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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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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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
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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.
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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
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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
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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.
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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.
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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
-------
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
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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.
- 14
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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,
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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.
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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.
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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
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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.
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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.
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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
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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.
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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
-28-
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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,
-29-
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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)
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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
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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
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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.
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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
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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
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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.
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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.
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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:
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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.
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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.
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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
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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.
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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.
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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
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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
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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.
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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
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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
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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.
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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
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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.
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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.
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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
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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
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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..
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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.
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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-
-------
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.
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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-
-------
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-
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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-
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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 •
-------
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 -
-------
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.
REFERENCES CITED
Anonymous. 1973. Monitoring for polychiorinated biphenyls in the
aquatic environment. Michigan Water Resources Commission.
Department of National Resources, Lansing, Michigan.
Bitton, G. 1975. Adsorption of viruses onto surfaces in soil and
water. Water Res. 9:473-484.
Bouwer, H.. J. C. Lance, and M. S. Riggs. 1974. High-rate land
treatment II. Water quality and economic aspects of the
Flushing Meadows Project. J. Water Poll. Cont. Fed.
46:844-859.
Braude, G. L., C. F. Jelinek, and P. Corneliussen. 1975. FDA's
overview of the potential health hazards associated with land
application of municipal waste-water sludge, p. 214—217. In
Proceedings of the National Conference on Municipal Sludge
Management and Disposal. Information Transfer, Inc.,
Rockville, Maryland.
Surge, W. D., W. N. Cramer, and E. Epstein. 1976. Pathogens in
sewage sludge and sludge compost. Trans. ASAE. (In press.)
Chaney, R. L. and P. M. Giordano. 1977. Microelements as related
to plant deficiencies and toxicities. In Soils for Management
and Utilization of Organic Wastes and Waste-waters. Soil Sci.
Soc. Amer. Madison, Wisconsin. (In press.)
Cliver, D. O. 1975. Virus association with waste-water solids.
Environ. Letters. 10:215—223.
Dean, A. B. 1975. Hazards from metals and organic pollutants in
sludge from municipal treatment plants. Presented at the
conference in connection with the International Water
Conservancy Exhibition, September 1—5, 1975. Copies
available from U. S. Environmental Protection Agency.
Cincinnati, Ohio.
Duggan, R, E., and P. E. Corneliussen. 1972. Dietary intake of
pesticide chemicals in the United States (III), June 1968-
April 1970. Pesticides Monit. J. 5:331-341.
Elinder, C., T. Kjellstrom, L. Friberg, P. Lind, and L. Linnman.
1976. Cadmium in kidney cortex, liver and pancreas from
Swedish autopsies. Arch. Environ. Health. 32:292—302.
Epstein, E. 1975. Effect of sewage sludge on some soil physical
properties. J. Environ. Qual. 4:139—142.
Epstein, E., and G. B. Willson. 1974. Composting sewage sludge.
p. 123—128. In Proceedings of the National Conference on
Municipal Sludge Management. Information Transfer, Inc.,
Rockville, Maryland.
Epstein, E. and G. B. Willson. 1975. Composting raw sludge.
p. 245—248. In Proceedings of the National Conference on
Municipal Sludge Management and Disposal. Information
Transfer, Inc., Rockville, Maryland.
Epstein, E., G. B. Willson, W. D. Burge, D. C. Mullen, and N. K.
Enkiri. 1976. A forced aeration system for composting sewage
sludge. J. Water Poll. Cont. Fed. 48:688-694.
144
-------
Fair, G. M., J. C. Geyner and D. A. Okun. 1971. Elements of water
supply and waste-water disposal. Second Edition. John Wiley
and Sons, New York. 634 p.
Parrel I, J. B. and G. Stern. 1975. Methods for reducing the infection
hazard of waste-water sludge, p. 12—28. In Radiation for a
Clean Environment. International Atomic Energy Agency.
Vienna, Austria.
Friberg, L., M. Pisator, and G. Nordberg. 1971. Cadmium in the
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
-------
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
-------
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-
-------
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
-------
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
-------
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.
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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
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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.
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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.
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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.
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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).
