BASIC HAZARDOUS WASTE MANAGEMENT - CHAPTER 1 potx

He developed and presented a program of seminars on hazardous waste management, underground storage tank management, emergencyplanning, and regulation of hazardous materials transportati

WASTE MANAGEMENT

Third Edition

BASIC HAZARDOUS WASTE MANAGEMENT

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Blackman, William C.

Basic hazardous waste management / William C Blackman, Jr. 3rd ed.

p cm.

Includes bibliographical references and index.

ISBN 1-56670-533-9 (alk paper)

1 Hazardous wastes—United States—Management I Title.

TD1040 B53 2001

As the demand for a clean, safe environment grows, so also grows the public demandfor protection from the health hazards and environmental horrors of hazardous wastemismanagement Entrepreneurs of industry and commerce provide daily evidence

of the general awakening to the need for reduction or elimination of hazardous wastesources and better management of the wastes that are generated However, the ever-present drive for new product advantage, competition, budget and capital restraints,and the activities of those who have not yet accepted their environmental responsi-bilities continue to threaten our environmental well-being Meanwhile the “not in

my backyard” (NIMBY) syndrome has reached the point that almost no site isacceptable as a hazardous waste treatment or disposal facility This clash of imper-atives must be dealt with We, as a people, cannot permit further episodes ofuncontrolled release of hazardous materials/waste to threaten us We, as a first-worldsociety, cannot tolerate the continuing aftermath of our history of uncontrolledhazardous waste disposal However, we, as a viable, self-supporting nation, cannotafford to force industry and commerce to their collective knees in the name ofenvironmental purity

The national conscience, as expressed in the form of research, technologicaladvances, legislative craft, regulatory issue, fiscal support, and public participation,has brought forth great improvement in our hazardous waste management practice.However, most of the easy achievements have been realized As we embark uponthe Third Millennium, the priorities and demands placed upon environmental man-agers are ever more complex, urgent, and broad in scope For example, exposurestandards for toxic or hazardous chemicals are progressively made more restrictive,but pressures increase for less expensive and intrusive cleanup procedures for sitescontaminated with these chemicals Regulatory agencies seek to eliminate the use

of particularly objectionable materials, while the industries traditionally forming theU.S industrial and labor base, seeking less restrictive operating conditions, flee toneighboring and third-world countries New generations of hazardous waste man-agers must acquire a broad-scope understanding of competing interests in scientific,technological, engineering, administrative, political, public health, and environmen-tal issues and the innovations that must be conceived and implemented in order toreconcile these imperatives

Our traditional approach to the education of future environmental technologistsand managers has guided the undergraduate through a basic skill curriculum, then

to be followed by a graduate program in engineering or a science This text isintended to provide an introductory framework which can be the foundation for aprogram of study in traditional as well as modern hazardous waste management or

a component of a related program It is in an overview format, with many references

to more detailed materials, to assist the student or instructor in expansion upon

specific topics or to flesh out complex issues The instructor is encouraged to expandupon issues or topics to meet the perceived needs of students, regions, or industries.Topics for discussion or review are provided at the end of each chapter.

ORGANIZATION AND CONTENT

The first eleven chapters deal with the topics, impacts, technologies, problems, andissues associated with “conventional” hazardous wastes and the management prac-tices and statutory and regulatory controls which have evolved around them Chapters

12 through 14 introduce the closely related medical/infectious waste, undergroundstorage tank, and radioactive waste management technologies and practices Chapter

15 introduces the hazardous waste worker health and safety issues and regulatorystructures that have become a major focal point and concern for managers andsupervisors of hazardous waste facilities and sites

Objectives are stated as the first element of each chapter Insofar as is possible

or appropriate, the chapters are structured to first outline the issue, subject, ortechnology, then to describe generic practice, and to then conclude with a summary

of the statutory and/or regulatory approach Historical perspective is provided whereappropriate to locale, industry, or other emphasis The reader who is unfamiliar with

examine these two entries in the Glossary before proceeding with the regulatorymaterial covered in the book

R Jenkins, R.N., of the Environmental Resource Center, Fayetteville, NC — thechapter on medical and infectious waste management; Mr Arthur C Gehr, Esq.,partner in the firm Snell and Wilmer, Phoenix, AZ — the radioactive waste man-agement chapter; and Ms Lisa Lund, then Manager, Underground Storage TankCompliance Section, Arizona Department of Environmental Quality, and later Dep-uty Director, Office of Underground Storage Tank Programs, U.S EnvironmentalProtection Agency — the underground storage tank management chapter Mr Harold

