EPA
          United States
          Environmental Protection
          Agency
            401 MSt..S.W.
            Washington. D.C. 20460   April 1980
         Solid Waste
Subtitle C, Resource Conservation
and Recovery Act of 1976

Final Environmental Impact
Statement—Part I

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                            Notice





     The attached document was prepared by one or more



contractors under the guidance of EPA.  It is printed here



largely as received from the contractor; the Agency has not



yet completed reviewing it.



     Because of the lead time necessary to produce this



study, it was necessary to base it on a preliminary draft



of the final regulations.  There were some changes made



later to the regulations.  Thus this document unavoidably



does not completely correspond to the regulations finally



promulgated.  The Agency is currently analyzing the effect



of the late regulatory changes on the findings of this



study.

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             DRAFT
               FINAL
ENVIRONMENTAL IMPACT STATEMENT
               PARTI
                FOR
   SUBTITLE C, RESOURCE CONSERVATION
     AND RECOVERY ACT OF 1976 (RCRA)
            PREPARED BY
      -  OFFICE OF SOLID WASTE
  U.S. ENVIRONMENTAL PROTECTION AGENCY
        WASHINGTON, D.C. 20460
           STEFFEN W. PLEHN
    DEPUTY ASSISTANT ADMINISTRATOR
           FOR SOLID WASTE
              APRIL 1980

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                            SUMMARY SHEET

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

                   Environmental Protection Agency
                        Office of Solid Waste

1.  Type of Action

    Administrative Action (Regulatory)

2.  Brief Description of Action

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

3.  Summary of Beneficial and Adverse Environmental Effects

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

4.  Alternatives Considered

    a.  Baseline Action
    b.  No Action
    c.  Phasing of Generators
    d.  Enhanced Public Health and Environmental Protection
    e.  Lesser Degree of Public Health and Environmental Protection
    f.  Phase I


                                  iii

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

    The proposed Subtitle C regulations and the Draft EIS were
    distributed to hundreds of individuals and organizations
    representing all sectors of our society.  Over 1200 written
    comments were received on the proposed regulations.  The
    following is a list of individuals and organizations who
    submitted written comments directly pertaining to the EIS:

         American Petroleum Institute
         American Textile Manufacturers Institute, Inc.
         Department of Health, Education,  and Welfare, Public Health
           Service
         Dow Chemical U.S.A.
         Mobil Oil Corporation
         The Utility Solid Waste Activities Group and The Edison
           Electric Institute
         United States Department of Commerce

6.  Date Available To The Public

    The Part I Final Environmental Impact  Statement has been provided
    to the Office of Environmental Review, EPA, for the purpose of
    publishing an official public notice of availability in the
    Federal Register.  The Economic Impact Analysis for Subtitle C
    has also been provided to the Office of Environmental Review,
    EPA.  The notice of availability of these documents is antici-
    pated on April 30, 1980.

    These documents may be obtained by writing:  Mr. Edward Cox,
    Solid Waste Information Office, U.S. Environmental Protection
    Agency, 26 West St. Glair, Cincinnati, Ohio  45260.  The        °
    documents may be viewed at the library of all EPA Regional
    Offices.
                                 iv

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                          ACKNOWLEDGEMENT
     This voluntary Environmental Impact Statement was prepared by
the U.S. Environmental Protection Agency (EPA) with the assistance
of the MITRE Corporation under EPA Contract Number 58-01-4641.   The
Project Officer was Ellen O'Boyle, Office of Solid Waste.

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                               PREFACE




     The Part I - Final Environmental Impact Statement (EIS) for




Subtitle C of RCRA presents an analysis of the Phase I Subtitle C




regulations as drafted in February 1980, as well as an analysis of




other alternatives to the baseline regulations that were considered




in the Draft Environmental Impact Statement.  It was necessary to




analyze the February 1980 version of the Phase I regulations due to




time constraints involved in preparing the regulations and conducting




an environmental impact analysis of them.




     As a result of numerous comments subsequent to the proposal of




RCRA Section 3004 regulations in December 1978, the Agency has con-




cluded that more study and analysis will be required to develop and




support many of the national "technical" standards which will pre-




scribe the design and construction of facilities.  The Agency has




chosen therefore to promulgate the Section 3004 regulations covering




waste management facilities on a phased basis.  Phase I, to be




promulgated April 30, 1980, includes primarily the requirements which




are incumbent upon facilities during the Interim Status period (the




time between the effective date of the regulations and final action




on a permit), plus most of the administrative requirements for




permitted facilities.  This EIS covers these Phase I Interim Status




Standards.




     Since the general technical standards will not be included in




Phase I, it will not be possible to grant permits until Phase II of




the regulations for waste management facilities are issued later this




                                vii

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year.  The Phase II regulations will contain a great deal of flexibi-




lity for the Regional Administrator to use his judgment in deciding




the environmental adequacy of a facility.  The Phase II regulations




will be sufficiently comprehensive to allow the permitting process to




commence, but will not contain many of the specific technical re-




quirements which the Agency hopes to promulgate over the next several




years as more information is developed.  A Part II - Final EIS will




be issued at the time Phase II of the regulations is promulgated.




This promulgation is anticipated for the fall of 1980.




     Phase III will involve reproposing and ultimately promulgating




more definite technical standards as the technical issues are re-




solved.  The Phase III regulations will not be included within the




scope of this EIS.




     A separate economic impact analysis has been prepared for the



final Subtitle C regulations.  The report entitled "Economic Impact




Analysis for Subtitle C Resource Conservation and Recovery Act of




1976" is to be available April 30, 1980.




     Several major revisions with respect to the Draft Environmental




Impact Statement have been incorporated into this Part I - Final En-




vironmental Impact Statement.  These revisions are based upon com-




ments received on the Draft Environmental Impact Statement and upon




standards considered for pomulgation under Phase I of the regula-




tions.  An additional alternative, the Phase I Alternative, has been



assessed in Chapter 8.  The number of generators required to comply
                                vlii

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with the baseline regulations has been modified to consider the




effects of the Transfer of Liability Contract.  The Assessment of




energy use impacts in Chapter 7 and 8 has been expanded to consider




impacts to energy production.  The assessment of impacts to hazardous




waste management facility capacity has been modified to clarify the




potential for localized capacity shortfalls.  The Summary Chapter has




been modified, as necessary, based upon changes to the rest of the




Environmental Impact Statement.
                                 ix

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                          TABLE OF CONTENTS

                                                                 Page

LIST OF ILLUSTRATIONS                                            xxvi

LIST OF TABLES                                                  xxvii


                         CONTENTS OF VOLUME I


S.O  SUMMARY                                                      S-'l

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

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

S.3  Description of the Reasonable Alternatives                   S-7

     S.3.1  No Action                                             S-8
     S.3.2  Phasing of Generators                                 S-9
     S.3.3  Enhanced Public Health and Environmental
            Protection                                           S-10
     S.3.4  Lesser Degree of Public Health and
            Environmental Protection                             S-10
     S.3.5  Phase I Alternative                                  S-ll

S.4  Impacts of the Baseline Regulations                         S-l2

     S.4.1  Potential Primary Impacts                            S-l3
     S.4.2  Potential Secondary Impacts                          S-31
                                 xi

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                    TABLE OF CONTENTS (Continued)

                                                                 Page

S.5  Impacts of the Alternatives                                 S-41

     S.5.1  No Action Alternative                                S-41
     S.5.2  Phasing of Generators Alternative                    S-42
     S.5.3  Enhancing Public Health and Environmental
            Protection Alternative                               S-45
     S.5.4  Lesser Degree of Public Health and
            Environmental Protection Alternative                 S-56
     S.5.5  Phase I Alternative                                  S-65

1.0  INTRODUCTION                                                 1-1

2.0  LEGISLATIVE BACKGROUND                                       2-1

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

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

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

     2.4.1  The Status of State Regulatory Criteria Applicable
            to Generators of Hazardous Waste                     2-30
     2.4.2  The Status of State Regulatory Criteria Applicable
            to Transporters of Hazardous Waste                   2-31
     2.4.3  The Status of State Regulatory Criteria Applicable
            to Treaters of Hazardous Waste                       2-32
     2.4.4  The Status of State Regulatory Criteria Applicable
            to Storers of Hazardous Waste                        2-33
     2.4.5  The Status of State Regulatory Criteria Applicable
            to Disposers of Hazardous Waste                      2-34

                                xii

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                    TABLE OF CONTENTS (Continued)
     2.4.6  The Status of State Hazardous Waste Definition,
            Monitoring, and Enforcement                          2-35

3.0  DESCRIPTION OF THE BASELINE ACTION                           3-1

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

4.0  IDENTIFICATION AND SELECTION OF REASONABLE ALTERNATIVES      4-1

4.1  No Action                                                    4-3
4.2  Phasing of Generators                                        4-5
4.3  Enhanced Public Health and Environmental Protection         4-11
4.4  Lesser Degree of Public Health and Environmental
     Protection                                                  4-19
4.5  Phase I Alternative                                         4-28

5.0  EXISTING HAZARDOUS WASTE GENERATION AND MANAGEMENT
     PRACTICES                                                    5-1

5.1  Characterization of Hazardous Waste Generation               5-1

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

5.2  Characterization of Hazardous Waste Transport               5-22

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

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                    TABLE OF CONTENTS (Continued)

                                                                 Page

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

     5.3.1  Storage                                              5-32
     5.3.2  Treatment                                            5-34
     5.3.3  Disposal                                             5-35
     5.3.4  Typical Management Practices for Hazardous
            Industrial Waste                                     5-36
     5.3.5  Hazardous Waste Management Service Industry          5-43
     5.3.6  State Data on On-Site and Off-Site Disposal          5-48

5.4  Resource Conservation and Recovery                          5-52

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

6.0  QUANTITIES OF HAZARDOUS WASTES GENERATED AND CONTROLLED      6-1

6.1  Current Hazardous Waste Generation                           6-1

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

6.2  Hazardous Waste Generators                                  6-11
6.3  Estimation of Future Hazardous Waste Generation             6-14
6.4  Hazardous Spills                                            6-15
6.5  Hazardous Wastes Under State Control                        6-24

7.0  IMPACTS OF THE BASELINE ACTION                               7-1

7.1  Potential Primary Impacts                                    7-4

     7.1.1  Hazardous Wastes to be Regulated                      7-5
     7.1.2  Changes to Existing Generation, Transport,
            Storage, Treatment, and Disposal Practices
            and Procedures                                        7-9
     7.1.3  Administrative Changes                               7-38
     7.1.4  Air Impacts                                          7-59
     7.1.5  Water Quality Impacts                               7-107
     7.1.6  Public Health Impacts                               7-145
                                xiv

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                    TABLE OF CONTENTS (Continued)        	

                                                                 Page

7.2  Potential Secondary Impacts                                7-161

     7.2.1  Impacts to Physiography and Soils                   7-161
     7.2.2  Biological Impacts                                  7-168
     7.2.3  Social Impacts                                      7-183
     7.2.4  Hazardous Waste Management Facility Capacity        7-192
     7.2.5  Land Use Impacts                                    7-201
     7.2.6  Water Use impacts                                   7-204
     7.2.7  Impacts to Resource Conservation and Recovery       7-206
     7.2.8  Energy Use Impacts                                  7-208
     7.2.9  Impacts to Special Interest Points                  7-211

7.3  Significant Uncertainties in the Impact Analysis           7-213

8.0  IMPACTS OF THE ALTERNATIVES                                  8-1

8.1  Potential Changes in Impacts Resulting from the
     No Action Alternative                                        8-2

     8.1.1  Primary Impacts                              	8--2
     8.1.2  Secondary Impacts                                     8-5

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

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

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

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

8.4  Potential Change in Impacts Resulting from the
     Lesser Degree of Public Health and Environmental
     Protection Alternative                                      8-69

     8.4.1  Primary Impacts                                      8-69
     8.4.2  Secondary Impacts                                   8-100

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                    TABLE OF CONTENTS (Continued)

                                                                 Page
8.5  Potential Charges in Impacts Resulting from
     the Phase I Alternative                                    8-117

     8.5.1  Primary Impacts                                     8-118
     8.5.2  Secondary Impacts                                   8-170

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

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

     9.2.1  Siting                                                9-8
     9.2.2  Transportation                                       9-10
     9.2.3  Construction and Operation                           9-11
     9.2.4  Closure                                              9-13

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

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

APPENDIX A - SELECTED STATE HAZARDOUS WASTE REGULATIONS           A-l

A.I  Regulations Applicable To Generators                         A-l

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

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                    TABLE OF CONTENTS (Continued)

                                                                 Page

A.2  Regulations Applicable to Transporters                       A-7

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

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

     A.3.1  California                                           A-13
     A.3.2  Georgia                                              A-14
     A.3.3  Illinois                                             A-15
     A.3.4  Maryland                                             A-16
     A.3.5  Minnesota                                            A-16
     A.3.6  Missouri                                             A-17
     A.3.7  Montana                                              A-18
     A.3.8  Oklahoma                                             A-18
     A.3.9  Oregon                                               A-19
     A.3.10 Texas                                                A-20
     A. 3.11 Washington                                           A-21

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

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

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

     A.5.1  Territory of Guam                                    A-24
     A.5.2  Territory of American Samoa                          A-24
     A.5.3  Trust Territory of the Pacific Islands               A-2S
     A.5.4  Puerto Rico                                          A-25
     A.5.5  The U.S. Virgin Islands                              A-25

APPENDIX B - BASELINE SUBTITLE C REGULATIONS                      B-l

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

                               xvii

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                    TABLE OF CONTENTS (Continued)

                                                                 Page

     250.10  Purpose and Scope                                    B-2
     250.11  Definitions                                          B-3
     250.12  Criteria                                             B-5
     250.13  Hazardous Waste Characteristics                      B-7
     250.14  Hazardous Waste Lists                               B-15
     Appendix I - Explosion Temperature Test                     B-29
     Appendix II - Separation Protocol                           B-30
     Appendix III - Structural Integrity Procedure               B-32
     Appendix IV - pH Adjustment Procedures                      B-33
     Appendix V - Sampling Methods                               B-34
     Appendix VI - Pesticides                                    B-35
     Appendix VII - Department of Transportation (DOT)
                    Classification Poison A, Poison B,
                    or ORM-A                                     B-37
     Appendix VIII - Autoclave Speifications                     B-43
     Appendix IX - CDC Classification of Etiologic Agents        B-44
     Appendix X - Radioactive Waste Measurements                 B-50
     Appendix XI - Detection of Gene Mutations                   B-51
     Appendix XII - Bioaccumulation Potential Test               B-61
     Appendix XIII - Controlled Substance List                   B-67
     Appendix XIV - Priority Pollutants                          B-69

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

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

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

     250.30  Scope                                               B-98
     250.31  Definitions                                         B-99
     250.32  Identification Code                                B-101
     250.33  Recordkeeping                                      B-101
     250.34  Acceptance and Transfer of Hazardous Waste         B-102

                                xviii

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                    TABLE OF CONTENTS (Continued)

                                                                 Page

     250.35  Compliance with the Manifest                       B-103
     250.36  Delivery of Hazardous Wastes to a Designated
             Permitted Facility                                 B-105
     250.37  Spills                                             B-105
     250.38  Placarding/Marking of Vehicles                     B-108

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

     250.40  Scope/Applicability                                B-lll
     250.41  Definitions                                        B-113
     250.42  Human Health and Environmental Standards           B-127
     250.43  General Facility Standards                         B-130
     250.44  Standards for Storage                              B-169
     250.45  Standards for Treatment/Disposal                   B-172
     250.46  Special Waste Standards                            B-210
     Annex 1 - Drinking Water Standards                         B-212
     Annex 2 - Threshold Limit Values for Chemical
               Substances                                       B-213
     Annex 3 - TSDF Report                                      B-221
     Annex 4 - Incompatible Wastes                              B-222
     Annex 5 - Methods for Determining Soil pH                  B-225

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

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

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

     250.70  Scope and Purpose                                  B-269
     250.71  Definitions                                        B-269
     250.72  Authorization                                      B-271

                                xix

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                    TABLE OF CONTENTS (Continued)
     250.73  Interim Authorization                              B-279
     250.74  Federal Outsight of Authorized Programs            B-282
     250.75  Application Procedure                              B-285
     250.76  Withdrawal of Authorization                        B-287

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

     250.800  Scope and Purpose                                 B-290
     250.801  Definitions                                       B-290
     250.810  Limited Interim Authorization                     B-293
     250.811  Application Procedures for States                 B-294
     250.812  Responsibilities and Authority of the EPA
              Regional Administrator                            B-295
     250.820  Who Must File Notification                        B-296
     250.821  When to File Notification                         B-298
     250.822  Where to File Notification                        B-299
     250.823  Information Required in Notification              B-299

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

C.I  Textile Industry                                             C-3
C.2  Inorganic Chemicals Industry                                 C-6
C.3  Pharmaceutical Industry                                      C-7
C.4  Paint and Allied Products Industry and Contract
     Solvent Reclaiming Operations                               C-l2

     C.4.1  Paint and Allied Products Industry                   C-l2
     C.4.2  Contract Solvent Reclaiming Operations               C-l6

C.5  Organic Chemicals, Pesticides, and Explosives
     Industries                                                  C-l7
C.6  Petroleum Refining Industry                                 C-l7
C.7  Petroleum Rerefining Industry                               C-34
C.8  Leather Tanning and Finishing Industry                      C-35
C.9  Metal Smelting and Refining Industry                        C-39
C.10  Electroplating and Metal Finishing Industries              C-46
C.ll  Special Machinery Manufacturing Industries                 C-48
C.I2  Electronic Components Manufacturing Industry               C-53
C.13  Storage and Primary Batteries Industries                   C-55
                                 xx

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                    TABLE OF CONTENTS (Continued)

                                                                 Page

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

D.I  Treatment Methods                                            D-l

     D.I.I  Physical Treatment                                    D-2
     D.I.2  Chemical Treatment                                    D-6
     D.I.3  Biological Treatment                                  D-9
     D.I.4  Thermal Treatment                                    D-l3

D.2  Methods for Ultimate Disposal                               D-19

     D.2.1  Open Dumping                                         D-20
     D.2.2  Landfills                                            D-21
     D.2.3  Landfarming                                          D-23
     D.2.4  Surface Impoundments                                 D-24
     D.2.5  Incineration                                         D-26
     D.2.6  Road Application                                     D-26
     D.2.7  Detonation                                           D-27
     D.2.8  Engineered Storage                                   D-27

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

     D.3.1   Textiles Industry                                   D-28
     D.3.2   Inorganic Chemicals Industry                        D-30
     D.3.3   Pharmaceutical Industry                             D-33
     D.3.4   Paint and Allied Products Industries and
             Contract Solvent Reclaiming Operations              D-3S
     D.3.5   Organic Chemicals, Pesticides, and
             Explosives Industries                               D-38
     D.3.6   Petroleum Refining Industry                         D-44
     D.3.7   Petroleum Rerefining Industry                       D-48
     D.3.8   Leather Tanning and Finishing Industry              D-51
     D.3.9   Metal Smelting and Refining Industry                D-54
     D.3.10  Electroplating and Metal Finishing
             Industries                                          D-60
     D.3.11  Special Machinery Manufacturing Industries          D-62
     D.3.12  Electronic Components Manufacturing Industry        D-64
     D.3.13  Storage and Primary Batteries Industries            D-67
                                xxl

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                    TABLE OF CONTENTS (Continued)
APPENDIX E - CHARACTERIZATION OF THE HAZARDOUS WASTE
             TRANSPORT INDUSTRY                                   E-l

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

     E.3.1  Common and Contact Highway Carriers                  E-10
     E.3.2  Rail Transport                                       E-14
     E.3.3  Air Transport                                        E-20
     E.3.4  Pipeline Transport                                   E-21
     E.3.5  Waterway Transport                                   E-22

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

F.I  Potential Recovery of Hazardous Wastes Generated by
     the Inorganic Chemical Industry                              F-l
F.2  Potential Recovery of Hazardous Wastes Generated by
     the Organic Chemical Industry                                F-4
F.3  Potential Recovery of Hazardous Wastes Generated by the
     Metals Smelting and Refining Industries                      F-4

APPENDIX G - INDUSTRIAL WASTE CLEARINGHOUSES AND EXCHANGES        G-l

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

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

H.I  Methods of Quantifying Hazardous Wastes                      H-l
H.2  Data Sources                                                 H-4
H.3  Development of Generation Factors                           H-l2
H.4  Limitations of Generation Factors                           H-l5

     H.4.1  Comparability of Data Sources                        H-l5
     H.4.2  Possible Biases in Industry Coverage                 H-l9
     H.4.3  Possible Inaccuracies Due to Company Responses       H-19
     H.4.4  Aggregation at the Two-Digit SIC Level               H-20
     H.4.5  Waste Generation per Employee                        H-23

H.5  Application of Generation Factors                           H-23


                                xxii

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                    TABLE OF CONTENTS (Continued)

                                                                 Page

APPENDIX I - DOCUMENTATION FOR PHASING CALCULATIONS               1-1

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

APPENDIX J - HAZARDOUS WASTE INCIDENTS                            J-l

J.I  Generation Incidents                                         J-l
J.2  Transport Incidents                                          J-2
J.3  Treatment and Lagoon Incidents                               J-3
J.4  Storage Incidents                                           J-10
J.5  Disposal Incidents                                          J-l7

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

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

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

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

APPENDIX N - PHASE I ALTERNATIVE                                  N-l

Part 260 - Overview and Definitions                               N-2

     Subpart A - Definitions                                      N-3

Part 261 - Identification and Listing of Hazardous Waste          N-5

     Subpart A - General                                          N-5
     Subpart B - Criteria for Identifying and Applying
                 Characteristics of Hazardous Waste
                 and for Listing Hazardous Waste                 N-l2
     Subpart C - Characteristics of Hazardous Waste              N-l7
     Subpart D - Lists of Hazardous Wastes                       N-22

                                xxiii

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                    TABLE OF CONTENTS (Continued)
Part 262 - Standards Applicable to Generators of Hazardous
           Wastes                                                N-70

     Subpart A - General                                         N-71
     Subpart B - The Manifest                                    N-72
     Subpart C - Pre-Transport Requirements                      N-73
     Subpart D - Recordkeeping and Reporting                     N-75
     Subpart E - Special Conditions                              N-77

Part 263 - Standards Applicable to Transporters of Hazardous
           Waste                                                 N-86

     Subpart A - General                                         N-87
     Subpart B - Compliance with the Manifest System
                 and Recordkeeping                               N-88
     Subpart C - Hazardous Waste Discharges                      N-92

Part 264 - Standards for Owners and Operators
           of Hazardous Waste Treatment, Storage, and
           Disposal Facilities                                   N-94

     Subpart A - General                                         N-96
     Subpart B - General Facility Standards                      N-97
     Subpart C - Preparedness and Prevention                    N-104
     Subpart D - Contingency Plan and Emergency Procedures      N-107
     Subpart E - Manifest System, Recordkeeping,
                 and Reporting                                  N-113
     Subpart F - Ground-Water Monitoring                        N-118
     Subpart G - Closure and Post-Closure                       N-126
     Appendix I - Recordkeeping Instructions                    N-132
     Appendix II - EPA Report Form and Instructions             N-137
     Appendix III - EPA Interim Primary Drinking Water
                    Standards                                   N-147
     Appendix IV - Tests for Significance                       N-148

Part 265 - Interim Status Standards for Owners and
           Operators of Hazardous Waste Treatment,
           Storage, and Disposal Facilities                     N-150

     Subpart A - General                                        N-155
     Subpart B - General Facility Standards                     N-156
     Subpart C - Preparedness and Prevention                    N-163
     Subpart D - Contingency Plan and Emergency Procedures      N-165
     Subpart E - Manifest System, Recordkeeping, and
                 Reporting                                      N-171
                                xx iv

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                    TABLE OF CONTENTS (Concluded)
     Subpart F - Ground-Water Monitoring                        N-175
     Subpart G - Closure and Post-Closure                       N-182
     Subpart H - Financial Requirements                         N-188
     Subpart I - Use and Management of Containers               N-208
     Subpart J - Tanks                                         ,N-210
     Subpart K - Surface Impoundments                           N-214
     Subpart L - Waste Piles                                    N-218
     Subpart M - Land Treatment                                 N-220
     Subpart N - Landfills                                      N-226
     Subpart 0 - Incinerators                                   N-230
     Appendix I - Recordkeeping Instructions                    N-233
     Appendix II - EPA Report Form and Instructions             N-238
     Appendix III - EPA Interim Primary Drinking
                    Water Standards                             N-249
     Appendix V - Examples of Potentially Incompatible
                  Waste                                         N-251

Part 266 - Standards for Owners and Operators of
           Facilities that Treat, Store, and/or Dispose
           of Waste Identified for Discriminate
           Standards                                            N-255

     Subpart A - General                                        N-256
     Subpart B - Uranium Mining and Phosphate
                 Rock Mining, Beneficiation, and
                 Processing Waste                               N-256

APPENDIX 0 - COMMENT LETTERS RECEIVED ON THE
             DRAFT ENVIRONMENTAL IMPACT STATEMENT                 0-1

0.1  American Textile Manufacturers Institue, Inc.                0-2
0.2  U.S. Department of Commerce                                  0-5
0.3  Department of Health, Education, and Welfare,
     Public Health Service                                        0-9
0.4  The Utility Solid Waste Activities Group and
     The Edison Electric Institute                               0-12
0.5  Mobile Oil Corporation                                      0-66
0.6  American Petroleum Institute                                0-72
0.7  Dow Chemical U.S.A.                                         0-87

APPENDIX P - LITERATURE CITED                                     P-l
                                XXV

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                        LIST OF ILLUSTRATIONS


                        CONTENTS OF VOLUME I
                                                                 Page
5-1  Geographic Distribution of Hazardous Waste
     Management Facilities                                       5-45
6-1  Cumulative Size Distribution of Hazardous Waste
     Generators 1975                                             6-12
6-2  Cumulative Hazardous Waste Distribution 1975                6-13
                        CONTENTS OF VOLUME II

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

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                           LIST OF TABLES


                        CONTENTS OF VOLUME I
                                                                 Page

S-l   Comparison of Potential Impacts of the Baseline
      Regulations and the Phase I and the Enhanced and
      the Lesser Degree of Public Health and Environmental
      Protection Alternatives                                    S-46
2-1   State Regulation and Control Authority                     2-19
2-2   State Legislation Applicable to Hazardous Waste
      Generators                                                 2-24
2-3   State Legislation Applicable to Hazardous Waste
      Transporters                                               2-25
2-4   State Legislation Applicable to Hazardous Waste
      Treaters                                                   2-26
2-5   State Legislation Applicable to Hazardous Waste
      Storers                                                    2-27
2-6   State Legislation Applicable to Hazardous Waste
      Disposers                                                  2-28
2-7   State Approach to Hazardous Waste Definition,         	
      Monitoring, and Enforcement                                2-29
4-1   Phasing of Generators                                       4-9
4-2   Enhanced Public Health and Environmental Protection        4-12
4-3   Lesser Degree of Public Health and Environmental
      Protection                                                 4-21
4-4   Phase I Alternative                                        4-29
5-1   Sources of Chemicals for Inclusion on the Initial
      List of the Toxic Substance Control Act Interagency
      Testing Committee                                           5-6
5-2   Examples of General Types of Potentially Hazardous
      Waste Constituents                                         5-12
5-3   Examples of Potentially Hazardous Waste Streams from
      Selected Manufacturing Industries                          5-14
5-4   Examples of Spills of Potentially Hazardous Materials      5-23
5-5   Relative Amount of Hazardous Wastes Transported
      Off-Site by Mode and Industry Segment                      5-25
5-6   Examples of Storage Practices in Selected Industries       5-33
5-7   Estimated Portion of Hazardous Wastes from Fourteen
      Manufacturing Industries Disposed by Method, 1973-1975     5-37
5-8   Estimated Percentage of Total Hazardous Wastes
      Treated/Disposed On-Site by Various Methods for
      Selected Industries - 1973                                 5-39
5-9   Estimated Percentage of Total Hazardous Wastes
      Treated/Disposed Off-Site by Various Methods for
      Selected Industries - 1973                                 5-40
                                xxvil

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                     LIST OF TABLES (Continued)
5-10  Estimated Percentage of Hazardous Wastes
      Treated/Disposed or Recovered On-Site and
      Off/Site                                                   5-42
5-11  Estimated Percentage of Hazardous Wastes
      Treated/Disposed by Level I, II, or III
      Technology for Selected Manufacturing Industries           5-44
5-12  Capacity of Selected Hazardous Waste Management
      Service Industry Processes - 1974                          5-47
5-13  Types of Hazardous Wastes Handled and Typical
      Treatment/Disposal Methods for the Hazardous
      Waste Management Industry                                  5-49
5-14  Estimated Percentage of Hazardous Industrial
      Wastes Disposed by Location or Reclaimed for
      Selected States                                            5-50
5-15  Distribution of Hazardous Waste Recovery Operations
      in the United States                                       5-54
5-16  Examples of Hazardous Waste Recovery and Recycling
      Practices in Selected Industries                           5-58
5-17  Waste Oil Sources and Uses, 1972               			5r62
5-18  Estimated Magnitude of Hazardous Wastes from
      Selected Industries that may be Potentially
      Recoverable or Recyclable                                  5-65
5-19  Generation and Potential Use of Organic
      Chemical Wastes                                            5-68
5-20  Industries and Hazardous Waste Types Studied for
      Energy Recovery Potential                                  5-69
5-21  Estimated Annual Waste Quantities and Total
      Recoverable Energy                                         5-70
6-1   Summary of Hazardous Waste Generated by EPA Region-1975     6-3
6-2   Estimated Annual Generation of Non-Manufacturing
      Wastes Identified as Including Potentially
      Hazardous Waste                                             6-6
6-3   EPA Hazardous Substance Spill File Summary
      (February 1977 - February 1978)                            6-17
6-4   Types of Discharges Reported for 1976 under
      Section 311, PL-92-500                                     6-20
6-5   Sources of Discharges Reported for 1976 under
      Section 311, PL 92-500                                     6-22
6-6   Commodities Named Most Often in Hazardous Materials
      Incident Reports                                           6-23
6-7   Summary - State Control over Hazardous Wastes              6-25
6-8   Hazardous Waste Control in Large Generator States          6-26
                               xxviil

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                     LIST OF TABLES (Continued)


                                                                 Page

7-1   Number and Types of Reported Incidents from the
      Improper Management of Hazardous Wastes                     7-3
7-2   Estimated Quantity of Hazardous Manufacturing
      Wastes and Number of Establishments Excluded
      from Regulation at a Generator Limit of 100 kg/mo           7-8
7-3   Number of Manufacturing Establishments by 2-Digit
      SIC Code                                                   7-46
7-4   Number of Manufacturing Establishments by EPA Region       7-47
7-5   Potential Hazardous Waste Generators within Selected
      Manufacturing Industries by EPA Region                     7-49
7-6   Estimated Number of Potential Producers of Hazardous
      Wastes within Selected Categories                          7-50
7-7   Estimated Number of Potential Permittees                   7-54
7-8   Estimated Change in Vehicular Emissions in 1984 from
      Transport of Hazardous Industrial Wastes under
      Subtitle C Regulations                                     7-78
7-9   Gas Composition Data                                       7-84
7-10  Origins and Pollutants in 57 Cases of Ground Water
      Contamination in the Northeast Caused by Leakage
      of Waste Water from Surface Impoundments                  7-128
7-11  Summary of Data on 42 Municipal and 18 Industrial
      Contamination Cases                                       7-130
7-12  Groundwater Contamination from Industrial Waste
      Land Disposal Sites                                       7-132
7-13  Properties of Wastes that are Hazardous to Living
      Systems                                                   7-169
7-14  Generalized Patterns of the Response of Biological
      Systems to Increased Levels of Environmental Stress       7-170
7-15  Estimated Change in Fuel Consumption in 1984 from
      Transport of Hazardous Industrial Wastes under
      Subtitle C Regulations                                    7-210
8-1   Regulated Hazardous Manufacturing Wastes During the
      First Year of Phasing (1980) by Region and SIC Code         8-9
8-2   Regulated Hazardous Manufacturing Wastes During the
      Second Year of Phasing (1981) by Region and SIC Code       8-10
8-3   Regulated Hazardous Manufacturing Wastes During the
      Third Year of Phasing (1982) by Region and SIC Code        8-11
8-4   Regulated Hazardous Manufacturing Wastes During the
      Fourth Year of Phasing (1983) by Region and SIC Code       8-12
8-5   Estimated Change in Vehicular Emissions in 1984 from
      Transport of Additional Hazardous Industrial Wastes
      under Subtitle C Regulations'                               8-36
                                xx ix

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                     LIST OF TABLES (Continued)
8-6   Estimated Change in Fuel Consumption in 1984 from
      Transport of Additional Hazardous Industrial Wastes
      under Subtitle C Regulations                               8-67
8-7   Estimated Quantity of Hazardous Manufacturing
      Wastes and Number of Establishments Excluded
      from Regulation at a Generator Limit of 1,000
      Kilograms Per Month                                        8-72
8-8   Estimated Change in Vehicular Emissions in 1984
      from Transport of Less Hazardous Industrial Wastes
      under Subtitle C Regulations                               8-88
8-9   Estimated Change in Fuel Consumption in 1984 from
      Transport of Less Hazardous Industrial Wastes under
      Subtitle C Regulations'                                    8-116
                        CONTENTS OF VOLUME II
C-l   Typical Waste Solvents Generated by the
      Pharmaceutical Industry                                     C-9
C-2   Typical Potentially Hazardous Wastes Generated
      During Pharmaceutical Active Ingredient Production         C-10
C-3   Selected Potentially Hazardous Waste Constituents
      from the Paint and Allied Products Industry                C-l4
C-4   Potentially Hazardous Components of Selected Waste
      Streams from the Organic Chemicals, Pesticides, and
      Explosives Industries                                      C-l8
C-5   Potentially Hazardous Waste Stream Components by
      Standard Industrial Classification, Organic
      Chemicals and Technical Pesticides Industries              C-21
C-6   Potentially Hazardous Constituents of Petroleum
      Refining Waste Streams                                     C-30
C-7   Potentially Hazardous Materials Contained in
      Petroleum Re-refining Sludge                               C-36
C-8   Potentially Hazardous Tannery Waste Constituents           C-38
C-9   Potentially Hazardous Waste Streams from Metal
      Smelting and Refining                                      C-40
C-10  Potentially Hazardous Waste Constituents Generated
      by Metal Smelting and Refining Industries                  C-42
C-ll  Typical Constituents of Potentially Hazardous
      Waste Streams in the Special Machinery Manufacturing
      Industries                                                 C-50

                                XXX

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                     LIST OF TABLES (Continued)
C-12  Potentially Hazardous Waste Streams from the Production
      of Storage Batteries                                       C-57
C-13  Potentially Hazardous Waste Streams from the
      Production of Primary Batteries                            C-59
D-l   Typical Hazardous Waste Handling Procedures for
      the Textiles Industry                                      D-29
D-2   Typical Hazardous Waste Handling Procedures for
      the Inorganic Chemicals Industry                           D-31
D-3   Typical Hazardous Waste Handling Procedures for
      the Pharmaceutical Industry                                0-34
D-4   Typical Hazardous Waste Handling Procedures for
      the Paint and Allied Products Industry and
      Contract Solvent Reclaiming Operations                     D-36
D-5   Typical Hazardous Waste Handling Procedures for
      the Organic Chemicals and Pesticides Industry              D-39
D-6   Percentage of Hazardous Wastes Treated/Disposed
      On-Site and Off-Site at Selected Organic Chemical
      Plants in 1973                                             0-43
D-7   Typical Hazardous Waste Handling Procedures for
      the Petroleum Refining Industry                            D-45
D-8   Estimate of the Percentage of Wastes Disposed/Treated
      On-site and Off-site by Petroleum Refinery
      in 1973 and 1983                                           D-49
D-9   Typical Hazardous Waste Handling Procedures for the
      Petroleum Rerefining Industry                              D-50
D-10  Percentage of Potentially Hazardous Waste Disposed
      On-site and Off-site or Recycled in 1975                   D-52
0-11  Typical Hazardous Waste Handling Procedures for the
      Leather Tanning and Finishing Industry                     D-53
D-l2  Typical Hazardous Waste Handling Procedures for the
      Metal Smelting and Refining Industry                       0-55
D-l3  Typical Hazardous Waste Handling Procedures for the
      Electroplating and Metal Finishing Industry                0-61
0-14  Typical Hazardous Waste Handling Procedures for the
      Special Machinery Industry                                 D-63
0-15  Typical Hazardous Waste Handling Procedures for the
      Electronic Components Industry                             0-65
D-l6  Typical Hazardous Waste Handling Procedures for the
      Storage and Primary Batteries Industries                   D-68
E-l   Relative Amount of Hazardous Wastes Transported Off-
      Site by Mode and Industry Segment                           E-4
E-2   Examples of Types of Vehicles Used by Generators Who
      Transport Wastes                                            E-6
E-3   Wastes Listed in the Hazardous Materials Table             E-l6

                                xxx i

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                     LIST OF TABLES (Continued)
E-4   Estimated Annual Carloads of Selected Potentially
      Hazardous Wastes Carried on Railroads in 1976              E-17
F-l   Summary of Technically Demonstrated Alternative
      Treatment Systems for Wastes Generated by the
      Inorganic Chemical Industries                               F-2
F-2   Cost Comparison of Resource Recovery Treatment
      Systems with Landfill Options for Wastes Generated by       F-5
      Inorganic Chemical Industries                               F-3
F-3   Summary of Alternative Treatment Systems for Waste
      Generated by the Organic Chemicals Industry                 F-5
F-4   Cost Comparison of Resource Recovery Treatment
      Systems with Landfill or Incineration Options for
      Wastes Generated by the Organic Chemicals, Pesticides
      and Explosives Industries                                   F-8
F-5   Summary of Alternative Treatment Systems for Waste
      Generated by the Metals Smelting and Refining
      Industries                                                  F-9
F-6   Cost Comparison of Resource Recovery Treatment Systems
      with Landfill Options for Wastes Generated by the
      Metal Smelting and Refining Industries                     F-l2
G-l   Comparison of Clearinghouses and Exchanges                  G-2
G-2   Approximate Quantities of Hazardous Waste Listed on
      the Iowa Industrial Waste Information Exchange in 1976
      and 1977                                                    G-6
H-l   Data Sources for Generation Factors                        H-14
H-2   Generation Factors for the Calculation of Estimated
      Quantities of Hazardous Waste Generated by Manufac-
      turing Industries (Based on Employment)                    H-16
H-3   Standard Industrial Classification Major Group 31 -
      Leather and Leather Products                               H-22
H-4   Summary of Hazardous Waste Generated by EPA Region —
      1975 (1000 Metric tons per year)                           H-24
1-1   Approximate Distribution of Hazardous Manufacturing
      Wastes Subject to Regulation in 1984 - Generation Limit
      100 kg/mo (All wastes in 1000'a of metric tons per
      year)                                                       1-5
1-2   Employee Ratios, 1975/1972                                 1-11
1-3   Ratio of total Employees by Interpolation to Given
      Total - 1972                                               1-12
1-4   Program Listing                                            1-16
K-l   United States Distribution of Manufacturing Firms by
      Size for Standard Industrial Classifications 20 -
      Food and Kindred Products                                   K-2
                                xxxii

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

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                     LIST OF TABLES (Concluded)
K-16  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      36 - Electric and Electronic Equipment                     K-17
K-17  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      37 - Transportation Equipment                              K-18
K-18  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      38 - Instruments and Related Products                      K-19
K-19  United States Distribution of Manufacturing Firms
      by Size for Standard Industrial Classification
      39 - Miscellaneous Manufacturing Industries                K-20
L-l   Compounds Identified in Groundwater from Landfill
      Well                                                        L-8
L-2   Range of Leachate Composition in 18 Sanitary Land-
      fills in the United States                                 L-10
M-l   Characteristics of Incineration of Selected
      Hazardous Wastes                                            M-5
M-2   Trace Metals on Particulate Filters from Test
      Incineration of Methyl Methacrylate Wastes                  M-6
M-3   Uncontrolled Emissions from Combustion of Selected
      Munitions in Rotary Kiln Incineration                      M-l2
M-4   Emission Rates from Open Burning of Selected
      Energetic Materials                                        M-l3
M-5   Detonation Products of Confined and Unconfined
      Explosions                                                 M-l4
M-6   Mass Spectrographic Analysis of Exhaust Gasses from
      Fluidized - Bed Incineration of Solvent Recovery
      Sludges from Paint Production                              M-l6
M-7   Analysis of Ash from Incinerated Solvent Recovery
      Still Bottoms at One Paint Production Facility             M-17
M-8   Ambient Air Concentrations of Lead Near Various
      Facilities Burning Waste Oil as Fuel                       M-19
                                xxxiv

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S.O  SUMMARY

S.I  Introduction

     The objectives of the Resource Conservation and Recovery Act of

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

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

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

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

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

consistent with these objectives.  Subtitle C also authorizes states

to implement their own hazardous waste management programs pursuant

to Subtitle C and directs EPA to promulgate guidelines to assist

states in the development of such authorized programs.

S.2  Description of the Baseline Action

     The baseline action is the set of regulations and guidelines

initially developed by the EPA in response to the mandate of the

following Sections of Subtitle C:

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

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

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

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

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

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     •  Authorized State Hazardous Waste Programs (Section 3006);

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

This Environmental Impact Statement (EIS) examines the potential

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

gulations and guidelines and from five regulatory alternatives.  The

specific regulations and guidelines being assessed in this EIS are

summarized below, and the five regulatory alternatives are summarized

in the following section.

     S.2.1  Identification and Listing of Hazardous Waste (Section

3001).  The Section 3001 baseline regulations define those wastes

that are to be considered hazardous and, therefore, subject to the

other Subtitle C regulations.  Two mechanisms are provided for

determining those wastes that are hazardous:  identifying character-

istics and lists of specific hazardous wastes and processes genera-

ting hazardous wastes.  Four identifying characteristics are

specified for determining whether a waste is hazardous:  ignitabil-

ity, corrosivity, reactivity, and toxicity.  Any waste which exhibits

any of these characteristics or which is listed (see Appendix B,

Subpart A), would be considered hazardous and would have to be

managed pursuant to the Subtitle C regulations.

     S.2.2  Standards Applicable to Generators of Hazardous Wastes

(Section 3002).  The Section 3002 baseline regulations establish

standards for manifesting and keeping records of hazardous wastes
                                     S-2

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shipped off the site of generation; for containerization of hazardous




wastes; for labeling, placarding, and marking of hazardous waste




shipments; and for reporting the disposition of hazardous wastes.



These standards would apply to those persons or Federal agencies,




except households, who generate and dispose more than 100 kilograms




(about 220 pounds) per month of wastes identified as hazardous under




the Section 3001 regulations.  Any person or Federal agency producing




and disposing 100 kilograms or less per month would not be required




to comply with the generator regulations.  Also any generator engaged



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




with the regulations only with regard to waste automotive oil; how-




ever, any person (e.g., a transporter) could assume a waste automo-




tive oil generator's total liability for compliance with the Section




3002 requirements, providing a written transfer of Liability Contract




is in effect.  Generators excluded from compliance with the Subtitle




C regulations would, however, still be obligated to dispose their




hazardous wastes in an acceptable manner, e.g., in a landfill that




meets RCRA Subtitle D criteria.



     S.2.3  Standards Applicable to Transporters of Hazardous Wastes




(Section 3003).  The Section 3003 baseline regulations establish




standards for the acceptance, loading, and stowing of hazardous



wastes; for compliance with the manifest system; for marking and




placarding of transport vehicles; for delivery of hazardous wastes;




and for reporting and cleaning up spills.  These standards would
                                     S-3

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apply to any person or Federal agency transporting, within the United




States, hazardous wastes that require a manifest under the generator




regulations and also apply to any transporter importing a shipment of



hazardous wastes from abroad.  Portions of the standards would also




apply to any transporter who consolidates and transports hazardous




wastes not requiring a manifest.  The transporter regulations would



not apply to persons or Federal agencies transporting hazardous




wastes solely on the site of generation or solely on the site of a




permitted hazardous waste management facility.



     S.2.4  Standards Applicable to Owners and Operators of Hazardous




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




The Section 3004 baseline regulations establish standards for protec-




tion of air quality, groundwater quality, and surface water quality;




for general facility practices and procedures including site selec-




tion, financial requirements, training, emergency preparedness,



monitoring, recordkeeping, reporting, and closure; for storage opera-




tions; for treatment/disposal operations including landfills, incin-




erators, surface impoundments, and landfarras; and for management of




'special wastes' (i.e., cement kiln dusts, utility wastes, oil dril-




ling muds/ brines, phosphate rock mining and processing wastes,




uranium mining wastes, and other mining wastes).



     These standards apply to owners and operators of any facility




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




as hazardous under the Section 3001 regulations, except 'special




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





                                     S-4

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




to comply only with specified general facility standards.  The




Section 3004 standards do not apply to on-site waste accumulation by



generators who store their own wastes for less than 90 days prior to




subsequent transport off-site, but do apply to any such on-site stor-




age which lasts for 90 days or longer.




     Certain practices that are controlled under other Federal acts




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




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




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




charges under a National Pollution Discharge Elimination System




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




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




vessels.  However the treatment, storage, and disposal regulations




would apply to above ground storage or treatment of hazardous wastes




prior to underground injection, on-shore facilities associated with




ocean dumping activities, and surface impoundments associated with




NPDES permitted industrial wastewater treatment facilities and




hazardous sludges from such facilities.




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




Waste (Section 3005).  The Section 3005 baseline regulations require



that all owners or operators of facilities treating, storing, or




disposing hazardous wastes obtain a permit prior to facility con-




struction, modification, or operation.  The regulations establish






                                    S-5

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standards for permit applications, permit issuance, and permit revo-




cation.  Permits would be issued for the projected life of the




facility.  The owners/ operators of new facilities would be required



to obtain permits prior to construction, and would have to certify




that construction was performed in compliance with the permit before




commencing operation.  Special permits would be available for experi-




mental facilities, qualified hospital and medical care facilities,




POTW's, and ocean dumping barges and vessels.  Standards would be




established for including public participation in the permit review




process.



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




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




authorization to administer and enforce their own hazardous waste




program pursuant to Subtitle C.  Under the baseline regulations there




would be three types of authorization for which states could apply:



full authorization, partial authorization, or interim authorization.




     Full authorization would allow a state to carry out a hazardous




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




tial authorization would allow a state to administer and enforce




selected components of a hazardous waste regulatory program estab-




lished pursuant to Subtitle C.  EPA would retain responsibility for




the remaining components of the program.  States would be considered




for partial authorization only if state legislative authority did




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



combination of the state and Federal program would have to meet the





                                   S-6

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requirements of a fully authorized program.  Partial authorization




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




newed .




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




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




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



after the date of promulgation of regulations under Section 3001.




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




orderly transition from its present program to a program eligible for




full authorization.




     S.2.7  Preliminary Notification of Hazardous Waste Activities




(Section 3010).  The Section 3010 baseline regulations require that



any person generating or transporting hazardous wastes or owning or




operating a facility for treatment, storage, or disposal of hazardous




wastes notify the EPA Administrator of such activity not later than




90 days after promulgation of regulations under Section 3001.




Section 3010 specifies in detail who would have to file notification




of hazardous waste activity, when and where such notification would




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




in the notification.




S.3  Description of the Reasonable Alternatives



     During the overall development of both the proposed regulations




and the final Phase I regulations, numerous alternative regulations




and regulatory approaches have been considered.  Both the baseline




regulations and subsequent versions of the regulations were selected





                                   S-7

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from among the many options initially considered based upon techni-
cal, environmental, institutional, economic, and legal considera-
tions.  Because of the enormous number of ways in which these various
options could be structured into alternative sets of regulations, the
approach taken in this EIS is to select and to develop a manageable
set of meaningful alternatives that reasonably bracket the overall
objectives and the resultant impacts anticipated from the regulations
that are ultimately to be promulgated under Subtitle C.  With this
approach it is possible to show the types of potential impacts that
could result under various alternatives without having to explicitly
consider the almost infinite variety of options for accomplishing the
same or intermediate objectives.
     Five different sets of alternatives, with respect to the base-
line regulations, have been selected and structured to reasonably
bracket the potential impacts that could be expected to result.
These alternatives are as follows:
                      <
     •  No Action;
     •  Phasing of Generators;
     •  Enhanced Public Health and Environmental Protection;
     •  Lesser Degree of Public Health and Environmental Protection;
     •  Phase I Alternative.
     S.3.1  No Action.  The No Action alternative has been selected
for the purpose of analyzing the potential impacts that could result
from taking no action, i.e., not promulgating regulations for Sub-
title C.  For reasons discussed in Chapter 4, the No Action

                                    S-8

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




be implemented and that hazardous waste management would continue as




currently practiced.




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




native has been selected for the purpose of analyzing the potential




changes in impacts that could result from the phasing of levels for



standards and criteria established by the regulations to their pro-



posed values over a period of time, rather than from initially set-




ting them at their proposed values.  For purposes of analysis, a




five-year time frame measured from the initial implementation date,




is assumed for the phasing of the more stringent levels.




     While there are many different ways in which the more stringent




levels for promulgated standards and criteria could be phased in,




most would have essentially the same effect—a gradual expansion of




the total quantity of hazardous wastes being controlled by the haz-



ardous waste program.  For purposes of analysis, the method selected




emphasizes increasing the quantity of wastes controlled during the




first 5 years following promulgation of the regulations by gradually




expanding the number of generators brought under control.  With this




approach, the level of the generator limit established under Section




3002 of the baseline regulations is to be reduced annually over a



five-year period of time in order to bring the larger generators into




the program first and the smaller generators into the program later.




Furthermore, the generator limit is to be reduced so that equal




amounts of hazardous wastes are annually brought under the programs's




                                    S-9

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control over the five-year period, i.e., 20 percent of the total




industrial hazardous wastes per year.




     S.3.3  Enhanced Public Health and Environmental Protection.  The



Enhanced Public Health and Environmental Protection alternative has




been selected for the purpose of analyzing the potential change in




impacts that could result from modifications to the baseline Subtitle




C regulations designed to further increase public health and environ-




mental protection even above that level afforded by the baseline




regulations.



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




tion of hazardous waste in order to bring additional wastes under




control of the program; to remove exclusions provided for hazardous



waste generators; to apply even more stringent design and operational




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




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




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




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




permits and impose additional restrictions on obtaining permits.



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




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




tion alternative has been selected for the purpose of analyzing the



potential changes in impacts that could result from modifications to




the baseline Subtitle C regulations designed to provide a lesser




degree of public health and environmental protection than that




afforded by the baseline regulations.




                                    S-10

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




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




control of the program; to increase exclusions provided for hazardous




waste generators; to reduce manifest requirements; to apply less




stringent design and operational requirements for storers, treaters,




and disposers; to eliminate any regulation of 'special wastes'; to




decrease recordkeeping times for generators, transporters, storers,




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




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




restrictions on interim authorization; and to ease restrictions on




full and partial authorization.




     S.3.5  Phase I Alternative.  The Phase I alternative contains




the set of non-technical modifications that are being considered for




inclusion in the final Phase I Subtitle C regulations.  The Phase I




Alternative has been included for the purpose of analyzing the




potential change in impacts that could result from modifications to




the baseline Subtitle C regulations which incorporate this specific




set of non-technical changes.




     Under this alternative, revisions have been made in  the mechan-




isms for identifying whether a waste is hazardous under Section 3001;




exclusions for hazardous waste generators have been modified; special




standards for  'special wastes' have been eliminated; Interim Status




standards have been added; permit requirements have been  modified;




reporting and recordkeeping requirements have been changed; General
                                S-ll

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Facility Standards have been extensively revised; and human health




and environmental standards have been eliminated.




S.4  Impacts of the Baseline Regulations



     The potential impacts, both beneficial and adverse, that could




result from implementation of the baseline Subtitle C regulations are




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



fied:  primary impacts and secondary impacts.  Primary impacts in-




clude those effects that would be directly attributable to the




implementation of the baseline regulations.  Secondary impacts



include those effects that would be indirectly attributable to the




implementation of the baseline regulations.  In some cases, secondary




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




implementation of the regulations.




     Potential impacts are analyzed for two separate years:  1980,




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



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




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




anticipated that at least five years would be required for such



effects and resultant impacts to become fully established.




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




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



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




tations noted in the text.  Because most available data relate to
                                   S-12

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manufacturing industries, the emphasis of the impact analysis is

necessarily directed toward manufacturing industries.

     Over 300 reported incidents of damage from the improper manage-

ment of hazardous wastes were reviewed to assist in identifying the

potential for beneficial impacts resulting from promulgation of the

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

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

incidents go unreported, especially human health incidents which may

require many years of exposure and for which direct causative

relationships are difficult to trace or establish.  The reported

incidents indicate that there is often a considerable time interval

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

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

reported incidents were discovered only after damage had already

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

similar damage incidents to be detected in the future from wastes

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

disposed.

     S.4.1  Potential Primary Impacts.  The potential primary impacts

from implementation of the baseline regulations fall into the follow-

ing areas:

     •  Hazardous wastes to be regulated;

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

     •  Administrative changes;

                                   S-13

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     •  Air impacts;




     •  Water impacts;




     •  Public health impacts.




     S.4.1.1  Hazardous Wastes to be Regulated.  Approximately 35




million metric tons of hazardous manufacturing wastes could be con-




trolled under the baseline Subtitle C regulations in 1980, and




approximately 40 million metric tons of hazardous wastes could be



controlled in 1984.  The wastes regulated would constitute slightly




over 10 percent of the total manufacturing wastes (hazardous and



non-hazardous) generated annually in the U.S.  The generator limit of




100 kilograms per month could exclude about 29,000 metric tons per




year of hazardous manufacturing wastes from regulation.  The excluded




wastes would represent less than 0.1 percent of the total hazardous




manufacturing wastes; approximately 26 percent of manufacturing




establishments generating hazardous wastes would be excluded, by this



generator Limit, from complying with the generator regulations.  In




addition to manufacturing wastes, an indeterminate portion of other




large volume wastes, such as waste automotive oil, coal ash, oil




drilling muds and brines, cement kiln dusts, phosphate mining and




processing wastes, and uranium mining wastes, could be more substan-




tially controlled under the regulations.



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




Treatment, and Disposal Practices and Procedures.  The baseline




Subtitle C regulations would lead to a number of major changes in






                                   S-14

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existing practices and procedures.  The changes would be caused by




the enactment of more stringent environmental requirements than those




that currently exist, resultant increases in treatment and disposal



costs, and specific procedural and operational requirements imposed




by the regulations.




     Generation.  The regulations would result in procedural changes




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




ing hazardous waste shipments and for preparing such shipments for




transport.  Every generator would be required to provide a manifest




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




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




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




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




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




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




reporting or recordkeeping requirements (although the facility itself




would be subject to reporting and recordkeeping requirements under




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




states would have to comply with the manifesting, recordkeeping, and




reporting requirements.  On-site shipments would not have to be mani-




fested, but would have to be sent to permitted on-site facilities and



would have to be reported to appropriate Federal or state authori-




ties.  All such hazardous waste shipments would have to be container-




ized, labeled, and placarded in accordance with Department of





                                   S-15

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Transportation (DOT) regulations.  Currently, very few shipments of




hazardous wastes are subject to such requirements.




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




to increase costs to generators and costs associated with hazardous




waste storage, treatment, and disposal, generators would have an




incentive to modify processes so as to reduce and/or change the types




and amounts of hazardous wastes generated, and to enable the in-



creased recycling of hazardous wastes as process feedstocks.




     Transport.  There are numerous reported instances of hazardous



waste transporters dumping wastes surreptitiously, rather than deliv-




ering the wastes to an environmentally acceptable storage, treatment,




or disposal facility.  The manifest and reporting requirements should




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




the regulations would impose requirements that all transportation-




related spills of hazardous wastes be reported immediately and be



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




and stowing hazardous waste shipments would potentially lead to fewer




accidents and spills from hazardous waste transport.  However, the




average distance over which hazardous wastes are transported would




likely increase as a result of the regulations.  Increased transport




distances would increase the potential for vehicular accidents.




Increased transport distances would also increase the potential for




spills, and this could off-set some of the benefits indicated above.
                                  S-16

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     Storage, Treatment, and Disposal.  A major impact resulting from




the Subtitle C regulations would be the closing of those hazardous




waste management facilities (both off-site and on-site) that could



not or would not comply with the storage, treatment, or disposal




requirements.  It would also lead to the modification of other




hazardous waste management facilities to enable compliance.  It is




expected that a large portion of existing facilities would require




modification in order to comply with the regulations.




     Those existing hazardous waste storage, treatment, and disposal




practices that are environmentally unacceptable according to the




baseline Subtitle C regulations would also be prohibited or restric-




ted or would have to be modified; some practices could be replaced by




other, more environmentally acceptable practices.




     Existing practices that are likely to be prohibited or severely




restricted by the baseline Subtitle C regulations include:  open



burning; uncontrolled incineration; road application of hazardous




waste oil; the use of landfills without leachate collection systems




and groundwater monitoring systems; the use of surface impoundments




without leachate detection systems and groundwater monitoring




systems; landfarming of highly volatile wastes; the location of land-




fills, surface impoundments, and landfarms within 150 meters (500



feet) of functioning public or private water supplies or livestock




water supplies; and the mixing of incompatible wastes in surface




impoundments and basins, except for the purpose of treatment.  In






                                   S-17

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addition, the Subtitle C regulations specifically prohibit such




existing practices as open dumping; the placing of reactive wastes,




ignitable wastes, and highly volatile wastes in landfills, surface




impoundments, or basins; the mixing of incompatible wastes in land-




fills and landfarms; the use of waste application practices that




allow the zone of incorporation of landfarms to become anaerobic; and




the use of continuous feed treatment facilities without automatic




waste feed cut-offs or by-pass systems that are activated when a




malfunction occurs.




     The baseline Subtitle C regulations also impose specific




requirements for the closure of treatment/disposal facilities.  For




example, at the time of closure, all disposal operations would have




to be completed and all wastes removed from storage and treatment




facilities for disposal in accordance with the regulations.  Hazard-




ous wastes and hazardous waste residue would also have to be removed




from all surface impoundments that do not meet the standards for




landfills and would have to be disposed in accordance with the regula-




tions.  Contaminated soil-filter medium at landfarms could also have




to be removed and disposed according to the regulations.  Monitoring




and maintenance care would have to be provided for a period that need




not exceed 20 years from closure.




     The baseline Subtitle C regulations would likely lead to changes




in the portion of hazardous wastes treated/disposed on-site by gener-




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






                                S-18

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discussed in Chapter 7, it is not possible to accurately determine




the extent of any shift that could occur under the baseline Subtitle




C regulations.  For purposes of analysis, a range of 13 to 25 percent



off-site treatment/disposal of hazardous manufacturing wastes in 1984




is used to assess potential impacts of a shift in off-site disposal.




     S.4.1.3  Administrative Changes.  Implementation of the baseline




Subtitle C regulations would necessitate a widesweeping series of



administrative changes that would affect industry, state governments,




and the Federal government.



     State Administration of Programs.  EPA staff estimates are that




approximately 34 states and territories could qualify for interim




authorization under the Subtitle C regulations.  No states are



believed to be currently able to qualify for full authorization.  No




states would be able to qualify for partial authorization before the




end of the interim authorization period.




     Although RCRA encourages states to administer their own author-




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




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




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




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




prohibit states without authorized programs from enacting and



enforcing their own more stringent or non-consistent hazardous waste




program to be run in the state in addition to the Federal program.




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






                                   S-19

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in addition Co the Federal program, or what regulations would be




promulgated under any such overlapping program.  Such additional




state programs, if enacted, would have the potential for creating



various impacts, including the imposition of conflicting and/or




duplicative requirements on hazardous waste generators, transporters,




storers, treaters, and disposers.




     Number of Generators Required to Comply with the Regulations.




It is estimated that on the order of 270,000 to 300,000 manufacturing




establishments, automotive service stations, hospitals, medical



laboratories, and research facilities could have to comply with the




generator regulations.  An indeterminable number of other potential




generators (e.g., 'special waste1 generators) could also have to



comply.




     Number of Storers, Treaters. and Disposers Required to Obtain




Permits.  It is estimated that on the order of 29,000 manufacturing



establishments, hospitals, Federal installations, and hazardous waste




management service industry facilities could be required to obtain




permits.  An indeterminable number of other storers, treaters, and




disposers could also be required to obtain permits.




     Paperwork Requirement Under the Regulations.  The potential gen-




erators and permitters identified above would initially have to file



about 270,000 to 300,000 notifications, under Section 3010, with EPA




or authorized states.  An indeterminable number of transporters and




other potential generators and permittees would also have to file






                                   S-20

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such notifications.  These permittees would also have to submit




approximately 29,000 permit applications and additional supplemental




material.



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




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




necessitating industrial generators to prepare between 350,000 and




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



and owners/operators of hazardous waste management facilities would




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



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




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




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




ceptable delivery documents in lieu of manifests, or use manifests




in lieu of existing delivery documents, this recordkeeping require-




ment would not constitute an additional burden on transporters.



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




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




facility, plus 3 years worth of specified records.



     It is estimated that generators and hazardous waste management




facilities could prepare upwards of 387,000 to 417,000 reports annu-




ally for submittal to permitting authorities.  Transporters could



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




reports are presently being filed by transporters under other acts.
                                   S-21

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      Most of this recordkeeping and reporting would represent addi-

tional requirements on generators and owners/operators of hazardous

waste management facilities, based upon the existing state

regulations.

     S.4.1.4  Air Quality.  Current hazardous waste generation,

transport, storage, treatment, and disposal practices involve a

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

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

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

ferent ways by the baseline Subtitle C regulations.  For the most

part, the regulations would lead to reduction in the release of air
                    »
contaminants and to resultant improvements in air quality.

     Generation.  Subtitle C regulations would not have a direct

effect on air emissions resulting from activities generating hazard-

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

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

fications engineered to recycle hazardous wastes or to reduce or

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

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

     Transport.  Current practices in the transport of hazardous

wastes have the potential to release air emissions in three major

ways:

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

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

                                   S-22

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

     Containerization requirements applied to both intrastate and

interstate shipments of hazardous wastes would reduce the potential

for fugitive emissions from the transport of hazardous wastes.

Requirements for the acceptance, loading, and stowing of hazardous

wastes, especially incompatible wastes or leaking containers, would

greatly reduce the potential for explosions and spills to occur from

hazardous waste transport.  Requirements for spill clean-up would

reduce the potential for the release of air emissions following

spills. Increased transport distances could result in increased vehi-

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

extremely small compared to total national vehicular emissions.

Increased transport distances would also increase the potential for

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

     Storage.  Current practices in the storage of hazardous wastes

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

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

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

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

     The regulations contain provisions that would reduce the poten-

tial for the release of air emissions from each of these sources.
                                   S-23

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Hazardous waste storage operations would have to be conducted in such

a manner that no discharge occurs; these storage operations would

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

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

release air emissions that could adversely affect human health or

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

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

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

potential for accidental releases to occur from improper storage.

Required spill containment measures and contingency plans could fur-

ther reduce the potential for accidental releases and the time neces-
                    w
sary to clean up any such accidental releases.  Hazardous wastes

would have to be removed from storage operations during facility

closure and be disposed in accordance with the regulations.

     Treatment/Disposal.  The major sources of air emissions from

current hazardous waste treatment/disposal practices are as follows:

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

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

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

     •  Fugitive emissions from other treatment facilities.

     The baseline Subtitle C regulations contain requirements that

should reduce the potential for fugitive emissions from the
                                   S-24

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land-based treatment/disposal of hazardous wastes.  For example,

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

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

landfills, surface impoundments, or basins; such wastes could be

landfarmed only if the facility owner/operator could demonstrate,

before landfarming the wastes, that the specified air contaminant

levels would not be violated.  With regard to wastes that are land-

filled, cover material would have to be applied daily on active

hazardous waste landfill cells.  At facility closure, a final cover

would have to be provided. Where gases are generated, a gas collec-

tion and control system would have to be installed in most instances
                    9
to control the vertical and horizontal escape of gases.

     The baseline Subtitle C regulations contain provisions that

should, to a large degree, reduce the potential for fires, explo-

sions, and other accidents at hazardous waste treatment/disposal

facilities.  The primary cause of most explosions and fires has been

the mixing of incompatible wastes and the improper treatment/disposal

of ignitable or reactive wastes.  The manifesting, labeling, waste

analysis, and training requirements would reduce the potential for

the improper management of such wastes.  Restrictions on the

treatment/disposal of incompatible, highly reactive, or ignitable

wastes and requirements for contingency plans and spill containment

measures would further reduce the potential for the release of air

emissions.
                                  S-25

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     The baseline Subtitle C regulations contain provisions that

should reduce the potential for the release of air contaminants from


the combustion of hazardous wastes.  The regulations would require

the use of controls for almost all combustion of hazardous wastes and


would set design and operational standards.  Open burning of hazard-


ous wastes would be prohibited in most instances.  All facilities

would also be required to comply with all applicable standards of the

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


     The regulations would also set specific standards for the incin-

eration of hazardous wastes.  Incinerators would also have to be

designed, constructed, and operated such that fugitive emissions of

                    f
unburned hazardous wastes and combustion products are controlled and

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

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


water pressure.

     The baseline Subtitle C regulations contain provisions that

should reduce the potential for fugitive emissions from other hazard-

ous waste treatment facilities (e.g., biological, physical, and chem-

ical treatment facilities).  Fugitive emissions would be controlled,


for the most part, by the regulatory provisions previously discussed.


     To the extent that the baseline Subtitle C regulations result in

modifications to or construction of additional hazardous waste stor-


age, transportation, disposal, or  treatment facilities, there would


be an increase in construction-related air emissions.  The major
                                   S-26

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emissions would include exhaust from motor vehicles, including con-

struction equipment, and fugitive dust raised by such construction

activities as grading, excavation, and movement of equipment.

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

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

additional wastes under the regulations as compared to the unregu-

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

quantities of air emissions generated from the management of specific

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

particular waste would result in the increased release of combustion

products and the reduc.ed release of particulate matter and/or vola-
                    »
tile gases.  Such shifts could, to an indeterminable extent, either

enhance or reduce the potential for indicated reductions in specific

air emissions.  Furthermore, the construction of new facilities could

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

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

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

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

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

air contaminants from hazardous waste management, and a localized

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

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

under the regulations, there could also be some localized degradation

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



                                   S-27

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



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




and Subtitle C standards).



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




current hazardous waste management practices through spills; runoff




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




ing or treatment facilities; or through discharges of contaminated




groundwaters.  Groundwater contamination may result from infiltration




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



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




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




from poorly sealed or unlined waste impoundments, or from injection




of wastes into aquifers.




     The baseline Subtitle C regulations would potentially result in




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



marily through containerization requirements.  However, any shift to




off-site treatment or disposal would necessitate more handling and




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




the potential for a decrease in hazardous spills.  Similarly, any




increases in the quantity of hazardous waste transported by barge




could increase the potential for spills directly into surface waters.




The regulations would, however, provide for more rapid notification




of authorities and for rapid initiation of clean-up procedures fol-




lowing spills.
                                   S-28

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     The baseline Subtitle C regulations would result in a consider-

able reduction in other surface releases of hazardous wastes.  The

regulations would require all generators to store, treat, and dispose

their hazardous wastes in permitted facilities.  All owners/operators

of such facilities would be required to construct and maintain

diversion structures to prevent surface runoff from entering active

portions of facilities and to collect any runoff or other discharges

originating on the active portions.  All discharges from the

facilities would have to be confined to point sources which comply

with the regulations promulgated under the Clean Water Act.  Storage

facilities would be prohibited from making any discharges.  These
                    9
regulations would constitute a substantial improvement over the

present unregulated situation and should produce a decrease in the

number of surface water pollution incidents resulting from hazardous

wastes.

     Since there are no estimates of the extent of existing

groundwater contamination due to hazardous wastes, it is not possible

to quantify the improvements that would result from the regulations.

However, numerous incidents of severe groundwater contamination have

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

regulations.  Although the regulations would not address the closure

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

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

ments designed to ensure that no contamination of any underground
                                  S-29

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




after the regulations are promulgated.




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



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




lation by this alternative.  As previously discussed, such shifts




could result in localized changes in the release of specific water




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




quality.




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




incidents that have resulted from the improper management of hazard-




ous wastes.  This improper management resulted in 49 separate




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




instances of drinking water contamination, including contamination of




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




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



incidents go unreported, especially human health incidents which may




require many years of exposure, and for which direct causative




relationships are difficult to trace or establish.  The reported




incidents indicate that there is often a considerable time lag




between the occurrence of those events which lead to public health




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



tually all of the reported incidents were discovered only after




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




potential for many similar public health impacts to be detected from
                                  S-30

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wastes that have already been, or currently are being improperly

transported, stored, treated, or disposed.

     The baseline Subtitle C regulations should significantly reduce

the potential for such public health impacts to occur from future

management of hazardous wastes.  The regulations would reduce the

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

hazardous waste management and, thus, for resultant public health

impacts.  Furthermore, requirement for recording where hazardous

wastes are disposed and prohibitions against using such sites for

residential or agricultural purposes could prevent future public

health catastrophes, such as that which occurred at Love Canal in
                    »
Niagara Falls, New York (see Section 7.1.6).

     S.4.2  Potential Secondary Impacts.  The potential secondary

impacts from implementation of the proposed regulations include

impacts to the following areas:

     •  Physiography and soils;

     •  Biological environment;

     •  Water use;

     •  Hazardous waste management facility capacity;

     •  Land use;

     •  Social impacts;

     •  Resource conservation and recovery;

     •  Energy use;

     •  Special interest points.
                                   S-31

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




ronmental concern regarding physiography and soils are soil contami-




nation, alterations of topography, and loss and physical disruption



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




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




The manifest system and permit requirements would eliminate most




irresponsible disposal of these wastes.  The closure of existing




sites which do not meet the proposed standards would result in




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




significant volumes of clayey soils would have to be acquired and




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




in alterations of topography.  Creation of new disposal sites could




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



tamination would occur in a controlled manner and would be localized




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




     S.4.2.2  Biological Environment.  The major routes of hazardous




waste transport to, and subsequent impact upon biological systems are




by:  groundwater contamination via leaching, surface water contam-




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




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




regulations would substantially reduce improper transport, storage,



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




containment and long-term separation of these wastes from biological




systems.  Although the impact of the regulations cannot be
                                   S-32

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quantified, many of the types of incidents of contamination and asso-

ciated biological effects which have been observed in the past would


be prevented by promulgation of the regulations.  In general, biolo-

gical impacts due to contact with regulated wastes or from fires or


explosions involving regulated wastes would be greatly reduced, while


other impacts would be reduced in proportion to the reduction of air,


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


necessitate the pre-emption of land from existing uses.  Although


siting restrictions would protect wetlands and critical habitats of

endangered species, construction of disposal facilities in remote

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

                    t
or domesticated animals.

     S.4.2.3  Social Impacts.


     Demographic Impacts.  Promulgation of the Subtitle C regulations


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

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


ganic chemicals industry, organic chemicals industry, metals smelting


and refining industry, electroplating and metal finishing industry).

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

relocations of some of the affected workers and their families.


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

or areas for which plants being closed constituted the primary source


of employment.
                                  S-33

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     Operational requirements for hazardous waste management, under




the baseline Subtitle C regulations, would likely result in addition-




al workers being required to track the hazardous wastes; to transport



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




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




and enforce the regulations at both the state and Federal levels.




Construction workers would also be required for necessary modifi-




cations to existing facilities or construction of new facilities.  It




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



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




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




be new workers due to the Subtitle C regulations.




     Some populations shifts could occur if the required number of




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




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



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




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




relatively large influx of workers.




     Social Conditions.  Impacts to existing social conditions could




result from changes in the siting and operation of hazardous waste




management facilities and from any population shifts caused by the



regulations.  The increased public health protection that would be




derived from the regulations would provide significant social




benefits.  Many of the social costs related to the exposure of
                                  S-34

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

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

     The regulations, while not applying to household wastes, could

also focus more public attention on the problems associated with the

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

increased care in the disposal of hazardous wastes and a further

reduction in public health impacts from such disposal.

     On the other hand, an increased public awareness of problems

that have been associated with improper disposal of hazardous wastes

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

hazardous waste management facilities.  However, in the long-term,
                    r
promulgation of the regulations, accompanied by increased public

participation in the facility siting process and specific demonstra-

tions that the objectives of the regulations can be achieved, could

also serve to lessen such opposition in the future and could lead to

more effective siting of facilities.

     Social impacts could also result from the expansion of construc-

tion of hazardous waste management facilities and from any increase

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

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

aesthetic impacts and could result in localized noise impacts, both

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

     Shifts in population that may result from the baseline Subtitle

C regulations would have the potential to cause social impacts.  The



                                  S-35

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magnitude of any such impacts would be site-specific and would depend


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


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


existing infrastructure in the affected areas, and the adequacy of


advanced planning.


     S.4.2.4  Hazardous Waste Management Facility Capacity.  It is


estimated that there would potentially be sufficient process capa-


city, on a nationwide basis, to manage hazardous industrial wastes


shipped off-site in 1980.  In the case of 13 percent off-site ship-


ment, there would potentially be sufficient process capacity on a


nationwide basis to manage hazardous industrial wastes shipped off-

                     t
site in 1984.  In the case of 25 percent off-site shipment, there


would potentially be a nationwide shortfall of 2.6 million metric


tons of environmentally adequate off-site capacity for treating/


disposing hazardous industrial wastes in 1984; without any growth in

existing, environmentally adequate, capacity, this nationwide short-


fall could be 4.9 million metric tons.  Approximately 45 additional


off-site facilities could be required to handle hazardous industrial


waste by 1984 in the former case and approximately 80 additional off-


site facilities could be required in the latter case.  Data are not


available to estimate if there would be any potential shortfall in


environmentally adequate, on-site, hazardous waste management process


capacity under the Subtitle C regulations.


     Even in those instances where sufficient capacity is estimated


to be available on a nationwide basis, regional, statewide, or


                                  S-36

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localized shortfalls of capacity would be very likely to occur as dis-


cussed in Chapter 7.  Furthermore, treatment/disposal of hazardous


non-manufacturing wastes could create shortfalls or exacerbate


existing shortfalls.


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


site, would be required for environmentally adequate hazardous waste


management under the baseline Subtitle C regulations than for hazard-


ous waste management under current practices.  The additional land


necessary for the environmentally adequate management of hazardous


waste would be required, both for the construction of permitted


facilities necessary to meet any additional capacity shortfalls that

                    t
could occur under the Subtitle C regulations, and for such conjunc-


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


lines.  However, while more total land would be required, in the case


of 13 percent off-site shipment, there could be less off-site land


use and more on-site land use for hazardous industrial wastes by 1984


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


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


use for hazardous industrial waste by 1984 than under current


practices.


     Existing land uses would cease, either permanently or temporari-

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


lowing closure of the hazardous waste management facility and rehab-


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



                                  S-37

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

existing uses.  Sites from which hazardous wastes have not been

removed would be precluded from residential and agricultural uses,

and may be precluded from some recreational and grazing uses follow-

ing closure.  Any activity requiring excavation would also be prohi-

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

regulations would require records to be kept of the location and

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

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

Falls, New York, would be reduced.

     To the extent that the regulations would prevent other lands
                    f
from being contaminated by improper disposal, dumping, storage, or

treatment under current practices and regulations, there would be a

potential for offsetting land use benefits.

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

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

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

resulted in a decreased supply of surface water or groundwater being

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

be an additional supply of groundwater or surface water potentially

available to such consumers and fewer restrictions on the productive

use of such surface water and groundwater supplies.  New facilities

would, however, be additional consumers of water.
                                    S-38

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




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




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




age, treatment, and disposal, the regulations would provide an incen-




tive for generators to modify processes so as to enable increased




recycling of hazardous wastes as process feedstocks, to reduce the




quantities of hazardous wastes generated by specific processes, or to




alter the nature of the wastes generated.  Any changes would be




extremely waste stream and process-specific.  Furthermore, since the



regulations prohibit the placing of ignitable wastes in landfills,




landfarms, surface impoundments, and basins, the potential for in-




creased incineration of such wastes, with possible energy recovery,



would be greatly enhanced.




     S.4.2.8  Energy Use.  The facility modification and construction




that would be necessary under the regulations would result in



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




construction of new facilities under the regulations than would have




otherwise been needed due to requirements directed toward making




these facilities more environmentally secure.  Increased energy use




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




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




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




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




tional energy, energy savings from increase energy recovery,  from







                                  S-39

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further reduction in the quantities of wastes requiring storage,




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




result in an overall energy savings from resource recovery



operations.




     The changes in energy use from the transport of hazardous wastes




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




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




estimated change in annual energy use in 1984 ranges from a decrease




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




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




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




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




site treatment/disposal.




     The regulations could also potentially have an impact on energy




production.  The requirements and their resultant costs could poten-




tially result in the closure of or reduced production at some energy




producing operations.  The regulations could also potentially lead




some facilities to change the fuels they use so as to reduce or elim-




inate the generation of hazardous waste.




     S.4.2.9  Impacts to Special Interest Points.  The baseline




Subtitle C regulations contain provisions which, while not applying




specifically to the protection of special interest points, would




provide indirect benefits to special interest points and to the human




enjoyment of such features.  For example, restrictions on the siting
                                  S-40

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of hazardous waste management facilities in wetlands and critical



habitats would reduce the potential for adverse impacts to such




areas.  Furthermore, provisions that would potentially reduce the



release of air, water, and soil contaminants from hazardous wastes




management activities would reduce the potential for these contami-




nants to infringe upon special interest points and would increase, or




at least maintain, the opportunity for human enjoyment of such spe-




cial interest points.  However, to the extent that additional lands




would be disturbed by facility construction and operation and by



conjunctive developments, there would be an increased potential for




some infringement upon other special interest points.




S.5  Impacts of the Alternatives



     This section summarizes the potential changes in impacts, rela-




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




mentation of each alternative.  Impacts that would be substantially



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




order to avoid duplication.




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




mandated by an act of Congress, implementation of this alternative is




not considered to be feasible without an additional act of Congress




repealing RCRA.  However, if implemented, this alternative would



result in a continuation of current hazardous waste management prac-




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




ed by individual states.
                                   S-41

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     The overall control of hazardous wastes would be much less




effective than with a national program.  The public health and




environmental problems previously discussed would continue to occur,



though they could be mitigated by the enactment of more stringent




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




significantly less stringent regulations than it would have under the



Federal program, there could be a significant increase in public




health and environmental problems relative to those that would occur




under the Subtitle C regulations.  Impacts could also extend to




neighboring states.




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




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




industrial wastes could be excluded from regulation during the first




four years following implementation of the Subtitle C regulations.




This would be about a 50 percent reduction in regulated hazardous



industrial wastes during this period, as compared to the baseline




regulations.  There would be no change in wastes regulated after the




first four years.




     During the first year, regulatory control would essentially be




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




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



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




controlled wastes being generated within SIC Code 28.  While wastes




would be regulated within all EPA Regions, Regions III, IV, and V
                                  S-42

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



mately 230 manufacturing establishments could be regulated nation-




wide.




     During the second year, regulatory control would be extended to




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




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




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




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




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



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




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




lishments would be regulated nationwide.



     During the third year, regulatory control would be extended to




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




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




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




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




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



4,300 manufacturing establishments would be regulated nationwide.




     During the fourth year, regulatory control would be extended to




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



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




Publishing).  The distribution of regulated wastes among the EPA




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







                                   S-43

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Approximately 15,500 manufacturing establishments could be regulated

nationwide.

     A major benefit resulting from this alternative would be the

gradual expansion of administrative requirements, rather than the

abrupt imposition of such requirements.  Administrative requirements,

primarily paperwork, would be reduced during the first four years

following implementation of the regulations.  There could be a 50

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

submittal of annual reports during this period, compared to the

baseline regulations.  Reduction in administrative requirements could

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

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

creased opportunity for planning and instituting measures to mitigate

the potential impacts of any population shifts or of any shortfalls

in hazardous waste management facility capacity.

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

dustrial wastes excluded from the generator regulations, under this

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

required under the baseline Subtitle C regulations, there would be an

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

nants from these wastes.*  Changes in public health and
*It should be noted that as discussed in Section 7.1.2, it is
 expected that at least 5 years would be necessary to act upon and to
 issue all permits under the proposed regulations.  Thus, some inde-
 terminable portion of the 74 million metric tons of hazardous waste
 excluded under this alternative might not be managed under the
 baseline regulations as adequately as would be required following
 issuance of a permit.

                                   S-44

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environmental effects would be directly related to changes in the


release of air, water, and soil contaminants.  To 'the extent that


increased releases were to occur, there would be an increased poten-


tial for the occurrence of adverse public health and environmental


impacts.  Both chronic health effects, related to long-term, low-


level exposure to such contaminants, and water quality impacts could


continue for many years following improper disposal of such wastes.


     S.5.3  Enhanced Public Health and Environmental Protection


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


alternative, compared to the baseline regulations.  These and other


major changes are discussed below.


     S.5.3.1  Primary Impacts.


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


mately 57 and 65 million metric tons of hazardous manufacturing


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


respectively.  This would represent about a 63 percent increase in


the hazardous industrial wastes controlled in both these years.


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


increase in hazardous non-manufacturing wastes regulated under this


alternative.
                                                           i

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


sal Practices.  Additional changes to generation, transport, storage,


treatment, and disposal practices, similar to those discussed for the


baseline regulations, would be likely to occur under this alternative
                                   S-45

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                                             TABLE S-l

     COMPARISON OF  POTENTIAL  IMPACTS  OF THE BASELINE  REGULATIONS  AND
            THE PHASE I AND THE ENHANCED  AND  THE  LESSER  DEGREE  OF
         PUBLIC  HEALTH AND ENVIRONMENTAL PROTECTION  ALTERNATIVES*
Impact
area
Regulated manufacturing
wasces - 1984
Baseline
regulations
40 million
metric tons
Enhanced
protection
alternative
65 million
metric tons
Lesser degree
of protection
alternative
26 million
metric tons
Phase I
alternative
*40 million
metric tona
Regulated non-manufacturing
wastes

Number of identifiable
regulated generators

Number of identifiable
regulated storers, treaters,
and disposers

Number of manifests
prepared annually - 1984

Number of reports
submitted annually

Number of workers required
to store, treat, or dispose
regulated manufacturing
wastes - 1984

Off-site process capacity
shortfall on nationwide
basis for hazardous
manufacturing wastes

     1930
    1984
      13Z off-site shipment
      25Z off-site shipment
Change in annual off-site
landfill requirements for
regulated manufacturing
wastes after 1984t

      13Z off-site  shipment

      25Z off-site  shipment
Potentially         Potentially large
large quantities     quantities
270,000-300,000


29.000
                  i2.2 million


                   not deteminable
350,000-690,000     580,000-1,100.000


390,000-420,000     3.9 million


20,000              33,000
Potentially         Potentially
small  quantities     large quantities!

110,000-140,000           «


not deteminable     t29,000



200,000-420,000           t


140,000-170,000     250.000-280.000


12,000                   t
2.6 million metric
tons (approximately
45 additional
facilities)
                                               2.7 million metric
                                               tons (approximately
                                               45 additional facilities)
                   0.9 million metric
                   tons (no additional
                   facilities)

                   9.6 million metric
                   tons (approximately
                   160 additional facilities)
-160 to -320 acres   -260 to -520 acres
800 to 1,600 acres   1,300 to 2,600 acres
                                            -95 to -190 acres

                                            500 to 1,000 acres
*Based upon methodologies and assumptions described in Chapters 7 and 8.

tlhere would be commensurate changes In on-slte landfill requirements.

TNot deteminable,  but expected to be on the order of the quantity estimated for the baseline  regulations.
IMosc special wastes subject to full set of regulations.
1110,000-140,000 for first 2 to 5 years; then 220,000-250,000.
                                                 S-46

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due to the additional wastes being regulated; due to the additional



generators, transporters, and owners/operators of hazardous waste




management facilities being regulated; due to the enactment of more



stringent environmental requirements; due to resultant increases in




storage, treatment, and disposal costs; and due to the imposition of




additional procedural and operational requirements.




     Administrative Changes.  Several changes in the administration



of hazardous waste management programs would result from promulgation




of the regulations within this alternative.  It is likely that fewer



states would apply for authorization under this alternative because




expansion of both the quantity of hazardous wastes and the number of




generators, transporters, storers, treaters, and disposers being




regulated, plus the increases in reporting frequencies, would lead to




increased administrative and manpower requirements for authorized




states.




     It is estimated that on the order of 2.2 million manufacturing




establishments, automotive service stations, hospitals, medical




laboratories, research facilities, farmers, and dry cleaning estab-




lishments could have to comply with the generator regulations under




this alternative.  This would represent over a 700 percent increase




in the number of generators being regulated, compared to the baseline



regulations.  It is expected, however, that there would be only a




relatively small increase in the number of permittees under this




alternative.
                                  S-47

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     It is estimated that the industrial generators could have to



prepare between 580,000 and 1.1 million manifests annually by 1984.




Based upon this number of manifests, the aggregated generators,



transporters, and hazardous waste management facility owner/operators




could each have to keep between 1.7 million and 3.4 million manifests




in storage on an annual basis.  This would represent over a 60 per-




cent increase in both requirements, as compared to the proposed




regulations.  It is estimated that generators and permittees could




prepare upward of 8.9 million quarterly reports on an annual basis—




over a 2,100 percent increase.




     The identified generators and permittees would have to file over




2.2 million notifications under Section 3010—about a 700 percent




increase.  Furthermore, since potential permittees would have to




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




for the projected life of the facility as under the proposed regula-



tions, there could be up to a six-fold increase (in the case of a




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




ing permits.  These potential permittees would also have to prepare




approximately 29,000 Supplemental Environmental Analyses as part of




the initial permit review procedure; these Supplemental Environmental




Analyses would not be required under the baseline regulations.



     Air and Water Quality.  The regulations under this alternative




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




tions, in the release of air emissions and water effluents from the
                                   S-48

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




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




the requirements under this alternative would cause further changes




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




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




generators to make process modifications designed to further increase




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




hazardous wastes generated; any such process modifications would




likely lead to changes in air emissions and water effluents released




by processes generating hazardous wastes.  Furthermore, to the extent




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




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




mination of exclusions, the potential for such process modifications




and resultant changes in air emissions and water effluents would be




increased.




     The additional 25 million metric tons of potentially hazardous




industrial wastes (plus other hazardous wastes) estimated to be




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




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




in accordance with the Subtitle C regulations.  Since most of these




wastes would otherwise have been transported, stored, treated, or




disposed by methods that are not likely to be environmentally accept-




able under the Subtitle C regulations, the overall potential for
                               S-49

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the release of hazardous air emissions or water effluents from the




management of such additional wastes would be reduced.




     Additional requirements imposed by this alternative would fur-



ther reduce the potential for the release of air and water contami-




nants from the management of both the additional 25 million metric




tons of hazardous industrial wastes controlled under this alterna-




tive, and the 40 million metric tons also controlled under the base-




line regulations.  The major impact, with regard to air quality,




would result from changing the application of the Threshold Limit



Values (TLV) from an air human health and environmental standard to a




mandatory standard with which facilities must always be in compli-




ance, and the imposition of the TLV's as a maximum concentration not



to be exceeded at any time, rather than as a time-weighted average




not to be exceeded over an 8-hour day and 40-hour week.  The major




impact, with regard to water quality, would result from requiring



lower permeabilities for soil liners for landfills and surface




impoundments.




     To the extent that additional storage, treatment, or disposal




facilities would have to be modified or would have to be constructed




under this alternative, there would be an increase in fugitive dust,




vehicular emissions, and runoff from such construction activities.



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




types of methods used to treat/dispose the additional wastes




regulated under this alternative, compared to the unregulated methods
                                  S-50

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




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




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




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




wide increase in the total releases of other air and water contami-




nants.  Thus, while there would most likely be improvements in air




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




localized degradation of air and water quality.  All releases and any




localized degradation of air or water quality would, however, have to




be in compliance with all applicable requirements (e.g., Clean Air




Act, Clean Water Act, OSHA standards, state standards, and Subtitle C



standards).




     Public Health.  The regulations under this alternative would




have the potential for further increasing the public health benefits




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




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




contaminants from hazardous waste management and, thus, for resultant




public health impacts.  Furthermore, since most of the additional




wastes to be regulated under this alternative would be potentially




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




significant reductions in chronic health effects related to long-




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




disposal of such wastes.




     S.5.3.2  Secondary Impacts.  The major changes in secondary




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



                                S-51

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




lion metric tons of potentially hazardous industrial wastes, plus




other hazardous wastes; the enactment of more stringent environmental




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




posal of hazardous wastes; and resultant increases in hazardous




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




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




soil contaminants, there would be further beneficial impacts to the




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




interest points, as compared to the baseline regulations.




     The above changes would also provide increased incentives for




generators to modify processes so as to enable increased recycling of




hazardous waste as process feedstocks, to reduce the quantities of




hazardous wastes generated by specific processes, or to change the




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




by the additional facility modification and construction required




under this alternative, by required changes in facility operation and




closure, and by any increases in hazardous waste transport.  Changes




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




cluding additional savings in energy use.  There could also be




increased reductions in energy production due to increased costs of




waste disposal and to the elimination of special standards for 'spe-




cial wastes'; many 'special wastes' are generated by energy produc-




tion activities.
                                S-52

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     Additional industrial plant closings or relocations due to the




increased costs, under this alternative, could lead to additional




population shifts and resultant impacts.  Additional workers would



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




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




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




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



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




compared to the baseline regulations.  Additional population shifts



could occur in response to the increased personnel requirements; any




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




there could be localized instances of a relatively large influx or



out flux of workers.



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




tially be a nationwide shortfall of 2.7 million metric tons of envi-




ronmentally adequate off-site capacity for hazardous industrial




wastes in 1980; without any growth in existing, environmentally




adequate, off-site capacity, this nationwide shortfall could be 4.2



metric tons.  Approximately 45 additional permitted off-site facili-




ties could be required to handle hazardous industrial waste in 1980




in the former case and approximately 70 additional permitted off-site



facilities could be required in the latter case, compared to the




baseline regulations.  In the case of 13 percent off-site shipment,




there could potentially be a nationwide shortfall of 0.9 million






                                   S-53

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metric tons of environmentally adequate off-site capacity for hazard-



ous industrial waste in 1984; without any growth in existing, envi-




ronmentally adequate, off-site capacity, this nationwide shortfall



could be 3.2 million metric tons.  Since less capacity would be re-




quired in 1984 than in 1980 in the case of 13 percent off-site ship-




ment, no additional permitted off-site facilities could be required




to handle hazardous industrial wastes in 1984.  In the case of 25




percent off-site shipment, there could potentially be a nationwide




shortfall of 9.6 million metric tons of environmentally adequate off-




site capacity for hazardous industrial wastes in 1984; without any




growth in existing, environmentally adequate, off-site capacity, this




nationwide shortfall could be 11.9 million metric tons.  Approximate-




ly 160 additional permitted off-site facilities could be required to




handle hazardous industrial waste in 1984 in the former case and




approximately 200 additional permitted off-site facilities could be




required in the latter case.  Based upon the estimated shortfall




under the baseline regulations, only 115 of the necessary permitted




facilities would be attributable to this alternative in the former




case and only 120 would be attributable to this alternative in the




latter case.  Data are not available to estimate potential shortfalls




in environmentally adequate on-site process capacity.  Treatment dis-




posal of hazardous non-manufacturing waste could exacerbate these




shortfalls, as could other factors discussed under the baseline




regulations.






                                  S-54

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



environmentally adequate hazardous waste management under this alter-




native than under the baseline regulations.  This land would be



required both for the construction of the permitted facilities neces-




sary for the storage, treatment, and disposal of the additional




wastes regulated under this alternative, and for such conjunctive




developments as construction of roads, power lines, and pipelines.



However, while more total land would be required under this alterna-




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



less off-site land use and more on-site land use for hazardous indus-




trial wastes by 1984, compared to the baseline regulations.  In the




case of 25 percent off-site shipment, there could be more off-site




land use and less on-site land use for hazardous industrial wastes by




1984, compared to the baseline regulations.




     Existing land uses would cease, either permanently or temporari-



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




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




lowing closure of the hazardous waste management facility and any




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




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




previously existing uses.  The biological community on disturbed



areas could differ in species composition and diversity following




site rehabilitation.




     The construction and operation of the required facilities, espe-




cially off-site facilities, would cause additional aesthetic impacts



                                   S-55

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and could result in additional instances of localized noise impacts.




Public opposition to the siting and construction of hazardous waste




management facilities could be further exacerbated by the increased



requirements for such facilities under this alternative.  However,




this opposition could be somewhat mitigated by the more stringent




environmental requirements under this alternative, by the require-




ment for the preparation of a Supplementary Environmental Analysis as




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




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



     S.5.4  Lesser Degree of Public Health and Environmental Protec-




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




alternative, compared to the baseline regulations.  These and other



major changes are discussed below.




     S.5.4.1  Primary Impacts.




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




mately 20 and 24 million metric tons of hazardous manufacturing




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




respectively.  This would represent about a 40 percent decrease in




the hazardous industrial wastes controlled in both these years.




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




decrease in hazardous non-manufacturing wastes regulated under this



alternative.



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




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







                                   S-56

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



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




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



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




hazardous waste management facilities being regulated; due to the




enactment of less stringent environmental requirements; due to




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



due to the imposition of fewer procedural and operational




requirements.



     Administrative Changes.  Several changes in the administration




of hazardous waste management programs would result from promulgation




of the regulations within this alternative.  Additional states could




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




elimination of almost all restriction on granting of interim authori-




zation, elimination of restrictions on granting of full or partial



authorization to states with more stringent standards, and reductions




in administrative and manpower requirements.  However, the elimina-




tion of the toxicity characteristic could also off-set such a poten-




tial for increases in state authorization.  If enough states felt




that the regulations were not adequate without the inclusion of toxic




wastes, there could be an overall reduction in authorized states



under this alternative.  Furthermore, the less stringent standards




and reduced amount of hazardous waste controlled under this alterna-




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






                                   S-57

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




hazardous waste program.




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



turing establishments, hospitals, and medical laboratories could have




to comply with the generator regulations under this alternative. This




would represent nearly a 60 percent reduction in the number of gener-




ators being regulated, compared to the baseline regulations.  Data




are not available to estimate the reductions in the number of trans-




porters and owners/operators of hazardous waste management facilities



to be regulated.




     It is estimated that the industrial generators could have to




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



Based upon this number of manifests, the aggregated generators,




transporters, and hazardous waste management facility owners/




operators could each have to keep between 200,000 nd 420,000 mani-



fests in storage on an annual basis.  This would represent approxi-




mately an 80 percent decrease in both requirements, as compared to




the baseline regulations.  It is estimated that generators and per-



mittees could prepare between 140,000 and 170,000 reports on an




annual basis—a reduction of approximately 60 percent.  The identi-




fied generators and permittees could have to file between 110,000 and



140,000 notifications under Section 3010—a reduction of nearly 60




percent.
                                   S-58

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     Air and Water Quality.  The regulations under this alternative




would have the potential to cause fewer changes affecting the release




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




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




baseline regulations.  The primary result would be fewer beneficial




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




requirements under this alternative would cause fewer changes in the




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




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




tors to make process modifications designed to further increase




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




hazardous wastes generated; any such reductions in process modifica-




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




water contaminants by processes generating hazardous wastes.  Fur-




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




control of the program, the potential for such process modifications




and resultant changes in the release of air and water contaminants




would be further decreased.




     The 16 million metric tons of potentially hazardous industrial




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




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




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




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




transported, stored, treated, or disposed by methods that are
                               S-59

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environmentally acceptable under the Subtitle C regulations, the




overall potential for the release of hazardous air emissions or water




effluents from the management of such additional wastes would be



increased.




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




ally hazardous industrial wastes (plus other hazardous wastes) that




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




stringent requirements under this alternative would have the poten-




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




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




line regulations.  The major impact, with regard to air quality,




would result from less stringent incineration requirements and from




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




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




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




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




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




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




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




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




ing higher permeabilities for soil liners for landfills and surface




impoundments.




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




ties would have to be modified or would have to be constructed under
                                 S-60

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




lar emissions, and runoff from such construction activities.




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



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




the regulated wastes and the wastes excluded from regulation under




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



to manage these wastes under the baseline regulations.  As previously




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




increases in the release of many air and water contaminants from



hazardous waste management, and localized and/or nationwide decreases




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




proposed regulations.  The likely result would be increased localized




degradation of air and water quality, along with some localized




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




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




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




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




     Public Health.  The regulations under this alternative would




have the potential for reducing the public health benefits to be



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




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




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




taminants from hazardous waste management and, thus, for resultant




public health impacts.  Furthermore, since most of the wastes to be
                                   S-61

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removed from regulations under this alternative would be potentially




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




increases in acute and chronic health effects to result from the




improper disposal of such wastes.




     S.5.4.2  Secondary Impacts.  The major changes in secondary




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




result of implementation of this alternative, would result primarily




from the removal of approximately 16 million metric tons of hazardous




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



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




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




of hazardous wastes; and potentially lower increases in storage,




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




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




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




fewer beneficial impacts to the biological environment, soils, water




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




line regulations.



     The above changes would also provide less of an incentive for




generators to modify processes so as to enable increased recycling of




hazardous waste as process feedstocks, to reduce the quantities of



hazardous wastes generated by specific processes, or to change the



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




by the lesser amount of facility modification and construction







                                   S-62

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required under this alternative, by less stringent requirements for




facility operation and closure, and by any resultant decreases in




hazardous waste transport.  Changes in resource recovery could lead




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




There could also be fewer reductions in energy production due to the




reduced costs associated with management of wastes from such activi-




ties and due to the exclusion of hazardous 'special wastes'  from




regulation; many 'special wastes'  are generated by energy production




activities.




     Fewer industrial plant closings or relocations, due to the




reduced costs under this alternative, could lead to fewer population




shifts and resultant impacts.  Fewer workers would also be required




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




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




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




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




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




pared to the baseline regulations.  Fewer population shifts could




occur in response to the reduced personnel requirements; any shifts




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




still be localized instances of a relatively large influx or out flux



of workers.




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




tially be sufficient, environmentally adequate, off-site capacity on
                                 S-63

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a nationwide basis to handle all hazardous industrial wastes sent



off-site in 1980 and 1984.  However, without any growth in existing,




environmentally adequate, off-site capacity, there could potentially




be a nationwide shortfall of 0.5 million metric tons in such capacity




in 1984 in the case of 25 percent off-site shipment.  In this case,




approximately 72 fewer permitted off-site facilities could be




required to handle hazardous industrial waste, as compared to the




baseline regulations.  Data are not available to estimate any poten-




tial shortfalls in environmentally adequate on-site capacity; how-



ever, there would be less of a potential for any shortfalls to occur.




Even in those instances where sufficient capacity is estimated to be




available on a nationwide basis, regional, statewide, or localized




shortages would be likely to occur, as discussed under the baseline




regulations.




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



the construction of any storage, treatment, and disposal facilities




needed under this alternative, and for such conjunctive developments




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



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




permitted facilities; the wastes removed from regulation could use




existing facilities or other facilities that were not adequate under




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




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




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






                                    S-64

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use for hazardous industrial wastes by 1984, compared to the baseline




regulations.  In the case of 25 percent off-site shipment, there




could be less off-site land use and more on-site land use for hazard-




ous industrial wastes by 1984, compared to the baseline regulations.




     Existing land uses would not change on lands excluded from




hazardous waste management under this alternative; however, there




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




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




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




disruptions of ecological communities as a result of the lesser land




disturbances.




     The construction and operation of fewer facilities, especially




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




result in fewer instances of localized noise impacts.  While public




opposition  to the siting and construction of hazardous waste manage-




ment facilities could be reduced by the need for fewer facilities




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




bated by the less stringent requirements under this alternative.




     S.5.5  Phase I Alternative.  Table S-l indicates some of the




changes under this alternative, compared to the baseline regulations.




These and other major changes are discussed below.




     S.5.5.1  Primary Impacts.




     Hazardous Wastes to be Regulated.  Various modifications under




this alternative would exclude  from regulation some wastes that would
                                  S-65

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have been regulated under this baseline regulation and would subject

to regulation additional wastes that would not have been regulated

under the baseline regulations.  While data are not available to

determine the specific changes in the quantity of waste that would be

regulated, it is estimated that the net effect of all the modifica-

tions would likely be a slight decrease in the total quantity of

waste regulated under this alternative.  There would likely be a net

decrease in the quantity of both manufacturing and non-manufacturing

wastes being regulated.  While there would also be a net decrease in

the quantity of 'special waste* being regulated,  much 'special waste'

would be subject to the full set of regulations rather than just to a

limited portion of the regulations.  During the first 2 to 5 years

following implementation of the regulations, less total waste would

be subject to regulation in the period that follows due to indicated

changes in the generator limit.

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

posal Practices.  Changes to generation, transport, storage, treat-

ment and disposal practices would likely occur under this alternative

due to the changes in wastes being regulated; due to implementation

of the Interim Status Standards*; due to revisions in procedural
 The Interim Status Standards represent the minimum requirements
 with which an existing treatment, storage, or disposal facility must
 comply until administrative disposition of the facility's permit
 application is made.  The Interim Status Standards would apply to
 all activities affecting any hazardous waste handled at such a
 facility after the effective date of the regulations.  Under the
 baseline regulations, existing facilities would not be required to
 modify their present practices until after being issued a permit.

                               S-66

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and operational requirements; and due to resultant changes in stor-




age, treatment, and disposal costs.




     In general, there would be some significant differences between




those changes related to the generation and management of hazardous




'special wastes' and those changes related to the generation and




management of all other hazardous wastes.  These differences would be




the result of the requirement that most hazardous 'special wastes'




comply with the full set of Subtitle C standards under this alterna-




tive, rather than the limited set of standards specified under the




baseline regulations.  All other hazardous wastes would already be




required to comply with the full set of baseline regulations.




     With regard to all hazardous wastes other than 'special wastes',




fewer changes of the types discussed for the baseline regulations




would be likely to occur to existing generation, transport, storage,




treatment, and disposal practices under this alternative.  However,




those changes that do occur would take place sooner due to the re-




quirements of the Interim Status Standards.  Generators, trans-




porters, and waste management facilities would also have to make some




additional modifications to comply with the additional requirements




discussed in Section 8.5.1.2.  These include increased requirements




for tracking of waste shipments and for post-closure care at disposal




facilities.




     With regard to hazardous 'special wastes', many additional




changes to generation, transport, storage, treatment,  and disposal







                               S-67

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practices would be likely to occur under this alternative.  Most of




these changes would be essentially equivalent to those discussed




under the baseline regulation.  These changes would occur sooner than




under the baseline regulations, however, due to the Interim Status




Standards.




     Administrative Changes.  Several changes in the administration




of the hazardous waste management program would result from promulga-




tion of the regulations within this alternative.




     Little or no change is expected to occur in the number of states




applying for interim or full authorization.  However, partial autho-




rization of state program would be eliminated under this alternative.




This could increase the potential for a few states to enact one or




more components of an independent, hazardous waste program.




     It is estimated that during the initial 2 to 5 years following



implementation of the regulations, on the order of 110,000 to .140,000




manufacturing establishments, hospitals, and medical laboratories




could have to comply with the generator regulations under this alter-




native.  This would represent nearly a 60 percent reduction in the




number of generators identified as being subject to the Section 3002




requirements under the baseline regulation during this period.




Following this initial 2 to 5 year period, on the order of 220,000 to




250,000 generators could be required to comply.  This would represent




over a 15 percent reduction, as compared to the baseline regulations.




There would also be an indeterminable reduction in the total number
                               S-68

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of other generators (e.g., hazardous 'special waste'  generators) who




would be required to comply with the regulations.




     It is estimated that there would also be a slight reduction in




the number of permittees under this alternative; fewer facilities




would, however, require permits during the initial 2 to 5 year period




than in the period which follows.  Facilities managing hazardous




'special wastes' would be subject to more stringent permit require-




ments under this alternative.




     Information required on manifests would be reduced under this




alternative.  Generators of hazardous 'special wastes' could have to




prepare an indeterminable number of additional manifests under this




alternative.  The aggregated generators, transporters, and hazardous




waste management facility owners/operators handling these wastes




would also have to keep the additional manifests in storage for 3




years.  There would, however, likely be a net reduction in the number




of manifests that would be prepared by generators of other hazardous




wastes.  The aggregated generators, transporters and hazardous waste




management facility owners/operators handling these latter wastes




would thus have to keep fewer manifests in storage.  The total number




of manifests prepared and stored would be less during the first 2 to




5 years than in the following years.




     It is estimated that the identified generators and permittees




could prepare between 250,000 and 280,000 reports on annual basis




after the initial 2 to 5 year period — a reduction of over 40
                                S-69

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percent.  Fewer reports would be prepared during the initial 2 to 5




year period.  However, other additional reporting, recordkeeping, and




administrative requirements would be imposed for generators and




permittees under this alternative.  For example, generators would




have to prepare outlines of programs for assessment of groundwater




damage and for implementing corrective actions.  The identified




generators and permittees could have to file on the order of 110,000




to 140,000 notifications under Section 3010 — a reduction of nearly




60 percent.  While the total number of permit applications would




likely decrease, permits would be reviewed at least once every 5




years rather than being issued for the projected life of the




facility.  Consolidation of requirements for obtaining RCRA permits,




National Pollution Discharge Elimination System permits, Underground




Inspection Control permits, and permits under Section 404 of the




Clean Water Act would reduce the total administrative requirements




associated with these permits.




     Air and Water Quality.  The regulations under this alternative




would have the potential to cause changes affecting the release of




air and water contaminants from the generation, transport, storage,




treatment, and disposal of hazardous wastes, as compared to the base-




line regulations.  As discussed below, this would lead to instances




of both localized improvements in air and water quality and localized




degradation of air and water quality.
                               S-70 '

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     For Chose generators of hazardous wastes other than 'special

wastes', to the extent that the requirements under this alternative

would cause lesser changes in the economics of storage, treatment, or

disposal relative to those of the baseline regulations, there would
              t
be less of a potential for these 'generators to make process modifica-

tions designed to increase hazardous waste recycling and to reduce

the quantity and/or type of hazardous wastes generated; any such

reductions in process modifications would likely lead to fewer

changes in the release of air and water contaminants by processes

generating hazardous waste.  For generators of 'special wastes', to

the extent that the requirements under this alternative would cause

further increases in the economics of storage, treatment, or disposal

relative to those of the baseline regulations, there would be greater

potential for generators of these wastes to make process or opera-

tional modifications designed to reduce the quantity and/or types of

hazardous wastes generated; any such modifications could lead to

increased changes in the release of air and water contaminants by

processes generating hazardous wastes.  Furthermore, to the extent

that fewer generators would be brought under control of the program

in both instances, the potential for any such process modifications

and resultant changes in the release of air and water contaminants

would be accordingly reduced.

     Slightly less waste would likely be regulated under this alterna-

tive than under the baseline regulations.  As a result, those

hazardous wastes excluded from regulation would not have to be


                                S-71

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transported, stored, treated, or disposed in accordance with the Sub-




title C regulations.  Since it is likely that many of these wastes




would not be managed by methods that are environmentally acceptable




under the regulations, the overall potential for the release of




hazardous air and water contaminants from the management of such




wastes would be increased.




     With regard to the hazardous waste that would still be regulated




under this alternative, the requirements under this alternative would




have the potential for affecting the release of air and water con-




taminants from the management of these wastes in various ways.  Some




of the requirements would result in an increase in the potential for




the release of such contaminants while others would result in a de-




crease.  Changes that could potentially have significant affects on




the release of contaminants are discussed below.



     Reductions in the release of air and water contaminants would




result from the more stringnet requirements being placed on the




management of hazardous wastes at existing facilities during the




Interim Status period.  These requirements include restrictions on




treating and/or disposing wastes in surface impoundments, incinera-




tors, landfartns, landfills, and basins.  They also impose require-




ments for monitoring, inspections, remedial actions, facility




closure, and post-closure care.  Following the Interim Status period,




other changes would further reduce the potential for the release of




air and water contaminants.  These include subjecting hazardous
                                  S-72

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'special wastes' to the full set of Section 3004 requirements; re-




ducing time requirements for completing closure activities; extending




time requirements for post-closure care; and adding requirements for




preparing groundwater damage assessment and corrective action pro-




grams, for conducting groundwater monitoring at landfarms, for in-




cluding provisions for controlling spills and unplanned non-sudden




discharges in contingency plans, and for performing necessary repairs



or remedial actions.




     Increases in the release of air and water contaminants from




regulated wastes would result primarily from the elimination of the




human health and environmental standards.  This would increase the




potential for the release of air and water contaminants from non-




point sources (e.g., surface impoundments, landfills, storage areas)




at permitted facilities.  The elimination of leachate monitoring




requirements could increase the potential for degradation of water




quality; however, other changes related to siting of groundwater




monitoring wells and to implementing groundwater damage assessment




and corrective action programs would tend to off-set this.  The




elimination of spill response information from manifests could




increase the potential for air and water quality impacts to result




from spills during transport.  Any increased off-site transport of




hazardous 'special wastes' could also increase the potential for




transportation related impacts.
                                  S-73

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     To the extent that additional storage, treatment, or disposal
facilities for hazardous 'special wastes' would have to be modified
or constructed, there would be an increase in fugitive dust, vehi-
cular emissions, and runoff from such construction activities.  To
the extent that fewer facilities for other hazardous wastes would
have to be modified or constructed, there would be a decrease in
fugitive dust, vehicular emissions, and runoffs.
     It should be noted that there would likely be some shift in the
types of methods used to store, treat, or dispose both regulated
wastes and the wastes excluded from regulation under this alternative
compared to the methods that would have been used to manage these
wastes under the baseline regulations.  Such shifts would change both
the types and quantities of air and water contaminants produced by
the management of specific wastes.  Such shifts could either enhance
or reduce the potential for this alternative to cause the indicated
increases or decreases in the release of specific air or water con-
taminants in any given locality.  Furthermore, the construction of
new facilities could lead to increased releases of air and water
contaminants in the vicinity of the facility and along any transport
routes. Closure of existing facilities could lead to reduced releases
of air and water contaminants in the vicinity of the facility and
along any transport routes.  All emissions and any localized degrada-
tion of air quality would have to be in compliance with all applic-
able requirements (e.g., Clean Air Act standards, OSHA standards,
state standards).
                                  S-74

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     Public Health.  The regulations under this alternative would




have the potential for increasing some of the public health benefits




to be derived from the control of hazardous wastes through the base-




line regulations and would also have the potential for reducing other




public health benefits to be derived from the baseline regulations.




As discussed, the regulations would both increase and decrease (rela-




tive to the baseline regulations) the potential for the release of




air, water, and soil contaminants from hazardous waste management




and, thus, for resultant public health impacts.




     Additional public health benefits could be derived from the re-




quirements for turning over to the local land authority records on




where wastes are disposed and for notations to be recorded on the




property deed (or equivalent instruments) to, in perpetuity, notify




any potential purchaser both that the land has been used to manage




hazardous waste and that the land is subject to use restrictions.




This could help prevent future public health catastrophes such as




that which occurred at Love Canal in Niagara Falls, New York (see




Section 7.1.6).  Additional restrictions on the disposal of hazardous




uranium and phosphate surface mining and beneficiation wastes would




also lead to increased public health benefits.  Review of permits at




least once every five years, rather than no review as under the base-




line regulations, would also reduce the potential for adverse public




health impacts.
                                   S-75

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     Elimination of the requirement that contingency plans must in-




clude an outline of a program for familiarizing employees with emer-




gency procedures and for drills on these procedures could increase




the potential for public health impacts to occur in the event of an




emergency situation at the facility; however, this would be off-set




by other indicated changes in contingency plans.  Elimination of the




requirement that the contingency plan must be implemented when there




is a discharge that threatens human health only within the facility




would increase the potential for adverse impacts to facility




employees.  The exclusion of some infectious wastes from regulation




could also lead to some increased instances of adverse public health




impacts.




     S.5.5.2  Secondary Impacts.  The major changes in secondary im-




pacts (relative to the baseline regulations) that could occur, as a




result of implementation of this alternative, would result primarily




from the net reduction in the quantity of waste that would be subject




to regulation; the enactment of more stringent environmental require-




ments with regard to the storage, treatment, and disposal of hazard-




ous wastes during the Interim Status period; the modification of some




requirements for managing wastes following the Interim Status period;




the enactment of more stringent requirements for tracking manifested




waste shipments; the enactment of more stringent environmental re-




quirements with regard to the storage, treatment, and disposal of




hazardous 'special wastes'; and from modified costs to generators and
                                  S-76

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costs associated with hazardous waste transport, storage, treatment,




and disposal as a result of these revised requirements.  To the ex-




tent that these changes result in indicated increases or decreases in




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




mensurate impacts to the biological environment, soils, water use,




land use, and special interest points, as compared to the baseline




regulations.



     The changes described above would, as previously indicated, also




affect the potential for generators to modify processes and opera-




tions so as to enable increased recycling of hazardous waste as pro-




cess feedstocks, to reduce the quantities of hazardous wastes gener-




ated, or to change the nature of wastes produced.  In addition, this




alternative would provide a further incentive for all generators to




recycle, re-use, or recover hazardous waste materials.  All hazardous




waste materials that are used, re-used, or processed for energy re-




covery or that are stored for such purposes would be excluded from




regulation under this alternative.  Similarly, all hazardous waste




materials, except waste oils, that are used or re-used in a manner




constituting disposal or that are being stored for such purposes




would be excluded  from regulation.




     Energy use, with regard to the management of hazardous 'special




wastes', would be  increased by the additional facility modification




and construction required under this  alternative, by required changes




in facility operation and closure, and by any increases in hazardous
                                 S-77

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waste transport.  Furthermore, many 'special waste1 generators are




energy producers (e.g., oil and gas drilling operations).  Due to the




more stringent requirements and increased costs associated with the




management of these wastes, there could be some increased reductions




in energy production.




     Energy use, with regard to the management of other hazardous




wastes, would be reduced by the lesser amount of facility modifica-




tion and construction and by any reductions in hazardous waste trans-




port.  The requirements of the Interim Status Standards along with




the lengthened post-closure care period could off-set some of this




decrease in energy use.




     With regard to generators of hazardous 'special wastes', in-




creased costs under this alternative could lead to some additional




closings or relocations of plants and operations, and this could lead




to additional population shifts and resultant impacts. In addition,




additional workers could also be required to manage these wastes and




to construct or modify facilities managing these wastes.  With regard




to generators of other hazardous wastes, lesser increases in costs




under this alternative could lead to fewer plant closings or reloca-




tions, and this could lead to fewer population shifts and resultant




impacts.  Fewer workers could also be required to manage these wastes




and to construct or modify facilities managing these wastes.  There




could also be an overall decrease in the number of personnel required




to administer and enforce the regulations.  Population shifts could
                                  S-78

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occur in response to changed personnel requirements.  Any such shifts




would be expected to be small on a national scale; however, there




could still be localized instances of a relatively large influx or




outflux of workers.  Due to the Interim Status Standards, plant




closings and changes in personnel requirements could occur earlier




under this alternative than under the baseline regulations.




     It is estimated that under this alternative there would poten-



tially be sufficient off-site capacity on a nationwide basis to




treat/dispose regulated hazardous manufacturing wastes shipped off-




site in 1980.  There would also potentially be sufficient off-site




capacity nationwide in 1984 in the case of 13 percent off-site ship-




ment.  As compared to the baseline regulations, there would be a




reduction in the potential shortfall in nationwide off-site capacity




estimated to occur in 1984, in the case of 25 percent off-site




shipment.  As a result, fewer permitted off-site facilities could be




required in this latter case under this alternative as compared to




the baseline regulations.  Similarly, under this alternative, there




would also be reductions in the potential for any shortfall in the




on-site capacity necessary for treating/disposing regulated hazardous




manufacturing wastes.




     With regard to hazardous 'special waste1, there would be an in-




creased potential for shortfalls in both environmentally adequate on-




site and off-site capacity in 1980 and 1984.  The increased potential




for shortfalls in on-site capacity would result from increased







                                S-79

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facility closings due to the requirement that facilities managing




'special wastes' comply with all Section 3004 requirements rather




than a limited portion of such requirements.  The increased potential




for shortfalls in off-site capacity would result from likely in-




creases in the quantity of wastes being sent off-site; however, any




increases in off-site shipments would also off-set some of the




potential for an increase in the shortfall of on-site capacity.




     Other factors discussed under the baseline regulations could




either lead to shortfalls or exacerbate the size of any estimated




shortfalls in both on-site and off-site process capacity, especially




on a localized basis.




     With regard to hazardous wastes other than 'special wastes',




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




the baseline regulations.  Lesser land requirements would result



since fewer wastes would have to be sent to permitted facilities; the




waste removed from regulation could use existing facilities or other




facilities that were not adequate under the baseline regulations.




However, while less total land would be required, in the case of 13




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




less on-site land use for hazardous manufacturing wastes.  In the




case of 25 percent off-site shipment, there could be less off-site




land use and more on-site land use.




     With regard to hazardous 'special wastes', more total land could




be required under this alternative for the management of all






                                 S-80

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(regulated and unregulated) hazardous special wastes.  There would
likely be more off-site land use and less on-site land use for
regulated special wastes.
     With regard to all hazardous wastes, existing land uses would
not change on any lands excluded from hazardous waste management
under this alternative; however, there could be localized changes in
land use from any additional shifts to off-site management from on-
site management or to on-site management from off-site management.
Existing biological communities would not be disturbed on lands ex-
cluded from hazardous waste management activities.  To the extent
that the management of wastes excluded from regulation under this
alternative would result in additional land being contaminated
through inadequate practices, there would be off-setting adverse
impacts to existing land uses.
     Existing land uses would, however, cease, either permanently or
temporarily, on all land converted to hazardous waste management
uses. Existing biological communities would also be disturbed on all
such lands.  Following closure of hazardous waste management facili-
ties and necessary post-closure care, the land used for the facility
could be available for new or, in some cases, previously existing
uses.  The biological community on disturbed areas could differ in
species composition and diversity following site rehabilitation.
Less land could be available for future use than under the baseline
regulations since this alternative eliminates the requirement that
all facilities
                                 S-81

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must be designed such that the land is amenable to some acceptable




use so that perpetual isolation and care to maintain isolation are




not required.  This alternative would also affect future use of the




land by requiring that a notation be recorded on the property deed




(or equivalent instruments) to notify, in perpetuity, any potential




purchaser both that the land has been used to manage hazardous waste




and that the land is subject to use restrictions.




     Indicated changes in the construction and operation of facili-




ties, especially off-site facilities, would cause commensurate




changes in aesthetic impacts and localized noise impacts.  Public




opposition to the siting and construction of hazardous waste manage-




ment facilities could be reduced by the requirement for permits to be




reviewed at least once every 5 years rather than not at all and by




the lengthening of the period specified for post-closure care.  With




regard to facilities managing hazardous wastes other than 'special




wastes', public opposition to such facilities could be further re-




duced by the need for fewer of thse facilities.  With regard to




facilities managing hazardous 'special wastes', public opposition to




such facilities could be reduced by the more stringent environmental




requirements under this alternative.  However, any opposition that




occurs could be exacerbated by possible increases in the number of




these facilities required.  The addition of the Interim Status




Standards could also reduce opposition to some existing facilities.
                                 S-82

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1.0  INTRODUCTION

     This document is Part I of the final Environmental Impact State-

ment (EIS) addressing the potential effects of implementing regula-

tions under Subtitle C of the Resource Conservation and Recovery Act

of 1976 (RCRA).  Specifically, the regulations addressed in this

document are those being developed under the mandate of the following

Sections of Subtitle C:

     •  Section 3001— Identification and listing of hazardous waste;

     •  Section 3002— Standards applicable to generators of
        hazardous waste;

     •  Section 3003— Standards applicable to transporters of
        hazardous waste;

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

     •  Section 3005— Permit system for treatment, storage, and
        disposal of hazardous wastes;

     •  Sectio'n 3006— Guidelines for state hazardous waste programs;

     •  Section 3010— Preliminary notification of hazardous waste
        activities.

In addition, the Environmental Protection Agency (EPA) has responded

to the mandate of all other Sections of Subtitle C, namely:

     •  Section 3007 — Inspections;

     •  Section 3008 — Federal enforcement;

     •  Section 3009 — Retention of state authority;

     •  Section 3011 — Authorization of assistance to the states.

     A summary of the major aspects of these sections is presented in

Chapter 2 of this document.  Chapter 3 summarizes the baseline

                                 1-1

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Subtitle C regulations that are the subject of this EIS (see Appendix

B for a detailed description of these regulations).  Chapter 4 sum-

marizes the set of alternatives selected and developed for analysis

in relation to these baseline regulations.

     The development of regulations under Subtitle C has been and is

continuing to be a dynamic, changing process.  In the event of major

changes to the regulations following their promulgation, and/or in

the event of additional regulations affecting specific wastes, such

as the large volume special wastes identified under the proposed

Subtitle C regulations (i.e., cement kiln dusts, utility wastes, oil

drilling muds/brines, phosphate rock mining and processing wastes,

uranium mining wastes, and other mining wastes), a supplemental

Environmental Impact Statement would be prepared if necessary.

