Hazardous Waste On Site

Once RCRA was passed in 1976, Congress no doubt believed most of the environmental problems with hazardous chemicals had been addressed. It wasn t until the discovery of Love Canal and other similar problems in the late 1970s that Congress realized there was a significant hole in its plan. 

Love Canal was built near Niagara Falls, New York, in the 1800s to link waterways. Although it was never completed, the canal, in the form of a half-mile ditch, remained until the Hooker Chemical Company purchased it in the early part of the twentieth century as a dumpsite for hazardous waste. Once full, the canal was covered and eventually wound up as the building site for a school with residential properties nearby. 

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Containers for hazardous wastes. On-site storage practices are a function of the types and amounts of hazardous wastes generated and the time period over which waste generation occurs. Usually when large quantities are generated, special facilities are used that have sufficient capacity to hold wastes accumulated over a period of... 

Hazardous waste (40 CFR Part 262). Facilities accumulating hazardous waste on site must label containers as Hamrdous Waste and include the accumulation start date. Label transport to meet DOT requirements. 

A facility is a limited-quantity generator if it produces less than 100 kilograms of hazardous waste per month. If, however, a limited-quantity generator stores more than 1,000 kilograms of hazardous waste on-site at any time, it becomes a small-quantity generator. A limited-quantity generator is not required to obtain an EPA identification number, but most licensed waste haulers will require an EPA identification number to ship the waste off-site. 

Hazardous waste may not be disposed of on-site unless a disposal permit has been obtained. Obtaining a permit to store, treat, or dispose of hazardous waste on site (40 CFR Part 270) can be costly and time consuming. 

Hazardous Waste Annual Report Forms must be submitted annually to the USEPA or state EPA (State of Kentucky, 1992, chap. 31). The annual reporting form includes information on all the hazardous waste generated and shipped during the report year. All facilities that treat, dispose, or recycle hazardous waste on-site must complete the form. Waste minimization activities must be identified on the form. 

Some form of training may be required to ensure that employees segregate hazardous and non-hazardous wastes on site. 

An LQG may accumulate hazardous waste on site for 90 days or less. Under temporary, unforeseen, and uncontrollable circumstances, this 90-day period may be extended for up to 30 days by the state or EPA on a case-by-case basis. 

Many but not all hazardous wastes can be disposed of on land in properly designed landfills. To minimize potentially adverse environmental effects from wastes deposited at hazardous-waste landfill sites, the U.S. Environmental Protection Agency (EPA) has developed specific regulations regarding the characteristics of wastes suitable for landfilling. These regulations (40 CFR 265) include a prohibition on the placement of ... 

Populations residing near hazardous waste disposal sites may be subject to higher levels of methyl parathion in environmental media (i.e., air, groundwater, soil) than those experienced by the general population. Methyl parathion has been identified in at least 16 of the 1,585 hazardous waste sites that have been proposed for inclusion on the EPA National Priorities List (NPL). However, the number of sites evaluated for methyl parathion is not known. As more sites are evaluated, the number of sites where methyl parathion has been detected may increase. 

Disposal The discharge, deposit, injection, dumping, spilling, leaking, or placing of any solid or hazardous waste on or in the land or water. A disposal facility is any site where hazardous waste is intentionally placed and where the waste will remain after a TSDF stops operation. 

Revegetation is a cost-effective method to stabilize the surface of hazardous waste disposal sites, especially when preceded by capping and grading. Revegetation decreases erosion by wind and water and contributes to the development of a naturally fertile and stable surface environment. It may be part of a long-term site reclamation project, or it may be used on a temporary or seasonal basis to stabilize intermediate cover surfaces at waste disposal sites. 

The means of transporting hazardous waste into the incinerator plant should be carefully considered. Routes of access should be selected to minimize accident (release) potential and to avoid residential and play areas if possible. For the remediation of Superfund sites, for which no over-the-road hauling is required, care is still needed to avoid spills and releases when transporting the wastes on-site. 

Endrin has also been shown to be absorbed after ingestion by humans (Coble et al. 1967 Curley et al. 1970 Kintz et al. 1992 Rowley et al. 1987 Runhaar et al. 1985 Waller et al. 1992 Weeks 1967) however, no studies were located on the rate or extent of absorption that occurs in orally exposed humans or animals. Exposure to endrin through ingestion of contaminated drinking water is not expected to be an important source of concern because the compound has only rarely been detected in drinking water (Schafer et al. 1969 Wnuk et al. 1987). Since endrin is tightly bound to soil particles, ingestion of endrin-contaminated soil, particularly by children, may be an important route of exposure near hazardous waste disposal sites that contain endrin. 

