch of semifinished  products (bars, rods, etc.) to various cus-
tomers. Recycling had no deleterious effects on the steel quality.
This assessment is based on  38 heats (with pellets) in different
specifications.
   Although not apparent in Tables 2 and 3, comparison of aim
carbon and opening carbon data for  heats with pellets  and  base-
line data showed a higher percentage of heats using pellets were
closer to aim carbon; 28°/o of the baseline heats opened with car-
bon higher than aim carbon compared with 44% of the heats with
pellets. Because operators were concerned about carbon loss with
pellets, they compensated for this by making  carbon  additions
exceeding  the  theoretical requirements  for the pellet recycling
trials. Coke consumption during continuous operation was  about
33% (260 Ib) higher for heats with pellet charging although the
                                                            difference does not meet the test of statistical significance (at the
                                                            5% level). A large portion of this additional carbon was recovered
                                                            in the bath. Electrode consumption  data were collected for the
                                                            period when pellets were used in the Block I experiments and were
                                                            compared with the electrode consumption of the previous month.
                                                            Electrode consumption increased slightly during pellet recycling
                                                            (by about 0.26 Ib/net ton of steel produced).
                                                              In the Green River operations, pea size lime is blown into the
                                                            furnace pneumatically near the top of the furnace, above the bath
                                                            line. Lime is required to produce slag that assimilates the gangue
                                                            materials charged in the  furnace, thereby  maintaining the re-
                                                            quired basicity. Although not presented in Tables 2 and 3, com-
                                                            parison of the baseline data with the heats charged with pellets
                                                            showed a slight increase in the lime consumption when pellets  are
                                                            used. An average of 1.2 Ib of extra lime was consumed  per ton of
                                                            steel produced.
                                                              Comparison of ferroalloy consumption data did not indicate
                                                            any significant differences between heats with and without pellets
                                                            after adjusting for differences in aim specifications.
                                                              During the tests, the Green  River  baghouse operated normal-
                                                            ly.  Dust was discharged from it periodically; i.e., when sufficient
                                                            dust had accumulated in the hoppers, it was conveyed  to the day
                                                            bin for pelletizing. No abnormal baghouse operation was noticed.
                                                              Observations did  not reveal any noticeable change  in dust or
                                                            slag generation rates due to the addition of pellets.
                                                              In  summary,  the  observations and the results of the experi-
                                                            ments indicate that an acceptable quality of pellets can be made
                                                            by  pelletizing, and that recycling to the furnace can be  conducted
                                                            without any operational or air pollution problems. Recycling at
                                                            the rate of dust  generation had  no deleterious effects on steel
                                                            quality at Green River Steel.
                                                            ECONOMICS
                                                              Table 7 summarizes the design and operating parameters for
                                                            three EAF units of different sizes. Table 8 presents the capital and
                                                            annualized costs developed for each of these three units.  These
                                                            economic analyses are preliminary in nature and must be refined
                                                            for each specific plant site. When compared to landfilling costs of
                                                            SlOO/ton dust,  the  economic analysis indicates  recycling to be
                                                            attractive, especially for larger plants.
416
REUSE & RECOVERY
-------
                           Table 7
         Base Units for Economic Evaluation of Recycling
                           Table 8
   Capital and Annualized Costs for Selected EAF Recycling Units

EAF plant size (tons steel/yr)
Dust quantity processed (tons/yr)
Recycle plant capacity (tons/h)
Recycle plant operating rate (tons/h)
Operating hours per year
Onsite operators/supervisors
Units
Small
70,000
1,000
0.5
0.5
2,000
1
Medium
200,000
3,000
2.75
1.50
2,000
1
Large
600,000
9,000
6.5
4.5
2,000
2
CONCLUSIONS
  This research has proved that EAF dust can be pelletized with
water only and recycled to  the furnace. The following original
objectives underlying PEI's philosophy for EAF dust manage-
ment have largely been met:
• Use of a simple process design
• Use of existing, proven, low-cost equipment
• Use of EAF dust only, with no additives other than water
• Use of a process with no residual pollution streams
• Use of a process with a high turndown ratio and capable of
  processing widely varying dust compositions
  Thus far, PEI's experimental research has included an evalua-
tion of pelletizer performance  parameters and the effects of re-
cycling on electrical energy consumption, raw materials consump-
tion and steel quality. Future research programs should focus on
the longer-term verification of EAF operation with dust recycling
and the fine-tuning of the process economics. In the research con-
ducted, it was not possible to include sufficient heats to obtain the
desired amount of process data  to close the material balance.  The
objectives of longer-term testing are:
• To establish the material balance for continuous EAF dust re-
  cycling, with particular emphasis on  the partition of zinc be-
  tween various phases
• To determine the optimum rate and composition of the blow-
  down stream from recycling
• To finalize the economic  model  for the process to determine
  the net cost per ton of dust recycled

BIBLIOGRAPHY
 1. Babcock and Wilcox,  "Recycle of Electric Arc Furnace  Emission
   Control Dusts, Evaluation of  Two-Year Program," Tubular  Pro-
   ducts Division, Beaver Falls, PA, 1985.
 2. Barnard, P.O., et al., "Recycling of Steelmaking Dusts," U.S. De-
   partment of the Interior, Bureau of Mines, TPR 52,1972.
 3. Center for Metals Production, "Electric Arc Furnace Dust,  Dis-
   posal, Recycle and Recovery," Report No. 85-2, Project No.  RP-
   2570-1-2, 1985.
 4. Fosnacht, D.R., "Recycle of  Ferrous Steel Plant Fines, State-of-
   the-Art," I & SM, 1981, 22-26.
 5. Harris, M.M., "The Use of Steel Mill  Waste Solids in  Iron and
   Steelmaking," Presented at American Iron and Steel Institute  86th
   General Meeting, New York, NY, May 1978.
 6. Higley, L.W., Jr. and Fine, M.M., "Electric Furnace Steelmaking
   Dusts—A Zinc Raw Material," Bureau of Mines Report of Investi-
   gation 8209,1977.

Capital (Installed) Costs
Fixed capital costs
Working capital (151 FC)
Total capital
Annualized Costs
Manufacturing costs
Raw material
OiK labor (includes
onsite supervision I
clerical)
(20BO h/y/person » 16/h
burdened)
Utilities
Electricity
Water
OiH supplies (JO! of FC1)
Lab charges ($l/ton)
Total Manufacturing Costs
Fixed charges
Equipment payments
(5 yr loan t 141)
includes working capital
Local taxes & insurance
(3J of FCI)
PI art Overhead
(151 of mfg. costs)
Home Office Management
and Administration
(2S'« of mfg. costs)
Other
Credit for sale of high
zinc material (SlO/ton
dust)
Freight
Total Annualized Cost
Unit Cost for Dust
processed, i/tor

Costs per Operating Unit, $
Small
70.000
10,500
80.500


0
33.280
2,000
250
7,000
1,000
43,500

22,500
2,100
6,500
10,900

(10,000)
10,000
85, SOU
85.50
Medium
130,000
19.500
149.500


0
33.280
6,000
750
13,000
3,000
56,000

41,700
3.900
8.400
14.000

(30,000)
30,000
124,000
41.33
Large
200,000
30,000
230. 00&


0
66,560
18,000
2,250
20,000
9,000
115,800

64,220
6,000
17.370
28.950

(90,000)
90,000
232.500
25.83
 7. Higley, L.W. and Fukubayashi, H.H.,  "Method for Recovery of
   Zinc and Lead from Electric Furnace Steelmaking Dusts," Proc. of
   the Fourth Mineral  Waste Utilization Symp., Chicago,  IL,  May
   1974.
 8. Hoffman, A.O., et al., "Environmental Appraisal of Reclamation
   Processes for Steel Industry, Iron-Bearing Solid Waste," Presented
   at the Symposium on Iron and Steel Pollution Abatement Technol-
   ogy for 1980, Philadelphia, PA, Nov. 1980.
 9. Holley,  C.A. and Weidner, T.H., "New Process for Converting
   Steelmaking Fumes into Low-Zinc Pellets," Presented at  Chicago
   Regional Technical Meeting of American Iron and Steel Institute,
   Oct. 1969.
10. Holowaty, M.O., "A Process for  Recycling of Zinc-Bearing Steel-
   making Dusts," Presented at Chicago Regional Technical Meeting of
   American Iron and Steel Institute, Oct. 1971.
11. Keyser, N.H., et al., "Characterization, Recovery and Recycling of
   Electric Arc Furnace Dust," Presented at the Symposium of Iron and
   Steel Pollution Abatement Technology for 1981, Chicago,  IL, Oct.
   1981.
12. Krishnan, E.R.,  "Recovery of Heavy Metals from Electric Arc
   Furnace Steelmaking Dusts," Environ. Prog., 2, 1983, 184-187.
                                                                                                      REUSE & RECOVERY    417
-------
13.  Lehigh University, "Characterization, Recovery and Recycling of      15. PEI Associates, Inc.,  "Technical Assistance  to the Missouri De-
    Electric Arc Furnace Dust," Final Report, Bethlehem, PA, Prepared          partment of Natural Resources—Heavy Metals Recycling," Prepared
    for U.S. Department of Commerce, 1982.                                  for U.S. Environmental Protection Agency, Office of Solid Waste,
14.  Lynn, J.D., "Electric Furnace Fume Greenball Recyding-A Tech-          Washington, DC, 1982.
    nical and Economic Evaluation," Presented at  the Symposium on      16. PEI Associates, Inc., "Recycling of Dust from Electric Arc Furn-
    Iron & Steel Pollution Abatement Technology  for 1983, Chicago,          aces," Phase I  Final Report, Prepared for U.S. EPA, Office of Re-
    IL, Oct. 1983.                                                         search and Development, Washington, DC, 1984.
418    REUSE & RECOVERY
-------
               Trends  in Used  Oil  Composition  and  Management
                                                  Jacob  E. Beachey
                                             Franklin Associates, Ltd.
                                               Prairie Village,  Kansas
                                                  William L. Bider
                                                Trans World Airlines
                                               Kansas City, Missouri
ABSTRACT
  In 1983 Franklin Associates, Ltd. prepared a major technical
report  for the U.S. EPA's Office of Solid Waste. This report
developed baseline data on the composition and management of
used oil generated in the United States.
  Traditionally, a significant fraction of the used lubricating oils
generated in the  United  States  have  been environmentally
mismanaged.  Contaminated used oils with little or no processing
commonly have  been  used for  dust suppression  or burned in
boilers without pollution controls. As a result, the hazardous con-
taminants present in the oil have been dispersed into the environ-
ment, and health impacts may have occurred.
  The  U.S.  EPA has attempted to minimize the health  risks
associated with improper  used oil management by promulgating
regulations under the authority of RCRA and the Used Oil Re-
cycling Act. While the U.S. EPA has been developing and pro-
posing regulations for used oil, the quality of oil has been improv-
ing due to the decrease in the lead content of gasoline. This paper
examines the changes occurring and expected to occur in used oil
composition and management practices resulting from U.S. EPA
regulations and changes in lead levels in gasoline.

INTRODUCTION
  Over the past decade, there  has been widespread and growing
interest in used oil issues. Used oil management practices of the
late 1960s and early 1970s were criticized as being wasteful of a
valuable resource and harmful to the environment. In general, the
concerned parties, which included industry, government agencies
and environmentalists, contended that used oils could be handled
wisely or unwisely. Wise handling included reuse practices such as
re-refining and carefully controlled burning with energy  recovery.
Unwise handling included such wasteful practices as dumping and
even land disposal. Oiling roads with used oil to suppress dust was
considered more desirable than dumping or land disposal, but less
desirable than re-refining or burning as a fuel.
  Studies completed in the early 1970s showed  that more  than
50% of the generated used oil in  the United States was being
managed in what were generally considered  to be undesirable
ways.  Less than  10%  was  refined into new  lubricating  oil. A
larger  fraction  was burned as fuel,  but often without  the
necessary monitoring to assure that the public was not  being ex-
posed to any potentially  hazardous substances. Over  the  next
decade, additional studies indicated that most unwise manage-
ment practices continued to occur at significant levels.
  The  U.S. EPA has attempted to minimize the health  risks
associated with improper used oil management by promulgating
regulations under  the authority of  RCRA and the Used Oil Re-
cycling  Act. Final rules governing burning were issued on Nov. 29,
1985. On the same day, the U.S. EPA  proposed an overall
regulatory program that covers all aspects of used oil manage-
ment.   The  regulations   provide  generators,  collectors,
transporters, processors and end-users with requirements related
to storage, testing with a specification, recordkeeping and other
administrative requirements.
  While the U.S. EPA was developing and proposing legislation,
used oil quality was improving; it will continue  to improve in
1986. This change in waste oil quality is due not only to a decrease
in the lead content of gasoline, but also to behavioral changes in
anticipation of the new regulations. Since lead is one of the major
contaminants in used  oil  and  since most  lead comes from
gasoline, this change will influence used oil quality  significantly in
the future.
  This paper presents data on  baseline  used oil  contamination
levels and used  oil  flows  as developed for a  1983  Franklin
Associates, Ltd. (FAL) study for the U.S.  EPA Office of Solid
Waste.1 The 1985 regulations are then briefly  summarized  fol-
lowed by a discussion of the changes in oil composition and flows
that are expected to result from the new  regulations.

BASELINE CONDITIONS
  Two data bases were developed as part of the 1983 FAL study
for the U.S. EPA: one data base characterized  used oil flows
through the management system and  the other data base char-
acterized contaminant  levels in used oil.  The flow characteriza-
tion was accomplished  by a  literature search,  hundreds of
telephone interviews and 25 site visits to facilities involved in com-
mercial used oil management.
  Much of the information regarding the flow of used oil is un-
documented because of the unstructured nature of the used oil
management system. Federal regulations prior to 1985 did not re-
quire participants in the used oil industry to report their collection
procedures or reuse practices.
  The used oil composition characterization is based on a series
of fairly simple statistical parameters that characterize over 1,000
used oil samples. The concentrations of 19 potentially hazardous
constituents  were determined, including several  heavy metals,
chlorinated solvents, aromatic solvents,  polynuclear aromatics,
PCBs and total chlorine.

Used Oil Generation
  In 1983 approximately 1.2  billion  gallons of  used oil were
generated in  the United States.  The 1.2  billion gallons were
generated from the sale of over 2.3 billion gallons of new oil.  A
summary of the automotive and industrial used oil sales and  used
oil  generation is shown in Figure 1. Approximately 54% of
automotive oils enter the used oil market compared to about 48%
                                                                                              REUSE & RECOVERY   419
-------
                         NEW OIL SALES
Automotive -
Industrial -
Total
1,251
1.061
1731?
                                                                  USED OIL GENERATION
Automotive x
Industrial x
0.559 • 699
0.478 • 507
                                                                                            TOTAL GENERATION
                     Note: All values in million gallons
                                                           Figure 1
                                          Used Oil Generation in the United States in  1983
of industrial oils. Generation rates for various used oils take into
account losses due to leakage, spillage, combustion, disposal with
equipment  and  incorporation  into  finished products such  as
paint, putties, etc.

Used Oil Management System
  The used oil management system (UOMS) is comprised of com-
panies that collect, process and  sell used oil into several markets.
There are three basic types of companies involved in the industry:
(1) independent  collectors, who only collect and sell the oil; (2)
minor and major processors, who collect, process and sell an im-
proved product oil; and (3)  re-refiners, who collect, process and
sell a refined lube base stock. Many variations exist for each basic
type of company.
  Figure 2 shows the flow of used oil from the point of generation
through the management  system to reuse or disposal  for 1983.
Also included is a description of the reuse practices for generated
oil that does not flow through the system. This oil is  reused or
disposed of directly by the generators. Only 55^0 (669.1 million
gallons) of all generated used oil entered the used oil management
system. The remainder was reused, dumped or disposed of by the
generators (e.g., those who change their own automobile oil).
  The total number of  companies  involved  in  the used oil
management system in 1983 (excluding 500 to 1,000 independent
collectors) was 253. There  were only 13 companies involved in re-
refining used oil;  however, approximately 15% of the oil that
entered the  management system was re-refined. There were ap-
proximately 115 minor processors and  125 major processors.
Dispose! 40.8


Dinplng. (18.0 ^_ u.l
Burnt
166.8
Direr
193.9
27.1
AUTOHO
GENER/
532


TueT"5ales K.B
V.O.F.O. 15.8*

INDEPENDENT .., .

605.2
TIVE 317.4 	 "
TORS 	 \ 167.3
2 \
Fuel Use 55.2 V
Au'ttott. ft"1* >»•*: AT5V,»'-«
Flftt iQM» „
,7 	
^" IMDUST
GENERA
— *• 513.
fn-House
POS.I t.f, \rn.v i

*m "'•' /
9 FROM MINOR ; j

Fuel Use 37.1
Disposal WTr1
Roa"
	 	 -^^
V.O. EO. 41.6 ( "»"'
Hon FM! Inri 44 N. 590.1* _S
Roid Olllno *•• ,
Mej. Proe. /Re-re 4.4
On-Slte Fuel *•'
DIsposel 4.4
Fuel Seles '9.8
V.O.F.O. '".I
loed Oiling J.a u
In-SHe Fuel 9.3 (
ISPOiil *'J
Fuel Sllei 125.9
Ion-Fuel Ind. 6.8 *
In-Slte Fuel 11.0
Lulx Oil 6.5
Dlstlllete Fuel 0.7 '
IDISPOS.I 5.B '
Lube 011 56.2
Xitllleti Fuel 5.3 '
Msposi) 4.5

-^M&2.0
"^Cj_-
-»/"l5
*/^34.2
^^
-t^TTi
^/^68.S
QM.
                                                                                              VIRGIN OIL |  Fuel Seles 204.t
                                                                                              FUEL OEAURr
                                                            Figure 2
                                        Used Oil Flow Description in (he United States in 1983
 420    REUSE & RECOVERY
-------
  The fuel oil market clearly dominated with respect to end-use
applications. About 590 million gallons of used oil (nearly 50% of
all used oil entering the used oil management system) was burned
as fuel in  1983. Approximately one-half of the burned oil was
blended with  virgin fuel oil before being burned.  The industrial
market was and is the largest for burning;  however, significant
quantities also were burned in commercial, residential and institu-
tional boilers.
  Comparable quantities of used oil were re-refined and applied
to roads  for  dust control  in 1983. Approximately  83 million
gallons were received by re-refiners and nearly 74 million gallons
were used  for roal oiling. Approximately 70% of the oil received
by re-refiners  became new  lube stock, and the  remainder was
recovered as lighter distillates or was lost during processing.
  Approximately 35 million gallons of used oil were marketed for
industrial purposes other than fuel. The major application in this
category included flotation oils, asphalt extenders  and form oils.
  In 1983 over 400 million gallons of used oil, out of the total of
1.2 billion gallons generated, were disposed  of by  landfilling, in-
cineration  and dumping. Nearly 50% more oil was dumped than
was disposed  by landfilling  and incineration combined. Most of
the dumped oil is automotive oil generated by do-it-yourselfers
and large off-road equipment operators such as farmers, moving
companies, construction companies and the military.

Used Oil Composition
  Analytical data that quantify waste oil contamination in  1,071
samples were obtained  from  50 sources  for the baseline study.
The majority  of the results were obtained from state and federal
government agencies in unpublished form. Because of the variety
of data sources, there is considerable variation in: (1) the constitu-
ents that were measured; (2) the precision of the tests; and (3) the
detection limits of the equipment. These differences in technique
complicate any procedure used to combine the data  into  sum-
marized statistics.
  Table 1  summarizes used oil contamination with respect  to 19
specific constituents, 17 of which are included on the U.S. EPA's
               published list of hazardous constituents. The results are summar-
               ized according to percent detection (mean, median, 75th and 90th
               percentile concentrations), and range of measured concentrations.
                 The data in Table 1  indicate high levels of contamination for
               many constituents including lead, chromium, cadmium and sev-
               eral chlorinated  solvents.  The mean concentrations  are  badly
               distorted by a few very high values. The mean concentration for
               each contaminant is much higher than the median. PCBs were de-
               tected in approximately 18% of the samples analyzed.

                 The data in Table 1 have been categorized according to source
               and end use with the following generalizations:
               • Automotive used oils  tend to  have  higher concentrations  of
                 potentially hazardous  heavy  metals; industrial  oils tend  to
                 have higher levels of chlorinated solvents and PCBs. No signif-
                 icant differences were  noted in the concentration of aromatic
                 solvents or polynuclear aromatics.
               • Used oils from gasoline engines have much higher  lead con-
                 centrations than those  from diesel engines due to the presence
                 of leads in some gasoline additives.
               • Metalworking industrial oils have higher levels  of heavy metals
                 and chlorinated  solvents than  other industrial oils  including
                 hydraulic, compressor, turbine, electrical and others.
               • Approximately 30%  of the oil samples had a  measured flash
                 point below 140°F,* which is a criterion for classifying a  waste
                 as hazardous. Since the flash point  for virgin fuel oils is above
                 350 °F, contamination with low flash points such as gasoline or
                 chlorinated and organic solvents is  indicated.
               • Used oils do not appear to differ significantly in contamination
                 levels according to end-use markets. Similar levels of contam-
                 ination  were measured in  used oils  that  were burned,  road
                 oiled and re-refined.
               * The new used oil rules are somewhat more lenient. Used oil is subject to the full
               hazardous waste rules due to the ignitability characteristic only if the flash point is
               less than 100 °F (see Table 2).
                                                               Table 1
                                     Concentration of Potentially Hazardous Constituents in Waste Oil'
                                      Samples with
                                       Detected
                                      Contaminants
                                   Number
   Mean           Median
Concentration 21 Concentration 31
   (ppm)            (ppm)
Metal a
  Arsenic                   537        135        25        17.26
  Barium                    752        675        89       131.92
  Cadmium                   744        271        36         3.11
  Chromium                  756        592        78        27.97
  Lead 4/                   »35        760        91       664.5
  Zinc"                    810        799        98       580.28

Chlorinated Solvents
  Dichlorodlfluoromethane      87         51        58       373.27
  Trlchlorotrlfluoroethane      28         17        60     69,935.88
  1,1.1-Trlchloroethane       616        388        62      2,800.41
  Trlchloroethylene           608        259        42      1,387.63
  Tetrachloroethylene         599        352        58      1,420.89

Total Chlorine               590        568        96      4,995

Other Organics
  Benzene                   236        118        50       961.2
  Toluene                   242        198        81      2,200.48
  Xylenea                   235        194        82      3,385.54
  Benzo(a)anthracene           27         20        74        71.3
  Benzo(a)pyrene              65         38        58        24.55
  Naphthalene                 25         25       100       475.2
  PCBs                      753        142        18       108.51
                      5
                     48
                      3
                      6.5
                     240
                     480
                     20
                     160
                     200
                     100
                     106

                   1,600
                     20
                    380
                    550
                     12
                     10
                    330
                      5
Concentration
  at 75th
 Percentile 3_/
   (PP°0
       5
     120
       8
      12
     740
     872
     160
   1,300
   1,300
     200
     600

   4.000
     110
   1.400
   1,400
      30
      12
     560
      15
Concentration
  at 90th
 Percentile 31
   (ppm)
       18
      251
       10
       35
    1,200
    1,130
      640
   100,000
    3,500
      800
    1.600

    9,500
      300
    4,500
    3,200
       40
       16
      800
       50
   Concentration
       Range
  	(ppm)
 <0.01
  0
  0
  0
  0
 <0.5
<20
110
  0
                                          High
   100
  3,906
    57
   690
 21,700
  8,610
  2,200
550,000
110,000
 40,000
 32,000

 86,700
 55,000
 55,000
139,000
    660
    405
  1,400
  3.800
 1. Results determined for the analyses of 1,071 used oil samples.
 2. Calculated for detected concentrations only.
 3. For purposes of determining median  and percentile concentrations, undetected levels were
  assumed to be equal to the detection limit.
 4. Used samples collected after 1979 only.
                                                                Source: Reference 1.
                                                                                                         REUSE & RECOVERY     421
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U.S. EPA REGULATIONS FOR USED OIL
  In 1985 the U.S. EPA issued three proposals and one final rule
for the regulation of used oil. On Jan.  11, 1985, U.S.  EPA pro-
posed under Subtitle C of the RCRA regulations' that prohibit
the burning of non-industrial  boilers of used oil that does not
meet specification levels for certain hazardous contaminants and
flash point. Final rules were issued on Nov. 29, 1985.' The regula-
tions also provide  administrative controls to monitor  marketing
and burning activities.  These controls include recordkeeping re-
quirements and U.S. EPA notification of used  oil activities, in-
cluding an invoice system for  shipments.  The specifications  for
used oil that may be  burned  in  non-industrial  boilers without
regulation are listed in  Table 2.

