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Hazardous Waste Management, 2nd ed.

Instructors Manual

Chapter 1: Hazardous Waste

CHAPTER 1 HAZARDOUS WASTE


Supplemental Questions: The opening quote is by Rachel Carson. Who was Rachel Carson? Rachel Louise Carson, 1907-64, was an American marine biologist. Her book Silent Spring (1962) is a seminal work in the environmental movement in the U.S. The book is discussed briefly under DDT on p. 4 of the textbook. She wrote several other popular works including The Sea Around Us (1951) and The Edge of the Sea (1954). What is the fundamental objective of hazardous waste management? To protect human health and the environment. What is the projected cost of hazardous waste site cleanup in the U. S. by the year 2020? $966 billion to 1.7 trillion. (see The Hazardous Waste Consultant, May/June 1992, p. 2.6-2.9). These costs include CERCLA, RCRA corrective action, UST, DOD, DOE and state and private cleanups. How many sites are currently on the Superfund National Priorities List (NPL) and how many additional potential sites are there? How does this compare to other countries? At the time of the 1st edtion, in the U. S. - on the NPL: 1232 as of the Federal Register, May 31, 1994; additional potential sites: 30,000. Germany: 90,000 to 100,000; Netherlands: 200,000; and U.K.: 50,000 to 100,000. Currently, for FY2000 there are 1509 sites including 218 deleted sites which wer either cleaned up or transferred to another agency. 1.1 What are some of the problems encountered in finding a working definition for hazardous waste? The term "hazardous waste" is by itself ambiguous. After the U.S. Congress passed the first hazardous waste law (RCRA) in 1976, which provided a general definition, it took four years before EPA published the regulations providing a legal definition of hazardous waste. Even once defined, it still had many exceptions. Defining hazardous waste first requires defining "waste". The definition used seems to imply solid waste which is not general enough when discussing hazardous waste because it must include solid, containerized gases, liquid wastes and sludges. Another problem is: what actually makes waste hazardous? A waste could be hazardous because of its explosive nature, its chemical reactivity, because it contains a toxic substance, or because of other reasons. In short, a hazardous waste could be any waste that poses a threat to human health or the environment. [Note: See sec. 1-l; Also see Chap. 2 pp. 44, 49 & 66 and Chap. 14, p. 839] 1-2. Is the form (e.g., solid, sludge, liquid, or gas) of a waste important in deciding if it is hazardous? The form is not important from a strictly legal sense because it does not provide any information about the character of a waste that cause it to be harmful to human health or the environment. As discussed in
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Hazardous Waste Management, 2nd ed. Instructors Manual

Chapter 1: Hazardous Waste

Chaps 4 and 14, form is important in determining the mobility of waste constituents, one of the factors in determining risk. [See also p. 2] 1-3. What is the purpose of grouping the different wastes according to characteristics (e.g., toxic) in classification lists? What are some of the problems with coding systems such as these? Grouping different wastes in inclusive classification lists according to their characteristics enables the government regulatory agencies to keep track of wastes which are hazardous. Once on a list, the waste is then regulated as a hazardous waste by the government. However, problems with this system arrive due to the limitations in having a listing which basically disregard the differences among wastes, including degree of hazard. Once considered hazardous, each waste in that classification is covered by the same regulatory procedures. Also, when coding a waste, the classification system doesn't consider the concentration of the constituents or other important characteristics of the particular waste. This information is imperative when determining the ability to treat the waste or determining the fate of the waste if released. 1-4. Why is the generation of hazardous waste not only a result of large-scale industry? What are some other sources? Large-scale industry is the largest contributor to the generation of hazardous waste. However, there are others as well. There are products manufactured through industry which are distributed throughout society, leading to the generation of hazardous waste by agricultural, commercial, and household activities. This includes even institutions such as universities and hospitals. Products in households, once thrown away, may become hazardous when they combine with other chemicals in the home. While it is true that other "categories" are a small percentage of the total mass, they may present a more serious problem in the future in that large industries have the infrastructure (trained staff, laboratories and TSDFs) in place to properly handle hazardous waste. Small quantity generators, local government and households often do not even understand the nature of the problem, much less have any ability to deal with hazardous waste. 1-5. Why is it necessary to include a section on ethics in this book? What are some of the ethical considerations regarding decisions engineers have to make when working in the hazardous waste management field? Give examples. It is not necessary! Most books on hazardous waste do not deal with ethics. However, the authors of this book felt that this was an extremely important topic. Some of the ethical considerations that engineers must include in their decisions can be seen from the Code of Ethics. [p.30] Perhaps most important here is the first of the Fundamental Canons: "Engineers shall hold paramount the safety, health and welfare of the public in the performance of their professional duties" "Paramount" has been interpreted to mean that concern for public health is more important than concerns about one's career, employer or client! It should be noted that these conflicts rarely arise in the hazardous waste field because no rational individual would consider harming someone's health in the interests of one's career, employer or client. However, it is possible to hypothesize a situation where short-sightedness on the part of a clients' representative may place an engineer in the position where improper or dangerous disposal of hazardous waste is being demanded in order to reduce costs. The response to this could be a presentation of the fact that this is a poor and short-sighted business decision. However, if this fails, the Code of Ethics may force