     The scope of this EIS includes all hazardous wastes within the

definition of the baseline regulations and the alternatives.  How-

ever, the regulations, and thus the EIS, do not address those wastes

specifically.excluded by the Act or by Congressional intent, namely:

     •  Solid or dissolved material in domestic sewage;

     •  Solid or dissolved material in irrigation return flows;

     •  Industrial discharges which are point discharges subject to
        permits under section 402 of the Federal Water Pollution
        Control Act, as amended (86 Stat. 880);

     •  Source, special nuclear, or by-product material as defined by
        the Atomic Energy Act of 1954, as amended (68 Stat. 923);

     •  Household wastes.
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2.0  LEGISLATIVE BACKGROUND

2.1  Federal Legislation Leading to RCRA

     The first Federal legislation relating to solid waste disposal

was the Refuse Act comprising Section 13 of the River and Harbor Act

of 1899 (30 Stat. 1152).  This Act states that:

          ...it shall not be lawful to throw, discharge, or deposit,
          or cause, suffer or procure to be thrown, discharged, or
          deposited either from or out of any ship, barge, or other
          floating craft of any kind, or from the shore, wharf, manu-
          facturing establishment, or mill of any kind, any refuse
          matter of any kind or description whatever other than that
          flowing from streets and sewers and passing therefrom in a
          liquid state, into any tributary of any navigable water
          from which the same shall float or be washed into such nav-
          igable water; and it shall not be lawful to deposit, or
          cause, suffer, or procure to be deposited material of any
          kind in any place on the bank of any navigable water, or on
          the bank of any tributary of any navigable water, where the
          same shall be liable to be washed into such navigable
          water, either by ordinary or high tides, or by storms or
          floods, or otherwise, whereby navigation shall or may be
          impeded or obstructed:  Provided, that nothing herein con-
          tained shall extend to, apply to, or prohibit the opera-
          tions in connection with the improvement of navigable
          waters or construction of public works, considered neces-
          sary and proper by the United States officers supervising
          such improvement or public work:  and provided further,    \,
          that the Secretary of War, whenever in the judgment .of the
          Chief of Engineers anchorage and navigation will not be
          injured thereby, may permit the deposit of any material
          above mentioned in navigable waters, within limits to be
          defined and under conditions to be prescribed by him, pro-
          vided application is made to him prior to depositing such
          material; and whenever any permit is so granted the condi-
          tions thereof shall be strictly complied with, and any
          violation thereof shall be unlawful.

Although the original intent of this Act was to prevent obstructions

to navigation, it did represent the first Federal regulation of open

dumping and is still in effect.
                                 2-1

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     The Solid Waste Disposal Act, passed in 1965, was the first Act


of Congress dealing directly with the solid waste problem and was


primarily aimed at establishing a national research and development


program for new and improved methods of proper and economic disposal


of solid waste.  It authorized the Secretary of Health, Education and


Welfare to make grants to state and interstate agencies to conduct


surveys of solid waste disposal practices and associated problems.


     In 1970, the Solid Waste Disposal Act was amended by the Re-


source Recovery Act, which shifted its objectives to include the pro-


motion of resource recovery programs and added provisions for grants


to these programs.  It also required the Secretary of Health, Educa-


tion and Welfare to submit to Congress a report on the feasibility of
      s

a system of national disposal sites for the storage and disposal of


hazardous wastes.  That report (Office of Solid Waste Management Pro-


grams, 1974c) was an important step in dealing with the problems of


hazardous waste management.  The Solid Waste Disposal Act has since


expired.


     The Environmental Protection Agency proposed the Hazardous Waste


Management Act (S.1086) early in 1973.  Although never enacted, this


Bill led directly to the Resource Conservation and Recovery Act of


1976 (RCRA).  There are several important differences between these


two pieces of legislation.  The objectives of the Hazardous Waste


Management Act included Federal regulation of certain hazardous


wastes and Federal guidelines for state regulation of others, while



                                 2-2

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RCRA aims to provide Federal assistance to state and local solid

waste management programs, thus giving the states more authority and

placing the Environmental Protection Agency in an advisory capacity.

     The definition of hazardous waste in the Hazardous Waste Manage-

ment Act was:

          Any waste or combination of wastes which pose a substantial
          present or potential hazard to human health or living
          organisms because such wastes are nondegradable or persis-
          tent in nature or because they can be biologically mag-
          nified, or because they can be lethal, or because they may
          otherwise cause or tend to cause detrimental cumulative ef-
          fects.

In the RCRA the definition was expanded to:

          A solid waste, or combination of solid wastes, which be-
          cause of its quantity, concentration, or physical, chemical
          or infectious characteristics may cause, or significantly
          contribute to an increase in mortality or an increase in
          serious irreversible, or incapacitating reversible,
          illness; or pose a substantial present or potential hazard
          to human health or the environment when improperly treated,
          stored, transported, or disposed of, or otherwise managed.

Other changes involve the definition of storage, treatment, and dis-

posal.  Under the Hazardous Waste Management Act, storage for more

than two years is considered disposal.  Under RCRA, storage may be

either temporary or for a period of years, but is not to constitute

disposal.  The definition of treatment was altered considerably from

"any activity or processing designed to change the physical form or

chemical composition of waste so as to render such materials non-

hazardous" in the Hazardous Waste Management Act to RCRA1s "any

method, technique, or process, including neutralization, designed to

change the physical, chemical, or biological character or composition


                                 2-3

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of any hazardous waste so as to neutralize such waste or so as to

render waste non-hazardous, safer for transport, amenable for recov-

ery, amen°ble for storage, or reduced in volume."  Under the Hazar-

dous Waste Management Act, disposal refers only to land disposal,

while RCRA considers disposal into or on any land or water, including

groundwaters.  RCRA also deals individually with generators, trans-

porters, treaters, storers, and disposers of hazardous wastes, where-

as the Hazardous Waste Management Act considered them all together.

     On October 21, 1976, the Resource Conservation and Recovery Act

of 1976 (Public Law 94-580) was signed by the President and became

law.

2.2  RCRA and Subtitle C

     RCRA has as its objectives the protection of health and the en-

vironment and the conservation of valuable material and energy re-

sources.  These objectives are to be met by:

     •  Providing technical and financial assistance to state and lo-
        cal governments and interstate agencies for the development
        of solid waste management plans (including resource recovery
        and resource conservation systems) which will promote im-
        proved solid waste management techniques (including more
        effective organizational arrangements), new and improved
        methods of collection, separation, and recovery of solid
        waste, and the environmentally safe disposal of nonrecover-
        able residues;

     •  Providing training grants in occupations involving the de-
        sign, operation, and maintenance of solid waste disposal sys-
        tems;

     •  Prohibiting future open dumping on the land and requiring the
        conversion of existing open dumps to facilities which do not
        pose a danger to the environment or to health;
                                 2-4

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     •  Regulating the treatment, storage, transportation, and dis-
        posal of hazardous wastes which have adverse effects on
        health and the environment;

     •  Providing for the promulgation of guidelines for solid waste
        collection, transport, separation, recovery, and disposal
        practices and systems;

     •  Promoting a national research and development program for
        improved solid waste management and resource conservation
        techniques, more effective organizational arrangements, and
        new and improved methods of collection, separation, and re-
        covery, and recycling of solid wastes and environmentally
        safe disposal of nonrecoverable residues;

     •  Promoting the demonstration, construction, and application of
        solid waste management, resource recovery, and resource con-
        servation systems which preserve and enhance the quality of
        air, water, and land resources;

     •  Establishing a cooperative effort among the Federal, state,
        and local governments and private enterprise in order to re-
        cover valuable materials and energy from solid waste.

     In addressing these objectives, Title II of RCRA, the Solid

Waste Disposal Act (the Act), is divided into eight subtitles:

     •  Subtitle A - General Provisions

     •  Subtitle B - Office of Solid Waste; Authorities of the
                     Administrator

     •  Subtitle C - Hazardous Waste Management

     •  Subtitle D - State or Regional Solid Waste Plans

     •  Subtitle E - Duties of the Secretary of Commerce in Resource
                     and Recovery

     •  Subtitle F - Federal Responsibilities

     •  Subtitle G - Miscellaneous Provisions

     •  Subtitle H - Research, Development, Demonstration, and
                     Information
                                 2-5

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     Subtitle C of the Solid Waste Disposal Act calls for regulatory

action and guidelines within 11 separate categories as follows:

     •  Section 3001 - Identification and Listing of Hazardous Waste

     •  Section 3002 - Standards Applicable to Generators of Hazard-
                       ous Wastes

     •  Section 3003 - Standards Applicable to Transporters of
                       Hazardous Wastes

     •  Section 3004 - Standards Applicable to Owners and Operators
                       of Hazardous Waste Treatment, Storage and Dis-
                       posal Facilities

     •  Section 3005 - Permits for Treatment,  Storage or Disposal of
                       Hazardous Waste

     •  Section 3006 - Authorized State Hazardous Waste Programs

     •  Section 3007 - Inspections

     •  Section 3008 - Federal Enforcement

     •  Section 3009 - Retention of State Authority

     •  Section 3010 - Effective Date

     •  Section 3011 - Authorization of Assistance to States

     2.2.1  Definitions Relevant to Subtitle C.  Several definitions

listed in Section 1004 of 'the Act are particularly important to an

understanding of the scope of Subtitle C and the mandate of each of

the Sections 3001 through 3011.  These definitions, not detailed

elsewhere in the regulations, are:

     •  Disposal—the discharge, deposit, injection, dumping, spil-
        ling, leaking, or placing of any solid waste or hazardous
        waste into or on any land or water so that such solid waste
        or hazardous waste or any constituent thereof may enter the
        environment or be emitted into the air or discharged into any
        waters, including groundwaters.
                                 2-6

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•  Hazardous waste—solid waste,  or combination-of solid wastes,
   which because of its quantity, concentration,  or physical,
   chemical, or infectious characteristics may:

   (1)  Cause, or significantly contribute to, an increase in
        mortality or an increase  in serious irreversible, or
        incapacitating reversible, illness; or

   (2)  Pose a substantial present or potential hazard to human
        health or the environment when improperly treated,
        stored, transported, or disposed of, or otherwise man-
        aged.

•  Hazardous Waste Generation—the act or process of producing
   hazardous waste.

•  Hazardous Waste Management—the systematic control of the
   collection, source separation, storage, transportation,
   processing, treatment, recovery, and disposal of hazardous
   wastes.

•  Resource Recovery—the recovery of materials or energy
   from solid waste.

•  Solid Waste—any garbage, refuse, sludge from a waste treat-
   ment plant, water supply treatment plant, or air pollution
   control facility and other discarded material, including
   solid, liquid, semisolid, or contained gaseous material re-
   sulting from industrial, commercial, mining, and agricultural
   operations, and from community activities but does not
   include solid or dissolved material in domestic sewage or
   solid or dissolved materials in irrigation return flows or
   industrial discharges which are point sources subject to
   permits under Section 402 of the Federal Water Pollution Con-
   trol Act, as amended (86 Stat. 880), or source, special
   nuclear, or byproduct material as defined by the Atomic En-
   ergy Act of 1954, as amended (68 Stat. 923).

•  Storage—the containment of hazardous waste, either on a tem-
   porary basis or for a period of years, in such a manner as
   not to constitute disposal of such hazardous waste.

•  Treatment—any method, technique, or process,  including neu-
   tralization, designed to change the physical,  chemical, or
   biological character or composition of any hazardous waste
   so as to neutralize such waste or so as to render such
   wastes nonhazardous, safer for transport, amenable for re-
   covery, amenable for storage,  or reduced in volume.

                            2-7

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     2.2.2  Section 3001 of Subtitle C.  Section 3001 of Subtitle C,

Identification and Listing of Hazardous Waste, requires:

     •   The development and promulgation of criteria for identify-
         ing the characteristics of hazardous waste and for listing
         hazardous waste, taking into account toxicity, persistence,
         degradability in nature, potential for accumulation in tis-
         sue,  flammability, corrosiveness, and other hazardous
         characteristics;

     •   The promulgation of regulations identifying the character-
         istics of hazardous waste and listing particular hazardous
         wastes which are subject to the provisions of Subtitle C,
         based on the above criteria;

     •   The ability of the Governor of any state to petition the
         Administrator of the Environmental Protection Agency to
         identify or list a material as a hazardous waste.

     2.2.3  Section 3002 of Subtitle C.  Section 3002 requires the

promulgation of regulations establishing standards applicable to

generators of hazardous waste.  These standards must establish

requirements respecting:

     •   Recordkeeping practices that accurately identify the
         quantities of such hazardous waste generated, the con-
         stituents thereof which are significant in quantity or in
         potential harm to human health or the environment, and the
         disposition of such wastes;

     •   Labeling practices for any containers used for the storage,
         transport or disposal of such hazardous waste such as will
         identify accurately such waste;

     •   Use of appropriate containers for such hazardous waste;

     •   Furnishing of information on the general chemical compo-
         sition of such hazardous waste to persons transporting,
         treating, storing, or disposing of such wastes;

     •   Use of a manifest system to assure that all such hazardous
         waste generated is designated for treatment, storage, or
         disposal in treatment, storage, or disposal facilities
                                 2-8

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        (other than facilities on the premises where the waste is
        generated) for which a permit has been issued as provided
        in this subtitle;

     •  Submission of reports setting out:

        (1)  The quantities of hazardous waste identified or listed
             under this subtitle that have been generated during a
             particular time period;

        (2)  The disposition of all hazardous waste reported
             above.

     2.2.4  Section 3003 of Subtitle C.  Section 3003 requires the

promulgation of standards applicable to transporters of hazardous

waste.  These standards must include, but need not be limited to,

requirements respecting:

     •  Recordkeeping concerning such hazardous waste transported,
        and their source and delivery points;

     •  Transportation of such waste only if properly labeled;

     •  Compliance with the manifest system referred to in Section
        3002;

     •  Transportation of all such hazardous waste only to the
        hazardous waste treatment, storage, or disposal facilities '
        which the shipper designates on the manifest form to be a
        facility holding a permit issued under this subtitle.

These standards must be coordinated with regulations of the Secretary

of Transportation regarding the transport of hazardous wastes that

are subject to the Hazardous Materials Transportation Act (88 Stat.

2156; 49 U.S.C. 1801 and following).

     2.2.5  Section 3004 of Subtitle C.  Section 3004 requires the

establishment of such performance standards, applicable to owners and

operators of facilities for the treatment, storage, or disposal of
                                 2-9

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hazardous waste identified or listed under Subtitle C, as may be

necessary to protect human health and the environment.  These

standards must include, but are n«u necessarily limited to,

requirements respecting:

     •  Maintaining records of all hazardous wastes identified or
        listed under this title which are treated, stored, or dis-
        posed of, and the manner in which such wastes were treated,
        stored, or disposed of;

     •  Satisfactory reporting, monitoring, and inspection and com-
        pliance with the manifest system referred to in Section
        3002;

     •  Treatment, storage, or disposal of all such waste received
        by the facility pursuant to such operating methods, tech-
        niques and practices as may be satisfactory to the
        Administrator;

     •  The location, design, and construction of such hazardous
        waste treatment, disposal, or storage facilities;

     •  Contingency plans for effective action to minimize unan-
        ticipated damage from any treatment, storage, or disposal
        of any such hazardous waste;

     •  The maintenance and operation of such facilities and re-
        quiring such additional qualification as to ownership, con-
        tinuity of operation, training for personnel and financial
        responsibility as may be necessary or desirable;

     •  Compliance with the requirements of Section 3005 respecting
        permits for treatment, storage, or disposal.

     2.2.6  Section 3005 of Subtitle C.  Section 3005 of Subtitle C

which deals with permits for the treatment, storage, or disposal of

hazardous waste requires:

     •  The promulgation of regulations requiring each person own-
        ing or operating a facility for the treatment, storage, or
        disposal of hazardous waste to have a permit;

     •  The promulgation of regulations requiring certain infor-
        mation to be contained in permit applications, including:

                                2-10

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       (1)  Estimates with respect to the composition, quantities,
            and concentrations of any hazardous waste identified
            or listed under Subtitle C, or combinations of any
            such hazardous waste and any other solid waste,
            proposed to be disposed of, treated, transported, or
            stored, and the time, frequency, or rate of which such
            waste is proposed to be disposed of, treated, trans-
            ported, or stored;

       (2)  The site at which such hazardous waste or the products
            of treatment of such hazardous waste will be disposed
            of, treated, transported to, or stored.

Section 3005 also discusses permit issuance, permit revocation, and

interim status for persons who have filed applications for permits

for existing facilities.

     2.2.7  Section 3006 of Subtitle C.  Section 3006 pertains to the

authorization of state hazardous waste programs.  It requires the

promulgation of guidelines to assist states in the development of

such programs.  Procedures are given for any state to apply for

authorization of its hazardous waste program and provides for interim

authorization of state programs which exist before the date 90 days

after the date required for promulgation of regulations under

Sections 3002, 3003, 3004, and 3005.  Any action taken by a state

under an authorized program is given the same force and effect as

action taken by the EPA Administrator under Subtitle C.  Procedures

are also established for withdrawal of authorization by the

Administrator.

     2.2.8  Section 3007 of Subtitle C.  Section 3007 requires any

person who generates, stores, treats, transports, disposes, or

otherwise handles hazardous wastes to allow access to records
                                2-11

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relating to these wastes to any officer or employee of the Environ-

mental Protection Agency designated by the Administrator or any duly

designated officer or employee of a state having an authorized

hazardous waste program.  Such officers or employees are authorized:

     •  To enter at reasonable times any establishment or other
        place maintained by any person where hazardous wastes are
        generated, stored, treated, or disposed;

     •  To inspect and obtain samples from any person of any such
        wastes and samples of any containers or labeling for such
        wastes.

Procedures are given for conducting such inspections.  In addition,

provisions are made for the public to obtain records, reports, or

information.

     2.2.9  Section 3008 of Subtitle C.  Section 3008 deals with

Federal enforcement of Subtitle C. Procedures are given for the

issuance of a compliance order and the commencement of a civil action

in the event the Administrator determines that any person is in

violation of any requirement of Subtitle C.  A public hearing may be

requested by the person or persons named in the order or permit

revocation.  Any compliance order shall specify the nature of the

violation and a time limit for compliance.  Provision is made for

criminal penalties for violations of Subtitle C.

     2.2.10  Section 3009 of Subtitle C.  Under Section 3009,

Retention of State Authority, no state may impose any requirements

less stringent than those authorized under Subtitle C, except that if
                                  2-12

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application of a regulation under Subtitle C is postponed or enjoined




by the action of any court, a state may not be prohibited from acting



on the matter until the regulation takes effect.




     2.2.11  Section 3010 of Subtitle C.  Section 3010 requires any




person generating or transporting hazardous wastes or owning or



operating any facility for treatment, storage, or disposal of hazar-



dous wastes to file a notification with the Administrator within 90




days of the promulgation or revision of regulations under Section



3001 identifying or listing such wastes as hazardous.  The regula-



tions under Subtitle C respecting requirements applicable to the




generation, transportation, treatment, storage, or disposal of



hazardous waste shall take effect six months after their date of



promulgation.




     2.2.12  Section 3011 of Subtitle C.  Section 3011 authorizes to




be appropriated $25 million for fiscal years 1978 and 1979 "to be



used to make grants to the States for purposes of assisting the




States in the development and implementation of authorized state



hazardous waste programs," and provides for the allocation of the



amounts authorized to be appropriated.




2.3  Related Federal Legislation



     A number of other Federal Acts are specifically addressed within



RCRA.  Section 1006 of RCRA states that "nothing in this Act shall be




construed to apply to...any activity or substance which is subject



to the Federal Water Pollution Control Act (33 U.S.C. 1151 and
                                 2-13|

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following), the Safe Drinking Water Act (42 U.S.C. 300f and follow-

ing), the Marine Protection, Research and Sanctuaries Act of 1972 (33

U.S.C. 1401 and following), or the Atomic Energy Act of 1954 (42

U.S.C. and following), except to the extent that such application...

is not inconsistent with the requirements of such Acts."

     The Federal Water Pollution Control Act contains a number of

sections which apply directly to the handling and disposal of

hazardous wastes.  Several of these sections are summarized below:

     •  Section 301, dealing with effluent limitations, prohibits the
        "discharge of any radiological, chemical, or biological
        warfare agent or high-level radioactive waste into the
        navigable waters."

     •  Section 304(f) requires EPA to publish guidelines for the
        pretreatment of pollutants which are determined not to be
        susceptible to treatment by publicly-owned treatment works.
        In accordance with the Clean Water Act of 1977, EPA is also
        directed to regulate the control of plant site runoff, spil-
        lage or leaks, sludge or waste disposal, and drainage from
        raw material storage which are associated with the industrial
        manufacturing or treatment process of the designated
        industries, which may contribute significant amounts of pol-
        lutants to navigable waters.

     •  Section 306 deals with new source performance standards for
        industrial point sources.  EPA is authorized to determine the
        best available demonstrated control technology, and require
        its installation for specified categories of sources.  If EPA
        determines that a zero-discharge standard is practicable,
        such a standard may be set.

     •  Under Section 307, the Administrator is directed to publish a
        list of toxic pollutants and effluent limitations.  These
        limitations may constitute an absolute prohibition against
        discharging.  Additionally, EPA must publish pretreatment
        standards requiring any industry discharging into a municipal
        sewage treatment plant to pretreat its effluent so that it
        does not interfere with the operation of the plant or pass
        through the plant untreated or without adequate treatment.
                                2-14 .

-------
     •  Section 311 is designed to protect the navigable waters and
        shorelines from "hazardous substance" discharges.

     •  Under Section 402, each state government is responsible for
        issuing permits under the National Pollutant Discharge
        Elimination System.  While EPA issues guidelines for state
        permit programs, it retains the right to review a state-
        issued permit affecting another state's water resources.

     •  Section 405 requires that a permit be issued by EPA for the
        disposal or relocation of sewage sludge that could affect the
        navigable waters.  Such disposal is prohibited without a
        permit.

     •  Under Section 504, the EPA Administrator may bring suit
        against any person contributing to a pollution source causing
        an imminent and substantial endangerment to public health or
        welfare.  In accordance with the 1977 amendments, EPA is also
        authorized to provide assistance in emergencies which may
        present an imminent and substantial danger to public health
        on welfare.  EPA may authorize emergency assistance "to prev-
        ent, limit, or mitigate the emergency; when "there is an im-
        mediate significant risk to public health or welfare and the
        environment;" and when "such assistance will not otherwise be
        provided on a timely basis."

     The Safe Drinking Water Act of 1974 authorizes EPA to regulate

underground injection of wastes (and other substances) to protect

underground sources of drinking water.  It also authorizes the EPA

Administrator to conduct a study of the impacts -on underground water

supplies of surface water disposal of wastes.

     The Marine Protection, Research and Sanctuaries Act of 1972

prohibits the marine transport and disposal into U.S. territorial

waters of any radiological, chemical, or biological warfare agents,

high level radioactive wastes, or any other material, except as

authorized by Federal permit.  In the granting of permits for ocean

dumping, EPA must consider "appropriate locations and methods of
                                2-15

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disposal or recycling, including land-based alternatives, and the




associated impacts of such actions.



     The Atomic Energy Act of 1954, as amended, authorizes botn the




Atomic Energy Commission and private industry to regulate the



disposal of byproduct, source, or special nuclear materials.



     In addition to the four acts specifically referred to in Section




1006 of RCRA, several other Federal acts affect the management of



hazardous wastes.  Selected acts are summarized below.



     The Toxic Substances Control Act of 1976 authorizes the regula-




tion of hazardous substances before they become wastes.  EPA is




authorized to require that data be developed by manufacturers con-



cerning the effects of chemical substances and mixtures on health and



the environment when EPA feels that such chemicals present an unrea-




sonable risk of injury to health or to the environment.  EPA may also



issue an order prohibiting or limiting the manufacture, processing,




distribution, or disposal of specified substances.



     The Clean Air Act of 1970 (Section 112) and its amendments



authorize the EPA to set standards for hazardous air pollutants at




any level which provides an ample margin of safety to protect public



health.  In accordance with the 1977 amendments, the Administrator



may instead promulgate design or equipment standards to protect




public health with an ample margin of safety.  The control strategy



of standards and/or design plans is meant to protect the public
                                 2-16

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health and welfare by placing the burden of standards compliance on

the air polluter.

     The Occupational Safety and Health Act of 1970 is designed to

protect workers from occupational hazards,  including hazards

associated with contact of hazardous materials.   Section 6(b)(5)

deals specifically with toxic materials, requiring the Secretary of

Labor to "set the standard which most adequately assures...that no

employee will suffer material impairment of health or financial

capacity" from regular exposure to such hazards.

     The Federal Insecticide, Fungicide, and Rodenticide Act,  as

amended by the Federal Environmental Pesticide Control Act of  1972,

requires EPA to establish procedures and regulations for the disposal

or storage of packages, containers, and excess amounts of pesticides

and to accept at convenient locations for safe disposal, those

pesticides whose registration has been cancelled or suspended.

     Under the authority of the Hazardous Materials Transportation

Act of 1974, the Department of Transportation promulgated regulations

listing hazardous materials and specifying procedures to be  followed

when transporting those materials.  Furthermore, the responsibility

for documentation, prevention, and containment of spills of  oil and

hazardous materials is divided between the Department of Transporta-

tion (including the U.S. Coast Guard) and the Environmental  Protec-

tion Agency under the Hazardous Materials Transportation Act of 1974

and the Federal Water Pollution Control Act as amended by the  Clean

Water Act of 1977.
                                 2-17

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     The Armed Forces Appropriating Authorizations of 1971 prohibits

the disposal of any chemical or biological warfare agent "within or

outside the United States unleoo such agent has been detoxified or

made harmless to man and his environment unless immediate disposal is

clearly necessary, to safeguard human life."

2.4  The Status of State Solid Waste and Hazardous Waste
     Legislation

     Every state has addressed the hazardous waste problem to at

least a limited degree, with the level of state control over hazar-

dous waste presently ranging from essentially none to full and

comprehensive programs.  The majority of states exercise their

legislative authority over hazardous wastes under their existing

solid waste legislation, with authority extended under broadly-

worded provisions that do not contain guidelines, criteria, or

regulations specifically dealing with hazardous waste.  As a result,

enforcement and management are largely a matter of individual inter-

pretation by state regulatory authorities, with most states exer-

cising their legislative authority on a case-by-case basis.  In some

states, the principal regulatory control of hazardous wastes is

divided between two agencies.

     Table 2-1 presents a summary of the extent of authority and con-

trol exercised by each state and U.S. territory as of 1978, and the

principal regulatory agency responsible for control within each state

and territory.  In accordance with the Solid Waste Disposal Act, all
                                2-18

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                                   TABLE 2-1
                  STATE REGULATION AND CONTROL  AUTHORITY*








STATES
Allhana
Aliaka
Arlcoaa
Artinaia
Calif orala
Colorado
Coanacclc.it
Dalavnn
Olicrlec of CaluabU
Plorldi
Caorila
Bavall
Idaho
Illlnola
1..XI-...
tova
Zaaaaa
Kaacucky
Loulalana
Malaa
Maryland
naiiachiiaat ta
Hlchllan
MlaniBoca
Hlailailppl
Hlaiourl
noncana
•abraaki
Ilavada
?•« Bamam
Raw Jaraay
Ian Tork
forth Carolina
•torch Dakota
Ohio
Oklahoaa
Onion
paanayLvanla
Ihoda laliad
South Carollni
South Dakota
TaoBMiaa
TBKU
otab
Virneat
Virginia
Uaablnitaa
UalE Vlrilnla
Ulaconaln
Uycaiag
D S. Tarrleorlait
ban.
Sanoi
Paclllc laliadl
Piarto Rico
Virgin Iilandi







nuciPAL lEcuunn
AGBUT
Dapt ol Public Baaltb
Dapt ol Environ Coniarvatlon
Oapt ol Bailth Sirvleaa
Pollution Control 4 Eeololy
Dapt ol Public Hialth
Dapt ol Hallch
Dapt. ol Environ. Protactlon
Dope, ol .lot laaourcu 1 Environ Control
tavirOB. Hoallh Admin -Dipt of lavlroa. S«rv
Dapt. of Environ. Boaulatloa
DOPE ol BBE. laaaurcia
Offlco of Environ. Quality Control
Dapc. ol Baalth 4 Haltara-Olv. of Environ.
Ul. Enirounaatal Protactlon Agamy
Buaiii ul BulLa-Solla U.U 1»L tcrclm
Dapt. ol Environ quality
Dapt ol Baalth 4 Eavlronaant
Oapc of Nat. laaeureM 4 Environ. ProEacEloa
Dapc. for Baalch 4 nuaaa Xoaourcoo
Dope, ol EnvlroB rrotoetloa
Uitar RiBourcai 4 Eavlroa Haaleh Adnln.
Dipt, ol Environ. Quality
Dapt. of Rat. laaourcaa
Minn Pollution Control Aaaney
Board of Bealch
Dipt, of Hie Eaauurcia
Dipt, of Baalth ana Eavlroa Sclancia
Dapc of Environ. Control
Dipt, of Ceaaarvatton 6 Nat. BoiourcM
Ifcar of Ranch 4 U-lfara
Dipt of Environ. Procactloa
Dipt, of Envlroa. CoaiorvatloB
Dipt: of BUBBB Baaourcaa
Dipt of Baaltb
Ohla EnvlraaBaatal Protactlan Aganey
Dipt of Baalth
Dipt of Environ. Duality
Dapt of Environ laaourcaa
Dapt. of Baalth
Dtpt. of Baalth 4 Environ. Control
Dipt, of Environ Protactlon
Dapc of ruhlle aailth
Dipt of Baalth; Dipt of Uacar Kaaourcai
Dope of Baalch
Agoacy for Environ. Coaaervaelon
Dipt, of Baaltb
Dipt of Ecology; Baalch Dapt
Dipt, of Bat laaourcia. Dapt of Baalth
Dipt of Nat. Baaaunia
Dipt, of Hatar QuallEy

Guam EavlraDaaaeal Pncaeeloa Aganey
EavlrouantAl Qiallty Coaaiaiioa
Truat Tarrltory Environ. Protactlon Board
Envlnnmancal Qiallty Board
Dipt, of Public Uarka






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                                        2-19

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states currently have laws regulating the management of solid wastes.




Even if no additional legislative action has been enacted within a




particular state, the management of hazardous wastes could be regula-




ted, to some extent, under this existing solid waste legislation.




However, the effective regulation of hazardous wastes requires the




application of significantly different management standards than does




the regulation of conventional solid waste.  Furthermore, solid waste




legislation must often be interpreted broadly to be effectively




extended to the control of hazardous waste.  Also, while various




aspects of hazardous waste management could be exercised under




existing authority, few designated regulatory agencies currently have




the resources or manpower necessary to run an adequate hazardous




waste program.




     Enabling solid waste legislation is often derived from early




state environmental control laws through which the management of




solid waste was first addressed.  As indicated in Table 2-1, specific




solid waste laws may date back many years, with updated versions




incorporated as amendments.  Many of the more recent amendments




specifically address hazardous wastes, or mention hazardous wastes




along with solid wastes.  Almost every state so far has found it




necessary to amend their current solid waste legislation at least




once to meet the increased need for more control.  Each state and




territory now has at least one principal regulatory agency that has




the enabling authority to control hazardous wastes.  State authority
                                 2-20

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to regulate hazardous waste is difficult to compare from one state to
another because the legislation allows widely varying individual
interpretation of the authority to be exercised.
     Fifteen states have passed separate and specific laws govern-
ing the management of hazardous wastes as of 1978.  In these cases,
authority is clearly distinguished and hazardous wastes are defined
for control purposes.  Although the comprehensiveness of these laws
varies among states, management plans and approaches generally follow
the requirements given in RCRA.  In addition to these 15 states,
another 10 states and one territory have proposed legislation that,
as of 1978, is pending approval of state legislatures.  These
proposed laws have been presented either as a bill, separate from any
authority designated under a state's existing solid waste
legislation, or have been presented as an amendment specifically
governing hazardous wastes under a state's existing solid waste
legislation.  The remaining states use existing solid waste
legislation to govern .hazardous wastes.
     Host states do not have specific regulations or guidelines for
hazardous waste management.  In those that do, the strength of
promulgated regulations may be a matter of the interpretation given
by the particular state.  Regulations may take the form of an amend-
ment to the existing solid or hazardous waste legislation, or may be
a separate document generated and used by the principal state re-
gulatory agency.  In some states, the existing regulations may
clearly distinguish between the designated levels of authority over
                                2-21

-------
hazardous wastes, with specific criteria and procedures described,
while in other states the regulations may limit the scope of
authority to a particular hazardous waste category, such as pesticide
disposal.  As shown in Table 2-1, as of 1978 16 states have
promulgated specific regulations or guidelines for the management of
hazardous wastes, and an additional four states have proposed such
regulations.  No attempt has been made to compare the equivalency of
these regulations.
     As indicated in Table 2-1, all but three of the states have
addressed the identification of hazardous waste in the definition
section of their general solid waste legislation or within a
particular section of the solid waste legislation.  The other three
states have defined hazardous wastes under separate hazardous waste
legislation that has been proposed or passed.
     Collectively, as of 1978 at least 37 states and two territories
have addressed the management of hazardous waste to a limited extent
within their existing solid waste regulations.  As illustrated in
Table 2-1, hazardous wastes may be either addressed "in part" for the
regulation of a particular activity, such as disposal procedures, or
may be specifically addressed as a separate section within the
general solid waste regulations.  When regulated under the authority
of existing solid waste laws, the management of hazardous wastes is
usually handled on a case-by-case basis, with little systematic
control on the various levels of hazardous waste management,
particularly for on-site activities.
                                2-22

-------
      Most of the states have initiated an effort to identify the




sources of hazardous waste generation within their boundaries by the



means of a survey.  In a few cases, a survey was not deemed necessary



since such sources were previously identified for control through the




use of state tax department listings or through industrial director-



ies in conjunction with a working manifest system.  As indicated in




Table 2-1, as of 1978 at least 24 states have completed such a



survey, and an additional nine states have surveys in progress.  Of



the remaining states, several have plans to conduct such a survey.



     Tables 2-2 through 2-7 are directed to the various aspects of



state hazardous waste management as they apply to generators, trans-



porters, treaters, storers, and disposers, respectively.  The speci-




fic control mechanisms included in the tables are some of those



included in Sections 3002 through 3004 of RCRA, addressing standards




applicable to each group involved in the hazardous waste management



process.  The tables should not be interpreted as a comparison of




equivalency but, rather, are presented to illustrate the presence and



form of the mechanisms by which hazardous wastes are being managed as




of 1978.  In four states, proposed regulations are far enough along




the legal path to be included in these tables for discussion



purposes.  In many states, legislation is being drafted for future



consideration; however, the majority of states are waiting for



Federal regulations on hazardous wastes to be approved before issuing



their own state regulations.
                                2-23

-------
                                 TABLE 2-2

STATE  LEGISLATION  APPLICABLE TO HAZARDOUS  WASTE  GENERATORS*

Stataa
Alabaoa (propoMd)
Alaata
Arizona
California
Colorado
Connaetlcut
Dalavara
Olatrlct of Columbia
Florida (propoiad)
Gaorila
Hawaii
I Ulioli
Indiana
Ion
Kanaaa
Kantuckr
Nalna
Maryland
Hlchl(aa
Hlaalaalppl
Mlaaourl
Montana
Hebnika
tta» BampiUn
N« Jaria?
.Saw Tork
north Carolina (propoMd)
Rorth Dakota
Ohio
Oklahna
Onion
Pointy Irani*
Ihoda laland
South Carolina
South Dakota
Teoaaaaaa
Tana
Utah
Varaoot
Virginia
Wuhlngton
Wait Virginia
Wlaconaln
fa
X

X
X




X

X
X

X

X

X
X
X

X

X

X
X

X
X

X
X
X


X

X
laalfaat
'fa
X


X







X

X

X
















X



X


%
X

X
X




X

X

X

X
X

X
X
X

X

X


X

X
X


X



X
X
X
Bacord-
kaiplni
*fa
X


X





X



.


















X



X


'//*
y/i
X

X
X




X

X
X
X

X
X

X
X
X

X

X


I

X
X


X



X
X

Raportlni
fA
i


X





X

X




















X



X









































         •Intonation prutntad In thla tabla «a rocalvad In perioaal comnlcatlon vlth rapnaentatlvai
          froo tha Stata offlcaa llatod In labla 2-1 and cha Environmental Protection
                                     2-24

-------
                                    TABLE  2-3

STATE LEGISLATION APPLICABLE  TO  HAZARDOUS  WASTE TRANSPORTERS*
Scau
Alabsae (proposed)
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
District of ColuabU
Florida (proposed)
Ceorila
Hawaii
Idaho
Illtaoli
Indiana
loua
Xanaaa
Kentucky
Louisiana
Maine
Maryland
Massif hiisefts
Hlchlgin
linnesota (propoaad)
Mississippi
Hisaourl
Montuia
Nabruka
Nevada
Raw Hampshire
Hav Jersey
S«v Xaxleo
»«v Vork
Borth Cuolina (propoaad)
north Dakota
Ohio
Oklahoma
Oragon
Pennaylvanla
Ihoda bland
Soutb Carolina
loath Dakota
Tannaaaao
Taxai
Utah
VarDont
Vlrilnla
Uaahiaston
vaat Vlrilnla
Vlaconaln
Wjraalnn
//t
X
X
X
X
X
X
X

X
X
X

X
X
X



X

Fraltt
•tonlfaat
Record-
kaaplni
Repottlnl
Inspection

X

X
X


X




X
X
X


X
X
X
X
X
X
X




X
X
X
X


X
X

X
X

X
X







X
X



X
X

X
X
X


X

X
X
X
X


X
X
X


X
X





X

X








X

X
X
X


X

X
X



X
X
X









X







X
X
X
X

X
>
X

X
X
X
X



X
X
X
X
X

X
X





X








     •Information preacntad in thia tablo vaa received in personal cooounlcatloa with represencaclw
      froo the State offices luted In Table 2-1 and the Environmental Protecti
     Uncludes pamlt. registration, license, and certification.
                                        2-25

-------
                                TABLE 2-4

STATE LEGISLATION APPLICABLE TO HAZARDOUS WASTE TREATERS*
Statea
Alabama (propoaad)
Alaika
Ariiona
Arkaaaaa
California
Colorado
Connecticut
Delaware
Dlitrlct o« Columbia
Florida (propoied)
Georgia
Hawaii
Idaho
Illlaole
Indiana
Iowa
Xaaaaa
Ceatuck;
loulalana
Maine
Maryland
Maasachuaetts
Michigan
Mlnneaou (propoied)
MlMUllppl
Hlaaauri
Montana
Hebreaka
Havana
><• nampablce
Hew Jeraay
Hew Mexico
new lark
north Carolina (propoied)
north Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Bhode Iiland
South Carolina
South Dakota
Tenaeaiee
Teiaa
Utah
Virginia
Vaahlnjton
Ueic Virginia
Uiaeonaiii
uyoilng

Perait
Hanifeot
Ricord-
kaeplnn
Reporting
Inapaetlon
^/$$/J$//l$/$$//J.
X
X
X
X
X
X
X
X


X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X




X


X
X
X

X
X
X
X
X



X

X
X
X
X
X
X
X
X
X
X
X
X
X






X


X
X
X
X
X
X
X
X


X
X
X

X
X
X
X
X
X
X
X
X
X





X


X
X

X
X
X
X
X

X
X
X
X

X
X
X
X
X
X
V
X









X
X


X
X
X
X
X
X

X
X
X

X
X
X
X
X
X
X
X
X
X
X


X
X
X


X
X



r




   •lafonucion proaaiccd In thla Gobi* vu received la personal cooBimLeatlon ^leb repr
    from che Seat* office* Lilted in Table 2-1 and the Environmental Protection Agency.
                                     2-26

-------
                          TABLE  2-5
STATE LEGISLATION APPLICABLE TO HAZARDOUS  WASTE STOKERS*
1 Panic 1 Manlfeac
//////////////.
Sutts
Alabama (proposed)
Arizona
Arkansas
California
Colorado
Connacticut
Dalavara
Dlacrlct of Columbia
Florida (propoied)
Caorsla
Hawaii
Idaho
Indiana
Ion
Kentucky
toulltua
Malna
Maryland
Maeaachueetta
Mlehltaa
Mlaalaalppl
Mlaaourl
Montana
i Kabraaka
Ravada
Hew Banpehlre
i Haw Jeriay
rtew lort
Horch Carolina (propoaad)
! Sorth Dakota
1 Ohio
Oklahoma
• Oregon
renniylvania
Rhode Iiland
Soutb Carolina
South Dakota
Tannaaaea
Utah
Vanoat
Vlrjlnla
Uaahlngun
Veat Virginia
Vlaeonala
Vyaplni
•Intonation praaancad In c
fraa eha Scaca offleea lla
///
*
X

x

X
X
X
X

X
X


X


X
X
X
•




X
X
X
X

X
X


X





/







X


X















X
X
X











r*
X
X




X

X

xt






X
X
X




X

X
X
X

X
X

X






/ft




































X



/4i
X
X




X

X


X





X
X
X







X
X

X
X








kSX 1 ««p<'«i»«
?//$/Ł//////.









































hla cabla waa received in paraonai rmnmmira
cad la Tabla 2-1 and Bnvlranuncal Protaccloi
/**
X
X




X

X


X





X

X







X
X

X
X








ton W1C
\ Aaaney
(








































n reprei
•/**
X
X

X

X
X
X
X

X



X


X
X
X







X
X

X
X


X





encaciv
Inspection
////
/* °










X





























/







































*
 tApplieabla Co off-*ita only
                              2-27

-------
                          TABLE  2-6
STATE LEGISLATION APPLICABLE TO HAZARDOUS WASTE DISPOSERS*
Statea
Alabana (propoied)
Alaafca
Arizona
Calif ora la
Colorado
Connecticut
Delaware
Dlatrlct of Columbia
Florida (propoaed)
Ceorila
Hawaii
Idaho
Ullnole
Iowa
Xaoaaa
Kentucky
louialane
Heine
Maryland
Maaaachuaatta
Michigan
Miauaota (propoaed)
Mlaalailppi
MUaourl
Montana
Kahraaka
•evade
Haw Baapahlre
Rev Jareey
Hew Maalco
Haw Tork
North Carolina (propoaad)
North Dakota
Ohio
Oklahome
Oreaon
Femaylnnla
Rhode leland
South Carolina
South Dakota,
Taonaaaee
Taxae
Utah
Vamont
Virginia
Ueohlaacon
Veat Virginia
Viacom in
Wyonlnj
•Inforaaclon preeenced in
from the scace off leea 111
t>
X
X
X
X
xt
X
X

X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
I
hla cab
cad in 1
Panic
f






X

X

i
X
X
X
X
X
^
X
X
X





X
X
X
X
X
X
X
X
X
X
X
X
e ware received
eble 2-1 end Q
Xaaifaac
r















X
^
X
X
X
X
X
X
X
X

X
X
X
X
X


X
X
X
X
X

X
X
X
Record-
keep la(
/&



X













X
i
X

X
X
X
X
X
X

X
I
X
X
X



X
X

X
in personal commie* clou vl
vinmenul Protection Agency
Reporciai




X














^
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X
X
X
X
X
X
ch repreeentatl
Enapectlon



X


X
X
X
X






X


ves
f



  toff-alta only.
                             2-28

-------
                                TABLE  2-7

               STATE APPROACH  TO  HAZARDOUS WASTE
          DEFINITION,  MONITORING, AND  ENFORCEMENT*
1 Uo*te Definition ikmltorlog 1 Enforcement
1 1
// /, //////ft/////
State
ftUhua (propoaed)
Maaka
Ar it ana
Ukaniae
California
Colorado
Connecticut
Delaware
Dlatrlct of Coliabla
Florida (prapoud)
Georgia
Brail
Idaho
Ullnoli
[nd<«i«
ton
Kanaaa
Kentucky
Loulalana
Halne
Maryland
Maeeachitetta
Michigan
Nlmeaoca (propoeed)
Xleolielppl
Hlaaoticl
Haacaaa
Nebratka
Reyeda
Soy HdapflhlrQ
Kay Jeraey
Rev Kazlco
Xau York
north Carolina (propoaed)

Ohio
OUahcoa
Oreton
FaanaylTiala
Uada IiUnd
South Carolina
South Dakota
Tennaaaae
Toaa
Utah
7anont
Virginia
Haahlagtoa
»aac Virginia
Ulacoaaln
Uvemlns
I



I
X











z

X


X

X


X




X




X
X


X


X

X
X
X



/




X











X



X
X




X




X




X



X






X



/
X

X

X
X
X


X



X

X
X

X

I
I

X

X
X
X


X
X
X
X

X
X
X

X
X


X
I


X
I
X

/
X



X





X


X


X






X







X




X


X
X


X



X
xt


/
X
X
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

X


X
X

X
X
X
X
X
X
X
X
X
X
X
X

X
/


X

X




X
X


X


X
X


X


X

X
X
X


X
X
X


X
X
X

1
X


X



X
X
X

I



















































• Intonation preeeued In chla table wae racalTed In pereonal coaaunlcattona vlth repreaentatlvea
 frm the Sceta off leu llacad In Table 2-1 and the BMronaencal Protection Agency.

t Ueat Virginia - Standards for Oa-Slte Only
                                    2-29

-------
     The various regulatory criteria presented in Tables 2-2 through




2-7 relate to general enabling authority or to more detailed stan-




dard? or regulations.  In a relative sense, the enabling authority




provides the formal power to regulate hazardous waste activities



while standards and regulations provide specific requirements.  En-



abling authority usually indicates that the particular state has the




power to control a particular acitivity.  In the absence of specific




standards or regulations, this authority may be exercised on a case-




by-case basis, or it may extend to the regulation of only a parti-



cular management activity, such as disposal.  In examining each of




these tables, it should be remembered that the status of state legis-




lation is in flux and that these tables are meant to present only a



general view of the nationwide status of hazardous waste management.




     Appendix A provides a description of the specific hazardous



waste management regulations for selected states as summarized in



Tables 2-2 through 2-7.  These tables illustrate the general differ-




ences in existing regulatory approaches while the information in Ap-



pendix A provides more specific detail.



     2.4.1  The Status of State Regulatory Criteria Applicable to




Generators of Hazardous Waste.  Table 2-2 illustrates the status of



the regulatory criteria that are applicable to generators of hazard-



ous waste as of 1978.  (Additional regulatory criteria applicable to




generators who treat, store, or dispose hazardous waste on-site are



discussed in Sections 2.4.3, 2.4.4, and 2.4.5.)  Twenty-five states
                               2-30

-------
currently have (or have proposed) the enabling authority over




manifest-type requirements pertaining to generators of hazardous




wastes; ten of these states have promulgated (or have proposed)




standards for such manifests.  Twenty-three states have (or have




proposed) the enabling authority over recordkeeping requirements




applicable to generators.  Seven of these states have (or have




proposed) recordkeeping standards for hazardous waste generators; one




additional state also has recordkeeping standards.  Twenty-three




states currently have (or have proposed) a reporting requirement




applicable to generators of hazardous waste.  Eight of these states




have (or have proposed) reporting standards that apply to these




generators; one additional state also has reporting standards.




     2.4.2  The Status of State Regulatory Criteria Applicable to




Transporters of Hazardous Waste.  Table 2-3 presents the status of




the regulatory criteria that are applicable to transporters of




hazardous waste as of 1978.  Twenty-three states have (or have




proposed) the enabling authority to require transporters of hazardous




waste to be permitted, licensed, registered, or certified.  Ten of




these states have (or have proposed) standards for the permitting,




licensing, registering, or certifying of hazardous waste transport-




ers.  Twenty-five states currently have (or have proposed) the




authority to initiate a manifest system applicable to such transport-




ers, eleven of these states have standards for manifests.  Twenty-




three states have (or have proposed) the enabling authority over




recordkeeping requirements; twelve of these states have (or have



                                2-31

-------
proposed) recordkeeping standards.  Nineteen states have (or have




proposed) the authority to require reporting requirements; while



eight of the states have (or have proposed) reporting standards.




Eighteen states have (or have proposed) the enabling authority for




inspection of transporters; five of these states have regulations or



standards for inspection.




     2.4.3  The Status of State Regulatory Criteria Applicable to




Treaters of Hazardous Waste.  Table 2-4 illustrates the status of the



regulatory criteria that are applicable to on-site and off-site




treaters of hazardous waste as of 1978.  Twenty-five states have (or



have proposed) the enabling authority to require such treaters of



hazardous waste to be permitted; nine of these states have



promulgated (or have proposed) permit standards.  Twenty-three states



have (or have proposed) the enabling authority to require treaters to



comply with a manifest system; ten of these states have promulgated



(or have proposed) manifest standards.  Twenty-two states have (or



have proposed) the enabling authority to regulate.recordkeeping



requirements; eight of these states have promulgated (or have



proposed) recordkeeping standards for treaters.  Twenty states (or




have proposed) the enabling authority to require reports from



hazardous waste treaters; six of these states have promulgated (or




have proposed) reporting standards for such treaters.  Twenty-four



states have (or have proposed) the enabling authority to inspect



hazardous waste treatment facilities; seven of these states have (or




have proposed) inspection standards.



                                2-32

-------
     2.4.4  The Status of State Regulatory Criteria Applicable to




Storers of Hazardous Waste.  Table 2-5 shows the status of the



regulatory criteria that are applicable to on-site and off-site




storers of hazardous waste .as of 1978.  Twenty-five states have (or



have proposed) the enabling authority to require permits of hazardous



waste storers; nine of these states have enacted (or have proposed)




permit standards for storage.  Twenty-one states have (or have



proposed) the enabling legislation to require compliance with the



manifest system.  Six of these states have promulgated (or have




proposed) standards for manifest compliance; one additional state



also has manifest standards.  Eighteen states have (or have proposed)



the enabling authority to require recordkeeping by the storer; six of




these states have (or have proposed) recordkeeping standards.




Seventeen states have (or have proposed) the enabling authority to



require reporting by storers of hazardous waste; five of these states



have (or have proposed) standards.  Twenty-three states have



indicated that they have (or have proposed) specified authority to



inspect hazardous waste storage facilities; five of these states (or




have proposed) have inspection standards.



    2.4.5  The Status of State Regulatory Criteria Applicable to



Disposers of Hazardous Waste.  The issue of the disposal of hazardous




waste has thus far received more legislative attention than has any




other hazardous waste management activity.  As of 1978 thirty-eight



states have (or have proposed) the legal authority to require permits






                                2-33

-------
for the operation of on-site and/or off-site disposal facilities




receiving hazardous wastes.  Seventeen of these states have



promulgated (or have proposed) standards specifically relating, to the



permitting of disposal facilities.  Twenty-five states have (or have



proposed) the enabling authority to require compliance with a




manifest system; twelve of these states have promulgated (or have




proposed) standards for manifest requirements.  Thirty-four states



have reported that they have (or have proposed) the authority to



require recordkeeping practices from hazardous wastes disposers;



fifteen of these states have (or have proposed) standards for the




recordkeeping requirements.  Twenty-nine states indicate that they



have (or have proposed) enabling authority to require hazardous waste



disposers to report on the materials being handled; thirteen of these




states have promulgated (or have proposed) standards for reporting.



Thirty-nine states have (or have proposed) legal capabilities to



inspect hazardous waste disposal sites; fifteen of these states have



(or have proposed) standards specifically relating to the inspection




requirements of disposal sites.



     2.4.6  The Status of State Hazardous Waste Definition, Moni-




toring, and Enforcement.  Table 2-7 presents the status of state



hazardous waste definition, monitoring practices, and enforcement




capabilities as of 1978.  While all of the states have a textual



definition of hazardous waste, several states have developed a more



specific definition of hazardous waste.  Seven states presently
                                2-34

-------
define hazardous waste exclusively by the use of criteria; one ad-




ditional state defines hazardous waste exclusively by a listing of



particular substances; eight additional states employ the use of both




criteria and a list.



     Both monitoring and enforcement refer to authority that is




generally exercised only over disposal activities; however, this



authority can be extended to include other hazardous waste management



activities.  Thirty states report that they have (or have proposed)



the enabling authority to control monitoring activities related to



hazardous wastes; tweleve of these states have promulgated (or have



proposed) standards with regard to monitoring procedures and re-




quirements.  One additional state also has such standards.




     Forty-five states have (or have proposed) some type of enabling



enforcement capabilities over hazardous wastes; twenty-four of these




states have (or have proposed) enforcement standards specifically re-




lating to hazardous wastes.  In most of the states, the enforcement



power is interpreted as an extension of the authority vested through



existing solid waste enforcement capabilities.
                                2-35

-------
3.0  DESCRIPTION OF THE BASELINE ACTION

     The baseline action is chat set of regulations and guidelines

initially developed by the U.S. Environmental Protection Agency in

response to the mandate of Subtitle C of RCRA.  Baseline regulations

have been developed under the mandate of Sections 3001 through 3006

and 3010 of Subtitle C.  These baseline regulations and guidelines

fall within several broad areas, as follows:

     •  Identification of hazardous waste subject to regulation;

     •  Control of hazardous waste from generation to ultimate dis-
        posal;

     •  Guidelines for state hazardous waste programs.

     Because of the extensive nature of the baseline regulations, a

summary of the most relevant points is presented in the following

sections.  The specific baseline regulations being assessed in this

EIS are described in Appendix B.

3.1  Criteria, Identification, and Listing of Hazardous Waste
     (Section 30017

     The Section .3001 baseline regulations delimit wastes-that are to

be considered hazardous and, therefore, to be brought under regula-

tory control.  The regulatory approach taken is to use both identi-

fying characteristics and lists of hazardous wastes, industrial

processes, and sources to be brought under regulatory control.

     The characteristics used to delimit hazardous waste are as fol-

lows :
                                  3-1

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     •  Ignitability;

     •  Corrosiveness;

     •  Reactivity;

     •  Toxicity.

     Any waste which exhibits any of these characteristics or which

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

and would have to be managed pursuant to the Subtitle C regulations.

The hazardous waste lists identify specific hazardous wastes (e.g.,

water-based paint wastes), sources generating hazardous waste (e.g.,

various departments of hospitals), and processes which generate haz-

ardous waste (e.g., asbestos wastes from cell diaphrams in production

of chlorine); and indicate for each listed waste or waste stream the

reason for its is inclusion (e.g., ignitable, corrosive, reactive,

toxic).  A generator producing a listed waste may be exempted from

regulation providing that he could demonstrate that the reason for

listing that waste does not apply to his particular waste stream.

The methods to be used for such a demonstration include the four

identifying characteristics plus tests for low-level radioactivity,

infectiousness, mutagenic activity, bioaccumulation potential, and

toxicity.

3.2  Standards Applicable to Generators of Hazardous Waste (Section
     3002)

     The Section 3002 baseline regulations identify generators of

hazardous waste who would be subject to regulation and specify the

responsibilities of these generators.  The generator requirements


                                 3-2

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would apply Co chose persons or Federal agencies, except households,




who produce and dispose more Chan 100 kilograms (abouC 220 pounds)



per month of wastes identified as hazardous under the Section 3001



regulations.  Any person or Federal agency producing and disposing




100 kilograms or less per month would not be required to comply with




the generator regulations.  Also any generator engaged solely in



retail trade or principally in fanning would have to comply with Che




regulations only with regard Co wasCe automotive oil; however, any



person (e.g., a transporter) could assume a waste automative oil



generator's total liability for compliance with the Section 3002



requirements, providing a written transfer of liability contract is




in effect.  Generators excluded from compliance with the Subtitle C



regulations would, however, still be obligated to dispose their



hazardous wastes in an accepCable manner, e.g., in a landfill chat




meets RCRA Subtitle D criteria.



     The requirements of the generators of hazardous waste fall




within the following broad categories:



     •  Compliance with the manifest system;




     •  Reporting;



     •  Recordkeeping;




     •  Containerization;



     •  Labeling;



     •  Furnishing information on general chemical composition.



     The key aspects of these regulations, and the greatest benefits



to be derived, revolve around the development of a manifest system




                                 3-3

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and periodic reporting requirements.  The manifest system would



require that detailed information regarding each off-site shipment of



hazardous waste is recorded, accompanies the waste during transport,



and serves as the basis for filing periodic reports.  This system



would serve to promote proper delivery and disposal of all hazardous



wastes consigned by the generator.  Other aspects of these




regulations (e.g., containerization and labeling) have been developed



to be consistent with existing Department of Transportation (DOT)



regulations.




     The full set of reporting and recordkeeping requirements under



Section 3002 would be applicable only to generators designating




hazardous wastes for off-site treatment, storage, or disposal in a




facility not owned by the generator.  These generators would have to



submit both an annual report summarizing all hazardous waste ship-



ments and a quarterly report for hazardous wastes which were shipped,



but not received by a permitted facility (as evidenced by the failure



to receive -the signed original of the manifest or delivery document



from the designated disposal facility).  Generators designating




hazardous wastes for disposal at an off-site facility owned by the



generator and located within the same state as the generator would




not have to comply with any of the reporting or recordkeeping




requirements (although the facility itself would be subject to



reporting and recordkeeping requirements under Section 3004).
                                 3-4

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     Generators designating hazardous wastes for on-site treatment,

storage, or disposal would be exempted from manifesting, contain-

erization, and labeling requirements, though they would have to make

an annual report, keep records, and comply with the Section 3004

regulations.

3.3  Standards Applicable to Transporters of Hazardous Waste (Section
     3003)

     The Section 3003 baseline regulations identify those transpor-

ters who are subject to regulation and specify requirements that fall

within the following broad categories:

     •  Recordkeeping;

     •  Acceptance and transport of hazardous waste;

     •  Compliance with the manifest;

     •  Delivery of the hazardous waste to the designated, permitted
        facility;

     •  Emergency situations;

     •  Marking and placarding of vehicles.

    • Many of these controls are currently imposed upon some trans-

porters of hazardous waste by regulations under the Hazardous Ma-

terials Transportation Act.  Therefore, the baseline regulations

within this section are designed to be consistent with current DOT

regulatory practices.  Further, the baseline regulations would extend

the DOT regulations to intrastate, as well as interstate, transporta-

tion of hazardous wastes.  The most significant additions to those

existing regulations affecting hazardous waste transport are the
                                  3-5

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manifest and delivery requirements that would assure that all

hazardous wastes are delivered to the designated permitted facility.

In the case of spills during transport, the transporter regulations

would require the transporter to immediately notify the specified

authority, to file a written report within 15 days, and to clean up

all spilled hazardous waste or take such action as required so that

the spilled hazardous waste no longer presents a hazard to human

health or the environment.

     The transporter regulations would apply to any person or Federal

agency transporting, within the United States, hazardous wastes that

require a manifest under the generator regulations and also apply to

any transporter importing a shipment of hazardous wastes from abroad.

Portions of the standards would also apply to any transporter who

consolidates and transports hazardous wastes not requiring a mani-

fest.  The transporter regulations would not apply to persons or

Federal agencies transporting hazardous wastes solely on the site of

generation or solely on the site of a permitted hazardous waste

management facility.

3.4  Standards For Owners and Operators of Hazardous Waste Treatment,
     Storage, and Disposal Facilities (Section 3004T

     The Section 3004 baseline regulations are intended to provide an

adequate degree of environmental and public health protection during

the treatment, storage, and ultimate disposal of hazardous wastes.

These standards include requirements relating to the general aspects

of facility operations (i.e., site selection, monitoring, training,


                                  3-6

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 security, emergency procedures, and contingency plans, inspections,




 closure, financial requirements, and recordkeeping/reporting) as well




 as standards applicable to specific types of treatment, storage, and




 disposal facilities (i.e., storage tanks, containers, landfarms,




 landfills, surface impoundments, basins, incinerators, and chemical,




 physical, and biological treatment facilities).




      With the few exclusions noted below, these standards apply to




 owners and operators of any facility that treats, stores or disposes




 any quantity of waste identified as hazardous under the Section 3001




/regulations, except 'special wastes'.  All owners and operators of




 facilities that treat, store, or dispose 'special wastes', and no




 other hazardous waste, would have to comply only with selected




 general facility standards.  The Section 3004 standards do not apply




 to on-site storage by generators who store their own wastes for less




 than 90 days prior to subsequent transport of-site, but do apply to




 any such on-site storage which lasts for 90 days or longer.




      Certain practices that are controlled under other Federal acts




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




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




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




 charges under a National Pollution Discharge Elimination System




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




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




 and vessels.  However, the treatment, storage, and disposal regu-




 lations would apply to above ground storage or treatment of hazardous




                                 3-7

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wastes prior to underground injection, on-shore facilities associated



with ocean dumping activities, and surface impoundments associated




with NPDES permitted industrial wastewater treatment facilities and




hazardous sludges from such facilities.




     The Section 3004 baseline regulations have been divided into




five major sections:  Human Health and Environmental Standards,




General Facility Standards, Storage Standards, Treatment and Disposal



Standards, and Special Waste Standards.  Some of the standards are




accompanied by notes which either provide further explanation of the




standard or specify a basis for permitting authorities to allow



deviations from the standard.  No deviation is allowed from standards




which do not have accompanying notes.




     There are overriding standards for human health and environ-



mental protection:  Groundwater, Surface Water, and Air.  They



establish criteria for human health and environmental protection and




are intended to assure that the design, construction and operation of



hazardous waste facilities does not adversely affect human health or



the environment by degrading the groundwater, surface water, or air.



     The human health and environmental standards are used by EPA in




drafting and evaluating more specific standards and can be used in




designing facilities.  While human health and environmental standards




would be legally binding, they are not intended to be directly



enforced.  They are designed to be used on a case-by-case basis only
                                 3-8

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where there is reason to believe (e.g., a third party challenge) that




the standards are insufficient for human health and environmental




protection.  In such cases, EPA may monitor to determine if the



facility is in compliance with the human health and environmental




standards at issue.



     Furthermore, it is the burden of the government to show that a



facility is in violation of a human health and environmental standard



if the facility is in compliance with all other applicable standards.




Therefore, if a facility is in compliance with all other applicable



standards, but is, nevertheless, discovered to be violating a-human



health and environmental standard, no penalty would be assessed to




the facility owner/operator for the period of time prior to that



discovery, and a reasonable time would be allowed for the facility to




be brought into compliance.




     Specific standards which provide measurable criteria and a means



to achieve the human health and environmental standards are necessary



for practical implementation of these regulations, and are required




by the statute.  Thus, the general facility standards, the storage



standards, and the treatment/disposal standards translate the human




health and environmental standards into usefully enforceable require-



ments.  The details of these standards are presented in Subpart D of



Appendix B.
                                  3-9

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     General facility standards apply to every type of hazardous



waste management facility.  They must be complied with at all times



by all regulated facility owners/operators.  If these standards are




not complied with, the facility owner/operator would be considered to




be in violation of these regulations and could be subject to enforce-



ment action for the entire period of the violation.  Unless exempted,




the facility owner/operator has the burden of demonstrating that



he/she is in compliance.  Facility owners/operators may be required



to monitor, report, and otherwise demonstrate compliance with the




general facility standards.



     In addition to the general facility standards, facilities which



store hazardous waste must also comply with general storage standards



as well as with standards which apply to storage tanks and storage




containers.  RCRA's definition of storage implies no discharge to



groundwater, surface water, or air.  The storage standards reflect




this intent.



     In addition to the general facility standards, facilities which



treat or dispose of hazardous waste must also comply with the general



treatment/disposal standards.  Facilities with incinerators; land-




fills; surface impoundments; basins; landfarms; or chemical,



physical, or biological treatment processes must comply with the




standards prescribed under these subsections.



     Several waste streams have been identified as being of special



concern due to their unique characteristics and the techno-economic
                                 3-10

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uncertainties regarding their disposal.  These 'special wastes' are

high volume wastes which are often disposed on-site by generators,

for which traditional land disposal technology is techno-economically

inappropriate, and whose environmental risk is ill-defined.  These

'special waste' streams include:  utility wastes (fly ash, bottom

ash), oil drilling muds and brines, cement kiln dusts, phosphate rock

mining and processing wastes, uranium mining wastes, and other mining

wastes.  In the event these wastes meet a hazardous characteristic or

are listed, unique facility standards will be developed for them.

However, these wastes would presently be subject only to general

standards for recordkeeping, reporting, etc.  EPA intends to

develop control technology standards for these wastes as soon as

possible.

3.5  Permit System for Treatment, Storage, or Disposal of Hazardous
     Wastes (Section 3005)

     Section 3005(a) of-RCRA requires "...each person owning or

operating a facility for the treatment, storage or disposal of

hazardous waste identified or listed under this subtitle to have a

permit issued, pursuant to this section."  In the baseline regula-

tions as presented in Appendix B, Subpart E, a hazardous waste

management facility is defined as any land and appurtenances thereto

used for the treatment, storage, and/or disposal of hazardous waste.

On the effective date of these regulations (i.e., 180 days after

their promulgation), no such facility would be allowed to accept
                                 3-11

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hazardous waste unless its owner or operator had applied for a per-
mit.  The purpose of such permits is to assure that facilities are
constructed and/or operated in a manner consistent with the objec-
tives of the Section 3004 standards.
     The Section 3005 baseline regulations would require that all
owners or operators of facilities treating, storing, or disposing
hazardous wastes obtain a permit prior to facility construction,
modification, or operation.  The regulations establish standards for
permit applications, permit issuance, and permit revocation.  Permits
would be issued for the projected life of the facility.  The owners/
operators of new facilities would be required to obtain permits prior
to construction and would have to certify that construction was
performed in compliance with the permit before commencing operation.
Special permits would be available for experimental facilities,
qualified hospital-medical care facilities, Publicly Owned Treatment
Works, and ocean dumping barges and vessels.
     The Section 3005 baseline regulations would also require the
circulation of a public notice of any tenative determination to
issue, deny, or modify a permit.  Within 30 days of publication of
the notice, any person would be able to request a public hearing on
the determination.  The Regional Administrator would decide whether
such a hearing is appropriate at his discretion.
3.6  Guidelines for State Hazardous Waste Programs (Section 3006)
     Section 3006 provides that states are to be encouraged to apply
for authorization to administer and enforce their own hazardous waste
                                 3-12

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program pursuant to Subtitle C.  Under the baseline regulations there



would be three types of authorization for which states could apply:




full authorization, partial authorization, or interim authorization.



     Full authorization would allow a state to carry out a hazardous




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



tial authorization would allow a state to administer and enforce



selected components of the program.  States would be considered for




partial authorization only if state legislative authority did not ex-



ist for all required program components.  In all cases, the combina-



tion of the state and the Federal program would have to meet the




requirements of a fully authorized program.  Partial authorization




would be granted for a period not to exceed five years, but could be



renewed.




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




ous waste program in lieu of the Federal Program under Subtitle C for



a period not to exceed twenty-four months, beginning on the date six




months after the date of promulgation of regulations under Section .



3001.  The purpose of interim authorization is to allow the state to



make an orderly transition from its present program to a program eli-




gible for full authorization.  The guidelines describe the substan-



tive and procedural requirements for States applying for authoriza-



tion, EPA's oversight of the State's hazardous waste program, and for




the withdrawal of authorization pursuant to Section 3006(e) of Sub-



title C.  Specific guidelines are drafted with respect to equivalency
                                 3-13

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of programs; consistency with Che Federal program; oversight; appli-

cation procedures; and withdrawal of authorization.

3.7  Preliminary Notification of Hazardous Waste Activicies (Section
      3010)

      These baseline regulations (see Appendix B, Subpart G) define

the administrative procedures under which states may be granted

authority to receive notifications of hazardous waste activities

(limited interim authorization) and specify the procedures for filing

such notifications by persons generating or managing hazardous

wastes.

     These regulations would allow states to receive a limited, one-

time authorization (expiring six months after promulgation of the

Section 3001 regulations) to receive notifications of hazardous waste

activities from generators, transporters, storers, treaters, and dis-

posers.  The states would not have authority to grant exceptions to

the filing requirements and would have to maintain files of all

receipts, making these files available to EPA at the request of the

Regional Administrator.

      The filing requirements would apply to every person conducting

a hazardous waste activity at the time of promulgation of the Section

3001 regulations.  Such notification would constitute one of the con-

ditions for interim status for storers, treaters, and disposers to

continue operations pending issuance of a facility permit.  The base-

line regulations would allow combination of notification requirements
                                 3-14

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with application for an identification code by generators and trans-




porters, and with application for facility permits for storers,



treaters, and disposers.
                                  3-15

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4.0  IDENTIFICATION AND SELECTION OF REASONABLE ALTERNATIVES

     Based upon the overall objectives of RCRA (see Chapter 2), the

major objectives for Subtitle C are to promote public health and en-

vironmental protection in the generation and management of hazardous

wastes, to enhance resource recovery from hazardous wastes, and to

encourage state participation in the hazardous waste management pro-

gram established under Subtitle C.  The baseline Subtitle C regula-

tions, summarized in Chapter 3, comprise the set of regulations

initially developed to achieve these objectives in a feasible and

enforceable manner.

     During the overall development of both the proposed regulations

and the final Phase I regulations, numerous alternative regulations

and regulatory approaches have been considered.  The baseline regula-

tions and subsequent regulatory versions were selected from among the

many alternatives based upon technical, environmental, institutional,

economic, and legal considerations.*  The various alternatives that

were considered included changes in regulatory approaches (e.g.,'per-

formance standards versus design and operating standards for hazard-

ous waste storage, treatment and disposal facilities) and changes in

the standards and criteria to be established by the regulations (e.g.,

the level of hazardous waste generation at which generators are

designated for purposes of regulation under Section 3002).
^Background documents prepared by EPA on the Subtitle C regulations
 provide a detailed discussion of the major issues raised and the
 major regulatory options considered during the development of the
 Subtitle C regulations.
                                4-1

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     Because of the enormous number of ways in which Che overall ob-

jectives, regulations, and standards could be structured and developed

the approach in this EIS is to select and develop a manageable set of

meaningful alternatives that reasonably bracket the overall objectives

and the resultant impacts anticipated from the regulations that are

ultimately to be promulgated under Subtitle C.*  The set of alterna-

tives that have been developed is meaningful in the sense that each is

considered to be technically, legally, economically, and institution-

ally feasible and enforceable, and each provides an assessable shift

in the potential impacts that might result from the proposed regula-

tions.  Also, the alternatives selected fall within the scope of

actions allowable under Subtitle C (e.g., tax incentives to promote

resource recovery are not within the allowable scope of Subtitle C

actions).  By reasonably bracketing the overall objectives and the

resultant impacts, it is possible to show the types of potential

impacts that could result -under various alternatives without having to

explicitly consider the almost infinite variety of options for accom-

plishing the same or intermediate objectives.

     It is not meant to be implied that the baseline regulations or

any one of the alternatives selected and structured in this chapter

would define the actual regulations promulgated under Subtitle C.
^Analyses of all the specific detailed alternatives and options
 considered are provided in the background documents for the Subtitle
 C regulations.


                                 4-2

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Rather, Che set of alternatives should only be viewed as representa-



tive cases for purposes of analysis and as guidelines for assisting in




the planning and development of the Subtitle C regulations.




     Based upon the objectives of Subtitle C, five different sets of



alternatives, with respect to the baseline regulations, have been




selected and structured to reasonably bracket the potential impacts



that could be expected to result.  These alternatives are as follows:



     •  No Action;




     •  Phasing of Generators;



     •  Enhanced Public Health and Environmental Protection;



     •  Lesser Degree of Public Health and Environmental Protection;




     •  Phase I Alternative.



     For each of these alternatives, the purpose and rationale for the




selection and structure of the alternative are discussed in the fol-




lowing sections.  To the extent practical, the major options that were



not considered to be reasonable for inclusion are also indicated, and



the rationale for their elimination is presented.  In the discussion




of the structure of each alternative, all components of the baseline



Subtitle C regulations (see Appendix B) are assumed to be included



under each alternative, except for those specific modifications that



are indicated below.



4.1  No Action



     This alternative has been selected for the purpose of analyzing




the potential impacts that could result from taking no action, i.e.,
                                4-3

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not promulgating regulations for Subtitle C.  There are two ways in




which the No Action alternative may be approached.  One way is to




assume that No Action involves not implementing any portion of RCRA,




including Subtitle C.  The other approach is to assume that No Action




involves implementing all portions of RCRA, except Subtitle C.




     Under the former approach, hazardous wastes would continue to be




generated, stored, transported, treated, and disposed in essentially




the same manner as is currently practiced.  Under the latter approach,




hazardous wastes would also continue to be generated, stored, trans-




ported, and treated in much the same manner as is currently practiced;




however, disposal would be somewhat different due to the Subtitle D




regulations.  Open dumps would be prohibited and criteria would be




established with which sanitary landfills would have to comply.  How-




ever, Section 4003(2) of Subtitle D specifically exempts hazardous




wastes from the requirement that solid wastes be utilized for resource




recovery or disposed of in sanitary landfills or otherwise disposed of




in an environmentally sound manner.  Thus, it is uncertain how the




implementation of Subtitle D would affect hazardous waste disposal if




Subtitle C were not to be implemented.




     It is not possible to prepare a meaningful assessment of the No




Action alternative that assumes that all of RCRA, except Subtitle C,




is to be implemented.  This conclusion is based upon the unavailabil-




ity of the state solid waste management plan required under Subtitle




D, the recent promulgation of regulations and criteria under Subtitle
                                 4-4

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D for sanitary landfills, and the many significant uncertainties and




lack of data about the ways Subtitle D and the rest of RCRA would




affect hazardous waste generation, storage, transport, treatment and




disposal.  Therefore, the No Action alternative to be assessed in this




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




implemented and that hazardous waste management would continue as




currently practiced.




4.2  Phasing of Subtitle C Regulations




     This alternative has been selected for the purpose of analyzing




the potential change in impacts that could result from the promulga-




tion of the baseline Subtitle C regulations on a phased basis, rather




than from their total implementation at one time.  For purposes of




analysis, a five-year time frame measured from the proposed implemen-




tation date is assumed for the phasing of the regulations.  The pri-




mary objectives of phased implementation are to ensure that resources




(e.g., manpower, disposal sites, and capital) would not be stressed




beyond their capacity to respond effectively to the baseline Subtitle




C regulations.




     There are two basic mechanisms for phasing the implementation of




baseline Subtitle C regulations.  First, the regulations within the




different Sections of Subtitle C (i.e., Sections 3001 through 3006 and




3010) could be implemented over a significantly extended period of




time (e.g., implementation of the 3001 regulations first, followed by




the implementation of the 3002 regulations 6 months later; or imple-




mentation of a portion of the Section 3004 regulations, followed by



                                 4-5

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implementation of the remainder of the Section 3004 regulations 6




months later).  Second, the regulations for all the Sections of Sub-




title C could be promulgated at the same time, and the levels for the



standards and criteria established by the regulations could be phased




to their proposed values over a period of time (e.g., the generator




limit under Section 3002 could be set at 1,075 metric tons per month



the first year, 303 metric tons per month the second year, ..., and




100 kilograms per month the fifth year).



     The implementation of each and every individual Section of Sub-



title C over a significantly extended period of time is not a feasible



alternative, due both to the interdependence of the various Sections




of Subtitle C and to court-imposed deadlines for the promulgation of



various Sections.  However, for reasons discussed in the Preface, the




Section 3004 regulation is necessarily being promulgated in three



phases.  A Phase I Alternative, which is discussed in Section 4.5, has



been developed for the purpose of analyzing the impacts associated



with the regulations to be included in the first phase of this




promulgation.  As discussed in the Preface, a Phase II Alternative



which relates to the second phase of this promulgation will be




developed and analyzed in Part II of the EIS.




     There are many different methods by which phasing could be



implemented with regard to the second phasing mechanism discussed



above (i.e., promulgation of all Subtitle C regulations at the same




time and a gradual phasing in of more stringent levels for those






                                 4-6

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standards and criteria that are established by the regulations).

However, most methods would have essentially the same effect—a

gradual expansion of the total quantity of hazardous wastes being

controlled by the hazardous waste program.  For purposes of analysis,

the method selected emphasizes gradually increasing the quantity of

wastes controlled by gradually expanding the number of generators

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

limit established under Section 3002 of the baseline regulations is to

be reduced annually over a five-year period of time in order to bring

the larger generators into the program first and the smaller genera-

tors into the program later.*  Furthermore, the generator limit is to

be reduced so that equal amounts of hazardous wastes are annually

brought under the program's control over the five-year period, i.e.,

20 percent of the total industrial hazardous wastes per year.

     A second method based on gradually increasing the quantity of

wastes controlled through the mechanism of expanding the promulgated

levels of the characteristics used to identify hazardous wastes has

been determined not to be a reasonable alternative at the present

time.  While it is a simple matter to change the levels of the char-

acteristics to include more wastes under the program's control, avail-

able data preclude the setting of characteristic levels (e.g.,

specific changes in the pH level) so as to increase the waste load
 The generator limit is the upper bound on the amount of hazardous
 wastes that can be produced and disposed monthly without being sub-
 ject to the Subtitle C regulations.

                                 4-7

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annually by a specified amount.  At the very least, such an alterna-



tive would result in difficult program management and enforcement




problems.




     A further approach to phasing which involves the gradual phasing



in of more stringent levels for those performance standards promul-



gated under Section 3004 and the permit requirements promulgated under




Section 3005 has also been determined not to be a reasonable alterna-




tive since no person can be reasonably expected to construct a hazard-



ous waste facility to meet regulations that would be superseded by




more stringent regulations in succeeding years*



     Table 4-1 presents the specific changes to each section of the



baseline Subtitle C regulations that are to be included under this




alternative.  All components of the baseline regulations discussed in




Appendix B are assumed to be included under this alternative, except



for those specific modifications that are indicated in Table 4-1.



For ease in correlating the indicated modifications with the baseline



regulations summarized in Appendix B, the appropriate section of



Appendix B being modified is given immediately following the change




presented in Table 4-1.



     While this alternative emphasizes the phasing of generators to be




regulated under the program, the modifications presented in Table 4-1



are not limited solely to this one change.  Rather, two additional




modifications have been included to assist in fulfilling the stated



objectives of this phasing alternative.  These additional modifica-




tions phase in the time limit that generators may accumulate hazardous




                                 4-8

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                         TABLE 4-1

                   PHASING OF GENERATORS


              3001 Modifications (Subpart A)*

•  No changes.


              3002 Modifications (Subpart B)*

•  Phase in the generator limit (250.21(6]).*
    1,075 metric tons per month during the first year;
      303 metric tons per month during the second year;
      125 metric tons per month during the third year;
       34 metric tons per month during the fourth year;
      100 kilograms per month during the fifth year.

•  Phase in the 90-day exclusion for generators who temporarily
   accumulate hazardous wastes prior to off-site disposal
   (250.61[dd]).*
   -  Twelve-month exclusion for the first two years, then
      decrease to 270 days, 180 days, and 90 days over the
      last three years.


              3003 Modifications (Subpart C)*

•  No changes.


              3004 Modifications (Subpart D)*

•  Phase in the time limit for reporting of unmanifested wastes
   delivered to permitted facilities (250.43-6(a)(4)).
   -  No reporting during the first year;
   -  Quarterly reporting during the second and third years;
   -  Monthly reporting during the fourth year;
   -  Immediate reporting during the fifth year.


              3005 Modifications (Subpart E)*

•  Phase in generator storage exemption as specified above under
   3002 modifications (250.61[dd]).*
                            4-9

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                        TABLE 4-1 (Concluded)
                                          •




                   3006 Modifications (Subpart F)*



     •  No changes.





                   3010 Modifications (Subpart G)*



     •  No changes.
*Section of the baseline regulations in Appendix B that is being

 changed by this modification.
                                 4-10

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wastes prior to off-site disposal without being brought into the per-



mit system and the time limit for reporting of unmanifested wastes.




     Since the baseline regulations provide for the phasing of state



participation into the program through both interim authorization and




partial authorization, no additional modifications have been made to




promote phasing of state authorized programs.



4.3  Enhanced Public Health and Environmental Protection



     This alternative has been selected for the purpose of analyzing



the potential change in impacts that could result from modification of



the baseline Subtitle C regulations designed to further increase pub-




lic health and environmental protection even above that level afforded




by the baseline regulations.



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




tion of hazardous waste in order to bring additional wastes under




control of the program; to remove exclusions provided for hazardous



waste generators; to apply even more stringent design and operational




requirements, for storers, treaters, and disposers; to eliminate spe-



cial waste standards; to reduce reporting intervals for storers,



treaters, and disposers; to eliminate the use of delivery documents in




lieu of manifests; and to decrease the life of permits and impose



additional restrictions on obtaining permits.



     Table 4-2 presents the specific changes to each section of the



baseline regulations that are to be included under this alternative.



As previously discussed, all components of the baseline regulations
                                 4-11

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                           TABLE 4-2

      ENHANCED PUBLIC HEALTH AND ENVIRONMENTAL PROTECTION


                3001 Modifications (Subpart A)*

Add characteristics for identifying infectious wastes and radio-
active wastes as hazardous wastes (250.13).*
(1)  A solid waste is an infectious waste if it is generated from
     the sources listed in Appendix B, Subpart A, 250.14(a)(2)(i),
     unless the waste does not contain microorganisms or helminths
     of CDC Classes 2 through 5 of the Etiologic Agents listed in
     Appendix B, Subpart A, Appendix IX.
(2)  A waste is a radioactive waste if it is not source, special
     nuclear, or byproduct material as defined by the Atomic
     Energy Act of 1954, as amended, and if a representative
     sample of the waste has either of the properties listed
     in Appendix B, Subpart A, 250.14(b)(2)(F)(i and ii).

Eliminate the toxic waste characteristic based upon the EPA Primary
Drinking Water standards and replace with the following character-
istic for identifying toxic wastes as hazardous (250.13(4]):*
-  A solid waste is a toxic waste if the extract obtained from
   applying the extraction procedure (EP) in Appendix B, Subpart A,
   250.13(b)(4)(i) to a representative sample of the waste has any
   of the following properties:
      (1)  Gives a positive response in any one of a set of re-
           quired tests for a mutagenic activity, described
           in Appendix B, Subpart A, 250.14(b)(2)tG)(i).
      (2)  Gives a positive result in the Bioaccumulation Potential
           Test, defined in Appendix B, Subpart A, Appendix XII.
      (3)  Contains more than the specified concentration of any
           substance in Appendix B, Subpart A, Appendix XIII.
      (4)  Exceeds any of the following thresholds, when applica-
           ble:
           (a)  Has a concentration of a substance, for which an
                EPA Primary Drinking Water Standard has been es-
                tablished, greater than or equal to 10 times that
                criteria.
           (b)  Contains any organic substance, which has a calcu-
                lated human LD50 of less than 800 mg/kg, at a con-
                centration in mg/1 greater than or equal to 0.35
                times its LD50 expressed in units of mg/kg.
           (c)  Has a concentration of any substance listed below
                greater than that specified:
                              4-12

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                        TABLE 4-2 (Continued)
                                          Maximum Permissable EP
                      Substance        Elutriate Concentration (mg/1)

                      Antimony                       ?
                      Beryllium                      ?
                      Copper                         ?
                      Dalapon                        3.5
                      Dichobenil                    10.
                      Diquat                        50.
                      Fenac                          1.0
                      Nickel                         ?
                      Picloram                       0.1
                      Thallium                       ?
                      Zinc                           ?
                   3002 Modifications (Subpart B)*

•  Eliminate the 100 kilograms per month generator limit (250.21[6]).*
      -  Anyone, except households, generating any amount of the
         hazardous wastes identified under Section 3001 must comply
         with the Section 3002 regulations.

•  Remove exclusion from Section 3002 regulations for generators
   engaged solely in retail trade or principally in farming
   (250.20[f]).*
      -  Farmers and retail generators must comply with Section 3002
         requirements for all hazardous wastes identified under Sec-
         tion 3001.

•  Increase reporting frequency from annually to quarterly for all
   generators (250.23).*
      -  All portions of the "previous" annual report are to be re-
         ported quarterly.

•  Increase the reporting frequency for manifests not received by the
   designated facility from quarterly to monthly (250.23[a][2]).*

•  Eliminate the use of a delivery document in lieu of a manifest
   (250.21[3]).*
      -  All hazardous waste shipments must be accompanied by the
         manifest at all times.

•  Eliminate the transfer of liability contract (250.20[i and j] and
   250.29).*

                                 4-13

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                        TABLE 4-2 (Continued)
                   3003 Modifications (Subpart O*

•  Eliminate the use of a delivery document in lieu of a manifest
   (250.31U]).*
      -  All hazardous waste shipments must be accompanied by the
         manifest at all times.
                   3004 Modifications (Subpart D)*

   Eliminate special waste standards for cement kiln dust waste,
   utility wastes, phosphate rock mining and processing wastes,
   uranium mining wastes, and oil drilling muds/brines (250.46).*
      -  These wastes, if hazardous under Section 3001, must comply
         with all Section 3004 standards.

   Change the application of the threshold limit value for air con-
   taminents from non-point emission sources (250.42-3[b]).*
      (1)  The threshold limit value is to be applied as a maximum
           concentration that is not to be exceeded at any time
           rather than as a time-weighted average for an 8-hour
           day and 40-hour week.
      (2)  The threshold limit value is to be applied as a mandatory
           standard rather than a human health and environmental
           standard.

   Increase the minimum distance active portions of facilities must be
   located from the facility's property line from 200 feet to 400 feet
   (250.43-1th]).*

   Increase the minimum distance surface impoundments, active portions
   of landfills, and treated areas of landfarms must be  located from
   any functioning public or private water supply or livestock water
   supply from 150 meters (500 feet) to 300 meters (1000 feet)
   (250.45-2[a][3], 250.45-3[a][3], and 250.45-5[c][3]).*

   Increase the financial responsibility required of owner/operators
   of treatment, storage, or disposal facilities during  site operation
   from a minimum of $5 million to a minimum of $10 million (250.43-2
   [b]).*
                                4-14

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                        TABLE 4-2 (Continued)
•  Increase Che tine during which the owner/operator of a facility is
   to provide post close-out care from a period which need not exceed
   20 years from closure to a period which need not exceed 40 years
   from closure (250.43-8[k] [1] ).*
      -  The annual cash payment into the trust fund for post close-
         out monitoring and maintenance is to be adjusted based upon
         this 40-year period (250.43-2[a] [2] ).*

•  Add a requirement that all inactive treatment, storage, and dis-
   posal facilities must comply with the Section 3004 regulations.'

•  Add a requirement that all wastes be treated using the best prac-
   tical technology (BPT) to reduce their waste solubility and over-
   all toxicity before disposal.'

•  For all landfills and surface impoundments, increase the required
   permeability of the soil liner and of the final cover from less
   than or equal to 1 x 10-7 cm/sec, to less than or equal to 1 x
   10-8 cm/sec. (250.45-2[bJ [10] , 250.45-2[b] [12] [ii] , 250.45-2[b]
   [12][v], 250.45-2[c][l], 250.45-3[c] [2] , and 250.45-3[c] [9] ).*

•  Add the requirement that any  land farm that has the potential to
   discharge to groundwater must be monitored so as to detect any
   discharge (250.43-9).*
      -  Such landfarms must comply with the groundwater and leachate
         monitoring standards.

•  Reduce the maximum vapor pressure of wastes that may be treated,
   stored, or disposed as indicated below from 78 mm of Hg at 25 C
   (250.44-lla]ll], 250.45-2lb] 15] liii] , 250.45-3lb] UJ lv] , 250.45-4
   [2][e], and 250.45-5[i] [ii] ).*
      -  Wastes with a vapor pressure greater than 53 mm of Hg at
         25 C may not be disposed in landfills, placed in surface
         impoundments or basins, landfarmed, nor put in storage
         tanks vented directly to the atmosphere.

•  Increase reporting frequency  for report based on manifest informa-
   tion from annually to quarterly (250.43-6[a] [3] ).*

•  Add a requirement that for those hazardous wastes determined by the
   permitting agency to have a recovery potential within the reason-
   able forseeable future, any land disposal must be in a segregated
   manner. t
                                 4-15
               4'

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                      TABLE 4-2 (Continued)
                3005 Modifications (Subpart E)*

Reduce Che duration of permits from the projected life of the
facility to a period no longer than 5 years (250.62-5).*
   -  Permits may be renewed for the maximum time period (5 years)
      an unlimited number of times.

Eliminate special permits for experimental facilities, qualified
hospital-medical care facilities, ocean dumping barges or vessels,
and publicly owned treatment works (POTW) (250.62-6, 250.62-7,
250.62-8, and 250.62-9).*
   -  All these facilities must submit both Part A and B of the
      permit application and a supplementary environmental analy-
      sis described below (250.62-6[b], 250.62-7[b], 250.62-8[b],
      and 250.62-9[b]).*
   -  Experimental facilities and qualified hospital-medical care
      facilities must comply with all Section 3004 requirements
      (250.62-6[b] and 250.62-6[a][3]).*
   -  POTW1s and ocean dumping barges or vessels must comply with
      Section 3004 requirements applicable to storage of hazardous
      wastes (250.62-8[b] and 250.62-9[b]).*

Owners/operators of facilities for the treatment, storage, or dis-
posal of special wastes (e.g., cement kiln dust wastes) must apply
for Section 3005 permits and comply with all Section 3005 permit
application requirements.'

All permit applicants must submit a Supplementary Environmental
Analysis of the facility and its potential impacts.  The Supple-
mentary .Environmental Analysis is to contain:'
  (1)  An analysis of the impact of and methods proposed to comply
       with the following Federal statutes and published regula-
       tions where applicable:  The Endangered Species Act; The
       National Historic Preservation Act; The Historic Sites,
       Buildings and Antiquities Act; The Fish and Wildlife Coor-
       dination Act; and The Coastal Zone Management Act.
  (2)  A discussion of whether alternative methods for treatment,
       recovery, or recycling of wastes to be stored, treated, or
       disposed were considered, or whether the wastes will be
       treated prior to storage or disposal.
  (3)  A description of how hazardous wastes will be transported to
       the facility, including a listing of the access routes.
  (4)  The proximity of the site to population centers and size of
       the population centers.


                              4-16

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                        TABLE 4-2 (Concluded)
      (5)  A description of any easements, pipelines, utilities,
           public roads, or rights-of-way located within the bounda-
           ries of the facility.
      (6)  A description of applicable local and state zoning or land
           use laws in effect.
      (7)  A description of adjacent land uses within one mile of the
           facility.
      (8)  A description of the methods proposed to minimize and con-
           trol impacts of dust, odors, and noise associated with
           construction and operation of the facility.
      (9)  A listing of applications submitted or permits obtained
           under local state, or Federal acts involving toxic or
           hazardous wastes.
                   3006 Modifications (Subpart F)*

•  No changes.


                   3010 Modifications (Subpart G)*

•  Eliminate the exclusion for owners of inactive hazardous waste
   treatment, storage, and disposal facilities.t
      -  The owner of inactive facilities must file a notification.
^Section of the baseline regulations in Appendix B that is being
 changed by this modification.
TNo equivalent regulation appears in the baseline regulations in
 Appendix B.
                                4-17

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discussed in Appendix B are assumed to be included under this alterna-




tive, except for those specific modifications indicated in Table 4-2.




     Under this alternative, the definition of hazardous wastes in




Section 3001 has been expanded by adding characteristics for defining




infectious wastes and radioactive wastes as hazardous.  The character-




istic for identifying toxic wastes has also been expanded to bring




additional wastes under control of the regulations.




     The exclusion from the Section 3002 regulations for generators




who produce less than 100 kilograms per month of hazardous wastes has




been eliminated.  The exclusion for those generators engaged solely in




retail trade or principally in farming for all hazardous wastes pro-




duced, except waste automotive oil, has also been eliminated.  All




hazardous wastes produced by such generators are to be managed in




accordance with the Subtitle C regulations.  The transfer of liability




contract for waste automotive oil has been eliminated.




     The use of delivery documents in lieu of manifests for hazardous




waste transport has been eliminated.  The reporting frequency for the




generator report on manifests not received by the designated facility




has been increased from quarterly to monthly.  Other reporting fre-




quencies for generators, storers, treaters, and disposers have been




increased from annually to quarterly.  A requirement has been added




that owners of inactive treatment, storage, or disposal facilities




comply with all Section 3004 regulations.
                                 4-18

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     Special standards for 'special wastes' (i.e., cement kiln dust



wastes, utility wastes, phosphate rock mining and processing wastes,



uranium mining wastes, and oil drilling muds/brines) have been




eliminated; such 'special wastes' must comply with all Section 3004




standards.  Design and operating standards for facility location,



non-point source air emission concentrations, post close-out care,



soil liner permeabilities, groundwater monitoring, financial responsi-



bilities, management of volatile wastes, and treatment and segregation



of wastes before disposal have been made more stringent.



     The duration of the permit life has been reduced from the pro-




jected life of a facility to a period not to exceed 5 years; permits



may be renewed an unlimited number of times.  Special permits for




experimental facilities, qualified hospital-medical care facilities,



ocean dumping barges or vessels, and publicly owned treatment works




(POTW's) have been eliminated; the former two have to comply with all



Section 3004 requirements, the latter two have to comply with Section




3004 storage requirements.  A requirement has been added that all



permit applicants submit a Supplementary Environmental Analysis.



4.4  Lesser Degree of Public Health and Environmental Protection




     This alternative has been selected for the purpose of analyzing



the potential change in impacts that could result from modifications



to the baseline Subtitle C regulations designed to provide a lesser



degree of public health and environmental protection than that



afforded by the baseline regulations.
                                 4-19

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




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




control of the program; to increase exclusions provided for hazardous




waste generators; to reduce manifest requirements; to apply less




stringent design and operational requirements for storers, treaters,




and disposers; to eliminate regulation of special wastes; to decrease




recordkeeping times for generators, transporters, storers, treaters,




and disposers; to increase the length of permit exclusions for genera-




tors who store prior to off-site disposal; to eliminate restrictions




on interim authorization; and to ease restrictions on full and partial




authorization.




     Table 4-3 presents the specific changes to each section of the




baseline regulations that are to be included under this alternative.




As previously discussed, all components of the baseline regulations




discussed in Appendix B are assumed to be included under this alterna-




tive, except for those specific modifications indicated in Table 4-3.




     Under this alternative, the definition of hazardous wastes in




Section 3001 has been modified to include fewer wastes by eliminating




the characteristic for toxic wastes; listed wastes whose listing is




based solely on the toxicity characteristic (including those listed




based on the criterion of Administrator's Judgment) have also been




removed from the Section 3001 lists.  Special wastes (e.g., cement




kiln dust wastes and utility wastes) have been specifically excluded




from being identified as hazardous wastes under Section 3001.
                                 4-20

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                              TABLE 4-3

     LESSER DEGREE OF PUBLIC HEALTH AND ENVIRONMENTAL PROTECTION



                   3001 Modifications (Subpart A)*

   Eliminate Che characteristic for toxic wastes (250.13[4]).*
      -  Eliminate the listed wastes whose listing is based solely
         on the toxicity characteristic or on the Administrator's
         judgment (250.14).*

   Exclude the following wastes from being identified as hazardous
   wastes under Section 3001:  cement kiln dust wastes, utility
   wastes, phosphate rock mining and processing wastes, uranium
   mining wastes, and oil drilling muds/brines (250.14[a]
                   3002 Modifications (Subpart B)*

•  Increase the generator limit from 100 kilograms per month to
   1000 kilograms per month (250.21[6]).*

•  Increase the length of the permit exclusion for generators who
   temporarily accumulate hazardous waste prior to off-site disposal
   from 90 days to 1 year (250.61[dd]).*

•  For off-site shipments of hazardous  wastes-by generators, replace
   the Section 3002 manifest requirements with a new manifest require-
   ment that all such shipments (interstate and intrastate) must be
   accompanied by shipping paper/bill of lading which designates
   delivery to a permitted storage, treatment, or disposal facility
   and which meets the requirements of the DOT Hazardous Materials
   Regulations (250.21[3] and 250.22).*
      -  For example, spill information need not be provided on the
         shipping paper/bill of lading, and the shipping paper/bill
         of lading need only be signed as required under the DOT
         Hazardous Materials Regulations (i.e., must be signed only
         by the generator shipping the wastes).

•  Replace requirement for recordkeeping of manifest copy with a
   requirement for recordkeeping of shipping paper/bill of lading
   (250.24).*
      -  Decrease recordkeeping time for shipping paper/bill of
         lading used in place of manifest from 3 years to 1 year.
                                 4-21

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                     TABLE 4-3 (Continued)
Eliminate the reporting of shipping paper/bill of lading not re-
ceived at designated facility (250.23[a][2]).*
                3003 Modifications (Subpart O*

Replace the Section 3002 manifest requirements with a new manifest
requirement that all shipments (interstate and intrastate) must be
accompanied by shipping paper/bill of lading which designates de-
livery to a permitted storage, treatment, or disposal facility and
which meets the requirements of the DOT Hazardous Materials Regu-
lations (250.21(31 and 250.22).*
   -  Eliminate need for signatures on shipping paper/bill of
      lading, except as required under the DOT Hazardous Mate-
      rials Regulations (i.e., must be signed only by the gen-
      erator shipping the wastes).

Replace requirement for recordkeeping of manifest with a require-
ment for recordkeeping of shipping paper/bill of lading (250.33).*
   -  Decrease recordkeeping time for shipping paper/bill of
      lading from 3 years to 1 year, except where DOT Hazardous
      Materials Regulations specify retention times longer than
      1 year.

Eliminate special emergency spill regulations (250.37).*
   -  Eliminate requirements for the transporter to notify
      appropriate officials in the case of a spill and to
      file a report on the spill.
   -  Eliminate requirement for transporter to clean up spill
      or to take other action required to insure the spill no •
      longer presents a hazard to human health or the environ-
      ment.

Eliminate requirement that if a transporter consolidates shipments
of hazardous wastes that do not require a manifest, the entire
shipment must be delivered to a permitted facility (250.30[a]).*

                3004 Modifications (Subpart D)*

Eliminate special waste standards for cement kiln dust wastes,
utility wastes, phosphate rock mining and processing wastes, ura-
nium mining wastes, and oil drilling muds/brines (250.46).*
   -  Exclude these wastes from compliance with Section 3004
      regulations.
                              4-22

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                     TABLE 4-3 (Continued)
Change Che application of the threshold limit value for air conta-
minants from non-point emission sources (250.42-3[b]).*
   -  The threshold limit value is to be applied as time-
      weighted average for a 24-hour day rather than as a
      time-weighted average for an 8-hour day and 40-hour
      week.

Decrease the minimum distance active portions of facilities must
be located from the facility's property line from 200 feet to 100
feet (250.43-l[h]).*

Decrease the minimum distance surface impoundments, active portions
of landfills, and treated areas of landfarms must be located from
any functioning public or private water supply or livestock water
supply from 150 meters (500 feet) to 75 meters (250 feet) (250.45-2
[a][3], 250.45-3[a][3], and 250.45-5[c][3]).*

Decrease the financial responsibility required of owners/operators
of treatment, storage, or disposal facilities during site operation
from a minimum of $5 million to a minimum of $2 million (250.43-2
[b]).*

Decrease the time during which the owner/operator of a facility is
to provide post close-out care from a period which need not exceed
20 years from closure to a period which need not exceed 10 years
from closure (250.43-8[k][1]).*
   -  The annual cash payment into the trust fund for post close-
      out monitoring and maintenance is to be adjusted based upon
     •this 10-year period (250.43-2[a][2]).*

For incineration, reduce the required destruction efficiency of the
principal components of the waste from 99.99% to 99.9%, the com-
bustion efficiency from 99.9% to 99%, and halogen removal from
exhaust gases from 99% to 90% (250.45-l[b], 250.45-1 [d], and
250.45-1[h]).*

For all landfills and surface impoundments, decrease the required
permeability of the soil liner and of the final cover from less
than or equal to 1 x 10-7 cm/sec, to less than or equal to 1 x
10-6 cm/sec. (250.45-2[b][10], 250.45-2[b][12][ii], 250.45-2[b]
[12][v], 250.45-2[c][l], 250.45-3[c][2], and 250.45-3[c][9]).*

Limit to groundwaters that are underground drinking water sources
the requirement that all facilities, except landfarms, that have
the potential to discharge to groundwater must be monitored to
detect any discharge (250.43-9).*

                              4-23

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                     TABLE 4-3 (Continued)
   -  There does not have to be monitoring of potential
      discharge to groundwaters which are non-underground
      drinking water sources.

For those facilities for which there is to be groundwater and
leachate monitoring, eliminate the quarterly monitoring and
minimum analysis of samples from both the leachate detection
system and the groundwater (250.43-9[b][4] and 250.43-9[b][5]).*
   -  Eliminate the quarterly reporting of this monitoring
      data (250.43-9[d][l]).*
   -  Retain annual monitoring and comprehensive analysis
      (250.43-9(c][4] and 250.43-9[c][5]).*

Eliminate the restriction on the maximum vapor pressure of
wastes that may be treated, disposed, or stored as indicated
below (250.44-l[a][l], 250.45-2[b][5][iii], 250.45-3[b][1][v],
250.45-4[2][e], and 250.45-5[1][ii]).*
   -  Wastes with a vapor pressure greater than 78 mm of Hg
      at 25 C may be disposed in landfills, placed in surface
      impoundments or basins, landfarmed, or put in storage
      tanks vented directly to the atmosphere.

Increase the time interval for completing training of personnel
from 6 months to 1 year (250.43-5[a]).*

Eliminate the regulation of commercial products made from
hazardous wastes (250.45-7).*
      Such commercial products are not to be considered
      hazardous wastes.

Replace requirements for recordkeeping of manifest copy with a
requirement for recordkeeping of shipping paper/bill of lading
(250.43-6[a][2].*
   -  Decrease recordkeeping time for shipping paper/bill of
      lading used in lieu of manifest from 3 years to 1 year
      (250.43-6[a][2]).*

Eliminate need for signatures on shipping paper/bill of lading,
except as required under the DOT Hazardous Materials Regulations
(250.43-6la][l][a]).*
                              4-24

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                        TABLE 4-3 (Concluded)

                   3005 Modifications (Subpart E)*

   Increase Che length of the permit exclusion for generators who
   temporarily store hazardous wastes prior to off-site disposal
   from 90 days to 1 year (250.61[dd]).*

   Eliminate the need for publicly owned treatment facilities,
   qualified hospital-medical care facilities, and ocean dumping
   barges or vessels to apply for a special permit (250.62-7[b],
   250.62-8(b], and 250.62-9[b]).*
      -  Such facilities are automatically granted the special
         permits.

                              ^-o
                   3006 Modifications (Subpart F)*

   Eliminate restrictions on granting of full or partial authori-
   zation to states with more stringent standards (250.72[a][ii]
   and 250.72[b][l]).*

   Eliminate all restrictions on granting of interim authorization,
   except for the Memorandum of Understanding (250.73).*
      -  All states desiring interim authorization are to be
         granted it, providing that they have a Memorandum of
         Understanding
                   3010 Modifications (Subpart G)*

•  Retail generators need not notify (250.820[a]).*
^Section of the baseline regulations in Appendix B that is being
changed by this modification.

tNo equivalent regulation appears in the baseline regulations in
 Appendix B.
                                 4-25

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     The exclusion from the Section 3002 regulations for generators

who produce less than 100 kilograms per month of hazardous wastes has

been replaced by an exclusion for all generators who produce less than

1000 kilograms per month.  The 90-day permit exclusion for temporary

waste accumulation by generators prior to off-site disposal has been

increased to a one-year exclusion.  Retail generators have been

excluded from notification required under Section 3010.

     For off-site shipments of hazardous wastes by generators, the

Section 3002 manifest requirements are replaced by a requirement that

all such shipments (interstate and intrastate) must be accompanied by

a shipping paper/bill of lading which designates delivery to a permit-

ted storage, treatment, or disposal facility and which meets the

requirements of the DOT Hazardous Materials Regulations.*  For example

the spill information required by the manifest is not required for the

shipping paper/bill of lading, and the signature requirements of the

manifest are replaced by signature requirements under the DOT Hazard-

ous Materials Regulations (i.e., only the generator shipping the

wastes needs to sign the shipping paper/bill of lading).

     The reporting of shipping papers/bills of lading not received at

the designated facility is eliminated.  Recordkeeping requirements for

shipping papers/bills of lading are reduced from 3 years to 1 year for
*The DOT Hazardous Materials Regulations are to be applied to both
 interstate and intrastate shipments of hazardous wastes.
                                4-26

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generators, transporters, storers, treaters, and disposers.  The spe-



cial emergency spill regulations for transporters have been elimi-




nated.



     Regulation of 'special wastes'  under Section 3004 has been elim-




inated.  Design and operating standards for facility location, non-



point source air emission concentrations, incineration, post close-




out care, soil liner permeabilities, groundwater monitoring, financial



responsibilities, management of volatile wastes, training of person-



nel, and commercial products have been made less stringent.




     Permit requirements for POTW's, qualified hospital-medical care



facilities, and ocean dumping barges or vessels have been eliminated.




Such facilities would be granted permits by rule and would not have to




comply with any Section 3004 requirements.



     All restrictions on the granting of interim authorization, except




the Memorandum of Understanding, have been eliminated.  Any state



desiring interim authorization would be granted such status, providing



the state submits a Memorandum of Understanding that specifies how the



state plans to become eligible to attain full authorization at the end



of the interim authorization period.  States may also impose consider-



ably more stringent standards than those promulgated under Sections



3001 through 3005 and still be authorized for full or partial authori-



zation, even if there is no public health and/or environmental protec-



tion basis for the more stringent standards.
                                 4-27

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4.5  Phase I Alternative

     The Phase I Alternative contains the set of non-technical modi-

fications that are being considered for inclusion in the final Phase

I Subtitle C regulations, based both upon recent studies conducted by

EPA and upon public comments received by EPA subsequent to the propo-

sal of Subtitle C regulations in December 1978.  The Phase I Alterna-

tive has been included for the purpose of analyzing the potential

change in impacts that could result from modifications to the base-

line Subtitle C regulations which incorporate this specific set of

non-technical changes.

     The regulations comprising Sections 3001 through 3004 of the

Phase I Alternative are presented in Appendix N.  The regulations

comprising Sections 3005 and 3006 are contained in the Proposed Con-

solidated Permit Regulations published in the Federal Register, Vol.

44, No. 116, Parts II and III, June 14, 1979.

     Table 4-4 summarizes the specific changes to each section of the

baseline regulations that are included in this alternative.  As pre-

viously discussed, all components of the baseline regulations dis-

cussed in Appendix B are assumed to be included under this Phase I

Alternative, except for those specific modifications indicated in

Table 4-4. Thus, all the Section 3004 technical standards of the

baseline regulations (e.g., landfill standards) are assumed to be

included under this alternative.*
^Modifications to the Section 3004 technical standards are to be
 assessed as an additional alternative in Part II of the EIS.

                                 4-28

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                              TABLE 4-4

                         PHASE I ALTERNATIVE


                   3001 Modifications (Subpart A)*

• Modify the definition of materials that are to be considered solid
  waste subject to the requirements of Section 3001 (such solid waste
  may be identified as hazardous waste under Section 3001) ( 250.11 [d
  and g]).*
  (1) Clarify the definition of those discarded (and not used or
      re-used) materials that are to be considered solid waste
      (261.2[a][2]).t
  (2) Add requirement for listing as solid wastes specific materials
      that are used or re-used or that are being stored for use or
      re-use (261.2[a](3] and 261.2[b]).t
      (a) Place waste oil on this list (261. 2[a] [3] [i])t and delete
          those specific used oils listed in 250.11(d) (2)(ii) .*
      (b) Listing of other materials is reserved (261. 2[a] [3] [ii] ) .t
  (3) Add requirement for listing as solid wastes specific materials
      that are used or re-used or processed for material or energy
      recovery, or stored for such purposes (261.2[a][4] and
      261.2[b]).t
      (a) Delete those specific used oils listed in
      (b) Listing of materials is reserved (261. 2[a] [4] [ij).t
  (4) Clarify two additional wastes specifically excluded from being
      identified as solid waste (250.10[c] ).*
      (a) Point source air emissions that are subject to regulation
          under the Clean Air Act, as amended (261. 4[a] [5]).t
      (b) Dredge spoils that are disposed of in navigable waters,
          including wetlands, and that are subject to regulation
          under Section 404 of the Clean Water Act, as amended
          (261.4[a][7]).t

• Exclude the following solid wastes from regulation as hazardous
  wastes and from notification under Section 3010 (250.10[d] ).*
  (1) Material that is used, re-used, or processed for energy
      recovery or is stored for such purposes and that is not listed
      in 261.2(a)(4).t
  (2) Material that is not listed in 261.2[a][3]t and that is used
      or re-used in a manner constituting disposal or that is being
      stored for such purposes.
  (3) In-situ mining wastes, including in-situ wastes from certain
      oil shale, uranium, and other extraction processes which
      extract minerals, fuels, or other materials from geological
      formations without removing the waste material from the
      formation (261. 4[b] [5]).t

                                 4-29

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                      TABLE 4-4 (Continued)
(4) Fly ash, bottom ash, or boiler slag that is both (i) generated
    by a utility or industrial boiler, process steam generator, or
    coal gasification or liquefaction unit from the sole use of
    fossil fuels or from the use of certain fuels in combination
    with fossil fuels, including refuse-derived fuels from
    municipal solid waste or any alternative fuel which is not a
    hazardous waste and (ii) used in the construction of roads, as
    a de-icing agent on roads, or as a soil conditioner
    (261.4[b][6]).t
(5) Cement kiln dust waste used in the construction of roads or for
    soil conditioning, including agricultural liming
    (261.4[b][7]).t
(6) Blast furnace slag used in the construction or maintenance of
    railroad beds or roads (261.4[b][8]).t

Eliminate the 100 kilogram generator limit (250.21(6])* and replace
it with the following:
(1) Except for those hazardous waste identified in subparagraphs
    (a) through (d) below, none of the hazardous wastes generated
    by a commercial establishment or the part(s) of commercial
    establishments that is exclusively engaged in the retailing of
    merchandise or an individual facility that generates and dis-
    pose of no more than 1000 kilograms (2200 pounds) of hazardous
    waste in any 30-day period is subject to regulation as hazard-
    ous waste (261.4[c]):t
    (a) Any quantity of those hazardous wastes listed under 261.33
        (a or b).t
    (b) Any quantity greater than 10 kilograms (22 pounds) of those
        hazardous wastes listed under 261.33(c).t
    (c) Any quantity greater than 100 kilograms (220 pounds) of
        those hazardous wastes listed under 261.33(d).t
    (d) Any quantity of a hazardous waste listed in 261.31t or
        261.32,t for which an exclusion limit is specified, that is
        generated and disposed of in an amount that exceeds the
        specified exclusion limit.

    Comment:  Exclusive of the exceptions in subparagraphs (a)
              through (d), paragraph (1) does not specifically
              exclude small quantities of hazardous wastes:  it
              only excludes hazardous wastes from retailers and
              generators of small quantities (less than 1000 kilo-
              grams per 30-day period) of hazardous waste.  If a
                              4-30

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                        TABLE 4-4 (Continued)
                non-retail, individual facility generates a quantity
                of hazardous waste that exceeds 1,000 kilograms in
                any 30-day period, all quantities of hazardous
                wastes, including any and all quantities of indivi-
                dual hazardous waste(s) generated in amounts less
                than 1,000 kilograms per 30-day period, are subject
                to regulation as hazardous waste.)
  (2) The Administrator will revise the exclusion of paragraph (1) to
      reduce the 1000 kilograms for a 30-day period to 100 kilograms
      (220 pounds) for a 30-day period.  This revision will be made
      through rulemaking initiated not before two years nor after
      five years after original promulgation of Section 3001. The
      Administrator may make this reduction in steps during the
      three-year period (261.4[d]).t

  Modify the pH limits for identifying an aqueous waste as a corro-
  sive waste (250.13[a][2]).*
  - Change the pH limits to Ł2 or M2.5 instead of <3 or M2 (261.21
• Modify the characteristic for identifying toxic waste
  (250.13[a][4]).*
    (1) A solid waste possessing the characteristic is defined as a
        Type I toxic waste (261.23[a])t , rather than as a toxic waste
        (250.13[a][4]).*
    (2) Raise the concentration of contaminants in the extract used
        to identify a Type I toxic waste (250. 13 [a] [4] [i]) .*
        - Increase the contaminant concentration in the extract from
          10 times the EPA Primary Drinking Water Standards to 100
          times that Standard (261. 23 [Table I]).t

• Eliminate the criterion of Administrator's Judgment for listing
  hazardous waste (250.14[a])* and replace it with the following
  criteria (261.11):t
  (1) The Administrator will list a solid waste (or classes or types
      of solid wastes) as a hazardous waste if, after considering the
      criteria delineated in 261.1 Kg thru j)t, he determines that
      the solid waste, if improperly treated, stored, transported,
      disposed of, or otherwise managed, may:
                                4-31

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                        TABLE 4-4 (Continued)
      (a) Cause, or significantly contribute to an increase in
          mortality or an increase in serious irreversible, or
          incapacitating reversible, illness; or
      (b) Pose a substantial present or potential hazard to human
          health or the environment.
  (2) In listing a hazardous waste or class or type of hazardous
      waste, the Administrator will designate the waste as one or a
      combination of the following (261.11[g thru j]t delineate the
      criteria for each category):
      (a) Type II Toxic Waste.
      (b) Type III Toxic Waste.
      (c) Radioactive Waste.
      (d) Infectious Waste*

• Modify the list of hazardous wastes from non-specific sources
  (250.14[a][l]).*
  - See 261.31t and 261.33t for new lists.  The listing of wastes
    under 261.33 is reserved.

• Modify the list of specific sources generating hazardous waste
  (250.14[a][2][ii]).*
  - See 261.32t for new list.

• Modify the list of infectious wastes (250.14[a][2][i]).*
    (1) For hospital, veterinary hospitals, and medical and research
        laboratories, eliminate the listing of all wastes generated
        by specified departments and replace with a more specific
        listing of wastes (See 261.34T for new list).
    (2) Delete listing of unstabilized sludge from non-publicly owned
        treatment works.

• Modify the methods used to demonstrate that a listed wastes
  generated by an individual facility is not a hazardous waste
  (250.14[b]).*
  - See 261.39T for revised methods.

• Delineate the procedure to be used for petitions both for identify-
  ing characteristics of hazardous waste or for listing of hazardous
  waste (250.12[b][2])*, (261.40).t
                                4-32

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                     TABLE 4-4 (Continued)
                3002 Modifications (Subpart B)*

Modify exclusion from Section 3002 regulations for generators
engaged solely in retail trade (250.20[f]).*
(1)  Eliminate exclusion that retailers must comply with all
     Section 3002 requirements only with regard to the generation
     of waste automotive oil (250.20[f)).*
(2)  Add a requirement that commercial establishments or the
     part(s) of commercial establishments exclusively engaged in
     the retailing of merchandise must comply with Section 3002
     requirements only for those wastes specified in 261.4(c).t

Modify exclusion from Section 3002 regulations for generators
engaged principally in farming (250.20[f]).*
(1)  Eliminate exclusion that farmers must comply with all Section
     3002 requirements only with regard to the generation of waste
     automotive oil (250.20[f]).*
(2)  Add a requirement that a farmer who disposes only waste
     pesticide from his own use is not subject to Subtitle C
    •requirements for the waste pesticide, if it is hazardous,
     providing the farmer complies with the requirements of
     262.51(a).t
(3)  Add a requirement that a farmer who generates hazardous waste
     other than waste pesticide in a quantity in excess of that
     specified in 261.4(c)t must comply with all Section 3002 re-
     quirements for that waste (262.51[b]).T

Add a requirement that any person who imports hazardous waste into
the jurisdiction of the U.S. must comply with all Section 3002
requirements (262.10[c] and 262.50[a and d]).T,4

Revise the generator limit of 100 kilograms per month (250.21(6])*
to the generator limit specified in 261.4(c and d).t

Limit the number of permitted facilities to which the generator
may designate transport of the waste (250.22[a][4]).*
(1)  Add a requirement that the generator must designate on the
     manifest one facility which is permitted to handle the waste
     described on that manifest (262.20[b]).t
(2)  Add a requirement that the generator may designate on the
     manifest one alternative facility which is permitted to han-
     dle the waste in the event an emergency prevents delivery to
     the primary designated facility (262.20[c]).t

Revise information required on manifest (250.22[a])*:
(1)  Eliminate spill response information.

                             4-33

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                     TABLE 4-4 (Continued)

(2)  Eliminate use of EPA shipping description and hazard class
     when the DOT shipping description and hazard class are not
     applicable (262.21[a][5]).t
(3)  Add a requirement for specifying number and type of
     containers (262.21[a][6]).t,4

Eliminate reporting and recordkeeping exclusion for generators
that designate hazardous waste for off-site treatment, storage, or
disposal at a facility which the generator owns and which is
located in the same state in which the hazardous waste generation
occurs (250.20[d]).*
-  Such generators need to prepare annual reports (262.41[a])t and
   exception reports (262.42)t and to retain copies of manifests
   for three years (262.40[a]).t

Add two additional recordkeeping requirements (250.24).*
(l)  A copy of each annual report and exception report must be
     retained for a period of three years (262.40[b]).t
(2)  Records of any test results, waste analyses, or other deter-
     minations made in accordance with 262.lit must be retained
     for not less than three years from the date that the waste
     was last sent on-site or off-site for treatment, storage, or
     disposal (262.40[c]).t

Except for international shipments, increase the reporting fre-
quency for manifests not recieved from the designated permitted
facility from quarterly to 45 days from date of acceptance by the
initial transporter'(250.23[a][2])* , (262.42[b]).t
-  Add a requirement that generators who do not receive a signed
   copy of the manifest from the designated permitted facility
   within 35 days of acceptance by the initial transporter shall
   contact the transporter and/or designated facility to determine
   status of movement (262.42[a]).t

For international shipments eliminate quarterly reporting of all
shipments (250.23[a][2] and 250.23[f][2])* and add manifesting
and reporting requirements specified in 262.50(a,b, and c).t

Add an additional requirement with regard to generators accumulat-
ing hazardous waste on-site for less than 90 days without a permit
(250.25)*.
-  The date upon which the period of accumulation begins is to be
   clearly marked and visible on each container (262.34[a][3].t
                             4-34

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                     TABLE 4-4 (Continued)
Add a requirement that the Administrator may, as he deems
necessary, require generators to furnish additional reports
(262.43).t,4
                3003 Modifications (Subpart C)*

Add one additional way in which a transporter is required to com-
ply with the Section 3002 generator requirements (250.36[c])*:
   The transporter imports a hazardous waste into the United
   States (263.10[c]).T

Eliminate the prohibition against transporters accepting
containers that are leaking or that appear to be damaged
(250.34[e]).*

Add a requirement that the transporter must deliver the entire
quantity of hazardous waste in accordance with 263.21(a) ; if the
movement cannot be delivered in accordance with that requirement,
the transporter must contact the generator for further directions
and must revise the manifest according to the generators
instructions (263.21[b]).t,4

Remove the exemption that allows non-bulk water transporters not
to obtain a signature (on the manifest or shipping papers) for
intramodal transfers of hazardous waste movements (250.35[b])*
-  Non-bulk water transporters must obtain signatures at each
   intramodal transfer (263.21[d][3]).T

Eliminate the requirement allowing a transporter up to five work-
ing days after delivery of the hazardous waste to obtain the
signature of the authorized agent of the designated permitted
facility (250.35[d][2]).*
-  The transporter must obtain the signature upon delivery of the
   waste (the transporter- is responsible for the waste until the
   signature is obtained) (263.21[c][3][i] and 263.21[d][4][i]).t

Add a requirement that transporters who transport movements out of
the United States must comply with the requirements of
263.21(e)t,4 and 263.22(c).T.4
                             4-35

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                     TABLE 4-4 (Continued)
Revise the start date of the three year period for retaining the
manifest or shipping paper to the date of initial acceptance by a
transporter (263.22)t instead of the date of transfer to another
transporter or the date of delivery to the designeated permitted
facility (250.33).*

Replace the term hazardous waste spill (250.37)* with the term
hazardous waste discharge (263.30).t
(1)  Replace the requirement that all transporters must im-
     mediately notify either the National Response Center or de-
     signated government official of any discharge of hazardous
     waste (250.37[b])* with a requirement that air, rail,
     highway, and water (non-bulk shipment) transporters must give
     notice as may be required by 49 CFR 171.15 and that water
     (bulk shipment) transporters must give notice as may be
     required by 33 CFR 153.203 (263.30[c][1] and 262.30[d]).t
(2)  Replace the requirement that all transporters must file a
     written report on each discharge within 15 days
     (250.37[b][3])* with a requirement that air, rail, highway,
     and water (non-bulk shipment) transporters must report in
     writing as required by 49 CFR 171.16 (263.30[c][2]).t

                3004 Modifications (Subpart D)*

Add a requirement that where portions of a facility at which waste
management activities took place before the effective date of the
Section 3004 regulations could potentially interfere with the mon-
itoring and/or control of an active portion, the owner/operator
may be required to comply with one or more of the requirements
specified in 264.1[e]t for those portions.+

Eliminate special wastes and the special standards for the special
wastes (250.40[c] and 250.46).*
(1)  Add the discriminate standards specified in Part 266t for
     uranium mining and phosphate rock mining, beneficiation, and
     processing waste.
(2)  All other special wastes must comply with all Section 3004
     requirements.

