United States
Environmental Protection
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 8
Number 4

                                          This photo shows drums of hazardous wastes stacked at the Chemical Control Corp.  site  in
                                          Elizabeth, A/. J.. which  exploded  and burned  on April 21,  1981, before the State of
                                          New Jersey could complete removal of  what it charged were improperly stored wastes.
                                          For a view of this scene after the fire and explosion, turn to the inside back cover.
Land   and   Pollution
In this issue of EPA Journal, we
take; a look at the comprehensive
programs being carried out by
Federal, State and local  govern-
ment and industry to help heal
land pollution scars and protect
the public from  discarded hazar-
dous wastes.
   EPA  Administrator Anne M.
(ioisuch has  pledged that "The
Agency will continue to press
responsible parties  through
legal action if necessary  -to
clean up sites threatening public
health  or the environment " She
added that "where this cannot be
doiii>. or if  it  cannot be accom-
plished  in  a timely manner,  EPA
and  the States will finance
remedial action under Superfund
and seek recovery from  responsi-
ble  parties under separate  legal
  Rita M  Lavelle, Assistant Ad-
ministrator for Solid Waste and
Emergency Response, notes in
an interview in this issue of EPA
Journal that "effective handling
and disposition of hazardous
wastes is one of the most
challenging environmental
problems facing our country to-
day "
  Lavelle  emphasizes that her
first responsibility, as defined by
law, "is to protect human health
and the environment through ef-
fective administration of two
Federal laws  regulating hazar-
dous wastes."
  The two laws are  the
Resource Conservation and
Recovery Act, which tracks  and
regulates the  handling and dis-
posal of hazardous wastes,  and
the Comprehensive Environmen-
tal Response, Compensation,
and Liability Act—generally
referred to as  Superfund -which
deals with immediate and long-
range environmental problems
created  by hazardous materials.
   In this issue  we review the
operation and enforcement  of
programs set  up to carry out
these laws.
   The  magazine also examines
various approaches to dealing
with wastes such as incineration,
recycling and  land disposal.
   One article gives a report on
how wastes are  handled in some
of the more progressive  coun-
tries in Europe.
   Another  problem examined in
this issue is how industry and
gove'nment deal with hazardous
waste emergencies.
   With the Superfund law,  Rita
Lavelle predicts that "our past
offenses and present  problems
will be eliminated. With  RCRA
we can avoid creating new  of-
fenses while encouraging and
motivating development of affor-
dable technologies for disposal
of our waste.
   "Proper  application  and strict
enforcement of  those laws will
enable us to achieve our goal of
protecting human health  and the

                               United States
                               Environmental Protection
                              Office of
                              Public Affairs (A-107)
                              Washington  D C  20460
                               Volume 8
                               Number 4
                               July-August 1982
                          wEPA JOURNAL
                               Anne McGiH  Gorsuch, Administrator
                               Byron Nelson 111,  Director. Office of Public Affairs
                               Charles D.  Pierce,  Editor
                               Truman Temple, Associate Editor
 EPA is charged by Congress to protect
 the Nation's land, air and water systems
 Under a mandate of national environ-
 mental laws, the Agency strives 10 for-
 mulate and implement actions which lead
 to a compatible balance between human
 activities and the abiltty of natural
 systems to support and nurture life

 The EPA Journal is published bi-monthly
 by the U S Environmental Protection
       Hie Administrator of EPA has
 determined that the publication of this
 periodical is necessary m the transaction
 of ilit! public business required by law of
 this Agency Use of funds for printing this
 periodical has been approved by the
 Director of the Office of Management
 and Budget through 4' 1 '84 Views ex-
 pressed by authors do not necessarily
 reflect EPA policy Contributions and in-
 quiries should he addressed to the Editor
 1A 107). Waterside Mall. 401 M  St.
 S W . Washington. D C 20460 No per
      necessary to reproduce contents
 except copyrighted photos and other
 Front Cover: Two tow-headed
 youngsters view scenic landscape
stretching below rocky peak near
Skyline Drive in the Blue Ridge
Mountains of Virginia.
 Photo Credits  Photn, Bob Hentincks
    t;rj  Credits  Robert Flanagan and
 Ron Farrah

            EPA JOURNAL
Regulating Hazardous
Wastes   2
An interview with  Rita M.

A  Superfund Progress
Report   6
A review of what has been ac-
complished under a landmark
new law

A  Two-way Street  8
How EPA works with citizens
at  Superfund sites

Superfund  Helps New
Hampshire   10
A report by a Congressman on
the impact of Superfund in his

The First Inning of Super-
fund    12
The role  played by the Torrey
Canyon oil spill in establish-
ment of  Superfund

States Active in Hazardous
Waste Control   14
An article on how the States
are moving to  control hazar-
dous wastes
A Burning Answer to a  Dif-
ficult Question   16
One of mankind's oldest
alternatives  for disposing of
wastes may offer the  best
hope for the future

European Waste
Management   17
An account of how wastes are
being handled  abroad

Recycling and Waste Ex-
changes   18
Economic factors are  en-
couraging recycling and
recovery of materials

A Moveable Burner   20
EPA has helped develop an
incinerator which can  be
moved to disposal sites

Land Disposal
Regulations    22
EPA moves  to tighten con-
trols on  ground waste sites
Training  Local Officials
A report  on a course
developed on  handling of
hazardous materials
Simplifying Transport of
Hazardous Waste   24
A proposal for relieving  some
paperwork burdens

Hazardous Waste Enfor-
cement   26
The Agency's new emphasis
on environmental  results is

Emergency Responses by
Industry and Government 28
   The Leaking Tank Car on
      TC-4  28
   CHEMTREC   29
   The Environmental
      Response Team   30
   A  photo essay showing
      Agency  coordinators
      helping  direct removal
      of  hazardous wastes 31

The California Enforcement
Program  32
The  Attorney General from
the Golden State  reviews en-
forcement of hazardous waste
The annual rate for subscribers in the
US for the bi-monthly EPA Journal is
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price of a single copy of the Journal is
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An Interview
with  Rita M.  Lavelle.
Assistant Administrator
for Solid Waste
and Emergency Response
U.  What are your primary
goals as Assistant Ad-
ministrator for Solid Waste and
Emergency Response?

r\  My first responsibility is to
protect  human health and the
environment through effective
administration of two Federal
Acts regulating hazardous
wastes. One law is the Resource
Conservation and Recovery Act
(RCRA), which tracks and
regulates the  handling and dis-
posal of hazardous wastes.
Second is the Comprehensive
Environmental  Response, Com-
pensation, and Liability Act.
generally referred to as Super-
fund. It deals with immediate
and long-range environmental
problems created by improper
handling of hazardous materials.
  Effective handling and dis-
position of hazardous wastes is
one of the most challenging en-
vironmental problems facing our
country today. RCRA and Super-
fund are effective tools, but
Federal dollars, talent or ex-
perience cannot do the job alone.
One of  EPA's goals, therefore, is
to build an effective Federal-
State-industrial partnership
which  will develop an environ-
mentally sound system for dis-
posing of  hazardous waste.
Another is to manage the na-
tion's hazardous waste programs
consistent with four of President
Reagan's basic objectives which
are particularly relevant to  this
effort. These objectives are
regulatory reform, economic
recovery, control of government
spending and transfer of more
authority to State and local
governments. Happily, both
RCRA  and Superfund afford ex-
cellent examples of Administra-
tion success in implementing all
four of  these  policies.
              EPA JOURNAL

Q  Since you view this
program as a partnership, what
roles  do you see each partner
playing in  the  effort?

A  Protection of human health
and the environment  requires a
unique partnership consisting  of
as many as four sectors, ail of
whom share one common  dis-
tinction.  But the key  to the
success of all four sectors is the
work  of citizens who  zealously
seek to protect the quality of life
we enjoy in this country. These
citizens bring to this undertaking
varied talents and experiences.
   First the Federal partner sets
the standards and provides
oversight. The  States,
with  Federal assistance and
guidance, develop and enforce
their  own programs in accor-
dance with Federal guidelines,
Industry complies with the stan-
dards and  contributes technical
innovations. These  actions yield
not only better environmental
protection  but  better  products
and increased competition which
in turn  leads to still better tech-
nology. Local  governments work
with  both  industry  and their
other governmental partners
to provide  insight through
day-to-day waste management
activities. We cannot just wish
away the waste which is con-
comitant with the way of life we
all enjoy. We must face the
reality of almost half a billion
metric tons of solid wastes per
year  We must all work together
to handle and  dispose of it
properly. All of these partners are
meeting this challenge in
laudable fashion. The job is
manageable, and it can be  done.
Q  Are the States doing an
effective job of tackling  their
waste problem?

/\  The States are willing and
eager to handle their waste
problem. They  know as we  do
that those closest to the problem
are best able to handle it. For
non-hazardous  wastes, the
States have an enviable record.
They  have long-standing
programs which not only
regulate disposal but provide in-
centives for proper  management
techniques such as recycling  and
resource recovery. For hazardous
waste, Federal and state govern-
ments are still learning each day
how to regulate effectively. EPA
Administrator Anne Gorsuch
has now signed a complete
waste regulatory package at the
Federal level EPA can authorize
States to administer the entire
regulatory  program. So far 32
States have received interim ap-
proval from EPA to operate all or
part of the program. Four  States
have  authority  to issue permits
for all storage, treatment and in-
cineration facilities. By  1985,
forty  States are expected to have
final authorization to operate and
enforce the entire RCRA
program. That  authorization will
be based upon  the fact that their
programs are at least as
stringent as EPA's  if not  more
Q  Since the Superfund
program gives the Federal
government the funds to clean
up hazardous waste sites, what
role do you see for the  private

/\  Industry has probably the
most important role in managing
and  disposing  of  hazardous
waste. First, industry continues
to invest significantly in  im-
provement of treatment and
disposal facilities, as well  as their
technologies. Secondly, the
preferred solution to any problem
will generally be found closest to
the problem.  In most cases  and
without fanfare, industry is utiliz-
ing various on-site  technologies
to dispose of the waste  it
creates. This growing practice
removes a tremendous burden
from off-site disposal and treat-
ment facilities. When it comes to
existing sites already on  the
Superfund list for action, the
private sector again plays an im-
portant role. First, private sector
technical initiatives are being
used to clean  the sites.
Second, where appropriate,
private sector  generators are
"stepping up to the table,"
assuming  their responsibilities
and bringing about timely resolu-
tion  of the problems. While  the
State governments also  must
make a significant contribution,
the generators  and disposers of
waste  still have the primary
responsibility for cleaning  up. We
need all the talents we can
muster, and  Superfund ensures
consistent, reliable performance
pointed toward a goal of ex-
pedited, environmentally-sound
cleanup in a cost-effective
Q  Has EPA been slow to
move on cleanups, past or

/\  When dealing with a sub-
ject that strikes  such an
emotional chord, the  perception
by some will always be that we
are not moving fast enough. The
truth is that we  are moving very
expeditiously to clean up the 1 1 5
sites on  the Agency's Interim
Priority  List and  we are  already
adding sites to that  list.  So far
S63 million has  been provided
for cleanups at 57  sites. Nearly
S25 million has  been allocated
for removal actions at 76 sites.
Removal actions  have been com-
pleted at 25 sites. Action of one
type or  another  is underway on
virtually every site on that interim
list. Cooperative  agreements
have been signed with 2 1 States
More than 1,300 notices have
gone to generators or disposers
of hazardous waste at 82 sites.
So far they have  responded with
more than $80 million in private
money for cleanups at more than
20 sites. When you consider EPA
has had  responsibility for the
Superfund program only since
last August, the  record is quite

                                                                                      "My first responsibility is to
                                                                                      protect human  health  and  the
                                                                                      environment. .
 Li  Why has the number of
cases brought against violators
of the different hazardous
waste law and  regulations
dropped in 1981?

 r\  Effective enforcement can-
not be measured by the number
of civil suits brought against
violators The previous Ad-
ministration depended upon civil
suits as its only enforcement
tool  We are relying on a number
of other, more effective, less
burdensome and less  expensive
devices. We have set  a results-
oriented course designed to
solve the problem, not discuss  it
in perpetuity in court  after
waiting two or three years to get
on a calendar. For instance, we
have issued twice as many con-
sent decrees this year as last
year. We have also  issued more
than 250 Administrative Orders
that accomplish better results
than civil  suits. As I just noted,
we have already collected $80
 million for Superfund cleanup ef-
forts through consent decrees
 and court orders. Litigation in the
same cases would still be under-
way with no income realized  Our
 enforcement policy  now has a
consistency which adds the vir-
 tue of predictability, an extremely
 important factor to the regulated
 community. That factor alone
 will  curb violations far more ef-
 fectively than headline-grabbing,
 time-and  talent-consuming law-
 suits. It is  high time we stop
 equating enforcement with the
 number of lawsuits underway,
and measure it instead by the
 results we are achieving. In this
area, we are  compiling a  record
which is a source of considerable
U.  What progress has been
made in developing a
regulatory program in  hazar-
dous waste?

f\  When this Administration
took office, a number of regula-
tions were about to go  into ef-
fect. Many were neither
reasonable nor workable. Conse-
quently, we held them up until
we could  take our own  look  at
the situation. We have now
published  all the major  compo-
nents of a realistic and workable
regulatory program. These stan-
dards now cover every aspect of
the hazardous  waste cycle,  from
generation to transportation,
storage  and disposal.  Only
recently we issued  regulations
covering land disposal and
incineration. These  regulations
complete  a realistic, achievable
program which will protect
human health  and the environ-
ment without  unnecessarily
hamstringing industry. Comple-
tion of the package has also
cleared  the way for the States to
begin permitting hazardous
waste management facilities  of
all  types.  Meantime, we are
proceeding with a regulatory im-
pact analysis and a series of
public hearings and task forces
which will fine-tune these
regulations as they begin to
make their effects felt.

Q  How do you plan to deal
with citizens' complaints about
dumps and hazardous waste

A  The National Contingency
Plan, the official blueprint for
Superfund, calls for clear ac-
countable channels of  com-
munication with the citizens to
clear up  apprehensions created
by misconceptions and mis-
representations.  EPA is a highly
visible Agency.  Our actions are
constantly and  carefully
scrutinized  and  questioned by
the media.  Our technology is
subject to intensive questioning
by both the media and the public
itself. This process is a  good and
healthy one. I  have no  doubt
whatsoever that it contributes
significantly to  better protection
for the environment, which is
what we all seek.  Practically
speaking, most citizen  concerns
will be handled  best by  local,
State or  Regional  officials. They
will ordinarily be familiar with the
specifics  of the cases in question.
One of EPA's primary concerns is
to maintain  a close working
relationship and dialogue with
the States and  through them in-
dustry and local governments, so
that all elements of the industry-
governmental partnership will be
well-informed on programs,
goals and environmental
progress. In that way, no matter
who responds to citizen com-
plaints, the answer will ac-
curately reflect  the rationale and
progress  of the  partnership's
Q.  To get away from hazar-
dous waste for a moment,
what is EPA doing in the area
of solid or non-hazardous

A  EPA leadership is responsi-
ble for bringing solid waste plan-
ning and management to its pre-
sent level  of sophistication Our
interest in providing for sound
non-hazardous waste  disposal is
just as strong  as our  interest in
hazardous waste. With our
guidance,  52 States  and
territories  have developed solid
waste  plans. By the end of this
fiscal year, EPA will  have ap-
proved more than half of them.
We no longer  have  to mandate
programs.  Our role now  is to
support the States' efforts. EPA's
open dump inventory and our re-
cent study on  the dioxin issue
and resource recovery are exam-
ples  of this  supportive role. The
open  dump  inventory  has been
extremely  helpful to State plann-
ing processes  by earmarking
those facilities which are  in need
of greatest improvement.  Ap-
proximately  2.000 dumps have
been inventoried  and  although
the program is no longer funded.
more than 30 States continue to
evaluate facilities with carryover
monies. The TCDD, or dioxin,
study responded  to  growing
public concern over emission of
the pollutant from refuse-to-
energy facilities. The study con-
firmed that levels of  TCDD
currently being released do not
constitute  a  hazard to human
health  or the environment. As
added insurance, we are continu-
ing to  monitor facilities.
CJ.  Can recycling play a ma-
jor role in dealing with future
solid waste disposal?