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the engineer to withdraw from the project and notify the management of the client firm that the action being taken is potentially dangerous. It must be noted that ethical questions of this type are rarely clear cut and normally extremely complex. Young engineers in particular are encouraged to seek the counsel of more experienced colleagues when they feel they are being confronted with an ethical dilemma. 1-6. In manufacturing a generic product, name five potential sources of hazardous -

waste generation.

In manufacturing a generic product, many of the examples included in Table 1-2, on page 15 could be possible sources of hazardous waste generation . This might include sludges from painting operations, spent filter cake, air pollution control dust, rinse water from chemical containers, or used cutting oils from machinery operations. Any location where chemicals are used present a potential source of hazardous waste generation. 1-7. Contrast Harding's Tragedy of the Commons with Leopold's Land Ethic. Give an example of how they apply to an environmental problem in the 1990s. Within the essay entitled "Tragedy of the Commons", Harding explains the need for laws in order to conserve within our environment. He explains this need by associating it to common grazing grounds for cattle and that every farmer maximizes the number of animals in the pasture thus destroying the land. In Leopold's discussion of environmental ethics entitled "The Land Ethic", he describes how the conservation of the environment is important even when there is no monetary benefit involved. One possible example of how these two concepts might apply to a hazardous waste problem in the 1990's is the clean up of hazardous waste sites. We have reached the point of having numerous contaminated sites by a number of completely rational individual decisions (most of which were perfectly legal at the time) to dispose of wastes in a cost-effective manner that we now know to be wrong. Decision-makers in industry and government, and the public at large, wanted to provide a modern technological society, and the "commons" (the air and water) seemed to have an infinite capacity to adsorb the by-products. The land was not perceived to have an intrinsic value in itself. In fact, much of the lands that have become superfund sites were in private hands with the owners exercising their property rights by disposing of wastes. 1-8. Why does the definition on hazardous waste specifically exclude radioactive waste?