NCRP reiterates that the risk-based waste classification system developed in this Report does not, and cannot, obviate the need to establish waste acceptance criteria at each hazardous waste disposal site based on the characteristics of the site, the particular disposal technology, and characteristics of the wastes that are intended for disposal at the site. NCRP expects that most waste that would be assigned to a particular class will be acceptable for disposal using the associated type of disposal technology indicated in Figure 6.1. However, the disposal capabilities of particular sites and engineered systems can vary substantially and can depend on the waste characteristics. The primary function of any waste classification system is to facilitate development of cost-effective approaches to waste management and disposal and effective communication on waste matters (see Section 2.1.2). 

The use of an acceptable (barely tolerable) risk to classify nonexempt waste can be justified, in part, on the following grounds. Disposal facilities for exempt and low-hazard waste both are located near the ground surface, and many scenarios for inadvertent intrusion into municipal/industrial landfills for nonhazardous waste also would be credible occurrences at disposal sites for low-hazard waste. However, these types of scenarios should be less likely to occur at hazardous waste sites, compared with sites for disposal of nonhazardous waste, given the intention to maintain institutional control and records of past disposal activities for a considerable period of time after closure of hazardous waste sites and the possibility that societal memory of disposal activities will be retained long after institutional control is relinquished. Thus, the risk to future inadvertent intruders at dedicated hazardous waste disposal sites, taking into account the probability that exposures according to postulated scenarios would actually occur, should be comparable to the risk at disposal sites for nonhazardous waste. 

Facilities located at a considerable depth below the ground surface, such as mined cavities, are used in some countries (e.g., Germany) for disposal of hazardous chemical wastes, as well as low-level radioactive waste. However, the selection of a deep disposal system often is based on general land-use policies that prohibit disposal of hazardous wastes on or near the land surface, as well as a desire to protect public health and the environment, and no distinction is made between wastes that pose a lesser or greater hazard in selecting such disposal systems and in developing site-specific waste acceptance criteria. 

Okrent and Xing (1993) estimated the lifetime cancer risk to a future resident at a hazardous waste disposal site after loss of institutional control. The assumed exposure pathways involve consumption of contaminated fruits and vegetables, ingestion of contaminated soil, and dermal absorption. The slope factors for each chemical that induces stochastic effects were obtained from the IRIS (1988) database and, thus, represent upper bounds (UCLs). The exposure duration was assumed to be 70 y. Based on these assumptions, the estimated lifetime cancer risk was 0.3, due almost entirely to arsenic. If the risk were reduced by a factor of 10, based on the assumption that UCLs of slope factors for chemicals that induce stochastic effects should be reduced by this amount in evaluating waste for classification as low-hazard (see Section 7.1.7.1), the estimated risk would be reduced to 0.03. Either of these results is greater than the assumed limit on acceptable risk of 10 3 (see Table 7.1). Thus, based on this analysis, the waste would be classified as high-hazard in the absence of perpetual institutional control to preclude permanent occupancy of a disposal site. 

The public and legislative debate which led up to the Enactment of the Comprehensive Environmental Response, Compensation, and Liability Act of 1980 ("Superfund") focused extensively on assessing the risks from old hazardous waste dump sites. Indeed, much of the controversy and difficulty in enacting the bill was a result of greatly differing perceptions about the risks posed by old dump sites and exposure to minimal levels of hazardous waste. 

Exposure Levels in Environmental Media. Limited, mostly outdated, data were available regarding the detection of acrolein in the environment. Information on exposure to acrolein in air in urban areas, rural areas, near hazardous waste disposal sites, as well as in water (specifically, drinking water supplied from groundwater downgradient from hazardous waste disposal sites and contaminated surface waters) and soil at waste disposal sites would be useful. Monitoring air and water over a 1-year period would provide some indication of seasonal variations. 

Composite data from the Comprehensive Emergency Response, Compensation, and Liability Act (CERCLA) monitoring program indicate that benzene was detected at a frequency of 11.2% in groundwater in the vicinity of 178 inactive hazardous waste disposal sites (Plumb 1987). Data from a 1980 national survey by the Council on Environmental Quality on groundwater and surface water contamination showed benzene concentrations in contaminated drinking water wells in New York, New... 

These provisions provide a tremendous impetus to hazardous waste generators to dispose of their waste on site under carefiilly controlled conditions. This concept of liability also burdens the generator with the threat of future costs as a result of someone else s improper actions. These values follow directly from our system of government, which was created to assure that individual citizens do not suffer loss of property and freedoms (health) by the actions of others. The need for a careful choice of a contractor to carry out waste management and disposal responsibilities is also highlighted by these provisions. 

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