                          Table 2
          Used Oil Furl Specification for Oil lhat May Be
                Burned in Non-Industrial Boilers
Constituent/Properly

Arsenic
Cadmium
Chromium
Lead
Total Halogens
Flash Point

Source: Rcfcrenct 3. r 49181
Allowable Level for
Burning without
Regulation

5 ppm maximum
2 ppm maximum
10 ppm maximum
100 ppm maximum
4,000 ppm maximum
100 °F minimum
   Also in  the Nov.  19,  1985  Federal Register,' the U.S. EPA
issued a proposed rule to establish standards for used oil that is
recycled, or "recycled oil."  These standards apply to generators
and transporters of recycled oil and owners and operators of used
oil recycling facilities. The standards would include tracking re-
quirements when  used oil is shipped off-site  for recycling and
facility management requirements when used oil is stored prior to
recycling. Recycled oil used as fuel would  be  subject to certain
regulations except that  fuel meeting the specifications listed in
Table 2 for toxic contaminants and flash points would be exempt
from regulations.  Uses of recycled oil  that constitute disposal
would be regulated as land  disposal,  and road oiling would  be
prohibited.
   The third  proposed rule,  also issued in the Nov.  29, 1985
Federal Register,'  would list used oil as a hazardous waste. The
effect of the listing, if promulgated, would be to control the treat-
ment and disposal of used oil (as well as its transportation, ac-
cumulation or storage prior to treatment or disposal) by subject-
ing it to full hazardous regulation under Subtitle C of RCRA. At
the same time, most used oil that is recycled would be subject to
the special management  standards of the previously mentioned
proposed standards for recycled oil.
   In the following sections, expected trends in  used oil  composi-
tion and management practices resulting from  the proposed and
final rules  are summarized.

CHANGES IN USED OIL COMPOSITION
   The burning regulations include specifications for metals, total
halogens and flash point for oil burned as fuel. Because of these
regulations, the concentrations of hazardous materials in used oil
will be reduced,  thus reducing the risk  to human health and the
environment.
   Most of the contaminants in used oil are the result of normal oil
usage. However,  significant quantities of  some contaminants
sometimes are introduced as a result of carelessness or intentional
mixing.
  Chlorinated solvents make up a major group of contaminants
in used oil. They are not a normal component of automotive oil
but often are introduced by careless practices. For  example,
automobile mechanics may pour solvents into tanks used primar-
ily for storing used automobile oils.
  Measuring total  chlorine  is  one  method  for assessing the
presence of chlorinated solvents. The 1983 baseline data indicate
typical chlorine concentrations range from 1,000 to 5,000 ppm.
However,  the total  chlorine content of some samples that were
identified  as  oil  were as  high as 40%. It is probable that these
materials were not oils at all, but rather solvents. It is expected
that  many industries,  when  faced with higher  disposal costs
because of mixing solvents with used oils, will modify these prac-
tices to keep oils and solvents segregated to the best of their ability
and therefore continue to manage the oil under the special used
oil rules rather than the full  hazardous waste rules.
  Most metals in used oil are the result of the oil's original use.
Metals concentrations in oil  can be  reduced only by blending.
Even  with blending at a 9:1  ratio,  many oils  will not meet
specifications.
  One of the major heavy metal contaminants in used oil is lead.
In the baseline study, the lead concentration in used oil ranged
from  0 to 21,700 ppm. The  high levels were most common in
crankcase  oils in samples taken in the early  1970s or from oils
taken from  leaded  gas-burning engines. Samples taken in the
1980s generally had  levels between 100 and 1,200 ppm. As stated
earlier, the major source of lead in automobile oil is the lead in
gasoline. As the  lead in gasoline continues to decrease (a tenfold
reduction  from 1983 is expected in early 1986), the  lead level in
used oil is expected  to decrease almost  proportionately.


CHANGES IN USED OIL FLOW
THROUGH THE WASTE MANAGEMENT SYSTEM
  Several  changes  are expected in used oil  flows through the
management  system. The U.S. EPA  has prepared a Regulatory
Impact Analysis (RIA) of its proposed standards for the manage-
ment of used oil.' The estimated total national annualized cost of
regulation is $168  million. The U.S.  EPA  predictions of how
these costs (and regulatory constraints) affect supply and demand
for used oil in different markets are shown in Table 3. A total in-
crease in  recycling  of  100  million  gallons is expected.  The
establishment of fuel standards is expected to shift recycled oil to
controlled  burners.  Although  the U.S. EPA study does  not
predict any burning  in hazardous waste incinerators, information
obtained  from industrial sources indicates that significant quan-
tities also may be managed in  this way, particularly oils recovered
from  treatment  facilities  and  various  types  of  oil/water
separators
  The use of used oil as a dust suppressant is banned by the pro-
posed rules. This displaced oil (currently 69 million gallons per
year)  is expected to  be used  as both re-refining feedstocks  and
fuel. Re-refining, which generally is considered a wise reuse prac-
tice by most segments of society, is expected to increase from 85
to 135 million gallons per year. There is, however, some question
about whether re-refiners can economically survive in a tight lube
oil market and with higher operating costs than the fuel oil pro-
cessors who compete for the  same oil.
  The RIA has estimated impacts on used oil generation, collec-
tion and  processor  facilities.  For industrial generators, used oil
management costs are usually very minor when compared to the
industry's production processes. It is expected that  used oil still
will be sold to collectors and processors but for a  lower price
because of the collector and  processor costs of regulatory com-
pliance. The generation from  industrial generators is not expected
to change significantly as a result of the regulations.
422    REUSE & RECOVERY
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  The impacts  of regulations  on  non-industrial (automotive)
generators are expected to be greater. The U.S. EPA has assumed
that since automotive oil  changes will cost more, more home-
owners will change their own oil. This impact could result in more
oil being dumped. The U.S. EPA estimates that full implementa-
tion of the rules will increase these homeowner oil changes by 12
million gallons per year.

                           Table 3
         Effect of Regulation on Market  Flows of Used Oil
                     (Million gallons per year)
                               Baseline

  Burning
       Industrial Boilers            249
       Asphalt and Cement Kilns      94
       Non-industrial Boilers        121
       Diesel Engines                15
       Space Heaters                 34
       On-site Boilers               _7J3
           Total Burned             586

  Re-refining
       Lube Oil                     59
       (total re-refined)            (85)

  Non-fuel Industrial                36
  Road  Oiling                       69
  Disposal                          405

       Total                     1,155


 Source: Reference 4, p. 49247.
Regulatory
  Impact
     185
     309
     117
      15
      34
      4J3
     708
     101
    (135)

     40
      0
     305

   1,155
  Collectors (particularly small collectors) are expected to ex-
perience the most significant changes in the industry structure
resulting from the U.S. EPA regulations. It is estimated that ap-
proximately 473 small and  medium-sized collectors will  find  it
uneconomical to continue operating as small independent busi-
nesses.  Although  these 473 collectors  represent  approximately
50% of the used oil recycling industry, they currently handle only
approximately 10%  of the  volume of oil entering the recycling
system. Initially, some oil may not be collected as facilities adjust
to the changes imposed by the regulations. In the long run oil will
be collected, but the nature  of the collection function is likely to
be very different after regulation.
  Some of the small collectors (an estimated 155) are expected to
grow or become part of larger businesses  and thus be able to ab-
sorb the costs of the U.S. EPA regulations.
  The  U.S. EPA  has optimistically estimated that the flow  of
used oil to re-refiners will grow by 59% as a result of the new
regulations.  This means the equivalent of six new facilities will be
opened (there are now 13).
  Minor and major processors are not likely to change drastically
as a result of the used oil regulations, although it is estimated that
12 out of the current 115 minor processors and two of the current
25 major processors may be involved in closures.
CONCLUSIONS
  The expected trends in used oil composition and management
following the promulgation of the 1985 proposed regulations are
summarized as follows:

• Reduction of lead in automotive oils as a result of the removal
  of lead from gasoline
• Reduction of chlorinated solvents in waste oil because of im-
  proved handling practices
• Reduction in the quantity of used oil burned in industrial and
  non-industrial boilers
• Increase of burning in asphalt plants and cement kilns
• Elimination of road oiling with used oil
• Large potential increase in re-refining of used oil
• Increase in  total used  oil burned  because of constraints on
  placing liquids in secure landfills
• Decrease in total disposal of used oil,  but with probable in-
  crease in dumping by do-it-yourself automobile oil changers

  The overall used  oil regulations and allowable lead level in
gasolines will result in a significantly better used oil management
system from an environmental perspective. Burning will be more
closely controlled, and the oils burned will  be of much  higher
quality.
  In the past,  generators were very careless and often purposely
mixed hazardous wastes into  oil. The new rules should modify
this behavior substantially, resulting in more oils that  are  con-
taminated only through normal use. With the planned lead reduc-
tion,  these levels of contamination are quite low compared to
earlier levels of contamination resulting from purposeful mixing.

REFERENCES
1. Franklin Associates,  Ltd., "Composition and Management of  Used
  Oil Generated in the  United States," prepared for the U.S. EPA Of-
  fice of Solid Waste, under Contracts No. 68-02-3173 and 68-01-6467,
  Nov. 1985.
2. U.S. EPA, "Hazardous Waste Management System; Standards for
  the Management of Specific Wastes and Specific Types of Facilities,"
  Proposed Rule  and  Request  for Comments,  Federal Register, 40
  CFR Part 266, 50, Jan. 11, 1985.
3. U.S.  EPA, "Hazardous Waste Management System;  Burning of
  Waste Fuel Used Oil Fuel in Boilers and Industrial Furnaces,"  Final
  Rule, Federal Register, 40 CFR Parts 261, 264, 265, 266 and 271,
  50, Nov. 29,  1985.
4. U.S. EPA, "Hazardous Waste Management System; Recycled  Used
  Oil Standards," Proposed Rule, Federal Register, 40 CFR Parts 260,
  261, 266, 270 and 271, 50, Nov. 29, 1985.
5. U.S. EPA, "Hazardous Waste Management System; General;  Iden-
  tification and Listing of Hazardous Waste; Used Oil,"  Proposed
  Rule, Federal Register, 40 CFR Parts 260, 261, 271 and 302, 50,  Nov.
  29, 1985.
6. Temple,  Barker &  Sloane, Inc., "Regulatory  Impact  Analysis  of
  Proposed Standards for the Management of Used Oil," prepared for
  the U.S.  EPA Office of Solid Waste, Washington, DC, Nov. 1985.
                                                                                                    REUSE & RECOVERY    423
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                             Used  Solvent Elimination Program

                                              Renato G. Decal, P.E.
                              Naval Energy and Environmental Support Activity
                                            Port  Hueneme,  California
ABSTRACT
  This paper will discuss the manner in which the Naval Energy
and Environmental Support Activity (NEESA) is supporting the
Navy in the implementation  of the Used Solvent  Elimination
(USE) Program.
  The Hazardous and Solid Waste Amendments of 1984 man-
date that industrial dischargers minimize hazardous waste gener-
ation at their facility. These amendments to RCRA provided an
impetus for launching the  Department of Defense (DoD)  USE
Program. The purpose of this program is to reduce the present
and  future risks  and cost associated  with the disposal of used
organic solvents by eliminating disposal as far as possible. This
program demonstrates DoD's conscientious efforts  to conserve
energy and protect the environment.

INTRODUCTION
  The Navy generates a  large amount of used oil and  solvents
(UO&S) in accomplishing its mission. As  an occupant of prime
coastal properties, the Navy is in a very precarious position of
maintaining a delicate balance between fleet readiness and pres-
ervation of environmentally sensitive  areas.  In  support of the
Department  of Defense's  (DoD) Solvent Elimination  System
(USE), the Navy  set a goal to  eliminate as far as possible the dis-
posal of used organic solvents. Means to achieve the goal include,
but are not limited to:

• Process changes
• Material substitution
• Recycling/reclamation

  The initial thrust of the Navy's USE Program is the recycling/
reclamation of solvents.  Process changes  and material substitu-
tion will be investigated further  under  the  Navy's  Hazardous
Waste Minimization Program. Recycle/reuse of these  by-pro-
ducts can reduce fuel consumption, save energy and provide mon-
etary savings to the Navy. Naval installations classified as major
generators of solvents (shipyards, ship repair facilities, air rework
facilities, etc.) have been identified and instructed to implement a
USE Program no later than Oct. 1, 1986.
  All other activities that generate over 400 gal of used solvents
per year must implement a USE Program by Oct. 1,  1987. Activ-
ities can receive technical assistance from their Engineering Field
Division (EFD) and Naval Energy and Environmental Support
Agency (NEESA) as they start their USE Program. This assis-
tance includes feasibility studies, equipment and training.
  Studies were initiated at six large industrial naval bases in Fis-
cal  Year (FY) 1985. In FY86, USE studies are scheduled to be
started at approximately 50 naval installations.
  NEESA studies include used oils since the U.S. EPA soon may
classify used oils as hazardous wastes and used oils often are
mixed with used solvents.
  The study focuses on developing a recycling program that is
environmentally sound, cost-effective, simple to implement, re-
quires little training, has low labor requirements and uses solvent
distillation equipment that is commercially available.

PLANNING
  Prior to initiating the UO&S study at an activity, an ad hoc
committee is organized to ensure maximum participation of per-
sonnel who will be directly affected by  this program. The  com-
mittee members will provide input on  which recycling alterna-
tives they prefer for implementation at their shops.  In addition,
the committee will be involved in the review of the interim reports
and decision-making process during the course of the study.

UO&S STUDY
  The UO&S recycling study consists of three steps:
• UO&S Inventory
• Evaluation of Alternatives
• UO&S Recycling Program Development

Step 1—UO&S Inventory
  A site visit is conducted to obtain the following information as
a minimum:

• Annual generation rates of UO&S in  gal/year
• Location (building number, ship type and hull number, etc.)
• Common name, chemical compound  name and MILSPEC of
  product
• Usage information (brief description of how UO&S are gen-
  erated)
• Probable contaminants and the corresponding chemical and
  physical properties
• Current disposal procedures
• Anticipated variations in above findings
• Purchasing and Disposal Records
• All UO&S in accordance with U.S. EPA, State and local regu-
  lations and requirements

  Previous studies related  to UO&S are reviewed and the rele-
vance of their findings to this effort indicated.
  In determining annual generation rates, maximum and  mini-
mum values as well as  average values are obtained.  Where aver-
age values are not available, as may be the case for solvent dis-
posal, estimates based on process  knowledge and characteristic
losses (i.e., solvent evaporative losses) are estimated.
  The information obtained is tabulated and reviewed by the ad
hoc committee for accuracy.
  It is preferable to conduct the inventory by visiting the  shops
and interviewing shop  personnel. This process  takes only  a few
minutes of shop personnel time and gives the investigator a first-
424   REUSE & RECOVERY
-------
hand knowledge of the operations. Questionnaires should not be
sent to shop personnel. More than likely, they will not be able to
provide all the  information needed.  Shop personnel should be
notified at least  1 month in advance of the site visit.


Step 2—Evaluation of Alternatives
  The key to a  successful recycling program is to keep it simple
and to maintain  the degree of segregation required.
  The most practical UO&S recycling program options are:
• On-site/Off-site reclamation of solvents
• Closed loop recycling of  high value hydraulics and lubricants
  with manufacturers
• Burning of appropriately segregated UO&S in Navy boilers
• Sale of UO&S through Defense Reutilization and Marketing
  Office (DRMO)

On-Site Recycling
  On-site recycling of used solvents located as close to the source
of generation as  possible usually will yield the most cost-effective
results. Accordingly, on-site recycling is emphasized as the pri-
mary USE program option.  On-site recycling of used solvents in-
volves use of distillation equipment (stills). There are many types
of stills commercially available in sizes ranging from 5 gal to over
200 gal. Stills are available which can be run on a batch or auto-
matic mode. In addition, some are explosion-proof and have op-
tional features for easy operation and maintenance.
  On-site recycling currently is being practiced at the  Norfolk
Naval Shipyard Paint Shop utilizing a small still for recycling used
paint thinners with impressive results. A savings of approximate-
ly $17,000/year  is realized due to reduced consumption of virgin
paint thinners and less volume of paint sludge for disposal. Pres-
ently,  10 stills are being ordered for four naval installations and
the Navy expects to procure more than 15 stills in FY87.

Off-Site Recycling
  Where on-site  recycling may not be cost-effective or may be dif-
ficult to implement, off-site recycling  by commercial contractors
offers a viable solution for recycling UO&S. As in the case of on-
site recycling, proper segregation of used solvents must be main-
tained. Costs for recycling by commercial contractors vary as a
function of virgin  material  costs, volumes, handling and trans-
portation costs and ease of recycling. Overall savings for naval in-
stallations of about 20-30%  can be achieved using reclaimed sol-
vents instead of virgin material for parts cleaning.
  There are some companies which provide equipment and sol-
vents for parts cleaning under a lease agreement. When the sol-
vent gets too dirty, it is replaced by the supplier. Because  the sol-
vent essentially is leased out to the customer, this type of opera-
tion becomes very attractive for smaller Navy  facilities because
the supplier assumes all responsibility for the solvent, including
ultimate disposal.  Presently, the Construction Equipment De-
partment at Naval Construction  Battalion  Center (CBC) Port
Hueneme is utilizing off-site recycling for Dry Cleaning Solvent.
Shop personnel are very satisfied with the operations.

Closed Loop Recycling
  Closed loop recycling of high value hydraulics and lubricants
with manufacturers is another recycling alternative worth inves-
tigating. This option may be employed when large volumes of
contaminated high value hydraulics and lubricants are being gen-
erated by an activity located near major industrial centers where
the manufacturers' processing facilities are available for reclama-
tion. Under this  option, the manufacturer contracts with the ac-
tivity to perform either of the following tasks:
 • Reclaim the used petroleum product and return it directly to
   the activity. A per gallon fee is charged which generally de-
   pends on the handling, transportation and processing costs.
 • Accept the  contaminated petroleum products and give the
   activity credits on its purchase of virgin materials. This option
   is not likely to be cost-effective for lubricants which have com-
   plex and diverse additive packages  and which  would require
   costly requalification testing.

Burning
   Burning of appropriately segregated UO&S in Navy boilers has
been practiced  at some  Naval  installations. CBC Port Hueneme
has burned contaminated oil at 5% blend with fuel oil #5 at the
Thompson Boiler Plant without any boiler modifications.
   Among the waste solvents being generated at Navy shops, only
PD-680 Type II is recommended for blending with fuel oils. Hal-
ogenated solvents must be kept segregated and must not be mixed
with used oils intended for use as boiler fuel. Halogenated  sol-
vents combine with  water to form a corrosive mixture that would
attack the boiler tubes and result in untimely breakdowns. Like-
wise, to avoid explosion, high flash solvents (having a flash point
greater than 140° F) must not be mixed with low flash solvents.
Sale
   Sale through DRMO is the least favorable option because, be-
fore this sale can be completed, it may go through a reuse, trans-
fer, donation and sale cycle which makes the UO&S available to
any federal, state or local government agency upon request and at
no economic benefit to the generating activity. Furthermore,
approval by knowledgeable personnel from a higher command is
required before this  option could be implemented.
   Recently, the DoD added an impetus to recycling used solvents.
The DoD directed naval activities to implement a  directive that
immediately prohibits landfill disposal  of certain  used  solvents.
This ban made  recycling of used solvents even  more  desirable
since  the amount of certain used solvents  to be ultimately  dis-
posed  of (by incineration) after recycling will be reduced by 70-
80%, thereby drastically reducing the disposal cost.
   The ad hoc committee is consulted to assist in identifying which
of the four alternatives provides a combination  of practicable
UO&S recycling programs that is in full compliance with applic-
able environmental regulations. For each recycling  alternative,
the following information is provided:
•  Present worth cost
•  Expected annual cost
•  Savings
•  Payback period
   Cost includes one-time  and recurring  costs associated  with
collection, transportation, segregation,  recycling and disposal of
non-recyclable UO&S. An interim Step 2 report incorporating the
above information is presented to the ad hoc committee for re-
view and concurrence.

Step 3—UO&S Recycling Program Development
   Once the ad hoc  committee decides on the preferred recycling
alternatives  for implementation, a recycling program is devel-
oped.  This program contains  instructions, detailed  operational
procedures and identification of key personnel to implement the
program. The UO&S recycling program consists of two parts.

Part I—Recycling
  The Part I program includes:
•  Identification of the UO&S sources with annual volumes by oil
  type or group.
                                                                                                   REUSE & RECOVERY    425
-------
• Identification  of the selected recycling  alternative  for  each
  group/source and the corresponding manpower requirements.
• Schedule for implementing the recycling program and delinea-
  tion of respective command responsibilities.
• Identification of interim practices/improved management pro-
  cedures that can be implemented immediately until the recom-
  mended recycling program can be fully implemented and re-
  quired facilities can be constructed.
• Identification of shop practices which will result in the reduc-
  tion of UO&S generation.

Part II—Recycling
  Part II of the recycling program delineates specific procedures
and  provides design parameters and specifications for necessary
facilities/equipment for the selected recycling alternative. In addi-
tion, a  description of the selected alternative for each group/
source is presented. This description  includes, but it not limited
to:

• A description of the source, recycling group and correspond-
  ing disposal program
• A description   of the responsibilities and identification of per-
  sonnel required to implement the selected recycling program; a
  description of the training program that will be required of the
  personnel who will implement the selected recycling program
• Procedures  for segregating UO&S  in accordance with respec-
  tive recycling alternative
• Procedures  for establishing  collection  points,  frequency  of
  collections and transfer centers where required
• Development of design parameters for facilities and/or equip-
  ment specifications for collection/transfer and recycling and its
  respective location
• Development of design criteria for special equipment required
  for  blending,  grouping  or  mixing chemically compatible
  UO&S. Establishment of procedures for blending,  handling
  and disposal of UO&S in accordance with the HSWA require-
  ments.
• Identification of existing collection, transfer,  treatment, dis-
  posal/reuse procedures that are  implementable within  the
  framework of the proposed program.
• Identification of disposal  procedures for UO&S sources that
  are not suitable for recycling
• Development of procedures or operational  improvements and
  providing design parameters and specifications  for  required
  support facilities or equipment for sources where reduction of
  UO&S generation is viable
  The completed UO&S Recycling Management  Program is re-
viewed and approved by the ad hoc committee.  Once  the pro-
gram is finalized, it is included in the base hazardous waste man-
agement  plan.  Instructions  for implementing this  program  are
outlined in the base instruction.

CONCLUSIONS
  NEESA UO&S studies showed that:
• Maintaining the degree of segregation required in UO&S is very
  important to ensure a successful recycling program.
• On-site recycling using  small capacity stills at the source of
  generation is the most cost-effective and simple way to recycle
  used solvents.
• For used oil, blending with virgin fuel oil and  burning in the
  boiler is practical.
• The estimated annual savings from recycling of UO&S at Navy
  and Marine Corps bases is $30,000-5200,000 depending upon
  the type of industrial operations.
• Recycling of UO&S has proven to be an effective program for
  conserving valuable resources and  preventing  environmental
  degradation without sacrificing the Navy's mission.

REFERENCES
I. NAVFAC UO&S Recycling Guide.
2. OPNAVINST5090.I.
3. "Utilization of Navy Generated Waste Oil as Boiler Fuel—Handbook
  of  Guidelines and Field Survey Results," NCEL Technical Report
  No. N-1674, Aug. 1983.
4. "Defense Fuel Supply Center Reference List of Commodities, Spec-
  ifications and Standards for  Petroleum and Related  Products," Oct.
  1982.
5. NAVFAC P-442, "Economic Analysis Handbook," June 1975.
6. "In-House Solvent Reclamation," NEESA 20.2-012, Oct. 1984.
7. "Guide for  Developing A  Recyclable  Materials Sales  Program,"
  NEESA 5-010.
8. "Assessment of Solvent Distillation Equipment," NEESA  20.3-012,
  Dec. 1985.
426    REUSE & RECPVERY
-------
                           Waste Reduction Audit Procedure—
                    A Methodology for Identification, Assessment
                   and  Screening of Waste Minimization  Options

                                              Carl H. Fromm, P.E.
                                            Michael S. Callahan, P.E.
                                     Hazardous & Toxic Materials Division
                                    Jacobs Engineering Group Incorporated
                                               Pasadena,  California
ABSTRACT
  This paper describes a waste reduction audit procedure, a man-
agement tool designed to generate a comprehensive set of waste
minimization options for a specific process and rank the options
to evolve those deserving either immediate implementation or an
in-depth evaluation. The procedure relies on a programmed sys-
tematic approach and is described in detail along with the actual
case example.
  Additionally, waste  minimization definitions are provided to-
gether with: a discussion on why waste occurs,  a characteriza-
tion of  factors inhibiting  waste minimization  activities and a
checklist to help identify waste reducing measures.

