The Challenge
        of Hazardous Waste

The  Challenge
of  Hazardous
   Disposal of hazardous
   waste in this country will
never be the same again.  This
issue of the EPA Journal
explores EPA's role in the
dramatic: changes that are
taking place.
  Leading off the issue is an
article by ]. Winston Porter,
the Agency's Assistant
Administrator for Solid
Waste and Emergency
Response. He looks at the
far-reaching implications of
the amendments to the
Resource; Conservation and
Recovery Act (RCRA) enacted
by Congress in 1984.  Then,
Marcia Williams, Director of
EPA's Office of Solid Waste,
explains how the Agency is
carrying out its sweeping
responsibilities under the
1984 amendments.
  Another feature considers
how EPA wil] handle one of
the biggest jobs under KCRA:
ending the disposal of
untreated waste on the land.
An article reports on  how
industry is responding as the
new RCRA is implemented.
The availability of treatment
alternatives to ease the waste
disposal crunch  is described,
and another article reports on
EPA research under way to
help the country make the
long-range adjustment to a
different way of  handling
hazardous waste.
  EPA's outreach efforts  to
alert and inform  the
thousands of small
businessmen now affected by
RCRA are discussed.  Another
article explains how EPA is
approaching the  job of
enforcing the rules under the
new hazardous waste control
law. An  observer outside; of
EPA comments on the job the
Agency has been given by
Congress and the new
directions the law is
  The challenge  of regulating
underground storage
tanks—another major
responsibility given to EPA
by the new RCRA—is
featured. Another article
describes the busy clays of
the members of EPA's task
force on hazardous waste and
ground water.
  The magazine concludes
with two regular
features—Update and
Appointments,  u
                                              Commercial chemical waste incinerator
                                              in Chicago. Incineration is one
                                              treatment alternative to Jand disposal of
                                              hazardous waste.

                               United States
                               Environmental Protection
                               Office of
                               Public Affairs (A-107)
                               Washington DC 20460
                               Volume 12
                               Number 3
                               April 1986
                           x>EPA JOURNAL
                               Lee M. Thomas, Administrator
                               Jennifer Joy Manson, Assistant Administrator for External Affairs
                               Linda Wilson Reed, Director. Office of Public Affairs

                               John Heritage, Editor
                               Susan Tejada, Associate Editor
                               Jack Lewis, Assistant Editor
                               Margherita Pryor, Contributing Editor
EPA is charged by Congress to pro-
tect the nation's land, air, and
water systems. Under a mandate of
national environmental laws, the
agency strives to formulate and im-
plement actions which lead to a
compatible balance between hu-
man activities and the ability of
natural systems to support and
nurture life.
  The EPA journal is published by
the U.S. Environmental Protection
Agency. The Administrator of EPA
has determined that the publica-
tion of this periodical is necessary
in the transaction of the 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. Views
expressed  by authors do not neces-
sarily reflect EPA policy. Contribu-
tions and inquiries should be ad-
dressed to the Editor (A-107),
Waterside Mall, 401 M St., S.W.,
Washington, DC 20460. No per-
mission necessary to reproduce
contents except copyrighted photos
and other  materials.
A Sweeping New Law
Brings Dramatic Change
by J. Winston Porter   2

Making the New RCRA
An Interview with
Marcia Williams   3

Banning Untreated Waste
from the Land
by Eileen Claussen   6

Industrial Responses
to RCRA's Rules
by Robert ). Griffin, Jr.   8
Can Pollution
Be Destroyed?
by John P. Lehman
Research to Break
the Land Disposal Habit
by John H. Skinner   12

Spreading the Word
About the Job Under RCRA
by Edgar Berkey
and Karen V. Brown   15
Tackling Pollution from
Underground Storage Tanks
by June Taylor  20

EPA's Task Force
on Hazardous Waste
in Ground Water
by Antoinette Ferrara   22

Update  24

Appointments   24
Making RCRA Stick
by Jacqueline Tenusak
                               RCRA's Challenge:
                               A View from the Outside
                               by Richard Fortuna   18

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A  Sweeping  New  Law
Brings  Dramatic  Change
 by J. Winston Porter
   There can be no question that
   hazardous waste management is a
major environmental issue of this
decade. It's been said, and 1 believe it's
true, that some element of the programs
we manage touches the lives of all
Americans each and every day. As
difficult as it may be to believe, it's only
been about ten years since the federal
government  began to understand the
scope and complexity of the hazardous
waste problem. Since that time,
Congress has enacted environmental
legislation to deal \vith this problem
and the Environmental Protection
Agency has developed  a regulatory
mechanism to meet the statutory
mandates. We have the tools to get the
job done.
  The Hazardous and Solid Waste
Amendments, enacted in late 1984,
reflect a radical change in the regulation
and management of hazardous and solid
wastes under the Resource Conservation
and Recovery Act (RCRA). We must
move away from land disposal of
hazardous wastes. We must issue
permits for some facilities and close
others. We must delegate the program
effectively and efficiently to the states.
Existing "loopholes" in the program
must be closed, and  past
mismanagement of hazardous wastes
addressed. The amount of waste
generated  must be minimized. And
finally, new and far-reaching
requirements are now governing a  vastly
larger and more complex regulated
  Let me offer a few facts to
demonstrate the dramatic change
brought about by the "new RCRA."
  The old program cost the regulated
community roughly $1  to $3 billion
when fully implemented. The new
RCRA will cost an estimated $20 billion
per year by the 1990s, putting the  cost
of hazardous waste management at a
level comparable to the air and water
regulatory programs.
  There are 72 deadlines in the
Hazardous and Solid Waste
Amendments, 58 requiring action

(PorhT is KJ'/Vs Assistant Administrator
for Solid VViistr mxl  h'rii(T,»(.')icv
within only two and one-half years of
enactment. The challenge is formidable.
Many requirements are imposed by
statute whether or not EPA issues
guidance or regulations, including
requirements which go into effect
automatically if EPA fails to act by a
specified date. These "hammer"
provisions are typically more draconian
than the Agency's normal requirements
as an incentive for the  regulated
community and others  to cooperate with
the Agency to expedite the development
and issuance of regulations.
  Finally, the "new RCRA" greatly
expands the regulated community,
adding over 100,000 small generators
of hazardous waste. These generators,
which produce between 100 and 1,000
kilograms of hazardous waste per
month, were previously exempt from
federal regulation. The  amendments also
cover more than a million underground
storage tanks and a few thousand
additional facilities burning waste as
fuel. Compared to our pre-amendment
regulated universe of 35,000, it is not
difficult to see the enormity of the task
ahead of us.
  What are the implications of the "new
RCRA" for the future of hazardous
waste management?
  The increase in the cost of waste
management will induce firms to
modify their production processes to
make waste less toxic, reduce the total
amount of waste residuals, and
recycle wastes.
  Waste treatment will become more
popular, requiring siting of new
facilities, training of new personnel, and
greater public acceptance. Conversely.
many wastes will be banned from direct
land disposal.
  More than 1.000 land disposal
facilities will close; about 500 others
must ensure that wastes are being
responsibly managed in order to obtain
permits necessary to continue operating.
  The corrective action program will
present unique problems. We will need
a cadre of experts who can address
many policy issues, including "How
clean is clean?" and the establishment
of priorities.
  Finally, we will  continue to focus on
effective communication  with the newly
regulated community, simplifying where
possible and consciously striving to
avoid what  I call "guidance overload."
Generators and operators will  require
training, assistance, and incentives to
comply. Together with state and local
governments and representative
associations, we will look for innovative
approaches  to meet our objectives.
  The Agency is already moving rapidly
and responsibly to implement the new
amendments. We're setting out to "get
the job done." We're writing regulations
and guidance, identifying the permitting
universe, writing permits, and reviewing
closure plans. We're working to more
effectively involve interested  parties in
the decision-making process to assure
reasonable,  achievable, and enforceable
  The "new RCRA" is an exciting
challenge, requiring full commitment. I
will look forward to working with the
states, others in EPA, Congress, and the
public  in meeting this challenge. Q

"Sonic element of thr;  programs ive
manage touches (lie lives of (ill
Americans each and every day."
/. Winston Porler

                                                                                                    EPA JOURNAL

Making  the
New  RCRA  Work
An Interview with
Marcia Williams
The Office of Solid Uu.stc in KPA is
responsible/or implementing [lie
Hosource Conservation (ind  Recovery
Act (RCRAJ.  For this special issue
focusing on RCHA, the Journal
intervieivecf Marcia Williams,
Director of the Office.
     You became Director of the Office
of Solid Waste a few months ago as
part of an Agencywide rotation of
senior executives. How has the
experience been for you?

-ii-  Excellent.  I've worked in various
parts of the agency for 15 years, and 1
bring the experience of those years to
the  hazardous waste program. This kind
of exchange facilitates cross-media and
cross-program considerations, which I
think is one of the things that Lee
Thomas hoped it would do.
  For example, the Toxic Substances
Control Act (TSCA), which I helped
administer in my previous role, is an
extremely powerful tool for gathering
information. The solid waste  program,
however, doesn't have the same ability
to collect information. So I've structured
a joint project where toxicological and
environmental fate data collected or
generated by manufacturers under TSCA
can be used in writing regulations for
the  Resource Conservation and Recovery
Act (RCRA).
     What do you hope to achieve in
your new position?

