A National
Conference About
 Hazardous  Waste
    Management
          Sponsored by the :
     U. S. Environmental Protection Agency
   Western Federal Regional Council Task Force for
       Hazardous Materials Management
    California State Department of Health Services
  Ventura (California) Regional County Sanitation District
  Governmental Refuse Collection and Disposal Association
       February 1 -4,1977
              — Golden Gateway
       1500 Van Ness Avenue
    San Francisco, California 94109

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           PROCEEDINGS OF
A NATIONAL CONFERENCE ABOUT
HAZARDOUS WASTE MANAGEMENT
             PUBLISHED BY

    VECTOR AND WASTE MANAGEMENT SECTION
    CALIFORNIA STATE DEPARTMENT OF HEALTH
              744 P STREET
       SACRAMENTO, CALIFORNIA 95814
                1978

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                                               FOREWORD
     The 53 papers comprising this volume were presented at a conference that was probably the first in the nation
devoted exclusively to hazardous waste management. The conference was developed pursuant to a requirement of an
EPA grant awarded to the California State Department of Health (DOH) in 1974, and was sponsored by the U. S.
Environmental Protection Agency  (EPA), Western  Federal  Regional Council Task Force for Hazardous Materials
Management, DOH, Ventura Regional County Sanitation District, and Governmental Refuse Collection and Disposal
Association. The grant, entitled "Implementation of California's Hazardous Waste Management Prograrh", initially
required the DOH to conduct a technology transfer seminar describing the results of the following tasks:

     1.    To develop and adopt comprehensive regulations governing the handling, processing and disposal of
           hazardous wastes;

     2.    To develop and test survey techniques and a questionnaire, and initiate a statewide survey of hazardous
           waste production;

     3.    To develop, test and implement a statewide surveillance and enforcement plan  for hazardous waste
           control; and

     4.    To develop and test model guidelines for land disposal of hazardous  wastes.

     However, as planning for  the seminar progressed, it became apparent  that the development and  ultimate
passage of the  Federal  Resource Conservation and  Recovery Act in  1976 had stimulated intense  interest in
hazardous waste management.  Consequently, EPA and the DOH decided to expand the half-day technology transfer
seminar into a 4-day national  conference. Perhaps one measure of the  wisdom of that decision was the attendees'
expressed desire for a second "National Conference about Hazardous Waste Management".

     The papers published in this  volume have been presented  in the same order as  they  were given  at the
conference.  They  were  received as manuscripts or  were transcribed  from tape recordings  made during  the
conference. All manuscripts and  transcripts were edited for  form, not content, and were submitted to the authors or
speakers for review prior to publication. The  majority of the reviewed documents were returned, and the suggestions
made were adopted wherever possible. Hopefully those who did not choose to return their papers were satisfied with
the editorial changes made.

     We would like to acknowledge the excellent work of Connie Davalos who composed the entire volume from
edited  manuscripts and transcripts. Her patience and skill are deeply appreciated.  We would also like to thank  Ron
Vikre for adapting some of the  illustrations for printing.

                                                                                       Eric B. Workman
                                                                                       Editor

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                                   TABLE OF CONTENTS


                                                                                     Page

KEYNOTE ADDRESS
    Senator John F. Dunlap  	   1

OVERVIEW AND OBJECTIVES OF HAZARDOUS WASTE MANAGEMENT
    John P. Lehman   	   3

DEVELOPMENT OF CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM:  FEDERAL ROLE
    Charles T. Bourns  	   6

DEVELOPMENT OF CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM:  STATE ROLE
    Harvey F. Collins, Ph.D., P.E	   8

DEVELOPMENT OF CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM:  COUNTY ROLE
    Phillip A. Beautrow, P.E	,	  14

WESTERN FEDERAL REGIONAL COUNCIL TASK FORCE FOR HAZARDOUS MATERIALS MANAGEMENT

    I. HISTORICAL BACKGROUND AND OBJECTIVES OF THE TASK FORCE
         Charles T. Bourns  	  16

    II. GUIDELINES FOR OPERATION AND MANAGEMENT OF HAZARDOUS WASTE DISPOSAL SITES
         David L. Storm, Ph.D	  18

    III. METHODS USED TO SELECT HAZARDOUS WASTE  DISPOSAL SITES
         Walter S. Weaver	  21

SUMMARY OF THE U. S. ENVIRONMENTAL PROTECTION AGENCY'S INDUSTRY
    STUDIES ABOUT HAZARDOUS WASTE MANAGEMENT
         Hugh B. Kaufman  	  22

CURRENT RESEARCH ON HAZARDOUS WASTE DISPOSAL
    Robert L. Stenburg and Norbert B.  Schomaker  	  26

USE OF MODEL LEGISLATION IN DEVELOPING A STATE HAZARDOUS WASTE CONTROL LAW

    I. MISSOURI HOUSE BILL 318
         Chilton W. McLaughlin   	  36

    II. NATIONAL SOLID WASTES MANAGEMENT ASSOCIATION'S MODEL LEGISLATION
         Rosalie T. Grasso   	  39

    III. U. S. ENVIRONMENTAL PROTECTION AGENCY'S MODEL LEGISLATION
        Murray Newton  	  41

METHODS PRESENTLY USED TO TREAT AND DISPOSE OF HAZARDOUS WASTES IN CALIFORNIA
    (CALIFORNIA CHEMICAL WASTE PROCESSORS ASSOCIATION)

    I. INTRODUCTION
         Leonard M. Tinnan  	  42

    II. METHODS USED IN NORTHERN CALIFORNIA
        Victor Johnson, Jr., P.E	  43

    III. METHODS USED IN THE SAN JOAQUIN VALLEY
        William H. Park  	  45

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                                                                                    Page

    IV. METHODS USED IN SOUTHERN CALIFORNIA
        Leonard M. Tinnan  	  47

    V. METHODS USED TO RECLAIM WASTES
        Kenneth O'Morrow  	  49

DISPOSAL OF HAZARDOUS WASTES AND INDUSTRIAL RESIDUES IN SANITARY LANDFILLS
    Robert E. Van Heuit. P.E	  50

DEVELOPMENTS IN THE LOW-TEMPERATURE, MICROWAVE-PLASMA PROCESS FOR
    DISPOSAL AND RECOVERY OF HIGHLY TOXIC HAZARDOUS WASTE
        Donald A. Oberacker and Lionel J. Baffin	  54

LARGE-SCALE RECOVERY AND RECYCLING OF SOLVENTS IN NORTHERN CALIFORNIA
    H. Michael Schneider   	  56

THE MANIFEST - GETTING HAZARDOUS WASTES FROM HERE TO THERE:
    CHEMICAL WASTE INDUSTRY'S VIEW OF MANIFEST PROGRAMS
        Rosalie T. Grasso  	  57

REUSE OF INDUSTRIAL RESIDUALS IN THE SAN FRANCISCO BAY AREA
    P. Chiu, Y. San Jule, M. Gorden, and J. Westfield   	  60

CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM

    I. OVERVIEW
        David L. Storm, Ph.D	  63

    II. HAZARDOUS WASTE CONTROL REGULATIONS
        Harvey F. Collins, Ph.D., P.E	  65

    III. CRITERIA FOR HAZARDOUS WASTES
        David L. Storm. Ph.D	  66

    IV. DEVELOPMENTS IN HAZARDOUS WASTE SAMPLING AND ANALYSIS
        Robert D. Stephens, Ph.D.	  70

    V. AUTOMATED DATA MANAGEMENT FOR CONTROL OF HAZARDOUS WASTES
        Warren G. Manchester	 .  75

    VI. FIELD SURVEILLANCE AND ENFORCEMENT
        Peter A. Zizileuskas  	   	  81

    VII. A CONTINGENCY PLAN FOR SPILLS OF HAZARDOUS MATERIALS
        James L. Stabler, P.E	  82

    VIII. SURVEY OF HAZARDOUS WASTE PRODUCTION
        George R. Sanders  	  84

    IX. RECYCLING AND RESOURCE RECOVERY: VITAL ELEMENTS
        IN THE MANAGEMENT OF HAZARDOUS WASTE
             Carl G. Schwarzer  	  86

    X. PESTICIDE WASTE DISPOSAL METHODS AND THEIR POTENTIALS
        FOR ENVIRONMENTAL IMPACTS
             Paul H. Williams, Ph.D	  88

CORRELATION OF BATCH AND CONTINUOUS LEACHING OF HAZARDOUS WASTES
    M. Houle, D. Long, R. Bell, D. Weatherhead, and J. Soy I and  	  90
                                            111

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                                                                                        Page

AN EVALUATION OF THE WEATHERING METHOD OF DISPOSAL OF
    LEADED-GASOLINE STORAGE TANK WASTES: A SUMMARY
         Howard K. Hatayama, P.E. and David Jenkins	107

SELECTION OF ADSORBENTS FOR IN-SITU LEACHATE TREATMENT
    P. C. Chan, J. W. Liskowitz, A. J. Perna, M.J. Sheih, R. B. Trattner, and F. Ellerbush   	121

HEALTH ASPECTS OF LAND APPLICATION OF SEWAGE SLUDGE AND SLUDGE COMPOST
    E. Epstein, J. F. Parr, and W. D. Surge	133

DESTRUCTION OF HAZARDOUS WASTES BY MOLTEN SALT COMBUSTION
    S. J. Yosim and  K. M. Barclay  	146

ASSESSMENT OF INDUSTRIAL HAZARDOUS WASTE MANAGEMENT
    PRACTICES IN THE LEATHER TANNING AND FINISHING INDUSTRY
         David H. Bauer, E. T. Conrad, and Ronald J. Lofy   	157

PETROLEUM REFINERY SOLID WASTE DISPOSAL PRACTICES
    Ronald J. Lofy, Ph.D., P.E	161

THE SOURCE, QUANTITY, AND FATE OF MERCURY AND ITS COMPOUNDS IN SOLID WASTES
    William H. Van Horn and Gary G. Kaufman  	166

CLOSING AND REHABILITATION OF HAZARDOUS WASTE DISPOSAL SITES
    Amir A. Metry,  Ph.D., P.E	176

ENGINEERING STUDY OF STRINGFELLOW CLASS I DISPOSAL SITE
    Gordon P. Treweek   	189

INCINERATION OF  INDUSTRIAL WASTES
    C. Randall Lewis, Richard  E. Edwards, P.E., and Michael A. Santoro   	227

DESIGN AND PERFORMANCE OF A CHEMICAL WASTE DISPOSAL FACILITY FOR HAZARDOUS CHEMICALS
    A. J. Shaw, P. Eng. and B.  H. Levelton, P. Eng	235

DEVELOPMENT OF  A HAZARDOUS WASTE DECISION MODEL FOR THE STATE OF
    MINNESOTA - WHAT IS A HAZARDOUS WASTE?
         James A. Kinsey	 . 242

DECISION MODEL FOR DETERMINING THE SUITABILITY OF LANDFILLING HAZARDOUS WASTE
    Cary L. Perket,  P.E	253

A QUANTITATIVE APPROACH TO CLASSIFICATION OF HAZARDOUS WASTE
    L C. Mehlhaff, T. Cook, and J. Knudson   	267

PLANNED EVOLUTION TO PROPER DISPOSAL
    Robert F. Heflin 	271

AN INVENTORY OF HAZARDOUS WASTES IN MASSACHUSETTS
    Paul F. Fennelly, Mary Anne Chillingworth, Peter D. Spawn, and Mark I. Bornstein, et al	273

SHIPPING CONTROL OF INDUSTRIAL WASTE IN TEXAS
    Jay Snow, P.E.	282

PROPER DISPOSAL  OF HAZARDOUS WASTES IN MISSOURI
    R. W. Pappenfort   	293

SUMMARY AND CLOSING REMARKS
    Richard F. Peters   	299
                                              IV

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                                               KEYNOTE ADDRESS

                                              Senator John F. Dunlap
                                                 State Legislature
                                                 Sacramento, CA
      Basically  I would like to discuss  with  you political
philosophy as it relates  to problems of hazardous waste
management. 1 first  became  seriously  interested in the
subject  of hazardous wastes in 1970 when  some  horses
pastured in my assembly district died, presumably from
lead poisoning, near the Carquinez Strait Bridge that joins
Solano  and Contra Costa counties. A smelting  plant, the
former Benicia  Arsenal, and an industrial waste dump were
probably  the sources of  the lead  that  had  apparently
contaminated the grass on which the horses had fed.
      This incident  indicated to me that  we needed tougher
laws. As a  result,  1  introduced hazardous waste control
legislation in 1971, but it was defeated  by  tough lobbying
from industry in the California Senate Finance Committee.
In  1972   I  reintroduced  similar legislation.  Assembly
Bill 598 (AB 598), which becarru  California's  present
Hazardous Waste Control Act. Three factors contributed to
the success of that law: (1) the bill had been improved over
the 1971  version;  (2) the need for the  legislation was far
more clearly demonstrated after  the  passage of additional
time; and (3) the legislation had developed a  constituency.
Quite often the legislative process may take years to bring
about change, but  sometimes this delay  is good because the
initial  ideas  that  people   have  might  need  further
development before they should be enacted into law.
      I  would like to discuss briefly our changing political
ethic as it relates to nature, science and mankind's place in
the scheme of  things. When I graduated from Napa High
School  in   1940,  the  Bay  Area  was  celebrating  the
completion of  the  San Francisco-Oakland  Bay Bridge and
the Golden Gate Bridge  at the World's Fair  on man-made
Treasure Island. The fair drew the attention of President
Franklin D.  Roosevelt who referred to  Treasure Island  as,
"America's   latest insular  acquisition, acquired  without
territorial aggression". I  really felt proud because I lived
near  an area where these great  events were happening.
Twenty-seven years later, in 1967, I became a member of
the California Legislature. That year we convinced the State
Division of Highways that a suspension bridge, similar to
the Golden Gate Bridge, should not be built across Emerald
Bay at  Lake Tahoe even  though the proposed bridge would
have been a great convenience. About a  year or two earlier,
the  Legislature had created the Bay Conservation and
Development Commission, an  organization that would
prevent you from building Treasure Island if you tried to
do so today. Events that had  made me proud in 1940 were
no longer acceptable.
      I  would  now  like to  look at the  background of
California's  Hazardous  Waste  Control   Act  from  the
standpoint that such laws are  not passed by one legislator;
he or she  merely  happens to be in  the right place at the
right time. More than 4 years before I became involved with
hazardous  wastes,  the California  State  Department of
Health (DOH) had  obtained a Federal grant to investigate
the waste disposal situation statewide. By 1970, the DOH
scientific  investigation  had been  completed,  conditions
were right to capture the public's interest, and we were in
the right place at the right time. The legislative process had
required  researchers, a politician,  and horses to  secure
passage of the Hazardous Waste Control Act.
      I would  like to comment briefly about the broader
significance of the  horses. Occasionally people talk about
conservationists  as  posy-pluckers.  I  would prefer to look
upon the posies, or  horses, or things  of that nature, as
thermometers  of  our  industrial  society,  similar to  the
canaries that miners formerly carried with them into  the
mines to determine  whether fumes in the air had reached
toxic  levels.  Because the canaries  were weaker than  the
miners, the miners were forewarned to leave if the birds
were overcome by fumes. In some respects our situation is
more difficult  because we humans  are probably only as
tough as some of the other living elements in nature.
      I would now like to consider some of the essential
elements of California's Hazardous Waste Control Act. The
law: recognizes the dangers of industrial waste; calls upon
the DOH to define and respond to  these dangers; provides
for safe waste  disposal; and establishes a manifest system
that  enables  the  DOH to  track  the transportation of
industrial wastes. However, the essential elements  of the
law from a political viewpoint are the provisions for the
creation   of  the  Hazardous  Waste  Technical   Advisory
Committee, and  for the  collection of fees  levied on
hazardous waste disposal to pay for operating a statewide
Hazardous Waste Management  Program. The  Committee is
important so that government can work with industry  and
others as  the program progresses. The fees for support of
the  program were not part of my  original bill. Later  I
became convinced  that fees would compel  producers of
industrial wastes to add the amounts of those fees to the
purchase  prices of their products,  rather than offer their
customers a subsidy from the general public if funds for
program support were provided by general taxation.
      We  now   have  the  new  Federal  law,  the  Resource
Conservation and Recovery Act  of 1976 (RCRA), which
parallels the Hazardous Waste  Control Act. I  believe that if
a  state shows resolve by trying to solve a problem on its
own, action from the Federal Government will follow. As a
result  of the  new Federal  law,  California law has some
catching up to do,  but I know that the DOH will be ready,
willing, and able to work with the  Legislature in order to
bring California law  into compliance with the Federal law
in a timely manner.
      In conclusion I would like to  leave  you with a few
additional thoughts. I believe that  recycling  is the  best
                                                        -1 -

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means of  handling hazardous wastes.  I  become scared
politically when I think of long-term storage as a means of
handling hazardous wastes because not only do we run the
risk that the wastes might  escape,   but we also have the
political problem of having to guard the wastes. If we have
too much  waste in too  many places to guard,  I wonder
what  social  effect this  will have on our free society.  I
believe  that this  is a  great challenge to all  of  us both
politically and scientifically.
      What  I consider to be the first maxim of conservation
is, "When in doubt, preserve".  If human beings have a basic
right  to walk on the earth, breathe the air, and drink the
water, we  ought  to be sure  that we  are not going to
interfere with that basic right before we decide to improve
on nature.  The law is beginning  to  recognize  that the
burden of proof rests on the person who seeks to tamper
with nature. In 1940 we thought that our manifest destiny
was to conquer  nature, but nature has kicked back a lot
during the last 37 years and will probably continue to do
so. Perhaps now we have learned that our destiny, if there is
one, is to live with  nature.
      With  regard to  various  scientific  and  industrial
endeavors, people  raise the  concern  that  we cannot live
without some risk. However, sometimes decisions must be
made as to which  risks we take and which  risks  we do not
take.  The political  process makes it possible for everyone to
share  the responsibility  for making those decisions. We are
in politics together whether  we like it or  not, and I look
forward to working with all of you over a long period of
time.
                                                        -2-

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                     OVERVIEW AND OBJECTIVES OF HAZARDOUS WASTE MANAGEMENT

                                             John P. Lehman, Director
                                       Hazardous Waste Management Division
                                               Office of Solid Waste
                                       U. S. Environmental Protection Agency
                                                 Washington, D.C.
     This conference is sponsored jointly by a consortium
of Federal, state, and  local governmental agencies, a fact
that bodes well  for  the future  because,  if all levels of
government can get together sufficiently to put on a major
hazardous waste conference like this one, there is hope that
we  can  work  together in the  future  to develop and
implement  a  national  hazardous   waste  management
program as well.
     As part of my presentation this morning, I would like
to  review  the highlights  of  the  new Federal  Resource
Conservation and  Recovery  Act (RCRA) to provide a
framework   for   my   overview  of  hazardous   waste
management. Basically, the objectives of the new law are to
promote  the  protection   of  public  health  and the
environment and to conserve material and energy resources.
In order to meet these objectives, the law:  requires EPA to
provide technical and financial assistance to state and local
governments  for the  development and implementation of
solid  waste  management   plans; prohibits future open
dumping  on land  and  requires  upgrading or closure of
existing  open  dumps;  regulates  the treatment,  storage,
transportation and disposal of hazardous  wastes;  requires
EPA  to develop  guidelines  setting  forth proper  waste
management   practices;  provides for demonstration of
improved solid  waste management and  resource recovery
systems; and, most importantly, establishes a cooperative
approach to  all  aspects  of  waste  management  among
Federal, state and  local government and private enterprise.
      I will now highlight 5 major aspects of the new law.
(1)The  new  law  includes several important  definitions.
"Solid waste" is no longer just solid because the term has
been  redefined  to  include  waste  sludges,  liquids and
contained gases from industrial,  commercial, mining, and
agricultural operations as well as the garbage and refuse that
we usually consider to be solid waste. The definition also
includes hazardous waste  as  part of solid waste, so the
scope  of  solid  waste  management  activities has  been
expanded significantly.
      "Disposal"  has been  broadly  defined  to   include
"... the discharge, deposition, injection, dumping, spilling,
leaking,  or placing of any solid waste or  hazardous waste
into or on any land  or water so that such solid waste or
hazardous waste or any constituent thereof may enter the
environment or be emitted into the air or discharged into
any  waters,   including  ground  waters".  The  explicit
reference to  ground  water emphasizes that solid waste
disposal has impacts  on all  aspects of the environment.
 EPA,  state and local governments  must  consider those
aspects when carrying out the provisions  of the new law.
The new definitions  of "solid waste" and "disposal" will
clearly require EPA to update  the  sanitary landfill  and
incineration guidelines  that were developed  previously by
the Office of Solid Waste.
      (2) Technical assistance teams are to  be formed to
provide  state  and  local  government  with advice  and
assistance upon request regarding all aspects  of solid waste
management, including hazardous waste management and
resource   conservation. The  act  somewhat confusingly
names these teams Resource Conservation  and  Recovery
Panels. As we currently  envision them,  the teams  will
operate from  EPA's 10 regional offices. No less than 20
percent of the funds appropriated for this  act are to be set
aside for technical  assistance,  a  fact which  reinforces
Congress' intent  that  technical assistance  is not  to be
overshadowed  by the  regulatory  provisions of the  law.
Congress can set  priorities two ways:  either by mandating
action within a certain time period or mandating action by
the  amount of money appropriated.  In the latter sense,
Congress has put a priority on technical assistance.
      (3)  EPA must develop  criteria for determining what
constitutes a sanitary  landfill and  an open  dump. Due to
the  expanded  definitions of  the terms "solid waste" and
"disposal",  these criteria  might well  apply  to many  land
disposal  practices  other  than the traditional  landfilling
method which we use for garbage and refuse.
      All open dumps  must be inventoried. We believe that
the states should  conduct that inventory, because they will
have  to   know  where  those  dumps   are   anyway.
Subsequently, EPA will publish a list identifying every open
dump in the country,  probably within the next two years.
Furthermore, all  open  dumping will become  illegal within 2
years, unless a time schedule  for closing or upgrading each
dump to sanitary landfill status has been established as part
of a  state  solid  waste   management plan.  Under no
circumstances can compliance with the prohibition of open
dumping take  longer than 5  years after EPA publishes the
inventory. Therefore,  7 years from  now, or by 1984, all
open dumping will be prohibited. That provision will have a
profound impact on solid waste management practices in
this country, particularly in rural areas.
      (4) In cooperation with local governments, the states
must develop comprehensive  solid waste management plans
that  provide not only for the typical refuse and garbage,
but for  hazardous wastes and resource conservation  and
recovery  as well. Few states already  have  comprehensive
plans, so the law provides for substantial new planning and
 implementation grant  programs to enable state and  local
governments to develop such  plans.
      (5) Under the new law all Federal facilities engaged in
solid waste or hazardous waste management activities and
                                                        -3-

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all  Federal  agencies  having jurisdiction over solid  waste
facilities, e.g., the Bureau of Land Management, are subject
to  all  Federal,  state,  and  local  requirements,   both
substantive and procedural, including reporting and permit
requirements. This is a major departure from precedents
established  under  the Federal Air  and Water  Pollution
Control Laws.
      The   new   law  contains   many  other  important
provisions that I  do not want to slight. For example, there
is an  entire section devoted to research, demonstration, and
development. I hope these highlights that I  have noted will
give you a  sense of the scope and direction that Congress
intends  for solid waste management  activities in  this
country and will put into focus the hazardous waste part of
the new law. Clearly, the nation  has entered a new phase.
For  the  first time.  Congress has  mandated  a Federal
regulatory  program  governing  land disposal.  However,
Congress  intends that the  states should  implement  the
regulatory program as part of  a comprehensive solid waste
program, and special  grants  for the  development and
implementation  of  state hazardous  waste programs  are
included in the law for that purpose.
      Before the new law was  enacted, our program at the
Federal level was really aimed at developing a better data
base  concerning  hazardous waste characteristics, damage
assessment  and control technology options, and translating
these data into advisory guidances and assisting the states in
developing  their  programs by providing technical assistance.
Now that the new law has  become effective, most of these
functions are still part of the Federal program, but the
emphasis   has   definitely   shifted  to   developing  a
comprehensive integrated set of national standards for the
definition of, and  the  "cradle-to-grave" management of,
hazardous wastes. What were originally to be guidances will
now  be Federal  regulations. These  new powers  will bring
added  responsibilities, so we  can no longer philosophize
about the way hazardous waste should be managed; we are
now  mandated  to  say  how hazardous  waste will be
managed. The program we  develop has to be tough enough
to  respond  to the congressional mandate  and to protect
public health and the environment, yet be practical enough
that  state   and   local governments  can  implement  the
program and that the private  sector can live with it. This
program  must  be developed  and operating by October
1978. Clearly, those of us at the Federal level cannot do the
job alone.
      I believe that most people will agree that the state
level  is the optimum  level of government at  which  the
hazardous waste management regulatory program should be
implemented. Many  hazardous wastes are transported for
hundreds of  miles to treatment  and disposal sites  within
and outside of the state of origin, and  local and regional
governments are not equipped to deal with this situation.
However, the Federal Government is not equipped to deal
with  state-by-state variations in climate, geology, and other
factors   which   influence   proper   hazardous  waste
management. Many people  in the private sector and in state
government would like to  see uniform national  standards
for hazardous waste management to remove the specter of
each  state  having  different  standards, definitions,  and
criteria.  In  my  view,  this  argues  forcefully  for  a
Federal-state  partnership for developing and implementing
the new national program, but local government will also
have a strong say in this matter, because the treatment and
disposal facilities which we must have to make this program
work will be located within local jurisdictions. Fortunately,
most states agree with this premise, and several states have
already begun to develop their own programs in advance of
the Federal program.
      Most of you probably have a reasonably good idea of
what the new law requires in the area of hazardous waste
regulatory  programs,  but perhaps you have not  thought
about how the parts  fit together.  The law addresses: the
definition  of  a  hazardous  waste;  national  standards
governing the treatment, storage, disposal, transportation,
and  generation   of such wastes;  a  permit program for
hazardous  waste facilities; guidelines for state  programs;
and  a system whereby anyone  who handles  hazardous
wastes must notify the government of that fact.
      The  keystone of the program,  in  my view,  is the
definition  of hazardous waste,  because that definition will
determine  the scope of the program and  thus influence
whether states choose  to participate in  it.  The definition
will also determine the  economic impact of the program on
industry. Our goal is to  base the definition of hazardous
waste on objective criteria or hazardous parameters such as
flammability, toxicity,  or corrosivity. This goal implies that
we   must  develop  standardized  testing,  sampling, and
analytical  methods by  which a waste can be tested against
these criteria. Wastes found to be hazardous will be placed
on the list of hazardous wastes required by the law.
       The  national standards for generators, transporters
and  operators of hazardous waste  treatment, storage, and
disposal facilities represent ^minimum levels of performance
that  are  somewhat  analogous to speed  limits on  the
 highway. They  are independent, enforceable standards, and
various legal sanctions can be applied to violators. Note that
all patties  subject to  the national standards are required to
 notify EPA,  or the  state if the  state has an  authorized
 program, during a 90-day period immediately following the
final  promulgation and  publication of  the definition of
hazardous waste. During those 90 days, we are  going to
receive notification  from  tens of thousands,  or perhaps
hundreds of thousands, of people  stating that they are in
some way  involved in hazardous waste management.
       Elements  common to all of the national standards
include the record keeping  and reporting requirements and
the compliance  with a manifest  system. The manifest is
basically a tracking and control  mechanism to  make sure
that  hazardous  wastes are transported to an  approved
treatment  and disposal facility. Each  waste shipment will
require a manifest. Therefore, we expect tens of thousands
of  transactions per  year,  and  that  large  number  of
transactions  implies that the manifest must be compatible
with data processing  systems. Because  wastes are often
transported across state lines, we are led to the  conclusion
that the manifest system should be uniform nationally.
       Hazardous waste  generators and transporters are not
required to obtain  permits; only operators of facilities that
treat, store, and dispose of such wastes must do so. We look
                                                         -4-

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upon  the permit system in  a  positive sense.  A hazardous
waste facility can obtain a permit only if Federal or state
authorities believe that the surrounding community will be
safeguarded. If we can  impart that concept to the public,
then  we will  have  gone a  long  way toward overcoming
public  opposition  to  new  hazardous  waste  facilities.
Congress   clearly   intended   for   states  to  implement
hazardous   waste   management   programs,   and
implementation of these programs implies issuing hazardous
waste  facility  permits  and  conducting  inspection  and
enforcement  activities.  Several states including California
do these things already.
      One  potential  problem that  we  see  is that state
programs,  in order to be given  implementation authority
for RCRA, must be "equivalent" to the Federal program
and "consistent" with other state programs. At this time we
are trying to fathom what Congress meant by "equivalent"
and "consistent" and will be asking for your opinions as to
what  you believe  these terms  mean. Congress evidently
foresaw  this  problem because the law provides for interim
authorization  of state programs during a 24-month period
while the details of full authorization are being worked out.
We intend to be liberal  in our  requirements for interim
authorization  with the understanding  that state programs
will  achieve  equivalence  during  this 24-month transition
period. Two years from now most states should  have at
least  interim, if  not fully authorized programs, and  2 years
after  that most states should have reached full equivalence.
      We do have Federal grant funds that are mandated for
the development and implementation  of state programs.
The  new law  mandates an integrated, comprehensive
program keyed to the definition of hazardous wastes, and a
series of  implementation  provisions.  These  provisions
consist of the national standards, the notification system,
and the facilities permit system. We feel that all of these
elements should be developed by the Federal Government
to provide nationwide consistency, but we fully intend that
the   states implement  and  enforce  them  with  federal
financial and technical assistance.
      We have  produced development  plans for proposed
hazardous waste  regulations, and  these  plans state the
purposes of the regulations, identify the major issues as we
see  them, and outline how  we  will  coordinate  this
regulatory development:  with other EPA offices,  such as
the  Office of  Enforcement, the  Office  of  Air Programs,
Office of Water Programs, Toxic Substances, and Office of
 Research  and  Development;  with other federal agencies;
with  state and local governments; and  with Congress. As
part  of  these  plans  we  have  made  some  preliminary
estimates  of  anticipated requirements  for environmental
and  economic  impact  appraisals  and  have provided an
anticipated  schedule  for  promulgation of  regulations.
 Presently, we are projecting the final promulgation of the
 hazardous waste  regulations  to be on schedule  in  April
 1978,  which is 18  months  after  enactment as  the law
 requires.
      We  are now preparing  advance notices of proposed
 rule  making which will be published in the Federal Register
 in the  next few months. These documents are intended to
 alert the public that EPA is  embarking on  the regulation
development  process and to solicit public comment on a
number of issues and  options  being  considered  by the
agency. I hope everyone here will comment on these issues
and  options,  because  we  really  do  need  input.  The
regulations  will  be  developed   in  EPA  by  carefully
structured  working  groups composed  of  representatives
from   EPA's  headquarters  and  regional  offices ^and,  if
appropriate, representatives from  other federal agencies,
and from state and local government.
      Perhaps this is a departure from past practice, but we
intend to have at least  a few representatives of state and
local governments on the working groups themselves. All of
these working groups are to be activated next week.
      EPA intends to provide ample opportunity for public
participation  in the development of these regulations. We
held public meetings about the new law in Washington last
December. Similar  meetings  are scheduled  in all 10  EPA
regions throughout the country later this month and early
in March. In addition, two sets of public hearings on  each
regulation are planned. (We hold a public meeting to  hear
the public voice  its opinions; we  hold a public hearing to
present a  proposal and receive comments specifically about
that proposal.) We intend to hold  1 public hearing after we
have  digested the  responses  received  about the advance
notices of  proposed  rule making and a  second  public
hearing after we have digested the comments received about
the  proposed rules. Also, we intend to form an advisory
committee, comparable to the Hazardous Waste Technical
Advisory  Committee established by Senator Dunlap here in
California,  to  review and   comment  on the  Federal
hazardous waste  regulations as they develop. In addition,
we plan a series  of conferences and workshops on specific
technical  issues  as  they  arise during this  period.   For
example,  we  are already  planning such a  conference to
discuss the application of the standard leaching tests as they
relate to the question of the definition of  a  hazardous
waste.  Lastly, we plan  to   develop a public  education
program  to  communicate the essence of  the  hazardous
waste issues to  the general  public. We intend to use the
public  education program, presently being pursued by the
State  of Minnesota {as part  of the chemical waste landfill
grant program), as a useful  model for this national program.
       In  summary,  RCRA covers a wide  range  of  new
initiatives in solid waste management  which will  have a
substantial  impact  on public health   and  environmental
protection,  on  material  and  energy  conservation   and
recovery. The hazardous waste management program is a
part  of this overall program. While our attention is now
focused on developing the new hazardous waste regulations
and guidelines that are mandated by the law, we  also will
continue  our  technical assistance and public education
efforts. The regulations are but the first step in a national
 hazardous waste management program. A  joint effort by
 Federal, state and local governments, by industry and the
 public, will be needed to translate these beginnings into an
 effective  program to protect the public health  and the
 environment  from  the   potential damage  inherent in
 improper hazardous waste management practices. Congress
 has given us the  green light to proceed with our program. It
 is now up to all of us to make it work.
                                                        -5-

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                             DEVELOPMENT OF CALIFORNIA'S HAZARDOUS WASTE
                                   MANAGEMENT PROGRAM:  FEDERAL ROLE

                                              Charles T. Bourns, Chief
                                    Solid & Hazardous Waste Management Program
                                                    Region IX
                                       U. S. Environmental Protection Agency
                                                San Francisco, CA
      I would like to recount briefly the Federal role in the
development of California's Hazardous Waste Management
Program.  In California the  State  Department of Health
(DOH) originally held the entire responsibility for acting on
environmental matters,  but had limited legal authority for
doing so. To correct this problem in part, the California
Legislature first established regional water quality control
boards whose primary concern was to protect surface and
ground water quality. Each of these boards operated rather
independently  for quite a while, but their independence
created  some cross-boundary problems. So, the Legislature
established  the  State  Water  Resources  Control  Board
(SWRCB) as the parent organization to which the regional
boards  had to respond. However,  the  state and regional
boards had the  responsibility for protecting water quality
and did  not concern  themselves  too  much with  other
aspects of environmental protection. The DOH still retained
primary responsibility for the protection of health, safety,
and the  environment,  although  its authority remained
somewhat limited.
      About 10 years ago the Federal Government entered
into an  agreement with the DOH that provided grant funds
through the  Solid Waste Management  Office,  Department
of  Health  Education and Welfare, to do planning for solid
and hazardous  waste management. We. worked with the
DOH in assessing hazardous waste management problems in
California,  and   the   DOH  published  several   reports
summarizing this  work. Most of you have some of these
reports or have seen them. This work led to the passage of
California's  Hazardous  Waste   Control   Act  of   1972
(AB 598).  I  was privileged to participate  in some of the
early  discussions  regarding this  legislation.   AB 598,
introduced  by  Senator Dunlap,  gave  to the DOH the
responsibility for regulating hazardous  waste  management
and provided  enforcement  powers.  At  the  same  time
another  state  law,  the  Solid   Waste  Management  and
Resource  Recovery Act of  1972  (SB 5), established a solid
waste management program under a new board called the
State Solid Waste  Management Board (SWMB). Inevitably
there were some overlapping authorities between the new
SWMB and the DOH.
      I  must  back up  a  bit and say  that the  SWRCB
preempted solid and hazardous waste management because
disposal  of these  wastes  did affect  water quality.  The
SWRCB   established   a  system   for  categorizing
wastes:  Group  I wastes are primarily hazardous wastes;
Group II wastes  are primarily decomposable wastes, such as
residential  and commercial garbage and refuse; Group III
wastes are primarily inert wastes, such as demolition wastes
which result from the destruction of buildings and bridges.
The  SWRCB also established a system  for  categorizing
disposal  sites  to  receive  these  wastes:  a  Class I  site is
theoretically  capable  of  receiving  any  group of  waste
without creating any hazard to surface or ground waters; a
Class 11   site affords  some  protection  to surface  and
ground waters, but cannot receive Group I wastes; a Class 111
site  affords  little protection to surface and ground waters,
and  can only receive Group 111 wastes which present a very
low  hazard to those waters.
      Actually  a  3-way  overlap   of  authority  existed
regarding  solid   and  hazardous  waste  management  in
California, because SB 5 charged the DOH with guiding the
new SWMB by writing regulations for health-related aspects
of solid  waste disposal. Thus, 3  agencies, all of whom
undoubtedly wanted  to build an  empire, had  to work
together. They have done so quite well with a minimum of
friction and now have  an interagency committee which
meets  frequently to coordinate  their activities. EPA has
worked with  all 3 of  these agencies by providing  both
technical assistance and grants.
      We have invested quite a bit of money in California's
Hazardous Waste Management Program.  From  1971  to
1974 we spent nearly $113,000 for planning, which  led to
the  development of the State's Hazardous Waste  Control
Act, and for developing the State's new regulatory program.
In  1974, we provided  additional  money  to  California's
program which was starting up with limited funds. We had
decided  that we would like to  see  the program  develop
faster  and progress further  because  we were anticipating
Federal  hazardous waste control  legislation.  Also, we
needed to develop considerable technology. Therefore, we.
awarded  California a 2-year, $220,000 grant in 1974.
      I will  discuss some of the tasks that the State agreed
to do as  part of that 2-year grant. We have also added a few
tasks to  the grant since  1974.  For example,  disposal of
pesticides and their containers has been quite a problem
throughout  the  nation,  so through  the Office of Pesticide
Programs in Washington,  D.C., we added $100,000 to the
original grant to enable California to develop model state
guidelines and a  model  EIS regarding disposal of pesticide
containers and wastes.  In 1975 and 1976 we again  added
money and tasks to the grant to accelerate implementation
of California's  Hazardous Waste  Management Program.
Thus, EPA  has  invested roughly $769,000 in the  State's
program. This amount represents about 40 percent of the
total program.   The   total   cost  from  1971  through
September  1976  has  been $1,838,000 from  State   and
Federal sources, combined.
     The grant  tasks for  the  development of  California's
Hazardous Waste  Management Program, other than  the
pesticide  program, were  as  follows:  (1)to develop  and
                                                       -6-

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adopt administrative regulations and enforcement standards      guidelines  for  land  disposal  of  hazardous  wastes  by
governing  the  handling,  processing   and  disposal  of      demonstration at a selected Class I site; and (5) to prepare a
hazardous wastes;  (2) to develop, test and produce a survey      final report and conduct a technology transfer seminar,
form, and plan and initiate a statewide survey of hazardous      which  is what  this conference is today. We believe that
waste production;  (3) to  develop,  test, and implement a      California has done very well  in  this regard and are quite
systematic, statewide surveillance and enforcement plan for      pleased with the effort to date. We will hear more about the
hazardous  waste control; (4) to develop and test model      results  of these tasks later in the program.
                                                          -7-

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                                      DEVELOPMENT OF CALIFORNIA'S
                         HAZARDOUS WASTE MANAGEMENT PROGRAM: STATE ROLE

                                           Harvey F. Collins, Ph.D., P.E.
                                     Supervising Waste Management Engineer
                                      California State Department of Health
                                                 Sacramento, CA
     Solid and hazardous wastes have been of concern to
the  California  Department  of  Health  (DOH) for many
years.  However, the DOH  had no resources to do much
more than recommend that vector control programs be
established.   Not  until  the  Federal  Government
implemented  the Solid  Waste Disposal Act of  1965 did
statewide planning really begin.
      In 1966, the Governor designated the DOH to be the
agency to  receive grant funds authorized by the  Federal
law. That year, the DOH Vector and Waste Management
Section staff, augmented with personnel funded  by the
Federal grant, undertook the task of assessing the problems
associated with solid waste management. The results of that
assessment revealed that large quantities  of  potentially
hazardous wastes were creating health  and environmental
problems. A subsequent study conducted by the  DOH, also
made possible by Federal funding, further documented the
serious health and environmental problems that could result
from mismanaged hazardous wastes. The scene in Figure 1
is representative of  what was then prevalent statewide. The
DOH study received the attention of Senator Dunlap and
other members of the California Legislature, and resulted in
passage of California's Hazardous Waste  Control  Act  in
1972. A key element of that law was the establishment of a
Hazardous Waste Technical  Advisory Committee that has
been invaluable to the DOH. The  law was   to become
effective in July 1973, but due to technical problems, staff
could  not be  recruited  until  fall 1973.  It  took  until
July 1974 to  adopt regulations governing  the essential
elements  required by the  law. These regulations included:

   • A manifest (trip ticket) (Figure 2);

   • A listing of  hazardous  and extremely  hazardous
     wastes;

   • A fee schedule for support of the State's regulatory
     program; and

   • A procedure for receiving a required permit from the
     DOH for the disposal of extremely hazardous wastes.

     Guidelines published by  the DOH along with the
regulations defined the "do's" and  "don'ts"  of mixing
incompatible wastes, regardless of whether the wastes were
in bulk or in containers.
     The first major problem the DOH faced was trying to
ascertain the types and quantities of hazardous wastes being
produced in the State in order to establish fees.  I know of
at  least 2 individuals in California who firmly believe that
                                                   FIGURE 1

                            AN OPEN, BURNING DUMP IN NORTHERN CALIFORNIA

                                                      -8-

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                                                                                  FIGURE  2
      R*vlMd December 1974
                                                CALIFORNIA  LIQUID  WASTE  MAULER  RECORD
                                                                                                                                           I   I   I  I  I  I   I   I   I
                                                                     STATE WATER RESOURCES CONTROL  BOARD
                                                                          STATE DEPARTMENT OF HEALTH
      PRODUCER  OF WASTE (Must  be  filled  by producer)

      turn (print or tYoa):

      Pick up Addrees:_
                                                                         Cod* No.
      Telephone Niaeber:^_

      Ordar Placed By;
                    (Number)
                    )	
(Street)       (City)
 P.O. or Contract N«._
                                                             Date
      Type of Process
      which Produced Until:
                     (Examples: metal plating, equipment cleaning, oil drilling.
                      wastewater treatment, pickling bath, petroleum refining)

DESCRIPTION OF WASTE (Must be  filled by producer)

Check type of wastes:
                                                                                odt No.
                         1. Q Acid solution
                         2. D Alk_llne lolutlon
                         3. D Pesticides
                         4. D Paint iludg«
                         5. D Solvant
                         6. Q Tetraathyl lead sludge
                         7. D Chemical tollat wastes
                                                    8. Q Tank  bottom sediment
                                                    9. O Oil
                                                   10. D Drilling mud
                                                   11. Q Contaminated toll and sand
                                                   12. Q Cannery waste
                                                   13. Q Latex waite
                                                   14. O Mud and water
                                                   IS. D Brine
          Other (Spaclfy)_
to    Components I
 •     (Exanplast Hydrochloric acid, line, cauatlc eoda,
       phanollcs,  solvents (list), metals (Hat),
       organlcs (list),  cyanlda)
                                              Upper
                                                       Concentration:
                                                        Lower       7.
                                                                           ppm
1.
2.
3.
4.
5.
6.
Hazardous Properties of Wests:
PH LJnone Qtoxlc __)f lanoable f"l corrosive
Bulk Volume: flaa! Qtonl _Jb«rr«li
(42 gal )
Containers: _- _*
(Number) |_Jdrums |_|cartons l_|bags
Physical State: Qsolld Q liquid Qiludge
Special Kandllna Instructions (If snv):

c
L
C
C
:
~~
I
.xp
fott
[ot>
|ott
lotlve
•r
.•r



—
=

clfy)
eclfy)
Specify)


      The waste  is  described to the best of  my  ability and it waa delivered to
      a licensed liquid waste hauler (if applicable).

      I certify  (or declare) under penalty
      of perjury that  the foregoing is true
      and correct.                            	
HAULER OF  WASTE  (Must  be filled by  hauler)

Name  (print or tvae);

Business Address:_

Telephone
                                                                                                                (NuBb«r)
    (Straat)
Pick Dp: 	
                                                                                                                                                  (City)
                                                                                                                                                        Tla
                                                                                                                                   (Date)
                                                                                   Stata Liquid Waste Haulsr's Registration No. (If applicable):_
                                                                                         Job No.:
                                                                                                                 No. of Loads or Trlps:_
                                                                                                                                                  Unit No.:
                                                Vehicle;    __|vacuum truck         barrels.  Qflatbed,  LJother

                                                The described waste was hauled by  me to the disposal
                                                facility  named below and was accepted.

                                                I certify tor declare) under penalty
                                                of perjury that the foregoing is true
                                                and correct.
                                                                                                                                                          (specify)
                                                                                         Signature of  authorized agent ana title
                                                DISPOSER OF WASTE (Must  be filled by  disposer)                ______

                                                Nave (print or typa);                                                   I   I   I   I
                                                                                                                      Code No.
                                                Slta Address: ___________________________________________
                                                                                   The hauler  aoove delivered the described waste to this disposal facility and
                                                                                   it was  an acceptable material under the terns of RWOCB requirements, State
                                                                                   Department  of Health regulation*,  and local restrictions.
                                                Quantity measured at  slta (If applicable):.

                                                Handling Hethod(s):

                                                  Q recovery

                                                  |~| treatment (specify):
                                                                                                                                                 State fee  (If any):_
                                                                                                               (Examples;
                                                                                           Q) disposal (specify):  Qpond
                                                                                                                  Incineration.
                                                                                                                  Mspreadlng
                                                                                                                  (specify);
                                                                                           neutralization. preclpltatlon)-Code No.
                                                                                             	  LJ Injection well
                                                                                         If waste la held for disposal elsewhera specify final location:

                                                                                         Disposal Pate:
                                                                                         I certify (or  declare) under penalty
                                                                                         of perjury  that  the foregoing is  true
                                                                                         and correct.                             	
                                                                                                                                  Signature of authorized  agent and title

                                                                                         The site operator shall submit a legible copy of each completed Record to the
                                                                                         State Department  of  Health with monthly fee reports.
                                                                                       FOR INFORMATION  RELATED TO SPILLS OR OTHER EMERGENCIES INVOLVING
                                                                                            HAZARDOUS WASTE OR OTHER  MATERIALS CALL (800)  424-9300.
                                               Signature of authorized  agent  and title

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we  need to complete  detailed  hazardous waste surveys in
every county statewide. Those 2 individuals are Phillip A.
Beautrow of  Ventura  Regional County Sanitation District
and I.  In 1974 we  coauthored  California's  first  grant
application subsequent to passage of the State's Hazardous
Waste  Control  Act. That  grant  called for  the Ventura
Regional County Sanitation District to develop a survey
form and to complete an industrial waste survey in Ventura
County. Phil will be telling you  more about that later. To
date, we have completed surveys  in 6 counties using the
form and techniques developed  in Ventura  County.  Nine
other counties are presently under contract with the  DOH
to complete similar surveys. The remainder of the State will
be surveyed as soon as sufficient resources can be obtained.
                                                   FIGURE 3
                           LOCATIONS OF CLASS I DISPOSAL SITES IN CALIFORNIA
                                                   FIGURE 4

                                       SURVEILLANCE VEHICLE IN USE
                                                      10

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                     FIGURES

      APPARATUS FOR SAMPLING HAZARDOUS WASTES
                         3/8" PVC  rod
72"
       60'
                         1-7/8" — outer dimensions
                         1-5/8" — inner dimensions
                         Class 200 PVC pipe
                          No.  9-1/2  neoprene  stopper
                          3/8" S.S. nut & washer
                        -11 -

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      The DOH was fortunate in obtaining additional EPA
grants to help develop other aspects of its program, such as
surveillance and enforcement. Our inspectors soon began to
document  problems at approved hazardous waste disposal
sites.  There  are  11   Class I  sites  (Figure 3)   and
approximately 50  Class 11-1 sites in  California, as  well as
private  sites  operated  by  industry.  We  have not yet
determined the total number of on-site dischargers or the
types and amounts of wastes disposed of on-site.
      We purchased trucks from the California Department
of  Transportation   and converted  them to  surveillance
vehicles with  mobile laboratories for conducting chemical
analyses in the field (Figure 4). One of these trucks will be
available  for  inspection. We  also  developed a sampling
apparatus  for collecting samples of wastes  from  waste
haulers' vehicles (Figure 5).
      In addition to the problems we have  documented at
off-site and on-site disposal facilities, we have apprehended
a  few people that had developed "emergency"  disposal
sites. One particular trucker developed an  emergency site
and saved approximately 24 miles on each  round trip that
he   made  to  deliver  wastes  (Figure 6).  Subsequent
investigations indicated that the address of this emergency
site was put on numerous  manifests. One  of our  research
chemists, David L.  Storm, Ph.D., and one of our engineers,
Lloyd  A.  Batham  III,  took  a  rather dim  view  of this
activity.  The  San Francisco  District  Attorney  and  the
California  State Attorney General concurred, so the case is
now in court.
     We started developing regulations at least 18 months
ago to cover these problems we encountered in the field.
After Congress enacted the Federal  Resource Conservation
and  Recovery Act (RCRA) last fall, we kept revising our
new  regulations  to  make  sure  they  were  essentially
equivalent to the hazardous waste management program
required  by  the  Federal  law.  I  will be  discussing those
regulations later in the week.  They  are  now  undergoing
legal review and subsequently  will  be heard publicly. We
expect to have them adopted  by mid-year.  Although the
present regulations  apply  only  to  operations at  waste
disposal sites that receive hazardous wastes from more than
one  source, the  proposed  regulations  will  apply  to
operations at all  disposal  sites that  receive  hazardous
wastes. They will also apply to all transfer stations, storage
facilities,  and treatment  facilities that receive  hazardous
wastes. They are far  more detailed  than the  present
regulations and explicitly prohibit undesirable  procedures
which  we have observed at some sites.  I should point out
that many of the sites are currently operating in such a way
that they  are in compliance with our proposed regulations.
The operator of one particular  site upgraded his operation
appreciably  at  our  request  and  is now  essentially in
compliance with those regulations.
      In addition to its proposed regulations, the DOH has
requested legislation that will  bring  California's program
essentially into compliance with RCRA.  Specifically, the
legislation will:  (1) authorize the  assessment of civil and
criminal   penalties  for  violations   of  the  law  or  the
                                                     FIGURE 6

                           TRUCKER DISPOSING OF HAZARDOUS WASTES ILLEGALLY
                                                        -12-

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regulations;   (2) authorize  the   DOH  to   establish  a
differential fee system that will encourage waste producers
to  recycle   hazardous   wastes;  (3) repeal  the  existing
requirement  mandating  the  DOH  to  adopt a  list  of
hazardous wastes and instead  require the DOH to develop
and maintain criteria and lists of  known  hazardous and
extremely hazardous wastes; (4) include certain infectious
wastes in the definition of hazardous wastes; (5) authorize
the DOH to:  (a) establish  a hazardous waste  cleanup and
abatement  account; (b) contract  for  services to  correct
conditions  that  result  from  improper management  of
hazardous  waste  and  that   imperil public  health; and
(c) obtain reimbursement  for  the  account from persons
who cause such conditions, through  billing, lien, or suit, if
necessary; (6) authorize  the  DOH  to register haulers  of
hazardous wastes to ensure that they are familiar with the
DOH  regulations and guidelines; and  (7) authorize the DOH
to prohibit the use of toxic chemicals in chemical toilets.
      The changes in  California's  regulations and the
changes (outlined above) in the law itself would ensure that
California's   program  is  essentially equivalent  to  that
required by RCRA. But - is that enough? Doesn't the spirit
of the  federal law encourage  resource recovery even of
hazardous wastes? Doesn't the management of hazardous
wastes  require  more  than  expertise  in science  and
engineering?  How  about  knowledge  of  the  4 laws of
ecology as defined by Dr. Barry Commoner? -

  First Law:    Everything is connected to everything else.
  Second Law:  Everything must go somewhere.
  Third Law:    Nature knows best.
  Fourth Law:  There is no such thing as a free  lunch.

               Barry Commoner
               The Closing Circle: Nature,
                 Man & Technology (1971)
      I cannot help but wonder about these laws  when  I
hear statements that  it is  not economically feasible to
recycle wastes. Yet, is the cost of dumping the wastes really
the total cost? If not, who is paying for the free lunch? Is it
EPA, state regulatory agencies, or could it be the land and
the environment?
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                                       DEVELOPMENT OF CALIFORNIA'S
                        HAZARDOUS WASTE MANAGEMENT PROGRAM: COUNTY ROLE

                                              Phillip A. Beautrow, P.E.
                                              Principal Civil Engineer
                                     Ventura Regional County Sanitation District
                                                   Ventura, CA
      The Regional County Sanitation District in Ventura
(VRCSD) collaborated with the California Department of
Health  (DOH) in preparing a  project proposal for  the
implementation  of California's  Hazardous Waste Control
Act, and obtained a grant from  EPA to support this effort.
The VRCSD was assigned two tasks for the project: (1) to
develop and test a hazardous waste survey form; and (2) to
formulate  model  guidelines governing land  disposal  of
hazardous waste.
      The VRCSD, a special  district encompassing all of
Ventura County, was  created  under  provisions  of  the
Sanitation District Act of 1939  and is unique in California.
The VRCSD is self-governing, with a 21-member board of
directors. We are responsible for the disposal of liquid and
solid wastes and  operate one  of the State's 11  Class I
disposal  sites.  Only about 200 different kinds of hazardous
wastes are produced in Ventura  County, so the county was
an  ideal place to  begin a manageable  hazardous waste
survey.
      How does one conduct a hazardous waste survey  and
obtain realistic results? Personal interviews would be ideal
but would be impossible on a statewide basis, so we decided
that survey by mail was the realistic course of action. We
looked at the  results that others had obtained in surveys by
mail. The State of Washington had conducted such a survey
and the results  were uniformly poor. We were told that
receiving a response rate of 30 percent would be fortunate.
Rather than turn to traditional technical survey procedures,
we looked at the mass merchandizing gimmicks that are
used  by  manufacturers and industry to get responses. After
developing  5  different   survey   forms   we eventually
developed  a  form  (questionnaire)  that  could  be used
effectively  in  all  of  California's  58 counties. The form
included all the  important questions, was brief and  easy to
complete, and made the reader feel that he was part of an
important  project. The questions  were clear and concise,
and did not  bias the  answers. Lastly,  the  format was
suitable for tabulating the results by computer.
      Many subtle techniques were employed in this  survey.
The survey form: was small (7 x 10 inches), so that it did
not look formidable; consisted of few pages, (only 4); was
printed on good  quality paper; was not overcrowded with
print and had decent margins.  We  used  a  few attention
grabbers, such  as  white  envelopes  that  were  not  the
standard business size,  so that  the forms would  not  be
identified with junk mail. We used  stamped envelopes to
mail out the forms because people feel free to throw away
unopened  envelopes  that  have  printed   stamps,   or
Pitney-Bowes postage meter stamps on them. Also,  we  put
stamps  on  the  return  envelopes  and  addressed them
individually because  people do not feel  free to  throw
stamps away. These are small items, but they  improve  the
response rate.
     Major  categories of  questions  used  on the form
addressed: the  company; the  industrial wastes produced;
the waste management procedures and processes employed;
the water used, wasted,  or reclaimed; and  the resources
recovered. The  specific questions used on the  form were
designed to: meet the goals set by the grant commitment
to EPA;  determine pollution controls or industrial waste
treatment  processes  utilized  by  industry; identify  the
industrial  wastes  produced   including their  quantities,
physical states,  and compositions. Some  of  the questions
covered 3 periods: the present, 5 years and  10  years from
now. We offered to share the results with the respondents
after the survey  had been completed.
     EPA has  found that  most  of the hazardous wastes
produced can  be  attributed  to  industries  in  10  general
Standard Industrial Classifications (SIC codes). We decided
to survey  the  industries  in the  county that belonged to
these 10 major groups because they were the  most probable
producers  of   hazardous   waste,  e.g.,  chemicals,  allied
products and electronics.  First, we conducted a test of our
survey  methods. We selected  10 percent  of  the industries
most likely to produce hazardous wastes in the county and
divided the group in half. We conducted personal interviews
with one half-group to  develop baseline survey data. We
sent a  postcard to the other half-group, notifying them of
the survey, and  mailed the questionnaires to them one week
later.  We  called   those  who  had  not  received  their
questionnaires,  analyzed  the  results of the  questionnaires
received, and  made minor changes  in the form of the
questionnaire. The results of the test indicated a 33 percent
response received voluntarily, which our research had led us
to  expect from a survey conducted  by mail. After  one
telephone  call  to  each  nonrespondent,  we  received
86 percent response  overall  to  the  mail   survey. After
completion of the test, we refined the form, simplified it
further, and surveyed the remainder of the county by mail
alone.  We ultimately obtained  an  85 percent response with
telephone follow-up for the survey as a whole. I believe that
the subtle techniques I have mentioned above can improve
the response to a survey by  mail.
      We concluded from our county survey  that: officials
of  major  companies required clearance  from a  higher
authority before they could release information; they often
had to  send  the  questionnaires  out-of-state to  their
headquarters for approval, a time-consuming process; some
of the small operators felt that the survey did not apply to
them;  some officials felt that the information could be used
against them, although we tried to maintain confidentiality
by  assigning a number to each company,  rather than its
name;  and some officials argued about the meaning of such
terms  as  toxic,  carcinogenic, irritant. In  summary, we
believe that  the  mail-type of survey can  work  if it  is
well-planned, and the percent  of responses received can be
high.
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     The second task that we were assigned as part of the
EPA grant was to formulate model guidelines for the land
disposal  of hazardous wastes.  As  I  indicated above, the
VRCSD operates one Class I site in the County of Ventura.
The  objectives  of the  task were:  (1) to  instruct  field
personnel; and   (2) to  assist engineers  in  planning  the
development  of  a  Class I  site.   VRCSD  received  a
demonstration  grant  from EPA  several  years  ago for
establishing a model Class I site,  and went through the
entire  procedure  from  start  to   finish   including  the
Environmental   Impact  Report (EIR).  Believe me,  the
procedure is frustrating and time-consuming. We indicated
wherever  possible the lessons to be learned and  short-cuts
to follow. We dealt with  permit applications from: the
local  land-use authority; Regional Water Quality  Control
Board; Coastal Commission; fire department; and others.
The  guidelines   we  developed  indicate: preconstruction
details; site  planning;  and the necessary  steps for site
operation.
     We  also documented what we  believe to be  ideal
procedures to follow when accepting wastes at a Class  I
disposal site. Too often a trucker with a load of hazardous
waste drives up to a site and says, "Here it is. You take it."
We do not follow that procedure at all. In Ventura County
we have developed  a  procedure whereby the disposal of
hazardous wastes requires an application. The application is
reviewed by VRCSD staff, and if it is acceptable, a disposal
permit is  issued. The permit indicates:  all the precautions
necessary  for handling the waste safely at the disposal site;
what tests of the waste should be made (e.g., temperature,
flammability, pH, etc.);  the  safety  gear required  of site
personnel; the method  of unloading;  and so forth. The
Class I site is subdivided into a grid pattern so that we can
ensure that compatible wastes are deposited in  the proper
locations.  We also  have indicated  in  the guidelines the
safety  procedures, equipment, and so forth that are needed.
The appendix of  the  guidelines document contains  a
description of all the methods of disposal that are used in
California, such as ponding,  mixing,  burial in wells, waste
treatment, and other procedures.
                                                         15-

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                                    WESTERN FEDERAL REGIONAL COUNCIL
                          TASK FORCE FOR HAZARDOUS MATERIALS MANAGEMENT

                     I.  HISTORICAL BACKGROUND AND OBJECTIVES OF THE TASK FORCE

                                              Charles T. Bourns, Chief
                                   Solid and Hazardous Waste Management Program
                                                     Region IX
                                       U. S. Environmental Protection Agency
                                                 San Francisco, CA
      Previously  I  had discussed  the  Federal  role  in
establishing  California's  Hazardous Waste  Management
Program. However, Region IX of the EPA includes more
than  just California:  3 other states, Arizona, Nevada, and
Hawaii are included, plus all U. S. territories in the Pacific.
In  fact, the total area of  Region IX encompasses about
25 percent of the world.
      We have  emerging  hazardous  waste  management
programs in Arizona and Nevada, and both states have now
completed assessments  of their hazardous waste problems.
Both states have also  completed drafting regulations which
are similar to those of California, and we hope that their
regulations  will reach  the  stages  of public hearing and
adoption later this year. Hawaii  has  written into the state's
new solid waste regulations a section on hazardous waste,
but those regulations  have  not gone far enough to be really
enforceable in my opinion. We have no  hazardous waste
control regulations in  the Pacific territories at this time.
      One of the problems in these other states and in the
Pacific territories is  that  you  cannot regulate  anything
unless you  have  a place  at which to regulate  it.  The
California State  Water  Resources  Control  Board has
established Class I sites for disposal of hazardous wastes. We
generally have  no similar facilities  in the other states and
territories of Region IX. Nevada has a disposal site for
receiving  low-level   radioactive  materials  and   some
hazardous wastes, but  we  have no comparable hazardous
waste disposal site in Arizona.
      Primarily, we  have   been discussing programs  to
handle hazardous  waste problems  outside  the  Federal
agency sphere  because we have  no program to manage
hazardous waste inside the  Federal sphere.  Such a program
should be quite important in Region IX. Eighty-five percent
of the land area in Nevada is under Federal control. More
than half the land area in Arizona is under Federal control,
excluding the many Indian  reservations. Forty-five percent
of the land area in California, and many areas in the Pacific
territories, are also under Federal control.
      There are important  hazardous waste  problems  in
these federally-controlled areas. Large quantities of surplus
industrial- and warfare-related chemicals remained after the
Vietnam war ended. Vietnam, Okinawa, Japan and Korea
discovered that stockpiled containers of  these chemicals
were  either leaking, stood  chances of being ruptured, or
were causing problems in their countries, and they wanted
the United States to remove them. This has created some
problems for the Department of Defense (DOD), primarily
because  they  were the people  that had bought these
materials in the first place.
     Some of the chemicals became problems of national
scope and notoriety.  For example, "agent orange", a 50-50
mixture  of  2  herbicides  (2,4,5-T and  2,4,5-D),  was
ordered  out  of  the Pacific  area.  We  ended up  with
1,800,000 gallons  of "agent  orange" stored  on Johnson
Island,  because that was the only place we could go with it.
No governor would allow any more into his state. The State
of Alabama  received 480,000 gallons  of it  before  the
Governor  realized  what he had and stopped any further
importation. So we had  2,285,000 gallons of the herbicide
sitting  around which contained  a contaminant, dioxin, a
mutagenic material that nobody wanted and nobody would
let anyone dispose of it.
     We have been involved  in a lot of research with the
DOD trying to figure out what to do with this herbicide. It
could be registered by EPA for use if we could remove the
dioxin  from it. However, the dioxin can only be removed
by filtering it out with coconut charcoal. So, to recover the
herbicide, we would end up with  a  million pounds  of
coconut charcoal  loaded with dioxin. What would we  do
with the contaminated  charcoal?  This is an unsolved
problem at the moment.
     We  have many  government  agencies  which  use
chemicals in their operations,  and some of these chemicals
become  surplus   or  produce   by-products   which  are
hazardous. Suddenly, Region IX was deluged with .inquiries
about  what to do with these  hazardous  materials. For
example,  the commanding  officer of the Army Depot in
Herlong, California, was designated to be the recipient of all
the hazardous materials returned from the  Pacific, and  he
had  no facilities for handling  them.  He called me and said
he was not equipped to  handle all this material and did not
know  how to handle it. We met with the  Army Hygiene
Agency,   the  Defense  Supply   Agency,  and  the Army
Materiel  Command  and designed  a  temporary  way  of
storing incoming hazardous materials safely  until we could
decide what else to do with them.
      Because of  all  the problems that had arisen among
various agencies, we decided to hold an ad hoc work group
meeting on August 2,1973 to discuss these problems. Some
of these agencies  had waste  treatment facilities,  or  were
planning to build them, or had disposal facilities that might
have been available for use by another agency. I announced
this  meeting  and  asked about a dozen people to attend.
(Walt Weaver of U. S. Forest Service collaborated with me
on  this.)  For  this meeting,  originally  scheduled  to
accommodate 12  people, 125 people showed up. However,
                                                        -16-

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we  were aware  that the additional people were going to
attend,  so  we rescheduled the program and  held a 2-day
session on  what to do about  hazardous wastes within the
Federal  establishment. What resulted from this meeting was
the formation of a task force to work on  the problem. We
appointed  an  executive steering  committee  composed of
members from  a  dozen  agencies  which were primarily
concerned  with  the problem to plan the program, and we
asked the Western  Federal Regional Council to  sponsor us.
      A regional council exists because of a law passed by
Congress which  authorized the establishment of a council
of the  Federal  agencies  located  within  each  of the 10
Federal  regions.  The heads of each of those agencies within
each  region  formed a  council,  e.g., the Department of
Agriculture, the Department  of the  Interior,  EPA, and
everyone except the military.  (However,  the councils did
allow the  DOD to attend  their  meetings  as ex officio
members.)  We finally received official sanction as a task
force from the Western  Federal Regional Council in 1974.
      The Western Federal Regional Council established 7
objectives for the task force:

     1.  To provide among responsible agency personnel
        within the region a mechanism for the transfer of
        technology  and   information  relating  to the
        management  of  hazardous   materials  in  an
        environmentally safe manner;

     2.  To develop and maintain a directory of individuals
        within  Federal agencies who are designated for
        contact  regarding   management of   hazardous
        materials and other environmental matters;
    3.   To  develop an  inventory  of surplus  hazardous
        materials and wastes;

    4.   To explore and recommend courses  of action to
        the  council to manage hazardous materials safely
        as problems are identified;

    5.   To   identify,   develop   and  disseminate
        recommended   plans   of   action   for  the
        environmentally safe management, transportation,
        storage, resale, recycling, reuse, modification, or
        ultimate disposal of these hazardous materials;
    6.
    7.
To  coordinate  interagency  action  relating  to
hazardous waste management when requested by
the agencies concerned; and
To  coordinate  with  state
actions were to be taken.
programs  whatever
     The Western Federal Regional Council Task Force has
accomplished its objectives and has written a final report.
This report is now in the review process and will eventually
be made available to the public.  We have identified the
problem, we have completed our inventory of wastes, and
we know the capability of existing disposal sites. Also, our
work has led to the establishment of new disposal facilities,
such  as  the  sophisticated  incinerator   now   under
construction at  Edwards Air  Force  Base for disposal of
excess rocket fuel and other hazardous materials. The task
force has been one of the most exciting activities in which  I
have been involved.
                                                         -17-

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                                    WESTERN FEDERAL REGIONAL COUNCIL
                           TASK FORCE FOR HAZARDOUS MATERIALS MANAGEMENT

                             II.  GUIDELINES FOR OPERATION AND MANAGEMENT OF
                                       HAZARDOUS WASTE DISPOSAL SITES

                                                David L. Storm, Ph.D.
                                                  Research Chemist
                                        California State Department of Health
                                                    Berkeley, CA
      The Western  Federal  Regional Council Task Force
 subcommittee,  charged  with  the  task  of  developing
 guidelines for the operation  and management of hazardous
 waste disposal sites, was formed in the summer of 1974 and
 held its first meeting in  September 1974.  During the
 subsequent 12 months, we  met periodically and drew up
 the  guidelines  as they  appear now.  In the process of
 drawing  up the  guidelines, we had  many concerns and
 considerations to discuss and resolve. Some of the problems
 that we had to address were the following:

    • Determine the major objectives of the subcommittee;

    • Determine what  we could expect to accomplish and
      what our limitations would be;

    • Obtain available information and data to establish the
      guidelines;

    • Identify the various concerns regarding the operation
      and closure of hazardous waste disposal sites;

    • Identify the monitoring needed at such sites to ensure
      protection of the public and the environment;

    • Decide  how to  address  permanent disposal versus
      interim  storage  for  possible  recovery  of  certain
      hazardous wastes in the future;

    •  Establish the operational safety and security  measures
      needed to protect the  public and environment from
      hazardous wastes;

    •  Decide  whether  processing   and   treatment  of
      hazardous wastes should be addressed;

    •  Decide  whether  we  were   preparing  operational
      guidelines   for:  Federal   sites.   State  and  local
      agency-operated sites, commercially-operated sites, or
      privately-operated sites.

      A fundamental concern which was discussed at great
length at the subcommittee meetings was the question of
the  acceptability  of the  wastes themselves. Should  any
wastes be excluded from a hazardous waste disposal site?
 Should the ideal disposal site be capable of accepting all
 hazardous wastes? It was decided that the guidelines would
 not address radioactive wastes  nor forbidden  or  Class A
 explosives.
      After  approximately  one-half  year  of monthly
 meetings, the subcommittee distilled all of these questions,
 concerns,  and  aspects of disposal  site  operation  and
 management to the topics which it felt were most pertinent
 to its charge and were within  our capability to address.
 These  topics   became  the   major  headings  in  the
 subcommittee's final report.
      It was decided that the purpose of the subcommittee
 was to provide recommendations to whatever entity might
 be   charged  with   responsibility   for  planning  and
 implementing  the operation   and   management  of  a
 hazardous waste disposal site. These recommendations were
 developed as guidance documents.  The format  of the
 guidance  documents  was  designed  to  conform  to the
 outline of existing Federal regulations so that they could be
 readily  converted  to  published Federal standards with
 minimum alteration. Specifically, the format was the same
 as that used for "Guidelines for Thermal  Processing and
 Land Disposal of  Solid Wastes" published by the U. S.
 Environmental Protection Agency (EPA)  in the August 14,
 1974, Federal Register.
      Under each major topic of the guidance document is
 a  requirements  section delineating minimum  levels of
 performance required  of a hazardous waste disposal  site.
 Next is  a  recommended  procedures  section  suggesting
 preferred  methods  by  which the  objective  of  the
 requirements could be met. The recommended procedures
 section  is subdivided  into  a design section, recommending
 designs,  and   an  operations  section,  recommending
 operations.
      Use of the  term "guideline" herein  should  not be
 construed to mean a "regulation" as the term is often used
 in Federal publications. "Guideline" is used here to denote
 a  "criterion", a "recommendation", or  "advice".  In  that
 respect the guidelines are advisory to Federal agencies that
 operate  disposal sites,  or to state, interstate, regional, and
 local governments that operate or regulate disposal sites.
      In developing the guidelines, we attempted to outline
what performance standards should be expected of an ideal
disposal site. In that  respect the guidelines  were directed
not only  toward potential hazardous waste disposal sites
and their  establishment, but  also toward existing disposal
sites and their upgrading.
                                                      -18-

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Summary of Guidelines

     The main  topics or headings in the guidelines are as
follows:

   • Scope
   • Definitions
   • Hazardous Wastes Accepted
   » Hazardous Wastes Excluded
   • Site Selection
   • Site Design
   • Water Quality
   • Air Quality
   • Gas and Vapor Control
   • Vector Control and Wildlife Protection
   •  Aesthetics
   • Cover Material
   •  Safety
   •  General Operations
   •  Records
   •  Monitoring and Surveillance
   •  Quality Assurance

      The following discussion will summarize highlights of
 the more important topics in the guidelines.
      Scope.  The guidelines state that a properly designed
 and operated hazardous waste disposal site should represent
 the ultimate in environmental safety. The site should be
 designed and operated so that hazardous wastes can be
 treated, and  reclaimed whenever possible, to ensure that
 their deposition onto the land has a minimal impact on the
 environment and on  the capacity of the  site. All attempts
 should  be  made  to ensure  that   hazardous wastes  of
 potential value are either placed in long-term storage or are
 disposed of in  such a manner that they may be retrieved at
 a future time.
       Hazardous  Wastes Accepted.  A disposal site should
 be  designed and equipped to  identify, accept,  process,
 detoxify, store, and dispose of most hazardous materials.
 The site should be capable of long-term, engineered storage
 so that it  can accept materials  which  cannot  be safely
 disposed of  to the earth and  for  which no satisfactory
 treatment  exists. The  guidelines  suggest  fairly  detailed
 acceptance, identification, and screening procedures.
       Hazardous Wastes  Excluded.   Agencies that license
 and  regulate a disposal site and the site operator should
 jointly  determine  the  specific   hazardous wastes  to  be
 excluded   and  should  identify  those  wastes  in  the
 operational  plan.  Special  or  unusual  hazardous  wastes
 should  be excluded  if they are  too hazardous for release
 into  the  environment by disposal  or by possible  escape
 during  storage, transport, and  handling,  and  if the
 capability  of full or partial destruction of the wastes exists
 at other available facilities.
       Site  Design.   Plans for the design, construction, and
 operation  of  new  disposal sites or the  modification of
 existing sites  should  be  prepared  and  approved  by a
  registered  professional engineer and should be submitted to
  the appropriate  licensing or regulatory agencies for review
  and approval  prior to commencing operation. The design
should ensure  isolation of the wastes from ground and
surface waters,  from the  public,  and from wildlife. The
guidelines  recommend  a development plan  and identify
various factors which should be included  in that plan, such
as topography,  land  use, soil characteristics, climate, and
geology.
      Water  Quality.  The  location,  design, construction,
and operation of a disposal site where hazardous wastes are
treated, stored,  and disposed of should ensure that  water
quality  is  reasonably safeguarded and  that  standards  of
responsible water quality  control  agencies are met. It is
recommended that, whenever  possible, the general criteria
established by the California State Water Resources Control
Board for  Class I  disposal  sites be used for the design and
operation of the site to ensure protection of water quality.
      Air Quality.  The design, facilities, and operation of a
disposal site should be planned to minimize the discharge of
airborne  hazardous  materials  in  dangerous or  polluting
concentrations  into the working  environment or into the
surrounding  area. The  standards of appropriate air quality
control agencies must  be  met. The guidelines suggest that
the   site   have  available  state-of-the-art  equipment  for
 collecting, measuring, and analyzing airborne materials, and
 that  all operations at the site be  equipped, designed, and
 operated  to prevent the  discharge of dangerous levels of
 airborne   materials.   An  air-monitoring   program   is
 recommended during the  period  of operation of the site
 until the site is no longer a potential threat to air quality.
      Gas Control.  Vapors  and  gases of  decomposition
 generated within a  disposal site  should be  controlled to
 avoid creating  a hazard  to  persons  at  the site  or to
 occupants of  adjacent property.  It is  recommended  that
 needed vents, barriers, cover  materials, or cutoff trenches
 be designed to mitigate these possibilities.
       Cover Material.  Cover material should be applied as
 necessary to:  minimize erosion of soil or wastes; prevent
 fire  hazards,  infiltration  of precipitation, odors,  and
 blowing   litter;  and   control   gas  release  and  vector
 production. Intermediate  cover should be applied on burial
 areas where additional activity is not planned for extended
 periods of time, e.g., several days to one year. Final cover
 should be placed on each area as  it  is completed or  on any
 area scheduled to remain idle for more than one year.
       Safety.    Occupational   Safety   and    Health
 Administration (OSHA) and other health  and safety work
 orders must be  recognized as they relate to: the  general
 working   environment;   the  design,   operation,   and
  maintenance of equipment; and the handling of hazardous
  materials. A vigorous and continuing accident prevention
 and safety program should be required at a hazardous waste
 disposal   site.  Safety  precautions   and  emergency
  contingency procedures  should  be identified in a  general
  operational plan. Personnel should be thoroughly trained to
  use  these procedures  and should be thoroughly familiar
  with chemical  hazards.   To ensure acceptable  safety, a
  security system  should be established  to  prevent entry of
  unauthorized persons into hazardous waste handling areas,
  and storage areas should  be designed as high security areas.
       General  Operations.  All operations at a disposal site
  should be  coordinated to  ensure that they are compatible
                                                         -19-

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with the physical characteristics of the site and provide for
the  health  and  safety  of  personnel.  The  guidelines
recommend that a general operational plan be prepared for
the site. The operational plan should not be confused with
the  planning  and  design  stages,  which  detail  specific
components of the  site. The plan should  describe  the
sequence of operations  including flow schemes indicating
how various wastes are processed, reclaimed, or disposed of.
The  specific  activities  and operations that should be
addressed in the plan include:

   •  Acceptance   and  screening  of  wastes,  including
      evaluation of waste compatibilities;

   •  Monitoring and analysis of wastes;

   •  Safety and emergency procedures;

   •  Transportation of wastes inside the site;

   •  Unloading of wastes;

   •  Holding and storage of wastes;

   •  Processing of wastes;

   •  Disposal  of wastes;

   •  Maintenance of equipment;

   •  Training  and qualifications of personnel;

   •  Record keeping;

   •  Site security.
      Records.  The operator  of  a  disposal  site must
maintain and provide records and monitoring data for his
own reference and  for regulatory agencies. Specific items
which should be  kept  on record include accident reports,
monitoring data, lists of wastes accepted, and others.
      Monitoring  and Surveillance.  Detailed plans should
be developed for detecting the:  discharge of unacceptable
amounts of hazardous  materials from the  site; the use of
hazardous  operations  or  designs;  and  the  creation  of
aesthetically   unpleasant  situations.   The   guidelines
recommend that baseline data  regarding air and  water
quality  be collected before a new  site  begins  operating.
These data should be gathered at the site and in the vicinity
of it.
      Quality  Assurance  Program.  A  quality-assurance
program should be  established at a disposal site to ensure
that  the  site  operators'  procedures  offer  maximum
protection  to  the  environment.  The  program  should
include:  a  definite   assignment  of   organizational
responsibility  for  environmental  quality;  a  means  of
specifying the level of quality; procedures for implementing
the quality assurance program; and an independent system
for verifying compliance with, and the adequacy of, quality
requirements.
      In conclusion, I  would like to  emphasize that the
guidelines   are  advisory.  They  include  recommended
minimum  levels  of performance for the operation and
management   of  hazardous  waste   disposal  sites.
Recommendations in varying detail are provided as possible
ways of meeting the minimum levels. The operator of a
hazardous waste  disposal site could use the guidelines as a
tool  to aid in  the preparation  of  detailed design and
operational plans.
                                                       -20-

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                                    WESTERN FEDERAL REGIONAL COUNCIL
                          TASK FORCE FOR HAZARDOUS MATERIALS MANAGEMENT

                     ill. METHODS USED TO SELECT HAZARDOUS WASTE DISPOSAL SITES

                                                  Walter S. Weaver
                                                 Sanitary Engineer
                                                   Forest Service
                                           U. S. Department of Agriculture
                                                 San Francisco, CA
     The Western Federal Regional Council Task Force for
Hazardous  Materials  Management  found that  existing
disposal facilities in the western states were inadequate and
incompatible   with   long-term   protection   of   the
environment. The designation of these sites  had  not  been
based  on  sufficient  consideration   of  all  necessary
parameters  for  environmental,  social   and   political
protection.   However,   large  quantities  of hazardous
materials  and  wastes  in  need  of disposal were  being
generated  within  the  Federal  establishment from  both
civilian and military sources. The task force was asked to
prepare recommendations for  the  environmentally sound
management of  these hazardous  materials and to develop
criteria for the selection of  hazardous waste  disposal  sites.
     We  have accepted  the doctrine that we must have a
few sites  located throughout the country that are situated
on geological materials that can accept hazardous wastes for
long-term disposal with minimum risk. These sites must be
safeguarded and remain under state or Federal stewardship
forever, essentially.  To select  such sites,  a  site  rejection
process can be used. We developed such a process applicable
to California, Nevada and Arizona, but the factors on which
we based our rejection would  have to be modified if the
process were used elsewhere.
     The rejection process consists of: an office review of
candidate sites;  a  preliminary field reconnaissance of sites
that survive office  review; a  costly, detailed  study of
remaining candidate sites; the preparation of environmental
impact statements; and the final selection of a site. After a
site has  been established,  it must  be operated,  managed,
monitored and maintained. During that time, information
gained about errors  or possible errors in the  rejection
process must be used  to modify that process to ensure that
such errors are not repeated or can be corrected.
      In the site rejection process, we deal with factors that
can   be   grouped    into  4  basic  elements: (1)the
hydrogeological  element;  (2) the biological or  ecological
element; (3) the  land-use  and status element; and (4) the
socioeconomic  element. We have developed a  numerical
rating system to evaluate each factor and to reveal possible
weaknesses of a proposed  site. Factors considered part of
the hydrogeological element range from  precipitation  to
hydraulic gradient and  include  all the generally accepted
hydrogeological factors used by geologists and engineers in
similar studies  worldwide.  Factors considered part of the
biological or ecological element relate to animal and plant
communities. Thus, these first two elements deal with the
environment; the last two deal with man-made factors.
      The land-use and status element includes factors that
are the products of laws, regulations, edicts, or ordinances.
These factors can be  changed,  although with considerable
difficulty at times.   For  example, an  otherwise suitable
hazardous waste disposal site can be excluded by law from
a recreational area. The final element, the socioeconomic
element,  includes  factors  such  as: the  availability  of
transportation  systems to  move  wastes to  a site and the
acceptability of a site  to the general public in the area.
      If the above 4 elements can be satisfied, then a costly,
detailed analysis of candidate sites is justified. The few sites
that  pass  such  an   analysis can be  made available for
receiving   persistently  toxic  residues  that  cannot  be
reclaimed, recycled or detoxified.
                                                       -21-

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                       SUMMARY OF THE U. S. ENVIRONMENTAL PROTECTION AGENCY'S
                        INDUSTRY STUDIES ABOUT HAZARDOUS WASTE MANAGEMENT

                                         Hugh B. Kaufman, Program Manager
                                        Hazardous Waste Management Division
                                       U. S. Environmental Protection Agency
                                                 Washington, D.C.
      I  would like to describe  the  results of one of the
major projects  EPA's  Office  of Solid Waste  has  been
conducting  during  the  past  few years. This  project  is an
assessment of the hazardous waste management practices of
the major industries in the United States. Before I describe
this program and its results to date,  t would like to explain
why we initiated the project  and how it fits into the overall
scheme of things at EPA.
      In 1970, the Solid  Waste Disposal Act of 1965 was
amended by the Resource Recovery Act. This act, among
other things, required  EPA  to perform a comprehensive
investigation and analysis of hazardous waste management
practices in the  United States. A report on hazardous waste
management  conducted   by   the  Hazardous  Waste
Management Division of the Office  of Solid  Waste (OSW)
was submitted to Congress in 1973. The report pointed out
that  hazardous  waste management  practices in the U. S.
were  generally  inadequate. Also, EPA realized that  more
detailed data on specific  industries were needed. It was in
this  context that the  Hazardous  Waste  Management
Division embarked on the effort to be described.
      Specifically, this study was designed to look at some
of the major industries  of the United States and determine
the following:  (1)the  type and quantity of  potentially
hazardous wastes generated and destined for  land disposal;
(2) the ways in which  these  wastes  are  presently  being
handled, treated, or disposed of; (3) the state-of-the-art of
treatment and disposal  technology which is, or could be,
applied to  reduce the potential hazard to health and/or the
environment; and (4) the  cost to industry of implementing
specific levels of treatment and disposal technology.
      As the results of these studies have been submitted by
our contractors, the information is and will continue to be
of great value to us in helping to  identify further study
areas and issues to be addressed in our implementation of
the hazardous waste management provisions of the  new
Resource Conservation and Recovery Act of 1976 (RCRA).
Moreover, the results of these  studies will help state and
local  governments  in their assessments of the magnitude
and types of hazardous waste  problems  that might affect
them. Further, and perhaps most important, in carrying out
these studies, we have set in motion the mechanisms for the
various industries to get a better handle on their hazardous
waste management problems  and to set up programs within
their own companies to address these problems.
      The following industry studies have been completed
and are available from the National Technical Information
Service:  (1) battery manufacturing;  (2) organic chemicals,
pesticides,    and   explosives;   (3)  inorganic   chemicals;
(4) leather   tanning  and  finishing;  (5) metals  mining;
(6) paint    manufacturing;     (7) petroleum    refining;
(8) Pharmaceuticals manufacturing; and (9) textile dyeing
and finishing.
      The following industry studies are nearly complete
and will be  available later this year:  (1) special  machinery
manufacturing;  (2) rubber and plastics; (3) primary metals
smelting  and   refining;  (4) electroplating;  (5) electronic
components manufacturing; and (6) waste oil refining. As I
have  previously described,  the outputs  of the  studies
included  an industry characterization, a characterization
and quantification  of the waste stream, an analysis of waste
treatment and  disposal  technologies and their associated
costs.
      Before presenting  the  results of  the  data gathering
program, it is necessary to describe the  concept of  hazard,
and the method of defining hazard, as used in these studies.
EPA has  defined "potentially hazardous waste" in terms of
potential damage from:

   •   Ground water contamination via leachate
   •   Surface water contamination via runoff
   •   Air  pollution  via  open   burning,   evaporation,
      sublimation and wind erosion
   •   Poisoning via the food chain
   •   Fire and explosion

Under this broad framework, we solicited  from  our
contractors their own definitions of "potentially hazardous
waste". These definitions were used as part of the basis for
our analysis of their results.
      In   gathering  raw data,  the  Hazardous   Waste
Management Division  was  pleased with  the  voluntary
cooperation it  received from the  industries being studied.
Because    of   this  cooperation   and   the   positive
problem-solving atmosphere, our contractors were  able to
visit plants around  the country.

                        TABLE 1
               NUMBER OF PLANT VISITS
GROUP 1
Batteries
Inorganic Chemicals
Petroleum Refining
Organic Chemicals, Pesticides,
and Explosives
Pharmaceuticals
Paint
Metals Mining
Primary Metals
Electroplating
GROUP II
Tanneries
Special Machinery
Textiles
Rubber and Plastics
Electronic Components
Waste Oil Refining
NO. VISITS
15
63
16

53
35
71
28
53
40

28
35
80
85
23
5
NO. PLANTS
263
1,607
247

2,200
1,508
1,550
148*
2,717
20,000

386
3,906
2,000
2,150
2,855
27
    Mines
                                                       22-

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     Table 1 describes the number of visits made by EPA
contractors and  the number of plants  identified in each
industry group. We can see from the table that a definite
effort was made  by the EPA contractors to gather as much
real-world data as possible. However, despite these efforts,
the sample size was limited to less than 10 percent of the
known facilities.
                       TABLE 2

         U. S. INDUSTRIAL WASTE GENERATION
                     (1975 DATA)
          (MILLION METRIC TONS ANNUALLY)
                      TABLE 3

  U. S. POTENTIALLY HAZARDOUS WASTE QUANTITIES
                     (1975 DATA)
          (MILLION METRIC TONS ANNUALLY)
INDUSTRY CATEGORY
1 . Batteries
2. Inorganic Chemicals
3. Organic Chemicals, Pesticides,
and Explosives
4. Electroplating
5. Paints
6. Petroleum Refining
7. Pharmaceuticals
8. Primary Metals
9. Textiles Dyeing and Finishing
10. Rubber and Plastics
11. Leather Tanning and Finishing
12. Special Machinery
1 3. Electronic Components
14. Waste Oil Refining
Totals (To Date)
TOTAL
DRY
0.005
40.000

2.200
0.909
0.370
0.624
0.244
100.351
0.310
2.007
0.064
0.305
0.036
0.057
147.482
TOTAL
WET
0.010
68.000

7.000
5.276
0.396
1.756
1.218
109.881
2.099
3.254
0.203
0.366
0.060
0.057
199.566
      Table 2 describes the total amount of waste generated
by  each industry group and destined for  land disposal.
Thus,  our  contractors  found  that approximately  200
million metric tons  of wet waste  were generated  and
disposed of on the land by the industries studied, excluding
the  metals  mining industry.  Note  that  the  total waste
quantity from the metals mining industry is approximately
4  times  the  quantity  from the  other  14  industries
combined,  while the potentially hazardous portion is about
8  times the quantity generated by the industry  groups
shown in Table 2. Thus, the metals mining waste quantity,
if included, would overwhelm the statistics from the other
industries.
      It  might be  helpful at this  point to  explain the
difference  between wet and dry weight. Wet weight is the
actual weight of the waste to be handled, i.e., the quantity
of waste generated  "as is". The dry  weight of the waste is
equal  to the  wet  weight  minus  the water  content. As
indicated in Table 2, there were approximately 200 million
metric  tons  of industrial  waste (wet  weight)  generated
during 1975 from the  14 industrial groups. This figure is to
be compared with an estimated 344 million metric tons of
waste  generated  from all manufacturing  industries. Thus,
approximately  60 percent  of  all  industrial  waste  is
generated by these 14 industries.
INDUSTRY
1. Batteries
2. Inorganic Chemicals
3. Organic Chemicals, Pesticides,
and Explosives
4. Electroplating
5. Paints
6. Petroleum Refining
7. Pharmaceuticals
8. Primary Metals
9. Leather Tanning and Finishing
10. Textiles Dyeing and Finishing
11. Rubber and Plastics
12. Special Machinery
13. Electronic Components
14. Waste Oil Refining
Totals (To Date)
DRY
BASIS
0.005
2.000

2.150
0.909
0.075
0.624
0.062
4.429
0.045
0.048
0.205
0.102
0.025
0.057
10.731
WET
BASIS
0.010
3.400

6.860
5.276
0.096
1.756
0.065
8.267
0.146
1.770
0.785
0.162
0.035
0.057
28.811
     Table 3 delineates further the amount by weight of
potentially hazardous  waste generated by  the industry
groups studied. This table shows that almost 29 million
metric tons (wet) of industrial waste generated by these 14
industry groups is potentially hazardous and disposed of on
land.
     Therefore, it is  estimated  that 14 percent of  all
land-destined wastes generated by the  industry categories
studied is potentially hazardous. This is an overall figure,
and obviously  some industries have a higher percentage
than others. (OSW estimates that approximately 10 percent
of all industrial waste is potentially hazardous.)
                       TABLE 4

              EPA REGIONAL CENTERS OF
          POTENTIALLY HAZARDOUS WASTES
INDUSTRY
1. Batteries
2. Inorganic Chemicals
3. Organic Chemicals, Pesticides,
and Explosives
4, Pharmaceuticals
5. Metals Mining
6. Primary Metals
7. Paints
8. Electroplating
9. Petroleum Refining
10. Textiles
11. Leather Tanning
12. Rubber and Plastics
13. Special Machinery
14. Electronic Components
15. Waste Oil Refining
EPA
REGION
V
VI

VI
II
IX
V
V
V
VI
IV
1
IV
V
II
V
PERCENT
TOTAL
36.2
45.5

54.6
51.5
51.6
38.9
31.6
44.4
43.1
58.8
38.3
24.5
25.0
28.0
30.1
                                                       -23-

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      Our studies  found (Table 4)  that certain  regions of
the  country  are  focal points  of problems related  to
potentially hazardous  waste from  certain industries.  For
example,  EPA  Region II   was  found  to contain  over
50 percent of the pharmaceutical  industry's potentially
hazardous waste, and  thus, over 50 percent of the related
problems associated with that industry. EPA Region V was
number  one  in  6  of the industry  groups,  while  EPA
Region VI attained this ranking 3 times.

                       TABLE 5

               EPA REGION RANKINGS
          HAZARDOUS WASTE GENERATION
EPA REGION (RANK)
I
II
III
IV
V
VI
VII
VIII
IX
X
(9)
(6)
(3)
(4)
(2)
(1)
(10)
(8)
(5)
(7)
PERCENT OF TOTAL
1.8
5.4
16.0
13.3
24.4
25.2
1.4
2.0
6.5
4.0
                       TABLE 6
          POTENTIALLY HAZARDOUS WASTE
                GROWTH PROJECTIONS
INDUSTRY
1. Batteries
2. Inorganic Chemicals
3. Organic Chemicals,
Pesticides,
and Explosives
4. Electroplating
5. Paint and Allied
Products
6. Petroleum Refining
7. Pharmaceuticals
8. Primary Metals
Smelting and
Refining
9. Textiles Dyeing
and Finishing
10. Leather Tanning
1 1 . Special Machinery
12. Electronic
Components
13. Rubber and Plastics
14. Waste Oil Refining
Totals (To Date)
AMOUNT
(Million Metric
Tons/Year Wat Weight)
1974
0.010
3.400


6.860
5.276

0.096
1.756
0.065


8.267

1.770
0.146
0.163

0.035
0.785
0.057
28.811
1977
0.164
3.900


11.666
4.053

0.110
1.841
0.074


8.973

1.870
0.143
0.153

0.078
0.944
0.074
34.043
1983
0.209
4.800


12.666
5.260

0.145
1.888
0.108


10.440

0.716
0.214
0.209

0.108
1.204
0.144
38.111
PERCENT
GROWTH
74-83
2,000
40


77
92

30
12
68


26

373
51
54

200
46
253
32
      Table  5 describes  the percent of total  potentially
hazardous waste generated in each EPA region, based on
these 14 industry groups. For example, EPA Regions V and
VI  were  found  to have about half of the  potentially
hazardous waste  generated  in  the  country, while EPA
Region VII was found to have a little over 1 percent. EPA
Region IX  has an  estimated  6.5 percent  of  the  total
potentially hazardous waste.
      Table  6 summarizes  the growth  projections  of
potentially hazardous waste generated  for each industry
between  1974 and 1983.  It  can be  seen  that certain
industries, like the battery  manufacturing industry, were
found to have tremendous  expectations  for  growth of
potentially  hazardous  waste,  whereas  the  petroleum
refining industry was found to have no appreciable growth
in the generation of potentially hazardous waste.
      In assessing  the present techniques for treatment and
disposal of potentially hazardous wastes throughout all of
the industries  studied, data developed by  EPA contractors
allowed us to arrive at the following conclusions. First, it is
concluded that  less  than  10 percent  of all  potentially
hazardous wastes  are now adequately treated or disposed
of. Methods of adequate treatment or disposal included the
use of secure  landfills,  controlled incineration, recycling,
and   resource  recovery.  For  the other  90 percent  of
potentially hazardous wastes inadequately managed, various
treatment and disposal methods were  used. These included
dumping and landfilling, which accounted for 30 percent of
all   potentially   hazardous  wastes;   lagooning,  which
accounted   for  almost  50 percent  of  all  potentially
hazardous wastes; uncontrolled burning, which accounted
for almost 10 percent of all  potentially hazardous wastes;
and  deep well injection and  road oiling, which accounted
for much smaller percentages.
      In  summary,  the studies found  that over 80 percent
of potentially hazardous wastes are disposed of on the land,
and  only 2 percent were recovered or recycled. Based on
the   studies,  it  is estimated  that  40 percent  of  the
potentially  hazardous wastes were disposed of or treated
away from  the site where the plants producing them were
located.  This  raises the  question  of  ensuring  the use of
environmentally  sound  techniques  by the  third parties
involved  in transporting  and  disposing  of  potentially
hazardous  waste. With  regard to the cost involved  in
treatment and disposal  of hazardous  waste, each industry
study  identified  3 levels of technology. Level I was the
technology currently employed by a typical facility in that
industry  group. Level II was the best  technology currently
employed by any  facility  in  the   industry group,  and
Level III  was that technology necessary to provide adequate
health and  environmental protection  (in the contractor's
opinion). Table 7  describes the costs identified  for each
treatment and disposal technology level in each industry
group (for 12 of the industry groups).
                                                      -24

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                   TABLE 7

         COSTS OF HAZARDOUS WASTE
            TREATMENT/DISPOSAL
        (MILLION DOLLARS ANNUALLY)
INDUSTRY
1 . Textiles
2. Petroleum Refining
3. Paints
4. Electroplating
5. Rubber and Plastics
6. Leather Tanning
7. Organic Chemicals,
Pesticides,
and Explosives
8. Inorganic Chemicals
9. Batteries
10. Pharmaceuticals
1 1 . Special Machinery
12. Electronic Components
Totals*
LEVEL 1
$ 4.7
54.2
10.4
20.6
15.6
3.2


106.0
104.5
1.6
5.6
2.4
0.4
$365.2
LEVEL II
$ 6.5
74.0
10.4
14.5
6.6
3.2


242.0
143.2
1.9
5.6
2.0
0.5
$510.6
LEVEL III
$ 11.7
74.0
- 11.2
18.0
16.6
3.4


243.0
191.1
1.9
5.6
3.4
0.6
$580.4
Excludes Metals Mining, Primary Metals, and Waste Oil
Refining Industries.
     Conclusions: The following  trends and conclusions
can be  drawn from the results to date:  (1) Amounts of
potentially hazardous waste generated will increase about
32 percent in the  next  decade,  due  in  great part to
installation of  air  and water  pollution control systems.
(2) About  14 percent  of  industrial  wastes generated by
those industries examined  can  be  classified as  potentially
hazardous to public health and the environment. (3) Land
disposal is the predominant hazardous waste management
practice  today.  (4) Generation  of potentially  hazardous
waste   is  concentrated  as  expected  in  the  heavily
industrialized  EPA  Regions VI,  V,  III,  and  IV.  (5) At
present, only 4 percent of potentially hazardous waste is
treated and 2 percent is recovered.
      EPA's future  industry study efforts will concentrate
on improving our industrial-waste data base, evaluating the
major treatment and disposal options for hazardous waste
management, and analyzing the economic impact of various
hazardous waste regulatory options. We alone cannot bring
about  the necessary  improvement  to current industrial
hazardous waste management  practices merely by writing
regulations. Therefore,  we  urge  the waste  generation
industry,  the waste  management industry, state and  local
government,  public and  environmental  interest  groups.
Federal agencies, and the general public to join with  us in
our   effort  to   upgrade  industrial  waste  management
practices   to   protect  better   the  public   health  and
environment.
                                                     25-

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                           CURRENT RESEARCH ON HAZARDOUS WASTE DISPOSAL

                                  Robert L Stenburg1 and Norbert B. Schomaker2
                                    Solid and Hazardous Waste Research Division
                                   Municipal Environmental Research Laboratory
                                       U. S. Environmental Protection Agency
                                                  Cincinnati, OH
INTRODUCTION

      Increasing amounts of hazardous and toxic wastes are
being directed to the land for disposal by landfilling. At the
same time, there is  increasing evidence of environmental
damage resulting  from  improper disposal. The  burden of
operating  landfills and coping with any resulting damages
falls  most  heavily  on  municipalities  and  other  local
government  agencies.   Their   problems   are  complex,
involving legislation, economics, and public attitudes as well
as technology. Furthermore,  comprehensive information
about how to landfill and protect the local  environment is
not readily available.
      Part of the long-range solution to this problem will be
design and  operation  manuals, to be  published  by the
Municipal Environmental Research Laboratory, describing
recommended procedures and technology  for minimizing
the  impact from  landfilling of strictly municipal wastes as
well  as of  hazardous and  toxic  wastes. Although  these
manuals will not be published until about 1980, a series of
intermediate reports will be published, detailing present and
future research findings  that will be incorporated  into the
final design and operation manuals. This paper describes 6
current projects  supporting  the  development of  these
manuals.

      IDENTIFICATION  AND   CHARACTERIZATION
      OF  HAZARDOUS WASTES

      Environmental Effects Documents

      This research3 is  being performed to  determine
      human health and environmental effects as they may
      relate  to  the  management  and  land disposal  of
      selected hazardous substances/wastes, thus providing
      a data  base that summarizes, assesses, and interprets
      health  and  ecological effects of specific hazardous
      wastes. The documents developed from this work will
      contain:

        •  Comprehensive  data   about  the  effects  of
           hazardous wastes  on all  forms of life,  both
           human and other living organisms, and on the
           air, water, and land.

        •  Environmental aspects of hazardous materials
           such as:  environmental distribution; transport
           through  soil,  through soil  to water or  air, and
           through   water or  air  to humans or  other
           organisms; transformation; fate; accumulation
           and magnification.
These documents are currently  being developed for
the  following  hazardous  materials  and   related
compounds:
     arsenic
     asbestos
     benzidine
     beryllium
     cadmium
     chromium
     cyanides
     endrin
fluorides
lead
mercury
methyl parathion
PCB's
toxaphene
mirex/kepone
chlorophenols
Several  previous reviews of these efforts have been
presented   (Schomaker    and    Roulier,   1975;
Schomaker, 1976a; Schomaker, 1976b).

Standard Sampling Techniques

Standard sampling procedures4, including collection,
preservation, and storage of samples, do not exist for
solid and semi-solid wastes. Hazardous wastes, both at
the point of generation and the point of disposal, are
not  homogeneous  mixtures   and  may  range  in
consistency from a liquid or a pumpable sludge to a
solid.   Existing  procedures   for  sampling  liquid
effluents and  soils will apply to sampling  hazardous
wastes  but  must  be  adapted  to  a  variety  of
circumstances  and, more  importantly,  field tested
extensively before  they can  be advocated as "the"
way to sample. Experience with sampling procedures
is being accumulated as part of several ongoing Solid
and  Hazardous Waste Research Division  (SHWRD)
projects, and  our initial effort in this area relates to
the  chemical   composition,  physical characteristics,
and origin of hazardous wastes delivered  to several
Class I (hazardous chemical) landfills in  the State of
California.

Standard Analytical Techniques

Assuming that a representative sample can be taken
from a  hazardous waste,  the next problem is to
analyze  the  waste. Existing analytical  instruments
function   well  on   simple   mixtures   at  low
concentrations but encounter interference problems
with  complex  mixtures containing materials at high
concentrations (1 percent  by weight and greater). In
this  range the sample cannot be analyzed directly but
must be diluted and/or analyzed by the method of
standard additions. Options here are the development
of standard procedures for diluting and accounting
                                                       26

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for errors introduced thereby or  the development of
instruments capable of accurate, direct measurements
at high concentrations in the presence  of  potential
multiple interference. Existing EPA  procedures for
analyzing  water and waste-water  are often  not
applicable. Analytical procedures are being developed
as needed  as part of  the SHWRD projects. However,
most of this work  is specific to the wastes being
studied and separate  efforts were required to ensure
that more  general procedures and equipment would
be   developed.   A   compilation   of  analytical
techniques4  used for hazardous  waste  analysis has
been published,  and  we  are currently conducting a
"round robin" study  of leachate analysis. Some 30 to
40 laboratories will be involved in this study.

Standard Leaching Test (SLT)

Because environmental  impact  cannot  occur  until
contaminants are released from  a waste, a standard
leaching   test   is   needed   to  assess   potential
contaminant release from a waste. Such a  test must
provide  information  about  the  initial release of
contaminants from a  waste wl  n it contacts not only
water  but  other solvents which could  be brought for
disposal. Additionally, such a test must  provide some
estimate of the behavior of the waste during extended
leaching. Experience  from  ongoing SHWRD projects
indicates that some wastes may  initially release only
small amounts of contaminants but, during extended
leaching, will  release much  higher  amounts.  Such
leaching   behavior   has   an  impact   on   disposal
regulation  and on management of a disposal site, so
information about this behavior  must be obtained as
part of the process of classifying a waste. The Office
of  Solid  Waste (OSW)  has  funded  an  Industrial
Environmental Research Laboratory (IERL) project*5
to  examine this subject and develop  procedures for
determining whether a  waste  contains  significant
levels  of toxic contaminants and whether a  waste will
release such contaminants under a variety of leaching
conditions. Validation of the SLT is  planned  as a
future project.

HAZARDOUS WASTE DECOMPOSITION

Waste Leachability

 In lieu of  developing a Standard  Leaching Technique,
we  have  patterned  one  current ongoing hazardous
waste leaching  study6 after a method  developed by
the International Atomic Energy Agency (IAEA) for
leach  testing  immobilized radioactive  waste solids.
 Plexiglass  columns of 0.35 cubic feet are loaded with
the sample, and a 1-inch  head  of leaching  fluid is
 maintained on  top  of  the samples. Two leaching
fluids are  used, deionized water and deionized water
at a pH of 7.5-8.0. The 2 leaching fluids represent
 both  sides of the pH scale since the deionized water
 will  assume  an acid pH  due to its reaction  with
carbon  dioxide.  The  selection  of leaching  fluids
should provide some concept  of the  pH  effect on
leaching. Flow through the  column  is regulated to
maintain  a  velocity   of  approximately  1 x 105
cm./sec., and  leachate samples  are collected  at the
base of the column. The columns are translucent and
observations of flow  patterns as well  as of possible
biological activity  can  be  made.  Five  industrial
sludges and  5 flue gas desulfurization (FGD) sludges
are being investigated.

Another  ongoing leachability study7  relates  to the
inorganic  industrial   waste  where   there   is  no
appreciable  biological  activity.  Consequently, the
chief mode of decomposition and pollutant release is
solubilization  and  other  strictly chemical changes
which take  place as the waste is leached with water.
Accordingly,  the  testing  program is designed to
evaluate leaching and pollutant release under a variety
of  leaching conditions which may be  encountered in
one or more disposal situations. This project is also
developing  batch  tests  to  replace   in  part the
time-consuming column tests presently used.

One  major  consideration   regarding  the  leaching
behavior of wastes is pH. Consequently, leaching tests
similar  to  the  one  described  above  are  being
conducted with leaching fluids maintained at pH 5, 7,
or 9 by  mixing a sample of the waste with water and
adding a mineral acid as  required  to achieve  the
desired pH. The solutions are  then filtered, and  the
contaminant concentrations  in the liquid phases are
measured.  A  second type  of  leaching  test  is
conducted  by  mixing  a  sample  of  waste with
deionized  water and allowing  the waste  itself to
control the pH. This type of leaching simulates the
action  of  rainfall   or   other   water, whereas  the
pH-adjusted  leaching  tests  simulate  the effect  of
simultaneous disposal with strongly acid or alkaline
wastes or of disposal on  soils of various pH. A third
type of leaching test is  conducted using municipal
landfill leachate as the solvent.  This  highly odorous
material contains many organic acids and is strongly
buffered  at a  pH of  about 5.  Consequently, it has
proved to be a very effective  solvent. This type of
leaching  is carried  out  to  simulate  the effect  of
simultaneous  disposal with municipal and industrial
wastes.

A  second major consideration  regarding the  leaching
behavior of wastes is time. Some wastes will  not
release appreciable  amounts of  contaminants  until
leaching  has  removed  salinity or reserve alkalinity
from the waste. Accordingly, each of the 3 types of
leaching tests is extended over a period of time. The
liquid is allowed to  remain in contact with the waste
for 72 hours and is agitated gently during this time.
Afterward  the  liquid  is  filtered off,  and a fresh
volume  of  liquid is added.  This process is repeated
seven times,  each  time  for  a  contact  period of
                                                   -27-

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72 hours.  Results  to  date  have  indicated  great
variability in the time-dependent leaching behavior of
wastes, confirming the need for careful consideration
of  this  variable   in  managing  land  disposal  of
hazardous wastes.

Co-Disposal

Environmental effects of landfilling result not only
from the soluble and slowly soluble materials  placed
in the landfill, but also from the products of chemical
and    microbiological    transformations.    These
transformations  should  be a  consideration  in the
management of a landfill to the extent that they can
be predicted or  influenced by disposal operations.

One  current project8  supporting development of the
 landfill  design  and operation manuals is a study  of
factors influencing: (a) the rate of  decomposition  of
 solid waste in a sanitary landfill; (b) the quantity and
 quality  of  gas   and  leachate   produced  during
 decomposition;  and   (c) the  effect of  admixing
 industrial  sludges and sewage sludge  with municipal
 refuse. Six industrial  sludges and sewage sludge in 3
 different  amounts have  been added  to simulated
 landfill test cells to evaluate the impact of a practice
 which is prevalent in the United States as a method of
 disposal  for hazardous  wastes. Presently,  little  is
 known  about what effect adding sludge has  on the
 decomposition  process,  and  on the quantity and
 quality  of  gases  and  leachate  produced  during
 decomposition.  There   is  a  strong concern  that
 addition of sludges, particularly those high in heavy
 metals, will result  in elevated metal concentrations in
 the  leachates  and will   pose   a  threat  to potable
 ground water supplies. Advocates  of co-disposal  of
 sludges  with  municipal  waste  believe  that  the
 presence of  organics  in  the landfill  will immobilize
 heavy metals. They also believe that the presence of
 such  sludges  may   accelerate  the  decomposition
 process  and shorten the time required for biological
 stabilization  of the  refuse  because  of the  high
 moisture content  and, frequently, the high pH and
 alkalinity  of these sludges. Periodic analysts  of the
 leachates in this study is expected to  provide answers
 to some  of these questions and  to allow rational
 evaluation of the practice of co-disposal.

 Poliovirus8 has been added to  one  simulated  landfill
 cell and the leachates from all  cells are being assayed
 for fecal coliform and fecal streptococci to study the
 potential health impacts  of  landfilling.  It has been
 assumed that the environment within a  landfill is
 generally antagonistic to pathogenic organisms, and
 poliovirus  was  shown in vitro to  have a very low
 survival  in  landfill leachates. However, other  studies
 have  demonstrated the  presence  of poliovirus  in
 leachate  when  municipal  solid  waste was leached
 rapidly; fecal  streptococci were  found over long
 periods  of  time in landfill leachates.  Fecal col if or ms
were  also  present,  but their  numbers in leachate
decreased considerably within several  months after
placement of refuse.

POLLUTANT MIGRATION THROUGH SOILS

Present management of land disposal  of  hazardous
wastes   is   frequently   inadequate.   Significant
environmental  impacts from  such activities are  not
mere possibilities - actual damages to ground water
have  occurred and  are  well documented. Although
the   potential  for  damage  in  general  can   be
demonstrated, migration  patterns of  contaminants
and the damage which would result from unrestricted
landfilling  at  specific  sites cannot  be  predicted
accurately. The ability to  do this must be developed
in order to justify the requirement for changes in the
design  and operation of disposal sites, particularly for
any  restriction   of  co-disposal.  Consequently,  a
significant number of the research projects funded by
SHWRD are focused on understanding the process of,
and   predicting  the   extent  of,  migration   of
 contaminants  (chiefly  heavy   metals)  from  land
 disposal  sites  used for  municipal  and  hazardous
 wastes. This research involves:

    • Studying the migration of hazardous materials
      in soils;

    • Documenting the movement of such materials
      to  establish the link  to  health/environmental
      effects; and

    • Establishing the role of  soil  in  controlling or
      reducing the  amount  of harmful  substances
      reaching water or air.

 These   pollutant  migration   studies  are  being
 performed    simultaneously    using: (a) industrial
 hazardous   wastes;   (b) municipal   refuse;   and
 (c) specialized wastes.  Several previous reviews (e.g.,
 Roulier, 1975) of these efforts have been presented.

 Bibliography and State-of-the-Art

 A  preliminary  bibliography7  relating to the  land
disposal of hazardous wastes other than sewage sludge
has been  developed.  It comprises the results of  a
search  of  recent literature and includes  information
about  the  transport,   transformation,  and  soil
retention  of arsenic, asbestos, beryllium, cadmium,
chromium, copper, cyanide, lead, mercury, selenium,
zinc, halogenated hydrocarbons, pesticides, and other
hazardous substances. In order to limit the size of the
resulting publication, the  literature search focused on
processes  directly related to transport (adsorption,
ion exchange, etc.) and  on documentation of  the
occurrence and extent of  transport while  specifically
excluding  topics such as uptake and translocation by
plants,   theoretical   modeling,  and  effects   on
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microorganisms   and   processes   mediated   by
microorganisms. The bibliography has been divided
into two volumes  to  facilitate  its  use. Citations
regarding pesticides have been  placed in a separate
volume,  and  detailed  information about  chemical
nomenclature and  structures  of pesticides has been
appended to that volume.

A "state-of-the-art"  document7  has  been  prepared
dealing with  the migration through soil of potentially
hazardous pollutants contained  in  leachates from
waste  materials. This work  is  being  published in a
report  entitled  "Movement  of  Selected   Metals,
Asbestos, and Cyanide in Soil: Applications to Waste
Disposal Problems",  EPA-600/2-77-020, April 1977.
The  document presents  a   critical   review  of  the
literature  pertinent  to  biological,   chemical,  and
physical reactions,  and  to mechanisms of attenuation
(decrease in  the maximum  concentration  for some
fixed  time as  distance traveled)  in  soil systems of
selected   elements,  such   as   arsenic,  beryllium,
cadmium, chromium,  copper,  iron,  mercury,  lead,
selenium,  and  zinc,  and  of   such  minerals  and
compounds as asbestos  and cyanide.

Controlled Laboratory  Studies

The initial effort7 in this area  is the  examination of
the factors  which  attenuate  contaminants (limit
contaminant transport) in leachate  from  municipal
solid  waste  landfills. Although  the work is strongly
oriented toward   problems   of  disposal  of strictly
 municipal wastes, the  impact  of  co-disposal  of
 municipal and  hazardous wastes  is  also considered.
The project  is concerned with contaminants normally
 present   in  leachates  from  municipal  solid waste
 landfills and with  contaminants  that are introduced
 or  increased  in   concentration   by  co-disposal  of
 hazardous wastes. These  contaminants are: arsenic,
 beryllium,  cadmium,  chromium, copper,  cyanide,
 iron,  mercury,  lead, nickel,  selenium, vanadium, and
 zinc.

 The  general approach was  to  pass  municipal  waste
 leachate as  a  leaching fluid  through  columns of
 well-characterized  whole soils,  containing a variety of
 organic and inorganic substances,  maintained  in a
 saturated,   anaerobic   state.  The   leaching   fluid
 consisted of typical  municipal refuse  leachate with
 high concentrations of metal salts added to achieve a
 nominal  concentration  of  100mg/l.  The   most
 significant factors  were then  inferred from correlation
 of  observed  migration  rates  and  known soil  and
 contaminant   characteristics.    This   effort    will
 contribute  to  the  development  of  a  computer
 simulation  model  for  predicting   trace  element
 attenuation in soils.

 The  second effort7 in this  area is the study of the
 removal of  contaminants from  landfill leachates by
soil  clay  minerals. Soil  columns  were utilized and
packed with mixtures of quartz sand and nearly pure
clay minerals. The leaching fluid consisted  of "as is"
typical municipal refuse leachate without  metal salt
additives. The general approach to this effort was
similar  to that  described  in  the preceding effort
except  that: (1)both   sterilized   and  unsterilized
leachates  were  utilized  to  examine  the  effect  of
microbial activity  on  hydraulic  conductivity; and
(2) extensive studies of the sorption of contaminants
from leachate on the clay minerals as a function of
pH   and  the   composition   of  leachate  were
investigated.