INTRODUCTION
  The Waste Reduction Audit Procedure (WRAP) described in
this paper  is a management tool intended to help  achieve  the
following objectives:
• To generate a comprehensive list of waste minimization meas-
  ures or options applicable to a specific industrial process
• To rank all identified waste reduction options and use these
  rankings to allow management to focus on options deserving
  further in-depth consideration
  The ultimate outcome of a WRAP is a report to management
that  contains  concrete  recommendations concerning which
options to pursue and/or implement.

BACKGROUND
  In 1981,  it was estimated that nearly 80% of all the hazardous
waste generated in the  United States ended up in landfills, pits or
ponds.1 Landfilling has been the most popular form of disposal
chiefly because of its low cost and simplicity. However, this situa-
tion has been changing  since the Federal government  adapted
The Hazardous and Solid Waste Amendments of 1984 to RCRA.
  The major goal of  the 1984 RCRA  Amendments is to min-
imize both the generation of hazardous waste and the practice of
land disposal. Achievement of this goal currently is being pro-
moted by at least two factors:
• Increased land disposal costs, which are the result of new regu-
  latory requirements for  mandatory groundwater monitoring,
  leachate  collection and treatment, installation of double liners
  and solidification of liquid wastes
• Waste minimization certification requirements demanding that
  generators of hazardous wastes certify that the volume or quan-
  tity and toxicity of the hazardous wastes they generate has been
  reduced to the degree economically practicable
  Land disposal costs have been increasing significantly and will
continue to do so. According to estimates over the last year, the
cost of landfilling drummed waste has increased more than 50%,
bulk solids 60 to 70% and bulk liquids 100%. The cost impacts of
waste  minimization certification requirements cannot be eval-
uated  easily since the requirements are recent (Sept.  1, 1985).
However, hazardous waste minimization already has been recog-
nized by many companies as a desirable goal, and there is strong
evidence indicating considerable interest, activity and progress in
this area.2

WORKING DEFINITIONS
  What is "waste minimization"? At the time of this writing,
the U.S. EPA had not issued a formal definition. In  lieu of a
formal definition, the following working definitions are used:
• Waste minimization—any source reduction, recycling or treat-
  ment activity  that reduces the volume or toxicity  (through
  means other than dilution) of any hazardous waste that is land
  disposed;
• Treatment  (as part of waste minimization)—any activity or
  series of activities that results  in reduction of the volume and/
  or toxicity  of the hazardous waste without attendant genera-
  tion of a valuable material that is subsequently employed in the
  manufacture of a commercial product (example—an incinera-
  tor for disposal  of spent chlorinated solvent with scrubbing
  and neutralization of hydrogen chloride from the flue gas);
• Recycling (as part of waste minimization)—any activity that re-
  duces the volume and/or toxicity of the hazardous waste with
  attendant generation of a valuable material subsequently em-
  ployed in the manufacture of commercial product (example—
  distillation  of spent cleaning solvent with subsequent reuse of
  the recovered clean solvent;
• Source reduction—any activity that reduces or eliminates the
  generation  of a hazardous waste within the industrial process
  (example—replacement of chlorinated solvent by a biodegrad-
  able, water-based  cleaning detergent solution).

  Of the three components of waste minimization, recycling and
source reduction can be subdivided further (Fig. 1). It is useful
to distinguish between reclamation and use/reuse as two separate
recycling activities.
  Source reduction,  the most prominent component  of waste
minimization, consists of product  substitution and source con-
trol. Product substitution means the replacement of an original
product and use of another product suitable for the same end use,
or the alteration of an original product use which results in a de-
crease or elimination of hazardous waste generation associated
                                                                               WASTE MINIMIZATION PROGRAMS   427
-------
                                                       MINIMIZATION OF HAZARDOUS WASTE  |




1
| RECYCLING | [SOLRCE RHXJCT1CN|


1 1 1
RECLAMATION
| |-»OR
•T |
ti pt
USE/REUSE
T?"'
TT>,
1 — OR
T
LEGEND
1 - PROCESS
1 — WASTE TREATMENT INIT
1 	 ' lEfOOFPIPE)
R — RAW MATERIAL
W — WASTE
U -PRIMARY. 2-SECOfOARY 1
| 	 | - WASTE TO DISPOSAL
»OTE5
1. «, < W. FOR BOTH VOLUME AMI/OR TOX1CITY


TOXCT SUBSTITUTION
l.USf OF COCRETE
PlLlNCS INSTEAD
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2 HERACEitNT OF
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-------
                                                                    Table 1
                                      Summary °f Waste Generation Origins, Causes and Controlling Factors
               Waste  Origin
                       Typical Causes
                                                            Operational Factors
                                Design Factors
               Chemical Reaction
                     • Incomplete reactant conversion
                     • Byproduct formation
                     • Spent catalyst - deactivation
                       due to poisoning, sintering, etc.
• Inadequate temp, control
• Inadequate mixing
• Poor feed flow control
• Poor feed purity control
• Inadequate reactor design.
• Catalyst design or selection
• Choice of  process path
• Choice of  reaction  conditions
• Fast quench
• Inadequate instrumentation or
  controls design
• Poor heat  transfer
               Contact Between
               Aqueous and
               Organic Phases
                       Vacuum production via steam jets    • Indiscriminate use of water    • Choice of process route
               Disposal of Unusable
               Raw Materials and
               Offspec Products
                     • Presence of water as a reaction
                       byproduct
                     • Use of water for product rinse
                     • Equipment cleaning
                     • Cleaning of spills

                     • Offspec product generation
                       caused by contamination,
                       temperature/pressure excursions,
                       improper reactants proportioning,
                       inadequate pre-cleaning of
                       equipment or workpiece
                     • Obsolete raw material inventories
  for cleaning or washing
• Poor operator training
  and supervision
• Inadequate quality control
• Inadequate production
  planning and inventorizing
  of feedstocks
• Vacuum production via vacuum
  pumps
• Use of  reboilers instead of
  steam stripping
• Clingage reduction

• Extensive use of automation
• Maximizing dedication of
  equipment to a single process
  function
               Process Equipment    • presence of clingage (process side)   • insufficient drainage prior     • design for lower film temp in
               Cleaning
Metal Parts
Cleaning
                       and scale (cooling water side)
                     • deposit formation •
                     • use of filter aids
                     • use of chemical cleaning agents
                                    • disposal of spent solvent,
                                      cleaning sludge or spent
                                      cleaning solution
  to cleaning
• inadequate cooling water
  treatment
• excessive cooling water
  temperatures

• indiscriminate use of
  solvents and water
  heat exchangers
• design of reactors or mixing
  tanks with wall wiper blades
• controls to prevent cleaning
  water from overheating

• choice between cold dip tank
  or vapor degreasing
• choice between solvent vs.
  aqueous cleaning solution
               Metal Surface
               Treatment
                     • dragout
                     • disposal of spent treatment
                       solutions
• poor rack maintenance        • counter-current rinsing
• indiscriminate rinsing with    • fog rinsing
  water                       • dragout collection tanks
• fast withdrawal of workpiece
               Spills and Leaks
               Cleanup
                     • manual material transfer
                       and handling operations
                     • leaking pump seals
                     • leaking flange gaskets
• inadequate maintenance
• poor operator training
• lack of operator attention
• indiscriminate use of
  water in cleaning
• choice of gasketing material
• choice of seals
• use of welded or seat-welded
  construction.
• Lack of awareness of the benefits of waste minimization
• Lack of technical staff
• A "hands off the process" attitude caused by fear of upsetting
  a product's quality
• Organizational inertia (for example,  an "if it  isn't broke—
  don't fit it" attitude)
                                                           • Internal politics  of the organization  (for  example, an inno-
                                                             vator may feel inhibited by a fear of the lack of management's
                                                             support)
                                                           • An "it  can't be done" attitude; people may reject an innova-
                                                             tive approach merely because it  is outside their  range of ex-
                                                             perience
                                                                                                WASTE MINIMIZATION PROGRAMS    429
-------
   In implementing a WRAP, the above inhibiting factors  al-
 ways must be recognized, since  their identification and recog-
 nition allows formulation of constructive approaches to over-
 come them.

HOW TO IMPLEMENT A WASTE REDUCTION
AUDIT PROCEDURE
  The WRAP developed by the authors of this paper consists of
eight sequential steps:
• Selection of the audit team
• Compilation by the audit team of a waste stream list for the
  facility with the associated flowrates
• Generation by the audit  team of waste reduction  options for
  each waste stream
• Ranking by the audit team of each compiled  option in three
  categories: effectiveness, extent of current use and  applica-
  tion potential
• Preparation by the audit team of documentation in support
  of selected options
• Presentation, discussion and joint review with  plant personnel
  of options and their rankings
• Analysis by the audit team of revised rankings
• Final report preparation
  The above procedure is  applicable to all three categories of
waste minimization (treatment, recycling and source reduction).
However, it originally was developed and tested for source reduc-
tion options only. Source reduction measures should be consid-
ered even  when  recycling  or treatment  options are given prior-
ity. This is because reducing the quantities of waste  that are re-
cycled or treated often means an increase in revenues (e.g., due to
an increase of product yield and lower cost of treatment).

Selection of the Audit Team
  To effectively conduct a WRAP, it is necessary first to desig-
nate a leader for the audit. This person should have solid  tech-
nical credentials and demonstrated problem-solving ability and
can be either from within the company being audited  or from the
outside consulting firm conducting the audit. The leader and his
team (audit team) preferably should not have any previous exten-
sive association with the plant to be audited, primarily  to avoid
biases and to  bring an independent  perspective into analysis.
Management must  give the audit team  enough authority to gain
access to all required technical documentation (process flow dia-
grams,  piping and instrumentation  diagrams,  inventory  logs,
operations logs, etc.) and technical personnel within the plant.

Waste Stream List
  The second step consists of compiling a list of all waste streams
leaving the plant. It may prove beneficial to include not only haz-
ardous wastes destined for landfilling, but also  other emissions
such as  wastewater, air emissions and  non-hazardous  wastes.
Waste stream identification and quantification may require exten-
sive site inspection,  review  of process documentation, interviews
with plant operations personnel and, in some cases, material bal-
ance calculations.
  Reviews of process flow  diagrams, heat and material  balances
and piping and instrumentation diagrams are particularly useful.
Each diagram should be analyzed for all points where waste gen-
eration can occur. When producing a chemical commodity, typi-
cal sources include reaction byproducts leaving the process as dis-
tillation column bottoms. Also, equipment cleaning wastes (e.g.,
wastes from storage tanks and heat exchangers) must be con-
sidered,  although they are usually minor in a continuous pro-
cess.  In a  batch  process, large  quantities of waste can  be  asso-
                                                             ciated with cleaning operations, such as cleaning out a mix tank
                                                             or reactor. Since these incidental wastes rarely appear on process
                                                             flow diagrams or are mentioned  in  process descriptions,  dis-
                                                             cussions with key operations personnel are important.
                                                               Waste streams must be quantified  on a uniform basis.  If a
                                                             stream is intermittent, it should be represented as a pseudo-con-
                                                             tinuous stream.  After all waste streams are quantified, it is  use-
                                                             ful to express each of them as a percentage of the total quantity
                                                             of waste leaving the process.

                                                             Waste Reduction Options
                                                               The third step in WRAP involves the generation of waste re-
                                                             duction options  for each stream previously identified. Good re-
                                                             sults can be  obtained in  the course of a brainstorming  session
                                                             preceded by  independent preparation  by each participant. This
                                                             session must  involve only the outside audit team — no plant per-
                                                             sonnel  must be present. The reasons for exclusion of plant per-
                                                             sonnel at this point include:
                                                             • Working through the options generation process without plant
                                                               personnel forces the audit team to work harder to gain a good
                                                               understanding of the process and analyze it with a long-vision
                                                               perspective — which is often absent among the plant operators.
                                                             • It is necessary, at this  stage,  to postulate a  maximum  number
                                                               of options.  The  presence of  plant personnel may inhibit peo-
                                                               ple from submitting an option to the list.
                                                               Tables 1 to 4, developed by the authors of this paper, are pro-
                                                             vided to stimulate the discussion process to identify possible use-
                                                             ful waste reduction measures. Tables 2 to 4 contain checklists of
                                                             waste reduction measures compiled based on many process analy-
                                                             ses and on experience with actual industrial WRAP applications.

                                                                                        Table 2
                                                                    Waste Reduction Methodology Checklist: All Processes
                                                             All Waste Streams
 6.
 7.
 8.
 9.
10.
11.
12.
                                                                                     Use higher purity materials
                                                                                     Use less toxic raw materials
                                                                                     Use non-corrosive materials
                                                                                     Convert from batch to continuous process
                                                                                     Tighter equipment inspection and maintenance
                                                                                     Better operator training
                                                                                     Closer supervision
                                                                                     Practice good housekeeping
                                                                                     Eliminate or reduce water use for spill cleanup
                                                                                     Implement proper equipment cleaning techniques
                                                                                     Use improved monitoring s> stems
                                                                                     Use pumps with double mechanical seals
                                                             Commodities Produced Continuously

                                                             Examples:            Aery lonitrile, Epichlorohydrin, Petroleum Refining,
                                                                                 1,1,1 Trichloroethane, Trichloroelhylene/Perchloro-
                                                                                 ethylene, Vinyl Chloride Monomer
                                                             Heav> and Light Ends
                                                             Spent and Lost
                                                             Catalyst


                                                             Equipment Cleaning
                                                             Wastes
                                                             Leaks and Spills
 1.   Develop more selective catalyst
 2.   Optimize the reaction variables/reactor design
 3.   Use alternate process routes
 4.   Combust with heat (and HCD recovery

 1.   Develop tougher catalyst support
 2.   Use filter inside reactor freeboard
 3.   Regenerate and recycle spent catalyst

 1.   Increase equipment drainage time
 2.   Use corrosion resistant materials
 3.   Agitate and/or  insulate storage tanks
 4.   Re-examine need for chemical cleaning
 5.   Use nitrogen blanket to reduce oxidation
 6.   Use in-process HX cleaning devices

 1.   Use bellow-sealed valves
 2.   Use canned (seal-less) pumps
 3.   Maximize use of welded vs. flanged pipe joints
430
WASTE MINIMIZATION PROGRAMS
-------
                             Table 3
    Waste Reduction Methodology Checklist: Commodities Produced
                            in Batches
 Examples:
                 Dyes, Inorganic Pigments, Paint, Agricultural Chemicals
                 Formulation, Phenolic Resins, Wood Preserving
Material Handling     1.
                    2.
                    3.
                    4.
                    5.

Reaction/Processing   1.
Step                 2.
                    3.

Filtration and        1.
Washing             2.
                    3.
                    4.
                    5.

                    1.
                    2.
                    3.
Baghouse Fines
Off-Spec Product     1.
                    2.

Equipment Cleaning   1.
                    2.
                    3.
                    4.
                    5.
                    6.
                    7.
                    8.
                    9.
Leaks and Spills
                    1.
                    2.
                    3.
                    4.
Segregate containers by prior contents
Use rinseable/recyclable drums
Purchase materials in bulk or in larger containers
Purchase materials in preweighed packages
Use pipeline for intermediate transfer

Optimize the reaction variables/reactor design
Optimize the reactant addition method
Eliminate the use of toxic catalysts

Employ efficient washing/rinsing methods
Eliminate the use of filter aids
Use countercurrent washing
Recycle spent washwater
Maximize sludge dewatering

Increase use of dust suppression methods
Use wet instead of dry grinding
Schedule baghouse emptying

Tighter control of reaction temperature
Reformulation of off-spec product

Install high pressure spray wash system
Alter production schedule
Use mechanical wipers on mix tanks
Clean mix tanks immediately after use
Use a countercurrent rinse sequence
Recycle spent rinse water
Increase spent rinse settling time
Re-examine need for chemical cleaning
Dewater spent rinse sludge

Use bellow-sealed valves
Install spill basins
Use canned (seal-less) pumps
Maximize use of  welded vs. flanged pipe joints
 Option Rating
   The fourth step involves rating, by the audit team, of each op-
 tion generated in term of three categories (effectiveness,  extent of
 current use and future application potential).  While the meaning
 of "effectiveness" is fairly obvious, "extent of current use" and
 "future application potential" need more discussion. The extent
 of current use can be based on either the number of waste streams
 that are controlled using a given method or the frequency of use
 of a given method on a particular waste stream. The future appli-
 cation potential is  a measure  of the probability that  a  given
 method will be implemented in the future. This variable is highly
 dependent on capital and operating cost, level of difficulty,  im-
 plementation period,  product  yield  credits,  technological risk
 and the risk of detrimental effects on product quality.
   In the course of developing and using this  audit  approach, it
 was convenient to ask people to  rank each item on a scale of zero
 to four or zero to ten. Usually, the scale chosen will depend on
 the people conducting the WRAP and the extent of their knowl-
 edge.  When people are asked to what  extent a given method cur-
 rently is implemented, it may be difficult for them to come up
 with an  answer.  However, when  asked  to rank  these  same
 methods  on a scale of zero to four where the inference is from
 low to high,  answers often are more forthcoming. Once each
 method is ranked, the amount of waste currently being minimized
 and the  potential  future  reduction   index  can  be  calculated
 according to  the equations presented in the Appendix of this
 paper. In addition, one or more waste reduction methods should
 be singled  out for further study and implementation for each
 waste stream.
                                                                                                    Table 4
                                                                         Waste Reduction Methodology Checklist: Manufacturing Operations

                                                                       Examples:          Electroplating, Lithographic Printing, Metal Parts
                                                                                          Cleaning, Metal Surface Treatment, Paint Application
                                                                                          Printed Circuit Boards
Material Handling    1.   Segregate containers by prior contents
                   2.   Use rinsable/recyclable drums
                   3.   Purchase materials in bulk or in larger containers
                   4.   Purchase materials in preweighed packages

Solvent Cleaners     1.   Install/operate cleaning tanks properly
                   2.   Avoid cross-contamination of solvent
                   3.   Avoid water contamination of solvent
                   4,   Remove sludge continuously
                   5.   Monitor solvent composition
                   6.   Consolidate cold cleaning operations
                   7.   Recycle spent solvent
                   8.   Use plastic bead blasting for  paint stripping

Alkaline/Acid       1.   Install/operate cleaning tanks properly
Cleaners            2.   Avoid cross-contamination of solvent
                   3.   Remove sludge frequently

Plating/Etching/     1.   Increase plating solution bath life
Surface Finishing    2.   Use lower concentration plating bath
Solutions           3.   Use trivalent Cr in place of hexavalent Cr
                   4.   Use non-cyanide plating solutions
                   5.   Use in-line recovery techniques
                   6.   Regenerate spent bath solutions
                   7.   Segregate all waste streams
                   8.   Inspect all parts for proper cleanliness

Rinse Water         1.   Install/operate all rinse tanks properly
                   2.   Use multiple rinse tanks
                   3.   Install drain boards and drip tanks
                   4.   Use fog nozzles and spray units
                   5.   Agitate rinse bath
                   6.   Use deionized water for rinsing
                   7.   Recycle and reuse rinse water
                   8.   Segregate all waste streams
                   9.   Reclaim metal from  rinse water

Paint Application    1.   Use equipment with low  overspray
                   2.   Inspect all parts before painting

Leaks and Spills      1.   Install splash guards and drip  boards
                   2.   Prevent tank overflow
                                                                       Audit Documentation
                                                                         The fifth step involves preparation by the audit team of any
                                                                       documents outlining the concept, rationale and intended imple-
                                                                       mentation of options which are  not obvious and hence require
                                                                       explanation. This may involve a block flow diagram, a proposed
                                                                       revision of a piping and instrument diagram, an outline of pro-
                                                                       posed new equipment, a narrative description, etc.

                                                                       Presentation to Plant Personnel
                                                                         The sixth  step  is most crucial, as it involves presentation  of
                                                                       the options evolved to the plant personnel. The chief objective of
                                                                       this session is to stimulate the innovative process within the entire
                                                                       group  and not simply to have the plant people select from the
                                                                       menu prepared by the  audit team.  For that reason, the  audit
                                                                       leader must be firmly in control of the meeting; after all, innova-
                                                                       tion is intended to occur through an interactive process that may
                                                                       include controlled conflict. An atmosphere of conflict, or at least
                                                                       polarization, is likely to exist between the members of the audit
                                                                       team and plant personnel as each proposed option is subjected to
                                                                       review. New rankings very often will be evolved, and alternative
                                                                       options to those previously compiled often will emerge. The func-
                                                                       tion of the audit leader  is to moderate the discussion, to provide
                                                                       positive  resolution of  conflicting  opinions (e.g.,  subject  the
                                                                       option to ranking by vote) and  to  keep the discussion focused
                                                                       on the subject. Prior to  the meeting,  plant personnel  must re-
                                                                                           WASTE MINIMIZATION PROGRAMS     431
-------
view and analyze the postulated options. However, the meeting is
the culmination of the entire process. At the end of the meeting,
the leader should undertake a review  of the new rankings ob-
tained for each option now appearing on the list. Any residual
disagreements should be resolved at that time.

Analysis Re-Ranking
  The seventh step involves the re-analysis of the  rankings to
evolve new waste reduction indices for each option as described
in the Appendix.

Future Reduction Potential
  The eighth and the final step involves review of "future reduc-
tion potential" indices, options screening and preparation of the
final report in which  the WRAP results are presented to com-
pany management. The report and any recommendations must be
reviewed and concurred with by plant personnel.

A WRAP CASE STUDY
  WRAP was applied to the batch process partially depicted in
Figure 2 with the purpose of developing a process or equipment
configuration minimizing emissions  of toxic powders  into the
workspace environment. The release  of these powders,  apart
from presenting an exposure problem to the operators, ultimately
results in hazardous waste generation. The waste is generated
when the work area is hosed down and the  wastewater is sent to
a clarifier in which a toxic sludge settles  out.
  The part  of the process described involves weighing, mixing
and dispersion of two toxic powders (Powders A and B) in the wet
grinding unit. At the end of the wet grind operation, the slurry is
poured into drying trays, which are placed into a drying oven.
After the mixture has dried, the trays are manually removed and
emptied into a dry grinding unit. As the powder is ground, it
flows into a lined drum which then is sent to the existing equip-
ment for additional processing. The waste producing operations
identified were weighing operation, wet grind loading and un-
loading and dry grind loading and unloading.
  For each operation, all of the control methods originally postu-
lated by the consultant were listed (Table 5). The list was reviewed
and modified during the meeting between the client's design and
operating personnel  and the  consultant. It was during this time
that  each method was ranked for its effectiveness, extent of cur-
rent  use, future application potential and the  fraction of waste
generated by each process operation. In addition, the group was
asked to add any methods that may have been overlooked.  The
paragraphs below describe each control method for every  unit
operation shown.
  Starting with the weighing  operation, the consultant suggested
that  the company return the empty containers to  its supplier
(some suppliers of toxic materials have facilities for recovering or
disposing of material left in empty containers), purchase powder
A (the more toxic of the two  powders) in preweighed plastic bags
and use drum covers when transferring  the material. While few
thought that the first method was practical, and the third method
was currently being employed, the second method met with much
enthusiasm.  By  using preweighed  containers, the likelihood of
spills or dusting of powder A would be greatly reduced. In addi-
tion, unloading of the preweighed powder at the wet grind  sta-
tion  would allow rinsing out the bag so that the bag would no
longer be considered hazardous.
                                                                         !§§!
                                                         Figure 2
                                      WRAP Case Study—Illustration of Process Modifications
432   WASTE MINIMISATION PROGRAMS
-------
                                                           Table 5
                                     Summary of Source Control Methodology for the A/B Powder
                                                      Formulation Process

Waste Source
Weighing
Operation


1.
2.
3.