*»  I have four goals. One is to
implement what is obviously a very
challenging statute and to be responsive
to the Congress in doing so.
  My second goal is to make RCRA a
more implementable statute. RCRA is
very complex. People may have a hard
time understanding it, and they can't
very well comply with  something that
they don't understand.  Making RCRA
easier to implement will, I believe, lead
to improved environmental protection.
  The third goal I have is to take a
proactive look to the future, and explore
how one might structure a hazardous
waste management program ten years
from now. This could help us develop a
more implementable solid waste
                                                                             My final goal is to prioritize our
                                                                           workload to get the most bang for the
                                                                           buck. In this program, there is so much
                                                                           to do that we've got to prioritize. I'm
                                                                           hoping to bring a more risk-based
                                                                           approach to the program, so that we
                                                                           spend our time on things that
                                                                           maximally reduce environmental risks.
      How would you describe the
significance of the 1984 RCRA

**   They are extremely significant,
because they set a precedent in reducing
flexibility and increasing specificity for
the Agency. One can speculate on
whether that's good or bad, but there's
no question that it's precedent-setting.
  Furthermore, the 1984 amendments
mandate activity in a number of areas
that had not received high attention in
the past: small  quantity generators, for
example, and leaking underground
storage tanks.
  One of the most significant aspects of
the statute is that it really makes it
crystal clear that Congress wants the
Agency to  move away from land
disposal to other forms of disposal. The
statute pushes us in that direction
  The last  point of significance regards
ground water. Some people might call
the 1984 RCRA amendments the Cround
Water Protection Act. The statute puts
down in black and white a whole series
of steps to  require stronger ground-water

v<   Many people both in and out  of
EPA have criticized the 1984
amendments for imposing "hammer
clause" deadlines. Are these
unreasonable? Are they impossible?

*»   Congress  set something on the
order  of  72 deadlines over the  next few
years for the Agency. The question is
how do you prioritize properly, so that
the  deadlines you make sure you meet
APRIL 1986

are the ones that are, in fact, the most
  The down side of deadlines is that
they make it very difficult to respond to
legitimate changes in priorities that
occur after the statute and the deadlines
have been put in place.

V£  What will you do if you don't
meet some of the deadlines?

/\   Again, my goal is  to make sure
that I prioriti/.e deadlines so I meet the
ones that have the most important
environmental consequences.
      Is America going to have to stop
disposing of waste on land?

/\   America is going to have to stop
disposing of most untreated waste on
land. We may, however, find that we
can treat waste first and render it
essentially  nonhazardous, after which
time land disposal would he
      How do you answer the criticism
that KPA's proposed regulations for
land disposal of hazardous waste are

 /\   We helieve the proposed rule on
land disposal is a landmark move
forward in the handling of hazardous
waste. We think  the proposal  will
ensure that no waste will go to the land
unless public health and the
environment are fully protected.
  We're; soliciting comments on the
proposal.  So far we've had three public
hearings. Based on the comments we've
received to date, there are a high
number of positive responses  to our
general approach for dealing with this
extremely complicated problem. We  are
continuing to meet with Congress  and
environmental groups to fully explore
tin: concerns they have raised.
   _   Recently, an environmental
research group, INFORM, said that
industry is not doing a good job of
reducing the hazardous waste it
generates. Do you think that industry
should be doing better?

/V   I'm not sure I'm in a good
position to answer that yet. We're
preparing a report to Congress, due in
October,  on waste minimization. The
report will include recommendations on
appropriate strategies to reduce waste.  I
don't want to speculate now on whether
I think industry is or is not doing
enough until I take a look at the report's
conclusions and recommendations.
      Will there come a time when
most waste will be recycled, or when
waste will no longer be produced at

/\   That would certainly be an ideal
situation. I think we can get a lot closer
to that situation than we are today, but I
suspect we will never reach that ideal of
zero waste or 100 percent recycling.
  In the past, there was no  economic
incentive to reduce the production of
waste. Dumping brought no
repercussions. But as handling waste
becomes more and more expensive,
people will put more effort into
avoiding waste production  in the first
place, and into recycling waste.
      In view of the fact that Superfund
wastes may themselves be
contaminating ground water near
central disposal sites, doesn't
hazardous  waste control sometimes
seem a thankless task?

 JL\   We don't want to put ourselves
into a situation where we're solving a
Superfund problem but creating a RCRA
problem. That's why  the Agency has
developed a strong policy in terms of
where Superfund waste is allowed to
go. Essentially, Superfund waste cannot
go to a RCRA facility unless that
facility, or a unit of the facility, is in
complete compliance with all RCRA
      Are you optimistic that the states
can do a good job of implementing

-TV   The success of RCRA depends on
our working out a strong federal-state
partnership for the program. I believe
we're headed on that track.
      What is EPA doing to address the
problem of household hazardous waste?

/i.   That's an interesting question
because, for the first time, the issue of
managing hazardous waste has the
potential to affect every family in this
country. Presently, we are addressing
this issue as part of our Subtitle D
(municipal landfill) report to Congress.
We are encouraged by the fact that
many communities are holding Amnesty
Days, when individuals bring their
household waste to collection points.
Managing household hazardous waste is
an educational issue that deserves
further attention.

Q  What's the Office of Solid Waste
doing to improve disposal of hazardous
waste at federal facilities across the

/x   When RCRA was reauthorized,
Congress wanted to make sure that
federal facilities were fully covered by
the new amendments. The law specifies
frequent inspection requirements for
federal facilities, and required federal
facilities to submit an inventory to EPA
of all their various units by January 31,
                                                                                                          EPA JOURNAL

                                                                     George Butler luisfies up at a well on
                                                                     his Maryland farm, RCH/A amendments
                                                                     require strong ground-water
1986, and every couple of years after
that. One of our important priorities is
to provide enough technical assistance
to the members of the federal family to
enable them to fully comply with these
and other provisions  of RCRA.
      You appointed seven task forces
to map hazardous waste goals. Have
you gotten any feedback yet that we
can discuss?

I\   I have gotten draft reports from a
number of the task forces, and I'm
consolidating them into an overall
strategy for the RCRA program. There
will be two strategies, actually: a
short-term strategy, for the next two to
four years, and a long-term strategy, for
the next five to ten years.
   We completed a working version of
the strategy in March. My intent is to
use that draft as a catalyst for discussion
about what is really important and key
in the implementation of RCRA.
      We've had laws on the books for
years about solid waste. Why haven't
we solved the problem up to now?

/\   It may sound like a flip answer,
but this problem wasn't created
overnight, and it's not going to be
solved overnight either. Over time,
we've come to realize that the problem
is more complex and more difficult than
anyone originally thought. I don't think
we had any concept of just how serious
some of our past problems were until
investigations under Superfund began.
  And the problem has become even
bigger. For example, under the 1984
amendments, RCRA not only addresses
future generated waste, but also requires
a cleanup of past waste mismanagment
in  every facility that currently manages
hazardous waste.
                                                                                 Having said all this. I  must say that
                                                                               we have also made progress. In fact, one
                                                                               of the things I'm doing right now is
                                                                               looking for better ways to explain to the
                                                                               public what that progress has been.
                                                                               While we still have a long way to go. we
                                                                               need to articulate the significant
                                                                               progress we have made in  certain areas.
      Are people overreacting to
hazardous waste problems?

/x   I would answer the question in
this way. I think EPA has a real
challenge and obligation to let the
public know about real risks and real
choices in dealing with hazardous
  In the past, we have not always been
successful in communicating this
information to the public. As a result,
there have certainly been instances of
overreaction.  The only way we can
overcome this is through a better job of
      What's the state of our knowledge
about solving waste disposal problems?
In its infancy? Maturing?