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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
-------
FIGURE 1
ROUTES OF MERCURY
INTO AIR & WATER
NATURE
o>
•vl
SOILS-
SEDIMENTS
MAN
AIR
SOLID
WASTES
ALL
USES
WATER
-------
FIGURE 2
RELATIVE CONTRIBUTION FROM
NATURAL & MAN-RELATED SOURCES
TOTAL- 2,732,000 K6
n
M NATURAL
-------
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
-------
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
-------
FIGURE 5
CONSUMPTIVE USES OF MERCUW-1973
BATTERIES
ELECTRICAL
CHLORALKALI
MANUFACTURING
\FINAL CONSUMPTION
TOTAL = 1,S2S,OOOf
-------
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
-------
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
-------
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
-------
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.
-------
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
-------
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.
-------
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
-------
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-
-------
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
-------
FIGURES
CONCEPTUAL EXCAVATION OF SATURATED REFUSE, LLANGOLLEN LANDFILL
oo
01
-------
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
-------
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
-------
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-
-------
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-
-------
FIGURE 1
LOCATION OF STRINGFELLOW CLASS I DISPOSAL SITE
AND DOWNSTREAM MONITORING WELLS
• \.-f- A •
- .... v 1 •
> ~- - - \"' '
-j'.- "". - '\ ^< »."--.•'
kXffiL^' 'j#r^* '^
-V
/'*" ' ' ""
-,,*•-'
.:
•.*»'". '• :'•-.<• --. - -,%i G",
""•^ if- [™,
,":- I x; -y//,
• - /A? ) ':^
-
r
'
'*:
-.-»,, •!
^ ^1-
^^MT
'* . ^
"4 i • ••<« ^Al Vx-Ur-!y~
-H^^^ >-A- y-Vv - -v. ^.xv
^:': '-I'?.
: • .•: •
• ••'••: :-
|n ':l;
: • • • I •
' '* --i* '
• ;«• - . ^i- v Clrn Avn . - ~
;..:::- ••• »t •-.-,*• ...ast..^.-/? KI • .
[ fl K2 • . "•=
•-;•; I;J.^.'-~l".'.'.! • > A,'-'- -
•"•.'. f, i ^i •*
•:• ;••• ?S r r(-: :••; v-v- -%'> j I!: '."; :-
I _,_x v ' . " .....'v.~.:..' . . \?,i ~*r[" '
^- ,-*-" "i ": %;'
-190
-------
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
|
.'.'.'
>,
T* Oil
DISPOSAL
SITE
:•;':•- V '••
r
(
: [
1 | ,
j
,
«.
2 |3 IQIIQ2 I2B2 RT60 '
PYRITE A A I2CI
DITCH / ouo M1SS,ON
i
I2EI 120 1
UK!
I2MI
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,
4
<
;
I 1
DISPOSAL.
SITE
,
112 13
P-,
01
1
1
1
'-
:
»
^
1 IQI IQ2 I2B2 RT6O
•RITE 4A >2CI
TCM
OLD MISSIOr
•
UEI I2QI I1R1 FIK2 1"
IZKI (CHAf
I2MI
1 I2M2
(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
•
",'
IQI IQ2 I2B2 HT60
f 4 IZCI
/ T OI_O MISSION
j/ BLVD.
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-
-------
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-
-------
FIGURE 11
EVAPORATIVE POND DESIGN LIFE
5 6 7 8 9 10
POND LIFE (YEARS)
-205-
30 40 50 60 70 80 90 100
-------
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
-------
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
-------
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-
-------
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
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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
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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.
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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.
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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-
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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-
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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-
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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 -
-------
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.
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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
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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.
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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.
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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.
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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
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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
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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.
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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.
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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)
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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
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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
248-
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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
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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
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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.
REFERENCES CITED
1. Office of Solid Waste Management Programs, U.S.
Environmental Protection Agency. 1975. Industrial waste
management 7 conference papers. Environmental
Protection Publication SW-156. Washington, U.S.
Government Printing Office, p. 111.
2. National Academy of Sciences. 1975. Principles for evaluating
chemicals in the environment. Washington, D.C., Printing
and Publishing Office.
3. Personal communication. January, 1977. M. W. Anders,
Department of Pharmacology, University of Minnesota, to
J. A. Kinsey, Minnesota Pollution Control Agency.
4. Booz-Allen Applied Research, Inc. 1973. A study of hazardous
waste materials, hazardous effects and disposal methods.