A  Recycling has always been
an important part of solid waste
management.  Most of the in-
novations in the recycling field
have come from municipalities
and industry, spurred by some
very interesting entrepreneural
endeavors. A great number of
cities and towns have been able
to reduce their solid waste dis-
posal costs through  recycling
programs. They have eloquently
demonstrated  the  feasibiiity of
recycling.  The Reynolds
Aluminum Company's program
paid S90  million last year alone
to can collectors. The most com-
mon form of recycling involves
newspaper and glass. Collection
centers  are springing up
throughout the country  for
recycling these and similar
household wastes. Industrial
waste also is recycled. The Dow
Chemical Company, for instance.
employs a thermal process to
recover  chlorine from wastes
The hazardous waste exchanges
are an excellent example  of the
old adage: "One man's trash is
another man's treasure " As the
price of materials rises, it is only
natural  that recycling will
Q  If you could choose one
achievement for your ad-
ministration, what would it be?

A  It would be to leave  my
post knowing there is in place
and operating, a complete  and
effective  system ensuring that
the nation would never again
suffer the environmental  horrors
caused by past practices of im-
proper waste disposal. With
Superfund, our past offenses and
present problems will be
eliminated. With RCRA we can
avoid creating new offenses
while encouraging and
motivating development of affor-
dable technologies for proper
disposal of our waste. Proper ap-
plication  and strict enforcement
of those  laws will  enable us  to
achieve our  goal of protecting
human health and the  environ-
ment n

A   Superfund
Progress   Report
 In December 1980. Congress passed the
 Comprehensive Environmental Response.
 Compensation, and Liability Act. In the year
 and  a  half since then, many start-up
 problems  have been overcome, and
 Superfund—as the law came to be known
 almost immediately—is getting into high
   Before  Superfund arrived on the scene.
 the Federal government had no authority to
 clean up old, abandoned  hazardous waste
 sites. The Resource Conservation  and
 Recovery  Act (RCRA) authorized  Federal
 regulation of operating sites, and  the Clean
 Water Act authorized  federal action against
 oil and hazardous discharges into  navigable
 waters. But there was no authority for
 Federal response to abandoned and uncon-
 trolled hazardous waste sites and spills in air
 or on land.
   Superfund filled that gap. The  law
 provides for a $1.6 billion fund to cover
 cleanup costs. Most of this—86 percent—
 comes from taxes on the manufacture or im-
 port of certain chemicals, petroleum, and
 petroleum products. The rest comes from
 general revenues.
   The government generally can  take legal
 action to  recover cleanup costs from those
 responsible for the waste. Responsible par-
 ties who do not take ordered cleanup action
 are.  under certain conditions, liable for
 punitive damages equal to three times the
 governments' response costs.

 Superfund Works

 In his Executive Order of August   14,  1981,
 President  Reagan delegated to the Environ-
 mental Protection Agency the responsibility
 to revise  the National Contingency Plan "to
 contain the implementing procedures for the
 coordination of response  actions to releases
 of hazardous substances  into the  environ-
 ment." EPA proposed a revised Plan  last
 March, and issued the final Plan  in July.
   The Plan establishes methods  for deter-
 mining where, when,  and how Superfund
 monies will be spent. It describes  two
 categories of cleanup: removal in response to
 acute emergencies or to  abate a  serious
 threat, and remedial action to provide a long
 term cleanup or solution  to the problem. It
 sets up a  process for determining the extent
of remedial cleanup. Sites are evaluated or
"scoped" to see what remedial action is
needed. Then cleanup  alternatives based on
environmental, economic, and engineering
criteria are  developed. The final remedy
selected will be the most cost-effective that
protects public  health, welfare, and the en-
   In conjunction with the Plan. EPA is com-
piling a national ranking of state-nominated
hazardous waste sites. Last fall the agency
selected 11 5 sites to be the first to receive
attention under Superfund. This fall EPA will
complete naming the nation's 400 priority
   EPA experience has shown that cleanup
conditions and needs vary greatly from site to
site, depending on the chemicals involved.
area geology, soil conditions, climate and
population.  That is why the National Con-
tingency Plan allows for flexibility in dealing
with waste sites. It also requires extensive
State and local involvement in Superfund ac-
tivities, with States involved from the beginn-
ing of the process to the end, from ranking
problem sites to cleaning them up.

A Progress
Superfund has  a Congressionally-mandated
life span of five years,  and  it's already one
and one-half years old. What has it accom-
 Superfund Accomplishments:
 Some Vital Statistics
 • $26 million allocated for 81 removal

 • 40  removal actions completed.

 • $75 million allocated for remedial actions
 (including investigation, feasibility studies.
 design, and construction) at 63 sites.

 • 26 cooperative agreements signed by EPA
 and the States:  6 state contracts awarded.

 • 1.450 notice  letters sent to responsible
 parties associated with  86  of the 1 15 top-
 priority hazardous waste sites.

 • Administrative Orders issued to abate
 dangers to public health or welfare (more un-
 der development in the regional  offices).
  As of June, the Federal government had
collected $300 million in  taxes under
Superfund. and. as of July  2. allocated nearly
$147 million for both remedial and removal
actions (see box). Forty removal actions have
been completed.
  According to William Hedeman, Director
of EPA's Office of Emergency and Remedial
Response, remedial  investigations or
feasibility studies are either underway or
soon to begin at 55  of the first 115 priority
sites. Designs  for cleanup are underway or
about to start at 20  of the sites: and actual
cleanup work,  at 19 others.
  Some investigative or remedial work is ex-
pected soon at another 20 or so sites.
  Hedeman explains that  action has not yet
begun at some sites  for a  variety of reasons.
Many are still  involved in  enforcement ac-
tions to bring about  voluntary cleanup by
responsible private parties. Some States
have decided to clean up certain sites under
State enforcement laws rather  than Super-
fund. Other States haven't come up with the
10 percent  matching funds for EPA cleanup.
Still others  have not  yet budgeted funds for
  EPA is encouraging voluntary cleanup by
private parties whenever possible. The
agency has identified responsible parlies at
about 70 percent of the priority sites, and has
sent more than 1.400 notice letters, the first
step in negotiating privately financed
  Overall. Superfund has moved quickly, and
only 16 of the first 115 priority sites are left
for  EPA to  consider  and process. Since the
full  national priority  list of 400 sites is not
due until fall. EPA has asked  its regional of-
fices and the States to nominate additional
sites for action between now and fall. Super-
fund work can begin at those sites im-
  Eighteen months  after  its establishment.
Superfund is entering a new  stage of
development. While its record of past accom-
plishments is significant, its record of future
accomplishments will be even more so. Rita
Lavelle. EPA Assistant Administrator for
Solid Waste and Emergency Response.
says the law  will be judged not by how
much money is spent, but by how many
hazardous waste  sites get cleaned up. D
                                                                                                             EPA JOURNAL

                                                                                 A  Superfund
                                                                                 December   Congress passes the Com-
                                                                                 1980        prehensive  Environmental
                                                                                             Response, Compensation, and
                                                                                             Liability Act of  1980 (CERCLA).
                                                                                             also known  as  Superfund.

                                                                                 August      President Reagan issues Ex-
                                                                                 1981        ecutive Order 12316. delegating
                                                                                             to the  Environmental Protection
                                                                                             Agency the  responsibility for
                                                                                             amending the National Con-
                                                                                             tingency Plan and for allocating
                                                                                             money from  the Hazardous Sub-
                                                                                             stance Response Trust fund to
                                                                                             carry out the purposes of the Act.

                                                                                 August      EPA awards first cooperative
                                                                                 1981        agreement under Superfund for
                                                                                             S2  million in remedial investiga-
                                                                                             tions and cleanup at Sylvester
                                                                                             site in Nashua,  New Hampshire.

                                                                                 October     EPA announces 115 top-priority
                                                                                 1981        hazardous waste sites targeted
                                                                                             for  action under Superfund.

                                                                                 February    EPA establishes a special task
                                                                                 1 982        force to accelerate cleanup  by
                                                                                             private parties at hazardous
                                                                                             waste sites  under Superfund.
                                                                                             EPA also announces an agree-
                                                                                             ment in which the  U.S. Army
                                                                                             Corps of Engineers will manage
                                                                                             construction  and design con-
                                                                                             tracts and  provide technical
                                                                                             assistance to EPA in Superfund

                                                                                 March      EPA proposes a  revised National
                                                                                 1982        Contingency  Plan setting criteria
                                                                                             for  determining  where, when,
                                                                                             and how Superfund monies will
                                                                                             be spent. Also, issues policies for
                                                                                             state participation and lead
                                                                                             through cooperative agreements.

                                                                                 April        EPA awards  first State contract
                                                                                 1982        under Superfund: $718,000 foi
                                                                                             remedial and site investigations
                                                                                             at the Commencement  Bay site
                                                                                             in the State  of Washington.

                                                                                 July         Final National Contingency Plan
                                                                                 1982        published.

                                                                                 Fall         Due date for  proposal of national
                                                                                 1982        priority list of 400 hazardous
                                                                                             waste site  "response targets."

                                                                                 September  Sunset date for end of Superfund
                                                                                 1985        tax

On   a   Two-Way   Street:
The  Superfund  Community  Relations  Program
 EPA's Superfund community relations
 program information  travels a two-way
 street It flows from EPA to the public, telling
 citizens about hazardous waste site cleanups
 planned for their communities; and from the
 public to EPA.  keeping the agency abreast of
 community concerns  Only with  this  kind of
 dialogue can EPA and the public understand
 each other's concerns and make informed
 decisions  about how cleanups should
   The Superfund law gave the  Federal
 government authority to respond to  aban-
 doned and uncontrolled hazardous waste
 sites and  spills on air.  land, or water EPA
 realizes that every such site and spill  has the
 potential for intense  public concern  over
 government actions.  However, an effective
 community relations  program can help ease
 citizen concerns by providing the facts.
   Before setting  up  its Superfund com-
 munity relations program,  EPA tried to  find
 out  what to expect by conducting a study of
 government-community interaction at 21
 hazardous waste  sites  across the country.
 The study showed that the credibility of the
 government agencies involved was more im-
 portant in determining  public concern about
 a site than the level of environmental threat.
 or the education, socio-economic status, or
 prior political  or environmental activism of
 the  citizens. Given the importance of
 credibility, the message to  EPA was obvious:
 tell  the whole  truth, tell it up front, and keep
 on telling it. This has become the corner-
 stone of the agency's community relations
   According to William Hedeman, Director
 of EPA's Office of Emergency and Remedial
 Response, the community relations program
 has six objectives:
 • To establish at each site some means of
 learning the community's  concerns.
 • To inform citizens about budget con-
 straints that limit Superfund  actions so they
 don't develop unrealistic  expectations,
 • To deal constructively  with public
 response to Superfund actions.
 • To decrease the likedhood of costly delays.
 cost overruns, and politicization of purely
 technical issues
• To establish a preventive program to
lessen or avoid public confusion about Super-
fund remedies.
• To stress the interaction of Federal, State.
and local governments in solving a  local
  There is no set formula for achieving these
objectives. The community relations program
is flexible to adapt to the variables  at each
Superfund site. The only requirement of the
program is  for preparation of a community
relations plan for remedial actions and for
planned removals lasting longer  than two
weeks. The purpose of the plan is to integrate
community  relations activities into technical
responses. Each plan  is based on the in-
dividual characteristics and level of  citizen
concern at a  particular site.
  A community relations plan starts with
discussions with local officials, community
leaders,  and citizens to  identify local con-
cerns. It  describes the background of the site,
the  objectives of the community relations
program at the site, techniques that will be
used to  achieve the objectives, a  workplan,
and a budget
  Such  a  plan is required for each planned
removal  expected to last over two weeks; the
level of  detail in the plan depends on the
scope of the action. When the removal is
finished, a "responsiveness summary" is re-
quired to document how EPA handled citizen
concerns. The summary lists the community
                                   The specific techniques in each plan are determined by

      relations activities that took place and the
      issues that came up, and evaluates the com-
      munity relations program at the site.
         For remedial actions, two plans are re-
      quired. The first comes once the need for
      remedial action has been determined; the
      second,  when investigation and  feasibility
      studies have  been completed and remedial
      design is beginning. A responsiveness sum-
      mary is  also  helpful in remedial  actions to
      evaluate  EPA-community interaction.
  The specific  techniques in each plan  are
determined by the site manager with exten-
sive community input.  Though the tech-
niques will vary from site to site, and from
stage to stage at each  site, one general rule
applies to most situations: informal is better.
  Therefore,  most pfans will tend to favor
such techniques as small  "living room"
citizen meetings, information interviews.
telephone contacts, courtesy visits to  local
officials, site  tours,  press releases, fact
sheets, exhibits, and mailings, rather than the
larger, more formal public hearing. The
reason is not to avoid public contact, but to
maximize  it.
   At remedial actions and especially at plan-
ned removals, the remedy may be limited. A
community relations plan should make  this
clear to the public. Since a community's  per-
ception of the public health threat posed by a
hazardous waste site can determine the level
of citizen  concern, a community relations
program should identify those  concerns,  and
then give  the citizens enough  knowledge to
base their perceptions on fact
   Superfund cleanups are just  getting under-
way across the country, so EPA  regional of-
fices have not yet accumulated  much ex-
perience in implementing community  rela-
tions plans.  Still, enough is  known so that
Marcia  Carlson, community  relations coor-
dinator  in EPA's midwest region, compares
the process  of developing a plan to "going
over an  area with a mine sweeper." Her com-
parison  points up the importance of identify-
ing potential  problems before  they erupt
   EPA's Superfund community  relations
program recognizes that abandoned hazar-
dous waste  sites  and hazardous materials
spiils are not just environmental problems.
but are  political, economic,  and  social
problems  as  well. The program's effort  to
deal with  these problems using  informal
channels of  communication  has  been
criticized as an attempt to bypass community
input. EPA feels that, to the contrary, it is an
attempt to enhance community  input  by
favoring dialogue  over confrontation.
   Superfund chief Hedeman makes a big
distinction between public relations and
community relations. The former is informa-
tion on a one-way track to citizens. The latter
is on a  two-way track, to and from citizens.
This, says Hedeman, helps insure respon-
siveness. "The Superfund community  rela-
tions program is not image-building.  It's an
honest effort  to conduct our business openly
and efficiently. EPA must be credible  to be
effective, and credibility can come only from
sincere  efforts to  address community con-
cerns." Q
the site manager with extensive community input.
      JULY/AUGUST 1982