Eliminate all Human Health and Environmental Standards and all
requirements to comply with such standards (250.42, 250.40[e],
250.43[a], 250.43[c], 250.43[d], 250.43[e], 250.44[d],
250.45-6[a], 250.45-4[1], 250.45-3[3], 250.45-3[c][1],
250.45-3[c][8], 250.45-3[d][1], 250.45-5[a][1][ii],
250.45-5[c][4], 250.45-2[a][3], 250.45-2[b][8,9, and 11].*

                              4-36

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                     TABLE 4-4 (Continued)
Revise the General Facility Standards (250.43)* as follows:
(1)  Add a requirement that an owner/operator of a facility that
     has arranged to receive hazardous waste from foreign sources
     must notify the Regional Administrator at least two weeks in
     advance of the expected arrival date of the shipment
     (264.12[al).T,4
(2)  Add a requirement that an owner/operator of a facility that
     receives hazardous waste from off-site (except when the
     owner/operator is also the generator) must inform the
     generator in writing that he has the appropriate permit(s)
     for and will accept the waste; such notice must be retained
     by the owner/operator (264.12[b]).T,+
(3)  Add a requirement that before transferring ownership or oper-
     ation of a facility during its operating life, or a disposal
     facility during the post-closure care period, the
     owner/operator must notify the new owner/operator in writing
     of the Section 3004 requirement (264 12[c]).T,4
(4)  Add a requirement for the development of a waste analysis
     plan which provides for periodic analysis of the waste man-
     aged at the facility (250.43[h])*, (264.13[a][3] and
     264.13[b]).t
(5)  Exempt on-site facilities from the requirement that each
     waste shipment be tested to determine whether the shipment
     matches the identity of the waste designated on the accom-
     panying manifest (250.43U])*, (264.13[a][4] and 264.13(c]).t

Replace the requirements that the active portion of a facility .
must be surrounded by a fence or barrier (250.43-3[a])* and that
the ingress to the facility must be controlled (250.43-3[b])* with
the requirements specified in 264.14(b).t

Revise the Inspection Standards as follows:
(1)  Eliminate the requirement for daily inspections of the items
     specified in 250.43-7(a).*
(2)  Add a requirement for facility owners/operators to develop
     and implement a schedule for inspection of monitoring equip-
     ment, safety and emergency equipment, security devices, and
     operating and structural equipment that are important to the
     prevention and detection of, or response to, environmental or
     human health hazards (264.15[a and b]).t,4
(3)  Add a requirement that repairs or other remedial action be
     performed as specified in 264.15(c).t
                             4-37

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                        TABLE 4-4 (Continued)
•  Revise the Emergency Procedures and Contigency Plans Standards as
   follows:
   (1)  Add a requirement that facilities must be designed, con-
        structed, maintained, and operated so that the possibility of
        a discharge, fire, or explosion which could threaten the en-
        vironment outside the facility is minimized (264.31).T,+
   (2)  Add a requirement that the contigency plan shall include
        provisions for unplanned non-sudden discharges of hazardous
        waste (250.43-4[a][l])*, (264.51[a]).t
   (3)  Limit implementation of the contigency plan to those dis-
        charges which threaten the environment or human health out-
        side the facility (250.43[a][1])*, (264.51[b]).t
   (4)  Add a requirement that the contingency plan must include
        provisions for controlling spills (250.434[a]),*
        (264.52[aJ).t
   (5)  Eliminate the requirement that the contingency plan must
        include an outline of a program for familiarizing employees
        with emergency procedures and for drills on these procedures
        (250.43-4[a][8]).*
   (6)  Add a requirement that the contigency plan must be maintained
        at the facility (264.53[a||).t,+
   (7)  Add a requirement for revision of contingency plan under the
        conditions specified in 264.54.t,^
   (8)  Add a requirement allowing the emergency coordinator to be
        on-call rather than present at the facility
        (250.43-44[a][4])*, (264.55).t
   (9)  Change the requirement that recovered waste, contaminated
        soil, or contaminated material shall be analyzed to determine
        whether it is a hazardous waste (250.43-4[c][9])* to a
        requirement that these materials must be handled as a
        hazardous waste unless analyzed and determined not to be
        (264.56[g]).T
  (10)  Increase the time for filing written report on emergencies
        from immediately after the incident (250.43-6[cJ[1])* to
        within 15 days of the incident (264.56[j]).t
  (11)  Require that the additional information specified in
        264.56[j][1,2,4,5,6, and 7]t be included in the emergency re-
        port (250.43-4[c][9]).*
  (12)  Add a requirement that the facility owner/operator must
        notify the Regional Administrator, and appropriate State and
        local authorities, that the facility is in compliance with
        the requirements of 264.56(h)t before operations are resumed
        in the affected areas(s) of the facility (264.56[i]).t

•  Revise Manifest System, Recordkeeping, and Reporting Standards as
   fo1lows:
                                 4-38

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                     TABLE 4-4 (Continued)
(1)  Add a definition of what constitutes a significant discre-
     pancy between the manifest and the waste shipment
     (250.43-6[c])*, (264.72[a]).t
(2)  Increase from immediately (250.43-6[a][1])* to 15 days
     (264.72[b])t the time limit for notifying the Regional
     Administrator when significant discrepancies are discovered
     between the manifest and the waste shipment; the owner/oper-
     ator must attempt to reconcile the discrepancy during this
     15 day period.
(3)  Increase from immediately (250.43-6[a][4])* to 15 days
     (264.76)t the time limit for notifying the Regional
     Administrator when a facility accepts waste without an
     accompanying manifest.
(4)  Decrease the time for retaining records and results of
     inspections from the time of facility closure
     (250.43-6[b][2][fj)* to a period of three years
     (264.73[b][5]).
(5)  Increase the time for retaining training records that docu-
     ment the training completed by facility employees from 3
     years (250.43-6[b][2][a][5])* to the time of facility closure
     for current employees and to three years from the time of
     departure for former employees (264.16[e]).
(6)  Add a requirement that records of waste disposal locations
     must also be turned over to the local land authority upon
     closure of the facility (250.43-6[b][3])*, (264.74).t
(7)  Add a requirement that the annual report submitted by both
     on-site (250.23[e])* and off-site (250.43-6[a][3][c])*
     facilities also include the methods of treating, storing, or
     disposing each hazardous waste (264.75[e]).t
(8)  Add a requirement that the Regional Administators may, as he
     deems necessary, require owners/operators to furnish addi-
     tional reports (264.77[d]).T,4

Revise Groundwater and Leachate Monitoring Standards as follows:
(1)  Add land treatment facilities to and delete incinerators from
     those facilities that may be required to install, maintain,
     and operate a groundwater monitoring system (250.43-9)*,
     (264.90U and b]).t
(2)  Revise the criteria for implementing groundwater monitoring
     from a potential for discharge to groundwater (250.43-9)* to
     that specified in 264.90[a and b].t
(3)  Delete all leachate monitoring requirements (250.43-9[b and
     c]).*
(4)  Increase the number of monitoring wells from four
     (250.43-9[a])* to a minumum of four (264.91[a]).t

                             4-39

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                      TABLE 4-4 (Continued)
 (5)  Add a requirement for annually evaluating and modifying the
      ne^esary number of groundwater monitoring wells
      (264.93[g]).t,*
 (6)  Revise the requirement for location of monitoring wells
      (250.43-9[a][3 and 4])* to that specified in 264.9l(b).t
 (7)  Revise sampling frequency and analyses (250.43-9[c])* to that
      specified in 264.92.t
 (8)  Add requirements for preparing a groundwater damage assess-
      ment program and a corrective action program, for evaluating
      impacts to groundwater quality, for notifying the Regional
      Administator, and for implementing the damage assessment
      program and/or the corrective action program
      (264.93[a,b,c,d,e, and f]).t,*
 (9)  Increase the time limit for maintaining groundwater moni-
      toring records from three years for all facilities
      (250.43-9[d][2])* to throughout the active life of storage
      and treatment facilities and to throughout the post-closure
      care period for disposal facilities (264.94[a]).t
(10)  Revise the reporting of monitoring data from quarterly
      (250.43-9[d][i])* to the times specified in 264.94(b).t

 Revise the Closure and Post-Closure Standards as follows:
 (1)  Add a requirement that all facilities must be closed in a
      manner that minimizes further maintenance necessary to prot-
      ect human health and the environment and that minimizes any
      discharge of wastes, leachate, contaminated rainfall, or
      waste decomposition products to ground or surface waters or
      the atmosphere (284.111).t,4
 (2)  Revise the required contents of the closure plan
      (250.43-8[d])* to that specified in 264.112(a).t
 (3)  Delete the term "close out" (250.43-8[e])* and add a re-
      quirement that within 90 days of receiving the final volume
      of wastes, the owner/operator must treat and/or remove all
      wastes in storage or in process from the site, or dispose of
      them on-site, in accordance with the closure plan
      (264.113[a]).T
 (4)  Decrease the time limit for completing closure activities
      from within three years after close out (250.43-8[f])* to
      within six months of receiving the final volume of wastes
      (264.113[b])t; a longer time may be permissible if the
      conditions specified in 264.113(b)t are met.
 (5)  Delete the requirement that the owner/operator must notify
      the Regional Administrator at least 15 days before any par-
      tial closure (250.43-8[d])*.
                              4-40

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                      TABLE 4-4 (Continued)
 (6)   For facilities other than land disposal facilities, increase
      the time for notifying the Regional Administrator of the ex-
      pected date of the completion of closure from 90 days before
      the end of final closure (250.43-8[d])* to 180 days before
      the end of final closure (264.115[a]).t
 (7)   Add a requirement that at the completion of closure, the
      owner/operator must certify that the facility has been closed
      in compliance with the closure plan (250.43-8[j])*,
      (264.115[b]).t
 (8)   Revise post-closure care as follows (250.43-8[m])*:
      (a)  Add requirements for reporting of monitoring results and
           for maintenance of monitoring systems (264.117[a]).T
      (b)  Delete requirement for maintenance of waste containment
           devices.
      (c)  Limit maintenance of site security devices to those con-
           ditions specified in 264.117(b).t
 (9)   Delete the requirement that all facilities be designed such
      that the land is amenable to some acceptable use so that
      perpetual isolation and care to maintain isolation are not
      required (250.43-8[c]).*
(10)   Remove the prohibition that after closure, all facilities
      shall be secured such that hazardous waste remaining cannot
      be contacted by animal (non-human) life (250.43-8[h])*.
(11)   Replace the prohibition on future use of the land
      (250.43-8[b])* with the requirements specified in
      264.117(c).t
(12)   Increase the time requirement for post-closure care from a
      period not to exceed 20 years (250.43-8[1])* to a period of
      at least 30 years, with some variances as noted in
      264.117(d).t    .       •
(13)   Add requirements for submitting and amending a post-closure
      plan to the Regional Administrator (264.118[a and b]).t,
(14)   Limit the time for filing a survey plat to within 90 days
      after completion of closure (250.43-8[k])*, (264.119).T
(15)   Add a requirement that the owner of the property on which a
      disposal facility is located must record a notation on the
      deed to the property or, in accordance with State law, on any
      other such instrument which is normally examined during title
      search, that will in perpetuity notify any potential pur-
      chaser of the property that the land has been used to manage
      hazardous waste, and of the use restriction on the land
      (264.120).t,4

 Eliminate requirements for commercial products (250.45-7).*
                               4-41

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                     TABLE 4-4 (Continued)
Add a set of interim status standards applicable only to facility
owners/operators who have fully complied with the requirements for
interim status defined in Section 3005(e) of RCRA (264.3).?,=}=
-  During the period of interim status, an owner/operator must
   comply with the requirements specified in Part 265T in lieu of
   the regulations in Part 264.t

Add the following General Facility Interim Status Standards (265
Subpart B):t
(1)  Applicability
(2)  Identification number
(3)  Required notices
(4)  General waste analysis
(5)  Security
(6)  General inspection requirements
(7)  Personnel training.

Add the following Preparedness and Prevention Interim Status
Standards (265 Subpart C):t
(1)  Applicability
(2)  Maintenance and operation of facility
(3)  Required equipment
(4)  Testing and maintenance of equipment
(5)  Access to communication or alarm system
(6)  Required aisle space
(7)  Special handling for ignitable or reactive waste
(8)  Arrangements with local authorities.

Add the following Contingency Plan and Emergency Procedures
Interim Status Standards (265 Subpart D):t
(1)  Applicability
(2)  Purpose and implementation of contingency plan
(3)  Content of contingency plan
(4)  Copies of contingency plan
(5)  Amendment of contingency plan
(6)  Emergency coordinator
(7)  Emergency procedures.

Add the following Manifest System, Recordkeeping, and Reporting
Interim Status Standards (265 Subpart E):t
(1)  Applicability
(2)  Use of manifest system
(3)  Manifest discrepancies
(4)  Operating record
(5)  Disposition of records

                             4-42

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                      TABLE 4-4 (Continued)
 (6)  Annual report
 (7)  Unmanifested waste report
 (8)  Additional reports.

 Add the following Groundwater Monitoring Interim Status Standards
 (265 Subpart F):t
 (1)  Applicability
 (2)  Groundwater monitoring system
 (3)  Sampling and analysis
 (4)  Preparation, evaluation, and response
 (5)  Recordkeeping and reporting.

 Add the following Closure and Post-closure Interim Status
 Standards (264 Subpart G):T
 (1)  Applicability
 (2)  Closure performance standard
 (3)  Closure plan; amendment of plan
 (4)  Time allowed for closure
 (5)  Disposal or decontamination of equipment
 (6)  Certification of closure
 (7)  Post-closure care and use of property;- period of care
 (8)  Post-closure plan; amendment of plan
 (9)  Notice to local land authority
(10)  Notice in deed to property.

 Add the following Financial Requirements Interim Status Standards
 (265 Subpart H):T
 (1)  Applicability
 (2)  Cost estimate for facility closure
 (3)  Financial assurance for facility closure
 (4)  Cost estimate for post-closure monitoring and maintenance
 (5)  Financial assurance for post-closure monitoring and mainte-
      nance
 (6)  Applicability of State financial requirements
 (7)  Transfer of ownership.

 Add the following Use and Management of Containers Interim Status
 Standards (265 Subpart I):t
 (1)  Applicability
 (2)  Condition of 'containers
 (3)  Compatibility of waste with container
 (4)  Management of containers
 (5)  Inspections
 (6)  Special requirements for ignitable or reactive waste
 (7)  Special requirements for incompatible waste.

                             '4-43

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                     TABLE 4-4 (Continued)
Add the following Tanks Interim Status Standards (265 Subpart J):t
(1)  Applicability
(2)  Construction requirements
(3)  General Operating requirements
(4)  Waste analysis and trial tests
(5)  Inspections
(6)  Groundwater monitoring
(7)  Closure
(8)  Special requirements for ignitable or reactive waste.

Add the following Surface Impoundments Interim Status Standards
(265 Subpart K):t
(1)  Applicability
(2)  General operating requirements
(3)  Containment system
(4)  Waste analysis and trial test
(5)  Inspections
(6)  Closure and post-closure
(7)  Special requirements for ignitable or reactive wastes
(8)  Special requirements for incompatible wastes.

Add the following Waste Piles Interim Status Standards (265
Subpart L):t
(1)  Applicability
(2)  Protection from wind
(3)  Waste analysis
(4)  Containment
(5)  Special requirements for ignitable waste
(6)  Special requirements for reactive waste
(7)  Special requirements for incompatible wastes.

Add the following Land Treatment Interim Status Standards (265
Subpart M):T
(1)  Applicability
(2)  General operating requirements
(3)  Waste analysis
(4)  Food chain crops
(5)  Zone of aeration monitoring
(6)  Recordkeeping
(7)  Closure and post-closure
(8)  Special requirements for ignitable or reactive waste
(9)  Special requirements for liquid waste.

Add the following Landfill Interim Status Standards (265 Subpart
N):t

                             4-44

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                     TABLE 4-4 (Continued)
(1)  Applicability
(2)  General Operating Requirements
(3)  Waste analysis
(4)  Surveying and recordkeeping
(5)  Closure
(6)  Post-closure care
(7)  Special requirements for ignitable or reactive waste
(8)  Special requirements for incompatible wastes
(9)  Special requirements for liquid waste.

Add the following Incinerators Interim Status Standards (265 Sub-
part 0):t
(1)  Applicability
(2)  General operating requirements
(3)  Waste analysis
(4)  Monitoring and inspections
(5)  Closure
(6)  Open burning; explosive waste.

                3005 Modifications (Subpart E)*

Add a requirement for review of RCRA permit at least once every 5
years to determine if the permit should be modified or revoked and
reissued (250.62-2[a])*, (122.9).S
-  If the facility also has a UIC, NFDES, or Section 404 permit,
   the RCRA permit shall be reviewed each time one of these other
   permits is modified, reissued, or terminated.

Add the following as cause for termination of the permit
(250.62-3[a])*, (122.10).§
(1)  Information indicating that the permitted facility posed a
     threat to the environment.
(2)  A change in ownership or control at a permitted facility
     where required by 122.8[e].§

Eliminate requirement setting a maximum of 3 years for completion
of a schedule of compliance (250.62-4[b][1])*, (122.12).§

Add a requirement limiting the duration of experimental facility
permits to not more than 1 year with an allowable extension of not
more than 1 additional year (250.62-6[c]*, (122.25[b][3]).§

Add a requirement for revocation of the health care facility spe-
cial permit (250.62-7)*, (122.25[a][4]).§
                             4-45

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                        TABLE 4-4 (Concluded)
•  Eliminate need for publically owned treatment works (POTW's) and
   ocean disposal barges or vessels to apply for a special permit
   C250.62-8[b]  and 250.62-9[b])*, (122.26[b and c]).§

                   3006 Modifications (Subpart F)*

•  Eliminate partial authorization of state programs (250.72[b]) ,*
   (123.33[b]).§

•  Allow states that have legislative authority to control on-site or
   off-site disposal facilities no later than 90 days after the date
   of promulgation of Section 3001 to be considered for interim
   authorization (250.73)*, (123.32[a][!]).§
   -  Previously a state needed legislative authority by July 20,
      1978.

•  Change the time period for interim authorization to the 24 months
   beginning on the date six months after the date of promulgation of
   Section 3001 (250.73U1) ,* (123.32[a]) .§
   -  Previously interim authorization was effective only from
      October 21, 1978 through October 21, 1980.

                   3010 Modifications (Subpart G)*

•  Eliminate the use of limited interim authorization (250.810,
   250.811, and 250.812).*
^Section of baseline regulation in Appendix B that is being changed
 by this modification.
tSect ion of Phase I Alternative in Appendix N in which this modi-
 fication appears.
+No equivalent regulation appears in the baseline regulation in
 Appendix B.
§Sect ion of 40 CFR 122, 123, and 124, Proposed Consolidated Permit
 Regulations (Federal Register, Vol. 44, No. 116, Parts II and III,
 Thursday, June 14, 1979) in which this modification appears.

                                 4-46

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     Under this alternative, revisions have been made in the mecha-

nisms for identifying whether a waste is hazardous under Section

3001.  The lists of hazardous wastes and processes generating hazard-

ous wastes have been modified.  The criterion of Administrator's

Judgment for listing hazardous waste has been replaced by specific

criteria for listing hazardous waste under four new categories.  The

methods used to demonstrate that a listed waste is not hazardous have

been modified.  The pH limits for identifying an aqueous waste as a

corrosive waste have been contracted.  The lower limit on the concen-

trations of contaminants used to identify a waste as a toxic waste*

has been raised.  Several additional wastes and materials have been

specifically excluded from being identified as hazardous waste.

Criteria have been added for listing, as solid wastes subject to the

regulations, materials that are used or re-used.  In addition, the

specific procedures used for petitioning for listing of hazardous

waste and/or for identifying characteristics of hazardous waste have

been delineated.  The exclusion from the regulations for generators

who produce less than 100 kilograms per month of hazardous waste has

been modified.

     The exclusion from the Section 3002 regulations for those

generators engaged solely in retail trade or principally in farming

for all hazardous waste produced, except waste automotive lubricating
*Such a waste is defined as a Type I Toxic waste rather than a
 toxic waste under this alternative.
                                 4-47

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oil, has been modified.  Generators engaged solely in retail trade



must comply with the regulations only for a specific set of listed



waste?.  Generators engaged principally in farming must comply with




the regulations for all hazardous wastes, except pesticide wastes if




certain conditions are met.




     The number of permitted facilities to which a generator may



designate transport of the waste has been limited to two.  Spill




response information and EPA shipping descriptions and hazards clas-




ses have been eliminated from the manifest.  Manifesting and report-



ing requirements for international shipments of hazardous waste have




been delineated.  The frequency for generators to report on manifests




not received by the designated facility has been increased.  The



reporting and recordkeeping exclusion for off-site generator-owned




facilities located in the same state in which hazardous waste genera-



tion occurs has been eliminated.  Additional recordkeeping require-



ments have been added.  A requirement for marking the date waste



accumulation begins has been added for generators who accumulate



wastes on-site, without a permit, for less than 90 days prior to



off-site disposal.



     The entire body of the Department of Transporation (DOT) hazard-




ous materials regulations were incorporated by reference under Sec-



tion 3003 of the baseline regulations.  Due to revision of the DOT




regulations, this incorporation by reference is duplicative and has



been eliminated under this alternative.  Similarly, the baseline






                                 4-48

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regulations on placarding, labelling, and marking are not considered



necessary and have been eliminated.  These modifications are not




listed in Table 4-4 since they would not lead to change in impacts.



     A requirement has been added under Section 3003 that a trans-




porter who imports hazardous waste into the U.S. can be considered a




generator subject to Section 3002 requirements.  The prohibition that



a transporter not transport containers that are leaking or that



appear to be damaged has been eliminated.  The exclusion allowing



non-bulk water transporters not to obtain signatures on manifests (or



shipping papers) for intramodal transfers of hazardous wastes has



been eliminated.  A requirement has been added that transporters must




contact the generator for further directions if the hazardous waste



movement cannot be delivered to either of the facilities designated




on the manifest.  The requirement allowing transporters up to five




working days after delivery to obtain the signature of the authorized



agent of the permitted facility has been eliminated; the signature




must be obtained at the time of delivery.



     Requirements for movements of hazardous waste out of the United



States have been added.  The requirements for all transporters to




notify immediately the National Response Center or designated



government official of any discharge of hazardous waste has been



replaced by a requirement that the transporter must give notice as




may be required by 49 CFR 171.15 or 33 CFR 153.203.  The requirement



that all transporters must file a written report on each discharge






                                4-49

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within 15 days has been replaced by a requirement that the trans-



porter must report in writing as required by 49 CFR 171.16.



     Under Section 3004, only the non-technical standards have been



modified; the technical standards (e.g., landfill standards)  are not




changed from the baseline regulations.  A requirement has been added




for regulation of portions of a facility at which waste management



activities took place before the effective date of the Section 3004



regulations if such portions could potentially interfere with the



monitoring and/or control of active portions of the facility.  All



human health and environmental standards and all commercial  product




standards have been eliminated.  Special wastes and the special



standards for special wastes have been eliminated.  Discriminate




standards have been added for uranium mining and phosphate mining,




beneficiation, and processing waste.



     Extensive modifications have been made to all General Facility



Standards except site selection and financial requirements.   For



example, leachate monitoring has been eliminated and the period for



post-closure care has been increased from a period not to exceed 20



years to a period of at least 30 years.




     A set of interim status standards have been added; during the




period of interim status specified in RCRA, an applicable owner/oper-



ator must comply with the interim status requirements instead of the




full set of Section 3004 requirements.  Interim status standards



apply to:
                                   4-50

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     • General Facility Requirements;




     • Preparedness and Prevention;




     • Contigency Plan and Emergency Procedures;




     • Manifest System, Recordkeeping, and Reporting;




     • Groundwater Monitoring;




     • Closure and Post-Closure;




     • Financial Requirements;




     • Use and Management of Containers;




     • Tanks




     • Surface Impoundments;




     • Waste Piles;




     • Land Treatment;




     • Landfills;




     • Incinerators.




     The application for a RCRA permit under Section 3005 has been




consolidated with the applications for NPDES permits under the Clean




Water Act, UIC permits under the Safe Drinking Water Act, and Section




404 permits (Dredge Or Fill) under the Clean Water Act.  A require-




ment has been added for the review of the RCRA permits at least once




every five years.  Requirements for termination of permits or revoca-




tion of the health care facility special permit have been added.




Requirements have been added allowing publically owned treatment




works (POTW's) and ocean disposal barges or vessels to obtain permits




by rule following Section 3010 notification.  The duration of the







                                  4-51

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experimental facility permit has been limited to one year with an




allowable extension of not more than one year.  The limit of three




years for the completion of a schedule of compliance has been



eliminated.




     Partial authorization of state programs under Section 3006 has



been eliminated.  The date for the beginning of interim authorization



and the date by which a state needs legislative authority to be able



to qualify for interim authorization have been changed to six and




three months, respectively, after the date of promulgation of Section



3001 regulations.




     Limited interim authorization of states under Section 3010 has



been eliminated.
                                4-52

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5.0  EXISTING HAZARDOUS WASTE GENERATION AND MANAGEMENT PRACTICES



     This chapter provides a characterization of the types of wastes




that could be considered as potentially hazardous under the Subtitle



C regulations and identifies potential sources of hazardous waste




generation.  Examples of the types of potentially hazardous waste



generated by selected sources are also presented.  Prevalent trans-



port, storage, treatment, and disposal methods are also described,



and the relevant aspects of typical hazardous waste management




practices are summarized. Estimates of the quantities of hazardous



waste being generated are provided in Chapter 6.




5.1  Characterization of Hazardous Waste Generation




     This section presents a general description of the charac-



teristics of wastes that are considered hazardous.  This is followed




by selected examples identifying existing sources of hazardous waste




and the types of potentially hazardous waste currently being gener-



ated by such sources.  It is the intent of this section to



characterize hazardous waste only to the extent necessary to provide




a general understanding of the various properties, types, and sources



of such waste rather than to present an exhaustive delineation of




potentially hazardous wastes and their sources of generation.



     5.1.1  Hazardous Waste Characteristics.  The Subtitle C regula-



tions and the alternatives to the regulations (see Chapters 3 and 4)




contain characteristics and lists for identifying wastes that are to



be considered hazardous and, thus, to be brought under control of the
                                    5-1

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regulations.  The specific characteristics that have been considered

for use in identifying hazardous waste are as follows:

     •  Flammability;

     •  Corrosiveness;

     •  Infectiousness;

     •  Reactivity;

     •  Radioactivity;

     •  Toxicity.

     Appendix B (Subpart A) and Chapters 3 and 4 describe the

specific properties a waste must exhibit to be considered hazardous

or nonhazardous under any one or more of these characteristics and

list waste materials which are considered hazardous•

     Wastes to which these characteristics apply and which could thus

be identified as hazardous under Subtitle C include garbage; refuse;

sludge from a waste treatment plant, water supply treatment plant, or

air pollution control facility; and other discarded material,

including solid, liquid, semisolid, or contained gaseous material

resulting from industrial, commercial, mining, and agricultural

operations, and from community activities.*  Wastes specifically

exempted from regulation by RCRA itself, and thus exempted from

Subtitle C, include solid or dissolved material in domestic sewage;

solid or dissolved materials in irrigation return flows or industrial

discharges which are point sources subject to permits under Section
*However, the Subtitle C regulations contain provisions specifically
 exempting household refuse and household septic tank pumpings from
 regulation.
                                  5-2

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402 of the Federal Water Pollution Control Act,  as amended (86 Stat.




880); and source, special nuclear, or byproduct  material as defined




by the Atomic Energy Act of 1954, as amended (68 Stat. 923).  Any



waste, except those wastes specifically exempted from regulation,




which meets any one or more of the specified characteristics or which




is listed, would be considered as hazardous under the Subtitle C



regulations.




     In attempting to characterize those wastes  that could be consi-



dered hazardous under Subtitle C, it must be realized that most waste



streams consist of a mixture of waste materials  and that it is this




mixture, not just individual components, which establishes the



hazardous nature of the waste.  Very rarely do wastes consist of just



one material.  The hazardous nature of every waste stream depends




upon several factors, including the types of materials present, the




concentration of each constituent, the interactions of the materials



present, and the physical form of the waste materials.




     The types of materials (both hazardous and nonhazardous) present




in any waste stream, and the relative concentrations of these



materials, vary  from waste stream to waste stream and are very highly




dependent upon such factors as the types of feedstock utilized by the



process or activity generating the waste, the specifics of that



process or activity, and the presence of any pollution controls and



waste treatment  practices.  No two waste streams are identical;



similar processes or activities can generate waste streams






                                  5-3

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that are very different in nature.  In fact, most waste generators

produce more than one type of waste stream, e.g., waste streams from

any generator may be in the form of liquids, solids, sludges, slur-

ries, containerized gases, or any combination of these and any one or

all of these waste streams may be classified as hazardous under the

Subtitle C regulations.  (Section 5.1.2 presents examples of poten-

tially hazardous waste streams and waste stream constituents for

selected generators.)

     With regard to the constituents present, the totality of the

waste streams generated in the U.S. is likely to contain, to some

degree, practically every type of substance or product produced in or

imported into the U.S. as well as nearly every type of material used

as a feedstock in a manufacturing process along with many of the

intermediate materials generated by these processes.  Many of these

constituents are by themselves potentially hazardous and their

presence, in sufficient concentration, can make the waste stream

hazardous.

     A number of studies have attempted to define the characteristics

that make materials toxic and/or hazardous* and to identify and rank

such materials.  Most of these studies have dealt with pure sub-

stances and commercial products, rather than with wastes.  Thousands
^Materials which are toxic are hazardous.  However, toxicity is just
 one of several characteristics for judging a waste to be hazardous.
 Wastes do not necessarily have to be toxic to be hazardous.
                                 5-4

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of compounds have been listed as potentially toxic or hazardous.  For




example, the United States Toxic Substances Control Act, Interagency




Testing Committee has initially identified about 3,600 compounds as



representing the potentially most hazardous compounds within the




larger universe of around 60,000 chemicals used in U.S. commerce.




These 3,600 compounds represent a consolidation of 19 separate




priority chemical lists compiled in recent years (U.S. Environmental




Protection Agency, 1978).  Table 5-1 indicates the sources of these




other 19 lists, the number of chemicals included, and the main



selection criteria.  For a more detailed discussion of the selection




criteria and the substances included on each list, see the individual




sources.  Every one of the thousands of materials contained in these




lists may appear in some waste stream, and the presence of any one




could, in sufficient quantity, result in the waste stream being




hazardous*




     While the types and the concentrations of materials present are




the prime determinants of the hazardous nature of the waste stream,




interactions among the various constituents 'can drastically alter the




hazardous nature of the waste stream.  Interactions which can occur




include synergisms, antagonisms, complex formation, and chemical




reactions.




     Synergism involves two or more materials acting together to




create a combined effect which is greater than the sum of their




individual effects or to lower the threshold level at which effects
                                  5-5

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                              TABLE 5-1

    SOURCES OF CHEMICALS FOR INCLUSION ON THE INITIAL LIST OF THE
      TOXIC SUBSTANCE CONTROL ACT INTERAGENCY TESTING COMMITTEE*
Source lists used
Number of
chemicals
included
  Main
selection
criteria
1.   Toxic Pollutants in Point Source Water       129           T
     Effluent Discharge, Environmental
     Defense Fund/EPA PL-92-500

2.   Scoring of Organic Air Compounds, June       337         T & P
     1976, MITRE, MTR-6248

3.   Final Report of NSF Workshop Panel to         80           P
     Select Organic Compounds Hazardous to
     the Environment, April 1975, Stanford
     Research Institute/National Science
     Foundation

4.   Potential Industrial Carcinogens and          88         T & P
     Mutagens, National Center for Toxico-
     logical Research

5.   Occupational Carcinogens for Potential       116           T
     Regulatory- Action, Department of Labor—
     Occupational Safety and Health Admin-
     istration (OSHA)

6.   Chemicals Tested or Scheduled for Testing    174           T
     at the Fish-Pesticide Research Labora-
     tory, Department of Interior—Department
     of Fish and Wildlife

7.   Substances with Chronic Effects other         —           T
     than Mutagenicity, Carcinogenicity or
     Teratogenicity:  A Subfile of the NIOSH
     Registry (Source List 13)

8.   Criteria Documents Prepared or Planned       127         T & P
     by NIOSH, February 24, 1977

9.   Suspected Carcinogens; A Subfile of        1,900           T
     the NIOSH Registry
                                 5-6

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                        TABLE 5-1 I Continued)
Source lists used
                                              Number ot
                                              chemicals
                                              included
  Main
selection
criteria
                                                             E, T, 0
                                                              E & T
                                                              T & 0
10.  Suspected Mutagens;  A Subfile of NIOSH       100
     Registry

11.  Suspected Teratogens; A Subfile of the       200
     NIOSH Registry

12.  Department of Health Education and Wei-   21,453
     fare, National Institute for Occupa-
     tional Safety and Health,  Registry of
     Toxic Effects of Chemical  Substances,
     1976

13.  The Ecological Impact of Synthetic             9
     Organic Compounds on Estuarine Eco-
     systems, September 1976, EPA-1600/
     3-76-075

14.  Threshold Limit Values for Chemical          570
     Substances and Physical Agents in the
     Workroom Environment with Intended
     Changes for 1976, American Conference
     of Government Industrial Hygienists

15.  National Occupational Hazard Survey        7,000
     (1972-1974)/National Institute for
     Occupational Safety and Health

16.  Chemicals Being Tested for Carcino-          372
     genicity by the Bioassay Program DCCP,
     National Cancer Institute, 1977

17.  EPA, Office of Toxic Substances List         162
     of Priority Toxic Chemicals, 1977

18.  A Study of Industrial Data on Candidate      650
     Chemicals for Testing, EPA Contract
     #68-01-4109, November 1976, Stanford
     Research Institute

19.  General List of Problem Substances,          160
     Environmental Contaminants Committee,
     Ottawa, Ontario, Canada, 1977
                                                              T & 0
                                                            0, T, & P
                                                              T & P
                                 5-7

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                        TABLE 5-1 (Concluded)
                                              Number of       Main
Other lists used for reference,               chemicals     selection
but not used as source lists	included	criteria

1.   Research Project to Gather and Analyze     3,200         T & P
     Data and Information on Chemicals that
     Impact Man and the Environment, National
     Institute of Health, National Cancer
     Institute/Stanford Research Institute

2.   Other Potential Modifiers of the Strato-      41         E & P
     sphere, 1975, National Institute of
     Environmental Health Sciences/Stanford
     Research Institute

3.   EPA/Office of Research and Development,      140           P
     Chemical Production, 1975
KEY:  T = Toxicity
      P = Production/Use
      0 = Occupational Exposure
      E = Environmental Persistence
*U.S. Environmental Protection Agency, 1978.
                                 5-8

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begin to occur.  For example, chlorinated aromatics become more toxic




in the presence of various solvents (Battelle Pacific Northwest




Laboratories, 1973).  Antagonism is the opposite of synergism and



involves two or more materials acting together to create a combined




effect which is less than the sum of their individual effects or to




raise the threshold level at which effects begin to occur.



     Complex formation in the waste stream involves the forming of a



chemical bond between a metal ion and a complexing agent, e.g.,




organic compounds.  This complex formation affects the solubilities



and re'actions of the materials involved.  For example, the formation




of water soluble metal-organic complexes with heavy metals may




increase the concentrations of these constituents in leachate to



levels far in excess of their normal solubilities, while the forma-



tion of water insoluble complexes may decrease the concentrations of




these constituents in leachate.  Chemical reactions in the waste



stream involve two or more materials combining to produce a poten-




tially hazardous, material which is not originally present in the



waste or combining to neutralize or eliminate potentially hazardous



materials which are present.



     The net effect of all such interactions can be to make waste




streams hazardous even if they do not contain any individually hazar-



dous materials and to render other waste streams nonhazardous even if




they contain individually hazardous materials.
                                 5-9

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      In addicion to such interactions, the physical form of both the

waste stream and its constituents can also influence the hazardous

nature of the waste stream.  For example, beryllium dust is toxic at

relatively low levels when inhaled; however, beryllium in water poses

little ingestive threat at equivalent concentrations (U.S. Environ-

mental Protection Agency, 1976a).

      With regard to identifying hazardous wastes, a number of pre-

vious studies (Booz-Allen, Applied Research, Inc., 1973; Battelle

Pacific Northwest Laboratories, 1973; Ottinger et al., 1973; Arthur

D. Little, Inc., 1973) have attempted to delineate the specific char-

acteristics that make waste hazardous, to list waste stream consti-

tuents whose forms and quantities could make waste streams hazardous,

and to identify sources of these potentially hazardous waste stream

constituents.  A series of more recent studies (Arthur D. Little,

1976b; Battelle Columbus Laboratories, 1976; Calspan Corporation,

1977; Jacobs Engineering Company, 1976; SCS Engineers, Inc., 1976;

Swain et al., 1977; TRW, Inc., 1976; Versar, Inc., 1975, 1975a, 1976;

Wapora, Inc., 1975', 1977, 1977a) have attempted to identify poten-

tially hazardous waste streams generated within selected industries,

using a few preselected hazardous constituents as the basis for the

determination.*                                                      4

     All of the above studies have indicated numerous problems in

identifying and characterizing hazardous waste streams and hazardous

waste constituents due to considerable data limitations, both with
*This group constitutes a series of EPA contractor studies on indus-
 trial hazardous waste practices in selected manufacturing indus-
 tries.  For ease in referencing these studies, the entire set will
 henceforth be called the Industry Studies (1975-1978).

                                5-10

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regard to determining what materials are actually hazardous and the

levels at which they are hazardous and with regard to determining

what materials are present in different waste streams and the concen-

trations and interactions of the various constituents.  Furthermore,

the different studies have used different definitions of hazardous

waste and hazardous material.  Therefore, the types and sources of

wastes identified as hazardous have varied among the studies and, in

some cases, may be discrepant with the regulatory definition under

Subtitle C.  Detailed descriptions of the waste streams considered in

the Industry Studies are presented in Appendix C.  Table 5-2 lists

some of the general types of hazardous waste constituents most fre-

quently identified in the various studies.

     5.1.2  Sources of Hazardous Waste.  Waste is generated as a

byproduct of nearly every activity of man.  Sources of hazardous

waste generation can be broadly grouped into four categories:

     •  Manufacturing processes;
     •  End use activities;
     •  Finished products becoming unusable, unneeded, or unwanted;
     •  Spills of hazardous, nonwaste materials during transport.

     5.1.2.1  Manufacturing Processes.  Manufacturing processes

generate a wide variety of potentially hazardous waste streams and

waste stream constituents.  The types of hazardous waste generated by

different manufacturing processes are characterized based upon the

findings of the Industry Studies (1975-1978).  These studies identi-

fied potentially hazardous waste streams within each of the following

thirteen manufacturing industries:


                              5-11

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                         TABLE 5-2

    EXAMPLES OF GENERAL TYPES OF POTENTIALLY HAZARDOUS
                    WASTE CONSTITUENTS

Acids
Caustics
Cyanides
Dyes
Explosives
Fluorides
Heavy metals and their compounds
Organics
  - Oils
  - Phenols
  - Polynuclear aromatics
  - Other organic compounds and organic residues
Paints
Pesticides
Radioactive materials
Solvents
                             5-12

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     •  Textiles;
        Inorganic chemicals;
        Pharmaceuticals;
        Paint and allied products and contract solvent reclaiming;
        Organic chemicals, pesticides, and explosives;
        Petroleum refining;
        Petroleum re-refining;
        Leather tanning and finishing;
        Metal smelting and refining;
        Electroplating and metal finishing;
        Special machinery manufacturing;
        Electronic components manufacturing;
        Storage and primary batteries.

     Table 5-3 contains examples of the potentially hazardous waste

streams and waste stream constituents generated by each of these

manufacturing industries.  Potentially hazardous waste from manu-

facturing processes very seldom consists of pure materials; the

wastes usually consist of a mixture of materials from one part of the

process which are then combined with other mixtures of wastes from

other parts of the process.  A detailed description of each poten-

tially hazardous waste stream from each industry and an enumeration

of specific, potentially hazardous constituents within the waste

stream appears in Appendix C.

     It should be noted that no one individual facility within any of

these industries generates all of the potentially hazardous waste

streams and waste stream constituents shown in Table 5-3.  It is also

not meant to be implied that all waste streams and waste stream con-

stituents identified as potentially hazardous in Table 5-3 would

necessarily be considered hazardous under the Subtitle C regulations.
                                 5-13

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                             TABLE 5-3

        EXAMPLES OF POTENTIALLY HAZARDOUS WASTE STREAMS FROM
                 SELECTED MANUFACTURING INDUSTRIES
Manufac tur ing
  industry
 Potentially hazardous
     waste stream
 Potentially hazardous
     constituents
Textiles*
  (SIC 22)
Wastewater treatment
sludge

Discarded dye and
chemical containers

Solvents and still
bottoms
Heavy metals, dyestuffs,
chlorinated organic s,
other residual organics
Residual dyestuffs and
residual chemicals

Solvents and organic
residues
Inorganic
  chemical st
  (SIC 281)
Wastewater treatment
sludges
Heavy metals, fluorides,
cyanides, pigments
                 Solids
                          Heavy metals, cyanides,
                          radioactive materials
Pharma-
  ceutical s$
  (SIC 2831,
  2833, 2834)
Waste solvents
Still bottoms, tars,
and muds

Solids
Organic solvents
Organic residues

Heavy metals, contaminated
high inert content wastes,
active ingredients
Paint and
  allied
  products §
  (SIC 285)
Raw material containers


Water treatment sludges

Solids
Waste products
                 Wash solvents and still
                 bottoms
Heavy metals, organic and
inorganic pigments, sol-
vents, additives

Heavy metals
Heavy metals

Heavy metals, solvents,
pigments, additives,
fungicides
Organic and Inorganic
solvents, pigments,
organic residues
                                5-14

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                        TABLE 5-3 (Continued)
 Manufacturing
   industry
 Potentially hazardous
     waste stream
 Potentially hazardous
     constituents
Leather
  tanning and
  finishing§§
  (SIC 3111)
Fleshings

Trimmings and shavings

Buffing dust

Finishing residues


Wastewater treatment
sludges
Heavy metals

Heavy metals

Heavy metals

Heavy metals, organic
solvents

Heavy metals
Metal smelting
  and
  refining ***
  (SIC 33)
Sludges



Slurries

Dusts

Slag

Waste ammonia liquor

Waste pickle liquor
Heavy metals, fluorides,
cyanides, oils, phenols,
grease

Heavy metals

Heavy metals

Heavy metals

Phenols, cyanides

Heavy metals, acids
Electroplating
  and metal
  finishingttt
  (SIC 3471)
Wastewater treatment
sludges


Process preparation
wastes

Miscellaneous process
solids
                  Oegreaser sludges
Heavy metals, cyanides,
acid and alkaline cleaners,
solvents, oils,-grease

Heavy metals, lubricants,
buffing compounds

Process chemicals, heavy
metals, acid and alkaline
cleaners, plating salts,
organic additives, sol-
vents , cyanides, paints

Heavy metals, oils, grease,
buffing compounds, organic
solvents, paint pigments,
abrasives
                                 5-15

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                       TABLE 5-3 (Continued)
 Manufacturing
   industry
      Potentially hazardous
          waste  stream
                          Potentially hazardous
                              constituents
Special
  machinery    |||
  manuf ac tur ing*^1
  (SIC 355 and
  347)
     Heat  treating wastes
                  Electroplating wastes
                  Machining wastes
                  Coating wastes
                         Heavy metals, cyanides,
                         oils, additives, organic
                         solvents, acid and alka-
                         line cleaners, organic
                         residues

                         Heavy metals, cyanides
                         organic solvents, acid
                         and alkaline cleaners,
                         oils, grease, scale

                         Oils, organic solvents,
                         heavy metals

                         Paints, solvents, acid
                         and alkaline cleaners
Electronic
  components
  (SIC 367)
§§§
Wastewater treatment
sludges

Solvents and still
bottoms

Waste oils


Paint wastes


Metal scrap
Heavy metals, fluorides


Organic solvents, organic
residues, heavy metals,
oils,

Oils, heavy metals,
additives

Heavy metals, oils, sol-
vents, fungicides, resins

Heavy metals
Storage and pri-  Wastewater treatment
  mary            sludges
 batteries****
  <« MU an,            "
                          .
                              Heavy metals, electro-
                              lytic solutions

                              Heavy metals
                                 5-16

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                       TABLE 5-3  (Continued)
 Manufacturing
   industry
 Potentially hazardous
     waste stream
 Potentially hazardous
     constituents
Organic
  chemicals
  pesticides and
  explosives **
  (SIC 286, 2879
  2892)
Petroleum
Liquid heavy ends
still bottoms
sludges
waste products
solids
semi-solids
See Appendix D.3.5 for
specifics
  refining tt
  (SIC 2911)
Tank bottoms
                  Process sludges
                  Filter clays
                  Wastewater treatment
                  sludges

                  Fines
Oil, phenols, polynuclear
aromatics, other organics
heavy metals
Oil, phenols, ammonia
salts, polynuclear
aromatics, other organics,
heavy metals, acids
Oil, phenols, polynuclear
aromatics, ammonia salts,
other organics, heavy
metals

Phenols, ammonia salts,
heavy metals, runoff
constituents

Phenols, ammonia salts,
heavy metals
Petroleum         Sludges
  re-refiningtt
  (SIC 2992)
                  Spent clay
                  Process water
                         Acids, caustics, heavy
                         metals, ammonia, cresol,
                         oils, polymers, other
                         polar compounds,
                         asphaltenes
                         Oil, heavy metals,
                         polymers, other polar
                         compounds
                         Heavy metals, oils,
                         polymers, other polar
                         compounds, phenols,
                         sulfur compounds
                                 5-17

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                       TABLE 5-3 (Concluded)
*
 Versar, Inc., 1976
 Versar, Inc., 1975
 Arthur D. Little Inc., 1976
 Wapora, Inc., 1975
**TRW, Inc., 1976
  Jacobs Engineering Company, 1976
±t
  Swain et.al., 1977
§§
  SCS Engineers Inc., 1976
***
   Calspan Corporation, 1977
   Battelle Columbus Laboratories, 1976
ttt
   Wapora, Inc., 1977
§§§
333Wapora, Inc., 1977a
****
    Versar, Inc., 1975a
                                5-18

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     5.1.2.2  End Use Activities.  Activities which involve the end

use of finished products generate four basic categories of poten-

tially hazardous wastes:

     •  Product containers with residual product;
     •  Spills of hazardous products;
     •  Used products containing hazardous materials;
     •  Residuals from product consumption.

     End use generators of potentially hazardous waste include, but

are not limited to, households*, governmental agencies, utilities,

agricultural activities, service industries, construction activities,

wholesale and retail trade, and transportation activities.  For the

most part, the potentially hazardous waste streams from these end use

activities tend to be more homogeneous than those from manufacturing

activities.

     Different end use activities use or consume practically every

product manufactured, produced, or imported into the U.S.  As

previously discussed, many of these products are by themselves poten-

tially hazardous.  Such products usually are packaged or container-  '

ized for delivery to the point of end use.  Following this end use,

the product container or packaging is normally discarded as a waste.

These waste containers or packaging materials usually contain resid-

ual amounts of the potentially hazardous product and, thus, may

represent a potentially hazardous waste.  These residues may include

pesticides, paints, cleaning fluids, and oils.  Packaging materials
^Households are specifically exempted from regulation under Sub-
 title C.


                                 5-19

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containing pesticide residuals, for example, may be found in wastes
from households, agriculture, garden stores, golf courses, and
organizations engaged in right-of-way maintenance such as govern-
mental agencies, utilities, and railroads.
     End use activities may also result in spills of potentially
hazardous products.  Following cleanup, the spilled product is
usually discarded as a waste.  Both this waste product and the
materials which are used to clean up the spill represent potentially
hazardous waste.
     A third category of potentially hazardous waste from end use
activities consists of used, broken, or nonfunctioning products that
are hazardous themselves or that contain potentially hazardous
material. These products may include waste automotive oils and
solvents; used dry cleaning fluids; spent batteries and fluorescent
tubes containing mercury; nonfunctioning capacitors and transformers
containing polychlorinated biphenyls (FCB's); nonfunctioning smoke
detectors containing radioactive materials; and waste construction
materials containing asbestos.
     End use activities which consume part or all of a product may
produce residual materials which are potentially hazardous.  For
example, coal-fired power plants generate coal ash which may be a
potentially hazardous waste, depending upon its constituents.
     5.1.2.3  Unusable, Unneeded, or Unwanted Products.  Unusable,
unneeded, or unwanted finished products that are potentially hazar-
dous represent a further source of potentially hazardous waste.
                                 5-20

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Finished products may become unusable, unneeded, or unwanted for a




variety of reasons,  including governmental regulations prohibiting




the  use of specific  products; product recalls due  to contamination,



decomposition, deficiencies, or other problems; and products becoming




obsolete or  overage.  For  example, a number of pesticides, such as




DDT,  chlordane, and  mirex  have had their registrations canceled for



some  or all  of their uses, and the existing supplies have become




potentially  hazardous wastes.  Recalled products that have become



potentially  hazardous waste  include contaminated or decomposed lots



of Pharmaceuticals.  Obsolete military munitions,  such as initiating



agents, propellants, pyrotechnics, explosives, and riot control



agents, represent a  third  type of  finished product that has become a



potentially  hazardous waste.




      5.1.2.4  Transportation-Related Spills of Hazardous Materials




That Are Not Wastes. Spills of hazardous materials that are not



wastes occasionally  occur  during transport and are a further source




of hazardous waste.  When many hazardous materials  particularly



•liquids, volatile materials, and fine materials, are spilled, this



material  is  likely to become a waste and would be  subject to regula-



tion under Subtitle  C if it  exhibits the properties in Appendix B,




Subpart A.   Spills can  also  occur  during the manufacture or end use



of any product or material;  however, such spills are included in




existing waste streams  from  such activities and do not represent an




additional source of potentially hazardous wastes.






                                   5-21

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      Major sources of transportation-related spills of hazardous

materials include rail, truck, barge, and pipeline transport and

transfer operations.  Table 5-4 shows examples of potentially

hazardous materials that have been spilled in recent years.

5.2  Characterization of Hazardous Waste Transport

     The basic role of the hazardous waste transport industry is to

move hazardous waste from the point of generation to off-site

facilities for purposes of storage, treatment, and/or disposal.

Hazardous waste transport includes intrastate, interstate, and inter-

national movements by highway, rail, air, pipelines, and waterway.

     Three hazardous waste transport industry segments have been

identified in a study by Arthur D. Little, Inc. (1978a).  These seg-

ments are as follows:  generator/transporter, hazardous waste manage-

ment facility/transporter, and for-hire transporter.

     •  Generator/transporters are hazardous waste generators who
        function as private carriers by self-hauling hazardous wastes
        off-site to hazardous waste management facilities (transport
        by this "segment is invariably by truck).

     •  Hazardous waste management facility/transporters are opera-
        tors of hazardous waste management facilities who also
        function as contract or private carriers in providing trans-
        portation from generators to storage, treatment, or disposal
        facilities (transport by this segment is invariably by
        truck).

     •  For-hire transporters are common and contract carriers who
        transport hazardous wastes (and other property as well) but
        who do not generate, treat, store, or dispose of such wastes
        (transport by this segment is primarily by truck, but
        includes rail, waterway, and air).
                                 5-22

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                            TABLE 5-4

      EXAMPLES OF SPILLS OF POTENTIALLY HAZARDOUS MATERIALS*
Acids
  arsenic
  chlo ro sulfur ic
  hydrochloric
  muriatic
  nitric
  phosphoric
  sulfuric
Acrylonitrile
Ammonia solution
Ammonium nitrate
Anhydrous ammonia
Batteries and electrolytic fluid
Benzene
Butyl cellusolve
Caustic soda
Chlorine
Coolants
Copper sulfate
Creosote
Cyanide
Cycloh exylam ine
Denatured ethyl alcohol
Dyes
Ethylene diamine
Ethylene glycol
Ferric chloride
Ferrous sulfate
Formaldehyde
Gasoline
Hexane
Ink
Kepone
Latex
Lead oxide
Linseed oil
Methyl alcohol
Methyl bromide
Naptha
Nitrofurdzone
Oils
  crude
  cutting
  fuel
  hydraulic
  lube
  turbine
Faint
Paint thinner
PCB
Pentachorophenol
Perchloroethylene
Pesticides
Phenol
Phosdrin
Phosphorus
Potassium hydroxide
Resins
Seed corn (containing captan)
Sodium hydroxide
Solvents
Toluene
Trimethylamine
* U.S. Department of Transportation, Materials Transportation
Bureau, 1976; personal communication, J.E.  Aho, Minnesota
Pollution Control Agency, 1977; State of Ohio, 1974;  personal
communication, J. Dobbins, Ohio Environmental Protection Agency,
1977; Illinois EPA Emergency Action Center, 1977.
                               5-23

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     According to the Arthur D. Little, Inc. study, neither the



number of firms within each industry segment nor in the industry as a




whole is known, nor is the rate of firms entering or leaving the




industry.  Furthermore, the quantity of hazardous wastes transported




annually by the industry is unknown, as is the distribution of waste



transport by mode or by industry segment.




     To illustrate the magnitude of hazardous waste being trans-



ported off-site, based upon the waste quantities in Chapter 6 and the



average off-site disposal factor (see Table 5-10), there is on the



order of 8 to 10 million metric tons of potentially hazardous




manufacturing waste currently being transported off-site on an annual




basis.  Table 5-5 presents a qualitative estimate of the relative



amount of hazardous waste moved by mode and by industry segment.  The



vast majority of such waste is transported by highway with a small



amount being transported by rail and even smaller amounts being moved



by waterway.  Appendix E contains a detailed description of the three



industry segments, based on the Arthur D. Little, Inc. (1978a) study.



The following reiterates pertinent portions of that description.



     5.2.1  Generator/Transporter.  According to Arthur D. Little,




Inc., reliable data are extremely limited with regard to generator/



transporters; most of the information available on generator/trans-



porters is contained in the Industry Studies (1975-1978) prepared for




EPA.  About 3.5 percent of the plants inventoried in the Industry
                                5-24

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                            TABLE 5-5

         RELATIVE AMOUNT OF HAZARDOUS WASTES TRANSPORTED
              OFF-SITE BY MODE AND INDUSTRY SEGMENT*

Mode
Air
Rail
Highway
Waterway
Pipeline
Generator/
transporter
None
None
Very small
None
Negligible
Hazardous waste
management facility/
transporter
None
None
Large
None
Negligible
For-hire
transporter
Negligible
Small
Large
Very small
None
Modified from Arthur D. Little, Inc., 1978a.
                               5-25

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Studies transported their own wastes off-site, and less than three




percent of the total quantity of waste hauled off-site was trans-



ported by the generator.




     The tendency to self-haul is industry dependent.  For example,




waste oil re-refiners self-haul over 50 percent of their wastes going



off-site while the metal smelting and refining industry does little




or no self-hauling.  The limited data available suggest that



self-hauling firms tend to be the smaller firms in an industry and




tend to be located in rural areas where contractor services are not



available.  Wastes transported by self-hauling firms are usually



transported a distance of under 10 miles, and often are moved no more



than 1 to 2 miles.



     Wastes that are hauled by generators are typically transported



as generated, without treatment, and are usually taken either to a



site owned and operated by the company and dedicated specifically to



its wastes, or to a general-purpose municipal or private'landfill




that also handles municipal wastes.



     Generators, at least the major generators, do keep records of




how much waste is shipped, who carried it, and where it went.  Such



records are usually kept for a period of at least seven years.  Self-



haulers transporting to a company-owned site  typically prepare a sum-



mary report monthly on the quantity of material hauled (Arthur D.



Little, Inc., 1978a).
                                5-26

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     5.2.2  Hazardous Waste Management Facility/Transporters.  In




1977, there were approximately 110 hazardous waste management facili-




ties in the U.S. (Straus, 1977).  An estimated 50 to 67 percent of



these facilities also transport hazardous wastes (Arthur D. Little,



Inc., 1978a; Straus, 1977).



     Transportation activities of the hazardous waste management/




transporters tend to be interstate; 64 percent of the facilities con-



tacted in the Arthur D. Little, Inc. study have interstate transpor-



tation capabilities.  Further, 56 percent have locations in more than



one state or receive waste materials from out of state.  Those haz-



ardous waste management facility/transporters who operate intrastate




tend to serve a relatively small geographical area or section of the




state.  Those who operate interstate generally operate within one re-



gion rather than within several regions.  The portion of hazardous




waste handled by each type of operation is not known, nor is the




portion of the interstate operator's business that is done outside



his home state.




     Nearly all the facilities contacted keep records which contain



limited information about the quantity, source, waste type, and



delivery point for each transport/disposal job.  These records are in




various forms and include:  billing records (invoices), shipping



documents or bills of lading, purchase orders or job tickets, and



self initiated or state required manifests.  Usually these documents



are filed together and are retained for several years, based in part
                                5-27

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upon requirements by the Interstate Commerce Commission (3-year




retention), Internal Revenue (7-year retention), state tax depart-



ment, and other state agencies (Arthur D. Little, Inc., 1978a).




     5.2.3  For-Hire Transporters.  For-hire transporters include




common and contract carriers that transport hazardous waste by high-



way, rail, air, pipeline, and waterway.




     5.2.3.1  Common and Contract Highway Carriers.  According to




Arthur D. Little, Inc., very few data are available with regard to



common and contract highway carriers involved in the transport of




hazardous waste, and as a result, it was not possible even to develop



a representative sample for study purposes.  Thus, the information



reported by the study should only be considered as preliminary.




     About one-half of the for-hire transporters contacted do not



transport any hazardous waste across state borders.  Others indicated



that anywhere from 80 to 100 percent of their hazardous waste trans-




port is interstate.  Within those states which required permits for



transporting hazardous waste, the transporters usually indicated



statewide service.  Smaller transporters tended to see states requir-




ing permits as the practical limit of their service radius.  Exclud-




ing the national common carriers who provided no estimates, transpor-



ters indicated trip distances ranging from 25 to 150 miles, with most



companies responding at 50 miles.  One common carrier indicated that



500 to 600 mile trips were normal.  However, the above figure may not



be representative of the entire industry.  Quantities of hazardous






                                  5-28

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waste being transported interstate or intrastate could not be identi-




fied, nor, in most cases, could the total quantity of hazardous waste



being transported by individual companies.




     Very sketchy information is available on the nature of the




wastes transported.  Most of the firms contacted handled primarily



liquid wastes.  General transporters who handled the following types




of waste were identified:  liquids/solids/sludges, waste oils, sol-



vents for recycle, general hazardous trash, paint wastes, hydrocar-



bons, chlorine, acids, cyanide wastes, caustic wastes, hydrogen



fluoride, cleaning solutions, and radioactive wastes.  Though some



general transporters specialize in a particular waste, such as waste



oil or spent acid, most handle many kinds of hazardous waste.



     All of the firms contacted keep records.  The most common forms



for recordkeeping are the bill of lading and the weigh ticket.  The




transporters indicated that records were retained for at least five




or seven years as a result of state, Internal Revenue Service, and/or



Interstate Commerce Commission regulations in addition to general



management practice.



     5.2.3.2  Rail Transport.  As common carriers under the ICC, the



railroads must accept all cargo tended to them that is properly pack-



aged and labeled.  One of the most important aspects of the practices



and regulations in the transport of hazardous waste by railroad is



that the railroad does not directly handle the hazardous material as



such, but only transports rail cars ready for delivery.  The shipper




must provide to the railroad the sealed or closed containers of the




                               5-29

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hazardous material or waste and certify in the bill of lading that



the shipment conforms to regulations.



     A small amount of hazardous waste is transported by rail as



compared to highway transport.  Most rail shipments are by tank car.




Only a limited number of disposal sites accept hazardous waste by



rail, and only a small portion of the total hazardous waste trans-




ported by rail is believed to go to such disposal sites; most of it




is believed to go to reclamation and recovery facilities.  For exam-



ple, nearly all spent sulfuric acid and petroleum refinery treating



wastes transported by rail go to recyclers who have rail sidings on



their own property.




     The relevant documents for the transport of hazardous waste con-




sist of the bill of lading and the waybill.  The bill of lading is



prepared by the shipper, the waybill by the railroad.  For hazardous



materials, a copy of the certified bill of lading must be kept on



file by the original carrier for at least three years, in accordance



with ICC regulations (Arthur D. Little, Inc., 1978a).



     5.2.3.3  Air Transport.  The amount of hazardous waste trans-



ported by air is very small, possibly on the order of several tons




per year.  Small amounts of waste acids, flammable metal shavings,




radioactive materials, and laboratory samples of hazardous wastes




have been identified as being shipped by air.



     The existing DOT and FAA regulations require that copies of



shipping papers, prepared by the shipper, must be carried onboard.
                                 5-30

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The originating carrier must then maintain a copy of the shipping




paper for 90 days.  In addition to shipping papers, the air carrier



is to prepare a manifest for the total cargo of the shipment.




     5.2.3.4  Pipeline Transport.  Off-site pipeline transport of



hazardous waste is extremely limited.  On a national level, there are



no major pipelines for transporting wastes; the commercial pipeline



industry is almost entirely devoted to the transport of fuel



products.  Waste transport by pipeline is generally limited to a few



concentrated industrial areas in the U.S.  A number of isolated cases



of hazardous waste transport by private, not for-hire, pipeline were




identified by the Arthur D. Little, Inc. study.



     5.2.3.5  Waterway Transport.  The quantity of hazardous waste



transported by barge on inland waters appears to be small relative to




highway transport.  No vessels other than barges are known to carry



hazardous waste.  Shipments of hazardous waste move primarily on the




Gulf Intracoastal Waterway-Mississippi River System in tank barges



with a capacity range of 1,200 to 1,500 tons.  A typical one-way trip



may be on the order of 1,000 or more miles.  Most often, the waste




transported includes spent acids, spent caustics, and waste glycol.



The wastes are generally in liquid bulk form with a water content up



to 90 percent and normally are transported to resource recovery



facilities.
                               5-31

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     The bill of lading, weigh ticket, and shipping manifest papers

are the commonly used forms for recordkeeping.  The companies contac-

ted by Arthur D. Little, Inc. stated that records are retained in

current files for 5 to 7 years because of legal requirements as well

as administrative procedures.  In addition to the above forms, ship-

ping papers and a dangerous cargo manifest must accompany shipments

of hazardous packaged cargo and solids in bulk.

5.3  Characterization of Hazardous Waste Storage, Treatment, and
     Disposal

     Hazardous waste storage, treatment, and disposal currently oc-

curs both on and off the site of generation.  When transported off-

site as described in Section 5.2, the hazardous waste goes to such

locations as dumps, hazardous waste management facilities, resource

recovery facilities, and municipal and private landfills and incin-

erators.  This section presents a summary of typical hazardous waste

management practices; Appendix D provides a more detailed discussion.

     5.3.1  Storage.  Hazardous waste is often stored before treat-

ment or disposal, both on-site by the generator and off-site by

treatment and disposal facilities.  In the case of off-site treatment

or disposal, the waste is usually also stored by the generator until

economically transportable loads are accumulated.  Hazardous waste is

typically stored in ponds, lagoons, basins, drums, tanks, piles on

the ground, tank trucks, and dumpsters (see Appendices D and J).

Table 5-6 shows examples of storage practices in selected indus-

tries.

                                 5-32

-------
m
u>
CJ
           Industry
Paints and
  coatings
                                                 TABLE 5-6

                            EXAMPLES OF STORAGE PRACTICES IN SELECTED INDUSTRIES*
                            Type of waste
                                      Storage mode
Emulsion sludge from tank
washings - 18% solids,
82% water
                                                                  with vermiculite
                                                                  Holding tank
Storage time
Pesticides
Pharmac eut ica Is
Rinsed and crushed 5-gallon
metal Insecticide containers
Radlocative material
Bin
Packed in drums
3 months
3-4 months
 1-2 days
Electroplating and
metal finishing
Waste oil re-
refining
Waste oil re-
refining
Plating sludges
Spent liquid PCB's
Tarry sludge
Oil soaked In earth
(filter medium)
Holding tank
5 5-gallon drums
Holding tank
Contractor sup-
plied containers
4 hours
5-10 days
3-7 days
5 days

       *Arthur D. Little,  Inc.,  1978a.

-------
     Engineered storage is sometimes used when there is no safe




method of treating or disposing a particular hazardous waste.  Under




such circumstances the waste is containerized and buried or otherwise




stored until technologies are developed for treating or disposing it.



Wastes that have been subject to engineered storage in recent years



are discussed in Appendix D.




       5.3.2  Treatment.  The treatment of hazardous waste is gen-




erally directed toward separating the hazardous components from the



non-hazardous components of the hazardous waste stream, concentrating



the hazardous waste, rendering the waste less hazardous, reducing the




volume of waste requiring ultimate disposal, and/or recovering




materials or energy from the waste.  There are four basic types of



methods typically used for the treatment of hazardous waste:  physi-



cal treatment, chemical treatment, biological treatment, and thermal



treatment.




     Physical treatment consists of non-chemical means to remove sol-




uble and suspended constituents from aqueous waste streams and to



concentrate various constituents of the waste stream.  Chemical




treatment involves alteration of the molecular structure of waste




constituents so as to render the wastes less hazardous or to



separate specific constituents of the waste stream.  Biological



treatment involves the use of microorganisms to remove or degrade



organic materials present in wastewater streams by adsorption and



direct metabolism.  Thermal treatment employs heat to destroy
                                5-34

-------
hazardous waste, to render the waste less hazardous, and to recover




materials and energy from the waste.  Appendix D describes typical



processes used for each of the four treatment methods and the types




of wastes amenable to treatment by each method.



     Treatment of hazardous waste is at times limited to the appli-



cation of just one of the methods discussed above.  However, in many



instances, especially in the case of wastewater treatment or re-




source recovery, several of the methods are used in the course of



treating the hazardous waste.




     The treatment of hazardous waste using the above methods does



not typically constitute the ultimate disposal of the waste.  Treat-



ment generally produces a residual (e.g., sludge, ash, still bottom,



concentrated waste) which may be hazardous and which is typically



disposed using the methods discussed in Section 5.3.3.  For example,



many of the various physical, chemical, and biological treatment




methods are used as part'of primary, secondary, or tertiary waste-



water treatment and produce a sludge which is potentially hazardous



(see Table 5-3) and which requires disposal.




     Data are not available to estimate the portion of hazardous



waste that is annually treated prior to disposal, nor to estimate the



portion treated using each of the four basic types of treatment



methods.



     5.3.3  Disposal.  Disposal of hazardous waste involves the dis-




charge, deposit, injection, dumping, spilling, leaking, or placing of




any of the waste into or on any land or water so  that such waste or





                                5-35

-------
any constituent thereof may enter the environment or be emitted into




the air or discharged into any waters, including groundwaters.  Meth-



ods typically used for ultimate disposal of hazardous waste include:




open dumping, landfilling, landfarming, lagooning (surface impound-




ment), incineration, deep-well injection, discharge to municipal



sewer systems, surface discharge to rivers and streams, ocean dump-



ing, road application, and detonation.  In addition, engineered




storage is used in some instances.  Appendix D describes each of



these disposal methods and the types of wastes amenable to disposal



by each method.




     Data are not available to estimate the portion of all hazardous




waste disposed annually by each method.  However, Table 5-7 provides



an estimate of the portion of hazardous waste from 14 manufacturing



industries disposed annually by each method during the period from



1973 to 1975.  The table also provides an estimate of the portion of



waste disposed by each method that were disposed in environmentally



adequate and inadequate manners.  Less than 10 percent of these



hazardous manufacturing wastes are estimated to have been treated/



disposed in an environmentally adequate manner.



     5.3.4  Typical Management Practices for Hazardous Industrial




Waste.  Typical hazardous waste management practices are charac-




terized for thirteen manufacturing industries in Appendix D.  The



manufacturing industries discussed are as follows:  electronic



components manufacturing; electroplating and metal finishing;
                                5-36

-------
                                                TABLE 5-7

                           ESTIMATED PORTION OF HAZARDOUS  WASTES FROM FOURTEEN
                         MANUFACTURING INDUSTRIES DISPOSED BY METHOD, 1973-1975
LJ
Disposal method
Surface Impoundment
Dump 1
Landfill J
Incineration
Deep-well injection
Landspreading
Road application
Sewer
Othert
Weighted average
i
Percent disposed
by method^
48 §
33
15 §
2
0.3
< 0.1
< 0.1
2
-
Percent
environmentally
adequate
< 0.1
7
37
-
-
-
-
N/AU
10
Percent
environmentally
Inadequate
> 99.9
93
63
100
100
100
100
N/Afl
90
      *0ffice of Solid Waste, unpublished data.
      tPrimarily resource recovery
      ^Due to rounding, total exceeds 100%.
      §An unknown portion of the wastes handled by this method were ultimately disposed by other
      methods, primarily landfilling and dumping.
      UNot available.

-------
inorganic chemicals; leather tanning and finishing; metal smelting



and refining; organic chemicals, pesticides, and explosives; paint




and allied products and contract solvent reclaiming; petroleum



refining; petroleum re-refining; Pharmaceuticals; special machinery




manufacturing; storage and primary batteries; and textiles.



     Tables 5-8 and 5-9 indicate the estimated portion of potentially



hazardous waste treated/disposed by various methods in four manufac-



turing industries for which data are available.  Table 5-8 shows



estimated on-site treatment/disposal.  Table 5-9 shows estimated off-



site treatment/disposal.  Some of the methods listed, e.g., inciner-




ation and recovery, may generate hazardous residuals requiring



further disposal.  Data are not available as to the disposal of such




residuals.  It should be noted that the data in Tables 5-8 and 5-9



are based upon limited surveys of the industries and, according to



the various authors, may not be entirely typical of the industry as a



whole.




     For the thirteen manufacturing industries, treatment of poten-



tially hazardous wastes has, for the most part, been limited to



dewatering and some neutralization of hazardous sludges from



wastewater treatment, segregation of some waste streams or waste



stream components, and incineration of specific wastes or waste



streams.  Where reclamation and recovery is practiced, it has



typically been limited to on-site recovery of solvents, metals, oil,



products, plating solutions, and energy and to off-site recovery of



solvents, metals, and oil.




                                5-38

-------
                                                             TABLE 5-8

                                  ESTIMATED PERCENTAGE OF TOTAL HAZARDOUS WASTES TREATED/DISPOSED
                                    ON-SITE BY VARIOUS METHODS FOR SELECTED INDUSTRIES - 1973*
U)

LO
VO
                                                                   Treatment/disposal method
                                                                 (percentage of total generated)
Industry
Organic chemlcalst,9
Pharmaceut Icala*. 1
Petroleum refining^,**
Petroleum re-ref iningt.tt
Biological
treatment/lagoon
<1
2
18
-
Deep-well
2
-
1
-
Incineration Landfarm
70 #
37
B
-
Landfill
15
-
17
12
Recovery Application
8
-
-
* *
         * 1975 data used for petroleum re-refining industry.
         t Baaed upon dry weight of hazardous waste stream.
f           Based upon wet weight of hazardous waste stream.
           TRW, Inc., 1976.
         11 Arthur D. Little, Inc., 1976b.
         **Jacoba Engineering Company, 1976.
         ttSwaln et al., 1977.
         ft Small amount, data not available.

-------
                                                TABLE 5-9

                    ESTIMATED PERCENTAGE OF TOTAL HAZARDOUS WASTES TREATED/DISPOSED
                      OFF-SITE BY VARIOUS METHODS FOR SELECTED INDUSTRIES - 1973*
Y1
S
                                                   Treatment/disposal method
                                                 (percentage of total generated)
                           Incineration    Lagoon    Landfill    Recovery    Road application
Organic chemicalt.i 2
Pharmaceutical s$, 11 51
Petroleum
4
- 9 1
21 34 -
  refining^,**

Petroleum
  re-refiningtjtt
                                                        70
12*+
       * 1975 data used for petroleum re-refining industry.
       t Based upon dry weight of hazardous waste stream.
       $ Based upon weight of hazardous waste stream
       § TRW, Inc., 1976.
       V Arthur D. Little, Inc., 1976b.
       **Jacobs Engineering Company, 1976
       ttSwain et al., 1977.
       ^Includes small amount treated/disposed on-slte.

-------
     Table 5-10 presents, for the indicated year of assessment, the

estimated portion of hazardous waste treated/disposed on-site and

off-site and the portion going to reclamation for each of the

thirteen manufacturing industries.  A weighted average of about 82

percent of the hazardous waste is treated/disposed on-site and about

15 percent is transported off-site for treatment/disposal.  It should

be noted that these figures for on-site and off-site treatment/

disposal must be considered slight overestimates since they include a

very small amount of hazardous waste that is recovered on-site or

off-site, but for which separate data are not available.  It is

estimated that such waste comprises less than two percent of the

total hazardous waste.  The weighted average of hazardous waste for

which resource recovery is practiced is thus estimated to be three to

five percent.

     Three levels of treatment/disposal were identified for the thir-

teen manufacturing industries by the Industry Studies (1975-1978).

These levels are as follows:

     •  Level I - the level of treatment/disposal used commonly by
        the industry for a particular waste;

     •  Level II - the best technology employed commercially by the
        industry for a particular waste;

     •  Level III - the technology necessary for protection of
        health and the environment.

It was possible (though unusual) for Level I to be the same as Level

II for a given waste.  Levels II and III were frequently reported as

being the same (Battelle Columbus Laboratories, 1978).
                               5-41

-------
                            TABLE 5-10

    ESTIMATED PERCENTAGE OF HAZARDOUS WASTES TREATED/DISPOSED
               OR RECOVERED ON-SITE AND OFF-SITE*
Industry
Electronic components
manufacturing§
Electroplating and
metal finish ing §
Inorganic chemical t
Leather tanning and
finishing^
Metal smelting and
refining^
Organic chemical st
Paint and allied
products^
Petroleum refineryt
Petroleum re-refinery §
Pharmaceuticalst .
Special machinery
manufacturing §
Storage and primary
batterlest
Textiles*
Weighted average
Treated/
disposed
on-site
13
19
85-90
10
98
87
5
44
12
39
10"
35
49
82
Treated/
disposed
off-site
66
81 1
10-15
90
2
5
90
56
76
60
90
65
51
15
Recycled/
reclaimed
21
—
**
**
tt
8
5
tt
12
1
tt
tt
**
3§§
* Industry studies, 1975-1978.
t 1973 data.
$ 1974 data.
§ 1975 data.
11 Includes 45% sent to sanitary sever systems
**Data not available, small amount reclaimed included in off-site data.
ttData not available, small amount reclaimed included in on-site data.
$$Data not available, small smount reclaimed Included in off-site and
onrsite data.
§§Small additional amount included in off-site and on-site data.
                                5-42

-------
      Table 5-11 provides, for four manufacturing industries for

which data are available, estimates of the portion of hazardous

wastes generated by each industry that was subject to Level I,  II, or

III treatment/disposal during the year of assessment.  Data are not

available to provide similar estimates for the other nine manufac-

turing industries.  For the industries listed in Table 5-11, between

70 and 85 percent of the hazardous waste was treated/disposed using

Level I technologies (i.e., one that is not the best technology

commercially available nor adequate for protection of health and

environment) and between zero and 5 percent was treated/disposed

using Level III technologies.

     5.3.5  Hazardous Waste Management Service Industry.  The hazard-

ous waste management service industry is engaged in the off-site

storage, treatment, disposal, and reprocessing/recovery of hazardous

wastes.  The industry operates independently of hazardous waste gen-

erators; however, as a service to generators, over half the firms in

the industry transport hazardous waste to their facilities from gen-

erators (Arthur D. Little, Inc., 1978a).

     In 1975 there were approximately 95 firms active in the indus-

try, operating about 110 hazardous waste management facilities.  The

industry's facilities are concentrated in industrial areas, with

nearly 60 percent of both the facilities and the overall process

capacity* located in EPA Regions II, V, and IX.  Figure 5-1 shows
^Process capacity consists of the throughput capability for hand-
 ling hazardous wastes and includes storage, treatment, disposal,
 and recovery capacity.

                                 5-43

-------
                             TABLE 5-11

      ESTIMATED PERCENTAGE OF HAZARDOUS WASTES TREATED/DISPOSED
                BY LEVEL I, II, OR III TECHNOLOGY FOR
                  SELECTED MANUFACTURING INDUSTRIES
Industry
Leather tanning and
finish Ing*, 1
Paint and allied
products t, H
Petroleum re-refining^,**
Special machinery
manufacturing!!,**
Level I
85
70

78
70
Level II Level III
10 5
25 5

22
30
 *SCS Engineers, Inc., 1976.
 tWapora Inc., 1975.
 ±Swain et al., 1977.
 iWapora, Inc., 1977.
 11974 data.
**1975 data.
                                5-44

-------
Cn

i
01
                                             SOUTH DAKOTA    ?      \ '""'

                                                              *•• •
                                                                •vw
                                   OOUDRAOO    	1

                                                  L       i
                                                      — ^.— -x
                                                 FIGURE 5-1

                       GEOGRAPHIC DISTRIBUTION  OF HAZARDOUS  WASTE MANAGEMENT FACILITIES
        Source:   Straus, 1977.

-------
Che geographic distributions of the facilities.  Total employment

within the industry was approximately 2,000 persons in 1975 (Foster

D. Snell, Inc., 1976).

     At the end of 1974, the process capacity for the industry as a

whole was nearly 7.3 million metric tons per year, with about 53 per-

cent of the overall process capacity being utilized on an annual

basis* (Foster D. Snell, Inc., 1976).  Since some hazardous waste

requires several process stages (e.g., treatment and disposal), the

total quantity of waste that can be handled is somewhat less than the

overall process capacity.  The Foster D. Snell, Inc. study es-

timated that about 5.3 million metric tons of the overall process

capacity might be considered environmentally adequate.t  The study

further estimated that the overall process capacity would expand to

8.2 million metric tons at the end of 1977, with about 6.2 million

metric tons being considered environmentally adequate.*  Table 5-12

shows, for selected processes, the daily capacity available in 1974

by EPA Region.
 ^According to the Foster D. Snell, Inc. study, the low capacity
  utilization is the result of poor regulations and/or poor enforce-
  ment of regulations applicable to hazardous waste treatment/
  disposal.
      Foster D. Snell, Inc. study considered incineration, secure
  landfills, chemical treatment, biological treatment, and resource
  recovery as environmentally adequate processes.  Some unknown
  portion of these processes, however, might not be considered
  environmentally adequate under the Subtitle C regulations.
                                 5-46

-------
                                       TABLE 5-12

                          CAPACITY OF SELECTED HAZARDOUS WASTE    ^
                      MANAGEMENT SERVICE INDUSTRY PROCESSES - 1974
Process capacity
(thousands of gallons per 24
EPA
region
I
II
III
u. IV
S v
VI
VII
VIII
IX
X
Total
Number of
facilities
6
18
9
7
27
10
8
1
19
5
110*
Chemical
treatment
46
71
265
20
1,530
70
250
t
57
28
2,337*
Secure
Incineration landfill
4
153
35
44
361
60
5
t
14
-
6764=
4
239
15
46
230
135
66
t
639
325
1,714*
hour day)
Deep well Resource
injection recovery
9
57
15
100 315
795 230
50
t tt
400
405
395* 1,481*
*Foster D. Snell, Inc., 1976.
tData are not available.
      not Include EPA Region VIII.

-------
      The hazardous waste management service industry generally




groups the wastes it handles into five categories:   metals/metal



finishing; paints/solvents/coatings; organics; petroleum;  and




inorganics.  Table 5-13 lists examples of the types of hazardous




wastes handled within each category and typical treatment/disposal



methods employed.




     5.3.6  State Data on On-Site and Off-Site Disposal.  Very few



states have at this time accumulated sufficient data to estimate the



portion of hazardous waste generated within the state that is being



disposed on-site and off-site of the generation facility.   Table 5-14




presents, for eight states and one EPA Region, recent estimates of



the portion of each state's hazardous industrial waste that is




disposed on-site and off-site, the portion of the waste whose



disposal whereabouts is unknown, and the portion of the waste being



reclaimed.  Table 5-14 also indicates the estimated portion of each




state's hazardous industrial waste upon which the disposal and



recovery estimates are based.  The fate of the remainder of the



hazardous industrial waste in these states is not known.




     Except for Texas and Illinois, the data in Table 5-14 were



collected as part of studies to assess existing hazardous waste



management practices in the state and to determine needed changes in



the state's regulatory approach to hazardous waste management.  The



data for Texas and Illinois were reported to these states as required



under their hazardous waste regulations.  Comparable data for dispo-



sal and recovery practices either prior to or after enactment





                                 5-48

-------
                            TABLE 5-13

           TYPES OF HAZARDOUS WASTES HANDLED AND TYPICAL
                TREATMENT/DISPOSAL METHODS FOR THE
                HAZARDOUS WASTE MANAGEMENT INDUSTRY
 Market category
       Typical
 treatment/disposal
       methods
    Types of
    hazardous
 wastes handled
Metals/metal
  finishing
Paints/solvents/
  coatings
Neutralization
Chemical treatment
Sanitary landfill
Secure landfill
Deep well injection
Ocean disposal

Incineration
Chemical treatment
Sanitary landfill
Secure landfill
Acid solutions
Metals containing
  sludges
Organics
Solvents
Organics
Incineration
Biological treatment
Chemical treatment
Sanitary landfill
Secure landfill
Pesticides
Biologicals
Rubber
Plastics
Petroleum
Inorganics
Incineration
Deep well injection

Chemical treatment
Ocean dumping
Secure landfill
Oily wastes
Aqueous
  solutions of
  salts, metals,etc.
 Foster D. Snell, Inc., 1976
                                5-49

-------
                                              TABLE 5-14


                          ESTIMATED PERCENTAGE OF HAZARDOUS INDUSTRIAL WASTES

                         DISPOSED BY LOCATION OR RECLAIMED FOR SELECTED STATES
Ul
o

State

Florida*,!
niinoisU
Kansas**
Marylandtt,**
Ma s sachu set t s § §
Mlnnesotaflfl
Region X***
Rhode Islandttt
Texas^tt

wastes included
In estimate*

NA§§§
100
23
NA
100
9-16
NA
NA
100
Disposal location
On-site

85
50
39
12
. -
65
63
1
36
Off -Bite

8
18
49
33
14
25
22
81
9
Unknown Othert
Unknown Diacharge8 Deep-well
Injection
7 g
21 - 10
5
51 #
65 10
- 3 -
_
14
20 - 31
Reclaimed

-
-
7
4
11
7
15
4
4

-------
                                   TABLE 5-14 (Concluded)
*  This is the estimated portion of the state's total, hazardous,
Industrial wastes upon which the disposal and recovery percentages are
based
t  Other Includes disposal by methods which are not regulated under
Subtitle C.  These Include discharges to municipal sewer systems, surface
discharges under National Pollution Discharge Elimination System (NPDES),
and deep-well injection.
$  Carter et al., 1977.
§  These data have been modified to eliminate a large volume of wastewater
containing a small amount of hazardous waste that is discharge to
municipal sewers.
H  Personal communication, S. Miller, 1978.
** State of Kansas, 1977.
ft State of Maryland, 1977.
$$ These data have been modified to eliminate a large volume of wastewater
containing a small amount of hazardous waste that is discharge
municipal sewers and to streams.
§§ Fennelly et.al., 1976.  If waste automotive oil is included, the
percentages are as follows:  on-slte - 0%, off-site - 8%, unknown - 68%,
discharged - 6%, reclaimed - 18%.
flu Battelle Pacific Northwest, 1977.
***Stradley et.al., 1975.  Region X includes Alaska, Idaho, Oregon, and
Washington.   .
tttRhode Island Department of Health, 1977.
±#State of Texas, 1976.
§§§NA means not available.

-------
of che state's current hazardous waste legislation (or equivalent



legislation) are not available.  Differences in the portion of waste



disposed on-site and off-site in the various states are due primarily



to factors such as differences in types of industries and wastes gen-




erated by these industries, availability of allowable on-site and




off-site disposal locations, and specific state regulations and



enforcement policies.




5.4  Resource Conservation and Recovery



     RCRA defines resource conservation as the reduction of the



amounts of solid waste that are generated, the reduction of overall



resource consumption, and the utilization of recovered resources.



Resource recovery is defined as the recovery of material or energy



from solid waste.




     This section describes typical methods used for resource conser-



vation and recovery and the typical operations specializing in_ the




recovery of hazardous waste.  Estimates of the extent to which



hazardous waste is presently being recovered or recycled are pre-



sented, along with examples of the potential for increasing the



recovery and recycling of hazardous waste.  Factors which have tended



to constrain the recovery and recycling of hazardous waste are



summarized.



     5°.4.1  Resource Conservation and Recovery Methods and Opera-




tions.  There are three basic procedures for recovering materials and



energy from potentially hazardous wastes:  separation, material



conversion, and energy conversion (Sittig, 1.975).




                                5-52

-------
     Separation involves the removal of specific waste constituents


using the physical and chemical treatment methods discussed in Appen-


dix D.  Material conversion involves the transformation of waste con-


stituents from a form which is not acceptable for recovery or reuse


to one that is acceptable, using the chemical treatment methods dis-


cussed in Appendix D; the waste may not be in an acceptable form due


to such factors as its toxicity or its inability to yield to separa-


tion.  Energy conversion involves the direct utilization of the waste


as an energy source either through combustion using the incineration


methods discussed in Appendix D or by using the waste to drive a


chemical process.


     Operations that specialize in the recovery of hazardous waste


can be categorized as follows:  solvent reclaimers, mercury reproces-


sors, metal reprocessors, petroleum rerefineries, industrial waste


information clearinghouses, and industrial waste exchanges (Straus,


1977).  Of these resource recovery operations, the industrial waste


clearinghouses and exchanges would likely have the most direct bear-


ing on increasing the recovery of hazardous waste.  These opera-
                            •

tions are described in Appendix G.


     Table 5-15 presents the nationwide distribution of these types


of recovery operations.  A total of 131 solvent reclaimers, eight


mercury reprocessors, seven metal reprocessors, 28 petroleum


re-refiners, eight industrial waste information clearinghouses, and


one industrial waste exchange have been identified.  The states with
                                 5-53

-------
                   TABLE 5-15
DISTRIBUTION OF HAZARDOUS HASTE RECOVERY OPERATIONS
              IN THE UNITED STATES*

State
Alabama
Alaska
Arizona
Arkansas
California

- Colorado
Connecticut
Delaware
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota

Solvent reclaimers
1

4

-. 11

1
1
1
2
3


14
5
7
4
2


2
2
9


4

1


10

6
1

a
Mercury reprocessol




2








1







1








1

1


„
Reprocessors (metal
non-mercury













1
1















1

4



Petroleum
rc-ref Iners




4




3
1


1
1

1





1
2
1





1

1



Industrial waste
Information
clearinghouses





1 Remarks

NA

NA
1 Waste
Exchani




i


i

i





•





NA









. one firm ocean
dumps



1




me firm ocean
dumps

1






NA


,NA

NA


NA
                       5-54

-------
                        TABLE 5-15 (Concluded)


Stste
Ohio
Oklahoma
Oregon
Pennsylvania
Puerto Rico
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Veroont
Virginia
Washington
West Virginia
Wisconsin
Wyoming

nt reclaimers

&
10

3
4

2
2

3
8



3

5
'
131
i
1
14
X
3




1





1


iH
i.
23
if
as
1












Agent for oeeai




8




7
Leura
refiners
S.
U b
S.
1
1
1
2




1
3
1

trial waste
oroation
ringhouaes
SSS
!"»








1
1


-going Incineration ship


1

28




8
3

1




NA


HA



NA


NA

HA
.
*Straus, 1977.'
                                   5-55

-------
the greatest activity in this area are California, with 17 reclaimers




and one industrial vaste clearinghouse, Illinois with 17 reclaimers




and one industrial waste exchange, New Jersey with 13 reclaimers, New




York with 13 reclaimers and one industrial waste clearinghouse, and




Texas with 12 reclaimers and one industrial waste clearinghouse




(Straus, 1977).




     5.4.2  Resource Recovery and Recycling Estimates.  This section




discusses the quantity of hazardous waste currently being re-




covered and recycled and the potential for increasing the recovery




and recycling of hazardous waste.




     5.4.2.1  Quantities Recovered and Recycled.  Extremely limited




data are available as to the extent to which resource recovery 'from




hazardous waste currently occurs in the U.S.  The available data tend




to be very industry and waste stream specific.  As discussed below,




the available data indicate that only a very small portion of the




total hazardous waste stream is subject to any resource recovery,




probably less than 3 to 5 percent of all such wastes.  This recovery




rate is similar to, but slightly less than, that for post-consumer




municipal wastes.  In recent years between 8 and 10 percent of the




overall post-consumer municipal wastes have been recovered for re-




cycling, with waste paper accounting for over 85 percent, by weight,




of the material recovery (Office of Solid Waste, 1977b).  Section




5.4.3 discusses factors that have tended to limit the recycling and




recovery of all waste materials.
                                 5-56

-------
     Table 5-16 presents examples of hazardous waste recovery and re-



cycling practices for the manufacturing industries analyzed in the



Industry Studies (1975-1978).  Such practices are generally limited



to the recovery of solvents, oil, metals, and energy and to some




recycling of off-specification and rejected products back into the



production process (see Appendix D for a more detailed discussion of




recovery and recycling practices).  For these industries, it is



estimated that on the order of 3 to 5 percent of the total hazardous



waste stream is annually subject to resource recovery (see Table



5-10).



     Table 5-14 shows, for eight states and one EPA Region, the




percentage of the industrial hazardous waste that is estimated to



have been reclaimed in recent years.  These available data indicate




that four percent or less of the hazardous waste is being reclaimed



in five of these states.  Only in Massachusetts and EPA Region X is




more than 10 percent of the hazardous waste being reclaimed.



     The only specific hazardous waste components for which nation-




wide recovery data are available are waste oil and waste solvents.



Table 5-17 indicates sources of waste oil generation and uses of this



waste oil during 1972.  Over 51 percent of the waste oil is estimated



to have been recycled, with about 44 percent used as a fuel and about



8 percent re-refined to lube oil.



     Data are not available as to the total quantity of wastes sol-



vent generated annually; however, it is estimated that in 1974
                                5-57

-------
                                               TABLE 5-16

                           EXAMPLES OF HAZARDOUS WASTE RECOVERY AND RECYCLING
                                    PRACTICES IN SELECTED INDUSTRIES*
          Industry
                             Hazardous waste stream
                                        Reclamation practices-
      Textiles (SIC 22)
                           Dye and chemical containers

                           Solvent and still bottoms
                                        Recycled

                                        Solvent recovery
Ul
in
oo
Inorganic chemicals
    (SIC 281)
Mercury contaminated wastes

Chlorinated hydrocarbons


Chrome pigments production
Mercury recovery

Used inorganic chemicals
   manufacture

Metal recovery
      Pharmaceuticals
          (SIC 2831,  2833,
          and 2834)
                           Waste solvents
                                 Heavy metals
                                        Solvent recovery; energy
                                        recovery; production of
                                        low grade fuel

                                        Zinc and chromium recovery
      Paint and allied
          products (SIC 285)
                           Discarded products and spills
                                        Recycled in lower grade
                                        products
                                 Waste wash solvents
                                                                   Solvent recovery

-------
                                               TABLE 5-16 (continued)
              Industry
     Hazardous waste stream
  Reclamation practicet
      Organic chemicals,       Heavy ends from nitrobenzene
         pesticides, and         production
         explosives (SIC 286,  Semisolid wastes from toluene
         2879, and 2892)         dllsocynate production

                               Sludge from lead alkyIs
                                 purification

                               Red water
                                       Energy recovery

                                       Energy recovery


                                       Lead recovery


                                       Recycled to kraft pulp mills
01
vo
      Petroleum refining
         (SIC 2911)
Crude tank bottoms

API separator sludge

Dissolved air flotation float

Slop oil emulsion solids

Spent lime


FCC catalyst fines

Spent catalyst
Oil recovery

Oil recovery

Oil recovery

Oil recovery

Recycled to spent acid
  neutralization

Aluminum recovery

Metal recovery

-------
                                         TABLE 5-16 (continued)
        Industry
     Hazardous waste stream
  Reclamation practicet
Leather tanning and
   finishing
   (SIC 3111)
Trimming and shavings
                         Finishing residues
Used in fertilizer, animal
  feed supplements, glue,
  leather articles

Solvent recovery
Metal smelting and
  refining (SIC 33)
Primary copper dusts

Primary copper slurries

Primary lead sludge

Primary zinc sludge

Primary aluminum potliners
  and pot skimmings

Iron and steel mill sludges

Iron and steel mill scales

Iron and steel pickle liquor
Metal recovery

Metal recovery

Metal recovery

Metal recovery

Cryolite recovery


Iron and tin recovery

Iron recovery

Acid regeneration
Electroplating and
  metal finishing
  (SIC 3471)
Degreaser sludges
Solvent recovery

-------
                                         TABLE 5-16 (Concluded)
        Industry
     Hazardous waste stream
  Reclamation practicet
Special machinery
  manufacturing
  (SIC 355 and 357)
Machinery wastes



Electroplating wastes

Heat treating wastes
Solvent recovery; metal
  recovery; recovery and/or
  reuse of oils

Metal recovery

Solvent recovery, metal
  recovery
Electronics components   Solvents
  manufacturing
  (SIC 367)              Oils
                         Metal scraps
                                       Solvent recovery

                                       Recovery and/or reuse metal
                                         recovery

                                       Metal recovery
Storage and primary
  batteries
  (SIC 3691 and 3692)
Wastewater treatment sludge

Rejected and scrap cells
Metal recovery

Metal recovery
* Industry studies (1975-78)
t On-site and/or off-site reclamation practices

-------
                             TABLE 5-17

                  WASTE OIL SOURCES AND USES, 1972*
                                              Quantity
         Source and uses                  (million gallons)


Consumption of lube oils

   Automotive                                  1,100

   Industrial and aviation                       700

   Other (includes government)                   400

     Total consumption                         2,200
Generation of waste lube oils
Automotive
Industrial and aviation
Other (includes government)
Total waste oil generation
600
400
100
1,100
Current uses of waste oil

   Fuel                                          480

   Re-refined                                     90

   Road oil and asphalt                          200

   Fate unknown                                  340t

     Total                                     1,110
*  U.S. Environmental Protection Agency, 1974
t  Includes 30 million gallons of re-refining wastes
                                 5-62

-------
contract solvent reprocessing operations reclaimed about 270,000




metric tons of waste organic solvents and that an unknown amount of



solvents was also recovered on-site by generators (Wapora, Inc.,




1975).  Two major categories of solvents are reprocessed.  One



category is halogenated solvents, such as me thylane chloride, tri-



chloroethylene, perchloroethylene, and 1,1,1-trichloroethane, which



result primarily from degreasing and metal cleaning operations.  The



other category is non-halogenated solvents which includes aliphatic



hydrocarbons, aromatic and naphthenic hydrocarbons, alcohols,



ketones, and esters.  These waste solvents are generated by the




chemical process industry, metal cleanings and coatings operations,



industrial painting operations, printing operations, solvent manu-



facture and distribution, and paint manufacture (Wapora, Inc., 1975).



     5.4.2.2  Potential for Recovery and Recycling of Hazardous



Wastes.  This section discusses the potential for increased resource




recovery and recycling of hazardous waste.  Any evaluation of the



potential recoverability of hazardous waste is complicated by the



diverse nature of both the waste itself and the processes for




recovering or for recycling the waste material.  Because of this



extreme diversity, each waste stream must be considered separately



within each industry, and often on a plant-by-plant basis, in order



to obtain an accurate picture of the recovery or recycling potential



for that type of waste.  In addition, the processes required for



recovery or recycling must also be considered to determine their
                                5-63

-------
economic viability.  The following examples are presented to illus-

trate the potential for increased recovery and recycling.  Appendix F

presents several other examples of specific waste streams that have a

potential to be recoverable.

      Arthur D. Little, Inc. (1976) examined the potential for trans-

ferring selected wastes from generators to other facilities that

could use the waste as a feedstock.*  Individual hazardous waste

streams identified as having a relatively high potential for recovery

or recycling are those which contain:  solvents, alkalies, concentra-

ted acids, catalysts, oils, combustibles, and high concentrations of

recoverable metals.  Based upon these potentially recoverable consti-

tuents, Table 5-18 presents estimates of the types and quantities of

selected hazardous wastes that might have a potential for being

recovered or recycled.  It should be noted that the quantities in

Table 5-18 are meant only as an order-of-magnitude estimate; the

listed wastes were selected by Arthur D. Little, Inc. based solely

upon the properties previously described, without regard to the eco-

nomic or technical feasibility of their recovery; the quantities

represent the estimated total amount of such wastes generated, not

necessarily the amount that could realistically be expected to be

recovered or recycled.  The listed wastes represent about 25 percent

of the hazardous waste stream from the industries included in the

Industry Studies and about 3 percent of the total solid waste stream
*The hazardous wastes examined were those identified in the
 Industry Studies (1975-1978).

                                  5-64

-------
                                          TABLE 5-18

           ESTIMATED MAGNITUDE OF HAZARDOUS WASTES FROM SELECTED INDUSTRIES THAT
                        MAY BE POTENTIALLY RECOVERABLE OR RECYCLABLE*
       Industry
         Waste
  Potential value
  for recovery or
  recycling
   Quantity as
generated (metric
   tons/year)
Pharmaceuticals
  (SIC 283)
Paint and allied
  products
  (SIC 2851)

Organic chemicals
  pesticides,
  explosives (SIC
  286, 2879, & 2892)

Petroleum refining
  (SIC 2911)
Leather tanning
  and finishing
  (SIC 3111)
Halogenated solvents,
tars, still bottoms,
carbon filter aid

Spoiled paint or
lacquer batches and
wash solvents

Chlorinated hydrocarbon
liquid heavy ends
Other still bottoms
Coke fines
FCC catalyst
fines

Sludges and trimmings
Degreasing solvents;
cleaning or paint
solvents; fuel

Solvent recovery,
upgrading
Degreasing solvents

Fuel
Fuel
Catalyst recovery
Leather composites
     160,000



      14,000



     247,000

   1,600,000
      13,000
     117,000
      12,000

-------
                                               TABLE 5-18  (Concluded)
            Industry
                                 Waste
  Potential value
  for recovery or
  recycling
   Quantity as
generated (metric
   tons/year)
01
Primary metals
  (SIC 331)

Electroplating
  (SIC 3471)

Special machinery
  manufacturing
  (SIC 355 & 357)

Primary batteries
  (SIC 3692)
          Total
                             Still pickle liquor
                             Degreaser sludges
6% sulfuric acid with
metals

Solvent recovery
                             Solvents, metals, oils,    Recovery and reclamation
                             acids,  and alkalis
                             Reject  cells

                             Wastewater  treatment
                             sludge
Metal recovery (17-70%
Zn, Hg, Pb, Cd)
Metal recovery (40% Cr)
    3,500,000


      105,000


       73,000



        1,200

           25


    5,800,000
       Modified  from Arthur D. Little, Inc., 1976.

-------
from these industries (Arthur D. Little, Inc., 1976).  It should also

be noted that an unknown portion of these wastes is currently being

recovered (see Appendix D).

     Table 5-19 shows, for selected industrial processes in SIC Code

28 and selected organic chemical wastes from these processes, poten-

tial uses to which the wastes might be recycled.  Again any such use

would be very dependent upon technical, economic, and environmental

considerations (Arthur D. Little, Inc., 1976).

     Reynolds, Smith and Hills (1977) examined the potential for

energy recovery from selected wastes from eight industries.  The

industries were chosen based upon the following criteria:  heating

value of their waste, annual volume of hazardous waste generated,

relative toxicity of hazardous components, and ability to use
                                 o
recovered energy.  Table 5-20 summarizes the industries selected and

the potentially hazardous waste streams studied.  Table 5-21 shows

the total quantity of process related wastes (hazardous and non-

hazardous) from each industry, the total' quantity of hazardous

process waste included in the study, the estimated average heating

value of the waste streams studied, the maximum energy estimated to

be annually recoverable from the waste streams studied, and the esti-

mated annual fuel savings based upon this maximum energy recovery.

It should be noted that in determining the maximum recoverable

energy, it was assumed that the entire waste stream would be incin-

erated.  Of the waste streams studied, those of the paints and


                                 5-67

-------
                                                       TABLE 5-19

                                  GENERATION AND POTENTIAL USE OF  ORGANIC CHEMICAL WASTES*
                              Waatea Generated
                                                                                               Potential Dies
alb
co
-------
                            TABLE 5-20

           INDUSTRIES AND HAZARDOUS WASTE TYPES STUDIED
                  FOR ENERGY RECOVERY POTENTIAL*
        Industry
   Types of hazardous wastes
           considered
Organic chemicals
      SIC 286
Distillation column bottom sludges,
evaporator, residues, filter
residues
Plastics
      SIC 282

Pharmac euticaIs
      SIC 283
Petroleum refining
      SIC 291

Tires and inner tubes
      SIC 301

Fabricated rubber products
      SIC 306

Paints and allied coatings
      SIC 285

Solvent reclaiming
Distillation column bottoms
Waste solvents (halogenated and
non-halogenated, organic chemical
residues, contaminated inerts

Tank bottoms, API separator sludges,
DAP sludges, slop oil emissions

Floor sweepings, air pollution
equipment dust

Air pollution equipment dust, floor
sweepings

Solvent recovery still bottoms,
waste solvents

Distillation column bottoms
^Reynolds, Smith and Hills, 1977.
                                5-69

-------
                                                        TABLE 5-21

                              ESTIMATED ANNUAL HASTE  QUANTITIES AND TOTAL RECOVERABLE ENERGY*
Industry
(SIC code)
Organic Chemicals
(286)
Plastics (282)
Petroleum Refining
(291)
Tires & Inner
Tubes (301)
in Fabricated Rubber
^ Products (306)
O (Dry Process Only)
Paints & Allied
Coatings (285)
Solvent Reclaiming
(No SIC Code)
Pharmaceuticals
(283)
Total process
related wastes
(103 metric
tons) (1977)t
Wet
109004=
2335
1504
236

210
450

72
1910S

Total hazardous
wastes considered
(103 metric tons)
Wet
3430
1
758
223

210
14

72
66

Average
value**
KCal/Kg
3900
1
6010
7220

7410
8300

6940
6180

heating
Btu/lb
7040
11
10820
13000

13340
14940

12SOO
11120

Maximum total
recoverable
energy (1977)
KCalxlO12 BtuxlO12
8.05 31.9
11 «
2.73 10.8
0.97 3.8

0.93 3.7
0.11 0.44

0.30 1.20
0.25 1.0

Annual fuel
savings (103
equivalent
barrels of oil)
6700
1
2275
808

778
88

253
204

*  Reynolds, Smith and Hills, 1977
t  Includes hazardous and non-hazardous wastes
+  This Includes those streams which are diluted for hydraulic  transport  for deep well Injection or lagoonlng.
Practically all wastes streams (ca.98Z) are dry as discharged from  the process.
§  This contains large Quantities of mycelllum which are  non-hazardous.

1  Not deternlnable
** For purpose of comparison, bituminous coal  has a higher heating value of approximately 6,200 KCal/kg (12,000 Btu/lb)

-------
allied coatings industry (SIC 283) had the highest estimated heating




value—8,300 KCal/kg (14,940 Btu/lb)—and those of the organic chemi-



cals industry (SIC 286) had the lowest estimated heating value—



3,900 KCal/kg (7,040 Btu/lb).  These heating values can be compared



with an approximate higher heating value of 6,700 KCal/kg (12,000



Btu/lb) for bituminous coal.



     The Reynolds, Smith and Hills study found that the organic



chemicals, plastic, petroleum refining, pharmaceuticals, paint, and




solvent reclaiming industries have considerable potential for



incineration with heat recovery.  The study found that the tire and




fabricated rubber industries do not have a high potential due to the



fact that the hazardous waste from these industries consists



primarily of floor sweepings with a large ash content.



     5.4.3  Constraints to Resource Conservation and Recovery.  There




are several basic factors that have tended to limit the application




of resource conservation and recovery measures to waste in general



and to hazardous waste in particular.  These factors include:



national policies favoring the use of virgin materials, economics,




technological considerations, and institutional constraints.



     The Federal government has historically played a major role in




stimulating natural resource development.  Special tax laws relating



to mining and forestry and Federal subsidies for raw materials



exploration, research, and development all have favored virgin raw
                                 5-71

-------
materials and encouraged a materials-intensive economy.  In addition,
a number of laws and agency policies have tended to discriminate
against recovered or recycled materials and waste reduction measures
(Office of Solid Waste, 1977b).  Similarly, most state laws have
either tended to favor the use of virgin materials or not to have
encouraged the recovery and recycling of waste materials.
      Economic factors affecting resource recovery and recycling
include both the cost of recovery and the cost of the transportation
required to bring the waste where needed, as well as the relation-
ship of recovery costs to disposal costs and to costs of virgin
materials.  As indicated above, tax laws and subsidy policies have
tended to favor the use of virgin materials.  Furthermore, due to the
nature of most waste, recovery costs have tended to be high compared
both to disposal costs under existing practices and to virgin
material costs, thus also favoring the use of virgin materials (see
Appendix F).  Historically, environmental costs from inadequate
hazardous waste disposal practices have tended to be borne by society
in general or by third parties rather than by the waste generators
whose disposal practices have caused damages; as a result, such costs
have not generally been included in the economic decision process.
Furthermore, the very limited data on the location and quantities of
wastes available for recycling and on the specific characteristics
of the diverse waste materials have tended to limit markets for waste
recycling (Office of Solid Waste, 1977b; Arthur D. Little, Inc.,
1976; Sittig, 1975).
                                 5-72

-------
      Development of technologies for the recovery and for the reuse




or recycling of waste materials have tended to lag behind the



development of technologies for utilizing virgin materials due to the




factors discussed above.  Technologies for recovering and reusing



many waste materials are still in a conceptual stage or have not been



commerically demonstrated (Versar, Inc., 1977; Arthur D. Little,



Inc., 1976; Sittig, 1975).



     Institution factors include the general lack of industrial,



institutional, and public acceptance or encouragement of resource



recovery practices.  For example, some generators hesitate to release



waste to others for recycling purposes for fear either of possible




injury to their reputation for quality or of legal liability for



incidents associated with the transfer (Arthur D. Little, Inc.,



1976).  Federal agency policies and standards have also tended to



discriminate against the use of recycled materials (Office of Solid



Waste, 1977b).  There have also been few formalized programs by



industry to encourage resource recovery, especially with regard to




potentially hazardous waste.  The National Ash Association, for




example, has a formalized program and has estimated that ash re-



cycling has risen to 20 percent from 12.3 percent in a recent 10-year



period (National Ash Association, 1977).
                               5-73

-------
6.0  QUANTITIES OF HAZARDOUS WASTES GENERATED AND CONTROLLED

     This chapter presents estimates of the quantities of hazardous

waste currently generated by both manufacturing and non-manufactur-

ing sectors, estimates of hazardous waste generation in 1980 and

1984, discussions of the magnitude of hazardous spills, and a discus-

sion of the amount of wastes currently under various aspects of state

control.

6.1  Current Hazardous Waste Generation

     Estimation of the amount of hazardous wastes which is currently

generated in the United States is complicated by a lack of comprehen-

sive data.  Data which are available are usually based on surveys

performed by many different groups with difference objectives who

consequently used varying definitions for hazardous wastes.

     6.1.1  Manufacturing Industries.  For the purpose of estimating

hazardous waste generation by the manufacturing industries at the

national level, data from the nine most consistent sources were used

to calculate generation factors for industry groups categorized by

the 2-digit SIC (Standard Industrial Classification) codes 20, 22-39.

The sources used represented data from eight states and one EPA

region:

     •  Illinois (Personal communication, S. Miller, Ohio Environ-
        mental Protection Agency, 1977)
        Kansas (State of Kansas, 1977)
        Maryland (State of Maryland, 1977 and 1977a)
        Massachusetts (Fennelly, et al., 1976)
        Minnesota (Battelle, Pacific Northwest, 1977)
        Mississippi (State of Mississippi, 1975)
                                 6-1

-------
     •  Texas (Personal communication, J. Carmichael, Texas
        Division of Solid Waste Management, 1977)
     •  Washington (State of Washington, 1974)
     •  EPA Region X (Stradley, et al., 1975)

     The generation factors were derived based on the assumption that

the ratio of the amount of hazardous wastes generated by an industry

to the number of employees in that industry is approximately constant

among all establishments in each industry (as grouped at the 2-digit

SIC code level).  The methodology used is presented in Appendix H,

along with a description of each data source and a discussion of the

assumptions and limitations.  As discussed in Appendix H, inaccura-

cies may have resulted from inconsistencies in data sources, possible

biases in the coverage of industries, errors introduced in the state

surveys, over-generalization of industry groups, and from variations

in actual hazardous waste generation per employee within industry

groups.  Nevertheless, it is felt that the computed generation fac-

tors represent the best presently available method of estimating the

total quantities of hazardous wastes generated by manufacturing

industries in the U.S.  The generation factors were used with U.S.

census data (U.S. Department of Commerce, 1977) to estimate the

amounts of hazardous wastes generated by each industry in each

EPA Region.  Table 6-1 summarizes the estimates by SIC code.

     Based on these estimates, the manufacturing industries generated

approximately 47.5 million metric tons of hazardous wastes during

1975.  Approximately 60 percent of this, or about 28.7 million metric

tons, was generated by industries in SIC code 28 (Chemicals and


                                 6-2

-------
                                                                TABLE  6-1

                                  SUMMARY OF HAZARDOUS WASTE  GENERATED BY EPA REGION — 1975*
                                                     (1000  metric tons per year)
CO

Standard Industrial Classification
20 Food and kindred products
22 Textile oil! products
23 Apparel and other textile products
24 Limber and wood producta
25 Furniture and fixtures
26 Paper and allied products
27 Printing and publishing
28 Chemicals and allied products
29 Petroleum and coal produces
30 Rubber and misc. plastics products
31 Leather and leather products
32 Stone, clay and glass products
33 Primary metal Industries
34 Fabricated metal products
35 Machinery, except electrical
36 Electric and electronic equipment
37 Tranaportatlan equipment
38 Instruments and related products
39 Misc. manufacturing Industries
TOTAL1'
Percent of Total
ENVIRONMENTAL PROTECTION AGENCY REGION
I
10
10
7.0
4.0
9.5
290
9.0
1.060
25
20
130
65
140
140
370
20
65
10
40
2.440
5
II
25
10
30
3.0
20
350
20
5.290
95
• 25
95
160
290
170
• 4SO
30
55
15
55
7.190
15
III
30
15
20
7.0
25
290
15
3,600
as
20
70
210
870
180
400
20
60
5.5
20
5,940
13
IV
45
100
40
20
75
530
15
5.920
50
35
90
• 230
350
180
420
25
80
4.0
35
8.240 .
17
V
70
3.5
10
10
50
760
30
5,770
160
75
120
350
1.520
700
1,830
55
350
IS
60
11,900
25
VI
30
2.5
10
8.0
15
200
8.0
3,270
330
15
35
120
190
150
350
10
60
2.0
15
4", 810
10
VII
25
0.5
4.0
2.5
7.5
120
8.5
1,230
45
10
85
60
110
85
290
9.0
60
2.0
10
2,170
5
VIII
9.0
<0.5
1.0
2.0
1.5
10
3.0
170
30
2.0
8.5
35
75
20
80
1.5
10
1.5
6.0
470
1
IX
35
2.0
10
8.5
25
180
10
1.880
110
20
10
130
200
160
400
25
150
8.0
20
3,380
7
X
15
0.5
1.0
20
2.5
130
2.5
460
20
2.0
1.5
30
95
25
60
1.0
45
1.5
5.0
920
2

Total
290
140
130
80
240
2,870
130
28,700
950
220
640
1.390
3.830
1.800
4,650
200
940
65
270
47,500


of Total
0.5
0.5
0.5
<0.5
0.5
6
0.5
60
2
0.5
1.5
3
8
4
10
0.5
2
<0.5
0.5



Ranking
10
15
16
18
12
4
17
1
7
13
9
6
3
5
2
14
8
19
11


             *Tbese numbers are estimated based upon the generation factors as derived in Appendix H.

             ^Totals may not balance due to rounding of numbers.

-------
 Allied  Products).   The next  largest  generators  were  industries  in  SIC

 codes 35  (Machinery,  except  Electrical),  33  (Primary Metal  Indus-

 tries), and  26 (Paper and  Allied  Products),  with  about  ten,  eight,

 and six percent  of  the total U.S.  generation, respectively.

     Also indicated in Table 6-1,  about  25 percent of the wastes are

 generated in the six  north-central states of EPA  Region V,  while the

'eight southeastern  states  of EPA  Region  IV account for  about 17 per-

 cent.   Application  of the  generation factors to individual  state

 employment indicates  that  seven states account  for approximately half

 of  the  total U.S. generation.   These states  are in alphabetical

 order:*  California,  Illinois,  New Jersey, New  York, Ohio,  Pennsyl-

 vania,  and Texas.   Following the  national pattern, most (46 to 83

 percent)  of  the  hazardous  wastes  generated in these  five states are

 produced  in  SIC  code  28, with  industries  in  SIC codes 35 and 33 rank-

 ing either second or  third.   These three  industry groups account for

 between 73 and 90 percent  of the  hazardous wastes" generated in each

 of  the  five  states.

     6.1.2  Other Potentially Hazardous Wastes.  In  addition to the

 manufacturing industries,  there are  numerous other sources  generating

 potentially  hazardous waste.  This section discusses various

 non-manufacturing waste categories that have been identified by

 previous  studies as containing potentially hazardous waste  and
 *Since  the  generation  factor  approach  relies  to a  large  extent on
  averaging  over large  areas,  its  accuracy decreases when applied to
  smaller  areas  such  as  states.  Therefore,  individual estimates of
  waste  generation are  not  presented  on a state-by-state  basis.

                                  6-4

-------
presents Che best available estimates on the quantity of potentially



hazardous waste generated within these waste categories.




     It should be recognized that there is a wide variation in the




degree of hazard associated with the waste categories discussed in



this section and that this variation exists both among and within the




different waste categories.  Data are incomplete with regard to both



the amount of waste generated within specific categories and the



protion of waste within each specific category that is associated



with any particular degree of hazard.  It is not meant to be implied




that all the waste generated within each category discussed would be



identified as a hazardous waste under Subtitle C, nor even that all




categories would contain any waste identified as hazardous under




Subtitle C.



     Categories of potentially hazardous waste from non-manufacturing



sources include non-industrial waste oils, hospital wastes,




agricultural wastes, household wastes, military wastes, fly ash, oil



well brines and muds, cement kiln dusts, dredge spoils, and phosphate



slimes.  Additionally, administrative and other governmental agencies



often engage in activities such as research and demonstration proj-



ects and pest control, which produce significant amounts of hazardous




wastes.



     Table 6-2 and the followng discussion present estimates of the



quantities of waste generated within each of the above categories



and, to the extent practical, estimates of the portion of the waste
                                6-5

-------
                                    TABLE 6-2

             ESTIMATED ANNUAL GENERATION OF NON-MANUFACTURING WASTES
               IDENTIFIED AS INCLUDING POTENTIALLY HAZARDOUS WASTE
      Waste
  Stream/Source
       Volume*
(million metric tons)
        Reference
Waste oils


Service stations


Hospitals




Pesticide containers

Households



U.S. Armed Forces

Coal ash - total

  Fly ash

  Bottom ash
  Boiler slag

Oil brines

Drilling muds


Cement kiln dust
Dredge spoils

  Corps of Engineers


  Other


Phosphate slimes

  Tailings and
   beneficiatlon
  Phosphoric acid
   production


Administrative/government
          2.5


          1.3


          .05t

          1-2 +


          .02 +

         10.5 +
                  i


     Not Avaiable

           54

           38

           12
            4

          1.9

          2.3


           13





      330-420


          210




           82


        20-27



     Not Available
Based on U.S. EPA, 1974
and U.S. D.O.C., 1977c

Battelle Columbus Labs,
1978

Battelle Columbus Labs,
1978;
Based on Singer et al.,
1973; and Kiefer, 1974

Trask, 1977

Based on person communica-
tion, Morris, OSW, 1977 and
U.S. D.O.C., 1977b.
Faber, 1976
OSWMP, 1977

Environmental Research Co.,
1978

Personal communication,
Portalnd Cement Aasoc., 1978
and U.S. EPA, 1973
Council of Environmental
Quality, 1975

American Society of Civil
Engineers, 1977
Personal communication,Palm,
G. F. Palm Assoc., 1978

Environmental Quality
Systems, 1976; and U.S.
EPA, 1974a
*Except as noted, it Is not yet known how much,  if any,  of the total quantity of
 each waste generated may in fact be hazardous vaste.   See text.
tlncludes only that portion of total waste estimated to be hazardous.
                                            6-6

-------
within each category that is potentially hazardous.  It should be



recognized, however, that the portion of waste actually meeting the



definition of hazardous waste under Subtitle C may be significantly




different.



     The primary sources of non-industrial waste oils are from the



transportation industry.  The U.S. Environmental Protection Agency




(1974) estimates indicate that about 56 percent of the automotive and




aviation oils sold in 1972 were not consumed and hence became waste



oils.  Applying this factor to the total U.S. 1975 automotive and




aviation oil sales (1.2 million gallons - U.S. Department of Com-



merce, 1977c) yields an estimated waste oil generation of 2.5 million



metric tons per year.  This is approximately twice the Battelle



Columbus Laboratories (1978) estimate of 1.3 million metric tons from




service stations alone.



     Battelle Columbus Laboratories (1978) estimates the annual 1977



hazardous waste generation from hospitals as 58,000 metric tons.  If




the rapidly increasing volumes of disposable items are included, this



number could reach 1 to 2 million metric tons (based on data from



Singer et al., 1973; Kiefer, 1974).



     The primary hazardous wastes associated with agricultural activ-



ities are used pesticide containers which still contain residual




amounts of pesticides.  Based on information compiled by Trask



(1977), approximately 98 million pesticide containers (mostly bags)



were used in 1971 by 2.5 million farmers.  The total container weight
                                 6-7

-------
(empty) was estimated at 20,000 metric tons.  Additionally, it was




estimated that 39 percent of the farmers using pesticides hired cus-



tom application services, and only 5 percent rinsed their containers.




Other estimates (Energy Resources Co., 1978) are that 25 to 40 mil-



lion small containers (made of glass, plastic, or metal) and 250,000




to 500,000 large containers (30 to 50 gallon steel drums) are used



annually.




     Based on an estimated hazardous waste generation of 7.5 pounds




per/household per year (Personal communication, M. Morris, Office of



Solid Waste, 1977) and 1975 Census data (U.S. Department of Commerce,



1977b), hazardous waste generation by individual households could




reach 10.5 million metric tons per year.  This figure may include



some of the waste automotive oils discussed above, plus various




cleaning fluids, caustics, pesticides, and miscellaneous chemicals.



     The amounts of hazardous wastes generated by the U.S. Armed



Forces is unknown.  However, the armed forces own and operate many of



their own supply and maintenance facilities, including munitions




plants, chemical production facilities, metal plating shops, and



foundries.  The military services maintain large stockpiles of muni-




tions which must be periodically replaced due to deterioration.




Additionally, the military services store large quantities of unused



and retrograde chemicals, primarily pesticides, which no longer have



valid registration for use or have deteriorated.  It can therefore be




expected that the amounts of hazardous wastes generated or stored by
                                 6-8

-------
Che military are large and may approach the amounts produced by all




the manufacturing industries combined.  Most of the services are




beginning to survey their hazardous waste generation as of the fall




of 1978.




     Estimates of the 1975 U.S. coal ash production are on the order




of 38 million metric tons of fly ash, 12 million metric tons of bot-




tom ash, and 4.2 million metric tons of boiler slag (Faber, 1976). Of




these amounts, about 8.9 million metric tons (16.3 percent) was uti-




lized in secondary products, primarily in the cement and concrete,




and in the manufacture of lightweight aggregates (Faber, 1976).  The




inclusion of many of the potentially toxic trace elements and other




constituents (e.g., complex organic compounds) originally contained




in the coal may result in the designation of at least some ash as




hazardous.




     The U.S. Army Corps of Engineers either conducted or contracted




for the dredging of between 310 and 390 million cubic yards (330 to




420 million metric tons) of bottom materials per year during the




period 1970 through 1975 (Council on Environmental Quality, 1975).




Of this, at least 24.8 million cubic yards (29 million metric tons)




was considered contaminated (U.S. Army Corps of Engineers, 1977).  An




additional estimated 200 million cubic yards (210 million metric




tons) are dredged annually by port authorities, municipalities, and




other government agencies (i.e., U.S. Navy and Coast Guard) (American




Society of Civil Engineers, 1977).
                                 6-9

-------
     Industry sources estimate that 120 million metric tons of




overburden and 82 million metric tons of tailings, clay, and mud ball




slimes (excluding overburden) are generated each year from phosphate




mining and beneficiation operations in Florida (the source of 78




percent of the phosphate rock mined in the U.S.) (Personal




communication, 6. Palm, Gordon F. Palm and Associates, 1978).  In




addition, estimates of the annual gypsum slime waste generation from




phosphoric acid production range from 20 million metric tons per year




(Environmental Quality Systems, Inc., 1976) to about 27 million




metric tons per year (U.S. Environmental Protection Agency, 1974a).




These wastes are generally radioactive, and contain fluorine and




trace contaminants.  The gypsum slimes from acid production also




exhibit very low pH.




     The amounts of hazardous wastes generated by non-military gov-




ernment agencies are not known.  Typical potentially hazardous wastes




generated by such agencies include unused pesticides, empty pesticide




containers, waste oils and solvents, paint sludges, petroleum wastes,




laboratory wastes, expired and unusable medicines, pathological and



infectious wastes, and other miscellaneous chemical wastes.  Bourns




et al. (1978) reported that non-military Federal agencies in Region




IX generate at least 5,000 metric tons/year (including 3,600 metric




tons of drilling muds), stating that the "quantities estimated prob-




ably are considerably less than those actually generated".