The third effort7 in this area  is the examination of
the   potential  for  contaminant   migration  from
industrial hazardous wastes disposed of on land. After
the composition and leachability of a  waste has been
established, a leachate from the waste is  applied to
columns of  various soils in  the laboratory to allow
study of rates of movement  of contaminants. Wastes
from the following industries are being studied or are
scheduled for study:

      Electroplating
      Inorganic pigments
      Water-based paints
      Nickel-cadmium batteries
      Chlorine
      Lead-acid batteries
      Carbon-zinc primary batteries
      Hydrofluoric acid
      Phosphorous
      Aluminum fluoride
      Titanium pigments
       Refining of used petroleum
       Flue gas desulfurization

 Because  of the chemical  complexity of hazardous
 wastes,  it is not  possible  to  simulate them; actual
 wastes are being  collected  and used  in the  project.
 Many  of these  wastes are being disposed of with
 municipal  wastes. To  assess  the potential  adverse
 effects  of  co-disposal,  the  industrial   wastes  are
 leached with  municipal  landfill  leachate  as well as
 water. Results to  date  indicate that when compared
 with  water, municipal  landfill  leachate  solubilizes
 greater  amounts  of  metals  from the  wastes  and
 promotes more rapid migration  of  metals  through
 soil. The soils being used in this  study are similar to
 those  being  investigated   in  the above described
 activities. It is anticipated that during the life of this
 effort,  studies will  be conducted on 43 industrial
 wastes,  3  types  of  coal  fly ash,  and 6  sludges
 generated by the  removal  of  sulfur oxides  from the
 flue gases of coal-burning power plants.

 The fourth effort7 in this area is a laboratory study
 of the  migration and  degradation  in   soil  of  the
 pesticides   methyl   parathion,   2,4-D,   Atrazine,
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 Trifluralin, and  Terbacil  applied  at  concentrations
 much higher than  those  used in normal agricultural
 practice.  The  intent of  the project is  to supply
 information  applicable to  problems encountered in
 land disposal of  pesticides and of solutions from the
 washing  of  pesticide application  equipment.  Such
 information  is presently  lacking because most  work
 to date  has been  conducted from an  agricultural
 rather than  a  disposal point of view and very low
 application rates have been used. The project includes
 work on adsorption-desorption,  chemical-microbial
 degradation, metabolite production, and soil column
 studies of migration rates. Data collected during the
 study will also be used to test the applicability  (at
 high concentrations)  of  existing pesticide migration
 models in predicting the rate and extent of movement
 through soil. Work to date indicates  that prediction
 errors will be greatest for highly  soluble pesticides;
 the  difference in  the  isotherm  for  low and high
 concentrations is the source of this error.

 Field Verification

 The  initial effort7  in  this  area  is to test current
 assumptions about  the  effectiveness of clays and
 other fine-textured earth materials in restricting the
 movement  of  contaminants into ground waters. We
 are examining  patterns of contaminant migration that
 occur as  a result of 2 secondary zinc smelting plants
 and an organic chemical manufacturing plant that are
 storing or disposing of their wastes on land. The soils
 in the area are  quite fine textured  and, based  on
 current knowledge of contaminant migration, should
 provide safe disposal sites.

 The  second  effort7 in this area relates to the use of
 simulation  modeling  as  one  method of predicting
 contaminant   movement   at disposal  sites.  The
 two-dimensional  model  which was used successfully
 to study  a chromium contamination problem is being
 developed into a three-dimensional model and will be
 tested at  a well-monitored landfill where contaminant
 movement has already taken place.  Although this
 type of model presently needs a substantial amount
 of input  data, it appears promising for determining
 contaminant transport properties of field soils and,
 eventually,  for  predicting contaminant  movement
 using limited amounts of data.

 Organic Contaminants

 A  planned  effort2  to be  initiated this fiscal  year
 relates to  organic contaminant attenuation by soil.
 Much  more  is  known  about  wastes  containing
 inorganic  contaminants than those containing organic
contaminants.  Analytical  techniques  for inorganic
materials  are well-developed and   relatively cheap
compared  to  analytical   techniques  for  organic
materials  which  are  both  time  consuming  and
expensive. The  problem  is  compounded  because
organic contaminants are more numerous, and more
are being synthesized all the time.

Work on predictive techniques has been included as a
part of all  contaminant migration projects  because
the  results from this  type oi work are only useful
insofar as they can be  applied to situations which
have not  been  studied. The results to  date  lack
generality, and no  one predictive technique can be
advocated at this time.

CONTROL TECHNOLOGY

Control technology is  needed  because experience and
case  studies  have  shown  that  some  soils will not
protect ground water  from  contaminants. Even  in
"good  soil",  selected  sites  may  have  to  be
supplemented by  additional  protection  to  prevent
subsurface   pollution  from  especially   hazardous
wastes. To minimize the impact of placing hazardous
wastes in  conventional  landfills, various treatments
are under investigation that are directed either toward
modification   of  the  waste  prior to  disposal or
modification of the waste disposal site.

Treatments

Natural Soil Processes:

The treatment by natural soil processes of pollutants7
from hazardous waste and municipal refuse disposal
sites  is   basically  being  performed  under  the
"Pollutant Migration through  Soils" studies whereby
various  raw  soils  are  being evaluated  for  their
pollutant   attenuation   capabilities.    The   U. S.
Department   of  Agriculture  (USDA)  soils series
currently  being  investigated  are: Anthony,  Ava,
Chalmers,  Davidson,   Fanno,  Kalkaska,  Mohave,
Molokai,   Nicholson,   and  Wagram.  These  soils
encompass the range  of soil  types -  from  sand to
clays to silts.  Other soils are  also being investigated
whereby  various  percentages  of the  clay minerals
kaolinite, montmorillonite, and itlite are mixed with
pure sand to form various mixtures of sand and clay
soils.

Physical/Chemical/Biological Processes:

Recognizing    the    present     inadequacy    of
treatment/disposal    technology   for    hazardous
materials, a SHWRD in-house research project6 was
initiated that resulted in a report describing promising
methods for  treating complex waste streams  and for
providing  resource recovery potential. The promising
methods identified were:

     Chlorinalysis
     Wet air oxidation
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       Decomposition by acids and bases
       Chemical oxidation
       Other chemical treatments
       Biological degradation
       —enzymes
       —trickling filters
       -activated sludge
       Catalysis
       Batch and continuous ion exchange
       Photochemical processing
       Low-temperature microwave discharge
       Osmosis/ultrafiltration
       Activated carbon absorption

 Another   in-house   study9  entitled   "Degradation
 Mechanisms:  Controlling   the   Bioaccumulation  of
 Hazardous    Materials",    EPA-670/2-75-005,   was
 conducted  to determine  the impact of  hazardous
 materials released into the environment.  This study
 revealed that  many  of the materials discharged are
 persistent  or  nonbiodegradable, will accumulate in
 man, and pose a serious threat to all living systems.

 A number  of  research  efforts have been initiated to
 develop and evaluate promising treatment techniques,
 identifed above, for  control  of  hazardous materials.
 The initial effort9 relates to the chlorinalysis process
 which appears  to be desirable for  eliminating some
 toxic   and  hard-to-dispose-of  chlorocarbons   and
 pesticide residues. This was a technical and economic
 study  of the  feasibility  of converting highly toxic
 wastes to  carbon  tetrachloride and  other  useful
 chemicals.  Laboratory  studies  have confirmed that
 herbicide   orange,   still-bottoms    from   organic
 manufacturing operations,  and pesticides can all be
 converted  to  the principal useful chemical, carbon
 tetrachloride.

 A second  effort6 relates  to  the investigation  of
 catalytic techniques for decomposing pesticides  and
 other  toxic wastes  to safe,  reusable  by-products.
 Basically, the catalytic  hydrogenation of chlorinated
 organic compounds is baing studied. While the results
 of  catalysis  are not   as  favorable  is  those   of
 chlorinalysis, there is evidence that a catalysi may be
 discovered that will  remove  the group of elements
 conferring  toxicity to a parent structure, and thereby
 provide a feedstock  for the synthesis of new useful
 chemicals.

 A  third   effort9  relates  to   the   assessment   of
 techniques  for  the   detoxification   of   selected
 hazardous   materials.   The   existing   techniques,
 identified above (including hydrogenation), are being
assessed  for  efficacy  and  practicality.  This also
 includes chemical and  toxicological investigation  of
all   products   and   residues   provided   in   the
aforementioned incineration studies or  the developing
detoxification studies. A  report  describing  results of
 the detoxification processes has been  received, and
 publication is planned for the near future.

 A fourth effort7 relates to a laboratory evaluation of
 10 natural  and synthetic  materials  (bottom ash, fly
 ash,  vermiculite,  illite,  Ottowa  sand,  activated
 carbon, kaolinite, natural zeolites, activated alumina,
 cullite)  for the  removal   of  contaminants  in  the
 leachate and  liquid portion of 3 different industrial
 sludges:  calcium fluoride  sludge; petroleum  sludge;
 and metal finishing sludge. This investigation involves
 studies to evaluate the static adsorption capacity of
 sorbent   materials  using   maximum  background
 concentrations  of contaminants  in   the  leachate,
 followed  by studies to obtain information regarding
 the dynamic absorption capacity and  permeability
 characteristics of these materials. The  analysis of the
 leachates   involves  the   determination   of   pH,
 conductivity,  residue,  chemical  oxygen  demand
 (COD), total  organic carbon (TOO, anionic species,
 and cationic  species  before and after contact with
 sorbent materials.

 Thermal Decomposition:

 Treatment  by thermal decomposition  relates to the
 establishment of time-temperature  relationships for
 the incineration of pesticides. Specifically, through
 the test program,  existing  information will  be
 summarized into  a state-of-the-art document,  and
 experimental    incineration/decomposition  studies
 will be conducted  on approximately 40 pesticides. A
 laboratory scale evaluation/confirmation study and a
 pilot-scale incinerator study are being performed. The
 pesticides   investigated for  thermal  decomposition
were:
      DDT
      Aldrin
      Picloram
      Malathion
Toxaphene
Captan
Zineb
Atrazine
The initial  nftort4  relates  to  the deterrrvnation of
incineration conditions necessary fo<  safe  iispesa* of
pesticides.   An   experimental    incinerator   was
constructed   and   utilized   to   determine   the
time-temperature  conditions   needed  for  the  safe
destruction  of  pesticides.  This  research  is  being
supplemented  by  another effort documenting in
detail the various research projects relating to thermal
destruction of pesticides.  Efficiencies of combustion,
residence  time,  and   other   parameters   for   safe
incineration were documented.

A second effort4   relates  to  the development of
laboratory-scale   methods   for   determining   the
time-temperature relationships for the decomposition
of  pesticides. The  successful  achievement of  this
effort would allow the ust  of  quick laboratory  test
                                                  -31 -

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 methods   to   determine   the  best   incineration
 conditions for full-scale destruction of pesticides.

 Isolation

 Underground Cavities:

 The  technology for  the  isolation  of wastes  in
 underground cavities offers attractive possibilities for
 disposal  of  concentrated  toxic hazardous  wastes.
 Efforts have been performed to evaluate:

    •  Deep-well injection (for  liquid waste disposal)
      including wells and permeable formations; and

    •  Salt mines and  hard-rock mines for storage of
      solid, fixed, or encapsulated wastes.

 The initial effort1 ° consisted of a review and analysis
 of  available   information  related  to  deep-well
 injection, and   an  assessment  of  this  method  for
 managing hazardous wastes and ensuring protection
 of the   environment  has  been  made.  The  study
 provided a  comprehensive compilation  of available
 information  regarding   the injection  of industrial
 hazardous    wastes   into   deep   wells.   Limited
 assessments  made  have  indicated  that deep-well
 injection of selected wastes is environmentally safe,
 provided  that  sound  engineering  and  geologic
 practices are followed in constructing and operating
 the well. Geologic and engineering data  are available
 in many areas to  locate,  design,  and operate  a
 deep-well system for injecting liquid  hazardous wastes
 into  saline aquifers  (salaquifers)   and  other  deep
 strata.  However, there  is  little information  about
 salaquifer   chemistry   and   the   chemical  and
 microbiological reactions of wastes within a receiving
 salaquifer. Federal and state statutes and regulations
 vary  greatly or  do not exist  to  answer problems
 arising  from  the  use   of interstate or intrastate
 aquifers.  Regardless of  these  identified  problems,
 deep-well injection  remains a suitable alternative for
 waste management.

 The  second  effort10  consisted of a  review and
 analysis   of   information about  the placement  of
 hazardous  wastes  in  mine openings.  The   study
 assessed   the   technical   feasibility   of   storing
 nonradioactive   hazardous   wastes  in underground
 mine openings.  The results showed that a majority of
 the wastes considered can  be stored underground  in
 an environmentally acceptable  manner  if they are
 properly  treated and  containerized. Various mine
 environments in the United States are applicable for
 such storage. Room and  pillar  mines in salt, potash,
and gypsum appear to be the  most favorable. This
 review concluded that storage in underground mines
 is  an environmentally acceptable method of managing
hazardous wastes provided  that the recommended
procedures   of   site  selection,  waste   treatment.
containerization,  and  handling  are  followed.  The
study showed that there now exists within the United
States environmentally  suitable underground space
for the storage/disposal of hazardous wastes. Systems
adequate to  detect, monitor,  and  control  waste
migration are  available or can  be developed  from
current technology.

Encapsulation:

The encapsulation technology program  is evaluating
promising organic and inorganic chemical processes
for fixing and coating hazardous  materials such  as
pesticides, soluble organics, and  heavy oily residues.
The  process  fixes   the  hazardous  material  in  a
55-gallon drum or in up to a 500-pound block and
then encapsulates the drum or block with a coating  of
nonporous plastic.

The initial effort10  relates to an organic chemical
process  to  encapsulate  effectively  hard-to-manage
hazardous wastes  into a relatively  dense mass which
will not  pollute  and  which  could  be utilized  or
disposed of in roadbeds, mines, or fill areas.

Stabilization

Stabilization is  achieved  by incorporating the solid
and liquid phases of a waste  into a  relatively inert
matrix which  increases  physical strength and protects
components of the waste from dissolution by rainfall
or  by ground water. If stabilization slows the rate  of
release  of pollutants from the waste sufficiently  so
that  no  serious  stresses  are  exerted  on  the
environment around the disposal  site, then the wastes
will have  been  rendered essentially harmless  and
restrictions on where the disposal site may be located
will be minimal.

Chemical Fixation:

The initial effort6 relates to the transformation of the
waste into an insoluble or minimally soluble form to
prevent significant leaching. The test program consists
of investigating 5 industrial waste streams, both in the
raw and fixed state.  Each waste stream will be treated
with  5 separate fixation  processes and  subjected to
leaching  and  physical  testing.  These  laboratory
studies   will  identify  which  processes  should  be
evaluated in the field by using large-scale field plots
or  I y si meters. Co-disposal of  the  fixed waste with
municipal  refuse  will  also be investigated.  The  5
industrial wastes  being investigated are the same  as
those being investigated  in the  pollutant migration
study:

      Electroplating
     Chlorine production
      Nickel-cadmium battery production
      Inorganic pigment manufacturing
     Calcium fluoride (electronics)
                                                   -32-

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 The following fixation processes will  be utilized with
 either  industrial  waste or  flue  gas  desulfurization
 waste  {SOX)  sludge.  The assignment  of  sludge
 categories to processors is shown below:
PROCESSOR
1. International Utilities Conversion
System, Inc. (IUCS)
2. Chem-Fix, Division of
Environmental Sciences
3. Nuclear Engineering Company —
Tiger-Lok Process
4. Wehran Engineering — Krete-Rok
Process
5. TRW Systems Group, Inc. - Organic
Binder
6. Lancy Lab
7. Oravo
SLUDGE
CATEGORY
Indus-
trial
Waste
X
X
X

X

Calcium
fluoride
only
Flue Gas
Desulfur-
ization
X
X

X

X
X
The   second   effort6   will   involve:  identifying
additional  stabilization processes that have  potential
application  to  landfill ing   of  hazardous  wastes;
studying the chemistry of these  processes to eliminate
duplication of work already underway; and evaluating
selected  processes  using  the  procedures  already
developed.

The third   effort6 is a  series  of  field verification
studies  to  assess the success with which pollutants
have been  immobilized at landfills receiving stabilized
hazardous  and  SOX  wastes. Detailed  investigations
will identify any movement  of  pollutants  away from
such  sites  and  interactions with  soils  that have
accelerated or  retarded such movement.  Sites have
been  selected to give the widest  possible  range  of
stabilization processes, wastes, and soils.

Liners/Membranes:

The  liner/membrane  technology is being  studied  to
evaluate  suitability  for  eliminating   or  reducing
leachate  from  landfill  sites  of industrial  hazardous
wastes and SOX sludge wastes.  The test program will
evaluate  in  a  landfill  environment the chemical
resistance and durability of the liner materials during
12- and  24-month  periods of  exposure to leachates
derived  from  industrial  wastes,  SOX  wastes,  and
 municipal  solid  wastes.  Acidic,  basic, and  neutral
 solutions will be utilized  to generate industrial waste
 leachates.

 •   Hazardous  Waste   Disposal  Liners:  The  initial
 effort6 relates to the investigation of materials for use
 as  liners of hazardous waste  disposal sites.  These
 liners will be tested in rectangular, epoxy-coated steel
 cells (25 cm by 38 cm) containing about 30 cm of the
 hazardous  waste  above  the  material  being tested.
 Because the  composition  of  the leachate  from
 hazardous   wastes   is  determined  mainly  by   the
 solubility products of the components and  is  not
 expected to change significantly during the period of
 the experiment, no provision has been included  for
 drawing leachate from above the liner  material. Any
 leachate passing  through the liner  will be collected
 and analyzed to determine whether there  is  selective
 passage of hazardous substances from the  waste. The
 liner materials being evaluated are:

      Polymeric membranes

           Butyl rubber
           Chlorinated polyethylene (CPE)
           Chlorosulfonated polyethylene (Hypalon)
           Ethylene propylene  rubber (EPDM)
           Neoprene
           Polyvinyl chloride (PVC)
            Elasticized polyolefin
           Polyester elastomer

      Admixed materials

            Emulsified asphalt (Petromat)
           Soil cement
           Hydraulic asphalt concrete
           Compacted fine-grained soil
           Polymeric  bentonite sealant

 A second effort7 relates to a laboratory evaluation of
 various materials which could be utilized as retardant
 materials to  minimize  migration of pollutants from
 disposal sites.  This  investigation  will  study  the
 following    materials   on    a    pilot    plant
 basis:  (a) agricultural  limestone, (b) hydrous oxides
 of  iron  (ferrous  sulfate mine waste), (c) lime-sulfur
 oxide  (stack-gas  waste),  (d) certain organic wastes,
 and  (e) soil  sealants.   Preliminary   research   on
 limestone and iron hydrous oxide liners indicates that
these  materials have a  marked retarding influence on
 many trace  elements.  However, the increased  water
contamination  from solubilization  of  iron  oxides
seems to rule out use of this treatment.

•   SOX  Sludge  Liners: The  initial effort6 relates to
the types of materials to be tested for use as liners for
sites receiving sludges generated by the removal of
sulfur oxides (SOX) from flue  gases of coal-burning
                                                   -33-

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power plants. The volumes of SOX sludge generated
in any particular place will typically be much greater
than those for other types of wastes, the disposal sites
will  be large, and the  hazards  (leachable trace and
heavy  metals) associated with the sludge  will not be
great. Consequently, methods of lining such disposal
sites must have a  low unit cost  to be covered. It is
desirable that the materials be easy to apply. Because
of these considerations,  the number  of polymeric
membranes  included in the study have been reduced
whereas admixed and sprayed-on materials are being
emphasized.  A total of  18 materials/processes  are
being evaluated. These include:

      Polymeric Materials

            Elasticized polyolefin
            Neoprene

      Admixed Materials

            Soil cements
            Lime stabilized soils
            Asphalt cements
            Emulsion asphalts
            Chemically stabilized SOX  sludge

      Sprayed-on Materials

            Polyvinyl acetate
            Natural latex
            Natural rubber latex
            Asphalt cement
            Hot sulfur

SPECIALIZED WASTES

The   specialized-waste   test  program  relates   to
hexachlorobenzene  (HCB), vinyl chloride monomer
(VCM), and oil  spill  debris. HCB wastes are being
investigated  to determine the volatilization of these
materials and to evaluate the effectiveness of various
materials   for  covering   these  wastes  to   reduce
volatilization.  VCM  is  retained  in polyvinyl chloride
(PVC)  processing sludge  wastes. These  sludges  are
being  investigated to determine the amount of VCM
present and the volatilization of the material. Oil spill
debris from cleanup efforts is being  investigated to
determine the best practicable methods available for
disposal.

Hexachlorobenzene (HCB)

The initial  effort7  relates to  an evaluation of  the
effectiveness of the  procedures presently being used
to seal  HCB landfills. This evaluation is conducted by
measuring the rate of movement of HCB through soil,
water, and  polyethylene film.  Results  of the study,
conducted under contract, will be used to specify  the
conditions,  if any, under which  it is safe to store or
dispose  of  HCB-containing  wastes  on  land.  The
general approach is to measure the steady state vapor
flux of  HCB under laboratory  conditions and then,
using Pick's first  law,  to calculate  the diffusion
coefficient  for  HCB  in that  material.  Once  the
diffusion coefficient is known, the flux through other
thicknesses of the  material can  be calculated. Results
to date indicate that compacted  soils of moderate
water  content   are   effective  barriers   to  HCB
movement. This suggests that safe landfills for HCB
could be constructed. However, results also indicate
that a meter's thickness of HCB could continue to
volatilize for as  long as 12 x 106 years, casting doubt
on the wisdom of land disposal for this waste.

Vinyl Chloride Monomer (VCM)

The initial effort10 relates to a study that determined
whether  a potential threat to the health of landfill
workers or nearby residents exists  as a result of VCM
disposal. Seventeen grab samples of air, analyzed in
the laboratory for  VCM content were collected  at 3
landfills  where  VCM sludges had  been disposed of.
Samples  of  PVC sludges  which  had been disposed of
at  the  3  landfills  also  were   collected. VCM
concentrations   in  the grab air and  sludge samples
were measured  using the gas chromatographic-flame
ionization detection technique. The  release rate of
VCM from sludge also was measured under controlled
laboratory  conditions,   using  a  specially  designed
apparatus. The VCM emissions  potential of the total
sludge  quantities   disposed  at  these landfills  was
calculated.

Oil Spill Debris

The  initial  effort12  is being performed  by the
 Industrial   Environmental   Research   Laboratory
 (IERL) of  EPA and relates to  the development of a
detailed,  practical, how-to-do-it manual  for  oil  spill
debris   disposal   and   to  the   making  of  an
accompanying  film for  state and local  officials. A
literature  search   has   been  completed,  sites  for
confirming  field studies  have been chosen, and some
film   footage   has    been   taken.    Present
recommendations  for   disposal   of  unrecyclable
material  include  burial,  incorporation  into  an
approved sanitary landfill, and land spreading.

ALTERNATIVES  FOR   HAZARDOUS   WASTE
LANDFILLS

Land Cultivation

The disposal technique  of land cultivation, whereby
specific waste residues have been directly applied to,
or  admixed into  soils has for many years been an
option for disposal of oily waste materials.  Because
many  industrial waste  sludges have characteristics
similar  to oily  waste materials, it appears that  land
                                                  -34-

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      cultivation could be a useful alternative to landfilling
      of hazardous  industrial  sludges. A state-of-the-art
      document to assess and determine the feasibility and
      beneficial aspects  of  land  cultivation  of hazardous
      industrial sludges, including oily waste  materials, will
      be available  about the  end  of the calendar  year
      1977.6 This state-of-the-art document would then be
      followed by a technical and economic assessment.

CONCLUSION

      The  laboratory and field research projects discussed
here reflect  the SHWRD overall effort in hazardous waste
management  research.  The projects will  be discussed in
much   more  detail  by  the  following   speakers.  More
information  about  a specific  project or study  can  be
obtained by contacting the project officer  whose name,
address, and phone number is listed in this paper. Inquiries
can also be  directed to  the Director, Solid and Hazardous
Waste  Research   Division,   Municipal    Environmental
Research   Laboratory,  U. S.  Environmental   Protection
Agency, 26 West  St. Clair  Street, Cincinnati, Ohio 45268.
Information will  be  provided with the understanding that it
is from research in  progress and conclusions may change as
techniques are  improved and  more  complete data become
available.
                    REFERENCES CITED

Roulier, M. H. 1975. Research on minimizing environmental impact
     from landfilling:  Research  on  contaminant movement in soils.
     Presented at a meeting of the NATO Committee for Challenges
     to  Modern  Society,  Project  Landfill.  London,  England.
     October 20-23,1975.

Schomaker, N. B., and Roulier, M.  H. 1975. Current EPA research
     activities in solid waste management. Research symposium on
     gas and  leachate from landfills:  Formation,  collection and
     treatment.  Rutgers,   State  University  of  New   Jersey.
     March 25-26, 1975.

Schomaker, N. B. 1976a.  Current research on  land disposal of
     hazardous  wastes: Residual  management by land  disposal.
     Proceedings of  the Hazardous  Waste Research  Symposium.
     University of Arizona. February 2—4, 1976.
Schomaker, N.  B.  1976b. Current research on land disposal  of
    hazardous wastes. Engineering Foundation Conference, Land
    Application   of  Residual   Materials.   Easton,  Maryland.
    September 26 — October 1, 1976.
                        FOOTNOTES

 1.  Director, Solid and  Hazardous Waste Research Division, U. S.
     Environmental Protection Agency, Cincinnati, Ohio 45268.

 2.  Chief,  Disposal  Branch, Solid and Hazardous Waste Research
     Division, U. S. Environmental Protection  Agency, Cincinnati,
     Ohio 45268.

 3.  Dr. Jerry  F. Stara, Health  Effects Research Laboratory, U. S.
     Environmental Protection  Agency,  26 West  St. Clair Street,
     Cincinnati, Ohio 45268. 513/684-7406.

 4.  Mr.  Richard  A. Carnes, Municipal  Environmental Research
     Laboratory, U.S. Environmental  Protection  Agency, 26West
     St. Clair Street, Cincinnati, Ohio 45268. 513/684-7871.

 5.  Mr.  Michael  Gruenfeld, Industrial   Environmental Research
     Laboratory, U. S. Environmental  Protection  Agency, Edison,
     New Jersey 08817. 201/548-3347.

 6.  Mr.  Robert E.  Landreth, Municipal Environmental Research
     Laboratory, U. S. Environmental  Protection  Agency, 26 West
     St. Clair Street, Cincinnati, Ohio 45268. 513/684-7871.

 7.  Mr.  Mike H.  Roulier, Municipal   Environmental Research
     Laboratory, U. S. Environmental  Protection  Agency, 26 West
     St. Clair Street, Cincinnati,  Ohio 45268. 513/684-7871.

 8.  Mr.  Dirk  R. Brunner, Municipal   Environmental Research
     Laboratory, U.S. Environmental  Protection  Agency, 26West
     St. Clair Street, Cincinnati,  Ohio 45268. 513/684-7871.

 9.  Mr. Charles  J.  Rogers, Municipal  Environmental Research
     Laboratory, U. S. Environmental  Protection  Agency, 26 West
     St. Clair Street, Cincinnati, Ohio 45268. 513/684-7881.

 10.  Mr. Carlton  C.  Wiles, Municipal   Environmental Research
     Laboratory, U. S. Environmental  Protection  Agency, 26 West
     St. Clair Street, Cincinnati, Ohio 45268. 513/684-7881.

 11.  Mr. Donald A. Oberacker, Municipal Environmental Research
     Laboratory, U. S. Environmental  Protection  Agency, 26 West
     St. Clair Street, Cincinnati, Ohio 45268. 513/684-7881.

 12.  Mr. John S.  Farlow, Industrial   Environmental Research
     Laboratory, U. S. Environmental  Protection Agency,  Edison,
     New Jersey 08817. 201 /548-3S47.
                                                             35-

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                                 USE OF MODEL LEGISLATION IN DEVELOPING
                                  A STATE HAZARDOUS WASTE CONTROL LAW

                                          I. MISSOURI HOUSE BILL 318

                                              Chilton W. McLaughlin
                                                 Sanitary Engineer
                                        Air and  Hazardous Materials Division
                                       U. S. Environmental Protection Agency
      The  development  of  hazardous waste management
legislation  for the State of Missouri began inadvertently in
May 1971  when waste oil was spread on Judy Piatt's horse
show arena in Moscow Mills, Missouri. For her, the next 3
years were a nightmare as 63 horses, the  family pets, and
countless wild animals died  of poisoning. Her two children
became sick with a chemically induced malady. The culprit
was "dioxin" contained  in the waste oil  and  was  not
identified for 3 years.
      In  an  unrelated   turn  of  events,  the  Missouri
Department of  Natural  Resources (MDNR),  Solid Waste
Management Program, began a Hazardous Waste Project in
1974  to  investigate  the  extent  of  hazardous waste
generation   statewide and to develop methods to ensure
control over such  wastes. The project began  with the hiring
of  Dr. Joseph Eigner, a research chemist from  Washington
University  in St. Louis, who initiated a survey of hazardous
waste generation  and began to explore the needs of a State
program. The survey results will be presented by Robert
Pappenfort, a chemical engineer with the project, on the
last day of  this conference.
      During  the  3  years of  the  project. Dr. Eigner
demonstrated  a  unique ability to understand the needs of
industry, public  interest groups, and  State agencies.  He
recognized  the   need   for a   method  of  identifying
constituents of industrial waste streams, so  that industries
could evaluate and perhaps find methods  of utilizing their
wastes. In  May  1975 the MDNR, the U. S.  Environmental
Protection   Agency  (EPA),  and the  East-West  Gateway
Coordinating  Council  sponsored a  meeting of industrial
waste  generators,  transporters,  brokers, treatment  and
disposal  facility   operators, and  the  public  to discuss
methods of recycling and/or recovering industrial wastes in
the St. Louis  area. From this  meeting, a task force was
formed with open representation to evolve a concept of an
"exchange".  The  task  force   met   monthly  through
November  1975,  and the  needs of industry slowly became
understood so that those needs could be formulated into an
organizational design which would work.
      In December 1975, the task force  approached the
St. Louis Regional Commerce and Growth Association with
the  exchange  concept,   and together they   began  the
St. Louis Industrial Waste Exchange in January  of 1976 as
the first nonprofit industrial waste clearinghouse in the
United States.
      Throughout the evolution of the exchange. Dr. Eigner
was a quiet leader and an alert observer of how to obtain
cooperation between environmental  and public interest
groups, industry and government. Also during this period of
time, the survey of hazardous waste generation located the
companies  in  Missouri who formed the  hazardous waste
management  service  industry.  In  addition,  the  survey
sparked the interest of several firms that recognized the
need for improved methods of treatment or land disposal of
hazardous wastes. Three permits were applied for under the
Missouri Solid Waste Management Act in the Kansas City —
St. Joseph  area explicitly  to handle such materials. Thus,
the  MDNR   had   to   design   their hazardous   waste
management   permit  program  to  ensure  health  and
environmental protection  at sites before the shape of the
State   legislation   was   even   considered.   However,
consideration of  the State program's requirements while
developing the  State legislation proved beneficial to both
efforts.
     Early in 1976 Dr. Eigner asked the  EPA  Region VII
office for assistance in gathering the laws and the program
designs of states, such as California,  that had implemented
hazardous waste  management  programs.  His request  was
honored by the development of "A Comparison of State
Hazardous Waste Management Legislation" which sought to
present, side by-side, the wording of bills from California,
Illinois, Iowa,  Minnesota, Oklahoma, and Oregon, as well as
the  draft  model acts that had been prepared by  EPA and
the  National  Solid  Wastes  Management   Association
(NSWMA). The 90 pages of comparisons provided a starting
point for the development of Missouri's legislation.
      Dr.  Eigner  was also concerned  about the  need for
involving  industry,  the  public,  and  government  in  the
process of developing the  State's legislation. In April 1976
he approached Kenneth Karen, Director of the Division of
Environmental  Quality, MDNR, with a plan to  invite all
interested  parties  to participate  in  the  process. The
following  month nearly  100 persons attended a meeting
called  by  MDNR to initiate the legislative development
efforts.  At   this   meeting   Dr. Eigner   presented  the
preliminary results of the statewide survey and  reviewed
selected case  studies of  improperly  managed hazardous
waste in Missouri. The need for legislation was established,
and  the Missouri Ad Hoc Hazardous Waste Legislative
Committee was formed.  The Committee consisted of  5
subcommittees,   one  each   on   definitions,  drafting,
responsibilities and permits, enforcement and penalties, and
citizen  participation. By November, 20 formal meetings had
been held  involving 300 person-days of  uncompensated
time, and  a  consensus  bill  had been  completed. The
deliberations  had  educated all of  us to  understand  and
appreciate each other's points-of-view.
                                                      -36-

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      The credit for the  success  of these deliberations
 belongs to the  entire Committee. Betty Wilson and other
 members  of  the  Missouri  League  of Women  Voters
 (MLWV),  Assistant  Attorney General Robert  Lindholm,
 Bernard  Raines  of  the  St. Louis  Metropolitan Sewer
 District,  Rosalie  Grasso of  NSWMA,  Curt Long of the
 Associated  Industries of Missouri,  the Missouri Highway
 Patrol and other State agencies, the Missouri Farm Bureau,
 members  of the  hazardous  waste  management  service
 industry, and  city  and  county  government officials,  all
 deserve a special vote of appreciation  for their attendance
 and contributions.
      How  did  model   legislation  aid  the Committee's
 efforts? First,  the models  provided the  Committee  with
 examples of the  best efforts of  all  the states and of the
 considerations   of  those  outside Missouri. Second,  the
 models were useful in providing explicit language for some
 sections of  Missouri's  bill,  such as  those dealing  with
 "imminent hazard", definitions, and the responsibilities of
 generators, transporters  and facility operators. Third, the
 models enabled the Committee to select  the organization
 and major provisions of the bill rather  quickly, so that
 important issues could  be  delineated  and  discussed  with
 sufficient time to allow a solution to be reached.
      Model  legislation is of two basic types. The first  is
 existing state legislation covering  similar topics which can
 provide court-tested language  in the form  of "boiler plate"
 for  major  sections of the  new bill. The second  type  of
 model legislation is that  from other  states or organizations
 which can provide  the  necessary elements  to develop  a
 comprehensive bill. The Committee drew from both sources
 to develop the  bill currently  embodied in Missouri House
 Bill 318 (MHB 318). An outline of MHB 318 is presented in
 Table 1.
      Missouri's   Water   Pollution   Control   Legislation
 provided the basic format  and the  language for sections
 on:  creation   and   powers  of  the   commission  and
 department (Sections 4-6); public hearings (11); variances
 (12); investigations,  orders, and  revocations (13); judicial
 review  (14);  and violations,  enforcement,  and  penalties
 (16). The following  sections were borrowed in part or in
 their  entirety   from   legislation  of  other  states  or
 models: the  title {Section 1);  intent  and   purpose  (2);
 definitions   (3);   responsibilities  of   generators   (7),
 transporters  (8), and facility  owners  and  operators (9);
 licenses of  transporters  and  permits  for facilities  (10);
 imminent hazard  (15); and confidential information and
 local  rights (17). Many  of the  departmental duties and
 powers were also developed from other  state's legislation or
 model laws..  The sections  unique to  MHB 318  are: the
 provisions  for  collection stations;  the requirements for
 federal  program coordination; the State plan and annual
 report;  the  registration   of  generators and licensing of
transporters; Missouri Highway Patrol Authority and public
 participation measures.
     The  open   method   of  developing  MHB 318
contributed  to  the  identification  of  many  points of
 potential conflict  with other  State  or Federal legislation
and  to the development  of appropriate language to avoid
 conflict.  Extensive negotiations on the provisions of the bill
 were carried out between private industry, interest groups,
 and the MDNR personnel, achieving a bill which all parties
 could support and understand.
       After the initial bill was developed, it was circulated
 to as many organizations as possible, and a program was
 devised  to involve  as many  persons  in the review and
 comment process as  possible.  As part  of this effort, the
 MLWV conceived of  the idea of holding a conference  or
 seminar  for   State   legislators  on   hazardous   waste
 management. In summer 1976 they  applied for assistance
 from  EPA  and received  a grant to hold  a conference on
 December 6 and 7, 1976 to  introduce the Committee's bill
 to State  legislators, to educate them about the problems
 and  needs, and to  initiate  a drive to  obtain passage  of
 MHB 318.  The  dedicated  work   of   Betty   Wilson,
 Environmental  Quality Chairman  of the  MLWV, and the
 State  staff  of the  MLWV  ensured the attendance   of
 lawmakers  from 3 states and  key State legislators  from
 Missouri. The conference was held during the pre-Christmas
 and post-election period,  but still drew  nearly 60 people
 and resulted in  numerous offers to sponsor MHB 318 from
 Missouri   State  representatives.  The   conference  also
 provided  basic information about the necessity for the bill
 as well   as who  supported  it  and  why.  No organized
 opposition to MHB 318 was (or has been)  identified.
      After the conference, an effort to enlist endorsement
 began both with the State's  executive  agencies  and the
 Legislature. Again, Betty  Wilson and Dr. Eigner  lead the
 efforts to  convince  reluctant State agencies either  to
 support or stay neutral on the issues of the bill.
      The election of State Representative  Rothman  as
 Speaker of  the House  provided a positive boost for the bill
 because he  had agreed to co-sponsor it.  Although he was
 reluctant  to embrace  the need  for a  new commission,  he
 and other key legislators added  their names to the bill  as
 co-sponsors. In addition, numerous meetings with agency
 personnel,  organizations supporting  such agencies, and
 media  representatives  began  to  pay  off with  positive
 newspaper editorials and favorable reviews of the legislation
 reaching the new Governor. Thanks to strong support from
 the  MLWV, the  MDNR  and  key legislators, Governor
 Teasdale  included  the  concept  of   the  bill   in  his
 recommendations  to  the Legislature.  This endorsement
 created even  stronger legislative  support and  provided
 additional incentive to  the Associated Industries of Missouri
 and other organizations  to  join  in the  effort to secure
 passage.
      MHB  318 has now  cleared the Missouri House  of
 Representatives  by  a  commanding  margin  with minor
 amendments. Substantial hurdles remain to be  faced in the
 Missouri   Senate on   issues  such  as sunset  provisions,
 coverage of small businesses, continued  Federal support,
 and who should appoint the new commission. However, the
 issues  are basically  of  a political nature  and  do not
challenge  the  need  for  a program administered  by the
 MDNR.  Thus,  there  is  room  for  optimism that the
 remaining issues can be resolved in time to complete action
on MHB 318 in 1977.
Note: MHB 318 was passed in June and signed into law in July 1977.
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                                                      TABLE 1
                                      OUTLINE OF MISSOURI HOUSE BILL 318
                                  Proposed Missouri Hazardous Waste Management Law
Section

   1       Title

   2       Intent  and  purpose  and  exemptions  (Regulates radioactive  wastes, air emissions,  water discharges, and
           well-injection fluids)

   3       Definitions  (Commission,  department,  director,  disposal, final  disposition, generation, generator,  hazardous
           waste,  hazardous waste  facility,  hazardous waste management, manifest, person,  resource recovery, storage,
           treatment, and waste)

   4       Creation  of  the  Waste Management Commission  (Appointment, membership,  interests, conflict of  interest,
           selection of officers, terms and limitations, removal, open meetings, call for  meetings, quorums, and voting)

   5       Powers of the Waste Management Commission (Adopt standards, rules and regulations required by the act or the
           Federal Resource Conservation and Recovery Act; procedures and considerations for adoption; coverage of the
           rules and regulations, and consistency with  other programs;  adopt and publish a  State  hazardous waste
           management plan; hold hearings; grant variances; and make orders)

   6       Powers and  Duties of the  Department  (Supervise  and  enforce the act, etc.; implement programs; provide for
           employees and consultants; budget and expend funds;  receive grants, etc.; support the commission; collect and
           maintain  records, reports, monitoring devices; secure services; make  inspections and  investigations with right of
           entry;  limitations and requirements; register generators; license transporters; permit  facilities; issue licenses and
           permits with terms and  conditions; encourage  cooperation; enter orders; institute  legal action; settle suits or
           orders; participate in  studies and research; provide technical assistance; develop interstate  agreements; arrange for
           collection stations; provide information; conduct training and education programs; facilitate public participation;
           encourage recovery; coordinate with the Federal  program; and present an annual report)

   7       Requirements of Generators (Effective date; file for registration; containerize, label, segregate, store, and handle;
           utilize  licensed transporters; provide manifests; utilize permitted  facilities or recovery facilities; maintain records
           and reports; sample wastes according to the rules and regulations; exemptions; determination of small quanitities
           of specific hazardous waste requiring special management or procedures for  small quantity handling)

   8       Responsiblities of  Transporters (Effective  date; approved equipment  and procedures; accept manifested
           shipments; sign and deliver manifest and waste only to permitted facilities or recovery facility; maintain records;
           provide samples; and obtain a license)

   9       Responsibility  of  Facility  Owners and  Operators (Effective date;  obtain a permit; accept manifested waste;
           exceptions;  procedures;  receive and file manifests; maintain records; file reports; provide samples;  and allow
           inspections according to the rules and regulations)

  10       Licenses for Transporters and  Permits for Facilities (Transporters: effective date; license required; application;
           equipment and procedures  certified to meet standards;  financial responsibility; fees; department issues within 90
           days;  denial;  revocation;  hearings; license  period; exemptions.  Facilities: effective  date;  permit  required;
           application;  plans;  financial responsibility,  fees;  public notice; department issues within  90 days; denial;
           revocation; hearings; permit period; exemptions; grandfather clause; character requirements)

  11       Public Hearings (Appeals or variances, oaths and transcripts;  notice and subpoenas; rules; promulgation, quorum
           of commission, findings; final actions, quorum  of commission; public hearings on promulgation, public notice,
           written and oral statements, notice of action, approval)

  12       Variances (Conditions; commission  determines;  period  limited;  petitions,  fees, investigation, notice of affected
           parties; denial, hearing, grant, hearing; bond; revocation,  hearing; judicial review)

  13       Investigations, Orders and  Revocations  (Initiation; violations; nonregulatory compliance; department orders or
           revocation actions; service; appeals to commission; stay; commission action; misrepresentation; petitioner actions;
           notice)
  14       Judicial Review

  15       Imminent Hazard (Evidence; causes; actions, orders, suits for orders or injunctions, precedence; limits of defense;
           OSHA violations excluded)

  16       Violations, Enforcement  and Penalties (Scope;  civil actions for relief or penalty; each day; attorney; location;
           misdemeanor; Missouri Highway Patrol  to detain equipment and arrest violators; other law officers to render
           assistance; knowingly  false  statements  or tampering with  devices, misdemeanor,  penalty; willful violations,
           penalties;  limits)

  17       Confidential  Information, Local Action and Limitation (Public information, confidential information, disclosure,
           limit, penalty; local government civil actions, recovery, relief; local law preempted except zoning and challenging
           on compliance)

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                                USE OF MODEL LEGISLATION IN DEVELOPING A
                                   STATE HAZARDOUS WASTE CONTROL LAW

              II. NATIONAL SOLID WASTES MANAGEMENT ASSOCIATION'S MODEL LEGISLATION

                                             Rosalie T. Grasso, Manager
                                                 Research Programs
                                    National Solid Wastes Management Association
                                                 Washington, D.C.
     The National Solid Wastes Management Association is
a  private trade association  for the  waste management
industry  and  is comprised of  the  Institute  of Waste
Technology.  One   committee   of  the  Institute  is  the
Chemical Waste Committee. That Committee has developed
a legislative guide  for establishing  a statewide  hazardous
waste management  program.  The Committee is  comprised
of  members  whose  firms  provide the majority  of  the
processing and  disposal of chemical and hazardous wastes,
and  the  members  are primarily  technical engineers  or
consultants. Why are  people who  deal in  nuts and bolts
developing  a  legislative guide?  This question is similar to
one  that I have recently  been asked on the many forms
required  for  admission  to  a  doctoral   program.  One
question, Item  28,  really  bothered  me. It  asked "Why do
you  want a doctorate?"  I  kept thinking  of one thing —
money — but, speaking to an academician, the world would
not appreciate that answer. Instead  I gave  them a 15-page
dissertation on the joys of learning. Know to whom you are
speaking  and  the  terminology they  are  accustomed  to
hearing. It is the first premise of communication.
     The  Association,   its   research  staff,    and   the
Committee conducted a survey in  1975 of existing state
hazardous  waste   control  legislation  and  found   one
dominant theme: although all states were aware of growing
hazardous waste problems, most did not have the statutory
authority to solve them. The chemical waste industry with
the  expertise  of its  membership  decided that the first
persons they needed  to talk to were legislators and hence
the Committee prepared a legislative guide. The guide  was
distributed to thousands  in Missouri to help develop the
hazardous  waste  bill there.  The   guide   has  also been
disseminated  to hundreds of legislators, county  and state
officials,  and other regulatory  personnel.  It sets forth the
issues  that  must be  considered in developing  statutory
authority for  hazardous  waste control. One  particularly
interesting   aspect  of  the  guide  is  the  background
information in the second part that answers the questions,
"What was the  reasoning for the specific language we have
used in the definitions? What was the reason for delineating
responsibilities  as we  have?" This background information
has  been helpful to regulatory  staff  in understanding the
legal language in the first part of the guide.
      The goals of the Committee are  responsive to the
social  and  environmental problems of hazardous waste
management, and  those  goals  are clearly  set forth in the
beginning of the model law. The provisions of the model
law  deal with the duties  of a state agency and reflect the
Association's  policy   that   1   state  agency  should  be
designated responsible for conducting  the  hazardous waste
 management program.
     The guide sets forth the definitions of "hazardous
waste transporter", "facility" and "disposal". The language
differs from that used in the Federal Resource Conservation
and Recovery Act of 1976 (RCRA) for 2  reasons:  (1) the
model  law preceded RCRA; and  (2) we  believe that the
definitions are  consistent with the goals  of RCRA. The
model  law also sets forth the responsibility of the state
agency to develop rules and regulations for  hazardous waste
management, including  a permit system. We believe that a
permit should  be required for the transporter, processor,
and  disposer of hazardous  waste.  The  guide  does not
address  the issue  of  registering or  permitting the waste
generator. We felt that such a provision was not appropriate
for the legislative guide at this time.
      The guide also  deals with enforcement. This is the
one major area where many states' laws are deficient. The
guide provides  for civil but  no criminal  penalties. RCRA
provides for both civil  and  criminal penalties, a provision
which would   probably require  many  states  to  change
existing  legislation  in  order to  be  consistent with the
Federal  program.  The  guide provides injunctive powers,
suspension of  permit, and other legal remedies directly to
the state agency, and does  not require the assistance of a
district   attorney   or   the   state  attorney  general  for
enforcement action.
      The  guide  addresses  inspection  procedures,  and
recommends that a designated representative of the state
agency   conduct inspections. This  would  eliminate the
situation that  has occurred in several  instances where a
well-meaning  person   in  a  state  agency  conducts the
inspection, although it is not really his job, and the results
of the procedure are inadequate.
      The   guide   also  deals  with  confidentiality  or
protection of  trade secrets, an important consideration in
hazardous  waste   management   as   compared  with
nonhazardous   industrial   waste  management.   The
responsibilities  of the generator to identify and ensure the
proper   disposal  of  wastes  are  clearly  established.  The
provisions for  the transporter, processor  and disposer are
also clearly set forth.  The administrative procedures are
referenced  in  this  guide because they  vary considerably
from state to state.
      The  guide, in  contrast to  Missouri  House Bill 318
(MHB 318), provides for a technical advisory committee. A
technical advisory committee  was recommended in 1975
because  it was  actually  a novel idea to most states to have
such  a  committee with representation  from  the  waste
generating, transporting, processing, and disposal industries
as well as from the more customary environmental groups
and   the  general   public.  In  Missouri,   there  was
representation from the full  spectrum involved in hazardous
                                                       -39-

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waste  management  at  the  first  meeting  to  develop
MHB 318.  The transactions! analysis attitude, "I'm okay,
you're okay", did not  exist at  that  first  meeting. The
environmentalists believed  that, "I'm okay;  let's see what
you're all about." MHB 318 goes to hearing today, and the
environmentalists, industry and the public support the bill.
The attitude is, "I'm  okay, you're not so bad." We believe
that we have achieved one major goal with this bill.
      We support the commission concept used to develop
MHB 318, because it  will work for Missouri, but we believe
that it will be a step in the right direction if most states
employ the technical advisory committee concept.
      Other issues affecting hazardous  waste management
that needed  to be addressed  were not  addressed  in the
legislative  guide.  This guide represents  current thinking
regarding the state of the art, but that does not mean that
at some later time we cannot go back and readdress an issue
or add new  issues.  Some of  the  current issues  under
consideration  by the Institute of Waste Technology deal
with: the severity of criminal  penalties; the definition of a
sanitary landfill; the questions  about perpetual care; the
establishment of a hazardous waste trust fund and  bonding
requirements; long-term liability; and site closure.
      The second phase of the Chemical Waste Committee's
program this year is the development of model regulations.
The  Committee believes that they have communicated with
legislators. They are now communicating with federal, state
and   local  regulatory agencies  to  develop these model
regulations.
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                                USE OF MODEL LEGISLATION IN DEVELOPING A
                                   STATE HAZARDOUS WASTE CONTROL LAW

                   III. U. S. ENVIRONMENTAL PROTECTION AGENCY'S MODEL LEGISLATION

                                                  Murray Newton
                                        Hazardous Waste Management Division
                                     Office of Solid Waste Management Programs
                                        U. S. Environmental Protection Agency
                                                 Washington, D.C.
      Rather  than describe in detail EPA's Model  State
 Hazardous Waste Management Act that we have developed,
 I would instead like to make several important points about
 it.  First,  the structure  and content of the model act,
 especially the  definitions,  are  consistent  with,  if not
 identical  to,  the  Federal   Resource  Conservation  and
 Recovery  Act of 1976 (RCRA). We have not changed any
 of the definitions because we believe that since Congress
 has explicitly told us the way they wanted terms  defined, it
 is prudent for us to pass similar information  on  to our
 constituents.
      Second, we have been working on  the model  act for
 quite some  time and have just  finished a final  draft.  We
 hope to publish it in the near  future. The  intent  of the
 model act is to show the states the kinds of authorities that
 we believe are necessary to establish an effective program.
 We have included  annotations on pages  facing the text of
 the act to: explain to the reader why we  have made certain
 choices, where we have done so; explain  to the reader that
 we see certain options where we have not  made choices;
 and explain some of the merits of each of those options.
      Third,  the model  act is not necessarily "equivalent"
 to the Federal program within the meaning of Section 3006
 of  RCRA.  The decision as to what  "equivalent" or
 "consistent"  means has not been made. That is what we
 shall be doing during the next 15 months or so. We  do not
 necessarily expect anyone to introduce without change the
 model act  as  we  have  written  it.   We appreciate the
 differences among the states  and the differences  among
 their perceptions of their needs.  Consequently, our task as
 we saw it was to  show people  the choices  available. For
 example, states should use the model act as a starting point,
 and as a list  of items to be included in state legislation  as
 was done both in Missouri House  Bill 318  and  in a bill being
 drafted in Wisconsin. Certain elements and certain phrasing
 have been taken directly  from the draft of the model act in
 both cases, by the way.
      Further, we  do  not necessarily assume that every
state  needs  a  hazardous waste management   act.  We
appreciate that a few, such as California, Illinois,  Maryland,
 Minnesota, Oklahoma, and Washington State, already have
such legislation.  To our knowledge, however, those 7 states
are the only  ones  that have state legislation  that uses the
term "hazardous waste".
      We  have no desire to insist  on,  or  to push down
anyone's  throat,  a need about which  we cannot agree.
Texas, for example, has  developed an extensive regulatory
program  for  hazardous  waste management without the
benefit of a  state law  which uses  the term "hazardous
waste". If a state believes  that it  has  existing authority
which will allow  it to write regulations  and to develop an
adequate  hazardous waste management regulatory program,
that is certainly quite acceptable to us. However, we believe
that is going to be the case in few states.
      Additionally, we  do   not  necessarily  urge  that
hazardous waste legislation be separated  from the rest of a
state's solid waste  management program. We are well aware
that RCRA is not called the "Hazardous Waste Management
Act".  RCRA encompasses all  solid waste  management
activities,  and the states may choose to  seek hazardous
waste  management legislation as part of bills which also
include other solid waste management legislation,, if such
legislation is needed; this  we encourage.
      We   appreciate  the problems with words such   as
"hazardous" in  dealing  with  the public.  We have heard
stories about the impact  that the word "hazardous" seems
to have in certain circumstances.   I  note,   for example,
that the Oklahoma bill through all of its drafts during the
course of  several months was called  a hazardous waste bill;
yet when the bill  appeared in the printed  version, it was
entitled,  "Industrial  Waste".  So we appreciate  that  an
adequate  piece of state legislation need not use the  term
"hazardous" in it. It might, as in Oklahoma, use the term
"industrial" or as in Maryland, use the term "toxic", or as
in Washington State  use  the term "extremely hazardous".
Although  we have our preferences, obviously there will  be
differences in usage.
      Lastly, the model act that we have drafted does not
include a  requirement for  transportation permits because
the Federal legislation  does not include such a provision.
(The  National Solid  Wastes Management Association's
Model  Act does include such a requirement.)  We realize
that some states may also  choose to set up such a permit
system. Let me differentiate here between the manifest and
the permit: RCRA requires that all  states have a manifest
program;  a transportation  permit program, on the other
hand, is entirely optional.
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                            METHODS PRESENTLY USED TO TREAT AND DISPOSE OF
                                      HAZARDOUS WASTES IN CALIFORNIA
                         (CALIFORNIA CHEMICAL WASTE PROCESSORS ASSOCIATION)

                                                I.  INTRODUCTION

                                                 Leonard M. Tinnan
                                             Vice President (Technical)
                                                 BKK Corporation
                                                  Wilmington, CA
      Yesterday you heard several governmental officials at
the  local,  state  and   federal  levels tell  about  many
policy-making activities and  regulatory needs or problems
related to hazardous waste management. I suppose that it is
only natural that  those  speakers should tend to focus on
what is not being  done, what needs to be done, or what is
being done  wrong or  illegally. Today,  we are going to
attempt to  reorient from the  negative to the positive and
focus on what is being done  correctly  and legally.  The
California Chemical Waste  Processors Association will offer
a series of four presentations covering the various methods
presently  used to  treat and dispose of hazardous wastes in
California.  I  and the  other  speakers  representing  the
Association are not legislators, planners, policy makers, or
researchers. We are the operators who live with and process
each day huge quantities of the hazardous wastes which this
conference addresses.
      Before proceeding with  our technical presentations,
please let me briefly  define the nature of the organization
we represent. Quoting from our Articles of Association,

      "The specific and primary purpose to which the
      organization  is organized and operated is to
      promote safe and environmentally sound waste
      management practices  on a statewide basis in
      cooperation   with   appropriate   governmental
      agencies  through  the interchange of  technical
      and  general information  pertinent  to  the
      storage, treatment,  reclamation  or disposal  of
      liquid and solid  chemical wastes."

Membership in our  Association consists  of organizations
actively  engaged  in  the  operation  of  chemical  waste
processing  facilities,  including  Class I  and   Class If—1
disposal   sites,  resource   recovery  facilities,  and  other
hazardous   waste   treatment   systems.   The   current
membership encompasses  both the  public  and  private
organizations which  operate  the facilities  that presently
handle   more   than   80 percent   of    the   so-called
environmentally dangerous wastes that are  now reclaimed
or legally disposed of in California. Associate membership
in the Association is open to and includes hazardous waste
transporters, engineering firms,  and other  organizations
engaged in related activities.
      We  believe that it is important to emphasize  that
California's  accomplishments regarding the management of
hazardous wastes  should  be  viewed in the context  of
national  progress and achievements in such matters. Just as
California has pioneered in other environmental protection
areas, so has  our State led the  way in establishing the
operating procedures and regulations for hazardous waste
management which will  serve for some time as models for
other states to  copy.  California's accomplishments  have
resulted   from  the cooperative  efforts  of  a  combined
government-industry  team.  Even with the most stringent
environmental  controls already  existing, the chemical waste
processors in this State provide  California's waste producing
industries with the lowest cost  disposal in the entire United
States. We  believe  the current  team approach — with the
State (supported  by regional or county  environmental
health  agencies)  serving  as   the  regulator,  and  private
industry, special districts,  or local governments serving as
the regulated operators — provides maximum assurance for
the  protection of public health  and safety  and for the
continued preservation of air and water quality.
      If  you were  to travel throughout  California on an
inspection  of  this State's  11  Class I  hazardous waste
treatment and  disposal facilities or of its approximately 40
Class 11—1 liquid waste disposal sites, or its  several waste
recycling  operations,  you would  observe many differences
between  the principal operating practices employed in the
northern, central and southern  regions of our State. These
differences result from the wide variation in such factors as
topography,  geology,  climate,  population  density   and
proximity, local and regional regulations (e.g., different air
quality standards  in the  north  and south).  Types  and
quantities of  waste vary  markedly  from one  region to
another.  Delivery scheduling, socio-political influences, and
economics are  also  parameters  which  dictate different
operating practices in different regions of our State.
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                            METHODS PRESENTLY USED TO TREAT AND DISPOSE OF
                                      HAZARDOUS WASTES IN CALIFORNIA
                          (CALIFORNIA CHEMICAL WASTE PROCESSORS ASSOCIATION)

                                II.  METHODS USED IN NORTHERN CALIFORNIA

                                              Victor Johnson, Jr., P.E.
                                                      President
                                              Pacific Disposal Systems
                                                    Martinez, CA
      Various  methods are used  for  the treatment  and
disposal  of  hazardous  wastes  in  Northern  California.
Incombustible,   liquid  industrial  wastes arrive at  our
Martinez,  California  site and enter a closed receiving tank
complex where they  are  treated.  After treatment the
effluent reaches 1 of  4 destinations:  (1) Oily  wastes are
transported  to a  facility  called San Pablo Oil  Company
which  recycles  approximately  5 million gal /yr  of  oil
products.  The U. S.  Forest Service purchases much of this
recycled oil  for use on their road system. (2) Waste solvents
are recycled at  a  special unit designed  for that purpose.
(3) Liquids that cannot be recycled are transported to solar
evaporation  ponds.  (4) Organic  sludges  remaining  after
treatment of the wastes are transported to biodegradation
ponds.
      Combustible wastes that arrive at  our  site enter a
closed receiving tank complex and are then incinerated. We
have a scrubber that controls air polluting emissions as the
wastes are being incinerated. These exhaust emissions from
the  incinerator are  monitored   by the Bay   Area  Air
Pollution Control District. The heat  from the incinerator is
recovered  by a heat exchanger which generates steam. We
use the steam for reclaiming oil and some solvents.
      We  treat  liquid  industrial  wastes prior to  solar
evaporation  of the liquid  fraction primarily  to detoxify,
neutralize,   or   reduce  the  quantity   of   the wastes.
Simultaneously we try to  remove any pollutant  that could
enter the  atmosphere  from  the treated  water in  our
evaporation   ponds.    Consequently,   we   must   have
considerable quality  control. Our  laboratory,  approved by
the California State Department of Health, is equipped with
two  gas   chromatographs,    an   atomic    absorption
spectrophotometer, and other  instruments that are used to
analyze  wastes so that we can ensure that pollutants are
removed before solar evaporation is permitted.
      Our   laboratory  also  monitors   the  quality  of
groundwater beneath our disposal site. In order to qualify
as a Class  I disposal site in California, we must monitor the
quality  of groundwater in wells drilled specifically for this
purpose. We have 20 such wells located around  one of our
sites that are  monitored regularly. The results of  our
laboratory  tests are  sent to the  Regional Water Quality
Control  Board to reaffirm that there has been no lateral or
vertical migration of any waste components.
      I  would like to describe some of  our  process units
that  actually   remove   pollutants. We have  become
increasingly  aware of  the  large quantities of  nitric  and
hydrofluoric acids generated by  the electronics industry.
Hydrofluoric acid etches glass,  and nitric acid is  such  a
strong  oxidizer  that  it will   ignite  some  combustible
materials  on  contact.   Handling  these  wastes  in large
volumes (in excess of 1 million gal /yr) requires processing.
Our nitric-hydrofluoric  acid neutralization unit removes
fluorides  and  nitrates  from  wastes by  precipitation  as
calcium fluoride  and calcium nitrate sludges.  The liquid
that remains after precipitation  is basically water that can
be  solar evaporated. We are required to scrub any of the
emissions  from our unit so that  we do not pollute the air.
      There  is increasing  concern  regarding  the  health
aspects of hydrofluoric  acid.  Because we are  involved  in
disposal of hydrofluoric  acid waste, we now give every one
of our employees a card outlining recommended treatment,
so  that we are assured that they will get proper  medical
treatment if they get burned with that acid. To treat such
burns, doctors inject sodium gluconate into the burned area
which binds  the  fluoride,  thereby  protecting the bones
from deterioration. This is an example of how the medical
and industrial hygiene professions have to follow hand in
hand with  the hazardous waste processing and disposal
industries.
      We formerly  had  problems with reclaiming materials
from mixtures of solvents and solids.  If we tried to burn
such  a  mixture directly  in our  incinerator, it clogged the
tips of the atomizer and prevented combustion. If we tried
to  spread  the mixture on  land,  the  reactive  organic
materials would have created air pollution. Thus, we could
neither incinerate nor spread the mixture. Therefore,  we
designed a special system. The solvent-solids mixture is put
into a cone tank and then  pumped into a reactor vessel.
Steam produced  by our incinerator is  injected  into the
vessel, and  the solvent  is driven off and  condensed as  a
liquid. The solvent can either be sold or burned directly in
our incinerator, and the  sludge that has been stripped from
the  solvent  can  be landfilled  without  creating  any  air
pollution problem.
      We  have two incinerators. One,  an 8,000  ft /min
incinerator designed in-house,  burns 4,000 gallons of light
hydrocarbon waste per day. This unit generates 20 million
Btu/hr  of steam which we use in  our treatment process.
The unit actually performs  3  distinct functions. First, it
works as an afterburner for air pollution control while we
are reacting  wastes together  to neutralize and  detoxify
them.  Second, different reactions occur at different rates,
so the vapors  released from our reactors have different heat
contents. Therefore, we must add combustible waste to the
incinerator to keep  the  combustion  chamber running at  a
                                                       -43-

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constant temperature. In this case the incinerator functions
as a waste disposal  device. Third, the incinerator generates
the steam  necessary to run the waste treatment plant. We
have   also   built   modern   scrubbers   that   remove
incombustible components prior to  incineration  in these
units.
      Hydrogen  peroxide  is a strong oxidizing agent. By the
injection   of  hydrogen  peroxide and chlorine  (another
strong oxidizing agent)  into various waste processing units,
many odorous compounds, such as sulfides and mercaptans
can  be oxidized. Our hydrogen peroxide  addition unit is
essential because we must oxidize these components prior
to solar evaporating the liquid.
      We have a new unit under construction that will use
both chlorine and sodium hydroxide to oxidize cyanide.
These compounds can oxidize  cyanide to produce harmless
nitrogen and carbon dioxide.
      There  is  a   science to  utilizing  solar  evaporation
without creating   air and water  pollution  in  Northern
California.  We  must  balance  the   amounts  of treated
industrial  waste-water  that we add to our  evaporation
ponds  against seasonal changes  in  evaporation  rate  and
precipitation. We receive literally 99 percent of our annual
rainfall   (about   16   inches)  during  the  period  from
November 1  to  April 1.  This  is also the period of  low
evaporation rates.  The period of high  evaporation rates
occurs during the  period from  April 1  to  November 1.
Some  of  the   problems  encountered   in  making solar
evaporation work result from salts and emulsified products
that remain in  the  waste  liquid after treatment. Water
contaminated with such materials does not evaporate at the
same rate  as distilled water  does. Consequently, we  have
had  to  correlate  the evaporation   rate of  the treated
waste-water we add to our evaporation ponds with the  rate
for  distilled  water  under  the   same environmental
conditions.  We  now have established  correction factors
which  enable us to  run  our solar  evaporation ponds in
balance.
     In  summary,  I  believe  that treatment of hazardous
wastes followed by solar evaporation works in areas such as
Northern  California  that  have  the  required  climatic
conditions.
                                                       -44

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                           METHODS PRESENTLY USED TO TREAT AND DISPOSE OF
                                      HAZARDOUS WASTES IN CALIFORNIA
                         (CALIFORNIA CHEMICAL WASTE PROCESSORS ASSOCIATION)

                               III.  METHODS USED IN THE SAN JOAQUIN VALLEY

                                             William H. Park, President
                                        Environmental Protection Corporation
                                                  Bakersfield, CA
     I   appreciate  this  opportunity  to  discuss  waste
management processes used in the southern San Joaquin
Valley  of California.  We have been  in the  waste disposal
business   in    Kern   County   since   passage  of   the
Porter-Cologne  Water  Quality Control  Act in November
1970. Some of  my compadres and  I had become concerned
about the  indiscriminate dumping of petroleum industry
waste on the valley floor and the percolation  of some of
these wastes into a priceless ground water basin. We joined
in a  venture to delineate those areas in Kern County that
would be acceptable for disposal of such wastes.
     I  am not an environmentalist.  I  am an economic
geologist and have spent most of  my life working in the
field of geology as a  conservationist. I get excited when I
look at a ground water basin.  A lot  of people are worried
about the pup fish, the blunt-nosed leopard lizard, and the
three-toed salamander, but  I get excited about things that
affect man. What really excites me is the enhancement of
this  world  so  that we human beings can  cope  with the
fragile  environment in which we live. I  frankly get upset
when I see aground water basin that has  been  so polluted
by misuse that it is no longer of benefit to mankind. But
when I  reflect on the millions of species of animal and plant
life  that have  become  extinct through geological  time
simply  because  they   could not  cope with their natural
environment  I  cannot get overly concerned about the
species today that are becoming  extinct. My  concern for
the  survival of  man  is the primary reason I  am  in the
business  I am  in and  why I  am here today. In  addition to
this,  of course, is the motive  to make a profit.
     We  with   Environmental   Protection  Corporation
(E.P.C.) have succeeded to some extent in saving or helping
to save a ground water basin  by providing safe places to
dispose of wastes in the southern San  Joaquin Valley. All of
California has  a tremendous interest in that basin because
Californians have spent literally billions of dollars from all
over the State to import water to that rich agricultural  area.
     We   have   nearly   unique   climatological    and
geographical conditions in the southern San Joaquin Valley.
We receive an average of about  6  inches  of  rainfall per
year. Temperatures  range   from  slightly below freezing
during  winter nights to above 100°F  during summer days.
During December, January,  and February the evaporation
rate  is virtually nil, whereas during July and  August the
evaporation rate  approaches  14  inches  per month. The
terrain  of  the  Valley varies  from  flat  on the west  to
mountainous on the east.
     We operate 2 Class 11—1  disposal sites in the southern
San Joaquin Valley. One is  located 6.5 miles northwest of
Taft on the west side  of the Valley; the other  is located in
the foothills of the Sierra  Nevada on the east side of the
Valley. The geology and hydrology differ at the 2 sites. Our
west-side site lies in a closed basin, bordered on the west by
the Temblor  Mountain  Range and the east by  the Buena
Vista and Elk Hills. This closed basin extends about 10 to
12 miles from Taft to McKittrick.The ground water there is
unusable for any practical  purposes, and the oil industry
has been allowed to percolate liquid wastes into the Valley
floor at  that  point for years.  At our disposal  site some
water percolates into the subsurface,  but we evaporate the
remaining water and biodegrade the oily residue.
      Our east-side site differs from our west-side site with
respect to geology and hydrology.There is no ground water
basin lying beneath our east-side site, and the soil there is
Middle   Miocene   Age  Round  Mountain   silt.  Round
Mountain silt  is a clayey, silty soil with permeability in the
range of 10~8cm3/sec This nearly impervious soil prevents
any  lateral flow from the  site to the  Kern River located
approximately one mile to the south. The engineered design
of the site restricts all runoff  from the site. Also we have to
provide approximately  1 acre-foot of storage for every 15
acres of land  used  for disposal. We must also exclude all
off-site  runoff so that it does not consume our storm water
storage space.
      We are  permitted by  the Central Valley  Regional
Water Quality Control  Board (CVRWQCB) to receive oily
waste material at our  disposal  sites. The  term "oil field
waste"   has   become  somewhat  troublesome  from  an
operational standpoint  because there  are various types of
oil  field  wastes.  We  consider any  waste  from the  oil
industry, whether it is oily or not, to be acceptable at our
sites, so we accept acids, bases, brine water, and oily wastes.
We accept any  waste from  a source  other  than the  oil
industry if it is an oily waste.
      We have received the  approval  of  waste discharge
from the CVRWQCB. The CVRWQCB reviews our plans,
engineering designs, and the geology of the site to ensure
that the site selected for waste disposal complies with the
law in every respect. The considerations most important to
the  CVRWQCB  are  the  permeability of  the soil, the
hydrology, and other natural conditions of the disposal site.
Incidentally,   I   have  devised  my   own  method  for
determining permeability of  soils which I  believe to be an
improvement  of the standard engineering percolation test.
Frankly, I do  not trust the standard percolation test  if the
permeability is as low as 10~6 to 10~~^ cm^/sec.
      The methods of waste disposal that we utilize at our
two sites are evaporation and biodegradation. The greatest
amount of research has probably  been done by Shell Oil
Company in  Houston, Texas. The Department of Interior
                                                       -45-

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has  published  a  fine  report about landspreading as  a
conserving method for disposing of  oily waste.  We try to
restrict saturation  of  the soil to  an average depth of  6
inches so that we can  mix the oily waste with the soil, but
keep  the  waste   near  the  surface.   The   secret   to
biodegradation is utilizing aerobic bacteria. If you bury  oily
waste too deep  (beyond 1 foot or  so), the bacteria cannot
decompose it.  After a field  has been saturated  with  oily
waste, we bring in our equipment as soon as possible  and
mix the  waste  with the soil. After 90 days the oil  has
turned to dust,  the water has evaporated, and we are ready
to  repeat the cycle. During the 5 years that our sites have
been operating,  we have evaporated liquids and biodegraded
oil  to the extent of   9   acre-feet  of liquid per acre. We
ordinarily rotate fields every 90 days.
     We recover a considerable amount of oil from wastes
received  at  our 2 disposal sites,  returning to the  energy
stream approximately 500 barrels of crude oil per month.
We do accept  some toxic and hazardous waste material,
acids and bases.
      I would like to conclude by saying that  I applaud the
California State Water Resources Control  Board and the
Regional  Water  Quality  Control  Boards  for   setting
definitive guidelines for proper siting of disposal sites. I also
applaud  the California  State  Department of Health for
giving us  some direction  about how to manage our waste
materials  for the  protection of public  health. I encourage
Dr. Harvey Collins in his  efforts to give us some guidelines
for our operations and hope that those guidelines will be as
definitive as those of the SWRCB.
                                                         -46-

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                           METHODS PRESENTLY USED TO TREAT AND DISPOSE OF
                                      HAZARDOUS WASTES IN CALIFORNIA
                         (CALIFORNIA CHEMICAL WASTE PROCESSORS ASSOCIATION)

                                IV. METHODS USED IN SOUTHERN CALIFORNIA

                                                 Leonard M. Tinnan
                                             Vice President (Technical)
                                                 BKK Corporation
                                                  Wilmington, CA
     There are 3 Class I  landfills and a large Class 11—1
landfill in Los Angeles County, and 2 Class I  disposal sites
in San Diego  County. I am  going to describe some of  the
waste  management  processes  used  at  the  BKK  Class I
landfill located in West Covina, Los Angeles County. The
processes  described  here  apply to  5 of the  6 sites  in
Los Angeles and San  Diego counties.
     The BKK  site  in West Covina  handles  70 million
gallons (about 310,000 tons) per year of Group 1  wastes
requiring disposal in  a  Class I  site.  BKK is  an unlimited
Class I  disposal site, which  means we can, from a water
quality  standpoint,  accept  any  form  of  nonradioactive
chemical waste. Nevertheless, we must safeguard the health
of our operating personnel,  the truck drivers who use  our
site, and the residents of the  surrounding communities. One
must remember that we operate a hazardous waste disposal
site in  the  midst of  10 million people,  approximately
5 percent of the nation's population.
     We  are  prevented from using  evaporation  ponds
similar to those used in  Northern California  because  of
regional  air  quality  restrictions.  Thus, we  must  utilize
different techniques.
     In   the  Los  Angeles   region,   we  have  a  heavy
concentration of industry producing about 1 million gallons
(about 4,000 tons)  of hazardous  wastes  each  day.  We
cannot schedule, like a dental appointment,  the arrival of
each load of  wastes as other facilities in other regions of
this State do. Trucks arrive without notice, and  we must be
able   to  accommodate  them  by  making  appropriate
technical judgments on the site.
     We carefully route the hazardous wastes received at
the BKK  disposal  site. Each load of such waste material
arrives accompanied by a California Liquid  Waste  Hauler
Record that (hopefully) includes the best possible chemical
description  of  the  waste  and  other   precautionary
information that the producer has provided. The waste load
is weighed on a truce scale and then proceeds to a sampling
station. The greatest percentage,  by volume,  of hazardous
wastes  we receive   is disposed  of  by  intermixing with
rubbish. These wastes include oily wastes, alkaline wastes,
various  hazardous  tank bottom  sediments,  and cannery
wastes.  A smaller percentage of wastes goes  to designated
disposal  wells,  and  the smallest percentage  of wastes is
disposed of by  either  spreading  in windrows  or special
burial.
     The BKK site  accepts Group 2 refuse which is used
as a "sponge" for  absorbing liquid  Group  1  wastes.  We
operate the site as a sanitary  landfill. Each day, we establish
a burial cell for waste material. A cell is about 10 feet high
and covers about  one acre.  Each day we  fill one cell, or
about 10 acre-feet  per day. We take the incoming  loads of
solid waste from rubbish trucks and compact them in place
to form a liquid-retaining basin. Vacuum trucks loaded with
hazardous wastes dump their loads into the basin of  solid
wastes which  act as a sponge that absorbs the liquid wastes.
Thus, we must accept nonhazardous  rubbish as well as
hazardous wastes. Throughout the day, as additional liquid
wastes are added, the dikes are reinforced with additional
rubbish. Dry  materials must be brought in continuously to
prevent seepage of liquid wastes through the dikes. During
the day, the  basin is left open, but at the end  of the day,
the dikes of solid wastes are folded over into the basin and
covered  completely  with  about  6  to  12   inches  of
compacted soil. The cover is solid, prevents the escape of
any odors, and provides necessary vector control. The  BKK
disposal site  is, therefore, a genuine  sanitary landfill. The
BKK site occupies almost 600 acres.
      In states other than  California liquid wastes are often
injected under pressure  into deep wells. We do not use that
type  of well  injection at  BKK. We select areas that  have
suitable soil and bedrock  foundations upon which we had
previously buried  solid wastes to a depth  of 100 to 175
feet. Into the buried waste, we drill uncased wells, 5 to 10
feet in diameter and 60 to 120 feet deep.  A 15-foot
diameter dome is placed over the top  of the completed well
to prevent the escape of air pollutants. Valves and plumbing
fittings  attached to the dome allow a vacuum truck to  hook
up  and discharge its waste load without ever exposing the
waste to the environment. The waste simply flows into the
well by gravity and migrates into the buried  solid waste
comprising the  walls  of the well.  The  liquid waste  is
absorbed by the solid waste and assists in decomposing the
solid waste. The decomposition process actually produces
methane gas which we are now recovering.  I would like to
emphasize that if you were to drill another hole 20 yards
away  from an exhausted well, the solid waste in  the new
hole would be as dry as if it had  never had liquid injected
near it.  Liquid never accumulates at the bottom of the well.
It disappears  by chemical reaction with the decomposing
rubbish to produce methane and CO2-
      We use land  spreading, in  windrows  for  disposal of
so-called "mud and water" and other nonodorous, nontoxic
wastes.  We mix those wastes with dry catalyst  fines or
powders. We  generally think of hazardous wastes as liquids
because the majority of them are, but we also receive large
loads  of hazardous solids in finely powdered form. Catalyst
                                                      -47-

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fines  arrive  in  trucks  equipped  with  bottom-dumping
hoppers. The trucks proceed down a windrow dumping or
spreading their loads. The liquid wastes are then spread over
the dry catalyst fines repeatedly so that the latter do  not
spread or blow. We do not attempt to saturate the catalyst
fines. Our spreading and windrow areas are separated from
the  normal  working  area of the  landfill.  We disk  the
windrow areas so that we can continuously reuse them.
      We do  use special  burial techniques for disposal of
certain  kinds  of wastes, but we  had  to  abandon this
technique in one instance. Each week we  receive about two
vacuum-truck  loads of  aluminum chloride  waste  from  a
chemical plant in the  Los Angeles  region.  This material
reacts with water in the rubbish  and creates hydrochloric
acid  vapor. To prevent this  problem, we selected  a  dry
place, a virgin area of our site, for burial of the  aluminum
chloride waste. However, after we had opened  a basin in
this  area, and a vacuum truck  had unloaded  aluminum
chloride waste into  it, the moisture in the free soil that we
used  to cover  the  waste  created an eerie  cloud of
hydrochloric  acid.  For that reason we now use a  designated
well   for  disposal   of  aluminum  chloride  or  other
water-reactive waste materials.
      During the planning and  designing  of  a  hazardous
waste disposal site,  the need for a wash-out facility is often
forgotten. Vacuum  trucks often carry materials which leave
sediments in their  tanks that must  be  flushed  out.  If a
trucker brought  in a load of  alkaline waste  and must
subsequently pick up a  load of acid waste, he must flush
the vacuum tank. We provide wash-out stations, with water
hoses strung around the side, where the trucker can actually
flush out the tank.  Several times daily we use our trucks to
collect the  washed-out  material  and dispose of it in the
solid wastes.
      Last year we constructed  a  sophisticated  hydraulic
barrier  designed   according  to  stringent   State Water
Resources   Control Board  and  Regional  Water Quality
Control Board specifications. We pump the collected water
from a barrier cut-off trench into  a storage tank using an
automatically-activated,  submersible  pump.  The collected
water is then  drawn into an  overhead tank and used for
landfill dust control. The water is principally from natural
sources, not from leachate, because it is of drinking water
quality, although the distance from the wash-out stations to
the barrier is less than 100 yards.
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                           METHODS PRESENTLY USED TO TREAT AND DISPOSE OF
                                     HAZARDOUS WASTES IN CALIFORNIA
                         (CALIFORNIA CHEMICAL WASTE PROCESSORS ASSOCIATION)

                                   V.  METHODS USED TO RECLAIM WASTES

                                                Kenneth O'Morrow
                                                Technical  Director
                                          Oil and Solvent Process Company
                                                    Azusa, CA
     The  Oil and  Solvent Process  Company  is perhaps
better known as OSPCO by its customers. We have been in
business for over 42 years,  22 years at our present location
in  Azusa,  California. When we arrived in Azusa 22 years
ago,  there was  little industry around us. Now  we  are
completely surrounded  by industry.  Now we  also have
problems  with air pollution control  districts (APCD) and
other governmental agencies, because we  are located next
to Santa Fe Dam where a recreation area is developing.
     OSPCO reclaims solvents  by distillation. We reclaim
most  common  solvents, including aliphatic and aromatic
hydrocarbons, ketones, esters and other solvents. You are
probably  more familiar with names  like   toluene, xylene,
mineral  spirits, and  paint  thinner. We also reclaim many
other solvents,  including  perchloroethylene,  methylene
chloride,  trichloroethylene,   and   1,1,1-trichloroethene.
Basically,  the solvents we  reclaim are  those used as wash
solvents in some types of cleaning or degreasing processes.
      We  have been  involved with the  development of the
Los Angeles  County  Solid Waste Management  Plan  for
several years. We have given testimony and tried to assist in
providing  information  which  might  be  helpful   to  the
county and the State. We also have worked with APCD's on
proposed  rules  and regulations.  More recently  we  have
become  a member of  the  California   Chemical Waste
Processors Association. We believe OSPCO has played an
important role  in waste management for more than 40
years. The growth of our business has been the result of our
working with customers, waste haulers, landfill operators,
sanitation   districts,  health  departments  and   other
governmental agencies.
      A number of waste  haulers arrive  at our plant each
day  with  tankloads  or truckloads of materials which  had
previously been disposed  of  in landfills.  In order  to
continue  to  obtain  referrals and additional business, we
accept all the  waste solvents  we  can  possibly  utilize.
However,  we cannot accept materials if their yields would
be so low as to be  a definite loss. The yield required for
reclamation to be profitable depends  on  the value of the
solvent. We can afford to process an  expensive solvent even
if we get  a low yield. Also, we continuously try to educate
our  customers to segregate their solvents. If a $2/gallon
solvent is mixed with a 50
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                        DISPOSAL OF HAZARDOUS WASTES AND INDUSTRIAL RESIDUES
                                             IN SANITARY LANDFILLS

                                               Robert E. Van Heuit, P.E.
                                                  Division Engineer
                                               Solid Waste Department
                                             County Sanitation Districts of
                                             Los Angeles County, California
      The  County  Sanitation  Districts of  Los  Angeles
County  (the  Districts)  operate part of  a large  regional
system   of  sanitary  landfills   in   Los Angeles   County,
California. Of the 9.5 million tons of solid waste disposed
of   annually   in   landfills   in   Los Angeles   County,
approximately half is disposed of in the Districts' facilities.
In addition, approximately 800,000 tons of hazardous solid
and  liquid waste and industrial residues are also disposed of
in sanitary landfills in Los Angeles County. Approximately
50 percent  of  these materials are  disposed of  in the
Districts' landfills.
      The  purpose of this paper is to discuss: the  methods
utilized  to review and evaluate  materials for  disposal, and
the  methods of safe disposal of hazardous solid and liquid
waste and industrial residues in landfills.  Included  in the
discussion will   be  those  categories of  materials  which
should be treated prior to disposal or should be considered
for disposal at facilities other than sanitary landfills.
      The facilities used for disposal of hazardous materials
and  industrial residues in Southern California  are primarily
limited to Class I landfills. Class I landfills in California are
those which  by  design, location  and geology are capable of
receiving chemical  wastes  with complete protection of
useable  ground  and surface waters. Disposal of hazardous
waste in California is regulated  by the State Department of
Health.  The current regulations were issued  in  February
1975 (1). At the present time, these regulations are in the
process of revision. The  revised  regulations are expected to
be   adopted  in  about  6  months.  Besides the   State
Department of  Health, the State Water  Resources Control
Board and the State Solid Waste Management Board have
an   interest  in   and  jurisdiction over  disposal  of  both
hazardous and nonhazardous liquids in sanitary landfills.
      To dispose of any hazardous or nonhazardous liquid
waste or any hazardous solid waste, the loads of  material
must be  accompanied to the disposal facility by a California
Liquid Waste Hauler  Record (CLWHR). The first section of
this   form describes  the  waste and,  most importantly,
describes the hazardous properties of the waste as well as its
components. Handling instructions are  also required. An
authorized agent of the waste producer  must certify under
penalty  of  perjury  that the waste  material  is  properly
identified. The hauler of the waste must fill out the second
section of the form, and the disposal  facility operator must
fill out the third section.
      In  addition to  the State's Hazardous Waste  Control
Regulations, the  Districts have adopted some supplemental
rules in order to handle these wastes properly. One of our
requirements is  that  disposal of all hazardous waste loads
must be approved  by  Districts' personnel at  least one
working  day prior to disposal.  The method of obtaining
approval for disposal of hazardous waste loads is by calling
on  the telephone and describing the waste's composition
and  characteristics,  including pH  if applicable.  At the
Districts' offices the loads are described on the form shown
in Figure 1. After a waste load has been fully evaluated, the
disposer is given a load  number  which  he places in the
margin of the CLWHR. The Districts' personnel who review
the  hazardous waste loads are staff members trained  in
engineering and chemistry. The  primary  reference books
used  to evaluate  hazardous  waste  loads are: Dangerous
Properties of  Industrial Materials (2), Condensed Chemical
Dictionary (3), and The Merck Index (4).
                       FIGURE 1
                    COUNTY SANITATION DISTRICTS
                      OF LOS ANGELES COUNTY

                   HAZARDOUS t LIQUID HASTE CALLS
  PRODUCER:
                                       DATE OF CALL:
  HAULER:
       MATERIALS TO BE DISPOSED
                                       PERSON
                                       CALLING:
 DATE FOR DISPOSAL:
 SENT TO:
       > CALABASAS
       t> PALOS VEROES
       > PUENTE HILLS
       C> SPAORA
       > MISSION CANYOrt
                           O.K. BY:
                           DATE SITE INFORMED:
SPECIAL INSTRUCTIONS:
                                                        -50-

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                                                      FIGURE 2

                                              LIQUID WASTE DISPOSAL
                                                                                           LIQUID WASTE
                                                                                              HAULER
                               CRAWLER
                               TRACTOR
            REFUSE
           HAULER
                             COMPACTED
                              REFUSE
      After a hazardous waste load has been fully evaluated
and  a  safe method for disposal has been determined, the
disposal facility is notified of the contents of the load, how
the load is to  be handled,  and the approximate time that
the load will arrive at the site. In addition, the load number
is given to the site in order to assist the site in identifying it.
With  this  basic  information,  the site  supervisor can  be
prepared to accept the  waste load for disposal at  the
appropriate time.
      In  the process  of  evaluating hazardous  wastes for
disposal, the potential for reaction with other wastes that
are delivered to the site must be considered. The potential
for reaction with organic materials is  important  because
solid waste has a high  organic content. It is most important
that  consideration be given  for  the   protection of  the
employee,   the  customer,  and   the   disposal  facility's
neighbors during the disposal operation and afterward.
     A number of methods are utilized by the Districts for
disposal  of  liquid  and  hazardous  wastes.  The  most
frequently  used method is  shown  in Figure 2.  The figure
shows  a cross-section  of  a typical  operating  area  on  a
typical day.  Solid waste  from  refuse collection trucks is
being dumped at the toe of the slope and being pushed up
the slope by a tractor.  The tractor pushes, spreads and
compacts the materials early in the day  in order to form a
dike to retain the liquids. The liquids are  generally delivered
to the disposal  facility in  vacuum trucks. As the liquids are
dumped from the top  of the slope into the pond area, solid
waste is pushed over the edge of the slope into the pond to
absorb the  liquid. Solid waste is, in effect, a sort of sponge.
The materials that are used to form the dike absorb some of
the liquid in the waste. At the  end of the day, the pond is
filled with  solid waste and compacted.  In that manner, all
of the free  liquid is absorbed. Materials that are disposed of
 in this manner are generally the most innocuous wastes that
 are  received  and are generally  sludges  characterized  by
 descriptions such as "tank bottom sediments", "mud and
 water",  "brines", and  "paint sludges". Obviously  this
 method is  not applicable for highly volatile materials or for
 materials which, for safety reasons, require more secure and
 safer handling methods.
      At sites such as the Districts' Palos Verdes  Landfill,
 restrictions must be  placed  on  disposal  of liquid  and
 semi-liquid materials. The  reason for additional restrictions
 is to avoid nuisances, primarily due to  odor.  In  order to
 accomplish this,  the  wastes  are  checked  for  odor,  pH,
 temperature, and flammability. The first 3 checks are made
 primarily to avoid odors.  It has been found generally that
 materials that have no odor initially, are cool, and are of a
 pH range  of  2  to 12, do not react with  each other to
 produce odors. The flammability check is required in order
 to prevent fires from flammable vapors given off  by some
 liquid wastes. This safety  precaution protects the disposal
 facility's operating personnel  as well  as customers. Wastes
 which might be  injurious to the checker may be checked in
 a different manner, depending on  the nature of the waste.
      A second method used for disposal  of liquid and
 hazardous  wastes  is to bring the materials to the disposal
 facility  in  containers. The containers,  usually  55-gallon
 barrels, are buried intact because these materials may give
 off flammable or  noxious vapors or may contain small
 containers  of  various kinds of chemicals. If a number of
 different types   of  chemicals are packed  in  the same
container, they must be of a similar nature,  and they must
 be  packed  in individual  containers.  In addition,  those
containers  must be packed in a packing  medium, such as
vermiculite, so that  some protection is  afforded to  the
individual containers against breakage during shipping and
handling. Different types of chemicals which might react
                                                        -51 -

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                                                     FIGURE 3

                                    TYPICAL LIQUID WASTE DISPOSAL WELL
4" Quick
Connector
Butterfly Valve
4" Steel Piping
8  Fittings
                                                                                    Earth Mound Around
                                                                                    Well Hood
                                                                                          ^***  o' ., o» ~ run" e

      to
                                              • O
                                                      30" Diameter Wei I
                                                                         O   .
                                                                                        O
                                                                                    Compacted
                                                                                    Earth Cover


                                                                                       Refuse Cell



                                                            .
                                                                                      Original Ground
                                                       - 52-


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with one another are not allowed to be packed in the same
container. When these materials are disposed of in a Class I
sanitary landfill, they are generally carefully buried  in an
excavation  in  the  existing  solid waste.  Containers of
incompatible  materials   are   not  buried  in  the  same
excavation.
      A third  method  used  for  disposal  of  liquid and
hazardous wastes  involves wells as shown in Figure  3. As
can be seen, these wells are approximately 60 feet deep and
are drilled entirely in the refuse mass. A substantial amount
of refuse must be  in place directly beneath  the  base of the
wells. These wells  are used for disposal  of liquid hazardous
waste that may give off  noxious vapors or of liquids which
should be isolated from  other materials. In  addition, these
liquids must be of relatively low suspended solids content.
Typical usage  of these wells is for highly caustic wastes and
for highly acidic wastes. Needless to say, separate wells are
used for acid  wastes and  for caustic wastes. Considerable
distance between acid and caustic wells is highly desirable
in order to prevent reactions between the chemicals.
      The disposal wells are  used by  a direct connection
between the vacuum  truck and the well. After the hookup
is made, the valve is opened and the liquid waste material is
discharged directly into  the well. The liquid is absorbed by
the material adjacent to  the well, and in many cases a mild
reaction occurs.  It has  been found that the liquid  waste
material tends to  disperse laterally from the well because
the  solid  waste  has  been  compacted in  more  or less
horizontal layers and because the liquid tends not to move
through  the  horizontal  layers  of  earth  from  previous
operating  decks. The advantage of this  method  of disposal
is that none of the fumes from the waste materials gets into
the atmosphere where it might create  an unsafe condition
or  at least   a  nuisance.  In  general,  weak  acids with
concentrations up to 40 percent are acceptable for disposal
by  this means. Strong  acids with  concentrations up to
20 percent are also accepted  with the  exception of  nitric
and  hydrofluoric  acids, which  are generally  limited to
10 percent concentrations or less.
      During the  past 2 years only  2 significant accidents
have occurred at the  Districts' landfills. Both of these were
related to loads that had been inaccurately described on the
CLWHR,  as well  as  to  the  Districts' staff. Both  of these
reactions  were rapidly and successfully controlled by the
disposal site's operating  personnel. There were no injuries
to staff personnel or to adjacent residents.
      Disposal  of  liquid wastes weighing up  to  half the
weight of  the  solid waste materials in which the liquids are
disposed,  has been accomplished  without  generation of
leachate.  This is  due  to the  low  quantities  of  rainfall
received  in  Southern   California  and  due  to  care  in
engineering  and  grading of  our sites  to  prevent  rainfall
runoff from entering the landfill mass.
      Because  of  their  reactivity  or  their  degree of
reactivity, a number of materials should not be disposed of
by burial in sanitary landfills except in small quantities. The
wastes that I refer to are: highly reactive or water-reactive
materials  such as sodium, potassium, lithium,  aluminum
chloride,  and  toluene  diisocyanate;  oxidizers such  as
chlorates,  permanganates  and  peroxides  which   react
vigorously with organic materials or  oxidizable materials;
and  certain  explosive  or extremely  flammable materials
such as picric acid,  trinitrotoluene, and  magnesium metal
grindings.  Haulers  and  disposers have  frequently  found
problems with these  materials, because they pose significant
dangers if disposed  of  in sanitary landfills. The important
point that needs to be made is that a Class I sanitary landfill
is  not necessarily the  most desirable  repository  for  all
hazardous wastes. Many of the above-mentioned  wastes can
be processed either  to  a nonhazardous or a less hazardous
form  that can be satisfactorily disposed of in  a sanitary
landfill.  Therefore,  disposers   of these  types  of wastes
should consider treatment processes  that  will result in a
material that can be safely disposed of in a landfill.
      In the  future  when the capacity in the Los Angeles
area to  receive  liquid  hazardous  wastes and  industrial
residues is diminished, some consideration for treatment of
certain  industrial  wastes  for  volume reduction may  be
necessary. The Districts' research and development staff has
already accomplished  a considerable  amount of research
work on a number of petrochemical wastes which appear to
be treatable by sedimentation and floatation. The brackish
water  remaining after treatment  may  be  of sufficient
quality that it  can be disposed of directly to  sanitary
sewers. The oily wastes that are removed by floatation can,
most likely, be treated for extraction of the oil. The sludges
can  be centrifuged  and then  disposed  of directly to the
landfill.
      In summary, it has been the Districts' experience that
the majority of hazardous wastes and  industrial residues can
be safely  disposed of at  Class I sanitary landfills provided
that: proper evaluation of the wastes takes place prior to
disposal; and the wastes, upon  delivery to'the landfills for
disposal,  have  sufficiently low reactivity  to preclude
accidents. Special techniques must be used for the disposal
of particularly toxic or flammable materials. In addition,
alternate  means of treatment and  disposal  should  be
considered for certain highly reactive materials.
                   REFERENCES CITED

1.   California State Department of Health. 1975. Hazardous waste
        management:  Law, regulations and guidelines  for the
        handling of hazardous waste.

2.   Sax, N.  I.  1975. Dangerous Properties of Industrial Materials.
        4th Edition. Van Nostrand, Reinhold, New York.

3.   Hawley, G. G. 1977. The Condensed Chemical Dictionary. 9th
        Edition. Van Nostrand, Reinhold, New York.

4.   Windholz,  M. 1976. The Merck Index. 9th  Edition. Merck  &
        Co., Ranay, New Jersey.
                                                        -53-

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                      DEVELOPMENTS IN THE LOW-TEMPERATURE, MICROWAVE-PLASMA
               PROCESS FOR DISPOSAL AND RECOVERY OF HIGHLY TOXIC HAZARDOUS WASTE

                                               Donald A. Oberacker
                                    Solid and Hazardous Waste Research Division
                                   Municipal Environmental Research Laboratory
                                      U. S. Environmental Protection Agency
                                                 Cincinnati, OH

                                                       and

                                                 Lionel J. Bailin
                                      Lockheed Palo Alto Research Laboratory
                                                  Palo Alto, CA
      This  progress   report  describes  a  research  and
development  program  in which microwave  plasmas  have
been utilized  to detoxify and dispose of various hazardous
liquids,   gases,  and  solids.  The  U. S.   Environmental
Protection  Agency's  (EPA)   Office  of   Research  and
Development contracted with the Lockheed Missiles and
Space  Company  to advance this  technology from the
ounces per hour range to the several pounds per hour range
at present, and up  to a  hundred pounds per hour by
1978—79. The process recently demonstrated its technical
and economic feasibility at 7 Ibs /hr on  such hazardous
wastes  as  methyl  bromide, malathion,  polychlorinated
biphenyls, phenylmercuric acetate, Kepone, and others.
      The state-of-the-art in the development of equipment
is  shown in  Figure 1.  Components  of the  system are
identified in the legend. Also shown in the figure are Lionel
J.  Bailin, Ph.D., (right) Principal Investigator, and Barry L.
Hertzler, Ph.D.,  both of Lockheed's Palo Alto  Research
Laboratory.
      The procedure  involves development  of a microwave
plasma discharge in a quartz reactor tube in which oxygen
is used as the plasma reactant gas. Pressures range from 50
to  150  torr,  a  "soft"  vacuum. The  material  to  be
decomposed is introduced  into the plasma zone by gravity,
and  the  resulting  electrical-chemical  interaction  begins
instantly.  The  reaction  products are similar  to  those
obtained by  complete  combustion, e.g., water vapor and
oxides of carbon,  in the case of hydrocarbon wastes. In
addition,  recovery  of  a  valuable  by-product, metallic
mercury, has been  accomplished  during processing of the
organomercurical pesticide, phenylmercuric acetate.
      EPA  is hopeful  that  this new  process will  serve
mankind in  the safe  treatment of many  highly toxic,
otherwise  untreatable, waste chemicals currently awaiting
safe disposal.
                  REFERENCE CITED

Lockheed Missiles  and  Space Company. 1976.  Development of
    microwave plasma detoxification process for hazardous wastes.
    Phase I. Final  Report, U.S. EPA Contract 68-03-2190, EPA
    600/2-77-030, April 1977.
                                                     -54

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                                         FIGURE 1

                   5KW MICROWAVE PLASMA DETOXIFICATION SYSTEM
                                         LEGEND
1.  Flexible Waveguide
     (each fed by 2.5kW supply, not shown)
2.  Triple Stub Tuner
3.  Power Meter
4.  Microwave Plasma Applicator
5. 3-Port Circulator and Water Load
6. Pesticide Dropping Funnel
7. Product Receiver
8. Dual Power Monitor
9. Dry Ice — Acetone Trap
                                           -55-

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            LARGE-SCALE RECOVERY AND RECYCLING OF SOLVENTS IN NORTHERN CALIFORNIA

                                           H. Michael Schneider, President
                                            Romic Chemical Corporation
                                                 East Palo Alto, CA
     I would like to present a brief history of the large-scale
reclamation of solvents and  oil. During  World War II  oils
and  solvents were  reclaimed by the  paint, varnish,  and
lacquer  industries  due  to  shortages of  raw  materials.
Reclaimers sprouted  like mushrooms.  After World War II
there was limited interest in  reclamation. Large companies
reclaimed their  contaminated solvents if they could save
money.  Small  companies  carried  their   contaminated
solvents  to  local dumps or emptied them in nearby fields.
There  were no  environmental  controls and  no  significant
savings for reclaimers.  Low profits prevented  reclaimers
from investing in new and better equipment. Their earnings
were primarily used just to survive. During the Korean War
new industries opened, such as electronics, tape and label
manufacturing,  exotic  adhesives, and new coatings  (e.g.,
epoxies) that required more expensive  and sophisticated
solvents.  These  new  industries  showed  an  interest in
reclaiming  these   solvents   because   they   could realize
substantial  savings.  Reclamation still  had  nothing to do
with preserving the environment.  In the 1960s and early
1970s  the space  program, defense  industries,  airplane
manufacturing  industries,  coating and  recording  tape
manufacturing industries began generating large quantities
of contaminated solvents. Reclamation became increasingly
attractive  to  these  industries. Reclaimers were  able to
generate  a profit,  so  they  invested  in new  and better
facilities, improved the quality of their work, and became
more efficient.  I would like to add that  nowadays quality
control  is important, so the reclamation process  must be
sophisticated if the  solvents are to meet tight specifications.
Today,  product reliability is probably one  of  the major
costs of  reclamation.
     We have Class I disposal sites in  California, but their
operators often do  not want to accept solvents because of
air pollution control problems, especially if the solvents are
flammable. Industrial  Tank, Incorporated, of Benicia  and
Martinez, California,  recognized this problem quite early
and now  disposes  of contaminated  solvents by  burning
them for energy. I  do  not believe  that burial in 55-gallon
drums  in  Class I disposal sites  is the  best  method  for
disposal  of contaminated solvents  because  eventually the
drums will rust, and the steel  drums, the potential energy of
the solvents, and the solvents themselves will be wasted.
     The most pressing problem regarding waste disposal in
the  San Francisco  Bay  Area today  is  what to  do  with
hydrocarbon mixtures  having a solvent  content of 40 to
60 percent. Presently  these  mixtures  must be buried in
55-gallon  steel  drums,  because they  cannot  be buried
openly.  The  cost  of such  burial  is  prohibitive. Romic
Chemical Corporation  has  a stripping  unit in operation
which can strip all but 3 to 5 percent of solvents from solid
residues. The  recovered  solvents can be  reused  or used as
boiler  fuel if no market can  be established.  Use for fuel is
less desirable than  reuse as solvent, but is at least better
than burning the solvent in an incinerator which yields no
value  whatsoever. We  are presently experimenting with a
unit which  will  remove all  but about  1 percent of the
solvents from solids like paint sludge. The best solution to
the problem of solvent recovery is probably a combination
of  solutions.  A company  interested  in reclamation of
solvents can call on Romic Chemical Corporation. We ask
for a representative sample of the contaminated solvent and
analyze the sample to  discover  what can be done with the
solvent. We then work  out the best possible solution for the
company.
     Reclamation  of  solvents   is absolutely  mandatory.
Distillation and  fractionation of solvents is practical and is
saving industry a great deal of money. Good housekeeping,
i.e., keeping solvents  separated as much as  possible, will
ensure a successful reclamation program and will help to
keep down costs for disposal of unrecoverable waste. Good
housekeeping is most  difficult  for some companies to do,
but if burying a solvent in 55-gallon drums costs  $1/gallon,
a company should improve its housekeeping. In some cases
good housekeeping may yield a  return on the contaminated
solvent,  or  if  a  company  can reuse  the solvent, as
80 percent of our customers do, the company might save
approximately  50 to  70 percent of the original purchase
price of the fresh solvent.
     Romic  Chemical  Corporation  primarily   uses
fractionation, i.e., separating  a mixture of 2 or 3 different
solvents into components which can then be reused. Most
of our customers have  been educated over the years about
what to do and  what not to do, because the earnings  they
derive from good housekeeping can be substantial. One of
our customers told me that he had saved against purchasing
of fresh solvent $0.75 million last year.
     Romic Chemical  Corporation  stores its  solvents in
tanks made of stainless steel because of the purity of the
material required, especially by the electronics industry. As
you can see reclamation of solvents is complex. One can no
longer just open a garage and  go into business. One must
abide by all the rules regarding water pollution control, air
pollution control, and  so forth. Sometimes it is difficult for
industry  to cope with the combined problems  of solvent
recovery and of government regulation.  Of  course, that is
how we make money, so we do not shy away from doing
the job.
     I  believe that Romic Chemical Corporation provides
an essential service to the environment and to the economy.
By working together with industry we can be a good team.
Anyone who plans to build  a  manufacturing plant today
should take into consideration either building  in facilities
that will reclaim wastes or otherwise should make sure that
a good reclamation facility will be available when the plant
begins operating.
                                                       -56-

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                           THE MANIFEST - GETTING HAZARDOUS WASTES FROM
                                      HERE TO THERE: CHEMICAL WASTE
                                 INDUSTRY'S VIEW OF MANIFEST PROGRAMS

                                            Rosalie T. Grasso, Manager
                                                Research Programs
                                   National Solid Wastes Management Association
                                                Washington, D. C.
     The  National Solid Wastes Management Association
(NSWMA)  represents the private solid  waste management
industry,  and  is  comprised  of the  Waste  Equipment
Manufacturers Institute (WEMI) and the Institute of Waste
Technology   (IWT).   The   IWT   consists   of  three
committees:  Resource   Recovery  Committee,  National
Sanitary   Landfill  Committee  and the  Chemical  Waste
Committee. The Chemical Waste Committee represents the
majority  of  firms  providing  treatment  and disposal  of
chemical   wastes.   This  committee   has  developed   a
"Legislative   Guide  for a  Statewide Hazardous  Waste
Management   Program"   and  is   currently   preparing
subsequent model  regulations for a state hazardous waste
regulatory program. The manifest is a critical component of
that regulatory program. Hazardous wastes will not go from
here to there without a  manifest.  That is, in essence, the
viewpoint  of the chemical waste management industry. This
presentation  is given from  the perspective of those  firms
engaged in hazardous and chemical waste management as
compared  to  those firms   that provide  residential  and
nonhazardous   commercial/industrial  waste   collection,
processing and disposal  services.  A  manifest  should
accompany hazardous  waste generated by all  the various
sources including  industry, commercial  and institutional
establishments.
      Even before the  passage  of  the Federal Resource
Conservation and  Recovery Act of  1976  (RCRA)  many
chemical waste management firms had instituted a manifest
program.  This  was  possible  because in most cases  a
contractual  arrangement between  the generator and the
waste  service  firms had been established.  However, there
were as many forms as there were firms — content, format,
and reporting  sequences varied.  Many  states including
California, Illinois,  Indiana,  Kentucky  and  Texas have
either  proposed or drafted a manifest form. The content,
wastes  encompassed,   and  reporting procedures   vary
considerably.   RCRA  requires  the  U. S. Environmental
Protection Agency to  implement a  manifest  system to
ensure that hazardous  wastes are  destined for treatment,
storage or disposal at a permitted facility. NSWMA through
the IWT Chemical Waste Committee  strongly advocates a
regulatory mechanism for tracking hazardous wastes from
"cradle to grave".  The manifest is  essential to the chemical
waste  management  firms   because   it:  (1) indicates the
source  of  the  hazardous   waste;   (2) identifies  the
composition of the waste; and (3) designates the disposition
of the waste shipment. Recognizing the need for a workable
manifest  system, the IWT  Chemical Waste Committee has
undertaken development of a model  manifest as a part of
its  overall   task  of preparing  model  regulations. The
remainder of this presentation will focus on each section of
the model manifest.
Generator Information

     First and most easily recognized  is the name and
address of the firm producing the waste. The name of the
firm preparing or packaging the  waste  for  shipment,  if
different  from that of the generator, should also be given.
The  address should be of the facility where the waste is
generated. Often the business address may differ from that
of the facility. If different, both addresses should be given.
An emergency number should  be  provided. ("Dial 911" is
not  sufficient.) A  responsible  officer of the company or
other trained  person   should be charged with preparing
information about the  waste's composition. An officer of
the company or a specifially designated employee should
sign  the  manifest verifying  complete  and  accurate
information in the presence of the transporter. Stamped
signatures that are acceptable for bills of lading and routine
shipping  documents are  not recommended for use on  a
hazardous waste manifest. A billing clerk, accounts  manager
or  shipping/loading foreman will  not have the necessary
information or authority required to sign the manifest.
      The  generator  is  responsible for describing  waste
composition,  waste characteristics, accident information,
and conformance with U. S. Department of Transportation
(DOT)   packaging  and  description  requirements,   if
applicable.  Placarding  requirements,  if  any,  should be
conveyed to the transporter.
      The generator  should indicate the destination  of
hazardous wastes.  This decision  should  not be  left to the
discretion of the transporter. RCRA provides that standards
be set for the transportation of all such hazardous wastes
only to the hazardous  waste treatment, storage, or disposal
facility which the generator  designates on the  manifest
form.  Large-volume   generators   will  most  likely  have
contractual  arrangements  with a   hazardous  waste
management facility. A  question  in  considering pending
State  legislation  is:  "What  about  the  small  volume,
infrequent generator of  hazardous waste?" Three options
depending  upon  the  ultimate  criteria  for  defining  a
hazardous waste can be considered in determining manifest
usage. (1) Depending upon the degree of hazard posed by a
specific  waste, an exemption  from manifest requirements
may be  granted based on the frequency, volume and type
of waste  generated.  (2) If a given  volume of  waste  is
excluded  from regulatory requirements,  a  manifest  is
 unnecessary.  (3) In order to monitor generation  rate and
ensure  proper disposal  of a  specific type of  waste, the
 regulatory  agency may  require  a simple report on  an
appropriate form.
                                                        57-

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      In deciding whether to grant any exemption either
 from manifest requirements or from regulatory provisions
 entirely, the regulatory agency should clearly delineate the
 waste type(s), volume and/or frequency of transportation
 to  be exempted. However, whenever a manifest is issued,
 the generator should indicate the final destination of the
 waste.  If an  exemption  is granted or a simple report is
 required, then the regulatory agency assumes responsibility
 in  permitting facilities  to receive  these wastes  and in
 providing procedures for accepting them.

 Waste Composition and Characteristics

      To date 3 checklist provisions  are employed on the
 model  manifest: <1) waste type by origin; (2) waste  type
 by  characteristic (e.g., liquid-state; corrosive-property); and
 (3) waste type by composition.
      The  IWT Chemical Waste Committee at this time is
 considering both  a  checklist by origin including,  but not
 limited to:

   •  air pollution control sludge;
   •  cooling and cutting oils;
   •  paint sludges;
   •  pharmaceutical wastes;
   •  plating wastes;
   •  rendering plant wastes;
   •  septic pumpings;
   •  waste treatment plant sludges; and
   •  waste oil;

as  well as  a  list  of waste  characteristics  using  DOT
terminology   when  appropriate,   such as  "flammable",
"poison",   and  "corrosive".   A   supplemental  section
detailing waste composition within a given percentage range
includes:
                                        ..contained gas	
                                        .1.1-1.3;	>1.3
Physical state: solid	liquid	sludge.
Specific gravity:	125°; none
pH:	<2;	2-5;	5-8;	8-11;    ^"
Odor: (description)
Reactivity: oxidizing agent.
Toxicity: (dermal)	low.
         (inhalation)
                             .; reducing agent	
                             ., medium	, high.
                        .lOW     mpHiiim      high.
            unnaiationi	low	, medium	, high	
   	% water	% organic,	% acids/akalies,	% salts

      An  inherent  danger  is that  a  list  might become
lengthy, a laundry  list  of all possible generating sources.
Emphasis should be placed upon waste composition rather
than  its  source.  The exact composition  of  each waste
shipment might be unknown and/or  a chemical analysis of
the waste  might  be economically prohibitive. Therefore,
given ranges for characteristics of the waste should suffice.
Laboratory analysis of  each  waste  load may  not  be
necessary to complete each manifest. Testing and analysis
should be required only  when the waste generating process
varies or is changed.
                                                               Hazardous Waste Transporter

                                                                    One  major  responsibility  of the  hazardous waste
                                                               transporter is  to ensure  that all  drivers, dispatch officers,
                                                               and  managers comprehend  the  scope of  the  manifest
                                                               program  including  the  completion and  retention of the
                                                               form. Personnel  should be informed about the customers to
                                                               be  served,  the  customers who  are   likely  to  generate
                                                               hazardous  waste,   and  the  destination  of  the wastes
                                                               accepted.  Drivers  should  be  instructed: to  request  a
                                                               manifest at the time they pick up a waste load, not by mail
                                                               two weeks later  necessitating storage of the load until the
                                                               paperwork catches  up; and to check for completeness of
                                                               the  manifest. The driver  should not be held responsible for
                                                               determining  the accuracy  of  waste-composition data.
                                                               However,  he  should: check  the  number and  type  of
                                                               container(s)  listed  on the  manifest versus  what  he  has
                                                               received; verify labelling  and packaging (what is described
                                                               on the manifest should  appear on the container); ensure
                                                               that a responsible person  signs the manifest; ensure that the
                                                               transport vehicle is  properly loaded or filled; acknowledge
                                                               the  designated destination;  and sign the manifest before
                                                               leaving the facility or site. If the facility or site  designated
                                                               on  the manifest  differs  from  that   given  in previous
                                                               instructions, the  driver should verify the instructions with
                                                               the home office.  If any question arises, he should remain on
                                                               the  premises and verify instructions with the home office.
                                                               The manifest should be completed legibly. The name of the
                                                               driver's firm, the firm's address and emergency telephone
                                                               number should  be  given.  The  manifest should be kept
                                                               readily accessible, separate from other shipping documents.

                                                               Hazardous Waste Facility  Operator

                                                                    The  name  of  the firm, the facility location, and the
                                                               emergency telephone number should be provided. The date
                                                               the  waste  was accepted  and the final  disposition of the
                                                               waste should be noted,  including the  percentages of the
                                                               waste subjected to the following processes:
                                                                   incineration.
                                                                   treatment	
                                                                   recovery	
                                                                   land disposal	
                                                                   other (specify).
                                                                  The manifest should  be completed  by  responsible,
                                                             designated  personnel at  the facility.  Facility personnel
                                                             should  be instructed to review manifests  for completion
                                                             before final receipt of incoming wastes.

                                                             Reporting Frequency

                                                                  All individuals  —  generator,  transporter,  facility
                                                             operator — should follow reporting requirements set forth
                                                             by the  regulatory  agency and  should adhere to record
                                                             retention  regulations.  All  individuals,   especially  the
                                                             generator, should report directly to the regulatory agency
                                                             to  ensure compliance  with  the  law  and  provision  of
                                                        58-

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 adequate data for equitable enforcement. The reporting
 frequency (by load, monthly, or quarterly) as well as the
 format (manifest or summary document) may vary for each
 individual. Often the reporting requirements are based on:

   •  The regulatory agency's manpower and capability to
      analyze information;
   •  Total waste volumes and types;
   •  Financial resources of the agency; and
   •  The cost burden to those reporting.

 Although the  logistics of  handling the  manifests and/or
 summary reports might be formidable, the reduction in cost
 to the agency for field personnel should be considered.
      Other  considerations  in   developing   a manifest
 program include the following:

   •  The  capacity for legible reproduction of multi-part
      forms should be available;

   •  Procedures   should  be   established  to   protect
      confidentiality;

   •  All  forms should  be sent  to one  agency —  state,
      county, or regional governmental  entity. If the forms
      are  sent  to  an  agency other than the  state, that
      agency   should   be   responsible  for   submitting
      quarterly/annual  reports to the state;

   •  A processor  who treats a  waste  or combines several
      wastes and then  transports, or causes  to transport,
      the waste(s) to a  land  disposal   facility  should  be
      considered a generator and should initiate a manifest;

   •  If a firm handles a spill and  repackages the spilled
      waste for transport, is he considered a generator and
      should he issue a manifest?