The U. S. definition of hazardous waste excludes radioactive waste because this waste is regulated separately under Federal law. To have two different, and at times conflicting, regulatory programs attempting to regulate the same material could prove to be chaotic. This is the current situation at U. S. Department of Energy facilities that have soil and ground water contaminated by "mixed wastes" (wastes that are radioactive and also meet one of the characteristics of hazardous waste). [Note to instructors: This material is not in the text] 1- 9. Contrast the incident at Minamata Bay with that Love Canal, noting similarities and differences. Similarities between the incidents at Minamata Bay and Love Canal include the fact that both communities were unknowingly poisoned from hazardous wastes contributed by chemical plants. Also, both events sparked awareness of the effects of environmental pollution. However, at Minamata Bay mercury was first released directly to the bay where it settled into sediments and then bioaccumulated in shellfish, whereas at Love Canal, the contaminants were disposed of in a landfill that later leaked,
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eventually the basements of homes via underground transport. In addition, the effects at Minamata Bay were of epidemic and tragic proportions. The effects on human health of Love Canal were gradual and not as apparent, and are still debatable. 1.10 Select an environmental controversy (e.g., proposed landfill, Superfund site, suspected contamination) and comment on progress (or lack thereof) since the landmark cases such as Love Canal. The Ciba Specialty Chemicals site at Toms River, New Jersey was listed as a Superfund Site in 1983. First, the site hosted a dye manufacturing plant, then an additives and plastic making business. As a result of waste disposal, that was legal at the time, groundwater at the Toms River Site was contaminated. As soon as the site was listed as a Superfund site, remediation began under the Environmental Protection Agency. Since that time, the first of a two-phase remediation effort has been completed. This first project was the installation of a full-scale pump-and-treat system. Currently, the second project is underway, which involves the areas at the site that are the sources of groundwater contamination. (www.epa.org) Clearly progress has been made since the enactment of the Superfund law. However, like most Superfund sites, remediation progress has been slow [Note: answers will vary from student to student] 1.11 As a result of changing methods in compiling data, the pie charts in Figure 1-1 use slightly different categories. From your assessment of the data presented, comment on the changes in the market for each of the categories (air quality, solid waste, etc.). Cite one possible explanation for each. This comparison is skewed because the first chart only incorporates consulting markets, while the second incorporates remediation markets. However, several points can be gleaned from the information. Hazardous waste encompasses 50% of the consulting market in 1991, while data from 1998 suggests that it only accounts for 36% of the total remediation consulting market. This could be due to changes in industrys handling of hazardous waste. With the cradle-to-grave approach, companies are ultimately held responsible for the waste at all times. Thus, companies spend time in their system to eliminate the amount of waste produced and the waste disposal process. This type of engineering deters from the remediation consulting as it takes place in the beginning of the waste cycle. The water quality consulting market, 36% of the total, was composed of both wastewater and water supply in the 1991 study, while in the 1998 study it was split into two catagories, representing 14% and 10% respectively. Water quality consulting may have had a higher percentage of the consulting market (Figure 1-1 a ) because it incorporated not only remediation but also new projects as well. Air quality and solid waste each accounted for 7% of the consulting market in 1991. However, in 1998, the two categories combined only explain 7% of the remediation market. Two possible reasons are 1) landfills have become increasingly more efficient in designing of new waste cells, and 2) due to the Clean Air Act, industries are not permitted to release contaminants into the air at such a concentration that would require future remediation. [Note: answers will vary from student to student] 1.12 Describe the impact advances in analytical chemistry have had on the hazardous waste management field.

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The advances of analytical chemistry in the late 1960s and early 1970s have enabled those in the environmental field to detect and measure contaminants at concentrations several orders of magnitude smaller than possible just a few years earlier. We can now detect toxic chemicals at concentrations below one part per billion (ppb). While in almost all cases, such low concentrations are unlikely to have any public health implications, the mere existence of "measurable" quantities of toxic materials in the environment often creates public demand to "do something". 1.13 In the United States, generators are responsible for hazardous waste they create from "cradle to grave." Explain what is meant by this phrase. The phrase "cradle to grave" means that a generator of hazardous waste is responsible for the waste from the time it is created until it is destroyed. In addition, even if the waste is treated and legally disposed, the generator is still responsible for the consequences should a release occur. This liability cannot be contracted to a third party (e.g. a disposal facility or transportation company). Since the company generating the waste remains responsible for it forever, industrial managers are very careful about who they select to transport and dispose of their hazardous waste. This is a significant change from the standard industrial practice prior to RCRA, where the selection of a waste management contractor would be made by a purchasing agent on the basis of lowest cost. [See also Chap. 2, pp. 48, 57 and 59) 1-14. What factors might explain the dramatic difference between the public's perception of the relative risk of hazardous waste sites and the opinions of an EPA expert panel (Table 1-1)? The factors that may explain the difference between public perception and the opinions of an EPA expert panel regarding the relative risk of hazardous waste sites include the non-technical views of the public and the strictly technical views of scientists. The public's perception will modify risk calculated in the strictest scientific sense. The public, because of these factors, may automatically deem something unacceptable no matter how small the risk may be. Some of these factors include: involuntarily encountered (contrast hazardous waste with the risk of smoking which is voluntarily assumed); little apparent benefit to the community; those situations which are uncontrollable or controlled by others; and, those situations having consequences that are unknown but perceived to be substantial. [See also Table 14-11, p. 893] 1-15. What are the four characteristics that make a waste hazardous in the United States? Can you suggest other characteristics that might be appropriate to such a listing? The four characteristics that make a waste hazardous in the U.S. are: corrosivity, ignitability, reactivity, and toxicity. Others which may be appropriate to such a listing could include ability to bioaccumulate, persistence, mobility, infectious nature, and radioactivity (See solution to problem 1-8). [Note: There is a discussion of how other countries define hazardous waste beginning on p. 74 in Chap. 2] 1-16. Explain why "degree of hazard" is not a factor in determining whether or not a waste is hazardous in the United States. "Degree of hazard" is not a factor in determining whether or not a waste is hazardous in the United States because it is a site-specific concept. In addition to the toxicity of individual contaminants, this term considers the concentration and the mobility of the each chemical. These vary for the same chemical from site to site. Therefore, using the "degree of hazard" concept at one site may designate a waste hazardous while at another site, it may not be in great enough concentration to present a danger. There are clear regulatory advantages to having a single clear definition of what is regulated, and degree of hazard considerations can be incorporated into decisions of how to manage the waste.