L Berkowitz, chemical engineer, consultant, and faculty associate of the Department

of Manufacturing and Industrial Technology, Arizona State University, providedextensive input and improvements to the new chapter on hazardous waste workerhealth and safety The valuable assistance of all of the reviewers is deeply appreci-ated Many of their respective contributions are retained in the third edition.Without the editing and word-processing skills as well as the extraordinarypatience of Ms Cindy Zisner, M.S., and the graphic skills of Mr Steve Scott, thesemonths of work on the new edition would have been much less pleasant Ms Zisner

is a private practitioner in Tempe, AZ Mr Scott practices in Pasadena, CA Mr JayCarr of the Dallas Morning News also made a valued contribution in the graphicpresentation of the Yucca Mountain Repository I sincerely appreciate the time andeffort of the many contributors of photographic materials The illustrations for which

no acknowledgment is made are either my own or have been provided to me onearlier occasions I can only apologize for lack of adequate memory regarding thesources of the earlier contributions

The Author

William C Blackman, Jr. is an Environmental Engineer

and Professor Emeritus of the Center for Environmental

Studies, Arizona State University Professor Blackman

was previously a career engineer and manager assigned

to enforcement programs of the U.S Environmental

Pro-tection Agency and predecessor agencies As Technical

Coordinator and Deputy Director of the EPA National

Enforcement Investigations Center, he planned and

directed early hazardous waste site investigations and

par-ticipated in the development of the site investigation

tech-niques and site health and safety procedures which have

become standard practice

In 1985 he was appointed Assistant Director, Arizona

Department of Environmental Quality, where he managed

state and federal RCRA and Superfund programs He joined the ASU faculty in

1989, teaching undergraduate and graduate courses in hazardous waste managementand control of toxic air pollutants He developed and presented a program of seminars

on hazardous waste management, underground storage tank management, emergencyplanning, and regulation of hazardous materials transportation He directed ASUparticipation in the California-Arizona Consortium, presenting OSHA health andsafety training for hazardous waste workers and underground storage tank workers

He continues to research and lecture in these programs

Professor Blackman received his B.S in Civil Engineering and M.S in SanitaryEngineering from the University of Missouri at Columbia, his MPA (EnvironmentalManagement) from the University of Southern California at Los Angeles, and hisDPA (Environmental Management and Public Policy) from the University of Colorado

at Denver He is a Registered Professional Engineer and a U.S Army Reserve SanitaryEngineer Colonel He has published a number of papers on water quality and pollutioncontrol, and on hazardous waste site investigations and safety procedures

Table of Contents

Chapter 1 The Hazardous Waste Perspective

Objectives

Introduction

Dawning of the Problem

Early Hazardous Waste Management

“Take It Out Back and Dump It”

“Treatment” and Other Assorted TechniquesNumbers and Impacts

Early Efforts — What Worked/Didn’t Work

Legislation/LitigationPolitical

AdministrativeTechnicalInternational AspectsTopics for Review or Discussion

Topics for Review or Discussion

References

Chapter 3 Pathways, Fates, and Disposition of Hazardous Waste

ReleasesObjectives

Introduction

Releases of Chemicals to the Environment

Releases to the Atmosphere

Releases to Surface Waters

Releases to Land

Movement, Fates, and Disposition

Behavior of Waste Constituents Released to the AtmosphereMovement of Hazardous Waste Constituents in SurfaceWaters

Pathways of Hazardous Waste Constituents ReachingGroundwater

The Generator Defined

The Three Classifications of Generators

Generator Responsibilities for Restricted Waste ManagementGenerator Requirements

Topics for Review or Discussion

Modes and Scope of Hazardous Waste Transportation

Highway Shipment of Hazardous Wastes

Railway Shipment of Hazardous Wastes

Accidents/Incidents Involving Hazardous Waste ShipmentsRegulatory Structures

Department of Transportation Regulations

Transportation Incidents Involving Hazardous WastesRCRA Regulations for Hazardous Waste TransportersEPA ID Number

Administrative and Nontechnical Requirements

Subpart A — Facilities That Are Subject to the RegulationsSubpart B — General Facility Standards

Subpart C — Preparedness and Prevention

Subpart D — Contingency Plan and Emergency ProceduresSubpart E — Manifest System, Record Keeping, andReporting