/y   Over the last ten years, we've
learned a tremendous amount about  the
nature of the waste constituents we're
dealing with — how they  move through
various pathways, how their toxicity
can be reduced.
  But at the same time, there are
tremendous gaps in the information we
have. For example, what happens when
you mix different wastes together? Is the
toxicity of the resulting mixture worse
than the toxicity of the individual waste
streams? How effective are the new
technologies in treating waste? Can we
develop reliable procedures for
determining the health effects from
exposure to hazardous waste?
  So the answer to your  question is that
we know a lot more about hazardous
waste than we used to, but we still have
a lot to learn, n
APRIL 1986

Banning  Untreated  Waste
from  the  Land
 by Eileen Claussen
                                       Approximately .'i3 billion i>
incinerator ash will be allowed in the
land. In some cases, the ash may still be
high in contaminants (probably metals
that are not destroyed by the burning),
and it may have  to be stabilized prior to
placement  in or on land. For wastes
with high metal content, the best
available technology may be
stabilization. In these cases, only
treated, stabilized wastes will  be
allowed in or on the land. Other  forms
of treatment that may be acceptable
include wastewater treatment, carbon
absorption, steam stripping, and
  In addition to the 33 billion gallons of
waste now going to landfills and
impoundments, another 37 billion
gallons of hazardous waste are injected
into deep wells. These wastes will also
be subject to ban decisions, although the
statutory time frame for  underground
injection is October 1988 for dioxin
wastes, solvent wastes, and the
 "California list." The EPA Office of
 Drinking Water has responsibility for
 this portion of the land disposal
 restrictions program.
 The land-disposal restrictions
 program will result in
 landmark shifts in the  way
 hazardous waste is managed.
  For the waste now placed in landfills,
surface impoundments, land treatment
facilities, and waste piles, the Agency
estimates that the cost of restricting land
disposal and requiring treatment is $1.3
billion per year. Other costly
improvements to land disposal
mandated by the Hazardous and Solid
Waste Amendments include location
standards; requirements for the use of
double liners  in landfills and surface
impoundments; and restrictions on all
liquids, hazardous and non-hazardous
 as well. As contemplated by the statute,
 these controls will be in place to safely
 handle the treatment residues that will
 continue to be land disposed even after
 the new RCRA program is fully
.effective. Once all these changes are
 made in the way we manage hazardous
 waste, we may finally be able to say that
 land disposal is  acceptable (even if only
 for the residuals of treatment
 technologies) and the circle—which
 began by removing toxicants from
 air and water, only to redeposit them on
 the land—may finally be closed
 satisfactorily, a
APRIL 1986

Industrial  Responses
to  RCRA's  Rules
 by Robert J. Griffin, Jr.
  In the public mind, protection of the
   environment from hazardous waste is
perceived as a job for EPA. And indeed,
EPA does have the statutory
responsibility for ensuring that
requirements of the Resource
Conservation and Recovery Act (RCRA)
are met. But, in truth, preventing future
environmental  damage from hazardous
waste must also be considered a job for
   Since August 5, 1985, amendments to
RCRA have greatly enlarged the scope of
industry's participation in the program,
to include not only large-scale
generators of hazardous waste, but also
firms that generate smaller amounts of
hazardous waste—quantities of 220
pounds or more per month.
   How well is industry able to meet its
responsibilities under RCRA? What are
its successes? What problems remain?
The answers to these questions are
important for EPA, for industry, and for
every American who has a  stake in
seeing that RCRA achieves its goal of a
cleaner, healthier environment.
   At the time the RCRA amendments
were passed, concern was voiced by
some that small-scale hazardous waste
generators would have relatively greater
difficulty meeting requirements of the
Act than would large-scale waste
generators. This concern was based
upon the fact that larger firms, almost
by definition, have a greater capacity to
handle administrative requirements  of
the Act, and often have greater in-house
technical capabilities as well.
   Although there is some truth to this
point of view, experience to date has
shown that many small-waste generators
are able to meet their RCRA
responsibilities without undue handicap
related to size of operation. In fact, the
Fundamental issues to be dealt with, if
RCRA is to be successful, apply to
 ((.'rijfin is (i Washington-based science'
industries that generate hazardous waste
on a large scale and to smaller waste
generators alike. It is also apparent that
certain industries are finding it
somewhat more difficult to comply with
RCRA than others, regardless of the size
of their waste stream.
  Most industry experts agree that
several factors, often interrelated, have
an important bearing on the cost and
relative ease of disposal of hazardous
waste from a given firm. Virginia Bliss,
Associate Washington Representative of
Certain industries are finding
it somewhat more difficult to
comply with RCRA than
others,  regardless of the size
of their waste stream.
the Automotive Service Industry
Association, representing service station
wholesalers and distributors throughout
the United States, cites transportation
cost as an especially important factor.
"Obviously," Bliss notes, "the nearer a
waste-generating  firm is to an acceptable
disposal site, the  more favorable the
transportation economics are likely to
be." Similarly,  with larger quantities of
waste to be removed, it is usually easier
to achieve economies of scale, thus
lowering the cost per unit of waste  that
must be hauled.
  The character of the waste stream
itself can be of critical importance in
determining the economics of disposal.
For example, the  cost to dispose of
waste materials with potential for
reclamation or  recycling may be offset
to some extent  by the proceeds from
sale or use of the reclaimed product. By
the same token, the nature of the
processing required for a particular
waste prior to disposal—whether by
incineration, chemical treatment, or
other means—can also be an important
cost factor.
  Wastes that are non-homogeneous or
mixed—and, indeed, those whose exact
chemical composition is
unknown—pose special difficulties.
Bliss notes that such diversity in the
waste stream—and uncertainty as to its
content—is characteristic of many small
hazardous waste generators, including
service stations.
  "There is no way for a service station
manager to know the chemical content
of all materials used in his business,"
she explains. "In addition, many
customers rely on service stations to
take used oil off their hands—and
there's  no way of knowing whether used
crankcase oil has been mixed with
poisons, household chemicals, or other
hard-to-get-rid-of materials."  Open
dumpsters at many small business
locations similarly invite homeowners
to discard hazardous wastes that  they
would  hesitate to place in household
  According to Dr. Geraldine Cox, Vice
President and Technical Director for the
Chemical Manufacturers Association, a
major problem facing all hazardous
waste generators is the virtual
impossibility of getting liability
insurance. "Insurance companies feel
that they cannot really estimate the risk
involved in handling and disposing of
hazardous waste," she says. A possible
solution to this problem, Cox suggests,
is establishment of a legal maximum
award,  or financial liability, in cases
arising  from the generation or disposal
of hazardous waste.
  Despite these difficulties, American
industry is forging ahead, searching for
ways to meet its responsibilities under
RCRA.  Dr. Cox indicates that most
member firms of the Chemical
Manufacturers Association maintain
their own in-house disposal capability.
Although such firms certainly possess
the necessary technical expertise and
                                                                                                      EPA JOURNAL

              Solid ivcisfr m(.m(i,Uf'm<>Jit is uur
              oli/fst environmental proMcm.
              This ivoodcuf depicts n Ixisir scim'fution
              method  in thr  Middle A»es; dumpim;
              the  garbage mil the window.
to handle, and so many possible
treatment technologies, that no single
technology stands out.  But it is possible
to make some generalizations.
  Treatment can only do  three things to
a waste: destroy it, immobilize it, or
prepare it for destruction or
immobilization through chemical or
physical changes. (See  related article on
hazardous waste research on page 12.)
  If a waste cannot be eliminated or
recycled, destruction is clearly the next
preferred option. Destruction implies
alteration to make a waste
nonhazardous under RCRA's
definitions, most often  by reducing its
toxicity. Thermal treatment, such as
incineration in a properly operated
rotary kiln, is probably the most
versatile and  reliable way to destroy
many organic wastes.
  Biological destruction is another
approach. It relies on microorganisms to
break down hazardous  materials into
simpler, nonhazardous compounds.
Another solution is to change those
properties that make the waste
hazardous.  While it may still need
disposal, at least the waste is no longer
hazardous.  Indestructible wastes such as
metals can be treated by
immobilization—a process that uses
physical and chemical  means  to bind
APRIL 1986
such materials into solid blocks.
Properly handled and disposed of, they
can remain stable and isolated for a  long

Putting the Options Together

In most cases, the key to successful
waste treatment is to put the right
processes together in treatment trains.
Combinations of processes are often
essential both to prepare wastes
properly for an end process and to
compensate for the inefficiencies of  the
end processes.
  Even the most efficient treatments
produce their own residuals.
Incineration requirements for RCRA
wastes are very demanding, but even so,
one-hundredth of one percent of the
waste will typically escape.
Immobilization can lower the leaching
of metals  by factors of 100 to  100,000,
but a measurable amount is still lost
over time.
  We  have to decide which options
produce the best environmental result.
Given a particular waste and the
available treatments, where is the
preferred place for it or its byproducts?
We try to  answer this question when we
identify the treatments that qualify as
"best demonstrated available
technology" (BDAT) for each class of
waste.  BDAT is used as the basis for
setting performance goals for waste
                                                                                 The most difficult part of defining
                                                                               BDAT is designing formal criteria for
                                                                               determining what we mean by "best."
                                                                               An ideal treatment process would
                                                                               produce no residues at all and pose zero
                                                                               risk to health and environment. We
                                                                               know realistically that such perfection
                                                                               is impossible. Moreover, until better
                                                                               waste treatment processes are
                                                                               demonstrated and become commercially
                                                                               available, the ones we already have may
                                                                               fall short of what we would like to
                                                                               achieve, which is a  level of risk from
                                                                               hazardous waste management that we
                                                                               can safely consider negligible. Defining
Experience has taught that
there is no such place as
"away," especially for
hazardous wastes.
the "best" treatments from among the
available options entails determining
whether they must produce negligible
levels of risk, or at least significantly
reduce the risks we already incur from
disposing  of waste on land. At the very
least, we want to avoid making matters
worse than they are now.
  As new  technologies are developed,
they can be incorporated into this
approach to designating best
demonstrated available treatment
without disrupting its underlying
structure and logic. We believe that the
regulations provide the final link that
will allow us to construct a system that
can take all segments of the industrial
pollution cycle into account to create
the most advantageous balance between
effective management of waste and
protection of health and the
environment, o