U. S. Environmental Protection Agency. 3v. (Distributed
by National Technical Information Service, Springfield,
Virginia, as PB-221 464.)
5. Battelle Memorial Institute. 1973. Program for the
management of hazardous wastes. Prepared for
Environmental Protection Agency. Office of Solid Waste
Management Programs. Richland, Washington, p. 385.
6. Office of Water and Hazardous Materials, U. S. Environmental
Protection Agency. 1976. Quality criteria for water.
(Prepublication copy.)
7. Ottinger, R. S., et al. 1973. [TRW Systems Group.]
Recommended methods of reduction, neutralization,
recovery or disposal of hazardous waste. U. S.
Environmental Protection Agency. 16v. (Distributed by
National Technical Information Service, Springfield,
Virginia, as PB-224 579.)
8. Battelle Memorial Institute. Toxicological criteria for defining
hazardous waste for the Minnesota Pollution Control
Agency; final report. Richland, Washington, p. 175.
9. Atwell, P. E. 1976. Identifying and correcting groundwater
contamination at a land disposal site. In Proceedings;
Fourth National Congress Waste Management Technology
and Resource and Energy Recovery. U. S. Environmental
Protection Agency.
10. Hans, R. K. 1975. The generation, movement and alleviation of
leachate from solid waste land disposal sites. Waste Age.
11. Shuster, K. A. 1976. Leachate damage assessment, case study
of the Sayville solid waste disposal site in Islip (Long
Island), New York. Environmental Protection Publication
SW-509. Washington, U. S. Government Printing Office,
p. 18.
12. U. S. Environmental Protection Agency. July 1, 1975.
Regulations for the enforcement of the Federal
Insecticide, Fungicide and Rodenticide Act. In Code of
Federal Regulations, Title 40, Part 162. Office of the
Federal Register, Washington, D.C.
13. Department of Transportation. October 1, 1975. Hazardous
materials regulations. In Code of Federal Regulations,
Title 49, Parts 170-179. Office of the Federal Register,
Washington, D.C.
14. National Research Council, National Academy of Sciences.
1974. System for evaluation of the hazards of bulk water
transportation of industrial chemicals; a report to the
Department of Transportation, United States Coast
Guard. Washington, D.C. p. 42. (Distributed by National
Technical Information Service, Springfield, Virginia, as
AD-782 476.)
15. Consumer Product Safety Commission. January 1, 1976.
Federal Hazardous Substances Act Regulations. In Code
of Federal Regulations, Title 16, Part 1500. Office of the
Federal Register, Washington, D.C.
16. Environmental Protection Agency. July 3, 1975. Pesticide
programs. Section 162; Registration, reregistration and
classification procedures for rebuttable presumptions
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-
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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.
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FIGURE 4
ENGINEERING CONTROLS
Earth Cover
With
Vegetation
Clay or
Liner
Cover
Clay
Liner
Chemical
Treatment
Bed
Leachate
Collection
System
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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
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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.
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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.
REFERENCES CITED
1. Esmaili, H. 1975. Control of gas flow from a sanitary landfill.
Environmental Engineering Division:555—566.
2. Parris, G. E. and F. E. Brinckman. 1976. Reactions which
relate to environmental mobility of arsenic and antimony.
11. Oxidation of trimethylorsine and trimethylstibine.
Environmental Science and Technology
X(12):1128-1134.
3. Markle, R. A., R. B. Iden, and F. A. Sliemers. 1976. A
preliminary examination of vinyl chloride emissions from
polymerization sludges during handling and land disposal.
Proceedings of the National Conference on Disposal of
Residues on Land. St. Louis, pp. 77—82.
4. Farmer, W. J., M. Yang, and J. Letey. 1976. Land disposal of
organic hazardous wastes containing HCB. Proceedings of
the National Conference on Disposal of Residues on
Land. St. Louis, pp. 83—86.
5. Streng, D. R. 1976. The effects of industrial sludges on landfill
leachates and gas. Proceedings of the National Conference
on Disposal of Residues on Land. St. Louis, pp 69—76.
