Hazardous Waste Control L3

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Hazardous waste controlAre we creating problems for future generations?

Every year approximately one tonof hazardous was te is added to theenvironment for each person in theU.S. Although there is some disagreement and uncertainty about theexact amount of hazardous wasteproduced annually, there is a generalconsensus that the quantity subject tofederal regulation is in the range of 30to 60 million tons. Hazardous wasteexempted from federal regulation bu tcovered by state regulations adds another 230-260 million tons, makingthe total number of tons comparable tothe population of this country (seeTable 1).Recently both the Office of Technology Assessment (OTA) and theNational Academy of Sciences (NAS)published reports on the managementof hazardous wastes. Although theserepor ts do not have the same focus,there is a striking similarity in theopinions and ideas contained in them.(The NAS report is oriented towardthe required control technologies,whereas the OTA report focusessomewhat more on changes in regulations that might improve hazardouswaste control.)According to these reports, as muchas 80% ofthe 260-320 million tons ofhazardous waste produced annually isdisposed of in or on the land. Many ofthe hazardous materials placed inlandfills are highly toxic and remainhazardous for hundreds of years. Thecommittee that prepared the NASreport decided that "at least 500 yearsis realist ic as a per iod of concern forhazardous wastes in landfills. . . . "Regulations under the ResourceConservat ion and Recovery Act(RCRA), however, require monitoringfor only 30 years after a landf il l isclosed. Therefore, it could begin to leaktoxic substances during the centuriesfollowing its shutdown, and t he leakwould not be detected by legal ly required monitoring.

Also, there is a scientific consensusth at no matter how well a landf il l isdesigned, no matter what the liner andcap are made of, the landfill eventuallywill leak. As the OTA report states,"even with new stricter RCRA regulations in place, eventual releases ofhazardous constituents from landdisposal facilities are highly probable."The NAS publication also concludesthat with time, the surface cover overa landfill can be penetrated and mobileconstituents can leak to groundwater.Thus, both s tudies conclude thatlandfills appear to be an inexpensivemethod of waste disposal, but becausethey require monitoring and maintenance for hundreds of years, theyt ransfer part of the cost of waste disposal to future generations. Eventually, 30 or 100 or 200 years la ter-whenever the l andf il l beg ins toleak-more money will be spent tocontrol hazardous releases and contain

the wastes. These costs will be borne bygovernment or by society in generalinstead of by the generator. The 30year postclosure monitoring requirement hides the true cost of long-termcare.Besides the too-short postclosuremonitoring requirement, the OTA andNAS reports say that existing regulations for landfills contain other deficiencies. Stringent monitoring is notrequired even while the landfill is inoperation. The regulations requiremerely that four ambient groundwatersamples be taken fOUf times a year. Noair monitoring is required to determineif emissions of volatile organic compounds pose a health hazard. Retrofit ting to meet new standards, such asthe installation of a liner, is not required at existing active landfills, noris i t required for those portions of existing landfills that do not yet containwaste. 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


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TABLE 1Examples of hazardous wastes exempted from federal regulationEstimated

annual generation DeterminedWaste type (mil l ion met r ic tons) Possible hazard by

Fly and bottom ash from burning fossil fuels 66 Trace toxic metals RCRAFuels gas emission control waste Unknown Toxic organics and inorganics RCRAMining waste, including radioactive waste 2100 Toxic metals, acidity, radioactivity RCRADomestic sewage discharged into publicly owned 5 Uncertain, toxic metals likely RCRAtreatment worksCement kiln dust 12 Alkalinity, toxic metals RCRAGas and oil drilling muds and production waste; Unknown Alkalinity, toxic metals, toxic RCRAgeothermal energy waste organics, salinityNPDES-permitted industrial discharge Unknown Toxic organics, heavy metals RCRAIrrigation return flo.ws Unknown Pesticides, fertilizers RCRAWaste burned as fuels 19 Unburned toxic organics EPAWaste oil Unknown Toxic organics, toxic metals EPAInfectious waste Unknown Infectious materials EPASmall-volume generators 2.7-4.0 Possibly any hazardous waste EPAAgricultural waste Unknown Variable EPAWaste exempted under delisting petitionsa Unknown Presumably insignificant EPADeferred regulations Unknown Unknown EPAEPA deregulation Unknown Presumably insignificant EPAToxicity test exemptions b Unknown Organics EPARecycled 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 hazardousconstituents may be present that have previously been unrecognized administratively.b Wastes not identif ied astoxic by the EPA extraction procedure test and not otherwise listed by EPAC Legitimate recycling is exempt fromRCRA regulations except for storage. However, there have been numerous incidents, such as the dioxin casein Missouri, involving recycled materials that are still hazardous.Source: Adapted from "Technologies and Management Strategies for HazardousWaste Control"; U.S. Congress, Office of Technology Assessment,Washington, D.C. 20510