Research  to  Break
the Land  Disposal   Habit
 by John  H.  Skinner
 f,i(jiii(J mjcrlin/i inriiicrdlfir fit Ff.'/'/\'s
 Combustion lifsrorch Fuci'lily in
 Mlrr.sim, A/!.
 (Hi. Skinner is Pmirlnr of (Jic Office of
 Environmental hiii'-mm-iiii; und
 TrrlmoJn.nv in KPA'.s Office o/Research
Materials Recovery

The metal finishing industry is well on
the way to developing systems for
recovering a host of potentially valuable
metallic compounds. Already, current
technology allows for selective
precipitation and recovery of metals, as
well as blending acidic wastes with
other industrial components that
produce alkaline discharges. Another
innovative technique on the horizon
offers the potential of metal  recovery
from a mixed hydroxide sludge through
hydro-metallurgical techniques.
Designed to remove iron, copper,  zinc,
chromium, and nickel from mixed
sludge* the recovery system  processed
100 pounds of sludge per day  during
testing and shows promise for
economical recovery in a full-scale (50
ton per day) plant.
  Another  approach uses living cells to
capture metals that are essential to the
cells' nutrition. EPA's research has
identified and even synthesized some of
these metal-capturing molecules. These
metal-binding organic materials can be
used to recover hazardous materials,
such as removing copper from mine

Energy Recovery
An estimated 25 million tons of
hazardous wastes produced each year
are combustible, and a substantial
percentage can be  used as a fuel. Many
hazardous waste streams contain spent
solvents and waste oils that have
significant  value as supplemental  fuel in
boilers and in industrial furnaces.
  EPA's research has found that large
industrial boilers can successfully use
wastes as fuel, but smaller boilers
appear to be less effective because of
incomplete destruction of the wastes.
  In properly operated cement kilns and
other such  high temperature furnaces,
using hazardous waste as a
supplementary fuel appears quite
attractive both environmentally and
economically. The commercial viability
of the concept is demonstrated by the
fact that waste is used as a fuel in 12
large cement kilns across the country.
EPA has been involved in evaluating
four of these cement facilities, some of
which can consume 25,000 gallons of
organic  wastes per day.

Waste Treatment

Biological, physical, chemical, and
thermal treatment processes are also
alternatives  to land disposal. EPA
research has shown that incineration
can destroy  in excess of 99.9999 percent
of the organic constituents in some
wastes,  and  that properly operated
incinerators can provide a permanent
solution to certain hazardous waste
problems  with minimal long-term
ecological burden.
  The use of ocean-going incinerator
ships has  also been proposed as a
means of destroying hazardous wastes
in a location far removed from people.
While there  are some advantages to this
approach, there are drawbacks, such as
the possibility of a spill at sea or during
loading operations. In order to respond
to some of the concerns in this area, we
are conducting  further research  into the
effects of ocean incineration on  the
marine ecosystem.
  EPA has participated in the
development of new thermal treatment
processes. Among these are a plasma arc
torch designed  to destroy organic  wastes
at temperatures in excess of 10,000
degrees  Centigrade, and a high
temperature fluid-wall reactor that uses
radiant heat to decontaminate solid
particles, such as soil.
  EPA is also looking at physical and
chemical processes such as
precipitation, solid-liquid and
liquid-liquid separation, neutralization,
and chemical oxidation. Biological
processes  more  advanced than activated
sludge are being investigated as well.
  The innovative physical and chemical
treatment  technologies currently under
development range from advanced
separation techniques to total chemical
destruction.  With newly developed low
pressure, composite reverse-osmosis
membranes,  it appears feasible to
concentrate a variety of organic and
inorganic hazardous wastes from
aqueous streams, thereby greatly
 reducing the volume of hazardous waste
 that must be further treated. Similarly,
 gel materials have been developed that
 can absorb and then release water from
 hazardous waste streams, leaving
 behind a concentrated brine or
 hazardous waste mixture of smaller
  Solvent extraction, which uses a fluid
 into which the hazardous contaminants
 readily dissolve, can also serve to
 remove and concentrate wastes from
 aqueous or nonaqueous streams.
  In a prime example of applying new
 technology to solution of a  persistent
 environmental problem, EPA scientists
 have developed a chemical process to
 detoxify the pesticide fumigant ethylene
 dibromide (EDB). EPA canceled the
 registration of this chemical in 1985.
 Under the terms of the Federal
 Insecticide, Fungicide and Rodenticide
 Act (FIFRA), the Agency is required to
 dispose of existing stores of cancelled
 material. Conventional techniques for
 disposal of EDB. including  incineration,
 would be extremely costly and have not
 been proven  to be  effective. Through the
 use of a mixture of potassium hydroxide
 and tetraethylene glycol (TEG), EPA
 researchers demonstrated rapid and
 economical destruction of EDB and
 produced a by-product, potassium
 bromide, which has significant
 commercial value. Use of the TEG
 method for EDB destruction could save
 EPA millions of dollars.
  Biological treatment of hazardous
 waste also shows tremendous promise.
 EPA researchers are experimenting with
 bacteria, yeasts, and fungi in a program
 to extend the capabilities  of
 biotechnology for hazardous waste
 treatment. Current  information indicates
 that the rather common white rot
 fungus, Phanerochaeta chrysasporium,
 can destroy DDT, dioxins, and related
 compounds at various concentrations.
Commercially developed strains of
microorganisms are also currently on
the  market for degradation of organic
                Continued to next page
APRIL 1986

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Ultimate Disposal
Even with adoption of all these treatment
and destruction measures, however, some
waste derivatives will still require land
disposal. To improve the security and
efficiency of land disposal systems, EPA
is addressing two important issues:
selection criteria for new sites and
containment technologies for exisitng
  In the past, little thought was given to
the physical characteristics of disposal
sites and their capacity to huffer or
absorb hazardous wastes. While we've
learned that some places simply cannot
hold toxic materials, it's possible that
other sites are suitable. To develop
better site selection criteria, EPA is
studying the effectiveness of cover
materials such as vegetation, soils, and
membranes to minimize moisture and
gas movement; the use of leachate
samples or mixtures to predict the
composition of field leachates; and the
effectiveness of chemical stabilization or
encapsulation processes to modify
  EPA is also seeking better waste
containment with improved liners and
leachate collection systems.  With
effective materials, seaming techniques,
and cover materials, potential leakage
can be minimized. In addition,
nondestructive leak detection  systems
are available now that can locate a
leak within one foot of its actual
location. Mathematical models allow
engineers to predict water flow through
a site under various conditions. EPA is
evaluating all of these technologies.

Monitoring, Process, and
Health Research

Another important focus of EPA
research is environmental emissions
from hazardous waste facilities. Agency
investigators are advancing our
understanding of how these emissions
migrate and are transformed in the
environment as well as their potential
impact on human health.
  At the Environmental Monitoring
Systems Laboratories in Las Vegas, NV,
and Cincinnati, OH, work is under way
to improve EPA's ability  to sample and
analyze ground water around hazardous
waste facilities. The labs  are
investigating the use of fiber optics and
lasers, as well as formulating generic
analysis procedures that will simplify
and reduce the costs of analyzing
ground-water samples.
  At the Environmental Research
Laboratory in Athens, GA, researchers
have developed a mathematical model
which predicts the fate and transport of
hazardous contaminants discharged
from hazardous waste landfills. This
research received an EPA Gold Medal
and is the keystone of the Agency's
program to restrict and prohibit the
disposal of certain hazardous wastes in
  Researchers at the Robert S. Kerr
Environmental Research Laboratory at
Ada, OK, are recognized worldwide for
their work in advancing the science of
ground-water processes and are EPA's
experts in understanding the ability of
soil to treat and destroy hazardous
waste. They have recently installed  two
experimental underground  injection
wells to test the performance of systems
that inject hazardous wastes deep into
underground formations.
  The Health Effects Research
Laboratory at Research Triangle Park,
NC, has developed a biological assay
screening  procedure to quickly identify
new  hazardous wastes and evaluate the
hazardous nature of effluents from
various facilities.  Research  in the Office
of Health and  Environmental
Assessment enables EPA to make the
key link between exposure to hazardous
wastes and its impact on human health.
  All of this work is instrumental in
improving our ability to monitor
hazardous waste facilities and reduce
their potential adverse impacts on
health and  the environment.


