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Hazardous waste control

Are we creating problems for future generations?


Every year approximately one ton
of hazardous waste is added to the
environment for each person in the
U.S. Although there is some dis-
agreement and uncertainty about the
exact amount of hazardous waste
produced annually, there is a general
consensus that the quantity subject to
federal regulation is in the range of 30
to 60 million tons. Hazardous waste
exempted from federal regulation but
covered by state regulations adds an-
other 230-260 million tons, making
the total number of tons comparable to
the population of this country (see
Table 1).
Recently both the Office of Tech-
nology Assessment (OTA) and the
National Academy of Sciences (NAS)
published reports on the management
of hazardous wastes. Although these
reports do not have the same focus,
there is a striking similarity in the
opinions and ideas contained in them.
(The NAS report is oriented toward
the required control technologies,
whereas the OTA report focuses
somewhat more on changes in regula-
tions that might improve hazardous
waste control.)
According to these reports, as much
as 80% of the 260-320 million tons of
hazardous waste produced annually is
disposed of in or on the land. Many of
the hazardous materials placed in
landfills are highly toxic and remain
hazardous for hundreds of years. The
committee that prepared the NAS
report decided that "at least 500 years
is realistic as a period of concern for
hazardous wastes in landfills...."
Regulations under the Resource
Conservation and Recovery Act
(RCRA), however, require monitoring
for only 30 years after a landfill is
closed. Therefore, it could begin to leak
toxic substances during the centuries
following its shutdown, and the leak
would not be detected by legally re-
quired monitoring.
Also, there is a scientific consensus
that no matter how well a landfill is
designed, no matter what the liner and
cap are made of, the landfill eventually
will leak. As the OTA report states,
"even with new stricter RCRA regu-
lations in place, eventual releases of
hazardous constituents from land
disposal facilities are highly probable."
The NAS publication also concludes
that with time, the surface cover over
a landfill can be penetrated and mobile
constituents can leak to groundwater.
Thus, both studies conclude that
landfills appear to be an inexpensive
method of waste disposal, but because
they require monitoring and mainte-
nance for hundreds of years, they
transfer part of the cost of waste dis-
posal to future generations. Eventu-
ally, 30 or 100 or 200 years later-
whenever the landfill begins to
leak-more money will be spent to
control hazardous releases and contain
the wastes. These costs will be borne by
government or by society in general
instead of by the generator. The 30-
year postclosure monitoring require-
ment hides the true cost of long-term
care.
Besides the too-short postclosure
monitoring requirement, the OTA and
NAS reports say that existing regula-
tions for landfills contain other defi-
ciencies. Stringent monitoring is not
required even while the landfill is in
operation. The regulations require
merely that four ambient groundwater
samples be taken fOUf times a year. No
air monitoring is required to determine
if emissions of volatile organic com-
pounds pose a health hazard. Retro-
fitting to meet new standards, such as
the installation of a liner, is not re-
quired at existing active landfills, nor
is it required for those portions of ex-
isting landfills that do not yet contain
waste. No geological strategies for
0013-936X/83/0916-0281A$01.50/0 1983 American Chemical Society Environ. Sci. Technol., Vol. 17, No.7, 1983 281A
TABLE 1
Examples of hazardous wastes exempted from federal regulation
Estimated
annual generation Determined
Waste type
(million metric tons) Possible hazard by
Fly and bottom ash from burning fossil fuels 66 Trace toxic metals RCRA
Fuels gas emission control waste Unknown Toxic organics and inorganics RCRA
Mining waste, including radioactive waste 2100 Toxic metals, acidity, radioactivity RCRA
Domestic sewage discharged into publicly owned 5 Uncertain, toxic metals likely RCRA
treatment works
Cement kiln dust 12 Alkalinity, toxic metals RCRA
Gas and oil drilling muds and production waste; Unknown Alkalinity, toxic metals, toxic RCRA
geothermal energy waste organics, salinity
NPDES-permitted industrial discharge Unknown Toxic organics, heavy metals RCRA
Irrigation return flo.ws Unknown Pesticides, fertilizers RCRA
Waste burned as fuels 19 Unburned toxic organics EPA
Waste oil Unknown Toxic organics, toxic metals EPA
Infectious waste Unknown Infectious materials EPA
Small-volume generators 2.7-4.0 Possibly any hazardous waste EPA
Agricultural waste Unknown Variable EPA
Waste exempted under delisting petitionsa Unknown Presumably insignificant EPA
Deferred regulations Unknown Unknown EPA
EPA deregulation Unknown Presumably insignificant EPA
Toxicity test exemptions b Unknown Organics EPA
Recycled waste C Unknown Improper application of various materials EPA
a Wastes may be delisted on the basis of a petition that concerns only the constituents that have determined the original listing; however, other hazardous
constituents may be present that have previously been unrecognized administratively.