New  Hampshire
By  U.S. Rep. Judd  Gregg
In an era when public perceptions of issues
are formed by simplified mass media presen-
tations, our view of our government frequen-
tly tends to be badly distorted; and probably
no agency has  fallen victim to the media
more than the  EPA.
  To hear some tell it, all that is clean and
beautiful around us is about to be ravaged by
lustful and greedy industrialists. EPA is pic-
tured as either  unwilling or unable to inter-
vene. Such allegations are  very disturbing to
those of us from states such as New
Hampshire which take great pleasure and
pride in our environment  and, at  the same
time realize just how sensitive and vulnerable
it is
  For that reason  it was tremendously
reassuring to find out first hand that the EPA
still lives. Not only does the Agency still have
the  will and resources to do the job, but the
recent  moves to streamline its functioning
seem to be working. In, my experience in
Washington ! have  not run into  any  other
agency that can match the responsiveness
which I  received from EPA.
  In December 1980, Congress passed the
Superfund law  authorizing the Federal
Government  to clean up old, abandoned
hazardous waste sites.
  That was only 1 8 months ago. But despite
the fairly brief stretch of time from  passage of
the  law to the  present, many critics  have
charged that the Environmental  Protection
Agency has not moved fast enough to imple-
ment the law. Even though some action is
already under way at 99 of the first 1  1 5 "in-
terim" priority sites the agency selected last
fall, the critics complain of foot-dragging.
  I can't speak for other States, but I can
speak for New  Hampshire, And  in New
Hampshire, what we have seen on the part of
EPA ts not foot-dragging  but  a prompt
response to local needs. EPA has provided
Superfund assistance for response actions at
three of the most hazardous sites in New
Hampshire. At sites in Epping and Kingston,
EPA has committed more  than $33  million
for ongoing cleanup actions.  At the Sylvester
dumpsite on Gilson Road in Nashua, EPA
officials have also acted quickly to help the
State diminish the immediate threat to public
health, and to come up with  a longer-range
                                                                                                          Judd  Gregg
                                                                                   The Gilson Road site is an abandoned
                                                                                 gravel quarry that had been illegally used
                                                                                 during the 1 970's for dumping all kinds of li-
                                                                                 quid and solid hazardous waste. More than a
                                                                                 thousand drums of chemicals were scattered
                                                                                 over the surface of the site. Even worse,
                                                                                 though, liquid hazardous  wastes  had been
                                                                                 deliberately poured through  makeshift pipes
                                                                                 directly into the earth  under the  old quarry
                                                                                   This would be bad enough if the site were
                                                                                 isolated, but it isn't. It  is adjacent to a  large
                                                                                 trailer park housing several hundred families.
                                                                                 It is also 600 feet from  a creek that flows into
                                                                                 the Nashua River, from which several towns
                                                                                 downstream draw their drinking water. There
                                                                                 was the potential for chemical explosions.
                                                                                 and there was the  potential for pollution of
                                                                                 the drinking water. Gilson Road  was a  dis-
                                                                                 aster waiting to happen.

   In 1979 and 1980,  the State of New
Hampshire and the  U.S. EPA took
preliminary steps towards cleaning up Gilson
Road. Then in  April  1981, four months after
passage of Superfund,  EPA and the State
released a report on the investigation of the
site. It found the situation was worse than an-
ticipated. The  report identified a significant
plume of contamination in the groundwater
beneath the site. The contaminated ground-
water was flowing toward the creek not at
the usual rate of inches  per month, but at the
alarmingly rapid rate of  one and one-half feet
per month! Obviously,  something  had to be
done, and fast.
   On May 25, Governor Gallen sent a letter
to EPA, requesting Superfund assistance and
agreeing  to  meet State responsibilities  as
specified  in  the law. On June 8, a public
meeting was held in Nashua. Represen-
tatives of the New Hampshire Water Supply
and Pollution Control Commission and
regional and headquarters EPA offices atten-
ded. The next day, State and Federal officials
met again in all-day  discussions on the tech-
nical aspects of cleaning up Gilson Road. On
June 30  the State submitted a formal  ap-
plication  for Superfund funding. And on Au-
gust  24,  New  Hampshire was awarded over
$2.4 million in the first  cooperative agree-
ment with a State under Superfund. Under
the agreement, the  State would carry out a
study of various ground water treatment op-
tions and would be responsible for the design
and construction of  a slurry wall and cap to
contain the wastes on  the  Gilson Road  site.
In addition.  EPA agreed to install and
operate  an interim ground-water pumping
and recirculation system which  would keep
the contamination from reaching the stream
below ground, while the slurry wall and cap
were under  construction.
   Subsequent work showed that the below
ground contamination—originally thought to
affect some  12 acres—had spread significan-
tly, and  now covered some 20 acres. This
meant the slurry wall and cap would have to
be expanded.  In addition, geological data
collected at the site showed that treatment of
the ground water within the containment
system would  be necessary.
   On June 22, 1982, the State-EPA
cooperative agreement was amended to
provide  New  Hampshire with another $2
million for expansion of  the containment
system and to design a  system  to treat the
contaminated ground water.
   Now  if you noticed the dates I  have  just
cited, you  realize that from the time the in-
vestigation report came out in April 1981 to
the time the  cooperative agreement was
awarded in August  1981, four months  had
elapsed. Four months for the State and the
Federal  agencies involved to work with a
brand new piece of legislation, untested  and
untried.  Four  months to  work out  a  com-
plicated, first-of-its-kind project. Four months
for New Hampshire and EPA to get the job
done. And they did it.  Is that foot-dragging?
  New Hampshire was successful  in  taking
prompt action under Superfund because
State officials stayed in constant contact
with  EPA officials, working  out details,  dis-
cussing changes,  hammering out mutually
acceptable compromises.  Perhaps if EPA
critics spent their time  as productively as we
did. we would see even greater progress un-
der  Superfund, D
                                                                                                                           t I

First   Inning
of  Superfund
The forces that led to the Superfund law and
the revised National Contingency Plan were
first  unleashed in March 1967 when the
mammoth oil tanker Torrey Canyon broke in
two  off the  English coast
   At least 15 of EPA's current Superfund
employees took  part in the original work
dc!si(|iiod to develop plans for dealing with
such a disaster if it ever occurred in waters
off the United States
   Thirty Ihree million  gallons of  crude oil
(|ur(jl<>d out  from the  Torrey Canyon's hold
and slithered across the sea  -enough to foul
parts of the coastlines of two nations
Military units in  England and France
mobilized troops in the attempt to deal with
this unprecedented emergency. The major oil
spill  damaged beaches,  wildlife, fishing and
tourist economies, and the marine foodchain.
   Across the Atlantic, the  U.S. Government
was deeply concerned about the implications
of this massive spill. In an era of steadily in-
creasing energy  use. the high seas were
criss-crossed with ever-larger supertankers
carrying oil  from the Middle East to the in-
dustrial nations. These leviathans,  seldom fly-
ing under flags with the safest maritime
codes, were often commanded and crewed
by sailors from diverse nations with no com-
mon language for giving and receiving orders.
To our government it appeared not unlike!/
that this first major marine disaster involving
so much oil might be the  harbinger of a
similar event on the U.S. shoreline or even on
the already  ecologically overburdened  Great
   The U S  therefore  sent over a six-man
team to see what could be learned. The ob-
servers represented Federal Agencies,  and a
State government as well. The team flew to
Europe in April  1967, about a month after
the disaster.
   Kenneth  Biglane, then with the Depart-
ment of the Interior and now Director of
EPA's Hazardous Response Support Division,
was a member  of the team
  The first stop  was Cornwall  on the
Southern English coast, still oil-drenched,
where  British troops were attempting to
break up the oil  molecules with 3 million
gallons of dispersents. This put the aquatic
life  cycle hopelessly out of kilter. Fish and
seaweed washed up on the beaches. Thou-
sands of birds died, although there were  bird
hospitals where workers attempted to clean
and revive rarer species, such as the guillimot
and puffins. Seashore tourists, who were ap-
palled by the oil  and  nauseating fumes,  not
only got  in the way of emergency cleanup
operations, but tracked up local lodgings with
oily footprints.
   But to the US.  team of observers, the
worst aspect and perhaps most notable
feature of the disaster was the  mismanaged
nature of the attempts to cope with it.  In-
structions for the workers conflicted. There
were no clear lines of authority,  as well as no
technology available at the disaster scene to
deal with  the incredibly  complex technical
problems facing  the troops.
   Across the English  Channel  a few weeks
later, the U.S. team found the  French Army
using straw  to sop up the oil on the sea.
Detergents had been ruled out. to avoid dis-
rupting water and seaweed maritime ecology
and the French fishing industry. The oil-
soaked straw was loaded  into  lorries and
trucks, then  into  railroad tank cars, and ship-
ped to Brest, where the plan was to recover
the oil by letting  it out through  stopcocks at
the bottoms of the tanks. Unfortunately, sand
and debris prevented the oil from flowing. In
short, the U.S. observers found that,  in
France as in England, efficient deployment of
resources was severely hampered by lack of
planning and an overall strategy.
   The six observers, convinced that lack of
planning and spill-technology should not be
allowed to happen in  the  United States,
reported their findings to their respective
cabinet officers. The need for a  national plan
and better technology also was reported to
the White House.
   At the  request of the President, the team
then completed  a report on  the status  of
United States spill technology, design of
vessels, available equipment and skilled man-
  The  report resulted in a presidential re-
quest to the Secretaries of Interior, Trans-
portation, Defense, Health, Education and
Welfare, and the offices of Science & Tech-
nology  and Emergency Planning to  assume
responsibility for developing a national con-
tingency plan.
  The  plan was developed and  signed into
law November 13,1 968. The same agencies
were designated to provide overall policy


The wreck of the  Torrey Canyon  which was responsible tor gigantic oil spill in the Atlantic off the Coasts of Fug/and and fi;nn:c
direction in carrying out the plan's provisions.
The Interior Department, as lead agency, es-
tablished a division  in the Federal Water
Pollution Control Administration  in January
1970 to handle the responsibility.
   Many of the original team comprising this
division, which preceded  first the EPA spill
control program and then  Superfund, are stili
working together on the  Superfund  team.
They include:
   Headquarters: Kenneth E. Biglane, Russell
H. Wyer, Richard Hess,  H.  D. Van Cleave,
Jean Wright, and Ruth Rexroth,
   Regions: John Conlon. Region  1;  Paul
Elliott,  Region 2; John A.  Little, George
Moein, Al Smith, all  of Region 4; Russell
Diefenbach,  Region 5; Charles Gazda,
Region 6; Richard Jones, Region  8;  James
Willmann, Region  10 D

States   Active
When given the chance,  most States are
showing that they welcome the opportunity
to run programs to control hazardous wastes.
  States are allowed by law to operate their
own hazardous waste program in place of the
Federal program, as long as the two are
"substantially equivalent." As of June 1982,
nearly two-thirds of the states had proved
their programs were substantially equivalent
and were running portions of their own

A Short  History
of A Long Process
In 1976. the Resource Conservation and
Recovery Act (RCRA)  authorized EPA to es-
tablish a  hazardous waste control program
for the country.
  Writing the regulations to implement that
part of the law  was a complicated and time-
consuming process. So complicated,  in fact,
that EPA decided to do it in stages. And so
time-consuming that it took four years just to
complete the regulations for the first stage.
   In 1980, these regulations took effect.
Regulations for Phase  1 cover identification
and listing of hazardous wastes, and require-
ment for generators, transporters,  and ow-
ners and operators of treatment, storage, and
disposal facilities.
   Regulations  for Phase 2 cover granting of
permits for such  facilities.
  Additional regulations covering permits for
containers, tanks,  waste piles, surface im-
poundments, and incinerators took effect in
1 981. Rules for permits for disposal facilities
have not yet taken effect.
  One part of RCRA-Section 3006
authorized "substantially  equivalent state
hazardous waste programs to operate in
place of the Federal program on a temporary.
interim basis.  After a  complete Federal
program has been promulgated. State
programs can receive final authorization if
they are "equivalent" to the Federal program
and "consistent" with other State programs.
   States wishing to operate their own
programs submit qualifying documents to
EPA  to demonstrate "substantial
equivalency." This material includes a
description of the state program and cer-
tification by the State Attorney General that
State law and regulations provide adequate
authority to carry out the program. Also
needed are a  Memorandum of Agreement
between EPA and the State; an Authoriza-
tion Plan specifying what  steps will be taken
to qualify for final authorization, and when;
and a letter from the Governor  requesting
   EPA advises the states  in developing these
submissions; then reviews the documents to
determine  if the State is  qualified for
authorization.  After a public hearing,
authorization notices are  published in the
Federal Register.

We Stand
Because the regulations came out in stages.
States that wanted to run their own hazar-
dous waste programs had two options. They
could wait until all  the Federal  regulations
were complete to apply directly for final
authorization.  Or they could go  for step-by-
step  interim authorization, establishing their
programs piecemeal as each set of Federal
regulations was issued. Most of them chose
to do the latter.
   Arkansas was the first State  to receive
Phase 1 authorization. Its authorized
program began .November 19,  1980, the
same day the Phase 1 regulations took effect,
Since then-another  31 States have received
similar authorization. Four States—Arkansas,
Georgia, North Carolina,  and Texas—have
also  received permitting authorization under
Phase 2.
   By September 1983. it is expected that
45 States will have received authorization for
Phase 1.  and 30 States  for Phase 2.
   In those States that have not  yet received
authorization, EPA runs the program with the
State's cooperation and assistance.
   Ironically, it  has  been  easier  for those
States without a hazardous waste control
program to set one up from scratch than it
has been for States with an established
program to make the necessary changes.