EPA is working under the provisions of
RCRA to develop and evaluate
improved technologies to help solve
hazardous waste problems. The 1984
amendments direct  the country toward
alternative  treatment and disposal
processes, and toward the upgrading of
existing land disposal sites. With waste
reduction, recycling, and treatment, we
can reduce the volume and toxicity of
those hazardous wastes that must go
ultimately in the land. EPA is
conducting research and development
along with  professional societies, trade
associations, and  other organizations to
advance state-of-the-art technology in
this field. Technical advances to
minimize waste production and develop
properly engineered treatment, storage,
and disposal facilities will ensure that
future generations won't be saddled
with dangerous hazardous waste dumps
because of our waste management
practices, n
                                                                                                           EPA JOURNAL


Spreading  the  Word
About  the  Job  Under  RCRA
by Edgar Berkey
and Karen V. Brown
    How can you get people to listen to
    you when they really don't want to?
How do you communicate effectively to
people so they're motivated to take
actions they might not otherwise take?
  The search for answers to these
questions has commanded the attention
of such noted institutions and fabled
people as ... mothers, Madison
Avenue, Rodney Dangerfield, Dr.
Pavlov, and Sigmund Freud, among
others. Now, as a result of the 1984
amendments to the Resource
Conservation and Recovery Act (RCRA),
the search has also intensified at EPA.
  Why? Because enactment of the  1984
RCRA amendments brought hundreds of
thousands of small businesses under
federal hazardous waste regulations for
the first time and presented EPA with a
fundamentally different community to
regulate. In addition to new
requirements for small  quantity
generators and underground  storage
tanks, there will also be new regulations
on used oil and the kinds of materials
that can be sent to landfills.
  Successful implementation of the
amendments with the small business
community is likely to be a long-term
process, and difficult to accomplish
without first overcoming historical
barriers, real or imagined, between
small businesses and EPA.
  Traditional forms of communication,
regulatory development, and
enforcement won't work. The small
business community is too large and
diffuse. New procedures for leveraging
resources and encouraging voluntary
compliance must be sought.
 (Berkey, a consultant to liPA. is
 President of Synco Consultants, Inc.,
 and Bmwn is h'PA's Small Business
There are definite signs that
some barriers are cracking.
  The newly regulated community
comprises many diverse small business
sectors that generate different kinds of
hazardous waste or operate
underground storage tanks containing
petroleum products or chemicals. This
community is not experienced in
understanding or complying with EPA
regulations. It knows very little about
environmental laws, has a generally
negative view toward all types of
regulators, is suspicious of their
intentions, and fears the economic
consequences of their regulations. On
the other hand, EPA also lacks
experience in understanding and
resolving critical small business issues.
  During debate on the 1984
amendments, many members of
Congress, and organizations and people
who  testified before it, agreed on the
need for a vigorous education effort
specifically designed tor small business.
The final amendments included specific
language directing EPA to conduct
educational and informational activities
to help small quantity generators
understand  their new responsibilities
under RCRA.
  However, before EPA could undertake
these activities, some key questions had
to be considered. From whom did small
business people normally get their
environmental information? What forms
of communication  were most effective?
Whom did they trust and believe?
Whom were they likely to resent? What
were the best delivery systems? What
types of businesses would be affected
and what information did they need?
  EPA's most commonly used means to
communicate regulatory
information—the Federal Register—was
found to be an ineffective resource for
small business operators. They tended
to shy away from detailed technical
information and to rely on their trade
associations to keep them informed.
They feared identifying themselves with
regulators but liked the idea of
confidential telephone Hotlines where
they could call for assistance. They
wanted practical "ho\v to" answers to
their problems.
  EPA's Office of Solid Waste (OSW)
was given primary responsibility for the
initial outreach effort to small quantity
generators—the most far-reaching and
intensive outreach program ever
conducted by EPA on a single set of
  An OSW survey estimated that more
than 650,000 businesses generate
hazardous waste in the U.S. Of these,
over 100,000 produce over 220 pounds
per month, the amount required to  come
under federal regulation. Over 18
individual industry categories affected
by the new requirements were
identified—each with its unique set of
  EPA recognized that to reach this
small business audience, material would
have to be "eye-catching," appealing,
and different from other information
produced by the Agency. It would also
have to be offered by organizations and
delivery systems trusted by small
  Several approaches were developed:
• A colorful, oversized brochure,
entitled "Does Your Business Produce
Hazardous Waste?," discusses the new
federal requirements for small quantity
generators and can include any one of
18 industry-specific inserts so readers
can obtain answers to their particular
• Through a cooperative effort, over 500
national  and  regional trade associations
and small business organizations, as
well as regional and state offices,
distributed more than 750,000 of these
brochures. For people who do not belong
 APRIL 1986

to any association, EPA has made
articles available to over 150 trade
journals covering all 18 identified
industry sectors.

• A 13-minute videotape presents
information on the new record-keeping
requirements. The videotape was
reviewed by people from the small
business community to ensure it  would
be understandable and meet their needs.
• A training program  developed  by EPA
with the National Fire Protection
Association (NFPA) has reached over
30,000 fire service personnel.  Local fire
departments are often  the first point of
contact for small businesses concerned
about storage and disposal of  hazardous
chemicals and materials.
• Finally, Congress specifically
allocated funds for state and local RCKA
activities.  A large portion of these funds
Traditional forms of
communication,  regulatory
development, and enforcement
won't work.
has gone to assist small quantity
generators. Across the U.S., over 70
projects have taken place involving
education and outreach, workshops,
seminars, and preparation of waste
management information. Over 50,000
people have  participated in these
  Is all this effort working? Is small
business compliance growing? It is a
little early to tell since successful
outreach is not a one-time activity.
However, there are definite signs  that
some barriers are cracking. The outreach
material stresses  that EPA hotlines can
be used to obtain  additional
information. As word has spread, usage
of these hotlines has grown to
unprecedented levels—the RCKA
Hotline (800/424-9346) is now
responding to over 8,000 calls per
month; the Small Business Hotline
(800/368-5888) to more than 700. Small
business people have also begun
attending seminars on hazardous waste
in record numbers, and there is greater
willingness on the  part of small
business groups to  work with EPA and
contribute to the ruleinaking process.
  Will this be the end? No. Additional
regulations for small quantity generators
were published in  the Federal Register
on March 24, 1986, and  will go into
effect September 22, 1986. To maintain
momentum will require  further
outreach. But now, EPA will be  more
experienced with small business and
have a better handle on answering those
tough "how to" questions.  D
Vehicle muiMfeiiiuiee operiifjons such (is
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small i/inmfifie.s o( fm/iin/ous iv 
Making  RCRA  Stick
by Jacqueline Tenusak
  If breaking in a pair of hiking boots can
   be painful, try breaking in a costly
new program. That can be excruciating.
  EPA's RCRA enforcement program is
now well broken-in, but its beginning
was no exception to the adage, "No
pain, no gain." With industry waiting to
take its cue, the Agency conducted its
first enforcement "sweep" in 1980 to
monitor compliance with the new
hazardous waste regulations. Many of
the inspectors had to be pulled from
other EPA programs. Most of them had
only just read the regulations they were
supposed to enforce, and  guidance was
extremely limited. But the effort paid
off; the Agency  made its point. Serious
enforcement was here to stay.
  Since that time, monitoring and
enforcement has become a
sophisticated, integrated process. It has
to be. Intended  as a cradle-to-grave
management system for hazardous
waste, RCRA is one of the most
complicated regulatory programs in the
  One of RCRA's major components  is
the permit program for treatment,
storage, and disposal facilities. To
receive a final permit, a facility must
demonstrate that it meets stringent final
operating requirements, including
double liners and a leachate collection
system for some kinds of  land disposal
systems. It's these land systems—about
1,500 of them—that have  become the
focus of EPA's RCRA enforcement
  Land disposal systems include
landfills, land treatment, surface
impoundments, waste piles, and certain
disposal wells. Ninety-five percent of
land systems are associated with
industrial operations; the remaining five
percent are the so-called commercial, or
off-site, facilities. RCRA legislation
allows existing facilities a qualified
"grandfathering" known as interim
status until their permit applications are
resolved. But even interim status
facilities have to comply with
(Tenusak is an Environmental
Protection Specialist in the EPA Office
of Waste Programs Enforcement.)
requirements to monitor ground water
and ensure their financial ability to
close down operations properly.
  The monitoring rules require that
hazardous waste facilities install
systems to detect leakage to ground
water from land  disposal units. If leaks
are found, the facilities must install
systems to track  and characterize the
contaminants. Under the financial
assurance requirements, facilities must
also prove that they have the financial
capability to continue monitoring those
wastes that may  remain after closure. In
addition, firms owning  hazardous waste
RCRA is one of the most
complicated regulatory
programs in the government.
facilities must have liability insurance
covering bodily injury and property
damage to third parties caused by
sudden and non-sudden accidental
occurrences arising from facility
  By 1984. however, only seven of the
1,500 land systems had received final
permits, and a little under 200 were
going through closure proceedings. The
rest were in interim status, and a
Congressional survey found that only 43
percent of them were complying with
the ground-water monitoring
requirements. The permitting process
was taking considerably longer than
originally envisioned.
  Congress lost patience. The Hazardous
and Solid Waste Amendments of 1984
included a provision for what EPA now
calls "loss of  interim status." Facilities
were given one year—until November 8,
1985—either to certify that they  were in
compliance with interim requirements
and apply for a final permit, or to begin
closure proceedings.
  The  effects  of this provision were
immediate. Since the November cutoff,
a resounding  two-thirds of land disposal
facilities have lost their interim status,
either because they could not certify
compliance with requirements, or
 because they chose to close rather than
 comply with new and more stringent
 requirements to be  imposed over the
 next two years.
   Most of the closing facilities are
 disposal units for small, on-site
 manufacturing firms that may now store
 their wastes for no  more than 90 days.
 After that,  they  must treat or recycle the
 waste  on-site or ship it to  a commercial
 or off-site facility.
   The overwhelming majority of these
 firms will remain in business, but
 because their disposal units are closing
 down, they must still be inspected to
 determine whether  their ground-water
 monitoring system adequately detects
 contamination. Many will require
 corrective action—a process that can
»range from removing a few tanks to
 conducting a major Superfund-type
 cleanup to bring waste releases  under
 control so that they no longer create a
 potentially dangerous situation  for the
 surrounding community.
   It's a tremendous challenge for the
 Agency to  inspect and clear these
 facilities before  they leave the RCRA
 system. Their compliance with
 monitoring and  financial responsibility
 requirements as of November 8  must be
 verified, and their closure plans
 reviewed. EPA must also make sure that
 those who  lost their interim status  do
 not continue to  use their disposal units
 for hazardous waste.
   The challenge posed by  those
 facilities remaining in the system will
 be just as great.  The new requirements
 are stringent and demanding. Tluire are
 extensive technical  standards, and  many
 of the  remaining facilities  will also need
 to take corrective action.
   It's up to EPA's permitting and
 enforcement teams to shepherd  these
 facilities through the
 process—monitoring compliance and
 using enforcement authorities if
 necessary, but also providing advice and
 assistance.  Congress wants far better
 compliance with RCRA regulations, and
 so do those who work in the hazardous
 waste program. It will be difficult, but
 the first steps have been taken,  a
APRIL 1986