protecting drinking water supplies aremandated in regulations for siting newlandfills.Hidden costs

Both NAS and OTA conclude thatlax policies regarding landfills makethem more economical than other alternatives and encourage industry touse them for nearly all its wastes. I findustry had to pay the true cost oflandfill disposal-the cost of containing the wastes over hundreds ofyears-it would be far more inclinedto use other methods. Alternatives toland disposal could cost 50-100%moretoday than current disposal costs. Butcleaning up newly created sites yearsfrom now might cost 10-100 times thisadditional outlay.NAS and OTA advocate minimaluse of landfills and changes in regulations that will encourage the use ofother methods of disposal. Currentregulations, they say, provide disincentives for other disposal methods.Neither report states, however, thatlandfills can be eliminated entirely asa method of hazardous waste disposal.Both conclude that even with ideal282A Environ. Sci. Technol., Vol. 17, No.7, 1983

waste disposal treatment methods,some wastes would have to be disposedof on land. But they agree that theamount of waste placed in landfills canbe reduced drastically.Hierarchy of optionsRather than relying almost exclusivelyon land disposal, OTA and NASpropose that a hierarchy of options beused. "There are basically three general options," NAS writes, "Elimination [or reduction] or reuse of thehazardous waste, conversion of the

hazardous waste into nonhazardous orless hazardous material, and perpetualstorage." These options and generalmethods for achieving them are diagramed in Figure 1.Neither OTA nor NAS believesthat there is a panacea for all hazardous wastes. But NAS considers thefirst general set of options, which itcalls in-plant options, "probably themost economical and effective meansof managing hazardous wastes." Included in this category are processmodifications, such as alter ing thechemistry or certain other aspects ofengineering operations, and recycling

and reuse of the hazardous by-products. For certain wastes, processmodif icat ions do not eliminate thewastes entirely but reduce their volumeor degree of hazard. For example,modificat ions to the mercury electrolysis cell have resulted in reductionsin the major types of waste producedby the chloralkali industry.For the wastes that are not eliminated by in-plant options, NAS advo

c a t e s t h a t t h ~ s e c o n d s e t o f o p t i o n s b eused-conversion of the hazardouswaste into nonhazardous or less hazardous material. The NAS committeemembers evaluated the state of development of the different methods in thiscategory and pointed out researchneeds in each area. Although chemicaland physical techniques could be used,in principle, to dispose of any hazardous waste, these methods would be tooexpensive for some wastes. The committee recommends that much additional research be performed in thisarea, such as: cont inued experimental determination of various hazardous wastespecies and mixtures;

further development of processes


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to remove metals from industrial wastestreams; further development of separationprocesses based on supercritical fluids,liquid membranes, an d foam fractionation; an d development of a low-cost processto remove water from slimes an dsludges.A large n u mb e r o f biological treat-ment processes exist that use indigenous or adapted microbes to remove ordetoxify wastes. N AS recommendsthat genetic engineering might beconsidered as a method to develop newspecies for this purpose.At present, incineration provides themost complete means of disposing of

many organic materials. NA S pointsout, however, that incineration hascertain drawbacks. For example, itoften requires emission controls an dsampling an d analysis of incinerationproducts. I f inorganic materials ar epresent in th e waste, slag an d ash ar eproduced as end products and must bedisposed of.Unlike incineration, which requiresan open flame, thermal methods useheat to treat hazardous waste. N ASmentions a n um be r o f techniques forthis purpose: c at al yt ic a n d reactivefluidized bed systems, molten salt reactors, plasma arcs an d torches, microwave systems, an d pyrolytic processes.-The only thermal method thathas been used widely in industry is thepyrolytic process.Land treatment (which is distinctfrom landfilling) is another methodthat has broad potential, according to