States with no existing program could adopt
the EPA reguiations almost intact. But States
like New York, New Jersey, and Ohio which
had well-established programs needed com-
plicated operational and legislative changes
to become "substantially equivalent" to the
Federal  program
  Some States, like West Virginia, were not
able to pass legislation before the application
deadline for interim authorization. That
meant  they would have had to skip the in-
terim phase entirely, wait for the Federal
program to be completed, and then apply for
final authorization. To avoid these delays.
EPA is working on extending the deadline.
When North Carolina received authorization
to administer Phase  2, EPA Administrator
Anne Gorsuch called the occasion a
demonstration of "the  Reagan Administra-
tion's desire to turn  over programs  to the
level of government  closest to the problem
and best suited to deal with it."
   Under Gorsuch, EPA views the States as
equal partners, who share the Agency's com-
mitment to environmental quality. The
agency  is seeking  to reinforce the primary
functions of State  and  local governments in
promoting and maintaining environmental
   EPA  believes that the states should be
principally responsible for the day-to-day
management of environmental programs
Evidence of the States' growing commitment
to environmental quality is the fact there are
ten times as many state environmental staf-
fers on the job today  as there were in 1 970
   In keeping with the  concept  of new
federalism, EPA encourages the States to run
their own hazardous waste control programs.
and will do whatever it can to help them
qualify.  The  Agency advises States  in
developing application materials and is seek-
ing to make deadlines  more realistic.
   A critical  factor, of course, is  money
Federal  grants to States now amount to less
than half of  total  State expenditures for en-
vironmental  programs.  In fiscal year 1982,
for example, EPA will provide about $237
million to states  Estimated  State funds for
the same period exceed $300 million
   Nevertheless,  if substantial budget cuts
are made. States  may not be able to afford
their own programs.  So EPA already has a
study of alternative funding underway. User
fees  and other innovative funding
mechanisms are  being examined for recom-
mendation to financially hard-pressed States.
   Running a hazardous waste control
program is more difficult for some States
than others. Still, as most are demonstrating,
they can do it themselves D

A   Burning


to   a   Difficult


Although an innovative research community
continues to  develop increasingly exotic
hazardous  waste disposal techniques, the
favorite disposal alternative for the near
future appears to be  mankind's oldest
alternative   burning.
   The rapidly growing popularity of incinera-
tion is readily seen in more than 300 in-
dustrial systems currently operating
throughout the nation. They handle about
seven million  tons of hazardous waste per
year, approximately  17 percent of the total
generated.  Many more are coming on line or
are  in the  permitting process.
   The sky  is the limit for this process which
has the capability of destroying 9.999 parts
of waste out  of every 10.000 treated.
   EPA's policy is one of  encouraging use of
more incinerators. Administrator Anne  M
Gorsuch calls  incineration "clearly one of the
 most effective ways of disposing of  hazar-
dous waste "
   The Agoncy recently took a major step  in
 encouraging  incineration when it published
 modified permitting  regulations providing
 maximum operational flexibility and economy
 while preserving requirements capable of
 protecting  the public health and environment
    Release of the  amended regulations not
 only will accelerate the permitting process, it
 also sets the stage for authorization of States
 to do their own permitting Four  Arkansas,
 North Carolina, Georgia  and Texas—now
 hiivr; such  authority, but EPA officials predict
 virtually all States will have it by  1983

 Adaptability: A Major Asset
 One of the strengths of  incineration  is its
 adaptability The system  can be designed to
 dispose of any  type of organic waste:  rub
 bish. solids, burnable liquids, difficult-to-burn
 liquids and sludges.  Incineration can also be
 designed to recover energy or raw materials
 during the burning process
    Incineration is actually a simple chemical
 oxidation reaction occuring at extremely high
 temperatures. Organic material, composed
 largely of carbon and hydrogen, reacts under
 those.' temperatures  with oxygen to produce
 c.nbon dioxide  and  water vapor.  The com-
 plexity of  the substances to be incinerated
 determines the degree of sophistication and
 expense required  in the  system.
    Rotary kilns are one of the  most versatile
 types of incinerators. They can  destroy solids.
 liquids, sludges, or even  entire containers  of
 toxic materials The name is derived from the
 rotation of the primary combustion chamber
 on  a central axis, permitting more efficient
 burning of solids.
  The most effective form of incineration will
be found in systems directly associated with
production processes  Such disposal
eliminates hazards associated with trans-
portation and storage  of waste materials. It
also permits final control by the  generator
and often allows incorporation of energy and
raw material recovery techniques  in the
  The recovery of energy, for instance, is a
popular process associated with combustion
The heat released when waste is burned can
be captured in  heat exchangers (boilers)
operating like huge radiators. These devices
capture the heat to convert water to  steam
and make a significant contribution to  energy
   Dow Chemical U.S.A., for instance.
operates more  than 25  heat recovery in-
cinerators throughout  the  nation. Their an-
nual heat recovery is estimated at about 2.8
trillion BTUs. the equivalent of 9.2 million
gallons of gasoline.

Hierarchy of Waste Incinerability
Under EPA's modified permitting regulations,
industrial incinerators must meet three major
performance standards:
   1.  Destruction and removal efficiency of
99 99 percent.  For every 10,000 pounds of
waste going into the incinerator, only one
pound can  come out
   2.  Hydrogen Chloride removal of 99 per-
cent,  before it is released  into the at-
mosphere, whenever the release exceeds
four pounds per hour
   3  Carefu! control of  paniculate emis-
sions. Particulates must not exceed  180
milligrams per dry standard cubic meter of
siack  gas.
   It was charged in some industry com-
ments that meeting such standards would be
prohibitively expensive, even impossible. Rita
M  Lavelle. Assistant EPA administrator  for
Solid  Waste and  Emergency Response, said
however that "a  careful review of  the
evidence affirms the Agency's belief that in-
dustry can meet  those standards."
   Cost is a critical factor, since a trial burn—
the central element in the permitting
process -may cost the  operator  from
550,000- 100,000.
   To minimize and alleviate the impact of
such  expenses,  Lavelle  said, the  Agency's
 The Westinghouse Marc 3 ^ Arc Heater Is an
 ultra-high temperature heat exchanger.
modified  regulations established a system
whereby  industry  need not  perform a trial
burn on all substances it intends to process.
It may perform the test only on components
that are hardest to burn, under the assump-
tion that  all  those which are easier to burn
also can  be  destroyed satisfactorily in the
process, she said.
   EPA's  permitting guidance  manual in-
cludes a  "hierarchy of waste mcinerability"
which  ranks approximately  300 chemical
constituents found in hazardous wastes  in
the order of  their degree of  combustibility. If
the trial burn demonstrates  compliance with
the performance standards  for  a given con-
stituent, then compliance is assumed under
the same operating conditions for any con-
stituents  ranking below  it on the hierarchy.

The Permitting Process
The amended regulations, which place both
new and  existing  incinerators under the
stringent  controls described above, greatly
simplify previous  permitting procedures.
   Here is how the permitting  process will
   1.  From a range of wastes  an  applicant
proposes to  burn,  the permitting official
selects a limited number of components—
usually 1-6   which are  most difficult to
destroy These substances are  called  "Prin-
cipal Organic Hazardous Constituents
   2  A trial burn  is conducted to prove that
the performance standards  are met. and to
establish the operating conditions required to
meet  them.
   3  If the  performance is successfully
demonstrated, the operating conditions
selected for the test burn become the  permit
   4  The permit allows burning of any waste
with constituents  which are less difficult to
burn than the selected principal hazardous
constituents, based on the hierarchy of waste
   The permitting process for new in-
cinerators provides regulation for four basic
operational phases: a "shakedown" phase to
ensure that  the incinerator  is functioning
properly: a trial burn to prove  compliance
with the  performance standards; temporary
limited operation  while the  trial burn results
are being evaluated: and final  long-term
operation based on the  trial burn  results.

The Next Step—Authorizing  States
The amended  regulations set the  stage for
State implementation of Resource Conserva-
tion and Recovery Act (RCRA) provisions ap-
plicable to  incinerators.  Ultimately most in-
cinerators will be  permitted by States under
the Federal  regulations  or their equivalent.
   Most States are expected to receive ap-
proval to issue incinerator permits by the end
of next year. Whether issued at the Federal or
State level,  permits will provide strict con-
trols to ensure  safe operation without harm
to human health  or the environment  and
without placing unreasonable burdens upon
the regulated community. Q

Garbage  is not  a tourist attraction. The
average sightseer in Copenhagen,  Denmark,
for example, doesn't  much care about the
city's carefully planned and operated system
of hazardous waste management. Nor is the
average tourist  in Paris the least bit in-
terested in that city's refuse power plant. Yet
these  two systems of hazardous and  solid
waste management, and others like them
throughout Europe, are worth some atten-
tion, for they are more advanced in many
ways than American  systems.
  Beautiful Copenhagen stays that way par-
tly because it has an organized method to
control its own  toxic  wastes. According to
John Lehman, Director of the Environmental
Protection Agency's Hazardous and In-
dustrial Waste Division, the Danish system of
hazardous waste management  is exemplary
in several ways. Unlike most U.S systems, it
integrates treatment,  disposal,  and  trans-
portation into a single system,  and  features
public-private cooperation.
  In Denmark, there is at least one collection
station in each municipality to collect  waste
oil and chemical waste from private
households. Twenty-three central collection
stations located throughout the country
receive waste from these local stations as
well as from industry and agriculture. The
waste then travels by road or rail to the treat-
ment plant, known as Kommunekemi.  There
the  hazardous waste  is incinerated,
chemically treated, or, if it cannot be treated,
disposed  of in abandoned salt  mines  700
meters underground. Every hazardous waste
producer  in Denmark must send its waste to
Kommunekemi unless it can  convince  the
local municipality that it can handle the
waste safely itself.
  With a capacity to  handle 80.000 tons of
hazardous waste a year, Kommunekemi is
the largest plant of its type in Europe. Similar
but smaller plants are  located in Ebenhausen
and Biebesheim. West Germany (70,000 and
60,000 tons respectively) and in St Vulbas,
France (30,000 tons).  All three plants accept
waste from beyond their immediate plant
area, even from other countries. And  there
are  other similar facilities elsewhere in
Europe. Lehman explains that these facilities
use  state of the art technology. "They  have
stood up to some heavy public pressure," he
says, "and were found to be pretty good."
Like Kommunekemi, the German plants are
owned and operated  by a government-
industry consortium. The French plant,
though privately owned,  is government
regulated and subsidized.
  Built last year, the Biebesheim plant is one
of the newest in Europe, and will eventually
 include wastewater treatment plants, a
 landfill, and physical/chemical treatment
 plants, all under the same management.
 Biebesheim will recover some of the energy it
 consumes. Heat from burning waste is
 already being converted to steam,  which in
 turn is being used to produce electricity and
 to power a system for reclaiming  crank case
 oil. Future  plans call for greenhouses to be
 built next to the plant, heated by turbine con-
 dense  from the plant and  used for growing
 winter vegetables.
   According  to Lehman, these European
 systems present an organized, logical ap-
 proach  to the management of hazardous
 waste. "Although the U.S is not behind them
 technologically," he says, "we don't have the
 centralization of facilities they have. And we
 don't yet see government  involvement in
 these projects." But the biggest  gap in the
 American  system, says Lehman, is the tie-in
 to transportation.  "Our transportation
 systems are usually independent  of the
 overall waste management picture," he ex-
   But things may be changing, Lehman con-
 cludes.  Kommunekemi is trying to market its
 system in this country:  a firm in  Baton
 Rouge, Louisiana  is trying to build a cen-
 tralized facility like  Kommunekemi; and
 states  and regional authorities "may be
 getting more interested."
A hazardous waste incinerator at the
Ebenhausen Facililty. Bavaria. West Germany
   In solid as well  as hazardous waste
management, we have a lot to learn from the
Europeans. From 1896, when the world's
first waste-to-energy plant was built in Ham-
burg. Germany, to  the  present, when there
are some 200 such plants throughout Europe
(but only eight in the U.S.). extracting
resources from refuse  has  become a  Euro-
pean specialty. In the Netherlands, in fact,  it
is more than a specialty; it is the law. New in-
cinerators cannot be built there unless they
contain equipment  for  heat recovery
   The largest of the 200 European plants  is
in Paris; it processes 2.600 tons of garbage a
day Smaller plants process less than 100
tons a day  According  to David Sussman of
EPA's State Programs  and Resources
Recovery Division, the plants are in all types
of  locations. "Often they're right in the mid-
dle of a city." Sussman explains. "After all.
that's where the garbage is. and that's where
the energy users are But sometimes  they're
in  the regional countryside, away from any
towns at  all. One small  plant in Switzerland.
for example, serves 47  communities  in two
   In a typical European city, says Sussman,
paper products are separated from other gar-
bage at  their source by homeowners. The
remainder of the  municipal trash goes to  a
central facility where it  is burned to produce
energy. Most of the plants in central Europe
generate  high pressure  steam for electrical
production. Plants in the Scandanavian coun-
tries tend to use the energy more for  district
   Sussman  estimates that a good energy
recovery  plant could meet about 10 percent
of  a city's energy  needs. Still, he emphasizes
that garbage disposal, not energy production.
is the prime purpose of the plants. The public
perception of harmful effects from landfills is
greater in Europe than in this country. While
Americans have tried to correct the problem
of leachate by building a better landfill. Euro-
peans have tried  to avoid the problem
altogether by burning and recycling the
refuse. Although operating costs per ton are
two to four times greater for a waste-to-
energy plant than for a landfill, the European
attitude  is that proper disposal through in-
cineration is worth  the  extra  cost.
   "Europe." says Sussman, "is 20 years
ahead of the U.S. in recognizing the problems
with continued land disposal  of solid waste
and also  in recognizing  the potential of
recovering energy from  solid  waste," But
continuing energy shortages and landfill
problems may yet combine to make
European-style waste-to-energy plants more
popular here.
   Europe is known for  its  historical sites.
Roman ruins, medieval  churches.
Renaissance palaces, Napoleonic monu-
ments. True, the continent is the repository of
many historical artifacts of  Western civiliza-
tion. But it is also  an advanced laboratory for
handling  the present and future artifacts of
that civilization  solid and  hazardous
wastes. D

Recycling  and
Waste   Exchanges
 The reuse, recovery and recycling of in-
 dustry's discarded materials is emerging as a
 solution  to the nation's waste disposal
    Increasingly, economic incentives  are
 playing a role in  changing attitudes toward
 discarded materials containing recoverable
 items As the price of raw materials steadily
 increases, so does the incentive to recover
 such materials from other sources More and
 more businesses are finding that what is
 good on a small scale  -in terms of  reuse,
 recovery and recycling  -is also good for
 large-scale operations
    The United States currently lags behind
 the rest of the industrialized world in recovery
 and recycling of materials. In Europe, for ex-
 ample, a long tradition of resource conserva-
 tion  has allowed several countries to es-
 tablish themselves as  recognized traders in
 resource recovery and recycling. The recycl-
 ing of paper products serves as one illustra-
 tion of the point.  The Europeans recycle fully
 twice as much paper as Americans do. This is
 true  for a number of other waste  products as
    This remarkable disparity may be  the
 result of this country's bountiful supply of
 relatively inexpensive raw materials. As  that
 picture is changing, however, so  is the coun-
 try's  interest in the reusing, recovering  and
 recycling of  materials.
    Recycling materials is  not a  new idea; in
 fact,  it has been around for quite some time.
 It is familiar to most Americans in the  form of
 newspaper  and  glass recycling.  Collection
 centers have sprung up all over the country
 for the recycling of common household
  A lesser  known, but widely used, form of
recycling involves industrial waste. Various
industries have made a common practice of
recycling waste products, such as steel scrap
and glass cutlet.  An area of increasing in-
terest in  industrial  waste recycling is  the
recycling of hazardous waste.

