dards in most cases. All studies performed in response to Section 212 will be completed in time to serve as useful input to Congressional consideration of our legislative proposal. Section 1 INTRODUCTION The Congressional Mandate In 1970, Congress perceived hazardous waste storage and disposal to be a problem of national concern. Section 212 of the Resource Recovery Act of 1970 (P.L. 91-512-an amendment to P.L. 89-272), enacted on October 26, 1970, required that the U.S. Environmental Protection Agency (EPA) prepare a comprehensive report to Congress on storage and disposal of hazardous wastes. That section stated: "The Secretary* shall submit to the Congress no later than two years after the date of enactment of the Resource Recovery Act of 1970, a comprehensive report and plan for the creation of a system of national disposal sites for the storage and disposal of hazardous wastes, including radioactive, toxic chemical, biological, and other wastes which may endanger public health or welfare. Such report shall include: (1) a list of materials which should be subject to disposal at any such site; (2) current methods of disposal of such materials; (3) recommended methods of reduction, neutralization, recovery or disposal of such materials; (4) an inventory of possible sites including existing land or water disposal sites operated or licensed by Federal agencies; (5) an estimate of the cost of developing and maintaining sites including consideration of means for distributing the short- and long-term costs of operating such sites among the users thereof; and (6) such other information as may be appropriate." The EPA Response This document represents EPA's Report to the President and [p. 1] *The Secretary of Health, Education and Welfare; Reorganization Plan Number 3 of 1970 transferred authority to the Administrator, Environmental Protection Agency. † EPA requested and received a time extension for submission of this report until June 30, 1973, since appropriation of funds to implement the Resource Recovery Act of 1970 was delayed for 8 months after enactment. the Congress summarizing the Agency's investigations and recommendations concerning hazardous wastes in response to the Congressional mandate. All information required by the mandate is included in the report and its appendices. This report provides a definition of current status, issues and options. It does not purport to provide a complete solution to the hazardous waste management problem. Section 212 requires an evaluation of a system of national disposal sites (NDS) for the storage and disposal of hazardous wastes as a solution to the hazardous waste problem. To evaluate the NDS concept properly, it is necessary to view it in the context of the total problem. On probing the problem, EPA determined that several means of accomplishing the NDS objective exist. To provide the Congress with maximum flexibility of action, EPA elected to investigate and evaluate several alternative solutions. A series of interrelated contractor and in-house studies was undertaken for the specific purpose of complying with Section 212 of the Resource Recovery Act of 1970: The first study, upon which subsequent efforts were based, quantified the hazardous waste problem. From a thorough literature survey and contacts with various trade and technical associations, government agencies, and industry, a list of hazardous materials was compiled, and each candidate substance on this list was rated according to the nature and severity of its hazardous properties. In addition, volume and distribution data (both by geography and by industry groups) was gathered, and current hazardous waste handling and disposal practices were surveyed. It was found that the magnitude of the hazardous waste problem was larger than originally anticipated, and that current disposal practices are generally inadequate. • Next, a more detailed technical study on the properties of these materials and their treatment and disposal methods was conducted. A "profile report" was written on each listed substance summarizing its physical, chemical, and toxicological properties, its industrial uses, and the hazards associated with proper handling and disposal methods. Each "profile report" incorporated a critical evaluation of currently used and available technology for the handling, storage, transport, neutralization, detoxification, reuse, and disposal of the particular substance. Also, advanced methods of hazardous waste treatment were surveyed, and research and development needs were formulated. The study showed that treatment and disposal technology is available for most hazardous wastes. • A favorable public attitude is essential for the successful implementation of any nationwide hazardous waste management program. Therefore, a third study was undertaken to determine citizen awareness and attitudes regarding the hazardous waste problem, and reaction to the possibility of having a treatment and disposal facility located in the vicinity. The majority of citizens sampled were found to be in favor of regional processing facilities for hazardous wastes since such facilities would increase environmental protection and stimulate the economy of the region. 