b Wastes not identified as toxic by the EPA extraction procedure test and not otherwise listed by EPA
C Legitimate recycling is exempt from RCRA regulations except for storage. However, there have been numerous incidents, such as the dioxin case
in Missouri, involving recycled materials that are still hazardous.
Source: Adapted from "Technologies and Management Strategies for Hazardous Waste Control"; U.S. Congress, Office of Technology Assessment,
Washington, D.C. 20510
protecting drinking water supplies are
mandated in regulations for siting new
landfills.
Hidden costs
Both NAS and OTA conclude that
lax policies regarding landfills make
them more economical than other al-
ternatives and encourage industry to
use them for nearly all its wastes. If
industry had to pay the true cost of
landfill disposal-the cost of contain-
ing the wastes over hundreds of
years-it would be far more inclined
to use other methods. Alternatives to
land disposal could cost 50-100% more
today than current disposal costs. But
cleaning up newly created sites years
from now might cost 10-100 times this
additional outlay.
NAS and OTA advocate minimal
use of landfills and changes in regula-
tions that will encourage the use of
other methods of disposal. Current
regulations, they say, provide disin-
centives for other disposal methods.
Neither report states, however, that
landfills can be eliminated entirely as
a method of hazardous waste disposal.
Both conclude that even with ideal
282A Environ. Sci. Technol., Vol. 17, No.7, 1983
waste disposal treatment methods,
some wastes would have to be disposed
of on land. But they agree that the
amount of waste placed in landfills can
be reduced drastically.
Hierarchy of options
Rather than relying almost exclu-
sivelyon land disposal, OTA and NAS
propose that a hierarchy of options be
used. "There are basically three gen-
eral options," NAS writes, "Elimina-
tion [or reduction] or reuse of the
hazardous waste, conversion of the
hazardous waste into nonhazardous or
less hazardous material, and perpetual
storage." These options and general
methods for achieving them are dia-
gramed in Figure 1.
Neither OTA nor NAS believes
that there is a panacea for all hazard-
ous wastes. But NAS considers the
first general set of options, which it
calls in-plant options, "probably the
most economical and effective means
of managing hazardous wastes." In-
cluded in this category are process
modifications, such as altering the
chemistry or certain other aspects of
engineering operations, and recycling
and reuse of the hazardous by-prod-
ucts. For certain wastes, process
modifications do not eliminate the
wastes entirely but reduce their volume
or degree of hazard. For example,
modifications to the mercury elec-
trolysis cell have resulted in reductions
in the major types of waste produced
by the chloralkali industry.
For the wastes that are not elimi-
nated by in-plant options, NAS advo-

used-conversion of the hazardous
waste into nonhazardous or less haz-
ardous material. The NAS committee
members evaluated the state of devel-
opment of the different methods in this
category and pointed out research
needs in each area. Although chemical
and physical techniques could be used,
in principle, to dispose of any hazard-
ous waste, these methods would be too
expensive for some wastes. The com-
mittee recommends that much addi-
tional research be performed in this
area, such as:
continued experimental deter-
mination of various hazardous waste
species and mixtures;
further development of processes
to remove metals from industrial waste
streams;
further development of separation
processes based on supercritical fluids,
liquid membranes, and foam frac-
tionation; and
development of a low-cost process
to remove water from slimes and
sludges.
A large number of biological treat-
ment processes exist that use indige-
nous or adapted microbes to remove or
detoxify wastes. NAS recommends
that genetic engineering might be
considered as a method to develop new
species for this purpose.