NAS. In land treatment, the top layerof soil, approximately 1 ft, is mixedwith the waste. Then, theoretically,chemical and biological reactions decompose p ar t o f the waste, part of it isadsorbed, a nd p ar t of it, consisting ofcertain anionic inorganic fractions,migrates without causing violations ofdrinking water standards. For manywastes, pretreatment is ~ e c e s s a r y before land treatment, to reduce theamount of land required and to reducethe amount of inorganic material inthe waste.At present, ocean dumping of hazardous wastes violates some international accords. NAS and OTA notethat the scientific community does notagree ab ou t the effects of oceandumping and recommend that muchmore research be under taken in thisarea. Except for studies of very specificmaterials in very specific areas, littleis known about the effects of hazard-ous wastes on the ocean environment.Both NA S and OT A suggest, however,that ocean dumping be reconsideredfor certain wastes. They believe thatthe ocean has the capacity to assimilate some kinds of hazardous materialswithout harm to human health orocean life.As wastes ar e treated by one ormore opt ions in the hierarchy mentioned previously, their volume an dtoxicity ar e reduced. NA S and OTAagree that perpetual storage, the thirdstep in the hierarchy, should be usedfor as few materials as possible.Theyrecommend that after wastes, havepassed through the first two steps in

the hierarchy, those nonreducible toxicwastes that remain should be buried,for the most part, in the deep subsurface, thereby isolating them from thebiosphere. NA S notes that in the past,some wastes have been placed inabandoned salt mines an d subsurfacecavities. It reports that not enoughresearch has been done to evaluate thesafety of such disposal, bu t recommends that with adequate research,this method can probably be used.NA S especially recommends investigating the possibility of using the thickunsaturated zones underlying parts ofth e arid western U.S. These zones ar efree of water and could provide a largearea for waste disposal. "The utility ofthese zones may be pivotal in providinga reasonable solution to th e wholeproblem of disposal of hazardouswaste," NA S reports. Th e committeealso suggests that an inventory ofpossible permanent disposal sites bemade.Risk assessment

No method of waste disposal is entirely risk free. To determine the safesttreatment for each type of waste, bothNAS an d OTA recommend the use ofrisk assessment. OT A cautions, however, that it should be considered ananalytical tool for scientific input bu tnot a means of providing a final regulatory decision. It also cautions thatcomparisons used in risk assessmentmust include the nature and impact ofpotential releases and not merely whatpercent o f th e hazardous material isremoved or detoxified by th e waste

FIGURE 1The National Academy of Sciences recommends that wastes be'treated by one or more of three general methodscomprising the treatment hierarchyIn-plant options

Process Recycle andmanipulation reuse

I-Conversion of hazardous to less hazardous or nonhazardous

Land Thermal Chemical, Ocean andtreatment Incineration treatment physical and atmosphericbiological assimilationerpetual storageifUnderground Waste Surface Salt Arid regionLandfill injection piles impoundments formations unsaturatedzone

Source: "Management of Hazardous Industrial Wastes: Research and Development Neec!s"; National Materials Advisory Board, Commission on Engineering andTechnical Systems, National Research Council; National Academy Press: Washington, D.C., 1983

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TABLE 2An example of a hierarchical fee system for hazardouswastes based on the amount generated and the disposalmethod

Creation of new sitesBoth OTA and NAS point out that

the RCRA and Superfund legislationare intimately related. Because thematerials that are removed from Superfund sites are usually disposed of inlandfills, and landfills have inherentproblems no matter how well they aredesigned, we may be creating newSuperfund sites in the process ofcleaning up the old ones. Furthermore,landfills that are now active and runaccording to regulations could becomefuture Superfund sites because nospecific compounds are banned fromthem, and nearly all landfills will leakat some time in the future. OTA notes

proach," OTA writes, "would be toreward those who minimize futurerisks and costs to society through theuse of preferred aJternatives whichpermanently reduce the risks involvedin hazardous waste management."Table 2 shows an example of a proposed hierarchical fee system.