General Technical Standards for Interim Status and PermittedFacilities

Part 265, Subpart F — Groundwater Monitoring

Part 264, Subpart F — Releases from Solid Waste

Management Units

Subpart G — Closure, Post-Closure

Subpart H — Financial Requirements

Hazardous Waste Treatment

Activated Carbon Adsorption

Stripping

Neutralization

Precipitation

Stabilization and Solidification

Oxidation and Reduction

Biological Treatment

Subpart Q — Chemical, Physical, and Biological TreatmentDestruction of Hazardous Wastes by Thermal Processes Subpart O — Hazardous Waste Incinerators

Subpart P — Thermal Treatment of Hazardous wasteAccumulation and Storage of Hazardous Waste

Subpart I — Containers

Subpart J — Tanks

Subpart DD — Storage in Containment Buildings

Land Disposal of Hazardous Waste

Subpart R — Underground Injection

Other Treatment and Disposal Methods

Ocean Dumping

Ocean Incineration

Land Disposal Restrictions

Topics for Review or Discussion

Appendix A: MACT Emission Standards for Hazardous Waste

Hazardous Waste Recycling

Use and ReuseReclamation Multi-Conceptual Approaches

The RCRA Hazardous Waste Minimization Program

RCRA Regulation of Recycling

EPA Implementation of The Pollution Prevention Act (PPA)

of 1990

Topics for Review or Discussion

Appendix A: State Agency P2 Linkages and Resources

Appendix B: P2 Information, Concepts, and Linkages

The Permitting Process

The “Permit As a Shield”

Closure Plans and Post-Closure Permits

RCRA Permits As a “Virtual Elimination” Tool

The Corrective Action Process

Remediation Waste Management Units

Compliance Requirements of RCRA

Self-Monitoring

Inspections

Enforcement of RCRA Regulations

Informal Administrative Actions

Formal Administrative Orders

Environmental Management Systems

Compliance Inspections/Investigations by Regulatory AgenciesPurpose

The Inspection Plan

Conduct of the Inspection/Investigation

Site Evaluation

National Priorities List

Hazard Ranking System

Remedial Investigation/Feasibility Study

Record of Decision

Negotiations, Enforcement

Topics for Review or Discussion

Appendix A: ASTM Standard Practice for Environmental Site Assessments:Phase I Environmental Site Assessment Process (Appendix x2)

Mechanical and Hydraulic Dredging

RCRA and Superfund Remedial Actions

RCRA Corrective Actions

Superfund Remedial Actions

Superfund Accelerated Cleanup Model

Brownfields Economic Redevelopment Initiative and

Environmental Justice

Topics for Review or Discussion

Infectious Waste Management

Designation of Infectious Waste

Segregation of Infectious Waste

Packaging of Infectious Waste

Storage of Infectious Waste

Transport of Infectious Waste

Treatment of Infectious Waste

Steam Sterilization

Incineration

Chemical Disinfection

Emerging Treatment Technologies

Disposal of Treated Waste

Contingency Planning

Regulatory and Advisory Considerations

Staff Training

Topics for Review or Discussion

Appendix A: Bloodborne Pathogens Final Standard: Summary of KeyProvisions

Permissible Dose Concepts and Applications

The ALARA Concept

Pathways of Dispersion and Human Exposure

Physical Protection

Radiological Monitoring Programs

Regulatory Structures

Historical Development of Policies and Statutes

Statutory and Regulatory Framework

Department of Energy Management of Cleanup ProgramsHigh-Level Radioactive Waste Management

HLW Defined and Described

HLW Treatment and Disposal

Transuranic Waste Management

TRU Defined and Described

TRU Disposal

Low-Level Waste Management

LLW Defined and Classified

Treatment and Disposal of LLW

Mixed Waste Management

Mixed Waste Defined and Described

Uranium Mine and Mill Tailings Management

Tailings Defined, Described, and Characterized

Treatment and Control

Topics for Review or Discussion

Appendix A: Commercial and Low-Level Radioactive Waste DisposalOptions

Spills and Overfills

Compatibility of UST and Contents

Mobility of Leaked Hydrocarbon Fuels

Protection of Tanks and Piping from Corrosion

Protection by Sacrificial Anode

Protection by Impressed Current

Protection by Cladding or Dielectric Coating

Protection of Piping

Detection of Leaks from Underground Storage Tank SystemsDetection of Leaks in Pressurized Underground PipingDetection of Leaks in Underground Suction Piping