At present, incineration provides the
most complete means of disposing of
many organic materials. NAS points
out, however, that incineration has
certain drawbacks. For example, it
often requires emission controls and
sampling and analysis of incineration
products. If inorganic materials are
present in the waste, slag and ash are
produced as end products and must be
disposed of.
Unlike incineration, which requires
an open flame, thermal methods use
heat to treat hazardous waste. NAS
mentions a number of techniques for
this purpose: catalytic and reactive
fluidized bed systems, molten salt re-
actors, plasma arcs and torches, mi-
crowave systems, and pyrolytic pro-
cesses.-The only thermal method that
has been used widely in industry is the
pyrolytic process.
Land treatment (which is distinct
from landfilling) is another method
that has broad potential, according to
NAS. In land treatment, the top layer
of soil, approximately 1 ft, is mixed
with the waste. Then, theoretically,
chemical and biological reactions de-
compose part of the waste, part of it is
adsorbed, and part of it, consisting of
certain anionic inorganic fractions,
migrates without causing violations of
drinking water standards. For many
wastes, pretreatment is ~ e c e s s a r y be-
fore land treatment, to reduce the
amount of land required and to reduce
the amount of inorganic material in
the waste.
At present, ocean dumping of haz-
ardous wastes violates some interna-
tional accords. NAS and OTA note
that the scientific community does not
agree about the effects of ocean
dumping and recommend that much
more research be undertaken in this
area. Except for studies of very specific
materials in very specific areas, little
is known about the effects of hazard-
ous wastes on the ocean environment.
Both NAS and OTA suggest, however,
that ocean dumping be reconsidered
for certain wastes. They believe that
the ocean has the capacity to assimi-
late some kinds of hazardous materials
without harm to human health or
ocean life.
As wastes are treated by one or
more options in the hierarchy men-
tioned previously, their volume and
toxicity are reduced. NAS and OTA
agree that perpetual storage, the third
step in the hierarchy, should be used
for as few materials as possible. They
recommend that after wastes, have
passed through the first two steps in
the hierarchy, those nonreducible toxic
wastes that remain should be buried,
for the most part, in the deep subsur-
face, thereby isolating them from the
biosphere. NAS notes that in the past,
some wastes have been placed in
abandoned salt mines and subsurface
cavities. It reports that not enough
research has been done to evaluate the
safety of such disposal, but recom-
mends that with adequate research,
this method can probably be used.
NAS especially recommends investi-
gating the possibility of using the thick
unsaturated zones underlying parts of
the arid western U.S. These zones are
free of water and could provide a large
area for waste disposal. "The utility of
these zones may be pivotal in providing
a reasonable solution to the whole
problem of disposal of hazardous
waste," NAS reports. The committee
also suggests that an inventory of
possible permanent disposal sites be
made.
Risk assessment
No method of waste disposal is en-
tirely risk free. To determine the safest
treatment for each type of waste, both
NAS and OTA recommend the use of
risk assessment. OTA cautions, how-
ever, that it should be considered an
analytical tool for scientific input but
not a means of providing a final regu-
latory decision. It also cautions that
comparisons used in risk assessment
must include the nature and impact of
potential releases and not merely what
percent of the hazardous material is
removed or detoxified by the waste
FIGURE 1
The National Academy of Sciences recommends that wastes be'treated by one or more of three general methods
comprising the treatment hierarchy
In-plant options
Process Recycle and
manipulation reuse
I-
Conversion of hazardous to less hazardous or nonhazardous
Land Thermal
Chemical, Ocean and
treatment
Incineration
treatment
physical and atmospheric
biological assimilation

Perpetual storage
if
Underground Waste Surface Salt
Arid region
Landfill
injection piles impoundments formations
unsaturated
zone
Source: "Management of Hazardous Industrial Wastes: Research and Development Neec!s"; National Materials Advisory Board, Commission on Engineering and
Technical Systems, National Research Council; National Academy Press: Washington, D.C., 1983
Environ. Sci. Technol., Vol. 17, No.7, 1983 283A
TABLE 2
An example of a hierarchical fee system for hazardous
wastes based on the amount generated and the disposal
method
Creation of new sites
Both OTA and NAS point out that
the RCRA and Superfund legislation
are intimately related. Because the
materials that are removed from Su-
perfund sites are usually disposed of in
landfills, and landfills have inherent
problems no matter how well they are
designed, we may be creating new
Superfund sites in the process of
cleaning up the old ones. Furthermore,
landfills that are now active and run
according to regulations could become
future Superfund sites because no
specific compounds are banned from
them, and nearly all landfills will leak
at some time in the future. OTA notes
proach," OTA writes, "would be to
reward those who minimize future
risks and costs to society through the
use of preferred aJternatives which
permanently reduce the risks involved
in hazardous waste management."
