United States
Environmental Protection
Agency
Office of
Public Affairs (A-107)
Washington DC 20460
Volume 8
Number 4
July-August
-------
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
action."
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
environment."
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United States
Environmental Protection
Agency
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
Articles
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
materials
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
Oo
r*
-
EPA JOURNAL
Subscriptions
Regulating Hazardous
Wastes 2
An interview with Rita M.
Lavelle
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
State
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
23
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
explained
Emergency Responses by
Industry and Government 28
Industry:
The Leaking Tank Car on
TC-4 28
CHEMTREC 29
Government:
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
laws
The annual rate for subscribers in the
US for the bi-monthly EPA Journal is
S9 50 The charge to subscribers in
foreign countries is $1 1.90 a year The
price of a single copy of the Journal is
$2.75 in this country and S3,45 if sent to
a foreign country Prices include mailing
costs. Subscriptions to EPA Journal, as
well as to other Federal Government
magazines, are handled only by the U.S.
Government Printing Office Anyone
wishing to subscribe to the Journal
should fill in the form at right and enclose
a check or money order payable to the
Superintendent of Documents The re-
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Regulating
Hazardous
Wastes
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
stringent.
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
sector?
/\ 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
manner.
Q Has EPA been slow to
move on cleanups, past or
present?
/\ 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
remarkable.
JULY/AUGUST 1982
-------
"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
pride.
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.
EPAJOURNAL
-------
Q How do you plan to deal
with citizens' complaints about
dumps and hazardous waste
spills?
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
program.
Q. To get away from hazar-
dous waste for a moment,
what is EPA doing in the area
of solid or non-hazardous
waste?
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
increase.
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
JULY/AUGUST 1982
-------
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
gear.
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.
How
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-
vironment.
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
sites.
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
Report
Superfund has a Congressionally-mandated
life span of five years, and it's already one
and one-half years old. What has it accom-
plished?
Superfund Accomplishments:
Some Vital Statistics
• $26 million allocated for 81 removal
actions.
• 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
cleanup.
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
cleanup.
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-
mediately.
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
Calendar
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
cleanups.
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
JULY/AUGUST 1982
-------
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
proceed
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
program
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
problem
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
EPAJOURNAL
-------
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
-------
Superfund
Helps
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
solution.
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
ph.
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.
10
-------
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
-------
The
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
Lakes.
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-
power.
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
EPAJOURNAL
-------
•-€.-
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
JULY/AUGUST 1982
13
-------
States Active
in
Hazardous
Waste
Control
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
programs.
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
authorization.
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.
Where
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.
14
EPAJOURNAL
-------
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.
New
Federalism
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
quality.
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
JULY/AUGUST 1982
-------
A Burning
Answer
to a Difficult
Question
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.
16
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
process.
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
resources.
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
work:
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
(POHCs)"
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
conditions.
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
incinerability.
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
EPAJOURNAL
-------
European
Waste
Management
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-
plained.
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
countries."
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
heating
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
JULY/AUGUST 1982
17
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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
problem.
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
well
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
items
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-
sideration.
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
Waste
Exchange
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
JULY/AUGUST 1982
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
19
-------
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-
ted
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.
20
EPAJOURNAL
-------
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."
More
Information
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
JULY/AUGUST 1982
21
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Land Disposal
Regulations
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
waste.
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
EPAJOURNAL
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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
departments.
• 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.
JULY/AUGUST 1982
23
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Simplifying
Transport of
Hazardous
Wastes
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.
Multiplying
Manifests
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
manifests.
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.
Rolierskating
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
24
EPAJOURNAL
-------
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-
tions.
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
Act.
Question
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
operators
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
JULY/AUGUST 1982
26
-------
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-
tion."
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-
tions.
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-
munity.
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
year.
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
together.
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
OWPE.
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?
26
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-
tions.
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
Cooperation,
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
releases,
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."
D
JULY/AUGUST 1982
27
-------
Emergency Responses by Industry and Government
(The
^^F
3 roles of industry and government in controlling hazardous material emergencies are described in the following articles
Industry
"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
Division
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
yard
At 3:30 p.m. the owner of the
car had been contacted His
quality assurance supervisor was
unsuccessful in controlling the
leak.
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
emissions
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.
28
EPAJOURNAL
-------
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
NOT LOAD UNTIL REPLACED"
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
team.
CHEMTREC
By John C. Zercher
Director,
Chemical Transportation
Emergency Center
WASHINGTON—One morning
recently, newspaper readers
were greeted with headlines
about three major transportation
incidents involving hazardous
materials.
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
material.
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
phosphorus.
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
employee.
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.
JULY/AUGUST 1982
29
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Government
The
Environmental
Response
Team
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
Response
Origin
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
substances.
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
substances.
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
procedures.
Functions
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
materials
The Changing Nature of
Response
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
officials:
• 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-
6660).
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.
30
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
found.
r^
H
r
i . CMW
JULY/AUGUST 1982
-------
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
review.
Superfund
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
followed:
• 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
32
EPAJOURNAL
-------
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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