RCRA Subtitle I Regulations and Requirements

Background

Implementation Schedule

Requirements for New Petroleum UST Systems

Requirements for Existing UST Systems

Corrective Action Requirements

Financial Responsibility Requirements

The LUST Trust Fund

Closure of Underground Storage Tank Facilities

Permanent Closure

Exceptions to Permanent Closure

Temporary Closure

Compliance Summary

Compliance Status As of September 30, 1999

Topics for Review or Discussion

Other Physical Hazards

Hazardous Waste Operations and Emergency Response

Background

The HAZWOPER Summarized

Standards Applicable to Clean-up Sites

Standards Applicable to Treatment, Storage, and DisposalSites

Standards Applicable to Emergency Response TeamsOther Important Topics and Compliance Issues

Respirator Selection Criteria

Applicable Air Contaminant Standards

Work-Related Musculoskeletal Disorders

Bloodborne Pathogens Standard

Chemical Hazard Communication

Workplace Violence

The OSHA Unified Agenda

Appendix A: OSHA Workplace Standards That May Apply to HazardousWaste Sites

References

Glossary

The Hazardous Waste Perspective

OBJECTIVES

At completion of this chapter, the student should:

• Have gained a perspective on the evolution of hazardous waste problemsand approaches to management in the U.S and other industrialized nations

• Understand the kinds of hazardous waste management/mismanagementpractices that create negative health, environmental, economic, and socialimpacts and the nature of those impacts

• Have overview familiarity with the federal statutes and legal mechanismsthat have been directed toward governmental control of hazardous wastes,why they succeeded or failed, and how they relate to present-day RCRAand CERCLA

• Be similarly familiar with political and administrative approaches to ernmental control of hazardous waste, the successes and failures, andsome cause-and-effect considerations

or unfortunately, that is the nature of the practice of hazardous waste management

In recent years it has become a highly complex mix of the life and natural sciences;several fields of engineering and technology; epidemiology, toxicology, and preven-tative medicine; industrial hygiene; administration; law; and public relations, to name

a few As this is written, it is currently poised to become even more complex in theembodiment and use of new technologies It goes without saying that a single coursecannot deal with any of the associated topics in any detail However, the studentshould gain from this book sufficient understanding of the field to assist in makingdecisions regarding the field of study and in organizing those studies

The intent is also to provide an overview of “generic” hazardous waste agement and to then relate that understanding to the basic federal waste management1

man-L1533_frame_C01 Page 1 Tuesday, May 1, 2001 12:23 PM

law — the Resource Conservation and Recovery Act (RCRA) as amended Such anoverview must also include an introduction to the Comprehensive EnvironmentalResponse, Compensation, and Liability Act (CERCLA) or “Superfund” as it pertains

to site remediation and other environmental, occupational health and safety, andhazardous materials transportation statutes

In reality, it is difficult to separate “generic” hazardous waste management tice from RCRA requirements since the structure and format of this very compre-hensive and complex law so completely define the practice in the U.S and territories.Nevertheless, we will attempt to begin each chapter with a description of the subject

prac-or activity, followed by a summary of accepted practice, and conclude with theapplication of RCRA, CERCLA, and the other related statutes and regulations.The first chapter provides some historical background, some of it anecdotal, toportray the kinds of events, reactions, policies, and outcomes that helped to shapethe original RCRA, the amendments that have followed, and the practice of hazard-ous waste management

Among students of environmental management in the U.S., it is generally postulatedthat the beginnings of the nation’s effort to gain control of hazardous wastes beganwith (1) the Love Canal episode and (2) the discovery that the circle of environmentallaws (Clean Water Act [CWA], Clean Air Act [CAA], Toxic Substances Control Act[TSCA], Safe Drinking Water Act [SDWA]), enacted since the beginning of the

“Environmental Decade” (1970–1980), required closure by the enactment of a ardous waste control measure

haz-Love Canal, a water conveyance originally excavated for a hydroelectric project

in Niagara Falls, New York, was used by Hooker Chemical Company as a dumpsite for nearly 22,000 tons of waste chemicals Hooker closed and capped thesite in 1952, and in 1953 the City of Niagara Falls pressured Hooker to sell thecanal land, to the city, for a school site Hooker filed disclaimers, citing thepossible dangers of building over the landfill, but the school board and the citywere determined to have the site After threats of an eminent domain proceeding,Hooker sold the land to the city for $1.1

The site was developed and a school and homes were built thereon In 1978,the site was declared to be a public environmental emergency because hazardouswastes were seeping into the basements of the houses Nearly 900 families wereevacuated After years of legal wrangling, Occidental Petroleum Corporation,the parent company of Hooker, recently agreed to pay $98 million to the state

of New York to cover some of the cleanup costs and will assume responsibilityfor monitoring the remaining cleanup operations In 1994, a federal courtrejected the state’s claim for $250 million in punitive damages against Occi-