 Information Compilation and Transfer

      Although format and reporting procedures might vary
 in  response  to governmental  structure  and  individual
 regulatory programs, the  content of the manifest should be
standardized  and coded to facilitate  compilation  at the
state  level. The goal might  be the transfer of information
from  state to state and eventually the compilation of data
at the  Federal  level.  Specific  numerical  codes can  be
established and/or  existing  identification systems utilized.
 For example,  the following could be used:
     Generator  —   Internal   Revenue
     employer identification number;
Service   (IRS)
   •  Waste  origin  -  Standard  Industrial  Classification
      (SIC) Code;

   •  Numerical   designation  based   on   waste
      characteristic(s);

   •  Hazardous waste management facility permit number;
      and

   •  Inter- or intra-state shipment number.

 Basic information should not be abbreviated on the form so
 that complete information will be readily available  during
 an emergency or inspection.

 Shipping Document Versus Manifest

      On several occasions it has been recommended that a
 shipping document or bill of lading be used as a manifest.
 NSWMA advocates a hazardous waste  manifest that is a
 separate document, even a nationally uniform document, if
 feasible. A combined bill of lading/manifest is inappropriate
 for several  reasons:

   •  Each has a different function;

   •  A combined  form is not adaptable to different  modes
      of transportation;

   •  More information is  needed  about existing DOT
      regulations; and

   •  Personnel responsible for initiating and completing, as
      well  as receiving, each document vary  (accounting
      versus waste management function).  .

      The  DOT,  Materials  Transportation  Bureau,  has
 issued an advance notice of proposed rulemaking under the
Transportation  Safety Act  regarding whether additional
transportation controls are necessary for classes of materials
which  present  hazards   to   human  health   and  the
environment. Comment  is  solicited  on  the  classification
system to  identify mixtures, packaging, and how existing
transportation documents  can  be utilized.  Because the
classification  of  hazardous wastes  is  crucial to a manifest
system,  consistency between DOT and EPA requirements is
paramount to  the  functioning  of  the  chemical  waste
management  industry.  Efficient  transport -  getting
hazardous waste from  here to there - is the first step in
managing hazardous waste.
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                                       REUSE OF INDUSTRIAL RESIDUALS
                                       IN THE SAN FRANCISCO BAY AREA

                                     P. Chiu, Y. San Jule, M. Gorden, J. Westfield
                                        Association of Bay Area Governments
                                           and Development Sciences, Inc.
      The Association of Bay Area Governments (ABAG) is
the Council of Governments and comprehensive planning
agency  for the  9-county  San  Francisco Bay  Area.  Its
membership includes 7 counties and 86 cities. It serves an
area of about  7,000 square miles and 5 million citizens.
ABAG has received  several  State and Federal designations
including  the designation as the areawide planning agency
in  accordance  with  Section 208 of the Federal  Water
Pollution  Control Act Amendments of 1972  (208 agency).
      Currently, ABAG, assisted  by  Development Sciences
Incorporated (DSI),  a consulting firm in Massachusetts, is
proposing  an  industrial  residuals  study  for  the  San
Francisco  Bay Area.  The  objective  of  the study  is  to
identify  treatment  and  reuse  alternatives  for industrial
residuals  including hazardous wastes, which are currently
disposed of on-site or in landfills. The goal of the study is
to promote implementation of regionwide programs for the
reuse of residuals in the San Francisco Bay Area.
      In   this  proposed  study,  current   quantities   of
industrial residuals available for  alternative treatment and
recovery   processing  will   be  estimated.  The   present
management  practices   for   residuals   will  then  be
investigated. Certain types of residuals with the greatest
reuse potential will  be selected for more detailed analyses.
Future treatment, recovery, and  disposal options will then
be developed. Finally, feasible  regionwide programs for the
reuse of industrial residuals will be recommended.
      There are four major tasks in this proposed study.

Estimation of Quantities of  Residuals

      In  California,  the  State Water  Resources  Control
Board and the State  Department of Health (DOH) have
developed regulations  concerning the transportation and
disposal  of liquid wastes. In particular, certain toxic wastes
including materials of industrial origin have been defined as
Group 1 wastes requiring transfer by registered liquid waste
haulers and disposal  at  California Class I  disposal sites.
These wastes must be described by the waste producer on
the California  Liquid Waste Hauler Record (CLWHR) at
point of origin, and then certified by the hauler, and lastly,
by the disposer who must then file each completed CLWHR
with the  DOH. In addition, the disposer must pay a fee to
the DOH  for each waste load identified as hazardous. The
CLWHR enables one to identify  and describe quantities of
industrial  residuals  and  then  track them from point of
origin to final destination.
      From a general survey of the CLWHR received during
a period of time, one can determine the types of materials
going to Class  I landfills in  the San Francisco Bay Area and
their general characteristics. This was accomplished during a
previous   DSI  study (1)  which   revealed   that  during
September 1974, more than  10 million gallons  of waste
materials were received in  the 4 Bay Area  Class I disposal
sites.  It  was  concluded  that there  were quantities  of
materials in the wastes going to landfills and possibly also
to sewers in the San Francisco Bay Area which should  be
considered  for  recovery.  After  the  1974  study, the
CLWHRs were updated to  include more information about
the chemical nature of the wastes, and sections of the forms
were computerized to assist in tabulation.
      As part of the proposed study, these CLWHRs will  be
examined in order  to estimate the types and quantities  of
residuals  potentially available  for reuse.  The  estimated
quantities of residuals can partly  be verified based on the
results of a recently completed  industry-by-industry waste
survey conducted in Alameda  County, one  of the Bay Area
counties.   If  necessary,  additional  verification  can  be
accomplished  through  interviews with  selected  waste
producers or through a survey of one of the other Bay Area
counties, such as Contra Costa County, which produces the
largest quantity of hazardous wastes in the Bay Area.
      During  the   estimating   process,   environmental
problems  associated  with the  handling and disposal  of
residuals will be identified. In  a region of this size, with the
variety and quantities of waste materials going to landfills,
it is  necessary to evaluate carefully  the most significant
problems  at the outset. Accordingly, study priorities will be
selected  based  on the  concerns of the private industries,
public interest groups, and the regulatory agencies.

Identification of Present and Future Options

      After the quantities  of residuals potentially available
for reuse have been estimated, the next  step will  be to
examine  the present  and  future options  for treatment,
recovery, and disposal. In  order to draw an overall picture
for the Bay Area, it is necessary to establish communication
with  the waste producers, haulers and disposers. In the
San Francisco  Bay  Area, there  are many organizations
involving  groups  of industries  (for example,  the  local
Chamber  of Commerce, the Bay Area Council, and the Bay
Area  League of Industrial Associations) which  could  be
utilized for organizing  discussion  meetings. Most of these
groups are represented on the Environmental  Management
Task   Force  (EMTF)  of ABAG  and/or its   advisory
committees  for  the  preparation  of  the  Environmental
Management Plan  (Section 208 Plan).  ABAG will utilize
this  existing structure for  communication.  Additional
meetings and coordinating programs will be set up to ensure
adequate participation of interested groups.
      By  including the waste haulers,  disposers, and  the
industries in these ABAG meetings, we can identify options
as either  existing or  potential  alternative  solutions to
                                                        -60-

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landfilling. At this time, it is anticipated that the alternative
treatment to be  considered  first  will  be  oil and  solvent
recovery which  presently exists and  may be capable of
expansion. Next will come the existing disposal treatments
at the various Class I landfills, such as neutralization and
precipitation.  Other  alternatives  in existence  for  sludge
handling,  or energy recovery from  wastes  can also be
examined.
      Discussions with the industrial community may entail
some consideration of on-site processing as opposed to
off-site  treatment.  Depending upon  the classes of waste
materials and the  goals  to be reached,  in-plant  process
changes could prove to be important.
      By taking a broad  view  of  both on-site and off-site
processing  options, we  will find more opportunities for
minimizing the amount of waste materials going to landfill
and  maximizing the amount recovered. In all cases, prime
consideration will   be  given  to  those  processes  which
coordinate with the established priorities.

Analysis of System  Components

      To develop an overall  management system  for the
identified residuals which meets the established priorities,
one  must evaluate the individual components of the system.
These   components   include  collection  methods,
transportation  methods,  various  treatment  and recovery
processes,  and final disposal  plans.  Depending upon the
nature  and quantities   of  the  waste  materials  to  be
recovered, different combinations  of components should be
examined.
      When a particular  residual  material  in  the Bay Area
 presents a  problem or  an opportunity, a  set of paths
 capable of transferring the residual from waste generator to
final disposal can  be identified. In the case of chlorinated
 hydrocarbon solvents,  for  example,  there are 4 paths to
 follow as shown in  Figure 1.
      Similar paths can be developed  for other recoverable
 waste materials,  so that  alternative processing options can
 be correlated with other required system components. In
 this  way, an overall residuals management  system can be
 developed  which  allows  different  paths  for different
 materials,  facilitating resource recovery if appropriate, or
 landfilling if required.

 Development of  Industrial Residual Management System

      The overall  management system will  be built upon
 components developed for selected recoverable materials. A
 system of this type, actively tracking waste materials within
 a region, will be developed over a period of time. It will
 start as a  small program to  encourage a few alternative
 processing  options,  and eventually  will  grow  to  a  point
 where  it  can actively  develop  others.  In  this way the
 program can be  an ongoing mechanism to identify problem
 areas or recycling opportunities as a series  of projects.
      An  example could  be  made   for a  procedure to
 encourage recovery of solvents:
                FIGURE 1
    TREATMENT/DISPOSAL PATHS FOR
 CHLORINATED HYDROCARBON SOLVENTS
          Chlorinated Hydrocarbon
                 Solvents
           Path 2
                         Path:
                                      Path 4


Waste
Producer
Colic
a
Trar
tat
ction
nd
spor-
ion
Disposal in
Hazardous
Waste
Landfill


Waste
Producer
CoilE
a
Tran
tat
ction
id
spor-
ion
Solvent
Manufac-
turer
Trai
ta
ispor-
tion

Waste
Producer
Colle
a
Tran
tat
Treat
Rec
ction
id
spor-
ion
ment/
overy
Reuse




Waste
Producer
Treat
Reco
ment/
very
Reuse

          Treatment/
           Recovery
Identify producers of solvents by reviewing CLWHRs.

Designate  priorities to assist and encourage recovery
of solvents.

Conduct a  detailed survey of all potential  solvent
producers.

Estimate quantities of available solvents by chemical
name, location, etc.

Evaluate existing treatment alternatives for recovery
and disposal (including capacity by solvent type and
location).

Identify possible new alternatives with cooperation
from solvent manufacturers, waste producers,  haulers,
disposers, and solvent recoverers.
                                                         -61 -

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   •  Select system  components for each  processing or
     disposal option.

   •  Estimate preliminary costs of the program based on
     the selected system components.

   •  Define implementation roles of affected agencies.

   •  Implement the selected program.

     This  example  is a  simple  case  of encouraging an
existing option. Obviously, the overall system will consist
of many such cases, each defined by a residual material and
a set of components and  given priority by the established
goals.
     In summary, the objective of this study is to identify
treatment and reuse alternatives for industrial residuals in
the  San Francisco Bay Area.  The main product of this
study will  be a program for  implementing  reclamation of
certain  residual materials.  An overall residuals management
system   will  be  built   upon  a  number  of  similar
implementation programs.
     Any  management system developed in  this manner
will  be effective only if  the individual programs  can  be
implemented.  It is important that a strong communication
network be established among ABAC, the OOH, industries,
waste haulers and disposers, and active waste processers in
the area. Each  group should understand what each has to
gain from the  implementation program and the  residuals
management system. All chances for success depend upon a
spirit of cooperation and understanding, for there is no way
that the State  can monitor every waste transaction, and
there is no way that every waste producer can economically
recycle  each gallon of residual material that he generates.
Rather, some  transactions  will  be monitored, and  some
residuals will be recovered.  The attractive alternatives will
only  be implemented in a  spirit of cooperation greatly
facilitated by the approach provided  in this study. Where
this willingness to work together does  exist much can be
accomplished.   Cost   effective  solutions  to  waste
management  problems will  occur   in  a   region: where
everyone  is informed of  governmental regulations, either
existing or proposed; where enforcement can be counted
on; and where  there are groups who can put together all of
the system components necessary to accomplish the goals.
                   REFERENCE CITED

     Development Sciences Inc. 1975. Regional opportunities for
         industrial residuals management, Prepared for Office of
         Research  and  Development,  U. S.  Environmental
         Protection Agency.
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                         CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM

                                                  I. OVERVIEW

                                               David L. Storm, Ph.D.
                                                 Research Chemist
                                        California State Department of Health
                                                   Berkeley, CA
     This  afternoon  we  will  present a series  of  talks
relating  our  experiences,  approaches,  and  problems in
turning  a hazardous  waste  control  law  into a  working
hazardous waste  management program.  Senator  John F.
Dunlap  discussed some  of the background and need for
California's Hazardous Waste  Control  Act  (HWCA), and
Dr. Harvey  F. Collins  covered some of  the major elements
of the resulting Department of Health (DOH) program.  I
will attempt during this brief overview not to be redundant.
     Our original staff of 6 joined the DOH in November
1973 to develop California's hazardous waste management
program. Of  course, much groundwork had been laid by
Don Andres and Jeffrey Hahn before the DOH received the
mandate of the HWCA to  develop the program. According
to the law,  we had 2 months, by January 1, 1974, to have  a
program  implemented,   including   regulations,  lists  of
hazardous  wastes,  a  permitting  system  for extremely
hazardous waste disposal,  and a fee  schedule. We did not
meet that deadline, but we did manage  to  adopt interim
regulations  by July 1974.
     Also  during 1974, Earl Margitan of our Los Angeles
office and  I  conducted a survey of operational  methods
used at Class  I disposal sites in order to generate a data base
needed to develop more detailed regulations. We also began
working with  the State Water  Resources Control Board to
establish a  new,  combined  manifest to  be used  by both
agencies. The new manifest was implemented in April 1975.
Throughout this  developmental period we attempted to
learn  as  much  as we  could  about  hazardous waste
management  in  California by  meeting,  cooperating, and
exchanging  information  with industry and other state and
local agencies.
     We   received  our  first  grant  from  the  U. S.
Environmental Protection Agency (EPA) during  1974 to
accelerate the  development of  our program. With  these
monies we  hired 5 more staff members to start a laboratory
support  program  for analysis  and characterization of
hazardous wastes, and to  accelerate  development of more
detailed  regulations.  However,  we  were  basically an
organization of office-oriented  people.
     We  visited disposal  sites occasionally to  gather
information,   and   we  gradually   became  aware  of
questionable waste management  practices. We had received
reports, for example,  that loads of hazardous wastes were
being dumped at unauthorized  disposal sites. We seldom
had the time  or staff to follow up on such reports, but on
one occasion while  in the field, office staff did catch one
hazardous waste  hauler  dumping illegally. It was  apparent
that we needed full-time field staff.
     Accordingly, we applied for and received a renewal of
our EPA grant during 1975 and hired 5 field inspectors to
start a surveillance and enforcement program. This program
allowed  us to visit disposal sites routinely and to follow up
on reports of illegal disposals. By May 1975, we had staffed
our  surveillance  teams.  Although  our  program is  still
modest,  1 believe  that we  really  had achieved a working
program with the development of the field teams.
     The year 1976 was particularly productive for our
program. We received a research grant from EPA to begin
the first part of a  series of studies to develop techniques for
sampling and analysis of hazardous wastes and to develop
guideline lists of  incompatible wastes. We completed a
study in cooperation  with  the University  of California,
Berkeley,  Sanitary   Engineering  Research Laboratory
(SERL) about the potential  health impacts of the disposal
of sludges containing tetraethyl lead  (TEL).  You will hear
about that study  tomorrow from Howard Hatayama of our
staff.
     After  writing   many  drafts  and  attending  many
meetings with our Technical Advisory  Committee (TAG),
industry,  and  environmentalists,  we  implemented  our
interim  regulations.  We completed proposed amendments
to  the  HWCA to ensure  compliance with the Federal
Resource Conservation and  Recovery Act oM976 (RCRA).
We also began our hazardous waste surveys statewide.
      If you were to  visit an  advanced  hazardous  waste
facility, you would see a multi-disciplined staff of scientists
and engineers. This is because  successful hazardous waste
management requires  a  systematic and  technically-based
approach similar to any chemical treatment operation. The
same approach is  required of the agency that must regulate
hazardous waste management. The diversity of these wastes
and of  hazardous waste management methods requires that
the  regulatory  agency   be  staffed  with  technically
competent engineers  and scientists.  In California, we are
attempting to take such  an approach and have staffed our
program with chemical and sanitary engineers,  geologists,
chemists, biologists,  industrial hygienists, and biochemists.
Presently our program  has  25 professionals  assigned
exclusively to hazardous waste control. Although we have
not yet achieved  a completely functional program, you will
see that we have made considerable progress.
      Another requirement for successful hazardous waste
management is organization. Because of  California's large
geographical  size,  we have  established regional offices. Of
course,  no such program can function without the exchange
of  information among the  offices; it cannot be run solely
from a  desk. There must be staff deployed  throughout the
                                                       -63-

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state visiting landfills and industrial plants, gathering data,      data  received  about waste  handling  practices throughout
providing  information,  and  enforcing regulations  when      the State.
necessary.  There must be chemists in laboratories analyzing           The  topics to be discussed this afternoon include our
samples of wastes and conducting research to back up field      hazardous  waste  control   regulations,  field  surveillance
staff. In the  offices, there  must be  industrial hygienists,      activities,  data  handling  approaches, research,  surveys,
engineers, and chemists to evaluate properties of wastes and      emergency procedures,  resource recovery studies, and the
develop  automated  methods to  process the mountains of      approach to defining hazardous wastes.
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                         CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM

                               II.  HAZARDOUS WASTE CONTROL REGULATIONS

                                            Harvey F. Collins, Ph.D., P.E.
                                      Supervising Waste Management Engineer
                                        California State Department of Health
                                                  Sacramento, CA
     The California  Department of  Health  (DOH) has
revised its interim Hazardous Waste Control Regulations.
These  regulations,  scheduled  for  public  hearing  and
adoption later  this  year,  have  been  written  with the
requirements of the  Federal  Resource Conservation and
Recovery Act of 1976 (RCRA)  in  mind. We hope  that
California's   amended  Hazardous   Waste  Control  Act
(HWCA)  coupled with our revised regulations will provide a
firm foundation on which  to  build our case for receiving
full  authorization  of  our  hazardous  waste  management
program from EPA pursuant to RCRA as soon as possible.
     Our revised regulations include 2 new provisions that
I  would like to discuss here:  (1) permitting of hazardous
waste facilities;  and  (2) registration  of hazardous waste
haulers. The permit will address the operational aspects of a
hazardous waste facility. We will  issue permits to qualifying
facilities  that receive  hazardous wastes for disposal on-site
as well as off-site. We will not issue permits to such facilities
unless  they  have received waste discharge  requirements
from the California Regional Water Quality Control Board
(RWQCB) having jurisdiction. At first we had intended that
a permit would expire after a specified number of years,
but after further study we  concluded that this could affect
the  resale  value of  the  permitted  facility.  Because we
believe that  our revised regulations and the waste discharge
requirements of the RWQCB provide sufficient controls, we
decided to require the DOH  to  review each  permit every
3 years, so that we will be  forced to investigate thoroughly
the operation of each permitted  facility at least that often.
      In addition to permitting  facilities, our regulations
will  require registration of hazardous waste  haulers. The
State Water Resources Control Board (SWRCB)  presently
registers all haulers of all liquid wastes excluding septic tank
pumpings. However, not all liquid wastes are hazardous and
not all hazardous wastes are liquids. Thus, haulers of solid
hazardous wastes, for example, are registered by no one. We
are proposing legislation to close that loophole specifically,
but  we believe that we  probably have enough  authority
under the present HWCA to close it now by regulation. We
propose to notify haulers registered with the SWRCB about
the  DOH regulations and require each of them  to  sign a
statement  certifying  that he   will  comply with  those
regulations. We would then note  on  our  copy  of the
SWRCB  list that the registered  hauler  is also capable of
transporting hazardous wastes. Haulers of solid hazardous
wastes would have  to  fulfill the same requirements to
receive certification from the DOH. We would then compile
one  list of all registered hazardous waste haulers statewide.
      Our  revised  regulations   tighten  the  controls  on
hazardous waste facilities and haulers, but they also include
provisions for an appeals process that will enable aggrieved
persons  to seek  relief.  Many  other  issues have  been
addressed in those regulations, so we believe that ours are
probably the most comprehensive regulations  in the nation
regarding hazardous waste control.  Our regulations have
evolved during  the  past several years, but now it will take
dedicated effort to make them work.
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                         CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM

                                    III. CRITERIA FOR HAZARDOUS WASTES

                                               David L. Storm, Ph.D.
                                                 Research Chemist
                                        California State Department of Health
                                                   Berkeley, CA
     One  of  the  important  tasks  in  establishing   a
regulatory  program  for  hazardous waste management is
resolving the  question,  "What is a  hazardous waste?"
Another way of expressing the question is, "What wastes, if
improperly managed and regulated, would present  a  high
potential  for harming  persons and  the  environment?"
Adoption  of a  fair and workable  set  of  definitions of
hazardous wastes is an important but complicated task. In
the process of developing the definitions or criteria for
evaluating the  potential  hazards of wastes,  several other
questions   inevitably  arise: "What are  the natures and
compositions of industrial wastes that might be hazardous?
How are they managed?  What types of potential hazards to
persons, wildlife, and the environment do they present? Are
they potentially toxic, flammable, corrosive, or explosive,
etc.?  Is there  any  way of systematically calculating or
estimating the risks? What is an acceptable or unacceptable
risk?"  We do not have all the answers to these questions
yet. Such questions are not, of course, unique to hazardous
waste  regulatory  programs. They face  most  persons  in
regulatory  agencies who  are charged with the responsibility
of protecting persons  or the environment from dangerous
chemicals or situations.
      In the case of a statewide or nationwide hazardous
waste   control  program,  however,  one  is  faced  with
thousands of different kinds of industrial sludges, slurries,
tars, emulsions, effluents, and solids that, for one reason or
another, cannot be discharged directly into the air, water,
or sewers and,  therefore, might be hazardous. They might
be handled, treated, and disposed of in  many different ways
and  in  many different places. As a  result,  the potential
hazards  multiply.   For   example,  hazardous  wastes   if
improperly managed can: pollute  air, water, or land; kill,
intoxicate  or injure persons or animals through direct or
indirect contact; and/or injure or kill persons or animals
through fires and explosions.
      Faced with this formidable combination of variables,
one  could  simply take  1  of 2  extreme approaches  in
defining hazardous  wastes: One  could  assume that any
waste materials that could not be legally discharged into the
air, water, or sewers  (and  therefore,  must be destroyed,
treated, or  deposited  on the land)  should be considered
hazardous; or  one could assume  that only  those  wastes
which present an immediate and extreme danger to persons
handling  them should  be  considered   hazardous (e.g.,
extremely toxic, flammable, or reactive materials). Neither
approach, of course,  would be entirely fair or adequate.
The first approach would define as hazardous such wastes
as  mud and  water  from  a water purification plant.
Admittedly,  any  material  can  be  hazardous in  some
manner.  For example, the suspended solids in mud and
water would be detrimental to water quality and possibly
to aquatic life,  but such wastes can be disposed of on land
using  minimal  care without creating  hazards  to the
environment.
      The   second   approach,  declaring  only   highly
dangerous wastes  to  be  hazardous, is inadequate  because
dilute solutions and mixtures whose effects on persons and
the environment may be long term or sub-lethal would be
excluded, (e.g., soils contaminated with polychlorinated
biphenyls, or dilute lead or mercury  solutions). The most
desirable approach probably lies somewhere between the 2
extremes, and  California  has  attempted to steer such a
middle course in defining hazardous wastes.
      California's  Hazardous Waste Management Program
was  created with the  passage of the  Hazardous Waste
Control Act (HWCA) in 1972. The law defined hazardous
wastes in general terms. Hazardous wastes were defined as
those  wastes which, because of  their toxic,  flammable,
corrosive,   irritating,  strong   sensitizing,  or  explosive
properties, can  cause illness or harm to persons or wildlife.
Extremely   hazardous  wastes  were  defined  as  those
hazardous wastes  which  can likely cause death, disabling
injury,  or  illness to  persons.  The law required  the
Department of Health (DOH) to adopt lists of hazardous
and extremely  hazardous  wastes. In identifying hazardous
wastes, the  DOH  was required to consider, but was not
limited to considering,  the  immediate or persistent toxic
effects of wastes on humans and wildlife,  and the resistance
of these wastes  to natural degradation or detoxification.
      California's approach to  defining hazardous wastes is
generally called the "pure substance approach", but this
description  is not entirely accurate. The  lists of hazardous
and extremely  hazardous wastes that the DOH adopted are
actually  lists  of  hazardous   and extremely  hazardous
chemicals or substances.  The  listed substances were taken
from  lists   presented in  other regulations, in chemical
reference books, and in industrial hygiene reference works
which identified the chemicals as hazardous.  The only
criteria used in  selecting the listed  substances were  the
general  definitions  given   in   California's  Hazardous
Substances  Act; that is, the  question was  asked, "Is  the
substance  generally  recognized  as  toxic,   flammable,
corrosive, or an irritant, etc.?"
      The  lists  of hazardous and  extremely  hazardous
wastes that  appear in our preserjJJHazardous Waste Control
Regulations  were  adopted  in July  1974. The   list of
hazardous wastes contains about 700 substances and the list
                                                       -66-

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of extremely hazardous wastes contains about 60. The lists
obviously are not meant  to  be all-inclusive, but rather to
provide examples of  the more common  hazardous and
extremely  hazardous  chemicals.  Any unlisted  chemicals
which  conform to  the general definitions  given  in  the
HWCA  are   also  considered  hazardous   or  extremely
hazardous.
     Our approach  to defining hazardous wastes has thus
been the following:  In the absence of other data, any waste
mixture which cannot be discharged  into  California's air,
water,   or  sewers and which  contains a  hazardous  or
extremely  hazardous  substance  will  be  considered  for
regulatory purposes  to be hazardous. The regulations place
the burden  on the waste producer  to characterize  and
identify a hazardous waste.  By using the hazardous waste
manifest he  must alert persons who handle  and dispose of
his waste that the waste  contains hazardous or extremely
hazardous components.
     We  recognize  that  our approach to defining  and
identifying  hazardous  wastes  is empirical.  A mixture or
solution of  hazardous substances may  be  more  or  less
hazardous   to persons,  wildlife,  and   the environment
because of synergistic  or  antagonistic effects or because of
dilution.  Sufficient  data are not presently  available to
calculate or even estimate the  risks associated with  various
wastes  of   various  concentrations  exposed  to  various
handling and disposal  methods. Until such risks can at least
be estimated, no across-the-board general judgment should
be made for all wastes  under all circumstances.
      Our  approach has  been the  following: If a waste
producer  believes that his waste should  not be considered
hazardous, even  though it contains a  hazardous substance,
he can  test  his  waste  mixture  directly for toxicity,
flammability, etc., and then  present the data to the DOH
along with a description of the methods used to dispose of
the waste. The DOH will then judge on a case-by-case basis
whether  the  waste  mixture  should  be  classified  as
nonhazardous, taking  into consideration  the data and other
information  provided by the  producer.
      In  our  revised  regulations,   the  hazardous  and
extremely hazardous waste lists will be expanded to about
790 and 213 entries,  respectively. Along with the revised
regulations and lists, a set of guidelines will be adopted. The
guidelines  will contain  criteria  and  definitions for the
identification of  hazardous and extremely hazardous wastes
that are not listed  in the regulations.  We have prepared
several drafts of  criteria and definitions to date that can be
summarized as follows:

   •  Toxicity limits will be set according to acute oral and
      dermal  LD^'s,  inhalation  LCso's  and  96-hour
      median tolerance limits  (TLm)  for  test animals. A
      limit based  on 8-hour  threshhold lethal values is also
      under consideration.

   •  A flammability  limit will be set based on flashpoints
      and  National   Fire Protection  Association (NFPA)
      hazard categories.
  •  Explosive or pressure generating properties of wastes
     will be evaluated according to definitions set forth in
     Title 49,  Code of Federal Regulations   (CFR)  and
     hazard categories established by the NFPA.

  •  Corrosive or irritating  properties of wastes will  be
     subject to limits set according to the  method  and
     scoring procedures  described  in  Titles 16 and  49,
     CFR.

The  same  criteria  will  be  used  to define  extremely
hazardous wastes, but of course the limits will be lower.
The  standard   testing  protocols   referenced  in  other
regulations will be the recognized procedures for evaluating
waste mixtures and components. The DOH will reserve the
option of calling a waste hazardous because of properties
not  covered  by  the criteria,  such  as persistence in the
environment, accumulation in living tissues or long-term,
chronic toxicity.
     The  criteria  will   serve  two  functions: (1)for
evaluation of waste  components, and (2) for evaluation of
waste  mixtures.  First, if  a  waste producer  has  a waste
mixture  which contains a substance  X, and  substance  X
does not appear on the  list  of hazardous wastes, he can
refer to  the criteria. He can then  consult the literature to
check  the  LD50's,  flashpoints, etc., of substance X to
determine  if any of these characteristics  falls within the
limits of the criteria. If any does, he must report and handle
the waste as hazardous.  Second, if the producer feels that
the  waste  mixture  need not  be  handled  as  a hazardous
waste, he may  test the waste  mixture to see if the mixture
itself falls  within the limits of the  criteria. He may then
submit an application to the DOH for reclassification of the
waste  as nonhazardous. The revised regulations will spell
out  more clearly what information  should be included in
the  application.  Figure 1 shows a  flow diagram  which
summarizes the foregoing evaluation process.
      California has adopted  a waste  evaluation approach
which  consists of hazardous waste or hazardous substance
lists,  and  a  system  of  checks   and  balances  using  a
sequential   evaluation  protocol.   The basic  evaluation
process  has  been  used  in California  for  2Va years, and
refinements  will be added  in  the revised  guidelines and
regulations. It  is a fair approach that has proved workable
in  real  life  through day-to-day  use. Hazardous waste
handlers and  disposers in California have expressed their
preference for lists  of hazardous  wastes, because the lists
enable them to evaluate  quickly in the field  the potential
hazards of the wastes  they manage. The lists are published
in   booklet   form   and  many  thousands  have  been
distributed throughout the State.
      Most hazardous  waste producers find the component
evaluation   approach  preferable  to a  mandatory waste
evaluation  approach.  More than  500  different hazardous
wastes  are  disposed of in California  each  day.  If waste
producers had to have each waste mixture evaluated in a
laboratory in order  to prove that  it was not hazardous, the
costs would be astronomical. From the DOH viewpoint, the
waste  evaluation approach is preferable because it gives the
public and the  environment the benefit of the  doubt.
                                                         -67-

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                                              FIGURE 1

                          FLOW DIAGRAM OF WASTE EVALUATION METHOD
1.  Component Identification
      Analysis
2.  Component Evaluation
          Is Component on Lists?
                                                                                           Yes v
                                                          No
                                       Does Component Conform
                                       to Criteria?
3.   Waste Evaluation
                                 No
                                                                                Yes
Application  to   Department  for
Reclassification
                                                              Application
                                                              Rejected
                                                    Application
                                                    Approved
                                      Nonhazardous
                                          Waste
                        Hazardous
                          Waste
                                                -68

-------
     We recognize that our approach is not the complete
solution to the problem of identifying hazardous wastes. As
we  accumulate  more  data  and  experience in hazardous
waste  control,  we  should  be  able  to estimate more
systematically the risks  associated  with  various  waste
mixtures under  various handling and disposal conditions,
and  to judge reasonably  which risks are acceptable or
unacceptable.  Eventually, concentration limits  may be set
for substances or groups  of substances  that  frequently
appear in waste mixtures. Until concentration limits can be
established, the hazardous waste identification  approaches
adopted immediately by governmental agencies will most
likely  be  the  first  step  in an evolutionary  process  of
developing  workable  and  technically  valid  evaluation
systems.
                                                         -69-

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                         CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM

                    IV.  DEVELOPMENTS IN HAZARDOUS WASTE SAMPLING AND ANALYSIS

                                             Robert D. Stephens, Ph.D.
                                                 Research Chemist
                                        California State Department of Health
                                                   Berkeley, CA
      Approaches   to  waste  sampling  and  subsequent
analysis must be based on information about the origins of
wastes and on goals of the sampling and analysis program.
Producers  of  wastes  resulting  from  single  industrial
processes may often use standard, well-established methods
of sampling and analysis. As the waste producer's industrial
processes become  more complex, the wastes become more
heterogeneous, and problems  of  sampling  and  analysis
increase  exponentially.  Governmental  regulatory agencies
most often are confronted with  the latter situation, that of
sampling  and analyzing complex, heterogeneous wastes.
The  techniques we use  in  California for sampling and
analyzing these complex wastes  are still  developing and
should not be considered final.
      Most of  our work  in  sampling hazardous  wastes is
done with the device shown in Figure 1. This figure shows
the latest version  of the Composite Liquid Waste Sampler
(Coliwasa)  used   by our field personnel.  This simple,
effective device was designed primarily for sampling bulk
and barreled liquids and sludges and yields a representative
sample of multi-phased, heterogeneous wastes. Using this
device,  we  have sampled successfully a wide variety  of
wastes.  We  are currently developing detailed data about
samples  obtained  with  the  Coliwasa regarding  phase
reproducibility  and cross-contamination.  In  addition, we
are testing the suitability of the device for  sampling  as
many types of wastes as possible.
      An important feature of the Coliwasa  is its simplicity.
The greater the complexity of the sampler, the greater the
difficulty in  cleaning it, and  the  greater the chance of a
malfunction when  "problem" wastes are encountered. Such
"problem"  wastes include  viscous  oils, highly toxic  or
odoriferous wastes, and polymeric materials.
      The Coliwasa is not suitable  for sampling a variety of
important  types  of wastes that  our  field personnel
encounter. These wastes include solids, extremely toxic  or
noxious   wastes,  wastes  in  large  holding  ponds,   or
contaminated soils. Sampling procedures and equipment for
proper  sampling  of these  wastes  are currently  being
developed. We  have found  that field  personnel  must  be
prepared  to  sample a wtde  variety of wastes in a wide
variety of situations.
      We  have learned  that  a  well-planned protocol  of
sampling,  with proper documentation, sample seals, and
duplicate or triplicate samples is important,  especially if the
sampling is associated  with a regulatory  action.  To aid
proper sampling, a surveillance form was created (Figure 2).
The important aspects of this form are the numbers used to
identify  the sample and  the information  obtained  to
identify  the  waste  producer. The processes  involved in
producing the waste and the probable components of the
waste direct the approach used in the laboratory to analyze
the waste.  Figure 3  shows the Requested  Analysis Form
that field personnel submit with each sample of waste. The
use of these 2 forms ensures that the proper information is
obtained at the  time the  sample  is  taken and that the
necessary analyses are performed.
      Analysis of  hazardous  waste is challenging  because
these wastes originate  from  virtually every  segment  of
industry. In addition, each  industry is characterized by a
variety  of  waste  producing processes, and each  industry
typically mixes  the wastes  resulting from   the  various
processes. The problem which confronts the chemist in the
laboratory  is that the black, viscous, fuming, odoriferous
sample  on his  bench could contain almost anything, and
probably does. We  estimate that  approximately  half the
samples submitted to the laboratory have few or  no clues
about their origin. Thus, the chemist must decide what the
purpose  of the analysis is and how detailed  the  analysis
should  be. We do not have the  laboratory  resources  to
complete a detailed analysis of every sample obtained in the
field.  Therefore,  this  strategic decision  is based  on the
information acquired at the time of sampling.
      The analysis procedure consists of the following basic
steps. The first  step is high-speed centrifugation to separate
phases and break emulsions. Separation of phases allows the
chemist to analyze each phase independently, and provides
information about the proportions of aqueous, organic and
solid fractions in  hazardous wastes. If the sample requires
further analysis, we  take the separated aqueous phase and
determine general information such as pH, total  acid or
base, and total dissolved solids. These data are recorded on
the Requested Analysis Form  (Figure 3). It is  usually
possible at  this point to identify  anions and heavy metals
by standard spectrochemical techniques. Analysis of anions
is  not  particularly  difficult  because  relatively  few are
hazardous, e.g., CN~, S~2, Cr04~2, F~,  N03~, and a few
others. However,  the workload becomes prohibitive if one
must  determine the concentrations of 40—50 metals. To
solve this problem, we use X-ray fluorescence spectroscopy.
                                                       -70-

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                     FIGURE 1

        COMPOSITE LIQUID WASTE SAMPLER
                   (COLIWASA)
72"
       60'
                         3/8" PVC rod
                         1-7/8" — outer dimensions
                         1-5/8" — inner dimensions
                         Class 200 PVC pipe
                        No.  9-1/2  neoprene stopper
                         3/8" S.S. nut &  washer
                      - 71 -

-------
Sample No.
Manifest No..




Producer	
        FIGURE 2



HAZARDOUS WASTE UNIT






  SURVEILLANCE FORM







Lab. No.	
.Sampling Date
              Time
Producer's Address.




Hauler	
Hauler's Address




Process Type	
Chemical Components
               Waste Type
          Concentration
      Volume
Units
Brief Physical Description
                                                                                             HWU 5/77
                                                 -72-

-------
                                                   FIGURES

                                            REQUESTED ANALYSIS


         .Physical Data (% wt.):  	Organic phase    	 Aqueous phase   	 Solid phase

         .General Chemical Data
         .A.    Flash Point (°C)	
         .B.   Volatile Organics (% wt.)                               <95°	>95°.

         .C.   Percent Weight:              Aromatics 	
                                           Saturates.	
                                           Oxygenates.
                                           Other	
         . D.   Water Soluble Organics (% wt.)

         . E.   Residue on Evap. (mg./kg.)	
         . F.    Sulfide Precipitate           pH 3	(ppm)
                                           pH 7	(ppm)
                                           pH 9	(ppm)

         .G.    Solution pH	Total acidity/alkalinity

         . H.    Organometallics	mg./l.

         . I.     Water Soluble Organics	 mg./l.
         .J.    Solid Phase:   % organic
                              > inorganic.
         .A.    Organic Functional Group Determination

         . B.    Organic Quantitative Analysis:
                             Test Requested                     Results
                             1. 	    	
                             2. 	    	
                             3. 	    	
                             4.	    	
IV.  	A.    Organic Characterization
                1.
                2.
                3.
 V.  	Metals Analysis

                Analysis Request                                 Results

                2.                                               	
                3.	    	
                4.	    	
                5.	    	
                6..	    	

                                                      -73-

-------
TABLE 1
Record Number = 189
WML026
EL
Tl
V
CR
MN
FE
CO
Nl
CU
ZN
GA
GE
AS
SE
BR
RB
SR
TA
W
HG
PB
TH
U


PPM
1,890.0
419.0
504.0
427.0
10,700.0
179.0
137.0
145.0
153.0
46.7
41.9
123.0
17.8
25.8
111.0
372.0
< 162.0
<88.2
<68.4
22,500.0
<79.2
<31.8
.0
.0
ERROR
310.0
182.0
106.0
71.0
1,000.0
125.0
18.0
14.0
15.0
22.6
10.6
68.0
8.0
6.8
11.0
37.0
0.0
0.0
0.0
2,200.0
0.0
0.0
.0
.0
Record Number = 197
WML026
EL
BR
PB
RB
SR
Y
ZR
NB
MO
RU
RH
PD
AG
CD
IN
SN
SB
TE
I
CS
BA
LA
CE


PPM
39.5
22,900.0
104.0
378.0
<70.2
94.9
<18.0
<15.6
<11.4
<10.2
<10.8
<10.2
<10.8
<12.0
4.9
<12.6
<15.6
<17.4
<27.0
1,470.0
<56.4
<75.0
.0
.0
ERROR
26.8
2,200.0
18.0
37.0
0.0
11.4
0.0
0.0
0.0
0.0
0.0
0.0
0.0
0.0
4.0
0.0
0.0
0.0
0.0
140.0
0.0
0.0
.0
.0
This  work  is  being  carried  out  in  cooperation  with
Dr. Robert Giaque of the Lawrence Berkeley  Laboratory.
The method involves simply  reducing the sample to a dry
solid  and grinding  the  solid  into  a fine powder.  The
powdered sample  is then mixed with a standard matrix,
such as sulfur,  pressed into  a pellet and analyzed. A wide
range  of emitted  X-rays  is scanned and the resulting data
are stored on magnetic  tape. The computer  prints these
data as shown in  Table 1. Note that the concentrations of
40 elements are displayed simultaneously.  Detection limits
and error limits  indicate that  this method needs much
further  refinement.  We anticipate  that  with  further
improvements  we shall  be  able  to  reduce the cost of
analyzing all 40  elements to $20-$25  per sample.  The
usefulness of this technique  is pointed out by the analysis
shown in Table  1. The sample consisted of soil taken from a
housing  development  under construction in  Southern
California.  Vile odors  were  emanating from  the site. In
addition to  various analyses  for organics which  were
conducted, the  sample  was subjected to X-ray fluorescence
spectroscopy. The concentrations of most of the elements
identified lie  within normal geochemical  ranges. Note,
however, some conspicuous exceptions, namely Pb=22,900
ppm,   Ba=1,500  ppm, and   As=123  ppm. This analysis
indicates that the area  sampled  was probably an  old waste
oil and drilling mud disposal site.
      The development of the sampling techniques and the
analytical techniques,  including  those  for  analysis  of
organic wastes,  which I have not discussed, are the subject
of a grant we received from  the Municipal Environmental
Research  Laboratory,   U. S.  Environmental   Protection
Agency, Cincinnati.  Richard A.  Carnes is Project Officer. It
is our goal to publish guideline protocols for the sampling
and analysis  of wastes.  These protocols will be issued in
preparation   for   implementing  the  Federal  Resource
Conservation and  Recovery Act of 1976.
                                  -74-

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                          CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM

                 V.  AUTOMATED DATA MANAGEMENT FOR CONTROL OF HAZARDOUS WASTES

                                               Warren  G. Manchester
                                                 Industrial Hygienist
                                        California State Department of Health
                                                    Berkeley, CA
      California's Hazardous  Waste Control  Act of 1972
 (Section 25100 et seq.. Health and Safety Code)  requires
 the   Department  of  Health   (DOH)  to  regulate  the
 management of nonradioactive wastes that might endanger
 public health,  domestic livestock, or wildlife. Among other
 provisions, the law requires that a manifest accompany each
 load  of hazardous waste transported in California from
 point of origin to destination. The DOH  uses this manifest
 in conjunction with an automated data management system
 to administer its  Hazardous Waste Management Program.

 The Manifest

      The   manifest  was  developed   by  the  DOH   in
cooperation  with the State Water Resources Control Board
 (SWRCB).  The  SWRCB  requires  haulers  to  carry  the
 California  Liquid  Waste  Hauler  Record  (CLWHR)  when
transporting  liquid  wastes.   Rather   than  add  another
government  form  to  the  cost  of  conducting business in
California, the  DOH chose to modify the CLWHR to suit its
needs as well as those of the SWRCB.  The revised CLWHR
 (Figure 1)  has  been used successfully by both state agencies
since 1975.
      The  CLWHR is a serially-numbered, multi-copy form
which consists of 3 sections which must be completed by
the waste producer,  hauler,  and  disposal  site  operator,
respectively. The waste producer must  provide the majority
of the information on the CLWHR. For example:

   •   He must  identify the type of process which produced
     the waste, e.g., metal plating, equipment cleaning, or
     oil drilling.  The  DOH plans to   relate  the types of
     processes reported to the types and volumes of wastes
     produced.  This   information   will   be  used  to
     characterize California's total industrial waste stream
     and to identify types of firms which probably should
     be reporting production of hazardous wastes.

   •  The  waste  producer  must characterize the waste by
     checking  on the CLWHR  one or more of  16 broad
     categories  of waste  which  include  the  category
     "other".  Experience  has indicated that the category
     "other" is checked often enough  to justify revision of
     the categories. This  revision could  be  done on  an
     empirical statistical basis.

  •  The waste producer must list the components in the
     waste  and  their  approximate concentrations.  This
     information enables  operators  of  hazardous  waste
     facilities to determine whether the waste will produce
      an undesirable chemical reaction if it contacts other
      wastes disposed of at the facility.

   •  The  waste producer must  describe  the  hazardous
      properties  of the  waste,   e.g.,  toxic, flammable,
      corrosive,  or explosive. In addition, he must prescribe
      any   special   handling   instructions,  e.g.,  safety
      precautions, to lessen hazards to persons who handle
      the waste.

   •  Finally,  the waste producer  must sign  and submit a
      copy  of the CLWHR to the  DOH with  the producer
      and hauler sections completed.

      The   waste  hauler  typically   provides the blank
 CLWHRs to his customers, the waste producers. After the
 producer has  completed  his section  of the  CLWHR, the
 hauler enters information about the time he picked up the
 waste load, the type of vehicle he used, and the Department
 of  Transportation  (DOT)  proper shipping  name which
 identifies the  waste.  After completing  his section of the
 CLWHR, he gives a copy to the waste producer.  When the
 hauler transports the waste, he is required to  carry a copy
 of the  CLWHR to show to an officer of the  California
 Highway Patrol  or  to  an  authorized representative of the
 DOH upon  request. He must give a copy of the CLWHR to
 the disposal site  operator when he arrives at the site.
      The disposal  site operator certifies on  the CLWHR
 that  the waste  was delivered and identifies  the type of
 handling the waste  received at the site, e.g., processed for
 reuse, treated to remove hazardous properties,  or simply
 landfilled, spread, ponded,  or  injected  into  a well. On a
 monthly basis the disposal site operator must send a legible
 copy of  the  CLWHR to  the  DOH for  each  load  of
 hazardous waste received at the site.

 The  Automated  Data Management System

      With   the  aid   of   the   DOH  automated  data
 management system, the  DOH  has summarized  the types
 and  quantities of the  hazardous  wastes reported  on  the
 CLWHRs which  were received from disposal site  operators
 during the  first  6  months of 1976. The  data must  be
 interpreted  cautiously  because  the CLWHRs  received are
 usually  carbon  copies  that are  difficult  to read. The
summaries are reported in "estimated  tons" because many
disposal site operators do not have scales to weigh  incoming
loads of  wastes accurately and  must rely on  visual
inspection to estimate the volumes  of the wastes (most
hazardous   wastes  are  liquids).   For  expedience  the
assumption has been made that the  average liquid  waste has
                                                      -7B-

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          Revised December 197*
                                                     FIGURE 1

                           CALIFORNIA  LIQUID  WASTE  HAULER  RECORD
                                          STATE WATER RESOURCES CONTROL BOARD
                                               STATE DEPARTMENT OF HEALTH
                                                                                                                                               ITTTIIII   M
CJ>
          Name  (pi

          Pick  up Address:,

          Telephone

          Order Placed By:

          Type  of Process
          which Produced Wastes:


(Number) (Street) (City)
,( ) P.O. or Contract N«.t
Date:

1 1 1 1 1 1 NXM (print or typ«
Code No.
Business Address:
Telephone Number:!.
State Llould Waste

.),

(Number)
) Pick
Hauler's Registration No.
No. of Loada or




(Street) (Cit?)
tie, tlm.:
(if
(Date)
aoDllcable):
1 1
Code No*
Oam
_j 	 Qp"
TrlDS: Unit No.:
(Example! i mstal  plating, equipment cleaning, oil drilling.
 wastawatar treatment, pickling bath, petroleum refining)
                                                                                                                                                             (•pacify)
          DESCRIPTION OF WASTE  (Must be  filled  by producer)

          Chick typt of wastes:
                             1. O Acid solution
                             2. D Alkaline lolutlon
                             3. Q Pesticides
                             *. Q F«lnt sludge
                             i, O Solvtnt
                             6. Q TttrMthyl l««d iludg*
                             7. D Ch«dtc«l toll*!
                               8. Q Tank bottca tidlMnt
                               9. D Oil
                              10. D Drilling mud
                              11. D Cont*Bln«t«d loll and aan
                              12. D C«nn«ry waata
                              13, O Lat« tfa>t<
                              14. a Hud  and watar
                              15. D Brlna
                                                                                   Vehicle:     Qvacuum truck         barrels.  Qflatbad,  Qother.
                                                                                   The described  wa.te vaa hauled by me  to  the di»po»»l
                                                                                   facility named below and waa accepted.
                                                                                   I certify  (or  declare) under penalty
                                                                                   of perjury that the foregoing I* true
                                                                                   and correct.                                             .i   \   •	T——j"~mm
                                                                                                                            Signature of authorized  agent ana title
                                                                                   DISPOSER OF WASTE (Must  be filled by disposer)

                                                                                   Neve (print or type): .^	              I   IL  I   I
                                                                                                                                                         Code No.
                                                                                   Site Address:                                                       -
                    (Specify),
                                                                                             Th. hauler aoove delivered  the  deacribed waate  to  thia dispoaal facility  and
          Couponantll
          (Exanpltn Hydrochloric acid, lUw, cauttic lode,
           phanollci,  (olvantt (Hit), Mtali (lift),
           organici (Hit),  cyanlda)
                                                 I   1   1   1   it%MUan'acc«ptabIe"m«teri«i  under the terna of  RWQCB requirements. State
                                                    Coda No.   Department of Health regulation*,  and local restriction*.

                                                                                                                  _   State fee (if any):
                          Upper
                                  Conctntratlon:
                                   Lower      J
                                                       ppa

Hasardous Properties*
  pH 	     [

Bulk Volune:

Containers: 	
                               Wa«t«:
                                    Qtoxlc   (~]tlemmeble   [TJ corrosive

                                              f~fton»
                                                             barrel!
                                                             '4? qai)
                       (Nuaber)

          phydcal Stat<:

          Special Handling Inltructlonl (If any):
      Qdruai   Qcartom

      Qaolld
                                                 (""I sludge
                                                                                   Quantity -eaeured at lite (If applicable):

                                                                                   Handling Hathod(i):

                                                                                     Q] recovery

                                                                                     Q treatment Upecify):

                                                                                     Qdlapoaal (apaclfy):
                                                                                                                        Taat  Incineration, nautraliiattaiL} pr«ctpttatton)-Cod« Ne.
                                                                                                                      pond  fjapraadlng  ni«nlifl11  LJ111^1"011 w«11   	
                                                                                                                      other Capacity):                           -
                                                                                                                                                                    Code No.
                                                                                                iMate la held for diapoaal elaawhere epecify final location:
                                                                                             Disposal  Date;
                                                                                             I certify (or declare) under penalty
                                                                                             of perjury that the foregoing  is  true
                                                                                             and correct.
                                                                                                                                      Signature of  authorized agent and  title
                                                              The aite  operator ahall submit  a  legible copy of each  completed Record to  the
                                                              State Department of Health with monthly fee reports.
          The  waate is deacribed to the beat  of «y ability and it was  delivered to
          a  licensed liquid waste hauler  (if  applicable).

          I  certify (or declare) under penalty
          of perjury that the foregoing is  true
          and  correct.                              	
                                                   Signature of  authorized agent and title
                                                                   FOR  INFORMATION RELATED  TO SPILLS OR OTHER  EMERGENCIES  INVOLVING
                                                                        HAZARDOUS WASTE OR OTHER MATERIALS CALL (800)  424-9300.

-------
TABLE 1: QUANTITIES OF HAZARDOUS WASTES DISPOSED OF IN CALIFORNIA





ACID


ALKALI

PESTI-
CIDE

PAINT
SLUDGE


SOLVENT


PBIETM*

CHEMICAL
TOILET

TANK
BOTTOM


OIL
DRILL-
ING
MUD
CONTAM-
INATED
SOIL

CANNERY
WASTE

LATEX
WASTE
MUD
AND
WATER


BRINE


OTHER


TOTAL
         MONTHLY REPORT STATEWIDE  FEE-71.365.67  MANIFEST COUNT-13,919
Recovary
Treatment
Ponding
Spreading
Landfill
Injaction Well
Othar
TOTAL
149
10.068
19.743
7,209
8.770
2,858
3,617
52.435
2,206
22,531
38,812
575
11,960
262
6.503
82.846
0
59
181
63
143
0
25
471
53
455
1,983
1,026
4,041
0
1,161
8.719
206
1,131
1.751
228
870
0
453
4,639
63
99
51
77
180
0
29
499
0
21
95
0
0
0
42
1S8
32
1,236
8,506
3.091
5,607
0
622
19,094
78S
10,166
9,096
647
4,150
30
3,200
28,072
0
19
242
6.340
67
0
18
6,684
0
58
102
212
52
0
0
423
0
30
13
0
2
0
0
44
0
51
121
0
167
0
10
349
23
1,731
3,246
1.707
3.557
144
617
11,024
0
84
189
3.251
19
0
29
3.572
1.577
22.423
22.014
9.848
14.299
249
16.903
87.314
5,093
70,182
106,145
34,272
53,882
3,543
33,229
306346
        TABLE 2: HAZARDOUS WASTE GENERATED PER COUNTY
County Unknown
Alimada
Alpina
Amador
Buna
Calaven»
Colon
Contra Coctt
Del None
El Dorado
Framo
Germ
Humboldt
Imparial
Inyo
Kam
Kings
Lake
Laaan
Lot Angelas
Madam
Marin
Meriposa
Mamiocino
Manad
Modoc
Mono
Monterey
Napa
Navada
Oranga
Placar
Plum*
Rivwiida
Sacramento
SanBanito
San BemanSno
SanDiago
SMI Francisco
San Joaquin
San Luis Ofritpo
SjnMmo
Santa Barbara
Santa Clara
Santa Cruz
Sham
Sierra
Sokiyou
SoUno
Sonoma
Stanislaus
Sutter
Tahama
Trinity
Tulara
Tuolumm
Vantura
Vote
Vuba
Out of Sttta
Tast County
4,708
4,423
0
0
84
0
0
15.826
0
0
4.348
0
0
0
0
0
1.886
0
0
8.056
0
0
0
0
0
0
0
9
0
0
423
0
0
314
47
0
992
1.720
193
30
0
3.674
34
3.459
16
0
0
0
677
1.481
0
0
0
0
0
0
16
120
0
0
0
1,703
8,017
0
0
0
0
0
24.706
0
0
211
0
0
0
0
108
0
0
0
10.443
0
39
0
0
0
0
0
0
0
0
399
0
0
77
146
15
738
1.312
160
11
28
1,658
5
7.126
0
0
0
0
26.427
19
160
0
0
0
0
0
317
0
0
0
21
43
15
0
0
0
0
0
86
0
0
0
0
0
0
0
0
0
0
0
87
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
12
30
0
48
0
0
21
5
71
0
0
0
0
39
0
0
0
0
0
0
0
15
0
0
0
0
424
1,618
0
0
0
0
0
170
0
0
0
0
0
0
0
0
0
0
0
3.708
0
0
0
0
0
0
0
18
0
0
65
0
0
54
13
4
45
160
296
414
0
622
0
1,088
0
0
0
0
10
0
0
0
0
0
0
0
0
0
0
0
10
279
2S5
0
0
0
0
0
1.340
0
0
0
0
0
0
0
0
0
0
0
626
0
0
0
0
0
0
0
0
31
0
131
0
0
8
85
13
18
265
16
48
0
321
0
1,147
0
0
0
0
39
0
11
0
0
0
0
0
8
0
0
0
0
110
6
0
0
0
0
0
103
0
0
0
0
0
0
0
0
0
0
0
183
0
0
0
0
0
0
0
0
5
0
0
0
0
0
0
0
0
0
0
0
0
0
77
0
11
0
0
0
0
0
4
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
75
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
63
0
19
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
2,650
333
0
0
118
0
0
8,290
0
0
1,249
0
0
0
0
0
124
0
0
4.794
0
8
0
35
9
0
0
0
0
0
528
0
0
18
21
0
63
129
176
12
0
169
0
57
0
0
0
0
110
177
16
0
0
0
0
0
8
0
0
0
0
2,342
1.877
0
7
0
0
0
17.047
0
0
49
0
0
0
0
0
30
0
0
4,089
0
53
0
0
0
0
0
0
11
0
168
51
0
18
4S5
0
4
649
281
52
0
70
3
288
19
0
0
0
484
0
0
11
0
0
0
0
0
0
5
0
0
5.042
0
0
0
0
0
0
98
0
0
1.357
0
0
0
0
0
67
0
0
67
32
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
21
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
133
0
0
0
0
0
0
158
0
0
18
0
0
0
0
0
0
0
0
48
0
0
0
0
0
0
0
0
0
0
0
0
0
0
39
0
0
28
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
43
0
0
0
0
0
0
0
0
0
0
0
2
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
42
0
0
0
0
0
39
0
0
0
0
0
0
0
0
0
0
0
167
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
D
0
0
0
0
101
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1,232
314
0
0
0
0
0
3,419
0
0
361
0
0
0
0
0
140
0
0
3.343
0
0
0
0
0
0
0
0
0
18
76
0
0
13
19
0
23
516
67
0
0
309
1
253
0
0
0
0
817
95
0
0
0
0
0
0
8
0
0
0
0
285
125
0
0
0
0
0
35
0
0
183
0
0
0
0
0
2.818
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
1
0
0
0
0
0
125
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
0
9.855
4.7S3
0
0
0
0
0
37.207
0
0
1862
0
11
0
0
0
1.951
0
0
13.477
0
170
0
0
0
0
0
23
19
0
559
64
0
59
253
204
224
1.116
858
9
0
1,050
4
3,757
0
0
0
0
8.226
347
0
49
0
0
0
0
196
0
0
0
11
28.806
21,779
0
7
202
0
0
108,643
0
0
10,637
0
11
0
0
108
7,016
0
0
49,090
32
270
0
35
9
0
0
50
66
18
2,349
115
0
561
1,088
249
2,136

2.006
578
28
8,103
128
17,366
46
0
0
0
35,728
2,120
190
60
0
0
0
0
568
120
5
0
42
                                -77-

-------
                                                    TABLE 3

                                    ESTIMATED TONS BASED ON MANIFEST


DISPOSAL SITE
Southern California
03 Calabasas
09 Palos Verdes
10 Simi
1 1 Operating Industries
13 BKK
Northern California
06 BeniciaPRD
07 Martinez SRD
12 Richmond

MONTH 1976
1

818
347
0
1.206
8,270

6,153
18,877
9,158
2

711
-391
0
2,428
6,850

6,517
21,478
6,720
3

1,019
672
0
1,697
7,173

9,292
21,652
3,626
4

891
461
348
2,815
7,651

10,005
23,950
4,018
5

1,110
1,021
133
1,557
7,359

11,074
23,749
2,675
6

1,000
672
100
1,642
9,993

7,686
21,276
3,599
1974 SITE
f f+r\* »\ gr nft* i™\
(CONVERTED
TO TONS)

3,000
28,000
1,700
N/A
17,000

9,500
17,000
3,800
the  density of water. The assumption enabled estimated
volumes to be mathematically coverted to tons. Thus, these
estimated volumes can be added to the weights reported by
operators of disposal sites that do have scales.
      Table 1  shows  the total  quantities  of hazardous
wastes  reportedly  disposed  of in California.  The rows
identify the methods used to handle the wastes  at the
disposal sites and the columns indicate how the wastes were
characterized by the producer. Table 2 indicates the county
of origin of the waste (in rows) and the types of waste (in
columns). The county of origin was determined from the
address given by the waste producer.
      As  expected,  the  quantities of  hazardous wastes
produced  seem  to  correlate  with   the   degree  of
industrialization of the county. However, a trend-line plot
of  monthly  quantities   of  hazardous wastes  reportedly
disposed  of  at  the  major  disposal   sites  in  California
(representing more than 80 percent of all hazardous wastes
reported) indicates that  operators of Southern California
disposal sites   reported  less  wastes  received  than  the
operators  of  Northern  California  sites (Figure 2). The
magnitude of the difference would not be expected on the
basis of the difference in industrialization of the 2 areas.
      In a  DOH  survey of operators of disposal sites
conducted in 1974, the  operators estimated the  monthly
quantities of hazardous wastes that they received (1). Their
estimates  (volumes were converted to tons based on the
density of water) are shown in  the last column  of Table 3
beside the quantities reported on the copies of the CLWHR
that the disposal  site operators had sent to the  DOH. The
operators' estimates indicate greater similarity between the
quantities  of  hazardous wastes disposed  of  in  Northern
versus Southern California than the quantities reported on
the CLWHRs. Thus, the information from the CLWHRs can
be used to evaluate trends observed in waste disposal.
      Within  limits,  the  CLWHR  has  been  a useful
enforcement tool. Suspected  illegal disposals have  been
found by matching the serial number of the CLWHR sent
to the DOH by the waste producer with the serial number
of the  CLWHR sent  to the  DOH  by the disposal site
operator. If matching serial numbers cannot be found, the
DOH  investigates the cause. Of the nearly 15,000 CLWHRs
that the DOH  received during the first  6 months of 1976,
the serial numbers of approximately 400  did  not match.
Because the DOH receives such a large number of CLWHRs,
the DOH automated  data management system  is used  to
match the serial numbers.
    The DOH  has received inquiries about its  automated
data   management system   from  other  agencies within
California and  from other states. Accordingly, the DOH is
preparing  for   distribution  a  package  containing  an
instruction  manual, sample printouts, and Fortran programs
that will enable others to use the system  with their  own
computers. The  present  system  is continuously  being
expanded as experience increases and as budgeting allows.
      The DOH is attempting to improve the quality of the
information submitted on the CLWHR. The DOH personnel
who  review and code the information from each  CLWHR
for keypunching telephone  the  waste producer, hauler,  or
disposal  site operator to clarify ambiguous information
supplied on the CLWHR.  The classification  of chemical
wastes on the  manifest is relatively new and unfamiliar to
                                                        78

-------
                                                                    FIGURE 2
CO
     o
     iz:
     LD

     rn
     oo
     rn
     o
                                                QUANTITIES OF HAZARDOUS WASTES RECEIVED AT
                                                    SELECTED DISPOSAL SITES IN CALIFORNIA
                                                                                                                               07 Martinez SRO
                                                                                                                                 O6 Benicia PRO
                                                                                                                              11 Operating Industries
                                                                                                                              03 Calabasas
                                                                                                                              09 Palos Verdes
                                                                                5
                                                                             MONTH DJ 1976
7
8

-------
most people. Many of the established terms for types of      Environmental  Protection  Agency) to minimize  costs of
l.qu.d  wastes  provide httle definitive  information, e.g.,      recycling  or disposal  and  maximize  the useful life of
 tank  bottoms",  "mud  and water",  "acid  or  alkaline      existing disposal sites.
solution".  As   more  detailed  information  about  the
hazardous wastes discarded is summarized and catalogued,
opportunities for recycling might be found. The DOH plans                        REFERENCE CITED
to  use  the   information   from  the  CLWHRs   and  a
mathematical model (the W.R.A.P. model for regional solid      Storm-  D-  U and  E. Margitan. 1975. Survey of operational
waste  management  p.anning,  developed for  the U. S.                                                    "~ '"
                                                     -80-

-------
               CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM

                     VI. FIELD SURVEILLANCE AND ENFORCEMENT

                                    Peter A. Zizileuskas
                                Waste Management Specialist
                             California State Department of Health
                                       Berkeley, CA



(Slide presentation of the California State Department of Health Surveillance and Enforcement Program.)
                                          -81 -

-------
                         CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM

                     VII. A CONTINGENCY PLAN FOR SPILLS OF HAZARDOUS MATERIALS

                                               James L. Stabler, P.E.
                                                    Consultant
                                       California State Department of Health
                                                 Sacramento, CA
      All   of   us  have  read  headlines  such  as,
"NINETY-FOUR   STRICKEN   AS   POISON   FUMES
COVER  FREEWAYS",   "POISON  FUMES",  "SPRAY
SPILLS",   "GAS  ATTACKS",   "ACIDS  MIX:  CLOUD
RISES OVER CITY".  These are  but a small indication of
perhaps hundreds  of accidents  that  occur daily  in  this
country. It has been reported that there are probably 13 to
14  thousand  spills involving  damaging  and  dangerous
materials yearly in the United States  and most of these
spills  are   caused   by  accidents,  equipment  failure,  or
intentional  acts. In  California there is another cause we
must consider:  earthquakes.
      The headlines quoted above appeared within the past
year,  and  all  of  the incidents  described  happened in
California.  The accident  involving poison  fumes  that
covered the freeway happened in Los Angeles. A semi-truck
carrying approximately   24,000  IDS.   of a  flammable,
extremely  toxic insecticide known as  Lannate  and about
10,000  pounds  of  tires  lost control on a busy freeway,
crashed through a  center  divider, and caught  fire. After
many  hours  under rather difficult  conditions,  firemen
brought  the   blaze  under  control.  As  a result  of  this
incident, 94 people were sent to the hospital: 43 firemen,
7 city policemen,  8 highway patrolmen, and 37 onlookers
or  people  who   had  assisted  in   the  cleanup   and
decontamination processes.  Later reports indicated that 4
of these victims had been in critical condition and had been
placed in intensive care units.
      The  second  accident mentioned  above involved an
insecticide  spilled  after  a traffic accident just north of
Sacramento in the  Yuba City-Marysville area. The chemical
was Telone 2, a soil fumigant. More than 24 persons were
hospitalized because of this accident,  and again firemen,
state and local police, and onlookers were involved.
      In  both   incidents  the  results  were   the
same: numerous injuries,  lingering illnesses,  damage to
property,   and  damage   to  the  environment.  Another
characteristic  common  to  both  incidents was that  the
methods used to control the situation  were at least partly
incorrect.  In  the Lannate incident, water  used to combat
the fire increased the production of toxic fumes. This water
and the water used to clean up the spill reportedly entered
a storm drain that emptied into a dry wash.
      In the Telone incident many people were overcome
by toxic gas before proper respiratory equipment was used.
Hundreds of feet of hose and pieces of equipment had to be
either  decontaminated  or  disposed   of.  Hopefully  the
material disposed of reached a  Class I  disposal site. These
incidents are all too common. The question is, "What must
be done and by whom?"
     The Waste Management Unit of the Vector and Waste
Management  Section,   California  State  Department  of
Health  (DOH) is well aware of the  problem of hazardous
materials spills  and  is trying to answer that question. The
DOH has just completed a nationwide  telephone survey to
determine how many states have adequately addressed the
problem of hazardous materials spills. Although the results
were not surprising, they were somewhat disappointing. We
found that probably only 5 states have made any significant
strides  toward developing acceptable programs. We  do not
include California among these. However, we believe that
the dedicated and concerned people of California who have
worked to bring the State's program up to its present level
should be recognized.  Therefore, I  would like to  discuss
what has been accomplished in this State so far.
     Until about 2 years ago, there were only 2 major spill
plans that had  been developed on a statewide basis in
California: the Oil  Spill Plan and the Pesticide Spill Plan.
The Oil Spill Plan was primarily concerned with oil spilled
in or near water.  The  Pesticide Spill  Plan was primarily
concerned with accidents which usually occurred  in  rural
areas.  Neither  of  these  plans  addressed other types  of
hazardous  materials spills.  Many  spill plans  have  been
developed by Federal  agencies,  by  state and  a few  local
agencies, to manage their specific concerns,  but there has
been no coordinated, unified plan within California. Some
examples  of good,  but specific plans that  have  been
developed  and  published  include:  Hazardous Materials,
Emergency Action  Guide,  1976 developed  by the U. S.
Department  of  Transportation;  Handling   Guide  for
Potentially  Hazardous  Materials,  published  by   private
industry  (M2S, Niles,  Illinois); Hazardous Materials  Spill
Procedures Manual published by the  California Department
of  Transportation;  Emergency Hand/ing  of  Radiation
Incidents  and  Emergency  Hand/ing of Radioactive and
Metallic  Fires,  2 excellent handbooks developed  by the
Colorado  Department  of  Health;  and Guidelines  to the
Handling of Hazardous Materials, a handbook developed by
Source of Safety,  Inc. The  DOH has  also put together a
handbook for use within the DOH.
     Approximately 3 years ago the  California State Office
of  Emergency  Services  (OES) recognized  that California
had  taken a  fragmented approach to the  problem  of
hazardous  material  spills. OES  contacted  all  concerned
agencies  to  determine if  there  was actually  a need  to
develop a coordinated statewide plan. They also sought to
determine who should play a role in the plan. The goal was
the identification of each  agency's responsibilities  and  its
respective capability to respond in an emergency. The State
agencies invited by  OES included the  State Fire Marshall,
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California Highway Patrol, State Water Resources Control
Board, Department of Fish and Game, and the DOH. The
DOH took the position that in almost any situation where
a hazardous material  has  been spilled on the ground, the
material  would  in  fact  become a  hazardous waste, and
thus would  become subject to the DOH  Hazardous Waste
Control  Act and  Regulations.  The  Waste  Management
Unit with the expertise of its research chemists, industrial
hygienists,  biologists,  and  engineers,  was recognized  as
having  a  vital   role  to  play  in  the  management  of
hazardous materials spills.
      As a  result  of that first meeting with  OES and
subsequent  meetings,  a prototype spill plan  emerged.  Its
rather  lengthy  title is. The County Hazardous Materials
Spills  and  Emergency  Response  Plan.  This  plan was
founded on the principle that the best system  is a statewide
system of mutual aid in which each local jurisdiction relies
first on its  own resources, then  calls  on its neighbors for
assistance. For example, mutual aid would extend from city
to city, city to  county,  county to  county, and finally, if
necessary from one of the regional offices of  OES to other
State agencies. This mutual aid system facilitates a constant
flow of information to and  from State agencies and local
government. Thus,  California's prototype spill plan  requires
local government to make the initial response followed  by
appropriate State action. The State has  been distributing
copies of the prototype spill plan to all directors of city and
county emergency  organizations. The plan is intended to
provide guidance for  development  of local plans to deal
with hazardous materials spills. Oil or radioactive materials
spills are not  addressed in  the  plan because  these are
covered  by other  plans  and  other  authorities.  The
prototype hazardous materials spill plan represents only an
interim  arrangement  because  a  more  specific  plan is
projected to be completed by the State later this year.
      Last  month  representatives  of many  of the State
agencies mentioned above met with State legislators to map
out the  future strategy for responding  to  hazardous
materials spills.  As a result  of this meeting, a  bill will
probably  be presented to the California Legislature later
this year which should  help to  eliminate  some  of the
fragmented  approaches  to  the problem  that presently
exist.  The   following  items  have  been  considered for
inclusion in the bill:  designating OES to be the lead agency
to  coordinate   training  programs  of individual  agencies;
appropriating funds   for  these  training  programs;  and
funding programs to assist in cleanup of spills, disposal of
residues, and restoration  of the environment.  At  future
meetings, the  group  plans  to consider some means for
recovering damages and perhaps for acquiring enforcement
authority.
      Major concerns  in California are hazardous materials
spills and other emergencies resulting from earthquakes and
other  natural disasters. California  has a dozen or  more
active faults, and  the possibility  of a major earthquake
could become a reality  at any time. To prepare for such a
situation, the DOH,  OES  and other State agencies  have
developed a  plan  for responding to major disasters. This
plan addresses  both  peace-time and war-time emergencies.
The plan established 5 regional control centers, strategically
located throughout the State, with the major control center
located  in Sacramento  and a backup center  located in
Fresno.  The other  3  centers  are located in  Concord,
Los Angeles and Oroville, respectively.
      The Vector and Waste Management Section recently
participated in  training  sessions conducted at each of the
5 centers. The schedule consisted  of morning  orientation
sessions  and afternoon  command  post exercises. At the
orientation  sessions,  principal  representatives assigned to
each   of  the  centers   discussed  their   section's  or
department's  responsibilities   and  capabilities  regarding
disaster  mitigation.  During the  command  post exercises
these  representatives  had  to  respond  to  a  simulated
emergency:  a major earthquake.
      The  Waste   Management   Unit  had  to  prepare
information  about  how to manage spills of  hazardous
materials.  This information   included  how  to control
spilled materials,  how  to  clean up these  materials, and
how to dispose of them. We developed maps marked with
locations of  disposal sites, lists (and location) of resources
for  controlling spills such as tarps,  lumber,  hardware,
sand, rock,  trucks,  loaders, portable electrical  generators
and hydraulic  pumps.  We  also developed interesting but
grim  scenarios  such  as  ruptured oil tanks and  pipelines,
and jack-knifed  trucks spilling  hazardous  materials  on
freeways.
      At each  of  the 5 centers, telephones,  teletype
equipment,  radios and other communications gear were
available. This communications capability is available not
only in cases of major emergencies and disasters, but is also
available for local emergencies such as spills of hazardous
materials.
      The  DOH   is  actively   involved   in  California's
hazardous materials spills plan. For example, the Waste
Management Unit has assigned 3 staff  members to be on
24-hour call  to respond in emergencies. However, we do not
encourage the  public to call those staff members directly.
OES should be contacted  first, and OES will contact our
staff for support.  In cases of  local emergencies we have
assigned  one person to the Sacramento  Area,  one  to the
 Los Angeles Area and one to the San Francisco Bay Area.
 In  cases of  major  emergencies such as earthquakes, we have
assigned 2 staff members to each of the 5 regional control
centers.  They must  go to their respective  control centers as
soon as  possible and assist in mitigating any spills or related
situations that might exist. The information outlined above
indicates that  California will soon  be one of  those  states
that has put its hazardous materials spill  plan  together, so
that hopefully there will be no more headlines proclaiming
 "NINETY-FOUR   STRICKEN   AS  POISON  FUMES
 COVER FREEWAY".
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                         CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM

                             VIII. SURVEY OF HAZARDOUS WASTE PRODUCTION

                                                George R. Sanders
                                              Public Health Chemist
                                       California State Department of Health
                                                  Berkeley, CA
     The purpose of the California  State Department of
Health (DOH) survey of hazardous waste production is to
estimate  the amounts of  hazardous waste that should,
under lawful procedure,  be accounted for at disposal sites
authorized by the California State Water Resources Control
Board (SWRCB) to receive these wastes.  The amounts of
hazardous wastes produced should approximately equal the
amounts deposited in the sites. The survey accounts for the
quantities of hazardous wastes destined for disposal in sites
open to the public,  and for  the quantities destined for
disposal on private property owned  by the industries that
produced those wastes. The DOH accounts for the amounts
of  hazardous  waste that  ultimately  reach  authorized
disposal  sites by monitoring the California Liquid Waste
Hauler Record  (CLWHR or manifest) that must accompany
each  load of hazardous waste  transported in  the State.
Copies of this document must be submitted to the DOH by
operators of disposal sites for each load of hazardous waste
received.
      A hazardous waste, by statutory definition, is a waste
which can harm or kill human beings, domestic livestock, or
wildlife. The properties of  a waste which characterize  it as
hazardous   include   one   or   more  of  the
following: carcinogenic, corrosive,  explosive,  flammable,
irritant/sensitizer, or toxic.
      The DOH conducts the statewide survey of hazardous
waste production  on a  county-by-county basis directly or
under contract. For each county survey, the DOH contacts
the appropriate county  agency, explains the purpose of the
survey, and  enlists  the  cooperation of its employees. In
every  case so  far,  the  county  agencies contacted have
enthusiastically  supported  the surveys and have provided
the services of their personnel.
      The questionnaire used  for  the  DOH  survey  was
developed by  the  Ventura  Regional  County  Sanitation
District  (VRCSD)  under a contract financed by  a U. S.
Environmental  Protection  Agency  grant awarded to the
DOH. The research and procedures used  to develop the
questionnaire and the results of the Ventura County Survey
have been described elsewhere  (Beautrow, 1977).
      Ventura County was the first county to be surveyed.
The second survey was conducted in  Alameda  County
under  contract  with   the   Alameda  County   Planning
Department.  The   Alameda  County survey   has  been
completed and the report  is  presently being  prepared.
Surveys have also been completed in San Benito, Monterey,
Santa Cruz, Humboldt, and  Del  Norte Counties. These
latter counties had  few industries,  so  they were surveyed
entirely by  DOH  personnel who used personal  interviews
rather than mailed questionnaires.
     Nine  counties located  in the San Joaquin Valley  of
California  have,  through their supervisors' association,
petitioned for and received funds from the DOH to conduct
a survey under DOH guidance. A major objective of the
survey  is to expand  the access of the  hazardous  waste
disposal  site at Coalinga to include all  9 counties. The
9-county survey  has  been arranged so that each  of the
counties will   conduct  its  own  survey with  its  own
personnel.  Fresno County,  the coordinating county, has
contracted  with the  DOH for  the  funds, and the other 8
counties have  subcontracted  individually  with  Fresno
County.  The DOH has trained the survey personnel  from
each county and has furnished the printed survey materials.
DOH staff  are presently assisting the counties with difficult
or complicated interviews. The rationale of this contractual
arrangement is  that each county, automomous with respect
to  its  own  area and  personnel, can  conduct  a  more
thorough and effective survey with DOH assistance than the
DOH could conduct  unassisted. Each of the 9 counties will
submit  a   final  report  along  with  completed  survey
questionnaires  to Fresno County.  Fresno County and the
DOH will then develop a composite report from the county
reports.  The 9 county  surveys are  presently about half
completed. The contractual arrangements that have been
made and  the survey techniques that have been used have
proven effective so far.
      The  counties surveyed to date have been primarily
rural   counties.  The  counties   having  the  greatest
concentrations of industries will be surveyed last so that the
DOH  can  become thoroughly familiar  with  the survey
techniques  beforehand.  Accordingly,   surveys  of  the
following industrialized  counties,  Los Angeles, San Diego,
San Bernardino, Riverside, and Contra Costa,  will not  be
undertaken   until  later  this  year.  Ultimately,   a
comprehensive  survey of hazardous waste production will
have been conducted in each of California's 58 counties.
      The variety of  industries encountered in the counties
surveyed has provided the DOH with valuable experience in
the  techniques of  interviewing.  Industries identified as
producers  of hazardous wastes have included: petroleum
refineries, oil well drilling companies, electronic equipment
manufacturers,  tanneries,  explosives  manufacturers,
agricultural chemical  industries,  and  plywood  adhesive
manufacturers.
      Experience in training personnel to conduct personal
interviews for the survey of hazardous waste production has
taught  the DOH several  basic lessons. Interviewers must
know  which wastes  are hazardous and  must understand
basic industrial chemical processes. To  know which wastes
are  hazardous, the  interviewer should consult  the  DOH
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Hazardous Waste  Control Regulations  (Section 60001  et
seq.. Title 22, California  Administrative Code) which sets
forth lists of hazardous and extremely hazardous wastes. To
obtain a  basic  knowledge  of  industrial  chemistry,  the
interviewer  should   peruse   a  textbook  of  industrial
chemistry and  become familiar  with  such terms as "still
bottoms",  "filtration",  "distillation",   "flocculation",
"fines",   "precipitates",  etc.  This  basic  knowledge  is
essential to the interviewer because it is the means by which
production  of   hazardous   wastes   is   discovered  and
quantified during the  survey.  Each interview  should  be
arranged  by  prior appointment to  save  time  and limit
interruptions during  the interview. With few exceptions
most  interviews  are  interesting and pleasant. Most people
like to discuss their jobs and the industrial processes with
which they work. During the interview, the questions and
discussion  should relate  directly to  wastes,  not to  the
products  of manufacture. This limitation will prevent  an
overly conscientious manager or employee from becoming
concerned about  revealing  proprietary information. The
interviewer will often be confronted with  unfamiliar  terms
used in  various plants even though the industrial processes
used are  identical. The  interviewer should ask to have these
terms explained  so that he understands the basic industrial
chemistry involved. In those rare cases where an interviewer
encounters a hostile individual, a good  sense of humor and
an affable manner will  alleviate the individual's  insecurity.
which  is usually the cause of his hostility. If any dangerous
or  illegal   operations   are  observed  or  revealed,  the
interviewer should be instructive, obtain aid if necessary to
correct the situation, and  refrain from  being critical or
officious. The interviewer should always make a determined
effort to finish the interview in a friendly manner.
     The DOH processes by computer the data gathered
during  the survey so that pertinent information regarding
hazardous wastes produced in any area of California will be
readily available. Along with the survey data gathered, each
interviewer should provide the following information:

   • A  detailed discussion of the method by which the
     interviewed   companies  were  selected   (this
     information is the  key to statistical  evaluation of the
     data obtained);

   • A  description  and  discussion of the methods used in
     interviewing; and

   • An autobiography of the interviewer.
                   REFERENCE CITED

Beautrow,  P.A.  1977.  (Development of California's Hazardous
    Waste Management Program:  County Role. Page  14.)
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                         CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM

                              IX.  RECYCLING AND RESOURCE RECOVERY: VITAL
                           ELEMENTS IN THE MANAGEMENT OF HAZARDOUS WASTE

                                                 Carl G. Schwarzer
                                           Waste Management Specialist
                                        California State Department of Health
                                                   Berkeley, CA
      Most of us are acquainted with the magical  3 R's of
waste disposal: resource, recovery and recycling. However,
the characteristics of the materials to which these terms
apply are not well defined and mean different things to
different people. I have heard knowledgeable people say
that,  "We are not so sure about recycling hazardous waste
materials, because what can be done with all the strange
new products recovered?"  Needless to say, the products
recovered would not be strange or new; they would be
materials that had already been used once and that had
simply been recovered for reuse. Few, if any, new  products
arise from recycling.
      The materials recycled from solid waste, such as glass,
metal, and paper, have become familiar to most people, and
the   markets  for  these  materials  have  become  well
established.   However,  the   materials  recycled  from
hazardous  wastes are not so familiar, and the markets for
them are  not so  welt established. The  suitability of  a
hazardous   waste   for   recycling  depends  on   many
factors:  the  complexity of the waste, the availability  of
equipment  needed  to reclaim the waste, the  technical
capability of industry'to reclaim the waste, the geographical
location where the waste is produced or reclaimed, and the
cost  of  reclamation  versus  the  value  of  the   product
reclaimed.
      A  slightly  contaminated solvent   can  often  be
reclaimed  if  the proper  equipment  for  purification  is
available, or  it can  sometimes be used without purification.
However,  more  complex  wastes  present more  difficult
problems.  If suitable  equipment and  technology are not
available,  these  wastes might  not be  reclaimed. For
example, a  mixture  of  epichlorohydrin,  methyl  ethyl
ketone,  methyl  isobutyl  ketone,  ethanol,  propylene
chlorohydrin,   and   water   that   resulted   from  the
manufacture of an epoxy  resin was routinely recycled by
the  manufacturer, a  large company.  A small company
would have considered such a mixture to be inseparable and
unsuitable for recycling.
      Geographical location of  a waste can often determine
whether  it  is   reclaimed.  Furthermore,  the  optimum
utilization of  a waste  might  require  combination  with
another  waste   produced  at  a different  location. The
feasibility  of recycling  such  wastes can  depend entirely
upon their proximity because of transportation costs.
      Recently, the California  State Department of Health
 (DOH) developed  a  recycling  program designed  to  locate
and identify the waste streams of  various companies and
industries. The information needed is obtained by personal
interviews with  industry  representatives  and by  mailed
questionnaires. The program has enabled the DOH to act as
a clearinghouse for assisting various companies in profitably
combining  their waste  streams.  Two such  examples are
discussed below.
     The  first   example  concerns  a  paper  recycling
company in Antioch that receives a certain  percentage of
paper which cannot be  pulped. The company biodegrades
the waste to make a loam which it sells for use in lawn
preparation.   During   an   interview   with  company
representatives, the DOH  discovered that the company
desired  to  make a complete fertilizer by adding nitrogen
and phosphorous to their loam.  In  Santa Cruz, 150 miles
south   of   Antioch,   a   tannery  produces  a   highly
proteinaceous  waste as  a  result  of dehairing hides.  The
tannery waste is difficult to dispose of because it contains
caustic sodium sulfides, undissolved  hair and various other
proteinaceous  materials. The tannery oxidizes the waste to
eliminate the sulfides, neutralizes  it  with sulfuric acid, and
sends the  resultant waste  to a disposal site. The tannery
waste appeared to be an ideal source of nitrogen for the
paper  company's  loam. The  DOH  suggested that the
tannery  contact   the  paper company  to work out an
agreement. The representatives of the  tannery received the
suggestion  enthusiastically and decided that they could use
phosphoric acid instead of  sulfuric acid to  neutralize the
caustic  tannery waste, thereby upgrading the value of that
waste for use in the paper company's  loam. The DOH also
knew of a large  stockpile of iron-zinc waste  in Martinez
(near Antioch) and suggested that the paper company could
use this waste to upgrade their loam  further.
      The second  example concerns a small  company that
recovers metals such as gold, silver, nickel, and copper. This
company processes an ammoniacal copper solution  that
originates from the manufacture of printed circuit boards.
The company used a  2-step process employing a  blister
copper  technique  for  the  final step.  The DOH suggested
that a sulfide-containing caustic waste from one of the local
petroleum  refineries  could be used  instead.  The  caustic
waste is difficult for the refineries to dispose of because it
tends to generate  obnoxious odors.  However, its  sulfide
content is ideal for precipitating copper sulfide from the
ammoniacal copper solution using a  1-step rather  than  a
 2-step process.
      To  promote  recycling,   the   DOH   encourages
companies to  keep waste streams separated and as simple as
possible. Chlorinated solvents should not be combined with
 oxygenated solvents, and these should be separated from
 hydrocarbons, etc. However, separation of waste streams is
 not always possible, and as a result, unrecyclable wastes are
 generated under the best of conditions.
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     Some  hazardous wastes can never  be recycled  and
require  disposal.   Examples  of  such   wastes  are  the
polychlorinated  biphenyls  (PCBs). PCBs  are  classified as
extremely hazardous because they can threaten health  and
inflict great damage on the environment. PCBs have been
used in  carbonless  paper,  in  capacitors for  fluorescent
lighting,  in  wax for lost-wax castings, as  a  dielectric in
high-voltage capacitors, and in many other products. They
are  presently   being  phased  out   of   production   and
eliminated from the  environment.  Burying PCBs in landfills
delays rather than solves the problems they can create.  The
ideal solution to the problem of disposal of PCBs is to burn
or pyrolyze  them. However, destruction of PCBs cannot be
carried out in an ordinary incinerator. A high temperature
and a relatively long residence time in the  incinerator are
required  to  destroy  them  because  of  their extreme
resistance to heat. If PCBs are not completely burned, they
could become airborne and spread over large areas. Clearly,
PCBs must be incinerated, not recycled or buried. However,
they could be used as a supplementary fuel under carefully
controlled conditions.
      The elimination of a disposal problem or the sale of a
product that was once  deemed a  waste is often  incentive
enough  for  most  companies  to reclaim  their wastes.
Nevertheless,  some  companies  will  not segregate  their
wastes, separate their solvents, or cooperate with  the DOH
recycling program. The  DOH is considering imposing a tax
on  all unreclaimed recyclable materials to discourage  the
cavalier attitude of such companies toward waste disposal.
If the economic incentives are sufficiently great, resource
recovery,  recycling, and reuse of hazardous wastes will  be
implemented. Thus, the 3 R's with which  this paper began
have  now developed into the magical 4 R's, which should
serve mankind and its economy well in the future.
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                          CALIFORNIA'S HAZARDOUS WASTE MANAGEMENT PROGRAM

                                     X.  PESTICIDE WASTE DISPOSAL METHODS
                            AND THEIR POTENTIALS FOR ENVIRONMENTAL IMPACTS

                                                Paul H. Williams, Ph.D.
                                                  Research Specialist
                                         California State Department of Health
                                                    Berkeley, CA
      The  Vector   and  Waste  Management  Section,
California  Department  of   Health   (DOH),  has  nearly
completed  a  study,  funded  by the  U. S. Environmental
Protection  Agency  (EPA), dealing with  the  disposal of
waste pesticides and empty pesticide containers. The major
emphasis of this study has  been  to determine what is
known  about the environmental effects of present methods
and conditions  of disposal of these  wastes. The primary
objective of the study has been to develop information that
could  be used  in the development of  Federal and State
guidelines governing the disposal of pesticide wastes, and in
the  preparation  of environmental  impact assessments for
proposed waste disposal facilities.
      The  study has   focused  chiefly  on  California's
agricultural sector,  the kinds and amounts of  pesticide
wastes that are being generated, and the prevailing approved
disposal practices.  Particular  attention  has been given to
regional geographical and climatic  differences  within the
State that might affect the suitability of different disposal
methods. In examining these  regional  differences, we  have
sought  to relate our studies and findings to the problems of
pesticide waste disposal in other regions of the country
which have geographical, climatic, and other environmental
conditions similar to, or different from, those in California.
      In  presenting  information  relating  to  potential
environmental impacts of different pesticide waste disposal
methods, we  have followed  the format and  content of
conventional environmental  impact  assessments.  In the
usual context of these  assessments,  we have  interpreted
environmental impacts as inclusive not only of impacts on
air, water, soil,  and the natural and domestic bioecologies
of these  environments, but also of economic, social, and
public health and safety impacts that the various disposal
methods might have on their neighboring communities and
service areas.
      The pesticide wastes  that must be disposed of consist
chiefly  of: manufacturing   and  formulating   wastes;
deregistered, obsolete, and deteriorated products; liquids
and solids from cleanup of spills; and mixing tank and spray
rig   rinses  and  washdown   waters   which  result  from
agricultural  pest control operations. Other wastes include
damaged pesticides from warehouse and  other storage  area
fires, unused  pesticide-treated seed  grains and predator
baits, and a variety of pesticides and pesticide-contaminated
wastes of other sources  and descriptions.  In greatest bulk
are  the emptied and partially  emptied pesticide containers
of all kinds and sizes that require disposal.
      Disposal  of  waste pesticides and  empty pesticide
containers in California, as  elsewhere  in  the country,  is
primarily to  land. Waste pesticides and used containers of
all  kinds may  be disposed of at most Class I landfills in
California. These  landfills, which  meet  and  exceed the
general criteria of EPA for secure or designated landfills, are
located and engineered to conform to stringent and explicit
requirements   regarding   hydrogeology  and   protection
against water inundation and erosion  set forth by the State
Water  Resources   Control  Board  to  ensure  complete
protection of surface  and ground waters for all predictable
time. There are presently 11 Class I landfills in the State.
      In some areas of California dilute  aqueous wastes
consisting of unused spray mixes and rinse and washdown
waters are (with the approval  of the appropriate regional
water  quality  control  board)  discharged   to  earthen
infiltration/evaporation  basins, or  to  lined  evaporation
ponds  for later  disposal  at  a Class I  landfill.  These
field-located basins and ponds are a feature of the Imperial
and  Coachella  Valleys,   which  have hydrogeologic  and
climatic conditions that favor these methods of dilute-waste
disposal, but they are also to be found in more northerly
agricultural areas of the State.
      Dilute aqueous wastes containing pesticides are often
sprayed as generated on nearby fields or unused lands, or
collected  in sumps for later  disposal  in the same manner.
The wastes may also be  injected or tilled into the soil, but
this is not common practice in California. Occasionally,
where water  or productive land resources would  not be
endangered,  dilute  rinse  and  washdown   waters  are
discharged to  dry  wells,  some  of  which  have  tiled
drainfields to disperse the wastes.
      Empty  metal, glass, and rigid plastic containers which
have  been well-rinsed to remove pesticide  residues,  and
paper  and plastic  bags,  sacks and fiber  drums may be
disposed of at  California Class II landfills. These landfills,
which meet  and  exceed EPA guidelines for  solid waste
disposal  landfills,  must  also  conform   with  stringent
requirements of the State Water Resources Control Board
for the protection of surface and ground waters. Discharges
to   these  landfills  are  generally  restricted  to   low
water-content wastes which on decomposition would not
impair the quality of usable waters. Class 11 landfills are
located in  most counties of the State, and most of these
landfills  accept rinsed  pesticide  containers  (subject  to
inspection  or certification of  rinsing)  and well-emptied,
combustible containers.
                                                       -88-

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       Empty rinsed containers may also be buried singly by
 the farmer in a safe place on his property, and combustible
 containers may be burned  in the field in small quantities if
 the practice  is not prohibited by the  local air  pollution
 control district or is otherwise unsafe.
       The foregoing are all methods that are in accordance
 with  EPA guidelines  for disposal of waste  pesticides  and
 pesticide containers  anywhere in  the  United States. In
 California, these methods meet the general approval of the
 State  Water  Resources Control Board and  other agencies
 concerned with the protection of surface and ground water
 quality and with the  impacts that pollutants might have on
 the beneficial uses of those  waters  to human, plant  and
 animal life.
       How well the quality of surface and  ground waters
 are protected depends,  in the case  of landfill  disposal,
 primarily  on whether there  is buildup of contaminated
 leachate  in  the landfill which might percolate through
 intervening soils and underlying structures into a freshwater
 aquifer,  or which  might emerge at the toe  of the landfill
 and flow directly or indirectly into surface waters. Surface
 waters might also be polluted by erosion  of waste from the
 landfill area if the landfill were not well-protected from
 stormwater inundation and runoff.
       Earthen  infiltration/evaporation  basins  for  dilute
 wastes must  be  well-isolated vertically and  laterally from
 usable  water resources.  Where this  isolation  cannot  be
 ensured,  either  open ponds  that  are  lined  to prevent
 infiltration  but allow evaporation, or  vented  sumps that
 retain  wastes pending  other disposal, are required. Spraying
 of  dilute  wastes  on   fields  and  unused  land,  and  soil
 injection   and   tillage   must   be  practiced  with   the
 consideration that  pesticide residues might be leached from
 the soil layers by storm or irrigation waters into natural or
 domestic water resources.  Field  burial  of containers  and
 burning  of empty  sacks and  bags  are subject  to  the same
 precautions against contamination of water resources.
      The suitability of any of these disposal methods with
 respect to protection  of water resources depends greatly
 upon the climatic  conditions of temperature and rainfall,
 the proximity of usable surface and ground waters, and the
 adsorptive capacities  and  other properties  of  intervening
 soils. These are highly critical considerations in regions of
 moderate  to high rainfall  and  prevalent  surface  and
 ground waters, which is   descriptive   of many agricultural
 areas of the country.
      All of these methods  of pesticide waste disposal have
 potentials also for pollution of the other primary receptors,
 the atmosphere and the land. Pesticides  may  be  airborne
 from landfill disposal sites as  vapors, gases, dusts and larger
 particulates  in  the  course  of unloading  and  disposal
 operations.  They  may  volatilize  from  infiltration  and
 evaporation basins  and ponds,  and may  volatilize and be
 raised  as dusts from field disposal surfaces. Once airborne,
 they might drift to nearby agricultural  crops  or natural
 vegetation, or onto water surfaces, or they might be widely
 dispersed in the atmosphere, to be brought down eventually
 in rain and snowfall.  Areas of productive soils might be
contaminated  by  pesticide residues  in  surface flows  of
 landfill leachate,  and  by migration or  leaching of wastes
from field disposal sites.
     Fortunately, the  greater the exposure to air, sunlight,
and moisture,  and to the chemicals and microorganisms of
soils,  the  more  rapidly  most pesticides decompose  to
relatively  harmless  substances.  Nevertheless,  the potential
 harm to life, associated with pesticides that might escape
 into the  atmosphere  and the soils, must be weighed in
 assessing  the possible  environmental  impacts  of  waste
 disposal methods.
       The   economic    impacts   to  be   considered   in
 environmental impact  studies of  disposal  methods include,
 for a landfill disposal  site,  the  costs  to the disposer of
 disposal  fees  and  associated  charges, and  the costs  of
 transporting  the wastes to the disposal site. Costs  to  the
 community, if the disposal site were publicly owned, would
 include  capital,  operating, and community services  costs,
 offset in some measure by disposal fee revenues and income
 from  marketable   recycled  materials.  Direct  economic
 benefits  to the community might include employment
 opportunities, and availability of  the facility for disposal of
 other kinds of wastes.  A privately-owned facility  would
 provide an additional source of property tax revenue.
       Also  to be  considered  in   the assessments are  the
 economic  and social effects of a pesticide waste disposal
 facility on the values and uses  of land and other properties
 located  near  the disposal site and  along  its access routes,
 and the  impact on regional property values and uses. In an
 agricultural  community  conveniently  located  near  the
 disposal   facility,  long-term  beneficial   regional  impacts
 would be anticipated.
       Among the public health  and safety aspects to be
 assessed,  whatever  the  method  of  disposal,   are  the
 potentials for exposure  of employees,  disposal site users,
 and  the general  public to harmful  contacts  with  the
 pesticide wastes, or to vapors and dusts in the atmosphere
 immediate  to the  site.  This would be  of special concern
 regarding  landfills to  which  the public  has  access, but
 field-located infiltration  and evaporation sites might  pose a
 hazard to farm workers and others in the vicinity.
       During  the course of the  pesticide  waste disposal
 study, we have reviewed in some depth various chemical,
 biological,   physical,    and   thermal   technologies   for
 degradation  of  pesticide  wastes  to  relatively  harmless
 substances or for recovery of usable chemical raw materials.
 There are many techniques within these categories that can
 be used  in the separation,  isolation, and degradation  of
 many individual pesticides of known chemical and physical
 compositions. We are not optimistic, however, that with the
 exception of incineration, any of these methods singly or in
 reasonably  few and simple  combinations,  would  be  of
 practical  use  in  handling  the   diversity  of  chemical
 compositions  and  physical states, and  the  mixtures  of
 wastes  that might  be  generated in a  major  agricultural
 region.  In  any  case,   all   of  the  methods, including
 incineration, must be backed  up by a secure landfill for the
 ultimate   disposition  of liquid  and   solid  degradation
 residues,  unless all products of degradation  were completely
 harmless or were recovered as reusable chemicals.
      The  state-of-the-art of  incinerator  technology for
 disposal  of pesticides and other hazardous  wastes is such
 that we are encouraged to believe that  incineration  has a
 considerable potential as  a pesticide waste disposal method.
 With  application of  efficient combustion  and pollution
 control  technology  now  available, incineration   holds
 promise as a disposal method that can be protective of the
 environment  and  result  in  minimal  residues requiring
further  disposition.  It  also   provides  opportunity  for
 recovery  of basic chemicals from the combustion  products
and  of metal  containers from  the ashes  for recycling  as
scrap.
                                                        -89-

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               CORRELATION OF BATCH AND CONTINUOUS LEACHING OF HAZARDOUS WASTES

                                            M. Houle, D. Long, R. Bell,
                                          D. Weatherhead, and J. Soy I and
                                           Chemical Laboratory Division
                                        U. S. Army Dugway  Proving Ground
                                                   Ougway, UT
 INTRODUCTION

      Industrial processes annually generate large quantities
 of hazardous wastes  which,  when deposited in industrial
 lagoons or municipal landfills, might present severe disposal
 or storage problems.  The problems of immediate concern
 here are the  potential health hazards that might result from
 land disposal of hazardous wastes, e.g., the contamination
 of drinking water caused by leaching of toxic substances
 from these wastes  into underground  water  supplies. It is
 necessary, therefore,  to know the quantity  of each toxic
 substance which might be leached from a waste. This paper
 describes a practical  procedure for rapidly evaluating the
 leaching characteristics of industrial wastes.

 MATERIALS AND METHODS

      Samples of 2 hazardous wastes, electroplating waste
 and inorganic pigment waste,  were leached with water. Two
 leaching methods  were compared, serial-batch extraction
 and the  more conventional continuous-column extraction.
 The extracts (leachates) of the wastes were analyzed for
 cadmium,  chromium,  copper,  and  nickel by  atomic
 absorption spectrophotometry  (AAS).  The conductivity
 and pH  of the  leachates were measured  to detect gross
 changes produced in the liquid environment.

 Continuous-Column Extraction

      Continuous-column   extraction   is  a   standard
 laboratory method  used to examine  the  leaching of
 substances from a  waste and  to  follow  their migration
 through soil.  For the present  study, the waste and the soil
 were packed  into  separate  glass  columns  as shown in
 Figure 1.  Each column was  made  from  37 mm   (inside
 diameter) glass tubing that  had an 8mm  outlet  at the
 bottom. A piece of glass wool was placed at the bottom of
 the  column and covered with  washed quartz sand.  One
 hundred  grams of  the  waste was then packed  into the
 column, occupying a depth of 10 to 13 cm depending on
 the type of waste. The waste  was covered with one cm of
 sand and  a thin layer of glass wool. The column was then
 fitted with a stopper containing a  3-way stopcock.  The
 stopcock  allowed   either the  periodic   (usually  daily)
 sampling of the leachate as it exited the column of waste or
 the directing  of the leachate upward into the soil  column.
 Upward flow was used to maintain saturation, to minimize
 channeling, and to permit better control of the flow within
 the range of  0.5 to 1.5 soil-pore volumes per day.  The
column  of soil  was prepared in a manner similar to the
column of waste.
                      FIGURE 1

  CONTINUOUS-COLUMN EXTRACTION APPARATUS
             SOIL
             COLUMN
   WASTE  COLUMN
   LEACHATE


   WATER  IN   *
                                       SOIL
                                       EFFLUENT
 NDUSTRIAL
WASTE
     The ease with which water penetrated the column of
waste varied greatly depending on the kind of waste. For
example, at the pressure of 213 cm (7 ft) of constant head
used  in  these   experiments,  water  penetrated   the
electroplating waste slowly but passed readily through the
inorganic pigment waste. Therefore, the rate of flow was
controlled so that the "front" of liquid moved an average
of 1.3 x 10~4 cm/sec in all cases.
     It was considered to be impractical to determine a
pore volume for  many  wastes because of their physical
states (e.g., heterogeneous suspension, liquid, certain solids,
etc.). But, if the volume of water passed through a column
of waste is expressed in standard units such as milliliters,
other applications of the data are facilitated. For example,
plotting the  concentration of a chemical species extracted
from a waste (e.g., ug /ml ) versus the cumulative volume
per unit weight of waste being leached (e.g., ml /g ) allows
                                                     -90-

-------
calculating the total weight  of  the  extracted component.
The weight can be obtained by determining the area under
a curve fitted to the experimental points or by multiplying
the volume  in  ml /g   times the average concentration
observed  during the passage  of that given volume. (For
example,  ug /ml   x  ml /g   =   ug /g  waste,  which  is
numerically equal to grams per metric ton (2,200 Ib ).) This
approach  also permits expressing the waste column output
in terms of cumulative volume per unit weight of soil being
challenged by the waste. The weights obtained from these
data can  be  used to calculate attenuation or penetration
factors for the soil. An additional advantage is that the data
from  different experiments  with  a given waste  can be
pooled regardless of the pore volume of the soil which had
been challenged by that waste.
      Pooling  the  data  in  this  way  provided  a better
estimate of the  concentration of each metal  presented to
the soil column and all of the data from a given waste could
be plotted on one  graph.  Least-squares regression analysis
was used to derive equations for the observed  relationships.
Equations such  as  these  provide a basis for  subtracting
curves for blank  samples, for  obtaining the  area  under
curves, and for evaluating  the effects of selected variables.

Serial-Batch Extraction

      Batch extraction is  a  less conventional laboratory
method for  studying  the leaching of substances from  a
waste. For the  present study,  samples of the hazardous
wastes studied were dried to determine their water content.
Duplicate samples of wastes that had not been dried were
then  added  to Erlenmeyer  flasks such  that each flask
contained the equivalent of 20 grams dry  weight of waste.
Water was added to the flasks in the ratio of 2 ml /g of dry
waste (i.e., 40 ml   of water). A small  water-to-waste ratio
was   desirable  at  first  to  remove  the readily soluble
components  without excessive  dilution which could have
changed   the  metallic  salt  concentrations  and  ionic
strengths,  conceivably  affecting  the  solubility  of other
components  of the waste.  Thereafter, progressively greater
dilutions  were  made  to  simulate  extended  periods  of
leaching.  Each  flask was  manually  shaken  4  or  5 times
during the workday (continuous mechanical shaking might
have  abraded the  particles of  waste,  making  them more
susceptible to extraction). After 24 hours each flask  was
shaken  again, and  the contents were allowed to settle and
were  filtered by vacuum through  a Buchner funnel.  (Some
wastes  required  longer than 24 hours  for   a maximum
amount to dissolve in water. To determine if equilibrium
had been  attained, aliquots of extract were withdrawn and
analyzed  for specific  constituents.  The  extraction  was
continued until  the analyses  detected  no further increases
 in concentration.)  The filtrate was then passed through a
fine  millipore filter to  remove all  suspended  materials
 before being  analyzed by AAS.
RESULTS AND DISCUSSION

Continuous-Column Extraction

      Polynomial  regression  curves of  degree  6  usually
fitted the data best  as judged  by the  R-square value. The
R-square value is  a goodness-of-fit parameter that can  be
interpreted  as  the  fraction  of  the  data  adequately
represented  by the least squares curve; a value greater than
0.3 is considered acceptable.  Although the R-square values
usually  indicated an excellent  fit statistically, humping in
some regions of the curves occasionally appeared excessive,
an  idiosyncrasy of  polynomial  curves.  In  such  cases, a
lower-degree poiynomial  was chosen.  The  R-square value
for  a  lower-degree polynomial equation usually  differed
only slightly from that for a higher degree. In other cases it
was  necessary  to  use   an   exponential  or  logarithmic
regression to describe relationships between the variables.
Figure 2 shows an example of the type of results obtained.

Serial-Batch Extraction

      Figure 3 shows the  results of serial-batch extractions
performed with gradually increasing ratios  of solvent to
waste.  In this case, ratios of 2, 3, 6, 12, 24, and 48 ml /g
were used  during a 7-day  period. This is equivalent to
approximately 7 months of continuous-column extractions.
Additional  extractions,   especially   with  much  larger
volumes,  could have been used  to simulate even  longer
leaching periods.
      To  achieve  estimates  of  the  yield  of extractable
constituents more rapidly than in 7 days, larger proportions
of  solvent could have been used, although the shape of the
curve   would   have   been less accurate than  if  smaller
proportions of solvent had been  used. Furthermore, large
proportions of solvent could have altered the solubility of
some constituents. To  achieve even more  rapid estimates
(e.g., in 24 hours) of the yield of extractable constituents
during  protracted leaching periods, several  batches could
have been extracted simultaneously using different ratios of
solvent to waste. Examples of  extractions using 2,  50, and
200 ml /g   are  shown  as histograms in  Figure 4. These
results  could  be refined by performing  2 more successive
extractions  on the residues from the 2 ml /g extract (which
had  had  the  bulk  of  the  readily  soluble components
removed) using perhaps  40 ml /g , and then 150 ml /g , as
illustrated in Figure 5.

Correlation  Between  Serial-Batch and Continuous-Column
Extractions

      The   relation    between   serial-batch  and
continuous-column  extractions  becomes  evident   by
recognizing that continuous-column extraction is equivalent
to  a series of  contiguous  batches extracted with an amount
                                                        -91 -

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                                                        FIGURE 2
                                       NICKEL LEACHED FROM ELECTROPLATING WASTE
                                     BY CONTINUOUS-COLUMN EXTRACTION WITH WATER.
                                  INSET: PARAMETERS FOR THE EQUATION DESCRIBING THE CURVE.
            H.HBr
co
ro
            3.0ft <
                                                                        COEFFICIENTS FOR PDLYNDMIflL OF DEGREE E
CDN5TRNT
COEFF X
CDEFF X2
COEFF X3
CDEFF XM
COEFF Xs
COEFF XB

 R2
                                                                                      2.HHS2E023I
a  0.373SBBa73
» -0.0S0B2HH7M
«  3.SIMMIE-03
« -I.22H9HE-0M
"  I .E9ESHE-0E

 «  0.SB493S225:
                                                                                                                  LCL
                                                      cum volume  (ml/gm)

-------
of water barely  greater than field saturation  for the soil
being tested.  Plotting the cumulative volumes extracted  as
ml /g of waste versus the observed concentration of each
constituent in the resulting extract puts the data from both
extraction  procedures on  a common  basis  and  allows
correlation of the results.
      The validity of this correlation was checked by using
serial-batch  extraction  on  wastes  for  which  extensive
continuous-column extraction work had already been done.
Figure 6 shows the concentration of  nickel extracted from
electroplating waste using  both  extraction procedures. The
data for the continuous-column extraction  are the same as
those in  Figure 2;  the data  for the serial-batch extraction
were added to the  figure as histograms. Only single samples
were  used for serial-batch extractions instead  of replicates
as we now recommend. Also, several different laboratory
technicians performed the extractions, so there were some
individual deviations from the data for continuous-column
extraction  (which  were  accepted as the  standard). The
serial-batch extractions were performed  using  substantially
greater amounts of water than  those contained within the
waste  in  the  continuous-column  extractions  (200  to
4,800 percent versus less than 50 percent) but the data still
showed good correlation.  This correlation indicates that
serial-batch  extraction   is  an  adequate  substitute  for
continuous-column  extraction over  a  range of moisture
contents.  A reduced  amount  of water was used  for the
initial extractions  because the adverse effects of dilution
would be greatest initially.
      For serial-batch extractions, the  area under each
histogram is equivalent to the  total weight of a constituent
extracted per gram of waste by a given  volume of water.
The sum of these weights provides an estimate of the total
weight of a constituent likely  to be leached per gram from
any mass of waste.  For continuous-column extractions, the
total weight of constituent extracted  from the waste  is
estimated by integrating  the area under the curve fitted to
the experimental data, such as the curve shown in Figure 2.
      Excellent  agreement was obtained between the total
weights of nickel extracted by the 2 methods in the range
from 0 to 20 ml of solvent per gram of waste. The ratio of
the total weight of nickel removed per gram of waste from
electroplating   waste   by  serial-batch  extraction  versus
continuous-column extraction  was 1.1 to 1.
      Figure 7 compares the weights of cadmium extracted
per gram of waste from the electroplating waste by the 2
methods. Considerably more cadmium  was extracted from
the waste by the serial-batch method in the first extraction
                                                     FIGURES

                         HISTOGRAM SHOWING RESULTS OF SERIAL-BATCH EXTRACTION
                •-I
                id
                -P
                I
                                 20         40         60         80

                                              cum volume  (ml/gin waste)

                                                        •93-
                         IOO       I20

-------
                                     FIGURE 4


               HISTOGRAM SHOWING RESULTS OF CONCURRENTLY-RUN RAPID

                             BATCH EXTRACTION TESTS
                              50              0

                               volume (ml 'gm)
                    200
                                    FIGURE 5


                    HISTOGRAM SHOWING REFINEMENT OF THE RAPID

                     LEACHING TESTS (SERIAL-BATCH EXTRACTION)
IB
4J
a
          20     40     60     80     100     120

                               cum volume (ml /gal waste)


                                      -94-
140     160     180    200

-------
CO
I
H
(0
4J
               1.5
                                                         FIGURES

                                          COMPARISON OF SERIAL-BATCH (HISTOGRAM)
                                        AND CONTINUOUS-COLUMN EXTRACTION METHODS
                                          OF LEACHING NICKEL FROM ELECTROPLATING
                                                     WASTE WITH WATER
     3.5
               3.1
                                                                                          Total ug leached

                                                                                  Continuous    12.2

                                                                                  Batch         13.6
               l.
               1.5
                            B  1  33
                                    BH
                                        i i
                                                                                                            LOL
                          M
B        K       H

cum volume  (ml/gin)
                                                                              W
                                                                             f
S

-------
2.5
2.1
I.S
                                         FIGURE?