     The wastes discussed in this section do not represent all of the



potentially hazardous non-manufacturing wastes generated in this




                                 6-10

-------
country.  Other sources include mining operations;  construction com-




panies; dry cleaning plants; testing, research, and development labor-




atories; cleaning, disinfecting, and exterminating  services;




retailers and wholesalers of drugs, chemicals, paints, solvents, and




other products; marinas; and others.  Although data on generation




from these sources are sparse, it can be concluded  that the total




amounts of potentially hazardous wastes from non-manufacturing




industries are very large (on the order of several  hundred million




tons) and could greatly exceed the 50 million metric tons attributed




to the manufacturing industries.




6.2  Hazardous Waste Generators




     U.S. Census data indicate that there were 313,000 establishments




engaged in the manufacturing industries in 1972 (U.S. Department of




Commerce, 1976).  SIC codes 27 (Printing and Publishing) and 35




(Machinery, except Electrical) contained the largest number of




establishments with about 40,000 each.  SIC codes 24 (Lumber and Wood




Products) and 34 (Fabricated Metal Products.) accounted for 34,000 and




30,000 of the establishments, respectively.  SIC code 28 (Chemicals




and Allied Products), the largest generators, ranked tenth in the




number of establishments with 11,000.




     Figure 6-1 shows the cumulative size distribution of hazardous




waste genrators in the manufacturing industries.  The horizontal axis




represents the annual waste generation of a single establishment, and




the vertical axis represents the percentage of establishments which




generate more than that value.  Figure 6-2 shows the cumulative



                                6-11

-------
,
I I
I H-1
I N>

,*- 70|
81
M 	
| 60|
a 	
«_5Ql
ol 40 1
S[~~~
*l Snl
1 	 30|
20|
ra






,
V
V

r







*^,_
^ 	
* Percent
annual §








—
o'f all ma
eneratlon








• i
	 J
nufacturii
amount gj












ig establishments exceeding
Lven on horizontal axis.















































                             200
300
|400|
1500
! 600
700
800
| 900
110001
                                    HAZARDOUS WASTE GENERATION PER ESTABLISHMENT]

                                                 | (IIETRIC TONS/YR))
                                                                                         "I
                                                  FIGURE 6-1
                      CUMULATIVE SIZE DISTRIBUTION OF HAZARDOUS WASTE GENERATORS  1975

-------
 15
ICA
 M
 1001


_9PJ

LJOJ

  7Q\




~5Q|


740|

!Zlg|


r?o|
    101
   I  Pi
            ^'Percent of total hazardous wastes generated by all manufacturing establishments
              exceeding annual generation amount given on horizontal  axis.
      '61
             100
200
300
400
500
600
|700]     |800 J    |9pO
lOOOj
                              |HAZARDOUS WASTE GENERATION PER ESTABLISHMENT|
                                            [(METRIC TONS/YR)j
                                             FIGURE 6-2
                          CUMULATIVE HAZARDOUS WASTE DISTRIBUTION 1975

-------
percentage of the total amount of hazardous wastes generated as



function of firm size (i.e., the fraction of total wastes generated



by all establishments exceeding a particular annual generation




value).  These figures are plots of the output of the cycling option



of the phasing program as described in Appendix I.  They were based




on the generation factors developed in Appendix H and on the U.S.



manufacturing establishment size distribution data published by the




U.S. Department of Commerce (1976 and 1977).  Examination of the two



figures reveals that although less than three percent of the



manufacturing establishments generate more than 1,000 metric tons of




hazardous wastes per year, those establishments account for 78



percent of the total hazardous manufacturing wastes generated in the



U.S.  Similarly, the 25 percent of the establishments which generate




more than 25 metric tons per year are responsible for about 98



percent of the total hazardous wastes.  It should be noted that these



estimates are subject to several important assumptions, the implica-




tions of which are discussed in Appendices H and I.  Additionally,



they do not account for the relative hazardousness of different waste



streams.




6.3  Estimation of Future Hazardous Waste Generation



     1980 has been selected as the base year, and 1984 as the target



year for estimating the full impacts of implementation of the Sub-




title C regulations.  Estimates of the rate of increase of hazardous



waste generation were developed using data presented in the Industry
                                 6-14

-------
Studies (1975-1978) discussed in Chapter 5.*  The total increase in

hazardous waste generation projected by these studies between 1974

and 1983 is 42 percent, or about 3.6 percent per year.  Much of this

increase is attributed primarily to increased sludge volumes result-

ing from the more effective air and water pollution equipment being

brought on line in response to recent environmental legislation.

Many other factors also affect future hazardous waste generation, but

there are no reliable means of estimating their effects.  These fac-

tors include changes in manufacturing processes, increased use of

coal and synthetic fuels, and growth in manufacturing industries in

general.  Although different industries will be affected to different

degrees', the average rate of 3.6 percent per year has been applied to

all SIC groups in the absence of more complete data.  The resulting

estimated annual hazardous waste generation from manufacturing indus-

tries is about 57 million metric tons in 1980 and 65 million metric

tons in 1984.

6.4  Hazardous Spills  •

     Spills of hazardous materials need to be handled as hazardous

wastes regardless of whether the spilled material was originally a
*The Industry Studies (1975-1978) are a set of studies of hazardous
 waste generation in 13 major industrial segments.  They were per-
 formed by individual contractors using their own definitions for
 hazardous wastes.  As a result of the differences in definitions and
 the incomplete coverage of potential waste sources, these studies
 were not used in the development of the hazardous waste generation
 factors.  However, it was assumed that the rate of increase of haz-
 ardous waste generation projected by the studies was applicable to
 all hazardous manufacturing wastes as estimated using the generation
 factor approach.
                                6—15

-------
waste or a valued product.  In addition to the volume of material



spilled, a much larger volume of soil, water, and/or sorbent or other




cleanup material often also becomes contaminated.  In most cases,



such contaminated materials must also be considered and handled as



hazardous wastes.




     As discussed in Chapter 2, the responsiblity for documentation



of, and dealing with, hazardous spills is presently divided between




the U.S. Coast Guard (USCG), Department of Transportation (DOT), and




the Environmental Protection Agency (EPA).  All releases of hazardous




materials (as defined in 49 CFR 172) during the course of transporta-



tion must be reported to DOT's Hazardous Material Regulation Board.




All discharges of hazardous quantities of oil or hazardous substances



(as defined in 40 CFR 116 and 118) to navigable wastes must be



reported to the National or Regional Response Centers or to regional



offices of either EPA or USCG.  Spills of materials not meeting the




definitions cited above, and spills which are not related to trans-



portation and which do not threaten the broadly interpreted "naviga-




ble waters" are not presently subject to reporting requirements.



     Table 6-3 presents statistics on the spill incidents reported to



EPA during the one year period from February 1977 to February 1978.




Since the regulations listing hazardous wastes subject to reporting



requirements (40 CFR 116) were not promulgated until March 1978, the



non-oil wastes listed in the table were reported voluntarily.  Of the




75 cases presented, 39 are either exclusively oil spills or are oil
                                 6-16

-------
                 TABLE 6-3

EPA HAZARDOUS SUBSTANCES SPILL FILE SUMMARY
     (FEBRUARY 1977 - FEBRUARY 1978)*
wee ol
upoctad
Oeeurranca
} Fib 1977
3 Fib 1977
1 Fib 1977
3 Fib 1977
21 Mir 197!
21 lir 1971
21 «ar 197)
21 Bar 1977
29 KH 197)
30 Mir 197)
31 (Ur 197)
31 nr 197)
31 Mar 191)
1 Apr 1977
1 apr 1977
11 Apr 1977
11 Apr 1977
11 Apr 197)
11 Apr 1977
11 Apr 1977
22 Apr 197)
19 Apt 1977
10 Mar 1977
13 B»7 1977
13 Mar 1977
19 IB? 1977
19 Mar 1977
19 Kay 1977
3 Jon 1977
3 Jim 1977
6 Jim 1977
10 Jin 1977
24 Jim 1977
26 JIB 1977
21 Jim 1977
1 Jill 1977
3 Jul 1977
 2 oil
Oil
ou
Oil
ou
Sadlm aolflda
Cruda oil
Crudl oil
Anbrdroua uamu
Ethyl banini
n 6 oil
! atari, J Marl. 1.3.
dlnxollU, Mluaai.
xrlcna, aaEbylana
ehlarlda. hipciai. lia-
tmjl wiuu. Kweai,
•IHril tplrlei
Cndi oil
Oil ud chnluli
Oil "~* oollutlatl
lUpclu
Oil
n 6011
ra
Cnidi oil
OIUOCICT SpllUd
10,000 lloiii
2,000 Billons
114.000 gallon.
M6.000 MUon.
32.000 wUoii
131.100 Mllomt
39.000.000 « fct
210.000 (lUou
600.000 ullnu
ZS.ODO cani iludgi
3 5 com* (1.7 JO gll)
21.000 MllOU
20.510 (illou
OataM
20,000 iillnu
2,500 dnm
«2,000 flUou
2,000 lallani
2,000 lllloni
Onknon
Uoknovn
Uoknmn
3.1 too.
6,400-10.300 fallaaa
16.800 ullou
15.000 lllloni
Dakaoua
1,000 jiillou
Unknown
16,600 (lllou
9-10,000 vlloni oU
24-30.000 6>Uam
ehulcill
173.000 (.lloni
Cn»no«n
3,000 llllani
148.000-210.000 filloni
163 lallau
12.600 |>llou
UaEiruiy Spill
Uatimy
viunnjt
Uicirvir
WaEiruiy
UaEinnir
UiEinny
Vatiruir
Air
Vitinnjr
Uplmd
Upland
UEirvar
VaEinnr
Watinar
Alv
Ulcaiva;
tAiKirvay •
Vaunnr
WiEarvay
Uatlivir
Ulttrvar
•Ihunn; .
Itttiniir
UAanm
Uilaad
Uktanir.
HaEinny and air
Vatinny and air
VaEiniT
Uitarmj
UaEinar
VaEinaw
Oacanajr
Wacino;
UiEirvay
ViEirvaw
Upland
UaurMT
TTPI of Spill
Baria wnc aground
BeiElng pilot
6lrii iplll
Tanlar iplll
TuUr iplll
Tlnkir Mill
Caa wall blawuE
noldlns eiok • aiparator avitia
Lifaon onrllow
Sauaci traaEoaat dliehlria
Illlraad apUl
Flpallni braik
Flpallna braak
Illlraad iplll
lallraad aplll
-
Flpallni bnik
Barra iplll
Snip aplU
Unknown
Unknown
Unknown
(tepanr apUl
Canpanr apUl
ripallaa braak
lallroad ipUl
Unknown
larta iplll
Oiinleal eonpiny dliclurai
Flpallni bruk
Scorata tank ipUl
Uioon aplll
Coapany aplll
larta aplll
Barja iplll
Canpin7 aplll
Flpillni iplll
Gaotraphlc Ueatlon
Partb Anbar. *U
waihlnjton, B.C.
Suzxirdi bay, HA
•Urcua Book. PA
Atlantic Ocaan
CuumUll Bay. Fl
laulilana/Taxaa
Oriean. Ohio
Oavtp. NT
LoalivUla, ST
tocUnfhu, 1C
Vincuri Blvir. CO
Bartln Couadr. n
locklojhaa. 1C
SinCoid, KC
Dllmar, HO
WnlEi Oak, TZ
nuidilpbla, PA
San Pranclaeo, CA
Capo San Martin, CO
Dal. Say. U
la; UUI, FL
Sav Martlni»llli. VA
Vmtiiri CiuatT, CA
Grant Couaty. OK
•Ullllllppl
aaltloota, NO
Hlaalaalppl Unr
Unolr. IK
Croekatt. IT
lirninvUli. BC
Ualrcoa, uv
Akron. OB
Torktan, TA
Clleoilav, LA
Brookwooa, AL
Stuart. 01
                    6-17

-------
TABLE 6-3 (Concluded)
fata of
lepartad
Occur raaca
6 Jul 1977
6 Jul 1977
6 Jul 1977
7 Jul 1977
11 Jul 1977
20 Jul 1977
21 Jul 1977
21 Jul 1977
21 Jul 1977
16 Aut 1977
16 Au| 1977
faterlal Splllad
Acidic ferric chlorlao
Cnidl oil
Oil
Acryllc/ityreae
polyaar aaulaloa
Bydrobraadc acid
HalacUm
Oil
Tricing
Crude oil
Xylaaa
Laeez
aisBialua eulfeta;
piradlchla nibaueae .
•ethyl uetato propa-
Quantity Splllad
100 lalloal
62,000
11,000 ullona
210.000 gallon!
10,000 pnunda
110 lalloai
20,000 aellona
9,000 lalloaa
60,000 aalloai
Ualuuwn
Unkeova
Uplud or
Uacenuy Spill
Uncanny
Waterway
Type of Spill
Coapuy iplll
Pipeline iplll
Upland ud waterway Coapuy iplll
Waterway
Coapuy iplll
GeoBrapbic Lecacloa
Port Waablaiton, WI
Dpihur County, IX
Rainay Pirk, n
Dartooutb. HA
Upland lad waterway Tank truck ipill kockwood, TB
Upland
Uecerway
Uecemy
Wetervey
Waterway
Uecerway
Plue creah
DaturU flood
Ducleir poMr plant epill
Pipeline bruk
It,,, .pill
Railroad epill
Shericaa, VT
Johnecon. PA
Plctaburi, PA
Anahela, CA
Mil. 161, IA
Hovi, HA
cauatic liquid; diaacund
alcohol
22 An| 1977
21 Sap 1977
21 Sip 1977
11 Oct 1977
2 Bo* 1977
4 Bo* 1977
10 low 1977
11 Bo* 1977
1 Dec 1977
7 Dae 1977
9 Dae 1977
11 Die 1977
1 Ju 197B
10 Ju 1971
11 Ju 1971
11 Ju 1971
16 Ju 1971
16 Ju 1971
19 Ju 1971
19 Jm 1971
26 Jm 1971
26 Ju 1971
26 Ju 1971
26 Jn 1971
10 Ju 1971
11 Ju 1971
11 Ju 1971
011
Hathychlor Unduit
endrla
Aaaonlua alcrate
FCB ud oil
Crude oil
alhydroue mala
Aerylaalda
nydrotu paroalda
Acrylonlcrlte
luieaa trichloride,
ethyl acetate. nltroBu
IUI! PCB
Sulfurtrloatte
Geaollaa; n fual oil
Caul Lea
Crude oil
Tetrahydrotaraa
Crude oil
Hechyl echyl kacau.
•catena, cauatlc mdi
Acacaluahyde
Aliened chancel.
HR 2 oil
ulehlonhydrln
Oil
Atryloaltrila. IPO
BE 6 Oil
liquid oiyim
•U.S. an*traaaaaul Protection Aeancy.
tAiaumlai all 9.1 cu ft af |U and 104
tauualRg 1 cm • SOO ealloae.
UakaaaD
Uakaoua
Uacarway
Uaterway
Unknown
Unknown
Oakaoua Upland ud uateney Railroad aplll
Unknown
21.000-126,000 Mllone
1,000 lalloaa
Oakann
5,000-4.000 ullma
ftduiewe
1,000-20,000 ullaai
Unknown
Oakeown
Hi ,000 eallooa
LQ.OOO galloai
12,600 lalloai
100 lallonl/ar
12.000.000 aallona
20,000 |«ll°n.
14,000 lallnai
110,000,000 j.llona
11,000 ullnai
20,000 jallon.
50,000 gallon.
Unknown
Oakaoun
Unknown
mtenay
Wateraay
Uatamay
Upland, waterway •
aad air
Waterway and Ur
Uacarway aad air
waterway
Upland |
Uecarwa, .
Air I
Uacenay
Uacarway ud air
Upland
Uplud
Waterway '
Uacerway
Uacerway
Wicerwey
Coop.ny mill
Coapuy mill
Tank truck mill
Railroad iplll
Tuk truck mill
Railroad epill
Railroad iplll
Company .pill
Pipeline epill
Coapuy iplll
urea epill
Coapuy iplll
Coapuy .pill
Railroad iplll
Tuker epill
Railroad epill
Railroad iplll
Lateon ipill
Upland ud waterway Coepuy Iplll
Upland
Waterway
Air
Waterway
Air and waterway
Railroad mill
Barea ipill
Railroad iplll
Barea aplll
Coapuy opinion ud iplll
Oil aad Special Hiterlala Control Dlvlalon, 1978c.
harrela of coadeaaate produced par (lay aecaoa to the air md the vacer. runecclvely
Ociu City, n>
B. Niaal Batch. PL
Kaeneiav, Ga
PUladeliala, PA
baaai City, HO
Alizudrla, VA
Peaaacelt. tl
t*er|rau, AL
Vuc Vlralala
rrmkfert, R
lo|tn TewaaUp, HI
Du*illa. II
Balclaori, Ml
Long lelaad. NT
BercŁord, RC
Danavllle, HI
Ohrleh>*ille, ni
lau Piulo. Ira.il
Rileceed. AL
Pond Iddy, PA
Palcaaoula. HS
Dreadea. HI
Paint Pleaaut, UV
Galwaicoa, IX
Lara, R
Portmeuth, BU
Moundertlle, u»
for 6 dm
         6-18

-------
mixed with other hazardous substances.  Although oil-related spills




represent 52 percent of the total for the year, this figure may be




unrepresentative due to the lack of a definition and, therefore, of




specific reporting requirements for hazardous substances during that




period.  Data on volumes are presented to give some idea of the




quantities of materials spilled in individual incidents.  Calculation




of the total volume of material spilled during the period would be




unrealistic due to the number of estimated ranges that were given and




due to the number of incidents reported where the spill volume was




not even estimated.  For comparison purposes, however, the volumes of




reported spills range from 500 gallons to as much as 150 million




gallons, though only two spills exceed 1 million gallons and most




were less than 100 thousand gallons.  Most of the reported incidents




involved spills to a body of water; however, it must be kept in mind




that the reporting of upland spills (not directly involving or




threatening U.S. waters) is not mandatory.




     Tabl'e 6-4 shows all discharges recorded, by the USCG Pollution




Incident Reporting System (FIRS), primarily oil and hazardous dis-




charges reported to the National Resource Center, or other USGS and




EPA offices, but also includes releases subject to the Hazardous




Materials Transportation Act, and other spills reported voluntarily




or collected from other sources.  The PIRS file contains only those




discharges into, or which threaten, the waters of the United States.




Assuming a range of densities from six to ten pounds per gallon, the
                                  6-19

-------
                               TABLE 6-4
  TYPES OF DISCHARGES REPORTED FOR 1976 UNDER SECTION 311,  PL 92-500*


Crude oil
Fuel oil
Gasoline
Other distillate fuel oil
Solvent
Diesel oil
Asphalt or residual fuel
oil
Animal or vegetable oil
Waste oil
Other oil
Liquid chemical
Other pollutant (sewage,
dredge spoil, chemical
wastes, etc.)
Natural substance
Other material
Unknown material
Total
Number of
incidents
2,667
909
658
251
34
2,063
132
93
1,217
2,636
296
130
94
146 .
1.329
12,655
% of
total
21.1
7.2
5.2
2.0
0.3
16.3
1.0
0.7
9.6
20.8
2.3
1.0
0.7
. 1.2
10.5
100.0
Volume in
gallons
4,990,691
9,780,886
764,168
462,140
95,317
1,100,133
4,982,195
94,513
131,377
724,294
2,110,048
6,468,940
6,468
2,120,386
20,274
33,851,830
% of
total
14.7
28.9
2.3
1.4
0.3
3.2
14.7
0.3
0.4
2.1
6.2
19.1
0.0
6.3
0.1
100.0

*U.S. Department of Transportation, Coast Guard, 1977.
                                  6-20

-------
total weight of the spilled materials shown in the table amounts to




90 to 150 thousand metric tons.  Table 6-4 includes the 7.5 million




gallon spill of fuel oil by the Argo Merchant, which accounts for 22




percent of the total volume of discharges during the year.  Excluding




that single spill the largest category in terms of volume is "other




pollutant", including sewage, dredge spoil, and chemical wastes, with




6.5 million gallons (about 25 percent of the total volume excluding




the Argo Merchant spill).  Much of the volume of spills such as that




reported in this table cannot be recovered and therefore could not be




placed in RCRA-approved disposal facilities.  However, as discussed




above, in the cases in which removal of spills is possible, the




clean-up operations must usually remove a large volume of contami-




nated soil and water in addition to the original volume of spilled




material.  This volume would greatly increase the amount of material




requiring disposal in RCRA-approved facilities.




     Table 6-5 gives the distribution of spills by source category.




The largest category of spill sources was non-transportation related




facilities other than refineries, bulk storage, and production facil-




ities.  These sources were responsible for 29 percent of the total




spill volume and 90 percent of the total non-oil spill volume.




     Table 6-6 is included to illustrate the type of commodities




which were named most often in hazardous materials incident reports




as documented by the U.S. Department of Transportation for the period




from January 1, 1971 to December 31, 1975.  This list does not imply
                                 6-21

-------
                            TABLE 6-5

          SOURCES OF DISCHARGES REPORTED FOR 1976 UNDER
                     SECTION 311,"PL 92-500*


Vessels
Dry cargo ships
Dry cargo barges
Tank ships
Tank barges
Combatant vessels
Other vessels
Total
Land vehicles
Sail vehicles
Highway vehicles
Other/unknown vehicles
Total
Non-transportat ion-related
facilities
Onshore refinery
Onshore bulk/storage
Onshore production
Offshore production
facilities
Other facilities
Total
Pipelines
Marine facilities
Onshore/offshore bulk
Cargo transfer
Onshore/offshore fueling
Onshore/offshore nonbulk
Cargo transfer
Other transportation
Related marine facility
Total
Land facilities
Misc. /unknown
Total
Number of
incidents

41
324
623
976
179
1.153
3,296

82
335
47
464


101
365
242
1,358

1.055
3,131
653

321

88
23


128
560
182
4.379
12,655
% of
total

0.3
2.6
4.9
7.7
1.4
9.1
26.0

0.6
2.6
0.4
3.6


0.8
2.9
1.9
10.7

8.3
24.6
5.2

2.5

0.7
0.2


1.0
4.4
1.4
34.6
100.0
Volume in
gallons
,
11,679
24,840
8,930,029
. 1,953,442
26,987
245.013
11,191,990

269 ,440
323,391
- 20.968
613,799


211,614
5,873,932
349 ,053
274,732

9.759.869
16,469,200
4,530,094'

333,712

21,708
15,643


5.787
376,850
442,730
227.167
33,851,830
% of
total

0.0
0.1
26.4
5.8
0.1
0.7
33.1

0.8
1.0
0.1
1.9


0.8
17.4
1.0
0.8

28.8
48.0
13.4

1.0

0.1
0.0


0.0
1.1
1.3
0.7
100.0

*U.S. Department of transportation, Coast Guard, 1977.

                              6-22

-------
                             TABLE 6-6




COMMODITIES NAMED MOST OFTEN IN HAZARDOUS MATERIALS INCIDENT REPORTS *
Section 172.5 Commodity
Paint and paint related compounds
Gasoline
Batteries and electrolyte fluid
Compounds, cleaning, liquid (Cor.)
Sulfuric acid
Cement, liquid, n.o.s.
Flammable liquids, n.o.s.
Hydrochloric acid
Corrosive liquids, n.o.s.
Insecticides, liquid (Poison B)
L.P.G.
Poisonous liquids, n.o.s. (Poison B)
Ink
Alcohol, n.o.s.
Acids, liquids, n.o.s.
Caustic soda liquid
Nitric acid
Resid solution
Anhydrous ammonia
Compounds, tree or weed kill (Poison B)
Compounds, cleaning, liquid (FL)
Total
Total of All Reports Received
Number of
Reports
(1971-1975)
6,590
4,243
3,593
2,194
1,081
903
844
825
714
422
395
364
355
337
316
304
265
240
222
215
211
24,633
32,000
Approximate % of
All 32,000 Reports
Received
20%
1%
11
7
34
3
2*5
2%
2*
Us
Us
1
1
1
1
1
0 3/4
0 3/4
0 3/4
0 3/4
0 3/4
77
100

*U.S. Department of Transportation,
Materials Transportation
     Bureau,  1976
                                 6-23

-------
a ranking of risk or hazard to Che public.  For example, most of the



paint spills (comprising 20.5 percent of the total number of reports



recorded) were less than 5 gallon amounts, and most of the battery



acid spills (comprising 11 percent) were less than one quart amounts.




Many of the gasoline spills, however, (comprising 13.5 percent of the



total number of reports recorded) were of 100 gallons or more.  This




table is intended to show only which commodities were reported most




often.



6.5  Hazardous Wastes Under State Control



     As discussed in Chapter 2, existing state programs to control



hazardous waste range in scope from essentially non-existent to



highly comprehensive.  Due to the variability in the degree of con-




trol and the uncertainties in estimating individual state generation,




the amount of hazardous waste presently under state control cannot be



estimated with confidence.



     Table 6-7 shows, summarized from Chapter 2, the number of states



with selected legal mechanisms for allowing control of hazardous



wastes.  As discussed in Chapter 2, the existence of enabling author-



ity provides the state with the formalized power to control a speci-




fic activity, while standards and regulations provide specific



requirements that are to be met.  In most states that do not have



standards or regulations, the enabling authority is exercised on a




case-by-case basis.



     Table 6-8 shows the status of state control in the seven states



which are estimated to generate about 50 percent of the potentially



                                6-24

-------
I-J
                                              TABLE 6-7

                             SUMMARY -  STATE CONTROL OVER HAZARDOUS WASTES

Permit
P* St
Generators!
Transporters
Storer§
Treateri
Disposers§
14
23
25
25
38
7
10
9
9
17
Manifest
P* St
25
25
21
23
25
10
11
7
10
12
Recordkeeping
P* St
23
23
18
22
34
8
12
6
8
15
Reporting
P* St
23
19
17
20
29
9
8
5
6
13
Inspection
P* St
22
18
23
24
39
6
5
5
7
15
          *Number of  states with  provisional  authority.
          tNumber of  states with  regulatpry standards.
          fControl of generators  who  store, treat, or dispose hazardous waste  on-site.
          iApplies to off-site storage,  treatment, or disposal.

-------
                                                          TABLE 6-8

                                     HAZARDOUS WASTE CONTROL IN LARGE GENERATOR STATES*
                  State
                                                State Legislation Applicable to:
Generatorst    Transporters    Storers
                                                                              Treaters
                                                                                            Disposers
California


Illinois
                                 (S):M,Rp,Rc,I    (S):P,M,Rc,I   (S):F,H,Rp,    (S):P,M,Rp,    (S):P,M,Rp,Rc,I
                                 (P):P                              Re.I  '        Re,I
                                 (S):M,RP
                              (S):M,Rc,Rp   (S):M,Rc.Rp   (S):P,M,Rp.Rc,I
N>
                 New Jersey      (P):M.Rc,Rp      (P):M,Rc

                 New York
                                                          (P):P,M,Rc,Rp,I

                                            (P):P         (S):P
                                                          (P):Rc,Rp,I
Ohio
Pennsylvania
Texas
(S):P
(P):M
	
(S):M,Rc,Rp,I
(S):P
(P):M
	
(S):M,Rc
(P):Rp
(S):P
(P):M
	
(S):P,M,Rp,
Re, I

-------
hazardous manufacturing wastes in the U.S.  The trend is towards




manifest systems in these states, though only three of these seven




states are presently operating such a system under specific




regulation.  Additionally, two of these states have essentially no




control over activities other than disposal, and another has only




enabling authority with no specific standards.




     It should be emphasized that, as discussed in Chapter 2, both




the comprehensiveness of existing state standards and regulations,




and the degree to which they are enforced, vary widely from state to




state.  Furthermore, only 16 states presently have officially defined




hazardous wastes by either criteria or listings.  In summary, even




when considering the subjective nature of the data presented in




Tables 6-7 and 6-8, it may be concluded that at present, state




control of hazardous wastes is fragmented, and that, although some




states exert very good control, the potential for damage from




uncontrolled disposal of hazardous wastes is substantial, as shown by




the reported incidents summarized in Appendix J.
                                 6-27

-------
7.0  IMPACTS OF THE BASELINE ACTION



     This chapter addresses Che potential impacts, both beneficial



and adverse, that could result from implementation of the baseline




Subtitle C regulations.  Two major types of impacts are analyzed:




primary impacts and secondary impacts.  Primary impacts include those



effects that would be directly attributable to the implementation of



the baseline regulations.  Secondary impacts include those effects




that would be indirectly attributable to the implementation of the



baseline regulations.  In some cases, secondary impacts might not be




observed until years or even decades after implementation of the




regulations.



     Where practical, potential impacts are analyzed for two separate




years:  1980, the year of expected implementation of the regulations,




and 1984, the year by which the full effects of the regulations are



expected to become established.  For the reasons discussed in Section



7.1.2, it is anticipated that at least five years would be required




for such effects and resultant impacts to become fully established.



     The impact analysis is, for the most part, both generic in scope



and conducted on a national level due to the extreme waste-specific,




process-specific, and site-specific nature of most impacts, and due



to the extensive data limitations previously indicated.  Because most




available data relate to manufacturing industries, the emphasis of



the impact analysis is necessarily directed toward manufacturing
                               7-1

-------
industries.  To Che extent the limited available data allow, impacts



are assessed quantitatively.




     Over 300 reported incidents of damage from the improper manage-




ment of hazardous wastes were reviewed to assist in identifying the



potential for adverse impacts resulting from current hazardous waste




management practices.  Appendix J briefly describes each of these




reported incidents.  Table 7-1 summarizes the type and extent of the



adverse impacts that have been reported.  From the way in which most




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



majority of such incidents go unreported, especially human health



incidents which may require many years of exposure and for which




direct causative relationships are difficult to trace or establish.




The reported incidents indicate that there is often a considerable



time interval between the occurrence of those events which lead to




damage and the time when the damage becomes evident.  Since virtually



all of the reported incidents were discovered only after damage had



already occurred, there is, nationally, a very significant potential




for many similar damage incidents to be detected in the future from



wastes that have already been improperly stored, treated, or



disposed.




     It should be noted that a potentially large category of hazard-



ous wastes, termed 'special wastes,1 are only briefly addressed in



the impact analysis.  'Special wastes' include cement kiln dusts,




utility wastes, oil drilling muds/brines, phosphate rock mining and
                                7-2

-------
                                       TABLE 7-1

                    NUMBER AND TYPES OF REPORTED INCIDENTS FROM THE
                       IMPROPER MANAGEMENT OF HAZARDOUS WASTES*

Management
Method
Generation
Transport
Storage
Dumping
Landfill
Lagoon
Incineration
Resource
recovery
Other
treatment
TOTAL
Air
quality
impacts
1
6
5
5
1
4
2
2
5
31
Water
Duality
impact st
4
1
23
73
69
55
1
4
3
233
Soil
contami-
nation
-
-
2
4
3
2
-
-
1
12
Identifiable
public health
impacts
1
4
9
12
16
2

2
3
49
Drinking
water
contamination
-
1
9
25
27
19
1
2
-
84
Identifiable
biological
impacts
2
-
7
37
20
19
1
2
2
90

^Summary is based on approximately 300 reported incidents listed in Appendix J.
tIncludes drinking water contamination incidents.

-------
processing wastes, uranium mining wastes, and other mining wastes.

Any 'special wastes' identified as hazardous under the Subtitle C

regulations would be subject to a limited portion of the Subtitle C

storge, treatment, and disposal regulations (see Sections 7.1.2.3 and

7.1.2.4).  As a result, it is not likely that there would be any

significant change in the current storage, treatment, or disposal

practices for such wastes.  EPA is planning to promulgate Subtitle C

requirements specific to the management of 'special wastes'.  An

additional environmental impact statement or supplementary statement

would be prepared for these 'special wastes', if warranted, at such

time.

7.1  Potential Primary Impacts

     The potential primary impacts from implementation of the pro-

posed regulations are analyzed within the following areas:

     •  Hazardous wastes to be regulated;

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

     •  Administrative changes;

     •  Air impacts;

     •  Water impacts;

     «  Public health impacts.

     In discussing the primary impacts of the proposed regulations,

especially air, water, and public health implications, a limited

number of incidents are used to illustrate the potential benefits of

the regulations.  It should be noted that Appendix J contains many


                               7-4

-------
additional examples of adverse incidents that have occurred under


present hazardous waste management practices.


     7.1.1  Hazardous Wastes to be Regulated.  The Section 3001 regu-


lations (see Appendix B, Subpart A) define the wastes that are to be


considered hazardous and, thus, subject to the Subtitle C regula-


tions. Two mechanisms are provided for determining those wastes that


are hazardous:  identifying characteristics and lists of specific


hazardous wastes and waste streams.  The identifying characteristics


are ignitability, corrosivity, reactivity, and toxicity.  Wastes


which exhibit any of these characteristics, or which are listed,


would be considered hazardous and would have to be managed pursuant


to the Subtitle C regulations.


     Chapter 6 contains estimates of potentially hazardous waste gen-


eration within manufacturing and non-manufacturing industries.  The


estimates for the manufacturing industries have been determined using


the generation factors described in Appendix H; the estimates for the


non-manufacturing industries have been developed as described in


Chapter 6.  The quantity of wastes that would be identified as hazar-

                                                               /
dous under the Section 3001 regulations would, however, be less than


the quantities indicated as hazardous in Chapter 6 due to the pro-


posed definition of the Section 3001 toxicity characteristic.  The


toxicity characteristic is to be based solely upon the EPA Primary


Drinking Water Standards and, as a result, many wastes that are po-


tentially hazardous due to other indicators of toxicity, especially
                               7-5

-------
organic wastes, would presently be excluded from regulations.*

However, many other such wastes are specifically included on the

lists of hazardous wastes and, thus, would be subject to the Subtitle

C regulations.

     It is expected that the primary effect of the present toxicity

characteristic on manufacturing wastes would be to eliminate from

regulation a large portion of the potentially hazardous wastes pre-

viously estimated to be generated by industries within SIC Code 28

(Chemicals and Allied Products).  EPA staff estimates are that about

35 percent of the potentially hazardous wastes previously estimated

to be generated within SIC Code 28 could be identified as hazardous

under the Subtitle C regulations.  It is therefore estimated, based

upon Chapter 6, that approximately 35 million metric tons of manu-

facturing wastes could be identified as hazardous under the Section

3001 regulations in 1980, and that approximately 40 million metric

tons could be identified as hazardous in 1984.  The distribution of

these regulated wastes among the manufacturing SIC Codes and EPA

Regions would be essentially that shown in Table 6-1, except that the

wastes in SIC Code 28 would be reduced by 65 percent.
*EPA is considering expanding the toxicity characteristic to bring a
 greater number of these potentially hazardous wastes under the
 regulations in the future and would prepare an additional environ-
 mental impact statement or supplementary statement for the expanded
 toxicity characteristic, if warranted, at such time.  Specific
 revisions are not known at this time.  The "enhanced public health
 and environmental protection alternative" assessed in Chapter 8
 does, however, include an expanded toxicity characteristic.
                                7-6

-------
     Only chose persons or Federal agencies who produce and dispose



of more Chan 100 kilograms (abouC 220 pounds) per monCh of wastes



identified as hazardous under Che Section 3001 regulacions would be




considered generators subject to the Subtitle C regulations.  As



shown in Table 7-2, this generator limit of 100 kilograms per month




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



turing wastes from regulation.  The excluded waste would be less than



0.1 percent of Che total hazardous manufacturing wastes.  However,



about 26 percent of manufacturing establishments generating hazardous



wastes could be excluded.



     For purposes of comparison, almost 350 million metric tons of



total manufacturing wastes (hazardous and non-hazardous) are estimat-



ed by EPA to be generated annually.  Thus, over 10 percent of the



total manufacturing wastes would be regulated as hazardous wastes.



Over 60 percent of the manufacturing wastes idenCified as potentially



hazardous in Chapter 6 would be regulated.



     In addition to manufacturing wastes, the identifying character-



istics and the lists would identify other wastes as hazardous.  Sev-




eral large volume, non-manufacturing waste streams are specifically



listed as being hazardous.  The listed waste streams include uranium



mining wastes, phosphate mining and processing wastes, and pesticide




containers that have not been triple rinsed.  As discussed in Chapter



6, phosphate mining and processing wastes amount to about 220 million



tons annually (however, as discussed in Section 7.1.2, these wastes
                                7-7

-------
                                               TABLE 7-2

                         ESTIMATED QUANTITY OF HAZARDOUS MANUFACTURING WASTES
                             AND NUMBER OF ESTABLISHMENTS EXCLUDED FROM
                            REGULATION AT A GENERATOR LIMIT OF 100 KG/MO
00




EPA Region
I
II
III
IV
V
VI
VII
VIII
IX
X

National
total
Number of
manufacturing
establishments
excluded
5,270
13,200
7,180
14,900
14,200
7,090
3,760
2,110
9,750
3,820


81,420
Percent of total
manufacturing
establishments
excluded
23
25
25
33
21
. 29
26
33
26
34
i

26
Hazardous
manufacturing
wastes excluded
(metric tons)
1,900
4,100
2,700
5,500
5,000
2,700
1,500
900
3,500
1,500


29,300
Percent of total
hazardous
manufacturing
wastes excluded
< 0.1
< 0.1
< 0.1
< 0.1
< 0.1
< 0.1
< 0.1
< 0.2
< 0.2
< 0.2


< 0.1

-------
would be subject to a limited portion of the Subtitle C storage,




treatment, and disposal regulations).




     Waste pesticide containers from persons engaged principally in



farming or solely in retail trade would not be subject to the



Subtitle C regulations.  This exclusion, coupled with the unknown




portion of waste pesticide containers already included in the



estimates of manufacturing wastes, precludes any determination of the




quantity of waste pesticide containers that would be subject to the



regulations.  The remainder would, however, be subject to the



requirements of the Federal Insecticide, Fungicide, and Rodenticide



Act of 1972, as amended.




     The identifying characteristics could result in the regulation



of such other large volume wastes as waste automotive oil, coal ash,




oil drilling muds and brines, cement kiln dusts, and dredge spoils.




Estimates of the annual production of these wastes are presented in



Chapter 6.  The portion of such wastes that could be identified as



hazardous by the characteristics is not known.




     7.1.2  Changes to Existing Generation, Transport, Storage,



Treatment, and Disposal Practices and Procedures.  Typical practices



and procedures used by generators, transporters, storers, treaters,




and disposers of hazardous wastes are discussed in Chapter 5.  The



Subtitle C regulations would lead to a number of major changes in



these existing practices and procedures.  The changes would primarily
                                  7-9

-------
be caused by the enactment of more stringent environmental require-




ments than those that currently exist, resultant increases in treat-




ment and disposal costs, and specific procedural and operational




requirements imposed by the regulations.  The intent of this section




is to indicate the scope of applicability of the Subtitle C regula-




tions and the major changes likely to occur in existing practices and




procedures as a result of the promulgation of the regulations.




     It is anticipated that at least five years would be required for




the changes in existing practices and procedures to become fully




established.  Several years would be required for hazardous waste




generators to become fully aware of the specific economic implica-




tions of the regulations, to assess the alternatives available to




them (e.g., process modification, increased recycling of hazardous




wastes, shifts in on-site and off-site treatment/disposal practices),




and to implement any changes.  Due to resource constraints, several




years would also be required for EPA or authorized states to act upon




all permit applications and to issue permits to acceptable storage,




treatment, and disposal facilities.  Facilities requiring modifica-




tions as a condition of their permits would then have up to three




years to complete such modifications.  Furthermore, the necessary




integration and coordination of RCRA requirements with those of other




acts (e.g., Federal Water Pollution Control Act and Safe Drinking
                                 7-10

-------
Water Act) requires that there be some delay in permit issuance.  For



example, in those instances where a treater or disposer has a Nation-




al Pollution Discharge Elimination System (NPDES) permit, issuance of



the RCRA permit would be delayed until the time that the NPDES permit




is to be renewed.  In addition, since very few states would currently




be qualified to attain full authorization, regulatory requirements in



those states granted interim authorization would be changed over



several years as the states become qualified for full authorization.



     7.1.2.1  Generation.  The regulations applicable to generators




(Section 3002 of Subtitle C) apply only to those persons or Federal




agencies, except households, who produce and dispose of more than 100




kilograms (about 220 pounds) per month of wastes identified as haz-



ardous under the Section 3001 regulations.  Any person or Federal



agency producing and disposing of 100 kilograms or less per month



would not be required to comply with the generator regulations.  Also




any generator engaged solely in retail trade or principally in farm-



ing would have to comply with the regulations only with regard to



waste automotive oil. However, any person may assume the generator's



total liability for compliance with the Subtitle C requirements with




regard to waste automotive oil.  Generators excluded from compliance



with the Subtitle C regulations would, however, still be obligated to



dispose of their hazardous wastes in an acceptable manner, e.g., in a




landfill that meets RCRA Subtitle D criteria.



     The Subtitle C regulations would result in procedural changes,



as described below, in the methods used by these regulated generators





                                7-11

-------
for tracking and reporting hazardous waste shipments and for prepar-

ing such shipments for transport.  The regulations could also lead to

process changes that would allow increased resource conservation

and/or recovery of hazardous wastes.

     Manifest.  Under the Subtitle C regulations, every generator

would be required to provide a manifest for each off-site hazardous

waste shipment—intrastate, interstate, and international—sent to a

facility not owned by the generator and to file reports and keep

records on such shipments.  Generators designating hazardous waste to

an off-site facility owned by the generator and located in the same

state as the generator would have to provide a manifest, but would

not have to comply with the reporting or recordkeeping requirements

(although the facility itself would be subject to reporting and

recordkeeping requirements under Section 3004); shipments to

generator-owned facilities in other states would have to comply with

the reporting and recordkeeping requirements.  On-site shipments

would not have to be manifested, but would have to be sent to

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

appropriate Federal or state authorities.*  Appendix B, Subpart B

describes the required content of the manifest and reports.  The

major purposes of the manifest would be to ensure that off-site

shipments of hazardous wastes are sent only to permitted storage,

treatment, or disposal facilities and to ensure that all such wastes
*0ff-site as used throughout this statement means any facility or
 location not on a generator's property.  On-site means any facility
 or location on a generator's property.


                                 7-12

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are actually delivered to the facility to which they are seat



(Appendix J describes numerous incidents from the indiscriminate



dumping of wastes in transit).




     Currently, there are very limited mechanisms for tracking of




hazardous wastes.  Based upon Tables 2-2 and 2-3, as of 1978 only 10



states have (or have proposed) standards for manifesting of hazardous




wastes by generators and only two other states have standards for



manifesting by transporters; an additional 14 states have (or have



proposed) enabling authority to enforce manifest requirements, but do




not have standards.  Nine states have (or have proposed) reporting



standards applicable to generators; 15 others have (or have proposed)



enabling authority for enforcing reporting by generators.  In addi-




tion, for the small portion of hazardous wastes that meet the Depart-




ment of Transportation (DOT) criteria of a hazardous material under



the Hazardous Materials Transportation Act (49 CFR 100-189), any in-




terstate or international'shipment of such wastes by common or con-



tract carriers must be accompanied by shipping papers prepared and



signed by the consignor (generator).  In addition, over 30 states




have adopted, with or without modification, the DOT Hazardous Materi-



al Regulations and apply them to intrastate shipments by common and




contract carriers.



     Due to these limited tracking mechanisms, generators, state



authorities, and Federal authorities, have little or no information



as to what currently happens to a large portion of the hazardous



wastes that are shipped off the generator's site; state and Federal





                                 7-13

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authorities also have little or no information about what happens to



a considerable amount of the wastes that remain on the generator's



site for treatment or disposal.  Furthermore, in states which do not




have manifesting or reporting requirements, the ultimate fate of the




wastes is not known for a very large portion of the wastes; for ex-




ample, in Kansas the disposal location is not known for almost 80



percent of the industrial wastes generated in the state and  in




Massachusetts the disposal location is not known for about 65 percent



of the industrial wastes (see Table 5-14).  Even in those states with




manifest and reporting standards, the disposal location is not always



known; for example, in Texas, the fate of about 20 percent of the




hazardous wastes is not known.



     To remedy this, the Subtitle C regulations would make the gen-



erator responsible for determining where his hazardous wastes are to



be delivered when sent off-site and for identifying those shipments




that may not have been delivered to the designated destination.  The



manifest (or the equivalent delivery document) would have to be



signed by authorized representatives of the generator, the trans-




porter, and the designated delivery facility; after the waste is de-




livered to the designated treatment, storage, or disposal facility,



the signed original of the manifest (or equivalent delivery document)




would have to be returned to the generator to verify that the waste



has been delivered.  Generators would have to file quarterly reports



on all manifested shipments for which a signed manifest copy (or



equivalent delivery document) is not returned.  In addition,




                                 7-14

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generators designating wastes for off-site shipment would be required



to file annual reports based on the information in the manifests and



to keep a copy of each manifest for a period of three years.  Genera-




tors who designate hazardous wastes for on-site treatment, storage,



or disposal would also have to file annual reports identifying the




types and quantities of wastes managed on-site.



     Containerization and Labeling.  Under the Subtitle C regula-




tions, the generator would also be required to containerize all




wastes for transport in accordance with the DOT regulations on pack-




aging under 49 CFR 173, 178, and 179.  If no specific packaging is



required, the generator would have to place the hazardous wastes in a




package in accordance with the DOT regulations on standard require-




ments for all packages (49 CFR 173.24(a), (b), and (c)(2)-(9)).  In



addition, the generator would have to label and placard each shipment




in accordance with DOT regulations on hazardous materials (49 CFR




172) and mark each package in accordance with DOT regulations on



marking (49 CFR 172.300) or with the EPA hazardous waste name (see




Appendix B, Subpart A, 250.14), as applicable.  Each package must



also contain the manifest document number and the generator's



identification number.



     The DOT regulations cited above currently apply only to inter-



state or foreign shipments by common or contract carriers or to




intrastate shipments by common or contract carriers in those states



which have adopted the DOT regulations.  The Subtitle C regulations




would extend these DOT regulations to all hazardous waste shipments.





                                 7-15

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     Process Changes to Promote Resource Conservation and Recovery.
In addition to these procedural changes, the Subtitle C regulations
would have the potential to cause generators to modify processes that
generate hazardous wastes in order to increase resource conservation
and recovery.  Since one major result of the regulations would be to
increase generator's costs and those costs associated with hazardous
waste transportation, storage, treatment, and disposal, generators
would potentially have an incentive to modify processes so as to
reduce and/or change the types and amounts of hazardous wastes gen-
erated by such processes and to enable the increased recycling of
hazardous wastes as process feedstocks.  According to a recent study
on hazardous waste management, (Foster D. Snell, Inc., 1976), there
is currently a trend in hazardous waste producing industries to
recover, reuse, or recycle waste products that were once either
treated or dumped; the primary reasons being economics and public
relations.
     As discussed in Section 5.4, the potential for process modifi-
cations to promote resource conservation and/or recovery would be
extremely waste stream and process specific and would depend upon
such factors as the economics of disposal, treatment, and transport;
the cost of raw materials and energy; the availability of markets for
and sources of recyclable hazardous wastes; and the availability both
of the necessary technology for specific resource conservation or
recovery applications and of environmentally adequate disposal meth-
ods.  Due to the many complex interrelationships among these factors,
                                  7-16

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the determination of specific process modifications and resultant
changes to waste streams that could occur as a result of promulgation
of the Subtitle C regulations is beyond the scope of the EIS.
     7.1.2.2  Transport.  The regulations applicable to transporters
(Section 3003 of Subtitle C) apply to any person or Federal agency
transporting, within the United States, hazardous wastes that require
a manifest under the generator regulations and also apply to any
transporter importing a shipment of hazardous wastes from abroad.
The transporter regulations do not apply to persons or Federal agen-
cies transporting hazardous wastes solely on the site of generation
or solely on the site of a permitted hazardous waste management
facility.  While the transporter regulations do not apply to hazar-
dous waste shipments not requiring manifests, if any person or Fed-
eral agency consolidates for shipment and transports any quantity of
unmanifested hazardous wastes from more than one source, the entire
shipment would have to be delivered to a permitted facility and would
have to comply (for both interstate and intrastate shipments) with  .
applicable DOT Hazardous Materials Regulations (49 CFR 100-189)
concerning shipping papers, labeling, marking, placarding, and trans-
portation.  Data are not available to estimate the number of trans-
porters that would be affected by the tranporter regulations (see
Appendix E).
     As discussed below, the Subtitle C regulations would signifi-
cantly curtail the 'midnight dumping1 of hazardous wastes and would
likely result in changes in the handling of transportation-related
                                  7-17

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spills, in the distances over which hazardous wastes are transported,


and in existing operational procedures and practices used for the


transport of hazardous wastes.


      Midnight Dumping.  There are numerous reported instances of


hazardous waste transporters dumping wastes surreptitiously rather


than delivering the wastes to an environmentally acceptable storage,


treatment, or disposal facility (see Appendix J).  Because such il-


legal disposal often occurs at night, this practice has been termed


midnight dumping.  Data are not available to quantify the total num-


ber of  such incidents, nor the amount of wastes disposed annually


through midnight dumping; however, the following example illustrates


the potential magnitude of the problem.  New Jersey shut down its


last legal land disposal site to chemical waste dumping nearly three


years ago.  The site was handling about one million gallons of chemi-


cal wastes per week when it was eliminated.  At this time it is not


known where most of the wastes that formerly went to such landfills


are currently being disposed, but there are reported incidents of


illegal disposal throughout New Jersey (Richards, 1978).


     The manifest and reporting requirements discussed in Section


7.1.2.1 should significantly reduce, if not eliminate, the practice


of midnight dumping.  These requirements effectively transfer the


opportunity for midnight dumping from the transporter to the genera-


tor and, to a lesser degree, to the receiving facility.  To the ex-


tent that generators manifest all off-site hazardous waste shipments
                                                                   /

and truthfully indicate the type and quantity of hazardous waste

                                  7-18

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being transported, midnight dumping should be nearly eliminated, pro-
viding the receiving facility accurately confirms the contents of
wastes delivered.
      Spills.  Section 2.3 indicates existing laws for the reporting,
prevention, and containment of transportation-related spills of haz-
ardous substances.  Only those hazardous wastes and other spilled
materials which meet the definitions and criteria for hazardous
materials under the DOT Hazardous Materials Transportation Regula-
tions or which are specifically listed under Section 311 of the
Federal Water Pollution Control Act as amended would come under these
existing spill regulations.  The Hazardous Materials Transportation
Regulations require reporting, but not clean up or containment, of
transportation-related spills of hazardous materials.  These require-
ments, however, apply only to interstate commerce or to intrastate
shipments in those states which have adopted the Hazardous Materials
Transportation Regulations.
     Section 311 of the Federal Water Pollution Control Act. applies
only to spills of the listed substances which threaten navigable
waters and which are into or upon the navigable waters of the U.S.,
adjoining shorelines, contiguous zones, or which may affect appli-
cable natural resources.  Section 311 requires the reporting and
clean-up of such spills by the responsible party.
     The Subtitle C regulations extend reporting and clean-up re-
quirements to all transportation-related spills of hazardous wastes
or hazardous materials which become hazardous wastes under Section
                                  7-19

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3001 when spilled.  In the case of a spill, transporters would have
to immediately telephone either the National Response Center (U.S.
Coast Guard) or the government official predesignated an the on-
scene coordinator, pursuant to 40 CFR 1510; a written report would
have to be filed within 15 days with the DOT Office of Hazardous
Materials Operations.  The transporter would also have to clean up
all spilled hazardous waste or take such action as may be required by
Federal, state, or local agencies so as to ensure that the spilled
waste no longer presents a hazard to human health or the environment.
     Transport Distances.  The average distance over which hazardous
wastes are transported would likely increase as a result of the Sub-
title C regulations.  This increase would result from several
factors.  First, the portion of wastes being shipped to off-site
facilities for treatment and disposal, rather than remaining at
on-site facilities, would most likely increase as discussed in
Section 7.1.2.4.  Second, all hazardous wastes would have to be
transported to permitted facilities, not just to any nearby disposal
site.  Since it would not likely be economically or environmentally
practical to site permitted facilities near every generator, the
average distance wastes would have to be transported should increase.
Third, increases in disposal costs resulting from the proposed regu-
lations should increase the distance over which waste may be economi-
cally transported for resource recovery purposes.
     According to a recent hazardous waste transport study (Arthur D.
Little, Inc., 1978a), most hazardous waste transport is by truck with
                                  7-20

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typical off-site transport distances ranging from 25 to 150 miles;


most of the surveyed firms reported transport distances of about 50


miles.  However, based on the limited number of firms replying to


the survey, the study concluded that the reported truck transport


distances might not be representative of the industry as a whole.


Host hazardous wastes transported by rail or barge are reported to go


to reclamation or resource recovery facilities; transport distances

               ^
on-the-order of 1,000 or more miles are common for such shipments.


Data are not available to determine by how much typical transport


distances are likely to increase as a result of the Subtitle C


regulations.


     Existing Practices and Procedures.  The Subtitle C regulations


would modify existing practices that have in the past led to re-


leases of hazardous wastes during transport and would impose addi-


tional procedural requirements on transporters to enable easier


identification of both the transporter and the wastes being trans-


ported.  For example, the regulations require that the transporter


not accept shipments of hazardous wastes unless such shipments are


accompanied by a manifest signed by the generator and are in con-


tainers which are not leaking or damaged and which are properly


labeled and marked.  In addition, the transporter (and any other


subsequent transporter(s)) is to sign the manifest; insure that the


manifest (or equivalent delivery document) accompanies the shipment


at all times; placard and mark the transport vehicle; deliver the


entire quantity of hazardous wastes to permitted facilities; and keep



                                7-21

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a copy of the manifest (or delivery document) for at least 3 years.


If the transporter consolidates or mixes hazardous wastes from


different generators or seoarate wastes from the same generator, the


transporter would also have to comply with the generator regulations


if the consolidated mixture was no longer adequately identified by


the manifest.


     Not all of the above requirements represent entirely new re-


quirements on all transporters.  For example, as discussed in


Appendix E, most transporters presently keep delivery documents for


at least 3 years due to various Federal and state regulations.  In


addition, common and contract carriers engaged in the interstate


transport of hazardous materials, as defined in the DOT Hazardous


Materials Transportation Regulations, have to comply with equivalent
                          •

placarding requirements and are not to accept shipments of hazardous


materials unless accompanied by shipping papers signed by the con-


signor (generator).


     7.1.2.3  Storage.  RCRA defines storage as the containment of


hazardous wastes, either on a temporary basis or for a period of


years, in such a manner as not to constitute disposal.  The regula-


tions applicable to storers (Section 3004 of Subtitle C) apply,


except as noted below, to all storage at off-site storage, treatment,


or disposal facilities and to all on-site storage by generators prior


to on-site treatment or disposal; the regulations do not apply to on-


site storage by generators who store their own wastes for less than


90 days prior to subsequent transport off-site, but do apply to any

                                   7-22

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such on-site storage which lasts for 90 days or longer.  Facilities




specifically excluded from complying with the storage regulations



include Publicly Owned Treatment Works (POTW) and ocean dumping



barges and vessels.  In addition, facilities that store only 'special



wastes', and no other hazardous waste, would have to comply only with



the General Facility Standards (e.g., manifest system, recordkeeping,




reporting—see Appendix B, Subpart D, 250.43) and not with any other



storage regulations.  All regulated facilities would require permits



under Section 3005 of Subtitle C.  Section 7.1.3.5 contains estimates




of the number of potential permittees.  Data are not available to



estimate the quantities of wastes that would be affected by the



storage regulations.




     As discussed below, the Subtitle C regulations would result in




the elimination of current storage practices that lead to or become a



form of disposal and would result in changes in the current design



and operation of storage facilities.



     Indefinite Storage.  Currently there are few regulations, if




any, that limit the time that hazardous waste may be left in storage.



As a result, there are a number of reported incidents of hazardous



waste being placed in storage for indefinite periods of time,




sometimes in very large quantities (see Appendix J).  In many such



instances, the wastes in storage are ultimately abandoned, rather



than being disposed in an acceptable manner, and are left to enter



the environment.
                                 7-23

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Even when the wastes are not abandoned, overly long storage times

have resulted in weathering and/or corrosion of containers and

weathering of storage piles, causing the eventual release of the

stored wastes into the environment.

     The Subtitle C regulations contain provisions that would

eliminate the indefinite storage of hazardous wastes.   At facility

close-out*, all hazardous wastes would have to be removed from all

storage and treatment operations, including surface impoundments that

do not meet the Subtitle C criteria for landfills, and would have to

be disposed as required by the regulations (see Section 7.1.2.4).

Facilities would have to post a bond that would be held until the

completion of both closure and post close-out care to ensure com-

pliance, t

     Facility Design and Operation.  The Subtitle C regulations would

prohibit or restrict existing storage practices that result either in

the discharge of hazardous wastes or in the storage of such wastes in

an environmentally unacceptable manner.  For example,  the regula-

tions require that storage operations be conducted in such a manner

that no discharge occurs and such that storage facilities be moni-

tored and inspected for the purpose of detecting any potential
*Close-out is the point in time at which facilities stop accepting
 hazardous waste for treatment, storage, or disposal.
tClosure is the series of actions to be completed within 3 years
 following close-out during which a facility is to be secured
 pursuant to Subtitle C regulations.  Post close-out is the period
 which need not exceed 20 years following closure during which
 required monitoring and maintenance activities are to be conducted.
                                  7-24

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discharge; Chat all storage areas be constructed so as to be capable

of containing any run-off or spills that occur, plus have sufficient

freeboard to allow for collection and containment of precipitation;

that storage areas be constructed of materials that are compatible

with the wastes to be contained; that incompatible wastes (see

Appendix D, Subpart D, Annex 4 for examples) not be mixed together;

and that facilities not be located on or near active fault zones or

in areas where they could be inundated by a 500-year flood.  As indi-

cated by the reported incidences listed in Appendix J, such regula-

tions would necessitate many changes both in the design and in the

operation of hazardous waste storage facilities.  Data are not avail-

able to estimate the number of facilities that would be affected, nor

to determine the specific changes that would be required for most

such facilities.

     7.1.2.4  Treatment/Disposal.  With the few specific exclusions

noted below, the regulations applicable to treaters and disposers
                                  i
(Section 3004 of Subtitle C) apply to owners and operators of any

facility that treats and/or disposes any quantity of any waste

identified as hazardous under the Section 3001 regulations (Appendix

B, Subpart A), except those wastes listed as 'special wastes'.  All

owners and operators of facilities that treat and/or dispose of

'special wastes', and no other hazardous waste, would have to comply

only with selected General Facility Standards of the treatment and

disposal regulations (see Appendix B, Subpart D, 250.43).
                                 7-25

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      Certain disposal practices that are controlled under other



Federal acts are not regulated under the treatment and disposal




regulations of Subtitle C.  These practices include underground




(deep-well) injection, ocean dumping, discharges to municipal sewer




systems, surfaces discharges under a National Pollution Discharge




Elimination System (NPDES) permit, and all treatment and disposal




activities at Publicly Owned Treatment Works (POTW).  However, the




treatment and disposal regulations would apply to above ground stor-




age or treatment of hazardous wastes prior to underground injection,




on-shore facilities associated with ocean dumping activities, and




surface impoundments associated with NPDES permitted industrial




wastewater treatment facilities and hazardous sludges from such




facilities.  All facilities regulated would require permits under




Section 3005 of Subtitle C.  Section 7.1.3.5 contains estimates of




the number of potential permittees under the Subtitle C regulations.




     As discussed below, the Subtitle C regulations would lead to the




closing or modifying, of many existing treatment/disposal facilities




and to significant changes in current treatment/disposal practices.




In addition, the regulations would likely affect the portion of




hazardous wastes treated/disposed on-site and off-site.




     Facility Closing or Modification.  A major impact resulting from




the Subtitle C regulations would be the closing of those hazardous




waste management facilities (both off-site and on-site) that could




not or would not comply with the treatment/disposal requirements and
                                 7-26

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the modification of other hazardous waste management facilities to



enable compliance with the requirements.  Facilities requiring



modifications would have to make such modifications in accordance




with compliance schedules contained in permits issued to them under



the Section 3005 regulations.  The modifications would have to be




made within 3 years from the original date of issuance of the




compliance schedule; for compliance schedules exceeding 6 months,



interim compliance requirements would also have to be met every 6




months.



     Data are not available to estimate the number and type of



hazardous waste treatment/disposal facilities that would have to



close down or be modified as a result of the proposed regulations.




However, based on the reported incidences in Appendix J and other



available data discussed below, it is expected that a very large



portion of existing facilities would require modification to be able




to comply with the treatment/disposal requirements.  For example,



less than 10 percent of hazardous manufacturing wastes from 14 major




generating industries are estimated to have been treated/disposed in




an environmentally acceptable manner in recent years (see Table 5-7).



While some of this environmentally unacceptable treatment/disposal



could be made acceptable by the use of alternative treatment methods



instead of by facility modification, it is likely that the vast



majority of existing treatment/disposal facilities handling such



wastes would require modifications in order to comply with the






                                  7-27

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treatment/disposal requirements.  For example, of 80 estimated haz-



ardous waste management service industry landfills currently handling




some form of potentially hazardous waste, it is estimated that ap-




proximately 20 could meet secure landfill standards (Foster D. Snell,



Inc., 1976; Straus, 1977).  Furthermore, according to the Industry



Studies (1975-1978), the vast majority of hazardous industrial wastes



that are disposed in landfills are disposed in general purpose land-




fills rather than secure landfills (see Appendix D).  Additionally,




about 16,000 land disposal sites accepted municipal wastes in 1976;



most also received some industrial waste; it is estimated that only



about 100 had impermeable linings and only about 200 had leachate




collection systems (Waste Age, 1977).  Appendix D discusses other



examples of facilities that could require modifications.



     Changes in Current Treatment/Disposal Practices.  Those existing



hazardous waste treatment/disposal practices that are environmentally



unacceptable according to the Subtitle C regulations would be pro-



hibited or restricted or would have to be modified; some practices



could be replaced by other, more environmentally acceptable, prac-



tices.



     Existing practices that are likely to be prohibited or severely




restricted by the Subtitle C regulations include:  open burning;



uncontrolled incineration; road application of untreated waste oil;




the use of landfills without leachate collection systems and ground-




water monitoring systems; the use of surface impoundments without
                                 7-28

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leachate detection systems and groundwater monitoring systems;



landfarming of highly volatile wastes or wastes containing arsenic,




boron, molybdenum and/or selenium in concentrations greater than soil



background conditions; the location of landfills, surface impound-




ments, and landfarms within 150 meters (500 feet) of functioning



public or private water supplies or livestock water supplies; and the




mixing of incompatible wastes in surface impoundments and basins,



except for the purpose of treatment.  In addition, the Subtitle C



regulations specifically prohibit such existing practices as open




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



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



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




waste application practices that allow the zone of incorporation of



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



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



systems that are activated when a malfunction occurs.




     The Subtitle C regulations also impose specific requirements for



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



closure all disposal operations would have to be completed and all




wastes removed from treatment facilities and disposed in accordance



with the regulations.  Hazardous wastes and hazardous waste residues




would also have to be removed from all surface impoundments that do



not meet the standards for landfills and disposed according to the



regulations.  Any contaminated soil-filter medium at landfarms would
                                7-29

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also have to be removed.  Monitoring and maintenance care would have

to be provided for a period that need not exceed 20 years from
close-out.
     For the most part, data are not available to enable an estimate
of the quantity of hazardous wastes currently treated/disposed by
each of the above practices, the number of off-site or on-site
treatment/disposal facilities that would be affected by such pro-
hibition or restrictions, nor any potential shift likely to occur in
the quantities of hazardous waste treated/disposed by various methods
as a result of the regulations.  Specific changes would be dependent
upon such factors as treatment/disposal economics; waste characteris-
tics; adequacy of available pollution control devices; availability
and adequacy of alternative treatment/disposal methods; and site-
specific conditions such as climate, soil characteristics, and
groundwater characteristics.
     As previously discussed, available data indicate that about 90
percent of the hazardous manufacturing wastes from 14 major generat-
ing industries are estimated to have been treated/disposed in an
environmentally unacceptable manner in recent years.  For each method
used for treating/disposing of these wastes, the portion of the waste
estimated to have been treated/disposed in an environmentally unac-
ceptable manner using that method is as follows (see Table 5-7):
surface impoundment—over 99.9 percent; dumping and landfilling—
about 95 percent; incineration—about 65 percent; other (road appli-
cation, landfarming, deep-well injection)—almost 100 percent.
                                 7-30

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      Table 5-11 shows, for four of these 14 industries, the esti-




mated percentage of hazardous wastes treated/disposed by environmen-




tally inadequate methods in recent years.  Between 95 and 100 percent




of the hazardous wastes were treated/disposed by such methods in




these industries.  Battelle Columbus Laboratories (1978) has esti-




mated, for selected hazardous waste streams from these 14 industries,




the percentage of the generating facilities in the industry that have




been using environmentally inadequate treatment/disposal methods in



recent years.  For most of the hazardous waste streams reviewed, 70




percent or more of the facilities were estimated to have used




environmentally inadequate treatment/disposal methods.




     Due to the enactment of more stringent Federal and state en-




vironmental regulations in the period since these 14 industries were




surveyed (1973-1975), it is likely that a somewhat greater portion of




hazardous waste is now being treated/disposed in an environmentally




acceptable manner in these industries.  For analysis purposes, based




upon a hazardous industrial waste generation of about 40 million




metric tons in 1984, and assuming, as an upper limit, that 90 percent




of such wastes would continue to be treated/ disposed in an environ-




mentally inadequate manner without the promulgation of the Subtitle C




regulations, it is estimated that these regulations could result in




up to an additional 36 million metric tons of hazardous industrial




wastes being treated/disposed in an environmentally adequate manner




annually by 1984.






                                  7-31

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     Change in Hazardous Wastes Treated/Disposed On-site and Off-

site.  The Subtitle C regulations would likely lead to changes in the

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

and off-site by the waste management industry.  Based upon the Indus-

try Studies (1975-1978), about 82 percent of all hazardous industrial

wastes are typically treated/disposed on-site by the generator; about

15 percent are treated/disposed off-site; about 3 percent are re-

claimed.  The percentage treated/disposed on-site and off-site, how-

ever, varies widely from industry to industry (see Table 5-10).*

     The trend in at least one industry is to increase the portion of

hazardous wastes being treated/disposed on-site.  A study of hazard-

ous waste practices in the petroleum refining industry (Jacobs En-

gineering Company, 1976) indicated that on-site treatment/disposal

was expected to increase from 44 percent in 1974 to 73 percent by

1983; most of the change was expected to be due to increases in on-

site landfarming and landfilling.  The major reasons reported to be

given by the industry (prior to the enactment of RCRA) for the poten-

tial increase in on-site treatment/disposal are as follows:

     •  The emerging stringent water and air emission requirements
        dictate that increasing volumes of hazardous wastes may need
        to be discharged to the land since land disposal is not as
        stringently regulated at the present time;
*These percentages are based upon a survey of a limited number of
 establishments within each manufacturing industry.  According to the
 Industry Studies, while the numbers for each industry are typical
 of those establishments which replied to the survey, they may not be
 representative of each industry as a whole.
                                  7-32

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     •  The legal protection surrounding the use of private property
        (as observed in a review of existing solid waste laws as they
        apply to private on-site versus public off-site disposal)
        sometimes allows industry to dispose of industrial wastes on
        its own property without the necessity of permit, monitor-
        ing, or supervision and control by regulatory agencies;

     •  The present trend is one of increasingly stringent require-
        ments by regulatory agencies surrounding disposal of in-
        dustrial wastes to outside municipal or private landfills;

     •  The closure of many dumps, lagoons, and sumps over the past
        few years has seriously reduced the availability of nearby
        disposal sites;

     •  The cost of transporting large volumes of wastes long dis-
        tances to certified secure hazardous waste disposal sites
        would bring about significant economic and price dislocations
        to a segment of the industry and place certain refineries at
        an immediate disadvantage.

     The Subtitle C regulations would likely reverse, or signifi-

cantly reduce, such a trend to on-site treatment/disposal since the

regulations contain stringent requirements for the treatment/

disposal of hazardous wastes and apply these requirements equally to

on-site and off-site treatment/disposal.  Thus, one of the primary

advantages given for on-site treatment/disposal—little or no

regulation—would be eliminated.

     Several factors would affect the portion of hazardous wastes

treated/disposed on-site and off-site under Subtitle C.  For the most

part, these factors would be very industry, waste stream, and site

specific and, as a result, it is not possible to accurately determine

the extent of any shift that could occur under the Subtitle C regu-

lations.
                                  7-33

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      Factors that would tend to increase the portion of wastes

treated/disposed off-site under the Subtitle C regulations are as

follows:

     •  An indeterminable portion of the existing on-site treatment/
        disposal facilities would not be able to be modified to
        comply with the Section 3004 requirements and would have to
    /   cease operation;

     •  A portion of generators, especially small generators, who
        currently dump or otherwise dispose wastes on-site in an en-
        vironmentally inadequate manner would not be able to afford
        permittable treatment/disposal facilities or would not want
        to construct such facilities and would have to ship
        wastes off-site;

     •  Certain existing practices would be prohibited or severely
        restricted and a portion of those on-site facilities
        employing such practices would likely send wastes off-site
        instead of using alternative on-site practices;

     •  In some states off-site treatment/disposal currently tends to
        be more stringently regulated than on-site disposal;
        enactment and enforcement of stringent regulations applicable
        both off-site and on-site treatment/disposal would tend to
        make on-site treatment/disposal less advantageous;

     •  Off-site hazardous waste management facilities in EPA Region
        IX have the highest capacity utilization rates in the U.S.
        for every type of treatment/disposal practice due to strict
        and uniform enforcement of treatment/disposal in the region
        compared to most other regions and due to siting problems re-
        sulting in restricted hazardous waste management capacity
        (Foster D. Snell, Inc., 1976).

     Factors that could tend to limit any potential increase in the

portion of hazardous wastes transported off-site include:

     •  Public opposition to siting of off-site facilities;

     •  The inability to locate permittable off-site facilities
        relative to generator needs and the inability to make
        sufficient treatment/disposal capacity available at such
        facilities;
                                7-34

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     •  Potential increases in volume reduction and in resource con-
        servation and recovery practices as a result of Subtitle C
        which could reduce the quantity of hazardous wastes requiring
        disposal.

     To quantify the potential shift in the portion of hazardous

waste disposed on-site and off-site, available state data were

reviewed to determine whether such shifts have occurred in states

that have enacted hazardous waste legislation and the extent of any

such shifts.  As indicated in Section 5.3.6, only a few states have

accumulated, as of 1978, sufficient data to enable an estimation of

the portions of hazardous wastes generated within the state that are

being treated/disposed on-site versus off-site (see Table 5-14).

Comparable historical data are not available from these states to

enable a determination of any change in the portion of wastes

treated/disposed on-site and off-site following enactment of the

state's hazardous waste (or equivalent solid waste) legislation

(personal communication with representatives of the following state

agencies:  California Department of Health, Vector Control Section,

1978; Florida Department of Environmental Regulation, Solid Waste

Section, 1978; Illinois Environmental Protection Agency, Division of

Land Pollution Control, 1978; Kansas Department of Health and

Environment, Bureau of Environmental Sanitation, Solid Waste Section,

Hazardous Waste Unit, 1978; Maryland Department of Health and Mental

Hygiene, Environmental Health Administration, Division of Solid

Waste, 1978; Massachusetts Bureau of Solid Waste Disposal, 1978;

Minnesota Pollution Control Agency, Division of Solid Waste,

                                 7-35

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Hazardous Waste Section, 1978; Rhode Island Department of Health,



Division of Solid Waste Management, 1978; Texas Division of Solid



Waste Management, 1978).




     In Illinois, on-site disposal is reported to be down and off-




site (including out-of-state) disposal up following enactment of the



state's solid waste legislation; the percentage change is not avail-




able (Personal Communication, Illinois Environmental Protection




Agency, Division of Land Pollution Control, 1978).  In California,



the hazardous waste going off-site is not expected to decrease as a




result of the state's hazardous waste legislation (Personal communi-



cation, California Department of Health, Vector Control Section,



1978).  Estimates of the direction of any other potential shifts are




not available from the other states.



     Of those states listed in Table 5-14, Illinois and Texas cur-



rently have hazardous waste regulations closest to those that would



be promulgated under Subtitle C.  In addition, the data for Illinois



and Texas in Table 5-14 are based upon the required reporting of



current practices; the data for all the other states are based upon



less recent, limited surveys directed toward determining existing




hazardous waste practices in each state and needed changes in the



state's hazardous waste regulation.  Furthermore, Illinois and Texas




have permitted facilities both on-site and off-site while several of



the other states, e.g., Kansas and Rhode Island, do not have
                                7-36

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permitted off-site facilities (most wastes go out-of-state in such



instances).




     For the reasons cited above, the Illinois and Texas data are



used, solely for analysis purposes, to provide an estimated range for



the portion of hazardous wastes that might be disposed off-site by




1984 under the Subtitle C regulations.  It should be noted that these




data are being used as a surrogate to analyze potential impacts that



could occur from a shift in on-site and off-site disposal, should



such a shift occur, and not as a firm estimate of the magnitude of




any such shift.



     Under this surrogate method, and assuming that the wastes whose




disposal location is unknown in these two states are disposed on-site




and off-site in the same ratio as those wastes whose disposal loca-




tion is known (see Table 5-14), about 25 percent of the hazardous




wastes in Illinois and about 13 percent of the hazardous wastes in




Texas are estimated to be disposed off-site.  For 1984, a range of 13



to 25 percent off-site treatment/disposal of hazardous industrial



wastes is thus used to analyze the potential impacts that could occur



from probable shifts in off-site and on-site disposal under the



Subtitle C regulations.  For 1980, it is assumed that 15 percent of




hazardous industrial wastes would continue to be treated/disposed



off-site.  It should be noted that the range used for 1984 includes




both eventualities previously discussed—a slight decrease or a
                                 7-37

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moderate increase in the portion of hazardous wastes currently esti-

mated to be shipped off-site for treatment/disposal.

     7.1.3  Administrative Changes.  Implementation of the Subtitle C

regulations would necessitate a widesweeping series of administrative

changes that would affect industry, state governments, and the

Federal government.  Potential effects are assessed in the following

sections with regard to:

     •  State administration of programs;

     •  Overlapping Federal and state hazardous waste programs;

     •  Number of generators required to comply with the regula-
        tions

     •  Number of transporters required to comply with the
        regulations;

     •  Number of storers, treaters, and disposers required to obtain
        permits;

     •  Paperwork requirements under the regulations.

     7.1.3.1  State Administration of Programs.  As specified in

Section 3006 of RCRA, states are to be encouraged to apply to the

U.S. Environmental Protection Agency for authorization to administer

and enforce their own hazardous waste program pursuant to Subtitle C.

There would be three different types of authorization for which

states could apply:  full authorization, partial authorization, and

interim authorization.

     Full authorization would allow a state to carry out a hazardous

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

According to RCRA, a state application for full authorization must be

                                  7-38

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approved unless the state program is determined:  not to be equi-

valent to the Federal program; not to be consistent with the Federal

program or with those programs authorized by EPA in other states; and

not to provide adequate enforcement of compliance with the require-
        s
ments of Subtitle C.

     To be considered equivalent, a state program would have to have

legislative authority, published criteria and standards, a permit

mechanism, a manifest system, identification of resources, inter-

agency delineation of responsibilities (if applicable), and public

participation.  To be consistent, a state program would have to allow

for the free movement of hazardous wastes (e.g., no ban on the impor-

tation of hazardous wastes from other states) and would not be al-

lowed to have standards that are more stringent than necessary (e.g.,

standards designed to discriminate against out-of-state wastes).

Adequacy of enforcement would be judged on a state-by-state basis; no

quantifiable standards have been set.

     Partial authorization would allow a state to administer and en-

force selected components of a hazardous waste regulatory program es-

tablished pursuant to Subtitle C.*  EPA would retain responsibility

for the remaining components of the program.  States would be con-

sidered for partial authorization only if state legislative authority
^Individual program components include a waste tracking system (mani-
 fest system); control of treatment, storage, and disposal of hazar-
 dous wastes through a permit system; conducting inspections and
 taking samples; and regulations governing hazardous waste generators
 and transporters and owners/operators of hazardous waste treatment,
 storage, and disposal facilities.

                                  7-39

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did not exist for all required program components.  The state would




be expected to run those program components for which it had legis-



lative authority, providing the state program was enforceable, con-




sistent with, and equivalent to the Federal program.  In all cases,



the combination of state and the Federal programs would have to meet



the requirements of a fully authorized program.  Before granting




partial authorization, EPA would expect the state to agree to submit




proposed legislation to the state legislature so as to remedy the



deficiencies preventing full authorization.  It is expected that




partial authorization would not be available during the two year




interim authorization period discussed below.  Partial authorization



would be granted for a period not to exceed five years, but could be




renewed.



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



dous waste program in lieu of the Federal program under Subtitle- C




for a period not to exceed twenty-four months, beginning on the date



six months after the date of promulgation of regulations under



Section 3001.  The purpose of interim authorization is to allow the




state to make an orderly transition from its present program to a




program eligible for full authorization.  To be eligible for interim



authorization, a state would have to have a hazardous waste program




pursuant to state law in existence prior to the the date 90 days



after the date of promulgation of regulations under Sections 3001 of
                                  7-40

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Subtitle C.  To achieve interim authorization, the state program


would have to be substantially equivalent to the Federal program and


would have to provide an Authorization Plan which describes the


addition or modifications necessary to qualify for full authorization


together with the schedule for such additions or modifications.


Substantial equivalency encompasses:  legislative authority, iden-
                                                            t

tification of resources, a permit mechanism, surveillance and


enforcement, and public participation.  Jn addition, the state would


have to agree with EPA on an oversight procedure which would allow


EPA to monitor the state's program to ascertain that the program was


being administered and enforced in accordance with RCRA.


      To achieve full, partial, or interim authorization, a state


must have prior legislative authority to provide the necessary pro-


gram components.  Chapter 2 contains a detailed description of the


existing and proposed state hazardous waste legislation. As of 1978,


15 states have separate and specific laws governing the management of


hazardous wastes; another 10 states and one territory have proposed


hazardous waste legislation.  Thirty-six states (including the


latter 10) and two territories have currently addressed hazardous


waste management as a separate section within their solid waste


legislation.  The state programs vary widely with regard to such


factors as wastes controlled, published criteria and standards,
                                 7-41

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on-site and off-site control of wastes, and importation bans.*

     EPA staff estimates are that approximately 34 states and

territories could qualify for interim authorization under the

Subtitle C regulations.  No states are believed to be currently able

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

qualify for partial authorization before the end of the interim

authorization period.

     7.1.4.2  Overlapping State Programs.  Although RCRA encourages

states to administer their own authorized hazardous waste program in

lieu of the Federal program, states are not required to administer

such programs.  If a states does not choose to administer a program

under Subtitle C of RCRA, there would be a Federally run program in

that state.  RCRA, however, does not prohibit states without auth-

orized programs from enacting and enforcing their own more stringent

or non-consistent hazardous waste program to be run in the state in

addition to the Federal program.

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

program in addition to the Federal program or what regulations would

be promulgated under any such overlapping program.  Such additional
*Six states currently have specific importation bans.  These states
 are Louisiana, Maine, Massachusetts, New Hampshire, Rhode Island,
 and Vermont.  In addition, Oklahoma has legislation equivalent to an
 importation ban.  Such bans preclude full authorization.  A recent
 U.S. Supreme Court decision (No. 77-404; June 23, 1978; City of
 Philadelphia et al. v. New Jersey et al.) struck down New Jersey's
 statutory importation ban.  It is not clear how importation bans in
 other states would be affected by this decision.
                                7-42

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state programs, if enacted, would have the potential for creating



various impacts.  Some of the major potential problems that could




result from the enactment of overlapping Federal and state programs



are briefly illustrated below.



      An overlapping state program would likely subject hazardous




waste generators, transporters, storers, treaters, and disposers to




conflicting and/or duplicative requirements and regulations.  For



example, storers, treaters, and disposers could be required to obtain




two permits, with potentially different requirements, before they




could construct or operate facilities.  Generators could be required



to fill out two separate manifests for each off-site shipment or



could be required to manifest wastes that would not be considered




hazardous under the Federal program.  Everyone generating or managing



hazardous wastes within such states could be required to prepare and




store two different sets of overlapping reports or to prepare and




store reports not required under the Federal program.  Economic



dislocations could result to firms located within such states if the



more stringent standards significantly increased the firm's cost of




doing business relative to that of firms in other states.  Under such



conditions some generators might choose to relocate to other states.




     Increased transportation demands and distances could result if




more wastes had to be shipped further distances within the state or



to out-of-state facilities due to increased controls within the gen-



erating state, or if wastes formerly going to one state had to be
                                  7-43

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shipped Co a more distant state due to enactment of import bans.



However, transportation demands and distances could also be reduced



in some states if increased controls or import bans in adjacent



states significantly reduced the amount of wastes being shipped out-




of-state. Localized shortfalls in storage, treatment, and disposal



capacity could result from or be exacerbated by stricter regulations



and import bans.  In the short run, there could be increased




instances of illegal or less desirable disposal in states with such



capacity shortfalls.  In the long run, there could be additional




waste treatment or process modifications.



     Furthermore, while an overlapping state program would likely




afford increased protection to the residents of that state, it would



likely hinder the effectiveness of the Federal program on a national-




scale and could result in a reduced level of protection for residents



of other states.  For example, importation bans or other regulations



hindering the free movement and/or disposal of wastes could result in




some hazardous wastes being managed in a less effective or less de-




sirable manner than would otherwise have occurred.



     7.1.3.3  Number of Generators Required to Comply with the




Regulations.  Potential hazardous waste generators within the scope




of this EIS are expected to fall within the following SIC Codes:



     •  Agriculture, forestry, fishing (SIC 07-09);




     •  Manufacturing (SIC 20-39);



     •  Transportation and public utilities (SIC 40-46, 49);
                                   7-44

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     •  Wholesale trade (SIC 50-51);



     •  Retail trade (SIC 52, 54-55, 58-59);




     •  Services (SIC 72-73, 75-76, 78, 80, 82, 84, 88-89);



     •  Public administration (SIC 95-97).




Not all producers of hazardous wastes within these SIC Codes would be




required to comply with the Subtitle C regulations.  Section 7.1.2.1



delineates those hazardous waste producers who would be considered



generators subject to the Subtitle C regulations.




     Available data generally relate to the manufacturing industries



and to selected other industry categories in which large numbers of



establishments are likely to produce hazardous wastes.  These indus-




try categories are discussed below to illustrate the potential mag-



nitude of both the number of hazardous waste producers and the number




of generators required to comply with the regulations based on a



generator limit of 100 kilograms per month.




     Magnitude of Potential Generators of Hazardous Wastes.



     Manufacturing Industries.  There are over 313,000 manufacturing




establishments in the United States (See Tables 7-3 and 7-4).  While



every one of these manufacturing establishments is not likely to be a



potential producer of hazardous wastes, the limited data available



preclude an accurate determination of the number that are.  An esti-



mate, solely for purposes of analysis, is made as described below.



     A recent study (Fred C. Hart Associates, 1978) summarizes the




available data as to the number of establishments generating
                                7-45

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                              TABLE 7-3




      NUMBER OF MANUFACTURING ESTABLISHMENTS BY 2-DIGIT SIC CODE*

Industry
Food and kindred products
Textile mill
Apparel and other textile
Lumber and wood
Furniture and fixtures
Paper and allied products
Printing and publishing
Chemicals and allied products
Petroleum and coal products
Rubber and plastics
Leather and leather products
Stone, clay, and glass
Primary metals
Fabricated metal products
Machinery, except electrical
Electric and electronic equipment
Transportation equipment
Instruments and related products
Miscellaneous
TOTAL
SIC code
20
22
23
24
25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
-
Number of establishments
28,185
7,204
24,430
33,931
9,242
6,047
42,103
11,430
2,080
9,271
3,206
16,025
6,795
30,299
40,795
12,268
8,804
5,989
15,185
313,289

*Based on Appendix K.
                                    7-46

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                              TABLE 7-4

         NUMBER OF MANUFACTURING ESTABLISHMENTS BY EPA REGION*

EPA Region
I
II
III
IV
V
VI
VII
VIII
IX
X
Number of Establishments'!"
23,258
52,302
28,213
45,729
68,994
24,360
14,322
6,619
38,126
11,366

*Based on Appendix K.
tSIC Codes 20, 22-39.
                                  7-47

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hazardous wastes within major industrial groups.  That study cautions

that the data provided on the number of hazardous waste producers can

only be regarded as tentative because the data are based on many dif-

ferent reports in which different criteria were used for identifying

hazardous wastes and hazardous waste generators.  Table 7-5 shows the

manfacturing SIC Codes considered in that study and indicates, by EPA

Region, the estimated number of establishments and hazardous waste

producers within the selected SIC Codes.  Based on Table 7-5, an esti-

mated 90 percent of the manufacturing establishments in the selected

manufacturing SIC Codes generate some hazardous wastes.  Assuming

that this percentage holds for all manufacturing establishments,

based on Table 7-3, it is estimated that about 282,000 manufacturing

establishments produce some hazardous wastes.

     Other Major Categories of Generators.  Other than the manufac-

turing industries, industry categories in which there would likely be

large numbers of hazardous waste generators include, but are not

limited to, automotive service stations*, hospitals, medical labora-

tories, and research facilities.t  It is estimated that there would

be up to 283,000 potential generators within these categories (see

Table 7-6).
*Automotive service stations include gasoline service stations,
 general automotive repair operations, and motor vehicle dealers.
tAs discusssed in Section 7.1.2.1, any hazardous waste generator
 engaged solely in retail trade or farming would be considered a
 generator subject to the regulations only with regard to waste
 automotive oil.  It is expected that as a result of this exclusion,
 there would be very few such generators subject to the regulations.
                                 7-48

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                                                TABLE 7-5
                           POTENTIAL HAZARDOUS WASTE  GENERATORS WITHIN
                         SELECTED  MANUFACTURING  INDUSTRIES BY EPA REGION*

Industry
Organic chenlcals, pesticides
and explosives
Ferrous metals

Electroplating
Job shops
Captive shops
Inorganic chemicals

Nonfcrrous metals
Textiles
Petroleum refining
Plastics naterials and
synthetics
Special machinery
Leather tanning
Paint and allied products
Contract-solvent recycling
Pharmaceuticals
Petroleum re-refining and
processing
Rubber

Electronic components
Batteries
TOTAL

SIC codes
2861. 2865. 2869.
2879. 2892
3312. 3313. 332.
3399

3471
N.A.t
2812, 2813, 2816
2819
333, 3341
22
2911
282

355. 357
3111
2851
N.A
N.A. t
2831. 2833. 2834
2992 + others

3011, 3021. 3031,
3041, 3069
367
3691. 3692
-
Number of
establishments
2.226

1.780


2,254
12,000
1,600

346
5,300
247
462

4,610
517
1.544
90
45 000
1,100
1.544

1,539
•
2,855
262
85,276

I
72

1


326
1,741
2

10
258
	
36

439
103
81
5
54


178

367
17
3,690

II
336

15


277
1,476
16

37
367
7
53

715
71
294
17
282
23

186

588
17
4.777
Number of
III IV
286 401

63 37


176 157
936 827
15 27

41 34
206 998
18 16
59 94

322 528
15 11
120 182
7 10
115 106
15 37

128 193

230 173
24 44
2,776 3,875
potentisl
V
388

59


861
4,584
21

91
71
35
99

990
42
393
generators in
VI VII
275 135

12 2


99 115
528 612
34 4

40 16
30 IS
80 13
55 8

192 147
4 5
118 77
23 7 4
215 68 81
37

495

524
52
8.980
23 15

82 47

132 78
24 18
1.803 1,392
EPA region
VIII
75

3


31
168
4

12
4
29
2

47
5
14
1
20
9

18

36
7
485
IX
198

12


163
863
9

45
49
37
54

538
15
221
13
143
33

187

694
41
3.315
X
60

10


49
265
6

20
9
12
2

130
6
44
3
16
14

25

33
13
717
Total
2,226

214


2.254
12.000
138

346
2,007
247
462

4,048
277
1.544
90
«nnn
t UUU
1.100
206

1,539

2,855
257
76.810
•Modified from Fred C. llart Associates. Inc., 1977.
tNot available. Captive shops are counted under the SIC Code of the parent
 establishment.

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                           TABLE 7-6

     ESTIMATED NUMBER OF POTENTIAL PRODUCERS OF HAZARDOUS
               WASTES WITHIN SELECTED CATEGORIES
Category
     Number of
potential producers
Service industry

  Hospitals*
  Medical laboratories*

  Research facilities*

    Sub-total

Retail industry

  Automotive service stationst

Special wastes

  Cement manufacturing^

  Coal-fired utilities§

  Oil drilling
  Phosphate rock mining and processing

  Uranium mining

  Other mining
     267,000
       250-275H

     Not available

     Not available

     Not available

     Not available
*Fred C. Hart Associates, Inc., 1977.
tModified from Fred C. Hart Associates estimates based upon
 EPA staff estimates that only 90 percent of gasoline service
 stations would produce hazardous wastes; the other 10 percent
 are self-service stations which are not likely to produce
 hazardous wastes.
fHolberger et al., 1978.
iPersonal communications, National Ash Association, 1978.
flThis is the total number of plants generating the special
 waste.  It is not known how many, if any, of these plants
 would generate special waste that would be identified as
 hazardous under the regulations.
                              7-50

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     With regard to 'special wastes', up to about 375 cement manufac-




turing plants and coal-fired utilities could potentially be producers




of such wastes (see Table 7-6).  Data are not available to estimate




the total number of these plants that could generate wastes that




would be identified as hazardous under the Subtitle C regulations.




Data are also not available' to estimate the number of potential pro-




ducers of other 'special wastes' that could be identified as hazard-




ous under the regulations; however, the number could be large.  For




example, 10,000 to 20,000 oil wells have been drilled annually in




recent years with about 60 percent of these wells being successful




(U.S. Department of the Interior, 1976); however, the number of cur-




rently producing wells generating potentially hazardous brines and




muds is not known.




     Number of Hazardous Waste Generators Required to Comply With the




Subtitle C Regulations.  The generator regulations provide that




establishments producing and disposing of more than 100 kilograms per




month of wastes are to be identified as hazardous waste -generators




subject to regulation.   Table 7-2 shows, by EPA Region, the esti-




mated number of manufacturing establishments producing less than 100




kilograms of hazardous wastes per month and the total amount of




hazardous wastes produced annually by such establishments.  Over




81,000 manufacturing establishments could potentially be excluded




from complying with the regulations based upon a generator limit of




100 kilograms per month.  While these establishments represent about




26 percent of all manufacturing establishments within the SIC Codes




                                7-51

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considered, they produce less than 0.1 percent of the total hazardous




wastes produced by all manufacturing industries within these particu-




lar SIC Codes.




     Based upon this information and a study by Fred C. Hart Asso-




ciates (1976), the total number of manufacturing establishments




generating hazardous wastes that potentially may not have to comply




with the generator regulations is estimated to range between 81,000




and 112,000.  The total number that potentially may have to comply is




estimated to range between 201,000 and 232,000.  The establishments




required to comply are estimated to generate over 99.9 percent of all




hazardous wastes produced by the manufacturing industries.




     With regard to automotive service stations, EPA staff estimates




are that about 35 percent of all gasoline service stations would be




likely to generate 100 kilograms or less per month of hazardous




wastes; thus, up to 210,000 automotive service stations could be




subject to the generator regulations.  However, EPA staff estimates




are that approximately 75 percent of these automotive service




stations would use transfer of liability contracts to avoid having to




comply with the generator requirements.  Thus, on the order of 50,000




automotive service stations could have to comply with the generator




regulations.  In addition, up to about 16,100 hospitals, medical




laboratories, and research facilities could have to comply (see Table




7-6).
                                7-52

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     Thus, there would potentially be on the order of 270,000 to



300,000 generators within these three categories who could be subject



to the generator regulations.




     7.1.3.4  Number of Transporters Required to Comply with the




Regulations.  Hazardous wastes are transported by highway, rail,




waterway, air, and pipeline, with the vast majority being transported




by truck (see Appendix E).  Hazardous waste transporters include



hazardous waste generators, treaters, and disposers as well as estab-



lishments engaged solely in transport activities.  According to a



recent study of the hazardous waste transport industry (Arthur D.



Little, 1978a), the number of firms currently transporting hazardous



wastes is unknown, both for the industry as a whole and for each of



its segments.




     7.1.3.5  Number of Storers, Treaters, and Disposers Required to




Obtain Permits.  Sections 7.1.2.3 and 7.1.2.4 delineate those hazard-




ous waste storers, treaters, and disposers who would be required to



obtain permits.  A study by Battelle Columbus Laboratories (1978)




attempted to estimate the number of potential permittees under the



regulations.  Table 7-7 shows the Battelle Columbus Laboratories'




estimate of the number of potential permittees for the manufacturing



industries (for those industries listed in Table 7-5), Federal in-



stallations, hospitals, automotive service stations, and the existing




hazardous wastes management service industry.  There are estimated to
                                 7-53

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                               TABLE 7-7
               ESTIMATED NUMBER OF POTENTIAL PERMITTEES*
                                                      Number of
      Category                                  potential permittees
Manufacturing industry
  Electronic components                                 325
  Electroplating and metal finishing
    Job shops                                           744
    Captive shops                                     4,000
  Explosives                                            577
  Inorganic chemicals                                   138
  Leather tanning and finishing                          30
  Metals smelting and refining                          549
  Organic chemicals                                     845
  Paint and allied products                             235.
  Pesticides                                            512
  Petroleum refining                                    143
  Petroleum re-refining                                   7
  Pharmaceuticals                                       421
  Plastics                                              462
  Rubber products                                        65
  Special machinery                                     781
  Storage and primary batteries                          52
  Textiles                                              190
  Miscellaneous                                      11,659
     Sub-total                                       21,735
Government
  Federal Installations                                 241
Service Industry
  Hospitals                                           7,174
  Hazardous waste management                            110
     Sub-total                                        7,284
Retail industry
  Automotive service stations                            0

  Total                                              29.260

""•Modified from Battelle Columbus Laboratories,  1978.


                                7-54

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be about 29,000 potential permittees within these groups.  According



to that study, data are not available to estimate the number of



potential permittees within other categories.



     With regard to treaters, storers, and disposers of 'special




wastes', there could be potentially a large number of permittees.




For example, in Wyoming alone there are about 10,000 lagoons used for



the disposal of oil drilling muds and brines.  Data are not available



to estimate the portion of 'special wastes' that would be identified



as hazardous, nor the number of potential permittees managing such



hazardous 'special wastes'.



      7.1.3.6  Paperwork Requirements Under the Regulations.  The




Subtitle C regulations establish reporting and recordkeeping require-



ments for generators, transporters, storers,' treaters, and disposers




of hazardous wastes.  Many of these reporting and recordkeeping re-



quirements would be in addition to existing requirements.




     Generators would be required to prepare a manifest for each off-



site hazardous waste shipment, keep a copy of each manifest for 3



years, submit a quarterly report on manifested shipments for which



the signed original manifest (or delivery document) is not returned,




and submit an annual report based on the manifests or on wastes



managed on-site.  Transporters would be required to keep a copy of



manifests (or delivery documents) for a perid of at least 3 years.



Owners/operators of permitted hazardous waste management facilities




(i.e., storers, treaters, and disposers) would be required to keep a



copy of each manifest (or delivery document) for 3 years and also to





                                7-55

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prepare and keep for 3 years records of specified operating



conditions, records of employee training, and records of groundwater



monitoring.  In addition, each owner/operator would be required to




prepare and keep until facility closure a log containing:  the




location and types of wastes disposed at the facility, required waste



analyses, required monitoring data, results of required visual




inspections, and records of any human health or environmental damage




caused by the facility.  Each owner/operator would also be required



to submit both an annual report based upon manifests received during



the year and a quarterly report on groundwater and leachate moni-




toring, if applicable.  Each owner/operator would also have to submit



a permit application and appropriate supplemental material.  In



addition, within 90 days following promulgation of the Section 3001




regulations, all generators, transporters, storers, treaters, and



disposers would be required to notify the EPA Regional Adminis-




trator (or an authorized state) that they fall into one of these



categories.



     Number of Manifests.  Based on the assumptions stated in Section




7.1.4.1, it is estimated that there could be between 350,000 and




690,000 off-site shipments of hazardous industrial wastes annually by



1984, necessitating industrial generators to prepare between 350,000




and 690,000 manifests annually.  An indeterminable number of mani-




fests could also have to be prepared by other generators.  The aggre-



gated generators, transporters, and owners/operators of hazardous




waste management facilities would each have to keep between 1.0 and





                                 7-56

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2.1 million manifests in storage on an annual basis.  Most transport-



ers currently keep at least 3 years worth of delivery documents in




storage due to various state and Federal requirements (see Appendix




E).  To the extent that transporters use acceptable delivery docu-




ments in lieu of manifests or use manifests in lieu of existing



delivery documents, this recordkeeping requirement would not consti-



tute an additional burden on transporters.  However, as indicated in



Chapter 2, most states do not require generators or hazardous waste



management facilities to prepare or retain records on hazardous waste



shipments and, as a result, much of such recordkeeping under Subtitle



C would represent an additional requirement.




     Other Recordkeeping Requirements.  Generators would also have to




keep records on wastes managed on-site to enable preparation of an-



nual reports.  Each owner/operator of a permitted hazardous waste man-



agement facility would have to keep an operating log for the life of




the facility, plus 3 years worth of those records specified above.



Most of this recordkeeping would represent an additional requirement,



based upon existing state regulations.



     Number of Recurring Reports.  Approximately 270,000 to 300,000




annual reports could potentially be prepared by the previously iden-



tified generators, assuming that generators who dispose wastes both



on-site and off-site prepare one combined annual report for both



types of disposal.  Permittees would have to prepare annual reports



only if they receive manifested wastes.  Most of the potential
                                 7-57

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permittees listed in Table 7-7 would be on-site facilities and would



not have to prepare additional annual reports.  Hazardous waste man-




agement service industry facilities and Federal installations could



prepare about 350 additional annual reports.  An indeterminable num-



ber of additional annual reports would also have to be prepared by




other generators and hazardous waste management facilities such as




generators or disposers of 'special wastes'.




     Each permittee would also have to submit four monitoring reports




annually, if there was a potential for discharge to groundwater from



the facility.  Based on Table 7-7, there could be up to 117,000 such



monitoring reports submitted annually.




     Thus, there could be upwards of 387,000 to 417,000 reports pre-



pared and submitted annually by generators and hazardous waste man-




agement facilities.  Most of these reports would represent additional



reporting requirements, based upon existing state regulations.



     Number of Non-recurring Reports.  The previously identified gen-




erators and permittees would have to file about 270,000 to 300,000



notifications under Section 3010 with EPA or authorized states.  An



indeterminable number of transporter and other potential generators




and permittees would also have to file such notifications.



     Transporters could potentially have to file between 140 and 270




spill reports annually, based upon Section 7.1.4.1.  Permittees would




have to file an indeterminable number of incident reports annually.




The potential permittees identified in Table 7-7 would have to submit



approximately 29,000 permit applications and additional supplemental





                                 7-58

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material.  The permit application consists of two parts which may be



submitted separately or together.  Most of these submittals would




represent additional requirements, based upon existing state regu-




lations.



     7.1.4  Air Impacts.  This section discusses potential impacts




that could occur with regard to air quality and climate as a result



of promulgation of the Subtitle C regulations.



     7.1.4.1  Air Quality Impacts.  Current hazardous waste genera-




tion, transport, and storage, treatment, and disposal practices in-



volve a variety of activities, each of which has the potential for




releasing air pollutants to the environment.  The potential for the




release of air pollutants by each of these activities (e.g., land-



filling, incineration, containerization) would be affected in differ-




ent ways by the Subtitle C regulations.  This section discusses




current sources of air pollutants from each of these activities,



incidents that have occurred from current practices, and the ways in



which the baseline regulations could affect potential air pollutant




releases from these sources and practices.



     Air Quality Impacts Relative to the Generation of Hazardous




Waste.  The Subtitle C regulations would apply only to those air




emissions, and resultant air quality impacts, that are produced by



activities occurring after the generation of hazardous wastes.   The




regulations would not apply to those air emissions produced during



the generation of hazardous wastes, nor to those air emissions pro-




duced from the reuse of hazardous wastes as an integral part of





                                7-59

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subsequent process steps without intervening storage.  Thus, the

Subtitle C regulations would not have a direct effect on air emis-

sions resulting from hazardous waste generation.  However, to the

extent that the regulations change the economics of disposal or

treatment, and thus result in process modifications engineered to

recycle hazardous wastes or to reduce or alter the quantity and/or

types of hazardous waste generated, Subtitle C could indirectly

result in changes in process air emissions.

     Air Quality Impacts Relative to Storage of Hazardous Wastes.

Current practices in the storage of hazardous wastes can lead to the

release of air pollutants in three major ways:

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

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

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

As discussed below, the Subtitle C regulations would reduce, to vary-

ing degrees, the existing potential for release of air emissions from

each of these sources.  In addition, any facility construction and/or

modification required by the Subtitle C regulations would affect

construction-related air emissions.

     Fugitive emissions are currently likely to occur in a number of

ways.  The loading or placing of hazardous wastes into storage con-

tainers, storage piles, or surface impoundments currently results in

the release of fugitive emissions containing the hazardous waste


                                 7-60

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itself.  For example, the loading of solid wastes, particularly fine



waste materials, onto open storage piles is likely to result in



particulate matter which contains hazardous waste constituents




becoming airborne in the vicinity of the loading area.  The loading




of hazardous wastes containing volatile materials into tanks or other



containers is also likely to result in the escape of fugitive air



emissions.  In both cases, the amounts of fugitive emissions emitted



is dependent upon the characteristics of the specific wastes being



stored, the degree of controls employed (e.g., dust or vapor recovery



systems), and the adequacy of maintenance operations, particularly



for pump seals, joints, flanges, and other equipment used with




volatile wastes.



     A major current source of fugitive emissions is the escape of




air pollutants from hazardous wastes which have not been properly



covered or containerized during storage.  Such wastes may be subject



to the release of particulate matter containing the hazardous waste




as a result of wind erosion.  Volatile wastes stored in containers




without adequate controls are also a potential source of fugitive



emissions.  The quantity of fugitive emissions produced is dependent



upon the volatility of the waste, the adequacy of the container and




its seals, and the effectiveness of any control equipment present.



Liquid wastes stored in surface impoundments and basins are also a



source of fugitive emissions due to evaporative losses and/or




volatilization of hazardous components.
                                7-61

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     While data are not available Co estimate the magnitude of fugi-

tive emissions presently occurring from hazardous waste storage, the

following reported incidents illustrate the types of air quality

problems that have occurred under current practices (see Appendix J

for other incidents):

     •  Since 1867, asbestos product manufaturers have accumulated
        nearly 2 million cubic yards of assorted industrial wastes in
        open piles in a small Pennsylvania town.  The original gen-
        erator of the wastes went out of business in 1962.  Since
        then two other companies have been responsible for enlarging
        the spoils piles.  The air in the vicinity of the piles has
        been observed to contain asbestos fibers due to wind erosion.
        An air-monitoring program conducted by the U.S. Environmental
        Protection Agency in October 1973 indicated ambient back-
        ground levels of asbestos in the area to be 6 ng/m^.  An
        asbestos level of 9.6 ng/nr* was found at a playground near
        the largest waste pile.  Values obtained near active disposal
        piles ranged from 114 to 1745 ng/m^ (Office of Solid Waste
        Program, 1974a).

     •  A firm engaged in the disposal of spent chemicals was storing
        and disposing of toxic chemical wastes at two Louisiana
        locations.  At one of these sites, several thousand drums of
        waste (some with and some without lids) were in storage.
        Many of the drums were popping their lids and leaking; vis-
        ible vapors were emanating from the area.  The pine trees
        beside the storage area were all killed as a result of this
        leakage (Office of Solid Waste Programs, 1974a).

     The Subtitle C regulations contain provisions that should, to a

large degree, reduce the potential for such fugitive air emissions

from the storage of hazardous wastes.  For example, the Section 3005

regulations would require that all owners/operators of hazardous

waste storage facilities, except storage facilities operated by

generators who store hazardous wastes for 90 days or less prior to

off-site treatment/disposal in an approved facility, obtain a permit

for such storage.  To obtain and keep a permit, such storage

                                7-62

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facilities would have to comply with the Section 3004 storage regula-



tions.  According to these regulations, hazardous waste storage op-




erations would have to be conducted in such a manner that no dis-




charge occurs; these storage operations would also have to be moni-




tored and inspected to detect any potential discharge. Hazardous




wastes which could release air emissions that could adversely affect



human health or the environment if stored in an open manner would be



required to be stored in tanks or other closed containers.  Hazardous



wastes to which this requirement would apply include those which



could potentially release air contaminants in concentrations, measur-



ed at the surface of the storage area, exceeding the Threshold Limit



Values (TLV) listed in Appendix B, Subpart D, Annex 2.  For example,




the asbestos-containing wastes previously discussed would likely have



to be stored in closed containers under the Subtitle C regulations




rather than placed in open piles.



     Furthermore, the regulations require that containers used to




store hazardous wastes must not be opened, handled, or stored in any



manner which could rupture the container or cause it to leak.  Wastes



in containers whose contents begin to leak would have to be recon-



tainerized.  Also, storage containers and tanks would have to be con-




structed of materials, or contain a liner, which are compatible with



the wastes stored.  These requirements would apply, for example, to



the hazardous wastes stored in leaking containers at the Louisiana
                                 7-63

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storage site previously discussed.  Under the Subtitle C regulations,




such wastes would have to be recontainerized and stored in another




manner less susceptible to leakage.




     In addition, volatile wastes—those with a true vapor pressure




greater than 78 mm mercury at 25 C~would not be allowed to be stored




in surface impoundments or basins under the Subtitle C regulations.




Storage tanks with a capacity in excess of 19,000 liters (5,000 gal-




lons) would not be allowed to be vented directly to the atmosphere if




they contained such volatile wastes.  Examples of listed hazardous




waste constituents (Appendix B, Subpart A, Paragraph 250.14(a)) which




have vapor pressures greater than that specified above and which have




also been identified in hazardous industrial waste streams (see




Appendix C) include:  acrolein, benzene, chloroform, methyl bromide,




trichloroethane, and vinyl chloride (Perry et al., 1973).  The




Louisiana landfill incident cited above illustrates one type of inci-




dent that has occurred from fugitive emissions from the storage of




volatile wastes.




     Spills, fires, explosions, and other accidents represent a




second major source of potential air emissions from current hazard-




ous waste storage practices.  Improper storage and mixing of incom-




patible wastes and the improper storage and handling of potentially




explosive or ignitable wastes have been major contributors to fires




and explosions in hazardous waste storage areas in the past.  Incom-




patible wastes are those wastes unsuitable for commingling with




another waste or material because the commingling might result in:





                                 7-64

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extreme heat or pressure generation; fire; explosion or violent reac-



tion; formation of substances which are shock-sensitive, friction-




sensitive, or otherwise have the potential of reacting violently;




formation of toxic dusts, mists, fumes, gases, or other chemicals;



volatilization of ignitable or toxic chemicals due to heat genera-



tion.  Appendix B, Subpart D, Annex 4 presents examples of potential-




ly incompatible wastes.



     Volatile wastes and wastes composed of fine materials are those



most likely to release air contaminants emissions as a result of




storage accidents.  In addition, ignitable wastes which catch fire as



a result of an accident are a further source of emissions.  Fires



could also create and release additional hazardous air contaminants




not originally present in the hazardous waste itself (Appendix M



describes some of the emissions that could occur from the combustion



of hazardous wastes).




     The following data illustrate the potential for such impacts



under current practices.  In 1976 there were, from sources other than




transport activities, approximately 4,000 spills of hazardous materi-




als (not generally wastes) reported under Section 311 of the Federal



Water Pollution Control Act (see Section 6.4.).  Over 1,300 of the




total reported spills (transportation and non-transportation related)



involved waste materials, primarily waste oil.  In 1976 in Ohio there



were another 160 reported spills involving potential air pollution




problems (this includes spills of both hazardous wastes and nonwaste




materials from storage and transportation).  Of the 160 reported




                                7-65

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spills, 39 involved hazardous air pollutants such as ammonia, chlo-

rine, acetone, hydrochloric acid, dimethoate, hexamethylene, para-

thion, vinyl chloride, propargyl alcohol, perchloroethylene, xylene,

butyl acrylate, titanium tetrachloride, chlorinated hydrocarbons,

hydrogen peroxide, ethyl ether, and nitric acid (State of Ohio,

1976).

     The following incidents identify some of the types of accidents

that have occured with a potential for releasing air pollutants.  Ad-

ditional examples of such incidents are discussed in the section on

treatment/disposal of hazardous wastes and in Appendix J.

     •  In 1973, a major chemical company in Virginia contracted with
        a processing firm in Alabama to pick up, haul, and dispose
        approximately 10,000 drums of aramite waste, containing 30 to
        80 percent sulfuric acid.  Most of the wastes were shipped in
        208 liter (55-gallon) steel drums and 190 liter (50-gallon)
        iber drums.  The wastes brought to Alabama were never proces-
        sed and remained in two open storage areas and in one en-
        closed warehouse.  Due to weathering, physical stress, and
        the corrosive and harsh nature of the wastes, many of the
        drums stored in the two open areas disintegrated and their
        contents spread over the adjacent ground.  In addition to
        contamination of local waters (chemical analysis of samples
        of drainage water from the storage site indicated very high
        acidity and high concentrations of heavy metals), the storage
        of waste at the three locations presented a great fire
        hazard.  On March 9 and 10, 1976, a fire broke out at the
        site, and two firefighters became ill, presumably due to
        inhalation of toxic fumes.

     •  At a land disposal site in Southern California, a tanker
        unloaded a waste listed as "waste acid" into a subsurface,
        bottomless tank through an open stack above the ground.
        Shortly after the unloading operation commenced, yellowish-
        brown clouds of nitrogen dioxide began to emanate from the
        open stack.  The reaction appeared to have subsided when the
        discharging of the wastes ceased.  However, an hour later,
        additional nitrogen dioxide started to spew from the stack.
        The emission was halted by filling the stack with soil.


                                 7-66

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        There were no reported injuries; however, there were many
        complaints from nearby businesses, and a factory was
        evacuated.

     •  The following incident while it did not involve wastes per
        se, illustrates the potential for combustion of wastes due to
        fire and the associated problems.  In April 1971, a fire
        occurred in the warehouse in Okanogen County, Washington,
        where about 2 tons of pesticides were stored, including
        guthion, parathion, endrin, dieldrin, DDT, and other chlori-
        nated hydrocarbons.  Nearly 50 tons of fertilizer were also
        stored in the building.  Toxic emissions from the burning of
        these chemicals forced the evacuation of nearby residents.
        Officials also feared the possibility of explosions caused by
        the fertilizers.  Nearly 2 million gallons of water were
        required to extinguish the fire.  Much of this water spilled
        into the street and flowed through gutters and storm sewers
        to the Okanogen River 1/2 mile away.  Endrin at a level of
        0.8 ppm was detected in the run-off into the river in early
        April.  Also, a city well about 500 feet from the fire site
        showed a nitrate concentration of 34.4 ppm in early June.
        Expectant mothers and small children were cautioned to avoid
        drinking the city water for a period of 2 weeks after the
        incident.

     The Subtitle C regulations contain provisions that should reduce

the potential for fires, explosions, and other accidents at hazardous

waste storage facilities and the potential for impacts from any acci-

dents that do occur.  For example, th.e Section 3004 regulations re-

quire that storage containers holding wastes that are incompatible

would have to be separated from each other or protected from each

other in order to prevent the wastes from mixing should the contain-

ers break or leak.  Storage areas would have to be constructed to

contain any spills that might occur.  Explosive, ignitable, or highly

reactive wastes (see Appendix B, Subpart A, Section 250.13) would not

be allowed to be stored in surface impoundments or basins.
                                 7-67

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Incompatible wastes would not be allowed to be mixed in storage



basins, nor in surface impoundments except for treatment purposes.




     One of the major causes of the mixing of incompatible wastes or



the improper storage of explosive, ignitable, or highly reactive




wastes has been the lack of accurate information about the waste



being provided to the waste handler (Office of Solid Waste, Hazardous




Waste Management Division, 1978a).  The manifesting and labeling




requirements under Section 3002 would make such information more



readily available and would further reduce the potential for



accidents from the improper storage of such wastes.




     In addition, owners/operators of storage facilities would have




to inspect storage areas daily for rust, corrosion, cracks, and



spills.  Also, hazardous waste storage facilities would have to




prepare contingency plans to minimize human health or environmental



damage in the event of an accidental discharge of hazardous materials



to the surrounding air, surface, or subsurface environment (see



Appendix B, Subpart D, 250.43-4).  To the extent that this latter re-




quirement and the spill containment requirement reduce the time



necessary to clean up spills or prevent additional accidental dis-




charges, there would be a reduction in air pollutants and resultant




impacts from any such accidental releases.  Furthermore, other



reductions in fugitive emissions, as previously discussed, would




reduce the potential for fires and explosions from such emissions,




especially from volatile wastes.






                                 7-68

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     A third source of air emissions are current practices in which

hazardous wastes are placed in storage for indefinite periods of

time; in many such cases the hazardous wastes are ultimately abandon-

ed rather than being disposed.  Such wastes may be stored in contain-

ers or may be stored in an open manner.  Due to such factors as

weathering and/or corrosion, containers eventually rupture or leak,

releasing their contents to the environment.  As discussed above,

volatile, flammable, or fine waste materials are the most likely

sources of air emissions following such releases.  Also, any such

releases increase the potential for the mixing of incompatible wastes

with the resultant consequences described above.  Wastes which were

not originally containerized would be subject to erosion and/or

volatilization during the time that they were in storage.

     Several incidents have previously been cited illustrating the

potential problems from indefinite storage of hazardous wastes (i.e.,

asbestos storage piles in Pennsylvania and aramite waste in Alabama).

The following incident further illustrates the potential problem:

     •  In 1971, a major chemical company in New Jersey contracted
        with an independent waste transporter to remove and dispose
        of 55-gallon drums containing petrochemical wastes.  The
        wastes included acrylonitrile, acetone, epichlorohydrin, and
        a number of other chemicals possessing toxic, flammable,
        explosive, and oxidizing properties.  A total of about 6,000
        of these drums were hauled away and were to be disposed of at
        a landfill.  However, approximately 4,500 of the drums were
        dumped by the transporter on a section of a former chicken
        farm in Dover Township, New Jersey.  The land had been leased
        to the transporter under the assumption that he was in the
        drum salvaging business and empty drums were to be stored
        there.  A few months later the owners detected unusual odors
        emanating from the leased land and discovered thousands of
        drums, many leaking, buried, and strewn about.  In 1974, it

                                7-69

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        was discovered chat an unknown portion of the Cohansey
        Aquifer, a major groundwater table aquifer,  had been con-
        taminated by the wastes (State of Minnesota, 1977).

     The proposed regulations contain provisions that should, to a

large degree, reduce the potential for air emissions that result from

the indefinite storage of hazardous wastes.  The Section 3004 regula-

tions require that at facility close-out, all hazardous wastes would

have to be removed from storage operations and disposed as required

under Subtitle C.  In addition, the manifest requirements under Sec-

tion 3002 would help to insure that wastes are delivered to permitted

facilities and not stored or abandoned in an environmentally unac-

ceptable manner.  It should be noted that acceptable treatment/

disposal methods would not necessarily exist for every hazardous

waste (see Chapter 5 for a discussion of wastes that have required

engineered storage in recent years), and any such wastes could have

to be stored for indefinite periods until treatment/disposal methods

were developed.  However, any such storage would have to be in com-

pliance with all the requirements previously discussed.  Based upon

Appendix D, large quantities of industrial wastes are known to be

stored in surface impoundments; such storage quite often constitutes

disposal.

     One other source of air pollutant generation common to all

hazardous waste management activities would be the construction of

necessary hazardous waste management facilities and related con-

junctive developments (e.g., roads, pipelines, power lines, reser-

voirs) .  To the extent that the Subtitle C regulations result in

                                 7-70

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modifications to or the construction of additional hazardous waste

storage, transportation, disposal, or treatment facilities, there

would be an increase in construction related air emissions.  The

major emissions would include exhaust from motor vehicles, including

construction equipment, and fugitive dust raised by such construction

activities as grading, excavation, and movement of equipment.

     Vehicle emissions during construction would consist primarily of

nitrogen oxides, hydrocarbons, and carbon monoxide.  The emission

levels would be extremely site-dependent.  The magnitude of fugitive

dust emissions would depend upon such factors as soil and terrain

characteristics, time of year, method of construction, size of the

area disturbed, and type of control measures utilized.  Cowherd et

al. (1974) summarized the available information on emissions from

fugitive dust sources and found that while activity levels signifi-

cantly influence emission rates, the relationship cannot be

quantified.

     Air Quality Impacts Relative to Transport of Hazardous Wastes.

Current practices in the transport of hazardous wastes have the

potential to release air emissions in three major ways:

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

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

     •  Through emissions resulting from the operation of the trans-
        port vehicle.
                                 7-71

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As discussed below, the Subtitle C regulations would affect, to

varying degrees, the potential for the release of air emissions from

each of these sources.  In addition, construction related air emis-

sions could be affected by construction and/or modification of trans-

portation facilities as a result of the Subtitle C regulations.

     There are several potential sources of fugitive emissions from

the transport of hazardous wastes.  These include emissions released

during the loading and/or unloading of hazardous wastes that have not

been containerized or that have not been properly covered and/or

containerized for transport.  Appendices D and E indicate that a

sizeable portion of hazardous wastes are typically transported

without being containerized.  Potential sources and types of fugitive

emissions from the loading, unloading, and transport of hazardous

wastes would be very similar to those discussed under storage and are

not repeated here.  In addition, solid hazardous wastes which are not

properly covered or containerized during transport would be subject

to wind erosion and would be a potential source of particulate matter

emissions.  Such particulate matter would be composed of the hazard-

ous waste material itself.

     Fugitive emissions during transport could result in adverse

impacts in the vicinity of the route of travel, as illustrated in the

following examples:

     •  A truck driver noticed that one of the drums he was hauling
        through the village of Mundelein was leaking titanium tri-
        chloride, a chemical that changes to an hydrocloric acid mist
        on contact with the air.  Fourteen people were hospitalized

                                7-72

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        for exposure to the fumes.  The four drums of chemicals were
        neutralized and buried (Office of Solid Waste, Hazardous
        Waste Management Division, 1978b).

     •  In the San Francisco Bay Area, an attempt was made to recover
        alkyl lead from organic lead wastes.  The wastes were trans-
        ported by truck to a recovery plant.  Toll collectors on a
        bridge along the truck route to the recovery plant became ill
        as a result of vapors escaping from the transporting truck
        (Office of Solid Waste Programs, 1974a).

     The regulations contain provisions that should, to some degree,

reduce the potential for fugitive air emissions from the transport of

hazardous wastes.  The Section 3002 regulations would require that

every generator containerize his hazardous wastes in accordance with

the Department of Transportation (DOT) regulations on packaging under

49 CFR 173, 178, and 179.  If no specific packaging is required, the

generator would have to place the hazardous waste in a package in

accordance with the DOT regulations on standard requirements for all

packages under 49 CFR 173.14(a), (b), and (c) (2-9).  Since the DOT

regulations currently apply only to interstate shipments of hazardous

materials, the effect of the Section 3002 regulations would be to ex-

tend the DOT regulations to interstate shipments of hazardous wastes

that are not identified as DOT hazardous materials and to most intra-

state shipments of hazardous wastes (about 27 states have adopted the

DOT Hazardous Materials Regulations in toto or have similar regula-

tions; about twelve others have adopted parts of the Hazardous

Materials Regulations).  According to a study by Arthur D. Little,

Inc. (1978a), about one-half of the hazardous wastes transporters

surveyed did not transport wastes across state borders.

                                 7-73

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     While the regulations do not contain specific provisions to

reduce fugitive air emissions from the loading and/or unloading of

uncontainerized wastes, nor from the placing of wastes in containers,

the air human health and environmental standard would reduce the

potential for the release of such emissions at permitted facilities.

     A second major source of air emissions from hazardous waste

transport are accidents which result in spills or other releases of

hazardous wastes.  The two most likely causes of such releases are

accidents involving the transport vehicle itself and explosions

occurring within the transport vehicle as the result of the mixing of

incompatible wastes.  Once the waste material has been released,

those wastes which are relatively volatile or which are composed of

fine particles are most likely to become sources of air emissions.

In addition, wastes which are ignitable can catch fire following an

accident and become the source of additional air emissions. Such

combustion can create additional hazardous air contaminants not

originally present in the waste itself and would serve to disperse

those air pollutants generated.

     The following incidents illustrate some of the types of air pol-

lutant problems that have occurred during hazardous waste transport:

     •  An industrial waste truck exploded in a truck bin on the Dan
        Ryan Expressway in Chicago spewing barrels of flames over
        cars and across all eight lanes of the roadway.  The chemical
        waste which exploded was believed to be sodium nitrate which
        was part of the load being carried by the truck (Office of
        Solid Waste, Hazardous Waste Management Division, 1978b.).

     •  In Richmond, California, a hazardous waste hauler mixed a
        liquid waste containing butyl acetate in xylene,  with an

                                 7-74

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        etching waste containing sulfuric acid, nitric acid, and
        hydrofluoric acid.  A hydrolysis reaction took place.  Pres-
        sure was generated in the tank, and the safety relief valve
        was blown off while the truck was travelling through a
        residential area.  A private residence was sprayed with the
        hazardous mixture.  No one was injured, but considerable
        clean-up was required (DeVera et al., 1977).