Hazardous Waste:
A Complex Problem
Hazardous  waste recycling  is a particularly
complex  area. It  is difficult to make
generalizations about hazardous waste
recycling because it is highly process- and
material-specific. Whereas municipal solid
waste recycling  is  fairly  similar throughout
the  country, hazardous waste recycling tech-
niques vary from industry  to industry, from
process to  process, from  waste to waste.
  The amount of hazardous waste currently
being recycled is not known. No one collects
comprehensive data on hazardous waste
recycling. In addition,  many recycling
processes are proprietary; information about
how much  is recovered  is not released  or
sought because it discloses valuable informa-
tion  about  the process, and gives business
competitors an unfair  advantage
  However, certain success stories are
known.  Dow Chemical Company, for  exam-
ple, operates a plant in Feeport, Texas, which
recovers  chlorine by a thermal process from
chlorinated wastes. Stauffer Chemical has
developed  a process for recovering and
reconstituting sulfuric  acid from the  spent
alkylation acids produced by oil refineries
Once the sulfuric acid is reconstituted it is
then recycled to oil refineries for reuse.
Another effective technique for the reuse of
industrial waste has been demonstrated by
Monsanto. This technique employs a  waste
stream from adipic acid manufacturing in the
desulfurization of stacks used in coal  com-
bustion. All of these techniques have proven
to be highly effective, and industry is well
aware of this
   A prime example of the multiple environ-
mental benefits which can result from in-
dustry creativity in  reprocessing hazardous
waste streams is provided by Dupont. At its
Edge Moor, Delaware, titanium dioxide plant,
Oupont  produces large amounts of iron
chloride as a by-product. Until 1974 Dupont
disposed of this iron chloride at sea. In 1 974
Dupont  invested several million dollars in a
process unit which  converts the iron chloride
into commercial grade ferric  chloride. The
ferric chloride is sold to waste water treat-
ment plants and water purification plants as
a coagulanf for suspended solids and an
agent for removing  phosphorus and dewater-
ing sewage sludge.  Not only  has Dupont
found an innovative way to recycle its iron
chloride waste stream, it has eliminated the
need for ocean  disposal and has converted
the waste into an essential element for water
treatment processes.
   The Office  of Solid Waste  estimates that.
excluding waste burned  for fuel, only  about
five percent of the hazardous waste
generated  in this country is currently  being
recycled. When  the  waste that is burned as
fuel is included, some 35 percent of the
hazardous waste generated is actually
recycled. This may appear impressive, but
                                                                                                               EPA JOURNAL

some estimates of the potential amount of
hazardous waste that can be recycled run as
high as 80 percent. Thus, there is significant
potential for improvement in this area.
   Basically, hazardous waste is recycled for
two reasons: (1) the value of the materials in
the waste, and (2) savings from not having to
manage the wastes.  The value of the
materials for  inhouse  use  or for resale has
long been the main reason for recycling, but
with the increasing costs imposed  on manag-
ing hazardous waste by RCRA regulations.
savings  will soon become a greater con-
   Silver is an excellent example  of hazar-
dous waste recycling  done for  reasons of
value. Silver is a highly valuable commodity;
it is  also quite  toxic. Photographic film  is a
basestock covered with a  silver emulsion.
Silver can be recovered from waste waters in
the emulsion  manufacturing process and
from scrap cuttings when the film  is trimmed
to roll size. Fully one  quarter of the silver
used in manufacturing can be recovered. The
process is fairly involved—it includes  settl-
ing, treating,  dewatering, roasting, smelting
and refining—but for  one  quarter of the
silver, it is worth it. Kodak, in Rochester, New
York, has the world's largest silver refinery;-it
operates completely on recycled waste silver.
   Savings as  a reason for recycling are
becoming more and more important as com-
panies look for methods to  deal with the
costs of  complying with RCRA and state
hazardous waste management regulations. A
pioneer  in this  effort is the  3M Company
which says it  has saved $76 million since its
waste reduction program began in 1 975. The
                            3M  program generates dollar savings by
                            reducing or eliminating pollution at  the
                            source rather than paying to clean it up. 3M's
                            motto, "Pollution  Prevention Pays."
                            recognizes that pollution represents  an inef-
                            ficient and uneconomical use of resources
                              Recognizing the potential  significance of
                            recycling  as a  tool for managing hazardous
                            waste, the RCRA regulatory  program has
                            adopted an approach which promotes recycl-
                            ing of hazardous waste. "UR3."which stands
                            for use-reuse-recycie-reclaim. is the acronym
                            which describes this approach. The goal is to
                            encourage hazardous waste  recycling while
                            still  maintaining control over some of the
                            recycling  methods. Under  UR3 the RCRA
                            regulations will impose stricter requirements
                            on some  recycling techniques compared to
                            others based on the wastes  involved; the
                            lighter regulatory  burden thus imposed on
                            some techniques should encourage recycling
                            through those  processes

                            Recycling within a company  or industry may
                            present a real solution with regard to certain
                            wastes, but what of the many other waste
                            products which the company  or industry can-
                            not  reuse, recycle, or  recover? Are  there
                            potential  uses  for these other industrial  by-
                            products?  Industry is discovering more and
                            more that one company's  waste may be
                            another company's  resource. Increasing  in-
                            terest in this form of recycling has led to  the
                            development of waste exchanges.
                              Waste exchanges are basically of  two  dif-
                            ferent types—waste information and waste
                                            A page from the Midwest Industrial Waste
                                            Exchange cy jnd news brochure.
                                             .  Fe
                                                     ' Acid
-entf-«' Kentucky

:  A-'9-]3
                  Nitric Acid
             60 gallons everv fir>°  SoJ"tion
                                   * 1*0
materials exchanges. The two differ in what
they transfer and the role they play  in the
basic transfer system. The former, of course,
deal only with the information about wastes.
serving  primarily as clearinghouses for
generators  and users. The latter actually
receive  and handle  the  waste materials
themselves, and thus function as an integral
part of  the transfer system
   EPA  has long been receptive to the idea of
waste exchanges. As early as 1976 the
Agency proposed to U.S.  industries  a
sequence of steps involving waste reprocess-
ing and exchange for their waste  manage-
ment strategies.
   These steps are designed  to:
•  Minimize the quantity of waste generated
by modifying the industrial process involved.

•  Concentrate the waste at the source to
reduce  handling and transport costs.

•  Transfer  the waste "as  is" without
processing, if possible, to another facility that
can  use it  as a feedstock.
•  Reprocess the waste for material recovery
when a transfer "as is" is not possible
•  When material recovery is not possible:
 -incinerate the waste  for energy  recovery
and  for destruction  of hazardous compo-
nents, or
  -if the waste cannot be incinerated, detoxify
and  neutralize it through treatment.
•  Use carefully controlled land disposal only
for that which remains
   One  example of  a successful  waste ex-
change  is the Midwest Industrial Waste Ex-
change. Begun in 1975 as the St  Louis In-
dustrial Waste  Exchange, this organization
was the first of its kind in the U.S.  An infor-
mation  source, this  exchange had 45 listers
in  each quarterly publication  of wastes in
1979. Today that number  has grown to ap-
proximately 1 25 listers per issue. The circula-
tion of the quarterly has jumped from 956  in
1979 to nearly 5,000 today.
   EPA  has assisted this exchange, where
possible, in upgrading and expanding its ser-
vices to the Midwest region. Other existing
waste exchange operations have joined the
Midwest exchange in its growing regional ef-
fort. The Minnesota  and  Iowa exchanges are
now participating in the expanding regional
program. Nebraska is also an active sponsor.
and the Waste Materials Clearinghouse in In-
dianapolis is expected to join forces with the
Midwest exchange  next year.
   The Midwest exchange  is one of the real
success stories in the area of waste recycling.
Its environmental contributions were
recognized  earlier this year when a panel of
judges for the President's Council on Environ-
mental  Quality, including EPA Administrator
Anne M. Gorsuch. conferred  on  this ex-
change  the  1982 Award for  Excellence in
Toxic Pollution  Control  Q

A   Moveable   Burner
 EPA has developed a mobile incinerator
 capable of burning large quantities of hazar-
 dous wastes at  a particular site.
   This three-trailer monster has the potential
 to eliminate some of the problems associated
 with hazardous  waste disposal. It  can  cut
 transportation and storage costs, and do
 away with accidental spills in transit.
   Still more encouraging,  the incinerator  is
 just  one  of dozens of technological innova-
 tions that  EPA's Office of  Research and
 Development (ORD)  is bringing to the  front
 lines of the war against  hazardous wastes.
   The incinerator was conceived in  1976,
 when ORD first issued a  request for
 proposals to develop the  unit. Mobility was
 critical for several reasons. Accidents that oc-
 cur while moving hazardous  wastes  to dis-
 posal sites  can  trigger health-threatening
 spills. But an incinerator that goes to the site
 of origin can eliminate the need for
 transporting small quantities of waste
 altogether Also, because a mobile in-
 cinerator  leaves the  site  when the job is
 done, it poses less danger to nearby residents
 than  a stationary incinerator or  landfill  The
 mobile incinerator should be  particularly ap-
 plicable to refractory synthetic organics such
 as  PCBs, Kepone. and dioxin --substances
 which are surrounded  by public sensitivity.
   In August 1980, the prototype incinerator
 arrived at EPA's Oil and Hazardous Materials
 Spills Branch in Edison, New Jersey for field
 tests and final  shakedown Since then, two
 test burns with  fuel  oil have been suc-
 cessfully completed.  A trial burn and field
 demonstration with PCBs are scheduled later
 this year at the Edison facility and Kin-Buc
 landfill. According to Frank Freestone,  Chief
 of the Hazardous Spills Staff at EPA's Edison
 lab. no major technical problems are expec-
   Trailer One of the  incinerator system is
 equipped with  a rotary kiln where organic
 wastes are fully vaporized. The kiln's 1800°F
 temperature partially destroys contaminants.
 The gases then pass to  Trailer Two, where
 decomposition  of contaminants is completed
 at 2200°F. In Trailer Three, a scrubber, par-
 ticulates are removed  and acid  gases
 neutralized. The cleansed gases are then dis-
 charged  from a stack.  A separate trailer
 monitors stack  gases.
  The mobile incinerator was the first of its
kind  A Massachusetts firm  has since
developed an  incinerator along similar con-
cept  lines. EPA is counting on the ingenuity
of American industry to produce future
generations of this technology. To encourage
this,  when testing is completed the agency
will provide interested companies with all in-
cinerator plans, specifications and permitting
application  materials.
  The incinerator can treat up to 100 tons of
dry hazardous waste,  or six  tons of liquid
hazardous waste  per day  Assuming an
operating cost of S10.000 per day. in-
cinerating costs, after set-up, should run
about S100 per metric ton of contaminated
solids and about  S1700 per metric ton  of
chlorinated fluid (S350 per 55 gallon drum).
While that is  by no means cheap, mobile in-
cinerators are still expected  to save money.
Savings will come from eliminating costs of
waste  transportation and storage.  Operating
costs will drop as experience is gained. And
companies  should be  able to reproduce  the
incinerator for less than half of the S2.2
million it cost  EPA to develop the prototype.
Of Soils
and  Spills
The  mobile incinerator  is one of many pieces
of innovative equipment that EPA's Office of
Research and Development  is working on to
meet program needs. Some equipment is still
in the research stage;  some is already
available for  field use  Private industry,
operating under Federal contract, can use the
equipment to clean up hazardous waste sites.
EPA believes the private sector will marshal
the technologies  and  skills to do  this job.
   The scope of EPA research projects is ex
tensive,  ranging from remote sensing to
acoustic monitoring, and from checking soils
to cleaning spills. These projects  include:
• A portable, inexpensive, and  low-
maintenance acoustic emission  monitoring
device provides early warning of potential
failure of earthen dams containing hazardous
materials.  It has been used for  industrial
waste impoundments and dams up to  1 50
feet  high,  and  on many occasions  has
provided adequate warning of dam  collapse.
• A carbon adsorption pilot plant can  be
used  to conduct on-site evaluations of the
treatability of chemica! waste solutions and
mixed chemical spills. Pilot scale systems
have  been used at two  uncontrolled hazar-
dous  waste sites  in New York
• A portable foam dike system sprays
polyurethane foam that forms a barrier, either
enveloping or diverting the flow of many
spilled hazardous  chemicals.  Firefighters and
other first-on-scene personnel often use this
to control the  flow of a spill.
• A mobile stream diversion system can dam
a stream above the site of a hazardous
materials  spill. This bypasses the normal
stream flow and facilitates cleanup  by  per-
mitting the spill area to.dry. The system was
 A full-length view of EPA's mobile incinerator
 when it was displayed behind the Agency's
 headquarters  in Washington.

recently used to provide uninterrupted water
service to communities in the area of a spill.
» Mobile systems for extracting spilled
hazardous materials from soil and for detox-
ification and regeneration of spent activated
carbon are under development.

• Also under development is a protective
clothing and equipment unit for workers in
highly toxic atmospheres. The self-contained,
fully encapsulating clothing and breathing
apparatus should protect workers  from
chemical exposure during cleanup operations
for  two and one-naif hours at a stretch.
  Since  technology transfer is  a  priority of
EPA's research program, the Agency  funds
conferences and publications so private in-
dustry  and others  can  learn about research
results. Conferences have been  held on con-
trol of  hazardous material spills, and on
management of uncontrolled hazardous
waste sites. Publications include a technical
handbook on preventing releases of hazar-
dous substances, and a bibliography on
hazardous materials analysis  methods
  There  is a futuristic quality to some of this
research work.  One example is the use of
remote  sensors to detect  leaching landfills.
Characteristics that may indicate leachate
pollution are wetness, gaps in vegetation or
snow cover, and anomalies in water, soil, or
rock. By tracking these characteristics over a
period of time,  remote sensing can identify
surface  water contamination at the land dis-
posal site, and  even some distance away
from the site.
   EPA's Office of Research and  Develop-
ment is  coming up with  a  whole assortment
of up-to-the-minute equipment to mitigate
the danger of hazardous  materials, industry is
picking  up  on some  of these opportunities.
and looking over others  in development. Ac-
cording  to Rita M. Lavelle.  EPA Assistant Ad-
ministrator for Solid Waste  and Emergency
Response, this  illustrates  how the Federal
government can support the private sector—
with frontier-piercing  technologies that  in-
dustry can duplicate. "Private firms know the
market," says Lavelle, "and  can adapt the
new technologies quickly."
   Lavelle explains that  private sector in-
genuity  is facing  a challenge: how  to put
prototype technology  into  practice to rid the
nation of hazardous waste. She is confident
the challenge  will  be met. She emphasizes
that Federal and state governments would do
well to work closely with industry to put new
technology on the road and to carry out
cleanup operations. "We must forge a new
relationship between regulators and the
regulated," Lavelle says, "one that  is based
on mutual  trust."