If the use of landfills were cut backby a large fract ion, many new wastetreatment facilities would be required.OTA sugges ts that a federal loanprogram could be instituted to providelow-interest loans to finance these facilities. OTA also recognizes thatparticularly difficult wastes wouldrequire R&D efforts to develop economic alternatives to landfill disposal.It advocates government support ofprivate R& D projects in this area.Currently, EPA's R&D budget forhazardous waste disposal methods allots only 10% to the development ofalternatives to landfills. Tn addition,the total proposed 1984 budget for thedevelopment of all hazardous wastedisposal methods is 27% lower than thetotal in the estimated 1983 budget.

85

4221

2111o

Tax onliquid waste(S/ton)

115o

42

2111

Tax onsolid waste(S/ton)aste management category

Land disposalOff-site:

Land disposal after treatmentTreatment

On-site:Land disposal after treatmentTreatment

Recycling/reuse; used crankcase oilSource: Minnesota Conference Report H.F. No. 1176, March 19, 1982.

under Superfund, there exist morethan 80 000 contaminated surfaceimpoundments (pits, ponds, and lagoons) in the nation. The potentialthreat of drinking water contaminationis posed by at least 90% of these, according to an unpublished EPA report.The re are few regulat ions for thecontrol, monitoring, or cleanup ofthese sites.The OTA study recommends anumber o f regu la tory changes thatwould close most of these loopholes. Itrecommends that the total exemptionfor hazardous wastes burned as fuel beended. It also suggests that regulatorycriteria should be established for hazardous wastes that do not fit EPA'scurrent definition of toxic but are implicated as hazardous by a substantialbody of scientific information (such asthose having s igni ficant levels ofdioxins or chlorinated organics). Inaddition, it states that certain hazardous wastes should be entirelybanned from landfills, surface impoundments, and deep wells. EPAshould be required to prepare a list ofsuch wastes, OTA reports. (On March17, 1983, EPA proposed two new rulesthat will close some of these loopholes.)

Other regulatory changes thatwould discourage the use of landfillsare also suggested. At present, Superfund is f inanced by a fee on chemical feedstocks, a so-called front-endfee. This fee provides industry with noincentive to reduce the volume of wasteproduced. OTA suggests that the Super fund monies be collected from atail-end fee-a fee on the amount ofwaste produced. This fee would not befixed for all wastes , but would varyaccording to the disposal method. "Theunderlying philosophy of this ap-

treatment system. OTA is especiallycritical of two risk assessment modelsdeveloped by EPA to apply to the Superfund law and RCRA. The assumptions on which these models arebased are so simplistic, OTA claims,"that their usefulness is questionable.For example, both models incorporatea concept t ha t can result in unequalprotection of some segments of thepublic," such as those who live in areaswith a low population density.OTA and NAS agree that manytechnically feasible methods of managing wastes are not being employedto their fullest potential. They recommend that regional centralized facilities for waste treatment be built. Suchfacilities would separate the wastesaccording to treatment class andmanage each in the most effective way.For small and medium generators, whomay not be able to purchase theequipment requi red for ideal wastetreatment, such facilities could providean economical and relatively safemeans of waste disposal. Examples ofsuccessful centralized waste treatmentfacilities in Europe, such as Kommunekemi in Nyborg, Denmark, aregiven. In Europe, landfills have beenalmost entirely phased out as a methodof hazardous waste treatment.Changes in regulations

