Hazardous Waste Management

Volume 1 The Law of Toxics and Toxic Substances

George S. Dominguez, Kenneth G. Bartlett

• Publisher: CRC Press
• Year: 2022
• eBook ISBN: 9781000649864
• Topic: Technology & Engineering
• Subtopic: Biology
• Index: Technology & Engineering

First published in 1986: The Purpose of this book is to provide working managers with a comprehensive introduction to practical operational aspects of hazardous waste management and with an extremely important foundation in relevant laws, rules and regulations.

Chapter 1 HAZARDOUS WASTE MANAGEMENT

George S. Dominguez

TABLE OF CONTENTS

I. Introduction

II. The Hazardous Waste Problem

III. Major Areas of Consideration in Hazardous Waste Management

IV. Waste Characterization

V. Waste Treatment Options

VI. Waste Disposal Options

VII. Reuse, Recycle, Recovery

VIII. Low- and Non-Waste Technology

IX. Management Programs

X. Summary

I. INTRODUCTION

Literature on hazardous waste has grown enormously in recent years. There seems to have been an almost endless succession of books, articles, and reference materials, not to mention conferences, seminars, and a virtually endless stream of government publications dealing with various aspects of this timely subject. These, prodigious as they are themselves, do not include the media coverage of virtually every aspect of hazardous waste from considerations of public health and safety to elaborate and exhaustive editorials soundly and roundly criticizing industry for its past and present actions on the one hand and government for its lack of action on the other. Since the essential purpose of this guide book is to provide working managers with a comprehensive introduction to practical operational aspects of hazardous waste management and with an extremely important foundation in revelant laws, rules, and regulations, it is not our place nor intention to enter into the debate of the relevant responsibility or lack thereof of past or present actions of the private or public sectors. Rather our purpose is to concentrate on those aspects of hazardous waste management which we feel either have not been previously addressed, insufficiently examined, or most importantly not considered in an integrated fashion.

II. THE HAZARDOUS WASTE PROBLEM

Since so much has already been written about the nature and extent of the “hazardous waste problem”, there is little purpose served in attempting to restate the entirety nor the complexity of the problem; to a great extent it is, in fact, a self-evident problem. There are a few points, however, that do warrant mention since they help to place present actions and future activities and the potential for adequate waste management control techniques to be utilized in perspective:

1. The hazardous waste management problem is not new and in fact waste disposal problems have plagued mankind since introduction of even the most rudimentary attempts at manufacturing; numerous historical examples exist from the predawn of civilization as we know it to present times.
2. There is an obvious national as well as international dimension to the problem even though, unlike more conventional pollution problems such as air or water pollution, hazardous waste problems tend to be more localized since we are not dealing with the opportunity for wide-spread transboundary distribution phenomena that can occur in the air or water pollution situations. However, we are potentially dealing with ground and aquifer transfer situations and, therefore, while the extent of the transportation problem may not be great, it nevertheless cannot be totally discounted. In fact, one of our most serious problems can be ground water contamination which is not only difficult to measure adequately but difficult to predict, control, and obviously remedy once it has occurred. The other potential transfer situation of importance occurs when hazardous wastes are deliberately transferred from point of origin to point of disposal, hence a concern with spills during transport and with the public policy issues associated with the establishment of dump sites. Similarly, this transportation and disposal siting problem is international in scope since there have been numerous instances of countries generating hazardous waste and then transporting them to other nations for eventual disposal.
3. The problems with inadequately treated or inappropriate disposal of hazardous waste can, as we have all seen, take years if not generations to manifest themselves. Once manifested, remedial action is extremely expensive, time-consuming, and in some cases arguably impossible. The practical significance of this has to be emphasized as various hazardous waste management options such as reduction in waste generation, waste treatment, and finally appropriate disposal techniques are considered.
4. Identification and classification is important since it is the basis, upon which various restrictions might apply. In addition, it is, of course, equally if not more important because it provides an indication of the potential application of the various manufacturing techniques already mentioned.
5. Cost is undoubtedly a major consideration, either in system review, design, or management, to say nothing of actual capital and operating costs involved in actual treatment and disposal. However, as we have repeatedly seen in the media the costs of reclaiming a hazardous waste dump site, and the liability that now exists based on such status as RCRA and Superfund also impose external cost considerations that have to be taken into account when undertaking an analysis of the costs vs. benefits of various management and control options. Cost today, therefore, just like the various scientific and technical considerations as well as management options to be reviewed, has to be considered in its totality. We have to consider all aspects of cost — both institutional and extrinsic when considering the development of an effective and comprehensive waste management system. Also included in this calculus, as difficult as it may be, is that very important factor, namely, public attitude and response to improper waste management practices. These are reactions which, as we have seen, not only influence such decisions as the legislative adoption of laws like RCRA and Superfund but the actions of federal and state agencies in their implementation and enforcement actions. In addition, such public reactions can well effect the position of individual companies in the market place with consequences such as adverse effects on marketing of goods and services and even effects on stock values. All together, a new dimension of concern arises as technical managers must also take into account factors which historically have, been considered outside their traditional realms of activity. The logical outgrowth is the development of a team approach to hazardous waste management — a concept which we will be describing in greater detail later in this chapter as one management option available to assure full integration of all of those diverse organization needs in hazardous waste management decisions.