A  publication  entitled Environmental
Emergency Response Unit Capability con-
tains more information on some of the equip-
ment  mentioned in this article The April
1982 publication describes technology that
is either currently available or under develop-
ment  in the Oil and Hazardous Materials
Spills Branch of the agency's  Municipal En-
vironmental Research Laboratory. It also ex-
plains how to order more detailed  descrip-
tions  of specific pieces of  equipment. Single
copies are available from James J. Yezzi. Jr.,
Oil and Hazardous  Materials Spills Branch.
Municipal Environmental  Research
Laboratory. U.S. EPA.  Edison. NJ  08837  D

Land   Disposal
 For many years, the traditional method of dis-
 posing of waste has been to dump it on land.
 However,  as society is now discovering, un-
 regulated  land disposal can  endanger the
 quality of the groundwater, the air and the
 land itself
   The mistakes of the past in land disposal
 are now being cleaned up through such
 programs  as Superfund. However, EPA has
 long realized that to ensure that land disposal
 does not create future  problems, this disposal
 must be controlled in a way to protect the
 water, the air  and the land.
   Since the passage  of the Resource Con-
 servation  and  Recovery Act  in  1976, the
 Agency has examined many approaches for
 controlling pollution from hazardous waste
 landfills: surface impoundments (settling
 ponds), waste piles, and land treatment units.
 One approach was very vague, with no
 operational or performance standards. The
 proposal called for an  elaborate "risk assess-
 ment" which asked owner/operators  to
 predict what type of  pollution could result
 from the operation of the facility. Another ap-
 proach was very  inflexible, mandating in
 great detail exactly how a land disposal
 facility should operate.
   On  July 8, EPA's Administrator, Mrs. Gor-
 such. announced  the  promulgation of final
 land disposal regulations. These regulations
 are stringent, establishing strict environmen-
 tal protection and design and operation stan-
 dards that must be met. However, they allow
 for innovation on the part of the ow-
ner/operator. Although he has to meet the
performance standards, the  owner/operator
can select the  appropriate method of con-
trolling pollution.
  The land disposal standards, which will
become effective in six months, approach
regulation from the standpoint of protecting
America's groundwater drinking supplies. In
announcing the regulations,  Mrs.  Gorsuch
said that "protecting the groundwater
resources of Americans has been one of
EPA's central concerns in developing a
regulatory strategy for  the disposal of hazar-
dous waste on  land. These  regulations in-
clude an environmental standard that will en-
sure that the quality of drinking water for
future generations will not be compromised."
  Under the new regulations, both new and
existing facilities applying for a permit must
comply with the requirements for ground
water  monitoring, run-off controls, cap at
closure, third party liability requirements, and
post-closure requirements.
  New facilities, with  the exception  of land
treatment units, are required  to install an im-
permeable (e.g. synthetic) liner system as
well as a  leachate collection and treatment
system.  They may be exempted from the
monitoring requirements if they install a dou-
ble liner and a  leak detection  system.
  Facilities now operating do not have to
retrofit to install liners but  must meet all
other  requirements.
  The design features required by the
regulations are  similar to the  pollution control
devices  presently being installed in many
new facilities.
  These standards are one of the final parts
of EPA's core regulatory program to control
the  disposal of hazardous waste. The first
sets of regulations controlling the disposal of
hazardous waste were issued in  1980 under
the  Resource Conservation and  Recovery
Act. Together, the  regulations provide
"cradle-to-grave" management of hazardous
  EPA believes that the standards issued
will not stifle innovation. The standards
clearly set forth  the environmental results to
be achieved. It is left to the owner/operator
to determine the most appropriate design to
accomplish this goal. Besides being more
cost-effective, such an approach  keeps EPA,
the  States and the public focused on the
issue  of greatest concern—the environmen-
tal results that can be expected. EPA also ex-
pects  the regulated community to devote its
environmental expenditures to measures that
will achieve these results.
  Agency officials believe  the purposes of
RCRA cannot be achieved  unless the stan-
dards  for land disposal facilities  are capable
of implementation within the context of the
permit program. To meet this need, EPA's
regulatory approach must be one that can be
implemented quickly. Therefore, the  land dis-
posal  regulations emphasize  standards that
provide a clear indication of what is expec-
ted. Such certainty should reduce the time in-
volved in acting  on permits and should avoid
the  need for complex analyses with uncertain
outcomes. Q

Training   Local
Health   Officials
It's a hot day in mid-August. The air hangs
heavy with humidity. In this town of 7,000
residents, everything appears to move a frac-
tion of a second slower than normal.
   John Blackstone. the town health officer,
is performing his mid-summer Saturday mor-
ning  ritual, mowing the lawn.  Suddenly his
wife  bursts from the back door and urgently
summons  him  to the phone.
   It's the  town police chief. He is calling to
inform  Mr.  Blackstone of a chemical spill in
the stream which flows through the town.
Earlier  that morning, the chief  had  been
called to the scene by an excited fisherman
who  had noticed fish floating belly-up in the
water.  The chief had found four containers:
three 55-gallon drums and one paper carboy
The carboy and one of the drums  were  leak-
ing into the stream. There was a smeil of rot-
ten eggs mixed with a curiously sweet odor.
On the stream embankment, the  chief had
started to cough violently. He had moved  to
higher  ground, and now was calling the
health  officer to find out what  to do.
   This scenario is part of a final exercise in a
course entitled Hazardous  Materials in the
Community: The Role of Local Health
Officials The course and its corresponding
student and instructor's manuals  were
developed by the  Department of  Environ-
mental Science. Cook College,  Rutgers Un-
iversity, under  an  academic training grant
from the Environmental Protection Agency.
   While the incident portrayed above  is fic-
titious, real incidents just like it are becoming
more common in  communities  throughout
the country. The increasing frequency of such
episodes involving  hazardous materials has
   Final drafts of the course manuals are
   in preparation. The model course will
   consist of 40 instructional hours con-
   sisting of 30 lectures and one incident
   response exercise. Further information
   on the course is available from  Dr.
   Peter Strom,  Dept. of Environmental
   Science, Cook College, Rutgers Univer-
   sity,  New Brunswick. NJ 08903.
accentuated the need to train people who
can respond in an appropriate.
knowledgeable way. Training courses
abound, but most are not targeted at an im-
portant, available manpower resource: en-
vironmental enforcement officials from local.
regional,  and county public  health agencies.
These individuals typically have a background
in biological, physical, or health sciences that,
with proper training, would  equip them to
make routine or emergency responses to
hazardous materials incidents.
  Some of the activities local health officials
could carry out include the  following:

• Inventory the community  to identify
sources of  hazardous materials.

• Help develop an mtra-local agency con-
tingency  plan for  emergency responses,
spelling out the roles of the police, fire, public
works, emergency management,  and other

•  Inform  citizens about hazardous materials
                                          "Hazardous waste is a matter of uni-
                                          que  concern to New Jersey . . .  Our
                                          problems  with toxic and hazardous
                                          waste are not limited to the cleanup
                                          of disposal sites or even the siting of
                                          new facilities. We need to do a much
                                          better job of law enforcement.
                                          Poisoning our water supplies and
                                          threatening  our health is a  heinous
                                          criminal act."

                                                    -Gov Thomas H Kean oi New Jersey
* Respond to public complaints about hazar-
dous materials.

• Make initial assessments of a hazard and
associated risks.

• As first-responder. help stabilize and
resolve an incident.

• Trigger appropriate remedial and enforce-
ment activities.
  The Rutgers/EPA  course and manuals are
intended to facilitate development of courses
for this specific audience: local, regional, and
county health officials Organizations that use
the course material to provide quality training
for this audience will also supplement course
material with state and local expertise This is
absoluteiy necessary so that  regional issues
can be adequately addressed
  The course was recently field tested in a
pilot presentation to 25  State and local
health officials co-sponsored by the New Jer-
sey State Department of Health and the New
Jersey Department of Environmental Protec-
tion. It will next be revised and offered by the
University of New Mexico in association with
the  American Public Health Association to
representatives of graduate-level environ-
mental and public health schools to become
part of their  own curricula.
  Local health officials are  knowledgeable
about a broad spectrum of hazardous waste
issues, and can  be a valuable community
asset in hazardous waste incidents  The
EPA/Rutgers/University of New  Mex-
ico/American Public Health  Association  ef-
forts should help these health officials yet the
additional  training in hazardous materials
that they both want and need. D
r/i/s  article  was  written  f>y  Di   Ji>ri,ir
Ht'ikowtts ,m<7 He/rn frnsAr ;,l tht* /VVu Jei
sey  State Department  of  Environmental
Protection; and by Frank Flower,  Dr Peter
Strom, and Maria  van Ouwerkerk of Cook
College, Rutgers  University. Dr. Berkowitz is
technical advisor to the director of the Divi-
sion of  Water  Resources.  Ms.  Fenske is
Assistant Commissioner  of  Natural
Resources, Mr.  Flower  is  an  Extension
Specialist. Dr Strom  is Assistant Professor,
and Ms. van Ouwerkerk is Pro/act Consultant.

Transport  of
EPA has a new plan for relieving some of the
paperwork burden on generators and
transporters of hazardous wastes.
  Currently almost half the states have their
own manifest forms, and a transporter may
have to carry the  manifest of each state
through which he travels. If EPA's proposal is
adopted,  this blizzard of manifests will be
replaced by a single, standard form for use in
every  state.

A manifest is a control and transport docu-
ment that describes a collection of waste and
accompanies it  from point of generation to
point  of destination. The purpose of a
manifest  system is to assure that hazardous
waste actually arrives at its intended destina-
tion for treatment, storage, or disposal (TSD).
  The Resource Conservation and Recovery
Act of 1976 (RCRA)  called for EPA to es-
tablish a manifest system. The agency first
proposed a system in December 1978. and
set it  in final form in February 1980. At
that time, EPA  considered and rejected the
idea of a uniform manifest, deciding instead
to require only specific information,  not
specific forms. Members of the regulated
community were already required by the
Department of Transportation to use a ship-
ing paper for transporting hazardous
materials. Trying to minimize  paperwork,
EPA  gave them the option of adapting the
shipping  papers to function as manifests or
designing their own forms.
  What the  agency didn't foresee was that
individual states would require state
  The result was multiplying manifests. At
least 21  states  developed their own forms.
often  asking  for dupficative information. If a
shipment of  hazardous waste had to go
through five or six of these states to reach its
destination, it was possible that  the
generator would have to fill out five or six dif-
ferent manifests. The lack of uniform require-
ments also kept multi-state generators from
standardizing their manifest procedures.
  Relief was needed. It came—or at least
the  promise of it came—this March when
EPA published in the Federal Register a draft
Uniform Hazardous Waste  Manifest form. In
a companion action, the Department of
Transportation declared that any state
manifest differing from EPA's would be con-
sidered inconsistent with DOT regulations.
  The new form identifies the generator,
transporters, and final destination site for
each shipment of hazardous waste. Wastes
are identified by name, hazard class, quantity,
type and  number of containers,  and  DOT's
key  emergency response number. Transpor-
ters and facility owners or operators
acknowledge,  on the form, receipt of the
materials listed.
  EPA has not increased its requirements for
information  on  the new form except for one
minor item,  inclusion of a telephone number
for the treatment, storage  and disposal
facility. A unique manifest document number
will  allow each generator to manifest up to
100,000 shipments before repeating a num-
ber. An optional continuation sheet for ad-
ditional wastes and transporters eliminates
the  need  to fill out multiple separate
manifests for one shipment.

in a Buffalo Herd
The period for  public comment on the
proposed uniform manifest, originally
scheduled to end May 3, was extended on re-
quest to June  1 7. In all, more than  1 50
organizations sent comments. Almost all
agreed on the need for uniformity, but almost
all disagreed on how to achieve  it.  Although
opposing  the uniform manifest is, in the
words of an Oklahoma official, like  roller-
skating in a buffalo herd, many people
decided to put on their skates.
  Most states want the form modified. They
want to continue receiving state-specific in-
formation that is required on their own forms
but  not on the  proposed Federal form. They
are  also concerned about their right to print
and control the manifest document.
  Industry generally supports the  form,
favoring rapid implementation. Uniformity is

the paramount concern here. The comments
received indicate that companies would
rather deal with more requirements for infor-
mation, as long as they are uniform, than
with "optional" spaces. The few firms that do
oppose the form are currently under no state
manifest regulations.
   Both industries and states worked hard to
help develop the proposed uniform  manifest,
and both are making extensive  suggestions
during the comment period. Through their
professional organizations—the Association
of State and Territorial Solid Waste Manage-
ment  Officials (ASTSWMO) and the Hazar-
dous  Materials Advisory Council (HMAC)—
the two factions are trying to  reach agree-
ment  on controversial issues. Some sort of
compromise appears inevitable, possibly a
tradeoff of more requirements for fewer op-
  EPA will consider all  comments before
making  any  revisions in  the proposed
manifest. However,  the Office  of  Manage-
ment and Budget has the final say because it
must approve the form A  lot  depends on
how broadly  or narrowly OMB views the
Congressional mandates of EPA to "protect
human health and the environment" and of
DOT to provide for transportation safety.
While inclusion of more information  on the
form may be  important for purposes of state
record-keeping, it may not  be  important  for
purposes of meeting the mandates of RCRA
and  the Hazardous  Materials Transportation

of Compatability
According  to EPA Administrator Ann Gor-
such, "A new hazardous waste manifest
system would clear up the current confusion
caused by  many separate and differing  state
manifests.  Reducing the paperwork burden
on the regulated  community is one of this
Administration's top priorities," she con-
tinued. "EPA and DOT have worked hard to
accomplish this goal by simplifying  the
paperwork  now required  from  hazardous
waste generators, transporters, and facility
   The question in many  states is whether
the regulated community's  priority of
paperwork  reduction is compatible with the
states' priority of state-specific waste infor-
mation.  States have commented that their
additional information is so important to their
hazardous waste programs that, if necessary,
they will use other methods to collect it. such
as requiring monthly reports from generators
and TSD facilities. Therefore, they argue, im-
plementation of the  proposed  uniform
manifest would not alleviate the paperwork
burden on  the regulated community  at all.
but would,  in fact, actually  increase it.
   The trick for EPA right now is to find a way
to maintain both uniformity and individuality
The agency wants a real  solution to  this
issue, and that will require real compromise
between  industry  and the states. P

Hazardous  Waste   Enforcement
A change is taking place in the enforcement
of RCRA and Superfund, a change best
characterized by the terms "environmental
results" and "cooperation, not confronta-
   Together these terms should translate into
significant benefits for public health and the
environment: for RCRA properly enforced
means no new  hazards due to  mismanage-
ment of hazardous wastes, and for Superfund
properly enforced means expeditious, effec-
tive cleanup of the nation's worst hazardous
waste  sites.
   Enforcing RCRA and Superfund for en-
vironmental results places the emphasis on
action—where it should be. A few examples
of such action should illustrate the point.

•  In May a Federal District judge sentenced
a landfill operator  in  Pennsylvania  to one
year's imprisonment and a $200.000 fine for
criminal violation of federal  pollution  laws.
The  landfill operator had been convicted of
repeatedly  allowing pollution to  drain into
two  tributaries of the  Schuylkill  River.

•  In June  1981, z New York businessman
received a two and one-half year prison sen-
tence for dumping PCB-laced oil along North
Carolina roads;  a second defendant received
an  18-month jail term.