                           COMPARISON OF RESULTS OF SERIAL-BATCH
                      (HISTOGRAM) AND CONTINUOUS-COLUMN EXTRACTION
                     METHODS OF LEACHING CADMIUM FROM ELECTROPLATING
                                    WASTE WITH WATER
3.5
3.1
       Total ug leached

Continuous   17.7

Batch        31.1
             B  •
B.f
                                                                                         •»L*L
                                     cum volume  (ml/gm)

-------
(0 to  2 ml /g  of  solvent per gram of waste) than  was
initially  extracted  by  the  continuous-column method.
However,  samples of solvent that first emerged from the
column  of  waste  were  not  collected   during  the
continuous-column  extraction.  As  a  result, the  initial
concentration of cadmium was uncertain. This uncertainty
would  directly affect the y-intercept of  the polynomial
regression curve.  The y-intercept of the derived curve was
probably too low; consequently, the estimated area under
the first segment of the curve for the continuous-column
extraction was significantly less  than the area under the
first histogram for the serial-batch extraction. However, the
areas under successive segments  of the curve correspond
well to the areas under successive histograms.
     Figure 8  compares the weights of copper extracted
per gram  of waste  from the electroplating waste by the 2
methods.  Although there are  some  differences  in the
results, reasonable agreement was obtained. The ratio of the
total weight of copper extracted per gram  of waste  by the
serial-batch versus the continuous-column methods for the
range 0 to 20 ml  of solvent per gram of waste was 1.6 to 1.
The third sample  from the serial-batch extraction of copper
was high,  probably because a small  amount of particulate
matter from the  waste  passed  through  the filter. For that
reason   final  filtration   through  a  millipore  filter  is
recommended.
     Figure 9  shows the weights of chromium extracted
per gram  of waste  from the electroplating waste by the 2
methods.  This  is the only  metal  for  which  a significant
difference between  the results of the 2 extraction methods
was observed.  A significant quantity  of chromium was
extracted  from the  waste  by the serial-batch method,
whereas  none  was  extracted  from  the  waste  by the
continuous-column   method.   The   failure  to   detect
chromium  by  continuous-column extraction  might have
been due to pH. Possibly as a result of aging during the
2-year  period  between  these  experiments, the pH  of the
serial-batch extracts was approximately 8, whereas that of
continuous-column  extracts  was  about  7.  Most  of the
chromium exists as  chromium hydroxide in the waste, and
chromium hydroxide is amphoteric. Chromium hydroxide
has maximum solubility in alkaline solutions and minimum
solubility  in neutral solutions (the difference between pH 8
and  pH 7  is  a  10-fold  decrease   in   hydrogen  ion
concentration). In alkaline solution chromium might form
more soluble complex ions. In addition, the electroplating
waste  contained  a  number of  cations  (and associated
anions) besides the 4 metals studied.
     A sample of inorganic pigment waste was subjected to
serial-batch  and continuous-column  extraction. Figure 10
shows the weights of nickel extracted per gram of waste by
the 2  methods;  a  ratio of 1.5 to  1   (serial-batch  versus
continuous-column  extraction) was obtained  for the total
weights extracted up  to  40 ml  of solvent  per gram of
waste;  Figure 11 shows the weights of cadmium extracted;
a  ratio of  1.9 to  1  was obtained from 0 to 40 ml/g
Figure  12  shows  the  weights  of   copper  extracted.
Concentration differences of a few tenths of a ug /ml were
observed between the 2 techniques in the later extracts;
however,  the  total  weight of metal  extracted  by both
methods  agrees  well,  indicating  a  ratio of  0.9 to  1.
Figure 13 shows the weights of chromium extracted; a ratio
of 0.7 to  1 was obtained. Further work has shown that the
24-hour contact time used in the  serial batch  extractions
was   not  sufficient   to  equilibrate   the  chromium
concentration.
      Conductivity (specific conductance) and  pH of each
extract were  measured  to indicate gross changes in  the
environment within a waste. The conductivities of extracts
from  serial-batch and continuous-column extractions  are
shown in Figure 14. The conductivities indicated that the
soluble salts present in the inorganic pigment  waste were
rapidly leached as expected.  In  addition,  the  inorganic
fraction was composed of slightly soluble inorganic pigment
compounds and  hydroxide salts  of each of  the metals
studied.  The  waste  also contained a significant organic
fraction.
      Figure  15 illustrates the pH measurements for each
extract.  Good agreement  between  the  results  of the  2
extraction methods was obtained.

Advantages of Serial-Batch Extraction

      Serial-batch  extraction  has  several  advantages  over
continuous-column extraction. The serial-batch method can
be used to evaluate the leaching ability of wastes much faster
than  can  be accomplished  with columns. This advantage
should be of particular value to the manager of an  industrial
plant who wants to check the effect of changing a step  in a
manufacturing process, changing a pretreatment process, or
changing the composition of a waste stream, or who wants
to obtain certification to dispose of a load of waste.
      The experimental  setup for serial-batch extraction is
much  simpler than  for  continuous-column  extraction.
Continuous-column extraction requires careful  packing of
columns  and  regulation  of   head  pressure  within  the
columns to achieve  the desired rate  of flow. In contrast,
serial-batch extraction requires only the use of stoppered
Erlenmeyer flasks that are shaken occasionally.
      Serial-batch extraction simplifies the investigation of
a wide variety of additional variables. For example, samples
can be included to test the effects of acid rain (1), of other
simulated  environmental   conditions  (e.g.,  drying   or
freezing),  or  of disposing of different  kinds  of wastes
together.  This flexibility  allows  the  investigations to be
conducted as  factorial experiments. Equations  relating the
significant variables  and their interactions  can  then  be
derived and used to make good predictions of leaching rates
under sets of conditions that match given field situations.
      Serial-batch extraction can also be used to determine
what an extract of a given waste will remove from another
waste located beneath the given waste in a disposal site.  The
effect of the extract of one waste  on another waste can be
tested simply  by  substituting the extract for the water used
in the batch extractions reported here.
                                                        -97-

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                                               FIGURE 8
     HJr
                                 COMPARISON OF RESULTS OF SERIAL-BATCH
                             (HISTOGRAM) AND CONTINUOUS-COLUMN EXTRACTION
                                   METHODS OF LEACHING COPPER FROM
                                   ELECTROPLATING WASTE WITH WATER
     3.5
     2.5
3    2.1
      1.5
      IJ
     1.5
•*
       x
       B
       1 >
      t *
                                       t  I  I
                       IMS    B
                         «l »
                                   "
............——-r *•-• *• ~-—~«.~|.'«.«
       •I        •)
                                                                             Total ug leached

                                                                     Continuous    14.2

                                                                     Batch         23.0
                                                                                                  • LW.
                                            cum volume (ml/gm)

-------
                                               FIGURES
     B.Br
                                COMPARISON OF RESULTS OF SERIAL-BATCH
                            (HISTOGRAM) AND CONTINUOUS-COLUMN EXTRACTION
                                  METHODS OF LEACHING CHROMIUM FROM
                                   ELECTROPLATING WASTE WITH WATER
     7.B
     6.1
       Total ug leached

Continuous    0

Batch        39.3.
V,    H.1
     2.1
     1.1

                                                  n
                                          cum volume (ml/gm)

-------
1.9


I.B


i.T


i.G
                               FIGURE 10

          COMPARISON OF RESULTS OF SERIAL-BATCH (HISTOGRAM) AND
        CONTINUOUS-COLUMN EXTRACTION METHODS OF LEACHING NICKEL
                FROM INORGANIC PIGMENT WASTE WITH WATER
                                                             Total pg leached

                                                      Continuous   4.2

                                                      Batch        6.1
1.5
1.4



In
.3


B.2


Bi
.1



E

H













a

I

1
*


B X 1
, V
M

S




•








H
.1
S
m
3*3 1 H
s
5 I1

B I












I*1* E

1 4 I Jl II * * 1
J 1 J. •."! k||J M J h . •«

llVIVlJlMlJl^iJlB
                                                                              *LPL
in
                           cum volume (ml/gm)

-------
1.9
I.e
1.7
                                          FIGURE 11

                     COMPARISON OF RESULTS OF SERIAL-BATCH (HISTOGRAM) AND
                  CONTINUOUS-COLUMN EXTRACTION METHODS OF LEACHING CADMIUM
                           FROM INORGANIC PIGMENT WASTE WITH WATER
       Total ug leached

Continuous   1.8

Batch        3.4
B.E
\
(fl
tn





as

1.3

1.2
1.1
„.



M
S

B
t ......



1

if f *i 01^ * - J * 1


                            1/1
                                     cum volume  (ml/gm)

-------
     1.4
     B.3
                                              FIGURE 12

                         COMPARISON OF RESULTS OF SERIAL-BATCH (HISTOGRAM) AND
                       CONTINUOUS-COLUMN EXTRACTION METHODS OF LEACHING COPPER
                               FROM INORGANIC PIGMENT WASTE WITH WATER
H
id
•M
IJ


1.9


I.B


1.7


I.B


I.S
                                                                               Total jug leached

                                                                       Continuous    3.4

                                                                       Batch         2.9
     1.2"
     I.I
     "•*-
                                       '     '      a  *  i,
                                                                            s  s
               —W-tM *«-?HN-•*««-•-	H—-»--H—M	1—I-	(••
               	Jr	F	±	£	±	s	*	a	i
                                                                                                  tM.
                ui
                                     R
                                                   K!
                                          cum volume  (ml/gm)

-------
                                                       FIGURE 13



                                  COMPARISON OF RESULTS OF SERIAL-BATCH (HISTOGRAM) AND

                               CONTINUOUS-COLUMN EXTRACTION METHODS OF LEACHING CHROMIUM

                                        FROM INORGANIC PIGMENT WASTE WITH WATER
o
CO
              fl.il
              7.1
              6.1
              £.0
         3
              3J
              2.9
              1.1
              B.I
                                          SH
                                JH  1

       Total ug  leached



Continuous  136.



Batch        94.


    IT
                        Uf
                                                   s       K        s

                                                   cum volume  (ml/gin)
                                                                                                        * LM.

-------
                                                       FIGURE 14


                         CONDUCTIVITY (SPECIFIC CONDUCTANCE) OF SOLUTIONS LEACHED FROM INORGANIC
                       PIGMENT WASTE BY SERIAL-BATCH (HISTOGRAM) AND CONTINUOUS-COLUMN EXTRACTION

                                                  METHODS USING WATER
g
           •s
           0
           M
           U
           (1)
           U
           C
           U
           3

           C
           0
           o

           u
           •H
           <4-(
           •H
               BBHBr
               700H
           ^   H000
3000
           a   2000
               1000
                 B
                           l/t
                                             UI
                                                           MS^H,,
                                                                                       HS5Si|5
                                                              Ul
                                                                                lI
                                                                                         B
                                                                                         X
                                                                                   M
                                                                                   X
                                                      cum volume  (ml/gm)

-------
                                                      FIGURE 15




                              THE pH OF SOLUTIONS LEACHED FROM INORGANIC PIGMENT WASTE BY

                      SERIAL-BATCH (HISTOGRAM) AND CONTINUOUS-COLUMN EXTRACTION METHODS USING WATER
o
01
IH
13-
12
II
10
9
e
7
&
£
H
3
Z
1
n,





i







'«*







V^






ms







***"







' 1? ^ ¥ *'







S u i(K u te
. i| 14 X X X S K H u
S






"BiuisiidiguiBiuiBibiB
~ — wwnnxxu
                                                  cum volume (ml/gm)

-------
CONCLUSIONS

      Except for chromium  in  electroplating waste, the
results of serial-batch and continuous-column extractions
differed  by no more  than a factor of 1.8 in  the  total
weights of the 4 metals extracted. Serial-batch extraction is
much  faster  and more flexible  than continuous-column
extraction. Serial-batch extraction could well serve as the
standard method for evaluating the leaching of toxic metals
from hazardous wastes.

ACKNOWLEDGMENT

      This  study was  part of a  major research  project
dealing with the migration of hazardous substances through
soil. The project  is presently being conducted by  U. S.
Army Dugway  Proving Ground under the auspices of, and
funded  by,  the U. S.  Environmental  Protection Agency
(EPA),  Municipal   Environmental  Research  Laboratory,
Solid and  Hazardous  Waste  Division,  Cincinnati,  Ohio,
under Interagency  Agreement  EPA-1AG-04-0443. Michael
Roulier,  Ph.D., is  the  EPA  Program  Manager for this
project.
1.
              REFERENCE CITED

Likens, G. E. 1976, Acid precipitation. Chem. Eng. News 54
    (Nov. 22): 29-44.
                                                      -106-

-------
                     AN EVALUATION OF THE WEATHERING METHOD OF DISPOSAL OF
                         LEADED-GASOLINE STORAGE TANK WASTES:  A SUMMARY

                                            Howard K. Hatayama, P.E.
                                           Waste Management Engineer
                                       California State Department of Health
                                                  Berkeley, CA

                                                      and

                                                   David Jenkins
                                      Professor, Department of Civil Engineering
                                    Division of Hydraulic and Sanitary Engineering
                                  Director, Sanitary Engineering Research Laboratory
                                               University of California
                                                   Berkeley, CA
INTRODUCTION

     The primary  purpose of  this  investigation was to
evaluate  the  weathering  method  recommended  by  the
American Petroleum  Institute  (A.P.I.)  for  the treatment
and/or disposal of leaded-gasoline storage tank sludge  (1).
The  sludge  is extremely hazardous  because of  its high
content  of organic lead. Concentrations of organic lead
with respect to tetraethyl lead (TEL) in methanol can range
from   20—200  ppm  on  a   dry  weight  basis.  Total
concentrations of organic and inorganic lead can range from
3,000-6,000 ppm on a dry weight basis.
      Leaded-gasoline  storage tank sludge is a dark brown
to black material that has a strong odor of gasoline.  The
solid fraction of the sludge can range from  30-60 percent
by  weight and is composed primarily of iron  oxide scale
varying in particle size from less than 0.07 mm.—2.4 mm. in
diameter. The liquid fraction of the sludge can range in pH
from  6—8, and contains  some soluble organic compounds.
There is usually no organic phase visible due to the  recovery
of residual gasoline during cleaning of storage tanks.
      The solid  fraction of the  sludge  is created by  the
oxidation of the steel walls of storage tanks and the flaking
off, or the scouring of, the resultant iron oxide scale by the
floating  covers of  the tanks. The liquid  fraction of  the
sludge derives from condensation of water vapor  in  the
tanks and from water used during cleaning to dislodge the
sludge  from  the  bottoms  of  the   tanks.  The   high
concentration of  organic lead in the sludge results  from the
use of TEL and other organic lead compounds as antiknock
additives in gasoline. A source of inorganic lead can be the
steel in the walls of the storage tanks themselves.
      The  California  State  Department  of  Health   has
collected data from  the California  Liquid Waste Hauler
Record  (manifest)  (2) which  indicate  that the  reported
off-site disposal  of leaded-gasoline  storage tank sludge in
California amounted  to  about  1,000 tons during 1976.
Each truck load of sludge is usually classified by the waste
producer as  "TEL Wastes" on the manifest.  However, if
records are misplaced, or if it is not known whether a given
storage tank  contained leaded gasoline, the waste  producer
typically labels the sludge to warn of  the  possible health
hazard associated with any  lead that might be present. The
problem of disposal of leaded-gasoline  storage tank wastes
will probably continue to be significant for about the next
decade during which  time governmental  regulation of the
lead  content  of gasoline will progessively decrease the
quantity of leaded gasoline requiring storage.
     TEL is a colorless, oily liquid with a sweet odor and a
vapor  pressure of 0.377 mm  of mercury at  25°C. It is
insoluble in  water but is  soluble in gasoline, benzene, ethyl
ether,  methanol, fats, and oils (3). Because of its solubility
in fat, TEL vapors can be absorbed through lung tissue  or
through  the skin.  Its high toxicity is  reflected by the
recommended Threshold Limit Value  (TLV) for 8 hours'
daily   exposure   of  only  0.075 mg/m3   (American
Conference  of Governmental  Industrial   Hygienists). For
infrequent exposure, only 0.15 mg /m ' is considered to  be
a  safe  concentration.  The  immediate   effects  of the
inhalation  of  TEL vapors are not  known precisely, but
exposure to 100 mg /m 3 for  1 hour is sufficient to cause
illness (4). Thus, the concentrations of organic lead released
into the air during  weathering of leaded-gasoline storage
tank  sludge as well  as the concentrations that  could  be
absorbed during handling of the sludge, constitute potential
health hazards.
      The weathering  method recommended by the A.P.I.
for disposal of leaded-gasoline storage  tank sludge involves
spreading the  sludge to form a bed not more than 3 inches
thick on a  smooth, well-drained surface.  Air is allowed to
circulate over the  bed, and  exposure  of the sludge  to
sunlight is considered to be desirable  but not  mandatory.
After  the  sludge has been spread, the  spreading area is
posted, and the sludge is allowed to weather for a period of
4 weeks. If after such time the concentration of organic
lead is less than 20 ppm, the sludge  can be  treated as a
nonhazardous material.  The weathering  method is simple
and  inexpensive  and  is  claimed  to   be  efficient  in
detoxifying the  sludge.  However,  the method can create
health hazards due to the presence of airborne organic lead
in the vicinity of the weathering bed and to the leaching of
lead from the sludge into ground water supplies.
      The  purpose of this investigation  was to determine
the reduction of organic  lead in leaded-gasoline storage tank
sludge  by  weathering and to assess the  magnitude of the
"worst case"  hazards associated with the weathering of the
sludge.
                                                        -107-

-------
MATERIALS AND METHODS
                        RESULTS AND DISCUSSION
      Two experimental cells were constructed to simulate
weathering beds (Cells No. 2 and No. 3). Each cell consisted
of a  column of  soil  covered with a layer of sludge over
which  a  stream  of   air  flowed  (Figure  1).   A  third
experimental   cell   was   constructed   to   simulate   a
water-covered sump which served as a control (Cell No.  1).
The  soil used in the columns was  Oakley sand  (Table  1).
The  volume of  the air chamber was 20.3 liters, and the  air
flow  rate  was  maintained  at  1 liter/rrin  throughout a
30-day weathering period.
      The air stream flowing over  the sludge was  directed
through a particulate filter to a carbon tube which was used
to sample airborne organic  lead (Figure 2)  (6). Airborne
organic lead was sampled for a 24-hour period on days 1, 2,
3, 6, 13, and  30 of the  weathering  period. Leachate in
midcolumn  was sampled  using  a gravity  leachate sampler
(Figure 1).   Soil-water   tension  was   measured   by   a
tensiometer (7). After the 30-day  weathering period, Cell
No. 3 was inundated  with  the equivalent  of  1  inch  of
rainfall, and the resulting leachate was collected. Also at the
end  of  the weathering  period,  the  supernatant and settled
sludge of Cell   No. 1 were sampled. Figure 2 shows Cell
No.  1 in the nonsampling  mode of operation with a water
trap to protect  the rotameters between sampling periods.
      A   Perkin-Elmer   Model/306  Atomic  Absorption
Spectrophotometer with a hollow cathode light  source and
a 4-inch single  slot-type burner was used to analyze samples
for lead at 283.3 nm. Organic lead was determined by using
a methanol extract (8) which was aspirated directly into  the
instrument.  Total lead was  determined by digestion with
nitric and perchloric acids (9), followed by aspiration of  a
dilute nitric acid solution  into the instrument.
                             Table  2   presents   the   characteristics  of  the
                        leaded-gasoline  storage  tank  sludge  used   in   this
                        investigation. The parameters  of primary  concern with
                        respect to  the  hazardous  nature of the sludge  and the
                        process of weathering were the  organic lead  and total lead
                        concentrations of the  sludge and the pH  and total lead
                        concentration of the sludge supernatant.
                             The lead concentration shown in  Table 2 represents
                        only those  compounds which were soluble in methanol or
                        in the filterable liquid fraction of the sludge. Other organic
                        lead  compounds,  such  as  tetramethyl  lead  and  mixed
                        organic-inorganic lead species, might have been present but
                        would  have escaped  detection.  Most of the  lead  in the
                        sludge, including the organic lead, was either precipitated as
                        lead  salts or was  in some way  associated with the sludge
                        solids. At the  pH values of  the supernatant, this might be
                        predicted based on results of previous studies by Gadde and
                        Laitinen  with  hydrous  ferric oxides  (11).  These workers
                        showed  that lead  compounds in suspensions  of  hydrous
                        ferric oxides were 91 percent adsorbed at pH 8.1.  Organic
                        lead  exhibits an affinity for  the solid fraction of the sludge
                        because of the poor solubility  of TEL in water and the
                        highly aqueous nature of the liquid fraction.
                              Figure 3  shows an increasing concentration of lead
                        with decreasing particle size of the sludge. This trend can be
                        attributed to an  increased  surface area  being available for
                        adsorption or exchange reactions in the smaller particle size
                        ranges. This implies that the primary  source of lead  in the
                        sludge was  indeed  the  gasoline  and  not the walls of the
                        stoiage tank.
                                                      TABLE 1

                                    CHARACTERISTICS OF OAKLEY SAND SOIL
                                                 SIEVE ANALYSIS
Screen No.
Pore Size (mm)
Percent Retained
8
2.362
-
16
1.18
0.6
30
0.589
6.0
50
0.297
23.2
100
0.149
35.8
270
0.053
28.5
>270 (Silt & Clay)
-
6.6
                                     PHYSICAL-CHEMICAL CHARACTERISTICS
         Total Nitrogen1
         Total Carbon2
         Ion Exchange Capacity3
0.04 Percent
0.51 Percent
4.4 meq 7100 g4
3.8meq/100g5
          1  Kjeldahl
          2  Dietert Carbon Analyzer
          3  Saturation with NH^and Distillation
          4  Without peroxide oxidation
          5  With peroxide oxidation
                                                         108-

-------
                                FIGURE 1


                        CELL SIMULATING WEATHERING BED
                                  15"
25"
               PVC Tank  w/cover
                                Air Chamber
1"

3"


3"
          4"
5"


1"
1
              Air
              Inlef
Leachate
 Sampler
                      I \
                                          '
                                    0
                                   ,0
                                 Soil  Sampling
                                     Port
                                                    Air
                                                    Outlet
-Sludge



•Soil  Column
                                          •Soil Pressure
                                            Tensiometer
                                                     Monterrey
                                                    " Coarse Sand

                                                    ~Pea Gravel
                                    ^Leachate Collection
                                           Outlet
                                 -109-

-------
                          FIGURE 2

               SCHEMATIC DIAGRAM SHOWING ARRANGEMENT
                       OF EQUIPMENT USED
  Cell #3  -  Simulation of Weathering Bed
                   Particulate Filter   ^-Metering Valve

                       Carbon Tube
                                 Rotameter
'Location  of  Vertical Core Sample

 Cell #2  - Simulation of Weathering Bed
       r
                             Metering Valve

                   Carbon Tube
                Particulate      Rotameter
                  Filter
Cell #1 - Simulation  of  Water Covered Sump
                                    ,	®	
                                                Metering  Valve
                                                           Air
                                                          Vacuum
                                                          Pump
                           Water Trap
                                               Metering
                                                 Valve
    C  denotes location of horizontal soil core  sampling port
    L  denotes location of leachate sampler
    T  denotes location of pressure tensiometer
                           -110-

-------
                                        FIGURE 3
   25
•H
 D
   20
a
o


•g  15
+->

Q)
nH
rH
O

   10
                              PARTICLE SIZE DISTRIBUTION OF DRIED

                             LEADED-GASOLINE STORAGE TANK WASTE




                                 2680
                                           4550
                                                      5780
                                                                        8600
               8         16       30        50        100      200
            (2.362)    (1.18)  (0.589)   (0.297)    (0.149X  (0.074)

                               Mesh Size  (pore size  in mm)


           total  of  size  ^action collected (ppm Pb,  dry  wt.)
                                                                        >200

-------
                       TABLE 2

       CHARACTERISTICS OF LEADED-GASOLINE
               STORAGE TANK SLUDGE
PARAMETER
[Pb] org as TEL in CH3OH (ppm Pb,
dry wt.)
[Pb] total (ppm, dry wt.)
Residue after evaporation @105°C (%)**
Residue after ignition @550°C or
dry wt. (%)**
Water content by a toluene azeotroph
method (%)
pH of supernatant**
Alkalinity of supernatant as CaCO-j (ppm)
Suspended solids of supernatant (ppm)**
[Pb] total of supernatant (ppm Pb)
MEAN

96.9
5,200.0
60.0

56.0

52.5
8.2
1,590.0
302.0
4.4
RANGE*

25.2
540.0
5.0

5.0

10.0
0.5
20.0
35.0
1.8
 * Absolute range
'* (10)
      Figures  4-6 show the  results of the sampling of
airborne organic lead plotted as the log^g of the ratio of
airborne organic lead to (TLV) y£L versus time in days. The
results were presented this way to emphasize the hazard of
airborne lead and to show that in the cell that simulated a
water  covered  sump  (Cell  No. 1),  safe conditions were
attained after only 2.5 days. In the 2 cells that simulated
weathering  beds  (Cells  No. 2 and No. 3), safe  conditions
were not attained even after 30 days of weathering. The
highest concentration of airborne organic lead  attained in
Cell  No. 1  was  approximately 7  times the (TLV)j£j_,
whereas the highest concentrations in Cells No. 2 and No. 3
were 59 and 82 times the (TLV) JEL, respectively.
      Figures 7—9 show the profiles of  total and organic
lead  in  Cells No. 2 and No. 3. Apparently  there was no
significant  movement  of any form of lead in  the soil
column  of Cell  No. 3 even after inundation with water. The
presence of significant total lead, but insignificant organic
lead, in the first layer of soil suggests that some degradation
to  forms insoluble in, or  incapable of extraction  from,
methanol was taking place.  The low concentration of total
lead  in  the  sludge  supernatant  suggests  that the high
concentrations  in the first layer of  soil  are  a  result  of
particle  transport or  filtration  phenomena rather than
adsorption of soluble lead species.
      Table   3   indicates   that   weathering  under  the
conditions  of these experiments is an effective method of
detoxifying  leaded-gasoline   storage   tank  sludge.  A
90—95 percent  reduction in organic lead concentration was
achieved in 30 days with no significant change in the total
 lead content. Furthermore, although ponding may be  a
 more acceptable method of disposal of these sludges in the
 short run, it merely prolongs the process of detoxification.
      A  mass balance of the  organic lead  in the  sludge
 layers of Cells  No. 2 and No. 3 (Table 4) shows that most
 of the organic  lead is  degraded in situ by oxidation in air
and is not evaporated. Although air oxidation of pure TEL
is  slow  (12),  the  turbulent  mixing conditions in  the air
chamber and  surface  phenomena might serve to catalyze
that reaction.  Although TEL in the gas and liquid phases is
known  to  decompose  by  ultraviolet  photolysis,  such
decomposition was prevented  in  these experiments by
covering the cells to exclude light.
     The rates of  detoxification  of TEL  sludge  under
laboratory  conditions do  not  compare  directly  with the
rates under  field conditions. The contributions of sunlight
and  higher  wind  velocities to  the  degradation  process
should  result  in much higher rates under field conditions.
Thus, the rates under laboratory conditions should be taken
as minimum rates. However, caution must be employed in
using these rates because they are average rates.
      Based on the  data  obtained  in  the  laboratory,  a
mechanism of detoxification of leaded-gasoline storage tank
sludge by weathering can be proposed. Upon application of
sludge to soil, the free liquid fraction rapidly leaches into
the soil displacing the soil water. The soil acts primarily as a
filter, retaining the solid fraction of the sludge and allowing
the  liquid  fraction  to pass into the soil. Because  lead  is
associated  with  the  solid  fraction  of the sludge,  it  is
retained by the soil.  Based  on the profiles for lead in soil
shown  in  Figures 7—9, the lead  is  retained within  the
one-inch depth of soil nearest the  surface. As the aqueous
fraction of the sludge is leached, the volatile organic lead
associated  with the solids fraction evaporates. The volatile
organic lead  evaporates rapidly from the surface  of the
sludge  and   contributes  to the high  concentrations  of
airborne organic lead observed during the  first few days of
weathering.  Thereafter, the rate of evaporation decreases
 and is  controlled by the diffusion  of vapors of organic lead
 through the  sludge  layer. Degradation  by  oxidation  is
 controlled by the diffusion  of air into the sludge layer and
 might  be  catalyzed by the surface effects  of the sludge
 solids.  Apparently  the  rate of detoxification exceeds the
 rate of evaporation of organic lead  from  the sludge, and
 weathering can  be viewed  primarily as a  combination of
 these 2 processes.

 CONCLUSIONS

      The weathering method recommended by the A.P.I.
 and  modeled in this  laboratory study appears to be an
 effective  method   of   treatment   and/or  disposal   of
 leaded-gasoline storage tank sludge.  The potential hazard
 posed  by organic lead in the sludge is substantially reduced
 by  evaporation and degradation, and the application of the
 sludge to Oakley sand soil does  not appear to pose a threat
 to the  quality of  ground water.
       The potential health  hazard of airborne organic lead
 is  expected  to  be much less  significant under  field
 conditions than under laboratory conditions. However, one
 cannot conclude that such a potential health hazard will
 not exist in the vicinity of a sludge bed during the first few
 days of weathering unless he has  results from a pilot field
 study  to support this conclusion.
                                                        -112

-------
                                      FIGURE 4

                            RATIO OF AIRBORNE ORGANIC LEAD TO
                              THRESHOLD LIMIT VALUE (TLV) OF
                             TETRAETHYL LEAD (TEL): CELL NO. 1
   1.000
   0.750
a
EH
   0.500
ri

d
•H
 fcJD
   0.250
g>      0
  -0.250
                                    Notes:

                                    (TLV)TEL = 0.075 mg/m3

                                    Control  cell simulating water covered  sump
                    i
                   5
                            10
 T
15
         20

Time  (days)
T
25
30
 i
35

-------
                                     FIGURES


                           RATIO OF AIRBORNE ORGANIC LEAD TO
                            THRESHOLD LIMIT VALUE (TLV) OF
                           TETRAETHYL LEAD (TEL): CELL NO. 2
    2.00
W
£   1.50
d
•H
 bfl
 $H
 O
    1.00 -
    0.50
bfl
O
       0
   -0.50
                   T
                   5
                            10
                                       Notes:

                                        (TLV)TEL =  00075mg/m3

                                       Simulation  of weathering bed
 i
15
          20

Time  (days)
25
30
35

-------
                                         FIGURES


                               RATIO OF AIRBORNE ORGANIC LEAD TO
                                THRESHOLD LIMIT VALUE (TLV) OF
                               TETRAETHYL LEAD (TEL): CELL NO. 3
    2.00
 w
 3
 fn
 •H
 c  1.00
 •PI
  blD
  O

!fi!
 fafl
       0
   -0.50
                                        Notes:
           (TLV)TEL =  0.075mg/m3

           Simulation  of weathering bed
                   I
                   5
I
10
 I
15
 I
20
 I
25
 i
30
 I
35
                                       Time  (days)

-------
0
                  FIGURE 7
   TOTAL LEAD RETAINED IN SOIL COLUMN: CELL NO. 2

[Pbl .   .  ,  in Soil Column(ppm Pb, dry wt.)
L  J total
  10        20        30         40        50
                                                             60
U-l
1-2
2-3
U)
0
1 3-4
•H
c
I— 1
<3 4-5
rH
•H
O
CO
o 5-6
0)
Q
6-7

7-8
8-9
i
-

—


—



—

-
.
i I ^^,^^1 '
/©
— 1 	 ^

/ Data Summary
1 Layer Mean Range*










<
© 0"-1" 57.1ppm 3.9ppm
l"-2" 13.1 11.1
2"-3" 16.5
3"-4" 16.6
0 4ff-5" 15.2
5"-6" 10.7
6" -7" 14.3
7fl-8ft 14.4
8"-9" 14.0
* Absolute Range
8.5
7.5
2.0
5.1
3.2
0.9
3.5

5 Background [Pb] totalin Soil
Mean 12.0ppm
Std.Dev. 2.3ppm
5
•i




                            116-

-------
   0-1
   1-2
   2-3
§  3-4:
•H
fl
S
o  4-5
•H
O
03
0)
a
   5-6
                              FIGURE 8
                 TOTAL LEAD RETAINED IN SOIL COLUMN: CELL NO. 3


                        in Soil Column  (ppm  Pb,  dry wt.)
   6-7
                                                Data Summary
Layer   Mean
2"-3"
3"-4"
4M-5"
5"-6"
6"-7"
7"-8M
8"-9"
61.7ppm
17.6
11.6
12.1
12.0
13.3
14.8
15.9
19.5
                                                          Range*
9.2ppm
3.6
3.9
2.1
2.6
3.0
2.0
2.7
5.8
*Absolute Range
Background [Pb] totalin
Mean     12.0ppm
Std.Dev.  2a3ppm
   7-8
   8-9
                              - 117-

-------
                              FIGURE 9

            ORGANIC LEAD RETAINED IN SOIL COLUMNS: CELLS NO. 2 AND NO. 3
       0
             [Pb]
                org
(ppm Pb, dry wt.)
                       10
CO
3
rH
O
•H
O
CO
   2-3< i-
   3-46-
p,
o 5-6<
       Not es:

       O Cell #2

       XCell #3
        [Pb] Q   w/respect to TEL in  CHgOH

        [Pb] org @  zero depth is concentration
                   in weathered sludge

        [Pb]    in sludge before weathering
             ^     96.9ppm w/respect  to TEL
                   in CH3OH

           org background in soil
                   not detectable
   7-84
   8-9®-
                               -118-

-------
                                   TABLE 3

                     CHARACTERISTICS OF LEADED-GASOLINE
                         STORAGE TANK SLUDGE BEFORE
                            AND AFTER WEATHERING


[Pb] org as TEL in CH3OH (ppm Pb, dry wt )
[Pb] total (ppm Pb, dry wt )
Dry weight (%)
Organic lead of settled sludge in
cell simulating water-covered
sump as TEL in CI-^OH (ppm Pb, dry wt )
BEFORE
Mean
96.7
5,700.0
56.1


N/A**
Range*
25.2
250.0
2.0


N/A
AFTER
Mean
5.6
5,690.0
69.7


116.0
Range*
2.9
240.0
2.0


13.0
 * Absolute range
** Not applicable
                                    TABLE 4

               MASS BALANCE OF ORGANIC LEAD IN LEADED-GASOLINE
                STORAGE TANK SLUDGE SUBJECTED TO WEATHERING

Mass of organic Pb applied to the soil
Mass of organic Pb evaporated during 30-day period
Mass of organic Pb in weathered sludge
Mass of organic Pb degraded to inorganic Pb
Percent of organic Pb degraded to inorganic Pb
Average rate of degradation of organic Pb
Percent detoxification of sludge
Average rate of detoxification
Average rate of detoxification per unit mass of sludge
CELL NO. 2
450 mg
42 mg
32 mg
376 mg
84 percent
1 3 mg /day
93 percent
14 mg /day
2.7 mg /day-kg *
CELL NO. 3
450 mg
53 mg
26 mg
371 mg
82 percent
1 2 mg /day
94 percent
14 mg /day
2.7 mg /day-kg *
   Dry weight of sludge applied to the soil.
                                       119

-------
      According to  the results  of this laboratory study,
weathering appears  to  be  an  effective and economical
method for treatment and/or disposal  of  leaded-gasoline
storage tank  sludge.  Weathering diminishes the  potential
health hazard of organic lead within about 30 days, whereas
ponding permits the sludge to remain extremely hazardous
for considerably longer periods  of time. The weathering
method is simple and inexpensive with respect  to labor,
capital, and  land  costs.  It can  result in  a savings of
50 percent or more in disposal  costs  each time  a storage
tank  is cleaned because  evaporation  and drainage of the
aqueous  fraction  reduces the  volume  or  weight of the
sludge.  If costs of disposal  are partially  based  on the
hazardous nature of the waste, additional savings can result
due to  detoxification of the sludge.
      The weathered sludge can  ultimately be disposed of
at sites authorized to receive  such wastes, provided that
incompatibility  with   other   wastes  is   taken   into
consideration.  In  particular, runoff  water of low pH or
acidic  wastes  should  be prevented from mixing  with the
buried  weathered  sludge because such water or wastes will
extract lead  from the sludge. For this reason, weathered
sludge  should be treated as if it were a hazardous waste.
                    REFERENCES CITED

  1.  Anonymous.  1968.  Recommended  practice  for  cleaning
          petroleum  storage  tanks. A.P.I.  RP  2015.  American
          Petroleum  Institute, Committee  on Safety  and  Fire
          Protection, Washington, DC.

  2.  California State  Department  of Health. 1975. Hazardous waste
          management:  law,  regulations and  guidelines for the
          handling of hazardous  wastes. Sacramento, California.
          74 p.
3.  Faith, W. L., D. B. Keyes, and R. L. Clark. 1966. Industrial
        chemicals.  John Wiley and Sons, Inc., New York. 852 p.

4.  Sax, N. I. 1968. Dangerous properties of industrial materials.
        Van Nostrand-Reinhold Company, New York. 1,251 p.

5.  Anonymous. 1963. Methods of analysis.  Sanitary Engineering
        Research Laboratory, University of California, Berkeley.
        157 p.

6.  Snyder, L. J. 1967. Determination of trace amounts of organic
        lead in air.  Anal. Chem. 39  (61:591-595.

7.  Klein, S. A., D. Jenkins, R. J. Wagnet, J. W. Biggar, and M.S.
        Yang.  1974.  An   evaluation  of  the accumulation,
        translocation  and  degradation of  pesticides  at  land
        disposal sites. Sanitary Engineering Research Laboratory,
        University  of California, Berkeley. 218 p.

8.  Anonymous. 1974.  Tank   cleaning manual: Lead  hazard
        aspects of cleaning  leaded-gasoline storage tanks. Ethyl
        Corporation,  Petroleum Chemicals  Division,  Houston,
        Texas.

9.  Anonymous. 1969. Determination of total  lead in water and
        water bottom deposits. Manual on  disposal of refinery
        wastes.  Vol. IV.   A.P.I.  Method  747-63.  American
        Petroleum  Institute,     Division  of Refining,
        Washington, DC.

10.  Anonymous. 1971. Standard methods for the examination of
        water  and  waste-water.   American  Public  Health
        Association, American  Water Works Association, Water
        Pollution Control Federation, New York. 847 p.

11.  Gadde, R. R., and H. A. Laitinen.  1973. Study of the sorption
        of  lead by  hydrous ferrous  oxides.  Environ.  Letters 5
        (4): 223-235.

12.  Shapiro, H., and F. W.  Frey. 1968. The organic compounds of
        lead. John Wiley and Sons, Inc., New York, 486 p.
                                                          -120

-------
                      SELECTION OF ADSORBENTS FOR IN-SITU LEACHATE TREATMENT

                                            P. C. Chan1, J. W. Liskowitz1,
                                             A.J. PernaVM. J.Sheih1,
                                          R. B. Trattner1, and F. Ellerbush2
INTRODUCTION

     The passage  of the  Federal Water Pollution Control
Act of 1972 established a national policy of no discharge of
pollutants  to receiving  waters by 1985. Consequently,
industry  will face  the task of developing  new technology
for the safe disposal of hazardous sludges generated during
the treatment of industrial wastes. The method most often
used for disposal of industrial sludges has been  burial in a
sanitary landfill. However, the disposal of  these  sludges by
landfilling  could  result in contamination of ground and
surface waters by  pollutants present in the liquid portions
of the wastes. In addition, pollutants could be transported
to ground or surface waters as a result of leaching caused by
infiltration of ground water or percolation  of rainwater (1).
     There  are no methods that enable one  to predict
accurately  the amount,  direction, and rate of flow of
leachate  in soils in  and around a landfill (2). One potential
solution  to the problem of leachate production would be to
isolate the soil of a landfill from its  immediate surroundings
and  to direct in some predetermined fashion the flow of
any  leachate produced. Isolation could be  accomplished by
lining the  bases and sides  of a landfill with compacted,
low-permeability  loess soil, thereby preventing movement
of ground  water into the  landfill.  Polyvinyl chloride and
butyl rubber liners could  also be used for  this purpose (3).
However, the use  of a liner would  not prevent percolation
of rainwater and would create a "bathtub without a drain"
unless the lined landfill had been  designed to channel the
leachate generated by rainwater. A lined  landfill could be
drained by utilizing gravity outlets, such as drainage tiles or
perforated corrugated metal  pipe, installed in  the  lowest
portion or along the base of the landfill to collect leachate
(4,5).  However, treatment of the collected leachate would
probably  be required to  reduce the concentrations of
pollutants to levels acceptable for  discharge, provided that
appropriate  technology for  such  treatment was available.
Such improvements would,  of  course, add to the costs of
construction and operation of a landfill.
      One of the  possible  solutions  to  the  problem  of
removing hazardous materials from leachate collected from
a lined landfill would eliminate the need for treatment of
the  leachate. The  basis for this solution  is adsorption. In
essence, the approach would be to line a landfill with an
inert,  impermeable membrane and to remove the leachate
from the landfill by allowing it to percolate through a bed
of  inexpensive   material(s)   whose  characteristics
satisfactorily  reduce  the  concentration  of  pollutants,
thereby preventing contamination  of  ground and surface
waters.  This paper  describes the results of a laboratory
study  of  adsorbents  for  in-situ  treatment  of landfill
leachate.

MATERIALS AND METHODS

      A laboratory study  was conducted  to evaluate the
effectiveness of 10  natural  and  synthetic adsorbents for
removing   contaminants  in  leachate  generated  from  3
different  industrial sludges. The  sludges chosen for study
were: a calcium fluoride sludge  of the type generated by
the electronics and  aircraft  industries;  a  metal finishing
sludge; and a petroleum sludge. These sludges were selected
because:  their annual production is of sufficient magnitude
to present disposal problems; and the  leachates from  these
sludges contain representative hazardous materials such  as
various organic compounds, heavy metal hydroxides,  toxic
anions  (e.g., cyanide),  and substantial quantities  of  fairly
soluble toxic salts (e.g., calcium fluoride). The  adsorbents
chosen  for study  were fly ash, bottom  ash, Ottowa  sand,
activated  carbon,  illite,  kaolinite,   vermiculite,  natural
zeolites,  cullite, and activated  alumina (mesh  size <325;
48-100 and < 100).
      Studies simulating static conditions  were  conducted
to  evaluate the adsorption and exchange capacities of the
adsorbents using maximum concentrations of contaminants
in  leachate. These studies were followed  by  studies
simulating  dynamic  conditions to  obtain information
regarding the capacities and permeability characteristics  of
these adsorbents. The leachates produced during the  static
and  dynamic  studies  were tested  for  pH, conductivity,
 residue, chemical oxygen demand (COD), total  organic
carbon (TOO, anionic species, and cationic species before
 and after contact with the adsorbents.

 Preparation of Adsorbents

      All  adsorbents   were  used  as  received  from  the
 supplier.  However,  adsorbents which  were not obtained in
 powdered form  (i.e., illite, bottom  ash,  and vermiculite)
 were  ground  and  passed through an  8-mesh  American
 Society  of Testing  Materials (ASTM) standard sieve. All
 adsorbents were  dried to constant  weight  at 103 C in
 accordance with standardized methods  (6) and  stored in a
 dessicator until used.
 1   Environmental Systems Instrumentation Laboratory, New Jersey Institute of Technology, Newark, New Jersey.
 2   Industrial Environmental Research Laboratory, Environmental Protection Agency, Edison, New Jersey.
                                                        -121

-------
Preparation of Leachate from Adsorbents
Sources of Adsorbents
      Mixtures  of  deionized  water  and  each  of  the
adsorbents were prepared in the ratio of 2.5 ml  of water
per gram of adsorbent and were agitated in a Bur re 11 shaker
for 24 hours  at ambient temperature. Preliminary studies
had revealed that saturation of each mixture with respect to
total  dissolved  solids  was  achieved  in  24  hours. The
resultant mixture was then filtered using a glass fiber filter
(Reeve Angel type 934A) to remove undissolved solids. The
filtrate (leachate) was then stored in a screw-capped plastic
bottle at ambient temperature until used.

Preparation of Leachate from Sludges

      A sample of each of the 3 types of sludge was dried at
103°C to determine its moisture content. Samples of each
unaltered sludge were then mixed with deionized water in a
ratio  of  2.5 ml  of water per gram of dried sludge (taking
into account the moisture content of the unaltered sludge)
and were  mechanically stirred for 24 hours. The ratio of
water to  sludge was selected because preliminary studies
(using various quantities of  water in  the  mixture) had
indicated that a maximum concentration of pollutants in
the leachates  from the sludges was achieved at that ratio.
After being stirred, each mixture  was filtered through a
glass  fiber filter  (Reeve  Angel  type 934A).  The filtrate
(leachate)  was then stored in a screw-capped plastic  bottle
at ambient temperature until used.

Studies Simulating Static Conditions

      One  hundred grams of dried adsorbent was  weighed
in  a  tared  one-liter,   screw-capped  polypropylene
Erlenmeyer flask, and 250 ml  of sludge leachate was added
to the flask. The flask was then sealed and agitated for 24
hours at ambient temperature. After agitation, the mixture
was filtered through a glass fiber filter,  and the filtrate
(leachate)  was stored  in a sealed plastic flask at ambient
temperature until analyzed.

Studies Simulating Dynamic Conditions

      A lysimeter constructed of plexiglass tubing (5.8 cm
1.0.;  0.6cm   wall  thickness; 90cm length)  was packed
with  550 g of adsorbent (250 g  if activated carbon was
used  as the adsorbent) supported by a porous corundum
disk (6.5cm  diameter; 0.6cm  thickness). Leachate was
permitted to flow into the top of the lysimeter and through
the adsorbent under constant hydraulic pressure. Samples
of  effluent  (leachate) were  collected  at  regular time
intervals  and  analyzed. At  the conclusion of a  test,  the
spent adsorbent  was  washed  and  the washings  were
analyzed  for  contaminants;  these analyses  provided  a
measurement  of  the ability  of  the adsorbent  to  retain
contaminants.
      The adsorbents selected for study were the following:

           Zeolite: Obtained  from  the Buckhorn Mine,
           New  Mexico, and  supplied by Double Eagle
           Petroleum   and  Mining   Company,  Casper,
           Wyoming.

           Cullite (H1-capacity cullite; 16—40 mesh; white
           particles): Supplied by Culligan USA, Culligan
           International Company,  Northbrook,  Illinois.

           Illite: Obtained  from A. P. Green Refractory
           Company's Morris Plant, Morris, Illinois.
           Kaolinite:  Supplied   by  Georgia
           Company, Elizabeth, New Jersey.
Kaolin
           Vermiculite:  Obtained from  W.  R. Grace  &
           Company, Trenton, New Jersey.

           Bottom Ash  and Fly Ash:  Supplied by Public
           Service  Electric  & Gas  Company's  Hudson
           Generating Station, Jersey City, New Jersey.

           Activated  Carbon (Grade 718): Obtained from
           Witco  Chemical, Activated  Carbon Division,
           New York, New York.

           Activated  Alumina:  Supplied by Alcoa, Morris
           Plains, New Jersey.

RESULTS AND DISCUSSION

      Comprehensive analyses using emission spectroscopy
and  X-ray  fluorescence  techniques  were  performed  in
accordance  with standardized  methods  (6)  on leachates
generated from 2 calcium fluoride sludges, 2 metal finishing
sludges, and one petroleum sludge. Analyses were  initially
performed for  the  following heavy  metals:  copper, iron,
nickel,  lead, zinc, chromium,  and cadmium. Subsequent
analyses were  performed for calcium and magnesium ions
(which  contribute to  hardness  in water)  and for fluoride,
chloride,  and   cyanide  ions (which,  if  present  in  high
concentrations, could  cause rejection of raw water  supplies
as potential sources of drinking water).

Studies Simulating Static Conditions

     The data  pertaining to this portion  of the study have
been reported elsewhere (7)  and will only be summarized
here.   These  data yielded  the  following  information
regarding the sludges studied:

     Calcium Fluoride Sludge

           Analyses of leachate from the calcium  fluoride
     sludge showed significant concentrations of calcium,
     magnesium, copper,  fluoride, chloride, and  cyanide
     ions. Also, significant levels  of organics as indicated
     by COD and TOC values were detected.
                                                      - 122-

-------
                                              TABLE 1

              PERCENT OF INDICATED CONTAMINANTS REMOVED FROM LEACHATES
                OF TWO CALCIUM FLUORIDE SLUDGES BY SELECTED ADSORBENT
                             MATERIALS UNDER STATIC CONDITIONS
MEASURED
PARAMETERS
Leachate No. 1
COD
TOC
Ca
Cu
Mg
F~
cr
CN~
Leachate No. 2
COD
TOC
Ca
Cu
Mg
F~
cr
CN~
ADSORBENTS
Bottom
Ash

0
100
4
55
0
58
0
20

0
100
29
59
0
58
0
0
Fly
Ash

49
100
0
91
91
64
0
7

42
100
0
67
34
61
0
0
Zeolite

0
13
66
77
0
73
0
10

0
2
76
59
0
65
0
0
Vermiculite

30
34
0
68
0
3
14
17

25
6
13
41
0
9
0
0
(Kite

37
100
16
0
0
90
32
75

55
100
18
0
0
85
10
62
Kaolinite

0
0
11
0
0
49
15
0

0
0
37
0
0
40
5
0
Activated
Alumina
(1)

0
1
100
91
95
74
0
20

0
2
100
57
96
79
0
0
Activated
Alumina
(ID

0
0
100
68
90
70
0
12

0
0
99
53
66
72
0
0
Cullite

0
0
100
0
73
67
0
0

0
0
100
14
92
67
0
0
Activated
Carbon

85
69
18
73
86
20
0
83

98
40
100
84
78
18
14
76
     The   results,   based   on   micrograms  of
contaminant removed per gram  of  adsorbent  used,
indicated that  adsorbents which effectively removed
the  specific  ions  studied   tended  to  remove
approximately   the  same  amounts  of those  ions.
Therefore, the adsorption  capacities of the effective
adsorbents were similar.
     Table  1  shows  the  percent of contaminants
removed from  the  leachate by  various adsorbents.
These results indicate that:

•  No  single adsorbent was  effective  in  removing
   from the leachate all of the various contaminants
   studied. However, all of the contaminants except
   chloride  could  be  effectively removed by one
   adsorbent. A combination  of  2  or  3 adsorbents
   could remove virtually  all  contaminants in the
   leachate.

•  Of the naturally occurring adsorbents, illite and
   zeolite were the  most effective  for  removing
   fluoride  from  the  leachate.  Of the  synthetic
   adsorbents, activated alumina  and cullite were the
   most effective for removing fluoride. Illite (natural
   adsorbent)   and  activated   carbon  (synthetic
   adsorbent) were the only adsorbents  capable of
   reducing the  levels of  cyanide  in  the leachate.
   Removal   of  calcium   ion   was  dramatically
   accomplished  by the synthetic adsorbents, cullite
   and activated alumina. Regarding the  natural
   adsorbents,  only  zeolite  removed  a  significant
   amount of calcium.

•  None  of  the  adsorbents  effectively removed
   chloride ion  from the  leachate.  However, the
   concentration  of   chloride   remaining   in  the
   leachate,  i.e., 78mg/l  and  59 mg/I , were  well
   within acceptable  levels set by the  United States
   Public  Health Service  (250 mg /I )  for  drinking
   water  supplies.  Consequently,  the  chloride
   concentration would present no problem.

Metal-Finishing Sludge

      Analyses of leachate  from  the metal-finishing
sludge indicated potentially high concentrations of
nickel, fluoride, and  chloride  ions. The following
results were found (Table 2):
                                                - 123-

-------
                                           TABLE 2

           PERCENT OF INDICATED CONTAMINANTS REMOVED FROM LEACHATES
              OF TWO METAL FINISHING SLUDGES BY SELECTED ADSORBENT
                          MATERIALS UNDER STATIC CONDITIONS
MEASURED
PARAMETERS
Leachate No. 1
COD
TOC
Ca
Mg
Ni
F~
cr
Leachate No. 2
COD
TOC
Ca
Mg
Ni
f~
cr
ADSORBENTS
Bottom
Ash

0
79
0
0
20
0
0

19
13
0
0
0
0
0
Fly
Ash

40
42
0
6
47
0
0

13
5
0
80
17
0
0
Zeolite

0
18
0
0
0
0
0

68
66
0
0
0
0
0
Vermiculite

21
48
0
0
47
0
16

53
3
41
25
33
0
0
Illite

49
92
60
0
0
72
39

72
88
0
0
0
76
36
Kaolinite

0
0
0
89
67
72
24

47
62
0
85
33
66
4
Activated
Alumina
(1)

0
0
97
99
50
0
0

0
0
99
100
50
0
0
Activated
Alumina
(ID

0
0
99
99
67
0
0

0
0
99
100
58
4
0
Cullite

0
0
100
96
0
64
0

15
0
99
96
0
74
0
Activated
Carbon

98
87
74
84
67
19
0

100
97
81
65
58
22
51
No single  adsorbent  material  was effective in
removing   from  the  leachate   all  of  the
contaminants studied.  However, a combination of
2  or  3   adsorbents  effectively   reduced  the
concentrations of all contaminants studied except
chloride ion.

Of the natural adsorbents, only illite and kaolinite
effectively  reduced the fluoride concentration in
the  leachate.  Of   the   synthetic  adsorbents,
activated alumina and activated carbon effectively
removed nickel ion. To a lesser extent, the natural
adsorbents  vermiculite and  kaolinite  were  also
effective in removing  nickel  ion.  Only illite (a
natural  adsorbent) was moderately successful in
reducing the  concentration  of  chloride ton in
leachate. Illite removed 36  and 39 percent of the
chloride  ion  from leachates  of 2  metal-finishing
sludges,  respectively.  The   concentrations of
chloride  ion  remaining    met   the  standard
acceptable for raw water supplies.
Petroleum Sludge

     Analyses of leachate from the petroleum sludge
indicated  high  levels  of  COD,  TOC,  calcium,
magnesium,  nickel,  lead,  fluoride,  chloride,  and
cyanide. The following results were found (Table 3):

•  Of the synthetic adsorbents, activated carbon was
   the most effective in lowering both COD and TOC
   levels in the leachate. Of the natural adsorbents,
   illite was the most effective.

•  All  of  the  synthetic  adsorbents effectively
   removed calcium and  magnesium ions from  the
   leachate.   None   of   the   natural  adsorbents
   appreciably  reduced  the  concentration   of
   magnesium  ion; illite was moderately effective in
   reducing the concentration of calcium ion.

•  The  natural  adsorbents   illite   and  kaolinite
   effectively removed fluoride ion from the leachate.
   The synthetic adsorbent  activated carbon  was
   effective to a lesser extent.
                                              -124-

-------
                                                   TABLE 3

                    PERCENT OF INDICATED CONTAMINANTS REMOVED FROM LEACHATE
                       OF PETROLEUM SLUDGE BY SELECTED ADSORBENT MATERIALS
                                         UNDER STATIC CONDITIONS


MEASURED
PARAMETERS
COD
TOC
Ca
Mg
Ni
Pb
Zn
F~
cr
CN~
ADSORBENTS

Bottom
Ash
19
25
0
0
0
0
50
40
39
63

Fly
Ash
19
27
0
1
17
0
50
15
44
38


Zeolite
22
23
0
11
0
0
33
32
39
63


Vermiculite
22
25
0
3
9
0
50
4
45
57


Illite
50
59
51
7
0
0
0
85
72
83


Kaolinite
14
26
4
4
0
10
0
89
63
33
Activated
Alumina
(1)
18
29
99
100
44
10
67
70
42
33
Activated
Alumina
(II)
12
19
100
99
44
10
67
67
55
10


Cullite
13
17
94
90
4
10
33
42
50
10

Activated
Carbon
92
95
89
91
26
0
67
89
75
96
     •  Activated carbon (synthetic) and to a lesser extent
        illite (natural) were the most effective in removing
        cyanide  ion from  the leachate.  However,  only
        activated carbon was effective in reducing cyanide
        ion to a concentration acceptable for raw drinking
        water purposes.

     •  Activated   alumina  was  the   only  synthetic
        adsorbent   that  was   moderately  effective  in
        removing nickel ion, whereas ash  appeared  to be
        the most effective natural adsorbent for removing
        that ion.

     •  All  of  the  synthetic  and  natural  adsorbents
        provided  only  limited   reduction   in  the
        concentration of lead ion.

     •  All  of  the adsorbents studied  removed  some
        chloride (illite and activated carbon  were  most
        effective).   However,  the chloride  concentration,
        10,990mg/l,  was so great  that  90 percent  or
        more would have to have been removed to achieve
        a concentration  of chloride  acceptable for raw
        water supplies.

Studies Simulating Dynamic Conditions

      Data  generated  from the  studies simulating  static
conditions served only to  determine  the  potential  of an
adsorbent for  removing ions  from leachate. To simulate
field conditions more closely, laboratory  studies using
lysimeters were  undertaken to test the  more promising
adsorbents: bottom ash, fly ash (acidic and  basic types),
vermiculite, illite, and kaolinite of the natural adsorbents;
and activated alumina and activated carbon of the synthetic
adsorbents.
     One problem encountered with vermiculite, illite, and
kaolinite was their poor permeability.  To overcome  this
problem these  materials  were  mixed  with  Ottawa sand
(20 percent adsorbent, 80 percent sand)  and then poured
into the lysimeters.
     Because  of  the  large  number  of  measurements
required for the studies using lysimeters, the analyses of the
leachates were restricted to testing for those constituents
whose  concentrations  were  significantly  higher than the
minimum   measurable  concentration  or  exceeded  the
standards  for raw water.  For example, the concentrations
of   chloride  ion  in  the   leachates   prepared  from
metal-finishing sludge (No. 3) and petroleum sludge (No. 2)
were  not  measured  in   lysimeter  tests  because  those
concentrations did not exceed 250 ppm. The concentration
of cadmium in  the leachate from calcium fluoride  sludge
(No. 3)  was not measured because it did not exceed the
minimum  measurable limit of 0.01 ppm.
     Tables  4  through   9 present data  regarding  the
leachate added  to the lysimeters  and  compare  results
obtained from the studies  simulating static conditions with
those  obtained  from the  studies  simulating  dynamic
conditions.  Examination  of  Tables  4—9 indicates  that
greater removal of contaminants, defined as  micrograms of
ion removed per gram of adsorbent  used,  was achieved
                                                     - 125-

-------
                                                      TABLE 4
                  CHEMICAL CHARACTERISTICS OF LEACHATE FROM CALCIUM FLUORIDE SLUDGE (NO. 3)
           BEFORE AND AFTER TREATMENT WITH SELECTED ADSORBENT MATERIALS UNDER STATIC CONDITIONS
MEASURED
PARAMETERS
pH
Conductivity
Ca (mg./l.)
Cd (mg./l.)
Cr (mg./l.)
Cu (mg./l.)
Fe (mg./l.)
Mg (mg./l.)
Ni (mg./l.)
Pb (mg./l.)
Zn (mg./U


CN~ (mg./l.)
COD (mg./l.)
TOC (mg./l.)
INITIAL
CONDITION
OF
LEACHATE
,2
1,680
318
<0.01
<0.20
0.10
<0.05
21.3
0.15
<0.20
0.18
6.7
65.0
0.05
44.0
16.0
DESCRIP-
TION*
(1)
(2)
(1)
(2)
(1)
(2)
(3)
(1)
(2)
(3)
(1)
(2)
(3)
(2)
(3)
(1)
(2)
(3)
(1)
(2)
(3)
(1)
(2)
(3)
(1)
(2)
(3)
(1)
(2)
(3)
(1)
(2)
(3)
(1)
(2)
(3)
(1)
(2)
(3)
(1)
(2)
(3)
(1)
(2)
(3)
ADSORBENT MATERIALS
Bottom
Ash
7.2
6.9
2,780
4,160
20.0
275
108
<0.01
<0.01
<0.20
<0.20
0.25
0.10
L
<0.05
<0.05
93.2
90.0
L
<0.05
0.15
0
<0.20
<0.20
<0.01
0.14
0.10
0.31
3.0
9.3
500
550
0
0.07
0.06
L
40.0
80.0
0
0
10.0
15.0
Fly
Ash
(Acidic)
5.1
5.4
3,150
3,800
357
344
L
<0.01
<0.01
0.50
<0.20
0.29
0.34
L
<0.05
<0.05
64.4
98.0
0
1.40
1.55
0
0.30
0.30
0
1.6
1.8
0
1.7
7.5
L
10.0
70.0
0
0.04
0.04
0.03
<2.0
<2.0
105
0.50
0.70
38.3
Fly
Ash
(Basic)
10.1
9.8
2,090
2,430
300
337
U
<0.01
<0.01
0.50
<0.20
<0.06
0.06
0.10
<0.05
<0.05
3.2
4.0
43.3
<0.05
<0.05
0.25
0.28
<0.20
<0.01
0.28
0
1.7
1.5
13.0
9.5
45.5
48.8
<0.03
<0.03
0.05
4.8
14.8
73.0
4.1
8.0
20.0
Vermiculite
9.3
8.2
115
1,120
1.5
266
65.0
<0.01
<0.01
<0.20
<0.20
<0.03
0.09
0
<0.05
<0.05
4.7
69.0
0
<0.05
0.50
0
<0.20
<0.20
<0.01
<0.01
2.1
1.2
7.2
L
2.9
60.0
5.0
<0.03
<0.03
0.02
13.0
39.9
4.1
2.7
20.5
0
lllite
3.0
3.2
4,460
2,360
2.5
325
0
<0.06
<0.01
0.70
<0.20
3.6
0.10
L
2.20
0.60
L
70.0
34.0
L
0.65
0.49
L
0.33
<0.20
1.5
0.74
L
0.33
0.31
79.9
2.7
40.0
313
<0.03
<0.03
0.25
15.8
22.9
264
0
10.3
71.3
Kaolinite
5.1
4.5
295
1,600
42.0
250
85.0
<0.01
<0.01
0.30
<0.20
0.16
0.27
0
<0.05
<0.05
4.9
23.5
0
<0.05
0.13
0.25
<0.20
<0.20
0.27
0.28
L
2.3
0.32
79.9
6.8
50.0
188
1.2
1.2
0
7.0
40.5
43.8
15.5
21.3
L
Activated
Alumina
(I)
9.8
9.8
2,790
3,490
<0.10
<0.10
795
<0.01
<0.01
1.1
>0.50
0.04
0.04
0.15
<0.05
<0.05
0.06
0.10
53.0
<0.05
<0.05
0.25
<0.20
<0.20
<0.01
<0.01
0.43
2.3
1.2
13.8
46.0
89.0
L
0.22
0.25
0
24.0
49.5
L
37.6
20.0
L
Activated
Carbon
9.4
8.7
575
1,000
0.50
208
275
<0.01
<0.01
<0.20
<0.20
<0.03
0.09
0.25
<0.05
<0.05
0.10
12.8
21.3
<0.05
<0.05
0.25
<0.20
<0.20
<0.01
<0.01
0.43
0.04
5.2
3.8
5.0
75.0
0
<0.03
<0.03
0.05
<2.0
2.5
104
5.1
1.3
36.8
MINIMUM
DETECTABLE
VALUE
-
-
0.10
0.01
0.20
0.03
0.05
0.05
0.05
0.20
0.01
0.02
2.0
0.03
2.0
-
(1) Concentration in adsorbent material (mg /I )
(2) Concentration in leachate after treatment (mg /I )
(3) Micrograms of contaminant removed per gram of adsorbent used.

Represents no adsorbent capacity and a reduction in leaching of contaminant when adsorbent mixed with leachate.
                                                       -126-

-------
                                                                         TABLE 5
                                   CAPACITIES* OF SELECTED ADSORBENT MATERIALS FOR REMOVING CONTAMINANTS
                         FROM LEACHATE OF CALCIUM FLUORIDE SLUDGE UNDER STATIC AND DYNAMIC  (LYSIMETER) CONDITIONS
MEASURED
PARAMETERS

Ca



Cd



Cu



Mg



Ni



F~



Ci~



CN~



COD



TOC


DESCRIPTION
Static Test #1
Static Test #2
Static Test #3
Lysi meter Test
Static Test #1
Static Test #2
Static Test #3
Ly si meter Test
Static Test #1
Static Test #2
Static Test #3
Lysi meter Test
Static Test #1
Static Test #2
Static Test #3
Lysimeter Test
Static Test #1
Static Test #2
Static Test #3
Lysimeter Test
Static Test #1
Static Test #2
Static Test #3
Lysimeter Test
Static Test #1
Static Test #2
Static Test #3
Lysimeter Test
Static Test #1
Static Test #2
Static Test #3
Lysimeter Test
Static Test #1
Static Test #2
Static Test #3
Lysimeter Test
Static Test #1
Static Test #2
Static Test #3
Lysimeter Test
ADSORBENT MATERIALS
Bottom
Ash
37.5
260
108
—
0.18
—
—
—
0.30
0.73
L
—
L
L
L
0
0.18
0.13
0
—
9.0
8.5
9.3
39.4
L
L
0
—
0.30
0
L
—
L
L
0
100
0
0
15.O
42.0
Fly
Ash
(Acidic)
	
—
L
350
_
—
—
—
—
—
L
2.2
	
—
0
250
	
—
0
—
	
—
L
109
_
—
0
—
	
—
0.03
—
	
_
105
704
	
_
38.3
156
Fly
Ash
(Basic)
L
L
L
0
0.18
—
—
—
0.48
0.83
0.10
0.49
25.0
4.3
43.3
172
0.30
0.13
0.25
—
9.8
9.0
13.0
57.0
L
0
48.8
—
0.10
0
0.05
—
93.5
91.0
73.0
232
41.3
21.3
20.0
62.4
Zeolite
663
693
—
—
0.13
—
—
—
0.43
0.73
—
—
L
0
—
—
0.18
0.13

—
11.0
9.5

—
0
0
—
—
0.15
0
—
—
L
L
—
—
0
0
—
—
Verm icu lite
0
47.0
65.0
84.8
0.70
—
—
—
50.15
0.20
0
0
L
0
0
0
0.09
0.05
0
—
0.2
0.5
L
2.4
2.5
0
5.0
—
0.10
0
0.02
—
22.8
21.5
4.1
0
5.6
0.50
0
0
Illite
163
163
0
630
0.05
0
0
—
L
L
L
0
L
L
L
0
L
L
L
—
13.7
12.5
79.9
205
46.3
20.0
313
—
1.1
0.65
0.25
—
70.0
121
264
250
41.3
21.3
71.3
88.0
Kaolinite
113
335
85.0
1,190
0.18
—
—
—
L
0
0
8.9
L
0
0
0
0
0.13
0.25
—
7.5
6.0
79.8
183
21.3
10.0
188
—
L
L
0
268
0
O
44.0
102
0
L
L
—
Activated
Alumina
(t)
998
913
795
6,300
0.18
—
—
—
0.48
0.70
0.15
2.9
26.0
11.9
53.0
534
0.43
0.13
0.25
—
11.3
11.5
13.8
348
L
L
L
—
0.30
0
0
—
L
L
L
0
L
L
L
0
Activated
Alumina
(II)
1,000
913
—
—
0.18
—
—
—
0.48
0.70
—
—
24.8
12,4
—
—
0.35
0.13
—
—
10.5
10.8
—
—
L
L
—
—
0.15
L
—
—
0
0
—
—
0
0
—
-
Cullite
1,000
912
—
—
0.15
—
—
—
L
0.18
—
—
20.0
11.5
—
—
0.03
0.13
—
—
10.3
10.0
—
—
0
0
—
—
0
0
—
—
L
L
—
—
L
L
—
•
Activated
Carbon
_
—
275
547
—
—
—
—
—
—
0.25
2.0
—
—
21.3
19.0
—
—
0.25

—
—
3.8
0.60
~
—
0
—
—
—
0.05
—
—
—
104
956
—
—
36.8
325
*  Expressed in mlcrograms of ion removed per gram of adsorbent used.
—  Indicates no data were obtained for specific adsorbent.
L  Represents no adsorbent capacity and a reduction in leaching of contaminant when adsorbent mixed with leachate.

-------
                                                           TABLE 6
                       CHEMICAL CHARACTERISTICS OF LEACHATE FROM METAL FINISHING SLUDGE (NO. 3)
              BEFORE AND AFTER TREATMENT WITH SELECTED ADSORBENT MATERIALS UNDER STATIC CONDITIONS
MEASURED
PARAMETERS
PH

Conductivity


Ca (rng./l.)


Cd (mg./l.)


Cr (mg./l.)


Cu (mg./l.)


Fe (mg./l.)


Mg (mg./l.)


Ni (mg./l.)


Pb (mg./l.)


Zn (mg./l.)


F~ (mg./l.)


Cl~ (mg./l.)


CN~ (mg./l.)


COD 0.13
2.1
1.0
1.2
46.0
79.9
37.8
0.22
0.30
0
24.0
63.2
L
37.6
39.3
0
Activated
Carbon
9.4
9.0
575
1,125
0.50
6.5
79.0
<0.01
<0.01
-
<0.20
<0.20
-
<0.03
<0.03
1.3
<0.05
<0.05
-
0.10
2.1
58.5
<0.05
0.10
0.23
<0.20
<0.20
-
<0.01
<0.01
0.13
0.04
1.6
0
5.0
75.9
47.8
<0.03
<0.03
-
<2.0
3.9
115.0
5.1
4.4
38.3
MINIMUM
DETECTABLE
VALUE





0.10


0.01


0.20


0.03


0.05


0.05


0.05


0.20


0.01


0.02


2.0


0.03


2.0




*  (1) Concentration in adsorbent material (mg /I ).
   (2) Concentration in leachate after treatment (mg /I ).
   (3) Micrograms of contaminant removed per gram of adsorbent used.

L  Represents no adsorbent capacity and a reduction in leaching of contaminant when adsorbent mixed with leachate.

                                                            - 128-

-------
                                                                             TABLE 7
                                        CAPACITIES* OF SELECTED ADSORBENT MATERIALS FOR REMOVING CONTAMINANTS

                               FROM LEACHATE OF METAL-FINISHING SLUDGE UNDER STATIC AND DYNAMIC (LYSIMETER) CONDITIONS
MEASURED
PARAMETERS

Ca



Cu



Mg



Ni



F~



Cl~



COD



TOC


DESCRIPTION
Static Test #1
Static Test #2
Static Test #3
Lysi meter Test
Static Test #1
Static Test #2
Static Test #3
Lysimeter Test
Static Test #1
Static Test #2
Static Test #3
Lysimeter Test
Static Test #1
Static Test #2
Static Test #3
Lysimeter Test
Static Test #1
Static Test #2
Static Test #3
Lysimeter Test
Static Test #1
Static Test #2
Static Test #3
Lysi meter Test
Static Test #1
Static Test #2
Static Test #3
Lysimeter Test
Static Test #1
Static Test #2
Static Test #3
Lysimeter Test
ADSORBENT MATERIALS
Bottom
Ash
L
L
19.0
-
L
0
0.35
-
L
L
L
-
0
0
L
-
L
L
1.4
-
L
L
0
-
1.3
195
0
-
78.3
50.0
18.0
-
Fly
Ash
(Acidic)
_
_
0
123
	
—
1.0
16.5
_
—
25.5
448
	
_
0
4.9
_
—
L
0
	
_
50.0
-
_
_
75.0
1,228
	
—
32.8
519
Fly
Ash
(Basic)
L
L
0
146
L
0
0.93
7.5
2.5
40.0
58.3
200
0.18
0.05
0.23
2.0
L
L
0.88
0
0
0
93.8
-
97.5
130
58.5
320
41.5
20.0
19.3
148
Zeolite
L
L
_
-
0.13
0
_
-
L
L
_
-
0
0
_
-
0
0
_
-
0
L
_
-
L
688
_
—
0
260
—
—
Vermiculite
L
55.0
273
1,280
0.90
0.20
4.6
20.5
L
50.0
88.8
485
0.70
0.40
1.4
3.0
0
L
L
0
200
340
313
-
200
2,130
300
1,048
71.0
60.0
115
444
Illite
0
0
0
1,828
0
0
L
57.5
L
L
6.3
1,840
L
L
0.50
7.3
8.6
10.5
12.6
2.7
123
325
369
-
470
2,880
258
3,060
368
1,381
143
1,430
Kaolinite
64.0
100
383
930
L
L
3.1
-
40.0
45.3
30.6
-
1.0
0
1.4
—
8.6
2.0
10.0
3.6
375
0
438
—
0
1,880
244
0
0
971
143
0
Activated
Alumina
(I)
15.8
33.5
95.3
737
0.23
0.03
0.98
6.3
44.6
49.8
63.5
495
0.18
0.15
0.33
2.5
L
L
1.2
11.4
0
0
37.8
—
0
L
0
0
0
0
0
0
Activated
Alumina
(ID
15.7
33.5
_
-
0.18
0.05
—
—
44.4
47.9
—
—
0.18
0.18
—
—
L
L
—
—
0
0
-
—
0
0
—
—
0
0
-
—
Cullite
16.0
33.5
—
—
0
0
—
—
43.1
48.1
-
—
0
0
—
—
1.9
2.6
—
—
0
0
—
—
0
150
-
—
0
0
-
—
Activated
Carbon
0
_
79.0
283
_
—
1.3
23.0
	
—
58.5
314
_
—
0.23
7.2
_
—
0
0
_
—
47.8
—
	
—
115
1,476
—
-
38.3
589
NJ
CD
      *  Expressed in micrograms of ion removed per gram of adsorbent used.

      — Indicates no data were obtained for specific adsorbent.


      L Represents no adsorbent capacity and a reduction In leaching of contaminant when adsorbent mixed with the leachate.

-------
                                                      TABLE 8
                         CHEMICAL CHARACTERISTICS OF LEACHATE FROM PETROLEUM SLUDGE
                        BEFORE AND AFTER TREATMENT WITH SELECTED ADSORBENT MATERIALS
                                             UNDER STATIC CONDITIONS
MEASURED
PARAMETERS

pH

Conductivity

Ca 0.35
<0.05
<0.05
-
93.2
71.4
L
0.20
0.20
L
<0.20
<0.20
0.40
<0.01
<0.01
0.30
0.31
0.84
0.90
500
647
L
0.07
0.07
0.33
40.3
105
588
0
40.3
224
Fly
Ash
(Acidic)
5.1

5.0
3,150
3,900
257
340
0
<0.01
<0.01
-
0.50
<0.20
-
0.29
0.28
L
<0.05
<0.05
—
64.4
74.8
L
1.4
1.5
0
0.30
<0.20
0.40
1.6
0.37
L
1.7
1.2
L
10.0
399
40.0
0.04
<0.03
0.43
<2.0
10.0
824
0.50
2.9
318
Fly
Astt
(Basic)
10.1

8.0
2,090
2,500
300
284
L
<0.01
<0.01
-
0.50
<0.20
-
0.06
0.06
0.28
<0.05
<0.05
-
3.2
4.0
58.8
<0.05
<0.05
0.13
0.28
<0.20
0.40
<0.01
<0.01
0.30
1.1
1.1
0.25
7.5
335
75.0
<0.03
0.06
0.35
4.6
55.1
712
4.1
21.0
273
Vermiculite
9.3

7.6
115
670
1.5
55.0
0
<0.01
<0.01
-
<0.20
<0.20
-
<0.03
<0.03
1.8
<0.05
<0.05
-
4.7
36.0
0
<0.05
0.15
0
<0.20
<0.20
2.0
<0.01
<0.01
1.5
4.7
5.0
L
2.9
390
313
<0.03
0.06
1.8
13.0
108
2,900
2.7
40.1
1,124
Illite
3.0

3.5
4,460
1,500
2.5
50.0
0
0.06
0.06
0
0.70
<0.20
-
3.6
1.27
0
0.60
0.60
0
70.0
24.0
25.6
0.45
0.40
L
<0.20
<0.20
2.0
1.5
0.23
L
0.33
0.39
10.1
2.7
275
1,750
<0.03
<0.03
2.1
16.8
57.9
3,526
0
24.0
1,325
Kaolinite
5.1

4.3
295
700
42.0
42.0
100
<0.01
<0.01
-
0.30
<0.30
-
0.16
0.23
L
<0.05
<0.05
-
4.9
26.0
18.8
0.06
0.08
0.25
<0.20
<0.20
2.0
0.30
0.11
0.25
2.3
2.9
L
6.8
387
350
1.2
1.2
0
7.0
84.0
3,200
15.5
30.8
1,240
Activated
Alumina
(1)
9.8

9.4
2,790
2,600
<0.10
<0.10
125
<0.01
<0.01
-
1.1
0.60
0
0.04
0.06
0.28
<0.05
<0.05
-
0.10
0.30
68.0
0.06
<0.05
0.13
<0.20
<0.20
0.40
<0.01
<0.01
0.30
2.1
2.1
L
46.0
400
15.0
0.22
0.31
0
24.0
217
308
37.6
80.1
125
Activated
Carbon
9.4

8.1
575
770
0.45
10.5
92.8
<0.01
<0.01
-
<0.20
0.20
-
<0.03
0.08
0.23
<0.05
<0.05
-
0.10
10.0
43.8
<0.05
<0.05
0.13
<0.20
<0.20
0.40
<0.01
<0.01
0.30
0.04
1.0
0.50
5.0
300
288
<0.03
<0.03
0.43
<2.0
39.0
753
5.1
14.5
289
MINIMUM
DETECTABLE
VALUE



-

0.10


0.01


0.20


0.03


0.05


0.05


0.05


0.20


0.01


0.02


2.0


0.03


2.0


_

(1) Concentration in adsorbent material (mg /I ).
(2) Concentration in leachate after treatment {mg /I ).
(3) Micrograms of contaminant removed per gram of adsorbent used.

Represents no adsorbent capacity and a reduction in leaching of contaminant when adsorbent mixed with leachate.
                                                        - 130-

-------
                                                                      TABLE 9
                                  CAPACITIES* OF SELECTED ADSORBENT MATERIALS FOR REMOVING CONTAMINANTS
                            FROM LEACHATE OF PETROLEUM SLUDGE UNDER STATIC AND DYNAMIC (LYSIMETER) CONDITIONS
MEASURED
PARAMETERS

Ca


Cu


Fe


Mg


Ni


Zn


F~


cr


CN~


COD


TOC

DESCRIPTION
Static Test #1
Static Test #2
Lysimeter Test
Static Test #1
Static Test #2
Lysi meter Test
Static Test #1
Static Test #2
Lysimeter Test
Static Test #1
Static Test #2
Lysimeter Test
Static Test #1
Static Test #2
Lysimeter Test
Static Test #1
Static Test #2
Lysimeter Test
Static Test #1
Static Test #2
Lysimeter Test
Static Test #1
Static Test #2
Lysimeter Test
Static Test #1
Static Test #2
Lysimeter Test
Static Test #1
Static Test #2
Lysimeter Test
Static Test #1
Static Test #2
Lysimeter Test
ADSORBENT MATERIALS
Bottom
Ash
0
0
157
L
0.35
0.04
0.15
—
-
L
L
0
0
L
-
0.08
0.30
0.23
1.5
0.90
0
10,630
L
-
12.5
0.33
0
628
588
495
208
224
219
Fly
Ash
(Acidic)
	
0
0
	
L
2.7
_
_
-
_
L
0
_
0
-

L
2.0

L
9.9
	
40.0
-
_
0.43
3.3
_
825
4,545
_
318
1,813
Fly
Ash
(Basic)
L
L
0
0
0.28
2.5
0.38
—
-
7.5
58.8
140
0.10
0.13
-
0.08
0.30
2.0
0.50
0.25
7.2
11,980
75.0
-
7.5
0.35
3.3
628
712
5,125
225
273
983
Zeolite
0
—
-
0
_
—
0
—
—
110
_
-
0
_
-
0.05
	
-
1.3
	
-
10,630
_
-
12.3
_
-
703
_
-
175
—
-
Vermiculite
0
0
1,010
0
1.8
1.6
1.0
_
-
100
0
90.0
0.20
0
-
0.30
1.5
6.4
1.0
L
0
49,600
313
-
45.0
1.8
13.0
2,850
2,900
12,555
810
1,124
4,995
Illite
415
0
1.110
0.15
0
0
0
0
-
70.0
25.6
180
0
L
-
0
L
0
3.2
10.1
12.1
19,780
1,750
—
16.3
2.1
15.5
1,628
3,526
5,525
618
1,325
2,620
Kaolinite
300
100
14.0
0.15
L
0
0
-
-
37.5
18.8
753
0
0.25
-
L
1.5
0
3.3
L
4.3
1 7,280
350
—
6.5
0
4.2
465
3,200
795
213
1,240
273
Activated
Alumina
(1)
812
125
200
0.15
0.28
0.39
0.38
—
—
996
68.0
107
0.25
0.13
. _
0.10
0.30
0.43
2.7
L
3.4
11,530
15.0
—
6.5
0
0
575
308
556
253
125
248
Activated
Alumina
(II)
811
—
-
0.15
—
—
0.38
-
—
995
—
—
0.23
-
—
0.05
—
—
1.9
—
—
11,630
-
—
4.8
—
—
448
-
—
180
—
—
Cullite
765
-
—
L
—
—
0
—
—
903
—
—
0.03
—
—
0.05
-
—
1.6
-
—
13,730
—
—
1.8
-
—
420
-
—
108
—
—
Activated
Carbon
728
92.8
160
0.08
0.23

0.38
—
—
468
43.8
10.0
0.15
0.13
—
0.10
0.30
1.3
3.3
0.50
1.3
20,480
288
—
19.0
0.43
2.9
2,985
753
3,000
1,055
289
1,270
*  Expressed In micrograms of ion removed per gram of adsorbent used.

—  Indicates no data were obtained for specific adsorbent.

L  Represents no adsorbent capacity and a reduction in leaching of contaminant when adsorbent mixed with leachate.

-------
under   dynamic  rather  than  under  static  conditions.
However, none of the adsorbents removed all of the ions
studied, and some adsorbents removed specific ions better
than others. For example, activated alumina removed more
magnesium  and  nickel  than  illite  did.  However,  illite
removed chloride and cyanide better than activated alumina
did. Specific  results  of  the dynamic tests  include  the
following:

   •  Calcium   fluoride sludge  (No.  3),  characterized in
      Tables 4 and 5,  yielded a leachate that differed from
      the leachates of the other sludges studied in the static
      tests.  Activated alumina  effectively removed  the
      greatest  number of contaminants:  calcium, copper,
      magnesium, and fluoride. Activated carbon  and acidic
      fly ash were the most effective for removing organics,
      although  illite appeared to be the most effective in
      the static tests.

   •  Metal-finishing  sludge  (No.  3}  is characterized in
      Tables 6 and 7.  The illite-sand mixture produced the
      best overall results regarding ion removal. Activated
      alumina  was extremely versatile. The  data indicate
      that  adsorbents that  were effective  in   removing
      fluoride  in leachate from calcium fluoride sludge were
      not  very effective  in  removing  fluoride  in  the
      metal-finishing  sludge. Probably this  difference  in
      effectiveness  was  due to  pH,  concentration,  and
      competition among ions.

    •  Petroleum sludge (No. 3) is characterized in Tables  8
      and 9. Vermiculite and  illite  mixtures produced the
      best overall results regarding removal of a broad range
      of the ions studied. This sludge produced the only
      leachate  which  had a significant  concentration of
      cyanide.  Vermiculite,  illite, acidic fly ash, and basic
      fly   ash   were  most  effective  in  reducing  the
      concentration of cyanide in the leachate.
Future Studies

      We  are  currently  evaluating  the  ability  of  the
adsorbent  materials tested to  retain  the  contaminants
adsorbed. Afterward we plan to study the effectiveness of
various combinations and quantities of adsorbents.
                   REFERENCES CITED

1.   Hughes, G. M., R. A. Landon, and P. N. Favolden. 1971.
         Hydrogeology of solid waste disposal sites in northeastern
         Illinois. Report SW-12d. U.S. Environmental Protection
         Agency, Washington, DC.

2.   Brunner, D. R., and D. J. Keller. 1972. Sanitary landfill design
         and operation. Report No. SW-65ts. U. S. Environmental
         Protection Agency, Washington, DC.

3.   Anonymous. 1972.  Sanitary landfill in old gravel pit. Pollution
         Equipment News: (10)1.

4.   Neeley, G.  A.  and N. S.  Axtz. 1972. Demonstration  sanitary
         landfill in Kansas City, KS. Civil Eng. 72 (10).

5.   Witt, P. A., Jr. 1971. Disposal of  solid  waste. Chem. Eng.
         78: 62-77.

6.   American  Public Health  Association, American Water Works
         Association, and Water  Pollution Control  Federation.
         1971. Standard methods  for the  examination of water
         and  waste-water.  13th   ed. American  Public  Health
         Association, Washington, DC. 874 p.

7.   Liskowitz,  J. W., et al. 1976. Evaluation of selected  sorbents
         for the  removal of  contaminants  in  leachate from
         industrial sludges. Proc.  Haz. Waste Res. Symp. U. S.
         Environmental  Protection Agency,   EPA-600/9-76-015,
         Washington, DC.

      This  study was  funded  in   part  by  EPA  Grant
No. R-803-717-01-0,   Industrial  Waste  Treatment
 Laboratories, Cincinnati, Ohio.
                                                          -132-

-------
                                  HEALTH ASPECTS OF LAND APPLICATION
                                 OF SEWAGE SLUDGE AND SLUDGE COMPOST

                                       E. Epstein, J. F.  Parr, and W. D. Burge
                                    Agricultural Environmental  Quality Institute
                             Biological  Waste Management and Soil Nitrogen Laboratory
                                         U. S. Department of Agriculture
                                                  Beltsville, MD
INTRODUCTION

     One of the most urgent problems confronting many
municipalities  in the  United  States  today  is  that  of
disposing  of their sewage  sludges in  a  manner  that  is
environmentally  acceptable,  economically  feasible,  and
above all  is not hazardous to human health. During the past
decade legislative actions have imposed strict limitations on
the disposal  of sewage sludge by incineration (Air  Quality
Act of 1967), fresh water dilution (Water Pollution  Control
Act Amendments of 1972). and ocean dumping  (Marine
Protection, Research, and  Sanctuaries Act of 1972). The
U. S.   Environmental   Protection  Agency  has   ordered
municipalities in coastal areas to cease ocean dumping of
sewage sludge  by 1981. The  situation will become even
more  critical because  the  costs of  present  methods of
sludge disposal (e.g., trenching, landfilling, incineration) are
increasing rapidly, and could reach  prohibitive levels in the
near   future.   Moreover   the   development   and
implementation   of  advanced  waste-water  treatment
technology  is  expected to  increase  the present annual
US. sludge production of about 5 million dry tons  to more
than  10 million  tons  by  1985.  Consequently, many
municipalities   are  now  considering  land  application
methods  for the disposal and/or utilization of their sewage
sludges.

CHEMICAL COMPOSITION OF SEWAGE SLUDGES

      Potentially  a  valuable  resource,  sewage   sludge
contains  from  40 to 60 percent organic matter, and both
macronutrients  (e.g., nitrogen and  phosphorus)  as well  as
micronutrients  (e.g., zinc  and copper) that are  essential
nutrients for plant growth and development. Sludge is also
valuable  as an organic amendment to improve the  physical
properties of marginal soils (Epstein,  1975). Sludge use on
land will be limited by the level of contamination from
heavy metals and toxic organic chemicals.
      Table   1  shows  how  variable  the  chemical
composition of different sewage sludges can be (Sommers,
1977). The composition  varies in accordance with the
extent   of  treatment  and   the  degree  of  industrial
contamination.

PROBLEMS ASSOCIATED  WITH LAND APPLICATION
OF SEWAGE SLUDGE

      Sewage sludges can be applied to land as liquids (2 to
10 percent solids), as partially dewatered materials (18 to
25 percent solids), or as heat-dried and air-dried products
(90 to 99 percent solids). There are, however, a number of
problems that must be considered when these materials are
applied to land.
                      TABLE 1

          COMPOSITION OF SEWAGE SLUDGE
         FROM A NUMBER OF MUNICIPALITIES
              IN THE UNITED STATES1
                   (Sommers, 1977)

COMPONENT
Organic C
Inorganic C
Total N
NH£- N
NO 3 - N
Total P
Inorganic P
Total S
Ca
Fe
Al
Na
K
Mg

Zn
Cu
Ni
Cr
Mn
Cd
Pb
Hg
Co
Mo
Ba
As
B
CONCENTRATION2
Minimum
6.5
0.3

-------
have  offensive odors. Avoidance of  odors  during  land
application requires immediate incorporation of sludge into
the soil. Sites must  be  selected with respect  to  human
population density, soil type and drainage characteristics,
and the  prevailing wind  direction.  Composting of sludge
under proper conditions eliminates putrefying odors so that
land  application  of  compost  does  not  require  special
precautions (Epstein and Willson, 1975).

Handling and Storage

      Land  application  may  entail  problems in cold
climates. Several states prohibit the application of sludge to
frozen ground, thus necessitating costly storage facilities.
Long  storage  of   sludge  can   result   in   anaerobic
decomposition  and   the  production  of odors.  Land
application may require specialized and costly equipment.
Sludge should  be incorporated  into  the  soil as soon as
possible  after  application  to  avoid  runoff   and odor
problems.  Improper  soil  or site management  can cause
excessive  runoff,  pollution  of ground or surface waters,
objectionable odors,  and other  environmental  problems.
Public opposition to  hauling  and surface application  of
sewage sludge can also be a major problem.

Chemicals from Waste-water Treatment

      Application of sludges to land can result in excessive
accumulation of salts, since ferric chloride, alum, and lime
are added  during waste-water treatment to flocculate and
precipitate  the suspended  solids.  These  salts have  the
potential to contaminate both  ground water and  surface
waters.  In arid climates, salt accumulation in  soils may
adversely affect plant  growth.

Organic Chemicals and Pesticides

      There   is  very   little  information  on  land
contamination by sludges  containing organic  chemicals.
The  concentrations  of   two polychlorinated  biphenyls
(PCB's)  in sludge from a number of municipal waste-water
treatment  plants in   Michigan   ranged  from  less  than
0.1 ppm to 352.0 ppm (Table 2). Analysis of  raw sludge
from  the  Blue  Plains Waste-water  Treatment Plant in
Washington,  D.C.  showed  a   PCB  level of  0.24 ppm
(Table 3).  Other  organics found were BHC (lindane)  and
DDT, both  pesticides,  at  concentrations of  1.22  and
0.6 ppm respectively  for  raw sludge. The  extent to which
these materials at these  levels are absorbed by  plants and
may cause toxicity to humans in food crops is not known.
Duggan  and Corneliussen  (1972) indicated that a 6-year
average  dietary  intake   of  DDT  and  its analogs  was
0.0007 mg  per kg  of body weight per day.  Intake from
crops, vegetables and  fruits accounted for 34 to 41 percent,
with  dairy and meat products contributing the rest.  The
amount  of intake from surface residues on plant products
compared with the amount accumulated in the  plant from
soil residues is not known but should be determined. Dean
                      TABLE 2

            CONCENTRATIONS OF TWO
      POLYCHLORINATED BIPHENYLS IN THE
          SLUDGES FROM A NUMBER OF
      MUNICIPAL WASTEWATER TREATMENT
               PLANTS IN MICHIGAN
                 (Anonymous, 1973)

CITY

Ann Arbor
Bay City
Benton Harbor-
St. Joseph
Cadillac
Charlotte
Detroit
Grand Rapids
Howell
Saginaw
Wayne County
AROCHLOR
1242
AROCHLOR
1254
(ppm — Dry Weight Basis)

352.0




32.1



2.0
1.1


13.8
<0.1
6.8

11.8
15.0
5.0

(1975) indicates that the hazards from organic pesticides
and chlorinated organics in sludges applied to land appear
to be minimal.

Heavy Metals

     Land application  of sewage  sludge  can result in
contamination of the soil with toxic trace elements (often
referred to as heavy  metals).  It has been shown that such
increases can  cause direct phytotoxic effects on plants and
result in decreased growth and yield. Heavy metals may
also accumulate in plant tissues and subsequently enter the
food chain reaching  humans  through direct  ingestion or
indirectly through  animals  (Page,  1974;  Chaney  and
Giordano,  1977).  The  elements  in  sludge  of  greatest
concern  are  zinc  (Zn),  copper  (Cu),  nickel (Ni),  and
cadmium  (Cd).  The  first  three  are important because
sufficiently high levels of these elements in soil can cause
direct phytotoxic effects, including decreased plant growth
and yield.
     Cadmium is  the  element of  greatest concern to
human health when  sewage sludges and sludge composts
are applied to land. While Cd is not usually phytotoxic, it is
readily  absorbed  by  plants,  and can accumulate  in the
edible parts. Most human exposure to Cd comes from food,
principally grain products, vegetables and  fruits.  Duggan
and  Corneliussen  (1972)  showed  that  26.5,  26  and
10 percent of the calculated daily intake of Cd came from
grains and cereals, vegetables, and fruits, respectively. High
levels of Cd in foods can be toxic to humans (Standstead et
al., 1974). Dietary Cd accumulates primarily in the liver
                                                      - 134-

-------
                                                     TABLE 3

                           COMPOSITION OF RAW AND DIGESTED SLUDGES FROM THE
                          WASHINGTON, D. C. BLUE PLAINS WASTE-WATER TREATMENT
                           PLANT, AND THEIR RESPECTIVE COMPOSTS PROCESSED AT
                          THE USDA COMPOSTING FACILITY, BELTSVILLE, MARYLAND
COMPONENT
pH
Water, %
Organic Carbon, %
Total N, %
NH 4 - N, ppm
Phosphorus, %
Potassium, %
Calcium, %
Zinc, ppm
Copper, ppm
Cadmium, ppm
Nickel, ppm
Lead, ppm
PCB1,ppm
BHC2, ppm
DDE3, ppm
DDT, ppm
f«AW
SLUDGE
5.7
78
31
3.8
1,540
1.5
0.2
1.4
980
420
10
85
425
0.24
1.22
0.01
0.06
RAW SLUDGE
COMPOST
6.8
35
23
1.6
235
1.0
0.2
1.4
770
300
8
55
290
0.17
0.10
<0.01
0.02
DIGESTED
SLUDGE
6.5
76
24
2.3
1,210
2.2
0.2
2.0
1,760
725
19
—
575
0.24
0.13
-
—
DIGESTED SLUDGE
COMPOST
6.8
35
13
0.9
190
1.1
0.1
2.0
1,000
250
9
—
320
0.25
0.05
0.008
0.06
                  1  Polychlorinated biphenyls as Arochlor 1254.
                  2  The gamma isomer of benzene hexachloride is also called lindane.
                  3  DDE results from the dehydrochlorination of DDT.
and kidney and  at high concentrations can result in liver
damage and kidney failure. This increase takes place up to
the age of about 50 and  then decreases  (Elinder et al.,
1976). Environmental pollution of  soils  with  Cd  and
subsequent accumulation  of Cd in rice  resulted in the
ttai-itai ("ouch-ouch") disease, which occurred in the Jiatsu
River basin of Japan (Yamagata and Shigematsu, 1970).
The  World Health Organization has established  that the
maximum  permissible level  of dietary  Cd  should not
exceed 70 ug/person/day. According to the Food and Drug
Administration (FDA) U. S. citizens now ingest from  70 to
90 percent  of  this  level   (Braude  et  al.,  1975).
Consequently, any further  increase in our dietary intake of
this element would not be acceptable.
      Smoking is a second source of human exposure to
Cd.  Tobacco  usually contains  1  to  6 ppm  Cd. Cd  is
absorbed  from  smoke  by the lung  and  can contribute
significantly  to  the total  body burden   (Elinder et al.,
1976; Friberg etal., 1971).
      The  availability of  heavy metals  to plants,  their
uptake and  accumulation, depend  on  a  number of soil,
plant, and miscellaneous  factors  listed  in Table 4. For
example,  toxic  metals are more available  to plants  when
the soil pH is below 6.5. Thus, the  practice of liming soils
to a pH range of 6.0 to 6.5 is recommended to suppress the
availability and toxicity  of  heavy metals to plants. Soil
organic matter  can chelate or bind metal cations, making
them  less available  to plants. The application of organic
amendments such as  manures and composts can also lower
the availability  of heavy metals through chelation and the
formation of complex ions. Soil phosphorus can interact
with certain metals thereby reducing  their availability to
plants.
      The cation exchange capacity (CEC), an expression
of a soil's capacity to retain metal cations, is important in
binding heavy metals, thus decreasing their availability to
plants. Generally, the higher the clay and organic matter
content of soils, the  higher their CEC  value. Heavy metals
are relatively less available to plants in high CEC soils (clays
or  clay  loams) than in low  CEC soils  (sands  or sandy
loams). Soil moisture, temperature, and aeration are factors
which  interact to  affect  plant growth,  uptake, and
accumulation of metals. For example, increasing the soil
temperature can increase plant growth and the availability
and uptake of heavy metals as well.
      Plant species,  and even plant varieties, vary widely in
their  sensitivity  to   heavy  metals.  For  example, some
vegetable crops are  very  susceptible  to  injury  by heavy
                                                       - 135

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metals;   corn,  soybeans,  and  cereal  grains  are  only
moderately susceptible, while forage grasses are  relatively
tolerant. Generally, the older leaves of most plants  will
contain  higher amounts of heavy metals than the younger
tissues.  Moreover, the grain and fruit of plants accumulate
lower amounts of heavy metals than the leafy tissues. This
observation is illustrated in Table 5, which shows the effect
of sludge application  rates on the Zn  and  Cd content of
corn grain and leaves.  As the sludge rate increased, both the
Zn and Cd  concentrations  increased in the plant tissues.
However, considerably lower amounts of these metals were
accumulated in the grain than in the leaves.
                       TABLE 4

    MAJOR FACTORS AFFECTING HEAVY METAL
     UPTAKE AND ACCUMULATION BY PLANTS
Soil Factors

1.  Soil  pH - Toxic metals are  more available to plants
    below pH 6.5.

2.  Organic  matter — Organic  matter can  chelate  and
    complex heavy metals so that they are less available to
    plants.

3.  Soil  phosphorus — Phosphorus interacts with certain
    metal cations to alter their availability to plants.

4.  Cation  Exchange Capacity  (CEC) -  Important in
    binding of metal  cations — Soils with a high CEC are
    safer for disposal of sludges.

5.  Moisture, temperature, and aeration — These can affect
    plant growth and  uptake of metals.

Plant Factors

1.  Rant species and  varieties - Vegetable crops are more
    sensitive to heavy metals than grasses.

2.  Organs of the plant - Grain and fruit accumulate lower
    amounts of heavy metals than leafy tissues.

3.  Plant age and  seasonal  effects — The older leaves of
    plants will contain higher amounts of metals.

Miscellaneous Factors

1.  Reversion—   With  time,  metals  may  revert  to
    unavailable forms in soil.

2.  Metals -  Zn, Cu, Ni and other metals differ  in their
    relative toxicities to  plants and their reactivity in soils.
      It is  noteworthy that heavy  metals differ  in their
relative toxicities to plants and in their reactivity in soils.
For example, on an equivalent basis Cu is generally more
phytotoxic  than  Zn, while  Ni  is  considerably  more
phytotoxic  than either  Zn or  Cu. For  reasons  as  yet
unexplained, heavy  metals  can  revert  with  time to
unavailable forms in soil.
                       TABLE 5

         UPTAKE OF ZINC AND CADMIUM BY
      CORN GROWN ON A KEPORT SILT LOAM
     SOIL AMENDED WITH INCREASING RATES
           OF DIGESTED SEWAGE SLUDGE

SLUDGE APPLIED
Tons/acre1
0
17.5
35
70
105
ZINC
Grain
ppm
27
41
46
36
45
Leaves
ppm
35
180
224
168
143
CADMIUM
Grain
ppm
0.04
0.11
0.21
0.17
0.20
Leaves
ppm
0.41
1.11
1.74
1.89
1.69
 1  Application rates are on a dry weight basis.
 USDA  Guidelines  Limit  Heavy
 Agricultural Land
Metal  Loadings  on
      In  1976 USDA recommended certain guidelines3 to
limit  the application of heavy metals on agricultural land
from  the landspreading of either sewage sludges or sludge
composts. These guidelines are based on the best available
knowledge  from scientists at a number of State Agricultural
Experiment Stations as well  as from  the USDA.  Two
categories  of  land  were delineated: (1) privately-owned
land,  and  (2) land dedicated  to sludge  application, e.g.,
publicly owned or leased land.
      Table 6 shows the maximum  allowable cumulative
sludge metal applications for  privately-owned land.  It  is
suggested that sludges  having cadmium contents  greater
than  25 mg/kg  (dry weight)  should not  be  applied to
privately-owned land unless their Cd/Zn is <0.010. That is,
the Cd content of the sludge should not exceed  1 percent
of  the  Zn  content,  so  that  Zn  will  accumulate  to
phytotoxic levels before sufficient Cd can be absorbed by
the plant  to  endanger the food chain. Annual rates of
sludge  application  should be  based  on  the  nitrogen
requirements of crops.  Cadmium loadings on land should
not exceed 1 kg/ha/year for liquid sludge and  not more
than  2 kg/ha/year for dewatered  sludge.  The soil  should be
limed to a pH of  6.5 when the  sludge  is applied  and
maintained at a pH of 6.2 thereafter.
                                                       -136-

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                      TABLE 6
  MAXIMUM ALLOWABLE CUMULATIVE SLUDGE
    METAL LOADINGS FOR PRIVATELY OWNED
    LAND AS A FUNCTION OF THE SOIL CATION
               EXCHANGE CAPACITY
                      SOIL CATION EXCHANGE
                              CAPACITY
                             (meq/IOOg)1
MbTAL

Zn
Cu
Ni
Cd
Pb
0-5
5-15
>15
(Maximum metal addition, kg/ha)
250
125
50
5
500
500
250
100
10
1,000
1,000
500
200
20
2,000
     CEC was determined prior to sludge application using 1 N
     neutral ammonium acetate and is expressed here as a
     weighted average for a depth of 50 cm.
     On  publicly  controlled  land,  up  to 5  times  the
amounts of sludge-borne metals listed in Table 6 may  be
applied  if the sludge is mixed into the top 15 cm of surface
soil.   Where   deeper   incorporation   is   practiced,
proportionally  higher  total  metal  applications may  be
made. These metal applications apply only to soils that are
adjusted to pH 6.5 or greater when sludge is applied.

Pathogens

     Sewage sludge contains human pathogens, many of
which are destroyed or reduced in number during sewage
treatment. Further  reduction  can  be  accomplished  by
heat-drying, composting, lime stabilization, irradiation, or
pasteurization.   Table 7  lists  the   4  major  groups  of
pathogens found in sewage  and their associated diseases.
Heukelekian and Albanese  (1976) found tubercle bacilli in
sludge   from  TB  sanitariums  but  not  in  that  from
municipalities. The tubercle  bacilli  were not destroyed by
anaerobic digestion or air-drying. Oliver (1975) showed that
anaerobically digested sludge contained measurable levels of
polioviruses and reoviruses. Similarly, data by Wellings et al.
(1976)  showed  polioviruses,  reoviruses and echoviruses in
digested and air-dried  sludge. Fair et al.  (1971) reported
that helminthic  ova, protozoan cysts, pathogenic bacteria,
and viruses in sludge survived  digestion and air-drying.
      The effect of land  application of sludge  on human
health  is a matter of great concern. Previous data indicate
that disease problems  related to soil application of human
wastes have been causes primarily by the use of raw sewage
effluent, raw sludge, or night soil (Sepp, 1971). Parsons et
al.  (1975) summarized various data shown  in Table 8 on
the survival of  certain pathogens in soils  and  on plants.
While most pathogens survive  in soil for several days to a
few months, the eggs  of  intestinal worms such as Ascaris
lumbricoides can survive for a number of years.
     Soil moisture, pH, and temperature greatly influenced
the  survival  of  pathogenic  organisms.  Absorption  and
movement of pathogens in soil  is affected by the clay and
organic matter content. Movement of bacteria through soils
was  generally  restricted  to  the upper  few  centimeters
(Romero, 1970).  However, Bouwer et al.  (1974) showed
that in porous soils subjected to high  flow rates of sewage
effluents, bacterial  movement  can  occur  to a depth of
several meters.
      Bitton  (1975)   cites  several  references  regarding
absorption  of viruses on soil particles and their movement
through  soils.  Migration   of   viruses  through soils  was
generally limited  to the upper  50cm. However, in porous
media  or  where  fissures,  fractures, or  cracks  in  the
substratum occur, movement of  viruses to ground water is
possible (Hori etal., 1970).
      The application of raw or  untreated primary  sludge
on land is  not  recommended  because  of the  possible
presence of pathogenic organisms. However, in most cases
land  application  of digested  sludges is  environmentally
acceptable  since health hazards are considerably minimized
by secondary  treatment.   Further  risk reduction  can be
obtained by avoiding  the use  of digested sludge on  soils
producing vegetables to be eaten raw and by managing soils
so that runoff  and  erosion are  minimal. Sludge should not
be  applied  on  shallow  soils  in   close  proximity to
groundwater, or near domestic wells.
      The relative abilities of sewage treatment processes to
destroy  pathogens  and to stabilize  sludge have been rated
by Farrell  and  Stern (1975) as shown in Table 9. Of these
processes,   pasteurization,  ionizing  radiation, and  heat
treatment are capable  of completely eliminating pathogens,
but the sludges  are left  in an unstabilized state and will
readily  putrefy  when applied  to  land.  Anaerobic  and
aerobic digestion stabilize sludge, but pathogen control is
rated only  fair.  Lime treatment and chlorination  provide
good pathogen control,  but stabilization  is  incomplete.
Composting  through   the   activity  of  thermophilic
microorganisms is  the only process producing both good
pathogen control and  stabilization  of sewage sludges. The
success  of pathogen  destruction  in all  these processes
depends upon  just how effectively each  one is performed.

COMPOSTING OF SEWAGE SLUDGE

      Several years ago the Agricultural Research Service of
the U. S. Department of Agriculture at Beltsville, Maryland,
developed  a windrow method that has proved to be suitable
for composting digested sludge  (Epstein and Willson, 1974).
This method, however, was not acceptable for composting
undigested  (raw) sludge  because of  the  greater  level  of
 malodors  associated  with  undigested sludges. This same
 research group has now developed a method for composting
 raw sludges (Epstein  and Willson,  1975;  Epstein et at.,
 1976). The method is widely  referred to  as the Beltsville
 Aerated  Pile  Method,  wherein raw sludge  (22 percent
 solids)  is mixed with woodchips  as a bulking material, and
 then composted  in a stationary aerated pile for a period of
 3  weeks.  Other bulking  materials such  as paper, leaves,
 corncobs,   peanut  hulls, cotton  gin  trash,  and  other
                                                        - 137-

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                                                      TABLE 7

                              MAJOR PATHOGENS FOUND IN SEWAGE AND DISEASES
                                       ASSOCIATED WITH THESE PATHOGENS
                                 ORGANISM
                                                                               DISEASE
                  1. Bacteria
                       Salmonella spp
                       Shigella spp
                       Mycobacterium tuberculosis

                  2. Protozoa
                       Entamoeba histolytica

                  3. Helminthic parasites (intestinal worms)
                       Ascaris lumbricoides
                       Ancylostoma duodenale
                       Necator americanus
                        Taenia saginata (Beef tapeworm)
                        Trichuris trichiura (Whipworm)

                  4. Viruses
                        Poliovirus
                        Coxsackievirus
                        Echovirus
                        Reovirus

                        Adenovirus
                        Hepatitis Virus
        Salmonellosis
        Shigellosis
        Pulmonary tuberculosis
        Amoebic dysentery
        Ascariasis
        Hookworm infection
        Hookworm infection
        Taeniasis
        Trichuriasis
         Poliomyelitis
         Aseptic meningitis, gastroenteritis*
         Aseptic meningitist
         Mild respiratory infection,
           gastroenteritis
         Acute respiratory infection*
         Infectious hepatitis
                   *  Two of the diseases caused by several serotypes of this virus.
                      Diseases caused range from trivial to lethal.
                   t  Diseases caused are similar to that of coxsackievirus.
                   $  Other diseases include pharyngitis and infant pneumonia.
agricultural  residues can be used  in place of woodchips.
Sufficiently high  temperatures are attained (above 60° or
140°F)   to     destroy  pathogens effectively.   During
composting, the pile is blanketed with a layer of screened
cured compost for insulation and odor control. Aerobic
composting conditions  are  maintained  by  pulling  air
through  the pile by  means  of a vacuum  system.  The
effluent  air stream is conducted into a small  pile of
screened  compost  where  odorous gases are  effectively
absorbed. A three-dimensional schematic diagram of the
aerated pile method is shown in Figure 1.
      There are at least 4  reasons for  composting organic
wastes such as sewage sludges. These include: (1) abatement
of  odors through sludge stabilization; (2) destruction of
pathogens by  heat  generated  during the  composting
process;   (3) production  of  a  material  that  can  be
conveniently stored and uniformly applied  to land; and
(4) narrowing   the  C/N   ratio  of the biomass being
composted. Furthermore,  the  composting of  raw sludge
eliminates the need for aerobic or anaerobic digestors. The
finished  compost can be used as both a fertilizer and soil
conditioner. Table 3 shows an  analysis  of the compost
produced at Beltsville. Since the sludge from the Blue Plains
Wastewater  Treatment  Plant  is  primarily from  domestic
sources the levels of heavy metals are low. Composting with
a bulking agent further  dilutes the heavy  metal content of
the final product.

DESTRUCTION OF SEWAGE SLUDGE PATHOGENS BY
COMPOSTING

      A major advantage of  the Beltsville Aerated  Pile
Method  is  the  uniformly  high temperatures  existing
throughout  the  pile (Figure 2).  Temperatures in the pile
increase rapidly into the thermophilic range during the first
3  to 5days,  ultimately rising as high as  80°C (176°F).
Temperatures  start  to  decrease  after  about 3  weeks,
indicating that the more decomposible organic constituents
have been utilized by the microflora and that the sludge has
been stabilized.  High temperatures generated through the
activity of thermophilic microorganisms are essential in the
aerobic composting process  for effective  destruction of
                                                      -138-

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                              FIGURE 1

            THREE-DIMENSIONAL SCHEMATIC DIAGRAM OF THE
             BELTSVILLE AERATED METHOD FOR COMPOSTING
                           SEWAGE SLUDGES
COMPOSTING
WITH FORCED  AERATION
  SCREENED
  COMPOST
            WOODCHIPS
            AND SLUDGE
                                   WATER TRAP
                                   FOR CONDENSATES
 FILTER PILE
"SCREENED COMPOST
                                 -139-

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                               FIGURE 2

               MAXIMUM, MINIMUM. AND MEAN TEMPERATURES
                RECORDED DURING THE COMPOSTING OF RAW
                 SLUDGE BY THE BELTSVILLE AERATED PILE
                          METHOD (MAY 1975)
   80


   70 •


~  60 •
o
%•*
   50 •
in
5 40 •

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                        TABLE 8

         SURVIVAL OF CERTAIN PATHOGENS IN
                 SOIL AND ON PLANTS
                   (Parsons et al. 1975)
  ORGANISMS
Coliforms



Fecal streptococci

Salmonella spp




Salmonella typhi


Shigella spp




Tubercle bacilli


f. histolytica cysts



Enteroviruses


Ascaris ova
                        MEDIUM
Soil surface
Vegetables
Grass and clover

Soil

Soil
Vegetables and fruits
Grass and clover
Soil
Vegetables and fruits

On grass (raw sewage)
Vegetables
In water containing
  humus

Soil
Grass

Soil
Vegetables
Water

Soil
Vegetables

Soil
Vegetables and fruits
                          SURVIVAL
                             TIME
                             (Days)
  38
  35
   6-34

  26-27

  15->280
   3-49
  12->42 (and
    over winter)

   1-120
  <1-68

  42
   2-10

  160

>189
   10-49

   6-8
    8
    4-6

  Up to 7 years
   27-35
pathogenic  organisms   and  undesirable   weed   seeds.
Decomposition or stabilization of the sludge also proceeds
more rapidly  at higher temperatures. Temperatures above
55°C (131°) will effectively destroy most pathogens.
      Data by Surge et al.  (1976) on  the  destruction of
salmonellae,  fecal  coliforms and  total  coliforms  in  raw
sludge  during  composting in  aerated  piles  are shown in
Figure 3. Although all of these organisms increased initially
in  numbers,  they  are reduced to essentially undetectable
levels by the 10th day. Studies using an f2 bacteriophage as
an indicator  virus showed  that the virus was  essentially
destroyed by  the  13th day (Figure 4). Survival  of the virus
did occur for some time, however, at the blanket-compost
mixture  interface where  lower temperatures prevailed.
Storage in a  curing  pile for 30 days, in accord with the
present process technology should complete the destruction
of the  virus,  or at least  reduce  the  numbers to extremely
low levels. The numbers of coliforms and salmonellae may
increase in the outer layer of curing piles where conditions
for regrowth are more favorable. Studies are in progress to
assess  this   possibility.   Sufficient  research   has  been
conducted to show that composting with forced aeration is
essentially unaffected by low ambient temperatures and/or
 rainfall.
HEALTH   ASPECTS  OF   SEWAGE  SLUDGE
COMPOSTING

      Because sewage  sludges  do  contain a  number  of
organisms that can cause human diseases, precautions must
be taken to  protect workers who are engaged in collecting,
transporting, and composting sludge. The principal route of
transmission of primary pathogens,  listed in Table 7, is the
fecal  to oral mode,  i.e., direct ingestion of water or food
contaminated with fecal material. Transmission could occur
where workers  fail  to  wash their hands thoroughly before
eating.
      Immunization  programs can play an important role in
protecting workers from sickness.  Local  or state medical
authorities  should  be  consulted  as  to  the   need  for
inoculation  of  workers against such  diseases  as typhoid
fever, poliomyelitis and tetanus.
      During the composting process secondary pathogens
(i.e.,  thermophilic  aspergilli and  actinomycetes) may  be
generated. The probability that individuals in good  health
may  be  infected is very  small. It is recommended that
workers who collect and transport sewage sludge and who
work at sludge  composting facilities  be carefully screened
by the  appropriate medical  authorities  before  they are
hired. Certain  individuals who  are predisposed with such
ailments as  diabetes, asthma, emphysema, tuberculosis, and
arthritis,  and who are  taking such medication as  cortisone,
corticosteroids,  or immunosuppressive drugs, may be more
susceptible to infection by pathogens.