Control Methodology
Return empty containers
Use preweighed containers
Use drum covers
Waste
Reduction
Effectiveness
2
2
2

Extent of
Current Use
0
0
2
Future
Application
Potential
2
4
1
Current
Fraction of Reduction
Total Waste Index
0.00
0.00
0.25
Future
Reduction
Index
0.25
0.50
0.06
                         Overall
                                                    2.00
                                                                 0.67
                                                                              2.33
                          Overall
                                                    1.B9
                                                                 0.00
                                                                              2.33
                                                                                          0.10
                                                                                          0.45
                                                                                                      0.25
                                                                                                      0.00
                                                                                                                  0.50
Wet Grind Loading
and Unloading






1.
2.
3.
It.
5.
6.
7t
8.
9.
Use plastic funnel/collar on unit
Use smaller trays? manual operation
Place trays on rack, walk-in oven
Use elevator table to carry trays
Install roller conveyor under valve
Install fail-close valve on discharge
Reduce cleaning frequency
Bypass dry grinding unit
2
2
2
1
1
2
2
3
2
0 4
0 2
0 2
0 1
0 1
0 3
01
1
0 3
0 4
0.00
0.00
0.00
0.00
0.00
0.00
0 00
0.00
0.00
0.50
0.25
0.25
0.06
0.06
0.38
Ql T
. 1 J
0.56
0.50
                                                                                                                  0.56
      Dry Grind Loading 1. Use plastic funnel/collar on unit        2
         and Unloading  2. Do not load while unit is operating      3
                     3. Inspect all seals regularly             2
                     4. Use drum covers                   2
                     5. Bypass dry grinding unit             4
                                     0.00
                                     0.75
                                     0.38
                                     0.25
                                     0.00
0.50
0.00
0.06
0.19
0.90
                          Overall
                                                    2.60
                                                                 l.BO
                                                                              2.60
                                                                                          0.45
                                                                                                      0.75
                                                                                                                  0.90
       All Sources
                        All Methods
                                                                                          1.00
                                                                                                      0.58
                                                                                                                  0.71
  For the second operation, wet grind loading and unloading,
eight waste reduction methods were suggested. For the loading
operation, it was recommended that a plastic funnel or collar be
used when pouring powder into the unit. The wet grinder had a
small opening port and therefore the  likelihood of a spill was
great. For the  discharge operation, the original procedure re-
quired the operator to manually slide-out a filled tray from under-
neath the discharge  valve. Since the filled  tray would be very
heavy, movement of the trays on the floor would cause much
spillage to occur. Once the trays were full, they  were placed on a
rack, taken to the oven and placed inside. Therefore, many of the
methods focused on making the job easier for the operator. Sug-
gested methods were to use smaller trays (easier to move), place
the trays on a rack that could fit inside the walk-in oven, use an
elevator table to carry the trays, install a roller conveyor under
the valve and install  a pump on the unit and pump the slurry to
the oven area for tray filling. Of these methods,  installing a roller
conveyor and using a rack/walk-in oven were considered the most
practical  by both  the consultant  and plant operations group.
Since drips from the  valve onto the conveyor could occur, it was
suggested that a fail-close valve also be installed so that the opera-
tor would be discouraged from the practice of opening the valve
and sliding the trays underneath while the slurry continued to
flow. Finally, it was agreed that the cleaning frequency of the unit
would be reduced  as compared to existing units since this  unit
would be dedicated tothis-operation.
  Por the third operation {which also involved a loading and un-
loading operation), the use of a plastic funnel or collar and the
use of drum covers  were again suggested.  In  addition, it was
recommended  that the unit not be loaded while operating and
that the unit be inspected regularly. Finally, the client was asked
why the dry grind operation was necessary—subsequent opera-
tions provided  additional mixing  and million. The  discussions
that followed proved to be the most productive of all.
  At first, the facility process staff indicated that the design of
the process had been taken from the procedure developed in the
laboratory. Technical reasons for performing the dry grind opera-
tion were that segregation of the powders might occur during the
long slurry drying operation and  that powder dried in the oven
had a tendency to form lumps or a crust. This then led  the con-
sultants' attention back to the drying oven. Could something be
done to the oven to increase the drying rate (so that segregation
would not occur) and yet produce a material with no lumps or
crust? The use of a continuous drying, as opposed to batch dry-
ing, oven was suggested. The client had a Turbodryer (a contin-
uous rotary tray dryer) that was seldom used. Since the material is
dried rapidly and on a continuous basis, no segregation or lump-
ing should occur. Also, since the material is not dried to the same
degree as in the batch oven (the slight increase in moisture content
would not affect the subsequent processing step), the degree of
dusting should be reduced. Finally, the manual operation of load-
ing the drying trays back at the wet grind operation is eliminated,
since the slurry now will be pumped into the Turbodryer.  A
process flow diagram comparing the original and revised opera-
tions is shown in Figure 1.
  Implementation of the modified process is currently underway.
Emissions of materials to the workplace environment and the re-
sulting generation of hazardous  waste will be significantly re-
duced when compared to the original processing scheme.

CONCLUSIONS
  It is believed  that the systematic approach described in this
paper for identifying and evaluating waste minimization options
will prove valuable in conducting effective waste reduction audits.
  As shown  in the case study description,  the systematic pro-
cess has been applied and has led to the identification and imple-
mentation of measures  to reduce hazardous waste  generation.
This will  have the obvious effect of reducing the  company's
                                                                                     WASTE MINIMIZATION PROGRAMS    433
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waste  disposal costs and of deriving higher profits  realized
through better utilization  of raw materials. At the same time, in
this particular case, there is the additional benefit to the company
of reduced worker exposure to toxic emissions.
  The reader is reminded, however, that the systematic Waste
Reduction Audit Procedure by itself is no panacea.  Successful
use of this approach requires cooperation among  the audit team
and facility operations personnel; it requires a good understand-
ing of the industrial process and its underlying principles, and
finally it requires creativity and hard work.

REFERENCES
1.  Josephson,  J.,  "Hazardous  Waste Landfills," Environ.  Sci. and
   Technology, 15,  1981,250-53.
2.  Conference materials, "Waste Reduction—The Untold Story," spon-
   sored by League of Women Voters of Massachusetts, Tufts Univer-
   sity and U.S. EPA, Woods Hole, Massachusetts, June 19-21, 1985.
3.  Briner,  R.P., "Making Pollution Prevention Pay," EPA  J.,  Dec.
   1984,28-29.
APPENDIX: COMPUTATIONAL
PROCEDURES
  The text below explains how individual rankings of each option
in three separate categories  (effectiveness, extent of current use
and future applications potential) are combined to obtain qualita-
tive measures of how much  waste has already been  reduced and
how much waste can be reduced in the future for each option, for
each waste stream and for the entire process.

Current Waste Reduction Index
  The current waste reduction index  C is the fractional reduc-
tion of waste resulting from  the employment of current waste re-
duction measures.  In other words, it represents the  reduction in
waste that occurred  because of measures currently  being imple-
mented. The derivation of equations allowing computation of C
from the  ratings given to each waste reduction method is pre-
sented below.
  Consider  a process which, in the past, generated waste at  a
specific rate, Wp. Assume that, due  to implementation of certain
source control techniques, the same process now generates waste
at a specific rate, W0. Hence, the currect overall fractional reduc-
tion of waste generated is:
 C = (Wp-W0)/Wp
where:
(1)
   C  -current fractional reduction of waste  produced  by the
      process
   Wp-past specific waste generation rate (Ib waste/lb product)
   W0-current specific waste generation rate (Ib wasle/lb product)
        given source control method will be implemented to control the
        j-th waste stream. Such a variable depends on capital and operat-
        ing cost, level of difficulty, implementation period, product yield
        credit technological risk and the risk of detrimental effect on pro-
        duct quality.
           In mathematical terms, the current fractional reduction of the
        j-th waste stream by the implementation of the i-th source control
        method is given by:

        cii = eijxuij/52                                             (2)
          The normalizing factor, S, a maximum score, equals 4 if u and
        e were ranked on a scale of zero to four or equals ten if u and e
        were ranked  on a scale of zero to  ten. If the cumulative effect
        and the mutual exclusivity of all methods can be ignored, the cur-
        rent  reduction  index for the entire  j-th waste stream  can be ex-
        pressed as:
                                                                 Cj = max (cjj, i = l,2,...Mj)
                                                                  (3)
          By ignoring the mutual exclusivity of the methods, the deter-
        mination of Cj is vastly simplified. While the mathematical equa-
        tion was formulated to account for any cumulative effects, it is
        doubtful if the accuracy of the estimation would actually have im-
        proved. After all, the current reduction index is based on a theo-
        retical waste generation rate from the past, and its intent is to pro-
        vide a qualitative estimate of what already has been done to re-
        duce waste.
          Now that Cj is determined, it is useful to express it in terms of
        WQ) and Cj. Rearranging equation  (1) and writing it in terms of a
        single waste stream gives:
         w
          PJ
woj/U -C,)
                  N
                           N
        w.
£ w   = I  wo/ (l-C)
(4)
                                                                 (5)
          To obtain the current reduction index C for the whole process
        (all waste streams), equations (5) and (1) are combined to yield:
                                                                  c - 1-
    N
 w0/  z woj/(i -
(6)
          Since it is usually easier to estimate the fraction of waste, Zj,
        that a waste stream represents as part of the total waste generated
        (as opposed to estimating the actual waste generation rate), the
        following equations are used to calculate C:
  Now consider that the process has N different waste streams
and that  for  each  j-th stream (j = 1.2,.-N) there are different
source control methods available. Each method can be charac-
terized by its effectiveness, eij, its extent of current use, uij, and
its extent of further application or application potential, pij. The
first parameter, effectiveness, eij,  is defined as the measure of vol-
ume or toxicity reduction for the j-th waste stream due to full im-
plementation of the i-th (»= 1,2,..Mj) source control method. The
second parameter, extent of current use, ij, is defined as the meas-
ure of current level  of use of the particular method to control the
j-th waste stream. Finally, the future application potential, pj, is a
stochastic variable  defined as the measure of probability  that a
                                                                  w,
          oj  -
                  N
         C = 1 - I/ £ Zj/(l -C;)
                                                                  (7)
                                               (8)
           The  above equation relates the current fractional extent of
         waste reduction for the entire process to the current fraction Zj of
         each process waste stream and to the current extent of waste re-
         duction Cj for each waste stream.
434
       WASTE MINIMIZATION PROGRAMS
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Future Waste Reduction Index
  In addition to the  current reduction index, C for the  entire
process, an estimation of the potential future reduction index F is
required. Future reduction indices for each control method can be
calculated by using the equation:
            ij (s-Uij) Pij/53
(10)
  Again, ignoring the effect of mutual exclusivity or assuming
that a given facility will implement the most effective control
method for each waste stream:
           max (Fjj, i - l,2,...Mp
           N
           I
                 FJZJ
(11)
(12)
  Future reduction index F, expressed by equation (12) is a semi-
qualitative measure of expected fractional waste reduction from
the process due to implementation of the single most effective
control option for each waste stream.
  In summary, the method described above is based on an heuris-
tic approach where the estimates of waste reduction were derived
from the ratings given to the variables eij, uij and pij. In actual
applications, it usually is not possible to obtain precise fractional
values of e, u and p. Instead variables should be ranked on some
integer scale such as zero to four or zero to ten with the degree of
resolution based on the expertise of the individuals involved and
availability of information. Since the use of an integer scale can
result in Cj or Fj equal to 1.0 (100%  reduction of waste), it is
recommended that the maximum fractional values allowed be set
equal to 0.9 to avoid division by zero.
                                                                                    WASTE MINIMIZATION PROGRAMS    435
-------
                      Minnesota  Technical  Assistance Program:
                               Waste Reduction Assistance  for
                                    Small  Quantity Generators

                                               Cindy A. McComas
                                                  Donna Peterson
                                   Minnesota Technical Assistance Program
                                             University of Minnesota
                                             Minneapolis, Minnesota
ABSTRACT
  Waste minimization is a feasible approach to hazardous waste
management, reducing the volume of waste generated at the
source and reducing industry's reliance on landfilling.
  Unlike the federal hazardous waste regulations governing com-
pliance of small quantity generators between  100 and 1000 kg/
month,  Minnesota regulations allow no exemptions for small
quantity generators. This means that more small quantity genera-
tors in Minnesota (0 to 1000 kg/month) must abide by the haz-
ardous waste rules. In addition, because Minnesota has no waste
disposal facility, the costs of disposal can be high.
  In response to the high costs of disposal and the additional
number of small quantity generators, Minnesota has adopted a
stringent policy of waste minimization or waste reduction. The
Minnesota Waste Management Board has created the  Minne-
sota Technical Assistance  Program (MnTAP) to foster and im-
plement waste reduction in Minnesota.
  Many states across the  country are initiating technical assis-
tance programs to assist industry with the changing regulations.
Technical assistance programs have the benefits of  being non-
regulatory and confidential and thus are a good vehicle for en-
couraging compliance and waste reduction. Compliance with haz-
ardous waste regulations, too often viewed by industry as difficult
and expensive, can instead present methods such as product sub-
stitution, waste segregation, more efficient equipment and quality
improvement  in addition to recycling and treatment opportun-
ities.
  MnTAP offers several services to foster and implement waste
reduction in industry  including  on-site consultation, research
grants, the engineer intern program, educational seminars,  in-
formation gathering and dissemination and a  telephone hotline.
Waste reduction successes achieved through research, the engi-
neer intern program and  on-site  consultation are documented
and provided to other industries through reports and presenta-
tions. Significant cost saving can be realized by  seemingly insig-
nificant changes in a manufacturing process, including savings
in raw materials, savings in disposal costs and savings in ultimate
liability.

INTRODUCTION
  The trend toward hazardous waste reduction is largely in re-
sponse to changing public policy at the Federal and State levels.
One of the goals of the RCRA Amendments of  1984 is the min-
imization or reduction of hazardous waste generation and its dis-
posal  on land. The obvious  consequences of land disposal as
historically acceptable waste management have been poor man-
agement  of hazardous waste, groundwater contamination  and
other significant hazards to human health and the environment.
  The U.S. EPA has set forth its "waste minimization" policy
by requiring generator certification on the manifest that the gen-
erator has reduced waste generation to the maximum extent which
is economically  feasible.  The U.S. EPA's definition of waste
minimization may include both source reduction and recycling/
reuse. Those reduction methods which  are economically feas-
ible for a  particular generator are left  to  the generator's dis-
cretion, rather than being specified by the U.S. EPA. Waste re-
duction measures taken must b« documented and reported every
2 years.
  A programmatic trend toward  hazardous waste reduction al-
ready is taking place among the states. Currently, approximately
20 states have programs in some stage of development to respond
to the U.S. EPA waste minimization policy and generator needs.
Both the U.S. EPA and the states believe such programs are best
handled at the state level to better respond to generator needs
and specific state regulatory requirements. These state programs
typically take the form of technical assistance, regulatory assis-
tance or both.
  The  Minnesota Technical Assistance Program (MnTAP),  for
example, was established by the Waste  Management Board  for
several reasons, largely driven by state needs: (1) the adoption of
waste reduction as the most favored state policy for waste man-
agement by  the  Waste Management Board  and  the State of
Minnesota due to the  absence of hazardous waste treatment/
disposal facilities in Minnesota; and (2) the regulation of all small
quantity generators in Minnesota with no exemption for any vol-
ume of waste generated.
  Two main areas of emphasis exist for MnTAP: waste reduc-
tion and small quantity generator assistance. A five-step approach
is taken in educating generators on the options available for waste
reduction and implementing waste reduction measures.

THE APPROACH TO WASTE REDUCTION
  In the past, the availability of cheap landfill sites has acted as a
disincentive to capital expenditures  or changes in operation
needed to implement waste reduction and waste recovery.' Land
disposal now is recognized by most as the waste handling method
of last resort. Long-term liability costs of disposal have become a
major incentive to some generators to reduce their waste genera-
tion and not rely upon landfilling. When these long-term costs
are factored in, landfilling no longer appears attractive.
  In place of land disposal, the hierarchy shown in Fig. 1 is gain-
ing greater acceptance as the optimal management strategy  for
hazardous  wastes. The goal of a waste management system is to
utilize the  most  cost-effective combination  of management  op-
tions to handle wastestreams  within the confines of the regula-
tions.1 Utilizing one or more of the elements in the hierarchy may
436   WASTE MINIMIZATION PROGRAMS
-------
                WASTE  REDUCTION
       In-plant waste reduction/process modification

            On-site recycling/waste segregation

     *§?,  \.     Off-site recycling/reuse
            ^^
                        Treatment

                      Land Disposal
                          Figure 1
        Optimal Management Strategy for Hazardous Wastes
result in a  three-fold benefit:  (1) savings on raw materials; (2)
avoiding disposal costs; and (3) minimizing future liability.

Iii-Plant Changes
  Source reduction, or in-plant  reduction,  is  the  preferred
method and first step in working toward the overall scheme of
waste reduction.  Source reduction not only has the greatest
potential to reduce waste generation over other options, but also
reduces occupational exposure to toxic substances in the work-
place. Source reduction is also most likely to result in the greatest
savings on raw materials and avoided disposal costs.
  A step in the right direction toward source reduction is to con-
duct an in-plant survey, or waste audit. A survey involves collect-
ing information on the volume and  characteristics  of waste
streams generated  in a  plant. With this information in hand,
opportunities for  source reduction  can be  identified. Some of
these opportunities are reviewed below.

Improved Housekeeping
  Low cost measures such as good housekeeping practices, rou-
tine checks for faulty and leaking valves or pipes, balancing ma-
terial inputs and outputs to identify losses, better inventory con-
trol and shipping and minor process changes all help to minimize
pollution in a cost-effective manner. Cutting back water usage in
electroplating rinsewaters or eliminating vented solvent emissions
in a dry cleaner's plant are examples.

Product Substitution
  Product  substitution  involves  replacing a hazardous product
used in a production process with a less hazardous or a non-haz-
ardous product. Examples  of  product  substitution may include
eliminating the use of metal-containing paints or solvent-based
paints and substituting water-based paints containing no metals.
Many companies have eliminated the use of chlorinated solvents
in degreasing operations and have replaced them  with non-
chlorinated solvents or caustic washes, as appropriate.

Product Reformulation
  Product reformulation is substituting an end-product which re-
quires a less  waste-intensive manufacturing  process.3  As an ex-
ample, during the manufacture of polyester  resins, toxic styrene
monomer was released  into the  air. This process was changed
when chemical producers began manufacturing a line of styrene-
suppressed  resins that reduced styrene  loss  into the air by 70%
compared with nonsuppressed systems.
Production Process Modernization
  Replacing existing equipment with more efficient equipment
based on the same production methods can significantly reduce
waste generation. A classic example is  replacement of conven-
tional air-atomized spray equipment having a transfer efficiency
of 30 to 60% with electrostatic equipment (transfer efficiency
of 65 to 80%) or with powder coating equipment at 90 to 99%
transfer efficiency.'

Production Process Redesign
  Developing and using production processes of a fundamental-
ly different design than those currently used, such as waste stream
segregation, can greatly enhance opportunities for waste recycling
or reuse. Wastewater  from one part of the plant may be clean
enough for reuse in another part  of the plant. Segregation  of
metals streams may allow metals recovery with installation of a
metals recovery system.

On-Site Reuse/Recycling
  Reuse or recycling a waste stream refers to returning the waste
stream as a raw material to the original process that produced  it,
with or without treatment. A large selection of equipment is avail-
able for solvent distillation on-site. It makes economic sense  to
reclaim waste paint or overspray (through reformulation if neces-
sary) for its original purpose.

Off-Site Reuse/Recycling
  The low volumes of waste produced by some small companies
may not justify the purchase of needed equipment for on-site re-
cycling. In this case, wastes may be shipped for off-site recycling
at a centralized recycling facility. "Milk runs" by solvent trans-
porters have been established to help reduce transportation costs
and facilitate recycling.

Treatment
  Treatment of the waste to render it less-hazardous or  non-haz-
ardous can be done by applying physical, chemical, biological
or other methods. These methods may include concentration,
neutralization, detoxification, stabilization or incineration of the
waste.

Disposal
  Once all reduction, reuse, recycling and treatment options have
been exhausted, remaining wastes or residuals must be disposed
of in some environmentally acceptable manner.
                           Table 1
         Hazardous Waste Generation in Minnesota in 1984"
Waste  Category
                              Amount ( t u n s ;
Oi ly was les
Waste oil
Paint
Pesticides/Herbicides
PCBs
Organic chemical production
Halogenated solvents
Non -ha logena t ed solvents
Other organ! cs
Heavy metal solutions
and sludges
Corros ive
React ive
Other organic
Misc chemicals
TOTAL
466
8720
1606
30
1753
26
2260
13461
19025
15386

42063
982
4483
13202
123,463
• 1%
7
1
<1
1
<1
2
11
15
12

34
1
4
11
100%
                                                                                    WASTE MINIMIZATION PROGRAMS    437
-------
 MINNESOTA HAZARDOUS WASTE GENERATION
 AND MANAGEMENT
   Approximately 123,000 tons of hazardous waste were reported
 to be generated in Minnesota in 1984 in 14 waste categories (Table
 1).  Some waste streams were not reported  by disclosure but
 should be included in the overall description of Minnesota waste
 generation. All waste streams  including  disclosed  wastes, SQG
 wastes, spill and site cleanup waste and waste oil result in an over-
 all waste generation amount of 221,000 tons (Table 2).

                           Table 2
      Overall Estimate of Waste Generation In Minnesota in 1984'
Source
Disclosed
Addit lonal
SOG waste
Spill and
site c 1 c (i n
Add it i ona 1
waste oil
TOTAL
Amount
123

I,

up .11

51
221
(tons:
, 000

,000

. 000

.000
.000
( ' (• r ' e n t
<•><•,"„

3

in

23
100X
   Disclosure data for 1984 suggest 51% of Minnesota waste  is
 being sewered  with or without pretreatment,  13% is being re-
 cycled, 10% is being incinerated, 6% is being land disposed and
 14% is unknown or being treated/disposed in  other ways. Mani-
 fest data for 1984 indicated that 58,000 tons (including site clean-
 up) of waste (47% of total reported waste) were shipped out-of-
 state for treatment, recycling or disposal. Approximately 31,000
 tons of waste were managed through on-site recycling,  fuel blend-
 ing, stabilization, waste  oil rerefining, land treatment or other
 methods in-state.' The remainder is being sewered.
   This information suggests  Minnesota's hazardous  waste gen-
 eration and management concerns may not be as severe as in some
 other states. However, the absence  of permitted hazardous waste
 treatment facilities in Minnesota causes  concern when one con-
 siders that roughly one-half of reported Minnesota waste must be
 sent out-of-state.
   In order  to reduce  reliance on out-of-state  facilities and take
 responsibility  for its  own waste generation,  Minnesota has
 adopted a policy of  waste reduction. MnTAP was  created to
 educate generators on waste reduction opportunities and to offer
 direct technical  advice and assistance to small quantity genera-
 tors.

 SERVICES OF THE MINNESOTA TECHNICAL
 ASSISTANCE PROGRAM
   MnTAP was established by the Minnesota Waste Management
 Board (WMB) in November 1984 as one of the recommendations
 to the Minnesota legislature in the Waste Management Board's
 Hazardous  Waste Management Plan.  The WMB is a solid and
 hazardous waste planning  and  siting  agency  and  provided the
 MnTAP grant  to the University of Minnesota in order to call
 upon the available technical resources and  faculty. In response
 to generator needs in Minnesota,  several services are available
 free-of-charge through MnTAP

 Information Dissemination
   Three  types of information  are available to generators through
 MnTAP: (1) technical literature on waste  reduction; (2)  pro-
 fessional assistance contacts; and (3) equipment information. All
 of this information is stored on the computer and can be accessed
 by industry or waste stream type.
Telephone Hotline
   Approximately 40-50 calls per month are received from a broad
base of industries  (service and  manufacturing) covering a wide
range of topics. The majority of calls have been received from
painters/coalers and metal finishers.

On-Site Consultation
   Assistance by telephone may  not be adequate to meet genera-
tor needs. An on-site visit may be made to provide the generator
with more detailed information, clarify regulations and  look for
waste reduction opportunities. As of November 1985 30 site visits
had been made by MnTAP staff.