The OTA report (see Table 1)points ou t loopholes in current wasteregulations that leave certain hazardous wastes entirely unregulated andallow releases of hazardous waste tothe environment. RCRA does notregulate small generators of hazardouswastes-those that produce less than1 metric ton/yo Some of the wastesproduced by small generators arehighly toxic and are placed in sanitarylandfills where no monitoring at all isrequired to detect leaks into groundwater. Wastes burned as fuel are alsounregula ted. These a re consideredrecycled wastes and are not regulatedunder RCRA. Some of them containhighly' toxic materials that releasehazardous substances to the atmosphere when burned. A third group ofunregulated wastes is one that isomitted from EPA's definition. "Anumber of industrial wastes containingsignificant levels of dioxins, chlorinated organics or pesticides are notnow regulated as hazardous wastesand cannot be shown to be toxic byEPA's t es t for toxici ty," the OTAstudy says. It goes on to note that inaddition to the 15 000 uncontrolledwaste sites (Superfund sites) classifiedunder the Emergency and RemedialResponse Information System, created284A Environ. Sci. Technol., Vol. 17, No.7, 1983


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William T. Carnall, EditorArgonne National LaboratoryGregory R. Choppin, EditorFlorida State UniversityReviews recent progress in plutoniumchemistry. Reports on fundamental re-search aswell as applied environmentaland process chemical research. Coversphysical-inorganic chemistry andspectroscopy, solution chemistry andbehaviorof plutonium in the aquatic environment, and separations chemistry.Includes introductory chapter by GlennT. Seaborg, Nobel laureate and codiscovererof element 94 and numerousradioactive isotopes.,CONTENTSPlutoniumChemistry: The Beginnings. MagneticProperties of Organometallic and CoordinationCompounds Reaction of Pu Metal withDiiodoethane Bis(,u-hydroxo)tetraaquadiplutonium(JV) Sulfate Superconductivity andMagnetism in Metallic Pu Systems Pu Halidesand Halogeno Complexes. Thermodynamics ofPu-Noble Metal Compounds. ThermodynamicAspects ofPu-O System Hypostoichiometric PuDioxide. x-Ray Photoemission Spectroscopy.PuFs Gas Photophysics and Photochemistry Measurement and Interpretation of Pu Spectra Stability and Electronic Spectrumof CSPUF6 PuSolution Chemistry Pu(IV) Hydrous PolymerChemistry Pu Ions and Products of H20Radiolysis. Stability Constants, Enthalpies, andEntropies Photochemistryof Aqueous Pu Solutions BehaviorofPuin NaturalWaters. AquaticChemistry of Pu Pu( IV) Ion in CarbonateBicarbonateSolu tions. Ground-Water Composition and Pu Transport Processes Overview ofPu ProcessChemistry. Pu ProcessChemistryatRocky Flats Pyrochemical Processing of Pu Pu Production and Purification at Los Alamos Carbamoylmethylphosphoryl Derivatives Ap-pendixes: Round Table Discussion; Pu IsotopesBased on a symposium jointly sponsoredby the Divisions of Nuclear Chemistry and

T e c h n o l o ~ y and Analytical Chemistry ofthe Amertcan Chemical SocietyACS Symposium Series No. 216480 pages (1983) ClothboundlC 83-6057 ISBN 0-8412-0772-0US & Canada $51.95 Export $62.95Order from:American Chemical SocietyDistribution Office Dept. 241155 Sixteenth St., N.W.Washington, DC 20036or CALL TOLL FREE 800-424-6747and use your VISA or MasterCard.

that in 1985, (the year Superfund expires), more sites may need to becleaned up than are now listed underSuperfund as sites requiring attention. 'Also, the old Superfund sites may notbe adequately cleaned up even whenthey are treated according to regulations. Current laws for cleanup provideno specific technical standard, such asconcentration limits, for the extent ofhazardous waste removal.Key to progress