SUMMARY AND CONCLUSIONS

      Recent  legislative  actions   have   imposed  strict
limitations   on   the   disposal   of  sewage   sludges   by
incineration, fresh  water dilution,  and  ocean  dumping.
Consequently,  many  municipalities  are  now  considering
land  application methods for disposal and/or utilization of
their sludges.
      The application  of sewage sludges on land has raised
certain questions concerning their possible adverse  effects
on human  health.  Some sewage sludges may contain large
 amounts of heavy metals  making  them unsuitable  for
 application to  land. Heavy metals can accumulate in plant
tissues and  enter the food chain through direct ingestion by
 humans,  or indirectly  through  animals. Some  sludges may
 also  contain certain organic chemicals of industrial origin
 that  could  cause  adverse  effects on human  health  by
 contamination of surface waters. Sewage wastes and sludges
 contain  a  number  of  organisms  pathogenic  to humans.
 These  organisms can  survive on  plants  for days or even
 weeks, and  in soils for much longer periods.
       An aerated pile method was recently developed  for
 the  composting of  raw  sewage  sludge  by  the  U. S.
 Department of  Agriculture at  Beltsville,  Maryland. This
 method transforms sludge into  compost in about 3 weeks,
 during  which  time  odors are  abated  and  pathogenic
 organisms  are   destroyed.  The  finished  compost is  a
 humus-like material, free of malodors, and can  be used as
 both a low analysis fertilizer and a soil conditioner. Unlike
 sludges, it is conveniently stored, and is easily handled, and
                                                          141 -

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            FIGURES

DESTRUCTION OF SALMONELLAE, FECAL
 COLI FORMS, AND TOTAL COLIFORMS
    DURING COMPOSTING BY THE
 BELTSVILLE AERATED PILE METHOD
                                  20
            - 142-

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                 FIGURE 4

     DESTRUCTION OF f2 BACTERIAL VIRUS
   DURING COMPOSTING BY THE BELTSVILLE
           AERATED PILE METHOD.
       CROSS SECTION OF PILE IN UPPER
RIGHT-HAND CORNER SHOWS SAMPLING LOCATIONS
                   - 143-

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                                                         TABLE 9
                            RELATIVE EFFECTS OF VARIOUS WASTEWATER TREATMENT
                                 PROCESSES ON DESTRUCTION OF PATHOGENS AND
                                         STABILIZATION OF SEWAGE SLUDGES
                                           (adapted from Farrell and Stern, 1975)
PROCESSES
Anaerobic digestion
Aerobic digestion
Chlorination, heavy
Lime treatment
Pasteurization (70° C)
Ionizing radiation
Heat treatment (195°C)
Composting (60°C)
Long-term lagooning of
digested sludge
PATHOGEN
REDUCTION
Fair
Fair
Good
Good
Excellent
Excellent
Excellent
Good

Good
PUTREFACTION
POTENTIAL
Low
Low
Medium
Medium
High
High
High
Low

—
ODOR
ABATEMENT
Good
Good
Good
Good
Poor
Fair
Poor
Good

-
can be uniformly spread on land. Careful consideration of
the health status of workers at sludge composting facilities
is  recommended  because  certain  individuals  who are
predisposed with such ailments as diabetes and emphysema,
or  who are  taking immunosuppressive drugs may be  more
susceptible to infection by pathogens.
      Research  at  Beltsville  on phytotoxicity,  and  plant
uptake of sludge-borne metals suggests that management
systems can  be  developed to  utilize  composted sludges as
nutrient and organic resources for agricultural lands, while
minimizing  any  potentially   hazardous effects of heavy
metals  on soil fertility, food quality,  and human health.
Where industries  are discharging effluents containing heavy
metals  and  toxic organic chemicals  into  sanitary sewers,
abatement   and/or  pretreatment  procedures should be
implemented to ensure good quality sludges for composting
and recycling on land.
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Bouwer, H.. J.  C. Lance,  and M. S.  Riggs. 1974.  High-rate land
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 Chaney, R. L. and P. M. Giordano. 1977. Microelements as related
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Epstein, E. and  G. B. Willson. 1975.  Composting raw  sludge.
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Epstein, E., G. B.  Willson, W. D. Burge, D. C. Mullen, and N. K.
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Fair, G. M., J. C. Geyner and D. A. Okun. 1971. Elements of water
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   environment. Chemical Rubber Co. Cleveland, Ohio. 166 p.

Heukelekian,  H., and M. Albanese. 1956. Enumeration  and survival
   of  human tubercle bacilli in polluted  waters. Sewage Ind.
   Wastes. 28:1049-1102.

Hori,  D. H.,  N. C. Burbank, R. H. F. Young,  L. S. Lau, and H. W.
    Klemmer. 1970.  Migration of poliovirus type 2 in percolating
   water  through selected Oahu soils. Tech.  Rep.  No. 36. Water
    Resource Research Center, University of Hawaii, Honolulu.

Page,  A. L.  1974.  Fate and effects of  trace  elements in sewage
   sludge when applied to agricultural lands. A  literature review.
    USEPA Project No. EPA-670/2-74-005. 96 p.

Parsons, D., C. Brownless,  D.  Wetter, A.  Maurer, E. Haughton,  L.
    Kornder,  and M. Slezak. 1975.  Health aspects of  sewage
   effluent irrigation. Pollution Control Branch, British Columbia
    Water Resources Services, Victoria, B. C. 75 p.

Romero, T. G. 1970. The movement of bacteria and viruses through
    porous media. J. Ground Water. 8:37—48.

Seppt, E.  1971. The  use of  sewage for irrigation—  A literature
    review.  State of  California  Department of  Public  Health,
    Bureau of Sanitary Engineering, Sacramento, California. 41  p.
Sommers, L. E. 1977. Chemical composition of sewage sludges and
     analysis of their potential  use as fertilizers. J. Environ. Qual.
     (In press.)

Standstead, H. H., W. H. Allaway, R. G. Burau, W. Fulkerson, H. A.
     Laithinen, P. M. Newberne,  J. 0. Pierce, and B. G. Wilxson.
     1974. Cadmium,   zinc  and  lead. Geochem.  and  Environ.
     4:43-56.

Wellings,  F.   M.,  A.   L.   Lewis and C. W. Mountain.  1976.
     Demonstration of solids - associated virus in waste-water and
     sludge. Appl. Environ. Microbiol. 31:354-358.

Yamagata, N., and  I.  Shigematsu. 1970.  Cadmium pollution  in
     perspective. Bull. Inst. Pub. Health. 19:1—27.
                         FOOTNOTES

 1.   Research on composting of sewage sludge reported herein was
     partially supported by funds from the Maryland Environmental
     Service,  Annapolis,  Maryland;  the   U. S.   Environmental
     Protection  Agency,  Office of Research  and Development,
     Cincinnati,  Ohio;  and,   USEPA,  Region III,  Philadelphia,
     Pennsylvania.

 2.   Soil Scientist, Microbiologist, and Soil  Scientist, respectively.
     Biological Waste  Management and Soil Nitrogen Laboratory,
     National Agricultural Research Service, U.S. Department of
     Agriculture, Beltsville, Maryland.

 3.   Copies of the draft document are available from the Office of
     Environmental  Quality Activities, USDA, Washington, D.C.
     20250.
                                                                  -145-

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                   DESTRUCTION OF HAZARDOUS WASTES BY MOLTEN SALT COMBUSTION

                                           S. J. Yosim and K. M. Barclay
                                           Atomics International Division
                                               Rockwell International
                                                 Canoga Park, CA
INTRODUCTION

      The disposal of wastes of a toxic or hazardous nature
is receiving increasing attention. Alternate methods to the
traditional  means  of disposal  (including open  dumping,
discharge  into  rivers, lakes, oceans, sanitary landfills and
conventional incineration) are being sought.
      This paper presents some experimental results which
demonstrate  the   feasibility   of  applying  molten  salt
combustion technology to the disposal of hazardous wastes.
The  concept  of molten salt combustion is described first.
This  is followed  by  a  description  of the molten salt
combustors  used  at Atomics International. Then  some
results of  molten  salt  combustion  tests  on  hazardous
materials  are  given.  A  brief  description of larger  scale
applications concludes the paper.

CONCEPT OF MOLTEN SALT COMBUSTION

General Considerations

      In the Atomics International concept for molten salt
combustion, combustible material  and air are continuously
introduced beneath the  surface  of  a  sodium  carbonate
(Na2CO3) —   containing  melt   at  a temperature   of
800-1000°C. A small amount of catalyst is included in the
melt for accelerating the combustion rate  of carbon. The
combustible material is added in such a manner that any gas
formed during combustion is forced to pass through the
melt before it is emitted into the atmosphere. Acidic gases
such as HCI  (produced from organic chloride compounds)
and  SC>2 (from organic sulfur compounds)  are  instantly
neutralized and absorbed by the alkaline Na2CO3 melt. The
temperatures  of  combustion  are  too  low  to  permit a
significant amount  of  nitrogen oxides to be formed by
fixation of the nitrogen  in the air.
      Ash and  other noncombustible  materials build  up  in
the melt and must be removed. In certain applications with
low  volumes  of waste,  the salt-ash mixture is removed  in
batches  and  discarded.  When the volume of  waste  is
sufficiently large, a  side stream of the  melt  is  withdrawn
either in batches or continuously and is processed. The ash
must be  removed to preserve the fluidity of the  melt at an
ash concentration  of about 20 wt.-percent. The inorganic
combustion products must be removed at some point  to
prevent complete conversion of the melt to the salts, with
an eventual loss  of the acid pollutant-removal  capability.
The  spent melt is first  quenched in water. The solution is
then filtered  to remove the ash and  processed to convert
soluble impurities to disposable products. The regenerated
salt is then recycled to the combustor.
Molten  Salt  Combustion  Applied  to the  Disposal  of
Hazardous Wastes

     The concept  for  disposal of  hazardous  wastes  by
molten salt combustion  is schematically shown in Figure 1.
The exhaust gas contains carbon dioxide, steam, nitrogen,
and unreacted oxygen. This gas is cleaned of particulates by
scrubbing in a Venturi scrubber or by passing it through a
baghouse. The chemical  reactions of the waste with the salt
and air depend on its constituents. The halogens form the
corresponding sodium halide salts. The phosphorus, sulfur,
arsenic, and silicon (from glass or ash in the waste) form the
oxygenated   salts,   Na3PO4,   ^2804,   NaAsC>3,   and
Na2Si03, respectively.  In  the  case  of arsenic-containing
wastes, the spent salt must be further treated before final
disposition because the arsenic is retained in the melt.
     The  heating  value  of  the  waste   is,  in  general,
sufficient to generate enough heat to heat the reactants to
the required  temperature,  maintain  the  salt  in a molten
state, and balance all heat losses from the system.
     The advantages of molten salt combustion for the
disposal  of hazardous wastes are:  (1) Intimate  contact of
the hot  melt,  air  and  waste  provides for complete and
immediate  destruction  of  the hazardous material. (2) No
acidic  gaseous  pollutants, e.g.,  HCI  from  chlorinated
compounds such as  DDT and trichloroethane and H2S from
sulfur-containing  compounds  such   as  malathion,   are
emitted.  (3) Combustion products are sterile and odor-free.
(4) Sodium carbonate  is stable, nonvolatile,  inexpensive,
and  nontoxic.  (5) The  process  is applicable for a  great
variety of wastes including pesticides and their containers,
hazardous industrial wastes, hospital wastes, carcinogenic
material and low-level radioactive wastes.

MOLTEN SALT COMBUSTOR  FACILITIES

     There  are  2  molten salt combustion facilities at
Atomics  International.  One  is a bench-scale molten salt
combustor for disposing of  Vz-2 Ib /hr of waste. Feasibility
and  optimizing tests  are  generally  carried  out  in this
combustor. The other is a pilot plant combustor, capable of
disposing of 50—200 Ib  /hr of waste, and is used to obtain
engineering data  for reliable extrapolation to  a full-scale
plant.

Bench-Scale Molten Salt Combustor

     A schematic of the bench-scale molten salt combustor
is shown in Figure 2. Approximately 12 Ib. of molten salt
are contained in a 6-inch ID and 30—inch high  alumina tube
placed in a Type 321   stainless steel retainer vessel.  This
                                                      -146-

-------
                                         FIGURE 1

                            MOLTEN SALT COMBUSTION PROCESS CONCEPT
                                         STACK
                                        OFF-GAS
                                        CLEANUP
|
C0
                                               2
                                                            0
       WASTE
       WASTE
     TREATMENT
     AND  FEED
AIR
            WASTE AND  AIR
                                      MOLTEN SALT
                                        FURNACE
                                                               SALT RECYCLE
                                                             	1
                                 I

                         I
                         I
                         !
                         •
                         •
                         t
                               SPENT MELT
                              REPROCESSING
                                 OPTION
                                                           SPENT MELT
                                                            DISPOSAL
                                                                                         i
                                                                                        ..j
                                                                             ASH

-------
                       FIGURE 2

           BENCH-SCALE MOLTEN SALT COMBUSTOR
                   AIR IN
1/2-in. STAINLESS STEEL
INJECTOR TUBE
  VIBRATOR
 to 400 rpm
SCREW FEEDER
                              OFF-GAS OUTLET
                                STAINLESS STEEL
                                RETAINER VESSEL

                              1-1/2 in. ID ALUMINA
                                FEED TUBE
                                6-in. ID ALUMINA TUBE
                              ^6-in. DEPTH OF
                                MOLTEN SALT
                       - 148

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stainless steel vessel, in turp, is contained in an 8-inch ID,
four heating-zone Marshall furnace! The four heating zones
are  each 8 inches in height, and  the temperature of each
zone  is controlled  by an SCR  controller.  Furnace and
reactor  temperatures  are   recorded   by   a   12-point
Barber-Colman chart recorder.
      Solids, pulverized in a No. 4 Wiley mill to <1 mm in
particle size, are metered  into the 1/a-inch OD central tube
of the injector by a screw feeder. Rotation  of  the screw
feeder is provided by a 0 to 400 rpm Ederback Corporation
Con-Torque stirrer  motor. In the  injector, the solids are
mixed with the air  being used for combustion, and this
solids-air mixture passes downward through the center tube
of the injector and emerges into the 11/2-inch ID alumina
feed tube. This alumina feed tube is adjusted so that its tip
is % inch above the bottom of the 6-inch diameter alumina
reactor 'tube. Thus, the solids-air  mixture is forcfe'd to pass
downward  through the feed tube, outward at its bottom
end,  and  then upward through  6 inches  of salt  in the
annulus between the 11/z inch and the 6-inch alumina tubes.
In the case of liquids,  a different feed system is used. The
liquid is pumped with a  laboratory pump and  is sprayed
into the alumina feed tube.
                      TABLE 1

  HAZARDOUS CHEMICALS AND WASTES TESTED
  TYPE OF
 CHEMICAL
 OR WASTE
Pesticide
Chemicals
Low-Level
Radioactive
Wastes
        MATERIALS TESTED
DDT  Powder, Malathion, DDT-Malathion
Solution, Chlordane, and 2,4—D

Chloroform, Trichloroethane, Nitroethane,
Nitropropane,   Diphenylamine .RCI,
Monoethanolamine,  Diethanolamine,  and
Para-Arsanilic Acid.

Pdlyvinylchloride,  Polyethylene,  Rubber,
Paper,  Ion  Exchange   Resins,  Tributyl
Phosphate Solvent, etc., contaminated with
transuranic and/or fission products.
Pilot-Scale Molten Salt Combustor

      A schematic  of the molten  salt pilot  plant at the
Santa Susana facility is shown in Figure 3 and a photograph
of the molten salt combustor is shown in Figure 4.
      The molten salt vessel, 10 feet high and 3-foot ID, is
made of Type 304 stainless  steel, and  is lined with 6-inch
thick refractory  blocks.  It contains  1 ton of salt, which
corresponds to a depth of 3  feet, with  no  air flow through
the bed. The vessel is preheated on startup and kept hot on
standby by a natural-gas-fired burner.
      The salt  loading  is  fed into the molten salt vessel
through the carbonate feeder. The combustible materials to
be processed are transferred  directly from  the hammermill,
in which they are crushed to the required  size, into a feed
hopper provided with a  variable-speed  auger, and then
introduced into the air stream for transport into the vessel.
      The exhaust gases generated in the vessel exit through
refractory-lined  tubes   in   the  vessel   head   to   a
refractory-lined   mist  separator.  The   separator  traps
entrained melt droplets on a baffle assembly. The gases are
then  ducted to  a  high energy  Venturi scrubber which is
used  to remove  any particulate matter before release to the
atmosphere.  An overflow weir (not  shown in Figure 3)
permits continuous removal of spent salt, thus permitting
long-term tests to be carried out.
 RESULTS OF COMBUSTION TESTS

      Some of the hazardous chemicals and wastes tested
 by molten salt combustion are listed in Table 1. In selecting
 examples  for discussion, emphasis  has  been placed on
 pesticides and the more common industrial wastes.
      The combustion tests with  pesticides and  chemicals
were  done in the bench scale combustor at the rate of
1/2-2 Ib /hr. The combustion tests  with solid waste and with
waste x-ray film were done in the pilot plant at the rate of
70-100 Ib/hr.

Pesticides

      Tests were carried  out  on  DDT powder,  malathion
dissolved  in   xylene,  solutions of  DDT  and  malathion
dissolved  in   xylene,  chlordane  and  2,4—D.  The melts
contained  either Na2C03 or l<2CO3.The use of K2CC>3 is
of  interest because  the combustion product KCI can be
used  as a fertilizer.  Table 2 shows some typical results of
DDT powder, malathion  and  on  DDT-malathion solutions
tested at about  900°C. Destruction of  the  pesticide was
greater than'99.99 percent. No pesticides were detected in
the melt; however, traces of pesticides were detected in the
off-gas. The last two columns compare the concentration of
pesticides in the  off-gas with  threshold  limit values,TLVs.
(The TLV s refer to airborne  concentrations of substances
and represent conditions  under  which it  is believed  that
nearly  all  workers may be repeatedly exposed,  day after
day, without adverse effect.)  In general, the concentrations
of  pesticides in  the off-gas were well below the TLVs. This
comparison is a conservative one  because the  off-gas will be
considerably  diluted  when   it  reaches the  worker area.
Another  consideration  is the fact  that in  these tests,  a
6-inch deep salt bed was used. In an actual disposal plant, a
36-inch deep salt bed is  expected  to  be used. This  will
increase the residence time and contact time by a factor of
6;  therefore, the extent of destruction of these pesticides  is
expected to exceed considerably  the 99.99+  percent found
in  the laboratory tests.
                                                        -149

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               FIGURE 3

SCHEMATIC OF THE MOLTEN SALT PILOT PLANT
                           MOLTEN SALT
                           COMBUSTION
                           FURNACE
                                             MELT AND ASH
                                             TO DISPOSAL

-------
       FIGURE 4

PILOT PLANT COMBUSTOR
                                             rocess  Air
                                               tf
                                       Startup Heater
       -161 -

-------
                                                    TABLE 2

                           TYPICAL RESULTS OF COMBUSTION TESTS ON PESTICIDES



PESTICIDE
DDT Powder
Malathion
DDT-Malathion
Solution
DDT
Malathion

AVERAGE
TEST
TEMPERATURE
894
896

992




PERCENT
PESTICIDE
DESTROYED
99.998
99.999


99.997
99.996
CONCENTRATION
OF
PESTICIDE
IN MELT
(ppm)
<0.2
<0.005


<0.05
<0.01

CONCENTRATION
IN EXHAUST
GAS
(mg/m3)
0.34
0.42


1.4
1.1


TLV* OF
PESTICIDE
(mg/m3)
1
15


1
15
   * Threshold Limit Value
      The  herbicide   2,4 —D   (an   ester  of
 dichlorophenoxyacetic acid) was of interest because it was
 an actual waste which  contained  30—50 percent 2,4—D,
 and   50—70 percent  tars   (mostly  bis-ester   and
 dichlorophenol  tars). The waste, which was rather viscous,
 was diluted by  the  addition of % its weight with ethanol.
 The destruction of  the  herbicide was >99.98 percent; no
 organic chlorides or HCI were detected in the melt or in the
 exhaust  gas.  (In  this  case,  a less  sensitive  analytical
 technique was used.)

 Chemicals

      A summary of the results from the combustion of
 chloroform,    diphenylamine«HCI,    nitroethane,    and
 para-arsanilic acid is shown in  Table 3. In these  cases, no
 unreacted material was  detected. The nitrogen-containing
 compounds did produce  substantial amounts  of NOX
 formed from the nitrogen in the feed. However, by suitably
 adjusting  the  air/waste  feed   ratio,  this  problem  was
 eliminated. Although no para-arsanilic acid was detected in
 the  melt, the  reaction product,  sodium  arsenate,  was
 retained in the melt as expected. Thus, it is recognized that
 in this case, the melt must be considered to be hazardous.
 One approach for the disposal of this particular melt would
 be to solidify it into  an unleachable glass.
      Another   chemical   which  was   destroyed  was
 trichloroethane  ((^^03),  an  industrial chemical waste
 which contains 80 wt.-percent Cl. This test was carried out
 to determine how much of the Na2CO3 could be converted
 into NaCI and  still  be  present in sufficient amount to
prevent HO emissions.  Prevention  of HCI  emissions was
accomplished with as little  as 2 wt,-percent  Na2CO3.  No
trichloroethane «0.001 percent of the material fed) could
be detected in the off-gas.
 Solid Waste Combustion Tests in the Pilot Plant

      Successful combustion tests  had been  carried out
 with  low-level radioactive waste in the bench-scale unit and
 showed that excellent volume reduction (98 percent) could
 be achieved while retaining all the transuranic elements in
 the melt. A scale-up test was  performed with  simulated
 nonradioactive waste in the pilot plant. A total of 1500 Ib.
 of waste was  burned   at the rate of about 70 Ib Air. The
 waste consisted of (by weight) paper (33 percent), kimwipe
 (20 percent), polyethylene (32 percent),  PVC  (8 percent),
 and rubber (7 percent). No HCI «5 ppm), S02 «2 ppm),
 CO (<0.1 percent), or hydrocarbons  (<0.1  percent) were
 detected. The NOX concentration was about 30 ppm.
      Although photographic film is not a hazardous waste,
 an interesting application of molten salt combustion is the
 destruction of waste film and the recovery of silver metal.
 In this process, the silver from the film forms a molten pool
 of metal on the floor of  the combustor and can be drained
 after  completion of the test.  A  total of  15,000 Ib  of
 developed x-ray film was  processed in the  pilot plant to
 yield   277 IDS   of  silver.  A  single  230  Ib   ingot  of
 99.9 percent pure  silver  obtained from this  test is shown
cut in half in Figure 5.

 LARGER SCALE APPLICATIONS

 Portable Molten Salt Disposal System

      A conceptual and preliminary design for a portable
 molten  salt disposal unit has been completed. An artist's
concept is shown in Figure 6 which shows a combustor and
the auxiliary components  mounted on a truck  bed.  The
combustor, which has a 6-foot ID and is 11  feet tall,  is
capable of  processing 500 Ib /hr   of waste.  The waste
                                                      -152-

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                FIGURES




230 LB. CUT SILVER INGOT RECOVERED FROM TEST

-------
                                  FIGURE 6

                   PORTABLE MOLTEN SALT WASTE DISPOSAL SYSTEM
          VIEWPORT
SALT FEED
SYSTEM
   ALT. FEED
   SYSTEM
                                                   PARTICLE
                                                   SEPARATOR,
                          VESSEL
                          PREHEATER
DRAIN CART
                                  STACK
         SHREDDER

     ROTARY VALVE
                                            COMBUSTION
                                            VESSEL
                                                                          PARTICLE
                                                                          COLLECTOR

                                                                          CONVEYOR

-------
                                                FIGURE 7

                MOLTEN SALT RADWASTE COMBUSTION SYSTEM FOR IDAHO NATIONAL ENGINEERING LABORATORY
CJI
                          PROCESS AIR
                          HEATER
        COMBUSTOR
           WASTE
           SHREDDER
HEPA
FILTER
              BAGHOUSE
              FILTER
                                                                                     COKE STORAGE
                                                                                   PROCESS AIR
                                                                                   BLOWER
                                                                                    EXHAUST BLOWER

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                                                    TABLE 3

                        SUMMARY OF RESULTS OF COMBUSTION TESTS ON CHEMICALS



CHEMICAL
Chloroform
Diphenylamine* HCI
Nitroethane
Para-Arsanilic Acid

AVERAGE
TEST
TEMPERATURE
<°C)
818
922
892
924


PERCENT OF
CHEMICAL
DESTROYED
>99.999
>99.9992
>99.993
>99.9991
CONCENTRATION
OF
CHEMICAL
IN MELT
(ppm)
<0.1
<0.1
<1.0

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                ASSESSMENT OF INDUSTRIAL HAZARDOUS WASTE MANAGEMENT PRACTICES
                            IN THE LEATHER TANNING AND FINISHING INDUSTRY

                                  David H. Bauer, E. T. Conrad, and Ronald J. Lofy
                                                  SCS Engineers
                                                 Long Beach, CA
INTRODUCTION

      During the last three years, the  U. S. Environmental
Protection  Agency's Office of  Solid Waste  Management
Programs,  Hazardous  Waste  Management  Division,  has
sponsored  a  series  of  15  industry-specific  studies  on
hazardous waste management practices.  As part of the
program, EPA contracted with SCS Engineers in mid-1975
to conduct a study  of the leather tanning and finishing
industry.  The  study  focused  on process  solid  wastes,
including liquid sludges, destined for  land disposal. Solids
resulting from waste-water pretreatment or treatment, and
residues  collected  by  air pollution control devices were
included if they were disposed to the land.
      The data base for this project was developed through
field  visits  to various  tanneries  and the collection  and
analysis of solid waste samples. A total of 156 samples were
collected from  the 41  tanneries visited.  These tanneries
represent  14 percent of  the plants  in  the industry  and
nearly 50 percent of the industry's production. The total
number  of establishments  in the  leather tanning  and
finishing   industry  is   298.   Twenty-two   of  these
establishments  are  located  in  EPA  Regions IX  and X.
Fourteen are located  in  California.  A total  of  23 land
disposal sites were visited which receive tannery solid waste.
      Based on  adjusted production  data for 1974, EPA
Regions IX and  X accounted for 6 percent  of total U. S.
production, of which approximately 5 percent occurs at the
14 tanneries located in California.

INDUSTRY CHARACTERIZATION

      The dozens  of individual  operations  conducted to
produce    leather    can   be   summarized   in   three
groups: (1) preparation of hides  for  tanning; (2) tanning
operations; and  (3) coloring  and finishing.  The principal
steps  in hide preparation involve soaking the hides in a lime
solution  to remove  the hair and mechanical  removal of
fatty  tissue from the flesh side of the hide. In the  tanning
stage, a "tanning agent", such as trivalent chromium, alum,
or  vegetable  extract  is  chemically   combined  with  the
protein in the hide to prevent decomposition.  In the third
stage,  the  tanned leather  is  imparted  with  the  desired
physical  properties,  such  as color, softness, and  surface
texture.

WASTE CHARACTERIZATION

      The major categories of tannery process wastes and
their  relative  contributions  are shown  in  Table 1.  As
indicated, trimmings, shavings and other pieces of leather
from  various  stages  of  processing,  and  waste-water
treatment sludges constitute the bulk  of the process solid
waste generated.
                       TABLE 1

         TANNERY PROCESS SOLID WASTE TYPES
TYPE
Trimmings and Shavings
Wastewater Treatment Residues
Finishing Residues
Floor Sweepings
PERCENT OF
TOTAL WASTE
(WET WEIGHT
BASIS)
35
60
2
3
MOISTURE
CONTENT
(PERCENT)
10-50
60-95
10-50
5-10
      Table  2 shows the  estimated quantities of process
solid  waste  destined for land disposal nationally,  and  in
EPA  Regions IX and  X. Examination of the data  reveals
that  7 percent  of  the  total  process  solid  waste  and
8.5 percent of the potentially hazardous  waste is generated
in Regions IX and  X.  Approximately 90 percent of both
the total process and potentially hazardous waste generated
                       TABLE 2

     1974 TANNERY SOLID WASTE QUANTITIES
                   (METRIC TONS)




AREA
National Total
Region IX
Region X

TOTAL PROCESS
SOLID WASTE

Wet
203,000
13,200
1,100
Dry
65,000
4,380
322
TOTAL
POTENTIALLY
HAZARDOUS
WASTE
Wet
151,000
12,200
111
Dry
45,200
3,620
211
                                                      -157-

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in EPA Region IX occurs in California. California is one of
only  five  states  in  which  potentially  hazardous  waste
generation exceeded 10,000 metric tons in 1974.
      The   increases  in  total  process   and  potentially
hazardous  solid waste generation anticipated for 1977 and
1983  are   presented in  Table 3.  The  1977  values  are
principally  due to projected increases in production. The
projected increases in solid waste generation for Regions  IX
and X reflect  production trends  that  differ from the
national average. The  increases in waste generation for 1983
reflect  projected  production  increases  and  secondarily,
projected   increases  in  waste-water  treatment  sludge
generation  resulting   from   increasingly   stringent
pretreatment and direct  discharge requirements.
                       TABLE 4

     POTENTIALLY HAZARDOUS CONSTITUENTS
              (METRIC TONS PER YEAR)
YEAR
1974
1977
1983
CHROMIUM
(III)
909
1,000
1,300
ZINC
0.46
0.59
0.94
LEAD
10.6
11.9
14.7
COPPER
16.9
19.6
28.0
                      TABLE 3

    PERCENT INCREASE IN WASTE GENERATION
                RELATIVE TO 1974
               (WET WEIGHT BASIS)
AREA
National Total
Region IX
Region X
1977
8
13
7
1983
38
53
35
      As   shown   earlier   in   Table 2,   approximately
75 percent of the total process solid waste was found to be
potentially hazardous. In all cases, the waste was considered
potentially hazardous only due to its heavy  metal content.
Scientific studies of the environmental fate of  tannery
waste following land disposal have not been conducted and
in many instances the chemical structure of tannery solid
waste  is not well understood. Thus,  it was necessary  to
select  individual  contaminant concentration values above
which  a waste  containing these contaminants  would  be
considered  potentially  hazardous.  For this study, the
geometric mean  background  concentration levels of the
heavy  metals found in soils in the  United States  were used
as the reference values.  In  the wastes sampled, trivalent
chromium, lead, copper, and  zinc were found to be present
above  these background concentration levels. Estimates  of
the nationwide  total quantities of these heavy  metals  in
tannery wastes are shown in Table 4.
     The  conflicting  information   on  the degree   of
environmental hazard associated with  trivalent chromium,
the high concentration  of trivalent  chromium in  tannery
waste,  and the quantity of wastes involved played a role in
the decision to consider trivalent chromium a potentially
hazardous  constituent  of tannery  waste.  As  shown  in
Table 4,  the  quantity  of chromium  in  tannery waste
exceeds all  other hazardous  constituents  by nearly  two
orders  of  magnitude. This  results  from  the  fact that
trivalent chromium concentrations on the order of 2 to
3 percent on a wet weight basis are common in trimmings
and  shavings,  which  represent about  35 percent  of all
tannery waste.
      Another important consideration is the possibility of
oxidation   of   trivalent  chromium   to  hexavalent.
Examination of the redox potentials  of  the half-reactions
involved in the oxidation of trivalent chromium, as chromic
hydroxide,  to chromate  indicates that  the reaction  is
thermodynamically   possible  under   basic  conditions.
However, the reaction is not generally  observed to occur
due  to kinetic considerations;  specifically, a high energy
of activation is required.
      Work currently in progress by Dr. Robert Stephens and
some of his associates with the California Department of
Health, Vector and Waste Management Section in Berkeley,
California,  indicates  that sunlight provides  the  energy
required  for  first order  kinetic  oxidation of  chromic
hydroxide to  chromate  ion  in slightly basic  synthetic
solutions. Due  to  problems associated with the  analytical
determination of  hexavalent chromium, it has  so far not
been established if sunlight provides the energy necessary
for oxidation in actual waste samples.  However, hexavalent
chromium has been  found at  landfills receiving tannery
waste.

TREATMENT AND DISPOSAL TECHNOLOGY


     Sludges  from   waste-water  pretreatment/treatment
facilities are the  only  tannery  solid  wastes  which are
currently  treated prior to disposal. Treatment consists of
sludge  dewatering using either gravity or mechanical means.
Three mechanical  methods are used by tanneries: vacuum
filters,  centrifuges, and filter presses. All three are effective;
however, there seems to  be a decided preference for filter
presses  due  to the  drier  (40 percent solids) filter cake
typically produced. Gravity dewatering systems are used to
a limited extent, but usage is declining.
     Sludge dewatering  appears to be  the only type of
solid   waste   treatment   necessary  for  tannery   waste.
Chemical fixation  and detoxification  and  similar methods
of  treatment prior to disposal do not appear to be required.
                                                      -158-

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     Table   5  shows  the  estimated  percentages  of
potentially hazardous  waste disposed of via each of the
various  disposal methods.  Landfilling is  the predominant
disposal method for 60 percent of the waste.
     Most  landfills accept  all  types  of tannery waste,
including   waste-water  treatment   sludges.  Potentially
hazardous waste, including sludge,  is usually  mixed with
municipal   refuse,   compacted,   and  covered.  Landfill
operators  have noted  no particular difficulty  in  handling
tannery waste when mixed in this manner except when the
sludge  is not sufficiently dewatered. Landfill equipment has
become stuck  under  these  conditions.  In  one  instance,
sludge  which was not dewatered was dumped in a separate
area of a municipal landfill until it dried  sufficiently  to be
mixed  with refuse.  However, large quantities of tannery
waste  alone,   particularly  trimmings  and  shavings, are
reportedly difficult to spread and compact.
     Due   to  the  general  satisfaction  with  sanitary
landfilling and lack of regulations  to  the  contrary,  it  is
believed that virtually  all tannery waste will  be disposed in
landfills by  1983. The potential  for environmental damage
as a result of sanitary landfilling  of  potentially hazardous
tannery waste  depends on the  method  of operation and
site-specific  conditions. Although good engineering and site
selection in  conjunction with careful attention to operating
procedures minimizes the potential for leachate generation,
it does not totally eliminate the possibility  of leachate
contamination  of   surface   or  ground waters.  Data are
unavailable  on  the  extent of   environmental damage
resulting  from landfilling  of tannery  wastes.  However,
experience indicates that the potential for degradation does
exist. Thus,  it is recommended that leachate  collection
systems  be   utilized  to  minimize  the  possibility  of
ground water contamination at landfills  receiving  tannery
waste.
      Experience   during   the  conduct of  this  project
indicates that use of lined trenches for  sludge disposal is
also  an environmentally  acceptable practice.  In  such
situations,   adequate  provisions  should  be  made  for
diversion of  surface waters away from  the  trenches and
collection of drainage from the trenches. Collected drainage
should either be treated, or recycled to  the trenches where
climatic conditions permit. Use of certified hazardous waste
disposal facilities for tannery wastes would certainly be  an
acceptable  method of disposal, but it is not thought to  be
required.

TREATMENT AND DISPOSAL COSTS

      Disposal costs reported by tanneries ranged from  $2
to  $31  a ton (December '73 dollars) depending on the size
and  location  of the  tannery  and  quantity  of  waste
generated.   The  lower  disposal  costs  were quoted  by
tanneries which utilize municipal landfills where they are
not charged a user fee and pay only  for  collection and
transportation.  Tanneries  quoting  higher  costs  either
utilized  certified  hazardous   waste  disposal   facilities,
sanitary landfills, or generated relatively small quantities of
waste.
      The  capital  costs  associated  with  dewatering  of
waste-water  treatment/pretreatment sludges at a "typical"
tannery were  found  to  be  approximately  $300,000.
                                                      TABLE 5

                                    SUMMARY OF POTENTIALLY HAZARDOUS
                                           WASTE DISPOSAL METHODS





DISPOSAL METHOD

Landfills
Sanitary
Engineered
Converted Dumps
Dumps
State-Certified Hazardous Waste
Disposal Facilities
Lagoons and/or Trenches






ON-SITE

1
1
1
1

0
1
POTENTIALLY
HAZARDOUS
WASTE
(PERCENT)
OFF-SITE

Public

3
11
13
23

0
4

Private

6
13
11
1

6
4






TOTAL

10
25
25
25

6
9
                                                        -159-

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Assuming five year straight-line depreciation of the capital
cost and  necessary operation  and maintenance expenses,
the annual cost for sludge dewatering at a "typical" tannery
is $85,000 per year or $33/ton on a wet weight basis. As a
result, waste-water sludge dewatering and disposal accounts
for approximately 65 percent of the cost of treatment and
disposal for the entire industry. It was estimated that the
total  cost of  treatment  and  disposal for the industry  in
1974 was $3.2 million. To put this in perspective,  this is
0.67 percent of  the  value added in  manufacturing and
0.32 percent of the value of shipments for the  industry  in
1974. The increased cost associated  with  disposal  of
potentially hazardous waste in landfills, with provisions for
leachate collection, is estimated at $0.9 million.

ALTERNATIVES TO DISPOSAL

      The necessity  for waste  disposal   can  be reduced
through in-plant process changes and sale of certain waste
materials  as by-products. Several tanneries have developed
or are developing recovery and reuse programs designed  to
reduce chemical  consumption, cut costs,  and improve the
quality of their waste-water.  These  programs  include
systems for recovery and  reuse of hide soaking solutions,
beamhouse sulfide  liquors,  and  spent  chrome  tanning
liquors. Successful implementation of any or all of  these
techniques will reduce the quantity of waste-water sludge
which would otherwise be generated.
      Depending upon  forthcoming  State  and  Federal
regulations, particularly  those resulting from the Resource
Conservation  and  Recovery  Act of 1976 (PL 94-580),
tanneries  may find it cost-effective to reduce the generation
of  potentially  hazardous waste through the elimination  or
reduction of  hazardous constituents  used in  production.
Laboratory analyses of  skins  and hides  prior  to  tanning
indicate   that  lead, zinc  and  copper are present  below
natural background levels. These heavy  metals are  most
often  introduced  in  the  retan,  color,  and  finishing
operations in  the form of dyes and/or pigments. Chemical
suppliers  have  developed  substitute  pigments  for  those
containing lead, copper, and zinc. Similar substitutions have
already been adopted for pigments containing mercury.
      Segregation of hide  preparation waste-waters  from
those  generated  by  other  processes is another  method  of
reducing  the  quantity  of potentially  hazardous  sludge
generated, because chemicals containing  heavy metals are
used  only in the later  tanning and  finishing  operations.
Segregation  of  the hide  processing  waste-water stream
allows agricultural utilization of this sludge as a slow-release
nitrogen  fertilizer.   Waste  stream  segregation   is  also
advantageous from the standpoint of waste-water treatment
and   is  becoming  increasingly  prevalent  in  tanneries
installing pretreatment systems.
      "Splitting  to weight" which is the extremely accurate
splitting of  tanned  leather immediately to the  desired
thickness, also serves  to reduce waste quantities. A few
tanneries are currently employing this  process, which has
resulted in reduced processing costs, increased the value of
the  split  leather  removed, and  essentially  eliminated
shavings a? a waste material.
      The disposal  of  wastes can also be avoided through
the sale of "waste" materials as by-products. At the present
time, by-product utilization of tannery waste is volatile and
dependent upon location. Leather trimmings are sometimes
sold to foreign  manufacturers of small  leather products.
However, this market depends  on  a variety of  unstable
variables, including  freight  rates, hide  prices, labor  costs,
availability, and market demand. The major interest centers
on trimmings and shavings which have been tanned, but not
colored or finished. Products include fertilizer, animal feed
supplements, glue, and leather board.
      Leather board is currently  produced by defibrillating
shavings  in a  wet-pulper similar  to that used in
converting  wood  chips to paper  pulp.  Unfortunately,
trimmings are not compatible with this process due to their
size.  In addition, the economics  are such that processing is
feasible only  if  large supplies of  shavings are available close
to the leather  board  factory.   The  Tanners'  Council of
America, an industry  association,  is  investigating the
technical  and  economic  feasibility  of utilizing  other
methods of defibrillating leather wastes. The possibility of
incinerating trimmings and shavings for energy and chrome
recovery is also being explored.
      Unfortunately, there   has  been a trend away from
by-product  utilization  in the past decade or two. Ninety
percent of the fertilizer producers have closed and many of
the   major   chrome   glue  manufacturers   have   either
discontinued  or  restricted  production.  Reversal  of this
trend in the future may result from:  (1) increased cost and
difficulty in finding disposal sites that will accept the waste;
(2) concerted efforts at market  development, such as the
Tanners' Council study; and  (3) sound marketing practices.
A large portion  of  tannery waste  does have  a market
potential, and hopefully these  markets can be developed
and maintained.
                                                      -160-

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                          PETROLEUM REFINERY SOLID WASTE DISPOSAL PRACTICES

                                              Ronald J. Lofy, Ph.D., P.E.
                                                    SCS Engineers
                                                   Long Beach, CA
INTRODUCTION

     The Environmental Protection Agency during 1974
commissioned a number of studies on discrete American
industry  groups  for  the  purpose  of  determining  and
evaluating the extent of  hazardous  waste  generation within
each. These  studies attempted to assess the sources, nature
and  amount of potentially  hazardous wastes generated by
each  industry,   the  treatment  and  disposal  methods
currently  practiced,  as  well as the  associated  costs  of
disposal and/or treatment.
     Jacobs Engineering Company, Inc.  was awarded the
contract  to study  the  petroleum refinery industry, and
subsequently  retained SCS Engineers to  investigate  the
disposal aspects of the  solid  and semi-solid wastes generated
by the industry. My purpose, this morning, is to provide an
overview  of  how  petroleum   refineries   are  presently
disposing of their solid wastes and sludges.

APPROACH

     The data base for  this paper was obtained primarily
from the following sources:

   • Site  visits  to  16  refineries,  which   constituted
     6 percent of the 247 petroleum refineries in the U. S.
     and 18 percent of the  nation's refining capacity.

   • State and regional  regulatory agencies, particularly in
     California and the gulf states.

   • Knowledgeable  individuals   within  the   refinery
     industry.

   • County  and  municipal agencies and  private firms
     responsible for operation of disposal sites.

TREATMENT AND DISPOSAL PROCEDURES

     Much  of the material  wasted by refineries only 20 or
25 years ago has either been eliminated by process changes,
is now processed into marketable products, is recycled for
reprocessing, or  is sold to secondary material processors for
extraction of valuable constituents. Noble metal  catalysts,
caustic  solutions containing  phenolic  compounds,  and
alkylation sludges reprocessed for sulfuric acid are examples
of such waste streams. Only materials actually  disposed of
to the land directly by the refineries fall within the scope of
this study. The  types  of wastes requiring disposal include:

   •  Crude Tank Bottoms
   •  Slop Oil Emulsion  Solids
  •  Non- Leaded Tank Bottoms
  •  API  Separator Sludge
  •  Dissolved Air Floatation Float
  •  Waste Biosludge
  .  Spent Lime from Boiler Feedwater Treatment
  •  Once-Through Cooling Water Sludge
  .  Storm Water Silt
  '•  Cooling Tower Sludge
  •  Neutralized HF Alkylation Sludge
  •  Lube Oil Filter Clays
  •  Exchanger Bundle Cleaning Sludge
  •  Fluid Catalytic Cracker (FCC) Catalyst Fines
  •  Coke Fines
  •  Kerosene Filter Clays
  •  Leaded Gasoline Sludge

     All  17  solid waste streams  are considered hazardous
because of the presence of one or  more contaminants above
levels considered safe. The contaminants in many cases are
a combination of oil and/or one or more heavy metals.
     The  various   technologies  for  treatment  and/or
disposal of these 17 potentially hazardous wastes streams
are described below.

Landfilling

      Landfilling is presently the  most widely used method
for  disposing of all  types  of petroleum refinery  waste
products.  The  environmental adequacy of this method is
contingent not only upon the  types and characteristics of
generated wastes, but also upon methods of operation and
upon site-specific geologic and climatologic conditions. Of
all the land disposal  methods used by the refining industry,
perhaps the  greatest variations in operations  and  in site
suitability are  experienced  with  landfills.  Landfilling
operations range from open dumping to controlled disposal
in secure landfills, most of which occur in western states.
      Several  on-site  refinery  landfill  operations were
observed  to  employ  good,  current  practices.  Special
problems  were  noted in  gulf state refineries  where water
table levels  were near the surface.  The major  problems
associated with most  landfill operations, as  well as other
disposal   technologies,  were  related  to  soil suitability,
facility design and  operation, and site development for
disposal   of  potentially  hazardous wastes. Many  of  the
landfill  sites  observed   would  probably be  designated
Class II-2. The  California definition of a Class II-2 landfill is
a site  which allows vertical and  lateral continuity with
useable ground water, but which has hydraulic and geologic
features which will assure some protection of the quality of
useable ground water underneath  or  adjacent  to the site.
These  requirements may be based upon soil type, artificial
barriers, depth to ground water, or other factors, for which
considerable site-to-site variation may  exist.
                                                       - 161 -

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Landspreading

      Landspreading is a relatively inexpensive  method of
disposal of petroleum refinery wastes which is  being used
by  a  growing  number of  refineries.  The  majority of
refineries contacted which employ landspreading have done
so for only one to four years; only a few have a working
experience with this process for a longer period of time.
      More than  100 species of bacteria, yeast, and fungi,
representing 31  genera, a.e known to attack one or more
types of petroleum hydrocarbons (1—7). Studies indicate
that   pseudomonous   bacteria   quickly   become   the
predominant microbes in the soil (8). Soil moisture appears
to be  a  significant factor in the rate of growth of these
bacterial populations; growth is  inhibited  when the  soil
moisture content falls below about 20 percent. Bacteria
quickly  degrade  the  oil  using  the  hydrocarbons as  a
substrate  for their  growth.  As the degradation  process
proceeds, the material changes from an oily, odorous black
sludge to a dried, cracked, cakey, soot-like material which
crumbles easily. The  oily characteristics of  the sludge are
lost after a short period of time. The microbial by-products
may change the soil moisture available to  plants,  reduce
iron and aluminum which  may accumulate to injure plants,
or release  nutrients which stimulate  plant growth. Various
salt marsh species have entirely different tolerances to oil
(9, 10). Most of the damage to plants appears to result from
their  inability to  obtain sufficient moisture  and air due to
physical obstruction (11).
      The  landspreading process is suitable for disposal of
almost any oily  waste  material  generated   within  the
refinery. Waste material is pumped into a vacuum truck and
conveyed  to a  disposal site. The oily  waste  is spread as
evenly as  possible on  the  assigned  land area.  The actual
depth of  application is  determined by experience,  and
varies with oil composition, the soil's moisture and nutrient
content, climatologic conditions, and amount of available
land. The application rates for oily sludge vary from one to
two inches in  thickness  in  the northwestern  U. S. to as
much as 3 and 4 inches in the warmer, subtropical climates
of  the  southwestern   U. S.   This  is   equivalent  to
1500—3000 gal./ac./yr.   The   rate   of  degradation   and
disappearance of oil requires between one and six months,
depending upon the thickness of the sludge deposit, percent
by weight  oil  content,  amount of fertilizer  used,  and
frequency   of   tilling.  After   much  of  the  water  has
evaporated, a tractor-drawn plow or rototiller is used to
break up the oily crust and mix it with the surface soil. The
frequency  of rototilling, plowing and aeration  varies from
one   location   to  another.   Although  some  of   the
hydrocarbons are evaporated as a result of  landspreading,
there  is  no  noticeable odor,  nor  is  there grounds for
concern about spontaneous combustion or flammability.
      Soil characteristics are reported to change with time.
In  one  instance, the  initial  bentonite  clay,  which  had
previously  dried to a very hard  cake, changed to  a  soft,
loamy  soil,  presumably due  to increased  organic  and
moisture content. The oily sludge material apparently does
not decompose  and disappear completely, because a small
fraction of the oil  remains combined with or interspersed
between  the individual soil  particles. The  oil-conditioned
soil appears to retain more moisture than native soil.
      Up  to this  time,  refineries  have been  concerned
largely with possible oil  contamination  of ground  and
surface waters which may result from landspreading.  The
real  concern is  not  only the  recognized short-term oil
problem  and incomplete  treatment of  organic acids  and
other  intermediate   by-products,   but  the  long-term
implications of trace metal  accumulation  in the soil  over
long periods of operation. The problem posed by disposal
of heavy metals on or in land is the same for all treatment
and  disposal  techniques.   The  major  difference   is a
quantitative one, with repeated  applications of oily wastes
to  the   same  land  areas  potentially  producing  greater
concentrations  of  heavy  metals than would result from
other disposal methods.
      An  assessment of the environmental adequacy of
landspreading  can  perhaps  best be made  by  comparing
alternative methods. The  desirability of  burial of these
wastes in a landfill is questionable because that petroleum is
not  degraded appreciably under anaerobic  conditions.  If it
were, there would be no  oil present in the world today.
Conversely, hydrocarbon seepages at the earth's surface are
not  known to exist in large concentrations or to be very old
geologically, because aerobic  bacteria  quickly  degrade
petroleum fractions to residual waxes and paraffins.  Oily
fractions deposited in a landfill are merely sequestered  for a
period of time  until they percolate or leach out. It  thus
becomes  important that  landfills be of a  secure type to
prevent this outward migration  of oil and  other hazardous
constituents.
      Even incineration, which destroys most of the organic
petroleum   fraction,  can  volatilize  certain trace  metal
constituents and organic compounds, and then release them
into the atmosphere.
      As progressively more oil is removed from refinery
waste  streams, disposal by incineration  will become an
endothermic process  requiring the application of additional
energy  to sustain combustion. Landspreading  does  not
require  the use  of external energy  to degrade marginal
fractions  of oily material,  because these substances are
effectively destroyed through natural aerobic degradation.
The problems  presented  by conservative  trace elements
once in the ground are similar whether they are present in
residual ash as a result of incineration, in a sanitary landfill,
or as a result of landspreading. It would appear, therefore,
that  landspreading may  be emerging as  an  important
method  for the disposal of  refinery oily wastes.  Industry
personnel indicate complete satisfaction with related costs,
effort, and  with  the surprising reliability and efficiency of
oil   degradation.  At the  present   rate of  two to three
applications annually, the  amount  of land space actually
required is comparatively small.
                                                        -162-

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Lagoons, Ponds, Sumps, and Open Pits

      Lagoons, ponds, sumps, and open pits have been used
for many decades by  the petroleum refining industry for
the disposal  of liquid and  semi-solid waste. In the  past,
convenience   and   easy  accessibility   rather   than
environmental  considerations  dictated   disposal   site
locations. Action is now being taken by a number of states
to phase out the use  of sumps and  lagoons as permanent
disposal  methods,  allowing them  to  be used only  as
temporary  retention  or treatment  ponds.  Because  of
simplicity and ease of construction, many of the  newer
refineries make considerable use of earthen or lined lagoons
as: primary  or secondary sedimentation  chambers; aeration
basins or emergency oil spill retention basins; or oxidation,
storm runoff,  evaporation,  or  thickening ponds. Of the
refineries visited, only one made use of a lagoon for the
disposal  of the  majority  of its wastes. Two  others had
recently   instituted  the  use  of sumps as a  temporary,
expedient method of disposing of tank bottoms and spilled
oily materials.
      The environmental acceptability of lagoons for any of
the prescribed purposes  is dependent upon the method and
materials of  construction,  specific  local  hydrogeologic
conditions,  and the types of waste handled. Unfortunately,
the potential for significant contamination of underlying
aquifers  from  many  inadequately lined lagoons, both old
and new, is appreciable because of improper location and
inadequate  safeguards.  Although many of  the units are
perfectly acceptable,  some attention needs to be paid to
ensuring  that  adequate  design  and construction practices
are followed in areas with high  water tables, porous soil, or
other adverse conditions.     -*

Incineration

      Incineration of semi-solid and solid wastes requires a
special type of system which provides  adequate detention
times, stable combustion  temperatures, sufficient mixing,
and high heat transfer efficiency. A fluidized bed is one of
the few  systems which appears to satisfy these criteria.
 Refinery wastes known to be incinerated by such systems
 include  spent caustic solutions, API  separator bottoms,
 DAF float, waste  biosludge, and slop oil emulsion  solids.
 Experience has shown that the  reaction is self-sustaining if
the thermal content  of the total wastes  incinerated exceeds
 about 29,000  Btu  per gallon. Loss of fluidization and
 plugging of the bed is still a major problem in the operation
 of these units.  The  only refinery  visited which  had an
 incinerator mentioned that mechanical problems with the
 unit  were  responsible for  significant periods  of  "down"
 time. Storage pumps and  basins  had been provided to
 handle the waste during these periods.
      Because   several   of   the    trace   metals    under
 consideration  in  this study are volatile  at temperatures
 normally encountered  during  incineration, expensive air
 emission control devices are required where air pollution
 emission requirements  are  stringent.  During combustion,
 organic   and  metallic  materials   are  converted   into a
 multitude  of  compounds.  Some are partially  oxidized  or
reduced and  their properties substantially changed. Others
remain chemically unaltered, changing only physically from
a solid to a gas. Recent incineration studies have shown that
volatilized  metals are  absorbed to a large degree by fine
paniculate matter. This material is so fine that many of the
conventional  air  emission  control devices remove only a
small percentage of it. Metals of most concern emitted from
these  incinerators  (as  well   as  fluid  catalytic  cracker
regenerators) are beryllium, nickel, and vanadium.
      Disadvantages expressed by several refinery managers
and plant engineers concerning the incineration process are:

   •  The  process has a high  capital cost, as well as high
      recurring   annual operation and maintenance costs.

   •  Because of the increased value of oil, as much oil as
      possible  is  now  extracted  from  all refinery waste
      streams.  Thus,  the  thermal  value  of the  various
      sludges (particularly those that had to be  blended
      with oily wastes) is decreased to such a point that  the
      combustion   reactions   are    either   no   longer
      self-sustaining   or only  marginally   so.  Continued
      operation  of  incinerators  thus  requires either that
      valuable  oil is  left  in  the various  wastes or that
      additional  thermal energy is supplied to the process,
      further increasing actual operating costs.

    »  The implementation  of  increasingly  strict   air
      pollution   regulations   may   mandate  extremely
      expensive  and  complicated  air  pollution  control
      devices at some future date.

    •  More economical and equally  efficient treatment  and
      disposal methods are becoming available.

 Deep Well Disposal

      Subsurface or  deep well  injection is  an  ultimate
 disposal  method which  originated with  the oil  and  gas
 extraction industry.  Connate brines, separated from  the
 extracted gas and oil, are  pumped back into the formations
 from which  the  fluid is originally taken, thus restoring the
 formation   pressure  and  facilitating  the  extraction  of
 additional gas and oil. Gradually, the  injection practice has
 been extended  to  include a multitude  of  wastes which
 would be difficult to dispose of by any other means.
      Only  one  of  the  16 refineries visited practiced deep
 well   injection   of   waste   solutions.   Approximately
  186.5 million  gallons per year are injected, consisting of
 sulfidic solutions generated  by caustic washing  of crude
 cracking  and  hydrotreating  streams,  sour water  from  a
 hydrotreating unit,  brines from the desalter operation, and
 other weak solutions from crude processing and pretreating.
       Several refineries in the southern California area are
 known  to inject waste brines into deep  wells. Deep  well
  injection  capital and operating costs can be considerable.
  The future  of  deep well injection has been clouded by
  recent legal  and  regulatory agency decisions (12,13).
                                                        -163-

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 Ocean Disposal

       The  1971 Dillingham report (14) for the EPA on
 ocean  disposal of barge-delivered liquid and  solid wastes
 reported  that  approximately  500,000  tons  of  refinery
 wastes have been dumped into the ocean. Sporadic records
 obtained from southern California refineries indicated that
 on random occasions small quantities of barge-transported
 alkaline  or acid solutions  have  been  disposed  off  the
 California  coast.  This practice  was terminated some time
 during the late 1960's. It was reported that, until recently,
 certain petroleum refinery wastes in 55-gallon drums were
 still being  dumped in the Gulf of Mexico by one or more
 gulf state refineries.
       The  Marine Protection  Act of 1972 (PL 92-532)  has
 transferred regulation and control of all ocean dumping from
 the district office of the U. S. Army Corps of Engineers to the
 Environmental Protection Agency. Ocean disposal of certain
 prescribed  hazardous wastes is prohibited, while permits for
 other less hazardous wastes are becoming increasingly
 difficult to obtain as alternative methods of ultimate disposal
 become available. Present trends indicate that ocean disposal
 will be gradually eliminated.

 Leaded Gasoline Sludge Treatment and  Disposal

       Because  organic lead vapors are known to be toxic at
 very    low  concentrations   (approximately   0.075   to
 0.15 mg/m^,  depending  on   lead  compound),  special
 procedures  have been  developed  exclusively  for   the
 treatment and  disposal  of leaded gasoline sludges which
 accumulate in aviation and motor gasoline storage tanks.
      The survey team encountered two basic procedures
 for  the disposal  of  leaded-gasoline sludge from gasoline
 product storage tanks. The procedures were developed and
 disseminated to  the  refineries  by   the  two  primary
 manufacturers,  the  Ethyl  Corporation and  DuPont. The
 first procedure is the older of the two and has largely been
 superseded by an improved method which  assures faster
 and more  complete  degradation. The  older  procedure
 involves the construction of a pond adjacent to the tank to
 be  cleaned. After the tank  contents,  except  sludge, are
 pumped to  another  tank,  the sludge  is pumped into the
 pond  to  evaporate  and  weather  in   place.  After  the
 tetraethyl lead concentration has diminished to less than 20
 ppm, the soil berm surrounding the sludge pond is pushed
 in and the sludge buried.
      With the newer procedure, the sludge is either spread
 in the tank  dike area to a depth of four to  six inches, or
 transported to a weathering pad elsewhere in the refinery.
 After it has degraded to less than 20 ppm organic lead, it is
 either  rotodisked  into the soil  within  the  diked area or
 taken  from the pad and buried  elsewhere  on  refinery
 property. The volume of leaded-gasoline sludge generated is
quite small and the  frequency of cleaning is subsequently
 low, on the order of every  one to ten years. Even then, the
frequency  of tank cleaning is dictated more by required
tank maintenance than by need for sludge removal.
 Chemical Fixation

       Another special  practice observed  in treatment  of
 both liquid and  solid wastes is that of chemical fixation.
 Among the chemical fixation methods used are:  (1) Use of
 chemical coagulants to create an insoluble precipitate. Only
 one waste stream in  the refineries visited is  deliberately
 treated to produce a chemically inert precipitate. This is the
 routing of cooling tower blowdown containing hexavalent
 chromium  through  the  API  separator  where  available
 sulfides bring about the reduction of hexavalent chromium
 to trivalent  chromium.  From the  API  separator, the
 now-reduced  chromium ion  is routed through  the spent
 lime slurry tank  where it is further precipitated by lime  to
 chromium  hydroxide.  The  lime  sludge  containing the
 precipitated  chromium  hydroxide  is usually  removed by
 vacuum truck. (2) Sorption of solvent-like hydrocarbons on
 imbiber beads. (3) Chemical fixation or solidification.  This
 method is used by a few refineries to solve specific disposal
 problems,   such   as   the  permanent  disposal  of
 environmentally   unacceptable  lagoons filled  with  API
 separator bottoms or crude  tank  bottoms. The Chemfix
 Process is an example of such a chemical system.
      One   of   the   Texas   refineries  visited   had  an
 accumulation of  API  separator bottoms "Chemfixed"  in
 February of 1974. Although samples previously  tested by
 the Texas Water  Quality Control Board had not produced a
 significant leachate  problem, the  Board had  nonetheless
 insisted that the  material be placed in a landfill  with a large
 dike around it to prevent surface runoff.  The Board  also
 required that approximately 2 feet of cover dirt  be placed
 over the waste as  a precautionary measure.

 Special Treatment and/or Disposal Practices

      A procedure for reducing the volume of crude tank
 bottoms, observed in at least one of the refineries visited, is
 the use of polyelectrolytes. The process is performed prior
 to cleaning the tanks, at which time any crude oil remaining
 in the  tank is  pumped out to the sludge layer and replaced
 with approximately  5,000 to 6,000 barrels of  "off-gas"
 from field wells.  The material in the tank is heated with
 steam  and  mixed with  the  crude  tank  bottoms to  a
 temperature of approximately 130°F.
     The results  exceeded expectations. The crude sludge
 was broken  down into a very distinct oil fraction and an
 underlying  clear  water fraction, both of which  could be
 separately decanted from the tank. The total quantity of
 residual sludge out of  a 125,000 barrel tank amounted to
 seven barrels.  It was found, furthermore, that when this oil
 fraction was pumped into a different crude oil storage tank,
 it helped to effect a separation in that tank as well.
     The same refinery observed that crude tank bottoms
 and API separator sludge exposed to alternate freezing  and
 thawing during winter months in  an  open sump had  a
considerable layer of oil on the surface the following spring.
 Subsequent laboratory  tests revealed that alternate freezing
and  thawing  does  indeed  break  the  emulsions  to  a
considerable degree. The refinery is planning to expand the
facility and to perform a controlled study of the method.
                                                      -164-

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                   REFERENCES CITED

1.  Ellis,  R. and R. S. Adams.  1961. Contamination  of soils by
       petroleum hydrocarbons. Advanced Agron. 13:192.

2.  Davis, J. B. 1967. Petroleum microbiology. Elsevier Publishing
       Company, New York.

3.  Beerstecher, E. 1954. Petroleum microbiology; an introduction
       to  microbiological  petroleum  engineering.  Elsevier
       Publishing Company, Houston.

4.  Byron,  J.A.,  S. Beastall, and  S. Scotland.  1970.  Bacterial
       degradation of crude oil. Marine Pollution Bull.

5.  Gossen, R. G. and D.  Parkinson. 1973. The effect of crude oil
       spills on the microbial populations of selected Arctic soils.
       Biomass  and  Respiration.  (Canadian)  Journal  of
       Microscience.

6.  McKenna,  E. G. and R. E.  Kallis.  1965.  The  biology of
       hydrocarbons.  Annual Review of Microbiology.

7.  McCowan, B. H., J. Brown, and R. P. Murrmann. 1971. Effect
       of  oil seepages and spills on the ecology and biochemistry
       in  cold-dominated environments.  U. S. Army  CRREL,
       Hanover, N,H.
 8.  Adams, R. S. and L. Ellis.  1960. Some physical and chemical
         changes in the soil  brought about by  saturation  with
         natural gas. Proc. Soil Sci. Am. 24:41.

 9.  Cowell, E.  B.  1969. The effects of oil  pollution on marsh
         communities  in Pembrokeshire and Cornwall. Journal of
         Applied Ecology, 6:133.

10.  Zobell, C. E. 1969. Microbial modification of crude oil in the
         sea. In Proceedings, joint conference on prevention  and
         control of oil spills, Washington, D.C. pp. 317—326.

11.  Plice,  M.  J. 1948. Some effects  of crude petroleum on  soil
         fertility. Proc. Soil Sci. Soc. Am., 13:413.

12'.  Ricci, L.  J.   1974.  Injection wells  iffy  future. Chemical
         Engineering, 81 (161:58.

13.  Ruckelshaus, W. D. 1973.  Administrator's decision statement
         No. 5:  EPA policy on subsurface emplacement of fluids
         by well injection.

14.  Smith,  D.  D.  and R. P.  Brown.  1971.  Ocean  disposal of
         barge-delivered liquid and solid wastes from U. S. coastal
         cities.  EPA   OSWMP  Report   No. 5W-lac,  U.S.
         Environmental Protection Agency.
                                                               -166-

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                               THE SOURCE, QUANTITY, AND FATE OF MERCURY
                                     AND ITS COMPOUNDS IN SOLID WASTES

                                     William H. Van Horn and Gary G. Kaufman
                                                   URS Company
                                                   San Mateo, CA
      URS recently completed a study for the Office  of
Toxic Substances of the Environmental Protection Agency
(EPA)  titled   "Materials   Balance   and   Technology
Assessment of Mercury and Its Compounds on National and
Regional  Bases" (1).  A  portion  of this study was
directed at the study of the source and quantity of mercury
and mercury-containing compounds which are discarded as
solid wastes each year and the fate of these mercury wastes
in the environment. However, before turning to the subject
of solid waste,  we  will consider the general characteristics
of mercury, how it can and does enter the environment, its
relative toxicity, and its general  usage pattern.
      All  soils  and  sediments  contain trace amounts  of
mercury or  its compounds.  Because of the unique physical
and chemical properties  of mercury, it migrates relatively
easily from  one physical and/or chemical  state to another.
Thus,  soils  and sediments continually  emit   mercury,
normally  in the elemental form, which passes into the air,
where it remains until it is washed  out of the air, probably
by rainfall,  moving thence into  bodies of water or returning
to the earth's  surface  (2).   Sediments in particular, can
also  form  (typically  through  bacterial action,  although
some chemical  processes may also be involved) soluble
compounds  which  move  directly into water.  A  very
simplified schematic of this process is shown  in Figure 1.
      Man mines mercury deposits and uses the resultant
metal  or  mercury  compounds   in  a  wide  variety  of
applications; ultimately,  most mercury used by man is
discarded  and is returned to the environment — air, water,
or land— as shown  in  Figure 1.   The  mercury that is
returned to  land is usually in the form of a solid and, as will
be discussed later,  ultimately  becomes available to other
environmental receptors, notably air or water.
      Since  mercury abounds naturally, it is of interest to
estimate  the   relative  contribution  from  natural  and
man-related  sources. Figure 2 provides such an estimate,  on
an  annual basis, for the conterminous United States.  An
estimated 2.7 million kilograms of mercury is released  to
the  environment each year. Over  half  of the mercury
released to  air and  water is traceable to natural  sources;
natural  occurrence in  land has not been estimated, although
the number is  very  large,  since no perturbation of  the
environment is  normally  involved.  Thus,  it   must  be
recognized that, while man does contribute to the mercury
burden  within  his environment, his contribution is only a
part of the total.
      Figure 3  indicates the  normal  range  of mercury
concentrations  found in  air, water, and land, and existing
EPA  standards as related to air and water. Presently  no
regulations  exist  on the  mercury content  of  sanitary
landfills,  although  standards  for  disposal  of  industrial
wastes are in force. Although the normal range of mercury
in air and water is below EPA standards, higher levels are
occasionally reported and are often traceable to industrial
discharges.  Of  particular  concern are industrial  mercury
discharges to water and thence to sediments where bacterial
action can  occur  forming  the very  toxic methylmercury
which is associated with several well-publicized incidents of
human poisoning.  However, since this particular hazard has
been  recognized, standards on  discharges to air and water
have been promulgated to prevent such future occurrences.
Similar standards have not  been applied to land because no
threat to  man and his  environment  from  land-based
mercury sources has been demonstrated. As a  result, most
mercury  from  man-related  activities  is  now discharged
directly to the land.
      As shown in Figure 4, the annual  mercury losses to
the environment are highest to land, much less to air, and
low to water.  Also of  interest in Figure 4 are the losses
generated by the major economic sectors within the nation.
Mining and smelting, which includes mercury,  copper, and
zinc production, results primarily in discharges of mercury
to the air.  Unregulated sources, which  includes mercury
discharges resulting  from  fossil-fuel  burning, incineration,
and human and animal waste disposal, results in appreciable
losses to the air and lesser losses to land. The manufacturing
sector, through which most mercury ultimately used by the
consumer must pass, results in rather small losses to air and
water with  discharges to  land, primarily in the form of
sludges, predominant. These discharges to land are expected
to  decrease  dramatically  in  the  future years as  new
technology and more stringent standards evolve. The major
loss to the environment arises from the final consumption
sector which includes  both commercial, industrial,   and
consumer   consumption.  Again, the  discharge  to  land
predominates.
      Figure  5  has been  prepared  to show the annual
consumption of   mercury  in  the United States and to
indicate use patterns. Of the  total of 1.5 million kilograms
used   in   1973,  almost  a   third  was  consumed  in
manufacturing processes, predominantly the production of
chlorine  in  mercury cell  plants. This industry is  now
regulated by EPA standards, and the  consumptive use is
decreasing  yearly.  Part  of the decrease is attributable to
improved  technology  within  the  industry  and part to
conversion to other processes which do not require the use
of  mercury.  Final  consumption usage  of  mercury is
predominated  by electrical   and   battery  applications.
Mercury, because of its unique properties, finds a variety of
uses in switches, lights (including fluorescent lights), special
equipment,  etc. While some  reclamation or recycling of
mercury in these applications is possible, little improvement
is forecast for the future.
                                                        166

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                       FIGURE  1

                ROUTES OF MERCURY
                 INTO AIR & WATER
           NATURE
o>
•vl
          SOILS-
          SEDIMENTS
      MAN
                      AIR

 SOLID
WASTES
ALL
USES
                     WATER

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             FIGURE  2
  RELATIVE CONTRIBUTION FROM
NATURAL & MAN-RELATED SOURCES
           TOTAL- 2,732,000 K6
                             n
                             M NATURAL

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                      FIGURE  3

            EXISTING  EPA STANDARDS &
              ENVIRONMENTAL CONTENT
                                     LAND
O)
CO
     8
     o
1000
100
10

1
I
Q!
0.01
O.OOI
—
A!R WATER
••
	 A 	 FDA


I
^NORMAL RANGE •
IT


1








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                          FIGURE  4

                ANNUAL  MERCURY LOSSES
             TO THE ENVIRONMENT BY SOURCE
        800-
-4
O
        600-
      15
§400-
.4^
K^
3
|a»|.
           MINING
             &
           SMELTING
                     AIR
 WATER
 LAND
                                          CONSUMPTION
U NREGULATED  MANUFACTURING

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               FIGURE  5
CONSUMPTIVE  USES OF MERCUW-1973
              BATTERIES
    ELECTRICAL
     CHLORALKALI
                              MANUFACTURING
                             \FINAL CONSUMPTION
                    TOTAL = 1,S2S,OOOf
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      Almost all  dry cell  batteries contain mercury and
most  such batteries are  not recycled. The elimination of
mercury from  batteries, at  least in  the near  future,  is
unlikely,  and  unless  Federal  standards  are  changed,
recycling is unlikely to increase appreciably.
      Relatively nontoxic  organic forms of mercury are
used as stabilizers and preservatives in water-based paints.
Despite attempts  on the  part  of  the industry and the
government  to  find  suitable substitutes,  these mercury
compounds  are still found  to be superior and are unlikely
to be eliminated as a use of mercury in the near future.
These organic mercury compounds are volatilized after the
water-based paint  is applied and contribute largely to the
man-related mercury which is found in air. Small amounts
also can be found in solid  wastes (in  painted debris, or in
discarded  paint cans)  where  they form a rather minor
amount of the total.
      Mercury also finds  a  multitude of other uses ranging
from  laboratory  to  dental  and pharmaceutical  uses.
However,  these uses, while oftentimes  unique,  do not
appear to offer any particular problems or hazards and are
likely to  continue. We will now turn to consideration of
how mercury in solid wastes affects the municipal solid
waste stream.
      As can be seen from  Table 1, a considerable amount
of mercury from  the disposal of such items as batteries,
instruments, switches, pesticides, fluorescent  lights, and
sewage  sludges  reaches the  municipal solid waste stream. In
fact, our calculations indicate that about 96 percent of the
mercury in  municipal solid waste is due to the disposal of
these items.  Once in the municipal solid waste stream, the
mercury may add to the existing environmental inventory
of the  metal by such processes as incineration and land
disposal.
                       TABLE 1

               SOURCES AND ANNUAL
             QUANTITIES OF MERCURY
                 IN U. S. MUNICIPAL
                   SOLID WASTES
SOURCE
Batteries
Instruments
Switches
Pesticides
Lights
Other
Total
QUANTITY
(KILOGRAMS)
403,000
108,000
46,000
38,000
37,000
15,000
647,000
     The flow of mercury in the solid waste stream, from
processing   to   environmental   disposition,   is   shown
schematically in Figure 6. The total quantity of mercury, in
kg, corresponds to that which  might be produced by a
typical  community  of  about  375,000;  the  relative
quantities of mercury allocated  to incineration  or landfill
are based upon  national averages. These national averages
must be applied cautiously since  incineration is widely used
on the East Coast but less elsewhere.
      Incineration without scrubbing is a very poor means
for disposal  of mercury  in municipal solid waste  because as
much as 90 percent of the incoming mercury may be lost to
the air environment  (3). With scrubbing, the amount
of mercury  lost through volatilization can be reduced to
below  50 percent, but  the problem  of disposal  of the
mercury-laden wash  water still remains. These loss figures
were collected from full-scale units that did not attempt to
maximize mercury capture. It is quite possible, however, to
design  systems that capture mercury more  efficiently, but
the requirement to do so has not  been established.
      Table  2 lists the ultimate  fate of the  mercury in all
U. S. municipal solid wastes in 1973 and 1983. We project
that during  this  10-year  period the total quantity of
                       TABLE 2

        ESTIMATED MERCURY LOSSES, IN KG,
                FROM U. S. MUNICIPAL
               SOLID WASTE DISPOSAL
RECEPTOR
Air
Water
Land
Reclamation
Totals
1973
49,000
22,000
575,000
647,000
1983
29,000
7,000
548,000
63,000
647,000
              3.6 percent of this total is first
              accumulated in sewage sludges.
mercury  in solid wastes will  not increase, reflecting a
growing awareness  of  mercury's  toxicity and a resultant
decrease  in  its  use. However, the impact on the receptor
environment  during   the  same period  will   decrease
significantly. We project  that modern technology  which
includes the use of  efficient scrubbers on incinerators (and
possibly  less reliance  on incineration),  improvements  in
landfill  practices which  will  reduce  the possibility   of
leaching, and  a  greater  concern with  reclamation, will
reduce emissions to air and water, which are the primary
concern  of man,  from  almost  11  percent  to  about
5.6 percent  of  the  total  mercury  loss  each  year.  On a
national basis, these values are encouraging. However, at the
local level, emissions of mercury to either air or water must
be a continuing concern to ensure that improper operations
do not lead  to  excessive losses and result in local hazardous
conditions.
                                                      -172-

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                      FIGURE  6

           FLOW OF MERCURY IN TYPICAL
         MUNICIPAL SOLID WASTE STREAM

CO
         IN
             (COO
                  925".
LAND
FILL
                         9O2
ALL VALUES IN KG.
                                6
                                s
                              LAND
                                   68
               I
                                     AIR
/
1


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                FIGURE  7

    THE FATE OF MERCURY PLACED IN A
    MUNCIPAL SOLID WASTE LANDFILL
      AIR
                VOLATILIZATION
EARTH
               TRANS FORM A TION
              PERCOLATION
ATTENUATING ACT/ON
 OF SOIL LAYER

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     Because  mercury does  seem to be tightly  bound in
the landfill environment, it is instructive to look at some of
the mechanisms and  transport processes that control the
fate  of  mercury  in  the  landfill  environment.  As  was
mentioned  previously,   most  of  the  mercury  in  the
municipal solid waste stream is in the form  of  discarded
manufactured  items such  as  batteries and switches. While
the form of mercury  in  these items varies from  elemental
mercury  to mixtures  of elemental mercury and mercury
salts, the predominant feature of the incoming mercury is
that  it is tightly  bound and concentrated; generally the
mercury will be in inorganic form  and only slightly soluble
in water.
     Although   there   may   be   some   crushing  of
mercury-containing items during compaction, once in the
landfill they are subject  to little or no external  force and
tend  to maintain their physical integrity.  Consequently, the
amount  of mercury  intimately  exposed to  the  landfill
environment is relatively small in  comparison to the total
mercury content of the  landfill. An example of this surface
area  limitation has been shown  in leaching tests done on
columns  containing   mercury cell batteries  mixed with
various   inorganic  and  organic   media  that  might  be
characteristic of a landfill environment.  In an unpublished
study,  it  was found that the total loss of mercury from the
batteries   over  a  4V2-month   period  was  0.5 percent
Evolution is likely to continue slowly over the life of the
landfill, and beyond.
     Once the mercury is liberated  from  the surface, as
shown  in Figure 7, it  must be transported across either the
air-waste  or ground-waste interface if  the released mercury
is to add to the general mercury  circulation. In order for
the mercury to be transferred across the  air-waste interface
it must either be  in  the elemental form or in an  organic
form  such as monomethylmercury  or  dimethylmercury.
Although  these organic forms are less volatile (but much
more toxic) than  metallic mercury, it is expected that they
would  be  found  in  landfill  gases. Elemental  mercury in
landfill gases  could   be  formed by volatilization  from  a
metallic  surface,   from  the  disproportionation  reaction
and/or from the action of bacteria on both  mercuric ion
and organic mercury. Organic mercury compounds could be
formed by  the action of bacteria on the mercuric ion. Once
in landfill  gas, these  mercury compounds could cross the
air-waste  interface either through the  general movement of
landfill gases to the surface or through diffusion driven by
concentration  gradients.  Unfortunately, at  the time at
which  this work was  completed, no experiments had been
carried out to  determine  the concentrations  of either
elemental  or  organic  mercury   in  landfill  gas.  It  was
concluded, though, that the rate  limitation on  release of
mercury  from the concentrated  source itself effectively
limits that found in  landfill gases. It was  also concluded
that  the rather slow movement of  landfill gases would limit
transport  across   the   air-waste  interface  by  either
advective/or  diffusive  mechanisms.  Advective  transport
would  be the  movement of mercury with the air mass itself
while diffusive movement  would  be independent of air
movement  and would depend on  concentration gradients.
     At the  ground-waste interface, transport could again
occur through  both advective  and diffusive mechanisms.
Advective transport would occur when mercury in solution
(in  the  elemental or ionic form)  or in a soluble complex
moves   across the  ground-waste  interface  due to water
movement. Diffusive movement might occur as a result of
concentration gradients of mercury in solution. Although
there are no data available on the relative  importance of
each of these mechanisms, the work that has been done
seems  to indicate  that little  mercury is lost  from  the
concentrated sources found in  landfills, and  when mercury
is lost the high immobility of mercury in the waste and soil
environment  limits its movement.
      For instance, in one  study   (4)  in  which chemical
analyses of landfill  leachate and downslope  observation of
well water  were  made,  mercury  concentrations  in  the
leachate ranged from  0.05 to 16.3 ppb with  most values
below  the EPA  drinking water  standard of 2 ppb. The
mercury content of water taken from the  wells downslope
of the site, which were  being affected by other more mobile
constituents  in the leachate, showed no increase in mercury
concentrations  above   the background  levels normally
found.  According to an unpublished review paper prepared
by   the  EPA's  Solid and  Hazardous  Waste  Research
Laboratory in Cincinnati, the mechanisms most responsible
for  this immobility are:  (1) valence-type adsorption by
both inorganic  and  organic  materials;  (2) formation of
covalent  bonds;  and  (3) formation  of  low  solubility
mercury salts with such anions as S=, PO T  and CO3=.
      In summary then, it would appear that the physical
nature  of the  mercury  in   solid  waste  and  its  high
immobility   in the  waste  and soil  environment  makes
disposal of mercury-containing items in a properly designed
and operated landfill  environmentally acceptable. If the
addition  of   increasing amounts  of  mercury  into  the
atmosphere   is  deemed  unacceptable,  then  solid  waste
disposal through incineration  with presently  installed air
pollution control  equipment must  also  be  deemed
unacceptable.
                   REFERENCES CITED

1.  Van Horn, W.  H., et al.. Materials Balance and Technology
         Assessment of Mercury and Its Compounds on National
         and Regional Bases, URS Research Company for the U. S.
         Environmental  Protection Agency, EPA-560/3-75-007,
         October 1975 (PB 274 000/3BE).

2.  McCarthy, J. H., et al., "Mercury  in Soil, Gas, and Air — A
         Potential Tool in Mineral  Exploration," U. S. Geological
         Survey Circular 609, Washington, D.C., 1969.

3.  Environmental Engineering, "Source Test Report for the 73rd
         Street Municipal Incinerator," New York, N.Y., EPA Test
         No. 71-C1-14, 1971.

4.  Emcon Associates, "Sonoma County Solid Waste Stabilization
         Study" for the Environmental Protection Agency, 1974.
                                                       -175

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                    CLOSING AND REHABILITATION OF HAZARDOUS WASTE DISPOSAL SITES

                                              Amir A. Metry, Ph.D., P.E.
                                                   Project Manager
                                     Weston Environmental Designers—Consultants
                                                   Westchester, PA
 INTRODUCTION

      Proper  closing  of  hazardous  waste  management
 facilities is a very important factor in the overall control of
 such waste.  Uncontrolled  closing  or abandonment of
 hazardous waste management facilities (storage, treatment
 and processing,  or land disposal) could result in substantial
 damage to the environment and a threat to public health
 and  safety.  Potential  environmental  and/or health  and
 safety impacts may include:

   •  The public's  consuming  contaminated surface or
      subsurface water, or inhaling contaminated air in the
      vicinity of an abandoned site.

   •  Fires   or   explosions  at  closed sites,  or  during
      uncontrolled construction activities at active sites.

   •  The danger to the health and safety of persons  who
      are redeveloping an abandoned site for other uses, or
      attempting to recover (or scavenge) waste materials
      from a site.

   •  Degradation   of  ground water   quality  through
      migration  of  toxic  substances  from  an abandoned
      facility (as shown   in  Figure 1). Infiltration  and
      contaminant   migration  can   be  intensified   by
      improper grading, cracking of final grades, or the  lack
      of adequate soil and vegetation covers.

   •  Degradation of  surface water quality through  the
      washing of contaminants from an abandoned facility
      (as  shown  in  Figure 2). Exposed waste and lack of
      runoff control devices could result in the washing of
      hazardous substances from disposal areas into surface
      waters.

   •  Degradation of  air quality through  the  release of
      toxic and  noxious gases from an abandoned facility.
      Improper  covering,  venting, and control of such
      emissions can result in release of toxic,  flammable, or
      irritating  gases and fumes  from a facility into  the
      ambient atmosphere.

CLOSING HAZARDOUS WASTE DISPOSAL SITES

      Hazardous  waste disposal  sites should be closed in a
manner which  prevents their causing future  hazards to
human health and to the environment. Site owners should
be responsible for terminating operations and closing a  site
in an environmentally safe manner,  and to  continue  site
maintenance after closure.
      Prior to a disposal site's termination of operation and
 closing,  a plan  for  its  closing,  including  the  following
 elements,  should  be  prepared:  (1)maps  and  drawings
 showing existing and final contours, site features, and the
 location on  a  site of different types of hazardous  waste;
 (2) means  of controlling  leachate and  prevention  of its
 migration into the environment;  (3) plans for final cover
 and seeding, and the means for  runoff and soil erosion
 control; (4) means of correcting future emergencies and of
 preventing leachate or gas migration;  (5) ground water and
 gaseous  emission  monitoring programs;  and  (6) financial
 statement  indicating  an  owner's  ability  to  meet  future
 liabilities related to a closed site.
      If a hazardous waste disposal site which has closed is
 to be reopened for any reason, the original owner should
 prepare  a report  to subsequent owners on the maintenance
 requirements of  the  property.  However,  reuse of  certain
 types of hazardous  waste  disposal  sites  should not  be
 permitted, because of the potential hazards to users and the
 environment. In some instances, the state regulatory agency
 may find that acquiring hazardous waste disposal sites that
 have been closed and conducting  the required surveillance
 and monitoring activities is environmentally safer.  However,
 prior to taking such an action, the state  agency  should
 collect  sufficient fees  for disposal  of a site's  hazardous
 waste,  covering   surveillance,  potential  liabilities,  and
 possible corrective actions which may  be  necessary for
 safeguarding against the hazardous  substances released.
      Regulatory  agencies should request  that ground water
 and surface water quality monitoring  points on a site be in
 working condition prior to the closing of the facility. The
 owner should be requested to continue  monitoring water
 and air quality, as appropriate, for a specific period of time
 after termination of   operation.  However,  regulatory
 agencies  should   consider  the  necessity  of  long-term
 surveillance of  all closed hazardous waste disposal sites. A
 monitoring  and   surveillance  program  should  primarily
 check for possible problems (e.g., subsurface and surface
 water quality  and air  quality) and  confirm  that  waste
 materials are  not escaping from the disposal  areas.  Problems
 detected  by   monitoring  and  surveillance should  be
 immediately corrected, and the cost of correction incurred
 by the original owner, or by  a  special fund established for
 long-term care of such facilities.

 REHABILITATION OF CLOSED HAZARDOUS WASTE
 DISPOSAL SITES


      Either of two approaches for controlling pollution of
subsurface  or surface waters  by  active (or abandoned)
disposal sites may be taken: (1) control of the source itself;
                                                      -176-

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                                                                      FIGURE 1

                                              CONTAMINATION OF SUBSURFACE WATER BY A LANDFILL
-j
 i
                     Pleistocene Aquifer

;t- Inl
Saturated Re
iltr
IIV
•tion
>
                   Contaminated

                   Ground Water
Potomac Aquifer
Uncontaminated

 Ground Water
                                CAUSES OF LEACHATE GENERATION AND MIGRATION

                                1  Excessive infiltration due to inadequate cover and grades

                                2  Lateral infiltration from Pleistocene Aquifer due to absence of confining materials or ground water
                                  diversion devices

                                3  Migration of leachate from landfill into the Pleistocene Aquifer due to absence of confining materials
                                  or interception devices

                                4  Migration of  leachate  from  landfill into Potomac Aquifer due to absence of confining materials or
                                  interception devices

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                                                                    FIGURE 2

                          CAUSES AND MODES OF LEACHATE GENERATION AND MIGRATION FROM EXISTING LANDFILL
                                     Flat areas promote rainwater
                                     infiltration   in   refuse   and
                                     create leachate.
                                                                        Rainfall
                                                                                      Steep  areas promote leachate
                                                                                      springs  and  migration   of
                                                                                      leachate to streams thereby
                                                                                      polluting such surface waters.
-4
00
Absence of vegetation cover
reduces evapotranspiration of
soil moisture and allows more
infiltration  and  leachate
formation.
                                   Lack  of proper soils fosters
                                   contamination  of   ground
                                   waters.
                                                                                   Lack of impervious materials
                                                                                   allows  leachate to migrate to
                                                                                   ground waters.

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and  (2) control  of  receiving waters (subsurface  or surface
waters).  In  many cases, a combination of controlling the
source and the receiving waters may be required.
      Control  strategies for abating surface and  subsurface
pollution   by   landfills  can   also  be  categorized
as:  (1) controls  for completed sites;  (2) controls for new
sites; and (3) controls for active (partially completed) sites.
Controls for completed sites require different technology
and  strategy than those required for new sites,  because  in
the former,  waste is already in place, and often  subsurface
pollution has  already occurred.  In the case of active sites,
which usually contain both completed  areas and areas for
future utilization, technology for controlling existing  and
proposed landfills  should  be  concurrently  implemented.
Figures 3 (existing landfill) and 4 (new  [proposed] landfill)
illustrate  some   surface  and  subsurface   water  quality
controls.

Rehabilitation of Land Disposal Site

      Conventional   methods   for   controlling   leachate
pollution of subsurface and surface  waters (e.g., use of
liners, leachate collection, and treatment systems) are not
expected  to be  feasible  for most existing  land disposal
facilities.  Experience in correcting existing  sites consists
basically of  methods  of minimizing leachate generation
rates  and/or interception  of contaminated  subsurface and
surface waters. Discussion of these methods follows.
      Minimizing infiltration  through  the  site,  and thus
minimizing leachate generation, as shown in Figure 5,  can
be achieved by the following means:

   •   Construction  of proper slopes on finished  grades to
      promote runoff and reduce infiltration.

   •   Use of  adequate  final   cover  and   vegetation  to
      promote evapotranspiration  losses of  soil  moisture
      and reduce infiltration (as shown in Figure 6).

   •   Diversion of  runoff waters and prevention of their
      entry into disposal areas.

   •   Construction  of  drainage  channels  and  swales  to
      speed runoff.

   •   Diversion and/or  blocking  of subsurface water flow
      into disposal areas through pumping, bentonite slurry
      walls, etc.

      Interception of ground water inflow can be achieved
by one of the several  techniques shown in  Figure 7 and
listed here:

  •   Installation of a well-point system, or a wall system.

  •   Installation of perforated drain pipe.

  •   Grouting of leaking areas in landfill.
   •  Excavation  of  sands,  resulting  in   ground water
      interception and drainage through a surface conduit
      around the site.

      Interception  of contaminated  runoff  waters  at
discharge points, such as:

   •  Springs which show high levels of pollutants.

   •  Leachate seeps from side slopes.

   •  Drainage channels and swales receiving leachate.

   •  Waters from monitoring wells which show high levels
      of pollutants.

      Attempts to isolate a disposal  site  from  all  water
influx have several shortcomings:  (1) some water will enter
the landfill, regardless of the external  controls. (2) system
requires continual   maintenance  and  operating  costs.
(3) operation has no apparent time limit, after which the
waste will be chemically stable.
      Hydrogeologic isolation of disposal sites is often the
only  immediate-term solution  that can  be considered. In
areas   heavily  dependent   upon     ground waters,
contamination  resulting  from leachate can  cause  water
quality  problems in a large portion of  a  downgradient area
of the  aquifer. A short-term solution would  be to install
counter-pumping wells in the area of leachate migration:

   •  Immediately downgradient  from the source to create
      a  cone  of depression which  would cause a local
      ground water  divide between  the source and  any
      centers of pumping.

   •  Immediately  beneath   the    landfill   to  isolate
      percolating waters from reaching  the water table.

      Recommendations  for  employing   hydrogeologic
controls must  be made on a  case-by-case  basis. Because
hydrogeologic controls are short-term, corrective measures,
their employment would be recommended if, and only if:

   •  An  aquifer   of   medium-to-high  yield   near  a
     community is threatened.

   •  An  ultimate  solution to  eliminate  the  source of
     pollution is not available.

   •  Natural  dilution and/or dispersion of contaminated
     water does not occur.

   •  Large  centers of pumping are relatively close to the
     pollution source.

     Spray  irrigation of  intercepted ground waters could
be a practical and cost-effective means for disposal of such
"low  pollution/high   volume"   waters. However,  when
                                                        -179-

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                                                                    FIGURES

                             MEANS OF LEACHATE CONTROL, TREATMENT AND/OR DISPOSAL FOR EXISTING LANDFILL
                   Locate and operate recovery
                   wells to recover pollutants in
                   ground water.
                          Grade  flat areas  to reduce
                          infiltration   and  leachate
                          generation.
                                               Plant  vegetation  to reduce
                                               infiltration and erosion.
                                       Stabilize  excessively  steep
                                       slopes by benching or using
                                       riprap.
               Locate   and   intercept*
               leachate  springs to  recover
               pollutants
8
                           Leachate   Treatment
                           and/or Disposal  Strategy.
Do  not pump,  if
quality  is  within
drinking   water
standards
                                                                              Discharge in stream
                                                                              if quality is within
                                                                              stream standards
                                        Spray irrigation and/or
                                        discharge to waste-water
                                        treatment plant if quality
                                        does not meet stream
                                        standards

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                                                                    FIGURE 4

                               MEANS OF LEACHATE CONTROL, TREATMENT AND/OR DISPOSAL FOR NEW LANDFILL
                                                     Provide  final  cover and
                                                     establish  vegetation  to
                                                     promote  evapotranspiration
                                                     and  minimize  leachate
                                                     generation.
                                                                                          Construct  proper slopes  to
                                                                                          minimize  infiltration,
                                                                                          leachate  generation, and
                                                                                          erosion.
                                                                           Evapotranspiration
oo
Collect leachate and transport
it to waste-water treatment
plant.
                                                                                                               Uncontaminated
                                                                                                                   Runoff
                  Original Grade
                                                        Install impervious lines and leachate collection system to
                                                        intercept leachate and protect ground water.

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                                                               FIGURES

                               MEANS OF MINIMIZING LEACHATE GENERATION AND CONTAINING WASTE

                              Final Cover (Grade 2-15 percent)


                                                 Vegetation Cover
                                                               Porous Medium (Sand Gravel)
                                                                                Impervious Cover
                                                                                                            Runoff Diversion

 IIS! f*- !:g!!!;i&uis&jj!!t!!il:::!:  H**!;:::;"J
•f//•:;.•'• '::(:::!^^;::: ':^i !i::iii!!l:: *?; p;!j ft
                                                                                            Porous Medium (Sand Gravel)
Impervious Liner
                                                                              Backup Liner
                                                            Leachate Collection Sump

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                         FIGURES

        REHABILITATION OF LANDFILL SURFACES
    Inadequate   cover   creates,
    pond   that  increases
    infiltration
                                                   Excessive Slopes
                                                   Create Leach ate Springs
CORRECTIVE ACTIONS

1  Place an impervious cover over the landfill
2  Fill in low areas and maintain a minimum slope of 2 percent
3  Maintain final cover at 2 ft. minimum of suitable material
4  Establish suitable vegetation cover
5  Reduce excessive slopes to less than 15 percent or rehabilitate by
   benching and riprapping
6  Provide means of draining runoff quickly
                           - 183-

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                                FIGURE?

SOME TECHNIQUES OF LEACHATE CONTROL FOR COMPLETED LANDFILLS
       1  Dewatering by pumping upgradient of landfill
       2  Reducing inflow of ground water by a bentonitc slurry barrier
       3  Reducing infiltration into landfill
       4  Grouting leaking areas in landfill
       5  Dewatering by pumping from beneath landfill
       6  Interception and treatment of leachate springs
       7  Interception of contaminated ground water by pumping
       8  Interception of contaminated ground water by infiltration gallery
       9  Blocking contaminant flow by bentonite slurry barrier

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                                                        FIGURES




                             CONCEPTUAL EXCAVATION OF SATURATED REFUSE, LLANGOLLEN LANDFILL
oo
01

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                                                  FIGURE 9

            SCHEMATIC CROSS-SECTION OF DEWATERING LLANGOLLEN LANDFILL DURING EXCAVATION
                        Excavated
                        Refuse to
                        New Landfill
Original Water
Table Surface
Drawn Down
Contaminated Ground Water
Reaching Potomac Aquifer

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                                                              FIGURE 10

                            MEANS OF CONTROLLING GASEOUS EMISSIONS IN HAZARDOUS WASTE DISPOSAL SITES
S3
          Impervious
            Cover
                                                Gas Flare (or
                                            Controlled Combustion)
                                                                                              Gas Venting or Collection
                           Gas Venting
                           or Collection
                                                   Impervious Liner

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recovered subsurface or surface waters show high polluting
loads,  on-site treatment or disposal in municipal sewers, if
available, may be necessary.

Reconstruction of Land Disposal Site

      When  a  land  disposal  site is found to  be  causing
significant degradation of subsurface and  surface waters,
and the previously listed means of controlling pollution are
determined  to  be   ineffective in  minimizing  leachate
formation  and migration,  more positive means of control
will be required.  When such conditions exist,  a program of
complete site rehabilitation  should be implemented.  This
total   reconstruction  program  would  consist   of   the
following:

   •  Reconstruction of new, landfill areas, including the
      selection and  installation of  a  liner  and leachate
      collection  system,  the   placement  of   refuse,
      intermediate and final cover, and the establishment of
      vegetation cover.

   •  Waste  handling,   including  provisions   for   the
      excavation  of   certain areas  in  existing site,  the
      temporary  storage of wastes  and their transportation
      to a  reconstructed  area  (Figure 8). Dewatering of
      landfill areas during excavation is shown in Figure 9.

   •  Leachate   collection  and   treatment,  including
      construction  of  subdrain collectors, installation of
      leachate  pumping and piping,  and construction of
      on-site or off-site treatment and disposal system.

   •  Other  environmental controls, such  as erosion and
      sediment control and odor, fire, vector, and wildlife
      controls.

Transfer of Waste to Another Disposal She

      This  alternative  is similar to reconstruction  of  the
land disposal site except that instead of replacing wastes in
reconstructed areas, the wastes are disposed of in a properly
designed existing landfill. One advantage of this concept is
the economy involved in  operating one landfill  and one
leachate  control  system,  rather than two separate ones.
However, disadvantages include overloading the existing
disposal facility, cost, and  hazards and nuisances associated
with off-site hauling of the waste.
Waste Incineration

      Incineration of waste reclaimed from a polluting site
may  be  considered  when other  alternatives   (such  as
rehabilitation   or  reconstruction)  are  believed to  be
inadequate  in  containing  pollutants within  the site.  It
should  be noted that excavation  of waste and ultimate
disposal via incineration  has a high capital and  operating
cost.  Implementation  of such  a  solution can only  be
justified in abating extreme subsurface pollution in major
aquifers.

OTHER ENVIRONMENTAL MEASURES

      Other  environmental  measures   in   closing  and
rehabilitating  hazardous  waste  disposal  sites  include the
following:

   •  Providing  means for control  of gaseous  emissions
      from the  disposal site. As shown in Figure 10, this
      should   include  combinations   of   the
      following:  (1) Means  of   preventing  gases   from
      migrating out of the disposal  site, such as impervious
      liners or barriers. (2) Means of collecting gases,  such
      as porous media  and perforated pipes.  (3) Means  of
      venting or collecting gases. (4) Means of intercepting
      gases near existing structures. (5) Means of disposal  or
      utilization   of  collected  gases,   such  as  flares,
      combustors, or boilers.

   •  Proper labeling, identification, and documentation  of
      location of waste disposed of at the facility.

   •  Providing  means of  limiting  public access to the
     closed  facility   and  posting  warning   signs,  as
     appropriate.

   •  Continued monitoring and surveillance in the vicinity
     of the closed site.

   • Continued maintenance and rehabilitation of the site
     after its closing.

   • Correcting  health  and/or  environmental  problems
     when they are discovered.
                                                       -188-

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                      ENGINEERING STUDY OF STRING FELLOW CLASS I DISPOSAL SITE

                                               Gordon P. Treweek
                                  James M. Montgomery Consulting Engineers, Inc.
                                                  Pasadena, CA
INTRODUCTION

     In the spring of 1972, the Santa  Ana Regional Water
Quality  Control  Board  (SARWQCB)  became  aware of
leakage   of  toxic   industrial   waste-water   from  the
Stringfellow  Class I  disposal site located  in  the Jurupa
Mountains near  Riverside, California.  The site had been
operated  as a toxic industrial  waste disposal  dump since
1957; approximately 32 million gallons of waste had been
dumped  at the site between  1957 and 1972. These liquid
wastes  (Table  1)  had  become  concentrated  through
evaporation  from  the  pond  surface and  from  spray
evaporators. Although  the exact  chemical composition of
the   discharged   waste-waters  is  unknown,  they  were
generally  spent acids and caustics with  significant amounts
of  sulfuric,   nitric,   and   hydrochloric   acid.  Some
waste-waters   contained   toxic   inorganic   chemical
compounds of zinc, lead, mercury, and chromium.
     After  the  detection of leakage  from the  site, the
disposal site ceased to accept wastes in December 1972 and
has  not  operated  since  that  time. The  site  has been
maintained in the intervening period by intercepting surface
waste-water leaking from the disposal area and  pumping
these wastes from a collection sump back into the disposal
area for evaporation.
     Three major objections to the operation of the liquid
waste disposal site were raised:  (1) the potentially serious
contamination of ground water  supplies   caused  by the
continued  seepage   of  toxic  waste-water,   especially
chromates; (2) the potential inundation and overflow of the
liquid waste ponds by heavy stormwater runoff  from the
surrounding hills, thereby carrying  toxic waste via surface
and ground water flow into  downstream water  supplies;
(3) the potential air  pollution  problems caused by the
evaporation  sprayers,   especially   if  operated   during
Santa Ana wind  conditions  when the evaporating fumes
might be carried  toward  residential communities.  In
addition,  strong winds in the canyon area  stir up the dry
residue and deposit  it  over   the  land  surface.  These
windborne residues might  spread the contamination outside
the immediate area of the ponds.
     The disposal site occupies  approximately 16.7 acres
of quarry property; roughly  4.2  of  these acres constitute
the actual disposal pond area. An additional 4.9 acres of the
site are heavily contaminated from  evaporation operations
or from  leakage from the disposal ponds and containment
berms. The location  of  the site in Riverside County is
depicted  in   Figure 1.  The  disposal  site  occupies the
northern  portion of a triangular shaped canyon located on
the  southern flanks of the Jurupa Mountains. The canyon
drains to the south and the southwest at a slope of about
300 feet per mile. The watershed above the disposal ponds
comprises about 270 acres.  The surface drainage from the
canyon  moves south  from the  site to  a  catch basin
immediately north of U.S. Highway  60. Here drainage is
captured  in a concrete channel  which  empties south of the
Glen  Avon  School into the Pyrite Channel. The Pyrite
Channel then  carries the water farther to the south and
west into the Chi no II Ground Water Basin.
                      TABLE 1

 MATERIALS NOT REQUIRING SPECIAL CLEARANCE
      PRIOR TO DISPOSAL AT STRINGFELLOW
              CLASS I DISPOSAL SITE*
Acetic Acid
Ammonium Biflouride
Boric Acid (borax)
Brines (water softener)
Chromic Acid
Chromate Compounds
Copper Sulfate
Ferric Sulfate
Ferric Chloride
Hydrochloric Acid (Muriatic Acid)
Hydrofluoric Acid
Iron Oxide (Ferric Oxide)
Nitric Acid (excepting fuming nitric acid)
Oxalic Acid
Paint Sludge
Paint Strippers
Phenolic Compounds (Cresilics, carbolic acid, etc.)
Phosphoric Acid
Sodium Chloride
Sodium Fluosilicate
Sodium Hydroxide
Sodium Nitrate
Sodium Phosphate
Sulfuric Acid
Zinc Sulfate
   Santa Ana  Regional Water  Pollution  Control  Board
   Resolution No. 55-11 (September 1961)
      The site  was well  suited for  liquid waste disposal
because   of   the  natural  barrier  or  dike  located
approximately % mile south  of the head of the canyon.
                                                     -189-

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                                      FIGURE 1

                    LOCATION OF STRINGFELLOW CLASS I DISPOSAL SITE
                         AND DOWNSTREAM MONITORING WELLS


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                              ^- ,-*-" "i ":            %;'

                                        -190

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This barrier  abuts the  east  wall  of  the canyon,  runs
perpendicular to the longitudinal axis of the canyon, and
terminates within 250 feet of the west wall of the canyon.
The bedrock of the east wall of the canyon is connected to
that of the west wall by a concrete barrier constructed to
prevent leakage through the natural watercourse.
     The natural dike or  barrier is an eroded remnant of a
small alluvial cone which  extended up a tributary canyon
on the east side of the main canyon. The dike is composed
of well-cemented gravels, cobbles, and boulders that appear
to  be  impermeable.  When  the  concrete  barrier  was
constructed to link the east  and west faces of the canyon,
the overlying soil  was stripped to bedrock and the  dam
keyed into the bedrock itself.
     The total area  of disposal ponds  is broken  up  by
earthen  berms into about 20 small ponds of which only 4
currently contain residual  liquid waste. The disposal site is
ringed by a continuous earthen berm ranging in width from
12 to 20 feet which serves to divert surface runoff from the
surrounding canyon sides from the ponds themselves. Thus,
the peripheral berm of compacted earth and quarry tailings
shields the ponds containing toxic liquid waste from storm
water runoff. Incidental rainfall adds  15 acre-feet of water
per year to the disposal ponds. Figure  2 is a contour map of
the Stringfellow Class I Disposal Site showing the peripheral
berms  and  roadway,  the concrete  barrier, the  disposal
ponds, the  final  collection  sump,  and the contaminated
areas (per visual examination).
      Dry  summer   weather  provides  an  annual   net
evaporation  rate   greater  than  64  inches  per year.
Occasionally,  particularly during the  winter,  high-speed
winds develop, known  as the  "Santa Anas",  which move
roughly  southwesterly  from the  Mojave  Desert through
Cajon  Pass  and over the Santa Ana River basin.  During
Santa Ana conditions, wind velocities have been recorded in
the  San Bernardino  Mountains exceeding 100 miles  per
hour. The  lower portions  of the  basin  are  somewhat
sheltered,  but  nevertheless  average winds   during   the
Santa Ana condition of 30 miles per hour can be expected
in the Jurupa Mountains.  The Santa Anas occur on 5 to 10
occasions or roughly 25 days each year. These hot desert
winds   rush    through  Cajon   Pass   over   the
 Riverside/San Bernardino   Valley,  including   low  lying
mountain groups and then  traverse Santa Ana  Canyon to
the Pacific Ocean. The Jurupa Mountains lie almost directly
in the path of the Santa Ana winds from the desert to  the
coast.  Because  of the Santa  Ana conditions, the spray
evaporation system should  not be used during the  midday
hours, because this is the  time when the toxic droplets
could be expected to be carried farthest down the canyon.
      Construction of the Stringfellow Class I Disposal Site
began in 1955; continuous improvements were made to the
site during  the  following 20 years.  Essentially, a Class I
disposal   site  must  provide  complete  protection  from
flooding, surface runoff,  or drainage, and waste materials
 and all  internal  drainage  must be restricted to the site. A
 secondary function of the Stringfellow Class I Disposal Site
 was to process these wastes through evaporation to reduce
the final  volume  of  the  material.  Dumping  at  the
 Stringfellow Site began in August 1956. As the initial ponds
filled  with  liquid  and  sludges,  additional ponds were
constructed  farther up  the  valley. The new ponds were
constructed  from overburden and tailings from the quarry
operations and from sludges dredged from  the bottom of
existing disposal ponds.
     The total area of the site located behind the concrete
barrier is approximately 16.7 acres. Within the pheripheral
berm are 20 major pond areas with a total surface area of
roughly 4.2  acres or 183,000 sq  ft With a net evaporation
rate of 64 inches per year, these ponds could evaporate 7.3
million gallons per year if operated at complete efficiency.
Because only roughly 25 percent of the existing area within
the pheripheral berm  has been  utilized for evaporation
ponds, additional  ponds could be constructed to provide
greater capacity at the site.
      In addition to  the construction  of the concrete
barrier across  the mouth  of the canyon, the Stringfellow
well was used for periodic sampling to determine if  any
changes  in  the  ground water quality  occurred  due to
operation of the  dump.  Actual monitoring of this well,
located  approximately  0.7 mile downstream  from  the
disposal site, began in July 1957. All samples were analyzed
for electrical conductivity, chlorides, hexavalent chromium,
and sutfates in accordance with standard procedures.
      During the spring of 1969, heavy storm water runoff
carried  waste  out of the dump, down Pyrite Channel,  and
across  Highway 60. Because of the leakage over  the dam
and out of the site, dumping of liquid waste ceased so that
repairs  could  be  made on the  dams and flood control
channels. These repairs  were completed in March and April
1969.  In 1972, samples from the monitoring well revealed
high  salinity  and  an  increase in the concentration of
hexavalent  chromium.  These findings  resulted  in  the
SARWQCB  issuing an order requiring the construction of a
positive hydraulic barrier  with a sump to recycle any waste
that  passed under  or around the retaining barrier. In
addition, a  contractor was hired to inject a sealant material
into the lower dam structure to seal any cracks and fissures.
This  sealing operation successfully  reduced the leakage
under the concrete barrier to less than 1 gallon per minute.

GEOLOGY AND HYDROLOGY

      Competent rock,  free  of faults, connecting fractures,
and joints is of utmost  importance in confining wastes. The
Jurupa Mountains are composed of intrusive rocks; siliceous
metamorphics  are the  predominant type  with  tonalite,
granodiorite,  and gabbro  present  in  lesser  amounts.
 Lens-shaped  limestone  deposits  are  found  within  the
Jurupas and are mined as a source of cement. The surface
of the mountains is weathered to red or brown soil cut by
faults  of small displacement, but which nevertheless might
have   an  important  effect  on ground water movement.
Jointing and foliation planes  are prevalent  throughout the
 rock  units  which make  up the  Jurupa Mountains.  Most
available  information  indicates vertical east-west trending
 patterns   of  unknown   depth   which   are   generally
discontinuous  and not in communication with each other.
 Locally,  fractures and  joints  in the uppermost zones
 provide some limited ground water storage  areas which are
                                                        -191-

-------
                   FIGURE 2



CONTOUR MAP - STRINGFELLOW CLASS I DISPOSAL SITE

                      192-

-------
capable of yielding water as indicated by a few wells in the
vicinity. However, extensive joints and fractures are not
generally  present  throughout  the  Jurupa  Mountains.
Stringfellow Rock Quarry,  adjacent to the disposal site, is a
prime example of the competency of this material. Large
granitic  blocks from this quarry have been used as rip-rap
material  for   many   construction   projects  throughout
California's interior and coastline. Figure 3 is  a geologic
map of the Jurupa Mountains and vicinity.
      Few water  wells exist within the Jurupa Mountains.
Logs of the existing wells indicate ground water within the
mountains  occurs mainly  in the  valley areas where  thin
alluvium and  near-surface-fractured  bedrock provide the
major storage  units. One such well is Stringfellow's Well IQI
located approximately 3,300 feet south of the disposal site.
Recent estimates  of the production from this well indicate
about 2 gallons per minute can be pumped on a sustained
basis  without  breaking suction at the pump. These  data
definitely  indicate that ground water  in  some areas of the
Jurupa  Mountains  is  stored  within  the fractures of the
bedrock.  Other  wells  exhibiting  similar  characteristics
include  2S/6W-1F1  and -12E1 which also obtain water
from the fractured bedrock.
      The hydraulic characteristics of the fractured material
are difficult to quantify. However, based on all available
information,   the  permeability  of  the upper  fractured
bedrock  might approach  1 gallon  per  day  per sq   ft
(4.7 x 10~^cm/sec )  and might yield  1 to 2 gallons per
minute to wells drilled in the area.

MOVEMENT  OF LEACHATE

      Since 1974 samples have been extracted  from wells
(Figure  1)  downstream of the Stringfellow  Disposal Site
and examined for  inorganic constituents. These wells are
not located in a  straight line downstream of the disposal
site,  but nevertheless are  indicators of the migration  of
inorganic chemicals in the general downstream direction.
Analyses of these  samples for arsenic,  barium,  cadmium,
copper, cyanide, lead, mercury, and  zinc  revealed  0.00
mg/l  concentrations  of these trace inorganic chemicals. In
all  instances, samples  exhibited near neutral  pH. The pH is
the   controlling   variable  for  precipitation   and   for
adsorption/desorption of trace  inorganic chemicals onto
soil particles.   In the pH  range near neutral, most trace
inorganic chemicals are either precipitated from solution or
exist  as cations  in solution.  These  cations  are generally
rapidly  adsorbed  to  soil  particles and  removed  from
solution. Consequently, the low concentrations of trace
inorganic chemicals recorded in the downstream wells are in
accordance with the neutral pH readings. As the pH drops
into the acidic range, larger  concentrations of available
trace  metals  remain  in solution because they are neither
precipitated nor adsorbed.
      Chromium  and  selenium  occur as anions in aqueous
environments  and consequently, a low pH generally results
 in  their  adsorption   onto   soil  particles.  As the  pH
approaches neutrality,  the chromium and selenium anions
desorb and remain  in aqueous solution. Throughout the pH
range of concern,  i.e., in  the  neutral  range, most of the
trace  metals are either precipitated or adsorbed, with the
 exception of the chromium and selenium anions.
         Figures 4 through 9  are topographs  for  inorganic
    chemicals which have been monitored downstream of the
    Stringfellow Disposal Site  for the  last  20  years.  The
    horizontal axis for each topograph  begins at the Class I
    Disposal Site and extends to the Chappell Well (14K1). The
    intermediate portions of other ground water sampling  wells
    are shown in their relative positions with respect to each
    other. The vertical axis  represents  the  time of sampling
    beginning in July 1957  and extending through July 1976.
    Water quality analyses were performed in accordance with
    Standard Methods.
         Figure  4  is  the   topograph for   the   chloride
    concentration  at  the Stringfellow  Disposal  Site  and at
    downstream wells. The California Department of Health has
    a recommended limit of 250 mg /I  chlorides, an upper limit
    of 500 mg./l. chlorides, and a short-term limit of 600 mg /I
    chlorides.
         The chloride  concentration imparts  a taste  at  a
    concentration  above 400 mg /I  but has no known health
    effects.   As  shown  by   the  topograph,  the  chloride
    concentration  within the  disposal  site  itself  is generally
    greater than 500 mg /I.  This falls off to the  range 250 to
    500 mg /I  immediately  downstream of  the disposal site.
    For the  Glen Avon School  well, the chloride concentration
    has  been below 250 mg /I  during the last  20 years. An
    increase  in  the chloride concentration  occurred at the
    Stringfellow well  during the  spring of  1972.  Between
    January  and   July  1972, the  chloride  concentration
    essentially doubled from 130 mg /I to 260 mg /I.
         Figure 5 is the topograph for hexavalent chromium at
    the  Stringfellow Disposal  Site and downstream wells. The
    California  drinking  water   standard   for   hexavalent
    chromium is 0.05 mg /I. As shown  in the topograph, this
    standard was exceeded  only for  a brief period during the
    summer of  1973  at the disposal site  itself. Downstream
    from the disposal site, the chromium concentration during
    the  period 1971 through 1975 generally ranged from 0.025
    to 0.05 mg /I.  Occasional readings greater than 0.05 mg /I,
    were recorded  at  the Stringfellow  well  especially in the
    summer of 1972. The hexavalent chromium concentration
    in the Glen Avon School well has in almost all cases been
    0.01 mg /I. One exceptional  reading was recorded in the
    summer of 1972 with a reading of 0.013 mg /I. Long-term
    exposure to high concentrations  of  hexavalent chromium
    causes nausea and ulcers.
          Figure  6  is  the  topograph  for  nitrate  for the
    Stringfellow Disposal Site and  the downstream wells. The
    drinking  water  standard  for  California  is   a  nitrate
    concentration  less than 45 mg /I.  The nitrate concentration
    at the Stringfellow Disposal Site itself has been greater than
    135 mg  /I during the past 20 years. Since the summer of
    1972, high nitrate concentrations have also been evident in
    the Stringfellow monitoring well. Between the spring and
    summer of  1972,  approximately  a  10-fold increase in the
    nitrate  concentration  was  observed at  the Stringfellow
    monitoring well. Originally, this increase was attributed to
    leakage  of   nitrates  from   the  former   munitions
    manufacturing  facility  located on  the east face of the
    canyon. While this explanation cannot be ruled out, a more
    likely explanation is the leakage of high nitrate waste from
    the disposal site.
193-

-------
        FIGURES

    GENERAL GEOLOGY
    JURUPA MOUNTAINS
(BASED ON MACKEVETT, 1950)

                                LEGEND
                            ALLUVIUM
                            OLDER
                            ALLUVIUM
                                            -•*•-

                            CRETACEOUS GRANITIC ROCK
                            (MAINLY -GRABSRO. TONALITE
                            AND GRANODIORITE)

                            TRIASSIC SILICEOUS
                            METAMORPHIC ROCK (MAINLV
                            GNEISS, QUARTZITE AND
                            SCHIST)
           194

-------
                          FIGURE 4

         CHLORIDE (CD TOPOGRAPH FOR STRINGFELLOW
            DISPOSAL SITE AND DOWNSTREAM WELLS
JUL
1976 JAN
JUL
1975 JAN
JUL
It74 JAN
JUL
l«73 JAN •
JUL-
1*71 JAN •
JUL -
1*71 JAN.
JUL.