As important as all of these points are, perhaps the most important of all is the necessity to recognize two major realities that have a direct bearing on the entirety of the hazardous waste problem and of our opportunity for future remedies:

1. As has often been said, we are living in a highly industrialized technology-dependent society and on both a national and global scale, we are continuing to evolve into, if anything, an even more industrial and technology-dependent society. The benefits are obvious as we are surrounded daily by an unprecedented plethora of goods and services that are directly and indirectly the result of this industrialization and our technology-dependent society. One price that we must pay is waste generation. This is the first of the two major points that we must recognize if sound hazardous waste management programs are to be developed and applied. The principle is a simple one; namely, that as goods are produced, wastes are generated. While a great deal has already been written about so-called “low- and non-waste technology” and a great deal more will undoubtedly be written about this approach, it remains, at least for the moment, largely an unrealized goal and one which, while it holds great promise, will never totally solve the problem because it is unrealistic to believe that the application of such techniques can be universally applied to all manufacturing and processing situations. The first point, then, is that we cannot sustain production of industrial goods and the numerous manifest benefits that derive from them without waste generation.
2. 2. There is a basic misconception in the minds of many that hazardous waste generation is, if not solely, predominately the result of industrial manufacturing and processing operations. In fact, this is absolutely incorrect. Hazardous wastes are generated from a number of public and private sector sources, some quite obvious and some, despite the potential hazards they generate, often totally unrecognized. To put this important consideration into perspective is essential since it is not only illogical but extremely ineffectual to consider from a public policy or a technical viewpoint control measures that apply solely or predominately to the industrial sector while overlooking or only minimally addressing these others. Table 1 lists the other important generators of hazardous wastes from sources which must be considered in any complete assessment of hazardous waste generation and management. It is only by examining these other sources that the full magnitude of the hazardous waste generation and management problem can be understood and adequate management techniques developed and applied. In this series we will be examining each of these sources in greater detail.

   Table 1 PRIMARY SOURCES OF HAZARDOUS WASTES

   Industrial

   Chemical manufacturing

   Manufactured products

   Formulating

   Extractive industries

   Mining

   Oil and gas production

   Municipal

   Waste treatment facilities

   Power generation

   Hospital

   Infectious and biohazardous

   Reclamation

   Land and buildings

   Nuclear

   Agricultural

III. MAJOR AREAS OF CONSIDERATION IN HAZARDOUS WASTE MANAGEMENT

From the preceding brief introduction to the scope and magnitude of the hazardous waste problem, we can begin to appreciate that there are no simple solutions available. It has been and continues to be a problem that will require a concerted and sophisticated professional approach to effective prevention, control, and treatment to solve. In this context, then, we intend in this chapter to cover the major broad topics that have to considered in understanding the basic areas of concern and the various elements that have to be asked in developing and implementing an effective hazardous waste management system.

As previously mentioned, one of the difficulties of developing and employing such a system is the very fact that to be effective it must be approached on a systems basis rather than on the basis of examining and considering only discrete elements of the problem. For example, we can consider hazardous wastes either from a single source or in the more generic sense as consisting of a rather simple but nonetheless important linear progression of discrete elements which have been quite reasonably and realistically employed as the basis for structuring the application of our Resource Conservation and Recovery Act (RCRA); these are

• Generation
• Storage
• Treatment
• Disposal
• Transportation

Important and appropriate as these elements are, and if we consider the progression of individual or several wastes from a single source or from a generic category of sources, they do in fact make up the components of a system. In that sense, it would be appropriate, from the perspective of hazardous waste management regardless of categorical source of waste derivation, to consider these elements both individually and collectively — the latter in the systematic sense. Such an approach would mean that one would not only examine existing practices and programs in each of the four basic areas identified but also as each of these areas relates to the other and to the ultimate objectives of either eliminating, reducing, or controlling waste generation, and effective treatment and disposal of those wastes that are generated.

As important as such a system is, it is only one way of examining and establishing a systematic approach to hazardous wastes. The other, which is based more on an examination of managerial options, combined with appropriate consideration of scientific and technological feasibility, involves a systematic analysis of management and control options. In that instance, we would utilize the approach shown in Table 1.

Whichever approach is used — and others of course may be developed with equal utility and validity — the basic point is tha...

Table of contents

• Cover
• Half Title
• Title
• Copyright
• Original Title
• Original Copyright
• The Editors
• Contributors
• Table of Contents
• Chapter 1 Hazardous Waste Management
• Chapter 2 The Constitutional Framework of Hazardous Waste Legislaton
• Chapter 3 Treatment Options in Hazardous Waste Management — An Overview
• Chapter 4 From Cradle to Grave: The Legislative History of RCRA
• Chapter 5 Summary and Analysis of the Resource Conservation and Recovery Act of 1976 as Amended
• Chapter 6 The Hazardous Waste Management Program Under the Resource Conservation and Recovery Act
• Chapter 7 The Legal Development of Remedies of Hazardous Waste Victims — Common Law Remedies
• Chapter 8 The Legal Development of Remedies of Hazardous Waste Victims — Statutory Remedies
• Chapter 9 Economic Issues and Aspects of Hazardous Waste Management
• References
• Index