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1.17 Review the hazardous waste facilities plan for your state and prepare a one-page summary of the most serious problems. [Note: answers will vary from state to state, a brief example of Pennsylvania can be found below.] The goal of the Pennsylvania Hazardous Waste facilities Plan is to address the present and future needs for the treatment and disposal of hazardous waste in [the] Commonwealth. This plan provides information on existing facilities available for hazardous waste treatment and the types of facilities needed for proper management of waste. Also, information on pollution prevention is provided and the plan calls for generators to improve waste generating technology, promotion resource recovery over treatment and disposal. One crucial part of the plan is its role in the establishment of new hazardous waste management facilities. In cases where a Certificate of Public Necessity (CPN) is required the Environmental Quality Board is given the power by the plan to issue a CPT, regardless of local restrictions. A CPN will, however, only be issued based on the four criteria set in the plan. There are; 1) the extent to which the facility is in compliance with the Pennsylvania Hazardous waste Facilities Plan, 2) the impact of the proposed facility on adjacent populated areas and areas through which the waste is transported, 3) The impact on the municipality in which the facility will be located, including health, safety, cost and consistency with local planning and 4) the extend to which citizens have had and opportunity to participate in site selection, including the development of siting criteria, evaluation of alternate sites and technologies, and socioeconomic assessment.
1-18.

What are small quantity generators?

Small quantity generators are those hazardous waste generators who are exempt from biennial reporting requirements since they generate less than 1000 kilograms per month (approximately 13 tons per year). 1-19 . Review the summaries of generation in New Jersey and Pennsylvania (Table 1-3 and 1-4). Explain the differences between these two contiguous states that cause the differences in waste generated. Pennsylvania does not regulate used oil as a hazardous waste, while New Jersey does. New Jersey contains more chemical and petrochemical plants and thus the chemical products group and the petroleum group contribute the largest percentage of the state's manifested waste (25%). Pennsylvania, however, attributes 40% of its manifested waste to the primary metals industry alone since the state is famous for its steel industry. 1-20. Explain briefly the factors that might influence the amount of hazardous waste generated in a given year. One of the factors which may influence the amount of hazardous waste generated in a given year is the state of the economy. If many steel mills reduce production because of the economy, the amount of hazardous waste produced will decline, generally in direct proportion to the drop in production. Also, technology may have an effect on the amount of hazardous waste generated. A company may develop new processes to manufacture a product which prove to create less waste while also being cost effective. 1-21. What is household hazardous waste?

Household hazardous waste is that waste that is generated within the home. There are many household products manufactured that are fairly toxic such as paint thinner and cleaning products. In addition there are other products within a household which may not be directly hazardous, such as medicinal products (i.e.: hydrogen peroxide), but, when thrown away with other items, can react and become hazardous.
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1-22. List?