JUL .
M> JAN -
tf7 JUL. -
•37 JUL


' * I








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T* Oil
DISPOSAL
SITE

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2RI IIK2 |4K
(CHAPPELL)
   (STRI
         ELLOW)
                      BLVD.     I2M2

                 (DURRETT)     (GLEN AVON)
          LEGEND


  < 250 MG/L


250 MG/l«fc 1<300 MG/L
                                IK?
CALIFORNIA DEPARTMENT OF HEALTH
      500 MO/


• TEST POINT
                              RECOMMENDED LIMIT   130 MG/L
                              UPPER LIMIT        9MMG/L
                              SHORT-TERM LIMIT    6OO MG/ L
                            195-

-------
                         FIGURES

       HEXAVALENT CHROMIUM (CR+6) TOPOGRAPH FOR
    STRINGFELLOW DISPOSAL SITE AND DOWNSTREAM WELLS
JUL."











1*71 JAN


JUL.-

IM7 JUL,

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DISPOSAL.
SITE









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I2MI
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                 (OURRETT)


              LEGEND
                            (GUEN AVON)
  1 ten J 
-------
                                FIGURES

        NITRATE (N03) TOPOGRAPH FOR STRINGFELLOW DISPOSAL
                     SITE AND DOWNSTREAM WELLS
ISPOSAL    PVRITE     i  i
 SITE      DITCH     7

      (STRINGFEUUDW)-^
                                  IZEI |2QI |ZR1  HK2
                                  IZKI
                                  IZMI
                      OLD MISSION   I2M2
                        BLVD.
                     IDURRETT)
                                  (GL.EN AVON)
               LEGEND

  ] fNoJ < 45. MG/L


  ] 45 <  JNOjJ  <»0 MG/U


DRINKING WATER STANDARD
                                         »0
-------
     The nitrate concentration in the Glen Avon School
well  has ranged from  45 to 90 mg /I  during the past 7
years.  However, this nitrate  concentration appears to be
unrelated to activities occurring at  the  disposal site. High
nitrates  in  rural/residential  areas  are  most commonly
attributed to waste-water from septic tanks, feed lots, farm
yards,  and fertilizers  utilized in  farm and lawn  practice.
High  concentrations  of nitrate  are  known to  produce
diarrhea and methemoglobinemia in infants.
      Figure 7 is the topograph for specific conductivity at
the Stringfellow Disposal  Site and  the  downstream wells.
The  California  Department of Health has recommended a
limit   of  800   micromhos,  an  upper  limit  of  1,600
micromhos,  and a  short-term limit of  2,400 micromhos.
For most aqueous solutions, the total  dissolved salts can be
determined  from  the  conductivity  by  multiplying  the
conductivity  by 0.65. The topograph  shows  that  the
conductivity at the disposal site has been greater than 2,400
micromhos during the past 20 years. The conductivities of
the water in the wells  intermediate between the disposal
site and the Glen Avon School wells,  however, have shown
limits  less than  800 micromhos (within the recommended
limit). The conductivity at the Glen Avon School well has
shown a progressive increase during the past 20 years within
the range of 800 to  1,600  micromhos.  This increase in
conductivity  is not  attributed  to any  activities at the
disposal  site  but rather is an artifact of  the urbanization
occurring within the Santa Ana River Basin. The increases
in conductivity for the Glen  Avon  and associated  wells
parallel  increases observed in the total  dissolved solids at
numerous wells throughout the Basin. As with Figure 4 for
chlorides and Figure 6 for nitrates,  a significant increase in
the conductivity occurred during the spring of 1972. At the
Stringfellow well, for example, the conductivity doubled
between January and July 1972.
      Figure  8 is  the  topograph  for  sulfate  for  the
Stringfellow Disposal  Site and  the  downstream wells. The
California Department  of Health  recommends  a sulfate
limit of 250 mg/I, an upper  limit of 500 mg /I, and  a
short-term limit of 600 mg/I.  At the disposal  site, the
sulfate concentration  during the past 20 years has exceeded
500 mg/I. Once again, in the spring of 1972, the sulfate
concentration,   as  monitored  at  the  Stringfellow  well,
essentially doubled  from less than 250 mg /I  to more than
450 mg /I. The  sulfate concentration at  locations farther
downstream, such as the  Glen Avon  well, has remained in
the  vicinity  of 100  to 120mg/l  and  thus within the
recommended limit. At high  concentrations, sulfates have a
laxative effect but no permanent effects.
      The parallel   changes  in  conductivity   and  in
concentrations of chlorides, nitrates, and sulfates, which
occurred during spring 1972 indicate  that for some reason,
significant new contaminants had reached the Stringfellow
monitoring well. The explanation that  these contaminants
had come from residues at the former munitions factory
would have seemed logical if only the nitrate concentration
had  increased. However, the  parallel  increases in the
chloride and sulfate concentrations would not substantiate
this explanation.
      During spring 1969, severe  storms occurred which
caused the disposal site to flood.  This flooding caused an
immediate surface degradation of the water quality because
all the parameters of  surface waters that were measured
showed an abrupt increase in concentration.  However, this
effect was short-lived; the concentrations for the inorganic
chemicals quickly approached their background values after
the recession of the storm waters. A more important effect
of the storm overflow during the  period January through
March 1969 was  the breaching of the concrete barrier and
the deposition of  large  quantities of toxic wastes, both
liquid and solid, in the immediate area downstream which is
now occupied by  the final collection sump.  The liquid
wastes, sludges, and contaminated soil particles in the sump
downstream of the concrete barrier served  as a source of
toxic materials which leached into the underlying alluvium.
      Figures 6 and 7 indicate that the  concentrations of
contaminants  that  appeared  in   the  Stringfellow  well
progressively increased as shown in the topographs for the
period   January   1975  through  July  1976.  If   the
contaminants in the well water had been caused by leaching
of  residues  resulting from  the  one-time flooding (spring
1969), then the concentrations should eventually peak and
taper off.
      The pH of  the water in the monitoring wells has not
dropped below 6.5, indicating that any acids formed by the
leaching  process have been  diluted  and/or  neutralized
during their  movement through the soil (Figure 9). An
abrupt lowering of the pH (by several units — equivalent to
a change in  the hydrogen  ion concentration  of several
orders of magnitude)  would  be  a  precursor to serious
ground water contamination, possibly caused by the direct
leaching of wastes from the contaminated liquids (pH 3 or
4) in the disposal ponds. In this respect, pH measurement
serves as  a  valuable  monitoring  tool because  of its
simplicity.
      Additional  evidence that contaminated ground water
has not left the Stringfellow property is  found  in the  Stiff
Diagrams for the 5 most recent  samplings (November 4,
1976).   Bore  Hole   No. 10,   approximately   500  feet
downstream  of the final collection sump and Bore  Hole
No. 12,  approximately 1,100 feet  downstream of the  final
collection sump, yielded samples with  magnesium as the
predominant cation and sulfate as the predominant anion.
However, wells 12C1,  12E1, and 11K2 downstream of the
Stringfellow property (see  Figure 1 for  locations) yielded
samples  with  calcium  and bicarbonate as the predominant
ions. The dramatic shift  in predominant chemical species
shown   in  Figure 10  indicates that  any  leachate from
deposited  residues or   the  ponds  themselves  remains
confined to the Stringfellow property and has not entered
the ground water supply south of Highway 60.

LEACHATE CONTROL*

      At  the   Stringfellow   Disposal  Site,   relatively
impermeable  soil conditions have  been  utilized to isolate
toxic wastes from the surrounding environment. However,
the  impermeability of the underlying granitic material and
    Leachate refers to any liquid which escapes from the site, irrespective of source (waste liquid, rainwater, groundwater).
                                                       -198-

-------
                               FIGURE?

          CONDUCTIVITY (EC IN MICROMHOS) TOPOGRAPH FOR
       STRINGFELLOW DISPOSAL SITE AND DOWNSTREAM WELLS
/      10 II 12 13       IQI IQ2 IZBZ HT60      f I2EI I2QI IZRI  II
                    AA  izci        / 'ZKi
5POSAL     PYRITE                   / IZMI
SITE        DITCH    / |                IZM1
                   / I    OLD MISSION
      
-------
                          FIGURES

          SULFATE (SO4) TOPOGRAPH FOR STRINGFELLOW
             DISPOSAL SITE AND DOWNSTREAM WELLS



/ JU(_ -

JUL -







JUI- -


1197 JUL .

















•




































MO 1112 13
DISPOSAL PYRITE"^
SITE DITCH
(STRINGFELLOW




•




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IQI IQ2 I2B2 HT60
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/ T OI_O MISSION
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MDURHETT) «
LEGEND








































































I2EI I2QI11RI IIKZ |4K|
I2M1! (CHAPPEUU
ISM1
tl_EN AVON)
n
       <250 MO/L


  | »SO< fsoj 
-------
                                FIGURE 9

           pH TOPOGRAPH FOR STRINGFELLOW DISPOSAL SITE
                        AND DOWNSTREAM WELLS
       10 I I 12 13 T     101 IQZ 'ZB2 RT60      f I2EI ,2QI I2HI   I IK2
                    k A              1 I2KI
ISPOSAL.     PYRITE    f t   I2CI         / !'„
SITE        DITCH    /  /    „, _ ..  ,,-./   ,".
       (STRINCFE1-UOW)







      ]  6.5 < pM < 7.5


      ]  5.5 < pH < 6.5
                          OLD MISSION   IZM2
                             BLVD.
   (DURHETT)


LEGEND
                 CGL-EN AVON)
                       4.5 - pH < 5.5



                       pH<4.5


                     •  TEST POINT
                                                     I4KI

                                                 (CHAPPEL_l_)
                                   -201 -

-------
                                FIGURE 10

STIFF DIAGRAMS FOR SAMPLES EXTRACTED IMMEDIATELY DOWNSTREAM OF FINAL
    COLLECTION SUMP (BORE HOLES NO. 10 AND 12) AND FOR SAMPLES FROM
           DOWNSTREAM MONITORING WELLS (12C1, 12E1, AND 11K2).
                          SAMPLES TAKEN 11/4/76
       STRINGFEL.L.OW
       BORE HOLE NO. 10
                                               HCO,
                       1200 1000 800 600 400  200  0  200 400 600 80» 1000 1200

                                   (MIUUIEQUIVAUENTS/U)
       STRINGFEUUOW
       BORE HOLE NO. It
                            SO  40  30  2*  10   0   10  20 30 40  SO  60
                                   (MIUUIEQUIVAUENTS/U)
       WEUU 12 ci
                               86420   146

                                   (MIUUIEQUIVAUENTS/U)
       WEUU I2EI
       WEUU IIK2
                                    Nd
                                                        HCO.
                                                  NO,
                               86420   246
                                   (MIUUIEQUIVAUENTS/U)
                                  6420   24
                                  (MIUUIEQUIVAUENTS/U)
                                  -202-

-------
the impermeability of the  linkage  between  the  granitic
material and the concrete barrier are questionable in light
of  the  degradation   of ground water  at   downstream
locations.  To  improve the  isolation of wastes from the
ground water materials such  as  clay,  concrete,  asphalt,
plastic, and  other  liners  and covers  are available to seal
cracks  in  the  underlying   granite  or  to   form  more
impermeable barriers.  A general investigation was made of
these  materials  to determine  which could  be used  to
complement the existing relatively impermeable material at
the disposal  site.  The materials can  be used for two
purposes:  first, as a base  course beneath the contaminated
material to  prevent  leachate  from  leaving the site; and
second, as a  cover or umbrella over the toxic waste  to
prevent additional  rainwater or runoff  from entering the
contaminated material  and picking up residues as it passes
through the disposal site.

CLAY SEALANTS

     A high clay content in the underlying soil is valuable
because of its  low permeability and beneficial adsorption
properties. The ability of clay soil to attenuate the passage
of contaminants has been found to be closely related to the
size of the soil particles (clay content), the cation exchange
capacity (Griffing and  Shimp,, N.D.) the free  "iron oxide"
content of the soil, the soil pH value, and the solution flux
through the  soil  (Fuller and   Korte,  N.D.). The size
distribution of the  soil  particles is important because of the
large surface area associated with many small clay particles,
as opposed to the smaller surface area of larger granular
sand and  gravel materials.  The hydrous iron oxide content
is important because of the  oxide's ability to mediate the
adsorption of trace  elements onto the clay surface.
     Similarly, the soil pH  value is important because of
the precipitation  of metal  hydroxides and the competition
of  hydrogen  ions with trace  elements  for available
adsorption sites on the clay surface. The soil solution flux
relates  most closely  to  the actual  clay content of the
underlying soil. The cation exchange capacity determines
the extent of beneficial   exchange  between  trace  metal
cations in  solution and  adsorbed  sodium  and calcium
cations. Some of the factors  which have been shown to be
least important in the attenuation of trace metal movement
in  the   soils   are:  sand   concentration;   biological
mineralization and  immobilization; and soil organic matter.
     The 3 basic clay groupings can be ranked according to
their attenuating  capacities:  montmoriilonite (bentonite)
>Hlite>kaolinite.  Montmoriilonite  attenuates  pollutants
approximately 4 times better than illite  and 5 times better
than kaolinite. These  ratios are nearly  identical with the
cation  exchange capacity ratio for the 3 clays. The ratios of
the surface areas  of montmoriilonite to the surface areas of
illite and  kaolinite  are  1.3 and 2.5 respectively. The data
from different investigators (Fuller and Korte, N.D.; Griffin
and Shimp,  N.D.)  suggest that  surface area  and  cation
exchange capacity are  both important in the attenuation of
trace elements in the clay layer.
      Some  research has determined the attenuation order
which can be expected against the movement of inorganic
constituents through clay both in its natural state and as
modified during emplacement (Griffin and  Shimp, N.D.).
The attenuation order can be ranked as follows:

   High       Mercury, lead, zinc, cadmium, copper
   Moderate   Silicon, magnesium, potassium, ammonium
   Low       Sodium, chloride, COD, chromium, selenium
   None      Calcium, iron, manganese

      The most important factor affecting the  amount of
trace  metal  removed  from  solution is  the pH  of  the
solution. The 5 cations, chromium, copper, lead, cadmium,
and  zinc, showed a marked increase in  adsorption with
increasing pH in the range from pH 2 to pH 6. This  increase
in adsorption  is  consistent  with  the  increase  in  the
pH-dependent cation  exchange capacity of clays and with
the formation  of metal hydroxyl complex ions known to
occur  in this pH  range.  The  formation  of insoluble
carbonate and hydroxyl compounds  is initiated between pH
values of 5.5 to 7.5 depending upon the element and  its
concentration.
      The metals selenium and hexavalent chromium follow
the reverse  trend with  respect to  pH. Their  adsorption
increases as  the pH is lowered. Because selenium is known
to exist in  solution  as  Se04~2  anion  and  hexavalent
chromium as the C^Oy"^ anion at low pH values, their
behavior is consistent with an anion exchange mechanism.
Evidence points to the fact that cation/anion exchanges are
the principal  attenuation  mechanisms  at pH values  that
preclude  precipitation,  such  as   those  found  at   the
Stringfellow Disposal Site.
      The amounts of metal cations  adsorbed from landfill
leachate at a constant pH vary widely. The wide variation is
caused  by  the relative affinity of each metal  ion  for
exchange  sites  when  competing   with  the   high
concentrations  of other cations  present in the leachate. A
tentative ranking indicates  relative adsorption affinities for
kaolinite at low pH's of each of 7 trace elements as follows:

         Cr+3 > Cu = Pb > Cd > Zn > Cr+6 > Se

      In summary, the  attenuation  of contaminant in the
soil can be  described  by the following physical-chemical
processes:   mechanical  filtration;  precipitation  and
coprecipitation; and sorption. Mechanical filtration is  the
physical restriction  to the flow of suspended contaminant
by  soil.  Precipitation  and  coprecipitation involve  the
formation of  insoluble compounds resulting  principally
from  a change  in  temperature,   pH,  and/or  solution
composition  as  the   leachate moves  through the  soil.
Sorption includes the  processes of adsorption, absorption,
and ion exchange where the sorbing medium may be the
soil  itself,  organic  compounds  in  the  soil,  microbial
growths, or chemical precipitants.
                                                      -203-

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      For day material used as a base for a waste disposal
site, all 3 mechanisms are important. For an umbrella cover
over  an existing site,  only  mechanical  filtration is of
importance.  On this basis,  montmorillonite  (bentonite) is
the most advantageous clay for the base of a waste disposal
site. The 2 most important properties of montmorillonite
are swelling and cation adsorption capacity. The ability of
the leachate to disrupt the swelling of bentonite can be
restricted by the use of proprietary products produced by a
number of  manufacturers.   For  the  surface   cover,
well-compacted native clay is adequate to provide the low
permeabilities needed to keep rainwater from  infiltrating
the site. In the case of a cover, the swelling and contraction
of montmorillonite with water is a disadvantage because the
dry  day tends to  crack,  producing  voids which permit
rainwater to infiltrate.
      The  swelling  of  bentonite can  be reversed  by the
presence of substantial  quantities of dissolved inorganic or
organic  material  in  the water  with which the  bentonite
comes into contact.  This reversal or inhibition of swelling is
caused  by the chemical action of the constituents with the
surface of the bentonite. This tendency can  be reduced
somewhat  by  prehydration of the bentonite  with fresh
water.  Prehydration  provides some protection against  the
deteriorating effect of contaminants by providing a barrier
of  water   between the  bentonite   and  contaminants.
However, such protection is only good in the presence of
low  level   contaminants   on  a   permanent  basis.  For
conditions that exist at the Stringfellow Disposal Site, the
normal  leachate  composition  is  sufficient to  produce
substantial deterioration in the swelling of the bentonites.
      Although  either  locally-available natural  days  or
imported bentonite  could be used  as  a cover material  for
the  Stringfellow Disposal  Site  to   prevent   rainwater
infiltration, both materials  were deemed unsatisfactory as
base sealants for the  contaminated residues at the site. Only
modified  bentonites,  such  as Saline Seal  100, were
investigated for use as base sealants.
      In the  design of the base course for the evaporation
ponds, the 2 concepts considered were "zero leakage" and
"limited transmission".

"Zero Leakage" Concept

      The   "zero   leakage"  concept  envisions  the
construction  of  a  long-life evaporation  pond  with  no
leakage.  This  design  features installation of a single clay
layer   at  a  relatively  high  moisture  content, then
presaturating the clay with  uncontaminated water prior to
introduction  of the toxic industrial  wastes. The clay seal is
covered  with a  more  permeable  protective blanket  of
granular soil which  has 3  functions:  a reservoir for  the
presaturating water; a guard against drying and cracking of
the clay seal  if the pond is allowed to  become empty for a
short time; and an overburden to restrain expansion of the
clay layer.
      The  seepage  velocity  through  the  day  layer  is
 determined by the following equation:
                       ki
           vs    =  	                           (D
                       n
   where:  vs    =     the seepage velocity in cm /sec
           k    =     the permeability constant in
                         cm /sec
           i     =     the hydraulic gradient in the clay
                         layer
           n    =     the coefficient of roughness of the
                         surface

      The  hydraulic  gradient  is  equivalent to  the  total
 hydraulic  head  "h"   divided  by the  thickness  of the
 impervious  layer  "b".  Once  the base  is saturated, the
 capillary head is zero,  and the total  head is equivalent to
 the hydraulic head. The time required  for the liquid to
 percolate completely through the clay layer is:
                       (3.17 x 10-8)  —
                              (2)
   where:  T
the  period   in   years   for   the
contaminated fluid to pass through
the clay layer or the effective life of
the evaporation pond
thickness of impervious layer in cm
 Combining (1) and (2);

           T    =     (3.17x10-8 >( bkn  ")        (3)

      Pond  life  is an  inverse  function  of  total pond
 hydraulic   head.  Using  a  design  permeability   of
 k=1 x 10~8 cm./sec. and an effective porosity  of 0.33,  the
 pond life is illustrated in Figure 11 for various thicknesses
 of the low permeability layer, based  on the concept of zero
 leakage.

 "Limited Transmission" Concept

      The concept of limited transmission of contaminated
 fluid through the  base seal  can also be applied to the
 evaporation ponds while retaining full protection of the
 local ground water resources.  In this concept, a  limited
 volume of contaminated fluid is permitted to  pass through
the clay  layer. The amount is determined by the volume of
 water that can be either permanently retained in the upper
 alluvium by capillary forces or removed by extraction wells.
 Since the pond  itself provides a reliable  and permanent
 barrier   to  surface  infiltration  and evaporation,  the
contaminated  fluid is effectively  immobilized indefinitely.
      The pond life determinations shown in Figure 11 also
 represent the  onset of discharge of the contaminated fluid
at the base of the clay layer. The discharge quantity can be
determined directly from Darcy's Law, whereby the steady
state transmission rate (q) in cubic feet per year is:
                      106:
                             kh A
                              (4)
                                                       -204-

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          FIGURE 11



EVAPORATIVE POND DESIGN LIFE
    5  6  7  8 9 10




      POND  LIFE (YEARS)






            -205-
                                   30   40  50  60  70 80 90 100

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   where:   k
           h
           b
           A
permeability in cm /sec
hydraulic head in cm
base thickness in cm
area of flow in sq  ft
     The unit transmission  rates for various clay base
thicknesses and  fluid  heads  are  illustrated in Figure 12.
From the curves, a seal layer will pass only small quantities
of contaminated water even under conditions of small base
thickness and high pond head.
     If  a  controlled or  limited  effluent  transmission
concept  is  adopted, the upper alluvial soils immediately
underlying  the  pond can  be utilized  as a permanent
reservoir for the small  quantity of effluent discharged,
provided the effluent is  not transmitted into ground water
supplies. This provision  would  significantly increase the
useful life of the pond or allow construction of a thinner
base layer.
     Referring to Figure 12,  for example, a pond with a
10-foot head and a 2-foot thick clay base will  begin to
discharge contaminated water after 13 years, providing all
design  parameters are met. During any additional years of
discharge, the pond would  transmit 0.05 cu. ft. of fluid per
square  foot of base per  year (Figure 12). At this rate, the
total 4.2 acres  of pond  area  at the Stringfellow Disposal
Site would discharge about 70,000 gallons per year, if the
ponds were maintained at a depth of 10  feet.  Leachates of
this magnitude are  well within the removal capacities  of
small extraction wells.
     A  satisfactory configuration  of  day  sealant and
extraction wells for  the evaporation ponds  can be designed
to  eliminate  completely  the seepage  of contaminated
liquids   into  the  ground water  system.   This  can  be
accomplished  under  the  "zero  leakage"  concept  by
specifying the time frame of pond utilization or under the
"limited transmission" concept by specifying the capacity
of  downstream extraction  wells. The "zero leakage" pond
life can be determined from Figure 11 as a function of base
thickness and fluid depth, assuming a permeability of 10~&
cm /sec  for the clay sealant. Similarly, the  thickness of the
day layer and the operating head can be determined from
Figure 12  as  the  function of an  acceptable  volume  of
effluent using the "limited transmission" concept.
     Theoretically,  the  clay seal can be set at any finite
thickness conforming to  the hydraulic  head and pond
lifetime  parameters.  For practical reasons, the minimum
recommended thickness is 10  inches, because the layer
should  not be constructed in less  than 2 lifts, and  the
thickness of each lift should not be reduced below 5 inches
for effective compaction.

CHEMICAL MODIFICATION

      The  chemical modification of the soil pH via  the
addition of lime or sodium hydroxide would have several
beneficial effects. First, an increase in the soil pH above
current  acidic  conditions would immobilize heavy metals
through  precipitation   and/or  adsorption.   Second,
contaminated liquids in  the near neutral pH  range would
not dissolve underlying  limestone layers as readily as low
pH liquids.
     Third, clay layers have exhibited significantly greater
attenuation   capabilities  at higher pH's,  with respect  to
both swelling to  seal liquid  passages and  adsorption  of
heavy  metals.  If the  contaminated material  at  the
Stringfellow  Disposal  Site was restricted to  the upper few
inches  of soil, then the removal or neutralization of these
residues might be feasible.
     Because the  chemical composition of the residues in
the underlying soil was unknown, 3 borings were made at
sites indicated in  Figure 2. The  primary purpose of these
3-foot  deep  borings  was to  determine the extent  of
penetration  of the contaminated  material into the pond
base.  However, during the excavation to  remove  the soil
cores, the auger uncovered saturated material below a depth
of about 24 inches. The liquids which drained from samples
taken  between 24 inches  and 36 inches were obviously
heavily contaminated  with the industrial wastes. The extent
of contamination of the soil material in the upper 24 inches
was determined by chemical analyses  of liquids extracted
from laboratory-saturated soil samples. The  saturation and
extraction  were  performed   according  to  procedures
outlined  in  Methods of Analysis for Soils, Plants, and
Waters (Chapman  and Pratt,  1961). The results of these
analyses are presented in  Table 2.
      The highly acidic nature of the extracted soil water,
the penetration of the contaminated material deep into the
alluvium,   the  enormous  quantities  of  potentially
                                                              TABLE 2

                                                     CHEMICAL COMPOSITION OF
                                                      LIQUIDS EXTRACTED FROM
                                                      SATURATED SOIL SAMPLE
                                                          (September 22,1976)


Constituent (Units)
Anions
Chloride (mg/l)
Nitrate (mg/l)
Sulfate (mg/l)
Cations
Calcium (mg/l)
Magnesium (mg/l)
Potassium (mg/l)
Sodium (mg/l)
Trace Metals
Cadmium (mg/l)
Chromium (mg/l)
Lead (mg/l)
Mercury (mg/l)
Zinc (mg/l)
PH
Acidity (mg/l as CaCO3)
Conductivity (micromhos)
SITE I
SITE II
SITE III
Depth
6"-12"

1,220
4
54,400

2,405
3,207
36
3,280

9.5
460
1.7

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                      FIGURE 12
         EVAPORATIVE POND TRANSMISSION RATE
0.02        0.04        0.06         0.08         0.10
      TRANSMISSION  RATE (CU. FT./YEAR/SQUARE FOOT)

                         -207-
                                                        o.iz
                                                                  0.14

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contaminated alluvium (335,500 cu  yd ), and the high cost
of chemical bases combine to make chemical modification
unfeasible as a means of controlling the I each ate from the
Stringfellow Disposal Site.

LINERS AND MEMBRANES

      The  use of  liners  or  polymeric membranes  has
become  more  widespread,  especially in  conventional
sanitary landfills. Liners can be utilized in both the base
underneath  a disposal site and  as a cover over an existing
site.  The  composition of  the  polymeric liners  varies
considerably among various  producers and to some extent
between quality lines of a given producer. Consequently,
care must be taken in generalizing on the performance of a
given polymeric or membrane  liner.  Generally, however,
the  classes  of  polymeric  liners  are  at  least partially
identified:  (1) Polyethylene   (PE)-  hydrocarbon
polyethylene  plus  antidegradient  and  carbon   black;
(2) Plasticized  Polyviny(chloride   (PVC) -  hydrocarbon
polyvinylchloride plus antidegradient and filler; (3) Butyl
Rubber   Sheeting  —   isolbutylene  plus   isoprene;
(4)  Chlorosulfonated  Polyethylene   (Hypalon)  -
hydrocarbon   polyethylene  plus   rubber  and   fillers;
(5) Ethylene  Propylene Rubber -  synthetic  rubber  of
ethylene, propylene, and drene monomers; (6) Chlorinated
Polyethylene (CPE) - high density polyethylene.
      Research is  currently underway  to  determine  the
properties of liner membranes  during exposure to landfill
leachate (Haxo, N.D.).  At the present time, results of this
research are not available.  However, properties of the liner
membranes  determined in tests before exposure to landfill
leachate are presented in Table 3.
     A major problem with the use of liners has not been
actual characteristics of the material but rather the binding
of the relatively narrow widths of liner manufactured in the
factory  into  larger  sheets  for  field  use. The effective
performance   of  a   polymeric  membrane  is   critically
dependent  upon  the ability to  make large  impervious
sheets.   Usually the  narrow panels manufactured  in the
factory  are prefabricated into larger sheets when brought to
the  site.   The   more   durable   seams  are  usually
factory-formed, although  successful  field splices can  be
made  using  electronic  sealing,   solvent  welding,  or
heat-curing adhesives.  Other  major limitations  in the use of
liner materials are  their propensity to tear  under  stress
associated with differential settling of supporting material
and the propensity  for small holes located in  the material
during manufacturing  to grow larger and leak contaminated
material. Research efforts currently underway  are designed
to quantify the extent  of failure  expected from various
polymeric  liners.  A preliminary  result   indicates  that
considerable  variation exists between liners of  the same
type  of  polymer.   These  variations  probably  reflect
differences  in compounding  and  fabricating   the  liner
materials.
     The costs shown in  Table 3 do not include the cost
for site and  surface  preparation nor  the  cost  of ground
cover which would be required in all cases. The surfaces  on
which the  liners are  placed must  be graded  smooth for
drainage and compacted to  prevent settling of the ground
beneath the liner. The cost of site preparation  is  essentially
the same for all liner systems, although some liner systems
may not require as much effort and preparation as others.
                                                     TABLE 3

                             PROPERTIES OF LINER MEMBRANES BEFORE EXPOSURE
                                             TO LANDFILL LEACHATE
Type of Membrane
Polyethylene (PE)
Polyvinyl Chloride (PVC)
Butyl Rubber
Chlorosulfonated Poly-
ethylene (Hypalon)
Ethylene Propylene
Rubber
Chlorinated Polyethylene
(CPE)
Thickness
(mils)
10
20
63
34
51
31
Acids
good
poor
poor
very good
very good
very good
Resistances
Bases
good
very good
very good
very good
very good
very good
Solvents
poor
poor
poor
poor
poor
fair
Weatherability
poor
good
excellent
excellent
excellent
excellent
Permeability
(cm. /sec.)
2.3 x 10-3
1.3x 10~2
2.9 x 10~3
5.2 x 10~3
5.3 x ID"3
3.3 x ID"3
Installed
Cost
($/sq. yd.)
1.20-1.90
1.50-2.80
4.25-5.20
3.75-4.00
3.45-4.45
3.15-4.20
                                                      -208-

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ADMIXTURES

     The  admix or formed-in-place liner systems include
hard surface  linings  and  soil  sealants.  They  are  made
by: (1) importing  an  admix  material,  such  as asphalt
concrete, and placing it in thicknesses of 2 inches or more;
or (2) mixing Portland cement or asphalt with the in-place
soil (or sometimes with  imported  soil)  to  form a hard
surface  more  than 6  inches  thick;  or (3)  spreading on
surface  sealant materials, such as  emulsion  seals,  rubber
latexes, resin solutions, expanding clays, or various forms of
asphalts. The  6 admixtures receiving  most  prevalent use
today  are:   (1)  Asphalt  Concrete-   hot-mixed   and
hot-placed  conventional  asphaltic concrete;  (2) Hydraulic
Asphalt Concrete  - hot-mixed  and hot-placed asphaltic
concrete with better aggregate gradation and more asphalt
to achieve voidless structure; (3) Soil Cement - Portland
cement  compacted with  in-place soil; (4) Soil Asphalt -
liquid asphalt compacted with in-place soil; (5) Bituminous
Soil - catalytically blown asphalt; liquid asphalt air-blown
with  catalyst  to  produce tough,  flexible  membrane;
(6) Bituminous  Seal -   fabric    plus  asphalt  emulsion;
emulsion  of  asphalt  and  water  sprayed onto  supporting
fabric.
      At  the  present   time,  research  is  underway to
determine the properties of admixtures exposed to leachate
from  landfills  (Haxo,   N.D.).  The   properties  of the
 admixtures   before  their  exposure   to  leachate  are
 summarized in Table 4. As shown in Table 4,  2 of the major
 advantages of admixtures are their very low permeabilities
 and moderate  price.  As with the liner materials, the costs
 shown do not include site and surface preparation, which
 would  be extensive  since compaction  of the underlying
 material must be obtained.
      A major drawback  of   asphaltic compounds is
 that organic  solvents may not be acceptable at the disposal
 site because dissolution of the asphalt will result. Similarly,
 soil cement is susceptible to attack by acidic waste. Neither
 of these problems would arise if the admixture was used as
 a cover over an existing disposal  site.

 SUMMARY OF SEALANT PROPERTIES

      The potential  hazard of  a waste traveling from the
  bottom of the disposal  pond through the containing soil
  layer and into a ground water system may be evaluated in
  terms of the permeability of the containing soil layer and
  its thickness.  Because  all natural  and geological materials
  possess  some measureable permeability, it  is  fatuous to
  think in terms of  an impermeable bottom in  a landfill. Even
  in a situation where an  artificial lining material  (such as
  day, plastic membranes, or admixtures) has been applied to
  the bottom  of a disposal pond, quite probably the artificial
  liner would not be impermeable. For example, clay liners
  are attacked by a variety of chemicals and become more
  porous. An  old construction practice is to mix clay with
  lime to yield a more resistant soil. More recently, the clay is
  encapsulated  with  polymeric  materials to  improve  its
  resistance to  attack by acidic  and/or  salty waste-waters.
  Many  plastic materials  used  in  linings  are  attacked  by
organic  solvents,   oxidizing  agents,  and   other  waste
compounds.  In  addition,   thin  sheets of  impervious
polyvinylchloride or  polyethylene  lining  can  be easily
pierced and penetrated during placement or after placement
by  sharp-edged equipment or rocks. Asphaltic liners  may
likewise crack because of the distortions experienced when
the bottom soil settles as a result of the applied loads of the
liquid. Thus, in all cases a certain measureable permeability
of  the  bottom  confining  layer  must  be  anticipated.
However, the leakage from  the  site  can  be  minimized by
proper design of the  base sealant and the cover material.
Finally,  the  leakage may  be  prevented  from entering
useable groundwater formations via extraction wells.

ALTERNATIVES FOR  CLOSING DISPOSAL SITE

      Essentially  5  major alternatives were considered for
closing the  Stringfellow  Disposal Site;  these  alternatives
have  been labeled  "A" through "E".  In addition to the
major alternatives, 3 subalternatives  for Plans B, C, D, and
E were considered for the 3 different materials used for the
rain  cover  over the  residual  material.  Alternative B, for
example, "Leveling  Berms and Covering  Site",  has the
following three subalternatives:

      B1   Installing a  clay cover over the residual material
      B2   Installing an  admix  cover  over the residual
            material
      B3   Installing a membrane cover over  the residual
            material

 The   actions  taken  under   Alternative   A,  "Minimal
 Improvements", are incorporated into all of the subsequent
 Alternatives B through  E in that the items of Alternative A
 become essential parts  of these more complex alternatives.

 ALTERNATIVE A - MINIMAL IMPROVEMENTS

       Alternative   A  is  designed  to  provide immediate
 protection   of  the  ground water   resources  from the
 continued leakage of contaminants from the disposal site.
 The  tasks described  will reduce the surface and subsurface
 flow into   the site  (peripheral  berm repair), lessen the
 leakage from  the  site  (gel  injection  at concrete barrier),
 collect  surface  leakage   (bedrock  sump),  remove
 contaminated  soil  below  the  disposal   site  (minimal
 earthwork), and collect subsurface leakage (interceptor and
 monitoring wells).

 Minimal Earthwork

       During the 1969 storms, flooding of the disposal site
 caused  liquid wastes  to overtop the concrete barrier and
 then  percolate   into  the  downstream   alluvium. Soil
  discoloration from the wastes was observed during the field
  investigations in several locations along the  stream channel
  immediately downstream from the earthen dam.
       The  contaminated soil  which  forms  the  existing
  earthen  sump  and   lines   the  natural   channel  for
  approximately 100 yards  downstream of the collection
                                                        -209-

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                                                    TABLE 4

                              PROPERTIES OF ADMIXTURES BEFORE EXPOSURE
                                           TO LANDFILL LEACHATE
Type of Admixture
Asphalt concrete
Hydraulic asphalt
concrete
Soil cement
Soil asphalt
Bituminous seal
Fabric plus asphalt
emulsion
Thickness
(in)
2.2
2.4
4.5
4.0
0.3
0.3
Water Swell
(mil)
1
0
0
17
-
—
Compression
Strength
(% retained)*
80
86
69
15
-
—
Permeability
(cm /sec )
1.2 xlO-8
3.3 x 10~9
1.5x 10~6
1.7x10~3
<10-9
<10-9
Installed
Cost
(S/sq yd )
3.05-4.20
3.90-5.45
1.65
1.65
1.95-2.60
1.65-2.45
          After 24-hour immersion in water, asphalt concrete and hydraulic asphalt concrete at 60 C, and soil asphalt and soil
          cement at room temperature.
sump must be loaded and hauled into the disposal area for
dumping. This will  remove a major source of contaminants
which   currently  leach directly  into  the  downstream
monitoring well  (1Q1).  The ability of the existing drainage
ditch system to handle probable storm water  runoff from
the outlying drainage areas  was estimated from available
hydrologic  data,   drainage  engineering  formulas,  and
physical site information as viewed or as documented.
     The probable  storm water runoff from the watershed
areas  which  contribute  to the site drainage  system was
estimated by the rational method:
                      CiA
   where:  Q   =     runoff, cu ft /sec
           C   =     a "runoff"  coefficient, expressing
                      the ratio of the rate of runoff to
                      the rate of rainfall
           i     =     intensity of rainfall, in /hr,  for a
                      duration  equal  to  the  time of
                      concentration of the drainage area
           A   =     drainage area in acres

The  "runoff" coefficient,  as  presented in the  literature,
may vary from 0.2 for bare earth of relatively flat slopes
(and less for  growth cover) to as much as 0.95 for smooth,
impervious surfaces. For the purposes of this study and in
consideration of the relatively impervious nature of  much
of the  surrounding canyon side slopes,  values  of "C"
ranging  from 0.5 to 0.8 have been used,  depending upon
the average slope of a particular drainage area.
      For this study, the 100-year return period was chosen
as the nominal design value for the site drainage system. In
addition,  the  10,000-year  return  period was selected for
presentation   to  provide  quantitative  comparison   of
protection against floods in excess of the 100-year event.
      To  determine the capacities  of the  site drainage
system, a visual  survey of cross-sections  was made at
selected points along the side drainage  ditches. Manning's
equation  for uniform, steady flow in open  channels  was
used  to estimate the hydraulic carrying  capacity of  the
selected cross-sections.  Manning "n"  values published for
use in design of canals  and ditches range from 0.045 for
jagged,  irregular  rock  cuts to 0.020 for good, straight,
uniform earth. For this  study, an "n" value  of 0.040  was
chosen to approximate the worst conditions encountered in
any part of the drainage system. In fact, the actual  channel
conditions should usually be better. Therefore, the use of
this  more conservative  value  provides a  useful reference
point for estimating the probable  degree  of protection
provided  by the  existing drainage ditches. The calculated
flow  capacities of  the selected  cross-sections and  the
additive   flows  from   the  contributing  drainage  areas
indicated  that the lower western portion of the peripheral
berm was inadequate for design flood levels.  The roadway
berm should be heightened in that portion.
      The final earthwork item to be  constructed under
minimal improvements  is replacing the present material in
the northeast corner of  the peripheral berm with a clay fill
berm. The existence of willows and other ground cover in
the northeast corner of the  disposal site  indicates  that
surface runoff from the canyon sides is leaking through the
                                                      -210-

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peripheral berm at that location. Approximately 1,500 cu
yd of existing berm material must be bulldozed into the
disposal site and an equal amount of clay fill  placed and
compacted into a new, more impermeable berm structure.
At the same time, the drainage ditch must be reshaped to
divert runoff around the newly constructed portion of the
peripheral berm.

Gel Injection at Concrete Barrier

     The estimated 1 gallon per minute of seepage at the
concrete barrier  can be  stopped  if pressure  grouting is
employed with emphasis  on two areas. The gel should be
injected  first  on  the  upstream  side  of the barrier, and
second  into  the  bedrock  at  both ends of the  barrier,
particularly into the east abutment. When injecting into the
upstream location,  one   would    normally   remove
the overlying sludges and then drill and inject grout into the
bedrock.  However,  an  alternative  method  was selected
because of the cost  of removal of the saturated sludges.
Slant drill  holes penetrating under the  barrier from  the
downstream side are recommended to overcome the sludge
removal problem. Downstream  of the dam, holes should be
drilled on 3-foot centers, 10 feet deep and at an angle of 20
to 45 degrees  from the horizontal. At the east and west
abutments, vertical holes should be drilled into the bedrock
in line with the concrete barrier on 3-foot centers. Pressure
grouting at the west abutment should continue for 30 feet
and at the east abutment for at least 100 feet. This distance
could change if, during grouting operations, the bedrock
does  not appear to  be  accepting  grout,  indicating  no
fractures. The slant drilling technique, used  in  lieu  of
removing the sludges and injecting upstream, should be as
effective in sealing fractures in  the underlying material and
would  be  considerably  less  expensive than  the  other
method.
     Using  a liquid sample from one  of the evaporation
ponds, 3 types  of gel grouts were tested for possible use.
Initially, all  3 grouts have water-like viscosity, enabling the
solutions to penetrate deep into the small fractures. Two
fluids are individually  pumped into the leakage area and
then  mixed together,  initiating a chemical reaction. The
mixture  is then  forced  under  pressure into the fractures
where it forms  a gelantinous seal. The trade names of the
gel recommended  are  Injectrol  (a silica)  gel), PWG  (a
polymeric water gel), and Herculox  (a formaldehyde grout
which sets up hard). All appeared to withstand the low pH
ofthe leachate.

Bedrock Sump

     A  small   bedrock   sump should  be  constructed
downstream from the concrete barrier in the same location
as the earthen  sump currently in  operation.  A hole,  36
inches in diameter, should be  bored or blasted into the
bedrock 4 to 5 feet deep.  A perforated 12-inch PVC casing
should then be placed into the hole and gravel placed in the
annulus.   Using   a   corrosion-resistant   sump   pump,
automatically  controlled  by level-sensitive  switches  and
PVC discharge piping, the collected surface leakage should
be pumped directly into  a  new fiberglass tank for storage
and  subsequent disposal. In this manner,  leakage flowing
under the  barrier can  be picked up prior to its entry into
the downstream alluvium. By locating the bedrock sump in
the former stream  bed and taking advantage of the steep
sides of the bedrock in this area, leakage along the length of
the concrete barrier could be collected in a single sump.
      Leakage  beneath the concrete  barrier is currently
estimated  at  1 gallon per minute  (approximately 1,500
gallons per day). Depending upon the success of proposed
pressure  grouting of the concrete barrier, the bedrock sump
should collect  less  than  1,000  gallons per day.  Because of
the toxic nature of the  leakage, it must  be collected and
disposed of properly.  A 10,000 gallon plastic or fiberglass
tank for collection of these wastes  should  be installed on
the east  bank out of the flood  plain in an area accessible to
tank trucks. Waste liquids can then be properly managed by
hauling to  another Class I site.

Interceptor Wells

      Samples  from exploratory test  holes drilled in 1973,
downstream  from  the concrete  barrier, showed that the
conductivity  decreased  with  distance from  the  barrier
(Figure 13).  Additional  samples  taken in  1976 showed
essentially  the same pattern.
      An  interceptor  well  or  wells  should  be drilled
downstream   from  the  barrier  to  ensure  that  the
concentrated slug of pollutants below  the  barrier will not
contaminate downstream domestic wells and eventually the
adjacent receiving ground water basins.  The most desirable
location for  the interceptor wells would be approximately
1,800 feet southwest from the barrier as  determined by
plotting  concentrations  versus  distance,   as  shown  in
Figure 13.  At  this distance,  the  wells  should  cause a
depression sufficient  to  capture most of the pollutants
through  ground water  extraction  (Figure 14).
      The  extracted  pollutants  should  then  either  be
pumped into a new nearby pond for evaporation, used for
dust control, or hauled away for proper disposal (discussed
later).
      Because the interceptor wells will be in bedrock, the
most favorable location cannot be precisely stated. No data
or information are  available to suggest which path or exact
direction  the  contaminants  will  travel   on  their  way
downstream.  The  number of wells needed  to intercept
the pollutants  adequately  was  determined by assuming
certain   characteristics   of   the  underlying  aquifer.
Considering  all  available  data,  the  permeability   was
estimated at about  1 gallon per day/sq ft, the specific yield
at  5 percent, and  the extraction rate at  approximately 2
gallons per minute. From these  assumed characteristics, 2
wells 100  feet deep spaced approximately  300 feet  apart
should  provide the necessary  drawdown to guard against
leachates moving beyond the interceptor wells (Figure 14).
Because  of the low yield of these wells,  6-inch diameter
wells should be adequate. Steel casings should be installed
in the upper alluvial zones which  are prone to collapsing.
Small,  corrosion-resistant  submersible pumps  should  be
used with  automatic level-sensitive switches to maintain a
                                                        211

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                                  FIGURE 13

            GROUNDWATER QUALITY DOWNSTREAM FROM DISPOSAL SITE
36.000
32,000
                                                      1800 FEET
                                                  RECOMMENDED FOR
                                                    LOCATION OF
                                                 INTERCEPTOR WEL.US
                                                        2500


                       DISTANCE FROM CONCRETE BARRIER (FEET)



                                     -212-

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                                    FIGURE 14

                 CROSS SECTION R-R* SHOWING ESTIMATED DRAWDOWN
                              OF INTERCEPTOR WELLS
WEST
           INTERCEPTOR WELL
      SCALE

 HORIZONTAL.  l"« ZOO1

 VERTICAL.
                                                    APPROXIMATE
                                                    GROUND WATER LEVEL

                                                    CONE OF DEPRESSION
                                                    CAUSED BY PUMPING ONE WEL.L.

                                                    CONE OF DEPRESSION
                                                    CAUSED BY PUMPING BOTH WELLS
                                      -213-

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 proper  hydraulic gradient of the ground water surface. The
 exact  location  of  the water  level ing-sensing  switch  is
 dependent upon the  results of a pump  test.  To assure
 corrosion-free life of the discharge line, 1 %-inch Schedule
 80 PVC pipe should be installed and  buried between the
 wells and evaporation pond or collection tank.

 Disposal of Interceptor Well Water
      The ultimate disposal  of the waters  extracted from
 the interceptor well could be accomplished  through hauling
 or piping of all waters to either a nonreclaimable line or
 another  Class I  disposal  site. The advantages of off-site
 disposal  include  no  percolation  or  runoff  of  waters
 containing  high  total dissolved  solids  (TDS)  and  no
 construction of an evaporation pond. The only foreseen
 disadvantage is the continuous high operation cost.
      The most inexpensive method of disposal of  water
 pumped from the interceptor wells would be through direct
 on-site  land  application.  This well  water  could be  used
 either for dust control and/or irrigation. James Stringfellow
 is currently  using the entire production from Well No. 1Q1
 for this purpose with no apparent adverse effect Additional
 water  could be  used beneficially by Stringfellow in  his
 quarry operations.
      The main concern in land  application is  the quantity
 of salt  that  is deposited on the land through continuous
 operations.  Not only  are these  salts recirculated into the
 groundwater,  but they are also  dissolved in surface runoff
 and  transported farther downstream.  In reviewing the
 literature, no maximum  limit was found  specifying TDS
 levels for water used  for  dust  control. In developing a
 rational approach for limiting the maximum TDS allowable
 for   land   application,   annual  precipitation,   runoff
 characteristics, acreage used for application, and existing
 water quality standards were investigated.
      Because of runoff conditions, only waters with TDS
 levels of 4,000 mg /I   or less should be  used for  dust
 control.  Water with  greater than 4,000 mg /I  TDS should
 be properly  contained and  hauled  away  for disposal  or
 evaporated. To monitor properly the leaching of the salts to
the ground water,  all  dust  control  operations should  be
 confined upstream from the monitoring wells.
     Another method of disposal of the water pumped
 from the interceptor wells would be through use of a new
 evaporation   pond  constructed  for  this   purpose.  The
advantage of  this method  over on-site land application
 would be that salts would be confined in a lined pond and
 not allowed  to  percolate to  the ground water or migrate
downstream  through surface flow.  The disadvantage  of
constructing a new evaporation pond would  be the cost, the
 preparation of an Environmental  Impact Report (EIR), and
the approval of the project.
     Using estimated ground water production of 5 gallons
per minute from the interceptor  wells, the total extractions
may approach 8  acre-feet per year. Based  upon  these
estimates of  interceptor well  production, the  evaporation
pond will require 2 acres of land with a  6- to 7-foot berm or
dike around the perimeter. Final sizing of the evaporation
pond  should be accomplished after pump testing of the
interceptor wells.
      The evaporation pond should be utilized whether the
disposal  site is opened  or  closed. If the disposal site  is
opened, the water extracted from the interceptor wells can
be evaporated in a relatively inexpensive evaporation pond,
in lieu of utilizing valuable pond surface area in the Class I
disposal  site.  The anticipated  quantity of  extracted well
water, approximately 2.6 million gallons per year, would be
larger  than  the annual amount of wastes disposed in the
Stringfellow  Disposal  Site,  with  the exception of years
1971 and 1972.
      The  concentrated liquid  wastes  currently  in  the
disposal site (approximately 300,000 gallons) should not be
placed in the new evaporation pond because of their toxic
composition.   The   evaporation  pond,  as   currently
envisioned,  is   designed to accept  relatively  innocuous
ground water and not concentrated wastes. Salt buildup will
occur as evaporation of well water continues. However, the
chlorinated-polyethylene  liner   has   excellent  chemical
resistance in addition to good temperature and weathering
characteristics.

Monitoring Wells

      As  part  of   the  original  site  investigation,  the
California Department of Water Resources recommended
"...that  at   least   one   appropriate  well,   such   as
2S/6W—1Q1,  be sampled  periodically  to ascertain any
changes in ground water  quality  which might result from
operation of the dump." This recommendation has been
complied with  since the  inception of the project. However,
because of the location, use, and distance of Well 1Q1 from
the disposal site, this one well is  inadequate to monitor all
ground waters moving  through  the canyon.  Exploratory
drilling in 1973 indicated that contaminants had reached a
minimum of 1,500 feet downstream from the disposal site
whereas  by comparison  water quality samples  from Well
1Q1 showed only  modest  increases  in TDS. These  data
indicate that additional monitoring wells should be installed
in  strategic  locations within  the  canyon  to monitor
properly the  possible changes in ground water quality and
levels.  The importance of monitoring  should  not  be
overlooked.   Through  careful   monitoring,  undesirable
conditions will be noticed  and corrective measures can  be
taken  long  before the  situation becomes hazardous  or
irreversible. Proper  monitoring is essential in this type  of
operation.
      Figure 15 shows possible locations and approximate
total  depths  of 7  new monitoring wells,  the 2  new
interceptor wells, and 4 possible locations for the proposed
evaporation pond.

ALTERNATIVE B - LEVEL PONDS AND COVER SITE

      All  of  the actions outlined under Alternative  A,
"Minimal   Improvements",   are   incorporated   into
Alternative B.  Under the provisions of this alternative, the
berms  located  within  the disposal site would  be leveled.
Prior to the actual  earth moving operations, an estimated
300,000  gallons of  contaminated  liquid waste would have
to  be pumped  from the  existing  disposal  ponds  and
transported to an authorized Class I disposal site.
                                                       -214-

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                     FIGURE 15


            LOCATION MAP OF PROPOSED IMPROVEMENTS
 \ r\ i \\ift fn^^^^J ^(/ K
 "/  I 4 W ( ((r^^/'r^J \ ( ] *j¥
 d (i (4 ^-yyyJ i Hr^-^-	7 rr--^ )Brf
3 wyv-6 „
 ' 106'"" \
                      -215-

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     The existing liquid waste disposal ponds would then
be graded  to  achieve  gently  sloping contours within the
confines of the  existing peripheral  roadway berm.  The
graded site would then be covered with a layer of selected
material  from  off-site  to   prevent  direct  contact  of
contaminated  soil with surface runoff. An "impermeable"
lining or layer of low permeability admix or clay soil might
be installed against the base layer of imported fill and then
covered with a top layer of imported fill  to retard surface
water infiltration at the site (Figure 16).
      The site grading operation would involve not only the
earth moving and grading of the existing material but would
likely require the importation  of off-site borrow material to
work with  the saturated, unstable subsoil in the areas of the
ponds.
      The  surface of the graded site, composed partly of
contaminated  soils,  would  be  subject to  inundation by
rainfall  incident on  the site.  The installation of a surface
cover  would   greatly  retard the  further  leaching  of
contaminants  from  the  site  by  percolating surface water
and  would prevent the transport of contaminants from the
site  by erosion.  A surface cover would also serve to prevent
the incidence  of contaminated dust being transported from
the site during periods of high winds. In order to achieve a
high degree of protection against surface water infiltration,
several conventional  methods  could be employed to provide
a  special  layer  of  "impermeable"  or low permeability
material.  As   a    final    measure,  a   top  coat   of
loosely-compacted, selected off-site borrow soil would  be
placed  to  provide  protection for the  rain  seal material
against   exposure and  erosion  by  surface  runoff.  The
protection afforded  by this final layer of surface soil would
be enhanced by establishing a growth of selected grasses to
help control surface erosion.
      Three basic systems for the control of surface water
seepage are presented here for comparison:
      Clay Soil.  A  clay soil  cover installed over the level
residual  material would require  2 lifts, each 6 inches  in
depth, covering the  entire 16.7 acres of the  disposal  site.
Two 6-inch  layers   of  day are  recommended  because
construction in this  manner would minimize the possibility
of thin  areas occurring within the clay cover. The  first
6-inch  layer  should  be  spread,  brought  to  optimum
moisture content, and compacted to a minimum 85 percent
of maximum density as determined by American Society of
Testing Materials (ASTM) Test Designation  D1557-70. The
second  6-inch lift should be  leveled over the site, but not
compacted, because natural  grasses will grow on  the site
thereby preventing erosion of  the clay layer.
      In addition to its impermeability, the clay blanket
would  present  several additional  advantages over other
sealant  materials. First, the clay layer would be flexible in
that it  could  settle  with  the  underlying material.  In most
cases the clay  would settle with the underlying material and
maintain  its  impermeability. The clay blanket could be
easily installed  by conventional earth moving  equipment
and  could  be  readily  contoured to meet the shape of the
land. If large cracks  developed, the clay  layer could be
easily repaired  by the addition of new material. At the
downstream end of the  disposal pond,  the  clay  blanket
could be shaped to channel surface runoff into the existing
peripheral drainage  ditches.  In addition, the clay blanket
could  abut  the  downstream concrete  barrier,  thereby
preventing surface runoff from  entering the underlying
contaminated  material  and  simultaneously  suppressing
ground water movement over the top of the dam.
      One of the principal  advantages of the clay raincover
is  its low cost in comparison with admix and membrane
covers. This  low  cost depends to a large  extent  on the
availability  of day  supplies of  adequate  permeabilities
located in the vicinity of the Stringfellow Disposal Site.
      Admixtures.  Various chemical products are designed
and  marketed for use as soil amendments or sand mixture
applications as rainwater seepage  barriers. Soil additives are
usually mixed in place with clean, selected soil. Where the
existing soil is unsuitable for use as a mixture filler material,
as in the case of a highly contaminated soil, an imported lift
of suitable  soil is required. The barrier layer should be
placed against uniform, uncontaminated, compacted soil.
For this reason, a  layer of selected borrow material must be
placed against a contaminated mass of soil as a preliminary
step to the installation of an admix type of system.
      Admix systems that  have physical properties of good
flexibility or actual shear  capacity are subject to scour or
washout should they become exposed to running surface
water. Systems that possess superior tractive resistance are
more rigid  by nature and are therefore more subject to
cracking  and show  failure as in the case  of differential
settling.
      As an  example, a proprietary vegetable oil derivative
might be sprayed to saturate a relatively thick (1-inch) layer
of washed   river  sand, rolled,  and dried  to  produce  a
hydraulic barrier  to surface water seepage.  Although this
particular system  is more applicable to an area of relatively
flat  grade where the process can be closely controlled,  it
serves to illustrate a relatively  low cost type  of  admix
installation.
      Liner  Membrane.  For the  purpose  of preventing
rainwater   infiltration,   a  relatively  thin  sheet  of
polyethylene liner  material would suffice  to provide  a
continuous  "impermeable" membrane cover for the site.
Use  of lining material would require protection from the
forces of  nature and other possible damage.  This would be
accomplished by  filling over the polyethylene membrane
with a protective  top cover of soil. The soil, in turn, would
be the base for establishing a growth cover that would help
control erosion and eventual exposure of the  membrane.
      The chief advantage of  Alternative B,  to level the
existing ponds and  provide the surface of  the graded site
with a  protective   covering,  would  be  that  it  would
effectively retard  the mobilization of contaminants held in
the  soil  residue  at the lowest reasonable cost. The chief
disadvantage of this solution would be that the potential of
pollution would  not be  removed, but simply controlled.
The  controlling  would, theoretically,  require  continuous
vigilance  and continuous  maintenance  in the  foreseeable
future.   In   terms  of  overall  protection   per  dollar  of
expenditure.  Alternative  B could provide  for all  of the
major features of abatement at the lowest total cost.
                                                        -216-

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                                     FIGURE 16

                   CROSS-SECTIONAL VIEW OF ALTERNATIVE B, SHOWING
            CONTOURS OF LEVELED CONTAMINATED MATERIAL AND RAINCOVER
       EXISTING 8ERM
                               RAINCOVER (6" OF COMPACTED CLAYFILL, OR

                               «" OF FILL AND I" OF CHEMICAL ADMIX,

                               OR 10 MIL OF POLYETHVLENE
  DRAINAGE

   DITCH
-\ —if ft - - ' ,v ' ^ I~/N!/ 'v— .• •> I  I % i -"'V.' r/  _ i  "/"••»' -~ \\ -1~> lx v.~ - >'v -•' '-1x XC ^l V'1  - \',x ' \ - S '
                                     FIGURE 17

             CROSS-SECTIONAL VIEW OF ALTERNATIVE D SHOWING CLAY SEALANT
                    UNDER CONTAMINATED MATERIAL AND RAINCOVER
  EXISTING
   BERM
                                                    RAINCOVER (6* OF COMPACTED CLAY FILL,

                                                    OR 6" OF FILL AND I" OF CHEMICAL ADMIX,

                                                    OR 10 MIL OF POLYETHYLENE
                                         217-

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ALTERNATIVE  C -  FILL  TO  GRADE AND COVER
SITE

     Whereas Alternative B envisioned adding only enough
fill  (13,000  cu.  yd.)  to provide a  working surface for
bulldozers  to level  the  existing  berms  between  ponds,
Alternative C would require the addition of fill to bring the
level of the site up to the level of  the peripheral berms. In
addition to  the  importing  of fill, a raincover  would  be
installed on top of the fill material.
     The site filling operation would involve the leveling of
existing  ponds  below  the  elevation  of the  peripheral
roadway berm and the complete filling of the disposal site
with selected off-site borrow material. The main advantage
of this alternative, as with Alternative  B,  would  be the
provision of a protective covering to control the leaching of
contaminants from the site.  In addition,  it would provide
extra protection in the form of a greatly increased depth of
protective covering and  a site drainage profile that would
tend to shed surface  runoff  directly into the  peripheral
drainage system  without temporarily collecting over the
invert  of a central drainage system, as in Alternative B. The
chief disadvantage is the lack of a  total solution to the
threat of potential pollution. Attendant monitoring and
operation costs  would be  a factor here  also  for the
foreseeable future. The  additional protection provided by
this alternative  over  that of Alternative B would not be
proportional to the additional cost.

ALTERNATIVE D - ENCAPSULATE MATERIAL

      Alternative  D would require  5 separate  operations
before the contaminated material would be encapsulated
with a clay sealant underneath and a raincover above. The
first task would  be the  removal of  existing contaminated
liquid  and transporting it to an authorized Class I disposal
site.  Secondly,   the  contaminated   sludges  and  bottom
deposits would be bulldozed from the lower portions of the
site upstream for temporary storage. Thirdly, a clay sealant
approximately 10 inches in depth would be installed in the
lower  pond area. Following installation of the clay  sealant,
the contaminated material would be bulldozed back on top
of the clay and leveled in place. The fourth and fifth tasks
would consist of installing a raincover as  in Alternatives B
and C and providing minimal improvements to the surface
and ground water removal  systems  as  in  Alternative  A
(Figure 17).
      Because of the high salt concentration and low pH of
the  contaminated soil  material  (Table 2), ordinary clay
sealants would not  be adequate to form the base of the
encapsulated material. The effectiveness of the clay sealant
would depend upon the ability of the clay to swell upon
contact with water  and to  remain in this condition  as
contaminants were added above the clay layer.  However,
the high salt  concentration and low pH of the contaminants
would serve to neutralize the double-layer, repulsive effect
between individual clay particles, resulting in a significant
reduction  in the swelling  of the  clay layer.  In tests
conducted  by   the  American Colloid  Company,  pure
bentonite swells to  approximately  33  times its  original
volume upon addition of the extracted liquid from the
contaminated soil at the Stringfellow  Disposal Site. The
inability of natural clay materials to swell in the presence of
high salt concentrations and/or low pH's and their inability
to maintain the swollen condition in the presence of these
contaminants makes  the  installation  of  a natural  clay
sealant  under  the  contaminated  material  unfeasible.
However,  the American Colloid Company has developed a
proprietary  product, Saline Seal  100,  which enables the
bentonite  to resist  the  attack of high  salt or low pH
concentrations. Essentially, Saline Seal 100 is a process by
which   normal  clay  particles  are   encapsulated  with
polymeric   materials  which  provide  resistance   against
chemical attack. The addition of Saline Seal 100 to normal
fill material  in the  proper  quantities will provide a clay
sealant  of 10~^cm /sec permeability which is guaranteed
against  leakage for  30 years. American Colloid Company
determined   that  with  the  clay fill  available   at  the
Stringfellow Disposal Site, approximately 4.5 Ib /sq ft  of
Saline Seal 100 would be required to develop the requisite
impermeability to leaching. The Saline Seal 100 would be
disked  into  a 4-inch  layer  of the clay  fill  placed  on the
bottom of the disposal site. The combined material is then
moistened with fresh water and compacted to specifications
of the  American Colloid Company, using a smooth roller,
wobble wheel,  or  vibratory roller.  A sheepsfoot roller
should  be used  for  the compaction of this mixed blanket
only when the blanket is designed at least 6 inches in depth
in which  case the sheepsfoot roller  could function  as a
mixer and compactor.
      After installation and  compaction, fresh water would
have to be brought into contact with the Saline Seal 100 to
activate the  system  prior  to  subsequent  contact  with
contaminated waste. The fresh  water could be introduced
by filling  the basin with  water,or water may be applied by
sprinklers or sprayed from  water trucks. After installation
of the 4-inch mixed blanket of Saline Seal 100 and clay, a
6-inch layer of fill material would be applied to provide a
working surface for equipment.  Because this 6-inch  layer
would  be the clay  material available at the Stringfellow
Disposal Site, its low permeability would serve as a further
seal  against leakage. However, the primary purpose of this
6-inch layer would be to provide a working surface for the
tracked vehicles to push contaminated material back on top
of the clay  seal. The use of the clay sealant underneath the
contaminated materials would have several advantages. Clay
materials  are known for their self-sealing capacity; if a  small
leak occurred, additional clay would be drawn to the point
of leakage  and  would serve to  block  off the leaching of
contaminated materials. Additionally, clay  material could
be emplaced using standard earthwork techniques even in
the difficult terrain  at the bottom of  the canyon where the
disposal site is located.  Both admix and membrane covers
would  be  difficult to  install  under  these  conditions.
Furthermore, admixes and membranes are susceptible to
attack  by  organic  solvents and  petrochemical products,
both of which were  disposed of at the Stringfellow Disposal
Site. Membranes in particular may be easily punctured by
sharp  objects or  torn by the  action of the earth  moving
equipment on top of them. Similarly, both membranes and
                                                        -218-

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admixes could be sheared by the differential settling of any
residual waste materials entrapped beneath the cover. The
in-depth coverage of the clay material would provide added
security against the possibility of leakage. A schematic of
the completed encapsulation is shown in Figure 17.
     Alternative D provides a further degree  of protection
in that the leachate from the contaminated material would
be entrapped between the bottom clay sealant, the concrete
barrier at the southern end of the site, and the cover over
the top of the residual material.
     The main disadvantage would be  basically increased
cost  without  ensuring  to any   measurable degree the
long-term permanence of the encapsulation system's ability
to maintain a high level of integrity with  regard to the
interaction of ground water and site contaminants. As is the
case with Alternative C, this alternative  would not provide
an equal amount of additional long-term protection for the
required increase in cost over Alternative B.

ALTERNATIVE   E   -   REMOVE   CONTAMINATED
MATERIAL

      Alternative E essentially would consist of loading and
 hauling away  both the 300,000 gallons  of  contaminated
 liquid  within the site and an estimated  333,000 cu yd  of
 contaminated  soil material. These  materials  would  be
 hauled to an authorized Class I  disposal site.  After removal
 of the materials,  a raincover would  be installed over the
 granitic bedrock, thereby keeping rainwater from washing
 loose any residual  sediments trapped  in cracks and fissures
 on the valley floor.  All of the proposed rainwater barrier
 systems  previously discussed  in  Alternative B  would  be
 applicable for this purpose if the exposed bedrock and/or
 consolidated substrata presented  a  sufficiently  smooth,
 regular surface. If all  or portions of the exposed surface
 were determined to have too severe relief, sufficiently clean
 borrow material should  be imported to permit grading of
 the objectionable areas to a satisfactory slope or profile.
      The  obvious advantage of Alternative  E over the
  alternatives for containment is that the major source of
  potential pollution would  be permanently  removed from
  Pyrite  Canyon.  This  would leave  only the  subsurface
  residue of contaminants within the valley bedrock complex
  which would eventually move toward the proposed bedrock
  sump and  interceptor well  system.  Additionally, the
  potential for subsequent transport of toxic  materials from
  the site, if maintenance were neglected  in the future, would
  be greatly reduced.
       The  equally obvious disadvantage of this alternative
  over the previous alternatives would  be the  enormous cost
  that would be incurred if the project were undertaken. The
  potential  hazard of  transporting   330,000  cu  yd   of
  contaminated  material  over surface roads and  highways
  would be an additional concern here  that did not enter into
  the consideration of  the  containment alternatives.  It can
  also be  argued that removal of  the  existing contaminated
  material from one site to  another site would not eliminate
  the long-term problem of containment but would merely
  pass the potential problem along to another location and
  another community.
SUMMARY

      The  costs  of the  5  alternatives for  closing the
Stringfellow  Class I  Disposal  Site  are  summarized  in
Table 5.  All  costs  have been  based on 1976 prices for
materials, equipment,  and labor. The costs  as  presented
include a  10-percent  contingency  factor for  necessary
engineering,  legal,  and  administrative  expenses and  a
10-percent contingency factor for unforeseen expenses. The
costs  for  operating  the  completed  facility,   including
pumping of the bedrock sump and the interceptor  wells,
monthly  inspection   of   water quality,  and  monthly
inspection  of the condition  of the rain cover have been
estimated to be $3,000 per month.

ALTERNATIVES FOR OPENING DISPOSAL SITE

      Five alternatives  labeled  "F"  through  "I" were
considered for  opening the Stringfellow Class I Disposal
Site. Three different methods are  presented for installing
new pond sealants to serve as the  base underneath the
contaminated  liquid  waste.  Alternative H,  for  example,
"Leveling  Berms and Constructing  New  Ponds",  has 3
subalternatives:

   H1 - Install a mixed clay  liner of Saline Seal 100 and  fill
   H2 - Install an admix liner of chemical admix and fill
   H3 - Install a chlorinated  polyethylene liner and fill

 The  actions   taken   in   Alternative   F,   "Minimal
 Improvements", are  incorporated  into all the subsequent
 alternatives, G through I, because the items of Alternative F
 become essential parts of these more complex alternatives.

 ALTERNATIVE  F - MINIMAL IMPROVEMENTS FOR
 SITE OPENING

       The minimal improvements required for site opening
 are   essentially  the  same  as   those required  under
 Alternative A, "Minimal  Improvements for Site Closing".
 The bedrock  sump would be constructed  downstream of
 the concrete  barrier upon  removal of the  contaminated
 earthen  sump  presently at  that  location. In  lieu of
 constructing  a new  fiberglass holding  tank  for the sump
 leachate, the leachate would be pumped directly back into
 the disposal  ponds for evaporation.  This would result in
 significant savings over hauling away the  contaminated
 liquid. As with the site closing, gel injection at the concrete
 barrier  is highly  recommended as  a means  of reducing the
 escape  of leachate  from the site.  The interceptor well
 locations and capacities  would be the same as  in the site
 closing. The anticipated quantity  of extracted well water,
 approximately 2.6 million gallons  per year,  would be  too
 large a quantity to recycle into the  disposal area without
 severely restricting the quantity of industrial waste which
 can be  accepted. Therefore, a new evaporation pond would
  be   recommended.   The  monitoring  wells   shown  in
  Figure 15, would be  constructed and operated in the same
  manner as for site closing.
                                                        -219

-------
                                                                         TABLE 5
                                               CAPITAL AND OPERATING COSTS OF VARIOUS ALTERNATIVES FOR
                                                     CLOSING THE STRINGFELLOW CLASS I DISPOSAL SITE



CONSTRUCTION TASK

1. Sealing of Leachate in Site
A. Remove earthen sump (26,000 ydt. ),
Conitruct bedrock sump
Repair peripheral berm, NE corner
B. Inject gel at concrete barrier
C. Remove contaminated liquid
(300,000 gall.)
D. Remove contaminated soil
(333,500 yds.3)
E. Install cover over residuals
(1 a? acres)
1. day (6 in. of 10~'cm./sec.
perm, clay & 6 in. of fill)
Z Admix (1 in. of admix and
i 6 in. of fill)
s 3. Liner membrane (10 mil.
PE and 6 in. of fill)
II. Encapsulating Residuals in Site*
A. Level site, add fill
(13,000 yds.3) at ponds
B. Add fill to level of berms
(310,000yds.3)
C. Install clay sealant under
contaminated material (4 in. of
10""**cm./sec. perm, clay w/Saline
Seal 100 and 6 in. of fill)
D. Remove contaminated material
and replace on clay sealant
III. Collecting/Monitoring Leachate from Site
A. Interceptor wells (2 each)
B. Evaporation pond (2 acre)
C. Monitoring wells (7 each)
Total Capital Cost
Monthly Operating Cost ($1,000/month)
ALTERNATIVE COSTS ($1,000)


A
Minimi
minimal
1 mprowmwits
$ 25
13
S
12
























18
107
10
190
3
B
Level Barms and Cover Site
B1
dm*
may
Cover
$ 26
13
5
12

35





75






70









18
107
10
370
3
B2
ArlftMli,
Main IX
Cover
$ 25
13
5
12

35







210




70









18
107
10
495
3
B3
ftjl ABH|B M. •• A
Membrane
Cover
$ 25
13
5
12

35









170


70









18
107
10
465
3
C
Fill to Grade and Cover Site
C1
*%!_-.
day
Cover
$ 25
13
5
12

35





10








770







18
107
10
1,010
3
C2
A^BMlw
Admix
Cover
$ 25
13
5
12

35







210






770







18
107
10
1,205
3
C3
Kfl^llJH •!!•
IVIVIIIUIBM
Cover
$ 25
13
5
12

35









170




770







18
107
10
1,165
3
D
Encapsulate Material
D1
Clay
Cover
$ 25
13
5
12

35





75






35





410

105

18
107
10
850
3
D2
Arlmiv
Mu mix
Cover
$ 25
13
5
12

35







210




35





410

105

18
107
10
985
3
D3
Bflaiiihi ••»•
mvmDranv
Cover
$ 25
13
5
12

35









170


35





410

105

18
107
10
945
3
E
Remove Contaminated Material
E1
Mfi
rao
Cover
$ 25
13
5
12

35

3,400




















18
107
10
3,625
3
E2
PI«*
uay
Cover
$ 25
13
5
12

35

3,400



75
















18
107
10
3,700
3
E3
Arimlv
Mumix
Cover
-$ 25
13
5
12

35

3,400





210














18
107
10
3,835
3
E4
Cover
$ 25
13
5
12

35

3,400







170












18
107
10
3,795
3
Costs based on using clay fill of permeability 10   cm./soc. which Is available at Stringfellow quarry and/or immediate vicinity.

-------
     Several advantages would accrue  from opening  the
Stringfellow Class I Disposal Site. There is a large demand
for disposal sites of this type, and its  reopening  would
enable waste-producing industries in the Fontana- Riverside
area to  have  access to a  convenient disposal  area. The
revenues from disposal charges imposed  at the Stringfellow
Disposal Site could  be used to pay for the improvements
outlined in this section.

ALTERNATIVE G - BENTONITE SLURRY ON PONDS

     The placing of a bentonite slurry on existing ponds
takes advantage of the original construction work used to
shape  the disposal area, while recognizing that  beneath a
depth of 2  feet under the ponds, the soil is saturated  and
unstable. For this reason,  heavy equipment could not be
utilized to emplace a clay sealant over existing surfaces. In
lieu of the usual disking of the Saline  Seal  100 into the
pond's surface  followed by  compaction, a slurry technique
has been devised in which Saline Seal  100 would be mixed
with  fill material  and then slurried on top of the existing
pond structure. After the clay slurry had been emplaced, a
6-inch layer of fill material would be placed over the mixed
blanket  to ensure that moisture would  be retained within
the mixed clay blanket. Because of the impermeability of
the fill  material  at  the  Stringfellow Disposal  Site,  this
additional 6 inches of clay fill would also serve to seal the
pond  from further  leakage. A properly installed  4-inch
Saline Seal  100 layer  is guaranteed by the  manufacturer
against leakage for 30 years.
     Although use  of the bentonite  slurry on  existing
ponds  would  provide new  impermeable  pond surfaces,
disadvantages to this alternative exist. First, the  use of the
bentonite slurry  on the pond surfaces only  would  not
enable the continued use of the evaporation sprayers which
are located on  land adjacent to  the  actual evaporation
ponds.  Because  of  the  site  layout, installation  of the
bentonite slurry  beneath the evaporation sprayer  area is
considered impractical. The emplacement of the bentonite
slurry on the existing ponds would not deter the continued
leaching from uncovered residues at the site. The net effect
of the  slurry  would  be to prevent new materials from
entering  the   leachate-ground water system.  Use  of  the
bentonite slurry system could be utilized as a first-aid type
repair  to   a  well-designed Class  I  disposal  site  which,
nevertheless, has  developed some  leakage.  The bentonite
slurry would effectively seal small  cracks or fissures which
might develop  in  an  otherwise impermeable Class I facility.
 For a facility such as the Stringfellow Disposal Site, with a
 large  surface  area and randomly-designed disposal  ponds
 and evaporation sprayers,  the bentonite slurry  method of
 correcting  the leakage of  liquids from the  site   is  not
 recommended.

 ALTERNATIVE  H  - LEVEL BERMS AND CONSTRUCT
 NEW PONDS

      Alternative H  is a  modification of  the  previously
 described Alternative B for site closure. In lieu  of leveling
 the existing ponds and berm  structure  into a gentle swale
along the contours of the valley, the  residuum would be
shaped  into  new  disposal  ponds in  a  stair-step fashion
upstream from the concrete barrier.  Following the shaping
of the ponds, 6 inches of a clay  fill  would be placed atop
the  residual material.   The  day   layer,  compacted  to
85 percent of maximum density, would serve to protect the
underlying residuum from incipient  rainwater and/or new
liquid wastes, and would serve in the pond area as the base
course for the final pond sealants which must be installed
prior to reopening the disposal  ponds.  In the remaining
areas of the  site, a second 6-inch  lift would be  installed to
enable native grasses to take root and prevent erosion of the
clay raincover.  Figure 18 is a  cross-sectional view of the
effects of Alternative H.
      Alternative H would require 4 separate tasks to create
a new solar evaporation pond system wherein liquid wastes
would be contained above the surface of the site by the use
of chemical-resistant pond liners. The first task  would be
providing the minimal  improvements  to the surface  and
ground water interception  systems   as   outlined   in
Alternative F. The second task would be the  removal of
residual  liquid wastes from the existing  ponds. The third
task  would  be  the leveling of the  existing  ponds  and
regrading the site to create the newly-formed pond system
and a uniformly contoured site surface. The fourth  task
would be lining the new ponds against seepage of liquid
contaminants into the site  substrata.  Three basic systems
for the control of waste pond seepage are presented  here
for comparison.
Clay
      The clay sealant consists of a bottom layer, 4 inches
thick,  of   highly   impermeable   clay   (10~^cm/sec
permeability). Roughly 4.5 Ibs/sq  ft, of Saline Seal 100
are  mixed with  or disked  into this 4-inch layer.  Once
compacted  under  the proper moisture  conditions, the
mixed blanket of Saline Seal 100 and clay would serve  to
resist chemical attack caused by either low pH or high salt
concentrations.  The  mixed  blanket  would  have  to  be
moistened with fresh water and compacted to the standards
of  the  American  Colloid  Company to  ensure proper
activation of the Saline  Seal  100. Compaction  would  be
accomplished through the use of a smooth roller, wobble
wheel roller, or a vibratory roller.  The Saline Seal 100
would have to be maintained in continuous contact with
fresh water prior to disposal of contaminated liquid wastes.
Fresh water could be applied by flooding the pond areas or
through  use  of  sprayers  or irrigation  trucks.  After the
installation of the  4-inch mixed blanket, a 6-inch layer  of
fill material  would be applied over the mixed  blanket  to
ensure  moisture retention during  low pond  levels. This
6-inch working  layer would be especially important if the
ponds were  ever allowed to dry, in which case the layer
would provide a moisture retention capacity to the overall
sealant.  In  addition, because the clay at the Stringfellow
 Disposal Site has a permeability of 10~8cm /sec, this lift
would provide a further barrier against the movement  of
contaminated liquid through the pond sealant.
                                                       - 221 -

-------
                                  FIGURE 18

          CROSS-SECTIONAL VIEW OF ALTERNATIVE H, SHOWING CONTOURS OF
        SHAPED CONTAMINATED MATERIAL AND THE NEW POND SEALANT SYSTEM
                                              SEALANT (4 OF MIXED SALINE SEAL 100
                                          OR 6 OF CHEMICAL ADMIX. WITH CLAY FILL,
                                               ON 30 MIL OF CHLORINATED
                                                 POLYETHYLENE LINER)
   EXISTING
     BERM
              COVER III* OF COMPACTED CLAY
                 FILL IN Z EACH «• LIFTS)
                                FIGURE 19

 CROSS-SECTIONAL VIEW OF ALTERNATIVE I, SHOWING ENCAPSULATED CONTAMINATED
        MATERIAL SHAPED INTO NEW PONDS, WITH OVERLYING POND SEALANT
  COVER (IZ  OF COMPACTED CLAY
     FILL IN Z EACH s" LIFTS)
EXISTING
 BERM
                               POND SEALANT (4 OF MIXED SALINE SEAL
                                      CLAY FILL, OR 6* OF CHEMICAL
                                         V) MIL OF CHLORINATED
                                     POLYETHYLENE LINER)
              WEARING SURFACE
              («" OF CLAY FILL)
DRAINAGE
  DITCH
                              CONTAMINATED
                                  -222-

-------
 Admixtures

      As in the case of surface covers and rainseals, various
 chemical  products  are designed  and  marketed  as  soil
 amendments for use  as  barriers against the seepage  of
 waters containing relatively  large quantities  of chemicals
 such  as  industrial   wastes.  Soil additives  are preferably
 mixed in place with  clean, selected soils.  Where existing soil
 is unsuitable for use as a mixture material, as  in the case of
 highly contaminated soil, an imported lift  of suitable soil
 would be  required. The barrier layer  should be  placed
 against  uncontaminated,  compacted  soil.  A proprietary
 2-part admix system would consist of spreading a polymer
 admix (Chem-crete "Hydroseal" TM) on the surface  of a
 12-inch layer of imported borrow and mixing it into the
 soil to a depth of 6 inches with a heavy duty rototiller. The
 admix layer  would  be compacted with  a heavy-duty  steel
 drum vibratory roller,  and the compacted surface would be
 sprayed with 2  consecutive  coats of a  urethane product
 (Grove  Specialities  X-1000  polymer TM). The  finished
 surface would then  be covered  with  a protective layer of
 soil.

 Liner Membrane

      Based on a survey of  similar applications  regarding
 containment  of chrome-plating wastes and other industrial
 acids, chlorinated polyethylene  (CPE), appears to be the
 most  suitable material  to  use as pond liner membrane. A
 2-ply,  30-mil,  dacron-reinforced CPE   liner would  be
 selected.  The  weatherability  of  CPE   with  regard  to
 ultraviolet light is rated as good to excellent  when properly
 compounded, and therefore would not necessarily require a
 protective  overcovering of soil as long as the ends of the
 liner were firmly anchored in the side berms.
      The chief advantage of Alternative H  would be that
 the aggravated mobilization of contaminants in the site soil
 caused by  percolation  of pond wastes would be prevented,
 and a  first line of defense would be created at the interface
 of the pond liners and the liquid waste. The disadvantage of
 Alternative  H is that the  use of a pond liner would  not
 guarantee  integrity  of  the liner material with regard to
 permeability.  Settling,  mechanical damage, seam failure,
 installation  imperfections, and burrowing animals could all
 contribute   to defeat  the  basic impermeability  of  any
 material. In terms of overall protection provided per dollar
 of expenditure, Alternative H would  provide the major
 features  of  protection  against  further   contaminant
 percolation at the lowest total cost.

 ALTERNATIVE I -  ENCAPSULATE  SITE,  CONSTRUCT
 NEW PONDS

     Alternative  I consists of 5 operations  to reopen  the
site with new, lined  ponds constructed  over  the existing
contaminated material following complete encapsulation of
the contaminated material in the manner described under
Alternative D. The first task would be the installation of all
of   the    minimal     improvements   proposed   under
Alternative F. The second task would be the removal of the
 existing contaminated liquid from the site. The third task
 would be the  installation of a clay sealant between the
 contaminated  overburden   and   the  bedrock  complex
 underlying the site, regrading the site while replacing the
 overburden,  and shaping  a new pond system. The fourth
 task would  be the  placement of  a surface cover over the
 site, including the newly constructed pond areas. The fifth
 task would be the installation of a pond liner system on the
 newly formed ponds.
       Figure  19  is  a  cross-sectional  drawing  of  the
 encapsulation of the contaminated  material between the
 underlying clay layer and the overlying new pond structure.
 As  with Alternative D, the existing contaminated material
 would be stored on top of a  Saline Seal 100 clay-fill
 blanket.  In  lieu of completely leveling the contaminated
 material   and  installing  a  raincover,   the  existing
 contaminated residue would be shaped in the form of new
 ponds and covered  with a 6-inch compacted clay layer. A
 6-inch top  cover  layer  would be installed  to  provide a
 growth surface for native grasses.  New pond sealants would
 be installed on top of the clay layer as per Alternative H.
       The  advantage  of Alternative  I  would  be   the
 abatement  of   the  present  problem  of  contaminated
 leachates leaving the disposal  site  while still permitting the
 site to reopen. Encapsulation of the existing contaminants,
 as discussed in Alternative D, would minimize and control
 the  interaction of external surface water and ground water
 because the toxic residues would be held within the existing
 site, thereby  suppressing the  mechanism  for the transport
 of    pollutants  beyond   the  concrete   barrier.   The
 disadvantages  of Alternative I, along  with  substantially
 increased  cost, would be essentially the  same  as those
 outlined for  Alternative H,  with  the exception that the
 problems of ground water infiltration and leakage would be
 corrected.

 ALTERNATIVE  J   -   REMOVE   CONTAMINATED
 MATERIAL, CONSTRUCT NEW PONDS

      Alternative J consists of 5 tasks to remove  all of the
 contaminated  material  from the  site  in  the manner
 described  under  Alternative F. Alternative J would start
 anew by building new, lined ponds in the original disposal
 area.  Initially, all of the improvements proposed  under
 Alternative F   for   minimal   improvements would   be
 accomplished. The second task would be the removal of the
 existing contaminated liquid from the site. The third task
 would be the removal of the contaminated  soil  from the
 site. The fourth  task would  be the construction  of a new
 pond system  with  clean,  imported borrow  material. The
 fifth  task would  be the installation of a pond liner system
 in the newly created ponds.
      The major  advantages of Alternative J would be the
elimination  of   potential   pollution   as  outlined   in
Alternative E, under conditions that would allow the site to
resume operation as a  regional,  controlled  location  for
liquid toxic waste disposal. Alternative J would  provide a
new  well-engineered  beginning  to   the  disposal   of
contaminated  wastes  at  the Stringfellow  Disposal Site.
Existing  contaminated  material  would  be completely
                                                      -223-

-------
removed and  new pond sealants installed to complement
the  relatively  impermeable  granitic  bedrock  of  Pyrite
Canyon. The primary  disadvantage of Alternative J would
be its enormous cost in comparison to the benefits to be
derived  from such an undertaking. As  discussed previously
in Alternative E, a serious question arises as to the logical
priority of allocating the amount of  money necessary to
accomplish this feat  when viewed in terms of the probable
environmental  protection  that  would   be  afforded. In
addition,  no  guarantee  exists  that  any  of  the other
authorized Class I disposal  sites  which would  accept the
Stringfellow wastes will not become damaged or altered in
some way,  resulting in  continued  problems with these
wastes.

SUMMARY

     The  costs  for  opening the   Stringfellow  Class I
Disposal Site  are summarized in Table 6. All prices are
based on  1976 costs for materials, equipment, and labor.
The costs as  presented  include a 10-percent contingency
factor for administration, legal, and engineering expenses,
and a 10-percent factor for unforeseen  contingencies.
      The  costs  for  operating  the  completed  facility,
including pumping of the bedrock sump and the interceptor
wells,  monthly inspection of ground water quality,  and
monthly  inspection  of  the  overall  site condition  are
estimated at $1,000 per month.

RECOMMENDATIONS

      Based on the  results of the foregoing study of the
various  techniques  available  to prevent the  leakage of
contaminated  liquids from the Stringfellow Class I Disposal
Site, and of the ability to intercept these wastes after  they
have  left  the site,  and   based  on  cost  considerations
summarized  in  Table 5, the recommended  solution for
closing   the   Stringfellow  Class I    Disposal   Site  is
Alternative B1.
     Alternative  B1 would  present  a  defense in depth
against  the  possibility  of  leachate  reaching downstream
ground  water supplies. The first and primary line of defense
would be the  interceptor wells to be located approximately
1,800 feet downstream of the Class  I disposal site.  The
second  line of defense would  consist of gel injection at the
concrete barrier and the downstream  bedrock sump. Both
should  significantly  enhance  the possibilities of  retaining
leachate within the disposal site. The  third line of defense
would   be  covering  the residual material  under  a  clay
blanket, thereby  preventing  rainwater  infiltration  and
preventing the surface residues from  becoming air-borne
during high velocity  wind conditions in the Pyrite Canyon.
     The  clay  raincover  installed  for  Alternative B1  is
recommended over the admix and membrane covers on the
basis of the ready availability of a high quality clay fill for
use for this purpose,  the  ease of construction, the reliability
of the material against shear and differential settling, the
ease of repair, and the significantly lower costs for the clay
blanket.
      If the  decision is made  to reopen the Stringfellow
Class I Disposal Site, Alternative H1 is recommended for
construction. Alternative H1 has essentially the same steps
as Alternative B1, up  to the  installation of the raincover
which  would be  omitted  if  the site  is reopened.  After
leveling the site through the addition of 13,000 cu  yd  of
fill  material,  new ponds would be shaped and a 6-inch base
course of clay  fill installed over the entire site. After the
installation  of  the protective  blanket, new pond sealants,
consisting of 4 inches of 10~^cm/sec permeability clay
mixed with Saline Seal  100, and 6 inches of  fill material
would be installed.  The monthly operating costs for site
opening would be $2,000/month less than for site closing,
because the contaminated leachates from the bedrock sump
would not  have to  be hauled  to an  authorized  Class I
disposal site but instead would be recirculated back into the
disposal ponds.
      The  installation  of  clay  sealant  beneath the  new
ponds is recommended over the use of  the chemical admix
because of its  proven  resistance to toxic wastes including
low pH and high salt concentrations. The clay layer also has
the  properties  of  self-sealing,  ready  reparability  and
flexibility with regard to settling of  the underlying material.
In  addition,  the clay  sealants for the  pond  could  be
installed at roughly 50 percent  of the cost of the  admix
sealant.
      Although  the chlorinated polyethylene liner  is  a
proven method for sealing the flow of highly contaminated
liquid wastes and would be comparable in cost with the
clay sealant,  the difficulties of installing such  a liner at this
particular site and  the  possibility  that the  underlying
material would sink as moisture seeps downstream, thereby
imposing  strong  shear  stresses against  the overlying liner,
would shift the balance for ihe more flexible clay sealant.
      If Alternative  B1 is  adopted for  closing of the site,
monthly sampling of  the  ground water at the monitoring
and interceptor wells would be required. From the monthly
samples,  the  trace   metal  concentrations  should   be
determined  as well as  the other  inorganic constituents
normally  measured.   Through   use  of  the   topographic
techniques  showing  the  changes  in  concentration  with
distance and time,  the movement of leachate from the
disposal  area  could  be   readily   observed,  and   the
effectiveness of  the  interceptor  wells  in  removing the
contaminated ground water should be apparent.
      Simultaneous with the collection of  the  monthly
ground water samples,  the  entire disposal  site should  be
inspected for erosion of the clay blanket, blockage of the
peripheral surface ditches,  corrosion or malfunction of the
bedrock sump pump,  malfunction  of  the interceptor well
pumps, and the overall appearance of the disposal site. This
monthly  inspection  also  should verify  compliance  with
SARWQCB  orders relating to securing the site from outside
intrusion.
                                                       -224-

-------
                                                                                        TABLE O




                             CAPITAL AND OPERATING COSTS OF VARIOUS ALTERNATIVES FOR OPENING THE STRINGFELLOW CLASS I DISPOSAL SITE





CONSTRUCTION TASK


1. Sealing of Leachate in Site
A. Remove earthen sump (25,000 yds.3)
Construct bedrock sump
Repair peripheral berm
B. Inject gel at concrete barrier
C. Remove contaminated liquid
(300,000 gals.)
D. Remove contaminated soil
(333,500yds.3)
II. Reconstruct Disposal Ponds*
A. Slurry bentonite on existing
ponds (4.8 acres)
M B. Level site, add fill
% (13,000 yds.3) at ponds
' C. Shape new ponds (and
add 6 in. of fill I
D. Install pond sealants
(4.8 acres)
1. Clay (4 in. of 10~8cm./sec.
perm, clay w/Saline
Seal 100 and 6 in. of fill)
2. Admix (6 in. of fill
and 6 in. of chemical admix)
3. CPE (30 mil) and 6 in. of fill
E. Install clay sealant under
contaminated material (4 in. of
10~°cm./sec. perm clay w/Saline
Seal 100 and 6 in. of fill material)
F. Remove contaminated material
and replace on clay sealant
G. Top cover (6 in. of
uncompacted fill)
III. Collecting/Monitoring Leachate from Site
A. Interceptor wells (2 each)
B. Evaporation pond (2 acres)
C. Monitoring wells (6 each)
Total Capital Cost
Monthly Operating Cost ($1,000/month)
ALTERNATIVE COSTS ($1,000)




F
Minimal
Improvements

25
13
5
12




























18
107
10
190
1



G
Bentonite
Slurry on
Existing
Ponds

25
13
5
12

35




225





















18
107
10
450
1

H
Level barms.
construct new ponds
H1
Clay
Sealant

25
13
5
12

35






70

60




120










25

18
107
10
500
1
H2
Admix
Sealant

25
13
5
12

35






70

60






230








25

18
107
10
610
1
H3
Membrane
Sealant

25
13
5
12

35






70

60







100







25

18
107
10
480
1

1
Encapsulate material.
construct new ponds
11
Clay
Sealant

25
13
5
12

35






35

60




120






410

105

25

18
107
10
980
1
12
Admix
Sealant

25
13
5
12

35






35

60






230




410

105

25

18
107
10
1,090
1
13
Membrane
Sealant

25
13
5
12

35






35

60







100



410

105

25

18
107
10
960
1
J
Remove contaminated
material.
construct new ponds
J1
Clay
Sealant

25
13
5
12

35

3,400






190




120












18
107
10
3,935
1
J2
Admix
Sealant

25
13
5
12

35

3,400






190






230










18
107
10
4,045
1
J3
Membrane
Sealant

25
13
5
12

35

3,400






190







100









18
107
10
3,915
1
*   Costs based on using clay fill of permeability 10~"8 cm./sec. which is available at Strlngfellow quarry and/or Immediate vicinity.

-------
      Monitoring  requirements   for   ground  water  and
physical inspection of the adequacy of the facilities should
be identical for site opening.


ACKNOWLEDGMENT


      Principal investigators, along with the author, on this
study were Ronald L. Barto, Hydrogeologist, and Kenneth
A. Lane, Engineer. The manuscript was typed and edited by
Karen L. Johnson, and graphic drawings were prepared by
Larry S. Quay.
                    REFERENCES CITED

Fuller, W. H., and N. Korte. Alteration mechanisms of pollutants
    through soils. University of Arizona Agricultural  Experiment
    Station, Department of Soil, Water, and Engineering, Journal
    Series Paper No. 2409.

Griffin,  R. A.,  and  N. F.  Shimp. Leachate migration  through
    selected  clays.   Illinois  State  Geological Society,  Urbana,
    Illinois.

Chapman, H. D., and P. F. Pratt. 1961. Methods of analysis of soils,
    plants, and waters. Division of Agricultural Science. University
    of California.

Haxo, H. E.  Assessing synthetic and admixed materials for lining
    landfills. Illinois State Geologic Society, Urbana, Illinois.
                                                          -226-

-------
                                      INCINERATION OF INDUSTRIAL WASTES1

                            C. Randall Lewis,  Richard  E. Edwards, P.E., and Michael A. Santoro
                                                      3M Company
                                                      St. Paul, MIM
       One  aspect of  any  manufacturing operation  has
 always been solid waste disposal.  In the past, the method of
 disposal was usually determined exclusively  by economic
 evaluation.  Because no consideration was  given to  the
 environmental  effects  of the disposal method, industrial
 wastes were disposed of into or on the  land in sites that
 were   selected   purely  for   economic  reasons.   The
 implementation of the Federal Water Pollution Control Act
 further added to land disposal of industrial wastes because
 li.quids and colloids that were once sluiced into the nation's
 waterways  now had  to  be removed and added to the solid
 waste load.
       In  recent  years  the  environmental  concerns  for
 industrial  waste disposal  have  been  increasing with  the
 effect that land disposal of  industrial  wastes is  becoming
 much more tightly  controlled.  In the final analysis, land
 disposal is still the only sink for the irreducible components
 of industrial waste. The practice of controlled landfilling of
 industrial wastes results in landfills  that  have been rigidly
 engineered  to minimize the environmental insult to water.
 Many waste streams, however,  require  pretreatment  for
 acceptable  disposal  to  land, and   the  most direct  and
 universally  applicable  pretreatment of waste containing
 organic chemicals is incineration.
      It has always been 3M Company policy that pollution
 control regulations  will be met and sound environmental
 practices followed. Thus, it was decided that the best long
 range   solution   to   organic  waste   pretreatment   was
 incineration.  It  is   neither  economically practical  nor
 socially responsible to incinerate all wastes indiscriminately
 because without careful operation, incineration can become
 an energy intensive process. At 3M, incineration was chosen
 for 3 basic reasons:  (1) Incineration is an excellent disposal
 method for all types of solvent-contaminated wastes. This is
 a critical factor because characteristics of scrap within the
 3M  Company vary  considerably due   to  many  types  of
 manufacturing processes. (2) Pretreatment by incineration
 eliminates the potential for ground water pollution from the
 scrap.  The  potential for  ground water pollution  is an ever
 present  possibility  in   the   most  heavily industrialized
 portions of this country.  Complete oxidation  of waste
 materials is the  most reliable  method available to produce
 an   inert   residue.   (3) Anticipated  pollution   control
 regulations could be  met by incineration. As the landfilling
of hazardous wastes  becomes more  and  more restricted,
incineration would continue to provide a  solution to the
disposal problem.
       A description of  the  4 basic components  of the
 incinerator facility  at 3M Company follows:  (1) Materials
 Handling System, consisting  of a  building and equipment,
 was designed for the proper handling of scrap materials so
 that the materials can be charged to the incinerator in a
 satisfactory manner. This involves the blending and mixing
 of pumpable scrap,  and the movement of scrap materials to
 the proper feeding  areas. (2) Incineration Components are
 the primary and secondary combustion  chambers used to
 oxidize  the  waste  material.  (3) Air  Pollution  Control
 Equipment scrubs  exhaust  gases  before emission  to the
 atmosphere. (4) Water Pollution Control Equipment treats
 scrubber water before discharge to the receiving stream.
      Generally,  there   has  been  a  reluctance  to  use
 incineration for waste disposal. The main areas of concern
 have been: the methods of handling waste materials; the
 design   of  the   incinerator   facility;  the  maintenance
 associated  with  operating  such  a  facility;  and  the
 conservation of  energy.  The purpose of this paper  is to
 describe an incineration  facility that has overcome these
 concerns and has provided a safe, economical, and efficient
 method for hazardous waste disposal.

 MATERIALS HANDLING

      Materials handling is a critical aspect of the industrial
 waste disposal process from the time a waste  is generated at
 the  manufacturing plant  until  it is properly  disposed of at
 the  incinerator  facility. Many  industrial  wastes   pose
 potential  problems  if  proper techniques are not used in
 their disposal. There are 7 basic steps involved in the proper
 disposal  of industrial wastes  which require  understanding
 and cooperation  between the  personnel  at  the  waste
 generation source and  the personnel  at the  incinerator
 facility.  These  7 steps  are:  (1) chemical  identification;
 (2)  categorization;     (3) segregation;     (4) packaging;
 (5) labelling;  <6) transportation;  and  (7) handling  and
 disposal. Steps 1-6 are  carried  out by  personnel at the
 source of waste generation whereas step  7 is carried out by
 the  personnel  at  the  incinerator facility.  A  materials
 handling flow diagram is shown in Figure 1.

 Chemical Identification

     Because the personnel at the waste generation source
 have  the  greatest  knowledge of  the  major  chemical
constituents in  the  waste, the components can best be
1   Based on a paper by C. R. Lewis, R. E. Edwards, and M. A. Santoro published in Chemical Engineering: Vol. 83 (22), October 18 1976
    copyright by McGraw-Hill, New York,  NY, used with permission.  A similar paper was also presented  at the 1976 National'Waste
    Processing Conference in Boston, Massachusetts and was included in the proceedings of that Conference. The National Waste Processing
    Conferences are sponsored by the American Society of Mechanical Engineers.
                                                        -227-

-------
                                               FIGURE 1

                        FLOW DIAGRAM SHOWS MATERIALS-HANDLING SEQUENCE
                          INVOLVED IN THE DISPOSAL OF HAZARDOUS WASTES
          MANUFACTURING  PLANT    i  TRANSPORTATION
               Waste  Source
            Chemical  identification
             "Categorization
              Segregation
    Pumpable
    waste
      Packaging
     Bulk   Drummed
                  Nonpumpable
                  waste i

                     Packaging
                       Drummed
Labeling
                 for identification
                                i	i
'DOT  comp-
 liance by
  carrier
                                                               INCINERATOR
                                                                      1
                                                                  Separation by
                                                                  incinerator  operator
                                                              Pumpable       Nonpumpable
                                                             Bulk Drummed      Drummed
                                                                       Pumped from
                                                                        drum
                                                                                 Inspection
I
                                                                                     Pack-and-drum
                                                                                      feed system
identified prior to shipment. The identification of waste at
the source facilitates compliance with the U. S. Department
of Transportation (DOT) regulations, ensures the maximum
safety of all personnel involved in processing the waste, and
permits  the proper precautions to  be  taken in  order  to
protect  the  physical  integrity   of  the  incineration
equipment.

Categorization

     At the 3M Company, 3 broad categories are used to
describe waste  material: (1)dry scrap,  (2) wet scrap, and
(3) extra hazardous scrap. Dry scrap is any dry material,
such as wood, paper, and rags, which exhibits no flammable
vapor hazards.  Wet scrap is composed  of 2 subcategories,
namely, pumpable wet scrap and nonpumpable wet scrap.
Pumpable wet  scrap  is any liquid material  which can be
pumped  or poured  into  a  drum or other container.
Nonpumpable  wet  scrap  is  any  solvent-contaminated
material that cannot  be pumped or poured into a drum.
Nonpumpable wet scrap includes such items as polymerized
adhesives  or  resins,   solvent-soaked  rags,  gloves, filter
cartridges, polybags,  films, and chemical powders. Extra
hazardous  scrap  is  any  material which  presents  an
extraordinarily   hazardous   characteristic   such   as
ftammability, toxicity, extreme chemical reactivity, or is
odor generating.
                                                 Segregation

                                                      The waste material is segregated such that dry scrap,
                                                 nonpumpable wet scrap, and pumpable wet scrap are not
                                                 mixed in any single shipping container. In-plant segregation
                                                 of the various categories of waste materials is essential  to
                                                 achieve the most flexible and economical disposal system.
                                                 The dry scrap and nonpumpable wet scrap are charged  to
                                                 the kiln while the pumpable wet scrap  is charged to the
                                                 primary and secondary burners.  This usage of pumpable
                                                 wet  scrap  is required  to  maintain  proper  combustion
                                                 temperatures within the incineration system. The need for
                                                 the difficult and labor intensive process of segregating waste
                                                 materials upon  arrival at the incinerator  is eliminated if
                                                 segregation is done at the plant.

                                                 Packaging

                                                      Waste materials  are packed in  reconditioned, 17H
                                                 open-head drums and 17E closed-head drums. These drums
                                                 afford  a most  convenient container  for  waste materials
                                                 because  they  are   common   to most manufacturing
                                                 operations  and provide a relatively inexpensive container
                                                 which  complies with all  DOT requirements. A 6 mil,
                                                 anti-static drum liner is used with all nonpumpable scrap so
                                                 that the waste materials can be  mechanically removed and
                                                  the  drum  reclaimed.  Before shipping,  the drum  liner is
                                                    228-

-------
gathered  at the top, doubled over,  and securely  taped.
Drum liners are not used with pumpable materials because
the liners inhibit the pumping operation by plugging the
pumping system. The drum lids are sealed with a fiber-ring
gasket prior to shipping.

Labelling

      Attached to each  drum of  waste materials  are the
appropriate  DOT labels  and a  company  label  which
categorizes  the   waste   materials   as  pumpable   or
nonpumpable  wet scrap and indicates the health, fire, and
instability hazards associated with the waste materials. The
label  also  indicates  the major chemical  component and
whether  the   material is  chlorinated  or nonchlorinated.
From this information the heat content (in Btu's) and the
compatibility characteristics of the waste materials  can  be
deduced.
      This  labelling  procedure  allows  the  incinerator
operator to identify easily the nature of the drum contents
so that proper disposal techniques can be implemented.
Because the waste materials  have been identified  at the
source prior to shipment, there is no need for an extensive,
costly,  and  time consuming  sampling  and  analytical
program at the incinerator facility.

Transportation

      The most common  method of transporting waste
materials to the incinerator facility is  by commercial truck
lines. The drums  are loaded  one-high  and  4 drums to a
pallet. Normally, a truckload consists of 72—76 drums. The
preferred method of  shipping large quantities of pumpable
wet scrap is by bulk tanker because less labor is required to
process the waste. Shipment by rail would also be feasible if
appropriate accommodations have been provided.

Handling and Disposal

      The handling  system for  waste  materials   at the
incinerator facility are  simple and flexible.  Only  2 basic
materials handling systems are necessary: one system that
processes nonpumpable waste materials and another  system
that processes pumpable materials.
      The system for nonpumpable materials consists of a
pack and drum feeder, a double door air-lock, and a drum
conveyor. The  drums of nonpumpable waste materials are
placed on a roller-type conveyor which moves the drums in
sequence to the pack and  drum feeder mechanism. While
the drums are  on the conveyor, operating personnel remove
the drum lids and  visually inspect the contents. The drums
are then charged  one at a time  into the  kiln with the
charging rate determined by the  Btu value of the contents.
As  each  drum enters  the  air-lock,  a vise-type  device
automatically  grasps  the drum. The operator then has the
option of tipping the drum to discharge the contents  or
releasing  the  entire  drum with  contents into the kiln.
Although many drums are routinely reclaimed, some drums
are unavoidably  charged  to  the  kiln because improper
packaging of  the waste  material  prevents  discharge  by
tipping.  Because  many   3M  manufacturing   processes
generate  adhesive-type waste materials, caution must also
be taken to avoid contaminating the inside of the drum or
the exterior of the liner with adhesive material which would
prevent the discharge of the drum contents by tipping.
     The system  for pumpable  materials  consists of  a
pumping room, blend tanks, and storage tanks.  Pneumatic
diaphragm pumps are used  to transfer the pumpable wastes
from the drums into storage tanks. If the material is too
viscous to pump, the drum is tipped and allowed to drain
by gravity flow into the storage tank. Care must be taken to
avoid mixing pumpable materials  which react, solidify, or
polymerize when  mixed.  The  only solution to  such  an
occurrence  is  to remove the material manually from the
storage tank(s). This unpleasant situation occurred several
times when  the incinerator facility was started up,  but
accumulated   experience   and   knowledge    regarding
segregation of liquid wastes  has eliminated this problem.
     The pumpable wet scrap is burned through solvent
burners  in  both  the  kiln  and  secondary combustion
chamber. In  order  to achieve a uniform quality of fuel, the
pumpable material  is  mixed  in  blend tanks prior  to
incineration.  All piping is  recirculated  to prevent settling
and    mechanically   comminuted  to    destroy  any
agglomerations which would cause plugging.
     This    7-step  program  must include  a  rigorous
follow-up program to ensure that personnel at the waste
generation source  follow the procedures set forth, so that
uniformity in handling waste at the incinerator facility can
be achieved. The follow-up program should emphasize such
benefits  as:  safety  of incinerator  operating  personnel;
physical well-being of equipment; capability of compliance
with all applicable  regulations; and most efficient operation
of the  incinerator.  In general, the  more effort put forth on
steps 1—6 of the disposal  process,  the easier and safer the
actual incineration  process of step 7 becomes.

FEATURES  THAT  CONTRIBUTE  TO  SUCCESSFUL
OPERATION

     The purpose  of incineration with  respect to chemical
waste  disposal  is  to produce  stable  oxides that can  be
returned to  the environment without causing detrimental
effects. In recent years one  more dimension has been added
to incineration, the air pollution aspect. It is not enough to
run an incinerator  that performs well only with respect to
oxidation; air  emission standards must  also be  considered.
Figure 2  is  a diagram  of  3M Company's  air pollution
control system.

Combustion  Features

     The key to the success of the incinerator facility  is
the use  of  a  rotary kiln for the primary combustion
chamber. The kiln measures 11m (35 feet)  in  length and
4 m (13 feet) in diameter; the inside consists of steel with a
0.3 m (11 inches) refractory lining of super duty firebrick.
This  refractory  provides   a  desirable  combination  of
economy, chemical  resistance, and mechanical  durability.
Material  is fed  into the  kiln  in  quantities of 210 liters
                                                      -229-

-------
                                                   FIGURE 2

                             INCINERATOR FACILITY FEATURES A ROTARY KILN.
                      AND A SECONDARY COMBUSTION CHAMBER FOR PARTICULATES
            Secondary air
       Jurner
        tanks
            Liquid
           pumpable
          Drummed
        nonpumpable
                                                                           Water
                                        Secondary
                                        combustiqn
                                                                       Quench
                                                                       chamber
!1lenum(_>\        Hater
air    *  V  J
                                             Ash    V/ater
                                            drums
                                                                                            x.^  Induced-
                                                                                                 draft fan
                                                                                            Sieve tower
                                                               ash
(55 gallons).   The  charges  weigh  between  70— 230 kg
(150-500 Ibs) and  average  80kg (180 Ibs).  A  most
important aspect  is  that  the rotary  kiln continuously
exposes new surfaces for oxidation. The tumbling action of
a rotary kiln  incinerator prevents sintering of the waste
materials; thus, complete oxidation of the charged materials
results.
      The rotary kiln  provides continuous removal of ash.
This is  important when incinerating solvent-contaminated
inorganic  material, especially if the material is contained in
steel drums. Incineration of the organic constituents occurs
in the kiln and only the inert inorganics remain. Continuous
removal of this ash prevents shutdowns for cleaning and
ensures  that  this  material does  not  interfere  with the
oxidation process. Because  3M  uses  standard drums as
waste containers, an effort  is made to reclaim the drums
through  use  of the  pack  and  drum feeder previously
described. However,  as also previously mentioned, some
material polymerizes and some is simply too adhesive or
viscous  to dump from the  drum. When this occurs the
container  must also be charged to the incinerator and the
rotary kiln ensures continuous discharge of these burned
out containers. These containers are then separated  from
the other ash residue and are reclaimed as metal scrap.
     By controlling the rotational speed of the kiln, the
rotary kiln also provides a method of varying retention time
of the charge  to ensure that containers are completely
                                                      burned out and that loose charges are oxidized completely
                                                      to   inert ash.  The retention  time  can  be  adjusted
                                                      immediately depending upon the nature of the material fed.
                                                           The rotation of the kiln also reduces the requirement
                                                      for  refractory repairs  due to  flame  impingement  and
                                                      slagging.  Because  the  refractory  surface is  continually
                                                      changing  spatially,  there is no  prolonged  direct flame
                                                      impingement  on  one  specific   portion  of  refractory.
                                                      Naturally, prolonged flame impingement  would cause the
                                                      refractory to  deteriorate prematurely.  The formation of
                                                      slag is spread  over a larger area  and is  easily  removed by
                                                      raising the kiln temperature to the melting point of the slag.
                                                      Caution should be exercised not to exceed the softening
                                                      point of the refractory.
                                                           Erosion  and thermal spading of the refractory are the
                                                      only unfavorable considerations associated with rotary kiln
                                                      incineration. The erosion is a result of the abrasion caused
                                                      by  waste material tumbling inside the kiln. The thermal
                                                      spading occurs at the discharge end of the kiln and is caused
                                                      by  the thermal shock created by the inrush of air at the end
                                                      plate seal. This spalling requires the periodic replacement of
                                                      a small section of castable. Neither of these 2 unfavorable
                                                      considerations results in  excessive maintenance.
                                                           The concept of drum feeding is important in that it
                                                      provides a relatively consistent feed.  Materials charged to
                                                      the  incinerator have  a large variation in heat of combustion
                                                      and in  volatility. After a charge is fed, the only method
                                                      230-

-------
available  for  controlling the temperature  increase of the
system is to increase the air flow. The heat and mass release
are  not controllable after the batch has been charged. By
staggering drums of material with low heat of combustion
and low  volatility  with those of high  heat of combustion
and high  volatility, a  much more  consistent feed can be
achieved. Thus, the kiln temperature and the retention time
of the combustion gases can  be  kept within acceptable
limits.
     A  secondary combustion chamber  is  provided to
allow for the oxidation of combustible paniculate matter
suspended  in the  gas stream. This  chamber, which is also
lined  with refractory brick, allows  a one-second  retention
period of the gases at 870-890°C (1600-1800°F). This is
sufficient to allow complete oxidation  of combustible
particles one micron in size.
     Successful  incineration  at   this  facility   is   made
possible by 4 basic operating features. These are  described
as follows: (1)  A relatively consistent temperature required
for proper oxidation.  As mentioned above, the rate of feed
can be varied depending on the heat of combustion which
allows for some  temperature control. In  addition, the
combustion  of the   pumpable   scrap is  automatically
adjusted  by direct control of the burners to compensate for
temperature changes.  The temperature  is sensed at the exit
from the  kiln and  at the exit from  the secondary chamber.
(2)  Complete mixing  of  combustion  gases. The physical
layout of  the  secondary  chamber  in relation to the kiln
allows  for  an increase  in  turbulence   of the  gases.
(3) Adequate  retention   to  permit the  kinetics of  the
combustion reaction to occur.  The kiln speed is adjustable
to vary the retention  of the nonpumpable material within
the kiln. The retention time of the gas stream through the
incinerator and the excess air are varied by controlling the
air  flow  into the system.  Air flow through the kiln and the
secondary chamber is induced by  the  fan downstream of
the  wet  scrubber air pollution  control equipment.  A
variable throat in the Venturi scrubber and louvers in the air
 intake duct to the head  end of the kiln  control air flow.
 The variable throat and  louvers are  controlled  from the
 operator's control  room. It is important to  point out that
the induced draft fan does have the capability to make large
 changes  in air  flow. This  is provided by  the specific inlet
 design that permits variation of flow through the fan. If this
 was not done, flow separation from the fan blades would
 cause the  fan  to vibrate; this is known as a "starved fan".
 As shown later, such  a condition  is of concern.  (4) Proper
 oxygen supply to  maximize the reaction without excessive
 cooling   of  the   combustion products.  This  is  also
 accomplished by the variable air flow control.
      The present system  has  successfully fulfilled the
 requirements  of   all  applicable  testing.  Recently,  in  a
 cooperative  test  with the  U.S.  EPA, a sludge from  a
 polymer manufacturing operation was  incinerated as a test.
 The exhaust stream  was  sampled  between the  secondary
 combustion  chamber  and the air pollution control system
 for  monomer  content.  Although  testing  is  not  yet
 complete, the  preliminary  indications  are that  at  this
 station,  ahead of  the air pollution control equipment, the
 concentration  was approximately   2 orders of  magnitude
 less than the anticipated allowable concentration.
Air Pollution Control

     Satisfactory  combustion in  the  primary  and  the
secondary chambers is the key to air pollution control, but
strict  standards  on   particulate   emissions  do  require
additional controls. This 3M incinerator is restricted to a
particulate emission standard of 0.23 gm per standard cubic
meter (0.1 gr/scf) of dry exhaust gas. This figure is adjusted
to a 12 percent carbon dioxide  concentration as required
by the regulation. The air pollution control system is  of the
water scrubber type and consists of 5 major components: a
quench chamber,  a Venturi scrubber, mist  separator,  an
induced draft fan, and a 60 m (200 ft.) stack.
     The quench chamber is a water spray chamber  which
acts  to  cool  the   gas   stream  from  870 —980 C
(1600-1800°F) to about 80°C (180°F). By quenching the
exhaust gases,  refractory-type lining is not required  in the
remaining chambers.  The quench  tank, however, is lined
with an  acid-resistant brick and mortar. Because some of
the    materials    incinerated     contain    halogenated
hydrocarbons,  halogen acids such as hydrochloric acid  are
present in the gas stream.  In addition  to the  quenching
process,  the quench  chamber does effect the removal of
some particulates.
      The Venturi scrubber was specified for the removal of
particles as small  as  0.1 micron. Because a high efficiency
Venturi scrubber was needed, a water spray header with
atomizing nozzles was added  to the Venturi  throat.  A
Venturi with a 0.76 m (30 in ) water-gauge pressure drop is
adequate for removal of  such small particles. The present
system complies  with the  air emission  regulations,  but
Venturi  scrubbers  must  be  carefully  designed for each
specific application.
      The mist separator removes the fine water droplets
generated in the Venturi  and entrained  in the gas stream.
The chamber consists of the counter-current flow of water
and air with the water cascading over plastic plates. Because
the gas stream provides the necessary mixing as it passes up
through the plates, a  most important aspect of this chamber
 is the  plate area. The initial mist separator design contained
more plate  area than needed and some of the porous plates
had to  be  replaced  with solid sections to  prohibit short
circuiting and channelling of the gas stream.
      An induced draft fan is required for any large Venturi
 scrubber because of the energy drop across the scrubber. In
 this system the Venturi throat is the principal  control  on the
 air  flow  through the combustion  train and, therefore, the
 induced  draft fan must be capable  of handling  varying
 amounts of gas. The fan  was purchased  with  an  inlet
 damper  that permitted compensation for variations in the
 gas flow. At  first the inlet  damper was  improperly used
 because of  insufficient operating data.  In addition, the fan
 collected wet  particulate that passed  through the Venturi.
 The combination of the  particulate  buildup  and  the
 incorrect inlet-damper setting caused the fan to run out of
 balance most  of the time.  When the  fan  was purchased it
 had a clearance of 0.076 mm (0.003 in ) between the shaft
 and the wheel hub. The imbalance caused considerable wear
 with the result that the hub of the wheel "belled" out to
 0.25 mm (0.01 in ).
                                                        -231 -

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      The  fan  has  been  modified  by  providing  an
interference fit between the hub and the shaft. The fan has
also been provided with  a water spray system to reduce
paniculate buildup on the fan. The inlet damper has been
adjusted to prevent "starving" the fan at the air flow rates
most frequently encountered. It is recommended that a fan
for such an application be constructed with an interference
fit  between the shaft and hub, that it be equipped with
water  sprays,  and   that  the  inlet  box  adjustment
automatically follow the flow control adjustment.
      Two fan wheels were purchased for this facility. One
was made of  a Hastelloy formulation  and the other was
rubber-covered steel.  The Hastelloy  fan is normally used,
and  the rubber-covered  wheel  serves  as  a  spare. The
rubber-covered wheel has been used on a trial  basis, and one
serious defect  has been  noted. Several rubber pads were
provided for balancing and  under the  stress of operation
these rubber pads delaminated.
      The scrubber water from  the  air pollution control
equipment requires acid neutralization, chemical treatment,
and sedimentation before discharge to the receiving stream.
 For neutralization, ammonia was originally selected because
of  low  cost and few handling  and storage problems. A
sparge pipe was placed in the sewer just ahead of the lift
station.  Because the sewer line did not flow full, much of
the ammonia simply bubbled through the water and  was
sluiced out of the sewer. As a result, the cast iron sewage
 pumps  and force main  were  destroyed  by  the  acidic
scrubber water within a  year of operation. To correct the
situation, neutralization  was improved by blocking  the
sewer with a weir so that the sewer pipe was completely
 filled, thereby allowing more contact between the ammonia
 and  the scrubber water.  In addition,  the pumps were
 replaced with horizontal process pumps designed for service
 in  halogen acids at a pH of 3 or greater. The force main  was
 replaced with  fiberglass-reinforced   plastic  pipe.   This
 modified system has been operating satisfactorily.