     The regulations contain provisions that should reduce the

potential for explosions and spills resulting from the mixing of

incompatible wastes during transport.  The Section 3003 regulations

contain the requirement that the transporter must load and stow

hazardous wastes so that those which are incompatible would not come

into contact with each other.  The Section 3002 requirement that

generators must label hazardous wastes and must furnish information

about the general chemical composition of each hazardous waste on the

manifest to be provided to the transporter would aid the transporter

in identifying incompatible hazardous wastes.  To the extent that

transporters can increase the identification of incompatible wastes

during transport, there would be a reduction in air incidents from

the mixing of hazardous wastes during transport.

     The baseline regulations do not contain provisions that would

directly reduce vehicular accidents, and subsequent spills, of

hazardous wastes during transport.  However, the regulations do con-

tain provisions that would reduce the potential for air emissions

following such accidents and spills.  The baseline regulations

require that the manifest provide either immediate response informa-

tion regarding what actions should be taken in an emergency situation

or a 24-hour telephone number for obtaining such information.  The

                                7-7~5

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manifest would also aid in identifying the general chemical compo-



sition of the spilled hazardous waste.  This information would likely



aid in cleaning up the spill.  To the extent that the time for clean-




up is reduced, the potential for the release of air emissions would



be reduced.  It should also be noted that any reduction in the mixing




of incompatible wastes would also result in a decrease in accidents




during hazardous waste transport and would result in fewer spills



generating air emissions.  Based upon an estimated spill rate of one




transportation-related spill per 37,500 metric tons of hazardous



waste transport (Office of Solid Waste, Hazardous Waste Management




Division, 1978a) and 40 million metric tons of hazardous industrial



waste generation in 1984, it is estimated that under the Subtitle C



regulations these could be on the order of 140 spills annually with




13 percent off-site treatment/disposal and on the order of 270 spills



with 25 percent off-site treatment/disposal.  Based upon a typical




transport vehicle size of '14.5 metric tons (Arthur D. Little, Inc.,



1978a), approximately 2000 to 4000 metric tons of hazardous wastes



could be involved in such spills.  Data are not available to estimate



potential air emissions likely to be released by such activities.




     The spill rate used above is based upon reported incidents from




the transport of hazardous materials which are predominantly not



wastes.  Such hazardous materials are currently subject to essential-




ly the same containerization, labeling, and placarding regulations as




would be required for hazardous wastes under the Subtitle C regula-



tions.  While the spill rate is a reasonable approximation of what




                                7-76"

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could happen under the Subtitle C regulations, it is not a reasonable



measure of what could happen without the Subtitle C regulations since




there would likely be a higher rate of spills due to improper con-




tainerization and to the mixing of incompatible wastes.  Thus, the




reduction in the number of spills under the Subtitle C regulations



cannot be estimated using this spill rate.




     Another major source of air pollutants from hazardous waste



transport are emissions from the transport vehicle itself.  To the



extent that the regulations shift hazardous waste transportation




patterns, there would be a change in the total amount of vehicle




emissions from hazardous waste transport.  At present, the relatively



high cost of long-distance transportation of hazardous wastes and the




lack of hazardous waste treatment and disposal regulations combine to




minimize the distances over which hazardous wastes are hauled.  As




discussed in Section 7.1.2.2, the regulations would likely increase




transport distances involved in hazardous waste management.




     Table 7-8 presents estimates of the potential magnitude of the



change that could occur in vehicular emissions in 1984 as a result of




promulgation of the Subtitle C regulations.  The estimates are




presented for both 13 and 25 percent off-site shipment of hazardous



wastes in 1984 (see section 7.1.2.4).  Since data are not available




to determine the average transport distances likely to occur in 1984



under the regulation, the potential change in emissions is estimated




for four possible transport distances.






                                7-77

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                      TABLE 7-8

ESTIMATED CHANGE IN VEHICULAR EMISSIONS IN 1984 FROM TRANSPORT
OF HAZARDOUS INDUSTRIAL WASTES UNDER SUBTITLE C REGULATIONS

Change in emissions (metric
Average
Wastes round- trip
transported distance
off-site (miles)
13 percent 100
^ 200
i
00 500
1,000
25 percent 100
200
500
1,000


Carbon monoxide

-160
880

4,000
9,100
. 780
2,800
8,700
18,600


Hydrocarbons

-20
140

630
1,500
120
440
1,400
3,000

Nitrogen
oxides

-110
640

2,900
6,600
540
2,000
6,300
13,500
tons)


Particulates

-10
40

180
410
40
120
390
840


Sulfur
oxides

-20
90

390
890
80
270
850
1,800

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     The estimates in Table 7-8 are determined as follows.  According



to the hazardous waste transportation study by Arthur D. Little, Inc.



(1978a), most hazardous wastes shipped off-site are currently trans-




ported by truck with typical reported transport distances of 50 miles




(100 miles round trip) and typical vehicle capacities of about 14.5




metric tons (18 tons).  Typical on-site transport distances are about



two miles round trip.  These typical transport distances are assumed



to be the baseline for estimating the changes in vehicular emissions.



The change in the quantity of hazardous wastes transported on-site




and off-site on an annual basis in 1984 is determined as discussed in



Section 7.2.5.  The estimated change is a decrease of 0.8 million



metric tons in off-site shipments in the case of 13 percent off-site




treatment/disposal and an increase of 4.0 million metric tons in




off-site shipments in the case of 25 percent off-site treatment



disposal.  The change in the number of off-site and on-site hazardous




waste shipments is determined based upon the typical vehicle capacity



of 14.5 metric tons.  For each of the four selected 1984 transport



distances, the change in emissions is estimated based upon emission




factors for heavy duty, diesel-powered trucks (U.S. Environmental




Protection Agency, 1977a).



     For purposes of comparison, total U.S. emissions of carbon




monoxide, hydrocarbons, nitrogen oxides particulates, and sulfur



oxides were 85.7, 26.1, 22.0, 14.3, and 25.9 million metric tons,



respectively, in 1975.  Total U.S. area emissions from heavy-duty



diesel powered vehicles in 1975 were 0.7, 0.2, 1.5, 0.1, and 0.2





                                7-79

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million metric Cons of carbon monoxide, hydrocarbons, nitrogen ox-

ides, particulates, and sulfur oxides, respectively (U.S. Environ-

mental Protection Agency, 1978a).  The emissions in Table 7-8 for the

1,000-mile round-trip distance with 25 percent off-site treatment/

disposal represent an increase of less than 0.06 percent in each of

the total U.S. emissions and of less than 3 percent in each of the

total U.S. area emissions from heavy-duty, diesel-powered vehicles.

The emissions for the 100-mile round-trip distance with 13 percent

off-site treatment/disposal represent a decrease of less than 0.0005

percent in each of the total U.S. emissions and of less than 0.02

percent in each of the total U.S. area emissions from heavy-duty,

diesel-powered vehicles.

     Air Quality Relative to Treatment/Disposal.  The major sources

of air emissions from current hazardous waste treatment/disposal

practices are as follows:

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

     •  Emissions generated by explosions, fires, and other
        accidents;

     •  Residuals from the combustion of hazardous wastes by
        incineration or open burning;

     •  Fugitive emissions from other treatment activities;

     9  Fugitive emissions from facility construction or
        modification.*
*These fugitive emissions are discussed under storage and are not
 repeated in this section.
                                7-80

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The Subtitle C regulations would affect the potential for release of



air emissions from each of these sources as discussed below.



     Such land-based activities for the treatment/disposal of hazard-



ous wastes as landfills, landfarms and surface impoundments currently




release air contaminants through several mechanisms.  Activities



which result in soil disturbance, such as excavation, trenching,




covering, grading, and compaction, generate fugitive dust.  The



magnitude of fugitive dust emissions depends upon such factors as



soil and terrain characteristics, time of year, type of equipment



utilized, size of the area disturbed, and type of control measures




employed.  Vehicles and equipment used in land disposal are a further



source of emissions from such activities, as previously discussed.




Fugitive emissions also occur when the hazardous waste is initially



being deposited 'in the treatment/disposal site.  Such fugitive




emissions usually consist of the waste and/or its constituents and



would be similar to those previously discussed under storage and



transportation.



     Following placement of the waste in the treatment/disposal




site, gaseous materials that are potentially hazardous are often gen-



erated and released under current practices.  Such emissions general-



ly result from volatilization, sublimation, chemical reaction, and/or




decomposition of the wastes.  The rate of generation and release of



such gaseous materials is a function of many factors including the



nature, water content, and depth of any cover material; chemical




characteristics and composition of the waste materials; and




                                7-81

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temperatures in the treatment/disposal site and temperature of the

waste.  With regard to volatilization, numerous instances of air

pollution problems have been reported under current practices, as

indicated below:

     •  An industrial solvent reprocessing firm in Maryland dumped
        large quantities of volatile organic liquid wastes, con-
        taining benzene, carbon tetrachloride, acetones, ketones,
        mythelene chloride, and other solvents into a sand and gravel
        quarry.  The wastes, even though volatile, were often left
        open in an evaporating pool before, being covered.  Many of
        the solvents contained in the waste were detected in signifi-
        cant concentrations in the air in the vicinity of the quarry
        (see Section 7.1.6, Public Health) (Office of Solid Waste,
        Hazardous Waste Management Division, 1978b).

     •  In July 1977 several truckloads of organohalides, amines, and
        hydrocarbons were dumped by a waste disposal firm at a
        disposal site near San Francisco, California.  The wastes
        were deposited in an evaporation pond, where they soon
        floated to the top and began to evaporate.  A visible and
        odoriferous plume of white mist hovered over the area for
        several hours, provoking nausea and other complaints from
        residents downwind of the site.  At least one building in
        the area had to be evacuated (Office of Solid Waste,
        Hazardous Waste Management Division, 1978b).

     Air quality problems from existing land disposal practices are

also associated with the products of chemical and microbial transfor-

mations.  Chemical reactions from the mixing of incompatible wastes

have occurred on numerous instances and are described in the subse-

quent discussion of explosions, fires, and accidents.  The disposal

of organic wastes can produce gases through the decomposition and

chemical reaction of the waste material.  Gases produced usually

include methane, carbon monoxide, carbon dioxide, hydrogen, and

oxygen.  Most studies of gas generation through decomposition of

organic wastes have focused only on municipal solid wastes.  Streng

                                 7-82

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(1976) is studying the effects on gas production from the codisposal

of six industrial wastes with municipal solid wastes.  Table 7-9

shows the gas composition data measured in the six industrial waste

test cells and one municipal solid waste test cell at the time of the

report.  According to Streng, most of the study cells were progres-

sing from an anaerobic nonmethanation stage to the early phases of

methanation at the time of the report.  However, the addition of re-

finery wastes to the municipal solid wastes appeared to have sped up

the decomposition of the municipal solid wastes and the resultant

production of methane.  In a later report, Streng (1977) noted that

the test cell containing the mixture of the solvent based paint

sludge and municipal waste produced less than the theoretical minimum

amount of gas expected to have been generated, indicating that this

industrial waste exerted an adverse effect on gas production.

     Migration of methane and other combustible gases resulting from

current landfill practices has caused explosions and other problems.

For example:

     «  A landfill in Deck Quarry, Montgomery County, Pennsylvania
        accepted municipal and industrial wastes until it closed in
        1969.  Two explosions and the contamination of residential
        drinking water resulted from the generation of methane gas
        and its migration through rock fractures.  Residents have had
        to evacuate their houses permanently (Office of Solid Waste,
        Hazardous Waste Management Division, 1978b).

     •  Migration of gases from a landfill containing household and
        industrial wastes, along with sewage sludge, resulted in the
        deaths of over 70 peach trees in Glassboro, New Jersey be-
        tween 1971 and 1975.  Combustible gases and carbon monoxide
        were found along with low oxygen concentrations in the root
        zones of the trees up to 24 meters (80 feet) from the land-
        fill (Flower, 1976).  Many similar cases, some with the

                                 7-83

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                                                TABLE 7-9

                                           GAS COMPOSITION DATA*'
                    Study cell contents^           QŁ      N2      City     C0Ł      H2
oo
Municipal solid waste only
Refinery sludge
Battery reproduction waste
Electroplating waste
Inorganic pigment waste
Chlorine production
brine sludge
Solvent based
paint sludge
0.3
0.2
1.1
0.3
0.2
0.1

0.4

29.9
26.4
22.3
16.4
2.9
16.6

47.0

0.0
17.1
0.0
1.1
0.0
0.0

4.9

69.2
56.1
76.5
81.9
96.9
83.3

41.0

0.0
0.0
0.0
0.0
0.0
0.0

6.4


                    *Streng,  1976.
                    tPercent  of  gas  produced  by volume.
                    ^Contents In addition  to  municipal solid waste.

-------
        potential for explosions affecting homes have also been re-
        ported for municipal landfills (Flower et al., 1976, 1977;
        DeGeare, 1976; James, 1977).

     The Subtitle C regulations contain requirements that should re-

duce the potential for fugitive emissions from the land-based treat-

ment/disposal of hazardous wastes.  For example, the Section 3005

regulations would require that all hazardous waste treatment/

disposal facilities obtain a permit before construction and opera-

tion.  To obtain and keep a permit, treatment/disposal facilities

would have to comply with the applicable Section 3004 air regula-

tions.

     The objective of the Section 3004 air regulations would be to

insure that treatment/disposal facilities are located, designed, con-

structed, and operated in a manner such that air emissions from such

facilities do not adversely affect human health or the environment.

The air regulations applicable to non-point emission sources (e.g.,

landfills, landfarms, and surface impoundments) would consist of two

sets of requirements:  mandatory standards with which all facilities

must always comply and air human health and environmental standards

which would be applicable, on a case-by-case basis, only when there

is reason to believe (e.g., a third party challenge) that the manda-

tory standards are insufficient for human health and environmental

protection.  If a facility is in compliance with all applicable man-

datory standards, it would be assumed to be in complaince with the

air human health and environmental standards; the burden of proof
                                7-85

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would be on the permitting authority to show that the facility was



actually in violation of the air human health and environmental




standard.




     The air human health and environmental standard would require




that non-point sources of air emissions not contribute any listed air




contaminant (see Appendix B, Subpart D, Annex 2) to the atmosphere,



at the surface of the non-point source, in concentrations exceeding



the listed Threshold Limit Value (TLV) for that contaminant, nor con-




tribute two or more listed air contaminants in a manner which causes



the sum of the individual concentrations divided by the individual




TLV's to exceed unity.  Examples of air contaminants from the pre-



viously discussed incidences to which the air human health and




environmental standard could apply include acetone, asbestos, ben-




zene, carbon monoxide, carbon tetrachloride, methane, and methylene



chloride.  However, the application of this standard could occur only



after the standard was violated; it would not be a means to initially




prevent release of air contaminants in violation of the standard.



The mandatory standards discussed below would, however, prevent the



initial occurrence of most such incidents.




     All facility owners/operators would have to obtain an analysis




of each type of waste to be treated/disposed for the purpose of iden-



tifying the principal hazardous components and characteristics of the



waste so as to enable the waste to be treated/disposed in compliance



with the Section 3004 requirements.  All owners/operators would also




have to sample waste shipments or batches received to confirm that




                                7-86

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the contents match the previous analysis.  Owners/operators of all

treatment/disposal facilities would also have to visually inspect the

facility daily to determine if there were any fugitive emissions.

     Volatile wastes—those with a true vapor pressure greater than

78 mm mercury at 25 C—would not be allowed to be treated/disposed in

landfills, surface impoundments, or basins; such wastes could be

landfarmed only if the facility owner/operator could demonstrate, be-

fore landfarming the wastes, that the air human health and environ-

mental standard would not be violated.  Examples of air contaminants

from the previously discussed incidents which have vapor pressures

greater than 78 mm mercury at 25 C and which could not be treated/

disposed under the Subtitle C regulations in the manner that caused

the indicated incidents include acetone, benzene, carbon tetrachlor-

ide, methylene chloride, and vinyl chloride.

     With regard to wastes that are landfilled, a minimum of 0.15

meters (6 inches) of cover material would have to be applied daily on

active hazardous waste landfill cells.  Cells which do not have addi-

tional wastes placed in them for at least one week would have to be

covered with 0.3 meters (12 inches) of material.*  Where gases are

generated, a gas collection and control system would have to be in-

stalled in most instances to control the vertical and horizontal

escape of gases.  At facility closure, a final cover of at least 0.15
^Different thicknesses or rates of application could be used if the
 owner/operator could demonstrate that the air human health and envi-
 ronmental standard would not be violated.

                                7-87

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meters of clay soil under a minimum cover of 0.45 meters (18 inches)

of soil would have to be provided.*  The facility would also have

to be secured such that discharges of wastes harmful to human health

or the environment would not occur.  These requirements would reduce

air emissions that occur under current landfill practices which often

do not employ such measures (see Appendix J).

     For example, emissions of hexachlorobenzene wastes are reported

to be reduced from 317 kilograms per hectare per year when disposed

uncovered to 4.564 kg/ha/yr. when covered with 0.02 meters of soil

and to 0.07 kg/ha/yr. when covered with 1.2 meters of soil (Farmer et

al., 1976).  Other studies, however, have indicated that even cover-

ing some wastes may,not completely prevent the release of air emis-

sions.  A study by Markle et al. (1976) indicated background air

concentrations of about 0.1 to 0.3 ppm VCM exist at landfills where

PVC sludge has been disposed for several years.  Peak concentrations

on the order of 1.0 ppm VCM were observed at normal breathing heights

as long as 24 hours after the PVC sludge deposits were covered.  The

required gas collection and control system could remove such emis-

sions as well as volatile gases generated by waste decomposition,

including methane and carbon monoxide.
^Different thicknesses or rates of application could be used if the
 owner/operator could demonstrate that the air human health and envi-
 ronmental standard would not be violated.
                                 7-88

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     With regard to surface impoundments, the Subtitle C regulations



would require that there be no discharges to the ambient air unless




the facility owners can demonstrate, before treatment/disposal, that




any discharges would not violate the air human health and environmen-




tal standard.  Furthermore, at the time of closure, all hazardous




wastes and waste residuals would have to be removed from surface



impoundments which do not meet the requirements for landfills.  Also



after closure, surface impoundments would have to be secured such




that discharges of wastes harmful to health or the environment would



not occur.



     It should be noted that the Subtitle C regulations do not cover



all types of potentially hazardous fugitive air emissions from land-



based treatment/disposal.  The air human health and environmental




standards only apply to those emissions for which there are TLV's




listed in Appendix B, Subpart D, Annex 2.  Other emissions which



could consist of the hazardous waste itself or various hazardous



constituents (e.g., trichloroethane) would not be subject to any




emission standards.  There are also no specific requirements aimed at



reducing fugitive dust emissions from treatment/disposal activities




which result in soil disturbance.



     Explosions, fires, and other accidents represent another major



source of air contaminants resulting from current hazardous waste



treatment/disposal practices.  The primary causes of most such



explosions and fires have been the mixing of incompatible wastes and
                                7-89

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Che improper treatment/disposal of ignitable or reactive wastes.

Often wastes involved in such accidents are those whose identity or

nature were not known prior to treatment/disposal.  Resultant fires

have led to the creation, release, and dispersion of additional air

pollutants which have threatened persons living or working in the

vicinity of the treatment/disposal facility.  Appendix M describes

types of emissions that can result from the combustion of hazardous

wastes.  A less obvious danger of fire occurring within an under-

ground storage or disposal cell is the possibility of destruction of

liners meant to protect groundwater.  While this has not been docu-

mented, since most liner materials cannot withstand temperatures in

excess of 150 to 200 C (300 to 400 F) it is theoretically possible

(Office of Solid Wastes, 1977d).

     Numerous instances of fires and explosions have been reported at

hazardous waste disposal areas.  The incidents presented below illus-

trate some of these occurrences and the subsequent problems.

     •  At a sanitary landfill near Dundalk, Maryland, a 2,000-gallon
        liquid industrial waste load containing iron sulfide, sodium
        sulfide, sodium carbonate, and sodium thiosulfate, along with
        smaller quantities of organic compounds was discharged into a
        depression on top of an earth-covered area of the landfill.
        When it reached eight to ten feet below the point of dis-
        charge, the liquid started to bubble and fume blue smoke.
        The smoke cloud quickly engulfed the truck driver and dis-
        abled him.  Several nearby workers rushed to his aid and were
        also felled.  During the clean-up operation, one of the coun-
        ty firefighters also collapsed.  All six of the injured were
        hospitalized and treated for hydrogen sulfide poisoning.  It
        was not determined whether the generation of hydrogen sulfide
        was due to the instability of the waste or the incompatibil-
        ity of the waste with some of the landfill material (De Vera
        et al., 1977).


                                  7-90

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     •  At a dump in Contra Costa County, California, a large number
        of drums containing solvents were deposited in a landfill.
        In the immediate area were leaky containers of concentrated
        mineral acids and several bags containing beryllium wastes in
        dust form.  The operators failed to cover the waste at the
        end of the day.  The acids reacted with the solvents during
        the night, ignited them, and started a large chemical fire.
        There was possible dispersion of potentially hazardous beryl-
        lium dust (De Vera et al., 1977).

     •  In Los Angeles County, a tank truck emptied several thousand
        gallons of cyanide waste onto refuse at a sanitary landfill.
        Another truck subsequently deposited several thousand gallons
        of acid waste at the same location.  Reaction between the
        acid and the cyanide evolved large amounts of toxic hydrogen
        cyanide gas.  A potential disaster was averted when a local
        chlorine dealer was quickly called to oxidize the cyanide
        with chlorine solution (De Vera et al., 1977).

     •  A load of empty pesticide containers was delivered to a dis-
        posal site in Fresno County, California.  Unknown to the site
        operator, several full drums of an acetone-methanol mixture
        were included in the load.  When the load was compacted by
        a bulldozer, the containerized waste ignited, engulfing the
        bulldozer in flames.  The ensuing fire involved dispersion of
        pesticide wastes (Office of Solid Waste, Hazardous Waste Man-
        agement Division, 1978b).

     •  A disposal site in central California accepted a load of
        solid dichromate salts and dumped it in a pit along with pes-
        ticide formulations and empty pesticide containers.  For sev-
        eral days thereafter, small fires erupted in the pit due to
        the oxidation of the pesticide .formulations by the dichro-
        mate (De Vera et al., 1977).

     •  In October 1974, a bulldozer operator was killed in an ex-
        plosion at an industrial landfill in Edison Township, New
        Jersey, as he was burying and compacting several 55-gallon
        drums of unidentified chemical wastes.  The victim died as a
        result of burns covering approximately 85 percent of his body
        (Lazar, 1975).

     The Subtitle C regulations contain provisions that should, to a

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

accidents at hazardous waste treatment/disposal facilities.  For
                                 7-91

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example, one of the major causes of many such accidents has been the




lack of accurate information about the identity or nature of the




wastes being treated/disposed (Office of Solid Waste, Hazardous Waste




Management Division, 1978a).  The manifesting and labelling require-




ments under Section 3002 would make such information readily avail-




able.  The requirement that facility owners/operators obtain an




analysis of each type of waste handled from every source (e.g.,




generator) would enable a prior determination of how the waste should




be treated/disposed.  The requirement that the facility owner/opera-




tor sample shipments or batches received to confirm that the contents




match the initial analysis would reduce the possibility of improper




handling due to undetected changes in the waste composition.  Fur-




thermore, the requirement for training of all personnel in hazardous




waste management procedures relevant to the facility operation would




make such employees less likely to handle or mix wastes in a manner




that could cause fires or explosions.




     Incompatible wastes, both containerized and non-containerized,




would also have to be disposed in separate landfill cells.  Landfarms




would have to be constructed and operated such that potentially in-




compatible wastes do not come in contact.  Incompatible wastes would




not be allowed to be mixed in surface impoundments and basins, except




for treatment purposes, providing the treatment does not violate the




air human health and environmental standard.  Furthermore, highly




reactive or ignitable wastes, as defined in Appendix B, Subpart A,






                                  7-92

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would not be allowed to be disposed in landfills, surface impound-



ments, basins, or landfarms.  Appendix B, Subpart 0, Annex 4 lists




examples of incompatible wastes.  Appendix C describes potential



sources generating many of these potentially incompatible wastes.




Examples of wastes identified as potentially hazardous due to reac-




tivity or ignitability (see Appendix C, Subpart D, 250.14) which have




been disposed in landfills, landfarms, and surface impoundments in



the past include slop oil emission solids and DAF sludge from petro-



leum refining (see Table D-7); semisolid wastes from toluene diisocy-




nate production (see Table D-5); and solvent and still bottom wastes



from the textile, paint, organic chemicals, special machinery manu-




facturing, and electronic components industries (see Tables 0-1, D-4,



D-5, D-14, and D-15).



     Hazardous waste treatment/disposal facilities would have to



prepare contingency plans to minimize human health or environmental



damage in the event of an accidental discharge (see Appendix B, Sub-




part D, 250.43-4 for specific requirements).  To the extent that the



contingency plan would reduce both the spread of the discharge with a



resultant reduction in the possible mixing of incompatible wastes and




the time required to stop and clean up the discharge, there would be



a reduction in the release of air contaminants and resultant impacts



from such accidental discharges.



     The intentional combustion of hazardous waste as a method of



treatment, energy recovery, or disposal represents another major



source for the release of air emissions.  The combustion of wastes




                                7-93

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typically occurs either as open burning or as controlled or uncon-




trolled incineration.



     Open burning is defined under Subtitle C as the combustion of




any material without control of combustion air to maintain adequate



temperature for efficient combustion, containment of the combustion-



reaction in an enclosed device to provide sufficient residence time



and mixing for complete combustion, or emission of the gaseous com-




bustion products through a stack or vent adequate for both visual



monitoring and point source sampling.  Open burning of hazardous



waste results in the uncontrolled release of hazardous gases and



particulate matter (see Appendix M for potential emissions from com-



bustion of hazardous wastes).  In addition, open burning may result



in the release of smoke (i.e., particulate matter) which can inter-




fere with visibility. For example, smoke from open burning in a dump



resulted in a chain accident on the New Jersey Turnpike several years



ago (Lazar, 1975).  Open burning is being phased out as a method of



most hazardous waste disposal due to implementation of the Clean Air



Act.  It should be noted that open burning is currently used by the



military to dispose of explosive wastes which cannot be incinerated




or treated by other means (Shapira et al., 1978).  Open burning is



currently the method most commonly used for such disposal (TRW, Inc.,



1976).




     Incineration is defined by Subtitle C as an engineered process




using controlled flame combustion to thermally degrade materials






                                  7-94

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(e.g., hazardous wastes).  Devices normally used for incineration

include rotary kilns, fluidized beds, and liquid injectors (see

Appendix D).  To the extent that incineration produces an ash or re-

sidue which is hazardous under Section 3001, incineration is a treat-

ment method (e.g., volume reduction) rather than a disposal method.

     It is estimated that in the period from 1973 to 1975, over 15

percent of the hazardous wastes from 14 selected manufacturing indus-

tries were incinerated or open burned with over 60 percent of this

incineration and open burning being uncontrolled (Office of Solid

Waste, unpublished data).  It should be noted that the percentage of

controlled incineration is likely to be higher now due to require-

ments of the Clean Air Act, as amended.  Tables 5-8 and 5-9 show the

portion of hazardous wastes estimated to be incinerated by selected

manufacturing industries during this period.  Data are not available

to estimate the quantity of air emission released by such incinera-

tion of hazardous wastes.

     In addition to the release of potentially hazardous emissions,

incineration of volatile, flammable, or explosive wastes have led to

many instances of explosions and fires in the past:

     •  The Harrisburg, Pennsylvania incinerator, for example, has
        experienced explosions in both 1972 and 1975 as a result of
        the incineration of hazardous wastes (Office of Solid Waste,
        Hazardous Waste Management Division, 1978b).

     Appendix M contains a detailed discussion of destruction effi-

ciencies achieved for the incineration of selected hazardous wastes,

potential air residuals from such incineration, and the nature of

                                  7-95

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solid residuals produced by the incineration.  Based upon this dis-




cussion, a vast number of different hazardous waste materials, rep-



resenting a broad spectrum of physical and chemical characteristics,




can be essentially destroyed or used for energy recovery by inciner-



ation.  Generally speaking, organic materials are the prime candi-




dates for incineration.  The amount of destruction of any specific




hazardous waste is dependent to a large extent on the relationship of



incineration temperature to dwell time (residence time in the incin-




erator) at that temperature and to a lesser extent on turbulence in




the combustion zone and the amount of excess oxygen available.  The



higher the temperature used, the shorter the dwell time necessary to



achieve a given destruction ratio.  As a general rule, the principal




components of most organic hazardous materials can be virtually com-



pletely destroyed at 1000 C (1830 F) with a dwell time of 2 seconds.



Many are destroyed at lower temperature/dwell time conditions; a few




require more rigorous conditions.  However, the knowledge of specific



incineration criteria for individual wastes is very limited.



     Very limited information is also available as to the fate of



hazardous waste constituents produced by the incineration.  Most




studies of emissions from the incineration of hazardous wastes have



considered only the fate of the gross components of combustion, com-




ponents for which regulations have been promulgated, or components



for which historical data have been accumulated regarding harmful ef-



fects.  Most studies have not given consideration to emissions which






                                  7-96

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result from side reactions, such as the formation of polynuclear aro-



ma tics (PNA's) from the incineration of wastes containing chlorinated




hydrocarbons, nor to the constituents of particulate matter entrained



in stack gases.  Also, little is known about the potential health




effects from long-term, low-level exposure to many of the gaseous and



particulate products of hazardous waste combustion.




     The Subtitle C regulations contain provisions that should reduce



the potential for the release of air contaminants from the combustion




of hazardous wastes.  As indicated, in recent years over 60 percent



of the hazardous wastes that were burned (either by incineration or




open burning) were burned in an uncontrolled manner.  The Subtitle C



regulations would require the use of controls for almost all combus-




tion of hazardous wastes and would set standards for the release of




many air contaminants.  Open burning of hazardous wastes would be



prohibited unless the facility owner/operator could demonstrate prior



to such open burning that the air human health and environmental



standard would not be violated.  All facilities would also be re-



quired to comply with all applicable standards of the Clean Air Act,



as amended, in order to maintain their permits.




     The regulations also would set specific standards for the incin-



eration of hazardous wastes.  Incinerators used to thermally degrade



hazardous waste containing more than 0.5 percent halogens would be



required to be equipped with wet scrubbers capable of removing 99



percent of the halogens from the exhaust gases.  Incinerators used to
                                 7-97

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burn pesticide wastes or wastes which are hazardous due to toxicity



would be required to maintain greater than a 1000 C combustion zone



temperature, greater than 2 seconds retention, and greater than 2



percent excess oxygen during incineration.  Such incinerators, except




for pathological incinerators, would also be required to be designed,




constructed, and operated to maintain a destruction efficiency of



99.99 percent of the principal toxic components of the pesticide or




toxic waste going into the incinerator.  All incinerators would be




required to be operated at a combustion efficiency equal to or great-




er than 99.9 percent.  All hazardous waste incinerators would also be



required to be operated in a manner that assures that emissions of




particulate matter do not exceed 270 milligrams per dry standard



cubic meter (0.12 grains per dry standard cubic foot) at zero excess




air.  Compliance with this latter requirement could be achieved by



having particulate emissions that when corrected to 12 percent carbon




dioxide are le~ss than 180 milligrams per standard cubic meter (0.08



grains per dry standard cubic foot).



     In addition, incinerators would have to be designed, construc-



ted, and operated such that fugitive emissions of unburned hazardous




waste and combustion products are controlled and such that waste feed



is automatically cut off if significant changes occur in flame, com-




bustion zone temperature, excess air, or scrubber water pressure.



Also, owners/operators of hazardous waste incinerators would be




required to conduct trial burns for each hazardous waste that is






                                  7-98

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significantly different than any one previously demonstrated under



equivalent conditions.  The trial burn would have to include:  an



analysis of the exhaust gases for concentrations of the principal



hazardous components, hydrogen halides, carbon monoxide, carbon diox-




ide, excess oxygen, and total particulates; an analysis of the ash



residue and scrubber effluent for the principal hazardous components;



an identification of sources of fugitive emissions and their means of




control; a measurement of the combustion temperature; and a computa-



tion of residence time, combustion efficiency, destruction efficien-



cy, and scrubber efficiency in halogen removal.




     Data are not available to estimate the extent to which the above



regulations would reduce the overall release of specific air emis-



sions from hazardous waste incineration.  Any reduction would depend




upon such factors as changes in types and quantities of hazardous



wastes incinerated, changes in the types of incinerators utilized,




and changes in control devices employed.  As previously indicated,




ignitable, volatile, and reactive wastes would, for the most part, be




prohibited from landfills, landfanns, and surface impoundments.  It



is likely that a large portion of such wastes would be incinerated as




an alternative means of treatment/disposal under the Subtitle C regu-



lations.  Such a shift would likely result in the increased release




of combustion products from these wastes, but would also reduce the



release of other emissions, such as particulates and volatile gases,



that would have occurred from land disposal of these wastes.  There






                                 7-99

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would also be other shifts in the types of methods used to treat/



dispose other wastes under Subtitle C regulations compared to current



practices.  All such shifts could either enhance or reduce the poten-



tial for reductions in specific air emissions under the Subtitle C




regulations.  Furthermore, the construction of new facilities could



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



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




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




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



both a localized and/or nationwide reduction in the total release of




many air contaminants from hazardous waste management and a localized




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



This could cause both localized improvements in air quality and some




localized degradation of air quality; however all emissions and any



localized degradation would have to be in compliance with all applic-



able standards (e.g., Clean Air Act, OSHA Standards, RCRA Standards,




State Standards).



     It should be noted that the incineration standards set limits



only for the destruction of the principal toxic components of the




waste feedstock and on the emission of halogens and total particu-



lates.  As indicated in Appendix M, combustion of hazardous wastes



can also generate and release other combustion products such as cya-




nides, sulfur compounds, hydrochloric acid, trace metals, nitriles,



ammonia, pyrophosphates, cyanogen, polycyclic hydrocarbons,






                                 7-100

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polynuclear aromatics, and other organics.  While the regulations re-

quire that such combustion products from incineration be controlled,

no standards are set for such control.   Thus, such combustion

products would still likely be released, but in quantities less than

those that would occur without the subtitle C regulations.  Further-

more, there could be small releases of the hazardous waste and/or its

principal toxic components; up to 0.01 percent of the principal toxic

components originally present in the waste could be released.  Little

is currently known about the potential for adverse health effects or

environmental effects from long-term, low-level exposure to such

potential emissions from hazardous waste combustion.

     Appendix M also indicates that while 99.99 percent destruction

has been demonstrated for many hazardous wastes, such destruction ef-

ficiencies have not yet been reported to have been demonstrated for

most hazardous wastes.  Furthermore, in spite of the impressive per-

formances of the incinerators reported in the literature in destroy-

ing hazardous wastes, it should be noted that most studies were per-

formed under extremely controlled conditions and only specific

products of combustion were sampled in many cases.  Problems could
                                     /
occur due to requirements for frequent maintenance and extensive
*For example, as indicated in Appendix M, hydrogen cyanide is
 generated from the destruction of nitrogen-containing pesticides.
 Temperatures much higher than those required for 99.999 percent de-
 struction of the nitrogen-containing pesticide are needed for de-
 struction of this hydrogen cyanide.
                                 7-101

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operator education in order to ensure proper functioning.  Mainte-

nance could be an especially serious problem since many wastes burned

in incinerators are either extremely caustic or produce caustic

products when burned.

     Other types of hazardous waste treatment constitutes a further

source for the release of potential air contaminants.  Such treatment

can be classified as biological treatment, physical treatment, or

chemical treatment (see Appendix D).  Fugitive emissions represent a

major source of emissions from such treatment.  The potential for the

release of fugitive emissions during treatment would be similar to

that previously discussed and is not repeated here.  In addition,

some chemicals and/or reagents used in treatment processes are poten-

tial sources of fires and/or explosions if not properly stored and/or

handled.  The combustion of fuel to provide steam or energy to treat-

ment processes is another source of emissions, primarily particulate

matter, sulfur oxides, nitrogen oxides, carbon monoxide, and hydro-

carbons.  The burning of coal could also result in aldehydes and

trace elements being emitted.  The following two incidents indicate

potential problems from hazardous waste treatment processes (other

incidents from treatment have been previously indicated):

     •  Organic lead waste from manufacturing processes for alkly
        lead in the San Francisco Bay area had been disposed in ponds
        at an industrial waste disposal site.  Attempts to process
        this waste for recovery resulted in alkyl lead intoxication
        of plant employees in one case.  In another instance, not
        only were plant employees affected, but employees of firms in
        the surrounding area were exposed to an airborne alkyl lead
        vapor hazard.  Toll collectors on a bridge along the truck


                                 7-102

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        route to the plant became ill from escaping vapors from
        transport trucks (Office of Solid Waste Management Programs,
        1974a).

     •  The Air Compliance Division of the Connecticut Department of
        Environmental Protection closed down two organic solvents re-
        covery operations in Southington, Connecticut due to air pol-
        lution caused by incineration of the wastes.  A similar oper-
        ation in Beaver Falls, Connecticut was also closed due to air
        pollution problems (Office of Solid Haste, Hazardous Waste
        Management Division, 1978b).

     The Subtitle C regulations contain provisions that should reduce

the potential for fugitive emissions from hazardous waste treatment

processes.  Most of these provisions and potential impacts have pre-

viously been discussed under storage, treatment, and disposal and are

not repeated here.  Additional requirements include the need for the

treatment facility to demonstrate the capability to handle hazardous

wastes during facility or equipment breakdown and for all continuous

feed facilities to be equipped with an automatic waste feed cut-off

or by-pass system which is activated when a malfunction occurs.  All

hazardous wastes would have to be analyzed prior to selection of a

treatment process to determine if the waste contains components or

contaminants which could cause the uncontrolled release of toxic

gases or fumes or which could form highly toxic components with

treatment chemicals or reagents.  These requirements in conjunction

with the previously discussed requirements would reduce the potential

for air emissions from hazardous waste treatment.  However, any

increased treatment occurring as a result of promulgation of the Sub-

title C regulations could offset the potential for such reductions to
                                 7-103

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an unknown degree.  There could also be other offsetting reductions




in the release of air emissions if the treatment reduced the quanti-




ty of wastes requiring disposal.



     7.1.4.2  Climate.  The potential effect of specific actions on




global, regional and local climates is not well understood at pres-




ent.  As a result, very few conclusions can be drawn as to the effect



of various hazardous waste management related actions on the climate.




Furthermore, even for those potential impacts that can be identified,



the effect on climate conditions would be so site-dependent as to



preclude quantification.  The following discussion describes poten-



tial changes that could result both from any construction of addi-




tional hazardous waste management facilities and from changes in



operational procedures as a result of the Subtitle.C regulations.




     Average temperatures could be slightly increased in the vicinity



of a hazardous waste management facility as a result of both heat re-




leased from the facility and increased reflection of heat from



cleared and paved surfaces on the facility site.  Heat would be re-



leased by incinerators, auxiliary boilers, and various treatment pro-



cesses.  This heat would increase the temperature slightly in the




immediate vicinity of each facility.  The heat would also cause local




convection currents, minor increased air turbulence, and slightly



greater instability in the immediate layer of air over the facility.




     Low-level wind patterns in the facility area could be slightly




modified as a result of the facility structure and minor topographic






                                 7-104

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changes.  Wind speeds could be slightly decreased and air turbulence




increased.  Aerodynamic effects of buildings could cause wake and



down-wash effects which could modify dispersion of low-level atmo-




spheric emissions.  Any such effects would be very localized in




nature.



     The creation of reservoirs and storage and treatment lagoons and



ponds would increase the surface area of water exposed to the atmo-



sphere and to solar radiation.  This would cause increased evapora-



tion which could influence the microclimate of the surrounding area.




The significance of such changes is not well understood at present.



     The precise role of airborne particulate matter and other aero-



sols emanating from hazardous waste management facilities with regard




to weather modifications cannot be determined completely.  Their in-




fluence on the amount of short-wave solar radiation is well estab-



lished and has important implications both on a global scale




(Mitchell, 1971) and on a regional scale.  In principbe, aerosol par-




ticles could also act as condensation nuclei and either enhance or



inhibit rainfall.  A considerable body of knowledge regarding cloud



seeding has been built up over the past 25 to 30 years (Byer, 1974;




Elliott, 1974) and numerous precipitation management programs are in



progress, notably in the U.S., Australia, Israel, and the Soviet




Union.



     While certain aspects of intentional weather modifications are




still regarded as controversial, it is generally recognized that






                                 7-105

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artificial nucleation can be effective in producing increases or



redistributions of precipitation under very specific meteorological




conditions and through the use of appropriate techniques.  A defini-




tive answer as to whether or not a local change in the concentration



of atmospheric aerosols resulting from dust or industrial emissions




would cause a significant change in precipitation patterns cannot be




given (Simpson and Dennis, 1974).  A few instances of anomalous snow-




falls have been recorded; industrial and urban emissions are thought



to be instrumental in producing generally light snowfalls in these



cases (Landsberg, 1974).  An increase in cloudiness due partly to the



aerosol condensation nuclei and partly to the heating effect of



cleared surface areas appears to be a more likely phenomenon than



persistent alterations in precipitation characteristics.  No signif-



icant localized or regional impacts are anticipated from changes in




hazardous waste incineration.



     The most frequently cited' factor associated with inadvertent




climate modification is the increasing carbon dioxide content of the



atmosphere (Machta and Telgadas, 1974; Massachusetts Institute of




Technology, 1970).  The steady growth observed in carbon dioxide con-




centration is attributed to the rapidly increasing use of fossil



fuels since the turn of the century.  Although the potential effects



of atmospheric carbon dioxide on global temperature and climate have



serious implications—the greenhouse effect through which the temper-



ature could increase—no significant localized or regional weather



effects from carbon dioxide emissions are anticipated from changes in




                                7-106

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hazardous waste incineration.  This is due to Che relatively small



quantity of carbon dioxide expected to be produced from hazardous




waste incineration in relation to the production from other sources.




     7.1.5  Water Quality Impacts.  The primary mechanisms by which




surface water may be contaminated with hazardous wastes are spills



(including deliberate dumping); surface runoff from storage, treat-




ment, or disposal areas (including overflows from impoundments);



direct discharges from generating or treating facilities; and dis-




charge of groundwater contaminated by subsurface migration of pollu-



tions.  Groundwater contamination can occur with almost any facet of



hazardous waste handling and disposal as now practiced.  It may occur



due to infiltration of spilled materials or wastes stored on perme-




able surfaces, due to percolation of leachate or runoff which has



been in contact with wastes either in storage or in landfills, or due



to leakage or infiltration of fluids from poorly sealed waste impound-




ments.



     These mechanisms may be generalized into three major pathways




through which contamination can occur:  spills, other surface releas-




es (including runoff and direct discharges), and underground dis-



charges (primarily off-site movement of leachates).  The following



sections discuss the effects of the Subtitle C regulations on these




pathways with respect to each of the steps in the hazardous waste



management sequence.



     A general discussion of the effects of the combined regulations




on each pathway is followed by discussions of the effects of any





                                7-107

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specific parts of the regulations which further control one of the



individual hazardous waste management activities (e.g., transporta-



tion).




     7.1.5.1  Spills.  The Subtitle C regulations would potentially




result in a decrease in the number and size of hazardous waste




spills.  This would occur primarily as a result of the requirements



for maintenance of adequate containerization, and indirectly, as a




result of the increased awareness of the waste hazard due to the



manifest system and labeling requirements.  The regulations would



not, however, significantly affect the frequency of major vehicular



accidents during transport resulting in spillage (available data on




the number and volumes of hazardous spills are presented in Chapter



6).



     It is expected that the effects of any spill which may occur



would be reduced as a result of the requirements for prompt reporting



of all spills to the National Response Center and for immediate



action to remove the spill in the most expedient manner.  These pro-



visions would complement those developed under Section 311 of the



Clean Water Act, and in effect, would extend the National Contingency




Flan to include upland spills as well as those into navigable waters.



     One of the side-benefits of the regulations would be the quanti-




fication of the amounts of hazardous material spilled, a presently



unknown figure, which is important for planning the size and deploy-




ment of emergency response teams as well as for assessing the need



for more stringent transportation safety codes.  At present it is




                                7-108

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estimated that there may be about 2,000 spills of hazardous sub-

stances, including wastes, per year (U.S. Environmental Protection

Agency, 1977b).

     Transportation.  The effects discussed above would apply to all

segments of the hazardous waste management sequence.  As indicated in

Section 7.1.2.1, the generator regulations (Section 3001) would fur-

ther reduce the likelihood of spills through the imposition of speci-

fic containerization requirements for the transport of hazardous

wastes.  These requirements would reduce the likelihood of rupture

and spillage of wastes during shipment.  Further, the transporter

regulations also prohibit transportation of containers of hazardous

wastes which are leaking or appear to be damaged, or the transport or

consolidation of incompatible wastes.  However, any increases in the

quantity of waste being shipped off-site or in the average distance

over which hazardous wastes are transported could lead to an increase

in vehicular accidents.  This would off-set some of the potential for

a reduction in spills.  Increases in the quantity of wastes.transpor-

ted by barge would also increase the potential for marine accidents

and spills.  Most hazardous wastes transported by barge are reported

to go to reclamation of resource recovery facilities (see Section

5.2.3.5) and, as such, would not be subject to the regulations.

     The regulations could also prevent the types of incidents due to

vehicle cleaning, as indicated below:

     •  An insecticide (endrin) applicator ringed and cleaned his
        truck into the Cuivre River at Moscow Mills, Missouri.  As a
        result, approximately 100,000 fish were killed, and the river

                                7-109

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        was closed to fishing for one year by the Missouri Game and
        Fish Commission (Office of Solid Waste Management Programs,
        1974a).

     Storage and Disposal.  Spillage or other unintentional releases

from storage and disposal facilities would be decreased due to the

requirements to maintain waste container integrity by recontaineriz-

ing the materials whenever their original container begins to fail.

Additionally, any spills occurring at a storage or disposal facility

would be contained at the site by dikes and impervious surfaces which

would prevent migration of the wastes until cleanup operations can be

completed.

     7.1.5.2  Other Surface Releases.  The regulations would signifi-

cantly decrease the number of, and environmental damage resulting

from, surface releases of hazardous wastes.  Many parts of the regu-

lations apply.  All generators of wastes designated as hazardous

would have to comply with all of the Subtitle C regulations.  These

stipulate that all hazardous wastes designated for on-site or off-

site treatment, storage, or'disposal would have to be sent to a

permitted facility.  The regulations would institute a manifest and

reporting system to enable tracking of wastes to ensure compliance.

All storage, treatment, and disposal facilities would have to use

diversion structures to prevent runoff from upland areas from flowing

onto active portions of the facilities.  Further, such facilities

would have to confine all runoff or any other discharge to a point

source which complies with the regulations promulgated under the

Clean Water Act of 1977.  The combined effects of these regulations


                                 7-110

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would be to eliminate most non-point surface discharge of wastes




defined as hazardous.  Specific effects of the various regulations



are discussed below.



     Characteristics. Identification, and Listing.  A large number of




hazardous wastes are either listed or fall under the characteristics



contained in the Section 3001 regulations.  Many have been involved



in past damage incidents.  The occurrence of such incidents would be




reduced as a result of the regulations.  However, many other poten-



tially hazardous wastes are not listed and would not be included by



the characteristics.  At present, numerous potentially toxic, carcin-




ogenic, or mutagenic organic chemicals would not be included by the




toxicity characteristic that is based entirely on EFA Primary Drink-



ing Water Standards.  At present, Primary Drinking Water Standards




are promulgated for nine inorganic contaminants and six organic con-




taminants (all pesticides). -Although the number of contaminants



regulated under the Drinking Water Standards will probably increase




in the future, it is likely that many potentially hazardous wastes



would escape regulation under this characteristic.  The Environment-



al Protection Agency plans to expand the toxicity characteristic at a




later time.



     Generators.  As mentioned above, generators of hazardous wastes



would not be allowed to dispose such wastes without also receiving a




permit as a disposal facility.  However, there would be a few exemp-



tions to these regulations.  Generators engaged solely in retail



trade or principally in farming would be regulated only with respect




                               7-111

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to waste automotive oil.  Household wastes would be entirely exemp-




ted.  Further, generators who generate less than 100 kilograms per



month of hazardous wastes would not be subject to regulation, but



would be expected to dispose their wastes in a responsible manner.



These exclusions would allow a small quantity of hazardous wastes to




escape regulation.  However, it is expected that the regulations




issued by EPA under the Federal Insecticide, Fungicide and Rodenti-



cide Act (FIFRA) of 1972 would control pesticide wastes from farmers;



and it is estimated that the 100 kilogram per month generation limit




would exclude less than 30,000 tons of hazardous industrial waste per



year annually by 1984, less than 0.1 percent of the total hazardous




industrial waste.  Wastes from these excluded generators could be



disposed as a nonhazardous waste using current practices, could go




into sewer systems or any other allowable disposal area, and could




conceivably eventually contaminate surface waters.  The impacts of



this'generation limit are difficult to define.  However, it is likely



that the excluded wastes would continue to cause essentially the same



types of impacts as they currently are causing, modified by the Sub-



title C requirements.  With proper disposal of the regulated wastes,




the total impact of hazardous wastes on surface waters should be sig-



nificantly reduced.  Thus, although it is true that some unregulated




releases of hazardous wastes could continue to occur and that some



hazardous wastes may cause significant damage in any amount, such




occurrences would be much less frequent and, generally, less severe



than those which occur in the present uncontrolled case.





                                 7-112

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     Transportation.  The transporter regulations would require that

transporters deliver all manifested hazardous wastes to a designated

permitted storage, treatment, or disposal facility.  In addition,

transporters could not transport containers which are leaking or

appear to be damaged.  These requirements would eliminate willfull

dumping of hazardous wastes by transporters.  A typical incident of

'midnight dumping1 which could be precluded by the proposed

regulations is as follows:

     •  In March 1972 a considerable amount of xylene was dumped into
        a drainage ditch along the Pennsylvania Turnpike.  The liquid
        waste flowed down the ditch, across a field, and into a
        nearby stream causing a fish kill (Cartwright and Lindorff,
        1976).

     As discusssed previously, the Subtitle C regulations would re-

duce the likelihood of spills of hazardous wastes and their associ-

ated surface water contamination by extending the DOT Hazardous

Materials Regulations to cover intrastate as well as interstate

transportation.

     Storage, Treatment, and Disposal.  The human health and environ-

mental standard for surface water would require that all facilities

be located, designed, constructed, and operated so that no discharges

from the facility violate the Water Quality Standards promulgated

under Section 303 of the Clean Water Act, or constitute a spill of

hazardous substances under Section 311 of that Act.  As previously

indicated, more specific regulations (General Facility Standards)

would require the use of diversion structures to prevent surface run-

off from flowing onto the facility and the use of dikes or other

                                 7-113

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contaminant structures to collect runoff originating on the facility.



All discharges from such facilities, including discharges from leach-



ate and/or runoff collection systems, would have to be confined to




point sources and must comply with the regulations promulgated under



the Clean Water Act.  Further, siting limitations would restrict



facility siting on floodplains and in wetlands.  Additionally, each




type of facility (storage, treatment, and five types of disposal




facilities—incineration, landfills, surface impoundments, basins,



and landfarms) would have to meet other standards which are discussed




in following sections.




     These regulations would constitute a substantial improvement



over the present unregulated situation and should result in a signif-




icant decrease in the number of pollution incidents resulting from



hazardous waste storage and disposal.  However, even though a dis-



charge may meet all presently promulgated standards (including those




under the Clean Hater Act), it could still decrease receiving water



quality up to the maximum allowable limit for each regulated constit-



uent.  Since these limits were picked to ensure adequate protection




of the environment and human health, such an impact would likely be




minimal.  In addition, there are many potentially hazardous constitu-



ents of these wastes for which no standards have yet been promul-




gated.  This may be due to lack of adequate substantiation of




suspected human health effects, or to lack of information on toler-



able levels to ensure the absence of chronic health effects.  It is




possible that some potentially harmful properties of other




                                7-114

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contaminants are not even suspected at this time.  In this respect,



waste discharges could conceivably meet all applicable standards and




still contribute to environmental degradation with potential human




health effects.  It must be emphasized, however, that such effects



are now occurring to a much greater degree without the controls that




would be instituted by the baseline regulations.  In addition, where




the permitting agency is able to document such a threat, they could



stipulate additional permit requirements on the authority of the




human health and environmental standard.




     The potential impacts of regulating the various types of facil-



ities are as follows:




     Storage.  The Subtitle C regulations would require that hazard-



ous waste storage operations be conducted, monitored, and inspected



in order to ensure that no discharge occurs.  Specific requirements




include impervious construction and the use of diversion and contain-




ment structures, such as dikes or trenches, to prevent the release ,of




runoff or spills.  Provisions are included requiring leakproof con-



struction of storage tanks and containers and for recontainerization




of leaking wastes.  Records of the identity and location of all



stored wastes must be kept during the entire storage period.  In



addition, the baseline regulations would require that all hazardous



waste facilities receive a permit and be subject to inspection at any



time to ensure that they were being properly maintained.



     Since there are presently no requirements to report the loca-




tions or amounts of hazardous waste in storage, there is no way of




                                 7-115

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quantifying even the existing pollution problems due to waste stor-

age, let alone the potential improvement due to the regulations.  In

the current unregulated situation, hazardous waste may be stored in

drums, sacks, or even in piles or unlined ponds.  The waste might be

housed in warehouses or sheds, or left in the open, occasionally cov-

ered with tarpaulins or other materials.  In addition, hazardous

waste may be stored for extended periods of time because all avail-

able methods have been considered too expensive to be utilized with-

out the legal requirement to do so.  As a result, water pollution

incidents from improper storage of hazardous wastes are common.  A

typical incident that could have been prevented by the baseline reg-

ulations is described in EPA files:

     •  A herbicide manufacturer stored many tons of arsenic salt
        wastes on his plant site in Wisconsin.  As a result, both the
        Menominee River and local groundwater have been contaminated
        with water containing up to 1.0 ppm arsenic (The National
        Interim Primary Drinking Water Standard is 0.05 ppm) and
        sediment containing up to 35 ppm arsenic (Office of Solid
        Waste, Hazardous Waste Management Division, 1978b).

     Other incidents have occurred in which unregulated storage piles

have produced surface water contamination as a result of fires.  The

following incident, while it did not involve wastes per se, illus-

trates the potential for surface water contamination due to combus-

tion of hazardous waste in storage:

     •  One and a half million gallons of water were used to extin-
        guish a warehouse fire in Oroville, Washington where two tons
        of various chlorinated pesticides and 50 tons of fertilizer
        were stored.  Much of the water flowed through storm sewers
        to the Okanogen River, where 0.8 ppm endrin was detected.
                                7-116

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        Elevated levels of nitrate and pesticides were also detected
        in the groundwater (Office of Solid Waste, Hazardous Waste
        Management Division, 1978b).

     Incidents such as this would be addressed under the regulations

only if the warehouses contained waste, outdated, or off-specifica-

tion pesticides awaiting disposal.

     Treatment.  The specific regulations for treatment facilities

stipulate that all facilities must have the capability to safely

handle hazardous wastes in the event of an emergency or equipment

failure of any sort.  Such capabilities include automatic cut-off or

by-pass systems on continuous feed processes, emergency transfer of

reaction vessel contents, and emergency storage capacity.  Further,

all treatment chemicals, reagents, and wastes must be stored in com-

pliance with the regulations for storage; any basins used for treat-

ment must comply with the regulations for basins; and the entire

facility must be designed, constructed, operated, and maintained in

accordance with the human health and environmental standards.  Any

wastes produced .from a treatment facility would also be subject to

the Subtitle C regulations.  If such a waste is hazardous in accor-

dance with the characteristics or listing regulations, the treatment

facility would have to comply with all other standards promulgated

under Subtitle C, including initiating a manifest and ensuring proper

disposal.  At the time of closure, all hazardous wastes and residuals

would have to be removed from treatment facilities and properly

disposed.
                                •7-117

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     With one exception, Publicly Owned Treatment Works (POTW's)

would be exempted from compliance with the Subtitle C regulations.

The exception is that for the wastes received at POTW's by truck or

rail, the POTW would have to comply with reporting and recordkeeping

requirements.  While sludges from POTW's would be exempt from the

Subtitle C regulations, the POTW's would still have to comply with

the regulations promulgated under Section 405 of the Clean Water Act.

Industries which discharge wastes into municipal sewer systems would

not need to comply with manifest requirements, but would have to meet

all applicable pretreatment standards under the Clean Water Act, and

would have to obtain the approval of the municipal sewer system

authority.  Application of these regulations could eliminate the

following type of incident:'

     •  In Louisville, Kentucky in March 1977, a wastewater treatment
        plant was shut down after receiving large amounts of
        hexachloro-cyclopentadiene and octachlorocyclopentene.  Con-
        centrations of "hexa" reached 47,000 ppm in sewer sediments,
        and 32 plant employees experienced watering eyes, respiratory
        ailments, or other ill effects due to the heavy vapors asso-
        ciated with the contaminants.  As a result, 105 million gal-
        lons per day of raw sewage was discharged to the 'Ohio river
        for more than two months.  It was estimated that the total
        diversion amounted to over 9 billion gallons of raw sewage
        while clean up costs reached over $450,000 (State of
        Minnesota, 1977).

     Many similar, though less spectacular, incidents have also oc-

curred but would likely be avoided following implementation of the

baseline regulations.  In such cases, wastes introduced to sewer sys-

tems often travel through municipal treatment plants without affect-

ing the plant and without being affected by treatment.  These then


                                7-118

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flow out with the discharge and may cause fish kills or water supply

contamination downstream, as illustrated below:

     •  Two fish kills were noted in August and November 1975 in the
        Crow River near Hutchinson, Minnesota.  It was determined
        that they were caused by cyanide levels as high as 0.31 mg/1
        in the stream.  The source was identified as the Hutchinson
        wastewater treatment plant which received ferrocyanide from a
        local industry.  Ferrocyanide dissociates in the presence of
        sunlight to release ionic cyanide which forms highly toxic
        hydrocyanic acid.  This dissociation process is accelerated
        with decreasing pH; therefore, the fish kills were only
        noticed during periods when the pH of the river or sewage
        effluent was lower than normal (State of Minnesota, 1977).

     Incineration.  In terms of potential to cause water pollution,

disposal facilities using incinerators are essentially the same as

treatment facilities.  Accordingly, the regulatory approach for pre-

vention of water contamination from the two types of facilities is

similar.  Both are treated as temporary facilities which would have

to comply with storage regulations, treat any residuals in accordance

with the Subtitle C regulation, and remove all wastes at the time of

closure.  Since incinerators have little direct impact on water qual-

ity, except possibly with regard to cooling water discharges, this

segment of the regulations would not likely constitute a significant

improvement over existing conditions.  However, application of the

general facility standards (including the storage regulations) would

help eliminate incidents such as one reported by the State of Minne-

sota (1977), where sloppy housekeeping at a hazardous waste incinera-

tion facility resulted in a fire and in possible water contamination.

     Landfills.  Pertinent features of the Subtitle C regulations

applicable to surface water pollution from landfills include the

                                7-119

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requirement that landfills be located or designed, contracted, and



operated to prevent direct contact between the landfill and navi-




gable water, and that all active portions of landfills must be at



least 150 meters from any public, private, or livestock water supply.




The regulations also specify that diversion structures would have to




be constructed to prevent surface runoff from entering the landfill




and to collect all runoff originating on the landfill for treatment,



if necessary.  The regulations would allow the use of one of several




designs.  Where natural conditions allow, the bottom and sides of the



landfill would have to consist of at least three meters of natural



in-place soil exhibiting a permeability equal to or less than 1 x




lO"? cm/sec and which satisfies certain other plasticity, pH, com-



position, and grain size requirements.  Such facilities would not



require a leachate collection system if it could be demonstrated that



liquids would not accumulate in the landfill to the extent that they



might be discharged to the surface in any manner or to the ground-



water in a manner that violates the groundwater human health and




environmental standard.  Where naturally occuring soils do not meet



the above criteria, the regulations would require the use of either a




1.5 meter soil liner and a leachate collection system; or a one meter




soil liner, a 20 mil synthetic liner, a leachate collection system,



and a leachate detection system.  Other designs would be acceptable



if it could be demonstrated that they could provide equivalent




containment.  Further, all landfills would have to either include



leachate collection systems or demonstrate that liquids would not




                                 7-120

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accumulate in Che landfill such that they may be discharged to the

surface in any manner (or to the groundwater in violation of the

groundwater human health and environmental standard).  Upon closure,

the landfill would have to be graded such that water would not pool

over the landfill and such that erosion would be prevented.

     These regulations should result in a significant decrease in

surface water contamination from landfills.  Quantification of the

magnitude of the impact is not possible since neither the number nor

areal distribution of landfills receiving hazardous waste nor the mag-

nitude of environmental problems associated with them are known with

any degree of accuracy.*  However, the Office of Solid Waste Man-

agement Programs (1977) estimates that there are about 18,500 land

disposal sites in the United States which accept municipal wastes,

most of which also receive some industrial wastes.  In addition, the

number of unauthorized and uncontrolled dumping grounds may reach

150,000 (TEMPO, 1973).  Most of these were located without concern

for potential environmental contamination and, as a result, many of

them probably cause some degree of water pollution.  Examples of sit-

uations which could be avoided are numerous.  Many such incidents are

included in Appendix J.  The following example illustrates a typical

incident which would likely be avoided as a result of implementation

of the baseline regulations:
*EPA is currently expecting to develop an inventory of industrial
 landfills during the second year following the publication of its
 hazardous waste disposal criteria (Office of Solid Waste, 1977a).

                                 7-121

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     •  la 1974, an investigation sparked by the deaths of three head
        of cattle near Byron, Illinois, discovered an abandoned dis-
        posal area for many industrial wastes, including cyanides,
        arsenic, cadmium, chromium, petroleum products, acids, and
        other wastes.  Soil, surface water, and groundwater con-
        tamination along with extensive damage to wildlife, aquatic
        life, and local vegetation were documented.  U.S. Drinking
        Water Standards were violated by at least five constitutents
        in surface water entering Rock Creek, 1.5 miles from the
        site:  arsenic, 60 ppb; cadmium, 340 ppb; chromium, 17,200
        ppb; cyanide, 365,000 ppb; and phenols, 8 ppb (standards for
        these contaminants are 50 ppb, 10 ppb, 50 ppb, 200 ppb, and 1
        ppb, respectively) (State of Minnesota, 1977, Cartwright and
        Lindorff, 1976; Office of Solid Waste, Hazardous Waste Man-
        agement Division, 1978b).

     Surface Impoundments.  Pertinent features of the regulations

regarding surface water pollution from surface impoundments include a

mandate against any direct connection with navigable waters; a mini-

mum separation of 150 meters from any public, private or livestock

water supply; a requirement for impervious natural or artificial

liners and leachate detection systems; and a system of dikes which

would prevent seepage of wastes either vertically or horizontally.

Design parameters for the liner and dike systems are specified which

include minimum thicknesses and permeabilities of liners as well as

minimum freeboard and capacities of dikes.  In addition, periodic

monitoring and inspections and rapid correction of any deterioration

are required.  At the time of closure, all wastes must be removed,

unless the impoundment meets the criteria for, and is closed in

accordance with, the regulations for landfills.

     As in the case of landfills, surface water contamination due to

failure of hazardous waste impoundments would be greatly reduced by

the implementation of these regulations.  Quantification of the
                                 7-122

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magnitude of the impact is not possible since neither the total

number of existing lagoons nor the number of leaking lagoons is

known.*  It is currently estimated that there are a total of

100,000 industrial impoundments in the U.S. and that 1.7 trillion

gallons (6.4 billion cubic meters) per year of industrial wastewaters

(not necessarily hazardous) are pumped to oxidation ponds or lagoons

in the U.S. (Office of Solid Waste Management Programs, 1977).  It

has been further estimated that 100 billion gallons per year of the

wastes placed in the secondary treatment lagoons leak to the ground-

water (Office of Solid Waste Management Programs, 1977).  The total

leakage from all lagoons is unknown, but is probably significantly

larger.  It is known, however, that numerous incidents have occurred.

Many of them are described in Appendix J.  A typical incident,

described in EPA files, is as follows:

     •  A copper reclamation company located in a mid-Atlantic state
        from 1965.to 1969 bought industrial wastes from other plants,
        extracted the copper and stored the remaining liquids in ce-
        ment lagoons.  Three of the lagoons developed open seams and
        leaked toxic pollutants into an adjacent creek, killing all
        its aquatic life.  After an injunction was issued requiring
        the wastes to be treated, the company defaulted, leaving 3.5
        million gallons of toxic wastes on the site.  Heavy rains in
        April, 1970 overflowed the lagoons into a tributary of the
        Delaware River, forcing county officials to build a dike
        around the area.  The wastes were finally neutralized and
        ocean dumped at the state's expense of $400,000 (Office of
        Solid Wastes, Hazardous Waste Management Division, 1978b).
*EPA is developing an assessment of surface impoundments and their
 potential for contaminating water.  The assessment will fulfill
 EPA1s mandates under the Safe Water, Drinking Act and RCRA (Office of
 Solid Waste, 1977a).            —"
                                7-123

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     Basins.  The baseline regulations would define basins as uncov-


ered devices constructed of artificial materials, used to retain


wastes as part of a treatment process, usually with a capacity of


less than 100,000 gallons, e.g., open mixing tanks, clarifiers, and


open settling tanks.  Such structures are generally temporary, and


operated in conjunction with other treatment facilities.  The regula-


tions would require impermeable construction and mechanical integrity


sufficient to prevent discharge of wastes to navigable water; daily


monitoring or inspection, and immediate repair of any damages; and


removal of all waste upon final closure.  As in the case of surface

                           i
impoundments, these regulations would result in a decrease in surface


water contamination compared to that occurring in the present unregu-


lated situation.  Due to the lack of data on the number of basins in


use, the degree of the impact cannot be determined.


     Landfarms.  Pertinent sections of the baseline regulations con-


cerning the potential for water pollution from landfarms include the


prohibition against the use of landfaras for certain water soluble


toxic inorganics; the requirement that landfarms shall be located,


designed, constructed, and operated to prevent direct contact between


the treated area and navigable water; and a minimum separation of 150


meters between the treated area and any public, private, or livestock


water supply.  Other requirements are that the potentials for stand-


ing water or erosion are both minimized and that waste application


shall not occur when the soil is saturated, or when its temperature
                                 7-124

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is at or below 0 C.  The general facility standards would further



require that all runoff from landfills be collected and confined to a




point source which is in compliance with the regulations promulgated



under the Clean Water Act.




     Although the concept of landfarming has been applied to munici-




pal sludges for many years, experience with, and data on landfarming



of hazardous industrial sludges are sparse.  The regulations contain



several provisions to reduce pollutant migration.  They would limit



application of arsenic, boron, molybdenum, selenium, and volatile



wastes; require the use of fine grained soils consisting primarily of



silts and clays; require maintenance of a minimum pH of 6.5 and pre-




vention of anerobic conditions in the zone of incorporation; require



semi-annual soil monitoring; and restrict the growth of food chain




crops.  While these requirements would certainly reduce water contam-




ination relative to existing uncontrolled disposal methods, the



regulations would not address rates of application; they would not



specifically require runoff monitoring; and they would not address




other toxic elements or organic wastes, some of which have caused



concern in land application facilities for municipal sludges.




     Although it is true that most municipal sludge landfarming oper-



ations were oriented towards agricultural crop production, and that



under aerobic conditions and at a pH greater than 6.5, most toxic




inorganics are relatively insoluble, the potential for water
                                 7-125

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degradation would still exist.  (It should be noted that the trans-



formation of Cr+3 to Cr*6 is favored by oxidizing conditions and




high pH; and that CrOf, the predominant ionic form under those



conditions, was not adsorbed by the common clay minerals tested by



Griffin et al., [1976].)  Additionally, the presence of acidic wastes




and wastes which exert high oxygen demands may make it difficult to




maintain the required pH and aerobic conditions, which could allow




dissolution of some previously precipitated toxic elements.



     7.1.5.3  Underground Discharges.  Groundwater pollution is pos-




sible in any situation in which hazardous wastes are placed in or on



the ground with a hydraulic connection to an aquifer.  Such a hydrau-



lic connection consists of a permeable pathway from the wastes to an




aquifer.  It may be composed of unconsolidated sands and gravels,



permeable bedrock such as some sandstones, or a system of fractures



or joints in the bulk rock.  A more complete discussion of ground-




water and its contamination is contained in Appendix L.



     There are no existing estimates of the amount of hazardous




wastes which presently contaminate groundwater.  However, it is esti-



mated that there are about 18,500 land disposal sites in the United




States which accept municipal wastes, most of which also receive some




amount of industrial waste (Office of Solid Waste Management Pro-




grams, 1977).  It is further estimated that these disposal areas



cover a total of approximately 500,000 acres and that they receive




approximately 135 million tons of refuse per year.  Based on average






                                 7-126

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infiltration rates, it is estimated that these sites generate a total



of 90 billion gallons of leachate per year (Office of Solid Waste



Management Programs, 1977).  In addition, the number of unauthorized



and/or otherwise unregulated dumping grounds in the U.S. may reach




150,000 (TEMPO, 1973).  EPA is currently planning to inventory indus-



trial landfills beginning the second year following promulgation of




its hazardous waste regulations (Office of Solid Waste, 1977a).



     It is estimated that there are a total of 100,000 industrial




impoundments in the U.S. (Office of Solid Waste Management Programs,



1977).  Data are insufficient to estimate the total volume of wastes




sent to all impoundments, but is has been estimated that secondary



treatment lagoons, such as oxidation ponds, receive 1,700 billion




gallons of industrial, though not necessarily hazardous, wastes per



year and leak 100 billion gallons (approximately 6 percent) (Office




of Solid Waste Management Programs, 1977).  Other types of surface



impoundments may contribute additional hazardous leachates.




     Tables 7-10 and 7-11 summarize some of the hundreds of reported



incidents of groundwater contamination due to waste disposal in im-



poundments and in landfills.  Table 7-10 summarizes incidents due to



leakage of wastewater from surface impoundments and lists the major




resultant pollutants, and Table 7-11 summarizes incidents due to




landfill leaching.  The fact that Table 7-11 lists more municipal



landfills than industrial landfills is due to a lack of data regard-



ing the location and operation of industrial landfills and to the






                                7-127

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                            TABLE  7-10
         ORIGINS AND POLLUTANTS IN 57 CASES OF GROUIfD WATER
         CONTAMINATION IN THE NORTHEAST CAUSED BY LEAKAGE OF
             WASTE WATER FROM SURFACE IMPOUNDMENTS *
Type of industry or activity
 Number
of cases
 Principal pollu-
 tant (s)  reported
Chemical
   13
Metal processing  and  plating
 Electronics
 Laboratories (manufacturing
   and processing)
 Paper

 Plastics
    3

    3
Ammonia
Barium
Chloride
Chromium
Iron
Manganese
Mercury
Organic chemicals
Phenol
Solvents
Sulfate
Zinc

Cadmium
Chromium
Copper
Fluoride
Nitrate
Phenol

Aluminum
Chloride
Fluoride
Iron
Solvent

Arsenic
Phenols
Radioactive
  materials
Sulfate

Sulfate

Ammonia
Detergent
Fluoride
                                  7-128

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                   TABLE 7-10  (Continued)
Type of industry or activity
Sewage treatment
Aircraft manufacturing
Food processing
Mining sand and gravel
Oil veil drilling
Oil refining
Battery and cable
Electrical utility
Highway construction
Mineral processing
Paint
Recycling
Steel
Textiles
Number
of cases
3
2
2
2
2
2
1
1
1
1
1
1
1
1
Principal pollu-
tant (s) reported
Detergents
Hitrate
Chromium
Sulfate
Chloride
Nitrate
Chloride
Chloride
Oil
Oil
Acid
Lead
Iron
Manganese
Turbidity
Lithium
Chromium
Copper
Acid
Ammonia
Chloride
"Miller et al., 1974.
                              7-129

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                          TABLt 7-11

          SUMMARY OF DATA ON 42 MUNICIPAL" AND 18 INDUSTRIAL
                         COHIAMI3ATION CASES *
                                                 Type of landfill
 Findings                                       Munlelpalt Industrial

Assessment of principal damage
   Concaoinacion aquifer only                      9           8
   Water supply well(s) affected                  16           9
   Contamination of surface water                 17           1

Principal aquifer affected
   Unconsolidated deposits                        33          11
   Sedimentary rocks                               7           3
   Crystalline rocks                               2           4

Type of pollutant observed
   General contamination                          37         '  4
   Toxic substances                                5          14

Observed distance traveled by pollutant
   Less than 100 feet                              6           0
   100 to 1.000 feet                               8           4
   More than 1,000 feet                           11           2
   Unknown or unreported                          17          12

Maximum observed depth penetrated by pollutant
   Less than 300 feet                             11           3
   30 to 100 Ceet                                 11           3
   More than 100 feet                              52
   Unknown or unreported                          15          10

Action taken regarding source of contamination
   Landfill abandoned                       •       5           6
   Landfill removed                                1           2
   Containment or treatment of leachate           10           2
   Ho known action                                26           8

Action taken regarding ground water resource
   Water supply vell(s) abandoned                  4           5
   Ground water monitoring program established   12           2
   Ho known action                                26           11

 Litigation
   Litigation involved                             8           5
   Ho known action  taken                          34           13


     *Miller  ec al.,  1974.
     tMany of these  municipal  landfills also accept some industrial
 sludges and  liquids in addition to septic wastes and sewage sludges.


                               7-130

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comparatively large number of well documented studies of municipal



landfills.  In fact, it is estimated that, at least in the northeast,




industrial landfills are far more abundant than municipal landfills




(Miller et al., 1974).



     The fact that many currently operating landfills are leaking and




that this leakage may not be detected for significant periods of time



is amply illustrated by a recent study performed for EPA (U.S. Envi-



ronmental Protection Agency, 1977c).  The study selected 50 landfill



sites representing a variety of geohydrologic and climatic condi-



tions, disposal methods, and a wide range of industrial wastes.  The



sites were a minimum of three years old, with no history of known or




suspected contamination.  Four of the sites had some kind of leachate




control system.  Thirty-two sites had existing monitoring systems.



Five others had water supply wells near enough to be used for moni-




toring.  At sites where no monitoring system existed, or where the



existing system was not considered adequate, new wells were placed.




Each site was covered by several monitoring wells and at least one




background well.  The results of sampling are summarized in Table



7-12.  It was determined that at 43 sites definite migration of haz-



ardous constituents had occurred.  The seven other sites were also



contaminated by hazardous materials, though it could not be shown



that their contamination was due to the disposal sites.  At 26 sites,



hazardous inorganic constituents in water from one or more monitoring



wells exceeded the EPA drinking water limits.  Only one of the four
                                 7-131

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                                      TABLE 7-12

                     GROUNDWATER CONTAMINATION FROM INDUSTRIAL WASTE
                               LAND DISPOSAL SITES*
!l of Wells
Contaminant Which Exceeded
Background

Arsenic
Barium
Chromium
Cobalc
Copper
Mercury
Molybdenum
Nickel
Lead
Selenium
Zinc
Lighc Volatile Organics
Heavy Volatile Organics
Halogenated Organics
Alkyl Benzenes
Benzene
Butyl Alcohol
Camphor '
Chlorinated Phenols
Cyanide
Hepcachlor
Methyl Ethyl ECetone
Napthalene
Polychlorinated Biphenyls
Tr ichlor oe thy lene
Toluene
Xylenes

5
29
12
15
19
5
2
18
3
28
13
13
9
21
2
2
1
1
2
20
1
2
1
1
2
3
4
6 of Wells
Above EPA
Drinking Water
Standards
3
3
3
t
2
1
t
4.
3
23
2
t
t
t
t
t
f
*
A
t
+
t
t
t
^
T
t
Max Cone.
Observed
(rng/1.)

S.8
3.8
420
0.22
2.8
0.0008
0.24
0.67
19
0.59
240
1000
0.59
0.006
Detected
Detected
Detected
Detected
0.003
14.0
Detected
Detected
Detected
0.002
0.3
Detected
Detected
   'Complied from data presented in U.S. Environmental Progection Agency,  1977c.
This study examined 50 disposal sites using a total of 112 monitoring wells In
addition to background wells at each site.  Eighty-six wells at 43 sites con-
tained one or more hazardous substances which were determined to have migrated
from the site.  Wells at 26 sites contained hazardous Inorganic contaminants
which exceeded EPA Drinking Water Standards.  The wells ranged from 10 to 1500
feet from the disposal sites.
   NOTE:  Three additional wells were contaminated by heavy metals, one with
light volatile organics, and one with halogenated organics; however, no back-
ground data was available Cor comparison.
   •Not presently covered by EPA Interim Primary Drinking Water Standards.
                                         7-132

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"controlled" landfills showed no contamination greater than back-

ground levels; one showed a slight increase in one constituent above

background levels; and the remaining two showed significant increases

of several contaminants.  Both of the leaky controlled landfills had

design failures which allowed portions of the leachate to escape.

The conclusions reached by the study group were that:

     •  Groundwater contamination at industrial waste land disposal
        sites is a common occurrence;

     •  Hazardous substances from industrial waste land disposal
        sites are capable of migrating into and with groundwater;

     •  Few hydrogeologic environments are suitable for land disposal
        of hazardous waste without some risk of groundwater
        contamination;

     •  Continued development of programs for monitoring industrial
        waste land disposal sites is necessary to protect groundwater
        quality;

     •  Most old industrial waste disposal sites, both active and
        abandoned, are located in geologic environments where
        groundwater is particularly susceptible to contamination;

     •  Many waste disposal sites are located where the underlying
        aquifer system can act as a pipeline for discharge of
        hazardous substances to a surface water body;

     •  At sites presently monitored, the use of wells as an aid in
        evaluating groundwater conditions is generally poor, due to
        inadequacies with respect to one or more of the following
        parameters:
        —number of wells
        —distance of wells from potential contamination source
        —positioning of wells in relation to groundwater flow
        —sealing against surface water contamination, or
            inter-aquifer water exchange
        —completion methods, such as development, maintenance, and
            protection against vandalism;
                                 7-133

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     •  At sites presently monitored, the sampling program is
        generally poor due to inadequacies with respect to one or
        more of the following parameters:
        —obtaining a sample representative of aquifer water
        —sample preparation
        —frequency of sampling
        —availability of background water-quality data
        —selection of constituents to be analyzed
        —availability of laboratories
        —maintaining records in usable form.

These conclusions emphasize the care with which hazardous waste land-

fills must be located, constructed, and monitored.

     With respect to surface releases, the Subtitle C regulations

would allow no surface or subsurface discharges of hazardous wastes

by generators, transporters, or storers.  The specific regulations

applicable to storers would require impervious construction and mon-

itoring to ensure that no groundwater contamination occurs.  Compli-

ance with these regulations would effectively eliminate contamination

of groundwater with the regulated hazardous wastes originating from

generators, transporters, and storers.  Many of the incidents repor-

ted in Appendix J could be avoided under the regulations.  The exis-

tence of the Section 3002 manifest system could make the following

type of incident highly unlikely to occur:

     •  In 1971 a major chemical company contracted with a trucker to
        haul approximately 5,000 drums of petrochemical wastes, in-
        cluding acrylonitrile, acetone, epichlorohydrin, and a number
        of other toxic, flammable? explosive, and/or oxidizing chemi-
        cals for disposal in a landfill.  Instead, approximately
        4,500 of the drums were transported to an abandoned chicken
        farm in Dover Township, New Jersey where they were stock-
        piled and subsequently dumped.  Although the drums and some
        contaminated soil were removed under court order in 1972, in
        1974 it was discovered that a large but unknown portion of
        the Cohansey Aquifer, a major regional aquifer, had become

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        contaminated with petrochemicals,  resulting in the condemning
        of approximately 150 private wells.  The cost of extending
        public water supply into the area  was about $300,000.  More-
        over, this incident resulted in adverse impact on local
        building and development.  The exact magnitude of the envi-
        ronmental and economic damage has  not yet been determined
        (Office of Solid Waste Management  Programs, 1976; State of
        Minnesota, 1977).

     The regulations for the other potential sources of groundwater

contamination (i.e., treatment and disposal facilities) are more

intricate.  The groundwater human health and environmental standard

for the proposed treatment and disposal (Section 3004) regulations

states the objective that no facility shall degrade groundwater such

that Underground Drinking Water Sources (UDWS) anywhere off the

facility property would at any time be endangered.  The proposed reg-

ulations would define UDWS as an aquifer which currently supplies a

public water system; has less than 10,000 mg/1 total dissolved sol-

ids; or is designated as a UDWS by the Administrator of EPA after a

public hearing.  The proposed regulations  would consider a UDWS en-

dangered if operation of a facility caused the violation of a Nation-

al Primary Drinking Water regulation; made it necessary to treat or

increase treatment of the water for any present or future use; or, if

such practice could otherwise adversely affect the health of persons,

such as by adding a substance that would make the water unfit for hu-

man consumption.

     The general facility standards for hazardous waste treatment and

disposal would require that discharges to groundwater not occur un-

less the facility owner/operator can demonstrate that the discharge

                                 7-135

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will not violate the groundwater human health and environmental stan-



dard.  Additional general standards would prohibit location of facil-




ities in the recharge area of sole source aquifers, would require



periodic groundwater monitoring for all facilities except landfarms,



and would require leachate monitoring for landfills and surface im-




poundments.  Additional specific requirements that would affect each



type of disposal facility are discussed below.




     Landfills.  The proposed regulations for landfills would require




a minimum separation of 1.5 meters between the bottom of the liner or



natural barrier and the historical mean water table, unless the land-



fill owner or operator can demonstrate that no direct contact will




occur between the landfill and the water table.  Further, the pro-




posed regulations would not allow disposal of bulk liquids or sludges




containing less than 20 percent solids; they would require a minimum



separation of 150 meters from any public, private, or livestock water



supply; and they would specify certain design characteristics, inclu-



ding minimum thicknesses, permeabilities, and other characteristics




of liner systems.  Where natural geologic conditions permit, land-



fills would be allowed to use in-place soils (meeting certain thick-




ness, permeability and structural requirements) without a leachate




collection system.  Otherwise, a leachate collection system would be



required.  In some cases, a double liner system (one synthetic and




one soil liner), with a leachate collection system and a leachate de-



tection system would be required.  Other designs would be acceptable
                                 7-136

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if it could be demonstrated that they provide equivalent containment.

The choice of design would have to be approved before construction of

the facility began.

     Successful implementation of these regulations would result in a

significant reduction in groundwater contamination caused by hazard-

ous waste landfills.  As discussed at the beginning of this section,

the extent of the reduction cannot be quantified since the amount of

contamination presently occurring is unknown.  However, many examples

of situations which could have been prevented by these regulations

are summarized in Appendix J.  A prominent example of the effects of

no control is as follows:

     •  Between 1960 and 1968, a large landfill near Llangollen, in
        New Castle County, Delaware, accepted industrial wastes of
        unknown character and origin, in addition to residential and
        commerical wastes.  The wastes were placed in an abandoned
        sand quarry underlain in part by a thin layer of sandy clay
        which separated it from the unconsolidated Potomac Aquifer, a
        major source of water supply for the area.  It turned out
        that the clay layer was absent beneath part of the site and
        that some of the clay was excavated for cover material at the
        landfill.  Groundwater contamination was first noted in 1972
        in a well 800 feet from the fill.  The resulting investiga-
      •  tiorf discovered a large plume of contaminated groundwater
        moving towards a well field producing 4 to 5 million gallons
        per day (mgd) located about 5,000 feet from the hill.  A mas-
        sive pumping operation now removes 3 mgd from the aquifer,
        while the well field is pumping at a reduced rate of 2 mgd,
        the deficit made up by other sources at the County's expense.
        Presently a dozen wells are pumping contaminated water to
        create a cone of depression near the site, and 35 wells are
        monitored monthly.  So far, expenses have reached $800,000
        for monitoring, pumping, and replacing water supplies. It is
        expected that is will cost more than $20 million if the dump
        must be moved, and that it will require 10 years to restore
        full usage of the aquifer (Cartwright and Lindorff, 1976;
        Garland and Mosher, 1975).
                                7-137

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     Surface Impoundments.  The regulations specific to surface im-


poundments would require the facility to be designed, constructed,


operated, and maintained such that no discharge to ground or surface


water would violate the respective human health and environmental


standards.  Other requirements would prevent direct contact between


the impoundment and the water table; maintain a separation of 150


meters from any public, private or livestock water supply; and would


specify certain design parameters, including the minimum thickness


and characteristics of liner systems.  Two types of design are cited,


though others could be acceptable if they provided equivalent con-


tainment.  Where natural conditions allow, the bottom and sides of


the impoundment would consist of at least three meters of natural,


in-place, clay-rich soils having a maximum permeability of 10"'
                          0

cm/sec and certain structural characteristics.


     A leachate monitoring system would also be required.  Under


other conditions, the impoundment would require a double liner system


and a leachate detection system.  The regulations would allow an


artificial liner meeting given specifications.  If an impoundment


meets the landfill standards, the baseline regulations would allow


its closure as a landfill, providing all bulk liquids, semi-solids,


and sludges were solidified in accordance with the regulations.


Otherwise, the hazardous wastes would have to be removed at the time


of closure.
                               7-138

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     Implementation of these regulations would significantly decrease

the occurrence of groundwater contamination by hazardous wastes.   As

in the case of landfills, the extent of the decrease cannot be quan-

tified due to the lack of information on the extent of present con-

tamination by improperly located and operated impoundments.  However,

as discussed in the beginning of this section, the problem is known

to be significant.  Numerous incidents of contamination have been ob-

served, some of which are summarized in Appendix J.  The following

example illustrates the potential magnitude of a single incident:

     •  An aircraft plant, operating in South Farmingdale on Long
        Island during World War II, generated large quantities of
        electroplating wastes containing chromium, cadmium, and
        other metals.  It has been estimated that 200,000 to 300,000
        gallons per day of these wastes were discharged into unlined
        disposal basins throughout the 1940"s.  A treatment unit  for
        chromium was built in 1949, but discharge of cadmium and
        other metals continued.  The local groundwater occurs in
        three unconsolidated aquifers resting on crystalline bedrock.
        The uppermost aquifer consists of beds and lenses of fine-
        to-coarse sand .and gravel and extends to within 15 feet of
        the land surface. Groundwater contamination by chromium was
        first noted in 1942 by the Nassau County Department of
        Health.  Extensive studies in 1962 indicated that a huge
        plume of contaminated groundwater had been formed, measuring
        up to 4,300 feet long, 1,000 feet wide, and extending from
        the surface of the water table to depths of 50 to 70 feet
        below the land surface.  Maximum concentrations of both hexa-
        valent chromium and cadmium were about 10 mg/1 in 1962.
        (Hexavalent chromium had been measured as high as 40 mg/1 in
        1949.)  This huge contaminated plume cannot be removed or de-
        toxified without massive efforts and will take many more
        years of natural attentuation and dilution before it becomes
        usable again.  Meanwhile, it is still slowly moving, threat-
        ening a nearby creek and other wells in the area (Tinlin,
        1976; State of Minnesota, 1977.)

     Landfarms.  The regulations for landfarms would prohibit direct

contact with the water table; would require the use of fine grained

                                 7-139

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silts and clays chosen to prevent vertical migration of the wastes



more than three times the depth of waste incorporation; would require




closing any caves, wells, or other direct connections to the subsur-




face environment; would require grading to prevent water from ponding



on the facility; would require maintenance of aerobic conditions and



a pH of 6.5; and would prohibit waste application when the soil is




saturated or frozen.  With respect to surface waters, implementation



of these regulations would help reduce both ground and surface water




contamination by hazardous wastes.  However, the regulations would




not require groundwater monitoring on the theory that any waste mi-



gration towards the groundwater would be detected by the required




semi-annual soil core analyses.  Further, although the baseline reg-




ulations specify soil types and certain structural characteristics



(liquid limit greater than 30, and plasticity index greater than 15),



they do not specify permeability or compaction of the soils or re-




quire liners or other base preparation.  While the soil 'types that



would be required are generally relatively impermeable and although



the regulations include the constraint that vertical migration of



hazardous constituents must not exceed three times the depth of waste



incorporation, the possibility of groundwater contamination would




still exist.  Such contamination could occur due to variabilities in



soil permeability (e.g., due to the inclusion of local sandy zones



within the silts and clays) or due to variations in the thickness or




compaction of the soils.  Additionally, although most toxic elements






                                 7-140

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are relatively immobile at the required pH and in oxygen rich envi-




ronments, formation of the hexavalent form of chromium (Cr04=) is



favored under those conditions.  Although the chrornate ion may be



precipitated by the presence of a few other metals (e.g., lead),




chromate is not adsorbed by two of the major clay minerals—the only




two tested by Griffin et al. (1976).



     Other Treatment and Disposal Methods.  Discharges to ground-



waters would be allowed from treatment facilities and basins, provid-



ing that such discharges would not violate the groundwater or surface



water human health and environmental standards.  The regulations




would also require facility maintenance to avoid leaks and emergency



releases due to equipment malfunctions and would require compliance




with applicable standards for storage facilities or surface impound-




ments.  These regulations would contribute to the reduction of water




contamination with hazardous wastes, though, as discussed previously,



quantification of the improvement is not possible.



     The regulations do not specifically deal with underground injec-




tion or ocean disposal of hazardous wastes.  It is anticipated that



these activities will be regulated by standards promulgated under the



authority of the Marine Protection, Research, and Sanctuaries Act and



the Safe Drinking Water Act.  This exclusion does not preclude use of



these techniques, and any storage or transportation of hazardous



wastes in conjunction with these activities would be subject  to  the




appropriate RCRA regulations.
                                 7-141

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     Taken collectively, the baseline regulations would eliminate

most of the pathways by which hazardous wastes presently contaminate

both surface water and groundwater.  The regulations would, there-

fore, result in a substantial reduction in the number of incidents in

which such contamination occurs.  However, a few pathways would re-

main, as discussed in the previous sections.  The following incident

serves to point out the potential for contamination by hazardous

wastes which could escape regulation:

     •  In May 1972, a private commercial well was dug for a new
        office of a small contractor in Ferham, Minnesota.  Within
        the same month, 5 of 13 employees became ill with gastroin-
        testinal ailments.  Six other employees also became ill with-
        in the next 10 weeks, two requiring hospitalization including
        one who lost the use of his legs for six months due to severe
        neuropathy.  After several weeks it was discovered that the
        well was located 20 feet from a site where approximately 50
        pounds of grasshopper bait had been buried between 1934 and
        1936.  The bait, which consisted of arsenic trioxide, bran,
        sawdust, and molasses, had been buried at a depth of 7 feet,
        while the affected well was 31 feet deep.  Well samples con-
        tained up to 21 ppm arsenic (U.S. Interim Primary Drinking
        Water Standards are 0.05 ppm).  Soil samples contained up to
        12,600 ppm of arsenic in the vicinity of the burial spot.  To
        date the affected well has been capped and an alternate water
        supply obtained at a cost of about $300.  Twelve nearby wells
        are also monitored periodically to establish the threat to
        the Perham municipal well field three-fourths of a mile away.
         It has been estimated that removal of the contaminated soil
        would cost up to $25,000 (Walker, 1973; Office of Solid Waste
        Management Programs, 1975a; Cartwright and Lindoroff, 1976;
        State of Minnesota, 1977).

     During two years only 50 pounds (about 23 kg) of wastes were

disposed, and 40 years later 11 people became seriously ill as a

result. The quantity of waste involved in this incident would easily

qualify for exclusion from the regulations under the generator limit

even if it was generated in one month.  Wastes thus excluded was
                                 7-142

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essentially unregulated, and may be disposed in conventional land-

fills, sewers, or by other less-controlled methods.  As a result,

although incidents due to the disposal of large quantities of wastes

would be reduced by the regulations, the potential for incidents,

such as that which occurred at Perham, Minnesota, would still exist.

     Disposal of small amounts of wastes does not necessarily result

in discrete identifiable incidents.  Perhaps a more serious problem
                                 ^
is the widespread increase in non-specific environmental

contamination by hazardous substances which has been occurring across

the nation, as evidenced by the following example:

     •  In Hay 1975, the U.S. Food and Drug Administration halted an
        interstate shipment of carp taken from Lake Pepin (located on
        the Mississippi River on the border between Minnesota and
        Wisconsin) by a commercial fisherman.  About 20,000 pounds of
        fish were destroyed when analysis revealed that some of the
        fillets exceeded the FDA limit of 5 ppm PCB.  At about the
        same time, an Inter-Agency Task Force on PCB's was formed to
        investigate PCB contamination in the Mississippi River.
        Their results indicate variable concentrations of PCB in the
        water; concentrations of up to 500 ppb in sediments in Spring
        Lake and up to 1000 ppb in sediments in Lake Pepin; con-
        centrations in individual fish ranging from 0.03 to 33 ppm;
        and average concentrations for fish species ranging from 0.04
        to-3.97 ppm, with the highest concentrations in white bass,
        carp, and channel catfish.  Significant damages have been
        sustained by both commercial fishermen and mink farmers.  The
        task force concluded that the contamination was probably
        caused by a large number of small inputs including municipal
        wastewater treatment plants, industrial discharges, re-
        suspension of bottom sediments during dredging, leachate from
        landfills, and fallout from the air after burning PCB con-
        taminated materials (State of Minnesota, 1977).

     Following successful implementation of the Subtitle C regula-
                       *
tions and associated regulations under FWPCA and other acts, the only
                                7-143

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unregulated sources of hazardous contaminants to surface waters would

be resuspension of bottom sediments; leachate from presently leaking

landfills or other dumps which are inactive when the regulations go

into effect, or are inadequately sealed following enactment; leachate

or other discharges from facilities receiving nonregulated wastes;

and spilled materials which escape clean-up attempts.  Thus, although

several of the major sources of contamination would be eliminated,
                                  V
situations like this one may continue to occur due in part to uncor-

rected existing problems (e.g., abandoned dumps and contaminated

river and harbor sediments), and in part to unregulated waste streams

(e.g., those from households and from generators not producing more

than 100 kilograms per month, and unlisted, potentially toxic

wastes).

     The problem of dealing with existing sites which cannot be modi-

fied to qualify for a permit is not specifically addressed in the

regulations.  These sites include marginal operations which may be

abandoned rather than complying with the closure procedures outlined

in the regulations.  It is likely that these facilities cannot be

properly closed without removing all the waste materials and the con-

taminated soils from the site, as illustrated by the following ex-

ample:

     •  During the 1960's, chromium from a waste lagoon in New Jersey
        contaminated several wells and a nearby stream.  The contam-
        ination continued for about 10 years before the problem was
        recognized in 1970.  By then, the total chromium concentra-
        tion was 150 ppm at a well 700 feet from the lagoon.  Since
        then, the source of contamination has been eliminated, but

                                 7-144

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        the plume of polluted groundwater is still there.  As a
        result, a former municipal drinking water well is currently
        used for industrial purposes only (Office of Solid Waste,
        Hazardous Waste Management Division, 1978b).

     In such cases, the regulations would provide the beneficial im-

pacts of identifying the unacceptable facilities and preventing their

continued use, although the procedures for preventing the on-going

pollution from wastes already in place at such sites are not clear.

     An analogous situation is the problem of former disposal sites

which have already been abandoned.  These sites may or may not even

have been recorded.  Due to the often long time periods required for

groundwater contamination to progress to the point where it is iden-

tified, such sites have the potential for creating severe problems

over the next few years.  This problem is particularly important in

light of the recent EPA study (U.S. Environmental Protection Agency,

1977c) reporting that at least 43 out of 50 randomly chosen landfills

which had never been suspected of leaking, were, in fact, contribu-

ting to groundwater contamination, with wells at 26 of the sites

exceeding U.S. Drinking Water Standards.  The major impact of the

regulations would be to prevent the creation of such problems in the

future, though discoveries of groundwater pollution due to improper

hazardous waste disposal in the past would probably continue to occur

for some time to come.

     7.1.6  Public Health Impacts.  Inadequate hazardous waste man-

agement practices have frequently led to cases of injury to human

health.  The two major pathways by which public health may be

                                7-145

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affected by hazardous wastes are direct contact (e.g., occupational



exposure) and secondary contact (through the media of contaminated




air, water, or soil).  The severity of the potential impacts is




illustrated by the numerous incidents described in Appendix J.  This



appendix documents 49 separate instances of traceable public health



effects, including deaths, and 84 instances of contamination of




drinking water, including major water supplies.




     From the way in which most of the reported incidents have come



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



go unreported.  Factors which contribute to under-reporting are the




long periods of exposure and/or gestation often required before




health effects are noted, the difficulties in establishing direct




causative relationships, and the synergistic effects of exposure to



pollutants from other sources in addition to hazardous wastes.



     As discussed in Chapter 6, the quantities of potentially hazard-




ous waste generated are expected to increase both as a result of ex-



panding industrial outputs and the progressive implementation of air




and water pollution control programs, ocean dumping bans, and associ-



ated environmental legislation.  Thus, in the absence of specific



regulations, inadequate hazardous waste management could be expected




to continue to result in numerous cases of potentially severe health




effects.



     Further, as witnessed by the examples cited in Appendix J, there




is often a considerable time lag between the occurrence of a






                                 7-146

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contamination event and the time at which its impact becomes evident.

Since virtually all the reported incidents were discovered only after

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

potential for many similar public health impacts to be detected from

wastes that have already been or currently are being improperly

transported, stored, treated, or disposed.

     A major incident recently came to light which illustrates the

magnitude of the potential health effects which can occur in the ab-

sence of regulatory control.  Although the incident was only recently

brought to national attention, its history dates back to 1947, when a

chemical company in Niagara Falls, New York used Love Canal as an

industrial toxic waste dump:

      •  Thousands of drums containing toxic chemicals were dropped >
         or buried into the receding water of Love Canal and its
         banks.  The site was last used as an industrial dump in
         1952.  In 1953, the surrounding land was sold and a school
         and homes were built on the site.  During the construction
         of the La Salle Expressway to the south of the original
         landfill site, noxious fumes, corrosive waters, and oily
         materials were encountered, according to State personnel and
         local residents.  When other locations within the 16-acre
         site were also developed, drums were exposed during excava-
         tion work allowing the release of noxious fumes and oily
         liquids, causing several work stoppages.  Noxious fumes and
         hazardous liquid chemicals were also detected in various
         storm sewers throughout the site.  To date, land subsidence
         in the grammar school playground, located over the actual
         canal and landfill, occurs regularly.  The subsidence holes
         are periodically filled with soil.  School personnel have
         reported to the County Health Department that children have
         received burns while handling waste phosphorus (Fred C. Hart
         Associates, Inc., 1978).  Organic contaminants have surfaced
         over the fill of the canal and in residential backyards.
         All through the 1970's, residents have experienced unpleas-
         ant odors in their cellars, particularly after rains during
         the summer.  Basement sump pumps have also been affected by
         oily liquids.
                                 7-147

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In 1976, after six years of abnormally heavy rains, the canal
overflowed its underground banks and at least 82 different
compounds, 11 of them suspected carcinogens, began percolat-
ing upward through the soil into backyards and basements of
the homes and school along the canal site.  Air monitors
placed by the EPA in the basement of surrounding homes have
detected significant levels of benzene and 24 halogenated
organic compounds, with concentrations of total halogenated
organics ranging from 8 to almost 1800 micrograms per cubic
meter in seven locations (Fred C. Hart Associates, Inc.,
1978).

The more common contaminants have been identified and mea-
sured in the analytical work done by several private con-
tractors.  Several of the chemical compounds detected are
listed on the U.S. Environmental Protection Agency's list of
priority Toxic Substances, as established by the Natural Re-
sources Defense Council Consent Decree in 1976, and iden-
tified as potentially carcinogenic, teratogenic, and/or
mutagenic.  Among the substances identified in samples of
ponded water by the Division of Laboratories and Research,
New York State Department of Health were trichlorophenol,
lindane, hexane, methyl cyclopentane, benzene, toluene,
chlorobenzene, benzychloride, dichlorobenzene, ortho-
dichlorotholuene, trichlorobenzene, and tetrachlorobenzene
(Fred. C. Hart Associates, Inc., 1978).

Although the site has not been used as an industrial dump in
over 25 years, the recent adverse effects to human health
have been numerous.  Children and dogs have been burned while
playing in the fields, people have had the soles of their
shoes corroded through, backyard trees have been killed by
chemical action, gardens have been destroyed, fence posts
have been eaten away, and local residents have indicated that
many persons in the neighborhood have died of rectal, blood,
and breast cancer.  New York State Department of Health
studies of the residents of the area indicate a prevalence of
problems in the areas of fetal malfunctions, miscarriages,
and liver disfunctions (Fred C. Hart Associates, 1978).  In
the area to the south of the canal, four out of 24 children
were born with malfunctions.  Malformations in the female
children included subcleft palate, deformed ears and teeth,
hearing defects, mental retardation, abnormalities of the
renal pelvis, and ureters with reflux.  In the male children,
congenital deafness occurred.
                        7-148

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        Data collected by the City of Niagara Falls identified 20
        homes where wastes were volatilizing and infiltrating into
        basements. Further investigation has indicated that an ad-
        ditional 10 homes are also affected.  According to Calspan
        Corporation (1977b), extensive abatement measures will be
        necessary to protect the health of the residents of these
        homes.  The recommendations include the installation of
        sealed sump pumps, and the sealing of basement walls and
        floors with an epoxy paint.

        The specific causes of the health and safety hazards that
        have occurred at Love Canal are numerous; however, the sub-
        surface migration of hazardous pollutants continues to pose
        the major problem.  On June 21, 1978, an Emergency Health De-
        claration under the State Public Health Law, Section 1303,
        was issued for the Love Canal site.  Further investigation on
        this area is planned.

     One of the major stated objectives of the Resource Conservation

and Recovery Act is to promote the protection of health and the envi-

ronment.  Implementation of the baseline regulations would result in

the institution of a program of responsible hazardous waste manage-

ment which would decrease the incidence of uncontrolled releases of

hazardous wastes to the environment.  This program is designed to

meet the above objective by limiting both direct and indirect public

exposure to hazardous wastes.  Direct exposure would be reduced by

requirements for treatment, storage, and disposal in permitted facil-

ities with minimum separation distances from buildings, roads, and

water supplies; by facility personnel training requirements; and by

facility security requirements.  Indirect exposure would be reduced

by limiting the movement of hazardous constituents of the wastes

through air, water, and soils, as discussed previously.
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     The following sections briefly describe the public health im-



pacts of some of the specific sections of the regulations.




     7.1.6.1  Generation.  Except for incidents due to occupational




exposure, few health incidents have been documented as having



occurred during the generation stage of hazardous waste management.



Host health incidents are related to subsequent transport, storage,



treatment, or disposal.




     Generators of hazardous wastes would not be permitted to dispose




of such wastes on-site without also receiving a permit as a disposal



facility and complying with the Section 3004 regulations.  Further,



any on-site storage for 90 days or more would also require a storage




permit.  As discussed previously, these requirements would effective-



ly reduce environmental contamination with hazardous wastes due to




illicit disposal activities or improper storage procedures by genera-



tors.  However, as also discussed in previous sections, a small quan-



tity of potentially hazardous wastes would escape regulation due to



exemptions and exclusions for households, retailers, and farmers, and



due to the generator limit of 100 kilograms per month.  Although it



is expected that regulations promulgated under other Acts would




partially control these wastes, the uncontrolled fractions could be



disposed as nonhazardous wastes using practices such as discharge to



sewer systems or any other conventional disposal method (though such



disposal would have to conform to regulations promulgated under



Section 4004 of RCRA).  However, the reduced degree of control for






                                 7-150

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this fraction could conceivably result in the eventual contamination



of some surface waters and in subsequent potential human exposure.



However, the effects of these exclusions would be much less harmful




to public health than those which occur now in the absence of any




hazardous waste regulations.  Thus, although it is true that some




unregulated releases of hazardous wastes could continue to occur, and




that some hazardous wastes may cause significant damage in any



amount, such occurrences would be much less frequent, and generally



less severe than those which occur in the present, uncontrolled case.




     7.1.6.2  Transport.  The regulations regarding the transport of



hazardous wastes could be expected to favorably affect public health



by reducing the potential for incompatible wastes to be combined for




transport, by requiring use and maintenance of adequate containeriza-



tion, by extending the DOT regulations to specifically include intra-




state, international, and interstate transport of hazardous wastes,



and by providing for spill notification and abatement procedures.




These regulations would enhance the measure of protection afforded to



persons involved directly with the transport of a waste and to the




general public.



     Without the promulgation of regulations for the transport of



hazardous wastes, incidents similar to those described in Appendix J



could be expected to continue to occur.  One of the more serious cur-




rent problems associated with the transport of hazardous wastes is



that, in the absence of a manifest tracking system, willful dumping
                                 7-151

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is very difficult to control.  Such dumped material is frequently



placed in a location where environmental degradation can occur, with




resultant adverse public health effects.  Both Sections 7.1.4  and



7.1.5 discuss the types of environmental degradation that can occur




in the absence of hazardous waste regulation during transport.  The




institution of a manifest system would allow enforcement agencies to




relatively easily locate the responsible parties for any dumping in-




cidents involving hazardous wastes subject to these regulations.




These regulations, in combination with hazardous spill regulations to



be promulgated under the newly amended Section 311 of the Clean Water




Act, would act as a deterrent to anyone contemplating such activ-




ities.



       Any increase in the amount of hazardous wastes transported to




off-site facilities, or in the distance over which the wastes are



moved, would create a potential for increased health effects due to



hazardous spills from transport accidents.  Although the containeri-



zation and other requirements would reduce spillage en route due to




leakage or poor packaging, the regulations would not significantly



affect accidents due to collisions or derailments.




     7.1.6.3  Treatment, Storage, and Disposal.  It is in this area




that the regulations would provide the most significant benefits to



public health.  The Section 3004 regulations would effectively



insulate the public from regulated wastes by requiring all storage,




treatment, and disposal to be restricted to permitted facilities that
                                 7-152

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would be designed and operated Co prevent harmful discharges.  As in

the case with transporters, implementation of a manifest system and

periodic reporting requirements would facilitate tracking the wastes

to ensure that they are received at a permitted facility.  The regu-

lations would require periodic inspections by facility personnel and

would give the Regional Administrator authority to perform additional

inspections to ensure that the facility does not violate its permit

conditions.  Restrictions on siting, including a minimum separation

of 200 feet between the active portions of a facility and its proper-

ty line, and 500 feet between active portions of disposal facilities

and public, private, or livestock water supplies would further con-

tribute to the reduction of adverse public health effects.  Rules for

segregating wastes within a facility and prohibiting the mixing of

incompatible wastes, as well as rules requiring employee training

programs for hazardous waste facility personnel, would reduce some of

the adverse health effects due to occupational exposure.

     Public health would be further enhanced by the increased.pub lie

awareness of the potential dangers of hazardous wastes.  The labeling

requirements for containers and transport vehicles used in connection

with hazardous waste and the public participation procedures which
                                    4
would be required under the Subtitle C regulations, as well as other

related regulations, would act to reinforce the mounting publicity

given to the potential dangers associated with the improper

management of hazardous waste.  Thus, though these regulations
                                 7-153

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specifically exclude households, most retailers, and most farmers

from the requirements, the regulations may indirectly provide some

reduction of the harmful effects associated with wastes from these

generators as well.  The following subsections discuss specific

public health benefits with respect to storage, treatment, and

disposal of hazardous wastes.

     Storage.  Although numerous reported incidents of environmental

contamination have resulted from improper storage of hazardous waste,

most reported incidents have not been directly identified as causing

adverse health effects.  However, there have been several reported

cases of health effects due to occupational exposure.  A typical

example of an occupationally-related incident from improper hand-

ling procedures at a storage facility is as follows:

     t  An employee was transferring two 5-gallon cans of waste vinyl
        cyanide and water from a still to a supposedly empty waste
        drum.  As the employee rolled the drum to a storage area
        across the road, it exploded.  The exothermic reaction cata-
        pulted the drum into a steel guard post, spraying the con-
        tents, causing thermal and possible chemical burns to the em-
        ployee (DeVera et al., 1977).

     •  In another incident 18 persons were exposed to deadly fumes
        from a stored canister of rat fumigant.  The stored canister
        was leaking a mixture of methyl bromide and chloropicrin.  At
        least 21 persons were affected by the incident including
        seven firemen who were hospitalized.  Two of the firemen have
        since retired with permanent disabilities.  Among the effects
        suffered from the gas incident are permanent lung damage to
        two individuals, and possible brain damage to another (Office
        of Solid Waste, Hazardous Waste Management Division, 1978b).
                                7-154

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     As can be seen from these incidents, the lack of regulation over




the storage of hazardous wastes has resulted in impairment to the



health of many persons.  Stored wastes have often been forgotten or



abandoned.  The regulations for storage should significantly reduce




the possibility for stored wastes to be abandoned or forgotten for



extended periods of time.  In compliance with the regulations, any




generator who stores hazardous wastes for a period exceeding 90 days,




and all off-site storage facilities would have to obtain a permit and



would be subject to recordkeeping and reporting requirements.  As



discussed in Section 7.1.5, no discharges would be permitted from




storage facilities.  Without these regulations, various occurrences



resulting in fires, explosions, the emission of toxic fumes or dusts,



and ground and surface water degradation due to reactions, corrosion,




or leaks have resulted.  Each such unexpected occurrence would have



the potential to impact public health.  See Section 7.1.4 for the



sources of emissions that may occur as a result of storage activities




and Section 7.1.5 for the related sources of water contamination that



may affect public health.



     Treatment/Disposal.  The most common method of treatment for




hazardous wastes involves the use of lagoons or stabilization ponds.



This method of treatment relies on the process of settling and evap-



oration.  Prior to the implementation of regulations, wastes have




been treated in unlined ponds or lagoons, or in otherwise unaccept-



able containment- areas.  Such treatment areas have frequently been
                                7-155

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subject Co seepage and subsequent groundwater contamination; overflow

or rupture, and subsequent surface water contamination; and/or air

emissions of potentially harmful volatile substances.  The potential

for, and interactions between, these occurrences are discussed in

previous sections.  Many such occurrences have considerable potential

for public health problems.

     An example of the type of health effects which have occurred as

a result of both direct and indirect exposure to hazardous wastes

during unregulated treatment is as follows:

     •  A chemical company dumped chemical solvent wastes at a quarry
        in Maryland between 1960 and 1974, often leaving the chemi-
        cals open to evaporate before covering them up.  Residents in
        the quarry area as well as company employees had complained
        of headaches, nausea and vomiting, chronic fatigue, weight
        loss, and memory loss—classic symptoms of chemical fume ex-
        posure. One doctor found that seven out of eight area resi-
        dents he had examined had abnormalities of the liver and/ or
        pancreatic functions.  Another doctor found carbon tetra-
        chloride, which is highly toxic to the liver and kidneys, in
        the blood of three area residents.  Cancer deaths from
        lymphoma malignancies were found in the quarry area and among
        employees to be 44 times higher than the national incidence.
        The death rate was 2.2 times greater than that of the rest of
        the county.  The death rate due to cancer was seven times
        greater than that for the county, the victims usually living
        within direct proximity to the chemical plant. Among the
        solvents dumped at the site were benzene, which is known to
        damage blood-forming organs and to cause leukemia; carbon
        tetrachloride, acetone, ketones, and methylene chloride.
        Many of these substances, when measured, were found to be
        present in abnormal amounts in the air at the site.  The
        company was ordered to cease dumping at the quarry in 1974,
        and by 1975 had removed most of the wastes (Office of Solid
        Waste, Hazardous Waste Management Division, 1978b).

     The Subtitle C regulations would control such activities under

the requirements for surface impoundments and ponds.  As discussed in
                                 7-156

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the sections dealing with air and water impacts, the regulations



would significantly decrease the release of hazardous contaminants to




the environment from such facilities.  Such decreases would result in




corresponding decreases in the adverse impacts of hazardous wastes on



public health.



     Other forms of treatment addressed by the regulations include




incineration; landfarms (if wastes are removed at closure); and chem-



ical, physical, and biological treatment facilities.  Except for



landfarms, each of these treatment methods is to be regulated in much



the same way.  Each must comply with any other applicable regula-




tions, such as those for storage facilities and basins, and those



affecting facility siting, security, and personnel training; each




must manifest its wastes if they meet the Section 3001 regulations;



and each must remove all wastes at the time of facility closure.




     The effects of these regulations on air, water, and soil contam-



ination are discussed elsewhere.  Any decrease in the contamination



of these media would result in corresponding decrease in adverse im-




pacts on public health.  Additionally, the regulations would directly



affect the health of facility personnel, through improvements in em-



ployee training, standards for facility design, requirements for doc-



umentation and verification of waste composition, and through the




requirements for the creation of emergency contingency plans to deal



quickly and knowledgeably with any accidents.
                                 7-157

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     Two graphic examples of occupationally-related incidents Chat

occurred during the treatment of hazardous wastes resulted in fatali-

ties which might have been avoided if the personnel were adequately

trained:

     •  Two youths were cleaning scale from a cyanide plating waste
        tank at a treatment plant.  When they were checked during the
        afternoon, they were using their safety equipment, the cya-
        nide level in the tank had been checked, there was positive
        purge in the air lines, and work was progressing normally.
        Later, both were found dead, the compressor for the purge had
        been turned off, and the gas masks had been removed.  Appar-
        ently a cyanide pocket had been encountered (Office of Solid
        Waste, Hazardous Waste Management Division, 1978b).

     •  Two men died as a result of fatal burns received at a metal
        processing plant.  One employee was working off an elevated
        work platform while the other man was operating a forklift.
        The resulting injuries were caused by contact with the ex-
        treme temperatures of a hydrogen explosion and zirconium
        fire.  The explosion and fire were caused when zirconium
        shavings, contaminated with oil and dirt, were dumped from an
        unlined 55-gallon steel drum into an unlined steel hopper to
        be scrubbed in water and detergent.  Ignition of the shavings
        through friction resulted in a violent explosion and fire
        that engulfed the two workmen (State of Oregon, Accident Pre-
        vention Division, 1975).

     Landfarming may.be considered as a treatment (if the wastes are

removed during closure), or as ultimate disposal (the proposed regu-

lations would not require removal of the wastes if the landfarm can

be closed so that food chain crops could be grown on the treated area

without violating specified human consumption standards).  In evalu-

ating the use of land application for hazardous wastes, consideration

must be given to the potential for offensive odor nuisances and pub-

lic health hazards that are peculiar to the use of spray irrigation

systems.  Groundwater quality is a primary consideration; however,

                                 7-158

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Che effect of aerosols, physical contact with the waste by the public



or facility employees, insects and rodents, isolation from the pub-



lic, stormwater runoff and erosion from the site, and contamination



of crops and potential for bioaccumulation, are all important effects




that are possible in any disposal method.




     Odors generally result from the spraying of industrial waste-



water that has been inadequately treated or has not been treated at



all prior to land application or lagooning.  The condition may be




compounded by excessive ponding at the irrigation site.  Sludge ap-




plication to the land potentially poses a relatively more serious



odor problem if not handled properly.  At this time almost all states




either prohibit or strictly regulate the use of this method of land



disposal in areas where crops are grown for human consumption (Was-




botten, 1976).  Information on the causes of groundwater contamina-



tion, the resulting discharges to the environment, and on the impacts



of the regulations on such discharges can be found in Section 7.1.5.



To the extent that the regulations for landfarms would reduce the po-



tential for water contamination, they would also reduce the potential



for adverse public health effects.




     Disposal.  The types of ultimate disposal facilities addressed



in the proposed regulations are landfills, some surface impoundments,



and some landfarms.  The public health effects of the regulations




concerning surface impoundments and landfarms are discussed above.



Additional requirements affecting public health include minimum






                                7-159

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separations from water supplies, maintenance of permanent records of



waste types and locations, restrictions on the types of wastes which



may be landfilled, application of daily cover on active cells, and




requirements for postclosure maintenance.



     These regulations should effectively prevent the creation of




future health disasters such as that which occurred at Love Canal.




Additionally, the regulations should also contribute to an overall




decrease in exposure to low concentrations of hazardous substances



resulting from environmental dispersion of hazardous wastes.




     Several sources of potentially adverse health effects would re-



main unaffected by these regulations.  As previously discussed, some




potentially hazardous wastes would not be regulated under the Sub-




title C regulations.  Further, EPA does not have the authority to



promulgate regulations concerning inactive and abandoned hazardous



waste disposal sites.  From the incidents discussed in this chapter



and those presented in Appendix J, it is apparent that there may be



many hundreds of such sites scattered around the country, whose loca-



tions may not even be recorded.  The potential for health disasters




caused by these sites is considerable.




     However, in spite of these omissions, it is evident that the



regulations would result in substantial benefits to public health




through the reduction of both chronic and acute exposure to contamin-



ation resulting from improper handling and disposal of hazardous



wastes.  The regulations have the potential to control and require
                                 7-160

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Che safe disposal of nearly 40 million metric Cons of hazardous



wastes per year by 1984.  In the absence of the regulations, these



wastes would have a significant potential to cause environmental deg-




radation and subsequent severe human health effects.



7.2  Potential Secondary Impacts



     The potential secondary impacts from implementation of the base-




line regulations include impacts to the following areas:



     •  Physiography and soils;



     •  Biological environment;




     •  Social impacts;



     •  Hazardous waste management facility capacity;




     •  Land use;




     •  Water'usY;



     •  Resource conservation and recovery;




     •  Energy use;




     •  Special interest points.



     7.2.1  Impacts to Physiography and Soils.  The principal areas



of environmental concern pertaining to physiography and soils




include:



     o  Alterations of topography;



     o  Loss and physical disruption of soils;




     o  Soil contamination.



     Physiography and soils are impacted by hazardous wastes in many



ways.  In the existing unregulated situation, the major adverse
                                7-161

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effects resulting from the management of hazardous waste relate to

soil contamination through indiscriminate disposal.  If the baseline

regulations are implemented, adverse effects to soils and physiogra-

phy would still occur, though their nature and severity would change.

For instance, soil contamination would still occur, but in more con-

trolled situations where the physical area affected is limited and

contaminants are retained at one location.  Erosion of disposal sites

would be reduced, though physical disruption of the soils may in-

crease during construction of facilities.

     As a result of the regulations, it can be anticipated that there

would be considerable effort made to upgrade and expand existing

process capacity and physical capacity and also to develop new

treatment and disposal facilities.  The effects of such activities

would be site specific in nature and would have to be addressed on a

case-by-case basis.  However, the types of potential impacts that

could result can be discussed generically in terms of facility

construction, facility operation, and facility closure.

     7.2.1.1  Facility Modification and Construction.  The

modification or construction of hazardous waste management facilities

would involve several types of effects on physiography and soils:

     •  Alteration of site topography;

     •  Alteration of off-site topography due to excavation of
        materials for liners and soil barriers;

     •  Loss of soil through erosion;
                                 7-162

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     •  Alteration of soil physical properties by disturbance and
        compaction;

     •  Degradation of soil quality by pollutants generated by
        construction vehicles, equipment, and materials.

     Most of these impacts are inevitable consequences of construc-

tion operations in general and are thus not unique to hazardous waste

facilities.  Any such impacts would be extremely site-dependent.

     The Subtitle C regulations would require the use of natural or

artificial liners of specific thicknesses and structural characteris-

tics for landfarms and surface impoundments.  Storage facilities and

basins would be required to use impermeable, continuous bases.  All

facilities would have to have diversion structures capable of divert-

ing the runoff from a 24-hour, 25-year storm  and would also have

to construct some means of containing any runoff from the site.  Land-

farms would have to be graded such that their slope would be between

zero and 5 percent, and such that no ponding of water occurs.  All of

these regulations would involve alteration of off-site and/or on-site

topography, and alterations of physical properties of the soil.

     In most cases, the adverse environmental impacts of such actions

would be negligible.  The most significant impacts would occur during

the construction of large landfills or surface impoundments which

cannot use the natural in-place soils as liners.  A two acre landfill

not using a synthetic liner would require about 8,000 cubic yards of

silty clay soils for its liner, plus about 1,000 cubic yards of
*A storm of 24-hour duration whose frequency of occurrence is once
 in 25 years.

                                7-163

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permeable materials for the leachate-drain layer.  Additional soils

would be required for daily operation and closure.  Surface impound-

ments would require a larger amount of clayey soil for construction

of dikes around the impoundments.

     7.2.1.2  Facility Operation.  Principal impacts on physiography

and soils that may result from the operation of hazardous waste

facilities include:

     •  Erosion, sedimentation, and other geomorphic processes;

     •  Soil contamination by hazardous materials during the course
        of normal operations or as a result of accidental
        discharges;

     •  Alteration of the physical properties of soils by equipment
        usage and other operational maintenance activities;

     •  Induced geological instability (e.g., micro-earthquakes).