Table 2 shows an example of a pro-
posed hierarchical fee system.
If the use of landfills were cut back
by a large fraction, many new waste
treatment facilities would be required.
OTA suggests that a federal loan
program could be instituted to provide
low-interest loans to finance these fa-
cilities. OTA also recognizes that
particularly difficult wastes would
require R&D efforts to develop eco-
nomic alternatives to landfill disposal.
It advocates government support of
private R&D projects in this area.
Currently, EPA's R&D budget for
hazardous waste disposal methods al-
lots only 10% to the development of
alternatives to landfills. Tn addition,
the total proposed 1984 budget for the
development of all hazardous waste
disposal methods is 27% lower than the
total in the estimated 1983 budget.
85
42
21
21
11
o
Tax on
liquid waste
(S/ton)
11
5
o
42
21
11
Tax on
solid waste
(S/ton) Waste management category
Land disposal
Off-site:
Land disposal after treatment
Treatment
On-site:
Land disposal after treatment
Treatment
Recycling/reuse; used crankcase oil
Source: Minnesota Conference Report H.F. No. 1176, March 19, 1982.
under Superfund, there exist more
than 80 000 contaminated surface
impoundments (pits, ponds, and la-
goons) in the nation. The potential
threat of drinking water contamination
is posed by at least 90% of these, ac-
cording to an unpublished EPA report.
There are few regulations for the
control, monitoring, or cleanup of
these sites.
The OTA study recommends a
number of regulatory changes that
would close most of these loopholes. It
recommends that the total exemption
for hazardous wastes burned as fuel be
ended. It also suggests that regulatory
criteria should be established for haz-
ardous wastes that do not fit EPA's
current definition of toxic but are im-
plicated as hazardous by a substantial
body of scientific information (such as
those having significant levels of
dioxins or chlorinated organics). In
addition, it states that certain haz-
ardous wastes should be entirely
banned from landfills, surface im-
poundments, and deep wells. EPA
should be required to prepare a list of
such wastes, OTA reports. (On March
17, 1983, EPA proposed two new rules
that will close some of these loop-
holes.)
Other regulatory changes that
would discourage the use of landfills
are also suggested. At present, Su-
perfund is financed by a fee on chem-
ical feedstocks, a so-called front-end
fee. This fee provides industry with no
incentive to reduce the volume of waste
produced. OTA suggests that the Su-
perfund monies be collected from a
tail-end fee-a fee on the amount of
waste produced. This fee would not be
fixed for all wastes, but would vary
according to the disposal method. "The
underlying philosophy of this ap-
treatment system. OTA is especially
critical of two risk assessment models
developed by EPA to apply to the Su-
perfund law and RCRA. The as-
sumptions on which these models are
based are so simplistic, OTA claims,
"that their usefulness is questionable.
For example, both models incorporate
a concept that can result in unequal
protection of some segments of the
public," such as those who live in areas
with a low population density.
OTA and NAS agree that many
technically feasible methods of man-
aging wastes are not being employed
to their fullest potential. They recom-
mend that regional centralized facili-
ties for waste treatment be built. Such
facilities would separate the wastes
according to treatment class and
manage each in the most effective way.
For small and medium generators, who
may not be able to purchase the
equipment required for ideal waste
treatment, such facilities could provide
an economical and relatively safe
means of waste disposal. Examples of
successful centralized waste treatment
facilities in Europe, such as Kommu-
nekemi in Nyborg, Denmark, are
given. In Europe, landfills have been
almost entirely phased out as a method
of hazardous waste treatment.