•  Last November, a Vermont paper-mill ex-
ecutive was sentenced to 90 days and fined
$25.000 for violating  an environmental con-
sent decree.
These  are examples of environmental results
achieved through criminal enforcement ac-
   Where enforcement efforts succeed, the
bad operators will be prevented from
polluting the environment further. Equally im-
portant, such actions  will deter  others from
attempting similar illegal activity. In all. the
environment stands to benefit considerably
 from both  the measurable enforcement ac-
 tions taken and the immeasurable effects
 these  actions have on the regulated com-
   OSWER's Office of Waste Program Enfor-
 cement (OWPE). working with the Office of
 Legal  and  Enforcement Counsel and the
 Department of Justice,  as well as various
 state and local authorities, plans to go after
 the  same type of environmental results.
   Another  important measure of environ-
 mental results  achieved by enforcement is
 the commitment of private money and effort
to improving hazardous waste management
and cleaning up problem sites. Enforcement
actions are often the catalysts for drawing
such commitments from the private sector.
   The Hyde Park landfill case in Niagara,
New York, is a good illustration. As a result of
EPA enforcement actions, the Hooker
Chemicals and Plastics Corporation signed a
consent decree on April 30 committing the
company to an estimated $30 million worth
of cleanup of the hazardous wastes at the
site. In all, OWPE enforcement efforts have
brought in more than $82 million in private
money for cleanup efforts at 22 hazardous
waste sites.
   Another measure of environmental results
is the number of facility inspections conduc-
ted under the RCRA regulatory program's
compliance monitoring system. Through these
inspections EPA is able to assess the impact
of the RCRA regulations on upgrading haz-
ardous waste management. EPA shares
this enforcement responsibility with states
authorized to carry out  their own RCRA
programs.  Thirty-two States and territories
are  currently authorized to monitor the
generators and handlers that treat, store and
dispose of hazardous waste. It is expected
that at least 45 States will obtain authoriza-
tion to implement the program by  1983.  In
fiscal 1981. more than 6.000 generators and
handlers were  inspected. A total of 1,006
EPA inspections and 6,222 state inspections
have been conducted so far in fiscal 1982.
EPA is projecting a total of 9.100 inspections
for the year—an increase of 50% over last
  In addition to the inspection program, both
EPA and authorized states can send warning
letters and issue administrative orders requir-
                        Waste Programs Enforcement
    Two of the key offices in the enforce-
    ment of hazardous waste laws are the
    Office of Waste Programs Enforcement
    (OWPE) and the Office of Legal Enfor-
    cement  Counsel (OLEC).
       OWPE is one of the three program
    offices within the Office of Solid Waste
    and  Emergency Response. Rita M.
    Lavelle is the Assistant Administrator
    responsible for that Office; Gene
    Lucero is the Acting Office Director. It
    has authority to act under both RCRA
    and  Superfund.
       OLEC is one of  two offices within
    the Office of Legal Enforcement Coun-
    sel and  General Counsel headed by
    Associate  Administrator Robert Perry.
    The legal work for each of the environ-
    mental media—such as air. water.
    waste and  toxics—is performed here.
       Basically there are two types of en-
    forcement activities—administrative
    and judicial. The tasks associated with
    these activities are divided between
    OWPE (administrative) and OLEC
    (judicial). But. because of the legal and
    technical complexities of hazardous
    waste cases, the administrative and
    judicial enforcement staffs work closely
       There are two aspects involved in
    any  enforcement action—legal and
    technical. The  legal matters are han-
    dled by attorney-advisors in OLEC. The
  technical work  is performed  by the
  engineers, environmental scientists,
  lexicologists  and hydrogeologists in
    In enforcing  both  RCRA and CER-
  CLA, OWPE has the  authority to carry
  out the administrative enforcement ac-
  tivities. These include issuance of
  notice letters or warning letters, ad-
  ministrative orders, and orders on con-
  sent. As a matter of policy and prac-
  tice. OLEC supports OWPE in these ac-
  tivities. In fact,  in the case of  Super-
  fund enforcement actions, legal and
  technical staff members at headquar-
  ters and the  regional offices form a
  case development team to handle all
  aspects of enforcement action at a site.
    Howev£r. once enforcement  actions
  escalate to the  level  of bringing a civil
  action—actually filing suit against a
  defendant in  federal  court—the
  attorney-advisors in OLEC take the
  lead. At this  point, OWPE supports
  OLEC by providing technical expertise
  such as expert  testimony, developing
  remedial actions plans, and monitoring
  cleanups performed in accord with a
  consent order.
    In a nutshell:
  OWPE asks the question: is the
  evidence technically sound? OLEC asks
  the  question: is it legally defensible?
                                                                   EPA JOURNAL

ing compliance with RCRA regulations.  In
fiscal  1982  EPA has already issued  275
notices of violation, the states have sent 862.
For the full year EPA is projecting a total of
approximately 2.000,  nearly a 100  percent
increase  over  1981. EPA  issued 155 ad-
ministrative orders in fiscal 1981. The states
issued a  total  of 444. So  far in fiscal 1982
EPA has  issued  164, the  states 1.100. The
projected total of 1,500 for the year repre-
sents nearly a 50% increase. These combined
EPA and state efforts have yielded
remarkable results
   More  serious  problems, repeated viola-
tions  or failure to comply  with such orders
will lead  to judicial action.  Twenty hazardous
waste cases have  recently been  referred to
headquarters from the regions, 60 more are
under development in the regions, with some
200 others in various stages of investigation
and development. There are currently nine
referrals  to the Department of Justice seek-
ing injunctive  relief for serious RCRA viola-
   The first results of EPA's efforts in criminal
enforcement are also  beginning to appear.
After  signing a memorandum of under-
standing  with  the FBI on criminal investiga-
tions. EPA referred eight cases to the Agency
in  the past year.  Many of the  65 criminal in-
vestigations  and referrals  currently being
made in  the Agency are RCRA cases This
number represents a real shift in criminal in-
vestigation emphasis from Clean Water Act
violations to RCRA actions  It also reflects
the high  Agency priority given to  hazardous
waste enforcement.
   A final measure of environmental results
in  enforcement involves progress in hazar-
dous waste litigation. Impressive results have
been achieved in litigation based on the "im-
minent hazard" provisions of RCRA and,
most  recently, under Superfund. Some 63
cases have been filed under these statutory
authorities. They involve both active and in-
active sites, and incidents of contamination
of  ground water, surface water, air, soil, and
danger of fire and explosion. So far, this
litigation has lead to 10 preliminary judicial
orders and 20 consent decrees which have
resulted  in privately financed cleanup —
impressive environmental results

Not Confrontation
Upgrading  hazardous waste management
practices in this  country will require the full
cooperation of the regulated community. The
same  is true for cleaning up the thousands of
sites where hazardous  wastes have been
buried. Thus, effective enforcement of RCRA
and Superfund must place  a  new emphasis
on cooperation with  all  parties  in order  to
achieve the desired results
   The confrontational strategies of the past
have proved more effective at producing con-
flicts than true environmental benefits. A
strategy of cooperation between EPA and the
parties affected by RCRA and Superfund
should change this pattern  and begin to
realize the  environmental improvements
which these laws were designed  to effect
   A case in point is the agreement reached
with Browning Ferris Industries in New
Brunswick, New Jersey. This company
purchased a landfill which it subsequently
discovered was leaking pesticides and toxic
chemicals. Wastes migrating from the site
contaminated ground water, surface waters.
and the surrounding soil.
  The company volunteered to undertake
the  assessment and cleanup of this site  The
case could  have been litigated literally for
decades had the company  not acted respon-
sibly, and had the EPA enforcement team not
carefully negotiated a satisfactory agree-
ment  Under the terms of the agreement
Browning  Ferris must:
  cany out a remedial investigation  plan:
—drill wells and take groundwater samples:
  -conduct hydrogeological studies and
report results.
  propose a remedial plan to prevent further
  implement remedial action and conduct
monitoring  for  three years.
  This agreement represents a significant
dollar investment in cleanup at that site  The
enforcement action leading to this agreement
probably did not cost the government a frac-
tion of that amount. An extended legal battle
might well have reached the same result, but
at much greater cost to the government
and to public health and the environment as
well In cost-benefit terms the choice is clear:
cooperation is preferable to  confrontation in
achieving environmental results.
  The most recent actions  taken under
Superfund provisions include the  first two
consent agreements negotiated under this
law, those  reached  with the Stauffer
Chemical Company in Woburn. Mass . and
Aerovox.  Inc., in New Bedford,  Mass  EPA
Administrator Anne M. Gorsuch cited these
two agreements as examples of companies
"coming forward voluntarily" to undertake
desired environmental actions In the first ex-
ample. Stauffer  Chemical committed itself to
an extensive, $2-3  million  program  of
studies, cleanup, and monitoring at its In
dustriplex site. In the second. Aerovox agreed
to conduct an estimated S300.000 worth of
studies and cleanup efforts  on PCB-
contaminated soil behind its plant on the
Acushnet River.
  Assistant Administrator Rita  M. Lavelle
emphasized that in  the enforcement area:
". . . while I  much prefer the carrot  to the
stick approach,  the  stakes are too high  to
hide the stick or fail  to use  it  when justified."

Emergency  Responses  by Industry and Government
3 roles of industry and government in controlling hazardous material emergencies are described in the following articles
 "The common conception of
     .'i) up hiuardous material
 spills is one of government
 spe< i.ilists rushing to the rescue
 In fact, 93 percent of the
       ',cs to such environmental
 i:m(.'t()'Mici(!s aie uiken <.,ire of by
     'lustn.il  i.onc:(!rns directly
 involvorf  The  majority of the
                .  .iteri quietly
 rind i.'fficKMitly. long before they
 hui ome ,1 Mimce of public con-
 i.eni The few emergent
 which  Federal or State govern-
 ments  i|(:t directly involved in
     ip .ifc fully coordinated and
 usually mi.hull- industiy expeits
    I CA . I mergency  Resp.
 !'ioi]Fiim encourages industry
 ;iri(i (tin States to take all
 .iv.iil;ibl(;  i. 01 inter measures
 without direct Federal interven
 linn  Indeed the response
 program is an excellent example
 of the  Administration's New
 ( eiiiT,ill-sin Approach "

 I Imuy Vrm Cleave,
 Acting Director.
 Lmoryency  Response
                           The  Leaking
                           Tank  Car
                           on  TC-4
                           At 11:05 a.m. on May 11, a Un-
                           ion Pacific  railroad dispatcher
                           reported that as Train TC-4. Extra
                           2830 East, stopped at a siding
                           near Topeka,  Kansas, the  con-
                           ductor had detected a possible
                           leak of sulfur dioxide from one of
                           the tank cars.
                             That report set off an effective
                           response, an example of how in-
                           dustry can  handle hazardous
                           substance emergencies
                             At 1111 a.m.. six minutes af-
                           ter the  initial  report, the
                           emergency response information
                           dealing with sulfur dioxide was
                           obtained. A cail was made to L.
                           R  Tierney. manager-
                           environmental control in the
                           railroad's Omaha headquarters,
                           for instructions..
                             As a slow  rollby inspection
                           yielded  no  further evidence of
                           damage, the train was allowed to
                           proceed to  the 18th Street Yards
                           in Kansas City, Kansas, where it
                           was stopped  on the outer belt
                           track. Radio contact with  the
                           conductor established the fact
                           that he had smelled a strong sul-
                           fur odor and  heard a "hissing"
                           sound coming from the top  of
                           one car
                              Bob  Stine, designated by
                           Tierney as emergency response
                           manager, donned  protective
                           gear, including self-contained
                           breathing apparatus, and inspec-
                           ted the car. Hearing the same
                           hissing sound reported earlier, he
                           checked valves and fittings and
                           sought unsuccessfully to tighten
                           the manway  cover plate nuts.
                              At  1:20 p.m., another  call to
                           Tierney confirmed the car
                           definitely was leaking and that
                           attempts were being made to
                           secure  the manway nozzie bolts
                           to stop the leak
                              At 2 p.m.  a buffer car was
                           coupled to the leaking tank  car
                           and the latter was isolated in the
  At 3:30 p.m. the owner of the
car had been contacted  His
quality assurance supervisor was
unsuccessful in controlling the
  At 5:30 p.m., a conference
call among the emergency
response specialists agreed that
another effort should be made to
tighten  the nuts with a wrench.
  At 7:15 p.m. an effort was
made, to no avail
  At 8 p.m. a  conference call
was initiated to critique the
situation. It was decided  the car
should be isolated insofar as
possible from populated areas as
well as from employees. The spot
was selected and  the car moved
at 11:30  p.m.  Barricades were
erected to seal off the area.
  On May 12. Tierney provided
other guidelines regarding safe
distances  from  the car and the"
necessity  of protective equip-
ment. Self-contained  breathing
apparatus was  used by those
working on the platform.  A total
of 38 cylinders of oxygen was re-
quired during the  response.
  Other emergency response
experts arrived  at  the scene  and
further efforts  were made to
reset the  manway cover. The
process of finding another tank
into which to transfer the sub-
stance was undertaken.
  Sulfur dioxide is a colorless
gas or liquid with a sharp,
pungent odor which is detectable
at  three parts per million. It is
soluble in water, forming sul-
furous acid, a suffocating, sulfur
odor and  highly toxic by inges-
tion and inhalation. It is also a
strong irritant to the skin.
   Neutralization processes were
suggested and approved. Two
steel drums of a water solution of
soda ash were placed at the car
and hoses were inserted bet-
ween the lips of the manway
cover plate and manway nozzle
to  direct some of the leaking
vapor into the drums, reducing
   On May 13, a  repair crew
arrived  with torches and air  im-
pact wrenches, but it was unable
to  stop  the leaking. It finally was
decided to cover the trouble-
some area with lead wool,
diverting the  leaking vapor into
the soda ash solution which
would neutralize it.
   Meantime, another tank was
dispatched to the scene, arriving
the morning of May 15.
   Pumping of the substance
from the leaking car to the new
one began at 8:35 a.m. on May
16. It continued until 10:30 p.m.
when the pumps failed.
   On May 1 7, an air compressor
was placed at the site.  The
transfer of the substance was
completed by 1 1:30 a.m.

   By utilizing the soda ash solu-
 tion from 2:30 p.m. until 7:30
 p.m.. the crew was able to
 neutralize the remaining vapor
 pressures inside the car.
   On  May  18. the hoses were
 removed and  the leak  area
 packed with lead wool. After in-
 spection, the  car was declared
 acceptable for movement. It was
 stenciled "LEAKY TANK.  DO
 in accordance with Department
 of Transportation regulations.
   Documentation of the incident
 was completed. Approximately
 one ton of sulfur dioxide had
 been released during the period.
 There  were no injuries.
   What might have been a
 serious threat to human health
 and the environment had been
 successfully controlled  by an in-
 dustrial environmental  response
By John C.  Zercher
Chemical Transportation
Emergency Center
WASHINGTON—One morning
recently, newspaper readers
were greeted with headlines
about three major transportation
incidents involving hazardous
   Trains had derailed in Florida.
Michigan and Canada. Chemicals
were spilled.  People and com-
munities were threatened.
   Story followed story on the
emergencies themselves. But lit-
tle was said about the behind-
the-scenes action triggered by
such incidents—or about the
even more important  efforts to
prevent them from happening
and  to limit their effects when
they do.
   While hundreds of  millions of
tons of chemicals are produced
and  shipped across the  United
States each year, only one-
hundredth of one percent of ship-
ments over five gallons  result in
problems. When these rare inci-
dents do occur, and carriers and
emergency services require
special assistance,  CHEMTREC
is ready to respond.
  In 1970. with the encourage-
ment of the United States
Department of Transportation.
the  Chemical Manufacturers
Association (CMA) authorized
the  creation of CHEMTREC. the
Chemical Transportation
Emergency Center. Funded
solely by CMA.  CHEMTREC.
through its single telephone
number, provides assistance on
handling chemical incidents to
emergency services and carriers
throughout the United States us-
ing  various forms of transporta-
tion such as ships, tank trucks.
barges, and trains.
  CHEMTREC operates on a
two-step basis.  First, when the
caller identifies the product in-
volved, the center provides infor-
mation from its extensive files.
  Next, the center contacts the
shipper or other source  of exper-
tise for additional telephone ad-
vice or on-site assistance.
  When  an incident occurs.
CHEMTREC might  receive a call
from a fireman, or a policeman.
which is taken by the com-
municator on duty. He  records
the  essentials of the incident, in-
cluding the caller's name and
callback number. This typically
represents the newspaperman's
"who. what, when and why" ap-
proach. When the essentials are
determined, the communicator
obtains the proper file  card and
reads this information to his
caller. The information includes
guidance on the general nature
of the product,  and information
on spill, leak, fire or exposure.
and a limited number of physical
characteristics of the spilled
   Once the communicator has
passed this information to the
caller, he contacts the involved
company immediately. This is
done either directly by telephone.
or with  other equipment which
transmits an identical copy of the
message on the screen to a
receiver at the  shipper's facility.
This eliminates  problems of
transposition, improper spellings.
and other delays that occur with
telephone transmission of  the
same type information.
   In making this call, the  com-
municator turns the problem
over to  a company represen-
tative, who could be a  plant
manager, a product superinten-
dent, a  technical service
representative or another
knowledgeable  person.  Hun-
dreds of companies have people
available to handle these calls.
giving CHEMTREC access  to
thousands of experts.
   Under certain circumstances,
the call will go to a mutual aid
team such as that operated by
the Chlorine Institute or the
National Agricultural Chemical
Association. In  these incidents.
the nearest producer will be
called on for assistance.
   There are also mutual
assistance groups  handling
specific products such as
hydrogen cyanide, vinyl chloride,
hydrogen fluoride and
   In the ten and one-half years
since  the program  started
operating. CHEMTREC has han-
dled 163.000 calls, involving
22,700 reportable  incidents.
There has been considerable
growth of activity in these years.
Also, there is a definite
seasonality in the operation with
lower activity in the winter.
   The percentage of shipments
by various means of transporta-
tion varies little over the years.
Most of the tonnage is sent in
bulk shipments.
   Tank cars and drums are con-
sistent in occurrance rate,  with
tank trucks experiencing a lower
rate because of more
knowledgeable drivers.
   When CHEMTREC started
most of the  calls were expected
to be  from police, firemen and
other  emergency workers.
However, usually the first person
to encounter a leaking drum.
tank or tank truck is the carrier
   CHEMTREC. a central coor-
dinator of the emergency
response capability of the  in-
dustrial community, plays a ma-
jor role in helping to ensure safe
shipment of hazardous materials.
The safe shipment  of hazardous
materials is  critical, and CHEM-
TREC  is the key component of
the shipment support system. D
                Dow's DAISY