Engineer Intern Program
   A site visit may  reveal the  need  for longer-term waste reduc-
tion assistance.  In  this case, a student intern (paid by MnTAP)
can be provided to  the company  to work on a dedicated waste re-
duction project for one school term. The project  typically in-
volves conducting an in-plant survey, evaluating equipment, talk-
ing to vendors and assisting with design and selection of equip-
ment. An intern is a valuable resource for a small company which
may otherwise be unable to hire  a consultant. Seven interns were
employed by MnTAP during the  summer of 1985.

Education
   Education of generators  is conducted primarily by presenta-
tions and seminars  for trade associations or generators. MnTAP
has just completed a series of industry-specific seminars for dry
cleaners, metal  finishers  and others.  Fact  sheets prepared by
MnTAP  staff provide information on waste  management dis-
posal and reduction options for specific waste streams.
SUCCESS IN WASTE REDUCTION
  MnTAP  assistance to Minnesota generators covers a broad
base of industries from service related firms, such as dry cleaners
and service stations, to manufacturing including metal finishing
and plastics manufacturing.  Informational  needs of generators
may be as straightforward as providing a transporter list or may
involve a long project such as evaluating and installing equip-
ment for metals recovery from plating operations. Two examples
of actual waste reduction practices implemented as a result of
MnTAP assistance follow.

Metal Plater Assisted
  Company A is a precious metal plater of gold and silver. The
spent gold and silver rinsewaters are sent off-site for recovery, but
copper and  other metal rinsewaters historically have been pre-
treated on-site, prior to discharge to the sewer system. The com-
pany uses an existing system for  neutralization, precipitation of
metals and sludge dewatering as  wastewater pretreatment prior
to sewer discharge.
  In order to expand operation and meet sewer discharge require-
ments, this company needed to install a metals recovery system to
remove metals from its wastewaters prior to the current pretreat-
ment  stage.  An  in-plant survey  was  conducted to characterize
the  various  waste streams. This  information  enabled  the com-
pany to select and size the needed equipment.
  After reviewing technical literature and talking with vendors,
Company A selected a  scheme proposed by an equipment ven-
dor using  electrolytic metal  recovery operating in conjunction
with the existing pretreatment system.  It is estimated that installa-
tion  of the new system will result in a reduction  of as much as
90% of the hazardous metal components of the sludge.
438    WASTE MINIMIZATION PROGRAMS
-------
Electronics Firm Assisted
  Company B, a large electronics and computer manufacturing
firm,  generates two drums per day of dewatered metals sludge
from its copper plating operations. The total cost of disposal in-
cluding transportation and cost of the drum is approximately
$200 per drum of waste  for  an annual total disposal cost of
$100,000. This cost is in addition to chemicals for the wastewater
treatment process, operating personnel and utilities.
  MnTAP provided  the firm  with an engineer intern to aid in
the evaluation and installation of a metals recovery unit. It is esti-
mated that metals recovery will reduce sludge generation from
two drums per day to two drums per month. This waste reduc-
tion will  result in an  annual cost  savings of approximately
$100,000 in avoided disposal costs and transportation costs.

CONCLUSIONS
  Waste reduction, or waste minimization, as the new approach
toward waste management is clearly an improvement over histor-
ical end-of-pipe treatment for  pollution control. The U.S. EPA
is encouraging waste reduction through  its waste minimization
program. Many states have adopted waste reduction as a way to
effectively manage large and small quantity waste generation. A
number of state  technical assistance  programs are in place to
educate generators on waste reduction opportunities and  help
them implement process changes.
  In Minnesota,  the Minnesota Technical Assistance  Program
plans to maximize waste reduction efforts. Much of the empha-
sis on waste reduction is due to the absence of hazardous waste
treatment/disposal facilities in Minnesota. MnTAP believes this
approach is working and that assistance at the state level respond-
ing directly to generator needs is the best way to reduce the na-
tion's dependence on landfilling.
REFERENCES
1. Campbell, M.E. and Glenn, W.M., Profit from Pollution Preven-
  tion, Pollution Probe Foundation, Toronto, Ont., 1982.
2. Maugh, T.,  "Burial is the Last Resort for  Hazardous  Wastes,"
  Science, 204, 1979.
3. Caldart, C.C. and Ryan,  C.W., "Waste Generation Reduction: A
  First Step Toward Developing a Regulatory Policy to Encourage Haz-
  ardous  Substance  Management  Through  Production  Process
  Changes," Hazardous  Waste and Hazardous Materials,  2,  1985,
  309-331.
4. Minnesota Waste Management Board, "Draft Estimate of Need,"
  Sept. 26, 1985.
                                                                                   WASTE MINIMIZATION PROGRAMS    439
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              Waste  Minimization  at Air  Force GOCO  Facilities

                                              Douglas L. Hazelwood
                                              Brian J. Burgher, P.E.
                                      The Earth Technology Corporation
                                               Alexandria, Virginia
                                                   Charles Alford
                                                   U.S. Air  Force
                                    Aeronautical  Systems Division/PMDA
                                          Wright-Patterson  AFB, Ohio
ABSTRACT
  Continuing waste minimization efforts at eight aerospace man-
ufacturing facilities owned by the U.S. Air Force have identified
significant opportunities for reducing the quantities of hazardous
wastes requiring off-site treatment or land disposal. In most in-
stances, these alternatives would allow operating cost reductions
from  current practices, provide payback  of capital  investments
within 3 years  and result in  significant liability exposure  reduc-
tions.
  Hazardous waste streams  which exhibit the greatest potential
for reduction include machine coolants, hydraulic oils, solvents,
cyanide wastes, paint stripping wastes, chemical milling  wastes
and wastewater treatment sludges. The Air Force is now  imple-
menting waste  minimization measures at  its facilities to achieve
these benefits and to comply with RCRA requirements. As a  part
of this program, the Aeronautical Systems Division/PMDA  is
funding a program to demonstrate zero waste generation  at Air
Force Plant 44 in Tucson, Arizona.

INTRODUCTION
  Interest in waste minization has long been promoted by Fed-
eral legislation, including the Federal Water Pollution Control
Act Amendments of 1972, the Energy Policy and Conservation
Act of 1975, the Used Oil Recycling Act and  Department  of De-
fense  (DOD) directives such as APR 78-22  and DODD  19-14.
More recently, the impetus for waste minimization  has become
even stronger. The 1984 reauthorization of RCRA includes bans
on  landfilling and underground injection  of  certain waste types
and a requirement for certification that  waste minimization  is
being conducted by hazardous waste generators. Similarly, DOD
has issued directives requiring zero land disposal of solvents by
1986.
  The Aeronautical Systems Division/Facilities Management Di-
vision (ASD/PMDA)  of the U.S. Air Force anticipated these
developments and  initiated  programs in  1983  to address these
issues.  Studies   at  government-owned  contractor-operated
(GOCO) facilities under ASD/PMDA's  cognizance were  con-
ducted in 1983  and 1984 to identify resource conservation and
recovery activities and opportunities.
  The 1984 study demonstrated that, in many cases, plant oper-
ators  were implementing methods that could substantially  reduce
waste generation volumes and raw material requirements. How-
ever,  significant opportunities for waste minimization which ap-
peared both technically and economically feasible but were not
being pursued were also identified. In light of these  findings and
the new  certification requirements  of  RCRA, ASD/PMDA
adopted a Waste Minimization Program which includes the study
reported in this paper.
STUDY APPROACH
  The Earth Technology Corporation was given a contract by
ASD/PMDA to assist in implementing the Waste Minimization
Program through detailed studies at each  GOCO facility where
significant opportunities had been identified in the preliminary
studies.  Each of the eight selected facilities was visited by a two-
person study team  for periods ranging from 2 to 5 days to re-
view in-plant records, observe current operations and  identify
waste minimization opportunities. Based on these data, exten-
sive vendor contacts  and engineering analyses of planned and
potential waste minimization measures, detailed reports were pre-
pared for each plant describing the opportunities for  minimiza-
tion of every hazardous waste stream generated, associated costs
and benefits.
  The following sections describe the most common waste  min-
imization opportunities identified during the study. These sec-
tions, arranged by  waste type, include descriptions of the tech-
nologies available to minimize each waste  type and case studies
illustrating the benefits available from implementation.
MACHINE COOLANTS
  Machining operations (e.g., milling, turning, grinding) typical-
ly utilize a water-soluble coolant diluted to a 2 to 5% concentra-
tion with water. The coolant mixture is sprayed  directly on the
tool-part interface to provide  lubrication and  dissipate heat,
thereby preventing part damage and excessive tool wear. After
prolonged use (usually 1  to 8 weeks) the coolant  is degraded, as
evidenced  by ineffective  lubrication, rancidity and free-floating
tramp  oils. Common disposal  methods for waste coolants in-
clude underground injection and treatment through oil-water sep-
aration in  industrial waste plants. Waste coolant treatment and
disposal costs range from  $0.10/gal to $1.00/gal and  average
$0.30/gal at the eight plants studied, while coolant replacement
costs are approximately $0.35/gal (diluted).
  Advances in coolant recovery technology have  allowed indus-
trial facilities to greatly extend the life of machine coolants. Sev-
eral systems are commercially available which effectively remove
tramp oil and other impurities from waste coolants. Fresh fluids
are  added as needed to replace lost oils and biocides, and the re-
cycled coolant is returned to the machine sumps for reuse.
  Centrifugation is the most common method now used for cool-
ant  recycling. Such systems provide high efficiency separation of
swarf and tramp orls from coolant. Biocide often  is added to the
recovered coolant to curtail bacterial growth before it is returned
to the machines for reuse. Alternately, systems may be purchased
with "flash pasturization" capabilities which negate the need for
biocide addition.
440    WASTE MINIMIZATION PROGRAMS
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  The second type of coolant recovery now finding wide appli-
cation is coalescing plate filtration. These systems utilize series of
corrugated plates  to enhance gravity separation of swarf and
tramp oil from the coolant. Although centrifuges can achieve
greater efficiencies than coalescing plate filtration systems, their
cost is typically five to ten times that of a plate system.
  Three approaches to  coolant recycling  are  commonly em-
ployed: (1) connection of all machines to central sump systems
with continuous recycling of sump coolants; (2) manual collection
of coolants with batch processing in a central location; and (3)
use of mobile recycling systems to treat coolants at each machine
separately. Although all three approaches will achieve approx-
imately equivalent recovery efficiencies,  their economics vary
significantly. Mobile systems have  the lowest  implementation
cost but have the highest labor requirements. However, even the
comparatively high labor costs  of mobile systems are still gen-
erally less than conventional coolant replacement labor costs.
  The advantages  offered by coolant recycling can be seen by
examining operations at Air Force Plant (AFP) 4 in Forth Worth,
Texas. Coolant use at AFP 4,  operated by General Dynamics,
is approximately 20,600 gal/yr (undiluted) with replacement costs
of  $158,500/yr. Waste coolants are disposed off-site by con-
tracted underground injection at a cost of $0.53/gal or $121,2007
yr.
  Coolant use  and waste generation already have been reduced
significantly  at AFP 4 by using a centrifuge.  Six of the plant's
largest machines are connected to a centralized drainage system, a
high  speed centrifuge and  a  12,000-gal coolant holding  tank.
Approximately 500 gal/yr of biocide are added  to the recycled
coolant to  control bacterial growth at a cost of $25,900/yr. This
system extends coolant life  to over 6 months, or approximately
four  times that of untreated coolant. A net reduction in plant-
wide waste coolant generation  rates of approximately 25%  is
attributable to this system.
  Additional measures now under consideration at AFP 4  could
result in a reduction in  current coolant waste generation rates
of 90%. These include:
• Installation of a second high speed centrifuge to reduce down-
  time and improve recovery efficiency of the  existing system
  (cost $126,000; payback 3.1 years)
• Connection of six additional large machines to the central re-
  covery system (cost $100,000; payback 1.8 years)

• Installation of a chip wringer  on the central system to recover
  excess coolant  now  carried  out  on  aluminum  chips  (cost
  $233,500; payback 0.9 years)
• Installation of a coolant recovery system and collection vehicle
  for machines not on the central sump (cost $104,000; payback
  1.9 years)
• Purchase of a coolant analyzer to allow better control of  cool-
  ant quality  (cost $5,000; payback 0.7 years)
  The total estimated cost of these improvements,  $570,000, is
expected to result in savings of $410,000/yr with  projected pay-
back in 1.4 years.

HYDRAULIC OILS
  Hydraulic oils are used as internal lubricants  in mills, grind-
ers, lathes, stretchers and other metal- and wood-working ma-
chines. After extended use,  hydraulic oils may become  contam-
inated with water,  acids and particulates,  leading to a loss of
antioxidants and critical lubricating properties. To avoid internal
damage to  machines, hydraulic  oils  typically are  replaced every
6 to 12 months.
  Used oils generally are sold to off-site recyclers for eventual re-
use. However, the geographical location  of the generator or the
presence of toxic constituents in the oil  occasionally result in a
disposal fee being levied for its removal.  During the study,, man-
agement costs were found to range from a $0.50/gal fee for dis-
posal to revenues of $0.40/gal for recyclable oil.  The  average
waste oil revenues at the eight facilities studied is $0.15/gal.  Oil
replacement costs average $2.00/gal.
  On-site purification of hydraulic oils to prolong their useful life
is a viable option for  implementation at many facilities. Com-
mercial "off-the-shelf" systems are available which effectively re-
move contaminants and allow continued oil use. Most of these
systems employ cartridge filters  to remove  particulate  matter.
Filter sizes ranging from 2 to  10 microns generally are  sufficient
for removal of all particulate matter of concern.  Advanced  oil
purification systems are equipped with systems for removal of
water, acids formed during  use and other volatile liquids. Such
systems usually function by exposing a thin layer of heated oil  to
a vacuum, effectively stripping these contaminants from the oil.
  Analyses  of  oils recycled with such  systems have consistently
demonstrated higher purity  levels than those found in  new oils.
Through the routine purification of hydraulic oils (purification
intervals of approximately  1  to  2 months are  recommended),
useful life can often be extended to 10 years or more.
  Labor requirements for on-site purification generally are equiv-
alent  to  or  less than those  for routine oil replacement.  Mobile
purification systems can be attached directly to the machine's oil
return line and left unattended. This compares quite favorably
with the labor required to periodically drain, flush and refill  oil
reservoirs and has the  added advantage of keeping the machine
in use during servicing.
  Rockwell International's operations at AFP 3 in Tulsa, Okla-
homa, illustrate the potential  benefits of an on-site oil purifica-
tion program. Approximately  12,300 gal/yr  of waste  hydraulic
oil are drained from metal-working machines and sold to a local
oil  recycler for $0.15/gal. It has been estimated  that two ad-
vanced, portable purification systems  could reduce Rockwell's
hydraulic oil use by 90%.  Based on manufacturer's estimated
operating costs of $0.20/gal, avoided new oil purchase costs of
$2.00/gal and lost resale revenues of $0.15/gal,  net annual sav-
ings of approximately $17,800 are projected. Based on system
acquisition costs of $28,000, payback could be expected in under
2 years.  Additional unquantified savings would result from  re-
duced maintenance labor requirements.

SOLVENTS
  A wide variety of waste solvents were  encountered during the
course of the study. Table 1 lists these wastes and their cumula-
tive generation rates and disposal costs at the eight facilities stud-
ied. The bulk of the solvent  wastes result from cleaning/degreas-
ing operations. Solvent wastes typically are disposed off-site by
underground injection, landfilling, combustion in industrial furn-
aces or boilers and high temperature incineration. Solvents with
wide commercial  applicability such as  1,1,1-trichloroethane and
Freon usually are sold  to off-site  recyclers for reclamation and
reuse. The eight facilities studied generate 302,650 gal/yr of sol-
vent wastes. Management costs for these wastes total $254,740/yr
and average $0.84/gal.
  Several viable approaches exist for reducing solvent waste gen-
eration, including on-site distillative recovery and reuse as fuels.
In most situations, improved segregation  of solvents^ the point
of generation and/or  accumulation is required to achieve the
maximum possible benefits from these  methods. In  addition,
many facilities could markedly increase the quantities of solvents
resaleable to off-site recyclers through improved segregation.
                                                                                     WASTE MINIMIZATION PROGRAMS    441
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Waste Solvent Segregation
  As shown in Table 1, over 75% of the waste solvents generated
at the COCO facilities were mixed with  other solvents, water,
paints and other wastes, usually during their accumulation. These
mixed solvents generally are not suitable  for recovery or use as
fuels because of this contamination.  It is estimated that 50 to
75% of these solvents could be recycled or used as fuel supple-
ments if properly segregated. In every situation encountered dur-
ing the study, proper  segregation appeared to be achievable by
increasing the number of containers used  for accumulation  and
training workers in the importance of waste segregation.

On-Site Solvent Recycling
  Many solvents used at the COCO facilities studied are excellent
candidates for on-site distillative recovery and reuse. Although
distillation has been used widely for  many years in commercial
facilities to extend solvent life,  concern exists over the use of re-
covered solvents in military applications. Solvents purchased for
use in cleaning, degreasing and painting operations usually must
meet rigid military specifications (mil specs). Two approaches
have been suggested for resolving this  problem: (1) recovered  sol-
vents can be tested to assure that they meet mil specs and are suit-
able for reuse without restriction and (2)  recovered  solvents  can
be assumed not to meet mil specs and their use restricted to non-
critical  operations. The former  approach  is being used success-
fully at one of the facilities studied.
  AFP 59 in Binghamton, New  York, operated by General Elec-
tric  (GE), has been using a simple batch distillation system for 7
years to extend the useful life of 1,1,1-trichloroethane (TCA) de-
greaser solvents. Simple pH and specific gravity analyses are used
to determine when TCA in the degreasers must be replaced  and
to  verify that the distilled TCA  is suitable  for  reuse. This
approach has resulted in a reduction of approximately 70% in
waste TCA generation at AFP 59.
  In addition, GE now is evaluating the use  of  additives to
further extend solvent  life. Acid acceptors  and white metal stabil-
izers present  in commercial blends of  TCA will become depleted
through continued use and eventually will  render the solvent un-
suitable for reuse. Replacement additives,  available from several
solvent manufacturers and  suppliers, can be used  to replenish
lost additives, thus allowing continued reuse of the solvent.
  The second  alternative,  restricting  the  use of recovered  sol-
vents, is particularly well suited to  painting cleanup operations.
The largest single type of waste solvent at the facilities studied,
painting cleanup waste, typically contains approximately 50%
methyl ethyl  ketone (MEK) from the  cleanup of spray guns  and
other equipment.  (Some facilities recently have switched from
MEK to  nonregulated cleanup solvents  to  comply with VOC
emission requirements.) As these cleanup solvents need not meet
mil  specs, they are excellent candidates  for on-site distillative
recovery and reuse. Segregation of  concentrated paint gun resi-
dues from the washing solvents can  further  increase the  effic-
iency of recovery measures.
  The efficiency of distillative recovery operations is highly  de-
pendent on the type of equipment utilized. The continuous type
side  stills used on many vapors degreasers  do extend solvent  life
considerably, but they also produce a  solvent-rich waste stream.
Analyses have shown that many side stills  produce residues con-
taining 95% or more solvent. Several manufacturers now offer
batch systems which generate a  waste stream that is virtually  sol-
vent-free. Recovery efficiencies of  95% and recovered solvent
purity levels in excess of 99% are commonly  reported with such
systems.
  The economics  of  on-site solvent  recovery usually  are very
attractive. As an example, the system  used by GE at AFP 59 re-
                           Table 1
       Solvent Waste Generation at Air Force COCO Facilities
          WASTE
         STREAM
                       RATE
                    (GAL/YEAR)
                                               DISPOSAL  COST
 1 .


 2 .

 3.


 4 .

 5.


 6.

 7 .
Methyl  Ethyl Ketone  133,800
Paints,  Thinners
Mixed  Solvents

1,1,1-Tr ichloro-
et hane

Trichloroethylene

Freons


Naptha

Isopropyl  Alcohol

Other  Segregated
Sol vents
102,500

 40,450


 18,500

  1, 100


  2,500

     600

  3,200



302,650
$144,300


$113,400

$ 20,600
(revenue)

$ 13,000

$     500
< revenue I

$  1,320

$     320

$  3,500
                                                    $254,740
duces waste generation and solvent purchases by approximately
7,500 gal/yr, resulting in an estimated net savings of $50,400/yr.
The distillation system was purchased in 1978 at a cost of $3,500.

Waste Solvents as Fuels
  Many waste solvents contain considerable energy and are ex-
cellent candidates  for use as supplemental  fuels  in boilers and
furnaces. Six of the eight facilities surveyed currently  sell a por-
tion  of their waste streams to off-site fuel blenders.  However,
none of the facilities studied reuse waste materials on-site as fuels,
even though most do operate  industrial boilers  to meet plant
steam needs. Although nonhalogenated waste solvents such as
MEK,  Stoddard solvent and acetone could  be used to provide a
small portion of these energy needs, uncertainties regarding the
eventual regulatory requirements which will apply to hazardous
waste fuel use have deferred  such undertakings at the facilities
studied.
  In its Nov. 29, 1985 promulgation of waste oil burning regula-
tions (Federal Register, 49164), the U.S. EPA has indicated that
regulations addressing the use of hazardous wastes as fuels will be
promulgated in 1986. Current regulations, contained in 40 CFR
Part 266,  do not address  issues critical to the decision  process
for facility  operators:  equipment  permitting and waste testing
requirements. It appears that the planned  regulations will have
significant impacts on the economics of waste fuel use, particu-
larly for facilities which generate small  quantities of  hazardous
waste suitable for use as fuels.
  The average GOCO facility surveyed generates approximately
23,000 gal/yr of nonhalogenated waste solvents suitable for use as
a supplemental fuel. Assuming an average disposal cost of $0.857
gal,  an average waste heat content of 110,000 Btu/gal and  fuel
costs of $6.00/mmBtu, it is  projected that the average GOCO
facility could save $34,000/yr in fuel and disposal costs through
the use of waste solvents as fuels. However, as the costs of regu-
latory compliance and boiler system engineering modifications
could  overshadow these potential savings,  it  now appears pru-
dent to delay  implementation  decisions until the U.S. EPA's
final regulations are promulgated.
442    WASTE MINIMIZATION PROGRAMS
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CYANIDE WASTES
  Cyanide is used widely at Air Force GOCO facilities in elec-
troplating processes. Cyanide, present in cadmium,  silver, zinc
and other electroplating solutions, typically renders the spent
solutions, tank sludges and  rinsewater treatment sludges haz-
ardous. These wastes typically are treated on-site through cyanide
destruction but also may be sent off-site for treatment  or dis-
posal. In addition to conventional cyanide destruction, two al-
ternative cyanide-free plating technologies are being considered
for application at GOCO facilities; Ion Vapor Deposition (IVD)
and acid plating.

Ion Vapor Deposition
  IVD  technology is now being considered  at AFP 4 in Fort
Worth, Texas, as an alternative to cyanide-cadmium plating of
aluminum aircraft components. The  system, which relies on the
deposition of ionized aluminum in a vapor form, would virtually
eliminate waste generation from the cadmium  plating line and
would reduce plant-wide cyanide waste generation by 80%. Cad-
mium consumption would decrease  significantly, owing to the
high efficiency of IVD, and the need for continuous rinsing would
be eliminated, thus reducing wastewater generation.

Acid Cadmium Plating
  A promising alternative available for cadmium cyanide  plating
replacement appears to be acid cadmium plating. One such plat-
ing solution  is manufactured by LeaRonel, Inc. of Freeport,
New  York, under the trade  name "Kadizid" plating solution.
This proprietary batch solution consists of cadmium oxide, sul-
furic acid, brightener, starter and stabilizer compounds.  Lock-
heed-Georgia Company at AFP 6 incorporated this acid cadmium
plating system in August 1983. Lockheed has found no reduc-
tion in product quality following changeover, but has realized  a
slight reduction in operating  costs and total elimination of cya-
nide operations.

PAINT STRIPPING WASTES
  Two  of the eight GOCO facilities  studied conduct large-scale
paint stripping operations. Paint stripper, typically a methylene
chloride/phenolic compound, is  rinsed with water from the part
being stripped and collected in floor drains for bulk off-site dis-
posal or on-site treatment in  wastewater systems. Waste genera-
tion at these  two facilities  totaled approximately 500,000 gal/yr
in 1984 with off-site disposal costs  of $117,000/yr.  Three ap-
proaches  for reducing the generation of paint  stripping wastes
are being considered by the GOCO  facilities:  (1) segregation,
(2) on-site treatment and (3) alternative stripping techniques.