RCRA's  Challenge:
A View  from  the  Outside
by Richard  Fortuna
ifTTuman kind cannot bear very
   XTLmuch reality," said T. S.  Eliot,
and the reality of hazardous waste is no
exception. But, in the 1984 amendments
to the Resource Conservation and
Recovery Act (RCRA), we have  finally
begun to face the grim fact that  without
change, the RCRA program itself could
be the leading cause of future
Superfund sites.  The 1984 amendments
challenge EPA, the regulated
community, and  the nation as a whole
to institute the most profound series of
changes in  hazardous waste policy and
practices that this or any nation has
ever attempted.
  It was in the late 1950s when the
nation began to realize that post-war
progress carried a price. Spurred by
fires on the Cuyahoga River, the
near death of Lake Erie, and
smog-obscured skylines,  the U.S.
Congress enacted landmark legislation
to control air and water pollution. The
nation can be justifiably proud  of this
  But while measures to protect air  and
water have begun to mature, threats to
the land ami its ground-water resources
are only now becoming understood.
Despite passage of RCRA in  1976, the
field of hazardous waste had little of the
ingenuity and technology-forcing
legislation that were brought to  bear on
air and water pollution.
  The consequences of not closing this
environmental loop are no less  sobering
than the dead fish I recall seeing on the
shores of Lake Erie in 1958.  Love Canal
and the Valley of the Drums are but the
most visible manifestations of our
collective failure to control hazardous
wastes and protect the media that we
see the least.
  The origins of  the 1984 Congressional
action are many.  More waste,
 (Fortmm is Kxecutive Director uf flic
 Hazardous Wastt: TrcdtiiKnil C.auncil.
 He helped develop ninny of flu.1 key
 amendments in the reauthorization of
 the. He.sourre CmiKervdtion 
 general prohibition. In many ways, land
 disposal is now presumptively guilty
 until proven innocent. The regulated
 community knows that unless it
 provides the Agency with good faith
 assistance in developing a regulation, it
 will have to live with a general rule that
 has no exceptions, legitimate or
   If the presumptive prohibitions and
 minimum regulatory controls (or
 hammers) are the heart of the 1984
 changes in RCRA, then the soul is the
 search for certainty—certainty that
 future generations will not have to bear
 the burden of current expedience, and
 certainty that the transition to treatment
 alternatives will occur on a timely and
 orderly basis.
   Despite the tight deadlines, the
 Agency has responded to these
 challenges with productivity
 unparalleled in the  program's history. In
 12 months, EPA has issued a land
 disposal schedule and ban, ended
 temporary de-listings and related
 protocols, and prepared new waste
 listings "and new controls on hazardous
 waste tanks, recycling generally, and the
 burning of hazardous wastes.
   A program that could never meet its
 statutory deadlines is now hitting more
 than  it misses. This new record of
 accomplishment is no coincidence, and
 is directly attributable to the
 decision-making structure of the 1984
   Despite these auspicious beginnings,
many challenges lie ahead. The Agency
and the states must be able to summon
the resources necessary for independent
regulatory development and
enforcement. In addition, closing
loopholes and restricting land disposal
are only part of the job. Unless the
limits of land disposal are understood
by all, and unless the permit policy can
adapt to the restrictions and program
expansion, we may well be all dressed
up with no place to go. For generators
and the treatment industry, the
challenges will be  similar—to assist the
Agency by providing information
necessary to define the limits of the
land disposal restrictions, and to make
timely investments in the technology of
transition even when one may not be
convinced such change is absolutely
required. The benefit of the doubt must
go to permanence rather than
perpetuation of the status quo.
  For the environmental community,
the challenges will be to ensure that the
aims of the legislation are realized in
the implementing regulations.
Environmentalists, however, must
recognize that the current permit
process  can actually impede the
transition away from land disposal.
  Every day, new investments and
expansions are occurring and treatment
needs are defined.  But where land
disposal is a one-step process, treatment
frequently requires multiple steps, and
different steps for different wastes.
Restrictions on land disposal will not
translate into acceptable treatment
unless the permit process adapts to the
transition under way. The pace of
permitting is one problem: even more
important is that the final permit
process be flexible enough to meet the
evolving and dynamic needs brought
about by the new amendments.
  For all of us, the real challenge will
be to accept in practice what we know
in theory needs to be  done. Most people
agree that we must move away from
land disposal and use alternative forms
of treatment. This philosophy, which
the Hazardous Waste Treatment Council
was founded on, is now the axiom of
this field. But when it comes to
implementing specific provisions of the
legislation, consensus vanishes.
  Even so, this diversity of views is  a
healthy sign that the program has finally
come of age.
  We must collectively acknowledge
that the 1984 amendments are not just a
repackaging of previous policies, and at
the same time, that land disposal does
have a role. In implementing this law
and its land disposal prohibitions, we
cannot forget the reasons for its
enactment, or the practical limitations
of conducting and "permitting" this
  Mutual recognition  of these facts,
punctuated by a high  level of
participation, should yield at long last  a
national program that is second to none.
one to  which we can point with pride,
rather than look back  to with chagrin.  D
APRIL 1986

Tackling  Pollution
from  Underground   Storage  Tanks
by June Taylor
     With the temperature at 2 degrees
     and a wind chill of 20 below, a
high school student starts his
before-school job—opening a service
station in Winona, MM. In the pitch
black morning, he chips away two
inches of ice before removing a metal
plate and dropping a 15-foot pole into
one of four underground tanks storing
gasoline at the station. The
measurements he takes will be
compared to those taken by his boss
before closing the previous night. At
this station and thousands of others like
it across the country, those numbers are
the only clue; telling the station owner if
his tanks an; leaking.
 Thousands of tanks are
 thought to be leaking,  with
 more leaks expected to
 develop in the next five  to ten
  In an era of computerized gasoline
 pumps, the dip stick may seem a crude
 way to measure gasoline left in an
 underground tank. It is. Temperature
 fluctuations affect the level of gas in the
 tank, and it takes several weeks of
 measurements to show losses. Even
 then, small leaks probably won't be
 detected. But despite its flaws, the dip
 stick is the only method of inventory
 control available for over 95 percent of
 America's service stations. It's cheap
 and  any worker at the station can use it,
 but the diligence with which it's
 practiced is questionable.
  Storage tanks were originally placed
 underground as a fire prevention
 measure, and underground tanks have
 fTin'Jor is the Unlrcucli Coordinator/or
 l/n1 l'.l\\ (M/icr nl Underground .Sf
 Tucks. I
substantially reduced the damages from
stored flammable liquids. But out of
sight leaks from underground tanks pose
a longer term problem, sometimes
causing fires and explosions and
polluting soils and underground water.
  The picturesque little Cape Cod
community of Truro, MA, for example,
discovered that its drinking water wells
were contaminated with gasoline from a
nearby underground storage tank. The
company responsible was ordered to
provide residents with bottled water
and to spend millions of dollars to
decontaminate the water supply. Across
the country in the "Silicon  Valley"
south of San Francisco, leaks and spills
of toxic solvents from underground
tanks and their associated piping have
contaminated the ground water.
  EPA estimates there are from three to
five million underground tanks in the
United States that contain petroleum
products or hazardous chemicals.
Thousands of these tanks are thought to
be leaking, with more leaks expected to
develop in the next five to ten years.
  Perhaps 90 percent of underground
tanks are for petroleum. Many were
installed in the boom period of the
1950s, when gas stations seemed  to pop
up at almost every intersection.
Unfortunately, most  of those tanks are
bare  steel, highly subject to corrosion,
and at the end of their useful lives.
(Even now, steel tanks improved  with
fiberglass coatings are only  guaranteed
for 30 years.)
  When these old tanks are pulled from
the ground, many of them have holes
right where the dip stick was dropped
hundreds of times to measure for leaks.
(Since the late 1970s, most  steel and
fiberglass tanks have an extra half-inch
steel plate  under the test hole to prevent
this problem.)
  Because of the problems with older
tanks and the liability posed by leaks,
many major oil companies have begun
to replace all company tanks  with
newer, safer designs.
  Replacement is easier for the majors
with their large financial resources and
ability to command quantity discounts
in ordering tanks. (Majors control about
one third of all gas stations.) But for the
smaller independents, the $10,000 to
$22,000  expenditure for a new 10.000
gallon tank is onerous, especially
considering that  most stations have three
to four underground tanks.
Leaks from  underground tanks
pose a longer term problem,
sometimes causing fires  and
explosions, and polluting soils
and underground  water.
  In addition to the problem of old
tanks still in use, there is still the
dilemma of thousands of gas stations
that closed during the oil crises of the
1970s. The abandoned tanks at these
stations may not have been closed
properly, and ownership and
responsibility for future problems may
be hard to track.
  A year and a half ago, Congress
enacted sweeping amendments to the
Resource Conservation and Recovery
Act (RCRA), the law regulating
hazardous wastes. The amendments
provide for federal regulation of
underground storage tanks, including
the imposition of interim requirements
for design and corrosion protection for
any tanks installed in the ground. In  the
meantime, EPA  is developing standards
                                                             EPA JOURNAL