8 • A fourth study analyzed and compared alternative methods of hazardous waste management. It was concluded that there are three basic approaches: (a) process hazardous wastes "on-site," i.e., at the plant where they are generated; (b) process "off-site" at some regional facility (either public or private); (c) combine "on-site" pretreatment with "off-site" treatment and disposal. These basic alternatives were evaluated with respect to economics, risk, and legal and institutional issues. The study indicated that option (b) is preferable for most hazardous waste streams* and option (c) is preferable for dilute aqueous toxic metal wastes. • A fifth comprehensive study examined the feasibility of a system of national disposal sites (NDS) for hazardous wastes.10 Potential locations for regional processing and disposal sites were identified. Conceptual designs of hazardous waste treatment and disposal facilities were developed based on multi-component waste streams characteristic of industry. Capital and operational cost estimates were made, and funding and cost distribution mechanisms were examined. • Lastly, a strategy analysis was performed, based on information from the previous studies. It was concluded that a regulatory program is the best approach to the hazardous waste problem. The case for hazardous waste regulation is discussed in Section 3. Issues of implementation are evaluated in Section 4 and findings and recommendations are given in Section 5. A review of the hazardous waste disposal problem precedes these discussions. *In this report the term "waste stream" refers to mass flow in the engineering process sense, and not necessarily to a liquid stream. Section 2 IDENTIFICATION AND DISCUSSION OF THE PROBLEM Inadequate hazardous waste management has the potential of causing adverse public health and environmental impacts. These impacts are directly attributable to the acute (short range or immediate) or chronic (long range) effects of the associated hazardous compound or combination of compounds, and production quantities and distribution.11,12 Many cases document the imminent and long-term danger to man or his environment from improper disposal of such hazardous wastes. For example: • Several people in Minnesota were hospitalized in 1972 after drinking well water contaminated by an arsenic waste buried 30 years ago on nearby agricultural land. • Since 1953 an Iowa company has dumped several thousand cubic yards of arsenic-bearing wastes on a site located above an aquifer supplying a city's water. Arsenic content in nearby monitoring well samples has been measured as high as 175 ppm; the U.S. Public Health Service drinking water standards recommend an arsenic content less than 0.05 ppm. • In Colorado a number of farm cattle recently died of cyanide poisoning caused by indiscriminate disposal of cyanidebearing wastes at a dump site upstream. Additional case studies citing the effects of hazardous waste mismanagement are given in Appendix A. Discussed in this section are: the types, forms, sources, and quantities of hazardous waste; the current status of treatment and disposal technology; and the economic incentives bearing on hazardous waste treatment and disposal. The Nature of Hazardous Wastes The term "hazardous waste" means any waste or combination of wastes which pose a substantial present or potential hazard to human health or living organisms because such wastes are lethal, nondegradable, persistent in nature, biologically magnified, or otherwise cause or tend to cause detrimental cumulative effects.13 General categories of hazardous waste are toxic chemical, flammable, radioactive, explosive and biological. These wastes can take the form of solids, sludges, liquids, or gases. The sources of hazardous wastes are numerous and widely scattered throughout the nation. Sources consist of industry, the Federal Government (mainly the AEC and DOD), agriculture, and various institutions such as hospitals and laboratories. During this study waste streams containing hazardous compounds were identified and quantified by industrial source (see Appendix B). These waste streams were selected by utilizing a decision model (see Appendix C) 14 which is relatively unsophisticated compared to that required for standard setting purposes. Therefore, the hazardous compounds and waste streams cited in this report should be considered as illustrative and not necessarily those that should be regulated. From these data, the total quantity of non-radioactive hazardous waste streams generated by industrial sources in 1970 was estimated to be 10 million tons (9 million metric tons), or approximately 10 percent of the 110 million tons (100 million metric tons) of all wastes generated by industry annually.15 This quantity includes most industrial wastes generated from contractor operated government facilities. Approximately 70 percent of industrial hazardous wastes are generated in the mid Atlantic, Great Lakes, and Gulf Coast areas of the United States (see Table 2.1). About 90 percent by weight of industrial hazardous wastes are generated in the form of liquid streams of which approximately 40 percent are inorganic, and 60 percent are organic materials. Representative hazardous waste substances have been cross-indexed by industrial sources in Figure 2.1. It is important to recognize that these hazardous substances are constituents of waste streams, and it is these waste streams which require treatment, storage, and disposal. Sources of radioactive wastes are: nuclear power generation and fuel reprocessing facilities; private sources, such as medical, R&D, and industrial laboratories; and government sources (AEC and DOD). Quantities of radioactive wastes generated in 1970 from the first two sources have been identified in Table 2.2. Only a limited amount of information is available on source material, special nuclear material or by-product materials from government operations. Such information is related to weapons production and is therefore classified. Disposal of uranium mill tailings represents a unique problem similar in magnitude to the disposal of all industrial hazardous wastes. Several Federal agencies are working on the problem at present; a satisfactory disposal or recovery method has not yet been defined. Aside from uranium mill tailings, the quantity of radioactive wastes associated with the commercial nuclear electric power industry and other private sources is estimated to be approximately 24,000 tons (22,000 metric tons) per year at present, or |