Segregation
  In both facilities involved in large-scale stripping, significant
quantities of other nonhazardous wastes also  could enter the
stripping waste collection systems by virtue of their designs. Im-
proved  segregation of paint stripping wastes from floor wash-
ings, noncontact rinsewater and surface runoff could  significant-
ly reduce waste  generation  at  these facilities.  For example,
segregation measures recommended at Lockheed's AFP 42 opera-
tions  in Palmdale, California, are projected to  cost $2,000 and
would result in a 70% reduction in waste generation with disposal
cost savings of $46,000/yr.

On-Site Treatment
  In conjunction with  waste generation reduction techniques or
alone, waste treatment represents a viable approach to reducing
off-site waste disposal. AFP 3 in Tulsa, Oklahoma, is now pro-
ceeding with the design of an on-site paint stripper waste treat-
ment  system as part of a long range wastewater treatment plan.
The planned system involves batch treatment of liquid stripper
wastes with hydrogen peroxide in the presence of an iron cata-
lyst to oxidize organics. Treated paint stripping waste then would
be discharged to the plant's general industrial waste treatment
system for further treatment.
  Through  this treatment scheme,  all stripper waste,  except
sludges currently generated in collection sumps, would be elim-
inated from off-site disposal. Some increase in sludge volumes
from  waste treatment would occur, but this would  be  insignifi-
cant. Although the economics of the planned system are not avail-
able, significant savings are expected to result as AFP 3 stripper
waste generation approaches an anticipated rate of 1.2 x  106
gal/yr.

Dry Media Stripping
  Several alternative paint stripping techniques currently are  be-
ing studied by DoD. One of the most promising methods is  dry
media stripping with plastic beads. Hill Air Force Base in Ogden,
Utah, has successfully demonstrated plastic media stripping  for
aircraft renovation. In the Hill AFB process, conventional sand
blasting equipment is being employed with recoverable plastic
beads for paint removal. A dry waste  of paint and plastic beads
is generated which can be separated to produce a relatively small
volume of paint waste. Waste volumes and labor requirements
have been shown to be significantly lower than conventional wet
stripping methods.  A full size dry media stripping  demonstra-
tion operation currently is being implemented at Hill AFB.
  In addition to Hill AFB, several other DoD facilities are inter-
ested  in  plastic media stripping  methods including Alameda
NARF and Pensacola NARF. At Pensacola, dry stripping cur-
rently is being tested for fiberglass helicopter components. Prob-
lems with dry media stripping appear  to be control of the strip-
ping operation  to prevent aircraft damage and dust generation
and collection. However, current  development efforts are  di-
rected at alleviating these problems through careful design and
operation of stripping systems.

WASTEWATER TREATMENT SLUDGE
  Five of the GOCO facilities studied operate on-site industrial
wastewater treatment plants. Approximately 2.9 x 106  Ib/yr of
sludge from three of these plants are disposed off-site at a cost of
$112,000/yr. The other two facilities produce 16.3 x  106 Ib/yr of
sludge for on-site disposal. Three of the GOCO facilities studied
are implementing renovations expected to  reduce sludge genera-
tion by 30 to 90%  at each facility.  Additional  reduction meas-
ures are under consideration at all facilities.
  The most significant sludge reductions planned will result from
the installation of more efficient sludge dewatering systems. Two
of the GOCO  facilities studied are planning to replace older
vacuum filtration systems, now producing sludge with approx-
imately 20% solids, with presses expected to increase solids levels
to 35% or greater. At AFP 3 in Tulsa, Oklahoma, a sludge  de-
watering system will be utilized to dewater a 2% solids slurry now
being disposed  on-site in lagoons. The planned AFP 3 renova-
tions also will include improved treatment measures which should
allow delisting of the dewatered sludge.
  Increasing chemical waste storage capacity often can allow  sig-
nificant decreases in sludge  production. During the study, sev-
eral waste  treatment plant operators  noted that a lack of ade-
quate holding capacity for waste acids and bases often required
the use of purchased chemicals to achieve neutralization. If addi-
tional storage capacity  were available, acidic and caustic wastes
could be mixed to  achieve neutralization, thus reducing chem-
ical usage and sludge production.
  Another waste minimization option  being considered is the use
of high-performance neutralizing and coagulating agents. Several
                                                                                    WASTE MINIMIZATION PROGRAMS    443
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chemical manufacturers now are offering substitutes for con-
ventional treatment compounds such as lime, caustic soda, ferric
chloride, ferric sulfate and aluminum chloride.  These high per-
formance substitutes reportedly decrease sludge bulk and improve
dewatering characteristics. In many  situations, plant throughput
can  be increased significantly  through  the  use of these com-
pounds, thus reducing or eliminating expansion needs.
FUTURE DIRECTIONS
   It is ASD's intent,  as demonstrated by this  program, to vig-
orously pursue all viable approaches for waste minimization at
the GOCO  facilities for which it has responsibility.  As appro-
priate, funding for implementing waste minimization measures
is being incorporated into current and future plant budgets.
  AFP 44 in Tucson, Arizona, is being used to demonstrate the
feasibility and benefits of waste minimization. In conjunction
with the  plant operator, Hughes Aircraft, ASD already has im-
plemented measures which have reduced waste generation by 99%
from 1983 levels. These measures include a state-of-the-art waste-
water treatment system which provides plant makeup water that is
cleaner than available city water, a coolant recycling system and
computerized plating lines.  Future plans at  AFP 44 call for in-
stallation of a  high-temperature hazardous waste incineration
system for organic wastes, replacement of cyanide plating lines
with IVD systems, and on-site solvent recycling and reuse.  It  is
ASD's goal  to demonstrate  the complete elimination of hazard-
ous waste generation at AFP 44 and eventually transfer these min-
imization technologies and management approaches to the other
facilities for  which it is responsible.
444    WASTE MINIMIZATION PROGRAMS
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                      Defense  Environmental Leadership  Project
                               Study  of  Industrial Processes to
                                     Reduce Hazardous Waste

                                        Thomas E. Higgins, Ph.D., P.E.
                                                  Drew P. Desher
                                                    CH2M HILL
                                            Industrial Services Division
                                                  Reston, Virginia
ABSTRACT
  The U.S. Department of Defense (DOD) operates industrial
facilities that  repair and recondition planes,  helicopters, ships,
tanks and other vehicles and equipment. At these facilities, paint
stripping, solvent cleaning  and metal plating are the industrial
processes that produce most of DOD's hazardous wastes.  In
policy directives issued in 1980, DOD directed the armed services
to significantly reduce the generation of hazardous wastes.
  CH2M HILL was contracted by the Defense Environmental
Leadership  Project and the U.S.  Army Corps of Engineers to
evaluate 42 cases of industrial process modifications attempted by
the three armed services to  reduce their generation of hazardous
wastes.  Process  modifications  evaluated  included  resource
recovery and recycling, source separation, raw material conserva-
tion, material substitution, improved housekeeping practices and
the development of innovative manufacturing techniques.

INTRODUCTION
  Traditionally, waste producers have not paid the true costs of
disposal. Prior to the twentieth century, these costs were borne by
water consumers and paid for in disease and premature death. At
the turn of the century, an understanding of the link between
polluted water and  disease  and the adoption of water treatment
led to a dramatic decline in the incidence of water-borne
epidemics. Still, the costs of waste disposal were borne by water
consumers,  this time in the cost of water treatment.
  Gradually, pressure was exerted to shift the burden from water
consumers to waste dischargers. Industries and communities were
required to  treat their wastes sufficiently to protect downstream
users.
  As our understanding of the long-term effects of trace quan-
tities of contaminants improved and our analytical capabilities for
detecting minute concentrations developed, increasingly stringent
treatment requirements were  placed on water and wastewater
treatment plants. The logical result has been to shift the burden of
compliance  closer  to  the  individual  producers  of  hazardous
wastes, since segregated concentrated wastes can be treated more
efficiently before they are mixed or diluted.
  Now that producers are faced with the true costs of disposing
of their hazardous wastes, it has become increasingly evident that
waste minimization is rapidly becoming an economic necessity.
Waste minimization can be accomplished by the  recovery and
recycling of waste  materials  or,  preferably, by modifying  in-
dustrial processes to reduce or eliminate the production of the of-
fending waste products.
  Since 1980 it has been DOD policy to limit the generation of
hazardous waste through alternative procurement policies and
operational procedures that are both environmentally attractive
and fiscally competitive. The DOD directed the Army, Navy and
Air Force to reduce quantities of hazardous waste, when feasible,
through resource  recovery and reclamation, recycling,  source
separation and raw material conservation.
  In carrying out the intent of these policies, many studies have
been performed that recommended industrial process modifica-
tions which, if successfully implemented, have  the potential to
significantly reduce the generation of hazardous  wastes at the
source, rather than treating these wastes at end-of-pipe facilities.
Several  modifications  have  been  successfully  implemented;
however, many other suggested changes either have not been im-
plemented or have failed to meet their goals.
  While there are specific circumstances and reasons behind the
success, or lack of success, of each modification attempted, two
factors have been an integral part of each of the successful pro-
cess modifications; one or both of these elements has  been miss-
ing from those modifications that have been less than  successful.
Very simply stated, in process modifications that were  successful-
ly implemented,  the  production   people  were  sufficiently
motivated to make the  change,  and the technologies  were
"elegant in their simplicity." Factors that motivated personnel in-
cluded an improvement in production rate and quality, a reduc-
tion in overall costs,  a decrease in manpower requirements and a
decrease in the quantity of hazardous wastes to be disposed of.
Technologies that were elegant in their simplicity were easy to
operate and maintain, reliable and cost-effective. Successfully im-
plemented process modifications combined effective technology
and motivated personnel to significantly reduce hazardous waste
production by substantially  changing the  process, substituting
raw materials, or recovering and reutilizing waste by-products.
  This paper reviews a few of the  more useful examples of in-
dustrial modifications attempted by the armed services. These ex-
amples include paint stripping modification, solvent recovery,
metal plating modification and the  elimination of solvent clean-
ing. These modifications affect the major sources of hazardous
waste generated by the DOD. The paper also summarizes the con-
clusions of the project on factors contributing to the successful
implementation of process changes. Detailed  analyses  can be
found in project reports1'2 and in a previous paper.3

PAINT STRIPPING
  Paint  stripping,  in  preparation  for  reconditioning  and
recoating, is performed at virtually every DOD industrial facility.
In a typical paint stripping operation, sprays or  baths containing
                                                                                WASTE MINIMIZATION PROGRAMS   445
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acidic methylene chloride, phenolic compounds or hot alkaline
sodium hydroxide solutions are employed to loosen and dissolve
old paint. After the paint softens, the resulting solvent-paint mix-
ture is scraped off. In addition, hard to remove paint is machine
sanded, often resulting in damage to the metal.
  The solvent-paint mixture falls to the floor, where it attacks the
concrete and makes the floor slippery. The floor  is frequently
washed with water to reduce the slipping hazard. For a typical
stripping operation on a fighter aircraft, thousands  of gallons of
solvent-laden wastewater  are generated. Wet  paint stripping  is
labor intensive, dirty and imposes a significant burden on waste
treatment facilities.
  Several alternative paint stripping processes have been studied
by private industry and the military. Among these are dry media
blasting, laser stripping, flash lamp stripping, water jet stripping,
CC>2 pellet blasting and cryogenics. The most promising of these
techniques is dry media blasting using recoverable plastic media.
  In plastic media stripping, small, angular plastic particles are
air blasted at the painted surface,  causing the coating to dislodge.
The key parameter for the successful use of plastic media blasting
is hardness.  The  paint must be  softer than the plastic media,
which, in turn, must  be softer  than  the underlying substrate.
Through careful control of the size of the particles and the condi-
tions of the process, the used plastic media can be separated from
the  loosened paint  particles and recycled. Generation  of  wet
hazardous waste (solvents and paint sludge in water) is completely
eliminated. A small  volume of dry hazardous waste is produced.
   While  there  are significant advantages to  the  plastic media
stripping  process, care must be taken in adapting it to specific ap-
plications. Stripping of  thin-skinned  aluminum,  magnesium,
fiberglas and other composite surfaces  requires skilled operators.
These operators must carefully select and control several variables
(e.g., media hardness, roughness and size; blast pressure; stand-
off distance; application angle; nozzle size; and feed rate) so that
surfaces are not damaged during  stripping.
   Following  extensive  testing  on  aircraft  components  to
demonstrate the effectiveness and safety of the process, personnel
at Hill AFB stripped a  complete  F-4 fighter plane in July 1984.
The aircraft was completely stripped with one-tenth of the man-
power  required for conventional wet  paint stripping.  This  test
demonstrated that the process is much less  labor-intensive than
solvent stripping. In addition, greater  control in  stripping was
achieved compared to that achieved with wet paint stripping and
sanding.  This degree of control  resulted in reduced damage to
underlying surfaces.
   A full-sized plastic media blasting booth has been constructed
at Hill AFB based  on  the prospects of reduced manpower re-
quirements  and  favorable environmental impact. The booth
incorporates five blast machines, a live floor vacuum system to
provide ventilation and particle and dust removal, and a separa-
tion system for media recovery and reuse. This booth was used to
blast strip an F-4 aircraft  in an elapsed time  of 5.4 hours.
  The new booth cost $650,000 to purchase and install. Yearly
savings are  anticipated  to be $5,600,000, resulting in  a  6-week
payback  period.  A significant  portion of this savings  is at-
tributable to a  reduction  in hazardous waste from the currently
estimated 10,000 Ib of wet hazardous sludge per aircraft to 320 Ib
of dry paint chips and decomposed plastic media per aircraft.
  The Naval Air Rework  Facility (NARF) in Pensacola, Florida,
has successfully stripped paint from aircraft and helicopter parts
using plastic media. Paint stripping of parts is currently being
done  in  enclosed  glove  boxes and  walk-in blast rooms.
Pensacola's long-range  plans involve converting two helicopter
hangars to accommodate  dry media stripping. These plans have
been postponed pending  resolution  of OSHA  regulations that
prohibit people from working in  rooms in which blasting is car-
ried out with  "organic"  media.  Concern was  expressed  that
generation of dust might post a possible explosion hazard.
  The Army is utilizing plastic media blasting to strip paint from
composite helicopter components at  Corpus Christi Army Depot
in Texas. Following a demonstration of the technology at Hill
AFB, Republic Airlines installed a plastic media  paint stripping
system  in  its repair  facilities in Atlanta, Georgia. Using this
system, they have successfully stripped the paint from more than
30 DC-9s.  Plastic media paint stripping is rapidly becoming the
state-of-the-art for paint stripping.
  The development of the plastic media blasting technology  at
Hill AFB in Ogden, Utah,  is a clear  example of the key elements
that contribute to the successful implementation  of a  modifica-
tion. The process is simple. Conventional sand  blasting equip-
ment was adapted to include media recovery and separation of the
media from the waste paint chips and dust. The modification was
championed  by R.  Roberts, a staff member at Hill AFB,  who
recognized  the  environmental  disadvantages of the existing
methods used  for  stripping planes. He  tried many  processes
before discovering, developing, implementing and promoting dry
plastic media stripping.
  The DOD has estimated  that millions of dollars could be saved
annually and that the generation of millions of gallons of hazar-
dous wastewaters could be  avoided by switching to plastic media
paint stripping at all facilities.

RECYCLE OF SOLVENTS
  Organic  solvents are used at  virtually every military facility.
Trichloroethylene (TCE),  1,1,1-trichloroethane and perchloro-
ethylene are used in vapor degreasers, and mineral spirits, such as
Stoddard solvent and Varsol, are used in cold cleaning baths.
Alcohols and Freon commonly  are  used for metal preparation
and  precision cleaning of electronic equipment. Solvents also are
used  in painting operations. Methylene chloride commonly  is
used to strip paint and carbon from  metal surfaces, and toluene
commonly  is used to thin solvent-based paints.  Volatile solvents,
such as methyl ethyl ketone (MEK) and xylene are used to clean
painting equipment.
  The safe disposal of waste solvents  can cost more than $100 per
drum. This cost is expected to increase substantially as a result of
RCRA  regulations  banning  the disposal  of  liquid hazardous
wastes on land. In addition, when waste solvents are disposed of,
fresh solvents must be purchased. A  recent study estimated  that
DOD purchases and disposes of  approximately 50,000 drums of
cleaning solvents per  year.' The  recycling of waste solvents can
result in a  savings of hundreds  of dollars per  drum due to the
elimination of the costs of waste disposal and initial purchase of
virgin material.
  Solvents  most frequently are  reclaimed  by  batch distillation
which typically consists of  a still pot, a heat source and a con-
denser. The waste organic mixture is loaded into the still pot, and
heat is  applied  to the contents, causing the  mixture  to  boil.
Organic  vapors separate  from  the waste mixture  and  pass
overhead to the condenser. Cleaned organic fluid then is collected
for  reuse, and the still bottoms are disposed  of as hazardous
waste.
  An atmospheric still can reclaim  organic solvents that  have
boiling points of less than 325 °F.  By adding vacuum, a distillation
unit  can be used to recover organic fluids that  have atmospheric
boiling points of up to SOOT while maintaining a 300°F limit in
the still's pot to limit degradation. A still is usually  heated directly
by electricity or indirectly by steam  generated by an electrically
heated boiler.
  Waste solvents can be collected and transported to a centralized
distillation  facility for recovery,  or they can be recycled at the
point of use. DOD facilities have  successfully used  both ap-
446    WASTE MINIMISATION PROGRAMS
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preaches. Regardless of where the distillation occurs, it is critical
that waste solvents  be properly  segregated and  stored so that
various solvents and impurities do not mix.
  The main advantage of operating a large centralized facility is
that capital costs can be recovered quickly due to economies of
scale. A centralized facility can redistill large quantities of various
types of solvents. The disadvantages of a centralized facility are
that, since many different types  of solvents  are  recycled, great
care must be taken with waste segregation and sample analysis,
and solvents must be transported to and from the point of use.
  Decentralized facilities are sometimes preferable because the
waste  generator has total control over the recycling  operation.
Since only a few types of solvents  are redistilled at small facilities,
laboratory analysis of waste solvents often is not required. Labor-
intensive  transportation  and  segregation  activities  also  are
eliminated.
  A centralized facility is dependent on a dedicated individual to
initiate and supervise the operation of the system and on an en-
thusiastic staff dedicated solely  to solvent collection, analysis,
recycling  and  distribution.  In a decentralized  facility, more
personnel (foreman  and operators) must be persuaded to adopt
solvent recovery as  part of their routine. Both centralized and
decentralized  solvent  recycle facilities have  been successfully
implemented by DOD.
  Warner Robins AFB, Macon, Georgia, has had a centrally
operated atmospheric still since August 1982.  Their organic fluid
recovery system consists of a single-stage batch still,  a water
separator and an electricallly powered steam generator. The still
can operate with a pot temperature up to 300 °F and can reclaim
organic fluids at a rate of 55 gal/hr.  The still has been used to
reclaim trichloroethane,  Freon-113 and isopropanol at recovery
rates of 70 to 99%. From the  initial  startup in August 1982 to
Dec. 31,1984, it was estimated that more than $230,000 was saved
due to a reduction in the need for virgin material and in hazar-
dous waste disposal costs. Reclamation of the used chemicals cost
only $13 per drum, whereas disposal of the chemicals and repur-
chase  of new materials would have cost from $250 to $500 per
drum.
  Robins AFB has been  able to successfully recycle solvents in a
large-scale operation  because of  careful  waste  segregation,
storage and transportation.  Site managers are responsible for
segregating and labeling waste drums at 30 different collection
areas,  Before solvents are reclaimed, samples are analyzed to con-
firm the labeling. Samples are also analyzed  after distillation to
ensure that they meet appropriate military specifications.
  Solvent recycling has been successful at Robins AFB because of
a strong commitment from management to reduce the quantities
of waste solvents that must be disposed of.  More importantly,
production personnel have cooperated with the recycling team so
that  waste  solvents can  be  segregated,  labeled,  analyzed,
transported and redistilled in an orderly and systematic fashion.
  One major factor in the success of the Robins solvent recovery
program was the commitment of  O.K. Carstarphen, the solvent
reclamation manager. Through his perseverance,  colleagues and
management were convinced to supply equipment and manpower
to set up and run the program. In  addition, Mr. Carstarphen had
extensive experience in distillation technology, and he selected
proven equipment that was reliable, simple to operate and easily
maintained.
  An  example of  a decentralized  facility  is Norfolk Naval
Shipyard in Norfolk, Virginia, which installed a $10,000 nonfrac-
tionating, batch still to recover waste  solvents generated in the
paint shop during cleaning operations. This small still, which has
a capacity of 2 gal/hr, is used to recover methyl isobutyl ketone,
MEK,  epoxy thinners and mineral spirits. Operators can operate
the  still with or without a vacuum system depending upon the
distillation temperature  required.  After a  15-minute startup
period, the still runs without operator attention. More than 80%
of the waste solvent is recovered at a cost of about $0.15/gal.
  The recovery process was successful at Norfolk because of the
personal dedication of J. Coulter, the paint shop foreman, and
the straightforward, uncomplicated operation  of a technically
innovative system.