What is the National Priorities List (NPL), and how does it differ from the CERCLIS

The EPA is required, by the Superfund law, to produce a list that represents those contaminated sites that pose the greatest potential threat. This list is called the National Priorities List (NPL). The EPA also maintains a larger list, which includes suspected sites of contamination called the CERCLIS list. The EPA selects sites from the latter to determine those sites to be placed on the NPL. 1-23. Explain what is meant by the Product Life Cycle approach to environmental management. Why have many corporations adopted this proactive approach? The Product Life Cycle is a systematic approach to environmental management that examines both the environmental and health consequences of a product. Each stage of the product's life cycle from research & development through manufacturing and distribution to the final fate of the product after its' useful life is over is analyzed. The consequences which result are then addressed in an integrated decision-making process. Corporations have adopted this pro-active approach because it ensures the creation of environmentally sound products. In addition to this, there is often a reduction in the quantity of waste generated during production. [Note: A detailed description of Product Life Cycle Analysis may be found in Sec. 7-3] 1-24. Describe briefly the two general perspectives for dealing with ethical problems.

The two general perspectives for dealing with ethical problems include those focusing on the act and those focusing on the consequences of the act. Regarding the first of these two perspectives, one would be expected make decisions based upon the analysis of moral behavior and not deviate from them. This theory considers only the act and whether or not it is ethical, regardless of the consequences. The latter of these perspectives is sometimes referred to as utilitarianism and takes into account the consequences of the action and the pleasure and pain induced because of the action. Basically, the ethical decision is that which creates the greatest benefit to the greatest amount of people. 1-25. When it became known that a new process planned for a chemical plant was expected to produce a highly toxic waste, a plant environmental engineer wrote to the city newspaper expressing opposition to the action. Under what circumstances would the engineer's action be legal and/or ethical? [Note: Engineering ethics is an extremely complex area and this question should be used to promote class discussion. There is insufficient information in the stated question and the student will have to make a number of assumptions. The authors have observed that these discussions are more effective if the students come in with written answers to questions such as this] The question seems to imply that "bad faith" between the chemical company and the community. If this is in fact true, a plant environmental engineer would be well advised to attempt to convince plant management that they should be more forthcoming and present their plans to the public in a well designed public information program. In the U. S., under the "Community Right to Know" provisions of SARA (see p. 55), communities have a right to know not only what wastes will be generated, but also what chemicals are present on the plant site. Another inference that might be made from the problem statement is that there will be releases of hazardous waste and there will be potential public health implications associated with these releases. If this is the case, and the company intends to attempt to somehow keep this secret, the plant environmental engineer (and others in management) clearly have an ethical problem and may be in violation of criminal laws as well. (e.g. see the discussion of knowing endangerment on p. 48)
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Under "The Fundamental Cannons" in the Code of Ethics of Engineers, the first statement declares: "Engineers shall hold paramount the safety, health and welfare of the public in the performance of their professional duties." Therefore, a plant environmental engineer who has knowledge of a new process which will produce a highly toxic waste and put citizens at risk has first and foremost, the obligation to protect the public. Also, the code states, "Engineers shall issue public statements only in an objective and truthful manner." Writing to the city newspaper should be an absolutely last resort, after attempts to have the company deal with the matter correctly have failed. Under these conditions the plant engineer is putting his or her views out into the public forum in an objective manner and therefore, this action would appear to be ethical. [Note: An excellent 24 minute video tape is available to assist faculty with this type of discussion. The title is Gilbane Gold. It is produced by the National Institute for Engineering Ethics (NSPE), 1420 King Street, Alexandria, VA 22314 (Phone:703-684-2840)] 1.26 Discuss possible reasons for the difference between the United States and other selected countries with respect to the assessment and remediation of contaminated sites in the past. European countries, historically, have shown more concern for the environment than the U.S. This could be due to several reasons. First, land is very scarce in Europe, and communities treat it with great respect. Secondly, in countries such as France people are socialized to appreciate the environment through social norms and legislation. Due to these reasons, the amount of waste generated in these countries is minimized resulting in less of a need for remediation. Other differences between the U.S. and other countries can be found by comparing our current practices to those of come third world countries. Most either have no environmental laws or laws that are not enforced. Companies in these countries are not required to adhere to the same environmental standards, as they would be in the U.S. Due to this difference, assessment and remediation projects, both costly endeavors, are not as common in the U.S.

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