1 For a more detailed account of the Love Canal episode, see: Wentz (1989), p 306ff.

dental, but the company faced additional lawsuits by the federal government,the City of Niagara Falls, and hundreds of former residents who contended thattheir health problems resulted from toxic materials in the area A recently signedconsent decree filed with the U.S District Court for Western New York (U.S.

ends all pending federal litigation related to the site A few families are movingback into their homes or into the area

It is correct that the Love Canal horror galvanized public opinion and stimulatedmuch regulatory activity by governments (federal, state, and local) However, haz-ardous waste horror stories were emerging before Love Canal became a householdword, and the frequency and intensity increased on a near-daily basis Following theLove Canal disclosures, the U.S Environmental Protection Agency (EPA) and othersmounted studies which determined that more than 750,000 generators had depositedalmost 60 million tons of hazardous waste in as many as 50,000 sites (Even theseseemingly shocking numbers did not adequately describe the problem.) At that time(1977), the EPA estimated that only 10% of the waste had been disposed of in anenvironmentally safe manner (Worobec 1986, p 12) (Figures 1.1 through 1.3)

Early Hazardous Waste Management

Other episodes shocked the nation and brought forth new and intensified efforts togain control of the problem In discussing a few of them here, we refer to them aspast practices, realizing full well that similar situations and practices can and docontinue to this time (Figure 1.4)

Inc (ESOI).)

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The ABM-Wade Site. The ABM-Wade site in Chester, Pennsylvania, was ical of dozens of sites throughout the industrialized areas of the nation During themid-1970s the operator accepted hazardous wastes; filled the former factory buildingand pipe tunnels with drums of hazardous waste; filled discarded tank trailers withhazardous waste and parked them on the site; and when aboveground space wasfilled, underground storage tanks and trenches were filled with wastes.

Inc (ESOI).)

Pittsburgh, VA.)

In February 1978, the site burned Nearby residents were endangered by clouds

of toxic air pollutants, by the proximate natural gas storage tanks, and by inated run-off to the Delaware River (Figures 1.5 through 1.9) The site was reme-diated by a 10-year, $3 million Superfund project (see Chapter 11)

The Hardeman County Landfill. In Hardeman County, Tennessee, 40 familiesnear a rural landfill drank from wells polluted with such pesticides as endrin, dieldrin,aldrin, and heptachlor The Velsicol Chemical Company had used a neighboring300-acre site from 1964 to 1972 for shallow burial of 300,000 55-gal drums ofpesticide production residues Residents complained of a wide variety of ailmentsincluding liver and urinary tract problems, dizziness, nausea, and rashes (Council

Pro-tection Agency.)

Pro-tection Agency.)

The LaBounty Dump. Salsbury Laboratories, a major manufacturer of nary pharmaceuticals, is located in the small northern Iowa community of CharlesCity From 1953 until December 1977, Salsbury disposed of 6.4 million cubic feet

veteri-of arsenical sludge and organic chemical wastes in the LaBounty Dump along theCedar River (Figure 1.10) The Cedar River flows southeasterly through much ofthe state (Figure 1.11) Wells in the river alluvium supply domestic water to morethan 300,000 users along its course The Iowa Department of Environmental Quality

leached from the dump to the underlying groundwater and to the Cedar River TheIowa DEQ issued an executive order requiring Salsbury to remove all hazardouswastes and contaminated materials from the LaBounty site, but Salsbury convincedthe courts that the cleanup costs would exceed the company’s net worth, and the

U.S Environmental Protection Agency.)

Environmental Protection Agency.)

• Wind and surface water dispersal of the tailings materials and the trolled release of radon from the tailings piles

uncon-• Seepage of contaminated liquids into soils and groundwater from severalareas in the mill complex and waste disposal areas

• Concentrations of large quantities of wastes in locations that pose a risk

to public health and the environment

Prior to remediation, soils in the vicinity of the mill contained elevated levels ofheavy metals and radionuclides The San Miguel River, a tributary to the DoloresRiver, the Colorado River, and Lake Powell, was contaminated with radium 226.For nearly two decades, process wastewaters were discharged to seepage pondsscooped in the alluvium of the San Miguel (Figure 1.12) Contaminated groundwaterfrom the tailings area emerged from the walls of the San Miguel Canyon (Figure1.13) and continued subsurface movement toward the river

The site was listed on the National Priorities List (NPL)2 in 1986, but the massivecleanup was conducted under a consent decree in the U.S District Court for the

Envi-ronmental Protection Agency.)

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