for new tanks, as well as regulations for
record keeping, leak detection and leak
prevention, closure, and reporting.
These rules will take effect in 1987 and
  To enable state agencies to locate
underground tanks, the law requires
owners to file basic information about
age, size, location,  and contents of their
tanks. These forms must be filed by
May 8, 1986,  or owners face a penalty of
$10,000 per tank. Tanks for residential
home heating oil and  small farm tanks
(1,100 gallons and under) are excluded
from the legislation. EPA expects the
new amendments to cover about one
million tanks.
  Some states, notably Florida, Rhode
Island, and California, have moved
ahead of the federal government in
registering and  regulating underground
tanks. But most other states are simply
struggling to  keep up  with the federal
provisions; if they fail to do so, EPA is
required to enforce the law in their
  A key concern for EPA is assuring
adequate state and local programs to
address the tank problem. Clearly,  a
small (or big] staff in Washington and
EPA regional offices cannot deal with
the millions of tanks scattered
throughout the United States. This is in
many ways a local problem. City and
county personnel now authorize the
installation of new tanks. Fire
departments, building and plumbing
codes, and health departments also play
roles in various communities—roles that
will no  doubt expand in the future.
  Both EPA and the states are grappling
with the new problem of
communicating with the thousands of
small businesses—principally gas
station owners—who now find
themselves subject to regulation. It's one
thing to regulate a steel mill, chemical
plant, or power plant whose staff
includes trained environmental
engineers. It's quite another to deal with
small businesses that feel overburdened
by paperwork and threatened by the
 i.euks from an underground tunk til liu's
 gds sditioii in Ti'iiro. MA. contaminated
 (he Joint's (frinkinj; ivater  The rompum
 responsible for the problem Iniiit ci
 chrm'Odl (tlti'utidn funk system. Uir
 riglil. (o (red! f/ie u'ii(er
potential costs of leak detection and
prevention as well as by the liability
implications of leaks. And finally,
whatever system EPA chooses for leak
detection, prevention, record keeping,
reporting, and the like, it has to be
understandable and "do-able" by a high
school student in the freezing cold and
dark of a Minnesota winter morning.
Otherwise, it may look good on paper,
but it won't work in the real
world—and that's where the leaks
are. Q
APRIL 1986

EPA's  Task  Force  on
Hazardous  Waste
in  Ground  Water
 by Antoinette Ferrara
  It's 5:30 n.m. In anticipation of the
   day's heat, the Hazardous Waste
 Ground Water Task Force members and
 contractors have risen early. After a
 quick breakfast, they clamber into the
 EPA van, already packed with their
 safety equipment. At 6:30, the van joins
 a lineup at the entrance to the waste
 disposal facility. Ahead, there must be
 40 trucks, all waiting to discharge their
 payloads into the facility's pug mills
 (mixing devices) and landfills. Many of
 the truckJoads were picked up within
 the week at a Superfund site two or
 three states away. Their payfoads are
 toxic wastes—noxious, and hazardous
 to human life.
  The trucks have come to this
 particular facility as part of an elaborate,
 long-term plan for removing such
 wastes from an NPL (National Priorities
 List) site and transferring them to safe
  Hut tin; question asked more and
 more frequently these days  is—are
 facilities such as this one really safe? Is
 it possible that all we're doing  is
 creating new Superfund sites? Well,
 most of such facilities are not  in
 heavily populated areas, and unlike
 untreated Superfund sites, they have
 safeguards and expensive infrastructures
 in place to  guard against unknowing
 exposure to the toxic wastes. Yet, the
 suspicion is growing within the
 environmental  and scientific community
 that ground water, one of our nation's
 most valuable resources, is being
 threatened  by the "safe" disposal of toxic
  Ground-water supplies are
 increasingly important for drinking and
 agricultural purposes. Once polluted,
 they can be cleaned up only at
 phenomenal expense, and with little
 guarantee of success.
 (Fm'uru is Communications Advisor to
 KI'.Vs Il(i/(irdous Waste Ground Water
 Task Force.)
  The Resource Conservation and
Recovery Act (RCRA) provides the legal
framework for requiring waste disposal
facilities to guard against ground-water
contamination. Its implementation is
primarily the responsibility of the
authorized states, which are directed by
the law to develop programs
"substantially equivalent" to that of the
federal government.
  But "substantially equivalent" has
turned out to mean a lot of different
things to different people. The result
has been varying degrees of
ground-water monitoring compliance.
  To encourage more consistency in
handling ground-water problems, the
EPA Hazardous Waste Ground Water
Task Force was formed  in January 1985.
Composed of personnel from
headquarters, regions, states, and the
National Enforcement Investigations
Center (NElCj, the Task Force now is
expected to investigate 58 land disposal
facilities (both commercial and
generator-owned) in the course of its
  The team's goals are to examine
facilities to determine their compliance
with RCRA regulations; to identify
problems which inhibit state and EPA
efforts to gain compliance with the law;
to develop and demonstrate a nationally
consistent approach to evaluating
ground-water monitoring at facilities
across the  country; and to deal with
deficiencies that may be found.

1 he Task  Force team heads first to
the  main office, where a meeting
with the plant's supervisory team is
scheduled. Together the group will go
over some of the facility's records,
negotiate technical support expected
from the facility, and finalize the week's
schedule for taking samples and
interviewing company officials.

  Prior to  this day, members of the Task
Force had  received and reviewed
numerous documents submitted by the
facility, including its Part B permit
application, all finished hydrogeological
reports, and a history of any federal,
                                                                                                   EPA JOURNAL

state or local enforcement actions in
which the facility was involved.
Additionally, they will have visited the
office to peruse the company's files and
request any other necessary data. That
review formed the basis of the project
plan for this present investigation,
having allowed the team to spot
potential weaknesses and lapses in
compliance ahead of time.
  Since only two weeks in the Task
Force's busy schedule are allocated for
the on-site inspection and sampling, the
members must be thoroughly familiar
with the facility and, in short, "have
their act together." This inspection will
require an all out effort involving hard
physical work from the Task Force each
day, as well as a nightly debriefing, and
discussions of individual observations
and the next day's plan.

Most waste  disposal facilities are large,
This one is no exception: 200 acres will
be covered (many of them on foot); from
25 to 30 monitoring wells will be
purged and sampled. Additional
sampling  sites include leachate sumps
and surface-water discharge points.
  It's hot, tool With the temperature in
the 100s, the  TYVEX suit, boots, and
double-lined gloves each team member
must wear as protection  makes for an
arduous, not  to mention
perspiration-soaked, ordeal. There's
little or no shade out there among the
disposal pools and landfills.  Breaks for
a drink of water—allowed only within
the confines of the team's vehicle—are
  First, the purging of wells begins.
Depending on the depth  of a well, this
can take up to two days  to complete,
On a Task Force inspection in Oregon.
contractors fnnt.sfer blank (clean] ivtiter
from u bailer inside a .storage container
(o a sample  collodion bottle, [f
subsequent Jab analysis shoivs
hazardous wash; constitue.'nls in (he
water,  inspectors will know that (lie
sampling equipment is contaminated.
and another day and a half may be
required for the well to "recover"
  Then, the sampling gets under way,
and this consists of several laborious
steps. As the samples are drawn, they
are trans/erred into 60 millimeter or 1
liter bottles which  are labeled and
packed  into ice-filled coolers. Three or
four coolers are needed for the
approximately 60-70 samples from each
well. These are carefully sealed with
custody tape and prepared for overnight
shipment to the analytical laboratories.
A suspicion is growing that
ground water is being
threatened by the "safe"
disposal of toxic wastes.
  In addition to the field investigators,
the Task Force also includes members
who are thinking about the overall
condition of ground-water monitoring in
the country, based on information from
the field. Their analysis is expected to
provide the states, regions, and facilities
with clear guidelines for improving
ground-water monitoring capabilities.
They identify and analyze problems that
could be caused by deficient guidance
or regulations, uneven enforcement, or
inadequate training or technology.

ixlext step: samples taken at the facility
are shipped to the contract laboratory
for analysis. Care is taken to ensure the
chain of custody is unbroken in case
the samples might later be needed as
evidence in a court proceeding.
Likewise, when the lab is finished with
its work, care will be exercised to
ensure the integrity of the analysis.
Quality assurance and quality control
studies are performed by a number of
scientists in EPA. If the lab analysis
proves valid, then and only then will
conclusions be drawn about the quality
of the ground water tested. These
conclusions will be determined in
consensus meetings involving the
headquarters, state, NEIC, and regional
members of the Task Force, and will
form the core of the subsequent
technical report.