METAL PLATING
  Plating is defined as the  deposition of a layer of metal on the
surface of a base metal for the purpose of changing the properties
of the base metal. Plating may be used to improve the appearance
of the metal (decorative plating), to increase its resistance to cor-
rosion or to  improve  its engineering  properties  (hardness,
durability, solderability or  frictional characteristics).  The prin-
cipal metals used for plating at military facilities are cadmium and
chromium.
  The major discharges of hazardous waste from typical metal
plating facilities are rinsewater contaminated by drag-out from
various cleaning and plating baths, cleanup of spills, disposal or
acid and alkaline cleaners and  occasional plating bath dumps.
  Sacrificial cadmium coatings normally are applied to protect
the base metal, which is typically iron or steel.  A thin surface
coating normally is applied  for decorative purposes or to provide
corrosion protection, improve wear  or  erosion  resistance, or
reduce friction. Many parts can  be efficiently plated in a few
tanks, but a significant amount of waste rinsewater is produced
due to the drag-out of plating  solutions on the parts.
  Cadmium almost universally has been plated  from  alkaline
cyanide baths, due to the improved plate resulting from the stable
cadmium cyanide complexes.  Unfortunately, cadmium  cyanide
baths are costly, dangerous to  operate and expensive to treat.
  Lockheed's  plating shop located in Air Force Plant No. 6,
Marietta, Georgia, switched from an alkaline cyanide cadmium
bath to a proprietary acidic noncyanide cadmium bath. Lockheed
found that the product quality improved as a result.  However,
more  careful process control  was required. Although the  new
plating  solution,  which  costs  approximately $3/gal, is more
expensive than the old cyanide formulation, reduced waste treat-
ment  costs have resulted in a net  cost savings for this modifica-
tion. As a result of this modification, alkaline chlorination for the
treatment of cyanide no longer is  needed.
  The new process was  implemented primarily  to reduce the
hazards associated with the operation and disposal  of  cyanide
baths. An improvement in quality and a reduction in total costs
led to the permanent adoption of the modification. In addition,
the process required a minimal amount  of change from the old
method,  and existing personnel had no trouble adapting to it.
  Getting rid of both cadmium and cyanide was the goal  of  a
modification  attempted at  North Island NARF in San Diego,
California. Wet cadmium plating was replaced by a method of
coating parts with aluminum using ion vapor deposition (IVD) for
corrosion resistance.  This  substitution  eliminated  the  en-
vironmental problems associated with cadmium and cyanide. For
the past 7 years, metal parts such  as landing gears, bolts and tail
hooks have been plated with the dry IVD process.
  Advantages of the process include safer working conditions, an
end product that can withstand higher operating temperatures,
improved throwing  power and better adhesion of the aluminum
coating compared to that achieved with  cadmium. Despite these
advantages, this process has not realized  its potential.
  The process is  considerably  more complex and requires more
labor and skill than cadmium plating. For this reason, the process
has been used for only a few parts, and new parts are evaluated on
an individual basis to determine the preferable plating technique.
The process change has not significantly reduced  the amount of
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cadmium plating performed at the facility. In addition, there was
no champion who assumed responsibility for implementing the
modification and ensuring its success.
  Chromium is used principally in the remanufacturing of worn
parts whose replacement with new parts would not be feasible or
economic because of their unique design. Remanufacturing con-
sists of machining the worn part or stripping a portion of the old
plate, overplating it  with a thick  layer  of chromium  (hard
chromium plating) and machining it back  to  original specifica-
tions. To achieve the required  thickness  of chromium, parts
typically are plated for more than 24  hours as opposed to minutes
required for cadmium plating. In contrast to  cadmium  plating,
many tanks are needed for a few parts, and drag-out losses are
slight. Lack of drag-out creates a buildup of contaminants in the
plating bath, and the resulting bath  dumps are the major source
of waste from hard chromium plating.
  Pensacola NARF and Charleston  NSY tested a vapor recom-
pression evaporator system for the recovery of chromium from
hard chromium plating rinsewater.  The system  consisted  of a
cation exchange unit used for the removal  of contaminating ca-
tions and a vapor recompression evaporator used to concentrate
the cleaned rinsewater to plating bath strength.
  There were several reasons  for the lack of success of this
modification.  The initial  feasibility evaluation was based on the
amount of drag-out experienced from decorative chromium baths
rather than the significantly lower quantity of chromium available
from  hard chromium plating.  The equipment was complicated
and required excessive operation and maintenance attention. The
system was plagued by the failure of seals and by severe corrosion
of the carbon  steel compressor.
  Despite the  fact that the testing programs were championed by
Ms. D. Preble (Pensacola) and  B.  Mordecai (Charleston), the
complexity of the chosen equipment and the faulty assumptions
used for the initial feasibility evaluation doomed this project to
failure.
  As a result of the lessons learned from the failure of the vapor
recompression evaporator system, the  Naval  Civil Engineering
Laboratory (NCEL),  Port Hueneme,  California,  chose  other
methods to modify the hard chromium plating  process at  Pen-
sacola  NARF to  reduce rinsewater  flows  and  recover  the
chromium. They retrofitted an existing countercurrent rinse tank
with a recirculating spray rinse  system. This new rinse system
reduces rinsewater  usage sufficiently enough to  allow all the
rinsewater  to  be used for plating bath makeup.  A pump recir-
culates  rinsewater  through eight high-velocity  spray  nozzles
located  around  the perimeter  of the  rinse tank.  The pump is
activated by a  foot pedal as parts are  lowered into the empty tank.
Clean  rinsewater is available  via a hand-held sprayer.  After
repeated use,  a portion  of the rinsewater is pumped through a
cloth filter into the plating tank and  added  to the plating bath to
replace  water  lost through evaporation. Plating baths  are
operated at elevated temperatures to increase the rates  of both
evaporation and plating.
  These modifications  reduced   the use of  fresh water  from
350,000  gal/mon  for countercurrent  rinsing to about  1,200
gal/mon for spray rinsing. Since this amount was less than the
evaporation rate, all of the spray rinse was returned to the plating
bath, resulting in a zero  discharge condition.  A total savings of
approximately $25,000 per year per bath was projected, principal-
ly due to reduced industrial wastewater treatment costs.
  Without drag-out to aid in removal of contaminants from the
bath, a  cleanup  process  was required to reduce the need  for
plating bath dumps. An electrolytic  bath purification system was
installed to continuously remove cations  from the chromium
plating solution. The system uses cathodes contained within mem-
brane modules to selectively precipitate cation impurities from the
plating solution and anodes to oxidize trivalent chromium to hex-
avalent  chromium.  Hexavalent chromium  ions  remain on the
anode side of the membrane and are returned to the plating bath.
  The purification system did not effectively remove contamina-
tion from the chromium plating bath during a trial run. The
system experienced a failure of the membrane modules caused by
a supplier's change  of material.  Replacement of the  membrane
modules is expected to rectify the problem, but further testing is
required before this technology  can  be recommended  at  other
DOD facilities.
  NCEL implemented these process modifications at Pensacola
as a prototype system. Although NCEL has proven that the spray
rinse system is effective in removing drag-out, plating personnel
remain skeptical about the effectiveness of the  system. Despite
resistance  from platers, there are plans to construct a  permanent
spray rinse and bath purification system because of the prospects
of reduced wastewater flows and treatment costs.
  At other military  installations where the spray system was im-
plemented, the rinsewater modifications were  received  more
favorably  because an extensive training program was provided
prior to startup. In  addition, engineering and management per-
sonnel have been  very supportive of  the process modifications.
That these plating modifications have succeeded is due in large
part to the dedication of C. Carpenter of NCEL, who originated
the  new system,  diligently supervised  its implementation and
remained available for ongoing consultation.

ELIMINATION OF SOLVENT CLEANING
  Prior  to servicing, tactical vehicles  and  equipment  used  at
Army bases typically are washed and  cleaned  at a common
washrack located at  individual motor pools. Each base as 2 to 45
washing locations with a total of 30  to 80 washracks.  Exterior
washing involves removing road dirt and sediment from tracked
and wheeled vehicles. Detergents and solvents sometimes are used
to assist in exterior cleaning.
  Scheduled maintenance of tracked vehicles usually is preceded
by removing the engine from the vehicle and cleaning both the
engine and its compartment. Cleaning prior to servicing often
removes large quantities  of petroleum, dirt  and vegetation.
Solvents regularly are used to assist in the cleaning operation.
  Vehicle washing produces a large volume of wastewater, which
is principally contaminated with soils and minimal concentrations
of oils and organic material. Maintenance produces low  flows of
wastewater that are contaminated heavily  with  oils,  greases,
solvents and  other  organic contaminants. Conventional Army
practice has been  to perform both washing and maintenance on
open wash stands, with the resulting large flow of contaminated
wastewater discharging to  the base  stormwater system.  Many
facilities were having difficulty meeting wastewater discharge per-
mit requirements. In addition to a lack of wastewater  treatment,
other deficiencies of the combined washing facilities include in-
adequate water pressure, ineffective  solvent and oil collection
facilities and undependable steam cleaners.
  Planning for process modifications to reduce water and solvent
use began in 1974  at the Corps of Engineers Construction
Engineering Research Laboratory (CERL), Champaign, Illinois.
J. Matherly of CERL developed the concept of segregating exter-
nal vehicle cleaning  from maintenance servicing so  that the
resulting two  waste streams can be treated separately.  It was Mr.
Matherly's influence that promoted the planning and installation
of the segregated cleaning and maintenance facilities at Fort Polk
and Fort Lewis.
  Fort Polk,  Louisiana, has two central vehicle wash facilities,
each consisting of a large washing basin or "bird bath." Two
staggered rows of 24-in. steel pipes were installed at the bottom of
each lane. This configuration causes a teetering action when a
448
       WASTE MINIMIZATION PROGRAMS
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tank or other tracked vehicle drives through. The tracks extend
through their entire range of motion as they move over the cor-
rugations on the bottom of  the bird bath.  This movement
dislodges caked-on soil. Water monitors (spray cannons) provide
secondary cleaning. Facilities are provided with hoses to clean the
insides of vehicles after they exit the bird bath. Waste washwater
is treated in a sedimentation lagoon and reused.
  J. Kelley of Fort Polk developed this simple concept for clean-
ing heavily soiled vehicles and implemented its use at his facility.
Aiding in the adoption of the process was a significant reduction
in manpower.  At the old washracks,  it took  an estimated 7
manhours to wash a tracked vehicle. At the central wash facilities,
only 0.5  manhours were needed to wash a tracked vehicle.
  At Fort Lewis in Washington, D. Hanke, Chief of the Sanita-
tion Branch, implemented the program to segregate cleaning and
maintenance facilities in response to notices of violations caused
by the discharge of polluted stormwater from the facility.
  In contrast to  Fort  Polk,  which uses predominantly tracked
vehicles and has heavy soils,  Fort Lewis has light soils and uses
mainly wheeled vehicles. For these local conditions, central ve-
hicle wash facilities were developed that consisted of individual
wash stations with high-pressure, high-volume (30 gal/min of 90
lb/in.2 water) hoses. These facilities met local needs better than
the bird bath installation used at Fort Polk.
  Waste washwater is reused after treatment  in a simple gravity
(API) oil/water separator and intermittent sand filters. At one of
the vehicle wash facilities, water is not recycled but is discharged
to the sanitary sewer instead.
  With the lower water pressure in  the old  system, cleaning a
vehicle required approximately 2 hrs. With the new high-pressure
system, a tracked vehicle can be washed in approximately 20 to 30
min, and a wheeled vehicle can be washed in 15 to 20 min.
  At Fort  Lewis, facilities were designed to  provide a covered
location  for scheduled maintenance  to exclude  rainwater and
thereby limit the amount of solvent- and oil-laden wastewater.
High-pressure,  hot water cleaners successfully remove oil and
grease  from engine compartments,  eliminating the  need for
solvents  and detergents  which promote oil  emulsification and
complicate  treatment. The resulting low volume  of  oil-laden
wastewater  then  is  treated in gravity oil/water separators and
discharged to the sanitary sewer system.
  The combination of reduced solvent use, separation of exterior
cleaning  from  vehicle  maintenance, installation of  oil/water
separators and recirculation of washwater has led to a 90 to 95%
reduction in the amount of  contaminants  being discharged
through the storm sewers to surface water at Fort Lewis.

CONCLUSIONS
  As demonstrated in the discussions of plastic media paint strip-
ping at  Hill AFB,  hard chromium  plating  at  the Pensacola
NARF, solvent recovery at Robins AFB and at Norfolk Naval
Shipyard and solvent  cleaning  elimination at Forts Polk and
Lewis, a number of features were common to the industrial pro-
cess modifications that were successfully implemented.
  Production people were enthusiastically and actively involved.
Attaining positive involvement usually required that the modifica-
tion result in some production benefit, such as reduced manpower
requirements or simplification of the process; the change did not
have  an adverse effect  on  product quality;  and  the change
preferably had a beneficial effect on the end product. Care was
taken to tailor the modification to the individual facility. During
design and  installation,  operations and  production personnel
were asked to provide input in order to inspire  them to adopt the
process change.
  A "champion" guided the project, overcoming developmental
problems and the inertia that protects existing processes, especial-
ly those that function, even though they may product undesirable
wastes.
  Support was provided at a sufficiently high level in the chain of
command to influence  production and  environmental policy
decisions.
  The technologies tended to require  evolutionary rather  than
revolutionary changes. That  is,  off-the-shelf equipment  was
adapted to a new application, and special or complex equipment
was avoided. Successful modifications were straightforward  and
simple to  operate, requiring minimal training  for personnel un-
familiar with the technology involved. Process  reliability  was
high, and  maintenance requirements were minimal.

ACKNOWLEDGEMENTS
  This  paper  was  supported by the Defense Environmental
Leadership Project and the U.S. Army Corps of Engineers under
contract number DAC  A87-84-C-0076.  The  views expressed
herein are the private views of the authors and  are not to be con-
strued as official or as reflecting the views of the Department of
Defense.
REFERENCES
1. Higgins, T.E., "Industrial Processes to Reduce Generation of Haz-
   ardous  Waste at DOD Facilities, Phase 1  Report,"  prepared by
   CH2M  HILL for the  Defense Environmental Leadership Project,
   Washington, D.C. DTIC No. AD-A159-239, July 1985.
2. Higgins, T.E., "Industrial Processes to Reduce Generation of Haz-
   ardous  Waste at DOD Facilities, Phase 2  Report,"  prepared by
   CH2m HILL for the  Defense Environmental Leadership Project,
   Washington, D.C. DTIC No. AD-A159-239,  July 1985.
3. Higgins, T.E., Fergus, R.B. and  Desher, D.P., "Evaluation of In-
   dustrial Process Modification  To Reduce Hazardous Wastes in the
   Armed  Services," paper presented at  the Purdue Industrial Waste
   Conference, Lafayette, IN, May 1985.
4. Bee, R.W., et al., "Evaluation of Disposal Concepts for Used Solvent
   at  DOD Bases," The Aerospace Corporation Report No. TOR-
   0083(3786)-01, Feb. 1983.
                                                                                    WASTE MINIMIZATION PROGRAMS    449
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                                                1986  EXHIBITORS'   LIST
 Allied Healthcare Products, Inc.                  227
 1720 Sublette Ave.
 St. Louis, MO 63110                   314/771-2400
 Allied Healthcare Products is a manufacturer of patient
 care products and medical gas delivery system products.
 We are now offering a hazardous waste compactor, the
 Red Bag Station, to improve efficiency in handling costs
 of hazardous/infectious medical waste, as well as reduc-
 ing  the potential of nosocomial infection.

 Analytical Instrument Development, Inc.           134
 Rt.  41 & Newark Rd., Box 689
 Avondale, PA 19311                   215/268-3181
 Manufacturer of portable instrumentation for the deter-
 mination of trace organic materials in the environment.
 Portable Gas Chromatograph with the Electron Capture
 Detector for the analysis of PCBs in  soil and  water.
 Model 590 OVM/GC for total organic vapors (OVM) or
 specific materials (GC) in air will also be shown. Other
 AID instrumentation for on-site organic measurements
 at  hazardous  waste sites  and  leaking underground
 storage tanks (LUST) will also be on display.
 BCM Engineers, Inc.
 P.O. Box  1784
 Mobile, AL 36633
                                               116
                                      205/433-3981
 BCM provides environmental guidance to plan for and/
 or demonstrate compliance with environmental laws and
 regulations.  BCM also provides  environmentally and
 economically sensible solutions to groundwatcr or soil
 contamination problems.  BCM provides management,
 engineering,  hydrogeological, air  quality, remedial ac-
 tion and EPA- and State-certified laboratory services for
 hazardous waste projects.
 BONDICO, Inc.
 2410 Silver St.
 Jacksonville, FL 32206
                                               325
                                      904/358-2602
 BONDICO,  Inc. has introduced a 90-gallon container
 system designed for transportation, storage, treatment
 and disposal of hazardous and toxic materials. A dual
 laminate composite of polyethylene and fiberglas, the
 container provides superior safety and extraordinary
 cost-effectiveness with multiple reuse. Manufactured in
 Jacksonville, FL, the unit may be  utilized as a salvage
 container, on-site storage  container, or encapsulate via
 its innovative on-site sealing system  (patent pending).
 BONDICO's container is  rustproof,  leakproof, corro-
 sion resistant, light-weight, nestable and reusable.

 Berghof/America, Inc.                          244
 27 Main St.
 Raymond, NH 03077                   603/895-4757
 Exhibiting the widest range of TEFLON products now
 available for research and induslry including:  Teflon-
 lined High Pressure Autoclaves and  Digesters, Teflon
 Acid Purifying Apparatus, Teflon Labwarc,  Fluid Flow
 Systems with Valves,  Fittings,  an all Teflon Pump and
 much more. Custom Fabrication a  Specialty.
Black SVealch                                 126
1500 Meadow Lake Pkwy.
Kansas City, MO 64114                 913/339-2000
Complete Hazardous  Wasle Management Services in-
clude:  RCRA Part B permit applications;  Irealmcnt,
 storage and disposal facility design; regulatory analysis;
 facility inspections;  underground storage  tank  design
 and evaluation; and  facility remediation services. These
 services  have  been  provided  for municipal,  state and
 Federal government  and private industries.

 Bryson Industrial Services, Inc.                   302
 411  Burton Rd.
 Lexington, SC 29072                   803/359-7027
 Bryson Industrial Services, Inc  is a hazardous waste
 management company.  We provide  consultation  and
 management services 10 customers on methods of reduc-
 ing, handling and disposing of Ihcir hazardous waste. In
 addition we provide secure permitted transportation and
 fully trained and experienced project  I cams for on-site
 service needs.

 Bulk Lift International, Inc.                      330
 455  Maple Ave.
 Carpentersville. IL 60110               312/428-6059
 The Bulk Life bag  is an innovative approach to cost-
 efficient material handling. Our bag  is a woven poly-
 propylene  bag  designed  for  shipping  dry  fiowable
 cargos. It is an efficient alternative to multi-wall bags,
 corrugated, rigids and bulk. The Bulk  Lift bag is de-
 signed with patented features  for product protection,
 double drawstring  closures  reduce product  pollution
 risk, and safety bands  with reinforcement. Our bags
 range from 1000 to 8000 pounds capacity for con-
 taminated soil and other hazardous wastes.

 CH2M HILL, Inc.                               103
 229 Peachtree St.. N.E., Suite 300
 Atlanta. GA 30303                      404/523-0300
 CH2M HILL is a consulting engineering firm with over
 40 offices throughout the world. With extensive experi-
 ence in hazardous waste  site investigation and cleanup,
 CH2M HILL provides services to both public and pri-
 vate sector clients. CH2M HILL is the primary contrac-
 tor lo EPA for Superfund in the western United States.

 California Analytical Laboratories, Inc.           204
 2240 Dabney Rd.
 Richmond, VA 23230                  804359-1900
 California Analytical Laboratories, Inc.  and Cal Lab
 East, Inc. provide quality environmental analyses from
 laboratories in West Sacramento and Richmond, Vir-
 ginia. Governmental, industrial and private clients pro-
 fil from Cal Lab's participation in EPA's Contract Lab
 Program. The Cal Lab family is dedicated (o providing
 prompt, high quality  pharmaceutical and environmental
 services,

Camp Dresser & McKcc Inc.                   127-129
 1945  The Exchange,  NW, Suite 290
Atlanta, GA 30339                     404/952-8643
Camp Dresser  & McKec Inc.  provides comprehensive
engineering and consulting services for hazardous waste
managcmcnl, including remedial investigations, feasibil-
ity studies, remedial design, groundwatcr modeling and
remediation, and RCRA  permitting.

Carbon Air Services, Inc.                         420
P.O. Drawer 5117
Hopkins, MN 55343                    612/935-1844
CarbonAir Services is a  groundwatcr decontamination
contractor providing treatment design and turnkey in-
stallation for removal of  organic and inorganic con-
taminants in surface, groundwater and process streams.
Treatment alternatives include airslrippmg. carbon ad-
sorption, metals precipitation and/or oil-water separa-
tion. Emphasis is on short-term leasing and  total  ef-
fluent responsibility.  Equipment can be purchased.

Chem-Mel Services                              321
18550 Allen Rd.
Wyandotte, MI 48192                  313/282-9250
Chem-Met Services provides environmentally safe treat-
ment for liquid  and  solid  wastes. Our process is eco-
logically  sound and  economically efficient.  We  have
been processing waste streams for industry since 1966.
Client-oriented,  we know that  dependable service  is
essential. Our waste disposal  treatment is proven sound
for our environment. We slay current wilh changing
government regulations. Analysis of all hazardous waste
is required and  maintained.
Dixie Poly-Dram Corp.
P.O. Box 597
Yemassee. SC 29945
                                           214-216
                                                                                                                                                   803/589-6660
Dixie Poly-Drum Corp. offers a complete line of DOT-
approved closed head and open top polyethylene ship-
ping drums. The "Super  Shipper"  line of closed head
polydrums is available in a 15. 20, 30. 35 and 55 gallon
size  The Plasti-Drum line of  open top polydrums is
available in a 14, 16, 30, 45 and 55  gallon size.
Duke Univenil) Press
6697 College Station
Durham, NC 27708
                                               227
                                      9I9'684-2173
Duke University Press was founded in 1921 as the first
scholarly publishing house in the South and became a
charter member of the American Association of Univer-
sity Presses in 1937. Duke currently publishes more than
40 books and  11 journals  annually and has some 300
titles in print.

E.NSCO                                        401
1015 Louisiana
Little Rock, AR 72202                  SOI/37S-8444
Environmental Services  •  Hazardous & Toxic Waste
Incineration •  On-Sile Hazardous Waste Incineration •
Environmental Laboratory Services • Geotechnical &
Hydrological Assessment • PCB Transformer Decom-
missioning and Rctrofill
 ERT                                          203
 696  Virginia Rd.
 Concord. MA 01742                     617/369-8910
 Full-service environmental  and engineering consulting
 firm with offices nationwide. Inactive site management,
 UST consulting,  closure and  plant decommissioning,
 land transfer, RCRA/CERCLA compliance, air toxics
 consulting and other waste-management related serv-
 ices.

 Earth Technology Corporation, The              438
 3777 Long Beach Blvd.
 Long Beach, CA 90807                  213/595-6611
 The Earth Technology Corporation provides environ-
 mental, geotechnical, gcosciemific and engineering con-
450     EXHIBITORS' LIST
-------
suiting services to industrial and governmental clients.
Our services include: remedial investigations; remedial/
corrective action; design and engineering; geotechnical
investigations; waste  stream reduction  and recovery;
facility closure; environmental  auditing/compliance as-
sessment;  hazardous waste permitting; laboratory and
special technical services.

Ecology and Environment, Inc.            121-123-125
P.O. Box D
Buffalo, NY 14225                     716/688-7876
E & E offers the complete range of services required for
generators, transporters and disposers  of hazardous
materials. Our staff of 500 scientists and engineers pro-
vides   hydrogeological  studies;  site  investigations;
remedial plans and specifications;  engineering designs
and project management;  hazards and risks analyses;
RCRA and LUST compliance programs; spill emergency
response; and extensive analytical laboratory services.

Engineering-Science                             310
57 Executive Park South, Suite 590
Atlanta, GA 30329                     404/325-0770
Engineering-Science (ES) is a major national and inter-
national  engineering  firm  with a  major specialty in
hazardous waste engineering and management. ES pro-
vides the complete range of services including health and
safety,  site  investigations,  remedial  investigation/
feasibility studies, hydrogeological, geotechnical  and
geophysics,  site cleanup,  analytical  services  and  air
pollution monitoring.
 Enviresponse, Inc.                           115-117
 110 South Orange Ave.
 Livingston, NJ 07039                   201/533-7289
 Enviresponse, Inc. offers a wide range of technologies
 and expertise relevant to the complex problems sur-
 rounding the treatment of hazardous  and toxic waste.
 Services range from consulting to design and construc-
 tion.  Enviresponse, Inc.  is a subsidiary of the Foster
 Wheeler Corporation.
 Environmental Protection Systems                206
 7215 Pine Forest Rd.
 Pensacola, FL 32506                    904/944-0301
 As a professional engineering and analytical firm, EPS
 provides the entire spectrum of services which are need-
 ed to support the hazardous materials  and hazardous
 waste  industry.  Our  master program  of  permitting
 negotiation and regulatory liaison is designed to support
 our clients needs with turnkey in-house services and con-
 tractors management. We can also provide sample pick-
 up and delivery service from sample sites with rapid
 turn-around of analytical results.  From operating per-
 mits to material characterization  to  feasibility studies
 and remediation, EPS is ready to  become part of your
 team.

 Environmental Quality Labs, Inc.                 422
 6107 E. Ten Mile Rd.
 Warren, MI 48091                      313/757-7970
 Independent  testing  lab—consultants  specializing in
 hazardous waste  sampling  and  analysis, water  and
 wastewater monitoring, along with coal and petroleum
 testing.
Environmental Science & Engineering, Inc.         406
P.O. Box ESE
Gainesville, FL 32602                   904/332-3318
ESE,  a  full-service multidisciplinary environmental
engineering firm, has performed work at more than 120
hazardous waste sites, including 15 CERCLA NCP sites.
Capabilities include:  remedial investigations,  feasibility
studies, QA/QC plans, safety and health planning and
monitoring,  community relations,  analytical services,
and expert witness testimony.
Fred C. Hart & Associates
530 Fifth Ave.
New York, NY 10036
                                                224
212/840-3990
Fred C.  Hart Associates is an environmental manage-
ment consulting firm providing technical, economic and
management service to industry. Specific services in-
clude the following: Remedial Investigations and Feasi-
bility Studies • Construction  Management Services  •
Remedial Engineering  and  Design  Services •  En-
vironmental  Audits  and   Risk  Assessments   •
Underground Storage Tank Management and Safety.

GA Technologies, Inc.                           139
P.O. Box 85608
San Diego, CA 92138                   619/455-3045
Circulating  Bed Combustor systems. Circulating bed
technology has demonstrated  safe, economical,  com-
plete elimination of hazardous wastes.  EPA require-
ments are met without the use of afterburners and scrub-
bers. In  addition to permanently  installed units, GA
Technologies has developed transportable CBC units for
on-site treatment of corporate/Superfund sites.
GSX Chemical Services, Inc.
60 State St.
Boston, MA 02109
     333-335
     432-434
617/367-8300
Complete chemical  and hazardous waste disposal and
complete solid waste collection and disposal services.