     Soil contamination would be an especially important concern,

especially because soils are widely used as an ultimate sink for the

disposal of hazardous wastes (Davidson, et al., 1976).  Numerous

instances of soil contamination by accidental discharges of hazardous

wastes have been documented.  Many of the incidents of hazardous

waste impacts that are cited in the sections of this chapter dealing

with impacts to air, water, and the biological environment pertain to

soil and soil contamination and are not repeated here.  Suffice it to

note that the soil contamination is a frequent result of current haz-

ardous waste management practices.
                                7-164

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     The Subtitle C regulations that would specifically address

physiographic and soil aspects of facility operation include the

following:

     •  Groundwater and leachate monitoring systems are to be in-
        stalled at all hazardous waste treatment, storage, and dispo-
        sal facilities (except landfarms) that have a potential for
        groundwater pollution;

     •  Soils of the treated area of landfarms are to be monitored
        for vertical migration of the waste or its consituents;

     •  Landfills and landfarms are to be located, designed, con-
        structed, and operated to prevent erosion, landslides, and
        slumping;

     •  Landfarms are to be sloped at less than 5 percent to prevent
        erosion, but greater than zero percent to prevent wastes or
        water from ponding or standing;

     •  All earthern dikes used for surface impoundments are to have
        an outside protective cover to minimize erosion by wind or
        water.

     •  Contingency plans are required at treatment, storage, and
        disposal facilities to minimize adverse impacts of subsurface
        discharges of hazardous materials;

     •  Soils contaminated by accidental discharges from hazardous
        waste facilities are to be considered to be a hazardous waste
        and are to be managed accordingly.

     The regulations are expected to have the following impacts:

     •  A substantial reduction in the contamination of soils in
        areas surrounding treatment, storage, and disposal facilities
        owing to specific provisions pertaining to soils as well as
        measures designed to prevent contamination of air and water
        quality, including accident contingency plans;

     •  A substantial reduction in soil contamination resulting from
        disposal of hazardous wastes at unauthorized and unsuitable
        sites;

     f  A reduction in erosion, sedimentation, and landslides at
        landfarms, landfills, lagoons, and ponds;

                                7-165

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a-.,1  V
                   •  Substantial upgrading of the disposal of soils subject to
                      accidental exposure of hazardous wastes discharges from
                      treatment, storage, and disposal facilities.

                   7.2.1.3  Facility Closure.  The impacts on physiography and

              soils that would occur as a result of facility closure are similar to

              those which would occur during construction.  Basins, storage facili-

              ties, treatment facilities, some surface impoundments, and some land-

              farms would have to be emptied of hazardous wastes, including any

              soils rendered hazardous during operations.  The primary impacts that

              these facilities would have on physiography would be due to the

              requirement for filling the empty impoundments and resultant changes

              in topography.  The removal of wastes from these facilities could

              increase the potential for impacts at the ultimate disposal site.

                   Landfills, some surface impoundments, and a few landfarms would

              be the ultimate disposal sites for hazardous wastes.  The minimum

              final cover depth for a landfill would be 15 centimeters (6 inches)

              of clay soil under a minimum cover of 45 centimeters (18 inches) of

              soil capable of supporting indigenous vegetation.  If deep-rooted

              vegetation is to be planted on site, the minimum cover thickness

              would be at least 1 meter (3 feet) of compacted soil.  Surface

              impoundments would have to be treated to render their solids content

              greater than 20 percent, and then closed in accordance with the

              requirements for landfills.  It is probable that a very large volume

              of soil would be needed to adequately cover and contain such a

              semi-solid mixture of hazardous wastes.  Landfarms would have to be
                                             7-166

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closed such that food chain crops could be grown on the treated area



without resulting in human consumption of substances listed in the




EPA Primary Drinking Water Standards, or food additives banned by the



U.S. Food and Drug Administration.  Since the landfarm design and




operation regulations would prevent waste migration from the site



(i.e., all wastes would remain at the site), meeting the closure




requirements without removing the wastes could be difficult.  Closing




such a facility would probably (at a minimum) require burial with




sufficient soil to prevent the roots of the crops from ever reaching



the wastes.  Additionally, a protective impermeable layer may be




necessary to prevent leaching of wastes by percolating irrigation



waters.



     7.2.1.4  Transportation of Hazardous Wastes.  Provision for the



extension of existing interstate safeguards to all intrastate trans-




port of hazardous wastes could reduce the relative frequency of



accidental spills and associated incidents of soil contamination.




Conversely, increases in the distances over which hazardous wastes



were to be transported could off-set some of this benefit.  Manifest




requirements should eliminate most incidents of dumping and improper



disposal and their resultant impacts to soils.  Contamination




incidents due to improper cleaning of vehicles could be greatly



reduced and improved spill contingency measures could reduce soil




exposure to hazardous wastes.
                                7-167

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     7.2.2  Biological Impacts.  This section addresses potential




impacts of the proposed regulations in terms of:  1) the welfare and




status of non-human biota, ecological systems, and habitats; 2) the




human amenities that are derived from these resources.  The scope of




the section includes agricultural as well as natural systems.




     Of particular importance from the perspective of biological




effects is the nature of hazards posed by waste materials to living




systems.  Two relevant aspects are the hazardous nature of the mate-




rial in question, and the degree to which environmental systems may




be exposed to the hazard.  The latter factor is dependent on the par-




ticular conditions under which hazardous materials are handled and




disposed.  As shown in Table 7-13, intrinsic harmful properties of




hazardous wastes to living systems include:  flammability, reac-




tivity, toxicity, bioconcentration, and genetic change.




     An equally important consideration is the response of biological



and ecological systems to the stresses imposed by hazardous wastes




and their management.  The specific responses would depend on  the




amounts and types of hazardous materials involved, the modes by which




living systems were to be exposed, and other sources of environmental




stress, as well as the organisms involved.  Because of the wide range




of materials and methods involved in hazardous waste management, and




of tolerances of different types of organisms, effects on living sys-




tems vary substantially and would be situation dependent.  However,




as shown in Table 7-14, it is possible to generalize about the ways





                                7-168

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                                                                             TABLE 7-13

                                                    PROPERTIES OF WASTES THAT ARE HAZARDOUS TO LIVING SYSTEMS*
               Hazardous  roperty
                                        Types of wastes Involved
                                                                                               Hazards Co living aystens
               Planmablllty
                                     Contaminated solvents
                                     Oils
                                     Pesticides
                                     Plastlclzers
                                     Complex organic sludges
                                     Off-apeclfleatlon chemicals
                                   An acute and latent danger to organisms and habitats.   Kill radii of 115 ft.
                                   and 230 ft. may be associated with Ignition of 9,000 gal.  and 30.000 gal.
                                   tank cars of flammable liquid.  Because of large volumes of wastes, danger
                                   at disposal sites nay be greater than In transportation.  Secondary fires
                                   and detonations may occur.  Plammablllty Is a hazard during all phases of
                                   the hszardous waste cycle.
               Reactivity
                                     Explosive manufacturing
                                      wastes
                                     Contaminated Industrial
                                      gases
                                     Old ordinance
                                   An acuta and latent danger to organisms snd habitats. Detonation may be
                                   caused by thermal or mechanical shock, electrostatic charge or contact of
                                   Incompatible materials.  Kill radius la typically less than for comparable
                                   volumes of flammable liquids.  Detonation may result In secondary explosions
                                   or fire.  Eesctlvity may occur at all phaaes of the hazardous ussta cycle and
                                   may pose a greater danger after disposal If sufficient amounts of reactive
                                   material are accumulated.
T1
VO
              Toxiclty
Toxic wastes may be derived
 from any Industry. (Toxi-
 clty may result from pure
 compounds, combined effects
 of more thsn one component
 or combined action of two
 Individually non-toxic
 materials).
The capability to produce Injury upon contact with a suitable sice on or In
the body.  Wastes may be acucely or chronically hazardous to plants or
animals.  Phytoxlc tfsstes may reduce chlorophyl production, retard growth or
Interfere with specific chemlcsl processes when present In soil, atmosphere
or water.  In mammals, acutely toxic wsates may cauae damage via Inhalation,
ingestIon, or skin contact.  Chronic coxlclty may occur for materials that
are bloaccumulated or that cause cumulative Irreversible damage.  In aquatic
organisms, toxlclty often results from the transfer of toxic materials across
ths gill membranes.  Wstsr Is probsbly the most common vector, but atmospheric
emissions may be more readily dispersed.  Direct contact Is the most easily
controlled route of exposure.  Exposure of organisms to toxic subscsnces may
occur In all phases of the hazardous waste cycle.
              Bloconcentratlon
                                     Various elements and compounds
                                     Including:  cadmium, lead,
                                     mercury, polychlorlnated
                                     blphenyls, carbon tetra-
                                     chlorlde
                                   The hazard posed by materials that are concentrated In an Individual organism
                                   or magnified at successive levels of the food chain until toxic concentrations
                                   are reached.  Threshold levels of toxicity often occur in vertebrates.  Includ-
                                   ing man, and may result in death.  Bloconcentration generally occurs when a
                                   contaminant is present in low ambient levels and is probably of greatest danger
                                   following the disposal of waate materials.
              Genetic Change
               Potential
Dye plant wastes
Petroleum sludges
Carcinogenic, mutsgenlc or teratogenlc effects on organisms, as evidenced by
mltotlc or meiotic malfunction.  Exposure is usually by direct and continuous
route.
                       *Bnttelle Psclfic Northwest Laboratories. 1973 .

-------
                                                  TABLE 7-14

                           GENERALIZED PATTERNS OF THE RESPONSE  OF BIOLOGICAL
                          SYSTEMS TO INCREASED LEVELS OF ENVIRONMENTAL STRESS*
 Degree

of Stress
                            Response at  Indicated level of organisation
   Individual' "organism
                                               Population
                                    Specie*
                                                                                         Community
Moderate
-Son* metabolic end behav-
 ioral Interference.
-Reduced competitive  abi-
 lity.
-Reduced realeteace to
 paraeltee and predators.
-Reduced capacity for re-
 production.
-Reduced competitive ab-
 ility of most  sensitive
 Individuals.
-Some genetic selection
 for more tolerant  Indi-
 viduals.
                                                                             -Host sensitive popula-
                                                                              tions undergoing selec-
                                                                              tion for hardiest lndl->
                                                                              vlduala. hence losing
                                                                              genetic diversity.
                                                                             -Most tolersnt popula-  .'
                                                                              tlons little affected.
                                                                                              -Noticeable shifts In re-
                                                                                               lative species abundance
                                                                                               as the aoat sensitive
                                                                                               species euffer reduction
                                                                                               in numbers while more
                                                                                               tolerant competitor ape-
                                                                                               clea remain the same or
                                                                                               Increase In abundance.
 I
t-'
o
             ^-Individual  under  heavy
              atreaa  load.
             -Survival  not  In Jeopardy.
Heavy         but individual weakened
             . and susceptible to  para-
             ! sites,  disease, and pred-
              atlon.
             f-Reproduetlon  greatly
              curtailed.
                                         -Elimination of meet
                                         sensitive Individuals.
                                         -Incresse In more tol-
                                         erant Individuals.

                                         -Population level may
                                         or may not be affected.
                                         -Reduction In genetic
                                         diversity.
                                                       -Most sensitive popula-
                                                       tions eliminated.
                                                       -Moat tolerant popula-
                                                       -tlena losing sensitive
                                                       Individuals, hence los-
                                                       ing genetic diversity.
                                                      -Significant  shifts  in
                                                       speclee  composition aa
                                                       sensitive  species sre el-
                                                       iminated and.hardy  com-
                                                       petitors reaaln  and often
                                                       Increase.
                                                      -New  hardy  species ma.  .-.-
                                                       ter  from elsewhere.
Severe
•-Severe metabolic and be-
 havioral Interference.

-Individual aurvlval in
 question.
l-Reproductlon no longer
' possible.
-Survival  of  only  the
 most tolerant-  individ-
 uals.
-Population level  may
 or aay  not be  reduced.
-Severe  reduction  in
 genetic diversity.
                                                                   -Only the hardiest indi-
                                                                    viduals of the most tol-
                                                                    erant populations still
                                                                    survive.
                                                                                                        -Great shifts in species
                                                                                                         composition.

                                                                                                        -Most species reduced or
                                                                                                         eliminated.

                                                                                                        -Bardy species may become
                                                                                                         very sbundant.

                                                                                                        -Total system greatly sim-
                                                                                                         plified.

                                                                                                        -Community metabolism
                                                                                                         greatly modified.

                                                                                                        -Stability severely reduced.
Total
                      Death
                                             Elimination
                                                                           Extinction
                                                                                                      Collapse
       'Darnell. 1976.

-------
in which living systems, from individual organisms Co biological com-

munities, would respond to various levels of environmental stress.  A

moderate degree of stress, such as that which might be caused by air

emissions from a treatment/disposal site, could affect the behavior
                                              •
of individual organisms, reduce the competitive ability of various

population segments and species, and ultimately lead to a shift in

species composition of the community.  At the other end of the spec-

trum, extreme stress, as represented by the massive discharge of

toxic wastes into a stream, could result in the elimination of some

species along a large stretch of the affected stream (see Section

7.1.5.2 for examples of such incidents).

     On the basis of available literature, present knowledge regard-

ing the effects of current non-radioactive hazardous waste management

practices on biological systems are based largely on scattered re-

ports of individual incidents rather than comprehensive surveys or

investigations.  Moreover, available reports deal largely with acute

effects from direct exposure of organisms to high concentrations of

hazardous substances and rarely consider chronic effects resulting

from long-term exposure to low concentrations.  The focus of most

reports has been directed to individual organisms or populations

rather than to communities or ecosystems.

     Determination of hazardous waste effects is complicated by vari-

ous phenomena, including:

     •  Synergistic or antagonistic interactions between waste
        constituents that could enhance or modify overall effects;
                                 7-171

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     •  The importance of the physical and chemical form of the waste
        on the mobility of toxic substances;

     •  The physical and chemical conditions of the receiving waters
        (such as pH, existing oxygen demand and availability, and the
        presence of ions rr materials which could immobilize toxic
        substancesvby precipitation or adsorption or could combine
        with them to increase their toxicity);

     •  Unpredictable nature of interactions between biological
        systems (e.g., bacteria) and hazardous wastes such that the
        end point is more dangerous than the original waste;

     •  Accumulation by mammals of persistent toxic substances such
        that low ambient concentrations may be magnified in tissues
        (Office of Solid Waste Management Programs, 1974a).  It has
        also been established that most pollutants are capable of
        crossing the placenta of mammals; cross effects on features
        have been demonstrated for high mercury and PCB exposure
        (Susten and Raskin, 1976).

     Despite limitations, the available information is sufficient to

establish that current hazardous waste management practices may pose

a substantial threat to biological systems.  Appendix J and the pre-

vious sections of this analysis describe many incidents in which

improper management of hazardous wastes has resulted in damage to

ecological systems.  Analysis of these incidents indicates that the

maj.or routes of hazardous waste transport to biological systems are

as follows (Lazar, 1975):  groundwater contamination via leaching,

surface water contamination via runoff or spills, air pollution,

poisoning via direct contact, poisoning via the food chain, and fire

or explosion.

     The potential effects of the proposed regulations on biological

species and processes can be perceived in terms of principal stages

of the hazardous waste cycle, discussed below:
                                7-175

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     7.2.2.1  Generation.  Improper handling or containerization of




hazardous wastes by generators could expose biological populations




and habitats to hazardous residuals.  Such exposure may result in



death and injury to organisms, the dispersal of hazardous materials,




and the degradation of aquatic, terrestrial, and atmospheric environ-



ments.




     The Subtitle C regulations would require all generators of



hazardous wastes to treat, store, or dispose hazardous waste in a




permitted facility in accordance with the regulations.  A manifest



and reporting system would be instituted to track the wastes and




ensure compliance.  All generators designating wastes for transport




to an off-site facility must containerize that waste in accordance



with DOT hazardous materials transportation regulations in 49 CFR.




The generators managing wastes in on-site facilities must obtain a




permit under the Section 3005 regulations and must comply with the



standards under Section 3004.




     These regulations would result in a decrease in the release of



hazardous wastes to the environment from generators covered by the



regulations.  This decrease would result in reduced air, soil, and




water contamination as discussed earlier, and subsequently in reduced




exposure of biological systems.  To the extent that some potentially



hazardous wastes would remain uncontrolled (see previous sections),




some adverse ecological impacts could continue to occur as they are



at present.
                                 7-173

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     7.2.2.2  Transportation.  Principal biological considerations

associated with hazardous waste transportation include:

     •  Emissions from improperly containerized wastes that may .
        degrade habitat values;

     »  Leakages and spillages of transported wastes that kill or
        injure organisms, degrade habitats, and create odors and
        other nuisances to organisms;

     •  Accidental large-scale discharges of hazardous wastes
        resulting in fires and detonation;

     •  Vehicular emissions;

     •  Vehicular collisions with wild and domestic animals.

     The regulations would require all transporters of hazardous

wastes to comply with the manifest system and to ship all hazardous

wastes to a permitted facility.  They would require specific labeling

and containerization procedures, and prohibit the transport of leak-

ing or damaged containers.  Further, the regulations would extend

certain DOT hazardous material regulations to intrastate transporta-

tion and would reinforce and expand hazardous spill notification

procedures established.by DOT and EPA through the National Response

Center.

     As discussed previously, these regulations would have the poten-

tial for reducing air, water, and soil contamination from uncon-

trolled transportation of hazardous wastes.  Additionally, the poten-

tial for hazardous spills caused by improper containerization during

transport would decrease.  To the extent that these regulations would
                               7-174

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reduce air, water, and soil contamination, there would be a corres-

ponding reduction in ecological degradation and other associated

adverse biological impacts.

     7.2.2.3  Storage.  The principal hazards to biological systems

associated with hazardous wastes storage may result from:

     •  Aerial emissions and effluent seepages from improperly stored
        wastes;

     •  Accidental spills, fires, and explosions of stored
        hazardous wastes during handling.

     The impacts resulting from such events would depend on the

nature and amounts of materials involved and on site specific charac-

teristics.  The regulations would allow no discharge from any storage

facility.  They would require periodic monitoring and inspection to

detect any potential discharges to air or water.  They would require

construction of an impervious, continuous base for the storage facil-

ity and of sturdy, leak-proof tanks and containers.  The regulations

would also require diversion of upland runoff and containment of run-

off and spills in the facility.  With respect to water quality, these

regulations would reduce the potential for water pollution from regu-

lated hazardous waste storage facilities.  Any reductions in water

pollution would result in a corresponding decreased potential for

adverse ecological and biological impacts.

     7.2.2.4  Treatment.  As with other phases of the hazardous waste

cycle, the potential effects of hazardous waste treatment facilities

on living systems would be site-specific and would depend on the
                                 7-175

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types and amounts of materials handled, the processes employed, and

the ecological setting of the facility.

     Any increased treatment of hazardous waste that could result

from the regulations should reduce the dangers associated with haz-

ardous waste disposal, but could increase those associated with the

treatment.  Adverse effects that are principally associated with haz-

ardous waste treatment are:

     •  The substantial land requirements for lagooning and resultant
        pre-emption of habitat and displacement of biological popula-
        tions;

     •  Leachate and overflow problems for lagoons and ponds that are
        improperly sited, constructed, or managed and resultant
        impacts on aquatic systems;

     •  Air emissions from incinerators that may degrade habitats.

     All hazardous waste treatment facilities would be subject to any

applicable section of the standards for hazardous waste storage,

treatment, and disposal facilities.  To the extent that these regula-

tions would reduce or eliminate hazardous discharges from facilities

subject to regulation, adverse biological or other ecological effects

due to improperly conducted treatment operations would be reduced or

eliminated.

     7.2.2.5  Disposal.  The ultimate disposal of hazardous wastes

poses unique and substantial environmental problems.  Major site-

specific problems associated with the handling and disposal of haz-

ardous wastes include:
                                7-176

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     •  Leachate contamination of surface and groundwaters resulting
        in hazards to biota and ecological systems;

     •  Air pollution hazards to vegetation and fauna due to fugitive
        emissions and uncontrolled or incomplete incineration;

     •  Exposure of environmental systems to hazardous materials due
        to indiscriminate or illegal dumping of wastes because of
        insufficient or expensive disposal facilities (Washington
        State Department of Ecology, 1977).

     Improper land disposal of hazardous wastes could result in a

wide range of effects depending on the types and amounts of wastes

involved, site characteristics, and facility safeguards.  The princi-

pal single site-specific concern would likely be the contamination of

surface and groundwater systems, and resultant impacts on organisms

and communities, due to leaching of toxic effluents.  In terms of

future changes, an increase in the number of facilities or in the

volume of wastes handled would be expected to increase the potential

for localized environmental problems while improvements in facility

safeguards and more stringent disposal standards would significantly

reduce the potential for adverse effects.  It is recognized that haz-

ardous wastes by their nature pose a potential threat to the environ-

ment, during either short periods prior to their destruction or over

very long periods for those materials not subject to detoxification.

     A universal impact of hazardous waste disposal facilities, re-

gardless of types of wastes or site environment, is their preemption

of land from other uses including habitat for natural and agricul-

tural biota.  An EPA study has determined that land disposal of haz-

ardous wastes is increasing because of the implementation of air and
                                7-177

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water quality standards and legal limitations on other disposal meth-



ods such as ocean dumping (Office of Solid Waste Management Programs,




1974a).  Legislation of particular importance in this regard includes



the Clean Air Act of 1973 as amended, the Federal Water Pollution




Control Act Amendments of 1972, and the Marine Protection, Research,




and Sanctuaries of 1972, as amended.  Thus, it is likely that terres-



trial biological systems may be subject to increasing potential




stress.  This stress would be greater without the Subtitle C regula-



t ions.




     The regulations would eliminate discharges from hazardous waste




storage, treatment, and disposal facilities to groundwater unless it



can be demonstrated that the discharge would not endanger an under-




ground drinking water source (UDWS).  The regulations would require




that all waterborne effluents including runoff and leachates must be



confined to point sources, and that all point source discharges to



navigable waters must comply with the regulations of the Clean Water



Act.  Since almost any aquifer which could be used as a water source




for wildlife would be classifed as a UDWS, and since navigable waters



is quite broadly defined, these regulations would greatly reduce the




occurrence of waterborne contamination of biological and other eco-



logical systems by hazardous wastes.  One incident which is illustra-



tive of the type of impacts which could be avoided by these regula-



tions is as follows:
                                 7-178

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     •  Near the Rocky Mountain Arsenal in Colorado, complex hazard-
        ous wastes (consisting of by-products of pesticides, herbi-
        cides, and chemical warfare agents) stored in unlined holding
        ponds infiltrated a shallow water table aquifer and migrated
        through groundwater.  As a result, crops on 6.5 square miles
        of farmland were damaged and water fowl were killed.  Results
        of the groundwater contamination were still evident 24 years
        following the initial report of damage and 15 years after
        remedial action was taken.

     Additional regulations would require specific design parameters

for landfills, surface impoundments, and basins that would minimize

leakage and emphasize structural integrity.  Monitoring, inspection,

reporting, and permit requirements would reinforce these regulations.

This group of regulations would decrease the potential for environ-

mental damage and adverse biological impacts from failure of inade-

quately designed and constructed containment structures.  Two promi-

nent examples of the type of incident which have occurred in the

current unregulated situation are as follows:

     •  In Pennsylvania the rupture of refining waste lagoons near
        the Allegheny River resulted in the death of approximately
        4.5 million fish in one incident, and the death of about
        450,000 fish along a 60-mile stretch in another incident (Of-
        fice of Solid Waste, Hazardous Waste Management Division,
        1978b).

     •  A waste pond dike ruptured at a phosphoric acid plant at Fort
        Meade, Florida, releasing 28 billion gallons of slime com-
        posed of halides and phosphatic clays.  The discharge contam-
        inated the adjacent creek, the Peace River, and the estuary
        of Charlotte Harbor.  Extensive mortality of benthic biota
        occurred, and no live aquatic organisms were found in the
        Peace River up to 8 miles downstream of the adjacent creek
        (Office of Hazardous Waste Management Programs, 1974a).

     These latter wastes are specifically listed as hazardous under

the Section 3001 regulations, and are classifed as 'special wastes'
                                   7-179

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under the Section 3004 regulations.  Since the Section 3004 'special

waste1 standards for phosphate were not developed as of the time of

this document, their impact is uncertain.  However, definition of

these wastes as hazardous and implementation of specific disposal

standards would certainly reduce the potential for adverse biological

impacts due to these wastes.

     Other parts of the Section 3004 regulations would restrict open

burning of hazardous wastes and require compliance with the regula-

tions developed under the Clean Air Act.  These provisions would

reduce the potential for adverse biological impacts caused by air

pollution.  Additional requirements and permit restrictions would

prevent the growth of food chain crops where they may contact hazard-

ous wastes, and would require fencing around active portions of

facilities.  Further, implementation of the manifest and facility

permitting system in general would result in a large decrease in un-

controlled open dumping of hazardous wastes.  The combined effect of

these provisions would greatly reduce the potential biological

impacts caused by ingestion or other contact with hazardous wastes.

An example of the type of incident which could likely be avoided is

as follows:

     •  In September 1971, six or seven cows died from arsenic
        poisoning, resulting from improper disposal of a cotton de-
        foliant in a Texas City landfill.  Approximately 100 boxes,
        each containing four "empty" plastic containers holding a
        small amount of residual arsenic, had been placed at the
        landfill by a warehouseman of a chemical company.  The graz-
        ing cattle had entered the landfill from nearby pasture
        lands.
                                  7-180

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                  In summary,  the baseline regulations for preventing or minimiz-

             ing the degradation of air,  surface waters,  subsurface waters, soils,

             and other physical features, could substantially reduce the stresses

             imposed on living systems by current hazardous waste management prac-

             tices.   The implementation of such regulations would reduce the

             direct  exposure of biota and habitats to hazardous wastes.  The over-

             all benefits accrued would generally correspond to the amounts of

             hazardous wastes  brought under control,  to the rate and uniformity at

             which such control is implemented, and to the degree to which the

             release of air, soil, and water residuals were reduced.

                  The regulations would result in the closing of some existing

             environmentally inadequate hazardous waste storage, treatment, and

             disposal facilities; the modification of other existing facilities;

             and the construction of new facilities that  would be in compliance

             with the regulations.  This would have the following types  of

             impacts:

                  •   Biological systems that occur in the vicinity of existing
                     sites which would be closed could be subject to a reduced
                     level of risk if the site were closed in accordance with the
                     regulations;

                  •   The construction of new hazardous waste facilities  would
                     result in localized destruction and  displacement of biota and
                     the temporary degradation of local habitats due to  noise,
                     emissions, effluents, and other construction impacts;

                  •   Any increased transportation of hazardous wastes would expose
                     biota and habitats along transportation routes to increased
                     outputs of vehicular emissions and increased road kills;
                     there could also be an increased frequency of spills as a
STOP TV-               result of increased transport distances;
OfJ ~-l* .


                                            7-181

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     •  The establishment of new hazardous waste facilities and the
        expansion of existing suitable facilities could reduce the
        habitat available to wild and domesticated biota by a
        presently indeterminable amount; a shift from on-site to
        off-site disposal could result in the placement of some new
        facilities in largely remote and rural areas, and thus could
        preempt habitats that support fish, wildlife, and other
        natural biota in addition to exposing new communities to
        hazardous waste management activities.

     Although these regulations would afford a significant amount of

protection from contact with hazardous waste to the larger terres-

trial animals in the immediate vicinity of facilities and to biologi-

cal systems in a particular group of habitat types (e.g., critical

habitats of endangered species and wetlands), the baseline regula-

tions do not include any special provisions for the protection of

waterfowl that may be attracted to hazardous wastes surface impound-

ments.  Thus, incidents such as that reported by Snyder et al.

(1976), in which migratory waterfowl were killed by alighting on

storage lagoons containing residues from a waste oil refinery plant,

could continue to occur.

     Additionally, the regulations apply only to safeguards at the

facility site itself.  No provisions are specified for the siting of

facilities in relation to many other land use or habitat types that

may be of value to wild or domesticated biota (e.g., prime agricul-

tural lands; upland wildlife habitats, habitats and ranges of state

designated rare and endangered species, areas in major migratory

routes, commercially valuable forests, unique plant communities,

etc.).  It is likely, however, that permit application and review

procedures would provide a mechanism for considering such impacts
                                 7-182

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             prior Co facility approval.   The regulations also make no specific

             provision for compensation or mitigation of losses of habitat and

             biota that may occur as a result of the installation or operation of

             hazardous waste facilities or as a result of accidents that may

             result during their operation.

                  7.2.3  Social Impacts.   Two major types of impacts could occur

             as a result of promulgation of the Subtitle C regulations:  demo-

             graphic changes and changes  in existing social conditions.

                  7.2.3.1  Demographic Impacts.  Potential sources of demographic

             changes from the promulgation of the Subtitle C regulations include

             closings or relocations of industrial plants; construction or modifi-

             cation of hazardous waste management facilities; changes in opera-

             tional requirements of hazardous waste management activities; and

             administrative requirements  for program management.

                  As indicated in the Integrated Economic Impact Assessment of

             Hazardous Waste Management Regulations (Regulatory Analysis Supple-

             ment), promulgation of the Subtitle C regulations'would likely cause

             some plant closings and job losses in a number of industrial segments

             (e.g., textile industry, inorganic chemicals industry, organic chem-

             icals industry, metals smelting and refining industry, electroplating

             and metal finishing industry).  Such plant closings and job losses

             would have the potential to cause relocations of some of the affected

             workers and their families.   The nature and extent of any such relo-

S_CP .  .       cations and population shifts would be site-specific and dependent
Ofj TV : .   . _
             upon such factors as number of workers affected, local and national


                                             7-183

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unemployment rates, number and types of jobs available, worker




skills, age of affected workers, and willingness of workers to relo-




cate.  There would be a potential for large-scale out-migrations from



any communities or areas for which plants being closed constituted




the primary source of employment.



     The Subtitle C regulations would result in modifications to




existing hazardous waste management facilities and the construction



of new facilities.  Due to the small number of construction workers




who would be required at any individual facility, it is unlikely that



there would be a significant amount of relocations or population



shifts due to construction requirements.  However, there could be



some localized instances of worker relocations, especially in the



case of facility construction in rural or undeveloped areas.  Any




such relocations would likely be of a temporary nature.



     Operational requirements for hazardous waste management under



the Subtitle C regulations would likely result in additional workers



being required to track the hazardous waste (due to the manifesting,



reporting, and recordkeeping requirements), to transport the wastes



(in the case of increased off-site disposal), and to store, treat, or




dispose the wastes both off-site and on-site.  Additional workers




would also be required to administer and enforce the regulations at



both the state and Federal levels.



     Some population shifts could occur if the required number of



workers were not available where needed, particularly in the case of
                                7-184

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

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

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

relatively large influx of workers, particularly for facilities

located near small towns or in rural areas.

     Based upon a study of the hazardous waste management service

industry (Foster D. Snell, Inc., 1976), it is estimated that about

500 workers (including clerical and professional employees) are

required to handle a million metric tons of hazardous wastes per

year.  Using this requirement as the minimum number of workers likely

to be required under the Subtitle C regulations,* it is estimated

that at least 20,000 such workers could be required by 1984 to handle

hazardous wastes.  Approximately 2,600 to 5,000 of these workers

could be required at off-site facilities, and approximately 15,000 to

17,400 could be required at on-site facilities.  Based upon Section

7.2.4, this would represent a decrease of 400 workers at off-site

facilities in the case of 13 percent off-site shipment and an

increase of 2,000 workers at off-site facilities in the case of 25

percent off-site shipment (there would be equivalent, but opposite,

changes at on-site facilities).  It should be noted that changes in

employment at off-site facilities would be more likely to cause
*This number does not include the additional workers that would
 likely be needed to track the hazardous waste under the Subtitle C
 regulations.  Some additional operational employees could also be
 required.
                                    7-

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population shifts than changes at on-site facilities.  In 1975




approximately 2,000 workers were employed off-site at hazardous waste




management service industry facilities (Foster D. Snell, Inc., 1976).



Data are not available as to the number of workers employed at




on-site facilities, nor to estimate the increase in the total number



of employees that would be required at all facilities under the



regulations.




     7.2.3.2  Social Conditions.  Impacts to existing social condi-




tions could result from changes in the siting and operation of haz-



ardous waste management facilities and from any population shifts




caused by the regulations.




     The increased public health protection that would be derived



from the regulations would provide significant social benefits.  Many



of the social costs related to the exposure of workers and the gener-




al public to hazardous wastes and their residuals under current prac-



tices would be reduced or eliminated.  This exposure is known and/or




suspected to have caused numerous instances of adverse health ef-



fects, including death (see Section 7.1.6).  Much of the individual



grief and suffering associated with such incidents, as well as the



resultant economic losses, would be reduced or eliminated.



     The regulations, while not applying to household wastes, could



focus more public attention on the problems associated with the




improper treatment/disposal of hazardous wastes.  This could result



in increased care in the disposal of hazardous household wastes and a



further reduction in public health impacts from such disposal.  A few






                                 7-186

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examples of health problems Chat have resulted from the improper dis-



posal of hazardous household wastes are presented in Appendix J.




This awareness could also result in more citizen pressure on authori-



ties to see that hazardous waste is properly managed and that gener-




ators, transporters, storers, treaters, and disposers comply with the




regulations•



     On the other hand, an increased public awareness of problems



that have been associated with improper disposal of hazardous wastes




could add to opposition to local siting of hazardous waste management



facilities.  Citizen reaction to the siting of hazardous waste facil-




ities has been mostly negative.  A number of communities and states




have been unable to overcome citizen opposition in attempts to site



hazardous waste landfill or treatment facilities.  Such opposition is



not usually centered upon specific data regarding the adequacy of the




proposed facility with respect to public health or the environment.



Rather, it is usually based upon reported incidents and the belief




that such incidents could not be prevented from reoccurring, regard-




less of the precautions to be taken.  For example, residents in



Bordentown, New Jersey, have recently shown extremely strong opposi-



tion to the siting of a chemical waste landfill whose construction




specifications appear to be well in excess of specific requirements



under Subtitle C regulations (Waldron, 1978).  This type of opposi-




tion represents an educational and attitudinal problem which solid



waste management officials could find to be a pivotal constraint and
                                  7-187

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issue in the development of alternatives and solutions.  Any inabil-




ity to effectively site or to provide necessary treatment or disposal



facilities would render other steps less effective in providing envi-



ronmentally adequate hazardous waste management (Office of Solid




Wastes, 1977a).  However, promulgation of the regulations accompanied




by increased public awareness and participation in the facility sit-



ing process, and specific demonstrations that the objectives of the




regulations can be achieved, could also serve to lessen such opposi-




tion in the future and could lead to more effective siting of facil-



ities.



     Other social impacts could also result from the expansion or



construction of hazardous waste management facilities and from any




increased off-site transport of hazardous wastes.  The construction



and operation of new facilities would have aesthetic impacts and



could result in localized noise impacts.  Construction of new facil-



ities, especially off-site facilities, and conjunctive developments




such as road construction would create new jobs, but would also rep-




resent an intrusion on the existing aesthetic environment.  This



intrusion would consist of visual, auditory, and olfactory altera-




tions.  Forms, colors, lines, textures, sounds, and smells could be



changed.  The perception of these alterations would depend upon many



variables including the context in which the alteration appears, the



terrain masking the alteration, the distance from which the altera-



tion is viewed, the magnitude of the alteration, and the weather con-



ditions at the time of perception.  Proper planning, while not able
                                 7-188

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to eliminate these aesthetic and noise impacts, could make them less



perceptible.




      Facility construction and operation, including the additional



truck traffic associated with new or expanded facilities, could




increase noise levels in the vicinity of such facilities, especially




in the case of off-site facilities, and also along transport routes.




Changes in noise levels would be extremely site-specific and would




depend upon such factors as existing noise levels in the area, type



of facility constructed, increase in'truck traffic, distance to



population centers, local topography, and local meteorological




conditions.  Active portions of facilities would have to be located



at least 200 feet from the facility's property line under the



Subtitle C regulations. Any changes in off-site shipments of




hazardous wastes or in the distances such wastes are transported




would also change the potential for accidents from such transport.



Assuming that the average round trip haul distance would increase to




200 miles and that there would be 8.9 truck accidents per million



vehicle miles (National Safety Council, 1975), based upon Section



7.2.4 there could be about 270 additional vehicular accidents




annually in 1984 in the case of 13 percent off-site shipment and 850




additional accidents in the case of 25 percent off-site shipment.



      The Subtitle C regulations do not contain specific provisions




for planning the siting of hazardous waste management facilities or



transportation routes.  However, the Section 3005 permit application



review procedure, including the opportunity for public hearings on





                                7-189

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the permit application, would provide a means for consideration of




such factors at the state and local levels.  Other Federal laws, such




as OSHA noise regulations, and state and local laws and ordinances



could also serve to mitigate potential noise and aesthetic impacts.




     Implementation of the regulations could potentially have long-



term beneficial impacts through the establishment of a framework of




"equivalent" and "consistent" state programs.  This could reduce the



likelihood for a state to implement importation bans or overly strict



standards directed towards preventing the entry of wastes into any



particular state.  This could prevent states from becoming isolated




in terms of their ability to dispose of hazardous wastes.  This con-




sistency between states could, in turn, reduce the potential for geo-



graphic shifts by industry to escape strict regulations.  However, as



previously discussed, in the near term there could be individual



plant closings or relocations from the enactment of the regulations.



     Any shifts in population that result from the Subtitle C regula-




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



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



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



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




existing infrastructure in the affected areas, and the adequacy of



advanced planning.



     Large, rapid, population outfluxes could be unavoidable within



some areas if the regulations caused industrial plant closings or
                                 7-190

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relocations, especially if the plant were the primary source of



employment for the area.  Such out-migration could have a deflation-




ary impact on the local area; however, the remaining residents could



also be hard-pressed to maintain existing public services and facili-




ties, and local tax rates could have to be increased.  Unemployment




would increase in the retail and service sectors, and the number of



people requiring financial assistance programs would also likely




increase.  Daily living patterns could be drastically changed for



many of the remaining residents.  Stress would likely increase and



could lead to increases in mental and physical health problems.




     Large, rapid, population influxes associated with relocation of



industrial plants or with construction of new hazardous waste manage-



ment facilities'could create inflation, social tensions, and a short-




age of housing and necessary infrastructure.  Provision of necessary




services and facilities could result in increases in local tax rates.



Large, rapid, population influxes could also create tensions and-dis-




putes between the existing population and the newcomers, especially



if the existing residents were forced to modify their daily living



patterns to accommodate the changes in their environment.  Increases



in crime and in mental health related problems (e.g., alcoholism,




drug abuse, child abuse, divorce) have at times accompanied large,



rapid, population influxes (Institute for Social Science Research,




1974).  On the otherhand, any growth could also provide increased job



opportunities and an expanded local tax base in the long term.






                                 7-191

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     Population shifts need not necessarily result in adverse



impacts.  Small shifts, which would be the more likely occurrence in



the case of construction or closure of hazardous waste management



facilities, could have beneficial impacts or no noticeable impacts.




For example, a small population influx could provide additional in-




come, tax revenues, and jobs in the local community without placing



any noticeable strains on the existing infrastructure or daily living




patterns.  A small population decline could reduce any existing unem-




ployment and strains on public services and facilities without no-



ticeably affecting local income, tax revenues, employment, or daily



living patterns.




     7.2.4  Hazardous Waste Management Facility Capacity.  There are



two measures of hazardous waste management capacity—process capacity



and physical capacity.  Process capacity represents the throughput




capability of the hazardous waste management facility for handling



hazardous wastes (e.g., tons per day, gallons per year).  Physical




capacity, on the other hand, represents the constraint imposed by the



facility site itself on the total amount of wastes that can ultimate-



ly be stored, treated, or disposed at the facility (e.g., landfilling



of a total of 100,000 metric tons to a depth of 5 meters over the




life of a landfill).



     7.2.4.1  Process Capacity.  The impact of the Subtitle C regula-




tions on the availability of sufficient on-site and off-site process



capacity is addressed below.





                                   7-192

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     Off-site Capacity.  A recent study of the hazardous waste man-

agement service industry (Foster D. Snell, Inc., 1976) indicated that

at the end of 1974, the process capacity for the industry as a whole

was nearly 7.3 million metric tons per year,  with up to approximately

5.3 million metric tons being considered environmentally adequate.*

The study further estimated that the process  capacity would expand to

8.2 million metric tons by the end of 1977, with up to about 6.2 mil-

lion metric tons being considered environmentally adequate.  This

represents a 4.0 percent annual growth rate for total process capa-

city and a 5.5 percent annual growth rate for environmentally ade-

quate process capacity.

     Assuming that the 4 percent annual growth rate for total process

capacity would continue between the end of 1977 and the start of 1984

if the Subtitle C regulations were not promulgated, it is estimated

that there would potentially be 8.9 and 10.4 million metric tons of

total process capacity at the start of 1980 and 1984, respectively.

     Assuming that "environmentally adequate"; as defined in the

Foster D. Snell study, is compatible with the requirements of the

regulations and that the 5.5 percent annual growth rate of such

capacity would continue between the end of 1977 and the start of
*It should be noted that all capacity considered environmentally
 adequate by the Foster D. Snell Study may not be considered
 environmentally adequate under Subtitle C.  Thus, the Foster D.
 Snell numbers should be viewed only as an upper limit on
 environmentally adequate capacity.


                                 7-193

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1984, it is estimated that under the regulations there could poten-




tially be as much as 6.9 and 8.5 million metric tons of environ-




mentally adequate process capacity available »«• the start of 1980 and



1984, respectively.




     Currently, about IS percent of all hazardous industrial wastes




are shipped off-site for treatment/disposal (see Table 5-10).  For



purposes of analysis, it is assumed that any shift in off-site




treatment/disposal under the Subtitle C regulations would occur



gradually and that approximately 15 percent of the hazardous indus-



trial wastes would continue to be shipped off-site in 1980 (the first



year the regulations would be in effect).  As discussed in Section



7.1.2.4, for 1984, the fifth year the regulations would be in effect,



a range of 13 to 25 percent off-site shipment for treatment/disposal



is assumed for analysis purposes.




     Approximately 35 and 40 million metric tons of hazardous indus-



trial wastes could be generated annually in 1980 and 1984,




respectively.  Thus, it is estimated that about 5.3 million metric




tons of hazardous industrial wastes could be shipped off-site in 1980



and that between 5.2 and 10.0 million tons could be shipped off-site




in 1984.  This would represent no change in off-site shipments under




the Subtitle C regulations in 1980.  The change in off-site shipments



in 1984 under the regulations would range between a decrease of 0.8




million metric tons and an increase of 4.0 million metric tons.



     Assuming that treatment/disposal facilities would utilize on an



annual basis an average of about 90 percent of the available process





                                7-194

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capacity, approximately 6.2 and 7.7 million metric tons of the envi-

ronmentally adequate capacity could be utilized nationwide in 1980

and 1984, respectively.  The estimated 6.2 million metric tons of

environmentally adequate capacity that could potentially be utilized

on a nationwide basis in 1980 would be sufficient to handle the

estimated 5.3 million metric tons of hazardous industrial wastes

shipped off-site.  Even if there was no growth in environmentally

adequate capacity between 1977 and 1980, there would still

potentially be sufficient capacity on a nationwide basis in 1980.

     The estimated 7.7 million metric tons of environmentally ade-

quate capacity that could potentially be utilized on a nationwide

basis in 1984 would be sufficient to handle the estimated 5.2 million

metric tons of hazardous industrial wastes shipped off-site, assuming

13 percent off-site shipment.  Again there would potentially be

sufficient capacity nationwide even if there was no growth in

capacity between 1977 and 1984.

     In the case of 25 percent off-site shipment, there would poten-

tially be a nationwide shortfall of 2.6 million metric tons of

environmentally adequate capacity for treating/disposing hazardous
                                                                 /
manufacturing wastes in 1984.*  Without any growth in environmentally

adequate capacity, this shortfall could be 4.9 million metric tons.

Shortfall in process capacity would first occur in 1984 in the former
*The actual shortfall would be 2.3 million metric tons.  However,
 with a utilization rate of 90 percent, 2.6 million metric tons of
 capacity would  be required.
                               7-195

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ON "SiS
            case and in  1981 in  the  latter case.  Based upon an  average  utiliz-



            able facility capacity of 60,000 metric  tons per year  (Foster D.




            Snell, Inc., 1976),  approximately 45 additional off-site  facilities




            could be required to handle hazardous manufacturing  wastes by 1984 in



            the former case and  approximately 80 additional off-site  facilities




            could be required in the latter case.




                 It should be noted  that the estimated availability of necessary,



            off-site, process capacity is based only on the treatment/disposal of




            hazardous industrial wastes and on the nationwide availability of



            this capacity.  As indicated in Section  7.1.1, an indeterminable



            quantity of  other hazardous wastes would be generated  and an unknown




            portion of such wastes would be treated/disposed off-site and could




            cause shortfalls in  capacity.  Furthermore, these estimates  assume



            that the available capacity would be of  the type that  is  specifically



            required (e.g., secure landfills, incinerators, surface impound-



            ments).  However, it is very likely that there could be national,



            regional, statewide, or  localized shortfalls of specific  types of




            capacity even in those cases where the total available capacity



            appears to be more than  adequate.  Furthermore, since  not all of the



            available capacity would necessarily be  sited where  it is needed,




            there could  be localized shortfalls of process capacity even if the



            total nationwide process capacity were sufficient.   Localized



            shortfalls could also result from public opposition  to siting new




            facilities or from public opposition which results in  the closing of
                                             7-196

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existing environmentally adequate facilities.  Any shortfall in

on-site capacity as discussed below, could create localized short-

falls in off-site capacity.  It should also be noted that if any

generators were to send potentially toxic wastes that would not be

considered hazardous under the Section 3001 regulations to permitted

facilities in order to obtain more secure treatment/disposal, there

would be an increased potential for localized shortfalls in off-site

capacity.  The requirement that at the time of facility closure,

wastes must be removed from permitted surface impoundments that do

not meet Subtitle C landfill requirements and from some landfarms

could create or exacerbate any shortfalls.  A recent report by the

U.S. General Accounting Office (1978) estimates that when Subtitle C

is implemented, 50 to 60 additional sites could be required

nationally for hazardous waste treatment, storage, and disposal.

     On-site Capacity.  Data are not available to estimate if there

would be any potential shortfall in environmentally adequate,

on-site, hazardous waste management process capacity under the

Subtitle C regulations.  Based upon the assumption stated above,

about 28.7 million metric tons of hazardous industrial wastes would

be treated/  disposed on-site in 1980 and between 28.8 and 33.6

million metric tons would be treated/disposed on-site in 1984*.
 The remainder of the hazardous industrial wastes not treated or
 disposed on-site or off-site would be recycled or sent to resource
 recovery operations, both on-site and off-site.
                                7-197

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This would represent no change in 1980.  The change in 1984 would




range between a decrease of 4.0 million metric tons and an increase




of 0.8 million metric tons.  As indicated in Section 7.1.2.4, the



Subtitle C regulations would likely result in an indeterminable




decrease in existing on-site process capacity and, as a result, could




potentially cause shortfalls in on-site process capacity in both 1980



and 1984.  The requirement that at the time of facility closure




wastes must be removed from permitted surface impoundments that do



not meet Subtitle C landfill standards could exacerbate any short-



falls, both on-site and off-site. Increased resource conservation and




recovery and use of more effi-cient processes would lessen the poten-




tial for on-site shortfalls.




     7.2.4.2  Physical Capacity.  Few data are available to estimate



the overall physical capacity of facilities to store, treat, or



dispose hazardous wastes.  EPA recognizes the need for data on



physical capacity and will be conducting a series of inventories



toward that end.  Under the mandate of the Safe Drinking Water Act,




an inventory of surface impoundments will be conducted.  Under the



mandate of RCRA, an inventory of open dumps, solid waste landfills,




and sludge disposal sites will be conducted (Office of Solid Waste,



1977a).



     Any increase in the use of on-site or off-site landfills would



accelerate the rate at which the physical capacity of such landfills




would be exhausted.  Although the rate of exhaustion of such land-



fills cannot be determined, it is possible to estimate the change in





                                7-198

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Che necessary on-site and off-site landfill acreage between 1980 and




1984.  Assuming that the shift in on-site and off-site disposal would



be apportioned equally over this period (e.g., 15 percent off-site



treatment/disposal in 1980, 17.5 percent in 1981, 20 percent in 1982,




..., 25 percent in 1984), there could be a total decrease of 1.9 mil-




lion metric tons in hazardous industrial wastes sent off-site during



this period, assuming 13 percent shipment off-site in 1984, and there




could be a total increase of 9.3 million metric tons in hazardous




industrial wastes sent off-site, assuming 25 percent shipment



off-site in 1984.




     Based upon Table 5-7, about 80 percent of hazardous industrial



wastes are disposed in landfills and surface impoundments.  Since




wastes treated in surface impoundments would be required to be dis-




posed in landfills if the surface impoundments do not meet the




Subtitle C landfill standards and since approximately 99.9 percent of



hazardous wastes are placed in surface impoundments that are environ-




mentally inadequate (see Table 5-7), it is assumed, for purposes of



analysis, that up to 80 percent of hazardous industrial wastes would



ultimately be disposed by landfilling.  Thus, there could be up to a



1.5 million metric ton decrease in off-site landfilling in the case




of 13 percent off-site shipment and up to a 7.5 million metric ton



increase in off-site landfilling in the case of 25 percent off-site



shipment.




     Assuming an average waste density of 0.8 metric tons per cubic



meter and a landfill depth of 10 feet, one to two acres would be





                                '  7-199

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required for every 5,000 cubic meters of waste disposal (personal



communication, J. Schaum, EPA, 1978).  Thus, up to 400 to 800 fewer




acres could be committed to off-site landfilling of hazardous



manufacturing wastes between 1980 and the end of 1984 in the case of




13 percent off-site shipment and up to 1900 to 3800 additional acres




could be committed to off-site landfilling of hazardous manufacturing



wastes between 1980 and the end of 1984 in the case of 25 percent




off-site shipment.  In the former case, after 1984 there could be 160




to 320 fewer acres required off-site annually for landfills compared



to requirements without the regulations.  In the latter case, after




1984 there could be an additional 1,800 to 1,600 acres required



off-site annually for landfills compared to total requirements with-



out the regulations.  There could be commensurate changes in on-site




land requirements in each instance.



     For purposes of comparison, based upon an average, secure, com-



mercial landfill size of 270 acres (U.S. Environmental Protection




Agency, Office of Toxic Substances, 1977), these land requirements




would be equivalent to siting 1 to 3 fewer off-site secure landfills



by the end of 1984 in the case of 13 percent off-site shipment.  In




this case, the equivalent of approximately one fewer off-site land-




fill could have to be sited annually after 1984.  The land require-



ments would be equivalent to siting 7 to 14 additional off-site



secure landfills by the end of 1984 in the case of 25 percent





                                  7-200

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off-site shipment.  In this case, the equivalent of 3 to 6 additional




off-site landfills could have to be sited annually after 1984.




     7.2.5  Land Use Impacts.  More total land, off-site plus




on-site, would be required for environmentally adequate hazardous



waste management under the Subtitle C regulations than for hazardous




waste management under current practices.  The additional land




necessary for environmentally adequate management of hazardous waste



would be required both for the construction of permitted facilities



necessary to meet any additional capacity shortfalls that could occur




under the Subtitle C regulations and for such conjunctive develop-



ments as construction of roads, power lines, and pipelines.  However,



as indicated in Section 7.2.4, in the case of 13 percent off-site




shipment there would be fewer hazardous industrial wastes sent



off-site by 1984 under the Subtitle C regulations than under current



practices.  Thus, while more total land would be required, there




could be less off-site land use and more on-site land use for hazar-




dous industrial waste in this case.  In the case of 25 percent



off-site shipment, there would be more hazardous industrial wastes




sent off-site by 1984 under the Subtitle C regulations than under



current practices.  Thus, there could be more off-site land use and



less on-site land use for hazardous industrial waste in this case.




Estimates of potential changes in off-site land requirements for



landfills (and commensurate changes in on-site land requirements) are



presented in Section 7.2.4.
                                7-201

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     It should be noted that while shifts to on-site land use could



reduce off-site land requirements in the short term, such shifts




could also accelerate the exhaustion of the relatively limited



on-site physical capacity and could result in increased pressure for




off-site facilities in the long term.  Increases both in resource




conservation and recovery and in treatment practices resulting in



volume reduction (e.g., incineration) that occur as a result of the




Subtitle C regulations would have the potential for reducing land




requirements, both on-site and off-site, in the long term.



     Existing land uses would cease, either permanently or temporari-




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




agricultural, grazing, forest, recreational, and other lands could be



removed from their existing uses.  The regulations would prohibit



facility construction, and thus not affect existing land uses, on



100-year flood plains, on or near active fault zones, in wetlands, in



critical habitat areas, or in recharge areas of sole source aquifers.



     Following-closure of the hazardous waste management facility and



rehabilitation of the site according to the closure plans, the land



would be available for new or, in some cases, previously existing




uses.  Sites at which hazardous wastes have not been removed would be




precluded from residential and agricultural uses, and may be pre-



cluded from some recreational and grazing uses following closure.



Any activity requiring excavation would be prohibited at sites where




wastes are not removed.  Further, since the regulations would require





                                 7-202

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records to be kept of the location and types of all hazardous wastes




remaining at the site, the potential for incidents such as occurred




at Love Canal in Niagra Falls, New York would be reduced.  (This



incident is discussed in Section 7.1.6.)




     To the extent that the regulations would prevent other lands




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




treatment under current practices and regulations, there would be a




potential for offsetting land use benefits.  Sections 7.1.4, 7.1.5




and 7.2.1 describe the potential for the generation of air, water,




and land residuals which could affect existing land uses under cur-




rent practices and regulations.  These sections also discuss the po-




tential for reducing these residuals under the baseline regulations.




     In addition to land use changes brought about by facility




siting, operation, and closure, the baseline regulations could have




an impact on a few current land use practices associated with




potentially hazardous wastes.  For example, landspreading of sludges




is specifically addressed in the regulations.  The requirements that




landfarms be operated so as not to allow waste migration, and be




closed so that food chain crops could be grown on site would both




minimize the areal extent of contamination and would allow continued




productive use of the land after waste applications ceases.  Another



example would be the regulation of road oiling for dust control.




This practice is not specifically addressed in the baseline regula-




tions, although numerous incidents of environmental contamination





                                 7-203

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have occurred as a result of road oiling.  (Some of these incidents




are described in other parts of this chapter and in Appendix J.)  The



baseline regulations would require generators of over 100 kilograms



per month of waste automotive oils to comply with the regulations.




Additionally, hydraulic and cutting oil wastes are listed as



hazardous wastes, and other waste oils may be included under the



various criteria.  Therefore, any waste oils which are considered



hazardous under the baseline regulations would have to be treated so




as to be rendered nonhazardous before being used for road oiling.



This procedure would reduce the environmental damage and resultant



adverse impacts to land use that have occurred due to unregulated




road oiling.



     7.2.6  Water Use Impacts.  The Subtitle C regulations would




affect water use in two ways—through a reduction in groundwater and



surface water contamination and through increased water demand by



expanded and new hazardous waste facilities.  It is estimated that




almost one half of the population of the United States depends on




groundwater as a source of drinking water, and that over one third of



the nation is underlain by groundwater reservoirs capable of yielding




at least 75,000 gpd to an individual well (Office of Solid Waste Man-




agement Programs, 1977).  It is further estimated that industrial



impoundments account for over 100 billion gallons of contaminant per



year to groundwater and that residential, commercial, and




institutional land disposal sites account for about 90 billion






                                 7-204

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gallons of leachate Co groundwater annually (Office of Solid Waste



Management Programs, 1977).  It is apparent that the potential




dangers of uncontrolled disposal of hazardous wastes are a serious



problem.  With the implementation of che regulations regarding




disposal and treatment of hazardous wastes, a significant reduction



in groundwater leachate should occur, thereby decreasing the




potential danger to private and public underground water supplies.




     The potential for the degradation of both groundwater and sur-




face water would be reduced under the regulations.  To the extent



that degradation of water quality would have resulted in a decreased




supply of surface water or groundwater being available to some or all




consumers in the water use area, there would be an additional supply



of groundwater or surface water potentially available to such  consu-




mers and fewer restrictions on the productive use of such surface




water and groundwater supplies.



     Implementation of the baseline regulations would necessitate




that some existing facilities currently accepting hazardous wastes be




upgraded in order to make them environmentally adequate, and that new



facilities be sited to minimize potential capacity shortfalls.  New




facilities would be additional consumers of water for purposes such




as:




     •  Dust control;



     •  Soil compaction;



     •  Washing and cleaning of equipment and containers;





                                 7-205

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     •  Biological treatment;


     •  Spill control;


     •  Laboratory requirements;

     •  Fire control and other emergencies;


     •  Site rehabilitation;


     •  Wet scrubbers for air pollution control;


     •  Miscellaneous uses, including cooling water.


     Such demands would affect the water budget of the localities in


which the facilities were located to varying degrees depending upon

such factors as the type of facility sited, its water requirement,


and the potential water availability in the area.  The additional


water requirement would be somewhat offset by the amount of water (if
                     k

any) that would have otherwise been used for the treatment/disposal


of these additional wastes under current practices and regulations.


     7.2.7  Impacts to Resource Conservation and Recovery.  As

discussed in Section 5.4.2, approximately 3 to 5 percent of hazardous


industrial wastes have been subject to resource recovery in recent


years with most efforts directed toward the recovery of solvents,


oils, metals, and energy.  The Subtitle C regulations contain few


provisions directed specifically toward increasing the portion of


hazardous wastes that would be subject to resource conservation and


recovery efforts.


     However, since one of the major impacts of the regulations would


be to increase generator's costs and the costs associated with


                                7-206

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hazardous waste transport, storage, treatment, and disposal, there



would be an incentive provided by the regulations for generators to




modify processes so as to enable increased recycling of hazardous



wastes as process feedstocks, to reduce the quantities of hazardous




wastes generated by specific processes, or to change the nature of




the wastes produced (e.g., to produce wastes that are less hazar-



dous).  In addition, the Section 3004 regulations direct that where




practical, disposal of hazardous wastes would have to be avoided and



alternatives, such as resource recovery, reuse, or other methods of



recycling, would have to be employed.  Furthermore, since the




regulations prohibit the placing of ignitable wastes in landfills,




landfarms, surface impoundments, and basins, the potential for



increased incineration of such wastes, with possible energy recovery,




would be greatly enhanced.




    • As previously indicated, the potential for the implementation of



process modifications or other changes to promote resource conserva-




tion and/or recovery would be extremely waste stream and process




specific and would depend upon such factors as changes in the econo-



mics of disposal, treatment, and transport; the cost of raw materials




and energy; the availability of markets for and sources of recyclable




hazardous wastes; and the availability both of the necessary techno-



logy for specific resource conservation or recovery efforts and of




environmentally adequate disposal methods and capacity.  Chapter 5



presents some examples of the potential for the increased resource





                                7-207

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             recovery from and recycling of hazardous wastes.   Due to the complex

             interrelationships among the above factors,  it is not possible to

             determine the specific  changes that could occur with regard to

             resource conservation and recovery, nor the  overall  extent of any

             such  changes.

                  7.2.8  Energy Use  Impacts.   Promulgation of  the Subtitle C

             regulations  could cause changes  in energy use in  the following areas:

             hazardous waste  management facility construction, facility operation,

             hazardous waste  transport, hazardous waste resource  conservation and

             recovery, and energy  production.

                  The facility modification and construction that would be neces-

             sary  under the regulations would  result in increased energy use (see

             Section 7.1.2).   More energy would also be used for  the construction

             of new facilities under the regulations than would have otherwise

             been  needed  due  to requirements  directed toward making these facili-

             ties  more environmentally secure  (e.g., requirements for site prepa-

             ration,  landfill liners,  diversion structures, monitoring systems,

             pollution control equipment).

                  There would also be increased energy use resulting from required

             changes  in storage, treatment,  and disposal  operations under the reg-

             ulations. For example, requirements for application of daily cover,

             for higher incineration temperatures and longer retention times, for

             increased removal of  potential air contaminants,  for periodic moni-

iTC?T  .       toring and analysis,  for removal  of wastes from surface impoundments
C,v TH S    •' .

                                            7-208

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             at  facility  closure,  and  for post-closure  care would all potentially

             result  in increased energy use.   However,  any increase in resource

             conservation occurring  under the  regulations  would reduce the quan-

             tity of wastes  that would have otherwise been stored,  treated, or

             disposed and could thus off-set  the increase  in energy use.   Pre-

             viously discussed changes in resource recovery would also lead to

             other changes in energy use. While any increase in resource recovery

             would likely require  the  initial  input of  additional energy, energy

             savings could result  from increased energy recovery; from further re-

             ductions in  wastes requiring storage, treatment, or disposal; and

             from materials  recovery and reuse.   This could result in an overall

             energy  savings  from resource recovery operations.

                  The changes in- energy use  from the transport of hazardous wastes

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

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

             Table 7-15 presents estimates of  the magnitude of the potential

             change  in energy- use  that could  occur annually by 1984 from changes

             in  transport distances  and shifts in off-site and on-site treatment/

             disposal. Changes in transport  distances  are estimated as discussed

             in  Section 7.1.4.1; the change  in energy use  is estimated assuming

             that trucks  average 7.5 miles per gallon of fuel.  The estimated an-

             nual change  in energy use ranges  from a decrease equivalent to about

             20,000  barrels of crude oil for  an average 100-mile round-trip dis-

S-QP-        tance with 13 percent off-site  treatment/disposal to an increase
ON ~- '-

                                             7-209

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                                             TABLE 7-15

                    ESTIMATED CHANGE IN FUEL CONSUMPTION IN 1984 FROM TRANSPORT
                    OF HAZARDOUS INDUSTRIAL WASTES UNDER SUBTITLE C REGULATIONS
ro

Wastes
transported
off-site
13 percent



25 percent



Average
round-trip
distance
(miles)
100
200
500
1,000
100
200
500
1,000
Change in fuel consumption
(million gallons)
-0.7
4
18
42
4
13
37
86
Crude oil
equivalent*
(1,000 barrels)
-20
100
460
1,100
90
320
920
2,200

    ^Assumes  95 percent  efficiency  in  producing  diesel  fuel  from crude oil.

-------
equivalent to about 2.2 million barrels of crude oil for an average




1,000-mile round-trip distance with 25 percent off-site treatment/



disposal.




     The regulations could also potentially have an impact on energy



production.  The Subtitle C requirements and resultant costs could



potentially result in the closure of or reduced production at some




energy producing operations (e.g., oil and gas drilling).  Most such



operations would, however, be subject only to the  'special waste1 re-



quirements, not to the full set of Subtitle C regulations.  The Sub-




title C regulations could also potentially lead some facilities to



change the fuels they use so as to reduce or eliminate the generation



of hazardous wastes.  Any changes in fuel utilization could affect




current energy supply/demand relationships.



     7.2.9  Impacts to Special Interest Points.  Special interest



points consist of natural, modified, or artificial features of the



environment that are'of special aesthetic, cultural, and recreational



•significance.  Such features include archaeological and paleonto-



logical sites; cultural areas; historical sites; parks and recrea-




tional areas; scenic areas and other aesthetic resources; unique



geological formations; wilderness areas; wild and  scenic rivers; and



wildlife refuges and other natural areas.  The extent to which



current hazardous waste management practices may have resulted in



adverse impacts to such resources is not documented.  However, the



types of incidents previously discussed would have had the potential





                                 7-211

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STC? '  ;
C '
             to cause adverse impacts, primarily through the release of air,

             water,  and soil contaminants that could disturb or degrade such

             special interest points.

                 The Subtitle C regulations contain provisions which, while not

             applying specifically to the protection of special interest points,

             would provide indirect benefits to special interest points and to the

             human enjoyment of such features.  For example, restrictions on the

             siting of hazardous waste management facilities in wetlands, perma-

             frost areas, and critical habitats would reduce the potential for

             adverse impacts to such areas.  Furthermore, provisions that would

             potentially reduce the release of air, water, and soil contaminants

             from such facilities would reduce the potential for these contami-

             nants to infringe upon special interest points located in the vicini-

             ty of hazardous waste management facilities.  Reductions in air,

             water,  and soil contaminants would also increase, or at least main-

             tain, the opportunity for human enjoyment of such special interest

             points.  Requirements applicable-to the closure of facilities such as

             landfills, landfarms, and surface impoundments would increase the

             potential for revegetation of such facilities and would reduce the

             potential for adverse aesthetic impacts.

                  To the extent that additional lands would be disturbed by

             facility construction and operation and by conjunctive developments,

             there would be an increased potential for infringement upon special

             interest points.  Construction of additional hazardous waste
                                             7-212

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           management facilities would represent an intrusion on the existing


           aesthetic environment and could also result in the disturbance of


           archeological or historical sites.  The clearing of trees or other


           vegetation could result in substantial alterations to the visual


           characteristics of the site.  Noise, dust, emissions, and other


           disturbances associated with site preparation, facility construction


           and operation, and hazardous waste transport could adversely effect


           nearby special interest points and could discourage their use or


           enjoyment.  The perception of these alterations would depend upon


           many variables, as discussed in Section 7.1.3.  Proper planning,


           while not able to eliminate these alterations, could make them less


           discernible.  The Subtitle C regulations do not contain specific


           provisions for planning the siting of hazardous waste management


           facilities or transportation routes with regards to special interest


           points.  However, the Section 3005 permit application review proce-


           dure, including the opportunity for public hearings on the permit


           application, would provide a means for consideration of such factors.


           Other Federal laws, such as the Archeological and Historic Preserva-


           tion Act of 1974, and state and local laws and ordinances would also


           serve to mitigate any potential impacts to special interest points.


           7.3  Significant Uncertainties in the Impact Analysis


                The impact analysis is subject to a number of significant


           uncertainties.  Limited data are currently available with regard to


o^ • "   -
IT1  ; .


                                           7-213

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STOP "
OX "<->•
             both the generation and the management of hazardous wastes.  Uncer-

             tainties exist as to the types and quantities of hazardous  wastes

             generated by various sources, especially non-manufacturing sources.

             Uncertainties also exist as to the number, distribution, capacity,

             and adequacy of existing hazardous waste management facilities.  Data

             are sparse on the generation and release of specific hazardous air,

             water, and soil contaminants by various storage, treatment, and

             disposal methods.  Data and methodologies are not available, for the

             most part, for determining the movement, transformation, and ultimate

             fate of most contaminants released to the environment.  Human and

             biological health effects which are a function of both the concentra-

             tions of such contaminants and the duration of exposure are, there-

             fore, uncertain.  Dose-response data are not yet established for

             determining health effects from many potentially hazardous contami-

             nants.  These limited data, coupled with the site, process, and waste

             specific nature of most impacts, necessitates a qualitative assess-

             ment.  Estimates of the probable range of changes and worst-case

             analyses have both been used to bound the magnitude of potential

             impacts.  The emphasis of the impact analysis has necessarily been

             placed on hazardous manufacturing wastes, though large volumes of

             some other hazardous wastes may also be generated.

                  Furthermore, uncertainties exist with regard to the adequacy of

             existing technologies and methods for controlling the release of

             environmental contaminants.  The long-term effectiveness of landfill
                                            7-214

-------
STC° "  -
0\ T- i; .
             and surface impoundment liners in preventing the discharge of leach-

             ate and other water contaminants is uncertain.  Over long periods of

             time even materials such as clay and polymeric membranes, which are

             usually considered inert, may react with leachate or waste components

             and may fail or become more porous.  Considerable research is cur-

             rently underway to determine the long-term capabilities of various

             liner materials.  Also, while 99.99 percent destruction efficiencies

             have been demonstrated for the incineration of many hazardous wastes,

             such destruction efficiencies have not been demonstrated for most

             hazardous wastes.  Furthermore, in spite of the impressive perfor-

             mances of the incinerators reported in the literature in destroying

             hazardous wastes, most studies were performed under extremely con-

             trolled conditions and only specific products of combustion were

             sampled in many cases.  Problems could occur due to requirements for

             frequent maintenance and extensive operator education in order to

             ensure proper functioning.  Maintenance could be an especially

             serious problem since many wastes burned in incinerators are either

             extremely caustic or produce caustic products when burned.
                                            7-215

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8.0  IMPACTS OF THE ALTERNATIVES

     Five reasonable alternatives to the baseline regulations have

been developed to bracket the overall objectives and the resultant

impacts anticipated from the regulations to be ultimately promulgated

under Subtitle C.  Each of the five alternatives is assessed in this

section to the extent that it elicits changes in impacts relative to

those that would result from implementation of the baseline regu-

lations.  Impacts of the alternatives that would be substantially the

same as those of the baseline regulations are not presented in order

to avoid duplication.

8.1  Potential Changes in Impacts Resulting from the No Action
     Alternative

     As previously discussed, the No Action Alternative is defined as

meaning that no part of RCRA, including Subtitle C, is to be imple-

mented and that hazardous waste management would continue as current-

ly practiced, modified by any future state legislation developed

without Federal guidance.  However, since implementation of RCRA is

mandated by an act of Congress, implementation of this alternative

would not be feasible without an additional act of Congress repealing

RCRA.  The No Action Alternative, therefore, is not realistically

considered a viable alternative at the present time.  The following

discussion briefly outlines some of the potential impacts which could

occur in the unlikely event that this alternative were followed.
                                     8-1

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     8.1.1  Primary Impacts.  In the absence of a Federal hazardous




waste control program under RCRA, the primary means of controlling




hazardous waste management activities would be through programs



developed by individual states and through various sections of other




Federal laws, notably, the Safe Drinking Water Act, the Federal Water




Pollution Control Act, and the Clean Air Act, as amended.  Since




there would be no established mechanism to encourage states to enact




equivalent regulatory approaches and consistent means of control, it




is probable that the states would continue to take different regula-




tory approaches and to exert very different levels of control.  Such




approaches would depend on the individual needs, the types and



amounts of waste generated, and the political climate in each state.




Approaches could range from essentially no control to regulations




more restrictive than the baseline Subtitle C regulations.  Further-



more, state programs would remain subject to pressures for sending




most hazardous wastes to other states, for banning hazardous waste




shipments from other states, and for the enactment of more stringent



or less stringent regulations than neighboring states.  Differences




in definitions and in criteria for characterizing hazardous wastes




would likely be a common occurrence.  The present splintered and




uncoordinated development of hazardous waste control programs would



continue.  This inconsistency of programs would result in the less




effective control of hazardous wastes and would allow the continued




occurrence of those types of incidents previously discussed.
                                     8-2

-------
     A detailed discussion of existing state regulations for selected




states that have promulgated hazardous waste programs is presented in




Appendix A.  Many of the states currently manage hazardous waste




problems on a case-by-case basis.  As of 1978, only 16 states have




specified criteria or lists for identifying hazardous waste.  Most




states identify hazardous materials through broad or generalized




definitions.  Also, only 17 states have (or have proposed) permit




system regulations specifically for the disposal of hazardous waste;




13 states have (or have proposed) standards or regulations for a man-




ifest program; 18 states have (or have proposed) recordkeeping or




reporting standards or regulations; 16 states have (or have proposed)




formalized inspection standards or regulations for some types of haz-




ardous waste facilities; and 13 states have (or have proposed) spe-




cific monitoring program standards or regulations with regard to




hazardous waste.  Many states do, however, have the enabling author-




ity to control each of these activities; however, most of these




states have been waiting for Federal action before proceeding with




their own programs.  Without such action, it is difficult to deter-




mine the outcome of pending waste management programs.




     It is likely that on-site activities would continue to escape




regulation under many states laws.  Existing regulations often apply




only to off-site facilities operated in a non-private capacity.




Without a Federal requirement for on-site control, a large portion of




waste managed on-site could continue to go unregulated.  Regulation
                                 8-3

-------
of hazardous wastes would likely continue to occur on a case-by-case




basis and, as a result, many wastes could continue to escape any con-




trol.  Intrastate movement of hazardous wastes would likely continue




to be poorly controlled.




     The present trend toward control of hazardous wastes is slowly




but steadily increasing as more states extend the limits of their




enabling authority to include hazardous waste management.  It is not




possible to determine whether this trend would continue to occur




independent of the requirements and goals provided by Subtitle C.




National awareness of the hazardous waste problem is increasing as




more environmental problems occur due to the improper management of




hazardous waste  However, individual states desiring to initiate




hazardous waste programs would not be able to use the Federal funding




authorized under the regulations.  Depending on the extent of the




control needed, the financial requirements for effective program




implementation could be a substantial constraint to some states.




      The impacts to air and water quality and to public health that




would occur as a result of this alternative would be a continuation




of those existing effects previously discussed.  In many cases, even




strict control by a state could not protect that state from air or




water pollution originating in neighboring states.  Incidents such as




those described in Chapter 7 would continue to occur, though state




regulations could produce local reductions.  Large amounts of poorly




controlled or uncontrolled hazardous wastes could contaminate many






                                 8-4

-------
water supplies, air sheds, and large areas of land in many scattered




locations.  Public health effects from these materials could be




manifested in many ways.  Of particular concern are the often



insidious effects of long-term, low-level exposure to toxic




materials; such effects often may not become apparent for many years.




      8.1.2  Secondary Impacts.  Current impacts to physiography and




soils, ecological systems, social conditions, land use, water use,




energy use, resource recovery, and special interest points would




continue to occur, though they could be mitigated by the enactment of



more stringent state regulations than those that currently exist. The




implementation of strict state controls would not necessarily protect




states from air and water contaminants originating in neighboring



states with less stringent regulations and from the secondary impacts




of such air and water contaminants.  Incidents such as those




described in Chapter 7 would continue to occur, particulary in those



states that exert little control over hazardous wastes.




     At present, most states do not have regulations or standards for




hazardous waste disposal sites or for disposing wastes in such sites.



As a result, even if a shortage of environmentally acceptable dispo-




sal sites actually exists, there could technically be no shortfall




since few states have requirements to use such sites.  As additional



states develop strict disposal regulations, local shortfalls of envi-




ronmental adequate treatment, storage, and disposal capacity could




occur.
                                     8-5

-------
     Variations in the degree of control states exert over hazardous

wastes could also create a tendency for industries to relocate in

those states with the least stringent requirements.  Other industries

might elect to ship their wastes to such states if treatment and dis-

posal costs in their own state were to be considered too high.  This

could lead to increased incidents of environmental degradation and

potential public health problems in such states.  Any widespread

implementation of import bans, if constitutional, could have severe

effects on states whose soils, climate, and geologic conditions are

generally unsuitable for secure waste disposal.

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

     This section discusses the potential changes in impacts (rela-

tive to those of the baseline regulations) that would occur as a

result of promulgation of the regulations contained in the Phasing of

Generators Alternative.  To avoid considerable duplication in the

presentation, potential impacts discussed in Chapter 7 that would not

be changed under this Alternative are not repeated.  Only major

changes in potential impacts are discussed.

     8.2.1  Primary Impacts.  The change in primary impacts that

could occur under this alternative are discussed below.

     8.2.1.1  Hazardous Waste to be Regulated.  The objective of this

alternative is to reduce the potential for overtaxing resources

(e.g., manpower, capital, disposal sites) beyond their capacity for

responding effectively to the baseline Subtitle C regulations.  This


                                    8-6

-------
would be accomplished by phasing in, over a five-year period from




1980 through 1984, the generators to be regulated (larger generators




first, then smaller generators), such that approximately twenty per-



cent of the total hazardous waste would be controlled during the




first year with an additional twenty percent being controlled each




subsequent year.  This alternative would be implemented by changing



the generator limit defined in the baseline regulations.  Under this




alternative, the generator limit would be quite large the first year,




and would be reduced each succeeding year, such that by the fifth




year it would be 100 kilograms per month.  This procedure would




exclude those hazardous wastes that do not meet the generator limit




from compliance with the generator requirements, though certain




disposal requirements would still apply.  Again, emphasis is placed




upon hazardous wastes generated by the manufacturing industries for




the purpose of analysis.



     To develop phasing limits, data on hazardous waste generation




from the manufacturing industries have been analyzed to estimate




quantities of hazardous waste generated by SIC Code and by EPA




Region, as well as to estimate the number of generating firms.




Appendix H describes the methodology used for estimating the total




potentially hazardous waste generation in the manufacturing indus-



tries.  Appendix I describes the computer program used to determine




the amounts of wastes and number of industries which would be con-




trolled in each year of the phasing alternative.  As in the analysis
                                    8-7

-------
of Che baseline regulations, this alternative is based on the assump-




tion that only about 35 percent of the estimated potentially hazard-




ous waste generated in SIC Code 28 would be subject to regulation,



due to the nature of the toxicity characteristic (see Section 7.1.1




for more detail).




     Using these methods, the generator limit is determined for each




year of the five-year program.  Then, using summary data from




Appendix K, the number of establishments and the EPA Region in which




they are located is determined.  Tables 8-1 through 8-4 show the



distribution of the hazardous waste regulated in each year.  Because




of assumptions and data limitations discussed in Appendices H and I,




Tables 8-1 through 8-4 do not present the specific quantities of




wastes or number of firms that would be subject to regulation during




each year of phasing, but only indicate the EPA Regions and SIC Codes




in which the regulated wastes are contained.



     In order to bring 20 percent of the manufacturing wastes that




are hazardous under control in 1980, it is estimated that the genera-




tor limit would have to be set at 12,900 metric tons per year;  all



establishments generating hazardous waste quantities greater than




approximately 1,075 metric tons per month would be regulated during




the first year.  This could limit control efforts to SIC Codes 26



(Paper and Allied Products), 28 (Chemicals and Allied Products), 29




(Petroleum and Coal Products), and 33 (Primary Metal Industries), as




shown in Table 8-1.  It is estimated that about 75 percent of the
                                    8-8

-------
                                                                      TABLE 8-1

                                                 REGULATED HAZARDOUS  MANUFACTURING  HASTES  DURING THE
                                               FIRST  YEAR OF  PHASING (1980)*  BY REGION  AND  SIC CODE
oo
vo



I II III

26 X X
28 X X X
29 X
33 XX


IV

X
X

X
EPA

V

X
X
X
X
Region

VI VII VIII IX X

X X
XX XX
X X
X X X X
Totals
Wastes
(1000 metric
tons)
157
5170
263
1310
Number of
establishments
af fectedl-
c
f
c
d
Totals-

1000     156   964   1430   1570  1540  938   109    35    78     76         6890
metric
tons

Number of
establish- bdd      d      edaa      aa
affectedt
             *Based on a generator  limit of  1075 metric  tons/month,  chosen, to  Include approximately  20  percent of
              the  total estimated hazardous  wastes  (see  Section  7.1.1).   An "X"  indicates  that at least some  hazardous
              wastes generated  in the appropriate SIC Code would probably be subject to  Subtitle C requirements
              in the corresponding  region.

             tThe  number of establishments subject  to Subtitle C requirements  are  presented as ranges:   a=l-5;
              b=6-10; c-11-25;  d=26-50; e=51-100; f=101-250; g=251-1000;  h=1001-2500; i«=2501 or more.

-------
                                                           .TABLE 8-2

                                         REGULATED HAZARDOUS  MANUFACTURING WASTES DURING
                                      THE SECOND YEAR OF PHASING (1981)* BY REGION AND SIC CODE






1°
I-1
o

SIC Code
26
28
29
31
32
33
34
35
EPA Reelon
I
X
X
X

X
X
X
X
II III
X X
X X
X X

X X
X X
X
X X
IV
X
X
X


X

X
V
X
X
X

X
X
X
X
VI
X
X
X


X
X
X
VII
X
X
X

X
X
X
X
VIII IX X
X X
XXX
XXX
X

XXX
X
X X
Totals
Wastes (1000 metric tons)
947
8790
619
8
104
2790
165
1440
Number of establishments
af fectedt
f
6
e
a
d
g
e
f
Totals

1000
metric     552  2090  2380  2640  4090  1670   532    117    549   246            14,900
tons

Number of
establish-  efffgfe      c      ed
ments      ,.
affectedt
*Based on a generator limit of 303 metric tons/month,  chosen to include approximately 40 percent of the total estimated hazardous
 wastes (see Section 7.1.1).  An "X" indicates that at least some hazardous wastes generated in the appropriate SIC Code would
 probably be subject to Subtitle C requirements in the corresponding region.

tThe number of establishments subject to Subtitle C requirements are presented as ranges:  a=l-5; b=6-10; c=ll-25; d=26-50; e=51-100;
 f°101-250; g=251-10001 g=1001-2500; 1=2501 or more.

-------
                                                                                TABLE 8-3

                                                           REGULATED HAZARDOUS MANUFACTURING WASTES  DURING  THE
                                                           THIRD YEAR OF PHASING (1982)* BY REGION AND SIC  CODE
00
SIC Code
25
26
28
29
30
31
32
33
34
35
37
39
EPA Realon
I

X
X
X

X
X
X
X
X
X
X
II

X
X
X

X
X
X
X
X
X

III

X
X
X

X
X
X
X
X
X
X
IV
X
X
X
X

X
X
X
X
X
X

V
X
X
X
X
X
X
X
X
X
X
X
X
VI
X
X
X
X

X

X
X
X
X

VII

X
X
X
X
X
X
X
X
X
X

VIII

X
X
X
X
X

X
X
X
X

IX X

X X
X X
X X

X
X
X X
X
X X
X X

Totals
Hastes (1000 metric tons)
9
2470
9960
898
9
360
360
3660
486
3000
803
6
Number of establishments
affectedt
e
g
h
f
a
f
f
g
f
8
f
b
Totals

1000
metric  1150  2890  3140  3550  6380  2240   934    205   1120   419
tons

Number
of       gggghgf      d      ge
establish-
ments
affectedt
                                                                                                       22000
                    *Based on a generator limit of 125 metric tons per month, chosen to Include approximately 60 percent of the total estimated hazardous wastes
                    (see Section 7.1.1).  An "X" Indicates that at least some hazardous wastes generated in the appropriate SIC Code would probably be subject
                    to  Subtitle C  requirements In the corresponding region.

                    tThe number of  establishments subject to Subtitle C requirements are presented as ranges:  a-1-5; b=6-10; c-11-25; d=26-50; e=51-100;
                    f°101-250; g=251-1000; h-1001-2500; 1-2501 or more.

-------
                                                                   TABLE 8-4

                                       REGULATED HAZARDOUS  MANUFACTURING WASTES  DURING THE
                                      FOURTH  YEAR OF PHASING  (1983)*  BY  REGION AND  SIC CODE
oo
I
SIC Code

20
22
25
26
28
29
30
31
32
33
34
35
36
37
38
39
Totals
1000
metr tc
tons
Number of
establish-
ments
affectedt




EPA
Region
Totals
Wastes (1000 metric tons) Number of establishments
I


X
X
X
X
X
X
X
X
X
X
X
X
X
X

1740



h


II
X.

X
X
X
X
X
X
X
X
X
X
X
X
X
X

3970



h


III
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X
X

4080



h


IV

X
X
X
X
X
X
X
X
X
X
X
X
X

X

4740



h


V
X

X
X
X
X
X
X
X
X
X
X
X
X
X
X

8830



1


VI


X
X
X
X
X
X
X
X
X
X
X
X
X
X

2940



h


VII
X

X
X
X
X
X
X
X
X
X
X
X
X

X

1430



8


VIII
X


X
X
X
X
X
X
X
X
X
X
X
X
X

330



f


IX



X
X
X
X
X
X
X
X
X
X
X
X
X

1960



h


X



X
X
X


X
X
X
X

X
X


S94



8



14
26
60
3.440
12,600
1.070
87
686
1.070
4.730
1,340
4.330
94
966
22
93

30.600






affectedt
d
e
f
h
i
8
f
g
h
h
h
i
f
g
c
f





i


              *Based on a generator limit of  34 metric  tons per month, chosen to include approximately 80 percent of  the total estimated hazardous wastes
              (see Section 7.1.1).  An "X" indicates that at least some hazardous wastes generated in the appropriate SIC Code would probably be subject
              to Subtitle C requirements in the corresponding region.

              tThe number of establishments subject to  Subtitle C requirements are presented as  ranges:  a=l-5; b=6-10; c=ll-25; d=26-50- e-51-100-
              f=101-250; g=251-1000; h= 1001-2 500; 1-2501 or more.

-------
controlled wastes would be from SIC Code 28.  All EPA Regions would




be involved to some extent; though, as indicated, Regions III, IV,




and V could generate about 65 percent of the regulated wastes.



Approximately 230 establishments could be regulated nationwide.




     In order to bring 40 percent of the manufacturing wastes that




are hazardous under control in 1981, it is estimated that the



generator limit would have to be set at 3,630 metric tons per year;



all establishments generating quantities of hazardous waste greater




than approximately 303 metric tons per month would be regulated



during the second year.  This could extend control efforts to SIC




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




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



Electrical), as shown in Table 8-2.  It is estimated that about 60




percent of the controlled wastes would originate in SIC Code 28.




Control efforts would be more pronounced in EPA Regions III, IV and



V, though their share would decrease to about 61 percent, with one-




half of that being in Region V.  Approximately 1,500 establishments




could be regulated nationwide.




     In order to bring 60 percent of the manufacturing wastes that




are hazardous under control in 1982, it is estimated that the gener-




ator limit would have to be set at 1,500 metric tons per year (125



metric tons per month).  Control efforts could be further expanded to




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




Miscellaneous Plastic Products), 37 (Transportation Equipment), and
                                   8-13

-------
39 (Miscellaneous Manufacturing Industries), as shown in Table 8-3.




Wastes from SIC Code 28 would still predominate, contributing about




45 percent of the total.  EPA Region V would contain about 29 percent



of the wastes, while Regions II, III, IV, and VI would each contain




between 10 and 16 percent.  About 4,300 establishments could be




regulated nationwide.




     In order to bring 80 percent of the manufacturing wastes that




are hazardous under control in 1983, it is estimated that the gen-




erator limit would have to be set at 410 metric tons per year (34



metric tons per month).  This control effort could now expand to




cover portions of the hazardous wastes generated by establishments




in all SIC Codes except 23 (Apparel and Other Textile Products), 24



(Lumber and Wood Products), and 27 (Printing and Publishing), as



shown in Table 8-4.  Again, SIC Code 28 would predominate, though its




share would be reduced to about 41 percent.  Distribution among the



EPA Regions would remain essentially the same as in 1982, though an




additional 8.5 million metric tons would be controlled.




Approximately 15,500 establishments could be regulated nationwide.



     In the fifth and final year of phasing, all hazardous waste




generators would be regulated except those producing 100 kilograms




or less per month.  Table 1-1 presents the quantities of hazardous



wastes from manufacturing industries that would be phased into the




program in 1984, as well as the distribution of the regulated estab-




lishments.  During this final year, industries in virtually every
                                    8-14

-------
manufacturing SIC Code and each EPA Region would be involved in

regulatory actions.  Approximately 232,000 manufacturing establish-

ments would be regulated.

     The net effect of this alternative is that a total of about 74

million metric tons of hazardous industrial wastes could be excluded

from regulation during the first four years following implementation

of the Subtitle C regulations.  These wastes would represent about 50

percent of the total hazardous industrial wastes that could be regu-

lated under the baseline regulations during this period.

     8.2.1.2  Changes to Existing Generation, Transport, Storage,

Treatment, and Disposal Practices and Procedures.  Since this alter-


native only reduces the number of generators who would be subject to

the generator regulations during the first four years following their

implementation, there would be few changes in the impacts previously
            •
discussed.  Those changes that do occur would be limited to the first

five years following implementation of the regulations.  Longer-term

impacts would not change.

     Generators who continue to produce a quantity of hazardous waste

exceeding the generator limit in all years would not be affected by

this alternative.  Generators who produce a quantity of hazardous


waste that exceeds the generator limit of the baseline regulations,

but that does not exceed the generator limit of this alternative,

would be excluded from the generator regulations under this alterna-

tive.  These excluded generators would not have to comply with the
                                   8-15

-------
manifesting, reporting, recordkeeping, or containerization require-




ments discussed in Section 7.1.2.1.  However, as in the case of the




baseline regulations, these generators would still be required to




treat/dispose their wastes in a responsible manner.




     The major options available to these generators would be




disposal in an approved sanitary landfill meeting RCRA Subtitle D




requirements (this would not be allowed for these generators under




the baseline regulations); treatment/disposal in a permitted off-site




facility; or treatment/disposal in a permitted on-site facility (al-




though the generating establishment would not be subject to the gen-




erator regulations, treatment/disposal of hazardous wastes on-site'




would still require permitting of the treatment/disposal facility,




unless the facility was an approved landfill meeting Subtitle D cri-



teria).  It should be noted that without requirements for manifesting




and reporting of these wastes, there would be a greater potential for



generators not to comply with these disposal requirements and a les-




ser potential for determining whether generators complied.  It is




therefore likely that additional wastes would be treated/disposed in




an environmentally unacceptable manner under this alternative.



     There would be few changes in transport, storage, treatment, or




disposal practices under this alternative.  Transporters would still



have to comply with all regulations for the transport of manifested




wastes; however, there would be fewer such manifested shipments.




Transport distances would likely decrease during the first four years
                                    8-16

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since the excluded hazardous wastes could be sent to sanitary land-


fills which would likely be more abundant and situated closer than


off-site permitted facilities.  To the extent generators would send


their wastes to Subtitle D landfills, there would potentially be a


lesser number of treatment/disposal facilities, primarily on-site


facilities, that would have to be modified during the first few years


following implementation of the regulations.  However, to the extent


that generators reverted to on-site treatment/disposal when again


subject to the generator regulations, their facilities would have to


be modified as before.  There would be no change in the requirements


for facilities that store, treat, or dispose hazardous wastes.
r

     It should be noted that this alternative would allow most gener-


ators a longer time to familiarize themselves with the implications


of the regulations before being required to comply.  They would have


a better opportunity to develop plans for compliance and be less sub-


ject to making quick decisions.  Also, there would be an opportunity


to detect any unexpected problems that arise from the implementation


of the regulations and to make any necessary modifications in the


regulations before all generators were included.


     8.2.1.3  Administrative Changes.  A major benefit resulting from


this alternative would be the gradual expansion of administrative re-


quirements, rather than the abrupt imposition of such requirements.


Administrative requirements, primarily paperwork, would be reduced


during the first four years following implementation of the regula-


tions.  The reduction in these administrative requirements could also



                                    8-17

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encourage additional states to apply for interim or full authoriza-

tion.

     The estimated change in the number of hazardous waste generators

who could be required to comply with the generator requirements is

shown in Tables 8-1 through 8-4.  Based upon Che assumptions dis-

cussed in Section 7.1.3.6, it is estimated that industrial generators

could have to prepare a total of between 660,000 and 1.3 million

manifests during the period from 1980 to the start of 1984.  This

represents about a SO percent reduction in the number of manifests

that would have to be prepared by industrial generators during this

period under the baseline regulations.  During the first year, the

industrial generators could have to prepare 72,000 manifests, an 80

percent reduction.

      During the first 6 years*, the aggregated generators,

transporters, and owners/operators of hazardous waste management

facilities could each have to keep a total of between 3.2 million and

5.2 million manifests in storage; this would represent over a 30

percent decrease in manifests in storage during this period.  During

the first year, 72,000 manifests could have to be stored, an 80

percent reduction.

     During the first four years, it is estimated that industrial

generators could have to prepare a total of about 22,000 annual
*Due to the requirement for three-year storage of manifests, the
 impact of this alternative on the number of manifests in storage
 would continue for the first six years.


                                    8-18

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reports; this would represent over a 97 percent decrease in such



annual reports.  During the first year, about 230 annual reports




could have to be prepared, a 99.9 percent reduction.



     It is estimated that transporters could have to file a total of




between 280 and 400 spill reports during the first 4 years, a reduc-




tion of over 45 percent.




     As previously discussed, there would be, at most, a small re-




duction in the number of permitted facilities during the first four




years.  As a result, there could be a small reduction in the number



of most reports prepared by permittees.  However, since the addi-




tional hazardous wastes that would not be subject to the generator




requirements under this alternative and would have to be sent to



approved sanitary landfills or to permitted facilities, there would




likely be an increase in the number of unmanifested shipments




received at permitted facilities.  Consequently, permittees could



have to prepare an increased number of reports on the receipt of




unmanifested wastes.  The increase in the length of the reporting




interval for such reports under this alternative would serve to




reduce the number of additional reports prepared.




     8.2.1.4  Air and Water Impacts.  To the extent that a total of




74 million metric tons of hazardous industrial wastes excluded from



the generator regulations under this alternative were not to be




managed in a manner equivalent to that required under the baseline




regulations, there would be an increased potential for the release of




air and water contaminants from these wastes.  These air and water





                                   8-19

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contaminants could be released as described in Sections 7.1.4.1 and




7.1.5, and could result in the types of incidents and impacts dis-




cussed in those sections.  The release of air and water contaminants



could continue for many years following the disposal of such wastes.




     3.2.1.5  Public Health Impacts.  Changes in public health




effects would be directly related to changes in the release of air,




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




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




public health impacts discussed in Section 7.1.6 to continue to



occur.  Chronic effects related to long-term, low-level exposure to




such contaminants could continue to occur for many years following




improper disposal of such wastes.



     8.2.2 "Secondary Impacts.  To the extent that a total of 74 mil-




lion metric tons of hazardous industrial wastes were not to be man-




aged in a manner equivalent to that required under the baseline regu-



lations, there would be an increased potential for additional soil




contamination, as described in Section 7.2.1.  Changes in impacts to




the biological environment, to water use, to land use, and to special




interest points would be directly related to these changes in the re-




lease of air, water, and soil contaminants.  To the extent that




increased releases were to occur, there would be an increased poten-



tial for the type of impacts discussed in Section 7.2 to continue to




occur.  These impacts, especially biological and water use impacts,




could continue to occur for many years following improper disposal of




such wastes.





                                  8-20

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     There would be less potential for demographic changes during the



first four years due to reduced economic demands on generators that




would in turn reduce the potential for plant closings or relocation,



due to reduced demands for new hazardous waste management facility




capacity, and due to the reduced administrative requirements.  How-




ever, demographic shifts that were just delayed during the first four




years could start to occur following the fourth year.  The longer




transition period would, however, provide an increased opportunity




for planning and instituting measures to mitigate the potential



impacts of any population shifts.  The longer transition period could




also reduce the potential for some plant closings by providing gener-




ators with an increased opportunity to evaluate alternatives avail-




able to them.




     With regard to hazardous waste management facility capacity,




Section 7.2.4.1 indicates that under the baseline regulations there




would potentially be sufficient capacity on a nationwide basis for




managing hazardous industrial wastes during the first four years,




with one exception.  In the case of no growth of existing environ-




mentally adequate capacity and 25 percent off-site shipment, there




could be a capacity shortfall by 1981, the second year of regulation.




Under this phasing alternative, the potential for such a capacity



shortfall could be delayed until 1983, the fourth year of regulation.




In addition, there would be a lesser potential for any shortfalls to




occur in all the other cases examined in Section 7.2.4.1.
                                    8-21

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Furthermore, there would be increased time for planning the siting of

any new facilities that could be required.

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

     This section discusses the potential changes in impacts

(relative to those of the baseline regulations) that could occur from

the promulgation of the regulations contained in the Enhanced Public

Health and Environmental Protection Alternative.  To avoid

considerable duplication in the presentation, potential impacts that

would not be changed under this alternative are not repeated.  Only

major changes in potential impacts are discussed.

     8.3.1  Primary Impacts.  The major changes to primary impacts

that could occur as a result of implementation of this alternative

are.discussed in the following sections:

     •  Hazardous Wastes to be Regulated;

     •  Changes to Existing Generation, Transportation, Storage,
        Treatment, and Disposal Practices and Procedures;

     •  Administrative Changes;

     •  Air Impacts;

     •  Water Impacts;

     •  Public Health Impacts.

     8.3.1.1  Hazardous Waste to Be Regulated.  Under this alterna-

tive, two additional hazardous waste characteristics would be added

to the Section 3001 regulations and the existing toxicity criteria

would be expanded so as to bring additional potentially hazardous
                                 8-22

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wastes under regulation.  It is expected that the expanded toxicity




characteristic would result in the regulation of most, if not all, of




the potentially hazardous organic wastes that would be excluded from




regulation under the baseline regulations, as discussed in Section




7.1.1.  Additionally, this alternative would eliminate the 100




kilogram per month generator limit and the previously discussed




exclusion for generators engaged solely in farming or retail trade.




Thus, all generators of any amount of wastes considered hazardous




under the Section 3001 regulations (except household wastes) would




have to comply with all Subtitle C regulations.




     Based upon the expanded toxicity characteristic and the proce-




dures described in Chapters 6 and 7 and Appendix H, it is estimated




that approximately 57 and 65 million metric tons of hazardous




manufacturing wastes would be controlled under this alternative in




1980 and 1984, respectively.  The expanded criteria could also result




in the inclusion of potentially large volumes of non-manufacturing




wastes, such as those described in Section 6.1.2.  The portion of




these wastes which would be identified as hazardous by the




characteristics is unknown, but could be quite large.



     There could thus be a minimum of 22 and 25 million metric tons




of additional wastes declared hazardous and brought under regulatory



control with this alternative in 1980 and 1984, respectively, as com-




pared to the baseline regulations.  This would represent about a 63




percent increase in the hazardous wastes controlled in both these
                                     8-23

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years.  The hazardous wastes controlled under this alternative would




represent about 16 and 19 percent, respectively, of the total annual




industrial solid waste stream currently estimated to be generated.




     8.3.1.2  Changes to Generation, Transport, Storage, Treatment,




and Disposal Practices.  Additional changes to generation, transport,




storage, treatment, and disposal practices would be likely to occur




under this alternative due to the additional wastes being regulated;




due to the enactment of more stringent environmental requirements;




due to resultant increases in storage, treatment, and disposal costs;




and due to the imposition of additional procedural and operational




requirements.




     Generation.  Under this alternative, many additional generators




would be required to comply with the generator regulations.  The ad-




ditional generators to be regulated include those previously ex-




cluded due to the generator limit of 100 kilograms per month, farmers




and retailers who only generate hazardous wastes other than waste




automotive oil, generators who only produce wastes that now meet the




expanded toxicity characteristic or the new infectious or radioactive




characteristics, and generators who only produce 'special wastes'.




Section 8.3.1.3 presents estimates of the number of additional gener-




ators to be regulated.  These generators would be required to change




their existing practices and procedures (as indicated in Section




7.1.4.1) with regard to manifesting, reporting, recordkeeping, con-




tainerization, and labeling.  Furthermore, these generators and those
                                 8-24

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generators previously regulated would both be subject to shorter



reporting intervals, as indicated in Table 4-2.




     Due to further increases in costs to hazardous waste generators




and costs associated with hazardous waste transport, storage, treat-




ment, and disposal under this alternative, all regulated generators




would potentially have an increased incentive to further modify their




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



hazardous wastes generated and to enable the increased recycling of




hazardous wastes as process feedstocks.




    Transport.  Due to the additional wastes subject to the generator




regulations, additional transporters would likely have to comply with




the transporter regulations discussed in Section 7.1.2.2.  As a




result there would likely be fewer instances of midnight dumping and




spills from the transport of these additional wastes, as compared to




existing practices.  However, any increases in the average distance



over which hazardous wastes are transported under this alternative




could lead to an increase in vehicular accidents.  This would off-




set some of the potential for a reduction in spills.




     The average distance over which hazardous wastes are trans-




ported would be likely to increase due to several factors.  The more




stringent treatment and disposal requirements under this alternative



would likely further decrease both the amount of existing on-site and



off-site treatment/disposal capacity that could be permitted and the




number of sites acceptable for construction of new facilities.  Any



such decreases in available facilities and sites would potentially






                                    8-25

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lead to increased transport distances.  Reductions in permittable on-



site treatment/disposal capacity could further result in additional




wastes being sent off-site for treatment/disposal.  Increases in



treatment/disposal costs could also further increase the distance




over which wastes could be economically transported for resource




recovery purposes.  However, increased on-site resource conservation




and recovery, as described above, could tend to reduce the quantity




of wastes sent off-site.




     The elimination of the use of a delivery document in lieu of a



manifest would further affect existing transportation practices.  The




use of specific delivery documents is now required under Interstate




Commerce Commission (ICC) regulations for transporters engaged in




interstate commerce and under DOT regulations for the interstate




transport of hazardous materials; as previously indicated, some




states have also applied the DOT regulations to intrastate shipments



of hazardous materials.  The requirement under this alternative that




all hazardous waste transporters use manifests, not delivery docu-




ments, could result in those transporters now being required to use




delivery documents to also carry a manifest.




     Storage.  Due to the additional generators and wastes regulated




under this alternative, additional storage facilities would likely



have to comply with the storage regulations discussed in Section




7.1.2.3.  Some of these existing storage facilities would be required




to be modified or to close.  Existing practices at most of these




storage facilities would also have to be changed as previously





                                     8-26

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indicated.  In addition, all regulated storage facilities would have




to comply with the additional requirements contained in Table 4-2.




As indicated in Section 7.1.2.3, data are not available to estimate



the number of facilities that would be affected, nor the quantities




of wastes that would be affected.




      Treatment/Disposal.  Due to the additional generators and




wastes regulated under this alternative, additional treatment/



disposal facilities would have to comply with the treatment/disposal




regulations discussed in Section 7.1.2.4.  Types of facilities likely




to come under regulation under this alternative include those  facil-




ities used exclusively for 'special wastes' and those facilities used




solely by farmers.  Some of these facilities would be closed because




they could not comply with the regulations or could not be economic-




ally modified.  Some previously regulated facilities that would be




permitted under the baseline regulations could be closed under this



alternative or could require additional modifications because of the




more stringent requirements.  To the extent that existing on-site




facilities were closed, increased quantities of hazardous wastes




could be sent off-site; however, increased on-site resource conserva-




tion and recovery applications could off-set such a change.




      Existing practices would have to be changed at most of the




additional facilities to be regulated under this alternative, as




indicated in Section 7.1.2.4.  In addition, these additional facili-




ties as well as all previously regulated treatment/disposal
                                     8-27

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facilities would now have to comply with the more stringent require-

ments contained in Table 4-2.  Due to these more stringent require-

ments and due to the costs associated with them, there would also be

a potential for increases in the treatment of wastes for such pur-

poses as volume reduction, energy recovery, and resource recovery.

The regulation that the permitting authority could require poten-

tially recoverable wastes to be land disposed in a segregated manner

could further increase resource recovery from such wastes.

     8.3.1.3  Administrative Changes.  Several changes in the admin-

istration of the hazardous waste management program would result from

promulgation of the regulations within this alternative.  These

regulations would affect:

     •  State administration of the program;

     •  Overlapping Federal and state programs;

     •  Number of generators required to comply with the regulations;

     •  Number of transporters required to comply with the
        regulations;

     •  Number of storers, treaters, and disposers required to obtain
        permits;

     •  Paperwork requirements.

     State Administration of the Program.  It is likely that fewer

states would apply for authorization under this alternative because

expansion of both the quantity of hazardous wastes and the number of

generators, transporters, storers, treaters, and disposers being

regulated, plus the increases in reporting frequencies, would lead to
                                  8-28

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increased administrative and manpower requirements for authorized




states.




     Overlapping Federal and State Programs.  Since Subtitle C prohi-



bits any state from enacting less stringent regulations than those in




the Federal program, the potential for overlapping Federal and state




programs would be reduced under this alternative.  The more stringent




standards and increased amount of hazardous waste controlled under




this alternative would reduce the potential benefits to, and thus the




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



ardous waste program.  It is not possible at this time to estimate




the number of states, if any, that would wish to have their own inde-




pendent programs in addition to the Federal program under this




alternative.




     Number of Generators Required to Comply with the Regulations.




As indicated in Section 8.3.1.2, there would be an increase in the



number of generators required to comply with the regulations.  Under




the baseline regulations, approximately 270,000 to 300,000 generators




are identified as potentially having to comply with the regulations.




The elimination of the generator limit could result in up to an addi-




tional 81,000 manufacturing generators being required to comply (see




Section 7.1.3.3).  The elimination of the generator limit and the




transfer of liability contract could result in up to an additional




217,000 automotive service stations being required to comply.  The




elimination of the exclusion for farmers and retailers, coupled with
                                     8-29

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the elimination of the generator limit and the transfer of liability



contract, could result in up to 1.5 million farmers (Trask, 1977) and




up to 42,000 dry cleaning facilities (Battelle Columbus Laboratories,




1978) being required to comply.  An indeterminable number of other




generators (e.g., 'special waste generators'  and other retailers)




could also be required to comply due to the expansion in the wastes




identified as hazardous as well as to the elimination of the other




provisions previously discussed.  Thus, on the order of 2.2 million




generators within these identified categories could be required to



comply with the regulations under this alternative.  This would




represent about a 700 percent increase in the number of generators




being regulated.



     Number of Transporters Required to Comply with the Regulations.




The increased amounts of regulated hazardous wastes that would poten-




tially be transported off-site would likely result in an indetermin-




able increase in the number of transporters carrying hazardous




wastes.




     Number of Storers, Treaters. and Disposers Required to Obtain




Permits.  Since there are no permit exclusions under the baseline




regulations for storage, treatment, or disposal facilities that han-




dle only small quantities of hazardous wastes, all facilities stor-



ing, treating, or disposing hazardous wastes would be required to




obtain a permit under the baseline regulations with the exception of




those generators who store wastes for less than 90 days prior to
                                    8-30

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off-site transport.  With one exception the only additional permit-




tees under this alternative would be those facilities that handle




wastes that would not be classified as hazardous under the baseline




regulations, but that would be classified as hazardous under this




alternative.  The exception is that the additional facilities that




could be needed to satisfy the potential capacity shortfall under




this alternative (see Section 8.3.2.4) would also require permits if




they were to be constructed.  Based upon Section 8.3.2.4, approxi-




mately 120 additional facilities could require permits by 1984.  How-




ever, to the extent that additional capacity would be added to exist-




ing facilities there would be a lesser number of such additional




permittees.



     Paperwork Requirements.  Based upon section 8.3.2.4, the indus-




trial generators could have to prepare between 580,000 and 1.1




million manifests annually by 1984.  The aggregated generators,




transporters, and hazardous waste management facility owner/operators




could each have to keep between 1.7 million and 3.4 million mani-




fests in storage on an annual basis.  This would represent over a 60




percent increase in both requirements as compared to the baseline




regulations.  This increase would even be greater for any transpor-




ters who would now have to keep both a delivery document and a mani-




fest in storage.  In addition, transporters would have to file a




total of between 220 and 440 spill reports annually—approximately a




60 percent increase.
                                    8-31

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      The additional 2.2 million identified generators would have to



prepare about 8.8 million quarterly reports on an annual basis; this




would be over a 2,800 percent increase in such annual reporting.  As



indicated in Section 7.1.3.6, most potential permittees would be on-




site facilities and would not prepare additional quarterly reports




based on the manifests.  Hazardous waste management service industry




facilities and Federal installations could, however, prepare about




1400 such reports—a 300 percent increase.  The permittees identi-




fied in Section 7.1.3.5 could prepare up to 117,000 monitoring



reports annually; this would not represent any change.  Thus, there




could be upwards of 8.9 million quarterly reports prepared annually




by generator, storers, treaters, and disposers—over a 2,100 percent




increase.




     The identified generators and permittees would have to file over




2.2 million notifications under Section 3010—about a 700 percent in-



crease.  Furthermore, since potential permittees would have to re-




new permits every 5 years rather than being issued one permit good




for the projected life of the facility as under the baseline regula-




tions, there could be up to a six-fold increase (in the case of a




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




ing permits.  These potential permittees would also have to prepare




approximately 29,000 Supplemental Environmental Analyses as part of




the initial permit review procedure; these Supplemental Environmental




Analyses would not be required under the baseline regulations.
                                    8-32

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     8.3.1.4  Air Impacts.
     Air Quality.  The regulations under this alternative would have
the potential to cause further changes, primarily reductions, in air
emissions resulting from the generation, transport, storage, treat-
ment, and disposal of hazardous wastes, as compared to the baseline
regulations.
     Generation.  As previously discussed, the baseline regulations
would not have a direct effect on potential air emissions resulting
from activities and processes generating hazardous wastes.  However,
to the extent that the requirements under this alternative would
cause further changes in the economics of storage, treatment, or
disposal relative to those of the baseline regulations, there would
be a greater potential for generators to make process modifications
designed to further increase hazardous waste recycling and to reduce
the quantity and/or types of hazardous wastes generated; any such
process modifications would likely lead to changes in air emissions
released by processes generating hazardous wastes.  Furthermore, to
the extent that additional generators would be brought under control
of the program through the expanded definition of hazardous wastes
and the elimination of exclusions, the potential for such process
modifications and resultant changes in air emissions would be
increased.
     Transport.  As indicated in Section 7.1.4.1, there are three
major ways air contaminants are released by the transport of hazard-
ous wastes:
                                 8-33

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

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

     •  Through emissions resulting from the operation of the
        transport vehicle.

As discussed below, this alternative would affect, to varying

degrees, the potential for the release of air emissions from each of

these sources.

     To the extent that the additional 25 million metric tons of

potentially hazardous industrial wastes (plus other hazardous wastes)

brought under the regulations annually by 1984 would otherwise have

been improperly covered, sealed, containerized, or segregated during

any transport, the potential for the release of fugitive emissions by

such transport and from any resultant spills or explosions would be

reduced as described in Section 7.1.4.1.  The following example il-

lustrates an incident that occurred from the transport of a hazardous

waste that would not likely be regulated under the baseline regula-

tions but which would likely be regulated under this alternative:

     •  In southern Louisiana, industrial wastes containing
        hexachlorobenzene (HCB), a relatively volatile material, were
        transported over a period of time to municipal landfills in
        uncovered trucks.  High levels of HCB have since been
        reported in the blood plasma of individuals along the route
        of transport.  In a sampling of 29 households along the truck
        route, the average plasma level of HCB was 3.6 ppb, with a
        high of 23 ppb.  The average plasma level of HCB in a control
        group was 0.5 ppb with a high of 1.8 ppb (Farmer et al.,
        1976).

     Both the total quantity of regulated hazardous wastes being

transported and the average distance over which such wastes are

                                     8-34

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transported could increase under this alternative, as previously

indicated.  Additional transport would result in increased vehicular


emissions and in an increased potential for vehicular accidents which

could further release air emissions.  However, transport of hazardous

wastes in accordance with the regulations discussed above would

reduce the potential for spills and explosions from improper trans-

port and from resultant vehicular accidents.  This would off-set some

of the potential for increased vehicular accidents to result from

increased transport distances.  The changes in both the vehicular

emissions and emissions resulting from accidents would be dependent

upon such factors as the increase in travel distances, the change in

portion of hazardous wastes transported off-site, and the increase in

the amount of regulated wastes being transported.

     Using the methodology and assumptions described in Section

7.1.4.1, the potential change in vehicular air emissions from the

transport of the hazardous industrial waste regulated under this

alternative has been estimated for four possible transport distances

for both 13 and 25 percent off-site shipment of hazardous wastes in

1984*.  Table 8-5 shows the change in vehicular emissions relative

to those of the baseline regulations (as presented in Table 7-8).

For example, for a 100-mile round-trip distance with 13 percent
*In this estimate, it is assumed that under the baseline regu-
 lations there would be 15 percent off-site shipment for those
 hazardous wastes that would not be regulated under the baseline
 regulations, but which would be regulated under this alternative.
                                    8-35

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                         TABLE 8-5

ESTIMATED CHANGE IN VEHICULAR MISSIONS IN 1984 FROM TRANSPORT OF
ADDITIONAL HAZARDOUS INDUSTRIAL WASTES UNDER SUBTITLE C REGULATIONS

Wastes
transported
off -site
13 percent



25 percent



Average
round- trip
distance
(miles)
100
200
500
1,000
100
200
500
1,000
Change in emissions (metric
Carbon monoxide
-100
550
2,500
5,700
480
1,700
4,900
11,600
Hydrocarbons
-15
90
400
910
80
280
100
1,900
Nitrogen
oxides
-70
400
1,800
4,200
350
1,300
3,600
8,500
tons)
Particulates
-5
25
110
260
20
80
220
530

Sulfur
oxides
-10
50
240
560
50
170
480
1,100

-------
off-site treatment/disposal, the decrease in each air emission under

this alternative could be equal to about 60 percent of that which

could occur under the baseline regulations.  For a 1,000-mile round-

trip distance with 25 percent off-site treatment/disposal, the

increase in each air emission under this alternative could be equal

to about 60 percent of that which could occur under the baseline

regulations.  In this latter case, the additional increase in each

air emission would be less 0.04 percent of the total U.S. emissions

of that air pollutant and less than 2 percent of the total U.S. area

emissions of that pollutant from heavy-duty, diesel-powered vehicles.

     Based upon the methodology and assumptions described in Section

7.1.4.1, there could be on the order of 220 to 440 transportation-

related hazardous wastes spills annually by 1984.  As previously

discussed, it is not possible to estimate the number of spills that

would have occurred if the additional 25 million metric tons of

hazardous wastes were not regulated under this alternative.

     Storage, Treatment, and Disposal.  As discussed in Section

7.1.4.1, there are several major ways that air contaminants can be

released by current hazardous waste storage, treatment, or disposal

practices:

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

     •  Through fugitive emissions from ground-based treatment/dis-
        posal activities such as landfills, landfarms, and surface
        impoundments;
                                 8-37

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

     •  Through emissions generated by spills, fires, explosions, and
        other accidents;

     •  Through the combustion of hazardous wastes by incineration or
        open burning;

     •  Through fugitive emissions from other treatment activities;

     •  Through fugitive emissions from facility construction or
        modification.

This alternative would affect the potential for the release of air

emissions from each of these sources as discussed below.

     The additional 25 million metric tons of potentially hazardous

industrial wastes (plus other hazardous wastes) estimated to be

brought under control of the regulations annually by 1984 would now

have to be stored, treated, or disposed in accordance with the

Section 3004 regulations.  Since, as previously discussed, most of

these wastes would otherwise have been stored, treated, or disposed

by methods that are not likely to be enviroraentally acceptable under

the Section 3004 regulations, the overall potential for the release

of hazardous air emissions from the management of such additional

wastes would be reduced as described in Section 7.1.4.1.

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

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

additional wastes under this alternative compared to the unregulated

methods that would have been used under the baseline regulations.

Such shifts would change both the types and quantities of air
                                     8-38

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emissions generated from the management of specific wastes.  For




example, a shift from landfilling to incineration of a particular




waste would result in the increased release of combustion products



and the reduced release of particulate matter and/or volatile gases.




Such shifts^ could, to an indeterminable extent, either enhance or




reduce the potential for reductions in specific air emissions under




this alternative.  Furthermore, the construction of new facilities



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




the facility and along any transport routes.  Closure of existing




facilities could lead to reduced releases of air emissions in the




vicinity of the facility and along transport routes.  The net result




could be both a localized and/or nationwide reduction in the re-




leases of many air contaminants from hazardous waste management and




a localized and/or nationwide increase in the total releases of other




air contaminants.  Thus while there would most likely be improvements



in air quality due to this alternative, there could also be some lo-




calized degradation of air quality.  All releases of air contaminants




and any localized degradation of air quality would, however, have to




be in compliance with all applicable requirements (e.g., Clean Air




Act, OSHA standards, state standards, and Subtitle C standards).




     The following two examples illustrate incidents that occurred




from the disposal of hazardous wastes that would not likely be




regulated under the baseline regulations but which would likely be




regulated under this alternative:
                                    8-39

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     •  The hexachlorobenzene wastes, previously discussed under
        transportation, were disposed in landfill items in southern
        Louisiana; some of this relatively volatile waste was covered
        following disposal, some was not.  Soil and plant samples
        taken near the landfill area showed a decreasing HCB content
        as distance from the landfill increased.  The HCB levels in
        the plasma of landfill workers was reported to range from 2
        to 345 ppb; the average level in a control was 0.5 ppb with a
        high of 1.8 ppb.

     •  Vinyl chloride monomer (VCM) is retained in sludge wastes
        produced during polyvinyl chloride (PVC) processing.
        Following disposal, the gaseous VCM escapes from the sludge
        if not removed before disposal.  A study by Markle et al.
        (1976) indicated background air concentrations of about 0.1
        to 0.3 ppm VCM exist at landfills where PVC sludge has been
        disposed for several years.   Peak concentrations on the order
        of 1.0 ppm VCM were observed at normal breathing heights as
        long as 24 hours after the PVC sludge deposits were covered.
        Other air samples collected in the vicinity of a New Jersey
        landfill indicated that vinyl chloride was continuously
        emitted from the landfill; vinyl chloride levels as high as
        0.4 ppm were found in a residential area one mile from the
        landfill (Office of Solid Waste, Hazardous Waste Management
        Division, 1978b.)

      Additional requirements imposed by this alternative would

further reduce the potential for the release of air contaminants from

the management of both the additional 25 million metric tons of

hazardous wastes controlled under this alternative and the 40 million

metric tons also controlled under the baseline regulations.  The

major impact would result from changing the application of the

Theshold Limit Values (TLV) from an air human health and environmen-

tal standard to a mandatory standard with which facilities must

always be in compliance, and the imposition of the TLV's as a maximum
                                      8-40

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concentration not to be exceeded at any time rather than as a time-




weighted average not to be exceeded over an 8-hour day and 40-hour




week.  To the extent that non-point source emissions, such as those



from landfills, landfarms, surface impoundments, and storage areas




(see section 7.1.4.1 for specific examples), would exceed the TLV's




under the baseline regulations there would be further reductions in



the release of air contaminants under this alternative.




     The reduction in the maximum vapor pressure (from 78 mm mercury




at 25 C to 53 mm mercury at 25 C) of wastes that may be placed in



storage tanks vented directly to the atmosphere or treated/disposed




in landfills, landfarms, surface impoundments, or basins would fur-




ther reduce the potential for the release of emissions from the




management of these volatile wastes, as described in Section 7.1.4.1.




Examples of wastes constituents which have a vapor pressure between




53 and 78 mm mercury at 25 C and which could be identified as hazar-



dous under the expanded Section 3001 lists and characteristics




include boron tribromide, 1,2-dichloropropane, methacrylonitrile, and




thiophene.



     The requirement that owners/operators of inactive storage,




treatment, or disposal sites would have to comply with the Section




3004 regulations would reduce the potential for releases of air



emissions from wastes remaining in such inactive sites.
                                    8-41

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      To the extent that additional storage, treatment, or disposal




facilities would have to be modified or would have to be constructed




under this alternative (see Section 8.3.2.4), there would be an in-



crease in fugitive dust and vehicular emissions from such construc-




tion activities.  These emissions would be extremely site dependent




as previously indicated.




     Climate.  Localized impacts to temperatures, humidities, and




low-level wind patterns could occur in those areas in which addi-




tional facilities were to be constructed and operated.  Any such



effects would be expected to be extremely localized.




     8.3.1.5  Water Quality Impacts.  The regulations under this




alternative would have the potential to further decrease adverse



water quality impacts resulting from generation, storage, transport,




treatment, and disposal of hazardous wastes as compared to the base-




line regulations.



     Many of the potential changes to groundwater and surface water




impacts would occur in much the same manner as the potential changes




discussed under air quality.  To avoid redundant discussions, such



changes are briefly summarized below rather than discussed in detail.




Following this summary, additional major changes are described.




     Any process modifications designed to further reduce the



quantity and/or types of hazardous wastes generated or to increase




recycling of such wastes would likely lead to changes in water
                                     8-42

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effluents produced by such processes, thus changing the potential for




groundwater and surface water contamination by such effluents.  To




the extent that additional generators were to be brought under the



control of the program through the expanded definition of hazardous




wastes and the elimination of generator exclusions, the potential for




such process modifications would be increased.



     Increases in the quantity of hazardous wastes being transported




subject to the Subtitle C regulations would reduce the potential for




midnight dumping and spills and for resultant impacts to ground-



water and surface water.  However, increases in the average distance




over which wastes are transported would increase the potential for




vehicular accidents and could off-set some of the potential for a




reduction in spills.  Increased transport distances would also result




in increased vehicular emissions and in an increased potential for




oil, grease, and the hydrocarbons and heavy metals contained in



vehicular exhausts to be carried into waterways by run-off.




     The major beneficial impacts to groundwater quality would result




from the elimination of the 'special waste1 standards for facilities




dealing with large volume wastes (e.g., phosphate slimes); from the




added requirement that inactive facilities must comply with the




Section 3001 regulations; from the lower permeability required for



soil liners for landfills and surface impoundments; and from the
                                      8-43

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control of at Least an additional 25 million metric tons of poten-




tially hazardous wastes annually by 1984.




     Under the baseline regulations there is a requirement that there




be no discharge from a hazardous waste storage, treatment, or




disposal facility to the groundwater, unless it can be demonstrated




that such discharge does not endanger Underground Drinking Water



Sources anywhere outside the facility's property.  (Endangerment




means degradation such that the water exceeds a National Interim




Drinking Water Standard, or that it becomes necessary to treat the




water more than would otherwise have been necessary for any present




or future use.)  This alternative would have the potential for




further reducing discharges of hazardous wastes to groundwater (and




thus degradation of groundwater} over and above those reductions




which would occur under the baseline regulations.  This would result




both from further reductions in discharges from permitted facilities



and from an increase in the amount of wastes subject to regulation.




Section 7.1.5 describes the potential for reducing groundwater and




surface water impacts by control of these additional wastes.



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




type of methods used to treat/dispose the additional wastes regulated




under this alternative compared to the unregulated methods used under



the baseline regulations.  As previously discussed, such shifts could




result in localized changes in the release of specific water
                                      8-44

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pollutants under this alternative compared to the proposed re-




gulations.




     A number of incidents cited in Appendix J involve wastes which



might not be controlled under the baseline regulations, but which




would be controlled under this alternative.  For instance, the inci-




dent of groundwater contamination by arsenic, discussed in Section




7.1.5, would escape control under the baseline regulations




due to the small quantities of waste involved (less than 100 kilo-




grams per month) and due to the fact that the waste was generated by



farmers.  This alternative would eliminate both of those exclusions




and would require such wastes to be manifested and sent to a permit-




ted disposal facility.