 MAINTENANCE

 Primary Combustion Chamber

       The 2 main concerns  regarding maintenance of  this
chamber are wear and replacement of the refractory,  and
 slagging of  inorganic salts. Because  of the  abrasiveness of
 the steel drums rotating  within  the  kiln and the high  and
 and fluctuating temperatures, the super duty firebrick,  and
 insulating brick must be replaced about once every 2  years.
 This is normally a 250 man-hour job. The insulating brick
 used at  first was made of compressed, diatomaceous  earth.
 Subsequently,  it  has been found  that other  refractory
 bricks  of  similar heat  conductive  properties  function
comparably. One  important concern  is that the hardness of
the  2  layers  of  bricks  be somewhat  the  same so that
 abrasive wear between them is at a minimum. Slagging of
 inorganic salts normally occurs where the heat in the  kiln is
 the highest, i.e., the  area to which the flame tip reaches.
 The  slag layer  can achieve a 70 to 230 mm  (3 to  9 in.)
 thickness. As  expected,  this  slag prohibits the  travel of
burned ash through  the  kiln.  The slag also acts to reduce
the life of the brick  by penetrating it, thereby reducing its
density and refractory properties. Normally the slag ring in
the kiln is maintained at about 50 to 70mm  (2 to 3 in.)
and is controlled by slowly raising the temperature to the
required melting point.

Secondary Combustion Chamber

      The major recurring problem with this  chamber  is
accumulation of ash. Because  there is not a continuous ash
removal system,  the ash must be cleaned out physically.
Naturally,  as ash volumes build up, the efficiency of the
secondary  combustion chamber decreases,  but noticeable
effects are not  evident  until  after about 2—3 months of
operation.  This  period varies, of course, depending on the
ash content of the pumpable wet scrap used as fuel.
      Generally,  throughout  the  primary and  secondary
chambers and connecting sections, particles tend to settle
out on all horizontal surfaces. All areas must be cleaned
periodically so that  air flows and detention times are not
affected.

Air Pollution Control Equipment

      The  major recurring maintenance problem related to
the air pollution control equipment is corrosion.  Because
the scrap  materials  incinerated contain some  chlorinated
hydrocarbons, the gas stream contains hydrochloric acid.
The concentrations  of acid vary, naturally, as a function of
the levels of chlorinated  hydrocarbons within the pumpable
and nonpumpable scrap.  In  addition  to the acid content
itself, the corrosiveness  of  the scrubber water becomes
greater because  of  dealkalinization. Corrosion rates are
increased even further by the effects of erosion created by
the particulate in the  air stream and the water  stream and,
in some areas, the velocity of the water flow itself. A major
effort  was placed  on  developing  coating systems  and
improvements in neutralization to reduce corrosion. This
effort is described in the  following sections.

Quench Elbows and  Quench Chambers

      These chambers were at first lined with acid-resistant
brick and mortar. Because of the corrosion from the water
and air flows,  much of the  mortar was dissolved  to the
point that the brick fell  out of the chamber. In addition, at
times the air stream also took on alkaline properties which
the mortar could not withstand. Two things were done to
 resolve these  problems. First,  the brick was replaced using a
furan-resin cement  as the mortar. This mortar was chosen
 particularly because of its ability  to resist attack or strong
 acid  and  mild  alkaline  conditions.  Secondly, the entire
 interior  surface  of  the chamber  was  coated   with  a
 one-eighth inch  layer of the  cement.  This provided better
 protection  and  made   repairs  significantly  less time
 consuming and  less costly.  The cement bonds extremely
 well to masonry surfaces as well as to itself.
                                                        -232

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     The ceiling  of the quench chamber has a rubberized
coating. This  coating  is  sensitive to  temperature, and
degradation  starts at approximately 80°C  (180°F).  The
location and efficiency of the water spray nozzles is critical
to preventing gas  channelling which results in hot spots and
deterioration of the lining.

Venturi Chamber

     The  Venturj chamber  was   installed  with  a butyl
rubber  lining.  This  lining  was   chosen  for  2  basic
purposes:  (1)to  protect  the  steel structure  from  acid
attack; and (2) to act as a resilient counter-force to the high
velocities present within the Venturi. Unfortunately, the
rubber fulfilled neither purpose completely. The acid in the
air stream  tends  to  penetrate  through  the  3.2 mm
(one-eighth  inch)  thick rubber  coating  along with water
vapor and condenses between  the  steel  and rubber layer,
causing corrosion of the steel and blistering  of the rubber.
Corrosion  occurs only to a small  degree at first until the
acid has  been   completely  neutralized.  As the  blister
enlarges,  the porosity of the rubber  increases, and more
acid penetrates to the  steel.  In the coated areas  of the
Venturi that are flushed with  water and where the coated
walls do  not experience high  velocities  of gas, the rubber
lining seems to remain  intact.  Without  a  water protective
layer,  however,  the  lining is unsatisfactory.  First, an
attempt   was   made  to  repair  the   rubber   lining.
Unfortunately, field application and repair are quite difficult
because new rubber does not bond well to cured rubber.
Subsequently, a  100 percent solid  resin  product was used.
The basic resin compound is acid resistant and bonds well
to most  common surfaces, such  as metal, masonry, and
rubber. The  product used is  applied  like plaster, i.e.,
troweled  in  3.2 mm (one-eighth  inch)  thickness.  The
thickness increases the corrosion protection.

Primary Exhaust  Stack

      Basically,  all the acid  has been removed by the air
pollution  control system  before  it reaches the  fan and
stack.  One would therefore assume that the corrosion levels
 within the  60 m (200 ft ) steel exhaust stack would  be
quite small. This assumption, however, is incorrect. The gas
stream at the point of the stack inlet is for the most part
saturated  or supersaturated with water vapor. As the gases
 rise through the stack, condensation occurs as temperature
 decreases.  The condensate returns to the  bottom of the
stack and is vaporized again by the warmer temperature of
 the incoming gas stream.  Essentially, the stack acts like a
 reflux-condenser  which tends  to concentrate the  small
 quantity of acid present. Samples  of water collected from
 the stack water drain contain acid levels  so high that the pH
 measurement  registers zero. Because  of this highly acidic
 condition, the steel stack  requires  protection. The original
 coating was an epoxy resin which was applied in a thickness
 of 5-10 mils  (0.2-0.4 in ). The particular coating selected
 was not adequate for protection because  of the extremely
 high  levels  of acid.  Blistering  and cracking of the coating
 occurred, especially at the weld seams and at the opposite
end  of  the  stack  discharge where erosion contributed  to
deterioration.   Attempts  to   patch   the  coating  were
somewhat fruitless because proper surface preparation was
difficult. Attempts to taper or feather the existing coated
areas had little benefit. Also the coating, when cured, did
not  bond well  to  itself, and thus random patchwork only
postponed the inevitable task of complete refinishing.
      The coating  system  studied, tested, and used for the
complete stack recoating  was a 5-part epoxy resin series.
Two separate  resins were used, and   to   the present time
have extended the  coating life by about 4 fold.
      In studying and finding a solution to this problem, 2
major  facts   became  apparent: the  importance  of   a
multi-numbered coating  system  and  the importance of a
superior surface  preparation.   The latter  item  somewhat
speaks for itself. The former item, however,  requires some
explanation. A multi-numbered and  multi-colored system
allows for nearly complete assurance that the steel shell is
protected with at least 4 coats and, hopefully, 5 coats. With
a single  coating in a stack with a 310 sq. m. (3340 sq. ft.)
surface area, the chance of inadequate protection is great.
In  addition, the  5-part  system provides for "safety  in
thickness".  This also contributes to  extending the life of
the coating.

CONCLUSION

      Although the corrosion  potential  of the air stream
and scrubber  waste water is high, the proper coatings and
their application  have been successful in minimizing the
effect.  Within the  air pollution control water  scrubbing
systems,  coatings  are  now   being  applied to properly
prepared surfaces  and in thicknesses necessary to overcome
erosion, deterioration, and the  probability  of inadequate
covering of the surface to be protected.

COSTS OF MAINTENANCE REPAIR

      Although the  major  maintenance repair items have
 been   discussed   previously,   there  have   been  other
maintenance expenses for the normal  repair items. Bearings,
pumps,  hydraulic systems,  etc., all require various repairs,
 but these are for  the most  part not unique to incineration
systems.
      Generally,  maintenance  costs  have averaged about
 5—6 percent of the capital cost on an annual  basis. In terms
 of unit cost per disposal unit this figure averages about $14
 per ton. Generally, maintenance costs  are  significant  yet
 comparable to other waste disposal systems.

ENERGY CONSIDERATIONS

      The  incinerator  expends energy  to  maintain  the
temperatures  necessary for proper combustion.  Presently,
about 75 percent  of a drum of liquid waste is needed  for
the incineration of one drum  of nonpumpable scrap. If  the
volume  of pumpable scrap for one week  is lower than
 normal, auxiliary fuel is required to continue operation.
 Each manufacturing operation will be different regarding
the amount of auxiliary fuel  needed  to supplement  the
                                                        -233-

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quantities  of liquid  waste. As presently operated, the
incinerator   requires   a  minimum  amount  of  energy,
regardless of the form of that energy.
      In  addition  to the  requirement  for auxiliary fuel,
another energy consideration that has been studied is the
possibility of utilizing the heat generated in the incinerator
to produce steam. 3M employed a consultant to conduct a
feasibility study of waste heat recovery from the facility. A
pilot-size  boiler  was installed at the secondary combustion
chamber and a small fan induced a flow of the 870— 980°C
(1600—1800°F) gas stream into a fire tube boiler. Steam
was  produced  from  this  unit, and operating data were
collected  for  an assessment of  the feasibility of steam
generation.
      Basically, the project is not economically attractive
because of  a  requirement  for a substantial distribution
system. Two  other  major  problems are corrosion and
particulate buildup in the boiler tubes. In addition, the run
time  factor indicates that  a  back-up  fuel  source or  a
complete boiler would be needed to match the confidence
levels  with  production  requirements.   For  this  system,
therefore, waste heat recovery  is probably not feasible at
the present time.
                                                       -234-

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                  DESIGN AND PERFORMANCE OF A CHEMICAL WASTE DISPOSAL FACILITY
                                         FOR HAZARDOUS CHEMICALS

                                   A. J. Shaw, P. Eng., and B. H. Level ton,  P. Eng.
                                          B. H. Levelton & Associates, Ltd.
                                                 Vancouver, B. C.
PURPOSE

     Early in 1970,  the President  of the University  of
British  Columbia  (UBC), Dr. Walter  Gage, established a
committee to determine improved ways of disposing  of
dangerous  chemicals.  Working together,  the  President's
committee, the Department  of Physical Plant, and B.  H.
Levelton  &  Associates  Ltd.,   Consulting  Engineers,
developed a process of collection, incineration and chemical
degradation  which was approved  by the  UBC Board  of
Governors in May  1971.

BASIS FOR HAZARDOUS WASTE MANAGEMENT

     The  collection,  transportation  and  disposal   of
hazardous  and toxic  chemicals from scientific,  technical
and   educational   institutions  poses   problems  not
encountered  in handling municipal and  industrial wastes.
Quantities of materials are relatively  small, and there are
extremely  large numbers of components,  many with a
potentially high degree of hazard (sometimes  unknown).
These factors create  a complex  handling  problem. The
philosophy which  guided the  development of the chemical
waste disposal facility (CWDF) at UBC can be summarized
as follows: (1) One cannot transfer from the originator to a
contractor  the  responsibility  for   proper disposal   of
chemical waste. (2) Preliminary detoxification, segregation
and  description  of the  waste rests  with  the  producer.
(3) The  producer  of  the waste  has  a  responsibility for
assisting in the planned  disposal process.  (4) The facility
should  provide "a place" for the handling and  disposal of
hazardous   materials   in  a   planned  manner.   (5) The
facility: (a) Must   be  provided   with  equipment  and
technology for disposing  of all normal laboratory wastes in
a pollution-free manner. Radioactive material would not be
handled   (already  under  control),   (b) Must   provide
laboratory/office  space  for  operating  personnel,  i.e., a
communications   and  control  center,  (c) Must  be  so
designed that it can  be modified to  incorporate improved
technology or increased demands,  (d) Would be associated
with a  pathological-waste disposal facility existing on a
1.03 acre (394 ft  x 114 ft) site on the south campus about
2 miles  from the  center  of the UBC complex, (e) Should
serve the  scientific community on campus, such as B. C.
Research, Federal  Government laboratories, UBC, and sister
universities, (f) Should be a well-designed  plant which could
be kept clean and could be viewed as a  demonstration
facility  as well  as  an  important part  of the Physical
Plant of UBC.
THE PROCESS

      Hazardous waste management in scientific, technical
and  educational   institutions  involves  many  hazardous
substances  that are widely dispersed and handled in small
amounts. The small amounts and wide dispersion of these
substances  is  an  added  hazard in  itself.  Frequently the
hazardous nature of many chemicals  is not well known. It is
necessary/  therefore,  to  consider all  phases  of the waste
handling  process,  namely   production,  merchandizing,
utilization, collection, transportation and disposal.

Production and Merchandizing

      There is a  growing  trend  requiring producers  and
sellers to state on labels what hazards are involved and what
methods should be used for disposal.

Utilization

      The   user   has   a   responsibility  to  ensure
that:  hazardous materials are clearly labelled as to hazard;
the hazardous nature is identified  and controlled; and a
follow-up  procedure  regarding the use and disposal of
hazardous materials is provided.

Collection and Identification of Wastes

      The   National   Fire   Protection   Association  has
developed  a color-coded label identifying  the degree of
hazard  associated  with  different  wastes.  The  National
Research Council  of  Canada  has developed a system for
identifying wastes according to type of hazard (fire, health,
reactivity,   environment) and to  severity  (inert=green,
slight=yellow, high=orange,  and severe=red).  For  chemical
wastes which are predominantly solvents, UBC distinguishes
between halogenated  or  nonhalogenated solvent mixtures.

Transportation

      Individual laboratories are responsible for bringing
their  wastes to a  central collection point.  Standardized
5-gallon containers are used. A special truck which was
designed for ease of loading and unloading chemical waste
containers  is  used to transport  collected  wastes to the
CWDF. There are about 36 collection points at UBC. The
truck makes 4 rounds every day,  collecting pathological
wastes in  the morning, animal bedding, etc. at noon, and
chemical wastes  in  the afternoon.  About  400  chemical
waste containers are presently in service at UBC.
                                                      -235

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 Disposal Facility
 Tank Farm:
      The process developed for chemical waste disposal at
 UBC was  designed to use  disposal procedures  given in
 "Laboratory Waste Disposal Manual,"  published by the
 Manufacturing Chemists Association (MCA), Washington,
 D.C. The CWDF at UBC was designed as "a place" where
 these procedures could be applied.  The MCA manual lists
 48 classes  of organic and  inorganic chemicals. These were
 divided into 5 groups:

     1.   Readily Combustible (13 classes of chemicals)
         Should be dissolved in a solvent and incinerated.
         Hydrocarbons,  amines,  organic acids,  etc., are
         examples of such compounds.

     2.   Difficult  and  Hazardous  but  Combustible
         (9 classes of chemicals)
         Should  be  absorbed   in   solids  and  burned.
         Peroxides, nitro compounds, unknowns,  etc., are
         examples of such compounds.

     3.   Incombustible   but  Chemically   Degradable
         (12 classes of chemicals)
         Should  react  oxidizing  agents  with   reducing
         agents, etc.  Acids,  bases,  acid halides, reactive
         metals, etc., are examples of such compounds.

     4.   Materials for Reuse (9 classes of chemicals)
         Should   be   accumulated  for  isolation  or
         purification. Examples  of  such  chemicals include
         precious metals, mercury, etc.

     5.   Highly Toxic Materials (3+ classes of chemicals)
         Should be segregated for  disposal in a chemical
         waste  landfill. Examples of such chemicals include
         arsenic, beryllium, etc.

      The process flow sheet of the CWDF  is shown in
 Figure 1. The process equipment layout occupies 0.49 acres
 (186ft  x  114ft) and is  shown in Figure 2. The CWDF
consists  of a laboratory/communication center adjoining
the  existing  incinerator  for pathological wastes plus 6
treatment units on  individual concrete pads. All  rainwater,
spills and residues from waste treatment run to  a central
sump and waste water treatment unit before passing to the
sanitary  sewer. Individual treatment units are described
briefly as follows:

Chemical Storage:

      Two  small buildings  (at present)  are  provided for
holding  chemicals  for  planned  disposal.  The  chemicals
received  for  disposal   can  be   segregated   into  5
categories:  flammable, reactive, corrosive, explosive, and
toxic. The rear walls of each building are designed to blow
out easily in case of explosion.
      Four 360 gallon (US) tanks allow waste liquids to be
 segregated into halogenated, nonhalogenated, aqueous, and
 oily (emulsion) mixtures.  A  360 gallon (US) tank  allows
 preparation of blends containing no more than 25 percent
 water, 2 percent metal oxides, and limited amounts (about
 25 percent) of halogenated hydrocarbons.

 Sub-X™ Incinerator for Group A Wastes:

      Sub-X™  incinerator for Group A wastes  has the
 following   characteristics: (1) Fixed  heat   release   of
 3 million Btu/hr.  (2) Capacity of 250 Ib /hr  of liquid at
 11,000 Btu/lb.  (3) Supplementary natural gas required to
 maintain  temperature. (4) Operating  temperature  about
 2,400°F (1,300°C). (5) Quench water (about 180  gal/min
 (US)) to cool combustion gases and scrub out water soluble
 acid components (alkali is added to the quench water spray
 zone). (6) Venturi  scrubber added to  Sub-X package with
 adjustable orifice,  rated at 97 percent efficiency  for  0.5
 micron particles when operating at 40-inch  pressure drop.

 Pit Incinerator for Group B Wastes:

      Pit  incinerator for Group B wastes  has the following
 characteristics: (1) Incinerates small  amounts at a time at
 controlled rate. (2) Designed for heat release of 2.4 million
 Btu/hr. (3) Operating temperature about 1,700°F (910°C)
 radiating to the sky. (4) Based on 50 Ib of waste at 10,000
 Btu/lb incinerated in  10 minutes.

 Chemical Degradation of Group C Wastes:

      Chemical degradation of  Group C wastes involves two
 reaction  vessels which have a capacity  of 120 gallons (US)
 and can be agitated. The vessels are used to react hazardous
 materials  in small volumes under controlled conditions (i.e.,
 dissolve sodium in alcohol; then hydrolyze alcoholate).

 Waste-Water Treatment:

     Waste-water treatment consists of passing the wastes
through a simple equalization-settling tank. All water (rain,
spills, neutralized quench water, residues from degradation
or incineration) receives this treatment.

 Storage of Reusable and Toxic Group D and  E Wastes:

     Storage of reusable and toxic  Group D and E wastes
involves  a small volume of wastes.  Because no chemical
landfill  is provided at UBC,  these wastes  accumulate  in
drums  which are shipped to a chemical landfill. Gases from
leaking gas cylinders (enclosed in plastic bags) may  be fed
to the  inlet  of the  combustion  air  fan   of the  Sub-X
 Incinerator.
     A close-up and a schematic of the Sub-X Incinerator
and Venturi  scrubber  are  shown   in  Figures 3  and  4,
respectively. The pit incinerator is shown in Figure 5.
                                                      -236-

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                                              FIGURE 2

                        OVERVIEW OF CHEMICAL WASTE DISPOSAL FACILITY
Showing  from left to right. Laboratory and Pathological Incinerator  (background). Chemical Degradation Unit,
Combustible-Liquid Tank  Farm,  Waste  Chemical Storage, Sub-X  Incinerator and Scrubber, Pit Incinerator  and
Waste-Water Treatment Unit
                                               -238-

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                  FIGURES

SUB-X INCINERATOR AND VENTURI SCRUBBER
Used for the disposal of combustible hazardous liquids
and solutes.
                FIGURE 5

           PIT INCINERATOR
Used for disposal of difficult or unknown liquids and
sludges.
      Liquid Waste -
      Natural Gas Fuel
     Combustion Air
     Water
     Sprays
     Neutralizer
     Gas Bubbles
                                             FIGURE 4

                                       SCHEMATIC DIAGRAM
                           SUB-X INCINERATOR AND VENTURI SCRUBBER
                                 Venturi
                                   Scrubber
                                                                                      To Drains
                                               -239-

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PERFORMANCE

     The CWDF has operated satisfactorily  since it  was
commissioned  in  March 1973. Some comments  regarding
individual units of the facility will support this experience.

Chemical Storage

     No increase in storage capacity has been necessary.

Tank Farm

     From January 1 to December 1, 1975, 5,400 gallons
(US) of  liquid waste were received and  incinerated. To
dispose of this quantity of waste, the CWDF  operates an
average of 6 hours  per day, one day per  week during an
8-month  academic  year.  Sometimes the  facility  is  used
2 days per week.
     The insides of the  mild steel  storage  tanks  are
corroding (as expected) requiring excessive attention to the
filter in the feed line and causing some variation in feed rate
to the Sub-X  Incinerator.  Expensive stainless steel  gear
pumps which supply liquid waste to the incinerator nozzle
at 100 psi have proved costly to maintain. An inexpensive
cast iron gear pump flushed out with oil after use has been
giving about a year's good service.

Sub-X Incinerator

     The incinerator normally requires one hour  to  heat
up, operates for 6 hours of incineration and requires 1 hour
to cool  down. Temperature in the combustion  zone was
measured  at  about  2,500°F  (1,360°C)  using  a
platinum-rhodium-platinum  thermocouple in  a ceramic
thermowell. It has been possible to blend liquid waste that
will sustain combustion. Feed rates average 30 gallons (US)
per hour (180 gallons per day).
     Composition of one typical combustible liquid waste
included  the following:  residue on evaporation, 5.8  percent
(85 percent combustible); nonfilterable residue,1.3 percent;
and water,42.0 percent. Typical emissions from the Sub-X
Incinerator   are:  particulate   matter   —   0.004  to
0.015gr./std.  cf. (9.2 to 34.4mg/cu   m ); and halogen
acids - 1.9 to 4.1 ppm v/v (2.9 to 6.3 mg /cu m )
     No  service to the refractory has been  required in
4 years.  However,  the  aluminum alloy  wheel  on  the
induced-draft pressure fan on the Venturi scrubber corroded
to the point where it flew apart  in December 1976 after
nearly 4 years' service.

Pit Incinerator

     The Pit  Incinerator  is used  about twice a week and
sometimes more often during the clean up of chemicals at
the end of a semester. Whole 5-gallon cans are placed in the
incinerator.  The seams or the cans split, jets of liquid are
absorbed into vermiculite and burned.
     Typical  materials that have  been sent to  the pit
incinerator include the following:
   •  Whole cans of ether (all kinds);
   •  Bulged containers of doubtful contents;
   •  Peroxides;
   •  Glass bottles that cannot be opened;
   •  Sludge from liquid waste collection containers;
   •  Explosives from student experiments;
   •  Unknowns from the police  (bomb-like parcels, etc.)

     The refractory has been changed twice in 4 years.

Chemical Degradation

     Sludges from the chemical degradation are generally
inert and  go  to the  incinerator that is ordinarily used for
pathological specimens.
     The heresite lining became chipped over the  years and
the tanks  leaked.  Stainless steel tanks have been installed as
replacements.

Waste-Water Treatment

     No problems and negligible sludge.

SPECIAL TEST:  DISPOSAL  OF PESTICIDE IN SUB-X
INCINERATOR

      From July  to  November 1975,  detailed tests were
conducted on the destruction of Methyl Trithion  (dimethyl
chlorophenyl thiomethyl phosphorodithioate) in the  Sub-X
Incinerator. This work was  carried out  under the direction
of Dr. V. C.  Runeckles, Ph.D., Professor  and  Chairman,
Department  of  Plant  Science,  UBC.  The   following
information  (personal communication)  is  taken from  a
progress report for January 1976 (preliminary results) and
reported with the permission of Dr. Runeckles.
     Numerous  45-gallon  (Imperial)  drums of Methyl
Trithion (MT) were available for disposal. The formulation
contained  approximately  1.71+0.02 Ib. MT per  gallon
Imperial.  Two methods of incineration were used: The
formulation  was  incinerated  undiluted   and diluted
50 percent with  diesel  oil.  Undiluted and 50 percent
dilutions were incinerated at 25 gallons  (Imperial) per hour.
     Effluent scrubbing water  was tested as follows: for
MT  by gas  chromatography  (FPD) — lowest  detectable
response,  0.5 ppb; for pH, specific conductance, sulfate,
sulfite,  sulfide, phosphate,  chloride; and for toxicity  by
rainbow trout and mosquito larvae bioassays, respectively.
Gaseous emissions from the  incinerator stack were collected
in acetone and  hexane,  respectively,  and assayed  by
combined  gas  chromatography   (FID)  and   mass
spectrometry.   MT  could  not   be  detected   by  gas
chromatography  in  scrubbing  water  or stack  emissions
during incineration of 100 percent MT and  50 percent MT
formulations.  Water  from incinerating  50 percent MT did
not exhibit any detectable acute toxicity by rainbow trout
bioassay or mosquito larvae bioassay. The material balance
with  respect  to   sulfur   and   phosphorus   was low
(60—80 percent) which is unexplained so far.
                                                      -240-

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COSTS

     The capital cost of the CWDF, excluding cost of the
land, in  1972 was about $150,000. The operating costs
calculated for October 1975 are itemized as follows:

                                    Cost/Hour

     Gas, 1000 cu  ft/hr              $ 0.0974
        $Q0974/therm

     Power, 32 hp (23.87 kw)            0.238
        $0.01 /kwh

     Chemicals                          3.295
        Na2C03 20 Ib /hr
        NaOH 15lb/hr

     City Water                         1.79
        155 Imperial gal /min
        9,300 Imperial gal /hr
        $0.12/100cu  ft

     Operator                          7.29
                                     $13.588

        Total cost per Imperial gal   $0.543
        Total cost per US gal         0.45

     Overhead  and  amortization are not  included. No
water reuse is assumed.

ACKNOWLEDGMENT

     We would  like to thank  the  University  of British
Columbia for permission to present this paper. We wish also
to express our appreciation to Dr. Runeckles for permission
to use preliminary  results  of his work on incineration  of
Methyl Trithion.
                                                    -241 -

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                     DEVELOPMENT OF A HAZARDOUS WASTE DECISION MODEL FOR THE
                           STATE OF MINNESOTA - WHAT IS A HAZARDOUS WASTE?

                                                James A. Kinsey
                                       Hazardous Waste Management Section
                                              Division of Solid Waste
                                       Minnesota Pollution Control Agency
                                                  Roseville, MN
INTRODUCTION

      During  the 1974  legislative session, the Minnesota
Legislature enacted a law requiring the Minnesota Pollution
Control  Agency  (MPCA)  to  adopt standards  for the
identification of  hazardous waste and  for  the  labeling,
classification,  storage,   collection,   transportation,  and
disposal  of  hazardous   waste.  There  was  no  special
appropriation for the MPCA to hire staff or to conduct the
required studies. The comprehensive regulations now being
proposed were made possible by a series of planning grants
from the U. S. Environmental Protection Agency (EPA).
      This  paper will focus on the development of the
hazardous  waste classification model for the Minnesota
hazardous  waste regulatory program. This effort consisted
primarily  of  utilizing available  information and did not
include the  validation   of  analytical procedures or the
development   of methods for obtaining  representative
samples of hazardous wastes.
      The  State  Legislature, in establishing the framework
for a comprehensive hazardous waste management program,
defined "hazardous waste" with respect to "routine waste
management techniques", as follows:

      "Hazardous  waste"   means  any   refuse  or
      discarded material or combinations of refuse or
      discarded materials in solid, semi-solid, liquid,
      or gaseous form which cannot be handled by
      routine waste management techniques  because
      they pose  a  substantial  present or potential
      hazard   to  human  health  or  other living
      organisms  because of their chemical, biological,
      or physical properties. Categories of  hazardous
      waste materials include, but  are  not  limited
      to:  explosives, flammables, oxidizers, poisons,
      irritants,  and corrosives. (Minnesota Statutes
      116.06, Subd. 13)

      Routine waste management in Minnesota consists of
the  collection, compaction, and burial of municipal  solid
wastes  in  sanitary  landfills that  are not,  in  all  cases,
constructed to  contain   or  restrict the  flow of  whatever
leachate is generated.  In  addition,  Minnesota  is almost
completely covered with  a  glacial  till that has  direct
hydrogeological  access to ground water upon which much
of the State is dependent. The potential for contamination
of  this  important  natural  resource by  improper  land
disposal  cannot  be  overemphasized.  The  classification
decision model  must, therefore, identify  not only  those
materials   that  pose  a  substantial  hazard   while  being
transported to and buried at the landfill, but also identify
those that pose a substantial  hazard after they have been
buried there.
      Initially, there was no agreement about the definition
of a "hazardous waste" or about the approach that should
be used in the development of a definition. Furthermore,
no accepted  standard criteria or limits for the evaluation of
"hazardous wastes" were available.

Materials and Methods

      The  major   sources  of  information  used   are
categorized below.  U. S. EPA-funded  studies of national
hazardous waste management problems:

   •  A Study of Hazardous Waste Materials,  Hazardous
      Effects and Disposal Methods, Booz Allen Applied
      Research

   •  Program for the Management of Hazardous Wastes,
      Battelle Northwest Laboratories (BNW)

   •  Recommended    Methods    of     Reduction,
      Neutralization, Recovery  or  Disposal of Hazardous
      Waste, TRW Systems Group

   •  Assessments of hazardous waste practices of selected
      industries, by various contractors

      Hazardous material  regulations  from the following
Federal regulatory agencies:

   •  Consumer   Products   Safety  Commission  (CPSC)
      (16 CFR, Part 1500)

   •  Department   of  Transportation  (DOT)  (49 CFR,
      Parts 170-179)

   •  Occupational   Safety  and   Health  Administration
      (OSHA) (29 CFR, Parts 1900-1999)

   •  Environmental Protection Agency (EPA) (40 CFR,
      Part 162)

      Hazardous  waste   regulations  contained  in   the
following Federal legislation:

   .  Clean Air Act (42 USC 1859)
   •  Federal Water Pollution Control Act (PL 92-500)
   .  Safe Drinking Water Act (PL 93-523)
                                                      -242-

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     The  following  studies  funded  by  the  Minnesota
Pollution Control Agency regarding State hazardous waste
management:

  •  Hazardous  Waste  Generation in  the  Twin  Cities
     Metropolitan  Eight-County Area,  Barr Engineering
     Company

  •  Toxicological  Criteria for Defining Hazardous Waste,
     Battelle Northwest Laboratories (BMW)

     Industrial Ad  Hoc  Committee with  representatives
from the following groups:

  •  Industry
  •  Environmental citizen groups
  •  Educational research institutions
  •  Governmental (local, state) agencies
  •  Trade associations
  •  Professional associations

     Temporal and fiscal constraints limited our efforts to
the consideration of existing hazard evaluation criteria. For
example, the Federal  Department of Transportation (DOT)
has  established criteria to evaluate the hazards of material
during  transportation through the lanes of commerce. The
U. S. EPA has criteria to evaluate the hazards of materials
spilled  into surface  waters. The Consumer Products Safety
Commission has  criteria to evaluate the hazards of most
commodities as a  result of  consumer  use.  Many  other
criteria could  be  cited, but each criterion varies somewhat
from all the others  according to the nature of the materials
that  it  is   designed to evaluate and the conditions that
may lead to an exposure to the material.
     Some  of the  criteria were designed to evaluate  the
hazards of materials  under the same conditions that are
inherent in  routine waste  management  and  could be
incorporated into a definition of "hazardous waste". With
regard  to most of the criteria, the conditions of exposure
were different from  those that  would  be of concern in
routine waste management. These criteria were evaluated to
determine if they could be modified sufficiently to be used
as a definition of a  "hazardous waste". Scenarios, based on
routes   of   environmental  translocation,  were  used to
determine which  criteria could best be modified to identify
hazards under the conditions of routine waste management.
     To evaluate the land disposal portion of routine waste
management, the following major routes of environmental
translocation were used:
   •  Surface water contamination from runoff
   •  Air  pollution  from  open   burning,  evaporation,
      sublimation, and wind erosion
   •  Poisoning from direct contact
   •  Poisoning via the food chain
   •  Fire and explosion

 EPA  (1) considered the above to be  the  major routes by
 which improper  land  disposal  of hazardous wastes may
 result in  damage.
      Two approaches were taken in using the criteria to
classify wastes as hazardous. Either a criterion was used as
part of the decision model, or a list of hazardous materials
was developed based on a criterion and used as part of the
decision  model. Both alternatives  had intrinsic advantages
and  disadvantages. However, on an administrative level, it
was   decided  that  the   decision   model  was  more
advantageous than a list and should be used in preference to
a list.
      A listing approach would tend to be simple and, as far
as  hazard evaluation is  concerned,  more economically
attractive.   Little additional   evaluation   by  the  waste
generator would be required because, if a  waste is itemized
on  the  list,  most  of the  evaluation is  already  done.
However, the most significant economic impact is generally
either to the disposal cost, or occurs as a  result of damage
caused by the improper disposal of hazardous waste.
      A  disadvantage of a list  is that  it is more limited in
applicability than a  decision  model. In simplifying  the
definition  by  using  a  list, the definition becomes rigid,
because  it applies only to materials actually identified on
the  list.  This presents a regulatory problem because after
the  list becomes part of the regulations,  it is difficult to
change or update in response to new information or to
changes in the composition of wastes. Furthermore, lists, in
contrast to decision models, do not account for synergism
or antagonism  between compounds or for variations in the
concentration, composition,  or production of a waste. In
the  decision mode),  the properties  of  individual  waste
streams themselves are evaluated based on  objective criteria,
and wastes are classified as hazardous because they have a
hazardous   property   rather   than  just  a  hazardous
component.
      The decision model, if too rigid, might result in extra
costs for an analysis that is not really needed; on the other
hand, a decision model may lull an investigator into a false
sense of security if more complex testing  is really required.
However, a decision model would ensure  the generation of
a  minimum  amount  of  technical  data  upon  which
consistent objective  decisions  could be based. The result
would be to maximize the protection from  those wastes
that are truly hazardous while minimizing  the disposal costs
of wastes that are not really hazardous.
       Many  important decisions, at least concerning the
sequence of testing, could be made on the basis of analyses
or experience with other known wastes. Wastes from similar
processes may differ only minutely from each other. Wastes
that fall into a genuinely unknown category would require
correspondingly  more complex  testing  to  evaluate the
hazards  (2).
       One  part  of  the drafting  and review  process that
deserves  special  mention is the formation and  use  of the
 Industrial  Ad   Hoc  Committee.  We  actively  solicited
widespread representation in the Committee and then met
 regularly to consider their views. The Committee provided a
 vast source of personal experience,  a wealth of technical
 information,  and  an   opportunity   for  practical  and
 constructive review. The process also served to educate the
 Committee   members   and   organizations   that  they
 represented by  providing  a  complete   picture  of  the
 problems  associated with  hazardous waste  management.
                                                         243

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This educational process is  expected to make the public
hearings  more meaningful  by focusing on the areas where
important  conflicts  of  interest appear.  Similarly, the
existence and effective use of this Committee is expected to
continue   during  the  difficult   transition   stages   of
implementation  of the program.

Results

      The evaluation scheme by which hazardous wastes are
defined  is  shown  in  Figure 1. The criteria include  a
combination of lists, tests, and generic descriptions.  In
many  instances, the  criteria are compatible with  existing
definitions of hazardous materials.
      Not all wastes  will be evaluated by this scheme.  In
Minnesota,  there  are  existing authorities  that  more
appropriately regulate the management of some wastes.
Household wastes are regulated  in a solid  waste program.
Air contaminants are regulated by the MPCA's Air Quality
Division. NPDES discharges and effluents from municipal
treatment  works  are  regulated by  State  and  Federal
permits. With  respect  to  radioactive wastes, Minnesota is
one of  the few  states that  has   not  enacted enabling
legislation  that would establish  a  program  to  control
radioactive materials.  There are both political and practical
reasons   for  this;  however,   the   Nuclear   Regulatory
Commission does  regulate the disposal of many types of
radioactive  materials,  and  at  this time  we have  not
identified a need for more comprehensive coverage.
      The generator would be required by these regulations
to evaluate all  other  wastes, and, if they are found to be
hazardous wastes,  to label, transport, treat, and dispose of
the  wastes according to the provisions of the regulations.
The  generator   would  evaluate each  of  his wastes  to
determine if any of the listed criteria were exceeded.
      The results of this evaluation along with a description
of any  data, tests, or assumptions  used in the evaluation
would be submitted to the MPCA  in the form of either a
certification that  the waste  is not hazardous or with a
disclosure of the management of those that are hazardous.
The  MPCA, in  turn, can accept or reject the generator's
evaluation and make a determination of its own.
      The criteria by which  the generator conducts  his
evaluation are given in Table 1.  Each criterion is defined as
being either the elements of a list, the value of a test, or a
generic category. The generator  may have to use additional
analytical testing  procedures  to evaluate criteria  that  are
defined  as generic categories. A qualitative analysis for a
strong  oxidizer or for  establishing  an oxidation potential
might be needed to  determine  if a  waste  is oxidative.  An
impact test, Trauzl test, or a card gap test may be needed to
determine explosivity. However, we could  not justify each
of these tests on every sample of waste. There are simply
too many other regulatory programs such as those of OSHA
and   DOT  that  provide  sufficient   overlap  for  the
identification of such materials.

Discussion

      The lexicological evaluation  includes acute lethality
tests and  an evaluation of selected hazards important to
waste management.  This approach  requires minimal data
for hazard evaluation and is reasonable in  both time and
cost. Tests of subacute and chronic toxicological properties
would   provide  additional  information  at a  significant
increase in cost and time, such that they are  not practical in
a definition that must be applied to all types of wastes.
     There  are some  sublethal  effects  that  are  quite
pertinent   to  waste   management  such   as   irritation,
corrosion,  and  the  delayed  toxicity of bioconcentrative,
neoplastigenic,  teratogenic, or mutagenic materials. These
effects are considered separately, but to keep the evaluation
reasonable, this list was kept to a minimum. To test all
wastes  for  every nonlethal  effect  is  an   unrealistic and
unmanageable  task; equally,  to  test  only  for  the most
serious  effects  would be subjective and unsound from  a
toxicological  standpoint.  Each   material   is  capable  of
producing many sublethal effects.  However,  there is no way
to select a single effect or even a limited number of effects
from all those observed for a given material and relate those
effects  objectively to  different  effects caused by other
materials  in  such a way as to rank the materials according
to the degree of hazard they pose. It is much easier, more
objective  and less expensive to use lethality as an endpoint
than to  assess  the  extent  of  damage  attributable  to
nonlethal effects.
      The difference between subacute and acute toxicity is
generally  a matter of dose and the effect of repeated doses,
rather than  a single massive dose. The symptoms may or
may not  be the same for acute exposures,  but  in order to
establish dosage levels for studies  of subacute toxicity, the
acute toxicity  must be determined  first. The endpoint for
studies of subacute toxicity is almost  never lethality. Such
studies lend themselves only  to  sublethal  effects,  and as
discussed  above, such  endpoints  are  not  the  critical
endpoints we need.  Evaluations of subacute toxicity might
require as much as 90 days to complete, and, for the added
expense,  one   must   question  the  usefulness  of  such
subjective information in a definition of hazardous waste.
In  our definition,  protection from  substantial  subacute
effects  is  afforded  by using a  safety factor of  100  in
developing a level at which  an acute  lethal test predicts a
hazard. This is reasonable because, depending on LDjjQ
dose response curve, range finding studies for investigations
of subacute  toxicity generally start with 1/12,1 /6, and 1 /3
of the LDso (3).
      The difference  between chronic and acute toxicity
goes beyond the duration of exposure. Such studies often
take 2 years or  more  to complete,  and,  like  studies of
subacute  toxicity, the endpoint is almost never as objective
as   lethality. Clearly  such  extensive subjective  studies,
 requiring  much  time  and  money,  are  not reasonable
prerequisites for  the  disposal of waste.  Not only  are the
symptoms  different  from  those  found  with an acute
exposure to the same material, but chronic exposures might
well pose the most insidious and serious threat with respect
to  land  disposal! Therefore, the  interpretation  of data
 regarding  acute exposure has been  modified  to ensure
 protection from substantial  hazards as a result of  chronic
exposures. As was done for subacute effects, a safety factor
 of 100 has been employed in  the acute exposure scenarios.
                                                         -244-

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                                                                   FIGURE 1
                  Household Waste
                  Air Contaminant
                  NPDES Discharge
                   Sewered Waste
                  Radioactive Waste
                 Certain Containers
ALL WASTES
                                                                     Evaluation by
                                                                     the Generator
10
.u
01

Neoplastigenic
Teratogenic
Mutagenic
1

Bioconcentrative

I
Oral LD50
Dermal LD50 Irritative
Inhalation LCcn Corrosive
uu
Aquatic LC5Q
1
Flammable
Explosive
Oxidizer
200° F
1
Health
Hazardoi
Wast
La bo rat o
I


(
y



J,
Certification of
Evaluation
1
N(

No


Review »
>

Any Criteria
Exceeded?

Agency
Determination
Is the Waste Hazardous?
Yes
^^
Disclosure of
Management
IS ^
%~
Yes


-------
                                                     TABLE 1
                                  WASTE
             CRITERIA
                    LIST

                    Neoplastigenic Waste
                    Teratogenic Waste
                    Mutagenic Waste

                    Bioconcentrative Waste
                    TEST

                    Toxic Waste
                      Oral
                      Dermal
                      Inhalation LCijQ

                      Aquatic LC5Q

                    Irritative Waste

                    Corrosive Waste


                    Flammable Waste


                    GENERIC

                    Explosive Waste
                    Oxidative Waste
                    Laboratory Waste
                    Health Services Hazardous Waste
                    Waste Oil
                    Waste in  Excess of 200°F.
Industrial use 0.1%
Concentrations that exceed threshold
limits in the leachate test
Less than 500 mg/kg
Less than 1,000 mg/kg
Less than 2,000 mg/m^ as dust or
  mist or 1,000 ppm as gas or vapor
Less than 100 mg/l

PSI Score of 5 or more
First or second degree burns
3>pH>12
Irreversible tissue damage
0.25 inch/year on 1,020 steel
Flashpoint below 200°F.
Spontaneous combustion
As defined in HW-1 and 2
It is generally accepted that safety factors ranging from 20
to  100  provide  reasonable protection from  chronic  and
persistent toxicity  (4, 5, 6, 7, 26). The factor of 100 is
more appropriate than the  factor of 20 because there is a
wide variety of unidentified materials handled collectively
without  either  regard  to  or  knowledge of individual
properties.
      Tests  of acute  lethality  were selected  to  evaluate
toxicity  of  wastes because they are relatively inexpensive,
and they produce objective  data. The 4 different routes of
administration were selected to maximize the  applicability
of such an evaluation. The physical properties of a material
limit the route of administration. For instance, gases cannot
be  tested orally, and  if a material does not form a dust,
mist, gas,  or vapor,  it cannot  be tested for hazard  via
inhalation. There are many reasons why one route might be
ineffective compared to another, even when exposure by
both is possible.
      Improper land disposal of hazardous waste can result
in  damage  if  ground waters are  contaminated  by  the
leachate. A dilution factor of  100-fold per  1/2  mile  of
distance traveled has been chosen for use in scenarios where
leachate-contaminated ground waters cause damage. Battelle
Northwest Laboratories reported actual data to support the
reasonableness of such a factor (8). Studies  in Saco, Maine
indicate that the leachate from  a landfill may be  diluted
from 4.7 to 196 times in traveling to a well  500 feet down
gradient  (9). Because dilution is  generally an exponential
function of  distance,   this would  suggest  a  minimum
dilution of better than 256-fold at % mile. Hence, use of a
factor of 100 is not unreasonable  as a conservative estimate
of dilution for  leachate. Similar studies were conducted at
the Old New  Castle County Landfill  near  Llangollen,
Delaware (10). Analysis of chloride content there revealed a
dilution factor  of 27 at 650 feet and 7100 at 2500 feet.
Hydrogeological studies  of  a landfill in Illinois yielded a
                                                       -246-

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dilution factor of 4—5  over a 650-foot distance  when
chloride was analyzed (10). Because chlorides tend to move
faster with  groundwater  than  do  other components  of
leachate,  one  would expect  even greater dilution for the
other  components.  Therefore,  both  of  these studies
generally agree with the findings in  Maine and confirm the
conservative nature  of  the  100:1  dilution.  Studies  of
leachate from  a  landfill in Islip, New  York showed plugs
that  achieved only a factor of 10 at a %-mile distance (11).
The  soil matrix there was one of  sand and gravel streaks,
and,  therefore, permitted rapid  flow  which  discourages
dilution. Although the dilution factor of 100 does not hold
for extreme situations, it is a conservative estimate  and
provides an adequate  margin of safety regarding possible
exposure levels. This dilution factor should not be confused
with  the safety factor of 100 that is applied to criteria of
lethal toxicity to account for chronic and sublethal effects.
A discussion of the individual criteria follows:

Acute Oral  Toxicity

      Utilizing the  dilution  factor  of  100, a  worst-case
situation could  result in  water containing 10,000  ppm
contaminant at a well Y2 mile from a sanitary  landfill. A
standard 100 kg man consuming 2.5 liters of water per day
would consume:

      = 2.5 liters x 10,000 mg/I

      = 25,000 mg or

        25,000 mg -MOO kg or

        250 mg /kg

      Recognizing that the  LD5Q is a measure of lethality
and  that  individual responses  might vary, an  acute  oral
LDijQ should be greater than 250 mg/kg, but not less. The
value of  50 mg/kg used  by the  U.S. EPA  (12)  and  DOT
{13)  to designate Class B poisons is clearly too low to be a
criterion of a  hazardous waste. An  LD5Q of 500 mg/kg is
the  cutoff  point  selected: by  the  National Academy of
Sciences  (14)  to  designate highly  toxic economic poisons
for  moderately  hazardous  substances; by  the Consumer
Product   Safety   Commission   (15)   as   requiring  a
precautionary  label  on a  consumer product;  and by the
U. S. EPA  (16) for pesticides of Class II requiring a warning
label.  Materials  with  an  LD50  under  500 mg/kg  are
considered toxic by  Gosselin  (17)  and  Railway Systems
Management Association  (18). A lethal dose at 500 mg/kg
amounts to only about  2 tablespoons  or one ounce for a
child,  and  about 4  tablespoons or  2 ounces for an  adult
male. Exposures at such dosages are not typical of routine
waste management,  but  it should  be borne in mind that
while lethality is the endpoint used  in testing, the practical
objective is not only to prevent human death, but a serious
intoxication  of  any  kind.  A material that  is lethal at
500 mg/kg might cause substantial harm at only 5 mg/kg.
Thus, the  amount of material needed  to produce serious
effects is much less than the amount that might kill.
      Battelle   Northwest   Laboratories  compared  the
criterion of 500 mg/kg to diet levels of various animals that
might be more  likely than man to receive a lethal dose as a
result of mismanagement  of  hazardous waste (8). The
data in Table 2 indicate that small quantities of such wastes
can  be  lethal  to  sensitive  species  and  pose  chronic or
sublethal hazards to most species.

Acute Dermal Toxicity

      Battelle  described  a worst-case situation for  acute
dermal toxicity (8). If a  100 kg man with a surface area of
20,000 sq cm  was half doused by a liquid waste resulting
in  a film  of 0.1 mm  thickness,   100 cu  m  or  about
100,000 mg (assuming the liquid to have the same density
as  water)  could  be  absorbed,  resulting  in  a dose of
1,000 mg/kg. Again, in an extreme  case, the dermal  (.050
of  200 mg/kg  used  by  DOT  (13) to designate  Class B
poisons  and by U.S.  EPA (12) to designate highly  toxic
economic poisons is  not sufficient to provide protection
from acute effects regarding hazardous waste management.
Furthermore, a larger  value is needed to offer protection
from substantial subacute and chronic harm as a result of
more likely circumstances of exposure. A dermal LDgQ of
1000 mg/kg would be within the range that the Consumer
Product Safety Commission  (15) considers toxic, that the
U.S.  EPA  (16)   employs  for  Class  II  designation of
pesticides, and  that the National Academy of Sciences (14)
considers moderately toxic.

Acute Inhalation Toxicity

      In the context  of hazardous wastes, a hazard due to
inhalation might result from  the suspension  of particles by
wind action, or the volatilization of materials at a landfill,
or during storage.  OSHA work area regulations require that
fugitive  dust levels should not exceed 10  mg/m^   during
an  8-hour day. This is a  level at which most dusts become
noticeable,  and it is  required that sanitary landfills  within
Minnesota operate under this  limit.  According to  MPCA
regulation APC 1, a landfill may not be operated when dust
levels exceed  0.15  mg/m^ more than once  per  year
measured at the boundary of the property. To protect the
operator and  the public downwind,  materials should not
produce a toxic  effect when present at these levels. It is
assumed that  short-term doses of  most wastes are  better
tolerated  than long-term  exposures.  The OSHA  dust
standard is  8-hour exposure  and  not the shorter term
encounter   one might  expect  from  gusts of wind or
disturbances raised when  heavy  equipment is in use. To
convert between  2 exposure  times, Haber's  law is used
wherein the   concentration of  the contaminant   in air
multiplied by  the time  of exposure remains a constant.
 Because it is applicable  only when effects are cumulative,
only on the uptake curve, and only with vapors and dusts
whose dispersion  and absorption characteristics are similar
to   those  vapors,  Haber's  law will  tend to provide an
additional  safety factor  in this application. Using Haber's
law for a one-hour exposure, the limit may become as much
                                                       -247-

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                                                     TABLE 2

                               RELATION OF 500 mg/kg CRITERIA TO DIET LEVELS
Species
LAB ANIMALS
Mouse (25g)
Rat (250g)
Guinea Pig (650g)
Rabbit P.OOOg)
Dog (25 Ib )
Monkey (30 Ib )
LIVESTOCK
Lamb (300 Ib )
Pig (500 Ib }
Beef Cattle (1,000 Ib )
Horse (1,200 Ib )
MAN (180 Ib )
WILDLIFE
Crow (500g)
Songbird (20g)
Total Daily
Intake (mg/kg
Body Weight)

200,000
70,000
56,000
31,000
25,600
40,000

30,000
45,000
20,000
7,500
28,400

120,000
180,000
Percent
of Diet
(500/Daily
Intake)

.25
.72
.89
1.61
1.95
1.35

1.66
1.11
2.50
6.66
1.77

.42
.28
Amount of
Material With
LD5o= 500 mg/kg
To Reach
LDijg Dose (Oz )

.00044
.0044
.0114
.052
.2
.24

2.4
4.0
8.0
9.6
1.44

.0088
.00036
as 100 mg/rrr*    and for a 5-minute exposure, the limit
might become as much as 1000  mg/m^.   Thus, the limit
set by EPA (12), and DOT  (13), and Consumer Product
Safety Commission (15) of 2000  mg/m^    would seem to
offer reasonable  protection at the landfill.  For one-hour
exposures, the safety factor would be 20, and a 5-minute
exposure  at 1000  mg/m**    would most likely be highly
objectionable, and therefore, not too likely.
      The  hazards resulting  from  vapors are evaluated
differently. Vapors are  not as easily  controlled as dusts
which can be wetted down. Vapors depend on slow release
and  wind for dispersion  to nontoxic  levels.  The National
Academy of Sciences has recommended that materials with
a Threshhold Lethal Valve (TLV) of 100 ppm or less as a
vapor be considered toxic.  Sax (19) assigns a high toxicity
rating  to  TLV's  less than 100 and recommends the use of
respirators for  short-term  exposure of 2—5 times those
TLV's. The TLV is also measured with respect to an 8-hour
exposure, and, reduced to one-hour exposure with Haber's
law.  the limit becomes 1000 ppm as a safety factor. DOT
(13), CPSO (15), and U. S. EPA (12) definitions of "highly
toxic" each use 200 ppm as the limit;  however, CPSO (15)
considers  levels  up  to  20,000 ppm  as still being toxic.
Because there is greater inherent lack of control with vapors
in routine  waste  management  than in  the  lanes  of
commerce, a value greater than 200 ppm is needed. A
of  1000 ppm  would offer  protection from toxic gases
which realistically may be encountered, such as  H^S and
HCN, which would not otherwise be included, and is within
the toxic  range of the more  inclusive existing definitions.
The National Academy of Sciences (14) hazard rating for
short-term inhalation considers gases or  vapors  whose
LC5Q/S are 200 to 2000 ppm to be moderately hazardous.

Acute Toxicity (Aquatic)

     At the point when leachate enters a surface water, it
simulates a hazardous  material spill in that it constitutes an
insult to water quality resulting from the direct addition of
contaminants. This insult has the potential of being massive
because the leachate-contaminated groundwater might be
moving as fast as 3 feet per day as it discharges into  the
surface water body. There would, however, be dilution due
to the slow rate at which the contamination discharges into
the water. The criterion of 100 mg/l provides for 100-fold
dilution in the worst possible case by which the leachate is
contaminating the   groundwater  at  10,000 ppm   as  it
discharges to a surface water body one-half mile from a
landfill. The criterion  of 100 mg/l is somewhat lower than
that proposed  by  U. S.  EPA (20)  for  designation of
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 hazardous  materials. It does, however, correspond  with
 comments  provided by   industry  in  response to  that
 proposal (20).  It also corresponds to grades 2, 3 and 4 of
 the  National  Academy   of  Sciences  (14)   ratings   and
 categories A, B, and C of the proposed Inter-Governmental
 Maritime Consultative Organization (IMCO) (21) system for
 control  of industrial  materials.  Materials  toxic at levels
 greater than  100mg/l  are generally defined as practically
 nontoxic.

 Neoplastigenic, Teratogenic, Mutagenic Materials

     These effects are regulated by a list  rather than by
 actual tests.  The list includes neoplastigenic,  teratogenic,
 and mutagenic  materials for which the National Institute of
 Occupational   Safety   and   Health   (NIOSH)  criteria
 documents have been prepared or will be prepared in fiscal
 year 1977, and also  includes the 14 carcinogens regulated
 by  the  Occupational  Safety  and  Health  Administration
 (OSHA).  There  are  many  different  criteria  used  to
 determine if  a material is neoplastigenic,  teratogenic,  or
 mutagenic and, as a result, many different lists could  have
 been considered.  In an effort to keep the criteria objective,
 a single  source  was  used  as  the  sole  arbitrator  for
 identifying such  materials. NIOSH was chosen  for  this.
 NIOSH has been reviewing pertinent data for many years
 and included only those materials for which a strong case
 could be made.
     In  using  the  list, its derivation  and its  originally
 intended  use must  be kept in  mind. OSHA has excluded
 from  regulation  solutions  of  even  the  most   potent
 carcinogens  if  they are present at less than  0.1 percent
 (1.0 percent for some carcinogens)  (22). These  levels are
 somewhat  arbitrary, but  nevertheless,  were  chosen  as
 practical  levels. It is assumed that in lesser concentrations
 there would  be no  practical use of these materials in an
 industrial process, and therefore, industry would not likely
 utilize   them   intentionally.   This  approach  considers
 intentional  industrial uses of these materials, but does not
 consider cases in which the presence of such a material is
either unknown or  incidental  to the process. Therefore, a
 quantitative analysis for any material on the list is required
 whenever it is known that such a material is present in the
 waste stream. A waste is classified as hazardous if any part
of it contains more than 0.1 percent of such a material. To
 prevent disposal of such materials by dilution, it is required
that if at any time during the production of the waste the
concentration of a listed material exceeds 0.1 percent, then
any  detectable amount of that material in the waste  would
cause the waste  to be classified as hazardous.

     The list of hazardous materials is given  below:

          2-Acetylaminofluorine (2-AAF)
          4-Aminodiphenyl (4-ADP)
          Arsenic and its compounds
          Benzene
          Benzidine
          Beryllium and its compounds
          Cadmium and its compounds
            Carbon tetrachloride
            Chloroform
            bis-(Chloromethyl) ether (BCME)
            Chloromethyl methyl ether (CMME)
            Chromium and its compounds (VI)
            3, 3'-Dichlorobenzidine (DCB)
            4-Dimethylaminoazine (DAB)
            Ethyleneimine (El)
            Lead and its compounds
            4, 4-Methylene-bis-2-Chloroniline (MOCA)
            a-Naphthylamine (1-NA)
            b-Naphthylamine (2-NA)
            Nickel and its compounds
            4-Nitrobiphenyl
            n-Nitrosodimethylamine (DMN)
            Polychlorinated Biphenyls  (PCB)
            B-Propiolactone (BPL)
            Vinyl Chloride (VCM)

      A criterion  based on  a  rapid  screening  test for
 mutagenesis was carefully  considered.  For instance, the
 Ames test  using 5  strains  of  Salmonella  typhimurium  is
 inexpensive,  rapid,   and   provides  a   dose-response
 relationship upon which objective  criteria could be based.
 Such screening  tests have obvious  limitations in that they
 do  not  identify  all   known  carcinogens.  Even  more
 importantly, there are no data about wastes to enable us to
 predict  which  waste   streams  would  be  classified  as
 hazardous   by  this  procedure.  These procedures  might
 ultimately   meet  screening requirements,   but there   is
 currently not enough experience to justify their use as the
 sole criterion for determining whether a waste would be too
 hazardous to dispose of on land.

 Bioconcentrative Materials

      The bioconcentrative  materials  on the list are those
 that  have   been   identified   by  the  U. S.   EPA  as
 bioconcentrative (6)  and that have either a drinking water
 limit (23) or a limit for  fresh water aquatic life (23). These
 levels have  been selected  by  the National Academy  of
 Sciences. The amount of each material sufficient to classify
 a  waste as  hazardous is based  on  earlier scenarios where
 leachate was shown to be diluted by 100 and 10,000 upon
 entry to the  nearest  allowable  well or surface water,
 respectively. A  waste, then, that can produce  a  leachate
 that contains a bioconcentrative material at greater  than
 100 times drinking  water standard, or 10,000 times criteria
 for fresh water aquatic life, is classified  as hazardous. This is
 summarized in Table 3.
      Laboratory analysis can  be used to determine if  a
 chemical has  become more concentrated  in an organism
 than it  is in the environment.  However, this can become a
 cumbersome and costly procedure for evaluating a waste
 because of the  many different chemicals that comprise  a
waste. If one  considers the  possibilities of a body burden
 increasing with higher trophic  levels, or with size or age of
the animal,  then it becomes clear that with the complex
structure of the food chain, that there can be  no simple
system  with general  applicability.  These  effects can be
                                                       -249-

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                                                       TABLE 3





Aldrin
Cadmium and Compounds
Chlordane
DDT
Endrin
Heptachlor
Lead and Compounds
Mercury and Compounds
Mi rex
Methoxychlor
PCB's
Toxaphene



Drinking Water
Criteria (ppb)(23)
1
10
3
50
1
0.1
50
2
—
100
—
5

Threshold in
Leachate Based
on Drinking
Water (ppb)
100
1,000
300
5.000
100
10
5,000
200
_
10,000
—
500

Freshwater
Aquatic Life
Criteria
(ppb)(23)
.01
.4
.04
.002
.002
.01
.30
.05
.001
.005
.002
.01
Threshold in
Leachate Based
on Freshwater
Aquatic Life
(ppb)
100
4,000
400
20
20
100
300,000
500
10
50
20
100
 detected in  the field, but  to  prove that a waste does not
 cause such an effect would require extensive analysis. The
 analytical work required to determine definitively if a waste
 is bioconcentrated is too expensive and time consuming to
 be a practical criterion. Some rapid, inexpensive tests have
 been devised to detect some instances of bioconcentration,
 but they lack general applicability. The lipid-water partition
 coefficient  measures only the  relative solubility   of  a
 material. This  process does not account for materials such
 as  mercury  and lead that  are retained through  their high
 affinity  for sulfhydryl groups and disulfides associated with
 proteins  in living tissue.  Furthermore, this approach  does
 not account for the rate of metabolism or even whether or
 not a metabolic pathway exists. Metabolic pathways might
 exist that detoxify the material fast enough to prevent its
 bioconcentration to toxic levels.

 Corrosive Materials

      The criterion to be used to determine if a waste is
 corrosive is  the  presence  of irreversible  damage to tissue
 when  tested on rabbit skin according to the procedure in
 16 CFR  1500.41,  or corrosion of  steel coupon in excess of
 0.250 inches per year when tested by procedures described
 in the National Association of Corrosion Engineers (NACE)
 standard TM-01-69, or a pH greater than  12 or less than 3.
 The irreversible damage to rabbit skin is the same criterion
 used by  DOT (13) and CPSC (15). In addition, DOT also
 uses  the  NACE  standard  TM-01-69  and requires  both
 aluminum and  steel to be tested.  We did not include the
aluminum test  requirement because it is  not applicable to
 waste management in Minnesota. We know of no situation
 where aluminum  containers are routinely  used for  solid
waste management. The pH limits were established to offer
an inexpensive alternative to the above tests. Solutions with
 a pH  in excess of 12 are corrosive to tissue, and solutions
 with a pH less than 3 are corrosive to steel. Therefore, this
 alternative  would  add  no  new  wastes to  the  list  of
 hazardous materials.  In addition,  pH  also affects surface
 waters. Water  is toxic to fresh and salt water aquatic  life
 when  it  has a  pH less than 6.5 or greater than 8.5 (8). As
 noted earlier, leachate is expected to be diluted by a factor
 of 10,000, that is 4 logs for pH. A waste with a pH less than
 2.5 or greater than 12.5 would pose a substantial threat to
 aquatic life if added in sufficient quantity.

 Irritative Materials

      Irritative  wastes are those that cause a local reversible
 injury at the site of contact. They cannot, by definition, be
 corrosive.  Either  practical  experience with the waste  in
 which short-term  exposures have caused first-degree burns
 and  long-term  exposures have  caused second-degree burns,
 or an  empirical score  of 5  or more in the primary skin
 irritation test described in 16 CFR  1500.41 will be used to
 determine if a waste is irritative. The primary skin irritation
 procedure  is the  same one used by the CPSC (15). The
 criteria for eye irritation established by the CPSC were not
 used because of concern that the irritative nature of many
 wastes that are suitable for routine waste management may
 be due to pieces of dirt or grit in the test sample, and would
 result  in  their inappropriate  classification  as  hazardous
 waste  (3). The criterion  of  experience was added  as an
 economical alternative to biological testing in cases where
the  generator  has practical  experience  in  handling the
 waste.

 Flammable Materials

      Criteria of flammability to be  used  are essentially
those used by  DOT  (13). The distinction made by  DOT
 between   flammable   and  combustible  does not   offer
                                                       -250-

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sufficient  protection  under  conditions  of routine waste
management.  Within  the  lanes  of commerce,  130°F is
considered  the maximum temperature to  which materials
are normally exposed, while wastes in landfills are subject
to intimate contact with hot machinery during compaction,
to temperatures  that may  reach  150°F  (65°C)  during
bacterial decomposition (24), and to higher temperatures as
a result  of  exothermic  reactions  between  wastes after
burial.

Generic Categories

     Explosive  waste,   oxidative  waste,  health  services
hazardous waste, and  waste oils are all defined generically.
The difficulty with these wastes is  not in identifying them,
but rather their need for special disposal alternatives.
     DOT  requires  all  explosive  materials  and  strong
oxidizers that are transported off-site to be identified (25).
To require tests such as a card gap test, a Trauzl test, an
impact  test,  or   a  test  of   oxidation  potential  to  be
conducted  on all  wastes would be repetitive and would
likely provide little new information.
     Health services hazardous waste includes pathological
waste,   infectious  waste,  and  sharp  objects  such  as
hypodermic needles, suture needles, and scalpel blades. The
difference  between this definition  and the definition of
"hazardous  infectious waste" which is presently in use by
the Minnesota Department  of Health,  is the  manner in
which the wastes are evaluated. Rooms wherein such wastes
are produced would be  identified, and all such wastes that
originate in those rooms would be classified as hazardous as
opposed  to the present system in  which  such wastes are
subject   to  individual  medical   evaluation   before
classification.
     Waste oils are limited to petroleum derivatives that do
not have a defined chemical structure. Oils of vegetable and
animal origin were not  included  because  they are not as
persistent  as  petroleum  oils, and their  taste  and odor
thresholds  are usually much higher. The properties of waste
oils vary greatly according to their source and the degree of
processing. Together with the heavy metals often associated
with such  wastes, many oil  wastes would be classified as
hazardous   on the  basis  of  flammability  or  toxicity.
 However,  due to their mobility as  a class, their ability to
contaminate groundwaters at  low concentrations, their
resistance to decomposition, and  the large volumes which
are being disposed, waste oils are categorically classified as
hazardous. This designation will greatly reduce the number
of wastes requiring testing and thus, eliminate some testing
costs. The economic impact on disposal costs will not be as
severe  as for other wastes because of the availability of low
cost alternatives  such as  land farming, incineration,  and
 re-refining.

 Summary and Conclusions

      The   Minnesota   hazardous  waste  management
 regulations are oriented toward land disposal. They are the
 latest  strands  in  a  regulatory fabric that is designed to
 control discharges of  industrial waste into the environment.
Regulations already exist that  restrict discharges into the
atmosphere and into the waters of the State. However, in
order to protect the environment from hazardous wastes,
regulatory  control also had to  be extended to cover land
disposal. Improper land disposal  results  in  both  air and
water discharges of hazardous materials and to have ignored
these elements would have permitted  a serious loophole in
the existing programs to continue. Even with the hazardous
waste management regulations, there will be an increasing
burden  placed upon our land resources when wastes that
once  were discharged as contaminants in air or in  waste
waters are  collected in the form of dusts and sludges and
buried.  One reason  for the program  is to ensure that this
process  does  not  become a futile exercise  in transferring
hazardous  waste  from one body of water to another or
from the atmosphere  of one area to  another. In order for
such  a   program  to  be effective, 3 questions must  be
answered. What is a hazardous  waste? At what time does a
material become a waste? Where  can hazardous wastes be
disposed?  The hazardous waste  decision  model  was
developed  to  answer the first  question for  the Minnesota
program.
      The  criteria  that  comprise  the  hazardous  waste
decision model include  some  numerical criteria and some
descriptive criteria. The approach for selecting these criteria
was similar for both  types. The conditions that lead to
possible exposures during routine waste management were
identified.  Then  exposure  methods  were estimated, and,
finally,  a safety factor was applied to provide  a margin of
safety.  Most of the criteria are to be used directly in an
evaluation  of each  waste stream. However, the tests for
neop I ast i gen i c,   teratogenic,   mutagenic,   and
bioconcentrative  materials were  too expensive and time
consuming to apply individually to every waste. Therefore,
we compiled  a list of  waste components that had those
properties  and included the lists in the decision model.
      By  using   this  combined  approach,   we   have
strengthened the decision model. The use of some lists in
the model  resulted in the inclusion  of criteria for  which
tests were too expensive and time consuming. The lists in
the combined approach did   not compromise the other
criteria. For those criteria, evaluation is still  conducted on
the basis  of  actual  waste  characteristics and  thereby
accounts for the synergism and other interactions  between
the components of the waste. Both types of criteria provide
the objective  basis needed to classify  waste for a regulatory
program.
      Use of the decision model  in a regulatory framework
does have limitations.  In extreme cases, the rigid nature of a
regulatory framework will result  in extra  costs for analyses
that is  not really needed  and  may lull investigators into a
false sense of security if more complex testing should be
pursued. The  information that  these criteria generate  is
suitable only for classification and  will  not be of  use in
broadening our  scientific understanding  of the hazards
posed.
      Although the approach may remain the same, these
criteria  will  need  to  be modified  in  the  near future.
Experience  with   the  decision  model  will   lead  to
adjustments  in  the  criteria   as  their effects upon the
                                                        -261 -

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classification   of   waste   streams   become   apparent.
Development and  subsequent  validation  of new sampling
techniques  or  analytical  procedures  will  also  lead  to
modifications of the criteria. There is a particular need for
rapid tests to replace the lists that have been incorporated
into the model. Unfortunately, the reliability of most such
tests  is  at  this  time  limited  to restricted groups  of
homologous chemicals,  and  it is very difficult to predict
their effect upon classification.
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  2.  National Academy of Sciences. 1975. Principles for evaluating
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  3.  Personal  communication.   January, 1977.  M. W.   Anders,
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  4.  Booz-Allen Applied Research, Inc. 1973. A study of hazardous
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  5.  Battelle   Memorial   Institute.   1973.  Program  for   the
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  7.  Ottinger,  R. S.,   et  al.   1973.  [TRW  Systems  Group.]
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13.  Department  of  Transportation. October 1,  1975.  Hazardous
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15.  Consumer  Product  Safety  Commission.  January 1,  1976.
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         against   registration   of  pesticides.  Federal   Register,
         Vol.40, No. 129.

17.  Gosselin, R. E., et al. 1976. Clinical  toxicology of commercial
         products.  4th Edition  Baltimore,  The  Williams   and
         WilkinsCo.
 18.  Railway   Systems  and  Management   Association.
          Chemical transportation safety index. Chicago.
1969.
19.  Sax, I. N. 1968. Dangerous properties of industrial materials.
          3rd Edition.  Van  Nostrand  Reinhold Co.  New York.
          p. 1251.

20.  Environmental  Protection  Agency.   December   30,  1975.
          Proposed rules,  designation of  hazardous  substances.
          Federal Register, Part IV, Vol. 40, No. 250.

21.  Dawson, G. W., et al. January, 1975. Determination of harmful
          quantities and rates of penalty for hazardous  substances.
          EPA-44019-75-O05-b.

22.  Occupational  Safety and Health Administration. January 29,
          1974.   Occupational  safety   and  health
          standards:  carcinogens.  Federal  Register,  Part III,
          Vol. 34,  No. 20.

23.  National  Academy  of  Engineering,   National  Academy of
          Sciences. 1974.  Water  quality  criteria,  1972.  U. S.
          Government Printing Office, Washington, D.C.

24.  Barr Engineering Co. 1973. Hazardous waste generation in the
          Twin Cities  metropolitan eight-county area. Metropolitan
          Inter-County  Council,   Minnesota  Pollution  Control
          Agency.  Minneapolis.

25.  Department of Transportation. April  15, 1976. Consolidation
          of  hazardous  materials  regulations. Federal Register,
          Part II, Vol. 41, No. 74.

26.  Environmental Protection Agency. January 11,  1977. Ocean
          dumping, final  revisions  of  regulations   and criteria.
          Federal Register, Part IV, Vol. 42, No. 7.
                                                               262-

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                          DECISION MODEL FOR DETERMINING THE SUITABILITY OF
                                       LANDFILLING HAZARDOUS WASTE

                                                Gary L. Perket, P.E.
                                                Saint Croix Research
                                              Marine on Saint Croix, MN
                                   (formerly of Minnesota Pollution Control Agency)
INTRODUCTION

     The purpose of this paper is to emphasize the need to
utilize  a  systems approach  when  evaluating whether  a
hazardous waste  is acceptable  at  a given land disposal
facility. To  this end, the  paper seeks  to  develop  a  basic
framework for a decision  model which also  encompasses
the concerns  that  should  be  considered  in  such  an
evaluation. Unavoidably, such a  model is so broad in scope
that it will be inappropriate in many cases, and the scope of
any such  model  must be  reduced or modified  whenever
professional  judgment requires it.
     As developed, the decision model is intended to focus
on the fact that hazardous  waste can represent a threat not
only to groundwater,  but, might also threaten air, soil, and
surface  water  resources. This multiple threat presented by
hazardous waste underscores the need  for  a firm working
knowledge of  the properties of the waste and how those
properties   will  interact  with  the  facility  and  the
environmental setting  in which the facility is located.

MATERIALS AND METHODS

      Not until the last few years has the field  of hazardous
waste  management  received significant  attention.  Not
surprisingly, this absence of attention has resulted in a lack
of research  on technologies for  land disposal of hazardous
waste.  Consequently, most of the developed technologies in
the field of  land disposal have originated from  the design  of
municipal  sanitary landfills. Traditionally,  the primary
concerns in  the design of sanitary landfills have been vector
control,  groundwater quality,  and  more recently, gas
migration.   Of   these  concerns,  the   protection   of
groundwater has received the most research and  attention.
The emphasis  on groundwater  quality   is   an  indirect
acknowledgment that in much of the nation, leachate from
municipal refuse is the most serious problem which must  be
confronted.
      Throughout   this   paper,   references  to   many
procedures,  techniques, and  tests are discussed in order  to
aid the  reader  in   expanding  the  decision  model.  A
significant portion of  these references  has  arisen from
work  done  in the field of municipal refuse. The disparity
between the properties of  municipal refuse and  hazardous
waste  requires  that  caution be exercised when utilizing
those  references with  respect  to  hazardous   waste. Even
those  references  which   originated  from  the field  of
hazardous waste management might not be appropriate for
the  particular  hazardous   waste  being   studied  due  to
differences  in  the properties of the  waste.  Nevertheless,
when  applicable,  the references  do provide  information
which can assist in the further development of the decision
model.
     As  mentioned  previously,  hazardous  waste  can
threaten air, soil, and water resources. Because of properties
unique to municipal refuse,  there has not been a need to
consider  air,  soil,  and  surface  water  contamination.
However,  these  types  of   pollution   have had  to  be
confronted  by  other  branches  of the  environmental
protection field. The research, techniques, and technologies
developed  to  manage  these types  of  pollution can  be
important contributions to the decision model developed in
this  paper.  Moreover,  the  references  cited  have  been
carefully selected to provide a basic understanding of how
the problem has been approached by these other branches.
     There is  a   need  to  research  and  develop new
methodologies appropriate for use in the decision model.
The modification  of  the  decision  model  will  require
expertise drawn  from many disciplines. By its very nature,
the overall  hazardous waste  management field builds on
many  disciplines,   ranging from toxicology to chemical
engineering. Therefore, the  land disposal  aspects of the
hazardous waste management field will need to build on
many fields  in order to develop properly.

RESULTS

      The intent of this paper is to emphasize the need for
a  systems  approach to  the design and review  of land
disposal facilities. Work in the field of  land  disposal  has
concentrated almost exclusively on groundwater resources.
However, more  emphasis  should be  placed on air, surface
water, and soil resources.
      It would be a mistake to devote an inordinate amount
of time evaluating the effect of a given land disposal facility
on one medium while neglecting a more serious effect on
another medium. In addition, there is often a tendency to
avoid  an  evaluation  until after a problem  has arisen, at
which  time, unfortunately, it  is difficult to correct.
      Figure 1 represents an overview of  the decision model
which  considers the  need for a balanced evaluation. The
text expands and  comments on the individual  sections of
the model and provides some  guidance about considerations
that might  be raised in expanding the model for  practical
application. Admittedly, the  absence of research will make
practical application of such evaluations difficult.
      The overview of  the  decision model  illustrates  the
necessity to consider: the interaction of the properties of
waste; the environmental setting, design and operation of
the facility; and meteorology. Clearly, one must consider a
wealth of data  before  drawing analogies between  any  2
situations.  This factor  makes  developing  a cookbook
approach to  land  disposal  of  chemical wastes  difficult.
Consequently, one  can  expect that the review of most land
disposal facilities will be conducted on a case-by-case basis
until  the necessary  research and performance data have
been gathered and disseminated.
                                                       -253-

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                                                                  FIGURE 1
                                                        DECISION MODEL OVERVIEW
                     Meteorology
Environmental
   Setting
                                        Facility
                                      Design and
                                      Operation
  Waste
Properties
                                                                              1
L 	 J* r "i "! %
Ur
ality
jation


Ground Water
Quality
Evaluation
1— )
!r»
Surface Water
Quality
Evaluation
•
^•-)
r^
f
Soil
Quality
Evaluation
£
                                     Surface Water
                                        Quality
                                         Data
Ground Watei;
  Quality
    Data
                                            Ground Water
                                             Standards
                                                                                                                                        Is
                                                                                                                                   Soil Quality
                                                                                                                                   Acceptable?

-------
     The decision mode! proposes to  use  air  emission
standards. National Pollutant Discharge Elimination System
(NPDES) discharge standards, etc.,  as a means for judging
the performance  of  land  disposal  facilities.  Because  a
significant portion  of these wastes arises from waste-water
treatment and emission control equipment, these standards
are not totally   unjustified.  However,  there are  other
circumstances in  which these standards would be difficult
to justify. The applicability of  such standards to  land
disposal  facilities  has  not been  adequately defined,  and,
consequently, a real "knowledge gap" exists in this  area.
However, such standards,  because they  function  as  a
criterion for what is  acceptable  to man and other living
organisms, are  valuable.  Without  such standards, there
would be no means by which to protect  man and organism
alike  from becoming, as  is  the case with media already
mentioned, ultimate receptacles for hazardous waste.

DISCUSSION

      A decision  model  for determining whether a  given
land disposal facility is environmentally acceptable should
ideally consider both qualitative and quantitative standards.
 In many areas of study, the hazardous waste management
 field  has not advanced  to  the point at  which technical
 standards  can  be set.   Even  in  cases where  technical
 standards can be established, environmental conditions that
 prevail  in different  geographical  areas  would  necessitate
 variations  in  the standards.  Consequently,  the decision
 model   proposed  herein   is   a   generalized   one   to
 accommodate improvements in knowledge and adjustments
 for geographical differences.
       Wastes or solutions of wastes can  be released from a
 land  disposal site to 4 major media:  air, soil, groundwater,
 and surface  water. The probability  that  wastes or solutions
 of wastes are likely to be released  to those media depends
 on a number of factors including:

    .   The biological,  chemical,  and physical  properties of
       the waste;

    •   The design  and operation of the facility;

    .  The  environmental setting in which  the facility is
       located; and

    .  The meteorology at the location of the facility.

       The above factors, therefore, become the basic data
  base  by which  a facility is designed and evaluated. The
  more understanding we have of these factors and how they
  interact, the  better basis we will  have for designing such
  facilities. Obviously,  there  must also be a balance between
  the   effort  necessary  to  gather  information and  the
  improvement which  can be made in the design of  the
  facilities as  a result of the data collected.
Air Quality Considerations

      Generally, the  design  and operation of  municipal
sanitary  landfills has not resulted  in a significant impact
upon air quality. This  can largely be attributed to  the
properties  of  municipal  refuse  and  the way in which
municipal  refuse  responds   to  the landfill  environment.
Obviously, chemical wastes can have many properties which
could make them a problem at a land disposal facility if
adequate compensating controls were not instituted. There
is a  need to  assess whether particular wastes consitute a
threat to air  quality,  to determine what operation  and
design  controls  are  necessary,  and  to  determine what
impact  the acceptance of specific wastes would have on air
quality.
      The field of land disposal has directed little research
toward evaluating  landfills  as a source of emissions and,
hence,  little has been  done to define the best approach.
 Figure  2 represents  the framework by which  one  could
approach  such an  evaluation.  Within  this  proposed
framework, 3 basic  factors interact to form the building
 block of the  evaluation: the properties of the wastes, the
design and operation of the facilities, and the meteorology.
 The properties of the wastes and the design and operation
 of the facilities are factors which can be controlled by man,
 whereas the meteorology is largely uncontrollable. For this
 reason,  the framework makes a clear distinction among
 each of the factors and emphasizes the need to consider the
 adequacy  of  the  design   and operation  of facilities  in
 relationship to the properties of the wastes.

 Determining   if a  Waste  in  the Landfill  Environment
 Produces an Emission

       To detemine whether a waste will  produce  an air
 emission when disposed of  at a  given landfill, one  must
 establish whether the  facility is designed or operated in a
 manner which allows or causes the waste to give rise to such
 an emission.  This is a difficult task because any number of
 factors can interact to create emissions.
       The waste itself  may be so constituted that it readily
 gives rise  to mists, vapors, or gases. Assuming that the
 emission should be  controlled, the assessment would then
 focus  on means by which the facility could  control the
 waste. The most suitable remedy in these cases would be to
 change  the   properties of  the  waste  to  eliminate the
  emission. If this can be done, an emission collection system
  and/or gas  migration barrier similar  to those used for
  methane recovery and control  at sanitary landfills could be
  utilized (1).  Such  an emission control system should be
  recognized  as being  uneconomical unless the gas  being
  generated is itself of economic value.
       A waste may also have properties which result in air
  emissions  during  facility  operations  or arise due to the
  landfill  environment  in   which  it is placed. The most
  common  example  of  an  emission  caused  by  facility
  operations  is that of  dust from earthwork and  waste
  materials.  The use of operation  controls such as surface
  retardant, additional  moisture,  or special  packaging can
                                                          256-

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                                        FIGURE 2

                               AIR QUALITY EVALUATION
  Properties
  of Waste
Facility Design
and Operation
                                    Determine if Waste
                                   Produces Emission in
                                   Landfill Environment
                                                                                  No
/Meteorological
Conditions

7 ^
J >
Determine Expected
Emission and
Dispersion of It
>
f
                                                                                Facility
                                                                               Adequate
                                      Air Emissions
Air Quality
 Standards
    Yes
                                         Facility
                                       Inadequate
                                         -256-

-------
effectively minimize these problems. If the waste is slurried
into the landfill, careful planning of the discharge locations
and adequate freeboard allowances are necessary to provide
standing water over the waste.
      Perhaps the most difficult problem in controlling air
emissions is  assessing the possibility of emissions as a result
of  the  interaction  of   the  waste  with  the  landfill
environment. The landfill  environment can alter the ability
of the waste to act  as a source of emissions.  For example, if
calcium sulfate wastes from the manufacture of wallboard
and ceiling tiles are placed in an anaerobic environment of a
landfill, the sulfate can be reduced to sulfide, ultimately
causing the formation of toxic hydrogen  sulfide gas. Many
other avenues also  exist for such chemical reactions  in the
landfill  environment.  For example,  wastes  can undergo
oxidation  or reduction as  a result of chemical or biological
factors,  react  with other   wastes,  or  be  subject  to
photochemical  oxidation. Even  some  elements such as
arsenic  and  mercury  can  be  incorporated  into  volatile
organometallic  compounds   by  microorganisms   (2).
Consequently, considerable care must  be  taken to evaluate
how  the  waste   may  interact  within  different  landfill
environments  and  to select disposal  conditions which are
least likely to cause emissions.

Determining Amount, Rate of  Release, and  Dispersion of
Emission

      Quantifying   the  amount  and  rate  of release of
contaminants into the air entails a thorough review of how
the contaminants  are released from the  facility, and how
they interact with the environment after release.
      Research on air emissions from land disposal facilities
is meager. The dearth of  such research could be construed
to  imply  that air emissions do not present  a problem;
however, this lack of research is more indicative of the lack
of  emphasis  placed on  this  subject. The  lack  of data
strongly argues that theoretical means and/or empirical data
from laboratory- or pilot-plant scale testing should be used
to predict the  amount and rate of  release.  After  this has
been  done, one could select a method from the field of air
pollution control to predict the dispersion of the emission.
      Presently  there  are no established  procedures for
determining the amount  and  rate of release of emissions
from a landfill. The number  of published  studies  which
might serve to  develop the basis for such  procedures  is
limited (3,4).  Consequently,  the  design  of  bench- or
pilot-plant scale testing must usually  be considered on  a
case-by-case  basis. The design  for  such testing could be
based on  theoretical  relationships,   even  though  such
relationships  are   often   qualified  by  assumptions  and
boundary conditions that severely limit  their applicability
to field conditions. For example,  fluid mechanic equations,
based on  particle  size,  density, shape, and  potential wind
conditions,  could  be used to evaluate the potential of  a
waste to  create   dust.  The  results  of  the theoretical
evaluation could  then be used  to  dismiss the need for
further investigation or  serve  as the basis for designing
experimental conditions.  Similar approaches  could be used
in many other circumstances.
     Admittedly, circumstances  arise which do  not lend
themselves  to   an  approach   based  on   theoretical
considerations,  e.g., when gases  result from chemical  or
biological reactions  in the landfill environment. In these
cases,   pilot-plant  scale  simulation   of   the  landfill
environment would be a means for generating information
(5). Such time consuming testing is impractical, particularly
if  the waste is  presently being produced  and  must  be
disposed of. A  more  practical  approach  would be  to
develop  monitoring at existing  operations and  use that
information as a basis for establishing  design criteria and
planning operations.

Ground Water Quality

      The control and reduction of ground water  pollution
has been the focus of concern in the design of most existing
land disposal facilities. Consequently, there is more research
and   experience  to  draw  on  in  investigating  this
environmental concern than, for example, in investigating
potential air quality problems.  This observation will  be
reflected in a  more comprehensive  discussion related  to
methodology and approach.
      The discussion in this paper considers the discharge of
leachate to ground water. The discussion of the decision
model,  however, should  not be construed to represent an
advocacy of such discharges, but rather a recognition that
discharges  can,   and do, occur.  Because such  discharges
occur, and  because little has been said or written about
what is acceptable for discharge and where, leaves the entire
concept  of  land disposal  somewhat  in question. It  is,
therefore, essential  that  land disposal  designers begin  to
explore  and raise more explicitly the question of discharge
to ground water.
      Figure 3  illustrates the basic  framework  that one
could use to approach the problem  of waste discharge to
ground  water. Even though research and emphasis has been
placed  on  this  problem, the model remains under the
general  format  for air quality evaluation. There are 4 major
contributing   factors   regarding   the  evaluation: the
properties  of the  waste, the design and  operation, the
facility,  the hydrogeologic setting, and the meteorology.

The Rate of Leachate Production and Leachate Quality

      The rate  at which leachate can be produced at a given
land disposal facility can be  estimated by means of a water
balance. It is beyond the scope of this paper to review the
entire methodology of water balance. Readers unfamiliar
with  water  balance may  refer to any one of a number of
publications on  water  balances  (6)  for sanitary landfills.
Herein  we  discuss some of the considerations  not often
associated with water balance.
      The existing water  balance at a land disposal facility
can  be used to estimate the rate of infiltration of water into
the buried bed of waste.  The rate at which  that water will
emerge as leachate at the bottom of  the bed depends on a
number  of factors, including the following:

   •  Moisture content and field capacity of the waste;
                                                        -257-

-------
   Properties
    of Waste
                                           FIGURES

                                GROUNDWATER EVALUATION
    Facility Design
    and Operation
Meteorology
                                       Determine Rate of
                                      Leachate Production
                                    and Quality of Leachate
                                                                                       No
                                             Yes
Environmental
   Setting
Evaluate Engineering
 and Site Controls
 Facility
Adequate
 Groundwater
  Standards
        Is
     Leachate
     Discharge
    Acceptable?
                                           Facility
                                          Inadequate
                                            -258-

-------
  •  Hydraulic gradient across the bed of waste;
  •  Channeling through the bed; and
  •  Permeability of the bed.

     Treatment or  handling of the waste  in  a  manner
which  would  cause these  factors  to  minimize leachate
production should, therefore, be a  design consideration.
These factors  influence not only the quantity of leachate
produced  but  also the quality produced. The amount of
contamination released in leachate  often depends on the
contact time between the waste and the water. Thus, in
some circumstances, one might promote channeling and/or
rapid flow through the bed to produce a less  concentrated
leachate. In other cases, one  might  minimize permeability
thereby reducing leachate production.
     The  quality  of  leachate  which  develops under
conditions found in a landfill  environment cannot be easily
predicted.  A  set  of standardized  procedures  should  be
developed  to  enable  a  designer   to  simulate  landfill
conditions and produce representative leachates.  A number
of such  tests  have  appeared  in  the  technical  literature
(7,8,9,10,11).  To decide whether to conduct any such tests
is primarily   a  matter  of   professional  judgment.   For
example, it would not be appropriate to conduct a test for
solubility  when the waste produces leachate only as a result
of biological degradation by microorganisms.  In  selecting a
leaching procedure, the following considerations should be
reviewed and considered:

   •  Activity of microorganisms and resulting intermediate
     and final degradation products;

   •  Reactions  that  might  result  from  co-disposal  with
     other wastes;

   •  Oxidation  initiated by exposure to sunlight;

   •  Contact  or  detention  time  of  liquid in  tests in
     relationship to field conditions;

   •  Solubility  or competing reactions, particularly those
     reactions which  result in changes  in concentrations of
     contaminants at  later stages of leaching;  and

   •  Dilution of liquid wastes by test procedures.

 Many  of  the  foregoing  items  can  be considered  by
 modifying referenced  procedures.  In  other cases,  larger
 pilot-scale test cells such as  those that have been used to
 study  municipal refuse might be useful and warranted (5).
     Whether the rate of leachate production or quality of
 leachate  predicted by utilizing leaching tests  and  water
 balance is as  representative  as that  leachate  which would
 form under field  conditions  is certainly subject to further
 investigation.  In conducting leaching tests for this purpose,
 it would  be  beneficial to determine the  leachate under  a
 variety of conditions to provide perspective on the range of
 leachate  quality  that could be  produced, 'information
 obtained  in  this fashion  could then be projected  and
 utilized for a  more thorough  evaluation of the impact that
 the facility would have on groundwater.
Engineering Controls

      Engineering  controls  are  often  utilized  at  land
disposal facilities as a means for improving leaching quality
and controlling the amount of leachate  discharged  to the
groundwater. There is also a tendency to use such controls
to  compensate   for   an  otherwise   marginal  natural
hydrogeological  setting. Inasmuch as  wastes are seldom
placed in a land  disposal  facility for later  recovery, the
difficult question arises as to how to design such controls to
withstand  the passage  of decades  or  centuries.  This is
particularly true  in  situations where  the  potential for
production of leachate  from the waste does not diminish
with time.
      There are no absolute assurances  that engineering
controls  will  not fail.  Thus,  possible  failure must  be
considered in the design and  evaluation of the potential
impact  of  the  facility  on  groundwater   quality.  This
consideration  becomes  more  important  when engineering
controls  are  utilized  to  compensate  for  an  otherwise
marginal hydrogeological setting in an area where usable
groundwater   is  a   valuable  resource.   Under   such
circumstances it becomes difficult to justify locating the
facility  in  that  area.  Thus,  this paper  should  not  be
construed  as  advocating such  locations unless no other
alternative exists. In such a  case, the facility  should  be
located in a groundwater discharge so  that groundwater
contamination,  if  it   occurs,  can  be  restricted   and
controlled.
      Figure 4  represents  a  layout  of  some of the  most
common engineering controls.  A control  which is often not
emphasized enough  is a clay or liner cover depicted in
Figure 3. Although covers  will not be discussed any further
here, they do represent one of the most effective means of
reducing  leachate  production by minimizing infiltration.
Between the bottom  grade of the waste and the underlying
soil,  several  different  engineering controls  are used, the
most common  being  treatment beds, leachate collection
systems, and liners.
      Treatment beds are not commonly used in the design
of  land  disposal  facilities, although they are  gaining in
popularity. Treatment beds are subject to many of the same
influences  which  affect  leachate  production  as  water
percolates   through  waste  (12,13).  Consequently,  the
research used in developing leaching tests might also apply
to estimating the  degree of treatment provided by the bed.
The design of the tests should be such that they consider
the following:

   •  Varying rates of leachate infiltration;
   «  Fluctuations in leachate quality;
   •  Hydraulic gradient through the bed;
   •  Permeability of the bed;
   •  Channeling through the bed;
   •  Rate of treatment reaction;
   •  Capacity for treatment;
   •  Reversibility of reaction.

The conditions of the tests should be such that both normal
and extreme  operating conditions are examined so that a
range of treatment results can be prepared.
                                                        -259-

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                                      FIGURE 4

                               ENGINEERING CONTROLS
Earth Cover
   With
Vegetation
  Clay or
   Liner
   Cover
  Clay
  Liner
 Chemical
Treatment
   Bed
                                      Leachate
                                     Collection
                                      System
                                       -260-

-------
      Leachate  collection  systems and liners  have  the
primary purpose of reducing the amount of discharge to the
underlying soil. This is  accomplished  by minimizing  the
hydraulic gradient which the leachate  can  create across a
liner. Of special interest  in evaluating these systems  is the
ability of these engineering controls to resist degradation by
the leachate. Data on the resistance of  liner and collection
system equipment are availablefrom various manufacturers.
In addition, independent tests have been conducted by the
Environmental  Protection  Agency  on  liner   materials
(14,15).  The  latter  studies also provide an experimental
design for testing liners which might be  useful in those cases
where it  is warranted.
      The  ability  of  liners to  provide treatment  varies
considerably depending  on the  materials they consist  of.
Polymeric and artificial  liners are not normally considered
in terms of their treatment  ability,  but  might provide
filtration for suspended  solids or colloids. Clay liners can
provide additional treatment by ion exchange, adsorption,
and  similar  soil mechanisms, but this may adversely  affect
the permeability of the liner. For example, calcium ions in
the leachate from  lime sludges can replace the sodium ions
in some clays,  thus  reducing  swelling of  the  clays (16).
Bench scale testing for treatment could be carried out with
experimental designs  similar to those used for studying the
integrity  of the  liners.   To this end,  it is important to
consider the potential discharge of leachate directly upon
the underlying soils.
      The soil beneath land disposal facilities has been and
should continue to  be a subject on which  a great deal of
attention is placed during the site  selection process. Land
disposal  might benefit from proper soil selection in 2 ways.
First, soil can effectively limit the amount of discharge to
the underlying groundwater. Secondly, individual soil types
might effectively improve the quality of leachate.
      The term commonly used to denote the effectiveness
of   the   soil  in   limiting  percolation is  permeability.
Permeabilities  of  10~~^  cm./sec. or less are often cited as
the   most  desirable for soils  underlying  land  disposal
facilities. Without an explanation of how the permeability
test  was conducted, however, a  specific  level such  as
 10~7cm./sec. is  virtually  meaningless.  In  reviewing such
permeabilities,  it  is important  that the  test  used  in
conducting the permeability  investigations consider  the
following (17,18,19,20,):

   •  Disturbed  soil samples  will not  distinguish  major
      differences   between   horizontal   and  vertical
      permeabilities which can occur;

   .  Permeability  is dependent   on  the  viscosity  and
      density of a leachate;

   •  Disturbed soil samples  will not demonstrate  the
      secondary permeabilities that occur in the field;

   .  Permeability of soil can  be  altered by ion exchange
      with contaminants in leachate;
   •  The accuracy  of methods  used to determine field
     infiltration must be considered;

   •  The potential for layers of high permeability sands or
     gravels in the soil must be considered; and

   •  The rate of flow of leachate is affected by the area
     over which the hydraulic gradient is exhibited.

Consequently, permeability measurements taken without
the study of soil samples and without knowledge about the
effect of leachate on the chemistry of the soil are of limited
value.
     The improvement of the quality of leachate  by the
soil  is  often  misunderstood and misrepresented.  More
emphasis must be placed on considering soil to be a mixture
of chemicals,  rather than  merely an  inert  medium  for
limiting percolation. The various mechanisms by which soil
can improve leachate quality  (by  removing contaminants)
has   often  been   termed   "attenuation".   The   word
"attenuation" implies that the contaminants in the leachate
are permanently removed and held by the soil. This is not
always   the   case.  The  removal  of  contaminants  by
adsorption can be an equilibrium condition which serves to
modify the quality of discharge, but results  in the same
amount  of contaminants being released.  In such cases, the
word "attenuation" creates a misconception  and perhaps
the word "retardation" or  "inhibition"  should be used in
its place.
      The characteristics of soil which are most commonly
associated  with  providing  an improvement  to leachate
quality are the following (21,22,23,24,25);

   •  Soil alkalinity;
   •  Soil acidity;
   •  Ion exchange capacity;
   •  Adsorption;
   •  Absorption;
   •  Filtration; and
   •  Organic content of the soil.

Although these characteristics can improve the quality of
leachate, they also have disadvantages. For example, ion
exchange  and  absorption  can  inhibit  and  reverse  the
swelling of  clay  soils,  thereby  increasing  permeability.
Consequently,  knowledge  of  the  chemistry  of  the
underlying  soils  is not only essential for predicting the
quality of leachate discharged to groundwater, but also for
predicting the rate of flow.
      The  composite  result of the evaluations  utilized in
this approach is a prediction of  the  effect  or potential
effect the land  disposal facility will have on groundwater.
 Unfortunately,  the  literature contains  only a  minimal
number of cases which  indicate  how such predictions can
be made. The State of Oregon, among others, has published
a theoretical modeling approach to making such predictions
 (26).  Empirical  approaches  based on  leachate and  soil
testing could  be used to make predictions, although there
                                                        -261 -

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are no  specific examples in the literature  to which  the
reader can be referred.  In either case, predictions should be
carried  out  for  normal  operating  conditions  and  for
conditions  which  would  result  from  failure  of  the
engineering controls.

Surface Water Considerations

      Situations that  could  result  in  contamination  of
surface  waters  in  the  vicinity of land disposal facilities
include  the following:

   •  Contamination of surface water runoff as a result of
      contact with wastes or contaminated surfaces;

   •  Direct  contamination of surface water as a result of
      the dispersion of air emissions;

   •  Local discharges  of contaminated groundwater; and

   •  Accidental discharges from spills.

Of these   situations,  the contamination of  surface  water
runoff  occurs most  frequently. The situations in which
either air  emissions or groundwater  discharges are sources
of   contamination  are  rather  specialized  cases,   and
consequently, lie outside the scope of this paper. However,
predictions  of  the   dispersion  of air   emissions  and
groundwater  discharges  mentioned  previously  would  be
necessary before the situations could be considered.
      Any number of incidents  could occur  at  a land
disposal facility that  would  result in spills of hazardous
materials.  The  probability  of such  incidents occurring is
much higher in some locations such as at unloading docks,
than  in others.  Even if special spill protection controls  are
installed in these  areas, the problem of retaining spills in
other areas still exists. Because  of this, the design of the
facility should  incorporate a  system  which confines such
spills, as well as the runoff carrying spilled materials, to the
facility itself.
      The framework  (Figure 5)  for  carrying out  the
evaluation of surface water is based  on  the premise that a
facility should  be  designed in a manner which effectively
contains  all  surface water runoff,  and,  consequently, any
accidental spills.  As a result, the facility  must contain
provisions for  evaluating the runoff  once  it has been
collected.  Admittedly,  there are circumstances where such
evaluations would  not  be needed,  but it is important that
the potential for such  problems not be dismissed without
due consideration.

Determining the Amount and  Quality of  Runoff

      Of the 2 tasks undertaken here, the task of estimating
the quantity of runoff is more precisely defined than that
of predicting the quality of runoff (6). This is because it has
been  necessary to estimate runoff quantity for other types
of engineering projects, such as the design of storm sewers
(27). As  a result,  methods have been  developed and are
available  for use.  Rather than  review  these  methods, it
would be  more useful to review how the characteristics of
runoff affect the quantity of runoff.
      There are basically  2 means by which runoff can
become   contaminated: runoff  can   either  dissolve
contaminants or can suspend them. (The amount of runoff
in contact with soluble contaminants obviously affects the
quality  of leachate.)  However,  because  such dissolution
processes depend on time, the velocity of  the runoff must
also   be considered.  The  velocity  of  the runoff  also
determines how much waste is suspended. Thus, the quality
of runoff  depends  on the characteristics of  the runoff,
particularly the amount  and  velocity. These factors,  of
course,  differ with each storm and the characteristics of the
facility.  Among  the   most  important  factors  are  the
following:

   •   The intensity of the rainfall;
   •   The duration of the rainfall;
   •   The type and density of vegetation;
   •   The infiltration into surface soils;
   •   The retention in surface depressions;
   •   Evaporation; and
   •   Transpiration.

Consequently, runoff quality will fluctuate depending on
the characteristics  of the storm and the facility.
      The  number of  variables affecting the amount and
velocity of runoff,  not to mention  the properties of the
wastes,  makes any attempt to predict actual runoff quality
for given storms difficult. The number of variables would
also  suggest that the statistical accuracy of the predictions
would not be reasonable for the amount of effort needed to
accomplish the task. The most practical approach would  be
to place engineering controls on the runoff and to design
these  controls  to  meet  situations  which  represent   a
probable worst quality of runoff. Such a case of  probable
worst quality would have to be developed by evaluating the
operations and design  of  the  facility, the various wastes
accepted,  the  effects  of  different  storms,   and  the
probability  of different   situations  occurring; the latter
becomes a matter  of professional judgment and experience.

Evaluation of the Effectiveness of Facility Controls

      The effectiveness of runoff controls at  a facility is
judged  by  whether the controls  result in  runoff  which is
suitable  for discharge.  Many such controls are  in effect
operating in capacities  analogous to  those of  waste-water
treatment plants and are  capable of  being evaluated  with
the same design theory that waste-water  treatment plants
are evaluated. It should be evident that any evaluation  of
the runoff controls  at a facility, employing this theory, is
only  as valid as  the  information regarding the influent
runoff stream. This suggests the need  to assess the  probable
quantity and quality  of  runoff  under   a multitude  of
conditions that permit a  perspective to be gained on the
effectiveness of the controls.
      If a quantitative approach is to be developed, it must
consider the various mechanisms by which contaminants
can  be  released  from the soil.  Surface water runoff,
percolating  precipitation,  eroding  winds,  and  covering
vegetation  can remove  contaminants. The evaluation must
also  consider the ability of microorganisms in the soil  to
degrade the contaminants.
                                                       -262-

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Meteorology
             FIGURES

EVALUATION OF SURFACE WATERS




               Waste
  Discharge
 Standards
                                      Determine Amount
                                         and Quality
                                          of Runoff
                                             Are
                                         Engineering
                                          Controls
                                         Necessary?
                                         Evaluate the
                                        Effectiveness
                                         of Runoff
                                          Facility
                                         Inadequate
 Facility
Design and
Operation
                                                       No
                                                      Facility
                                                     Adequate
                                                       Yes
                                          -263-

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Soil Quality Considerations
SUMMARY AND CONCLUSIONS
      The most obvious question is whether the problem of
soil  contamination  in  the vicinity of land disposal  is a
problem which warrants consideration, and if so, how much
consideration. Research on the effects of wastes on surface
soils and vegetation  is sporadic. Whereas information about
the  effects  of   sewage  sludge,  metals,  waste oil,  and
pesticides is available, little  can be found  regarding most
other types of wastes. Given the wide range of substances
found in  wastes, it  is conceivable  that the operation of a
facility could cause  soil  contamination sufficient to make
adjacent   lands  unusable   for   agricultural  purposes
(28,29,30).  The  lack of research appears to be inconsistent
with  the  fact that  land  disposal  facilities are  located in
agricultural  areas. Clearly,  the resources offered by the soil
should not be dismissed as readily as they have been in the
past.
      Land  disposal, in the  context in which  it has been
considered in this paper,  is subsurface burial and does not
include such land treatment  techniques as spray irrigation,
soil cultivation,  or disking. Contamination of surface  soils
at land disposal  facilities is, therefore, not intentional, but
rather arises from air emissions, contamination of surface
water, runoff and spills. The differentiation has the obvious
effect  of causing the degree of soil contamination to be
directly  influenced  by  the occurrence of these 3 events.
Any estimation of the amount  of soil contamination would
have to be based on projections of the air emission and the
contamination   occurring  to  surface   water   runoff.
Admittedly,  the  methodologies are not developed to the
extent desirable, and the accuracy of any estimate would be
questionable.  Consequently,   a   review   of   the  soil
contamination at this time  must be qualitative, although
the approach in Figure 6 is more quantitative in nature.
      If a quantitative approach were to be developed, it
must  consider  the  various  mechanisms  by   which
contaminants can be removed from the  soil. Research on
biodegradation of waste oil  indicates that microorganisms
might effectively consume organic contaminants, thereby
eliminating  toxic accumulations  in  the soil.  There  are
situations  where   surface   water  runoff,  percolating
precipitation, and eroding winds may cleanse the soil of
contaminants, but  only at the expense of contaminating
other  media.   In   addition,   vegetation  can   extract
contaminants, but in doing so, often provides a means of
channeling them into the food cycle.
      More  emphasis should  be placed on this  subject and
more  research dealing  with the  effect  of land disposal
facilities  on  adjacent   soils  should  be  conducted to
determine whether a problem exists. A major problem that
would  be   encountered   is  that  the  subject  of  soil
contamination does  not easily lend itself to generalization.
The response of  soil to a given amount of contamination
can   vary  considerably,   depending  on  soil   chemistry.
Furthermore, the response of vegetation to contamination
in  a  given  soil  can vary significantly  between species.
Conceivably, almost every case could be so different  that
testing  might   have to   be  conducted  with  particular
attention to the waste, soil, and vegetation. Thus, it would
appear that such  evaluation and research would have to be
carried out on a case-by-case basis for each facility.
      Despite  the  fact that  chemical  wastes have  been
produced in large quantities for many decades, there is still
much to learn about how to dispose of such wastes on land
properly.  Considerably more effort must be devoted to this
subject if this problem is to be adequately addressed in the
near future.  If that effort were extended,  it is hoped that
this  decision  model could serve to provide  direction  to
research and result in a better balanced effort.
      Admittedly, considerable development  will  have to
occur  before the  decision model  could  be commonly
utilized. This development is not  confined to technological
areas, but applies also to  administrative and  management
aspects of the field. Among the most important of these are
the following:

   •  Presently  there  are significant  differences  in  the
      requirements  that  individual states apply  to land
      disposal which cannot be explained by environmental
      considerations. It would be desirable to obtain more
      uniformity among the states in this respect.

   •  The  applicability of Federal  and state  standards in
      other environmental areas,  such  as  air  emission
      standards,  to land   disposal  is  presently  a  rather
      confused  matter.   If   these  standards  are  not
      applicable, then some applicable  standards should be
      developed  to   provide  a  means   of  measuring
      performance.

   •  Facility  managers   tend  to  view  environmental
      monitoring as an expensive  nonproductive part  of
      landfill   operation.   To   designers   however,
      environmental monitoring  provides  the  only true
      measure  of successful  facility  development.  Thus,
      there is a need for more and better  monitoring, in
      most cases, to provide a basis for evaluation.

   •  More emphasis must be placed  on  evaluating the
      means for disposing of a hazardous waste before it is
      produced in a large quantity.  It would be desirable to
      have all new chemical wastes evaluated during the
      research   and   development   stage  of  process
      development, in  order  to determine  what must  be
      done to dispose of the waste properly.

      In summary,  it is important to convey the view that
the decision model  does have  applicability to  other wastes
besides those classified as  hazardous. The fact that a waste
is not hazardous does not mean that it  does not represent a
threat   to the   environment, especially   if  improperly
managed.  Any set of properties used to classify wastes as
hazardous must  be  a matter of professional judgment, and,
consequently, cannot  be  inclusive  of  all  of those wastes
which  cause  environmental problems.  Thus,  determining
whether  a waste  is hazardous or  not is  only  a part  of
evaluating  how to dispose  of the waste,  regardless  of
whether it is hazardous.
                                                      -264

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                                         FIGURE 6

                               SOIL QUALITY EVALUATION
     Air Quality Data
Groundwater Quality Data
Surface Water Quality Data
         Facility
        Design and
        Operation
  Waste
Properties
                                     Determine Amount
                                           of Soil
                                       Contamination
                                      Soil Quality Data
Soil Quality
  Criteria
     Is
    Soil
  Quality
Acceptable?
  Facility
Inadequate
                                           -265-

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ACKNOWLEDGMENT

      My  sincere appreciation to Mr. Samuel  Hasson who
fought  courageously  to   protect  the  English   language
throughout the writing of this paper.
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  2.  Parris,  G. E. and  F.  E. Brinckman. 1976. Reactions which
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  3.  Markle, R.  A.,  R. B. Iden, and  F.  A. Sliemers.  1976. A
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  4.  Farmer, W. J., M. Yang, and J. Letey.  1976.  Land disposal of
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  5.  Streng, D. R. 1976. The effects of industrial sludges on landfill
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  6.  Fenn,  D. G., K. J. Hanley, and T. V. DeGeare. 1974. Use of a
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  7.  Lee, G.  F., M. D. Piwoni, J. M.  Lopez, G.  M.  Marian!, J. S.
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  8.  Hespe. E. D.  1971. Leach testing of immobilized radioactive
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 11.  Mahloch, J. L. 1976.  Leachability and physical characteristics
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          contaminants  in  leachate   from   industrial   sludges.
          Proceedings  of  the  Hazardous   Waste   Research
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         EPA/530/SW-137, Washington. D.C., p. 66.

16.  Hughes, J. 1975.  Use of bentonite as a soil  sealant for leachate
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17.  Anonymous. 1972. Groundwater hydraulics. U. S. Geological
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18.  Reeve, R. C.  1965.  Hydraulic head. Methods of soil analysis.
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19.  Klute,  A.  1965.  Laboratory  measurement   of  hydraulic
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         Madison, Wisconsin, pp. 210—221.

20.  Boersma,   L.  1965.   Field   measurements  of  hydraulic
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         analysis.  Madison, Wisconsin, pp. 222—233.

21.  Korte, N. E., I. Skopp, W. H. Fuller, E. E. Niebla, and B. A.
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         122:350-358.