Changes in regulations
The OTA report (see Table 1)
points out loopholes in current waste
regulations that leave certain hazard-
ous wastes entirely unregulated and
allow releases of hazardous waste to
the environment. RCRA does not
regulate small generators of hazardous
wastes-those that produce less than
1 metric ton/yo Some of the wastes
produced by small generators are
highly toxic and are placed in sanitary
landfills where no monitoring at all is
required to detect leaks into ground-
water. Wastes burned as fuel are also
unregulated. These are considered
recycled wastes and are not regulated
under RCRA. Some of them contain
highly' toxic materials that release
hazardous substances to the atmo-
sphere when burned. A third group of
unregulated wastes is one that is
omitted from EPA's definition. "A
number of industrial wastes containing
significant levels of dioxins, chlori-
nated organics or pesticides are not
now regulated as hazardous wastes
and cannot be shown to be toxic by
EPA's test for toxicity," the OTA
study says. It goes on to note that in
addition to the 15 000 uncontrolled
waste sites (Superfund sites) classified
under the Emergency and Remedial
Response Information System, created
284A Environ. Sci. Technol., Vol. 17, No.7, 1983
William T. Carnall, Editor
Argonne National Laboratory
Gregory R. Choppin, Editor
Florida State University
Reviews recent progress in plutonium
chemistry. Reports on fundamental re-
search as well as applied environmental
and process chemical research. Covers
physical-inorganic chemistry and
spectroscopy, solution chemistry and
behavior of plutonium in the aquatic en-
vironment, and separations chemistry.
Includes introductory chapter by Glenn
T. Seaborg, Nobel laureate and co-
discoverer of element 94 and numerous
radioactive isotopes.
,CONTENTS
PlutoniumChemistry: The Beginnings. Magnetic
Properties of Organometallic and Coordination
Compounds Reaction of Pu Metal with
Diiodoethane Bis(,u-hydroxo)tetraaqua-
diplutonium(JV) Sulfate Superconductivity and
Magnetism in Metallic Pu Systems Pu Halides
and Halogeno Complexes. Thermodynamics of
Pu-Noble Metal Compounds. Thermodynamic
Aspects of Pu-OSystem Hypostoichiometric Pu
Dioxide. x-Ray Photoemission Spectroscopy.
PuFs Gas Photophysics and Photochemistry
Measurement and Interpretation of Pu Spectra
Stability and Electronic Spectrumof CSPUF6 Pu
Solution Chemistry Pu(IV) Hydrous Polymer
Chemistry Pu Ions and Products of H20
Radiolysis. Stability Constants, Enthalpies, and
Entropies Photochemistry of Aqueous Pu Solu-
tions Behavior of Pu in Natural Waters. Aquatic
Chemistry of Pu Pu(IV) Ion in Carbonate-
Bicarbonate Solutions. Ground-Water Composi-
tion and Pu Transport Processes Overview of
Pu Process Chemistry. Pu Process Chemistry at
Rocky Flats Pyrochemical Processing of Pu
Pu Production and Purification at Los Alamos
Carbamoylmethylphosphoryl Derivatives Ap-
pendixes: Round Table Discussion; Pu Isotopes
Based on a symposium jointly sponsored
by the Divisions of Nuclear Chemistry and
and Analytical Chemistry of
the Amertcan Chemical Society
ACS Symposium Series No. 216
480 pages (1983) Clothbound
lC 83-6057 ISBN 0-8412-0772-0
US & Canada $51.95 Export $62.95
Order from:
American Chemical Society
Distribution Office Dept. 24
1155 Sixteenth St., N.W.
Washington, DC 20036
or CALL TOLL FREE 800-424-6747
and use your VISA or MasterCard.
that in 1985, (the year Superfund ex-
pires), more sites may need to be
cleaned up than are now listed under
Superfund as sites requiring attention. '
Also, the old Superfund sites may not
be adequately cleaned up even when
they are treated according to regula-
tions. Current laws for cleanup provide
no specific technical standard, such as
concentration limits, for the extent of
hazardous waste removal.