  While the Task Force may spend only
two weeks and a few days on the
grounds of a facility, the complete
investigation takes close to nine months.
At the conclusion, a final report is
issued. This contains the technical
report and Task Force recommendations
for improving any deficiencies that have
come to light. The remedies can range
from changes in a permit application, to
corrective or enforcement actions, to an
actual shutdown. The option required to
bring the facility into line with  RCRA
regulations is arrived at through
consensus by all Task Force members,
and will be spelled out in this final
report.  As of March, 1986, the Task
Force had completed site inspections at
15 facilities, and records reviews at six
others. The first technical report/facility
management plan was expected to be
released at the end of March. As this is
written, it is too early to tell what those
reports will say about the state of
ground water near those facilities
investigated. However, a critical tenet of
Task Force procedure is that if,  during
the course of an investigation, severe,
health-affecting contamination is
discovered, there will be no waiting for
the final report  to be compiled-—rather,
immediate steps will be taken to ensure
the health and safety of anyone
potentially affected.

1 he inspection is finally completed.
One last meeting with company officials
is held. The Task Force team thanks the
officials for their cooperation and
explains the investigation phases still to
come  which will culminate in a final
report. Then, it's probably off to the
nearest watering hole to relax and swap
tales of heat and fumes and hard
work,  a
 APRIL 1986

A review of recent major EPA activities and developments in the pollution control program areas
Emissions Rule
EPA has proposed national
work practice standards to
limit radon-222 emissions
from mill tailings at licensed
uranium mill sites.
  The Agency has made a
preliminary finding that
these emissions from
uranium mill tailings cause a
significant public health risk.
The proposed rule is
intended to reduce this risk.
  There are 26 licensed
uranium mills in the United
States located in seven states:
Colorado, New Mexico,
       South Dakota, Texas. Utah,
       Washington, and Wyoming.

       Lead Violations
       Ashland Oil, Inc., has agreed
       to pay $600,000 in civil
       penalties for exceeding
       federal gasoline lead content
       standards. The penalty
       amount is the largest ever
       received in settlement of a
       case involving violation of
       EPA fuels regulations.
         The penalty agreement
       settles a suit brought against
       Ashland by the Department
       of Justice last May in the U.S.
       District Court in Kentucky
       after an attempted settlement
       of Agency administrative
       charges failed.

Aerojet Settlement
EPA and the State of
California have signed a
settlement agreement  with
Aerojet General Corp. and its
subsidiary, Cordova Chemical
Co., for a comprehensive
investigation and cleanup of
ground-water and soil
contamination at Aerojet's
manufacturing facility in
Rancho Cordova, CA.  The
settlement could be worth up
to $82 million, depending on
the selection of the ultimate
cleanup remedy.
  The decree includes a $45
million financial guarantee to
ensure that cleanup funds are
available. Aerojet will also
make payments of up to
$7.15 million directly to the
federal government and the
state which includes
reimbursement of past
investigative costs and
approximately  $2.5 million
for oversight of future work.
  The Aerojet facility,
classified by the state as one
of its most severe hazardous
waste sites, has been on
EPA's National Priorities  List
under the federal Superfund
program since the
publication of the first
national list in December
   EPA Administrator Lee M. Thomas
   recently announced the reassignment
of ten senior executives as part
of an ongoing management program
designed to bring greater cross-media
perspectives to.EPA's decision-making
and to build agency-wide experience in
the senior management team.
  The assignments were to become
effective late March or early April.

Bruce Barkley, who was a member of
the Senior Executive Service (SES) at
the Department of Transportation
(DOT), has been selected as Director of
the EPA Office of Management Systems
and Evaluation (OMSE). Most recently,
he was Director of Management
Planning in the Office of the Secretary
at DOT.

Irwin Baumel, who has been Director of
the Health and Environmental Review
Division, Office of Toxic Substances,
was named Director, Office of
Regulatory Support in the Office of
Research and Development (ORD). He
brings to this position considerable
government management experience in
the area  of regulatory science policy.

Thomas Devine, currently the Director,
Waste Management Division, Region 4,
will become Director, Office of Policy,
Budget, and Program Management in
the Office of Solid Waste and
Emergency Response (OSWER).  Aided
by his broad experience, he will
undertake an extensive review of the
                 organization of the Assistant
                 Administrator's office and the rest of
                 OSWER, with emphasis on the
                 provision of planning and technology

                 James Falco,  who has been Director of
                 the Exposure Assessment Group in
                 ORD, will become the Director of the
                 Office of Environmental Processes and
                 Effects Research. His scientific and field
                 experience in dealing with multi-media
                 exposure assessments will be
                 instrumental  in leading an office whose
                 principal responsibility encompasses
                 advancing the state of the art in
                 environmental risk assessment.

                 Gordon Hueter and Francis Mayo will
                 assume the additional responsibilities of
                 Designated Senior ORD Officials in
                 Research Triangle Park (RTP) and
                 Cincinnati, respectively. Hueter
                 currently is Director of EPA's Health
                 Effects Research Laboratory at RTP and
                 Mayo is Director of the Agency's Water
                 Engineering Research Laboratory in

                 Thomas Hauser has assumed the
                 position of Director of the Hazardous
                 Waste Engineering Lab in Cincinnati for
                 the Office of Research and Development.
                 He was previously Director of
                 ORD's Environmental Monitoring Lab  at
                 RTP. He will  apply his 30 years of
                 scientific and management experience
                 in air pollution measurement and
                 monitoring to seeking solutions to
                 hazardous waste disposal.
                   Clarence Mahan will become the
                   Director of the Office of Research
                   Program Management in ORD.
                   Previously he held the  position of
                   Associate Comptroller in the Office of
                   the Comptroller in the Office of
                   Administration and Resources
                   Management (OARM). He will bring
                   with him substantial technical and
                   managerial experience in budgeting,
                   financial management systems, and

                   Peter Preuss, most recently the Director
                   of the Office of Regulatory Support  in
                   ORD, will become the Director of the
                   Office of Health and Environmental
                   Assessment (OHEA). He has significant
                   international, state government, and
                   federal level experience in dealing with
                   the interface of science and policy
                   issues as they relate to health hazard
                   assessment and risk assessment.

                   Samuel Rondberg will become the
                   Associate Director for Managment,
                   Planning, and Evaluation in the Office
                   of Information Resources Management
                   in OARM. He now holds the position of
                   Director  of the Office of Research
                   Program Management in ORD. He has
                   been with EPA since 1974, and has  been
                   one  of the Agency's major supporters of
                   integrating telecommunications, ADP,
                   and  related applications into a
                   management framework. Q
                                                                                                     EPA JOURNAL

Standards for Fluoride
Final Revised Drinking Water
Standards have been set by
EPA for fluoride.
  Agency actions include
issuing a final Maximum
Contaminant Level (MCL),
amending an Interim MCL,
and setting new requirements
for monitoring and public
notification at the local level.
The MCL and Interim MCL
are both set at a level of 4
milligrams of fluoride per
liter, EPA also announced  a
Secondary Maximum
Contaminant Level (SMCL)
for fluoride of 2 milligrams
per liter.
  RMCLs and MCLs are
required steps in the
regulation process leading  to
primary drinking water
standards that are enforceable
by law. Secondary standards
(SMCLs) deal with esthetics
such as taste and odor and
are not mandatory.
  The action announced by
EPA has no  bearing  on
drinking water  fluoridation,
which is practiced in many
communities that have very
low levels of natural fluoride
in their  water supplies. It
deals with communities that
currently have water supplies
with very high  natural levels
of fluoride.
                                                                                  "While measures to protect air and
                                                                                  water are beginning to mature, the lull
                                                                                  nature and .scope of the threats Jo. . .the
                                                                                  land  and its ground-water resources (ire
                                                                                  only  now being fully defined."
                                                                                  Richard Fortuna (See story on page 18.)