22.  Gloyna, E. F.. and R.  L. Somks. 1977. Suitability of clay beds
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          Industrial Waste-Waters and Residuals. Houston.

23.  DeVries,  J. 1972. Soil filtration of waste-water effluent and
         and  the mechanisms for pore clogging.  Journal  of the
         Water Pollution Control  Federation  44:565—573.

24. Wentink,  G. R., and I. E. Etzel. 1972. Removal of metal ions
          by soil. Journal of the Water Pollution Control Federation
         44:1561-1574.

25.  Griffin, R. A., K. Cartwright, N. F. Shimp, J. D. Steele, R. R.
         Reich, W. A. White, G.  M. Hughes, and R. H. Gilheson.
         1976.  Attenuation of  pollutants  in municipal landfill
         leachate  by  clay minerals.  Environmental  Geology Notes,
         Illinois   State  Geological  Survey,   Springfield,  p. 34.
26.  Elzy, E. T., T. Lindstrom, L. Boersma, R. Sweet, and P. Wichs.
         1976. Analysis of the  movement  of hazardous waste in
         and from a landfill  site  via a simple vertical-horizontal
         routing  model.  Oregon  State University,  Agricultural
         Experiment  Station   Publication.   No. 414.  Corvallis.
         p. 109.

27.  Anonymous.  1970.  Design  and construction of sanitary and
         storm  sewers.  American  Society  of  Civil  Engineers,
         Manual and Reports on Engineering Practice, No. 37. New
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28.  Purves, D., 1972 Consequences of trace element contamination
         of soils. Environmental Pollution  131: pp. 17—24.

29.  Anonymous,  1976. Application of sewage sludge to cropland:
         Appraisal of potential hazards of the  heavy metals to
         plants and animals. Council for Agricultural  Science and
         Technology Report, No. 64. Ames, Iowa, p. 63.

30.  Chaney,  R.   L., Metals in  plants:  Absorption mechanisms,
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         Proceedings on  Land  Resource  Science.  University of
         Guelph,  Guelph, Ontario.
                                                              - 266-

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                              A QUANTITATIVE APPROACH TO CLASSIFICATION
                                            OF HAZARDOUS WASTE

                                      L. C. Mehlhaff, T. Cook, and J. Knudson
                                             Hazardous Waste Section
                                              Department of Ecology
                                                  Olympia, WA
     We have  developed in the  State of Washington a
classification system for hazardous wastes which is entirely
consistent with  existing definitions,  but because  of its
quantitative basis the system allows a simple, realistic assay
of the hazard associated with a waste.
BACKGROUND

      The Washington Legislature passed a hazardous waste
bill in March 1976 requiring the Department of Ecology to
adopt  regulations   for  the  designation of  extremely
hazardous  waste. The definition of extremely hazardous
waste included the concept of a category  called dangerous
waste, of which extremely hazardous waste was  a subset.
 Extremely hazardous waste was to be distinguished from
dangerous   waste   because   of  ". . . persistence,
 bioconcentration or genetic effects, and extreme toxicity,
or because such quantities  present an extreme hazard to
 man  or wildlife." Extremely hazardous  waste was to be
 disposed of only at a site in  eastern Washington owned by
 the  state and  operated  by a  contractor, or was  to be
 detoxified.
       To avoid possible catastrophic criticism at the public
 hearing  of the regulations,  the  Department  decided to
 develop  them  through  an  ad   hoc  committee.  This
 committee consists of 28 persons who represent as many
 facets of  the waste  management community as could be
 justified on  a "working committee".  This committee has
 met   approximately  monthly   since  September 1976 to
 advise the Department.
 CONSTRAINTS

       Besides the constraints of the state legislation and the
 ad hoc committee format, the Department intended to:

    .  Follow as  closely as  possible existing schemes  for
       classifying hazardous wastes;

    .  Avoid  creating  a listing  of  extremely  hazardous
       wastes or substances;

    .  Minimize the testing  of wastes  by utilizing known
       data wherever possible;

    .  Avoid the "any quantity and any concentration" trap
       which is unrealistic; and
     With these constraints the  Department developed  a
system for classifying hazardous wastes based on:

   •  Published LDsg's and  LCso's;

   •  A categorization that  accounted for the meager data
     available;

   •  The existing criterion  for extremely hazardous waste,
      namely an LDgQ of 50 mg/kg;

   •   The proposed spill  regulations of U. S. EPA; and

   •   Persistence in the environment.


 EQUIVALENT TOXICITY  CONCEPT

     The  proposed  U.S.  EPA  spill  regulations  are
 modifications   of  the   Intergovernmental  Maritime
 Consultative Organization  (IMCO)  system.  Materials are
 classified into 4  categories according  to their toxicity
 (LC50) to organisms in an aquatic environment:
Category   (A)
           (B)
           (C)
           (D)
                              <  1 ppm
                              =  1-10 ppm
                              =  10-100 ppm
                              =  100-500 ppm
     .  Simplify insofar as possible the assay procedure.
 The U. S. EPA system recognizes that one Ib. of Category A
 substance  is as toxic (will kill  as many fish) as 10 IDS. of
 Category B substance.
       Linear  extrapolation  (assuming  no antagonistic or
 synergistic effects)  would  indicate  that one Ib. of "A"
 substances would be as toxic as 10 Ibs. of "B" substances,
 and 10 Ibs. of "B" substances would be as toxic as 100 Ibs.
 of "C" substances. Thus,  the following have equivalent
 toxicities:

    100 Ibs. of 1 percent "A" substances (one Ib. of "A")
    100 Ibs. of 10 percent "B" substances  (10 Ibs. of "B")
    100 Ibs. of 100 percent "C" substances (100 Ibs. of "C")

       The  Department  chose  one Ib. of  the most toxic
 substances (Category  "A") as the "harmful quantity" and
 based its  decision  on  the fact that  this is the smallest
 container  that  is  commonly  available  commercially.
 Although  this  assumption  might  not  apply to wastes,
 another rationale to be discussed later  in  this paper does
 apply. The Department believes that the one, 10, and 100
  Ib. quantities are  entirely justifiable  thresholds  for its
  regulations.
                                                       -267-

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 TOXICITY TO HUMANS

      Using a modified categorization of toxicity developed
 for  pesticides by  the Federal  Insecticide, Fungicide, and
 Rodenticide  Act (FIFRA), a categorization of substances
 based on acute oral LDijn/s can be made such that:
      Category   (A)
                 (B)
                 (C)
5 mg/kg
5-50 mg/kg
50-500 mg/kg
      To  be classified as extremely toxic, a waste should
 have an oral LDgg of 50 mg/kg (the basic criterion). Based
 on the concept  of  equivalent toxicity (assuming linear
 effects of dilution), a waste (to be less toxic than the basic
 criterion) must contain:

   •  Less than 1  percent Category "A" substances;
   •  Less than 10 percent Category "B" substances; or
   •  Less than TOO percent Category "C" substances.

      Using justifications discussed later  in this paper, the 2
 categories of toxicity, oral and aquatic, can be combined.
 Thus,
      Category (A) Oral  LDfjo < 5 mg/kg or Aquatic
           < 1 ppm
      Category (B) Oral LDjjg = 5-50 mg/kg or Aquatic
                   1 — 10 ppm
      Category (C) Oral LDjjQ = 50-500 mg/kg or Aquatic
                   10-100 ppm
QUANTITY-TOXICITY RELATIONSHIP

      Based on  the  quantity concept developed by U. S.
EPA, and the concentration concept developed above, the
regulations have set their  boundaries.  Figure  1 fits these
concepts  together  based  on  the  example  of a  waste
containing a  category "B"  hazardous substance.  The
vertical line (m,n) represents the oral LDgQ = 50 mg/kg or
10 percent "B"  in the  waste. Wastes more concentrated in
"B"  would  be more toxic.  The  diagonal  line  (o,p)
represents  10 IDS. of  the  constituent "B" in the waste.
Below this line the waste contains less than 10 IDS. of "B".
The quadrant (m,p) should always designate extremely
hazardous wastes. These wastes would be extremely toxic
as well as contain more than 10 IDS. of "B". The quadrant
(n,p) represents  toxic  wastes, but the quantity of "B" in
these wastes is less than 10 Ibs. and thus is not deemed to
be  a problem  requiring regulation.  The quadrant (o,n)
similarly would  not designate extremely hazardous wastes
because it is not extremely  toxic nor does it contain 10 Ibs.
of "B".
      The quadrant (o,m) presents a problem. Although the
waste contains mpre than 10 Ibs. of "B", the waste itself is
not  extremely  toxic.  An  extremely  hazardous  waste
designated by quadrant (m,p) could be placed in quadrant
(o,m) by simply diluting that waste (e.g.,  with dirt). The
Department  utilized a second part  of  the  state legislation
(sufficient quantity)  to  designate as extremely hazardous
wastes those indicated by the hatched area in Figure 1. This
designation  provides  a  safety  factor  of   10.  If  the
Department  were to  tighten its  designation by a factor of
10, many sewage sludges  would have to  be  regulated as
extremely hazardous waste due to their content of metals.
                                             FIGURE 1

                              DESIGNATION FOR CATEGORY B WASTE
                              O.l-
                                                               LD  -SOmfl
                                        Never
                                         EHW
                                                             m
                                                                         7kg
                                                               Always
                                        ICrof B
                                         In  Waste
                                   O.I           I           I0
                                          %   B   in  Waste
                                               (log   scale)
                                               IOO
                             Figure 2 summarizes the complete regulations. Note
                        that  wastes, for which  data regarding the  constituents
                        present and the LCtjQ values are available, a designation can
                        easily be made. However, for wastes for which  no such data
                        are available, the waste producer could test the criteria by
                        simply  verifying  that the LCgg of the waste was greater
                        than  100 ppm. The  Department has  2 relatively  simple
                        methods of assaying the toxicity of a waste for designation
                        as extremely hazardous (not discussed herein).
                                                     -268-

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                       FIGURE 2

               DESIGNATION FOR EHW
IOO.OOO-


  10.000-
EHW
                   Not
                  EHW
          o.i           i            10
               %  Substance  in  Waste
                     (log   scale)
        IOO
  PERSISTENCE

       One  major problem the  Department  had with its
  designation  system  was  the  legislative  requirement of
  considering   "persistence,   and  genetic  effects".  The
  Department finally decided to identify known hazardous
  materials by  class and to  specify tests  to measure these
  materials as a separate  section  of the  regulations. Thus,
  "heavy  metals,  halogenated  hydrocarbons,  and aromatic
  hydrocarbons" were designated as persistent and as having
  potential genetic effects.  To avoid the trap  of regulating
  small  quantities  and low concentrations, the Department
  chose to regulate only amounts greater than 100 Ibs. and 1
  percent  in  concentration  of  toxic   materials.   The
  Department similarly limited its broad  interpretation to
  "soluble"   substances   and   established  specific  test
  procedures to define "soluble".

 JUSTIFICATION OF AQUATIC AND ORAL EXPOSURE
  LIMITS

      Another major problem the Department faced with
 its system was to justify the U.  S. EPA limits  of 1,  10, and
  100 Ibs based on aquatic  (LCjjQ) and oral exposure tests
  (LDi^)). The leachate approach and exposure-risk approach
 discussed below,  indicates  that  these limits  were  of the
 correct order of magnitude for regulation.
 A TECHNICAL RATIONALE FOR THE  LIMITS THAT
 DEFINE  EXTREMELY  HAZARDOUS  WASTES-  A
 RISK APPROACH

       Based on the concepts of equivalent toxicity, it can
 be shown that a landfill  operator experiences the same risk
 (hazard) in his daily operation with ordinary garbage as he
 would experience  with one Ib. of Category "A" material at
 a landfill.
       The  risk or  hazard a landfill operator experiences is
 the product  of 3  probability terms:  (1) the probability of
 ingestion, inhalation, or dermal contact; (2) the probability
 of exposure  to  a hazardous  material which could  be
 ingested, inhaled,  or contacted; and (3)  the probability that
 this  exposure would  cause  harm  or  have some  effect.
 Therefore,

       Risk = (probability of ingestion, etc.)  (probability of
           exposure) (probability of effect)

      The probability of ingestion, etc., has been assumed
 to be a constant independent of the character of the waste
 because  this   probability  will  generally  be  determined
 primarily by  the  operator and his  personal work  habits.
 However,  the  probabilities  of  exposure  and  effect,
 respectively, will depend  on the character of the waste. The
 probability of exposure is related to the daily quantity,  or
 percent of the daily quantity, of waste which has harmful
 characteristics sufficient to create an effect.

 ASSUMPTIONS

      A  typical landfill  operator services approximately
 20,000 people, each of whom generates approximately 5
 Ibs. of ordinary garbage per day. Thus, the operator  is
 exposed  to about  100,000 Ibs. per day of material which
 presents  a hazard  typical of ordinary garbage.  (Recognize
 that these arguments are order of magnitude in impact.)
      What hazard is associated  with  ordinary garbage?
 Based on  the  hazard   ratings  scale  developed  in  the
 regulations,  wastes are  categorized  by factors  of  10
 according to their  LD^ values. Although one could talk of
 LDjjg values for garbage, the concept  of LD^ does not
 strictly hold for  garbage,  but certainly the concept of
 hazard  does  hold.  Noting  that  wastes  belonging   in
 Categories "A" and "B"  are regulated because of extreme
 hazard, and  in Category "C"  because of  quantity and
 potential hazard. Category "D" becomes what might be
 termed dangerous  waste, and ordinary garbage becomes
 either Category "E"  or  "F"  in  hazard  rating, most
 reasonably Category "F".

 EQUIVALENT TOXICITY CONCEPT

      Based on the equivalent toxicity concept,  100,000
 Ibs. of Category "F" hazard is equivalent to 10,000 Ibs of
Category "E", which is equivalent to 1,000 Ibs of Category
                                                        269

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"D".  which is equivalent to  100 Ibs. of Category "C",10
Ibs. of Category "B", and 1 Ib. of Category "A". Thus, each
of the following has the same risk:

   •  200,000 IDS. of ordinary garbage (Category "F");

   •  100,000 Ibs. of ordinary  garbage  containing 10,000
      Ibs. of Category "E" waste;

   •  100,000  Ibs.  of  ordinary garbage  containing 1,000
      Ibs. of Category "D" waste;

   •  100,000 Ibs. of ordinary garbage containing 100 Ibs.
      of Category "C" waste;

   •  100,000 Ibs. of ordinary garbage containing 10 Ibs. of
      Category "B" waste; and

   •  100,000 Ibs. of ordinary garbage  containing 1  Ib. of
      Category "A" waste.

      This analysis of relative hazards provides a framework
for addressing immediate hazards at a landfill, and provides
the basis  for a total  waste management scheme.  Thus,
Category "D" and "E" materials might be considered to be
dangerous wastes, and be regulated at levels of 1,000  Ibs.
for "D", and 10,000 Ibs. for "E". Similarly, the analysis of
relative hazards  indicates that  Category "D" and "E"
materials,  and possibly  Category  '"C",  "B", and "A"
materials might be "properly managed" by the operator.
Thus, one could  reduce the  probability of ingestion, etc.,
and keep the overall risk the same. Generally, this analysis
provides a  realistic method for assessing materials and  the
risks associated with their handling.

A TECHNICAL  RATIONALE FOR THE LIMITS THAT
DEFINE   EXTREMELY  HAZARDOUS  WASTE-  A
LEACHATE APPROACH

      Based on reasonable assumptions, it can be shown
that leachate will have the LCj^Q value when diluted 100 to
1 by groundwater, if no  more than the regulated quantities
(1 Ib. of "A", 10 Ibs. of "B",  or  100 Ibs. of "C")  are
allowed in a landfill. Based on the previously discussed risk
approach, no more than 1 Ib.  of "A" was allowed per
100,000 Ibs. of ordinary garbage. If garbage has a density of
200 Ibs./cu. yd. and will be compacted approximately 3
times when finally deposited in a landfill, the garbage will
ultimately occupy 160 cu. yds. (see calculations below):
                 (100.000 Ibs.)

                (200 lbs./yd.3)
= 500yds.3
                                  If the landfill can be assumed to be 50 feet deep
                            (16 yds.), the compacted garbage will have an exposed area
                            of  10 sq.  yds.  Based  on one year's  rainfall  of 40 in.
                            (100cm)  and  50 percent infiltration, 5,000 liters of water
                            would be available to leach the garbage (see calculations
                            below):

                                  (10 yds.2) (1 m.2/yd.2) (If^cm.2) (100cm.)
                                       (50 percent) (103 cm.3/l.) = 5 x 103  liters.

                                  If one Ib. (500 g.)  of Category  "A" substance  is
                            sufficiently soluble to  dissolve  in 5,000 liters of water, a
                            leachate will be created whose  concentration is 100 ppm.
                            (see calculations below):
                                  (500 g.)

                                 (5,000 I.)
                  0.1 g./l. = 100 mg./l. = 100 ppm
                            A  computer  simulation   model  (1)  Based  on  these
                            conditions, indicates that a leachate would come out of the
                            landfill  at  400 ft.,  4 years  after  burial,  with  a  peak
                            concentration of Category "A" substance of 20 ppm.
                                  If one assumes a 30-acre landfill with a monitoring
                            well located 1 mi. downhill from the  landfill, the leachate
                            at  the  well  would be  diluted  75:1  by  rainfall (see
                            calculations below):

                                  15:1 (area ratio) x 5:1 (distance ratio) = 75:1

                                  Similar calculations (2) show a  minimum of 100:1
                            dilution of leachate at monitoring wells located  1 mi. from
                            a  50-acre  landfill.  Data  from  Llangollen,  Delaware (3)
                            indicated  actual dilutions of leachate to  be greater than
                            100:1 at 2500 ft. {%  mile) downhill from a  landfill.
                                  Thus,  if  1 Ib. of "A", 10 Ibs. of "B",  or 100 Ibs. of
                            "C" per  100,000  Ibs.  of garbage were  deposited  in  a
                            landfill, the leachate  collected % mi. to 1 mi. downhill from
                            the landfill  would approach the  LCj^ of the  material
                            regulated  ("A"  less than  1  ppm; "B"  1-10 ppm; "C"
                            10-100 ppm).  Thus, failure  to regulate  1 Ib. of "A",
                            10 Ibs. of "B", or 100 Ibs. of "C" would cause substantial
                            damage to water resources into which the leachate flows.
                         and

                (500yds.3) =  160yds.3
                  REFERENCES CITED

1.   Anonymous.  1974.  Disposal of environmentally hazardous
        wastes: A  report to the Oregon State Department of
        Enviromental Quality.

2.   Dawson, G.  W. 1976.  Toxicological criteria  for  defining
        hazardous wastes.

3.   Han, R. K.  1975. The generation, movement, and attenuation
        of leachates from solid waste land disposal sites.
                                                      -270-

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                                   PLANNED EVOLUTION TO PROPER DISPOSAL

                                                    Robert F. Heflin
                                       Formerly of Brown ing-Ferris Industries, Inc.
                                                     Houston, TX
      The  U. S. Environmental  Protection  Agency  (EPA)
 finally   obtained  favorable  hazardous  waste  control
 legislation  after  a long  process that  built on  previously
 enacted environmental protection legislation. For example,
 air  pollution  control  legislation   has included  the Air
 Pollution Control  Act of  1955, the  Air Quality Act of
 1967, and  the Clean Air  Act of  1970. Water  pollution
 control legislation has included the  Rivers and Harbors Act
 of 1886 and  1899, the Water Pollution Control Act of 1948
 amended in  1956, and the  Water Quality Control Act of
 1965 amended in 1972.  Solid  waste control legislation has
 included  the  Solid  Waste Disposal  Act  of 1965, the
 Resource Recovery Act  of  1970, and finally the Resource
 Conservation and Recovery Act of  1976, EPA's hazardous
 waste control legislation.
      During this long period of development, the efforts of
 states, counties,  and cities in establishing  environmental
 legislation  have lacked firm direction. The control  of air
 pollution, water pollution, and  solid  waste management was
 often vested in many different agencies. Frequently  these
 agencies   were  undermanned,   underbudgeted,   and
 overworked.  To complicate  this   chaotic  situation, the
 authorities of these local agencies overlapped which created
 further  confusion.   Thus,   final  responsibility  for
 environmental protection  ended up at the state level.
      Some states have issued  aggressive mandates to their
 disposal  industries  to limit or stop existing  "state of the
 art" disposal methods. The reaction to such  mandates has
 been twofold. Some states found that they did not have the
 legal power to  enforce their programs, whereas other states
 found that alternate  disposal methods were inadequate or
 nonexistent.  For  example, the  State  of Ohio had attempted
 to issue a cease and desist order to a major chemical-waste
 disposal firm and had to take the struggle ultimately to the
 state supreme court, but never succeeded in closing the site.
 However, that  state's efforts were not in vain because the
 owners of the  site agreed to install an effluent treatment
 facility  which  had some value. The State  of New Jersey
 began planning to limit the disposal of chemical waste in
 landfills.   Four  attempts  in   2  years were  required to
 establish  this plan, and the state is still trying to enforce its
 mandates to eliminate completely the disposal of chemicals
 in landfills.
      Some  state  and local governments have  "pushed"
their own industrial wastes  into  other  states  and localities
 by  effectively  outlawing   existing  disposal  sites  and
establishing too severe restrictions on the establishment of
new disposal sites. Therefore,  these achievements did not
solve  the problem of chemical waste disposal but merely
relocated  it,  thereby creating  additional  problems for
neighboring states and localities.
      In  some  states  the  waste disposal  industry  built
 complex  processing plants  for  chemical  waste treatment.
 These plants provided advanced treatment to reduce the
 toxicity and other hazardous properties of chemical waste
 in a manner "far superior" to existing "state of the art"
 disposal practices. However,  these  states required these
 plants  to  adhere  to  new sets of rules and eventually
 regulated  them   into   a   noncompetitive  situation.
 Nevertheless, these  states  allowed  the  dump sites  to
 continue in operation as a much cheaper alternative.
      Examples of the results  of excess state and local
 regulation  of chemical waste treatment plants include:  the
 New Jersey,   Baton   Rouge,  and  Houston  plants   of
 Rollins-Purle; the  Youngstown  plant  of  BFI; the Hyon
 plant in Chicago; and Pollution Control, Inc., in Minnesota.
 All of these sites were built by private industry's investment
 capital  with the intention  of providing more  responsible
 chemical  waste  disposal.  The  Rollins-Purle plants were
 required  to  upgrade  their  systems  continually  which
 resulted in higher and higher operating costs, whereas at the
 same time cheaper alternate disposal methods were allowed
 to continue. The BFI facility  in Youngstown, Ohio, had to
 spend   18  months acquiring government permits  which
 resulted in operational requirements  that priced its services
 above alternate disposal methods in the same area; Ohio's
 promises to upgrade disposal practices elsewhere were never
 fulfilled, and BFI was forced to lease  a more competitive
 facility  already in operation to limit their  losses. The Hyon
 facility  in Chicago was essentially legislated out of business
 because Illinois established  a permit program that  would
 allow most wastes to be disposed of in landfills. Pollution
 Control,  Inc.,  in  Minnesota  survived 3  generations  of
 investors,   and  the present  owners  still have  extreme
 operating difficulties meeting air pollution control criteria.
      With  these  forces  acting  on the  chemical  waste
 disposal industry, there is little doubt why the U. S. EPA
 determined in a recent study that most  industries have poor
 cash flow and  that 15 percent are actually losing money.
 There is even less doubt that without unified regulations,
 one  cannot  afford  to  invest  to meet  the  potential
 requirements of his industrial customers.
      At  BFI,  we believe  that a  program of  planned
 evolution to  proper disposal is the only practical answer to
 obtaining suitable facilities in the shortest possible time. To
 try to  jump from indiscriminate dumping, the existing
 "state of the art", to  the best engineered, most technically
 advanced  disposal process is  impossible.  Considering the
time required to close an existing "state of the art" disposal
site  and the noncompetitive  position that a technically
advanced disposal site would have, the  investment required
to upgrade disposal facilities could not be justified.
                                                       -271-

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      The  passage  of the   Resource  Conservation  and
Recovery Act of  1976  has set the  stage  for  planned
evolution to  proper  disposal.  We  urge state  and  local
governments to concentrate immediately on stopping the
worst offenders in the disposal industry to provide a stable
market  for  investment. Every possible incentive should be
given to industry to build disposal sites that are competitive
in their initial  phases and that have the built-in capability to
evolve, as alternate disposal sites are upgraded or closed.
      We  believe  that  the most  important assistance we
need  is with respect to site selection and approval. We do
not believe that it is possible today to obtain full approval
of a new disposal site  based on local public hearings and
local  laws as they presently exist  in some states. The local
citizenry, as is  frequently the  case with local  groups,  is
blind to reason, regardless of the technical soundness of a
project.  Perhaps state  pre-emption  of  local  laws,  as in
Illinois, is the best method.
                                                         272-

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                                               AN INVENTORY OF
                                   HAZARDOUS WASTES IN MASSACHUSETTS

                                     Paul F. Fennelly, Mary Anne Chill ingworth.
                                        Peter D. Spawn, and Mark I. Bornstein
                                    CGA Corporation — GCA/Technology Division
                                                    Bedford, MA

                                                        and

                                           Hans I. Bonne and Glen Gil more
                                   Massachusetts Division of Water Pollution Control
                                                    Boston, MA
INTRODUCTION

      In the field of environmental technology, the disposal
of hazardous  industrial  waste has  been  somewhat of a
sleeping tiger;  however, the  passage  of the new Federal
Resource  Conservation  and  Recovery  Act will arouse
considerable interest. This  new law calls for each state to
develop a  statewide hazardous waste management plan, the
first  step  of which  is a hazardous waste inventory. The
Commonwealth of  Massachusetts has  made a  significant
head  start in this  direction. Since  1970, they have had a
hazardous  waste  regulatory program  and  have  recently
completed a  statewide  hazardous waste inventory. The
purpose  of this paper is  to review  briefly the  current
hazardous waste regulatory program in Massachusetts, and
to describe  the approach taken and the results uncovered
during  our  hazardous  waste  inventory. Based  on our
experience in this  work, we also provide recommendations
for improved  hazardous waste management as  required
under the new  Federal law.

REGULATION   OF  HAZARDOUS   WASTE  IN
MASSACHUSETTS

      Legislation to control the handling and disposal of
hazardous wastes  was adopted  in Massachusetts  in  1970.
This  law  established a  Hazardous Waste Board, comprised
of the members of  the Water  Resources Commission and
the Commissioner of the Department of Public Safety, and
designated  the Division of Water Pollution Control to
administer the regulations adopted by the Board.
      Assignment  of hazardous  waste responsibility to  the
State's water pollution control agency traces back to earlier
programs which the Division of  Water Pollution Control
initiated  in 1968 and  1969 aimed at the prevention and
control of  oil  pollution and  which  included  a  licensing
requirement for waste oil collectors. Collection and disposal
of waste  oils  was subsequently incorporated into the new
hazardous waste  regulations, and in  fact, waste oils still
comprise  the  largest volume of hazardous materials covered
by the regulations.
      The regulations  define wastes that are considered
hazardous, specify methods for the handling and disposal of
such materials and  require that any firm engaged in their
conveyance,  handling  or  disposal  be  licensed by  the
 Division of Water  Pollution Control.
     The  Massachusetts  regulations  do  not  contain  an
itemized list of specific materials by their chemical names,
but rather define  "hazardous wastes" as any  "... waste
substances which,  because of their chemical, flammable,
explosive,  or  other characteristics  constitute  or  may
reasonably be expected to constitute a danger to the public
health, safety, or welfare or to the environment." Further,
the regulations establish categories of hazardous materials
and describe  in broad terms allowable disposal methods for
each category.
     The  categories   are   arranged  into  4  classes -
hydrocarbon  liquids, aqueous liquids,  solids and sludges,
and  special   hazards —  typical  subdivisions  of  which
include: waste oils, solvents and chlorinated  oils; plating
and  pickling waste; metal hydroxide sludges;  oily solids,
explosives, reactive  metals,  pesticides, waste cylinders of
gas, and other compounds assigned a hazard rating of No. 2
or  greater in  the National Fire  Prevention  Association
identification system.  To date, this manner of definition
and  classification  has  proven adequate in bringing those
materials needing  speciai control under the legal authority
of the regulations.
      The Division's licensing activities include review of
applications,  inspection of  equipment and  disposal  sites,
and monitoring of operating reports which each collector or
disposal facility must submit on a monthly basis.  Because
many disposal  methods are subject to air quality standards
or rules regulating the operation of sanitary landfills, there
exists  a  strong need  for coordination  with other state
agencies.  In  addition,  the  regulations  require that  any
disposal of wastes outside of Massachusetts be approved by
the appropriate environmental agency of the receiving state.
      Licenses, which  must be renewed annually, specify
which  types  of materials may  be handled, and  indicate
whether  licensing is for conveyance, storage, disposal, or
any combination of these. Currently, about 100 firms hold
Massachusetts  hazardous waste licenses.  More than half of
these provide  for only collection  of wastes, or collection
and storage only,  and must rely on other licensed firms for
ultimate  disposal.  Approximately  20   of  the  licensed
companies are located out-of-state. Most of these offer final
disposal for one or more categories of waste.
      Two problems have limited the  effectiveness of the
hazardous waste  program in the past.  The first has  been
lack of sufficient manpower to ensure strict enforcement of
the  rules.  Recent reassignment  of  Division of  Water
                                                         273-

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Pollution Control personnel to hazardous waste control and
the creation of two new engineering positions under a grant
from  the  Environmental Protection  Agency's Solid Waste
Management   Program  have  significantly improved  this
situation.  Between  the Division's central  office in  Boston
and its 3 regional  offices, the  total professional activity
directed toward hazardous wastes in fiscal 1977 will be 6
man-years.
      The second and more important problem  is the lack
of suitable disposal options within Massachusetts for certain
types of wastes, particularly hazardous solids and  sludges
which require a secure chemical waste landfill. Reasons for
this lack include: (1) limited private investment due partly
to  previously weak  enforcement;  (2)  absence  of  an
extensive  chemical process industry to provide the  base
load  for  a  major facility; and (3)  disunity  among  state
regulatory and management agencies. The net result has
been   economic  hardships to  industry  caused by   long
distance transportation and incentive for some industries to
use illegal or questionable disposal methods.
      As a first step towards resolution of these problems,
the Division of Water Pollution Control  in  1976 engaged
GCA/Technology  Division to  perform a hazardous waste
survey and to  recommend  methods of hazardous  waste
management.

HAZARDOUS WASTE SURVEY

       The primary effort in the survey was to improve the
data   base  with  respect   to   hazardous   wastes  in
Massachusetts.   Based   on   the   improved  data  base,
recommendations  could  then  be  made  for  improved
hazardous waste management.
       This  project  was  designed   to   satisfy  3 major
objectives:

    •   Estimate the quantities of hazardous waste — using a
       telephone survey in conjunction with personal  visits to
       selected industries, estimates were to be made of the
       amounts and  geographic  distribution of the various
       categories   of  hazardous   wastes   generated  in
       Massachusetts.

    •   Identify  disposal  and  recycling  options—  in
       conjunction with the survey, a search was also  made
       to  identify  options available  for improving the
       present manner of disposing of hazardous wastes.

    •   Recommend disposal options  — based on the above
       information, recommendations for optimum  disposal
       practices  were to  be   made   on     immediate
       (3 months  to 1 year) and long-term (1 to  5 years)
       bases.

ESTIMATE HAZARDOUS WASTE QUANTITIES

       The first step in this project was to review the files of
the Division  of  Water  Pollution Control containing the
annual permit applications and monthly reports from the
waste haulers licensed and operating in Massachusetts. The
data from the permit files provide a lower limit with which
to compare the results of the next phase of the project, a
survey of  Massachusetts industries  with  respect to  the
methods of disposal  or hazardous wastes and the quantities
of such wastes they produce.

Review State Permit  Files

      For each  licensee,  the quantities of each class of
hazardous waste handled in  1975 were obtained by adding
the amounts  reported for each month. Table 1 summarizes
these findings. For  consistency, all  reporting  units were
convened to gallons. A major  problem  encountered in
reviewing the hazardous waste files in their present form is
that the origin of the wastes is  almost never reported  and
the delivery  to another licensee or to a recycling/disposal
facility might not be specified  on each monthly report.
Rather, many monthly reports state that the wastes will be
delivered to  any  of several alternatives which are listed on
their annual  permit applications. Such a system hinders the
tracing of many individual waste streams; nevertheless,
using  the  available   data,   best   estimates  for   the
disposal/recycling fates of the 5  classes of hazardous wastes
are also displayed in Table 1. These figures suffer from the
fact that some  licensed  haulers deliver  their   loads   to
other  licensed handlers, thus causing some wastes  to be
counted twice.
      Of the 13,329,000 gallons of waste oil  picked  up,
approximately 6,917,000 gallons, or 52 percent are burned,
either  as   fuel   or   in  an  incinerator.  Another
1,715,000 gallons, or 13 percent, are used for dust control
on roads and 486,000 gallons (4 percent) are delivered to
asphalt plants. Only 3,046,000 gallons  or 23 percent are
reclaimed, while 500,000 gallons or 4 percent are landfilled.
The landfilled oils are primarily derived  from spills  and
usually contain the absorbing media. Solvents are reclaimed
(59 percent), burned (9  percent) or  landfilled  (1 percent).
Most  of the 783,000 gallons (30 percent) which  is  not
accounted  for is solvent sludge or distillation bottom which
is incinerated or landfilled.  Most of the  aqueous chemicals
picked up  are treated and then  discharged to the sewer. A
small percentage (0.5 percent) are reportedly being buried
directly in  a  landfill.   Solids and sludges  are  landfilled
(56 percent), or  in  the  case of sludges from oil tanks or
solvent reclamation, are burned (41 percent).
      Of  the  1,620,000 gallons of  hazardous  materials
reported as being hauled to landfills, 503,910 (31 percent)
are  taken  out-of-state,  primarily to  New Jersey landfills;
713,020 (44 percent) gallons of hazardous  wastes  were
disposed of  in Massachusetts landfills which today are not
licensed to  accept  these wastes. (No new licenses  were
awarded to any Massachusetts landfills  in 1975 and 1976.)

Survey of Massachusetts  Industries

      To supplement the data in the hazardous waste  files
and to  provide  a  better understanding of the  flow  of
hazardous wastes within  Massachusetts, a survey of the
amount, geographic  distribution and  current  practices  of
hazardous waste disposal was organized.
                                                       -274-

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           The first step was to identify the types of industries
      which  would  be expected to generate hazardous wastes.
      After a review of the technical literature and discussions
      with the state and federal regulatory agencies, the industries
      shown   in  Table 2  were  selected  for  the  survey. The
      Massachusetts Industrial Directory  1974-1975 which lists
      industries by Standard Industrial Classification (SIC), was
      used to identify the companies  and number of employees
      within  each selected SIC.
           To speed  the flow  of information, contacts were
      made  primarily  by  telephone.  Using  a  telephone survey
      form   developed  by GCA,  the  plant   manager  or  the
      environmental engineer  from each facility was questioned
      about  the types of wastes generated by his plant. Several
      industries were reluctant to release what they considered to
      be proprietary information but were willing to discuss their
      wastes  in terms of broad classes, such as waste oils, solvents,
      acids, sludges, etc.
           The responses of  most of the individuals contacted
      during  the survey were cooperative; less than 1 percent of
      those contacted  refused to participate in the survey in any
      manner.  In  all,  446 plants completed  the questionnaire.
      These account for 9.2 percent of the 4,868 plants  listed in
      the  industrial  categories  selected  for  this survey and
      represent 45.4 percent of the employees in these industries.
      Ninety-one plants were  either  unable  to estimate waste
      quantities or could not be contacted in follow-up calls.
           Most of  the information provided to the survey team
      represents a  "best  guess" by the plant  manager or  the
      plant's  environmental engineer.  In many cases, the exact
      quantities of wastes generated were unknown, but waste
      volumes were estimated based on factors such as number of
      pickups per  year, size of  storage tanks, and quantities  of
      new materials used.
           The   data  collected   during  the   survey  were
      extrapolated  to yield statewide  totals  on  the  basis  of
      number of employees in each industrial category.  In order
      to represent the industries as accurately as possible, these
      extrapolations were performed at the 3- or 4-digit SIC level.
      This assumed  that all industries within each 3- or 4-digit
      category were  engaged in the same types of operations and
      would  therefore have similar types and quantities of wastes.
           The extrapolation  procedure  also assumes  a linear
      relationship  between wastes  generated   and number  of
      employees. This may introduce a source of error  as plants
      with large numbers  of employees may have only a small
      number engaged in production activities and  smaller plants
      may use  different  manufacturing  processes than  larger
      plants.  The  estimates presented here are  best treated  as
      lower limits, accurate probably to within a factor of 2 or 3.
           The major part of our survey dealt with hazardous
      waste material from manufacturing (or related) industries,
      but also included  in the  project  were surveys of special
      classes  of hazardous wastes such as  automotive waste oil,
      fly  ash  from  power  plants,  polychlorinated  biphenyls
      (PCB's) and  pesticides. These wastes were estimated from
      published  and   unpublished   generation  factors  and
      discussions with key industrial and regulatory officials.
           In  all, 37,750,000 gallons  of hazardous wastes  are
      generated each year in Massachusetts. Of this, 18.5 million
      gallons  are waste oil, 9.2  million  gallons are sludges, 4.0
-275-

-------
million  gallons are  plating wastes and metal containing
sludges, 2.7 million gallons are solvents, 2.3 million gallons
are acids and  alkalies and 0.8 million  gallons are  other
hazardous  wastes.  Table  3  (page 277)  summarizes  the
distribution of  hazardous waste among the various sources.
Waste oils from automobiles account for 83 percent of the
state's total waste  oil.  Fabricated  metal products and
machinery  are  the major  industrial sources, contributing
9 percent.
                       TABLE 2

         MAJOR SIC CATEGORIES EXPECTED
        TO GENERATE HAZARDOUS WASTES
    SIC
   CODE
     22

     26
     27
     28
     29
     30
     31
     33
     34

     35
     36

     37
     38
     39
               INDUSTRY
Textile  mill products (dyeing and finishing
only)
Paper and allied products
Printing, publishing, and allied industries
Chemicals and allied products
Petroleum refining and related industries
Rubber and miscellaneous products
Leather and leather products
Primary metal industries
Fabricated metal products except machinery
and transportation equipment
Machinery, except electrical
Electrical   and  electronic   machinery
equipment and supplies
Transportation equipment
Measuring,  analyzing,   and   controlling
instruments: photography,  medical,   and
optical goods, watches and clocks
Miscellaneous manufacturing industries
         Solvents  are  used  primarily  by  the  electronics
   industry (SIC 36) and by miscellaneous industries such as
   jewelry  and   silverware  manufacturers   (SIC   39).
   Approximately 41 percent of the state's total solvent waste
   is generated by these 2 industrial classifications.
         As anticipated, metal  sludges and plating wastes are
   generated primarily  by  3 industries:  primary  metals;
   fabricated metal products; and machinery, except electrical.
   The combined waste from these 3 classes is approximately
   71 percent of the total metal sludge and  plating waste in
   the Commonwealth.
         Acid and  alkali waste are  produced almost solely
   from   the  primary  metals  industry,  which  produces
   approximately 80 percent of the state total for this type of
   waste. These reactive materials are used for cleaning and
   plating metals.
         Miscellaneous sludges are mostly comprised of wastes
   from  the chemical industry. They contain numerous types
   of organic  and  inorganic  components and account  for
60 percent  of   the   miscellaneous   hazardous  sludges
generated  in  the  »tate.   Paper,  printing,  and  textile
industries generate large quantities of sludge, but these were
not generally considered hazardous.
     The  last  major  category, "Other Hazardous Waste"
represents undefined wastes reported during the survey, as
well as wastes that do not fit into the other 5 categories.
Almost  60 percent of  these  wastes are generated by  the
chemical industry. Fabricated metals, electrical equipment,
and   miscellaneous  manufacturing  industries  together
generate  34 percent of the unclassified wastes which may
include photographic chemicals, resins, inks, and polymer
solutions. Most  of the "Other Hazardous Wastes," which
are  derived from the  paper and printing industries,  are
waste inks.
      In Table 4, the survey results are compared with  the
state permit data. The  last column in the table provides the
percentage of the  hazardous types which  the  state  has
identified through its permit system. Note that the first 3
categories maintain a high profile — waste oils and solvents,
because of their current value, and aqueous liquids because
of the relative ease of handling and disposal. The problems
in  regulating  sludge  and  other  types  of  waste  are
self-evident
      Figure  1   shows the  geographical  distribution  of
hazardous wastes generated throughout the Commonwealth
on  a countywide basis. Not unexpectedly, the metropolitan
areas  around  Boston,  Worcester,  Springfield   and
New Bedford have the greatest quantities.
      Several  states have  published the  results of their
hazardous waste surveys.  Table 5 compares our survey
results with those obtained in Arizona, Minnesota, Oregon
and Washington. Surprisingly close correlation is found in
the ratio of industrial wastes to manufacturing employees,
despite differences in the kinds of industries.
                                                                         TABLE 4

                                                             COMPARISON OF SURVEY RESULTS
                                                             WITH LICENSED HAULER PERMIT
                                                                     DATA - GAL/YR
WASTE
MATERIAL
Waste oil
Solvents
Aqueous liquids
Solids and sludges
Other
TOTAL
SURVEY
RESULTS
18,313,000
2,784,000
2,293,000a
13,928,000b
756,000
38,074,000
PERMIT
DATA
13,329,000
2,602,000
2,009.000
834,000
144,000
18,918,000
PERCENTAGE
IDENTIFIED
PERMIT
DATA
73
93
88
6
19
50
                                                   a  Acids and alkalies only.
                                                   b  Includes plating solutions (770,000 gallons).
                                                         -276

-------
                                                                                                                          TABLES


                                                                                THE DISTRIBUTION OF HAZARDOUS WASTES AMONG VARIOUS INDUSTRIAL CATEGORIES






TYPE OF INDUSTRY
22 Textile mill
products
26 Paper and
allied
producti
27 Printing,
publishing
and allied
Industrie*
28 Chemicals
and alllad
Industries
20 Petroleum re-
fining and
related
induitry
30 Rubber and
miscellaneous
plastics
31 Leather end
leather
prcxkicts
32 Stone, day.
glau, concrete
producti
33 Primary maul
Industrial
34 Fabricated metal
products
36 Machinery, except
electrical
36 Electrical and
electronic
machinery
37 Treneportetlon
equipment
38 Measuring,
analyzing and
controlling
ecfulpment
38 Miscellaneous
manufacturing
Industries
TOTAL



f^tMMV
comp-
anies
Con-
tacted

26


67



47


21



12


40


12


3

19

79

21


67

S



9


18
446




Total
Comp-
anies

111


329



926


266



53


447


392


6

22S

960

628


664

1S6



262


272
4,868


Employees
Repre-
e^.lail
Nfma
by Con-
tacted
Companies

4,866


17,663



18,647


9,966



1,686


13,874


6.603


126

4,647

31,147

20,137


60,629

6.880



13,292


6,716
216,404





Total
Employee!

10,977


31,603



37,711


21.778



2,697


36,038


36.109


246

16,707

69.687

38.086


89.686

16,922



40,338


18,682
474,104



PaaaMkaan*
rVFMfif
Employees
Repre-
sented

44.2


66.6



49.2


46.7



61.0


39.6


18.8


51.0

29.6

62.3

62.9


67.7

43.2



33.0


30.8
46.4
TYPE OF WASTE (GALLONS/YEAR)


Oil

Oallone
Reported

1,166


12,210



20,130


24.420



330


186,230


66


_

30,910

463,685

643,675


189,310

62,086



97,846


5,940
1,617,880
Extrap-
OUltd
Quenttrtv

2,310


20,460



36,090


51,690



440


416,680


110


_

89,266

683,660

908,436


316,196

202,840



140,415


22,110
2,766,655


Solvent

(Jettons
Reported

99,000


91,366



46,146


26,740



_


69,906


27,600


_

3,630

143,935

27,776


421,796

2,476



614,460


96,260
1,668,976
Extnp-
olated
Quantity

282,700


169,775



124,410


56,980



_


103,666


74,360


_

13,146

241,230

30,470


602,370

4,676



823,020


339,956
2,784,165

rUtlflQ WsWtH
and metal always

Galons
Reported

276


-



_


UKN



_


_


304,645


_

292,986

737,770

349,910


267,025

_



58,520


8,416
2.019,646
Extrap-
olated
Quantity

650


-



_


UKN



_


_


730,786


_

1,066,230

1,001,606

802,450


329,176

_



80,025


24,365
4,036,186

MkmManeoui
sludge

Gallons
Reported

a


b



c


2,233,166



2,116,896


440


128,866


_

13,760

8,746

49,390


606

92.786



260,196


826
4,895,660
Extrap-
olated
Quantity

a


b



c


5,071,385



2.468,060


1.375


308,496


_

46,476

18,150

83,380


1,320

134,200



322,685


2,200
8/447,726

Acids and
Alkalies

Gee-one
Reported

-


-



27,600


36,685



_


_


_


_

638,010

26340

145,090


15,400

_



—


-
789.626
Extrap-
olated
Quantity

-


-



42,240


83,490



-


_


_


_

1,824,240

47,795

266,680


29.315

_



—


—
2,292.730
Other
Hazardous
Waste

Gallons
Reported

-


2,266



6,646


131,670



25,026


165


_


UKN

_

71,610

—


47,740

_



67.320


—
362,330
Extrap-
olated
Quantity

-


3,410



18,096


444,960



28,820


560


_


UKN

_

91,366

—


81,610

_



87,010


—
765,700


Totals

Gallons
Reported

100,430


105,820



100,320


2,451,680



2,142,260


256.740


481,065


UKN

879,286

1,442,486

1,115,840


941,875

147,346



1,088,340


110/440
11,343,916
Extrap-
olated
Quantity

285,660


183,646



219,086


6,708,395



2,487,320


621,070


1,113,760


UKN

3,039,356

2,083,786

2,090,385


1,269386

341,716



1,463,165


388,630
21,176,485
Percent
of Total
In Mesa.




1.4


0.9



1.0


27.0



11.7


2.5


6.3


—

14.4

9.8

9.9


6.0

1.8



6.9


1.8
100.0
CO
-4
-4
          UKN  Unknown


             a  The miscellaneous sludge reported for this cetegory was 680,570 gal./yr. (1,369,216 gal./yr. extrapolated). Almost ell of this material is inert and not considered hazardous.
             b  The miscellaneous sludge reported for this category was 1,874,730 gal./yr. (2,263,746 gal./yr. extrapolated). Almost all of this material It inert and not considered a hazardous watte.
             c  The miscellaneous sludge reported for this cetegory wes 2,156,176 gel./yr. (9,960.940 flal./yr. extrapolated). Almost all of this material Is Inert and not considered e hezerdous waste.

-------
                                                                  FIGURE 1

                                    GEOGRAPHIC DISTRIBUTION OF HAZARDOUS WASTES IN MASSACHUSETTS
'
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                             G AUTO WASTE OIL

-------
                       TABLE 5

           COMPARISON OF MASSACHUSETTS
        SURVEY RESULTS WITH OTHER STATES
                   A. Industrial Wastes






State
Massachusetts
Arizona

Minnesota
Oregon
Washington



Industrial
Hazardous
Wastes,
Gal./Yr.
22,135,000
12,387,000

11,886,000
7,717,000
13,390,000




Number of
Manufacturing
Employees
618,000
(1,460
manufacturers)
343,000
197,000
252,000
Ratio of
Industrial
Waste to
Number of
Manufacturing
Employees,
GaUYr.-Person
36
—

35
39
53
                 B. Automotive Waste Oil
State
Massachusetts
Minnesota
Oregon
Automotive
Waste Oil,
Gal./Yr.
15,435,000
6,000,000
8,004,000
Population
5,800,000
1,914,000a
2,219,000
Per Capita
Automotive
Waste Oil,
Gal./Yr.-Person
2.7
2.6
3.6
 a  1970 population for the 8 counties surveyed.
DISPOSAL AND RECYCLING OPTIONS

Existing Capacity

      The severity of the hazardous waste disposal problem
is  most  evident  with respect to sludges -  there are no
disposal sites within the  state which  are currently licensed
to accept these materials. Some of these materials are being
shipped   to   out-of-state  disposal   sites  or   waste
recycling/disposal firms as shown in Figure 2, but most are
either  being temporarily stored in company facilities  or
disposed  of  illegally.  Because of  the distances involved,
out-of-state shipment is  economically  practical only for
large  quantities  of  wastes.  The  survey  confirmed  the
difficulties that  small waste generating industries have in
disposing of their waste sludges.
      Many  sludges  could   be   landfilled  within  the
Commonwealth  if an acceptable site were  available and
licensed.   GCA's  survey  indicated  that  a  total  of
approximately  13 million gallons of  potentially hazardous
industrial waste  sludges are generated  per year.  If these
sludges  (assumed  to  contain  10 percent  solids)  were
dewatered  to   an  18 percent  solids  concentration  (as
required for disposal of  municipal waste treatment sludges
in  conventional  landfills),  the resulting sludge  volume
would be on the order of 1.0 million  cubic feet (7.2 million
gallons). This volume of sludge would only occupy about
1 acre per  year,  if landfilled to a  depth of 20 feet (no
allowance for earth fill or cover). This indicates that small
sections  of existing  landfills,  if modified  for  accepting
hazardous waste, would be adequate, at least over the next
1 to 5 years until new facilities can be built.
     With respect to solvents and waste oils  for which the
preferred  disposal method is  reclamation or reprocessing,
the capacity  of Massachusetts firms alone is  not sufficient
to handle the quantities of waste materials generated within
the stata.  For solvents, an estimated 2.8 million  gallons a
year are generated, while in-state reclamation  capacity is on
the order of  1.3 million gallons per year. Similarly, annual
waste oil  generation is estimated at 18 million gallons per
year compared to an in-state reprocessing capacity of about
5 million  gallons annually. Despite  this excess of waste oil
and  solvents,  local   reprocessors  are   still   running
considerably  under capacity  due to competition for waste
oil  and solvents from rerefiners in other states as shown in
Figure 2,  as well as from firms who burn waste oil directly
as a fuel or apply it for dust control. More than 70 percent
of  the  waste oil  and  solvents are  disposed  of  in  an
acceptable manner.  The current economic value of these
wastes probably goes far in explaining their relatively high
pickup rate.

Transfer Stations

      Most of the sites shown in  Figure 2 are running well
below  capacity despite  the  strong  need  for  adequate
disposal  facilities. One of the primary reasons for this is the
cost of transportation. The smaller waste generators simply
cannot afford to ship wastes to some  of these facilities.  A
solution which has much potential  for alleviating the waste
disposal  problem is the development  of private industrial
transfer   stations.   A  transfer   station   is  simply  a
 centrally-located area which receives, for a fee, wastes from
 surrounding  industries. When  a truckload of  economic size
 (usually  2,000 to 4,000 gallons bulk)  has  accumulated,
 wastes are removed to the out-of-state disposal firms by an
 independent  hauler or by  the disposal firms themselves.
 Two private transfer stations have recently begun  operating
 in  Massachusetts, and the initial  response looks promising.

 RECOMMENDATIONS FOR  IMPROVED  HAZARDOUS
 WASTE HANDLING AND DISPOSAL

      Concerted action must be taken with  respect to the
 management  of hazardous waste disposal. In Massachusetts
 the severity  of the problem is most evident with respect to
 hazardous sludges; there are no landfills within  the State
 which are now licensed to accept these materials. Some of
 these  materials  are being shipped to out-of-state disposal
 sites,  some  are being temporarily  stored  in  company
 facilities,  but considerable amounts are being disposed  of
 improperly and illegally.  The following recommendations
 have been made to improve control  of hazardous waste
 disposal  in  Massachusetts.  The  state  must continue  to
 refine its approach to hazardous waste management. The
 new Federal  Resource Conservation and Recovery Act calls
 for  the  development  of  statewide  hazardous waste
 management plans,  but in many cases, the implementation
 of these  plans will  require legislative changes which can
 sometimes be painfully slow.
                                                          279-

-------
                      FIGURE 2

DISPOSAL OPTIONS FOR MASSACHUSETTS INDUSTRIAL WASTES
              *.-




                             -TV
                                            "'   "A
                              LEGEND-TYPES OF WASTES PROCESSED
                                * TRANSFER STATION
                                X WASTE OIL
                                O PLATINC WASTES
                                • ALL CLASSES
                                A SOLVIMT
                     -280

-------
     To alleviate the  problem, action  is required on  2
levels:  steps which can be implemented  immediately (i.e.,
3 months to  1 year); and steps which can be implemented
over a longer  period (i.e., 1 to 3 years). Each is discussed
below.

RECOMMENDATIONS FOR IMMEDIATE ACTION

   • Consolidate Authority  for  the  Hazardous  Waste
     Program —  The regulation of  hazardous waste  will
     often cut across air, water and solid waste regulatory
     agencies; often each  will have  its  own regulatory
     approach and order of priorities. Within one of these
     agencies, a  single section should  be designated as
      having   overall responsibility  for  hazardous  waste
      management,  planning,   and   enforcement.  In
      Massachusetts  this  section should  be placed within
      the  Division  of  Water  Pollution  Control,  which
      currently has  the broadest authority within existing
      state  agencies with  respect  to  hazardous  waste
      regulation.

   •  Modify   Several   Existing   Landfills  to   Accept
      Hazardous Waste —  Modification of several existing
      landfills to accept  hazardous  wastes is essential to
      relieve the current lack of  state approved disposal
      sites. One potential site is a private landfill  in eastern
      Massachusetts, which  is  lined  with  a  relatively
      impervious  material   and  fitted  with  a  leachate
      monitoring and collection  system.  Initial  contacts
      have  been  made  with  the  owners by  the  state
      concerning  possible adaptation  of  this landfill  for
      certain  hazardous  wastes.  Action along these lines
      should be  accelerated. In addition, other landfills in
      the state should be evaluated as soon as possible as
      potential hazardous waste disposal sites.

    .  Enforce Existing Hazardous Waste Regulations More
      Strictly-  Strict  enforcement  of  hazardous waste
      regulations,  assuming  that  disposal  sites  become
      available, is the  key to  improving  hazardous waste
      disposal.  Strict enforcement of existing regulations
      would   reduce   illegal    and    environmentally
      unacceptable  disposal of wastes  and stimulate  the
      private   waste   disposal/recycling  industry  by
      guaranteeing a market for disposal services.

    .  encourage  Use   of  Transfer   Stations-   Many
      companies that generate small amounts of  hazardous
      waste   are   reluctant   to  use  out-of-state
      reclamation/disposal services because of the high unit
      costs associated with handling and transporting small
    quantities of waste. A solution to this problem is the
    transfer  station concept  where  a  centrally  located
    storage  area  receives  wastes  from  surrounding
    industries. When  a  truckload of an economic  size
    (usually  80 drums, or 2  to  4,000 gallons  bulk) has
    accumulated, wastes are removed to the out-of-state
    disposal  firms by an independent hauler, or by the
    disposal  firms themselves. (Since the completion of
    this report,  at least 2 firms are now operating as
    transfer  stations  for  hazardous waste disposal in
    Massachusetts.)

  • Promote   Better  Waste  OH  Disposal Practices —
    Presently  waste oil collectors in Massachusetts  are
    selling collected oils for road oil, fuel oil, and asphalt
    manufacture. About 52 percent is burned, 23 percent
    rerefined (or reclaimed), and  13 percent used for road
    oiling.  The  optimum disposal method is  rerefining
    and  it  should  be encouraged  wherever  possible.
     Burning waste oil without removing contaminants can
    result in significant emissions of lead and other heavy
    metals,  and  road oiling  can result in  significant
    environmental  contamination,   because  EPA tests
     indicate that 70 to 90 percent of untreated waste oil
     applied to a road is reentrained to the atmosphere (on
     dust particles) or surface water (via  runoff).  It is
     recognized  that  each of these practices  may be
     acceptable in certain limited locations,  but in general
     they should be phased out.

   •  Develop  Public   Relations  and  Educational
     Programs —  An  important  step   should   be  an
     educational  and  public  relations campaign geared
     toward   plant  engineers   and   plant  managers
     (especially  in   small   to  medium-size   plants)
     to  publicize  the regulations; to  define  hazardous
     wastes;  and indicate proper  waste handling methods.

LONG-TERM RECOMMENDATION

   •  The basic long-term recommendation is to develop a
     statewide  hazardous  waste  management  plan  as
     required by the new  Federal law. This would address
     topics such  as number and type  of waste  facilities
     needed,  criteria for disposal site selection, schedule
     for developing new facilities, manpower requirements
     for  increased enforcement,  etc.  As  part  of  this
     management  plan,  a stricter enforcement  program
     should  center on  a  waste   manifest system which
     requires waste generators, haulers and disposers to file
     monthly  reports on  the quantities, destination and
     final disposal  locations of hazardous wastes.
                                                        -281

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                             SHIPPING CONTROL OF INDUSTRIAL WASTE IN TEXAS

                                               Jay Snow, P.E., Chief
                                             Industrial Solid Waste Unit
                                                  Permits Division
                                       Texas Department of Water Resources
                                                    Austin, TX
INTRODUCTION

      In  June, 1975,  the Industrial Solid  Waste Branch
of the  Texas  Water  Quality  Board  (TWQB) submitted
an   application  for   grant   funds   to  the   U. S.
Environmental   Protection   Agency.   The   funds,
authorized  under  Section  207  of  the   Solid  Waste
Disposal Act (PL 98-272)  as  amended, were  requested
for the  support of  a $126,666 project to design and
implement  a  regulatory  system  for  industrial  solid
waste management.
      The  project   was  initiated   in   response   to
environmental  problems  arising  from  the  indiscriminate
disposal  of industrial  solid waste (waste). Several  studies
had  indicated that industries in Texas were generating a
considerable  amount   of  waste, but   TWQB  had  little
information  regarding  industrial  waste disposal  practices.
Therefore, 2 basic goals of the project were to establish a
mechanism to control  off-site waste disposal and to provide
a  regular  flow of data  regarding  waste generation  and
disposal practices.
      The  regulatory system was formulated as  part of a
comprehensive  program  for  waste management  which
included:  (1) the establishment of minimum performance
levels and  recommended technical standards for all disposal
sites; (2) permit requirements for commercial disposal sites;
and  (3) record  keeping  and reporting requirements for
generators, carriers, and disposal site operators.
      This  report   discusses  the  development  of  the
shipping-control  and reporting system, summarizing  the
system's conceptual origin, regulatory framework, technical
design and implementation.

BACKGROUND

Existing Statutes and Regulations

      The  Texas Solid Waste Disposal Act, enacted in 1969,
assigned the  responsibility  for control of  waste  to the
TWQB and the responsibility for control of municipal solid
waste  to  the  Texas  Department of  Health Resources.
Specifically, the TWQB was designated as the coordinating
agency  for all waste management activities with  respect to
collection,  handling,   storage  and disposal.  The  Act
authorized the  Board  to adopt  regulations and  require
permits for  all  of  these  activities except in the case of
on-site  disposal operations.  The  Act prohibited  the
requirement  of  permits for such on-site (noncommercial)
operations which were defined as waste disposal activities
undertaken within  the property boundaries of  a tract of
land owned and controlled by the owners and operators of
the particular industry from which the waste resulted, and
which tract of land was within 50 miles from the industry
producing  the  waste.  This  prohibition did not apply  to
waste which was collected, stored, or  disposed of with
waste from any other source.
     To implement controls pursuant to this Act, in 1971
TWQB passed Board  Order 71-0820-18 which  established
general   design   criteria  and  permit  requirements  for
commercial disposal operations. This order also established
the policy  that the waste generator was responsible for the
safe and proper disposal  of any  waste produced by him,
regardless  of  the disposal  process  employed.  On-site
disposal operations were required to  obtain a certificate of
registration under the  TWQB   Rules   of   Procedure.
Subsequently, each of some 200 on-site and 30 commercial
industrial waste disposal sites were identified and issued a
certificate of registration or a permit, as applicable.
      Later, a  Texas  court's  ruling  on an unrelated solid
waste disposal case indicated that  certificates of  registration
were,  in  all  probability,  legally  invalid.  Because  the
certificates prescribed certain limitations and requirements,
they could be considered  as perm its; therefore,  they would
be prohibited under the Solid Waste Disposal Act.

Previous Projects and Public Hearings

      During 1970—72, a statewide  survey, conducted  by
TWQB   under   EPA  Grant   GO5-EC-00031-04,  was
undertaken to   examine  waste  disposal  practices  and
determine  what  problems might be involved.  The  survey
revealed  that most industries generating wastes considered
waste disposal to be a minor problem. Consequently, it was
difficult  to obtain   sound  information  regarding  the
characteristics and/or volumes of the various wastes being
generated.  Further, the utilization  of  new methods for
waste recovery and disposal, coupled with changes in the
types  and  volumes  of  wastes  being generated,  would
seriously  affect  the  continuing   reliability  of  any
information collected  on a  one-time basis. To be  useful,
data on generation rates,  waste characteristics, disposal
methods  and  recovery  techniques  would  have  to  be
collected  by consistent methods over a period of time.
Then periodic analyses of such data could provide current
information from which  needs for  disposal capacity,  site
locations, and regulatory actions could be assessed.
      In  1973 a  coordinated surveillance and enforcement
project was undertaken as a joint  effort between the TWQB
and the Texas Department of Health Resources. This EPA
supported  project (Grant L-006083)  was undertaken  to
                                                      -282-

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explore surveillance and enforcement techniques, evaluate
present  solid  waste  regulations  and  procedures,  and
determine manpower and  fiscal  requirements necessary to
provide an effective level of solid waste management. The
information  compiled  from  this  project  was  useful in
establishing  compliance  monitoring  procedures   and
budgetary needs.
      In recent  years, public  objections to the installation
of  new  waste disposal sites  had seriously  hampered the
efforts  of  various commercial  entities  to  expand waste
disposal  capacity  within  the  State.   In  1974,  TWQB
conducted  a  statewide series  of  15 public hearings to
provide a forum in which private citizens,  industries, and
waste disposal entities could address various waste disposal
problems.  Testimonies given at  these  hearings  expressed
concern for the safe transportation  of wastes as well as for
the proper  location of disposal sites. The hearings verified
that there were widespread objections to the creation of
waste disposal sites in close proximity to populated areas.
Special concern for the safe  handling of hazardous wastes
was also noted.  Testimonies given  at  the hearings and
numerous cases investigated by  the TWQB staff indicated
that improper disposal practices were not uncommon.
      The  1974  hearings  and  preceding  studies clearly
indicated that greater control of waste handling,  storage,
and off-site disposal was needed.

Regulatory Development

      The  task  remained to  establish a regulatory system
which   would   exercise  sufficient   control   over  and
accumulate data about the handling, storage, and disposal
of  waste.   Basic   requirements   for   the  system
included:  (1) ample regulatory authority; (2) some criteria
for applying regulatory provisions; and  (3) the ability to be
operated  within   existing  manpower  and   budgetary
constraints.
      The   method  most  favorably  considered  was  a
shipping manifest (or "trip ticket")  system.  This method
had been discussed at public hearings in 1974 and was being
used in other  states.  Alternatives  to this method  were
limited. It  was not feasible  to require permits for  waste
carriers  because the Texas Railroad Commission already
had such requirements. Also, the trucking industry, with its
many independent operators, was less accessible and less
reliable  for  data  acquisition  than  the   stationary
manufacturer. An effective alternative would  be to require
off-site disposal permits which would specify disposal sites
and  reporting  requirements,  but  such  a  method was
considered  to   be   too   burdensome,   in   terms  of
 implementation  and maintenance,  for both  industry and
the TWQB.  Also,  as previously mentioned, such permit
 requirements might conflict with the statutory  prohibition
of on-site disposal permits. At  the other extreme, simply
 requiring record  keeping by generators and  receiving site
 operators  would  provide for data acquisition, but would
 probably be grossly ineffective in terms of control and data
 accuracy.
       The "trip ticket" method had  numerous  advantages.
 Procedural burdens would be minimal for  both the waste
 generator  and  TWQB because  no  authorization process
would be  necessary. Properly structured, such  a  system
would  require  that the  generator  control  the  off-site
disposal  of his waste, while providing a  mechanism to
detect,  investigate,  and  resolve  possible problems  with
improper disposal. Also, the method was suitable  for the
application  of  reporting provisions for acquiring data for
use in surveillance and planning.
      Criteria  for applying  the requirements of  such  a
system   were   not  readily  apparent.  Texas enjoys  an
industrial sector consisting of nearly 13,000 manufacturing
installations which generate many different types of waste
in various quantities. Because information translating waste
characteristics  and   quantities  into  a  relative  hazard
potential was  scarce, it was not readily apparent which
wastes  and waste quantities might  present  a  significant
environmental threat and thus need regulation.
      In the initial  draft of the shipping and  reporting
regulations  the criteria  employed were  based  upon: (1)
TWQB's waste  classification system; and (2) the size of the
generating  facility as indicated by the number of persons it
employed. These criteria  were chosen because information
on employees  was readily available,  and  the TWQB waste
classification system, which was already in use, provided a
relatively  reliable   index  of waste  characteristics.  Data
received under these criteria then  could be analyzed to
examine the effectiveness of this approach  and used to
develop criteria  for  relating  waste  classification to waste
quantity.  The  definitions of  Class I, II  and  III waste
included in the new  TWQB regulation are listed below. Also
listed is the new definition of hazardous waste.

   •  "Class I Waste" - All waste materials not classified as
      Class II or III, normally including all industrial solid
      wastes in liquid form and all hazardous wastes.

   •  "Class II Waste" —  Organic and  inorganic industrial
      solid waste that is readily decomposable in nature and
      contains  no hazardous waste materials.

   •  "Class III Waste" — Essentially inert and essentially
      insoluble industrial solid waste, usually  including
      materials such  as  rock,  brick,  glass,  dirt,  certain
      plastics   and  rubber,  etc., that  are  not  readily
      decomposable.

   •  "Industrial  Hazardous Waste"  —  Any  waste or
      mixture  of wastes  which,  in  the  judgment of the
      Executive  Director  (of TWQB),  is toxic,  corrosive,
      flammable, a  strong sensitizer or irritant, generates
      sudden  pressure by decomposition,  heat or  other
      means and  would therefore be  likely  to  cause
      substantial personal injury, serious illness, or  harm to
      human and other living organisms.

      Five  preliminary hearings were held across the State
 to discuss the proposed shipping and reporting regulations
 and  draft regulations for commercial  and  noncommercial
 disposal operations. Based  on manpower and  budgetary
 constraints, the  draft   of   the  shipping  and  reporting
 regulations required that industries  employing more  than
 250  persons issue  shipping tickets for and  report on all
 classes of waste.
                                                        -283-

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     This approach was intended to restrict the number of
active   participants  to  a   manageable  number  while
implementing controls  for  and acquiring data on a large
percentage of wastes being generated. However, testimonies
at the  preliminary hearings  expressed  concern  that  the
proposed system  would implement  controls for  wastes
presenting little potential hazard (Class II and III) while  not
providing controls  for  Class I wastes generated by smaller
companies.   Subsequent  TWQB  staff studies  of  Texas
manufacturing (discussed later) indicated that the number
of potential generators of Class  I waste was much greater
than had been anticipated. These  findings were reflected in
the  final document draft of the shipping and reporting
regulations. The final document required all generators to
issue shipping tickets for and compile monthly reports on
all  Class I off-site disposals. Monthly  reports  were also
required  from Class  I  commercial  disposal  sites —  a
provision  necessary  to verify shipment receipts. Annual
reports and record keeping  were required for  all  on-site
disposals of Class  I waste,  and  both on-site and off-site
disposals  of  Gass II   wastes produced  by   generators
employing   100 or more  persons.  The  100  employee
criterion for the reporting of Class II  waste was selected to
examine the waste generations  and  disposal  practices of
generators  who produce a significant quantity  of Class II
waste.   No  reporting  requirements  were  applicable to
Class III waste disposal.
      In  addition  to the basic requirements noted above,
several ancillary requirements considered critical  to the
effective implementation and operation of the system were
included. Provision was made to allow the agency to require
specific information (including chemical analysis) necessary
to  determine waste classifications.  In  conformance with
TWQB policy  regarding generator responsibility, shipping
procedures   not  only   required  the  issuance   of
shipping-control   tickets,  but   also  required   that  the
generator  designate the  disposal  site.  To  avoid  initial
confusion and allow for an orderly implementation of the
system, an industry was required to participate only after
being notified by the TWQB. All shipping and reporting
procedures were clearly outlined in the regulation, and all
 newly employed terms were  defined.  Also, specific actions
which constituted  violations  of the regulations were stated.
      The  final   draft  of   the  shipping and  reporting
 regulations  was   consolidated  with  the draft of  the
commercial  and  noncommercial  regulations  into  one
 comprehensive   document.   The  regulations  were
subsequently adopted by TWQB Order 75-1125-1 and took
 effect on December 31,  1975. The shipping and reporting
 provisions  were included in Chapter IV of the regulations,
 while definitions of terms were provided in Chapter I.

 SYSTEM DESIGN

 Procedural Basis

      The  shipping-control  and reporting   system  was
designed to achieve 2 objectives: (1) procedural clarity for
system  participants; and  (2) acquisition of reports which
would require a minimum amount of preparation for data
processing   while  providing   a   maximum  amount  of
information.
      The shipping procedure described in the regulations
requires  that  a waste  generator  issue  a  shipping  ticket
(manifest) for each shipment of Class I waste. The shipping
ticket is a  3-part form  comprised of an original  and 3
copies. The  generator retains one copy  for his records; the
other 2 copies are provided for the carrier and receiver. The
original,  showing  a  receiving  site  signature  verifying
shipment receipt,  is  returned to the  generator by the
carrier.  The regulation also  describes procedures for the
compilation of monthly summary reports by generators and
receivers and requires that annual reports be compiled from
records of all on-site and Class II off-site disposals. Record
keeping requirements are  mandatory. The off-site disposal
shipping procedures are schematically described in Figure 1.

Waste Classification Coding Subsystem

      A   major   problem  to  be  overcome  was  the
development of  a report format which would  provide a
maximum   amount of  data  without  requiring  clerical
encoding for keypunching.
      A  report  form  utilizing verbal  waste descriptions
would not be a satisfactory computer data source unless it
were first reviewed and  each  waste assigned a descriptive
code. Such  reports would require extensive and continuing
administrative  efforts   and   be  prone  to  errors  and
 inconsistencies.
      An alternative reporting  scheme that was considered
involved providing generic categories for different types of
industrial  waste.  The  categories  would  be  printed  on
shipping tickets and  report  forms for selection by  the
generator.  Keypunch codes for each category would then
be provided on  the  report  forms. However, this method
would  limit capabilities for data processing  and require
revision  of the  forms if the  number  of categories were
increased.  Similar approaches were being  tried in other
states with these  limitations  as well  as other problems
becoming evident
      A third approach  was developed  for use  in  the
system.   The   method  involved   assigning  a  waste
classification code (waste code) to each waste produced by
a generator prior to  involving the generator in shipping
ticket issuance and reporting.  This scheme did not  require
the presumptive action of establishing waste categories or
groups, was easily expandable, and provided an extensive
capability for data retrieval. The waste code file could be
built as the  system  was implemented, thereby avoiding
possible delays. Also,  a high degree of consistency in waste
classification  and  coding could  be achieved by assigning
codes at the agency's central office. Possibilities for errors
would  be  limited to  3 points:  manual  entries by  the
 generator on either the shipping ticket or the report forms,
 or in keypunch operations.
      The coding format developed is displayed in Figure 2.
The  first digit of the  six-digit numeric code provides the
 waste classification for easy interpretation.
                                                       -284

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                                               FIGURE 1

                         OFF-SITE DISPOSAL SHIPPING CONTROL PROCEDURES
  TEX AS WATER
QUALITY BOARD
                                 WASTE
                              GENERATOR
CARRIER
                                                                  RECEIVER
                                                                (DISPOSAL SITE)
Register Class I
  Generators
                            Receive:  Notice of
                                Registration
                                   i
                             Originate Shipping
                              Control Ticket
                                   and
                             Designate Receiver
                                                               1
                                                             Sign Ticket,
                                                             Detach Copy
                                 Copy to
                                 Records
                                                           Deliver Shipment
                                 Original
                                    to
                                 Records
->
ADP Reports for
  Surveillance
  and Planning
    1
 Receive Process
 for Data Entry
                                   I
                                  Records
                              Compile Monthly
                             Shipment Summary
                                  Report
                                                             Detach Copy,
                                                            Return Original
                                                             to Generator
                                                                1
                                                               Copy to
                                                               Records
                                                                1
                                                               Records
                             Receive, Sign
                            Ticket, Detach
                                Copy
                               Copy to
                               Records
                                                                                             1
                                                                                            Records
                                                                                              I
                            Compile Monthly
                            Receipt Summary
                                Report
                                                 -285-

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                         FIGURE 2

         WASTE CLASSIFICATION CODE FORMAT
                        CHLORINATED HYDROCARBON
   WASTE CODE        PESTICIDE PRODUCTION WASTE
         3 6
                    CATALOG DESCRIPTIVE REFERENCE
                      NUMBER

                    FORM IDENTIFIER:

                    0 = Liquid, Water Base
                    1 - Liquid, Other Base
                    2-(Open)
                    3 - Emulsion
                    4 - Sludge, Water Base
                    5 - Sludge, Other Base
                    6-(Open)
                    7 - Solid, Predominantly Inorganic
                    8 - Solid, Predominantly Organic
                    9-(Open)


                    TWQB WASTE CLASSIFICATION:

                    0 - Clan Code Not Assigned
                    1-Class I
                    2-Class II
                    3-dan III
                    4-9 - (Open)
 Design of Forms

      After  the  waste  coding  approach  was  chosen,
 problems  with  the design  of the  forms were greatly
 reduced. The Shipping-Control  Ticket (Form WQB-170). as
 previously  described,  is  a 3-part,   4-copy,  carbonless
 "snap-out" form.  Each  ticket  has a 6-digit, all-numeric,
 ticket number which is printed on the form. Instructions
 are printed on the reverse  side of each copy of the ticket
 for easy reference. The form provides a table in which 8
 wastes can be listed by waste code. Quantities are listed in
 one of 4 units:  gallons, tons, cubic yards, or drums. Part I,
 completed by the generator, provides a space to designate
 the receiver and a space for the TWOS solid waste disposal
 permit number. The generator also includes his registration
 number which refers to  his TWQB records. (The registration
 process is described later.) Parts II and III of the  form
 provide space for the carrier and receiver, respectively, to
 acknowledge  receipt of  the shipment and  include any
 necessary comments.
      The  generator's   report  form  (Industrial  Waste
 Shipment  Summary, Form WQB-171) and  the receiver's
 report form (Form WQB-172)  were  designed  for use as
 source documents for the solid waste data system described
 later  in this section. Each  form  reduces the information
 needed on  each shipment   to  a  line  of numerical  data.
 Instructions for completing a form are printed on its reverse
side.  The  Shipment Summary provides  spaces for the
generator's registration number,  waste codes, quantities and
units. Each shipment is itemized by shipping ticket number
and includes the date of shipment and the receiver's permit
number (TWQB permitted sites only). Other indicators are
used for nonindustrial disposal sites.
      The  Receipt Summary  provides the shipping ticket
number and date of receipt for each shipment. This allows
verification of  shipment receipt. No additional data are
required  from the receiver  because the generator's report
provides  all  the  basic  data  necessary  for any  analysis
involving  waste character  or quantity.  Generators and
receivers are provided all information necessary to complete
their  reports  on  their respective copies of the shipping
ticket
      The data provided by the 2 reports  do not allow the
TWQB to verify that the specific quantity of waste shipped
was  received.  This  provision  was  considered but not
included because  available  evidence indicated  that in the
vast majority of cases, problems with unauthorized off-site
disposal involved  indiscriminate  dumping  of entire loads
rather man partial dumping of loads prior to their reaching
the disposal  site.  However, the shipping-ticket procedure
provides  the generator and receiver  with  a mechanism  to
detect such problems because  the shipping ticket describes
the waste  volume which  is  normally  the  basis  for the
receiver's  disposal fee. Also,  the  shipping  ticket  itself  is
considered to be a deterrent to such actions by the carrier.
      By design, the TWQB regulations allow generators to
print their own copies of the  shipping  ticket form. To
alleviate some of the administrative burden and reduce the
possibilities for error, certain information can be preprinted
on the  forms  by  generators.  The agency provides  blank
forms and instructions for this purpose. The individuality
of each shipping  ticket is retained because the computer
program  considers  the ticket  number  and  registration
number together as a unique indentifying ticket number.
      Forms  for annual reporting of on-site disposals were
not developed during the project period. They are expected
to be similar to the Solid  Waste Management Inventory
Form (described later in this report) except waste codes
will be used. These reports might be eventually generated
by computer.

Development of Data Processing System

      As previously stated, the report forms were designed
as source  documents  for entries  into a  data  system for
industrial  solid   waste  management.   Preliminary
development of this system began with the inception of the
project and focused on the agency's needs for compliance
monitoring and planning.
      To date. TWQB Data Processing, Solid Waste Branch,
and Field Operations staffs have produced  a design for a
data system which deals exclusively with reported  data on
both  off-site and  on-site disposals. The solid  waste data
system is schematically described in Figure 3. Monthly and
annual reports  provide all  the  data on  Class I  off-site
disposals  and Class I and II disposals, respectively. These
reports require only cursory clerical editing before they are
keypunched  for  entry  into  the system. Solid  waste
generator  registrations  and disposal  site  permits  provide
generator- and disposer-specific data.  Certain information
                                                      -286-

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                                                                       FIGURES

                                              SOLID WASTE DATA SYSTEM SCHEMATIC FLOW DIAGRAM
1




Monthly
Reports
Class 1
Off-Site
Disposal

,
I

to
oo

.
1



Annual
Reports
Other
Class 1 &II
Disposal
1


                                     Edit
.1
1



Waste
Code
Origination
1


.1
1



Solid Waste
Registration and
Permits
Issued
1


                                    Encode
                                                              Keypunch

                                                                                        Report Data
                                                                                        (Historical)
                                                             Edit/Update
                                                              Programs
 Edit/Update
Error Reports
                                                                                        Report Data
                                                                                           File
                                                                                        Registration
                                                                                        Permit File
Waste Code
    File
                                                     System Report
                                                        Programs
                                                                                                                                              Registration
                                                                                                                                                 Permit
                                                                                                                                                 Master
                                                                                                                                                 Report
                                                                                    Waste
                                                                                     Code
                                                                                    Master
                                                                                    Report
                                                       Off-Site
                                                       Disposal
                                                       Activity
                                                                                                                                               On-Site
                                                                                                                                               Disposal
                                                                                                                                               Activity
                                                                                                                                                Other
                                                                                                                                                Data
                                                                                                                                               Analyses

-------
from  these  documents  is  encoded  and  subsequently
keypunched.   Additions  and   changes   to  the  waste
classification code subsystem are entered into the computer
in the same manner. Thus, all encoding tasks performed by
TWQB personnel are essentially nonrepetitive;  repetitive
encoding tasks  are performed by the reporters.
      Data from generator and agency sources are edited
and stored  by  one of several programs.  As indicated  in
Figure 3, these programs also produce file  update reports to
enable errors made in the entry process to be detected and
corrected.
       Included  in the planned outputs of the solid waste
data system  are 2 general purpose  and 2 specific purpose
reports.  The reports will be produced by  a set of programs
that access all or a portion of the system's  files to produce a
certain report.  For example, the Registration/Permit Master
Report  indicated  in  Figure 3 will be a general purpose
reference   report  produced   by    accessing  the
registration/permit file  for  all generator/disposer general
information and the waste code file for verbal descriptions
of the wastes  produced by each registered generator. The
Off-Site Disposal Activity Report will be  a specific purpose
report  (compliance  monitoring)  produced  from   the
registration/permit, waste code, and report data files. The 4
reports  indicated  in  Figure 3 were  planned during  the
project  As the amount  and  integrity of stored  data
increase, other data  analysis  reports might  be produced
from the existing file structure. Hence, the system should
provide  a  long-term  capability for data  analysis without
requiring significant modifications.
       Following is a  list of information to be retained for
each generator and commercial disposer.

       Registration (and Permit) Data File  Contents:
       1.    Name, address, phone, etc.
       2.    Registration (or permit number)
      3.   Classes  of  wastes  acceptable  for  disposal
            (permits only)
      4.   Generating   and  disposal   site   locations
           geographically  by district, county, river basin,
           and segment
      5.    Standard Industrial Classification codes
      6.    Wastes generated, class, disposition
      7.    Disposal,  treatment,  and storage facilities and
           corresponding waste
      8.    Other miscellaneous data
      9.    Verbal comments by staff

SYSTEM IMPLEMENTATION AND OPERATION

Overview

      During the development of  the  TWQB  Industrial
Solid  Waste  Management  Regulations  consideration  was
given  to the  administrative  task  of  implementing the
shipping-control and reporting system. Alternative methods
of implementation were weighted against various factors
which would   affect  the program's  effectiveness  and
efficiency. These factors included manpower and budgetary
constraints  and  the  result of  a  preliminary analysis of
potential  industrial  waste  generation  in Texas,  which
indicated  that 7,000 manufacturing sites needed at least an
initial   examination.  Three   general   approaches  to
implementation were considered:

      1.     Determining waste classification and procedural
            responsibilities for  each waste generator  by
            central   office  interpretation  of  submitted
            information;

      2.     Fostering participation and compliance through
            publication of suggested guidelines and relying
            on   industries  to   determine  both  the
            classification  of  their  wastes  and  their
            procedural   responsibilities   under  the
            regulations; and

      3.     Determining  waste   classifications  and
            procedural   responsibilities   for  each  waste
            generator by field  interview.

      Upon evaluation, the first alternative was considered
to be optimum, the second to be ineffective, and the third
to  be  inefficient  in  terms  of available  manpower  and
ineffective for achieving uniform waste classifications.
      The method ultimately developed for implementation
and operation  utilized a 2-step registration process  to
evaluate a  potential generator,  determine  his status, and
notify him of  procedural requirements.  Figure 4  depicts
this process. The 2 steps in the registration process, usually
referred  to as  inventory  and registration, are discussed
below. It  should be noted  that these steps are not directly
addressed in Chapter IV of the TWQB regulations.

Inventory

      The inventory process involves the  identification of
wastes and  waste  disposal practices. This information  is
gathered under the authority established in Chapters II and
IV of the TWQB regulations.
      The Industrial  Solid Waste Management Inventory
Form  was   developed  for  acquiring  from   each
potential  generator the minimum amount of information
necessary    to   determine  that  generator's  need  for
registration.  Because the  same information  was  needed
from  all generators, regardless of size, the design of the
form  stressed  simplicity. The  small generator needed only
to complete and return the one page; an industry generating
more than 5 wastes could reproduce the  waste inventory
table to include the additional  data.
      The primary mailing list for the inventory was drawn
from  the  Directory of Texas Manufacturers.  The  13,000
directory  listings were subjected to a preliminary computer
analysis based on Standard Industrial Classifications (SIC)
in order  to select those  manufacturers which the Solid
Waste Branch considered to be possible generators of Class I
or Class II waste. The results,  presented in  Table 1  placed
each prospective generator  within one of 12 TWQB districts
                                                       -288-

-------
                                            FIGURE 4

                           REGISTRATION PROCESS FLOW DIAGRAM
   TEXAS WATER QUALITY BOARD
                                                 WASTE GENERATOR
       Generator Identification
       Request Waste Inventory

   Waste description, quantity,
   disposition; facilities description
                                                    Complete Inventory,
                                                    Submit Notification
              Review
Adequate
Request Additional
      Data
      Waste Classification Review
                                                  	J
       On-Site Disposal Facilities
            Identification
                                No
                            Registration
                                                                                          J_
                                            Request Waste Reclassification Changes,
                                                   Corrections, Additions
X ? /
, V
	 ^r 	 — 	 • —
Issue Notice of
Registration

Central and Field Office
Surveillance

/

•4



^
1
1
Review, Follow Shipping
Control Procedures and
Record Keeping Requirements
1
Submit Monthly Reports
                                               -289

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                                                     TABLE 1

                                      DISTRIBUTION OF MANUFACTURERS






Statewide
District 1
District 2
District 3
District 4
District 5
District 6
District 7
District 8
District 9
District 10
District 11
District 12
District ?**


TOTAL
MANUFACTURERS

Number
13,338
561
608
1.171
3,993
973
531
2,686
1,017
268
655
438
400
37

Percent
100
4
5
9
30
7
4
20
8
2
5
3
3
-

TOTAL
CLASS 1 & II
GENERATORS

Number
12,066
513
548
1,036
3,695
856
483
2,463
883
230
604
380
345
30

Percent
100
4
5
9
31
7
4
20
7
2
5
3
3
-
POSSIBLE
CLASS!
GENERATORS '
EMPLOYEES
>100
Employees
893 -
19 (9)
22 (8)
46 (5)
302 (1)
59 (3)
46 (5)
259 (2)
50 (4)
11 <1D
27 (6)
13 (10)
26 (7)
13 -
<100"
Employees
5,408
237
241
361
1,715
312
157
1,367
318
79
289
155
171
6
POSSIBLE
CLASS II
GENERATORS'
EMPLOYEES
>100
Employees
764
21
32
70
246
90
43
72
65
14
46
43
16
6
<100"
Employees
5,001
236
253
559
1,432
395
237
765
450
126
242
169
132
5
         Includes approximately 2 percent for which employee code not known.
         Location not determined.
and categorized each generator as a possible  generator  of
Class I  or  Class II  waste  with more  or  less  than 100
employees. In accordance with the criteria in Chapter IV of
the  regulations,  inventory  forms were mailed to each
company suspected of  generating Class I waste or Class II
waste and employing more than 100 persons. The primary
mailing  list was supplemented with listings of possible
nonmanufacturing  waste  generators  compiled  by each
TWQB District Office. The process included the assignment
of  an inventory  control  number so that nonrespondents
could be detected and reviewed for further action.
      After the  necessary  information  was  collected, all
wastes were classified according to regulatory definitions of
Class I,  II and III  wastes and TWQB Technical  Guideline
No.   1: Waste  Evaluation and Classification. To  achieve
maximum  consistency   in   waste   classifications,  all
classification reviews were conducted by the Solid Waste
Branch   staff  chemist  When  waste  classifications  and
disposal   facility   identifications  were  completed,  the
inventory  data  were  compared  with  the  criteria  for
participation in the shipping and reporting procedures of
Chapter IV of the TWQB regulations. Those that met these
criteria   and/or  (in accordance with  Chapter II  of  the
regulations)  operated  an  on-site  disposal  facility, were
registered pursuant to the authority granted in  the Texas
Solid Waste Disposal Act  and the TWQB regulations. This
action is described below.
Registration
      By  design.   Chapter  IV  of  the  agency's  solid
waste  regulations   specifies  that  a  generator  is  not
required   to   comply  with   shipping  and   reporting
procedures  until   30  days  after  notification  by  the
TWQB   Executive   Director.   This  provision  allowed
the  inventory/registration  process  to  proceed  in  an
orderly,   methodical  fashion   without   automatically
assigning  noncompliant status   to  a  large segment of
Texas  industry.  The  official  notification   takes  the
form  of  a   notice  of   registration   transmitted   by
letter  from  the   agency's  Chief  of  the  Solid  Waste
Branch.  Registrations  for  Class I  off-site  shippers are
transmitted   by   registered  mail   to   provide evidence
of  receipt
      The   registration  packet   includes  all  of  the
shipping-control (manifest) and report forms to be used by
the generator. The notice of registration provides the waste
codes and registration number required for the completion
of  the forms.  Also  included  are  all  applicable  TWQB
technical guidelines  pertaining to the generator's disposal
operations,  a list  of authorized  industrial waste disposal
sites, and the  TWQB Industrial  Solid Waste Management
Regulations.
      Thus,  the registration process allows  the TWQB to
assign waste classifications to the industrial waste stream of
any given company. Simultaneously, the registration serves
                                                        -290-

-------
                                    FIGURES

       STATISTICAL SUMMARY: SHIPPING CONTROL AND REPORTING SYSTEM
                      IMPLEMENTATION, DECEMBER 31,1976
                        INVENTORY/REGISTRATION STATUS

Total Inventories Transmitted	7,578

Total Inventories Received and Reviewed    	4,753  (63%)

Total Inventories Processed  	4,033
     Generators Registered   	753
     Not Generators or Not Registered   	3,280

Total in Processing   	720
                    DISTRIBUTION OF REGISTERED GENERATORS


TWQB
DISTRICT
1
2
3
4
5
6
7
8
g
10

11
12
TOTAL
NUMBER OF
SOLID WASTE
REGISTRATIONS
IN EFFECT
26
20
31
206
43
59
248
29
6
43

8
34
753

PERCENT
OF TOTAL
REGISTRATIONS
3.5
2.7
4.1
27.4
5.7
7.8
32.9
3.8
.8
5.7
1 1
I . I
4.5
100.0

NUMBER OF
CLASS 1
OFF-SITE
6
11
23
189
29
34
726
23
6
12
5

24
588

PERCENT
OF TOTAL
REGISTRATIONS
2.8
1.4
3.1
25.1
3.9
4.5
30.0
3.1
.8
1.6
.7

3.2
78.2
                                      -291 -

-------
as  a  tool  for  notifying  participants  in  the shipping and
reporting system of their procedural requirements and for
transmitting the information necessary for compliance.
      Previously  mentioned but  not discussed were the
TWQB  technical guidelines. These guidelines recommend
methods  and  specifications for various aspects of waste
disposal  as  prescribed   by   waste   classification.   The
registration process has presented  many opportunities to
evaluate the solid waste leachate test procedure set forth in
Technical  Guideline 1.  A  request for  the upward numeric
reclassification of a waste (i.e.. Class I to Class II,  etc.) is
considered  only  after  a  chemical   analysis  has  been
performed in accordance with the procedures in Technical
Guideline 1. The leachate  test procedure has proven to be a
useful tool for determining the relative potential for water
quality  hazard posed by  the disposal of any given waste.
The results of such tests eventually might be coupled with
the waste classification coding subsystem to allow such data
to be retrieved  by specific  waste codes.

Alternate Procedures

      While the system was being implemented, the need
for at least one alternate procedure became evident. Certain
Class I  waste generators  might store their wastes for long
periods before shipping them  for disposal; their monthly
reports indicating "no shipments" would be of little value.
Consequently,   an  alternate   reporting  procedure  was
developed for  generators  who  ship Class I waste less than
once in any 3  month period. These low frequency shippers
fulfill their reporting responsibilities by transmitting a copy
of  the shipping manifest to the TWQB central office after
each shipment.
      Present shipping and reporting  procedures do not
require  that  ticket  copies be submitted  with monthly
summary reports. However, the tickets must be retained on
file for 3 years  and be available for inspection by the TWQB
field  staff. Consideration is  being given  to modifying
procedures  to  require  that   ticket  copies accompany
the monthly reports. This change would make ticket copies
readily  available  to the  TWQB  central  office staff for
monitoring and clarifying erroneous entries  on the report
forms.

SUMMARY

Ancillary Activities

      Throughout the  project period,   the  Solid  Waste
Branch  staff coordinated  their efforts with  the agency's
Field Operations  Division staff in the central  office as well
 as  in  the district offices. The TWQB  District 7 office,
 located  in  the  Houston  industrial  complex,  provided
 valuable  advisory   services   during  the   design   and
 implementation  phases  of the project. Also,  2 technical
 conferences were held with district supervisors and selected
 field  staff members  to  brief them on the new  Industrial
 Solid   Waste   Management   Regulations   and   the
 administrative  procedures being  used to  implement the
 shipping and reporting system.
      Pursuant to the adoption of the new regulations, the
 TWQB   District 7   staff  (Field   Operations   Division)
 developed  a   new  solid   waste   compliance  survey
 form  for   use  by  field  inspectors.   This  form   is
 currently  being  tested.

 Project Summary

      At the conclusion  of the project in June  1976, all of
 the goals established  in the 14-point work plan of the grant
 contract were achieved.  However, during the project, minor
 modifications to the work plan and budget were made in
 cooperation with the EPA Region VI office to facilitate the
 effective   reassessment   and   reorganization   of  project
 activities.
      The solid waste management inventory  commenced
 during the third project quarter with the mailing of  over
 7,000  inventory packets.  By  June  30,  1976,  nearly
 50 percent of  the inventories  had  been  completed and
 returned, and  processing had  resulted in registrations for
 330 generators of Class  I waste.  Two hundred  of  the
 generators  who  had   been   registered   were  actively
 submitting monthly off-site disposal reports. A review of
 the first series of off-site disposal reports  resulted in the
 identification of several  unauthorized disposal  operations.
      Figure  5  displays  data reflecting progress made in
 implementing the  system  through  December  1976. As
 processing proceeds,  the relative  proportion of  Class I
 off-site generators is expected to decrease because priority
 was given to registering such generators.
      From  its  inception,  the project was intended  to
establish   a   system  to  be   maintained  with   State
 appropriations  for industrial solid waste management. The
termination of the project can be considered as a significant
milestone toward the establishment of an  effective waste
 management program.
NOTE:  The Texas Water Quality Board was reorganized as part of the Texas Department of Water Resources on September 1, 1977.
        Questions regarding this paper or any aspect of the State of Texas' Industrial Waste Shipping Control and Reporting System should
        be directed to the author at the Texas Department of Water Resources, P. O. Box 13087, Austin, Texas 78711.
                                                       -292-

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                            PROPER DISPOSAL OF HAZARDOUS WASTES IN MISSOURI

                                                  R. W. Pappenfort
                                               Environmental Engineer
                                      Missouri Department of Natural Resources
                                                 Jefferson City, MO
      In  recent  years, the disposal  of complex chemical
waste materials into the environment has been brought to
the attention of  the  public. The Kepone  incident  on
Chesapeake Bay  is a  prime example.  As a result of  this
catastrophe  and others. Congress adopted and  President
Ford  signed  into  law  on  October 21,  1976,  Public
Law 94-580, the Resource Conservation and Recovery  Act
of 1976 (RCRA). The purpose of this act is ". . . to provide
technical and  financial  assistance for the development of
management plans and facilities for the recovery of energy
and other resources  from discarded  materials and for the
safe disposal of discarded materials, and  to  regulate the
management of hazardous waste."
      Missouri   has   not  been   left  unscarred.   From
1968-1971,  prior to passage  of  the Missouri Solid Waste
Management   Law   (1972),  4   major  incidents  were
documented  as  cases of environmental damage resulting
from  the improper disposal of hazardous waste. As a result
of these incidents, 2 people died,  11 became ill (including 2
small  children),  numerous livestock perished, the  Kansas
City water supply became polluted, and  the  Cuivre River
was closed to fishing for one year.
      First of all, what is hazardous  waste? RCRA requires
that  not later  than  18 months  after  enactment,  the
Administrator of EPA shall develop and promulgate criteria
for identifying  the  characteristics  of hazardous  wastes.
Several  states,  such  as  Minnesota and Washington, have
already   established   criteria  for  the  identification  of
hazardous wastes. The  general provisions  of  the Missouri
Solid  Waste Rules and Regulations (effective 1974) define
hazardous wastes as waste materials that are:
      Toxic or poisonous;
      Corrosive;
      Irritating or sensitizing;
      Radioactive;
      Biologically infectious;
      Explosive;
      Flammable; or
      A  significant  hazard
      environment.
to  human  health  and the
      Numerous  other  definitions  are  available, but  for
purposes of this paper, this definition will  suffice.

THE HAZARDOUS WASTE PROJECT

      In  January  1975,  the  Missouri  Department  of
Natural Resources  initiated a  hazardous waste project in
Missouri.  This  project was to involve on a statewide basis:
   •  A survey of hazardous waste generation;
   •  Drafting of hazardous waste legislation;
   •  Development of a hazardous waste management plan;
   •  Promotion of the recycling of hazardous wastes both
     at the regional level and at the point of generation;
     and
   •  Promotion  of   construction  of  disposal  sites  for
     hazardous wastes.

THE HAZARDOUS WASTE SURVEY

     The hazardous waste survey began in early 1975 and
was completed in December  1976.  It involved 3 man-years'
time, 481  interviews and plant-site visits, and an estimated
40,000 miles of travel. In the Kansas City area, a survey of
117 plants in Missouri was  done for  the  Department  of
Natural Resources by the  Mid-America Regional  Council
(MARC)  which also coordinated that survey with a survey
being conducted on  the  Kansas side  (i.e., Leavenworth,
Wyandotte, and Johnson Counties in Kansas).
     The  survey   form  requested  the  following
information:

   •  Identification of establishment including:

        Name and location of facility;
        Person interviewed;
        Person responsible for the facility;
        Number of employees;
        Normal operating schedule;
        Standard Industrial Classification (SIC);
        Seasonal variations in production; and
        Plot of  on-site process  waste, storage  and  disposal
        sites.

   •  Wastes generated as a result of operations

        Flow diagram of processes  including waste flow
        outputs;
        Process mass balance; and
        Conventional solid waste generation.

   •  Storage and transportation of wastes including:

        Description of wastes;
        Method of storage;
        Quantity stored;
        Frequency of collection;
        Location of storage;
        Means of collection; and
        Name and address of all collectors.
                                                       -293-

-------
  •  Treatment and disposal including:

        Description of process waste;
        Treatment methods before disposal;
        Waste streams after treatment;
        Quantity per year;
        Methods of disposal and comments;
        Details of any on-site land disposal or incinerator;
        and
        Empty container disposal.

   •   Expenditures  and  receipts for waste  management
      including:

        Expenditures  (process,  storage, transportation,
        disposal);
        Receipts (amount of wastes  salvaged, method of
        salvage, total annual return) from salvage; and
        Future  plans  (research,  exchanges  with other
        plants, opinion about a waste exchange).

      These data were then condensed and transferred to a
specially designed and coded data card shown in Figures 1
(front of card) and 2 (back of card). All amounts of wastes
ware  converted  to  metric tons (kkg).  One metric ton is
equivalent  to 2205 English pounds or 1.1025 English tons.
     Companies  were selected  for the  survey  using the
following criteria:

   •  SIC  number (particularly those plants with SIC codes
     which matched those designated  by the U. S. EPA
     Office of Solid Waste Management in its Hazardous
     Wastes Practices Assessment Studies  for   Thirteen
     Industries);
                              existing  hazardous waste
   •  Size of industry;

   •  Plants  known to  have
     disposal problems; and

   •  Sampling of other SIC groups not covered in the EPA
     assessment.

     A  summary  of  the  findings  of  the  survey  are
presented  in  Tables 1,  2,  and  3.  In  addition  to  the
424,700 metric  tons/yr  of  hazardous wastes shown  in
Table 2,  it  was  also  found  through analysis of  sewer
discharges in Kansas City and St. Louis and some National
Pollution  Discharge  Elimination System (NPDES)  permits
that  an  additional   245,603 metric  tons/yr  of  pure
contaminants are being discharged either to sewers or to the
waters of the State. The hazardous waste identified as being
discharged to sewers or to state waters represents data from
only about 30 percent of the larger plants surveyed.
                                                    TABLE 1

                                                 SUMMARY OF
                             HAZARDOUS WASTE SURVEY FINDINGS IN MISSOURI
                                                      1976

Plants Surveyed
Total Plants
(Est. June 1976)
Total Employees in
Plants Surveyed
Total Employees
(Est June 1976)
Total Population
(Est. 1976)
Percent Plants Surveyed
Percent Employees Surveyed
ST. LOUIS
AREA1
217
2,416
113,201
204,469
1,920,000
9.0
55.4
KANSAS
CITY
AREA2
117
1,077
53,554
94,690
910,000
10.9
56.6
AREA
OUTSIDE
MISSOURI
147
2,380
40,581
147,776
2,170.000
6.2
27.5
TOTAL
481
5,873
207,336
446,935
5,000,000
8.2
46.4
       1  St. Louis City, St. Louis County, St. Charles, Jefferson and Franklin Counties.
       2  Jackson, Cass, Plane, Clay and Ray Counties.
                                                        294

-------
                                                        FIGURE 1

                                        HAZARDOUS WASTE SURVEY DATA CARD (FRONT)
                                                 COMPANY NAME
LOCATION
  CODE  •<
 en
   SIZE
                                                       t
                                                                                             \
ABCDEFGHIJK
- NAMF Bicentennial Widgets, Inc
LMNOPQRST
SIC # GROUP NAME
3496 Misc. Products
U V W X Y Z FL SV
PRODUCTS
Widgets -«
« STREET 1 Jefferson Ave. *•
" CITY Washineton ZIP 63090
" COUNTY Franklin ( 1) RFRION EWGCC

f 10l WASTF HA 11
2 #FMPinVFFS 13 DATF SURVEYED 7-4-76 WASTF Trash
PERSON TO CONTACT
01 NAMF A. J. Doe
"* TITLF Plant Manager
* PHONF 314/ 123-1776
NAMp Adams & Sons
32 Revere St.
ADDRESS Waehinaton MO
PHONE 314/ 245-6341
K>
LERS AND COLLECTORS -
Sludge ^
Hancock Bros. »
1620 Jackson Dr.
Union MO M
314/ 623-4837
fnone —
SOIJRHF: MDMM D & R SIIRVFY OTHFR Conversation -
u REMARKS: *.
-j Co. is leading widget mfg. in Midwest. Only HW is metal-plating sludge.
5 Red, white & blue dyes are non- toxic.
:VI
8
3 «
en _.
CM
™IZ 01 61 81 Li 91 SI M Cl El 11 01
68^ 9S^£Z I
8 L 9 S f E Z I
                V
A
                                   + SIC
                                   CODE
                                         HAZARDOUS WASTE CODE
           DISPOSAL

-------
              FIGURE 2



HAZARDOUS WASTE SURVEY DATA CARD (BACK)
"::l
II "
V
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f*.
r*
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WASTE ITEM

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DESCRIPTION
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2. Trash







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n












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t»

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-------
                                                    TABLE 2

                              MAJOR HAZARDOUS WASTE GROUPS BY REGIONS1
HAZARDOUS
WASTE
Acids
Alkalies
Solvents
Waste Oils
Paint Sludges4
Toxic Metals
(Plating)
Toxic Metals
(Other)
Other Organic— Inorganic
Chemical Wastes^
Miscellaneous6
TOTAL
ST.LOUIS
AREA2
9,947
18,330
6,262
6,264
7,957

41,945

9,826

173,288
2,972
276,791
KANSAS
CITY
AREA3
29,476
12,305
3.525
19,892
6,524

445

5,268

13,471
484
91 ,390
AREA
OUTSIDE
MISSOURI
7,520
661
2,913
4,944
749

13,293

10,751

11,161
4,527
56,519
TOTAL
46,943
31,296
12,700
31,100
15,230

55,683

25,845

197,920
7,983
424,700
               1  All numbers shown are in metric tons (2,205 lbs.)/yr., excluding sewered wastes and NPDES
                  discharges.
               2  St. Louis City, St. Louis County, St. Charles, Jefferson and Franklin Counties.
               3  Jackson, Cass, Platte, Clay and Ray Counties.
               4  Includes paint filters, pigments, scrap paint.
               5  Includes organic—inorganic chemicals, pesticides, cyanides.
               6  Includes contaminated empty containers, radioactive wastes, explosives, asbestos.
      Only 14 percent of the total  hazardous waste shown
in Table 2  is  currently  being disposed  at a permitted
hazardous  waste facility intrastate or outside the State.
Data  from  15  disposal/recycling  firms in  the  Midwest
indicates Missouri is currently exporting 1.4 times as much
hazardous  waste as  it  imports.  Total  hazardous waste
reported from facilities outside the  State amounted to
76,166 metric tons/yr.
      The number of potential hazardous waste producers
was  estimated at  2,150.  The  present total amount of
hazardous  waste produced is  estimated to be 1 million
metric tons/yr.,  and that amount is increasing at a rate of
10—15 percent/yr.  This total  amount  does not  include
9,310,306 metric tons/yr.of materials such as fly ash, mine
tailings, foundry sands,  baghouse dusts, and slags, whose
hazardous properties are under study at present.


DRAFTING OF HAZARDOUS WASTE LEGISLATION

      Missouri House Bill  No. 318 (MHB  318) (pre-filed
December 1,   1976)  "The  Missouri   Hazardous  Waste
Management  Law" is currently  being introduced  in the
79th General Assembly of the State  of Missouri.
      This  bill culminates  5 months of intensive  work by
100 persons who served on  a voluntary  drafting committee.
Representatives  from  industry,   state   environmental
agencies,  waste  haulers, disposal  firms,  environmental
groups, and citizens groups,  such as the League of Women
Voters,  were  involved  in  the  drafting  of  MHB 318.
Although it is not possible to describe the bill in detail due
to its complexity, this legislation is a necessary tool for the
implementation of any  hazardous waste management plan
for Missouri.

PROMOTION   OF   HAZARDOUS  WASTE
RECYCLING/EXCHANGES

      Through the efforts of  the  Department of Natural
Resources, the St. Louis Regional Commerce and Growth
Association (RCGA)  and  other  organizations, the first
industrial waste  exchange in the nation was successfully
established  in  1976. The  concept  was developed from
similar exchanges in European and  Scandinavian countries.
The RCGA runs the exchange and  publishes a quarterly
listing of hazardous wastes available for reuse or sale in the
interest of resource recovery and reducing  the volume of
industrial waste.
      The  Directory  of Facilities Available  to Missouri
Industry for Disposal or Treatment of Hazardous Wastes,
published  yearly,  is  available through  the  Solid  Waste
Management  Program  of  the  Missouri  Department  of
Natural  Resources and  provides  information about  18
recycling and disposal firms in the Missouri area in addition
to a description of each facility available.
                                                       -297-

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                                                    TABLE 3

                             MAJOR HAZARDOUS WASTE GROUPS BY REGIONS1
HAZARDOUS
WASTE
Acids
Alkalies
Solvents
Waste Oils
Paint Sludges
Toxic Metals4
(Plating)
Toxic Metals
(Other)
Other Organic— Inorganic
Chemical Wastes5
Miscellaneous6
TOTAL
ST. LOUIS
AREA2
190,440
85
—
6,208
—
106

187
8,146
244
205,416
KANSAS
CITY
AREA3
16,958
562
—
180
—
639

59
6,786
25,184
AREA
OUTSIDE
MISSOURI
14,405
6
_
3
—
96

35
422
36
15,003
TOTAL
221,803
653
_
6,391
—
841

281
15,354
280
245,603
               1  All numbers shown are in metric torts (2,205 lbs.)/yr., sewered wastes and NPOES discharges only.
               2  St. Louis City, St.  Louis County, St. Charles, Jefferson and Franklin Counties.
               3  Jackson, Cass, Platte, Clay and Ray Counties.
               4  Pure metal ion in solution.
               5  Includes organic—inorganic chemicals, pesticides, cyanides.
               6  Includes contaminated empty containers, radioactive wastes, explosives, asbestos.
NEW HAZARDOUS WASTE DISPOSAL  FACILITIES IN
MISSOURI

      In 1975—1976, the Solid Waste Management Program
issued permits for 3 new  hazardous waste facilities listed
below:

   •  Wheeling Disposal Service, St. Joseph, Missouri;
   •  BFI  Chemical Landfill, Missouri City,  Missouri; and
   •  Ace Pipe Cleaning Co.,  Lawson, Missouri.

      These  facilities use  the  following  techniques in
disposing of industrial wastes:

   •  Waste oil farming (aerobic decomposition in soil);
   •  Lagooning;
   •  Cell burial of solids, sludges, and liquids in containers;
   •  Soil blending;
   •  Chemical fixation;
   •  Solar evaporation; and
   •  Liquid trenching.
      Detailed  descriptions  of these facilities are in the
Directory.

SUMMARY

      Missouri  has had numerous  incidents  resulting in
fatalities and environment damage as a result of improper
hazardous waste management.  The ultimate responsibility
for  proper  management  lies  with  Federal  and  State
governments  as outlined in RCRA. The Missouri hazardous
waste project began  in  1975  to  attempt to  alleviate the
problem  of  hazardous  waste  disposal. This  is  being
accomplished through:  the  results of the hazardous waste
survey  conducted  in  1975-1976; the  introduction of
MHB318,  "The  Missouri Hazardous  Waste  Management
Law" in December   1976;  helping establish  the St. Louis
Waste  Exchange;  publishing  the  Directory  of Facilities
Available for Recycling and Disposal of Hazardous Wastes;
and  promotion of and permitting of properly designed
special hazardous waste disposal sites in Missouri.
                                                      -298

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                                       SUMMARY AND CLOSING REMARKS

                                               Richard F. Peters, Chief
                                        Vector and Waste Management Section
                                        California State Department of Health
                                                  Sacramento, CA
      Perhaps the best advice that can be given to the last
speaker of a 4-day  conference  is to observe the 3 B's:  be
sincere, be brief, and be seated. I shall try to observe all 3.
      As you are aware  from reading the  program, this
conference  has  been  a  cooperative venture  sponsored
by: the  U. S.  Environmental  Protection  Agency  (EPA),
particularly Mr. Charles  T.  Bourns  from the  Region IX
office; the  Ventura Regional County Sanitation  District,
Jack Lambie,  principal   engineer  and   manager;  the
Governmental Refuse Collection and Disposal Association;
the  Western Federal  Regional  Council  Task  Force  for
Hazardous Materials Management of which  Mr. Bourns is
chairman; and  last  but certainly not least, the Vector and
Waste  Management   Section  of   the   California   State
Department of  Health.
      Anytime  a conference such as this  is  held, there is
always someone, usually inconspicuous, who has done most
of the work to make it a success. Therefore,  I have insisted
that the 2 gentlemen who have appeared  at the end of the
table be recognized for what they have  done to put this
conference  across: Mr.  Wade   Cornwell   and   Dr. Eric
Workman. I should not say  that they were  inconspicuous
because  anybody  who  went  to the front desk should
certainly  have  noticed that somebody  was working out
there, and they were the principals.
      I  believe  that it  is entirely appropriate to mention a
few statistics about this  conference. You have probably
wondered how many people actually attended; 314 people
registered, representing a  total  of 32 states, the District of
Columbia, and  3 Canadian provinces.
      Throughout this  conference I have been trying to gain
an impression about the program. Although I  recognize that
it was an effort to  display a level of achievement, if I were
to  rename the conference,  I would probably call it "The
Transitional Status of  Hazardous Waste  Management".
Certainly the conference has revealed the solution to many
pressing problems,  but the  problems that remain clearly
outnumber those that  have been solved.  I do not intend to
demean the accomplishments that have been made.
      Our  Hazardous  Waste   Management  Program  in
California  is  presently  entering  its  fourth   year.
 Representatives of  many other states probably believe that
our  program  is quite  ancient history  by comparison.
However, we certainly recognize that much remains to be
accomplished here. I  am  particularly impressed  with  the
statistics that  only 10 percent of  the nation's hazardous
wastes  are  presently  being managed at all  and  that a
32 percent increase in production of hazardous wastes is
anticipated within  the next decade. Also, only 2 percent of
the wastes that are being  managed are reclaimed and only 4
percent are treated. These statistics certainly suggest a long
 row to hoe.
      We  generally consider  something  to be  extensive
 when we refer to it as  having covered the whole waterfront.
 At this conference  we have covered much of the land front
and the air front as well as the waterfront. However, much
more  remains  to  be  discovered  about all 3. We have
presented definitions of all kinds for "hazardous  wastes"
giving  much substance for  thought.  We  have tried  to
characterize them, we  have tried to enumerate them, and
still they remain  to be thoroughly understood for what
they  are.  We  have  dramatized  chromium,  cadmium,
mercury, lead and  PCB's. We have acknowledged that if
indeed the hazard waste stream is ever to be diminished, we
must aim for an affirmative program  of  resource recovery.
Of course,  such a program involves a  cooperative approach
among federal, state and local government and the private
sector. In California we are just beginning to establish  an
information exchange  that will facilitate the objective  of
resource recovery.
     The disciplines which relate to the field of hazardous
waste  management  show  great career  promise  for the
future.   Certainly   geologists,  soil  scientists, chemists,
biologists,  and engineers have tremendous futures in this
field.  It  behooves  everyone to point young  people in the
direction that will  one  day enable them  to acquire a career
in  this  field.  There  probably are  too  few of these
professionals available  at  this point in  relation  to the
anticipated growth of the field.
      From the standpoint of the politics  of hazardous
waste  management,  much  remains to be done to  achieve
appropriate funding nationwide. Although adequate funds
were  appropriated for the  Resource  Conservation  and
Recovery  Act  of  1976, they were  never authorized for
expenditure in the amount of  the original appropriation.
All of  us must make evident to the new administration that
funding  for state  hazardous  waste management programs
must  continue. However, this  responsibility cannot  be
borne  entirely by government.  It must be  borne by the
private sector as well.
      I  would  now  like to recognize 2 members of our
Technical  Advisory   Committee  on  Hazardous Waste
Management who have  participated  prominently in this
conference: Donald R. Andres, Vice President of  EMCON
Associates,  Inc., and John A. Lambie, General Manager of
Ventura Regional  County Sanitation District. We certainly
appreciate their having participated so effectively.
      I  would  like to recognize J. D. Jackson for having
added  a little spice to  the program; I believe that everyone
who attended the banquet  received the same favorable
impression  as I.  We  would  also  like  to express  our
appreciation to the people  of Pacific  Reclamation and
Disposal, Inc., and of Sierra Reclamation and Disposal, Inc.,
who made yesterday's field trip a  reality. Finally,  I would
like to recognize Dr. Harvey Collins.  I  believe that I have
the  best  hazardous  waste  management  leader  in  the
United States,  and  I  believe that our  staff  reflects  his
leadership.
      Thank you.
                                                        -299-

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