6. Fenn, D. G., K. J. Hanley, and T. V. DeGeare. 1974. Use of a
water balance method for predicting leachate generation
from solid waste disposal sites. U. S. Environmental
Protection Agency. EPA/530/SW-168. Washington, D.C.
p. 40.
7. Lee, G. F., M. D. Piwoni, J. M. Lopez, G. M. Marian!, J. S.
Richardson, D. H. Homer, and F. Salen. 1975. Research
study for the development of dredged material disposal
criteria. U. S. Army Engineers' Water Experiment Station,
Vicksburg, Mississippi.
8. Hespe. E. D. 1971. Leach testing of immobilized radioactive
waste solids. Atomic Energy Review IX(1):195— 207.
9, Mullen, H., and S. I. Taub. 1976. Tracing leachate from
landfills — a conceptual approach. Proceedings of the
National Conference on Disposal of Residues on Land, St.
Louis. PP. 121-126.
10. Conners, J. R. 1975 Ultimate disposal of liquid wastes by
chemical fixation. Proceedings of the 29th Annual Purdue
Industrial Waste Conference. West Lafayette, Indiana.
11. Mahloch, J. L. 1976. Leachability and physical characteristics
of chemically stabilized hazardous waste. Proceedings of
the Hazardous Waste Research Symposium. Tucson.
pp. 127-138.
12. Liskowitz, J.W., P. C. Chan, R. B. Trattner, R. Diesnack, A. J.
Perna, M. I. Sheik, R. Traver, and J. Ellerbuch. 1976.
Evaluation of selected sorbents for the removal of
contaminants in leachate from industrial sludges.
Proceedings of the Hazardous Waste Research
Symposium. Tucson, pp. 162—176.
13. Fuller, W. H., C. McCarthy, B. A. Alesii, and E. Niebla.
1976. Liners for disposal sites to retard the migration of
pollutants. Proceedings of the Hazardous Waste Research
Symposium. Tucson, pp. 112—126.
14. Haxo, H.E. 1976. Evaluation of liner materials exposed to
leachate: Second interim report. U. S. Environmental
Protection Agency, EPA/600/2-76-255, Washington, D.C.
p. 54.
15. Geswein, A. J. 1975. Liners for land disposal sites: An
assessment. U. S. Environmental Protection Agency,
EPA/530/SW-137, Washington. D.C., p. 66.
16. Hughes, J. 1975. Use of bentonite as a soil sealant for leachate
control in sanitary landfills. American Colloid Company,
New York. p. 36.
17. Anonymous. 1972. Groundwater hydraulics. U. S. Geological
Survey, Washington, D.C. p. 70.
18. Reeve, R. C. 1965. Hydraulic head. Methods of soil analysis.
Madison, Wisconsin, pp. 180—196.
19. Klute, A. 1965. Laboratory measurement of hydraulic
conductivity of saturated soil. Methods of soil analysis.
Madison, Wisconsin, pp. 210—221.
20. Boersma, L. 1965. Field measurements of hydraulic
conductivity below a water table. Methods of soil
analysis. Madison, Wisconsin, pp. 222—233.
21. Korte, N. E., I. Skopp, W. H. Fuller, E. E. Niebla, and B. A.
Alesh. 1975. Trace element movement in soils: Influence
of soil physical and chemical properties. Soil Science
122:350-358.
22. Gloyna, E. F.. and R. L. Somks. 1977. Suitability of clay beds
for storage of industrial solid wastes. Proceedings of the
National Conference on Treatment and Disposal of
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
York. p. 332.
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,
accumulation, and tolerance of metals in the biosphere.
Proceedings on Land Resource Science. University of
Guelph, Guelph, Ontario.
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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.
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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).
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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.
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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
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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
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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
'
i
•••
r" -• -—.
'-, FHAMK1!
I
/
'
"
******
22: 2;::
- • 5 « A S
,' *******
• 5 I S3 2.2'i"
B SOCVtMT
C UCTAL ILUOOC ri>TWO NUTt
0 WSCELLAKrOUS ILUOOE
*CID ALKALI
OTHCN HA7AHOOUS WAITI
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.
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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
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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.
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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-
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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-
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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.
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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.
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• 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
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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)
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DESCRIPTION
1. Metal platlne aludae
2. Trash
kkg
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UN1SOMT ANALYSIS CARD
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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.
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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.
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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.
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