     8.3.1.6 Public Health Impacts.  Under this alternative, the




potential for providing public health benefits would be increased




relative to that of the baseline regulations.  Section 7.1.6



discusses public health under the baseline regulations.




     In addition to the 40 million metric tons of potentially hazard-




ous manufacturing waste which would be controlled under the proposed



regulations, another 25 million metric tons would be brought under




control annually by 1984.  Most of this increase would be attribut-




able to the additional toxic wastes that would now be considered haz-



ardous under the Section 3001 regulations.  Part of the increase




would also be due to the inclusion of additional infectious wastes




and radioactive wastes.  Based upon current practices, a large
                                    8-45

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portion of these wastes would have been transported, stored, treated,

or disposal in a manner that would not be acceptable under this

alternative.  Due to the inclusion of these wastes, there would be

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

and for fires, explosions, spills, and other accidents.  As a result,

there would be less of a potential for the occurrence of associated

public health incidents.  Furthermore, the more stringent standards

for hazardous waste management under this alternative would reduce

the potential for release of contaminants and for the occurrence of

associated health problems from the management of those wastes

already controlled under the baseline regulations (see Sections

8.3.1.4, 8.3.1.5, and 8.3.2.1).

     Although the characteristics and lists under the baseline

regulations identify many hazardous wastes, a number of other

potentially hazardous wastes would not be regulated.  In particular,

many potentially toxic wastes which are suspected to be carcinogenic,

mutagenic, or teratogenic substances are not specifically listed and

could be excluded from regulation.

     The following examples illustrate health incidents that occurred

from the management of hazardous wastes that would not likely be

regulated under the baseline regulations, but which would likely be

regulated under this alternative:

     •  In southern Louisiana, industrial wastes containing
        hexachlorobenzene (HCB) were transported in uncovered trucks
        and left uncovered at landfills.  In a sampling of residents
        from 29 households situated along the transport route, the

                                  8-46

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        average plasma level of HCB was 3.6 ppb, with a high of 23
        ppb.  The range for Che landfill workers exposed to HCB was 2
        to 345 ppb.  In comparison, the average plasma HCB level in a
        control group was 0.5 ppb, with a high of 1.8 ppb (Farmer et
        al., 1976).  HCB is considered to be a moderately toxic
        substance.  In cases where persons were exposed to HCB
        through oral ingestion, over long periods, the health effects
        observed included cases of permanent focal alopecia, corneal
        opacity, atrophic hands, and hypertrichosis with dermal
        lesians.  Recovery usually followed termination of exposure,
        but relapses were known to occur (Gosselin et al., 1977).

     •  As indicated in Section 8.3.1.4, vinyl chloride monomer (VCM)
        is retained in sludges produced during polyvinyl chloride
        (PVC) processing.  Landfilling of such sludges has resulted
        in release of the VCM.  In 1974 the deaths of four workers in
        the polyvinyl chloride processing industry were believed to
        be attributable to VCM exposure.  Since that time, angiosar-
        coma of the liver, a rare and fatal tumor, has been identi-
        fied in at least 15 workers in U.S. PVC facilities.  In
        addition, other forms of cancer, certain nonmalignant liver
        diseases, and acroosteolysis, a unique occupational disease,
        have also been found in such workers (Office of Solid Waste,
        Hazardous Waste Management Division, 1978b).

     •  In 1972 in Perham, Minnesota, 11 out of 13 persons using
        a well that had been dug on a construction site exhibited
        symptoms of arsenic poisoning.  Five of the employees became
        ill with gastrointestinal symptoms and others exhibited
        symptoms of nausea, vomiting, abdominal pain, and diarrhea.
        Two persons required hospitalization and treatment, including
        one victim who lost the use of his legs for about six months
        due to severe neuropathy.  After analysis, it was discovered
        that the affected well contained arsenic concentrations of up
        to 21 ppm.  The drinking water standard for arsenic is 0.05
        ppm.  Human deaths have been reported in South Africa due to
        water containing 12 ppm arsenic.  The source of the contami-
        nation was traced back to the mid-1930's when about 50 pounds
        of excess grasshopper bait containing arsenic trioxide was
        buried by farmers in the area (see Section 8.3.1.5) (State of
        Minnesota, 1977).

     Due to the small amount of wastes involved in this latter

incident and the fact that the wastes were generated by farmers, this

waste would not be controlled under the baseline regulations.  It

should be noted that nature and persistence of arsenic is a health

                                 8-47

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hazard in even small quantities.  Other wastes that could constitute




a public health hazard in small quantities would also be brought




under regulation by this alternative.




     8.3.2  Secondary Impacts.  The major changes in secondary im-




pacts (relative to the baseline regulations) that could occur as a




result of implementation of this alternative are discussed in the




following sections.  These changes would result primarily from the




control annually by 1984 of an additional 25 million metric tons of




potentially hazardous industrial wastes plus other hazardous wastes;




the enactment of more stringent environmental requirements with




regard to storage, treatment, and disposal of hazardous wastes; and




further increases in hazardous waste storage, treatment, and disposal




costs.




     8.3.2.1  Physiography and Soil Impacts.  The major change in




impacts to physiography and soils under this alternative would result



from bringing an additional 25 million metric tons of potentially




hazardous manufacturing wastes under regulation annually by 1984;



from the elimination of exclusions for other hazardous waste genera-




tors (e.g., farmers and retailers); and from the enactment of more




stringent regulations for the storage, treatment, and disposal of




'special wastes' (e.g., utility wastes).




     All such wastes would have to be stored, treated, and disposed




in accordance with the Section 3004 regulations.  To the extent that




these wastes would otherwise have been stored, treated, or disposed
                                    8-48

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by methods which would not be acceptable under the Section 3004




regulations, the potential for soil contamination would be reduced as




described in Section 7.2.1.




      Disposal of the large volumes of 'special wastes' that could be




brought under control by this alternative could create a significant




demand for low permeability clays.  Such a demand could be especially




significant in areas having a high density of such hazardous waste



generators, such as west-central Florida which produces over 200 mil-




lion metric tons of phosphate rock overburden and gypsum slimes from




phosphoric acid production (see Section 6.1.2).  Local clay supplies




in such areas may not be sufficient to meet the demand.  Even where




sufficient clays are available, their extraction would result in




severe alternation of local topography.




     Increases in the quantity of hazardous wastes being transported




subject to the Subtitle C regulations would reduce the potential for




midnight dumping and spills and for resultant impacts to soils.  How-




ever, increases in the average distance over which wastes are trans-




ported would increase the potential for vehicular accidents and could




off-set some of the potential for a reduction in spills.  Increased




transport would also result in increased vehicular emissions and in




an increased potential for oil, grease, and the hydrocarbons and




heavy metals contained in such emissions to be carried onto soils by




run-off.




     An example of a soil contamination incident associated with




improper transportation and disposal of a waste that would likely be •



                                 8-49

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regulated under this alternative, but not under the baseline regula-




tions, occurred in Louisiana in 1972.  This incident, which resulted




in contamination of soil, area residents, vegetation, and beef cattle




in a 200 square-mile area, is discussed in Section 8.J.I.4.




     To the extent that additional storage, treatment, or disposal




facilities would have to be constructed to handle the potential




increase in the shortfall of capacity (See Section 8.3.2.4), there




would be a potential for further impacts to soils and physiography.




Additional land and soils could also be disturbed by conjunctive




developments such as construction of roads, power lines, pipelines,




and housing.  However, all these additional land requirements would




be offset to the extent that land would also be required for the




storage, treatment, and disposal of these additional wastes under




current practices.  Potential impacts to soils and physiography from




construction would be essentially the same as those described in




Section 7.2.1.




     8.3.2.2.  Biological Impacts.  Existing vegetation would be




destroyed on the additional lands disturbed by construction and




operation of hazardous waste management facilities and conjunctive




developments.  Present plant succession would cease on such lands.




Following rehabilitation of the site after closure of the facility,




the plant community on the disturbed areas would likely differ in




species composition and diversity.




     These construction and operational activities could also result




in the direct destruction of animal habitat.  Some of this



                               8-50

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destruction would be permanent; other areas would be impacted only




temporarily and would, over a period of time, recover in value as a




habitat.  However, the habitat and, consequently, the wildlife




species composition following such recovery might be different from



that which existed prior to disturbance of the area.  In addition,




the direct destruction of some wildlife could also result from




activities which excavate, bury, overturn, clear, or grade large



areas of previously undisturbed terrestrial habitat.  While direct




mortality would be rare to big game and other animals which have the




ability to flee, many small animals with limited ranges may be killed




by construction and operation activities.  Operations which cause




additional dewatering of aquatic habitats would result in the death




of fishes, aquatic invertebrates, and amphibians in certain life




stages.  Furthermore, any increase in transport distances would




increase the potential for road kills and, possibly, spills that




could disrupt aquatic ecosystems.




     These potential adverse impacts from land disturbance would,




however, be offset by several potentially beneficial effects of the




regulations under this alternative.  An additional 25 million metric




tons per year of potentially hazardous industrial wastes (plus other




hazardous wastes) would be brought under regulatory control annually




by 1984.  Based on current practices, a large portion of these wastes




would have been stored, transported, treated, dumped, or disposed in
                                 8-51

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a manner that would not be environmentally acceptable under this

alternative and would have had the potential to create the types of

impacts dicussed in Section 7.2.2.  By bringing these additional

wastes under control of the program, the potential for such impacts

would be greatly reduced.  It should be noted, however, that in

bringing these wastes under regulation, there could be shifts in the

methods used to treat/dispose the wastes as described in Section

8.3.1.4.  The potential for beneficial impacts to the biological

environment would be modified to the extent of any such shift.

     The following example illustrates an incident that occurred from

the disposal of a hazardous waste that might not be controlled under

the baseline regulations but which would likely be controlled under

this alternative:

     o  Waste oil containing dioxin was sprayed in horse arenas and
        on an adjacent road in "Missouri for dust control.  This
        resulted in the death of six dogs, 12 cats, at least 63
        horses, and a large number of birds, rodents, and other
        animals, there were also 26 abortions and six birth
        abnormalities among horses from this incident (Office of
        Solid Waste Management Programs, 1975b).

     For both the additional wastes to be regulated under this

alternative and for those wastes that would already be regulated

under the baseline regulations, the potential for water quality

impacts, and subsequent adverse impacts to both aquatic ecosystems

and wildlife using contaminated water supplies, would be further re-

duced by the requirements for the use of less permeable liners for
                                 8-52

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landfills and surface impoundments.  The potential for air quality




impacts, and subsequent adverse biological impacts, would be further




reduced as discussed in Section 8.3.1.4.  Furthermore, the potential




for soil contaminant, and subsequent adverse impacts to biological




productivity, would be further decreased as discussed in Section




8.3.2.1.




     The requirement for the preparation of a Supplementary Environ-




mental Analysis (SEA) as part of the permit process would provide an




additional means for mitigating or preventing adverse impacts to the




biological environment.  The SEA would require that the permit appli-




cant analyze the impact of and methods proposed to comply with the




following federal statutes and regulations:  the Endangered Species




Act, the Fish and Wildlife Coordination Act, and the Coastal Zone




Management Act.



     8.3.2.3  Social Impacts.




     Demographic Impacts.  Additional industrial plant closings




or relocations due to the increased costs under this alternative




could lead to additional populations shifts as described in Sec-




tion 7.2.3.1.  In addition, there would be an increased need for




construction workers due to the increased facility modification and




construction under this alternative; there would be an increase in




the number of personnel required for hazardous wastes management




activities due to the additional operational requirements and the
                                 8-53

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increase in wastes being regulated; and there would be an increase




in the number of personnel required to administer and enforce the




regulations due to the increase in both the quantity of hazardous




wastes and the number of generators, disposers, and permittees being




regulated.  Additional population shifts could occur in response to




these increased personnel requirements as discussed in Section




7.2.3.1.  Any such shifts would be expected to be small on a national




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




large influx of workers, particularly for hazardous waste management




facilities located near very small towns, or there could be localized




instances of a relatively large outflux of workers, especially in




a case where a plant being closed constituted the primary source of




employment in an area.




     Based upon a minimum requirement of 500 workers to handle




(store, treat, or dispose) a million metric tons of waste per year,




it is estimated that at least 32,500 such workers could be required




nationally by 1984; this would represent over a 60 percent increase




in this requirement compared to the baseline regulations.  Approxi-




mately 4,200 to 8,100 of these workers could be required at off-




site facilities; about 24,400 to 28,300 of these workers could be re-




quired at on-site facilities.  This would represent over a 60 percent




increase at both types of facilities.  To the extent that personnel




would still be required to manage these additional wastes even if




not regulated, there would be fewer new workers required nationally.
                                 8-54

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     Social Conditions.  The increased public health benefits to be




derived from this alternative would provide increased social benefits




as discussed in Section 7.2.3.2.  Reductions in chronic and acute




health effects would also reduce the social and economic costs asso-




ciated with such effects, e.g., increased mortality, birth defects,




lowered productivity, lost wages.




     The increased potential for population shifts under this alter-



native would increase the impacts associated with such shifts.  As




discussed in Section 7.2.3.2, any large, rapid, population influx




could cause inflation, strains on the existing infrastructure, social




tensions, changes in daily living patterns, and increased physical




and mental disorders.  Any large, rapid, population out flux could




cause problems in maintaining the existing infrastructure, deflation,




additional unemployment, social stress, changes in daily living pat-




terns, and increased mental and physical health problems.




     Public opposition to the siting and construction of hazardous




waste management facilities could be further exacerbated by the




increased requirements for such facilities under this alternative.




However, this opposition could be mitigated by the more stringent




environmental requirements under this alternative and by the




requirements for the preparation of a Supplementary Environmental




Analysis as part of the permit review process and for permits to be



renewed every 5 years rather than not at all.
                                8-55

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     Increases in Che necessary construction of hazardous waste




management facilities and in the off-site transport of hazardous




wastes could cause several adverse social effects.  Aesthetic im-




pacts would occur from the construction of new facilities.  Noise




levels would increase both in the vicinity of new facilities and




along access routes to such facilities.  Any increased transport




of hazardous wastes would also increase the potential for vehicular




accidents.  Based upon the methodology and assumptions discussed



in Section 7.2.3.2, it is estimated that there could be about 170




additional vehicular accidents annually in 1984 in the case of 13




percent off-site shipment and about 540 additional vehicular acci-




dents annually in the case of 25 percent off-site shipment.  This




would represent about a 63 percent increase in vehicular accidents




in both cases compared to the baseline regulations.  The requirement



for the preparation of a Supplementary Environmental Analysis as part




of the permit process would provide an additional means under this




alternative for mitigating the above types of adverse impacts.  The




Supplementary Environmental Analysis would require that the permit




applicant describe such factors as proposed access routes; the




promixity of the proposed site to populations centers; and the




methods to be used to minimize noise, dust, and odors associated with




the construction and operation of the proposed facility.




     The requirement that inactive sites be required to comply with




the Section 3004 requirements would cause adverse social and economic
                                8-56

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impacts.  People who own property that contains an inactive hazard-

ous waste disposal site could be required to comply with the Section

3004 regulations even if they brought the property after all disposal

activities had ceased at the site and were unaware of such former

activities.  The need to comply with the Subtitle C regulations in

such cases would undoubtedly be tested in the courts.

     8.3.2.4  Hazardous Waste Management Facility Capacity.

     Process Capacity.  Based upon the methodology and assumptions

described in Section 7.2.4.1, it is estimated that about 8.6 million

metric tons of hazardous industrial wastes could be shipped off-site

for treatment/disposal in 1980 and that between 8.5 and 16.3 million

metric tons could be shipped off-site in 1984.  This would represent

an increase of approximately 3.3 million metric tons of regulated

industrial wastes required to be sent to permitted off-site facili-

ties in 1980 and an increase of between 3.3 and 6.3 million metric

tons of regulated industrial wastes required to be sent to permitted

off-site facilities in 1984.

     Based upon the estimate 6.2 million metric tons of environmen-

tally adequate off-site capacity that could be utilized on a nation-

wide basis in 1980, there could potentially be a nationwide shortfall

of 2.7 million metric tons of off-site capacity for hazardous indus-

trial wastes in 1980.*  Without any growth in environmentally
 All estimates of shortfall are based upon a 90 percent utilization
 rate for the additional capacity required.  The indicated shortfall
 is thus the difference between the quantity of wastes requiring
 treatment disposal and the utilizable capacity, all divided by 0.9.

                                8-57

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adequate off-site capacity between 1977 and 1980, this nationwide




shortfall could be 4.2 million metric tons. It is estimated in




Section 7.2.4.1 that under the baseline regulations there could be




sufficient off-site capacity on a nationwide basis for hazardous




industrial wastes.  Based upon a utilizable facility capacity of




60,000 metric tons per year, approximately 45 additional permitted




off-site facilities could be required for hazardous industrial wastes




in 1980 in the former case and approximately 70 additional permitted




off-site facilities could be required in the latter case.




     Based upon the estimated 7.7 million metric tons of environmen-




tally adequate off-site capacity that could be utilized on a nation-




wide basis in 1984, in the case of 13 percent off-site shipment there




could potentially be a shortfall of 0.9 million metric tons of envi-




ronmental adequate off-site capacity for hazardous industrial wastes




in 1984.  Without any growth in environmentally adequate off-site




capacity between 1977 and 1984, this shortfall could be 3.2 million




metric tons.  It is estimated in Section 7.2.4.1 that there could be




sufficient off-site capacity on a nationwide basis for the treatment




disposal of hazardous industrial wastes under the baseline regula-




tions in both instances.  Since less off-site capacity would be




required in 1984 than in 1980 in the case of 13 percent off-site




shipment, no additional permitted off-site facilities would be




required for hazardous industrial wastes in 1984.
                                8-58

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     In the case of 25 percent off-site shipment, there could poten-

tially be a nationwide shortfall of 9.6 million metric tons of envi-

ronmentally adequate off-site capacity for hazardous industrial

wastes in 1984.  Without any growth in environmentally adequate

off-site capacity between 1977 and 1984, this shortfall could be 11.9

million metric tons.  It is estimated in Section 7.2.4.1 that under

the baseline regulations there could be a nationwide shortfall of 2.6

million metric tons in the former case and a nationwide shortfall of

4.9 million metric tons in the latter case.  Approximately 160 addi-

tional permitted off-site facilities could be required to handle

hazardous industrial wastes in 1984 in the former case and approxi-

mately 200 additional permitted off-site facilities in the latter

case.  Based upon the estimated shortfall under the baseline regula-

tions, only 115 of the necessary permitted facilities would be attri-

butable to this alternative in the former case and only 120 would be

attributable to this alternative in the latter case.

     Data are not available to estimate potential shortfalls in envi-

ronmentally adequate on-site process capacity.  Industrial generators

could send 46.7 million metric tons of hazardous wastes to permitted

on-site treatment/disposal facilities in 1980 and between 46.8 and

54.6 million metric tons of hazardous wastes to permitted on-site

facilities in 1984.*  This would represent an increase of
*The remainder of the hazardous waste not sent on-site or off-
 site would be recycled or sent to resource recovery operations, both
 on-site and off-site (see Table 5-10).
                                5-59

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approximately 18.0 million metric tons of regulated industrial wastes




required to be sent to permitted on-site facilities in 1980 and an




increase of between 18.0 and 21.0 million metric tons of regulated




industrial wastes required to be sent to permitted on-site facilities




in 1984.  It should noted that more stringent treatment/disposal




requirements under this alternative would likely result in a decrease




in the existing on-site capacity.  Any such decrease would further




increase any potential for a shortfall in on-site capacity.




     Section 7.2.4.1 discusses other factors that could either lead




to shortfalls or that could exacerbate the size of the estimated




potential shortfall in both on-site and off-site process capacity,




especially on a localized basis.  In addition to those factors, the




potentially large quantity of 'special wastes'  that could be hazard-




ous would significantly exacerbate any shortfall.  Also, the more




stingent requirement under this alternative could reduce the number




of sites at which facilities could be located.




     Physical Capacity.  Based upon the methodology and assumptions



discussed in Section 7.2.4.2, relative to the baseline regulations




there could be a further decrease of approximately 1.3 million metric




tons in the total hazardous industrial wastes sent off-site during




the period from 1980 through 1984, assuming 13 percent shipment off-




site in 1984, and there could be a further increase of 6.1 million
                                8-60

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metric Cons in the total hazardous industrial wastes sent off-site

during this period, assuming 25 percent shipment off-site in 1984.*

     Up to 250 to 500 fewer acres could thus be committed to off-

site landfilling of hazardous industrial wastes during this period in

the case of 13 percent off-site shipment and up to 1,200 to 2,400

additional acres could be committed to off-site landfilling of haz-

ardous industrial wastes during this period in the case of 25 percent

off-site shipment.  In the former case, after 1984 there could be 100

to 200 fewer acres required off-site annually compared to total

requirements under the baseline regulations.  In the latter case,

after 1984 there could be 500 to 1,000 additional acres required off-

site annually compared to the total requirements under the baseline

regulations.  In all instances there could be commensurate change in

on-site land requirements.

     For purposes of comparison, based upon an average, secure, com-

mercial landfill size of 270 acres (U.S. Environmental Protection

Agency, Office of Toxic Substances, 1977), these land requirements

would be equivalent to siting one to two fewer off-site secure land-

fills by the end of 1984 in the case of 13 percent off-site shipment.

In this case, the equivalent of less than one fewer off-site secure

landfill could have to be sited annually after 1984 for hazardous
*In this estimate, it is assumed that under the baseline regula-
 tions there would be 15 percent off-site shipment for those
 hazardous wastes that would not be regulated under the baseline
 regulations but which would be regulated under this alternative.
                                8-61

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industrial wastes.  The land requirements would be equivalent to

siting five to nine additional off-site secure landfills by the end

of 1984 in the case of 25 percent off-site shipment.  In this case,

the equivalent of two to four additional off-site landfills could

have to be sited annually after 1984.

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

site, would be required for environmentally adequate hazardous waste

management under this alternative than under the baseline regula-

tions.  This additional land necessary for environmentally adequate

management of hazardous waste would be required both for the con-

struction of the permitted facilities needed for the storage, treat-

ment, and disposal of the additional hazardous wastes regulated under

this alternative and for such conjunctive developments as construc-

tion of roads, power lines, and pipelines.  However, as indicated in

Section 8.3.2.4, in the case of 13 percent off-site shipment there

would be fewer regulated hazardous industrial wastes sent off-site by

1984 under this alternative than there would be total hazardous

wastes sent off-site under the baseline regulations.   Thus, while

more total land would be required under this alternative, in the case

of 13 percent off-site shipment there could be less off-site land use

and more on-site land use for hazardous industrial wastes.  In the
*The total hazardous wastes consist of those wastes regulated under
 the baseline regulations plus the additional wastes that would not
 be regulated under the baseline regulations but which would be re-
 gulated under this alternative.
                                 8-62

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case of 25 percent off-site shipment, there would be more regulated




industrial wastes sent off-site by 1984 under this alternative than




there would be total hazardous wastes sent off-site under the




baseline regulations.  Thus, there could be more off-site land use




and less on-site land use for hazardous industrial wastes in this




case.  Estimates of potential changes in off-site land requirements




for landfills (and commensurate changes in on-site land requirements)




are presented in Section 8.3.2.4.




     In should be noted that while shifts to on-site land use could




reduce off-site land requirements in the short term, such shifts




could also accelerate the exhaustion of the relatively limited on-




site physical capacity and could result in increased pressures for




off-site facilities in the long term.  However, additional increases




in resource conservation and recovery and in treatment practices




leading to volume reduction (e.g., incineration) under this alterna-




tive would also provide a greater potential for reducing total land




requirements, both on-site and off-site, in the long term.




     Existing land uses would cease, either permanently or temporar-




ily, on all land converted to hazardous waste management uses.  Some




agricultural, grazing, forest, recreational, and other lands could be




removed from their existing uses.  Following closure of the hazardous




waste management facility and any rehabilitation of the site accord-



ing to the closure and post-closure care plans, the land would be




available for new or, in some cases, previously existing uses.  Sites
                                 8-63

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at which hazardous wastes have been disposed would be precluded fol-




lowing post-closure care from certain future uses (such as residen-




tial, recreational and grazing uses, and any activities requiring




excavation).  To the extent that the regulations under this alterna-




tive would prevent other lands from being contaminated by improper




dumping, treatment, or disposal of the hazardous wastes not regulated




under the baseline regulations, there would be off-setting land use




benefits.  Section 7.2.5 describes the types of land use benefits




that could occur.




     8.3.2.6  Water Use Impacts.  As previously discussed, the poten-




tial for the degradation of groundwater and surface water would be




further reduced under this alternative.  To the extent that degrada-




tion of water quality would have resulted in a decreased supply of




surface water or groundwater being available to some or all consumers




in the water use area, there would be an additional supply of ground-




water or surface water potentially available to such consumers and




fewer restrictions on the productive use of such surface water and




groundwater supplies.




     The additional on-site and off-site permitted hazardous waste




management facilities that could be required would be additional con-




sumers of the available water supply.  This water could be required




for such purposes as dust control, soil compaction, biological treat-




ment, wet scrubbers for incinerators, and site rehabilitation.  This




additional water requirement would be reduced to the extent that






                                8-64

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water would otherwise have been consumed in the management of the




additional wastes now regulated under this alternative.




     8.3.2.7  Resource Conservation and Recovery.  The major changes




in resource conservation and recovery would result from bringing an




additional 25 million metric tons of hazardous manufacturing wastes




under the Subtitle C regulations annually by 1984 and from further




increases in costs to hazardous waste generators and costs associated



with hazardous waste transportation, storage, treatment, and disposal




due to the more stringent requirements under this alternative.  As




discussed in Section 7.2.7, these changes would provide increased




incentives for generators to modify processes so as to enable in-




creased recycling of hazardous waste as process feedstocks, to reduce




the quantities of hazardous wastes generated by specific processes,




or to change the nature of wastes produced.  In addition the require-




ment that the permitting authority could require that wastes which




could be recoverable in the foreseeable future would have to be land




disposed in a segregated manner would increase the potential for




future resource recovery from such wastes.  Chapter 5 presents




examples of the potential for increased resource recovery from and




recycling of hazardous wastes.



     8.3.2.8  Energy Use.  Energy use would be impacted under this




alternative by changes in facility construction, facility operation,




hazardous waste transport, and resource conservation and recovery.




The additional facility modification and construction that would be
                                8-65

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necessary under this alternative would result in increased energy




use.  The requirement for decreased permeability of landfill and




surface impoundment liners and for reduced non-point source air




emissions from these facilities would increase the energy use




required for construction of such facilities.




     There would also be increased energy use associated with re-




quired changes in facility operation and closure.  Management of the




additional 25 million metric tons of hazardous industrial wastes re-




gulated annually by this alternative would require increased energy



use as discussed in Section 7.2.8.  The additional 20-year period




over which post-closure care could be required would increase the




energy use associated with such care.  Additional energy could also



be required for control equipment used to insure that the non-point




source air emission standard was not violated.




     Previously discussed changes in resource recovery would lead to




other changes in energy use.  While any increase in resource recovery




would likely require the initial input of additional energy, there




could be a net savings in energy from recovery operations as dis-



cussed in Section 7.2.8.




     The changes in energy use from the additional transport of haz-




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




of wastes managed on-site and off-site and changes in transport dis-




tances.  Based upon the methodology and assumptions described in




Section 7.2.8, Table 8-6 contains estimates of the magnitude of the
                                 8-66

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                                         TABLE 8-6

                ESTIMATED CHANGE IN FUEL CONSUMPTION  IN 1984 FROM TRANSPORT OF
                ADDITIONAL HAZARDOUS INDUSTRIAL WASTES UNDER SUBTITLE C^REGULATIONS

Average
Wastes round-trip
transported distance
off-site (miles)
13 percent 100
oo 200
CT>
•" 500
1,000
25 percent 100
200
500
1,000
Change in fuel consumption
(million gallons)
-0.5
3
11
26
2
8
23
54
Crude oil
equivalent *
(1,000 barrels)
-10
60
290
660
60
200
580
1,400

*Assumes 9.5 percent efficiency in producing diesel fuel from crude oil.

-------
potential change in energy use (compared to that under the baseline
regulations) that could occur annually from changes in transport dis-
tances and shifts in off-site and on-site treatment disposal.  The
estimated change in energy use under this alternative ranges from an
annual decrease equivalent to approximately 10,000 barrels of crude
oil for a 100 mile round-trip distance with 13 percent off-site
treatment/disposal to an annual increase equivalent to approximately
1.4 million barrels of crude oil for a 1,000-mile round-trip distance
with 25 percent off-site treatment/disposal.
     There could also be further reductions in energy production due
to the increased costs associated with the management of wastes from
such activities and due to the elimination of the special regulations
for 'special wastes'; many 'special wastes' are generated by energy
production activities.  There could also be increased changes in
fuels used by facilities, so as to reduce hazardous waste generation.
This could result in increased changes in energy supply/demand rela-
tionships.
     8.3.2.9  Impacts to Special Interest Points.  To the extent that
unregulated treatment/disposal of the additional wastes brought under
control by this alternative would have disturbed, destroyed, or in-
truded upon special interest points, there would be a commensurate
reduction in such adverse effects as discussed in Section 7.2.9.
However, the additional lands, especially off-site lands, that would
be disturbed by the increased requirements for facility construction
and associated conjunctive developments under this alternative would
                                8-68

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increase the potential for the disturbance and/or destruction of such

special interest points as sites of aesthetic, archaeological, his-

torical, paleontogical, or recreational value.

     The requirement for the preparation of a Supplementary Environ-

mental Analysis as part of the permit process would provide an ad-

ditional means for mitigating such adverse impacts.  The SEA would

require the permit applicant to analyze the impact of and methods

proposed to comply within the following Federal statutes and pub-

lished regulations, if applicable:  The Endangered Species Act; The

National Historic Preservation Act; The Historic Sites, Buildings,

and Antiquities Act; The Fish and Wildlife Coordination Act; and The

Coastal Zone Management Act.

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

     This section discusses the potential changes in impacts (rela-

tive to those of the baseline regulations) that could occur as a

result of promulgation of the regulations contained in the Lesser

Degree of Public Health and Environmental Protection Alternative.  To

avoid considerable duplication in the presentation, potential impacts

that would not be changed under this alternative are not repeated.

Only major changes in potential impacts are discussed.

     8.4.1  Primary Impacts.  The major changes to primary impacts

that could occur as a result of implementation of this alternative

are discussed in the following sections:
                                8-69

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     •  Hazardous Wastes to be Regulated;

     •  Changes to Generation, Transportation, Storage,
        Treatment, and Disposal Practices and Procedures;

     •  Administrative Changes;

     •  Air Impacts;

     •  Water Impacts;

     •  Public Health Impacts.

     8.4.1.1  Hazardous Waste to be Regulated.  Under this alterna-

tive, the toxicity characteristic and wastes whose listing is based

solely on toxicity or Administrator's judgment (AD) would be removed

from the Section 3001 regulations identifying hazardous wastes, and

'special wastes' (e.g., utility wastes and oil drilling muds and

brines) would be specifically excluded from regulation.  Addition-

ally, this alternative would increase the generator limit from 100

kilograms per month to 1,000 kilograms per month.  EPA staff esti-

mates are that eliminating the toxicity criteria and the wastes whose

listing is based upon toxicity would result in the exclusion of about

40 percent of those manufacturing wastes that would be regulated

under the baseline regulations.  Further, the 'special wastes' and

some portion of the other large volume wastes discussed in Section

6.1.2 (e.g., utility fly ash and toxic dredge materials) which may

have been identified as hazardous under the baseline regulations,

would be excluded, either directly (e.g., fly ash) or through

elimination of the toxicity criteria (e.g., dredge materials).
                                8-70

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     Based upon Che procedures described in Chapter 6 and 7 and Ap-




pendices H and I, it is estimated that approximately 20 and 24 mil-




lion metric tons of hazardous manufacturing wastes could be control-




led under this alternative in 1980 and 1984, respectively.  These es-




timates include an adjustment for wastes that would not be regulated




due to the change in the generator limit.  Table 8-7 shows the es-




timated quantity of hazardous manufacturing wastes and the number of




generating establishments that could be excluded from regulation




based upon a generator limit of 1,000 kilograms per month (due to the




reduction in wastes considered hazardous under this alternative, some




of these generators would also be excluded even without the increase




in the generator limit).  In addition, an unknown portion of the




potentially hazardous non-manufacturing wastes discussed in Section




7.1.1 would also be excluded from regulation.




     There could thus be a decrease of at least 14 and 16 million




metric tons in potentially hazardous wastes brought under regulatory




control in 1980 and 1984, respectively, as compared to the baseline




regulations.  This would represent approximately a 40 percent de-




crease in regulated hazardous industrial wastes in both years.  The




hazardous wastes controlled under this alternative would represent




about 6 and 7 percent, respectively, of the total annual industrial




solid waste stream (hazardous and non-hazardous) currently estimated




to be generated.
                                8-71

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                        TABLE 8-7

ESTIMATED QUANTITY OF HAZARDOUS MANUFACTURING WASTES AND
 NUMBER OF ESTABLISHMENTS EXCLUDED FROM REGULATION AT A
    GENERATOR LIMIT OF 1,000  KILOGRAMS PER MONTH

EPA
Region
I
II
III
« IV
to
V
VI
VII
VIII
IX
X
National
total
Number of
manufacturing
establishments
excluded
13,300
34,200
16 , 100
28 ,300
35,500
14,800
8,300
4,400
23,900
8,000

186,500
Percent of
total manufacturing
establishments
excluded
57
65
57
62
52
61
58
68
63
70

60
Hazardous
manufacturing
wastes excluded
(1000 metric
tons/year)
28
68
32
50
70
29
17
10
50
17

371
Percent of total
hazardous
manufacturing
wastes excluded
1
1
<1
<1
<1
<1
<1
2
2
2

<1

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     8.4.1.2  Changes to Generation, Transport, Storage, Treatment,




and Disposal Practices.  Fewer changes to generation, transport,




storage, treatment, and disposal practices would be likely to occur




under this alternative due to the lesser amount of wastes being re-




gulated; due to the enactment of less stringent environmental re-




quirements; due to resultant reductions in storage, treatment, and




disposal costs; and due to the imposition of fewer procedural and




operational requirements.




     Generation.  Under this alternative, fewer generators would be




required to comply with the generator regulations.  Those generators




specifically excluded from regulation under this alternative include:




those who generate between 100 and 1,000 kilogram per month of any




identified hazardous wastes; those who store hazardous wastes on-site




for 90 days to 1 year prior to off-site disposal; those who generate




only 'special wastes'; and those who generate only wastes identified




as toxic under the baseline characteristics and listings.  Section




8.4.1.3 presents estimates of the number of generators to be excluded




from regulation.  These generators would not be required to change




their existing practices and procedures (as indicated in Section




7.1.4.1) with regard to manifesting, reporting, recordkeeping, con-




tainerization, and labeling.  In addition, those generators who would




still be regulated under this alternative would be subject to reduced




manifesting and reporting requirements, as indicated in Table 4-3.
                                 8-73

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     Furthermore, due to likely reductions under this alternative




both in costs to hazardous waste generators and costs associated with




hazardous waste transport, storage, treatment, and disposal relative




to those of the baseline regulations and in the number of regulated




generators, there would be a lesser incentive for generators to mod-




ify their processes so as to reduce and/or change the types and




amounts of hazardous wastes generated by the process and to enable




the increased recycling of hazardous wastes as process feedstocks.




     Transport.  Due to the lesser quantity of wastes subject to the




generator regulations, fewer transporters would likely have to comply




with the transporter regulations discussed in Section 7.1.2.2.  There




would likely be increased instances of midnight dumping and of spills




from any transport of those additional wastes excluded from regula-




tion.  Elimination of the requirement that generators report on haz-




ardous wastes not received at the designated facility would further




increase the potential for midnight dumping.  Any decreases in the




average distance over which hazardous wastes are transported under




this alternative could lead to a decrease in vehicular accidents.




This would off-set some of the potential for an increase in spills.




     The average distance over which hazardous wastes are transported




would be likely to decrease due to several factors.  The less strin-




gent treatment and disposal requirements under this alternative would




likely increase both, the amount of existing on-site and off-site
                                 8-74

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treatment/disposal capacity Chat could be permitted and the number of




sites acceptable for construction of new facilities.  Any such in-




creases in available facilities and sites would potentially lead to




reduced transport distances.  Furthermore, increases in permittable




on-site treatment/disposal capacity could result in fewer wastes




being sent off-site for treatment/disposal.  Decreases in treatment/




disposal costs could also reduce the distance over which wastes could




be economically transported for resource recovery purposes.  Elimina-




tion of the requirement that consolidated wastes not requiring a man-




ifest must be delivered to a permitted facility would likely de-




crease the average distance such wastes would be transported.  How-




ever, any reduction in on-site resource conservation and recovery, as




described above, could tend to increase the quantity of wastes being




sent off-site.




     The replacement of the baseline Section 3002 manifest require-




ments with a new manifest requirement that all shipments (inter-




state and intrastate) must be accompanied by shipping paper/bill of




lading which designates delivery to a permitted storage, treatment,




or disposal facility and which meets the requirements of the DOT




Hazardous Materials Regulations would further reduce changes to ex-




isting transport practices.  The use of such delivery documents is




now required under Interstate Commerce Commission (ICC) regulations




for transporters engaged in interstate commerce and under DOT regu-




lations for the interstate transport of hazardous materials; as






                                8-75

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previously indicated, some states have also applied the DOT regu-




lations to intrastate shipments of hazardous materials.  Thus, ex-




cept for the requirements that the shipping paper/bill of lading must




designate delivery to a permitted facility, those transporters now




required to prepare shipping papers/bills of lading would not have to




modify their existing practices.  However, those transporters who




make intrastate shipments or who do not transport hazardous wastes




that are also identified as DOT hazardous materials would still have




to modify their practices.  Similarly, the reduction in required re-




cordkeeping times would not likely affect those transporters current-




ly required to prepare shipping papers/ bills of lading since, as




indicated in Appendix E, most such transporters keep such records for




at least 3 years due to various existing requirements.




     The elimination of the emergency spill requirements for notifi-



cation and clean up would also not affect transporters carrying in-




terstate and some intrastate shipments of hazardous wastes that are




also identified as DOT hazardous materials.  Such transporters are



currently required to report and clean up such spills.  Also, any




spill by any transporter that could threaten navigable waters or




which are into or upon navigable waters, adjoining shorelines, or




contiguous zones, or which may affect applicable natural resources




would still have to be reported and cleaned up under Section 311 of




the Federal Water Pollution Control Act.
                                8-76

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     Storage.  Due to the lesser number of generators and reduced




quantities of wastes regulated under this alternative, it is likely




that fewer storage facilities would have to comply with the storage




regulations discussed in Section 7.1.2.3.  In addition, the increase




in the permit exclusion from 90 days to one year for generators who




store wastes on-site prior to off-site disposal would further reduce




the number of generators subject to the storage regulations.



     As a result, fewer storage facilities could be required to be




modified or to be closed.  Existing storages practices would not




have to be changed at facilities excluded from regulation under this




alternative.  In addition, those storage facilities that would still




be regulated under this alternative would be subject to reduced con-




struction, operational, and closure requirements as indicated in




Table 4-3 and would have to make fewer changes to existing practices.



     Treatment/Disposal.  Due to the lesser number of generators and




reduced quantities of wastes regulated under this alternative, it is




likely that fewer treatment/disposal facilities would have to comply




with the treatment/disposal regulations discussed in Section 7.1.2.4.




As a result, fewer facilities would be closed because they could not




comply with the regulations or could not be economically modified.




In addition, regulated facilities would be subject to the less strin-




gent requirements contained in Table 4-3.  As a result, fewer regu-



lated facilities would be required to be modified; for those




facilities requiring modification, the changes would also likely be






                                8-77

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less extensive.  Regulated facilities would also have to make fewer

changes in their existing operation and closure practices.

     Due to these less stringent requirements and the reduced costs

associated with them, and due to fewer wastes and generators being

regulated, there would also be a lesser potential for treatment of

wastes for such purposes as volume reduction, energy recovery, and

resource recovery.  Furthermore, to the extent that fewer existing

on-site facilities were closed and fewer wastes and generators were

regulated, there would be a potential for fewer wastes to be sent

off-site for treatment/disposal.  However, reductions in on-site re-

source conservation and recovery practices, as described above, could

tend to off-set any change in wastes being sent off-site.

     8.4.1.3  Administrative Changes.  Several changes in the admin-

istration of the hazardous waste management program would result from

promulgation of the regulations under this alternative.  These regu-

lations would affect:

     •  State administration of the program;

     •  Overlapping Federal and state programs;

     •  Number of generators required to comply with the regulations;
     •  Number of transporters required to comply with the
        regulations;

     •  Number of storers, treaters, and disposers required
        to obtain permits;

     •  Paperwork requirements.

     State Administration of the Program.  Several factors would

increase the potential for states to apply for full, partial, or


                                8-78

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interim authorization under this alternative.  Elimination of all




restrictions on granting of interim authorization, except the




Memorandum of Understanding, would make every state eligible to be




granted interim authorization.  The elimination of restrictions on




granting full or partial authorization to states with more stringent




standards would also enable additional states, including the six with




importation bans identified in Section 7.1.1.3, to qualify for full




or partial authorization.  In addition, reductions in the quantities




and types of wastes considered hazardous and the raising of the




generator limit would decrease the number of potential generators,




transporters, storers, treaters, and disposers that the state would




have to regulate.  This, plus the reductions in reporting require-




ments, would lead to further reductions for administrative and




manpower requirements for authorized states and could increase the



willingness of states to apply for authorization.




     However, the elimination of the toxicity characteristic could




off-set any potential for increased state authorization.  If enough




states felt that the regulations were inadequate without the in-




clusion of toxic wastes, there could be an overall reduction in




authorized states under this alternative.




     Overlapping Federal and State Programs.  Since Subtitle C




prohibits any state from enacting less stringent regulations than




those in the Federal program, the potential for overlapping Federal




and state programs would be increased under this alternative.  The
                                8-79

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less stringent standards and reduced amount of hazardous waste con-




trolled under this alternative would increase the potential benefits




to, and thus the likelihood of, a state enacting a more stringent,




independent, hazardous waste program.  It is not possible at this




time to estimate the number of states, if any, that would wish to




have independent programs in addition to the Federal program under




this alternative.




     Number of Generators Required to Comply With the Regulations.




As indicated in Section 8.4.1.2, there would be a decrease in the




number of generators required to comply with the regulations.  Under




the baseline regulation, 270,000 to 300,000 generators are identified




as potentially having to comply with the regulations (see Section




7.1.3.3).




     The increase in the generator limit could result in approximate-



ly 105,000 additional manufacturing generators being excluded from




compliance with the regulations (see Tables 7-2 and 8-7).  The total




number of manufacturing generators excluded would represent about 60




percent of all manufacturing generators; however, they are estimated




to generate less than 1 percent of the total hazardous manufacturing




wastes.  Some additional manufacturing generators could also be




excluded by the elimination of the toxicity characteristic and




listings, however data are not sufficient to estimate the number of




additional exclusions.  EPA staff estimates are that most, if not




all, of the 50,000 automotive service stations and 5,800 research
                               8-80

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facilities that could be potential generators under the baseline re-




gulations could be excluded by the increased generator limit under




this alternative.  An indeterminable number of other generators could




also be excluded.  Thus, on the order of 110,000 to 140,000 genera-




tors within the categories identified could be required to comply




with the regulations under this alternative.  This would represent




almost a 60 percent reduction in the number of generators being re-




gulated.




     Number of Transporters Required to Comply with the Regulations.




The reduced of regulated hazardous wastes that would potentially be




transported off-site would likely result in a decrease in the number




of transporters carrying hazardous wastes.  However, since the number




of such transporters under the baseline regulations is not known, it




is not possible to estimate the decrease that could occur under this




alternative.



     Number of Storers, Treaters, and Disposers Required to Obtain




Permits.  Since there are no permit exclusions under the baseline re-




gulations for storage, treatment, or disposal facilities that handle




only small quantities of hazardous wastes, all facilities storing,




treating, or disposing hazardous wastes would be required to obtain a




permit under the baseline regulation, with the exception of those




generators who store wastes for less than 90 days prior to off-site




transport.  Thus, with one exception, the only facilities that would




be excluded from the requirements to obtain a permit under this






                               8-81

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alternative would be those facilities that handle only wastes that




would be classified as hazardous under the baseline regulations, but




that would not be classified as hazardous under this alternative.




The exception is that generators who store hazardous wastes between




91 days and one year would also be excluded under this alternative.




Data are not available to estimate the reduction in potential permit-




tees under this alternative.




     Paperwork Requirements.  Based upon the estimated number of off-




site shipments (see Section 8.4.2.4), the industrial generators could




have to prepare between 200,000 and 420,000 shipping papers/bills of




lading annually by 1984.  This would represent about a 40 percent de-




crease in the number prepared under the baseline regulations.  The




aggregated generators, transporters, and hazardous waste management




facility owner/operators could each have to keep a minimum of between




200,000 and 420,000 shipping papers/bills of lading in storage on an




annual basis.  This would represent about an 80 percent decrease in




recordkeeping requirements as compared to the baseline regulations.




This decrease in both the number of new manifests prepared and stored




under this alternative would be even greater to the extent that




generators and transporters were able to use and store shipping




papers/bills of lading that would also have to be prepared and stored




under other existing regulations (see Section 8.4.1.2).




     The 110,000 to 140,000 identified generators would have to pre-




pare 110,000 to 140,000 reports on an annual basis; this would
                                8-82

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represent nearly a 60 percent decrease in such annual reporting.  As




indicated in Section 7.1.3.6, most potential permittees would be on-




site facilities and would not have to prepare additional annual re-




ports based on the manifests.  Transporters would not have to prepare




any spill reports under this alternative as compared to between 140




and 270 under the baseline regulations; however, some transporters




would have to prepare spill reports to satisfy requirements under




other existing laws (see Section 8.4.1.2).  The reduction in the




number of permittees is not determinable, but is expected to be small




as previously indicated.  Due to the relatively small number of off-




site permittees (see Table 7-7) and due to the potentially small de-




crease in such permittees, any reduction in the number of annual re-




ports based upon manifested wastes to be prepared by such permittees




should also be small.  There could, however, be a large decrease in




the number of monitoring reports prepared by permittees under this




alternative.  Permittees would have to prepare such reports annually




rather than quarterly.  There could be up to 117,000 such monitoring




reports under the baseline regulations.  Using the number of poten-




tial permittees from the baseline regulations as an estimate of the




upper limit of the number under this alternative, there could be up




to 29,000 monitoring reports prepared annually under this alternative




— a reduction of at least 75 percent.  Overall there could be a




total of 139,000 to 169,000 generator and permittee reports prepared




annually under this alternative — a reduction of about 60 percent.







                                8-83

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     There would also be a slight decrease in the number of permit




applications prepared.  The identified generators and permittees




could have to file on the order of between 110,000 and 140,000




notifications under Section 3010—a reduction of nearly 60 percent.




The likely reduction in the number of regulated transportees would




also reduce the number of transporters who would be required to file




notifications under Section 3010.




     8.4.1.4  Air Impacts.




     Air Quality.  The regulations under this alternative would have




the potential to cause fewer changes in air emissions resulting from




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




hazardous wastes, as compared to the baseline regulations.




     Generation.  As previously discussed, the baseline regulations




would not have a direct effect on potential air emissions resulting




from activities and processes generating hazardous wastes.  However,




to the extent that the requirements under this alternative would




cause less changes in the economics of storage, treatment, or




disposal relative to those of the baseline regulations, there would




be less of a potential for generators to make process modifications




designed to increase hazardous waste recycling and to reduce the quan-




tity and/or types of hazardous wastes generated; any such reductions




in process modifications under this alternative would likely lead to




fewer changes in air emissions released by processes generating




hazardous waste.  Furthermore, with fewer generators being brought






                                 8-84

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 under  control  of  Che  program,  Che  potential  for such  process  mod-

 ifications  and resultant  changes in  air  emissions  would  be  further

 decreased.

     Transport.   As indicated  in SecCion 7.1.4.1,  Chere  are Chree

 major  ways  air contaminants  are released by  the transport of  hazard-

 ous wastes:

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

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

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

     As discussed below,  this alternative would affect,  to varying

 degrees, the potential  for the release of air emisions from each of

 these  sources.

     By 1984,  approximately  16 million metric tons of potentially

hazardous industrial wastes  (plus other  hazardous wastes) would be

 removed annually  from regulations under  this  alternative as compared

 to the baseline regulations.  As a result, transport of  these wastes

would  not have to be in accordance with  the Section 3002 containeri-

zation requirements or the Section 3003  transport requirements unless

 the wastes were also identified as hazardous materials under  the DOT

Hazardous Materials Transport Act.*  Thus, to the extent that these

wastes would be containerized or transported  using methods not
*In such a case, for all interstate transport and some intrastate
 transport, these wastes would be subject to essentially the same
 containerization and transport requirements as under Che baseline
 regulations.

                               8-85

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acceptable under the baseline regulations, the potential for  the re-




lease of fugitive emissions by such transport and from any resultant




spills or explosions would be increased under this alternative.  Sec-




tion 7.1.4.1 discusses the potential for the release of air emissions




from unregulated transport practices.  Furthermore, the elimination,




except as previously noted, of the requirement that transporters need




to report and clean up spills would further increase the potential




for air contaminants to be released from such spills under this




alternative.  The elimination of spill response information from the




manifest could further increase the time for spill clean up and thus




increase the potential for the release of air contaminants.




     Both the total quantity of regulated hazardous wastes being




transported and the average distance over which such wastes are




transported could decrease under this alternative, as previously




indicated.  Any such reductions would lead to the release of  fewer




vehicular emissions and to a reduced potential for vehicular  acci-



dents to occur and to release air emissions.  However, less transport




of hazardous waste in accordance with the regulations would increase




the potential for spills and explosions from improper transport and




from resultant vehicular accidents.  This would off-set some  of the




potential for fewer vehicular accidents to result from reduced trans-




port distances.  The changes in both the vehicular emissions  and



emissions resulting from accidents would be dependent upon such fac-




tors as the decrease in travel distances, the change in portion of
                                8-86

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hazardous wastes transported off-site, and the decrease in the amount




of regulated wastes being transported.




     Using the methodology and assumptions described in Section




7.1.4.1, the potential change in vehicular air emissions resulting




from the reduced transport of regulated hazardous industrial waste




has been estimated for four possible transport distances for both 13




and 25 percent off-site shipment of hazardous wastes in 1984.  Table




8-8 shows the change in vehicular emissions relative to those of the




baseline regulations (see Table 7-8).  For example, for a 100-mile




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




there could be an increase in each vehicular air emission equal to




about 40 percent of that which could occur under the baseline regu-




lations.  For a 1,000-mile round-trip distance with 25 percent




off-site treatment/disposal, there could be a decrease in each air




emission equal to about 40 percent of that which could occur under




the baseline regulations.  In the former case, the increase in each




air emission would be less than one one-thousandth of a percent of




the total U.S. emission of that air pollutant and less than 0.007




percent of the total U.S. area emission of that pollutant from




heavy-duty, diesel-powered vehicles.  In the latter case, the




decrease in each air emission would be less than 0.03 percent of the




total U.S. emission of that air pollutant and approximately 1 percent




of the total U.S. area emission of that pollutant from heavy-duty,




diesel-powered vehicles.
                                8-87

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                         TABLE 8-8

ESTIMATED CHANGE IN VEHICULAR EMISSIONS IN 1984 FROM TRANSPORT
OF LESS HAZARDOUS INDUSTRIAL WASTES UNDER SUBTITLE C REGULATIONS

Change in emissions (metric cons)
Wastes
transported
off-site
„ 13 percent
A,
oo


25 percent



Average
round-trip
distance
(miles)
100
200
500
1,000
100
200
500
1,000
Carbon monoxide
+ 60
-350
-1,600
-3,600
-310
-1,100
-3,200
-7,400
Hydrocarbons
+10
-55
-250
-580
-50
-180
-510
-1,200
Nitrogen
oxides
+45
-250
-1,200
-2,700
-230
-800
-2,300
-5,400
Particulates
+ 3
-15
-70
-170
-15
-50
-140
-340
Sulfur
oxides
+6
-35
-150
-360
-30
-110
-310
-730

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     Based upon the methodology and assumptions described in Section

7.1.4.1, there could be on the order of 80 to 180 transportation-

related hazardous wastes spills annually by 1984 from the transport

of the regulated wastes.  As previously discussed, it is not possible

to estimate the change in the number of spills that would occur from

the removal of 16 million metric tons of hazardous waste from

regulation by 1984.

     Storage, Treatment, and Disposal.  As discussed in Section

7.1.4.1, there are several major ways that air contaminants can be

released by current hazardous waste storage, treatment, or disposal

practices:

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

     •  Through fugitive emissions from ground-based treatment/
        disposal activities such as landfills, landfarms, and surface
        impoundments;

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

     •  Through emissions generated by spills, fires, explosions, and
        other accidents;

     •  Through the combustion of hazardous wastes by incineration or
        open burning;

     •  Through fugitive emissions from other treatment activities;

     •  Through fugitive emissions from facility construction or
        modification.

This alternative would affect the potential for the release of air

contaminants from each of these sources as discussed below.
                                 8-89

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




ties would have to be modified or would have to be constructed under




this alternative (see Section 8.4.2.4), there would be a decrease in




fugitive dust and vehicular emissions from such construction activi-




ties.  Such emissions would be extremely site dependent.




     By 1984, approximately 16 million metric tons of potentially




hazardous industrial wastes (plus other hazardous wastes) would be




removed annually from regulation under this alternative as compared




to the baseline regulations.  These hazardous wastes would not have




to be stored, treated, or disposed in accordance with the Section




3004 regulations.  Since it is likely that most of these wastes would




not be managed by methods that are environmentally acceptable under




the Section 3004 regulations, the overall potential for the release




of air contaminants from the management of such wastes would be




increased under this alternative relative to the baseline regula-




tions.  Section 7.1.4.1 discusses the potential for the release of




air contaminants from unregulated treatment, storage, and disposal




practices.




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




tially hazardous industrial wastes (plus other hazardous wastes) that




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




less stringent requirements under this alternative would have the




potential for increasing the release of air contaminants from the
                               8-90

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management of these wastes as compared to their management under the




baseline regulations.  For example, many of the incineration require-




ments under the baseline regulations apply only to the incineration




of pesticide wastes or to wastes that are hazardous due to toxicity.




The proposed regulations require that such wastes be incinerated at




1,000 C with greater than 2 seconds retention time and greater than 2




percent excess oxygen and that the incineration achieve 99.99 percent




destruction of the principal toxic components of the wastes.  Elimi-




nation of the toxicity characteristic under this alternative would




remove the incineration of almost all regulated wastes from compli-




ance with the above requirement.




     Only pesticide wastes that are hazardous due to a characteristic




other than toxicity would still have to be incinerated under the




above operating conditions.  The incineration would, however, have to




achieve a 99.9 percent destruction efficiency of the principal com-




ponents of the pesticide waste rather than a 99.99 percent destruc-




tion efficiency; thus, there could be up to a 900 percent increase in



the release of the principal components from the incineration of such




pesticide wastes (however, as indicated in Appendix M, incineration




under the conditions specified above can result in better than 99.99




percent destruction of the principal components of many pesticides).




Incineration of other wastes regulated under this alternative that




would have been identified as toxic under the baseline regulations
                               8-91

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(e.g., slop oil emission solids from petroleum refining — see Table




D-7) would also be removed from complying with the incineration




requirements noted above.  Thus, under this alternative there would




be a much greater potential for incineration of these wastes to




release hazardous air contaminants.




     Furthermore, the incineration of all regulated wastes would be




subject to less stringent requirements for combustion efficiencies




and for halogen removal under this alternative.  Required combustion




efficiencies would be reduced from 99.9 percent to 99 percent;




required halogen removal efficiencies would be reduced from 99




percent to 90 percent.  Thus, there could be up to a 900 percent




increase in the release of halogens and carbon monoxide under this




alternative.  In addition, the reduced combustion efficiencies could




also result in the less complete destruction both of other combustion




products and of hazardous waste constituents with a resultant in-




crease in their release to the atmosphere.  Thus, incineration under




this alternative would likely lead to locally higher ambient air




concentrations of many of the hazardous air contaminants generated by




the incineration.  However, all emissions and resultant changes in




air quality would have to be in compliance with all applicable




requirements (e.g., Clean Air Act standards and state standards).



     Other changes that would potentially increase the release of air




contaminants from wastes regulated under this alternative include the




removal of the prohibition against placing volatile wastes in
                                8-92

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landfills, landfarms, surface impoundments, or storage tanks vented
directly to the atmosphere (see Section 7.1.4.1 for examples of
volatile hazardous wastes).  To the extent that regulated volatile
wastes would be stored, treated, or disposed by such methods under
this alternative, there would be an increased release of air contami-
nants as described in Section 7.1.4.1.  The application of the Thres-
hold Limit Values (TLV's) as a time-weighted average for a 24-hour
day rather than as a time-weighted average for an 8-hour day and a
40-hour week would allow increased emissions from such non-point
sources as landfills, landfarms, surface impoundments, and storage
areas.  The reduction in the minimum distance that active portions of
facilities must be located from the facility boundary, coupled with
the above changes, would likely lead to increased ambient air
concentrations of hazardous emissions beyond the facility boundary.
Increases in the time interval for completing required training would
also increase the potential for personnel to improperly manage
hazardous wastes so as to cause fires, explosions, or other accidents
that could release air contaminants.
     It should be noted, however, that there would likely be some
shift in the types of methods used to store, treat, or dispose both
the regulated wastes and the wastes excluded from regulation under
this alternative compared to the methods that would have been used to
manage these wastes under the baseline regulations.  For example, the
elimination of restrictions on the management of volatile wastes
could reduce the incineration of such wastes and increase their
                                8-93

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landfilling, relative to the baseline regulations.  Such shifts would




change both the types and quantities of air emissions produced by the




management of specific wastes.  For example, a shift from incinera-




tion to landfilling of a particular waste would potentially result in




a decrease in the release of combustion products and an increase in




the release of particulate matter and/or gases contained in the




waste.  Such shifts could either enhance or reduce the potential for




this alternative to cause increases in the release of specific air




emissions in any given locality.  All emissions and any localized




degradation of air quality would have to be in compliance with all




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



standards, state standards).




     Climate.  Fewer hazardous waste management facilities would




potentially have to be constructed under this alternative than under




the baseline regulations.  Thus, there would be fewer localized




impacts to temperatures, humidities, and low-level wind patterns from




such construction.



     8.4.1.5  Water Quality Impacts.  While the regulations under




this alternative would reduce the potential for adverse impacts to




water quality resulting from generation, storage, transport, treat-




ment and disposal of hazardous wastes, the potential reduction in




impacts would be significantly less than the potential reduction




which would result from implementation of the baseline regulations.
                                 8-94

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     Many of the potential changes to groundwater and surface water

impacts under this alternative would occur in much the same manner as

the potential changes discussed under air quality.  To avoid redun-

dant discussions, such changes are briefly summarized below rather

than discussed in detail.  Following this summary, additional major

changes are described.

     Since generators would be less likely to make process modifi-

cations designed to increase recycling or to reduce the quantity

and/or types of hazardous wastes generated, this would lead to fewer

changes in water effluents produced by such processes and thus to

fewer changes in groundwater and surface water contamination by such

effluents.  With fewer generators being brought under the control of

the program, the potential for such process modifications would be

further decreased.  Furthermore, to the extent that this alternative

would bring less storage by generators under the Section 3004

regulations,* the potential for groundwater and surface water

contamination by spills and runoff from storage of these additional

wastes would be increased.

     Decreases in the quantity of hazardous wastes being transported

subject to the Subtitle C regulations would increase the potential

both for midnight dumping and spills and resultant impacts to

groundwater and surface water quality.  However, decreases in the
^Generators who store hazardous wastes for less than 1 year prior to
 off-site shipment would not be required to obtain a permit under
 this alternative; under the baseline regulations, this permit
 exclusion would be limited to 90 days storage.


                                8-95

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average distance over which wastes are transported would decrease the
potential for vehicular accidents and could at least partially off-
set the potential for an increase in spills.  The elimination, except
as previously noted, of the requirement that transporters need to
report and clean up spills and that manifests need to contain spill
information would further increase the potential for water quality
impacts to result from such spills under this alternative.  Decreased
transport distances would also result in decreased vehicular emis-
sions and in a decreased potential for oil, grease, and the hydrocar-
bons and heavy metals contained in vehicular exhausts to be carried
into waterways by run-off.
     One major change in water quality impacts would result from the
removal of 16 million metric tons of hazardous industrial wastes
(plus other hazardous wastes) from regulation annually by 1984 under
this alternative as compared to the baseline regulations.  These
potentially hazardous wastes would not have to be treated/disposed in
accordance with the Section 3004 regulations, though they could be
subject to applicable regulations under Subtitle D of RCRA and other
State and Federal legislation (e.g., the Clean Water Act and the Safe
Drinking Water Act).  Based on current practices, most of these
wastes would not be stored, treated, or disposed by methods which are
environmentally acceptable under the Section 3004 regulations.  Thus,
the overall potential for groundwater and surface water degradation
would be increased.  Section 7.1.5 describes the potential for
surface water and groundwater impacts from the treatment/disposal of
                                8-96

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such wastes under current practices and requirements.  Many of the
incidents reported in that section involve toxic wastes which would
not be regulated under this alternative.  These include all incidents
exclusively involving pesticides or heavy metals (e.g., the Moscow
Mills, Missouri endrin incident, and the groundwater contamination
incident involving chromium and cadmium from an aircraft plant in
South Farmindale, Long Island).  Similar types of incidents would
also not be prevented by the regulations under this alternative.
     Additional impacts to water quality could also result from the
enactment of less stringent regulations for the treatment/disposal of
the 24 million metric tons of potentially hazardous industrial wastes
(plus other hazardous wastes) that would still be under control of
the program annually.  This alternative decreases the required
minimum distance between the active portions of facilities and water
supplies; allows the use of more permeable soil liners for surface
impoundments and landfills; limits groundwater monitoring require-
ments to facilities which have the potential to discharge to under-
ground drinking water sources; eliminates quarterly groundwater mon-
itoring while retaining the requirement for annual monitoring; and
decreases the time requirement for post close-out care.  To the ex-
tent that more permeable liners would allow more rapid movement of
leachates and that less frequent monitoring would delay detection of
liner failure, there would be an increased potential for degradation
and contamination of groundwater and of surface waters recharged by
the groundwater.  Similarly, the other changes would also increase
                                8-97

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the potential for undetected groundwater and surface water degra-




dation.




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




type of methods used to treat/dispose regulated wastes and wastes re-




moved from regulation under this alternative, compared to methods




used under the baseline regulations.  As previously discussed, such




shifts could result in localized changes in the release of specific




water pollutants under this alternative, compared to the baseline re-




gulations.




     8.4.1.6  Public Health Impacts.  This alternative would have the




potential to reduce the public health benefits that would be derived




from the baseline regulations.  The impacts to public health under




the baseline regulations are discussed in Section 7.1.6.




     Approximately 16 million metric tons of potentially hazardous



industrial wastes would be removed from regulation annually by 1984




under this alternative as compared to the baseline regulations.  This




decrease would primarily be attributable to the large quantity of




toxic substances that would be excluded from regulation.  Based upon




current practices, a large portion of these wastes would potentially




be stored, transported, treated, and disposed in a manner that was




not environmentally acceptable under the regulations.  Also through




the imposition of less stringent standards, there would be a greater




potential for the regulated wastes to release air, water, and soil




contaminants that could cause adverse public health impacts (see
                                8-98

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Sections 8.4.1.4, 8.4.1.5, and 8.4.2.1).  The removal of all toxic

wastes from regulation would result in many wastes that are known or

suspected to be carcinogenic, mutagenic, or teratogenic being ex-

cluded from regulation.  Of particular concern is the possibility for

the occurrence of additional disasters similiar to that of Love Canal

in Niagara, New Falls, New York (see Section 7.1.6).   In that inci-

dent, an undeterminable quantity of toxic chemicals had been im-

properly disposed, homes had been built adjacent to the disposal

site, and numerous public health problems resulted.

     An example of wastes containing potentially toxic substances,

such as cadmium or chromium compounds, that might not be regulated

under this alternative, but that could be controlled under the base-

line regulations is as follows:

     •  An aircraft plant in Nassau County, New York generated and
        disposed large quantities of electroplating wastes containing
        chromium, cadmium, and other metals during World War II.
        An estimated 200,000 to 300,000 gallons per day of these
        wasteswere discharged into unlined disposal pits throughout
        the 1940's.  Groundwater contamination by chromium was first
        noted in 1942 by the Nassau County Department of Health.
        Subsequent studies indicated that a Hugh plume of contami-
        nated groundwater had been formed, extending from the surface
        of the water table to depths of 50 to 70 feet below the sur-
        face.  In 1962, test wells revealed concentrations of hexava-
        lent chromium up to 14 ppra, and concentrations of cadmium up
        to 3.7 ppm. The contaminated plume cannot be removed or de-
        toxified without massive efforts and will take many more
        years of natural attentuation and dilution before it becomes
        usuable again.  Meanwhile, it is still slowly moving,
        threatening a nearby creek and other wells in the area
        (Tinlin, 1976; State of Minnesota, 1977).

     For purposes of comparison with regard to this incident, the

National Interim Primary Drinking Water Standard for chromium is .01


                               8-99

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ppm and .05 ppm for cadmium, respectively.  While the harmful effects




of this incident are believed to be limited to groundwater contamina-




tion, it is important to note that the incident which began in the




1940's continued for over two decades.  Although hexavalent chromium




has been found to be toxic to some aquatic species, information on




its chronic effects to humans is limited almost entirely to data on




occupational health effects.  Lung cancer, ulceration, and perfora-




tion of the nasal septum, and other respiratory complications and




skin effects have been observed (U.S. Environmental Protection




Agency, 1976a).  In 1941, it was reported that a group of 29 school




children experienced violent nausea after eating popsicles containing




13 to 15 ppm of cadmium (U.S. Environmental Protection Agency,




1976a).




      8.4.2  Secondary Impacts.  The major changes in secondary



impacts that could occur as a result of implementation of this




alternative would result primarily from the removal of approximately




16 million metric tons of hazardous industrial wastes (plus other




hazardous wastes) from regulation annually by 1984; the enactment of




less stringent environmental requirements with regard to storage,




treatment, and disposal of hazardous wastes; and potentially lower




increases in storage, treatment, and disposal costs as a result of




these less stringent regulations.




     8.4.2.1  Physiography and Soils Impacts.  The major change in




impacts to physiography and soils would result from the elimination
                                8-100

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of 16 million metric tons per year of hazardous industrial wastes




(plus other hazardous wastes) from regulation.  To the extent that




these wastes would be stored, transported, treated, or disposed by




methods which are not environmentally acceptable under the baseline




regulations, the potential for adverse impacts to soils would be




increased.  Section 7.2.1 describes the types of impacts to soils




that could occur from such methods.  The potential for adverse



impacts to soils would be further increased by allowing longer




storage of wastes by generators without requiring a permit.




     Reductions in the quantity of hazardous wastes being transported




subject to the Subtitle C regulations would increase the potential




both for midnight dumping and spills and for resultant impacts to




soils.  However, decreases in the average distance over which wastes




are transported would decrease the potential for vehicular accidents




and could off-set the potential for an increase in spills.  Reduced




transport would also result in decreased vehicular emissions and in a




decreased potential for oil, grease, and the hydrocarbons and heavy




metals contained in such emissions to be carried onto soils by




run-off.




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



ties would have to be constructed under this alternative due to a




potential reduction in the off-site process capacity shortfall (see




Section 8.4.2.4), there would be a lesser potential for physical
                                8-101

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impacts to soils and physiography.  Allowing the use of more per-




meable soil liners would allow more disposal sites to use natural,




in-place soils, and would therefore reduce the demand for, and




impacts of off-site excavation of clays.  Less land and soil would




also be disturbed by facility construction and by conjunctive devel-




opments such as construction of roads, power lines, pipelines, and




housing.  However, these reduced land requirements would be off-set




to the extent that land would still be required for the storage,




treatment, and disposal of the wastes excluded from regulation under



this alternative.  Potential impacts to soils and physiography from




construction would be essentially the same as those described in




Section 7.2.1.




     8.4.2.2  Biological Impacts.  Land requirements for facility




construction and operation and for conjunctive developments would be




reduced under this alternative.  As a result, the potential for



adverse impacts to flora, fauna, and ecological systems from land dis-




turbance would also be reduced.  In addition, the reduction in the




transport of hazardous wastes could lead to a reduction in road




kills.




     These potential benefits to the biological environment would,




however, be off-set by several other changes that could occur under



this alternative.  Approximately 16 million metric tons of poten-




tially hazardous industrial wastes (plus other hazardous wastes)
                                8-102

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would be removed annually from regulation.  Based upon current




practices, a large portion of these wastes would potentially be




stored, transported, treated, or disposed in a manner that was not




environmentally acceptable under the baseline regulations.  To the




extent that these wastes were to be handled in such a manner, the




potential for adverse impacts to the biological environment would be




increased.  Section 7.2.2 describes the types of impacts that could




occur from practices not regulated under Subtitle C.




     It should be noted, however, that in removing these wastes from




regulation, there could be shifts in the methods used to treat/dis-




pose these wastes.  This could result in localized changes in the




quantity of specific air, land, and water residuals generated by the




treatment/disposal of these wastes as described in Section 8.3.1.4.




The potential for increased adverse biological impacts from these




residuals would be modified to the extent of any such shifts.




     For those hazardous wastes that would still be controlled under




this alternative, the potential for water quality impacts, and sub-




sequent adverse impacts to aquatic ecosystems and to wildlife using




contaminated water supplies, would be increased by the use of more




permeable liners and by other changes discussed in Section 8.4.1.5.




The potential for air quality impacts, and subsequent adverse eco-




logical impacts, would be increased as discussed in Section 8.4.1.4.




Furthermore, the potential for impacts to soils, and subsequent
                                8-103

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adverse impacts to biological productivity, would be increased as




discussed in Section 8.4.2.1.




     8.4.2.3  Social Impacts.




     Demographic Impacts.  Fewer industrial plant closings or reloca-




tions due to lesser increases in costs under this alternative could




lead to fewer population shifts as described in Section 7.2.3.1.  In




addition, there would be a decrease in the number of construction




workers required due to the lesser amount of facility modification




and construction necessary under this alternative; there would be a




reduction in the number of personnel required for hazardous waste




management activities due to both the less stringent operational




requirements and the decrease in wastes being regulated; and there




would be a decrease in the number of personnel required to administer




and enforce the regulations due to reductions in both the quantity of




hazardous wastes and the number of generators, disposers, and permit-




tees being regulated.  Fewer population shifts could also occur in




response to these reduced personnel requirements as discussed in




Section 7.2.3.1.  Any such shifts would be expected to be small on a




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




relatively large influxes of workers, particularly for hazardous




waste management facilities located near very small towns, or of




relatively large outfluxes of workers, especially in the case where a




plant being closed constituted the primary source of employment in an




area.  Based upon a minimum requirement of 500 workers to handle
                               8-104

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(store, treat, or dispose) a million metric tons of waste per year,




it is estimated that at least 12,000 such workers could be required




nationally by 1984; this would represent about a 40 percent decrease




in this requirement compared to the baseline regulations.  About




1,500 to 3,000 of these workers could be required at off-site facili-




ties; about 9,000 to 10,500 of these workers could be required at




on-site facilities.  This would represent about a 40 percent decrease




at both types of facilities.  To the extent that pesonnel would still




be required to manage the wastes excluded from regulation under this




alternative, there would be a lesser reduction in the number of




workers required nationally.




     Social Conditions.  The lesser public health benefits to be




derived from this alternative relative to the baseline regulations




would provide fewer social benefits as discussed in Section 7.2.3.2.




Fewer reductions in chronic and acute health effects would also




result in an increase in the social and economic costs associated




with such effects, e.g., increased mortality, birth defects, lowered




productivity, lost wages.




     A reduction in population shifts would decrease the potential




for impacts associated with such shifts.  However, as discussed in



Section 7.2.3.2, any large, rapid, population influx could still




cause inflation, strains on the existing infrastructure, social




tensions, changes in daily living patterns, and increased physical




and mental disorders.  Any large rapid, outflux could still cause






                               8-105

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problems in maintaining existing infrastructures, deflation, ad-




ditional unemployment, social stress, changes in daily living pat-




terns, and increased mental and physical health problems.




     Public opposition to the siting and construction of hazardous




waste management facilities could be reduced by the need for fewer




facilities under this alternative.  However, any opposition that oc-




curs could be exacerbated by the less stringent environmental re-




quirements for such facilities under this alternative.




     Decreases in the construction of hazardous waste management




facilities and in the off-site transport of hazardous wastes could




result in several beneficial social effects.  Reductions in facility




construction would eliminate the potential for noise impacts,




aesthetic impacts, land use impacts, water use impacts, and pressures




on existing infrastructures that could be associated with the facil-




ity.  Any decrease in the transport of hazardous wastes would de-




crease the potential for vehicular accidents.  Based upon the




methodology and assumptions discussed in Section 7.2.3.2, it is es-




timated that there could be approximately 110 fewer vehicular ac-




cidents annually in 1984 in the case of 13 percent off-site shipment




and about 340 fewer vehicular accidents in the case of 25 percent




off-site shipment.  This would represent about a 40 percent decrease



in vehicular accidents compared to the baseline regulations.
                               8-106

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     8.4.2.4  Hazardous Waste Management Facility Capacity.




     Process Capacity.  Based upon the methodology and assumptions




described in Section 7.2.4.1, it is estimated that approximately 3.0




million metric tons of regulated hazardous industrial wastes could be




shipped off-site for treatment/disposal in 1980 and that between 3.1




and 6.0 million metric tons could be shipped off-site in 1984.  This




would represent a decrease of 2.3 million metric tons of regulated




industrial wastes required to be sent to permitted off-site




facilities in 1980 and a decrease of between 2.2 and 4.0 million




metric tons of regulated industrial wastes required to be sent to




permitted off-site facilities in 1984.




     Based upon the estimated 6.2 million metric tons of environment-




ally adequate off-site capacity that could be utilized on a nation-




wide basis in 1980, there would potentially be sufficient capacity on




a nationwide basis to handle the estimated 3.0 million metric tons of




regulated hazardous industrial wastes shipped off-site.  Even if




there was no growth in environmentally adequate off-site capacity




between 1977 and 1980, there would still potentially be sufficient




capacity on a nationwide basis in 1980.  Under the baseline regula-




tions there would also potentially be sufficient off-site capacity




available on a nationwide basis in 1980.




     The estimated 7.7 million metric tons of environmentally ade-




quate off-site capacity that could be utilized in 1984 would be




sufficient on a nationwide basis to handle the estimated 3.1 million
                               8-107

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metric tons of regulated hazardous industrial wastes shipped off-site

in the case of 13 percent off-site shipment.  Again there would

potentially be sufficient off-site capacity on a nationwide basis

even if there was no growth in capacity between 1977 and 1984.  Under

the regulations there would also potentially be sufficient off-site

capacity available on a nationwide basis in 1984.

     In the case of 25 percent off-site shipment, sufficient off-site

capacity would also potentially be available on a nationwide basis

for hazardous industrial wastes in 1984.  However, without any growth

in environmentally adequate off-site capacity between 1977 and 1984,

there could potentially be a nationwide shortfall of almost 0.5 mil-

lion metric tons in 1984.*  In this latter case, 1984 could be the

first year of shortfall.  Based upon a utilizable facility capacity

of 60,000 metric tons per year, approximately eight additional off-

site facilities could be required to handle hazardous industrial

waste in 1984 in this latter case.  It is estimated that under the

baseline regulations that there could be a nationwide shortfall of

2.6 million metric tons of capacity in 1984 in the former case and of

4.9 million metric tons in the latter case.  Thus, approximately 45

fewer permitted off-site facilities could be required for hazardous

industrial waste under this alternative in the former case and 72

fewer permitted off-site facilities could be required in the latter

case, as compared to the baseline regulation.
*The actual shortfall would be 0.4 million metric tons; however, with
 a utilization rate of 0.9, approximately 0.5 million metric tons of
 capacity would be required.

                                8-108

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     Data are not available to estimate the potential for shortfalls

in environmentally adequate on-site process capacity.  Industrial

generators could treat/dispose approximately 16.4 million metric tons

of regulated hazardous industrial wastes on-site in 1980 and between

17.3 and 20.2 million metric tons of regulated hazardous industrial

wastes on-site in 1984.*  This would represent a decrease of approxi-

mately 12.3 million metric tons of regulated industrial wastes

required to be sent to permitted on-site facilities in 1980 and a

decrease of between 11.5 and 13.4 million metric tons of regulated

wastes required to be sent to permitted on-site facilities in 1984.

It should be noted that less stringent treatment/disposal require-

ments under this alternative would likely result in an increase in

the existing on-site capacity.  Any such increase would further

decrease any potential for a shortfall in necessary on-site capacity.

     Section 7.2.4.1 discusses other factors that could either lead

to shortfalls or that could exacerbate the size of the estimated

potential shortfall in both on-site and off-site process capacity,

especially on a localized basis.  Furthermore, the wastes removed

from regulation would still have to be treated/disposed, both on-site

and off-site.  While such wastes could be treated/disposed in

non-permitted facilities, their management could increase the poten-

tial for an overall shortfall in available capacity;  however, any
*The remainder of the waste not sent on-site or off-site would be
 recycled or sent to resource recovery operations, both on-site and
 off-site.

                                8-109

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resultant shortfall would be less than that under the baseline regu-

lations.  The less stringent requirement under this alternative would

also increase the number of sites at which facilities could be loca-

ted.

     Physical Capacity.  Based upon the methodology and assumptions

discussed in Section 7.2.4.2, relative to the baseline regulations

there could be an increase of approximately 0.6 million metric tons

in the total hazardous industrial wastes sent off-site during the

period from 1980 through 1984, assuming 13 percent shipment off-site

in 1984, and there could be a decrease of 4.3 million metric tons in

the total hazardous industrial wastes sent off-site during this peri-

od, assuming 25 percent shipment off-site in 1984.*

     Up to 120 to 240 additional acres could thus be committed to

off-site landfilling of hazardous industrial wastes during this per-

iod in the case of 13 percent off-site shipment and up to 860 to

1,700 fewer acres could be committed to off-site landfilling of

hazardous industrial wastes during this period in the case of 25

percent off-site shipment.  In the former case, after 1984 there

could be 65 to 130 additional acres required off-site annually com-

pared to total requirements under the baseline regulations.  In the

latter case, after 1984 there could be 320 to 640 fewer acres re-

quired off-site annually compared to the total requirements under the
*In this estimate, it is assumed that under this alternative there
 would be 15 percent off-site shipment for those hazardous wastes
 that would be regulated under the baseline regulations but which
 would not be regulated under this alternative.

                                 8-110

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baseline regulations.  In all instances there could be commensurate




changes in on-site land requirements.




     For purposes of comparison, based upon an average, secure com-




mecial landfill size of 270 acres (U.S. Environmental Protection




Agency, Office of Toxic Substances, 1977), these land requirements




would be equivalent to siting about one additional off-site secure




landfill by the end of 1984 in the case of 13 percent off-site ship-



ment.  In this case, the equivalent of less than one additional off-




site secure landfill could have to be sited annually after 1984 for




hazardous industrial waste.  The land requirements would be equiva-




lent to siting three to six fewer off-site secure landfills by the




end of 1984 in the case of 25 percent off-site shipment.  In this




case, the equivalent of one to two fewer off-site landfills could




have to be sited annually after 1984.




     8.4.2.5  Land Use Impacts.  Less total land, off-site plus.on-




site, would be required for the construction of any storage, treat-




ment, and disposal facilities needed under this alternative and for




such conjunctive developments as construction of roads, power lines,




and pipelines.  Less additional land would be required since fewer




wastes would have to be sent to permitted facilities; the wastes re-



moved from regulation could use existing facilities or other facili-




ties that were not adequate under the baseline regulations.  However,




as indicated in Section 8.4.2.4, in the case of 13 percent off-site
                               8-111

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shipment there would be more total hazardous industrial wastes (those




regulated plus those removed from regulation) sent off-site than




there would be in the similar case under the baseline regulations.




Thus, while less total land would be required, there could be more




off-site land use and less on-site land use for hazardous industrial




wastes in this case.  In the case of 25 percent off-site shipment,




there would be less total hazardous industrial wastes sent off-site




than there would be in the similar case under the baseline regula-




tions and, thus, there could be less off-site land use and more




on-site land use for hazardous industrial wastes.  Estimates of




potential change in off-site land requirements for landfills (and




commensurate changes in on-site land requirements) are presented in




Section 8.4.2.4.  Existing land uses would not change on lands




excluded from hazardous waste management under this alternative;



however, there could be localized changes in land use from any




additional shifts to off-site management from on-site management or




to on-site management from off-site management as discussed above.




     It should be noted that while shifts to on-site land use could




reduce off-site land requirements in the short term, such shifts




could also accelerate the exhaustion of the relatively limited on-




site physical capacity and could result in increased pressures for




off-site facilities in the long term.  Furthermore, the reduced




potential under this alternative for increases, both in resource
                                 8-112

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conservation and recovery and in treatment practices leading to




volume reduction (e.g., incineration), would also provide a lesser




potential for reducing total land requirements, both on-site and




off-site, in the long term.




     To the extent that the regulations under this alternative would




result in additional lands being contaminated by improper storage,




treatment, or disposal of hazardous wastes, there would be off-



setting adverse impacts to existing land uses.  Section 7.2.5 de-




scribes the types of impacts that could occur.




     8.4.2.6  Water Use Impacts.  The potential for the degradation




of groundwater and surface water quality would be increased under




this alternative as previously discussed.  Increased degradation of




water quality would result in a decreased supply of surface water or




groundwater being available to some or all consumers in the water use




area and increased restrictions on the productive use of the water.




     Since fewer hazardous waste management facilities could be re-




quired, less water would be required under this alternative for oper-




ation of such facilities.  This reduced water requirement would, how-




ever, be off-set to the extent that water would still be consumed in




the management of the wastes removed from regulation.




     8.4.2.7  Resource Conservation and Recovery.  The major changes




in resource conservation and recovery would result from excluding 16




million metric tons of hazardous manufacturing wastes from control
                              8-113

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under the Subtitle C regulations annually by 1984 and from the rela-




tively lower costs to hazardous waste generators and costs associa-




ted with hazardous waste transportation, storage, treatment, and




disposal due to the less stringent requirements under this alterna-




tive.  As discussed in Section 7.2.7, these changes would provide




less incentive for generators to modify processes so as to enable




increased recycling of hazardous wastes as process feedstocks, to re-




duce the quantities of hazardous wastes generated by specific pro-




cesses, or to change the nature of wastes produced.  Chapter 5




presents examples of the potential for increased resource recovery




from and recycling of hazardous wastes.




     8.4.2.8  Energy Use.  Energy use would be impacted under this




alternative by changes in facility construction, facility operation,




hazardous waste transport, and resource conservation and recovery.




The lesser amount of facility modification and construction that




would be necessary would result in a decrease in energy use.  Less




stringent requirements for soil liner permeabilities and for non-




point source air emission releases would further decrease the energy




use associated with facility construction.




     There would also be less energy use associated with changes in




facility operation and closure under this alternative.  Removal of 16




million metric tons of hazardous industrial wastes (plus other haz-




ardous wastes) from regulation annually by 1984 would reduce energy
                                8-114

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use as discussed in Section 7.2.8.  The reduction in the post close-




out period from 20 years to 10 years would decrease the energy use




associated with post close-out care.  Less energy would also be




required due to less stringent requirements for such activities as




incineration and leachate and groundwater monitoring.




     Previously discussed changes in resource recovery would lead to




other changes in energy use.  While any reduction in resource re-




covery would result in less energy being initially required for such




activities, there would be a lesser potential for net energy



savings from resource recovery activities.




     The changes in energy use resulting from a reduction in the




transport of hazardous wastes would depend upon such factors as



shifts in the portion of wastes managed on-site and off-site and




changes in transport distances.  Based upon the methodology and




assumptions described in Section 7.2.8, Table 8-9 presents estimates




of the magnitude of the potential change in energy use (compared to




that under the baseline regulations) that could occur annually from




changes in transport distances and shifts in off-site and on-site




treatment disposal.  The estimated change in energy use under this




alternative ranges from a decrease equivalent to approximately




870,000 barrels of crude oil for a 1,000-mile round-trip distance




with 25 percent off-site treatment/disposal to an increase equivalent




to approximately 7,000 barrels of crude oil for a 100-mile round-trip




distance with 13 percent off-site treatment/disposal.






                               8-115

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                                               TABLE 8-9

                      ESTIMATED CHANGE IN FUEL CONSUMPTION IN 1984 FROM TRANSPORT OF
                      LESS HAZARDOUS INDUSTRIAL WASTES UNDER SUBTITLE C REGULATIONS
oo

Wastes
transported
off-site
13 percent



25 percent



Average
round- trip
distance
(miles)
100
200
500
1,000
100
200
500
1,000
Change in fuel consumption
(million gallons)
+0.3
-2
-7
-17
-2
-5
-15
-35
Crude oil
equivalent *
(1,000 barrels)
+7
-40
-180
-420
-40
-130
-370
-870

    ^Assumes 95 percent efficiency in producing diesel fuel from crude oil.

-------
     There could also be fewer reductions in energy production due to

the reduced costs associated with management of wastes from such

activities and due to the exclusion of 'special wastes' from regula-

tion; many special wastes are generated by energy production activi-

ties.  There could also be fewer changes in fuels used by facilities.

This could result in reduced impacts to energy supply/demand rela-

tionships.

     8.4.2.9  Impacts to Special Interest Points.  To the extent that

treatment/disposal of the wastes removed from regulation under this

alternative would disturb, destroy, or intrude upon special interest

points, there would be less of a reduction in adverse effects to such

special interest points as discussed in Section 7.2.9.  However, to

the extent that fewer lands, especially off-site lands, would be dis-

turbed for facility construction and operation and for conjunctive

developments under this alternative, there would be a lesser poten-

tial for the disturbance and/or destruction of sites of aesthetic,

archaeological, historical, paleontological, or recreational value.

8.5  Potential Changes in Impacts Resulting from the Phase I Alterna-
     tive

     This section discusses the potential changes in impacts (rela-

tive to those of the baseline regulations) that could occur from the

promulgation of the regulations contained in the Phase I Alternative.

To avoid considerable duplication in the presentation, potential

impacts that would not be changed under this alternative are not

repeated.  Only major changes in potential impacts are discussed.
                                   T
                                 8-117

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     One of Che major changes under this alternative is the addition

of Interim Status Standards (see Table 4-4).  The Interim Status

Standards represent the minimum requirements with which an existing

treatment, storage, or disposal facility must comply until admini-

strative disposition of the facility's permit application is made.

The Interim Status Standards would apply to all activities affecting

any hazardous waste handled at such a facility after the effective

date of the regulations.  Under the baseline regulations existing

facilities would not be required to modify their present practices

until after being issued a permit.

     8.5.1  Primary Impacts.  The major changes to primary impacts

that could occur as a result of implementation of this alternative

are discussed in the following sections:

     • Hazardous Wastes to be Regulated;

     • Changes to Existing Generation, Transporation, Storage, Treat-
       ment, and Disposal Practices and Procedures;

     • Administrative Changes;

     • Air Impacts;

     • Water Impacts;

     • Public Health Impacts.

     8.5.1.1  Hazardous Waste to be Regulated.  Under this alterna-

tive several modifications would affect the quantity of waste that is

subject to Subtitle C requirements, as compared to the baseline

regulations.  These modifications relate to the following:

     • Generator limit;

                                 8-118

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     • Corrosivity characteristic;




     • Toxicity characteristic;




     • Listed wastes;




     • Wastes that are re-used;




     • 'Special wastes';




     • Farm wastes;




     • Retail wastes.




     Each of the above would affect the quantity of waste subject to




the Subtitle C regulations in different ways.  General effects are




discussed first.  Specific changes with regard to the regulation of




manufacturing wastes, 'special wastes', and non-manufacturing wastes




are then summarized.  Changes are quantified to the extent that data




permit; however, most of this discussion is necessarily qualitative.




EFA staff estimates are that the net effect of all the above modifi-




cations would likely be a slight decrease in the quantity of waste




regulated under this alternative, as compared to the baseline regula-




tions.




     General Changes.  The first five modifications listed above




would affect wastes generated by all sources (i.e., manufacturing




wastes, 'special wastes', and non-manufacturing wastes) and are




discussed in this section.  Each of these modifications, except for




changes in listed wastes, would act to reduce the quantity of waste




subject to regulation.  The last three modifications listed above




would relate only to the wastes specified and are discussed in






                                8-119

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subsequent sections.  It should be noted that the overall effects of




the individual modifications would be somewhat duplicative in that




some of the same wastes would likely be excluded from regulation by




more than one modification.




     Under the baseline regulations, the generator limit would be 100




kilograms per month.  Under this alternative, the generator limit




would be raised to 1,000 kilograms per month during the first 2 to 5




years following implementation of the regulations.  At the end of




this period, the generator limit would again be set at 100 kilograms




per month.  During this initial period, almost all hazardous wastes




from each source generating a total of between 100 and 1,000 kilo-




grams of hazardous waste per month would be excluded from regulation.




Based on Sections 7.1.1 and 8.4.1.1, the net effect of this change is




estimated to be a slight reduction in the quantity of waste being



regulated.  There would, however, be two categories of wastes which




would not be subject to this new generator limit.  The first category




consists of those listed waste for which a separate, lower exclusion




limit is specified.*  The second category consists of those wastes




which result from discarding any quantity of specified commercial




chemical products and manufacturing chemical intermediates,' from




discarding over 10 kilograms of containers and liners used for these




chemical products and intermediates, and from discarding over 100
*There are no such exclusion limits specified at this time, however.




tSee Section 4.5.



                                8-120

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kilograms of spill clean-up residues from these products and interme-

diates.  Except for the spill clean-up residues, the portion of

hazardous waste that is generated from these products and intermedi-

ates at a rate in excess of the limits indicated above, but at a rate

of less than 100 kilograms per month, would constitute an additional

quantity of waste not previously controlled under the baseline reg-

ulations.  The control of these two additional categories of wastes

would off-set some of the reduction in regulated waste that results

from raising the generator limit under this alternative.

     Modifications to the characteristics for corrosivity and toxi-

city would also reduce, by an indeterminable amount, the quantity of

waste regulated under this alternative, as compared to the baseline

regulations.  The pH limits for identifying an aqueous waste as a

corrosive waste would be narrowed.  Wastes with a pH between 2 and 3,

or between 12 and 12.5, would not be regulated as a corrosive waste

under this alternative.  The concentrations of contaminants in the

extract used to identify a waste as toxic waste would also be rais-

ed.*  Wastes whose extract contains a concentration of any speci-

fied contaminant that is between 10 and 100 times its EPA Primary
*Under this alternative, wastes meeting the toxicity characteristic
 are defined as Type I toxic wastes to distinguish them from other
 wastes that are listed as toxic based on criteria other than this
 toxicity characteristic (see Table 4-4).  To be consistent with
 other portions of the EIS, the Type I toxic waste is referred to as
 toxic waste in this section, and the other listed toxic wastes are
 referred to as general toxic wastes.

                                8-121

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Drinking Water Standard would not be regulated as a toxic waste under




this alternative.




     Changes in the quantity of wastes to be regulated would also




result from modifications to the criteria for listing hazardous waste




and modifications to the lists themselves.  The criterion of Admini-




strator's Judgment for listing wastes would be eliminated and




replaced by a set of specific criteria for listing waste.  Little or




no change in the quantity of waste regulated is expected from this




change since it is essentially a formalization of the decision pro-




cess implicitly used under the baseline regulations.




     The lists of hazardous wastes from specific and non-specific




sources and the list of infectious waste would all be modified under




this alternative.  Wastes would be both added to and deleted from the




lists.  Many of the additional wastes listed would be included based




upon the criteria of general toxicity (as opposed to the toxicity




characteristic) and, thus, would not have been controlled under the




baseline regulations.  To the extent that any other wastes that are




added to the lists would previously have been hazardous under the




baseline characteristics, there would be essentially no change in the




quantity of such wastes being regulated.  Similarly, to the extent




that any wastes deleted from the lists would still be hazardous under




the characteristics of this alternative, there would also be essen-




tially no change in the quantity of such wastes being regulated.  The




net effect of these changes in listed wastes is estimated to be an
                                8-122

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increase in the quantity of such wastes being regulated under this

alternative, as compared to the baseline regulations.

     With regard to waste materials that are both re-used and whose

re-use constitutes disposal (e.g., wastes incinerated for energy

recovery or re-used in road construction or as a soil conditioner),

there would be a significant reduction in the quantity of such wastes

regulated under this alternative.  Under the baseline regulations,

specified waste oils and any other hazardous waste whose re-use con-

stitutes disposal would be subject to the regulations.  Under this

alternative, only specified waste materials* that are used, re-

used, or stored for use or re-use would be subject to the regula-

tions.  Waste materials that are not specified would be excluded from

regulation if used, re-used, or stored for use or re-use.  Waste oil

used for purposes other than material recovery or energy recovery is

the only waste specified for regulation under this alternative.t

Examples of wastes which, if identified as hazardous, would be

excluded from regulation by this change include waste oils' and sol-

vents incinerated for energy recovery; coal ash used for road con-

struction, as a soil conditioner, and as a de-icing agent on roads;

cement kiln dust used for soil conditioning and road construction;
*Waste materials include by-products as well as wastes.

tit is anticipated that additional materials would be specified;
 any such additional listing would off-set some of the reduction in
 waste being regulated as a result of this modification.
                                8-123

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and iron and steel slags used for road construction, for landfilling,




and as railroad ballast.




     Specific Changes.




     Manufacturing Waste.  Under the baseline regulations, it is




estimated that approximately 35 and 40 million metric tons of manu-




facturing waste could be subject to the Subtitle C regulations in




1980 and 1984, respectively.  Except for the change in listed wastes,




each modification discussed above would tend to reduce the quantity




of manufacturing waste that is subject to regulation under this




alternative.  While the specific impact of most of these modifica-




tions is not quantifiable, it is estimated that there would likely be




a net reduction in the quantity of manufacturing waste being con-




trolled, as compared to the baseline regulations.




     The change in the generator limit could result in a small (i.e.,




less than 0.1%) decrease in the quantity of manufacturing waste regu-




lated during the first 2 to 5 years.  Based upon Tables 7-2 and 8-7,




this change could result in approximately 340,000 metric tons of man-




ufacturing wastes being excluded from regulation during each of the




first 2 to 5 years.  There would be a total reduction of between 0.7




and 1.7 million metric tons of manufacturing waste being regulated




during this period as a result of this change.  However, some of this




reduction would be off-set by the increased control of specified com-




mercial chemical products and manufacturing chemical intermediates.
                                 8-124

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     Modification of the characteristics for corrosivity and toxicity




would also reduce, by an indeterminable amount, the quantity of manu-




facturing wastes being regulated.  For example, some lime treated




sludges would be excluded by the change in the corrosivity character-




istic.



     There would also be a significant reduction in the regulation of




those hazardous waste materials that are re-used in a manner consti-




tuting disposal.  For example, approximately 30 million metric tons




of iron and steel slags were re-used in such a manner in 1976 (U.S.




Environmental Protection Agency, 1979).  Data are not available to




estimate the portion of such slags or any other re-used waste materi-




als (e.g., oils and solvents) that could be considered hazardous




under the regulations and that could, thus, be excluded from regula-




tion under this alternative.




     Modifications to the listed wastes are estimated to result in a




net increase in manufacturing wastes that would be subject to the




regulations.  For example, pesticide production wastes, PCB's and PCB




items, and additional organic chemical wastes would be added to the




hazardous waste lists.  Cooling tower sludges, non-stabilized sewage




treatment sludges, and copper production slags would be deleted.




     Special Waste.  The baseline regulations specify six, large vol-




ume, 'special wastes' that, if identified as hazardous, would be




subject to a limited subset of the regulations.  Under this alterna-




tive, all hazardous 'special wastes', except for uranium mining and
                                   8-125

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phosphate rock mining, beneficiation, and processing wastes, would

now be subject to the full set of Subtitle C regulations.*  The

uranium mining and phosphate mining, beneficiation, and processing

wastes would still be subject to a limited subset of the regulations,

though modified from the baseline regulations (see Table 4-4).

     Changes in the generator limit and corrosivity and toxicity

characteristics and in the control of waste materials that are

re-used would reduce, by an indeterminable amount, the total quantity

of all 'special wastes' that are subject to regulation under this

alternative.  For example, approximately 13 million metric tons of

coal ash were re-used in 1977 (The Utility Solid Waste Activities

Group and The Edison Electric Institute, 1979).  Data are not avail-

able to estimate the portion of any coal ash or other re-used waste

materials that could be considered hazardous under the regulations

and that could thus be excluded from regulation under this alterna-

tive.  An exclusion added for in-situ mining wastes would further

reduce the quantity of 'special waste1  being regulated.  Changes in

listed wastes would not effect the quantity of 'special wastes' being

regulated.

     The net effect would be an increase in 'special wastes' being

subject to the full set of regulations, but a decrease in the total

quantity of 'special wastes' being subject to any regulation.
*It should be noted that several bills are presently pending in
 Congress to exempt, at least temporarily, most 'special wastes' from
 any regulation under Subtitle C.

                                8-126

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     Non-Manufacturing Waste.  The net effect of this alternative is

estimated to be a reduction in the quantity of non-manufacturing

wastes being regulated, as compared to the baseline regulations.

     The changes in the generator limit and the corrosivity and

toxicity characteristics and in the control of waste materials that

are re-used would reduce the quantity of non-manufacturing wastes

subject to regulation by an indeterminable amount.*  The change in

listed wastes would also reduce the quantity of non-manufacturing

wastes regulated.  The list of infectious wastes would be more speci-

fic, resulting in fewer wastes from hospitals, veterinary hospitals,

and medical and research laboratories being identified as hazardous.

Cooling tower sludges would also be deleted from the lists while

PCB's and PCB items would be added.  Leachate from hazardous waste

disposal facilities would also be added to the list; however, it is

anticipated that most of this leachate would previously have been

identified as hazardous under the baseline regulations.

      Other changes would result in less waste from commercial estab-

lishments being subject to regulation.  Under the baseline regula-

tions waste automotive oil is the only waste from commercial estab-

lishments that would be subject to control.  The waste'automotive oil
*A recent study (TRW, 1979) estimates that changing the generator
 limit from 100 kilograms per month to 1,000 kilograms per month
 could exclude about 15 percent of non-manufacturing wastes from
 regulation.  However, much of this non-manufacturing waste is
 generated by commercial establishments and, as such, would already
 have been excluded under the baseline regulations.
                                   8-127

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from commercial establishments would be excluded from regulation

under this alternative.  However, control of waste chemical commer-

cial products generated by commercial establishments would off-set

some of this reduction in the control of commercial waste.

     Under the baseline regulations, persons engaged principally in

farming would be subject to the regulations only with regard to the

generation of waste automotive oil.  Under this alternative, such

persons would be regulated with regard to all hazardous waste gener-

ated, except waste pesticides.*  Consequently, there would be an

increase in the quantity of farm wastes regulated when the generator

limit is lowered to 100 kilograms per month.  However, during the

initial 2 to 5 year period when the generator limit is raised to

1,000 kilograms per month, there likely would be a net reduction in

farm wastes regulated, as compared to the baseline regulations.

     8.5.1.2  Changes to Generation, Transport, Storage, Treatment,

and Disposal Practices.  Changes to generation, transport, storage,

treatment, and disposal practices would likely occur under this

alternative due to the changes in wastes being regulated; due to

implementation of the Interim Status Standards; due to revisions in

procedural and operational requirements; and due to resultant changes

in the cost of hazardous waste generation and in storage, treatment,

and disposal costs.
*Waste pesticide would be excluded from regulation provided it is
 generated by the farmer's own use and is managed as specified in
 Table 4-4.
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     In general, there would be some significant differences between




those changes related to the management of hazardous 'special wastes'




and those changes related to the management of all other hazardous




wastes.  These differences would be the result of the requirement




that most hazardous 'special wastes' comply with the full set of




Subtitle C standards under this alternative, rather than the limited




set of standards specified under the baseline regulations.  All other




hazardous wastes are already required to comply with the full set of




regulations.  As a result, the changes related to 'special wastes'




and the changes related to all other hazardous wastes are discussed




separately throughout this section.




     Generation.  There would be changes in those generators that are




required to comply with the generator regulations.  A number of




generators would be excluded from regulation under this alternative.




These generators include those who, during the first 2 to 5 years,




generate between 100 and 1,000 kilograms per month of almost any




identified hazardous waste; those who generate only wastes deleted




from the baseline hazardous waste lists; those who generate only




wastes no longer identified as hazardous under the revised corrosiv-




ity and toxicity characteristics; those who general only wastes that




are re-used in a manner constituting disposal; and those commercial




sources generating only waste automotive oil.  A number of additional




generators would also be required to comply with the generator regu-




lations.  These generators include those who generate only wastes
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added to the baseline hazardous waste lists; those who only import




hazardous wastes into the jurisdiction of the U.S.; those who gener-




ate only wastes from the specified commercial chemical products; and




those fanners who only generate hazardous waste other than automotive




oil or pesticides.  Section 8.5.1.3 presents estimates of changes in




the number of generators to be regulated.




     Those generators excluded from regulation under this alternative




would no longer be required to modify their existing practices and




procedures, as indicated in Section 7.1.4.1, with regard to manifest-




ing, reporting, recordkeeping, containerization, and labeling.  Those




additional generators brought under regulatory control would, on the




other hand, be required to modify their existing practices and proce-




dures.  Furthermore, all generators regulated under this alternative




would be subject to reduced manifest requirements and increased



reporting, recordkeeping, and waste accumulation requirements, as




indicated in Table 4-4.  For example, generators who do not receive a




signed copy of the manifest from the designated permitted facility




within 35 days after acceptance by the initial transporter would have




to contact the transporter and/or designated facility to determine




the status of the movement.



     Furthermore, with the exception of those generators of hazardous




'special wastes,1 there would be less of an incentive for generators




to modify their processes or activities so as to reduce and/or change




the types and amounts of hazardous wastes generated and to enable the
                                8-130

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increased recycling of hazardous wastes as process feedstocks.  This

would be the result of reductions under this alternative in costs to

such hazardous waste generators*; reductions in costs associated

with transportation, storage, treatment, and disposal of these


wastes*; reductions in the number of generators being regulated;

and reductions in the quantity of wastes being regulated.  Most gen-

erators of hazardous 'special wastes' would, however, have increased

costs for storing, treating, and disposing their wastes since the

wastes would be subject to the full set of regulations instead of a

limited portion.  This could provide an increased incentive for some

of these generators to further modify their processes or operations

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

waste generated.

     Transport.  Changes in transport practices and procedures are

discussed first with regard to hazardous wastes other than 'special

wastes.1  Changes related to the transport of hazardous 'special


wastes' are then addressed.

     Due to expected reductions in the quantity of hazardous wastes,

other than 'special wastes', subject to the generator regulations,

fewer transporters would likely have to comply with the transporter

regulations discussed in Section 7.1.2.2.  There would likely be

increased instances of midnight dumping and spills from transport of

those wastes excluded from regulation.  The requirement that
*See the Economic Impact Analysis for Subtitle C, Resource
 Conservation and Recovery Act of 1976.


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transporters deliver the waste movement only to facilities designated
by the generator, along with the shorter interval for the reporting
of manifests not received from the designated facility would,
however, reduce the potential for any midnight dumping of regulated
wastes.  Any decreases in the average distances over which these
regulated wastes are transported under this alternative could lead to
a decrease in vehicular accidents and in resultant spills.  This
would off-set some of the increased potential for spills indicated
above.  Elimination of the prohibition on transporters accepting
containers that are leaking or that appear damaged could slightly
increase the potential for spills; however, since the transporter
would be responsible for the waste during transport, it would not be
in the transporters interest to accept such containers.
     The average distance over which hazardous wastes (other than
'special wastes') are transported would likely decrease due to
several factors.  The requirements under this alternative would, to a
small extent, reduce the likelihood of on-site and off-site treat-
ment/disposal facility closure.  However, the Interim-Status Stan-
dards could result in those facility closings that do occur taking
place sooner under this alternative than under the baseline regula-
tions.  Any increase in available facility capacity would potentially
lead to reduced transport distances.  Furthermore, increases in per-
mittable on-site treatment/disposal capacity could result in fewer
wastes being sent off-site.  Decreases in treatment/disposal costs
could also reduce the distance over which wastes could be
                                 8-132

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economically transported for resource recovery purposes.  However,




any reductions in on-site resource conservation and recovery, as




described above, could tend to increase the quantity of waste being




sent off-site.




     The replacement of the baseline requirements for spill notifica-




tion and reporting with requirements specified under Department of




Transportation regulations (49 CFR 171) and Coast Guard regulations




(33 CFR 153) would further reduce changes to some existing transport




practices.  Interstate and some intrastate shipments of those hazard-




ous wastes that are also identified as DOT hazardous materials are




currently subject to these DOT regulations.  Consequently, existing




spill notification and reporting practices would not have to be




modified in the case of spills of such wastes.  Also, water (bulk




shipment) transporters are currently subject to the Coast Guard




Regulations for any spill that could threaten navigable waters; any




spill that is into or upon navigable waters, adjoining shorelines, or




contiguous zones; or any spill that may affect applicable natural




resources.  Thus, these transporters would not have to modify their




existing spill notification procedures in the event of such spills.




The reporting requirement added under the baseline regulations for




spills by these transporters would also be eliminated under this




alternative.




     Other changes would impose additional administrative require-




ments on transporters.  Those transporters who ship hazardous waste
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out of the U.S. would be subject to additional reporting and record-



keeping requirements.  Water (non-bulk shipment) transporters would




have to obtain signatures for intramodal transfers of hazardous




waste.  All transporters would be required to obtain signatures




immediately upon delivery of the waste to the designated facility,




instead of within 5 days as allowed under the baseline regulations.




     With regard to hazardous 'special wastes,1  there would be a les-




ser quantity of such waste subject to regulation under this alterna-




tive.  However, there could be a net increase in the quantity of




hazardous special wastes being sent off-site and, thus, in the number




of transporters of 'special wastes' who would be required to comply




with the transporter regulations previously discussed.  Currently,




'special wastes' are typically managed at on-site facilities.




Imposition of the full set of Subtitle C regulations could result




in the closing of some of these on-site facilities; this could lead




to increased off-site shipments of hazardous 'special wastes.'




Increased off-site shipments could potentially result in increased




spills of such wastes and increased vehicular accidents.




     Transport practices for those hazardous 'special wastes' already




shipped off-site under the baseline regulations would be modified in




a manner similar to that discussed above for hazardous wastes other




than 'special wastes.1
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     Storage.  Changes in storage practices and procedures are dis-
cussed first with regard to hazardous wastes other than 'special
wastes.1   Changes related to the storage of hazardous 'special
wastes' are then addressed.
     Due to anticipated reductions in both the number of generators
and the quantity of hazardous wastes (other than 'special wastes')
regulated under this alternative, it is likely that fewer storage
facilities handling such wastes would have to comply with the storage
regulations discussed in Section 7.1.2.3.  As a result, fewer of
these facilities could be required to be modified or closed.  Those
closings or modifications that do occur could, however, take place
sooner under this alternative due to the requirements of the Interim
Status Standards.  Facilities excluded from regulation under this
alternative would not have to change existing storage practices.
However,  for those facilities still regulated, compliance with the
Interim Status Standards could necessitate earlier implementation of
required changes to existing practices.  Regulated facilities would
also have to comply with the modified requirements contained in Table
4-4.
     With regard to hazardous 'special waste,' there would be a
lesser quantity of such wastes subject to regulation under this
alternative.  Thus, fewer facilities storing these wastes would have
to comply with the storage requirements.  However, for those facili-
ties still regulated, compliance with the full set of storage
requirements would likely lead to additional changes in existing
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practices, similar to chose discussed in Section 7.1.2.3, and to
additional modifications and closings.  These facilities would also
have to implement some required changes sooner, in accordance with
the Interim Status Standards.
     Treatment/Disposal.  Changes in treatment/disposal practices are
discussed first with regard to hazardous wastes other than 'special
wastes.1  Changes related to the treatment/disposal of hazardous
'special wastes' are then addressed.
     Due to anticipated reductions in both the number of generators
and quantity of hazardous waste (other than 'special wastes') regu-
lated under this alternative, it is likely that fewer treatment/dis-
posal facilities would have to comply with the treatment/disposal
regulations discussed in Section 7.1.2.4.  As a result, fewer facili-
ties would be closed because they could not comply with the regula-
tions or could not be economically modified.  Those closings or
modifications that do occur could take place sooner, however, due to
the requirements of the Interim Status Standards.  To the extent that
fewer on-site facilities were closed and fewer wastes and generators
were regulated, there would be a potential for fewer wastes to be
sent off-site for treatment/disposal.  However, reductions in on-site
resource conservation and recovery practices, as described above,
could tend to off-set any such change in wastes being sent off-site.
     Facilities excluded from regulations would not have to change
existing treatment/disposal practices.  However, for those facilities
still regulated, compliance with the Interim Status Standards could
                                 8-136

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necessitate the earlier implementation of some changes to existing
practices.  In addition, regulated facilities would now also have to
comply with the other modified requirements contained in Table 4-4.
Some of these requirements would be more stringent than those of the
baseline regulations.  For example, the period for post-closure care
would be increased from a period not to exceed 20 years to a period
of at least 30 years in most cases.  Other requirements would be less
stringent.  For example, all Human Health and Environmental Standards
and all requirements to comply with such standards would be elimi-
nated.  And still other requirements would be essentially equivalent
to baseline requirements in their effect, but would be more flexible
in their application.  For example, the requirement that the active
portion of a facility must be surrounded by a fence or barrier would
be replaced by several options for insuring equivalent site security.
     With regard to hazardous 'special wastes,1  there would be a les-
ser quantity of such waste subject to regulation under this alterna-
tive.  Thus, fewer facilities treating/ disposing these wastes would
have to comply with the treatment/disposal regulations.  However, for
those facilities still regulated, compliance with the full set of
treatment/disposal requirements would likely lead to additional
changes in existing practices, similar to those discussed in Section
7.1.2.4, and to additional facility modifications and closings.
These facilities would also have to implement some of these changes
sooner, in accordance with the Interim Status Standards.  To the
extent that existing on-site facilities were closed, increased
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quantities of hazardous special wastes could be sent off-site.  The

regulated facilities would also have to comply with the modified

requirements contained in Table 4-4.

     8.5.1.3  Administrative Changes.  Several changes in the admini-

stration of the hazardous waste management program would result from

promulgation of the regulations within this alternative.  These regu-

lations would affect:

     •  State administration of the program;

     •  Overlapping Federal and state programs;

     •  Number of generators required to comply with the regulations;

     •  Number of transporters required to comply with the regula-
        tions;

     •  Number of storers, treaters, and disposers required to obtain
        permits;

     •  Paperwork requirements.

     State Administration of the Program.  It is likely that there

would be little change in the number of states applying for interim

and full authorization under this alternative.  Reductions in both

the quantity of wastes being regulated and the number of generators,

storers, treaters, and disposers being regulated would lead to some

reduced administrative and manpower requirements for authorized

states and could increase the willingness of a few states to apply

for authorization.  The revisions contained in Table 4-4 are based,

in part, upon public comments received on the proposed Subtitle C

requlations and as such could also increase the willingness of some

states to apply for authorization.  However, those revisions include

                                 8-138

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less stingent requirements, more stingent requirements, and equiva-
lent but more flexible requirements than those of the baseline regu-
lations.  While these changes could make some states more willing to
apply for authorization, they could make some other states less
willing to apply.
     Partial authorization would be eliminated.  As a result, some
states that might have applied for partial authorization could
attempt to become eligible to qualify for full authorization.  How-
ever, others could decide not to apply for either interim or full
authorization.
     Overlapping Federal and State Programs.  The elimination of par-
tial authorization could increase the potential for a few states to
enact one or more components of an independent, hazardous waste pro-
gram.  However, the revised regulations under this alternative would
not be expected to significantly impact the number of states desiring
to enact their own independent programs.  It is not possible at this
time to estimate the nuber of states, if any, that would wish to have
independent programs or program components in addition to the Federal
program under .this alternative.
     Number of Generators Required to Comply With the Regulations.
As indicated in Section 8.5.1.2, there would likely be a net reduc-
tion in the total number of generators required to comply with the
regulations.
     The increase in the generator limit could result in approxi-
mately 105,000 additional manufacturing generators being excluded
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from compliance with the regulations during the first 2 to 5 years
(see Tables 7-2 and 8-7).  The total number of manufacturing genera-
tors excluded during this period would represent about 60 percent of
all manufacturing generators; however, they are estimated to generate
less than 1 percent of the total hazardous manufactuing wastes.  On
balance, some additional manufacturing generators could also be ex-
cluded by the other changes discussed in Section 8.5.1.1, however
data are not sufficient to estimate the number of any such additional
exclusions.
     Commercial facilities generating waste automotive oil would be
excluded from regulation under this alternative.  As a result, ap-
proximately 50,000 automotive service stations, plus those persons
assuming liability for waste automotive oil generators, could be
excluded from regulation (see Section 7.1.3.3).  About 5,800 research
faciliteies could be excluded during the first 2 to 5 years due to
the revision in the generator limits (see Section 8.4.1.3).  An inde-
terminable number of other non-manufacturing generators would also be
affected.  For example, additional numbers of farmers, hazardous
waste importers, and facilities generating wastes from commercial
chemical products would be required to comply with the regulations.
Other non-manufacturing generators would be excluded by changes in
the corrosivity and toxicity characteristics and in the listed
wastes.  In addition, an indeterminable number of 'special waste1
generators would be excluded by the changes discussed in Section
8.5.1.1.
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     Under the baseline regulations, approximately 270,000 to 300,000




generators are identified as potentially having to comply with the




regulations (see Section 7.1.3.3).  Based upon the additional exclu-




sions discussed above, during the first 2 to 5 years, on the order of




110,000 to 140,000 identified generators could be required to comply




with the regulations under this alternative.  This would represent




nearly a 60 percent reduction in identifiable generators.  At the end




of this 2 to 5 year period, on the order of 220,000 to 250,000 iden-




tified generators could be required to comply.  This would represent




over a 15 percent reduction.  As discussed above, there would also be




an indeterminable reduction in the number of other generators who




would be required to comply with the regulations.




     Number of Transporters Required to Comply with the Regulations.




The reduction in the amounts of regulated hazardous wastes (other




than 'special wastes') that would potentially be transported off-site




would likely result in an indeterminable decrease in the number of




transporters carrying these hazardous wastes.  The increased amounts




of regulated 'special wastes' that could potentially be transported




off-site would likely result in an increase in the number of trans-




porters carrying these wastes.




     Number of Storers, Treaters. and Disposers Required to Obtain




Permits.  Since there are no permit exclusions under the baseline




regulations for storage, treatment, or disposal facilities that han-




dle only small quantities of hazardous wastes, all facilities storing
                                8-141

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treating, or disposing hazardous wastes would be required to obtain a
                                                                   o
permit under the baseline regulations with the exception of genera-
tors who accumulate wastes on-site for less than 90 days prior to
off-site transport.  Thus, the only facilities that would be entirely
excluded from the requirements to obtain a permit under this alterna-
tive would be those facilities that handle only those wastes that
would be classified as hazardous under the baseline regulations, but
that would not be classified as hazardous under this alternative. In
addition, facilities receiving wastes only from generators producing
between 100 and 1,000 kilograms per month of hazardous wastes would
be excluded from the requirement to obtain a permit during the first
2 to 5 years of the program.  The only additional facilities that
would be required to obtain a permit under this alternative would be
those facilities that handle wastes that would not be classified as
hazardous under the baseline regulations, but that would be classifi-
ed as hazardous under this alternative.  On balance, the number of
facilities requiring permits is expected to be slightly reduced, as
compared to the baseline regulations.  However, facilities managing
'special wastes' would now have to comply with the full set of treat-
ment, storage, and disposal regulations.
     Paperwork Requirements.  The information required on manifests
would be reduced under this alternative as indicated in Table 4-4.
Based upon the expected change in off-site shipments of hazardous
waste, generators of hazardous 'special wastes' could have to prepare

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additional manifests under this alternative.  The aggregated gen-
erators, transporters, and hazardous waste management facility
owners/operators handling these wastes would also have to keep the
additional manifests in storage for 3 years.  There would, however,
likely be a net reduction in the number of manifests that would be
prepared by generators of other hazardous wastes.  The aggregated
generators, transporter, and hazardous waste management facility
owners/operators handling these latter wastes would also have to keep
fewer manifests in storage.  The total number of manifests prepared
and stored would be less during the first 2 to 5 years than in the
following years.
     The generators previously identified would have to prepare
110,000 to 140,000 reports on an annual basis during the first 2 to 5
years and 220,000 to 250,000 reports on annual basis therafter; this
would represent nearly a 60 percent decrease in annual reporting dur-
ing the first period and over a 15 percent decrease thereafter.
     Generators would also be subject to additional recordkeeping and
reporting requirements under this alternative.  Copies of annual
reports, exception reports, test results, waste analyses, and other
required records (see Table 4-4) would have to be retained for at
least 3 years.  Following the first 2 to 5 year period, over 660,000
to 750,000 of each of these records could be kept in storage on an
annual basis.  For international shipments, generators would have to
comply with the additional rporting requirements in Table 4-4 (e.g.,
notifying the Regional Administrator two weeks before the initial
                                 8-143

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shipment to any foreign country in each year).  However, these




generators would have to report on international shipments annually,




rather quartherly as under the baseline regulations.  Generators who




designate hazardous waste for off-site management at a facility which




the generator owns and which is located in the same state in which




waste generation occurs would also be required to prepare annual




reports and exception reports and to retain copies of manifests under




this alternative, but not under the baseline regulations.




     The generators previously identified would initially have to




file on the order of 110,000 to 140,000 notifications under Section




3010.  This would represent nearly a 60 percent decrease in the




number of such notifications.  At the end of the first 2 to 5 year




period, approximately 110,000 additional generators would have to




file such notifications.  Overall, there would be about a 15 percent




reduction in the number of notifications filed by generators.




     Transporters would have to prepare fewer spill reports under




this alternative since only those hazardous waste spills meeting the




requirements of 49 CFR 171 would have to be reported.  Reportable




spills include those which result in a person being killed or receiv-




ing injuries requiring hospitalization and those resulting in a con-




tinuing danger to life, health, or the environment at the scene of




the incident.




     Under this alternative, owners/operators of facilities treating,




storing, or disposing hazardous waste would be subject to revised




reporting and recordkeeping requirements in the period after being



                                 8-144

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issued a permit and to additional reporting and recordkeeping

requirements in the period before being issued a permit.  Changes

related to reporting and recordkeeping by permitted facilities are

discussed first.

     The total number of facilities requiring permits is not expected

to be significantly less under this alternative than under the base-

line regulations.*  Any reduction in the number of annual reports

prepared by permittees would thus be relatively small under this

alternative.  There could, however, be a large reduction in the num-

ber of monitoring reports prepared by permittees.  After completing

one year of monitoring, permittees would have to submit all subse-

quent monitoring reports annually rather than quarterly; furthermore,

these monitoring reports would be submitted as part of the annual

report rather than as additional reports.  Under the baseline regula-

tions there could be up to 117,000 such monitoring reports prepared

annually.  Using the number of potential permittees from the baseline

regulations as an estimate of the upper limit of the number of

permittees under this alternative, there could be up to 29,000 moni-

toring reports prepared annually under this alternative once all

facilities have completed one year of monitoring.  This would repre-

sent a reduction of at least 75 percent in such reports.
*However, for reasons discussed above, slightler fewer facilities
 would be sujbect to the treatment, storage, and disposal regulations
 under this alternative during the first 2 to 5 years than in the
 following years.  The total amount of reporting and recordkeeping
 would thus be slightly less on an annual basis during these first 2
 to 5 years than in the following years.

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     Permittees would also be subject to revised recordkeeping




requirements under this alternative.  Groundwater monitoring data




would have to be retained until closure of the facility rather than




for 3 years; in the case of disposal facilities, the monitoring data




would have to be kept throughout the entire post-closure period.




Inspection records would have to be retained for 3 years rather than




until facility closure.  Training records for current employees would




have to be kept until closure of the facility rather than for 3




years.  For former employees these records would have to be kept for




three years from the time of the employee's departure.




     These facility owners/operators would also be subject to other




administrative requirements.  For example, waste analysis, inspec-




tion, and post-closure plans would have to be prepared and submitted




with Part B of the permit applications.  Outlines of programs for




both groundwater damage assessment and for groundwater corrective




action would also have to be prepared and submitted with the permit




application.  Owners/operators of facilities receiving waste from




off-site would have to notify generators in writing that they have




the appropriate permit for and will accept delivery of the waste the




generator is shipping.  Facility owners/operators would also have to




notify the Regional Administrator at least two weeks before the




expected date of arrival of hazardous waste shipments from foreign




sources.