Geo-Con, Inc.                                  210
P.O. Box 17280
Pittsburgh, PA 15235                   412/244-8200
Geo-Con  is a full-service hazardous waste contractor
with capabilities of  total site cleanup including special-
ized types of remedial activities  such as:  soil/sludge
stabilization, geomembrane systems, earthwork,  drum
and tank sampling, assistance  in transportation and
disposal of hazardous wastes and total health and safety
capabilities.

Geonics Limited                                205
1745 Meyerside Dr., #8
Mississauga, Ontario, Canada
L5T1C5                               416/676-9580
Geonics Limited, a manufacturer of electromagnetic
geophysical equipment  used worldwide by  government
and industry for mapping groundwater contaminant
plumes, is proud to  introduce two innovative products.
The first, a data logger and contour plotting system, will
greatly enhance survey data presentation. The second, a
high resolution borehole induction conductivity logger,
will accurately delineate contaminant plume stratifica-
tion through PVC cased,  monitoring wells.

Greenhorne & O'Mara, Inc.                      235
9001 Edmonston Rd.
Greenbelt, MD 20770                   301/982-2800
One of the nation's largest consulting engineering firms,
Greenhorne & O'Mara  combines a wide variety of serv-
ices in the hazardous waste area with special emphasis
on remote sensing and the natural sciences. Founded in
1950, the  firm has 13 offices nationwide.

Groundwater Decontamination Systems, Inc.      326
Suite 210, 140 Rt. 17 North
Paramus,  NJ 07652                     201/265-6727
Introducing Groundwater  Decontamination Systems
(CDS), the unique new system for soil and groundwater
decontamination. The  GDS process eliminates hydro-
carbon  and  halogenated hydrocarbon contaminants
from the groundwater and from the soil through a pro-
cess of accelerated biodegradation by micro-organisms
existing in the contaminated soil. Patent awarded.

Gundle Lining Systems  Inc.                      209
1340 E. Richey Rd.
Houston, TX 77073                     713/443-8564
Gundle Lining Systems Inc. is recognized as the World
Leader in lining systems, manufacturing and installing
High  Density  Polyethylene from  20 to  100 mil thick.
Also, Driline,  Hyperlastic and Gundnet Draining Net-
ting for leachate systems. For the past 22 years, Gundle
has installed over 3 million square feet of lining systems
throughout  the world.  For more  information,  call
800/435-2008 or 713/443-8564.

HAZCO, Inc.                                500-502
1347 E. Fourth St.
Dayton, OH 45402                     513/222-1277
Turn key supplier of health and safety equipment for all
phases of remedial and emergency response. Specializing
in complete rental and  training packages.
                  HAZTECH
                  5280 Panola Industrial Blvd.
                  Decatur, GA 30035-4013
                                                                 220
                                      404/981-9332
HAZTECH, a hazardous waste contractor, provides the
following  services: contaminated soil  removal;  on-site
water treatment; drum, soil and tank excavation; lagoon
closures and  cleanings;  sludge  solidification;  24-hour
emergency spill response;  surface and  groundwater
treatment; sampling; site  assessment,  including  the
handling  of  shock-sensitive   materials  (Lab  pack
removal).

Hazardous Materials Control              223-225-227
Research Institute
9300 Columbia Blvd.
Silver Spring, MD 20910                 301/587-9390
HMCRI  is a unique public,  nonprofit,  membership
organization  which  promotes  the  establishment and
maintenance of a reasonable balance between expanding
industrial  productivity and an acceptable  environment.
Our goals are met  through  a variety of publications,
conferences, workshops, newsletter, equipment exhibi-
tions and other information dissemination programs.
We provide members and all other interested persons
with a distinctive forum in which they can exchange in-
formation  and  experiences  dealing  with hazardous
materials.  JOIN HMCRI TODAY!!!
                  Hoyt Corporation
                  251 Forge Rd.
                  Westport, MA 02790
                                                                                                                                                               317
                                       617/636-8811
                  Solvent  Vapor Recovery/Air Pollution Control Equip-
                  ment, Distillation Equipment

                  Hydro Group, Inc.                              304
                  P.O. Box 266
                  Linden, NJ 07036                      201/862-7800
                  Hydro Group, Inc. provides comprehensive solutions to
                  groundwater pollution problems—hydrogeological in-
                  vestigations, well drilling, treatment  process and equip-
                  ment design and manufacture, and  system  installation
                  and maintenance. Its wholly owned subsidiary corpora-
                  tion, Ground Water Associates, and  its six operating
                  divisions   provide  Hydro  Group,  Inc.  turnkey
                  capabilities in groundwater pollution.

                  In-Situ, Inc.                                    403
                  P.O. Box I
                  Laramie, WY 82070                    307/742-8213
                  In-Situ, Inc. manufactures computer-automated,  field
                  hydrologic  monitoring  instruments;  software  (both
                  mainframe and IBM PC-compatible) for environmental,
                  hydrologic  and  engineering applications; time-sharing
                  on our VAX 11/780 computer with free access to In-Situ
                  proprietary  software;  geotechnical  and  hydrological
                  consulting services.

                  Inmetco                                       207
                  (International Metals Reclamation Company)
                  P.O. Box 720
                  EllwoodCity, PA16117                 412/758-5515
                  Waste Metal Processing and Refining • Hazardous and
                  Non-Hazardous  Waste Processing • Approved Hazar-
                  dous Waste Processing Facility — #PAD087561015
                                                                                                                                   EXHIBITORS' LIST     451
-------
International Technology Corporation         133-135
23456 Hawthorne Blvd.                      232-234
Torrance, CA 90505                    213/378-9933
International  Technology Corporation  is the nation's
largest firm devoted exclusively to the management of
hazardous materials,  with  expertise in such  areas as
nuclear decontamination  services, emergency  response
and  remedial action  involving dioxins  and PCBs, la-
goons and sludges, hazardous  material  transportation,
treatment, disposal, and resource recovery, geotechnical
profiling and modeling, analytical services, health and
safety training and environmental permitting.

Labelmasler                                    141
5724 N. Pulaski Rd.
Chicago, IL 60646                      312/478-0900
Supplier of labels, forms, placarding, publications and
packaging for the safe transport of hazardous malcrials.

Liquid Waste Technologies, Inc.                  423
990 North Main
Las Cruces, NM 88001                  505/523-3132
Stabilizing and  solidifying  polymers for organic and
petroleum waste and oil spills. Volume expansion of
treated wastes  is less than  lO^o.  Polymers effectively
solidify waste oils, paint and  oil  sludges,  transformer
and   other oils  contaminated with PCBs,  kerosene,
gasoline and solvents. Safe,  economical and easy to use.

 MUD CAT Div. National Car                    242
 Rental Systems  Inc.
 1411  Perimeter Clr. E., NE
 Atlanta, GA 30346                     404/394-3013
 Manufacture and marketing of MUD CAT Low  Tur-
 bidity Dredges • Marketers of Kenner Billy Goat Cutter-
head Dredges, Vaughan Chopper Pump Lagoon Pump-
ers,  AQUA Dozer Pollution Control Equipment and
 UMI Awuatic Weed  Harvesters.
 Mid-America Environment Service, Inc.           314
 17450 South Halsted St.
 Homewood, IL 60430                  312/957-7600
 Services  include:  hazardous  waste  transportation;
 chemical  treatment  and  neutralization;  soil borings;
 hydrogeologic surveys;  tank  and lagoon cleaning; in-
 cineration; resource reclamation; dewatering; industrial
 maintenance; solidification/fixation; water blasting; site
 closure plans; spill contingency plans; emergency spill
 response; and sampling and analysis.


 Mineral By-Products, Inc.                       446
 777 Franklin Rd., #100
 Marietta, GA 30067                    404/424-0247
 POZZALIME™  calcic  powder  is  used  for  sludge
 solidification  and pH adjustment.  POZZALIME™
 calcic  powder is available in  bag or bulk for truck or
 barge  shipment from various locations throughout the
 United States.

 National Lime Association                       211
 3601 N. Fairfax Dr.
 Arlington. VA 22201                    703/243-5463
 Effective use of  lime  for treating hazardous  waste.
 Neutralization of acids,  precipitation of heavy metals,
 solidification of toxic elements. Low cost and recom-
 mended by U.S. EPA.

 National Water Well Association                  102
 500 W. Wilson Bridge Rd.
 Worthington, OH 43085                 614/846-9355
 The  National Water  Well Association,  the  nation's
 leading organization committed  to  the protection of
groundwater, offers information on its 70 educational
 programs, its more than 100 scientific publications, its
own research studies and membership with its scientific
division,  the  Association of Ground Water Scientists
and Engineers.
                                                        O.K. Materials Co. (OHM)                       104
                                                        16406 U.S. Rt. 224 East
                                                        Findlay. OH 45840                     419/423-3526
                                                        OHM provides a wide range of services: groundwater
                                                        recovery,  on-site treatment,  facilities decontamination,
                                                        hazardous waste  cleanup, technical  advisory services,
                                                        sampling and analytical services, management of under-
                                                        ground storage tanks, emergency response, surface im-
                                                        poundment restoration—from response center in Mas-
                                                        sachusetts, New  Jersey,  Virginia,  Florida, Georgia,
                                                        Alabama, Louisiana,  Texas,  Ohio,  Michigan,  Minne-
                                                        sota, Missouri and California.

                                                        Orlando Laboratories, Inc./                      404
                                                        Global Resource Planning, Inc.
                                                        P.O. Box 19127
                                                        820 Humphries Ave.
                                                        Orlando, FL 32814                     305/896-6645
                                                        Orlando Laboratories is an  analytical laboratory  pro-
                                                        viding services to the public, engineering firms, govern-
                                                        ment agencies, industries and consultants. We endeavor
                                                        to utilize only the most modern analytical equipment in
                                                        the  analysis of our client's samples.  Our expertise in-
                                                        cludes hazardous waste facility monitoring, gas chroma-
                                                        tography/mass spectromctry confirmation and planning
                                                        services.

                                                        P.E. LaMoreaux & Associates                    147
                                                        P.O. Box 2310
                                                        Tuscaloosa, AL 35403                  205/752-5543
                                                        P.E. LaMoreaux  and  Associates,Inc.  (PELA),  hy-
                                                        drologists, geologists and environmental scientists, offer
                                                        hydrological, geological, environmental and hazardous
                                                        waste consultation services throughout the world. Other
                                                        services include  emergency  spill  response, sampling,
                                                        laboratory analysis,  development of monitoring  pro-
                                                        grams and installation of wells, reclamation, govern-
                                                        ment permitting, court testimony and graphic and com-
                                                        munication programs.
Photovac International, Inc.                      442
739B Park Ave.
Huntington, NY 11743                  516/351-5809
Photovac manufactures ultra high sensitivity analyzers
for the detection of trace levels of airborne and water-
borne contaminants; these have gained wide acceptance
as a practical screening tool in hazardous waste sites.
This year we shall  be demonstrating our new  10S70
model, which has fully automated sampling  with com-
pound  identification  and  quantification,  automatic
calibration. Time Weighted Averaging and Level Alarm.
The 10S70 has an RS232 interface with autodial modem
for telephone  communication. Also featured will be
Photovac's  TIP—our  very economical,  lightweight
photoionization survey device.
Poly-America
2000 W. Marshal]
Grand Prairie, TX 75051
                                               303
                                      800/527-3322
Poly-Flex  is a polyethylene  gcomcmbranc offering  a
cost-effective  method  for  lining  hazardous  waste
disposal facilities and preventing groundwaier pollution.
Poly-America, one of the largest and most technologi-
cally equipped film extrusion facilities in the United
Stales, has the world's largest  blown film line which pro-
duces a 25-foot wide seamless geomembrane.

Pressure Filtration Specialists, Inc.                 107
P.O. Box 686
Torrington, CT 06790        203/489-1221 or 485-2524
Pressure  Filtration  Specialists,  Inc.  (PFS)— Volume
Reduction of Liquid Waste. PFS' mobile, self-contained
trailer-mounted filter presses reduce generator  liquid
sludge volume by producing filter cake of 35-60% solids
by weight. This reduced volume offers substantial sav-
ings to generators  on transportation and disposal costs.
On-site sample testing available upon request.
                                                        R.E. Wright Associates, Inc.                  231-233
                                                        3240 Schoolhouse Rd.
                                                        Middletown, PA 17057                  717/944-5501
                                                        R.E. Wright Associates, Inc. designs and manufactures
                                                        groundwater cleanup and oil spill recovery equipment,
                                                        including  the  Auto-Skimmer,  Air-Stripping Towers,
                                                        Water  Table Depression  Pumps and  Liquid  Interface
                                                        Samplers.  The Auto-Skimmer  automatically recovers
                                                        subsurface spills of floating hydrocarbons from both
                                                        large and  small diameter wells.  This equipment  will be
                                                        exhibited along with a  working  scale model of an Air-
                                                        Stripping  Tower system for removing volatile organic
                                                        compounds from water.
                                                        RETROTEX
                                                        1700 Gateway Blvd., SE
                                                        Canton, OH 44707
                                                                                                       227
                                       216/453-4677
                                                        RETROTEX specializes in the turnkey replacement of
                                                        PCB transformers and related equipment. We also have
                                                        a complete substation maintenance organization to per-
                                                        form all  facets of transformer and switchgear repair,
                                                        testing, calibration and maintenance. We are a complete
                                                        organization devoted to the complete PCB elimination
                                                        through equipment replacement and disposal.
                                                        Radian Corporation
                                                        P.O. Box 9948
                                                        Austin. TX 78766
                                                                                                       122
                                                                                              512/454-4797
Technology-based company which provides professional
services and specialty products to government and in-
dustry.  Full range of services offered in environmental
services, and specifically in the area of solid and hazar-
dous waste management. These services include the
areas of permitting; remedial action planning/imple-
mentation; soils,  water and  waste analysis; and waste
management facilities design.

Recra Research, lac.                              110
4248 Ridge Lea Rd.
Amherst, NY 14226                     716/838-6200
Environmental services including: Geologic/Hydrogco-
logic Investigations,  chemical and biological, analyses
(including  bench  pilot and feasibility  studies),  field
sampling, monitoring and analysis (including experi-
enced remedial teams and  fleet of mobile laboratories),
hazardous  waste management, regulatory compliance,
environmental research and  development and concep-
tual engineering. Permit assistance and chemical control
management.

Rcxnord                                       144
5103 West Beloit Rd.. Bldg.  N.
Milwaukee, WI 53201                    414/643-3083
Rexnord offers broad services to solve RCRA problems
through  its Envirex  subsidiary and its  EnviroEnergy
Technology Center.  Services  include:   In-plant  En-
vironmental Assessments,  SPCC Plans, Contingency
Plans, Right-to-Know Programs, Laboratory-analytical
and Bench Treatability Services, Pilot Plant Systems and
Operations, Underground  Tank  Management/Closure
Programs,  Full-scale   systems-Phys/Chem   and
Biological,  Mobile Van Dewatering Services, "Van of
the '90s" Groundwaier Treatment System.
Rocky Mountain Analytical Laboratory            322
5530 Marshall St.
Arvada, CO 80002                      303/421-6611
Located  near  Denver, Colorado,  Rocky  Mountain
Analytical  Laboratory  (RMAL) provides  analytical
chemistry services in a variety of environmental areas,
but specializing in RCRA and CERCLA investigations.
While  RMAL is one of the major contract laboratories
supporting EPA's Supcrfund investigations, the majori-
ty of laboratory work is for industrial clients. RMAL
has received  national recognition for its work  in  two
areas: analysis of the Appendix Hazardous Constituents
and support of RCRA activities at petroleum refineries
(waste delisting, Part B, LTD, etc.). The laboratory is
452     EXHIBITORS' LIST
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staffed with over 100 professionals and has all of the
analytical instrumentation to support virtually any type
of environmental project.

Roy F. Weston, Inc.                              Ill
Weston Way
West Chester, PA 19380                 215/692-3030
Roy F, Weston, Inc. (Weston) provides hazardous waste
remedial action services in design, permitting, investiga-
tion, construction management  cleanup  and closures.
Support  services  include:  emission   monitoring,
analytical  laboratories,  data  management systems,
emergency  response,  health and safety  training, and
right-to-know training.

Schlegel Lining Technology, Inc.                   238
P.O. Box 23197
Rochester, NY 14692                    716/427-7200
Schlegel  Lining Technology, Inc. manufactures/installs
HOPE liner, SCHLEGEL®  sheet, available in thick-
nesses up to 100 mils.  A single SCHLEGEL® sheet: 34
ft wide, up to 900 ft long, reduces field seams. No fac-
tory seams. Sheets are joined with patented extrusion
welding producing 100% bond strength. Unmatched in
chemical resistance, puncture/tear resistance, strength
under physical loadings. Schlegel  Lining Technology has
15 years  experience in design/manufacture and installa-
tion of containment systems. Laboratory and design ser-
vices available.

Sevenson Containment Corporation              343
2749 Lockport Rd.
Niagara Falls, NY 14302                 716-284-0431
Sevenson Containment Corporation provides services to
government and industry  in  the  areas  of hazardous
waste management and waste  site  cleanup. Sevenson's
full service capabilities include: site restoration; secure
landfill design & construction; sludge solidification &
fixation; slurry wall & trench construction; waste isola-
tion & stabilization; waste recovery & treatment; drum
removal; and transportation & disposal.
 Shirco Infrared Systems
 1195 Empire Central
 Dallas, TX 75247
                                                316
                                       214/630-7511
 Shirco, Inc., incineration systems featuring the use of in-
 frared heating and conveyor  belt transport  of waste
 materials  through an  efficiently insulated modularly
 constructed waste disposal system. Since no fossil fuel is
 required, the reduced gas flow is economically treated to
 meet requisite emission standards. Systems are excellent
 for intermittent operation and have transportable cap-
 ability. Shirco Portable Pilot Test Unit is available for
 on-site testing at your facility.

 Soil & Material Engineers, Inc.                     114
 1903 Harrison Ave.
 P.O. Box 609
 Gary, NC27511                         919/481-0397
 Soil &  Material Engineers, Inc. is a multi-disciplinary en-
 vironmental engineering consulting firm with over 800
 employees  based  in the Southeast and Midwest. Our
 professional staff of engineers,  hydrogeologists and
 scientists provide environmental services to industry and
 government in the following areas: Groundwater Assess-
 ment   •  Underground  Tank  Management  •  RI/FS
 Studies • Regulatory Liaison & Permitting • Remedial
 Action--Design.

 SilidurN.A. Company                           339
 2200 N. Ridge Rd. East
Elyria, OH 44036                        216/277-0981
An imbankment  stabilization  process  for  stable and
unstable soil conditions.  It addresses all types of slips
and channel work very cost effectively. If functions as a
flexible concrete retaining wall that turns  into a living
wall.
Soiltest, Inc.                                     440
(Soiltest/Environmental Division)
P.O. Box 931
Evanston, IL 60204                      800/323-1242
For sampling  of soils and water, the Environmental
Division of Soiltest, Inc. offers simple stainless steel soil
samplers up to sophisticated systems capable of remov-
ing a  specimen in a sealed container to retain volatile
gases and liquids. Water sampling equipment selection is
the largest in the U.S. Site investigation equipment in-
cludes  resistivity and  conductivity meters, lysimeters,
tensiometers and a full range of portable instruments.
SolidTek Systems, Inc.                            105
5371 Cook Rd., P.O. Box 888
Morrow, GA 30260                     404/361-6181
Full spectrum of  hazardous  waste  treatment  and
disposal services.  Custom chemical products and serv-
ices for chemical fixation and solidification to meet the
latest requirements.  Regional TSD  service.  Dedicated
systems  at  generator  locations.  Mobile  service  for
closures,  remediation projects.  Advanced  secure land-
fill.
Teledyne Geotech                                323
3401 Shiloh Rd.
Garland, TX 75041                      214/271-2561
Leakage Alarm System  for  Pipelines and  Pollutants
(LASP). The LASP represents a method for early detec-
tion of small subsurface leaks from storage tanks and
pipelines.  The location and size of a leak can be easily
determined. High  detection sensitivity with automatic
self-checking and  a  large signal-to-background  level
ratio provides a highly reliable system.
 The Tensar Corporation
 1210 Citizens Pkwy.
 Morrow, GA 30260
                                                345
404/968-3255
 Drainage Nets: Landfill Leachate Collection • Landfill
 or Surface Impoundment Leakage Detection • Landfill
 Cover Drainage • Landfill or Surface Impoundment Gas
 Drainage • Waste Pile Liquid Drainage • Landfill or
 Surface Impoundment Groundwater Underdrain. Slope
 Reinforcement Geogrids. Roadway and Base Reinforce-
 ment Geogrids.

 Trofe Incineration, Inc.                          332
 Trofe Industrial Park
 Mt. Laurel, NJ 08054                   609/235-3030
 Trofe Incineration, Inc. is an engineering and construc-
 tion firm that manufactures, markets and installs high-
 temperature incineration and  energy recovery systems.
 Three types of modular combustion systems are offered:
 a solids system, a liquids system or a single all-purpose
 system. The systems are designed with flexibility for ex-
 pansion upon need.

 U.S. Pollution Control, Inc.                  425-427
 2000 Classen Ctr.
 Oklahoma City, OK 73106               405/528-8371
 Waste disposal and transportation of RCRA and PCB
 waste. Remedial resonse and cleanup.  Commercial
 analytical  laboratory  and   state-of-the-art   recycling
 facilities.
                 WAPORA, Inc.                                 204
                 1555 Wilson Blvd., Suite 700
                 Rosslyn, VA 22209                     703/524-1171
                 WAPORA is a leading engineering and environmental
                 consulting firm that has served industry and government
                 for  over 15 years. The firm offers a wide range of ex-
                 perience  in  hazardous  waste site  investigation  and
                 remediation, including groundwater cleanup. Our cor-
                 porate  headquarters  are located in Washington,  DC,
                 and  we  maintain  regional  offices  in  New  York,
                 Philadelphia, Cincinnati, Chicago, Atlanta and Dallas.
                 Waste-Tech Services, Inc.
                 445 Union Blvd., #223
                 Lakewood, CO 80228
                                                                 421
                                       303/987-1790
                 Waste-Tech Services, Inc. provides a total service pro-
                 gram designed to destroy organic hazardous waste at a
                 client's site by using our proven and patented fluidized
                 bed  incineration technology.  Our  patented  system
                 handles gases, liquids, slurries, sludges and solids. WTS,
                 Inc. secures and holds all permits, provides all com-
                 pliance reports and interfaces with  all  regulatory agen-
                 cies.
                 Watersaver Company, Inc.
                 P.O. Box 16465
                 Denver, CO 80216
                                                                 334
                                       303/238-1818
                 Watersaver Company provides the world's most reliable
                 membrane  lining  systems.   Our  products  meet  all
                 regulatory requirements for zero seepage. With over 30
                 years' experience and 300 million square feet of suc-
                 cessful  installation,  Watersaver  leads  the  way  with
                 proven  products and systems that work correctly and
                 continuously. Linings and floating covers of Hypalon,
                 CPE and PVC up to 60 mils.
                 Wilson Laboratories
                 525 N. 8th St.
                 Salina, KS 67401
                                                                 217
                                       913/825-7186
Full service analytical laboratory specializing in en-
vironmental monitoring and the analyses of hazardous
waste samples. Expertise includes GC, GC/MS, HPLC
and Industrial Hygiene.

Woodward-Clyde Consultants                     305
P.O. Box 66317, 2822 O'Neal Ln.
Baton Rouge, LA 70815                 504/291-1873
Woodward-Clyde Consultants is  a nationwide profes-
sional services firm serving clients for over 30 years. Our
practice  includes  the  application  of  knowledge  in
engineering, the earth  sciences  and the environmental
and social sciences. Services  offered include:  waste
management; environmental assessments;  geology and
hydrogeology; hydrology;  site selection studies; oil spill
contingency planning; air and water quality studies; geo-
technical engineering, and risk and decision analysis.

YWC, Inc.                                      431
200 "Monroe Tpke.
Monroe, CT 06468                      203/261-4458
A  multidisciplinary  environmental   laboratory/engi-
neering  consulting firm, YWC, Inc. provides air, soil,
water and waste characterization for full-profile site
assessments. The York Laboratories Division is a par-
ticipant in EPA's Contract Laboratory Program. Addi-
tional services available include contract operation of
wastewater treatment facilities, interim sludge dewater-
ing services, hazardous waste-management and remedial
investigation/feasibility studies.  Growth  has  been
achieved through dedicated personal service with an em-
phasis on quality at most competitive prices.
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