                If a chemical spills and threatens
                nearby areas, Dow Chemical U.S.A.'s
                Louisiana Division calls on DAISY.
                   DAISY is the acronym for a disper-
                sion analysis information system which
                tells emergency response personnel at
                Dow whether a gas will travel outside
                the plant and reach nearby homes.
                   The new  response system.
                developed in 19 78. was prompted by a
                chlorine release that heightened public
                awareness of chemical  spills and ac-
                centuated the need for improved  coor-
                dination with local emergency forces.
                          Fed information about weather con-
                       ditions, size of a spill, dispersion
                       characteristics of gases, and wind
                       speed, the DAISY computer deter-
                       mines what action if any must be taken
                       to protect 135 homes located adjacent
                       to the Dow plant, plus an additional
                       300 homes within  a  one-mile radius.
                          If DAISY says the release will travel
                       outside the 1,100-acre plant site, local
                       authorities are notified to coordinate
                       safety activities.
                          Only once in three years has DAISY
                       called for action outside the plant. In
                       that  case about 20 homes were
                       evacuated temporarily.




 by Steve Dorrler
 EPA Environmental
 Response Team  Leader

 A flat bed  tractor trailer rig,
 placarded with diamond-shaped
 signs reading  "DANGEROUS".
 spills its load near a freeway in-
 terchange during the morning
 rush hour.  Boxes and 55-galton
 drums litter the site  A deputy
 sheriff arrives, reroutes traffic
 and radios his office that a
 serious  situation involving hazar-
 dous materials could exist. He re-
 quests  expert  assistance im-
 mediately to assess  the situation
 Mini Mdvise on cleanup.
   If uncontrolled, release of
 hazardous  substances in this in-
 cident could have adversely af-
 fected public health or the  en-
 vironment  The incident.
 however, was not real. It was
 simulated,  as it is periodically, by
 EPA's Environmental Response
 Team at the Agency's Region  2
 facility  in Edison. New Jersey.
   "Assistance" in this and
 similar  simulated cases is
 provided by participants in  a
 crisis (raining  course conducted
 by the  ERT for emergency
 response officials from Federal.
 State and  local agencies and in-
 dustrial facilities.
   Teaching this and comparable
 courses is  only one of many
 associated duties of the busy
 ERT, which serves as the focal
 point of on-site assistance  for
 EPA's Office of Emergency and
 and History
 The ERT  is composed of eleven
 experts who provide multi-
 disciplinary assistance to the
 Agency's other hazardous waste
 and iMnercjency response experts
 located in the ten Regional  of-
fices. Together,  the members of
the ERT have nearly 1 00 years of
technical  experience in dealing
with  hazardous  wastes.
   The  ERT was established in
1978 under the National Con-
tingency  Plan, the vehicle
through which the  coordination
of federal hazardous  cleanup
and response efforts was direc-
ted under the Clean Water Act.
   The  basic ERT function in-
itially was to advise On-Scene
Coordinators and Regional
Response Teams on environ-
mental issues dealing  with the
cleanup of oil spills in navigable
waters, and accidents involving
approximately 300 hazardous
   When  Congress  enacted the
Superfund Act in 1980,  it  direc-
ted EPA  to broaden the
emergency response authority in
the National Contingency  Plan.
Thus, Superfund is currently ac-
tivated by emergencies at sites
as well as spills, by  threats to air.
land, and non-navigable  as well
as navigable waters, and  by acci-
dents involving  a much  larger
number of hazardous
   When local communities are
afflicted  by environmental
catastrophes, they  often  are un-
able  by themselves to deal with
them.  Through  its  Regional of-
fices and the ERT. EPA is able to
furnish support  personnel,  highly
skilled in various aspects of en-
vironmental emergencies
   The eleven ERT  members
have experience in major  dis-
ciplines involved in dealing with
hazardous substances, including:
biology, ecology; chemistry and
chemical engineering; civil and
sanitary  engineering,  environ-
mental health and  science; and
industrial hygiene
   ERT training emphasizes ap-
plication  of new technology and
equipment, especially  safety
equipment and  decontamination

and  Duties
Primary functions Team mem-
bers are equipped to perform in-
clude  chemical, biological and
physical  treatment  and monitor-
ing techniques; control,  restora-
tion,  disposal and contingency
planning during emergencies; in-
stallation, operation and evalua-
tion of instrumentation and field
response systems; sampling and
analysis of air.  water  and  soil;
water pollution biology and tox-
icology, environmental response
training; occupational  health and
safety risk assessments; extent
of contamination studies;
preparation of cleanup contracts;
groundwater and soil contamina-
tion studies.
  The ERT's major duties in-
clude;  Maintaining an around-
the-clock  activation system; dis-
patching team  members to
emergency sites to assist
Regional and program offices;
consulting and  providing
specialized equipment; training
and developing training

The  Changing  Nature of
Since its founding in  1978, the
ERT has responded to  more than
170  emergency incidents  and
hazardous waste sites. It has
provided technical assistance  in
another 250 incidents.
  The type of  support provided
has changed since  1978,
however.  During its first year  of
operation, the ERT responded to
42 incidents, approximately half
of which were oil spills. Such in-
cidents can be handled  by a
single individual with  little or  no
respiratory protection. Now
cleanup cases involving  various
hazardous materials take longer,
require a minimum of two people
operating on the "buddy  system",
and generally utilize
sophisticated personnel  protec-
tion  equipment.
  The average duration of
responses has  increased from
45 days  in 1978 to  nine days.
Some responses have  entailed in-
termittent actions over several
months At its  present rate of
response, the ERT will be on-site
at more than 60 incidents during
fiscal 1982.
  Overall, preventable incidents
such as housekeeping-type oil
spills, which formerly  comprised
90 percent of all reported hazar-
dous substance episodes, have
decreased steadily in recent
years. Credit for this welcome
trend is due to a  growing sense
of responsibility by  industry,  to
rapidly advancing waste disposal
technology,  and  to  the Spill
Prevention Control and Counter-
measure Program provided by
the Clean Water Act.
   How the ERT
   is Activated

   The ERT is available  24
   hours a day. Once an EPA
   On-Scene Coordinator
   determines that ERT
   assistance is  required, he
   may telephone these
   •  During working hours:
   Kenneth Biglane, Director
   of the Hazardous
   Response Support Division
   (FTS 245-3048).
   •  During nonworking
   hours: Steve  Dorrler. the
   ERT leader (or his
   designee) at the 24-hour
   response telephone (201-
   321-6660) or FTS (340-
   The authority to activate
   the  ERT rests with the
   Director of Hazardous
   Response Support Division
   or his designee. Upon ac-
   tivation, appropriate  ERT
   personnel and resources
   are  dispatched to operate
   under the direct
   operational control of an
   On-Scene Coordinator.
                                                                             EPA JOURNAL

                                       On-Scene  Cleanup
                                       When Federal assistance is requested under
                                       Superfund, an on-scene coordinator is ap-
                                       pointed by the lead Federal cleanup agency
                                       to guide and monitor all protective and
                                       precautionary measures. The overriding mis-
                                       sion of the coordinator  is to see that every
                                       possible measure is taken to protect human
                                       health and the environment. Each year EPA
                                       answers hundreds of  calls for emergency
                                       assistance and cleanup expertise at spills and
                                       hazardous waste sites. The Agency's on-
scene coordinators are drawn from more
than  100 emergency response specialists
located in EPA's 10 regional offices After
reaching a removal site, these highly trained
on-scene coordinators assess the problem
and then make a decision to assist or monitor
industry and local officials in the cleanup or
to  seek assistance from the  EPA Regional
Emergency Response offices and the special
Environmental Response Teams based  in
Cincinnati. Ohio,  and Edison, N.J.
Official takes soil samples to determine
extent of contamination.
Officials wearing self-contained breathing ap
paratus and special protective "moon suit"
clothing investigate contamination at site.
Work at hazardous sites sometimes continues
through the night when safety  hazards are
                                    i . CMW

The   California
Enforcement  Program
By George  Deukmejian
Attorney General, State of California
Californians can certainly take pride  in their
State's hazardous waste program. It is one of
the largest and most active State programs in
the country.  Based on State laws modeled
after the Federal Resource Conservation and
Recovery Act (RCRA). the Department of
Health Services has established a regulatory
program which should markedly  improve
hazardous waste management practices  in
California and effectively protect public
health and the environment from the risks of
improperly managed waste.
   As Attorney General of the State. I am
responsible for the legal  enforcement of
California's hazardous waste laws and
regulatory program: I  would like to take this
opportunity to cite the progress in enforce-
ment which is guaranteeing compliance with
the regulatory program and securing the
cleanup of California's interim priority Super-
fund  sites.
   In October 1981, the  Department of
Health Services created a new Toxic Sub-
stances Control  Division. Its function is to
provide recognition and dedicate sufficient
resources  for development of a  comprehen-
sive  State program to regulate the handling,
processing, resource recovery, and disposal
of the  growing quantities of hazardous
wastes and other toxic materials being
produced  in  California. Within this division
the Hazardous Waste Management  Branch
consists of 146 authorized positions with a
budget of more than $7 million—making it
one  of the largest State waste management
efforts in the nation.
   The State's hazardous waste management
program  has received Phase  I interim
authorization under RCRA. This allows the
State to  undertake full enforcement of the
program's regulatory  provisions.  In carrying
out its enforcement  responsibilities, the
Department  of Health Services  (DHS) per-
forms compliance inspections and issues ad-
ministrative orders for failure to comply with
State regulations. So far  in fiscal year 1982.
DHS has inspected 226  of the  State's 840
treatment, storage, and disposal facilities,
and  139  of the State's 6,506 generators. As
a result of these inspections, DHS has issued
119 compliance orders for violations of
regulatory requirements.  All indications are
that  the  violations cited  are being ex-
peditiously remedied. For example,  in
followup on  those in the Berkeley office it
was found that 30 of the 36 violations noted
have already been resolved.
  Where DHS enforcement actions do not
result in compliance, however, legal enforce-
ment action  may have to be taken. DHS
refers such cases to my office and to the Dis-
trict Attorneys for prosecution. As an indica-
tion of our aggressive enforcement policy,
between March 1979 and May 1982 we
filed  some 20  hazardous waste cases in
State court. Several of these  cases, such as
the litigation involving the Occidental
Chemical Co. in Lathrop, Calif., have received
national attention and should have far-
reaching results.
  The  Occidental case  involved soil and
groundwater contamination  resulting from
the 'improper disposal of inorganic, organic
and radiological chemicals. A  consent decree
was  filed in February 1981. After the  com-
pany completed contamination surveys and
feasibility studies, a remedial action plan was
approved in January 1 982. The remedial plan
includes use of extraction wells to draw the
contaminated groundwater out, treatment of
the water to prescribed performance levels
by granular activated  carbon,  and the subse-
quent injection of the effluent into a lower.
isolated aquifer that is not suitable for drink-
ing water.
   Another example of  enforcement is the
case involving  the Capri Pumping Service, a
company which recycles electroplating
hazardous waste and precious metals. The
company had maintained deteriorating tanks
and  containers which resulted in  soil  con-
tamination and off-site  migration  of hazar-
dous materials. Both the State and EPA have
taken enforcement actions. The State ob-
tained  a preliminary injunction against Capri
in July 1 980, and instituted State Superfund
cleanup activities at  the site in November
 1981.  Capri was found in contempt of the
State injunction not to operate in  December
 1981.  The company will submit its plans for
cleanup of the site to EPA and the State for

California has also actively pursued enforce-
ment actions under the  Federal Comprehen-
sive  Environmental Response, Compensa-
tion, and Liability Act of 1980 (Superfund).
There is a similar State Superfund statute as
well. Three California sites were included on
the Superfund interim priority sites list
published in October  1981. These actions

• California began legal action in 1979
against Aerojet General in  Rancho Cordova
for improper disposal of industrial waste sol-
vents and chemicals which resulted in
groundwater contamination. The State filed a
Cease and Desist Order in December 1979.
Aerojet began an approved groundwater
treatment plan in February  1982.  The State
is currently  monitoring compliance with the
Order and reviewing the company's
groundwater monitoring data.

• At the Iron Mountain Mines site in
Keswick. acid leachate from open pits con-
taining heavy metal mining wastes have
resulted in river and lake contamination. The
State has instituted several  enforcement ac-
tions for violations of water pollution control
permits  (NPDES).

• The Stringfellow Acid Pits in Riverside
County contain 32 million gallons of acid and
DDT wastes which are contaminating a
groundwater basin used for irrigation and in-
dustrial  purposes and the Santa Ana River.
An interim abatement program was ordered
in December  1980 to provide protection
from leaching or washout of the  waste
material. The State has assumed  ownership
of the site and has completed  on-site con-
tainment measures. A long-term cleanup
plan  is being developed by the State. In July
EPA  announced the award of $6.1 million of
Superfund money to the Department of
Health Services for cleanup work at the site.

  As the cases mentioned above indicate,
California is fully assuming its enforcement
responsibilities under the RCRA and Super-
fund  programs. But the State also relies on a
high  degree of cooperation from industry  in
tackling  these problems. Active State enfor-
cement and industry cooperation so far have
permitted California to take one of the
leading roles in the nation  in hazardous
waste regulation and cleanup. We  have char-
ted the right course, and we look forward to
continued cooperation with EPA in the enfor-
cement  of both State and Federal require-
ments intended to upgrade waste manage-
ment practices and effect the cleanup of sites
which pose  a hazard to public health and the
environment. Q

These are the ruins left alter a 7 981 fire and explosion at the Chemical Control Corp. waste
disposal site in Elizabeth, N.  J., shown in the inside front cover photo before the lire.
                                             Back Cover: Workmen assemble new EPA
                                             mobile incinerator for a demonstration
                                             behind EPA  Headquarters in Washington.


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