     Due to the expected reduction in the number of permittees, there




would be a slight decrease in the total number of notifications



                                8-146

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required to be filed by facility owners/operators under Section 3010




and in the number of permit applications prepared under this alter-




native.  However, any reductions in permit applications would be




off-set by the requirement that permits be reviewed at least once




every 5 years rather than being issued for the projected life of the




facility.  Consolidation of requirements for obtaining NPDES permits




under the Clean Water Act, UIC permits under the Safe Drinking Water




Act, Section 404 permits under the Clean Water Act, and facility




permits under RCRA would reduce the overall administrative




requirements associated with such permits.




     Facility owners/operators would also be subject to additional




reporting and recordkeeping requirements in the period before being




issued a permit.  During this period, the owners/operators of exist-




ing facilities would be subject to the Interim Status reporting and




recordkeeping requirements indicated in Table 4-4.  These Interim




Status requirements would essentially be identical to the reporting




and recordkeeping requirements applicable to permittees.  Under the




baseline regulations, facility owners/operators would not be subject




to reporting or recordkeeping requirements until after being issued a




permit.



     8.5.1.4  Air Impacts.




     Air Quality.  The regulations under this alternative would have




the potential to cause changes affecting the release of air
                                8-147

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contaminants resulting from the generation, transport, storage,




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




baseline regulations.




     Generation.  As previously discussed, the baseline regulations




would not have a direct effect on air emissions resulting from




activities and processes generating hazardous wastes.  However, for




generators of hazardous wastes other than 'special wastes,1 to the




extent that the requirements under this alternative would cause les-




ser changes in the economics of storage, treatment, or disposal




relative to those of the baseline regulations, there would be less of




a potential for these generators to make process modifications




designed to increase hazardous waste recycling and to reduce the




quantity and/or types of hazardous wastes generated; any such reduc-




tions in process modifications under this alternative would likely




lead to fewer changes in air emissions released by processes generat-




ing hazardous waste.  For generators of 'special wastes,1 to the




extent that the requirements under this alternative would cause fur-




ther increases in the economics of storage, treatment, or disposal




relative to those of the baseline regulations, there would be a




greater potential for generators of these wastes to make process or




operational modifications designed to reduce the quantity and/or




types of hazardous wastes generated; any such modifications could




lead to increased changes in air emissions released by processes




generating hazardous wastes.  To the extent that fewer generators




would be brought under control of the program in both instances, the



                                 8-148

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overall potential for any such process modifications and resultant

changes in the release of air emissions would be accordingly reduced.

     Transport.  As indicated in Section 7.1.4.1, there are three

major ways air contaminants are released by the transport of hazard-

ous wastes:

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

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

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

     As discussed below, this alternative would affect, to varying

degrees, the potential for the release of air emissions from each of

these sources.

   .  Less waste would likely be regulated under this alternative than

under the baseline regulations.  As a result, transport of the wastes

removed from regulation would not have to be carried out in accord-

ance with the Section 3002 containerization requirements or the Sec-

tion 3003 transport requirements unless the wastes were also identi-

fied as hazardous materials under the DOT Hazardous Materials Trans-

port Act.*  Thus, to the extent that these wastes would be contain-

erized or transported using methods not acceptable under the baseline

regulations, the potential for the release of fugitive emissions by

such transport and from any resultant spills or explosions would be
*In such a case, for all interstate transport and some intrastate
 transport, the wastes would be subject to many of the same contain-
 erization and transport requirements as under the baseline regula-
 t ions.
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increased under this alternative.  Section 7.1.4.1 discusses the




potential for the release of air emissions from unregulated transport




practices.




     For those hazardous wastes other than 'special wastes,' both the




total quantity of regulated wastes being transported and the average




distance over which such wastes are transported could decrease under




this alternative, as previously indicated.  Any such reductions would




lead to the release of fewer vehicular emissions and to a reduced




potential for vehicular accidents to occur and to release air emis-




sions.  However, the elimination of spill response information from




manifests could increase the time for spill clean-up and thus in-




crease the potential for the release of air contaminants from such




spills.  Elimination of the prohibition on transporters accepting




containers that are leaking or that appear damaged could also in-




crease the potential for spills or for the release of fugitive emis-




sions from the transport of regulated wastes; however, acceptance of




such containers would not be in the transporter's interest under the




Subtitle C regulations.




     For hazardous 'special wastes' there could be an increase in the




quantity of regulated wastes being transported off-site under this




alternative.  This would increase the potential for the transport of




such wastes to release fugitive emissions, to release vehicular emis-




sions, and to result in vehicular accidents causing spills.  Particu-




late matter would likely be the major air contaminant released by




such spills.  Any increased transport of 'special wastes' would,



                                 8-150

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however, have to be in compliance with all Subtitle C generator and

transporter requirements.

     For all wastes, the changes in fugitive emissions, vehicular

emissions, and emissions resulting from accidents and spills would be

dependent upon such factors as the change in travel distances, the

change in portion of hazardous wastes transported off-site, and the

change in the amount of regulated wastes being transported.

     Storage, Treatment, and Disposal.  As discussed in Section

7.1.4.1, there are several major ways that air contaminants can be

released by current hazardous waste storage, treatment, or disposal

practices:

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

     • Through fugitive emissions from ground-based
       treatment/disposal activities such as landfills, landfarms,
       and surface impoundments;

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

     • Through emissions generated by spills, fires, explosions, and
       other accidents;

     • Through the combustion of hazardous wastes by incineration or
       open burning;

     • Through fugitive emissions from other treatment activities;

     • Through fugitive emissions from facility construction or modi-
       fication

     This alternative would affect the potential for the release of

air contaminants from each of these sources in various ways as dis-

cussed below.

                                 8-151

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     To  the extent  that additional storage,  treatment, or disposal




 facilities for hazardous  'special wastes' would have  to be modified




 or constructed under  this  alternative,  there would be an increase in




 fugitive dust and vehicular emissions  from such construction activi-




 ties.  To  the extent  that  fewer  facilities for other  hazardous wastes




 would have to be modified  or constructed under this alternative  (see




 Section 8.5.2.4), there would be a decrease  in fugitive dust and




 vehicular  emissions from such construction activities.  Such emis-




 sions would be extremely  site dependent.




     Less waste would  likely be  regulated under this  alternative than




•under the  baseline  regulations.  As a  result, those hazardous wastes




 excluded from regulation would not have to be stored, treated, or




 disposed in accordance with the  Section 3004 regulations.  Since it




 is likely  that most of these wastes would not be managed by methods




 that are environmentally acceptable under the Section 3004 regula-




 tions, the overall  potential for the release of air contaminants from




 the management of such wastes would be increased under this alterna-




 tive relative to the  baseline regulations.  Wastes that are incinera-




 ted for  energy recovery (e.g., waste solvents and oil) represent one




 type of waste that  would be excluded from regulation  under this  al-




 ternative.  Section 7.1.4.1 discusses  the potential for the release




 of air contaminants from unregulated treatment, storage, and disposal




 practices.
                                 8-152

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     With regard to the hazardous waste that would still be regulated




under this alternative, the requirements under this alternative would




have to potential for affecting the release of air contaminants from




the management of these wastes in various ways.  For example, most of




the 'special wastes' would now have to be stored, treated, or dis-




posed in accordance with the full set of Section 3004 requirements




rather than a limited portion of these requirements.  Most of the




requirements applicable to these wastes under this baseline regula-




tions relate to general facility practices, such as reporting and




recordkeeping, visual inspections, post-closure care, and waste




analyses, rather than to specific treatment, storage, or disposal




practices.  As such, they would have little effect on the release of




air contaminants from such wastes.  By subjecting these wastes to the




full set of Section 3004 requirements, the overall potential for the




release of air contaminants from the management of these wastes would




be reduced in a manner similar to that described in Section 7.1.4.1



(with modifications as discussed below).




     The Interim Status Standards would further reduce the potential




for the release of air emissions from the management of all wastes




regulated under this alternative.  Existing facilities would not be




required to modify their current practices until after being issued a




permit, under the baseline regulations.  Thus, in the period before




being issued a permit, it is likely that regulated wastes would




continue to be managed by methods that would not be environmentally






                                 8-153

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acceptable under Che Interim Status Standards.  Under this alterna-




tive, existing facilities would have to manage wastes in accordance




with the Interim Status Standards until they were issued a permit.




Provisions of the Interim Status Standards that should reduce the




potential for the release of air emissions during this period are




discussed below.




     The Interim Status standards would require that facility




owners/operators inspect facilities for equipment malfunctions and




deterioration, operator errors, and spills which may be causing or




which may lead to the release of hazardous constituents to the air;




the Interim Status Standards would also require owners/operators to




make necessary repairs or take necessary remedial action.  The




facilities would have to be maintained and operated so that the pos-




sibility of a discharge, fire, or explosion which could threaten the



environment or human health outside the facility is minimized.




Ignitable or reactive wastes would have to be separated and protected




from sources of ignition or reaction.  Contingency plans would have




to be developed to minimize human health and environmental damage in




the event of an unplanned sudden or non-sudden discharge of hazardous




waste.  During an emergency, the facility's emergency coordinator




would have to take all reasonable measures to ensure that fires and




explosions do not occur, re-occur, or spread and would have to




monitor for leaks, pressure buildups, gas generation, or ruptures if




the facility stops operations.






                                 8-154

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     In addition, ignitable, reactive, and/or incompatible wastes



would be prohibited from being placed in tanks, surface impoundments,




land treatment facilities, or landfills unless the waste both would




not generate heat, fumes, fires, or explosive reactions and would be




rendered non-ignitable or non-reactive by such activities.  Ignitable




and/or reactive wastes could not be placed in waste piles unless the




above two conditions were met.  Incompatible wastes would be prohi-




bited from being placed in the same container or pile, and containers




or piles holding incompatible wastes would have to be separated from




incompatible wastes in other piles, containers, or impoundments.




Furthermore, all wastes placed in piles would have to be covered or




otherwise managed so as to prevent wind dispersal.




     Incinerators would have to be brought to steady state (normal)




conditions of operation before hazardous wastes were added so as to




insure adequate destruction of the waste and to minimize the release




of air contaminants.  Wastes would have to be analyzed to establish




steady state operating conditions and to determine the types of pol-




lutants that might be emitted.  The stack plume and existing instru-




ments which relate to combustion and emission control would have to




be monitored periodically to insure that the incinerator was operat-




ing properly.  The complete incinerator and associated equipment




would have to be inspected at least daily for leaks, spills, and




fugitive emissions.  Open burning would be prohibited for all wastes




except explosive wastes.
                                8-155

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       Following  the  Interim Status  period,  other  changes  under  this
  alternative  would further  affect the  potential for  the release  of air
  emissions.   With regard  to equipment  malfunctions or  deterioration,  a
  requirement  would be  added for making repairs or taking  other  reme-
  dial  action  on  a timely  basis so as to ensure that  environmental or
  human health hazards  do  not occur.  A requirement would  also be added
  for contingency plans to include provisions  for  controlling spills.
  To the  extent that  such  provisions reduce  the number  of  spills  or the
  time  for  spill  clean-up,  the potential for the release of  air  emis-
  sions would  be  reduced.
       The  air human  health  and environmental  standards would be  elimi-
  nated under  this alternative.  This would  reduce the  potential  for
  decreases in the release of air contaminants from non-point sources
  (e.g.,  surface  impoundments, landfills,  storage  areas) at  permitted
  facilities,  as  compared  to the baseline regulations.  The  air  human
  health  and environmental  standard  would have required that non-point
  sources of air  emissions not contribute any  listed  air contaminant
  (see  Appendix B, Subpart D,  Annex  2)  to the  atmosphere,  at the  sur-
  face  of the  non-point source, in concentrations  exceeding  the  listed
  Threshold Limit Value (TLV)  for that  contaminant, nor contribute two
  or more listed  air  contaminants in a  manner  which causes the sum of
  the individual  concentrations divided by the individual  TLV's  to
  exceed  unity.   Examples  of air contaminants  to which  the air human
  health  standards would apply and which have  been identified in  the
•  reported  incidents  cited in Section 7.1.4.1  include acetone,
                                  8-156

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asbestos, benzene, carbon monoxide, carbon tetrachloride, methane,




and methylene chloride.  As discussed in Section 7.1.4.1, the air




human health and environmental standard would apply only after the




standard was violated; it would not be a means to initially prevent




the release of air contaminants.  Thus, under this alternative, air




emissions from regulated wastes would be increased to the extent that




releases from non-point sources would exceed the limits indicated




above.




     It should be noted that there would likely be some shift in the




types of methods used to store, treat, or dispose both regulated




wastes and the wastes excluded from regulation under this alternative




compared to the methods that would have been used to manage these




wastes under the baseline regulations.  For example, the elimination




of air human health and environmental standards could reduce the




incineration of some wastes and increase their landfilling or treat-




ment in surface impoundments, relative to the baseline regulations.




Such shifts would change both the types and quantities of air emis-




sions produced by the management of specific wastes.  For example, a




shift from incineration to landfilling of a particular waste would




potentially result in a decrease in the release of combustion pro-




ducts and an increase in the release of particulate matter and/or




gases contained in the waste.  Such shifts could either enhance or




reduce the potential for this alternative to cause the indicated




increased or decreases in the release of specific air emissions in






                                8-157

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any given locality.  Furthermore, the construction of new  facilities



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




the facility and along any transport routes.  Closure of existing




facilities could lead to reduced releases of air emissions.  All em-




issions and any localized degradation of air quality would have to be




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




standards, OSHA standards, state standards).




     Climate.  To the extent that additional hazardous waste manage-




ment facilities would have to be constructed and operated  for hazard-




ous 'special wastes' under this alternative, there could be increased




localized impacts to temperatures, humidities, and low-level wind




patterns from such construction.  To the extent that fewer hazardous




waste management facilities would have to be constructed for other




hazardous wastes, there could be fewer localized impacts to tempera-



tures, humidities, and low-level wind patterns.  Any such effects




would be expected to be extremely localized.




     8.5.1.5  Water Quality Impacts.  The regulations under this



alternative would have the potential to cause changes affecting the




release of water contaminants from the generation, transport, stor-




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




baseline regulations.  As discussed below, this would lead to instan-




ces of both incresed and reduced localized improvements in water




quality, as compared to the baseline regulations.
                                    8-158

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     Many of the potential changes to groundwater and surface water




impacts would occur in much the same manner as the potential changes



discussed under air quality.  To avoid redundant discussions, such




changes are summarized below rather than discussed in detail.  Other




major changes are described in more detail.




     As indicated, generators of hazardous 'special wastes' would be




more likely to make process modifications designed to reduce the




quantity and/or types of hazardous wastes generated and to increase



recycling of such wastes.  This would likely lead to increased




changes in any water effluents being produced by such processes and




thus to increased changes in any resultant groundwater and surface



water contamination. Generators of other hazardous wastes would be




less likely to make such process modifications.  This would lead to




fewer changes in any water effluents produced by such processes and




thus to fewer changes in any resultant groundwater and surface water




contamination.  To the extent that fewer generators would be brought




under control of the program in both instances, the overall potential



for any such process modifications and resultant changes in the re-




lease of water contaminants would be accordingly reduced.




     For hazardous wastes other than 'special wastes', both the total




quantity of waste being transported subject to the Subtitle C regula-




tions and the average distance over which the wastes are transported




could decrease under this alternative.  A decrease in the quantity of



such waste transported subject to the regulations would increase the
                                    8-159

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potential both for midnight dumping and spills and for resultant im-




pacts to groundwater and surface water quality.  Other changes dis-




cussed under air quality, such as the elimination of spill response




information from the manifest, could further increase both the poten-




tial for spills to occur and the time for clean-up of such spills,




thus increasing the potential for water quality degradation.  How-




ever, any decrease in the average distance over which these wastes




are transported would decrease the potential for vehicular accidents




and for resultant spills.  Reduced transport distances would also re-




sult in decreased vehicular emissions and in a decreased potential




for oil, grease, and the hydrocarbons and heavy metals contained in




vehicular exhausts to be carried into waterways by run-off.




     For hazardous 'special wastes', there could be an increase in




the quantity of regulated wastes being transported off-site.  This




would increase the potential both for vehicular accidents to occur




and to cause spills and for oil, grease, and the hydrocarbons and




heavy metals contained in vehicular exhausts to be released and car-




ried into waterways.  Other changes discussed above could further




increase the potential for water quality impacts.  Any increased




transport of 'special wastes' would, however, have to be in compli-




ance with all Subtitle C generator and transporter requirements.




     The hazardous wastes excluded from regulation under this




alternative would not have to be stored, treated, or disposed in ac-



cordance with the Section 3004 regulations, though they could be sub-




ject to applicable regulations under Subtitle D of RCRA and other





                                   8-160

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State and Federal legislation (e.g., the Clean Water Act and the Safe




Drinking Water Act).  Wastes with a pH between 2 and 3 or between 12




and 12.5 and wastes whose extract contains any specified water con-




taminant in a concentration between 10 and 100 times its EPA Primary




Drinking Water Standards would be among those excluded.  Based on



current practices, many of the wastes excluded from regulation would




not be stored, treated, or disposed by methods which are environmen-




tally acceptable under the Section 3004 regulations.  Thus, the



potential for groundwater and surface water degradation from manage-




ment of these wastes would be increased relative to the baseline




regulations.  Section 7.1.5 describes the potential for surface water



and groundwater impacts from the treatment/disposal of such wastes




under current practices and requirements.




     With regard to the hazardous waste that would still be regula-




ted, the requirements under this alternative would have the potential




for affecting the release of water contaminants from the management




of these wastes in various ways.  Some of the requirements would



result in an increase in the potential for the release of such




contaminants relative to the baseline regulations while others would




result in a decrease.  Changes that could potentially have signific-




ant affects on the release of contaminants are discussed below.




     To the extent that additional storage, treatment, or disposal




facilities for hazardous 'special wastes' would have to be modified



or constructed, there would be an increase in fugitive dust,
                                   8-161

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vehicular emissions, and runoff from such construction activities.




To the extent that fewer facilities for other hazardous wastes would




have to be modified or constructed, there would be a decrease in




fugitive dust, vehicular emissions, and runoff.  Such emissions would




be extremely site dependent.



     Much hazardous 'special wastes' would now have to be stored,




treated, or disposed in accordance with the full set of Section 3004




requirements rather than just a limited portion of these require-




ments.  By subjecting these wastes to the full set of Section 3004




requirements, the overall potential for the release of water contami-




nants from the management of these wastes would be reduced in a man-




ner similar to that described in Section 7.1.5 (with modifications as




discussed below).




     The Interim Status Standards would further reduce the potential




for the release of water contaminants and for resultant water quality




impacts from the management of all wastes regulated under this alter-




native.  As discussed under air quality, various requirements, such



as those for inspections, repairs, contingency plans, and emergency




procedures, would reduce the potential for spills and for other un-




planned suddent and non-suddent discharges, thus reducing the poten-




tial for water quality impacts.



     In addition, the Interim Status Standards would require that




within one year after the effective data of the regulations that



owners/operators of surface impoundments, landfills, or land
                                    8-162

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treatment facilities intall, maintain, and operate a groundwater mon-




itoring system.  These owners/operators would also be required to




prepare an outline of and time estimate for completion of a ground-




water damage assessment program based on this monitoring.




     The Interim Status Standards would also impose general require-




ments for controlling or containing spills and/or runoff from land-




fills, surface impoundments, tanks, waste piles, and land treatment




facilities.  For example, surface impoundment would have to maintain




enough freeboard to prevent overtopping of the dike by overfilling,




wave action, or storm event.  Restrictions would also be placed on




the management of wastes that could lead to the release of water



contaminants.  For example, the restrictions discussed under air




quality on the management of incompatible, reactive, or ignitable




wastes-would reduce the potential for damage to storage, treatment,




or disposal areas and for resultant releases of water contaminants.




Additional restrictions related to preventing water quality impacts




include a prohibition on placing bulk liquid wastes in a landfill un-




less the landfill has a functioning liner and leachate collection and




removal system, the liner is chemically resistant to the waste, and




the collection and removal system has a capacity sufficient to remove



all leachate produced.




     Following the Interim Status period, other changes under this




alternative would further reduce the potential for the release of




water contaminants and for the degradation of water quality.  As
                                    8-163

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discussed under air quality, these include requirements for making re-




pairs or taking remedial action on a timely basis and for adding pro-



visions to the contingency plan for controlling spills and unplanned




non-sudden dischages.  In addition, facility owners/operators not




covered by the Interim Status Standards would be required to prepare




an outline of and time estimate for completion of a groundwater dam-




age assessment program.  All owners/operators would also be required




to prepare an outline of and time estimate for completion of a




groundwater corrective action program to be implemented if the




groundwater damage assessment program indicates the need for such ac-




tion.  Requirements would also be added for groundwater monitoring at




land treatment facilities and at some tanks; however, groundwater




monitoring would be eliminated at incineration facilities.  The post-




closure care period and associated groundwater monitoring activities



would be extended from a time not to exceed 20 years to a period of




at least 30 years.




     On the other hand, leachate monitoring requirments would be



eliminated under this alternative, and groundwater monitoring samples




would have to be analyzed for fewer parameters characterizing water




quality.  Elimination of leachate monitoring would extend the time




before potential water quality problems could be detected and would




thus reduce the potential for the prevention of significant impacts




to water quality.  However, other revisions incorporated under this



alternative would off-set much of the potential for an increase in
                                    8-164

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significant water quality impacts.  These include increases in the




minimum number of monitoring wells; revisions in the siting of mon-




itoring wells and in the frequency of sample collection and analysis;




and requirements for groundwater damage assessment programs and




groundwater corrective action programs.  Reductions in the number of



water quality parameters being analyzed under this alternative would




increase the potential for some water quality problems to go undetec-




ted; however, in most instances the parameters still being analyzed




are considered to provide essentially the same level of protection as




those of the baseline regulations in detecting occurrences of ground-




water contamination.




     The surface water and groundwater human health and environmental




standards would also be eliminated under this alternative.  This




would reduce the potential for non-point preventing sources (e.g.,




surface impoundments, landfills, storage areas) at permitted




facilities from contributing to surface water and groundwater quality




degradation, as compared to the baseline regulations.  However, as



discussed in Section 7.1.5, these human health and environmental




standards would not have applied until after either a release of




water contaminants or a reduction in groundwater or surface water



quality violated the standard; they would not have been a means for




initially preventing the release of water contaminants and subsequent




water quality degradation.
                                   8-165

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     The surface water human health and environmental standard would




have required that all facilities be located, designed, constructed




and operated in such a way that any surface or subsurface discharge




from the facility into waters of the United States does not at any




time cause a violation of Water Quality Standards promulgated or ap-




proved under Section 303 of the Clean Water Act, or constitute a




spill of hazardous substances under Section 311 of the Clean Water




Act.  The groundwater hunan health and environmental standard would




have required that facilities be located, designed, constructed, and




operated in such a manner that they do not degrade any groundwater




such that an Underground Drinking Water Source anywhere outside the




facility property would at any time in the future be endangered**



Thus, under this alternative, water quality degradation would be




increased to the extent that releases from non-point sources exceed




the limits indicated above.  However, any facility causing water




quality degradation in excess of the requirements of the Clean Water




Act or the Safe Drinking Water Act would still be subject to the




provisions of those acts.



     As discussed under air quality, there would likely be some shift




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




ted wastes and the wastes excluded from regulation under this alter-




native compared to the methods that would have been used to manage




these wastes under the baseline regulations.  Such shifts would




change the types and quantities of water contaminants produced by the
*See Section 7.1.5 for the defintion of endangerment.



                                    8-166

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management of specific wastes and could at any locality either en-




hance the indicated potential for beneficial or adverse water quality




impacts.  All effluents and any localized degradation of water qual-




ity would have co be in compliance with all applicable requirements




(e.g., Clean Water Act, Safe Drinking Water Act, state standards).




     8.5.1.6  Public Health Impacts.  As discussed below, the regula-




tions under this alternative would have the potential for increasing




some of the public health benefits to be derived from the control of



hazardous wastes through the baseline regulations and would also have




the potential for reducing other public health benefits to be derived




from the baseline regulations.  Section 7.1.6 discusses public health




impacts under the baseline regulations.




     Slightly less total waste would likely be regulated under this




alternative than under the baseline regulations.  As discussed in




Section 8.5.1.1, a lesser quantity of toxic, infectious, and corro-




sive wastes would be regulated.  Those hazardous wastes excluded from




regulation would not have to be transported, stored, treated, or




disposed in accordance with the Subtitle C regulations.  Based upon




current practices and reported incidents, it is likely that much of




this waste would not be managed by methods that were environmentally




acceptable under the regulations.  Consequently, there would be a




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




nants from the management of these wastes, as compared to the



baseline regulations (see Section 8.5.1.4, 8.5.1.5, and 8.5.2.1).
                                   8-167

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There would also be a greater potential for the release of infectious




agents.  As a result, there would be less of a potential for prevent-




ing the occurrence of public health impacts associated with such con-




taminants (See Section 7.1.6).




     With regard to the hazardous waste that would still be regula-




ted, the requirements under this alternative would have the potential




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




the management of these wastes in various ways.  Some of the require-




ments (e.g., elimination of human health and environmental standards)




would result in an increase in the potential for the release of such




contaminants relative to the baseline regulations while others (e.g.,




the Interim Status Standards) would result in a decrease, as discus-




sed in Sections 8.5.1.4, 8.5.1.5, and 8.5.2.1.  Changes to public




health' impacts would be commensurate with such changes in the release



of air, water, and soil contaminants and infectious agents.  These




would be both increased and reduced public health benefits to be




derived from the regulation of these wastes relative to the baseline




regulations.




     Increased public health benefits could further be derived from




additional requirements imposed under this alternative.  Facility




permits would be reviewed at least once every 5 years rather being




issued for the projected life of the facility as under the baseline




regulations.  Owners/operators of facilities managing hazardous




wastes would have to turn over records of waste disposal locations to
                                   8-168

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the local land authority upon closure of the facility.  The owner of




the property on which a disposal facility is located would also be



required to record a notation on the property deed (or equivalent




instrument) to, in perpetuity, notify any potential purchaser both




that the land has been used to manage hazardous waste and that the




land is subject to use restrictions.  These restrictions include




prohibitions against any use of the property that disturbs the integ-




rity of the final cover, liners, any other components of the contain-




ment system, and the monitoring system unless it can be demonstrated




that any such disturbance would not result in an increase in the




potential hazard to human health and the environment.  These require-




ments could further help prevent future public health catastrophes




such as that which occurred at Love Canal in Niagara Falls, New York




(see Section 7.1.6).



     Additional restrictions would be placed on the disposal of




hazardous uranium and phosphate surface mining and beneficiation




wastes.  These wastes are identified as hazardous under the radio-



activity criteria of this alternative.  Restrictions would be placed




on using these wastes as fill around or under habitable structures.




The wastes would also be prohibited from being incorporated into any




building materials that are of potential use for the construction of




habitable structures.  Both uses take place in the current, unregula-




ted situation.  These requirements would thus reduce the potential
                                    8-169

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for such disposal of these wastes to cause adverse health impacts by




releasing radioactive emissions (radium 226 and its decay products)




into habitable areas and dwellings.




     Elimination of the requirement that contingency plans must




include an outline of a program for familiarizing employees with em-




ergency procedures and for drills on these procedures could reduce




the potential for preventing public health impacts in the event of an




emergency situation at the facility; however, this would be off-set




by other, previously indicated changes in contingency plans.  Elimi-




nation of the need to implement the contingency plan when there is a




discharge that threatens human health only within the facility, but




not outside the facility, would reduce the potential for preventing




adverse impacts to facility employees.




     8.5.2  Secondary Impacts.  The major changes in secondary




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




result of implementation of this alternative are discussed in the




following sections.  These changes would result primarily from the




net reduction in the quantity of waste that would be subject to re-




gulation; the enactment of more stringent environmental requirements




with regard to the storage, treatment, and disposal of hazardous




wastes during the Interim Status period; the modification of some re-




quirements for managing wastes following the Interim Status period;




the enactment of more stringent requirements for tracking manifested




waste shipments; the enactment of more stringent environmental
                                    8-170

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requirements with regard to the storage, treatment, and disposal of




hazardous 'special wastes'; and from modified costs to generators and




costs associated with hazardous waste transport, storage, treatment,




and disposal as a result of these revised requirements.




     8.5.2.1  Physiography and Soil Impacts.  The regulations under




this alternative would have the potential to cause changes affecting




physiography and soils, as compared to the baseline regulations.




These changes would lead to localized beneficial and adverse impacts




to physiography and soils, as compared to the baseline regulations.




     The waste removed from regulation under this alternative (e.g.,




hazardous waste materials used as soil conditioners) would not have



to be transported, stored, treated, or disposed in accordance with




the Subtitle C regulations.  Based upon current practices and re-




ported incidents, it is likely that much of this waste would not be




managed by methods that were environmentally acceptable under the re-




gulations.  To the extent this occurs, the potential for preventing




adverse impacts to soils would be reduced relative to the baseline




regulations.  Section 7.2.1 describes the types of impacts to soils




that could occur from such current methods and practices.




     With regard to the hazardous waste regulated under this alterna-




tive, the requirements under this alternative would have the poten-




tial for affecting impacts to physiography and soils in various ways.




Changes that could potentially have significant effects are discussed



below.
                                   8-171

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     The revised requirements would affect the release of air and




water contaminants as described in Sections 8.5.1.4 and 8.5.1.5.




Changes in impacts to soils would be commensurate with the changes in




the release of such contaminants, as discussed in Section 7.2.1.




There would be localized instances of both increased and reduced soil




contamination, as compared to the baseline regulations.




     With regard to hazardous 'special wastes', more total land could




be required for waste management under this alternative than under




the baseline regulations.  There would likely be more off-site land




use; there would be an indeterminable change in on-site land use (see




Section 8.5.2.5).  Increased land requirements, especially off-site




requirements, would result in a greater potential for physical




impacts to occur to soils and physiography.  Potential impacts from




increased facility construction would be essentially the same as




those described in Section 7.2.1.



     Disposal of the large volumes of hazardous 'special wastes' that




could be brought under control of the full set of Section 3004 re-



quirements could create a significant demand for low permeability




clays.  Such a demand could be especailly significant in areas having




a high density of such hazardous waste generators.  Local clay sup-




plies in such areas may not be sufficient to meet the demand.  Even




where sufficient clays are available, their extraction would result




in severe alternation of local topography.
                                    8-172

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       With regard to other hazardous waste, less total land, off-




site plus on-site, could be required for waste management under this




alternative than under the baseline regulations.  In the case of 13




percent off-site shipment of hazardous manufacturing wastes, there




could be more off-site land use and less on-site land use.  In the



case of 25 percent off-site shipment, there could be less off-site




land use and more off-site land use.  Changes in impacts to soils and




physiography would be directly related to these changes in land re-




quirements; however, changes in off-site land use would likely cause




greater impacts than changes in on-site land use.




     8.5.2.2  Biological Impacts.  The regulations under this



alternative would have to potential for both increasing and reducing




some of the benefits to flora, fauna, and ecological systems that




would be derived from the control of hazardous waste through the




baseline regulations.  Section 7.2.2 discusses biological impacts




that would occur under the baseline regulations.




     Land requirements for facility construction and operation and




for conjunctive developments would be modified under this alternative




as summarized above.  As a result, the potential for impacts to




flora, fauna, and ecological systems from land disturbance would be



accordingly modified.




     Existing vegetation would be destroyed on additional lands dis-




turbed by construction and operation of hazardous waste management



facilities and conjunctive developments.  Present plant succession




would .cease on such lands.  Following rehabilitation of the site






                                     8-173

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after closure of the facility, the plant community on the disturbed




areas would likely differ in species composition and diversity.




These construction and operational activities could also result in




the direct destruction of animal habitat.  Some of this destruction




would be permanent; other areas would be impacted only temporarily




and would, over a period of time, recover in value as a habitat.  How-




ever, the habitat and, consequently, the widlife species composition




following such recovery might be different from that which existed




prior to disturbance of the area.  In addition, the direct destruc-




tion of some wildlife could also result from activities which




excavate, bury, overturn, clear, or grade large areas of previously




undisturbed terrestrial habitat.  On lands excluded from hazardous




waste management activities under this alternative, flora, fauna, and




ecological systems would not be subject to such impacts, as compared




to the baseline regulations.  In both cases, changes in off-site land




use would cause greater impacts than changes in on-site land use.




     These modification to the biological environment would be off-



set by other changes that could occur under this alternative.  Less




total waste would likely be regulated under this alternative than




under the baseline regulations.  As discussed in Section 8.5.1.1, a




lesser quantity of toxic, infectious, and corrosive wastes would be




regulated.  Those hazardous wastes excluded from regulation would not




have to be transported, stored, treated, or disposed in accordance



with the Subtitle C regulations.  Based upon current practices and




reported incidents, it is likely that much of this wastes would not






                                   8-174

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be managed by methods that were environmentally acceptable under the




regulations.  Consequently, there would be a reduced potential rela-




tive to the baseline regulations for preventing the release of air,




water, and soil contaminants from the management of these wastes (see




Section 8.5.1.4, 8.5.1.5, and 8.5.2.1).  There would also be a great-




er potential for the release of infectious agents.  As a result,




there would be a reduced potential for preventing the occurrence of




biological impacts associated with such contaminants (see Section




7.2.2).  In addition, previously indicated changes in the off-site




transport of hazardous wastes would lead to commensurate changes in




the number of animal road kills.



     With regard to the hazardous waste that would still be regula-




ted, the requirements under this alternative would have the potential




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




the management of these wastes in various ways.  Some of the require-




ments (e.g., elimination of human health and environmental standards)




would result in an increase in the potential for the release of such




contaminants relative to the baseline regulations while others (e.g.,




the Interim Status Standards) would result in a decrease, as discus-




sed in Sections 8.5.1.4, 8.5.1.5, and 8.5.2.1.  Changes in impacts to



bioloigcal systems would be commensurate with these changes in the




release of air, water, and soil contaminants and infectious agents.




These would be both increased and reduced benefits to the bioloigcal



environment to be derived from the regulation of these wastes




relative to the baseline regulations.





                                    8-175

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     It should be noted, however, that due to changes in wastes being




regulated and in requirements for management of regulated wastes,




there could be shifts in the methods used to treat/dispose the wastes




as described in Section 8.5.1.4.  The potential for impacts to the




biological environment would be modified to the extent of any such



shift.




     The bioloigcal environment could derive additional benefits from




the requirement that facility permits be reviewed at least once every




5 years rather being issued for the projected life of the facility as




under the baseline regulations.  Elimination of the requirements that




contingency plans must include an outline of a program for




familiarizing employees with emergency procedures and for drills on




these procedures could increase the potential for biological impacts




to occur in the event of an emergency situation at the facility; how-



ever, this would be off-set by other indicated changes in contingency




plans.  Elimination of the requirements that after closure, all




facilities must be secured such that any remaining hazardous wastes



cannot be contacted by animal life, would have little practical ef-




fect since the baseline regulations would not truly prvent burrowing




animals and animals foraging on plants in the site area from coming




into contact with such waste.




     8.5.2.3  Social Impacts




     Demographic Impacts.  With regard to generators of hazardous




'special wastes,1 increased costs under this alternative could lead




to some additional closings or relocations of plants and operations,






                                   8-176

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and this could lead to additional population shifts as described in




Section 7.2.3.1.  With regard to generators of other hazardous



wastes, lesser increases in costs under this alternative could lead




to fewer plant closings or relocations, and this could lead to fewer




population shifts.  Some closings could, however, occur earlier under




this alternative due to the requirements of the Interim Status




Standards.




     In addition, there could be both an increase in the number of




construction workers needed at facilities managing hazardous 'special




wastes' due to any increased amount of facility modification and




construction and a decrease in the number of construction workers




required at facilities managing other hazardous wastes due to any




lesser amount of necessary facility modification and construction.




There could also be an increase in the number of personnel required



for hazardous wastes management activities at facilities managing




'special wastes' due to the more stringent operational requirements.




There could be a decrease in the number of personnel required for



hazardous waste management activities at facilities managing other




hazardous wastes due to decreases in the quantity of such wastes




being regulated.  There could also be an overall decrease in the




number of personnel required to administer and enforce the regula-




tions due to reductions in both the quantity of hazardous wastes




being regulated and the number of generators, disposers, and
                                    8-177

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permittees being regulated.  Again, necessary personnel would likely




be needed earlier under this alternative due to the requirements of




the Interim Status Standards.  Population shifts could occur in




response to changed personnel requirements as discussed in Section




7.2.3.1.  Any such shifts would be expected to be small on a national




scale; however, there could still be localized instances of




relatively large influxes of workers, particularly for hazardous




waste management facilities located near very small towns, or of




relatively large outfluxes of workers, especially in the case where a




plant being closed constituted the primary source of employment in an




area.




     Social Conditions.  As discussed in Section 8.5.1.6, there would




be both increased and decreased public health benefits to be derived




from this alternative relative to the baseline regulations.  The




indicated increases (decreases) in public health benefits would




accordingly provide increased (decreased) social benefits as dis-




cussed in Section 7.2.3.2.  Resultant changes in chronic and acute




health effects would correspondingly modify the social and economic




costs associated with such effects, e.g., increased mortality, birth




defects, lowered productivity, lost wages.



     The indicated changes in the potential for population shifts




would correspondingly modify the impacts associated with such shifts.




As discussed in 7.2.3.2, any large, rapid, population influx could
                                    8-178

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cause inflation, strains on the existing infrastructure, social ten-




sions, changes in daily living patterns, and increased physical and



mental disorders.  Any large, rapid, population outflux could cause




problems in maintaining the existing infrastructure, deflation, addi-




tional unemployment, social stress, changes in daily living patterns,




and increased mental and physical health problems.




     Public opposition to the siting and construction of hazardous




waste management facilities could be reduced by the requirement for




permits to be reviewed at least once every 5 years rather than not at




all and by the increase in the period specified for post-closure




care.  With regard to facilities managing hazardous wastes other than




'special waste,1 public opposition to such facilities could be




further reduced by the need for fewer of these facilities.  With




regard to facilities managing hazardous 'special wastes,1 public




opposition to such facilites could be reduced by the more stringent




environmental requirements under this alternative.  However, any




opposition that occurs could be exacerbated by possible increases in



requirements for such facilities.  The additon of the Interim Status




Standards could also reduce opposition to some existing facilities.




     Indicated changes in the contruction of hazardous waste manage-




ment facilities and in the off-site transport of hazardous wastes




could modify other social effects.  The indicated increases (decreas-




es) in facility contruction would increase (decrease) the potential
                                    8-179

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for noise impacts, aesthetic impacts, land use impacts, water use




impacts, and pressures on existing infrastructures that could be




associated with such facilities.  Indicated increases (decreases) in




the transport of hazardous wastes would increase (decrease) the




potential for vehicular accidents.




     8.5.2.4  Hazardous Waste Management Facility Capacity.




     Process Capacity.  Less hazardous waste would be subject to Sub-




title C requirements under this alternative than under the baseline




regulations.  However, increased quantities of hazardous 'special




wastes' and reduced quantities of other hazardous wastes could be




shipped off-site for treatment/disposal under this alternative.




     As discussed in Section 7.2.4.1, under the baseline regulations




there would potentially be sufficient off-site capacity available on




a nationwide basis in 1980 to handle the regulated hazardous manufac-



turing wastes shipped off-site, both with and without growth in




existing capacity. Also, there would potentially be sufficient off-




site capacity on a nationwide basis in 1984 to handle the regulated




hazardous manufacturing wastes shipped off-site in the care of 13




percent off-site shipment, both with and without growth in existing




capacity.  However, in the case of 25 percent off-site shipment in



1984, there would potentially be a nationwide shortfall of 2.6 mil-




lion metric tons of environmentally adequate capacity for treating/




disposing hazardous manufacturing wastes, based upon the specified



growth in existing capacity.  Without any growth in existing
                                    8-180

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environmentally adequate capacity, this shortfall could be 4.9 mil-




lion metric tons.  As indicated, data are not available to extimate




any potential for shortfalls in environmentally adequate on-site pro-




cess capacity for regulated hazardous manufacturing wastes.




     Consequently, under this alternative there would also poten-



tially be sufficient off-site capacity on a nationwide basis to




treat/dispose regulated hazardous manufacturing wastes shipped off-




site in 1980 and also in 1984 in the case of 13 percent off-site




shipment.  In the case of 25 percent off-site shipment in 1984, there




would be a reduction in the potential shortfall in off-site capacity.




As a result, fewer permitted off-site facilities could be required in




this latter case under this alternative as compared to the baseline




regulations.  Similarly, under this alternative there would also be




reductions in the potential for any shortfall in on-site capacity




necessary for treating/disposing regulated hazardous manufacturing




wastes.




     With regard to hazardous 'special waste,'  there would be an



increased potential for shortfalls in both environmentally adequate




on-site and off-site capacity in 1980 and 1984.  The increased poten-




tial for shortfalls in on-site capacity would result from increased




facility closings due to requirement that facilities managing special




wastes comply with all Section 3004 requirements rather than a




limited portion of such requirements.  The increased potential for



shortfalls in off-site capacity would result from likely increases in
                                   3-181

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Che quantity of wastes being sent off-site; however, any increases in




off-site shipments would also off-set some of the potential for




increased shortfalls in on-site capacity.




     Section 7.2.4.1 discusses other factors that could either lead




to shortfalls or exacerbate the size of any estimated shortfall in




both on-site and off-site process capacity, especially on a localized




basis.  Furthermore, the wastes removed from regulation under this




alternative would still have to be treated/disposed, both on-site and




off-site.  While such wastes could be treated/disposed in non-




permitted facilities, their management could increase the potential




for an overall shortfall in available capacity;  however, any resul-




tant shortfall would be less than that under the baseline regula-




tions.  The Interim Status Standards could also lead to earlier




closings of some facilities and thus increase the potential for




shortfalls during the first few years after implementations of the




Subtitle C regulations; however, the reduction in the generator limit




would act to off-set this.




     Physical Capacity.  Based upon the methodology and assumptions




disucssed in Section 7.2.4.2, relative to the baseline regulations




there could be an increase in the total (regulated plus uneregulated)




hazardous manufacturing wastes sent off-site during the period from




1980 through 1984, assuming 13 percent shipment off-site in 1984, and




there could be a decrease in the total hazardous manufacturing wastes



sent off-site during this period, assuming 25 percent shipment off-




site in 1984.






                                    8-182

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     Consequently, increased land area could be committed to off-site




management of hazardous manufacturing wastes during this period in




the case of 13 percent off-site shipment and less land area could be




committed to off-site management of hazardous manufacturing waste




during this period in the case of 25 percent off-site shipment.  In




the former case, after 1984 there could be an increase in the land




area required off-site annually compared to total requirements under




the baseline regulations.  In the latter case, after 1984 there could




be a decrease in the land area required off-site annually compared to




the total requirements under the baseline regulations.  In all




instances there could be commensurate changes in on-site land




requirements.




     8.5.2.5  Land Use Impacts.  With regard to those hazardous




wastes other than 'special wastes,' less total land, off-site plus




on-site, would be required for the construction of any storage,




treatment, and disposal facilities needed under this alternative and




for such conjunctive developments as construction of roads, power



lines, and pipelines.  Less additional land would be required since




fewer wastes would have to be sent to permitted facilities; the waste




removed from regulation could use existing facilities or other



facilities that were not adequate under the baseline regulations.




However, as indicated in Section 8.5.2.4, in the case of 13 percent




off-site shipment there would be more total hazardous manufacturing



wastes (those regulated plus those removed from regulation) sent
                                    8-183

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off-site than there would be in the similar case under the baseline




regulations.  Thus, while less total land would be required, there



could be more off-site land use and less on-site land use for hazard-




ous manufacturing wastes in this case.  In the case of 25 percent




off-site shipment, there would be less total hazardous manufacturing




wastes sent off-site than there would be in the similar case under




the baseline regulations and, thus, there could be less off-site land




use and more on-site land use.




     It should be noted that while shifts to on-site land use could




reduce off-site land requirements in the short term, such shifts




could also accelerate the exhaustion of the relatively limited on-




site physical capacity and could result in increased pressures for




off-site facilities in the long term.  Furthermore, the reduced




potential under this alternative for increases both in resource con-



servation and recovery and in treatment practices leading to volume




reduction (e.g., incineration) of these hazardous wastes would also




provide a lesser potential for reducing total land requirements, both




on-site and off-site, in the long term.



     With regard to hazardous 'special wastes,' more total land could




be required under this alternative for the management of all (regu-




lated and unregulated) hazardous special wastes.  While a lesser




quantity of hazardous special wastes would be regulated, more land




(on-site plus off-site) could be required for construction of the



permitted facilities necessary for the management of regulated wastes




under this alternative and for conjunctive developments.  Those






                                    8-184

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wastes removed from regulation could continue to use existing facili-




ties or other facilities that were not adequate under the baseline




regulations.  There would likely be more off-site land use.  Changes




in on-site land use would depend on changes in the portion of wastes




sent off-site and on changes in land requirements for individual



facilities managing wastes on-sites.




     With regard to all hazardous wastes, existing land uses would




not change on lands excluded from hazardous waste management under




this alternative; however, there could be localized changes in land




use from any additional shifts to off-site management from on-site




management or to on-site management from off-site management.  To the




extent that the management of wastes excluded from regulation under




this alternative would result in additional land being contaminated




through environmentally inadequate practices, there would be off-




setting adverse impacts to existing land uses.  Section 7.2.5




describes the types of impacts that could occur.




     Existing land uses would, however, cease, either permanently or




temporarily, on all land converted to hazardous waste management




uses.  Following closure of hazardous waste management facilities and




any necessary post-closure care, the land used for the facility could




be available for new or, in some cases, previously existing uses.




However, this alternative eliminates the requirement that all facili-




ties must be designed such that the land is amenable to some accept-



able use so that perpetual isolation and care to maintain isolation




are not required.  Thus, less land could be available for future





                                    8-185

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use under this alternative than under the baseline regulations.  On




the other hand, this alternative eliminates the prohibiton against




using sites at which hazardous wastes remain after closure (e.g.,




landfills) for rcoidential, agricultural, or other purposes which




disturb the integrity of the closed facility.  All such uses would be




allowable under this alternative providing that it can be demon-




strated that any disturbances to the integrity of the final cover,




liner, any other components of the containment system, and the moni-




toring system would not result in an increase in the potential hazard




to human health or the potential for environmental contamination.




This alternative would also affect future use of the land by requir-




ing that the owner of the property on which a disposal facility is




located must record a notation on the property deed (or equivalent




instruments) that would in perpetuity notify any potential purchaser




both that the land has been used to manage hazardous waste and that




the land is subject to the use restrictions noted above.




     8.5.2.6  Water Use Impacts.  The potential for the degradation



of groundwater and surface water quality would be modified under this




alternative as indicated in Section 8.5.1.5.  There would be instan-




ces of both reduced and increased localized improvements in water




quality, as compared to the baseline regulations.  To the extent that




less degradation of water quality would result in an increased supply




of surface water or groundwater being available to all consumers in




the water use area, there would be an additional supply of ground-




water or surface water potentially available to such consumers and





                                    8-186

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fewer restrictions on Che productive use of such surface water and




groundwater supplies.  Localized instances of increased water quality




degradation would have the opposite impact.




     Fewer permitted facilities would be required under this alterna-




tive for the management of hazardous wastes other than 'special



wastes.'  Less water would thus be required for these permitted




facilities.  Reductions in water use would, however, be off-set to




the extent that water would still be consumed in the management of



those wastes removed from regulation.  Fewer permitted facilities




could also be required for the management of hazardous 'special




wastes.1  However, the more stringent requirements under this alter-




native could increase the quantity of water required by individual




facilities.




     8-.5.2.7  Resource Conservation and Recovery.  The major changes




in resource conservation and recovery would result from the previous-




ly indicated modifications in the wastes being regulated and in costs




to hazardous waste generators and costs associated with hazardous




waste transportation, storage, treatment, and disposal.  As discussed




in Section 8.5.1.2, these changes could provide an increased incen-




tive for some generators of hazardous 'special wastes' to further




modify their processes or operations so as to reduce and/or change




the types and quantities of hazardous wastes generated and to in-




crease the re-use of the wastes that were generated.  However, these



changes would provide less of an incentive for generators of other
                                   8-187

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hazardous wastes to modify processes or operations so as to enable

increased recycling of hazardous wastes as process feedstocks, to

reduce the quantities of hazardous wastes generated by specific

processes or operations, or to change the nature of wastes produced.

Chapter 5 presents examples of the potential for increased resource

recovery from and recycling of hazardous wastes.

     This alternative would provide a further incentive for all

generators to recycle, re-use, or recover hazardous waste materials.

All hazardous waste materials that are used, re-used, or processed

for energy recovery or that are stored for such purposes would be

excluded from regulation under this alternative,* but would be sub-

ject to Subtitle C requirements under the baseline regulations.  For

example, waste oils or solvents incinerated for energy recovery would

not be-regulated.  Similarly, all hazardous waste materials, except

waste oils, that are used or re-used in a manner constituting dispo-

sal or that are being stored for such purposes would be excluded from

regulation under this alternative.t  For example, hazardous materi-

als used for road construction or as a soil conditioner or as a

de-icing agent on roads would not be regulated.  Thus, generators

would have an increased incentive to use or re-use such wastes rather

than to dispose them.
*However, it should be noted that EPA is planning to list waste
 materials that would still be regulated if used for such purposes.
     is planning to list additional waste materials that would
 still be regulated if used in such a manner.
                                    8-188

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     8.5.2.8  Energy Use.  Energy use would be impacted under this




alternative by changes in facility construction, facility operation,




hazardous waste transport, resource conservation and recovery, and




energy production.




     With regard to hazardous 'special wastes,1 the additional facil-




ity modification and construction that could be necessary for the




management of such wastes under this alternative would result in




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




struction of new facilities under this alternative due to the more



stringent requirements directed towards making these facilities more




environmentally secure.  There would also be increased energy use




associated with the more stringent requirements for operation and




closure of these facilities, as discussed in Section 7.2.8.  The




requirements of the Interim Status standards along with the addi-




tional 10-year period over which post-closure care could be required,




would further increase the energy use associated with such wastes.




Increase in energy use associated with any additional transport of



hazardous "special wastes" would depend upon such factors as shifts




in the portion of wastes managed on-site and off-site and changes in




transport distances.  The reduction in the quantity of such wastes




being regulated would, however, off-set some of these increased in




energy use.  Furthermore, indicated changes in resource recovery




activities could also lead to some net energy savings.



     Many 'special waste1 generators are energy producers (e.g., oil




and gas drilling operations).  Due to the more stringent requirements






                                    8-189

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and increased costs associated with the management of these wastes,




there could potentially be reductions in energy production.




     With regard to other hazardous wastes, the lesser amount of




facility modification and construction that would be necessary for




the management of such wastes would result in a decrease in energy




use.  The reduction in the quantity of such wastes being regulated




would also reduce energy use associated with facility operations, as




discussed in Section 7.2.8.  However, the requirements of the Interim




Status Standards along with the lengthened post-closure care period




could off-set some of this decrease in energy use.  Reductions in




energy use could also result from any reductions in the average dis-



tance over which these wastes could be transported.  Furthermore,




indicated changes in resource recovery and recycling activities could




lead to a lesser potential for net energy savings to result from such



activities.




     8.5.2.9  Impacts to Special Interest Points.  To the extent that




the requirements of the Interim Status Standards and the more strin-



gent regulation of hazardous 'special wastes'  would reduce the dis-




turbance, destruction, or intrusion upon special interest points,




there would be a commensurate reduction in such adverse effects as



discussed in Section 7.2.9.  However, the exclusion of additional




wastes from regulation under this alternative would reduce the poten-




tial for such beneficial effects.
                                    8-190

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     Any additional lands, especially off-site lands, that would be




disturbed by the requirements for facility construction and associ-



ated conjunctive developments under this alternative would increase




the pocential for the disturbance and/or destruction of such special




interest points as sites of aesthetic, archaeological, historical,




paleontogical, or recreational value.  As indicated, more off-site




lands could be required for the management of hazardous 'special




wastes' while less off-site lands could be required for the manage-



ment of other hazardous wastes.
                                   8-191

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9.0  MITIGATING MEASURES AND ADVERSE IMPACTS WHICH CANNOT BE AVOIDED




     In a sense, the Subtitle C regulations are themselves a miti-




gating measure acting to reduce the adverse environmental impacts of




uncontrolled storage and disposal of hazardous wastes.  Although




these beneficial impacts are not discussed in this section, it is




recognized that they far outweigh any adverse environmental impacts




which may result from the regulations.  The major adverse effects




which would result from the regulations would be economic.  These are




discussed in the Integrated Economic Impact Assessment of Hazardous




Waste Management Regulations (Regulatory Analysis Supplement).  Most




non-economic, adverse, environmental impacts associated with these




regulations could be mitigated by making the corresponding portions




of the regulations more strict (i.e., increasing the number of wastes




defined as hazardous, decreasing the allowable permeability for soil




liners in landfills, etc.).  Many of these types of changes are




addressed in the Alternatives Chapter, Section 8.3 (Greater Degree of




Protection) and Section 8.5 (Phase 1 Alternative).  Any such reduc-




tion in adverse environmental effects would, however, be accompanied




by increased economic costs.




     The major, non-economic adverse effects of these regulations




would primarily be the continuation of impacts presently occurring




and may be grouped into two categories.  One group of impacts




involves the redistribution of hazardous wastes and their associated




environmental problems (which would be at least partially dimin-




ished).  This would occur as existing treatment and disposal




                                9-1

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sices which do not meet Che sCandards (including many on-site




facilicies) close down and Che wastes are senC elsewhere.  The second




group of impacts arise from areas not covered or specifically




excluded from Che regulations.  Again, any adverse impacts resulting




from such exclusions would be continuations of existing  impaccs and




would not be directly caused by the regulations.




9.1  Redistribution of Hazardous Wastes




     When the regulations become effective, they could force the




closure of a large number of facilicies which currently accept




hazardous wastes.  A recent EPA study (U.S. Environmental Protection




Agency, 1977c) indicated that environmental contamination from




existing landfill sites may be more widespread than previously




realized.  Out of 50 randomly chosen sites which had never before




been suspected of leaking and of which 32 were already being



monitored, 43 sices were determined to be causing local groundwater




degradation, 26 to such a degree that one or more EPA drinking water




standards were exceeded.  Poor groundwater quality was noted in six




of the remaining sites, but could not be definitely linked to the




disposal operation.  Closure of a large portion of existing disposal




sites, primarily on-site facilities, could create an immediate and




potentially severe shortfall of facility capacity.  Since the total




capacity of all existing sites is not known, it is difficult to




determine the ultimate impact of this relocation of wastes.  However,




it is essential that situations such as occurred in New Jersey do not
                                9-2

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recur on a national scale.  Enactment of strict environmental




regulations in New Jersey forced the closure of the last legal land




disposal site for chemical wastes in 1976.  Since then, the costs of




acceptable disposal methods have increased tremendously, and many




companies have been faced with the alternatives of paying much higher




treatment costs or using illegal disposal methods.  The result has




been a series of indiscriminate dumping of hazardous wastes through-




out New Jersey and in neighboring states (Richards, 1978).




     Such a situation may be mitigated by one method or a combination




of several methods.  The one method, while temporary, would be to




delay the closing of unacceptable facilities until there were accept-




able alternative treatment, disposal, or storage methods for all of




the wastes presently going to each facility.  This could be accom-




plished by delaying action on  permit application by such facilities




for.several years.  The advantage of such a strategy would be that,




since these sites already have large amounts of waste that must at




some point be cleaned up, it would not create any significant new




problems to continue using them for a short period of time.  These




sites should be prohibited from accepting any wastes from new sources




and every effort should be made to relocate the wastes presently




going to the sites as quickly as possible, but the consequences of




immediately closing the site without providing acceptable alterna-




tives could lead to the creation of new problems in previously




uncontaminated areas.
                               9-3

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     Volume reduction, resource recovery, and recycling of wastes are




other measures which would help mitigate the problems of finding more




disposal capacity.  These are partially addressed in the regulations




by the mandate that "where practical, disposal of hazardous wastes




shall be avoided and alternatives such as resource recovery, reuse,




or other measures of recycling shall be employed."  As a further




method of coping with the short-term shortfall of capacity, this




requirement could be extended to include treatment for volume




reduction.




     A third measure to cope with the shortfall of capacity is to




provide assistance for the rapid expansion of existing facilities to




the greatest extent possible.  Such assistance could take the form of




guaranteed loans, grants, large-scale demonstration projects, and




provision of technical expertise.




     In addition, it would undoubtedly be necessary to site and




construct facilities in order to meet the increased demands for




treatment/disposal.  This process could be greatly expedited by




effective cooperation between the permitting agencies (state or




Federal), waste generators, and disposers in order to compile and




evaluate information on needs, quantities and types of wastes




generated, available transportation, and location of suitable




disposal areas.  Information and advice should be solicited from




the state geologic surveys, local offices of the Soil Conservation




Service, Fish and Wildlife Service, and other pertinent agencies
                                 9-4

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early in the siting search.  In addition, experience in states such




California, Illinois, and New Jersey has indicated that there is




substantial public resistance to the siting of new facilities, re-




sulting in long delays and considerable expense. It is possible that




a well-conceived public information program on both the  national and




local levels could help alleviate this problem.  Points that could be




emphasized are the required procedures to limit groundwater and air




pollution, the necessity of disposing of the waste in an acceptable




manner, and the physical and geologic conditions which make a par-




ticular location a suitable site.  It might also be advisable to




prohibit the construction of new plants which would generate signifi-




cant quantities of hazardous wastes unless either an acceptable local




hazardous waste disposal facility has sufficient excess capacity to




handle the new wastes, or unless such a facility could and would be




constructed in conjunction with the new generator.  This requirement




could help to off-set the public opposition to siting disposal




facilities by providing the economic benefits of additional local




employment and a larger tax base due to the presence of the generat-




ing facility.  This requirement could also reduce transport




distances, result in lower costs, and reduce potential for spills




resulting from transport of hazardous wastes.



     Relocation of waste shipments from existing environmentally




unacceptable disposal sites to acceptable sites may produce some




local impacts in the vicinity of the new sites.  Since the
                                9-5

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regulations require strict compliance with all state and Federal laws




regarding air and water quality, these impacts should be relatively




minor.  However, the creation of large facilities in remote areas (as




may be required by public opposition or by the location of suitable




geologic conditions) could result in the loss of potentially valuable




habitat, range lands, or prime agricultural lands.  In addition, some




degree of socio-economic impact could occur as a result of the added




manpower and support facilities which may be required to construct




and operate the disposal facilities.  The Integrated Economic Impact




Assessment of Hazardous Waste Management Regulations (Regulatory




Analysis Supplement) addresses the latter types of impacts; coordina-




tion of planning efforts with the Fish and Wildlife Service, and the




USDA Soil Conservation Service should help mitigate the former.  An




increased potential for hazardous spills and vehicle emissions is




also expected to result due to the necessity to transport more wastes




off-site and to the probable longer distances to acceptable disposal




facilities.  Air emissions may also result from the construction and




operation of new resource recovery facilities, though, again, these




emissions are required to be within all applicable air standards.




     Impacts could occur to water quality as a result of discharges




of treated effluents from waste treatment facilities.  Such discharg-




es would have to meet all applicable water quality standards includ-




ing those promulgated under the Clean Water Act (P.L. 92-500, as




amended), and under the various state laws, and would have to be
                                9-6

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approved by Che permitting agency.  However, even though a discharge




meets all applicable standards, it could still reduce receiving water




quality up to the maximum allowable limit.  Since this limit was




picked to ensure adequate protection of both environmental and human




health, such an impact should be minimal, though it may involve some




loss of value to local water users.  However, there are many




potentially hazardous constituents of these wastes for which no




standards have yet been promulgated.  This may be due to lack of




adequate substantiation of suspected human health effects, or to lack




of information on tolerable levels to ensure the absence of chronic




health effects.  In addition, it is possible that some potentially




harmful properties of these wastes are not even suspected at this




time.  In this respect, waste discharges could conceivably meet all




applicable standards and still contribute to environmental




degradation with potential human health effects.  It should be




emphasized that such effects are now occurring to a much greater




degree without the controls which would be implemented by the




proposed regulations. They could be further mitigated by requiring




that all waste streams be sent to permitted treatment/disposal




facilities.




     In spite of any local increase in impacts which might occur, the




net effect of the relocation of hazardous waste disposal operations




to acceptable facilities in other areas would produce a marked




decrease in the overall adverse environmental impact of the wastes.
                                  9-7

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     An additional group of adverse impacts would be associated with




increased paperwork requirements and the enlargement of the govern-




ment bureaucracy to deal with those regulations.  It is estimated




that under the baseline regulations about 270,000 to 300,000




generators could be required to notify EPA following promulgation of




the regulations.  An additional 29,000 facility permit applications




could also require processing.  Further, monitoring reports and




annual summaries of receipts of manifested wastes could produce up to




400,000 reports per year.  Manpower to deal with such requirements is




not presently available in either EPA, or in most state governments.




The regulations could therefore require the establishment of new




government jobs and procedures which could both increase the size and




unwieldiness of many bureaucratic systems and the size of government




payrolls.  Reduced notification or reporting requirements would,




however, weaken the effectiveness of control over hazardous wastes.




9.2  Impacts Unaffected by the Regulations




     9.2.1 • Siting.  The baseline regulations prohibit locating




hazardous waste facilities on active fault zones, in wetlands, on




100-or 500-year flood plains, in the recharge zone of sole source




aquifers, or in the critical habitat areas of endangered species,




with certain exceptions.  In addition, the regulations require that




landfills, surface impoundments, and landfarms be located, con-




structed, and operated so as to prevent landslides, slumping, and




erosion.
                                 9-8

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However, other siting considerations that could have or that could




cause adverse impacts are not addressed.  These include siting




facilities in areas prone to subsidence or to geothermal activity; in




areas on migration pathways or rangelands of important regional




(though not necessarily endangered) species; or in areas of prime




agricultural lands.  Although formally increasing the permit review




process to include state geologic surveys, the Fish and Wildlife




Service, and local soil conservation services may not be desirable




due to resultant increased paperwork and processing times, there




should be some means of ensuring coordination with these agencies in




order to assure that all potential problems have been considered.




The information requirements for permit applications could also be




expanded to include ecological data for the site area that identifies




any local migratory pathways and the occurrence of any browsing or




burrowing animals wh.ich could obtain access to the material stored or




disposed of at the site.




     As discussed previously, i.t may -also be desirable to examine




siting considerations before beginning the construction of major new




facilities generating hazardous wastes.  This should be studied in




light of both the local environmental impacts, as well as the




location and capacities of potential treatment/disposal facilities.




     In any case, all siting of hazardous waste facilities would also




be subject to a number of additional constraints, besides those cited




in the regulations.  These include restrictions promulgated under the




following laws protecting fish, wildlife, and natural resources:




                                9-9

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     •  Endangered Species Act of 1973 (16 U.S.C. 1531-1543)

     •  Federal Aid in Wildlife Restoration Act (16 U.S.C 669)

     •  Protection of Wild Horses and Burros (16 U.S.C. 1331-1340)

     •  Fish and Wildlife Act of 1956 (16 U.S.C. 742-754)

     •  Fish and Wildlife Coordination Act (16 U.S.C. 661-667)

     •  Forest and Rangeland Renewable Resources Act (16 U.S.C.
        1601-1610)

     •  National Environmental Policy Act of 1969 (42 U.S.C.
        4321-4347)

     •  Administration of National Wildlife Refuge System (16 U.S.C.
        668)

     •  Open Space Land (42 U.S.C. 1500)

     •  Protection of Bald and Golden Eagles (16 U.S.C. 668)

     •  Wild and Scenic Rivers Act (16 U.S.C. 1271-1287)

     •  Wilderness Act and Amendments (16 U.S.C. 11-31-1136; P.L.
        93-662)

Other constraints would include national, state, and local forests,

parks, trails, and historic sites.

     9.2.2  Transportation.  The baseline regulations require that if

the waste meets the DOT definition and criteria for a hazardous

material (49 CFR 171.8 and 173), it must be handled in accordance

with-the provisions of applicable DOT regulations under 46 and 49

CFR.  These regulations contain detailed requirements for the

construction, inspection, handling, and labeling of hazardous

materials and other containers.  The baseline regulations for

hazardous wastes also specify that transporters must not transport
                                 9-10

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containers which are leaking or appear to be damaged, and that leaks




which are discovered enroute be treated as emergency situations.




     Except for the restrictions on accepting damaged containers,




there are no other provisions in the baseline regulations designed to




prevent spillage or other accidental releases during transport. This




could be alleviated by requiring studies to determine a route from




the generating site to the treatment/disposal site which presents the




least chance of an accident and which would involve the least amount




of damage to human health and the environment in general.  Such




studies might prove especially useful if the total ton-miles of




hazardous waste transport increase.




     9.2.3  Construction and Operation.  The baseline regulations




mandate that landfills, landfarms, and surface impoundments "shall be




located, or constructed and operated, so as to prevent landslides,




slumping or erosion."  This requirement does not specifically include




the implementation of a sediment control plan during construction




activities, though the effective use of such a plan would mitigate




most physical impacts of construction.  Requirements to minimize the




construction impact on wildlife would provide additional benefits.




Such plans may be required by state or local statutes.




     Although the baseline regulations require that "facilities shall




have fencing completely surrounding all active portions of the




facility," they do not make provisions for securing the facilities




against small burrowing animals and birds.  The case of waterfowl at
                                 9-11

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ponds and lagoons may present particular problems.  Burrowing animals




may be excluded by constructing fences which are buried several feet




in the soil, the exact depth determined by the types of animals which




might be present in the region.  Solution of the problem of birds may




be more difficult, but may be attempted by growing non-palatable




vegetation such as Phragmites (Martin and Uhler, 1951) or pine trees




around the perimeters of the area.  Intermittent noise makers may




also be used when necessary.




     The baseline regulations would prohibit endangerment of




underground drinking water sources (UDWS).  Such sources are defined




as those which currently supply a public water system; or an aquifer




with a total dissolved solids content of less than 10,000 mg/1; or an




aquifer otherwise designated as usable by the Administrator.  It is




possible, especially in water-short areas, that some groundwaters




that are not classified UDWS may at some point be required for




salinity-tolerant industrial uses such as dust control, ash quench-




ing, or cooling purposes.  Contamination of these waters with




hazardous wastes could prevent such use and require the use of




freshwater instead, possibly contributing to water shortages.  This




occurrence could be avoided by extending the regulations to protect




all groundwaters.  Alternately, the Administrator could limit




exemptions to this procedure to areas which are highly unlikely to




experience water shortages, or could designate all aquifers in




potential drought areas as UDWS.
                                9-12

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     Adverse impacts could occur as a result of potentially hazardous

wastes which are not covered by the regulations* or which are pro-

duced by generators who produce less than the generator limit and are

thereby excluded from regulation.  These wastes would be subject to

all other applicable state and Federal regulations, including the

Clean Water Act, Safe Drinking Water Act, Clean Air Act, Subtitle D

of RCRA, Federal Insecticide, Fungicide, and Rodenticide Act, and

others.

     Any remaining impacts resulting from these wastes not subject to

the regulations could be further mitigated by specifically requiring

proper labeling and disposal of all potentially hazardous wastes

(while excluding generators producing less than 100 kilograms per

month from the paperwork and other requirements of the regulations).

     9.2.4  Closure.  One additional area not specifically covered in

the baseline regulations is the impact resulting from disposal sites

which already have been abandoned or which would be abandoned rather

than modified to meet the regulations.  The Section 3004 regulations

would require that facility owners/operators close all portions of

their facilities which do not comply with the regulations.  Such

closure is to be in accordance with the specified closure procedures.

However, most of the closure requirements are directed at new
*As discussed in Chapter 7, EPA is considering expanding the toxicity
 criteria to regulate a greater number of potentially hazardous
 wastes at a future time.  An additional environmental statement or
 supplementary statement would be prepared covering this change, if
 warranted at that time.
                                 9-13

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facilities and those existing facilities able to obtain permits;




previously abandoned facilities and those existing facilities which




could not be modified to obtain permits could not satisfy many of the




requirements (e.g., financial requirements, submission of closure




plans before beginning operations, certification of closure in




accordance with permit, and preparation of a survey plat showing




types of waste and their location at the site).  While some owners of




these latter facilities could be located, there are no specific




provisions for insuring proper closure, for financing the cleanup and




closure, or even for locating previously abandoned facilities.  While it




is EPA's intent that all hazardous waste facilities be closed in




accordance with the regulations, some abandoned facilities may have




to be satisfactorily closed using public funds.




     Lastly, it should be repeated that the regulations themselves




are an important and potent mitigating measure.  The administrating




agencies must ensure that the location, design, construction, moni-




toring,  and closing of all facilities are all carefully planned and




that all provisions of the regulations are strictly followed and




enforced.  This point is emphasized by the recent study (U.S.




Environmental Protection Agency, 1977c) which discovered that a large




percentage of sites which were presumably secure and already being




monitored were actually causing groundwater pollution.
                                9-14

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

     The Subtitle C regulations may result in some localized adverse

impacts, though as discussed previously, such impacts would essen-

tially be continuations of adverse impacts which are already

occurring.  On the other hand, the regulations would also result in a

significant overall reduction in the adverse impacts associated with

hazardous waste management and would thus provide for the significant

enhancement of the long term productivity of man's environment.

     The major short-term adverse impacts would include economic

impacts, which are discussed in detail in the Integrated Economic

Impact Assessment (Regulatory Analysis Supplement), some localized

instances of environmental degradation, and possible increased public

opposition to the location of additional hazardous waste disposal

sites.  These must be balanced against the benefits derived from

likely increases in resource recovery, improved air and water

quality, and reduced damages to environmental systems and human  .

health.

     The possible increase in resource recovery would contribute to

two beneficial effects.  It would decrease the rate of depletion of

raw materials through increasing emphasis on the development of

separation technology and resource recovery.  In addition, any

increased resource recovery could result in decreases in the amount

of waste generated, thereby extending the usable lifetimes of

disposal facilities.


                                10-1

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     The control of hazardous wastes required by the regulations




would end many of the incidents of water quality degradation which




occur as a result of current disposal methods.  Increases in water




quality would effectively increase the water potentially available




for various uses and should provide additional benefits through the




prevention of adverse human health effects resulting from exposure to




hazardous materials in drinking water supplies.




     The permanent isolation of many of the harmful and persistent




waste products from man's industries would have many beneficial




effects on the environment and human health.  As a result, bioaccumu-




lation of these materials in the food chain would be decreased, as




would many of the effects of chronic exposure to low levels of toxic




contaminants.
                                10-2

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11.0  IRREVERSIBLE AND IRRETRIEVABLE COMMITMENTS OF RESOURCES




     The requirements contained in the Subtitle C regulations would




result in the essentially irreversible or irretrievable commitments




of land, wastes, fuel, container materials, and clays, even though




many of these resources are also presently being irretrievably




committed by the haphazard methods currently employed in hazardous




waste disposal.




     Land commitments are currently being made for hazardous waste




disposal.  The regulations may cause a reduction in the number of




small scattered disposal sites and an increase in the number of larg-




er, more centrally located sites due in part to the economics




involved with providing a secure facility.  However, the prohibitions




and restrictions on disposal of volatile, reactive, and ignitable




wastes in landfills, surface impoundments, and landfarms would also




necessitate either the upgrading or the construction of new




incinerators and other treatment facilities.  Closure of any existing




facilities which could not be upgraded to meet the regulations and




the construction of necessary replacement facilities would create




additional demands for land and associated land use impacts.




     Due to the requirements for the environmentally acceptable




operation and closure of disposal sites, the land used for disposal




would not actually be irretrievably lost to all uses.  However, due




to the nature of the wastes, future uses would be restricted to




surface activities which do not require any excavation or other




disturbance of the wastes buried below.




                                 11-1

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     The wastes themselves represent a substantial quantity of poten-




tial resources, particularly in the case of heavy metals and other




inorganic materials.  At the present time, technology is not avail-




able to economically recover many of these materials, but at some




point in the future such a procedure may become feasible.  In that




case, some of the permanent disposal methods employed as a result of




this act could be regarded as irreversibly and irretrievably




committing wastes to ultimate disposal.  The required records of




types and locations of wastes within landfills could, however, aid in




recovery efforts.




     Any increased transport of wastes would result in greater fuel




consumption and the increased release of vehicular emissions, with




associated human health effects.  Containerization of hazardous




wastes in landfills would result in the irretrievable loss of raw



materials.




     Large amounts of clays would be required for the construction of




dikes and liners for landfills and surface impoundments.  Additional




amounts would be required as cover material during the operation of




landfills and during closing procedures for landfills, landfarms, and




surface impoundments.  Since these clays would ultimately be contami-




nated by adsorbed wastes, they would be essentially irreversibly lost




to future uses.




     Fuels, electric power, lubricants, structural materials,




capital, and manpower resources used in the construction of necessary

-------
new facilities and in the modification of existing facilities could




be irretrievably lost to other uses.  Additional capital and manpower




resources used in complying with the operational requirements of the




regulations, in administrating the regulations, and in enforcing the




regulations would also be irretrievably lost to other uses.  Any




plant closings as a result of promulgation of the regulations would




likely be irreversible.  Any resultant population shifts could cause




irreversible changes in daily living patterns in affected areas.
                                11-3

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12.0  DISCUSSION OF COMMENTS RECEIVED ON THE DRAFT ENVIRONMENTAL
      IMPACT STATEMENT

     The notice of availability of the Draft Environmental Impact

Statement was published in the Federal Register on December 18, 1978.

Copies of the statement were sent to Federal, state, and local

agencies; environmental, health, and citizens groups; professional

associations; trade associations; and solid waste management

professional groups.

     Information copies were made available at the 10 EPA Regional

Office libraries and at the EPA library reading room, Room 2404,

Waterside Mall, 401 M Street, S.W., Washington, D.C.  Single copies

were also furnished for review and comment upon request.

     The 90-day review period expired officially on March 16, 1979.

Comments on the Draft Environmental Impact Statement were received

during this period from the following (no additional comments on the

Draft Environmental Impact Statement were received after this

period)*:

     •  American Textile Manufacturers Institute, Inc.;
                                                 «
     •  United States Department of Commerce;

     •  Department of Health, Education, and Welfare, Public Health
        Service;

     •  The Utility Solid Waste Activities Group and the Edison
        Electric Institute;

     •  Mobil Oil Corporation;
*0ver 1,200 comments were also received on the proposed Subtitle C
 regulations during this period.  Those comments are addressed in the
 background documents prepared for the Subtitle C regulations.

                                 12-1

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     •  American Petroleum Institute;




     •  Dow Chemical U.S.A.




     These seven comments were considered and responded to in the




preparation of the Final Environmental Impact Statement.  The text of




these comments is presented in Appendix 0.




     This chapter discusses the comments received on the Draft




Environmental Impact Statement, the environnmental issues raised




through those comments, and the resolution of the issues.  Responses




to the environmental issues raised by each commenter are presented




below.  Consideration of the comments and disposition of the issues




raised are reflected, in part, by the revised text in other sections




of the Environmental Impact Statement and, in part, by these point-




by-point responses.




12.1  Comment Responses




     Sections 12.1.1 through 12.1.7 present the environmental issues




raised by each of the commenters and the resolution of these issues.




     12.1.1  American Textile Manufacturers Institute, Inc.




     Extension of Comment Period




     Comment:  The December 18, 1978 Federal Register notice states




that the economic, environmental, and regulatory impact analysis for




these proposed regulations is to be available for inspection on




January 8, 1979.  We have just received a copy of this report, and we




are unable to review it in depth and prepare comments within the




present comment period.
                                12-2

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     Response:   Copies of the Draft Environmental Impact Statement for




the proposed Subtitle C regulations were available at the ten U.S. EPA




regional offices and Headquarters on January 8,  1979, for the express




purpose of allowing the public ample time to review and comment on the




document prior to individual mailings.




12.1.2  United States Department of Commerce




     12.1.2.1.   Foreign Shipments




     Comment;   According to the Section 3002 differences discussed in




the Preface, generators who ship hazardous waste to a foreign country




are required to inform the foreign government.  Are generators




required to inform foreign countries if the material is only in




transit through their country?  (In the case of material being shipped




through the Panama Canal to be disposed of at sea, is the generator




required to notify Panama?)




      Response:  Generators who ship wastes to a foreign country will




be required to notify EPA in advance of the initial shipment in any




calendar year.   EPA will then notify others as appropriate.  With




regard to in transit shipments, generators must comply with national




and international laws, e.g., Panamanian Law.  See the February 26,




1980, Federal Register. Part 262, for further information.




      12.1.2.2  Long-Terra Land Capacity




      Comment;   Epic long-term capacity of land filling was not




addressed in Section 7.2.5.  It is stated that "existing land uses




would cease, either permanently or temporarily, on all land converted
                                12-3

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to hazardous waste management uses.  Some agricultural, grazing,




forest, recreational, and other lands could be removed from their




existing uses."  With a hazardous waste production of 4.7 million




metric tons per year (Table 5-21), it seems that 1.3 square miles of




land could be filled with a 20-foot thick layer each year.  Elsewhere




in the document and in recently-issued proposed regulations in the




Federal Register, EPA discusses total current volumes of hazardous




waste in the 35 million ton per year range, a figure that is expected




to grow rapidly in the next few decades.  How many years can we




continue land filling on the scale this implies before the decrease in




available land through waste containment has a significant effect on




food production and other land uses?




      Response; . The use of land for hazardous waste management is




just one of many factors that would affect the long-term availability




of land for both food production and other uses.  Other factors that




would also affect long-term land availability and productivity include




economic growth, population growth, energy development, technologic




innovation, water availability, environmental pollution, and regula-




tory policies.  Long-term land availability and productivity would




depend upon extremely complex interactions among these and other




factors and would have to be the subject of a comprehensive in-depth




study in its own right.  At this time, it is not possible to determine




with any reasonable degree of accuracy how these interactions will
                                 12-4

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resolve themselves and how they will thus affect long-term land



availability and productivity for specific uses.




     The EIS discusses those land use impacts that are attributable to




promulgation of the Subtitle C regulations.  Section 7.2.4.2 indicates




the changes in on-site and off-site land requirements that could re-




sult from the baseline regulations.  Section 7.2.5 describes long-term




land use impacts that could result from these changes in land re-



quirements and from other changes likely to result from the baseline




regulations.




     The DEIS does indicate that the regulations might result in



increased land use for the environmentally acceptable management of




hazardous waste.  However, the primary reason behind additional lands




being required for hazardous waste management under the regulations is




the need to provide acceptable facilities for managing those wastes




that are currently being generated, but that are not being managed in




an environmentally acceptable manner.  The DEIS notes that, to the ex-



tent that the regulations would prevent other lands .from being con-




taminated by improper disposal, dumping, storage, or treatment of




hazardous wastes under current practices and regulations, there would



be a potential for offsetting land use benefits.  The DEIS also notes




in Section 7.1.2.1 that, due to increased costs associated with both




hazardous waste generation and management under the regulations,




generators would have an incentive to modify processes so as to reduce




the amounts of hazardous waste produced by their processes and so as
                                12-5

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to enable increased recycling of hazardous wastes as process feed-




stocks.  To the extent that such modifications occur, less waste would




have to be disposed in the long-term.  This would also potentially




provide offsetting land use benefits.




     It should be noted that Table 5-21 does not indicate that




hazardous waste generation is 4.7 million metric tons per year.  As




stated in the text, Table 5-21 shows the total quantity of hazardous




wastes contained in selected waste streams that were studied to




determine their potential for energy recovery.




     12.1.2.3  Agricultural Use of Closed Sites




     Comment;  Section 7.2.5 of the Draft EIS states that "Sites at




which hazardous wastes have not been removed would be precluded from




residential and agricultural uses, and may be precluded from some re-




creational and grazing uses following closure."  If the intent of



limiting the use to non-agricultural purposes is to keep highly per-




sistent molecules out of the food chain, it will not work due to wild




animals, insects, and birds foraging on plants in the site area.  We  •




recommend this concept be reviewed.




     Response:  This comment has been considered in the revision of




the proposed Subtitle C regulations.  Modifications to post-closure




requirements (including stipulations on the future use of hazardous




waste sites) have been considered and are addressed in the Phase I




Alternative (See Sections 4.5 and 8.5).
                                12-6

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     12.1.2.4  Probability of Marine Accidents

     Comment:   With regard to Section 5.2.3.5, an impact that is not

discussed is the possibility of a marine accident that would cause the
                                                                   &
release of up to 1,500 tons of hazardous waste into the Mississippi

River or Gulf intercoastal waterways.  A discussion of the probability

of it happening, similar to the discussion on page 7-190 (Section

7.2.3.2) for highway transportation, would be useful.

     Response:  Section 7.2.3.2 discusses the potential change in the

number of vehicular accidents that could result under the baseline

regulations from a change in the quantity of hazardous waste being

sent off-site by truck.

     As indicated in Section 5.2.3.5, most hazardous waste material

transported by waterway is sent to a resource recovery facility.

Those waste materials sent to resource recovery facilities would not

be identified as a solid waste under the Subtitle C regulations and


would thus not be subject to the regulations.

     The total quantity of hazardous waste.materials transported by

barge appears to be small, relative to highway transport.  Data are

not, however,  available to estimate the quantity of waste presently

transported by barge that could be subject to the regulations nor to

estimate the change in the quantity of such waste that would be

transported by barge under the baseline regulations.  Consequently,

the potential change in the number of marine accidents that could

result under the baseline regulations cannot be estimated.
                                 12-7

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     Section 7.1.5.1 has however been expanded to include a generic

discussion of the potential for any changes in the quantity of

regulated waste being transported by barge to result in changes in

marine accidents.  (It should be noted that Section 5.2.3.5 contains

background information, not the impact assessment.)

     12.1.3  Department of Health, Education, and Welfare, Public
             Health Service

     12.1.3.1  Generator Limit

     Comment:  The EPA Standards, as proposed, would not apply to a

generator producing less than 100 kilograms of hazardous waste per

month.  While this amount might not be considered significant for

some chemicals, 100 kilograms of radioactive material or infectious

material could present a substantial problem if proper handling,

storage, transportation, and disposal practices are not observed.

     Response:   This comment has been considered in the revision of

the proposed Subtitle C regulations.  Section 7.1.6.1 discusses

potential impacts that could result from the exclusion of such wastes

from control under the baseline regulations.  Sections 8.3 and 8.4

discuss the potential impacts that could result from alternative

generator limits.

     12.1.3.2  Storage Without a Permit

     Comment:  The proposed standards would not apply to a generator

who stores hazardous wastes less than 90 days.  Has the issue of

regulating all generators been considered since the improper storage,
                                 L2-8

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handling, treatment, or disposal of hazardous wastes may represent a




sustained threat to health irrespective of the time factors involved?




     Response;  This comment has been considered in the revision of




the proposed Subtitle C regulations.  Under the proposed regulations,




those generators who accumulate wastes, prior to off-site disposal,




for less than 90 days without a permit are still required to comply




with the container standards specified in Section 3002.  One addi-




tional requirement is being considered for on-site accumulation




without a permit and is addressed in the Phase I Alternative (see




Sections 4.5 and 8.5).  Other changes with regard to the accumulation




of wastes without a permit in storage tanks are being considered and




will be addressed in the Phase II Alternative to be added in Part 2 of




the final Environmental Impact Statement.




     12.1.3.3  Number of Generators




     Comment:  On page S-19 of the DEIS it is estimated that 430,000




to 460,000 generators would have to comply with hazardous waste




regulations.  An indeterminant number of "special waste" generators



could also have to comply.  These figures are inconsistent with the




statement noted on page 58946, column 3, of the December 18, 1978,




Federal Register.  That reference estimates approximately 270,000



waste generating facilities.  This discrepancy should be resolved




since the actual number of generators will have a drastic effect on




the estimates of paperwork required under this regulation, numbers of
                                12-9

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generators affected, and the potential health and safety impact on the




general population.




     Response:  The DEIS estimate of the number of generators required




to comply with the regulations has been revised downward.  The




revision has been made to account for the effect of the waste




automotive oil transfer of liability contract on the number of




regulated generators.




     12.1.3.4  Phasing of Generators




     Comment:  Using the figures in the Federal Register, it is




estimated that approximately 270,000 waste generating facilities and




10,000 transporteres will be regulated, although only about 30,000 of




that number will require treatment, storage, or disposal permits.




Generators would be phased over a 5-year period with the larger




producers brought into compliance first.




     We do not agree with this philosophy and believe that through the




application of the regulations to everyone, many generators can




immediately b.e brought into "voluntary" compliance with little effort.




It is recognized that some firms may require time extensions to



achieve compliance, but this extension should be on a case-by-case




basis.




     Response:  The phasing of generators under the regulations is one




of many alternative approaches that were considered in the development




of the Subtitle C regulations.  This alternative is analyzed in the




DEIS in Section 8.2, but was not included in the proposed Subtitle C




regulations.




                                12-10

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     12.1.4  The Utility Solid Waste Activities Group and The Edison
             Electric Institute

     12.1.4.1  Quantitative Estimates

     Comment:  The DEIS lacks quantitative estimates which measure

impact assessments in absolute terms.  In this most crucial aspect of

an impact statement, the DEIS is seriously deficient because of the

lack of quantitative and specific data and information, especially in

key decision-making areas.  Typically, when assessments are attempted

in the DEIS, they are presented on a comparative, qualitative basis,

presumably based on the judgment of EPA and their contractors.  This

absence of quantitative, absolute data and information effectively

frustrates any attempt to distinguish clearly either absolute or

incremental effects or impacts of the proposed or alternative actions.

(See Appendix 0 for specific examples indicating the qualitative

nature of the impact assessment).

     Response:  As is indicated in the DEIS, extremely limited data

are currently available with regard to both the generation and the

management of hazardous waste.  To the extent that the limited data

allow, impacts are assessed quantitatively in the DEIS.  However,

while every effort has been made to make the analysis as quantitative

as possible, data limitations for the most part, necessitate a generic

and qualitative assessment of impacts.  Section 7.3 indicates the

significant uncertainties present in the impact assessment.

     Although the specific magnitude of impacts may not always be

known, the types of impacts that could occur (both beneficial and

                               12-11

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adverse) are identified.  Also identified are the types of impacts

that may be significant, the types of impacts that cannot presently be
                              •
mitigated, and data gaps and uncertainties that need to be resolved.

These are some of the important environmental considerations with

regard to decision-making and program planning.

     12.1.4.2  Incomplete Data Base

     Comment;  The value and meaningfulness of the qualitative as-

sessments are further weakened by the fact that they have been based

on a limited data base representative of only the manufacturing

industries.  (See Appendix 0 for excerpts from the OEIS which outline

the limitations in the data base used to support impact assessments.)

The completeness of even that data base was called into question in

Section'7.1.3.3.   While there would seem to be ample justification to

question the selection of the manufacturing industries data base as

the basis for impact assessments in the DEIS, this comment relates not

to the matter of data base selection, but to the inappropriateness of

the DEIS subjective/qualitative judgments (based an manufacturing

industry waste information) as applied to other industries' wastes.

The differences in waste characteristics and treatment and disposal

practices between industries and industrial groupings are extremely

significant.  This was recognized to a great extent by EPA in estab-

lishing the "special wastes" category.

     Notwithstanding the special waste categorization, the proposed

regulations do apply to and will have significant impacts on non-
                                 12-12

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manufacturing industries.  Yet, there has been no effort made to




evaluate just what the impacts will be for these industries and




whether or not the regulations are accordingly justified.  This is a




serious deficiency in the DEIS which significantly limits its useful-




ness to support decision-making.




     Response:  It is agreed that the regulations would have signifi-




cant impacts on both manufacturing and non-manufacturing industries.



As indicated in Section 7.0, the emphasis of the impact analysis is




necessarily directed toward manufacturing industries because most




available data concerning hazardous waste generation and management




relate to manufacturing industries.  Impacts from the regulation of




non-manufacturing industries are addressed to the extent that the




available data allow (see, for example, Sections 6.1.2, 7.1.3.3, and




7.1.3.6).




     Due to the significant differences that exist in waste charac-




teristics and management practices among both the various manufactur-




ing and non-manufacturing industries, any detailed assessment of the




overall potential impact of the regulations on various manufacturing




and non-manufacturing industries would essentially require the prepa-




ration of an entire separate assessment for each and every industry.




Such an undertaking is not manageable within the scope of this Envi-




ronmental Impact Statement.  Furthermore, the extensive data limita-



tions previously indicated (and reaffirmed by the public comments on
                               12-13

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the proposed regulations) along with the extreme waste-specific,




process-specific, and site-specific nature of most impacts would at




this time preclude the preparation of a meaningful comprehensive




assessment for most industries, and especially for non-manufacturing




industries.  It should be noted that, for the most part, the major




impact of the regulations on industry would be economic in nature.




The major economic impacts of the regulations on various industries




are analyzed in the Integrated Economic Impact Assessment of Hazardous




Waste Management Regulations (Regulatory Analysis Supplement), not in




the EIS.




     12.1.4.3  Meaningfulness of Alternatives




     Comment:  We question the meaningfulness of EPA's alternatives



selection on two accounts.  First, EPA does not provide any support or




foundation to demonstrate that the alternatives that were selected



actually do bracket the anticipated overall objectives and resultant




impacts.  We believe that such a demonstration by EPA is in order.




Our basic contention in suggesting such a need is that unless the




"world" that is to be affected (in this case, by the proposed or




alternative regulations) is reasonably well known and defined, one




cannot reasonably assume that the appropriate "bracket" has been




established or that the resultant impacts have been bracketed.  More




specifically, and as reviewed previously, EPA has stated that the




focus of its assessment has been with respect to manufacturing indus-




tries and that in many of these, the number of hazardous waste
                                12-14

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generators are not known.  Alternatively stated, EPA has assessed the




impacts of the regulations (i.e., proposed and alternatives) based on




a "sample" of the "world" that will be impacted while it has demon-




strated no support that its "sample" is representative.




     If it were discovered that the "sample" used by EPA in its an-




alysis was not representative, it is possible that the impacts such as




plant closings or community out-migration could become extremely




significant.  Given that EPA has not quantified the absolute impacts




of each of its alternatives or quantified the incremental quantitative




impacts among the alternatives and the proposed action, the reviewer




has no reasonable way of accepting that the alternatives are meaning-




ful ones which truly bracket the impacts from "whatever set of re-




gulations that are ultimately promulgated. . . ."




     Response;  The latter part of the comment indicates that




variances in data would change the predicted impacts that could occur




under the alternatives analyzed and could thus invalidate EPA's selec-




tion of alternatives used to bracket anticipated impacts.  Based upon




this, it appears that there is some confusion about the difference be-




tween the brackets (constraints) imposed by the set of alternatives




used for the assessment and the constraints imposed by the adequacy




and/or representativeness of the existing data base.  This difference




is very important and needs to be addressed before responding to the




first part of the comment.
                                12-15

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     The set of alternatives provides the framework for assessing




impacts by defining those wastes and activities that are excluded from




regulation and by defining those wastes and activities that are to be




regulated and the manner in which they are to be regulated.  The set




of alternatives thus limits both the "world" that is to be affected by




the regulations and the types of impacts that can potentially occur




and be assessed within that world.  This bracketing occurs independent




of data considerations and exists whether or not data is available to




assess impacts within these limits.  While the adequacy and represen-




tativeness of the existing data base does, without question, affect




the reliability of the assessment of the set of alternatives, the data




base does not in any way affect those brackets (constraints) imposed




by the set of alternatives.




     With regard to the issue that there is no support to demonstrate




that the set of alternatives truly brackets the impacts from the set




of regulations to be ultimately promulgated by EPA, it should first be




noted that during the development of the Subtitle C regulations numer-




ous issues have been reviewed by EPA and numerous regulatory options




have been considered for promulgation by EPA (see the Background




Documents for a discussion of the major issues raised and the major




regulatory options considered).  For reasons discussed in response to




comment 12.1.4.4, it was not possible for the EIS to assess each and




every regulatory option considered; as a result, it was necessary to
                                12-16

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select and develop a manageable set of meaningful alternatives for an-




alysis purposes.




     The various regulatory options considered reasonable for promul-




gation by EPA under the mandate of Subtitle C were used in selecting




such a set of alternatives.  To insure that the set of alternatives




reasonably brackets the anticipated impacts from the regulations that




are ultimately to be promulgated, the regulatory options included in




the set of alternative were put at the limits at which they were con-




sidered for promulgation.  For example, while EPA proposed a generator




limit of 100 kilogram per month, EPA also considered as reasonable




proposing a generator limit as high as 1,000 kilograms per month or




eliminating the generator limit entirely and regulating all hazardous




waste generators.  The set of alternatives selected imposes generator




limits between zero and 1,000 kilograms per month and thus brackets




the regulatory options considered reasonable.




     By setting the regulatory options at the limits considered for




promulgation, the set of alternatives thus .reasonably brackets the




regulations considered for promulgation and thus reasonably bracket




the impacts anticipated from these and intermediate regulations.




Obviously, if the regulations that are ultimately promulgated contain




options not previously considered by EPA, it is possible that not all




significant impacts would be bracketed; however, it is not possible to




anticipate such developments.  As is discussed above, the validity of
                                12-17

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Che data base available for impact assessment does not in any way


affect the brackets imposed by threse alternatives.


     It should be noted that a new alternative, the Phase I Alterna-


tive, has been added to enable the assessment of additional regulatory


options now being considered for promulgation as part of the Phase I


regulations.  A second new alternative, the Phase II Alternative, is


to be added in part II of the final EIS so as to enable the asssess-
                                           •

ment of additional regulatory options being considered for promul-


gation as part of the Phase II regulations.


     12.1.4.4   Analysis of Each Regulatory Option


     Comment;  Second, we question the meaning fulness of the


alternatives since each alternative represents a combination of many


different regulatory mechanisms and controls.  For example, the lesser


degree of control alternative involves elimination of the identifying


characteristics test of hazardousness, increasing the generator cutoff


to 1000 kg/month, and other changes.  Similarly, enhanced degree of


control involves elimination of the special waste standards, no


generator cutoff, and expansion of the identifying characteristics ap-


plicability.  Thus, when assessing the impact of an alternative, the


DEIS is presenting the combined impact of a number of regulatory op-


tions.  By this method of evaluation, the importance/significance of


each of the regulatory options which make up a whole alternative is


lost.  For example, if 90 percent of the benefits accruing from the


enhanced degree of control are achieved by eliminating the cutoff and
                                 12-18

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very little benefit is achieved through expanding the identifying




characteristics test (at probably considerable additional cost and




inconvenience), these factors would be essential to the development of




meaningful and cost effective regulations.  The alternatives as they




are presently structured do not allow for this type of regulatory op-




tion "sensitivity analysis."




     The alternatives evaluation, in our opinion, should be structured




so as to test the impact of each regulatory option, in and of itself.




Thus, those options having real and significant benefits could be




identified and included in the final regulations.  Conversely, those




options that have questionable or limited benefits but real and




significant costs could be excluded.




     Response;  First, it is not meaningful, nor even possible, to




assess a regulatory option by itself.  A regulatory option takes on




meaning only in relation to the remainder of the regulations.  For




example, a generator cutoff has no real meaning unless characteristics




for identifying hazardous waste are defined along with requirements




for managing of the waste to be regulated.  Without defining a com-




plete set of regulations, it is not possible to fully assess the




impact of any regulatory option since the effects of excluded portions




of the regulations would not be taken into account.  For example, if




landfill requirements, transport requirements, and/or reporting re-




quirements were not specified, it would not be possible to provide a
                                12-19

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complete or even accurate assessment of the environmental or economic




impacts of different generator cutoff limits.




     Similarly, changes in other parts of the regulations would re-




sult in changes in the impacts from the various components of a




specific regulatory option.  For example, the overall impacts of




generator cutoffs of zero or 1,000 kilograms per month would vary con-




siderably depending upon how toxic wastes were defined, depending upon




whether retailers and farmers were regulated or excluded from regu-




lation, and depending upon whether incinerator destruction efficien-




cies were required to be 99.9 or 99.99 percent.  Thus, a truly ac-




curate assessment of each regulatory option, in and of itself, would




require both that an entire set of regulations be specified for the




assessment and that the regulatory option be assessed for all




variations of all other regulatory options.  Furthermore, every as-




sessment of each regulatory option would have to include all the prim-




ary and secondary impacts addressed in the DEIS.




     Second, a large number of different regulatory options have been




considered in the development of the Subtitle C regulations.  See the




background documents prepared on the Subtitle C regulations by EPA for




a discussion of the major regulatory options considered.  The back-




ground documents consider specific changes on a one-at-a-time basis.




As is discussed in Section 4.0, these regulatory options could be




structured into an enormous number of different sets of regulatory




alternatives.  Consequently, for reasons discussed above, it would not
                               12-20

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be practical, nor even manageable, to attempt to provide a complete
assessment of each and every regulatory option.  Thus, the only rea-
sonable approach was the development of a manageable set of meaning-
ful alternatives for assessment purposes.  This is what was done.
     12.1.4.5  Relative/Qualitative Nature of Alternatives Assessment
     Comment:  As was the case for the impact assessment of the pro-
posed regulations, the DEIS presents assessments of the impacts of the
alternatives which are for the most part qualitative in nature and
seriously deficient with respect to absolute/quantitative measures of
impacts.  Because the alternatives are assessed in such a qualitative/
subjective fashion, the meaningfulness of the assessments cannot be
determined and the overall value of the evaluation of alternatives is
questionable.
     The problem is further compounded by the fact that, in comparing
an alternative to the proposed regulations, the comparison is carried
out in relative terms.  Thus, we are told that a particular alter-
native will have a greater or a lesser impact than the proposed
regulations without being told how much greater or how much lesser
that impact will be.  Further, we are given no indication of how
significant or important this particular difference in impact is.
When this is viewed in light of the fact that we have not been
presented an assessment in quantitative terms of the impact of the
proposed regulations—to which we are comparing the alternative—the
value and credibility of the DEIS to support federal agency
                    l
                               12-21

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decision-making is open to significant doubt.  (See Appendix 0 for




specific excerpts of qualitative analyses presented in the comment




letter.)




     Response;  As is indicated in the response to comment 12.1.4.1,




impacts are assessed quantitatively in the DEIS to the extent that the




limited data available allow.  Data limitations, for the most part,




necessitate a generic and qualitative asessment of the impacts of both




the baseline regulations and the alternative.




     Although the specific magnitude of changes in impacts may not




always be known, the evaluation of the alternatives identifies the




types of impacts (both beneficial and adverse) that could occur under




each alternative and relates them to the types of impacts that could




occur under the baseline regulations.  Also identified are those types




of changes in impacts that may be significant, those types of impacts




that cannot presently be mitigated, and data gaps and uncertainties




that need to be resolved.  These are some of the important environ-




mental considerations with regard to decision-making and program plan-




ning.




     12.1.4.6  Relationship Between Waste Volume and Impact




     Comment:  In comparing the impacts of the proposed regulations to




those of the alternatives, and in fact, in assessing the impacts of




the alternatives, EPA's assessments often contained an underlying as-




sumption that degree of hazardousness was directly related to waste




volume.  This is obviously an incorrect assumption; one, in fact, to




which EPA would certainly not subscribe.  However, as a result of a




                                 12-22

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Lack of information and a Lack of other avaiLabLe assessment means,




EPA often assessed the alternatives in terms of the volumes of wastes




generated.  As a result of the inclusion of this incorrect assumption,




the results of EPA's analysis could be extremely misleading.




     This point can best be demonstrated by the example of the as-




sessment of the phasing alternative.  The phasing alternative con-




sisted of increasing the volume of waste under control at a rate of 20




percent per year, resulting in all wastes being subject to control



after an initial five year period.  In assessing this particular




alternative, EPA's analysis was directed at the volume of waste under




control without giving consideration to the threat to public health,




welfare and the environment inherent in the waste, regardless of




volume.




     Specifically, a "straight line" type of approach is implied in




the analyses.  That is, if 20 percent of the total washes is managed,




then 20 percent of the ultimate benefit is achieved at 20 percent of




the cost.  This is obviously an overly simplistic approach, and, in-




deed, may well ignore reality.  For example, management of relatively




small wastes could yield far greater proportionate benefits if such




wates had high risks or high potential for environmental harm.  Ulti-



mately, it may be possible to control less than the amount of wastes




currently expected by EPA with far less dislocation and greater




benefit.




     We suggest that a more meaningful approach to analyzing this




alternative would entail focusing on' "threat" or "risk" potential of




                                12-23

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wastes and the step-wise management of those posing the greatest risk/




threat first and the least risk/threat last.  In the analysis of such




an approach, the benefits/disadvantages that may accrue to society by




allowing monitoring of the results (i.e., actual cost/benefit) at the




end of years one through "n" could be assessed and allow for "re-




focus" of the regulations as a function of time.




     Response:  EPA agrees that the degree of hazard posed by vari-




ous wastes is not necessarily directly related to their relative waste




volumes.  As discussed below, the impact assessment does not contain




the underlying assumption that the degree of hazard is directly rela-




ted to the waste volume.




     With regard to the Phasing Alternative, Section 4.2 discusses




different methods by which phasing could be implemented and presents




the rationale for the selection of the phasing method analyzed in the



impact statement and for the elimination of other phasing options.




The method selected emphasizes a volume approach to phasing.  A method




based upon a degree of hazard approach was also considered and deter-




mined not to be a reasonable alternative due to data limitations and




program management and enforcement problems.  The elimination of this




method as an alternative in the impact statement does not, however,




imply that the impact assessment assumes that the degree of hazard is




directly related to waste volume.




     Sections 4.3 and 4.4 present the rationale for the selection of




the Enhanced Public Health and Environmental Protection Alternative
                                 12-24

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and the Lesser Degree of Public Health and Environmental Protection




Alternative.  As discussed in response to comment 12.1.4.4, these




alternatives were developed to bracket the impacts of the regulations




ultimately promulgated by EPA.  To this end, the Enchanced Protection




Alternative regulates all the waste already subject to the baseline




regulations plus other additional wastes.  Similarly, the Lesser




Degree of Protection Alternative regulates only a portion of the total



waste already controlled under the baseline regulations.




     The analysis of the Enhanced Protection Alternative does indicate




that the regulation of the additional waste would provide greater



protection than that afforded under the baseline regulations.  How-




ever, this does not in any way imply that the analysis assumes that




the degree of hazard is directly related to the waste volume.  Rather



the conclusion is based upon the fact that since this alternative




regulates all the waste already subject to the baseline regulation,




the regulation of the additional volume of waste, which contains both



highly hazardous and moderately hazardous waste, must necessarily




result in enhanced protection as compared to the baseline regulations.




     Similarly, the analysis of the Lesser Degree of Protection Alter-



native does indicate that the regulation of a lesser quantity of waste




would provide less protection than that afforded under the baseline




regulations.  Again, this does not in any way imply that the analysis




assumes that the degree of hazard is directly related to the waste




volume.  Rather the conclusion is again based upon the fact that since




this alternative regulates only a portion of the waste already subject




                               12-25

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to the baseline regulations, the regulation of this lesser volume of




waste, which contains less highly hazardous and moderately hazardous




waste, must necessarily result in less protection than that provided




by the baseline regulations.




     12.1.4.7  Overall/Comparative Assessment of Alternatives




     Comment:  The DEIS describes the proposed regulations and four




alternative sets of regulations.  It presents an impact assessment




(albeit qualitative) for the proposed regulations and individual




assessments for each alternative relative to the proposed regulations.




There is, however, no overall/comparative assessment indicating, all




things considered, how the proposed regulations and the alternatives




"stack up" one against the other.  This is in direct contradiction to




the EPA guidelines for impact statements on regulatory actions (see




Appendix 0) which require that "the reasons why the proposed action is




believed by the Agency to be the best course of action shall be




explained."



     Obviously, EPA has decided that the proposed regulations, in an




overall sense, are preferred as compared to each of the alternatives.




However, the rationale for why the proposed regulations are preferred




is not presented.  Each of the alternatives and the proposed regula-




tions are compared in specific areas.  That is, the phasing alterna-




tive may require less paperwork than the proposed regulations and from




that standpoint is preferred.  Similarly, the lesser degree of control




alternative will result in greater emissions of air, water and soil




contaminants and from that standpoint may be inferior to the proposed



                                12-26

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regulations.  What is lacking, however, is an analysis combining the




positive and negative aspects of each of the alternatives in compari-




son to the proposed regulations and demonstrating the overall desira-




bility of the proposed regulations.




     We feel that such an overall/comparative assessment considering




economic, social and environmental costs and benefits is required.




Since the DEIS does not include economic cost estimates (this informa-




tion is supposedly included in the Economic Impact Analysis which is




referenced), the least that the DEIS could do is to present an analy-




sis from the standpoint of the environmental and social considerations




which have been addressed.  As it currently stands, we feel that the




document is inconclusive and does not present EPA's reasoning for its




selection of the proposed regulations.




     Response:




     The proposed and final regulations were prepared on the basis of




protecting human health and the environment.  Likewise, alternatives




were established to emphasize the objects of RCRA and to be consistent




with the scope of actions feasible under RCRA.  The overall/ compara-




tive assessment is addressed in the Regulatory Analysis prepared for




Subtitle C.  Comments were sought to assist the Agency in establishing




the best of several options.  For further information, see the Regula-




tory Analysis which is referenced in the preamble of the final regula-




t ions.
                                12-27

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     12.1.4.8  Impact Assessment with Respect co Utility Industry
               Wastes

     Comment;  The DEIS does not include, nor does it purport to

include, an impact assessment of the proposed regulations with respect

to utility industry wastes whether these wastes be high volume wastes

and included in the special wastes category or otherwise.  The draft

impact statement does point out that certain utility wastes, because

of unique characteristics, have been included in the "special wastes"

category wherein (provided they are found to be hazardous under an

identifying characteristics test of Section 3001), they would only be

subject to some of the Subpart D requirements.  No impact assessment

is, however, presented with respect to the impact of even those

limited requirements on the electric utility industry wastes which

fall under the special waste category (see Appendix 0 for specific ex-

amples).  Moreover, no assessment is presented with respect to the

impact of the entire set of regulations on all other utility wastes

which are not included in the special waste category.

     Response:  A detailed assessment of the overall potential impact

of the regulations on various industries, such as the electric utility

industry, would essentially require the preparation of an entire sepa-

rate assessment for each and every industry.  The extensive data

limitations previously indicated (and reaffirmed by the public com-

ments on the proposed regulations) along with the extreme waste-

specific, process-specific, and site-specific nature of most impacts
                                 12-28

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would preclude Che preparation of a meaningful comprehensive assess-




ment for most, if not all, industries at this time.  For the most




part, the major impact of the regulations on industry would be eco-




nomic in nature.  The major economic impacts of the regulations on




various industries are analyzed in the Integrated Economic Impact As-




sessment of Hazardous Waste Management Regulations (Regulatory Analy-




sis Supplement).




     12.1.4.9  Electric Utility Waste




     Comment:  Notwithstanding an admitted lack of information on the




electric utility industry and its wastes, the DEIS refers in numerous




instances to wastes resulting from the combustion of coal as "poten-




tially hazardous" (see Appendix 0 for examples of statement, presented




in Chapters 6 and 7).  In reality, in accord with the regulations,




every waste is potentially hazardous until a specific determination




based on the Section 3001 testing procedures is made.  Identification,




at this stage, of a particular waste as being potentially hazardous




(without any knowledge of whether or not it will be determined to be




hazardous or, if so, to what extent), is patently irresponsible.



Industries whose wastes have been identified and characterized as such




could suffer serious consequences purely from such a characterization.




Clearly, because of the obvious implications, it is incumbent upon EPA




to refrain from giving inappropriate and damaging "labels" to wastes




when, in fact, it is acting without factual data and information.
                                12-29

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     Response:  The intent of Chapter 6 is to present available data




with regard to various sources that have been previously identified as




potential generators of hazardous waste.  It was not, however, meant




to be implied that all wastes generated by these sources would be




identified as hazardous waste under Subtitle C.  Sections 6.1.2 and




7.1.3.3 have been modified to clarify this intent with regard to both




electric utility wastes and the other wastes discussed.




     12.1.4.10  Reported Groundwater Contamination




     Comment;  Table 7-10 lists 57 cases of groundwater contamination




caused by leakage of wastewater from surface impoundments.  One of




these 57 cases is reported as iron and manganese pollution from an




electric utility industry source.  However, no detail or further in-




formation is given on the impact, if any, on public health or the en-




vironment.  Moreoever, in referring to this particular table in the




DEIS, EPA refers to the table as presenting incidents of groundwater




contamination due to hazardous waste disposal.  This is obviously in



conflict with the title of the table, "Origins and Pollutants in 57




Cases of Ground Water Contamination in the Northeast Caused by Leakage




of Waste Water from Surface Impoundments/' and certainly, without




presenting any further information, seems to be a rather careless use




of the characterization "hazardous."




     Response:  Table 7-10 is based upon a study of groundwater con-




tamination in the Northeast by Miller et al.  This study is referenced




in Appendix N of the DEIS (Appendix P in the final EIS).
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     It is agreed that sufficient data does not exist to determine




which of the wastes listed in Table 7-10 would be identified as haz-




ardous under Subtitle C.  The text in Section 7.1.5.3 has been modi-




fied to eliminate identifying all wastes listed in Table 7-10 as




hazardous waste.




     The intent of the table is to illustrate the potential for




ground-water contamination to occur from present unregulated




practices.  Even though it is not possible to identify exactly which




wastes in the table would be considered hazardous under the




regulations, the table does indicate the likelihood of potentially




harmful leachate to be released from surface impoundments managing




hazardous wastes under current practices.




     12.1.4.11  Recovery Potential




     Comment;  At a broader level, the DEIS has not considered recov-




ery and utilization potential of utility industry wastes or the extent




to which such potential may be foreclosed by the proposed regulations.




(A complete discussion of reuse and recovery is included in the over-




all comments on the Subtitle C regulations in the appendix entitled




"Summary Report on Large Volume Electric Utility Industry Solid Wastes




as a Resource for Recovery and Utilization.")




     Response;  As is discussed in response to comment 12.1.4.8, a




detailed assessment of the potential impacts of the regulations on




individual industries is beyond the scope of the EIS.  Furthermore,




the limited data available (see Section 5.4) precludes the preparation
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of a meaningful assessment of changes in hazardous waste utilization



for most, if not all, industries (including the electric utility




industry) at this time.




     With regard to the referenced Summary Report, the information




presented is much too general to be of use in assessing the impact of




the regulations on the utilization of utility waste.  For example, the




data presented does not even allow a determination of which, if any,




of the utility waste being utilized for various purposes would be both




hazardous and subject to the regulations.  It should be noted that the




Subtitle C regulations would apply only to a limited portion of the




waste materials that have a potential for utilization.  For example,




waste materials that are recycled or recovered or whose re-use does




not constitute disposal would not be subject to the regulations.  '




Wastes whose re-use constitutes disposal would be subject to the




regulations only if the wastes are hazardous under the Subtitle C




regulations.




     12.1.4.12  Coal Consumption




     Comment;  In a similar vein, the DEIS has not considered the




impact of the regulations, vis-a-vis reduced coal consumption, on U.S.



plans to develop our coal reserves extensively in order to achieve




energy independence.




     Response;  The Subtitle C regulations are just one of many fac-



tors that could have an impact on U.S. coal development and consump-




tion.  Other factors that would also affect coal development and
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consumption include Federal and state restrictions on the development




of certain specific coal reserves, manpower and equipment constraints,




water availability, economic growth, technologic innovation, energy




conservation, availability of alternative energy supplies, and




various other environmental regulations.  Future coal development and




use would depend upon complex interactions among these and other




factors and would have to be the subject of a comprehensive in-depth



study in its own right.  There have been many in-depth studies in




recent years that have attempted to project future coal consumption.




Due to the significant uncertainties associated with the above




factors, these studies have arrived at widely varying estimates of




future coal consumption.  It is not possible to determine with any




reasonable degree of accuracy at this time the interrelationship of




the Subtitle C regulations and the future developmentof U.S. coal




resources.




     To the extent practical, the discussions of energy use impact




(Sections 7.2.8, 8.3.2.8, and 8.4.2.8) have however been expanded to




address the potential for the regulations to impact energy production.




     12.1.5  Mobil Oil Corporation




     12.1.5.1  General Deficiencies




     Comment:  The Agency has not justified the regulations with




adequate supporting data and as a result, they have severely under-




estimated the impacts of the proposal.  This has resulted in gross




deficiencies in the Agency's Environmental Impact and Regulatory
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Analyses.  We support the detailed comments on this aspect submitted



by the American Petroleum Institute and the Manufacturing Chemists As-




sociation.




     Response:   The American Petroleum Institute's comments on the




DEIS are addressed in Section 12.1.6.  The Manufacturing Chemists As-




sociation did not submit comments on the DEIS.




     12.1.5.2  Degree of Hazard




     Comment;  The Agency has failed to differentiate the relative de-




grees of hazard posed by different types of wastes, has not assessed




the potential risk to the environment in setting stringent performance



standards, and has not addressed the risk to the environment in set-




ting a policy where almost all non-municipal waste materials will be




hazardous wastes.  The overly broad definition of hazardous waste com-




bined with the stringent requirements for management will be coun-




terproductive and lead to the situation where compliance is impossible




because of the shortfall of approved facilities.  Due to overloaded




facilities, there could be a greater risk to the environment.




     Response:   The DEIS assesses the potential impacts that could re-




sult from the baseline action (Section 7) and from two alternatives



structured to provide a greater degree (Section 8.3) and a lesser de-




gree (Section 8.4) of environmental protection.  Due to differences in




the definition of hazardous waste among these three alternative




actions, each of the three alternative actions provides for the regu-




lation of significantly different quantities of hazardous waste.  The







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assessment of these three alternative actions thus addresses the over-




all impacts that would result from the regulation of significantly




different quantities of hazardous waste, including changes in any




potential shortfall of hazardous waste management capacity.  The Phase




I Alternative added in Part I of the final EIS provides a further as-




sessment of .the impacts from the regulation of different quantities of




hazardous waste.



     Modifications to the technical standards for treatment, storage,




and disposal will be included in the Phase II regulations and will be




addressed in Part II of the final EIS.



     12.1.5.3  Alternatives




     Comment:  The Agency's difficulties in meeting court mandated




promulgation dates are appreciated; however, no proposed regulation




should be promulgated without an adequate background in fact.  A regu-




lation characterized in the introduction as extraordinarily complex,




difficult, and comprehensive, requires an adequate and complete envi-




ronmental impact statement which does not in our judgement exist for




the regulation as a whole and certainly not as related to major im-




pacts on oil drilling and production operations.  The environmental




impact statement should be expanded to more completely evaluate




impacts of selected and alternate regulatory choices.




     Response:  The discussions of energy use impact (Sections 7.2.8,




8.3.2.8, and 8.4.2.8) have been expanded, to the extent practical, to




address the potential for the regulations to impact energy production.







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A detailed assessment of the overall potential impact of the regula-




tions on various industries, such as the oil production industry,




would essentially require the preparation of an entire separate as-




sessment for each industry.  The extensive data limitations pre-




viously indicated (and reaffirmed by the public comments on the pro-




posed regulations) along with the extreme waste-specific, process-




specific, and site-specific nature of most impacts would preclude the




preparation of a meaningful comprehensive assessment for most, if not




all, industries at this time.  For the most part, the major impact of




the regulations on industry would be economic in nature.  The major




economic impacts of the regulations on various industries are analyzed




in the Integrated Economic Impact Assessment of Hazardous Waste Man-




agement Regulations (Regulatory Analysis Supplement).




     The issue of the need for evaluation of selected and alternative




regulatory choices is addressed in the response to comment 12.1.4.4.




     12.1.5.4  State Responsibilities




     Comment;  The impact analysis appears to inadequately assess




state resources and the ability of the states to implement the regu-




lation and assure costly continued compliance.  In the case of oil




drilling and production, comprehensive regulations using alternate




proven approaches are already in place.




     Response;  The analysis of state resources and of the ability of




states to implement the regulations and assure continued compliance
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is a regulatory issue, not an environmental issue.  As such, it is ad-




dressed in a separate document — "Operational Resource Impact Analy-




sis:  Resource Conservation and Recovery Act of 1976, Subtitle C",




Final Report, March 1980.  It should be noted that RCRA mandates that




states be authorized to carry out their own program in lieu of the




Federal program, provided that specified conditions are met.  Authori-




zation would be granted by EPA only to those states that are in com-




pliance with all the specified requirements.  EPA will evaluate all




applications for authorization to determine those states that are to




be granted authorization.




     12.1.6  American Petroleum Institute




     12.1.6.1  Contravention of NEPA's Mandate




     Comment;  The DEIS,-although deficient as to some of the NEPA - -




Section 102(2)(c) requirements, demonstrates that EPA's proposal will




violate NEPA Sections 101(b)(3) and (4) by imposing requirements which




will cause more harm than good.  For example, the DEIS predicts that




there may be substantial shifts from on-site to off-site disposal.




Such shifts will result in greater hauling distances causing increased




air pollution and congestion in many areas.




     The DEIS points to another impact of the proposed regulations




which is contrary to NEPA1a purposes of maintaining land for a variety




of uses; that is, "[mlore total land, off-site, plus on-site, would be




required for hazardous waste management under the Subtitle C regula-




tions than for hazardous waste management under current practices."








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The DEIS explains that "[ejxisting land uses would cease, either per-




manently or temporarily, on all land converted to hazardous waste man-




agement uses.  Some agricultural, grazing, forest, recreational, and




other lands could be removed from their existing uses."




     Response:  The DEIS indicates both the beneficial and the adverse




impacts that could result from promulgation of the Subtitle C re-




gulations.  The DEIS does indicate that the regulations might result




in more hazardous waste being sent off-site and that the regulations




would result in increased land use for environmentally acceptable




management of hazardous waste.  However, the primary reason behind any




additonal waste being sent off-site is that the waste was not being




managed on-site in an environmentally acceptable manner to begin with.




Furthermore, the primary reason behind additional land being required




for hazardous waste management under the regulations is the need to




provide acceptable facilities for managing those wastes that were not




previously being managed in an environmentally acceptable manner.  The



DEIS notes that to the extent that the regulations would prevent other




lands from being contaminated by improper disposal, dumping, storage




or treatment of hazardous wastes under current practices and




regulations, there would be a potential for offsetting land use




benefits.




     The DEIS complies with all the requirements specified in Section




102(2)(c) of NEPA.  Section 102(2)(c) requires that environmental




impact statements analyze:
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     •  The environmental impact of the proposed action;

     •  Any adverse environmental effects which cannot be avoided
        should the proposal be implemented;

     •  Alternatives to the proposed action;

     •  The relationship between local short-term uses of man's
        environment and the maintenance and enhancement of long-term
        productivity;

     •  Any irreversible and irretrievable commitments of resources
        which would be involved in the proposed action should it be
        implemented.

These points are all specifically addressed in the DEIS in Chapters 7,

9, 8, 10, and 11 respectively.

     12.1.6.2  Costs and Benefits

     Comment;  The DEIS fails to assess whether benefits justify

costs.  As an instrument to be used in the decision-making process,

the failure of the DEIS to address costs and benefits indicates that

EPA did not balance the "pros and cons" of the proposed program in

order to minimize environmental and economic disruptions.  Further,

the failure to estimate costs and benefits makes the consideration of

alternatives to the proposed action impossible.  The DEIS is particu-

larly deficient in its discussion of the alternatives it considered to

the proposed program.  This glaring omission to balance costs with

benefits is not corrected by the Draft Economic Impact Analysis.  As

explained in detail in Fart III of the American Petroleum Institute

comments, the Draft Economic Impact Analysis omits costs incurred by

several important segments of the petroleum industry.
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     Response:




     The intended purpose of the DEIS is to assess the impact of the




proposed Subtitle C regulations on human health and fhe environment.




The intended purpose of the Draft Economic Impact Analysis (DEIA) is




to assess the cost impact of the proposed Subtitle C regulations.  The




DEIA, which accompanied the December 18, 1978 proposed regulations,




qualitatively discussed the potential impacts of complying with these




regulations.  There are large benefits from the regulation of hazard-




ous waste; however, many are extremely difficult to quantify.  EPA has




not attempted to quantify the economic benefits from avoiding human




health damage.  A chapter on benefits of the hazardous waste regula-




tory program, included as part of the Econmic Impact Analysis asso-




ciated with the final regulations, contains a generic discussion on




this subject.




     12.1.7  Dow Chemical U.S.A.




     12.1.7.1  Extension of Comment Period



     Comment;  The Dow Chemical Company respectfully petitions that




the due date for public comment on EPA's proposed regulations imple-




menting Sections 3001, 3002, and 3004 of the Resource Conservation and




Recovery Act of 1976 proposed in the December 18, 1978 Federal Regis-




ter (43 Fed. Reg. 58946 et seq.), and now set to expire on March 16,




1979, be extended until at least 60 days after the proposal of all re-




gulations implementing Subtitle C.  Although the regulations for




Sections 3001, 3002, and 3004 were proposed on December 18, 1978, the
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background documents were not available for review until January 8,




1979, and published copies of the draft Environmental Impact Statement




(EIS) were not available for distribution until early February.  The




integrated permit regulations pursuant to Section 3005 of the RCRA




have not yet been proposed.  Regulations for Sections 3003, 3006,




3010, and 4004 were previously proposed in mid-1978 before the charac-




teristics of hazardous waste described in proposed Section 3001 were




fully developed.  This piece-meal proposal and promulgation has made



coherent overall assessment of the changes occurring among the indi-




vidual Sections of the regulations impossible.




     Response:




     EPA has provided the public with ample time for comment on the




draft Environmental Impact Statement for the proposed Subtitle C




regulations.  Although copies were not individually distributed until




February 1979, they were made available for review in the EPA regional




offices as well as Headquarters on January 8, 1979.
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