Key to progress
No other issue affecting society has
resulted in as wide a gap between the
beliefs held by the public at large and
the beliefs of scientists who are experts
in the field. Progress in solving the
hazardous waste problem rests in part
on bridging this gap.
"Public attitudes toward hazardous
industrial wastes and their disposal,'"
NAS notes, "include a number of
misconceptions." ,There is a "general
belief that hazardous waste generation
can be eliminated,. that waste dis-
charges can be avoided, and that waste
disposal can be risk free. " The public
also seems to believe that all hazardous
waste disposal technologies present the
same risks.
On the other hand, some of the
public's concerns about siting haz-
ardous waste facilities are valid. Under
current law, the community where the
facility is located bears the risk and is
subject to potential damages from such
facilities, although society as a whole
, enjoys the benefits (the products) as-
sociated with hazardous waste gener...
ation. Another problem is that the
public does not trust the government to
write good regulations or to enforce
them strictly. This concern may be
partially valid because hazardous
waste regulations may be inadequate,
and enforcement during the past few
years may have been lax.
Progress in siting hazardous waste
facilities and in developing and using
new technologies will thus depend on'
several factors. One of them is public
education to further an understanding
of the technical issues involved. An..
other is creating and enforcing con-
sistent regulations to protect both
present and future generations.
- Bette Hileman
Additional reading
"Technologies and Management Strategies for
Hazardous Waste Contro}"; Congress of the
United States, Office of Technology Assess-
ment, Washington, D.C., 1983.
"Management of Hazardous Industrial Wastes:
Research and Development Needs"; National
Materials Advisory Board, Commission on
Engineering and Technical Systems, National
Research Council; National Academy Press:
Washington, D.C., 1983
Charles G. Gebelein, Editor
Youngstown State University
David J. Williams, Editor
Xerox Corporation
Rudolph Deanin, Editor
Lowell University
Focuses on the ways polymers can be
used to construct efficient anddur-
able solar energy systems. Points out
the advantages in cost, weight, and
variety of polymers and describes the
problems of photodegradation. Sec-
tions include general solar applica-
tions, polymer photodegradation in
solar applications, and photovoltaic
and related applications.
CONTENTS
Applications and Opportunities Economics of
Solar Heating Systems Film and Laminate
Technology for Colfectors Stability of Poly-
merip Materials in the Collector Environment
Reduction of Solar Light Transmittance in Collec-
tors Optical, Mechanical, and Environmental
Testing of Collector Films Protective Coat-
ings and Sealants Reactivity of Polymers with
Mirror Materials IR Reflection-Absorbance of
Films on Metallic Substrates Adhes',ves in
Reflector Modules of Troughs Solar Ponds and
Liner Requirements Flexible Membrane lin-
ings for Solar Ponds Plastic Pipes for Ground-
Coupled Heat Pumps Prediction or Photoox-
idation of Plastics Photodegradation and Sorp-
tion and Transport of Water UV Microscopy of
Morphology and Oxidation. Novel Diagnostic
Techniques for Detection of Photooxidation
Photodegradation of Poly(n-butyl Acrylate)
Stability of UV-Screening Transparent Acrylic
Copolymers Deformation and Low-Density
Polyethylene Films Luminescent Solar Con-
centrators Encapsulation Materials for
Photovoltaic Modules Encapsulant Material
Requirements Encapsulant Degradation
Vacuum Lamination of Photovoltaic Modules
Polyacrylonitrile as a Photovo/taic Material
Polymeric Phthalocyanines Photophysics of
Doped Poly(2-Vinylnaphthalene) Films.
Catalysis with Polymer Electrodes
Based on a symposium sponsored by
the Divisions ofOrganic Coatings and
Plastics Chemistry and Polymer
Chemistry of the American Chemical
Society
ACS Symposium Series No. 220
510 pages (1983) Clothbound
LC ISBN
US & Canada $51.95 Export $62.95
Order from:
American Chemical Society
Distribution Office Dept. 27
1155 Sixteenth St., N.W.
Washington, DC 20036
or CALL TOLL FREE 800...4246747
I and use your VISA or MasterCard.
Environ. Sci. Technol., Vol. 17, No.7, 1983 285A

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