No other issue affecting society hasresulted in as wide a gap between thebeliefs held by the public at large andthe beliefs of scientists who are expertsin the field. Progress in solving thehazardous waste problem rests in parton bridging this gap."Public attitudes toward hazardousindustrial wastes and their disposal,'"NAS notes, " include a number ofmisconceptions." ,There is a "generalbelief that hazardous waste generationcan be eliminated,. that waste discharges can be avoided, and that wastedisposal can be risk free." The publicalso seems to believe that all hazardouswaste disposal technologies present thesame risks.On the othe r hand, some of thepublic's concerns about siting hazardous waste facilities are valid. Undercurrent law, the communitywhere thefacility is located bears the risk and issubject to potential damages from suchfacilities, although society as a whole, enjoys the benefits (the products) associated with hazardous waste gener...ation. Another problem is that thepublic does not trust the government towrite good regulations or to enforcethem stric tly. This concern may bepart ia lly valid because hazardouswaste regulations may be inadequate,and enforcement during the past fewyears may have been lax.Progress in siting hazardous wastefacilities and in developing and usingnew technologies will thus depend on'several factors. One of them is public

education to further an understandingof the technical issues involved. An ..other is creating and enforcing cons is tent regulations to protect bothpresent and future generations.- Bette Hi lemanAdditional reading"Technologies and Management Strategies forHazardousWaste Contro}"; Congressof theUnited States, Office of Technology Assessment, Washington, D.C., 1983."Management of Hazardous Industrial Wastes:Research and Development Needs"; NationalMaterials Advisory Board, Commission onEngineering and Technical Systems, NationalResearch Council; National Academy Press:

Washington, D.C., 1983

Charles G. Gebelein, EditorYoungstown State UniversityDavid J. Williams, EditorXerox CorporationRudolph Deanin, EditorLowell UniversityFocuses on the ways polymers can beused to construct efficient anddur-able solar energy systems. Points outthe advantages in cost, weight, andvariety of polymers and describes theproblems of photodegradation. Sections include general solar applications, polymer photodegradation insolar applications, and photovoltaicand related applications.CONTENTSApplications and Opportunities Economics ofSolarHeatingSystems Film and LaminateTechnology for Colfectors Stabilityof Poly-merip Materials in the Collector Environment Reduction of Solar Light Transmittance in Collectors Optical, Mechanical, and EnvironmentalTesting of Collector Films ProtectiveCoat-ings and Sealants Reactivityof Polymers withMirrorMaterials IRReflection-Absorbance ofFilms on Metallic Substrates Adhes',vesinReflector Modulesof Troughs Solar Ponds andLiner Requirements Flexible Membrane lin-ings for SolarPonds Plastic Pipes for GroundCoupled Heat Pumps Prediction or Photooxidation of Plastics Photodegradation and Sorption and Transportof Water UV Microscopy ofMorphologyandOxidation. NovelDiagnosticTechniques for Detection of Photooxidation Photodegradation of Poly(n-butyl Acrylate) Stability of UV-Screening Transparent AcrylicCopolymers Deformation and Low-DensityPolyethylene Films Luminescent SolarConcentrators Encapsulation Materials forPhotovoltaic Modules Encapsulant MaterialRequirements Encapsulant Degradation Vacuum Lamination of Photovoltaic Modules Polyacrylonitrileas a Photovo/taic Material Polymeric Phthalocyanines Photophysics ofDoped Poly(2-Vinylnaphthalene) Films.Catalysis with Polymer ElectrodesBased on a symposium sponsoredbythe Divisions ofOrganic Coatings andPlastics ChemistryandPolymerChemistryof theAmerican ChemicalSocietyACS Symposium Series No. 220510 pages (1983) ClothboundLC 8 3 ~ 6 3 6 7 ISBN 0 - 8 4 1 2 - 0 7 7 6 ~ 3US & Canada $51.95 Export $62.95Order from:American Chemical SocietyDistribution OfficeDept. 271155 Sixteenth St., N.W.Washington, DC 20036or CALL TOLL FREE 800...4246747

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Environ. Sci. Technol., Vol. 17, No.7, 1983 285A

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Hazardous Waste Control L3